United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-91/165
June 1991
Superfund
Record of Decision
Pagel's Pit, IL
-------
50272-101
REPORT DOCUMENTATION 11. REPORTNO. . 1 ~ So A8dpIenI'. Acc8uIon No.
PAGE EPA/ROD/R05-91/165
4. TIt8 8nd 8ubtIII8 5. Report 0.18
SUPERFUND RECORD OF DECISION 06/28/91
Pagel's Pit, IL &.
First Remedial Action
7. Aulhor(.) B. Perfonnlng Organization Rept. No.
.. PiIrfonning Org8lnlza1lon NIIm8 8nd ~ 10. ProjectlTulllWOIII Unit No.
11. Contraet(C) or Gr.nt(G) No.
(C)
(G)
1~ 8poI8DrIng Org8lllullon NIIm8 8nd ~ 1 So Type of Report . P8r1od CoV8l'8d
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. SuppIemenWy No..
1&. Ab81r.c1 (LJm1: 200 _rd8)
The 100-acre Pagel's Pit site is an active sanitary landfill facility in a
predominantly rural area of Winnebago County, Illinois. Surrounding land use is
mixed agricultural, rural res.idential, commercial, and industrial. The site is
bounded on the west by Killbuck Creek. Another Superfund site, Acme Solvent
Reclaiming, Inc., is located east and upgradient of Pagel's Pit. The Acme Solvent
site has been shown to have contaminated the ground water in the downgradient
direction. The landfill at the Pagel's Pit site is a former sand and gravel quarry
with a sealed asphalt liner that covers about 47 acres. The landfill, which began
operating in 1972, accepted primarily municipal waste, sewage sludge, and limited
amounts of Illinois special wastes. Beginning in 1980, a network of gas extraction
wells was installed to remove landfill gas that is. generated by the wastes. Gas
collected from the wells is used as a fuel source for a sludge drying operation.
Some of these wells also are used for leachate collection along with the manholes
installed in the landfill. In 1990, it was estimated that the landfill contained
about 4,700,000 cubic yards of waste and had 5 to 7 years of operating capacity
remaining. It has. been determined that the landfill has caused contamination of the
(See Attached Page)
17. Doc:um8nt An8Jy8I8 L DMcrIpIo..
Record of Decision - Pagel's Pit, IL'
First Remedial Action
Contaminated Media: gw
Key Contaminants: VOCs (1,2-dichloroethene, vinyl chloride, xylenes), metals
b. IcI8ntill8r8lep...End8d T- (arsenic, barium, manganese, thallium, zinc)
Co COBA 11 FleldlGrcql
18. Avllllblity 9t8I8m8nt 1.. SeC&8'IIy ca... (ThI. Report) 21. No. of PllII88
None 72
20. SeC&8'IIy ca... (1111. PllII8) n PrIce
Nnnp.
(888 ANSl-Z38.18)
s.. llultucll- on "--
(FOI'III8Ify ~)
D8p8rtment of Co-
-------
EPA/ROD/R05-91/165
Pagel's Pit, IL
First Remedial Action
Abstract (Continued)
ground water. This Record of Decision (ROD) addresses the landfill wastes and
contaminated ground water at the downgradient side of the site as Operable Unit 1 (OU1).
A future ROD will address ground water contamination in the southeast corner of the site
that is undergoing further study. The primary contaminants of concern affecting the
ground water are VOCs including 1,2-dichloroethene and vinyl chloride; and metals
including arsenic, barium, manganese, thallium and zinc.
The selected remedial action for this site includes constructing a sanitary landfill
cover for the waste disposal area; pumping ground water along the west side of the site;
removing inorganics by treating with ion- exchange or coagulation/flocculation, if
necessary, prior to onsite treatment using carbon adsorption or air stripping, followed
by carbon polishing of the treated water, with onsite discharge to surface water;
removing spent carbon offsite for regeneration or disposal; extracting and treating
leachate offsite at a publicly owned treatment works (POTW); extracting landfill gas and
using the gas for fuel, or flaring the gas; monitoring ground water, leachate, and air;
maintaining all remedial action components; and implementing institutional controls
including deed restrictions. The estimated present worth cost for this remedial action
is $9,800,000 or $11,000,000, which includes O&M costs of $310,000 or $248,000 for 30
years, depending on the process selected.
PERFORMANCE STANDARDS OR GOALS: Ground water goals are based on currently promulgated
MCLs or non-zero MCLGs, except for arsenic and 1,1,-dichloroethene, or a risk level of
10-5 or an HI=1 for contaminants without MCLs. Chemical-specific goals were not
provided.
-------
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Paqel's pit Site
Winnebaqo County, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Paqel's Pit site in Winnebaqo County, Illinois, which was
chosen in accordance with the Comprehensive Environmental
Response, compensation, and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
(hereinafter CERCLA), and, to the extent practicable, the
National Oil and Hazardous Substances Pollution continqency Plan
(NCP). 'This decision is based on the administrative record file
for this site. '
Althouqh the State of Illinois has aqreed in principle that the
remedy would address contamination at the site, it does not
concur with this 'decision. The State has concerns over their
possible loss of some control over the State permitted solid
waste landfill.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementinq the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endanqerment to public health, welfare,
or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This remedy is the first of potentially two operable units at
the site. It provides for interception of contaminated
qroundwater for the purpose of preventinq it from leavinq the
site; use of contaminated qroundwater as a water supply posed
the risk identified at the site that exceeded criteria used by
the United States Environmental Protection Aqency (USEPA). It
also addresses the wastes contained at this operatinq sanitary
landfill. The qrobndwater will be treated, the wastes will be
contained.
The second operable unit will address contaminated qroundwater
located primarily on the paqel' s Pit site in the southeast
corner. The potentially responsible parties (PRPs) who have
done the remedial investiqation for the Paqel'sPit site contend
that another National Priorities List site, upqradient of the
--paqe 1--
Plld'. Pit Sile, DcA:l&ralioa (or 1he Record 01 Dcciliaa
.
-------
'J
Pagel's Pit site, may contribute to this contamination.
The major components of the selected remedy include:
a sanitary landfill cover for the waste disposal area;
groundwater extraction along the west side of the site;
on-site groundwater treatment by carbon adsorption or air
stripping following pretreatment with a solids filter, with
the treated water being discharged to surface water;
removal of inorganics by treatment, if necessary, prior to
carbon adsorption or air stripping; .
leachate extraction and transfer to the local publicly
owned treatment works for.treatment; .
gas extraction and the use of the gas for fuel or the
flaring of the gas;
deed restr~ctions; and
site monitoring and maintenance of all remedial action
components.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The remedy utilizes
permanent solutions and alternative treatment or resource
recovery technologies, to the maximum extent practicable, for
this site. The large size of the landfill and the apparent lack
of on-site hot spots representing major sources of contamination
thwart use of the statutory preference for a remedy requiring
permanent treatment as a principal element. A principal threat,
which the Agency would expect to treat, has not been indicated.
Instead, as discussed in 40 CFR 300.430 (a) (1) (iii) (B), USEPA
expects to use engineering controls, such as containment, for
this operable unit because the wastes pose a relatively low-
level, long-term threat and because permanent treatment of the
entire landfill is impracticable. .
Because this remedy will result in hazardous substances
remaining on-site above health-based levels, a review will be
conducted within five years after commencement of remedial
action to ensure that the remedy continues to provide adequate
prot:;~:;~~1 human health an~enVironmen .
Date
Pqel'. Pit Site, Dcelaralioo for !be Record of DceiaiaD
--Page 2--
.
-------
RECORD OF DECISION SUMMARY
PAGEL'S PIT SITB
I.
SITE LOCATION AND DESCRIPTION
The Pagel's pit site (Winnebago Reclamation Landfill or WRL)
occupies about 100 acres on the west side of Lindenwood Road,
south of Baxter Road and about 5 miles south of Rockford,
Illinois (see Figure 1). The landfill has been in operation
since about 1972 and the operator has estimated that 5 to 7
years of capacity remain. Municipal refuse and sewage treatment
, plant sludge have been the primary wastes accepted at the site.
Illinois special wastes (industrial process wastes, pollution
control wastes, or hazardous wastes, except as determined
pursuant to the Illinois Environmental Protection Act) have also
been disposed of at the facility. '
The site is located in a predominately rural unincorporated
area. It ,is bounded on the west by Killbuck (or Kilbuck) Creek
and on the east by Lindenwood Road. Killbuck Creek, a perennial
stream, merges with the Kishwaukee River about 2.5 miles
northwest of the ,site. The Kishwaukee River merges with the
Rock River about 1.5 miles rnorthwest of the confluence of
Killbuck Creek and the Kishwaukee River. The site is located on
a topographic high between Killbuck Creek to the west and
unnamed intermittent streams to the north and the south. Land
use around the site is a mix of agricultural, rural residential,
commercial, and industrial.
The topography surrounding the landfill area is relatively flat
to gently rolling. The ground surface elevation is
approximately 706 feet mean sea level (MSL) at Killbuck Creek.
The landfill lies outside of the 100-Year floodplain of Killbuck
Creek and is not within any designated wetland area. A small
jurisdictional wetland area, rated low in'quality because of its
artificial nature, has been delineated south of the landfill.
Although an inventory of terrestrial plant and animal species
has not been performed, the site is not known to be inhabited by
endangered or threatened species.
Access to that part of the site closest to Lindenwood Road is
restricted by a chain link fence. Access to the rest of the
site is restricted by other fencing and the topography, which
includes steep slopes and heavily wooded areas.
The surficial unconsolidated deposits in the area of the site
are predominantly glacial drift ranging from a thin mantle over
the dolomite in the bedrock uplands to the east of the site to
greater than 70 feet in the bedrock valley west of the site.
--Page 1--
PileI'. Pit Sile. Record of Decisioa SIImmary
.
-------
The unconsolidated deposits are predominantly sand and gravel
underneath and north of the site with a silty clay to the south
of the site. The underlying bedrock surface is highly variable.
A bedrock map, based on available data, is shown in Figure 2.
The dolomite bedrock is generally fractured but the intensity is
variable. Chert layers or nodules were commonly noted on boring
logs as were vugs (void spaces), but cavernous zones were not
reported.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
.
The landfill is located at a former sand and gravel quarry. It
has been sequentially constructed and filled in several
sections. Development has generally occurred in an east to west
direction, first in the southern half and then in the northern
half. The base 'of the landfill is now complete and the landfill
wastes cover approximately 47 acres. The landfill liner was
constructed by grading and compacting the base and side walls of
the landfill. Asphaltic concrete was installed over the sides
and floor and compacted, resulting in a two inch thick layer.
The surface of the asphalt was sealed with a cationic coal tar
sealer. This sealed asphalt liner was covered with eight inches
of san~. A network of perfo~ated pipes was installed in the
sand on the sloping base. The pipes were connected to manholes
in which the liquid that drains from the wastes (leachate)
collects. The leachate is pumped from the, manholes to a
leachate pond located on top of the landfill. The leachate is
aerated in the pond and periodically trucked to, the wastewater
treatment plant in Rockford.
Wastes to be disposed of in the landfill enter through the gate
where there is a scale. The hauler takes the wastes 'to the
working face of the landfill where they are unloaded. Since
1985, however~ sewage sludge has first been taken to the on-site
sludge drying plant where it is dried before being placed in the
landfill. The operator at the working face compacts the wastes
into the active section of the landfill. A six-inch cover is
applied over the wastes daily; this generally ,consists of sand
and clay with some gravel. When an area has been filled to an
intermediate elevation (the area will not be receiving wastes
for sixty days and the fina~ permitted elevation has not been
reached), a compacted layer of additional suitable material is
placed on the surface. Much of the present landfill is covered
with this intermediate cover. Further filling of the landfill
is expected to bring the western end of the landfill to the
,elevation of the eastern part, which is at about 790 feet MSL.
Then most of the surface will have additional wastes placed upon
it and the final top grade of the central portion of the
landfill will be brought to 820 feet MSL. At that time, the
landfill will have reached its capacity, which is estimated at
P8&el'. Pit Sile. R~ord of DeciaiOll Summary
--Page 2--
.
-------
about 6 million cubic yards of wastes; it has been estimated
that the landfill contained about 4.7 million cubic yards of
wastes in April 1990. The proper side slopes will be maintained
with the final filling. .
Around 1980, landfill gas, consisting primarily of methane and
carbon dioxide, was discovered to be escaping from the landfill
near Lindenwood Road. Five gas extraction wells were installed
in the southeast corner of the landfill. A few months later,
four additional wells were installed in the northeast corner.
These. wells were connected to a flare, where the gas was burned.
In 1981, it was learned that landfill gas was still escaping to
the northeast of the landfill. FOllowing this determination,
the gas extraction system's operation and maintenance were
upgraded. In 1984, these wells were replaced by a network of 70
wells located in the eastern, non-active portion of the.
landfill. The gas is collected from the wells through the use
of blowers and a system of header pipes and is used as a fuel
source in the sludge drying operation. In November 1988, 21
additional wells were installed in the central section of the
landfill and connected to the system. The gas extraction wells
are also used for the removal of leachate from the landfill.
.When used for this purpose, a gas extraction .well is
disconnected from the system and a portable pump is placed in
the well. The pump transfers the leachate to the leachate pond.
Because the nearby groundwater was found to be contaminated with
arsenic, cadmium, and bis (2-ethylhexyl) phthalate, the site was
proposed for inclusion on the U. S. Environmental Protection
Agency's (USEPA's) National Priorities List (NPL) in October
1984. The NPL is the list of uncontrolled hazardous substance
releases in the united States that are priorities for long-term
remedial evaluation and response. The site was added to the NPL
in June 1986.
The USEPA and several of the potentially responsible parties
(PRPs) for this site reached agreement embodied in an
Administrative Order. by Consent, with an effective date of
October 16, 1986. This. Order requires the Respondents to
conduct a remedial investigation (RI) and a feasibility study
(FS) at the site. Portions of these studies were carried out by
Warzyn Inc., and the reports for the RI and the FS for the work
that has been done were submitted in March 1991. At least one
additional study is planned.
The Acme Solvent Reclaiming, Inc. site (Acme Solvent site) is
located east of the Pagel's Pit site (see Figure 1). The Acme
Solvent site was proposed for the NPL in December 1982 and was
placed on this list in September 1983.
--Page 3--
Pilei" Pit SiIe, Record of D«ilioa Summary
.
-------
III.
COMMUNITY RELATIONS ACTIVITIES
Community relations activities for the Pagel's Pit site
been conducted for a number of years, at least since 1987
several fact sheets were issued and the Community Relations
was released. In the early years, community relations for
site were combined with those for t~e Acme Solvent site.
A Proposed Plan was released to the public on April 16, 1991,
which presented a number of alternatives as possible remedies
for the problems that had been identified at the Pagel's Pit
site and informed the public of USEPA's and IEPA's preferred
remedy. It also informed the public that the reports for the RI
and the FS and the other documents comprising the administrative
record were available for review at the information repository.
located at the Rockford Public Library and at the offices of
USEPA, Region V, in Chicago. The Administrative Record Index is
included here as Appendix A. A public comment period was held
from April 16, 1991 through May 16, 1991, . and a public meeting
was held on April 25, 1991. At this meeting representatives. of
USEPA and IEPA discussed the proposed alternatives for
remediating the site, answered questions about the site and. the
problems there, and were prepared to receive verbal comments.
A notice of the availability of the Proposed Plan and an
announcement of the public comment period and the public meeting
was published in the Rockford Sunday Reaister star on April 14,
1991. . .
have
when
Plan
this
A response to the comments received during the comment period is
contained in the Responsive Summary which is included as part of
this Record of Decision as Appendix B.
IV.
SCOPE AND ROLE OP RESPONSE ACTION
This Record of Decision addresses the first of potentially two
response actions at the Pagel's Pit site. . The selected remedial
action that is described in this ROD addresses the wastes that
have been disposed of at the site and the contaminated
groundwater at the downgradient side of the site. This remedial
action does not address the groundwater contamination that has
been found in the southeast corner of the site.
The second response action at the site will address this
southeast corner of the. site. Further studies will be
undertaken to address the contamination there. .
No principal threat has been found at the site. The response
action for this site includes containing low level threats. No
documentation or physical evidence has been found to indicate
the presence and approximate locations of hot spots.
Pllcl', Pi\ Site, Record of ~iJioa Summary
--Page 4--
.
-------
v.
SITE CHARACTERISTICS
During the remedial investigation for the Pagel's Pit site, the
areas on and around both the Acme Solvent site and the Pagel's
Pit site were studied. Additional monitoring wells were
installed; groundwater from the shallow aquifer was sampled and
analyzed at these wells and many of the other wells in the areas
of the two sites; samples of leachate were analyzed; samples of
water and sediments from Killbuck Creek were analyzed; and the
air at the Pagel's Pit site was monitored. In addition, water
levels in many of the groundwater wells were measured several
times and permeability testing was performed at some of the
monitoring wells. It should be noted that there are no
monitoring wells that allow access to the groundwater directly
beneath the wastes.
There were four rounds of groundwater sampling; the first two
rounds consisted of samples from wells throughout the areas 'of
the two sites and the last two rounds consisted of samples from
the wells on or near the Pagel's Pit site. There were five
rounds of leachate sampling. During the first three rounds of
leachate sampling and' the first two rounds of groundwater
sampling, the samples were analyzed for volatile organic
compounds (VOCs) by gas chrom~tography (GC) with ten percent of
the samples being confirmed by gas chromatography/mass
spectroscopy (GC/MS) . Analytical difficulties (matrix
interference) were observed with these leachate samples, so the
final two rounds of leachate samples and the final two rounds of
groundwater samples were analyzed by GC/MS. Samples were not
analyzed for all parameters in all rounds.
The water table occurs in the fractured dolomite bedrock east of
and below the eastern quarter of the Pagel's Pit site. Under
the remaining three quarters of the site and west of the site,
the water table occurs in the unconsolidated materials.
Groundwater flow in the area of the two sites is generally from
east to west in the upper aquifer. Beneath the northern
portions of the site, groundwater flow is towards the northwest,
while beneath the southern portions of the site, the groundwater
flow is towards the southwest. North of the site, near Killbuck
Creek, groundwater flow appears to be west to southwest towards
the creek. South of the site, groundwater flow appears to be
west to southwest towards the creek. A potentiometric map using
. data obtained in June 1988 (the time during which Round 2
groundwater samples were taken) is shown in Figure 3. The
groundwater flow direction is perpendicular to a groundwater
contour line. (The groundwater elevations in parentheses on
this figure are generally for wells screened at elevations below
the water table.)
