PB95-964028
EPA/ROD/R04-95/243
February 1996
EPA Superfund
Record of Decision:
Interstate Lead Company (ILCO)
Superfund Site (O.U. 3), Leeds, AL
9/29/1995
-------
RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
FOR
OPERABLE UNIT THREE
INTERSTATE LEAD COMPANY (ILCO) SUPERFUND SITE
it
LEEDS, JEFFERSON COUNTY, ALABAMA
PREPARED BY
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
-------
DECLARATION
of the
RECORD OF DECISION
for
OPERABLE UNIT THREE
SITE NAME AND LOCATION
Interstate Lead Company (ILCO) Super-fund Site
Leeds, Jefferson County, Alabama
STATEMENT OF BASIS AND PURPOSE
This decision document (Record of Decision) presents the selected remedial action for
Operable Unit Three of the ILCO Superfund Site in Leeds, Alabama. The selected
remedial action was chosen in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as amended, and to the
extent practicable, the National Contingency Plan (NCP) 40 CFR Part 300. This decision
is based on the administrative record for the ILCO Superfund Site. The State of
Alabama has concurred with the selected remedy.
ASSESSMENT OF THE SITE
I:
Actual or threatened releases of hazardous substances from the ILCO Site, if not
addressed by implementing the response action selected in this ROD, may present an
imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF SELECTED REMEDY
The ILCO Site is divided into three operable units. Operable unit one (OU-1) was
defined in the Record of Decision that was signed by EPA on September 30,1991 and
amended as part of the Record of Decision for operable unit two (OU-2). OU-1 includes
soil, sediment, and ground-water contamination at the seven satellite sites located in and
around the City of Leeds, excluding groundwater contamination at the ILCO Parking Lot
satellite site. OU-2 was defined in the Record of Decision that was signed by EPA on
October 13,1994. OU-2 includes soil and groundwater contamination at the ILCO Main
Facility, as well as groundwater contamination at the ILCO Parking Lot. Operable unit
three (OU-3), which is enumerated by this Record of Decision, includes surface water,
sediment, and biota contamination attributable to the ILCO Main Facility. The selected
remedy for OU-3 requires response measures which will protect human health and the
environment.
-------
The major components of the selected remedy for OU-3 include:
Natural attenuation (e.g., dilution, flushing, burial, etc.)
of the contaminated sediment
Recommending to the Alabama Department of Public Health (ADPH) that a
fishing advisory be issued for the unnamed tributary and Dry Creek near
the ILCO Main Facility
Posting of warning signs along the unnamed tributary and Dry Creek to
indicate the presence of contaminated sediment and the fish advisory
Annual surface water, sediment, and biota monitoring
Five-year reviews as required by CERCLA to evaluate the effectiveness of
the selected remedy
STATUTORY DETERMINATIONS
The selected remedy for OU-3 is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable or relevant and
appropriate to the remedial action (unless such requirements are waived), and is
cost-effective. EPA has determined that the selected remedy for OU-3 represents the
extent to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner at OU-3. The statutory/preference for remedies that
utilize permanent and treatment technologies solutions is/jnot satisfied at OU-3. EPA
has concluded that remedies which utilize permanent solutions and treatment
technologies are impracticable and not cost-effective at OU-3 based on the results of the
baseline risk assessment conducted for OU-3. The selected remedy for OU-3 represents
the best balance of the nine criteria used by EPA to evaluate possible cleanup
alternatives. A review will be conducted within five years from commencement of the
remedial action to ensure that the remedy continues to provide adequate protection of
human health and the environment.
\
RICHARD D. GREEN, ASSOCIATE DIRECTOR OF DATE
SUPERFUND AND EMERGENCY RESPONSE
-------
TABLE OF CONTENTS
RECORD OF DECISION FOR OPERABLE UNIT THREE
ILCO SUPERFUND SITE
1.0 SITE LOCATION AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
4.0 SCOPE AND ROLE OF OPERABLE UNITS 6
5.0 SUMMARY OF SITE CHARACTERISTICS 7
5.1. Landfonns 7
5.2 Surface Water 7
t
5.3 Geology 7
5.3.1 Regional Geology 7
5.3.2 Site-Specific Geology and Soils 8
i;
5.4 Ground Water I 8
5.4.1 Regional Hydrogeology 8
5.4.2 Site Hydrogeology 9
6.0 SUMMARY OF SITE RISKS 9
6.1 SELECTION OF CHEMICALS OF POTENTIAL CONCERN 9
6.2 HUMAN TOXICITY ASSESSMENT : '. 12
6.3 HUMAN EXPOSURE ASSESSMENT 12
6.4 HUMAN RISK CHARACTERIZATION 12
6.5 RISK-BASED REMEDIATION GOALS 17
6.6 ENVIRONMENTAL RISK. 18
7.0 DESCRIPTION OF ALTERNATIVES 18
-------
8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 21
9.0 SUMMARY OF SELECTED REMEDY FOR OU-3 26
10.0 STATUTORY DETERMINATION 28
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 29
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs) 29
10.3 COST EFFECTIVENESS 30
10.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM
EXTENT PRACTICABLE 30
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT 30
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES 31
APPENDDC A: RESPONSP7ENESS SUMMARY* 32
APPENDDC B: STATE CONCURRENCE LETTER 37
-------
LIST OF FIGURES
RECORD OF DECISION FOR OPERABLE UNIT THREE
ILCO SUPERFUND SITE
FIGURE 1-1, SITE LOCATION MAP 2
FIGURE 1-2, SITE LAYOUT 3
-------
LIST OF TABLES
RECORD OF DECISION FOR OPERABLE UNIT THREE
ILCO SUPERFUND SITE
TABLE 6-1: CHEMICALS OF POTENTIAL CONCERN FOR SEDIMENT 10
TABLE 6-2: CHEMICALS OF POTENTIAL CONCERN FOR SURFACE WATER 11
TABLE 6-3: SUMMARY OF SCREENING LEVEL CONCENTRATIONS FOR LEAD 13
TABLE 6-4: SUMMARY OF CONCLUSIONS REGARDING LEAD 15
TABLE 6-5: SUMMARY OF QUANTITATIVE RISK ESTIMATES FOR POTENTIALLY
COMPLETE HUMAN EXPOSURE PATHWAYS UNDER CURRENT LAND-USE
CONDITIONS 16
TABLE 6-6: SUMMARY OF QUANTITATIVE RISK ESTIMATES FOR ADDITIONAL
POTENTIALLY COMPLETE HUMAN EXPOSURE PATHWAYS UNDER FUTURE LAND-
USE CONDITIONS 17
TABLE 8-1, SUMMARY OF PRESENT-WORTH COSTS FOR/SEDIMENT CLEANUP
ALTERNATIVES ij 25
-------
Decision Summary
for the
Record of Decision
for
Operable Unit Three
Interstate Lead Company (ILCO) Site
Leeds, Alabama
1.0 SITE LOCATION AND DESCRIPTION
The Interstate Lead Company (ILCO) Superfund Site is located approximately 15 miles
east of Birmingham, in Leeds, Jefferson County, Alabama (see Figure 1-1, Site Location
Map). The ILCO Site consists of the ILCO Main Facility and seven satellite sites located
hi and around the City of Leeds, where lead-contaminated wastes from the ILCO Main
Facility were disposed.
The ILCO Main Facility is located at 1247 Borden Avenue on the southwestern side of
the City of Leeds. The ILCO Main Facility (including the ILCO Parking Lot across the
street) occupies approximately 11.5 acres of real property, most of which is owned by
ILCO with a portion owned by Interstate Trucking Company, Inc., an affiliated company.
The ILCO Main Facility is bordered by an abandoned foundry and a wooded area to the
south, an unnamed tributary to Dry Creek to the west, Borden Avenue and the ILCO
Parking Lot to the north, and another business to the east* j(see Figure 1-2, Site Layout).
The area is primarily industrial with a few residences within a half-mile radius.
The satellite sites include the ILCQ Parking Lot, located across the street from the ILCO
Main Facility; the GulfTBP Service Station, located in the center of Leeds on U.S.
Highway 78; J&L Fabricators, located east of Leeds on U.S. Highway 78; Fleming's
Patio, located west of Leeds on Alaska Avenue; the Connell Property, located east of
Leeds in St. Clair County; the Acmar Church of
-------
FIGURE 1-1, SITE LOCATION MAP
-------
p
EPA
APPROXIMATE SCALE1
?00 400
MONTGOMERY OIL
PARKING LOT-s-
.'
PS.
CD J MAIN FACILITY
,.....\. i
WT£f£1 .r I \
CALDWELL FOUNDRY
AND MACHINERY
FIGURE 1-2
, SITE LAYOUT
ILCO SUPERFUND SITE
LEEDS, ALABAMA
-------
ILCO stored furnace slag, battery chips, and wastewater treatment sludge in piles on the
ILCO Main Facility. Furnace slag generated by ILCO was used as fill material at the
ILCO Main Facility and at the satellite sites. Wastewater treatment sludge and battery
casings were also disposed of at the ILCO Main Facility and at some of the satellite
sites.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
In May 1984, EPA and the Alabama Department of Environmental Management
(ADEM) conducted a joint inspection of the ILCO Main Facility, which was found to be
in violation of the interim status standards set forth in RCRA
--- - . . __»_.... ,_,
In March 1985, the United States brought suit against ILCO and its principal, Diego
Maffei, seeking injunctive relief, penalties, and damages for violations of the Clean
Water Act and RCRA. The government also sought to recover response costs pursuant to
CERCLA for a removal action taken by EPA at the Acmar Church of God satellite site.
The complaint also included a count for corrective action at the ILCO Main Facility. The
case was brought in the United States District Court for the Northern District of
Alabama (District Court Case). The State of Alabama intervened in the litigation
asserting violations of Alabama's Water Pollution Control Act and Hazardous Waste
Management and Minimization Act.
