PB98-964102
EPA 541-R98-089
November 1998
EPA Superfund
Record of Decision:
H. O. D. Landfill
Antioch, IL
9/28/1998
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
H.O.D. Landfill
Antioch, Lake County, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedy for the H.O.D. Landfill (the Site) in
Antioch, Illinois, which was chosen in accordance with the Comprehensive, Environmental,
Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA), and, to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the
Administrative Record for the Site. The Administrative Record Index identifies items that
comprise the Administrative Record, and is included as an appendix to this Record of Decision
(ROD).
The State of Illinois has verbally concurred with the selected remedy. The United States
Environmental Protection Agency (USEPA) will include the State letter of concurrence in the
Administrative Record upon receipt of the letter.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Site, if not addressed by
implementing the selected remedy in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OP THE SELECTED REMEDY
The selected remedy will be a final Site-wide remedy. The selected remedy addresses the
sources of the contamination by containment of the landfill and contaminated soils, and treatment
of leachate and landfill gas. The major components of the selected remedy for the Site are:
waste cap improvements
enhanced gas collection and treatment
enhanced leachate collection
leachate treatment
groundwater monitored natural attenuation
institutional controls
The selected remedial action will address the low level threat of contaminated groundwater posed
by the Site. Principal threat wastes are defined by USEPA as source materials that are highly
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mobile or highly toxic, and incapable of being reliably contained. Groundwater is generally not
considered a source material. Since there are no principal threats from the Site, treatment of the
waste mass was not included in the selected remedy.
USE OF NATURAL ATTENUATION FOR GROUND WATER RESTORATION IN
LIEU OF GRQTJNDWATER TREATMENT
The USEPA has determined that use of natural attenuation for groundwater restoration will
result in expeditious attainment of cleanup levels, and that risks associated with the
contaminated groundwater will be minimized in the interim. Based on monitoring data and
geological information, USEPA believes that cancer risks and other hazards to human health
associated with contacting the groundwater can be minimized by monitoring the groundwater
and restricting its use until the levels of contaminants in the water are below drinking water
standards, background levels, and/or other health-based standards. The USEPA has
determined that groundwater at the Site does not pose a threat to off-site residential drinking
water supplies, and that restricting groundwater use will prevent any contact with this water.
Natural attenuation is a viable remedy for contamination found in the groundwater at the Site
based on the specific hydrogeological conditions present. The USEPA believes that known
groundwater remediation technologies will not significantly expedite attainment of groundwater
cleanup levels over that anticipated to be attained through natural attenuation. Furthermore,
due to the immobile and highly localized nature of the groundwater contamination, USEPA
believes that groundwater remediation is not a suitable alternative.
Groundwater contaminant levels will be closely monitored to ensure that there is progress
toward and expeditious attainment of groundwater cleanup levels. Should future evidence
show the existence of a groundwater contaminant plume, or should progress toward or
attainment of expeditious cleanup not occur through natural attenuation, USEPA has specified
in this ROD that the contingency measure of an active, groundwater remediation alternative be
considered.
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 selected
remedy, and is cost-effective. The selected remedy uses permanent solutions and alternative
treatment technologies to the maximum extent practicable. Since the selected remedy includes
leachate and landfill gas treatment, the selected remedy satisfies the statutory preference to
employ treatment as a principal element to permanently and significantly reduce the volume,
toxicity, or mobility of the hazardous substances, pollutants, and contaminants.
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Because the selected remedy will result in hazardous substances remaining on-site, a review will
be conducted within five years after commencement of remedial action to insure that the selected
remedy continues to provide adequate protection of human health and the environment.
William E. Muno, Director
Superfund Division
Date
r/it/ff
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RECORD OF DECISION
H.O.D. LANDFILL SUPERFUND SITE
TABLE OF CONTENTS
PAGE
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 7
IV. SCOPE AND ROLE OF RESPONSE ACTION 8
V. SUMMARY OF SITE CHARACTERISTICS 9
VI. SUMMARY OF SITE RISKS '15
VII. DESCRIPTION OF ALTERNATIVES 21
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 36
IX. THE SELECTED REMEDY 54
X. STATUTORY DETERMINATIONS 58
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 61
H.O.D. ROD; September, 1998
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RECORD OF DECISION
H.O.D. LANDFILL SUPERFUND SITE
FIGURES, TABLES, AND ATTACHMENTS
FIGURE 1
FIGURE 2
FIGURES
FIGURE 4
FIGURES
FIGURE 6
FIGURE?
TABLE 1
TABLE 2
TABLE 3
TABLE 4
TABLES
TABLE 6
TABLE?
TABLE 8
TABLE 9
TABLE 10
TABLE 11
TABLE 12
SITE LOCATION MAP
DESIGNATION OF OLD AND NEW LANDFILL
EXISTING CONDITION OF THE LANDFILL COVER
EXISTING MONITORING WELL AND PIEZOMETER LOCATION
MAP
EXISTING GAS AND LEACHATE EXTRACTION DEVICES
LEACHATE AND GAS COLLECTION SYSTEM FOR THE
SELECTED REMEDY
GROUNDWATER MONITORING PLAN FOR THE SELECTED
REMEDY
LIST OF ACRONYMS AND ABBREVIATIONS
CHEMICALS OF CONCERN FOR GROUNDWATER
CHEMICALS OF CONCERN FOR SURFACE WATER, SEDIMENT,
AND SOIL
SUMMARY OF REMEDIAL INVESTIGATION ANALYTICAL
RESULTS FOR LEACHATE SAMPLES (FOR VOCs, SVOCs, AND
PESTICIDES/PCBs)
SUMMARY OF REMEDIAL INVESTIGATION ANALYTICAL
RESULTS FOR LANDFILL GAS SAMPLES (FOR VOCs)
SUMMARY OF REMEDIAL INVESTIGATION ANALYTICAL
RESULTS FOR GROUNDWATER SAMPLES (FOR VOCs, SVOCs,
AND PESTICIDES/PCBs)
SUMMARY OF REMEDIAL INVESTIGATION ANALYTICAL
RESULTS FOR SURFACE WATER SAMPLES (FOR VOCs, SVOCs,
AND PESTICIDES/PCBs)
SUMMARY OF REMEDIAL INVESTIGATION ANALYTICAL
RESULTS FOR SEDIMENT SAMPLES (FOR VOCs, SVOCs, AND
PESTICIDES/PCBs)
SUMMARY OF REMEDIAL INVESTIGATION ANALYTICAL
RESULTS FOR SURFACE SOIL SAMPLES (FOR VOCs, SVOCs,
AND PESTICIDES/PCBs)
SUMMARY OF BASELINE RISK ASSESSMENT RESULTS
CHEMICAL-SPECIFIC APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
LOCATION-SPECIFIC APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
H.O.D. ROD; September, 1998
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RECORD OF DECISION
H.O.D. LANDFILL SUPERFUND SITE
FIGURES, TABLES, AND ATTACHMENTS, cont.
TABLE 13
TABLE 14
TABLE 15
TABLE 16
TABLE 17
TABLE 18
TABLE 19
TABLE 20
TABLE 21
TABLE 22
APPENDIX A
APPENDIX B
ACTION-SPECIFIC APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
DESCRIPTIVE SUMMARY OF ALL ALTERNATIVES
COST ESTIMATE SUMMARY FOR ALL ALTERNATIVES
HYDROLOGIC EVALUATION OF LANDFILL PERFORMANCE
(HELP) MODEL SUMMARY
DETAILED COST ESTIMATE FOR THE CAPPING PORTION OF
THE SELECTED REMEDY
DETAILED COST ESTIMATE FOR THE GAS COLLECTION
PORTION OF THE SELECTED REMEDY
DETAILED COST ESTIMATE FOR THE LEACHATE COLLECTION
PORTION OF THE SELECTED REMEDY
DETAILED COST ESTIMATE FOR THE LEACHATE TREATMENT
PORTION OF THE SELECTED REMEDY
DETAILED COST ESTIMATE FOR THE GROUNDWATER
MONITORING PORTION OF THE SELECTED REMEDY
GROUNDWATER CLEANUP STANDARDS
RESPONSIVENESS SUMMARY
ADMINISTRATIVE RECORD INDEX
H.O.D. ROD; September, 1998
111
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DECISION SUMMARY
H.O.D. LANDFILL SUPERFUND SITE
ANTIOCH, ILLINOIS
I. Site Name, Locaiion, and Description
The H.O.D. Landfill Superfund Site (the Site) is located within the eastern boundary of the
Village of Antioch in Lake County, in northeastern Illinois. See Figure 1. The Site consists of
approximately 51 acres of landfilled area out of the total 121.5 acres of property that make up the
facility. Although the landfilled area is continuous, it consists of two separate landfill areas,
identified as the "old landfill" and the "new landfill " The "old landfill" consists of 24.2 acres
situated on the western third of the property. The "new landfill" consists of 26.8 acres located
immediately east of the "old landfill." The two landfill areas have been legally delineated under
an Illinois Environmental Protection Agency (IEPA) permit. The location of the two landfill
sections'is shown in Figure 2.
There are approximately 14,300 people living within three miles of the Site. Approximately 40
private wells and 6 public water supply wells are in the vicinity, and are used for domestic
purposes, including drinking water.
The Site is bordered on the south and west by Sequoit Creek. Silver Lake is located
approximately 200 feet southeast of the Site. A large, seasonal wetland area extends south of the
Site from Sequoit Creek.
Surface drainage around the Site is generally toward the Fox River, located approximately five
miles west of the Site. Locally, surface water flows from the Site toward Sequoit Creek. Sequoit
Creek flows west from Silver Lake along the southern boundary of the Site, then flows north
along the western boundary of the Site. Approximately 250 feet north of the northwestern corner
of the Site, the creek channel turns west and the creek flows approximately two miles before
discharging into Lake Marie. Lake Marie eventually discharges into the Fox River.
The landfill cover is continuous across the filled areas of the Site. The landfill cover ranges in
thickness from a total of 49 inches to 87 inches based on borings and test pits performed during
the Remedial Investigation (RI). Refuse was generally encountered beneath the existing landfill
cover. The landfill cover supports a healthy vegetative layer. Since the closure and capping of
the Site in 1989, precipitation has resulted in erosional rills and gullies in some areas of the
landfill cover. See Figure 3. Several areas of differential settlement and stressed vegetation have
developed since the cap construction. Minor leachate seeps, animal burrows, and landfill gas
(LFG) emission areas have also been noticed since the cap construction.
Based on aerial photographs and a 1960 United States Geological Survey (USGS) topographic
H.O.D. ROD; September, 1998 1
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map of the Site area, the eastern portion of the Site was a wetland area prior to landfill
development. Seasonal wetlands exist within only the low elevation portion of the Site, south of
the "new landfill" area. The wetlands are limited to tr 2 areas outside the delineated landfill
boundaries. Sequoit Creek flows from Silver Lake by way of two stream channels which
eventually join and proceed through the seasonal wetlands.
Four distinct, depositional units make up the Site geology. The four units are, in order of
increasing depth and age, the surface soils, the surficial sand, the clay-rich diamict, and the deep
sand and gravel. For Site hydrogeology, the hydrostratigraphic units of concern that underlie the
Site are, in order of increasing depth, the surficial sand aquifer, the clay-rich diamict aquitard,
and the deep sand and gravel aquifer. The June, 1998 Feasibility Study (FS) contains more
information on the geology and hydrogeology of the Site.
A. Land Use
The Little Silver Lake Subdivision in unincorporated Lake County is located east of the Site.
Agricultural land, scattered residential areas, and undeveloped land are located to the north. A
large industrial park area (Sequoit Acres Industrial Park), which was constructed on former
landfill and fill areas, is located west of the Site and borders Sequoit Creek. Several companies
have operations on Sequoit Acres Industrial Park, including some companies that are designated
as small quantity hazardous waste producers.
The Site is currently zoned as "M2," according to the Village of Antioch. This designation
covers special use manufacturing and industrial purposes, and includes landfills. The Site was
closed and capped under EEPA permitting in 1989. Sequoit Acres Industrial Park has been
designated an "Ml" (light industrial) zoning area by the Village of Antioch.
Future land use is expected to be similar to current land use. According to Village of Antioch
officials, the Village of Antioch is expected to experience significant population growth in the
next five years.
B. Groundwater Use
The Village of Antioch obtains its water from six water supply wells screened in the deep sand
and gravel aquifer. This is the same aquifer under and adjacent to the Site. The Village wells are
located west and southwest of the Site. The closest Village well to the Site, Village Well 4
(VW4), was decommissioned in 1997 and replaced with Village Well 7 (VW7), approximately
one mile southwest of the Site.
Privately owned wells in the vicinity of the Site are either screened in the same deep sand and
gravel aquifer as the Village wells, or in the deep, underlying dolomite. In particular, residents of
the Little Silver Lake Subdivision use these private wells. Household wastewater from the
subdivision is discharged to septic systems.
H.O.D. ROD; September, 1998 2
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Future groundwater use is expected to be similar to current use.
n. Site History and Enforcement Activities
A. Site History
Permitted waste disposal activities began at the Site in approximately 1963 and continued
through approximately 1984. The Site has been owned and/or operated by three distinct
companies:
• Cunningham Cartage and Disposal Company (1963 - 1965)
H.O.D. Disposal, Inc. (1965 - 1972)
• C.C.D. Disposal, Inc. (1972 - present, including merger with Waste
Management of Illinois, Inc. (WMII))
Murrill Cunningham, owner, operator, and president of the Cunningham Cartage and Disposal
Company, operated a 20-acre landfill (much of the "old landfill" area) at the Site from 1963
until August 1965. The property was then purchased by John Horak and Charles Dishinger,
who operated the Site under u> name H.O.D. Disposal, Inc. In December 1972, the 20-acre
landfill was conveyed to C.C.D. Disposal, Inc., and C.C.D. Disposal, Inc. purchased the
adjacent 60-acres of land to the east of the Site. WMII merged with H.O.D. Disposal, Inc. in
December 1972 and C.C.D. Disposal, Inc. in June 1973, gaining ownership of the entire Site.
An eastern portion of the Site is currently owned by the Village of Antioch. WMII operated
the landfill from 1973 until 1984 when the Site stopped accepting waste. During the time
WMII operated the landfill, portions of the "new landfill" area were opened for landfilling.
In June 1981, WMII submitted to the USEPA a Hazardous Waste Site Notification Form, as
required by Section 103(c) of CERCLA. The form indicated solvents, heavy metals, and
cutting and hydraulic oils were disposed of at the Site, in addition to municipal waste.
The USEPA conducted a Preliminary Assessment in 1983, a Site Inspection in 1984, and an
Expanded Site Inspection between 1986 and 1989. In 1989, the Site was closed, and a landfill
cover, leachate wells, and LFG vents were installed in accordance with the applicable
regulations in force at the time. The Site was placed on the National Priorities List (NPL) on
February 21, 1990, based on a Hazard Ranking Score (HRS) of 34.68 (out of 100), which was
above USEPA's eligibility threshold limit of 28.5 for Sites to be proposed for the NPL. The
USEPA identified a number of potentially responsible parties (PRP); however, only WMII
agreed to participate in the Remedial Investigation/Feasibility Study (RI/FS). An
Administrative Order on Consent (AOC) to perform the RI/FS was signed between USEPA
and WMII in August, 1990.
In May, 1990, WMII retained Montgomery Watson (formerly Warzyn) to support WMII's
RI/FS effort by preparing the Work Plan for Preliminary Site Evaluation Report/Technical
H.O.D. ROD; September. 1998 3
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Scope (PSERATS) and by subsequently performing the RI. The RI was conducted between
1990 and 1994. The final RI Report was approved by USEPA on February 14, 1997. The
draft Baseline Risk Assessment (BLRA) was submitted by ICF Kaiser (a WMH contractor) in
1994. WMH received comments on the BLRA from IEPA and USEPA in late 1996/early
1997. WMH responded to the BLRA comments, and the BLRA was approved by USEPA on
October 29, 1997.
Several investigations have been conducted at the Site and are listed below in approximate
chronological order. Additional details and the results of the investigations are described in
the RI Report.
• In 1965, prior to drilling and constructing VW4, three test holes were drilled (to
identify adequate thickness of water bearing units) in the Sequoit Acres Industrial
Park area.
• A soil investigation was conducted by Testing Services Corporation (TSC) in 1973 to
assess conditions for the expansion of the landfill and the construction of an on-site
maintenance building.
• TSC installed six groundwater monitoring wells for WMH in May, 1974.
• In 1982, TSC prepared a hydrogeologic report for the proposed landfill expansion to
the north.
• Five leachate samples were collected from leachate/gas wells and from a leachate
collection manhole in May, 1993. The analytical results and field parameters may be
found in Appendices O-3 through O-7 and Table 4-1 of the RI Report, respectively.
• A Preliminary Assessment (PA) was completed on February 11, 1983 by the field
investigation team (FIT) at the request of USEPA. The PA identified several data
gaps including determination of waste quantity and information related to possible
groundwater or surface water contamination.
• A Site Inspection was conducted on July 10, 1984 by the FIT. Groundwater samples
were collected from on-site monitoring wells. Analysis of groundwater samples
revealed the presence of elevated concentrations of zinc, lead, and cadmium.
Analysis of surface water samples did not reveal elevated levels of analyzed
parameters.
• Dames and Moore conducted a hydrogeologic assessment of the Site in 1985 at the
request of WMH.
• In January, 1986, IEPA collected groundwater samples from four residential wells
H.O.D. ROD; September, 1998 4
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located east of the Site. The samples were analyzed for nitrates, organic compounds,
and trace metals. The results of the chemical analysis indicated no trace metals and
no organic compounds were detected.
• An Expanded Site Investigation (ESI) was conducted by the FIT (Ecology and
Environment) during the period of 1987 through 1989.
• Between 1989 and July 1990, P.E. LaMoreaux & Associates, Inc. (PELA), on behalf of
WMII, conducted various Site investigations.
• Video camera logging of VW4 was conducted by PELA. Some areas of the well
appeared to be badly pitted.
• Patrick Engineering, Inc. (Patrick) prepared an Environmental Audit of Sequoit Acres
Industrial Park in 1989 on behalf of WMII. Patrick concluded that several potential
sources of soil and/or groundwater contamination existed in the Sequoit Acres
Industrial Park, including industry and landfilled areas containing fill and refuse.
• Shallow borings were drilled at three locations in October 1989 by Patrick for
Geoservices Inc. of Boynton Beach, Florida, to collect samples of the clay diamict for
laboratory permeability testing. Hydraulic conductivity values for the clay soils
ranged from 2.1 X 10~7 centimeters per second to 9 X 10"9 centimeters per second.
Results of the permeability testing of the clay diamict soils are summarized in Table 5
ofthePSERH'S.
• Five temporary leachate piezometers were installed at the "old landfill" for WMII by
Stratigraphies, Inc. in July, 1990. Leachate samples were collected for laboratory
analysis from temporary leachate piezometers in July and August, 1990. The
Stratigraphies report indicated clay underlies refuse at each of the temporary leachate
piezometer locations. Samples were analyzed for organics, metals, and indicator
parameters. Low levels of volatile organic chemicals (VOC), primarily alkenes and
aromatics, were detected in each of the leachate samples. Few detections of semi-
VOCs (SVOC) were noted in the leachate samples, with naphthalene being the most
commonly detected of the SVOCs. The RI presented specific leachate analytical data.
• A Hydropunch groundwater sample was collected near monitoring well US4S in May,
1990. The sample was collected from a fine to medium sand at a depth of about 20
feet below ground surface and was submitted for VOC analysis. VOCs detected in
the groundwater sample included cis-l,2-dichloroethylene (110.3 parts per billion
(ppb, equal to micrograms per liter O^g/l)), trans-1,2-dichloroethylene (1.4 ppb),
methylene chloride (2.7 ppb) and vinyl chloride (188.4 ppb).
• Groundwater quality samples were collected by WMII at 10 on-site monitoring wells
H O.D. ROD; September, 1998 5
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in July, 1990. Samples were analyzed for organics, metals, and groundwater quality
indicator parameters. Analytical results indicated that VOCs were detected in
samples collected from wells US4S (cis-l,2-dichloroethylene at 39.7 ppb; trans-1,2-
dichloroethylene at 1.8 ppb), US6D (trichloroethylene (TCE) at 0.7 ppb) and R103
(cis-l,2-dichloroethylene at 0.5 ppb and TCE at 4.0 ppb).
• The USGS, in cooperation with USEPA, performed an evaluation of the aquifer pump
test data collected during the ESI Report and presented the results in a 1990 report
titled "Determination of Hydraulic Properties in the Vicinity of a Landfill Near
Antioch, Illinois."
• Leachate results from the 1996 and 1997 semi-annual compliance reports can be
summarized by ranges as follows: barium from 736 to 837 ppb, chromium from 12.3
to 20.5 ppb, iron from 6,680 to 11,600 ppb, lead from 5.0 to 7.1 ppb, magnesium
from 118,000 to 139,000 ppb, zinc from 21.9 to 49.5 ppb, 1,1-dichloroethane at 6
ppb, 1,2-dichloroethane from 6 to 13 ppb, 1,2-dichlcropropane from 9 to 17 ppb,
benzene from 12 to 19 ppb, ethylbenzene from 22 to 41 ppb, methylene chloride from
8 to 26 ppb, toluene from 140 to 210 ppb, TCE from 7 to 9 ppb, and vinyl chloride
from 11 to 15 ppb.
B. Enforcement Activities
The USEPA proposed adding the Site to the NPL on September 18, 1985, based on a Site
Inspection which found elevated levels of zinc, lead, and chromium in the groundwater (50 Efid.
Keg. 37,956 (1985)). During the public comment period, WMII challenged the proposed listing
of the Site based on disagreement concerning the HRS and hydrogeological conditions at the
Site. Following review of all comments, USEPA performed an ESI at the Site. The ESI led
USEPA to rescore the Site, based in part on a lowered estimate of the level of zinc releases, as
well as on newly discovered releases of TCE, trans- 1-2-dichloroethylene and total-1-2-
dichloroethylene to the groundwater. The Site was added to the NPL on February 21, 1990 (55
led. Reg.6162 (1990)).
On December 26, 1989, USEPA issued special notice to several PRPs and began negotiations for
performance of an RI/FS. These negotiations resulted in an AOC with WMII to perform the
RI/FS and to pay USEPA's oversight costs. WMII began an RI at the Site in August, 1990, and
the RI Report was approved by USEPA in February, 1997. WMII completed the FS in June,
1998.
The USEPA issued a demand letter to the PRPs on February 24, 1992 to recover past response
costs associated with the Site. When no settlement was reached by the close of the negotiation
period, USEPA nominated the Site for Alternative Dispute Resolution (ADR) on May 14, 1992.
The USEPA referred the cost recovery action to the Department of Justice for civil litigation on
June 30, 1992. On November 5, 1993, a Consent Decree provided for reimbursement of
H.O.D. ROD; September, 1998 6
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$636,000 in costs incurred by USEPA through August 19, 1990. This Consent Decree involved
13 PRPs, comprised of WMII, the Village of Antioch, and eleven generators. In November
1997, USEPA issued a number of information requests under CERCLA Section 104(e) in an
unsuccessful attempt to identify additional PRPs.
ffl. Highlights of Community Participation
The USEPA developed a Community Relations Plan in 1993 to ensure that the public was well
informed during the Superfund process. As part of this process, residents near the landfill were
interviewed to find out their concerns. The main concerns were drinking water, property values,
and being kept informed of future Site events.
In order to respond to these needs, USEPA produced a fact sheet and held public information
meetings in 1993. In April, 1993, USEPA issued a press release announcing the start of the RI
by WMII. Since then, USEPA has perceived community interest to be low, and USEPA's
public involvement efforts were correspondingly reduced. In December, 1997, USEPA met with
Village of Antioch officials in Antioch to provide an update of Site-related activities and to
discuss the Village's concerns.
The USEPA issued the Proposed Plan to the public on July 22, 1998. In order to encourage
public participation in the remedy selection process consistent with Section 117 of CERCLA,
the RI/FS and the remainder of the Administrative Record file for the Site were made available
for review by the public at the Antioch Public District Library in Antioch, and at USEPA
Region 5 offices in Chicago, during and before the public comment period. The public
comment period ran from July 22 through August 20, 1998. An announcement regarding the
public comment period and describing the preferred alternative in the Proposed Plan was
published in the Daily Herajd newspaper on July 22, 1998 and in the Antioch News Reporter
newspaper on July 24, 1998.
A public meeting was held in the Antioch Village Hall on August 11, 1998. The meeting was
attended by approximately 40 people, including representatives from WMII, Montgomery
Watson (a WMII contractor), the Lake County Health Department, the Village of Antioch, and
local newspapers. At the meeting, representatives from USEPA summarized the findings of
the RI/FS, explained the Proposed Plan and remedy selection process, answered questions
from the public, and accepted statements from members of the public. Comments were
recorded by a court reporter, and a transcript of the meeting is included in the Administrative
Record.
The USEPA received a total of six written submittals from the public during the public
comment period. This included written comments from some PRPs (WMII and the Village of
Antioch). Public comments recorded during the public meeting and a comment from the
United States Army Corps of Engineers are included in the Responsiveness Summary
(Appendix A) of this ROD, but are not included in the count of six written submittals from the
H.O.D. ROD; September, 1998 7
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public.
The USEPA's responses to comments received during the public comment period are contained
in the Responsiveness Summary. In some cases, USEPA summarized or consolidated
comments to present a more readable document.
This ROD presents the selected remedy for the H.O.D. Landfill Superfund Site in Antioch,
Lake County, Illinois, chosen in accordance with CERCLA, as amended by SARA, and the
NCP. The decision for the Site is based on the Administrative Record. The Administrative
Record includes all items and documents such as work plans, data analyses, public comments,
transcripts, and other relevant information provided by Section 113 of CERCLA. The
Administrative Record Index is attached to this ROD as Appendix B. The provisions for
public participation in remedy selection in Section 113flc)(2)(B)(i-v) and Section 117 of
CERCLA have been satisfied.
IV. Scope and Role of the Response Action
The selected remedy will be a final Site-wide remedy. The main threat to human health
identified in the BLRA is through the ingestion of vinyl chloride-contaminated groundwater.
Vinyl chloride, a carcinogen, has appeared in a monitoring well, nearby and downgradient of the
Site, at levels above the maximum contaminant level (MCL) established by USEPA and above
the Illinois Pollution Control Board Groundwater Quality Standards for drinking water aquifers.
The NCP requires remediation of drinking water sources with contaminant levels above MCLs.
The Human Health Risk section shown later in this ROD further describes the vinyl chloride
threat and lesser threats.
The Site will be remediated according to USEPA's Presumptive Remedy guidance. This
guidance establishes containment as the presumptive remedy for CERCLA municipal landfills,
such as the H.O.D. Landfill. Containment technologies are appropriate for municipal landfill
waste because the volume and heterogeneity of the waste generally make treatment of the waste
impractical. As is true for this Site, the presumptive remedy also often includes leachate
collection and landfill gas collection, as well as institutional controls such as deed restrictions.
Containment through waste cap improvements minimizes infiltration of rainwater into the waste
mass, thereby minimizing leachate generation and slowing contaminant migration from the waste
mass into the groundwater. Waste cap improvements also prevent direct contact with the waste
mass. Leachate collection reduces potential migration of leachate to surface water and
groundwater. Landfill gas collection prevents direct inhalation and uncontrolled migration of
gases, eliminates potential explosion hazards, and significantly reduces the dissolution of VOCs
from the landfill gas into the leachate or groundwater.
H.O.D. ROD; September, 1998
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V. Summary of Site Characteristics
A. Nature and Extent of Contamination
The following media were sampled during the RI: groundwater (from Site and nearby
monitoring wells, Village wells, and Little Silver Lake Subdivision private wells), leachate,
landfill gas, surface water, sediments, and surface soils. A monitoring well and piezometer
location map is included as Figure 4. Leachate piezometer and gas probe locations are shown on
Figure 5. Surface water, sediment, and surface soil sampling locations are shown in Figure 5 of
the FS. The Village of Antioch and private water supply well sampling locations are shown in
Figures 6 and 7 of the FS, respectively. Tables 4 through 9 of this ROD present summaries of
VOC, SVOC, pesticides, and polychlorinated biphenyl (PCB) analytical results for sampling
conducted during the RI. Based on results of the BLRA (see Section VI), ingestion of vinyl
chloride, a VOC, presents the only significant health risk associated with the Site.
The groundwater samples collected from wells screened in the surficial sand immediately
adjacent to the "old landfill" area in which VOCs were detected were found to contain relatively
low concentrations of alkenes and carbon disulfide. (Carbon disulfide was detected during the
RI in the Round 1 and Round 2 samples collected from well Gl IS at concentrations of 0.8J ppb
and 18 ppb, respectively. 1,2-Dichloroethylene was detected during the RI in the Round 1 and
Round 2 samples collected from well US4S at concentrations of 35 ppb and 44 ppb, respectively.
"J" indicates an estimated value below the detection limit.) VOCs were not detected in the
surficial sand wells located on the west or south sides of Sequoit Creek during either of the two
rounds of groundwater samples obtained as part of the RI. See Table 6 and Figure 4. In Table 6,
wells with a "D" designation indicate sampling from the deep sand and gravel aquifer, wells
with an "I" designation indicate sampling from the clay diamict, and wells with an "S"
designation indicate sampling from the surficial sand aquifer. The second page of Table 6
includes private well and village well results.
For the clay diamict sampling, TCE was detected in one groundwater monitoring well (US6I)
which is located at the southeast corner of the "old landfill" area. The TCE concentrations in
groundwater samples collected from that monitoring well since 1987 exhibit a decreasing trend.
VOCs were not detected in the on-site deep sand and gravel wells. VOCs (vinyl chloride and
1,2-dichloroethylene) were detected in groundwater samples from one deep sand and gravel
monitoring well (US3D), which is located southwest of the Site, in the industrial park. VOCs
(vinyl chloride, acetone and 1,2-dichloroethylene) were also detected in one water supply well,
VW4, which was the closest Village well to the Site. This well was decommissioned in 1997,
and replaced with VW7, farther west of the Site.
