UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
     RESPONSE TO COMMENTS

            FOR THE
     US ECOLOGY, INC. SITE
      SHEFFIELD, ILLINOIS
         OCTOBER  1990

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                               US ECOLOGY,  INC.
                             SHEFFIELD, ILLINOIS
                               (ILD 045 063 450)
INTRODUCTION

      This response to comments (RTC)  is being presented by the United States
Environmental Protection Agency (U.S.  EPA).   The purpose of the RTC is to
present concerns and issues raised during the public comment period and to
provide responses.  All of the significant comments received were carefully
reviewed during the final selection of the remedy and have been responded to
in this RTC.  Some additional  alternatives and suggested additions to
components of the remedy were  raised by commenters that were not considered
during the Corrective Measure  Study (CMS), previously referred to as the
Feasibility Study (FS).  All these comments have been considered, and the
selected remedy is the proposed remedy with some modifications and
clarification.  To the extent  possible, and where appropriate, additional
details and requirements have  been added to direct US Ecology, Inc. in the
Corrective Measure Implementation (CMI) design phase, which will be initiated
following the signing and release of this document.

      The U.S. EPA, in its selection of the corrective measures to be
implemented by US Ecology at its Sheffield,  Illinois, landfills, has
determined that the individual components of the remedy for source control and
ground-water remediation will  be both effective and protective.  The selected
remedy was chosen by U.S. EPA to promote remediation of contamination from
both past and continuing releases of hazardous waste and/or hazardous
constituents to ground water and to significantly reduce the likelihood of
future releases from those areas addressed.   However, the U.S. EPA wishes to
make the following points very clear:

      1.    The Administrative Order By Consent, signed by U.S. EPA and US
            Ecology, remains in effect after remedy selection.  Under Section
            VIII, titled Additional Work, U.S. EPA can require US Ecology to
            conduct additional remediation investigation (RI) work and/or
            feasibility studies (FS) if the Agency makes a determination that
            it is necessary.

      2.    Although U.S. EPA expects the number of future releases to be
            reduced once source control components are designed, approved, and
            implemented, it is clear that U.S. EPA retains statutory authority
            for corrective action, which can be used to address any newly-
            identified areas of releases (e.g., from different areas of the
            New Site (see Figure 1)).

      3.    If it is determined, following implementation of the selected
            corrective measures, that a specific component is not achieving
            the design specifications and, as such, will not be effective in
            source control or remediation of ground water, U.S. EPA will
            require US Ecology to redesign and reimplement the specific remedy
            component or implement another technology following further FS
            work.

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                                                             n>
U S ECOLOGY SHEFFIELD HAZARDOUS WASTE DISPOSAL SITES

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      US Ecology Is obligated under Section X of the Consent Order,  titled
Corrective Action, to implement the corrective action selected by U.S.  EPA.
The corrective action will  be completed in accordance with Attachment I to
this document (i.e., Scope  of Work for Corrective Measures Implementation at
US Ecology, Inc., Sheffield,  Illinois).  The Consent Order (Section  XVII.C)
provides for financial assurance in the amount of $1,750,000.00 to guarantee
performance of and payment  for any corrective action selected by U.S. EPA.


SELECTED CORRECTIVE MEASURES

      The selected corrective measures consists of two essential elements:
(1) source control, and (2) ground-water remediation.  These two elements are
detailed below and depicted in Figure 2.

1.    The selected corrective measures for source control  consist of the
      following components, some of which are described in considerable detail
      in the draft FS report for source control (Alternative 1):

      a.    Placing slurry  walls around the Old Site trenches.

      b.    Placing slurry  walls at trench I8EWC and the G-120 area  of the New
            Site.

      c.    Capping of the  Old Site with a RCRA-required cap.

      d.    Implementation  of modifications to the existing New Site clay cap,
            if required by  the Illinois Environmental Protection Agency (IEPA)
            for closure purposes.

      e.    Extension of RCRA-required caps over areas encircled by  slurry
            walls tied into existing barrier walls at 18EWC and the  G-120
            area.

      f.    Placement of recovery/extraction wells screened near bedrock in
            areas encircled by slurry walls (i.e., the Old Site trenches).
            The purpose of  these wells is to lower the level of the  ground
            water within the slurry walls to a level below that of the buried
            hazardous waste and a high percentage of the contaminated soils.

      g.    Because of concerns expressed by commenters regarding the adequacy
            of the existing system of ground-water monitoring wells  to detect
            releases, US Ecology will be required to reduce the spacing
            between existing wells by approximately one-half north of New Site
            trenches 4, 5,  and 24; west of trenches 24, 23, and 22;  south of
            trench 23; and  east of trenches 14C, 15, 16B,  and 18EWB.

      h.    Installation of sumps and/or extraction wells inside the slurry-
            walled and capped areas at trench 18EWC and G-120.

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GROUND WATER
SEEPS
  18EWC AREA
    LEGEND

     SLURRY WALL
     CAP/COVER

     GROUND WATER CONTAMINATION
     (OLD SITE PLUME)
     GROUND WATER EXTRACTION WELLS
                                   U S ECOLOGY SHEFFIELD  SITE

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      i.    Repair or modification of the existing trench barrier walls at
            18EWC to ensure that they are effectively tied into a low-
            permeability stratum beneath the trench.

      j.    Installation of additional effective sumps into New Site trenches
            1, 2, and 3, and 18EWC to control leachate generation and release
            from these trenches.

2.    U.S. EPA's selected corrective measures for ground-water remediation
      will require US Ecology to:

      a.    Employ ground-water pumping to:

            (i)   Limit expansion of the existing contaminated ground water by
                  hydraulic controls; and

            (ii)  Remove the contaminated ground water from each location of
                  contamination until ground-water quality at the completion
                  of the remediation meets the following ground-water
                  protection standards:
                        Arsenic:                    10.0
                        Benzene:                     5.0 /jg/L
                        Chloroform:                  5.0 /jg/L
                        1,1-Dichloroethane:          5.0 /jg/L
                        1,2-Dichloroethane:          5.0 /ig/L
                        1,1-Dichloroethylene:        5.0 /ig/L
                        1,2-Dichloropropane:         5.0 fig/L
                        Methyl ene Chloride:          5.0 jjg/L
                        Tetrachloroethylene:         5.0 /ig/L
                        Trichloroethylene:           5.0 /*g/L
                        Vinyl Chloride:              2.0 /tg/L

      b.    Treat the removed ground water as necessary to comply with
            applicable State regulatory programs for discharge to air, surface
            water, and ground water (e.g., reinjection).

      c.    Provide a ground-water monitoring program to verify progress
            toward achieving U.S. EPA's ground-water protection standards.

      d.    Screen ground-water extraction wells in both the glacial aquifer
            and bedrock aquifer (including the G-120 area), as necessary, to
            achieve the ground-water protection standards specified herein in
            both the saturated zones.

      e.    Perform additional ground-water modeling to predict, to the extent
            possible, the effects of implementing the selected corrective
            measures particularly in regard to the low level radioactive waste
            (LLRW) site.

      f.    Provide for the placement of piezometers, and the institution of
            regular recordkeeping of water-level measurements in them, to

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            allow detection, assessment, and to assist in management of any
            potentially adverse effects on the ground-water gradients
            associated with the adjacent LLRW site.

      g.    Develop and submit contingency plans to  raise or lower the ground-
            water levels associated with the LLRW site in the event that the
            implemented corrective measures (source  control and/or ground-
            water remediation activities) are determined to be producing
            adverse effects on the LLRW site ground-water flow direction,
            ground-water elevations, etc.

      h.    Develop a treatment system(s) capable of handling extracted ground
            water removed from the chemical plume, including those areas where
            the radiochemical plume is mixed with the chemical plume.  This
            requirement will include regular sampling of extracted ground
            water for those radionuclide parameters  in Table 5-7 of the Final
            Remedial Investigation (RI) report plus  1-129 and appropriate
            handling, treatment, storage, or disposal of the water and sludge.

      The detailed designs for implementing these corrective measures will be
developed in accordance with the Scope of Work for CMI attached to this
document.  In addition to these requirements, the following activities will be
initiated/continued and considered.

1.    Site access restrictions (including Trout Lake);

2.    Collection of water discharging from the New Site north slope seeps and
      its treatment and discharge; and

3.    Installation of additional monitoring wells in the Herrin Coal, upon
      approval of the plan by U.S. EPA.

      The selected corrective measures provide the best balance among the
alternatives with respect to the evaluation criteria, including:

            •     Long-term reliability and effectiveness;
            •     Reduction of toxicity, mobility, or volume of waste;
            •     Short-term effectiveness;
            •     Implementability; and
            •     Cost.

The selected corrective measures provide overall protection of human health
and the environment as follows:

1.    Source Control

      The selected corrective measures for source control are expected to
      provide an appropriate degree of overall protection of human health and
      the environment by containing (with slurry walls) all Old Site hazardous
      wastes and most contaminated soil at the Old Site and the 18EWC and G-
      120 areas.  The slurry walls will be designed to be compatible with the
      chemicals in the buried wastes and will be constructed to isolate the

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      wastes and contaminated soils and reduce  further contaminant migration
      to ground water.   RCRA-requlred caps,  designed to achieve the maximum
      effective lifetime with the lowest maintenance, over the Old and New
      Sites and cap extensions over the G-120 and 18EWC plume areas will
      reduce the chance of exposure to contaminated soil  and significantly
      reduce surface water Infiltration, leachate generation and mobility, and
      help control  future releases of contamination.  Extraction wells placed
      inside the encircling slurry walls of the Old Site will be designed to
      create a reduced  hydraulic head inside the walls that will reduce the
      probability of contaminated water exiting outward through the walls; to
      draw the ground-water surface level  down  inside the slurry walls to
      below the buried  waste elevation; and to  transmit extracted ground water
      to the proposed treatment system.  By engineering the effective long-
      term isolation and containment of the relatively small volume of the Old
      Site waste and by reducing the volume of  ground water in contact with
      the buried waste  and contaminated soil through implementation of the
      selected source control, it is felt that  short-term protection is
      greater and that  long-term goals for protection of human health and the
      environment will  be achieved as well.

      Slurry wall technology is commonly used.   However, its use requires care
      in design and implementation to achieve the desired goals of containment
      and isolation of  the hazardous wastes.  Installation of landfill capping
      and its maintenance is straightforward.  The estimated costs of
      implementing the  slurry wall and Old Site cap are $1,153,500 and
      $928,000, respectively, over thirty (30)  years.  The slurry walls could
      be designed and installed in two (2) years.

2.    Ground Water

      The selected corrective measures for ground-water remediation will
      provide adequate  protection of human health and the environment since
      they provide for  halting plume expansion  and initiating remediation of
      the plumes of contamination by extraction and treatment of ground water
      (i.e., from the Old Site, trench 18EWC, the G-120 area, and the north
      slope seeps).  Following ground-water remediation by using reliable
      metals precipitation, air stripping, and  carbon adsorption technologies
      to achieve the concentrations proposed by U.S. EPA, the residual health
      risks from ingestion of ground water will be reduced to acceptable
      levels.  The draft FS report estimates there will be a 98 percent
      reduction of the  total mass of organic constituents in the ground water
      within thirty (30) years.  Extraction and ground-water treatment will
      continue indefinitely toward achieving U.S. EPA's ground-water
      protection standards.  A National Pollutant Discharge Elimination System
      (NPDES) permit will restrict the effluent discharge levels of the
      various parameters of concern.  Monitoring wells will be sampled
      regularly to test for the effectiveness of the extraction and treatment
      systems by monitoring for changes in plume size and contaminant
      concentration levels.  Because US Ecology owns all of the land surface
      under which hazardous constituent plumes  are currently delineated,  .no
      third party has a well water supply screened in a plume.  Containment of
      the plume and extraction and treatment of the ground water will reduce

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      or eliminate potential  risks from ingestion of contaminated ground water
      downgradient of the landfill at any off-site location.

      It is estimated that it will take eighteen (18) months to design and
      install the ground-water treatment system.  All components are readily
      available technologies  that have been extensively used at other sites
      and do not restrict future expansion or modification of the selected
      ground-water corrective measures.  The estimated cost over thirty (30)
      years for the ground-water remediation is projected to be about $10
      million.

      The total cost of the selected corrective measures is estimated to be
about $12 million over thirty (30) years.


COMMUNITY RELATIONS ACTIVITIES

      U.S. EPA released the Proposed Plan for the US Ecology, Sheffield,
Illinois, facility in May 1990.  At citizens' requests, a 2-week informational
period was scheduled by U.S.  EPA from May 14 to May 28, 1990.  This period
permitted the public to become familiar with the Proposed Plan prior to the
start of a 45-day comment period.  The comment period began on May 28 and
terminated on July 26, 1990,  fifteen (15) days after the original closure
date.  The extension to the comment period was granted at the request of
Attorney General Neil Hartigan and Congressman Lane Evans.

      On June 14, 1990, U.S.  EPA conducted an informational meeting at the
Buda-Sheffield Western School in Buda, Illinois.  The purpose of the meeting
was to present and explain the Proposed Plan and to answer the community's
questions on a more informal  basis.  Over seventy-five (75) people attended
the slide presentation and question and answer period that followed.  A court
reporter recorded the meeting and a transcript was made and is available at
the Information Repository at the public library in Sheffield, Illinois.

      U.S. EPA held a public  hearing on June 28, 1990, to take and record
formal comments on the Proposed Plan.  Transcripts from the court reporter
have been made available.  Approximately 150 people attended the hearing and
fifteen (15) people gave oral testimony.  The meeting was attended by
representatives from the Illinois Environmental Protection Agency (IEPA), the
Illinois Department of Nuclear Safety (IDNS), the Attorney General's office,
Senator Simon's office, Representative Mautino's office, and the press.

      U.S. EPA regularly updates the community through letters, to citizens,
media relations, and conversations with citizens.


CONCERNS RAISED DURING THE COMMENT PERIOD

      During the public comment period, U.S. EPA received written comments on
the proposed plan from several sources including government officials and
agencies, citizen groups and  their representatives, private citizens, and US
Ecology.  Additional comments are included within the transcripts of the June

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14 public informational meeting and June 28 public hearing.   Table 1 lists all
written comments received by the Agency.  A complete copy of all written
comments is available for review at the U.S. EPA, Region 5,  library (located
on the 16th Floor, 230 South Dearborn Street, Chicago,  Illinois), and at the
Information Repository in the public library in Sheffield, Illinois.

      All comments presented in this section are referenced  according to
source document numbers presented in Table 1.  For example,  comments from
William C. Child of the Illinois Environmental Protection Agency (IEPA) are
referenced as A2, while comments from Eloise Baker, a private citizen, are
referenced as C7.  Citations are also provided for the location of the
comments [page (p), paragraph (U), and section (§)] within a source document,
as appropriate.  For example, a specific comment that appeared on page 3,
Section 6 of William C. Child's (IEPA) written comments would be referenced as
[A2,p.3,§6]; a specific comment from the first paragraph on  page 2 of Eloise
Baker's written comments would be referenced as [C7,p.2,<|[l].  In cases where
U.S. EPA received the same comment from several sources, all sources are
referenced.  For example, a comment that was made by both William C. Child of
IEPA and Eloise Baker might be referenced as [A2,p.2,§2; C7,p.l,1f3].

      The comments listed below are separated into seven categories.  The
categories are titled:

      I.    Source Control Corrective Measures
      II.   Ground-Water Corrective Measures
      III.  Site Geology and Hydrogeology
      IV.   Remedial Investigation and Feasibility Study
      V.    Interactions Between Chemical and Radioactive Waste
      VI.   Health Effects and Cleanup Goals
      VII.  Miscellaneous Comments
I.    SOURCE CONTROL CORRECTIVE MEASURES

      1.    Concern:

            IEPA and others questioned the technical feasibility of slurry
            wall installation and is concerned that installing the slurry wall
            through permeable, saturated and unconsolidated sediments will
            cause the sediments to collapse into the trench.  [A2,p.l,§la;
            B6,p.II-l,§2; E2,p.55,H2]

            Response:

            Experienced engineers and contractors are available for hire by US
            Ecology who can overcome, by increased engineering, the potential
            limitations raised by IEPA regarding slurry wall installation.
            Regarding the issue of depth, walls up to eighty (80) feet can be
            installed with modified backhoes; deeper walls would most likely
            utilize a hydraulic clam shell.  The potential for collapse of
            unconsolidated sediments into the trench during excavation will be
            eliminated by introduction of slurry just after the trench is

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                                   TABLE  1

                            LIST OF PUBLIC COMMENTS
                         ON U.S.  ERA'S  PROPOSED  PLAN
                          FOR US ECOLOGY'S SHEFFIELD
                             HAZARDOUS WASTE  SITES


A.    Government Agencies and Public Officials

1.    Lane Evans, Congressman, "Remarks of Congressman Lane Evans, US Ecology
            Chemical Waste Disposal  Facility, Hearing on the Corrective Action
            Plan," written statement read at June 28, 1990, Public Hearing by
            Jerry Lack (received June 28,  1990)

2.    William C. Child, Manager,  Division of Land Pollution Control, Illinois
            Environmental Protection Agency,  letter to David A. Ullrich, U.S.
            Environmental Protection Agency,  undated (received June 28, 1990)

3.    Dave Ed, Senior Scientist,  Illinois Department of Nuclear Safety,
            "Statement by the Illinois Department of Nuclear Safety at the
            U.S. Environmental Protection Agency's Public Hearing on the
            Proposed Plan for Corrective Action at the US Ecology Inc.
            Hazardous Waste Facility Near Sheffield, Illinois," written
            statement read at June 28, 1990,  Public Hearing (received June 28,
            1990)

4.    Thomas W. Ortciger, Director,  State of Illinois Department of Nuclear
            Safety, letter to Jonathan Cooper, U.S. Environmental Protection
            Agency, July 10, 1990 (received July 11, 1990)

5.    Neil F. Hartigan, Attorney General,  State of Illinois, letter (with
            attached "Comments of the People of the State of Illinois and the
            County of Bureau Concerning the United States Environmental
            Protection Agency's Proposed Plan for the US Ecology, Site,
            Sheffield, Bureau County, Illinois") to Valdas V. Adamkas,
            Regional Administrator,  U.S. Environmental Protection Agency
            (dated and received July 26, 1990)


B.    Citizens' Groups

1.    Rodger Bruyn, Manager, Bureau County Farm Bureau, memo (with attached
            report "A Review of the Final  Remedial Investigation Report for
            the Sheffield Hazardous Waste Disposal Sites" prepared by K.W.
            Brown & Associates, Inc., College Station, Texas, July 1989) to
            Thomas J. Kenney, U.S. Environmental Protection Agency, August 15,
            1989
                                       8

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                             TABLE  1  (Continued)

                            LIST OF  PUBLIC COMMENTS
                          ON U.S.  ERA'S  PROPOSED PLAN
                          FOR US ECOLOGY'S SHEFFIELD
                             HAZARDOUS WASTE  SITES