There was a partial settlement of the District Court Case in August 1988. A partial
consent decree was entered requiring ILCO to conduct all necessary corrective actions
and remediation of contaminated sediment in the surrounding waterways.
II
The outstanding issues were tried in July and August 1988. On December 10, 1990, the
district court issued an Order and Findings of Fact and Conclusions of Law holding that
the defendants had violated the Clean Water Act and RCRA and that injunctive relief
and penalties were appropriate. The court also found that the defendants were liable for
all response costs incurred by the United States in connection with the removal action at
the Acmar Church of God satellite site.
In its December 10, 1990 Order, the district court did not enter a judgment but ordered
the parties to endeavor to reach an agreement as to the relief which should be provided.
The parties were unable to come to such an agreement, and each submitted a proposed
fip«1 judgment. On October 8,1991, the court entered a judgment. The district court
granted injunctive relief and assessed a penalty of two million dollars against ILCO, in
favor of the United States, for violations of RCRA and the Clean Water Act. In addition,
the district court entered judgment in favor of the United States against ILCO and Diego
Maffei, in the amount of $845,033.40, as reimbursement for response costs for the
removal action at the Acmar Church of God satellite site. The district court also
awarded a penalty in the amount of $1.5 million in favor of the State of Alabama.
On appeal, the Eleventh Circuit Court issued a decision in favor of the United States
-------
and the State of Alabama on every issue and affirmed the district court's award of civil
penalties and response costs.
In June 1986, the ILCO Site (including the ILCO Main Facility and the seven satellite
sites) was placed on the National Priorities List (NPL) of uncontrolled hazardous waste
sites.
EPA conducted a Remedial Investigation/Feasibility Study (RI/FS) of the satellite sites
(Operable Unit One) which was completed in July 1991. A proposed plan was issued
shortly after completion of the RI/FS. After a public comment period, a Record of
Decision (ROD) was signed on September 30, 1991, which set forth the selected remedy
for Operable Unit One. -
When ILCO ceased operations in March 1992, EPA initiated a removal action to mitigate
the imminent threat associated with the abandoned ILCO Main Facility. During the
removal action at the ILCO Main Facility, approximately 5,368 tons of lead
contaminated slag, found stored in different areas around the facility, were removed to a
permitted hazardous waste landfill. Approximately 200,000 gallons of lead contaminated
sludge found in the onsite wastewater treatment system was removed, stabilized, and
stockpiled onsite with contaminated soils excavated from the facility. Acid from several
impoundments was collected and treated in the onsite wastewater treatment system, in
addition to approximately 15,000,000 gallons of wastewater. The battery cracking
building, the furnace building, and the small slag vault were demolished and
decontaminated due to extensive lead contamination. The contents of the small slag
vault were removed and stockpiled onsite with the contaminated soils. Waste
encountered during the demolition of the furnace building/included lead waste, baghouse
dust, and a sulfur residue from the emissions system. The lead waste was stockpiled
inside a building onsite. The baghouse dust was placed into two roll-off boxes, covered,
labeled K069, and also stored inside a building onsite. The sulfur residue found inside
the duct pipe was placed on the contaminated soil stockpile. During the demolition of
the battery cracking building, process soils from the battery cracking operation were
removed and stockpiled inside a building onsite. The process soils consisted of a mixture
of battery chips and contaminated soils.
EPA conducted a RI/FS of the ILCO Main Facility (Operable Unit Two), which was
completed in June 1994. A proposed plan was issued shortly after completion of the
RI/FS. After a public comment period, a Record of Decision (ROD) was signed on
October 13, 1995, which set forth the selected remedy for Operable Unit Two. The ROD
for Operable Unit One was also amended as part of the ROD for Operable Unit Two.
The third and final operable unit consists of -surface water, sediment, and biota
contamination attributable to the ILCO Main Facility. EPA also conducted a RI/FS for
Operable Unit Three which was completed in April 1995. The proposed plan setting
forth EPA's preferred cleanup alternative was issued in July 1995.
-------
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Leeds Public Library at 802 Parkway Drive, S.E. in Leeds, Alabama is the local
information repository for the ILCO Site. The proposed plan for Operable Unit Three
was issued in July 1995 and a public comment period was established from July 25, 1995
to August 24, 1995. A public meeting on the proposed plan was held on August 17, 1995
at the Leeds Civic Center in Leeds, Alabama.
The administrative record for the ILCO Site is available to the public at both the
information repository maintained at the Leeds Public Library and at the EPA Region IV
Library at 345 Courtland Street in Atlanta, Georgia. The notice of availability for the
proposed plan for Operable Unit Three was published in The Birmingham News on July
24, 1995 and August 10, 1995 and in The Leeds News on July 27, 1995 and August 13,
1995. Responses to the significant comments received during the public comment period
are included in the Responsiveness Summary, which is part of this ROD and designated
Appendix A.
This decision document presents the selected remedial action for Operable Unit Three of
the ILCO Site, chosen in accordance with CERCLA, as amended, and to the extent
practicable, the NCP. The decision for Operable Unit Three is based on the
administrative record. The requirements under Section 117 of CERCLA/SARA for public
and State participation have been met for this operable unit.
4.0 SCOPE AND ROLE OF OPERABLE UNITS
n
The problems at the ILCO Site are complex. As a result, EPA has divided the work into
three manageable components called "operable units" in order to simplify remedial
planning and response activities associated with the disposal and discharge of hazardous
substances from the Site.
Operable Unit One (OU-1): Contaminated soil, groundwater, and sediment at the
seven satellite sites are addressed in OU-1, excluding groundwater at the ILCO
Parking Lot satellite site. Groundwater contamination at the ILCO Parking Lot is
addressed in Operable Unit Two.
Operable Unit Two (OU-2): Contaminated soil at the ILCO Main Facility and
contaminated groundwater at the ILCO Main Facility and the ILCO Parking Lot
are addressed in OU-2.
Operable Unit Three (QU-3): Contaminated surface water, sediment, and biota in
the unnamed tributary, Dry Creek, and the Little Cahaba River attributable to the
ILCO Main facility are addressed in OU-3.
6.
-------
This ROD is for OU-3 of the ILCO Site and documents the selected remedy for
contaminated surface water, sediment, and biota attributable to the ILCO Main Facility.
Based on the results and recommendations of a biological assessment performed by EPA
at the ILCO Site, EPA separated the unnamed tributary, Dry Creek, and the Little
Cahaba River into a separate operable unit (OU-3) for further investigation of the
surface water, sediment, and biota. This additional investigation began in July 1994 and
was completed in April 1995.
6.0 SUMMARY OF SITE CHARACTERISTICS
5.1. Landforms
The ILCO Site is located in the Appalachian Valley and Ridge Physiographic Province,
within the Cahaba Valley. The area is characterized by series of linear, sub-parallel
ridges, developed on the underlying structurally deformed rock sequences, and separated
by valleys of varying widths. Topographic relief in the area is moderate to high, with
rapid changes of several hundred feet common.
5.2 Surface Water
c
Three significant surface water bodies are present in the Leeds area. These are the
Cahaba River, located to the north of the City of Leeds; the Little Cahaba River, which
runs through Leeds; and Dry Creek, a stream that runs near the ILCO Main Facility
and ILCO Parking Lot and flows into the Little Cahaba River in the vicinity of the Leeds
wastewater treatment plant. The general orientation of the major streams and rivers is
parallel to the major topographic structures. I1
A smaller surface water body, identified as the unnamed tributary to Dry Creek, flows
north, generally along the western boundary of the ILCO Main Facility, crosses under
Borden Avenue, and ultimately drains into Dry Creek. The unnamed tributary has in
the past received run-off water from the ILCO Main Facility that was highly
contaminated with lead. Even though ILCO conducted a soil and sediment removal from
the unnamed tributary in August 1990, some of the sediment in the stream immediately
downgradient of the ILCO Main Facility still contains elevated levels of lead.
5.3 Geology
5.3.1 Regional Geology
The suite of rocks in the Cahaba Valley is typical of the Valley and Ridge and consists of
sandstones and shales, commonly interbedded, as well as limestone and dofomitic
limestone. The regional structure is typically characterized by northeast-southwest
trending layers of rock, which are locally steeply inclined and frequently folded and
-------
faulted. The larger structures generally dip to the southeast at angles up to 45 degrees
and are intensely fractured and jointed.
5.3.2 Site-Specific Geology and Soils
The ILCO Main Facility is underlain by a veneer of unconsolidated material, consisting
of weathered light-brown to dark-gray, sandy, silty, clayey alluvium that generally
ranges from 5 to 20 feet thick. The Floyd Shale lies directly beneath the alluvium along
the southeast border of the property; the contact between the Floyd Shale and the
Hartselle Sandstone is in the same area. The Hartselle Sandstone is overlain by
alluvium in the southeastern portion of the property and in the area previously occupied
by the battery cracking building. The remainder of the ILCO Main Facility is underlain
by the Pride Mountain Formation, which extends to the northwest in the vicinity of Dry
Creek.
5.4 Ground water
5.4.1 Regional Hydrogeology
Generally, groundwater is available, in some quantity, in four different horizons or
formations in the Leeds area. These zones are not necessarily, in themselves, major
regional aquifers, but rather represent hydrogeological conditions or situations in which
a completed well may produce water more significantly than in others, such as massive
shale formations, etc. The more shallow zones are usually unconfined, with the lower
units sometimes occurring under confined conditions, depending on the geology of the
overlying material. Because of the degree of fracturing observed in the area, it is
conceivable that all zones may, to a certain extent, be interconnected in some areas.
These zones include the following:
Surficial Aquifer - Consists of a thin layer of unconsolidated alluvial deposits that
covers most of the valley. The maximum thickness is 20 feet. It is separated from
the shallow aquifer system by a silty clay at some locations and is a very poor
source of water to wells. Water occurs under unconfined conditions.
Shallow Aquifer - Consists of weathered to consolidated material in the upper part
of the bedrock and is generally no more than 30 feet thick. It is separated from
the underlying rock in some areas by a dense, dark-gray clay and is a very limited
source of water to wells. Water occurs under unconfined conditions.