--Page 5--
Pilei'. Pit Site. Record of Dceiaioll Summary
.
-------
Leachate samples from the Pagel's Pit site were found to contain
relatively high levels of. chloride ion. Chloride ion was
selected by the remedial investigation contractor as an
indicator of areas of groundwater that may have been affected by
leachate from the landfill; chloride ion is generally recognized
as a conservative, non-reactive parameter in groundwater
systems. . Based on the presence of elevated chloride ion
concentrations in the groundwater, leachate from the landfill
has been shown to be affecting the groundwater. Figure 4 shows
the chloride results for Round 2 of groundwater sampling. Later
sampling rounds showed generally similar results, but the
chloride concentrations decreased in wells Pl, P4R, and Gl16A
and increased in wells P3R, Gl15, GllO, and Gl14; see Table 1.
As can be seen from the figure, the area found to contain
elevated chloride ion concentrations extended from about midway
along the north border of the landf ill (east of well B15R) ,
around the western end of the landfill, and along the south
border of the landfill to at least the southwest area (well
Gl15), and probably back into the southeast area of the site as
well. Generally, the affected area was relatively close to the
waste boundary, but a well on the other side of Killbuck Creek
(well Gl16A) also exhibited elevated chloride concentrations.
The depiction of the chloride concentrations with contour lines
under the wastes is speculative since no sampling of the
groundwater was done there; it is probable that the levels under
the wastes do not decrease to the extent shown.
VOCs were found in the shallow aquife.r on and in the vicinity of
both sites. They were found both inside and outside of the area
defined by elevated chloride concentrations. An example of the
distribution of these VOCs is shown by the results for
chlorinated ethenes, the dominant group of VOCs that were found
in the area, for Round 2 of sampling for the Pagel's Pit study
(Figure 5). The concentrations of chlorinated ethenes in wells
on the Pagel's Pit site and near the waste boundary are shown in
Table 1. Note that these chlorinated ethenes were found in a
well (well Gl16A) on the west side of Killbuck Creek. other
groups of VOCs that were found in the groundwater were
chlorinated ethanes, BETX (benzene, ethylbenzene, toluene, and
xylenes), and 1,2-dichloropropane. The detection of VOCs from
the easterly to the westerly direction was as follows: 'the VOCs
detected at well B4, the well in this study with the highest
contamination, included chlorinated ethenes, chlorinated
ethanes, 1,2-dichloropropane, chloromethane, and BETX; the VOCs
associated with wells near Lindenwood Road that are upgradient
of the landfill with respect to the general groundwater flow,
and not found at well B4, included chlorobenzene, trans-l,3-
dichloropropene, and dibromochloromethane; the VOCs detected
only in locations downgradient of the waste area included carbon
tetrachloride, bromoform, chloroform, bromodichloromethane, and
Pilei', Pit Site, Record or Dcc:i,iOll SII1IIIII8IY
--Page 6--
.
-------
acetone.
The investigation of the Pagel's Pit site and the recent
investigations at the Acme Solvent site revealed that the
highest concentrations of VOCs were found in several wells on
and close to the Acme Solvent site. The next highest
concentrations wE!re found in several wells in the southeast
corner of the Pagel's Pit site. However, a connection has not
been established between the contamination on and near the Acme
Solvent site and the contamination in the southeast corner of
the Pagel's Pit site since wells between these two areas either
contained no VOCs or contained VOCs at concentrations much lower
, than those in these two areas. Because a connection was not
established with the contamination at the Acme Solvent site and
because the southeast corner of the Pagel's Pit site is side-
gradient of the waste area, USEPA has decided to treat that area
of contamination separately from the rest of the groundwater"
contamination area. It will undergo further study before a
remedial action is chosen to address the contamination there.
None of the dichlorobenzenes were found in well B4 during the
first two rounds of sampling, when this well was sampled; no
other analyses were done for semi-volatile organic compounds
(SVOCs) in this well. The general group of SVOCs associated
with wells near Lindenwood Road included 1,2-dichlorobenzene and
1,4-dichlorobenzenei however, all but two of the detections of
the two dichlorobenzenes were in wells west of Lindenwood Road.
The SVOCs generally detected only in wells downgradient of the
waste area were bis(2-ethylhexyl)phthalate (there was one
detection near the road), 1,3-dichlorobenzene, acenaphthene, and
dibenzofuran. No pesticides or polychlorinated biphenyls (PCBs)
were detected in any of the groundwater samples during this RI.
The leachate samples qenerally contained BETX compounds at
higher concentrations than chlorinated compounds, whereas
groundwater samples generally showed the opposite. Some SVOCs
were detected in limited testinq of leachate samples. Some PCBs
and pesticides at low levels were also found in some leachate
samples. Besides having higher than typical chloride
concentrations, the leachate also had higher than typical sodium
concentrations.
The groundwater which contained elevated chloride concentrations
also tended to contain elevated sodium, potassium, magnesium,
manganese, and iron. other constituents sometimes associated
with the same groundwater area included total phenolics,
cyanide, arsenic, barium, cobalt, copper, lead, nickel, silver,
vanadium, and zinc.
Generally,
elevated
levels
of
specific
conductance
and,
Pilei'. Pit Site, Record of Dcci.ioa SummaIy
--paqe 7--
.
-------
alkalinity were found in the qroundwater in the wells around the
landfill. These wells included some that are nominally
upqradient and sideqradient of the landfill, and some of these
wells did not contain elevated levels of chloride ion. The
increased conductivities indicate that some substances are beinq
added to the qroundwater from the landfill, even in the
upqradient and sideqradient directions. Since conductivity
depends on the presence of ions, amonq other thinqs, an increase
in the conductivity indicates an increase in the presence of
inorqanic acids, bases, or salts; molecules of orqanic compounds
that do not dissociate in aqueous solution, and this is the case
for many of the orqanics,do not contribute appreciably to the
conductivity. Specific conductance data for Round 1 is shown in
Fiqure 6. Specific conductance results are also presented in
Table 1.
The shallow aquifer in the area of the two sites serves several
nearby residences as a source of water. Five residences with
contaminated qroundwater, all located alonq Lindenwood Road,
have been supplied with home carbon treatment units under a
Consent Order with some of the Acme Solvent PRPs.
No upstream-downstream trends were noted in the results of the
samplinq of water and sediment from Killbuck Creek. This
indicated that the Paqel's Pit site was not havinq an impact on
the water quality there.
Durinq air monitorinq, fifteen VOCswere found to be present.
However, the data was of limited value because sample holdinq
times were exceeded. The total of the hiqhest concentrations of
each of these VOCs found at any location was below the National
Ambient Air Quality standards for hydrocarbons.
VI.
SUMMARY OP SITB RISKS
A baseline risk assessment was performed which characterized the
extent of contamination and determined the potentially exposed
human and ecoloqical population(s) sufficiently to evaluate
which risks need to be prevented. The baseline risk assessment
was composed of a human health evaluation and an endangerment
assessment. The Risk Assessment Guidance for Superfund (RAGS)
(USEPA, March 1989 and December 1989) was used in the
preparation of the baseline risk assessment which has been
reviewed by a regional toxicologist for consistency with
guidance pursuant to OSWER Directive No. 9835.15.
The objective of the baseline risk assessment was to assess
risks at the Pagel's Pit site regardless of the source(s) of the
contamination. For the baseline risk assessment,samplinq
locations for qroundwater west of Lindenwood Road were qenerally
--Page 8--
Pilei'. Pit Sile, Record of Decisioo SWIIIIW)'
.
-------
considered to represent the Pagel's Pit site.
A.
Human Health Ri8k8
The human health evaluation was conducted to estimate the risks
that people might incur as a result of exposure to contamination
from or at the site. The risk assessment was made for both
current and potential future site conditions.
Chemicals of potential concern were selected on the basis of the
following criteria: a.) positively detected in at least one
sample in a medium; b.) detected at levels significantly above
the levels in blank samples; c.) detected at levels elevated
above naturally occurring levels; d.) only tentatively
identified, but which may be associated with the site; and e.)
transformation products of chemicals demonstrated to be present.
Those chemical.s that met one of these five initial selection
criteria were considered chemicals of potential concern. The
exceptions to this were those chemicals detected in landfill
leachate but not in other media and chemicals for which critical
toxicity values had not been developed; these latter were
evaluated qualitatively.
The chemicals of potential congern identified at the Pagel's Pit
site were:
Volatile Organic Compounds
acetone
benzene
bromoform
bromodichloromethane
carbon tetrachloride
chlorobenzene
chloroethane
chloromethane
chloroform
dibromochloromethane
l,l-dichloroethane
1,2-dichloroethane
l,l-dichloroethene
l,2-dichloroethene (both)
1,2-dichloropropane
1,3-dichloropropene
ethylbenzene
methylene chloride
tetrachloroethene
l,1,2,2-tetrachloroethane
toluene
l,l,l-trichloroethane
trichloroethene
vinyl chloride
Semi-Volatile ComDounds
bis (2-ethylhexyl) phthalate
di-n-butylphthalate
1,2-dichlorobenzene
l,3-dichlorobenzene
l,4-dichlorobenzene
diethylphthalate
PAHs (noncarcinogenIc)
Metals/Inoraanics
arsenic
barium
cadmium
chromium
cobalt
copper
iron
lead
manganese
nickel
nitrate & nitrite
silver
sodium
thallium
vanadium
--Page 9--
Pilei'. Pit Sile. Record or Decilica SumIIwy
.
-------
xylenes (0-, m-, p-)
zinc
cyanide
Pesticides/PCBs
none
Note: PAHs are polynuclear aromatic hydrocarbons.
The Pagel's Pit site is an operating landfill that is expected
to be closed in accordance with the regulations that apply to
its. operations. These regulations require a sanitary landfill
cap for closure. It presently has a gas collection system and
a leachate removal system, and these are to be operated and
maintained after closure in accordance with the regulations.
Access to the site is controlled. The primary problem
identified for this site and which led to its inclusion on the
NPL is possible contamination of the groundwater. Therefore, it
has not been necessary to consider certain possible present and
future exposure conditions. For example, since the landfill has
yet to be finally covered (most of the surface is presently
covered by an intermediate cover) and the landfill operations
are similar to most operating landfills, consideration of
present and future exposure to the soil on the landfill has not.
been done and this soil has not been tested for chemical
contamination. . .
Under current land use conditions, only one potential exposure
pathway was quantified. This was the exposure of children to
contact with surface water and sediment and ingestion of
sediment during recreation at J<:illbuck Creek. For the analysis,
it was assumed that the children would be exposed once each week
for eight months of the year for a period of 10 years. The
exposur~ point concentrations for the surface water and
sediments were determined from the lesser of either the 95
percent upper-bound confidence limit of the arithmetic mean or
the maximum concentration detected for the four downstream.
sampling locations. Another pathway, the one arising from
inhalation exposure to fugitive chemical emissions released to
the air, was qualitatively addressed.
Under future land use conditions, the above two conditions apply
in addition to possible exposure to the groundwater, through
ingestion, inhalation, and dermal contact, from local wells
downgradient of the site. This latter pathway results from the
potential installation of new water supply wells near the site
or the possible movement of the contaminated groundwater to
private wells that exist downgradient of the site or may be
installed there. This is not a current pathway because the
closest private well (well PW1 which is about 0.4 miles
southwest of the landfill) is not presently contaminated. For
this analysis it was assumed that the residents would be exposed'
for 30 years on a daily basis. The exposure point
--Page 10--
PileI'. Pil Sile, Rccord of Dcci.iOD SII1DIIIU)'
.
-------
concentrations were determined from the lesser of either the 95
percent upper-bound confidence limit of the arithmetic mean or
the maximum concentration detected. The qroundwater data used
for these concentration determinations were for the on-site and
downqradient wells as well as well Gl12, which is just east of
Lindenwood Road, except for wells B14 and PW1, which did not
appear to be affected by artificial sources; this represents a
total of 28 wells.. .
Exposure point concentrations are combined with estimates of
media intake rates for the receptors in each exposure pathway to
arrive at the receptor's intake. The media intake rates were
qenerally based on USEPA procedures and suqqested values.
The relationship between the level of chemical exposure and the
maqnitude of the toxic effect (dose-response relationship) for
each chemical has been determined by applyinq critical toxicity
values (e.q., reference doses (RfDs) and carcinoqenic slope
factors (SFs» developed by USEPA. The toxicity values used
have been obtained from the Inteqrated Risk Information System,
the fourth quarter Health Effects Assessment Summary Tables
(September 1990), or from the Environmental Criteria and
Assessment Office (for interim values). .
SFs have been developed for ~stimatinq excess lifetime cancer
risks associated with exposure to potentially carcinogenic
chemicals. The product of the SF and the estimated intake
provides an upper-bound estimate of the excess lifetime cancer
risk associated with .exposure to a potential carcinoqen at a
particular intake level. The term "upper bound" reflects the
conservative estimate of the risks calculated from the SFs. Use
of this approach makes underestimation of the actual cancer risk
hiqhly unlikely. SFs are derived from the results of human
epidemioloqical studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors are'
applied.
RfDs have been developed for. indicatinq the potential for
adverse health effects from exposure to chemicals exhibi tinq
noncarcinoqenic effects. A chronic RfD is an estimate of a
lifetime daily exposure level for humans, includinq sensitive
humans, that is likely to be without an appreciable risk of
deleterious effects durinq a lifetime. Estimated intakes of
chemicals from environmental media are compared to chronic RfDs.
These RfDs are derived from human epidemioloqical studies or
animal studies to which uncertainty factors are applied. These
uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinoqenic effects
to occur.
--paqe 11--
Pilei', Pit SiIe, Record
-------
Excess lifetime cancer risks (probabilities) are determined by
multiplying the intake level by the cancer SF for each chemical
of concern. An excess lifetime cancer risk of 1X10-6 for a
specific chemical indicates that, as a plausible upper bound, an
individual has a one in a one million chance of developing
cancer as a result of site-related exposure to a carcinogen over
a 70-year lifetime under the specific exposure conditions at a
site.
Potential concern for noncarcinogenic effects of a .single
contaminant in a single medium is expressed as the hazard
quotient (HQ), the ratio of the estimated intake to the RfD.
Adding the HQs for all contaminants within a medium or across
all media to which a given population may reasonably be exposed
gives the hazard index (HI). The HI provides a. useful reference
point for gauging the potential significance of 'multiple
contaminant exposures within a single medium or across media.
For current and future site conditions, exposure of children to
chemicals in Killbuck Creek sediment and water was evaluated.
The cumulative HI due to exposure to sediment via both
incidental ingestion and dermal contac~ and to surface water by
dermal contact was 0.01, based on reasonable maximum exposures
to noncarcinogenic chemicals I present. The cumulati ve cancer
risk for the same pathway was calculated to be 6X10.7 based on
reasonable maximum exposures to carcinogenic chemicals present.
USEPA recommends that HQs and the HI should be less than one.
USEPA recommends that remedies considered should reduce ambient
chemical concentrations to levels associated with a carcinogenic
risk range of 1X10"" to 1X10-6. Thus, for this pathway,
noncarcinogenic health effects are not expected and cancer risks
are low.
For current and future site conditions, the release of chemicals
to air via volatilization was not considered a substantial route
of exposure to humans. This was based mainly on a comparison of
the ambient air data, which has limited usefulness, to safe
exposure levels for workers. Also, the data did not indicate
any increase in the levels of the chemicals downwind from those
levels upwind.
For potential future site conditions, noncarcinogenic health
effects may be of concern and cancer risks are substantially
greater than the USEPA's suggested risk range when the
groundwater at the site is considered as a water supply. The
cumulative HI due to exposure to chemicals of potential concern
in the groundwater was 5 based on reasonable maximum exposures
to the noncarcinogenic chemicals present; thus, adverse health
effects might be caused by exposure to the groundwater. The
majority (84%) of the HI was associated with the potential
--Page 12--
Pilei" Pit Sile. Record of DcciliOll Summary
,
-------
exposure to 1,2-dichloroethene (26%), arsenic (5%), barium (7%),
manqanese (7%), thallium (22%), and zinc (17%). (This HI does
not include the contribution from cobalt, which would increase
the HI to 100 if it were included. It has not been included
because cobalt was detected infrequently (only at two wells in
Round 1, and one of these samples was the duplicate) and because
only an interim value oral RfD was available and it appeared to
be unrealistically low.) The cumulative cancer risk for the
same pathway was calculated to be 1x10.3 based on reasonable
maximum exposures to carcinoqenic chemicals present. The
majority (91%) of the cancer health risk was associated with the
potential exposure to vinyl chloride (74%) and arsenic (17%).
Actual or threatened releases of hazardous substances from this
si te, if not addressed by implementinq the. response action
selected in this ROD, may present an imminent and substantial
endanqerment to public health, welfare, or the environment.
B.
Environmental Risks
The environmental evaluation portion of the baseline risk
assessment was done to characterize the natural habitats which
may be influenced by the Paqel's Pit site and to estimate the
actual or potential effects 90ntaminants miqht have on these
habitats. Killbuck Creek and the nearby wetlands were assumed
to be the most sensitive ecoloqical habitats near the landfill.
Killbuck Creek is rated a "Class B stream--Hiqhly Valued Aquatic
Resource".
Fish were considered the qroup of aquatic species that would be
the most susceptible to chemical exposure in Killbuck Creek.
Effects on fish are not expected based on the concentrations in
the water in comparison to the Ambient Water Quality Criteria.
Since this sensitive qroup of orqanisms appears to be safe from
health effects, other aquatic ecosystem effects. are not
anticipated.
Health risks to the terrestrial environment could not De
compared to applicable criteria because floodplain sediment and
surface soil samples were not analyzed durinq the remedial
investiqation. Visual observations did not reveal any siqns of
impacts on the terrestrial ecosystem. Also, because of the
nature of the contamination at the site (primarily in the
qroundwater), impacts on the terrestrial ecosystem would not be
expected. .
VII.
DESCRIPTIO~ OF ALTERNATIVES
A.
Common Elements
Pilei'. Pit Site. Rccord or Deciliall SIIIIIIIW)'
--paqe 13--
.