2.    Dr. R.S. Nelson, Environmental Exploration Associates, Inc.
            (representing Associated Citizens for Protection of the
            Environment), "Summary -- Evaluation of Geology and the Hazardous
            Waste Sites, Sheffield,  111.," written comments submitted at June
            28, 1990, Public Hearing (received June 28, 1990)

3.    Stan Gingrich, President, Associated Citizens for Protection of the
            Environment, written statement read at June 28, 1990, Public
            Hearing (received June 28, 1990)

4.    Alan T. Dale, President,  Bureau County Farm Bureau, "Public Hearing —
            U.S. EPA Remediation Proposal," written statement read at June 28,
            1990, Public Hearing (received July 12, 1990)

5.    Rodger Bruyn, Manager, Bureau County Farm Bureau, "Farm Bureau's
            Position," written statement read at June 28, 1990, Public Hearing
            (received June 28,  1990)

6.    Jeanine L. Morse, Hydrogeologic Consultant for Bureau County Farm
            Bureau, "Comments on the Final Remedial Investigation, Draft
            Feasibility Study Reports and the Proposed Plan for Corrective
            Action for the US Ecology, Inc. Landfill Near Sheffield, Bureau
            County, Illinois," written comments submitted at June 28, 1990,
            Public Hearing  (received June 28, 1990)

7.    Dr. R.S. Nelson, Environmental Exploration Associates, Inc. (On Behalf
            of Associated Citizens for Protection of the Environment),
            "Geologic and Hydrologic Interpretation & Comments on Proposed
            Corrective Action,  US Ecology Hazardous Waste Sites, Sheffield,
            Illinois," dated July 11, 1990 (received July 26, 1990)


C.    Private Citizens

1.    Chester M. Grafft, Princeton,  Illinois, written comments submitted at
            June 28, 1990,  Public Hearing (received June 28, 1990)

2.    Steve Barlow, Princeton,  Illinois, written statement read at June 28,
            1990, Public Hearing (received June 28, 1990)

3.    Roy L. Mahnesmith and Edward F. Glubczynski, memo to Jonathan Cooper,
            U.S. Environmental  Protection Agency, July 6, 1990 (received July
            10, 1990)

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                             TABLE  1  (Continued)

                            LIST OF  PUBLIC COMMENTS
                         ON U.S.  ERA'S  PROPOSED PLAN
                          FOR US ECOLOGY'S SHEFFIELD
                             HAZARDOUS WASTE  SITES


4.    Laverne Weidler, Kewanee, Illinois, letter to Jonathan Cooper, U.S.
            Environmental Protection Agency,  undated (received July 12, 1990)

5.    Timothy D. Wilson, Sheffield,  Illinois, written comments (postmarked
            July 10, 1990)

6.    Mr. and Mrs. Ronald Wilson,  Sheffield,  Illinois, written comments
            (postmarked July 10,  1990)

7.    Eloise P. Baker, Neponset,  Illinois,  written comments (postmarked July
            18, 1990)

8.    Eloise P. Baker, Neponset,  Illinois,  written comments (postmarked July
            24, 1990)

9.    I. Jay and Louise J.  Langford, Sheffield, Illinois, written comments
            dated July 19,  1990 (received July 25, 1990)

10.   Ted Strouse, Buda Illinois,  written comments dated July 18, 1990
            (received July 20,  1990)

11.   Rev. Frank Rottier, Sheffield, Illinois, written comments dated July 16,
            1990 (received July 26,  1990)


D.    US Ecology

1.    Laurence Levine, US Ecology, Inc., written comments (received June 28,
            1990).

2.    Bradley E. Dillon, General  Counsel, US Ecology, Inc., "US Ecology,
            Inc.'s Comments on U.S.  EPA's Proposed Plan (with Attachments 1
            through 13)," dated July 26, 1990 (received July 27, 1990)


E.    Transcripts from Public Meeting and Public Hearing

1.    Transcript of "The Informational Meeting on U.S. EPA's Proposed Plan for
            Corrective Measures for the US Ecology, Inc. Site, Sheffield,
            Illinois," held at Buda-Sheffield Western School, Buda, Illinois,
            June 14, 1990 (prepared by Kathy L. Johnson Professional Reporting
            Services)
                                      10

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                             TABLE  1  (Continued)

                            LIST OF  PUBLIC COMMENTS
                         ON U.S.  ERA'S  PROPOSED PLAN
                          FOR US ECOLOGY'S SHEFFIELD
                             HAZARDOUS WASTE  SITES


2.    Transcript of "The Public Meeting on U.S. EPA's Proposed Plan for
            Corrective Measures for the US Ecology,  Inc. Site, Sheffield,
            Illinois," held at Bureau County Courthouse, Princeton, Illinois,
            June 28, 1990 (prepared by Kathy L. Johnson Professional Reporting
            Services)
                                      11

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                                12

      opened and before the water table Is reached.   The
      viscosity/density of the slurry is maintained  at a level  that is
      appropriate for hydraulically shoring up and stabilizing  the
      trench walls.   Also, during trench excavation,  a thin filter cake
      forms on the trench walls minimizing slurry loss into the
      surrounding geologic materials, stabilizing the soil  in contact
      with the slurry, and providing a plane on each trench wall  against
      which the hydraulic pressure of the slurry can act to stabilize
      the excavation (EPA/540-2-84-001; Feb. 1984).   Test borings will
      be done along  the proposed wall locations during the design phases
      of Corrective  Measure Implementation (CMI) and the presence of the
      various sediment types will be considered in fine tuning  the
      engineering design.
2.    Concern:
      Compatibility tests of the waste with bentonite slurry walls were
      not performed.  Bentonite is sensitive to chemical attack and
      alteration and published information (EPA/530-SW-86-007; March
      1986) does not recommend soil/bentonite mixtures for use where
      hazardous waste or leachates occur.   [A2,p.l,§lb; A5,p.2,H2]

      Response:

      The potential for adverse effects on slurry wall materials from
      chemicals exists and will be addressed.  Compatibility tests will
      be performed during the CMI design phase.  A work plan will be
      required which will describe procedures to collect representative
      leachate (ground water) samples from the site.  These will be used
      in specified laboratory tests to determine the effects of the
      leachate on various proposed backfill mixtures which incorporate
      site soils and other soils with different types of bentonites.

      The specific draft document cited in this concern is titled:
      Design,  construction, and evaluation of clav liners for waste
      iranagemcint facilities.  The vertical slurry walls:
      a.    Will not be in direct contact with hazardous waste as a
            landfill liner might be,  but instead with contaminated
            ground water (i.e., less  concentrated);

      b.    Will be used in conjunction with complementary technologies
            (i.e., an effective landfill cap and ground-water extraction
            wells inside the slurry-walled areas).  The extraction wells
            in the Old Site constitute use of slurry walls with active
            (rather than passive) management,  "mat is, the hydraulic
            gradient will be inward into the Old Site thereby
            controlling releases of leachate moving outward through the
            wall.  It is expected then that any water which permeates
            the slurry wall around the Old Site, when the extraction

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                                13

            wells are operable,  will  be less contaminated and have less
            of a potential  for an adverse impact on the slurry wall.

      c.    Will be In contact with more dilute organic solutions than
            those used In some laboratory studies showing marked
            permeability Increases In clays.  Tests conducted with less
            concentrated solutions of organics (I.e., at or near their
            solubility limits In aqueous solution) caused no appreciable
            Increases In permeability (Evans, Fang, and Kugelman, 1985).

      d.    Will be engineered and designed to the fullest degree
            possible In relation to this important concern.  Different
            types of bentonite and even other types of clay, less
            affected by chemical attack, can be used.
3.    Concern:
      Commenters are concerned that ground water will mound on the
      outside of the slurry wall  and cause an increased gradient through
      the wall which may result in containment failure.  [A2,p.2,§2a]

      Response:

      A potential does exist for mounding of ground water beneath the
      New Site immediately west of the proposed location of the west
      side of the Old Site slurry wall.  Because of the increased
      potential for piping and hydrofracturing in a wall if the head
      differential across a slurry wall is high, U.S. EPA will require
      the design phase to ensure eventual:  (1) implementation of a wall
      as homogeneous, both horizontally and vertically, as possible; (2)
      use of only specified backfill materials to yield the established
      design permeability; (3) requirement of monitoring of ground-water
      levels inside and outside of the wall to ensure that design head
      levels are not exceeded; and (4) ability to control the hydraulic
      gradient across the wall by appropriate use of extraction wells on
      both sides of the wall.
4.    Concern:
      US Ecology did not evaluate the cap on the New Site to determine
      if it meets the minimum technology requirements for landfill  cover
      pursuant to 35 Illinois Administrative Code 724.410a.  [A2,p.2,§5]

      Response:

      US Ecology has already responded to this comment by IEPA.
      Attachment 4 of their submittal evaluates the existing New Site
      cap and IEPA has a copy of this.  US Ecology referred to landfill
      final cover design objectives as "10 CFR 264.310a".  That should
      read 40 CFR 264.310a.  The State analogs are 35 111. Adm. Code
      724.410a.  US Ecology will be required to implement a RCRA-
      approved cap.

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                                14

5.    Concern:

      Commenters question the plan to 'key'  the slurry wall  three feet
      into the bedrock because the bedrock is comprised of various
      geologic units of differing permeability.  US Ecology has not
      evaluated the effectiveness of keying  a slurry wall  into fractured
      bedrock.  Therefore, the ability of the wall  to cut-off the
      ground-water flow can not be judged.  [AS,p.3,12; A2,p.l,§lc]

      Response:

      These comments raise potentially valid concerns, but increased
      engineering and design can surmount these problems if these
      conditions actually exist beneath the  Old Site at the depth at
      which the slurry walls would be keyed  into bedrock.   The RI report
      examined the bedrock for the presence  of fractures and jointing.
      These are stated in the RI report to be "sparse based on
      observations from core samples, caliper logs, and borehole
      televiewer logs" (pages 4-67, 4-69).  During the actual design
      phase, an approved plan will require drilling boreholes on a
      specified spacing along the actual slurry wall location to further
      characterize the sediments through which the trenching and
      installation will occur.  In addition, cores of bedrock will be
      taken to the design depths for examination.

      U.S. EPA believes the following factors indicate that this comment
      is less of a concern than it initially might appear:  (1) this
      further subsurface study will provide  additional location-specific
      information during the design phase to ensure an adequate keying
      of the wall into bedrock; (2) the ground-water level within the
      slurry wall will be maintained at or near the surface of the
      bedrock as extraction wells remove ground water inside the slurry
      wall thus eliminating all or most of the vertical driving force;
      and (3) data from monitoring wells during the RI study have shown
      that the bedrock is relatively uncontaminated and that most of the
      organic contamination is migrating along the interface between the
      bedrock and glacial sediments (i.e., the tendency on site appears
      to be for lateral, not vertical, movement of ground water).

6.    Concern:

      Commenter states that a major flaw in  the plan is that it does not
      address excavation of the Old Site as  an alternative and suggests
      U.S. EPA reconsider alternatives such  as solidification or
      incineration and aboveground storage.  [Al,p.l,15; B2,p.2,14;
      B3,p.2,12; C2,p.2; C3,p.l,§6; C7,p.2,ll; C9,p.l,ll;  C11.15;
      Bl,App.A,p.l,12 and p.2,HI; Bl,App.A,p.3,ll;  B5,p.2,15;
      E2,p.18,14; E2,p.35,15; E2,p.43,11; E2,p.56,14; E2,p.62,12;
      E2,p.80,ll]

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                                15

      Response:

      Excavation of the hazardous wastes at the Sheffield site has been
      fully evaluated.   US Ecology initially eliminated exhumation in
      the document titled "Preliminary Screening of Remedial
      Technologies and  Development of Alternatives" (dated August 19,
      1988).  U.S. EPA  required,  however, that exhumation be  evaluated
      further in the FS documents and this was done.  For reasons stated
      in the Proposed Plan (e.g., short-term hazards to workers and
      nearby residences from potential explosions or releases of
      volatiles  to the  air; a longer implementation time; the need for
      special equipment and permits; and disposal capacity issues),
      exhumation was not selected by U.S. EPA as a component  of the
      preferred  alternative.  As such, solidification and incineration,
      processes  performed following the exhumation of the hazardous
      wastes, are also  eliminated from further consideration.
      Aboveground storage of land disposal restricted wastes  in waste
      piles is banned and storage in tanks and containers is  not
      permitted  under the regulations (40 CFR 268.50(a)) for  more than
      one year absent appropriate treatment (40 CFR 265.41 to 268.43).
7.    Concern:
      The reliability and effectiveness of proposed slurry walls and
      landfill caps as components of a containment system were
      questioned.  [Al,p.l,^7; C5; C6; C7,p.l,^3;  Bl,App.A,p.l,^[l and
      p.2,12; E2,p.18,15]

      Response:

      Landfill caps are a commonly used technology for reducing surface
      water infiltration into burial trenches containing hazardous
      wastes.  U.S. EPA issued a technical guidance document for
      caps/covers titled "Final Covers on Hazardous Wastes Landfills and
      Surface Impoundments" (EPA/530-SW-89-047; July 1989).  During cap
      design, many factors will be considered including, but not limited
      to:  existing trench bottom liner permeability; slope of the final
      cap (to promote runoff, but to minimize erosion); inclusion of
      drainage layers in the design; a top vegetative or armored surface
      component; and freeze-thaw phenomena.  In addition to designing
      effective and appropriate covers for the landfills, the design
      will also rely on sumps and/or extraction wells to permit
      collection and removal of any surface water that does infiltrate
      the cover.

      Regarding the reliability and effectiveness of slurry walls,
      please refer to the responses to concerns 1.2 and 1.5.
8.    Concern:
      Several commenters questioned the effectiveness of slurry walls
      proposed for the New Site.  One commenter suggested that the

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                                16

      slurry walls will  not be tied into lateral  barriers and will  be
      aligned parallel  to ground-water flow.   Thus,  they will have
      little effect on  contaminant migration.   Another commenter
      suggests that the existing barrier wall  around the New Site is not
      keyed into the bedrock.   Since slurry walls will be constructed
      along only a small portion of the barrier wall, they will  not be
      effective in stopping ground-water flow along  most of the  wall.
      [A5,p.6,Hl; B2,p.2,13; B7,p.l,H3; B7,p.l5,f2;  B6,p.II-3,§10]

      Response:

      Existing New Site barrier walls were not required or designed to
      be keyed into bedrock under the construction permit.  The  barriers
      to vertical flow  in the New Site consist of in situ scraped and
      reworked glacial  materials in the east portion of the site and, in
      the western portion, a ten- (10) foot thick low-permeability,
      imported material  recompacted under the trenches.  Lateral
      barriers were also constructed of recompacted, low-permeability
      materials.  Slurry walls, installed in a semi-circular
      configuration, are proposed which will  both tie into existing
      lateral barrier walls and key into bedrock in  two locations around
      the New Site where ground-water contamination  has indicated
      releases from the facility (i.e., G-120 and 18EWC areas).   These
      slurry walls are  expected to be effective by practically
      encircling the areas of releases by slurry walls and lateral
      barrier walls, covering the encircled areas with an effective
      landfill cover, installing extraction wells positioned inside the
      slurry walls such that they capture any existing or continuing
      releases of contaminated ground water,  and reducing the likelihood
      of further releases from landfill trenches by  installing
      additional sumps  (or more aggressively pumping existing sumps) and
      installation of a more effective cap over the  New Site.
9.    Concern:
      Eloise Baker, speaking on the behalf of the Associated Citizens
      for Protection of the Environment (ACRE),  stressed the importance
      of extracting the water in the New Site trenches and preventing
      ground water from entering waste disposal  cells by installing
      protective caps.  [C7,p.l,H6]

      Response:

      U.S. EPA concurs with the comment.  Removal of any water in
      trenches reduces the head or vertical driving force.
10.   Concern:
      One commenter agreed with U.S.  EPA's proposed corrective action
      plan for the New Site.  [C2,p.2,!l]

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                                17

      Response:

      U.S.  EPA appreciates the input of all  parties.

11.    Concern:

      The remedy should be total  encapsulation of the Old Site,  New
      Site, and LLRW site.  The vertical  containment  barrier should be
      constructed of concrete and extended downward five (5) feet into
      the top of the Canton Shale, the uppermost bedrock unit with
      hydraulic integrity.  This remedy should include a perimeter drain
      along the inside of the containment wall and a  cap covering all
      waste disposal areas and extending beyond the containment  wall.
      The estimated cost of this remedy,  not including the cap,  is $225
      million.  [B2,p.3,Ul; B7,p.l,H4; B7,p.16,^1; C7,p.l,f8; E2,p.32]

      Response:

      Dr. Robert Nelson's proposal for total encapsulation of all three
      waste disposal sites would involve two different owners (i.e., the
      Old and New Sites are owned by US Ecology and the LLRW site is
      owned by the State of Illinois), ignores the existence of  separate
      jurisdictional authorities/agencies (i.e., U.S. EPA and IDNS), is
      not developed or designed to the degree necessary to evaluate
      either its feasibility as an alternative or its costs as required
      in the FS guidance, and is not necessary based  on data in  the
      RI/FS reports.

      "Guidance for Conducting Remedial Investigations and Feasibility
      Studies Under CERCLA" (EPA/540/G-89/004; October 1988) specifies
      that each alternative for proposed remedies be  evaluated against
      factors such as effectiveness, implementability, and cost.  Dr.
      Nelson states that estimating the cost of total encapsulation "is
      difficult because of the need to dig trenches to a depth of 120 to
      150 feet through unstable surficial material into bedrock" (B7,p.
      16).   The cost estimate ("on the order of $225  million") does not
      detail cost of individual components (e.g., equipment, materials,
      labor, operation and maintenance, associated ground-water
      extraction costs to allow containment implementation, etc.).  It
      is not even clear if this estimate includes the cost of a  cap over
      the three sites.  It appears that the cap cost  is not calculated
      or considered.