Fort Pavne Chert Aquifer - Provides some of the water supply to the City of
Leeds. City wells are installed to depths of 150-300 feet and located approximately
one-half mile to the northeast of the ILCO Main Facility and the ILCO Parking
Lot. The Fort Payne Chert Aquifer behaves similarly to a confined aquifer because
of the lower permeability of the overlying formations. However, these lower
8
-------
permeability formations do not prevent the movement of contaminants into the
Fort Payne Chert Aquifer.
Ordovician UndifFerentiated Aquifer - Consists of 1,000 feet of crystalline
limestone. Two springs in this formation provide part of the water supply to the
City of Leeds. The Weems Spring is located off Cemetery Road approximately 5
miles southeast of the Acmar Church of God satellite site in Moody, Alabama,
north of Leeds. The Rowan Spring is located in Leeds at the intersection of
Highway 119 and President Road.
5.4.2 Site Hydrogeology
Groundwater at the ILCO Main Facility occurs in the unconsolidated alluvium and
underlying weathered zone of shales and generally occurs in unconfined conditions in the
area. Water levels range from four feet to almost 50 feet below land surface. At the
ILCO Main Facility, groundwater tends to flow toward Dry Creek and the unnamed
tributary to the north and northwest of the area with infiltration into the underlying
weathered shallow aquifer, which is in the Floyd Shale, the Hartselle Sandstone, and the
Pride Mountain Formation. Data and information from groundwater monitoring wells
indicate that water-bearing zones occur in joints and fractures deep in the shales under
partially confined conditions.
6.0 SUMMARY OF SITE RISKS
ILCO's battery cracking and recycling operations have resulted in extensive lead
contamination on and near the ILCO Main Facility. As stated previously, OU-3
specifically addresses the contamination in surface water, sediment, and biota in the
streams located adjacent to and downstream of the ILCO Main Facility. EPA collected
surface water, sediment, and biota samples during 1994 from the unnamed tributary,
Dry Creek, and the Little Cahaba River and analyzed them for lead and other chemicals.
In order to examine the potential risks associated with OU-3, EPA used the analytical
results of the surface water, sediment, and biota samples to perform a Baseline Risk
Assessment (BRA) on OU-3. The BRA evaluated the risk to human health and the
environment which would result if no action was taken to address the contamination
associated with OU-3.
f
6.1 Selection of Chemicals of Potential Concern
The first task of the BRA was to summarize the data collected for surface water,
sediment and fish tissue used in the OU-3 assessment. The available data for these
media include surface water and sediment data-collected in July and December 1993 for
the OU-2 RI, and surface water, sediment, and fish tissue data collected in March and
July 1994 during the OU-3 Ecological Assessment. From these data, chemicals of
potential concern were selected for detailed evaluation in the BRA, It is important to
-------
recognize that the selection of a chemical of potential concern does not necessarily
indicate that it poses a risk to human health or the environment. The selection of a
chemical only indicates that a decision has been made to evaluate that chemical in the
risk assessment to determine if the chemical could result in potential risks.
The chemicals selected as chemicals of potential concern in sediment and carried
through 'the human health risk assessment are listed in Table 6-1. The selection of
chemicals of potential concern for sediment was based on a comparison to concentrations
in the background samples and identification of essential human nutrients. Chemicals
whose wiMTimiim concentrations were less than twice the background value were
eliminated from further evaluation, ha addition, chemicals that are essential human
TABLE 6-1, SUMMARY OF INORGANIC CHEMICALS DETECTED IN SEDIMENT
(Concentrations presented in ppm)
Chemical
Frequency of
Detection
Mean
Sample
Size
Arithmetic
Mean
Range of
Detection Limits
Range of Detected
Concentrations
Background
Comparison
Values
In the Vicinity of
the ItCtf'Site
AUaurua 17/17 17 4,850
Antimony 2/21 21 4.94
Arsenic 21 / 21 21 11.6
tariwi 17/17 17 43.5
eryUitn 13 / 17 17 0.48
Cadmiua 12 / 17 17 3.2
m Calciua 16 / 17 17 5.530
Chromiua 17 / 17 17 20.5
Cobalt 17 / 17 17 8.99
« Copper 21 / 21 21 19
Iron 17 / 17 17 15.300
Xead 21 / 21 21 1.010
N Magnesium 17/17 17 1.920
Manganese 17 / 17 17 422
Mercury 2/21 21 0.06E
Nickel 21/21 . 21 19.9
N Potassium 17 / 17 17 521
Selenium 12 / 17., 17 1.42
Vanadium 12 / 17 17 15.6
Zinc 21/21 21 85.6
Downstream from the
ILCO Site
KU
3.5 - 20
NU
KU
1
0.34 - 0.48
210
NU
NU
HU
KU
' NU
NU
NU
0.05 - 0.2
NU
NU
1 -
NU
2
20
2.800
15
4.8
12
! 0.33
0.68
1.400
9.4
1.7
6.4
8.300
65
200
30
0.09
6.5
330
0.99
14
37
8.600
26
26
120
0.89
12
26.000
52
21
48
23.000
5.400
12,000
1.700
0.25
38
1.200
2.5
27
190
9.600
NO (4.0)
19
81
1.3
NO (0.38)
7.000
68
93
29.2
55.000
85.8
2.130
1.660
HO (0.065)
51
830
4
36
180
Arsenic
Copper
* Lead
Mercury
Nickel
. Zinc
4 /
4 /
4 /
3 /
A /
4 /
4 .
4
4
4
4
4
4
4
4
4
4
4
14
14
157
0.086
20.5
70.8
NU
NU
NU
0.05
NU
NU
10 -
8.4 -
46 -
0.05 -
18
60
17
18
260
0.14
24
81
32
38
70
0.17
30
164
«-Selected as a chemical of potential concern.
NU Not used; chemical was detected in all samples.
HO « Not detected; detection limit shown in parentheses.
N Chemical was not selected as a chemical of potential concern, because it is an essential hunan nutrient.
10
-------
nutrients, such as calcium, magnesium, and potassium, were also eliminated from the
list of chemicals of potential concern. Based on recommended dietary allowances and on
the concentrations that were detected in sediment, these nutrients do not have adequate
tozicity criteria to evaluate risks quantitatively and are unlikely to adversely affect
humans.
The chemicals selected as chemicals of potential concern in surface water and carried
through the human health risk assessment are also listed in Table 6-2. As for sediment,
the selection of chemicals of potential concern for surface water was also based on a
comparison to background data and identification of essential human nutrients.
Lead was the only chemical of potential concern that was considered for fish tissue.
Lead was selected as a chemical of potential concern in filet fish from Dry Creek and the
Little Cahaba Elver. Lead was also selected as a chemical of potential concern in the
forage (whole-body) fish caught in the unnamed tributary, Dry Creek, and the Little
Cahaba River.
TABLE 6-2
SUMMARY OF INORGANIC CHEMICALS DETECTED IN SURFACE
tc
(Concentrations presented in ug/L except where noted)
Chemical
frequency of
Detection
Mean
Sample
Size
Arithmetic
Mean
Range of
Detection
Range of Detected
Concent rat i ons
Background
Comparison
Values
In the Vicinity of
the 1LOO Site
-------
6.2 Human Toxicity Assessment
The next step of the BRA, the human toxicity assessment, was performed in order to
identify numerical toxicity criteria with which to assess human health exposures. For
lead, no surface water or sediment screening levels exist, thus EPA screening levels for
soil and groundwater were identified and presented as surrogate values. In addition, no
EPA-approved screening levels were available for lead in fish, therefore, lead screening
values found in other sources (i.e., Eisler [1988] report) were presented. The health
effects information available for lead and the criteria that were used to assess potential
adverse effects associated with lead exposures at OU-3 are summarized hi Table 6-3.
6.3 Human Exposure Assessment
A human exposure assessment was then performed to determine which human exposure
pathways could potentially be complete at OU-3 under current and future land use
conditions. Currently the Site is not operating; therefore, only exposures to nearby
residents were evaluated in the current land use scenario.
Under future land use conditions, it was assumed that the area around the Site could
become residential in the future. For each complete exposure pathway, the chemical
concentrations assumed to be contacted (i.e., the exposure point concentrations) were
derived in the human exposure assessment. These values were either the 95% upper
confidence limit on the arithmetic mean concentration or the ma-gimmn detected
concentration, whichever was less. The exposure point concentrations for lead were used
in a direct comparison to the lead criteria identified in the/toxicity assessment, and, for
fish, were input into the EEUBK model. The exposure point concentrations for other
chemicals of potential concern were combined with reasonable maximum estimates of the
extent, frequency, and duration of exposure in order to calculate chemical doses.
For chemicals of potential concern other than lead, quantitative dose-response data were
compiled from EPA's Integrated Risk Information System (IRIS), Health Effects
Assessment Summary Tables (HEASTs), and the Environmental Criteria and
Assessment Office (ECAO).
6.4 Human Risk Characterization
Using the human exposure and toxicity information, potential human health risks for
each chemical of potential concern, except lead, and selected exposure pathway were
evaluated. For lead, the potential for human health risks was assessed by comparing
lead exposure point concentrations to the most applicable EPA screening criteria. In
addition, the lead concentrations offish caught in the streams near the ILCO Site were
input into the IEUBK lead model to determine the percentage of a child's diet that could
be fish (caught in the unnamed tributary or in Dry Creek immediately downstream of
the ILCO Main Facility) without resulting in adverse health affects to the child.
12
-------
Table 6-3
Summary of Screening Level Concentrations for Lead
Exposure
Medium
Screening Level
Health Criteria
Source
SEDIMENT
400 ppm A USEPA (1994e) residential screening
level for soil was used to indicate
whether lead concentrations in
sediment could cause adverse health
effects. This concentration is based
on expected responses to background
lead exposures input into USEPA's
integrated exposure uptake/biokinetic
(IEUBK) model.