-------
Some components are common to several of the alternatives and
these are described here. With all alternatives, it is planned
that the landfill would continue to operate until it reaches
capacity as long as the rate of filling does not fall below the
level specified in this document. If it is decided to close the
landfill early, then those components of the remedy that were to
be implemented at final closure would be implemented at the time
of actual closure. All future operations will be governed by
applicable State permits and State regulations. The following
alternatives have been evaluated:
Alternative 1 No Action
Alternative 2 Planned Closure
Alternative 3 Clay-Synthetic Membrane Cap
Alternative 4 Off-Site Treatment of Groundwater and
Leachate
Alternatives 5 and Sa On-Site Carbon Adsorption.Treatment of
Water
Alternatives 6 and 6a On-Site Air stripping of Water
Alternatives 7 and 7a On-Site Photolysis/Oxidation Treatment
of Water
In-situ Landfill Waste Fixation
Alternative 8
Alternatives 2, 4,. 5, 5~, 6, 6a, 7, and 7a include an Illinois
sanitary landfill final covert system for the wastes that have
been deposited at the site. This cover system would meet the
recent regulations adopted by the State of Illinois. The cover
would be constructed of a low permeability layer followed by a
final protective layer. The low' permeability layer would
consist of a compacted earth layer at least 3 feet thick and
would have a permeability that would be no greater than 10.7
cm/s. Any alternative to this cover would have at least the
performance of this system. The protective layer would consist
of soil capable of supporting vegetation, would be at least J
feet thick, and would protect the low permeability layer from
freezing. The final slopes of the cover system would be at a
grade that would be capable of supporting vegetation and
limiting erosion and would prevent accumulation of water on the
cover. The cover would be maintained after installation.
In all of the alternatives except Alternatives 1 and 8, the
current landfill gas extraction system would be upgraded. The
newest 21 wells would probably be retained, but would be
extended upward to accommodate the increased height of the
landfill. The other extraction wells would be replaced with new
wells, and additional new wells would be placed in the newer
portions of the landfill. It is expected that the current
system for handling the gas (for example, the blowers and the
incinerator) would be able to handle the increased amounts of
. gas; if this would not be the case, additional handling capacity
would be installed. Gas monitoring at selected perimeter
Pilei', Pit Si~, Record of DcciliaD Summuy
--Page 14--
.
-------
locations would be installed to detect gas migration from the
landfill. The need for a perimeter gas recovery system would be
evaluated, and it would be installed if necessary. Landfill gas
would continue to be used as a fuel or it would be flared. It
would be flared if the amount of gas exceeded that which could
be used or if the gas were no longer needed for sludge drying or
some other appropriate use.
Alternatives 4, 5, Sa, 6, 6a, 7, 7a, and 8 include a groundwater
extraction system. The purpose of the system would be to
prevent the migration of contaminated groundwater to the west
from the waste disposal area. Groundwater would be extracted in
a series of wells installed near the western boundary of the
site. Further study of the contamination in the groundwater and
the flow of the groundwater would be necessary in order to
define both the vertical and horizontal extent of the.
groundwater contamination at the western boundary and beyond so
that the extraction system designed would intercept the flow of
contaminated groundwater and would recover the contaminated
groundwater that exceeds the specified cleanup levels and that
had already passed beyond the western boundary. The wells would
be sized and spaced to capture the contaminated groundwater
flowing from the vicinity of the waste disposal area. They
would be operated in a manneri that would lead to an.efficient
blocking operation. The line of extraction wells would stop the
advance of the contaminated qroundwater. It is expected that
the groundwater extraction system would have to operate many
years before the contamination in the groundwater at the site
boundary would decrease to acceptable levels. At the present
time, it is not possible to satisfactorily estimate this time
period. The water taken from these wells would be disposed of
in different ways in the various alternatives. The descriptions
of the alternatives provide further details for this.
In Alternatives 3, 4, 5, Sa, 6, 6a, 7, and 7a, deed restrictions
for property development and new well development on and
adjacent to the landfill would be sought. Where restrictions on
groundwater use because of the contamination from the Pagel's
Pit site would result in an inadequate water supply, provisions
would need to be made for an alternative water supply.
Monitoring of groundwater, sUrface water, landfill gas,
leachate, and the cover system would be carried out and all
systems would be properly maintained.
B.
Alternative 1: No Action
The Superfund program requires that the "no action" alternative
be evaluated at every site to establish a baseline for
comparison. Under this alternative, no further action would be
taken at the site to address the problems that have; been
Pilei', Pit Sile, Record of Deci,iaa SIIIIIIIWY
--Page 15--
.
-------
identified.
At this site, this no action alternative could occur if the
landfill suddenly shut down operations and failed to close as
required by its permit. The leachate collection and gas
management systems would no longer be operated. The
contaminating of the groundwater would continue, and there would
be no provisions for preventing future development on or very
near the site. Funds derived from the financial assurance
provisions of Winnebago Reclamation Service, Inc., the operator
of the landfill, would be used to place a minimal cover on the
landfill and possibly provide additional monitoring.
C.
Al~.rna~ive 2: Planned Cloaure
Under this alternative, the site would be properly closed when
it reached capacity, or a decision was made by the operator to
close it early. The Illinois sanitary landfill final cover
system and the upgraded landfill gas extraction system described
previously would be installed at the site. The leachate
collection system would be operated, and the leachate would be
sent to the local publicly owned treatment works (POTW) for
treatment before being discharged, as is done now; pretreatment
of the leachate by the current aeration system wo~ld continue
with modifications as necessary to continue meeting the POTW's
pretreatment requirements. The groundwater would be monitored.
The site would be properly cared for according to the terms of
its operating permit.
D.
Al~erna~iv. 3: clay-syn~h.~ic Membrane Cap
The wastes would be covered by a Resourc.e Conservation and
Recovery Act (RCRA) Subtitle C compliant hazardous waste cap
that would reduce the infiltration of water into the wastes to
very low levels and, therefore, reduce the amount of leachate.
This cap might consist of two feet of compacted clay on top of
the wastes, covered by a synthetic membrane, a sand drainage
layer, a geotextile fabric, a soil layer (root zone), top soil,
and grass. .
The upgraded landfill gas extraction system described previously
would be installed. The current leachate extraction system
would be upgraded by installing permanent pumps in the manholes
and selected gas extraction wells. The leachate would be sent
to the local POTW by means of a sanitary service line connected
to an existing sanitary sewer; pretreatment of the leachate by
the current aeration system would continue with modifications as
necessary to continue meeting the POTW's pretreatment
requirements. The POTW would treat the leachate before final.
discharge.
--Page.-16--
P8&el'l Pit Site, Record of Deci.ion Summary
.
-------
Deed restrictions and monitoring and maintenance, as described
in the common elements section, would apply.
E. Alternative 4: Off-Site Treatment of Groundwater and
Leachate
In this alternative, contaminated groundwater and landfill
leachate would be extracted and sent to the local POTW for
treatment. The combined stream would be sent to the POTW by
means of a sanitary service line connected to the sanitary
sewer. The groundwater extraction system described previously
would be used to extract the groundwater. The leachate would be
extracted using the system described in Alternative 3.
The Illinois sanitary landfill final cover system and the
upgraded landfill gas extraction system described previously
would be constructed at the site. Deed restrictions and
monitoring and maintenance, as described in the common elements
section, would apply.
P. Alternative. 5 and 5&:
Treatment of Water
On-Site Carbon Adsorption
In Alternative 5, extracted grQundwater would be treated on site
to remove VOCs and semivolatile organic compounds (SVOCs) by
carbon adsorption. The contaminated water would be pumped
through two vessels containing the activated carbon, operated in
series. Spent carbon would be shipped off site for regeneration
or disposal. A solids filter would be used to pretreat the
water going to the carbon adsorption vessels to remove suspended
solids. The solids removed would be disposed of as their
characte~istics allow. Ion exchange or coagulation/flocculation
would be added for removal of inorganics if this were determined
to be necessary to meet discharge requirements or to prevent
interference with the organic treatment process. Again, the
solids would be disposed of as their characteristics allow. The
treated water would be discharged to Killbuck Creek. The
discharged water would be sampled periodically to ensure that
discharge requirements were being met. The discharge
requirements would be those for a National Pollutant Discharge
Elimination System (NPDES) permit. The leachate would be
transferred to the local POTW as described in Alternative 3.
. In Alternative Sa, both the groundwater and the leachate would
be treated on-si te by carbon adsorption preceded by solids
filtration. The leachate would be pretreated for removal of
turbidity, solids, and inorganics by pH adjustment,
precipitation, flocculation, and sedimentation and these solids
would be disposed of as their characteristics allow.
Pilei" Pit Site, Record of DeciaiOll Summary
--Page 17--
.
-------
Except for the treatment that replaces transfer to the local
POTW, these two alternatives are the same as Alternative 4.
G.
Alternatives' and 'a: on-site Air stripping of Water
Alternatives 6 and 6a are identical to Alternatives 5 and Sa,
respectively, except that air stripping would be used in place
of carbon adsorption. In addition to the air stripping, carbon
polishing of the water leaving the air stripper would be
included if it were determined to be necessary to meet discharge
limits. The air stripping system would remove volatile
contaminants from the groundwater by passing the water through
a packed column through which air flows countercurrently to the
water. The volatile contaminants in the water would be
transferred to the air. It is expected that the air emissions
from the column would be low enough that treatment of the vapors
would not be required. However, the air emissions would' be
studied further during the design of the system, and if that
study dete,rmined that controls would be necessary, controls
would be added. This study would include modeling to predict
air emissions from the si te and might include further air
monitoring studies since those done previously had limited
value. The discharges from th. air stripper would be subject to
IEPA approval, could not exceed health-based levels (an excess
cancer risk of lX10~ at the nearest residence or business), and
would have to meet all federal and state requirements. All
solids removed from the fluids being' treated would be disposed
of as their characteristics allow.
B. Alternatives 7 and 7&: On-sit. Photolysis/oxidation of
Groundwater
Alternatives 7 and 7a are identical to Alternatives 5 and Sa,
respectively, except that photolysis and oxidation would be used
in place of carbon adsorption. An ultraviolet photolysis
process enhanced by the introduction of ozone or hydrogen
peroxide would be used to oxidize the organic contaminants in
the water. The treatment unit would consist of a tank with
ultraviolet fixtures installed inside.
I.
Alternative 8: In-situ Landfill Waste Fixation
In this alternative, the landfill wastes would be solidified in
place (in-situ) by injection of a reagent slurry into the closed
landfill. In this fixation process, the wastes are treated by
boring into a landfill and adding the reagents. Each boring
creates a column of treated material circular in cross section.
The wastes are transformed into a stable, solidified mass by the
process.
--Page 18--
Pilei', Pit Sile, Record or Deci,ioa SIIJDDW)'
.
-------
Groundwater would be extracted and treated on site by air
stripping as in Alternative 6. There would be no cap with this
alternative or gas or leachate extraction systems since these
should not be necessary. Deed restrictions, as described in the
common elements section, would be sought and groundwater
monitoring and care of the site would be performed.
J.
Costs
The estimated capital costs, costs for annual operation and
maintenance (O&M), and total present net worth costs for the
alternatives are given below:
Alternative Ca~ital Costs Annual O&M Costs Present Worth
1 0 0 0
2 $ 5,170,000 $149,000 $ 7,500,000
3 10,850,000 147,000 13,100,000
4 5,850,000 293,000 10,400,000.
5 6,240,000 310,000 11,000,000
5a 6,620,000 439,000 13,400,000
6 5,960,000 248,000 9,800,000
6a 6,400,000 296,000 11,000,000
7 6,360,000 327,000 11,400,000
7a 6,940,000 463,000 14,100,000
8 985,000,000. 204,000 989,000,000
Note: Alternative 1 (No Action) has no specific capital costs.
It has been assumed that there will be no periodic sampling and
analysis. .
It.
Time Required for Implementation
The periods of time required to implement the various remedial
actions are comparable. The cover system would be constructed
after waste capacity had been reached or .a decision to close
early had been made. If, however, the rate of waste disposal
fell significantly so that the time for closure would extend
more than a few years (approximately three years) beyond the'.
presently estimated years of remaining capacity, USEPA would
order that closure be implemented before capacity had been
reached. The cover system would be installed as the wastes
would reach final elevations so that the beginning of the
construction of the cover system would be well before final
closure of the entire landfill would have to be accomplished.
The landfill would be operated according to the terms of its
permit and the rules of the state of Illinois during its
remaining life. The cover system would be maintained as long as
necessary. The fixation process would be implemented on much
the same schedule as the final cover system.
The groundwater extraction system would be installed within an
estimated two to three years after the decision was made in the
Pilei" Pit Sile, Record of Deci,iaa Summuy
--Page 19--
.
-------
ROD that the extraction system would have to be installed. The
length of time this system would have to operate cannot be
estimated at this time. However, it would be operated at least
until it was demonstrated to USEPA's satisfaction by the results
of four quarters of monitoring that the concentrations in the
groundwater beyond the extraction area were not exceeding the
applicable standards and that the concentrations in the
groundwater upgradient of the extraction area were not exceeding
values that would, as shown by modeling, lead to an exceedance
of the applicable standards in the downgradient groundwater.
The system for handling the extracted groundwater would be left
in a stand-by condition until at least the following five-year
review or for three years, whichever is longer. However,
monitoring of the groundwater would continue even beyond that
time, and should monitoring indicate that the applicable
standards were being exceeded, groundwater extraction would have
to be reinstituted to control the contaminated groundwater.
The landfill gas extraction system would be operated until the
waste has stabilized enough to no longer produce methane in
quanti ties that exceed the minimum allowable. concentrations
stated in 35 IAC 811.311. The leachate management system would
be operated untii treatment, would no longer be necessary
according to the requirements of 35 IAC 811.309. .
Since wastes are being left at the site, the comprehensive
Environmental Response, compensation, and Liability Act of 1980,
as amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA) (hereinafter CERCLA) requires that a review of
the remedial action selected be conducted at least every five
years a~ter the beginning. of the remedial action. This will
require that groundwater, leachate, and landfill gas monitoring
be continued in order to furnish data for the reviews. with the
no action alternative, this review would probably require some
minimal amount of sampling and analysis of the groundwater and
other media, but the costs for this sampling have not been
included for this alternative.
VIII.
SUMMARY OP COMPARATIVE ANALYSIS OP ALTERNATIVES
The National Contingency Plan (NCP) requires that an explanation
be presented as to how the nine evaluation criteria were used to
select the remedy. These criteria are categorized into three
groups: threshold criteria (overall protection of human health
and the environment and compliance with applicable or relevant
and appropriate requirements (ARARs»; primary balancing
criteria (long-term effectiveness and permanence; reduction of
toxici ty , mobili ty, or volume through treatment; short-term
effectiveness; implementability; and cost); and modifying.
criteria (state acceptance and community acceptance).
--Page 20--
Pilei', Pit Site, Record of Deci,iCIII SIIIII1IWY
.
-------
The NCP states that containment technologies. will generailY be
appropriate remedies for wastes that pose a relatively low low-
level threat or where treatment is impracticable. Containment
has been identified as the most likely response action at
municipal landfills because: municipal landfill are primarily
composed of municipal, and to a lesser extent hazardous, wastes,
and therefore, they often pose a low-level threat rather than a
principal threat; and the volume and heterogeneity of waste
within a municipal landfill often makes treatment impractical.
As shown earlier in this document, the Pagel's Pit site is a
municipal landfill.
A.
Threshold criteria
1. Overall
Environment
Protection of Human Health
aDd
the
All of the alternatives except Alternative 1 (No Action) and
Alternative 2 (Planned Closure) and Alternative 3 (Clay-
Synthetic Membrane Cap) provide adequate protection of human
health and the environment. Alternatives 1, 2, and 3 do not
include groundwater extraction and treatment and consequently do
not protect against exposure to contaminated groundwater;
Alternative 3 does include institutional controls as protection
against exposure to contaminated groundwater in place of an
active response measure. The groundwater would be remediated
generally until maximum contaminant levels (MCLs) and non-zero
maximum contaminant level goals (MCLGs) are reached, as
appropriate. When necessary, a carcinogenic risk of lO~ and a
cumulative hazard index of one would be used. All of the
alternatives except Alternative 1 provide adequate protection
against contact with the wastes. All of the alternatives except
Alternative 1 provide some protection against the release of
contaminants from the landfill by means of gas and leachate
extraction; however, Alternative 2 might not provide this
protection for as long a period as the o~her alternatives.
2. Compliance with Applicable
Appropriate Requirements
or
Relevant
and
All alternatives except Alternatives 1, 2 and 3, and possibly
Alternative 4, should be able to meet the identified ARARs.
Alternatives 1, 2, and 3 leave contaminated groundwater in place
and do not provide means for preventing its movement away from
the site. MCLs and MCLGs set under the Safe Drinking Water Act
(SDWA) and National Pollutant Discharge Elimination System
(NPDES) limits set under the Clean Water Act (CWA) are ARARs for
this site. Alternatives 1, 2, and 3 would not meet the MCLs and
non-zero MCLGs in the aquifer, but the groundwater extraction
system with the other alternatives would be operated to meet
--Page 21--
P.,eI', Pit Sile. Record or DcciaiOll s-ry
.
-------
these requirements or more stringent requirements presented
below. On-site treatment units for either groundwater or
leachate would meet the NPDES requirements for discharge of the
treated water to surface water. If RCRA wastes have
contaminated the groundwater at the Pagel's Pit site, then RCRA
ARARs may apply to the remediation of the groundwater. This
would mean that any residue from the treatment of this
groundwater would be a listed waste under RCRA and would have to
be treated accordingly. The on-site treatment of the
groundwater would be able to meet these ARARs, but these ARARs
might make it impossible to send the groundwater to the local
POTW for treatment (Alternative 4). The sanitary landfill cover
designed to meet the requirements of the applicable Illinois
regulations for solid waste landfills would meet the identified
ARARs. The exact quantity of RCRA hazardous wastes that may be
present in the landfill is not ascertainable. The bulk of the
wastes disposed of at the site were household wastes. While
consideration of a RCRA Subtitle C cap is relevant, requiring
the installation of such a cap would not be appropriate in view
of the predominance of solid wastes and lack of evidence of a
RC~ hazardous waste problem within the landfill. The RCRA land
disposal regulations are not relevant to the selected remedy as
no wastes are required to be~excavated and disposed of.
B.
primary Balancing Cri~eria
1.
Long-~erm Effec~ivene.. and Permanence
Alternative 8 could provide the highest degree of long-term
effectiveness and permanence because the fixation process could
greatly reduce the mobility of the contaminants in the wastes.
However, this is a relatively new technology and testing would
be required to determine its effectiveness at this site,
particularly whether it would fix all of-the material in the'
landfill. The final landfill cover systems included with all
alternatives except Alternatives 1 and 8 provide long-term
effectiveness with proper maintenance. The covers reduce the
mobility of the contaminants by covering the wastes and reducing
water infiltration. The covers provide protection against
contact with wastes and contaminated soils. Groundwater
extraction and treatment provide long-term effectiveness by
removing contaminants from the groundwater and preventing the
spread of this contamination. Air stripping and carbon
adsorption are processes that have been proven to be generally
reliable. Management of the landfill gas and leachate provides
long-term effectiveness ,by reducing the migration of
contaminants to the groundwater. Since wastes will remain at
the site in all of the alternatives, five-year reviews of the
protectiveness of the remedy will be required.