Although VOCs were detected in the on-site surficial sand wells, they were not present in the
on-site deep sand and gravel wells, indicating that downward migration of VOCs from the
H. O.D. ROD; September, 1998 9
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surficial sand through the clay diamict does not appear to be occurring. The differences in the
hydraulic heads from the surficial sand and the deep sand and gravel also indicate that the clay
diamict may be continuous and may provide resistance to downward vertical flow (i.e., low
vertical hydraulic conductivity).
Concentrations of VOCs (2-Hexanone and 4-rr-ethyl-2-pentanone) were estimated below the
detection limits in one surface water sample which was collected from Sequoit Creek during
Round 1. This sample was collected adjacent to the northwest corner of the landfill. No other
VOCs, SVOCs or Pesticides/PCBs were detected in any of the other Round 1 or Round 2
samples. See Table 7.
The concentrations of inorganic constituents detected hi the surface water samples are much
lower than the concentrations detected in the leachate samples. Results presented in the RI
indicate that Site leachate has not had a detectable effect on Sequoit Creek surface water
quality.
No VOCs or pesticides/PCBs were detected in the sediment samples collected from Sequoit
Creek. Concentrations of SVOCs that were estimated below the detection limits consisted of
polynuclear aromatic hydrocarbons (PNAs), with the exception of bis(2-ethylhexyl) phthalate,
which is a common laboratory contaminant. The PNAs could be due to other industrial
sources, as they are common to urban industrial areas. See Table 8.
Surface soil samples during the Round 1 sampling activities were collected from areas
exhibiting discolored soils, leachate seeps, stressed vegetation, or standing water. These
locations were chosen as "worst case" samples in order to document the potential effects of the
Site's LFG and leachate on the shallow surface soils of the Site.
The surface soil analytical results generally indicate that concentrations of VOCs (primarily
aromatics and methylene chloride/acetone) and SVOCs (primarily phthalates and PNAs) are
present in areas with visible evidence of potential impact. No VOCs and few SVOCs were
detected in a sample collected from an off-site location north of the "new landfill" in an urea of
standing water and apparent stressed vegetation. Similarly, fewer VOCs and SVOCs were
detected off-site in a sample collected from a wetland area near the southeast corner of the "old
landfill" and in a sample collected from the wetland area east of the "new landfill." See Table
9.
B. Contaminant Fate and Transport
Migration pathways are defined as routes along which contaminants migrating out of, and
away from, a contaminant source (e.g., landfill leachate or LFG) travel towards groundwater,
surface soil, surface water, and sediments. The primary vehicle for mobilization of VOCs is
partitioning of contaminants from LFG into the leachate and interstitial water in the waste.
The primary transport mechanism from the source areas is via LFG, leachate, or groundwater
H.O.D. ROD; September, 1998 10
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migration.
LFG generation in the reducing environment of the landfill is largely the byproduct of
anaerobic decomposition of the refuse. Gas pressure within the landfill builds, and gas
migrates away from the waste mass through the path of least resistance. Passive gas flares
have been installed in the landfill to vent and burn off this gas but are not totally effective.
Therefore, some LFG appears to be migrating horizontally and vertically through the surface
soils in some locations.
Leachate is produced through the solution and suspension of chemicals mobilized by the
interaction of the interstitial water with the waste mass and LFG. The water necessary for the
formation of leachate may enter the landfill interior in the following ways: 1) stormwater
infiltration through the cover, 2) groundwater seepage through the subsurface, and 3) moisture
present within the waste at .^e time of placement within the landfill.
Leachate may migrate out of the landfill in the following ways:
• Release and transport by groundwater
• Release directly to surface water and sediments
• Release through the landfill cover and potential release to the surface soils, surface
water, and sediments
Potential chemicals of concern in landfills, such as those at the Site, can be mobilized by the .
interstitial water passing through the waste and dissolving chemicals which form leachate, and
by chemicals in LFG partitioning into the leachate. This leachate may then migrate from the
landfill to affect potential receptors.
However, a landfill itself functions as a bioreactor, where the organic substrate (the organic
fraction of the waste mass), in the presence of moisture, produces an anoxic (reducing)
environment which degrades organic compounds and stabilizes the waste mass. This reaction
produces LFG, which is primarily a combination of methane and carbon dioxide, with trace
concentrations of VOCs.
The potential transport of the chemicals of concern to groundwater may be minimized by the
low permeability clay underlying the waste, similar to the clay underlying the entire Site, and
by the organic materials and peat, similar to that underlying areas of the southern portion of
the "old landfill." Low permeability clay materials, peat, and organic materials have a high
capacity to adsorb the chemicals of concern, thereby helping to significantly reduce the
concentrations of chemicals entering the groundwater. Further attenuation occurs by mixing,
adsorption/desorption, biodegradation, oxidation and reduction reactions, precipitation, and
volatilization as groundwater moves away from a landfill.
Once generated, LFG migrates from areas of high gas pressure to areas of low pressure (above
H.O.D. ROD; September, 1998 11
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the fluid levels in the landfill) and is flared (combusted) or emitted to the ambient air via the
following release pathways:
Leachate piezometer/gas wells
• Unlit gas flares
Fissures in the landfill cover
The ensuing dilution of the gas in the air is affected by wind speed, turbulence, temperature,
height of the release point above the surrounding area, the roughness of the surrounding area,
and by decomposition through direct photolysis.
Some LFG chemical constituents commonly partition into the soil (including the landfill cap)
or vadose zone, interstitial soil water. The infiltration of this vadose zone water presents a
potential transport pathway for LFG chemical constituents to enter the leachate and eventually
the surficial sand aquifer. This mechanism can contribute to leachate and/or groundwater
contamination.
Leachate samples collected from the Site contained a variety of chemical compound groupings,
including chlorinated alkanes and alkenes, ketones, aromatics, phenols, phthalates, PNAs, and
PCBs.
The biodegradation of waste materials in a reducing environment produces various chemical
degradation compounds in the leachate. The biodegradation process may consume much of the
organic contaminant mass and produce ammonia, methane, carbon dioxide, and other anaerobic
biodegradation and abiotic intermediate and end products. These compounds are detected in
the landfill leachate and gas, and indicate that a high level of anaerobic biodegradation is
occurring.
Stormwater percolating vertically through the landfill cap into the waste mass and groundwater
flowing horizontally into the waste mass provide the transport and mixing vehicle that
promotes anaerobic biological and abiotic degradation of the chemical compounds. During this
process, some of the compounds and degradation products remain or are introduced into the
liquid leachate, while other compounds partition into the gas phase. The chlorinated alkenes
and alkanes which were detected in the leachate tend to biodegrade more readily under the
reducing conditions present in the landfill.
Leachate may migrate from the waste mass into the surrounding subsurface soils or
groundwater, or may enter the ambient environment via surface seeps. As leachate moves
from the waste mass, conditions become less anaerobic (less reducing), providing an
environment more favorable to aerobic degraders. It is under these conditions that the
phenols, ketones, aromatics, and to a lesser degree the PNAs and phthalates, will be more
readily biodegraded.
H.O.D. ROD; September. 1998 12
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In addition to biodegradation, adsorption occurs in both the waste mass and in the subsurface
environment as leachate moves through the system Adsorption is a significant attenuation
mechanism for the relatively less soluble and less degradable leachate constituents such as the
PNAs, phthalates, and PCBs. Leachate from the landfill can mix with and be transported by
groundwater, so dilution and groundwater attenuation processes may also influence
contaminant concentrations.
In addition to subsurface movement, a leachate seep was observed in an erosional cut in the
cover near the center of the south slope of the "new landfill." The leachate flows from the
landfill and down the erosional cut towards the base of the landfill where standing water was
periodically observed during wet seasons.
Relatively higher concentrations of metals were detected in the leachate than in the surrounding
groundwater, soils, surface water, or sediments. The concentrations of metals detected in the
leachate, except for barium, are all below the lEPA-specified typical range of values for
leachate from municipal solid waste landfills. Metals in leachate can migrate into the ambient
environment along the same pathways described above. Metals concentrations in leachate tend
to increase as metal complexes dissolve into leachate from the waste mass under highly
reducing anaerobic biodegradation conditions present in the landfill. These conditions are not
suitable for metals precipitation which would reduce the metals concentrations in the leachate.
Concentrations of metals in leachate that migrate to the surface and subsurface environments
are attenuated through dilution, adsorption, precipitation, and oxidation/reduction.
Concentrations of metals in the leachate will drop rapidly when exposed to oxygen, as metal
complexes form.
VOCs were detected in groundwater samples from the on-site surficial sand monitoring wells.
Shallow groundwater within the surficial sand flows toward and discharges to Sequoit Creek.
Strong horizontal gradients are present in the surficial sand and result in rapid, shallow
groundwater flow (4 to 215 feet per year). Groundwater elevation data also indicate the
presence of a very slight downward vertical gradient within the surficial sand aquifer and the
clay-rich diamict aquitard. However, the RI data indicate that the hydraulic conductivity of the
surficial sand is more than two orders of magnitude greater than that of the clay-rich diamict.
Therefore, dissolved constituents will readily migrate horizontally toward Sequoit Creek rather
than vertically into the clay aquitard.
Based on the information presented, groundwater flow and contaminant migration in the
vicinity of the southeast and southwest corners of the "old landfill" are toward Sequoit Creek,
with the shallow groundwater discharging to the Creek. The surface water and sediment
analytical results indicate that the contaminants detected in on-site shallow groundwater
samples have not migrated to the Creek.
TCE was detected at one Site well in the clay till aquitard. This compound will migrate slowly
with groundwater flow in the clay till. Deep groundwater flow is slow and predominantly
H.O.D. ROD; September, 1998 13
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downward through the low permeability clay aquitard under the existing hydraulic gradient.
The attenuation of organic and inorganic contaminants is high within the clay, primarily
through adsorption. Further dilution and biodegradation can also occur, although
biodegradation is probably limited within the clay till.
For organic sampling in the deep sand and gravel aquifer, the contaminants of concern selected
for the BLRA (see Table 2) were detected in the off-site deep sand and gravel aquifer at the
three Village wells (VW3, VW4, and VW5) and at monitoring well US3D. The organic
contaminants of concern detected in the first round samples collected from the Village wells
included carbon disulfide, 2-methylphenol, and 4-chloroaniline. During the second round of
sampling, detected contaminants of concern included acetone, chloroform, cis-1,2-
dichloroethylene, and 1,2-dichloroethane. The organic contaminants of concern detected in
monitoring well US3D included vinyl chloride and 1,2-dichloroethylene in both sampling
rounds.
The contaminants detected in the deep sand and gravel can be transported with groundwater
flow in the deep sand and gravel at a flow velocity between 3 and 8 feet per year. These
contaminants are attenuated through dilution, biodegradation, and adsorption.
For inorganic groundwater sampling, arsenic was detected in samples from municipal wells
VW3 and VW5, but based on the background and downgradient data, arsenic may not be an
analyte associated with the Site. Beryllium was also detected in the off-site surficial sand
aquifer. However, beryllium was identified as a compound of potential concern only because .
background data for beryllium was not available. See the "Summary of Site Risks" Section for
further discussions of arsenic and beryllium.
Surface water does not appear to have been affected by the landfill. Low concentrations of two
ketone compounds were detected in one surface water sample. These compounds were not
detected in the second round of surface water sampling. As previously discussed, these
compounds would be significantly attenuated by adsorption, dilution, and volatilization in
surface water.
Inorganic contaminants of concern in the surface water included antimony, barium, and lead.
These metals in the surface water would also attenuate through dilution, adsorption to
particulate matter, and precipitation along the pathways discussed at the beginning of this
section.
S VOCs were the only compounds detected in two of the sediment samples collected from
Sequoit Creek along the perimeter of the "old landfill." The primary transport mechanism for
the migration of these organic compounds from the landfill to the Sequoit Creek sediments
would be migration and discharge of groundwater to Sequoit Creek. SVOCs are attenuated by
dilution and biodegradation and are adsorbed to soils and sediments. Once entrained in the
soils and sediments, these organic compounds will either be consumed through biodegradation
H.O.D. ROD; September, 1998 14
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or will be released to surface water and ground water, and further attenuated by dilution.
As described in the BLRA, the metals detected in sediments are arsenic and thallium. These
metals are attenuated through adsorption and precipitation as they migrate through the
pathways previously discussed. The metals can be released to the surface water under physical
agitation or can be dissolved into surface water through the reduction of the metals in a
reducing sediment environment. Once in the surface water, oxidation is likely to cause the
metal complex to precipitate and be transported with surface water flow.
The surface soil organic and inorganic impacts on the Site appear to be primarily related to
localized LFG and leachate seeps through the landfill cap. As the leachate and LFG migrates
through the cover material, many VOCs are volatilized into the air. Other less volatile and
inorganic constituents are adsorbed to the surface soils. Precipitation may then transport these
constituents to surface water and/or groundwater through overland runoff and infiltration.
Phthalates detected in the surface soils are strongly adsorbed to the organic materials in the
soils, and thus will resist leaching into the groundwater. To a limited extent, biodegradation
may also occur in surface soils. PNAs found in the surface soils are also strongly adsorbed to
soils, have low water solubilities, and are therefore not expected to be mobilized by
precipitation. Under aerobic conditions PNAs will undergo natural biodegradation. The
inorganics determined to be contaminants of concern in the BLRA generally were selected due '
to the lack of regional background data. These metals are attenuated in the surface soils.
Precipitation and oxidation also occur as the metal complexes are exposed to the atmosphere.
VI. Summary of Site Risks
A. Human Health Risks
The BLRA was conducted to characterize the current or potential future threat to human health
and the environment that may be posed by chemicals originating at or migrating from the Site.
The BLRA was primarily based on data and information obtained during the RI. The IEPA
and USEPA reviewed and commented on the BLRA, and USEPA approved the final BLRA on
October 29, 1997.
The first step in the risk assessment process was to select appropriate chemicals of potential
concern based on data from the RI and on naturally occurring background chemical
concentrations in the soils and groundwater. Chemicals of concern are those chemicals present
at the Site most likely to be of concern to human health and the environment. The selected
chemicals of concern and the rationales for selection are identified in Tables 2 and 3.
The next step was to identify potential and complete pathways of concern to human health.
The following pathways were selected for detailed evaluation:
H.O.D. ROD, September, 1998 15
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• Incidental ingestion of on-site surface soil by child/teenage trespassers on the Site
• Dermal absorption of chemicals in on-site surface soil by child/teenage trespassers on
the Site
• Dermal absorption of chemicals in Sequoit Creek surface water by child/teenage
trespassers on the Site
• Incidental ingestion of Sequoit Creek sediment by child/teenage trespassers on the
Site
• Dermal absorption of chemicals in Sequoit Creek sediment by child/teenage
trespassers on the Site
• Groundwater ingestion from public water supply wells by nearby adult residents
• Groundwater ingestion from private wells by nearby adult residents
• Groundwater ingestion from off-site groundwater monitoring wells by nearby adult
residents (surficial sand and the deep sand and gravel aquifers)
• Inhalation of VOCs while showering with groundwater from public water supply
wells by nearby adult residents
• Inhalation of VOCs while showering with groundwater from the off-site deep sand
and gravel aquifer by nearby adult residents
• Dermal absorption while showering with groundwater from public water supply wells
by nearby adult residents
• Dermal absorption while showering with groundwater from private wells by nearby
adult residents
• Dermal absorption while showering with off-site groundwater (surficial sand and the
deep sand and gravel aquifers) by nearby adult residents
• Inhalation of VOCs emitted from the landfill surface by nearby residents
Potential exposures within each identified pathway scenario were then calculated using
reasonable maximum exposure (RME) protocols, as is the USEPA-accepted method for a
BLRA. This method produced a conservative estimate of risks at the Site.
Chemical concentrations at the potential points of exposure were calculated and combined with
H.O.D. ROD; September, 1998 16
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information on the magnitude, frequency, and duration of potential exposures. Mathematical
models were used to estimate exposure point concentrations in indoor air while showering and
in ambient air from LFG emissions. Once this step was completed, RME excess lifetime
cancer risks and RME hazard indices were calculated for the predominant chemicals in each
exposure pathway.
Tables 4 through 9 summarize the SVOC, VOC, and pesticides/PCB analytical results for all
media considered in the RI (leachate, landfill gas, ground water, surface water, sediments, and
surface soil). These tables do not include inorganics results, since the BLRA showed only
vinyl chloride (a VOC) to be a significant risk (see below).
A summary of the BLRA results for carcinogenic risk is shown in Table 10. Only one
chemical in one pathway, ingestion of vinyl chloride from the off-site deep sand and gravel
aquifer groundwater, exceeded the established carcinogenic risk guideline of 1 x 104 used by
USEPA to determine if remedial action generally is warranted. The excess lifetime cancer
risks from inhalation and dermal absorption of vinyl chloride while showering with water from
off-site deep sand and gravel aquifer collectively add a risk of 9 x 10"5 to the ingestion risk of 8
x KT*.
The quantified, carcinogenic risk for vinyl chloride is based on MCL exceedances of vinyl
chloride in a single monitoring well (well US3D; see Figure 4 for the location) adjacent to and .
downgradient of the waste boundary at the Site. Table 6 shows that the vinyl chloride level in
US3D (in the deep sand and gravel aquifer) was as high as 35 ppb. The USEPA MCL for
vinyl chloride is 2 ppb; therefore, contaminant levels in US3D have been as high as 17.5 times
the MCL. Deep sand and gravel aquifer groundwater analytical results from wells near US3D
did not detect vinyl chloride during the RI.
Other chemicals that posed a lifetime carcinogenic risk greater than 1 x 10* were:
• Beryllium — ingestion and dermal absorption while showering with off-site
surficial sand and gravel aquifer groundwater (equating to a total carcinogenic risk
of 7X10-')
• Beryllium — dermal absorption from surface soil (equating to a total carcinogenic
risk of 1 X ICT5)
• Arsenic — ingestion of municipal well water (equating to a total carcinogenic risk
of9X KTJ)
In accordance with the Technical Work Plan for the BLRA, the concentrations of chemicals in
on-site groundwater were compared to Federa' and State standards and guidelines. See Table
22 for the Illinois Pollution Control Board (IPCB) Groundwater Quality Standards used.
H.O.D. ROD; September, 1998 17
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Beryllium was detected in 1 of 4 samples from off-site, surficial sand groundwater at a
concentration of 0.95 ppb. The surficial sand aquifer is not a drinking water aquifer.
Beryllium was not detected in on-site, surficial sand or deep sand and gravel groundwater, or
in off-site, deep sand and gravel groundwater. It was detected in 1 of 34 regional background
samples at a concentration of 1.0 ppb. The IPCB Groundwater Quality Standard for beryllium
is 4.0 ppb.
The two detected concentrations of arsenic in municipal well samples of 2.1 ppb and 4.3 ppb
are well below the USEPA MCL of 50 ppb, which is also the Illinois Pollution Control Board
Groundwater Quality Standard. The two detected concentrations are well within the regional
background range of 1-26 ppb.
Table 10 also summarizes noncarcinogenic risk levels. For an RME Hazard Index of greater
than one, USEPA concludes that there is a significant risk to human health or the environment.
Table 10 shows that no exposure pathways (individually or cumulatively) resulted in an RME
Index of greater than one, indicating that children or adults are not likely to experience
adverse, noncarcinogenic health effects from exposure to contaminants from the Site.
In summary, the BLRA evaluated risks to human health from potential and complete pathways.
These pathways included various exposure scenarios from surface soil, surface water, air,
sediment, groundwater from public and private wells, and groundwater from off-site wells.
Only one exposure scenario, ingestion of vinyl chloride from the off-site deep sand and gravel
aquifer groundwater, exceeded the MCL and/or the 1 X 104 carcinogenic risk threshold used
by USEPA to determine if remedial action generally is warranted.
This vinyl chloride exposure scenario is unlikely because use of groundwater from the. Site
vicinity has been prohibited by the Village of Antioch ordinance (Antioch Water Works and
Sewage Ordinance Sections 50.008, 52.009, and 52.011) requiring new residences within the
Village limits to connect to the municipal water supply system, and because VW4, near and
downgradient of the Site, has been taken out of service. Also, analysis of downgradient
private well samples to date have shown no detects of the contaminants of concern. Finally,
evidence to date does not indicate a contaminant plume in the groundwater that could migrate
toward active wells.
B. Ecological Risks
The BLRA contains an ecological risk assessment of the Site. The following information is a
summary of that assessment. More detailed information can be obtained by reading the BLRA,
available in the information repository. The ecological risk assessment evaluated exposure
pathways via surface water, sediments, surface soil, air, and leachate seeps.
For risk via surface water pathways, information from sampling Sequoit Creek indicated that
risks to aquatic and terrestrial wildlife are minimal. Chemical concentrations in shallow
H.O.D. ROD; September, 1998 18
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groundwater near the creek were low, suggesting that the overall contribution of groundwater to
surface water is not likely significant with respect to ecological exposures. For Sequoit Creek
surface water samples, only iron was detected at concentrations above background levels. But
the iron concentration was well below the chronic ambient water quality criterion, suggesting
that iron poses no threat to aquatic life. Organic contaminant concentrations were also low,
indicating an unlikely threat to aquatic life.
Terrestrial wildlife are also unlikely to be affected by contaminant concentrations in the creek.
For example, the lexicological limit of iron in mammals is well above that which could be
obtained by ingesting surface water from the creek. None of the low concentrations of
contaminants detected will bioaccumulate in aquatic prey; therefore, food-chain exposures are
not of concern.
The results of sediment sampling in Sequoit Creek indicate that contaminant concentrations do
not likely pose a threat to ? juatic life of the creek. Contaminant concentrations were generally
below the screening level sediment guidance values that have been developed. Terrestrial
wildlife are also unlikely to be at risk from exposure to creek sediment contaminants at the
concentrations detected.
Results of surface soil sampling showed that contaminant concentrations were low relative to
potentially toxic concentrations, indicating an overall low risk to terrestrial wildlife. Other
factors contributing to probable low risk are the sporadic distribution of contaminants in surface
soil that would likely result in sporadic wildlife exposure, and the fact that none of the detected
contaminants bioaccumulates in terrestrial food chains.
Contaminant criteria for the protection of wildlife species from exposure to airborne
contaminants have not been established, making an impact evaluation difficult. Measured
contaminant concentrations from the landfill gas samples are below threshold limit values
established for human workers. Assuming wildlife species are no more sensitive than humans to
inhalation exposure of VOCs, the concentrations measured in the landfill gas are not likely to
cause adverse effects in soil-dwelling species. Burrowing and soil-dwelling species are likely to
experience the greatest exposures because they can be exposed to contaminants in soil gas prior
to dispersion and dilution of the gas on the landfill surface.
Terrestrial wildlife exposure to contaminants present in leachate was judged to be limited
because surface seeps flow intermittently and because other surface water that could serve as a
source of drinking water for wildlife is accessible and prevalent in the surrounding area. It is
unlikely that the contaminant concentrations found in the surface leachate could be such to cause
toxicity in intermittently exposed wildlife. Although many contaminant concentrations detected
in leachate seep water were above those that could be toxic to certain aquatic life, the overall
effect of such toxicity, if occurring, is considered very low, given the size of the seeps relative to
other available habitat in the area.
H.O.D. ROD; September, 1998 19
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Based on observations of the conditions of the vegetative communities of the Site, local
vegetation, including terrestrial plants, appeared to be unaffected by surface soil contaminants,
exposure to landfill gas via stomatal uptake, or exposure to surface leachate via uptake through
roots or leaves.
In conclusion, pathways exist by which aquatic and terrestrial wildlife might be exposed to
contaminants of potential concern present at or migrating from the Site. Overall, however,
contaminant concentrations are such that potential risks to plants, aquatic life, and terrestrial
wildlife are estimated to be minimal. Visual observations of the character and composition of the
terrestrial and aquatic communities of the Site suggest a relatively healthy community. These
observations, combined with predictions of low exposure and risk, support the conclusion that
biological populations and communities of the area have not been adversely affected by
contaminants present at or migrating from the Site.
C. How Current Risks Compare with Remediation Goals
The following remedial action objectives are pertinent to Site remediation.
• Preventing direct contact (dermal contact or ingestion) with impacted soil and landfill
contents
• Minimizing infiltration and contaminant leaching to groundwater
• Controlling surface water runoff and erosion
• Collecting and treating contaminated leachate to prevent further migration of
contaminants from the source area
• Controlling and treating LFG
These objectives are consistent with the presumptive remedy objectives identified in the USEPA
"Presumptive Remedy for CERCLA Municipal Landfill Sites" guidance of September, 1993.
Also implementation of the selected remedy (described in Section IX of this ROD) of waste cap
improvements, gas collection and treatment upgrades, leachate collection upgrades, leachate
treatment, monitored natural attenuation, and institutional controls will achieve the remedial
action objectives listed above.
The current risk that is driving USEPA's decision to remediate the Site under CERCLA is the
carcinogenic risk of ingesting and showering with vinyl chloride-contaminated water. This risk
has been identified in the BLRA as approximately 9 X 10"4. See Table 10. The remediation
goal for groundwater from drinking water aquifers on and near the Site are for contaminant levels
not to exceed EPA Groundwater Quality Standards, which are at or below MCLs, for USEPA
Safe Drinking Water Act National Primary Drinking Water contaminants. Implementation of the
H.O.D. ROD; September. 1998 20
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selected remedy identified in this ROD, using the groundwater remediation goal described, will
reduce carcinogenic risks to a level of between approximately 1 X 10"* and 1 X 10"6 or less,
consistent with the remediation goals identified in the
Actual or threatened releases of hazardous substances from the Site, if not addressed by the
selected remedy, may present a current or potential threat to public health, welfare, or the
environment.
VII. Description of Alternatives
In addition to the No Further Action (NFA) alternative, the sets of alternatives are presented as:
Capping (Cl, C2, and C3), Landfill Gas Collection and Treatment (Gl, G2, and G3), Leachate
Collection (LCI, LC2, LC3, and LC4), Leachate Treatment and Disposal (LT1, LT2, and LT3),
and Groundwater Monitoring (GW1 and GW2). Regardless of the alternatives selected, the
following Site-related features will be implemented or will continue to be implemented:
• Institutional controls, including restrictions on private well use
• Site access restrictions, including fencing, locked gates, and warning signs
• Post-closure care consisting of cap maintenance, storm water control, landfill gas
collection, and leachate collection and treatment
• Groundwater monitoring
Tables 11, 12, and 13 list the chemical-specific, location-specific, and action-specific applicable
or relevant and appropriate requirements (ARAR), respectively, for the Site. The alternatives
will be evaluated against the major ARARs in the next section ("Summary of Comparative
Analysis of Alternatives").
Table 14 provides a brief description of each alternative. Table 15 summarizes capital costs,
operation and maintenance (O&M) costs, and present worth values for each alternative. A
discount rate of seven percent is used, consistent with USEPA's Office of Solid Waste and
Emergency Response (OSWER) Directive No. 9355.3-20.
A. The No Further Action Alternative
The NCP requires the "No Action" or "No Further Action" (NFA) response alternative to he
carried through detailed analysis. Under the NFA alternative, no further remedial actions
would be implemented at the Site under CERCLA. However, the routine O&M activities
currently being performed at the Site under the existing IEPA permit, which include cap
maintenance, and O&M of the existing passive LFG and manual leachate collection systems,
would continue. The groundwater monitoring activities being performed at the Site would also
H.O.D. ROD; September, 1 998 21
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continue under this alternative. See Figure 4 for existing monitoring well and piezometer
locations, and Figure 5 for existing gas and leachate extraction devices. The NFA alternative
includes the gas collection and treatment alternative Gl, the leachate collection alternative
LCI, the leachate treatment alternative LT1, and the groundwater monitoring alternative GW1.
These four alternatives are described later in this section. The existing Site security fence and
deed restrictions would remain in place along with all existing Site control features, including
the in-place landfill cover, and the leachate and LFG collection and control systems. The
following estimated cost is associated with the NFA alternative:
Capital Cost $923,200
Annual O&M $196,360
Total Present Worth (30 yrs @ 7%) $3,360,000
The costs for decommissioning VW4 and installing VW7 are included hi the above cost
estimate. The decommissic ning of VW4 and installation of VW7 have already been completed
at a cost of $652,800, and VW4 will eventually be abandoned at an estimated cost of $39,400.
B. Capping Alternatives
1. Cl: Landfill Cap Restoration and Maintenance .
This alternative involves using cover materials from the existing cap (or off-site clay, if
necessary) to restore the cap to the approximate grades which existed when the Site was closed
in 1989. Based on observations and performance to date, the "old landfill" has an excellent
vegetative cover and is very uniform over the entire area. The "new landfill" area has some
limited areas of erosion, differential settlement, and resulting ponded water. Therefore, the
cap repairs would be performed on the "new landfill" area, with limited potential repairs on
the "old landfill" area. The cap repairs would be performed by supplementing the existing
cover, thus adding thickness to the existing soil cover of 49 to 87 inches. (This soil cover
thickness is documented in the RI Report.) Alternative Cl would involve stripping and
stockpiling existing cover soils in the low areas and other areas to be repaired on the Site.
Clay soils from the existing cover or from an off-site source would be compacted into the low
areas and used to repair leachate seeps. The stockpiled cover soils, along with necessary
supplementary soils from an off-site source, would then be regraded atop the compacted clay to
promote drainage and eliminate surface water ponding. After regrading is completed to
promote drainage, a 12-inch thick soil layer would be placed on the repaired areas and seeded
to establish vegetation. The resulting dual layer cap would meet or exceed the final cover
specifications embodied in 35 IAC 807 (which call for "a compacted layer of not less than two
feet of suitable material").
Construction activities would include the removing vegetation; stockpiling of topsoil to be
reused as vegetation layer soils; consolidating the off-property waste at the northern edge of
the "old landfill" onto Site property; regrading, placing, and compacting the clay soils; placing
H.O.D. ROD; September, 1998 22
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the uncoinpacted, vegetative layer soils; and re-establishing the vegetation. The existing
landfill access roads are adequate; therefore, the construction of additional access roads is not
included under this capping alternative. Construction activities would be planned to avoid
encroaching on or impacting the adjacent wetlands or floodplain.