SURFACE
WATER
15 ppb The groundwater drinking water
maximum contaminant level (MCL)
of 15 ppb (USEPA 1990b) was used
' for comparison purposes only.
FISH
0.3 ppm The screening criteria for protection of
human health associated with
ingestion of fishery products was
obtained froqi an Eisler (1988)
report Although not stated
specifically in the Eisler (1988)
report, this value is most likely based
on the World Health Organization's
(1972) maximum safe level (0.3 ppm)
in fish tissue for human
consumption.
For comparative purposes, daily doses have been calculated for consumption of the
sediment, surface water, and fish at the lead screening levels listed above. For
sediment, the lead screening level of 400 ppm was multiplied by a child soil
ingestion rate of 200 mg/day resulting in a daily dose of lead of 0.08 mg Pb/day.
For surface water, the drinking water MCL for lead of 15 ppm was multiplied by a
daily water ingestion rate of 2 L/day resulting in a daily dose of 0.03 mg Pb/day.
For fish, a conservative ingestion assumption (i.e., an intake rate of 100 grams of
fish per day) was multiplied by the 0.3 ppm safe level for fish, resulting in a daily
dose of 0.03 mg Pb/day.
13
-------
For OU-3, EPA developed screening level concentrations for lead in sediment, surface water,
and fish. Since no human health based cleanup level has been developed for lead in
sediment, a screening level of 400 parts per million (ppm) was selected for lead in sediment
based on EPA's residential screening level for soil. This screening level was used to indicate
whether lead concentrations in sediment could cause adverse health effects to humans.
Based on the soil criteria, concentrations of lead in sediment from the unnamed tributary
and Dry Creek in the immediate vicinity of the ILCO Main Facility could potentially result
in a risk to human health if no action were taken to reduce the potential risk. Based on the
soil criteria, concentrations of lead in sediment in the Little Cahaba River and Dry Creek
further downstream from the ILCO Main Facility are unlikely to result in a risk to human
health or the environment.
Since no screening criteria or cleanup levels have been developed for lead in surface water,
a screening level of 15 micrograms per liter (ug/L) was selected. This screening level was
selected for comparison purposes only, based on the maximum contaminant level (MCL) of
15 ug/L for lead in drinking water. The lead concentrations in surface water in the
immediate vicinity of the ILCO Main Facility exceeded the screening level; however, the
screening level is based on drinking water exposures and water from the surface water
bodies in OU-3 is not used for drinking water. Exposures to surface water in the immediate
vicinity of the ILCO Main Facility are likely to include dermal (skin) contact exposures only
and lead is poorly absorbed through the skin. Therefore, skin contact exposures to lead hi
surface water are not likely to cause adverse health effects to humans. As a result,
concentrations of lead in surface water from all OU-3 streams are not likely to result in a
risk to human health or the environment.
i'
4 *
As with surface water and sediment, no EPA-approved screening levels have been developed
for lead in fish. Therefore, a screening level of 0.3 ppm was selected for fish, based on a
U.S. Fish and Wildlife Service health-protective concentration of 0.3 ppm. The lead
concentrations in all forage (whole-body) fish caught in the OU-3 streams exceeded the
screening level for lead in fish. However, only the fish caught near the ILCO Main Facility
exceeded the screening level for lead in filet fish. Since the screening level for lead was
exceeded in some of the sampled fish, EPA used the IEUBK lead model to assess the
potential risk to children from only ingesting fish from OU-3 of the ILCO site. Lead
concentrations in other exposure media to which the same child would be exposed were
assumed to be at average background concentrations (IEUBK model default values) in order
to determine the risks from only ingesting the lead-contaminated fish; lead in soil and
groundwater at the ILCO site is known, from previous studies of other operable units at the
ILCO site, to be at unacceptable levels and remediation is planned for these media. The
IEUBK model was used to backcalculate the maximum amount offish from OU-3 that could
be consumed by a child without adverse health effects to the child. The IEUBK lead model
showed that between 1.3% to 28% of a child's meat diet could be. fish (caught in the
unnamed tributary or in Dry Creek immediately downstream of the ILCO Main Facility)
without resulting in a risk to the child. At the Trm-rimnm lead concentrations detected in
fish, the risk assessment determined that 1.3% (forage fish) and 10% (filet fish) of a child's
14
-------
meat diet could be fish (caught in the unnamed tributary or in Dry Creek immediately
downstream of the ILCO Main Facility) without resulting in a risk to the child. At the
average lead concentrations detected in fish, the risk assessment determined that 3.8%
(forage fish) and 28% (filet fish) of a child's meat diet could be fish (caught in the unnamed
tributary or in Dry Creek immediately downstream of the ILCO Main Facility) without
resulting in a risk to the child. It should be noted that this is a very conservative analysis,
since the risk assessment results are based on the protection of the most sensitive receptors
(i.e., young children from 0.5 to 7 years old). This analysis focused on children rather than
adults since children are known to be much more sensitive to the effects of lead than adults.
The percentages determined in this analysis are also protective of adults consuming fish
from the ILCO OU-3 streams. In addition, the concentrations of lead in filet fish caught in
the Little Cahaba River and Dry Creek further downstream from the ILCO Main Facility
were below 0.3 ppm and,, therefore, do not pose a human health risk. The conclusions
drawn from these comparisons are summarized in Table 6-4.
Table 6-4
Summary of Conclusions Regarding Lead
SEDIMENT Based on the soil criteria, concentrations of lead in sediment
from the Unnamed Tributary and Dry Creek in the
immediate vicinity of the ILCO Main Facility could contrib-
ute to or result in an unacceptable risk. Concentrations of
lead in sediment from the'Little Cahaba River and Dry
Creek further downstream of the ILCO Main Facility are
unlikely to contribute to or result in an unacceptable risk.
SURFACE WATER Concentrations of lead in surface water are unlikely to signifi-
cantly contribute to or result in an unacceptable risk.
FISH The lead concentrations in all forage fish caught in the OU-3
streams and only in filet fish caught near the ILCO Main
Facility exceeded the screening level for lead in fish. The
concentrations of lead in filet fish caught in the Little
Cahaba River and Dry Creek further downstream of the
ILCO Main Facility were less than the screening level. The
results of the ffiUBKlead model showed that between 1.3%
to 28% (depending on the fish lead concentrations used in
the model) of a child's meat diet could be fish (caught in the
unnamed tributary or in Dry . Creek immediately
downstream of the ILCO Main Facility) without resulting in
a risk to the child.
15
-------
For the chemicals of potential concern other than lead, upper-bound excess lifetime cancer
risks for carcinogenic chemicals and hazard quotient and hazard index values for
noncarcinogenic chemicals were estimated. The upper-bound excess lifetime cancer risks
were compared to USEPA's risk range for health protectiveness at Super-fund Sites of IxlO"6
to IxlO"4. This range is representative of risks that must be considered in the selection of
remedial alternatives. The noncarcinogenic hazard quotients and hazard indices were
compared to a value of one, since hazard quotients/indices greater than one indicate a
potential for adverse health effects. Tables 6-5 and 6-6 present risk estimates for human
exposure pathways quantitatively evaluated under current and future land use conditions,
respectively.
Table 6-5
Summary of Quantitative Risk Estimates for Potentially Complete
Human Exposure Pathways Under
Current Land IJse Conditions
[Nearby Teenage Trespasser]
Exposure Medium
Exposure Point
Receptor
Exposure
Route
Upper Predomi- THfza«1 Predomi-
rSouna nant index tor nant
Excess Chemical ;Noncar; Chemicals
Lifetime si> cinogemc «
Cancer Effects0
Sediment:
In the Vicinity of
the ILCO Site:
Incidental
Dermal contact
Downstream from
the ILCO Site:
Incidental
Dermal contact
Surface Water:
In the vicinity of
the ILCO Site:
Dermal contact
8xlO'7
SxlO"8
NC
NO
NC
3xlO'2
IxlO-2
2X10-4
2X10"4
IxlO-1
16
-------
Table 6-6
Summary of Quantitative Risk Estimates for Additional Potentially
Complete Human Exposure Pathways
Under Future LanoTUse Conditions
[Child Resident]
Exposure Medium Upper Predomi- Hazard
Exposure Point Bound n^t Index for Predominant
Receptor Excess Chemicals Non- Chemicals'1
Exposure Lifetime b carcino-
Ttfmte finrifwr ; _ <*nif. _
Sediment:
In the vicinity of
the ILCO Site:
Incidental 8x10"* Arsenic 2x10"*
ingestion
Dermal contact IxlO"7 - 3xlO"2
Surface Water:
In the vicinity of
the ILCO Site:
Dermal contact NC - 4xl(T
The upper bound individual excess lifetime cancer risk represent* the probability, over background risks, than an individual may
develop cancer over a 70-year lifetime as a result of the exposure conditioni evaluated.
The predominant chemicals are those which were associated with cancer rules greater than 1x10"*.
The hazard index indicates whether or not exposure to mixtures of noocaicinogeaic chemicals may remit in adverse health effects. A
hazard index less- th'i* one indicates that advene human f**yT*K effects are unlikely to occur. A hazard index greater than one
indicates that adverse human health effect! may potentially, but not necessarily, occur.
The predominant chemicals are those which were associated with hazard quotients greater than 1.
*/
NC = Not f.Vni«t»«i Carcinogenic tenacity values were not available for any chemicalsA-of potential concern in mis medium.
6.5 Risk-Based Remediation Goals
The risk assessment also included risk-based remediation goals for the chemicals and
pathways evaluated in the human health risk assessment that were associated with upper-
bound excess lifetime cancer risks greater than IxlO'6 or for which hazard indices were
greater than one. These goals incorporate the exposure scenarios and.exposure assumptions
that were developed in the human health risk assessment.