--Page 22--
'lid'. Pit Site, RecorcI of Deciaioa Summary
.
-------
2. Reduction of Tozicity, Mo~ility, or Volume (TMV)
Through Treatment
Alternatives 4, 5, Sa, 6, 6a, 7, 7a, and 8 provide extraction
and treatment of the groundwater. This will reduce the mobility
and volume of the contaminants. Carbon adsorption may reduce
the toxicity of the contaminants in the groundwater if these
contaminants are destroyed during carbon regeneration.
Alternative 7 reduces toxicity by oxidizing VOCs and SVOCs that
are present in the groundwater. Treatment of leachate at the
POTW reduces toxicity by destroying some of the VOCs and SVOCs.
Burning landfill gas reduces its toxicity. Extraction of
leachate and gas from the landfill for treatment reduces their
mobility. The fixation of the wastes in Alternative 8 may
greatly reduce mobility, but testing would have to be done to
determine if this would be the case.
3.
Short-term Effectivene..
The groundwater extraction in Alternatives 4 through 8 prevents
the migration of contaminated groundwater and provides the
greatest short-term effectiveness. There is the possibility of
a slight impact - on local residents from the air -stripper
emissions in Alternatives 6 ~and 6a. This would be managed by
means of emissions controls, if necessary. Handling of the
exhausted carbon in Alternatives 5 and Sa and the wastes from
the pretreatment units in Alternatives 5, Sa, 6, 6a, 7, and 7a
may present some slight risks to the workers and to others when
wastes from these processes are hauled off site for proper
disposal. The amount of wastes to be handled would be expected
to be greater in the alternatives that are also treating
leachate on-site. Installation of the groundwater extraction
wells and gas extraction wells and modification of the leachate
extraction system might present some risks to the workers.
There are some possibilities of risks to residents and workers
if the sanitary service line or sanitary sewer being used to
transport leachate and contaminated groundwater were to leak.
The - extraction of gas and leachate from the wastes provides
added protection against spreading of contamination. The waste
fixation system in Alternative 8 might pose some risks for the
workers and the local residents during its implementation since
the wastes must be penetrated.
In each of the alternatives involving application of a final
cover system and in the alternative involving the fixation
process, the landfill would continue to operate until it is
full. This should not expose the workers or local residents to
excess risks. The present operation of the landfill includes
leachate and gas extraction, and the areas of the landfill that
are not currently being filled have an intermediate cover that
--Page 23--
P.,d'. Pit Site. Record ~ Decilioa Suamwy
.
-------
prevents contact with the wastes. The principal risk identified
. would be addressed wi thin a short period of time if the
groundwater extraction system was installed and operated as soon
as possible after the selection of the remedy. This would
result in control of the migration of contaminated groundwater.
Such control would not be present in the cases of Alternatives
1, 2, and 3.
4.
Imp 1em8ntabi lity
Among the alternatives requiring active remedies, Alternatives
2 and 3 would be the simplest to implement. All of the
alternatives should be fairly easy to implement except for the
fixation process of Alternative 8. A possible future
implementation problem might arise in the alternatives in which
leachate is sent to the POTW if changes in the content of the
leachate occur or regulations regarding waste streams that can
be sent to a POTW change. Alternatives 5, Sa, 6, 6a, 7 and 7a
require that NPDES requirements be met for discharge of the
treated water to Killbuck Creek. There should be no problem
meeting these requirements. Alternatives 6 and 6a require that
IEPA air requirements be met, which should pose no problem;
these alternatives would have to meet all federal and state
requirements related to air discharges. The
photolysis/oxidation process and the fixation process are fairly
new and would have to be tested before they could be
implemented. The air stripping and the carbon adsorption
processes are well established and should present few technical
problems that have not arisen and been solved elsewhere.
. 5.
Cost
The costs of the various alternatives h~ve been presented in
section VII.J. Alternatives 4, 5, 6, 6a, and 7 all cost about
the same (from $9,800,000 to $11,400,000 for the present net
worth costs). Alternative 1 has essentially no costs associated
with it. Alternative 8 is much more than an order of magnitude
more expensive than the other alternatives ($989,000,000 for the
present net worth cost).
c.
MOdifyinq criteria
1.
state Acceptance
IEPA has been involved with the investigations at the Pagel's
Pit site throughout the RI/FS process. The State will not
concur on this Record of Decision, however. They agree in
principle that the selected remedy will address contamination at
the site. However, they believe that they will not have the
necessary approval rights over the landfill closure and-post-
--Page 24--
Paacl" Pit Site, Record of Deci,ioa SIIIIIIIW)'
.
-------
closure activities when implementation occurs because they will
not be a party to any settlement that is negotiated. The letter
stating their position is in Appendix C.
2.
community Acceptance
community acceptance of the selected remedy is discussed in the
Responsiveness Summary (Appendix B).
IX.
SELECTED REMEDY
Based on the comparative analysis of the alternatives, which is
summarized above, and the information obtained. from the remedial
investigation and the feasibility study, USEPA and IEPA have
s.elected either Alternative 5 or Alternative 6 as the most
appropriate remedial action for the Pagel's Pit site. The two
remedies are very similar, differing only in the manner in which"
the extracted groundwater is treated at the site. The actual
selection of the treatment system to be used will be made during
the design of the system. Permitting the choice to be made at
that time will allow the selection of the most appropriate
system for the task to be performed by allowing for additional
information to be used in the decision. The selection will be
made using good engineering practice. The treatment system that
best meets the removal requirements in a cost effective manner
will be chosen. The effectiveness of the carbon adsorption
system in removing the contaminants of most concern (for
example, single chain chlorinated compounds are not easily
adsorbed), the possible inability to remove the more nonvolatile
contaminants to the required degree in an air stripper, and the
ability of activated carbon to remove some inorganics are some
of the items that will have to be considered in the selection.
Because of the presence of vinyl chloride in the groundwater, at
this time it appears likely that Alternative 6 will be used.
Alternative 5 includes a sanitary landfill cover for the waste
disposal area; groundwater extraction along the west side of the
site; on-site groundwater treatment by carbon adsorption
following pretreatment with a solids filter and treatment for
removal of inorganics, if necessary, with the treated water
being discharged to Killbuck Creek; leachate extraction and
transfer to the local POTW for treatment; gas extraction and use
of the gas for fuel or the flaring of the gas; and deed
restrictions. Alternative 6 is the same except that air
stripping, possibly followed by carbon pOlishing, is used in
place of carbon adsorption. The cost estimates for these two
alternatives are presented in Table 2.
As a reminder, the remedial action being selected here does not
address the groundwater contamination that was found in the
--Page 25--
Pilei" Pit She, Record of Dcciaioa SIIIIIIIW)'
.
-------
southeast corner of the site; that contamination will
addressed after additional studies have been conducted.
be
The sanitary landfill cover has been described in Section VII.A.
It will meet the requirements presented in 35 IAC PartSll.
However, if, during the period that the landfill continues to
operate, the State issues new regulations for landfills of this
type that contain requirements for a more protective cap than
the one specif ied here, and these regulations apply to this
landfill, then the new cap shall be used. The cap will be
ins~alled according to the schedule given in Section VII.R and
it will be maintained. .
During the remaining years of operation, the landfill will be
operated according to the terms of its permit(s) and the
regulations of the State of Illinois. This applies to the
continuation of present practices and to any future operating
practices that may be required,' such as. the control of runoff
from the site. Section 121 (e) (1) of CERCLA states that, "No
Federal, State, or local permi t shall be required for the
portion of any removal or remedial action conducted entirely
onsite, where such remedial action is selected and carried out
in compliance with this ~ection." During the continued
operation of the landfill, the operator will have to develop and
operate the site in compliance with all applicable laws and will
have .to obtain various permits from time to time, when these
laws require them. The continued operation of the landfill,
involving the placement of wastes in the landfill and the
operations associated with this, are not part of the remedial
action. Only those actions that are part of the final remedy
selected in this ROD and that are conducted entirely on-site are
exempt from having permits. Placement of the final cover system
and modification of the leachate and gas extraction systems are
some of. the actions that do not require permits because they are
part of the implementation of the final remedy. Placement of
wastes, operation of the leachate and gas extraction systems
prior to final cover placement, and groundwater monitoring
required of an operating landfill are some of the activities
that will need permits if they are required by Federal, State,
or local authorities because they are part of the day-to-day
operations of an operating landfill. Conditions of the current.
IEPA operating permit must be satisfied.
The groundwater extraction system has been described in Section
VILA. The duration of operation and the conditions under which
its operation can be discontinued are discussed in section
VII.R. This system will be installed and operated to prevent
the migration of contaminated groundwater from the western edge
of the site and to remove any contaminated groundwater that
exceeds the levels specified below and that has passed beyond
--Page 26--
Pilei" Pit Sile. Reeord of Deciaioll SImmIuy
.
-------
the western boundary. This will necessitate the full
determination of the extent of the contaminated groundwater
along that boundary. . This extraction system will be operated to
maintain the concentrations of contaminants in the groundwater
downgradientof the line of wells below the specified levels.
These specified levels are MCLs or non-zero MCLGs, except that
a cumulative carcinogenic risk of 1X10~ and a cumulative HI of
1.0 will be used for 1,1-dichloroethene, arsenic, and those
contaminants without MCLs; groundwater cleanup standards below
detection limits using USEPA approved methods for analysis of
drinking water may be modified. MCLs and the 1X10~ risk level
have been selected because concentrations in the neighborhood of
a 1X10~ risk are often below reasonably achievable detection
levels.
This aquifer has been classified as a Class II aquifer under the
USEPA's Groundwater Protection strategy and is widely used as a
source of .drinking water. The proposed containment of
contaminated groundwater is consistent with USEPA' s goal of
returning usable aquifers to their beneficial use.
The groundwater along the sides and the upgradient boundary of
the waste disposal area will be monitored to ensure that.
contamination is not leaving t~e site in directions other than
along the western boundary.
In Alternative 5 (see Section VII. F) , the extracted groundwater
will be treated on-site by carbon adsorption to remove VOCs and
SVOCs. Extracted groundwater (estimated at roughly 100 gpm from
about 6 recovery wells) .is. first routed to a pretreatment
process' consisting of a solids filter where the particulate
concentration is reduced to an acceptable level. The water then
goes to a two-vessel granular carbon. adsorption system operating
in a series mode. Spent carbon will be transported off-site for
thermal regeneration at an approved regeneration facility.
Because of the presence of chlorinated compounds, some of which
are not easily adsorbed, it may be necessary to add a
pretreatment step for their partial removal in order to reduce
carbon usage rates. Other treatment, such as
coagulation/flocculation or ion exchange, may be used for
removal of inorganics if needed to meet discharge requirements
or prevent interference with the organics treatment process.
These additional treatment steps have not been included in the
cost estimate. The treated water (effluent) will be discharged
to Killbuck Creek and will be monitored periodically. All solid
waste products will be disposed of as their characteristics
allow.
In Alternative 6 (see Section VII.G), the extracted g~oundwater
--Page 27--
PileI'. Pit Site, Rccord or Decilioa SIImmIJy
.
-------
will be treated on-site by air stripping to remove volatile
contaminants. The extracted groundwater first flows through a
solids filter and then flows downward through the stripping
column. Air blowers will provide counter-current air for
stripping of the volatile. contaminants. Air emissions from the
column are expected to be low enough that treatment will not be
required. The discharges from the air stripper will be subject
to the approval of IEPA, will not be allowed to exceed health-
based levels, and will have to meet all federal and state
requirements. Carbon polishing of the water effluent from the
stripper and treatment for removal of inorganics will be added
to the treatment system if they are needed; they have not been
included in the cost estimate. The treated water will be
discharged to Killbuck Creek and will be monitored periodically.
All solid waste products will be disposed of as their.
characteristics allow.
The current leachate collection system will be upgraded by
installing dedicated pumps in some of the gas extraction wells.
The manholes connected to the perforated pipe for leachate
collection will be equipped with dedicated pumps. These pumps
will be equipped with automatic level switches that. will keep
the level of leachate no more than one foot above the bottom of
the manhole or well. The extracted leachate will be pretreated.
at the site by the current aeration system; the pretreatment
system will be modified as necessary in order to continue to
meet the POT~'s pretreatment requirements. The extracted
leachate will be sent to the POTW for treatment and disposal via
a sanitary service line connected to an existing sanitary sewer.
The leachate management system will be operated for the length
of time specified in section VII.K.
The gas extraction system will be modified as described in
Section VII.A. It will be operated for the length of time
specified in Section VII.K. It will be operated so that the
standards in 35 IAC 811.311 will not be exceeded.
Insti tutional controls may be employed. Deed restrictions
limiting the development of the property and the placement of
. new wells on the property and adjacent to the site may be sought
vOluntarily from owners or compelled to the extent authorized
under any applicable local and state laws. If any property with
groundwater contamination that is attributable to the Pagel's
pit site requires an alternate water supply, an alternate water
supply will be provided. The groundwater, surface water,
landfill gas, leachate, and landfill cap will be monitored. The
cover system, the gas and leachate extractiori, handling, and
disposal systems, the groundwater extraction, treatment, and
disposal systems, and any other systems installed as part of the
remedial action will be properly operated and maintained.
--Page 28--
Paa~I'. Pit Sile. Record of Deci.ioo Summuy
.
-------
There has been a proposal that a new landfill be constructed on
land immediately south of the Pagel's Pit site. This proposal
includes the future placing of wastes in the space between the
two landfills once the new landfill to the south has been
filled. It is further proposed that additional wastes be placed
on top of both landfills to a specified elevation. This
placement of wastes on the top of the Pagel's Pit site is not
part of the wastes that have been mentioned previously which
will be placed to reached the presently permitted elevations and
capaci ty. When the presently permi tted capaci ty has been
reached, the final cover system will be installed.
Whether additional wastes will be placed on the Pagel's Pit site
at the time the south landfill reaches capacity will be reviewed
as part of the five-year review process. The deed restrictions
for property development will include a prohibition on the use
of the land covered by the cover system for any future
development that might interfere with the effectiveness of the
cover system unless such use is approved by USEPAi this would
include the construction of a landfill or the placement of
wastes. Construction of a landfill on top of the closed
landfill (Pagel's Pit) will require approval of USEPA and the
permitting authorities.
x.
STATUTORY DETERMINATIONS
The Proposed Plan for the Pagel's Pit site was released for
public comment in April 1991. The Proposed Plan identified
Al ternati ves 5 and 6 as the preferred al ternati ves. USEPA
reviewed all written comments received (no oral comments were
received) during the comment- period. Upon review of these
comments, it was determined that no significant changes. to the
remedy, as it was originally identified in the Proposed Plan,
were necessary.
A.
Protection of Human Health and the Environment
The baseline risk assessment performed for the Pagel's pit site
identified one exposure scenario that resulted in
noncarcinogenic health effects that may be of concern and cancer
risks that are sUbstantially greater than the USEPA's suggested
risk range. This scenario was for the use of the contaminated
. groundwater at the site as a water supply, and the exposures
were due to ingestion of and dermal contact with the water and
inhalation of vapors that might arise from the water.. These
risks are addressed by the selected remedy by extracting the
contaminated groundwater before it leaves the site and treating
it before discharging it to surface water. This groundwater
extraction system will be operated until groundwater leaving the
site will result in a cancer risk of no more than lXl0~ and a HI
--Page 29--
Pilei'. Pit Sile, Record or DecisioD Summ.uy
.
-------
of no more than 1.0 or the contaminant concentration will be
less than the MCL (modified in the case of some contaminants).
Since it was known that it was necessary to install a landfill
cover system over the wastes, no sampling of the surface soils
was done and no risk assessment for exposure to these soils was
performed. The landfill cover system and gas and leachate
extraction systems will provide the required protection from the
wastes that are being left in place.
Use of air emissions controls on the air stripper, if they are
required, will protect against exposures during the remedial
action. Discharges of treated water to Killbuck Creek will be
regulated by the NPDES requirements, which will ensure that the
remedial action does not adversely affect the stream.
Based on the present levels of contaminants detected in the
aquatic 'ecosystem, ecological effects are not expected. Based
on the fact that the groundwater is the main means by which
contamination is transported, te~restrial ecosystem effects are
not expected.
B. Compliance with App~cable or Relevant and Appropriate
Requirements
Either of the selected remedies will meet ,all identified
applicable or relevant and appropriat~ requirements, both
Federal and State. The following ARARs have been identified.
Chemical specific
SDWA national primary drinking water standards (40 Code of
Federal Regulations (CFR) 141)
Clean Air Act (CAA) national ambient air quality standards
(NAAQS) (40 CFR 50)
CAA national emission standards for hazardous air
pollutants (NESHAPs) (40 CFR 61)
Illinois water quality standards
Administrative Code (IAC) 302)
Illinois general effluent standards (35 IAC 304)
Illinois sewer discharge criteria (35 IAC 307)
Illinois air quality standards (35 IAC 243)
. Action specific
CWA NPDES administered permit programs (40 CFR 122)
CWA NPDES standards (40 CFR 125)
CWA pretreatment standards (40 CFR 403)
RCRA definition and identification of ' hazardous waste (40
CFR 261)
RCRA standards for generators of hazardous waste (40 CFR
262)
(35
Illinois
PIIel'l Pit Sile. Record or Deciliao Sumawy
--Page 30--
.
-------
RCRA standards for transport of hazardous waste (40 CFR
263).
Occupational Safety and Health Act (OSHA) general industry
standards (29 CFR 1910)
OSHA safety and health standards for construction (29 CFR
1926)
Department o~ Transportation (DOT) rules for transportation
of hazardous materials (49 CFR 107, 171) .
Illinois regulations for solid waste (35 Part 807)
Illinois regulations for special waste hauling (35 IAC 809)
Illinois regulations for solid waste disposal (35 IAC 810)
Illinois standards for new solid waste landfills (35 IAC
811)
Illinois regulations for permit application (35 IAC 812)
Illinois procedural requirements for permitted landfills
(35 IAC 813) .
Illinois standards for existing landfills and units (35 IAC'
814) .
