United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-89/106
September 1989
Superfund
Record of Decision
Cross Brothers Pail
(Pembroke), IL
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50272-101
REPORT DOCUMENTATION 1. REPORT Na 2.
PAGE EPA/ROD/R05-89/106
4. Till* and Subtitle
SUPERFUND RECORD OF DECISION
Cross Brothers Pail (Pembroke) , IL
First Remedial Action - Final
7. Authors)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Addres*
U.S. Environmental , Protection Agency
401 M Street, S.W.- :'
Washington, D.C-:. 20460
3. Recipienf a Accession No.
5. Report Date
09/28/89
6.
8. Performing Organization Rept No.
10. Projecl/Tssk/Work Unit No.
11. Contnct(C) or Gr«nt(G) No.
(C)
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EPA/ROD/R05-89/106 .
Cross Brothers Pail (Pembroke), IL
First Remedial Action - Final
|.6. Abstract (Continued)
The selected remedial action for this site has been divided into two operable units.
The first involves resampling a localized PCB-contaitiinated soil area followed by
excavation and offsite incineration of approximately 5 cubic yards (dependent upon
resampling results) of soil with a PCB level exceeding 10 mg/kg. The second operable
unit addresses ground water and soil remediation. The 6.5'-acre area will be covered
with a 6-inch vegetative cover, and the 3.5-acre area will be covered by 6 inches of
gravel. Ground water will be pumped and treated onsite with discharge onto the 3.5-acre
gravel area via an irrigation system, thus establishing a "cleansing loop" and inducing
soil flushing through the area of VOC contamination. Deed and access restrictions will
be implemented. The estimated present worth cost for this remedial action is
$2,076,500, which includes an annual O&M of $59,235 for 15 years.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Cross Brothers Pail Recycling
Pembroke Township, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action
for the Cross Brothers Pail Recycling site developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
This decision is based upon the contents of the administrative
record for the Cross Brothers Pail Recycling site.
The United States Environmental Protection Agency and the
State of Illinois agree on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present a current
or potential threat to public health, welfare, or the
environment.
DESCRIPTION OF REMEDY
This final remedy addresses remediation of groundwater and soil
contamination by eliminating or reducing the risks posed by the
site, through treatment and engineering and institutional
controls.
The major components of the selected remedy include:
° Re-sampling of the localized PCB soil area to identify
the existence of a PCB source.
0 If identified, remove the localized PCB-contaminated
soil area and incinerate the soils at a TSCA approved
incinerator.
° Install and maintain a groundwater collection system
capable of capturing the groundwater contaminant plume.
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Install and maintain an on-site groundwater treatment
facility to remove contaminants from the collected
groundvater.
Install and maintain a soil flushing system for the
3.5 acres of contaminated soil within the disposal
area.
Install and maintain a 6 inch vegetative cover over
that portion of the disposal area not subject to the
soil flushing operation.
Monitor the groundwater collection/treatment system and
the groundwater contaminant plume during groundwater
remediation activities.
Install and maintain a 6 inch vegetative cover over
the 3.5 acre area subject to soil flushing upon
terminating the soil flushing operation.
Install and maintain a fence around the site during
remedial activities.
Initiate a deed notification identifying U.S. EPA and
IEPA concerns regarding the conductance of intrusive
activities at the site.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element. As this remedy will initially result in
hazardous substances remaining on-site above health-based levels,
a review will be conducted within five years after commencement
of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
O
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The State of Illinois, through the Illinois Environmental
Protection Agency, concurs with the decision the Regional
Administrator has made, in the exercise of his authority, in
selecting this remedy.
9/it/i
Bernard P."Killian
Director
Illinois Environmental Protection Agency
Date
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RECORD OF DECISION SUMMARY
CROSS BROTHERS PAIL RECYCLING
I. SITE DESCRIPTION
The Cross Brothers Pail Recycling site is a 20-acre parcel
of land located 12 miles east of Kankakee, Illinois in
Pembroke Township (Figure 1). Approximately half of the
20-acre site was used for waste disposal.
The site is situated within a semi-residential area which is
interspersed with small farms and undeveloped pastureland.
The nearest surface body of water is the Kankakee River,
which is located approximately 4.5 miles north of the site.
The site is owned by James D. Cross. Mr. Cross currently
resides on the site. In addition, Mr. Cross presently
operates a wood pallet reclamation business on-site
employing approximately 10 part-time workers.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
James and Abner Cross operated a pail and drum reclamation
business at the site from 1961 until 1980. The reclamation
operation consisted of placing drums and pails containing
dye, ink, and paint residue onto the ground, allowing their
contents to drain. Waste solvents were then poured over and
into the pails and drums to dissolve the remaining residue.
This mixture was then ignited to burn out the remaining
contents. The pails and drums were then moved to a
reconditioning shed, sand blasted, and repainted. This
process resulted in a layer of waste residue up to 6 inches
thick covering approximately 10 acres of the property. The
operation also included burial of crushed pails and drums in
approximately 10 trenches at various locations around the
site. The trenches varied in size, but were generally less
than 20 feet in width and depth.
In June 1980, the site was discovered by Illinois
Environmental Protection Agency (IEPA) personnel during an
aerial survey. Subsequent to a site inspection, the Illinois
Attorney General's Office obtained a court order from the
Kankakee Circuit Court on August 19, 1980, requiring the
site to be closed and cleaned up.
Following the court order, IEPA sampled and analyzed water
from local private water supply wells. Based on the results
from that sampling, the two home owners immediately north of
the site were advised by IEPA to obtain an alternative
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TOWNSHIP 32 NORTH, RANGE II WEST,
SW 1/4, NE 1/4, OF SECTION 15,
SECOND PRIME MERIDIAN,
• KANKAKEE COUNTY, ILLINOIS
SYMBOLS
[v ' j | INCORPORATED AREA
- • - PAVED ROAD
1 UNIMPROVED ROAD
—@ — STATE ROAD
-*• — -»- DRAINAGE DITCH
CROSS BROTHERS SITE
MAP SOURCE: ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
SCALE IN MILES
FIGURE i
SITE LOCATION MAP
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source of water to replace their contaminated wells.
Subsequently, Mr. Cross paid for the installation of new,
deeper water wells at these two residences.
The IEPA then conducted a limited amount of additional field
work to further characterize the contamination at the site.
The results of this investigation are summarized in a August
1981 report by R.B. St. John entitled A Hydroaeoloaical
Study of the Pembroke Cross Brothers Site. This report
indicated the presence of surficial and buried waste
materials (i.e. pails and drums) and a groundwater
contaminant plume.
In December 1982, the Cross Brothers Pail Recycling site was
proposed for inclusion on the National Priorities List
(NPL). The site listing was finalized in September 1983.
From May 1983.to June 1984, IEPA conducted a Remedial
Investigation/Feasibility Study (RI/FS) at the Cross
Brothers Pail Recycling site through a Cooperative Agreement
(CA) with the United States Environmental Protection Agency
(U.S. EPA) . The primary focus of this investigation was to:
locate additional drums/bulk waste, perform a waste
.inventory and characterization survey and accurately define
the.groundwater contaminant plume. The RI results indicated
however, that additional studies would be necessary to
accurately define the groundwater contaminant plume.
Therefore, the FS focused on source control alternatives
(i.e. removal of pails and drums), in addition to
recommending that additional groundwater studies be
performed.
Concurrent with the RI/FS, the Kankakee County Circuit Court
ruled that James and Abner Cross could continue their pail
and drum reclamation business at the site, as well as begin
a wood pallet reclamation operation, as long as the pails
and drums contained no hazardous wastes or substances.
On March 25, 1985, U.S. EPA, with lEPA's concurrence, signed
a Record of Decision (ROD) requiring certain Initial
Remedial Measures (IRM) at the Cross Brothers Pail Recycling
site. The primary focus of the IRM was to remove surficial
and buried waste materials, as well as visibly contaminated
soils. In addition, the ROD recommended an investigation of
soil and groundwater be continued after completion of the
IRM, to determine if any additional remedial actions would
be necessary at the site.
From October 16, 1985 until November 15, 1985, IEPA
conducted the IRM utilizing State funds. During the IRM, the
disposal area was cleared of all vegetation and 6438 tons
of surficial soil containing paint, ink, dye and tar-like
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residue, 56 tons of crushed pails, 542 drums still
containing wastes and 572 empty drums were removed from the
site (Figure 2).
From January 1986, until the present, IEPA has been the lead
agency in conducting a Hydrogeological Study/Feasibility
Study (HS/FS) at the site. The HS/FS was conducted through a
CA with the U.S. EPA. The HS was conducted to define the
nature and extent of groundwater and residual soil
contamination at the site and to characterize the potential
threats to public health and the environment from the site.
Field activities for the HS were conducted in two phases and
Were completed in October 1988. The results are described in
the Final HS report, dated April 1989.
The Public Comment FS was completed in July 1989. The FS
documents and describes in detail the development and
evaluation of an array of remedial action alternatives for
the Cross Brothers Pail Recycling site. Public comment on
the FS ended August 25, 1989.
B. Enforcement Activities
U.S. EPA and IEPA have identified approximately twelve
Potentially Responsible Parties (PRPs) for the Cross
Brothers Pail Recycling site. This identification was based
on records from the State of Illinois, responses to
government information requests, on-site investigation
reports, and company records.
All of the PRPs were identified by a general notice letter
dated June 13, 1989. On July 11, 1989, U.S. EPA and IEPA
held a meeting with the PRPs to discuss the HS and future
enforcement activities.
On July 26, 1989, Special Notice Letters were sent to the
twelve PRPs pursuant to Section 122(e) of the Superfund
Amendments and Reauthorization Act (SARA) of 1986. The
deadline for receipt of a "good faith offer" to conduct the
remedial design and remedial action discussed in this Record
of Decision Summary is October 3, 1989. If a "good faith
offer" is not received by October 3, 1989, U.S. EPA and IEPA
may conduct the Remedial Design/Remedial Action (RD/RA) with
Federal and State funds or, U.S. EPA may issue an Unilateral
Administrative Order (UAO) to the PRPs, to conduct the
RD/RA.
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-
D
SYMBOLS
EXISTING IEPA MONITORINQ
WELL(PVC)
EXISTING STAINLESS STEEL
MONITORING WELL
PROPERTY LINE
" N EXISTING CONTOUR
^\y^T PROPOSED CONTOUR
•• AREAS OF INTEREST OUTLINE
-//—//- HOT LINE
••• IRM CONSTRUCTION LIMITS
NOTE: FIGURE REDRAWN FROM NOV., M. isas
AS BUILT PLANS OBTAINED FROM
J J LARSON. ICPA.
100 ZOO 300
SCALE IN FEET
CONTOUR INTERVAL = I FOOT
FIGURE 2
SITE CONDITIONS FOLLOWING
THE IRM
METCALF OEOOY
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III. COMMUNITY PARTICIPATION
The HS/FS and Proposed Plan for the Cross Brothers Pail
Recycling site were released to the public in July 1989.
These documents were made available to the public in both
the administrative record and information repositories. The
administrative record is at the following locations:
U.S. EPA - Region V Illinois EPA
230 S. Dearborn 2200 Churchill Road
Chicago, IL 60409 Springfield, IL 62706
Kankakee Public Library
304 South Indiana Avenue
Kankakee, IL 60901
The information repositories are at the following locations:
Kankakee Public Library Hopkins Park Village Hall
304 South Indiana Avenue Central & Main Streets
Kankakee, IL 60901 Hopkins Park, IL 60944
A public comment period was held from July 26, 1989 through
August 25, 1989. In addition, a public meeting was held on
August 21, 1989. At this meeting representatives from U.S.
EPA and IEPA answered questions about the problems at the
site and the remedial alternatives under consideration.
Responses to the comments received are. included in the
Responsiveness Summary, which is a part of this ROD.
IV. SCOPE AND ROLE OF RESPONSE ACTION
U.S. EPA and IEPA previously determined it necessary to
perform an IRM at the Cross Brothers Pail Recycling site.
The selection of the IRM was documented in the March 25,
1985, ROD for the site. The primary focus of the IRM was
removal of surficial and buried waste materials (i.e. pails
and drums), as well as visibly contaminated soils. This
action was completed in November 1985.
This ROD supplements the earlier ROD, and addresses
contaminated groundwater and residual surface and
subsurface soil contamination not addressed by the IRM.
Contaminated groundwater is the principal threat at the
site, as it contains contaminants above health-based levels.
In addition, the contaminants present in the surface and
subsurface soils will continue to leach into groundwater.
Therefore, the purpose of this response action is to prevent
current or future exposures to the contaminated groundwater
and to reduce contaminant migration into groundwater. This
action will be the final response action for the site.
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V. SITE CHARACTERISTICS
The nature and extent of site related contamination was
determined by a series of field investigations during the
HS. The results of these field investigations are
summarized, by medium, in the following discussion. Any
specific characteristics associated with a medium, are also
summarized in the following discussion.
A. Surficial Soils
Results of the surface soil investigation indicate volatile
organic, semi-volatile organic and polychlorinated biphenyl
(PCB) contamination to be present at the site. Volatile
organic compounds (VOCs) were identified at 13 of the 21
surface soil sampling locations. Tetrachloroethene was the
most frequently detected VOC, while total xylenes were
detected in the highest concentration.
Semi-volatile organic compounds were detected at 8
locations. The most frequently identified semi-volatile
organic compound was bis (2-ethylhexyl) phthalate (DEHP).
At 5 locations PCBs were detected in surface soils. Each of
these locations contained less than 10 ppm PCBs, which is
the suggested cleanup level given in 40 CFR 761.
Concentrations of the inorganics detected were all within
the median range of inorganics found naturally in soils in
the United States. Therefore the surface soil is not
considered to be contaminated with inorganics.
B. Subsurface Soils
Results of the subsurface soil investigation found volatile
organic, semi-volatile organic and PCB contamination to be
present at the site.
Sixteen VOCs were identified at 18 locations on the site.
The compounds most frequently identified were acetone and
methylene chloride. However, these compounds were also
detected in the laboratory blanks indicating possible
laboratory contamination of the samples. Total xylenes were
detected in the highest concentrations.
Semi-volatile organic compounds were found to be present at
the same locations as the VOCs. A total of 26 compounds were
identified. The most frequently detected semi-volatile
compound was DEHP.
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PCBs were detected at four subsurface locations. One sample
was found to contain 110 ppm of PCBs at a depth of 6 feet
below ground surface. All other samples were below 10 ppm.
Soil contamination at depth by inorganics was not detected.
C. Distribution of Soil Contamination
The surface and subsurface soil investigation results
reveal a strong similarity in contaminant distribution
between surface and subsurface soils. Soil contamination by
organic compounds exists throughout the thickness of the
unsaturated zone. PCBs were also detected in surface and
subsurface soils.
The areal extent of contamination is also very similar
between surface and subsurface soils (Figure 3). The areal
extent of soil contamination is approximately 3.5 acres.
Assuming soil is contaminated throughout the unsaturated
zone (0 to 6 feet), the estimated volume of contaminated
soil is 33,880 yd^. This area represents an area of fairly
consistent contamination, but does not represent the only
probable area of soil contamination. The waste disposal
practices performed on-site may have left small localized
areas of contaminated soil at other locations throughout the
site area.
Table 1 presents a summary of the range and frequency of the
organic contaminants detected in the surface and subsurface
soils.
D. Groundwater HydroQeolocrv and Quality
The site area is underlain by the following sequence of
sedimentary units: windblown deposits, glacial outwash,
glacial till and a carbonate bedrock (Figure 4). The
windblown deposits/glacial outwash and carbonate bedrock
serve as the .principal sources of groundwater in the site
area. Each of these sources functions as a distinct
hydraulic unit, as they are separated by a glacial till
aquitard.