The regrading of the Site would be performed to improve1 areas of the landfill that have been
affected by erosion and/or settlement, to create and maintain a continuously sloped surface
sufficient to maintain positive drainage over and off the Site. The soil in the area of leachate
seeps would be excavated and consolidated in the low areas. The resulting excavation would
be backfilled and compacted with clay soils, effectively sealing the cover. The existing cover
soil thickness should provide sufficient cut and fill material balance for these regrading
activities. Off-site soils would be used, only if necessary. The Site would be graded to a
minimum two percent slope and the side slopes would be no steeper than a slope of 4 times
horizontal to 1 times vertical (4H:1V). The exception to this would be in the "old landfill"
area next to Sequoit Creek, where some of the side slopes exceed 4H:IV. However, these
slopes have been in place for at least 10 years, and will not be significantly affected by
regrading. There are no signs of beginning slope failure, and the vegetation in these areas
adds to the stability of the slopes. In the "new landfill" area, the existing side slopes range
from 4H:1V to 6H:1V, and, therefore, should not hinder the regrading effort.
Appropriate erosion control measures to protect nearby Sequoit Creek and the adjacent
wetlands would be implemented prior to construction activities. These measures may include
construction of berms/silt fences, rip-rap and straw bale dikes, and use of temporary cover
material.
After repairs to the soil cap are made, maintenance of the cap would include mowing at a
minimum of twice per year, and quarterly perimeter ditch inspection and maintenance.
Maintenance of the ditches would include removal of silt and debris. Quarterly inspections
would include walking the Site and visually noting signs of erosion, settlement, or other
damage. Noticeable, significant cover damage would be repaired. Although the majority of
settlement on the Site has already occurred, additional differential settlement could occur as a
result of continued or upgraded LFG and/or leachate extraction. However, any such
settlement would be repaired by stripping soils, placing and compacting clay in the settled
areas, and regrading the stockpiled soils as part of routine maintenance.
Infiltration would be reduced by over two inches per year (from 3.9 inches) by these cap
improvements. Approximately 1.6 inches/year of infiltration would be expected following the
implementation of this cap alternative. Table 16 summarizes the Hydrologic Evaluation of
Landfill Performance (HELP) modeling results of the FS.
Construction would be expected to take approximately six weeks and may be completed in one
construction season (May-October) with the following estimated cost:
H.O.D. ROD; September, 1998 23
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• Capital Cost $1,370,000
• Annual O&M $72,000
• Total Present Worth (30 yrs @ 7%) $2,270,000
2. C2: Augmentation of the Existing Landfill Cap
This alternative involves using clay and cover materials from the existing cap to rework the cap
over both the old and new landfill areas. The reworked cap would be constructed by stripping
the existing soil cover, stockpiling the soils for later use, placing a two-foot compacted clay layer
atop the entire landfill using on-site and off-site clay sources as necessary, and replacing the
stockpiled soil in a two-foot uncompacted rooting zone/cover layer to support vegetation. The
resulting dual layer cap would meet or exceed the final cover specifications embodied in
35 IAC 807. The additional two feet of material would help to facilitate the post-closure goal of
minimizing future cap maintenance by providing an additional protective layer conducive to
vegetative rooting.
Construction activities would include the removing vegetation; stockpiling of soils to be used as
vegetation layer soils; consolidating the off-property waste at the northern edge of the "old
landfill" onto Site property; regrading, placing, and compacting the clay soils; placing the
uncompacted, vegetative layer soils; and re-establishing the vegetation. The existing landfill
access roads are adequate; therefore, the construction of additional access roads is not included
under this capping alternative. Construction activities would be planned at the landfill to avoid
encroaching on or impacting the adjacent wetlands or floodplain.
The regrading of the Site will be performed to improve areas of the landfill that have been
affected by erosion and/or settlement, to create and maintain a continuously sloped surface
sufficient to maintain positive drainage over and off the Site. Recompaction of the cover would
reduce infiltration of surface water by establishing a less permeable barrier layer. All work
would be expected to be performed using existing on-site soils and supplemental off-site borrow
soils. The Site would be graded to a minimum two percent slope and the side slopes would be no
steeper than 4H: IV. The side slopes in the "old landfill" area next to Sequoit Creek, where some
of the side slopes exceed 4H:IV, would require some amount of regrading to ensure slope
stability following placement of the additional cover soils in these areas. The tops of the slopes
would likely be pulled back, and the compacted clay and cover soils would be regraded on the
reduced slopes. A detailed analysis of the slope regrading and reconfigurations would be part of
the Remedial Design (RD) for the Site. In the "new landfill" area, the existing side slopes range
from 4H: 1V to 6H: 1V, and, therefore, should not hinder the regrading effort.
Appropriate erosion control measures to protect nearby Sequoit Creek and the adjacent wetlands
would be implemented prior to reworking the cap. These measures may include construction of
berms/silt fences, rip-rap and straw bale dikes., and use of temporary cover material.
After the reworking of the soil cap, maintenance of the cap would continue to be required and
H.O.D. ROD; September, 1998 24
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would include mowing at a minimum of twice per year, and quarterly perimeter ditch inspection
and maintenance. Maintenance of the ditches would include removal of silt and debris.
Quarterly inspections would include walking the Site and visually noting signs of erosion,
settlement, or other damage. Any damage would be repaired. Although the majority of
settlement on the Site has already occurred, additional differential settlement could occur as a
result of additional weight from reworking the existing landfill cover. However, no additional
thickness of cover soils is planned to be placed; therefore, settlement would not be expected to be
significant for this option.
Approximately 2.0 inches/year of infiltration would be expected following the implementation of
this cap alternative. This infiltration value is greater than that of Cl because of the greater
thickness of soil atop the compacted clay, allowing a greater volume of pore water to collect atop
and eventually infiltrate through the compacted clay. See the Table 16 HELP model results for
infiltration values.
Construction would be expected to take approximately 20 weeks and may be completed in one
construction season (May-October) with the following estimated cost:
• Capital Cost $4,925,000
• Annual O&M $72,000
• Total Present Worth (30 yrs® 7%) $5,825,000
3. C3: Reconfiguration/Supplementation of the Existing Landfill Cap
This alternative includes using the soil materials from the existing cap as a "final protective
layer" and using either existing on-site clay, supplemented as needed with off-site clay, or
using entirely new off-site clay as a "low permeability layer." A cap that uniformly consists of
a three-foot compacted clay layer, a three-foot uncompacted rooting zone/cover soil layer, and
a vegetative cover would be constructed. The resulting cap would comply with the final cover
specifications of 35 I AC 811, which require a low permeability layer with a minimum
allowable thickness of three feet, overlain by a final protective layer not less than three feet
thick, sufficient to protect the low permeability layer from freezing and to minimize root
penetration.
Construction activities would include removing vegetation; stockpiling the cover soils for re-
use as needed; consolidating the off-property waste at the northern edge of the "old landfill"
onto Site property; re-grading the Site using existing soils to a uniform graded surface;
excavating and hauling supplemental off-site clay to the Site; placing and compacting three feet
of clay as the barrier layer; placing the rooting zone soils and topsoil layer; and re-establishing
vegetation. A borrow-source investigation would be conducted to confirm the quality of off-
site clay before it is excavated and used in the cap. The cap could be supplemented with clay
from the previously used clay source (north of the "new landfill" area) if the clay is available
in sufficient quantity and is of acceptable quality (to be determined by borrow-source testing).
H.O.D. ROD; September, 1998 25
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Existing landfill access roads are adequate; therefore, construction of additional access roads is
not included under this capping alternative. Construction activities could be performed so as
not to encroach on or impact the adjacent wetlands or floodplain.
Regrading of the Site using existing cover soils would be performed to eliminate the erosional
rills, gullies, and settlement depressions that effect approximately 20 percent of the Site area.
This would create a continuously sloped surface sufficient to maintain positive drainage over
and off the Site and would also reduce infiltration and the formation of leachate.
Recompaction of the cover would reduce the infiltrating volume of surface water by
establishing a less permeable barrier layer. The Site would be graded to a minimum two
percent slope and to a maximum 4H:1V slope on side slopes, except at the property boundary
where Sequoit Creek abuts the Site. The 4H: IV design criterion is intended as a generalized
guidance for the cap and may have to be evaluated at the very edge of the property boundary in
these areas. Although significant grading may be necessary to place the additional thickness of
cover soils in the steep areas, these slopes appear to be in relatively good shape, and a detailed
analysis would be conducted to determine the proper slope grades and configurations, since
these areas would be regraded to install the cap upgrade.
Appropriate erosion control measures to protect nearby Sequoit Creek and the adjacent
wetlands would be implemented prior to reworking the cap. These measures may include the
construction of berms/silt fences, the placement of rip-rap, and straw bale dikes, or the use of
temporary cover material.
After the reworking of the landfill cap, maintenance would continue to be performed and
would include mowing at a minimum of twice per year and quarterly Site inspections.
Quarterly inspections would consist of walking the Site and visually noting evidence of
erosion, settlement, clogged swales, and/or other damage. Repair would be performed as
needed. Maintenance of the ditches would include removal of silt and/or debris that may
impair surface water flow. Additional differential settlement could occur after the
reconstruction of the landfill cover as a result of the additional weight provided by the new
cover soils; however, additional settlement would be addressed as part of the routine Site
maintenance.
Approximately 2.2 inches/year of infiltration would be expected following the implementation
of this capping alternative. Infiltration is greater through the C3 cover than that of the C2
cover because the thicker soil layer is able to retain more moisture, thus allowing a greater
volume of pore water to infiltrate through the clay to the waste mass. See the Table 16 HELP
model results for infiltration values.
Construction would be expected to take approximately 27 weeks and may need to extend over
the course of two construction seasons, with the following estimated cost:
H.O.D. ROD; September, 1998 26
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• Capital Cost Up to $9,034,500
• Annual O&M $72,000
• Total Present Worth (30 yrs @ 7%) Up to $9,934,500
C. Landfill Gas Collection and Treatment Alternatives
1. Gl: NFA
This alternative involves the continued use of the existing passive gas vent system at the Site.
Repairs to the existing gas flares may be required in order to maintain the gas collection
efficiency of the system. (See Figure 5 for the existing gas flare locations.) The following
estimated costs are associated with using the existing gas collection system:
• Capital Cost $231,000
.. Annual O&M $35,000
• Total Present Worth (30 yrs® 7%) $665,400
2. G2: Supplementation of the Existing Landfill Gas System
The existing passive flare system in the new landfill area, consisting of flares GWF1-GWF14
(see Figure 5), would be repaired as necessary, and continue to be operated. LFG collection
and treatment would also be supplemented through the addition of an active system in the old
landfill section, consisting of approximately five new vertical extraction wells, and use of the
nine existing extraction points (LP1-LP4, and LP10-LP14; see Figure 5). The extraction
points would be interconnected by header piping to a blower/flare station. A pilot/pre-design
study would be undertaken to determine the necessary repairs to the existing passive flares in
the "new landfill," viability of using the nine existing wells in the "old landfill," and optimal
locations for placement of new wells in the "old landfill."
The installation of the new system in the "old landfill" area would require trenching in areas of
the Site where header pipe placement is needed, the placement of header piping and installation
of the new wells, backfilling, the reworking of the cap, and construction of the blower and
flare station. Trenching work would be coordinated with the "new landfill" cap
reconstruction, if performed.
The existing gas collection system consists only of passive vent points. These existing gas vent
points will be raised or lowered, as necessary, concurrently with the cap repair or upgrade.
Care will be taken when grading around these vent points, and grading will likely be done by
hand in the immediate vicinity of the wells or vents, so that damage will be avoided or
minimized.
After installation of the new system, operation, inspection, and maintenance would be required
H.O.D. ROD; September, 1998 27
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as described for alternative G3. The existing system in the "new landfill" area would also
require inspection and maintenance. Construction activities would be staged so that they
would not encroach on or impact the adjacent wetlands or floodplain.
Air monitoring will be performed in order to comply with the action-specific ARARs for landfill
gas management, gas collection, and landfill gas processing and disposal identified in Table 13.
Frequencies of monitoring, monitoring points, contaminants and indicators monitored, and the
duration of monitoring will be covered during the RD.
Construction of this gas collection/treatment alternative can be completed in one construction
season, and can occur concurrently with the cap restoration. The following estimated costs are
associated with this gas collection/treatment alternative:
• Capital Cost $701,100
• Annual O&M $35,000
• Total Present Worth (30 >.-s @ 7%) $1,135,500
3. G3: Active Site Upgrade of the Landfill Gas System
Existing stick flares (GWF1-GWF14) in the "new landfill" area would be converted to extraction
wells, as necessary. See Figure 5 for flare locations. Existing vertical extraction wells in "old
landfill" would be used, and additional wells in the "old landfill" would be installed, as needed.
See Figure 5 for existing leachate extraction well locations. A header system would be installed
that would interconnect all of the wells, including LP1-LP14, located throughout the landfill, to
convey LFG to one centralized blower/flare station, forming an entirely active extraction and
treatment system. As in the case of alternative G2, a series of pilot/pre-design studies would be
conducted to determine the viability of using existing extraction points and to identify new
extraction points, if any, which may be needed. The results of these pilot/pre-design studies may
indicate that the fully active system proposed under G3 is not necessary, and that G2 is sufficient
to address the LFG at the Site.
The implementation of this alternative would require trenching in areas of the Site for pipe
placement, placement of pipe and new wells, placement of backfill around these new features,
localized cap reconstruction, and construction of the blower and flare station. If cap
reconstruction occurs, placement of piping would be coordinated with such work. Construction
activities would be performed so they do not encroach on or impact the adjacent wetlands or
floodplain.
This LFG system upgrade would allow LFG to be actively extracted from the waste mass,
increasing the radius of influence (ROI) of each well to between 100 and 150 feet per well, which
is typical for active municipal LFG extraction wells. The existing gas flare locations (GWF1-
GWF14) are spaced approximately 200 feet apart, allowing for effective use of a 100 to 150 foot
ROI after conversion to extraction wells. Approximately five new wells would be constructed in
H.O.D. ROD; September, 1998 28
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the "old landfill" area and one new well would be proposed for installation in the "new landfill"
area to provide complete coverage. These new wells would have an approximate 35-foot depth
and would be spaced approximately 200 feet apart. Approximately 12,000 feet of piping would
connect all of the LFG extraction wells, and a blower and flare station would be constructed.
This active gas system, after installation, would require continual operation and regular
maintenance. Inspections would be performed monthly to assure proper operation of warning
lights, telemetry systems, and building vents. Measurements of valve settings, pressures and
blower settings would be recorded. Routine maintenance and LFG monitoring would be
performed as well.
This active LFG extraction/collection system could be constructed as part of a dual extraction
system for leachate and gas. An additional feature of this option would be leachate extraction;
therefore, the leachate collection portion of the dual extraction system is presented as leachate
collection alternative LC4. See Figure 6 for a layout of this dual extraction system.
Air monitoring will be performed in order to comply with the action-specific ARARs for landfill
gas management, gas collection, and landfill gas processing and disposal identified in Table 13.
Frequencies of monitoring, monitoring points, contaminants and indicators monitored, and the
duration of monitoring will be covered during the RD.
Construction of this gas collection/treatment alternative can be completed in one construction
season, and can occur concurrently with the cap restoration. The following estimated costs are
associated with this gas collection/treatment alternative:
• Capital Cost $924,000
• Annual O&M $35,000
• Total Present Worth (30 yrs @ 7%) $1,358,400
D. Leachate Collection
1. LCI: NFA
This alternative would use the existing toe-of-slope collection pipes and leachate extraction
manholes. See Figure 5 for existing piping and manhole locations. Collection of leachate would
continue as is. The current leachate removal rate is about 1,000 gallons per day, according to
WMII. The documented volume of leachate removed for 1997 was 63,000 gallons.
The following estimated costs are associated with this leachate collection alternative:
• Capital Cost $0
• Annual O&M $4,000
• Total Present Worth (30 yrs @ 7%) $49,700
H.O.D ROD; September. 1998 2 9
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2. LC2: Toc-of-Slope Leachate Collection
This combination passive/active leachate collection alternative involves extending the existing
leachate collection piping along the perimeter of the waste mass on both sides of the separation
barrier between the "old and "new" landfill areas, and using the leachate extraction wells (PI,
P2A, P3A, and P8-P10; see Figure 5) in the "new landfill" area. In the "new landfill" area, piping
would be constructed along the north and south perimeters and would tie into the pipe which runs
along the west side of the "new landfill" area into the east manhole (MHE). In the "old landfill"
area, piping would be constructed along the north, south, and west perimeters that would tie into
the pipe which runs along the east side into the west manhole (MHW). Approximately 4,200 feet
of total piping would be placed. See Figure 5 for existing piping and manhole locations.
Construction of this alternative includes removal of the cap in areas of pipe placement,
placement of backfill, relocation of excavated waste, and replacement of the cap. If cap
reconstruction occurs, pipe nlacement would be coordinated with such work. Construction
activities would be staged so that they do not encroach on or impact the adjacent wetlands and
floodplain.
This alternative would increase leachate collection efficiency, reduce leachate levels near the i
of slope to eliminate seeps, and induce an inward gradient at the perimeter of the landfill,
potentially capturing impacted shallow groundwater in the surficial sand aquifer in the vicinity of.
the Site. Extraction of leachate would continue via the leachate extraction wells in the "new
landfill," and from MHE and MHW. In addition, the extraction points installed in 1993 (LP1-
LP14) could be used. These 14 wells were constructed for leachate/gas extraction, if needed.
See Figure 5 for existing leachate extracting devices.
After construction of the new piping, routine O&M activities would be performed. Inspections
would be performed to assure proper operation of pumps and switches, and alarms and
equipment maintenance would be done, as needed. Monitoring of leachate volumes and
composition would also be performed.
Construction of this leachate collection alternative can be completed in one construction season,
and can occur concurrently with the cap restoration. The following estimated costs are associated
with this leachate collection alternative:
• Capital Cost $232,300
• Annual O&M $60,000
• Total Present Worth (30 yrs @ 7%) $976,900
3. LC3: Upgrade/Supplementation of Leachate Collection System
The toe-of-slope collection piping would be extended along the north and south perimeter of the
"new landfill" only; existing extraction points in the "new landfill" would also continue to be
used. A dual extraction system consisting of five new wells interconnected with existing wells
H.O.D. ROD; September, 1 998 30
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LP1-LP4 and LP10-LP14, and a header connected to a blower/flare station would be constructed
in the old section of the landfill. A pilot/pre-design study would be conducted to determine the
viability of using existing extraction points and to identify new extraction points, if any, which
may be needed. This alternative would be considered in conjunction with the LFG alternative
G2, because the required construction for each of these alternatives is similar (i.e., use existing
systems with minor upgrades in the "new landfill" and install new wells in the "old landfill").
See Figure 5 for existing leachate extraction devices.
The work includes removal of the cap in areas of pipe placement, installation of additional
leachate/gas extraction wells and header piping, backfilling, relocating of excavated waste, and
re-installation of the cap. If cap reconstruction is performed, pipe placement and well installation
would be coordinated with such work. Construction activities would be performed so that they
would not encroach on or impact the adjacent wetlands or floodplain.
The "new landfill" area has six existing leachate extraction wells from which leachate can be
pumped and discharged into a leachate holding tank. The collection pipe along the perimeter
would act as a control measure to eliminate side slope seeps. This alternative would also induce
an inward gradient at the perimeter of the Site to control and collect shallow groundwater in the
surficial sand aquifer in the vicinity of the Site.
After the systems are constructed, inspection and O&M activities would be performed. For the
"old landfill" area, inspections would be performed monthly for the gas and leachate systems to
assure proper operation of warning lights, telemetry aystems, building vents, pumps, and
controls. The monitoring of valve settings, pressures, blower settings, and leachate volumes and
composition would also be done. For the "new landfill" area, inspections would be performed
monthly for the piping and pumps along with monthly monitoring of leachate volumes and
leachate composition.
Construction of this leachate collection alternative can be completed in one construction season,
and can occur concurrently with the cap restoration. The following estimated costs are associated
with this leachate collection alternative:
• Capital Cost $367,800
• Annual O&M $72,000
. Total Present Worth (30 yrs @ 7%) $ 1,261,300
4. LC4: Active Leachate Extraction
The toe-of-slope collection piping would be extended along the north and south perimeter of the
"new landfill" only; existing extraction points in the "new landfill" would also continue to be
used. A dual extraction system consisting of five new wells interconnected with existing wells
GWF1-GWF14 and LP1-LP14, and a header connected to a blower/flare station would be
constructed in the old section of the landfill. A pilot/pre-design study would be conducted to
determine the viability of using existing extraction points and to identify new extraction points, if
H.O.D. ROD; September, 1998 31
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any, which may be needed. This alternative would be considered in conjunction with the LFG
alternative G3, because the required construction for each of these alternatives is similar (i.e., use
existing systems with minor upgrades in the "new landfill" and install new wells in the "old
landfill"). See Figure 6 for a layout of this dual extraction system.
The work includes removal of the cap in areas of pipe placement, installation of additional
leachate/gas extraction wells and header piping, backfilling, relocating of excavated waste, and
reconstruction of the cap. Pipe placement and -ell installation would be coordinated with cap
reconstruction, if performed. Construction activities would be performed so that they would not
encroach on or impact the adjacent wetlands or floodplain.
The "new landfill" area has six existing leachate extraction wells from which leachate can be
pumped and discharged into a leachate holding tank. The collection pipe along the perimeter
would act as a control measure to eliminate side slope seeps. This alternative would also induce
an inward gradient at the perimeter of the Site to control and collect shallow ground water in the
surficial sand aquifer in the vicinity of the Site.
After the systems are constructed, inspection and O&M activities wuuld be performed. For the
"old landfill" area, inspections would be performed monthly for the gas and leachate systems to
assure proper operation of warning lights, telemetry systems, building vents, pumps, and
controls. The monitoring of valve settings, pressures, blower settings, and leachate volumes and
composition would also be done. For the "new landfill" area, inspections would be performed
monthly for the piping and pumps along with monthly monitoring of leachate volumes and
leachate composition.
Construction of this leachate collection alternative can be completed in one construction season,
and can occur concurrently with the cap restoration. The following estimated costs are associated
with this leachate collection alternative:
. Capital Cost $439,000
• Annual O&M $60,000
• Total Present Worth (30 yrs @ 7%) $1,183,600
E. Leachate Treatment and Disposal
1. LT1: NFA, Continue To Discharge To A Licensed, Publicly Owned Treatment Works
(POTW)
Under this alternative, leachate would continue to be discharged to the Fox River Water
Reclamation District (FRWRD), which is a permitted POTW. The leachate would be pumped
directly from the collection system and transported via tanker trucks to the POTW for treatment
under an industrial discharge permit for the Site.
The following estimated costs are associated with this leachate collection alternative:
H.O.D. ROD; September. 1998 32
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• Capital Cost $0
• Annual O&M $66,800
• Total Present Worth (30 yrs @ 7%) $829,000
2. LT2: Pretreatment and Discharge to a POTW
Under this alternative, leachate would be pretreated prior to discharge to the local POTW.
Pretreatment may include chemical precipitation for metals removal and aeration to lower
biochemical oxygen demand (BOD) concentrations. The leachate may or may not continue to be
discharged to the currently-used POTW (FRWRD).
An on-site pretreatment facility would require the construction of a treatment building;
installation of tanks, piping, gauges, valves, fittings, pumps, electrical controls, and meters; and
connection of utility service to the building. Construction activities would not encroach on or
impact the adjacent wetlands or floodplain.
This alternative would eliminate the hazards associated with overland transport of contaminated
leachate to an off-site POTW, and would accommodate the increased volume of leachate
associated with increasing leachate collection efficiency at the Site. The leachate collection
alternatives presented previously are intended to bring about the reduction of leachate levels
throughout the landfill.
Currently, approximately 1,000 gallons per day of leacliate is pumped and transported to the
POTW, according to WMII. The quantity of leachaie removed would initially increase if an
enhanced leachate collection system is installed at the Site. For this alternative, an initial
increase in the extraction rate has been assumed. A permit from the local POTW would be
required. The permit would specify the leachate constituent concentrations and acceptable
leachate quantities that could be effectively handled by the POTW. The pretreatment facility
would be designed and constructed to attain the pretreatment level required by the POTW.
Monitoring would be performed at the frequency specified by the POTW to ensure compliance
with the POTWs requirements.
After construction of this system, inspections would be performed on a monthly basis to ensure
proper operation of pumps, switches, controls, warning lights, telemetry systems, and building
vents. Maintenance, adjustments, and repairs to the system would be made as necessary.
Construction of this leachate treatment alternative can be completed in one construction season,
and can occur concurrently with the cap restoration. The following estimated costs are associated
with this leachate treatment alternative:
H.O.D. ROD; September, 1998 33
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• Capital Cost $476,000
• Annual O&M V752.100
• Total Present Worth (30 yrs @ 7%) $9,809,600
3. LT3: Treatment of Leachate and Surface Discharge
This alternative involves treatment of leachate to meet surface water discharge standards. A
combination of multiple treatment technologies would likely be required to provide the necessary
level of treatment to reduce all of the leachate constituents to required levels.
An on-site treatment facility would require the construction of a treatment building; installation
of tanks, piping, gauges, valves, fittings, pumps, electrical controls, and meters; and connection
of utility service to the building. Construction activities would not encroach on or impact the
adjacent wetlands or floodplain. O&M of the facility would require the services of a certified
treatment plant operator for a minimum of 20 hours per week to operate and maintain the plant,
and to perform the required monitoring.
A National Pollutant Discharge Elimination System (NPDES) permit would be required for this
alternative. Leachate would be extracted at a rate sufficient to control the off-site migration.
After treatment, leachate would be discharged to a surface water location of adequate
assimilative capacity. Since adjacent Sequoit Creek is not suitable for discharge due to its low
assimilative capacity, another, more remote surface discharge location would have to be
identified for this alternative to be considered feasible. To demonstrate compliance with the
NPDES permit requirements, monitoring at a frequency to be specified in the permit would be
performed.
The treatment system would require continuous operation and ongoing routine maintenance.
After construction of the system, inspections would, at a minimum, be performed on a monthly
basis to assure proper operation of pumps, switches, controls, warning lights, telemetry systems,
and building vents. Maintenance, adjustments, and repairs to the system would be made as
necessary.
Construction of this leachate treatment alternative would require a significant effort, due to the
pipeline construction to an adequate outfall location. Therefore, this alternative would likely
extend over two construction seasons. The following estimated costs are associated with this
leachate treatment alternative:
• Capital Cost $1,843,000
• Annual O&M $605,200
• Total Present Worth (30 yrs @ 7%) $9,353,600
H.O.D. ROD; September, 1998 34
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F. Groundwater Monitoring
1. G\V1: NFA, Continue Current Groundwater Monitoring
The existing groundwater monitoring program would be continued under the NFA alternative.
As stated in the current EEPA Site permit, additional monitoring points would be established
during the CERCLA RD process, and a formal monitoring program would be presented to
USEPA and IEPA at that time. The groundwater monitoring frequency will be quarterly, in
accordance with 35 IAC 811.319(a).
The following estimated costs are associated with the NFA groundwater monitoring alternative:
• Capital Cost $692,200
• Annual Cost $63,000
• Total Present Worh (30 yrs @ 7%) $1,474,000
To mitigate the potential adverse environmental impact posed by groundwater contamination
identified in the RI, the nearest public well, VW4, was replaced with a new well (VW7) which is
located more than one mile from the Site. The estimated capital cost for alternatives GW1 and
GW2 include the already-incurred cost of $652,800 to remove VW4 from service and install
VW7, and an estimated cost of $39,400 to abandon VW4.
2. GW2: Monitored Natural Attenuation
Under this alternative, in addition to the continuation of the groundwater monitoring program, a
groundwater monitoring plan would be implemented to assess the effectiveness of natural
attenuation to reduce the contaminant impacts to groundwater. The groundwater monitoring
program would include monitoring the quality of groundwater from both the surficial sand and
the deep sand and gravel aquifers. To further study the extent, if any, of a groundwater
contaminant plume, a pre-design investigation will also be conducted. The pre-design
investigation will consist of installing and monitoring approximately two wells downgradient of
well US3D, and analyzing the groundwater samples.
A groundwater management zone (GMZ) in accordance with 35 IAC 620.250 cannot be
established because a contaminant plume requiring corrective action has not been identified. In
the event that a contaminant plume is discovered in the future, the need for establishing a GMZ
would be reevaluated. Wells to be monitored would be selected based on the RI analytical
results and well locations relative to known groundwater flow directions (generally west along
Sequoit Creek and in the surficial sand aquifer, and southwest in the deep sand aquifer). Wells
located along the south and southwest perimeter of the Site would be likely candidates for
inclusion in the groundwater monitoring plan.
The upgradient monitoring wells (G14S, G14D, Gl IS, and Gl ID) and the selected downgradient
monitoring wells include wells which are screened in the surficial sand aquifer and wells which
H.O.D. ROD, September, 1998 35
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are screened in the deep sand aquifer at the Site. Monitoring wells US3D, US4D, and W3D form
a linear downgradient monitoring network which is screened in the deep aquifer. Periodic
sampling from this network of wells would be performed to gauge the effectiveness of remedial
measures and document groundwater conditions in the vicinity of the Site. As groundwater
contaminant conditions continue to be evaluated during the 30-year O&M period, monitoring
wells and/or private wells may be added to the groundwater monitoring well network. See
Figure 7 for a layout of the likely monitoring points for this groundwater monitoring alternative.
