United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R04-91/090
September 1991
&EPA Superfund
Record of Decision:
Interstate Lead (IICO), AL
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REPORT DOCUMENTATION 11. REPORT NO. I~ 3. ReclpIent'a Accealon No.
PAGE EPA/ROD/R04-91/090
4. TIlle and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 09/30/91
Interstate Lead (ILCO), AL
6.
First Remedial Action
7. Author(a) 8. Performing OrglUllz81lon ~ No.
8. P8t1ormlng Orgalnlza1lon Name and Add.... 10. ProjedlTa*JWork UnIt No.
11. Contract(C) or Gr8nt(G) No.
(C)
(G)
1~ SpDl18Dring Organization Name and Addre.. 13. Type of RIIpOf1 & P8t1od Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Notea
16. Abetract (Unit: 200 worda)
The Interstate Lead (ILCO) site consists of seven subsites located in and around the
City of Leeds, Jefferson County, Alabama. The site includes an 8.S-acre active lead
smelting facility and its parking lot, a service station; a manufacturing company; a
church parking lot; a l.4-acre residential property; a municipal landfill; and a
restaurant. Land use in the area is mixed industrial and residential. Parts of the
ILCO site overlie the Fort Payne Chert and Ordovician Undifferentiated aquifers, both
of which are sources of drinking water for the City of Leeds. Since 1970, ILCO has
manufactured refined lead alloys through the smelting and refining of lead-bearing
scrap metals including lead-acid automobile batteries. The resultant furnace slag has
been disposed of at the seven subsites along with battery casings and wastewater
treatment sludge. From 1973 to 1984, ILCO stored furnace slag, battery chips, and
wastewater treatment sludge in piles at the main facility and also used these wastes
as fill material at the other site areas. Additionally, some waste was disposed of at
the municipal landfill. State investigations in 1983 and 1984, and a number of
subsequent EPA investigations, identified metal contamination in onsite soil,
sediment, ground water, surface water, and air. In 1984, EPA conducted an emergency
(See Attached Page)
17. Document Analyaia L DeecripIDre
Record of Decision - Interstate Lead (ILCO), AL
First Remedial Action
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: metals (arsenic, chromium, lead)
b. ldentlflera/Open-Ended Terme
c. COSA 11 FlekllGroup
18. AvlilabiYty Statement 19. Security CI... (Thia Report) 21. No. of Pagea
None 108
20. Security Cia.. (Thla Page) 22. Price
None
)
50272-101
(See ANSl-Z38.18)
See /n.weeon. on Reverse
(FDmIeI1y N11~)
Departrnentof Comn.wce
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EPA/ROD/R04-91/090
Interstate Lead (ILCO), AL
First Remedial Action
Abstract (Continued)
removal action at the church subsite, and removed and disposed of approximately 5,000
cubic yards of waste material and soil offsite. This Record of Decision (ROD) provides
a final remedy for soil contamination at all of the subsites except the main facility
portion of subsite #1, and ground water contamination at four of the subsites as
Operable Unit 1. Future RODs will address sediment, ground water, and surface water
contamination at the main facility. The primary contaminants of concern affecting the
soil, sediment, debris, and ground water are metals including arsenic, chromium, and
lead.
The selected source control remedial action for the ILCO parking lot and the restaurant
subsites includes excavating soil and sediment with lead concentrations exceeding
300 mg/kg and 50 mg/kg, respectively; controlling dust with water spray during
excavation and removal; dewatering the sediment; treating the contaminated material
onsite using solidification and stabilization; replacing the treated soil into the
excavated areas in compliance with RCRA requirements, and capping the areas; removing
battery casings and other debris with solidification of battery casing material, and
onsite disposal of solidified material and offsite disposal of other debris; and
conducting air monitoring. The selected source control remedial action for the service
station, the manufacturing company, the residential property, and church subsites
includes excavating and treating soil using solidification and stabilization at a
centrally located treatment area in the parking lot subsite; disposing of treated
material at the ILCO parking lot with filling and revegetation of excavated areas with
clean soil, or disposing of treated materials in the original excavated areas with
implementation of institutional controls including deed restrictions; removal of
sediments exceeding 50 mg/kg lead, dewatering, and treating the sediment along with the
soil; and air monitoring. The selected source control remedial action for the
municipal landfill includes constructing a multi-layer cap over soil contaminated with
lead concentrations exceeding 300 mg/kg; implementing institutional controls including
land use restrictions, and access restrictions; and ground water monitoring. The
selected ground water remedial action for the restaurant, manufacturing facility, and
residential property subsites includes natural attenuation and implementing
institutional controls. The selected ground water remedial action for the municipal
landfill includes pumping and onsite treatment of contaminated ground water using
chemical/physical methods, followed by onsite discharge; solidifying generated sludge
if necessary to meet LDRs before disposal; and ground water monitoring. The estimated
present worth cost for this remedial action is $29,009,000, which includes a present
worth O&M cost of $689,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Clean-up goals for soil are based on leachability
modeling and health-based levels, and include lead 300 mg/kg (leachability), arsenic
10 mg/kg (health-based), and chromium 1,750 mg/kg (health-based). The clean-up goal
for sediment is a Regional Aquatic Species Protection Level and is set at lead
50 mg/kg. Ground water clean-up goals are based on Federal MCLs or proposed MCLs, and
EPA Guidance Criteria. Chemical-specific goals include arsenic 50 ug/l (MCL), chromium
50 ug/l (MCL), and lead 15 ug/l (EPA).
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Rec~d of Decision
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Interstate Lead .Company (ILCO)
1247 Borden Ave.
Leeds, Jefferson County, Alabama
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
Operable Unit One for the Interstate Lead Company (ILCO) Site, in
Leeds, Alabama, which was chosen in accordance with The Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by The Superfund Amendments and Reauthorization
Act of 1986 (SARA), and, to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). This
decision is based on the administrative record for this site.
The State of Alabama concurs with the selected remedy (Appendix D).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site,
if not addressed by implementing the response action selected in th~
Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The ILCO site has seven areas of concern or subsites. This operable
unit is fthe first of two operable units. Operable unit one includes
the ILCO Parking Lot, the Gulf Service Station (currently operating
as British petroleum), J & L Fabricators, Fleming's Patio, the
Connell Property, Acmar Church of God and the City of Leeds
Landfill. The subsites are located in and around the city of Leeds.
All seven of the subsites have soil and/or sediment contamination.
Groundwater contamination will be addressed at four of the subsites.
Two of the subsites, the Gulf Station and the Acmar Church of God,
did not have any groundwater contamination. Groundwater
contamination from the Parking Lot is being addressed under RCRA in a
future operable unit two. Operable unit two also includes
remediation at the ILCO Main Facility and remediation of the
tributary adjacen~to the main facility.
The major components of the selected source remedy at each subsite
in operable unit one includel
A.
The ILCO parkina Lot. and Flemina's Patio
-Excavation and solidification/stabilization of soil with
lead concentrations exceeding 300 mg/kg~
-Replacing the treated soil back into the excavated areas;
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-2-
-Removal of batterI casings and other debris;
-Solidification of battery casing material that can be
sufficiently crushed and replacing the solidified material
onsite. Offsite disposal of other debris;
-Revegetation of excavated areas;
-Institutional controls, consisting of access and deed
restrictions, and long-term groundwater monitoring; and
-Semi~annual samplinq and analysis of existing monito~ wells
for the primary metals associated with automotive batteries.
B. The Gulf Service Station. J , L Fabricators. The Connell
PrODertv and The Acmar Church of God
-Excavation of soil with lead concentrations exceeding 300
mg/kg;
-Transportation of the excavated soil to the Parking Lot
where a centrally located treatment unit will be located;
-Treatment of contaminated soil with a successfully
demonstrated solidification and stabilization process;.
-Placement of the solidified material into the ILCO Parking
Lot subsite (if treated wastes are placed at the Parking
Lot, then the subsites from which the material originate
would not need 5 year reviews, Subtitle D closure, or deed
restrictions. Instead, these subsites can be backfilled
with clean fill and revegetated.) or replacement of the
solidified material into its original excavation if there
are space limitations in the Parking Lot;
-Removal of sediments exceeding 50 mg/kg lead, dewatering,
and transport and treatment along with the soil for sediment
at the Gulf Station; and
-Temporary relocation at the Connell Property and the Acmar
Church of God if necessary.
The Leeds MuniciDal Landfill
C.
-Conatruction of a multilayer compacted clay and geomembrane
cap that_would cover areas with soil exceeding 300 mg/kg of
lead; and
-Institutional controls consisting of access and deed
restrictions to protect the integrity of the cap system, and
long-term groundwater monitoring.
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-3-
The selected alternatives for groundwater contamination are as
follows:
Gulf Service Station and Acmar Church of God
-No groundwater remediation activities will be conducted at
these subsites since no contamination was detected; and
-Longterm groundwater monitoring will be conducted.
J & L Fabricators. Flemina's Patio. and the Connell Property
-No groundwater remediation activities will be conducted at
these subsites. Contaminants would naturally attenuate or
lessen with time; and
-Lonqterm groundwater monitoring will. be conducted.
City of Leeds Landfill
-Extraction of contaminated groundwater;
-Treatment onsite with a mobile chemical/physical treatment
unit;
-Discharge of the groundwater onsite into the adjacent
drainageway (surface outfall); and
-Groundwater monitoring during and after extraction is
finished.
STATUTORY DETERMINATION
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable, and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element.
Because this remedy will result in hazardous substances remaining
onsite, the Environmental Protection Agency (EPA) will conduct a
review within five years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection of
human health and the environment.
m ~O 1991
Date
Gau:~M;:~ /~
~ Greer C. Tidwell '
Regional Administrator
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Record of Decision
The Decision Summary
Interstate Lead Company (ILCO)
Leeds, Jefferson County, Alabama
Prepared bya
u.s. Environmental Protection Agency
Region IV
Atlanta, Georgia
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1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
TABLE OF CONTENTS
Site Name, Location and
Description...................!
Site History and Enforcement Activities...............3
Highlights of Community Participation.................5
Scope and Role of Operable Unit Within Site Strategy..6
Summary of Site Characteristics.......................7
5.1 Regional Geology................................. 7
5.2 Subsite Specific Geology.........................7
5. 3 Regional Hydrogeology............................ 9
5.4 Subsite Specific Hydrogeology....................9
5.5 Surface Water................................... 12
5 . 6 Ecology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
5.7 Sampling Results............................... .12
Summary of Site Risks................ ~ . . . . . . . . . . .-. . . .28
6.1 Contaminants of Concern.........................30
6.2 Exposure Assessment . . . . . . . . . . . . . . ! . . . . . . . . . . . . . .30
6. 3 Toxicity Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . .34
6.4 Risk Characterization Summary...................36
6.5 Environmental Risks............................. 37
6.6 MINTEQA2 Modeling Results.......................45
6.7 Remediation Goals............ . . . . . . . . . . . . . . . . . . .45
Descriptions of Alternatives.........................48
Summary of the Comparative Analysis of Alternatives..56
8.1 Overall Protection of Human Health and the
Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .58
8.2 Compliance with ARARB...........................59
8.3 Reduction of Toxicity, Mobility or Volume through
Trea'tment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .59
8.4
8.5
8.6
8.7
8.8
8.9
Short Term Effectiveness........................60
Long Term Effectiveness.........................60
Implementabili ty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .61
Co 8 t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2
State Acceptance................................ 62
CODDlluni ty Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
EPA's Selected
Al terna t i ve. . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2
Statutory Determinations.............................66
10.1 Protection of Human Health and the
Env~onment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
10.2 Attainment of the Applicable or Relevant and
Appropriate Requirements (ARARs)................66
10.3 Cost Effectiveness.............................. 68
10.4 Utililization of Permanent Solutions and
Alternative Treatment Technologies to the Maximum
Extent Practicable.............................. 68
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11.0
10.5 Preference for Treatment as a Principle
E 1 emen t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 8
Documentation of Significant
Changes. . . . . . . . . . . . . . . . . 68
FIGURES
Figure 1 - Site Location
Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Figure 2 - ILCa Parking Lot-Extent of Lead Contamination......16
Figure 3 - Gulf Service Station-Extent of Lead Contamination..17
Figure 4 - Gulf Service Station-Metal Concentrations in
Sedim.ent. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Figure 5 - J , L Fabricators-Extent of Lead Contamination.....20
Figure 6 - J , L Fabricators-Metal Concentrations in Surface
Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21
Figure 7 - Fleming's Patio-Extent of Lead Contamination.......23
Figure 8 - Connell Property-Extent of Lead Contamination......25
Figure 9 - Leeds Landfill-Extent of Lead Contamination........27
Figure 10- Acmar Church of God-Extent of Lead Contamination...28
Table
Table
Table
Table
Table
Table
Table
TABLES
1 - Rock Types Encountered at ILCa Subsites~............8
2 - Summary of Contamination of Potential Concern...13-14
3 - Toxicity Values I Potential Carcinogenic
and Noncarcinogenic Effects.....................35
4 ~ SUDIDlary of Risk................................. 38-41
5 - Remediation Goals........ . . . . . . . . . . . . . . . . . . . . . . . . . . 47
6 - Criteria for Evaluation Cleanup Alternative........57
7 - Coat............................................... 63
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,
APPENDICES
Appendix A - Responsiveness Summary
Appendix B - Lead Groundwater Clean-up Level Memorandum
Appendix C - Lead Sediment Clean-up Level Memorandums
Appendix D - State Concurrence Memorandum
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RECORD OF DE~ISION
The Decision Summary
Interstate Lead Company (ILCO)
Leeds, Jefferson County, Alabama
1.0
SITE HAMB, LOCATION, AND DBSCRIPTION
Interstate Lead Company (ILCO) was formed in the 1960's in
response to growth in the field of lead recycling. The facility
has been operating as a lead smelter since 1970. From 1973 to
1983, ILCO disposed of furnace slag in and around Leeds,
Alabama.
The ILeO site is located approximately fifteen miles east of
Birmingham, Alabama in the city of Leeds. The site consists of
seven "subsites" distributed throughout the city (see Figure 1,
Site Location Map) and includes the ILeO Main Facility and
parking Lot, (the Parking Lot is across the street from the Main
Facility), the Gulf- Service Station (currently operating as
British Petroleum), J&L Fabricators, Inc., the Acmar Church of
God, the Connell residential property, the City of Leeds
municipal landfill and Fleming's Patio. All but two of the
subsites, the Connell Property and Acmar Church of God, are
within a 3-mile radius of wells that serve as water supply wells
for the Leeds area. The ILeO Main Facility and Parking Lot are
located on approximately 8.5 acres on the south side of Borden
Avenue nearly one mile southeast of the center of Leeds.
The subsites are located in a mixed industrial and residential
area in and near the City of Leeds in Jefferson and St. Clair
Counties, Alabama. According to the 1980 census, the population
of Jefferson County is 671,197 and the population of St. Clair
County is 41,115. The Leeds Chamber of Commerce lists the
population of Leeds at 8,638, and the 1980 census reports a
population of 9,264.
The ILCO Parking Lot site is in a section zoned as heavy
industrial. Within three miles of the property, land is zoned
as residential, agricultural, light industrial, and business.
The Gulf Service Station, now operating as British Petroleum, is
in the center of Leeds. and is surrounded by other businesses.
The Little Cahaba -River borders the northwestern property
boundary. A residential trailer park borders the Little Cahaba
River to the northwest. The Leeds Blementary School is located
southwest of the Gulf Service Station across U.S. Highway 78.
J&L Fabricators is on U.S. Highway 78, east of the City of
Leeds. The company is in a small industrial and business
complex bordered by low-density residential housing to the east
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and southeast, an abandoned shale pIt to the south, a heavy
industrial complex to the southwest, and light industry and
businesses to the north. Immediately to the west of the J & L
Fabricators site are two homes, a building, and a trailer. The
homes and trailer are occupied.
Fleming's Patio is a restaurant and bar west of the City of
Leeds, on Alaska Avenue off Erie Street. On the south side of
the restaurant and bar is a house trailer occupied by the
proprietor and his family. The area is a transition area from
rural to residential properties on the western periphery of the
City of Leeds.
The Connell Property is approximately 1.4 acres in size and
contains two houses and one trailer home served by the county's
water system. The house and trailers are occupied. Low-density
residential properties lie to the north and east, with mixed
hardwood-conifer forests to the south and west.
The City of Leeds Landfill is southwest of the city, off
Dunavant Road at the end of Peach Street. A limited number of
residential properties and dwellings lie directly north of the
landfill property. The landfill is surrounded on the east,
south, and west sides by hardwood-conifer forests.
The Acmar Church of God is approximately 5.5 miles northeast of
the City of Leeds, off Acmar Road, near Acmar, Alabama, in a
predominantly rural area. The church property is bordered by
natural vegetation and trees.
2.0
SITE HISTORY AND BBPORCBJIBRT ACTIVITIBS
ILeO manufactures refined lead alloys through the smelting and
refining of lead-bearing scrap materials. The primary materials
reclaimed by ILCO are discarded ~ead-acid automobile batteries.
After batteries are processed and separated, lead plates and
lead oxide are smelted in a blast furnace for separation, and a
slag is produced which is classified under the Resource
Conservation and Recovery Act (RCRA) as a characteristic
hazardous waste due to its lead content. Battery casings were
disposed at the ILeO facility and other subsites and are also
characteristic hazardous waste due to their lead content.
Wastewater treatment sludge was disposed of at some of the
subsites. However, the furnace slag comprises most of the waste
that has been disposed of at the Main Facility and Parking Lot
and at the siz other subsites.
From approximately 1973 to 1984, ILca stored furnace slag,
battery chips, and wastewater treatment sludge in piles on the
Main Facility property. ILCa used the material as fill on its
own property and some of the material was hauled off of the ILca
property to be used as fill at other locations. Lead waste was
used as fill material at the ILCa Parking Lot, the Gulf Station,
J & L Fabricators, the Connell Property, Fleming's Patio and
Ac~:_ar Church of God. Some waste was disposed in the Leeds
L,-I\dfill.
Page 3
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ILCO filed a chapter 11 bankru~cy petition on August 20, 1982.
A plan of reorganization was accepted by the court and ILCa
implemented the reorganization and on June 11, 1987 a final
decree was entered. ILCO filed a second chapter 11 bankruptcy
petition on July 22, 1991 with the United States Bankruptcy
Court for the Northern District of Alabama under Case no.
91-05465. ILCO continues to operate its business as a debtor in
possession under the jurisdiction of the bankruptcy court.
Past state and federal investigations at the ILCO Site include
stream/sediment sampling conducted by the Alabama Department of
. Environmental Management (ADEM) in July/August 1983 and an
ecological/biological assessment conducted by ADEM in
February/March 1984. In April 1984, EPA conducted an emergency
removal action at the Acmar Church of God Site, and
approximately 5,000 cubic yards of waste material and soil was
removed from the site during the immediate removal action. The
waste material and soil was transported to the Chemical Waste
Management Disposal Facility in Emelle, Alabama. Subsequent
investigations include a site screening study conducted by EPA
in July 1984; a sampling investigation conducted by EPA in
February 1985; and a sampling investigation conducted by EPA in
May 1985. Because the disposed wastes pose a potential threat
to human health and the environment, the ILca Site was placed on
the National Priorities List (NPL) of uncontrolled hazardous
waste sites in June 1986.
A treatability study was conducted in 1988 by EPA on
lead-contaminated soil from the site and another treatability
study was conducted in 1990 on the waste and contaminated soils
in the ILCO Parking Lot Site.
Initial remedial investigation studies were conducted during
1989. Additional RI studies were conducted in 1990 in order to
further characterize the site and the RI/FS report~.for this
investigation were complete July 1991. Information from both
1989 and 1990 studies have been used.
In March 1985 the EPA Region IV office filed a .complaint against
ILCO, Inc. and its principal owner, Diego Maffei, seeking
injunctive relief, penalties and damages for violations of the
Clean Water Act, RCRA, and CERCLA. The State of Alabama .
intervened in the litigation asserting violations of Alabama's
Water Pollution Control Act and Hazardous Waste Management and
Minimization Act. As a partial settlement, a partial consent
decree was entered requiring ILeO to conduct "necessary
remediation of the contamination of sediment" in surrounding
waterways. The outstanding issues (Northern District of
Alabama, Southern Division Case No. CV85-H-823-S) were tried
before the court in 1988. On December 10, 1990, the Court
issued an Order and Findings of Fact and Conclusions of Law.
The court found with respect to the government's claims under
the Clean Water Act that the defendants violated their NPDES
permit. With respect to the government's claims under RCRA, the
Page 4
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-;
court found that the defendants con~inuously stored, treated and
disposed of hazardous waste at the plant site without a RCRA
permit and in violation of RCRA federal and state regulations.
The court found that injunctive relief was appropriate and that
ILCO has subjected itself to civil penalties under NPDES and
RCRA. With respect to the government's CERCLA claim, the court
held that the defendants were liable for all costs incurred by
the United States in connection with a removal action taken by
EPA at the Church of God subsite.
The court directed the parties to try to reach an agreement as
to the relief which should be provided based upon the court's
determinations as to liability and with regard to the importance
of the secondary lead smelter industry to the environment and
the economy. The parties could not reach an agreement and each
has submitted a proposed final judgment with the court.
3.0
BIt:RT.IGB'l'S OF COJOmRI'l'Y PARTICIPATION
Community interviews were conducted in 1986. A fact sheet was
distributed February 1987 to inform the public about EPA
investigations. EPA updated the community relations plan in
1989 and held community interviews again in January 1990.
The Proposed Plan for the ILCO Site was released to the public
on July 25, 1991. This document was made available in both the
administrative record and an information repository maintained
at the EPA Records Center in Region IV and at the Leeds Public
Library. The notice of availability was published in the
Birminaham News and the Birminaham Post-Herald on July 24, 1991
and was published in the Leeds News July 25, 1991. A public
comment period was held from July 25, 1991 through August 24,
1991. In addition to public comment and the accessibility of
the information, a public meeting was held on August 8, 1991.
At this meeting, representatives from ADEM and EPA answered
questions and addressed community concerns. Due to a request
from ILeO the comment period was extended to September 23,
1991. A response to comments received during this period is
included in the Responsiveness Summary, Appendix A of this
Record of Decision. This decision document presents the
selected remedial action for the ILCO Site, in Leeds, Alabama,
chosen in accordance with The Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by The Superfund Amendments and Reauthorization Act of
1986 (SARA) aDd, to the extent practicable, the National
Contingency Plan. The decision for this site is based on the
administrative record."
The ILeO Community Relations Plan (CRP), and previous fact
sheets can also be found in the repository and the Leeds Public
Library .
Page 5
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4.0
SCOPB AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
The problems at the ILCO Superfund Site are complex. As a
result, EPA has divided the work into two manageable components
called "operable units (OUS)". The action discussed in this
Record of Decision (ROD) is considered the first of two planned
operable units for the site. The first operable unit addresses
contamination at the areas where Superfund remedial action will
be conducted. This includes the following:
OPERABLE UNIT lOU} i1
SUDerfund Activities
ILCO Parking Lot (Subsite lb) - Source (Soil, Slag,
Battery Casings)
Gulf Service Station (Subsite 2) - Source (Soil,
Sediment), and Groundwater
J & L Pabricators (Subsite 3) - Source (Soil,
Sediment) and Groundwater
Pleming's Patio (Subsite 4) - Source (Soil, Slag,
Treatment Sludge, Battery Casings) and Groundwater
The Connell Property (Subsite 5) - Source (Soil,
Slag) and Groundwater
City of Leeds Landfill (Subsite 6) - Source (Soil,
Slag, Treatment Sludge, Battery Casings) and
Groundwater
Acaar Church of God (Subsite 7) - Source (Soil, Slag,
Treatment Sludge) and Groundwater
The ILCO facility is an operating RCRA facility and they are
currently under a 1988 EPA RCRA Consent Order to conduct
corrective action at their facility. The second operable unit
will address contamination at the areas where RCRA Corrective
Action will be conducted. This includes the following:
OPERABLE UNIT lOU} .2
RCRA Activities
ILCO llain Pacility (Subsite la) - Source (Any
contamination on or around the ILCO Main Facility) and
Groundwater (including groundwater contamination from
the Parking Lot).
The UnftA-~d Tributary Cleanup - Any contamination
associated with the stream contamination from the main
facility and parking lot.
A DowD8treaa Study of Dry Creek - An investigation
into any contamination from ILCO found downstream of
the facility.
EPA has now selec1!ed cleanup alternatives for OU'1. The Agency
will monitor the progress of the RCRA actions in OU .2 and
review those actions to ensure that they meet CERCLA
requirements. Many of the activities outlined in OU .2 are
currently in progress or will be soon. Upon completion of these
activities the Superfund program will present to the public an
Page 6
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appropriate plan of No Action or whatever further action is
necessary and a Record of Decision (ROD) will be written to
address OU #2.
Contamination at various subsite locations affects different
environmental media. Due to the complex nature of the ILCO
Superfund Site, the alternatives that have been evaluated have
been divided into two groups. The first group of alternatives
addresses cleanup of the source of contamination. The
remaining group of alternatives address cleanup of groundwater.
A source is an area or material found at a hazardous waste site
from which contamination originates. Groundwater is the water
found beneath the earth's surface that fills pores between
materials such as sand, soil, gravel, and cracks in bedrock and
sometimes serves as a source of drinking water.
Removal of the source at some of the subsites will eliminate the
principle threat at that subsite. Treatment of the groundwater
or natural attenuation of the groundwater contaminants and
removal of the source at these subsites will return the
groundwater to its beneficial uses within a reasonable
timeframe. .
5.0
SUMMARY OF SITE CHARACTERIZATIONS
5.1 REGIONAL GEOLOGY
The ILCO Site is located in the Appalachian Valley and Ridge
Physiographic Province, within the Cahaba Valley. The
northeast-southwest trending layers of rock in the ILeO area are
steeply inclined to the southeast at angles up to 45 degrees and
are intensely fractured and jointed (Kidd 1977). Table 1
describes the rock types encountered at each ILCO subsite.
5.2 SUBSITE SPECIFIC GEOLOGY
The Parking Lot area, including the slag and other wastes, is
underlain by alluvium, the Pride Mountain Formation, the
Hartselle Sandstone, and the Tuscumbia Limestone.
The Gulf Service Station subsite is underlain by 3 to 10 feet of
chert gravel, sand, and silt of Quaternary age, which directly
overlies crystalline limestone of the undifferentiated
Ordovician-age.