The carbonate bedrock aquifer consists of limestone and
dolomite, with minor amounts of shale, that is overlain by a
confining till layer. Boring logs indicate a gravel zone
between the till and the bedrock. It is suspected this zone
represents a highly fractured phase of the bedrock. The
carbonate bedrock aquifer is used to supply large quantities
of irrigation water regionally, and is used locally for
residential water supplies.
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WELL SYMBOLS
O
A
CD
O
®
•
FULLY SCREENED
SHALLOW
INTERMEDIATE
DEEP
PUMPING
OBSERVATION
SYMBOLS
: BASELINE
-. PROPERTY LINE
IRM CONSTRUCTION LIMITS
: UNIMPROVED ROAD
EXISTING SPOT ELEVATION
CONTOUR LINE
EXISTING TREE LINE
EXISTING ROAD
FENCE
AREAS OF CONTAMINATION IDENTIFIED BY'.
MAGNETOMETER
COMBINED
MAGNETOMETER/ELECTROMAGNETIC
GROUND PENETRATING RADAR
(PAINT RESIDUE)
GROUND PENETRATING RADAR
(TRENCH WALL)
SOIL GAS SURVEYS
(ROUND I AND 2)
SURFACE SOIL SAMPLING
(ROUND 3)
SOIL BORINGS (ROUND 4)
NOTE' SURFACE ELEVATIONS ESTABLISHED IN NOV. 1306
ELCVA1ION5 REFERENCED TO AM ASSUMED ON-SITC
BENCHMARK Of W«.« FEET ABOVE TK RATIONAL
GEODETIC VERTICAL DATUM.
ITS
350
525
SCALE IN FEET
CONTOUR INTERVAL •= I FOOT
FIGURE 3
AREAS OF CONTAMINATION IDENTIFIED
DURING THE SOILS INVESTIGATION
METCALF6 EDO)
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TABLE 1
RANGE AND FREQUENCY OF ORGANIC CONTAMINANTS DETECTED IN SOIL
Surface Soils Concentration
Range (ug/kg)
NO - 226000 8
NO - 132000 B
NO - 9.3
NO - 15.8
NO - 500
NO
NO - 2400
NO - 95400
NO - 71900
NO - 1270000
. NO - 20600
NO - 215000
. . NO - 126000
NO
NO
NO
NO - 1370
NO
NO .
NO - 1970
NO - 1770
NO - 13200 .
NO
NO
NO
NO
NO.
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO - 887
NO - 1120
NO - 568
NO - 429
NO • 9.8
Frequency of Oe
Detection
1/26
2/26
1/26
1/26
2/26
0/26
6/26
3/26
1/26
6/26
2/26
2/26
1/26
0/26
0/26
0/26
2/26
0/26
0/26
1/26
10/26
1/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
0/26
1/26
1/26
1/26
2/26
1/26
ep Soils Concentration
Range (ug/kg)
NO - 46 3
NO - 110 8
NO • 64
NO
NO • 2800 E
NO - 120
NO - 1300
NO - 250000
NO • 580000 0
ND - 3700000 0
NO - 17000 0
ND - 2300
ND - 27000 D
ND - 330 E
ND - 94 E
ND - 81 E
ND - 4900
ND • 280 E
NO - 260 E
ND - 6300
NO - 25000 D
NO
NO - 210 E
ND - 130 E
ND - 980
NO - 240 E
ND - 240 E
NO - 210 £
NO - 39 E
NO - 43 E
NO - 180 E
NO - 540
NO - 1200
NO - 4300
ND - 1300
NO - 51 E
NO - 240 E
NO - 110000
NO
ND - 3900
NO • 250
NO
Frequency of
Detection
13/30'
13/30
2/30
0/30
2/30
5/30
9/30
9/30
7/30
9/30
10/30
6/30
9/30
4/30 '
3/30
2/30
13/30
2/30
5/30
9/30
20/30
0/30
2/30
2/30
4/30
2/30
2/30
2/30
1/30
1/30
2/30
3/30
1/30
2/30
3/30
2/30
4/30
2/30
0/30
1/30
1/30
0/30
Contaminants Detected
VOLATILE ORGAN ICS
Methylene-Chloride
Acetone
2-butanone
c-1,3-dichloropropene
Trichloroethene
4-Methyl-2-Pentanone
Tetrachloroethene
Toluene •
Ethyl benzene
Total Xylenes ..
SEHI-VOLATHE ORGAN I CS
2-methylnaphthalene
Iso'phorqne
Naphthalene
Acenaphthene
Fluorene :.•'•••
Anthracene
Oi-N-Butylphthalate
Fluoranthene ...
Pyrene . .'..••
Butylbenzylphthalate
bis(2-ethylhexyl)phthalate
3,3'-Dichlorobenzidene
Chrysene...
BenzoCa)Anthracene
Di-N-Octylphthaiate
Benzo
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NOrUHWEST
H-13 R-12
SOUTHEAST
n-43 R-38 R-36 P-1 P-«
200
SAND
CLAY
GRAVEL
LIMESTONE
R = RESIDENTIAL WELLS
P = O'APPOLONIA WELLS
NOTE: DISTRIBUTIONS BASED ON DRILLERS REPORTS FOI
RESIDENTIAL WELLS AND WCLL LOGS (APPENDIX I
HORIZONTAL SCALE
0 IOO 2OO 30O
SCALE IN FEET
LINE OF CROSS SECTIONS
SHOWN ON FIGURE 2-7
FIGURE 4
GEOLOGIC SECTIONS OF STUDY AREA
c a CODY
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The windblown deposits/glacial outwash collectively form an
extensive aquifer referred to as the Kankakee aquifer. This
aquifer consists of well sorted, fine to medium grain sand
with minor amounts of fine to medium gravel. The top of the
aquifer is found within 10 feet below ground surface and
ranges from < 10 to about 70 feet in thickness. The bottom
of the aquifer is formed by the glacial till unit which
hydraulically separates the Kankakee aquifer from the
carbonate bedrock aquifer. The Kankakee aquifer is
moderately productive and is a source of small domestic
water supplies in the site area.
The general flow direction of the Kankakee aquifer is
towards the north (Figure 5). The linear groundwater
velocity of the Kankakee aquifer is approximately
192 feet/year.
Contaminant distribution in the aquifer system is limited to
the Kankakee aquifer. Samples collected from residential
bedrock wells in the site area do not indicate contaminants
to be present in the carbonate bedrock aquifer.
Groundwater samples collected from 22 monitoring wells in
the site area indicate the Kankakee aquifer is contaminated
with volatile and semi-volatile organic compounds.
Contamination was found primarily at the water table. This
occurrence can be attributed to the low solubility of the
contaminants identified, as well as the minimal density
differences between the contaminants and the groundwater.
The most frequently detected compounds include: acetone,
total xylenes, toluene, ethylbenzene, 1,2-dichloroethene,
2,4-dimethylphenol and isophorone. Concentrations of the
following contaminants exceeded their established Maximum
Contaminant Levels (MCLs):
° benzene
° ' trichloroethene
° vinyl chloride
° 1,1-dichloroethene
° 1,2-dichloroethane
Several inorganic compounds were detected in groundwater
downgradient of the Cross Brothers Pail Recycling site.
However, the concentrations of these inorganic compounds do
not exceed background conditions.
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WELL SYMBOLS
O . FULLY SCREENED
A SHALLOW
CD INTERMEDIATE
O DEEP
Q PUMPING
• OBSERVATION
SYMBOLS
BASELINE
PROPERTY LINE
IRM CONSTRUCTION LIMITS
UNIMPROVED ROAD
X669.4 . EXISTING SPOT ELEVATION
'—665'- CONTOUR LINE
<£ZH2 EXISTING TREE LINE
--—•~ EXISTING ROAD
X K K FENCE
s~*~*r GROUNOWATER FLOW LINE
0.5 FEET GROUNDWATER CONTOUR INTERVAL
NOTE: SURFACE EUVATIOHS ESTABLISHED IN NOV, oea.
ELEVATIONS REFERENCED TO AH ASSUMED ON-SITE
BENCHMARK OF CG£.4 FEET ABOVE THE NATIONAL
GEODETIC VERTICAL DATUM.
f?5 350
525
SCALE IN FEET
CONTOUR INTERVAL . I FOOT
FIGURE 5
PIEZOMETRIC SURFACE
MARCH, 1986
KETCH r t fOOY
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8
Table 2 presents a summary of the range and frequency of
contaminants detected in groundvater.
Figures 6 and 7 illustrate the distribution of groundwater
contamination within the aquifer.
E. Residential Wells
Twenty-two residential wells were sampled during the HS.
These wells were screened in both the Kankakee and carbonate
bedrock aquifers.
Analysis of the residential well samples identified the
presence of 2 organic compounds and 13 inorganic parameters.
Phenol and DEHP were the 2 organic compounds detected at low
levels. Although the cause and origin of these compounds can
not be confirmed, it is probable that the phenol is a result
of the septic fields present in the area, and the DEHP
originated from the PVC plumbing fixtures used within the
houses.
Maximum Contaminant Levels (MCLs) have been established for
3 out of the 13 inorganic compounds identified, while
Secondary Maximum Contaminant Levels (SMCLs) have been
established for 3 out of the 13 inorganic compounds
identified. MCLs have been established for: arsenic, lead
and nitrate as nitrogen. SMCLs have been established for
iron, manganese and zinc. None of the residential well
samples exceeded the MCLs. Only the concentrations of iron
and manganese exceeded the established SMCLs. As the SMCLs
are established for the aesthetic quality (i.e. taste, odor)
of drinking water, they do not represent a potential health
risk.
Table 2 presents a summary of the range and frequency of
contaminants detected in residential wells.
VT. SUMMARY OF SITE RISKS
A baseline risk assessment was performed for the Cross
Brothers Pail Recycling site as part of the HS. The risk
assessment identified and evaluated potential human health
and environmental threats from the site under the no action
alternative. The no action alternative assumes that no
remedial action (including institutional controls) will
occur at the site.
-------
TABLE 2
RANGE AND FREQUENCY OF CONTAMINANTS DETECTED IN GROUNOUATER
Contaminants Detected
VOLATILE ORGAN ICS
Chloromethane
Vinyl Chloride
Chloroethane
Methylene Chloride
Acetone
1 , 1-dichloroethene
1,1-dichloroethane
1 ,2-dichloroethene (total)
Chloroform
1 ,2-dichloroethane
2-butanone
1,1, 1-trichloroethane
Trichloroethene
Benzene
2-Hexanone
4-Methyl-2-Pentanone
Tetrachloroethene
Toluene
Ethyl benzene
Total Xylenes
SEMI- VOLATILE ORGAN ICS
Benzyl Alcohol
P- me thy I naphthalene
Isophorone
Naphthalene
Di-N-Butylphthalate
bis(2-ethylhexyl)phthalate
Benzoic acid
2-Methylphenol
2,4-Oimethylphenol
4-methylphenol
Pentachlorophenol
INORGANICS
Aluminum
Ant i mony
Arsenic
Barium
Calcium
Chromium
Copper
Iron
Lead
Manganese
Magnesium
Potassium
Sodium
Zinc
Nitrogen- Ammonia
Nitrogen-Total Kjeldahl
Monitoring Well Concentration
Range (ug/kg)
NO - 150 E
NO • 1200
NO - 7 E
NO - 3900
NO - 2600 0
NO - 74 E
NO - 15 0
ND • 1200
. NO -. 3 E
NO - 6
NO - 43
NO - 12
NO - 24
NO • 24
NO - 15
NO - 26.1
NO • 14
NO - 14000
ND - 2300
ND - 14000 0
NO - 12
NO - 3 E
ND - 70
NO - 110
ND - 4 E
NO.- 10 E
NO - 180
NO • 180
NO - 200
NO - 120
ND - 3 E
NO - 1520
. ND - 60 E
NO • 19
NO - 100
16400 - 85700
NO - 29
NO - 12 E
NO - 21000
NO - 48
46.7 - 4680
5610 - 16500
5220 - 24600
5170 - 8220
NO - 48
ND - 4000
80 -.4380
Frequency of
Detection
1/33
6/33
3/33
4/33
13/33
1/33
2/33
12/33
2/33
1/33
1/33
2/33
3/33
11/33
3/33
6/33
4/33
13/33
8/33
8/33
1/33
3/33
13/33
6/33
10/33
2/33
1/33
4/33
9/33
8/33
1/33
3/28
1/28
11/28
14/28
13/13
6/28
1/28
6/28
18/28
15/15
13/13
13/13
13/13
3/13
13/15
15/15
Private Well Concentration
Range (ug/kg)
ND
NO
ND
ND
ND
NO
ND
NO
ND
NO
ND
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
ND
NO
NO
NO : 210
NO
NO
NO
NO
NO
NO - 410
NO
NO - 6
NO
ND
NO
NO - 137
ND - 2300
NO - 14
NO - 1170
HA
NA
HA
NO
30 - 8500
40 - 9920
Frequency of
Detection
0/22
0/22
0/22
0/22 .
0/22
0/22
0/22
0/22
0/22
0/22
0/22
0/22
0/22
0/22
0/22
0/22
0/22 . ..
0/22
0/22
0/22
0/22
0/22
0/22
0/22
0/22
7/22
0/22
0/22
0/22
0/22
0/22
1/22
0/22
2/22
0/22
0/22
0/22
4/22
12/22
11/22
18/22
NA
NA
NA
0/22
22/22
22/22
-------
TABLE . 2 CCOMT'O)
3 - Indicates that the contaminant was also found in the blanks of all samples in which it is detected.
E • Contaminant levels detected are all estimated concentrations.
0 - Diluted sample.
NO - wot detected.
MA - Mot analyzed.
-------
O
A
CD
O
WELL SYMBOLS
FULLY SCREENED
SHALLOW
INTERMEDIATE
DEEP
PUMP ING
OBSERVATION
SYMBOLS
BASELINE
PROPERTY LINE
IRM CONSTRUCTION LIMITS
== UNIMPROVED ROAD
X66S.4 EXISTING SPOT ELEVATION
~665— CONTOUR LINE
CZCC2> EXISTING TREE LINE
mr— EXISTING ROAD
-» i> x - FENCE
110.000-25.000 ppb TOTAL CONCENTRATION
OF VOLATILE ORGANIC
. COMPOUNDS
1.000-10.000 ppb TOTAL CONCENTRATIOK
I OF VOLATILE ORGANIC
COMPOUNDS
SOO-I.OOO ppb TOTAL CONCENTRATION
OF VOLATILE ORGANIC
COMPOUNDS
NOTES
SUAFACC ELEVATIONS ESTABLISHED IN NOV. 1966.
ELEVATIONS REFERENCED TO AN ASSUMED ON SITE
BENCHMARK OF 66*4 FEET ABOVE THE NATIONAL
CCODCTIC VERTICAL DATUM
CONCENTRATIONS Of TOTAL ORGANIC COMPOUNDS ARC
CASED OH ROUND f UtOUNOWATEH CAMPLING DATA
350
5Z5
SCALE IN FEET
CONTOUR INTERVAL = I FOOT
FIGURE 6
GENERALIZED AREAL EXTENT OF GROUND-
WATER CONTAMINATION BY TOTAL VOLA-
TILE ORGANIC COMPOUNDS IN THE
MONITORING WELLS SCREENED AT
THE WATER TABLE
ME I CALF t EOOY
-------
tmmmmmmmm^mmmmm^mm
WELL SYMBOLS
O FULLY SCREENED
& SHALLOW
I—i INTERMEDIATE
O DEEP
® PUMPING
A OBSERVATION
SYMBOLS
BASELINE
PflOPCRTV LINE
IRM CONSTRUCTION LIMITS
UNIMPROVED ROAO
EXISTING SPOT ELEVATION
CONTOUR LINE
EXISTING TREE LINE
EXISTING ROAO
FENCE
IOOO-3000 ppb
IOO-IOOO ppb
10-IOQ ppb.
