PB95-964002
EPA/ROD/R04-95/192
November 1994
EPA Superfund
Record of Decision:
Interstate Lead Company,
Leeds, AL,
10/13/1994
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECnON
FOR
OPERABLE UN" TWO
AND.
AMENDMENT TO RECORD OF DECISION
FOR
OPERABLE UN" ONE
INTERSTATE LEAD COMPANY (ILCO) SUPERFUND SITE
LEEDS, JEFFERSON COUNTY, ALABAMA
PREPARED BY
U. S. ENVIRONMENTAL PROTECnON AGENCY
REGION W
A TLANTA, GEORGIA
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DECLARATION
of the
RECORD OF DECISION
for
OPERABLE UNIT TWO.
and
AMENDED RECORD OF DECISION
for
OPERABLE UNIT ONE
SITE NAME AND LOCATION
Interstate Lead Company (ILCO) Superfund Site
Leeds, Jefferson County, Alabama
STATEMENT OF BASIS AND PURPOSE
This decision document (Record of Decision) presents the selected remedial action for
Operable Unit Two of the !LCO Superfund Site in Leeds, Alabama and documents
fundamental changes to EPA's previous September 1991 Record of Decision for Operable
Unit One. The selected remedial action was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended, and to the extent practicable, the National ContingenCy Plan
(NCP) 40 CFR Part 300. .
This decision is based on the administrative record for the ILCO Superfund Site.
The State of Alabama has concurred with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the ILCO Site, if not
addressed by implementing the response action selected in this ROD, may present an.
;mm;nent and substantial endangerment to public health, welfare or the environment.
DESCRIPTION OF SELECTED REMEDY
The ILCO Site is divided into three operable units. Operable unit one was defined in the
Record of Decision that was signed by EP A on September 30, 1991. Operable unit one
includes soil, sediment, and ground water cont.$lmination at the seven satellite sites
located ill and around the C!ty DfLeeds. Operable unit two, which bgnumerated by this
Record of Decision, includes soil and ground water contam;n9tion at the !LCO Main
Facility. Operable unit three will address the surface water and sediment cont~mination
attributable to the !LCD Main Facility. The selected remedy for operable unit two and
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. " - .'
the modified remedy for operable unit one call for the design and implementation of
response measures which will protect human health and the environment.
The major components of the selected remedy for operable unit two include:
.
Conduct a Site-specific field-scale treatability study to determine the
effectiveness of the acid leaching process on the types of soil at the ILCO
Site during the design phase;
.
If the treatability study concerning the acid leaching of cont.Hm;nated soil
and other waste fails to meet the required performance standards in a cost-
effective and timely manner, Alternative S-3, Solidification/ Stabilization,
will be implemented;
.
Excavate contslm;nated soil, treat soil to established performance standards
onsite by acid leaching, if determined to be effective during the treatability
study, otherwise treat soil to established performance standards onsite by
solidification/stabilization;
.
If acid leaching is implemented, backfill excavated areas onsite with treated
(i.e., clean) soil. If solidification/stabilization is implemented, dispose of
treated (i.e., stabilized) soil in an onsite engineered containment cell and
backfill excavated areas with clean fill. Grade and revegetate excavated
areas once backfilled;
.
Decontslm;nateltreat debris using specific best demonstrated available
technologies (BDAT) based on the type of debris and the type of
cont.Hm;nants present in the debris; recycle decontHm;nated debris that can
be recycled and dispose of deconwm;n9ted debris that cannot be recycled
offsite in a non-hazardous landfill; debris which cannot be decontHm;nated
will be disposed offsite in a permitted hazardous waste landfill;
decont.Hm;nate any rem~;n;ng buildings and/or structures onsite;
.
Package and ship slag that can be recycled to an offsite permitted facility for
recovery of lead using a secondary smelter; non-recyclable slag will be
solidified/stabilized and disposed offsite in a permitted hazardous waste
landfill, if acid leaching is implemented; if solidification/stabilization is
implemented, non-recyclable slag will be solidified/stabilized to pass the
Toxicity Characteristic Leaching Procedure (TCLP) test and disposed in the
onsite cont.H;nment Cell;
.
Package and ship battery casing components and battery chips that.can be
recycled to an offsite permitted facility for recovery of lead using a secondary
smelter; non-recyclable components that fail TCLP will be disposed offsite in
a permitted hazardous waste landfill and non-hazardous, non-recyclable
components will be disposed offsite in a non-hazardous landfill, if acid
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leaching is implemented; if solidification/stabilization is implemented, non-
recyclable components will be solidified/stabilized to pass TCLP, if necessary,
and disposed in the onsite containment cell;
.
Send roll-off boxes of baghouse dust (K069) offsite to a RCRA permitted
Treatment, Storage, and Disposal (TSD) facility. Teatment and disposal of
the baghouse dust shall comply with all pertinent ARARs, including Land
Disposal Restrictions (LDRs);
.
Monitor air emissions from OU-2 during remedial action activities;
.
Conduct additional ground water investigations on operable unit two during
the design phase to fill data gaps and determine the technical practicability
of restoring the ground water aquifer to its beneficial use;
.
Pump contaminated ground water from the shallow, intermediate, and deep
zones of the aquifer, where technically practicable, using a ground water
extraction system of trenches and wells;
e
Treat the ground water contRminated with inorganics to established
performance standards via precipitation/flocculation using the existing onsite
water treatment plant (with necessary renovation), if available;
.
Segregate ground water in the shallow extraction system from the
intermediate and deep ground water for treatment of both free phase and
dissolved phase hydrocarbons. Shallow ground water will pass through an
organics treatment system before entering the treatment train for inorganics
shared with ground water extracted from the intermediate and deep zones;
.
Discharge treated ground water emuent, meeting applicable requirements,
to the nnnHmed tributary adjacent to the ILCa Main Facility; and
.
Implement institutional controls, as necessary, for both ground water usage
and land usage at aU-2.
-J.'he major components of the amended remedy for operable unit one include:
.
Excavate contaminated soil with lead concentrations exceeding 300 mg/kg;
.
Excavate and dewater sediments at the Gulfi'BP Service Station with lead
concentrations exceeding 50 mg/kg;
Transpvct all contHminated soil and dewatered sediment to th~ ILCa Main
Facility for treatment by acid leaching (or solidification/stabilization if acid
leaching does not meet performance standards during the treatability study);
.
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.
Remove slag, battery casings, and other conVlmin~ted debris from the
satellite sites and transport to the ILCO Main Facility;
.
Package and ship slag that can be recycled to an offsite permitted facility for
recovery of lead using a secondary smelter; non-recyclable slag will be
solidified/stabilized and disposed offsite in a permitted hazardous waste
landfill, if acid leaching is implemented; if solidification/stabilization is
implemented, non-recyclable slag will be solidified/stabilized to pass TCLP
and disposed in the onsite containment cell at the ILCO Main Facility;
Package and ship battery casing components and battery chips that can be
recycled to an offsite permitted facility for recovery of lead using a secondary
smelter; non-recyclable components that fail TCLP will be disposed offsite in
a permitted hazardous waste landfill and non-hazardous, non-recyclable
components will be disposed offsite in a non-hazardous landfill, if acid
leaching is implemented; if solidification/stabilization is implemented, non-
recyclable components will be solidified/stabilized to pass TCLP, if necessary,
and disposed in the onsite containment cell at the ILCO Main Facility;
.
.
Decont~minate/treat debris using specific best demonstrated available
technologies (BDAT) based on the type of debris and the type of
contamin~:mts present in the debris; recycle decontaminated debris that can
be recycled and dispose of decon~min~ted debris that cannot be recycled
offsite in a non-hazardous landfill; debris which cannot be decon~min8ted
will be disposed offsite in a permitted hazardous waste landfill;
deconVlminate any rem~ining buildings and/or structures onsite;
.
Backfill excavated areas at the ILCO Parking Lot with treated (Le., clean)
soil from the acid leaching process (or clean fill if solidification/stabilization
is iinplemented instead of acid leaching);
.
Backfill excavated areas at the .other satellite sites, excluding the City of
Leeds Municipal Landfill, with clean fill;
.
Revegetate excavated areas once backfilled;
.
Temporarily relocate Connell Property residents and Acmar Church of God
congregation, if necessary; and
.
Monitor air emissions from the satellite sites during remedial action
activities.
EPA is not amending the selected OU-l soil (source) remedy for the City of Leeds
Municipal Landfill or any of the selected OJJ-l ground water remedies.
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STATUTORY DETERMINATIONS
The selected remedy and the contingency measures for QU-2 and the modified remedy
for QU-l are protective of human health and the environment, comply with federal and
state requirements that are legally applicable or relevant and appropriate to the
remedial action (unless such requirements are waived), and are cost-effective. The
selected remedy for QU-2 and the modified remedy for QU-l satisfy the preference for
treatment that reduces toxicity, mobility, or volume as a principal element. Finally, it is
determined that the selected remedy for QU-2 and the modified remedy for QU-l utilize
a permanent solution and alternative treatment technology to the maximum extent
practicable. A review will be conducted within five years from commencement of the
remedial action for ground water and for soil, if the contingent remedy is implemented,
at OU-2 and for ground water at QU-l to ensure that the remedy continues to provide
adequate protection of human health and the environment.
~/11~
r John H. Hsmkinson, Jr, Regional Administrator
/O-/3-Q4
Date
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TABLE OF CONTENTS
RECORD OF DECISION FOR OPERABLE UNIT TWO
ILCO SUPERFUND SITE
1.0 SITE LOCATION AND DESCRIPTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
2.0 SITE HISTORY AND ENFORCEMENT ACTMTIES . . . . . . . . . . . . . . . . . . " 5
3.0 IDGHLIGHTS OF COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . . . . .. 6
4.0 SCOPE AND ROLE OF OPERABLE UNITS ....... . . . . . . . . . . . . . . . . . . .. 7
5.0 SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . '. 8
5.1. Landforms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8
5.2 Surface Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8
5.3 Geology'[[[ 8
5.3.1 Regional Geology' ..................................... 8
5.3.2 Site-Specific Geology' and Soils. . . . . . . . . . . . . . . . . . . . . . . . . .. 9
5.4 Ground Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
5.4.1 Regional Hydrogeology' . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' . . .. 9
5.4.2 Site Hydrogeology' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 10
5.4.2.1 General Conditions. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 10
5.4.2.2 Ground Water Movement Patterns. . . . . . . . . . . . . . . . .. 10
5.4.2.3 Ground Water Gradients. . . . . . . . . . . . . . . . . . . . . . . . .. 11
6.0 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11
6.1 SELECTION OF CHEMICALS OF POTENTIAL CONCERN. . . . . . . . .. 11
6.2 HUMAN TOXICITY ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11
6.3 HUMAN EXPOSURE ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
6.4 HUMAN RISK CHARACTERIZATION. . . . . . . . . . . . . . . . . . . . . . . . . .. 13
6.5 RISK-BASED REMEDIATION GOALS 20
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7.0 DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 22
8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . .. 28
9.0 SUMMARY OF SELECTED SOIL AND GROUND WATER REMEDIES. . . . .. 35
10.0 STATE ACCEPrANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 47
11.0 COMMUNITY ACCEPrANCE ..................................... 47
12.0 STATUTORY DETERMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 47
12.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT. . . .. 47
12.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs) . . . . . . . . . . . . . . . . . . . . . . . . . .. 48
12.3 COST EFFECTIVENESS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 52
12.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM
EXTENT PRACTICABLE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 53
12.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT. . . .. 53
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . . . . . . . . . .. .. 53
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LIST OF FIGURES
RECORD OF DECISION FOR OPERABLE UNIT 1WO
!LCO SUPERFUND SITE
FIGURE 1-1, SITE LOCATION MAP .................................... 3
FIGURE 1-2, SITE LAYOUT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 4
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LIST OF TABLES
RECORD OF DECISION FOR OPERABLE UNIT TWO
ILCO SUPERFUND SITE .
TABLE 6-1, ORAL TOXICITY CRITERIA FOR THE CHEMICALS OF CONCERN
OTHER THAN" LEAD ................................................ 12
TABLE 6-2, EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION OF AND
DERMAL CONTACT WITH CHEMICALS IN SURFACE SOIL, CURRENT LAND-USE
CONDITIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
TABLE 6-3, EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION OF
AND DERMAL CONTACT WITH CHEMICALS IN SURFACE SOIL, FUTURE LAND-
USE CONDITIONS: COMMERCIAIJINDUSTRIAL SCENARIO. . . . . . . . . . . . . .. 14
TABLE 6-4, EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION OF AND
DERMAL CONTACT WITH CHEMICALS IN SUBSURFACE SOIL, FUTURE LAND-
USE CONDITIONS: COMMERCIAUINDUSTRIAL SCENARIO. . . . . . . . . . . . . .. 15
TABLE 6-5, EXPOSURE PARAMETERS FOR INGESTION OF CHEMICALS IN
GROUND WATER, FUTURE LAND-USE CONDITIONS: COMMERICIAIJ .
INDUSTRIAL SCENARIO. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 15
TABLE 6-6, EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION OF AND
DERMAL CONTACT WITH CHEMICALS IN SURFACE SOIL, FUTURE LAND-USE
CONDITIONS: RESIDENTIAL SCENARIO. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 16
TABLE 6-7, EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION OF
CHEMICALS IN GROUND WATER, FUTURE LAND-USE CONDITIONS:
RESIDENTIAL SCENARIO. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . .. 16
TABLE 6-8, COMPARISON OF LEAD CONCENTRATIONS IN ENVIRONMENTAL
MEDIA AT THE ILCO OU-2 SITE TO RELEVANT CRITERIA. . . . . . . . . . . . . . . .. 17
TABLE 6-9, SUMMARY OF QUANTITATIVE RISK ESTIMATES FOR POTENTIALLY
COMPLETE HUMAN EXPOSURE PATHWAYS UNDER CURRENT LAND-USE
CONDITIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17
TABLE 6-10, SUMMARY OF QUANTITATIVE RISK ESTIMATES FOR ADDITIONAL
POTENTIALLY COMPLETE HUMAN EXPOSURE PATHWAYS UNDER FUTURE
LAND-USE CONDITIONS. . . . . . . . . . . . . . . . . . . . . . > . . . . . . . . . . . . . . . . . . . .. 18
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TABLE 6-11, SUMMARY OF QUANTITATIVE RISK ESTIMATES FOR ADDITIONAL
POTENTIALLY COMPLETE HUMAN EXPOSURE PATHWAYS UNDER FUTURE
LAND-USE CONDITIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19
TABLE 6-12, SUMMARY OF HUMAN HEALTH RISK-BASED CLEANUP LEVELS
FOR CHEMICALS OF CONCERN OTHER THAN LEAD ..................... 21
TABLE 8-1, SUMMARY OF PRESENT-WORTH COSTS FOR SOIL AND GROUND
WATER CLEANUP ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32
TABLE 12-1, CHEMICAL SPECIFIC ARARS .............................. 49
TABLE 12-2, LOCATION SPECIFIC ARARS. ............................. 50
TABLE 12-3, ACTION SPECIFIC ARARS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 51
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TABLE OF CONTENTS
AMENDMENT TO RECORD OF DECISION FOR OPERABLE UNIT ONE
lLeo SUPERFUND SITE
1.0 INTRODUCTION.......... ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 55
2.0 DESCRIPTION OF THE PREVIOUSLY SELECTED REMEDY AND
MODIFIED REMEDY FOR OU-l .... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 56
3.0 SUMMARY OF THE COMPARATIVE ANALYSIS FOR THE
PREVIOUSLY SELECTED REMEDY VERSUS THE MODIFIED REMEDY
FOR aU-I. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.0 STATUTORY DETERMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 61
4.1 PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 63
4.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs) . . . . . . . . . . . . . . . . . . . . .. 63
. 4.3 COST EFFECTIVENESS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 63
4.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE
MAXIMUMEXTENT PRACTICABLE. . . . . . . . . . . . . . . . . . . . . . . . . .. 63
4.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT. 64
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LIST OF TABLES
AMENDMENT TO RECORD OF DECISION FOR OPERABLE UNIT ONE
ILCO SUPERFUND SITE
TABLE 3-1, TOTAL ESTIMATED COST OF PREVIOUSLY SELECTED SOIL
REMEDY FOR OU-1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 62
TABLE 3-2, TOTAL ESTIMATED COST OF EPA'S MODIFIED SOIL REMEDY FOR
QU-1 .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 62
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Decision Summary
for the
Record of Decision
for
Operable Unit Two
Interstate Lead Company (ILCO) Site
Leeds, Alabama
1.0 SITE LOCATION AND DESCRIPTION
The Interstate Lead Company (ILeO) Superfund Site is located approximately 15 miles
east of Birmingham, in Leeds, Jefferson County, Alabama (see Figure 1-1, Site Location
Map). The ILeO Site consists of the ILCO Main Facility and seven satellite sites located
in and around the City of Leeds, where lead-cont$lm;nated wastes from the ILCO Main
Facility were disposed.
The ILCO Main Facility is located at 1247 Borden Avenue on the southwestern side of
the City of Leeds. The ILea Main Facility (including the ILCa Parking Lot across the
street) occupies approximately 11.5 acres of real properly, most of which is owned by
ILca with a portion owned by Interstate Trucking Company, Inc., an affiliated company.
The ILCa Main Facility is bordered by an abandoned foundry and a wooded area to the
south, an nnnamed tributary to Dry Creek to the west, Borden Avenue and the ILeO
Parking Lot to the north, and another business to the east (see Figure 1-2, Site Layout).
The area is primarily industrial with a few residences within a half-mile radius.
The satellite sites include the ILCO Parkin~ Lot. located across the street from the ILCa
Main Facility; the Gul£IBP Service Station. located in the center of Leeds on U.S.
Highway 78; J&L Fabricators. located east of Leeds on U.S. Highway 78; IDemin~s
Patio. located west of Leeds on Alaska Avenue; the Connell Propertv. located east of
Leeds in St. Clair County; the Acmar Church of God. located off Acmar Road in Moody,
Alabama; and the Citv of Leeds Municipal Landfill. located off Dunavant Road at the'
end of Peach Street.
ILCO operated a secondary lead smelting and lead battery recycling business from 1970
to 1992 at the ILeO Main Facility. In March 1992, ILCO ceased operating pursuant to
an order of a state court of Alabama. ILeO manufactured refined lead alloys through
the smelting and refining of lead-bearing scrap materials. The primary materials
reclaimed by ILea were discarded lead-acid automobile and industrial batteries. The
used batteries were cracked and the lead plates and lead oxides were smelted in a blast
furnace. Furnace slag was produced as a by-product and is regulated under the
ResourCt: Conse:!"Vation and Recovery A£.-t (RCRA) as a .~h~racteris~_:.c hazardous waste
due to its lead content. Wastewater treatment sludge and baghouse dust were also
generated. Wastewater treatment sludge is a RCRA regulated hazardous waste and
baghouse dunt jg a RCRA list.ed hazardous waste (K069). ILCO stored furnace slag,
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~
SCALE 1:24000
o
I~
-
,..,...
FIGURE 1-1
SITE LOCATION MAP
ILCO SUPERFUND SITE
LEEDS, ALPBMJiA..
.. .,-
:::.--
FROM: DAMES AND MOORE
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APPROXIMATE SCALE'
400 0 200 400
< IN rccr >
I inch.« 400 t\
MONTGOMERY OIL
1 MAIN FACILITY
\
FIGURE 1-2
, SITE LAYOUT
ILCO SUPERFUND SITE
LEEDS, ALABAMA
CALDWELL FOUNDRY
AND MACHINERY
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battery chips, and wastewater treatment sludge in piles on the ILCO Main Facility.
Furnace slag generated by ILCO was used as fill material at the ILCO Main Facility and .
at the satellite sites. Wastewater treatment sludge and battery casings were also
disposed of at the ILCO Main Facility and at some of the satellite sites.
2.0 SITE mSTORY AND ENFORCEMENT ACTIVITIES
In May 1984, EP A and the Alabama Department of Environmental Management
(ADEM) conducted a joint inspection of the ILCO Main Facility, which was found to be
in violation of the interim status standards set forth in RCRA.
In March 1985, the United States brought suit against ILCO and its principal, Diego
Maffei, seeking injunctive relief, penalties, and damages for violations of the Clean
Water Act and RCRA. The government also sought to recover response costs pursuant to
CERCLA for a removal action taken by EPA at the Acmar Church of God satellite site.
The complaint also included a count for corrective action at the ILCO Main Facility. The
case was brought in the United States District Court for the Northern District of
Alabama (District Court Case). The State of Alabama intervened in the litigation
asserting violations of Alabama's Water Pollution Control Act and Hazardous Waste
Management and Minimization Act.
There was a partial settlement of the District Court Case in August 1988. A partial
consent decree was entered requiring ILCO to conduct all necessary corrective actions
and remediation of contSlm1nated sediment in the surrounding waterways.
The outstanding issues were tried in July and August 1988. On December 10, 1990, the
district court issued an Order and Findings of Fact and Conclusions of Law holding that
the defendants had violated the Clean Water Act and RCRA and that injunctive relief
and penalties were appropriate. The court also found that the defendants were liable for
all response costs incurred by the United States in connection with the removal action at
the Acmar Church of God satellite site.