      Based on the results of the RI report, ongoing  indicator parameter
      evaluation and assessment monitoring of ground  water at the New
      Site, and on the geologic maps, cross sections  and statements in
      Dr. Nelson's report, dated July 11, 1990, U.S.  EPA's selected
      remedy will work.  This is true for the following reasons.  The
      bedrock wells, if Dr. Nelson's models 1 and 2 were appropriate
      theoretical models of contaminant migration, would be extensively
      contaminated.  However, ground water sampled from the six  bedrock
      wells screened in the Herrin Coal (i.e., the deepest penetration

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                                18

      of the coal  exploration borings)  yielded only low levels  (<,  36
      parts per billion (ppb) of laboratory contaminants (e.g.,
      methylene chloride,  acetone, bis(2-ethylhexyl) phthalate).   Even
      if some contamination were migrating preferentially in a  vertical
      direction (a conclusion not supported by most of the RI data),  Dr.
      Nelson's cross sections,  geologic map of the bedrock,  and text
      would support contamination migrating vertically to the Herrin
      Coal  (the base of coal  borings)  and then moving preferentially
      horizontally at that depth.  Dr.  Nelson states, on page two, that
      the "Herrin  Coal  is  highly jointed with vertical and horizontal
      joint spacing measured in inches  or fractions of an inch"  and,  on
      page  four, that the  "coals are aquifers because ground water moves
      relatively easily along the abundant joints in the coal beds.
      Springs and  seeps typically occur where coal units outcrop."
      Thus, any contamination migrating through unplugged boreholes
      would eventually move laterally away from the landfills and  be
      captured within the  cones of influence of extraction wells
      required for the selected corrective measures.  Because the  Old
      and New Site landfills are isolated on their own bedrock  high
      (i.e., away  from the LLRW site)  and because U.S. EPA's selected
      remedy does  not require a vertical barrier wall encircling the
      LLRW  site and the Old and New Sites, it will be possible  to
      install effective slurry walls without tying them into the Canton
      Shale.  If additional boreholes,  to be taken along the final
      location of the slurry walls during the CMI design phases,
      indicate the need to tie into deeper shale (i.e., below the
      Danville coal), that would then be required by U.S. EPA.   Refer
      also  to the  response to concern III.3.
12.    Concern:
      Slurry walls keyed into the top of bedrock will  not stop the
      potential  leakage of contaminants from the Old Site.   Contaminants
      will  migrate downward through unplugged boreholes,  along the
      bedrock aquifers, and into glacial  aquifers where bedrock aquifers
      subcrop beneath the Old Site.  [B2,p.2,H3; B7,p.l,^3;  B7,pp.14-15;
      E2,p.30,12]
                                                      •
      Response:

      Please refer to the response directly above concerning capture of
      potentially migrating contaminated ground water.
13.   Concern:
      The cap proposed for the Old Site should include a geomembrane and
      should be thick enough to prevent infiltration of water through
      cracks caused by desiccation.  [C4,p.5,Hl]

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                                19

      Response:

      Issues such as the one Involving desiccation will  be carefully
      evaluated  during review of cap designs submitted to U.S.  EPA and
      IEPA for approval.  Technical  guidance documents and experience
      available  from other sites will  assist in selecting an effective
      cap design.  Flexible membrane liners (FML)  may not be required
      for these  landfills because neither one has  an FML in the bottom
      and 40 CFR §265.310(a) requires that the final cover "have a
      permeability less than or equal  to the permeability of any bottom
      liner system or natural subsoils present."
14.    Concern:
      US Ecology believes that releases from the 18EWC area of the New
      Site have already been effectively controlled by prior activities.
      With the addition of the proposed slurry walls,  modifications to
      the existing trench barrier wall  are not necessary.   [02,p.15,HI;
      D2(Att.l),p.l4,14]

      Response:

      Although US Ecology has shown some evidence indicating possible
      shrinkage in the 18EWC plume size, U.S. EPA is not convinced that
      this issue is adequately resolved.  The selected remedy will
      require further review during the design phase of CMI to evaluate
      the existing trench barrier wall's effectiveness in containing
      leachate in the trench thereby allowing removal  by sumps in the
      trench.  If the barrier wall is ineffective as constructed,  repair
      will be required to tie the wall  into a low-permeability stratum.
15.    Concern:
      US Ecology believes that Resource Conservation and Recovery Act
      (RCRA) land disposal  restrictions will  not apply to soil  removed
      during construction of slurry walls,  as long as the removed soil
      is mixed with bentonite and backfilled  as part of the wall.
      [02,p.16,15]

      Response:

      Soil  excavated during construction of slurry walls will  trigger
      land disposal restrictions.  The appropriate handling and disposal
      of the contaminated soil and debris will  be established during the
      design phase of the CMI.  The soils and debris generated may
      qualify for a treatability variance under 40 CFR 268.44(h).
      Please refer also to a March 8,  1990, Federal Register (55 FR
      8666), which discusses these issues in  relation to RCRA corrective
      action.  In the past, US Ecology was required to handle all
      borehole cuttings as hazardous waste.  This request is consistent
      with past practices.

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                                20

16.    Concern:

      Since the submittal  of the draft FS for source control,  potential
      advantages of a new barrier wall technique have become evident.
      The technique,  called deep soil  mixing (DSM),  requires that little
      contaminated soil  be excavated and brought to  the land surface.
      [D2,(Att.l),p.l4,Hl-3]

      Response:

      Without any details on DSM, it is impossible to compare this
      newer, less proven procedure technically with  soil-bentonite
      slurry walls and to evaluate its overall implementability and
      effectiveness.   It seems likely that the DSN techniques would be
      more difficult  to quality assure during construction and less
      likely to achieve performance standards approaching those of a
      well-constructed,  well-designed slurry wall.

17.    Concern:

      The Illinois Attorney General's Office states  that there is no
      long-term history of slurry walls at hazardous waste sites and
      that slurry walls are not reliable.  [A5,p.2,U2]

      Response:

      A review of U.S. EPA's Record of Decision (ROD) database indicates
      that nineteen (19) Superfund RODs have included installation of
      slurry walls as part of site response actions.  In addition,
      slurry walls have been implemented at non-Superfund sites.  Slurry
      walls are generally included as one component  of an overall
      remedy.  When used in conjunction with ground-water extraction and
      capping,  U.S. EPA has considered slurry wall technology a viable
      part of remedial actions which are protective  of overall human
      health and the environment.  Although the technology's use for
      environmental control is relatively new, significant experience
      has been gained in implementing this technology.  A few examples
      of successful slurry wall implementation are included below.

      A slurry wall was installed in 1984 at the Lipari Landfill in New
      Jersey.  Site contaminants included a wide range of volatile and
      semi-volatile organic compounds.  The slurry wall completely
      encircled this 16-acre site.  Fred Cataneo, Remedial Project
      Manager,  stated that since this slurry wall was installed, water
      migration from the site has been reduced 90 to 95 percent.  Due to
      the effectiveness of containment, an innovative batch flushing
      remediation method will be implemented at the  site.  This system
      will inject fresh water into the containment area.  This water
      will then be extracted, in effect "flushing" out contaminants.  A
      treatment system will be used and treated water discharged to;a
      Publicly Owned Treatment Works (POTW).  Batch  flushing will be

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                          21

conducted two to three times per year.   In addition to the slurry
wall and treatment system, a cap has been placed over the site.

Another site which has implemented slurry walls is the Rocky
Mountain Arsenal site in Colorado.  Contaminants consisted chiefly
of pesticide components and by-products and army agent by-products
(although several hundred of unknowns were also detected).  Two
slurry walls were installed at different subsites in the early
1980s.  Each one was built downgradient of the contaminant plume
in an effort to reduce migration.  Each wall is approximately one-
half mile long.  One wall has been extended as the contaminant
plume was detected moving around the wall's ends.  In addition,
extraction wells were installed upgradient of the wall to pump and
treat ground water.  Treated water is injected to the downgradient
side of the wall.  Project Officer, J.D. Smith, reports that the
walls have performed well in reducing migration.

Slurry wall installation capabilities are rapidly developing.
Recently, for example, a slurry wall was installed around the
entire circumference of the South Side Landfill in Indiana.  This
site is an operating sanitary landfill, currently on the National
Priorities List (NPL).  A permit application renewal required that
a slurry wall and ground-water pump and treatment system be
installed.  A slurry wall surrounding the site's 265 acres was
installed using Italian equipment which simultaneously digs a
trench and fills it with water to prevent collapse.  The slurry
wall was installed to a depth of 100 feet and keyed into bedrock.

Another site, located in Mountain View, California, also involved
construction of a slurry wall to a depth of 100 feet.  However,
this wall was not keyed into bedrock.  Instead, ground water is to
be extracted from within the barrier to prevent contaminants from
leaving the site.  Site contaminants included a range of
industrial solvents in the soil and ground water underneath a
semiconductor manufacturing facility.  Extracted ground water will
be treated by air stripping and filtration.  Installation of the
wall involved a staged approach.  First, a backhoe with an
extension arm was used to excavate to a depth of fifty (50) feet.
A pair of cranes utilizing 13-ton cable grab buckets excavated to
the 100 foot depth.  Initial permeability tests conducted on the
wall had a result of 1.1 X 10"8 centimeters/second.  U.S. EPA will
seek to achieve a performance standard in this range at US
Ecology.

Several technical considerations are important in ensuring that
the overall alternative will provide both short- and long-term
effectiveness.  The considerations include:  (1) compatibility
between site wastes and the slurry wall;  (2) a knowledge of site
specific requirements (geology, depth of wall, hydrology, etc.);
and  (3) assurance that other components of the remedial action
work with the slurry wall to provide an effective overall remedy.

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                                22

      In addition,  quality assurance is  important  in  assuring wall
      design and installation results in a highly  impermeable wall.
      These considerations will  be addressed in the CMI  design phase.
18.   Concern:
      U.S.  EPA should consider in-situ bioremediation as an option for
      cleaning up the US Ecology hazardous waste sites.
      [Bl,App.A,p.2,Hl;  C4,p.6,\4]

      Response:

      U.S.  EPA evaluated the potential effectiveness of in-situ
      bioremediation as  a cleanup method for both soil  and ground water
      at US Ecology.  However, at the present time,  this technology does
      not appear to be feasible based on site-specific conditions.  The
      major organic contaminants at US Ecology are primarily chlorinated
      compounds, such as tetrachloroethene, trichloroethene, 1,2-
      dichloroethane, and others.  To date, in-situ  biodegradation of
      chlorinated organics has not  been demonstrated at a hazardous
      waste site in either pilot- or full-scale tests.   Several
      technology developers claim to have demonstrated biodegradation of
      chlorinated organics in the laboratory and at  smaller facilities.
      U.S.  EPA is currently evaluating these claims  and plans to test a
      bioremediation technology in  the near future under the Superfund
      Innovative Technology Evaluation (SITE) Program.

      If in-situ bioremediation is  demonstrated as an effective
      technology for chlorinated organic compounds,  the technology could
      be employed at US  Ecology in  the future to:  (1)  enhance the
      remedies proposed  by U.S. EPA and (2) reduce the amount of time
      needed to reach ground-water  cleanup goals.
19.   Concern:
      Slurry walls will  be ineffective in containing the types of wastes
      and leachate present at the US Ecology sites.   The buried wastes
      include some organic liquids with densities greater than water.
      "At concentrations above their respective solubilities in water,
      these will  form separate phases which will  sink to the bottom of
      the water phase and adversely" affect the bottom and side liners
      or slurry wall  barriers.  [Bl,App.A,p.2,U2; Bl.p.G.^l; Bl,
      p.17,HI]]

      Response:

      It is unlikely that organic chemicals are present in ground water
      at sufficient concentrations to form separate  phases.  The highest
      concentrations detected in remedial investigation ground-water
      samples were found in wells at the northern and eastern boundaries
      of the Old Site.  (One well in the center of the Old Site had much
      lower concentrations.)  However, even those organic chemicals

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                                      23

            detected at the highest  concentrations  (chloroform,
            tetrachloroethene,  1,2-dichloroethane,  and others) were well  below
            their water solubility limits.   For example,  the maximum
            tetrachloroethene concentration in ground water was  96 parts  per
            million (ppm)  while the  water solubility of this organic chemical
            is 150 ppm.  Based on this comparison,  there 1s little evidence to
            support the theory that  organic chemicals in the ground water will
            sink to form concentrated layers.


II.    GROUND-WATER CORRECTIVE MEASURES

      1.     Concern:

            Additional  monitoring wells are needed  north and west of the  New
            Site to detect potential continuing or  future releases of
            contaminants to the ground water.   [A2,p.3,§6; A5,p.6,K2]

            Response:

            In the Proposed Plan (page 5),  U.S. EPA stated that  facility
            activities  have contaminated  ground water along the  west side of
            the New Site.   US Ecology disputes this claim [D2,p.14,^2]  by
            referencing data from 1987 and 1988. Data from 1987 showed
            contamination in the ground water  west  of trenches  23 and 24  in
            wells G-131, G-145, and  G-146.   Contaminants were
            tetrachloroethylene (PCE) and methyl ethyl ketone (MEK).  Data
            from 1988 did not show contaminants in  the ground water in  those
            wells.  US  Ecology labels the 1987 results "anomalous".  However,
            soil gas and ground-water sampling results (in G-131) from
            November and July of 1986, respectively, indicated  the release of
            methylene chloride, trichloroethylene (TCE),  PCE, and chloroform
            at locations along the north  and west sides of the  New Site.
            Please refer to the Final Remedial Investigation (RI) Report
            (pages 4-46 and 4-55) and to  analytical data in Appendix C  to the
            RI report.   Page 4-55 states  that  "these data indicate that a
            ground-water contaminant plume, if one  exists, may  be isolated
            between G-145 and G-146."  In 1987, well water from  G-109 and
            G-147 contained the contaminants chloroform and PCE.  Based on the
            comment and the data, U.S. EPA will require submittal of a  work
            plan to install additional monitoring wells north and west  of the
            New Site to decrease the existing  spacing between wells G-160, G-
            161, G-162, G-146,  G-169, G-170, G-145, and G-147.,

      2.     Concern:

            Additional  monitoring wells are necessary south and  east of the
            New Site to detect potential  present or future releases to  ground
            water.  A contingency plan should  specify actions to be taken in
            the event a new release  is detected.  [A5,p.6,H2; A5,p.7,Ul]  \

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                                24

      Response:

      There are at least eighteen (18)  monitoring wells (for Indicator
      parameter evaluation,  assessment, and RI  activities)  south of
      trenches 20, 21,  and the three 18EW trenches.   (See page 5-14 of
      the RI report.)  This is a linear distance of about 800 feet.
      Well spacing appears to be less of a concern in these locations
      than east of trenches 14c, 15, and 16 B of the New Site, west of
      trench 22, and south of trench 23.  US Ecology will be required to
      submit a work plan to reduce well spacing at these locations.
      Under the RCRA program that IEPA is monitoring and directing, the
      "contingency plan" for actions to be taken if significant
      increases (or decreases in the case of pH) over background water
      quality are detected in specific wells, is described in 35 111.
      Adm. Code 725.193.  Resampling of ground  water would be done to
      confirm the initial results, a ground-water quality assessment
      plan would be submitted to IEPA,  and the  facility would be
      required to implement an assessment program capable of determining
      the rate and extent of the ground-water contamination and the
      concentration of the hazardous constituents.  Upon confirmation of
      a new release of contaminants from the facility, corrective action
      would be addressed either under the existing corrective action
      order or under an lEPA-issued post-closure permit.
3.    Concern:
      To limit or possibly halt the commingling of chemical  and
      radioactive contamination, and the eventual  discharge into Trout
      Lake, IDNS recommends U.S. EPA consider installing additional
      extraction wells south and southeast of the Old Site.   [A3,p.2,^1;
      A4,p.2,12; E2,p.71,12]

      Response:

      US Ecology modeled ground-water flow to assist in predicting the
      transport and concentrations of contaminants over time
      specifically in the vicinity of the Old Site for the Feasibility
      Study (FS) report.  (See the FS for Ground-Water Remediation
      Vol.1, Section 4.4.3 and Vol. II,  Appendix C.)  The locations  of
      the extraction wells and subsurface drains depicted on page 4-40
      of Vol. I were selected by US Ecology based on modeled ground-
      water flow which indicated those were the optimum locations,
      considering proposed ground-water extraction rates, to
      specifically address this concern.  However, further modeling  will
      be required under the CMI design phases.  U.S. EPA is also
      cognizant of the concerns that the ground-water extraction system
      implemented under corrective action must not negatively impact
      existing ground-water flow conditions at the LLRW site.  Modeling
      will be required to address these concerns as well.

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                                25

4.    Concern:

      One commenter suggests placing additional  extraction wells in any
      permeable saturated units encountered beneath the Toulon Sand
      above the bedrock to capture contaminants  which could "sink" below
      the capture system, and suggests recalculation of the estimated
      total water flow from extraction wells and subsurface drains.
      [A2,p.2,§2b-c]

      Response:

      This concern cannot be discounted and will be carefully evaluated
      during the design phase of the CMI.  The draft FS for ground-water
      remediation (Vol.1, p.4-39) discusses placement of well screens
      (also referred to as subsurface drains) at an elevation four (4)
      feet above the bottom elevation of the Toulon Sand.  The stated
      reason was that this elevation was "adequate to capture the Old
      Site plume without significantly affecting the regional flow
      directions outside the drain."  The final  extraction well design
      will have to consider the need to capture "sinkers" and
      "floaters", to reduce additional mixing of the chemical plume with
      the radionuclide plume, and to minimize potentially adverse
      effects on regional ground-water flow.  Based on the numbers,
      locations, and pumping rates of the wells in the finalized
      extraction well design, a recalculation of estimated total water
      flow will be possible.

5.    Concern:

      The exact locations where U.S. EPA is proposing that US Ecology
      place additional extraction wells is unclear.  [A2,p.2,§2e;
      B6,p.II-3,§8]

      Response:

      In the Proposed Plan (p.22) U.S. EPA states that US Ecology must
      modify its proposed extraction well system to "include placement
      of additional extraction wells at or near plume boundaries which
      will hydraulically prevent further migration of contaminated
      ground water."  Conceptually it is clear that the extraction well
      design must capture the plume and prevent its expansion.  Further
      modeling will indicate the optimal numbers and locations (i.e.,
      the detailed design) necessary to accomplish the established
      design goals.

6.    Concern:

      A commenter supports the proposed alternatives for extraction and
      treatment of contaminated ground water, but says the effectiveness
      depends upon immediate implementation.  [Al,p.l,H6; E2,p.18,^4]

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                                26

      Response:

      Based on ground-water remediation activities conducted at U.S.  EPA
      Superfund sites,  experience has shown that early implementation of
      a ground-water extraction and treatment system is advantageous  for
      both controlling  expansion and for remediation of the
      contamination in  a more timely manner.  Early installation and
      operation of a limited extraction system which is partially
      effective (i.e.,  not achieving all the established design goals)
      is preferable to  delaying installation of the extraction-well
      system for months or years during extensive RI/FS and design and
      modeling phases.   In fact, because of the actual data provided
      (e.g., ground-water levels and flow rates) during operation of  a
      more limited ground-water extraction system, the iterative process
      of developing an  effective, long-term, final design is advanced
      greatly.  Design  and installation of the extraction wells and
      treatment system  is presently estimated to take eighteen (18)
      months.