The selected monitoring wells would be sampled on a quarterly basis for 30 years, in accordance
with 35 IAC 811.319(a)(l)(A), and groundwater samples would be analyzed for the current list
of analytes, including boron, chloride, iron, ammonia nitrogen, total dissolved solids, and zinc; as
well as for the Illinois Pollution Control Board Groundwater Quality Standards list of
contaminants shown in Table 22. The list of contaminants to be monitored must satisfy the
requirements of 35 IAC 811.319(a); however, the owner or operator may request USEPA to
reduce the list of contaminants to be monitored, according to 35 IAC 811.319(b)(5)(E).
According to 35 IAC 811.319(a)(3)(C), VOCs are to be monitored yearly. However, for the first
five years of monitoring, VOC groundwater monitoring frequencies will be quarterly, due to the
VOC contamination present in the groundwater. After the first USEPA Five Year Review,
USEPA may approve a reduced monitoring frequency based on a review of the VOC
groundwater monitoring data.
In addition, natural attenuation parameters would be monitored in select groundwater monitoring
wells, specifically near the southwest corner of the Site. These parameters would include: total
organic carbon, BOD, nitrate nitrogen, nitrite nitrogen, total kjeldahl nitrogen, orthophosphate,
sulfate, conductivity, alkalinity, dissolved oxygen, pH, temperature, and redox potential.
Additional natural attenuation parameters will be considered, and may be proposed in the
monitoring plan to be developed during the RD phase. The monitoring program would be
capable of recording changes in groundwater contaminant concentrations over time.
in one
Installation of approximately two wells for the pre-design investigation can be completed i
construction season, and can occur concurrently with the cap restoration. The following
estimated costs are associated with monitored natural attenuation:
• Capital Cost $723,600
• Annual Cost $69,700
• Total Present Worth (30 yrs @ 7%) $ 1,588,600
VIE. Summary of Comparative Analysis of Alternatives
The remedial alternatives developed in the FS w^re evaluated on the basis of the nine evaluation
criteria listed below. The advantages and disadvantages of each alternative were then compared
to determine which alternative provides the best balance among the nine criteria. The nine
H.O.D. ROD; September. 1998 3 6
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evaluation criteria are set forth in the NCP, 40 CFR Part 300.430(e)(9)(iii). Each of the nine
criteria is either a threshold criterion, primary balancing criterion, or modifying criterion.
A. Threshold Criteria:
1. Overall Protection of Human Health and the Environment
Overall protection of human health and t' *. environment refers to whether an alternative
provides adequate protection of human health and the environment and describes how risks
posed through each exposure pathway are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARAR)
Applicable requirements are those cleanup standards, standards of control, or other
substantive environmental protection requirements, criteria, or limitations promulgated
under federal environmental or state environmental or facility siting law that specifically
address a hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site. Only those state standards that are identified by a state in
a timely manner and that are more stringent than federal requirements may be applicable.
Relevant and appropriate requirements are those cleanup standards, standards of control,
and other substantive environmental protection requirements, criteria, or limitations
promulgated under federal or state environmental siting law that, while not "applicable" to
a hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site, address problems or situations sufficiently similar to those
encountered at a CERCLA site that their use is well-suited to the Site. Only those state
standards that are identified by a state in a timely manner and that are more stringent than
federal requirements may be relevant and appropriate.
Compliance with ARARs refers to whether an alternative will attain ARARs under federal
environmental laws and state environmental and facility siting laws, or provide a basis for a
waiver. Federal and state ARARs are divided into three categories: chemical-specific,
action-specific, and location-specific.
B. Primary Balancing Criteria:
3. Long-term Effectiveness and Permanence
Long-term effectiveness and permanence refers to expected residual risk and the ability of
an alternative to maintain reliable protection of human health and the environment over
time, once cleanup levels have been met. This criterion includes consideration of adequacy
and reliability of controls.
H.O.D. ROD, September, 1998 37
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4. Reduction of Toxicity, Mobility, or Volume Through Treatment
Reduction of toxicity, mobility, or volume through treatment refers to the anticipated
performance of the treatment technologies for the remedy.
5. Short-Term Effectiveness
Short-term effectiveness refers to the potential adverse effects that implementation of an
alternative may have on human health and the environment, during construction and before
cleanup levels are achieved. The length of time needed to complete the remedy is also
evaluated.
6. Implementability
Implementability refer- to the technical and administrative feasibility of an alternative,
including the availability of services and materials.
7. Cost
Cost includes estimated capital and long-term O&M costs for an alternative, and also is
expressed as net present worth cost.
C. Modifying Criteria:
8. State Acceptance
State acceptance indicates whether the State of Illinois supports the selected remedy, and
includes key concerns the State of Illinois may have about the selected remedy and other
alternatives.
9. Community Acceptance
Community acceptance refers to the community's acceptance of the preferred alternative
presented in the Proposed Plan based on comments received during the public comment
period. The Responsiveness Summary, which is Appendix A of this ROD, contains
significant comments received during the public comment period and the USEPA response
to those comments.
The following discussion summarizes the compliance of the alternatives with the nine criteria.
H.O.D. ROD; September, 1998 38
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1. Overall Protection of Human Health and the Environment:
Capping:
The BLRA demonstrated that the only carcinogenic risk to human health and the environment
greater than 1 X 10"4 associated with the Site is that posed by the ingestion of vinyl chloride-
contaminated water from the off-site deep sand ?nd gravel aquifer. Repairs to the cap would not
further reduce the specific risk posed by vinyl chloride since a repaired cap would not directly
mitigate the current possibility of ingestion of vinyl chloride from the off-Site deep aquifer. The
goal of a waste cap is to provide adequate protection to human health and the environment by
preventing dermal contact with landfill contents, reducing contaminant leaching to groundwater,
controlling surface water runoff and erosion, and reducing the potential for direct inhalation of
LFG by providing increased containment of LFG.
The capping portion of the NFA alternative includes no capital costs associated with improving
the cap, but does include minimal O&M activities to maintain the cap over the 30-year O&M
period. The planned activities would not folly protect human health and the environment from
dermal exposure to contaminated soil, and would allow excessive infiltration through the cap
into the waste mass, thereby only minimally controlling contaminant leaching to groundwater.
The capping improvements of the NFA alternative also would do little to control surface water
runoff and erosion, due to the lack of capital improvements and minimal maintenance activities. •
Since the capping improvements would result in only a modest containment system, they would
not significantly reduce the potential for direct inhalation of LFG.
• The cap improvements prescribed under alternatives C2 and C3 would not further reduce the
current risk of ingesting vinyl chloride-contaminated water from the deep sand and gravel aquifer
because improvements would not eliminate this ingestion pathway. Significantly augmenting the
existing cap structure could increase environmental threats posed by LFG. A much "tighter" cap
could increase the rate of partitioning of LFG constituents into leachate and groundwater, thus
elevating the potential level of risk associated with the Site. As a result, alternatives C2 and C3
would elevate risk levels above those associated with alternative Cl. Alternative C3 would be
the "worst case" alternative for this reason; also, alternative C3 could introduce further risks
because it would involve the manipulation of cover materials on a much larger scale than the
other two alternatives.
Benefits provided by alternatives C2 and C3 would include preventing direct contact with landfill
contents, reducing contaminant leaching to groundwater, and controlling surface water runoff;
however, all of these benefits could be achieved by making simple repairs to the cap as described
under alternative C1. Reworking the existing cover for both alternatives C2 and C3 would
involve regrading of the Site prior to recompaction of the barrier layer of the cap and placement
of the cover soils. Both alternatives would reduce rainfall infiltration through the cap slightly
less than alternative Cl (an estimated maximum infiltration of approximately 2.0 inches per year
and 2.2 inches per year for Alternatives C2 and C3, respectively, compared to 1.6 inches per year
for alternative Cl), as shown by the HELP model results in Table 16, and ultimately would
H.O.D. ROD; September. 1998 39
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reduce leachate head levels within the waste mass. The infiltration values for these cap
alternatives are higher than that of the Cl alternative because the added thickness of soil on top
of the compacted clay results in a higher volume of pore space water available to infiltrate
through the clay.
Since a portion of the Site was constructed with the base of the landfill below the water table,
reduction of infiltration alone will not prevent leachate generation. Therefore, a balance between
the capping alternative and the leachate collection alternative must be considered when selecting
the Site remedial components. According to the HELP model results, capping alternatives C2
and C3 do not reduce infiltration more than Cl, and because of the zone of saturation, leachate
generation and collection will be required regardless of what cap alternative is selected.
Therefore, the additional disturbance necessary to construct C2 and C3 cap alternatives and the
increased infiltration through these caps make these alternatives less protective of human health
and the environment than alternative Cl.
Gas Collection and Treatment:
The risks posed by LFG from the Site are attributable to the potential for direct inhalation of LFG
and partitioning of LFG constituents, including vinyl chloride, to groundwater. However, the
RME excess lifetime cancer risks attributable to inhalation of VOCs from the ambient air at the
Site falls below the USEPA 1 x 10"6 lower threshold and are therefore considered acceptable.
(The calculated risks for child or teenage trespassers, and for nearby, adult residents are 4 X 10"9
and 5 X 10"7, respectively, as summarized in Table 10.)
Alternative Gl proposes using the existing passive gas vent system for the entire landfill. This
system has been demonstrated over time to be marginally effective in venting and flaring LFG,
but is not totally effective due to flare blow-out and corrosion of the vent/flare stacks. If the
system is used as originally intended (venting and flaring the LFG on a consistent basis) and is
properly maintained, the existing passive system reduces risk to human health and the
environment by preventing inhalation of vapors and controlling migration of LFG.
Alternative G2 provides for active extraction of LFG in the "old landfill" area only. The "new
landfill" area would continue to use the existing system, following necessary repair of the
existing wells and stick flares. If the existing system in the "new landfill" area were used as
originally intended and maintained, coverage and efficiency in the "new landfill" area would be
provided, along with increased protection from LFG migration or inhalation of vapors.
Operation of the existing system in the "new landfill" and a new active system in the "old
landfill" area would reduce risk to human health and the environment. This alternative could
also be implemented with leachate collection alternative LC3, which involves installation of an
active leachate collection system in the "old landfill."
Alternative G3 proposes an active gas extraction system with a treatment flare for the entire
landfill. This alternative assumes each installed well has a radius of influence of between 100
and 150 feet, and therefore provides adequate Site coverage. LFG would be collected by the
H.O.D. ROD, September, 1998 40
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wells and piping, and would be discharged to a flare system for destruction. This alternative
meets the remedial action objectives and reduces risk to human health and the environment by
preventing inhalation of vapors and controlling migration of LFG. This alternative would
provide the added benefit of further reducing the concentrations of VOCs in the leachate by
removing them before they partition into the liquid phase. It could also be integrated with
leachate collection alternative LC4 through the installation of a dual extraction system.
Leachate Collection:
Alternative LCI would use the existing collection pipes and leachate extraction manholes.
Collection of leachate would continue as is, with approximately 1,000 gallons per day (gpd)
removed from the landfill. This alternative would not provide additional leachate collection, and
would not directly address leachate seeps from the landfill side slopes. However, based on the
results of the BLRA, the leachate seeps do not pose an unacceptable risk to human health or the
environment.
LC2 extends the existing toe-of-slope leachate collection piping in both the "old" and "new
landfill" areas. The extended toe-of-slope drains would be installed several feet below the soil
cover/waste interface, but would not be installed at the base of the waste. The object of this
system would be to maintain the "leachate maintenance level" in accordance with the existing
EEPA permit. These additional collection pipes, in conjunction with a repaired or upgraded cap,
would actively control leachate seeps on the side slopes of the facility.
Alternative LC3 proposes extension of the existing toe-of-slope collection piping and use of the
existing leachate extraction wells in the "new landfill" area. In addition, five new leachate
extraction wells (to be installed as part of this alternative) and the existing leachate piezometers,
if necessary, will be used for leachate extraction in the "old landfill." Leachate levels within the
"new landfill" area would not be expected to significantly decrease under this alternative,
although they would be maintained at or below the "leachate maintenance level" noted above.
This would achieve containment by inducing an inward gradient, which is consistent with the
original design of the Site.
Alternative LC4, active extraction of leachate, provides a system in both the "new landfill" and
"old landfill" to actively pump leachate from the entire waste mass. By actively extracting
leachate from within the waste mass and maintaining an inward gradient, shallow groundwater in
the immediate vicinity of the landfill perimeter would be captured. This active system would
increase leachate collection volumes and control leachate head levels within the Site. By
reducing head levels and maintaining the "leachate maintenance level" within the waste mass, the
potential for leachate migration would be reduced, and the potential impacts due to infiltration
through the cap would be minimized. Capture and control of shallow groundwater from the on-
site surficial sand aquifer would result in an increased margin of safety for protection of human
health and the environment.
H.O.D. ROD; September, 1998 41
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Leachate Treatment:
Alternative LT1 is currently operational at the Site. The leachate is pumped directly from the
collection manholes, stored in a tanker truck, and transported to a POTW for treatment under an
industrial discharge permit for the Site. This alternative is protective of human health and the
environment, provided the leachate is discharged to the POTW in accordance with the industrial
discharge permit.
Alternative LT2 proposes to pretreat leachate on-site prior to discharge to a POTW. The leachate
would be pretreated to remove and/or reduce the concentrations of various constituents as
required by the POTW (potentially BOD and metals, for example). The POTW would receive
the treated water and complete the removal and/or reduction of concentrations of the remaining
contaminants. This alternative would be protective of human health and the environment.
Alternative LT3 proposes construction of an on-site leachate treatment facility that would use
various treatment technologies required to treat leachate to meet surface water discharge
standards as required by a NPDES discharge permit. LT3 would protect human health and the
environment, provided the NPDES limits were not violated.
Groundwater Monitoring: .
Groundwater monitoring alternative GW1 is a long-term monitoring program that will provide
warning of a potential change in contaminant conditions that could impact public or private
wells. Groundwater monitoring alternative GW2 provides an additional measure of protection by
monitoring the effectiveness of the natural attenuation processes. In addition, a pre-design
investigation, consisting of one or two additional monitoring wells, would be implemented as
part of GW2. Both monitoring programs would be capable of recording changes in groundwater
contaminant concentrations over time and would provide an early warning system to effectively
reduce the risk of future exposure of residents to impacted groundwater. Both monitoring
programs would also be effective in demonstrating the effectiveness of source control measures
implemented at the H.O.D. Landfill.
2. Compliance with ARARs:
The requirements of 35 1AC 807 are applicable to the Site. The H.O.D. Landfill is classified as a
municipal solid waste landfill as defined in 35 I AC 810.103, because it received waste before
October 9, 1993. It received an operating permit under 35 IAC 807, and was closed in 1989
under 35 IAC 807. Under 35 IAC 814.101(b)(3), the Site is required to comply with the terms of
its existing permit under 35 IAC 807, along with any relevant additional requirements specified
in Appendix A of 35 I AC 814.
The requirements of 35 I AC 811 are relevant to the Site. These are the requirements currently
applicable to municipal solid waste landfills in Illinois. Certain requirements of 35 IAC 811 are
H.O.D. ROD; September, 1998 42
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also appropriate to address conditions at the Site, as components of an integrated remedy which
combine ARARs under 35 IAC 807 and 35 IAC 811. Those relevant and appropriate
requirements of 35 IAC 811 which are ARARs for the selected remedy are identified in the
following narratives for each component. The narratives also identify additional ARARs for the
components.
Capping:
ARARs that apply to capping alternatives involve protection of the floodplain, wetlands, and
surface waters, and compliance with 35 IAC 807 capping and 811.11 l(c) post-care requirements.
Capping alternatives Cl, C2, and C3 all comply with the applicable State 35 IAC 807
requirements by providing cover design and performance to include, at a minimum, a two-feet
thick low-permeability layer of compacted soil overlain by adequate cover soils to minimize
erosion and maintenance requirements. Alternatives Cl and C2 also comply with the relevant
and appropriate 35 I AC 81M1 l(c) post-closure requirements, since they include the 30-year
O&M described in the 811.11 l(c) AAAR. Alternative C3, by definition, complies with the
811.11 l(c) post-closure requirements. All of the alternatives would involve erosion control and
staged construction activities such that the adjacent wetlands and floodplain would be protected.
Gas Collection and Treatment:
The State of Illinois, under 35 IAC 811.311, establishes minimum requirements for gas venting
and collection systems to ensure the protection of human health. The State has promulgated
specific air emission standards for LFG venting and gas collection systems. State of Illinois
regulations (35 IAC Part 218) require that VOC emissions from the Site must not exceed 25
tons/year, because the Site is located in an ozone non-attainment area. Other pertinent State of
Illinois air emission standards regulate particulate matter, sulfur, organics, carbon monoxide,
nitrogen oxides, and hydrogen sulfide (35 I AC Parts 212-217). There are also general
provisions for the control of gas emissions.
Alternative Gl would comply with the above-mentioned ARARs only if the existing system was
repaired so that it could be operated as originally intended, and maintained so that it could be
operated continuously. This alternative, because it relies on dated technology (passive stick-type
flares), may not be as efficient at managing LFG emissions.
Alternative G2, which combines the dated, passive stick flare technology in the "new landfill"
area, and an active system in the "old landfill" area, would potentially meet the ARARs if the
"new landfill" system was repaired and maintained so that it could be continuously operated.
However, the dated technology used in the "new landfill" may not be as efficient for controlling
LFG emissions.
Alternative G3 satisfies the accepted presumptive remedy objectives for landfill gas
management, which are gas collection and treatment. This alternative would satisfy 35 IAC 212
through 218 and 811.311 ARARs through active gas control and treatment, and would include
H.O.D. ROD; September, 1998 43
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monitoring to ensure continued compliance.
Leachate Collection:
The State of Illinois requirements for landfill leachate collection systems, 35 IAC 811.308,
include specifications and design criteria to prevent threats to human health and the environment
from leachate releases. Although the BLRA indicates that risks posed by leachate seeps at the
Site are not unacceptable, these leachate seeps violate 35 IAC 807 or 35 IAC 811 requirements.
Therefore, LCI, which includes the current practice of scheduled manual extraction of leachate
from the existing collection pipes and extraction manholes, would not directly address the
identified leachate seeps and thus may not comply with ARARs.
LC2, which would add the toe-of-slope leachate drains, would actively control the leachate
seeps; however, the potential for leachate breakouts or migration to the ground water due to the
volume of leachate remaining in the landfill would still be present. LC2, therefore, would be
questionable with regard to ARAR compliance.
LC3, which would use both automated and manual methods to control leachate, partially
complies with the ARARs because the potential for leachate seeps in the "new landfill" is
eliminated, but the potential for migration to groundwater in the "new landfill" would still exist.
LC4, active collection of leachate from the entire landfilled waste mass, would comply with
ARARs by eliminating the potential for leachate seeps, and by significantly reducing the
likelihood of leachate migration to the groundwater.
Leachate Treatment:
The 811.309 ARARs listed in Table 13 are associated with all leachate treatment alternatives
involving prevention of leachate release to groundwater or surface water. All three alternatives,
if properly implemented, would comply with the general requirement to prevent discharge of
leachate to groundwater or surface waters such that threats to human health and the environment
are eliminated. In addition, alternatives LT1 and LT2 would comply with the applicable sewer
discharge criteria and POTW pretreatment standards, if properly implemented.
LT3 would be required to comply with the Clean Water Act, use best available technology to
control pollutants, and properly operate the discharge system, including monitoring,
maintenance, analyses, and establishment of effluent standards. Alternative LT3 includes the
complete treatment and discharge of leachate to surface waters. Such treatment, if properly
implemented, would comply with State and Federal ARARs.
Groundwater Monitoring:
35 IAC 811.319(a) and 811.318 apply to the groundwater monitoring alternatives. Both
alternatives GW1 and GW2 meet the minimum groundwater monitoring requirements and thus
H.O.D. ROD; September, 1998 44
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comply with applicable ARARs. Should the owner or operator demonstrate that reduced
monitoring is sufficient to protect human health and the environment, USEPA may be petitioned
for a reduction in monitoring according to 35 IAC 811.319(a). However, USEPA may reinstate
increased monitoring if a statistically significant increase is determined according to 35 IAC
811.319(a).
35 IAC 620.250, which requires establishment of a GMZ, does not apply because a coherent
contaminant plume requiring corrective action Ins not been identified. However, compliance
with Illinois Groundwater Quality Standards at 35 IAC 620.410 will be monitored, and the
effectiveness of source control actions in achieving the groundwater quality standards will be
documented.
3. Long-term Effectiveness and Permanence:
Capping:
Alternatives Cl, C2, and C3 address long-term protection by controlling stormwater infiltration
into the landfill, thus decreasing the potential for contaminant transport into the leachate and
groundwater. These alternatives, which combine both access restrictions and improved covers,
would prevent direct contact with landfill contents. They would also minimize future erosion
and control surface water runoff by implementation of the maintenance plan described for each
alternative. The soil cover of each of the alternatives can last indefinitely if correctly maintained.
Gas Collection and Treatment:
Alternative Gl, if maintained and operated continuously, could potentially provide long-term
effectiveness. Over the years, LFG generation would decline and the LFG extraction system, if
maintained, would continue to perform. The "old landfill" portion of the Site is approximately
30 years old and gas generation is likely declining. The "new landfill" portion of the Site is
approximately 13 years old. LFG generation in this area of the Site is also declining, although it
remains greater in this area than in the "old landfill." If the existing system were repaired and
operated continuously, LFG in both areas could potentially be effectively controlled by this
alternative. However, the existing system, as it is currently operating, does not provide long term
effectiveness and permanence.
Alternative G2, because of the use of the passive stick flare technology in the "new landfill" area,
would potentially provide reduced long-term effectiveness, because there is evidence that the
existing passive system used for LFG control in the "new landfill" area is not controlling landfill
gas completely, and the "new landfill" area would be producing a greater quantity of LFG for a
longer period of time than the "old landfill" area. However, if the existing system were repaired
and operated continuously, this alternative would potentially control LFG emissions from the
Site.
Alternative G3 provides increased long-term effectiveness. This alternative provides active
H.O.D. ROD; September, 1998 45
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extraction of LFG, thereby reducing the VOC concentrations within the waste mass. This active
system uses Reasonably Available Control Technology (RACT) for control of LFG, and would
be effective at eliminating LFG emissions from the Site.
Leachate Collection:
Alternative LCI would not collect more leachate than is now being collected. Therefore, the
increased effectiveness of this alternative for controlling leachate seeps and migration to
groundwater would be minimal.
Alternative LC2 would result in an increase in leachate collection quantities in the short term and
in the long term, if properly maintained. The leachate mound within the waste mass would likely
remain, although the potential for seeps would be minimized. This alternative would be
somewhat effective in the long-term for minimizing leachate migration to groundwater.
Alternative LC3 also represents an increase in long-term effectiveness, because leachate levels
would be controlled within the waste mass in the "new landfill" area. Furthermore, the leachate
levels are expected to remain in conformance with the requirements of the IEPA permit for the
Site. However, the minimization of leachate migration to groundwater is not generally addressed
by this alternative.
Alternative LC4 would increase leachate collection quantities in the short term, and if
maintained, should continue to operate effectively for many years. This increased leachate
extraction would reduce leachate levels in the landfill and control the formation of leachate
seeps. The reduction of leachate volume within the waste mass would serve to minimize the
potential for migration of leachate to groundwater.
Leachate Treatment:
If properly maintained, any of the leachate treatment alternatives would provide long-term,
effective leachate treatment.
Groundwater Monitoring:
Both monitoring programs will be effective in measuring the long-term effectiveness and
permanence of the required source control actions. Changes in groundwater quality will be
monitored over time and would provide early notice of any change in groundwater quality. The
GW2 alternative would provide better indicators of the effects of natural attenuation; therefore,
GW2 is considered to offer better long-term effectiveness than GW1.
H.O.D. ROD; September, 1998 46
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4. Reduction of Toxicity, Mobility, or Volume through Treatment:
Capping:
Capping alternatives do not involve treatment and therefore are not evaluated against this
criterion.
Gas Collection and Treatment:
All of the alternatives reduce the volume of LFG via combustion. Alternative Gl uses the
existing stick flares. These flares can be adversely affected during periods of low gas flow or
under high winds. Keeping these flares lit requires increased monitoring and O&M. G2 uses a
combination of passive and active control for LFG, incorporating both the benefits of an active
system and the increased maintenance issues associated with Gl. Alternative G3 would use an
active system to collect LFG from the entire waste mass and would feature combustion at a
single point flare, allowing for less labor-intensive O&M. Reduction in toxicity through
treatment would be addressed by Gl, G2, and G3, provided the flares would stay lit. However,
any of the alternatives could allow for periods of time when flares become extinguished and LFG
can escape uncontrolled. Alternative G3 is the most effective at reducing toxicity, mobility, and
volume of LFG because of its fully active feature.
Leachate Collection:
The leachate collection alternatives do not involve treatment; therefore, they are not evaluated
against this criterion.
Leachate Treatment:
Each of the leachate treatment alternatives reduces the toxicity of the leachate by reducing and/or
removing the contaminants of concern. Metals would possibly remain as a treatment by-product
(sludge or concentrate) to be disposed of appropriately. These metals would appear in the POTW
sludge or in the on-site treatment system sludge. Toxicity would be reduced for the majority of
the contaminants, and for metals, the mobility and volume of contaminants would be
significantly reduced.
Groundwater Monitoring:
The groundwater monitoring alternatives do not involve treatment; therefore, they are not
evaluated against this criterion.
H.O.D. ROD; September, 1998 47
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5. Short-Term Effectiveness:
Capping:
The potential short-term impacts on the community, environment, and construction workers
during Site construction activities were evaluated. These potential impacts include noise, dust,
erosion, dermal contact with waste, and increased truck traffic. Construction activities for each
alternative would be performed in accordance w Mi USEPA-approved health and safety plans.
Alternative Cl would have relatively low short-term construction impacts. These impacts may
include additional noise and dust generation due to soil relocation/placement during cap
regrading and waste consolidation. Since this alternative would primarily involve regrading and
recompacting areas of the upper layer of the existing cap, dermal contact with the waste mass
should not be a concern. Potential dermal contact with the waste mass would be minimized
through the use of personal monitoring and protective equipment (if necessary). Equipment
decontamination would be implemented, thus further reducing the potential concern for dermal
contact.
Noise levels increase during construction; however, noise can be minimized by maintaining noise
control devices on construction equipment. Wearing hearing protection can also reduce the
effects of heavy machinery noise on Site workers. Fugitive dust emissions would occur during
construction; however, measures can be taken to minimize the amount of dust generated by the
watering of construction areas and roads, and by the potential use of dust masks by Site workers.
Additionally, erosion control measures and protection of Sequoit Creek from construction-related
sedimentation would be conducted during construction and thereafter, as needed. Alternative Cl
would take approximately six weeks to construct, based on moving approximately 6,000 cubic
yards of material per day for five days per week.
Alternative C2 would also have relatively low short-term construction impacts. These impacts
would be similar to those of the Cl alternative, described above. This alternative would take
approximately 20 weeks to construct based on moving approximately 6,000 cubic yards of
material per day for five days per week. Since this alternative would take significantly longer
than Cl, it does not offer as much short-term effectiveness.
Alternative C3 would have some short-term construction impacts, including increased dust,
noise, and the potential for dermal contact with waste. As stated above for alternative Cl,
measures can be taken to minimize all of these construction impacts. This alternative may also
involve importing supplemental clay to complete the compacted clay cap. Therefore, an increase
in truck traffic, noise, and dust generation could be expected during the construction period,
which could affect nearby community roads. Construction is expected to take approximately 27
weeks and would likely extend over the course of two construction seasons. If a clay borrow site
is needed, it would also have short-term construction impacts requiring dust control, noise
control, erosion control, and surface water management. These impacts would be addressed
using the same measures outlined above to minimize impacts at the Site. Due to the greater
H.O.D. ROD; September, 1998 48
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implementation time and volume of material needed, this alternative offers the least amount of
short-term effectiveness.
Gas Collection and Treatment:
The potential short-term impacts from alternative Gl include minimal disturbance of the Site
during repairs to the existing system. Both G2 and G3 involve the installation of LFG header
piping and the potential installation of additional gas extraction wells and a blower/flare station.
This work would result in an increase of noise, dust, and the potential for dermal contact with
waste by construction workers. Measures can be taken to minimize dust and noise, as previously
discussed. Personal protective equipment and decontamination of equipment can reduce the
potential for dermal contact and inhalation.
Leachate Collection:
Because LCI uses the existing system, no short term impacts are anticipated. Alternatives LC2,
LC3, and LC4 would result in increased noise and dust during construction. In addition, the
potential exists for construction workers to have dermal contact with contaminants. Personal
protective measures can be taken to minimize these impacts, as discussed previously.
Leachate Treatment:
LT1 would require no additional disturbance of the Site, although the loading and transport of
leachate would present noise and dust. Alternatives LT2 and LT3 could result in increased noise
and dust during construction. Measures could be taken to minimize these impacts; for example,
watering for dust control, the installation and maintenance of noise control devices on machinery,
wearing noise protection equipment, and wearing of dust masks.
Groundwater Monitoring:
There is no current risk to workers attributable to exposure to groundwater. Alternative GW2
poses a greater short-term risk to workers than GW1, because of the installation of pre-design
investigation wells.
6. Implementability:
Capping:
Alternatives Cl and C2 would require the coordinated work of an earthwork contractor with a
landscape subcontractor. Alternative Cl could be implemented with a minimum of earthwork
activity, limiting the activity to the low areas of the Site only. Alternative C2 would require
more disturbance of surface soils, and therefore more earthwork and compactive effort. Under
either alternative, off-site materials are not expected to be required to complete the cap
construction. Earthwork contractors with landfill capping experience are readily available in the
H. O. D. ROD; September, 1998 49
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area of the Site. An agreement with the adjacent property owner would be necessary for access
to consolidate the off-property waste at the northern edge of the "old landfill" onto Site property.
Both Cl and C2 could be implemented in one construc'ion season.
Alternative C3 would involve the coordinated work of an earthwork contractor with a landscape
subcontractor. A clay source would likely be required which can provide clay meeting the
quantity needs and quality specifications established for the Site. Approximately 103,000 cubic
yards of quality clay meeting the maximum permeability of 1 x 10'7 centimeters per second
(according to 35 LAC 811) would be required to construct a three-foot thick barrier layer. Prior
to transporting off-site clay, weight restrictions and other local road requirements would be
evaluated. An agreement with the adjacent property owner would be required for access to
consolidate the off-property waste at the northern edge of the "old landfill" onto Site property.