TOTAL CONCEl
OF VOLATILE
COMPOUNDS
TOTAL CONCENTRATION
OF VOLATILE ORGANIC
COMPOUNDS
~ • CONCENTRATION
TOTAL CONCj
OF VOLATILE
COMPOUNDS
NOTES:
I) CURf ACf OCVATIONJ ESTABLISHED IN NOV.
CLCVATIONS MfCR£NC£0 TO AN ACJUHTO o
aCNCMUAMt Of SStA FEET MOVC THE NATIONAL
CCOPTUC VCKTICAL PATUR
2)COHCETflATIONS OF TOTAL ORCANIC COMPOUNDS
ARE BASED ON ROUND 2 CROUNDWATEA
(AMPLINC DATA.
175
3SO
S2S
SCALE IN FEET
CONTOUR INTERVAL" I FOOT
FIGURE I
GENERALIZED AREAL EXTENT OF GROUNDWATE
CONTAMINATION BY TOTAL VOLATILE ORGANIC
COMPOUNDS IN MONITORING WELLS
SCREENED IN THE MIDDLE OF THE AOUIFIER
Ml I CMC t CODY
-------
The baseline risk assessment included the following:
° Identification of indicator chemicals
0 Toxicity profiles
° Exposure Assessment
° Risk characterization
Identification of Indicator Chemicals
Developing a list of indicator chemicals is the first stage
in the characterization of risk. The selection of indicator
chemicals was designed to identify the "highest risk"
chemicals at the site. Choosing the "highest risk" chemicals
focuses the baseline risk assessment on the chemicals of
greatest concern.
The indicator chemicals for the Cross Brothers site were
selected in two steps. First, the chemicals were ranked
utilizing the scoring system defined in the Superfund Public
Health Evaluation Manual..Final selection was then based on
a more comprehensive review of the physical and chemical
characteristics of the contaminants, frequency of
contaminant detection, distribution of contaminants across
medium and the contaminants tentative rankings. Table 3
presents the groundwater and soil indicator selection
process.
Twelve chemicals were ultimately selected as indicator
chemicals for the Cross Brothers Pail Recycling site.
Table 4 presents the indicator chemicals selected.
Toxicity Profiles
Toxicity profiles were developed for the selected indicator
chemicals. Within each profile chemical and physical
parameters of the compound as well as toxicological data on
the compound are presented. Table 5 presents the physical
and chemical parameters of each indicator chemical, while
Table 6 presents the toxicological data for each indicator
chemical.
Chemical and physical.parameters assist in understanding the
potential fate and transport of a chemical in the
environment, while the toxicological data assists in
defining the potential health effects of a given chemical.
The chemical and physical properties taken under
consideration included:
-------
TABLE 3
GROUNDUATER INOIC/UOR COMPOUND SELECIIOM
COMPOUND
Irichloroethcne
Vinyl Chloride
1,2-Dichloroethene
Toluene
Benzene
Ethylbenzene
Tetrachloroethylene
2-Butanone
1,1,1-Trlchloroe thane
4-Hethyl -2-pcntanone
2,4-Dimethylphenol
Cresol
Xylenes
Isophorone
Naphthalene
Benzyl alcohol
lead
Acetone
Benzole acid
1,1-dichtoroethane
HAX
CONC
(ug/l)
66
1200
1200
UOOO
24
2300
110
43
98
440
200
300
14000
70
110
74
48
2900
180
15
H of limes DetectoC
H Times Analyzed
1/20
4/20
8/20
6/20
2/20
4/20
1/20
1/20
1/20
1/20
7/20
7/20
8/20
6/20
4/20
1/20
19/20
11/20
1/20
1/20
Blank
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
In Blank
OK
OK
Weight
of Evidence
Oral Inhalation
B2
A
B2
0
A
D
B2
D
0
D
D
D
C
D
0
82
0
D
82
A
B2
0
A
0
B2
D
0
D
D
0
C
D
0
82
0
D
B2
Other Notes
Detected in one well in
1987 4 88.
All wells above MCI.
Prevails in wells onslte.
Found at concentrations usually
exceeding 300 ug/l.
Found In C2 and F1. Found at
either end of the site.
Found In both 1987 and
1988.
Hot prevalent throughout
samples.
Detected In 1988 only.
Found In only one well
In 1987 and 1988.
Found In C2 on round 1 (87)
only.
Found In 1987 and 88 where
sampled.
Found In 1987 and 88 where
sampled.
Prevails In GU samples.
Found In 1987 and 88.
Found in 1987 and 88.
Found In 1987 and 88.
Found at concentrations
below HCL in both 1987 and 88.
Found In blank and, therefore,
will not be evaluated
Found at low concentrations.
Found only In one well at low
concentrations
Include
as Indicator
Compound
YES
YES
YES
YES
YES .
YES
YES
NO
NO
NO
NO
YES
YES
YES
YES
NO
NO
NO
NO
NO
-------
TABLE 3 (continued)
GROUHDUATER INDICATOR COMPOUND SELECTION
H
CO
COMPOUND (u
1, 1-dichloroethene
2-hexanone
2 -methyl naphthalene
Bis(2-ethylhexyl)phthalete
Di-n-butylphthalate
Chloromethane
AX n
NC
g/l) *
74
12
15
10
4
150
of Times Detecte
Times Analyzed
1/20
1/20
4/20
2/20
10/20
1/20
J
Blank
OK
OK
ok
OK
OK
OK
Weight
of Evidence Other Notes
Oral Inhalation
C
D
D
. B2
0
C
C
D
0
B2
D
C
Found only In one well at low
concentrations
Found only In one well at low
concentrations
Found at low concentrations
Found at low concentrations,
but throughout the site area.
Found at low concentrations
Found only once
1 nc 1 ude
as Indicator
Compound
NO
NO
NO
YES
NO
NO
Weight of Evidence Groups:
A Human Carcinogen (sufficient evidence from epldemfological studies)
B Probable human carcinogen
81 At least limited evidence of carcinogeniclty to humans
B2 Usually a combination of sufficient evidence in animal and Inadequate evidence In humans
C Possible human carcinogen (limited evidence of carcinogenic!ty in animals in the absence of human date
0 Noncerclnogen
-------
1ABU 3
SOU INDICATOR COMPOUND SELECIIOM
COMPOUND
Trlchloroethene
Toluene
Ethylbenzene
TetrecMoroethylene
2-Butanone
2,4-Dimethylphenol
Cresot
Xylenes
Isophorone
Naphthalene
Butyl benzyl phthalate
8is(2-ethylhexyl)phthalate
Phenol
Pentechlorophenol
Di-n-butytphthelate
Polychlorlnatod biphenyls
1,1, 1- trlchloroe thane
2 -me thy I naphthalene
4-mothyl -2-pentanone
Cnnina-BMC
Benzole acid
MAX a
COHC
(ug/Kg) »
2600
95400
260000
2(00
9300
4300
1200
1520000
215000
126000
6300
25000
560
13000
13000
110000
1
20600
1300
9.8
160
of Times Detecte
Times Analyzed
2/54
6/54
6/54
12/54
3/54
1/54
2/54
14/54
6/54
11/54
11/54
25/54
1/54
1/54
7/54
9/54
1/54
3/54
14/54
1/54
1/54
•d
- Blonk
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
Weight
of Evidence Other Notes
Oral Inhalation
B2
D
0
B2
0
D
0
D
C
0
D
82
D
D
62
D
D
D
B2
D
B2
0
D
B2
0
0
D
D
C
D
0
82
D
D
82
0
D
0
B2
0
Found in 1987 only.
Found at high concentrations
Found in both 1987 and
1988.
Found in both 1987 and 1988.
samples.
Hot found at high concentrations.
Lou frequency of occurance.
low frequency of occurance.
Found In 1987 end 88
at high concentrations.
Found In 1987 and 88
at high concentrations.
Found at many locations.
Found In 1987 and 88.
Found In many samples.
Found In only one sample.
Found In only one sample.
Not found In groundwater samples
Found at high concentrations
Found at low concentrations
Found at low concentrations
Found in only 3 locations
One at 1300, all others < 120
Found at low concentrations
Include
as Indicator
Compound
YES
YES
YES
YES
NO
NO
YES
YES
YES
YES
NO
YES
NO
NO
NO
YES
NO
NO
NO
NO
NO
Weight of Evidence Groups:
A Human Carcinogen (sufficient evidence from epidemiological studies)
B Probable human carcinogen
Bl At least limited evidence of carcinogenic!ty to humans
82 Usu.il I y a combination of sufficient evidence in animal and inadequate evidence in humans
C Possible human carcinogen (limited evidence of carcinogenic!ty in animals in the absence of human data
0 Noncarcinogen
-------
TABLE 4
LIST OF INDICATOR CHEMICALS
Benzene
Bis (2-ethylhexyl) phthalate
Cresols
1,2-dichloroethene
Ethyl benzene
Isophorone
Naphthalene
Polychlorinated biphenyls
Tetrachloroethene
Toluene
Vinyl chloride
Xylenes (total)
-------
TABLE 5
Physical Characteristics of Indicator Compounds (a)
1
1
1
1
| COMPOUND
|1 ,2-Oichloroethene
i
1
| Benzene
i
1
|Bis(2-Ethylhexyl)Phthalate
i
1
(Cresol
i
1
|E thy I benzene
i
1
(Isophorone
1
(Naphthalene
1
(Polychlorinated Biphenyls
i
1
(Tetrachloroethene
i
1
| Toluene
1
(Total Xylenes
1
(Vinyl Chloride
1
1
i . ..........
Koc
(ml/9)
49-59
83
na
500
1100
na
na
530000
364
300
240
57
Molecular
Weight
<9/mol)
96.95
78.12
391
108
106.18
138.21
128
328
165.85
92.15
106
62.5
Log Octanol
Uater Partition
Coefficient
0.48-0.70
2.12
na
1.97
3.15
1.7 (b)
na
6.04
2.6
2.73
3.26
1 .38
Water
Solubil i ty
(n>9/L)
20-25 Oeg. C
3500-6300
1750
0.4
31000
152
12000
34. i
0.031
150
535
198
2760
na - not available
Koc - Organic carbon partition coefficient
(a) Values obtained from the US EPA Superfund Public Health Evaluation Manual
(b) US PHS, 1988. Toxicological profile of Isophorooe.
-------
TABLE 6
TOXOLOGICAl DATA FOR INDICATOR COMPOUNDS
INDICATOR
COMPOUND
Vinyl chloride
1,2-Dichloroethene
Toluene
Benzene
Ethylbeniene
Tetrachloroethylene
Xylene (total)
Polychlorlnated blphenyls
Isophorone
Napthalene
Bis(2-ethylhexyl )phthalate
Cresol
WEIGHT OF
EVIDENCE (a)
A
0
D
A
0
82
D
B2
C
D
82
D
CPF
(mg/Kg/day)-1
2.3 (f)
0.029 (f)
0.051 (b)
7.7 (b)
0.0041 (b)
O.OU (b)
RID
(mg/Kg/day)
0.0013 (1)
0.01 (c)
0.3 (d)
0.0007 (c)
0.1 (e)
0.01 (b)
2 (g)
0.0001 (j)
0.15 (b)
0.4 (b)
0.02 (b)
0.05 (k)
CRITICAL
EFFECT
Liver (1)
Fatty deposit in liver (c)
Hematolbgical parameters (d)
Leukopenia (f)
Liver, Kidney toxlclty (e)
Hepetotoxlclty In mice (b)
Hyperactlvlty, Increased
body weight (g)
Reduced Offsping size (j)
Kidney lesions (h)
Ocular and Internal lesions (k)
Increased liver weight (k)
Reduced body weight (k)
(a) USEPA, 1V88e. Integrated Risk Information System, tetrachloroethene, January, 1989.
(b) USEPA, 1966. Super fund Public Health EvaluatIon Manual Update, July 1988.
Cc) USEPA, 1987e. Health Advisories for 25 Organlcs, March, 1987.
(d) USEPA, 19B9e. Integrated Risk Information System, Toluene, January, 1989.
(e) USEPA, 19896. Integrated Risk Information System, Ethylbenzene, January, 1989.
(f) USEPA, 1988b. Integrated Risk Information System, Benzene, January, 1989.
(g) USEPA, 1988c. Integrated Risk Information System, Xylenes, October, 1988.
(h) USEPA, 1988d. Integrated Risk Information System, Isophorone. June, 1988.
(I) USPHS, 1988. Toxilogicel Profile of Vinyl Chloride. Not an RfD referred to a*
"minimal risk of effects other than cancer for lifetime". See lexicological profile In Appendix N.
(J) USPHS, 1987. Toxlcological Profile for Selected PCBs.
(k) USEPA, 1989. Health Effect* Assessment Summary Tables. March, 1989.
Weight of Evidence Groups:
A Human carcinogen (sufficient evidence from epldemlolbglcal studies)
B Proboble human carcinogen
B1 At (east limited evidence of carcinogen!city to humans
B2 Usually a combination of sufficient evidence In animals and Inadequate
data In humans.
C Possible human carcinogen (limited evidence of carcinogenic!ty In animals In the absence of human data.
0 Noncarclnogen
CPF - Carcinogenic Potency Factor
RFD - Reference Dose
-------
10
0 Organic Carbon Partition Coefficient (Koc)
0 Molecular Weight
° Log Octanol-Water Partition Coefficient (Log Kow)
0 Water Solubility
Cancer Potency Factors (CPFs) and Reference Doses (Rfd) are
the main pieces of toxicological data considered for each
chemical. CPFs are developed by U.S. EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of
(mg/kg-day)""1, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg-day, to provide an upper-
bound estimate of the excess lifetime cancer risk associated
with exposure at that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes underestimation of
the actual cancer risk highly unlikely. CPFs are derived
from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human
extrapolation and uncertainty factors have been applied.
Rfds have been developed by U.S. EPA for indicating the
potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. Rfds, which
are expressed in units of mg/kg-day, are estimates of
lifetime daily exposure levels for humans, including
sensitive individuals. Estimated intakes of chemicals from
environmental media (i.e. the amount of a chemical ingested
from contaminated drinking water) can be compared to the
Rfd. Rfds are derived from human epidemiological studies or
animal studies to which uncertainty factors have been
applied (to account for the use of animal data to predict
effects on humans). These uncertainty factors help ensure
that the Rfds, will not underestimate the potential for
adverse noncarcinogenic effects to occur.
C. Exposure Assessment
In the exposure assessment, the potential exposure pathways
by which humans and wildlife could come into contact with
contaminants from the site were evaluated. Exposure pathways
were considered for both current and future land use
conditions.
A complete exposure pathway has five elements: a contaminant
source, a mechanism for contaminant release, an
environmental transport medium, an exposure point and a
route of exposure.
-------
11
An initial screening of each potential pathway was performed
to identify the routes likely to present the largest
exposures and greatest health impacts. This screening
identified two primary exposure pathways:
° Ingestion of contaminated groundwater; and
° Ingestion of contaminated soil.
Figure 8 presents the potential exposure pathways considered
for the the Cross Brothers Pail Recycling site. Table 7
presents the results of the initial screening of potential
exposure pathways.