7.    Concern:

      U.S. EPA's preferred alternative for ground water is unacceptable
      because it will not provide long-term effective or permanent care
      to prevent or minimize the release of hazardous substances and
      will not protect  the water supply.  [A5,p.l,U2; B3,p.1,^4;
      E2,p.34,11]

      Response:

      U.S. EPA respectfully disagrees with these commenters.  The source
      control measures, when completely and acceptably implemented and
      maintained, will  prevent or minimize the release of hazardous
      waste, hazardous  constituents, and substances from burial
      trenches.  In conjunction with the source control components,  the
      ground-water extraction system will be designed to stop plume
      expansion while remediating the contaminated ground water
      maintained under  US Ecology property.  US Ecology will be required
      to maintain and operate the ground-water extraction and treatment
      system until the  company can demonstrate that established ground-
      water protection  standards (GPS) have been achieved for the
      remaining ground  water beneath the landfills and that the residual
      levels of contamination left in the ground water will not pose  a
      future threat to  human health or to the environment.  Therefore,
      ground-water and  surface water supplies adjacent to US Ecology
      will be protected.

8.    Concern:

      IDNS monitoring data indicate that radioactive contaminants have
      migrated to the ground water east of Trout Lake and suggest that
      chemical contaminants will do the same.  Therefore, existing water
      supplies to the east of the US Ecology site may be threatened by

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                                27

      migrating contaminants from the LLRW and Old Sites.   [A5,p.8,^l;
      A5,p.5; A2,p.2,§2f;  B6,p.1-4,1(1 and p.I-7,\l; E2,p.55,\2]

      Response:

      U.S.  EPA is aware and concerned about data indicating that
      radioactive contamination  (tritium) is present east  of Trout Lake.
      RI data confirmed also that some chemical contamination from the
      Old Site ground-water plume was discharging to Trout Lake.  These
      data necessitate an  effective system of extraction wells designed
      to prevent further plume expansion as soon as technically
      feasible.  Some existing monitoring wells may have sufficient
      casing diameter and  construction and be appropriately located to
      be used as interim or final design extraction wells.
      Unfortunately, however,  the delays in actually initiating the
      ground-water extraction and treatment system on site will  most
      likely be associated with design and construction of the treatment
      system itself and with obtaining a permit for discharge of treated
      ground water to surface water.  Current tritium concentrations are
      not yet a significant concern (see response to concern VI.1).
      However, ongoing ground-water monitoring will continue to assess
      concentrations and the effectiveness of all source controls
      implemented.
9.    Concern:
      The glacial units beneath the US Ecology sites are complex and do
      not function as a "single heterogeneous unit" with respect to
      subsurface contaminant migration.  The site hydrogeology has not
      been adequately defined.   Without this information, migration
      routes and velocities of plumes cannot be defined sufficiently to
      develop an adequate ground-water cleanup plan.  [84,1(2; B6,p.I-l,
      H2 through 4 and p.1-2,1(1-2; E2,pp.44-45]

      Response:

      The following statement is included in the RI report on page 4-96:
      "In general, the glacial  deposits can be treated as a single
      heterogeneous hydrogeologic unit."  This sentence followed several
      pages (e.g., 4-15 through 4-23; 4-95) documenting the observed
      heterogeneity of the geologic units which comprise the glacial
      aquifer.  The RI report states (page 4-95) that the ground-water
      flow is "controlled by variable ground surface topography . . .
      and by the heterogeneous hydraulic conductivities of the various
      hydrogeologic units" in the glacial aquifer.  The fact that the
      geology is complex does not eliminate from consideration use of a
      ground-water extraction system for remediation purposes.  Complex
      hydrogeology simply makes the design phases of the extraction well
      system more challenging.   Initial ground-water modeling done for
      the feasibility study indicated that the glacial aquifer, although
      complex lithologically, could be modeled credibly as a single
      layer with heterogeneous zones (see pp. C-18 to C-33; C-39 to C-

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                                28

      65;  and C-82 of Vol.  II  of the  draft  Ground  Water FS  Report).
      Implementing an effective extraction  well  system is an  iterative
      process.   Characterizing the geology  and ground-water modeling
      provides  limited information.   Actual  installation of wells  and
      observation of the effects of pumping on water levels is the final
      step in design.
10.    Concern:
      U.S.  EPA should identify sites where a ground-water extraction
      system (like the one proposed for US Ecology)  has worked
      effectively in such a complex geological  environment.   [64,^3;
      E2,p.37,f2]

      Response:

      Utilization of a ground-water extraction  system for halting plume
      expansion  and remediation of ground-water contamination is not
      uncommon.   Geologic complexity associated with glacial  activity is
      by no means unique to the Sheffield, Illinois, area.  Many areas
      of the central and eastern United States  have  been affected by
      glacial  erosional and depositional  activity.

      U.S.  EPA has developed a summary of pump-and-treat applications
      nationwide in a March 1990 document (EPA/600/8-90/003).  Locations
      (by site name and state) where this technology has been used in
      glacial  sediments include:  Des Moines, Iowa;  Verona Well  Field,
      Michigan;  General Mills, Inc., Minnesota; Amphenol Corp.,  New
      York; and  Black and Decker, New York.
11.    Concern:
      U.S.  EPA's assertion that the cleanup of the US Ecology could
      continue "indefinitely"  is not consistent with the Agency's
      positions under either CERCLA or RCRA.   Proposed U.S.  EPA rules
      for corrective action at RCRA sites require that the Agency
      "specify a schedule for ....  completing remedial activities."
      [D2(Att.l),p.l7,K3-5]

      Response:

      Existing statutory provisions and regulations regarding corrective
      action under RCRA, and with which this  action must be consistent,
      require the owner/operator to, among other things:

      1.     After the Regional Administrator  of U.S. EPA has specified
            the ground-water protection standard (GPS) in a permit (in
            this case under a Consent Order)  (40 CFR §264.100(a)), the
            owner/operator must implement, within a specified time, a
            corrective action program that prevents hazardous
            constituents from exceeding the GPS for individual

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                                29

            constituents  at  the  established  compliance  point  by  removing
            or treating them In  place"  (40 CFR  §264.100(b)  and  (c);

      2.     Establish  and implement  a ground-water monitoring program to
            demonstrate the  effectiveness of the  corrective action
            program (40 CFR  §264.100(d)); and

      3.     "Continue  that corrective action for  as long  as necessary to
            achieve compliance with  the ground-water protection
            standard"   (40 CFR §264.100(f)). The subpart states that
            corrective measures  may  be  terminated if the  owner/operator
            can demonstrate  that the GPS has not  been exceeded  for  a
            period of  three  consecutive years as  indicated by the
            ground-water  monitoring  program  established under 40 CFR
            264.100(d) to demonstrate the effectiveness of the
            corrective action program.

      US  Ecology is subject  to regulations requiring the  facility to
      eventually obtain a post-closure  permit.   It is,  therefore,
      logical  to be consistent with  the existing  requirements for
      permitted facilities.

      If  US Ecology is concerned about  the prospect of  perpetual
      extraction and treatment of contaminated  ground water,  it  is
      certainly to the company's advantage to:   (1) design, install,  and
      maintain the source control components of the selected  corrective
      measures to be as effective as possible;  (2) implement, as soon as
      technically feasible,  the  ground-water extraction well  system and
      treatment system meeting the guidelines established herein; and
      (3) consider voluntarily implementing  available or  emerging
      technologies to  enhance recovery  of organic contaminants  (e.g.,
      soil vapor extraction, in-situ bioremediation, etc.) and  achieve
      the GPS  within a shorter timeframe.
12.   Concern:
      A 30-year period will  not be sufficient to clean ground water if
      the source of contamination remains in place.   [B5,p.2,U4;
      E2,p.42,12]

      Response:

      Please refer to the response immediately above regarding US
      Ecology's responsibility to undertake corrective action and to
      remediate the ground water and the time involved to do so.
      Because the contaminant sources will  remain in place,  it is
      essential that all  components of the  selected  corrective action
      are well designed,  carefully installed, and properly maintained
      and operated to control future releases from the Old and New
      Sites.  The main objective of the CMI will be  appropriate design
      and effective implementation of each  component of the remedy.  As
      a result of these corrective measures, contaminated ground water

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                                      30                      A

            will  be addressed to achieve protection of human health and the
            environment.

      13.    Concern:
                                                                i
            It appears that ground-water cleanup will  continue Indefinitely.
            Without a defined end point, the success or failure of the cleanup
            plan  will be  difficult to measure.   [B5,p.2,<|[4; E2,p.42,\3]

            Response:                                   _     -  ;
                                                       "•i
            The primary objectives of the selected remedy are:  (1) to halt
            further contaminant plume migration; and (2) to effectively stop
            further release from the sources of contamination.  tA secondary
            objective is  remediation of the contaminated ground water while
            the contamination is hydraulically  controlled from further
            expansion.  The effectiveness of the extraction well system will
            be gauged by continued regular ground-water monitoring of wells
            inside and outside of the plumes to mon(,itor-j)oth for;plume
            concentrations (increases or decreases^ and ^expansion or shrinkage
            of the plumes.


III.   SITE GEOLOGY AND HYDROGEOLOGY                •   .  ,      '"{

      1.     Concern:

            Steve Barlow, a resident of Princeton, Ill.inpis, and'.other
            commenters, argued that because of  the presence of numerous
            cracks, joints, and fissures in the bedrock ielow the US Ecology
            site  (which contains the Old Mississippi River Bed Aquifer), the
            contaminants  are moving through the glacial fill toward the
            Princeton Bedrock Valley that many  people depend on as a source of
            drinking water.  [C2,p.l,1[4 and p.2,^1; Bl,pr.3,H2; E2,p.56,^2]

            Response:

            The RI report contains three years  worth of ..ground,-,water data from
            numerous monitoring wells.  When this RI investigation began in
            June  1986, 226 wells existed on site.  Nineteen (19) mere wells
            were  added in late 1986 and thirty-six (36) bedrock and glacial
            wells were installed in 1988.  Bedrock contamina^n^has been
            shown to be minimal except in the G-120 area and north slope seeps
            where the #7 coal seam contains contaminated-ground water.  Ground
            water is being drained to the north slope area by pipes inserted
            in the coal seam.  Contaminated water has been collected in this
            manner for a couple of years and sent off site for treatment and
            disposal.  Now, however, an on-site treatment plant is being
            constructed to properly handle the  extracted water on site and
            treat it to State-approved contaminant discharge limits.  There is
            no evidence to suggest contamination of the bedrock in the north
            slope area wells (glacial or bedrock) except the G-120 assessment

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                                31

      well area.  The contamination in the G-120 area is predominantly
      above and in the #7 coal.   Because empirical  data show limited
      bedrock ground-water contamination on site,  geologic conditions
      slow vertical movement of  ground water,  and  eventual
      implementation of a ground-water extraction  well  system will  halt
      plume expansion and remove and treat bedrock and  glacial ground
      water on site, the threat  of  contamination of any drinking water
      supplies will be minimized if not eliminated.
2.    Concern:
      Roy Mahnesmith and Edward Glubczynski  posed the question of what
      effect catastrophic events (i.e.,  statistical  outliers)  and the
      presence of unknown materials might have on containment  structures
      and hydrogeology at the site.  [C3,§3]

      Response:

      Although the records are incomplete regarding  hazardous  wastes
      disposed of in the Old Site trenches,  considerable information
      exists on the general  types of waste buried there.  Considerable
      information is known about the types of hazardous constituents
      that have been released to ground  water by infiltrating  surface
      water since the Old Site ceased receiving waste in 1974.  The
      hazardous constituents in the ground water are essentially a
      finger print of the waste buried in the landfill and after sixteen
      (16) years of surface water leaching constituents and of drums
      leaking to ground water, future significant changes to the general
      composition of the existing chemicals in the ground water are not
      anticipated.  Future releases will be reduced  by the placement of
      an effective landfill  cap on both  the Old and  New Sites.
      Catastrophic events, such as very  heavy rainfalls, can cause
      erosion of landfill caps (which can be repaired) and a rise in the
      ground-water table.  During the CMI design phases, contingencies
      will be developed for addressing such events should they occur.
3.    Concern:
      One commenter suggested that coal  exploration borings may have
      been drilled in the areas of the Old Site,  New Site, and LLRW site
      prior to waste disposal activities at the US Ecology site.  These
      exploratory borings would have penetrated to the Herrin Coal, and
      it is likely that the borings were never plugged or backfilled.
      If present, the borings would provide a direct pathway for
      contaminant migration from waste disposal areas into the glacial
      aquifers and deeper into the bedrock below the sites.  [B2,p.2,H2;
      B7,pp.11-14; C2,p.l,\4; C10,p.2,Ul; E2,pp.27-31]

      Response:

      This is a valid concern.  However, RI ground-water data suggest
      that the potential impact of unplugged coal exploratory borings on

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                                32

      the vertical  migration of contaminant from the Sheffield chemical
      disposal sites is very limited.   This may be the case for many
      reasons:  (1) The number of boreholes for coal exploratory
      purposes that are actually now covered with hazardous waste
      disposal cells is small  (possibly as many as eight to ten).
      Compared to the total  landfilled area of about forty-five (45)
      acres, the effect from these boreholes (each two or three inches
      in diameter)  is not expected to be significant; (2) The
      "unplugged" boreholes  are certainly not unobstructed conduits for
      contamination.  Upon withdrawal  of drilling equipment from an
      exploratory borehole,  some drilling muds would remain and become
      compacted in the borehole, other consolidated materials above
      bedrock would be expected to collapse into the corehole, and the
      reworking of glacial materials by heavy equipment during burial
      trench construction activities would also contribute to reducing
      the potential impact of abandoned boreholes; (3) The RI data
      suggest ground water moves more readily in a horizontal direction
      through the glacial sediments than vertically into the lower
      permeability bedrock.   For whatever reason, ground-water data from
      bedrock wells, especially in those screened in the Nos. 6 and 7
      coals, generally show  little or no contamination compare to
      glacial wells.  It is  difficult to definitively correlate any of
      the contamination in bedrock wells with the known approximate
      locations of the exploratory borings.  If any of these boreholes
      are acting to any extent as contaminant migration pathways, the
      components of the corrective action for both source control and
      ground-water remediation will reduce those effects over time. To
      further discount or test the potential validity of the migration
      pathway hypothesis, US Ecology has proposed to install seven (7)
      new monitoring wells screened in the #6 coal (i.e., the deepest
      bedrock penetrated by  the exploratory borings).  U.S. EPA is
      reviewing that proposal  now prior to approving it.
4.    Concern:
      U.S. EPA owes the public a "debt of explanation" for either
      failing to identify mining company test borings near the waste
      sites or withholding this information from the public.
      [CIO,p.2,12]

      Response:

      Under a RCRA corrective action, U.S. EPA directs studies.  U.S.
      EPA approved US Ecology's RI work plan in 1986 which included a
      search for all existing borehole data.  The chronology of the
      search for these data was presented by US Ecology in its comments
      to the Proposed Plan [D2,Att.l,p.l5] and more fully in a September
      11, 1990, document.  US Ecology submitted logs of exploratory
      boreholes and their approximate location in September 1990.  U.S.
      EPA neither knew of nor withheld any information regarding these
      exploratory boreholes.

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                                33

5.    Concern:

      US Ecology contends that ground water west of the New Site Is not
      contaminated,  based on the results of numerous samples collected
      after January  1987.  [D2,p.l4,2H;  D2(Att.l),p.l,!2]

      Response:

      Please refer to the response to concern II.1 which addresses
      lEPA's request for additional monitoring wells based on soil gas
      survey results west and north of the New Site.  There 1s
      sufficient documentation to confirm past releases and enough
      doubts about the adequacy of the present number of wells to
      require a closer well  spacing In those locations.

6.    Concern:

      US Ecology contends that there Is no evidence to support migration
      of Inorganic contaminants to Trout Lake, as implied by U.S. EPA's
      Proposed Plan.  [D2,p.14,1(3]

      Response:

      U.S. EPA concurs with this statement in that it is difficult to
      say definitely whether or not the inorganic contaminants in the
      Trout Lake water resulted from strip-mining activities primarily
      or could have  migrated from the Old Site in ground water
      discharging to the lake.  The inorganics under discussion were
      barium and zinc.  What is virtually certain is that PCE, at 5
      /jg/L, was related to the Old Site plume discharging to Trout Lake.
7.    Concern:

      U.S. EPA's Proposed Plan incorrectly implies that inorganic
      compounds detected in ground water, surface water, soil, and
      sediment are site-related.  Background concentrations an the
      effects of adjacent coal strip mining activities have not been
      considered.  [D2(Att.l),p.l,H4; D(Att.2),p.l3,1fl-3]

      Response:

      US Ecology had failed, prior to the Soils Addendum to the RI
      report, to successfully argue its own case (i.e., to show that
      observed levels of inorganic compounds are more likely related to
      strip-mining than waste disposal activities).  Many of the wastes
      accepted for disposal contained inorganics and, while agreeing
      with US Ecology that strip-mining activities have affected the
      concentration and distribution of inorganics, the origin of these
      must not be automatically assumed to be non-site related.  USX
      Ecology has stated on page 5-1 of the RI report that "organic and
      inorganic constituents have migrated from burial trenches and have

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                                34

      entered shallow ground water in three areas"  (underline added here
      for emphasis).
8.    Concern:
      It is clear that contaminants are migrating from ground water to
      Trout Lake.  A complete study of the hydraulic interaction between
      ground water and the lake should be conducted. Is IONS or US
      Ecology responsible for developing hydrogeologic data and
      investigating contaminant levels for Trout Lake?  [B5,p.2,\3;
      B6,p.II-3,§9; E2,p.41,K4]

      Response:

      US Ecology has conducted a study for IEPA in the area north, east,
      and south of Trout lake.  In December 1989, several  borings were
      completed and new monitoring wells were installed.  This was a
      one-time study to further characterize the hydrogeologic
      conditions in the southern half of Trout Lake.  A report on the
      additional studies is expected to be submitted to IEPA in the near
      future.  Ground-water samples were taken from these  new wells and
      were analyzed for both radionuclides and organics.