The J & L Fabricator subsite and the Connell Property are
underlain by . 0 to 50 foot thick veneer of generally
unconsolidated deposit8 of Quaternary gravels. The gravels
overlie the Floyd Shale. At J & L Fabricators the shale and
interbeds of gray shaley siltstone are highly jointed. The
geologic unit underlying the City of Leeds Landfill subsite was
not identified, but it appears to also be the Floyd Shale.
Page 7
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Table 1
Rock Types Encountered 81 ILCO SIUdy Sites
ApproXImate
Thickness
Rock Type (Ct) Site Descrip!ion
Quaternary-age gravel 5.20 Main racility Quanz & chen pebbles. cobbles in fine to very coa~
5.20 Parking Lot quanz. chen sand. clay matrix.
3.10 Gulf Ser"lce Station
0-50 J &I: L rabncaton
0-50 Connell Propeny
Pennsylvanian.age
Poltsville Formalion . Atmar Church Inlerbedded sandstone. sillStones. shales. clay. and coal
seams.
Mississippian-age
Floyd Shale 300-1.000 Main racility Dark-gr.ry clayey shale within sandslone lenses. weathers
Parking LOI 10 dark-brown to lighl-gr3y clay.
J &t L Fabricalors
Connell Propeny
Leeds Landfill
Hanselle Sandstone 0-12 Main Faciliry Clean. well.soned. very fine. 10 medium'grained. cros.~-
Parking Lol bedded sandslone. In valley. Ihin 10 medium bedded.
very.fine. 10 fine.grained and panly argillaceous.
Pride Mounrain
Formalion 1204W Main Faciliry Dark-gray. fISSile. clay shale within beds of sillslone or
Parking Lol fine.grained sandslone wilh a basal bed of oolitic
sandstone approx. 8 ft thic:1t. Contains siderile nodules
and marine invenebrale fos&ils.
Tuscumbia Limestone
. Parking Lot Gray. massive. conlains ~ular pockets of chen.
Fon Payne Chen
90-200 Main Facility Gnyish~range 10 Iipt-craY bedded. fossiliferous chen
Parking Lot (beds 2-3 feet thick) wilh separation by Ihin shaly zones.
Maury Formation
. Parking Lot Greenish-gr3y to gnyish-mS Ihinly laminaled shale
commonly c:ontaining phosphate nodules.
OrdOYiciJln-age
Undifferenualed 2..300-2.600 Gulf Service Slatton Medium-bedded. lighl-Io-dark 10 very dark.gray
sublilhographic:. 10 very coarsely cryslalline limeslone.
fossiliferous. andlor c:herty in pan.
OrdOYiciJln Cambrian.
age
Knm Group
Undifferenlialed 3.000 Fleming's Palio Thick-bedded c:hem dolomile wilh lesser amounls of
limestone and dolo~ilic: limestone. wealhers 10 irregular
boulders and fragmenlS of lipl-sray 10 grayish-pink
chen. generally non.fOS&i1iferous.
.Unknown
dbt065\092.S 1
-------
The Fleming's Patio subsite is underlain by Knox Group
Undifferentiated cherty dolomite, limestone, and dolomitic
limestone. The unit is a light brown clay with irregular chert
fragments and boulders. This weathered material was present at
a depth of 104 feet in one well at the site.
The Acmar Church of God site is underlain by black organic
shales and coals of the Pottsville Formation. Outcrops of coal
and associated carboniferous black shales are just northeas~ of
the church. An underclay, typical of coal deposits, underlies
the coal-bearing material and outcrops to the northwest. A
massive sandstone overlies the coal to the southeast. All of
these lithologic units trend northeast-southwest and are steeply
inclined to the southeast at an angle approaching 45 degrees.
5.3 REGIONAL HYDROGEOLOGY
Generally, four water bearing zones are present throughout
different areas of Leeds area. They include the followin~1
Surficial aquifer--Consists of a thin layer of
unconsolidated alluvial deposits that covers most of the
valley. Maximum thickness is 20 feet. Separated from the
shallow aquifer system by a silty clay at some locations.
Very poor source of water to wells. Unconfined water.
Shallow aquifer--Consists of weathered to consolidated
material in the upper part of the bedrock. Generally no
more than 30 feet thick. Separated from the underlying rock
in some areas by a dense, dark-gray clay. Very limited
source of water to wells. Unconfined water.
Fort Payne Chert Aquifer--Provides some water supply to
the City of Leeds. Leeds city wells installed to depths of
150-300 feet and located approximately 1/2 mile to the
northeast of the Main Facility and Parking Lot site. The
formations above it are of a lower permeability thereby
creating a confined water system.
Ordovician Undifferentiated Aquifer--Consists of 1,000
feet of crystalline limestone. Two springs in this
formation provide water supply to the City of Leeds. The
Weems Spring"ia located off Cemetery Road approximately 5
miles southeast of the Acmar Church in Moody, Alabama, north
of Leeds. The Rowan Spring is located in Leeds at the
intersection of Highway 119 and President Road.
5.4
SUSSITE SPECI-l'IC HYDROGEOLOGY
The groundwater monitoring at the subsites was conducted in the
local surficial aquifers found in that particular area. The
rock formations found in these surficial aquifers vary from
subsite to subsite. The hydrogeologic discussion and the
groundwater remediation at the Parking Lot will be addressed in
Operable Unit '2.
Page 9
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The Gulf Station
Groundwater occurs in weathered shales and Ordovician-age
limestones at 4.5 to 14.5 feet below land surface (bls).
Groundwater is unconfined and flow is to the northwest,
discharging from fractures in the l~estone into the Little
Cahaba River. Groundwater flow is shallow and to the northwest.
Water yield from these rocks varies quite a lot, ranging from
poor to good, as determined from slug tests. The hydraulic
conductivity of the two wells te~ted was 0.92 ft/d (3.3 x 10-4
cm/sec) and 35.2 ft/d (1.2 x 10- cm/sec). The difference in
the two hydraulic conductivities is thought to be due to
fractures encountered in one of the wells. This well produces
the most water. An average hydraulic conductivity of 18 ft/d
was used. The groundwater flow velocity was estimated to be
approximately 8 ft/d to the northwest.
J & L Fabricators
Groundwater generally occurs under unconfined conditions from
4.5 ~o 7.5 feet bls in the weathered Floyd Shale. The
groundwater flow is to the southwest toward Dry Creek from
alluvium and the Floyd Shale. The average hydraulic
conductivity of thes~ rocks, as determined from a slug test, is
0.94 ft/d (3.3 x 10- cm/sec), indicating a very poor
water-yielding unit. The groundwater flow velocity was
estimated to be approximately 0.22 ft/d, with flow to the
southwest.
Flemina's Patio
Groundwater occurs in dolomites and cherty clay underlying the
fill material. The groundwater is unconfined. Water levels
range from about 1.5 to 83.5 feet bls. Flow has been modified
by the presence of a recharge mound in the low permeability
clayey chert zones and dolomitic materials underlying the fill
at the site. Surface stormwater flowing down Alaska Avenue and
from adjacent uplands percolates rapidly into the highly
permeable fill material. The water contained in the fill.
material then slowly seeps downward into the underlying rock,
forming a water 1;.able recharge mound. This mound flows from the
fill area toward the northeast in the northern section of the
sUbsite and to the southwest in the southern section of the
sUbsite.
The average hydraulic conductivity of t~ese rocks, as determined
from slug tests, .k 2.45 ft/d (8.6 x 10 cm/sec), indicating a
poor water-yielding unit. The groundwater flow velocity from
the fill area, which appears to be underlain by a groundwater
recharge mound, was estimated to be approximately 6.53 ft/d to
the northeast and 10.9 ft/d to the southwest due to the mounding
effect.
Page 10
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The Connell Pro~ertv
Groundwater is unconfined and occurs in the surficial aquifer
and the shallow weathered zone of the fractured Floyd Shale.
Water levels range from 3 to 12 feet bls. The flow is toward
the northwest at depths of about 9 feet below land surface into
a marshy area. In the northwest corner of the property,
groundwater seems to co~e to land surface during very rainy
years. This provides flow as seepage during those years.
The average hydraulic conductivity of thlse rocks, as determined
from slug tests, is 0.93 ft/d (3.3 x 10- cm/sec), indicating
a very poor water-yielding unit. The groundwater flow velocity
estimated to be approximately 0.95 ft/d.
The City of Leeds Landfill
Groundwater occurs in clay and along fractures in the underlying
steeply inclined Floyd Shale. Water levels range from
approximately 6.5 to 25 feet bls. According to the water
elevations at three onsite monitor wells, groundwater appears to
flow to the west-northwest.
Groundwater flow is to the west-northwest, generally conforming
to the contours of the land. The average hydraulic conductivity
of ihese rocks, as determined from slug tests, is 2.6 ft/d (9 x
10- cm/sec), indicating a poor water-yielding unit. The
groundwater flow velocity was estimated to be approximately 2.95
ft/d, to the west-northwest.
The Acmar Church of God
Groundwater flow is through Pennsylvanian-age Pottsville
Formation shales and poorly sorted, silty sandstone, with some
associated coal beds. Water levels in the two onsite wells
range from 37 to 45 feet bls. No groundwater was encountered in
the upper silty sand and shale. It is not possible to determine
the direction of groundwater flow based on the water levels in
the two onsite wells aloneJ however, it is expected that
groundwater flow follows the topographic slope downward to the
northwest and southeast. The Weems Springs is located
approximately 5 miles southeast of the site. No other springs
have been observed in the vicinity of the site.
The depth to groundwater exceeds 40 feet at the site. The
average hydraulic conductivity of the~e rocks, as determined
from slug testa, is 8.5 ft/d (3 x 10- cm/sec), indicating a
low to moderate wfter-yielding unit. The availability of only
two wells at the subsite allowed the estimation of an
approximated groundwater flow velocity of 3.4 ft/d in a
southwesterly directionJ it is likely to be as much as 25 to 50
percent greater on the steep. slopes of the ravine above which
the site is located.
Page 11
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5.5 SURFACE WATER
Three significant surface water bodies in the Leeds area are the
Cahaba River to the north of the City of Leeds; the Little
Cahaba River, which runs through Leeds just north and west of
the Gulf Service Station; and Dry Creek, a stream that runs near
the Main Facility and Parking Lot and J&L Fabricators and flows
into the Little Cahaba River in the vicinity of the wastewater
treatment plant. The Acmar Church of God is located at the
confluence of Big Black Creek and Little Black Creek, which
flows into the Cahaba River north of the City of Leeds.
5.6
ECOLOGY
No endangered or threatened species were observed during the
RI. Although none were found there is a remote possibility that
some of the endangered or threatened animals may potentially
occur within the general geographic area. Possible aquatic
species that may be present include the Cahaba shiner, goldline
shiner and the blue shiner. Other animals that may be present
in surface water habitats include the southern hognose snake,
eastern tiger salamander, green salamander, coal skunk, northern
pine snake, and the red-cockaded woodpecker.
5.7
SAMPLING RESULTS
The primary emphasis for analytical testing during the RI was
placed on determining the impact that the lead waste may have
had on the environment at each of the seven subsites, including
the effect on soil, surface water, sediment, air, and
groundwater. Specifically, the analytical testing program was
developed to detect the presence of lead. In addition to lead,
other inorganic compounds were identified during the RI.
However, due to lead's wide spread distribution, concentration,
and toxicity, lead was selected a8 the primary contaminant of
concern at each subsite. The complete analytical data used for
the remedial investigation is available in the RI Report. A
summary of contaminants of potential concern found at all of the
subsites is shown in Table 2.
Background surface soil samples were collected in an area
located approx~tely 1,800 feet southeast of the ILCO Facility.
parkina Lot
Groundwater - The RI investigated groundwater at the Main
Facility and Parking Lot. However, this groundwater
contamination is included in Operable Unit #2 and is being
addressed under RCRA. It will be addressed in a future ROD.
Soil - Lead concentrations exceeding 1,000 mg/kg were detected
in nearly all the surface soil samples collected around the
outer borders of the Parking Lot. Subsurface samples taken from
Page 12
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TAB:.E 2
SUMMARY OF CONTAM ~ANTS OF POTENTIAL CONCERN
ILCO Parking Lot
oncentration '
Parameter' Groundwater Analytical XRF Surface Water Sediment Air Fish
Soil Soil Tissue
(ug/l) (mg/kg) (mg/kg) (ug/l) (mg/kg) (ug/m3) (mg/kg)
Lead 5J-11,000J 11-28,000J 10-82,874 49-1,200 1,200-19,100 0.117-0.316 10-12
Antimony 77J 10J-170J 67-120 20J-61JH 0.023-0.106 NA
Arsenic 11-16 2.7NJ-160 ND 7.4J-22J 0.006-0.049 NA
Cadmium 5-34 1.2*-50 6J-14J 4.8-22 ND 0.6-0.79
Chromium 7-130 8.6-29* ND 7.4-8.5 ND 0.68-0.94
Copper 8-84 4.9J-89J ND 33-50 NA 0.63-9.94
Nickel 34-270 6.6-100 ND 10-39 NA 0.69-0.8
Gulf Service Station
Lead 7 12J-2,100 8-2,490 ND 23J-660J 0.0264 0.4-0.8
Antimony ND ND ND ND 0.0178-0.0187 NA
Arsenic ND ND 12 5.7J-10J ND NA
Cadmium ND 3.5 ND ND ND ND
Chromium ND 13-36JH ND 24J-47J ND 0.76-1.1
Copper ND 66 ND 39J-74J NA 0.67-2.4
Nickel ND 5.4-28 ND 7.06-25 NA 0.76-3.5
J & L Fabricators
Lead 96J 9.3-130,000A 7-84,355 5J-7J 16J-39J 0.021-0.391 2.8-3.3
Antimony ND 5-11 ND 30JH 0.09-0.10 NA
Arsenic ND 2.7-11 ND 4.2J-8.4J 0.0008-0.025 NA
Cadmium ND 0.6-2 ND 0.26J 0.0009-0.008 ND
Chromium ND 9-140 ND 20J-58J 0.002-0.006 0.74
Copper ND 8.2-91 ND ND NA 1-1.6
Nickel 13-64 6.1-220 ND 14J-22J NA 0.48-0.59
Pleming'. Patio
-
6-180 1.4J-110,000J 9-50,103 -- 19.6-239 0.0279-0.0766 --
t --..r\y ND 36JN-l,600JR -- NA ND --
r " ND 2.2-1,500J -- NA ND --
C .J!l ND 1.3J-71J -- NA ND --
C .wn 49-60 4.9-32 -- 6.1-32.6 ND --
Co:;.... -- 16-130 6.5J-2,800J -- NA NA --
Nickel 29-110 6.6-200J -- 2.6-15.4 NA --
* Le.. than bac~ concentration.
A - Average value ba.ed on two or more 88mple concentration.
J - Betimated value
JH .'Analyte waa -tentatively identified,- and the a..ociated numerical value may
be con.istent with the amount actually pre..nt in the environmental sample.
NA . Mot analyzed
ND - Mot detected
-- . Mot applicable
XRI' . X-ray Fluorescence
!
I
-------
TABLE 2 CONTINUED
Connell Property i
-oncentration I
Parameter Groundwater Analytical XRP Soil Surface Sediment Air Fish Tissue
(ug/l) Soil (mg/kg) (mg/kg) Water (ug/l) (mg/kg) (ug/m3) (mg/kg)
Lead 5-18 21-84,000 42-44,473 -- 5.78-167 0.0349-0.0555 --
Antimony ND 13J-22J -- NA 0.0178 --
1U:senic lie 6.aJN-S1JN -- NA .m I
--
Cadmium ND 7.2 -- NA ND --
Chromium ND 9.8-200 -- 2.48-15.2 ND --
. Copper 19-46 9.4-63J -- NA NA --
Nickel 47-52 4.3-280 -- 5.19-10.5 NA --
City of Leed. Landfill
Lead 24-44 9.5J-34J* 3-716 -- 15.0-190 0.0543 --
Antimony ND 7.8J-20J -- NA 0.0172 --
ArSeniC 12J 2.1JN-4.4JN* -- NA 0.0046 --
Cadmium ND ND -- NA ND --
Chromium 96 4.5-18* -- 17-73.1 0.0196 --
copper 53 4.1J-21J* -- NA NA --
NiCkel 44-130 4.8-14 -- 9.43-27.4 NA --
Ac:mar Church of God
Lead 6-10 960 12-32,225 -- 10.3-11.2 ND --
Antimony ND ND -- NA ND --
Ar..nic ND 12 -- NA ND --
Cadmium ND ND -- NA ND --
Chromium ND 12 -- 6.32-6.70 ND --
copper ND 46 -- NA NA --
NiCkel ND 19 -- 6.46-15.0 NA --
* Le.. than background concentration.
J - Estimated value
IN - Analyte was "tentatively identified," and the associated numerical value may
be consistent with the amount actually present in the environmental sample.
NA - Not analyzed
ND - Not detected
-- - Not applicable
XRP - X-Ray Pluore.cence
-------
the northwest and southeast corners of the Parking Lot exceeded
1,000 mg/kg. The center of the Parking Lot had lead
contamination at greater depths than the outer borders. The
extent of lead concentrations in soil greater than 300 mg/kg at
the Parking Lot is shown in Figure 2. X-Ray Fluorescence (XRF)
data ranged from 10 to 82,874 mg/kg lead in soil. Analytical
results showed concentrations ranging from 6.6 to 100 mg/kg for
nickel, 8.6 to 29 mg/kg for chromium, 1.2 to 50 mg/kg for
cadmium, 2.7NJ to 160 mg/kg for arsenic, 10J to 170J mg/kg for
ant~ony, and 4.9J to 89J for copper.
Sed~ent and surface water contamination will be addressed in a
later Record of Decision (ROD).
Gulf Station
Groundwater - Lead was detected in the turbid unfiltered samples
at the Gulf Station at a concentration of 7 ug/l. It was found
in the well closest to the fill area. None of the other'
parameters were detected in the monitor wells. The upgradient
well, GG-2, contained sufficient water for water level
measurement purposes, but there was not enough water present for
sampling and analysis. Figure 3 shows the results for
unfiltered lead specific conductivity and pH for each monitoring
well. Insufficient data points were available for preparing a
map showing, as contours, the approximate distribution of lead'
in groundwater when unfiltered samples were collected.
Soil - Lead concentrations exceeding 300 mg/kg were detected in
surface soil samples collected along the southwest edge of the
site (adjacent to Highway 78) and collected north of the Gulf
Station. The extent of lead contamination in the soil at the
Gulf Service Station is shown in Figure 3. The lead
concentrations greater than 300 mg/kg are contained' within the
upper 6 feet of the soil. Only one sample (located in the
depression on the southern edge of the site) was analyzed for
the other parameters, and the results were 12 mg/kg, 24 mg/kg,
3.5 mg/kg, and 66 mg/kg for nickel, chromium, cadmium, and
copper, respectively. Samples collected from groundwater well
borings detected chromium at 13-36JN mg/kg and nickel at 5.4-28
mg/kg. XRF data for soile detected lead at concentrations
ranging from 8 to 2,490 mg/kg. '
Lead was not detected above 300 mg/kg in the five surface soil
samples collected at the Leeds Elementary School.
Surface Water - ~enic wae the only metal detected in surface
water samples collected at the Gulf Service Station. It was
detected at 12 ug/l at location SG-4. This is below the AWQC
for arsenic. Fish tissue samples detected lead, chromium,
copper and nickel.
Sediment - Analytical results for sediment samples were all
reported as estimated concentrations. Concentrations ranged
form 23J to 660J mg/kg for lead, 7.06 to 25 mg/kg for nickel,
Page 15
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lu
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24J to 47J mg/kq for chromium, and 5.7J to 10J mg/kg for
arsenic. The highest lead concentration detected was located
southwest of Highway 78. The sampling locations and
concentrations are shown in Figure 4.
Air - Lead and antLmony were detected in air samples.
J&L Fabricators
Groundwater - In samples collected from the monitor wells at the
J & L Fabricators site, lead was detected in one sample at 96J
ug/l, nickel was detected at 13 and 64 ug/l, and the other
parameters were undetected. Unfiltered groundwater samples from
Monitor Wells GJ-2, GJ-4, and GJD-1 were turbid. Figure 5 shows
the results for unfiltered lead, specific conductivity, and pH
for each monitor well.
Soil - Lead concentrations at the J & L Fabricators subsite
ranged from 9.3 to 130,000A mg/kg. The A represents an average
value based on two or more sample concentrations. Lead.
concentrations in the surface soil ranged from 149 mg/kg on the
south side of the site to 61,798 mg/kg in the central part of
the site. Lead concentrations exceeded 300 mg/kg in most of the
surface samples except in samples collected from the
southeastern and southwestern corners of the site. Most of the
subsurface samples that exceeded 300 mg/kg were located just
northwest and southeast of the metal fabricating building. A
1985 EPA soil sampling event detected a level of 130,000A mg/kg
for lead, 140 mg/kg for chromium, and 220 mg/kg for nickel.
XRP data detected lead in soil at levels ranging from 7 to
84,355 mg/kg. Analytical results detected concentrations in
subsurface soil ranging from 6.1 to 23 mg/kg for nickel, 9 to 54
mg/kg for chromium, 0.6 to 2 mg/kg for cadmium and 2.7 to 11
mg/kg for arsenic. The extent of lead contamination in the soil
at J & L Fabricators is shown on Figure 5. .
Surface Water - Lead was the only constituent detected in
surface water. Lead concentrations ranged from SJ to 7J ug/l.
The 7J ug/1 result is above the AWQC for lead in surface water.
Figure 6 shows the samples locations and concentrations. Fish
tissue samples detected lead,. chromium, copper and nickel.
SedLment - Concentrations ranged form 16J to 39J mg/kg for
lead. Other metals were detected below the NOAAs Effects Range
for those contaminants in sedLment.
Air - Air samples detected all of the contaminants of concern
except for copper~d nickel.
Flemina's Patio
Groundwater - Groundwater concentrations detected in the turbid
samples from Fleming's Patio ranged from 6 to 180J ug/l for
Page 18
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10CAMNS AND UMin Of
•• inrtf" UIIIMI ran IM u tutut
• M HiMUM •IMMAtM **•'
FIGURE 5
EXItNI OF UAO
CONTAMINAHON IN SOIL -
J *L FABRIC AIORS
• CO IB/I s
-------
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FIGURE 6
MnAl CONCfN IRA nONS DE IE r. Ii II
IN SURf' ACt WATER
J . l f AtiRI(;A JUt(:.
!lCO III" S
.
-------
lead. The highest concentration levels for nickel, chromium,
and copper were detected in Monitor Well GF-2A~ The highest
reported concentration of lead (180J) was found in Monitor Well
GF-6. Monitor well GF-6 is centrally located beneath the fill
area in undisturbed rock. None of the parameters were detected
in Monitor Well GF-3, which appears to be the upgradient monitor
well. Cadmium, .arsenic, and antimony were not detected in any
of the monitor wells. Figure 7 shows the unfiltered lead,
specific conductivity, and pH results for each monitor wells.
This figure also shows the approximate distribution of lead in
groundwater based on the analysis of unfiltered samples.
Two model runs were conducted to determine what might be
expected to happen if the excessive lead concentration reported
in Monitor Well GF-6 is valid and the flow is from Monitor Well
GF-6 toward the groundwater of Monitor Well GF-7. An assumption
for one model run was that the carbonate concentration reported
represents carbonate alkalinity. In a second run, the
assumption was that there was an infinite source of dolomite in
the area of Monitor Well GF-7 for reactions to take place with
the metals-bearing groundwater moving from the area of Monitor
Well GF-6. The modeling results indicated that the lead content
of the groundwater would be reduced to about 0.0883 and 0.0971
mg/l, respectively, by the time that it reached Monitor Well
GF-7.
Soil - Lead concentrations detected in the surface soil at the
Fleming's Patio site exceeded 300 mg/kg at sampling locations
west of Alaska Avenue and Erie Street, northwest of the
Fleming's Patio building, and south of the Fleming's Patio
building.
In sampl~ng events conducted prior to 1990 the highest surface
soil concentration (XRF data - 30,742 mg/kg) was detected in a
sample from the parking area west of Alaska Avenue.and Erie
Street. The highest subsurface soil concentration (XRF data -
50,103 mg/kg) was detected in a sample located north of the
Fleming's Patio building Concentrations in the subsurface soil
ranged from 6.6 to 23 mg/kg for nickel, and 4.9 to 18 mg/kg for
chromium. Arsenic was detected at 2.2 mg/kg. A 1984 sampling
detected chromium at a level of 32 mg/kg.
During the 1990 remedial investigation, additional surface and
subsurface soi1 samples were collected at six locations to
depths up to 25 feet. The latest soil sampling results show that
lead concentrations in the soil samples collected from the
surface ranged from 5.5J to 440J mg/kg in location FSS2. In the
o to 5 foot depth Tange, lead was detected in concentrations
from 4.1J to 65,000J mg/kg. Higher concentrations of lead were
found with depth at location FSS1 (100,000 J) and FSS4 (110,000
J). The lead concentration in the only sample collected in the
20 to 25 foot depth range was 18,000J mg/kg. The extent of lead
contamination in the soil at. Fleming's Patio is shown in Figure
7.
Page 22
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FLEMING S PA 110
PARKING 101
UAO (UNIU HKItl)
COMIOUHV u«/l
It AD (UNFIl II RID) CONCENTRATIONS
DC IECTEO IN GROUNOWATER
FLEMING'S PA no
• COM/tS
OF LEAD
CONIAMWAHON IN SOL -
FLtMINGS PAHO
-------
Nickel concentrations were all less than 40J mg/kg except the
concentrations detected at location FSS1 where the results were
71J mg/kg - 200J depending on depth. Chromium concentrations
were also less than 40J mg/kg and cadmium concentrations were
all less than 50 J mg/kg except for one concentration of 71J
mg/kg detected at location FSS1. Arsenic concentrations were
all less than.100J mg/kg except for one concentration of 200
mg/kg detected at location FSS4. At location FSS1, the vertical
distribution of arsenic concentrations ranged from 7.4J mg/kg to
1,500J mg/kg. Copper was found at 2800J mg/kg.
Sediment - No surface water was found at the site although
sediments from a ditch were sampled and detected lead, chromium,
and nickel.
Air - The only constituent detected in the air samples was lead.