In its December 10, 1990 Order, the district court did not enter a judgment but ordered
the parties to endeavor to reach an agreement as to the relief which should be provided.
The parties were unable to come to such an agreement, and each submitted a proposed
final judgment. On October 8, 1991, the court entered a judgment. The district court
granted injunctive relief and assessed a penalty of two million dollars against ILCO, in
favor of the United States, for violations ofRCRA and the Clean Water Act. In addition,
the district court entered judgment in favor of the United States against ILCO and Diego
Maffei, in the amount of $845,033.40, as reimbursement for response costs for the
removal action at the Acmar Church of God satellite site. The district court also
awarded a penalty in the amount of $1.5 million in favor of the State of Alabama.
4
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On appeal, the Eleventh Circuit Court issued a decision in favor of the United States
and the State of Alabama on every issue and affirmed the district court's award of civil
penalties and response costs.
In June 1986, the ILCO Site (including the ILCO Main Facility and the seven satellite
sites) was placed on the National Priorities List (NPL) of uncontrolled hazardous waste
sites.
EP A conducted a Remedial InvestigationIFeasibility Study (RIIFS) of the satellite sites
(Operable Unit One), which was completed in July 1991. A proposed plan was issued
shortly after completion of the RIlFS. After a public comment period, a Record of
Decision (ROD) was signed on September 30, 1991, which set forth the selected remedy
for the satellite sites.
When ILCO ceased operations in March 1992, EP A initiated a removal action to mitigate
the imminent threat associated with the abandoned ILCO Main Facility. During the
removal action at the ILCO Main Facility, approximately 5368 tons of lead cont~m;n~ted
slag, found stored in different areas around the facility, were removed to a permitted
hazardous waste landtill. Approximately 200,000 gallons of lead cont~m;nated sludge
found in the onsite wastewater treatment system was removed, stabilized, and stockpiled
onsite with cont~m;nated soils excavated from the facility. Acid from several
impoundments was collected and treated in the onsite wastewater tre.atment system, in
addition to approximately 15,000,000 gallons of wastewater. The battery cracking
building, the furnace building, and the small slag vault were demolished and
decontaminated due to extensive lead cont~m;nation. The contents of the. small slag
vault were removed and stockpiled onsite with the contRm;nated soils. Waste
encountered during the demolition of the furnace building included lead waste, baghouse
dust, and a sulfur residue from the emissions system. The lead waste was stockpiled
inside a building onsite. The baghouse dust was placed into two roll-off boxes, covered,
labeled K069, and also stored inside a building onsite. The sulfur residue found inside
the duct pipe was placed on the contaminated soil stockpile. During the demolition of
the battery cracking building, process soils from the battery cracking operation were
removed and stockpiled inside a building onsite. The process soils consisted of a mixture
of battery chips and contaminated soils.
EPA conducted a RI/FS of the ILCO Main Facility (Operable Unit Two), which was
completed in June 1994.
3.0 mGHLIGHTS OF COMMUNITY PARTICIPATION
The Leeds Public Library at 802 Parkway Drive, S.E. in Leeds, Alabama
is the local information repository for the !LCO Site. The proposed plan for Operable
Unit Two and :aotice of the proposed modifications to the ROD for Operab1i; U:ni~ One
5
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. .. - -.
was issued and a public comment period was established from July 11, 1994 to
September 9, 1994. A public meeting on the proposed plan was held on July 21, 1994.
The administrative record for the ILCO Site is available to the public at both the
information repository maintained at the Leeds Public Library and at the EP A Region IV
Library at 345 Courtland Street in Atlanta, Georgia. The notice of availability for the
proposed plan for Operable Unit Two was published in The Birmingham News on July
13, 1994 and July 18, 1994 and in The Leeds News on July 14, 1994 and July 21, 1994.
A 30-day extension to the public comment period was requested and granted by EP A.
The 30-day extension notice was published in The Birmingham News on July 22, 1994
and July 28, 1994 and in The Leeds News on August 4, 1994 and August 11, 1994.
Responses to the significant comments received during the public comment period are
included in the Responsiveness S11mm~ry, which is part of this ROD and designated
Appendix A.
This decision document presents the selected remedial action for OU-2 of the ILCO Site,
chosen in accordance with CERCLA, as amended, and to the extent practicable, the
NCP. The decision for OU-2 is based on the administrative record. The requirements
under Section 117 of CERCLA/SARA for public and state participation have been met for
this operable unit.
4.0 SCOPE AND ROLE OF OPERABLE UNITS
The problems at the ILCO Site are complex. As a result, EP A has divided the work into
three manageable components called "operable units" in order to simplify remedial
pJanning and response activities associated with the disposal and discharge of
cont.amin~ted media from the Site as follows:
erable Unit One OU-l: The seven satellite sites located in and around the
City of Leeds. Contaminated soil, ground water and sediment at the seven
satellite sites are addressed in OU-l, excluding ground water at the ILCO Parking
Lot satellite site. Ground water contamination at the ILCO Parking Lot will be
addressed in Operable Unit Two.
erable Unit Two OU-2: The ILCO Main Facility. Con~minated soil at the
ILCO Main Facilityand contaminated ground water at the ILCO Main Facility and
ILeO Parking Lot are addressed in OU-2.
ODerabl~hree (OU-3): The Unnamed Tributary and Dry Creek.
Contaminated surface water, sediment, fish, and other aquatic organisms will be
addressed in OU-3.
This ROD is for OU-2 of the ILCO Site and documents the selected remedy for
contslminated soil and ground water at the ILCO Main Facility. This ROD also amends
6
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the soil remedy previously selected as part of the ROD for OU-1 issued on September 30,
1991. Based on the results and recommendations of a biological assessment performed
by EP A at the ILCO Site, EP A separated the unnamed tributary and Dry Creek into
another operable unit (OU-3) for further investigation of the surface water, sediment,
fish, and other aquatic organisms. This additional investigation began in July 1994 and
is currently scheduled to be completed by Fall 1995.
5.0 SUMMARY OF SITE CHARACTERISTICS
5.L Landforms
The ILCO Site is located in the Appalachian Valley and Ridge Physiographic Province,
within the Cahaba Valley. The area is characterized by series of linear, sub-parallel
ridges, developed on the underlying structurally deformed rock sequences, and separated
by valleys of varying widths. Topographic relief in the area is moderate to high, with
rapid changes of several hundred feet common. .
5.2 Surface Water
Three significant surface water bodies are present in the Leeds area. These are the
Cahaba River, located to the north of the City of Leeds; the Little Cahaba River, which
runs through Leeds; and Dry Creek, a stream that runs near the ILCO Main Facility
and ILCO Parking Lot and flows into the Little Cahaba River in the vicinity of the
wastewater treatment plant. The general orientation of the major streams and rivers is
parallel to the major topographic structures.
A smaller surface water body, identified as the unnamed tributary to Dry Creek, flows
north, generally along the western boundary of the ILCO Main Facility, crosses Borden
Avenue, and ultimately drains into Dry Creek. The 11nn~med tributary has in the past
received run-off water from the ILCO Main Facility that was highly con~minated with
lead. Even though ILCO conducted a soil and sediment removal from the tributary in
August 1990, the stream is still contaminated. Surface water and sediment
cont.Rm;n~tion associated with the ILCO Main Facility is being addressed Wlder OU-3.
5.3 Geology
5.3.1 Regional Geology
The suite of rocks in the Cahaba Valley is typical of the Valley and Ridge and consists of
sandstones and shales, commonly interbedded, as well as limestone and dolomitic
limestone. The regional structure is typically characterized by northeast-southwest
trending layers of rock, which are locally steeply inclined and frequently folded and
faulted. The larger structures generally dip to the southeast at angles up to 45 degrees
and are inte:r~el:1! frar.tured and jointed.
7
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..- ..'..,. - .
5.3.2 Site-Specific Geology and Soils
The ILCO Main Facility is underlain by a veneer of unconsolidated material, consisting
of weathered light-brown to dark-gray, sandy, silty, clayey alluvium that generally
ranges from 5 to 20 feet thick. The Floyd Shale lies directly beneath the alluvium along
the southeast border of the property; the contact between the Floyd Shale and the
Hartselle Sandstone is in the same area. The Hartselle Sandstone is overlain by
alluvium in the southeastern portion of the property and in the area previously occupied
by the battery cracking building. The remainder of the ILCO Main Facility is underlain
by the Pride Mountain Formation, which extends to the northwest in the vicinity of Dry
Creek
5.4 Ground Water
5.4.1 Regional Hydrogeology
Generally, ground water is available, in some quantity, in four different horizons or
formations in the Leeds area. These zones are not necessarily, in themselves, major
regional aquifers, but rather represent hydrogeological conditions or situations in which
a completed well may produce water more significantly than in others, such as massive
shale formations, etc. The more shallow zones are usually unconfined, with the lower
units sometimes occurring under confined conditions, depending on the geology of the
overlying material. Because of the degree of fracturing observed in the area, it is
conceivable that all zones may, to a certain extent, be interconnected in some areas.
These zones include the following:
Surficial Aauifer - Consists of a thin layer of unconsolidated alluvial deposits that
covers most of the valley. The maximum thickness is. 20 feet. It is separated from
the shallow aquifer system by a silty clay at some locations and is a very poor
source of water to wells. Water occurs under unconfined conditions.
Shallow Aauifer - Consists of weathered to consolidated material in the upper part
of the bedrock and is generally no more than 30 feet thick. It is separated from
the underlying rock in some areas by a dense, dark-gray clay and is a very limite-d
source of water to wells. Water occurs under unconfined conditions.
Fort Pame Chert Aquifer - Provides some of the water supply to the City of
Leeds. City wells are installed to depths of 150-300 feet and located approximately
one-half mile to the northeast of the ILCO Main Facility and the ILCO Parking
Lot. The Fort Payne Chert Aquifer behaves similarly to a confined aquifer because
of the lower permeability of the overlying formations. However, these lower
permeability formations do not prevent the movement of contaminants into the
Fort Payne Chert Aquifer.
8
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Ordovician Undifferentiated A . er - Consists of 1,000 feet of crystalline
limestone. Two springs in this formation provide part of the water supply to the
City of Leeds. The Weems Spring is located off Cemetery Road approximately 5
miles southeast of the Acmar Church of God satellite site in Moody, Alabama,
north of Leeds. The Rowan Spring is located in Leeds at the intersection of
Highway 119 and President Road.
5.4.2 Site Hydrogeology
5.4.2.1 General Conditions
Ground water at the ILeO Main Facility occurs in the unconsolidated alluvium and
underlying weathered zone of shales and generally occurs in unconfined conditions in the
area. Water levels range from 4 feet to almost 50 feet below land surface. At the ILCO
Main Facility, ground water tends to flow toward Dry Creek and its 11nn~med tributary
to the north and northwest of the area with infiltration into the underlying weathered
shallow aquifer, which is in the Floyd Shale, the Hartselle Sandstone, and the Pride
Mountain Formation. Data and information from monitoring well GM-2B, a deep well,
indicates that water-bearing zones occur in joints and fractures deep in the shales under
partially confined conditions.
5.4.2.2 Ground Water Movement Patterns
Based on water elevations and data interpretations, ground water is moving generally to
the northwest in the shallow and intermediate ground water zones, with sma11localized
differences in direction. The pattern of movement in the deep zone is more difficult to
determine, based on ground water elevations alone. Based on measured water levels, it
appears to be moVing north or even to the northeast, perhaps under the influence of a
large, pumping municipal water supply well used by the City of Leeds and located
approximately one-half mile away. 'The cont.slminant pattern, however, indicates that it
is moving in a direction much like ground water in the shallow and intermediate ground
water systems.
The possibility exists that a strong influence on flow patterns and cont.slminant
distribution in the deep zone is being exerted by a fault identified at the ILCO Main
Facility. This is further supported by the potential for impact on the local ground water
system by the Lehigh quarry, west of the ILeO Main Facility and south of Leeds.
Several facts are pertinent. One, the quarry is de-watered at a rate of approximately
1,000 gallons per minute, based on statements by the quarry superintendent. Also, it is
possible that the quarry is located on or closely within the influence of the fault
identified at the ILCO Main Facility. The tremendous ground water withdrawal, which
has depressed the water table by approximately 200 feet in the vicinity of the quarry,
could be de-watering the fault as far away as the ILCO Main Facility. This scenario is
further corroborated by the strong vertical downwarC:: J:radient observed in the
monitoring wells along the spur adjacent to Dry Creek, where heads measured in the
9
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deep wens are approximately 60 feet lower than in the shallow and intermediate wens.
Further investigation is warranted to conclusively define ground water movement
patterns in the deep ground water system.
5.4.2.3 Ground Water Gradients
Average ground water gradients across OU-2 were determined for each of the three
ground water zones from measured water levels. These gradients were determined
across the known affected portions of the aquifer in the regions of the aquifer for which
remediation is anticipated. Based on these measurements, gradients of 0.016, 0.034 and
0.045 were calculated for the shallow, intermediate and deep zones, respectively.
6.0 SUMMARY OF SITE RISKS
Over 20 years of battery recycling operations at the ILCO Main Facility resulted in
elevated concentrations of lead and other chemicals in nearby environmental media,
including soil and ground water underlying the ILCO Main Facility and adjacent ILCO
Parking Lot. A large quantity of the source materials at the ILeO Main Facility were
removed during the 1992-1993 emergency removal action.. The OU-2 RI was performed
from 1993 to 1994 to determine the nature and extent of rema;n;ng coIitam;nation. The
Baseline Risk Assessment (BRA) was primarily based on the OU-2 RI findings and was
performed in order to examine the potential human health risks associated with lead
and other chemical concentrations in environmental media at OU-2. .
6.1 SELECTION OF CHEMICALS OF POTENTIAL CONCERN
The first task of the BRA was to snmmarize the data collected for surface and
subsurface soil, sediment, surface water, and ground water during the OU-2 RI. This
was supplemented to some degree by data from other investigations (e.g., the removal
action and the OU-1 RI). From these data, chemicals of potential concern were selected
for detailed evaluation in the BRA. Lead was selected as a chemical of potential concern
based on ILCO Main Facility operations and investigations. Primarily based on a
comparison to background data and an evaluation of essential nutrients, additional
metals were also identified as chemicals of potential concern (Le., were identified as
potentially toxic chemicals present above naturally occurring levels). A small number of
organic chemicals detected in ground water were also identified as chemicals of potential
concern. The chemicals of potential concern other than lead are listed in Table 6-1.
6.2 HUMAN TOXICITY ASSESSMENl'
The next step of the BRA, the human toxicity assessment, was performed in order to
identify numerical toxicity criteria with which to assess human health exposures. For
lead, criteria based on EP A-derived cleanup levels for soil and ground water were
identified and presented. For chemicals of potential concern other than lead,
quantitative dose-response data were compiled from EPA"s Integrated Risk Information
10
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System (IRIS), Health Effects Assessment Snmmsny Tables (HEASTs),and the
Environmental Criteria and Assessment Office (ECAO). The quantitative dose-response
data for the chemicals of potential concern other than lead are given in Table 6-1.
ORAL TOXXCXTY CRXTERD. FOR THE CBElaCALS OF POTENTIAL CONCERN OTHER THAN LEAD
TABLE 6-1
_Gal
CbzoD1c cnal
..f-
- lafD)
(8CrIkcr~)
cna1
.~
hDto%
(8CrIkcr-4q'"
"l~....f-
.,,~
Cl888 (..,
.~
-~
~
~t~
~ltlGal
aff~ (b'
1JD"Uta~
P8Gto~ (a'
afD
~
Inorganic Chemical-
Aluainua
Anti8GIIY
Anenic
Bariua
Barylliua
c.4oIiua
Chro8i.... XII
Ch~i.... VI
c:cbalt
copper
l8aDgane..
tIercu%y
Nickel
Seleni,.
Silver
'%haUi..
'1'1n
'1'itaniua
Vanadiua
Tttriua
Zinc
organic O1e1ftica18
Benzene
Et!\y1 benzena
X80pr0py1 benz"""
n-Prc>pylbenz8D8
1.2.4-'1'ri8ethylbenzene
1,3.5-'1'ri8ethy1benz8n&
-- 8ZId/o~ I>->Xy1ene8
II&\ST
U:-04 1,000 Blood Che8iGUy %RIS
JE-04 3 Skin JRJS 1.75&+00
71\-02 3 Jncreued BP JRJS
5r;-OJ 100 None Ob8otrvwd JRIS 4.3&+00
51\-04 10 lI:idn"Y JRJS
U-03 10 lI:idn8Y JRJS
1&+00 1,000 Liver JRIS
51\-03 500 CIS JRIS
611-02 Blood Che8i8Uy ECAO
3 .711-02 1 CI Irritation KEAST
51\-03 1 0lS JRIS
1.eE-01 1 CIS JRIS
JE-04 1,000 1l:idn8Y KEAST
2£-02 300 ~ Weight JRIS
5 £-03 3 seleno8i. JRIS
5£-03 3 Argyria JRIS
IE-OS 3,000 Li...r JRIS
6£-01 100 Li Y8r /ll:idn"Y BEAST
----
711-03 100 lI:idney KEAST
3£-01 3 Blood CIIaIi8try JRIS
JRJS 2.9£-02
U-01 1,000 Li Y1!r/lI:idn8Y JRIS
eE-02 3,000 lI:idn8Y JRIS
5£-04 10,000 CIS ECAO
4£-04 10,000 CIS ECAO
2&+00 100 CIS II&\ST
A
82
IRIS
IRIS
IRIS
IRIS '.
IRIS
n
II
JRIS
JRIS
JRIS
IRIS
II
II
JRJS
A JRJS
JRJS
II IRIS
la)
Uncertainty factors presented are the products of specific'uncertainty factors and modifying
factors. Uncertainty factors used to develop reference doses generally consist of multiples of
10, with each factor representing a specific area of uncertainty in the data available. The
. standard uncertainty factors include:
- a 10-fold factor to account for the variation in sensitivity among the members of the human
population: .
- a lO-fold factor to account for the uncertainty in extrapolating animal data to the case of
humans:
- a lO-fold factor to account for the uncertainty in extrapolating from less-than-chronic NOAELs
to chronic NOAELs:
- a lO-fold factor to account for the uncertainty in extrapolating from LOAELs to NOAELs:
ModifYing factors are applied at the discretion of the reviewer to cover. other uncertainties ~n
the data and range from 1-10.
A target organ or critical effect is the organ/effect most sensitive to the chemical exposure.
RfDs are based on toxic effects in the target organ or critical effects. If an RfD is based on a
study in which a target organ or critical effect was not identified, the organ/effect listed is
one known to be impacted by the chemical.
USEPA weight-of-evidence classification scheme for carcinogeJls:
A = Human CarcinogeJl, sufficient evidence from human epidemiological studies:
B2 = Probable Human Carcinogen, inadequate evidence from human epidemiological studies and
adequate evidence from animal studies: and
D = Not classified as to human carcinogeJlicity.
IRIS = Integrated Risk Information System - February 1994
BEAST = Health Effects AssesBmeJlt Summary Tables - Annual 1993
ECAO = EnvironmeJltal Criteria and Assessment Office. provisional guidance
No Information Available
CNS = CeJltral Nervous System
< = Decreased
BP = Blood ?r~asure
GI = GastroiL~estinal
tb)
(c)
NOTE :
11
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6.3 HUMAN EXPOSURE ASSESSMENT
A human exposure assessment was also performed to determine the potential human
exposure pathways at OU-2 under current and future land use conditions. The ILCO
Main Facility is not active, therefore, only a trespasser exposure was evaluated for
current conditions, while under future land use conditions, both a commercia1fmdustrial
use scenario and a residential use scenario were considered. For each complete exposure
pathway, the chemical concentrations assumed to be contacted (Le., the exposure point
concentrations) were derived. These values were either the 95% upper confidence limit
of the arithmetic mean concentration or the maximum detected concentration, whichever
was less. The exposure point concentrations for lead were used in a direct comparison to
the lead criteria identified in the toxicity assessment. The exposure point concentrations
for other chemicals of potential concern were combined with reasonable mJlYimum
estimates of the extent, frequency, and duration of exposure in order to calculate
. chemical doses. Exposure parameters for the human exposure pathways at OU-2 under
CUlTent and future land use conditions are given in Tables 6-2 through 6-7.
6.4 HUMAN RISK CHARACTERIZATION
Using the human exposure and toxicity information, potential human health risks for
each chemical of potential concern and selected exposure pathway were evaluated. For
lead, the potential for human health risks, described in terms of the potential for blood
lead levels of concern resulting from exposure, was assessed by comparing lead exposure
point concentrations to relevant cleanup criteria. .
Table 6-8 gives a comparison of lead concentrations in environmental media at OU-2 to
the relevant lead cleanup criteria established for OU-2.