      Under the Consent Order with IDNS, US Ecology is required to
      sample specific IDNS monitoring wells on a stated regular basis
      and to analyze for  the presence and concentration of specified
      radionuclides and organics.  US Ecology is also required to
      analyze ground-water samples in some instances for the full list
      of 40 CFR Part 264 Appendix IX parameters.
9.    Concern:
      Contradicting statements are made in the RI report regarding
      "laterally continuous" geologic units and fractures and joints in
      those low-permeability rock sequences.   [Bl,p.25,^4; 81,p.8,^2;
      Bl,p.15,^2]

      Response:

      A basic concept in geology is that of the law of original
      continuity wherein the same sedimentary stratum is observed to be
      present in borings from place to place.  Lateral continuity of a
      geologic unit (e.g., the Farmington Shale) beneath the landfills
      and the presence of joints or fractures within that unit are not
      mutually exclusive conditions.
10.   Concern:
      Some commenters criticized the RI reports (e.g., no easy way to
      locate the 200+ monitoring wells; figures are too small; geologic
      cross-sections are too simplistic, although "a wealth of data is
      contained on the bore logs"; wanted additional bore holes to

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                          35

better define bedrock contours, etc.; over simplifications of
glacial geology and hydrology; potentiometrie surface maps may be
misrepresenting actual conditions; data points are not labelled or
are inaccurate; maps and figures are poorly labeled and difficult
to read; appendices do not include all data collected; the
reference list is incomplete; material in the text is attributed
to the wrong source; and contradictory information's presented.
[Bl,pp.9-13; B5,p.1,15-7; B5,p.2,Hl-2; BGip.VB.^nd p.1-6,1(1-2;
E2,pp.39-41 and pp.43-51]                ?         -*:.
                                         •'.  •'• ''j    £0 '  , ":
Response:                                "     >'•  •*• :<  '•'•

The Final RI Report was approved by U.S. EPA in April 1989,
following its original submittal (March 18, 1987), the appended
version (October 5, 1988) after completion of,one, year of
additional study, and two subsequent revisions YeWested by U.S.
EPA.  It is not easy to present the vast amount i>f data generated
for this RI report without some simplification "orgeneralization
of hydrogeologic conditions found on site.  The gb%l in the RI
process is to distill from the RI study thennfordsjion necessary
to make decisions regarding corrective measures "selection.  U.S.
EPA RI/FS guidance states:  "the objective of the Wl/FS process is
not the unobtainable goal of removing all uncertainly,1 but rather
to gather information sufficient to support an informed risk
management decision regarding which remedy appears1 %o be most
appropriate for a given site."  Choices made durini the RI
investigations, "like the remedy selection itseTf:,-rinv|qlve the
balancing of a wide variety of factors and thW ex^cisB of best
professional judgment" (EPA/540/G-89/004; 'OctoBer:¥98&; p.1-3).
Based on this guidance, U.S. EPA determined tttsC^-he Final RI
Report contained and presented sufficient data (e.g., borelogs,
ground-water analyses, plume dimensions, etc.) to develop,
evaluate, and make decisions regarding remedial alternatives.

With respect to the specific comments raised by Ms.; Morse (B6),
most comprise a summary and reintroduction of comments she
submitted as a former employee of the State of Illinois.  In fact,
her submittal attaches the complete list of IEPA comments on the
October 5, 1988, draft of the RI report transmitted to U.S. EPA on
February 2, 1989.  All of these comments were reviewed by U.S. EPA
before approval of the Final RI Report in April ftSJJ".  US Ecology
satisfactorily addressed all significant comments1 Wresponse to:
(1) Revisions requested by U.S. EPA prior to receitfV orf IEPA;
comments; (2) A second set of revisions requested py: U.S. EPA
after receipt and inclusion of most IEPA comments;"1 a^nd (3) Direct
responses to IEPA on each issue raised in their February 2, 1989
comments.  It is not useful to itemize herein the responses to all
these comments.  They are already present in the record.

U.S. EPA, using professional judgment, approved the^Ffnal RI
Report after determining that sufficient informaticSi had been"
generated under the RI to allow informed decisions to'be made

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                                36

      regarding the corrective measures study and that the Information
      was adequately presented In the RI report.   It 1s U.S.  EPA's
      position that sufficient information is available to allow
      technical decisions to be made in selecting the corrective
      measures appropriate for this facility.
11.    Concern:
      The Old Site plume has migrated to bedrock in spite of what US
      Ecology says on page 5-34 of the RI report.   See page 5-22, Table
      5-5.
      Response:

      The RI report states (p. 5-34)  "it can be concluded that the plume
      remains confined primarily to  the glacial  aquifer and has not
      penetrated into the bedrock to any great extent."  Table 5-5 does
      indicate the detection of four organics in four bedrock wells (not
      all four in the same well). Three of these chemicals are common
      laboratory contaminants and the other, benzene, was found in only
      one well at 14 ppb.  All  concentrations were below 37 ppb.  These
      concentrations are minimal when compared,  for example, to glacial
      aquifer contaminant concentrations (see Table 5-4, p. 5-17) of up
      to 180,000 ppb for chloroform.  No one is stating that the bedrock
      aquifer is unaffected by releases.  However, empirical data
      support the first sentence of  this response.  The distribution of
      contamination indicates that the ground water transporting it
      shows a greater tendency to move horizontally than vertically
      (i.e., through unconsolidated  glacial sediments rather than into
      fractures in bedrock).
12.   Concern:
      One commenter described several problems with hydraulic gradients
      presented in the RI report; gradients are based on incorrect
      calculations of screened intervals or well depth; hydraulic
      conductivity values attributed to one unit are based on data from
      a different unit; vertical  gradients were not calculated from
      supplemental RI well  data as planned; and no ground-water
      velocities or horizontal gradients are provided.  [B6,p.1-4,^3 and
      1-5,HI; E2,pp.48-51]

      Response:

      It appears these comments are based on those originally submitted
      by IEPA regarding the October 5, 1988, draft RI report.  All
      hydraulic gradients were recalculated for the Final  RI Report.
13.   Concern:
      Ground-water surface maps presented in the RI are inaccurate
      because data used to construct the maps were collected over too

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                                      37

            long a time span and  data from different  glacial  units  are
            combined.   [B6,p.1-4,\3  and p.1-5,HI;  E2.p.48,H3-4]

            Response:

            Certainly,  the time span over which  ground-water  levels are
            recorded in monitoring wells  can affect the final  map produced in
            some cases.  Readings were taken by  US Ecology for all  wells
            usually on  one day, when possible, but never over a  time period
            exceeding 48 hours.  For example, the  June 1988 water levels were
            taken on June 6 and 7.   Wells screened in different  glacial units
            undoubtedly will cause some minor inaccuracies.  However,  the data
            generated during the  RI, using many  wells and water  level  readings
            from three  years,  compare favorably  to potentiometric maps from
            the site from as early as 1976 to the  present and show  similar
            ground-water flow directions  and gradients.  These maps also
            generally agree with  those produced  in studies of the LLRW site.

      14.    Concern:

            Data collected during the RI  (e.g.,  core  descriptions,  drilling
            water loss, and influx records) refute the claim  that shallow
            bedrock strata act as an impediment  to ground-water  flow.
            [B6,p.1-2,13; E2,p.45,H3-4]

            Response:

            While review of such  records  kept during  installation of
            monitoring  wells may  indicate this is  true in some instances, the
            fact remains that empirical data from  ground-water sampling and
            analysis in bedrock and  glacial wells  generated during  the RI show
            limited vertical migration of contamination.  The data  suggest a
            much greater inclination to move laterally through shallow,
            unconsolidated glacial sediments than  vertically  through the
            bedrock.


IV.    REMEDIAL INVESTIGATION AND  FEASIBILITY STUDY

      1.     Concern:

            A few commenters questioned the reliability of the RI as
            pertaining  to the ground-water sampling because of. the  extreme
            drought conditions that  were  present in the county dating back to
            1986.  [Cl; C3,2§; Bl,p.22,Hl; E2,p.53]

            Response:

            Ground-water sampling has been conducted  at US Ecology  since 1981
            and continues to be done.  Results are sent to IEPA  on  a regular
            basis for  assessment  and indicator parameter evaluation monitoring
            wells.  Wells which initially detected releases of hazardous

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                                38

      wastes or hazardous constituents leading to the 1985 Consent Order
      to perform corrective action did so prior to the drought
      conditions and have continued,  when sampled, to show evidence of
      contamination.  Drought conditions could have the following effect
      on the ground-water table and the results from the sampling and
      analysis in the wells:   (1)  A general  lowering of the water table
      potentially leaving some hazardous constituents adhering to soil
      particles; and (2) Less infiltration of surface water through the
      buried wastes and, therefore, lower levels of constituents in the
      ground-water samples.  A review of ground-water contours under the
      Old Site, on October 20, 1976,  (p.4-19 of RI report) and June 1988
      (p.4-99 of the RI report) show that the elevations (west to east)
      were about 760 to 730 feet and 750 to 730 feet, respectively.
      These pages indicate some decreases in water table elevation over
      the twelve (12) years,  but the changes in the contours on the four
      glacial aquifer maps are not striking.  The contamination has been
      shown to be present by reliable sampling and analytical techniques
      and the effect the drought conditions had on the concentrations is
      difficult to assess.  The contaminated ground water requires
      remediation and it must be hydraulically controlled to stop
      further plume migration.

      U.S. EPA obtained annual precipitation data from Moline, Geneseo,
      Walnut, Tiskilwa, and Kewanee for the years 1980 to 1988.  These
      data do not support fully the claim that drought conditions
      affected sampling results.  Annual precipitation for most sites
      (Kewanee is the exception) tended to exceed long-term averages
      during this period.
2.    Concern:
      Climatological data presented in the RI report (such as average
      and maximum 24-hour rainfall) are incorrect and underestimate real
      conditions.  This could have an effect on hydrologic modeling of
      the site and on the design of corrective measures.  [B7,p.18,^1]

      Response:

      The commenter has pointed out that certain data contained in the
      RI report were incorrect (e.g., the mean annual precipitation for
      Moline, Illinois, was stated to be 35.70 inches rather than 35.83
      inches and the 24-hour rainfall was stated to be 5.7 inches rather
      than in excess of six (6) inches).  Further hydrologic modeling of
      the sites will be performed during the CMI design phases.  Data
      inputs will be updated as necessary.
3.    Concern:
      The RI report does not include any geologic maps of the site,  such
      as a bedrock geologic map.  [B7,p.18,^2]

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                                      39

            Response:

            While this Is true,  many cross section maps depicting the
            thickness and distribution of geologic strata are included for the
            Old and New Sites.   These, along with the bedrock contour map,
            were sufficient to  provide an adequate two and three dimensional
            picture of the geology.

      4.    Concern:

            Several maps in the RI report are computer-generated and do not
            accurately represent site conditions.  [B7,p.19,^1; B6,p.1-3,1(2]

            Response:

            Subsurface maps, whether drawn by hand or computer generated,  are
            based on a limited  number of data points.  A map drawn by one
            geologist or hydrologist may not exactly resemble that drawn by
            another using the exact same data.  The goal, however, is to
            produce maps which,  in spite of their inherent inexactness,
            provide tools which will allow decisions to be made regarding the
            corrective measures selection.  The RI report has provided the
            detail necessary for technical decisions.  The U.S. EPA has
            provided comments to US Ecology on Figure 4-22 of the RI report.
            That bedrock topography map indicates a closed-contour depression
            in the bedrock which does seem illogical and may be a result of
            too few data points at the east end near Trout Lake.


V.  INTERACTIONS BETWEEN CHEMICAL AND RADIOACTIVE WASTE

      1.    Concern:

            Commenters say that the preferred ground-water alternative does
            not address remediation of ground water contaminated with
            radionuclides.  They suggest that extracted water from wells south
            and southeast of the Old Site be monitored and treated for
            radioactive contamination, if such contamination is found.
            [A2,p.2,§2d; A3,p.2,U2i  A4,p.2,1(3; E2,p.71,13]

            Response:

            U.S. EPA does not agree with the first part of the comment.  The
            very last item in Section V of the Proposed Plan (page 22) states
            that US Ecology must:

                  "Provide for regular sampling of the extracted ground water
                  for those radionuclide parameters in Table 5-7 of the RI
                  plus 1-129.  A plan and schedule for these sampling
                  activities will be required."

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                                40

      Regarding the second portion of the concern raised,  U.S. EPA
      stated in the Proposed Plan (page 36):

            "The alternative will require testing of extracted ground
            water for the presence of a specified list of radionuclides
            and, if any are detected, appropriate treatment of the water
            and management of associated wastes generated."

      South or southeast of the Old Site are the locations where the
      chemical/radioactive ("mixed") plume is most likely to be
      encountered.
2.    Concern:
      Commenters are concerned that alterations in the ground-water flow
      patterns will  cause radioactively contaminated ground water from
      the LLRW site to combine with chemically contaminated ground water
      from the Old Site.   [A5,p.4]

      Response:

      This is a valid concern and certainly will be an important factor
      in designing the extraction well system (e.g., number of wells,
      well locations, pumping rates, possible use of reinjection wells,
      etc.).  The CMI will include additional ground-water modeling as
      various designs are considered to address concerns of U.S. EPA and
      several commenters.  The modeling already done by US Ecology (p.
      4-39 of the ground-water FS) indicated a desire to limit southerly
      and southeasterly flow:  "The eastern edge of the drain is
      designed to prevent further migration of the plume toward the
      tritium plume."  Also on page 4-39, US Ecology discusses design
      considerations related to adequately capturing "the old site plume
      without significantly affecting the regional flow directions
      outside the drain."

3.    Concern:

      Commenters share concerns of the Illinois Department of Nuclear
      Safety (IDNS)  about ground-water flow and problems this may cause
      at the Low Level Radioactive Waste (LLRW) site.  They suggest that
      U.S. EPA select a remedy that will not adversely affect the LLRW
      site.  [A2,p.l,§ld; A5,p.8,H2; Al,p.l,K7; E2,p.19,12; E2,p.55,ll]

      Response:

      Please refer to the response immediately above.

4.    Concern:

      The mixture of radioactive and chemical contaminants, pumped from
      the Old Site,  will  complicate safe handling and treatability of
      extracted ground water.  [A5,p.4]

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                                41

      Response:

      U.S.  EPA concurs with this statement.   However,  1t 1s unacceptable
      to allow continued expansion  of the Old Site plume of contaminated
      ground water.   U.S. EPA's position remains unchanged:  the Old
      Site  plume must be managed so as to preclude further plume
      expansion and  the contaminated ground  water must be extracted and
      treated until  established ground-water protection standards are
      achieved In spite of the presence of radionuclides mixed In with
      the chemical plume.  The details of how the extracted water will
      be managed will be determined during the CMI design phase.
5.    Concern:
      US Ecology believes that:   (1)  draft U.S.  EPA guidance on
      "Corrective Action for Solid Waste Management Units (SWMU) at
      Hazardous Waste Management Facilities11 supports a position of non-
      action on portions of the  ground-water plume that are contaminated
      with both chemical and radioactive wastes  and (2) natural
      attenuation is an appropriate remedy for this part of the plume.
      [D2,p.lO,12]

      Response:

      The "guidance" cited by US Ecology is from the Proposed Rule (55
      Federal  Register 30798) dated July 27, 1990.  U.S. EPA disagrees
      with this comment by US Ecology on page 10 of their submittal.  US
      Ecology quotes preamble language from the  proposed rule (page
      30825) to support their position.   However, US Ecology's argument
      is unsupportable because:   (1)  It  is unlikely that, in this
      situation, "ground-water cleanup standards can be achieved through
      natural  attenuation within a reasonable time frame"; (2) The
      contaminant plume is already greater than  twenty-three (23) acres
      in size, contains multiple contaminants of concern to human health
      and the environment, including radioactive constituents; (3)
      tritiated water is already detected in ground water east of Trout
      Lake and the RI report contains data showing organics from the Old
      Site plume have been discharged to Trout Lake; and (4) The plume
      will continue to increase  in size  until an extraction well and
      treatment system is installed and  operational under the CMI.
      These points argue for active restoration  of the contaminated
      ground water and for hydraulic controls on further migration of
      the plumes.
6.    Concern:
      Commenters recommend that U.S.  EPA require US Ecology to show
      (through modeling and monitoring) that construction of the slurry
      walls and cap will have no adverse effects on the known hydrology
      of the radioactive site.  [A3,p.3,11-2; A4,p.3,12-3; E2,p.73,12-3]

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                                42

      Response:

      US Ecology will  be required to conduct additional  ground-water
      modeling during  the design phase of the CMI.   Prior modeling for
      the ground-water FS did not take into account the  effects of a
      slurry wall around the Old Site on the hydrology of the
      radioactive site.   Modeling will provide insight into the probable
      effects on the ground-water elevations and flow directions in the
      vicinity of the  LLRW site. Upon implementation of the source
      control components, piezometers will  be installed  (or existing
      ones could be used, if appropriately located) to assess,  on a
      regular basis, the effects on the hydrology.   The  design  of the
      extraction well  system for ground-water remediation will  be such
      that increased or decreased pumping rates from suitably located
      wells will assist in maintaining the desired  design water table
      levels.
7.    Concern:
      Commenters recommend that U.S.  EPA require a sequential  approach
      during application of ground-water remediation and source control
      measures so that any effects of either activity on the
      radiological site can be distinguished and assessed.   [A3,p.1,^4;
      A4,p.l,13; E2,p.70,13]

      Response:

      U.S. EPA believes that it is necessary to install  extraction  wells
      in the whole plume rather than  sequentially extracting and
      treating portions of the plume, as is suggested by this  comment.
      The commenter can be assured that additional ground-water
      modeling, prior to installation of components, will be performed
      and ground-water levels will be monitored to assess potentially
      adverse effects on the hydrology after installation.   A
      contingency plan will be prepared to respond to any observed
      adverse effects.
8.    Concern:
      Laboratory analysis of ground water contaminated with both
      radionuclides and chemicals poses unique problems.  Potential
      delays in receiving laboratory results could affect the flow of
      ground water through the treatment processes.  The accuracy of
      analytical results is important if this information will be used
      to make treatment or disposal decisions for radioactively
      contaminated water.  [B6,p.II-3,§7]

      Response:

      U.S. EPA concurs with these concerns and every effort will be made
      during the design of the ground-water extraction and treatment
      system to fully address them.

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                                      43

      9.    Concern:

            The hazardous waste sites and the LLRW site at US Ecology should
            be dealt with together in a comprehensive cleanup plan.   [B6,p.I-
            7,f2; E2,p.51,15-6]

            Response:

            In response to the suggestion that the various units be  treated as
            one large facility, there are reasons why the current approach is
            preferable.  First, various government agencies have independent
            jurisdiction over the various units located at the site.  IDNS has
            jurisdiction over the radioactive waste site.  IEPA 1s responsible
            for overseeing the closure activities at the New Site as this
            would be part of its authorized program.  U.S. EPA has
            jurisdiction over the corrective action activities at the
            hazardous waste units under the Consent Order.  This Order was
            entered into between U.S. EPA and US Ecology and is binding upon
            them and no other parties.  Second, it makes sense to split off
            the remedies related to the radioactive site from the hazardous
            waste sites as the contamination related to each are different in
            nature and should be addressed independently.  To a degree, the
            ground-water activities set forth here will address contamination
            emanating from all of the units at the site.

      10.   Concern:

            Several commenters stated that the chemical and low level
            radioactive waste sites should not be considered separately in
            terms of public health or proposed cleanup plans.  The entire area
            should be treated as one problem.  [B3,p.l,U5; B7,p.15,^3;
            C10,p.l,H4; E2,p.34,H2]  However, others believe that the chemical
            and radioactive waste sites at Sheffield are distinct facilities
            with separate ownership, and should be regulated as such.
            [D2,p.9,13]

            Response:

            Please refer to responses to concerns 1.11, V.9, and VI.1.