Connell PrODertv
Groundwater - Concentrations in the unfiltered groundwater
samples ranged from S to 18 ug/l for lead, 47 to S2 ug/l for
nickel, and 19 to 46 ug/l for copper. Lead was detected at 18
and 12 ug/l in the turbid samples from Monitor Wells GC-3 and
GCS-2, respectively. Copper was detected at 19 and 46 ug/l in
the two upgradient monitor wells, GCS-1 and GCS-2. The other
parameters were not detected in any of the monitor wells.
Figure 8 shows the unfiltered lead, specific conductivity, and
pH results for each monitor well. This figure also shows, as
contours, the approximate distribution of lead in groundwater
when unfiltered samples were collected.
Soil - Based on analytical results, lead concentrations in the
soil at the Connell Property ranged from 21 mg/kg on the western
side of the property to 3,600 mg/kg on the southwest of the
house. Lead concentration exceeding 300 mg/kq were primarily
detected in surface soil samples collected. just south of the
Connell residence and along the western edqe of the site. The
only subsurface soil samples with lead concentrations exceeding
300 mg/kq were located in the southwest corner. of the Connell
Property site. XRP data ranged from 42 to 44,473 mg/kq lead in
soil. A 1985 EPA sampling event detected lead in soils at
84,000 mq/kq. This event also found 200 mqlkg for chromium and
280 mg/kq for nickel. Analytical results indicated
concentrationa in the subsurface soil ranging from 4.3 to 83
mg/kq for nickel, 9.8 to 26 mg/kq for chromium, 7.2 mg/kq for
cadmium, and 6.8JH to S1 JH for arsenic. The extent of lead
contamination in bhe soil at the Connell Property is shown in
Figure 8.
Sediments - No surface water was found at this subsite.
Sediments contained lead, chromium and nickel.
Air - Air samples detected lead and antimony.
Page 24
-------
^
[•Ml »•»
U MOt MK CKD
o
o
70
O
MOIL.
tOCAWMS MO UMK Of
FIGURE 8
LEAD (UNFUIEREO) CONCENTRATIONS EXIENT Of U AD
0£1ECTE6 IN CROUNOWATER CONTAMINATION IN icML
CONNELL PROraR 1TV f*MQ CONNELL PROPfRlY
-------
Citv of Leeds Landfill
Groundwater - Groundwater concentrations detected in the turbid
unfiltered samples at the City of Leeds Landfill ranged from 24
to 44 ug/l for lead, and 44 to 130 ug/l for nickel. Arsenic was
detected at a concentration of l2J. Chromium was detected at a
concentration of 96 ug/l and copper at a concentration of 53
ug/l. The highest concentration levels for lead, nickel,
chromium, and copper were detected in Monitor Well GL-3.. None
of the parameters were detected in Monitor Well GS-l, which is
the upgradient monitor well. Cadmium and antimony were not
detected in any of the monitor wells. Figure 9 shows the
unfiltered lead, specific conductivity, and pH results for each
of the monitor wells. Insufficient data points were available
for preparing a map showing, as contours, the approximate
distribution of lead in groundwater.
Soil - The lead concentrations in the City of Leeds Landfill
were generally less than 500 mg/kg. Only three surface soil
samples collected had lead concentrations that exceeded 3aO
mg/kg. The surface soil sample collected near the western e~ge
of the site contained the highest reported concentration (XRF
data - 716 mg/kg). Concentrations ranged from 4.8 to 14 mg/kg
for nickel and 4.5 to 18 mg/kg for chromium. Cadmium was not
detected. Arsenic was found at levels from 2.1JN to 4.4JN
mg/kg, and copper from 4.1J to 21J and antimony from 7.8J to
20J The extent of lead contamination in the soil at the City of
Leeds Landfill is shown in Figure 9.
Sediments - Surface water was not sampled at this subsite.
Sediments detected lead, chromium and nickel.
Air - Air samples detected lead, antimony, arsenic, and
chromium.
Acmar Church of God
Groundwater - Lead was detected in the upgradient monitor well
GS-2 at 10 ug/l and in the downgradient monitor well GA-1 at 6
ug/l. Both of these unfiltered groundwater samples were
turbid. None of the other parameters were detected in the two
monitor wells. The lead, specific conductivity, pH for each
monitor well are "shown in Figure 10. Insufficient data points
were available for preparing a map showing, as contours, the
approximate distribution of lead in groundwater.
Soil - An emergency response remedial action at the Acmar Church
of God removed some of the contaminated soil; however, lead
concentrations exceeding 300 mg/kg were detected in both surface
and subsurface soil samples. The surface soil samples with lead
Page 26
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IO HIGHWAY 25
(UUNAVANT ROAD)
g MOMIDH KLL LOCATION
44 UAO (UNntTEMCDX Uftl*.
(140) SrCOFIC CONDUCTANCE. wnl>M
|t 4) »
0 NOT MTECTEO
J (SIMATCO VALUE
•• m*mm mtomt rai •• u VMM
• »• !••«•! tUANRIAMM UMI.
•numcKMi DATA pown ran
UA* »««.••»)
wo IMIIS or
AMI
a i
I
LEAD (UNFILTERED) CONCENTRATIONS
DEIECTE6 IN GROUNDWATER
QTY OF LEEDS LANDFILL
FIGURE 9
EXTtN! OF HAD
CONTAMINATION IN SOIL -
OTY OF LEADS LANDFILL
• CO Hi/IS
POOR QUALITY.
ORJGINAL
-------
- WEE LINC
( APPROXIMATE
LOCATION)
TREE LINE
(APPROXIMATE
LOCAItON)
UQW1ON Mil IOCAIIOM
10 l£AO(ONf«.««O)
(JSO)
[3 M)
SKCIflC CONOUCIANCt,
COMCfNIHAROU
DlCtCOS 500 UC/VC m
S1IO««. I OB n« u vuul
auoNni»noN IIMII
•HUtflOMI DAI» r»M
CUUIOUWNC UAO (
LOCAIKMS AND I lull!,
*«
FIGURE
EXTENT or IE AD
CONTAMINATION IN SOIL
ACMAft CHURCH OF COO
ICAO (UNTILTEREO) CONCENTRATIONS
DETECTED IN GROUND WATER
ACMAR CHURCH OF GOD
ICO MAS
-------
concentrations exceeding 300 mg/kg were located in the drive
leading to the church and along the sloping eastern edge of the
site. In the 2 to 4.5 foot depth interval, lead concentrations
exceeding 300 mg/kg were detected in samples from the eastern
edge of the site. Analytical results found lead at 960 mg/kg.
XRF data ranged from 12 mg/kgto 32,225 mg/kg for lead. Only
one sample was analyzed for other parameters, and the results
were 19 mg/kg for nickel, 12 mqlkg for chromium, 12 mg/kg for
arsenic and 46 mq/kq for copper. The extent of lead
contamination in the soil at the Acmar Church of God is shown in
Figure 10.
Sediment - No surface water was sampled at this subsite.
Sediments contained lead, chromium and nickel.
Air - No air contaminants were detected.
6.0
SOMMARY OF SITE RISKS
CERCLA directs the Agency to protect human health and the
environment from current and potential exposure to hazardous
substances at the Site. In order to assess the current and
potential risk from the Site, a baseline risk assessment was
conducted as part of the RI. A detailed discussion of the
results of that investigation can be found in Chapter 7 of the
RI report. This assessment evaluated the potential risk posed
by the Site to humans and the environment without the benefit of
any further remediation. The assessment focused on lead which
is the primary contaminant of concern. Other contaminants of
concern include antimony, arsenic, cadmium, chromium and
nickel. The results of the risk assessment show that lead is
the major contaminant of concern resulting from disposal of ILCO
waste at the subsites. The other constituents contribute
additional risks from exposure to the waste and may influence
the selection of remediation levels for lead. Remediation
measures to control contact with lead or reduce mobility of lead
will concurrently reduce hazards from the other waste
constituents. .
Although specific conditions vary at the ILeO subsites, the
general exposure pathway information applies to all of the
subsites. The source of contamination is the waste materials
that were used as fill material at the subsites. In addition to
direct contact with waste at the surface, contaminants may be
transported to groundwater by means of infiltrating rainwater or
carried to adjacent surface water bodies by storm water runoff
or wind erosion. -Dust from the sites may be released to the
air.
Page 29
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6.1
CONTAMINANTS OF CONCERN
Based on the historical information relating to the ILCO
Superfund Site and sampling results from the RI, the primary
contaminant at the site is lead. Although lead is the primary
contaminant other inorganics were detected at the site in excess
of background conditions. The secondary contaminants of concern
include antimony, arsenic, cadmium, chromium, and nickel. These
contaminants were present in groundwater and soils from the
site.
6 . 2 EXPOSURE ASSESSMENT
Exposure assessment is the estimation of the frequency,
duration, and routes of exposure to humans. Whether a chemical
is actually a concern to human health and the environment
depends upon the likelihood of exposure, i.e. whether the
exposure pathway is complete. A complete exposure pathway (a
sequence of events leading to contact with a chemical) is
defined by the following four elements I
A source and mechanism of release from the source,
A transport medium (e.g., surface water, air) .and
mechanisms of migration through the medium,
The presence of a receptor at. the exposure point, and
A route of exposure (ingestion, inhalation, dermal
absorption) .
If all four elements are not present, the pathway is not
complete. Although the pathways differ at each subsite, the
principle potential pathways of exposure for all of the ILCO
subsites is direct contact with contaminated soils or sediments,
contaminated groundwater consumption, and inhalation of
contaminated dust. The current and potential future exposure
scenarios for each subsite are discussed within this section.
.
.
.
.
The residential scenario poses potential for the greatest
exposure. This scenario was used to evaluate the Connell
Property, Fleming's Patio,-J & L Fabricators, the Gulf Service
Station, and the..Acmar Church of God. Exposure was assumed to
occur for 365 days/yr for 30 years. Ingestion of water is .
assumed to be 2 liter/day for an adult and 1 liter/day for a
child. Ingestion of soil is assumed to be 0.1 grams/day for an
adult and 0.2 grams/day for a child. Inhalation of soil is
assumed 1.4. lhour for an adult and 0.33 mJ /hour for a
child.
The industrial/commercial scenario assumes a more limited
exposure during a working day, with reduced exposure to outside
soils. This scenario was used to evaluate the ILeO Parking
Lot. Exposure was assumed to occur for 365 days/yr for 20
years.
The recreational scenario results in increased exposure of
children to contaminants in areas that are not expected to
become residential. This scenario was used to evaluate the City
Page 30
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1-
of Leeds Landfill. Exposure was assumed to occur for 365
days/yr for 10 years.
parkina Lot
The Parking Lot site is located in an area zoned for heavy
industry. Surrounding properties include light industrial,
commercial, and residential uses.
The current exposure scenarios area
Direct contact with contaminated soil and inhalation of
dust containing contaminants by workers.
Ingestion of offsite contaminated groundwater and/or
fish by residents and the adult public from surface
water/sediment contact in Dry Creek.
The future exposure scenario is:
Ingestion of contaminated groundwater from local wells
used for potable water supply by residents.
Gulf Service Station
The Gulf Service Station is located in the center of Leeds, and
large numbers of individuals may be subjected to short-term
exposures to the ILca wastes~ The contaminated area is located
several hundred feet west of the station and has been covered
with a rock wool mixture. There is vegetation and other natural
cover on the site, which would reduce the effect of surface
runoff and the resultant erosion. The owners have lived in the
Lmmediate vicinity of the fill area. An elementary school is
located across the street.
The current exposure scenarios area
Direct contact with contaminated soil and inhalation of
contaminated dust by workers.
Direct exposure to contaminated soil by the public and
specifically public children trespassers because there
is & school nearby and there is no access restriction.
Contact with surface water and/or sediment or through
inge.tio~ of fish in Little Cahaba River by the public.
The future exposure scenarios area
Continued direct contact with contaminated soil by
residents.
Page 31
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Ingestion of contamin~ed groundwater from local wells
by residents.
J&L Fabricators
As a steel-fabricating company, J&L Fabricators represents an
industrial setting. However, homes are located adjacent to the
facility, and access to the site is not restricted. Therefore,
although exposures to workers occur onsite, the more sensitive
populations in the area are likely to be children in the
adjacent homes. Nearby residents could also be affected by wind
erosion and deposition that could result in contaminants in
soils at their residences. Exposures protective of the
residents are expected to be protective of the workers. The
back portion of the property was used as a fill area for ILCO
wastes. The surface of the fill area is reported to be covered
with sand and rock wool. There are no reports of topsoil cover,
such as grass or other vegetation, that would reduce erosion and
the resultant movement of contaminated soil offsite.
Current exposure scenarios:
Direct contact with contaminated soils and inhalation
of contaminated dust by workers and residents.
Ingestion of fish, surface water or sediment by.
residents. Children may play in the creek.
Future exposure scenarios:
Ingestion of groundwater from local wells by residents.
Flemina's Patio
Fleming's Patio is a restaurant and bar located east of the
Russell Heights subdivision of Leeds in a hilly, wooded area.
Both furnace slag and wastewater treatment sludge were deposited
at this location. Wastes from the ILCO operation were disposed
in two locations in this area. One area includes the
restaurant/tavern, which is bordered on two sides by fill. The
surface of this fill area is covered with a clay and. gravel
mixture. The back portion of the area has been roped off, and a
patchy grass cover has been established. The front portion is
used as a parking lot for the tavern. The second fill area is
located acros. the street from the tavern and appears to be used
as additional parking for Fleming's Patio. A portion of the
fill area containing slag material at the surface has been
covered with a cl5¥ and gravel mixture. The remainder of the
fill area has been covered with rock wool.
Current exposure scenarios:
Direct contact to contaminated soils and inhalation of
contamin~ted dust by workers and residents.
Page 32
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Future exposure scenarios:
Ingestion of groundwater :rom local wells by residents.
Connell ProDerty
There are two houses and a trailer on the Connell Property. One
of the houses was built in a low area adjacent to a swamp. It
is served by a septic tank. The area in back of the house was
filled using slag, and possibly sludge. The fill area has been
covered with soil and chert, and a grass cover has been
established. The western edge of the fill drops three feet to a
drainageway. The trailer house is located on top of the filled
area.
Current exposure scenarios I
Direct contact with contaminated soil.and inhalation of
contaminated dust by residents.
Future exposure scenarios I
Ingestion of groundwater from local wells by future
residents.
Ingestion by future residents of vegetables from
gardens grown onsite in contaminated soil.
City of Leeds MuniciDal Landfill
The landfill encompasses approximately eight acres. It is
unlined and is currently operated by the City of Leeds for the
disposal of tree limbs and demolition debris. The .surrounding
area is hilly and heavily wooded. From 1976 to 1980, furnace
slag, battery ca~ings, and wastewater treatment sludge were
disposed at the site. .
Current exposure scenarios I
Direct contact with contaminants in soil by workers.
Inhalation of contaminated dust by workers and offsite
resident8.
Future exposure 8cenarios (Future land use is considered to be
recreational. There are no present plans to develop this site.
However, a reasonable change in land use may be recreation, in
which increased public exposures may occur.) I
Direct contact with contaminated soil and inhalation of
contaminated dust.
Page 33
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Ingestion of groundwa.er from local wells by future
residents.
Acmar Church of God
The Acmar Church of God is located between Acmar Road and a deep
ravine approximately 1.9 acres in size. The ravine was created
by former coal strip-mining operations that occurred in the
area. The ILCO slag was placed on the steep embankment of the
ravine. The embankment drops approximately 40 feet to the base
of the ravine. The embankment is covered by kudzu vines.
Current exposure scenarios:
Direct contact with contaminated soil by the public.
Future exposure scenarios:
Direct contact with contaminants in surficial soil and
ingestion of groundwater from local wells by future
residents.
6.3
TOXICITY ASSESSMENT
To assess the possible toxicological effects from exposure,
human health criteria are derived from a review of health and
environmental standards and published toxicological studies.
For risk assessment purposes, individual pollutants are
separated into two categories of chemical toxicity:
noncarcinogenic and carcinogenic.
For noncarcinogenic chemicals, reference doses (RfDS) have been
developed by EPA for indicating the potential for adverse health
effects from exposure to these chemicals. RfDs, which are
expressed in units of mg/kg-day,.are estimates of lifetime daily
exposure levels for humans, including sensitive individuals that
will result in no adverse health effect. Estimated intakes of
chemicals from environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have bee~ applied (e.g., to account for the use of
animal data to predict effects on humans). These uncertainty
factors help ensure that the RfDs will not underestimate the
potential for adverse noncarcinogenic effects to occur. The
RfDs for oral ingestion and inhalation exposure to the
contaminants of cancern at the subsites are contained in Table
3.
Unlike noncarcinogens, carcinogens do not have threshold
exposure levels which will result in no adverse health effects.
Page 34
-------
TABU 3
'l"OUCIft' VALIJBS I P
-------
Rather CPFs have been develop~ by EPA's Carcinogenic Assessment
Group for estimating excess lifetime cancer risks associated
with exposure to potentially carcinogenic chemicals. CPFs,
which are expressed in units of (mg/kg-day)-l, are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-day, to
provide an upper-bound estimate of the excess lifetime cancer
risk associated with exposure at that intake level. The term
"upper bound- reflects the conservative estimate of the risks
calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the result of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation factors have been applied. The
CPFs for oral ingestion and inhalation exposure to the
contaminants of concern at the subsites are contained in Table
3.
6.4
RISK CHARACTERIZATION SUMMARY
Risk characterization involves combining the results of the
exposure and toxicity assessments to develop a numerical
estimate of the health risk associated with the contaminants
present at each of the ILCO subsites. The risk characterization
is based on identifying potential chemicals of concern and
developing exposure scenarios for each of the potential and
future exposure pathways.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in-a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a
given population may reasonably be exposed, the Haaard Index
(HI) can be generated. The HI provides a useful reference point
for gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific
notation (e.g., lxlO-1 or lE-6). An excess lifetime cancer
risk of lxlO-1 indicates that, as a plausible upper bound, an
individual haa a one in one million chance of developing cancer
as a result of site-related exposure to a carcinogen over a
'O-year lifetime under the specific exposure conditions at a
site.
For noncarcinogens, a hazard index in excess of one indicate a
potential adverse impact to human health should exposure to the
contaminant levels present at a specific subsite occur.
Exposure pathways which were evaluated and determined to pose a
Page 36
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risk greater than lxlO-6 indicate an unacceptable increased
possibility of contacting cancer as a result of exposure to the
waste present, compared to the probability if no exposure
occurred. The 1xlO.6 risk level is considered the goal for
remediation at Superfund sites [See 40 CFR
300.430(e)(2)(i)(A)(2)].
As shown in Table 4, the primary risk associated with the ILCO
Site is through ingestion and inhalation of contaminated soils.
All of the subsites have a hazard index of one or greater than
one for ingestion or inhalation of contaminated soils.
Ingestion of contaminated groundwater at several subsites
carries a hazard index of one or greater than one (ILCO Parking.
Lot, J & L Fabricators, Fleming's Patio, Connell Property, and
the Leeds Landfill). Particularly, the hazard index for
consumption of groundwater at the ILCO Parking Lot subsite is
two to five hundred times greater than the Hazard Index goal of
1. It should be noted, however, that this subsite will be
addressed through a separate action pursuant to RCRA. .
Contamination at the remaining subsites have been evaluated by
EPA pursuant to 40 CFR300.430. In addition, groundwater
modeling indicates that soil levels exceeding 300 mg/kg lead
could cause lead leaching into the groundwater resulting in
groundwater lead levels exceeding the lead action level of 15
ug/l.
The 1x10.6 risk level for soil ingestion or inhalation is
exceeded at the ILCO Parking Lot, J & L Fabricators, Fleming's
Patio, the Connell Property, Leeds Landfill and the Acmar Church
of God. The Parking Lot and Leeds Landfill are the only
subsites that exceed the 1x10.6 remediation goal for
groundwater.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
6~5
ENVIRONMENTAL RISKS
Data concerning ~vailable chemical, physical, and biological
parameters from each site as well as recent literature on each
of the contaminants of concern were reviewed. For example,
Ambient Water Quality Criteria (AWQC) for the protection of
freshwater aquatic life have been established under the U.S.
Clean Water Act for a number of chemicals. These criteria are
developed to be protective of 95 percent of all aquatic species,
and therefore protect fish, aquatic invertebrates, and plants.
As part of the National Status and Trends (NS & T) Program, the
National Oceanic and Atmospheric Administration (NOAA) has
compiled data on chemically analyzed sediments from coastal
marine and estuarine environments throughout the United States.
Page 37
-------
Expo.ur. Pathway
C1JRRBN'l' OSB
Inhalatlun ot duct
Hac... lifetime cancer ri.k
Hazard index - Adult
Ing..tion of .oil
!xce.. lif.time canc.r ri.k
Hazard index - Adult
Inge.tion of fi.b
Bxc... lifetime canc.r ri.k a
Haaard index - Adult
PtJ'1'tJU OS8
Ing..tioD of groundwat.r
!xc... lifetime cancer ri.k
Hazard index - Adult
Child
TABLB 4
S~ O. RISK
ILOO parking Lot
Ri.~
Major Contributor. to Ri.k
2B-05 . Ar..nic:, (lead)a
0.009 Lead
31:-05 . Ar..niC:, (lead)a
2 .. Lead, Antimony
HC (L.ad)a
0.8 Lead, cacllDiWII
3B-04 . Ar..riic, (l.ad)a
200 .. L.ad, Antimony, cadmium
500 .. L.ad, Antimony, cadmium
Qulf S."ic. station
CORRBft OS8
Inhalation of du.t
Hazard index - Adult Worur 0.001 LeaeS
CbileS Tre.pa...r 0.00003 L.ad
Inge8tion of .oil
Hazard index - Adult worker 0.3 Lead
ChileS tre.pa..er 0.3 Lead
Inge8tion of n.b
HazareS J.ndax - Adult 0.1 L.ad, ChromiWII, nickel
rtrrmUI on - Recr.ational
Inhalation of du8t
Hazard index - Adult 0.001 Lead
Child 0.001 Lead
Ing.8tion of .oil
HazareS J.ndax - Adult 0.5 Lead
ChileS 10 ..
Ing..tion of groundwatu
HaaareS J.ndax - Adult 0.2 Lead
CbU4 0.5 Lead
(a) . Lead conu~1oD to carcinogenio ri.k i. not inclueSed in the ..Umat.,
C&DCU ~ factor no1: available
HC . Hot calculated for lead 8Xp08UA
b . carcinogenio ri.iw an 8Xp&'8..ecS .. probability number. rai8ed to a negative
expon.nt (8) a. ci.8CribecS in text (page 37). Honcarcinoqenic ri.Jc8 are
ezpre..ecS in fraction or wllal. number. a. &aaareS IneSa (HI) valu... Th. HI
for 1.ad utiliz.. a d8riV8cS RfD (... text on pag. 35).
. . 8xc88cS8 Superfund r888cSiation goal of 1x10.1.
.. . Bqual to or exC88CS8 hazard J.ndax of on. (1).
OOR QL;\\..\ d
p OR\G\NAL
-------
TABLE 4 Continued
Ixpo.ur. Pathway
J ~ L Fabricator. -.Summary of Ri.k
Major Contributor8 to Ri8k
CtJRRBIft' us.
Inhalation of du.t
Bxc... lifetime canc.r ri.k HC
Hazard index - Adult R8.ld.nt. 0.003
Child R8.iant. 0.006
Inge.ton of .oil
&xc... lif.time canc.r ri.k
Child tA8p&..er '.-05 .
Hazard index - Child 'rr.8p&..er 1 ..
I"tJ'l'tJU us.
Inge.tion of qrounctwat.r
Bxc... lifetime cancer ri.k HC
Huard index - Adult 3 **
Child 6 **
IDCJ8.tion of 8011
bc... lifet188 GaDC8r ri8k
AdIIlt: R8.1d8nt ".-04 *
Hazard 1Dd8x - AdIIlt: R881d8nt 1 **
CbJ.1d ".1d8n1: 200 *.
CtJRRBN'l' USB
Ing..tion of .oil
Ixc... lif.ttm8 canc.r 'ri.k
Hazard index - Adult worker
Child tr..pa...r
FtJTtJRB USB
Inhalation of du.t
Ixc... lif.time cancer ri.k
Hazard index - Adult
Child'
Ing..tion of 80il
&xc... lif.time cancer ri.k
Hazard index - Adult
Child
lng..tion of q1"ouncJwat.r
&xc... lif.time canc.r ri.k
Hazard index - Adult
Child
Ingeetion of fl.b
bc... lifetime cancer ri.k
Hazard index - Adult
Ri8Je11
51-06 .
10 ..
10 ..
Ar..nic, (l.ad)a
Lead
L.ad
3B-05 .
0.02
0.03
Ar..nic a
L.ad
Lead
111-05 .
100 **
2,000 .*
Ar..nic a
L.ad
L.ad
HC
3
,
(L.ad) . a
L.ad
L.ad
.
.
HC
0.1
(L.ad) a
Lead
rl8llU.ng'. Patio
(Lead) a
Lead
Lead
..
Ar..nie, ( 1.ad) a
Lead, antimony, ar..nic
(Lead) a
Lead, antimony, cAdmium
Lead, antimony, cadmium
Ar.enic, ( 1.ad) a
Lead, antimony, cadmium
Lead, antimony, cacllllJ.um
(a) . Lead contribution to carcinogenic d.k l. not lnclud8d in the .etim&t.,
cancer pot.ncy factor DOt ayaLla!)l.
HC . Not calculated for l.ad expo.ure
b . carcinogenic rl.k8 an expr...ad a. proba!)ility number. rai.ad to a negative
expon.nt (B) a. d8.cr1b8d in text (page 37). Noncarcinog.nic ri.k8 are
expr...8d in fraCtion or whole number. a. Hazard Index (HI) valu... Th. HI
for l.ad utiliz.. a derived RfD (... text on page 35).
* . &xc8ad. SUpu'fund r88diatlon goal of 1810-'.
.* . Squal to or exc88d8 hazard index of on. (1).