For the chemicals of potential concern other than lead, upper-bound excess lifetime
cancer risks for carcinogenic chemicals and hazard quotient and hazard index values for
noncarcinogenic chemicals were estimated. The upper-bound excess lifetime cancer risks
were compared to USEP A's risk range for health protectiveness at Superfund Sites of
hl0.6to hl0". This range is representative of risks that must be considered in the
selection of remedial alternatives. The noncarcinogenic hazard quotients and hazard -
indices were compared to a value of one, since hazard quotientsl'mdices greater than one
. indicate a potential for adverse health effects. Tables 6-9, 6-10, and 6-11 present risk
estimates for human exposure pathways quantitatively evaluated under current land use
conditions, future commercial! industrial land use conditions, and future residential land
use conditions, respectively. As shown in the tables, predominant chemicals (chemicals.
associated with cancer risks greater than lx10.6 or hazard quotients greater than one)
included the following: arsenic and beryllium in soil and antimony, arsenic, beryllium,
cadmium, cobalt, manganese, nickel, zinc, benzene, 1,2,4-trimethylbenzene and 1,3,5-
trimethylbenzene in ground water.
12
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TABLE 6-2
EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION OF AND DERMAL
CONTACT WITH CHEMICALS IN SURFACE SOIL
CURRENT LAND-USE CONDITIONS
Etaramater8
Tre.pa88er
~ge Period
~sure Frequency (days/year or events/year)
8-13 Years of Age
~sure Duration (years)
80
6
Ingestion Exposure Parameters:
Soil Ingestion Rate (mg/day)
Fraction Ingested (dimensionless)
100
1
Direct Contact Exposure Parameters:
. Skin Surface Area Available for Contact (cm2)
Soil-to-Skin Adherence Factor (mg/cm2-event)
Dermal Absorption Factor (dimensionless).
Inorganic Chemicals
5,900
1.0
0.001
Body Weight (kg)
'37
70
Lifetime (years)
TABLE 6-3
EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION OF AND DERMAL
CONTACT WITH CHEMICALS IN SU$'ACE SOIL
FUTURE LAND-USE CONDITIONS:
COMMERCI:AL/INDUSTRIAL SCENARIO
Parameter.
Regular Worker
Age Period
Adult
Exposure Frequency (days/year or events/year)
250
25
Exposure Duration (years)
Ingestion Exposure Parameters:
Soil Ingestion Rate (mg/day)
Fraction Ingested (dimensionless)
50
1
Direct Contact Exposure Parameters:
Skin Surface Area Available for Contact (cmt)
Soil-to-Skin Adherence Factor (mg/cm2-event)
Dermal Absorption Factor (dimensionless)
Inorganic Chemicals
3,500
'1.0
0.001
Body Weight (kg)
_.
Lifetime (years)
70
70
13
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TABLE 6-4
EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION OF AND DERMAL
CONTACT WITH CHEMICALS :IN SUBSURFACE SOIL
Ft1TtJRB LAND-USE CONDITIONS:
COMMERCIAL INDUSTRIAL SCENARIO
Parameters
Excavation Worker
Age Period
Adult
Exposure Frequency (days/year or events/year)
Exposure Duration (years)
7
1
Ingestion Exposure Parameters:
Soil Ingestion Rate (mg/day)
Fraction Ingested (dimensionless)
480
1
Direct Contact Exposure Parameters:
Skin Surface Area Available for Contact (cm2)
Soil-to-Skin Adherence Factor (mg/cm2-event)
Dermal Absorption Factor (dimensionless)
Inorganic Chemicals
3,500
1.0
0.001
Body Weight (kg)
70
70
Lifetime (years)
TABLE 6-5
EXPOSURE PARAME'l'ERS FOR INGESTION OF CHEMICALS IN GROUNDWA'l'ER
Ft1TtJRB LAND-USE CONDITIONS:
COMMERCI~I :INDUSTRIAL SCENARIO.
Parameters
Regular Worker
Age Period
Adult
Exposure Frequency (days/year)
Exposure Duration (years)
250
25
Water Ingestion Rate (liters/day)
1
Body Weight (kg)
70
70
Lifetime (years)
14
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TABLE 6-6
EXPOSURE PARAMETERS FOR XNCXDENTAL XNGESTXON OF AND DERMAL
CONTACT WXTH CHEMXCALS XN SURFACE SOXL
FUTURE LAND-USE CONDXTXONS:
RESXDENTXAL SCENARXO
Child Resident
Adult Resident
Adult
350
30
100
1
5,900
1.0
. 0.001
70
70
Parameters
Age Period
Exposure Frequency (days/year or events/year)
1-6 Years of Age
350
Exposure Duration (years)
6
Ingestion Exposure Parameters:
Soil/Sediment Ingestion Rate (mg/day)
Fraction Ingested (dimensionless)
200
1
Direct Contact Exposure Parameters:
Skin/Surface Area Available for Contact (cm2)
soil/Sediment-to-Skin Adherence Factor
(mg/cm2-event)
Dermal Absorption Factor (dimensionless)
Inorganic Chemicals
3,100
1.0
0.001
16
Body Weight (kg)
Lifetime (years)
70
TABLE 6-7
EXPOSURE PARAMETERS FOR XNCXDENTAL XNGESTXON OF
CHEIUCALS XN GROUNDWATER
FUTURE LAND-USE CONDXTXONS:
RESXDENTXAL SCENARXO
Parameters
Child Resident Adult Resident
1-6 Years of Age . Adul t
350 350
6 30
1 2
16 70
70 70
Age Period
Exposure Frequency (days/year)
Exposure Duration (years)
Water Ingestion Rate (liters/day)
Body Weight (kg)
Lifetime (years)
15
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TABLE 6-8
COMPARISON OF LEAD CONCENTRATIONS IN ENVIRONMENTAL MEDIA AT THE ILCO
OU-2 SITE TO RELEVANT CRITERIA
ILeO OU-2 ENVIRONMENTAL CONCEN"IRATIONS
RIm Ezponre PoInt Cleanup CoadudODS
CoDceDtratiOD or LeveIa
EDvUoDJDeDtalloiedium RaDle of
CoDceDtratlOD8
SOIL: CoDt8ct with ate 80Ds (Le.. ~ m,-ttoD)
OD ate (II8ID FadJitJ) 4,200 mUq 1000 mUq for could coDtdbate to or resa1t ID 8D
Smface SoD DOrmal pH 800. UD8CCeptable halth risk or abcne1y affect
poaad water' qua1Ity. The 150 rq/'q
OD ate (II8ID FadJitJ) 1.7oomUq or cIeaDap leftt for low pH _118 Is --eel 1IpOD
Sab8111face SoD protectioD of ero_d water. while the 1000
150 mg/'q for 10.. mVJq "~"up level for DOnD8I pH .0& Is :
SoD 11Dder CoDcrete 0DIy 4-190.000 mc/"q pH 80& baed apGD protectiOD oflumaaD health d-
SoD ID Stockpile SO.()()().44.ooo mc/"q to cUrect caDtact with the 80& uad
protectioD of ero~ water. Tbe 1000
mVJq deaDup Jeft11s ba8e4 apGD . fDtare
COIIIJDeI'dal/lDilaatdalluad- of the .1te.
GROmm WATER: 11" of .Ite ero-d water for 4IrIDIdDt water
OD ate (II8ID FacDity 150 q/L 15 q/L could caDtdbate to or ren1t ID 8D
aDd ParkID& Lot) UDaCCepbble halth d8k.
an_a water
1rable 6-9 .
Summary of Quantitative Risk Estimates for Potentially
Complete Human Exposure Pathways Under
Current Land Use Conditions
Exposure Medium
Exposure Point
Receptor
Exposure Route
Upper Bound
Excess Lifetime
Cancer Risk;8
'Hazard Index for
Predominant Noncarcinogenic
Chemicals" EfTemc
Predominant
Chemical~
Surface Soil:
On Site (Main Facility):
Trespasser:
Incidental Ingestion
Dermal Contact
2x1
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Table 6-10
Summary of Quantitative Risk Estimates for Additional
PotentiaUy Complete Human Exposure Pathways
Under Future Land Use Conditions
[ColllllJerciaJlIndustrial Scenario]
Exposure Medium
Exposure Point Upper Bound Hazard Index for
Receptor Excess Lifetime Predominant Noncarcinogenic Predominant
Exposure Route Cancer Ris~ Chemicals" Eff~ Chemicals'
Surface Soil:
On Site (Main Facility):
Worker:
Incidental Ingestion 7xlcr Arsenic <1 (8xI0"'l)
Dermal Contact 8xlcr Beryllium <1 (4xlO"'l)
Subsurface Soil:
On Site (Main Facility):
Excavation Worker:
Incidental Ingestion IxlO"' 1(9x101) Manganese, cadmium,
benzene 1,2,4- and 1,3.5-
trimethybenzene
Note:
-rile Upper bound individual excess lifetime cancer risk represents the probability, ov~ background risks. than an individual
may develop cancer over a 70 year lifetime as a result of the exposure conditions evaluated.
"'The predominant chemicals are those which w~c associated with cancer risks greater than lx1~.
"The hazard index indicates wheth~ or not exposure to mixtutes of noncarcinogenic chemicals may result in adverse health
effects. A hazard index less than one indicates that adverse human health effects are unlikely to occur. A hazard index greater
than one indicates that adverse human health may potentially, but not necessarily, occur.
4tJ1Ie predominant chemicals are those which were associated with hazard quotients greater than 1.
17
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Table 6-11 .
Summary of Quantitative Risk Estimates for Additional
Potentially Complete Human Exposure Pathways
Under Future Land Use Conditions
[Residenti;il Scenario]
~xposure Mecbum
Exposure Point Upper Bound Hazard Index for
Receptor Excess Lifetime Predominant Noncarcinogenic Predominant
Exposure Route Cancer RisJc8 Chemicalsb Erreasc Chemicals4
Surface SoU:
On Site (Main Facility):
Child Resident:
Incidental Ingestion 4xlo-s Arsenic. Beryllium >1 (2xl0~ Antimony. Arsenic
Dermal Contact lxlo-s Beryllium <1 (2xl0-1)
Adult Resident
Incidental Ingestion 2x 1 o-S Arsenic. Beryllium <1 (2xl0-1)
Dermal Contact 2xlo-s Arsenic. Beryllium <1 (9XlO-2)
Groundwater:
On Site (Main Facility
and Parldng Lot):
Child Resident
Ingestion 4xlQ4 Arsenic. Beryllium. ;> 1 (600) Antimony. Arsenic.
Benzene ' Cadmium. Cobalt, Manga-
nese. Nickel, Zinc. 1.2.4-
and 1.3.5-Trimethylbenzene
Adult Resident:
Ingestion 9xlQ4 Arsenic. Beryllium, > 1 (300) Antimony. Arsenic.
Benzene Cadmium, Manganese.
. Nickel, Zinc. 1.2.4- .
and 1.3.5-Trimethylbenzene
Note: -'The U~ bound individual excess lifetime cancer risk repn:sents the probability, over background risks, that an individual
may develop cancer over a 70 year lifetime as a result of the exposure conditions evaluated.
'The predominant chemicaJs are those which were associated with cancer risks greater than lx1~.
"'The hazard index indicates whether or not exposure to mixtures of noncarcinogenic chemicaJs may result in adverse health
effects. A hazard index less than one indicates that adverse human health effects are unlikely to occur. A hazard index greater
than one indicates that adverse human health may potentially, but not necessarily, occur.
'*The predominant chemicaJs are those which were associated with hazard quotients greater than 1.
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6.5 RISK-BASED REMEDIATION GOALS
[n accordance with EP A guidance, the BRA also included risk-based remediation goals
for the chemicals and pathways evaluated in the human health risk assessment that
were associated with upper-bound excess lifetime cancer risks greater than 1x10-6 or for
which hazard indices were greater than one. These goals incorporate the exposure
scenarios and exposure assumptions that were developed in the BRA. Remediation goals
for lead were not developed in the BRA since EP A-derived cleanup levels for this
:iliemical were already available (and used in this assessment). Table 6-8 summarizes
llie lead cleanup levels developed by EPA for soil and ground water at OU-2.
Concentrations of lead in soil and ground water were compared to the cleanup levels to
~etermine if they could potentially result in adverse effects on human health.
Predom;mmt chemicals (chemicals associated with cancer risks greater than lx10-6 or
!lazard quotients greater than 1) in environmental media of OU-2 were identified by
~xposure pathway in Tables 6-9, 6-10, and 6-11. The development of risk-based
remediation goals focused on exposures to these chemicals, through the ingestion route
[)n1y. Although cancer risks exceeding lx10.6 were associated with some pathways
lnvolving dermal contact with soil, the risk-based remediation goals derived in the risk
iissessment did not incorporate exposures through this route. This is due to the great
lUlcertainties associated with assessing this route of exposure, including uncertainties
iiSsociated with the use of default dermal absorption fractions and adjusted oral toxicity
::riteria. Additionally, ingestion is assumed to be the dominant pathway of exposure to
~und water and soil.
rable 6-12 presents the risk-based remediation goals for contaminants of concern other
llian lead developed in the BRA for relevant exposure media and receptors.
It'or carcinogenic chemicals, risk-based remediation goals were developed using a target
risk level of lx10-6, an EPA benchm~rk. To derive risk-based remediation goals for
1%10-5 and lx10'" (other EPA benchm~rks), the goals can be adjusted upward by a factor
[)f 10 or 100 (lor 2 orders of magnitude), respectively. For noncarcinogenic chemicals,
risk-based remediation goals were calculated to correspond to a target hazard quotient of
[)ne. Goals corresponding to alternate target hazard quotients (i.e., 10) can be derived by
scal;ng the goals appropriately (i.e., by a factor of 10, or one order of magnitude). For'
:iliemicals which exhibit both carcinogenic and noncarcinogenic effects (e.g., arsenic),
risk-based remediation goals presented are based on carcinogenic effects, which are more
stringent than goals based on noncarcinogenic effects.
6.6 ENVIRONMENTAL RISK
~ ecological risk assessment (ERA) was conducted for OU-2 to evaluate the probability
md magnitude of adverse affects to ecological receptors associated with actual or
potential exposure to chemicals in soil associated with past activities at the ILCO Main
Facility. The EHA used S&LC.pling data collected Juring the OU-2 RI and focused
primarily on surface soil data collected at or near the ILCO Main Facility.
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TABLE 6-U
SUMMARY OF HUMAN HEALTH RISK-BASED CLEANUP LEVELS
FOR CHEMICALS OF CONCERN OTHER THAN LEAD
Route of Exposure and Exposure Medium aeanup Coadusloas
Levels
Claemlca1 or CoacerD
JacldeaUi ..... or Coatlld wltb lite lOlls (Le. . 1agestIoa) coaIcI
s.face SoR coatribute to or result ID an uaacceptable .aJda
risk.
Aneale 13 ppm
Ja&eId- or er-dw8t«
ADdmou1 6ppb Use or site &f'OGDd water for drIIIIdag water
Aneale 50 ppb c:ouJd coatrIbUle to or result ID aD IlDAcaptable
BerJW- 4ppb bealtb risk.
CadmI- 5 ppb
Mangaaese 510 ppb
Nickel 100 ppb
Beauae 5ppb
1,2,4-Trlmetb11beazeae 51 ppb
1,3,5- TrlmetbJlbeazeae 41 ppb
Note: Tbe deaaup level lor Aneak 10 ..u Is baed upoa file avenge badtgnluaclleYei or ...-Ie Ia ..u at OU-2. Tbe deaDlIp leY. lor Maaganew,
1,2,"'TrlmetbJlbeazme. aDd 1,2,3-Trlmeltb1Ibeazeae ID zrowd water are based.poa a future commerdalllDdustriailaDd-ue or OtJ.2. Tbe deaaup
levels for the raualnlDg COC'. In grouacl water are the MQim- Coatamlaaat Levels (MCLs) or these COC'. Ia r:roaad waf« usable for drIaIdag
water-
The following chemicals were identified as chemicals of potential concern in surface soil
at the ILCO Main Facility: Aluminum, Antimony, Arsenic, Barium, Beryllium,
Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Nickel, Thallium, .
Vanadium, and Zinc. The identification of chemicals of potential concern for surface soil
was based on a comparison to offsite concentrations and identification of essential plant
and animal nutrients.
The ERA for OU-2 included an evaluation of impacts to terrestrial receptors (plants mid
earthworms). Impacts to terrestrial receptors were evaluated using risk quotients
representing a comparison of surface soil exposure point concentrations to chemical
concentrations levels from the scientific literature below which adverse effects are not
likely to occur.
The ERA evaluation indicates that adverse impacts to terrestrial plants coulel occur from
exposure to antimony, lead, and zinc in surface soils, with lead being the chemical of
most concern. Adverse impacts to soil invertebrates inay occur from exposure to lead
and zinc in surface soil However, the likely magnitude of the risks associated with
invertebrate exposure to these chemicals in soil is not high, as indicated by the close
p~~ty of the toxicity reference value (TRV) ratios to one. Fu...rilie:rmore, additional
20
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lead toxicity data collected at OU-2 suggested that earthworms may be able to tolerate
soil levels above the estimated no-effect concentrations. Therefore, based on the results
of the biological assessment and the ERA performed, EP A has determined that there is
not a significant environmental risk posed by surface soil at OU-2. Remediating the
soilto established soil cleanup levels should alleviate any environmental risk currently
posed by the soil. Any environmental risk posed by the surface water and sediment
adjacent to the!LCO Main Facility will be assessed under OU-3.
7.0 DESCRIPTION OF ALTERNATIVES
The site-specific remedial alternatives represent a range of distinct waste-management
strategies addressing the human health and environmental concerns. Although the
selected remedial alternative will be further refined as necessary during the predesign
and design phases of the remedial action, the following analysis reflects the fundamental
components of the various alternatives evaluated during the Feasibility Study for OU-2.
SOIL ALTERNATIVES
ALTERNATIVE 8-1: NO ACTION FOR SOIL
The no-action alternative-for soil involves no further remedial actions for any-of the
wastes or cont.Hm;nRted soil at OU-2. The purpose of including the no-action alternative
is to provide a baseline for comparison of the other remedial alternatives. The no-action
alternative would entail limited activities, including:
The posting of warning signs along the fence line of the ILCO Main Facility
to indicate the presence of hazardous and/or toxic wastes.
5-year reviews as required by CERCLA. The purpose of these reviews would
be to evaluate the effectiveness of the no-action alternative. The 5-year
reviews would include limited sampling and analysis activities to identify
trends in the distribution and magnitude of contJlm;nation in all currently or
potentially affected OU-2 media.
The purpose of these activities would be to limit exposure to Site-related contaminants
with a m;n;m~l commitment of funds or onsite activities.
ALTERNATIVE 8-2: CONTAINMENT OF SOIL
Alternative 8-2 involves cont.H;nment of the cont.Hm;nRted media by capping to reduce
the potential for exposure to contaminated soil and waste and infiltration of water. The
alternative also includes removal of material (e.g., debris, slag, battery casings, and
baghouse dust) not applicable for onsite containment. This alternative considers existing
Site conditions, su~h as location of existing co~c::-ste and asphalt paving, and utiEzu
these conditions as a portion of an effective barrier to exposure in addition toethe
21
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1-
construction of a RCRA cap over consolidated materials. Alternative 8-2 includes
institutional controls, monitoring, and an operations and maintenance program to
evaluate long-term protectiveness and performance of the alternative. General activities
for the different media are outlined below.
Soil:
Debris:
Slag/Lead:
Battery
Casings!
Chips:
Baghouse
Dust:
Excavate contaminated soil not contained under concrete and dispose of
onsite under a multi-media RCRA cap. Place cap over concrete slabs
covering contJ:lm;nated soil in former smelter area.
Decontam;nateltreat debris using specific best demonstrated available
technologies (BDAT) based on the type of debris and the type of
contam;nants present in the debris; recycle decontJ:lm;nated debris that can
be recycled and dispose of non-recyclable decontJ:lm;nated debris offsite in a
non-hazardous landfill; debris which cannot be decontam;nated will be
disposed offsite in a permitted hazardous waste landfill;
Package and ship slag that can be recycled to offsite permitted facility for
recovery of lead using a secondary smelter. If slag cannot be recycled,
solidy/stabilize and dispose of the slag offsite in a permitted hazardous waste
landfill.
Package and ship battery casing components and battery chips that can be
recycled to an offsite permitted facility for recovery of lead using a secondary
smelter. Dispose of non-recyclable components that fail TCLP offsite in a .
permitted hazardous waste landfill and dispose of non-hazardous, non-
recyclable components offsite in a non-hazardous landfill.
Send roll-off boxes of bag house dust (K069) off site to a RCRA permitted
Treatment, Storage, and Disposal (TSD) facility. Treatment and disposal of
the baghouse dust shall complay with all pertinent ARARs, including Land
Disposal Restrictions (LDRs); ..
ALTERNATIVE 8-3: SOLIDIFICATION/STABILIZATION
Alternative 8-3 for remediation of soil and debris involves: solidification/stabilization of
soils; onsite disposal of treated material in an engineered conw;nment cell;
decontamination of debris; offsite treatment of slag and battery casings/chips for
recovery of lead, if recyclable, otherwise offsite disposal; and offsite treatment and
disposal of bag house dust (K069). The alternative includes institutional controls,
monitoring, and ~ operations and maintenance program to ensure long-term
protectiveness and performance of the alternative. General treatment methods for the
different media are outiined below:
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Soil:
Debris:
Excavate contJlmin8ted soil; treat soil Viilinf TCLP onsite by
solidification/stabilization, and dispose of all soil (treated and untreated)
onsite in an engineered containment cell with a multi-media bottom liner
(including leachate collection) and multi-media RCRA Subtitle D cap.