As shown in the Tables 6-5 and 6-6, the only chemical associated with cancer risks greater
than IxlO"6 was arsenic (for which a risk of 8xlO'6 [slightly greater than the lower end of the
risk range] was calculated for incidental ingestion of sediment by a hypothetical future child
resident). No hazard indices were greater than one. As a result, the only risk-based
remediation goal that was developed in the risk assessment was for a future child's
incidental ingestion of arsenic. The risk-based remediation goal was developed using a
target risk level of IxlO"6, an EPA benchmark. Based on the conservative toxitity criteria,
exposure assumptions, and risk methodologies used for developing the risk-based
remediation goal for arsenic, the goal was calculated to be 1.87 ppm.
17
-------
The remediation goal should also be compared to Site-specific or background levels when
considering remedial action. Because the arsenic background values in the vicinity of the
ILCO Main Facility range from 4.8 - 26 ppm, and because the reasonable maximum
exposure concentration that was used in the risk assessment was 14 ppm, it appears that
the onsite and background concentrations are similar.
Based on the results and conclusions of the human health risk assessment, a performance
standard of 400 ppm was established for lead in sediment in the unnamed tributary and
Dry Creek. No cleanup levels were established for lead in surface water, because the risk
assessment showed that lead concentrations in surface water are unlikely to result in a risk
to human health or the environment. In addition, no cleanup levels were established for
arsenic in sediment, because the reasonable maximum exposure concentration used in the
risk assessment for arsenic was within background levels at the Site.
6.6 Environmental Risk
An ecological risk assessment (ERA) was conducted for OU-3 to evaluate the impacts to
aquatic receptors and piscivorous wildlife. Adverse effects to aquatic receptors were
evaluated using risk quotients representing a comparison of surface water and sediment
exposure point concentrations to chemical concentration levels from scientific literature
below which adverse effects are not likely to occur. Potential adverse effects to aquatic
receptors were also evaluated using data from EPA biological investigations on the OU-3
streams, including a habitat assessment, toxicity tests, and macroinvertebrate survey.
Piscivorous wildlife were evaluated by comparing the estimated daily dose to belted
kingfisher resulting from consuming lead-contaminated fish' with toxicological benchmarks
from the literature. //
Comparisons of surface water and sediment levels to scientific literature suggest that the
aquatic invertebrates may be adversely affected. Nevertheless, it should be noted that
actual Site-specific biological sampling on the OU-3 streams indicated no significant
observable adverse effects seem to be occurring. The reason for this disparity may be that
the lead and the other chemicals of potential concern are bound to sediment particles and,
as a result, may not be very bioavailable or may be bioavailable but in non-toxic forms. The
results of the fish tissue analyses indicate that some of the lead in the sediment hi the
unnamed tributary and Dry Creek is being taken up by fish. However, the results of the
ecological risk assessment indicate that adverse effects to aquatic receptors and piscivorous
wildlife from consuming lead-contaminated fish are unlikely, even when using very
conservative exposure assumptions. As a result, concentrations of lead in sediment and
surface water in the OU-3 streams are not likely to result in an environmental risk.
7.0 DESCRIPTION OF ALTERNATIVES
The site-specific remedial alternatives represent a range of distinct waste-management
strategies addressing the human health and environmental concerns. Although the selected
18
-------
remedial alternative will be further refined as necessary during the design phase of the
remedial action, the following analysis reflects the fundamental components of the various
alternatives evaluated during the Feasibility Study for OU-3.
EPA evaluated four cleanup alternatives for contaminated sediment in the unnamed
tributary and Dry Creek in the immediate vicinity of the ILCO Main Facility. A brief
description of each of the sediment alternatives is given below.
ALTERNATIVE 1: NO ACTION
The no-action alternative involves no further cleanup for any of the contaminated media at
the site; current conditions would change only through natural attenuation processes (e.g.,
dilution, flushing, burial, etc.). The purpose of including the no-action alternative is to
provide a baseline with which the other alternatives can be compared. The no-action
alternative would, however, include conducting 5-year reviews, as required by the Superfund
law, to evaluate the effectiveness of the no-action alternative. The purpose of the 5-year
reviews would be to determine whether the action remains protective of human health and
the environment.
ALTERNATIVES LIMITED ACTION
Limited action consists of controls to limit exposure to contaminated media. The purpose
of these activities is to limit exposure to contaminated sediment and the ingestion of
contaminated fish tissue. The limited action alternative would include:
;/
Natural attenuation (e.g., dilution, flushing, burial, etc$ of the contaminated sediment.
Recommending to the Alabama Department of Public Health (ADPH) that a fishing
advisory be issued for the unnamed tributary and Dry Creek near the ILCO Main
Facility.
Posting warning signs along the unnamed tributary and Dry Creek to indicate the
presence of contaminated sediment and the fish advisory.
Annual surface water, sediment, and biota monitoring.
5-year reviews as required by CERCLA to evaluate the effectiveness of the limited-action
alternative.
EPA, in cooperation with ADPH, would also evaluate the feasibility of a community
education program designed to educate the community on the potential health effects caused
by being exposed to contaminants from OU-3 of the ILCO site.
19
-------
ALTERNATIVES: CONTAINMENT
Alternative 3 for sediment would involve installing a barrier over the most highly
contaminated sediment in portions of the unnamed tributary and Dry Creek. The barrier
would isolate and prevent further migration of and exposure to the contaminated sediment.
This alternative consists of a multimedia layer of rip-rap (rocks) overlying a geotextile
fabric. As required by CERCLA, controls and monitoring to evaluate long-term
protectiveness would also be performed.
The area to be capped is based on lead concentrations in the sediment exceeding 400 ppm.
A predesign effort to confirm and further define the area to be capped would be needed.
The sequence of cleanup activities for the unnamed tributary and Dry Creek would be:
Selected areas along the unnamed tributary and Dry Creek where lead concentrations
in sediment exceed 400 ppm would be cleared to provide access for equipment and
vehicles.
A rerouting system, consisting of dikes, pumps, and a piping network, would be
constructed to temporarily divert surface water around the affected stream segments
during construction.
The streambed channel would be cleared of debris (i.e., large rocks, tree limbs) and
graded to ease installation of the liner.
* i
ii
An appropriate non-woven geotextile fabric would be placed in the graded channel.
The geotextile liner would be covered with rip-rap for scouring protection.
The surface water rerouting system would be removed once the rip-rap has been
successfully placed.
All equipment and materials that come in contact with contaminated sediment would be
decontaminated.
The stream banks would be revegetated to prevent excess erosion of banks.
After site construction activities, the following controls would be initiated:
Warning signs would be posted along the unnamed tributary and Dry Creek to indicate
the presence of contaminated sediment beneath the cap and to warn against excavation
or other disturbances.
The cap would be inspected annually and repaired as needed.
20
-------
ALTERNATIVE 4A: REMOVAL WITH ACID LEACHING TREATMENT
Alternative 4A would involve a more aggressive cleanup approach than the previously
described alternatives. It would entail removal of sediment with lead concentrations greater
than 400 ppm from the unnamed tributary and Dry Creek and transportation to the ILCO
Main Facility for treatment and disposal along with contaminated soil from OU-2. The
alternative would not include controls, monitoring, or operations and maintenance (O&M)
because no lead-contaminated sediment above 400 ppm would remain at OU-3. The
components of this remedy would include:
Removal - Contaminated sediment would be removed using high-pressure washing,
vacuum cleaning, and-excavation methods.- Removed material would be loaded into
watertight trucks for transporting a short distance to the ILCO Main Facility.
Treatment - Contaminated sediment would initially be dewatered before entering the
acid leaching treatment process for soil from OU-2.
Disposal - Disposal of treated sediment would be onsite at the ILCO Main Facility along
with treated soil from OU-2.
t
Lead recycling - Thermal treatment (i.e., secondary smelting) would be used for recycling
lead residuals from acid leaching, as specified and discussed in Section 9.0 of the ROD
for OU-2.
ALTERNATIVE 4B: REMOVAL WITH SOLIDIFICATION/STABILIZATION
TREATMENT //
Alternative 4B involves the removal of sediment from the unnamed tributary and Dry Creek
and transportation to the ILCO Main Facility for treatment, as described above under
Alternative 4A. The treatment process for the sediment in this alternative would be
solidification/stabilization and onsite disposal under a multimedia cap. The process is
specified as the contingent treatment option in Section 9.0 of the ROD for OU-2 in the event
the treatability study results for acid leaching do not meet performance goals. Like
Alternative 4A, this alternative would not include such activities as controls, monitoring,
or O&M because no lead-contaminated sediment above 400 ppm would remain at OU-3.
8.0 SUMMARY OF THE COMPJ
The remedial action alternatives selected for OU-3 were formulated to provide a range of
discrete options to attain the remedial action objectives established for OU-3. These
alternatives generally satisfy NCP requirements regarding the development of alternatives,
including treatment to address, principal threats and a range of treatment options that vary
in the degree of treatment as-well as the type and quantity of treated residuals or untreated
waste requiring long-term management.
21
-------
This section documents the comparative analysis conducted to evaluate the relative
performance of each alternative in relation to each of the evaluation criteria. The purpose
is to identify the relative advantages and disadvantages of each alternative. The key
tradeoffs that must be balanced in the selection of remedy can then be identified. As stated
in the NCP [40 CFR 300.430 (f)], the evaluation criteria are arranged in a hierarchial
manner that are then used to select a remedy for a site based on the following categories:
Threshold Criteria:
Overall Protection of Human Health and the Environment
Compliance with AKARs
Primary Balancing Criteria:
Long-Term Effectiveness and Permanence
Reduction of Toxitity, Mobility, or Volume
Short-Term Effectiveness
Implementability
Cost
c
Modifying Criteria:
State Acceptance
Community Acceptance
'- **
COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES FOR SEDIMENT
EPA used the criteria listed above to evaluate each sediment alternative to determine which
would best reduce the contamination and potential risk for ILCO OU-3.
Overall Protection of Human Health and the Environment
A comparison of the relative protectiveness of the OU-3 alternatives is limited by the small
levels of risk reduction possible at OU-3. Alternatives 3 and 4 would reduce the potential
for exposures to contaminated sediment in the unnamed tributary and Dry Creek.