COR Q\JA.t\"\'<
P QR\G\NAL
-------
TABLE 4 Continued
Bxpo.ure Pathway
Connell Property
Rh)(la
Major Contributor. to Ri8k
CURRBN'l' 05B
Inhalation of du.t
Exc... lif.time cancer ri.k
Hazard ind.x - Adult
Child
Inge.tion of .oil
&xce.. lif.tim8 cancer ri.k
Bazard index - Adult
Chl1d
rtrrt7R8 081
lnge.tion of groundwater
Bxc... lif.t~ canc.r ri.k
Hazard 1nc!ex - Adult
Chl1d
-
SWIIIDUy of Rhk
HC (l.ad)a
0.002 Lead
0.005 Lead
lB-05 . Ar..nic, (l.ad)a
20 .. Lead
600 .. Lead
HC (lead)a
0.5 Lead
1 .. Lead
:
City of L88d. Landfill
CtJ1UUI1ft 08. - Indu.trial
Inhalation of du.t
&xc... lif.ttm8 cancer rl.k 11-05 . Chroaaiwa, ar..nic, (lead)a
Hazard index - Adult WOrJc8J: 0.003 Lead
Child Tr.ep&8..r 0.0002 Led
lftq88tion of .011
&xce.. litet~ canc.r ri.k HC (lead)a
Huard 1nc!8X - Adult worJc8J: 0.08 Lead, antiJDony, nickel
Child tnapa..u 0.04 Lead, antiJDony, nickel
PU'rOU OSI - R8c:national
lnge.tioD of grouftc1watu
bc... U,fet~ cancer ri.k 21-04 . Ar..nie, (le&4)a
Baaa.rcl index - Adult 2 .. Lead, chroaaiwa, ar.enic, nickel
Chl1d 4 .. Lead, chroaaiwa, ar.enic, nickel
(a) . Lead contribution to carciDogenic ri8Jc i. not incluc18d in the ..ti.m&te,
cancer potency factO&' DOt a.a1lable
HC . Hot calculated for lead 8Xp08Ur8
b . see pap 1 of Table 4
. . &xC88d. SuperfwuS r~J.at1cm goal ot ula-'.
.. . lqual to 0&' ..=-1111. b&8ard 1nc!8X ot on. (1).
EOOR QUAU'T'f
" ORIGiNAL
-------
CURRBHT OSI - commercial
Inge.tion of 80il
Exce.. lifetime cancer ri8k
Hazard index - Adult
Child
PUTURB OSI - Re8idential
Inge.tion of 80il
lace.. lifetime cancer ri.k
Hazard index - Adult
Child
Ingestion of groundwater
Exce.. lifetime cancer ri.k
Hazard index - Adult
Child
Table 4 continued
Acmar Church of God
7!-07
0.03
0.4
71-06
0.2
7
*
..
Ar8enic, (lead)a
Lead
Lead
Ar.enic, (lead)a
Lead
Lead
(lead)a
Lead
LeacS
(a) . Lead contribution to carcinogenic ri.k i. not included in the e.timate,
cancer potency fact:or not: a"ai!&]:)le
HC . Hot: calculated for lead expo.ure
b . S- page 1 of T&]:)le "
. . Bxceed. Superfund r8D8cSiation goal of 1&10-'.
.* . lqual to or exceed. hazard index of one (1).
MC
0.3
0.7
P-OOR QUALiTY
'- ORIGiNAl
-------
Results of surface water and sediment analyses from each site
were primarily considered in the examination of. potential
impacts to aquatic communities, but were also considered in the
impacts on associated terrestrial animals. Groundwater data
were reviewed in cases where contaminated groundwater could
potentially mix with surface water. Data concerning soil
contamination were examined in instances where soi1 erosion or
direct exposure could potentially affect terrestrial organisms.
Contaminants that were detected at levels that exceeded
established criteria or guidance for a particular medium were
considered for further discussion in the site-specific risk
characterizations.
ILCO parkina Lot
There is a potential impact on the aquatic communities of the
northern portion of the unnamed tributary and Dry Creek through
contamination by groundwater movement, surface water runoff, and
possible soil erosion from the western edge of the Parkinq Lot.
Surface water in Dry Creek and the unnamed tributary is a source
of drinking water for terrestrial animals and birds living in
the area.
Acutely toxic concentrations of lead and cadmium ware higher in
the segment of the unnamed tributary adjacent to the Parking Lot
than in the segment upstream at the Main Facility. At the
downstream sampling location, SP-1, in Dry Creek, the
concentration of cadmium in surface water was below the AWQC.
The lead concentration also decreased at this station, but
remained above criteria. Aquatic communities would be adversely
affected by lead and cadmium levels above the AWQC. Wildlife
would be more likely to frequent Dry Creek, which is wider and
deeper than the unnamed tributary. The unnamed tributary also
has very limited habitat. However, the highest concentration of
lead detected in the surface water (1,200 ug/l at SP-2) is below
the range of No Observable Effect Levels (NOELS) observed for
birds and mammals (10 to 50 mg/l). Literature regarding
toxicity of lead to amphibians indicated that the contaminants
in the creeks would affect them.
In the unnamed tributary, the highest concentrations of cadmium
and chromium in ~he sediment, 62 mg/kg and 110 mg/kg,
respectively, exceeded the known dietary concentrations that
produce adverse effects in mammals .and birds. The unnamed
tributary will be addressed in au 12.
Gulf Service Station
The Gulf Service Station is located in downtown Leeds adjacent
to the Little Cahaba River. Terrestrial habitat is limited to a
variety of grasses and shrubs growing along the fill area and
the Little Cahaba floodplain. Contaminated surface soil enters
the river through erosion and surface water runoff. This
Page 42
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migration presents a potential health risk to aquatic organisms
in the Little Cahaba River. This river is known to contain
green sunfish, long-eared sunfish, bluegill, smallmouth bass,
largemouth bass, and northern hogsuckers. The river is also
expected to provide habitat for numerous other fish,
invertebrates, reptiles, birds, and aquatic mammals.
Terrestrial animals are not expected to have frequent direct
contact with this urban site because of human activity and lack
of abundant food and cover.
Three sediment samples collected adjacent to or downstream of
the site exceeded the Regional Aquatic Species Protection Level
for lead (SO mg/kg) while the upstream samples did not. Two of
the lead sediment samples exceeded the Effects Range Median
(ER-M) value of 110 ppm. The ER-M for lead indicates the
concentration above which adverse effects are frequently or
always observed. Above this concentration, sediment lead levels
could potentially affect aquatic life, primarily bottom-dwelling
fish and benthic invertebrates.
J & L Fabricators
Impact on aquatic communities (fish and invertebrates) in Dry
Creek could potentially occur with surface runoff, soil erosion,
and air and groundwater transport of contaminants from the
site. .
The maximum concentration of lead in surface water was 7 ug/l.
It exceeds the chronicAWQC of 3.2 ug/l for lead. Fish and
aquatic invertebrates exposed to lead concentrations greater
than 3.2ug/l will be adversely affected. On the basis of the
surface water data, the J & L Fabricators subsite is continuing
to contribute unacceptable levels of lead that will negatively
affect the aquatic biota downstream due to surface water runoff
and erosion of exposed fill material.
Sediment samples were found to contain detectable levels of
lead, antimony, arsenic, cadmium, chromium, and nickel. During
dry periods, terrestrial animals such as raccoons could be
exposed to sediments from Dry Creek. Chromium and lead in the
concentrations detected (58 and 100 mg/kg, respectively) would
be of concern if. these sediments were ingested by wildlife.
Adverse effects of chromium and lead in animals occur at dietary
levels as low as' 10 mg/kg and SO mg/kg, respectively. Chromium
and lead level. can potentially affect benthic invertebrates and
bot~on-dwelliD9 fish in direct contact with sediments, as well
as other aquatic animals exposed to desorbed metals.
Flem~na's Patio
Exposure of wildlife to the fill areas is possible, but the lack
of cover and food sources may reduce the frequency of direct
contact with contaminated soil.
Page 43
-------
Average lead and chromium con~ntrations for the drainageways
were 231 and 31.8 ug/l, respectively, Direct ingestion of these
concentrations of metals would be toxic to wildlife. Water flow
is intermittent and would not be suitable for aquatic community
development. Exposure of these sediments to terrestrial animals
is possible because of the habitat provided by the large
forested areas adjacent to the site. The potential for direct
contac.t with the sediment is greatest with animals such as the
raccoon, which would attempt to feed in the drainageways during
periods of flow.
Connell PrODertv
Wildlife inhabiting these woodlands could potentially be
affected by surface water runoff or groundwater transport of
contaminants from the Connell Property. Aquatic life is not
expected to occur in these intermittent drainage ways.
Groundwater contamination of surface water is not expected to
adversely affect aquatic or terrestrial life.
The wooded area adjacent to the Connell Property is expected to
contain a diverse wildlife population. Some animals may be'
attracted to the grass habitat on the property. Direct contact
with contaminated soil on this site may be minimal.
Leeds Landfill
The landfill area provides relatively poor quality habitat (food
and cover) for terrestrial species, and as a result the amount
of wildlife activity at the landfill is probably quite limited.
Because of the intermittent nature of the surface water
resource, significant populations of aquatic life are not
expected to be present. As a result, exposure to aquatic life
through direct contact with contaminated surface water or
sediment is considered to be insignificant.
Acmar Church of God
The steep topography around the church is char~cterized by dense
woodlands and a small intermittent creek at the base of a
ravine. The area immediately southeast of the church is
composed of a dense hardwood-conifer forest and natural shrub
vegetation, whic~ provides excellent habitat for a variety of
terrestrial species.
Wildlife may occasionally move from the protected woodland to
the relatively open area formed by the church grounds. However,
because of the l~ted vegetative growth, the fill area, which
is overgrown with kudzu vines, provides relately poor-quality
habitat (food and cover) for terrestrial species.
By addressing the human health concerns at the ILca Site the
environmental concerns will be satisfied.
Page 44
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Actual or threatened releases of haEardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
6.6
MINTEOA2 MODELING RESULTS
In order to evaluate the potential for trace metals at the ILCO
subsites to migrate with groundwater through and/or into the
aquifers, MINTEQA2, an equilibrium chemical speciation model for
dilute aqueous systems, was used. This model examined the lead
levels and the pH found in the groundwater. An adsorption model
based on research data for a Wisconsin sand was used.
Adsorption is when gas, vapor or, in this case, dissolved matter
(lead) attaches itself to the surface of a solid. The shales
and limestone at the ILCO subsites would be expected to adsorb
even more than the sands modeled. In other words, the
adsorption data presented should be conservative because the
final equilibrium adsorption expected at the ILCO subsites
should be even stronger. .
Besides the Main Facility and Parking Lot the MINTEQA2 model was
applied using data from Fleming's Patio. The model was not used
for the other subsites because the filtered trace metal values
were at levels too low for use in the model. Filtered sampling
results were used for the MINTEQA2 model to show whether .
precipitation or adsorption are taking place. However, EPA only
recognizes unfiltered samples for the determination of whether
contaminants exist in the groundwater.
The model showed that once the pH rises past the pH 4-5 range or
become8 les8 acidic, adsorption is by far the main factor in
limiting the solubility of lead. That is because that, due to
ad2crption, the lead would be less likely to be found in the
Wat"Hr once the pH rises past the pH of 4-5 range.' Lead at the
IL~O subsites appears to be even less mobile than predicted once
the source has been removed. These observations indicate that,
at subsites other than the Parking Lot where lead contamination
levels are relatively low but pH values are higher, the
remaining dissolved concentrations of lead should be very low as
equilibrium between the soil and water particles is approached.
At these subsites BPA concludes that the lead would have a very
strong tendency to adhere to the rock formation surface and
therefore not dissolve into the groundwater.
6.7
REMEDIATION GOALS
Based on the results of the baseline risk assessment, the ILCO
Site presents a threat primarily due to the presence of lead.
In addition arsenic, cadmium, chromium, antimony, copper and
nickel may pose an added threat. Groundwater, soil, surface
water, sediment and air remediation goals have been developed
Page 45
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based on a site specific risk or, when available, existinq
federally regulated criteria. Remediation qoals are presented
-on Table 5.
Althouqh inqestion of contaminated qroundwater is considered a
complete exposure pathway, health based remediation qoals were
not developed because the contaminants of concern have Maximum
Concentration Limits (MCLs) or proposed MCLs which are
Applicable, Relevant and Appropriate Requirements (ARARs) and,
therefore, these limits will be used as remediation qoals, with
the exception of lead.
The current MCL of 0.05 mq/l for lead was promulgated as an
interim drinking water regulation in 1975. Since that time,
considerable human health information has been produced that
indicates that this level may not be protective as a final
cleanup level for all potential receptors. In 1988, EPA
proposed a lead MCL of 0.005 mq/l. A treatment technology final
rule for lead and copper was published on June 7, 1991 (5~ FR
No. 110). This rule provides an MCLG and an action level for
both metals respectively, but no MCL. The rule becomes
effective in November 1992, at which time the current MCL for
lead will no longer exist. The action level measured in the
90th percentile at the tap is 15 ug/l (or 0.015 mg/l) for lead
and 1,300 ug/l for copper. In consideration of this
information, the remediation level for groundwater at
is set at a level of 0.015 mg/l. Appendix B contains
memorandum that supports the 0.015 mg/l as protective
health and the environment, thus recalculation during
Risk Assessment was not necessary.
this site
a
of human
the ILCO
The presence of groundwater contamination at several of the
subsites indicates that leaching of contaminants from the
contaminated soil has occurred. Due to the contaminant
leaching, soil remediation goals were developed to be protective
of human health through all potential pathways as well as for
protection of qroundwater. Soil remediation goals for lead,
antimony, arsenic and chromium were based on protection of human
health through a direct pathway. In addition, the lead soil
remediation goal of 300 mg/kg was calculated to ensure leachable
lead levels from the soil will not result in groundwater
exceeding the 0.915 mg/l remediation goal.
Remediation goals for surface water and air are based on
existing, federally regulated criteria. The Ambient Water
Quality Criteria (ANQC) established by the CWA are ARABs and
considered acceptable for remediating the ILCO site. Although
air monitoring d~ng RI did not indicate elevated lead levels
in the air, it is expected that during remediation disturbance
of the soil will produce contaminated dust particles in the
air. Therefore, air lead levels will be monitored during site
remediation using National Ambiant Air Quality Standards
(NAAQS) .
Page 46
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Table 5
Remediation Goals
Medium Parameter Goal Source Goal Level
Groundwater Lead EP A guidance criteriona 15 ~g/1
Arsenic MCL 50 ~g..1
Cadmium MCL 10 ~g/1
Chromium MCL 50 ~g/1
Antimony Proposed MCL 5~g/1
Copper Proposed MCL 1.300 ~g/1
Nickel Proposed MCL 100 IIS'I
Soil Lead Soil remediation goal Cor protection 300 mgfkg
of groundwater (concentration below
which leaching will not result in
groundwater exceeding 15 lIg/l
le~d)l'
Antimony Basc:d on RfD value applied to 32 mg/1cg
resiuential scenario
Arsenic I x 10.5 risk applied to residential 10 mg/1cg
scenario
Chromium (hexavalent) Based on RfD value applied to 1. 750 mgfkg
recreational exposure
Surface water Lead AWQC 3.2 ~gll
Antimony AWQC 1.600 ~g/1
Arsenic: (pentavalent) AWQC ~ 1Ig/1
. Arsenic (trivalent) AWQC 190 1Ig/1
Cadmium AWQC , 1.1 ~ g/1
Chromium (hexavalent) AWQC II ~g/1
Chromium (trivalent) AWQC 210 1I!V1
Copper AWQC 12 ~g/1
Nickel AWQC 160 ~g/1
Sediment Lead Regional Aqu,aic Species Protection
Level SO mgfkg
Air Lead ~AAQS 1. 5 ~g/m3
-See EPA memorandum dated June 21. 1990. in Appendix G.
"see EPA memonndum dated December 21. 1990. in Appcndi.'( G.
MCL - Maximum Contaminant Level
AWQC - Ambient Water Quality CritcriJ (Chronic) Cor the protection oC aquatic: liCe
NMQS - National Primary and ~'Ondary Air Quality Standards
OSWER - Office or Solid Waste and Emergency Response
dbl109~9-'1
P-OOR QU/\U ff
'.OR\G\NAL
-------
The EPA does not have standards or established guideline~ or
criteria for any hazardous substance in sediment. Sediment
remediation goals for lead at the ILCO site were developed by
using a published literature review to determine a remediation
goal that is protective of aquatic species and below human
health concern levels. Based on this literature review
concerning sediment clean-up goals for lead in similar
environmental conditions, a value of 50 mg/kg was selected for
the ILca ~ite (see Appendix C).
The determination for a no action alternative comes directly
from the Risk Assessment. Once the Risk Assessment is complete
and a No Action determination is made, the Feasibility Study
(FS) does not then evaluate other remediation alternatives for
that area (or Subsite) that will require No Action.
7.0
DBSCRIPTIONS OP ALTERNATIVES
The Feasibility Study (FS) Report presents the results of .a
detailed analysis conducted on five potential remedial action
alternatives for addressing the source of contamination and six
potential remedial action alternatives for addressing
groundwater contamination at the ILCO Site. This section of the
ROD presents a summary of each of the alternatives. The
estimated cost of each alternative is different for every
subsite. The individual subsite estimated costs are more
specifically presented in Table 7 on page 63. These cost
estimates are order-of-magnitude estimates with an intended
accuracy range of +50/-30 percent.
Based on information obtained during the remedial investigation,
and the analysis of all remedial alternatives, EPA has concluded
that the selected remedy may be able to achieve the remediation
goal. Groundwater contamination may be especially persistent in
the ~ediate vicinity of the contaminants' source. The ability
to achieve cleanup goals at all points throughout the area of
attainment, or plume, cannot be determined until the extraction
system has been implemented, modi~ied as necessary, and plume
response monitored over time.
Treatability studies have indicated that the selected treatment
methods will treat the waste materials to levels below Land
Disposal Restriction (LDR) levels for lead. If some of the
waste material or groundwater treatment sludge cannot be treated
to below LDR levels, Superfund will meet treatability variance
levels for the contaminated 80il and debris. The treatability
variance level for lead is the 99-99.9 percent reduction range.
Page 48
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SOURCE CONTROL / SC \ ALTERNATIVES
Soil and Sediment
Alternative SC-l: &0 Action: The Superfund program requires the No Action
Alternative be considered at every site [Section-300.430 (e) of the NCPJ. This
alternative was evaluated to serve as a baseline for comparison with other
cleanup alternatives under consideration. Under this option, no treatment or
containment of disposal areas would occur and no further effort would be made to
restrict potential exposure to contaminants. only groundwater monitoring would
be conducted
. REMEDIAL Parking Gulf J&L Flemings Connell Leeds Acmar
ALTERNATIVES Lot Station Fabric. Patio Property Landf ill Church
SC-l $ Killion
Total Capital -0- -0- -0- -0- -0- -0- -0-
Total 0&11 0.033 0.010 0.015 0.026 0.013 0.008 0.005
Present Worth
Total Est.Cost 0.033 0.010 0.015 0.026 0.013 0.008 0.005
All of the remaining alternatives would require institutional controls consisting'
ot access and use restrictions to protect the integrity ot the cap system, and
long-term groundwater monitoring would apply. Also, temporary relocation of
residents may be necessary at sUbsites during the remedial action activities.
Alternative SC-2: Multilayer Cap: Thi8 alternative provide8.for construction
of a multilayer compacted clay and geomembrane cap that would cover areas that
have soil contaminated with lead concentrations exceeding 300 mg/kg. A
multilayer cap would reduce the infiltration of water through the fill area to
the groundwater, reduce surface contaminant runoft to the adjacent surface water
body, and reduce the potential for direct human contact to contaminated surface
soil..
The cap would be con~tructed to 8ati8fy RCRA's minimum technology guidance
requirements and would consist of a 2-foot thick clay layer with a hydraulic
conductivity lese than lxlO-7 cm/s, a 40-mi1 flexible membrane liner, a 1-foot
drainage layer, &ad a 2-foot topsoil-fill cover layer. The final cover would be
graded to provide an approximate 3 to 5 percent slope and surtace vegetation
would be applied to the topsoil. Brosion and surface water control. would be
incorporated into the .esign. Cap maintenance would consist of mowing, regular
inspection., and cap repair it needed. Institutional controls consisting of
access and use restrictions to protect the integrity of the cap system, and
long-term groundwater monitoring would apply. Warning signs would be installed
around the perimeter of the contaminated areas. Existing monitor welle would be
sampled annually and analyzed for the primary metals aSBociated with
Page 49
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Itomotive batteries, and deed restrictions would be instituted for a minimum of
I years. Operation and Maintenance (O&H) consisting of groundwater monitoring
Id cap maintenance would be conducted for a minimum of 30 years. As required by
Ie superfund Amendments and Reauthorization Act of 1986 (SARA) to the
Imprehensive Environmental Response Compensation Liability Act of 1980 (CERCLA),
5-year review of the site would be conducted. After the design of the
Iltilayer cap i8 complete it would take 150 to 300 days to construct the cap
lpending on the subsite.
REMEDIAL Parking Gulf J&L Flemings Connell Leeds Acmar
ALTERNATIVES Lot Station Fabric. Patio Property Landfill Church
.C-2 $ Million
Total Capital 3.604 0.258 0.842 1.372 0.624 1.485 0.315
Total O&H 0.081 0.052 0.039 0.049 0.035 0.030 0.027
Present Worth
Total Est. Cost 3.69 0.31 0.88 1.42 0.66 1.52 0.34
.ternative SC-31 BzcavatioD and Offsite RCRA Landfill Disposal: Alternative
:-3 includes excavating 80il with lead concentration8 exceeding 300 mg!kg and or
IIDOval of contaminated sediments (exceeding 50 mg!kg lead) by hydraulic
~edging, sediment dewatering, and loading and tran8porting contaminated soils
Ld 8ediments to an offsite RCRA permitted (Subtitle C) landfill. The excavated
Lterial would be considered a characteristic hazardous wa8te and would have to
I manifested to the RCRA di8posal facility. The RCRA disposal facility would
Lve to meet all land disposal restrictions prior to dispo8al.
Lring excavation and r8mOval activities, dust will be controlled with a water
Iray mist twice a day, and more often when wind speeds exceed 15 mph, to insure
tat contaminated dust will not migrate offsite. Downwind air monitoring for
tad and other metals will be conducted during and after remediation. samples
~om at least one downwind lead sampler will be collected daily during
tmediation. Air monitoring will continue for at least two weeks after the
~ediation is complete on . less frequent basia.
Ice the contaminated material had been removed, the affected areas would be
Ickfilled with clean fill to the original elevations, graded, and vegetated.
:ter the design of the excavation operation 18 complete it would take 120 to 300
IYs to Lmplement this remedy depending on the subsite. Temporary relocation of
t8idents may be necessary.
REMEDIAL parkinq Gulf J&L Plemings Connell Leeds Acmar
ALTERNATIVBS Lot Station Pabric. Patio Property Landfill Church
IC-3 $ Million
Total Capital 28.23 2.25 6.91 11.93 5.49 0.82 3.94
Total O&M -0- -0- -0- -0- -0- -0- -0-
Pre8ent Worth
Total Est. Cost 28.83 2.25 6.91 11.93 5.49 0.82 3.94
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1---
Alternative SC-4: bcavatioD, Onsite Treatment, and Replacement Onsite: This
alternative consists of excavating soil/sediment with lead concentrations
exceeding 300 mg/kg and 50 mg/kg, respectively, treating the contaminated
material onsite through solidification and stabilization, and replacing the
treated soil back into the excavation in compliance with RCRA requirements. A
portable hydraulic dredge would remove the sediment. Sediment would be dewatered
and transported prior to treatment with the soil.
During excavation and removal activities, dust will be controlled with a water
spray mist twice a day, and more often when wind speeds exceed 15 mph, to insure
that contaminated dust will not migrate offsite. Downwind air monitoring for
lead and other metals will be conducted during and after remediation. samples
from at least one downwind lead sampler will be collected daily during
remediation. Air monitoring will continue for at least two weeks after the
remediation is complete on a less frequent basis.
A RCRA Subtitle D cap would be placed on the treated material and would meet the
state requirements for closure. Sediment removal would only be done at the Gulf
Service Station. After the design of the solidification operation is complete it
would take 180 to 360 days to implement this remedy depending on the sUb.ite.
This alternative will comply with the Land Disposal Restrictions (LDRs) through a
Treatability Variance for the contaminated soil and debris. A Treatability
Variance for Solidification/Stabilization may be necessary. Temporary relocation
of residents may be necessary. O&H consisting of groundwater monitoring,
inspections and maintenance would be conducted for a minimum of 30 years. As
required by SARA, a 5-year review would be conducted.
REMEDIAL Parking Gulf J&L !'lamings Connell Leeds Acmar
ALTBRNATIVBS Lot Station Fabric. Patio Property Landfill church
SC-4 $ Million
Total Capital 12.65 1.22 2.89 4.63 2.50 0.65 1.85
Total O&H 0.13 0.04 0.05 0.07 0.05 0.03 0.03
Present Worth
Total Bst. Cost 12.78 1.26 2.94 4.70 2.55 0.68 1.88
Alternative SC-5a bc&vatioD, CeDt.ral Location '!'r8&~, aDd It8plac Itt
On8itea This alternative is the same as Alternative SC-4 except that the
excavated material wi:ll be tak8n to a centrally located treatment area (the ILCO
parking Lot). Tba ezcavated material would be considered a characteristic
hazardous waste ADd would have to be manifested as a hazardous waste until it is
treated and rend8l:8d non-hazardous. It would be treated at the centrally located
treatment area aDd then either placed in the parking Lot or returned to its
original location. If-the treated waste 18 placed in the ILOO Parking Lot then
the subsite excavation from which the wasts originated would not need 5 year
review, Subtitle D closure, or deed restrictions. Inste.d, these subsite
excavations would be backfilled with clean fill and revegetated. If the solid
waste cannot be placed in the Parking Lot due to space limitations the wa8te
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would be returned to its original loc tion or possibly placed in the Leeds
Landfill. A RCRA Subtitle D cap woulc Je placed on the treated material and
would meet the state requirements for closure. After the design of the
solidification operation is complete it will take 150 to 240 days to implement
this remedy depending on the subsite. Temporary relocation of residents may be
necessary. Air monitoring would be conducted the same way as described in
Alternative SC-4. O&K, consisting of groundwater monitoring and maintenance
would be conducted for a minimum of 30 years. As required by SARA, as-year
review would be conducted.
REMEDIAL Parking Gulf J&L Flemings Connell Leeds Acmar
ALTERNATIVES Lot Station Fabric. Patio Property Landfill Church
SC-5 S Hillion
Total Capital 12.65 1.19 3.20 5.15 2.66 0.51 1.95
Total O&K 0.13 0.04 0.05 0.07 0.05 0.04 0.03
Present Worth
Total Est. COst 12.78 1.23 3.25 5.22 2.71 0.54 1.98
GROURDWATBR OORTROL 100\ ALTBRRA'l'IVBS
Alternative 00-11 Bo ActiODI Thi. alternative was evaluated to serve as a
baseline for comParison with the other alternatives under consideration. Onder
this option, no active measure. would be taken to address or contain the
groundwater contamination at the site. Groundwater use would not be restricted.