Decontaminate/treat debris using specific best demonstrated available
technologies (BDAT) based on the type of debris and the type of
contaminants present in the debris; recycle decontaminated debris that can
be recycled and dispose of non-recyclable decontJlminated debris offsite in a
non-hazardous landfill; debris which cannot be decontslminated will be
disposed offsite in a hazardous waste landfill;
Slag/Lead: Package and ship slag that can be recycled to offsite facility for recovery of
lead using a secondary smelter. If slag cannot be recycled, solidifty/stabilize
the slag to pass TCLP and dispose of the slag in the onsite containment cell.
Battery
Casings!
Chips:
Baghouse
Dust:
Package and ship battery casing components and battery chips that can be
recycled to an offsite facility for recovery of lead using a secondary smelter.
Solidify/stabilize to pass TCLP, ifneeessary, and dispose of non-recyclable
components in the onsite containment cell.
Send roll-off boxes of bag house dust (K069) offsite to a RCRA permitted
Treatment, Storage, and Disposal (TSD) facility. Treatment and disposal of
the baghouse dust shall complay with all pertinent ARARs, including LDRs;
In general, the solidification/stabilization process consists of media size reduction with
metal and large debris removal, followed by a mhring process. Cont.Rminated media and
portland cement and/or lime are mixed with other binders such as fly ash or silicate
reagents to solidify/stabilize the media. This forms a monolithic mass of high structural
integrity, which binds the contJlminant within the matrix. -
ALTERNATIVE 8-4: ACID LEACHING
Alternative S-4 for soil and debris involves: acid leaching of lead-contaminated soil;
onsite backfimng of treated soil; decontamination of debris; secondary smelting of slag
and battery casings/chips, if recyclable, otherwise offsite disposal; and offsite treatment
and disposal of K069 baghouse dust. This alternative does not include such activities as
institutional controls, monitoring, or operations and maintenance since no contamination
or treated residuals would be present once treatment is complete. General treatment
methods for the diff~rent n:.:;dia are outlined below.
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- - u- - -'.. -, '. .'- _.- 'n
Soil;
Debris:
SlaglLead:
Battery
Casings!
Chips:
Baghouse
Dust:
- - .. _..u.---. - --- .
Excavate contaminated soil, treat all soil onsite by acid leaching, and backfill
excavated areas onsite with treated (i.e., clean) soil.
Decontaminate/treat debris using specific best demonstrated available
technologies (BDAT) based on the type of debris and the type of-
cont~minants present in the debris; recycle decont~minated debris that can
be recycled and dispose of non-recyclable decontHminHted debris offsite in a
non-hazardous landfill; debris which cannot be decont~minated will be
disposed offsite in a permitted hazardous waste landfill;
Package and ship slag that can be recycled to offsite permitted facility for
recovery of lead using a secondary smelter. If slag cannot be recycled,
solidify/stabilize the slag and dispose offsite in a permitted hazardous waste
landfill.
Package and ship battery casing components and battery chips that can be
recycled to an offsite permitted facility for recovery of lead using a secondary
smelter. Dispose of non-recyclable components that fail TCLP offsite in a
permitted hazardous waste landfill and dispose of non-hazardous, non-
recyclable components offsite in a non-hazardous landfill.
Send roll-off boxes of bag house dust (K069) offsite to a RCRA permitted
Treatment, Storage, and Disposal (TSD) facility. Treatment and disposal of
the baghouse dust shall comply with all pertinent ARARs, including LDRs;
In general, the acid leaching process begins with a soil washing/separation process to
remove clean soil fractions from the media to be treated. The fines ~e not treated by
tbis process but are bypassed to acid leaching for treatment. Only the larger fractions
are actually washed in this step. Once the clean soil fractions have been removed and
washed, the cont~min9ted soil fractions (generally the fines) undergo additional size
reduction to allow 1t'I9Y1mum surface contact during acid leaching. The contaminated.
media are then introduced into the appropriate leaching solution and agitated to ensure
thorough surface area contact between soil and leaching solution. The slurry is then
separated into clean soil and leachate, which is reused until it is no longer capable of
removing metals from the media. The spent leachate is then processed to remove the
metals, which are then ready for recycling at a secondary smelter. The used leaching
solution is also recycled back into the leaching process.
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GROUND WATER ALTERNATIVES
ALTERNATIVE GW.I: NO ACTION FOR GROUND WATER
The no-action alternative for ground water is included to serve as a baseline against
which other alternatives are compared. The only activity involved in the no-action
alternative is the posting of warning signs and the 5-year review which is mandated by
CERCLA whenever conVim;nated or untreated waste rem~ins onsite.
The no-action alternative involves no further remedial actions for ground water at OU-2.
The no-action alternative would entail limited activities, including:
The posting of warning signs along the fence line of the ILCO Main Facility
to indicate the presence of hazardous or toxic wastes.
5-year reviews as required by CERCLA. The purpose of these reviews would
be to evaluate the effectiveness of the no-action alternative. The 5-year
reviews would include limited ground water sampling and analysis activities
to identify trends in the distribution and magnitude of cont=:Im;nation in the
ground water.
The purpose of these activities would be to limit exposure to Site-related conVim;nants
with a m;nima1 commitment of funds or onsite activities.
ALTERNATIVE GW.2: CONTAINMENT OF GROUND WATER
Alternative GW-2 uses a containment system to prevent the ground water contamination
from migrating any further ofIsite. A ground water extraction system would pump water
from the shallow, intermediate, and deep zones of the aquifer creating a hydraulic
barrier along the downgradient margin of the conVim;nation, thereby preventing further
migration.
Alternative GW-2 is designed to take full advantage of the existing water treatment
facility at the ILCO Main Facility. However, an alternative treatment system may be .
used if the existing system is not available. The components of Alternative GW-2
include an extraction system of trenches and wells, a ground water treatment plant, an
effiuent discharge to the Unnamed Tributary adjacent to the ILCO Main Facility, and
institutional controls.
The ground water treatment components of Alternative GW-2 consist of oil/water
separation, carbon adsorption, chemical precipitation, and flocculation/clarification. Both
free phase and dissolved hydrocarbons would be removed through physical separation
and carbon adsorption. Inorganics would be removed from solution in the form of
im;cluble solid precipitates. The solids formed are then separated from th.e wastewarer
by settling, clarification, and/or polis~urocesses.
25
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Institutional Controls
Appropriate institutional controls, such as deed restrictions, may be required with
respect to the !LCO Main Facility and all properties within a reasonable distance
downgradient of the ground water contamination. These controls would prohibit the
drilling of new water supply wells and the use of ground water for potable supply.
Monitoring would be performed on selected onsite monitoring wells and wells outside the
area of restricted use to monitor the movement of the ground water contamination. This
will provide data as to any potential threat to water supply wells located north of the
ILCO Main Facility.
Monitoring activities, as stated above, would be used to track migration of the
contsnnination. Monitoring would include annual ground water sampling and analyses of
a selected group of wells.
The selection of wells to be monitored would be completed during the remedial design
phase.
ALTERNATIVE GW-3: PRECIPITATIONIFLOCCULATION
The purpose of the ground water remediation system in Alternative GW-3 is to.restore
ground water quality within the aquifer underlying OU-2 by remediating ground water
to cleanup concentrations. The ground water extraction system would pump from the
shallow, intermediate, and deep zones of the aquifer. Extracted ground water would be
treated and subsequently discharged to the Unnamed Tributary adjacent to the ILCO
Main Facility.
Alternative GW-3 is also designed to take full advantage of the existing water treatment
facility at the ILCO Main Facility. However, an alternative treatment system may be
used if the existing system is not available. The components of Alternative GW-3
include an extraction system of trenches and wells, a ground water treatment plant, and
an eflluent discharge system.
The treatment system in this alternative is the same as the one for Alternative GW-2,
but the volume of ground water to be extracted and treated in this alternative is greater
than in Alternative GW-2.
Institutional Controls
The institutional controls for Alternative GW-3 are the same as proposed in
.Alternative GW-2.
26
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ALTERNATIVE GW-4: ION EXCHANGE
The purpose of the ground water remediation system in Alternative GW-4 is to restore
ground water quality within the aquifer underlying OU-2 by remediating ground water
to cleanup concentrations. Alternative GW-4 is a pump-and-treat system in which the
ion exchange process is used to remove toxic inorganics from the aqueous phase in
exchange with relatively harmless ions held by the ion exchange material. The
components of Alternative GW-4 include an extraction system, a ground water treatment
plant, and effiuent discharge to surface water. Extracted ground water would be treated
and subsequently discharged to the Unnamed Tributary adjacent to the ILCO Main
Facility.
The ground water treatment components of Alternative GW-4 consist of oil/water
separation, carbon adsorption, and ion exchange. Both free phase and dissolved
hydrocarbons would be removed through physical separation and carbon adsorption.
Inorganics would be removed from solution by exchanging hazardous cations with
nonhazardous cations through a medium of resin beds specifically designed for the
inorganic of concern.
Institutional Controls
The institutional controls for Alternative GW-4 are the same as proposed in
Alternative GW-2.
8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial action alternatives selected for OU-2 were formulated to provide a range of
discrete options to attain the remedial action objectives established for OU-2. These
alternatives generally satisfy NCP requirements regarding the development of
alternatives, including treatment to address principal threats and a range of treatment
options that vary in the degree of treatment as well as the type and quantity of treated
residuals or untreated waste requiring long-term management.
This section documents the comparative analysis conducted to evaluate the relative
performance of each alternative in relation to each of the evaluation criteria. The
purpose is to identify the relative advantages and disadvantages of each alternative.
The key tradeoffs that must be balanced in the selection of remedy can then be
identified. As stated in the NCP [40 CFR 300.430 (£)], the evaluation criteria are
arranged in a hierarchial manner that are then used to select a remedy for a site based
on the following categories:
Threshold Criteria:
Over~! i '. Protection of Human Health and the Enviror~m~nt
Compliance with ARARs
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Primary Balancing Criteria:
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume
8hort- Term Effectiveness
Implementability
Cost
Modifying Criteria:
State Acceptance
Community Acceptance
COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES FOR SO~
Overall Protection of Burnap Health and Environment
Alternative 8-1 (No Action) would not provide protection of human health or the
environment. ContJlminants would not be isolated from direct contact by the public and
would continue to leach into the ground water. Alternative S-2 (ContRinment) would
isolate the contRminRnts tbrough capping, but protectiveness is contingent upon long-
term maintenance of the engineering controls that will be used to isolate the
conwminated materials from the environment. Alternative S-2 thus accomplishes the
remedial action objective for soil by preventing further exposures but does not represent
a permanent remedy for OU-2.
Alternative 8-3 (Solidification/Stabilization) provides an additional level of protectiveness
over Alternative 8-2 by treating the waste prior to onsite disposal but is also dependent
on a long-term maintenance program to maintain this protectiveness. Alternative 8-4
(Acid Leaching) provides the highest level of protection of any of the remedial
alternatives for soils, as all wastes and soil contamination above health-based levels are
removed from OU-2.
Compliance with ARABs
Since both RCRA listed and characteristic waste are present at the ILCO Main Facility,
all the alternatives involving handling, treatment, storage, and/or disposal of these
materials must comply with the appropriate RCRA requirements, including, under
certain circumstances, RCRA LDRs. Alternatives 8-2, 8-3, and 8-4 all employ the same
method for addressing the K069 baghouse dust - offsite treatment and disposal at a
ReRA permitted TSD facility. Once the listed waste has been removed from OU-2, the
characteristic waste need only be treated to below RCRA TCLP limits to comply with the
. LDRs. The 8-2 (ContJlinment) and 8-3 (Stabilization) alternatives would be designed
and implemented so as not to trigger the RCRA LDRs. The onsite treatment units used
for stabilization and acid leaching of con~ated soils determined to be RCRA
28
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hazardous wastes would have to comply with RCRA requirements for treatment units.
The requirements complicate, but do not preclude, the implementation of Alternative 8-3
or 84. Alternative S-2, involving consolidation and capping in place, would have the
least onerous ARAR commitments. The most difficult to implement in compliance with
ARARs would be 8-3 because the onsite activities include both treatment and disposal.
Alternatives S-2, 8-3, and S4 would be designed and implemented to meet all other
ARABs. Alternative 8-1, No Action, does not meet all identified ARABs.
Long-Term Effectiveness and Permanence
The lowest level of residual risk and the highest degree of permanence are associated
with Alternative S4 (Acid Leaching), which involves removal of all soil contamination
above health-based levels. ContSlm;nated soils are also treated in Alternative S-3
(Solidification/Stabilization), but the stabilized residuals are left onsite, and effectiveness
depends on long-term maintenance of the cap and other engineering controls.
Alternative 8-3 provides a higher level of permanence than Alternative 8-2, where no
soil treatment is employed and residual risk levels are much higher. The no-action
alternative is not considered to be either effective or permanent in addressing risks from.
OU-2.
Reduction of Toxicity, Mobility, or Volume
The no-action alternative (8-1) would not affect the toxicity, mobility, or volume of
conbnninated soils or wastes at OU-2. For contSlm;nated soil, Alternative 8-2
(Containment) achieves a reduction in mobility (but not in toxicity or volume) by .
isolating the contSimination under a multi-media cap. Alternative 8-3 (Solidification!
Stabilization) achieves an even greater reduction in mobility through binding of
COnVlmin8nts in a matrix highly resistant to leaching and disposal of stabilized soils in a
RCRA-type containment cell. A drawback to stabilization is the increase in the volume
of contaminated (albeit stabilized) material reynain;ng onsite. Alternative S4 (Acid
Leaching) achieves the greatest reductions in toxicity, mobility, and volume through the
removal of all contamination above health-based levels from onsite soil.
Alternatives S-2, 8-3, and S4 involve treatment of the slag that can be recycled at a .
secondary smelter, while the K069 baghouse dust is sent to a RCRA permitted TSD
facility. Treatment of slag in a secondary smelter is consistent with technology-based
treatment standards under RCRA and would result in a reduction of toxicity, mobility,
and volume; the end result is pure lead that will be reused in manufacturing and
smelter byproduct. Sending the baghouse dust to a RCRA permitted T8D facility for
treatment and disposal in accordance with LDRs would result in a reduction in the
volume of waste at OU-2. .
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Short-Term. Effectiveness
Alternative 8-1 (No Action), involving no onsite remediation activities, would result in no
additional risks. to the community or workers beyond those currently associated with
OU-2. All other soil remediation alternatives (8-2, 8-3, and S-4) involve excavation and
processing of contaminated material. Differences in the short-term effectiveness of these
more aggressive soil alternatives are not significant; potential impacts to the community,
site workers, and the environment can be minimized through proper use of engineering
controls, monitoring, and appropriate health and safety procedures.
Because Alternative S-2 (Cont~inment) entails the excavation/handling of a smaller
volume of contaminated material, it would be less likely to have an adverse impact to
the community and/or workers.
Time required to achieve protectiveness has been estimated at 2 to 3 years for
Alternatives S-2, 8-3, and 8-4. Although the time frames are similar, the levels of
protectiveness obtained at the end of this 2- to 3-year period are not equivalent.
Alternatives S-2 and 8-3 attain the remedial action objectives through containment and
solidification/stabilization technologies, but both leave waste onsite, and protectiveness is
contingent upon maintenance of engineering control measures. Alternative S-4 involves
a permanent solution for OU-2 that results in removal of all cont~mination above health-
based levels; at the end of the 2- to 3-year construction period, protectiveness will be
attained with no further need for engineering controls.
Implementability
Alternative 8-1 (No Action) is the most easily implemented as it entails no remedial
design or construction activities. Implementation of Alternative S-2 (Cont~inment)
would require coordination between EP A and the state because of the long-term O&M
activities necessitated by leaving untreated waste at the Site. Site-specific treatability
studies are required prior to implementation of Alternative 8-4 (Acid Leaching). Bench-
scale treatability studies have already been performed on OU-2 soil that would enhance
the implementability of Alternative S-3 (Solidification/Stabilization); however, the
landfill siting issue could require extensive predesign studies and administrative
coordination prior to implementation of this alternative. Alternative 8-4 (Acid Leaching)
involves a relatively complex treatment train but is likely to be easier to implement than
Alternative 8-3 (Solidification/Stabilization) because it does not include an onsite
disposal cell.
Cost
A summary of the present worth, capital, and O&M costs for each of the alternatives is
presented in Table 8-1. Alternative 8-1 is the least expensive, while Alternative 8-4 is
the most expensive.
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TABLE 8-1
Summary of Present-Worth Costs for Soil and Ground Water Cleanup Alternatives
TOTAL
ALT. TOTAL PRESENT
NO. DESCRIPTION CAPITAL COST O&M COST WORm COST
Soil Alternatives
S-1 No Action for Soils 513,00> 5134,00> $147,00>
S-2 Containment of Soils $16,092,00> $1,286,00> $17,378,00>
S-3 Stabilization 527,215,00> 51,285,00> $28,500,00>
5-4 Acid Leaching $34,764,00> 50 $34,764,00>
GrolU1d W81t:c Alternatives
GW-l No Action for GIOlU1d Water $13,000 $148,000 $161,000
GW-2 Containment. of GrolU1d Wa1.er: $611,000 $7,015,000 $7,626,000
GW-3 PrecipitationJF].occulation $688,00> $6,739,000 $7,427,00>
GW-4 Ion Exchange $1.284,00> $7,805,000 $9,089,00>
COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES FOR GROUND
WATER
Concerns as to the technical practicability of capturing CQntSiminated ground water will
be investigated in detail during predesign ground water ,~tudies. Available data indicate
that contaminants directly below the source area at OU~2 (i.e., the former battery
cracking area) are mobile and, therefore, recoverable. As a result, the ground water
alternatives presented in Section 7.0 of the ROD and the following comparative analysis
of the ground water alternatives are based, at a mimimum, on the ground water below
the source area at OU-2. IfEPA determines from the results of the the pre~esign
ground water studies that it is technically impracticable to remediate portions of the
aquifer outside the source area because the contSiminants are immobile and, therefore;
not recoverable, then the no action alternative would be protective for those pOrtions of
the aquifer due to the absence of an exposure pathway. However, ifEPA determines
from the results of the predesign ground water studies that contSiminants are mobile in
any portion of the aquifer outside the source area, then the following comparative
analysis of the ground water alternatives will also apply to those portions of the aquifer,
as well as the source area at OU-2. .
Overall Protection of Human Health and the Environment
Alternative GW-l (No ACti:J::i) would not provide £01:' protection "fhuman health or the
en~onment in the areas of the aquifer where contaminants are mobile, as the ground
31
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water contRmin~tion would continue to migrate in the absence of remedial response
measures. Alternative GW-2 (Containment) would be protective, but only if long-term
maintenance, monitoring, and enforcement of institutional controls are performed. The
uncertainty associated with these long-term actions reduces the overall protection of
human health and environment that can be expected from Alternative GW-2.
Alternatives GW-3 (Precipitation/Floccu1ation) and GW-4 (Ion Exchange) would provide
comparable levels of protection of human health and the environment, assnming that the
proposed extraction systems are capable of capturing the contamination and restoring
ground water quality at OU-2.
Compliance With ARABs
Alternative GW-l (No Action) would not comply with ARARs in the areas of the aquifer
where ground water restoration is technically practicable, nor is there justification at
this time for an ARARs waiver. Alternative GW-2 (Cont.slinment) would not comply with
State of Alabama ARARs for ground water restoration; the waivers necessary to select
this alternative would require additional supporting data. Alternatives GW-3
(PrecipitationlFlocculation) and GW-4 (Ion Exchange) would be designed to attain
chemical-specific ARARs for ground water (wbich formed the basis of the OU-2 ground
water cleanup goals); however, the ability of these actions to restore the aquifer to these
levels has not been established due to complex hydrogeologic conditions. The ground
water treatment systems for GW-2, GW-3, and GW-4 would be designed and operated to
meet effiuent guidelines and applicable water quality standards for discharge of treated
ground water. There are no significant differences regarding compliance with ARARs for
Alternatives GW-3 and GW-4. .
Long-Term Effectiveness and Permanence
Because Alternative GW-l (No Action) would not impact the existing risks at OU-2, it.
would be least effective in accomplishing the remedial action objectives. Alternative GW-
2 (ContSiinment) provides for long-term isolation of the contRmination, with institutional
controls to prevent exposure to conwmin~ted ground water. Alternative GW-2 does not
involve ground water remediation and relies heavily on engineering and institutional -
controls to remain effective; therefore, it may not represent a permanent remedy.
The lowest level of residual risk and highest degree of permanence would be associated
with successful implementation of Alternatives GW-3 and GW-4 (assuming these actions
are able to capture and extract cont::lmin~ted ground water such that ground water
cleanup goals are attained). These alternatives involve treatment of the contaminated
ground water using carbon adsorption and either precipitation! flocculation or ion
exchange technology for the removal of organic and inorganic contamin~nts. Both
alternatives result in cross-media transfer of risk, generating residuals that must be
managed. Proper management of these residuals would be incorporated into the
operation and maintenance :plan for the t.1'eatment system. Final disposition of the
32
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residuals is likely to entail thermal destruction of organic residuals and the disposal of
inorganic residuals in an appropriate RCRA disposal facility. These measures would
reduce the level of residual to negligible levels.