Risk Characterization
This portion of the risk assessment evaluated the various
exposure pathways and identified, by medium, the potential
risks to human health and the environment. The risk
characterization for the Cross Brothers Pail Recycling site
was presented in three parts: a comparison of contaminant
levels with standards or criteria (i.e. MCLs), a comparison
of estimated human dose with the Rfds and a calculation of
increased lifetime cancer risk.
Increased lifetime cancer risks are determined by
multiplying the intake level with the CPF. These risks are
probabilities that are generally expressed in scientific
notation (e.g. 1 x 10~6 or 1E-6). An increased lifetime
cancer risk of 1 x 10~6 indicates that, as a plausible upper
bound, an individual has a 1 in 1 million chance of
developing cancer as a result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific
exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
ratio (the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the
contaminant's reference dose). By adding the hazard ratio
for all contaminants within a medium or across all media to
which a population may reasonably be exposed, the Hazard
Index (HI) can be generated. The HI provides a useful
reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or
across media.
-------
CONTAMINATED
GROUNDWATER
Rainwater Infiltration
CONTAMINATED
SOIL
DRINKING
WATER
IRRIGATION
DISCHARGE
TO SURFACE WATER
Surface Water
Runoff
Exposure
By Inhalation
Of Volatilized
Contaminants
Dermal Contact
With Contaminated
Water
Exposure
By Inhalation
Of Volatilized
Contaminants
CONTAMINATED
SURFACE
WATER
AERIAL
DISPERSION OF
CONTAMINANTS
Inhalation of inhalation of
Chemicals Contaminants
following on Dusts
Volatilization
DIRECT CONTACT
WITH CONTAMINATED
SOILS
INGESTION OF
SOIL
Ingestion Of
Contaminants
Following Uptake
By Plants
Direct Contact
with Surface
Water/lngestion
of Surface Water
Ingestion of
Fish
Absorption of
Contaminants
Following Dermal
Contact with Skin.
Ingestion of Game
Following Exposure
of Game to Contaminants
in Soil.
INGESTION OF
GROUNDWATER
Potential
Figure 8 -EXPOSURE PATHWAYS
-------
TABLE
Potential Exposure
Route
Contaminated groundwater:
Drinking water and
water used for domestic
purposes
Irrigation
Ingestion of
contaminated foods
Initial Screening of Exposure Pathways
Potential Factors
Contaminant Source Influencing Exposure
Contaminated grounduater There are residential wells located near the site, and contamination of the
groundwater has been documented. This exposure pathway will be evaluted
quantitatively using an ingestion rate of two liters of water a day.
Inhalation and direct contact dose calculations will not be performed, however
the two pathways will be discussed qualitatively.
Detailed
Evaluation
Yes
Contaminated groundwater
Inhalation of
volatile organics
Contaminated Soil:
Ingestion
Direct contact
Contaminated
Surface soil
Inhalation of dust
Inhalation of
volatilized chemicals
Surface water
Surface water
Contaminated game
Contaminated game
Where contaminated groundwater is used to irrigate crops, there is a potential
for uptake of contaminants by plants. Much of the surrounding area is cropland.
Irrigation wells are installed in deep bedrocks, and since the data collected
shows greatest contamination' in wells screened at the water table interface, it
is not expected that high concentrations of contaminants would be detected in a
deep bedrock aquifer. In addition, groundwater cleanup based on protection of
the aquifer as a drinking water supply is expected to be protective of use for
irrigation.
No
Contaminants may volatilize during irrigation.
evaluating, see previous discussion.
Hot included for quantitative
Factors influencing the extent of ingestion of contaminated
soil include the accessability of the site, nearby population, and the
extent of ground cover. Since there is no fence or other barrier, the
site is active, and people are on site regularly, this pathway will be
considered for a detailed evaluation.
Exposure to contaminants In soil by dermal contact is dependant on the above
mentioned factors and the potential for absorption through the skin. For
volatile organic compounds ft is often assumed that 10-Z5X of the contaminants
in soil on skin Is absorbed (Ryan, 1987). This exposure pathway is likely
to present a smaller impact than the ingestion pathways and will not
be evaluated quantitatively.
Dust dispersion beyond local tree cover Is expected to be limited. In addition,
exposure to soil as dust is expected to be small compared to exposure to soil
by ingestion, end the inhalation of dust exposure Is* not expected to greatly
impact this baseline assessment.
Inhalation of contaminants following volatilization from soil is expected
to represent a minimal exposure when compared to exposure by ingestion of soil.
It will not be evaluated in detail. .
3 = 3333s3=333333333333 = 333333z = 3333S3*3333S333333a3SS3ss33S33S3333ss333ES3Be333se3=:
Migration of contaminants to the nearest natural surface water, the Kankakee
River, Is expected to be minimal. This is due to the distance from the site to
the river and expected decreases in contaminant concentration from interactions
in the environment such as dilution, adsorption, and biodegradation.
Drainage ditphes In the area, used to collect runoff, are often dry.
Exposure duration/ frequency Is not expected to be large enough to include a
detailed evaluation.
3 = = 3333333 = 33333 = = 3 = 3S33=-333SS = 33333 = 33333S3S3B3SS3 = = 33-S3rE3333333S33SSSS33333S33
While hunting does occur onslte, it seems unlikely that meat
from hunting makes up a large portion of an individuals diet.
The exposure pathway is not expected to result as large in an exposure
as other pathways and, therefore, will not be evaluated in detail.
No
3333S
Yes
No
No
No
No
No
No
-------
12
1. Groundvater Risk Characterization
As groundwater is currently being used by area residents as
a drinking water source, the ingestion of contaminated
groundwater is a probable exposure pathway. Although
sampling of residential wells in the vicinity of the site do
not indicate the presence of site related contaminants,
contamination of these wells, in the future, is likely given
current groundwater flow conditions. In addition,
groundwater is an environmental resource which has been
contaminated as a result of the disposal practices occurring
during the site's operation.
Concentrations of the following groundwater contaminants
currently exceed their established MCLs: benzene,
trichloroethene, vinyl chloride, 1,1-dichloroethene and
1,2-dichloroethane. The MCLs are legally enforceable
standards of the maximum permissible levels of contaminants
allowed in a drinking water used by the general public.
These standards reflect the best achievable levels
considering monitoring capabilities, cost of treatment,
available technology and health effects.
In addition, a Hazard Index (HI) and the cumulative
increased lifetime cancer risk was calculated for the
ingestion of groundwater. A maximum and representative value
was calculated for each of the above parameters. The maximum
and representative HI for groundwater are 33.49 and 2.59,
respectively. The maximum and representative cumulative
increased lifetime cancer risk values for groundwater are
7.9 x 10~2 and 4.2 x 10~3, respectively.
The concentration of vinyl chloride is a significant
contributor to the calculation of both the maximum and
representative HI and .cumulative increased lifetime cancer
risk. In addition, the following chemicals are at
concentrations of concern due to either their exceedance of
the MCL or their calculated hazard ratio or increased
lifetime cancer risk: 1,1-dichloroethene, toluene, benzene,
1,2-dichloroethene, 1,2-dichloroethane, and
tetrachloroethene.
Table 8 presents a summary of the groundwater risk
characterization.
-------
TABLE 6
Grounduater Risk Characterization
1 v- .-"•
1 • ''--.'
1 INDICATOR
| CHEMICAL
i : ' • •-'. "• ' '
:
(Vinyl chloride
(1,2-Dichloroethene
(Toluene
(Benzene
(Ethylbenzcne
(Tetrachloroethene
(Xylene (total)
(Polychlorinated biphenyls
|lsophorone
(Naphthalene
|Bis(2-Ethylhexyl)Phthaiete
jcresol
i
1
1
1
CONCENTRATION
MAXIMUM REPRESENTATIVE
(mg/l)
1.2
1.2
14
0.024
2.3
0.11
14
ND
0.07
0.11
0.01
0.3
DOSE
MAXIMUM REPRESENTATIVE
(mg/l) (mg/Kg/day) (mg/Kg/day)
0.063
0.075
0.5714
0.019
0.2245
0.019
1.434
ND
0.012
0.018
0.005
0.021
0.0343
0.0343
0.4000
0.0007
0.0657
0.0031
0.4000
—
0.0020
0.0031
0.0003
0.0086
0.001B
0.0021
0.0163
0.0005
0.0064
0.0005
0.0410
...
0.0003
0.0005
0.0001
0.0006
INCREASED
LIFETIME
HAZARD RATIO CANCER RISK
RfD CPF MAXIMUM REPRESENTATIVE MAXIMUM REPRESENTATIVE
(mg/Kg/day) (mg/Kg/day)-1
0.0013
0.01
0.3
0.0007
0.1
0.01
2
0.0001
0.15
0.4
0.02
0.05
TOTAL (HAZARD
2.3
0.029
0.051
7.7
0.0041
0.014
INDEX) -
26.37
3.43
1.33
0.98
0.66
0.31
0.20
—
0.01
0.01
0.01
0.17
33.49
1.38
0.21
0.05
0.78
0.06
0.05
0.02
—
0.00
0.00
0.01
0.01
2.59
7.89E-02
...
...
1.99E-05
...
1.60E-04
...
—
8.20E-06
...
4.00E-06
...
7.90E-02
4
1
2
1
2
4
.14E-03
...
...
.57E-05
...
.77E-05
...
—
.41E-06
...
.OOE-06
...
.19E-03
NO: Not detected
RID - Reference Dose
CPF • Carcinogenic Potency Factor
EQUATIONS:
Dosages were calculated as follows:
(Concentration (mg/D) x (2 Liters.of water per day)
Dose (mg/Kg/day)
Hazard Ratio (un'tless) =
(70 Kg body weight)
(Calculated dose (mg/Kg/day))
(Reference dose (mg/Kg/day))
Hazard Index
Increased L
Cancer Ris
Sum of Hazard Ratios
,me
less) = (Dose (mg/Kg/day)) x (Cancer Potency Factor (mg/Kg/day)|
-------
13
and Subsurface Soil Risk Characterization
At this time, no standards have been established by U.S. EPA
or IEPA for soils. U.S. EPA does however, have guidance
relating to the cleanup of PCB spills onto soils. This
guidance sets a 10 ppm requirement for decontaminating PCB
spills in nonrestricted access areas (40 CFR 761. 125 (c) (4) ) .
It is considered appropriate to compare the concentrations
of PCBs found in the soils at the Cross Brothers Pail
Recycling site to this requirement.
The concentrations of PCBs in surface soils do not exceed
the 10 ppm cleanup requirement of U.S. EPA's PCB spill
guidance. In addition, the concentrations of PCBs in
subsurface soils, with the exception of one location, do not
exceed the 10 ppm cleanup requirement of U.S. EPA's PCB
spill guidance. One sampling location in the south-central
portion of the site had PCBs at 110 ppm (Figure 9) .
In calculating the HI and the cumulative increased lifetime.
cancer risk for the soils at the Cross Brothers Pail
Recycling site, the representative values were calculated
using an average of the surface soils concentrations. The
maximum value was calculated however, using the maximum soil
concentrations found in surface and subsurface soils. As
such the representative HI and cumulative increased lifetime
cancer risk is felt to represent the potential exposure
resulting from trespassing or working on the site, while the
maximum HI and increased lifetime cancer risk reflects a
conservative, worst-case exposure scenario. The maximum and
representative HI for the soils are 1.6 and .006
respectively. The maximum and representative cumulative
increased lifetime cancer risk for the soils are 1.21 x 10~3
and 2.45 x 10"6.
A review of the hazard ratios and increased lifetime cancer
risk for each indicator chemical indicates that PCBs are the
primary contributor to the HI and cumulative increased
lifetime cancer risks for soils. As such, the one sampling
location with 110 ppm of PCBs present in the south-central
portion of the site is responsible for the calculated
maximum HI and cumulative increased lifetime cancer risk.
Although volatile and semi-volatile organic compounds were
detected in surface and subsurface soils, the hazard ratios
and increased lifetime cancer risk values for the various
indicator chemicals representing these groups of compounds
indicate, volatile and semi-volatile organic compounds
present a negligible amount of risk to human health from
direct contact. The presence of these compounds in the soils
due to their physical and chemical properties do, however,
present a continual risk to groundwater.
-------
WELL SYMBOLS
O FULLY SCREENED
A SHALLOW
C3 INTERMEDIATE
O DEEP
® PUMPINO
• OBSERVATION
SYMBOLS
BASELINE
PROPERTY UNE
IRM CONSTRUCTION LIMITS
===== UNIMPROVED ROAO
. X66S.4 EXISTING SPOT ELEVATION
^665 v- CONTOUR LINE
£ZZ£) EXISTING TREE LINE
= = = =•' EXISTING ROAD
XX-K- FENCE
BIIJL BORING LOCATION
PCB soil area
NOTE! SURFACE ELEVATIONS ESTABLISHED IN MOV. 1*88.
ELEVATIONS REFERENCED TO AN ASSUMED OH-SITE
BENCHMARK OF CCC.4 FEET ABOVE THE NATIONAL
GEODETIC VERTICAL DATUM.
176
350
525
SCALE IN FEET
CONTOUR INTERVAL • I FOOT
FIGURE 9
Localized PCB Soil
Area
-------
14
Table 9 presents a summary of the soil risk
characterization.
3 •
The purpose of this section is to present a qualitative
assessment of the site's potential impact on the existing
habitats of endangered species or sensitive environments in
the site area. The proximity of the site to a sensitive
environment or critical habitat along with the site's source
type and potential migration pathways were evaluated and to
determine the potential adverse effects on such habitats.
Several Federally endangered species are known to have
migratory paths over Kankakee County . These species
include: the Indiana bat, the American Peregrine, the Arctic
Peregrine Falcon and the Kirtlands Warbler. In addition, the
Higgins Eye Tearly Mussel is known to exist in the Kankakee
River.
The Kankakee River is the critical habitat to the survival
of the Kankakee Mallow. The Kankakee Mallow is currently a
proposed Federally endangered species.
The site's effect on the aforementioned endangered species
and critical habitat is expected to be minimal. Although
migration of the birds and bat across the site area is
possible, exposure would occur for a very short-term. A
chronic or long-term exposure is unlikely as none of the
endangered birds or the Indiana bat are known to nest near
the site.
The Kankakee River is 4.5 miles from the site. Current
groundwater information indicates that the groundwater
contaminant plume is not impacting the Kankakee River area.
As such, the Higgins Eye Tearly Mussel and the Kankakee
Mallow are not expected to be impacted by the site.
•
VTI. DESCRIPTION OF ALTERNATIVES
During the Feasibility Study (FS) , the U.S. EPA and IEPA
identified and evaluated a list of alternatives that could
be used to address the threats and/or potential threats
identified at the site. U.S. EPA and IEPA narrowed the list
of alternatives based on their effectiveness (i.e.
protection of human health and/or the environment and
reliability), implementability (i.e. technical feasibility
and compliance with identified state and federal
regulations) and relative costs (i.e. capital and operation
and maintenance) .
-------
TABLE 9
Soil Risk Characterization
'". INDICATOR
CHEMICAL
Vinyl chloride
1,2-Dichloroethene .
loluene
Benzene
Ethylbenzene
Tetrachloroethene
Xylene (total)
Polychlorinated biphenyls
Isophorone
Naphthalene
Bis(2-ethylhexyl)phthelate
Cresol . .
CONCENTRATION . .DOSE.
MAXIMUM REPRESENTATIVE MAXIMUM REPRESENTATIVE.
(mg/Kg) (mg/Kg) (mg/Kg/day) (mg/Kg/day)
ND
NO
95.4
ND
260
2:4
1520
110
215
126
25
1.2
NO
NO
5.28
NO
2.6
0.287
63.4
0.208
10.797
7.325
4.094
0.0001
1.36E-04
3.71E-04
3.43E-06
2.17E-03
1.57E-04
3.07E-04
1.80E-04
3.57E-05
1.71E-06
7
3
4
9
2
1
1
5
1
.54E-06 '.