Only monitoring would be conducted.
REMEDIAL Parking Gulf J&L Plemings COnnell Leeds AclDar
ALTERNATIVES Lot Station Pabric. Patio Property Landfill Church
00-1 $ Million
Total Capital ** -0- -0- -0- -0- -0- -0-
Total O&K ** 0.01 0.015 0.026 0.013 0.008 0.005
Present Worth
Total Est. COst ** 0.010 O.OlS 0.026 0.013 0.008 0.005
I
** Groundwater remediation at the ILOO Parking Lot i. being handled under RCRA
and will be addre..ec1 in OU '2. Therefore, no evaluation of groundwater
alternative. was done.
Alternative 00-21 .atura! AttaDuatiOD. Thi. alternative i. generally the same
as the No Action Alternative in that no active mea.ure. would be taken to address
or contain the groundwater at the .ite. However, in.titutional control. would be
implemented to restrict usage of groundwater until remediation goals are attained
through the attenuation proce... Natural Attenuation.mean. that any
contamination that is.currently found in groundwater would lessen with time
naturally without active measure. being taken. Natural Attenuation relies on the
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groundwater'S natural ability to reduce contaminant concentration through a
physical process until remediation goals are met. Based on modeli~g and
hydrogeologic data EPA has found that lead in the groundwater will adhere to clay
particles found in the aquifer. When this happens the lead concentration in the
groundwater is reduced. Based on the pH of the aquifer EPA has determined that
this adsorbtion proce.. will effectively remove contaminants from the groundwater
over a period of time. According to the preamble of the National Contingency
Plan (NCP), natural attenuation may be considered only when groundwater
contaminants are expected to be reduced to the remediation goals determined to be
protective of human health and sensitive ecological environments in a reasonable
time frame. Following the attainment of the groundwater remediation goals,
groundwater would continue to be monitored for a minimum of 30 years to verify
the effectiveness of the remedy.
REMEDIAL Parking Gulf J&L Flemings Connell Leed. Acmar
ALTERNATIVES Lot Station Fabric. Patio Property Landfill Church
GC-2 $ Killion
Total Capital ** NA -0- -0- -0- -0- NA
Total O&K ** NA 0.015 0.026 0.013 0.008 RA
Present Worth
Total Est. Cost ** NA 0.015 0.026 0.013 0.008 NA
**
Groundwater remediation at the ILCO Parking Lot is being handled under RCRA
and will be addressed in OU 12. Therefore, no evaluation of groundwater
alternative. was done.
NA
Because no lead or other contaminants of concern were found above the
remediation goal at the Gulf Station or the Acmar Church of God, no
groundwater alternative. were evaluated for these subsites.
Alternative GC-31 MUltilayer Cap aDd Slurry Walll Thi. alternative would have
to be implemented in conjunction with SC-2. GC-3 include. the installation of a
slurry wall around the contaminated area to contain contaminated groundwater. A
cap over the area minimize. the infiltration of rainfall within the inner
boundary of the slurry wall. The .lurry wall is con.tructed by excavating a
narrow vertical trench, typically 2 to. 6 feet wide, and back filling the trench
with a thin mixture Qf liquid, that contain. water, and other substance. such as
cement or clay. The average depth of the wall would be 30 feet. Thi. remedy
would take 240 to 390 day. to con.truct depending on the subsite. O&K consisting
of groundwater monitoring and maintenance of the cap would be conducted for a
minimum of 30 ~.. A8 required by SARA a 5-year review would be conducted.
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REMED IAL Parking Gulf J&L Flemings Connell Leeds Acmar
ALTERNATIVES Lot Station Fabric. Patio Property Landfill Church
GC-3 $ Million
Total capital ** NA 1.46 3.38 1.22 2.93 NA
Total O&H ** NA 0.04 0.05 0.04 0.03 NA
Present Worth
-- -.---.- ..-----
Total Est. Cost ** NA 1.50 3.43 1.26 2.96 NA
"'*
Groundwater remediation at the ILCO Parking Lot is being handled under RCRA
and will be addressed in 00 '2. Therefore, no evaluation of groundwater
alternative. was done.
~A
Becau8e no lead or other contaminants of concern were found above the
remediation goal at the Gulf Station or the Acmar Church of God, no
groundwater alternatives were evaluated for these subsite..
~lternative GC-4a Bztraction &ad Di8Cbarge to r.LCOa Thi8 alternative consists
of pumping contaminated groundwater that exceed8 15 ug/L from extraction wells,
collecting and storing the contaminated groundwater in a temporary etorage tank,
and transporting the contaminated groundwater in vacuum truck. to the ILCO Main
racility plant for treatment in the RCRA-corrective-Action groundwater treatment
system which is currently in compliance with RCRA. It would take 60 days to
construct this remedy. Extraction would take anywhere from 3 to 20 years
depending on the subeite. O&H con.isting of groundwater monitoring would be
conducted for a minimum of 30 years. Extraction monitoring and transportation of
groundwater to ILCO would be conducted a. long as the groundwater level were
above the 15 ug/l action level for lead. A8 required by SARA a 5-year review
would be conducted.
RBHBDIAL Parking Gulf J&L Plemings connell Leed. Acmar
ALTERNATIVES Lot Station Pabric. Patio Property Landfill Church
GC-4 $ Million
Total Capital ** NA 2.42 4.80 3.09 8.75 NA
Total O&H ** NA 0.17 0.16 0.16 0.16 NA
Present Worth
Total B.t. CO.t .**. NA 2.59 4.96 3.25 8.91 NA
**
Groundwater r.-diation at the ILCO Parking Lot i8 being handled under RCRA
and will be addre..ed in 00 '2. Therefore, no evaluation of groundwater
alternativee wae done.
NA
Becau.e no lead or - other contaminant. of concern were found above the
remediation goal at the Gulf Station or the Acmar Church of God, no
groundwater alternative. were evaluated for the.e sub.ite..
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Alternative GC-5: Bztraction, Chemical/PbJbical Treatment, and Discharge to
ILCO: Contaminated groundwater would be pumped from extraction wells, collected
and stored in a temporary storage tank, treated onsite with a mobile
chemical/physical treatment unit, and then transported to the ILCO Main
Facility's permitted (RPDBS) point-80urce-discharge-surface outfall in vacuum
trucks. There would also be groundwater monitoring ongoing. Sludges generated
from the pump and treat system will be tested for determination as to whether
they are RCRA hazardous waste. If 80, these sludges will be solidified in order
to meet the Land Disposal Restrictions treatability variance levels and to be
rendered non-hazardous before disposal in a Subtitle D unit. Construction of
this alternative would take approximately 90 days. Extraction would take
anywhere from 3 to 20 year. depending on the subsite. O&H consisting of
groundwater monitoring would be conducted for a minimum of 30 years. Extraction
and treatment monitoring and transportation of the groundwater to ILCO would
continue as long as the groundwater contained levels of lead above the 15 ug/l
action level for lead. As required by SARA a 5-year review would be conducted.
RBHBDIAL Parking Gulf J&L Flemings Connell Leeci. Acmar
ALTERNATIVES Lot Station Fabric. Patio Property Landfill Church
GC-5 $ Killion
Total Capital ** NA 2.43 4.82 3.11 8.70 NA
Total O&H ** NA 0.54 0.54 0.53 0.53 NA
Present Worth
Total Bst. Co.t ** NA 2.97 5.36 3.64 9.23 NA
**
Groundwater remediation at the ILCO Parking Lot is being handled under RCRA
and will be addres.ed in OU '2. Therefore, no evaluation of groundwater
alternative. was done.
Because no lead or other contaminant. of concern were found above the
remediation 90al at the Gulf Station or the Acmar Church of God, no
groundwater alternative. were evaluated for the.e subsite..
NA
Alternative GC-6a Bxtraction, l'!ha8fcal/Phytlical 'l'reatmen1:, aDd Di8Charge to the
Surface OUtfalla Thi. alternative i. the same as the preceding alternative,
except that the previous alternative include. discharge at the ILCO Main Facility
and this alternative include. .urface outfall di.charge on.ite. Under this
alternative, contaminated groundwater would be pumpec:I from extraction wells,
collected, and stored in a temporary storage tank, treated on.ite with a
chemical/pbysical treatment unit, and then discharged onsite into an adjacent
creek. Surface water di.charge mu.t comply with NPDBS requirements. It is
e.timated the CODStruction of this alternative would take 120 day.. Bxtraction
would take anywbue frcaa 3 to 20 year. depending on the sub.ite. O&H, consisting
of groundwater JDODitor1-ng would be conducted for a minimum of 30 years.
Extraction and treatment monitoring would continue as long a. groundwater
contained level. of lead exceeding the 15 ug/l action level for lead. A8
required by SARA, a 5-year review would be conducted.
Page 55
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REMEDIAL Parking Gulf J&L Flemings Connell Leeds Acmar
ALTERNATIVES Lot Station Fabric. Patio Property Landfill Church
GC-6 $ Million
Total capital ** NA 0.55 0.55 0.55 0.55 NA
Total O&H ** NA 0.06 0.09 0.06 0.22 NA
Present Worth
Total Est. Cost ** NA 0.61 0.64 0.61 0.77 NA
**
Groundwater remediation at the ILOO Parking Lot is being handled under RCRA
and will be addressed in OU '2. Therefore, no evaluation of groundwater
alternatives was done.
NA
Because no lead or other contaminant. of concern were found above the
remediation goal at the Gulf Station or the Acmar Church of God, no
groundwater alternative. were evaluated for these sub.ites.
8.0
StJIIImRY oW' TB8 OOMPARA'UVII ADLYSIS oW' AL'1'DIIA~IVBS
This section of the ROD provide. the basi. for determining which alternative
provide. the best balance with respect to the .tatutory balancing criteria
Section 121 of CERCLA and Section 300.430 of the NCP. The SPA has established
nine criteria that are used to evaluate potentially fea.ible alternatives for
remediating Superfund .ite. (... Table 6). Bach alternative i. reviewed to
determine if that alternative meet. each of the nine criteria. The following
analysis i. a summary of the evaluation of alternative. for remediating the
Interstate Lead COmpany Superfund Site under each of the criteria. The
determination for a no action alternative come. directly from the Ri.k
A.se..ment. Once the Ri.k AB.e..ment i. complete and a No Action determination
i. made, t~e Fea.ibility Study (FS) doee not then evaluate other remediation
alternative. for that area (or Sub.ite) that will require No Action. The No
Action alternative i. propo.ed for groundwater at the Acmar Church of God and the
Gulf Station becau.e no groundwater contamination was found there.
The NCP categorize. the nine criteria into thr.. group.a (1) Threshold Criteria
- overall protection of human health and the environment and compliance with
ARAR. (or invoking a waiver) are thre.hold criteria that mu.t be .ati.fied in
order for an alternative to be eligible for .election, (2) Primary Balancina
Criteria - long-term.effectivene.. and permanence, reduction of toxicity,
mobility, or volume, .hort-term effectivene.., implement ability, and co.t are
primary balancing factor. u.ed to weigh major trade-off. among alternative
hazardous wa.te lII&D&9_nt .trategie., and (3) Kodifvina Criteria - .tate and
community acceptance are modifying criteria that are formally taken into account
after public comment i. received on the propo.ed plan and incorporated in the
ROD.
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TABLE 6
CRITERIA FOR EVALUATING CLEANUP ALTERNATIVES
1) Overall ~rotection of public health and environment:
Degree to which each alternative eliminates, reduces,
or controls threats to health and environment through
treatment, engineering methods, or institutional
controls (e.g. deed, land use or other restrictions).
2) Com~liance with state and federal reauirements:
Degree to which each alternative meets environmental
regulations determined to be applicable or relevant and
appropriate to site conditions.
3) Short term effectiveness: Length of time needed to
implement each alternative and risks posed to workers
and nearby re.idents during implementation.
4) Lena term effectiveness: Ability to maintain reliable
protection after implementation.
5) Reduction of mobilitv. toxicitv. and volume: Degree to
which alternative reduce. (1) ability of contaminant.
to move through the environment, (2) harmful nature of
contaminants, and (3) amount of contamination.
6) Imolementabilitv: Technical feasibility (difficulty
of constructing, operating or maintaining), and administra-
tive ea.e (e.g. amount of coordination with other
government agencies or relocation of re.ident.) of
implementing remedy, including availability of good.
or service..
7) Cost:
Benefit. of alternative weighed against cost.
8) State acce~ance: BPA requests state comments and
concurrence for consideration in final remedy selection.
9) COlIIIDqnitv acce~ancel SPA hold. public cOlllD8nt period
to get input from affectsd community and considers and
re.pond8 to all cOIIID8nt. received prior to the final
select10D of a remedial (long term cleanup) action.
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The selected alternative must meet the Threshold Criteria and
comply with all ARARs or be granted a waiver for compliance with
ARARs. Any alternative that does not satisfy both of these
requirements is not eligible for selection. The Primary
Balancing Criteria are the technical criteria upon which the
detailed analysis is primarily based. The final two criteria,
known as Modifying Criteria, assess the Public's and the State
Agency's acceptance of the alternative. Based on these final
two criteria, EPA may modify aspects of the specific
alternative.
The following analysis is a summary of the evaluation of
alternatives for remediating the ILCO Superfund Site under
of the criteria. A comparison is made between each of the
alternatives for achievement of a specific criterion.
each
THRESHOLD CRITERIA
8.1
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Source Control Alternatives
All of the alternatives, with the exception of the -No Action"
alternative, would provide protection of human health and the
environment by minimizing or controlling the risk associated
with the contaminated soils through treatment or containment and
institutional controls. Since the No Action alternative for
source control does not meet the criteria of overall protection,
it will not be discussed further in the source control
evaluation. Alternative SC-2 would protect against direct
exposure to the contaminated soils. The alternatives involving
excavation WOuld minimize risk by removing and treating the
principal source of the soil and possible groundwater
contamination and use of institutional controls where
necessary. Precautions would need to be taken to protect the
public' environment during transportation of hazardous
materials when implementing Alternative SC-5.
Groundwater Control Alternatives
All of the alternatives except the No Action alternative would
provide protection of human health and the environment by
minimizing or controlling the risk associated with any
contaminated groundwater through institutional controls,
containment or treatment. For those subsites with groundwater
contamination the No Action alternative would not restrict usage
of. the contaainated groundwater. The Natural Attenuation (GC-2)
alternative would only provide protection of human health and
the environment il source removal is implemented concurrently.
GC-2 .relies on institutional controls for protection until
contaminant levels are achieved. GC-3 would be protective by
containing contaminated groundwater. GC-4 through GC-6 would
provide protection by removing and treating the contaminated
groundwater.
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1 ---
I
8.2
COMPLIANCE WITH ARARS
Source Control Alternatives
All of the remaining alternatives would comply with Applicable
or Relevant and Appropriate Requirements (ARARs). Compliance
with action-specific ARARs would occur in all of the
Alternatives except for No Action by meeting RCRA closure,
storage, and transportation criteria in the RCRA regulation and
by complying with National Ambiant Air Quality Standard {NAAQS}
for lead and particulate matter as defined in 40 CFR 50.12.
Based on treatability studies the selected treatment is expected
to treat the waste material to levels below Land Disposal
Restriction (LDR) levels for lead. If some of the material
cannot be treated to below LDR levels Superfund will meet
treatability variance levels for lead. The treatability
variance level for lead is the 99-99.9 percent reduction range.
Groundwater Control Alternatives
Alternative GC-2 (Natural Attenuation) would comply with
chemical-specific ARARs as a result of natural dissipation.
During the time period required to attain the remediation goals,
GC-2 requires restriction of groundwater usage. Compliance with
chemical-specific ARARs would actively occur using Alternatives,
GC-4, GC-5, and GC-6 by meeting the Maximum Contaminant Levels
(MCLs) established in 40 CFR 141.61 for final clean up levels
for aquifer restoration. Surface water discharges would comply
with NPDES requirements.
If the groundwater treatment sludge cannot be treated to below
LOR levels, Superfund will meet treatability variance levels for
lead. The treatability variance level for lead is the 99-99.9
percent reduction range.
PRIMARY BALANCING CRITERIA
8.3
REDUCTION OF TOXICITY. MOBILITY OR VOLUME THROUGH TREATMENT
Source Control Alternatives
Alternative SC-2.(cap) would not include any provision to reduce
mobility, toxicity or volume. Alternative SC-3 (disposal) would
reduce mobility once the waste had been treated at the disposal
facility prior to disposal. In Alternatives SC-4 and SC-S
contaminated 80i1, sediments and/or battery casings would be
solidified/stabilized using a mix of other materials.
Solidification does not reduce the toxicity of the contaminants,
but it does greatly reduce their mobility. Because materials
such as cement and other additives are added to the waste
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material, in the treatment process, the volume of the soil and
waste material increases.
Groundwater Control Alternatives
GC-2 (Natural Attenuation) and GC-3 (Cap and Slurry Wall)
alternatives would not include a provision to reduce toxicity or
volume. GC-2 would reduce the mobility of the contaminants
through the natural attenuation process and GC-3 would reduce
mobility by preventing the contaminated groundwater from
migrating offsite. The alternatives that call for groundwater
treatment (GC-4, GC-5 and GC-6) would all reduce the volume and
toxicity of the groundwater contaminants by extraction and
chemical and physical treatment.
8.4
SHORT-TERM EFFECTIVENESS
Source Control Alternatives
SC-2 (containment) avoids short-term impacts and uncertainties
associated with excavation. All of the alternatives would
requi.re varying amounts of time to implement. The health risks
to remedial workers is unlikely, particularly when appropriate
monitoring and engineering controls are applied. In Alternative
SC-5 measures must be taken to protect the community during
transport of the contaminated materials.
Groundwater Control Alternatives
All of the remaining alternatives would require varying amounts
of time to implement. The groundwater would be remediated using
Alternative GC-2 only after it naturally attenuates. GC-3,
GC-4, GC-5 and GC-6 would prevent or limit migration of
groundwater contamination immediately after implementation.
8.5
LONG-TERM EFFECTIVENESS
Source Control Alternatives
Each of the remaining alternatives would provide long-term
effectiveness t~ough limiting the migration of contamination or
treatment of the contaminated soils at the site. As long as a
cap is installed and maintained properly Alternative SC-2 would
be effective. According to the NCP, EPA expects to use
engineering controls, such as containment, (Capping - SC-2) for
waste that poses a relatively low long-term threat or where
treatment is impracticable for long term effectivenes8.
Alternative GC-3 provide8 for the removal of contaminants from
the site and treatment at the disposal facility, thus greatly
reducing the long-term human-health and environmental risks at
the site. In the remaining alternatives the contaminated
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materials would be solidified. Exc lvation and solidification
are proven technologies, but woulc require increased operation
and maintenance.
Groundwater Control Alternatives
The GC-2 alternative alone would not provide long-term
effectiveness. Without addressing the source, contamination
could continue to migrate through subsurface soil to the
groundwater and the groundwater contamination would not be
reduced over time. If Alternative GC-2 is implemented in
conjunction with source removal then the natural attenuation
process would provide long term effectiveness. Once the source
is removed and the contamination attenuates to the soil
particles the area would be remediated. GC-3 (Containment from
Cap and Slurry Wall) for wastes that pose a relatively low
long-term threat or where treatment is impracticable (Leeds
Municipal Landfill) meets the NCP expectations and municipal
landfill guidance. Installation of a multilayer cap would
reduce the potential for increased groundwater contamination.
The slurry wall would contain the contaminated groundwater
preventing it from migrating but the contaminated groundwater
would remain a potential exposure point. The remaining
alternatives (GC-4, GC-S, and GC-6) provide a high degree of
long-term effectiveness and permanence by removal and treatment
of groundwater to restore it to drinking water standards.
8.6
IMPLEMENTABILITY
Source Control Alternatives
All of the alternatives evaluated are implementable. Quality
control during construction of the cap in Alternative SC-2 is
important to maximize the effectiveness of the system in
reducing infiltration. Treatment of heterogeneous ,waste (such
as municipal landfill waste) is often difficult or infeasible,
reducing implementability. The remaining alternatives are
technically feasible and implementable. However, difficulties
may arise as a result of problems with unknown subsurface.
conditions, materials handling, transportation" and disposal or
replacement of fill.
Groundwater Control Alternatives.
All of the alternatives evaluated are implementable. Quality
control during construction of the cap and slurry wall in
Alternative GC-3 i8 important to maximize the effectiveness of
the system in redQ.cing infiltration. The GC-4 and GC-S
alternatives are implementable, however, difficulties may arise
with transportation of the contaminated groundwater following
extraction.
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8.7
COST
All of the estLmated costs are for construction and operation
and maintenance (O&M) of each alternative. A factor is applied
to O&M costs to make them equivalent to current construction
costs. This is known as a present worth cost. In this way the
total life cycle cost of an alternative can be calculated and
compared by adding the construction and O&M present worth
costs. These cost estLmates are order-of-magnitude estLmates
with an intended accuracy range of +50/-30 percent. As shown on
the Table 7, the cost estLmate for SC-4 and SC-S is
substantially less than SC-3. They also provide a greater level
of protection of human health and the environment. GC-3, GC-4
and GC-S are substantially higher than the remaining groundwater
alternatives, with GC-S costing the most. The only estLmated
costs associated with GC-1 and GC-2 is groundwater monitoring
and operation and maintenance.
MODIFYING CRITERIA
8.8
STATE ACCEPTANCE
The State of Alabama has reviewed EPA's proposed Plan and have
concurred with EPA on the alternatives proposed for site
remediation. The concurrence letter can be found in Appendix D.
8.9
COMMUNITY ACCEPTANCE
The public was concerned about protection of the residents and
workers in the Leeds area during excavation. Based on comments
received at the public meeting as well as during the public
comment period, the public supports the remediation of the site
and does not oppose the selected remedy.
9.0
EPA's SELEC'l'BD ALTBRHATIVB
Selected Source Alternatives
The selected alternative for cleanup of the source of
contamination at the rLCO Parking Lot and Pleming's Patio is
Alternative SC-4, Excavation, Onsite Solidification and
Replacement Onsite. The estimated cost for this source
alternative for the ILeO Parking Lot is $12,780,000 and the
estLmated cost for this source alternative for Fleming's Patio
is $4,700,000. The total estimated cost for this alternative is
$17,480,000.
The selected alternative for cleanup of the source of
contamination at the Gulf Service Station, J , L
Pabricators, the Connell Property, and the AcIIar Church of God
is Alternative SC-5, Excavation, Centrally Located
Solidification (with placement in the Parking Lot instead of
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Table! 7
Cost Estimates of- Alternatives
($ million)
REMEDIAL parking Gulf J&L Flemings Connell Leeds AcInar
ALTERNATIVES Lot Station Fabric. Patio Property Landfill Church
Source
SC-l No Aci:ion u.033 0.010 0.015 0.026 0.013 0.008 0.005
SC-2 capping 3.69 0.31 0.88 1.42 0.66 1.52 0.34
SC-3 RCRA 28.83 2.25 6.91 11.93 5.49 0.82 3.94
Landfill
SC-4 Onsite 12.78 1.26 2.94 4.70 2.55 0.68 1.88
Treatment
SC-5 Central 12.78* 1.23 3.25 5.22 2;71 0.54 1.98
Treatment
Groundwater
GC-1 No Action ** 0.010 0.015 0.0~6 0.013 0.008 0.005
GC-2 Natural ** NA 0.015 0.026 0.013 .0.008 NA
Attenuation
GC-3 Cap & ** NA 1.50 3.43 1.26 2.96 NA
slurry Wall
GC-4 Pump & ** NA 2.59 4.96 3.25 8.91 NA
Discharge
to ILCO
GC-5 Pump, Treat ** NA 2.97 5.36 3.64 9.23 NA
& Discharge
to ILCO
GC-6 Pump, Treat ** NA 0.61 0.64 0.61 0.77 NA
I & Discharge
to OUtfall
*
Alternative sc-4 (On.ite treatment) and Alternative SC-5 (Centrally
treated at the Parking Lot) are the same for the ILCO parking Lot.
Groundwatel: cleanup at the ILCO parking Lot i. being addressed under RCRA
and a 8ub88qU8J1t ROD that will be written for OU '2. Therefore, no
evaluation of aiternative. wa. done.
.Becau.e no lead or other contaminant. of concern were found above the
groundwater remediation goal. at the Gulf Station or the Acmar Church of
God, no groundwater alternative. were evaluated for these 8ub.ite8.
** -
NA -
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replacement at the other subsites). .Volume increase at the
Parking Lot due to placement of solidified material from the
Gulf Station, J & L Fabricators, Connell Property and the Acmar
Church of God may be of concern. This would be examined in the
design phase of the cleanup, and, if the Parking Lot cannot
accommodate the increase in volume of treated materials,
materials from the four subsites may be placed back in its
original location or possibly in the Leeds Landfill. This would
be done after the waste material was solidified, stabilized, and
rendered nonhazardous. If the solidified wastes can be placed
in the Parking Lot, the excavations from which the waste
originated will be backfilled with clean soil and revegetated.
Subtitle D closure, and institutional controls would only be
necessary at the Parking Lot location in this case. They would
not be necessary a~ the clean filled excavation locations. The
estimated cost of this source alternative for the Gulf Station
is $1,230,000, J&L Fabricators is $3,250,000, the Connell
Property is $2,710,000 and the Acmar Church of God is
$1,980,000. The total estimated cost for this alternative is
$9,170,000.
The selected alternative for cleanup of the source of
contamination at the City of Leeds Landfill is Alternative
SC-2, Multilayer Cap. The estimated cost for this alternative
for the Leeds Landfill is $1,520,000.
Selected Groundwater Alternatives
A No Action Alternative (GC-1) is the selected alternative at
the Gulf Station and the Acmar Church of God because there is
no groundwater contamination at these subsites. Only
groundwater monitoring will be required. The estimated cost of
this alternative for the Gulf Station is $10,000 and the
estimated cost for the Acmar Church of God is $5,000. The total
estimated cost for this alternative is $15,000.