ReductioD of Toxicity, Mobility, or Volume
Alternative GW-l (No Action) has no impact on either the toxicity, mobility, or volume of
ground water contamination; Alternative GW-2 (Containment) would decrease the
mobility of the contSlmination and would therefore have some impact on the volume of
contamination (through treatment of water extracted to create the barriers) but would
have little impact on the toxicity of contaminated ground water. Alternatives GW-3 and
GW-4 are expected to accomplish significant reductions in mobility, toxicity, and volume
through extraction and treatment of cont8minated ground water.
Short-Term Effectiveness
Implementation of Alternative GW-l (No Action) would result in no additional risk to the
community or remedial construction workers. Alternatives GW-2, GW-3, and GW-4
utilize similar ground water extraction, treatment, and discharge systems, which would
be designed, installed, and operated using procedures and safety precautions that
minimize risk to the community. These more aggressive ground water altern~tives are
also comparable in the potential risk to remedial construction workers. Alternatives
GW-2, GW-3, and GW-4 all involve treatment of contaminated ground water; however,
potential exposures and risks would be controlled through use of personal protective
equipment, monitoring, and rigid conformance with a Site-specific health and safety
plan. Overall, the short-term effectiveness is more or less equivalent for Alternatives
GW-2, GW-3, and GW-4. None of the alternatives are expected to involve measurable
environmental impacts.
The time required to achieve protection is greater for Alternative GW-l (No Action).
Both containment (GW-2) and the aquifer restoration alternatives (GW-3 and GW-4)
create hydraulic barriers that minimize further offsite migration of contSlminated ground
water; protectiveness would be achieved once the capture zones for the extraction
systems have developed. Because start-up of the extraction system is dependent on
completion of the treatment system, Alternatives GW-2 and GW-3, which use the
existing treatment system at OU-2, would be protective sooner than Alternative GW-4,
which entails construction of a new treatment facility. Protectiveness as measured by
actual remediation of the ground water aquifer would be attained only through
successful implementation of Alternative GW-3 or GW-4, both of which entail a more
aggressive pump-and-treat strategy than that associated with Alternative GW-2.
Although the actual remediation time cannot be quantified at this time, the overall time
required to achieve protection would be similar for Alternatives GW-3 and GW-4 (Le.,
the time is independent of the type of treatment system used).
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Implementability
Alternative GW-1 (No Action) is most easily implemented. Alternatives GW-2
(Containment) and GW-3 (PrecipitationlFloccu1ation) are easily implemented using the
existing wastewater treatment system at OU-2 and can therefore be considered
equivalent. Alternative GW-4 (Ion Exchange) may utilize some of the equipment
currently onsite as equalization tanks; however, most equipment would have to be
procured and is therefore not as easily implemented as GW-2 or GW-3. All of the
treatment processes under consideration in Alternatives GW-2, GW-3, and GW-4 are
highly reliable and proven treatment technologies.
The technical practability of att.slining the ground water cleanup goals within a
reasonable time frame in the shallow, intermediate, and deep zones at OU-2 cannot be
determined at this time. Therefore, the technical practability of successfully
implementing Alternatives GW-3 and GW-4 has more uncertainty than that associated
with Alternatives GW-1 and GW-2. Additional ground water studies during the
predesign phase are required to determine the technical practacability of Alternatives
GW-3 and GW-4.
Cost
A S11mmary of the present worth, capital, and O&M costs for each of the alternatives is
presented in Table 8-1. Alternative GW-1, as expected, is the least expensive, followed
by Alternative GW-2 and GW-3, which take advantage of the wastewater treatment
system currently available at the ILCO Main Facility. The most expensive alternative is
alternative GW-4. O&M costs for GW-3 and GW-4 were estimated at 20.years, while
O&M costs for GW-1 and GW-2 were estimated at 30 years.
9.0 SUMMARY OF SELECTED SOn.. AND GROUND WATER REMEDIES
Based upon consideration of the requirements of CERCLA, the NCP, the detailed
analysis of alternatives and public and state comments, EPA has selected a soil and
ground water remedy for OU-2. The total present worth cost of the selected soil and -
ground water remedies, Alternatives 8-4 and GW-3, is estimated at $42,191,000.
A Soil Remedy
A.I The major comDonents of the soU remedy to be
imDlemented include:
Based on the comparative analysis performed on the soil alternatives in Section 8.0,
EP A's preferred soil remedy for OU-2 is Alternative 8-4, Acid Leaching. This alternative
includes:
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Conduct a Site-specific field-scale treatability study to
determine the effectiveness of the acid'leaching process on au-
2 soil during the design phase;
Excavate contslmin9ted soil and treat soil onsite to established
performance standards by acid leaching (excluding soil where
the water treatment facility is located);
Transfer and treat cont~m-inated soil and sludge from the large
and small covered waste piles by acid leaching (Note: If sludge
has previously been stabilized and, therefore, cannot be treated
via acid leaching and fails TCLP, the sludge will be disposed
offsite in a permitted hazardous waste landfill);
Transfer and treat cont~m-in9ted soil contained in the
Interstate Trucking Building by acid leaching;
Backfill excavated areas onsite with treated (i.e., clean) soil,
grade, and revegetate areas once backfilled;
Dismantle existing surface structures not intended to remain;
decontaminate/treat all debris onsite using specific best
demonstrated available technologies (BDAT) based on the type
of debris and the type of cont~m-inants present in the debris;
recycle decontaminated debris that can be recyled; dispose of
decontslminated debris that cannot be recycled offsite in a non-
hazardous landfill; decontamination/treatment must be
performed in accordance with specified performance and design
and operating standards for BDAT technologies; treaters of the
debris must comply with the applicable residue analysis,
notification, certification, recordkeeping, and other
requirements; debris which cannot be decontam-inated will be
disposed offsite in a permitted hazardous waste landfill;
Decontslm-inate any rema-ining buildings and/or structures
onsite;
Package and ship slag that can be recycled to an offsite
permitted facility for recovery of lead using a secondary
smelter. If slag cannot be recycled, stabilize and dispose of the
slag offsite in a permitted hazardous waste landfill;
Package and ship battery casing components and battery chips
that can be recycled to an offsite permitted facility fCl. j.'.?covery
of lead using a secondary smelter. Dispose of non-recyclable
35
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contaminated components that fail TCLP offsite in a permitted
hazardous waste landfill and dispose of non-hazardous, non-
recyclable components offsite in a non-hazardous landfill;
Send roll-off boxes of bag house dust (K069) offsite to a RCRA
permitted Treatment, Storage, and Disposal (TSD) facility.
Treatment and disposal of the baghouse dust shall complay
with all pertinent ARARs, including RCRA LDRs;
Monitor air emissions from OU-2 during remedial action
activities. Air monitoring will be conducted to ensure that
contslminant concentrations do not exceed levels considered to
be safe for human health. If levels are exceeded, mitigative
procedures such as dust suppression, vapor capture, or other
EP A-approved methods will be employed to prevent harmful
levels of air emissions from leaving OU-2; and
Appropriate institutional controls may be required with respect
to the ILCO Main Facility to prohibit future residential land-
use of the property.
Note: Contaminated soil in the vicinity of the onsite water treatment facility will
not be addressed until after ground water treatment is complete in order to
facilitate the potential use of the existing water treatment facility.
The cost of the selected soil remedy, acid leaching, is estimated to be $34,764,000.
Acid LeachinS! Treatability Study
A Site-specific field-scale treatability study to determine the effectiveness of the acid
leaching technology on soil at the ILCO Site will be performed during the remedial
design phase. The treatabi1j.ty study will be designed to accomplish the following
objectives:
1.
Determine if the acid leaching technology is amenable to
removing or lowering lead and arsenic concentrations in soil at
the ILCO Site to below established performance standards.
2.
Determine if the acid leaching technology can be implemented
at the ILCO Site for treatment of contaminated soil in a cost-
effective and timely manner.
The cost-effectiveness of the acid leaching remedy will be evaluated by EPA, in
consultation with the State, by 1) weighing the long-term benefits of the acid
leaching technology (i.e., a clean site that may be re-developed) against the cost
36
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and 2) comparing the cost to implement the acid leaching remedy, with
consideration of the long-term benefits, to the cost to implement the contingent
remedy (solidification/stabilization). The timeliness of the implementation of the
acid leaching remedy will be evaluated by EP A, in consultation with the State, by
comparing the time to implement the acid leaching remedy, with consideration of
the long-term benefits, to the time to implement the contingent remedy
(solidification/stabilization).
Contin2ent Remedy
If EPA, in consultation with the State, determines from the results of the treatability
study that the acid leaching technology cannot be implemented in a cost-effective and
timely manner and/or will not meet the required performance standards as set forth in
Paragraph A2, solidification/stabilization will be implemented.
The major components of the contingent remedy, solidification! stabilization, include:
o
Excavate cont.aminated soil (excluding soil where the water
treatment facility is located); treat soil failing TCLP onsite by
solidification/stabilization, and dispose of all soil (treated and
untreated) onsite in an engineered conta1nJpent cell with a
multi-media bottom liner (including leachate collection) and a
RCRA Subtitle D multi-media cap;
.
Transfer and treat contaminated soil and sludge from the large
and small covered waste piles by solidification/stabilization;
.
Transfer and treat contam1n~ted soil contained in the
Interstate Trucking Building by solidification/stabilization;
.
Construct an engineered conta1nment cell onsite. The
engineered containment cell will be designed to meet existing
minimum technological requirements for landfills. The
engineered containment cell cap will be a RCRA Subtitle D cap
constructed of five layers with a leachate collection system and
multi-media bottom liner;
.
Backfill excavated areas onsite with clean fill;
.
Grade and revegetate excavated areas once backfilled;
.
Dismantle existing surface structures not intended to remain;
decontaminate/treat all debris onsite using specific best
demonstrated. available technolog~d (BDAT) based va the type
of debris and the type of contaminants present in the debris;
37
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recycle decontaminated debris that can be recycled; dispose of
decontSiminated debris that cannot be recycled offsite in a non-
hazardous landfill; decontamination/treatment must be
performed in accordance with specified performance and design
and operating standards for BPAT technologies; treaters of the
debris must comply with the applicable residue analysis,
notification, certification, recordkeeping, and other
requirements; debris which cannot be decontSiminated will be
disposed offsite in a permitted hazardous waste landfill;
Decontaminate any remRining buildings and/or structures
onsite.
Package and ship slag that can be recycled to an offsite
permitted facility for recovery of lead using a secondary
smelter; non-recyclable slag will be solidified/stabilized to pass
TCLP and disposed in the onsite containment cell;
Package and ship battery casing components and battery chips
that can be recycled to an offsite permitted facility for recovery
of lead using a secondary smelter; non-recyclable components
will be solidifed/stabilized to pass TCLP, as necessary, and
disposed in the onsite contAinment cell;
Send roll-off boxes of K069 baghouse dust offsite to a RCRA
permitted Treatment, Storage, Disposal (TSD) facility.
Treatment and disposal of the baghouse dust shall comply with
all pertinent ARARs, including RCRA LDRs;
Monitor air emissions from OU-2 during remedial action
activities. Air monitoring will be conducted to ensure that
contSiminant concentrations do not exceed levels considered to
be safe for human health. If levels are exceeded, mitigative -
procedures such as dust suppression or vapor capture will be
employed to prevent harmful levels of air emissions from
leaving OU-2; and
Appropriate institutional controls, such as fencing and posted
warning signs, may be required to limit access and inform the
public of the dangers of exposure. Additional institutional
controls may also be required with respect to the ILCO Main
Facility to limit future use of the Site. Since waste will be left
onsite, a long-term monitoring program will be implemented,
including five-year reviews as required by CERCLA to evaluate
the performance of the solidification/stabilization remedy.
38
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Note: Contaminated soil in the vicinity of the onsite water treatment facility
would not be addressed until after ground water treatment is complete in order to
facilitate the potential use of the existing water treatment facility.
The cost of the contingent remedy, solidification/stabilization, is estimated to be
$28,500,000.
The selected remedy and the contingent remedy for soil at OU-2 are consistent with the
requirements of Section 121 of CERCLA and the National Contingency Plan. Both the
selected remedy and the contingent remedy are believed to be protective of human
health and the environment, will attain all Federal and State ARARs, will reduce the
mobility, toxicity, or volume of cont.Am;nated soil at OU-2, and will utilize permanent
solutions and alternative treatment technologies to the m~nnmum extent practicable.
A.2. Performance Standards for Soils
Acid Leachin~
The Performance Standards for the soil component of the selected remedy include, but
are not limited to, the following excavation and treatment standards:
Con~m;n8ted soil and related materials shall be excavated from the areas of
contamination. Excavation shall continue until the remaining soil achieves the
following maximum lead concentration levels (performance standards). A
sampling program will be conducted to determine the actual volumes of surface
and subsurface soil requiring remedial action. Testing methods approved by EP A
shall be used to determine if the ma,nmum allowable lead concentrations have
been achieved in the soil remaining in the ground. All soil exceeding the following
performance standards will be treated by the acid leaching technology.
Medium
Performance Standard for Lead
Soil with Low pH (pH < 5)
Soil with Normal pH (pH> 5)
150 ppm
1000 ppm
Testing methods approved by EP A shall be used to determine if the maximum
allowable lead concentration of 1000 ppm has been achieved in all treated soil.
The soil from the low pH area will be neutralized to a normal pH level during the
acid leaching treatment process; therefore, all soil, including the soil from the low
pH area, will be treated to the performance standard (1000 ppm) established for
lead in normal pH soil.
Testing, using EPA-approved methods, shall also be performed to determine if the
maximum al1t>wable :arsenic concentratiQn has been achieved in the soil remainjng
in the ground, as well as all the treated soil, as follows:
39
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Medium
Performance Standard for Arsenic
Surface Soil
13 ppm
During the field-scale treatability study to be performed at OU-2, the established
cleanup levels (performance standards) for both lead and arsenic will be used to
determine the effectiveness of the acid leaching technology. Soil will need to be
treated to a standard of 1000 ppm lead and 13 ppm arsenic to be considered
"clean" soil. The 1000 ppm standard for lead is based upon protection of human
health for a future commercialrmdustrialland-use of OU-2 and is also protective of
ground water. The 13 ppm standard for arsenic is based upon the average
background level for arsenic in surface soil at OU-2.
Solidification/Stabilization
The Performance Standards for the soil component of the contingent remedy include, but
are not limited to, the following excavation and treatment standards:
ContoSlminated soil and related materials shall be excavated from the areas of
contJ:lmination. Excavation shall continue until the remaining soil achieves the
following maximum lead and arsenic concentration levels (performance standards).
A sampling program will be conducted to determine the actual volumes of surface
soil and subsurface soil requiring remedial action. Testing methods approved by
EP A shall be used to determine if the mSlYimum allowable lead and arsenic
concentrations have been achieved in the soil remaining in the ground. All soil
exceeding the following performance standards will be treated by the
solidification/stabilization technology.
Medium
Performance Standard
Lead:
Soil with Low pH (pH < 5)
Soil with Normal pH (pH> 5)
150 ppm
1000 ppm
Arsenic:
Surface Soil
13 ppm
Testing, using EP A-approved methods, will be performed to ensure that the
solidification/stabilization process effectively immobilizes the conWmin8J1ts of
concern at the Site. The solidification/stabilization process will be effective if the
treated soil from the Site achieves the following requirements:
40
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. - "'" .
1.
The boiling point of the cont$lmimmts to be stabilized must be
higher than the boiling point of water. The temperature of the
process should not exceed 130 degrees F.
2.
The TCLP leachate from solidified/stabilized soils will be
required to, at a minimum, yield a leachate that does not
exceed the established performance standards (cleanup levels)
for the cont$lminants of concern at the Site.
3.
Total Waste Analysis (TWA) will be utilized and compared to
the original analysis of waste using the same extraction
procedures. A 90 percent reduction in concentration or
mobility of the cont$lminated soil and other waste after
treatment is the treatment target. (This target is consistent
with Superfund's guidelines for effective treatment, which
recommend a treatment range of 90 to 99 percent reduction in
the concentration or mobility of the contaminants of concern).
However, the 90 percent reduction in contaminant
concentration or mobility is a general guidance and may be
varied within a reasonable range considering the effectiveness
of the technology and the performance standards (cleanup
levels) established for the Site. Although this policy represents
EP A's strong belief that TW A should be used to demonstrate
effectiveness of immobilization, successful achievement of other
leachability tests may also be required in addition to TW A to
evaluate the protectiveness of the treatment.
4.
In addition, the solidification/stabilization mixture will be
required to achieve a minimum of 50 psi compressive strength
and must demonstrate a permeability of 1X10-s or less.
Soils and other waste from the Site requiring treatment by solidification/stabilization
which do not comply with these standards will be disposed offsite in a permitted
hazardous waste landfill. During the early stages of the Remedial Design, the treatment
standards will be used to determine the effectiveness of the solidification/
stabilization technology. Treatment and disposal actions shall comply with all pertinent
applicable or relevant and appropriate requirements (ARARs).
B. GROUND WATER REMEDY
Based on the comparative analysis performed on the ground water alternatives in
Section 8.0, EPA's preferred ground water remedy for OU-2 is Alternative GW-3,
treatment of ground water using a precipitation/flocculation pump and treat system.
Tho Dbjecti7e of the selected gl"ound water remedy is to restore ground water to its
beneficial use, which is a potential drinking water source. Based on information
.
41
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obtained during the remedial investigation, and the analysis of all remedial alternatives,
EP A believes that the selected remedy may be able to achieve this objective. However,
the ability to achieve the established performance standards at all points throughout the
area of contslm1nation cannot be determined until predesign ground water studies are
conducted. Therefore, the selected ground water remedy will be refined, as necessary,
during the predesign phase.
If EP A determines from the results of the predesign ground water studies that portions
of the ground water aquifer outside of the source area at OU-2 cannot be restored to its
beneficial use due to the contam1mmts not being mobile and, therefore, not recoverable,
the following measures involving long-term management may occur as a modification to
the existing ground water remedy:
a.
Chemical-specific ARARs will be waived for the cleanup of
those portions of the aquifer based on the technical
impracticability of achieving further contam1nant reduction;
b.
Institutional controls will be provided/maintained to restrict
access to those portions of the aquifer which cannot be restored
and remain above performance standards; and
c.
Monitoring of specified wells will be conducted for an indefinite
period of time as designated by EP A. .
If ground water restoration is shown to be technically impracticable in certain portions of
the aquifer, ground water restoration will occur only in those areas where contaminants
are recoverable. Where restoration is possible, the ground water extraction system will
pump from the shallow, intermediate, and deep zones of the aquifer. Extracted ground
water will be treated and subsequently discharged to the unnamed tributary adjacent to
the ILCO Main Facility. The estimated cost of the selected ground water remedy is
$7,427,000.
B.I. The major compOnents of the In"Ound water remedy to be
imulemented include: .
Conduct additional ground water investigations on OU-2 to fill
necessary data gaps and determine the technical practicability
of restoring the ground water aquifer to its beneficial use;
The following activities will be implemented for all portions of the contam1nated aquifer
where restoration is determined by EP A to be technically practicable based on the
results of the predesign ground water studies:
.
42
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.
Pump contaminated ground water from the shallow,
intermediate, and deep zones of the aquifer using a ground
water extraction system of trenches and wells;
.
Treat the ground water contam;nated with inorganics via
precipitation/flocculation technology using the existing onsite
water treatment plant, if available; if the existing treatment
system is not available, an alternative system may be used;
.
Segregate ground water from the shallow extraction system
from the intermediate and deep ground water for treatment of
both free phase and dissolved phase hydrocarbons. Shallow
ground water will pass through an organics treatment system
before entering the treatment train for inorganics shared
with ground water extracted from the intermediate and deep
zones;
It
Discharge treated effiuent, meeting applicable requirements, to
the Unnamed Tributary adjacent to the ILCa Main " Facility;
and
e
Implement institutional controls for ground water, as
necessary.
The ground water treatment components of the selected ground water remedy consist of
oil/water separation, carbon adsorption, chemical precipitation, and flocculation!
clarification. Both free phase and dissolved hydrocarbons would be removed through
physical separation and carbon adsorption. Inorganics would be removed from solution
in the form of insoluble solid precipitates. The solids formed are then separated from
the wastewater by settling, clarification, and/or polishing processes. .
Predesign Ground Water Studies
The purpose of the predesign studies is to enable EP A to determine the areas and zones
of the aquifer where restoration is technically practicable. The studies shall determine
the mobility and recoverabilitY of the inorganic contaminants, as well as determine the
areal extent of organic contamination at aU-2.
Additional data shan be collected, as necessary, to determine 1) the influence of local
geology (i.e., fractures, faults, and formations) and nearby ground water withdrawals on
the migration potential of ground water contam;nation from aU-2 and 2) the potential
impacts on ground water from residual soil cont~m;n~tion.
A field-scale pomp aild t:tt:d~ investigation 1:tlli:t.;..g the existing IUO:Jitoring wells and
treatment system, as appropriate, shall be implemented as part of the predesign studies.