.71E-06
.10E-07
.06E-05
.97E-07
.54E-05
.05E-05
.85E-06
.43E-10
RfD CRF
(mg/Kg/day) (mg/Kg/day)- 1
0.0013
0.01
0.3 .
. 0.0007
: 0.1.
0.01
2
0.0001
0.15
0.4
0.002
0.05
TOTAL (HAZARD
2-3
0.029
0.051
7.7
0.0041
0.014
INDEX) •
INCREASED.
LIFETIME
HAZARD RATIO CANCER RISK
MAXIMUM REPRESENTATIVE MAXIMUM REPRESENTATIVE
0.00045
.0.00371
0.00034
0.00109
1.57143
0.00205
0.00045
0.01786
0.00003
1.597414
0.00003
0.00004 .
0.00004
0.00005
0.00297
0.00010
0.00003
0.00292
0.00000
0.006173
..;;;
....
1.75E-07
—
1.21E-03
1.26E-06
...
5.00E-07
...
1.21E-03
-•-
2.09E-08
...
2.29E-06
6.32E-08
...
8.19E-08
...
2.45E-06
ND: NOT DETECTED
RfD - Reference Dose
CPF • Cercinog'enic Potency Factor
EQUATIONS:
Dosages were calculated as follows:
(Concentration (mg/Kg)) x (0.0001 Kilograms of contaminated soil per day)
Dose (nig/Kg/day) •»
(70 Kg body weight)
(Celeuleted dose (mg/Kg/day))
Haihrd Ratio (unitless) »
: (Reference dose (mg/Kg/day))
Hazard Index = Sun of Hazard Ratios
Increased Li fetime
Cancer Risk (unitless) = (Dose (mg/Kg/day)) x (Cancer Potency Factor (mg/Kg/day)-1)
-------
15
Four remedial alternatives were developed for the Cross
Brothers site. These alternatives progress from addressing
the principal threat of groundwater contamination; to more
complex alternatives addressing both the threat of
groundwater contamination and surface/subsurface soils as a
source for groundwater contamination. In addition, two
options addressing the small, volume of PCB contaminated
soils were developed. These alternatives and options are
described below.
ALTERNATIVE 1 - NO ACTION
Estimated Total Remedial Cost: $ 0
Estimated Remedial Action Time: 0
The Superfund program requires that the "no action"
alternative be considered at every site. Under this
alternative, U.S. EPA and IEPA would take no further action
at the site to control the sources of contamination. All
wastes, routes of off-site contaminant migration (i.e.
groundwater), and human and environmental exposure pathways
will remain unchanged. This alternative would not reduce the
threats to human health, or the environment identified at the
site. ._'•';'•.•.- • ' " .' • ;" - '..
ALTERNATIVE 2 - PUMP AND TREAT/SOIL FLUSHING
Estimated Total Remedial Cost: $ 1,729,400 present worth
Estimated Total Capital Costs: $ 888,708
Estimated Annual 0 & M Costs : $ 58,130
Estimated Remedial Action Time: 15 years
Alternative 2 includes the following major components:
access restrictions, a groundwater collection system, an on-
site groundwater treatment system and a soil flushing
system. Figure 10 shows the major components of
Alternative 2.
Groundwater would first be removed from the aquifer with a
series of pumping wells. The collected groundwater is then
transported through piping to the on-site treatment system
for treatment. Subsequent to treatment the groundwater will
meet the following 2 standards:
° Currently promulgated MCLs; and
° A cumulative lifetime excess cancer risk not
exceeding 10"6 and a Hazard Index < 1.
-------
;, f'I'7~'vvT'" S V /'-• -f
WELL SYMBOLS
O FULLY SCREENED
A SHALLOW
CD INTERMEDIATE
O DEEP
9 PUMPING
O OBSERVATION
• PROPOSED PUMPING
SYMBOLS
X665.4
BASELINE
PROPERTY LINE
IRM CONSTRUCTION LIMITS
UNIMPROVED ROAD
EXISTING SPOT ELEVATION
CONTOUR LlriE
EXISTING TREE LINE
EXISTING ROAD
FENCE
INTERMITTENT STREAM
****** PROPOSED FENCE
BEHM
NOTE!sJiftf ACE ELEVATIONS ESTABLISHED IN HOV, isee.
ELEVATIONS REFERENCED TO AN ASSUMED ON-SITC
BENCHMARK OF CES.4 FEET ABOVE THE RATIONAL
GEODETIC VERTICAL PATUH.
200
400
600
SCALE IN FEET
CONTOUR INTERVAL"« I FOOT
.FIGURE 10
ALTERNATIVE 2 LAYOUT
-------
16
The treated groundwater will then be applied with a spray
irrigation system to the 3.5 acre area of heavy soil
contamination in the center of the site (Figure 10). Six
inches of gravel will be laid in this area to assist in
distributing the treated groundwater evenly across the area.
The water will then flush through the soils, leaching
contaminants from the soil and into the groundwater where
they will be captured and treated. This type of soil .
flushing operation should reduce the contaminant levels
present in the soils to negligible levels.
A groundwater monitoring program will be implemented to
assess changes in aquifer conditions during and after the
remedial activities, and to evaluate the effectiveness of '
the groundwater collection system. Access restrictions will
include fencing the site and a deed notification. . .
ALTERNATIVE 3 - PUMP AND TREAT/SOIL COVER :
Estimated Total Remedial Cost 3A: $ 1,956,700 present worth
Estimated Total Capital Costs 3A: $ 1,214,541
Esitmated Annual O & M Costs 3A : $ 59,235
Estimated Total Remedial Cost 3B: $ 1,872,800 present worth
Estimated Total Capital Costs 3B: $ 1,006,680
Estimated Annual O & M Costs 3B : $ 72,170
Estimated Remedial Action Time 3A: 15 years
3B: 11 years
Alternative 3A includes the same major components as
Alternative 2. Alternative 3A will however, include a 6 inch
vegetative cover. Initially, the cover will be placed over
that portion of the site not subject to soil flushing. The
cover will however be extended to include that portion of
the site subject to soil flushing upon completion of the
soil flushing activities. Figure 11 illustrates the extent
of the vegetative cover.
Alternative 3B includes most of the same major components as
Alternative 3A. Alternative 3B will use the same access
restrictions, 6 inch vegetative cover, groundwater
collection system and groundwater treatment system described
for Alternative 3A. In Alternative 3B however, the treated
groundwater will be reinjected back into the aquifer and the
6 inch vegetative cover will be placed over the entire site
area (10 acres) initially.
-------
WELL SYMBOLS
O FULLY SCREENED
A SHALLOW
CD INTERMEDIATE
O DEEP.
(S PUMPING
9 OBSERVATION
SYMBOLS
BASELINE
PROPERTY LINE
IRM CONSTRUCTION LIMITS
== UNIMPROVED ROAD
X665.4 EXISTING SPOT ELEVATION
<%665A- CONTOUR LltfE
C^333 EXISTING TREE LIN£
---- EXISTING ROAD
-X X X- FENCE
—-..__ INTERMITTENT STREAM
****** PROPOSED FENCE
BEHM
FLUSHING AREA
SOIL COVER '
100 ZOO 300
SCALE IN FEET
CONTOUR INTERVAL*(FOOT
FIGURE 11
Extent of Vegetative Cover
-------
17
Estimated Total Remedial Cost 4A:
Estimated Total Capital Costs 4A:
Estimated Annual O & M Costs 4A :
Estimated Total Remedial Cost 4B:
Estimated Total Capital Costs 4B:
Estimated Annual O 4 M costs 4B :
$ 2,285,000 present worth
$ 1,371,268
$ 74,378
$ 2,997,300 present worth
$ 1,946,575
$ 77,254
Estimated Remedial Action Time 4A: 10 years
4B: 10 years
Alternative 4A utilizes the same major process options as
Alternative 3B, with the exception that a multi-layer cap is
installed rather than a vegetative cover. The multi-layer
cap would be installed, over the 3.5 acre area of heavy soil
contamination. The multi-layer cap will prevent rainwater
from infiltrating through the area, thereby precluding
contaminant leaching into the groundwater.
Alternative 4B is identical to Alternative 4A except the
multi-layer cap would be installed over the entire site
area (10 acres).
OPTIONS FOR PCS CONTAMINATED SUBSURFACE SOILS
Both options require resampling of the PCB soil area
initially, to confirm the presence of a PCB source in the
area. If these samples indicate soils to be contaminated
above 10 ppm then the other activities (i.e. excavation,
incineration, etc.) described in either option would be
conducted.
OPTION 1 - PCB SOILS REMOVAL AND INCINERATION
Estimated Total Remedial Cost:
$ 17,700
Option 1 includes excavation of an estimated 5 yd3 of soils
contaminated above a concentration of 10 ppm PCBs. This area
will initially be resampled to determine the exact volume of
PCB contaminated soils to be excavated. Under this option
the excavated soils will be drummed and transported to an
off-site TSCA approved incinerator for thermal treatment.
OPTION 2 - PCB SOILS REMOVAL AND LANDFILLING
Estimated Total Remedial Cost:
$ 8,600
Option 2 is similar to Option 1 except the excavated soils
would be transported in bulk to a TSCA approved landfill for
land disposal.. . ...
-------
18
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives developed during the Cross
Brothers Pail Recycling site FS were evaluated by U.S. EPA
and IEPA using the following 9 criteria. The advantages
and disadvantages of each alternative were then compared to
identify the alternative providing the best balance among
these 9 criteria.
1. Overall Protection of Human Health and the Environment
addresses whether or not an alternative provides adequate
protection and describes how risks are eliminated, reduced
or controlled through treatment and engineering or
institutional controls. .
2. Compliance with Applicable or Relevent and Appropriate
Requirements (ARARs) addresses whether or not an alternative
will meet all of the applicable or relevant and appropriate
requirements or provide grounds for invoking a waiver.
3. Long-term Effectiveness and Permanence refers to the
ability o-f an alternative to maintain reliable protection, of
human health and the environment, over time, once cleanup
objectives have been met.
4. Reduction of Toxicity, Mobility or Volume is the
anticipated performance of the treatment technologies an
alternative may employ.
5. Short-term Effectiveness involves the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed during
the construction and implementation period until cleanup
objectives are achieved.
6. Implementability is the technical and administrative
feasibility of an alternative, including the availability of
goods and services needed to implement the solution.
7. Cost includes capital costs, as well as operation and
maintenance costs.
8. Agency.Acceptance indicates whether, based on its
review of the HS/FS and Proposed Plan, U.S. EPA and IEPA
agree on the preferred alternative.
9. Community Acceptance indicates the public support of a
given alternative. This criteria is discussed in the
Responsiveness Summary.
-------
19
A matrix summarizing the comparative analysis of
alternatives on a criteria by criteria basis is presented in
Table 10.
The following discussion expounds on the information
provided in Table 10.
A. Overall Protection of Human Health and the Environment
All of the remedial alternatives considered for the Cross
Brothers Pail Recycling site, except for the no action
alternative, are protective of human health and the
environment by eliminating, reducing or controlling risks
through various combinations of treatment and engineering
controls and/or institutional controls. As the no action
alternative does not provide protection of human health and
the environment, it is not eligible for selection and shall
not be discussed further in this document.
All of the alternatives reduce the risks associated with
groundwater contamination by pumping and treating
contaminated groundwater. A groundwater monitoring program
will also be implemented to evaluate the effectiveness of
the groundwater remediation activities. In addition, all of
the alternatives utilize access restrictions (i.e. fence and
deed notification).
Alternative 3A does, however, include the removal of soil
contaminants through soil flushing. The treated groundwater
will be utilized as the flushing agent. In addition, a
6 inch vegetative cover will be placed over the non-flushed
areas to stablize the soils on-site. Alternative 2 includes
the same basic remedial components as Alternative 3A, less
the vegetative soil cover.
Alternative 3B does not include the soil flushing system.
Treated groundwater would be returned to the aquifer through
a series of re-injection wells. Alternative 3B also includes
a 6 inch vege'tative cover over the entire site area. The use
of this cover type will result in passive flushing of the
soils through natural infiltration.
Alternative 4A is very similar to Alternative 3B. The
treated groundwater will be re-injected into the aquifer.
Rather than a 6 inch vegetative cover, Alternative 4A
utilizes a small multi-layer cap over the most heavily
contaminated soil area to prevent the infiltration of
precipitation. Alternative 4B is identical to Alternative 4A
except the multi-layer cap will cover the entire site area.
-------
TABLE 10
COMPARISON OF ALTERNATIVES SUMMARY
ALTERNATIVE
SHORT-URN EFFECTIVENESS
LONG-TERM EFFECTIVENESS
AND PERMANENCE
REDUC1IOM OF TOXICITT.
HOBHIIT AND VOLUME
IMPIEMENTABILTY
COSI
(10TAI PRESENT
WORTH)
ARARS COMPLIANCE
OVERALL PROTECTION
OF HUMAN HEALTH
AND THE ENVIRONMENT
Alternative i
Soil flushing
Pirp I Treat
15 year remedial action time;
toll flushing causes a
temporary Increase of
contaminant nobility.
Soil flushing yields excellent
long-term effectiveness and •
permanance.
Excellent reduction of toxlclty,
mobility and volume of the
contaminants.
Highly Implementable.
Meets or
exceeds ARARs.
Yes
Alltrnativc }a
Soil Flushing with
Punp and Treat and
Soil Cover
IS year remedial action time;
soil flushing causes a
temporary Increase of
contaminant mobility.
Soil flushing yields excellent
long-tern effectiveness and
permanance. The use of • toll
cover provides «n added level of
protection.
Excellent reduction of toxlclty,
nobility and volume of the
contaminants.
Highly Impltmntable.
*1,956,700 .
Meets or
exceeds ARARs.
Yes
Alternaiive 3b
Purp and Treat
Soil Cover
It year remedial action time
required to meet remedial
action goals.
Ccnparltlvely lou level of
long-tern *ffectlvenesa due to no
action on contaminated lolls.
Reduction of toxlclty and volume
of grounduater contaminants only.
Highly Implemenlable.
tI,872.800
Meets or
exceeds ARARs.
Tes
Alternative (a
Pimp i Treat
Partial Multi-layer Cap
10 year remedial action time;
dust control measures
necessary to prevent
excessive dust emissions from
cap construction.
Good long-ten* effectiveness from
small rultl-layer cap.
Reduction of toxlclty and volume
of grounduater contaminants and
reduction of mobility of soil
contaminants. .' •
Highly Implementable.
»?,285.000 Meets or
exceeds ARA2s.
Tes
Alternative 'b
Pimp t Treat
Full Multi-layer Cap
10 year remedial action time;
dust control measures
necessary to prevent
excessive dust emissions from
cap construction.
Good long-tern effectiveness fro
large multi-layer cap.
Reduction of toxlclty and volune
of grounduater contanlnmts and
reduction of mobility of soil
contaminants.
Highly Imptementable, but the
large slie of the cap causes
lengthy construction period.
12.797,300 Meets or
exceeds ARARs.
Option 1
PCS Soil Removal
and Incineration
Option ?
PCS Soil Removal
\
and land Disposal
Short-term risk of exposure
by uncovering deep PCB
contamination ulthln the soil.
Short-term risk of exposure
by uncovering deep PCB .
contamination ulthln the soil.
Excellent long-tens effectiveness
from removal and off-site
Incineration.
Adequate long-term effectiveness
from removal and off-site
landfllllng of PCB-eontamlnated-
soils, but landfllllng cannot.be
considered • permanent solution.