VI.   HEALTH EFFECTS AND CLEANUP LEVELS

      1.    Concern:

            The Public Health Risk Evaluation did not address risks  associated
            with ground water contaminated with low level radioactive waste.
            [A2,p.2,§3; C3,§4]

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                          44

Response:

This is a correct statement.  The calculated risks to health
presented in the RI report focused on the risks associated with
the multiple chemical contaminants being released to ground water
principally from the Old Site.  The radioactive constituents in
the ground water are more restricted in their distribution than
these chemical constituents and are associated solely with
specific portions of the Old Site plume.  In addition, the levels
of chemicals contaminants in the overlapping areas of the chemical
and radioactive plumes are lower relative to the more contaminated
areas of the plume.  See figures on pages 5-30, 5-31, and 5-32 for
maps showing contoured chemical concentrations in the Old Site
plume.  Table 5-7 on page 5-36 of the RI report lists the levels
of radioactive contaminants detected in the ground water in 1988.
Figure 1-10 of the ground-water FS (page 1-48) illustrates
overlapping areas of the two plumes.

Using sampling data supplied in Appendix M of the Remedial
Investigation (RI) report, the estimated lifetime excess cancer
risk from ingesting the ground water containing radionuclides from
the LLRW has been estimated.  The sampling data included data for
samples taken from 20 wells in the area affected by the LLRW that
were analyzed for 19 radionuclides (radioactive elements).  Of the
19 radionuclides sampled for, eleven were identified at the site.
To be conservative, any radionuclide concentration detected was
assumed to come from the site.  (Many radionuclides are found to
occur naturally.)

Two methods were used to estimate the excess cancer risk resulting
from exposure to the radionuclides identified at the site.
Exposure was assumed to result from ingestion of ground water as
drinking water.  The first method, using risk factors generated by
the U.S. EPA, estimated an excess cancer risk of 4 x 10"6.  This
means that under a recreational use scenario, four (4) excess
cancer cases can be expected out of each 1,000,000 recreational
users.

The second method, using similar calculations, but with
incorporating risk factors generated by the International
Commission on Radiological Protection (ICRP), estimates an excess
cancer risk of 5 x 10 .  This means that the excess cancer cases
expected from the previously-discussed exposure will be five (5)
excess cancer cases for every 100,000 recreational users.

The difference in risk estimates between the two methods exists
because the second method allows more of the radionuclides
identified at the site to be considered in the final risk
estimate.  The first method (using U.S. EPA risk factors) allows
inclusion of seven (7) of the eleven (11) nuclides identified.

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                                45

      The second method (using ICRP risk factors)  allows Inclusion  of
      all eleven (11).
2.    Concern:
      One commenter expressed a growing concern that there may be a
      cancer cluster near Sheffield,  with an increasing "number of
      cancers of the nature of those  normally associated with
      radioactivity."  [CIO, p. 1,1(6]

      Response:

      An investigation into the incidence of cancer in Bureau County,
      Illinois, was performed by the  Illinois Department of Public
      Health (IDPH), Division of Epidemiological Studies.  A report on
      the results of this investigation, entitled "Incidence of Cancer
      in Buda, Mineral,  Neponset,  and Sheffield in Bureau County,
      Illinois," was released in September,  1990.  The investigation was
      performed under the administration of Dr. Holly L. Howe, Chief of
      the Division of Epidemiological Studies.

      Data for all cancer incidence  in the designated area from 1985 to
      1988 were obtained from the Illinois State Cancer Registry (an
      incidence of cancer is a newly  diagnosed case).  These data, the
      "observed" incidence of cancer, were  compared to data from an
      area in the State  of similar population and age distribution, the
      "expected" incidence of cancer.  Statistical tests were then
      performed on these data to see  if there were any statistically
      significant differences between the incidence of cancer for each
      population.  A statistically significant difference could indicate
      that the incidence of cancer in Bureau County is higher than
      "normal."

      The results for all types of cancer combined were as follows.  In
      males, 37 cases were observed,  with 38 expected.  For females, 45
      cases were observed, with 40 expected.  These differences were not
      found to be statistically significant for either sex.  Therefore,
      with regard to combined cancers, no cancer cluster was identified
      in the report.  Incidence of site-specific canc°rs was also
      compared in the report, with no conclusions being made.

      It is possible that with a larger data set, possibly facilitated
      by using mortality data, more  conclusions could be drawn from the
      report.  (Mortality data is based on deaths attributable to a
      particular cause.)                             :
3.    Concern:
      US Ecology questions the assumptions behind the risk assessment
      used as a basis for determining ground-water cleanup levels.  :
      These assumptions result in an overestimate of risk by nearly two
      orders of magnitude.  The risk assessment uses an exposure

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                          46

scenario that assumes future residential  use of the site,  with
residents drinking two (2) liters of ground water per day  over a
70-year period.  Current U.S. EPA guidance on risk assessment for
Superfund sites suggests that 30 years is a more appropriate time
period to estimate "reasonable maximum exposure."  Further,  future
residential use of the US Ecology Sheffield sites is highly
unlikely, and alternate exposure scenarios, such as recreational
use of the site, should be considered if the risk assessment
process will be used to derive ground-water cleanup goals.
[Dl,p.2,H5; D2,p.4,12; D2,p.5,ll; D2(Att.l),pp.5-10;
D2(Att.2),pp.2-3,12,14-15,19-21,23]

Response:

As this comment indicates, risk estimates in the Final Remedial
Investigation Report (April 1989) were based on the assumptions of
future residential use of the US Ecology site and a 70-year  period
of exposure to the most contaminated ground water.  These
assumptions were carried through to the risk assessment summary in
U.S. EPA's May 1990, Proposed Plan.

U.S. EPA has carefully considered this comment in light of the
most recent Agency guidance on conducting risk assessments at
hazardous waste sites (Risk Assessment Guidance for Superfund,
Volume I, Human Health Evaluation Manual, December 1989
[EPA/540/1-89/002]).  This guidance states that cleanup actions
"should be based on an estimate of the reasonable maximum  exposure
(RME) expected to occur under both current and future land-use
conditions."  The guidance further indicates that "an assumption
of future residential use may not be justifiable if the
probability that the site will support residential use in  the
future is exceedingly small."  For example, "if the site is  ...
located in a very rural area with a low population density and
projected low growth, ... a more likely alternate future land
use may be recreational."

U.S. EPA believes that future residential use of the US Ecology
site is highly unlikely.  The corrective measures proposed by the
Agency will be designed to effectively contain wastes in place and
long-term management and maintenance of the facility will  be
required, including continued extraction and treatment of ground
water.  Thus, U.S. EPA agrees that a recreational use exposure
scenario is more appropriate for evaluating future risks at  this
site.  U.S. EPA has adopted the exposure assumptions suggested in
this comment (ingestion of 2 liters of water per day for 32  days
per year over a 20-year period).  The Agency has used these
assumptions to evaluate future risks associated with various
ground-water cleanup goals, as described in the next response.

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                                47

4.    Concern:

      US Ecology disagrees with the ground-water remediation goals in
      the Nay 1990 Proposed Plan.  The company states:  (1) that U.S.
      EPA's use of RCRA practical quantitation limits (PQLs) to
      establish ground-water cleanup levels is excessive and unwarranted
      and is not supported by any agency guidance and (2) that PQLs have
      no basis in the protection of human health and do not consider
      conditions specific to the US Ecology site, such as background
      concentrations of chemicals.  US Ecology further states that the
      ground-water remediation goals proposed in the draft FS for ground
      water are acceptable and will protect human health and comply with
      all applicable or relevant regulations.  However, US Ecology's
      comments propose two additional sets of ground-water cleanup
      levels, based primarily on Maximum Contaminant Levels (MCLs),
      regulatory standards for drinking water.  [01,p.2,1(3-4; D2,pp.4-6;
      D2,p.8,Hl; D2(Att.l),pp.3-13; D2(Att.2),pp.l-2,6,9-ll,21-23]

      Response:

      In this Response to Comments, U.S. EPA is proposing a set of
      ground-water remediation goals slightly different from the goals
      listed in the Proposed Plan.  In putting forth these goals, the
      Agency has considered:  (1) regulatory requirements for ground-
      water protection standards in 40 CFR 264; (2) the Proposed Rule
      for Corrective Action for Solid Waste Management Units at
      Hazardous Waste Management Facilities (55 FR 30798, July 27,
      1990); (3) background concentrations for the 11 contaminants that
      account for the majority of risk; and (4) the exposure and risk
      assessment assumptions described in the previous response.

      According to 40 CFR 264.94(a), ground-water protection standards
      should be set at background levels of the hazardous constituents
      or at the maximum contaminant levels (MCLs) established by U.S.
      EPA under the Safe Drinking Water Act.  Alternate concentration
      limits (ACL) are appropriate only if the use of these limits will
      not pose a substantial present or potential hazard to human
      health.  The Proposed Rule for Corrective Action requires ground-
      water cleanup standards that ensure protection of human health,
      taking into account the potential uses of ground water.

      Background concentrations for all eleven (11) contaminants were
      evaluated by reviewing sampling results from well 434, designated
      in the RI as the background well for the glacial aquifer.  Nine of
      the eleven (11) contaminants were not detected in this well;
      arsenic and methylene chloride were found in two (2) of eight (8)
      samples with maximum concentrations of 7 jig/L and 10 /jg/L,
      respectively.  Based on these results and on the guidelines listed
      above, U.S. EPA has selected ground-water protection standards
      that reflect either site-specific background concentrations (based
      on routinely achievable analytical detection limits) or MCLs.
      These goals are as follows:

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                                48

            10 /jg/L                 arsenic

            5 /ig/L                  benzene,  chloroform,  1,1-
                                    dichloroethane,  1,2-dichloroethane,
                                    1,1-dichloroethene, 1,2-
                                    dichloropropane, methylene chloride,
                                    tetrachloroethene,  trlchloroethene

            2 ng/L                  vinyl  chloride

      Ingestion of ground water with these concentrations, under the
      exposure assumptions described in the previous response, will
      result in an excess cancer risk of 2 x 10'5.   This value is within
      the 10"4 to 10"* target range defined  as  the "protective risk range"
      in the Proposed Rule for Corrective Action.

      U.S.  EPA believes these goals to be reasonable, achievable, and
      protective of human health under the assumptions  that:  (1) ground
      water above these concentrations has not and will not migrate
      beyond the current facility boundary; and (2)  the facility will
      remain under active management and post-closure care by US
      Ecology.  Should either of these conditions change, the cleanup
      goals and exposure assumptions on which they are  based would be
      reevaluated.
5.    Concern:
      Risk assessment of hazardous waste sites is an uncertain process.
      The results of this process must be viewed as estimates, with a
      range of possible values, rather than as single value, invariant
      results.  U.S. EPA has failed to acknowledge that the uncertainty
      about the results of risk assessments is generally at least an
      order of magnitude.  [D2(Att.l),p.5,1fl; D2(Att.2),p.l9,12]

      Response:

      U.S. EPA recognizes the uncertainty inherent in the risk
      assessment of hazardous waste sites and has specifically
      considered this uncertainty in proposing ground-water cleanup
      goals for the US Ecology site.  The estimated risk for ingestion
      of ground water containing chemical contamination at the proposed
      cleanup levels is approximately 2 x 10"5.  This estimate is near
      the middle of U.S. EPA's target risk range of KT1 to 10"6.   The
      Agency believes that these cleanup goals are more appropriate than
      less protective goals suggested by US Ecology because of the
      uncertainties that must be factored into the risk assessment.
      These uncertainties include:  (1) the potential synergistic
      effects of exposure to multiple chemicals; (2) the additional
      risks due to radionuclides in ground water at the site (see
      response to concern VI.1 above); and (3) the need to maintain
      adequate post-closure care at the facility.

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                                49

6.    Concern:

      The Risk Assessment Summary in the proposed plan Indicates that if
      ground water were cleaned up to the RCRA Practical  Quantitative
      Limits proposed,  risks from exposure would still be above the
      target risk range established by U.S. EPA.  [A2,p.2,§4]

      Response:

      The Proposed Plan estimated the cancer risks for future ground-
      water consumption to be slightly higher than 10"* (one (1) case of
      cancer for every 10,000 people exposed).  The 10"* figure
      represents the lower limit of U.S. EPA's target risk range.  This
      risk estimate was based on the assumptions that:  (1) ground water
      would contain contamination at the proposed cleanup goals; (2) the
      US Ecology site would be used for future residential development;
      and (3) persons drinking the ground water would reside in this
      development for seventy (70) years.

      As indicated in the response to comment VI.3 above, future
      residential development of the US Ecology site is extremely
      unlikely.  Current U.S. EPA guidance on risk assessment suggests
      that recreational use of the site is a more plausible scenario for
      future exposure to ground water, after cleanup goals proposed in
      this document have been achieved.  Under these conditions, the
      estimated cancer risk of 2 x 10'* would be within U.S. EPA's target
      risk range.

7.    Concern:

      Risks due to arsenic in ground water should be reconsidered for
      two reasons: (1)  the uncertainty about the carcinogenic potency of
      this chemical and (2) the high background levels of arsenic near
      the site.  US Ecology believes that the carcinogenic effects of
      arsenic should not be considered in establishing cleanup levels
      for this metal.  [02,p.5,13; D2,p.6,12; D2(Att. l),p.!3,1f3-4]

      Response:

      U.S. EPA strongly disagrees with both portions of this comment.
      First, there is little debate about the carcinogenicity of
      arsenic.  This metal can cause cancer in humans after inhalation
      exposure and from ingestion of drinking water.  The specific
      carcinogenic potency of arsenic via ingestion is currently under
      review.  However, this is not sufficient justification for
      ignoring arsenic in estimating risks or proposing cleanup goals
      for ground water at US Ecology.  U.S. EPA has used the most
      recently available unit risk for arsenic (from the Agency's
      Integrated Risk Information System database, June 1990) to
      estimate ground-water ingestion risks.  This assessment can be

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                                     50

           repeated when a new risk factor is available,  and the risks and
           ground-water cleanup goal adjusted, if necessary.

           Second, ground-water sampling data from the RI do not support the
           statement that background concentrations of arsenic in ground
           water are high.  Arsenic was detected in only two of eight samples
           from well 434, the glacial aquifer background well for the RI.
           The maximum concentration detected was 7 /*g/L.  Further, although
           most of the waste volume for the Old Site is unknown, the known
           portion includes arsenic-containing wastes.  Thus, arsenic found
           in ground water near the Old Site Is much more likely due to waste
           disposal activities than background, and arsenic must be
           considered when evaluating site risks and proposing cleanup goals.
VII. MISCELLANEOUS COMMENTS

     1.    Concern:
           Hazardous and toxic wastes buried at the landfill pose a present
           and future danger to the environment and to the health and welfare
           of the People of the State of Illinois.  Every possible step to
           protect citizens' health and welfare has not been examined; a
           final cleanup plan must promote long-term effectiveness.
           [A5,p.l,12; Al,p.l,H4-5; C3,§5; C3,§8; E2,p.l9,H3]    :

           Response:

           U.S. EPA has required US Ecology to conduct the Remedial
           Investigation and Feasibility Study (RI/FS) following U.S. EPA
           guidance.  A document titled "Initial  Screening of Remedial
           Technologies" was submitted by US Ecology in August 1988.  U.S.
           EPA required US Ecology to consider further (in the draft FS)
           exhumation and other technologies not screened out in the August
           1988, document.  All viable, practical, proven technologies have
           been evaluated.  U.S. EPA has selected a remedy which will be
           protective of human health by reducing greatly the chances of
           future releases through effective source control and by addressing
           the previous releases by stopping plume expansion and extracting
           and treating contaminated ground water until established ground-
           water protection standards specified by U.S. EPA in this document
           are achieved.  US Ecology will be required to manage the source
           control and ground-water remediation components of the corrective
           measure so that long-term protection is assured.  Should any
           additional areas of release be identified around the New Site
           which were not apparent during the RI/FS process, further studies
           would be conducted and a separate decision made as to how to
           address them.

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                          51
Concern:
One commenter stressed a need for corrective action to begin as
soon as possible.  [C4,p.7,f2]

Response:

U.S. EPA concurs with the commenter.  Experience with ground-water
remediation at other hazardous waste sites has shown the
importance of early installation and operation of extraction
wells.  This is conducive to controlling plume expansion and a
more rapid remediation of the ground water.  In addition,
identified releases of hazardous wastes or constituents will
likely continue until source control measures are in place.
However, all components of the corrective measures require further
design phases prior to implementation and some components may
require obtaining a permit before certain procedures can be
performed.

Comment:

As a result of IDNS and U.S. EPA's meeting on December 21, 1989,
to discuss proposed alternatives, U.S. EPA concluded that IDNS
"concurred" with the preferred alternative, specifically, slurry
walls.  IDNS feels 'concurrence' is not entirely accurate.
[A3,p.2,14; A4,p.2,H5; E2,p.72,13-5]

Response:

The Proposed Plan (page 36) did not wish to imply total
concurrence with the Plan; rather it qualified the degree to which
IDNS and U.S. EPA agreed on the conceptual approach for
remediation during discussion at that meeting.  Specifically,
discussions resulted in the conclusion that, among other things:
(1) Placing slurry walls around the Old Site, rather than
subsurface drains, was expected to ultimately result in fewer
changes to the local hydraulic gradients thus impacting the
existing conditions around the LLRW site to a lesser degree.
Ground-water levels outside the slurry wall can be maintained at a
higher level than inside, whereas drains would be more likely to
cause a more  general lowering of the water table.  (2) Extracted
ground water, which may contain radioactive constituents, would
require testing for the presence of specified radipnuclides.
Appropriate treatment and management would be required if
detected.

Concern:

There is some concern that the cost of remedying the site will
ultimately fall on the taxpayers.  Several commenters stated that
the corporation responsible for problems at the site should bear
the full financial responsibility for cost of corrective action.