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This pump and treat investigation shall be centered around the source area (i.e., former
battery cracking area) at OU-2. This field-scale pump and treat investigation, as well as
an in-depth investigation of the rems:lining portions of the contslmin~ted aquifer, will be
used by EPA, in consultation with the State of Alabama, to determine the technical
practicability of restoring the ground water aquifer to its beneficial use.
Institutional Controls
Appropriate institutional controls, such as deed restrictions, may be required with
respect to the ILeO Main Facility and all properties within a reasonable distance
downgradient of the ground water cont;s:lmination. These controls will prohibit the
drilling of new water supply wells and the use of ground water for potable supply.
Monitoring will be performed on selected onsite monitoring wells and wells outside the
area of restricted use to monitor the movement of the ground water contamination. This
will provide data as to any potential ~at to water supply wells located north of the
ILCO Main Facility. .
Monitoring activities, as stated above, will be used to track migration of the
cont.s:lmination. Monitoring will include annual ground water sampling and analyses of a
selected group of wells.
Selection of wells to be monitored will be completed during the remedial design phase.
B.2. Performance Standards for Ground Water
a. Treatment Standards
IfEPA determines from the results of the predesign ground water studies that it is
technically practicable to restore all or portions of the conUiminated aquifer at OU-2,
ground water shall be treated until the following maximum concentration levels
(performance standards) are attained in the aquifer (or portions of the aquifer), at the
wells to be designated by EP A as compliance points. It may become apparent during the
implementation or operation of the treatment system that levels of cOntamination in the
ground water have ceased to decline and are remaining constant at levels higher than
the performance standards. In such a case, the system's performance may be re-
evaluated by EP A, in consultation with the State of Alabama.
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Contaminant of Concem
Performance Standard
Antimony
Arsenic
Beryllium
Cadmium
Lead
Manganese
Nickel
Benzene
1,2,4- Trimethylbenzene
1,3,5- Trimethylbenzene
6.0 ppb
50.0 ppb
4.0 ppb
5.0 ppb
15.0 ppb
510.0 ppb
100.0 ppb
5.0 ppb
51.0 ppb
41.0 ppb
b. Discharge Standards
Discharges from the ground water treatment system shall comply with all ARARs,
including, but not limited to, substantive requirements of the NPDES permitting
program under the Clean Water Act, 33 U.S.C. 1251 et sea., and all effiuent limits
established by EP A.
c. Operation Standards
The operation of any ground water treatment system shall be conducted in accordance
with all Performance Standards and applicable federal and state requirements.
C. Compliance Monitorinl!
Ground water monitoring shall be conducted at OU-2. After demonstration of .
compliance with all Performance Standards, OU-2 ground water shall be monitored for
at least five years. If ground water monitoring indicates that the Performance
Standards set forth in Paragraph B.2 are being exceeded at any time after monitoring
and/or pumping has been discontinued, extraction and treatment of the ground water
will recommence, if technically practicable, until the Performance Standards are once
again achieved.
Monitoring will not be required as part of the selected soil remedy (acid leaching)
because no waste above es~lished performance standards will be left onsite. However,
if acid leaching does not meet performance standards during the treatability study and
solidification/stabilization is implemented, soil monitoring will be required for at least
five years. If monitoring of the treated soil under the solidification/stabilization remedy
indicates that Performance Standards set forth in Paragraph A.2 have been exceeded,
the effectiveness of the soil remedy component will be re-evaluated by EP A, in
consultation with the State of Alabama.
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I
Air emissions during the cleanup will also be monitored to ensure the safety of workers
and residents near OU-2. Air monitoring will be conducted to ensure that contaminant
concentrations do not exceed levels considered to be safe for human health. Iflevels are
exceeded, mitigative procedures such as dust suppression, vapor capture, or other EPA-
approved methods will be employed to prevent harmful levels of air emissions from
leaving OU-2.
10.0 STATE ACCEPTANCE
The State of Alabama, as represented by the Alabama Department of Environmental
Management (ADEM), has been the support agency during the Remedial Investigation!
Feasibility Study process for the ILCa Site. In accordance with 40 CFR 300.430, as the
support agency, ADEM has participated in this process. The State of Alabama, as
represented by ADEM, has concurred with the selected remedy. .
11.0 COMMUNITY ACCEPTANCE
Based upon comments expressed at the proposed plan public meeting and written and
oral comments received during the public comment period, the reaction of the Leeds
community to the selected remedy at the ILCO Site has been favorable.
12.0 STATUTORY DETERMINATION
EP A's primary responsibility at Superfund Sites is to undertake remedial actions that
are protective of human health and the environment. In addition, Section 121 of
CERCLA establishes additional statutory requirements and preferences. These specify
that, when complete, the selected remedy must also meet all Federal and State ARARs,
be cost effective, and utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable. CERCLA also
includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous substances as their
principal element. A review will be conducted within five years from commencement of
the remedial action for ground water and for soil, if the contingent remedy is
implemented, to ensure that the remedy continues to. provide adequate protection of
human health and the environment. The following sections discuss how the selected and
contingent remedy for soil at OU-2 and the selected remedy for ground water at OU-2
meets these statutory requirements.
12.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Both the selected remedy and the contingent remedy for soil and the selected remedy for
ground water is protective of human health and the environment. The selected soil
remedy, acid leaching, provides the highest level of protection of any of the remedial
alternatives for soil, since all wastes and soil contamination greater than established
cleanup levels will be permanently removed_from OU-2. The selected ground water
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remedy, a pump-and-treat system using precipitation/flocculation, is also protective of
human health and the environment. .
Actual or threatened releases of hazardous substances from OU-2, 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.
12.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs)
The selected remedy must comply with the substantive requirements of federal and state
laws and regulations which have been determined to constitute applicable or relevant
and appropriate requirements (ARARs).
Applicable requirements are those cleanup standards, control standards, and other
substantive environmental protection requirements, criteria, or limitations promulgated
under federal or state law that specifically address a hazardous substance, pollutant,
cont.Rm;nant, remedial action, location, or other circumstance at a Superfund site.
Relevant and appropriate requirements are those cleanup standards, control standards,
and other substantive environmental protection requirements, criteria, or limitations
promulgated under federal or state law that, while not "applicable" to a hazardous
substance, pollutant, cont.Rm;nant, remedial action, location, or other circumstance at a
Superfund site, address problems or situations sufficiently similar (relevant) to those
encountered and that are well-suited (appropriate) to circumstances at the particular
site.
Chemical Specific ARABs
Chemical-specific ARARs are specific numerical quantity restrictions on individually-
listed chemicals in specific media. Table 12-1 lists chemical specific ARARs for OU-2 of
the ILCO Site.
Safe Drinkinl! Water Act. MCLs and MCLGs: Alabama's Primarv Drinkinl!.Water
Standards. Maximum con~m;nant levels (MCLs) and Maximum Contaminant Level
Goals (MCLGs) promulgated under the authority of the Safe Drinking Water Act
(SDW A) are specifically identified in Section 121 of CERCLA as well as the NCP as
remedial action objectives for ground waters that are current or potential sources of
drinking water supply. The ground water underlying the ILeO Main Facility is
classified as a Class IT-A ground water (i.e., potential source of drinking water)
under EPA's Guidelines for Ground-Water Classification. MCLs and non-zero MCLGs
are therefore relevant and appropriate as remedial action objectives for ground water
cleanup for OU-2. Alabama's primary drin1cing water standards are also relevant and
appropriate b~ca1f~b they set standards for potential sources of drimring water.
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TABLE 12-1
CHEMICAL SPECIFIC ARABS
n..CO SUPERFUND SITE
CITATION EXPLANATION
R&A Safe Drinking Water Act, MCLs and MCLGs Maximum contaminant levels (MCLs) and maximum
42 U.S.C. f300 contaminant level goals (MCLGs) promulgated under the
40 C.F.R. Part 141 Safe Drinking Water Ad. and Alabama's Primary
Drinking Water Standards set standards for potential
Alabama Primary Drinking Water Standards . sources of drinking water.
Ala. Admin. Code. 335-7-2
R&A Clean Water Act, Ambient Water Quality Federal Ambient Water Criteria are developed as
Criteria, 33 U.S.C. f12S1 et. seq. guidance for the states to develop ambient surface water
40 C.F.R. Part 131 quality standards that will be fully protective--of human
Alabama Water Quality Standards health and the environment. Alabama's Water Quality
Ala. Admin. Code 335-6-10 Standards set forth numerical and narrative standards
for ambient ground water and surface water in the State
of Alabama.
A Clean Water Ad. NPDES requirements regulate the discharge of any
National Pollution Discharge Elimination pollutant or combination of pollutants to waters of the
System Regulations United States from any point source.
33 U.S.C. fl251 et. seq
40 C.F.R. Parts 121. 125. 129. 133. and 136
Alabama Pollution Discharge Elimination
System Regulations
Ala. Admin. Code 335-6-6
-
A Resource Conservation and Recovery Act Land disposal restrictions establish treatment standards
42 U.S.C f6901 et. seq. which must be met before hazardous wastes may be
40 C.F.R Part 268 land disposed.
Alabama Hazardous Waste Regulations
Ala. Admin. Code 335-14
Clean Water Act. Ambient Water ~bama .Water Qua1itv Stand~.
Ambient Water Quality Criteria (AWQC) are specifically identified in Section 121 of
CERCLA as remedial action objectives. A WQC are developed as guidance for the states
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to develop ambient surface water quality standards that will be fully protective of
human health and the environment. A WQC are relevant and appropriate to the selected
remedy and the discharge of the treated effluent from the Site must not result in
ambient surface water concentrations that exceed those chemical-specific AWQC.
'Alabama's Water Quality Standards are relevant and appropraite as they set forth
numerical and narrative standards for ambient ground water and surface water in the
State of Alabama.
Clean Water Act National Pollution Disch e Elimination S stem DES' Alabama
peDartment o~ronmental...Manaeement Water Quali..JL.Proeram: National...£Q..llution
Disch e Elimination S tem Re ations. NPDES requirements regulate the
discharge of any pollutant or combination of pollutants to waters of the United States
from any point source. The substantive requirements of the NPDES permitting program
are applicable to the selected remedy because the discharge of treated ground water to
the unnamed tributary will constitute a point source discharge to waters of the United
States.
Resource Conservation and Recovery Act (RCRA): Alabama DeDartment of
Environmental Manaeement Hazardous Waste Rerolations: Land DisDOsal Restrictions.
Land disposal restrictions establish treatment standards which must be met before
hazardous wastes may be land disposed. Land disposal restrictions are applicable. Both
acid leaching and solidification/stabilization involve treatment of con~minated soils and
on-site disposal. Therefore, the land disposal restrictions must be met before treated
soils may be redeposited.
Location-Specific ABARs
Location-specific ARARs are restrictions placed upon the. concentration of hazardous
substances or the conduct of activities on the basis of location. Table 12-2 lists location
specific ARARs for OU-2 of the ILCO Site.
TABLE 12-2 I
LOCATION SPECIFIC ARARS
ILCO SUPERFUND SITE
CITATION EXPLANATION
RkA Alabama Water Use Identifies surface water utilization classifications for the
Classification Regulations State of Alabama.
Ala. Admin. Code 335-6-11
_.~"'.- .. .- --
-_.' ,.
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Alabama's Water Use Classification for Interstate Waters Regulations. Dry Creek and
the unnamed tributary are classified as fish and wildlife streams and therefore,
Alabama's Water Use Classification for Interstate Waters regulations are applicable.
Action-Specific ARABs
Action-specific ARARs are technology or activity based requirements or limitations or
actions taken with respect to cleanup. Table 12-3 lists location specific ARARs for OU-2
of the ILCO Site.
TABLE 12-3
ACTION SPECIFIC ARABS
ILCO SUPERFUND SITE
CITATION EXPLANATION
A Resource Conservation and Recovery Act These regulations set forth the criteria for municipal solid
42 U.S.C ~6901 et. seq. waste landfills.
40 C.F.R. Part 258
Alabama Solid Waste Regulations
Ala. Admin. Code 335-13
A Resource Conservation and Recovery Act These regulations address the treatment, storage, and
42 U.S.C ~6901 et. seq. disposal of hazardous waste including the following: the
40 C.F.R Parts 261, 262, and 264 definition of those solid wastes which are subject to
regulation as hazardous, decontamination of debris,
Alabama Hazardous Waste Regulations storage of hazardous waste, and treatment of hazar:dous
Ala. Admin. Code 335-14 waste.
,Besource Conservation and...,Becoverv Act ~ous Waste ~ations:
Alabama pepartment o~nvironmenta1.....Mana(!ement (AD~ous Waste
Rerolations. The selected remedy involves the treatment, storage, and disposal of
hazardous waste. The selected remedy provides for the decontam;nation and disposal of
debris and the recycling or disposal of slag and battery components. Disposal of debris
that cannot be decontam;nated, and slag and battery components that cannot be recycled
if the acid leaching remedy is implemented, will be disposed in an offsite permitted
hazardous waste landfill. Regulations which define those solid wastes which are subject
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to regulation as hazardous are applicable. Regulations which address decontamination
of debris are also applicable. The selected remedy for soil, acid leaching, and the
contingent remedy for soil, solidification/stabilization, both involve treatment of
hazardous wastes and the selected ground water remedy involves the treatment of
contaminated ground water. Hazardous waste regulations which address the
management of hazardous wastes, including treatment and storage, are therefore
applicable.
Resource Conservation and..Becoverv Act ~ Waste ~ations: Alabama
DeDartment o~ronmenta1..Mana!!ement (AD~ Waste :}le!!Ulations. If the
contingent soil remedy, solidification/stabilization, is implemented, Subtitle D of RCRA is
applicable and the containment cell must meet the substantive requirements of Subtitle
D.
DeDartment o(1'ransDortation (~ons an4 OccuDational Safety and Health
~nistration (OS~ations. While DOT and OSHA regulations do not fall
within the technical definition of ARARs because they are not environmentally based,
they are nonetheless directly applicable to the extent they address activities associated
with the cleanup such as the transportation of hazardous materials and health and
safety requirements for workers at the Site.
12.3 COST EFFECTIVENESS
EPA believes the selected remedy for both soil and ground water for OU-2 will eliminate
the risks to human health and the environment at an estimated cost of $42,191,000.
Selected Soil Remedv
Although more costly than the other alternatives, the selected soil remedy provides the
best balance of evaluation criteria. The selected soil remedy has several advantages:
1.
The soil contJlm;nation can typically be monitored during the cleanup process to
determine when cleanup levels have been met.
2.
No waste streams are generated - only clean soil and concentrated metal product
ready for recycling at a secondary smelter.
3.
The treated (i.e., clean) soil is reusable onsite.
4.
No waste is left onsite; therefore, long-term operation and maintenance is not
required.
5.
Tfhe site may be reused :in the future.
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Contine:ent Soil Remedv
The contingent soil remedy, solidification/stabilization is protective of human health and
the environment, cost-effective, and meets all requirements (ARARs).
Ground Water Remedv
Based on the information available, the selected ground water remedy provides the best
balance of evaluation criteria and is the least expensive of the ground water alternatives
(except the no action alternative). The selected ground water remedy is fully protective,
cost-effective, and meets all requirements (ARARs), unless such requirements are
waived.
12.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM
EX,'l'ENT PRACTICABLE
EP A has determined that the selected remedy for both soil and ground water represents
the 1n~Yimum extent to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner at OU-2. Of those alternatives that are protective of
human health and the environment and comply with ARARs, EPA has determined that
the selected remedy provides the best balance of trade-oft's in terms of long-term
effectiveness and permanence, reduction in toxicity, mobility, or volume achieved
through treatment, short-term effectiveness, implementability, and cost, while also
considering the statutory preference for treatment as a principal element and
considering state and community acceptance.
12.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating the conVlm1nated soil and other material by acid leaching and the
contJ:l1n1nated ground water by a pump and treat system utilizing
precipitatioi1lflocculation, the selected remedy addresses the principal threats posed by
OU-2 through the use of treatment technologies. Therefore, the statutory preference f
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and the cleanup level for arsenic in surface soil at OU-2 from 3.3 ppm to 13 ppm.
As a result of the comments received during the Proposed Plan comment period and new
guidance currently being drafted on determ1n1ng lead cleanup levels for an industrial
site, EP A reevaluated the applicability of the 500 ppm cleanup level for lead in normal
pH soil at OU-2. EP A's reevaluation of the 500 ppm lead cleanup level was based
primarily upon EPA's 1989 Interim Guidance on Establishinl! Soil Lead Cleanup Levels
at Superfund Sites. which states that "lead in soil and dust appears to be responsible for
blood levels in children increasing above background levels when the concentration in
the soil or dust exceeds 500 to 1000 ppm. Site-specific conditions may warrant the use
of soil cleanup levels below the 500 ppm level or somewhat above the 1000 ppm level". A
cleanup level for lead in soil in the 500 to 1000 ppm range is considered to be protective
of human health in a residential setting. EP A originally proposed a cleanup level of 500
ppm for lead in normal pH soil at OU-2. However, since the ILCO Main Facility is
located in an area zoned for industrial land-use and 500 ppm is normally the cleanup
level selected for residential sites, EPA, in consultation with the State of Alabama,
determined that 1000 ppm is a more applicable cleanup level for lead in normal pH soil
at OU-2. This revised cleanup level is supported by the assumption of a future
commercialfmdustrialland-use of the Site. The 1000 ppm cleanup level for lead in
normal pH soil is also protective of ground water. Appropriate institutional controls may
be required to prevent future residential land-use of the Site.
In addition to re-evaluating the lead cleanup level in normal pH soil at OU-2, EPA also
re-evaluated the cleanup level for arsenic in surface soil at OU-2. EP A originally
proposed a cleanup level of 3.3 ppm for arsenic in surface soil based upon a future
commerciall industrial land-use of OU-2. However, it is EPA's policy not to set cleanup
levels below background levels for any con1;slm1n~mt of concern at a site. Upon re-
evaluation of the cleanup level for arsenic, EP A determined that the cleanup level of 3.3
ppm was less than the average background level of 13 ppm for arsenic in surface soil at
OU-2. Therefore, EP A determined that a cleanup level of 13 ppm is a more applicable
cleanup level for arsenic in surface soil at OU-2 based upon Site-specific average
background levels.
As a result of raising the cleanup level for lead in normal pH soil from 500 ppm to 1000
ppm, the volume of contSlm-inated soil to be excavated and treated decreased slightly (by
approximately 3500 cy). This decrease in the volume to be excavated and treated
resulted in a slight decrease in the total cost of both the acid leaching and the
solidification/stabilization soil alternatives. The cost for the acid leaching alternative,
based upon the 500 ppm cleanup level, was $35,551,000. The revised cost for the acid
leaching alternative, based upon the 1000 ppm cleanup level, is $34,764,000. The cost
for the solidification/stabilization alternative, based on the 500 ppm cleanup level, was
$29,034,000. The revised cost for the solidification/stabilization alternative, based on the
1000 ppm cleanup level, is $28,500,000. As a result, the total present worth cost of the
selected soil and ground wa°i;er yemedies for OU-2 decreased from $42,978,000 to
$42,191,000.
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Decision Summary
for the
Amendment to the Record of Decision
. for
Operable Unit One
Interstate Lead Company (lLCO) Site
Leeds, Alabama
1.0 INTRODUCTION
The Record of Decision (ROD) for Operable Unit One (OU-t) of the Interstate Lead
Company (ILCO) Superfund Site in Leeds, Alabama was signed on September 30, 1991.
This amendment to the ROD for OU-1 presents the modified selected remedy for OU-1.
This amended remedy was chosen in accordance with the Comprehensive Environmenta1
Response, Compensation and Liability Act (CERCLA) of 1980, as amended, and to the
extent practicable, the National Contingency Plan (NCP). This ROD amendment is
based on the administrative record for the ILCO Site and will become a part of the
administrative record file for OU-t. The ac1miniRtratiVe record for the ILCO Site is
available to the public at both the information repository maintained at the Leeds Public
Library at 802 Parkway Drive, S.E. in Leeds, Alabama and at the EPA Region N
Library at 345 Courtland Street in Atlanta, Georgia.
Based upon new developments, EP A re-evaluated the previously selected remedy for soil
contSlmination for OU-t. For consistency with the remedy selected for OU-2 and long-
term permanence, EPA is amending the selected remedy for OU-1 to use acid leaching
instead of solidification/stabilization for treatment of the excavated soils from the
satellite sites (if acid leaching meets performance standards during the Site-specific
treatability study to be conducted). The OU-1 remedy is also being amended to change
the location that the contSlmil1ated material from the satellite sites will be taken for
treatment. At the time that the ROD for OU-1 was signed (September 1991), the ILCa
Main Facility was still operating and, therefore, the contSlminated material from the
satellite sites could not be taken to the Main Facility for treatment. Now that the ILCO
Main Facility is no longer operating and is also being addressed under Superfund, the
contSlminated material from the satellite sites will be taken to the ILCO Main Facility
for treatment along with the waste from OU-2.
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2.0 Descrintion of the Previ"ously Selected Remedy and Modified Remedy for
OU.l
PREVIOUSLY SELECTED REMEDY FOR OU.l
The major components of the previously selected soil (source) remedy at each satellite
site in OU-l include:
A. The ILCO Parkin Lot and Flemin s Patio
. Excavation of soil with lead concentrations exceeding 300 ppm;
. Transportation of the excavated soil from the Fleming's Patio satellite site to the
ILCO Parking Lot where a centrally located treatment unit will be located;
. Replacing the treated soil back into the excavated areas (which includes
transporting the applicable treated material back to Fleming's Patio for placement
into the excavated areas);
. Removal of battery 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
ground water monitoring; and
. Semi-annual sampling and analysis of existing monitoring wells for the primary
metals associated with automotive batteries.