Excellent reduction of toxlclty,
mobility, and volume of PC8
contaminants In the soil matrix.
Reduction of contaminant mobility
.only through off-site TSCA
landfllllng.
Good Implemenlablllty. but 1T7.700
treatment of large quantities
of soil ulll be subject to . .' •
Incinerator capacity
constraints.
Good lirplementabllity under 16,600
current regulations.
Meets or
'exceeds ARARs.
Compliant with
current ARARs,
but'future land
ban regulations
may prohibit the
landlilllng of
PCBs.
• . Yes
Tes
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20
PCB Soil Removal - Option 1 requires removal of the
localized PCB-contaminated soil area and incineration at a
TSCA approved incinerator. PCB Soil Removal - Option 2
requires removal of the localized PCB-contaminated soil area
and landfilling of the soils at a TSCA approved landfill.
B. ARARs Compliance
SARA requires that remedial actions meet legally applicable
or relevant and appropriate requirements (ARARs) of other
environmental laws. These laws may include: the Toxic
Substances Control Act, the Safe Drinking Water Act, the
Clean Air Act, the Clean Water Act, the Resource
Conservation and Recovery Act, and any state law which has
stricter requirements than the corresponding federal law.
A "legally applicable" requirement is one which would
legally apply to the response action if that action were not
taken pursuant to Sections 104, 106 or 122 of CERCLA. A
"relevant and appropriate" requirement is one that, while
not "applicable", is designed.to apply to problems
sufficiently similar that their application is appropriate.
All of the alternatives proposed for the Cross Brothers Pail
Recycling site meet or exceed ARARs.
C. Long-term Effectiveness and Permanence
The alternatives considered for the Cross Brothers Pail
Recycling site vary in their ability to provide long-term
effectiveness and permanence.
Each of the alternatives considered includes a groundwater
pump and treat component. By eliminating the contaminants
present in groundwater each of the alternatives achieves a
certain degree of long-term effectiveness and permanence.
The difference between the alternatives with regard to
long-term effectiveness and permanence is directly related
to how each alternative addresses soil contamination at the
site.. . ' :
Alternative 3A provides the greatest degree of permanence.
The heavily contaminated soil area is flushed, removing any
leachable materials from the soil. A 6 inch vegetative
cover is placed over the site's non-flushed area, stabilizing
the soils on-site. Alternative 2 follows Alternative 3A in
degree of permanence. Alternative 2 does not include the
6 inch vegetative cover. As such, soils in the non-flushed
areas will be subject to wind and water erosion.
Alternative 3B, which includes pump and treat with re-
injection of the treated groundwater, provides the least
amount of long-term effectiveness and permanence.
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21
Alternative 3B does not actively address the contamination
in the soil. The presence of only a 6 inch vegetative cover
will alloy passive flushing of the soil contaminants. Thus
recontamination of the groundvater due to leaching of the
contaminated soils is likely. Alternatives 4A and 4B, while
not removing the contaminants present in the soil, do offer
greater long-term effectiveness than Alternative 3B by
containing the contaminants. Both of these alternatives
include a multi-layer cap that will limit the infiltration
of precipitation through the soils and preclude the leaching
of contaminants into the1 grpundwater.
The long-term effectiveness and permanence differ greatly
with respect to the PCB Soil Removal Options. Option 1,
removal and incineration/ provides far greater permanence
than Option 2 - removal and landfilling. Under Option 1, the
•PCBs present in the soils will be permanently destroyed.
Option 2, however, only displaces the contamination to a new
location.
Reduction of Toxicity. Mobility or Volume fchT-ough Treatment
All of the alternatives include a component which reduces
the toxicity, mobility and volume of the contaminants
present in the groundwater at the site through treatment.
The difference between alternatives is most noted with
regard to the contaminants present in the soils at the site.
Alternatives 2 and 3A provide for the greatest reduction in
the toxicity, mobility and volume of the contaminated soils.
Both of these alternatives require the soils to be
continually flushed during the groundwater remediation
activities. Upon completion of the groundwater remediation
activities (estimated 15 years), any leachable contaminants
will be removed, from the soils. Alternatives 4A and 4B
reduce only the mobility of the soil contaminants through
the use of a multi-layer cap. The multi-layer cap will
limit the infiltration of precipitation, and preclude the
leaching of s'oil contaminants into the groundwater.
Alternative 3B does not actively address the contaminated
soils at the site. Therefore, Alternative 3B does not
provide a significant reduction in the toxicity, mobility or
volume of. the soil contaminants. . .
PCB Soil Removal - Option 1 significantly reduces the
toxicity, mobility and volume of the PCB contaminated soils
by thermally destroying the PCBs. Option 2, however, only
reduces the mobility of the PCBs by landfilling the soil in
a TSCA landfill.
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22
E. Short-term Effectiveness
All of the alternatives considered have similar impacts on
short-term effectiveness resulting from a groundwater
treatment system being utilized. The alternatives differ,
however, with respect to the other remedial components used,
as well as the length of time required to remediate the
site. These factors present varying potential short-term
risks across all the alternatives. It is not obvious
however, that any one alternative presents lower overall
short-term risks than the others.
The use of the soil flushing under Alternatives 2 and 3A
presents a potential short-term risk to the environment by
temporarily increasing the mobility of the contaminants
within the soils. This increased risk, however, will be
controlled through the proper placement of the groundwater
pumping system. In addition, the groundwater monitoring
program will assess any changes in aquifer conditions. The
use of soil flushing in these alternatives lengthens the
estimated period required to meet the site's cleanup
objectives. The remedial action time estimated for
Alternatives 2 and 3A is 15 years, compared with the 11
years estimated for Alternative 3B and the 10 years
estimated for Alternatives 4A and 4.B.
Alternatives 3A, 3B, 4A and 4B which utilize a vegetative
coyer or a multi-layer cap will involve the grading of
surface soils which may create a temporary dust problem.
Conventional dust control measures will be employed
however, to limit any fugitive dust emissions that may occur
during grading activities.
The PCB Soil Removal Options are similar in the area of
short-term effectiveness. Both options require the
excavation arid off^site transport of the contaminated sub-
soils. Short-term exposure risks to workers and the
community may result. One potential difference between the
options is the length of time necessary to complete the
remedial action if a larger quantity of soil needs to be
removed. Option 1 will take longer than Option 2 due to
capacity restraints of the licensed TSGA incinerators. The
projected volume of soil to be excavated under either
option, however, is expected to be small enough that no
problems would arise with either incineration or
landfilling. :
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23
Impl ementab i 1 ity
While all of the alternatives considered are implementable,
some alternatives are technically easier to implement than
others, based on their design and complexity.
Alternative 3B is the easiest alternative to implement as
the remaining alternatives involve modifying this design.
Next in implementability would be Alternative 2, which
involves installing flushing equipment at the site.
Alternative 3A is next and is similar to Alternative 2 with
the addition of the 6 inch vegetative cover.
Alternatives 4A and 4B would be next, respectively, due to
the complexities in designing and installing a multi-layered
cap. Alternative 4A would be easier to implement than
Alternaitve 4B as it involves a smaller multi-layer cap
than Alternative 4B.
Excavation of the localized PCB-contaminated soil area is
easily implemented under either PCB Soil Removal Option.
Option 1 has some implementability problems due to the
finite availability of incinerators that are licensed to
handle PCB contaminated soil. This could potentially lead
to delays in transporting the materials to be incinerated if
a large volume of soils is removed.
G. Cost
The estimated present worth value of each alternative and
option is as follows:
Groundwater and Soil Remediation Alternatives
Alternative 2 $ 1,729,400
Alternative 3A $ 1,956,700
Alternative 3B $ 1,872,800
Alternative 4A $ 2,285,000
Alternative 4B $ 2,997,000
Localized PCB Soil Removal Options
Option 1 $ 17,700
Option 2 $ 8,600
H. Agency Acceptance
U.S. EPA and IEPA agree on the preferred alternative. Both
Agencies have been involved in the technical review of this
state-lead fund financed HS/FS, and the development of the
Proposed Plan and ROD.
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24
I. community Acceptance
Community acceptance is assessed in the attached
Responsiveness Summary. The Responsiveness Summary provides
a thorough review of the public comments received on the
HS/FS and Proposed Plan, and U.S. EPA's and lEPA's responses
to the comments received.
IX.
Based upon the information developed in the HS/FS, as well
as the comparative analysis of the remedial alternatives
with the 9 criteria, the U.S. EPA and IEPA have selected
Alternative 3A in combination with PCB Soil Removal -
Option 1 as the appropriate remedial action for the Cross
Brothers Pail Recycling site. The major components of this
remedy are as follows:
0 Re-sampling of the localized PCB soil area to identify
the existence of a PCB source.
° If identified, remove the localized PCB-contaminated
soil area and incinerate the soils at a TSCA approved
incinerator.
° Install and maintain a groundwater collection system
capable of capturing the groundwater contaminant plume.
° Install and maintain an on-site groundwater treatment
facility to remove contaminants from the collected
groundwater .
° Install and maintain a soil flushing system for the
3.5 acres of contaminated soil within the disposal
area.
° Install and maintain a 6 inch vegetative cover over
that portion of the disposal area not subject to the
soil flushing operation.
° Monitor the groundwater collection/treatment system and
the groundwater contaminant plume during groundwater
remediation activities.
° Install and maintain a 6 inch vegetative cover over
the 3.5 acre area subject to soil flushing upon
termination of the soil flushing operation.
° Install and maintain a fence around the site during
remedial activities.
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25
o Initiate a deed notification identifying U.S. EPA and
IEPA concerns regarding the conductance of intrusive
activities at the site.
Initiation of the remedial action will involve securing the
site, which begins with placing a deed notification on the
property. Any buildings left on-site will be demolished or
removed, and a fence constructed around the site area. The
remedial activities will involve two operable units: the
localized PCS soil removal and the groundwater and soil
remediation.
Prior to initiating the localized PCB soil removal, the area
will be re-sampled to establish whether a PCB source truly
exists in that area. If a PCB source is identified to exist
in that area above a 10 ppm action level, the soils will be
removed. The PCB soil removal would involve excavating the
soils and transporting the soils to a TSCA licensed facility
for incineration.
The groundwater and soil remediation will be treated as one
operable unit. The site can be divided into 2 areas: a 6.5
acre area that is characterized by small local areas of soil
contamination and a 3.5 acre area that contains
contamination throughout the unsaturated zone. Initially,
the 6.5 acre area will be covered with a 6 inch vegetative
cover, while the 3.5 acre area will be covered by 6 inches
of gravel.
Groundwater will be extracted by a series of downgradient
extraction wells and pumped back to a treatment facility on
the site. The groundwater will be treated and pumped into
an irrigation system that will place the treated groundwater
onto the 3.5 acre gravel area.
This system will establish a "cleansing loop". The
groundwater will pass through the soil and pick up
contaminants on its way back to the water table. The
groundwater will then be captured by the extraction wells,
treated and sprayed back on the site. This process will
continue until the groundwater analyses consistently
indicate that the groundwater cleanup objectives have been
achieved. The groundwater cleanup objectives for the Cross
Brothers Pail Recycling site require that treated
groundwater meet the following 2 standards:
•' ' •>
° Currently promulgated MCLs; and
° A cumulative excess lifetime cancer risk not
exceeding 10~6 and a hazard index ratio < 1.
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26
It is estimated that this process will take 15 years to
achieve the groundwater cleanup objectives.
Once the groundwater cleanup objectives are met, the fence,
treatment system and irrigation equipment will be removed
from the site, and a 6 inch vegetative cover placed on the
area initially flushed.
Table 11 presents a cost breakdown of the selected remedy.
X. STATUTORY DETERMINATIONS
U.S. EPA and IEPA believe the selected remedy satisfies the
statutory requirements to: protect human health and the
environment, attain ARARs, be cost-effective, utilize
permanent solutions and alternate treatment technologies (or
resource recovery technologies) to the maximum extent
practicable and provide the preference for treatment as a
principal element.
The following sections discuss how the selected remedy meets
these statutory requirements.
The selected remedy protects human health and the
environment through the removal and incineration of the
localized PCB-contaminated soils, pumping and treating the
contaminated groundwater and flushing the leachable
contaminants from the 3.5 acre contaminated soil area.
Excayation of the localized PCB-contaminated soils will
reduce the potential direct contact risk posed by these
soils. Incineration of the soils will reduce any possible
future threat the soils could provide if landfilled
elsewhere. Pumping and treating groundwater will result in
the removal of any risks to humans or the environment from
contact with or utilization of the groundwater. The soil
flushing will remove any leachable contaminants from the
soil. These contaminants will then be treated through the
..'. groundwater collection and treatment system. By flushing
the contaminants from the soils, future leaching of
contaminants will be prevented.
B. Compliance with Applicable or Relevant and
Appropriate Requirements
The selected remedy will comply with ARARs. The ARARs for
the selected remedy are presented in Table 12.
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Table 11
COST BREAKDOWN FOR SELECTED REMEDY IN TOTAL PRESENT WORTH
Site Security/Restriction
Fencing
Monitoring
Deed Restriction
Building Demolition
Localized PCB Soil Removal
Total
Mob/Demobilize/Decon
Excavation/Backfilling
Sampling and Analysis
Loading, Transport, Incineration
Total
$
$
$
$
$
$
$
$
96,000
119,400
10,000
10,000
235,400
3,400
500
900
12,900
17,700
Groundwater Treatment/Soil Flushing/6 Inch Vegetative Cover
Extraction Wells
Water Treatment
Phase I Soil Cover
Phase II Soil Cover
Irrigation/Flushing System
$ 13,800
$ 1,298,700
$ 289,100
$ 43,300
$ 178,500
Total
Total Cost
$ 1,823,400
$ 2,076,500
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TABLE 12
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
FOR THE SELECTED REMEDY
Federal Action-Specific ARARs
Resource Conservation and Recovery Act (RCRA)
0 40 CFR 261 - Definitions and Identification of
Hazardous Waste
° 40 CFR 262 - Standards for Generators of Hazardous
Wastes
0 40 CFR 263 - Standards for Transport of Hazardous
Wastes
Toxic Substances Control Act
0 40 CFR 761 - Regulations of PCBs and TSCA Section 6
Occupational Safety and Health Act
0 29 CFR 1910 - General standards for Worker Protection
° 29 CFR 1910 - Regulations for Workers Involved in
Hazardous Waste Operations
Intergovernmental Review of Executive Programs
(Executive Order 12372)
0 40 CFR 29
State Action-Specific ARARs
0 35 AIC 2'l5.101-102, 215.121-122, 215.141-144, 215.304,
215.500, 215.541, 215.562 - Organic Air Emission
Standards
0 35 AIC 807.101-104, 807.316-317 - Permits for Waste
Disposal Sites
0 35 AIC 809.101-802 Special Waste Hauling
0 35 AIC 700 -Hazardous Waste Management
0 Title 8, Chapter 1, Part 650 - State Guidelines for
Erosion and Sediment Control (Department of
Agriculture)
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TABLE 12 (CONT.)