Alternative 4 would go one step further by actually removing the contaminated sediment.
Both of these alternatives, however, would be constrained by the reo^rirements associated
with construction activities in Dry Creek and possible RCRA requirements. These
constraints would add uncertainly to any conclusions regarding the protectiveness of either
alternative.
Natural processes, combined with the cleanup of the ILCO Parking Lot and the ILCO Main
Facility under the OU-1 and OU-2 remedial actions, respectively, should eventually cause
lead concentrations in the unnamed tributary and Dry Creek to decline to health-based
22
-------
levels. Alternative 2, involving controls that should minimize exposures to the contaminated
sediment, would be more protective than Alternative 1 (no action) and may be as protective
as Alternatives 3 and 4 given the uncertainties associated with the implementation of either
of those alternatives.
Compliance with ARARs (Standards)
The most difficult to implement in compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) or, in other words, Federal and State requirements would be
Alternative 4 because the activities include excavation, transport, handling, storage,
treatment, and disposal. If testing shows some of the sediment to be RCRA characteristic
waste, implementation -of-Alternative - 4 must-comply-with the appropriate RCRA
requirements. Alternative 4 could, however, be designed and implemented so as to attain
compliance with RCRA and other ARARs.
Both Alternatives 3 and 4 would also have to comply with Clean Water Act requirements
related to capping of aquatic environments and resuspension of sediment into surface waters
or wetlands. Compliance with these requirements should be possible but is expected to
increase both the schedule and cost of Alternatives 3 and 4. Alternatives 1 (No Action) and
2 (Limited Action) would have the least difficulty meeting ARAR requirements because they
would only have to comply with the Alabama Water Use Classifications.
Long-Term Effectiveness and Permanence
The lowest level of residual risk and the highest degree of permanence would be associated
with Alternative 4 (Removal, Treatment, and Disposal)//which involves removal of all
sediment contamination above health-based levels. The long-term effectiveness of this
alternative would be further enhanced because it requires no O&M activities. The
effectiveness and permanence of Alternative 3 would depend on long-term maintenance of
the cap and other engineering controls. Alternative 2 would also be effective as long as the
public follows the warning signs and/or fish advisory. Effectiveness and permanence of risk
reduction for Alternative 2 would be dependent on the maintenance of the controls.
Historical lead analysis data of sediment from ILCO OU-3 indicate that Alternative 1 could
eventually result in a permanent solution for OU-3. However, tile time to achieve this level
of risk reduction would be dependent on natural processes, such as redistribution and
dilution of contaminated sediment downstream of the ILCO site.
Reduction of Toxicity, Mobility, or Volume
Alternatives 1 and 2 would not affect the toxicity, mobility, or volume of contaminated
sediment in ILCO OU-3. Any reduction of toxicity or volume would be dependent on natural
redistribution and dilution of contaminated sediment downstream of the site. Alternative
3 (Containment) does not involve treatment, therefore, there would be no reduction of
toxicity or volume of contaminated material. Alternative 3 would achieve a reduction in
23
-------
mobility by isolating the contamination under a multi-media cap, as long as the cap and
other engineering controls are maintained. Alternative 4 (Removal, Treatment and
Disposal) would achieve the greatest reductions in toxicity, mobility, and volume through
the removal, treatment, and disposal of sediment with lead contamination above
health-based levels.
Short-Term Effectiveness
Alternatives 1 and 2 (No Action and Limited Action), involving no onsite cleanup activities,
would result in no additional risks to the community or workers beyond those currently
associated with this site. Much greater impacts to these receptors are possible if
Alternatives 3 or 4 are implemented, because both involve construction activities within or
handling of contaminated sediment. The transport of contaminated sediment through the
Leeds community and increased potential for releases during treatment (air emissions, dust,
runoff, odors, etc.) would make Alternative 4 the least effective from a short-term
perspective. Potential impacts to the community, site workers, and the environment for all
of the alternatives would be minimized through proper use of engineering controls,
monitoring, and appropriate health and safety procedures.
The time required to implement protectiveness, would be the quickest for Alternative 2 Gess
than 1 year), however, time required to achieve protectiveness would be dependent on the
public following the warning signs and/or fish advisory. The longest time to achieve
protectiveness would be for the no action alternative, which would be dependent on natural
processes to reduce lead concentrations in OU-3 sediment. A reliable estimate of the time
for this to occur is not available, but there is evidence that i$ is already occurring. The rate
at .which concentrations decline in the sediment are expected to increase following
implementation of the remedies for OU-1 (which includes the ILCO Parking Lot) and OU-2
(the ILCO Main Facility). If so, the time to achieve protectiveness for no action may not be
significantly greater than that associated with capping or removal, given the expected delays
due to complications associated with capping or excavation in Dry Creek.
Implementability
Alternatives 1 and 2 (No Action and Limited Action) would be the most easily implemented
as neither would require design or construction activities. Alternative 3 (Containment)
would involve common construction techniques which are considered technically feasible and
routine. Alternative 4 (Removal, Treatment, and Disposal) would involve removal using
conventional construction equipment and a relatively complex treatment train. The
treatment process has been demonstrated to be effective in the treatment of lead
contaminated sediment but has more uncertainty from an implementability perspective than
the placement of a geotextile liner and rip-rap.
The administrative feasibility of implementing Alternatives 3 and 4 is uncertain given the
applicability of the Clean Water Act Section 404 permitting process. The question of
24
-------
whether a permit can actually be obtained is an unknown. Even if EPA is granted an
exemption from the administrative requirements of the permit, complying with the
substantive portions may be a problem, especially for Alternative 3, which would convert
an ecologically healthy creek into a rip-rap lined industrial-type drainage ditch.
Cost
A summary of the present worth, capital, and O&M costs for each of the alternatives is
presented in Table 8-1. Alternative 1 would be the least expensive, while Alternative 4A
would be the most expensive.
State Acceptance
The State of Alabama, as represented by the Alabama Department of Environmental
Management (ADEM), has been the support agency during the RI/FS process for the ILCO
Site. In accordance with 40 CFR 300.430, as the support agency, ADEM has participated
in this process. The State of Alabama, as represented by ADEM, has concurred with the
selected remedy.
Table 8-1
Summary of Present-Worth Costs Sediment Cleanup Alternatives
Alt
No.
1
. 2
' 3
4A
4B
Description
No Action
Limited Action
Containment
Removal with Acid
Teaching
Removal with
Stabilization
Capital Cost
$ 0
$ 5,800
$ 451,500
$1,403,600
$1,191,000
Total
O&M Cost
$105,000
$529,700
$606,800
$0
$115,200
'
IWal Pass*
Worth Cost
$ 105,000
$ 535,500
$1,058,300
$1,403,600
$1,306,200
Note: Alternative 4B is a contingency treatment in the event the acid leaching treatability
study results do not meet performance criteria.
25
-------
Community Acceptance
Based upon comments expressed at the proposed plan public meeting and written and oral
comments received during the public comment period, the reaction of the Leeds community
to the selected remedy at the ILCO Site has been favorable.
9.0 SUMMARY OF SELECTED REMEDY FOR OU-3
Based upon consideration of the requirements of CERCLA, the NCP, the detailed analysis
of alternatives and public and State comments, EPA has selected a cleanup remedy for OU-
3. The total present worth cost of the selected remedy, Limited Action, is estimated at
$535,500. '._.._
A. Selected Remedy
Based on the comparison of sediment alternatives and the results of the risk assessment,
EPA selects Alternative 2, Limited Action, for reducing potential risks posed by sediment
contamination in OU-3 (the unnamed tributary and Dry Creek). The purpose of the limited
action alternative is to limit exposure to contaminated sediment and to limit ingestion of
contaminated fish tissue. The limited action alternative includes:
Natural attenuation (e.g., dilution, flushing, burial, etc.) of the contaminated sediment.
Recommending to the Alabama Department of Public Health (ADPH) that a fishing
advisory be issued for the unnamed tributary and Dry Creek near the ILCO Main
. Facility. jl
Posting of warning .signs along the unnamed tributary and Dry Creek to indicate the
presence of contaminated sediment and the fish advisory.
Annual surface water, sediment, and biota monitoring.
« 5-year reviews as required by CERCLA to evaluate the effectiveness of the limited-
action alternative. The 5-year reviews would primarily involve a comprehensive
evaluation of the monitoring data.
EPA, in cooperation with ADPH, will also evaluate the feasibility of a community education
program designed to acquaint the community with the potential health effects caused by
being exposed to contaminants from the ILCO site.
Warning signs will be posted along creek and tributary access points. The warning signs
will warn .the public against the exposure to contaminated sediment and against the
consumption of fish from the unnamed tributary and Dry Creek.
26
-------
Surface water, sediment, and biota samples will be collected annually from the unnamed
tributary and Dry Creek. Additional sampling events may be requested by EPA, such as
sampling after major rainfall events, in order to monitor different flow conditions in the
unnamed tributary and Dry Creek. In addition, EPA may also request additional sampling
events, as determined necessary by EPA and the State of Alabama, prior to remediation of
the ILCO Main Facility and the ILCO Parking Lot to ensure early detection of any
increased contaminant levels and/or contaminant migration.
Game fish samples will be prepared in accordance with the FDA filet method (i.e., filet
including the rib cage and belly flap with skin on and scales off - except for catfish where
the skin is removed), while forage fish will be whole-body composite samples. All samples
will be analyzed for total lead. - -
Monitoring will commence within one to two years of signing this ROD. The monitoring
program will be conducted under the direction of EPA. Surface water, sediment, and biota
monitoring stations will be selected by EPA, in consultation with the State of Alabama,
prior to beginning the monitoring program and will be based primarily on previous sampling
results. Data collected from the monitoring events will allow EPA to evaluate
contamination trends in the surface water, sediment, and biota of the unnamed tributary
and Dry Creek. These trends will be used to,support decisions to modify the monitoring
program as needed.