B. The Gulf Service Station. J & L Fabricators. The Connell Propertv. and the
Acmar Church of God.
. Excavation of soil with lead concentrations exceeding 300 ppm;
. Transportation of the excavated soil to the ILCO Parking Lot satellite site where a
centrally located treatment unit will be located;
. Treatment of cont.am;n9ted soil with a successfully demonstrated
solidification/stabilization process;
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o Placement of the solidified material into the ILCO Parking Lot satellite site or
replacement of the solidified material back into its original excavation area if there
are space limitations in the parking lot. (If treated wastes are placed at the parking
lot, then the satellite sites from which the material originated would not need five-
year reviews, Subtitle D closure, or deed restrictions. Instead, these subsites can be
backfilled with clean fill and revegetated.);
. Revegetation of excavated areas;
. Removal of sediments exceeding 50 ppm lead at the GulfiBP Service Station satellite
site, dewatering, and transporting the sediments to the ILCO Parking Lot for
treatment along with the cont-9m;nated soil; and
. Temporary relocation of the Connell property residents and the Acmar Church of
God congregation, if necessary.
C. The Citv of Leeds Municipal Landfill
. Construction of a multilayer compacted clay and geomembrane cap that would cover
area with soil exceeding 300 ppm of lead; and
. Institutional controls consisting of access and deed restrictions to protect the
integrity of the cap system and long-term ground water monitoring.
The major components of the previously selected ground water remedy at each satellite
site in OU-l include:
A. Gulf Service Station and Acmar Church of God
. No ground water remediation activities will be conducted at these satellite sites
since no contamination above risk-based standards was detected; and
. Long-term ground water monitoring will be conducted.
B. J & L Fabricators. flemin~s ~o. and...lhe ConnelLPropertv
. No ground water remediation activities will be conducted at these satellite sites.
Contaminants will naturally attenuate or lessen with time; and
. Long-term ground water monitoring will be conducted.
C. The City of Leeds Municipal Landfill
. Extraction of con~m;n~ted ground water
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. Treatment of cont$lmin~ted ground water onsite with a mobile chemica1/physica1
treatment unit;
. Discharge of the ground water onsite into the adjacent drainage way (surface
outfall); and
. Ground water monitoring during and after extraction is complete.
MODIFIED REMEDY FOR OU-l
The major components of the modified soil (source) remedy at each satellite site,
excluding the City of Leeds Municipal Landfill, in aU-l include:
. Excavate contaminated soil with lead concentrations exceeding 300 ppm (The 300
ppm cleanup level for the satellite sites is based upon protection of human health in
a residential setting and protection of ground water);
. Excavate and dewater sediments at the GulfYBP Service Station satellite site with
lead concentrations exceeding 50 ppm;
. Transport all con~min~ted soil and dewatered sediment to the ILCa Main Facility
for treatment along with aU-2 soil by acid leaching (or solidification/stabilization if
acid leaching does not meet performance standards during the treatability study);
. Remove slag, battery casings, and other debris from the satellite sites;
. Transport all slag, battery casings, and other debris to the ILCa Main Facility;
. Package and ship slag that can be recycled to an offsite permitted facility for
recovery of lead using a secondary smelter; non-recyclable slag will be solidified/
stabilized and disposed offsite in a permitted hazardous waste landfill, if acid
leaching is implemented; if solidification/ stabilization is implemented, non-
recyclable slag will be solidified/stabilized to pass TCLP and disposed in the onsite-
con~inment cell at the ILCa Main Facility;
. Package and ship battery casing components and battery chips that can be recycled
to an ofIsite permitted facility for recovery oflead using a secondary smelter; non-
recyclable components that fail TCLP will be disposed offsite in a permitted
hazardous waste landfill and non-hazardous, non-recyclable components will be
disposed offsite in a non-hazardous landfill, if acid leaching is implemented; if
solidification/stabilization is implemented, non-recyclable components will be
solidified/stabilized to pass TCLP, as necessary, and disposed in the onsite
contabment cell at the ILCO Main Facility;
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I
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. Deconwminateltreat debris using specific best demonstrated available technologies
(BDAT) based on the type of debris and the type of contaminants present in the
debris; recycle decontJIminated debris that can be recycled and dispose of
decont.aminated debris that cannot be recycled offsite in a non-hazardous landfill;
decont.amination/treatment must be performed in accordance with specified
performance and design and operating standards for BDAT technologies; treaters of
the debris must comply with the applicable residue analysis, notification,
certification, recordkeeping, and other requirements; debris which cannot be
decont.aminated will be disposed offsite in a permitted hazardous waste landfill;
decontaminate any remaining buildings and/or structures onsite;
. Backfill excavated areas at the ILCO Parking Lot with treated (i.e., clean) soil from
the acid leaching process (or clean fill if solidification/stabilization is implemented
instead of acid leaching);
. Backfill excavated areas at the other satellite sites, excluding the City of Leeds
Municipal Landfill, with clean fill;
. Revegetate excavated areas once backfilled; and
. Temporarily relocate Connell Property residents and Acmar Church of God
congregation, if necessary.
EPA is not amending the selected OU-I soil (source) remedy for the CitY of Leeds
Municipal Landfill or any of the selected OU-I ground water remedies. Therefore, the
description for these remedies are the same as presented above under the desription of
the previously selected remedy for OU-I.
For more detailed information, please see the ROD for OU-I and the ROD for OU-2.
3.0 SUMMARY OF THE COMPARATIVE ANALYSIS FOR THE PREVIOUSLY
SELECTED REMEDY VERSUS THE MODIFIED REMEDY FOR OU-I
This section documents the comparative analysis conducted to evaluate the relative
performance of the previously selected remedy and the modified remedy for OU-I in
relation to each of the evaluation criteria. The purpose is to identify the relative
advantages and disadvantages of each alternative. The key tradeoffs that must be
balanced in the selection of the remedy can then be identified. The following
comparative analysis does not include the City of Leeds Landfill satellite site.
Overall Protection of Human Health and Environment
Solidification/stabilization provides protectiveness by treating the waste prior to onsite
disposal but is also dependent on a long-te1"D.l.-maintenance program to maintain this
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protectiveness. The solidification/stabilization alternative is not considered to be a
permanent remedy for OU-l because these residuals remain a viable if somewhat
unlikely source of future exposure and risk. Acid leaching provides the highest level of
protection of any of the remedial alternatives for soil, as all wastes and soil
cont.:.mination above established performance standards (cleanup levels) will be
permanently removed from the satellite sites.
Compliance with ARABs
The solidification/stabilization alternative will be designed and implemented so as not to
trigger the RCRA Land Disposal Restrictions. The onsite treatment units used for
solidification/stabilization and acid leaching of contaminated soils determined to be
RCRA hazardous wastes will have to comply with RCRA requirements for treatment
units. The requirements complicate, but do not preclude, the implementation of both
alternatives. Solidification/stabilization would be the more difficult to implement in
compliance with ARARs because the onsite activities include both treatment and
disposal. Both alternatives would be designed and implemented to meet all other
ARARs.
Long-Term Effectiveness and Permanence
The lowest level of residual risk and the highest degree of permanence is associated with
acid leaching, which involves removal of all soil contamin8tion above established
performance standards (cleanup levels). Stabilization/solidification also treats
contaminated soils, but the stabilized residuals are left.onsite, and effectiveness depends
on long-term maintenance of the cap and other engineering controls.
Reduction of Toxicity, Mobility, or Volume
Solidification/stabilization achieves a reduction in mobility through binding of
contaminants in a matrix highly resistant to leaching and disposal of the stabilized soils
in a RCRA Subtitle D cont.:.inment cell. A drawback to stabilization is the increase in
the volume of contamin9ted (albeit stabilized) material rem9ining onsite. Acid leaching
achieves the greatest reductions in toxicity, mobility, .and volume through the removal of
all waste above established performance standards (cleanup levels) from aU-I.
Short-Term Effectiveness
Both soil remediation alternatives, solidification/stabilization and acid leaching, involve
exca:vation and processing of contaminated material. Differences in the short-term
effectiveness of these soil alternatives are not significant; potential impacts to the
community, site workers, and the environment can be minimized through proper use of
engin'";ering controls, monitoring, and appropriaw health and safety procedures.
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Time required to achieve protectiveness has been estimated at 2 to 3 years for both
alternatives. Although the time frames are similar, the levels of protectiveness obtained
at the end of this 2- to 3-year period are not equivalent. Solidification/stabilization
attains the remedial action objectives through stabilization technologies, but
protectiveness is contingent upon maintenance of engineering control measures. Acid
leaching involves a permanent solution that results in removal of all cont.$lmin9tion
above health-based levels; at the end of the 2- to 3-year construction period, .
protectiveness will be attained with no further need for engineering controls.
Implementability
A Site-specific treatability study is required prior to implementation of acid leaching.
Bench-scale treatability studies have already been performed on aU-1 and OU-2 soil
that would enhance the implementability of solidification/stabilization; however, the
landfill siting issue could require extensive predesign studies and administrative
coordination prior to implementation of the solidification/stabilization alternative. Acid
leaching involves a relatively complex treatment train but is likely to be easier to
implement than solidification/stabilization because it does not include an onsite disposal
cell.
Cost
A summary of the total estimated present worth cost for the previously selected remedy,
solidification/stabilization, is presented in Table 3-1 and a summary of the total
estimated present worth cost for the modified remedy, acid leaching, is presented in
Table 3-2.
4.0 STATUTORY DETERMINATION
EP A's primary responsibility at Superfund Sites is to undertake remedial actions that
are protective of human health and the environment. In addition, Section 121 of
CERCLA establishes additional statutory requirements and preferences. These specify.
that, when complete, the selected remedy must also meet all Federal and State ARARs,
be cost effective, and utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable. CERCLA also
includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous substances as their
principal element. A review will be conducted within five years from commencement of
the remedial action for ground water to ensure that the remedy continues to provide
adequate protection of human health and the environment. The following sections
discuss how the modified remedy for aU-1 meets these statutory requirements.
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TABLE 3-1
Total Estirmted Cost of Selected Soil Remedy for OU-l
SateDite Site
n..co Padcing Lot
Fleming's Patio
Gulf Service Station
J&L Fabricators
Connell Property
Acmar Church of God
City of Leeds Municipal Landfill
Description or Remedy
Total Estimated Cost
Solidificaion
Solidification
Solidification
Solidification
Solidification
Solidification
Multilayer Cap
$12,780,000
$ 4,700,000
$ 1,230,000
$ 3,250,000
$ 2,710,000
S 1,980,000
$ 1,520,000
Total:
$28,170,000
Note: The total CXJst shown abov~ does not include the CXJst for the selected ground water remedy for au-I. The total
ground water cleanup cost for aU-l is $839,000. Therefore, the total CXJst for soil and ground water cleanup for aU-l is
$29,009,000.
TABLE 3-2
Total Estimated Cost of EPA's Modified Soil Remedy for OU-l
Satellite Site
ILCQ Parking Lot
A6ning's Patio
Gulf Service Station
J&L Fabricators
Connell Property
Acmar Church of God
City of Leeds Municipal Landfill
Description or Remedv
.'
,.
Total Estimated Cost
/
Acid Leaching
Acid Leaching
Acid Leaching
Acid Leaching
Acid Leaching
Acid Leaching
Multilayer Cap
S 13.032,000
S 6,600,000
S 1,140,000
$ 3,791,000
$ 3,074,000
$ 2,189,000
$ 1.s2O,~
Total:
$31.346.000
. No change to soil mnecly Cor City or Leeds MuaicipallaDd.liU
Note: The total CXJst shown above does not include the cost for the selected groWld water remedy for aU-t. The total .
ground watcr cleanup cost for aU-l is $839,000, Therefore, the total modified cost for soil and ground water for QU-l is
$32,185,000.
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4.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The modified remedy is protective of human health and the environment. The modified
remedy, acid leaching, provides a higher level of protection for soil than the previously
selected remedy, solidification/stabilization, as all wastes and soil contamination greater
than established cleanup levels are permanently removed from OU-l.
Remedial actions performed under CERCLA must comply with all applicable or relevant
and appropriate requirements (ARABs). Both alternatives considered for OU-l were
evaluated on the basis of the degree to which they complied with these requirements.
The modified remedy and the previously selected remedy for OU-l will both meet or
exceed all Federal and State ARABs listed in Tables 12-1, 12-2, and 12-3 (unless such
requirements are waived), located in Section 12.0 of the ROD for OU-2.
4.3 COST EFFECTIVENESS
EPA believes the modified remedy for OU-1 will eliminate the risks to human health and
the environment for both the soil and ground water at an estimated cost of $32,185,000.
Although more costly than the previously selected remedy, the modified remedy provides
the best balance of evaluation criteria. The modified remedy has several advantages:
1.
The soil cont~mination can typically be monitored during the cleanup process to
determine when cleanup levels have been met. .
2.
No waste streams are generated - only clean soil and concentrated metal product
ready for recycling at a secondary smelter.
3.
The treated (i.e., clean) soil is reusable onsite.
4.
No waste is left onsite; therefore, long-term operation and maintenance is not
required.
5.
The site may be reused in the future.
4.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM
Ex'l'~NT PRACTICABLE
The modified remedy for OU-1 represents the mRximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-effective manner at OU-1.
Of those alternatives that are protective of human health and the environment and
comply with ARABs, EP A has determined that the modified remedy provides the best
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balance of trade-offs in terms of long-term effectiveness and permanence, reduction in
ooxicity, mobility, or volume achieved through treatment, short-term effectiveness,
implementability, and cost, while also considering the statutory preference for treatment
:is a principal element and considering state and community acceptance.
i.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating the contslminated soil and other waste by acid leaching, the modified remedy
for aU-! addresses the principal threats through the use of treatment technologies.
rherefore, the statutory preference for remedies that employ treatment as a principal
~lement is satisfied.
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APPENDIX A
RESPONSIVENESS SUMMARY
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Responsiveness Summary
ILCO Superfund Site
Record of Decision
Comment #1:
A cleanup plan of the ILCa Site should be implemented in the most expedient
manner which will result in decontamination of all effected soil and ground water
and return the same to usable condition, thus ensuring that the City of Leeds and
her citizens can plan for the twenty-first century with a sense of hope, pride and
confidence.
EPA's Response:
The selected soil and ground water remedies for remediation of the ILCa Site will
restore the Site to a usable condition by treating all contaminated soil, waste, and
ground water that are contaminated at levels greater than the established
performance standards. The selected soil remedy, .acid leaching, will leave no waste
onsite. However, acid leaching is an innovative technology and, as such, there is a
possibility that this technology may not be effective. In such event, a contingent soil
remedy, solidification/stabilization, will be implemented for treatment of the
contaminated soils. The remedial action at the Site will be implemented as
expeditiously as possible.
Comment #2:
A patented vitrification process used to immobilize lead-contaminated soils in
bricks would provide beneficial effects with regard to the ILCa Site with a
tremendous cost savings over the proposed soil remedy for the Site. Therefore,
this technology should be implemented at the ILCa Site instead of the proposed
remedy, acid leaching.
EPA's Response:
The information presented by Advanced Recycle Technology on their patented
vitrification process was insufficient to determine the applicability of this technology
for treating waste at the ILCa Site. During the review process the following
observations and concerns were noted:
-------
.
While the Advanced Recycle Technology treatment process contains
proprietary elements, it is similar to both ex-situ vitrification and stabilization
proceSs options which were considered in the ILCO Focused Feasibility Study.
No information was provided as to the number of sites at which this
technology has been applied, which brings into question the effectiveness and
implementability of the technology.
o
.
Due to the lack of details provided regarding Advanced Recycle Technology's
vitrification process, it is likely that permitting requirements for air emissions
could represent a significant complication associated with implementability.
.
H the addition of clay or another material was required to make bricks from
the waste material, an increase in the volume of waste would result.
.
Following treatment the contaminated materials may no longer be a RCRA
hazardous waste; however, the bricks would still contain a CERCLA waste and
would require long term monitoring and maintenance.
.
The cost data which was provided was not applicable for evaluation at the
ILCO Site since no kiln exists at the ILCO Site. The cost would likely be
similar to other vitrification costs of between $150/yd and $250/yd, which
would represent a total project cost of approximately $40,000,000.
Therefore, acid leaching is considered to be a superior solution based on the available
information.
Comment #3:
Hayes Targets has two facilities operating at the end of Borden Street next to the
old ILCO plant. Employees at Hayes Targets went through the first phase of the
cleanup and was inundated with the dust that came in while EPAwas conducting -
the removal action and stockpiling the soil. Hayes Targets recommends that °EP A
select either Altemative S-1, No Action, or Alternative 5-2, Containment, for soil.
EPA's Response:
The ROD for OU-2 states that air monitoring will be conducted during remediation
activities to ensure that contaminant concentrations in dust emissions do not exceed
levels considered to be safe for human health. H levels are exceeded, mitigative
procedures such as dust suppression or vapor capture will be employed to prevent
harmful levels of air emissions from leaving OU-2.
2
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r-
Comment #4:
What is the relative cost of no action for soil and ground water contamination at
the ILCa Site in terms of impact on the community, environmental degradation,
and water hazard and is that cost greater than the projected cost due to no
implementation?
EPA's Response:
The no action alternative for soil and ground water contamination at the ILCO Site is
included to serve as a baseline against which other alternatives are compared. The
no action alternative does not meet all nine evaluation criteria set forth in the NCP
and does not provide protection of human health or the environment. If the no
action alternative was selected, contaminants would not be isolated from the public
and would continue to leach into the ground water at the Site. In the absence of
remedial response actions, contaminated ground water could continue to migrate
offsite and eventually impact city supply wells located approximately one-half of a
mile from the ILCO Main Facility.
Comment #5:
Who would be doing the recycling component of the acid leaching and will there
be any money generated from the recycling and, if so, has any recovery of cost
been computed in the estimation of the total cost to implement the acid leaching
remedy?
EPA's Res1'0nse:
Lead recovered from the acid leaching process will be sent off to a secondary smelter
for recycling. Some money may be generated as a result of recycling the recovered
lead; however, EPA did not include any recovery of cost for the recycling component
in the acid leaching cost estimate.
Comment #6:
Has acid leaching been implemented successfully in Region 4? If not, in what
other EP A regions has it been done and what were the cost overruns that ran with
it in comparison to what the original estimate was? What's the downside of
actually doing a combination of treatment at the ILCa site, such as capping the
ILCa Main Facility and sending the soil and other material in the stockpile off to
a RCRA landfill for disposal, and either solidifying the contaminated soils from
the satellite sites or treating the contaminated soils from the satellite sites by acid
leaching.
3
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EP A's ResDonse:
The acid leaching technology has not previously been implemented in Region 4. It is
currently being implemented in Region 5 at the Twin Cities Army Ammunition Plant
in Minneapolis, Minnesota. The acid leaching process, combined with a soil washing
process, has been successful thus far at that particular Site on lead-contaminated soil.
EPA Region 4 is not aware of the differences in the actual cost for implementation
versus the estimated cost at that particular Site. A treatability study will be
conducted at the ILCO Site during the design phase to determine if the acid leaching
process is amenable to the types of soil at the ILCO Site. The treatability study will
also be used by EP A, in consultation with the State of Alabama, to evaluate the cost-
effectiveness of the acid leaching technology with respect to the ILCO Site. In
evaluating the cost-effectiveness of the remedy, EP A will weigh the long-term
benefits of acid leaching against the cost to implement the remedy at the ILCO Site.
EPA will also compare the cost of the acid leaching remedy, with long-term benefits
taken into consideration, to the cost of the contingent remedy, solidification/
stabilization. H EP A determines from the results of the treatability study that acid
leaching cannot be implemented in a cost-effective and timely manner and/or will
not meet the required soil performance standards, solidification/stabilization, will be
implemented.
Capping the ILCO Main Facility would leave untreated waste onsite. Capping or
containment of the contaminated soil at the ILCO Main Facility would essentially cut
off infiltration which would reduce the potential for further ground water
contamination; however, it would not eliminate the source completely (Le., the low
pH water and material). Therefore, the threat to the ground water would continue,
with two city supply wells located within one half of a mile from the ILCO Main .
Facility. Removing the source of ground water contamination rather than leaving it
in place is a more protective remedy. In addition, there is also a preference in the
current Superfund law for treating waste as opposed to just containing the waste
onsite.
.,
Comment #7:
Does EP A know if the ground water flow is from the ILCa Main Facility towards
the city wells at this time?
EPA's Response:
The ground water system is very complex at the ILCO Site. Data from the RI
indicates that the gradient from the Site is towards the city supply wells. Monitoring
wells at the ILCO Main Facility respond to pumping at the city supply wells.
Therefore, there is a hydraulic connection between the Site and the city wells. While
the exact flow path and flow times to reach the wells is not known at this time, the
4
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connection does exist. Therefore, the best action to take to be protective of human
health is to prevent ground water contamination from migrating offsite through a
pump and treat extraction system. Due to the complex geology in the area, which is
highly fractured, faulted, folded, and uplifted, there are still a lot of uncertainties
which will be investigated during predesign ground water studies for OU-2.