Federal Chemical-Specific ARARs
Safe Drinking Water Act
0 40 CFR 141.11 - Maximum Contaminant Levels (MCLs)
Clean Air Act
° 40 CFR 50 - National Ambient Air Quality Standards and
CAA Section 109
° CAA Section 112 - National Emission Standards for
Hazardous Air Pollutants
State Chemical-Specific ARARs
0 35 AIC 302.208 - General Use Water Quality Standards:
Chemical Constituents
0 35 AIC 302.301-305 - Public Food Processing and Water
Supply Standards
° 35 AIC 303.202-203 - Nonspecific Water Use Designations
Federal Location—Specific ARARs
None
State Location-Specific ARARs
Designated State Highway Truck Route System for Large
Vehicles and Combinations (Illinois Department of
Transportation, January 1989)
Informational, Notification and Consultation
Responsibilities of Government at Public Hearings
(35 AIC 164-165)
Hazardous Waste Crane and Hoisting Equipment Operators
Licensing Act (S.H.A., Chapter 111, Paragraph1 7701)
Hazardous Waste Laborers Licensing (S.H.A., Chapter
111, Paragraph 7801)
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TABLE 12 (CONT.)
Monitoring Well Worker Licensing (Illinois Water Well
Construction Code Law, Illinois Revised Statutes,
Chapter 111.5, Paragraphs 1116.111-118, as amended)
Federal "To Be Considered* — Chemical—Specific
0 40 CFR 141.50 Maximum Contaminant Level Goals (MCLGs)
° Any Proposed MCLs and MCLGs
0 Any 10~6 Lifetime Health Advisories
0 TSCA PCB Spill Policy
State "To BG Considered" — Chemical—Specific
TB.C Chemical Cone.
Proposed MCL Toluene 2000 ug/1
Lifetime Health Advisory Toluene 2420 ug/1
MCLG Xylene 440 ug/1
Lifetime Health Advisory Xylene 400 ug/1
MCLG Cadmium 5 ug/1
MCLG Lead 20 ug/1
Lifetime Health Advisory Mercury l.l ug/1
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27
C. Cost-Effectiveness
The selected remedy, Alternative 3A in combination with PCB
Soil Removal - Option 1, is considered to be cost-effective.
This remedy is permanent, provides long-term effectiveness
and reduces the toxicity, mobility or volume of the
contaminants at the site at a cost proportional to the
overall benefits achieved by the remedy. This alternative
has a present worth value of $2,076,500.
Of the alternatives that cost less, Alternative 3B treats
the groundwater but does not actively pursue treatment of
the contaminated soils. As such, future leaching of the
soil contaminants into the groundwater is probable rendering
the overall timeframe for groundwater cleanup to be
questionable. Alternative 3A actively addresses the
contaminated soils, thereby eliminating future concerns
with regards to the contaminated soils. Although
Alternative 2 provides for treatment of soil contamination,
the alternative does not include the 6 inch vegetative cover
that Alternative 3A includes. This cover increases the
stability of the non-flushed areas, where small localized
areas of soil contamination exist. This cover should prevent
wind or water erosion of these soils and provide a
foundation for vegetative growth which was destroyed during
the site's operation.
While Alternatives 2 and 3B cost the least, Alternative 3A
provides a better solution for the on-site soils than
Alternative 3B for a 4.4% increase in cost. The cost
difference between Alternatives 2 and 3A (approximately
13%), is offset by the stability the presence of the
vegetative cover adds to the non-flushed areas.
Alternatives 4A and 4B cost the most of all the alternatives
considered. These costs are due primarily to the
complexities of the multi-layer cap which will contain the
soil contaminants.
As for the PCB Soil Removal Options, it is believed that
Option 1 is the most cost-effective of the 2 Options.
Although Option 2 costs less than Option 1, Option 2 does
not provide the permanence that will be attained by
Option 1. The cost difference between landfilling and
incineration is minimal due to the limited amount of PCB
contaminated soils expected to be removed from the site
(estimated 5 yd3).
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28
D. utilization of Permanent Solutions and Alternative Treatment
Technologies for Resource Recovery Technologies1 to the
ygvimn-m Extent Practicable • .
The U.S. EPA and IEPA have determined that the selected
remedy utilizes permanent solutions and alternative
treatment technologies (or resource recovery technologies)
to the maximum extent practicable. The selected remedy -
Alternative 3A in combination with PCB Soil Removal -
Option 1 - focuses on providing permanent and significant
treatment for those threats (i.e. groundwater, soil
contamination and the localized PCB soil area) identified at
the site.
E. Preference for Treatment as a Principal Element '
The selected remedy addresses the principal threats posed.by
the site (i.e. groundwater, soil contamination and the
localized PCB soil area) through treatment. The selected
remedy requires groundwater treatment and soil flushing. In
addition, subsequent to identifying the existence of a PCB .
soil source, the selected remedy requires that area to be
excavated and the soils incinerated. As such, the selected
remedy employs treatment as a principal element.
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RESPONSIVENESS SUMMARY
I. RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (U.S. EPA) and the
Illinois Environmental Protection Agency (IEPA) recently
held a public comment period from July 26, 1989 through
August 25, 1989 for interested parties to comment on the
Proposed Plan and Hydrogeological Study/Feasibility Study
(HS/FS) for resolving the remaining contamination problems
at the Cross Brothers Pail Recycling Superfund Site,
Pembroke Township, Illinois. An August 21, 1989, public
hearing focused on the results of the HS/FS and the
Agencies' preferred remedial alternative set forth in the
Proposed Plan. The public comment period and public
hearing were held in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act
(CERCLA) Section 117, the Superfund Amendments and
Reauthorization Act (SARA) Section 117(a) (2) and applicable
Illinois State Law (35 IL Admin. Code 164).
The purpose of this responsiveness summary is to document
the Agencies' responses to questions and comments received
during the public comment period. These comments were
considered before selecting the final remedy, for the Cross
Brothers Pail Recycling site.
Based on the comments received from residents and local
officials during the public comment period and the Public
Hearing, the community of Pembroke Township, and the
Kankakee County authorities, are generally supportive of the
preferred alternative presented in the Proposed Plan.
This responsiveness summary contains the following sections:
° Background on Community Involvement
0 Public Hearing
° Summary of the Significant Questions and Comments
Received during the Public Comment Period, and the
Agencies' Responses
II. BACKGROUND ON COMMUNITY INVOLVEMENT
As the lead agency for the HS/FS, IEPA is responsible for
conducting the community relations program relating to the
Cross Brothers Pail Recycling site. A Community Relations
Plan for the site was approved by U.S. EPA in May, 1983. It
established a process by which a two-way flow of project
information between local officials, concerned citizens, the
media, and the IEPA could occur. During 1983 and 1984, a
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Remedial Investigation and Feasibility Study (RI/FS) was
conducted at the site. The RI/FS was followed by a Public
Hearing in September 1984. At this time, a Site Information
Repository was established at the Pembroke Area Health
Center with all relevant documents. In addition to news
releases, 3 Fact Sheets were distributed to the public,
describing the need for the environmental investigation, the
nature of its findings, and the various initial remedies
being considered. Informal meetings were also held with
nearby residents, local officials, and other concerned
citizens during this period.
As a result of a March 25, 1985 U.S. EPA Record of Decision
(ROD), an Initial Remedial Measure (IRM) was carried out at
the site by IEPA during the fall of 1985. This initial
action removed the majority of surface contamination at the
site, allowing for further investigation of soil and
groundwater contamination in the period since 1986.
The present Hydrogeological Study/Feasibility Study (HS/FS)
presents the results of these investigations of soil and
groundwater at and near the site. Site Information
Repositories were established at both the Hopkins Park
Village Hall and the Kankakee Public Library. These
repositories contain the HS/FS reports, the original 3 Fact
Sheets for the site, a new Fact Sheet describing the HS/FS
findings and the preferred alternative, and the Proposed
Plan for the site. Public Hearing Notices were published in
both the Kankakee Daily Journal (July 23, July 28, and
August 4, 1989) and the Pembroke Informer (The August
edition, published the first week of August). In addition,
both the Public Hearing Notice and the HS/FS Fact Sheet were
mailed to all citizens, officials, news media, and other
parties previously identified as being interested in the
project. The local media were instrumental in responsibly
reporting the results of the HS/FS and the Preferred
Alternative.
III. PUBLIC HEARING
The public hearing on the HS/FS and Proposed Plan was held
from 1:00 p.m. to 3:00 p.m. on August 21, 1989, at the
Hopkins Park Village Hall, at Central and Main Streets in
Hopkins Park, Illinois. Approximately 35 people attended,
including village, township and county officials;
representatives of State Legislators; and members of the
press.
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• 3 •"•.. •.-. ' '
IV. SUMMARY OF SIGNIFICANT QUESTIONS AND COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD AND THE AGENCIES/ RESPONSES
Questions and comments received during the public comment
period are paraphrased and organized below into two discrete
sections: Those received at the public hearing and the
written comments received from Conestoga-Rovers & Associates
Limited on behalf of several of the Cross Brothers Pail
Recycling site Potentially Responsible Parties (PRPs) (the
only written comments received). The Agencies' response is
given after each individual question or comment. The public
hearing comments are grouped by topic.
A. Questions and Comments Received at the Public Hearing
Health and Safety:
Comment 1: How safe is it for the. site's neighbors to
remain in the area during the proposed 15 years of
remediation? Aren't they threatened by contaminated runoff
and groundwater or by windblown contaminants? And wasn't
there a "vault" of contaminated material constructed at the
site, which might leak? Nearby residents should be
relocated.
Response: The extensive environmental studies carried out,
both before and after the Initial Remedial Measure, have
shown in detail the location of any seriously contaminated
soil and groundwater ~on and near the Cross Brothers Pail
Recycling site. The proposed Remedial Action is designed to
ensure that nearby neighbors are protected both during and
after the remedial process.
The sandy soils on the site are extremely porous, and
rainwater tends to soak into the ground immediately; so
there is little threat of contaminated soils leaving the
site through rainwater runoff. In addition, the many
groundwater monitoring wells installed during the
Hydrogeological Study clearly show that the groundwater at
the site is moving to the north, where the groundwater
extraction wells will be installed. As such, the neighbors
to the south need not be concerned that their private
drinking water wells might be contaminated by the site at
any time during or after the remedial process. The two
residential wells next to the site were replaced in the
early 1980's with deep wells which draw from the deeper,
uncontaminated aquifer. Because the proposed remedy will be
designed to capture the contaminated groundwater moving to
the north of the site, any private water supplies farther
north, toward Florida Avenue, will be protected. Thus none
of the neighbors of the Cross Brothers Pail Recycling site
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have any reason to be concerned that the site's
contamination might threaten the safety of their private
water supplies during the remedial action process.
The proposed alternative removes any possibility of
windblown contamination leaving the site and affecting
neighbors. The 3.5 acre area subjected to soil flushing
will be covered with. 6 inches of gravel, and the remaining
6.5 acres used during the Cross Brothers operation will be
covered with 6 inches of topsoil and planted with grass.
After the soil flushing phase is complete, the 3.5 acres
will also be covered with ,6 inches of topsoil and planted
with grass. The topsoiL and grass will stabilize the soils
at the site and ensure that the soils will not be carried
onto neighboring properties by the wind.
Some residents apparently were under the mistaken impression
that a "vault" of contaminated material had been left
on-site at the Cross Brothers Pail Recycling site. A
"vault" alternative was,considered and rejected in 1984.
All contaminated surface materials collected on-site during
the IRM were hauled to a permitted hazardous waste facility
elsewhere. Thus, there is no "vault" present at the Cross
Brothers Pail Recycling site'.
As the proposed alternative will control all public health
and environmental threats remaining at the site, there is no
reason to relocate nearby neighbors of the Cross Brothers
Pail Recycling site.
Question 1: How can we be sure that the groundwater at the
site moves to the north and will be captured by the series
of pumping wells?
Response: The Hydrogeological Study showed in two ways that
the groundwater moves to the north. First, the study used
established scientific principles in determining the
direction of groundwater movement. Water levels were
measured in each of the groundwater monitoring wells a
number of times during the HS. These measurements were then
plotted to indicate where the water table is located in each
well. A review of these plots indicates the direction of
groundwater movement based on the "slope" of the water
table. At the Cross Brothers Pail Recycling site, the water
table slopes to the north, showing that groundwater is
moving in a northerly direction.
A second, even more convincing way we can be sure that
groundwater at the Cross Brothers Pail Recycling site moves
to the north is that the groundwater to the north of the
site is contaminated. Since the groundwater to the south,
east, and west of the site was found not to be contaminated,
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and since we know that the Cross Brothers site is the source
of the contamination, we are sure that groundwater is
moving to the north. .
Question 2: How can we be sure that the deep wells
installed on the Cross Brothers property and the 2 nearby .
residences will not allow contamination to move from the
contaminated upper layer of groundwater to the deeper, .
uncontaminated layers? Could faulty construction or ,
materials (plastic pipe, for example) allow these wells to
contaminate these deeper water sources?
Response: The deep wells present at the Cross Brothers
property and at the two residences north of the site were
installed in the early 1980's. These wells were sampled in '
1987 during the HS. If these wells had not been installed .
properly, then contaminants might have migrated into the
lower aquifer subsequent to their installation. The
sampling results from the HS do not indicate contaminants to
be present in the lower aquifer. In addition, the Agencies
have reviewed the well logs for these wells. These logs
indicate that the wells were properly installed. As such, it
is unlikely that the deeper wells in the area of the Cross
Brothers property will allow contaminants to move from the
upper to the lower aquifer.
Question 3: Is the Village of Hopkins Park's Public Water
Supply safe? Could its wells be affected by the Cross
Brothers site? Could contamination enter the public water
lines through underground vents on the fire hydrants in the
system?
Response: The Hopkins Park Public Water Supply is tested
regularly as part of a State regulatory program under the
Federal Safe Drinking Water Act. Moreover, the public
water is drawn from the deeper, uncontaminated, aquifer. In
addition, the public water supply wells are located
southwest of the Cross Brothers Pail Recycling site.
Contaminated groundwater is moving to the north of the Cross
Brothers Pail Recycling site. As such, it would be
extremely unlikely for the site's contamination to reach the
Village's wells. The only way even a tiny amount of
contaminated water could accidentally enter the public water
lines in the area of the Cross Brothers site would be if a
fire hydrant happened to be located directly within the area
of the contaminated groundwater, to the north of the site.
The IEPA will investigate to make sure that this is not the
case.
There is no reason for the public to be concerned that the
Cross Brothers Pail Recycling site poses a risk to the
Hopkins Park Public Water Supply.
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Question 4: How do we know what chemicals to test for when
deciding whether the treated groundwater is safe to
spray-irrigate onto the 3.5 acres of contaminated soil?
Response: The environmental investigations at the site were
designed to detect a very wide range of chemicals often
found at hazardous waste and industrial sites. The
contaminants found in the soil and groundwater at the Cross
Brothers site fall into two categories: Volatile Organic
Chemicals (VOC's) and Semi-Volatile Organic Chemicals. The
treatment system proposed for the groundwater will be
designed to reduce both of these types of chemicals to meet
the strictest drinking water standards. The treated water
will be tested to make sure it meets these standards before
being used in the soil flushing operation on the 3^5 acre
portion of the site.
Question 5: For the two families which were exposed to
contaminated drinking water before they got the deep wells,
have they suffered any health effects that might be related
to this chemical exposure? - ,
Response: Because IEPA was concerned about this issue, it
arranged with the Illinois Department of Public Health for a
special health assessment of the children of both these
families, in November 1983. Because it was not convenient
for the families to take the children to Cook County
Hospital where the chemical-exposure specialists were based,
the two doctors were brought to the Pembroke Health Center
to examine the families. The specialists could find no
evidence of negative health effects due to chemicals from
the Cross Brothers Pail Recycling site. :
Technical Issues
Question 6: Isn't the Proposed Plan the same technical
approach that was supported by many residents in the earlier
public hearing, held in 1984? Wouldn't this project be much
farther along if that approach had been adopted in 1984?