C3 may require two construction seasons to implement the entire capping remedy.
Gas Collection and Treatment:
Alternative Gl has already been implemented and would not require additional work beyond
repair of existing vents, where necessary, and typical upkeep and periodic replacement of the
existing vents and flares (as needed). O&M activities (inspections of flares) for this LFG system
are many and frequent; however, they are easily performed.
Alternatives G2 and G3 would involve coordination of earthwork contractors'and gas extraction
system installation specialists. Materials required for the LFG system construction (piping,
blower, flare, fittings, etc.) are readily available, as are the qualified contractors and
subcontractors needed to perform the work. O&M activities (inspections of flares, settings,
controls, telemetry systems) for these LFG systems are required; however, they are also easily
performed.
Leachate Collection:
The equipment used for LC1 already exists, and therefore this alternative would be easily
implemented. Existing wells and manholes would continue to be used, and upgrades or repairs
to these components would be easily made, if necessary.
LC2 would require the installation, via trenching and possible excavation, of corrugated,
perforated piping at the toe of the landfill slopes. This activity is a standard construction
technique and would be readily implemented. Coordination with an earthwork contractor and
potentially a subsurface utility contractor (for yard piping) would be required. Materials
necessary for the installation are readily available in adequate quantities.
LC3 would require installation of wells, installation of header piping, and construction of a
blower and flare system in the "old landfill." Coordination of earthwork, mechanical, and
electrical contractors, as well as other utility contractors, would be necessary. Materials
necessary to construct these components (wells, piping, pumps, fittings, blower, instrumentation,
H.O.D. ROD; September, 1998 50
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etc.) are all readily available. O&M activities (inspections of pumps, fittings, controls, telemetry
systems, and monitoring of leachate volume) would all be necessary and are all easy to perform.
LC4 would require construction similar to LC3, although it would be implemented in both the
"old landfill" and "new landfill." Therefore, coordination of contractors and use of materials
similar to those used for LC3 would be necessary, but on-a larger scale. Materials and labor
necessary to construct this alternative are readily available in sufficient quantity. O&M of this
alternative would be similar to that for LC3, but on a larger scale.
Leachate Treatment:
LT1 would be easily implemented, as the existing treatment is conducted at a POTW following
transport from the Site. The existing pumps could be used, and a tanker truck would be required
to periodically transport the leachate. The tanker truck is already in use.
LT2 would require the construction of a pretreatment plant and ongoing monitoring to verify that
required pretreatment standards are met. This pretreatment alternative would require an on-site
treatment facility be constructed and treatment chemicals be maintained on-site. In addition,
continued O&M of the pretreatment facility would be necessary.
LT3 would also require construction, management, and O&M of a leachate treatment plant. An
NPDES permit would be required before the leachate treatment system could begin operation and
discharge of treated leachate to a surface water body of adequate assimilative capacity. O&M of
this type of treatment plant would be intense and continual, and would require ongoing
monitoring. In order to implement LT3, easements and rights-of-way would have to be obtained
to construct the required piping from the treatment facility to the selected discharge point.
Special property access rights would also have to be obtained, making this alternative the least
implementable of the three.
Groundwater Monitoring:
Both groundwater monitoring programs are readily implementable. The GW2 alternative
involves the addition installation of pre-design investigation wells.
7. Cost:
Table 15 summarizes capital costs, O&M costs, and present worth values for each alternative. A
discount rate of seven percent is used, consistent with OSWER Directive No. 9355.3-20.
Capping:
Alternative Cl is estimated to cost approximately $2.3 million dollars, and reduce infiltration by
approximately 2.3 inches per year (to approximately 1.6 inches per year). Alternative C2 will
cost approximately $5.8 million dollars, and only reduce infiltration by 1.9 inches per year (to 2.0
H.O.D. ROD, September, 1998 51
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inches per year). If C2 was implemented, the additional $3.5 million over Cl would allow more
infiltration due to additional pore space water. C3 will potentially cost from $7.6 to $9.9 million
dollars, depending on the use of existing clay, and will be less effective than C2, reducing
infiltration to 2.2 inches per year. Therefore, Cl is the most cost-effective capping solution, by
having the greatest impact on infiltration control for the least cost. The expected infiltration rates
for the three capping alternatives are based on the HELP model, the results of which are shown in
Table 16.
Gas Collection and Treatment:
The long-term costs of alternatives Gl and G2 are approximately $665,400 and $1.1 million
dollars, respectively. G2 would cost more in capital expenditures. G3 would cost approximately
$1.4 million, because of the increased cost of capital improvements, but would also be the easiest
system to maintain and would be the most reliable system. Alternative G3, because of the
increased reliability and effectiveness of a totally active system, and because the additional costs
to install a totally active system are relatively minimal (compared with the benefit and reliability
of the system), is the most cost-effective alternative.
Leachate Collection:
Alternative LCI, the lowest cost alternative, would cost approximately $49,700, the total of
which is for long-term O&M. Alternative LC2 would cost approximately $1 million, of which
approximately $230,000 is for capital expenditures and the balance is for long-term O&M for
pumping and labor. LC3 and LC4 would cost $1.3 and $1.2 million, respectively. Although the
highest capital cost is associated with LC4 ($439,000), the less intensive O&M requirements for
pumping and upkeep of LC4 make it more attractive than LC3, from a cost perspective.
Therefore, because LC4 provides the greatest benefit (a fully automated leachate collection
system with minimal O&M required) for $1.2 million, and is only marginally more expensive
than the LC2 alternative, LC4 is the most cost-effective alternative.
Leachate Treatment:
LT1 would cost the least (approximately $829,000), all of which is for O&M expenditures.
Alternative LT2 would be the most expensive at $9.8 million. Approximately $476,000 would
be required for the capital costs of the treatment system, and the majority of the LT2 cost
($9,300,000) is associated with O&M for the on-site treatment system. LT3 would be the second
most expensive at $9,400,000. Approximately up to $1,840,000 would be required to build a
treatment and discharge system for LT3 so that the treated leachate could be discharged using an
NPDES permit. Given the excessive costs associated with construction and operation of an on-
site treatment system and the relative ease of directly discharging to a POTW, alternative LT1,
which is equally protective of the environment, and the most readily implementable of the three
alternatives, is also the most cost-effective.
H.O.D. ROD; September, 1998 52
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Groundwater Monitoring:
Alternative GW1 will cost approximately $1,500,000, and alternative GW2 will cost
approximately $1,600,000. These costs represent the total present worth costs of implementing
these groundwater monitoring programs for 30 years. The costs include capital costs of
approximately $39,400 to abandon Public Well VW4 and approximately $652,800 to install a
replacement municipal well, VW7.' The installat; ->n of VW7 is complete. Since GW2 includes
the additional features of a pre-design investigation and natural attenuation monitoring, and since
GW2 is only marginally more expensive than GW1, GW2 is considered more cost-effective.
8. State Acceptance:
The EPA has verbally concurred with the selected remedy of alternatives Cl, G3, LC4, LT1, and
GW2. The USEPA will include the State letter of concurrence in the Administrative Record
upon receipt of the letter.
9. Community Acceptance
Comments from the public and PRPs are covered in the Responsiveness Summary (Appendix A)
of this ROD. Oral and written comments from the community received during the public
comment period were varied, with many comments covering the safety of drinking water from
the groundwater aquifer, and the effectiveness of the preferred alternative of the Proposed Plan to
ensure this safety.
The main issues covered by the WMII (a PRP) comments included WMII's contention that the
vinyl chloride risk quantified in the BLRA is overstated, that the vinyl chloride contamination is
probably not Site-related, and that a discount factor of less than seven percent should be used for
cost estimating. The USEPA responded that it used proper procedures to develop the BLRA and
to recommend use of the seven percent discount factor. The USEPA also responded that it has
not been conclusively shown that the vinyl chloride contamination is not Site-related.
The main issues covered by the Village of Antioch (a PRP) include its concurrence with the
preferred alternative of the Proposed Plan, its emphasis that the leachate and gas collection
system must be active and must be implemented in conjunction with the cap improvements, its
challenging of parts of the Rl/FS, its challenging of WMII claims of current and past leachate
extraction rates, and its request to review remedial inspection and monitoring reports.
The USEPA responded to the Village of Antioch that the USEPA does not plan to approve a less
than fully active leachate and gas collection system unless the pilot studies conclusively show
that such a lesser system will be fully protective of human health and the environment. The
components of the selected remedy will be implemented together; they are not each stand-alone
remedies. The USEPA acknowledged the Village's difference of opinion regarding some of the
information presented in the RI/FS. Finally, USEPA noted that submission of inspection reports
H.O.D. ROD; September, 1998 53
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to the Village of Antioch may be negotiated between the Village of Antioch and any PRP or
PRPs agreeing to perform the Remedial Design and Remedial Action (RD/RA), if the Village
does not become a party to such an agreement.
IX. The Selected Remedy
The Site will be remediated according to USEPA's "Presumptive Remedy for CERCLA
Municipal Landfill Sites" guidance of September, 1993. This guidance establishes containment
as the presumptive remedy for CERCLA municipal landfills. The guidance states that
containment technologies generally are appropriate for municipal landfill waste because the
volume and heterogeneity of the waste generally make treatment impracticable. The guidance
also states that collection and/or treatment of landfill gas, and measures to control landfill
leachate may be implemented as part of the presumptive remedy.
The USEPA selects the folio ving set of alternatives for the remediation of the Site, consistent
with USEPA Presumptive Remedy guidance: Cl (landfill cap restoration and maintenance) for
capping, G3 (active Site upgrade of the landfill gas system) for gas collection and treatment, LC4
(active leachate extraction) for leachate collection, LT1 (continue to discharge leachate to a
POTW) for leachate treatment, and GW2 (monitored natural attenuation) for contaminated
groundwater.
The selected remedy alternatives are integrated in that all of the selected remedy alternatives
must be implemented to ensure that there is adequate protection to human health and the
environment. In particular, the Cl selected alternative must be implemented along with the
G3/LC4 gas collection and treatment/leachate collection upgraded system. Without such an
upgraded system, the Cl selected alternative is not sufficient to protect human health and the
environment.
Should problems arise at the FRWRD POTW due to the increased volumes of leachate to be
processed, an alternate POTW, or an on-site or off-site treatment alternative will be considered.
The selected remedy for leachate treatment allows for the flexibility of the leachate to be
transported to a POTW other than FRWRD, as long as leachate permitting requirements are met.
See Section VII of this report for a description of each of the selected components of the remedy.
See Figure 6 for a layout of the G3/LC4 dual gas/leachate extraction system, and see Figure 7 for
a layout of the monitoring locations for selected component GW2. Locations and/or quantities of
collection and/or monitoring points may vary slightly in the RD.
Tables 17, 18, 19, 20, and 21 provide breakdowns of the cost estimates for each component of
the selected remedy (Cl, G3, LC4, LT1, and GW2, respectively). O&M costs were estimated for
a 30-year period. A discount rate of seven percent (before taxes and after inflation) was used to
convert annual costs to present worth values. The seven percent discount rate is consistent with
the latest USEPA guidance. The cost estimates are intended to represent a range in accuracy of
-30% to +50% of the overall implementation costs of the selected remedy, which is also
H.O.D. ROD; September, 1998 54
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consistent with USEPA guidance.
Table 15 shows a cost estimate summary for all alternatives. Based on this information, the net
present worth of the selected remedy is $7,229,600 ($2,270,000 for Cl + $1,358,400 for G3 +
$1,183,600 for LC4 + $829,000 for LT1 + $1,588,600 for GW2 = $7,229,600).
The selected remedy also includes the following features: 1) a pre-design investigation to further
study the extent, if any, of a groundwater contaminant plume, and 2) a contingent, active,
groundwater remediation alternative. Should significantly more groundwater contamination be
found during the pre-design investigation, should the VOCs in the groundwater be found to be
migrating, or should the remedial actions taken not cause a decrease over time in the groundwater
contaminant levels, then an active, groundwater remediation alternative will be considered as
part of the remedial action for the Site.
For the GW2 groundwater monitoring component of the selected remedy, groundwater
monitoring will be performed in order to comply with the chemical and action-specific ARARs
of Table 13. The list of contaminants to be monitored, shown in Table 22, will be studied further
during the RD.
For the G3 gas collection and treatment component of the selected remedy, air monitoring will be
performed in order to comply with the action-specific ARARs for landfill gas management, gas
collection, and landfill gas processing and disposal identified in Table 13. Frequencies of
monitoring, monitoring points, contaminants and indicators monitored, and the duration of
monitoring will be covered during the RD.
Surface water monitoring of Sequoit Creek will be performed to comply with the chemical-
specific, surface water ARAR (35 IAC 302.202-302.212) shown in Table 11. Frequencies of
monitoring, monitoring points, contaminants and indicators monitored, and the duration of
monitoring will be covered during the RD.
A. Institutional Controls
The selected remedy includes institutional controls and Site access restrictions. Access
restrictions will include upgrading the existing fencing, signs, gates, and deed restrictions.
Upgrading the existing fencing will improve Site security and restrict access to the Site by
unauthorized individuals. A newly constructed chain-link fence will be approximately six-feet
high with three strands of barbed wire at the top. Approximately 2,000 lineal feet of fencing will
be needed to either replace or augment the existing fencing and completely enclose the Site.
Locking gates will be located at entry points. Warning signs that include a phone number to call
for further information will be posted approximately every 300 feet along the fence, at a height of
approximately five feet. The Site owners are responsible for implementing and maintaining the
effectiveness of these access controls.
Restrictive covenants on deeds to the Site will be maintained to prevent or limit Site use and
H.O.D. ROD; September, 1998 55
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development. The covenants will notify a potential purchaser of the property of the past landfill
activities, and will assert that the land use must be restricted to ensure the continued integrity of
the waste containment remedy. The Site owners will ensure that these restrictive covenants are
maintained.
Use of groundwater from the Site vicinity is prohibited by the Village of Antioch ordinance
(Antioch Water Works and Sewage Ordinance Sections 50.008, 52.009, and 52.011) requiring
properties within the Village limits that abut the rublic water works and sewerage system to
connect to the municipal water supply system. Furthermore, the ordinance prohibits the
installation of private wells within Village limits. The Village of Antioch is responsible for
implementing these groundwater use restrictions.
B. Natural Attenuation
The natural attenuation remedy is described in the 1990 Preamble to the NCP at 55 Federal
Register 8734 as a process that will effectively reduce contaminants in groundwater to
concentrations which are protective of human health and sensitive ecological environments
within a reasonable time frame. The natural attenuation remedy is not a no-action alternative.
Rather, contaminant reduction is accomplished by any or all of the following mechanisms:
dilution, adsorption, dispersion, and biodegradation. The circumstances under which the natural
attenuation remedy should be considered include those situations where active restoration is not
practicable, cost-effective, or warranted because of site-specific conditions, and those situations
where physical and chemical attenuation mechanisms will effectively reduce contaminants in
groundwater to concentrations protective of human health in a timeframe that is comparable to
that which could be achieved through active restoration.
Recent guidance disseminated by USEPA (OSWER Directive No. 9200.4-17) clarified the
circumstances under which a natural attenuation remedy should be used. These circumstances
include the following:
• there is no demand for the resource while the natural attenuation remedy is in progress;
• long-term exposure controls are in effect to prevent exposure to contaminated
groundwater and ensure protectiveness;
• the potential for further contaminant migration is low; and
• the natural attenuation remedy is employed in combination with other remedial
measures.
The Site meets each of the criteria stated above. Vinyl chloride degradation behavior and the
degradation rate is dependent on a number of environmental factors including the availability of
electron donors (such as natural or anthropogenic organic carbon) and the concentration of
acceptors (such as dissolved oxygen, nitrate, iron(III), and sulfate) in groundwater. Natural
H.O.D. ROD, September, 1998 56
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carbon can be expected to be plentiful in the wetland areas. Vinyl chloride degrades in a
reducing environment such as the Site. The most recent data developed for the Site appears to
indicate that the natural attenuation process has been reducing tne concentrations of vinyl
chloride downgradient of the landfill.
Currently, there is no demand for the groundwater either on-site, or off-site in the vicinity of the
vinyl chloride contamination. Furthermore, institutional controls, current regulations, and
practical land-use considerations will effectively prevent exposure to the contaminated
groundwater. The hydrogeological and contaminant distribution data developed demonstrate that
the vinyl chloride contaminant area is not migrating, and the concentrations are decreasing. The
VOC groundwater contaminant levels, particularly for vinyl chloride, are expected to attenuate
further as a result of implementing the waste cap improvements, and leachate and gas collection
upgrades. Well US3D, which showed the highest levels of vinyl chloride contamination in 1994,
already shows lower levels. In 1994, the level was 35 ppb, whereas the level in 1998 is
approximately 15 ppb.
On the basis of the above evaluation, this Site meets each of the USEPA's criteria for
implementation of a natural attenuation remedy.
C. Groundwater Cleanup Levels
Table 22 lists the groundwater cleanup levels for the Site. The list of contaminants and standards
is taken from 35 IAC 620.410, which is the applicable State ARAR for groundwater cleanup
levels. The deep sand and gravel aquifer under and adjacent to the Site showed vinyl chloride
levels above the Federal MCL of 2 ppb, which is also the Illinois Groundwater Quality Standard
for Class I (drinking water) aquifers. The USEPA considers the subject deep sand and gravel
aquifer a Class I aquifer, based on the current use and expected future use for drinking water.
The point of compliance for the groundwater cleanup levels is at and beyond the waste
management unit boundary. The approximate waste management unit boundary is shown in
Figure 2. In particular, well US3D is the primary point of compliance since vinyl chloride
contamination was detected in excess of the MCL at only this location. Well US3D is directly
adjacent to and southwest of the waste management unit boundary, as shown in Figure 4. Figure
7 shows the groundwater monitoring locations that are part of the GW2 selected remedy
component. Final locations to be used to monitor groundwater quality will be determined during
theRD.
Since the effectiveness of the selected remedy components of waste cap improvements and
leachate and gas collection upgrades on the remediation of the landfill (in terms of the rates of
reducing the waste mass and reducing migration of VOCs into the groundwater) will not be
known until the remedy is in operation, it is difficult to estimate the time period required to reach
groundwater cleanup levels. It is also difficult to estimate this time period because of the
uncertainties of the biological activity in the deep sand and gravel aquifer, the velocity of the
groundwater flow, and the diffusion of VOCs in the subsurface environment.
H.O.D. ROD; September, 1998 57
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Since vinyl chloride was the only contaminant identified in the BLRA as being associated with a
significant health risk, the estimated range of time needed to fall below the vinyl chloride MCL
of 2 ppb is presented:
Assuming that the remedy eliminates further migration of vinyl chloride into the
groundwater, the concentration in well US3D is expected to drop below 2 ppb (from
current levels of approximately 15 ppb) in about 3.5 years. This is a best-case estimate, and
takes into account the groundwater flow velocity in the deep sand and gravel aquifer, and
the diffusing effect of the non-contaminated groundwater. The expected reduction in
contaminant levels over time is supported by recent groundwater analytical results that
show vinyl chloride concentrations are decreasing over time (from 35 ppb in 1994 to
approximately 15 ppb in 1998).
A worst-case estimate for the time of degradation assumes no groundwater flow. This
estimate discounts microbial biodegradation and dilution in the flowing groundwater, and
only accounts for natural diffusion of vinyl chloride over time. Given these conservative
assumptions, the current, approximate concentration of 15 ppb vinyl chloride in well US3D
may be expected to decrease below the MCL of 2 ppb in approximately 11 years.
X. Statutory Determinations
CERCLA Section 121(b)(l) (Cleanup Standards) states: "Remedial actions in which treatment
which permanently and significantly reduces the volume, toxicity, or mobility of the hazardous
substances, pollutants, and contaminants is a principle element, are to be preferred over remedial
actions not involving such treatment. The off-site transport and disposal of hazardous substances
or contaminant materials without such treatment should be the least favored alternative remedial
action where practicable treatment technologies are available." Section 121 of CERCLA also
requires that the selected remedy be protective of human health and the environment, comply
with ARARs unless a statutory waiver is justified, be cost-effective, and use permanent solutions
and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. The following sections discuss how the selected remedy meets these statutory
requirements.
A. Protection of Human Health and the Environment
The Cl cap restoration and maintenance alternative will protect human health and the
environment by preventing dermal contact with landfill contents, by reducing contaminant
leaching to groundwater, by controlling surface water runoff and erosion, and by reducing the
potential for direct inhalation of landfill gas by providing increased containment for landfill gas.
Any short term risks associated with regrading and placement of soil (dust generation and
contaminant vaporization) will be minimized by the use of good construction practices. Air
monitoring will be conducted during remedial action to assure compliance with all ARARs and
other specified air quality standards.
H.O.D. ROD; September, 1998 58
-------
The G3 active gas collection and treatment alternative sufficiently reduces risk to human health
and the environment by preventing inhalation of vapors and by controlling migration of landfill
gas. This alternative will further reduce the concentrations of VOCs in the leachate by removing
them before they partition into the liquid phase.
The LC4 active leachate extraction alternative will extract leachate from the entire waste mass.
This system will increase leachate collection volumes and control leachate head levels, thereby
reducing the potential for leachate migration and minimizing potentially adverse impacts due to
infiltration through the cap.
The LT1 leachate treatment alternative is currently operational at the Site. Under alternative
LC4, larger volumes of leachate would be transported to the POTW during the beginning years
of the remedial action. However, the LT1 alternative is protective of human health and the
environment, provided the If ichate is discharged to the POTW in accordance with the industrial
discharge permit.
The GW2 monitored, natural attenuation alternative provides 30 years of ground water
monitoring. Because migration of groundwater contamination and contaminant levels will be
closely monitored over time, this alternative is protective of human health and the environment.
B. Attainment of ARARs
The selected remedy will comply with all Federal and State ARARs. The ARARs are identified
in Tables 11, 12, and 13 of this ROD. The requirements which significantly impact the remedy
are summarized here.
The primary chemical-specific ARAR is the IEPA Groundwater Quality Standards for Class I
(drinking water) groundwater. This requirement states that concentrations of the listed inorganic
and organic chemical constituents must not be exceeded in Class I groundwater, except due to
natural causes or as provided in 35 IAC 620.450 (Alternative Groundwater Quality Standards).
The primary location-specific ARAR for the selected remedy relates to the protection of wetlands
at the Site, as the Site is not located in a floodplain. Compliance will be assured by minimizing
physical disturbance of the seasonal wetlands during cap improvement activities. Since the
seasonal wetlands are located south of the "new landfill" area, outside the delineated landfill
boundaries, there should be no physical disturbance of the wetlands during the remedial action.
The primary action-specific ARARs are IEPA cover requirements at 35 IAC 807; IEPA post-
closure care (including leachate collection) requirements at 35 I AC 811; DEPA leachate
treatment, storage, and disposal requirements at 35 I AC 811; and landfill gas management,
collection, processing, and disposal requirements (described in various parts of 35 IAC).
Compliance with leachate treatment and disposal requirements will be achieved by trucking the
leachate to a permitted POTW and properly treating the leachate at the POTW.
H.O.D. ROD; September. 1998 59
-------
C. Cost-Effectiveness
The present worth of the selected remedy (based on 30 years of O&M and a seven percent
discount rate) is $7,229,600. This total cost is made up of the Cl component cost of $2,270,000,
the G3 component cost of $1,358,400, the LC4 component cost of $1,183,600, the LT1
component cost of $829,000, and the GW2 cost of $1,588,600. See Table 15.
The selected remedy provides overall cost-effectiveness because it uses on-site and off-site
remedial measures to obtain a high level of protectiveness, compared to the cost of
implementation.
The selected remedy includes the least costly capping and leachate treatment alternatives. The
gas and leachate collection portions of the selected remedy are more costly because of the need to
effectively reduce the waste mass, thereby minimizing the chances for groundwater contaminant
migration. The groundwater monitoring portion of the selected remedy is slightly more costly
than the NFA groundwater alternate e, because of additional monitoring requirements and
because of the requirement for a pre-design investigation to further study the extent, if any, of a
groundwater contaminant plume.
D. Use of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The Cl alternative will control stormwater infiltration into the landfill, thereby decreasing the
potential for contaminant transport into the leachate and groundwater. This alternative, which
combines both access restrictions and improved cover, will prevent direct contact with landfill
contents. It will also minimize future erosion and control surface water runoff by implementing
the maintenance plan described for the alternative. The soil cover can last indefinitely if
correctly maintained.
The G3 alternative will provide increased long-term effectiveness and permanence over the other
gas collection and treatment alternatives. It will provide active extraction of landfill gas, thereby
reducing the VOCs in the waste mass. This alternative will also be very effective at minimizing
landfill gas emissions from the Site.
The LC4 alternative will increase leachate collection quantities compared to the current system,
and should operate effectively for many years. The increased leachate extraction will reduce
leachate levels in the landfill and control the formation of leachate seeps. The reduction of
leachate volume within the waste mass will minimize the potential for migration of leachate to
groundwater.
The LT1 alternative will provide long-term, effective leachate treatment. However, this is
contingent on the POTW being able to process tiie increased volume of leachate delivered from
the Site.
H.O.D. ROD; September, 1998 60
-------
The GW2 alternative has long-term effectiveness in that it will provide for 30 years of
groundwater monitoring and analysis.
Since transport of the leachate to a POTW and POTW leachate treatment is already an efficient
method of leachate treatment that is protective of human health and the environment, alternative
treatment technologies are not appropriate for inclusion to the selected remedy.
Containment is an appropriate remedy for the rr. j.nicipal landfill waste because the volume and
heterogeneity of the waste generally make direct treatment of the waste impractical and cost-
ineffective. Instead of direct treatment of the waste, the selected remedy uses leachate collection
and treatment, gas collection and treatment, and waste cap improvements, which are much more
cost-effective measures that provide protection of human health and the environment.
E. Preference for Treatment as a Principal Element
The selected remedy reduces the threat of ingesting vinyl chloride-contaminated groundwater by
employing waste cap improvements, landfill gas collection and treatment, and leachate collection
and treatment. Since the selected remedy includes leachate and landfill gas treatment, the
selected remedy satisfies the statutory preference to employ treatment as a principal element to
permanently and significantly reduce the volume, toxicity, or mobility of the hazardous
substances, pollutants, and contaminants.
XL Documentation of Significant Changes
There are no significant changes in the selected remedy from the preferred alternative originally
presented in the Proposed Plan.
H.O.D. ROD; September, 1998 61
-------
SITE LOCATION MAP
SITE LOCATION
FIGURE 1
-------
£
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-------
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-------
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-------
Table 1: List of Acronyms and Abbreviations, Page 1 of 2
ADR Alternative Dispute Resolution
AOC Administrative Order on Consent
ARAR applicable or relevant and appropriate requirement
BLRA Baseline Risk Assessment
BOD biochemical oxygen demand
Cl Capping Alternative # 1
C2 Capping Alternative # 2
C3 Capping Alternative # 3
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980
CFR Code of Federal Regulations
ESI Expanded Site Investigation
FIT Field Investigation Team
FRWRD Fox River Water Reclamation District
FS Feasibility Study
Gl Gas Collection and Treatment Alternative # 1
G2 Gas Collection and Treatment Alternative # 2
G3 Gas Collection and Treatment Alternative # 3 .
GMZ groundwater management zone
gpd gallons per day
gpm gallons per minute
GW1 Groundwater Monitoring Alternative # 1
GW2 Groundwater Monitoring Alternative #2
HELP Hydrologic Evaluation of Landfill Performance
HRS Hazard Ranking Score
IAC Illinois Administrative Code
IEPA Illinois Environmental Protection Agency
IPCB Illinois Pollution Control Board
LC1 Leachate Collection Alternative # 1
LC2 Leachate Collection Alternative # 2
LC3 Leachate Collection Alternative # 3
LC4 Leachate Collection Alternative # 4
LFG landfill gas
LT1 Leachate Treatment and Disposal Alternative # 1
LT2 Leachate Treatment and Disposal Alternative # 2
LT3 Leachate Treatment and Disposal Alternative # 3
MCL maximum contaminant level
MCLG maximum contaminant level goal
MHE east manhole
MHW west manhole
NCP National Oil and Hazardous Substances Pollution Contingency Plan
-------
Table 1: List of Acronyms and Abbreviations, Page 2 of 2
NPDES National Pollutant Discharge Elimination System
NFA no further action
NPL National Priorities List
O&M operation and maintenance
OSWER USEPA Office of-Solid Waste and Emergency Response
PA Preliminary Assessment
PCB polychlorinated biphenyl
PELA P.E. Lamoreaux & Associates
PNA polynuclear aromatic hydrocarbon
POTW publicly owned treatment works
ppb parts per billion
PRP potentially responsible party
PSER/TS Preliminary Site Evaluation Report/Technical Scope
PW present worth value
RA Remedial Action
RACT Reasonably Available Control Technology
RD Remedial Design
RI Remedial Investigation
RME Reasonable Maximum Exposure
ROD Record of Decision
ROI radius of influence
SARA Superfiind Amendments and Reauthorization Act of 1986
SVOC semi-volatile organic contaminant
TCE trichloroethylene
TSC Testing Services Corporation
USEPA United States Environmental Protection Agency
USGS United States Geological Survey
VOC volatile organic contaminant
VW village well
WM1I Waste Management of Illinois, Inc.