Illinois procedural requirements for exempt landfills (35
IAC 815)
Illinois waste disposal regulations (35 IAC 700, 702, 703,
70?, 720, 721, 722, 723~ 724)
Illinois landfill regulations (35 IAC 729)
Illinois requlations f~ prohibition of air pollution (35
IAC 201)
Illinois regulations for emissions of 'fuqitive and
particulate matter (35 IAC 212)
Illinois organic air emission standards (35 IAC 215)
Illinois NPDES permit regulations (35 IAC 309)
Illinois pretreatment programs (35 IAC 310)
Illinois treatment plant operator plant certification (35
IAC 312)
Illinois recommended standards for sewer works (35 IAC 370)
Illinois regulations for major stationary sources
construction and modification (35 IAC 203)
Illinois sulfur limitations (35 IAC.214)
Illinois carbon monoxide emissions for incinerators (35 IAC
216) ,
Illinois nitrogen oxide emissions, fuel combustion (35 IAC
217)
Illinois sound emission standards and limitations (35 IAC
901)
Location specific
National Environmental POlicy Act, wetlands and floodplains
and fish and wildlife (40 CFR 6)
Illinois floodplains construction permits (Ill. Revised
Statutes, Chapter 19, Paragraph 65(f»
To Be Considered Criteria
--Page 31--
PIIC)'S Pit Sile. Record of Dec:isioD Summary
.
-------
SDWA maximum contaminant level goals (40 CFR 141.50)
CWA proposed sludge disposal criteria and state sludge
programs (40 CFR 258, 501, and 503)
c.
Cost-Bffectivene..
The lowest cost alternative involving some remedial action is
Alternative 2, Planned Closure, at $7,500,000 for the total net
present worth. This cost approximately represents the cost for
the normal closure of the landfill and, therefore, represents a
base cost for the remedial action. This alternative does not
provide a means for stopping the movement of the contaminated
groundwater from the site. The total net present worth for
Alternative 6, $9,800,000, is the least costly alternative that
provides a barrier to the migration of the contaminated
groundwater, something which the remedial action must provide.
Alternative 5, with a total net present worth of $11,000,000, is
slightly more costly, based upon the assumptions made in the
cost estimates, but it might be found during the design to
provide some advantages in the treatment of the water. Thus,
either alternative is cost effective for providing the
protection that is required at the site. No benefit. was
apparent in treating the le~chate on site rather than at the
POTW in view of the increased'cost. The leachate has been going
to the POTW .for a number of years, and no adverse effects from
this practice have been demonstrated. Treating the groundwater
at the POTW has the disadvantage of sending a water to the plant
that contains low levels of contamination; the POTW does not
allow such materials as stormwater, groundwater, and surface
drainage to be sent to the POTW. .
D. utilization of Permanent Solutions and Alternative
Treatment (or Resource Recovery) Technologie. to the
Maximum Extent Practicable (MEP) .
. .
USEPA and IEPA believe that the alternatives selected represent
the maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner. The
selected alternatives provide the best balance of long-term
effectiveness and permanence, reduction of. TMV through
treatment, short term effectiveness, implementability, and cost,
taking into account the statutory preference for treatment as a
principal element as well as state and community acceptance.
B.
Preference for Treatment as a principal Element.
This site is a sanitary landfill, and it is generally recognized
that containment will be the main method of addressing the
wastes, which pose only relatively low, long-term threats to
human health and the environment.
--Page 32--
Pilei'. Pit Site, Record of ~i.iOll Summary
.
-------
Treatment on-site is being used to address the contaminated
groundwater, which represents the greatest identified health
risk. Leachate will be sent to the POTW for treatment.
Landfill gas will be burned on-site.
This remedy does not. satisfy the statutory preference for
treatment as a principal element of the remedy. The size of the
landfill and the fact that no on-site hot spots representing
major sources of contamination have been located preclude a
remedy in which contaminants could be excavated and treated
effectively. No principal threat has been identified at the
site. .
--Page 33--
. Pilei'. Pit Site. Rccord of Dcciaioa SumIIwy
.
-------
Table 1
selected Groundwater Results, Four Rounds of Sampling
Well Chlorinated Ethenes, ug/l Chloride Ion, mg/l Specific Conductance, umho/em
815 0.6 3.0 -- -- 609. 860. -- -- 4390 5620 -- --
815P 17.3 15.2 15.0 18.0 14. 15. 13. 10. 660 630 585 610
815R 22.8. 19.8 6.6 10.0 477. 348. 529. 459. 4130 3300 3840 3365
P1 12.0 21.6 7.0 9.0 252. 176. 65. 80. 2200 1610 1220 1255
MW106 18.9 21.2 -- -- 430. 378. -- -- 3310 2980 -- --
P3R 16.2 12.1 6.0 7.0 47. 46. 72. 77. 1010 1090 535 1240
P4R 53.9 47.1 30.0 30.0 149. 188. 25. 28. 1380 1360 680 790
G116 0.0 0.0 0.0 0.0 7. 7. 7. 7. 530 625 645 645
G116A 12.3 27.5 12.0 22.0 41. 99. .' 39. 38. 780 1030 875 950
I G115 II 21.4 I 23.0 I 1.0 I 8.0 I 40. 48. 178. 191. 1510 1410 1620 1840
813 243. 268. 219. 215. 28. 32. 33. 34. 1180 1400 1260 1220
P6 89.2 164. 51.0 80.0 16. 18. 16. 20. 640 665 615 655
G110 23.0 127. 8.0 25.6 166. 234. 379. 523. 1420 1820 2380 3590
G114 14.8 11.6 3.0 1.0 42. 44. 176. 134. 1550 1540 2080 1910
812 137. 116. -- -- 22. 25. -- -- 1550 1510 -- --
G109 24.1 18.6 33.0 4.0 28. 27. 20. 10. 1410 1390 1470 1260
G109A 99.0 115. 107. 73.0 62. 60. 73. 70. 1640 1520 1590 1450
G113 34.4 24.0 -- -- 30. 29. -- -- 1680 1620 -- --
G113A 310. 534. -- -- 30. 28. -- -- 1430 1480 -- --
.
......-. PIt 5100, ...... of Dodolaa ibmIuy
--Page 34--
-------
Selected Groundwater Results, Four Rounds of Sampling
Well Chlorinated Ethenes, ug/l Chlor ide Ion, mg/l Specific Conductance, umho/em
~I -- I 57.1 I 59.0 I 50.0 I -- 22. 22. 26. I -- I 670 I 755 I 685 I
0.0 0.0 -- -- 10. 12. -- -- 630 660 -- --
814
GI07 2.2 10.2 -- -- 20. 16. -- -- 690 620 -- --
G118R -- 0.0 -- -- -- 33. -- -- -- 730 -- --
Gl18A 0.2 0.0 -- -- 12. 14. -- -- 410 617 -- --
G117 0.0 0.0 -- -- 28. 26. -- -- 780 770 -- --
810 23.6 27.7 -- -- 15. 17. -- -- 1230 815 -- --
GI08 27.7 16.0 -- -- 9. 11. -- -- 1010 1080 -- --
811 1.1 0.8 -- -- 5. 6. -- -- 680 760 -- --
.-
811A 14.1 16.4 -- -- 9. 11. -- -- 840 840 -- --
G112 1.1 1.0 -- -- 29. 34. -- -- 1310 1430 -- --
Notes:
The chlorinated ethenes include vinyl chloride, 1,1-dichloroethene, trichloroethene,
tetrachloroethene, trans-l,2-dichloroethene, and cis-l,2-dichloroethene.
For each parameter, the data are shown for the four rounds of sampling in the order in
the sampling was done. .
Well locations are shown on Figure 4.
which
.
"""0 '" Sito, -- of DocioIaa -.,
--Page 35--
-------
~able 2
Coat Eatiaatea for R..edial Action
Alternative 5: On-Site Carbon Adsorption of Groundwater
Alternative 6: On-Site Air Stripping of Groundwater
Direct CaDital Coata
lAC 811 Compliant Cap (47 acre8)
Upgraded Gas Collection System (53 well.)
Enhanced Leachate Collection SY8tem (42
pump. ) .
Service Pipeline to POTW Sewer (5000 f.et)
Groundwater Extraction/Collection Sy.tem
. (6 we1l8)
Groundwater Treatment Sy.tem
Organic Pretreatment Contingency
Groundwater Monitoring Well8 (9 well.)
~otal Direct Capital Coata
Indirect CaDital Coata
Mobilization
Health & Safety
Engineering Design
Startup Costs'
Permits and Document8
, of CaDita1
5'
10\
5\
S\
10\
~otal Indirect Capital Coata
TOTAL CAPI~AL cos~s
Annual CDeration 'Maintenance Coata
Site Maintenance and Monitoring
Gas Extraction/Treatment System
Leachate Collection/Treatment System
Groundwater COllection/Treatment SY8tem
Insurance
Reserve Fund
Administrative
~otal ADDual 0 , K Coata
~otal a & M Net Prea.nt Wortb
~O~AL NE~ PRESE~ WORD
Alt. 5
~
$2,863,000
$412,000
$335,000
$556~000
$120,000
$150,000
$100,000
$48,000
$4, 62.0, 000
$231,000
$462,000
$231,000
$231,000
$462,000
$1,620,000
$6,240,000
$41,400
$25,000
$16,300
$157,300
$10,000
$10,000
$50,000
$310,000
$4,770,000
$11,000,000
Alt. ,
~
$2,863,000
$412,000
$335,000
$556,000
$120,000
$72,000
$48,000
$4,410,000
$221,000
$441,000
$221,000
$221,000
$441,000
$1,550,000
$5,960,000
$41,400
$25,000
$16,300
$95,300
$10,000
$10,000
.$50,000
$248,000
$3,810,000
$9,800,000
Note: Net present worth i8 based on a 5\ discount rate and 30 years.
PopI'. PIt Silo, -- 01 Docioias s-.y
--Page 36--
.
-------
------ .
35 ;oi, - - -... .
... .,., . .. ! . .. -11-. -..... ' ,.,. '- - ~ ,
" -'---- ---'-----"'.~---",--- - "-.' -
. : " - - -- - : 'I \ ;--.. ~~
-) '~"""'" I .:.--- T,.,I" p.,. I \........-;.
/:\" ", . !---- ~ ~Ia-- ' "
: ',"": ;-~ --......:~.
. ",: -;c:.'~:~Iorristown" '.' . ~~
. 'JJ -,,:,'. ° .. .' .~~. "_v
,6 \'---~- -- _.. T!Ji ...--.~- -
; ...~":.:,.~..- .;
\ ".. " ~ ' ------, .co. /
- " ~ , ~'---'"" .' -;.
\ -,' '...... -- I .~.. ----- , -. ....----:
..... - ':,--~ '- '""'--' ' ., ,/
\:-:~ ~~-----,._-_._., NORTHERN ---..,-~/..:-_-'
", - - ~ '" " - INTERMITTENT ".....r r-:-
". . ." ~- CREEK' -,' :
.! ~ ;;......;- ,~" ' ;
- , v ~ '" I' -, , CUI'ry G""I'
. , i I '. , -- ~. 1 ~ .A.Jtf'i-!q ..~ ..- \'.' ~9 "'1_'..
....... -._----~ ~ -~. - .-
'- ,.:';?'!Ol.:.. ~---......- '\ I~'.' '.. :'.', ...:...--_~ .
'OU5~ PRt3tRI'E ..." :/ \,.-... '....... ~ ./'''! "
~, : '--- ''., I ~ :;""1 ---- ,,, " " ./ !
0: l \ ' " ";"1 -~ '-..../ :
<0 .........;-...... ~ /"'9!,~C(l~~ ' :' ;
.--. '.;..-0' 'RAI~"" - c- - ,t . "'---, - ; I"G",~I,:,
~ -'-u.' '/"-'" ' ;~~P'I',.
WRL -"",...,,, t""I.o \' '~:: ACME S~L~~j (,- ! ,-
"~' .'~ -..- -I 'X""; '- ,"- . I
'.: >,:.~' .'-.;,~>",(~",' -,./' ,"-'; , .
'.::'\.- . "- ". .~\ / Qa...-.~'..-==-.... .~. -. -
- 36 ':\ ',.. '-.::~, - ~ cu.",.:] ,,-'.. t' ,
USGS STATION ,;~' ' -" I ,: ~ "~. -,.:,::"~"""""~::;'''''''''~:
'\ ~.:./..., '\.i~'f.. '
, ..Jo !-' . ~".::p ; -.... :
, -":" -: ~....' . I
"~h)~' I::,' .,'
j~ ~.... I ((' SOUTHERN CREEK ,-..-...-
:f ..~ ..... i \~..'
~~: .,:.. .:,~ . - !
'~\:I-', ., "'~~r""'~ .
. '.~' 1: , ;"'J. .. .:.. -' ~1 ° .
--~I- ,. ,I -', ,-
{ \ ,'--,--/ M
1\, \ \' i \,
I"'.'" .......... ',I ("
'(~~~" - I \\.~ 'r-~------,=_J\~J >
v " I /; ..., ( ('~: i\ )
'.~. II ' I v
. ----- ~ll; \.', 6 ~,.'
l' .' \.. ~ -r ~t44------?--- ,~" : "---{'I
:' ~ J .lJJ fJ :, '" / \ I ~/
'< ~". (o~~_:.:::: .\.;~ '''-.J \,~,'!/ !
"" "(' ~ r-----,-\----------------:!..~--_:
-------,---"'-..; ; ----'ll ,( =;;, '/ \ ..:
" i / i\:'1 \. --~ / _I
.~ . " .."..." r,. ' - ,
, . .--::::::-~ /1 ':~; j'-... \ /"" i -.:,;" C!
~. '~'....,;"".... .."go".. "1.1"- .': ':"!? ~~I 7'11 .-. !-~_. :
R1E I R2E
r'o:"""
"~"
. '.. I~!
~.:"v::.
. .. ~
.' /' ,
---' -'-
'/
7 G"..~ '"
~- '.1)'1 I' :
/ " ,
: \ -k.Il.'->--':'
,,'-- '~~/;- , /. B I,
~/ '"" ~ C'"r
""'-
"
........
Z
CO)
~
I-
"
-
,-
-!.:.!......:.;~
- I~!
'_0 ~!!....
z
C\I
~
I-
--/
\
i
,'"""" r..J
/ V
"
"
"..
~-----
~
o
----_. }\
'-'
,
".....
-
,- ,
..,:.,
"
\
'--,
SASE MAP DEVELOPED FROM ROCKFORD ,SOUTH, ILLINOIS
7.5 MINUTE USGS TOPOGRAPHIC QUADRANGLE MAP
DATED 1971 PHOTOREVIS:D 1976
Figure 1. Location of Pagel's
Site (Winnebago Reclamation
fill (WRL»
Pit
Land-
~.
north
SCALE: 1°-2000'
... ,
DWN I.r.... -'
13160
WARZYN
~
A 1 I IIIWG1""'...'lIIIfa ItIIC
SlfE LOCATION MAP
WINNESAGO RECLAMATION
LANDFILL
ROCKFORD. ILLINOIS
.
-------
LEGEND
1rG1I3 MONITORING WELL LOCATION & NUMBEiI
~SB-I TEST BORING 1.0CATION & NUMBER
755
BEDROCK SURFACE ELEVATION 1FT. MSLI
BEDROCK SURFACE CONTOUR
no- !DASHED WHERE It-FERREDI
APO'!OXIUA!t lUT
wAStE DISPOSAl.
-EIIAGO RECt.WAt1OH ~L
<669
GII9A
#
~
-I~'.
\
""01
-$-788
NOTES
t . CLUSTER OF WE1_LS SHCWN AS ONE SYMBOL
FOR ClARITY. .
.
-$-""07
738
Clt6
..
C~m
KU'UCK
CREEK
~
o
"
o
8
~
..
o
z
::;
-$-
83
<702
Figure 2.
Bedrock Surface
~
north
o 800 1200
~
SCAlE IN FEET
...
I ~
~
~
e
..IJ
~ "-
~ ~
~ '
J ;
) J
~~
[j~
; \
. ~~ i
j i I ~ ;
~i
~i
. J
~
...
"
:>
..
i
~
A
! ~
!H
~~
~ ~
~.
"
e
..
....--
13160 87.
_1IrnI
--
-.
-------
1CI1IBUCK
CRUM
.
~~i':n[Nr
:~X"""[ llYlT
WlNNE:SAl
A£Cl-UIAOOH l.VIOntl
(m:l)
#
CII'
107.3.
/"
/
~
~
Q
o
z
:J
-$-
9J
(7J8,I~)
(Cl.'Y)
Figure 3.
Potent"
10metric M
ap, June 16
.
1988
LEGEND
~G"3 MONIT
-fSG-r SfN=F ORING WELL LOCATION
G!\lX>E LOCA & NUMB
720.21 GROUNOWATE riCH & NUMBER ER
WELL (FT. MS~)ELEVATION MEASU
GROUNOWA RED IN
,1721.201 PRIMARILY J~R ELEVATIONS F
~.~~~~~~~~?igR~~n~ir~~~~~R~O:
118- GROUNOW ELOW WATER LY
(CASHED ~~~~~TOUA LINE TABLE. ETC.I
NOTES INFERREOI
1. . CLUSTER
FaA CLARITa: WELLS SHOWN A
. S ONE SYMBOL
""'0'
-$-
~
o north
600 12
,~oo
SCALE IN FEET
.'
G'
:::
:I
!;:
~
~
1=
;I ~
3 z
~ ~
:jg
~~
z "
z 0
i ~
,,;
..
z
1
~
o
, ~
:I
o
0=
Z
~
o
..
. "
-------
~~GEND
~G1I3 MONITORING WELL LOCATION & NUMBER
13
GIItA
.
/'
/
;' :NTERMITTENT
STREAM
"'-",..--
CHLORIDE CONCENTRATION Imglll
CHlORIDE CONCENTRATION CONTOUR
-100- LINE Imglll
.. SO-I STN'F GAOOE LOCATION & NUMBER
NOTES
1. . CLUSTER OF WELLS SHOWN AS ONE SYMBOl
FOR CLARITY,
30
\
GII' 33
I GIIIIR J
".~,.,~~' IT '\
-$- ,. 15 810 ".
Glt7 _~.815P-:I\~' 81M. --",
Z~""""~-=81~ ~~ r----......... . It "
~.-.....-:..e-~-- -~r-,- '108 IT "-
378"'," I - -- ~ \ 11 811
""108 'T.'. -~::-- -- /~ \ .Jl!.!.~-_..8-_~~---------+--------'----..