Comment #8:
Does the GulfIBP Service Station satellite site located across the street from the
Leeds Elementary School have a 12 inch cap of clay on top of it? When will the
GulfIBP Service Station site be cleaned up?
. EP A's Response:
EP A is not aware of a 12 inch clay cap at the Gulf/BP Service Station satellite site.
The Gulf/BP Service Station site will be remediated as part of the remedy for OU-l
of the ILCO Site. Remediation of the Gulf/BP Service Station site will be
implemented as expeditiously as possible.
Comment #9:
The Little Cahaba and the Dry Creek both run into Lake Purdy. Is EPA going to
take fish samples from Lake Purdy, which supplies water to the City of
Birmingham?
EPA's Response:
EP A is not currently planning to take fish samples from Lake Purdy as it is not
located in dose proximity to the ILCO Main Facility. However, EPA is conducting a
study of Dry Creek, which is located adjacent to the ILCO Main Facility property.
Fish samples will be taken from Dry Creek as part of this study. EP A will track lead
contamination from the ILCO Main Facility downstream in Dry Creek until lead
contamination is no longer considered to be a threat to human health or the
environment.
Comment #10:
There is northwest directed fracture zones and the Cahaba Valley fault moving
toward the northwest towards the drinking water source for the City of Leeds.
~as EP A considered stopping the pumping of water out of the Lehigh Quarry and
does EPA think that stopping the pumping at the quarry would have a significant
effect in reducing the migration rate of contamination from the ILCa Main
Facility?
5
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EP A's Response:
EPA does not feel that stopping the pumping of water out of the Lehigh Quarry
would be a positive influence on the system at this time. The pumping from the
quarry may have a strong influence on the migration of ground water in the area.
The quarry is currently dewatered to an elevation around 370 feet, which is
approximately 200 feet below the water level present at the ILCO Main Facility.
Therefore, the quarry is having a major influence on ground water flow in the area.
However, there is not sufficient data to determine the exact influence of the quarry
on ground water flow at the ILCO Main Facility at this time. This influence will be
investigated as part of the predesign ground water studies to be conducted at OU-2.
Comment #11:
Is the pumping rate at the quarry pulling the water in the same direction as the
city supply wells?
EPA's Response:
The interconnections of the faults and fractures in the area are not known at this
time. However, there is a strong vertical gradient, which may be caused by the
pumping from the quarry. Since no lead has been detected in the city supply wells
to date, EP A believes that the fracturing system and the pumping from the quarry
may be preventing migration from reaching the city wells. Additional data will be
gathered during predesign ground water studies to examine this possibility further.
Comment #12:
Have there been any reports of people in the Leeds area being affected by lead?
EP A's Response:
The Agency for Toxic Substances and Disease Registry (ATSDR) took blood samples
from children in the Leeds area several years ago in relation to the ILCO Site, but
elevated levels of lead were not significant at that time.
Comment #13:
What are the health effects of lead on people in the Leeds community? Who is at
risk more, a child or an adult?
6
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EPA's Response:
Elevated lead levels in the blood and effects on the central nervous system may result
from continual elevated lead exposure. Children are more at risk from lead exposure
than adults. Significantly more lead is taken up into the blood in children from
ingestion of lead than in adults. Therefore, higher lead levels occur in the blood of
children than in the blood of adults from the same exposure. The Alabama
Department of Public Health (ADPH) indicated that it will be conducting a study in
the near future on health effects related to the ILCO Site. If the ADPH determines
from their study that health problems related to the ILCO Site exist in the
community, they will make recommendations to ATSDR for appropriate actions.
Comment #14:
What's the concern with the central nervous system?
EP A's Response:
There is concern about the central nervous system not developing properly, such as
decreased learning skills.
Comment #15:
Are there any motor skills involved in a health impact to the central nervous
system?
EPA's ResDonse:
Yes, there could be motor skills involved. The motor skills involved would probably
be affected at higher lead levels than the learning skills. However, there could be
effects on all parts of the central nervous system if the exposure was high enough or
long enough.
Comment #16:
Was the risk assessment done on the corrective actions that will be taking place as
opposed to just the Site as is and its impact?
EPA's Response:
By definition, the risk assessment is a baseline risk assessment which considers the
site in its present condition (i.e., nothing is done to. clean up the Site). Therefore, the
risk assessment is done to determine if the site as it is now ~1.Lrrently poses a risk to
human health and the environment.
7
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Comment #17:
Are our children that are in the elementary school across the street from the
GulfIBP Service Station at risk?
EPA's Response:
EP A does not feel that the children are at risk just by attending the elementary school
located across the street from the Gulf/BP Service Station site. There is no Site-
related risk involved unless the children ingest significant amounts of soil or
sediment from the contaminated areas on the Gulf/BP Service Station site. The
remedial action at the Gulf/BP Service Station site will be implemented as
expeditiously as possible to alleviate any risk associated with that site.
Comment #18:
The parking lot at ILCO is in the flood plain, so you could have some sediment
problems there. Is this being addressed?
EP A's Response:
Surface water and sediment contamination associated with the ILCO Main Facility
and the ILCO Parking Lot is being addressed under Operable Unit Three for the
ILCO Site.
Comment #19:
Did you look at air pathways in your health based risk assessment and are you
going to look at those pathways in relationship to past deposition of material on
adjacent lands?
EPA's Response:
I
I -
I
I
The baseline risk assessment, by its nature, looks forward into what exposures and
resultant risks could occur if nothing is done to remediate a site. The baseline risk
assessment considered the air exposure pathway and there may be some risk from
inhaling lead-contaminated dust particles, but the air pathway was really insignificant
compared to the ingestion pathway. Assessment of past emissions and potential past
exposures falls under the authority and expertise of ATSDR or ADPH.
Comment #20:
Have the former ILCO employees been tested for lead?
8
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EP A's Response:
EP A is not the appropriate agency for testing employees. EP A is not aware if ILCO
had a standard of testing employees on a regular basis while the facility was
operating or if such testing was required or done by the Occupational Safety and
Health Administration (OSHA). The ADPH may address this issue as part of their
study on the ILCO Site.
Comment #21:
What pathways did EP A identify in the baseline risk assessment as the potential
receptolS?
EP A's Response:
The primary route of exposure evaluated in the Baseline Risk Assessment for both
soil and ground water at the ILCO Site was ingestion. There may also be lesser
contributions from absorbing the lead through the skin or inhaling lead-contaminated
dust particles. However, ingestion is the most important route for getting lead into
the blood.
Comment #22:
Will the satellite sites be closed while they are being cleaned up?
BPA's Response:
The necessity of closing the satellite sites during remedial action activities will be
evaluated during the design phase of the remedial action. It may be necessary to
close the sites during this time in order to be protective of human health. During the
design phase, EP A will work very closely with the satellite site owners to minimize
any inconvenience and problems for them. However, we will certainly have to look
at protection of human health as the primary concern.
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Comments Submitted by the Steering Committee for the Potentially
Res onsible Parties PRPs at the ILCa Site
PRP Steering Committee Comment #1:
EP A bas proposed acid leaching for soil (containing slag, matte, and battery
fragments at OU-2 and six OU-l satellite areas) and for concrete and other debris.
Tbe PRP Steering Committee is proposing an alternative remedy, consisting of
excavation, stabilization/fixation, and capping at the ILCO Main Facility. Tbe
advantages of the Steering Committee's proposal include the following:
.
Stabilization/fixation and capping involves proven technologies that have been
adopted by EPA at numerous.lead-contaminated sites throughout Region IV and the
rest of the nation. In contrast, acid leaching is an experimental technology that
requires significant development prior to full-scale utilization at secondary lead
smelter sites. For materials other than soil, acid leaching is not yet even in the
development stage, has failed at one site (the United Scrap Lead site in Ohio) with
batteI}' cases, and may be infeasible and result in the generation of dangerous
hydrogen sulfide gases. Acid leaching also may involve difficult material separation
processes (also unproven and which will generate lead dust> and, in all cases, involves
complicated treatment systems. Based on information from prospective vendors, the
Steering Committee also believes that separation of batteI}1 cases, slag, matte, and
other debris (by an unproven technology) would be required and the separated
material (if feasible) would need to be managed in a separate manner. The Steering
Committee's proposal requires far less time for process development and design. Due
to the length of time required for development, design and implementation of an acid
leaching remedy, and due to the experimental nature of the remedy, the Steering
Committee does not believe this technique will gain the support of local residents
who have expressed a desire for expeditious implementation of a remedy. The cost
for an acid leaching remedy will exceed the cost of stabilization/fixation by more than
$52 million.
EPA's Response:
Acid leaching will be used for treatment of contaminated soil, sludge, and sediment
only. All other wastes and debris will be separated from the soil and treated by
other EP A approved methods. .
Stabilization/fixation and capping do involve proven technologies that have been
adopted by EP A at numerous lead-contaminated sites. However, stabilization/
fixation and capping would leave waste onsite that would require long-term
maintenance.
Acid leaching is an innovative technology that has not been widely used by EP A at
other lead-contaminated sites. However, it is a permanent remedy that will leave no
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waste onsite. Other benefits of the acid leaching remedy include: 1) soil
contamination can typically be monitored during the cleanup process to determine
when cleanup levels have been met; 2) no waste streams are generated - only clean
soil and concentrated m"etal product ready for recycling at a secondary smelter; and
3) the treated (i.e., clean) soil is reusable onsite. In addition, the acid leaching
remedy satisfies the statutory preference for utilizing permanent solutions and
innovative treatment technologies to the maximum extent practicable.
A Site-specific field-scale treatability study on the acid leaching technology will be
conducted prior to implementation of the remedy at the ILCO Site to determine (1) if
acid leaching is amenable to the types of soil at the ILCO Site, (2) if acid leaching can
accomplish established performance standards (clean-up levels) for soil at the ILCO
Site, and (3) if acid leaching can be implemented at the ILCO Site in a cost-effective
and timely manner. Material handling processes for separating other wastes from the
soil will also be investigated as part of the treatability study. The separated materials
and other contaminated waste and debris will be treated by other EP A-approved
methods. In addition, material handling and separation will also be required for the
contingent remedy, solidification/stabilization, if implemented.
The citizens of Leeds have expressed a desire for expeditious implementatio~ of a
remedy; however, they have also expressed a desire to have the Site returned to a
usable condition for re-development.
EPA's initial cost estimates indicate that the cost of acid leaching will exceed the cost
of solidification/stabilization by approximately six million dollars. However, EPA, in
consultation with the State of Alabama, will evaluate the cost-effectiveness and
timeliness of the acid leaching remedy based upon the results of the treatability
study. If the results of the treatability study indicate that acid leaching cannot be
implemented in a cost effective and timely manner, the contingent remedy,
solidification/stabilization, will be implemented.
PRP Steering Committee Comment #2:
The PRP Steering Committee urges EP A to recalculate site specific cleanup levels
for soil in light of the analytical data collected during the remedial investigations
and EPA's recent guidance for selecting lead cleanup levels in soil. Site-spedfic
soil excavation to a concentration not less than 1,000 mg Pblkg is a compromise
level more stringent than necessary to protect human health and the environment.
The Steering Committee also urges EP A to consider pH control of soil by chemical
treatment as a means of minimizing potential leaching of inorganic constituents
from the soil to the subsurface. Chemical treatment/pH adjustment of soils is a
proven technique selected by EP A at other Superfundllead battery reclamation
sites.
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EPA's Response:
EP A re-evaluated the proposed cleanup levels for lead and arsenic in soil at OU-2.
Based upon this re-evaluation, as documented in Section 13.0 of the ROD for OU-2,
EP A, in consultation with the State of Alabama, determined that 1000 ppm is a
protective cleanup level for lead in normal pH soil at OU-2, an area zoned for
industrial land-use. Therefore, EP A raised the cleanup level for lead in normal pH
soil at OU-2 to 1000 ppm. EP A also determined that 13 ppm is a protective cleanup
level for arsenic in surface soil at OU-2, since 13 ppm is the average background level
for arsenic in surface soil at OU-2. The proposed cleanup level of 3.3 ppm for arsenic
in surface soil at OU-2 is less than the average background level for arsenic in soil. It
is EP A's policy not to set cleanup levels lower than average background levels.
Therefore, EP A raised the cleanup level for arsenic in surface soil at OU-2 to 13 ppm,
based upon Site-specific background levels.
While chemical treatment/pH adjustment of soils has been selected by EPA at other
Superfund battery reclamation sites, excavation and treatment. of the soil to cleanup
levels protective of ground water and human health is a preferred method of
treatment for soil at the ILCO Site.
PRP Steering Committee Comment #3:
EPA should also consider several other proven technologies (i.e., treatment of
debris by surface washing, followed by consolidation with other onsite materials
and capping) as part of the proposed remedy at the ILCa Site. This technique is
proven, readily implementable, and has been selected by EP A at other lead battery
reclamation sites.
EPA's ResDonse:
Proven technologies, such as decontamination of debris by EP A-approved methods, is
part of the selected remedy at the ILCO Site.
PRP Steering Committee Comment #4:
EP A did not take into account its land disposal restrictions (LDRs) for K069
baghouse dust. The LDRs mandate thermal recovery by secondary lead smelting.
EP A's Response:
EP A did take into consideration its LDRs for K069 baghouse dust by stating that the
baghouse dust will be sent offsite to a RCRA permitted treatment, storage, and
disposal (TSD) facility for treatment and disposal. The treatment and disposal of the
baghouse dust must comply with all pertinent ARARs, including LDRs.
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PRP Steering Committee Comment #5:
EP A has proposed offsite reclamation of slag and matte from the onsite vault at an
offsite secondary lead smelter. Because reclamation of blast furnace slag is not
known to be feasible, the Steering Committee believes that stabilization/fixation
(the common industry practice for secondary lead smelter slag) should be selected
as an alternate remedy. Following stabilization/fixation, the slag would be capped
at the ILCO Main Facility.
EP A's Restmnse:
Slag and matte that can be recycled will be sent to a secondary lead smelter for
recovery of lead. Slag and matte that cannot be recycled will be stabilized and
disposed offsite in a permitted hazardous waste landfill, if the add leaching remedy
is implemented. If the contingent remedy, solidification/stabilization, is
implemented, the slag and matte will be stabilized and disposed in the onsite
containment cell at the ILCO Main Facility.
PRP Steering Committee Comment #6:
A final decision on ground water remediation should be based on a more complete
understanding of the actual geologic conditions at the Site. Geologic data from the
immediate area and from the published literature differ somewhat hom the
interpretations in the Remedial Investigation (RI).
EPA's Res~onse:
A more complete W\derstanding of the Site-specific geologic conditions is necessary.
Therefore, one of the objectives of the predesign ground water studies to be
conducted as part of the selected ground water remedy is to obtain a better
W\derstanding of geologic conditions at the Site.
PRP Steering Committee Comment #7:
Hydrogeologic data are necessary to demonstrate whether there are preferential
flowpaths along which target compounds could migrate, and which could serve in
the design of a remediation system, if necessary. This analysis was not performed
during the Remedial InvestigationlFeasibility Study (RIfFS).
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-.. ,.,." --
EPA's Resoonse:
Additional hydrogeologic data is necessary. Therefore, another objective of the
predesign ground water studies to be conducted as part of the selected ground water
remedy is to collect and analyze additional hydrogeologic data for the Site.
PRP Steering Committee Comment #8:
Sampling and analysis are necessary to determine (a) whether target compounds
are present in the dissolved state in ground water: (b) whether those compounds
have the potential to migrate; and (c) whether residual compounds in soil continue
to impact ground water, or whether the removal action already conducted has
eliminated further impact These data were not determined in the RIlFS.
EPA's Response:
Predesign ground water studies to be conducted as part of the selected ground water
remedy will involve additional sampling and analysis to determine if contaminants
are mobile in the ground water and have the potential to migrate offsite. Soil
partitioning tests and soil leaching models have indicated that residual soil
contamination is a continuing threat to ground water. However, because there is a
concern as to the mobility of target compounds in ground water, the predesign
ground water studies will also include an investigation of the potential impacts on
ground water from residual soil contamination.
PRP Steering Committee Comment #9:
If the target compounds are in a dissolved state, further testing is necessary to
determine whether they can be recovered from the ground water using standard
pump and treat extraction systems. This was not determined in the Focused
Feasibility Study (FFS).
EP A's Re~onse:
The technical practicability of recovering contaminants from the ground water using
a pump and treat extraction system will be investigated in detail during the
predesign ground water studies to be conducted at OU-2.
PRP Steering Committee Comment #10:
The FFS did not examine potential treatment technologies for the actual ground
water. Instead, it used a hypothetical liquid that was assumed to contain target
compounds. The results might have no application to actual Site conditions. The
14
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PRP Steering Committee urges EP A to reevaluate the feasibility of remediation
using data from an actual ground water extracL
EP A's ReSDonse:
The FFS examined potential treatment technologies for ground water at OU-2 based
upon data from the remedial investigation. Additional data from Site-specific
predesign ground water studies, as well as data from the RI, will be evaluated by
EP A, in consultation with the State of Alabama, to determine the technical
practicability of remediating ground water at OU-2.
PRP Steering Committee Comment #11:
The Baseline Risk Assessment should be revised to reflect legal and institutional
constraints that exist at the Site. The only potential exposure pathway identified
in the baseline risk assessment was the scenario that future site development
would include residences that contain private domestic supply wells screened in
the contaminated zones. Jefferson County law does not allow new domestic
supply wells, and the area is currently zoned for industrial use. Therefore, the
scenario that serves as the basis for EP A's proposed plan is extremely unlikely and
should be revisited.
EPA's Response:
The Baseline Risk Assessment (BRA), by definition, does not allow for institutional
controls to be assumed in assessing risk at a site. The BRA evaluated all potential
current. and future exposure pathways for both soil and ground water at the ILCO
Site. A future residential scenario for ground water (Le., residents drinking from
private supply wells screened in the contaminated zone) was only one of the
exposure pathways evaluated under the BRA. The scenario that serves as the basis
for EPA's proposed soil remedy at the ILCO Site is a future commercial/industrial
land-use of the Site. Ground water at the Site is a potential drinking water source
and is a resource that should be protected and restored, if technically practicable, to
its beneficial use.
PRP Steering Committee Comment #12:
The evaluation of ground water extraction potential in the FFS relied on a
computer model which was not developed for hydrogeologic environments similar
to that at the ILCO Site. ~e assumptions applied in developing the proposed
remedy were those for a hydrogeologic system very different than that at the ILCO
Site, and they might not be accurate. Also, the fate and transport modelling in the
Remedial InvestigatifJn did not adequately address the state and form of lead
compounds and their consequent mobility potential. It also did not define
15
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migration pathways in the subsurface. The computer models of ground water and
target compound behavior should be revised so that they are based on actual
geochemical conditions rather than on assumptions.
EPA's Response:
The evaluation of ground water extraction potential in the FFS was based upon
available data from the RI. Site-specific predesign ground water studies will be
conducted at OU-2 to fill any data gaps. Additional data from the predesign ground
water studies, as well as the RI data, will be used to determine the technical
practicability of ground water extraction and remediation at OU-2.
..
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I .
APPENDIX B
STATE OF ALABAMA CONCURRENCE LETTER
ILCO SUPERFUND SITE
RECORD OF DECISION
-------
: ~ ~ ~r:
'.~S W. Warr, Director
:, ;!ing Addre5S:
" ; B!)X 301£63
,',' ')NTGOMERY AL
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,: 'iiical Address:
L'51 Cong.W.l.
, :~inU)n Driye
';1tgomery,Al
,09.2608
, :»271-7700
, 270.5612
" ::~ Offi,.,:
, ' ') Vulcan Road
",ingham, Al
: :{,S!-4702
';l}942-6168
" 9~1-160)
Wall Street
, Box 953
:~lur, AL,
, ' .~J2-o9~3
. ~) 353-1713
" : ~40'9359
, ,J,' Perimeter Road
,;;;\.3.AL
',5-1131
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;,. 1..79-2593
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ALABAMA' ',. :,~;Q
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT (f'}~
Jim Folsom
Governor
October 13. 1994
Mr. John H. Hankinson, Jr.
Regional Administrator
U.S. Environmental Protection
345 Courtland Street, NE
Atlanta. GA 30365
Aqency
Dear Mr. Hankinson:
Re:
Interstate Lead Company (lLCO)
Leeds. Alabama.
The Alabama Department of Environmental Management
has reviewed the draft Record of Decision (ROD) for
Operable Unit 2 and the amended ROD for Operable Unit 1 at
the referenced faci 1i ty. After review by OUI staff. and
in consultation with EPA staff, we agree with the approach
recommended in these documents. ADEM concurs with the
draft Record of Decision (ROD) for Operable Unit 2 and the
amended ROD for Operable Unit 1 at lLCO.
Should your s'taff have questions or comments,
contact Mr. David Thompson at 205-213-1300.
please
C}~cerelY ,
~~~
Director
JWW/JLB/ssg
pc:
Kimberly Q. Lanteman, RPM
David Thompson. SAC
PMo8d onlllql>l8d..... @
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