-------
Table 2: Selection or Chemicals of Concern in Groundwater
Chemical
Aluminum
Arsenic
Ban urn
Beryllium
Cadmium
Calcium
Chromium (total)
Co bah
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Thallium
Vanadium
Zinc
DATA GROUPING
ON-SITE
Surficial
Sand
ND
6
6
ND
ND
5
S*fc^9Fj|^!>
ND
ND
5
ND
5
' 2 -
ND
5/6
5/6
ND
ND
ND
Deep
Sand/Onvel
ND
6
6
ND
6
5/6
*^mm&
ND
ND
5
ND
5/6
' - >!<;", :
VD
5/6
5/6
- -2' — •
ND
ND
Carbon disulfide
4-Chloroaniline
1,2-DichJoroethene
2-Mcthylphenol
Trichloroethene
Vinyl chloride
Acetone
Chloroform
1,2-Dichloroethane
"""• *% fr *
ND
3
ND
' -3 •
..- '*' '
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
OFF-SITE
Surficial
Sand
ND
6
6
S. ',V%< V t <•»
6
5
«&mwm?'f'-
3&&%W™:
ND
5
ND
5/6
: 'l'>i
6
5/6
5/6
ND
ND
6
Deep
Sand/Gravel
ND
ND
.. .. j
ND
ND
5
*"» '>.•{. £ JS^ / -5"
ND
ND
5
ND
5
, --I ,
;i
5
5
ND
ND
\> "•
Private
Wells
(Silver Lake
Area)
6
ND
6
ND
ND
5/6
<4 1* *%»&fg.r>i' ,
''l'^''^'*,? ", *'
', '"•£'>' '••
', r'f ^ -.4 S
5/6
6
5/6
6
ND
5/6
5
ND
6
2
ND
ND
3
ND
ND
3
ND
ND
ND
ND
ND
j
ND
ND
;"'^ %
ND
ND
ND
ND -
ND
ND
' < v<'J, -
ND
ND
ND
ND
ND
Municipal
Wells
I,-
<~.-'\
s~>,-i -
ND
ND
5
-------
Table 3: Selection of Chemicals of Concern in On-site Surface Water, Sediment, and Soil
Chemical
On-site Soil
Sequoit Creek
Surface Water
Sequoit Creek
Sediment
Accnaphtfaene
.ML
Acetone
ML
-fctCL
^njhi
.NIL
lenzene
ND
Si. ". ~**&?Ms3lKS?'.i .* ,'<'
-ML
_ML
*'*?'"/• •
.ML
A-DDD
htntane
ms38®?mm
_ML
-NO.
ML
Methvlem Chloride
??*<£",
bOL
• &>'•• $v
L
Phenanth
Pyrrne
Toluene
.ML
ND
Antimnnv
Aluminum
Aracnic
ML
±
bOL
5/6
JflL
JHL
^vmnide
-ML
5/6
5/6
5/6
Mercury
Jin.
ND
NT)
5/6
-ML
ShMted in* indiada * oontunmaK of cancan (elected forthu daU poupng.
ND - Not deudcd in Ihn diu poup.
Rjtiontlc Tor caaUmuuu* iclectian:
I =
2 =
3-
4 =
Selected u * defiuh became then wtre fewer than three simple* in thia d«U grouping, in accordance with telephone conference call with
USEPA Region 3 on February 3. 1994.
Selected because background data were not available for this contaminant
All organic conUminanla were selected.
Selected because a significant difference waa observed in a Hest with regional background data (at p - 0.05 significance level).
Rationale for contaminant exclusion:
3 = Chemical not selected because it u an essential human nutrient.
6 = Chemical not selected because no significant difference was observed in a l-test with background data (at p = 0.03 significance level), or
significant difference was observed because background level] were significantly higher than Site levels.
-------
Table 4
Summary of Analytical Rnulti
Detect*) VOCt, SVOCt and P«tlcldn/PCB»
Remedial Invtttifalion - Leachate Samples
aO.D. Landnil
Antkx-h, Illlnou
C«»HW<1''
D*urtt4 VOO
Dttichtm Ltmit
Vtftyl CWonde
OhloroetHuw
Methytcnc Chlondc
Acetone
,,1-Dtchloroethcne
1.1-Ochlurocthuie
I 2-Dichloroethent
l,2-Dich)oroeth*iie
2-Buttnone
1 7-DichlorupropBne
Tnchkw oethenc
Benzene
4 • Methyl - 2 • Penunonc
2-Hexanone
Tttrachlorocthene
Tohwnc
Ethyttwnunc
Xyknes(loUl)
D«tMtotfSVOC»
£*t*cllo* Umli
PhmoJ
1 4-Dichk)robenzfln«
3-MMhylplMfurf
4-M«hytoheno)
2 4-Dime0iylphenol
Niph(h*l«M j
Di-n-butytphlhrnUto
bo< 1 -«Uiylh»yl)ph!hiln«
O*Uct*4 l>«ua«>r4i
MCL
2
>
7
10
•>
—.. -
5
5
3
1.000
TOO
11.000
CUol
2
5
700
7
100
70
}
5
^
»
5
1.000
700
10.000
100
J50
140
25
5.600
100
6
05
Clwll
10
50
TOO
J5
3.iOO
200
25
25
25
25
23
2.300
1.000
10,000
100
350
140
39
5.600
1.500
60
rs
Sraiti DtitguUra
HD-LCLMl-ll
25
45
160
110
7
190
12
22
14
9
330
52
100
50
160
730
12)
321
1
46
HD-LCLM1-»1
50
46
ISO
13
22
450
46
90
54
170
760
11)
34J
31)
1
63
HD-LCLm-ll
250
58
2.200
3.200
160
210
170
10
83
5
16
1.300
. 4) 1
6)
1
HD-LCLTM-ll
1.000
19.000
12.000
450
260
52
840
2.200
20)
26)
1
HD-LCLTll-tl
500
1,500
190
3,900
740
130
330
10
51
20
48
3)
16
4)
42
1
HD-LCMME-41
10
11
44
.140
3
13
70
22
120
28
14
22
43
»
62
41
10
19
5)
61
1.1
HD-LCntl-ai
10
1
13
10
1)
1 1
HD-LCTBtl-41
10
3
5
1
Notes
TICi not reported m T«bl.. TlCi refute oMMnttd a Append" O-7 of the RI
ConcentnhoM reported m micnjgrmiro pef btffl (ue/L)
1 • Einnuted nlue below detection toil
Simples coDected on Mey 12-13. 1°93
-------
TiblcS
Summary of Detected VOCt
Remedial Inveitijation - Landlill Gu Simple*
H.O.D. Landfill
Antiocb. Illlnou
Com pounds
Frcon 12
ChJoromctiunc
Freon 114
Vinyl Chloride
Chloroethftftc
Frcon II
cii-l 2-DCE
Cubon Dindftdc
Acetone
Methylcne Chloride
I I -Dichloroclhanc
1 1 -Dichlorocthcne
2-BuUnonc
Renzcne
Trichl orocthcnc
TclrichlorocUicne
f* K f i irnh enzcn C
Fthvlbcftzcftc
Yvlenea (loUl)
4Pthvl toluene
1 3 5-TrimeUiylbenzen
1 74-Truncthylbenzeni
Sample De*l(fiatlon
HD-LGLPOI-OI
47
78
6.3
95
21
10
540
34
52
•-
DL
4
5
4
5
10
2
, 4
20
20
8
5
4
6
6
5
6
6
5
5
10
8
5
6
D LGLP06-0
6.300
7,200
4,900
810
12,000
370
690
730
220
140
1,800
420
160
11,000
270
180
3,700
7.600
J20
200 j
440
DL
80
6,000
" 80
100
200
[200
80
400
400
160
100
80
120
120
100
120
120
100
100
200
160
100
120
HD-LGLP07.0I
1,800
21,000
270
5,400
3,900
540
480
5,200
970
2,500
66.000
4.400
11,000
30,000
1,300
510
1.200
JM.
400
500
400
500
1,000
200
400
2,000
2,000
800
500
400
600
600
500
600
600
500
500
1,000
800
500
600
D-LGLPoa-0
2.100
720
760
13,000
1,400
15,000
22,000
670
590
53,000
830
4,500
9,700
24.000
2,600
910
2,100
DL
400
500
400
500
LOGO
200
400
2,000
2,000
800
500
400
600
600
500
600
600
500
500
1,000
800
500
600
D-LGLPI' 0
9,100
860
1,100
310
2,40(1
630
960
20,000
2.700
3.200
7.000
1
DL
400
500
400
500
1,000
200
400
2,000
2,000
800
500
400
600
600
il)0
600
600
HD-LGLPI1-91
8,600
940
1,300
330
2,700
520
600
690
1,000
21.000
2,800
500
500
1,000
800
500
600
3,400
7,100
490
420
DL
200
250
200
250
500
100
200
1,000
1.000
400
250
200
300
300 '
250
300
300
250
250
500
400
250
300
HD1.GTB01-01
._ .
DL
Note*:
Sunplci collected on June 4,1993
ConcenUitiom reported in pint per billion
Only delected compound! reported
No compound* detected in Trip Blank
DI. - detection limit
-------
Table 6, Page 1 of 2
Summary of Analytical Results
Detected VOCs, SVOCs and Pesticides/PCBs
Remedial Investigation - Round 1 and 2 Groundwater Samples
H.O.D. Landfill
Antiocb, Illinois
1 —
D*tlc**U°*
MCL
Cliu 1 Sid.
dm II Sid
Ul IS-OI
UIID-OI
usois-oi
inoiD-oi
IJS03S-01
USOM-OI
US03D-OI
US04SOI
US04D-OI
US06S-OI
US06I-OI
US06D-OI
W3D-OI
W3SB-OI
W4S-OI
W5S-OI
WU-OI
W7D-OI
700
• ^_.
_-. —
ttnt 1 Cr*u«w«Uf »
C«
CarW* DteaWW*
700
3)00
OBJ
~
.
_ 1
•mr«*t
.p~.d.
Vl«yt Cbbrkk
1
7
10
~~~~
.
11
l»
•
l.l-DCI
70
70
700
_
11
35
71
TCI
5
1
7'
9..pb
DM|£»UO>
MCL
Cliu I Sid
Cl.ii II $id.
Ol IS-OI
OIID-07
usois-oi
U50 ID 02
USOM-02
IIS03D-07
US04S-07
US04O-07
IIS06S-07
US06O-07
W3D-07
W3SB-07
W4S-02
W5S-07
WoS-02
W7D-OJ
Ac*tek«
700
700
- -
^
R«ud II Gr*u4tw«IOT Si
C»i
C.rW. Dh.ttW.
700
»00
IB
, ,
*ru*t
•roud
Vli^ Cklorld.
3
7
10
_
<5
i.i.nct
70
70
700
18
44
,
TCI
5
1
75
" ~~
II
NotM
Round I Urowdvtta Swnpltl cobcud m Miy'liiM I«J
Round II OioundwitH Swnpl« toQ«cl»d in Much l«94
ConcMtntioni ttfonft in nuaoymmt per bur (u(A.)
J • MtimiUd vthu Mow dMcaon limit
SVOTi «nd PnliadWI'CBt •"• MM dMMUd in pouniiw«« ninpUt mi m Dunfon not rapoiud m 0>« Tibl.
Tht dXicbon lunil fof VCXTi for ill umpln wu 10 U|/1
-------
Table 6, Page 2 of 2
Summary of Analytical Results
Detected VOCs, SVOCs and Pesticides/PCBt
Remedial Investigation - Private/Village Well Groundwater Samples
UO.D. LandHII
Antioch. Illinois
Compound*
DetectedyOCi
Carbon Diiulfide
Detected SVOC
T^Mclhylphenoi
4-Chloroinilinc
_. -
•• -•
Grouadwater Sluidirdi
MCL
Cluil
700
350
Claull
3500
350
DL
, 1
5
5
VW3-01
07J
VW5-OI
0.6J
0.5J
.,_
Sample Dciif nation (Round 1 Sampling)
TVS-OI
0.6J
0.5J
PWI-01
PW2-OI
0.9]
•
PW3-01
PWS-01
Compounds
Delected VCX'J
Acetone
cii-l.2-DCF.
Detected SVOc
2-Methylphcnol
4-Chlooaniline
"
— -•
•-
—
Groundwder Slandwdi
MCL
-
,
Claal
700
70
70
1
350
Caiill
700
200
200
350
Sample Designation (Round 2 Sampling)
DL
5
1
1
-J
VW3-02
I1J
0.7J '
0.7J
VW4-OJ
61
0.5J
- - - - - -
VW5-OI
08J
0.5J
Note*
Concentiationi reported in microgrinu pet liter (ug/L)
1,2-DCE- 1,2-Dichloroethene
J - Eilurutcd value below detection limit
Round I Simplei collected in JuncVuly 1993
Round 1 Samplei collected in March 1994 (Private wclli not umpled during Round 2 activitiet)
Peiticidea/PCBi were not detected n Private or Village Well Groundwater umples
DL - detection limit
-------
Table 7
Summary of Analytical Results
Detected VOCs, SVOCs and Pesticides/PCBs
Remedial Investigation - Round 1 and 2 Surface Water Sample*
H.O.D. Landfill
Antioch, Illinois
VOCi
2-Hexanonc
T-melhyl-2-pcnUnone
Drtrrttd VOO
2-Hexanone
4-melhyl-2-penUnone
Round I Surf«r« W«t*r Sample.
"swsioi-oi
SWS201-OI
SWS30I-OI
3J
SWS101-02
Round 2 Surhct W.i»r Sunpltt
SWS30I^)2
. .
SWS40I-02
SWS30I-02 SWS601-02
SWPSO1-02
SWPSG2-02
—
NoU«
Tentatively IdenttTicd Compound! (TK'i) not reported in Table
Concentration reported in microgrunt per kilogram (ug/kg)
J - EilimMcd value below detection limit
SVOCi and Paticidet/PCBi were not detected in Round I or 2 surface water umplei
VOCi were not detected in umplo other than SWS301-01
Round I Samplct collected in May. 1993
Round 2 lamplet collected in March 1994
The detection limit for all ««mplet wai 10 ug/1
-------
TablcS
Summary of Analytical Results
Detected VOCs, SVOCi and Pesticides/PCBs
Remedial Investigation - Round 2 Sediment Samples
H.O.D. Landfill
Antioch, Illinois
Dtticae* Limit
Drttrtrd VOCt
PhcnanUucnc
Fluoranthene
Pyren7_ __ ~
I Heiuo (a) anthracene
Ch/ytene
b^2^elhyihexyl)-phtjialatie __ I
Henzo (b) fluoranthene
Bcnzo (a) pyrene
Simple Dttl(nation (Round I Srdlmtnt Sunftea)
SDSIOI-02
510
SDS201-02
1500
"370
940J
SDS301-02
ISO
3IOJ
680J
580J
250J
300J
I500J
430J
290J
SDS401-02
1100
SDS50I-02
4*0
SDS601-02
«M
SDPSGI-02
ZSOO
....
sc
-- -
2100
Noler
TenUUvcly Identified Compound" (TICl) not reported in Table
Concentration reported in microgram* per kilogram (ug/Vg)
J - Eilimated value below detection limit
VCX7« and Peiticidca/PCBi were n-U detected in aediment aamplei
SVOCi were not detected in umplo other than SDS20I and SDS301
Samples collected in March 1994
Sediment samplei not collected during Round I field activities
-------
Table 9
Summary of Analytical Results
Detected VOCs, SVOCs and Pesticides/PCBs
Remedial Investigation - Round 1 Surface Soils Samples
H.O.D. Landfill
Antioch, Illinois
— — ~ «?._.!_ FV__t ___*!«•»
fMnpoundt _.. —
Dtierted'VOCi
• " DatcDoHUmil
Melhytene Chlonde
Acetone
Carbon Ouullide
jenzene ..„_
Polucne - —
Kihylbenzene
Xylenes _
ri;r.rt."ftft
420
36)
59)
52)
3.500
4.2
HD-SU04-91
11
510
15
2J
410
3,600
4J
HD-SU05 01
12
410
51)
7J)
54)
9.600
4.1
Notes
TenUUvely Identified Compound! (TIC>) not reported in Ttble. TICj result] pretentod m Appendix O-12 of the Rl
Concentiatioru reported in nucrogrura pa ktlogrun (ug/kg)
J • Estimated value below detection limit
Surt'uc Soils simples not collected during Round 2 Rl sampling acuv
Sumples collected on Miy 14. 199J
:tjvities
-------
Table 10: Summary of Baseline Risk Assessment Results
Contami-
nants of
ncern
Contami-
Hazard I nants of
Index I Concern
RME Excess
Lifetime Cancer Risk
TC Pathwa
hilri/Tx-nnor Sit* Trnuatatrr
forinVntal Snrfare Snfl Inwttinn
Ahurrntim frnra Snrfare Sflfl
IVrmal CAatrnfl vMh Snrfar* W
TnrM*n«l Sorflnmit In
Inhslatimi nfVnlarilM frmn Amki»< Ah-
nirrrl rnntirr wtrti r*rr*nnamir FAR
Surface Soill Cincer risk not likelv
Cancer mk not lilrelv
laeestion of Groimdwat
Off-Site Surficial Sand
Ofr-Site Dcco Sand and Gravel
Murocinil Wells
Inhalation nf VnlotflM whilr ShflHpvfa
Off-Site Deeo Sand and Gravel
Weils
nrrmal Ahuimdon While Shnwrrino
Off-Site Surficial Sand
Off-Site Deeo Stnd and Gravel
Muraaoal Wells
Off-Site Surficial Sand
Off-Site Deep Sand and Gravel
Muriciual Wells
PrivntK Wplj^
7E-05
9E-04
9E-05
SF jn
Berrllhim
Vmvl Chloride
Anenic
NA
LT 1 (6E-011
LT 1 «E-On
LT 1 (5BOH
i T \ rw-cm
NA
NA
NA
MA
Information taken from "Baseline Risk Assessment for the H.O.D. Landfill Site Antioch, Illinois," The Wdnberg
Group, Inc./ICF Kaiser, 1997.
Notes:
1E-03-1X10-*- 0.001
LT - Less than
NA = Not applicable
NE = Not eraluated since chemicals rderant for this heahh endpoiot were not selected or detected In this data grouping.
(a) Contaminants of Concern are those with RME cancer risks greater than l.E-06.
(b) Contaminants of Concern are those with RME hazard indices greater than 1.
-------
Table 11: Potential Chemical-Specific ARARs
MEDIA
Surface Water
Groundwater
Air
REQUIREMENT
Protect State water for aquatic life, agricultural use, primary and
secondary contact use, most industrial use, and to ensure aesthetic
quality of aquatic environment.
Pretreatment Standards of State and local POTW
Effluent Guidelines and Standards
Prohibition of discharge of oil or hazardous substances into or
upon navigable waters
Comply with all applicable Federal and State water quality
criteria.
Meet State Groundwater Quality Standards using a Groundwater
Management Zone, if appropriate
Air Quality Standards
CITATION
Water Quality Standards 35 IAC 302.202-
302.212
35 IAC 310.201-220, 35 IAC 307.1 101-1 103
35 IAC 304. 102- 126
Federal Water Pollution Control Act
Section 3 11 (bX3)
40 CFR 11 0.6, 117.21
CWA Section 304(a) and information published
in the Federal Register pursuant to this section;
35 1AC 302.612-669
35 IAC 620.410 unless modified in accordance
with the substantive requirements in 35 IAC
620.250 to 350
35 IAC 243. 120-126
-------
Table 12: Potential Location-Specific ARARs
MEDIA
Floodplains
Wetlands
Stream
REQUIREMENT
Action to avoid adverse effects, minimize potential harm, and
restore and preserve natural and beneficial values (in relation to
implementation of the RA).
Facility located in a 100-year floodplain must be designed,
constructed, operated, and maintained to prevent washout of any
hazardous waste by a 1 00-year flood
Governs construction and filling in the regulatory floodway of
rivers, lakes, and streams of Cook, DuPage, Kane, Lake,
McHenry, and Will Counties, excluding the City of Chicago
Minimum requirements for stormwater management aspects of
new development in Lake County
Action to minimize the destruction, loss, or degradation of
wetlands
Action to minimize adverse effects of dredged or fill materials
Permits for Dredged or Fill Material
Requires Federal agencies involved in actions that will result in
the control or structural modification of any stream or body of
water for any purpose, to take action to protect the fish and
wildlife resources which may be affected by the action
Action to minimize adverse effects of dredged or fill materials
Permits fo' Dredged or Fill Material
CITATION
Executive Order 1 1988, Floodplain
Management, 40 CFR 6, Appendix A, Section
o(aX5)
351AC724.118(b)
92 IAC Part 708
Lake County Stormwater Management
Commission Watershed Development
Ordinance
Executive Order 1 1990, Protection of Wetlands,
'0 CFR 6, Appendix A, Section 6(aX5)
CWA, 40 CFR 230.70-230.77
CWA Section 404
Fish and Wildlife Coordination Act,
40 CFR 6.302(g)
CWA, 40 CFR 230.70-230.77
CWA Section 404
-------
Table 13: Action-Specific ARARs
MEDIA
Capping
Post Closure Care
Leachate Treatment Storage
and Disposal
•
*
REQUIREMENT
Final cover system: A compacted layer of not less than two feet of
suitable material shall be placed over the entire surface of each
portion of the final lift not later than 60 days following the
placement of refuse in the final lift.
Cover stabilization: Residual settlement erosion and control
work; mowing
Post Closure Maintenance: Establishes minimum requirements
for the maintenance and inspection of the final cover and
vegetation
Groundwater Monitoring Program: Establishes minimum
requirements for groundwater monitoring at the site
Leachate Collection System: Establishes minimum requirements
for a ieachate collection system at the site
Landfill Gas Monitoring Program: Establishes minimum
requirements for gas monitoring at the site
Leachate Treatment and Disposal System: Establishes standards
for on-site treatment and pre-treatment
Leachate Treatment and Disposal System: Establishes standards
for Ieachate storage systems
Leachate Treatment and Disposal System: Establishes standards
for discharge to an off-site treatment works
Leachate Treatment and Disposal System: Establishes standards
for Ieachate monitoring
CITATION
35 IAC 807.305( c )
35 IAC 807.622(dX3)
35 IAC 811. 11 l(c)
35 IAC 81 1.319(a) and Part 81 1.318
35 IAC 811.308(aXcXdXeXfXgXh)
35 IAC 811.310
35 I AC 81 1.309(cX3X4)(5X6) Note that this is
only applicable for scenarios LT2 and LT3.
35IAC811.309(d)
35 IAC 8 11.309(eX 1X3X4X5X6)
35IAC811.309(gXlX2)
I of 4
-------
Table 13: Action-Specific ARARs
Landfill Gas Management
Gas Collection
Landfill Gas Processing and
Disposal
Landfill Gas Management System: Establishes minimum
requirements for gas venting and collection systems
Visible and paniculate matter emission standards and limitations
Sulfur air emissions standards and limitations
Organic material emissions standards and limitations
Carbon monoxide emissions standards and limitations
Nitrogen oxide emissions standards
Volatile Organic Material emission standards
Verify that there is no "excessive release" of hydrogen sulfide
emissions during landfill gas management.
Verify that emissions of hazardous pollutants do not exceed levels
expected from sources in compliance with hazardous air pollution
regulations.
Estimate emission rates for each pollutant expected.
Develop a modeled impact analysis of source emissions.
Use Reasonably Available Control Technology (RACT).
Landfill Gas Processing and Disposal System: Establishes
minimum requirements for landfill gas processing and disposal
Estimate emission rates for each pollutant expected.
Develop a modeled impact analysis of source emissions.
Use Reasonably Available Control Technology (RACT).
35 IAC 811.311
35 IAC 212.123 (visible) and 212.321
(paniculate)
35 IAC 2 14. 162
35 IAC 215.143
35 IAC216.121, 216.141
35 IAC 217.121
35 IAC 218.143
35 IAC 211.2090, 35 IAC 214.101
415 ILCS 5/9.1(b), CAA Section 1 12,
40 CFR 61. 12-14
35 IAC 29 1.202
35 IAC 29 1.206
35 IAC 21 1.5370, 35 IAC Part 215, Appendix E
35IAC811.312(aXbXcXdXc)
35 IAC 29 1.202
35 IAC 29 1.206
35 IAC 2 11 .5370, 35 IAC Part 2 1 5, Appendix E
2 of 4
-------
Table 13: Action-Specific ARARs
Direct Discharge of
Treatment System Effluent
The discharge must be consistent with the relevant Water Quality
Management Plan approved by EPA under Section 208(b) of the
CWA, and developed by Illinois EPA.
Use of Best Available Technology (BAT) that is economically
achievable is required to control toxic and nonconventional
pollutants. Use of best conventional pollutant control technology
(BCT) is required to control conventional pollutants.
Technology-based limitations may be determined on a case-by-
case basis.
Discharge limitations must be established for all toxic pollutants
that are or may be discharged at levels greater than those that can
be achieved by technology-based standards.
The discharge must be monitored to assure compliance. The
discharger will monitor:
The mass of each pollutant discharged,
The volume of effluent discharged, and
The frequency of discharge and other measurements as
appropriate.
Approved test methods for waste constituents to be monitored
must be followed. Detailed requirements for analytical
procedures and quality controls are provided.
Duty to mitigate any adverse effects of any discharge
CWA Section 208(b)
CWA Section 306, 40 CFR 122.44(a), and 35
IAC 30 1.400
CWA Section 307(a), 40 CFR 122.44(e), and 35
IAC 309. 152
40 CFR 122.44(1) and 35 IAC 309.146(a)
CWA, 40 CFR 122.21
40 CFR 122.41(d)
3 of 4
-------
Table 13: Action-Specific ARARs
Direct Discharge of
Treatment System Effluent
(continued)
Discharge to Surface Water
Discharge to Sewers
Discharge to POTW
Proper operation and maintenance of treatment and control
systems
Develop and implement a Best Management Practices (BMP)
program to prevent the release of toxic constituents to surface
waters.
The BMP program must:
1 . Establish specific procedures for the control of toxic and
hazardous pollution spills,
2. Include a prediction of direction, rate of flow, and total
quantity of toxic pollutants where experience indicates a
reasonable potential for equipment failure, and
3. Assure proper management of solid and hazardous waste in
accordance with regulations promulgated under RCRA.
Sample preservation procedures, container materials, and
maximum allowable holding times are prescribed.
Effluent standards which establish maximum contaminant
concentrations that may be discharged to the waters of the State
Sewer discharge criteria
Prevent introduction of pollutants into POTW which will interfere
with POTW operation.
40CFRI22.4l(e)
CWA Section 304(e), 40 CFR 125.104
40 CFR 136.3
35 I AC 304. 101-304. 126
35 IAC 307.1 101-1 103
35 IAC 310.20l(aXc) and 310.202, and local
POTW regulations
4 of 4
-------
Table 14: Descriptive Summary of All Alternatives
Action Components
Description
NFA
Under existing IEPA permit, cap maintenance, operation and maintenance of the
existing LFG and manual leachate collection systems, and groundwater monitoring
activities would be performed.
Capping
Cl
C2
C3
Restoration of Cap: The cap would be restored to the original grades established and
approved by the IEPA in the Site Closure Plan. The existing soils would be regraded
and/or off-site clay soils would be imported and compacted to fill low
areas and repair leachate seeps.
Augmentation of Cap: The existing cover soils would be reworked to form a uniform
35 LAC 807 compliant cap consisting of two feet of compacted clay and 2 feet of
additional cover soil.
Reconfiguration/Supplementation of Cap: Existing cover soils would be reworked and
supple icnted (if necessary) to form a 35 LAC 811 compliant cap with 3 feet of
compacted clay and 3 feet of cover soil.
LFG Collection and Treatment
Gl
G2
G3
No Further Action: Continue to passively vent LFG with existing wells and stick flares.
Supplement Existing System: Existing passive flares in new landfill would continue
operation. LFG collection/treatment supplemented through addition of an active
extraction system in old landfill. Pilot/Pre-design investigation would be conducted.
Activation of LFG System: Existing wells (passive) converted to active wells,
additional wells installed in old portion of Site, and LFG conveyed to centralized
blower/flare station. Pilot/Prc-design investigation would be conducted.
Leachate Collection
LCI
LC2
LC3
LC4
No Further Action: Continue to use existing leachate collection points (manual
operation).
Toe-of-Slope Leachate Collection: Toe-of-slope collection piping extended along toe
of both old and new section of landfill and existing extraction points used. Automated
system.
Upgrade/Supplement Leachate System: Toe-of-slope piping extended in new section
of landfill only. Dual extraction system (leachate/LFG) with blower/flare station
constructed on old section of landfill. Pilot/Pre-design investigation would be
conducted.
Active Leachate Extraction: Existing gas and leachate wells in both sections converted
to dual extraction wells. Blower/Flare station would be constructed. Pilot/Pre-design
investigation would be conducted.
Leachate Treatment/Disposal
LT1
LT2
LT3
No Further Action: Continue to directly discharge to licensed POTW.
Pretreat/Discharge Leachate: Physical/chemical pretreatment of leachate followed by
discharge to licensed POTW.
Pretreat/Surface Discharge Leachate: Full treatment of leachate to NPDES standards
followed by remote surface discharge to surface water source (Fox River).
Groundwater Monitoring
GW1
GW2
No Further Action: Continue Groundwater Monitoring Program.
Monitored Natural Attenuation.
-------
Table 15: Cost Estimate Summary for All Alternatives
No Farther Actioa
CippiBf
Cl
C2
O - SipplMMBtaJ Ctoy
O - Hcplscnrat CUy
Cu EilnKtioi/TrcalBcit
Gl - No Farther AcOo«
02
C)
Lackite Extnctioi
LCI-NoF.rthtrAcUoB
LC2
LC3
LC4
.
LackMe Tr*»<»«t
LT1 - No Faitkcr Actioa
LT2
LT3
Gnmmi-mtr Mo*ltori«|
CW1 . No Firtkcr Aettei
CW2
Capital
1923,200
SIJTOMO
s
-------
Table 16: Hydrologic Evaluation of Landfill Performance
Summary Output of Infiltration (Average Annual Totals)
Cl w/freeze of
top 30 centimeters
Cl w/freeze of
top 30
centimeters &
lateral drainage
Precipitation (in.)
Runoff (io.<%))
22.095(67.18%)
22.621(68.77%)
Evapotranspi radon
28.789(87.53%)
Percolation/
Leakage through
Clay Liner
1.62455(4.94%)
1.62966(4.95%)
1.83317(5.57%)
Lateral Drainage
Collected (in.(V.))