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                                52

      [A5,  transmittal  letter,  U2; B3,p.2,J2-4;  C3,p.l,§l;  C9,p.l,U2;
      Cll}  E2,p.35,fl]

      Response:

      US Ecology signed the Consent Order 1n 1985 to conduct an RI/FS
      and to Implement  the corrective action selected by U.S. EPA.   To
      date, US Ecology  has performed each task required under the
      Consent Order at  considerable expense to the company (I.e.,
      estimated, 1n a US Ecology press release,  to be about $4.5 million
      so far).  US Ecology provided financial assurance $2.50 million),
      as required In the Consent Order, to guarantee performance of the
      RI/FS and Implementation  of the selected corrective action.  US
      Ecology has absorbed the  costs of the RI/FS and has given every
      indication that the company intends to comply with the Consent
      Order and implement the selected remedy.
5.    Concern:
      Area citizens should be the final  judge of the plan's
      effectiveness.  [Al,p.2,Kl]

      Response:

      U.S. EPA policy and guidance promotes public involvement and
      comment during the decision-making process.  The State of
      Illinois, public officials, and private citizens have commented on
      the Proposed Plan.  The next step, that of selecting the remedy,
      is left to U.S. EPA under its statutory mandate.  The preferred
      alternative from the Proposed Plan can be, and has been, modified
      based on comments received during  the comment period.
6.    Concern:
      Commenter says that the cost of the remedy is secondary to
      citizenr/ protection.  [Al,p.2,\2]

      Response:

      U.S. EPA has selected corrective measures based on the ability of
      the technologies chosen to protect human health and the
      environment.  Under RCRA, cost is not considered as a factor
      except when deciding between alternatives which are determined to
      be equally protective.
7.    Concern:
      Several individuals emphasized the need for some type of
      contingency plan to deal with components of the corrective action,
      such as slurry walls, caps, and ground-water monitoring,     ;
      extracting, and treatment.  The contingency plan is necessary
      because these components are not totally reliable and are not

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                                53

      described in sufficient detail  in U.S.  EPA's proposed plan.   The
      contingency plan should describe the required care,  maintenance,
      and repairs for slurry walls and other  components.   The plan
      should also include provisions  to use advances in technology as
      these become available.  [A5,p.3,^l; 64,^3-6; C4,p.4,\5,p.2,f2,
      and p.7,1(2; B6,p.I-7,U3; E2,p.37,^3; E2,p.52,K3]

      Response:

      U.S. EPA's Proposed Plan selected alternatives from the two  draft
      FS reports submitted by US Ecology as a conceptual  approach  to
      remediate the site and suggested some modifications to the
      alternatives proposed.  While it is true that the Proposed Plan
      itself does not contain design  detail,  the individual alternatives
      themselves are described in considerable detail in the draft FS
      reports and their appendices.  It is clear that estimated costs
      for construction and for operation and  maintenance of specific
      components could not have been  calculated and presented in these
      reports if considerable detail  had not  been generated.  However,
      during the CMI, much more detail will be added prior to approval
      of a final design.  U.S. EPA will require that specific
      performance criteria be established for each component of the
      corrective measures.  In conjunction with the performance
      standards, procedures will be established for evaluating each
      component's performance and, if the performance is not adequate,
      an existing contingency plan will be implemented to address  the
      problem identified.  If a specific technology is shown to not be
      effective, the company will be  required to implement other
      technologies, as approved by U.S. EPA.
8.    Concern:
      US Ecology points out that the Old Site ceased operation before
      the passage of RCRA and should not be referred to as a RCRA site.
      [D2,p.l4,Hl]

      Response:

      The US Ecology site is a RCRA hazardous waste disposal facility.
      A RCRA Part A permit application was submitted by US Ecology for
      the New Site activities and US Ecology obtained interim status
      allowing it to operate at this facility.  The New Site was
      operated from 1974 into 1983.  The Old Site was operated from 1963
      to 1974 prior to passage of RCRA in 1976.  However, the wastes
      disposed of in both disposal sites consist of wastes currently
      defined as hazardous under RCRA.  The Old Site is most correctly
      called a "solid waste management unit" (SWMU) and both sites are
      subject to post-closure permit requirements.  Releases of
      hazardous waste or hazardous waste constituents from a permitted
      facility require remediation under the permit.  Under interim
      status, a corrective action consent order has been used to
      implement corrective action activities.  In this case, U.S. EPA

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                                54

      and US Ecology entered Into a Consent Order to address corrective
      action at this interim status facility.
9.    Concern:
      One commenter questions the reasons US Ecology purchased 84.5
      acres during the period 1985-1987.  Did they fear "off-site
      migration of plume?"  [Bl,p.4H3]

      Response:

      US Ecology has purchased property at various times for at least
      three different reasons:  (1) For remedial investigation studies,
      including placement of RI monitoring wells (see purchased blocks
      of property labeled numbers "7" and "10" on Figure 2-2, page 2-6
      of the RI report); (2) For creation of a "buffer zone" required
      under a Consent Order with IDNS (see blocks of property labeled
      numbers "5," "6," "8," and "9"); and (3) For use as "borrow
      areas," including clay for the LLRW site cap (see property labeled
      number "4").
10.   Concern:
      U.S. EPA's Proposed Plan does not include detailed design and
      construction information.  When a complete remediation plan is
      developed at a later date, the public should be allowed to comment
      on this document.  [B6,p.II-l,H2]

      Response:

      No statutory authority requires U.S. EPA to solicit public
      participation or comment on the various stages of design under the
      CMI (i.e., preliminary, intermediate, prefinal, and final) and no
      guidance or framework has been developed for incorporating public
      comments or such documents which, by their nature, are draft until
      approved.  However, U.S. EPA will continue to update citizens and
      send documents to the repository for review as they become
      available.
11.   Concern:
      U.S. Ecology is concerned about lEPA's role in overseeing
      corrective action at the Sheffield sites and that IEPA will impose
      unnecessarily stringent and unrealistic requirements in this role.
      Response:

      IEPA has authority to review closure activities at hazardous waste
      facilities because Illinois has been authorized to carry out these
      activities in lieu of U.S. EPA in the State of Illinois.  U.S. EPA
      believes that IEPA has responsibility and authority to review

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                                      55

            closure activities at the New Site.   It is U.S.  EPA's
            understanding that IEPA and US Ecology jointly waived the 90-day
            review requirement for closure/post-closure plans In 1985.   Thus,
            IEPA will  continue to be involved in closure activities for the
            New Site.

            The US Ecology landfills are also subject to a post-closure permit
            to be issued by IEPA.  As of this year (April 1990), IEPA has been
            authorized to include the corrective action portions of post-
            closure permits in the permits it Issues as an authorized State.
      12.   Concern:

            US Ecology believes that U.S.  EPA should take full  RCRA
            jurisdiction over the US Ecology Sheffield sites and that the
            Agency should declare that corrective action implemented pursuant
            to the §3008(h) order is equivalent to final closure of the
            facility.  [D2,p.12,^3]

            Response:

            It has also been suggested that the Old and New Site should be
            treated as a corrective action management unit.  The basis for
            this suggestion is the proposed corrective action rule issued on
            July 20, 1990, at 55 Federal  Register 30798.  Under this proposal,
            the Agency has the authority to designate corrective action
            management units (CAMU) which may contain more than one unit in a
            contaminated area under certain circumstances.  The Agency does
            not feel it is appropriate to designate these units as a CAMU at
            the current time.  First, the Agency under the proposed
            regulations has discretion to designate units as CAMUs based on
            site-specific circumstances.   In this case, the old and new units
            are sufficiently independent of each other such that the Agency
            feels that they should not be designated as a CAMU.  Second, to
            date, the proposed regulations have not been finalized; and
            therefore, the process for designating units as CAMUs is not in
            force at this point.  As far as lEPA's jurisdiction over this
            facility, Illinois is an authorized State for portions of the RCRA
            program.


RESPONSE TO PUBLIC CONCERN

      All of the significant concerns raised by the public were answered as
described above.  Although the major components of the selected corrective
measures are the same as those proposed in the Proposed Plan, several
significant details and requirements were amended based on comments received.

1.    Several new monitoring wells will be added around the New Site to
      facilitate detection of any future or presently undetected releases-to
      ground water.

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                                      56

2.    Revised ground-water protection standards are included.

3.    Ground-water modeling will be required to predict the effect of these
      corrective measures, once implemented, on the LLRW site.

4.    Contingency plans will be developed to negate any potentially adverse
      effects on the LLRW site which may result during or after implementation
      of the corrective measures.

5.    Performance standards will be required and established for each
      component of the corrective measures.  This will allow for evaluation of
      the component's effectiveness.


REMAINING CONCERNS

      One remaining concern is the request from at least one group of
commenters that they be allowed to review and comment on the CMI design
details as they are developed prior to implementation of the selected
corrective measures.  At this time, no mechanism exists to grant this request.
Certainly, the community will be provided with updates on the project during
the CMI process through citizen letters and documents sent to the repository
in Sheffield, Illinois.

                                             y
DECLARATIONS

      It has been determined that the selected remedy being implemented is
appropriate and will be protective of human health and the environment.

Date
Valdas V. Adaml
Regional Admin/strator
U.S. Environmental Protection Agency
Region 5     '

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ATTACHMENT I

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                      CORRECTIVE MEASURE IMPLEMENTATION
                                      AT
                    US ECOLOGY. INC.. SHEFFIELD. ILLINOIS


The purpose of this  Corrective  Measure Implementation  (CMI) program  is  to
design, construct, operate,  maintain,  and monitor the  performance  of the
corrective measure or  measures  selected to  protect  human  health  and  the
environment.  Respondent  will furnish  all personnel, materials and services
necessary for the implementation of  the corrective  measure or measures.

   I.   Corrective Measure  Implementation Program Plan

        The Respondent shall prepare a Corrective Measure Implementation
        Program Plan.   This  program  will include the development and
        implementation of several  plans, which require concurrent  preparation.
        It may be necessary  to  revise  plans as the  work is performed to focus
        efforts on a particular problem.  The Program  Plan includes  the
        following:

        A.  Program  Management  Plan

            The Respondent shall prepare a  Program  Management Plan which will
            document the  overall management strategy for  performing  the
            design,  construction,  operation, maintenance  and monitoring of
            corrective measure(s).   The plan shall  document the  responsibility
            and authority of all organizations and  key personnel involved with
            the implementation.  The Program Management Plan will  also  include
            a description of qualifications of key  personnel directing  the
            Corrective Measure  Implementation Program,  including contractor
            personnel.

        B.  Community  Relations Plan

            Respondent shall propose a Community Relations Plan, or  revise an
            existing one, to include any changes in the level of concern of
            information needs to the community during  design and construction
            activities.

            1.  Specific  activities  which must be conducted during the  design
                stage  are the following:

                a.   Revise the  facility Community Relations Plan to  reflect
                    knowledge of citizen concerns and  involvement  at this
                    stage of the process; and

                b.   Prepare  and distribute  a public notice and an  updated
                    fact  sheet  at  the  completion of engineering  design.

            2.  Specific  activities  to be conducted during the construction
                stage  could  be  the following:  Depending  on citizen  interest
                at a facility at this  point in the  corrective action process,

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        community relations  activities  could  range  from  group  meetings
        to fact sheets  on  the technical  status.

C.  Data Collection Quality  Assurance Plan

    The Respondent shall prepare a plan to  document all  monitoring
    procedures:  sampling, field measurements and sample analysis
    performed during the design, construction, and  operation phases  of
    the corrective measures  implementation  and the  long-term
    monitoring  of the  performance of the measures.  The plan  shall  be
    designed to ensure  that  all  information,  data and resulting
    decisions are technically sound,  statistically  valid,  and  properly
    documented.

    1.   Data Collection Strategy

        The strategy section of  the Data Collection Quality Assurance
        Plan shall include,  but  not be  limited to the following:

        a.  Description of the intended uses  for the data,  and the
            necessary level  of precision and  accuracy for  these
            intended uses;

        b.  Description of methods and  procedures to be  used to assess
            the precision, accuracy and completeness of  the
            measurement data;

        c.  Description of the rational  used  to assure that the data
            accurately  and precisely  represent a characteristic of a
            population, parameter variations  at a sampling  point, a
            process condition or an environmental condition.   Examples
            of factors  which shall  be considered and discussed
            include:

              i.   Environmental  conditions  at the time of  sampling;

             ii.   Number of  sampling  points;

            iii.   Representativeness  of selected media;  and

             iv.   Representativeness  of selected analytical
                  parameters.
            Description  of  the measures  to  be  taken  to  assure that  the
            following  data  sets can  be compared  to each other:

              i.   RFI  data  generated by  the Respondent  over  some  time
                  period;

             ii.   RFI  data  generated by  an  outside laboratory or
                  consultant  versus  data generated by Respondent;

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    iii.   Data generated  by separate consultants  or
          laboratories; and
     iv.   Data generated  by an outside consultant or
          laboratory over some time period;  and
e.  Details relating to the schedule of,  and information  to  be
    provided in quality assurance reports.   The reports should
    include but not be limited to:
       i.  Periodic assessment of measurement data accuracy,
          precision, and  completeness;
      ii.  Results of performance audits;
     iii.  Results of system audits;
      iv.  Significant quality assurance problems  and
          recommended solutions; and
       v.  Resolutions of  previously stated problems.
Sampling
The Sampling section of the Data Collection  Quality  Assurance
Plan shall discuss:
a.  Selecting appropriate sampling locations, depths,  etc.;
b.  Providing a statistically sufficient number of sampling
    sites;
c.  Measuring all necessary ancillary data;
d.  Determining conditions under which sampling should be
    conducted;
e.  Determining which media are to be sampled (e.g., ground
    water, air, soil, sediment, etc.);
f.  Determining which parameters are to be measured  and where;
g.  Selecting the frequency of sampling and  length of sampling
    period;
h.  Selecting the types of samples (e.g., composites vs.
    grabs) and number of  samples to be collected;
i.  Measures to be taken  to prevent contamination of the
    sampling equipment and cross contamination between
    sampling points;
j.  Documenting field sampling operations and procedures,
    including:

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           i.  Documentation  of procedures for preparation of
              reagents  or  supplies which become an  integral part
              of  the sample  (e.g.,filters, and adsorbing
              reagents);
          ii.  Procedures and forms for recording the exact
              location  and specific considerations  associated with
              sample acquisition;
         iii.  Documentation  of specific sample preservation
              methods;
          iv.  Calibration  of field devices;
           v.  Collection of  replicate samples;
          vi.  Submission of  field-biased blanks, where
              appropriate;
         vii.  Potential interferences present at the facility;
        viii.  Construction materials and techniques, associated
              with  monitoring wells and piezometers;
          ix.  Field equipment and sample containers listing;
           x.  Sampling  order; and
          xi.  Decontamination procedures;
    k.   Selecting appropriate sample containers;
    1.   Sample preservation; and
    m.   Chain-of-custody,  including:
           i.  Standardized field tracking reporting forms to
              establish sample custody in the field prior to
              shipment  and during shipment; and
          ii.  Pre-prepared sample labels containing all
              informationnecessary for effective sample tracking.
3.  Field Measurements
    The Field  Measurements section of the Data Collection Quality
    Assurance  Plan  shall discuss:
    a.   Selecting appropriate field measurement locations, depths,
        etc.;

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b.  Providing a statistically sufficient  number  of  field
    measurements;
c.  Measuring all  necessary ancillary data;
d.  Determining conditions  under  which field  measurement
    should be conducted;
e.  Determining which media are to be addressed  by  appropriate
    field measurements (e.g., ground  water, air, soil,
    sediment, etc.);
f.  Determining which parameters  are  to be measured and where;
g.  Selecting the  frequency of field  measurement and length of
    the field measurements  period; and
h.  Documenting field measurement operations  and procedures,
    including:
       i. Procedures  and  forms for recording  raw data and  the
          exact location, time, and facility-specific
          considerations  associated with  the  data acquisition;
      ii. Calibration of  field devices;
     iii. Collection  of replicate measurements;
      iv. Submission  of field-biased  blanks,  where
          appropriate;
       v. Potential  interference  present  at the  facility;
      vi. Construction material and techniques associated  with
          monitoring  wells  and piezometers used  to  collect
          field data;
     vii. Field equipment listing;
    viii. Order in which  field measurements were made;  and
      ix. Decontamination procedures.
Sample Analysis
The Sample Analysis section of the Data Collection  Quality
Assurance Plan shall  specify the  following:
a.  Chain-of-custody  procedures,  including:
       i. Identification  of a responsible party  to  act as
          sample custodian  at the laboratory, who is

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          authorized to sign  for  incoming  field  samples,
          obtain documents  of shipment,  and  verify  the  data
          entered onto the  sample custody  records;
      ii.  Provision for a laboratory sample  custody log
          consisting of serially  numbered  standard  lab-
          tracking report sheets; and
     iii.  Specification of  laboratory sample custody
          procedures for sample handling,  storage,  and
          dispersion for analysis;
b.  Sample storage procedures and storage  times;
c.  Sample preparation methods;
d.  Analytical  procedures,  including:
       i.  Scope and application of the procedure;
      ii.  Sample matrix;
     iii.  Potential interferences;
      iv.  Precision and accuracy  of the  methodology;  and
       v.  Method detection  limits;
e.  Calibration procedures  and frequency;
f.  Data  reduction, validation and reporting;
g.  Internal  quality control  checks, laboratory  performance
    and system audits and frequency, including:
       i.  Method blanks;
      ii.  Laboratory control  samples;
     iii.  Calibration check samples;
      iv.  Replicate samples;
       v.  Matrix-spiked samples;
      vi.  "Blind" quality control samples;
     vii.  Control charts;
    viii.  Surrogate samples;
      ix.  Zero and span gases; and

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                              8
               x.  Reagent  quality control checks;
        h.   Preventative maintenance procedures and schedules;
        i.   Corrective  action  (for laboratory problems); and
        j.   Turnaround  time.

D.  Data Management  Plan
    The Respondent shall develop and initiate a Data  Management  Plan
    to document and  track  investigation  data and  results.  This plan
    shall  identify and  set up  data documentation  materials and
    procedures, project file requirements,  and project-related
    progress reporting  procedures and  documents.   The plan shall  also
    provide the format  to  be used to present the  raw  data  and
    conclusions of the  data collected  (e.g., ground-water  elevations,
    hydraulic conductivities,  permeabilities, analytical data,
    particle-size  analysis, etc.).
    1.  Data Record
        The data record shall  include  the following:
        a.   Unique sample  or field measurement code;
        b.   Sampling or field  measurement location and  sample or
            measurement type;
        c.   Sampling or field  measurement raw data;
        d.   Laboratory  analysis identification number;
        e.   Property or component measured; and
        f.   Result of analysis (e.g.,  concentration).
    2.  Tabular Displays
        The following data shall be presented in  tabular displays:
        a.   Unsorted (raw) data;
        b.   Results  for each medium, or  for each  constituent
            monitored;
        c.   Data reduction for statistical  analysis;
        d.   Sorting  of  data by potential stratification factors  (e.g.,
            location, soil  layer, topography); and

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             e.  Summary data.

         3.   Graphical Displays

             The following data shall be presented in graphical formats
             (e.g., bar graphs, line graphs, area or plan maps, isopleth
             plots, cross-sectional plots or transacts, three dimensional
             graphs, etc.):

             a.  Display sampling location and sampling grid;

             b.  Indicate boundaries of sampling area,and areas where more
                data are required;

             c.  Displays levels of contamination at each sampling
                location;

             d.  Display geographical extent of contamination;

             e.  Display contamination levels, averages, and maxima;

             f.  Illustrate changes in concentration in relation to
                distance from the source, time, depth or other parameters;
                and

             g.  Indicate features affecting intramedia transport and show
                potential receptors.

II.   Corrective Measure Design

     Respondent shall prepare final construction plans and  specifications
     to implement  the corrective measure(s) at the facility as  defined  in
     the Corrective Measure Study.