The selected alternative for groundwater cleanup at J . L
Fabricators, Fleming's Patio, and the Connell Property is GC-2,
Natural Attenuation Alternative. The estimated cost of this
alternative for J&L Fabricators is $15,000, for Fleming's Patio
is $26,000 and for the Connell Property is $13,000. The total
estimated cost for this alternative 1s $54,000. .
The selected alternative for groundwater cleanup and long-term
containment up to the landfill boundary at the City of Leeds
Landfill is GC-6, Extraction, and Chemical/Physical Treatment,
and Discharge to onsite Surface Outfall. The estimated cost of
this alternative for Leeds Landfill is $770,000.
Cost Estimates
The estimated total cost of Source Alternatives is $28,170,000.
The estimated total cost of Groundwater Alternatives is
$839,000. The estimated total for the entire site is
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$29,009,000. This cost includes total capital cost, total
operation and maintenance (O&M) present worth cost and other
considerations of each alternative such as temporary relocation
costs.
Treatability studies have indicated that the selected treatment
methods will treat the waste materials to levels below Land
Disposal Restriction (LDR) levels for lead. If some of the
waste material or groundwater treatment sludge cannot be treated
to below LDR levels Superfund will meet treatability variance
levels for the contaminated soil and debris. The treatability
variance level for lead is the 99-99.9 percent reduction range.
Placement in the Leeds Landfill will meet State RCRA Subtitle D
requirements and Land Disposal Restriction Levels. Placement in
the Leeds Landfill would only be done if it was protective and
met all ARARs.
The Natural Attenuation groundwater alternative is selected for
J & L Fabricators, Fleming's Pa~io and the Connell Property.
Lead was found in the groundwater at these subsites at levels
above. the cleanup level for lead in groundwater.. EPA has
concluded that, based on groundwater data and groundwater
modeling that has been conducted for these subsites, the lead
concentrations in the groundwater will naturally attenuate or
lessen with time once the source is removed. Modeling has shown
that the mobility of the lead will be reduced once the source is
removed. A source removal alternative has also been selected
for all three of these subsites. Longterm groundwater
monitoring will be conducted with this alternative.
For Fleming's Patio the plume should no longer exist when the
fill and the contaminated well in the fill are removed as part
of the site remediation. For J&L Fabricators modeling indicates
the plume should be transported by ground-water to the discharge
point in no less than 3.8 years. At the Connell Property,
modeling indicates that natural attenuation will result in the
plume having a concentration below the ground-water clean-up
goal in less than five years. .
If, during the groundwater monitoring the level of lead does not
decrease with time then the issue of groundwater remediation at
these particular subsites will be reevaluated. There would also
be a 5-year review conducted 5 years after Remedial Action is
implemented to assess whether cleanup levels will be reached.
Temporary relocatJ..on will be necessary for the Connell Property
residents and for the Acmar Church of God congregation. It will
be necessary to move these people based on risk and the
feasibility of them remaining while the remediation is being
conducted. In both cases it appears that it would not be
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feasible for the residents or the
their homes and facilities during
excavation. Temporary relocation
total cost.
In summary, the preferred alternatives are believed to provide
the best balance of trade-offs among alternatives with respect
to the criteria used to evaluate remedies. Based on the
information available at this time, therefore, EPA and the State
of Alabama believe the selected alternatives will protect human
health and the environment, will comply with ARARs, will be cost
effective, and will utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. The preferred alternative satisfies
the preference. for treatment as a principle element.
church congregation to utilize
part or all o.f the
costs are reflected in the
10.0
STATUTORY DBTBRJlIRATIOHS
The u.S. EPA has determined that this remedy will satisfy the
statutory requirements of Section 121 of CERCLA by provid~ng
protection of human health and the environment, attaining ARABs,
providing cost effectiveness, and utilizing permanent solutions
and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedies provide protection of human health and the
environment by treating the waste and groundwater to health
based remediation goals. The remedies also rely on land and
groundwater use restrictions to prohibit the usage of the
contaminated media until the remediation goals are achieved.
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND APPROPRIATE
REOUIREMENTS ( ARARs )
Remedial actions performed under CERCLA, as amended by SARA,
must comply with all applicable or relevant and appropriate
requirements (ARARs) or comply with a justifiable waiver. The
selected alternatives were evaluated on the basis of the degree
the alternatives complied with these requirements. The selected
alternatives were found to attain ARABs.
When ARAR8 are not available for specific compounds or exposure
media (such aa groundwater), the cleanup goals are based on
non-promulgated advisories or guidance such as proposed federal
HCLGs, lifetime Health Advisories (HAs), and reference dose
(RfD) based quide1-ines.
Federal location-specific ARAR8 for the ILCO subsites include
the followingl
Resource Conservation and Recovery Act (RCRA) location
requirements - Mandates that hazardous waste treatment,
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storage, or disposal facilities located within a lOa-year
floodplain must be designed, constructed, operated, and
maintained to avoid washout.
Resource Conservation and Recovery Act (RCRA) Closure under
Subtitle D - Requirements for closure of municipal landfills
is used to close solid waste areas at the ILca subsites.
Endangered Species Act - The selected remedy is protective
of species listed as endangered or threatened under the
Endangered Species Act. Requirements of the Interagency
Section 7 Consultation Process, 50 CFR Part 402, will be
met. The Department of Interior, Fish and Wildlife Service,
will be consulted during remedial design to assure that
endangered or threatened species are not adversely impacted
by implementation of this remedy.
Fish and Wildlife Coordination Act - Requires adequate
protection of fish and wildlife if any stream or other body
of water is modified. Additionally, actions in wetlands are
required to avoid adverse effects, minimize potential -harm,
and restore and preserve natural and beneficial values.
Federal regulations that contain potential action-specific ARARs
for the site are listed beiowl
RCRA Compliance Monitoring Program 40 CFR Section 264.99
establishes criteria for monitoring groundwater quality when
contaminants have been detected.
Federal Ambient Water Quality Criteria (AWQC) from Quality
Criteria for Water 1986 (Gold Book) - is the maximum
concentration for the protection of aquatic life. The AWQC
may not be initially met. However, these standard will be
achieved over a short period of time because the source of
contamination will be removed or capped.
RCRA Land Disposal Restrictions (LDRs) 40 CFR 268 -
Established restrictions on the placement of RCRA hazardous
wastes. Th$ LDRe are applicable only if the contaminated
soil is excavated and removed from site, or excavated and
treated, and then replaced in a way that constitutes'
placement. .
Standards Applicable to Transporters of Hazardous Waste 40
CFR 263 - B8tablished standards for transporting hazardous
waste if the transportation requires a manifest under 40 CFR
Part 262. These standards are applicable when transporting
waste from one subsite to another prior to treatment.
Federal Occupational Safety and Health Administration Act
(OSHA) - The selected remedial action contractor will
develop and implement a health and safety program for its
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workers. All onsite workers will meet the minimum training
and medical monitoring requirements outlined in 29 CFR 1910.
10.3
COST EFFECTIVENESS
The total present worth cost of EPA's selected remedies are
$29,009,000. Cost effectiveness is determined by comparing the
costs of all alternatives being considered with their overall
affective~esg tc determine whether the costs ~re proportional to
the effectiveness than other, less costly combinations of
remedies. EPA has determined the cost of the selected
alternatives are proportionate to the overall effectiveness.
Therefore, the combined remedy is considered cost effective.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
EPA has determined that the selected combination of remedies
provides the best balance among the nine evaluation criteria for
the alternatives evaluated. The selected combination provides
protection of human health and the environment, reduces the
mobility of the contaminants, and' is cost effective. The
remedy, when complete, will provide a high degree of
permanence. The remedy represents the maximum extent to which
permanent solutions and treatment can be practicably utilized to
remediate the ILCO site.
10.5
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The statutory preference for treatment will be met by the
selected combination of remedies. The combination relies on
solidification/stabilization of contaminated soil to permanently
immobilize the material. The surficial aquifer contaminated
with lead as well as other inorganic compounds will attain
groundwater remediation goals through passive treatment and by
removal and treatment of the source.
11.0
DOC'OIIBBTATIOH OF SIGRIFICAHT CHARGES
EPA issued a Proposed Plan (preferred alternative) for
remediation of the ILCO Superfund Site on July 25, 1991. The
selected combination of remedies does not differ from the
Proposed Plan. EPA reviewed all written and verbal comments
submitted during the public comment period. Upon review of
these comments, it was determined that corrections in the RI/FS
documents needed to be made and an adjustment needed to be made
in .the cost estimates that were in the proposed plan.
The RI and FS documents state that the NAAQS lead level is 15
ug/mJ. The correct NAAQS level is 1.5 ug/m3. Also,in the RI
and FS it states that air levels exceeded the NAAQS level for
lead. Lead was detected at some of the subsites but no samples
were found above the NAAQS level. These corrections have been
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1--.
made by adding memos to the documen.s that serve as errata
sheets.
The cost estimates for J&L Fabricators found in the proposed
plan include the cost of remediating the sedLments in Dry
Creek. SedLment removal is not necessary there. Changes in the
cost estLmates. were made in the FS during the public comment
period before the public meeting. This changed the total
estLmated cost from $19,139,000 to $18,872,000.
An computer error was found in the Feasibility Study in the cost
estimate for Alternative SC-4 for the Parking Lot. The cost was
originally stated as $2,660,000 and the corrected cost is
$12,780,000. This changes the total from $18,872,000 to
$29,009,000.
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APPENDIX A
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RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) established a
public comment period from July 24, 1991 through August 24, 1991
for interested parties to comment on EPA's Proposed Plan for
Remedial Action at the ILCO Superfund Site in and around Leeds,
Alabama. A public meeting was conducted by EPA on August 8,
1991, at the Leeds, Civic Center in Leeds, Alabama. The meeting
presented the results of the Remedial Investigation and
Feasibility Study (RIfFS) for the ILCO Site and the Proposed
Plan of action for the ILCO Site. The public comment period was
extended until September 23, 1991 after EPA received a request
for an extension.
A responsiveness summary is required to provide a summary of
citizen comments and concerns about the Site, as raised during
the public comment period, and the responses to those concerns.
All comments summarized in this document have been factored into
the final decision of the interim action for the ILCO Site4
This responsiveness summary for the ILCO Site is divided into
the following sections.
I.
Overview - This section discusses the recommended
alternative for remedial action and the public reaction
to this alternative.
Backaround on Community Involvement and Concernsl This
section provides a brief history of community interest
and concerns regarding the ILCO Superfund Site.
III. Summarv of Maior Ouest ions and Comments Received Durina
the Public Comment Period and FDER's or EPA's
ReSDonses: This section presents comments submitted
during the public comment period, and provides the
responses to these comments.
II.
IV.
Remainina Concernsl This section discusses community
concerns of which EPA should be aware "during remedial
design.
I.
Overview
The preferred remedial alternative was presented to the public
in a Proposed Plan released on July 25, 1991, a public notice in
the Birminahaa News and the Birminaham Post-Herald on July 24,
1991 and a public notice in the Leeds News July 25, 1991. A
public meeting was held August 8, 1991. The selected
alternatives consist of source and groundwater remedies at each
subsite.
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The source alternative selected include transport ion of lead
contaminated soils from the Gulf Station, J & L Fabricators, the
Connell Property, and the Acmar Church of God to the ILCO
Parking Lot, where the contaminated material will be treated by
solidification/stabilization methods and placed into the ILCO
Parking Lot. This alternative includes the Parking Lot material
as well. The same type of treatment will be used for the
Fleming's Patio contaminated material. This material will be
treated at the Fleming's Patio location and replaced there.
Soil contamination at the Leeds Landfill will be capped.
The groundwater alternatives selected include no action for the
Gulf Station and the Acmar Church of God; natural attenuation
for J & L Fabricators, Fleming's Patio and the Connell Property;
extraction and treatment of contaminated groundwater at the
Leeds Landfill with discharge to a surface outfall. The Parking
Lot groundwater remediation is currently being addressed under
the Resource Conservation and Recovery Act (RCRA) and will be
addressed in a future ROD.
The public was concerned about protection of the residents and
workers in the Leeds area during excavation. They are also
concerned about any groundwater contamination and the health
impact on their children. Based on comments received at the
public meeting as well as during the public comment period, the
public supports the remediation of the site and does not oppose
the selected remedy.
II.
Backaround on Community Involvement and Concerns
The Leeds, Alabama community has been aware of the contamination
problem at the ILCO Superfund Site for several years. Community
interviews were conducted in 1986. EPA distributed an RIfFS
fact sheet in February 1987. EPA updated the community
relations plan in 1989 and held community interviews again in
January 1990.
An EPA prepared Proposed Plan which described alternative
remediation plans, along with EPA's preferred remedy, was mailed
to the members of the public who had previously expressed an
interest in the site. The Proposed Plan gave a brief site
history, described the Superfund process and the remedial
alternatives, provided details about the public comment period
and the public meeting. A public notice was published to notify
the public of the availability of the Proposed Plan and the
upcoming public meeting.
Concern is high among the local community regarding the ILCO
Site. Citizens are generally concerned about contamination of
groundwater and air. They are concerned about the effect the
lead may have on their children. The citizens were disturbed
over conclusions from a lead-blood level study conducted in
February 1984. A subsequent lead-blood level study was
conducted by the Alabama Department of Health and the Agency for
Toxic Substances and Disease
-------
Reg~stry (ATSDR) ~n AUguSt l~~~. Tn~5 5~udy indicated that the
blood lead levels of the 81 children tested are within the
expected reference ranges for u.s. children of 0-15 ug/dcl.
Some of the citizens expressed concerns about this study as
well.
III Summary of Maior. Ouestions and Comments Received Durina the
Public Comment Period and FDER's and EPA's reSDonses
Comment 1: The commentor stated that he would like to see all
of the subsites treated as a comprehensive unit because they are
"ultimately all connected to the overall environmental health of
the Leeds area".
EPA ReSDOnse: All of the subsites have been investigated and
are being addressed under Superfund with the same degree of
importance. We are including each of the subsites together in
this ROD for Operable Unit 1 because of the similarities of the.
waste and the origin of the waste material. Due to funding
considerations and technical feasibility the clean up of .
individual subsites will be phased. The determination for this
phased approach will be based on risk, engineering design
considerations and cost.
Comment 2: Another commentor questioned the "postponement of
clean up of the ILCO Main Facility and the Unnamed Tributary".
EPA ResDonse: EPA is not postponing the clean up of the ILCO
Main Facility and the Unnamed Tributary.
ILCO's operations at the Main Facility are regulated under the
Resource Conservation and Recovery Act (RCRA). Remediation of
the Main Facility and the Unnamed Tributary has been initiated.
ILCO is conducting this clean up pursuant to a partial consent
decree entered by the U.S. District Court for the Northern
District of Alabama. ILCO has excavated contaminated sediments
from the upstream portion of the tributary and they have
submitted documentation of this to EPA. They are in the process
of closing out the waste piles at the Main Facility and have
installed wells for the groundwater remediation pump and
treatment system. The cleanup under Superfund of Operable Unit
#1 and the cleanup of the Main Facility and the Unnamed
Tributary under RCRA have been coordinated to approach the
problem in an economically and environmentally sound manner.
Comment 3: Several commentors questioned the use of natural
attenuation at J & L Fabricators, Fleming's Patio and the
Connell property.
EPA ResDonse: The natural attenuation alternative was selected
for groundwater cleanup at J&L Fabricators, Fleming's Patio and
the Connell property based on modeling, geologic and hydrologic
conditions. EPA has concluded, based on the extent of
groundwater contamination that natural attenuation is the
-------
best way to approach groundwa:er cleanup at these subsites. The
source of contamination will Je removed at all of these subsites
and some of the contaminated groundwater will be removed when
the source of contamination is removed.
The natural attenuation alternative is recommended in the
National Contingency Plan when natural attenuation is expected
to reduce the concentration of contaminants in the ground water
to the remediation goals-levels determined to be protective of
human health and sensitive ecological environments-in a
reasonable time frame. Based upon modeling, EPA has concluded
that when the source of contamination is removed, the
groundwater concentration will naturally attenuate. For
Fleming's Patio the plume should no longer exist when the fill
is are removed as part of the site remediation. For J & L
Fabricators modeling ind~cates the plume should attenuate to
levels below the action level of 15 ug/l in no less than 3.8
years, and at the Connell Property, less than five years.
Comment 4: A commentor also questioned the alternative for the
Leeds Landfill that calls for pumping and treatment of the
contaminated groundwater and discharging it to a onsite surface
outfall. The commentor's concern relates to whether the
contaminants will be released into the groundwater and surface
waters from this discharge.
EPA Res~onse: Discharge to an onsite surface outfall as in the
case of the Leeds Landfill subsite would be conducted only after
EPA's guidelines for discharge under the NPDES program have been
satisfied. Sampling would be conducted to verify that the
contaminants were properly removed.
Comment 5: A few commentors questioned the possibility of
drinking water contamination from the contaminated groundwater
beneath the Leeds landfill, and the possibility of future
groundwater contamination if waste is left in place with a cap
over it. They also questioned how long the groundwater pump and
treatment system will operate.
EPA ResDonse: The remedy that has been selected (multilayer
cap) will reduce the possibility of groundwater contamination,
however, contaminants may continue to migrate from the source
into the groundwater. Therefore, the groundwater pump and
treatment system is necessary. This system will remove
contaminated groundwater and treat it to acceptable levels.
Currently, the groundwater contamination found at the landfill
is located in a groundwater aquifer that is not used for
drinking water. The pump and treatment system will be
intercepting the groundwater as near to the source as possible
so that groundwater contamination will not migrate to a zone or
another aquifer used as a possible drinking water source.
Groundwater wells' located in the area of contamination will be
monitored and will not be used for drinking water. The pump and
-------
treatment system will continue to operate until the groundwater
contaminants associated with the ILCO wastes are reduced below
their remediation goals.
Comment 6: One commentor questioned why residents would need to
be relocated during clean up but the workers and the Leeds
residents work and live around the Main Facility's daily
operations without "warnings or alarms".
EPA ResDonse: Temporary relocation of some residents may be
necessary during the remedial action process. When the material
is removed from the ground and soil is excavated it is likely
that dust will blow around carrying contaminated materials. EPA
will be taking precautions by using water sprays to control dust
but there is still a risk of direct exposure if residents and
remedial action workers at the subsite inhale the contaminants
in the dust as well as a risk of direct exposure through dermal
contact and ingestion. The remedial action workers would have
to meet Occupational Safety and Health Administration Act (OSHA)
requirements when working in these conditions and will be ~itted
with respirators. It would be impractical for the residents and
church congregation to wear protective clothing and equipment of
this ~ature when going about their daily activities and living
in their homes. Further, it may not be feasible for them to use
their facilities during remediation. For these reasons
temporary relocation has been considered.
As far as the ILCO Main Facility's operations are concerned,
ILCO must comply with OSHA requirements to protect their workers
at their facility, comply with RCRA in order to properly manage
their hazardous and solid waste and comply with the Clean Air
and Clean Water Act and all other applicable state and federal
laws. The response action selected by EPA does not relieve ILCO
from the need to comply with the laws and regulation regarding
the operation of its business.
Comment 7: One commentor asked that EPA conduct the clean up at
the Gulf Service station during a time when the children are not
in school at the Leeds Elementary School located across the
street from the Gulf Station (Currently the British Petroleum
(BP) station).
EPA ReSDonse: Precautions will be taken to keep contaminants
onsite during remediation. It will be necessary to consider a
number of factors when planning the design, and remedial action
that mayor may not allow for remediation at a time when the
children are not in school. These include risk, engineering
designs and logistics for this subsite as well as its
relationship to the other subsite remediation. Overall risk
will be regarded when looking at which subsite will be addressed
first. Engineering designs and logistics must also be taken
into consideration. As stated earlier EPA will take measures to
minimize air releases during excavation of contaminated soil.
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Comment 8: A commentor suggested that a new process be used to
remediate the ILCO waste instead of burying the solidified
material onsite. This new process would take hazardous and
solid waste material such as the waste at ILCO and solidify this
material into bricks to be used as building material.
EPA Response: Although the Superfund statute allows for the
selection of innovative technology, the technology must be
protective of human health and the environment. To date, EPA
does not have sufficient data to definitively show that this new
technology is protective. EPA's primary goal in conducting a
remedial action is the remediation of the contamination at the
site. The process is a new technology and extensive studies and
testing would have to be conducted before it could be
implemented. This would further delay the implementation of a
remedy. Further, EPA is not in a position to sell the material
once the bricks were made if EPA conducted the RD/RA
themselves. EPA is required to conduct a 5-year review at which
time EPA examines the treated material to see that it remains
protective. In the case of bricks being sold as building'
material it would be extremely difficult to follow up on the
protectiveness of the selected remedy.
Comment 9: Another commentor asked if it had ever been brought
to EPA's attention that the "Keep Leeds Beautiful" organization
has announced for several years that the Leeds Municipal
Landfill has been used as a mulching area for the organization's
recycling program. Residents were told that they could get
mulch from the landfill to be used on their lawns and gardens.
The commentor also asked about the risk associated with this.
EPA Response: It has not been brought to EPA's attention in the
past. At this time the City of Leeds Landfill does contain lead
contaminated waste. The general location of that waste is
known. The risk assessment for the ILCO Superfund Site has
determined that there is a risk associated with the lead
contamination at the landfill. EPA does not know the risk
associated with any mulch that may have been taken from the
landfill.
Comment 10: One commentary stated that a door-to-door campaign
is needed around the Leeds Landfill and the Fleming's Patio to
advise residents .in the immediate area of the clean up action
and the precautions to protect themselves.
EPA Response: The risk associated with these subsites has been
addressed in the Risk Assessment that was conducted at the
site. The alternative proposed for the Leeds Landfill does not
involve disturbing the lead contaminated soil. A cap of clean
material would be constructed over the landfill soils. The risk
of ingestion or inhalation of contaminated dust is substantially
less in this case than at the other subsites. Air monitoring
will be conducted to make sure the activities are protective.
The pumping and treatment of groundwater at this subsite will
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not pose a threat to the residents. A tact sheet with
information regarding the remedial activities will be
distributed to the public.
The primary health risk associated with remediation activities
at the Fleming's Patio site is the possibility of ingestion or
inhalation. of contaminated dust. The soils will be sprayed with
a water mist to keep the dust from blowing offsite and there
will be air monitoring conducted. During Remedial Design if it
is determined that offsite dust control will be a problem the
residents will be notified of risks and/or procedures that they
will need to take other than those procedures already
implemented by EPA.
Comment 11: A commentor asked what will be done about the
possible effects blasting, by LeHigh Portland Cement Company
will have on the aquifers and remediation.
EPA ReSDonse:
of the remedy.
blasting would
accordingly.
Comment 12: One commentor wanted to know what criteria was used
to determined the soil clean-up level of 300 ppm for lead. They
did not agree with the clean-up level of 300 ppm and commented
that a range of 500-1000 ppm has been used at other Superfund
Sites and should be used in the case of ILCO.
This will be reviewed during the remedial design
EPA will address what kind of impact the
have on remediation and plan the remediation
EPA Res~onse: The presence of groundwater contamination at
several of the subsites indicates that contaminants have leached
from the contaminated soil to the groundwater. Due to the
contaminant leaching, soil remediation goals were developed to
be protective of human health through all potential pathways as
well as for protection of groundwater. Soil remediation goals
for lead, antimony, arsenic and chromium were based on
protection of human health through a direct pathway. The lead
soil remediation goal of 300 mg/kg represents a level of lead in
soil that would ensure leachable lead levels from the soil will
not result in groundwater exceeding the 0.015 mg/l remediation
goal. .
Comment 13: One .commentor asked to what extent has EPA
investigated the geology and hydrology for placing our
monitoring wells. The commentor said that the hydrology in the
area is different from homogenous mediums and contains voids.
EPA ReSDonse: The hydrology of the area has been sufficiently
determined for well placement. Along with studies conducted at
the ILCO facility and subsites, EPA utilized published
geological surveys for the state of Alabama and specifically for
the area of Leeds.
J
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~omment 14: One commentary was concerned about the waste
naterial from Fleming's Patio being treated at Fleming's Patio
)ecause of space limitations and concerned that this would be
10ne without relocating the residents there.
~PA Response: The actual staging area for treatment will be
1esigned during the remedial design but because small amounts of
naterial will be solidified at a time EPA believes there is a
~ufficient. C11I1ount of space for this work at the subsite.
[f it became necessary to relocate residents located near the
?leming's Patio subsite EPA would do so. At this time it does
lot appear that this will be necessary. During remediation EPA
iill be taking precautions to assure that contaminated dust will
lot be released to nearby residents.
~omment 15: One commentary wanted to know if businesses would
)e able to operate while remediation is being conducted.
~PA Response: EPA anticipates that, based on the location' of
:he contaminated soil, the businesses located in the areas where
~emediation will continue to operate.
~omment 16: ILCO commented that contaminated material does not
neet the NCP criteria for treatment because they assert that
:here is a low mobility of lead in soils and a low threat of
Leachability of lead from blast furnace slag. For these reasons
[LCO believes that the material does not have to be treated.
~PA Response: EPA disagrees. The NCP states in 40 CFR
~00.430(a)(1)(iii), 55 FR 8846, March 8, 1990 the following:
[A] EPA expects to use treatment to address the principal
threats posed by a site, wherever practicable. Principal
threats for which treatment is most likely to be appropriate
include liquids, areas contaminated with high concentrations
of toxic compounds, and highly mobile materials.
~he ILCO site's principal threats include high concentrations of
:oxic compounds. Each subsite where EPA is contemplating
:reatment has contamination of 1,000 ppm lead in soil and some
is high as 100,000 ppm lead in soils. Groundwater contamination
ind pH levels associated with the subsites indicate that there
Ls a threat of lead leaching further into the environment. The.
~CP directs that .the EPA use treatment when practicable in this
:ase.
~omment 17: ILeO maintains that the waste at the Gulf Station
ias' not generated nor disposed by or on behalf of ILCO.
~herefore ILeO questioned the proposed placement of the Gulf
;tation waste in the Parking Lot which is located on ILCO's
?roperty. ILCO stated that they will not allow disposal of this
naterial on their property.
~PA Response: If it were necessary to do so, the proposed plan
)f action allows for the Gulf Station material to be placed back
-------
in its original excavation or possibly in the Leeds Landfill.
Further determinations will be made regarding the Gulf Station
and based on those EPA will act accordingly.