Cl w/frceze of
top 30 centimeters
C2 w/freeze of top
30
centimeters &
lateral drainage
Precipitation (in.)
Runoff (in.(%)>
24.871(75.62%)
24.923(75.77%)
Evapo transpiration
Percolation/
Leakage through
Clay Liner
Lateral Drainage
Collected (in.(%))
C3 w/freeze of
top 30
centimeters
C3 w/freeze of
top 30
centimeters &
lateral drainage
32.89(100%)
•^^••^^^HM^^W
5.691(17J%)
••V^H^^^^H^Bi^^
24.878(75.64%)
3249(100%)
^^^•^^^^•^••^•^••^
5.669(17^4%)
^^V^^»^K^B^M~^-^
24^8(75^5%)
32.89(100%)
^^^^^^•^^^^•^^^^^^
1.902(5.78%)
B^M-^li^>^^^^^^^K
24.799(75.4%)
PrecipiUtion (in.)
^•MIB^^^^^^B^^HVM
Runoff (in.(%»
^^^•••M^^M^^HA^HM^baM
Evapolranspl ration
Percolation/
Leakage through
Clay Liner
(ln.%))
Lateral Drainage
Collected (ia.%))
-------
TABLE 17: CAfMNC COST ESTIMATE FOR THE SELECTED REMEDY
Aimmt under tHa alumatnt that the cutting cover toils will t*
regmdtd mt tfockpik tapcoU)
mil • Inw mrm (HT 1 nf Mm \ T «TJ rdecp)
Ptaoe aa^MCttri 0% • low «a («% of New LF va, 4' deep)
Rcpwfa rtaatyiled «Ml (40% of New Lf wn.
(«aoc40*of 51
(MBaie $500 per wdl * 75 wcdi)
(34,600 CY •SSperydS)
(69,200 CY 'STpciydS)
(34.600 CY • 15 per j«D)
(•MM 40% of 51 am* @ $1,500/«
SI 5.000
SI 2.500
S30.600
$37.500
SI 73.000
S4M.400
$173.000
$30.600
$100.000
$25.000
$109,000
$179,000
TOTAL:[ $1.370,000]
Fence rapun md lock rcpbccBeol - iiiumr S2.500 per e«r
Sign repuiWfcpUcemeBl • MKXBC $300 per year
Mowiog - twice per yew @ $30/«cre
[mpoctioa of cover aadnraki qoaterfy @ l/lv • S50/hour
Clon^ of it ami (atom qoirtcrly Jl 32/tv • $50/hcw
Rework rf cover nib
(MHH I Vycv neok rework. 3 Km/yew (§ $5 per yd3 M ? deplk)
• 15S of cotd O*\f)
$2.500
$300
$3,060
$1,600
$6,400
$48,400
$9.400
TOTAL 0*M/YR:r$72.00oJ
Note: CY>o*ieywil»
-------
TABLE \». GAS COLLECTION SYSTEM COST ESTIMATE FOR THE SELECTED REMEDY
CAPITAL CONSTRUCTION AND O*M COST ESTIMATE
lUtn
,.
2.
3.
4.
5.
6.
7.
I.
9.
10.
11.
12.
13.
14.
15
16
17.
18
Type of Work
Mobitzaim/Dcmobilizalioo
Site Safety Pirn
G»Wefc
Gaj Pipe Titachc*
Header Riacf/CleaBOUti
G» WcAeadi
Knoct-OutOjft Stain (KO/LS)
Indnidu*! Coofrol Wra (To KO/LSt)
CnudmtUr Priamu Conveyance Pipe
Dqpbg
CoiKfcauKHaldbDgTnk
CanpraMor and Control Station
Bbwtr Station
Uttly Flare Station
Our awl Grub
AcceaiRoad
ChantDk Fencing
Ekctncal Service Supply
E
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TABLE 19: LEACHATE COLLECTION SYSTEM COST ESTIMATE FOR THE SELECTED REMEDY
CAPITAL CONSTRUCTION AND CAM COST ESTIMATE
Htm Type of Wort
1. MobiliZJUoo/Dernobilizition
2. Site Safety Plan
3 Gaa Wella
4. Ga> Pipe Trcncaea
5. Lcaclute Gnvity Conveyance Pipe
6. Header Riacr/CleanooU
7. Gaa/Ladulc Wellhead.
8. Well Pi*npaw/Traa*nitter /Control!
9. Knock-out/Lift Station (KO/LS)
10. hidividual Control Wnea (To KCVLS.)
II. Uachatc Praaure Conveyance Pipe
IZ Dripkg
1 3 . Condematc/Lcachate Holding Tank
14. Comprcaaor and Control Station
15. • Blower Station
16. Utility Flare Station
17. Clear and Grab
18. AcccaeRoad
19. ChainJink Fencing
20. Electrical Service Supply
21. Syuem Automation
TOTAL Eitcnded Capital Conalroction Price
Estimated
QlaXJtio
1
1
2lu
11.500
11,500
34
34
34
3
4,200
4.200
1
1
1
1
1
0.62
3000
300
300
15% of Cap. Coat
Unit
LS
LS
LF
LF
LF
EACH
EACH
EACH
LS
LF
LF
EACH
LS
LS
LS
LS
jcrea
SY
LF
LS
LS
Unit
Price
S50.000
SI 2,500
$100
S25
15
$500
$600
$3.500
$20,000
$2
$7.50
$6,000
$23,000
$40,000
$40,000
$40,000
$1,200
$5
$25
$15,000
$15,000
Extended
Price
$50.000
$12,500
$21,000
$287,500
$57,500
$17,000
$20,400
$1 19,000
$60,000
$8.400
$31.500
$6,000
$25,000
$40.000
$40,000
$40,000
$744
$15,000
$7,500
$15.000
$132,000
S1.010.MO
ADDITIONAL CONSULTING SERVICES
Item Type of Work
1. CoMtruction Completion Report
2. Bid-Phaae AatiaUnce
3. Conmclioa Management
4. Engineering
TOTAL Extended Capital Construction Price
TOTAL Eilended Price
Eatinxed
Quantities
1
10% of Cap. Coat
10% of Cap. Coat
1 OS of Cap. Coal
Unit
LS
LS
LS
LS
Unit
Pi ICC
$50.000
$101,000
$101,000
$101.000
Total capital coal of SI, 363, 000 ia for the dual leachale and
Eitended
Price
$50,000
$101,000
$101,000
$101.000
S3S1,MO
$1,363,000
KU collection lyatcm. The additional co*t for the leachatr tvitcm
ia eojual to the coat of the dual extraction lyttem minus
the coal of the gaa collection lytUm
Sl.363.000 - $924,000 = $439.000
S435DMi
OAM Coat Eateate
Aaaumc QAM coata of $60.000 per year, baaed on previous experience.
rYcaenl worth of OAM = $60.000 , TV 30 yean) = $744,600
$60.000
Note:
LS = lump nun
LF = linear fool
SY = K)uare yard
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TABLE 20: LEACHATE TREATMENT SYSTEM COST ESTIMATE FOR THE SELECTED REMEDY
LTl - No Further Action: Pump, Transport, ft Dispose at Remote POTW
Assume the total cast of pumping leachatefrom the existing manholes and wells
is approximately equal to the-present worth of transport/discharge costs for 30 years.
Assume that the current extraction rate is 1 gpm and that the cost for transport
using a 5.000 gallon tanker truck and discharge to the POTW combined is SO. 09/gaUon.
Annual OAM Costa:
Annual O&M = ((1 gal/min) • (60 min/hr) * (24 hr/day) * (365 day/yr) • S0.09/gal) + 20% Contingency = $56,800
Additional annual operation cost for this option is approximately Si0,000
Annual O&M = $56,800 + SI 0,000 = $66,800
Calculate Present Worth of this option over 30 years
O&M P.W. (7%, 30 years) = S829.000|
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TABLE 21: GROUNDWATER MONITORING SYSTEM COST ESTIMATE FOR THE SELECTED REMEDY
GW-2 - Monitored Natural Attenuation
Capital Coyls
Replacement of VW4 with VW7
Pre-Design Investigation Monitoring Wells
Well Inst., 2 double cased wells»85 ft.*$125/ft =
Field Oversight, 10 days*10hr/day*592/hr =
Contract Mgt./Admin., 10 hrs * 92/hr =
O&M Costs
Quarterly Sampling: Assume sampling of 20 wells
Labor, 20 wells«(loV8 wells)*(8hr/d)«(S62/hr*2)*4/yr =
Travel Expenses, (5d • $40/d + $40)*4/yr =
Equipment/Supplies, assume 4*5700 =
Laboratory Analysis of Samples: Assume $550/well
$550Avell ' 20 wells • 4/yr =
Quarterly Reporting
Data Prep, (562/hr • 8hrs)*4 =
CAD/Admin, ($44/hr • 8hrs)*4 =
Report Writing/Data Interpretation (574/hr * 24)»4 =
QA/QC (S92/hr • 4hrs) *4 =
. Total Annual Cost
Totml Capital Com.
$9,920
$960
52,800
544,000
51,984
51,408
57,104
51,472
569,700
Present Worth (7%, 30yn) :
TOTAL::
Costs incurred to abandon and replace VW4
Well Abandonment Cost
Engineering/Consulting (574/hr * 40hrs + 592/hr'20hrs)=
CAD/Administrative Support (S54/hr*20h + S44/hr»20h) =
Bid-phase costs (Assume 57,500)
Mobilization/Demobiltzation/Labor (52,500 + 550/hr"2'50) =
Misc. matenaVsubconsulling costs (Assume 510,000)= .
Letter Report/Agency Communication (574/hr'20hr + 592/hr • 10 hr) =
SUBTOTAL1:IL
Assume a 15V. contingency factor :
SUBTOTAL2: i
Well Replacement Cost
based on actual costs
Property purchase
Well replacement
Additional field investigation assistance
Well production
Well hook-up (includes capital & commodity charges)
SUBTOTALS:
TOTAL:
5692,200
521,250
59,200
5920
5723,600
5865,000
51,588,6001
54,800
51,960
57,500
57,500
510,000
52,400
534,200,
i5,200
539,400 I
57,040
576,012
51,355
577,963
5490,356
5652,800
5692,200 j
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Table 22: Groundwater Cleanup Standards
620.410 Groundwater Quality Standards for Class I: Potabh Resource
Groundwater
a) Inorganic Chemical Constituents
Except due to natural causes or as provided in Section 620.450,
concentrations of the following chemical constituents must not be
exceeded in Class I groundwater:
Constituent
Units
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Chloride
Chromium
Cobalt
Copper
Cyanide
Fluoride
Iron
Lead
Maganese
Mercury
Nickel
Nitrate as N
Radium-226
Radium-228
Selenium
Silver
Sulfate
Thallium
Total Dissolved
Solids (TDS)
Zinc
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/l.
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
pCi/l
pCi/l
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Standard
0.006
0.05
2
0.004
2
0.005
200
0.1
1
0.65
0.2
4.0
5
0.0075
0.15
0.002
0.1 •
10
20
20
0.05
0.05
400
0.002
1,200
5
Iof3
-------
b) Organic Chemical Constituents
Except due to natural causes or as provided in Section 620.450 or
subsection (c), concentrations of the following organic chemical
constituents shall not be exceeded in Class I groundwater:
Constituent
Alachlor*
Aldicarb
Atrazine
Benzene*
Benzo(a)pyrene*
Carbofuran
Carbon Tetrachloride*
Chtordane*
Dalapon
Dichloromethane*
Di(2-ethylhexyl)phthalate*
Oinoseb
Endothall
Endrin
Ethylene Dibromide*
Heptachlor*
Heptachlor Epoxide*
Hexachlorocydopentadiene
Lindane (Gamma-Hexachlorocydohexane)
2.4-D
ortho-Oichlorobenzene
para-Dichlorobenzene
1,2-Dibromo-3-
Chloropropane*
1,2-Oichloroethane*
1.1-Dichloroethylene
cis-1,2-Dichloroethylene
trans-1,2-Dichloroethylene
1,2-Dichloropropane*
Ethylbenzene
Methoxychlor
Monochlorobenzene
Pentachlorophenol*
Phenols
Picloram
Polychlorinated
Biphenyls(PCB's)(as
decachloro-biphenyl)*
Simazine
Styrene
2,4.5-TP (Silvex)
Tetracrtloroethylene*
Toluene
Toxaphene*
1.1.1 -Trichloroethane
1,1,2-Trichloroethane
1,2.4-Trichlorobenzene
Trichloroethylene*
Vinyl Chloride*
Xylenes
•Denotes a carcinogen.
Standard (mo/lJ
0.002
0.003
0.003
0.005
0.0002
0.04
0.005
0.002
0.2
0.005
0.006
0.007
0.1
0.002
0.00005
0.0004
0.0002
0.05
0.0002
0.07
0.6
0.075
0.0002
0.005
0.007
0.07
0.1
0.005
0.7
0.04
0.1
0.001
0.1
0.5
0.0005
0.004
0.1
0.05
0.005
1
0.003
0.2
0.005
0.07
0.005
0.002
10
2 of 3
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c) Complex Organic Chemical Mixtures
Concentrations of the following chemical constituents of gasoline, diesel
fuel, or heating fuel must not be exceeded in Class I groundwater:
Constituent Standard fmq/Li
Benzene* 0.005
BETX 11.705
'Denotes a carcinogen.
d) pH: Except due to natural causes, a pH range of ^.5 - 9.0 units must not be
exceeded in Class I groundwater.
e) Beta Particle and Photon Radioactivity
1) Except due to natural causes, the average annual concentration of
beta particle and photon radioactivity from man-made
radionuclides shall not exceed a dose equivalent to the total body
organ greater than 4 mrem/year in Class I groundwater. If two
or more radionuclides are present, the sum of their dose
equivalent to the total body, or to any internal organ shall not
exceed 4 mrem/year in Class I groundwater except due to natural
causes.
2) Except for the radionuclides listed in subsection (e)(3), the
concentration of man-made radionuclides causing 4 mrem total
body or organ dose equivalent must be calculated on the basis of
a 2 liter per day drinking water intake using the 168-hour data in
accordance with the procedure set forth in NCRP Report Number
22, incorporated by reference at in Section 620.125(a).
3) Except due to natural causes, the average annual concentration
assumed to produce a total body or organ dose of 4 mrem/year of
the following chemical constituents shall not be exceeded in Class
I groundwater
Critical Standard
Constituent Organ (Pci/l)
Tritium Total body 20,000
Strontium-90 Bone marrow 8
(Source: Amended at 18 III. Reg. 14084, effective August 24,1994)
3 of 3
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APPENDIX A: RESPONSIVENESS SUMMARY
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SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
This Responsiveness Summary has been prepared to meet the requirements of Sections
113(k)(2)(B)(iv) and 117(b) of the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), which requires the United States Environmental
Protection Agency (US2PA) to respond "to each of the significant comments, criticisms, and
new data submitted in written or oral presentations" on a proposed plan for a remedial action.
The Responsiveness Summary covers concerns expressed by the public and potentially
responsible parties (PRP) in written and oral comments received by USEPA about the
proposed remedy for the H.O.D. Landfill Site.
A. Overview
1. Proposed Plan
The Final Remedial Investigation (RI) Report, which was prepared by Montgomery Watson (a
Waste Management of Illinois (WMII) contractor), was released to the public in May, 1997.
(WMII is one of the PRPs.) The Final Baseline Risk Assessment (BLRA), which was prepared
by ICF Kaiser Engineers, Inc. and the Weinberg Consulting Group (which are or were WMII
contractors), was released to the public in November, 1997. The Final Feasibility Study (FS),
which was prepared by Montgomery Watson, was released to the public in July, 1998. A Fact
Sheet summarizing the FS and Proposed Plan was released to the public in July, 1998, and was
mailed directly to the PRPs and to residents near the Site.
The Proposed Plan for the remedial action included the No Further Action alternative, and
capping, gas collection and treatment, leachate collection, leachate treatment, and groundwater
monitoring alternative components. The preferred alternative in the Proposed Plan called for
waste cap improvements, upgraded gas collection/treatment and leachate collection systems,
leachate treatment, groundwater monitored natural attenuation, and institutional controls.
2. Public Comment Period
The Administrative Record file for the Site was made available for review by the public at the
Antioch Public District Library in Antioch, and at USEPA Region 5 offices in Chicago, during
and before the public comment period. The public comment period ran from July 22 through
August 20, 1998.
An announcement regarding the public comment period and the public meeting was published
in the Daily Herald newspaper on July 22, 1998 and in the Antioch News Reporter newspaper
on July 24, 1998.
A public meeting was held in Antioch on August 11, 1998. At this meeting, attended by
H.O.D. Responsiveness Summary; September, 1998 1
-------
approximately 40 members of the public, representatives from USEPA summarized the
findings of the RI/FS and the Proposed Plan, described the remedy selection process, answered
questions from the public, and accepted statements from members of the public. Comments,
including formal statements from community members, were recorded by a court reporter, and
a transcript of the meeting is included in the Administrative Record.
A total of six written submittals was received from the public during the public comment
period. This included written comments from PRPs (WMn and the Village of Antioch).
Public comments recorded during the public meeting and a comment from the United States
Army Corps of Engineers are included in this Responsiveness Summary, but are not included
in the count of six written submittals from the public.
Responses to all of the above-mentioned comments are contained in this Responsiveness
Summary.
B. Community Involvement
Based on the assessments of the release of hazardous substances at the Site, the Site was
proposed for inclusion on USEPA's National Priorities List (NPL) for Superfund Sites in
1985, and was finalized on the NPL in February, 1990. A Community Relations Plan was
developed in 1993 to ensure that the public was well informed during the Superfund process. As
part of this process, residents near the landfill were interviewed to find out their concerns. The
main concerns were drinking water safety, property values, and being kept informed of future
Site events.
To respond to these concerns, USEPA produced a fact sheet and held public information
meetings in 1993. In April, 1993, USEPA issued a press release announcing the start of the RI
by WMII. In December, 1997, USEPA met with Village of Antioch officials in Antioch to
provide an update of Site-related activities and to discuss the Village's concerns.
C. Summary of Significant Comments
The public comments for the Site are organized into the following categories:
Comments from Christine Gustafson. Ms. Gustafson is a resident near the Site;
A summary of comments from the remainder of the local community on the
RI/FS, BLRA, Proposed Plan, and Superfund process;
A summary of comments from PRPs concerning the RI/FS, BLRA, and the
Proposed Plan; and
A comment from the United States Army Corps of Engineers.
H.O.D. Responsiveness Summary; September, 1998 2
-------
Some of the original comments have been paraphrased or combined to present a more readable
document. The reader is referred to the Administrative Record for the Site, located at the
Antioch Public District Library in Antioch and at the USEPA Region 5 Office in Chicago,
which contains copies of all written comments submitted. The Administrative Record also
contains a copy of the public meeting transcript. The Administrative Record Index is included
in Appendix B of this Record of Decision (ROD).
• Comments from the Community
Comments from Christine Gustafson
1. Ms. Gustafson requested information on the Cunningham and Quaker dump.
USEPA Response: The former Cunningham/Quaker Village Dump is located west of and
adjacent to the H.O.D. Lardfill. This property is not part of the H.O.D. Landfill, and is not
owned by WMII. Since the former Cunningham/Quaker Dump is not part of the H.O.D.
Landfill, the Cunningham/Quaker dump was not part of the investigative or decision-making
processes used by USEPA to arrive at the selected remedy for the H.O.D. Landfill.
Consequently, USEPA has no further information on the former Cunningham/Quaker Village
Dump.
2. What past or current businesses that were or are located in or near Antioch's Industrial
Park near the Site have had storage violations and have needed USEPA and/or Local
Emergency and Hazardous Materials personnel intervention and response?
USEPA Response: The USEPA does not consider this question pertinent to the discussion of
the planned remedial activities for the Site.
3. What is the chemistry of vinyl chloride and other volatile organic chemicals (VOC) as
they relate to the Site?
USEPA Response: The VOCs such as tetrachloroethylene (PCE), tetrachloroethane (PCA),
trichloroethane (TCA), trichloroethylene (TCE), and dichloroethylene (DCE) all may naturally
degrade to vinyl chloride, then to carbon dioxide and water. Degradation rates vary based on
different situations. For the vinyl chloride found in the groundwater of well US3D, USEPA
expects the concentrations to attenuate over time, based on the expected effectiveness of the
remedy to minimize further contaminant migration from the waste mass to the groundwater.
4. What types of geological surveys were used to show what geological conditions are
capable of attenuation and to show the location of the contaminant plume? What
individuals or agencies were involved?
USEPA Response: USEPA's premise that natural attenuation will occur in the groundwater is
H.O.D. Responsiveness Summary; September, 1998 3
-------
based on characteristics such as Site groundwater contaminants and concentrations, extent of
the contamination, and expected effectiveness of the remedy in reducing contaminant migration
into the groundwater. Based on groundwater monitoring results, a groundwater contaminant
plume has not been identified. (Contaminants, once entrained in saturated groundwater flow,
tend to form plumes of contaminated groundwater downgradient of the contaminant source
until they attenuate to a minimum quality level. This is analogous to smoke from a smokestack
as it drifts downwind in the atmosphere. This condition has not been found at the Site.) The
pre-design investigation, as part of the selected remedy, will further study the extent, if any, of
a groundwater contaminant plume. The USEPA had and continues to have overall Site
approval authority for investigative and remedial work, and has benefited from the services of
various agencies, contractors, and WMH to conduct such work.
5. Have free products in saturated soils and any leaking containers been removed?
USEPA Response: The USEPA's Superfund activities for the Site have not included any
removal activities.
6. Is there free product in or on the groundwater?
USEPA Response: No USEPA investigative studies have shown free product to be present in
or on the groundwater.
7. Is the (groundwater contaminant) plume increasing, decreasing, or stable? What
properties have been or will be affected by the plume? How long will the plume exist?
USEPA Response: No groundwater plume has yet been identified. The pre-design
investigation, as part of the selected remedy, will further study the extent, if any, of a
groundwater contaminant plume.
8. What municipal, and current and future private wells are or could be (contaminant)
receptors?
USEPA Response: The BLRA showed Uiat the drinking of vinyl chloride-contaminated water
posed the only significant health risk. No municipal or private wells sampled during the RI
showed vinyl chloride levels in the groundwater, and Village Well Four showed vinyl chloride
levels up to year 1989. This well has since been decommissioned. The USEPA does not
expect municipal or private wells to be adversely impacted by Site contamination.
9. What mechanism or mechanisms are controlling .plume size?
USEPA Response: A groundwater contaminant plume has not been identified. The pre-
design investigation, as part of the selected remedy, will further study the extent, if any, of a
groundwater contaminant plume.
H.O.D. Responsiveness Summary; September, 1998 4
-------
10. How will natural attenuation occur, and what is the monitoring plan?
USEPA Response: The selected remedy will minimize contaminant migration from the waste
mass into the groundwater. The existing vinyl chloride and other VOCs in the groundwater
are expected to attenuate over time as part of the natural degradation process. See response
number 3. The groundwater monitoring plan will be issued as part of the upcoming Remedial
Design (RD). For a general description of the GW2 groundwater monitoring component of the
selected remedy, see Section vn of this ROD.
11. What is the plan if the concentration and areal extent of the contaminant plume is not
maintained or reduced?
USEPA Response: Should a groundwater contaminant plume be found that cannot be
maintained or reduced, active groundwater remediation, such as a pump and treat system, will
be considered.
12. What other containment methods can be used besides (those included in the selected
remedy), such as a Waterloo Containment Barrier?
USEPA Response: Since USEPA followed its presumptive remedy guidance, USEPA did not
consider all containment remedies. The USEPA believes that the selected remedy components
of waste cap improvements, leachate and gas collection, leachate treatment, groundwater
monitored natural attenuation, and institutional controls will be sufficient to protect human
health and the environment.
13. What other reductive methods can be used for the contaminants detected in well US3D,
and in municipal and private wells (besides blending or diluting)?
USEPA Response: The USEPA included monitored, natural attenuation in its selected
remedy as a method of reducing VOC contaminant levels in the groundwater. Active
groundwater remediation will be considered if natural attenuation does not occur over time.
14. What is the extent of the contamination in the groundwater?
USEPA Response: Based on the results of the RI, groundwater contamination is limited.
Table 6 in this ROD summarizes the analytical results of the groundwater organic sampling
during the RI. (The BLRA showed that the only significant health risk was from the ingestion
of vinyl chloride-contaminated groundwater. This risk was associated with contaminant levels
from well US3D, near and southwest of the Site. Vinyl chloride is a VOC.) Wells with a
"D" designation indicate sampling from the deep sand and gravel aquifer, wells with an "I"
designation indicate sampling from the clay diamict, and wells with an "S" designation indicate
sampling from the surficial sand aquifer. The RI Report documented that poor hydraulic
communication exists between the surficial sand, and deep sand and gravel aquifers. Section V
H.O.D. Responsiveness Summary; September, 1998 5
-------
of this ROD also documents groundwater contamination levels found during the RI.
15. For exposure to VOCs while showering, aren't the risks to infants, children, elderly,
and the health-impaired significant, especially for private well systems that do not get
diluted or treated water?
USHPA Response: Thi results of the RI showed that VOCs were not detected above detection
limits for the private and village wells sampled. Based on this finding, the question is not
applicable to Site-related issues.
16. What types of special requirements are in effect from State, County, or local
governments for current and future private wells that may be affected by Site-related
contaminants? Who manages the programs, and how often are the private wells tested?
USEPA Response: Based on the results of the RI and BLRA, USEPA found that there are no
significant, Site-related risks for ingesting private well water. This conclusion is consistent
with recent Lake County Health Department analytical results from sampling private well
water.
The Lake County Health Department performs annual testing and analysis of Safe Drinking
Water Act inorganic and organic chemicals for selected private well owners near the Site in
unincorporated Lake County. The Village of Antioch does not have a monitoring program in
place for private wells.
The Lake County Health Department is expected to continue its private well monitoring
program.
The Village of Antioch also has ordinances in effect that prohibit installation of private wells
within Village limits.
17. Do sellers' or agents' disclosure requirements dictate that sellers or agents notify
potential property purchasers that there is a Superfund Site in Antioch? Is a disclosure
document required to be signed by the purchaser and filed with Lake County?
USEPA Response: The USEPA is not aware of local disclosure requirements. The USEPA
recommends that the local governments such as Lake County or the Village of Antioch be
contacted for such information.
18. When organic compounds are mixed with chlorinated compounds, don't they make new
chlorinated hydrocarbons?
USEPA Response: The USEPA cannot respond to this general question without more
information, such as the specific types of organic and chlorinated compounds under
H.O.D. Responsiveness Summary; September, 1998 6
-------
consideration.
19. Doesn't the Antioch water treatment plant use chlorination, and can ozonation or
ultraviolet treatment be used instead?
USEPA Response: The USEPA recommends that the Village of Antioch or the Illinois
Environmental Protection Agency (IEPA) be contacted to determine what water treatment
methods are used by the Village of Antioch. The USEPA has delegated responsibility for
direct oversight of Illinois public water suppliers, such as the Village of Antioch, to IEPA.
Since the Village of Antioch is currently in compliance with the IEPA drinking water program,
and there is no evidence of contamination of drinking water from the Site, the use of alternate
water treatment methods is not an issue at this time.
20. What treatment methods can private well owners use to reduce contaminant
concentrations in the water to safe levels? Will private well owners be provided with
home treatment systems? If so, who will provide and pay tor the systems? Who will
be required to test and maintain the efficiency of the systems?
USEPA Response: Based on the results of the RI and BLRA, USEPA found that there are no
significant, Site-related risks from ingesting private well water. Therefore, USEPA has no plan
to recommend or provide home treatment systems for private well owners to reduce Site-
related contaminant concentrations.
21. What type of program is being implemented to educate children to the dangers of the
Site and to the fluoranthane detected above guidance levels in Sequoit Creek sediments?
USEPA Response: The USEPA has not implemented any specific program to explain the
dangers of the Site to children. It should be noted that the only danger above risk-based
guidance levels identified in the BLRA is through the ingestion of vinyl chloride-contaminated
drinking water. This was a result of readings from monitoring well US3D, which is prohibited
for drinking water use. The BLRA quantified risk levels associated with dermal contact of
Sequoit Creek surface water to be well below the 1 X 104 carcinogenic level used by USEPA
to determine whether remedial action generally is warranted. Furthermore, the contaminant
levels for fluoranthene estimated during RI sediment sampling were below detection limits.
Site access controls will be enhanced to prevent children from trespassing on-site. These
controls include fencing with barbed wire, warning signs, and gates with locks. Since most of
Sequoit Creek is beyond the Site borders, and since contaminant levels of Sequoit Creek were
found during the RI to be low, no Site-related access restrictions will exist for Sequoit Creek
beyond those imposed at Site boundaries.
22. Is the Wetlands Restoration and Pathway Project a part of the cleanup actions? What
H.O.D. Responsiveness Summary; September, 1998 7
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agency and people are doing the project?
USEPA Response: This project is not part of the remedial action. For more information on
this project, please call USEPA Region 5's Watershed and Non-point Source Programs Branch
at 312-353-2308.
23. What will be done to prevent accidental trespass of 6 to 16-year old children to Sequoit
Creek and its sediments, as well as to the Site?
USEPA Response: Please see the response to comment number 21.
24. Access to the Site from Depot Street, which is north of the Site and runs east and west,
is not blocked. How and when will this access be blocked?
USEPA Response: Specifics of the "site access restrictions'* component of the selected
remedy will be evaluated by USEPA during the RD. All access to the Site will be prohibited
by the public until cleanup levels are reached, at the earliest.
25. What contaminants are in Little Silver Lake and its sediments? What are the
contaminant levels, and where are the contaminants located?
USEPA Response: Little Silver Lake was not within the geographical boundaries included in
Superfund Site investigations; therefore, USEPA cannot respond to this question.
26. What is wrong with the surface water body that is west of Deeplake Road and south of
Depot Street?