     A.  Design Plans and Specifications

         Respondent shall develop clear and comprehensive design plans  and
         specifications which include, but are not limited  to the
         following:

         1.    Discussion of the design strategy and the design  basis,
              including:

              a.   Compliance with all applicable or relevant
                  environmental and public health standards; and

              b.   Minimization of environmental and public  impacts.

         2.    Discussion of the technical factors of importance including:

              a.   Use of currently accepted environmental control measures
                  and technology;

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                              10
         b.   The constructability of the design; and
         c.   Use of  currently  acceptable construction practices and
             techniques.
    3.    Description of assumptions made and detailed justification of
         these assumptions;
    4.    Discussion  of the possible sources of error and  references to
         possible operation  and maintenance problems;
    5.    Detailed drawings of  the proposed design  including:
         a.   Qualitative flow  sheets; and
         b.   Quantitative flow sheets.
    6.    Tables listing equipment and specifications;
    7.    Tables giving material and energy balances;
    8.    Appendices  including:
         a.   Sample  calculations (one example presented and explained
             clearly for significant or unique design calculations);
         b.   Derivation of equations essential to  understanding the
             reports; and
         c.   Results of laboratory or field tests.
    9.    Detailed performance  standards for each component of  the
         corrective  measures and development of procedures to  evaluate
         performance and also  contingency plans to address inadequate
         performance.
B.  Operation and Maintenance  Plan
    Respondent shall prepare an Operation and Maintenance Plan to
    cover both implementation  and long-term maintenance of the
    corrective measure components.  The plan shall  be composed of  the
    following elements:
    1.    Description of normal operation and maintenance  (O&M):
         a.   Description of  tasks for operation;
         b.   Description of  tasks for maintenance;
         c.   Description of  prescribed treatment or operation
             conditions; and

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                      11
 d.  Schedule showing frequency of  each  O&M task;
 Description of potential  operating problems:
 a.  Description and analysis  of potential  operation problems;
 b.  Sources of information regarding  problems;  and
 c.  Common and/or anticipated remedies;
Description of routine monitoring and  laboratory testing:
 a.  Description of monitoring tasks;
 b.  Description of required laboratory  tests  and  their
     interpretation;
 c.  Required QA/QC; and
 d.  Schedule of monitoring frequency  and date,  if
     appropriate, when monitoring may  cease;
 Description of alternate  O&M:
 a.  Should systems fail,  alternate procedures to  prevent
     undue hazard; and
 b.  Analysis of vulnerability and  additional  resource
     requirements should a failure  occur;
 Safety plan:
 a.  Description of precautions, of necessary  equipment,  etc.,
     for site personnel; and
 b.  Safety tasks required in  event of systems failure;
 Description of equipment:
 a.  Equipment identification;
 b.  Installation of monitoring components;
 c.  Maintenance of site equipment; and
 d.  Replacement schedule  for  equipment  and installed
     components; and
 Records and reporting mechanisms required:
 a.  Daily operating logs;

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                              12

         b.   Laboratory  records;

         c.   Records  for operating  costs;

         d.   Mechanism for  reporting  emergencies;

         e.   Personnel and  maintenance records;  and

         f.   Monthly/annual  reports to the  Illinois Environmental
             Protection  Agency.

    An initial  Draft  Operation and  Maintenance Plan shall  be submitted
    simultaneously with  the Prefinal  Design Document  submission  and
    the Final Operation  and Maintenance  Plan with  the Final  Design
    Documents.

C.  Cost Estimate

    Respondent shall  develop cost estimates for the purpose  of
    assuring that the facility has  the financial resources necessary
    to construct and  implement the  corrective measure.   The  cost
    estimate developed in the Corrective Measure Study shall  be
    refined  to reflect the  more detailed/accurate  design plans and
    specifications being developed.  The cost estimate shall  include
    both capital and  operation and  maintenance costs.

D.  Project  Schedule

    Respondent shall  develop a Project Schedule for construction and
    implementation of the corrective  measure or measures which
    identifies timing for initiation  and completion of all critical
    path tasks.  Respondent shall specifically identify dates for
    completion of the project and major  interim milestones.   An
    Initial  Project Schedule shall  be submitted simultaneously with
    the Prefinal Design  Document submission and the Final  Project
    Schedule with the Final  Design  Document.

E.  Construction Quality Assurance  Objectives

    Respondent shall  identify and document  the objectives and
    framework for the development of  a construction quality  assurance
    program  including, but  not limited to the following:
    responsibility and authority; personnel  qualifications;  inspection
    activities, sampling requirements;  and documentation.

F.  Health and Safety Plan

    Respondent shall  prepare a facility  Health and Safety Plan to
    address  the activities  to be performed  at the  facility to
    implement the corrective measures.

    1.   Major elements  of  the Health and Safety Plan shall  include:

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                     13
a.  Facility description including availability of resources
    such as roads,  water supply,  electricity and telephone
    service;
b.  Describe the known hazards and evaluate the risks
    associated with the incident  and  with each activity
    conducted;
c.  List key personnel and alternates responsible for site
    safety, response operations,  and  for protection of public
    health;
d.  Delineate work  area;
e.  Describe levels of protection to  be worn by personnel  in
    work area;
f.  Establish procedures to control site access;
g.  Describe decontamination procedures for personnel and
    equipment;
h.  Establish site  emergency procedures;
i.  Address emergency medical  care for injuries and
    toxicological problems;
j.  Describe requirements for an  environmental surveillance
    program;
k.  Specify any routine and special training required for
    responders; and
1.  Establish procedures for protecting workers from weather-
    related problems.
The Facility Health and Safety Plan shall be consistent with:
a.  NIOSH Occupational Safety and Health Guidance Manual  for
    Hazardous Waste Site Activities (1985);
b.  U.S. EPA Order  1440.1 - Respiratory Protection;
c.  U.S. EPA Order  1440.3 - Health and Safety Requirements
    for Employees engaged in Field Activities;
d.  Facility Contingency Plan;
e.  U.S. EPA Standard Operating Safety Guide (1984);
f.  OSHA regulations particularly in  29 CFR 1910 and 1926;

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                              14

         g.   State and  local  regulations; and

         h.   Other U.S.  EPA guidance  as provided.

G.  Design Phases

    The design of the corrective  measures should  include the phases
    outlined below.

    1.   Preliminary design

         The Respondent shall  submit  the preliminary  design  when  the
         design effort  is  approximately 30%  complete.   At this  stage
         the Respondent shall  have  field verified  the existing
         conditions of  the facility.  The preliminary design shall
         reflect a level of effort  such that the  technical
         requirements of the  project  have been  addressed and outlined
         so  that they may  be  reviewed to determine if the final design
         will  provide an operable and usable corrective measure.
         Supporting data and  documentation shall  be provided with the
         design documents  defining  the functional  aspects of the
         program.  The  preliminary  construction drawings by  Respondent
         shall  reflect  organization and clarity.   The scope  of  the
         technical specifications shall be outlined in a manner
         reflecting the final  specifications.   The Respondent shall
         include with the  preliminary submission  design calculations
         reflecting the same  percentage of completion as the design
         they support.

    2.   Intermediate design

         Complex project design may necessitate review of the design
         documents between the preliminary and  the prefinal/final
         design.  At the discretion of the Agency,  a  design  review may
         be  required at 60% completion of the project.  The
         intermediate design  submittal should include the same
         elements as the prefinal design.

    3.   Correlating plans and specifications

         General correlation  between  drawings and  technical
         specifications is a  basic  requirement  of  any set of working
         construction plans and specifications.  Before submitting the
         project specifications the Respondent  shall:

         a.   Coordinate and cross-check the  specifications and
             drawings;  and

         b.   Complete the  proofing  of the edited  specifications and
             required cross-checking  of all  drawings  and
             specifications.

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                          15

     These activities shall  be completed  prior  to  the 95% prefinal
     submittal  to the Agency.

4.   Equipment  start-up and  operator  training

     The Respondent shall  prepare,  and  include  in  the technical
     specifications governing  treatment systems, contractor
     requirements for providing:   appropriate service visits  by
     experienced personnel to  supervise the installation,
     adjustment, start-up  and  operation of  the  treatment systems,
     and training covering appropriate  operational  procedures once
     the start-up has been successfully accomplished.

5.   Additional  studies

     Corrective Measure Implementation  may  require additional
     studies to supplement the available  technical  data.  At  the
     direction  of the Agency for  any  such studies  required, the
     Respondent shall furnish  all  services,  including field work
     as required, materials, supplies,  plant, labor,  equipment,
     investigations, studies and  superintendence.   Sufficient
     sampling,  testing an  analysis  shall  be performed to optimize
     the required treatment  and/or  disposal  operations and
     systems.  There shall be  an  initial  meeting of all  principal
     personnel  involved in the development  of the  program. The
     purpose will be to discuss objectives,  resources,
     communication channels, role of  personnel  involved and
     orientation of the site,  etc.  The interim report shall
     present the results of  the testing with the recommended
     treatment  or disposal system (including options).  A review
     conference shall be scheduled  after  the interim report has
     been reviewed by all  interested  parties.   The final report  of
     the testing shall include all  data taken during the testing
     and a summary of the  results of  the  studies.

6.   Prefinal and final design

     The Respondent shall  submit  the  prefinal/final  design
     documents  in two parts.  The first submission shall be at 95%
     completion of design  (i.e.,  prefinal).  After approval of the
     prefinal submission,  the  Respondent  shall  execute the
     required revisions and  submit  the  final documents 100%
     complete with reproducible drawings  and specifications.

     The prefinal design submittal  shall  consist of the Design
     Plans and  Specifications, Operation  and Maintenance Plan,
     Capital and Operating and Maintenance  Cost Estimate, Project
     Schedule,  Quality Assurance  Plan and Specifications for  the
     Health and Safety Plan.

     The final  design submittal shall consist of the Final Design
     Plans and  Specifications  (100% complete),  the Respondent's

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                                   16

              Final  Construction Cost Estimate, the Final Operation and
              Maintenance  Plan, Final Quality Assurance Plan, Final Project
              Schedule and Final Health and Safety Plan specifications.
              The  quality  of the design documents should be such that the
              Respondent would be able to include them in a bid package and
              invite contractors to submit bids for the construction
              project.

III.   Corrective Measure Construction

      Following  U.S. EPA approval of the final design, the Respondent shall
      develop  and  implement a construction quality assurance  (CQA) program
      to ensure, with a reasonable  degree of certainty, that  a completed
      corrective measure(s) meets or exceeds all design criteria, plans and
      specifications.  The CQA plan is a facility specific document which
      must be  submitted to U.S. EPA for approval prior to the start of
      construction.   At a  minimum,  the CQA plan should include the
      elements,  which are  summarized below.  Upon U.S. EPA approval of the
      CQA plan the Respondent shall construct and implement the corrective
      measures in  accordance with the approved design, schedule and the CQA
      plan.  Respondent shall also  implement the elements of  the approved
      Operation  and Maintenance plan.

      A.   Responsibility  and Authority

           The responsibility and authority of all organizations (i.e.,
           technical consultants, construction firms, etc.) and key
           personnel involved in the construction of the corrective measure
           shall be described fully in the CQA plan.  Respondent must
           identify a CQA  officer and the necessary supporting inspection
           staff.

      B.   Construction Quality Assurance Personnel Qualifications

           The qualifications of the CQA officer and supporting inspection
           personnel shall  be presented in the CQA plan to demonstrate that
           they  possess the training and experience necessary to fulfill
           their identified responsibilities.

      C.   Inspection Activities

           The observations and tests that will be used to monitor the
           construction and/or installation of the components of the
           corrective measure(s) shall be summarized in the CQA plan.  The
           plan  shall include the scope and frequency of each type of
           inspection.  Inspections shall verify compliance with all
           environmental requirements and include, but not be limited to
           air quality and emissions monitoring records, waste disposal
           records (e.g.,  RCRA transportation manifests), etc.  The
           inspection should also ensure compliance with all  health and
           safety  procedures.  In addition to oversight inspections,
           Respondent shall conduct the following activities:

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                        17

1.  Reconstruction inspection and  meeting

    Respondent shall  conduct  a preconstruction  inspection  and
    meeting to:

    a.   Review methods  for documenting  and  reporting  inspection
        data;

    b.   Review methods  for distributing and storing documents
        and reports;

    c.   Review work area security and safety protocol;

    d.   Discuss  any appropriate modifications of  the
        construction quality  assurance  plan to  ensure that
        site-specific considerations are addressed; and

    e.   Conduct  a site  walk-around  to verify that the design
        criteria, plans, and  specifications are understood and
        to review material  and equipment storage  locations.

    The preconstruction inspection  and  meeting  shall  be
    documented by a designated person and minutes should be
    transmitted  to all  parties.

2.  Prefinal inspection

    Upon preliminary project  completion Respondent shall notify
    U.S. EPA for the purposes of conducting an  prefinal
    inspection.   The prefinal  inspection will consist of a
    walk-through inspection of the  entire project site.  The
    inspection is to determine whether  the  project is complete
    and consistent with the contract documents  and the U.S. EPA
    approved corrective measure. Any outstanding construction
    items discovered during the inspection  will be identified
    and noted.  Additionally,  treatment equipment will be
    operationally tested by the Respondent.

    Respondent will certify that the equipment  has performed  to
    meet the purpose and intent of  the  specifications.
    Retesting will be completed where deficiencies are revealed.
    The prefinal inspection report  should outline the
    outstanding  construction  items, actions required  to resolve
    items, completion date for these items, and date  for final
    inspection.

3.  Final inspection

    Upon completion of  any outstanding  construction items,
    Respondent shall  notify U.S. EPA for the purposes of
    conducting a final  inspection.  The final inspection will
    consist of a walk-through inspection of the project site.

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                                  18

              The prefinal Inspection report will be used as a checklist
              with  the final inspection focusing on the outstanding
              construction items identified in the prefinal inspection.
              Confirmation shall be made that outstanding items have been
              resolved.

      D.    Sampling  Requirements

           The sampling activities, sample size, sample locations,
           frequency of testing, acceptance and rejection criteria, and
           plans  for correcting problems as addressed in the project
           specifications  should be presented in the CQA plan.

      E.    Documentation

           Reporting requirements for CQA activities shall be described in
           detail the CQA  plan.  This should include such items as daily
           summary reports, inspection data sheets, problem identification
           and corrective  measures reports, design acceptance reports, and
           final  documentation.  Provisions for the final storage of all
           records also should be presented in the CQA plan.
IV.   Reports
     Respondent shall  prepare  plans,  specifications, and  reports  as  set
     forth in Tasks  I  through  IV  of this attachment to  document the
     design,  construction,  operation, maintenance, and  monitoring of the
     corrective measure.  The  documentation  shall  include,  but not be
     limited  to the  following:

     A.   Progress

         Respondent  shall at a minimum  provide  the U.S. EPA with  signed,
         bimonthly progress reports during the  design and construction
         phases and  quarterly  progress  reports  for operation and
         maintenance activities containing:

         1.    A description and estimate of  the percentage  of the CMI
              completed;

         2.    Summaries of  all findings;

         3.    Summaries of  all changes  made  in  the CMI  during the reporting
              period;

         4.    Summaries of  all contacts with representative of the local
              community, public interest groups or State  government  during
              the  reporting period;

         5.    Summaries of  all problems or potential problems encountered
              during the reporting period;

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                              19

    6.    Actions  being  taken to rectify problems;

    7.    Changes  in  personnel  during the reporting period;

    8.    Projected work for the next reporting period; and

    9.    Copies of daily reports, inspection reports,
         laboratory/monitoring data, etc.
B.  Draft
         Respondent  shall  submit a draft Corrective Measure
         Implementation  Program Plan, etc. as outlined  in Task  I of
         this  attachment;

         Respondent  shall  submit draft Construction Plans and
         Specifications, Design Reports, Cost Estimates, Schedules,
         Operation and Maintenance plans, and Study Reports as
         outlined in Task  II of this attachment;

         Respondent  shall  submit a draft Construction Quality
         Assurance Program Plan and Documentation as outlined in Task
         III of this attachment; and

         At the "completion" of the construction of the project, the
         Respondent  shall  submit a Corrective Measure Implementation
         Report to U.S.  EPA.  The Report shall document that the
         project is  consistent with the design specifications,  and
         that  the corrective measure is performing adequately.  The
         Report shall include, but not be limited to the following
         elements:

         a. Synopsis of the corrective measure and certification of
            the design  and construction;

         b. Explanation of any modifications to the plans and  why
            these were  necessary for the project;

         c. Listing of  the criteria established before the corrective
            measure was initiated, for judging the functioning of the
            corrective measure and also explaining any modification
            to these criteria;

         d. Results of  facility monitoring, indicating that the
            corrective measure will meet or exceed the performance
            criteria; and

         e. Explanation of the operation and maintenance (including
            monitoring) to be undertaken at the facility.

         This  report should include inspection summary  reports,
         inspection  data sheets, problem identification and corrective

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                              20

         measure reports,  block  valuation  reports,  photographic
         reporting data  sheets,  design  engineers' acceptance  reports,
         deviations from design  and material  specifications (with
         justifying documentation) and  as-built drawings.
C.  Final
    Respondent shall  finalize the Corrective Measure Implementation
    Program Plan,  Construction Plans  and  Specifications,  Design
    Reports, Cost  Estimates,  Project  Schedule,  Operation  and
    Maintenance Plan, Study Reports,  Construction  Quality Assurance
    Program Plan/Documentation and the Corrective  Measure
    Implementation Report incorporating comments received on  draft
    submissions.

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Facility Submission Summary

A summary of the information reporting requirements  contained in the
Corrective Measures Implementation Scope of Work is  presented below.
Facility Submission
                            Due Date
Draft Program Plan Community Relations
Plan and Data Collection and Data
Management Plans (Task I)

Final Program Plan Community Relations
Plan, and Data Collection and Data
Management Plant (Task I)

Design Phases
   (Task II A)

   - Preliminary Design (30% completion)
   - Intermediate Design (60% completion)


   - Prefinal  Design (95% completion)


   - Final Design (100% completion)

   (Task II B  through G)


   - Draft Submittals
   - Final Submittals
Additional Studies:
   (Task II F)

Additional Studies:
   (Task II F)
Interim Report


Final  Report
Draft Construction Quality Assurance
  Plan (Task III)

Final Construction Quality Assurance
  Plan (Task III)
                        45 days after submittal
                        of the final  CMS report
                        30 days after receipt of
                        U.S.  EPA comments on these
                        Draft Plans
                        30 days after submittal of
                        Final  Program Plan

                        60 days after approval of
                        Preliminary Design

                        90 day after approval of
                        Intermediate Design

                        14 days after approval of
                        Prefinal Design
Concurrent with Prefinal
Design

Concurrent with Final
Design

(Due date established prior to
Final Design)

30 days after receipt of
U.S. EPA comments on Interim
Report

Prior to construction
                        30 days after U.S. EPA
                        comments on Construction
                        Quality Assurance Plan

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