Comment 18: ILCa suggested that the ILca Parking Lot should be
capped instead of treated and replaced. ILca stated that
excavation of .the lead contaminated material would have an
adverse impact on the public by causing contaminated particles
to be airborne. ILca also stated that another Superfund Site in
Granite City, Illinois with similar highly contaminated lead
wastes was capped. ILCa stated that because the Main Facility
groundwater pump and treatment system would address any
contamination around the Parking Lot, concern about migration of
contaminants is alleviated, so there is no need to excavate the
material.
EPA ResDonse: ane of the criteria used to evaluate remedial
alternatives is long-term effectiveness. Both capping and
treatment would provide long-term effectiveness through limiting
the migration of contamination or treatment of the contaminated
soils at the site. As long as a cap is installed and maintained
pr:1perly it would be effective but to a lesser degree than
treatment. Also, according to the NCP's preference for
treatment, EPA expects to use engineering controls, such as
containment, for waste that poses a relatively low long-term
threat or where treatment is impracticable for long term
effectiveness. Treatment is practicable and there is a high
long-term threat at the Parking Lot. During excavation
precautionary measures will be taken to make sure that
contaminated airborne dust particles do not move offsite. Also
measures will be taken to limit the dust that is there by
spraying the area regularly with water.
Comment 19: ILca argues that excavation and natural attenuation
are not necessary at the J & L Fabricators subsite and the
Connell Property subsite and that a no action alternative should
be selected. The Bureau of Mines conducted a study at these
subsites that, according to ILca's interpretation, shows that
there has been no migration of contaminants at this site. It
states that the background soils and subsurface soils under the
slag show comparable lead values and that no lead was found in
shallow groundwater.
EPA ReSDonse: BPA did not participate in the analysis of the
Bureau of Mines soil and groundwater samples and BPA did not
approve any of those reports submitted to ILCa by the Bureau of
Mines. BPA's analysis of the Bureau of Mines report is
different from that of ILca. According to Bxhibit I of ILCa's
comments (Bureau of Mines "Assessment of Lead Slag Landfill Site
and the Use of a Computational Program for Chemical Species.)
groundwater lead contamination above the .015 mg/l remediation
goal was found at the site and soil lead levels were high. The
Bureau of Mines used the HeLof .05 mg/l for lead which was
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promulgated as an interim drin .ing water regulation in 1975.
Since that time, information 1as been produced that indicates
that this level may not be pro~ective as a final cleanup level
for all potential receptors. A new MCL of .005 mg/l has been
proposed, but the current action level used for lead in
groundwater is .015 mg/l. This is the level set for the ILCa
Superfund Site, not .05 mg/l. The Bureau of Mines does not take
into account the soil remediation level for the protection of
groundwater of 300 mg/kg lead in soils. Also, in the conclusion
of the document it states "Soil at the site under investigation
had lead concentrations in the extract from the EPA extraction
test that exceeded the allowable concentrations for lead. EPA's
RI/FS results support the excavation and natural attenuation
alternative.
Comment 20: ILca comments that the size of the proposed cap at
the Leeds Landfill is too large. They also assert that the
possibility of placing material from other subsites into the
landfill is "inconsistent with the capping scenario planned for
that site".
EPA ReSDonse: The proposed cap to be placed on the Leeds
Landfill will cover the side of the landfill where the waste was
disposed north of the gravel road. It is generally known how
much waste was disposed of and generally where the waste was
placed. However, because it is not specifically known where or
how deep the waste has been placed it is not appropriate to cap
only a small portion of the north side of the landfill. The cap
that is proposed would limit the infiltration of water into the
landfill thus reducing migration into the groundwater. The
specific design of the cap will be addressed in the remedial
design. Placing a cap on the landfill meets EPA guidance for
remediation of municipal landfills of this kind.
Comment 21: ILCO proposes that capping is the best. and most
cost-effective alternative for the Fleming's Patio subsite.
They assert that capping would be protective of Human Health and
the Environment and would avoid the exposure concern related to
removal and treatment. ILca states in their comments
"Additionally, in the Exposure Assessment contained in the
Feasibility Study (PS), EPA acknowledges that the amount of time
spent by the general public in the vicinity of contaminated
soils is expected to be low and exposures to the public will be
infrequent and insignificant in comparison with worker
exposure." ILeO asserts that migration of contaminants will be
minimal.
EPA ReSDOnsel By treating the contaminated material EPA is
meeting the NCP preference for treatment. During excavation
precautionary measures will be taken to make sure that
contaminated airborne dust particles do not move offsite. Also
measures will be taken to limit the dust that is there by
spraying the area regularly with water.
-------
The Exposure Assessment for Fleming's Patio is in the Risk
Assessment, not in the FS. It states that the workers at
Fleming's Patio would be exposed to contaminated soil for short
periods on an intermittent basis and contaminated soil may be
accidently ingested through unintentional hand-to-mouth contact
when handling food or smoking using soiled hands. It says that
"The general public [Fleming's customers] may also be exposed to
the contaminants through direct contact, although the amount of
time spent in the vicinity of contaminated soils [outside of the
establishment] is expected to be low..." [in comparison to the
employees]. It goes on to say, however, that "Potentially
sensitive receptors are children and a small number of
adults...it may be assumed that children are present in the
adjacent residences and are exposed to the contaminated soil
through their daily activities. II Therefore, the exposure of
children to contaminated fill from this subsite was an important
exposure scenario.
Comment 22: EPA conducted a removal of hazardous material. from
the Acmar Church of God Site. ILCa asserts that there is no
need to do further remediation of any ILca related wastes at the
Acmar Church of God subsite. They assert that any additional
remediation would be inconsistent with the NCP. ILca maintains
that there is. II no more hazardous material at the Church of God
Site" further remediation is not necessary. ILCa argues that an
EPA representative testified, in connection with the Acmar
Church of God Superfund removal action, that no more hazardous
material was remaining at the Church of God. Therefore ILca
maintains that further remediation is not necessary.
EPA ReSDonse: The clean-up criteria for the ILea Superfund Site
had not yet been determined at the point at which the removal
was complete. According to 1987 and 1989 EPA soil sampling
results from the Acmar Church of God lead contamination remains
in the soil at levels above 300 mg/kg, some levels above 10,000
mg/kg. Since these levels exceed health based levels EPA is
required by CERCLA to remediate the contamination to acceptable
levels that are protective of human health and.the environment.
Comment 23: A commentor asked if the Rock Wool from nearby
industry could be contributing to soil and groundwater lead
contamination
EPA ReSDonse: The Rock Wool does not contain lead. Therefore,
EPA has concluded that it does not contribute to soil and
groundwater lead contamination.
Comment 24: Many residents expressed concern about the impact
of lead contamination on the health of the children of Leeds and
concern about the number of children that participated in a
recent blood level study.
EPA ResDonse: A lead-blood level study was conducted by the
. Alabama Department of Health and the Agency for Toxic Substances
and Disease Registry (ATSDR) in August 1989. This study
indicated that the blood lead levels of the 81 children tested
J
-------
are within the expected reference ranges for u.s. children of
0-15 ug/dcl, while the mean was approximately 6 ug/dcl. The
study participation rate was exceptionally high at 80.2 percent
(81 of 101 eligible children).
Comment 25:
the NPL.
Several people wanted to know how ILCa ranked on
EPA Response:
371.
According to the August 1990 NPL list ILca ranked
Comment 26: Several people suggested that fences and signs be
put up at the subsites immediately, prior to remediation.
EPA ReSDonse: EPA will investigate the placement of fences and
signs. The selected remedy includes land use restrictions
established to limit exposure of contaminants from the subsites.
Comment 27: ILCa commented that no action should be the
selected alternative at the J & L Fabricators subsite and the
Connell Property subsite. ILCa asserts that the Extraction
Procedure (EP) Toxicity test (and apparently the subsequent
Toxicity Characteristic Leaching Procedure as well) is not
representative of what happens in a "monolandfill situation".
They believe that J & L Fabricators and the Connell Property
represent a monolandfill environment and that waste material
from these subsites will not leach. ILca asserts that the EP
toxicity test does not adequately determine whether these waste
material will leach.
EPA Response: EPA does not agree. The EP toxicity test and the
TCLP test are standard test procedures used by the EPA to
determine the mobility of both organic and inorganic analytes
present in liquid, solid, and multiphasic wastes. Based on
these leaching procedures EPA maintains that the levels of lead
in soil are of concern and should be remediated.
Comment 28: ILca claims that blast furnace slag from smelting
operations do not pose a significant environmental threat when
"monolandfilled". They cite the "Bevill Exclusion" in their
comments which exempted primary lead smelter furnace slag from
being a hazardous waste. Primary lead smelter slag is produced
from mining operations. ILCO's slag is secondary lead smelter
furnace slag which is produced from recycling of spent lead-acid
batteries. ILeO stated that primary lead smelter slag is
landfilled in this country and the proposed treatment of the
ILca waste is inconsistent with the management of primary lead
smelter slag. ILeO asserts that the exemption from being a
hazardous waste should apply to secondary lead smelter slag as
well as primary lead slag.
EPA ReSDonse: The Bevill Exclusion under RCRA does exempt
primary lead smelter furnace slag from being a hazardous waste.
This exclusion does not, however, apply to secondary lead
-------
sme 1 ter s lag such as ILca' s slag. I ~ 1e level 0 f lead
contamination at the ILca Superfunc Site exceeds EPA health
based. levels for lead.
IV. Remainina Concerns:
As was previously mentioned some of the public's concerns
expressed during the public comment period will be addressed
during the remedial design. These include:
-Taking into consideration when the children are in school
at the Leeds Elementary School when planning the remediation
at the Gulf Station (BP Station).
-Consideration of providing information door-to-door to the
residents around the Leeds Landfill and Fleming's Patio.
-Investigating the impact of the blasting that is conducted
in the area by LeHigh Portland Cement Company.
-Determining how long temporary relocation will last, where
would the people be relocated to and what happens if damage
is done to the property.
Various commentors raised questions regarding ILca's liability
and payment for the cleanup. As these comments do not relate to
the selection of the remedy, they will not be addressed here in
detail. EPA will take all appropriate action to hold liable
parties responsible for cleanup of this site.
The community's concerns surrounding the ILca Superfund Site
will be addressed in community relations support throughout the
Superfund process and incorporation of comments/suggestions from
the community into all phases of the Superfund activities
planned at the site.
Community relations will consist of making final documents.
available in a timely manner to the local information repository
for the site. EPA will also issue fact sheets to those on the
mailing list to provide further information on progress of the
project and schedules for future activities at the site. EPA
will inform the community of any principal design changes made
during the remedial design. If, at any time during the Remedial
Design or Remedial Action, new information is revealed that
cou~d affect the implementation of the remedy, the Record of
Decision may be revised with an opportunity for public comment.
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APPENDIX B
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
~ - - ~ - 4-
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MEMO RAN Dtnt
Bruce M. Diamond, Director
Office of Waste Programs En
»J 2 I 1990
FROM:
Cleanup Level for Lead in Grou d
Henry L. Longest, Director
Office of Emergency and Reme
ter
SUBJECT:
:ro:
Patrick M. TObin, Director
Waste Management Division, Region IV
PURPOSE
This memorandum addresses the issue of a protective cleanup
level for lead in ground water usable for drinking water, which
is a major concern for several Superfund sites in Region IV.
OBJECTIVE
The objective of this memorandum is to recommend a final
cleanup level for lead in ground water usable for drinking water
which will meet the CERCLA requirement that all Superfund
remedies be protective of human health and the environment.
BACKGROUND
The current Maximum contaminant Level (MCL) for lead is 50
ppb and was promulgated in 1975 as an interim national primary
drinking water' regulation (NPDWR) under the Safe Drinking Water
Act (SDWA). On November 13, 1985, the Agency began the process
of revising this standard by proposing a Maximum Contaminant
Level Goal' (MCLG) as required by the SDWA (50 m 46936).
On Augu.~ 18, 1988 EPA proposed an MCLG for lead at zero and
an MCL of 5 ppb (53 Ii 31516). Also, since the primary cause of
lead-contaminated drinking water is corrosion of lead-bearing
pipes in public water supply (PWS) distribution systems and/or
household plumbing, the proposed rule would direct PWSs to meet
treatment technique requirements and to deliver public education
to reduce and minimize exposures to lead in drinking water.
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These re~irements ~ould be triggered ~hen an ac~ion level
is exceeded at consumers' taps throughout the water distribution
system. The Agency proposed an action level of 10 ppb, on
average, to trigger corrosion control and public education.
Another lead action level of 20 ppb, measured at the 95
percentile of samples, was proposed as a trigger for public
education.
The Agency is considering'promulgation of treatment
technique requirements which may include additional source water
treatment, lead service connection replacement, and public
education if lead concentrations at the tap exceed an action
level. Any such technological treatment targets will provide
substantial health protection. A final rule is being worked on,
and is scheduled for promulgation in December 1990.
DISCUSSION
No cancer potency factor or reference dose has been
promulgated for lead: therefore, an assessment of protective
levels of lead in ground water that may be used for drinking
water purposes will be based on current data. The Agency has
identified 10 micrograms per deciliter (ug/dl) as a blood lead
level of concern in young children. Blood lead levels above 10
ug/dl are associated with increased risks of potentially adverse
effects on neurological development and diverse physiological
functions.
Attached is available data that support the recommended
final cleanup level for lead in drinking water at Superfund
sites. This information includes the June 15, 1990, EPA draft
final report entitled, "Contributions To a Risk Assessment For
Lead in Drinking Water" and the June 1986, EPA draft final report
entitled, "Air Quality Criteria for Lead" (Volume III of IV, p.
11-129). Based on these data, lead levels in drinking water of
15 ppb and lower should correlate to blood lead levels below the
concern level of 10 ug/dl. The Agency estimates that steady
exposure to a water lead concentration of 15 ppb would
contribute, at most, 2-3 ug/dl to a child's blood lead. Sources
of lead other than drinking water (e.g. food, air, soil, dusts)
typically contribute approximately 4-5 ug/dl to children's blood
lead. Accountinq for the variability inherent
in childhood behavior, nutrition, and physiology, it is
estimated that total lead exposure, given 15 ppb in drinking
water, would result in blood lead levels below 10 ug/dl in
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-J-
roughly 99 percent of young children ~ho are not exposed to
excessive lead paint hazards or heavily contaminated soils.
Therefore, a I5 ppb cleanup level Nould provide substantial
health protection for the majority of young children. Most of
the remaining lead problem will continue to be contaminated
soils and old lead-painted housing.
In an April 10, 1989, Federal Register notice (54 IE
14316), EPA announced the availability of a guidance document and
testing protocol entitled, "Lead in School's Drinking Water," to
assist schools in determining the'source and degree of lead
contamination in school drinking water supplies and how to remedy
such contamination. That document, which is also attached,
recommends that schools take remedial steps whenever the lead
level at any drinking water outlet exceeds 20 ppb.
RECOMMENDATION
Based on a review of these and other studies, it is
recommended that a final cleanup level of 15 ppb for lead in
ground water usable for drinking water is protective. If water
used for drinking purposes subsequent to achieving the cleanup ~
goal in the aquifer may need further treatment to account for
lead contributions related to the distribution of water through
pipes, the responsibility for this additional treatment or the
replacement of lead-bearing water pipes lies with the persons who
are using or distributing the water. A concentration of lead of
15 ppb in drinking water should generally correlate with a blood
lead level below the concern level of 10 ug/dl. In some
situations, lower cleanup levels may be appropriate based on
site-specific factors, such as multiple pathways of exposure
caused by lead from the site.
If the remedial action will include treatment and supplying
water directly to the public for drinking water consumption,
compliance with a 15 ppb action level should be met at 90 percent
of the taps to ensure that the remedy is protective. When the
lead NPDWR is promulgated, applicable or relevant and appropriate
requirem8ft~ of that rule should be met.
FUTURE GUY DANCE
After promulgation of the lead NPDWR, guidance will be
issued discussing those provisions of the rule that may be
applicable or relevant and appropriate for Superfund actions.
For further information, please contact Tish Zimmerman at
FTS 382-2461 or Neilima Senjalia at FTS 475-7027.
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DISCU.IMER
The recommendations in this document are intended solely as
guidance. They are not intended and cannot be relied upon to
create any rights, substantive or procedural, enforceable by any
party in litigation with the United States. EPA reserves the
right to act at variance with these recommendations and to
change them at any time without public notice.
Attachments
cc: Directors,
Directors,
II
Directors,
VI, IX
Directors,
Waste Management Division, Regions I, V~ VII, VIII
Emergency and Remedial Response Division, Region
Hazardous Waste Management Division, Regions III,
Hazardous Waste Division, Region X
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APPENDIX C
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UNITED STATES ENVI~C';~1=:NTAL ?R07E:7!':.'" ~GCJCY
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MEMORANDUM
DATE:
July 18, 1991
SUBJECT:
Clean-up Levels for Lead in Sediments for the ILCO, Inc.
FROM:
Elmer Akin ~ ~&<\... ~
Health Assessment Officer
Jane Stone-Spann
RPM, ILCO, Inc.
Tbe Agency does not have standards or established guidelines or
criteria for any hazardous substance in sediment. The
development of sediment guidance is a current headquarters
project.
TO:
In the interim, the remediation of sediment lead at the ILCO
site may be addressed by one of two approaches.
The requirement for remediation of sediment lead levels, below
human health concern levels, to protect aquatic species could
be determined by site-specific toxicity tests conducted under
an approved work plan. If the test results were positive, a
judgement as to a site specific remediation level would be
required. If negative, no remediation would be required.
A second approach is to set a default clean-up goal that would
be protective of aquatic species based on published literature
values. Based on such a literature review, the GWTU in the
Water Management Division previously suggested a remedial goal
of 50 mg/kg for sediment lead at another region IV superfund
site. The 50 ppa limit appears to be resonable default clean
up level for the protection of fresh water aquatic species and
could be applied to the ILeO site.
cc
Bernie Hayes
Printed on Recycled PJper
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MEMORANDUM
D ATE: SEP 1 5 1;99
SUBJECT: Sediment Clean-up
Kos suof -Kimmerling
Goals for Lead at the
Hazardous Waste Site
FROM:
Ronald B. Landy, V.M.D., Ph.D.
Regional Toxicologist
TO:
David Abbott, Remedial Project Manager
Superfund Bra.nch
Through,
Rutherford B. Bayes, Chief
Ground- Water Technology Unit
This memo is in response to your request for a summary of the
information I presented. at the meeting with the State of Florida and.
the PRPs for th~s site on August 16th. As I have mentioned
repeatedly, the techniques for establishing sediment clean-up
criteria, especially when dealing with metals, are still under
development. The methocls being used for establishing clean-up goals
are under review by the Science Advisory Board and the Criteria and
Standards Office of the Environmental Protection Agency. The
guidance out of these two offices and the two laboratories focusing
on the relevant research issues associated with sediment clean-up
goals is as follows,
1.
Sed~ent clean-up goals must be site specific, i.e., one number
can not be chosen and assume.d to be appropriate for all sites.
Due to the complex che~ry of sediments, any. number derived for
a single site may be overly protective .or not protective enough
for other sites.
2.
Based on the chemical complexitie8 of sediments and the lack of
well v~ated methoclologies, bioassays are essential in deriving.
a realist:ic .concentration which is protective of the environment.
If bioas8ay. are not performed, it is difficult to derive a default
clean-up level. The re8ults of a survey of other agencies and their
respect~v. .ed~ment criteria reveals the following:
1.
The National Oceanic and Atmospheric AdmirU.stration has completed
a review of the literature concerning effects of contaminated
sed~ents. Based on 100 observa~ns reported in the literature.
covering a range of. effects, three -threshold - levels have been
establ~shed for lead in the sediment.
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2.
3.
4.
5.
-2-
30-50 ppm - Some effects in sensitive species could be
expected The lowest obser/able effect level was
27 ppm observed in a Daphnia bioassay.
> 100 ppm - Effects
assured.
in
sensitive
species
be
fairly
can
> 300 ppm - Effects
assured.
in
at
sensitive
least
species can be
50 ppm -
concentration at or below which biological
effects have been shown to be minimal (Chapman,
P.E., 1986. Sediment Quality Criteria from the
Sediment Quality Triad: An ~xample
Environmental Toxicology and Chemistry, vol. 5,
pp. 957-964).
50-300 ppm -
Separate approaches (sediment quality triad,
screening level concentration, apparent affects
threshold) to determining marine sediment
criteria yielded similar values for three
contaminants. (Chapman, R.C., Barrick, J.M.,
Neff J.M., and Swartz R.C., 1987. Four
Independent Approaches to Developing Sediment
Quality Criteria Yield Similar Values for Model
Contaminants, Environmental Toxicology and
Chemistry, vol. 6, pp. 723-725).
50 ppm -
Maximum allowable concentrations of contaminants
in Great Lakes sediments for beach nourishment
and in-water disposal in Wisconsin. Report of
the Sediment Subcommittee and its Assessment
Work Group to the Water Quality Board.
Procedures for the Assessment of COntaminated
Sediment Problems in the Great Lakes.
50 . ppm - Ontario Ministry of the
contamination criteria.
Environment
sediment
40-60 ppm - "Moderately polluted" according
sediment contamination criteria.
to u.S. B.P.A.
60 ppm - "Heavily polluted"
sediment criteria.
according to the u.S. B.P.A.
- Source: International Joint Commission, 1982.
Guidelines and register for evaluation of Great
Lakes dredging projects. Report of the Dredging
Subcommittee to the Water Quality Program
Committee of the Great Lakes Water Quality
Board. International Joint Commission.
Windsor, Canada, 365 pp.
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6.
< 83-100 ppm - Range of concentrations considered
pollution for the states of
Massachusetts, Connecticut, and New York.
"LoW"
Maine,
100-285 ppm -
"Moderately"
polluted,
> 200-285 ppm -
"High"
polluted.
Once again, it should be emphasized that tbe
sediment criteria is a relatively new and evolving
a consensus that concentrations must be
site-specific basis.
establishment of
field and there is
established on a
When using the numbers shown above, the souroe ar.d purpose of these
concentrations must be kept in mind. The ~rOAA review focuses on
marine environmen~s which may result in ve~1 different sediment
criteria, not necessarily applicable to f=eshwa~2r environments. The
dredging data (#5 and #6) is not firmly biologically based. Some of
it relates to average background concentrations and deviations from
background, i.e., a percent over background or 1-3 standard
deviations from background. Human health criteria, e.g., maximum
concentration limits, for drinking water is a190 a consideration in
establishing these levels in the Great Lakes. Chemical differences
in the sediment, e.g., sulfides, carbonates, organic carbon, can
significantly impact the bioavailability of metals and subsequently
result in clean-up criteria which can vary be 3-4 orders of
magnitude.
In conclusion, it is extremely difficult to arbitrarily pick anyone
clean-up goal for sediments and the state-of-the-art for predicting
/partitioning and biological effects is in a fairly nascent state.
However. in the case of Kossuof-Kimmerling, where there have '.~J)een'..
~-'_~.1'~iira . ~om8ct and . there is no data to support higher-
sedUient concentrations a ':.~_4ef!-U1~.:. ":t~u~_'.i_ot'~ 4Ct.-:,~O"'~ would be a
reasonable concentration basea on ~he literatu.oa ana the other
sources of sediment levels which have been mentioned. The specific
chemical factors mentioned above are a few of the factors which could
result in a decreased availability of lead, and ultimately, a much
higher leve1 of lead which would not have significant ecological
impact. However, siJDilar factors (e.g., very low levels of acid
volatile sulfides) could drive the level which would be protective
much lower.
In addition, other biological factors could come into play which may
impact sediment quality target levels. A review of four of the
approaches presently in use pointed out the following deficiencies:
-------
-4-
1.
Equilibrium Partitioninq Kodel
- assumes that equilibrium partitioning and exposure via the
water is the only significant pathway from the 8ediment8 to the
bio~a. Inqestion and dermal absorption trom s8di=ent is not
considered.
- assumes that equilibrium steady-state conditions exist in
aquatic systems.
- assumes that the water
sediment-free bioassays
systems.
quality criteria values determined by
have a direct application to benthic
2.
Screening Level Concentration
- requires a large database.
- the presence of a species at a site does not necessarily imply
lack of bioloqical effect.
4WM-GWP: LANDY: RLK: KOSS-KIH: 9-13-89: 3866
4WM-GWP
LANDY
4WM-GWP
iC/1t' ~. t5J5. t,/t(O
~S"Sq"1' -,CNt';t'j
7P""j7~" PL
AJPL s:~
M~~0
I ~,(
-------
;'~O n"J,,>
'0 ~
. .. -.
~. ... ~ ...
:~~
~ ~u' / ;
'. -J
, ..
... .,
~'. .-:1t..""
''';~i'7"!= .$7_~ 7!3
~~rr~C;'I.'yjE~~...l.:" ?~C-:-::':7~CN ..1.(;Z>C':'
::t:: :;:CM :'{
:.I~ :=\,;~~'_.',,,c S7~5:Z~
~~._~.'t~.~. ~C:CRC::;;" :O:S!
.:~_::~ :
c:"'..-o::: --:-,-..., .
~'-..;_w_--_.
?==;csa: === S~~~ent C:=~-~p Gca: a~
~~e=li~~ S~ts, ~am~a, ?:==ica
-:.::;'e 3::::.S3CU.::-
::~C}! :
Lau..=a E. )!a::anti, ~:l~li=::nment.al
G=~u.~d-~atsr Tsc~~ology wni~
Sci=n:=~.s~
TO:
Gail X. Vander~ocgt, Chisf
Ground-~a~er Tecr~olc~J Uni~
At t~e ~assouii-~~erling sits, the proposed cle=-~-up level fcr sad~en~s,
300 ~pm, was based upon t~e Fr=tsc~icn of human health fr~m t~e risk
assecia~:d with i~C'estion of contami~a~ed ma=sh sediments. It is f~~~er
ne~ed i~ the proposal that s~ch human ex;csure was considered to =e t~e
mcst si~i=ican~ haza=~ associated with t~e con~~~ated sec~en~5. ~e
telie~'e that aqua-:.ic species, -,.;ateriowl and ether ter=sstrial s;ecies t~at
utili~e the ma=~h for habita-:. and sustenance will te e~osed to
unaccepta=ly high levels of lead en a more frequent and-reason~le =asi3
t~"'n '...;" ",uma"" \..Q;-'-C:: C"""C:-"""s"''''-' _O"Q "';,.....~ ~;""""'c"" C.:: t'-c =...-os..-.".'--
4.--'. 7--~.~ ... J,.".--_.~-: ;"",r-"':=~Io8...~-_1 -..- W"-:----;----"... w. .L., .--:- 7.~::" ~-_. '---
a~a~~c ana ter=es~r~a~ s;ec~=~ ~s far g==ater t~an tr.a~ w~~cr. ~s
asscciated with h~~~ heal~h. Thus, t~e cl=an-~? goal fer sed~en~5
sh0':11d be set at a le~.7'el tllo:-t ~s as prot7ctive of the more sensiti"re
en~~ronmental rsceptors as ~t ~s protac-:'~7e of human receptcrs.