-ar"' ,- - ~ ~----..---... . 82 81 \
5G":~;;:- _300- -wINNE AGO \ 8llsn-...u.DllA"'~ I
p ......P.EClAMATION ~' u -~sn-50 ~t1. ACME SOLVENT ,
. ".--100 LANDFILL Gfo A Gm ZI '~........ 'I
u ZT .~ --$;' ~/
~ U.""'GI!i!f Glog.. P' ~----7;':':'-=-+~~0~
" GlIO~..I 2~ 225 B9 -$-1IW202
,~ ,""""qIt"OV GII I" 1''''105 .: " ,
~.... .. -"I. WW201A'
.... ..."IJIJ GIIJ IAtIOl9 \." \..Ib.~
AL', ..."'" 3Z" n 11 860 "'-..../ ~
~"5 '..-.... U 865 P9
q' . ~
G~~I . ' 98 -$-
, ""104
-$-\/WI07
.
~
north
o 600 1200
~
, SCALE IN FEET
t.
12
$-
BJ
a
-(
o
a:
o
o
o
~
~
a
z
:J
-$Pw,
13
Figure 4.
Chloride Concentrations, Round 2
I
I
I
I I I
III~!
~
....
:!i
~
....
z
o
~
..
:: ~!'!
o ....0
IZ uz
9 ~3
J: 0-:
u Clo
,. .:~
o Id"
Z z><
:2 %0
~ J:i!
"
1316f.B22:
_IIZYII
.....
-------
LEGEND
SGII3
MONITORING WELL LOCAnON & NUMBER
CHLORINATED ETHENE CONCENTRATION
luglll (PCE, TCE, DeE & VCI
30
NO
NOT DETECTED
NOT TESTED
~.
/
(INTERMITTENT
STREAM
"'-....-.
NT
.50-1
STN'F GALGE LOCATION & NLNBER
NOTES
t . CLUSTER OF WELLS SHOWN AS ONE SYMBOL
FOR CLARITY. .
1.57
CI19A
#
CIII NO
NO ClIP J
.. ~...
'~..' ClitIA 1;'07 U 7 '\
-$- NO NO 1'.1 ..70 810 "-
cm NO 3 815P ~~5~381OA . _d.
81'~ . --..... NT
..P7 .. ------",. .. '.
QI ------ -.....--- 'CI0S II.!'\.
10.43 . r- \ ~5.. 818
"''''061~.,J \ t~~:---=4 -=~7"---------+-------~---'
, WINNEBAGO \ 811 8111A ........~ 82 8\'
r,;l RECLAMATION ~' NNOO i1I-~S:~50 ~tl ACME SOLVENT :
. n.07 LANDFill ,~~.I GII2 . NO '~"".... I'
\ 11.'5 1... ..\ '-$;'.12... -,oj
2\ 128.. GI¥ Glog -$- P' "'----7~:':==~--~
-2 " CIIO~ 532 ~' 2 US.. lit -$-UW202 "'10
" "....~. CllJA. I NO 0.UIIWI05. :
.... ~"1fjj CII] =:~'..:
.'" ,." 1...1 1.0 U.03 ...5886D~' ""\£1'11
"'15 ""..-... N086S ~
~..
-$-- B5~
GIll ~
57.1 -$-
.....,0.
\
-$-IIWI07
.
~
north
o 600 1200
~
SCALE IN FEET
i.
NO
$-
83
a
-<
o
a:
o
o
o
~
z
'"
o
z
::;
~WI
NO
Figure 5.
Chlorinated fthenes Concentrations, Round 2
..
..
Z
III
X
to
a
..
!C
z
ii
o
~
x
o
..
-------
.
~~END
$0113 MONITORING WELL LOCAnON & NUMBER
'00
~DUCTIVITY lumhos/cml
NOT TESTED
1\
NT
-+ 00-1
ST~F GIlU3E LOCAnCJII & NUMBER
100
G119A
.
~'
/
r INTERt.lITIENT
/ STREAJ.A
"'-- ' ' ' ---(.
NOTES
1. . CLUSTEFI OF WELLS SHOWN AS ONE SYMBOL
FOR CLARITY,
\
G119 NT :
410 GnSR J
" ~..,
'---...,,' GlleA IUO "\
-$- "0 110 .10 910....
0117 '00 1310 9151' ::~: ~IOA "'--.,
tl1P1 91~ -..---"", NT 1010 ",
~ ,------ -.....--- \ IDS 110"-
3310 r . \ .10 911......
.81114 --8.-... ----------~-
WIDS 22001 . \ ~---=-.-~ - ~---------...,.- -qr --..
I : WINNEBAGO " .:~\':':"9~;"" ~ 92 91 \
;JR-mL RECLAMATION ~ 1)10 -~sn-5D~,l ACME SOLVENT I
jOIl'~ LANDFILL 1110 0112 no ':-0, II
13.. 01 " ...
\ 1550 I" '\ ""..$;'" ..J /
2\ . ~~~~~~~:I:.. 89" tI" " ;:;;-7':':':':=-'';;;-~
'.... . ," GIlJA I .00 "OUWI05. : .
" UW201A ' ,
~ . ,'1f13 GI13 IIW2DI9 \," "'\.Jb. '
'... ,." 1110 ':0 1180 57 0 I18D "-./ ~1'8
GII' ''''-'' .50965 pg
ISW ' .
'-$: 9'""1""
.;111 118 , .
NT ~
UWI01
-$-""07
.
~
north
o 600 1200
~
SCALE IN FEET
t.
'30
.$-
93
o
«
o
a:
o
o
o
~
Z
!oJ
~
:J
-$-::J
Figure 6.
Specific Conductance, Round 1
-r~
-;!I~
.~~
J J
..i
~
,:' "
~,
.
J ~
"
~~ i
I I I
I I I ~ !
!I
i
.
I
.J
.. -'
o Ii:
z CJ
~ ~
o -'
~ . z
z 0
o ~
o :2..
!:! ~o
.. uz
U uo:J
.. a; -'
.. 0-:
.. ,,0
""a;
1110
D UO'"
Z . z)l::
:> zO
~ i~
m60B27 :
~I
-------
:~;C' -.;~. Appendix A
... ~'/:;'
ADMINISTRATIVE RECORD INDEX
PAGEL'S PIT LANDFILL SITE
ROCKFORD, ILLINOIS
fICHE/fRAHE PAGES DATE TITLE AUTHOR RECIPIENT DOCUHENT TYPE DOCNUMBER
.
3 75/11120 Letter re: Receipt of Michael~. Rapps, USEPA Rocltford Blaclttop Correspondence
series of requests for Constr.
issuance or renewal of
certain supplemental
permi tS
5 8D/Olo128 Letter Re: Hydrogeo.l 09 i c Steven G. Wittmann and (.Howard, Blktop Correspondence 2
Investigation, Pagel Pit Daniel R. Viste, ~arzyn Canstr:
Landfill Engineering, Inc.
, 80/1 0/1 0 Letter re: leachate for Violet Chen, Sanitary ~. Foristal, RSSI Correspondence 3
the EP Toxicity Test for District of Rockford
Pagel Pit
9 810/010/30 letter re: At"tachec Richard ~. E iCk, D. favero, IEPA .Cor resconcenc e
copies of Pagel Pit Sanitary District of
leacnate analysIs ~ockford
2 810110/19 letter re: PropOSed Ridgway H. Hall, Crowell ~. Hedrman, USEPA Correscondence -
Amendment to CERCLA & Horing
National Priorities List
2 8'/10/22 Letter re: Proposed Ridgway H. Hall, Crowell L. friecinan, USE?A Correscondence ~
Amenament to CE~CLA & Horlng
National Priorities List
::10/10/22 letter re: ?rocosec ~idgway II. Hall, C.owell R. Bart l ett, USE"~ Cor.esponcence
Addition of PageL's Pit ~ Horing
to tne NatIonal
Priorities
List
3 810/12/06 Letter re: ?rocoseo ~idgway H. Hall, Crowell 101. Hedeman, USEP~ Correscondence
Amenanent to tl'le CE~CLA 'Moring
National Priorities list
7
85/03/27
Letter re:
SuppLement
Ridgway II. Hall, Jr.,
Crowell & Horing
O. favero, USEPA
Correspondence
;
to ComnentS in
Response to EPA's
Notice of Proposai to
Add Sites to the CE~lCA
National Priorities
List (Proposed
Octocer , 5, ~ yaL )
;
:5/07/12
letter -e:
:!"c~:-:~.at~r
.ames A. ~ill ana Oaniel
10'. Hall, ;':arzyn
Eng i neerl ng
C. Howaro, \,';nne~a;o
-::: ~ ~ es~cnce~c ~
I eve l r:1on It Ort n;
.
-------
Page Ho.
:~/12191
2
ADHINISTRATIVE RECORD INDEX
PAGEL'S PIT LANDFILL SITE
ROCKFORD, ILLINOIS
fICHE/FRAHE PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCNUHBER
Inc.
86/08/28
Letter re:
Aaninistrative
Lisa Seglin, USEPA
R. Hall, Crowell &
Horing
Correspondence
11
Order by Consent and the
date of the press release
z
86/10/09
Letter re: Comment
period on the
Aaninistrative Consent
Order (receipt attached)
Lisa S. Seglin, USEPA
G. Marzorilti
Correspondence
12
2
87/01/21
Letter re: Pagel's Pit
Aaninistrative Order by
Consent, USEPA's comments
on Receptor/Pathway
Analysis
David Favero, USEPA
G. Harzorati,
lIimebego
Correspondence
13
i!7/1D/08 Letter re: liarzyn James A. Hill ana Daniel D. Faver~, USEPA CorresPondence 11.
Project Hanager for the II. Hall, lIarzyrl
Remedial Investigation Engineering, Inc:.
activities
Z 88/01./22 Letter re: Corrmenu Robert T. Kay, United K. Waldvogel, USEPA Correspondence 15
concerning sameling at States Department of
Pagel's Pit Interior
6 a9/05/2~ Letter re: Enclosee ~ooert Kay, Uniteo States B. Schorle, USE?A :"rrespondence . i6
copies of stream Tl ow ~epartment of Interior
ana water ~uality cata
for Killbuck CreeK soutn
of New Hilford
3 89/05/31 Letter re: ROUnd IV James A. Hill, \larzvn B. Schorle, USEPA Corresponaence 17
leachate Samel ing Pagel's Engineering, Inc.
Landfill
15 89/10/16 Letter re: Comnents Robert Kay 8. Schorle, USEPA Correspondence 18
concerning technical
matters at Pagel's Pit
89/10/20 Letter re: Locaticns of Sernard J. Schorle, G. Harzorat i , Correspondence 19
aeditional wells USEPA \linnebago
:9/10/21. Letter re: Projec: oJ aIMS A. Hill ana Gary E. B. Schorle. liSEPA ::rresconeence ~.
S,,~tu~. "';"'"!!'oagc :larlCe!'", IJar%vn
ReclamatIon Lano;;i;, :"'gineerlng
Remeoial InvestigatIon Inc.
.
-------
Page No.
~':'/12/91
3
FICHE/FRAME PAGES DATE
2
89/10/25
"
89/11/13
3
90/01/15
.:.
;0/03/09
2
;0/05/03
2
90/10/01
90/10/05
5
;0/11/27
. 7
;0/1' /30
B7/00/00
TITLE
Letter re: Certified
Letter of October 20, '
1989 Winnebago
Reclamation (Pagel Pit)
Landfill
Letter re: Response to
letter of October 20,
1989 requesting
Respondents undertake
certain additional work
Letter re: Update of
Table 3 in CAPP,
Winnebago Reclamation
Landfi II
ADMINISTRATIVE RECORD INDEX
PAGEL'S PIT lANDFill SITE
ROCKFORD, ILLINOIS
AUTHOR
Gary l. Marzorati,
Winnebago Reclamation
Service, Inc.
RECIPIENT
B. Schorle, USEPA
James A. Hill and Gary E. B. Schorle, USEPA
Parker, warzyn
Engineering
Inc.
Gary E. Parker, Warzyn
Engineering, Inc.
'.
Letter re: Additional Rid;way M. Hall, Jr.
wells in the area between Crowell & Moring
Winnebago Reclamation
Landfill and the Acme
Solvent sites
Letter re: March 9, 1990 Steven p. Kaiser, USEPA
letter setting fortn
proposal to share costs
and responsibility 'or
the installation 0'
aeditionSI grounowater
sallS)ling wells
Letter re: Update on . Gary L. Marzorati,
status of plan to aeveloc Winnebago Reclamation
additional landfill space Service, Inc.
in area south of existing
Pagel's landfill
Letter re: Request for
ARARs and TaCs
letter re:
Identification
of ARARs
:'etter re:
Pagel's p;~
S:te.-:';::'::~
Acme Solvent ana Pagel'S
Pit Site
B. Schorle, USEPA
S.Kaiser, :.:SEPA
R. Hall, ~rowell &
Horing
B. Schorle, USEPA
Bernard J. Schorle, USEPA P. Takacs, lEPA
Paul E. Takacs, III inois
Environmental Protection
Agency
B. Schorle, USEPA
5ernaro J. Scnorle, WSEPA G. Parker, .arZY~
:ng.
~SEPA
DOCUMENT TYPE
Correspondence
Correspondence
Correspondence
::Jrresponaence
CorrespOndence
Corresconcience
Correspondence
Corresponoence
::rreSC:Jnoence
Fa.ct Sheets
.
DOCHUHBER
21
22
23
;.
..
~-
26
,7
"0
~-
; T
;~
-------
Page No.
u~/12/91
I.
FICHE/FRAME PAGES DATE
87/06/00
10
90/10/00
2
90/10/29
I.
90/11/02
2
90/11/05
2
90/11/09
7
90/1 1 /09
"
00/00/00
51.
81./06/1 1
59
81./07/17
198
81./12111.
TITLE
Superfund Update, Acme
SOlvent/Pagel's Pit
Proposed Plan for the
Acme Solvent Reelaiming,
Inc. Superfund Site
Pagel's Pit Alternatives
Array
ADMINISTRATIVE RECORD INDEX
PAGEL'S PIT LANDFILL SITE
ROCKFORD, ILLINOIS
AUTHOR
USEPA
USEPA
Judy Kleiman, USEPA
Memo re: ~ater Division Dale S. Bryson, USEPA
Review of Draft
Alternative Array Report
Memo re: Alternatives
Array Doeument(AAD)
Memo re: rSCA ARARs
review of Pagel's Pit
NPL Site, ~innebago
Reelamation Landfill,
CERCLA Alternatives
Array Doeument
~illiam Beyer, USEPA
RECIPIENT
B. Sehorle, USEPA
D. Ullrieh, USEPA
B. Sehorle, USEPA
SteChen M. JOhnSOn, USEPA B. Sehorle, USEPA
Memo re: Toxieity Values Pei-Fung HurSt, USEPA
(Pagel'S Pit/Illinois)
Response to' Comments on
Prooosea NP. ~;sting
Revisea Scoring Package
for Pagel's Pit
Letter re: Attachee
booklet including
Ecology & Environment's
HRS Ranking, Roto
Rooter and ~arzyn HRS
Rank i ng
COIII'IIenu Submi tted to
the united States
Environmental Protection
Agency on its Proposed
Listing of Pagel's Pit
~n tne Suoer{4r~
National PrioritIes
List (~roposed
October 15. 198'»
C.J. Howard, ~innebago
Reclamation Service, Ine.
~innebago Reclamation
Service, Inc.
B'. Schorle, USEPA
R. Bartlett, USEPA
DOCUMENT TYPE
Fact Sheets,
Fact Sheets
Memoranciun
Memorandlnl
Memorandlnl
Memo r analnl
Memorandlnl
Other
Other
Other
Other
.
DOCNUMBER
31
32
33
3'
35
3~
37
38
39
':'0
':'1
-------
Page No.
0../12/91
FICHE/FRAME PAGES DATE
5
8J./06/07
81
86/08/27
I.
80/05/27
37
80/08/15
13
81/1Z100
5
83/02121
':)9
B3/03/00
16
83/08122
163
85/03/27
~20
B5/06/00
,.
86/11/00
TITLE
Phone Conversation re:
Winneblgo Co. Forest
Preserve.
Administrative Order by
Consent with attached
Statement of Work
(effective date October
16, 1986)
Potential Hazardous Waste USEPA
Site Identification and
Preliminary Assessment
Methane Study, Winnebago
Reclamation Service, Inc,
Pagel Pit Landf; II
(Cover Letter)
Geology for Planning
in Boone and Winnebago
Counties Illinois
Preliminary Assessment
Extent 0+ Sources of
Grounawater
Contamination,
Acme Solvents Pagel's Pit
Area Near Morristown,
Illinois
Potential Hazardous Waste USEPA
Site Inspection Reoort
Report Entitled:
Supplemental
Investigation Winneoago
Reclamation Landfill
Meview of RI/FS WorK on
:he ~~"~ Solvents S:~e
CA/ec ~ata Rev;ew .
Technical Hemoranaum
ADMINISTRATIVE RECORD INDEX
PAGEL'S PIT LANDFILL SITE
ROCKFORD, ILLINOIS
AUTHOR
Rodney J. Lynn
Warzyn Engineering, Inc.
"
Richard C. Berg, John P.
K~ton and Amy N.
Stecyk Illinois State
Geological Survey
Paul D. Shea, Ecology &
Enviroment
:cology 6 Envi, roment
In~.
Uarzyn Engineering, Inc.
:ugene A. HickoK ana
Associates
Uarzyn Engineering, Inc.
RECIPIENT
Mark Keister
C.Howlrd,Winnebago
Reclam
USEPA
USEPA
USEPA
Acme Tecnnlcal
Cormll nee
DOCUMENT TYPE
Phone Record
Pleadings/Orders
ReportS/Studies
ReportS/Studi es
ReportS/Studi es
ReoortS/Stud; es
ReportS/Stuo; es
ReportS/Studies
Reports/Studies
ortS/S:UCles
Reports/Stuoies
.
DOCNUHBER
1.2
1.3
"
'5
1.6
'7
-8
':'9'
so
- .
<-
-,
-------
Page NO.
01./12/91
~
FICHE/FRAME PAGES DATE
19
86/11/00
18
87/08/00
79
87/08/11.
296
87112/DO
101.
88/01119
2'
88/01/30
1.78
;0/03/00
;6
;0/09/00
TITLE
Technical Memorand~:
Receptor/Pathway Analysis
Plgel's Pit Landfill
Health Ind Safety Plan,
Remedial Investigation
and Felsibility StUdY,
Pagel's Pit Landfill
Remedial Investigation/
Felsibility Study Work
Plan
ADMINISTRATIVE RECORD INDEX
PAGEL'S PIT LANDFILL SITE
ROC~FORD, ILLINOIS
AUTHOR
Warzyn Engineering, Inc.
Warzyn Engineering, Inc.
RECIPIENT
DOCUMENT TYPE
DOCNUMBER
PRP Steering
Conmi ftee
Re.pcrts/Studies
53
Respondent'sSteering Reports/Studies
Conm.