The primary purpose of the monitoring program is to ensure that natural attenuation is
working, that the lead levels in surface water, sediment, and/or biota are decreasing versus
increasing over time, and that the lead contamination is not?rnigrating further downstream.
If the monitoring results show that lead concentrations in/surface water, sediment, and/or
biota are actually increasing over time, as compared with previous sampling results, and/or
contamination is migrating further downstream, the limited action remedy will be re-
examined by EPA, in consultation with the State of Alabama.
The monitoring results will be incorporated into the 5-year reviews required by CERCLA
to ensure that human health and the environment continue to be protected by the selected
remedy, that natural attenuation processes are effective, and that sediment performance
standards continue to be appropriate.
The monitoring program will continue until EPA approves a 5-year review concluding that
the selected remedy has achieved continued attainment of the sediment performance
standards and remains protective of human health and the environment.
The cost of the selected remedy, Limited Action, is estimated to be $535,500.
The selected remedy for sediment at OU-3 is consistent with the requirements of Section
121 of CERCLA and the National Contingency Plan. The selected remedy is protective of
human health and the environment and will attain all Federal and State requirements that
27
-------
are legally applicable or relevant and appropriate to the remedial action (unless such
requirements are waived). The selected remedy for OU-3 represents the best balance of the
nine criteria used by EPA to evaluate possible cleanup alternatives.
B. Performance Standards
Based on the results and conclusions of the baseline risk assessment conducted for OU-3,
a performance standard of 400 ppm is established for lead in sediment in the unnamed
tributary and Dry Creek.
C. CoTy|pli»T>ce Monitor*Tig
Annual surface water, sediment, and biota monitoring shall be conducted at OU-3 in the
unnamed tributary and Dry Creek. Data collected from the annual monitoring will allow
EPA to evaluate contamination trends in the surface water, sediment, and biota of the
unnamed tributary and Dry Creek. These trends will be used to support decisions to modify
the monitoring program as needed. In addition, if the monitoring results show that lead
concentrations in surface water, sediment, and/or biota are actually increasing over time,
as compared to previous sampling results, and/or migrating further downstream, the limited
action remedy will be re-examined by EPA, in consultation with the State of Alabama. The
monitoring results will be incorporated into the 5-year reviews required by CERCLA to
ensure that human health and the environment continue to be protected by the selected
remedy and that natural attenuation processes are effective. The monitoring program will
continue until EPA approves a 5-year review concluding that the selected remedy remains
protective of human health and the environment and has achieved continued attainment
of all Federal and State ARARs (unless such ARARs are waived) established in Section 10.2
of this ROD and the sediment performance standards established in Section 9.0 of this ROD.
10.0 STATUTORY DETERMINATION
EPA's primary responsibility at Superfund Sites is to undertake remedial actions that are
protective of human health and the environment. In addition, Section 121 of CERCLA
establishes additional statutory requirements and preferences. These specify that, when
complete, the selected remedy must also meet all identified Federal and State ARARs
(unless such ARARs are waived), be cost effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the TnaTiTniiTn extent
practicable. In addition, CERCLA includes a preference for remedies that employ treatment
that permanently and significantly reduce the volume, toxitity, or mobility of hazardous
wastes as then* principal element. A review will be conducted within five years from
commencement of the remedial action for OU-3 to ensure that the remedy continues to
provide adequate protection of human health and the environment. The following sections
discuss how the selected remedy for OU-3 meets these statutory requirements.
28
-------
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy, Limited Action, is protective of human health and the environment.
Natural processes, combined with the cleanup of the ILCO Parking Lot and the ILCO Main
Facility under the OU-1 and OU-2 remedial actions, respectively, should eventually cause
lead concentrations in the unnamed tributary and Dry Creek to decline to health-based
levels. In addition, the selected remedy involves institutional controls that should
exposures to the contaminated sediment and biota in OU-3 while natural attenuation
processes are in progress.
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs)
The selected remedy must comply with the substantive requirements of Federal and State
laws and regulations which have been determined to constitute applicable or relevant and
appropriate requirements (ARARs).
Applicable requirements are those cleanup standards, control standards, and other
substantive environmental protection requirements, criteria, or limitations promulgated
under Federal or State law that specifically .address a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance at a Super-fund site.
Relevant and appropriate requirements are those cleanup standards, control standards, and
other substantive environmental protection requirements, criteria, or limitations
promulgated under Federal or State law that, while n<$ "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance at a
Super-fund site, address problems or situations sufficiently similar (relevant) to those
encountered and that are well-suited (appropriate) to circumstances at the particular site.
Chemical Specific ARARs
Chemical-specific ARARs are specific numerical quantity restrictions on individually-listed
chemicals in specific media.
Alabama Water Quality Standards. ADEM Admin. Code R. 335-6-10 Alabama's Water
Quality Standards are relevant and appropriate with respect to non-point source discharges
emanating from the Site as these standards set forth numerical and narrative standards for
surface water in the State of Alabama. However, in order to comply with such standards,
portions of the unnamed tributary, Dry Creek, and the Little Cahaba River would need to
be drained and re-routed during excavation of sediment. As a result, the diverse aquatic
communities living in these waters would be destroyed. Further, Site-specific biological
sampling conducted during the RI for OU-3 indicated that there are no adverse impacts on
the diversified aquatic communities living in the OU-3 streams. Accordingly, EPA has
concluded that compliance with these standards would result in a greater risk to the
29 .
-------
environment and, therefore, invokes a waiver pursuant to CERCLA Section 121(dX4XB), 42
U.S.C §9621(dX4XB), for Alabama's Water Quality Standards.
Location-Specific ARARs
Location-specific ARARs are restrictions placed upon the concentration of hazardous
substances or the conduct of activities on the basis of location.
Alabama's Water Use Classifications. ADEM Admin. Code R. 335-6-11. Dry Creek and the
unnamed tributary are classified as fish and wildlife streams and, therefore, Alabama's
Water Use Classifications are relevant and appropriate.
Action-Specific ARARs
Action-specific ARARs are technology or activity based requirements or limitations or
actions taken with respect to cleanup. No action-specific ARARs have been identified for
the selected remedy for OU-3 of the ILCO Site.
10.3 COST EFFECTIVENESS
<
Based on the information available, the selected remedy provides the best balance of evaluation
criteria and is the least expensive of the sediment alternatives (except for the no action
alternative). EPA believes the selected remedy for OU-3 will reduce the risks to human health
and the environment at an estimated cost of $535,500.
;;
10.4 UTDLiIZATION OF PERMANENT SOLUTIONS TO /THE MAXIMUM
PRACTICABLE
EPA has determined that the selected remedy for OU-3, based on the results of the BRA,
represents the maximum extent to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner at OU-3. Of those alternatives that are protective of human
health and the environment and comply with ARARs, EPA has determined that the selected
remedy provides the best balance of trade-offs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility, or volume, short-term effectiveness, implementability, and cost,
while also considering the statutory preference for treatment as a principal element and
considering State and community acceptance. The statutory preference for remedies that utilize
permanent solutions is not satisfied at OU-3. EPA has concluded that remedies which utilize
permanent solutions are impracticable and not cost-effective at OU-3 based on the results of the
baseline risk assessment not showing a significant risk posed to human health or the environment
by OU-3. The selected remedy for OU-3 is consistent with the requirements of Section 121 of
CERCLA and the National Contingency Plan to the extent practicable. The selected remedy is
protective of human health and Hie environment and will attain all identified Federal and State
ARARs. The selected remedy for OU-3 represents the best balance of the nine criteria used by
EPA to evaluate possible cleanup alternatives.
30
-------
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The selected remedy for OU-3 utilizes treatment technologies to the extent practicable. The
statutory preference for remedies that employ treatment as a principal element is not satisfied.
EPA has concluded that remedies which employ treatment technologies are impracticable and not
cost-effective at OU-3 based on the results of the baseline risk assessment not showing a
significant risk posed to human health or the environment by OU-3. However, it was determined
that the selected remedy for OU-3 is consistent with the requirements of Section 121 of CERCLA
and the National Contingency Plan to the extent practicable. The selected remedy is protective
of human health and the environment and will attain all identified Federal and State ARARs. The
selected remedy for OU-3 represents the best balance of the nine criteria used by EPA to evaluate
possible cleanup alternatives. -
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for OU-3 was released for public comment in July 1995. The Proposed Plan
identified Alternative 2, Limited Action, as the preferred alternative at OU-3. EPA has reviewed
all written and verbal comments submitted during the public comment period. The only
significant changes made based on the comments received and an evaluation by EPA of the
proposed remedial action are: ,
EPA modified the monitoring program to be conducted under the selected remedy for OU-3
to state that EPA may request additional sampling events, such as sampling after major
rainfall events, to monitor different flow conditions in the unnamed tributary and Dry Creek.
EPA modified the monitoring program to be conducted uiider the selected remedy for OU-3
to include surface water sampling in addition to the proposed sediment and biota sampling.
EPA modified the monitoring program to be conducted under the selected remedy for OU-3
to state that EPA may request additional sampling events, as determined necessary by EPA
in consultation with the State of Alabama, prior to remediation of the ILCO Main Facility and
the ILCO Parking Lot to ensure early detection of increased contaminant levels and
contaminant migration.
31
-------
APPENDIX A
ILCO SUPERFUND SITE
RESPONSIVENESS SUMMARY
#1:
A choice among the four alternatives listed for cleanup at the ILCO OU-3 site yields only
a single alternative that even approaches being acceptable. That is alternative 4 -
removal and treatment of the contaminated sediment. Alternatives 1-3 do little or
nothing to protect the public health or the larger ecosystem formed by the Cahaba, if s
tributaries, and the watershed.
EPA's Response:
«
A comparison of the relative protectiveness of the OU-3 alternatives is limited by the small levels
of risk reduction possible at OU-3. EPA agrees that alternative 4 would reduce the potential for
exposures to contaminated sediment in OU-3 by actually removing the contaminated sediment.