In absence of
the published
to:cicoloc;ists
and not cause
site-s~ecific 5e~~ent bioa35a~s, it is
literatur: anc ccnsult wi~h acUat~c and
to cete~ne the level of lead t~a~ can
chronic or acute toxicity to sens~ti7e
necessa=-J to
t~-...=c::--.; ",
-..--- "-----
==";":"=~N
remai~i~ se~~en~3
s;ecies.
Re~iew of the Literature
It is well-documented that waterfowl a:ld wadin~ birds will contact and
ccns~e sediment qritwhile feeding in wetland areas. The potential fer
the ex;osure of bLrds, in addition t~ aqua~ic s;ecies, to sed~ent =o~e
contami~~~ts via ingestion or contact is significant. Mucll of the
available literature relating lead toxicity to wildlife is based c~ s;e~-:.
lead shot in sediments. According to Pain and Rat~:ler (1988), t~e
acciden~al i:lgestion of sed~ent-borne l:ac shet kills 1.5 to 3.8 ~illi=~
waterfcwl each year in North America. While the effects of lead i~~es~i=~
are fairly serious in most wildlife s~eciest t~e ~~act can =e C=~7e i:l
o:-cutely sensitive species. Fer e:cample 1 blac~<: c-.:.cks appea= to fe
~ne:C;?licably susceptible to lead poiscni~g~ mu.ch mer: so than i~ =~~e=
tested wateriowl. In black ducks dosed wi-:.h cne *4 lead shc~, a 6J%
mo=tali':y '",as =scorded All dosed ~i==s e:thi:=i,:ed signs cf aC'.lts l.:ac
~o;scn~"''- ~v -~--c d,,~ps C. ~oc::a~e "nc'~' ~ '-~Q'~ 0.:: 'Q-~ '-e-o -'-'T~--~
~ - ---..,:: -- 1.....- =- "'..1 P \.-,- - ~ f ~.. ..._CC("A -=., --- ~ .J.._c,- N - - :.;..= - -~-
by 3 o-"'e-~ o~ ~"C"";"""~e '...~-'.,;.., ".1 ':10"-S .1-::",:.., ~,..~ Ra~"'-e"" '':33'.
-- -- - ~-_....-.,-....\..4 . -----... _.. .. \08.- . \ - ---- -...."--.. --.... -,.... J
~OOR QUALITY
'" ORIGINAL
-------
-
----
.: ::-=c 5~:==
.=.::c. :;: c .:..= -=!: ':'..-::;
---
=--..;'-
;:;::~:.:.==:~
-- -----
-= .....'::',.--
::.::.':-::=::
...-.-
:.~c ':'~..-.=
- -
:.~:.= -...:.:...:.
:.?.:.~..:::=:::-.=.
::::c.== :':C~i.:.~':"--::";:: ~::'::..la~!:
:::--
- - - ~
--"- -
-';a-=-=-=:-== ,
- -
:.~ f
::331
-~=-::7
.:~:~~~::.=s
0",.e=3
----
=-=='"':- - ::::
:.:: 9
--- -..---.. --
--....--- -----
.. -
-=:.c.-:~.:...::-==~
::~=-='::'~~=.:;
.~-z:-=-:: :'"..
::.::c.~: ~::'::S
-:.:-:a ~
==:"'_~==:-_:=
.. -
.. . .. .. .
==C<:.-.:::.=.':'--: ==-.=.-:'::-=-
"o;.e':'':'-: :~::c.c~.
====C~3
:.:.: -=
--
~:. =~l=.~-=C.
- - .. _.- -
--,;.;: 1-.:::
_=~i=_.s
--
:..: -
-- -
.. .. - ... ... . . . ... -.."-
!_--C-...-- :.::::1! - - -- ~~:;.;: =;=:e=~e!:-:.::c. -.;:- -:.--- :.:-= "~;:~'='-~:: :;y. :::=7:,,::-3:1 =? ':'7'='~: ..
:=~~ .=.~~.=.:'~= =:c.~e~~3 ~~ ~as ~e~::~~::ec. -:.~a-:. -:.~= :=:-::c~:a~ ~ec~a::.:.~~ --
:"=.=.c. ''::;:-:'.=.:~e i..:l -==::'Y=~:3h ',.;as ~:-:.=::\:~h c::n~.=.c-:' .=.c.sc=;-:.~cn t.::J t::e i..:l-:.e~.:.:'J.'::!~-:'.
_lc::...:=.-..::".=.-:.~:n e:: lead cn -:.::.e e::cs;ce2.et::n i...= li.:<=:7 t::J a£:ec-:. pr=c.a~::=3 cf
t;:e e==.',=~shi in -;;a::"'::"C'..l:a=, ~:::e :::cur..d laac. ::nav :::ec::me scl-.D:ii2.~::sc. ~.:1. ~ie
c.'~"-c::-::.Q ~-"'C- e;.C!l """c"c:n" ~"'Q e"'cs''''ei~-'''''n -0;""':""5 "'o'at~'.Q"r
____,,-_1- --- - 1_- '-.. ~ '-..-....'- --\".- --~~_.J. --- ..I__~
u~~~::es-:.=d. R=sul~s of tSese e:~er~e!l~s c.emcns~=ate the reis
ccn-:';~:":la~ed sediznen~s pl'='7 as 7.c::~ti~:cUS s~u==e.o~ heavy meta~s ~~
-cu---- ~,~-'" ~V~!l a--~'" ccn"'am'''''at'-n ---m ~~e c-'c'na' sou--: ~-s
c.-. c:.:-~- .""'--'-:- - -:- .:.._--" ... -'-'''.'''''' ."'-: ."'. ""-..-.~. ~...- ...c:.
s~;.:.~e~. -~sc c.emcns~=~-:.ec Has t~e s~~~f:-=~ce t.:la~ c.~=ec~ c=n~:c~ H~:'~
c=n~~~:lated sed~e!l~s has i:l causing fotentially delstericas e:c;cs~=es to
a~~a~~= c=;auisms and ~==cat=rs.
:.:1..7 :;35 ~~~7Y by P7t==.c~af~an, cc~pa=::,~~"e ~n',~~~~~ent~~ dat.=. f==m
--r- ---- c-ezn' ---, ,.... s- -" :\' -"'ct:a~-o'''''cv ""'c -er.:.:nen- ,.., c-<:---'s --as
;:C:_~=--': . ---'.-"''''-- ~ --- . -~.... ..7'::'" ~ -... "''':'~.' -: .::. -". ... -- c._~Q,':' .~
=~;~~7:-=- ~= c.e~e~~~e ~~e sec~en~ qual~-:'7 c=:-te=~.=. !== seve=;~
a!l-;:'==:-_"'."le!:~.=.l cont.:.:ni!la~~s, i:1cl'.ldi:lg laaci. I':. 'lias est.ablished t:la-:.
~~~~.=.l bi=:=gica: 9=:::C~~ could =e an~ici..;ated i:'l sed~ents c::nt.=.i.:li:lg
~==s -:.~~n 50 ;pm lead; ~ed~ents wi~h ;=e.=.te= ~ha~ 130 ppm lead ~c\::d:
ca~s: =a~c= =~=:=c::..=al e==ec~s (=es~i=::'~=~T =e~==ss:..on, mitc~:..c
.. .J .." . .' ~ -. -. ..
~e==~~~ons, l~ver l=s~=ns, c.eatn) ~n a~a-:.~c s;ec~es. The aut~c=
ca\:t:..:~s t::a':. c=nsicera~i~n should ce give!l to the synergistic or
c::m;c::.:-.d~:lg effects t::.a-:. ccmpanion contaminants :D.ay ha"e upon the t::d=:.~:r
cf a ;:,,',e!l. i::c.:..vic::.al c=::~aminant. It is fcssi~l= that a partic-..:l.=.= NCE:'
=== c::e cCffi;c\:~d way o~:~ be pr::Jtecti7s (appli=~le) as a c=ita=:..a Hhe!l
e~::.e= :::r:.-:..:..-:.:..::a:1ts do ::::-:. e:cceed their rela-:.ed NCZ::'S. in that syste~.
Adc.~-:.::.::r.al ~=u=~al ar-:.icl~s, while not s~ecificallv referenced i:l this
dis::::.=~:..=r:., -Ne== usec ~:: c.ete~ine the risk associated with sed~er:.t-bc~e
l=a~ -- a~a-:.i7 ~~d ter==~trial s~7cies. The w~rk disc?ssed in ~~e:e
ar~~.:_::s a~.3= ~::.c.:-=at=d ,:.-.at a sec..l.:!1ent lS'Tel o~ lead tnat e:cceec.s :0 f~:n
ccu:~ =es::.lt i:l ac.verse .~~acts to aauatic life. Those articles are
ref===r:.ced along ~i~h the others in the bibliography and are available
u;o:: ==ques~.
5ec~~=~~ C=i~a~ia
..:,....~
--'-
Lead
}~ ~~~="..:s3ec a~cve, t~e c=nse~e!lces cf lead e:~osure and ingest~e:: ;=:
3e=:..=::.~ :":1 a~~.=.~i= and ~a==es~=~al species, a::.d thus the clea!l-~p cr l=ac
ccr:.-:'~~~::.=.-:.=c. sec.~ent~ t:: levels that are protecti7e of such sfeci::s
s~--c::.:"~ :::e ~:"7=!l ;:=~:na=-.! -=:::lsicerat~cn L'1. the de'Tslopment of r=!!",ec~~l
;::.a=~a-:.i-;es. 3asec cn t~= li::erat~re r:view and d~sc~ssions wi-:.i a~~a-:.~=
~::.c. :.e===s-:.=~a: =cclcg~sts :::cth i!l ;nd cutsi~e t~e Agency, ~e ==c:z=.er:.c.
:.~a:. ~::e sec.~-:.e!:~ c~=a~-~;: ;cal fer lead ~e est~l:..shed at 50 oJ ~p:n.
eooR QUAUP(
, ORlG\NAl
-------
-3l
S~~a-==ec~t~c (?=el~i~a~~) C=st
We =ac::mmend t:"la~ the surficial sed.:..:nen~~ (ap-.:r::x.:..:nata2.:r 5 i::c~es J ::e
=amcved i~ t~cse areas where the laad c::nt=n~ exceeds 5J - 60 ~~m.
A<::;:Ull1i:tg -t:lt:: 'Ncrs~-case scenario (that Remedial Se5i.;It sampli:tg - indic.3.~=s
~he en~ire wetland area exceeds this level), appr::x~ately 705 c~ic yards
would need to be excavated. The area of sedDnent in the marsh was
est~ated from maps contained in the Remedial Investigation, t~e scale of
which was not exact. The cost of excavating marsh sedLments to this level
is approxLmately $35,250.00. (The cost of sediment excavation per cubic
yard was obtained from the Feasibility Study.) Under the original
proposal, 1056 cubic yards of sediments are to be excavated, resulting in
a higher removal cost of $52,800.00. It is apparent that the clean-up
goal for lead recommended by the Agency is both economically feasible and
enviror~entally sound.
POOR QUAUT'<
. OR'G'NAL
-------
i'JHJP TT-V.——
OOODQOOOOODOOOD
LJU U lj'«"'"'u"» ruMimti UUU
tfOINO
AFFflOIIMATf IHtlMfAOl IITMEIN IAHD AHO WAKH .
• UONItONINO Will LOCATION /
* fit 10MITIH IOCATIOH !
• »TAPf OAUOeLOCATION
/
/'
t
"••-/• —
0 ••'" 18
m*a****m
nil
KK-«
'S
~-» t«fH.IIMIT lAnoriii tin
TAUFA. riomoA
LOCATION OF MONITORINO WELL »
SURFACE WATER STATIONS
053—
•South, Int.
riaunc
3.3
f\-
ft
7-
S c«/l'»< O
-------
I
~[:
Leigh Pegues, Director
1751 C.,ng. W. L.
Dickinson Drive
Montgomery, AL
36130
205/271.7700
Field Offices:
Unit 806, Building B
225 Oxmoor Circle
Birmingham, AL
35209
205/942-6168
P.O. Box 953
Decatur. AL
35602
205/353-1713
2204 Perimeter Road
Mobile. AL
36615
205/479-2336
:M
ALABAMA
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
September 24, 1991
Ms. Jane Spann, Remed1a1 Project Manager
South Superfund Remed1a1 Branch
USEPA Region IV
345 Court1and Street, N.E.
Atlanta. GA 30365
RE:
ILCO Superfund Site - Leeds, Alabama
Record of Decision
Dear Ms. Spann:
The A1abama Department of Env1ronmenta1 Management, after
review, concurs with the above Record of Decision (ROD) as
drafted, dated August 6, 1991. Thank. you for pointing out
the contractor's miscalculation concerning the cost of
remediation at the park.1ng lot.
It is our understanding that supplemental sampling will
be accomplished during the Remedial Design to verify the
extent of contamination at each subs1te. This should be
requ1 red due to the d1 fferences noted between XRF and CLP
soil sample values in detected lead leve1s.
Please be advised that concurrence with this ROD does not
bind the STATE contractually to matching requirements under
Fund Lead remediation. If this Lead is followed, the
department would approach the Legislature to request funds to
meet the fisca1 matching requirements concerning this site.
s:f\ere 1 Y .
~~Z:~
Special Projects
-
JEM/jm
. -,34 t,
-'. .,
...-
,:"(.,......... ~
: 'r _'t
Guy Hunt
GO'lerno.
-------
Material Safety Data= Sh'eet ~p ~o. 31 i
Genium Publishing Corporation TOLL~r:
114S CaW)'Il Street (Revision D)
Schenectady, NY 12303-1836 USA Issued: August 1979
(S18) 377-885S. GIM\8~~. Revised: Anril 1986
SEcnON L MATERIAL IDE~TmCATION 20
\iATnIAL NA~: TOLUENE HMIS ~
rTT"m='R DFS1GN" ,"ONS: Methyl Benz.ene. Methyl BenzoL Phenylmethme. TolllOL H:2
F: 3
C7H3. CAS 110108-38-3 R:O
\1:ANtJFi\CTl.TRERiSL'PPUER: Available tram mmy supplien. i:Dcluding: PPE.
.See sect. 8 R 1
Allied CArp.. PO Box 2064R. Morri.stoW'Q, NJ 07960; Teltphone: (201) 455-£400 I 3
Ashlmd Chemical Co.. lnc1usuial Chemiuls & Solvmts Diy.. PO Box 2219, S 2
Columbus, OH; Telephaae: (614) 889-3&44 K 4
SECfION 2. INGREDIENTS ..\.~1) HAZARDS ~ HAZARn n~TA
Tolu.cnc caloo &-iIr TL v: 100 ppm. or
CH) 375 qim3. (Skin)..
6 MID, 1nhaW:ioa. TCI.D:
100 i'Pm: P~h~ic."
. CuIm21 (19&5-86) ACGIH TL V. The OSHA PEL is 100 ?pm with an Ras. Oral. LDso; Sea> Ini"k&
acceptable ceilin& coacen~ of 300 ppm aM aD ac.ceptable Ru. ~ LCLo:
mv;...um peak of SOO 1'1'11)'10 minuteS. 4000 ppmt4 In.
.. SkiD dcsipDDD illdi.c:ala that toluene W1 be absorbed through intaCt 1U.bbit. Skm. LD5O: 14 P'k&
skiD md c:onaibut& to OYcr11l exposure. -
... AtfeclS!he mind. Humm. Eye: 300 ppm
SECTION 3, PHYSICAL DATA
Boilini Poim... 23l'F (lll'C) EYIpCf1EIDD Rile (BuAc . I) ... 2..24
Viper PressIIR @ 20'C. mm Hg - 22 Specific GnvUy (H20. I) ...0.866
WaJJ:r Solubility @ W'C, \Nt. ~ ... O.OS Meldn& Point - -139"F (-9~'C)
Vapor Deasity (Air . 1) ...3.14 Pm=I1 V ol&tiJe by V olumc - ca 100
Molecullr Wei&h1- 92.15
Ap~ and odar: Cle8', c:o\orlalliquid wUh I ch.ancteri.s1:ic aromatic odor. The odor is det&cuble to most illdivi.du.a1s in
the f'IZ!P of 1010 15 ppm. BecIlUC olfactory fatigue occun ~idly upoD exposure II) tolllCDC, odor is DOt I 800G wlming
propc:ty.
S"I TIlIN 4. Fiitl" AND EXPLOSION DATA <,. LOWER UPPER
.
Flash Point and Medlod Aucoigniaoo Temo. I flammability Limia In Ajr
4O'F (4"C) CC 896"F (480'C'I I ~ bv Volus 1.27 7.1
FXI1NGU1SHING MEDIA: CartIo1I c1ioXJdc. Ory chemical. alcohol f~ Do DOC II.IC .lOlid saum of Wlloer bec.a&uc In: scum
will scaa.c:r IDCi sprud!be fire. Use wlIa' spray to cool tmk3Ic:onWDm IhU are e~ to fire aDd to dispenc vapors.
lJNUSUAL FlRI:~T n.~ON H&7ARDS: This OSHA clasalB flamIIW)le liquid is I d.mgcrous fire haunl It is I ~t£ fire
hazazd we. uposai II) cWdizcn, bc&I. spen. or opeD flame. Vapors are heavier thm air md may mil c:.cm.s:idcnble
c1isLmce II) III ipiSiDD lDurce IDI! !!a:;h back.
!\P~C1AL FIR~.RGJ.mNG PRocmU1tEs: rIR fighrm shoWci We8' selt
-------
..i=i~~:,L]~j-=7""'I'l.: 1:-.
~'JP:)u,.:)-.\r~ ~2S,Jr;UT1;.{",rr'1 ~.)L:" ":~':,::n.;~: ..\"40 ::o=~"'T,='J r.-. ?~=:~'J~::-;-:
GQ JTH~~ o~SITIV= ,J~~ssu~~ ~GJ~ [~ CJ~~r~ATtJ~ ~~T~ ..\~ iU([L[i~Y
:~~F-CuNTAINEQ 8~EATHI~G ..\,Jp~~~rJ~ l?=~AT~O ~~ P~~SSU~E-Cc~A~~ ;~ Jr~"
P~SITIYE PReSSURE MOCE.,
":'L-.~T~r'4t;: , '
:1oI?LJ'f.:=7 ~usr ..EAR APPROP~I~T:: ;I,'r-:..:.r~,,-: lI"I?-::)'L1)'~} CLH~r"',:; ..'j"';
f~I' JKcl::,...T ~i:p=Ar=~ ,JR P~OL1,"''i=J SQ'4 ;:"'cT\Ci ..rL1 r~[s S,Lq~'4C=.
-:;ur~"-:'I~
r'
,..:..J'I':<;:
~"'''I_jv=,:: IoIJ~r
:J'J-' 3 r4'.c~.
..:U ..\,JP".J?'HAf-: :>:(,'~TEcr['c ~L....J.:<; Tj PJ,::'I='IT C;'d..\':T ",:T,...
r...; ~ ;
-:1:; ::'J JT=c.rr~'j: ,
;:",JL-'f~:: "'Ij:;f "C::~Q, S;:L"\:r1-?~C')F j'~ ';..;.;r-,,-:j!5r..',r ~..\F::ry r;u';vL:::S r~
:;;.'f-=. .:nT..r::f ..rrH f-1£) :j'J:J<;r..\~r::;:. CJ'H..\CT L;:'ISES ';~'jUL') ~,H ~= ,,'l~',.
J/::;,.:';r
~JT~u~r:;~ - =I5~::~
c~.:..\rL'J ~AT:: 1')/.:5/'34
;C: ::'iT P= II:
~=JI~[1N )Ar~: 01/10/dQ
------------------------
r~~ ~~~'I= [~~0~IoI~Tr'~ lS ~~LI~V~J TJ 1E ~CCUq'T~ ~~o ~~P~=3=~TS THE 8E~T
l'IF;-~"'~rro~ C')~~="rLY ~,,~rL~jL- T'J us. ~J)..,:'Ir:Q, ..c: "~K2 ,','1 oo/A~RANTY OF
~~~CM~~rA~rLrTY ~~, A~1 ~T~~o ~AR~A~TY, ~,P~~SSE) ~~ r"PLr~0, ~ITH RESPECT T:
3fJC'-j r'ff=u""",H[J~, ~"'J ...:: ASSu~e:: ,~O lr~DrLrry ~t:5ulrrlllG ~';G,"4 :rs USE. USi:RS
j'-i,j'JL') "'~I(,; r'-id~ jf4N l..,v=:>TrS.ATlfJNS T) ;)cT::~."'I~E TH:: SUIT~~ILITY OF TH':
{~FJ~..~r:l~ FJ~ rHEt~ ~ARTrCJLA~ °U~PGS~S.
~~\I
~LwL.
(I L~D-)JA'- qi~' ~ i
,.." Q' U/~\'
eOOR '. r,.>..,\;, ,
, "G' "N" ~
QR' ~ 'r;, ~
~--"-"----.----,
... '-_.-.~
-------
Material Safety Data Sheet ~p ~(\. 3.3
From Geniurn's Reference Collection XYLE~E I\tixed 1<;0mcr<;)
Genium Publishing Corporation
1145 CatJlyn Street (lh:..I...ItIlII))
S~henectady, NY 12303-1836 USA I....ued: :-';ovcmber 11)80
(518) 377-8855 CENIUM 'UILISHINC COR'. Revised: August 1988
SECTION 1. MATERIAL IOENTIFICA TION 2(
:'-1..lerl... Name: XYLENE (Mixec1lsomcrs) V
Ueseriplion.( Or.llia/Uses): Usec1 as I raw malCrill for the productJon of benzoIc aCid. phthalic anhydride. isophthalie
and terephthalic acids Ind their dimethyl es~1'1 in the maaufacture of poiyes~r fiben; In 5lCnll7.lng catgut; with
Canadian balsam as ou-irnmcl'1ion In microsc:opy; and a.s a cleaning agent In microscopic lC~hnlquc~.
Olher Uull:nllIIQn~: Dimcthylben7~nc; Xylol; C,H.; CAS No. 1330.20.7 . :\1-"1'\
.\hnur..clurer: Cuntacl your supplier or distnbutOr. Consult the lateSt etlllJon or the ChemaL'a/wed. H'.IIS
lJ"yers' G"lde (Genium rd. 73) for I USI of suppliel'1. H :: R '
Comments: Although there are lhree diUcrent isomen of ~ylene (orrJo.o. "It!ra, and para). the health and physical F 3 '
hazards of alllhree isomers are yery sImilar. This MSDS is wTlllen for a ~ylene mI~lUre or all three I~()mer~. R 0 I 3
which is usually commercial xylene. PPGO S '
-
'See see:. 1 K ~
SECTION 2, INGREDIENTS AND HAZARDS % EXPOSL'RE LI\t ITS
XyLene (Mixed Isoa1eI'1), CAS No. 1330-20-7. .. IDLHu. Leyel: \000 ppm
°o-Xylene, CAS No. 0095.47-6 OSI!.\ PEL
m.Xylene, CAS No. 0108-3g-3 8.HrTWA: IOOppm,J35 rr.g m\
p-Xylene, CAS No. 01Q6.42-3 .\CC;III TLV~, 19R7.RR
"Check with your supplier to delCrmine if there arc addilions, conLamlnanLS, or TL V :I"W A: 100 Pl'm. 435 m~'m'
impurilies (such as benzene) thai are presenlln reporLable quanllties per TLV.S'( EL: 150 ppm. 655 mg:m'
29 CFR 1910.
.-Immediately dangerous to tife and health. To'Ciclty Dau""
.... See NIOSH, RTECS (No. ZE2100000), for additional daLa with referen~s Human, Inhalation, TC,.. :00 ppm
'.tan. Inhalallon. LC,.. 10000 ppm. 6 flr~
lo reproduclive, irriLalive. and mULagenic effecls. RJt. Oral. LD.o: J30U mg!kg
SECTION 3, PHYSICAL DATA
80illng Point: 275'F ID 293'F (13S'C ID 14S.C)8 Waler Soluhllily (%): Inmluble
'hltln2 Folnt: -13'F (-ZS.C) .\lulrcula.r Wcl~ht: I ,It) c.;ram~'Mule
Eyaporatloa Rate: 0.6 Relative ID BuAc . I <;, Volatile by Volume: Ca 100
Specific GrlYlty (HaO = 1): 0.86 Vapor Pressure: 7 to Q Tom al6S'F I:O'C)
Vapor Den~ity (Air = I): 3.7
Appearance and Odor: A clear liquid; aromatic hydrocarbon odor.
o~aLeriais with wider and aarrower boiting ranges are c:oaunercially available.
SECTIO~ 4 FIRE AND EXPLOSIO~ OA TA LOWER l'PPEI{ :
Flash Point and Method Autoignition Temperature Flammability LimitS in Air
81'F to 90'F (27'C 10 32'C) 867.F (464'C) ~ by Volume 1% ~~
Extlngulsblns ~edla: Use foam, d.ry chemical, or carbon dioxide. Use wa~r sprays to reduce the ralC or burning and In cool C(lnlalner~.
Unusual Fire or Explosloa Huards: Xylene vapor is hcavier than air and may travel a c:onsiderable dislance ID a low-lying source of
ignition and nash back..
Special Flre.nabtln, Procedures: Wear a se!f-c:onLained brealhing apparalus (SCBA) With a full fa\;epiece operalCd In !he prcs.~ure-
demand or positive-pressure mode, I
SECTION S. REACTIVITY DATA
Xyleae IS sLable in closed COOLaUlCI'1 during rOUlU1e operalioos. Il does nol undergo haz.ardous pol)'mcTlzalion.
Chemical IncompatibilitIes: This material may rCal:l dangerously with strong oxidizcl'1.
Conditions to Avoid: Avoid any exposure 10 sources of ignition and to strong oxidiz.crs.
Hazardous Products o( Decomposltloa: Carbon moaoxide (CO) may be eyolved during xylene fLl'es.
C"","I/IIO 198. OeftItolll .....-. CGf!oonI-
Aft, ..-.... - Of rrp..- .._Il1o"""""1 -- .,....,.".....
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