5{,
Warzyn Engineering, Inc.. Respondent'sSteering Reports/Studies
Conm.
Quality Assurance Project Warzyn Engineering, Inc.
Plan, Remedial.
Investigation/FeasIbility
StUdy
Report: Activity 3A.1
Landfill Operation (with
cover letter)
55
Respondent'sSteering Reports/Studies
Conm.
56
Gary Marzorati, Winnebago J. Hill, Warzyn Eng. Reports/Studies
Reclamation Service, Inc.
Quality Assurance Project Warzyn Engineering, Inc.
Plan (QAPP)
57
Reports/Studies
58
Interim Groundwater
Quality Evaluation ana
,:,ppenaices
Alternatives Array
Doc~nt
Warzyn Engineering, Inc.
Warzyn Engineering, Inc.
Resgcndent'sSteering Reports/Studies
C 01IIII.
59
PRP Group
Reports/Stud; es
60
270 91/03/00 Remeaial Investigation Warzyn, Inc. Pagel's Pi t PRPs Regcrts/Studi es 61
Report, Winnebago
Reclamation Landfill
Vol~ 1 of 2
{,66 91/03/00 Remedial Investigation Warzyn, Inc. Pagel's Pit PRPs Reports/Studies !:o2
Report, Winnebago
Reclamation Landfill
VI"!:ume 2 of 2
':':;9 ;>1/03/00 Feasibility Study Warzyn, Inc. Pagel's Pit PRPs Reports/Stud i es ::3
-eocrt. 'Jinnecago
"e~iamation Lanat;l,
e
-------
Page No.
01./12/91
ADMINISTRATIVE RECORD REFERENCE INDEX
PAGEL'S PIT LANDFILL SITE, ROCKFORD, ILLINOIS
DOCUMENTS LISTED MAY BE FOUND IN THE ACME SOLVENT CAR)
AT THE ROCKFORD PUBLIC LIBRARY, 215 N. WYMAN, ROCKFORD, IL.
DATE 11 TLE AUTHOR RECIPIENT DOCUMENT TYPE
85/02/00 Preliminary Feasibility E.C. Jordan Co. IEPA . Reports/Studi es
Study, Technical Report,
Acme Solvents Superfund
Site
87/09/00 Final Community Relations Jacobs Engineering Group, Inc. USEPA Reports/Studies
Plan, Acme Solvent Site and
Pagel's Pit Site
90/02/23 Supplemental Technical Harding Lawson Associates USEPA Reports/Studies
Investigation Final Report,
Acme Solvents Site
90/08/06 Engineering Evaluation/Cost Harding Lawson Associates USEPA Reports/Studies
Analysis Final Report
'.
;0/09/20 Remedi.l Action Alternatives Haroin; "awson Associates USEPA ileportstStudies
Evaluation Final Report,
Acme Solvent Site
.
-------
Page No.
01,112/91
TITLE
Superfund Remedial Design
and Remedial Action
(RD/RA> Guidance
Superfund Federal-Lead
Remedial Project
Management Handbook
Data Quality Objectives
for Remedial Response
Activities: Example
Scenario: RI/FS
Activities at a Site with
Contaminated Soils and
Ground Water (Volume 2>
Data Quality Objectives
for Remedial Response
Activities: Development
Process (Volume 1>
A C~ndi\ll1 of
Superfund Field Operations
Community Relations in
Superfund: A Handbook
(Interim Guiaance)
Standard Operating
Safety Guides
CERCLA Compliance with
Other Laws Manual, Part
I (Interim Final)
Guidance for Conducting
Remedial Investigations
and Feasibility Studies
(RI/FS) Under CERCLA
Guidance on Remedial
Actions for Contaminated
Ground Water at Superfund
Sites
~iSk Assessment Guidance
lor Superfund, Vol\ll1e II:
Environmental Evaluation
GUIDANCE DOCUMENTS INDEX
PAGEL'S PIT LANDFILL SITE
Guidance Documents are available for
USEPA Region V-Chicago IL
review at
AUTHOR
DATE
USEPA
86/06/01
USEPA
86/12/00
USEPA
87/03/00
USEPA
87/03/00
USEPA
87/12/01
USEPA
88/06/00
OSHA
88/07/05
USEPA
88/08/00
USEPA
88/10/00
USEPA
88/12/00
USEPA
89/03/00
.
-------
Page No.
0l,I1V91
2
T1 TLE
Manual
Applicable or Relevant
and Appropriate
Requirements (ARARs)
Qs & As
Control of Air Emissions
from Superfund Air
Strippers at Superfund
Ground Water Sites
Guidance on Prepering
Superfund Decision
Documents: The Proposed
Plan, the Record of
Decision, Explanation
of Significant
Differences; The Record
of Decision Amendment
(Interim Final)
Superfund LDR Guide #5:
Determining When Land
Disposal Restrictions
(LORs) are "Applicable"
to CERCLA Response
Actions
Superfund LOR Guide ~:
Complying with the Hammer
Restrictions Under Land
Disposal Restrictions
(LDRs)
Superfund LDR Guide #3:
Tr~atment' Standards and
Minimum Technology
Requi rements Under Land
Disposal Restrictions
(LDRs)
Superfund LDR Guide #2:
Complying with the
California List
~::~~~::~:~S ~~~ei ~a~
Disposal Restrictions
(LDRs)
GUIDANCE DOCUMENTS INDEX
PAGEL'S PIT LANOFILL SITE
Guidance Documents are available for
USEPA Region V-Chicago IL
review at
AUTHOR
DATE
USEPA
89/05/00
USEPA
89/06/15
USEPA
89/07/00
USEPA
89/07100
USEPA
89/07/00
USEPA
89/07/00
USEPA
89/07/00
.
-------
Page No.
01,/12/91
3
TITLE
Superfund LOR Guide '1:
Overview of RCRA Land
Disposal Restrictions
(LDRs)
CERCLA Compliance with
Other Laws Manuel, Part
II: Clean Air Act and
other Environmental
Statutes and State
Requi rements
Gettin; Ready:
the RIIFS
Scoping
The Feasibility Study:
Develooment and Screening
of Remedial Action
Alternatives
A Guide to Developing
Superfund Records of
Decision
The Remedial Investigation:
Site Characterization and
TreataOility Studies
A Guide to Developing
Superfund Proposed Plans
Notification of
Out-of-State Shioments
of Superfund Site Wastes
Riak Assessment Guidance
for Superfund, Volume I:
Human Health Evaluation
Manual, Part A
CERCLA Compliance with
Other Laws Manual:
CERCLA Compliance with
the Clean Water Act (C~A)
a~= ~~: ~of~ :r~~k~~;
;;atar Act (SDWA)
The Feasibility Study:
GUIDANCE DOCUMENTS INDEX
PAGEL'S PIT LANDFILL SITE
Guidance Documents are available for
USEPA Region V-Chicago IL
review at
AUTHOR
DATE
USEPA
89/07100
USEPA
89/08/00
USEPA
89/11/00
USEPA
89/11 100
USEPA
89/11/00
USEPA
89/11/00.
USEPA
89/11/00
USEPA
89/11/11.
USEPA
89/12/00
USEPA
90/02/00
USEPA
90/03/00
.
-------
Page No.
01,/12/91
I,
TITLE
Detailed Analysis of
Remedial Action
Alter-natives
Guide to Selecting
Super-fund Remedial Actions
R i st Assessment Gui dance
for- Super-fund. Volume I:
Human Health Evaluation
Manual. Par-t A
Str-eamlining the RIIFS for-
CERCLA Municipal Landfill
Sites
CERCLA Site Dischar-ges to
POTWs: Guidance Manual
Basics of Pump and Tr-eat
Cr-ound Water- Remediation
Technology
.'
GUIDANCE DOCUMENTS INDEX
PAGEL'S PIT LANDFILL SITE
Guidance Documents ar-e available for
USEPA Region V-Chicago IL
r-eview at
AUTHOR
DATE
USEPA
90101.100
.USEPA
90/01./00
USEPA
90/09/00
USEPA
'.
90/09/00
USEPA
90/09/00
.
-------
Alternatives Array
Docunent
Applicable or Relevant
and Appropriate
Standards, Limitations,
Criteria and
Requi rements
C~rehensive
Env;rormental
C~nsat;on,
Li abil i ty Act
Hazardous Ranking Score
Illinois Environmental
Protection Agency.
Land Disposal
Restriction
National Priority ~!5:
Publicly Owned
Treatment lIorks
Potentially Responsible
Party
Qua Ii ty Cont ro II
Quality Assurance
Quality Assurance
Project Plan
Remedial Action
Remedial Design
Remedial Investigation/
Feasibility Study
Raltech Scientific
Servi.ces, Inc.
Toxic Substances
Control Act
United States
Envi ronmenu I
Agency
Page No.
04/12/91
..
ACRONYM
DEF I NIT ION
AAD
ARARs
CERCLA
HRS
IEPA
LOR
NPL
POTII
PRP
QA/QC
QAPP
RA
i\D.
RI/FS
RSSI
TSt:A
USEPA.
.
Response,
and
of 1980
Protection
ACRONYM
GUIDE for the Administrative
Pagel's Pit Landfill Site
Rockford, Illinois
Record
.
-------
Administrative Record Update No.1
Pagel's Pit Site
~
Preliminary Health Assessment for Pagel's Pit, Rockford, Illinois, January
13, 1989
Memorandum, April 22, 1991, to David Ullrich, Director, (Hazardous) Waste
Management Division,.Region 5, from Sally Mansbach, Acting Director, CERCLA
Enforcement Division, USEPA, Washington, Containment-Only Consultation,
Pagel's Pit, Winnebago County, IL
Letter, April 2, 1991, from Paul E. Takacs, IEPA, to Bernard J. Schorle,
USEPA, Draft of Proposed Plan
Proposed Plan for the Pagel's Pit Superfund Site, Winnebago County, Illinois,
. April 1991 .
proposed Plan for the Pagel's Pit Superfund Site, Winnebago County, Illinois
(Fact Sheet), April 1991
Declaration for the Record of Decision and Record of Decision Summary, Acme
Solvent Reclaiming, Inc., December 31, 1990
Transcript. of the Public Meeting, Pagel's Pit,
1991), May 1, 1991
(Meeting Date: April 25,
Letter, April 20,
Proposed Plan
1991,
from James Lightcap to USEPA,
Comments on the
"
Letter, May 9, 1991, from Ben Costello, Applied Hydrology Associates, Inc. to
Bernard J. Schorle, USEPA, Acme Solvents Site PRPs Comments on the Proposed
Plan for the Pagel's Pit Superfund Site Winnebago County, Illinois
Letter, May 13, 1991, from Betty Johnson, The League of Women Voters ,of
Rockford, Comments on EPA Proposed Plan for the Pagel's Pit Superfund Site,
April, 1991
Letter, May 15, 1991, from Ridgeway M. Hall, Jr. and Susan R. Koehn, Crowell
& Moring, to Bernard J. Schorle, USEPA, transmitting the report "Comments by
Pagel's Pit Landfill Participating PRPs in Response to EPA's Proposed Plan
for the Winnebago Reclamation Landfill Superfund Site", by The Pagel's Pit
Landfill Participating PRPs, May 15, 1991.
Letter, June 3, 1991, from Ridgeway M. Hall, Jr. and Susan R. Koehn, Crowell
& Moring, to Bernard J. Schorle, USEPA, Winnebago Reclamation Landfill, and
enclosed EPA Guidance, OSWER Directive 9285.6-03 dated March 25, 1991
Memo, June 11, 1991, from Erin Moran, USEPA, to Bernard Schorle, USEPA,
Pagel's Pit, Winnebago County, Illinois, Risk Assessment Review
.
-------
APPE1fDI% B
RESPONSIVENESS SUMMARY
PAGEL'S PIT SITB
WINNEBAGO COUNTY, ILLINOIS
RESPONSIVENESS SUMMARY OVERVIEW
I.
In accordance with CERCLA Section 117, the USEPA and IEPA held
a public comment period from April 16, 1991 through May 16, 1991
to allow interested parties to comment on the reports for the
remedial investigation and the feasibility study and on the
Proposed Plan for remedial action at the Pagel's Pit site. At
a public meeting that was held on April 25, 1991,
representatives of USEPA and IEPA discussed the proposed
alternatives for remediating the site, answered questions about
the site and the problems there, and were prepared to receive
verbal and written comments.
, ,
The, purpose of this responsi ve summary is to document the
comments received during the public comment period and the
response of USEPA ,to these comments. All comments summarized in
this document were consider-ed in USEPA' s final decision for,
remedial action at the Pagel's Pit site.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The residents on Lindenwood Road near the site have been
concerned about this site and the Acme Solvent site since at
least 1981. Groundwater wells of some of the residences are
contaminated, and this is presently being addressed by some of
the PRPs for the Acme Solvent site who have furnished home
carbon treatment units for these residences. Being neighbors of
an operating landfill causes some concern to the people in the
neighborhood, as does the proposal to open another landfill to
the south of the present site.
Generally, the site does not appear to cause much concern to
people who are not immediate neighbors. News about the site is
published, but the attention that is paid to it does not appear
to be any greater than one would expect.
At the April 1991 public meeting, no comments were presented.
The questioning generally dealt with the Acme Solvent site, the
groundwater contamination, the methane gas, the proposed'
landfill to the south of the present landfill, the continued
operation of the Pagel's Pit site as a landfill until it reaches
capacity, the future study in the southeast corner of the site, ,
the sludge going to the landfill, and the land purchases by the
operators of the Pagel's pit site in the area.
--Page B-1--
Pegel's Pit Site, Responsiveneu Summery for the Record of Decision
.
-------
III. SUMKARY OF . SIGNIFICANT COMMENTS RECEIVED DURING THE
COMMENT PERIOD AND THE RESPONSES OF USEPA
The comments have been organized into the following categories:
A. Comments from the general public
1. Comments from the community (including The Leaque
of Woman Voters of Rockford)
2. Comments from the Acme Solvent site PRPs
B. Comments from the Pagel's Pit site PRPs
The comments have been summarized for presentation in this
document. The reader is referred to the public repository for
the full comments. .
A.
Commen~. From ~he General Public
1.
Commen~. From ~he Communi~y
COMMENT: A Rockford resident said that it was foolish to place
a burden on Rockford for a landfill, apparently referring to the
cost of the remedial action.
RESPONSE: When a site may present an imminent and substantial
endangerment to public heal~h, welfare, and the environment,
USEPA must take some action: The Pagel's Pit site is such a.
site. Whether taking action at this site will place a financial
burden on the citizens of Rockford will depend upon the parties
that are named as being potentially responsible and that
participate in the remedial design and remedial action, and
whether they pass their share of the costs on to the citizens of
Rockford.
COMMENT: Alternative Sa is better than 5 because this would
result in the reduction of both toxicity and volume for the
leachate by destroying most of the volatile. organic compounds
(VOCs) and semi-volatile organic compounds (SVOCs). The report
for the feasibility study is quoted, stating that it says that
Alternative Sa is one of the simplest to construct and operate
because it does not involve discharging leachate to the publicly
owned treatment works (POTW) for treatment. It is pointed out
that future regulations might make it difficult or impossible to
send the leachate to the POTW and this should be anticipated.
RESPONSE: The leachate has been going to the POTW for a number
of years, and no adverse effects from this practice have been
demonstrated. The quantity of leachate generated at the site is
expected to decrease significantly as the final cover is placed
on the landfill. This will greatly complicate the design and
operation of a process for the treatment of leachate since most
processes have only a restricted range of capacity over which.
optimum results are obtained. Treatment at the POTW will result
in the destruction of some of the organics through biological
--Page B-2--
P8gel'. Pit Site. Responsiveness Summ8ry for the Record of Decision
.
-------
oxidation, which will be a reduction in toxici ty . It is
debatable that Alternative Sa is simpler to construct and
operate than Alternative 5. It would appear that it would be
easier to send a material, with a small amount of pretreatment,
through a pipe to another facility than it would be to operate
a plant at the site for full treatment, particularly when the
plant would not be very large. And, although it is true that
requlations might change and cause a significant change in the
way the leachate must be handled in the future, this is
something that can be addressed at the time that it happens.
This is not believed to be rea'son enough at this time to
discontinue a system that has been working for a number of
, years.
COMMENT: Alternatives 6 and 6a do not include ,the advantages of
Alternative Sa and should not be used. The concern here is with
the emissions of VOCs to the atmosphere if no activated carbon"
is used for removal of VOCs from the stripping gas. It is
pointed out that there is no reliable data on ambient air
pollution testing at the site.
RESPONSE: It is expected that the air emissions from the air
stripping column. would be low enough that treatment of the
vapors would not be require~. If an air stripper is used, the
air emissions will be examined further during the design of the
system, and if that study determines that controls' are
necessary, the controls will be added. This study will include
modeling to predict air emissions from the site and might
include further air monitoring studies since those done
previously had limited value. The discharges from the air
stripper will be subject to the approval of IEPA, will not be
permitted to exceed health-based levels (an excess cancer risk
of lX10.S at the nearest residence or business), and will have to
meet all federal and state requirements.
COMMENT: A clay-synthetic membrane cap should be used for
closure rather than an Illinois sanitary landfill cap in order
to reduce the infiltration of water into the wastes to very low
levels and therefore reduce the amount of leachate, which could
be increased by long-term subsidence.
RESPONSE: The Pagel's Pit site is a sanitary landfill. There
is no evidence that RCRA hazardous waste has been disposed of at
the site, so a RCRA subtitle C cap would not be required. For
these reasons, a sanitary landfill cap has been chosen for the
closure. This sanitary landfill cap will be maintained until it
can be shown that the maintenance is no longer needed.
COMMENT: The risk analysis does not include other health
effects besides cancer, which include non-fatal tumors, birth
and genetic defects, and diseases, such as those affecting
--Page B-3--
Pege"a Pit Site. Responsivene.. Summery for the Record of Ceciaion
.
-------
kidney and liver functions that may be caused by toxic and
hazardous substances in the landfill. CUmulative and
synergistic effects on human health and in the environment also
need to be considered. Bioaccumu1ation seems to be ignored when
calculating risk of contamination from Ki11buck Creek.
RESPONSE: Health effects other than cancer are considered in
the reference doses (RfDs) and in the calculations of the hazard
quotients (HQs) and hazard indices (HIs). Such effects of
concern as effects on the kidney, liver, nervous system, heart,
brain, body weight, and reproduction are included. See, for
example, Health Effects Assessment Summarv Tables, January 1991
. for other effects of concern that are considered. Also, ~
Assessment Guidance for Superfund (RAGS), Volume I, Part A
(December 1989), on page 8-15 says that the hazard indices
include such major effect categories as "neurotoxicity,
developmental toxicity, reproductive toxicity, immunotoxicity,'
and adverse effects by target organs (Le., hepatic, renal,
respiratory, cardiovascular, gastrointestinal, hematological,
musculoskeletal, and dermal/ocular effects)."