However, implementation of this alternative would be constrained by the requirements associated
with construction activities in Dry Creek and possible RCRA requirements. These constraints add
uncertainty to any conclusions regarding the protectiveness o^ alternative 4. Natural processes,
combined with the cleanup of the ILCO Main Facility and the ILCO Parking Lot, should
eventually cause lead concentrations in OU-3 to decline to health-based levels. As stated in the
risk assessment, the risk associated with the contaminated sediments and fish is very uncertain,
so any decline would benefit both people and the environment. EPA's preferred alternative,
alternative 2, involves controls that should minimize exposures to the contaminated sediment and,
given the uncertainties associated with implementation of alternative 4, alternative 2 may be as
protective as alternative 4. hi addition, the ecological risk assessment concluded that the
concentrations of lead in sediment in the OU-3 streams are not likely to result in an ecological
risk. Despite the presence of lead concentrations in excess of EPA's conservative 400 mg/kg
screening level at some locations downstream from the ILCO Main Facility in the unnamed
tributary and Dry Creek, EPA's macro-invertebrate surveys and toxicity tests indicated no adverse
impact from site-derived contaminants on the aquatic communities in OU-3. As a result, EPA
believes that alternative 2 will be protective of public health and the larger ecosystem formed by
the Cahaba. However, if the OU-3 monitoring results show that lead concentrations in sediment
and biota are actually increasing over time and/or migrating further downstream, the selected
remedy,, alternative 2, will be re-examined by EPA, in consultation with the State of Alabama, to
ensure the protection of human health and the environment.
32
-------
Comment #2:
Considering EPA's nine criteria for evaluating the alternatives, since alternatives 1 and
2 are very similar, what made EPA choose alternative 2 over alternative 1?
EPA's Response:
The human health risk assessment determined that concentrations of lead in sediment and fish
from the unnamed tributary and Dry Creek in the vicinity of the ILCO Main Facility could
contribute to or result in an unacceptable risk to human health. Although this risk is uncertain,
there is still the potential for adverse impacts to people from exposure to contaminated sediments
and ingestion of contaminated fish. As a result of this potential risk to human health, EPA
believes that alternative 2 is more protective than alternative 1. Alternative 1, unlike alternative
2, does not involve any controls to minimize exposure to contaminated sediment and ingestion of
contaminated fish. Alternative 2 also includes annual monitoring of the sediment and biota to
ensure that lead levels are not increasing over time and to ensure that the alternative continues
to remain protective of human health and the environment. As a result, EPA prefers alternative
2 over alternative 1. Alternative 2 provides the best balance of the nine criteria used by EPA in
evaluating alternatives for cleanup.
t
Comment #3:
How long will it take to implement alternative 2 at the ILCO OU-3 site?
EPA's Response:
The monitoring program should commence within one to two years of signing this Record of
Decision, as long as there are no delays to the project. Other components of alternative 2, such
as the fish advisory and warning signs, should be implemented even sooner than the monitoring
program. The monitoring program will continue until EPA approves a 5-year review concluding
that the selected remedy remains protective of human health and the environment, has achieved
continued attainment of all Federal and State ARARs established in Section 10.2 of this ROD, and
has achieved the sediment performance standards established in Section 9.0 of this ROD.
Comment #4:
If alternative 2 is enacted and EPA does annual monitoring on OU-3* will EPA monitor
different flow conditions, such as after a rainfall event, or will EPA strictly use base
flow?
EPA's Response:
EPA agrees that the monitoring program should include monitoring of different flow conditions
versus just base flow conditions alone. As a result, EPA will modify the monitoring program to
33
-------
be conducted under the selected remedy for OU-3 to state that EPA may request additional
sampling events, such as sampling after major rainfall events, to monitor different flow conditions.
Comment #5:
Only sediment and biota are proposed for monitoring of OU-3. It is realized that surface
water does not pose a threat at this time, but since sediment and biota samples have to
be taken, wouldn't it be beneficial to have surface water data to reference if there were
changes in the future?
EPA's Response:
EPA agrees that surface water data may be useful to reference if there are changes in the future
to the selected remedy for OU-3. As a result, EPA will modify the monitoring program to be
conducted under the selected remedy for OU-3 to include annual surface water sampling, in
addition to sediment and biota sampling.
Comment #6:
EPA should consider sampling OU-3 on a, quarterly basis until the source of the
contamination is removed (Le., the contaminated soils at the ILCO Main Facility and the
ILCO Parking Lot). Quarterly sampling episodes would allow early detection of
increased contaminant levels and contaminant migration.
EPA's Response:
il
EPA agrees that additional sampling events may be necessary until the time that the source of
the contamination is removed, but EPA does not necessarily believe that sampling on a quarterly
basis is required. EPA will modify the monitoring program to be conducted under the selected
remedy for OU-3 to state that EPA may request additional sampling events, as determined
necessary by EPA, in consultation with the State of Alabama, prior to remediation of the ILCO
Main Facility and the ILCO Parking Lot to ensure early detection of any increased contaminant
levels and contaminant migration.
Comment #7:
According to EPA's technical documents, the unnamed tributary and Dry Creek in the
vicinity of the ILCO site do not support large populations of edible fish because of the
small size of the streams. In fact, no fish were caught at several stations along the
unnamed tributary and at the reference station near the Leeds Memorial Park. For
these reasons, the ILCO PKP Steering Committee does not believe that the record
supports the need for issuance of a fishing advisory for the unnamed tributary and Dry
Creek near the ILCO Main Facility.
34
-------
EPA's Response:
EPA disagrees that the record does not support a need for issuance of a fishing advisory for the
unnamed tributary and Dry Creek. The human health risk assessment determined that there was
a potential risk associated with consuming contaminated fish from the unnamed tributary and Dry
Creek in the vicinity of the ILCO Main Facility. EPA agrees that there were no fish caught at
several stations along the unnamed tributary and at the reference station, however, several fish,
some of edible size and some exceeding EPA's screening level for lead in fish, were caught at some
of the stations on the unnamed tributary and at most of the stations on Dry Creek. Therefore, in
order to protect the public from any risk associated with consuming contaminated fish from the
unnamed tributary and Dry Creek, EPA believes that a fish advisory is warranted. As a result,
EPA will recommend to the Alabama Department of Public Health (ADPH) that a fishing advisory
be issued for the unnamed tributary and Dry Creek. However, the decision on whether or not to
actually issue the fishing advisory will be made by ADPH, not EPA.
Comment #8:
The results of EPA's OU-3 remedial investigation, coupled with data from previous
studies, have confirmed a declining trend in the stream sediment lead levels during
recent years. EPA has attributed this declining trend to the cessation of operations at
the Interstate Lead Company, to EPA's removal project which reduced the levels of lead
in soil at the ILCO Main Facility thereby minimizing the potential for storm water
runoff impacts from the site, and to the hydraulic characteristics of the unnamed
tributary which have caused erosion of sediment to occur from most areas in the stream
channel. The declining trend in stream sediment lead levels suggests that annual
sediment and biota monitoring may not be necessary. The ILCO PKP Steering
Committee instead urges EPA to reevaluate the frequency of monitoring on an ongoing
basis, in light of the results of the previous sediment and biota monitoring and the
status of remedial activities at the ILCO Main Facility and the ILCO Parking Lot. As
remedial activities proceed and as declining trends in sediment lead levels continue to
be observed, the Steering Committee believes that there should be the flexibility to
reduce the frequency of the monitoring program or to eliminate it.
EPA's Response:
EPA agrees that the data, in general, has shown a declining trend in the stream sediment lead
levels over time. However, samples taken during 1994 actually showed an increase in lead
concentrations over what had been detected in past sampling episodes. As a result, EPA feels that
monitoring, at least on an annual basis, is necessary until such time that the monitoring results
. show that the sediment lead levels are consistently decreasing over time. EPA believes that
annual monitoring is necessary to ensure that natural attenuation is working, that the lead levels
are decreasing versus increasing over time, and that the lead contamination is not migrating
further downstream. As a result, the monitoring program will continue until EPA, in consultation
with the State of Alabama, approves a five-year review concluding that the selected remedy has
35
-------
achieved continued attainment of the sediment performance standards and remains protective of
human health and the environment. Data collected from the monitoring events will allow EPA,
however, to evaluate contamination trends in the sediment and biota in OU-3 and these trends
will be used to support decisions to modify the monitoring program as needed.
36
-------
APPENDIX B
STATE OF ALABAMA CONCURRENCE LETTER
ILCO SUPERFUND SITE
RECORD OF DECISION
37
-------
W.Warr
ALABAMA
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
September 29,1995
Governor
MciTmg Address:
PO BOX 301463
MOMTGOMCRYAL
36130-1463
fhy tictl Addrctt:
1751 Cong. W.L
Didttmon Drive
. AL
3*109-2608
034)271-7700
FAX 270-5612
Field Offices:
110 VukanRoad
35209-4702
POS 1942-6168
FAXM1-1603
400 W«W Street HE
f.0. 50X9S3
Ocotur.AL
35602-0953
(205)353-1713
* AX 340-9359
2204PcririMMrRo»d
Mobile. AL
36615-1131
034)450-3400
FAX 479-2593
Mr. John H. Hankinson, Jr.
Regional Administrator
U.S. Environmental Protection Agency
345 CourtJand St. NE
Atlanta. GA 30365
Re: Interstate Lead Company OLCO)
Leeds, Alabama
Dear Mr. Hankinson:
The Alabama Department of Environmental Management has reviewed the draft Record of
Decision for Operable Unit 3 at the referenced facility. After review by our staff and in
consultation with EPA staff, we agree with tho approach recommended in this document
ADEM concurs with the Record of Decision for Operable Unit 3.
Should your staff have questions or comments, please contact Mr. David Thompson at 334-
213-4322.
Sincerely, ' /
James W. Warr
Acting Director
JWW/dwt
pc: Kimberly Q. Lantcrman, RPM
David Thompson, SAC
------- |