Response: The preferred alternative now under consideration
is indeed the same, approach supported by Pembroke Township
citizens in the earlier hearing. However, the approach
presented at that time included the removal of the highly
contaminated surface materials present at the site. This was
accomplished during the fall of 1985 through the Initial
Remedial Measure. The present Proposed Plan is the second
part of the approach.
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Question 7: What percentage of the contaminated groundwater
from the site will be captured by the 4 proposed pumping
wells? Will this proposed treatment alternative just be
diluting the contamination?
Response: The proposed alternative will not simply dilute
the site's contamination. Instead, the extraction wells
will be located so that essentially 100% of the
contaminated groundwater will be drawn up into the treatment
system. The contamination will be removed from the water
before it is sprayed onto the 3.5 acre soil area. As the
.water flows through the soils, contaminants will be picked
i up and carried to the groundwater. The groundwater then
.will travel north to be drawn up once again into the
extraction wells for treatment. The system will be designed
.to treat and recycle the groundwater, so that contaminants
•do hot escape into the environment.
"Question 8: Did the Agencies consider bioremediation as a
treatment alternative?
Response: The Agencies did consider bioremediation for both
the.soils and groundwater at the Cross Brothers Pail
Recycling site. This technology was eliminated from further
; consideration due to the low levels of organic contaminants
present in both the soils and groundwater. In addition,
neither the soil nor the groundwater naturally contain
enough of the organic nutrients necessary to support
biological treatment.
Question 9: Have the Agencies considered adding a second
line of pumping wells, along the north edge of the Cross
Brothers property, to remove contaminated groundwater for
treatment more quickly, and reduce the time it takes
.groundwater to travel from the site to the treatment system,
thus speeding up the process?
Response: The Agencies consider this to be an excellent
suggestion. The actual locations of the extraction wells
will be determined during the Remedial Design, and the
Agencies will assess the implamentability and effectiveness
of adding a second set of extraction wells along the north
edge of the Cross Brothers Pail Recycling site at that time.
Question 10: Have the Agencies considered operating the
pump and treat system all year, and simply reinjecting the
treated water south of the site during the winter months,
when it is too cold for soil flushing?
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8
Response: During the FS, the Agencies did consider an
alternative involving pump and treat with reinjection of the
treated groundwater (Alternative 3B). The Agencies also
considered the preferred alternative - pump and treat with
soil flushing (Alternative 3A). In developing the
alternatives presented in the FS, the Agencies did consider
developing an alternative that involved both soil flushing
and reinjection (during the winter months). The Agencies
initial evaluation of this type of alternative indicated
that it is no more effective (i.e. time period required for
Remedial Action) than the Agencies' preferred alternative.
An alternative involving both soil flushing and reinjection
would however, cost more than the Agencies' preferred
alternative.
Question 11: Have the Agencies considered adding a system
of underground "tiles" to speed the movement of groundwater
through the site and reduce the time needed for the remedial
action?
Response: After considering this suggestion, the Agencies
do not believe the installation of field tiles would
represent an effective technology for this site. The
objective of field tiles is to collect water from a depth of
18 inches to 3 feet. The soil contamination present at the
site is located at a depth equal to the water table level.
As such, field tiles could not be placed to collect all of
the water that will be flushed through the contaminated
soils. In addition, the tile system would not address the
groundwater contamination existing beneath the site. As
such, the contaminated groundwater will still have to be
addressed by the downgradient extraction system.
Therefore, the time required to perform remedial action
would not be shortened by using a tile system.
Mr. Cross's Present and Future Operations at the Site
Question 12: m Why is Mr. Cross still operating a business on
this property? Is this business a threat to the environment
or his neighbors?
Response: During the original environmental investigation
at the site, the Cross brothers obtained a court order from
the Kankakee County Circuit Court saying that they could
operate a pail and drum recycling - operation so long as the
pails and drums contained no hazardous wastes or substances.
Since that time, the Cross brothers operation has continued,
primarily as a wood pallet reclamation operation. As long
as Mr. Cross obeys the terms of the court order, his
operations should not threaten either the environment or
public health.
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Question 13: How do the Agencies know that Mr. Cross is not
illegally handling hazardous wastes on the site, and how can
we be sure he will not bring hazardous wastes onto the site
during the remediation process?
Response: Although Mr. Cross' operation has not been under
constant surveillance, Agency staff and their
representatives have been on. the site regularly over the
past nine years. During this period, there has been no
evidence indicating the handling of hazardous wastes/
substances at the site. In addition, the generators of
hazardous wastes would have to knowingly violate
environmental laws, risking, severe legal penalties and major
cleanup costs, if they were to send wastes to the Cross
Brothers Pail Recycling site today.
Impacts on Local Groundwater
Question 14: With the nearby agricultural irrigation
systems operating, is there any chance that contamination
could be drawn into the uncbntaminated deeper layers of
groundwater?
Response: In the site area, a confining clay layer exists
between the contaminated upper aquifer and the deeper,
uncontaminated, bedrock aquifer. This clay layer prevents
contamination from moving into the bedrock aquifer. In
addition, groundwater samples collected from the bedrock
aquifer during the HS do hot indicate that contaminants are
present. As the groundwater contamination has existed in
the site area for a number of years and the irrigation
systems have been operating for a number of years, the
absence of contaminants in the groundwater samples collected
during the HS indicates the clay layer is serving as an
effective barrier between the aquifers.
Question 15: Will the groundwater extraction system remove
enough groundwater to lower the local groundwater levels and
possibly cause nearby private wells to go dry.
Response: The system will be designed to ensure that
private wells are not impacted by the remedial action. Most
of the groundwater extracted will simply be returned to the
groundwater through, the soil flushing operation. The small
amount (at most 20%) lost to evaporation will not have a
serious effect beyond the immediate site area.
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10
Distribution of bruins from Cross Brothers
Question 16: A kankakee weekly newspaper reports it has
been contacted by Pembroke Township residents who say they
had gotten driims still containing residues from Mr. Cross,
and that these drums had been used for barbecue pits, burn
barrels, feed storage barrels, and animal feed and water
troughs. Has there been any study of the possible health
impacts of such uses?
Response: The Agencies have never been contacted by any
individual who has claimed to have received barrels still
containing residues from the Cross Brothers site. In 1983
and 1984 an effprt was made to determine if barrels had left
the site to be used by local residents. No evidence could
be found to support that barrels had left the site to be
used by local residents. However, based on the possibility
that such practices did occur, IEPA consulted with the
Chief Toxicologist. of the Illinois Department of Public
Health. His professional opinion was that the volatile
nature of the chemicals brought to the site would have
caused them to burn off or evaporate quickly in barbecue
pits or burn-barrels, thus posing no significant health
risk. A minimal health risk would exist if barrels still
containing residues were used for storing feed or for
feeding/watering;animals. However, this type of exposure
would have been, at most, a one-time occurrence. As this
exposure would have occurred a number of years ago, it would
be impossible to define today.
If a large number of barrels still containing residues left
the site to be taken to a single location, then a
significant health risk might exist at that location.
Emptying the barrel residues onto the ground could cause
localized soil and groundwater contamination at that
location, which could result in a threat to public health
and the environment. If any member of the public or press
knows of such a situation, it should be reported to the
Agencies to be investigated. So far, no such reports have
been received.
Question 17: A representative of the Kankakee weekly
newspaper stated that many citizens were concerned about the
possible health impacts of the site, both to those who lived
near the site itself, and those who might have used barrels
from the site in the ways outlined. He questioned whether
there was any arrangement for compensation to people who may
have been injured by contamination from the site.
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Response: CERCLA, as amended by SARA, does not provide for
the direct compensation of those believed to be injured due
to a release from a Superfund site. Individuals do,
however, have the right to undertake appropriate legal
action against any party which they believe to be
responsible for causing the injury.
Responsibility/Liability for the Site
Question 18: Why aren't Mr. Cross and the companies that
sent hazardous wastes to the site responsible for doing the
investigation and remedial action at the site?
Response: Under CERCLA, the owners and operators of a
hazardous waste site are legally responsible for the costs
of investigating and cleaning Up the site. In addition, any
company or individual that generated hazardous wastes that
were brought to the site, as well as any person or company
that transported the wastes to the site, is liable for these
costs.
In the case of the Cross Brothers site, the Agencies have
been negotiating with a group of Potentially Responsible
Parties (PRPs). PRPs are those individuals or companies
thought to have transported or generated wastes that went to
the site. The Agencies hope to recover their past costs at
this site and to obtain payment by these individuals or
companies for the remedial action needed at the site.
Question 19: Will Pembroke Township or Kankakee County
residents have to pay for this project if the PRPs do not do
so?
Response: Local residents and taxpayers do not pay for
Superfund Remedial Actions. The State pays 10% of the cost
of the Remedial Action at the site. Most of the Remedial
Action costs (90%) are paid from a Federal fund. The money
in this fund .comes from taxing various industries. If the
PRPs do not agree to carry out the Remedial Action, then
Federal and State money would be used. The Agencies would
then try to recover the costs from the PRPs in court. If the
PRPs do agree to carry out the Remedial Action, the PRPs
would pay for all activities and no Federal or State money
would be used.
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B. Questions and Comments Received in Writing
Technical Issues
Comment 1: . There appears to be a discrepancy between the
measured groundwater flow direction and the modelled
groundwater flow direction. This discrepancy appears to
have resulted in placing the extraction wells too far to the
east in the FS. Modelled groundwater flow and measured flow
should be reconciled prior to final selection of extraction
well locations.
Response: The Agencies agree with this comment. The FS was
not, however, meant to be a design document. The FS
presents merely a "conceptual picture" of the various
alternatives considered by the Agencies. Actual extraction
well locations will be determined during development of the
Remedial Design.
Comment 2: The capital cost for groundwater treatment were
not itemized in the FS.
Response: The following is an itemization of the $ 670,000
groundwater treatment cost presented in the FS:
Groundwater Treatment System: $ 650,000
Includes:
° Air Stripping Tower,
Carbon Filtration Unit,
Air Filtering Equipment -
Vendor Quote = $ 515,000
° Additional Cost Contingency
(i 15%) for Installation and
Initial Set-Up Cost - $ 135,000
»
Treatment Building and Foundation $ 20,000
Comment 3: The installation of a 6 inch soil cover to
provide physical separation is not justified by the baseline
risk assessment. Fencing the site and the other access
restrictions will eliminate any accidental exposure.
Response: Although fencing the site and placing a
notification on the property deed will eliminate any
accidental exposure due to trespassing, the site currently
is not vegetated. As such, the soils present on-site might
be subject to wind erosion. A fence and deed notification
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13
will not prevent this type of erosion. The proposed soil
cover, which is really a vegetative cover, will stabilize
the soils at the site preventing wind erosion.
Comment 4: A cap would be counter-productive to the soil
flushing and pump and treat option identified to be
advantageous for the site because a cap will reduce the
natural soil flushing.
Response: The Agencies' preferred alternative does not
include a "cap". The preferred alternative includes a
6 inch vegetative cover. This type of cover will reduce
infiltration to only a small degree. As such, the 6 inch
vegetative cover will allow a natural flushing of the 6.5
acres of soils not subject to the soil flushing activities.
Comment 5: Inclusion of the PCB-contaminated soil option in
the preferred alternative is based on only 1 soil sample.
The uncertainty associated with the level of contamination
and the volume of soil affected should be addressed as soon
as possible.
Response: The Agencies' PCB-contaminated soil option
explicitly states that the area identified be resampled
prior to initiating excavation. The primary purpose of the
resampling effort is to define the level of contamination
and the volume of soil affected in that area.
Comment 6: A risk range of 10~4 to 10~6 with a target of
10~5 would be a more appropriate cleanup objective,
especially for such a small population.
Response: The Agencies do not consider the size of the
population a relevant factor in determining the appropriate
cleanup objectives for a site. The current or future
potential use of the land and aquifer are considered. For
the Cross Brothers Pail Recycling site, the Agencies expect
the land to be usable as residential property subsequent to
cleanup. The aquifer is a drinkable aquifer that is
currently in use. As such, the groundwater cleanup
objective was set at a cumulative 10""^ risk level.
Comment 7: The use of maximum concentration reported is
inappropriate and of no value in risk assessment and risk
management. The conditions which are required to achieve
the worst-case exposure in the risk assessment do not exist
at this site. By maximizing the parameters in a scenario
for exposure, the assessor is looking at the top end of the
distribution of exposures in a population. This assumes the
worst case actually exists in the population. It is not
legitimate to use a worst-case scenario to demonstrate that
there in fact exists a concern in a real population.
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14
Response: The risk assessment was completed in accordance
with U.S. EPA's Superfund Public Health Evaluation Manual.
Pursuant to this guidance, a maximum, as well as a
representative, concentration was utilized in quantifying
the risks present at the site. By using the maximum
concentration in quantifying risk, the Agencies were able to
assess the upper bound current or future potential risk for
the site. By defining the upper bound current or future
potential risk at the site, the Agencies are not assuming
that the worst-case actually exists in the population. The
Agencies are merely considering the range of current or
future potential risks (representative as well as maximum)
presented by the site. This range is then used by the
Agencies to determine the extent of work necessary to
protect human health and the environment.
Comment 8: The baseline risk assessment is overly
conservative. Several examples were given to illustrate
this point.
Response: The baseline risk assessment was developed in
accordance with U.S. EPA guidelines and procedures. Since
the document follows U.S. EPA's guidelines and procedures,
the Agencies do not believe the baseline risk assessment to
be overly conservative.
Comment 9: Groundwater cleanup goals should be determined
using risk based calculations rather than drinking water
quality standards. Other processes which limit contaminant
concentrations such as dilution, attenuation and degradation
have not been included in the calculation of exposure but
are relevant to the establishment of realistic cleanup
goals.
Response: The groundwater cleanup goals established for the
preferred alternative require treated groundwater to meet:
° ' Currently promulgated MCLs; and
0 A cumulative lifetime excess cancer risk
not exceeding 10~6 and a Hazard Index < 1.
The Agencies chose these cleanup goals for several reasons.
The purpose of the groundwater cleanup activities at the
Cross Brothers Pail Recycling site is to achieve aquifer
remediation. The Agencies expect the aquifer to be returned
to drinking water quality. As such, currently promulgated
MCLs are relevant and appropriate requirements to be met. In
addition, a risk based standard has been set by the
Agencies to account for the presence of multiple groundwater
contaminants at the Cross Brothers Pail Recycling site.
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15
Dilution, attenuation and degradation may reduce
contaminant concentrations and thus the potential exposures
to residences currently using the aquifer. Dilution,
attenuation and degradation will not immediately reduce the
potential exposures associated with any new well
installations within the plume area. A reduction to this
type of exposure will only occur over time. As such, the
Agencies believe active remediation of the aquifer is
necessary, and that the groundwater cleanup goals set by the
Agencies should be achieved at the site.
Comment 10: Neither the FS nor the HS contains the QA/QC
deliverables which are necessary to properly evaluate the
data presented. This deficiency has limited the ability to
fully rely upon the conclusions reached.
Response: The HS presented information pertaining to the
QA/QC of data. Appendix J of the HS discusses the data
validation procedures used. Appendix K of the HS discusses
the data evaluation procedures used. Appendix L of the HS
presents a summary of the QA/QC data. All QA/QC procedures
used were in accordance with U.S. EPA guidelines and
procedures.
Comment 11: Cost estimates for several components of the
preferred alternative are on the low side which could result
in increases to the remedy cost.
Response: The cost estimates presented in the FS are only
intended to be accurate to +50%/-30%. A cost estimate to
the +50%/-30% accuracy level conforms to U.S. EPA's
guidance on the costing of Remedial Actions. As such, the
Agencies are aware that the cost of Remedial Action could
potentially increase, as well as decrease.
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