Adding the HQs to get an HI does add together the effects even
though the effects of concer~ from the various substance might
be different. This procedure assumes dose additivity in the
absence of information on specific mixtures, which is rarely
available.
"uncertainties associated with summing risks or hazard indices
for several substances are of particular concern in the risk
characterization step. The assumption of dose additivity
ignores possible synergisms or antagonisms among chemicals, and
assumes similarity in mechanisms of action and metabolism.
Unfortunately, data to assess interactions quantitatively are
generally lacking. In the absence of adequate information, EPA
guidelines indicate that carcinogenic risks should be treated as
addi ti ve and that noncancer hazard indices should also be
treated as additive. These.., assumptions are made to help prevent
an underestimation of cancer risk or potential noncancer health
effects at a site." (RAGS, Vol. I, Part A, p. 8-22)
In the environmental portion of the baseline risk assessment,
maximum surface water concentrations were compared to lowest
reported toxic chemical concentration for freshwater, ambient
water quality criteria. For the VOCs, it appeared that there
was little potential for adverse effects based on this
comparison, and these substance are not expected to biomagnify.
Exposure of fish to inorganic chemicals is not expected to cause
adverse health effects based on acute exposure criteria. The
chronic criteria is marginally exceeded for cyanide, but the
average cyanide concentration was below the criteria.
Therefore, deleterious health effects on fish are not expected.
--Page B-4--
Pegel'l Pit Site, Responsiveness Summery for the Record of Cecilion
.
-------
Since the fish appear to be safe from health effects, other
aquatic ecosystem effects are not anticipated.
COMMENT: Regulations need to
wastes from sanitary landfills
materials so that they do not
water.
be changed to exclude special
and reduce and reuse the toxic
contaminate the land, air, and
RESPONSE: Sending of these special wastes to sanitary landfill
is not the purview of the USEPA.
2.
Comments Prom the Acme Solvent Site PRP8
These comments were submitted by a party who stated that it was
the Technical Manager for the remedial design and remedial
action, employed by the Acme Solvents PRP Steering Committee.
The comments have been presented here as submitted.
COMMENT: "The Proposed Plan contains no indication that the
ground water in the St. Peter Sandstone was sampled and
analyzed. Without sampling and analysis of the St. Peter
Sandstone it may not be possible to accurately characterized the
po~ential for vertical migration of materials from the Pagel's
Pit site. We do not understand how it is possible to adequately
'...characterize the natur~ and estimate the magnitude of
potential risks to public health and the environment.' from the
Pagel's Pit site without information on the potential for
vertical migration of materials from .the Pagel's Pit site."
RESPONSE: Not all of the studies and information that were in
the report for the remedial investigation could be discussed in
the few pages of the Proposed Plan, and there never is an
attempt to do so. The upper aquifer was sampled at various
depths to determine how the concentrations of substances changed.
with depth. Also, water levels in wells at different depths at
essentially the same locations were meas~red to determine the
vertical directions of groundwater flow. During the design of
the groundwater extraction system, additional groundwater
sampling will be done to make sure that the full extent of the
groundwater contamination has been determined so that the needed
extraction system can be designed.
COMMENT: "The alternatives that are presented as having been
evaluated under the 'Summary of Alternatives' do not seem to
a~dress the full range of remedial alternatives that are
required by the National Contingency Plan. Specifically, there
does not appear to have been any evaluation of an alternative
that addresses restoration of any affected ground water
resources not immediately adjacent to the Pagel's Pit site. The
lack of an evaluation of an aquifer restoration alternative
seems unusual in light of the evidence presented that materials
--Page B-S--
Pagel', Pit Site, Responsiveness Summery for the Record of Decision
.
-------
have migrated from the Pagel's Pit site and the potential future
use of ground water as a water supply is presented as a primary
consideration in the baseline risk assessment."
RESPONSE: The groundwater contamination downgradient of the
site that has been found will be addressed by the design and
installation of the groundwater extraction system. Of course,
the groundwater contamination in the southeast corner of the
site will be addressed in the future.
COMKENT: "The elevated levels of conductivity and alkalinity
that were reportedly found in the wells '...nominally upgradient
and sidegradient from the landfill' could be an indication that
the development of the lan~fill may have altered the local
hydrologic regime with the landfill acting as a ground water
recharge mound for the shallow aquifer. This. is not an uncommon
situation around municipal solid waste landfills. Such a
condition might easily lead to the contamination identified in
the southeast corner of the Pagel's Pit site. However, the
statement that '[a] connection has not been established between
th~ contamination on and near the Acme Solvents site and the
contamination in the southeast corner of the Pagel's Pit site'
could cause a reviewer to, believe that there is reason to
suspect a more significant connection between the Acme Solvents
site and the southeast corner of the Pagel's Pit site than any
data seems to support. The Acme Solvents PRPs do not believe
such a connection exists and should not be implied."
RESPONSE: The groundwater contamination in the southeast corner
is to undergo additional studies in order to further define it.
In these studies, an attempt will be made to determine the
source(s) of the contamination there. The ROD issued for the
Acme Solvent site (signed on 12/31/90) also mentions these
further studies. .
The level of VOCs in the groundwater in the southeast corner of
the site is higher than at any other place near the Pagel's Pit
site. However, upgradient of the southeast corner is the highly
contaminated well B4, located at the Acme Solvent site. There
are elevated levels of VOCs in well Glll which is some distance
away from the landfill in a sidegradient direction and which
does not have elevated levels of specific conductance. These
.are some of the reasons that additional studies must be carried
out to attempt to determine the source(s) of the contamination
in the southeast corner. Since there is the possibility that
the extent of the movement.through the fractured bedrock of the
contamination in well B4 has not been adequately characterized,
this is one item that has to be looked at for the additional
studies of the southeast corner of the Pagel's pit site. There
is no data that has been generated that shows that there could
not be a connection between the contamination in the southeast
--Page B-6--
Pegel's Pit Site. Responsiveness Summery for the Record of Decision
.
-------
corner and the Acme Solvent site.
COMMENT: "The ground water control system described in the
Proposed Plan seems to only address affected ground water in the
unconsolidated deposits near the western boundary of the site.
We are interested in how EPA plans to control any other affected
ground water from the Pagel's Pit site, specifically the ground
water that may be in the unconsolidated deposits beneath the
site but not along the western boundary of the site and the
fractured bedrock below the eastern quarter of the site."
RESPONSE: The groundwater at the site is moving generally
toward the west and the contaminated groundwater moving in that
direction will be intercepted at the western boundary of the.
site. Reduction in the amount of. infiltration into the landfill
and time should result in a decreased rate of contamination of.
the groundwater under the site. The extraction system will be
operated until contamination in the groundwater leaving the site
does not exceed the criteria specified.
COMMENT: "It may be incorrect to assume that the only source of
leachate from the landfill is infiltration of precipitation
through the landfill contents. Decomposition of the landfilled
materials, in situ moisture ~ontent of the landfilled materials
and precipitation that falls on the landfill contents during
placement will all contribute to leachate formation. As a
result it will be necessary to maintain and operate the leachate
extraction system until leachate is no longer generated rather
than until infiltration is controlled as stated in the Proposed
Plan."
RESPONSE: It is recognized that infiltration is not the only
source of leachate. The Proposed Plan does not say that the
leachate extraction system will be maintained and operated
"until infiltration is controlled". In the Proposed Plan in the
"Time Required for Implementation" section, it says, "The
leachate extraction system would be operated until rainwater no .
longer leached contaminants out of the wastes." In the "Summary
of the Preferred Alternative" section, it says, "ongoing
extraction of gas and leachate until these substances no longer
pose a problem should significantly reduce the levels of
groundwater contamination."
B.
Comments From the Pagel's Pit sit. PRPs
These comments were submitted by a law firm that stated that it
was representing. the Pagel's Pit Landfill Participating PRPs.
The comments were submi~ted in the form of a report that
contained a considerable amount of background and claimed
supporting material. In much of this, the work done ~or the
remedial investigation and feasibility study was attacked. This
--Page B-7--
Pegel', Pit Site, Re,ponsiveness Summery for the Record of Decision
.
-------
background and supporting material is generally not presented
here; their original report is to be consulted for that. What
follows are the comments made along with some of the supporting
material.
In much of the background and claimed supporting material there
are some misstatements of the facts as presented in the reports
for the remedial investigation and feasibility study. There are
some incorrect references and unsupported claims and
conclusions. Generally, no attempt has been made here to
comment on these.
COKHEN'1': "In addition, while the source of vinyl chloride
contamination may not be particularly relevant.to the effects of
the contamination itself, the Pagel's Pit Landfill PRPs do point
out that vinyl chloride is a biodegradation product of precisely
those solvents, ~, tetrachloroethene (PCE),trichloroethene
(TCE), and 1,1- and 1,2-dichlorethenes (DCE), that were disposed
of at the Acme Solvents site and detected in wells between the
WRL and Acme Solvents sites. (RI, pp. 4-40 to 4-45).
Therefore, any discussion of the hydrogeology in the WRL area
that EPA decides to include in the Record of Decis.ion must
recognize this fact. (~Section 4 of the Remedial
Investiaation ReDort for a detailed discussion of groundwater
releases from the Acme Sol vents site and their degradation
products)."
RESPONSE: There are chlorinated ethenes in many of the wells
throughout the area. The remedial investigation did show that
leachate from the landfill was affecting the groundwater. There
are chlorinated ethenes in the leachate. The report for the
remedial investigation did not consider all of the possible
mechanisms that could have caused chlorinated ethene
contamination in the groundwater. The report for the remedial
investigation did not establish that none of the chlorinated
.ethene contamination in the groundwater in the neighborhood of
the landfill could have come from the landfill. The remedial
investigation and the feasibility study for the site must
address the contamination that exists at the site. This is
being done, except for the contamination in the southea~t corner
of the site.
What is requested to be included in the Record of Decision is
not clear. Certainly not all of the results of the remedial
investigation and the feasibility study can be put in the Record
of Decision.. It is generally more appropriate to use the
limited room available for reporting the facts that have been
determined rather than the speculation that has been put forth.
COMMENT: The baseline risk assessment was not properly done,
and the risks for the future use of groundwater are not as great
--Page B-a--
Pegel's Pit Site, Responsiveness Summery for the Record of Decilion
.
-------
as what has been determined. A very lengthy discussion is
presented to back up this claim. One of the main arguments is
that the toxicity values used should not have been used.
RESPONSE: The baseline risk assessment was generally done in
accordance with the requirements of the Risk Assessment Guidance
for SUDerfund (RAGS) (USEPA, March 1989 and December 1989).
While someone may not agree with this guidance, this is what is
to be used in the Superfund program. The critical toxicity
values were taken mostly from the Integrated Risk Information
System or the fourth quarter Health Effects Assessment Summary
Tables, September 1990. These are the correct sources (see
RAGS, Volume I, Part A, pp. 7-13ff).
COMMENT: Alternative 2 should be chosen. . To say that this
al ternati ve would not provide adequate protection of human.
health and the environment has no merit.
RESPONSE: The. baseline risk assessment showed that future
possible use of the groundwater at the site as a water source
will result in unacceptable risks to the users. Therefore, the
groundwater must .be addressed in any acceptable alternative.
Alternative 2 does not address this groundwater.
Also, section 300.430 (a) (1) (iii) (F) of the NCP states, "EPA
expects to return usable ground waters to their beneficial uses
whenever practicable, within a timeframe that is reasonable
given the particular circumstances of the site. When
restoration of ground water to beneficial uses is not
practicable, EPA expects to prevent further migration of the
plume, prevent exposure to the contaminated ground water, and
evaluate further risk reduction. n Alternative 2 would not
prevent further migration of the plume.
COMMENT: Alternative 2 does not meet the ARARs because it
leaves contaminated groundwater in place. There has been debate
over the effectiveness of groundwater extraction and treatment.
Support exists for an ARAR waiver because "compliance with such
requirements is technically impracticable from an engineering
perspective" and because "the remedial action selected [in this
case planned closure] will attain a standard of performance that
is equivalent to that required under the otherwise applicable
standard, requirement, criteria, or limitation, through use of
another method or approach". Thus Alternative 2 is consistent
with the remedial requirements of Superfund.
.
RESPONSE: An ARAR waiver because compliance is technically
impracticable is not supported. It is technically practicable
to block the further migration of contaminated groundwater. An
ARAR waiver because planned closure alone will result in the
same performance as planned closure plus groundwater extraction
--Page B-9--
Pegel', Pit Site, Responsiveness Summary for the Record of Decision
.
-------
is not supported. Planned closure, which will not occur for a
number of years, will not result in the relatively quick
checking of the movement off the site of the contaminated
groundwater that gro~ndwater extraction will. Planned closure
will probably not prevent the further transfer of leachate to
the groundwater, only reduce the amount. Alternative 2 does not
meet the remedial requirements of Superfund because it does not
prevent migration of contaminated groundwater.
COMMENT: Alternative 2 plus institutional controls on new well
development in contaminated zones and deed restrictions for
property development provide reasonable measures to eliminate
. future risks.
aESPONSE: These institutional controls will not prevent the
migration of the contaminated groundwater. .There is a
reasonable, cost-effective method for doing that, groundwater
extraction, and no convincing reason for not using this method
has been presented.
COMMENT: If USEPA does not adopt Alternative 2, then it should
select Alternative 6 rather than Alternative 5. Alternative 6
would achieve each of USEPA'~ nine criteria. Alternative 6 is
not as costly as Alternative"S.
RESPONSE: In the Record of Decision, USEPA and IEPA are
choosing both Alternatives 5 and 6. The decision as to which
should be used will be made during the design when more
information is available for the decision. Each has some
advantages and disadvantages, and these can better be weighed
later.
COMMENT: USEPA is wrong in claiming that a connection between
the contamination at the Acme Solvent site and the contamination
in the southeast corner of the Pagel' s Pit site has not been'
established. Measurable levels of VOCs have been found in the
groundwater between the sites. The presence of significant
levels of VOCs "upgradient of the WRL between the area south of
the WRL site and west of Lindenwood Road and at well B4 at the
Acme Solvents site" are indicated. The majority of the VOCs
present in the area of the WRL are the same types of VOCs that
were disposed of in the 1960' s and early 1970' s at the Acme
Solvent site, and their degradation products.
RESPONSE: It is recognized that measurable concentrations of
VOCs have been found between the Acme Solvent site and the
southeast corner of the Pagel's Pit si te. However,
concentrations found between these areas are much lower than
concentrations at the two areas. Thus, it is difficult to make
a convincing case that the two areas are connected.
--Page B-10--
Pegel', Pit Site, Responsiveness Summery for the Record of Decision
.,
-------
"
COMMENT: It is claimed that it is unfounded to say, as the
Proposed Plan states, that the "chloride leachate plume"
probably extends back to some of the southeast corner.
RESPONSE: Wells G109A, GllO, and Gl14 in the southeast corner
definitely have elevated levels of chloride. Wells B13, Gl13,
and Gl13A probably have elevated levels of chloride. Thus, the
statement in the Proposed Plan is supported.
COMMENT: The Proposed Plan is quoted with regard to the
statement that if RCRA wastes have contaminated groundwater at
the Pagel's .Pit site, then RCRA ARARs would apply to the
remediation of the groundwater. The commenter says that there
is no evidence of RCRA wastes going to Pagel's Pit.
RESPONSE: The statement in the Proposed Plan about RCRA wastes
did not state that RCRA wastes have gone to Pagel's Pit. What
is being referred to here is the fact that listed wastes did go
to the Acme Solvent site, and if some of the VOCs in the
groundwater at the Pagel's Pit site are due to the contamination
at the Acme Solvent site, then remedial action on the
groundwater may be subject to RCRA ARARs.
--Page B-ll--
Pegel's Pit Site, Responsiveness Summery for the Record of Decision
.
-------
')
.:;
~
il!;uOIS EnYlrc,nn:ent.:i: ~':-0lt-\::..)n .~g~:1~'::
:>.0. Box 192-ib. Sp:inglif"Jd. IL o:i2ifl.I.~Z;6
217/"'82-6760
R.fe'~ to:
.
L20180S0001 -- W~nnaba9g County
Pagel'8 Pit -- New Milford
Superfund/Complian~e
June 26, 1991
Hr. Ilavid A. Ullri~h, Director
Wa.tf! Manaoement Diviaion
Unit..d Stat.. Environmental Protection Agency, Revion V
230 !:ou~h Dearborn Street
Chic..go, IllUtoi8 60602
Pear Mr. Ullrich:
The Illinois Environmental 'Pro~ection Aq8ncy (IEPA) is in receipt of the prop08ed
Record of pecision (ROD) for the Pagel's Pit Superfund Site. IEPA haa found that
the select~d remedy proposed. 01. the U~it.d St~te8 Environmental Protection Agency
(USE~A) i. protective of human health and the environment, attains Federal and
State reqyirements that are applicable or relevant and appropriate for thh
ramecial action and is cost-effective.
Alth~ugh IEPA has agreed in principle that the propo.ed ramedy would effectiyely
addre.a Contamination at this site, we are unable to concur on thie ROD becau.e
of ..riou. concerne over the manner in wh~ch a portion of the remedy would be
adminiatered. The aec~ion of the ROD concerning landfill Cl08ure and poet-
cl08ure activities .hould b8 administered by IEPA .ince Illinoi. re~lation8
qovern. Secause the S~ate will not be participatlnq in settlement negotiation.
addre.8inq remediation due to the unacceptable role in which the. State would be
placed under the current Model CERCLA RD/RA Con.ent Decree, IEPA will not have
the I,ece.eary approval right. over the landfill closure and poet-clo.ur~.
activities when impl.mentation 1e proposed. In eff.ct, IEPA's ability to enforce.
IlU,noi. rec;ulation8 would be eliminated. .
In th. apirit,of cooperation, IEPA will a881st USEPA to the beat e~tent po.sible
in th.! i.mplementa~ion of the remedy. Please do not hesitate to contact ua should
the nlled ar1.e.
Respectfully,
,-'~ L)&:
~r~f
Willi~ C. Child, Manager
Division of Land Pollution Control
Illin~i. Environmental Protection Agency
CCI
Mary Gade
Bernie Jl:illian
R0ger Xanerv.
'William Child
Gary Kin;
Administrative
Record
Appendix C
.
------- |