USEPA Response: This surface water body was not within the geographical boundaries
included in Superfund Site investigations; therefore, USEPA cannot respond to this question.
27. Why was no radiation detected at the Site? Doesn't waste in the landfill emit iodizing
radiation as the waste decays? Who tested the landfill for radiation, and what method
and instruments were used?
USEPA Response: In 1987, Ecology and Environment, a USEPA contractor, tested the Site
for radiation, and found that radiation levels at the Site were not above background levels.
The contractor used a miniature radiation detector, known as a "rad-mini."
28. Why aren't the photos taken of the stressed vegetation and surface seeps on the landfill
a part of the information repository at the Antioch Public District Library? Why aren't
the photos of the standing water with apparent, stressed vegetation a part of the
information repository at the Antioch Public District Library? Where are these photos,
and who has them?
H.O.D. Responsiveness Summary; September, 1998 8
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USEPA Response: Any photographs taken that were part of the USEPA-authorized Site
investigations should be part of the information repository. If the photographs are part of the
USEPA-authorized Site investigations and are missing from the information repository,
USEPA will attempt to locate the photographs and send copies to the information repository.
29. What intolerant species were found and identified during the biological assessment of
the landfill? What Standard of Methods was used, and by whom? What other Natural
Areas had biological assessments off-site, by whom, and what Standard of Methods
were used, and when did the assessments occur?
USEPA Response: Chapter six of the August 31, 1994 BLRA (approved with addenda by
USEPA in October, 1997) documents the ecological risk assessment for the Site. This
assessment describes the methods used and species identified. Please refer to the ecological
risk assessment of the BLRA for the requested information. The BLRA is found in the
information repository at the Antioch Public District Library.
The ecological risk assessment covered Site-related concerns. The USEPA does not consider
the discussion of other off-site, biological assessments to be relevant to the selected remedy for
the Site.
30. When was the notice of the public comment period published, and in.what newspapers?
Did the notice contain information on where comments should be sent and by when?
Were television stations or radio stations notified?
USEPA Response: An advertisement was published in the Daily Herald newspaper on July
22, 1998 and in the Antioch News Reporter newspaper on July 24, 1998, announcing that
USEPA issued the Proposed Plan for the Site, and that the Proposed Plan was available in the
information repository. The advertisement announced the date, time, and location of the
public meeting. The advertisement also documented the time period for USEPA to accept
written comments, and where the comments should be sent. Television stations and radio
stations were not directly notified.
Comments from Other Private Citizens
31. An employee of the Antioch Community High School District 117 sent a written
comment to USEPA that described the implementation of a system where the gas
generated from a landfill was piped to a school and converted to heating fuel for the
school. The writer asked that USEPA give such a system consideration to potentially
supply landfill gas from the Site to the Antioch Community High School, where the gas
would be converted to heating fuel.
USEPA Response: The USEPA appreciates the community's interest in remediation
technologies. The USEPA will discuss this proposal with WMII and/or with any contractors
H.O.D. Responsiveness Summary; September, 1998 9
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involved in the RD.
The USEPA cautions the commenter that the proposed system is not without concerns, one of
which is the safety of boiler emissions from the school.
32. A commenter was concerned about the amount of heavy metals, such as arsenic,
beryllium, and thallium in the landfill, and wanted the concentrations of heavy metals to
be monitored. He was also concerned that inorganic arsenic compounds, such as lead
arsenate, can be converted into organic arsenic compounds that should also be
monitored.
USEPA Response: The BLRA identified no significant risk associated with Site-related,
heavy metals, including lead and arsenic. However, the groundwater monitoring component of
USEPA's selected remedy includes monitoring for heavy metals. The list of contaminants to
be monitored in the groundwater will likely not include lead arsenate, because the BLRA did
not identify this compound as posing a significant risk, and because this compound is not
included in the list of contaminants in the Illinois Groundwater Quality Standards.
33. The same commenter felt that, based on all the contaminants found on-site, the
groundwater monitoring frequency in the selected remedy should be no less frequent
than quarterly.
USEPA Response: The applicable or relevant and appropriate requirement (ARAR) for the
groundwater monitoring program is 35 Illinois Administrative Code (IAC) 811.319. This
states that the monitoring frequency will be quarterly, except for organic chemicals, where the
monitoring frequency will be annual. However, this ARAR allows for less or more frequent
monitoring than quarterly, based on contaminant conditions. The USEPA's selected remedy
calls for quarterly monitoring until the USEPA Five Year Review occurs, at which time
USEPA will evaluate monitoring data to determine appropriate monitoring frequencies for the
next time period in question.
34. The same commenter questioned how the Site would ever be delisted from the NPL,
based on the contaminant level of heavy metals on-site.
USEPA Response: According to section 300.425 of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), the following criteria must be met before a site
is deleted from the NPL:
a. PRPs or other persons have completed all response actions required,
b. The State must concur on the proposed deletion,
c. All appropriate Superfund-financed responses are complete, and no further response
H.O.D. Responsiveness Summary; September, 1998 10
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from PRPs is appropriate, and
d. The Site poses no significant threat to public health or the environment, and taking
remedial measures is not appropriate.
The USEPA will consider these four criteria before delisting the Site. If, after deletion from
the NPL, a release from the Site merits further remedial response, the Site may be restored to
the NPL. The USEPA does not anticipate the Site being delisted in the near future.
35. All chemicals, not only vinyl chloride, should be considered before deciding what type
of remedial action is required.
USEPA Response: The USEPA used proper screening methods to develop Site contaminants
of concern. Therefore, mLny contaminants were evaluated during the investigative process.
According to the BLRA, crly vinyl chloride posed a significant risk to human health. The
components of the selected remedy will reduce contaminant concentrations of many Site
contaminants including vinyl chloride.
36. A commenter challenged the claim by USEPA that groundwater flow at and near the
Site is southwesterly. He asked if the groundwater flow direction could be restudied.
USEPA Response: The USEPA's understanding of a southwesterly groundwater flow
direction is based on the results of the RI. It is possible that groundwater flow direction has
changed since the RI. However, should USEPA obtain information to show that groundwater
flow direction is other than southwesterly, this information will not fundamentally change
USEPA's selected remedy for the Site. The USEPA will consider groundwater flow direction
before approving the groundwater monitoring plan, which is part of the RD. The groundwater
monitoring plan will cover groundwater monitoring locations.
37. A commenter was concerned about the vinyl chloride in the groundwater, and its effect
on local ground water supplies. Money should be set aside for monthly testing of
VOCs and synthetic organic chemicals (SOC) for each of the village wells, and the
results should be published in the local newspapers. Currently, the Village is not
required to test the (village wells) for VOCs and SOCs other than the annual State
requirement. Because of the present situation, it is extremely important that the
Antioch residents be assured of safe water.
In demonstrating its commitment to public health protection and the public's right to
know about local environmental information, USEPA is requiring water suppliers to
put annual drinking water quality reports into the hands of their customers. These
consumer confidence reports will enable Americans to make practical, knowledgeable
decisions about their health and their drinking water. The reporting of monthly testing
will surely convey public confidence in the USEPA.
H.O.D. Responsiveness Summary; September, 1998 11
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USEPA Response: The Village of Antioch has been monitoring for organic and inorganic
chemicals in its village wells, in accordance with the IEPA requirements for community water
systems. Currently, the Village has an IEPA waiver in effect for most VOCs and SOCs, to
monitor every three years. The exception is the newly installed Village Well Seven, which is
monitored quarterly for VOCs and SOCs, and annually for inorganic compounds. The IEPA
reviews the results of the Village's monitoring, and will alert USEPA if IEPA feels that the
Village's public water supply is adversely affected by Site contamination. Also, results of the
RI showed that no village wells monitored as part of the RI had organic contaminant levels
above detection levels. At this time, USEPA does not believe that monthly monitoring for
organic chemicals is warranted.
Should USEPA find (through IEPA or otherwise) that Site contamination is adversely affecting
Antioch's public water suprty, USEPA will work with IEPA and the Village of Antioch to take
corrective action.
o
The Village of Antioch noted during the public meeting that groundwater analytical results are
available on request from the Village.
38. An employee of the Antioch Township stated he had environmental concerns.about
Sequoit Creek Channel by Pedersen Marina, and wanted the soil to.be tested where the
channel empties into the Chain-O-Lakes, to determine if runoff could be harmful to the
environment.
USEPA Response: The BLRA showed that soil, surface water, and sediment-related exposure
pathways resulted in no significant health risks. The surface water and sediment pathways
were those from Sequoit Creek. Should USEPA become aware of credible findings to the
contrary, it will take appropriate action and will inform the community of this action.
Comments from PRPs
Comments from Waste Management of Illinois,. Inc. (WMID
39. The BLRA quantified the current or potential future threats to human health and the
environment that may be posed by chemicals originating at or identified in the vicinity of
the Site. The BLRA used data and information obtained during the RI. The BLRA was
prepared according to Agency guidance. That methodology significantly overestimates
the actual risks associated with the Site for the following reasons:
a. The potential risks within each identified pathway scenario were calculated using
reasonable maximum exposure (RME) protocols only. As indicated, the derived risks
represent maximum values. This evaluation, instead of the most likely exposure (MLE)
protocol, produces very conservative estimates of risk. Many risk assessments use both
H.O.D. Responsiveness Summary; September, 1998 12
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protocols to establish a range of risks. It is likely that if MLE risk estimates were used,
the results of the BLRA would indicate that the quantified risks fall below the Agency's
action level(s).
b. Only the hypothetical future use of vinyl chloride-impacted groundwater from the
off-site deep sand and gravel aquifer exceeded the established cancer risk guideline (1 x
10"4) used to determine if corrective action is warranted. The total calculated cumulative
RME risk associated with vinyl chloride was 9x10"*. A Village of Antioch ordinance
requires properties within the Village liiuits to connect to the municipal water supply
system. Reportedly, the municipal water system currently provides clean water to its
users. Vinyl chloride was detected in only one off-site monitoring well, US3D, which is
downgradient of the Site, in the industrial park.
c. The RME risk attributable to vinyl chloride was calculated using the maximum
detection found in the off-site deep sand and gravel aquifer (at US3D), during sampling
in March, 1994. The concentration detected at that time was 35 micrograms per liter.
The highest off-site concentration of vinyl chloride detected during subsequent sampling,
in March 1998, was 15 micrograms per liter. Therefore, the risks attributable to vinyl
chloride in the BLRA are overstated based on current conditions. The 50% reduction in
the maximum vinyl chloride concentration would result in an RME risk within USEPA's
range of acceptability.
d. Hazardous constituents migrating from the landfill mass must first discharge to the
surficial sand aquifer and then intersect Sequoit Creek. The two most likely primary off-
site receptors, the surficial sand aquifer and Sequoit Creek, fail to exhibit impacts from
vinyl chloride and as such, do not pose unacceptable risks. The RI data indicate that these
two most sensitive receptors have not been significantly impacted. Consequently, it is
reasonable to assume that the downgradient impacts from vinyl chloride in the deep sand
and gravel aquifer do not represent an ongoing release from the Site.
e. Monitoring Well W3D, which is also downgradient of the landfill, but sidegradient
of the industrial park and only 600 feet from US3D, did not exhibit concentrations of
vinyl chloride above MCLs. Therefore, the extent of vinyl chloride in the deep sand and
gravel aquifer is limited.
f. The BLRA assumes that the H.O.D. Landfill is the source of the concentrations
present in US3D. This assumption may not be true. If these concentrations are due to the
other documented possible sources of contamination (the industrial park or the fill areas
located west of the H.O.D. Site), then the calculated risks may not have anything to do
with the H.O.D. Landfill.
H.O.D. Responsiveness Summary; September, 1998 13
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USEPA Response:
a. For the BLRA, USEPA quantified risk based on accepted USEPA policy. This policy
states: "In the Superfund program, the exposure assessment involves developing reasonable
maximum estimates of exposure for both current land use conditions and potential, future land
use conditions at each site" (55 Federal Register 8710 (March 8,1990)). The USEPA agrees that
using RME protocol results in conservative estimates of risk.
b. The BLRA does not consider the number of residents that may be exposed to a drinking
water pathway, but whether such a pathway exists. The BLRA does not consider the
effectiveness of the public water supplier to provide safe drinking water. Also, although most of
the area residents are connected to the Antioch public water supply, there are still area residents
using private wells. USEPA guidance states that if a ground water MCL is exceeded (as in this
case), remedial action generally is warranted. The NCP requires remedial action to attain MCLs
in groundwaters or surface waters that are current or potential sources of drinking water (40 CFR
§300.430).
c. The BLRA is developed from the results of the RI; therefore, by definition, USEPA does
not revise and reissue the BLRA based on more recent, analytical results. The RI occurred in the
early 1990s. The USEPA agrees that vinyl chloride contaminant levels for well US3D are now
lower than during the RI.
d. The issue of whether the vinyl chloride contamination is Site-related or whether the vinyl
chloride contamination represents an ongoing release from the Site has not been conclusively
resolved. Since the contaminant location is nearby and downgradient of the Site, USEPA
believes the contamination is likely Site-related.
e. The extent of the vinyl chloride contamination in the deep sand and gravel aquifer is not
entirely known at this point; therefore, USEPA included as part of the selected remedy a pre-
design investigation to further study the extent, if any, of a groundwater, contaminant plume.
f. Please see response "d" above. Although industrial operations and land disposal of waste
are possible sources of contamination, there is no evidence showing any specific source of vinyl
chloride located in the industrial park or fill areas.
40. The Deep Groundwater Technical Memorandum presents the logic for not implementing
an active deep groundwater remedy associated with the Site. It is critical that this
document be entered in the Administrative Record, to be used as a resource during the
pre-design investigation of the deep groundwater and establishment of the groundwater
monitoring network. As described therein, and for the following reasons, active
groundwater remediation is not necessary at the H.O.D. Landfill Site:
H.O.D. Responsiveness Summary; September, 1998 14
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The source of vinyl chloride in the deep sand and gravel aquifer is uncertain and is
unlikely to be identified. Potential nearby sources include the H.O.D. Landfill, the
adjoining industrial park, or former waste dump areas to the west of the Site.
The limited distribution and existing concentrations of vinyl chloride in the deep sand and
gravel aquifer do not represent a current or future risk to VW3, the nearest point of
human exposure.
A suitable long-term monitoring program, particularly at US3D, should give adequate
warning of a potential change in conditions that could impact VW3.
Implementation of source control measures that include capping and leachate and landfill
gas control will reduce the amount of contaminants that may potentially enter
groundwater from the H.O.D. landfill.
USEPA Response:
The USEPA has included the Deep Groundwater Technical Memorandum in the Administrative
Record, as a comment on remedial options previously submitted by WMII.
The USEPA agrees that, based on current information, active groundwater remediation is not
necessary. This ROD includes the following wording under Section IX (The Selected Remedy):
"Should significantly more groundwater contamination be found during the pre-design
investigation, should the VOCs in the groundwater be found to be migrating, or should the
remedial actions taken not cause a decrease over time in the groundwater contaminant levels,
then an active, groundwater remediation alternative will be considered as part of the remedial
action for the Site."
41. The proposed pre-design studies for the deep sand and gravel aquifer, as described in the
FS and discussed with USEPA, should be limited due to the factors identified in the RI/FS.
Due to the other potential sources in the area, the installation of additional wells should be
limited, with locations near (within approximately 300 feet of) US3D, downgradient of the
Site. It is doubtful that the additional wells will determine the source of the contamination,
and therefore, the pre-design studies will be of limited usefulness. However, the limited
pre-design studies will help confirm the effectiveness of natural attenuation processes
within the deep sand and gravel aquifer.
USEPA Response: The pre-design investigation will be limited, as described in Section VII
(Description of Alternatives, alternative GW2) of this ROD.
42. The 7% discount rate used in the FS does not reflect current economic conditions. This
discount rate is based on a June 25, 1993 USEPA OSWER Directive (No. 9355.3-20).
However, this OSWER directive is over five years old and does not reflect currently
H.O.D. Responsiveness Summary; September, 1998 15
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available rates. The solid waste industry has been using a discount rate of 3% as an
appropriate rate to forecast future costs and, in fact, a lower discount factor (4%) has
recently been used by USEPA at other Superfund Sites. Therefore, we believe a more
realistic indication of the potential project remedial costs are reflected in the 3% cost tables
included in Appendix D of the Final FS. It is important to note that the true cost of ihe
proposed remedial action will be, in fact, higher given the lower prevailing discount rate.
USEPA Response: The USEPA OSWER Directive mentioned is still the current guidance for
the discount rate to be used for Superfund cost estimates. For comparison purposes, the seven
percent discount rate should be used for all Superfund cost estimates.
43. USEPA should clarify that the leachate from the Site can be managed at any POTW,
where the quantity and quality of the leachate meets the criteria identified in local
codes/ordinances. While the leachate from the Site is currently managed through the Fox
River Water Reclamation District (FRWRD) POTW, there is no reason why the leachate
could not be discharged to the Village of Antioch POTW, or another POTW, if it meets
that POTW's current criteria.
USEPA Response: USEPA has made the requested clarification in this ROD that a POTW
other than FRWRD may be used. It should be noted that in comment number 51 from the
Village of Antioch in this Responsiveness Summary, the Village questions the capability of its
POTW to accept the increased leachate volume for treatment.
Comments from the Village of Antioch
44. First of all, the Village wishes to emphasize the importance of the interconnection of all
the USEPA (selected remedy components) and their full implementation. The selection
of the lesser 807 cap, rather the 811 cap which would presently be required for a landfill,
is acceptable only in conjunction with the proposed active nature of the withdrawal of
leachate and landfill gas. With regard to the selection of an "807" rather than an "811"
cap for the Site, the ARAR which specifies an 807 cap as suitable for this Site basically
allows older landfills a lesser degree of protection than landfills presently being sited in
Illinois. Such an ARAR is merely meant to designate a minimum and not prohibit a
better remedy. However, if all the measures selected are fully implemented, the Village
accepts the premise that the lesser cap becomes acceptable because the risk is reduced as
active extraction reduces the mass of contaminants.
USEPA Response: The waste cap improvements of the selected remedy of this ROD are
considered in conjunction with the gas collection and leachate collection active, dual extraction
system.
45. The portions of the RI/FS which indicate the possibility that pre-design studies may later
indicate that the active remedies selected are not necessary or that lesser measures may in
H.O.D. Responsiveness Summary; September, 1998 16
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some way be considered are very disturbing. The Village residents need to assured that
measures are being taken to control the landfill, not that controls might be abandoned and
the goals shifted from one of active prevention of possible contamination of the aquifer to
a reactive response if contamination occurs. It is impossible to make a meaningful
comment to vague comments about pre-design studies without knowing the precise
nature of those studies. The Village suggests that if any changes are proposed in the
recommended measures as a result of "pre-design studies" that reduce in any manner the
level of remediation, protection, or prevention, a renewed period for public comment
must somehow be given in fairness to the Village residents who drink the water from the
aquifer which underlies the landfill.
USEPA Response: The pre-design/pilot studies referenced in this ROD are for the active, dual
extraction system component of the selected remedy. The USEPA will thoroughly review any
such studies before considering a less than fully active, dual extraction system. Since the studies
and the possibility of going to a less than fully active, dual extraction system are allowed for in
this ROD, implementation of a less than fully active system would not constitute a fundamental
change to the selected remedy, and would not usually warrant a renewed, public comment period.
A fundamental change to the selected remedy of the ROD would necessitate a ROD Amendment,
along with another public comment period and public meeting.
46. Part of our problem today stems from the failure of the landfill operator to install and
fully use the landfill perimeter leachate collection system initially proposed and required
as part of its IEPA permit requirements in 1974. A copy of that abandoned early total
perimeter system with piezometers located every 500 feet is attached as Reference One.
While the IEPA refused an operator request to abandon the system in 1976, IEPA Site
inspections in 1978 showed it had been abandoned anyway; the IEPA then acquiesced to
the abandonment and modified the permit rather than pursuing the notice of violation. In
fairness to all, it should perhaps be stated that the operator claimed difficulties in
construction of the perimeter system and creation of odors as among the reasons for
abandonment. For whatever reason, we have a Site which lacks even a perimeter leachate
collection system.
USEPA Response: The USEPA is well aware of the inadequacies of the current leachate
collection system. The leachate collection component of the selected remedy is a substantial
upgrade to the current system.
47. Page 1-5 of the FS notes the clay-rich diamict beneath the entire Site. It should be noted
that an extensive sand lens or lenses were encountered in the construction of this landfill
requiring the reshaping of the "new" landfill and the construction of man-made partial
side and bottom seals along a portion of the southern border of the "new" Site, according
to IEPA records of inspections and permits. IEPA approval of the Site as a suitable
location, noted at page 1-6, took place in 1975, almost 25 years ago when the regulation
and monitoring of landfills was just beginning in Illinois. Borings taken on and off-site
H.O.D. Responsiveness Summary; September, 1998 17
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indicate some sand is present in the clay. Therefore, any use cf the adjacent property as a
soil-borrow pit should be carefully scrutinized.
USEPA Response: The USEPA will take this information into consideration before approving
any potential borrow-pit materials.
48. It should also be noted that at Page 1-7 of the Feasibility Study, it is stated that a small
portion of the landfill Site'is currently owned by the Village of Antioch. Actually, the
Village took title to about half of the Site by donation from WMH in 1974 subject to a 20-
year reservation for use as a landfill. That ownership should support the Village's and its
consultant's request that the Village be given copies of the quarterly cap monitoring data
and other monitoring data as well, as it accrues. It is difficult to examine and adequately
respond in 30 days to studies which have taken five years to prepare.
USEPA Response: The USEPA revised the wording in this ROD to note that the Village owns
"a portion," not "a small portion" of the Site. Since it is not known at this time which entities
will be performing the RD/RA, it is premature to discuss the distribution of remedial reports.
Should one or more PRPs perform the RD/RA, the PRP(s) performing the RD/RA may work
with other PRPs to develop a PRP distribution list for remedial reports. Should USEPA or one
or more of its contractors perform the RD/RA, USEPA will discuss the distribution of remedial
reports with interested PRPs.
49. The Village wishes to note what it believes is an error in Table 4-1 showing vinyl
chloride found the Village Well No. 4 (VW4), which is the Village well closest to the
landfill and no longer part of the public drinking water supply system. The Village has
no record of vinyl chloride having been found in VW4 at the level of 6.7 ppb in 1984.
We do show, however, that vinyl chloride was discovered at that 6.7 level in the sampling
taken January 13,1989, when all the Village wells were tested for certain organics
pursuant to a new state law. This is the discovery that triggered the Emergency Response
from the USEPA in 1989.
USEPA Response: The USEPA notes this additional information; however, the information
does not affect the selected remedy.
50. At Page 1-3 of the Feasibility Study it is noted that based upon 1993 records,
approximately 450,000 gallons of leachate are removed from the Site yearly. According
to WMII reports submitted to the IEPA, in the first three quarters of 1997, only 38,000
gallons of leachate were moved. In the fourth quarter an additional 25,000 gallons was
removed for a total collection and removal of only 63,000 gallons from the Site for the
year 1997. Reference Two. Evidently, the larger gallonage removal figures cited in the
RI/FS of 35,000 gallons per month are based on what was done in 1993.
USEPA Response: The USEPA notes this additional information; however, the information
H.O.D. Responsiveness Summary; September, 1998 18
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does not affect the selected remedy. If the WMII estimates in the Feasibility Study (FS) for
current leachate removal rates are overstated, it becomes more important to include the active,
dual collection system in the selected remedy as USEPA has done.
51. It appears that leachate has been allowed to accumulate, and a great deal of treatment
capacity will have to be located. Candor requires us at this point to state that the Village
. POTW would not be able to participate as an alternative POTW in this remedy due to our
small size, construction, location, history of problems and restrictions, and lack of
adequate monitoring for a leachate waste stream whose characteristics we believe may
vary from the leachate profile presently postulated once active extraction becomes a
reality. (Our capacity is 1.6 MOD while the Fox River Water Reclamation District's
average day flow is 12 MOD.) No mention of such possible use of our POTW was made
in the August 11,1998, public presentation by the USEPA, perhaps because of awareness
of our POTW size and prior problems, but the operator has raised the issue with us. (The
possible use of other POTWs is mentioned at Page 3-19 of the FS and at page 4 of the
June 3, 1998, WMII Responses to the May 20,1998, USEPA Comments.)
USEPA Response: If a POTW other than the Fox River Water Reclamation District is used for
leachate treatment, the alternate POTW must be a viable candidate for accepting the leachate, and
the leachate transporter must satisfy the permitting requirements of the alternate POTW.
52. With regard to Page 3-3 of the FS, Section 3.2.1 No Further Action Alternative, the
Village comments that no real coherent leachate collection system is in place and that the
total amount of leachate removed for the year in 1997 according to reports to the IEPA
was 63,000 gallons for the entire year, not 6,000 to 8,000 gallons per week. Since the
leachate is not really being extracted, it raises the consideration of where the infiltration
which the present state of the landfill cap presently allows into the Site is going.
USEPA Response: The USEPA is aware of the inadequacies of the current leachate collection
system. The inadequacy of the current waste cover is allowing substantial infiltration, such that
much leachate is being generated. Some of this leachate is migrating to the groundwater. The
USEPA will expeditiously pursue implementation of the selected remedy to minimize leachate
generation and migration.
The USEPA will note in this ROD the 63,000 gallons removed in 1997. WMII of Illinois claims
that this was an abnormally low yearly rate, and that the 1998 rate is closer to 1,000 gallons per
week.
53. At Appendix D, Page 17 of the FS, the statement is made that "Historically leachate
elevations have remained fairly constant; therefore assume the average leachate elevation
as of 4/94 is still representative." The Village comments that historically there has never
been a consistent, continual leachate extraction from the Site sufficient to counteract the
effect of infiltration, yet alone the millions of gallons of liquid specials wastes that were
H.O.D. Responsiveness Summary; September, 1998 19
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deposited. One is left to ponder where that logically increasing volume of leachate is, if
not still on the Site. In actuality, the December 19,1997, leachate level readings from the
fourteen on-site piezometers used in the Appendix calculations indicate an average
leachate elevation of 768.95 feet ((766.96 + 767.90 + 765.37 + 771.92 + 770.21 + 783.13
+ 780.47 + 760.94 + 764.96 + 765.90 + 771.49 + 764.81 +766.22 + 764.97) divided by
14 sampling points). The level in monitoring well Gl ID was 760.18 feet, indicating a
permit level for leachate of 758.18 feet. These levels show an increase in the average
leachate level of 1.89 feet over 51 acres, a substantial increase for the active leachate
extraction system to remove. As part of the pre-design studies for the RD, one might
consider subtracting the amount of actual leachate amounts withdrawn from 1994 through
1998, calculating the assumed infiltration, and reviewing the actual leachate levels to
examine the validity of assumptions regarding the present landfill cap or conversely the
possibility of off-site migration of the leachate.
USEPA Response: The USEPA notes the additional information on leachate volumes; however,
this information does not affect the selected remedy. The USEPA is aware of the inadequacy of
the current waste cover (allowing excessive infiltration and leachate generation) and of the
inadequacies of the current leachate collection system (allowing excessive leachate mass in the
landfill). The selected remedy includes a substantial upgrade to the current leachate collection
system. If the expected leachate removal requirements have been underestimated in the FS, it
becomes more important to implement the active leachate collection system described in the
selected remedy. During RD review, USEPA will review the capabilities of the active leachate
collection system to remove sufficient volumes of leachate and to minimize leachate migration.
54. This is a landfill that accepted millions of gallons of liquid industrial wastes under the
State of Illinois special wastes system in the late seventies-early eighties. This system
allowed liquid wastes with certain minimal concentrations of contaminants today
considered hazardous to be placed in solid waste landfills and mixed with "regular"
garbage. These special waste streams were generally not even tested for the presence of
some of the present contaminants of concern at this Site, like vinyl chloride and 1,2
dichloroethylene. Today, of course, such liquids, any liquids, are not permitted into solid
waste landfills. Even then for good Site management, it was believed that one needed to
maintain a certain daily solid-to-liquid ratio, something which did not always happen at
our Site, based upon an analysis of the IEPA manifests of the special waste streams
permitted and accepted by the Site during the late 1970s and early 1980s. Thus, the
Village believes that the leachate on-site may be far less uniform that assumed for typical
municipal landfills and computer-modeling programs thereof which recognize and
account for the addition of small amounts of hazardous household wastes.
USEPA Response: The USEPA thoroughly studied leachate characteristics during the RJ. The
USEPA believes that the leachate collection component of the selected remedy will sufficiently
reduce the leachate mass in the landfill and significantly reduce leachate migration to the
groundwater.
H.O.D. Responsiveness Summary; September, 1998 20
-------
55. With regard to Page 1-20 and the BLRA statement that VW4 has been taken offline, it is
important to note that the nearby major Village Wells Three and Five are screened in the
same aquifer. Present water distribution problems with regard to the new Village Well
Seven are causing increased use of these wells. We have not as yet been able to fully use
the new well to replace Well No. 4 and as a result, both of the remaining wells in this
aquifer are working overtime and being heavily used. These wells are major workhorses
for the Village and we cannot overemphasize the importance of protection of that aquifer
for Village residents.
USEPA Response: The USEPA is aware of the proximity of Village Wells Three and Five to
the area of contaminated groundwater. The main purpose of the selected remedy to protect
human health and the environment is for the protection of groundwater for human consumption.
56. The RI/FS indicates that the leachate levels are substantially above those allowed in the
IEPA permit. Such conditions also prevailed in 1989 prior to the finding of vinyl chloride
in Well. No. 4. In the course of litigation with the Village regarding the landfill, WMII
pointed out that Well No. 4 had been used more heavily than normal in the months that
preceded the 1989 sampling done pursuant to a new State law. As previously stated, we
are presently having to use both Wells Three and Five more than normal due to the
integration and distribution problems of the new well No. Seven. Therefore, it would
seem wise to increase the withdrawal of leachate from the available point withdrawals to
reduce the buildup of leachate and any pressure toward off-site or downward movement
of the contaminants during any pre-design phase or other delays. The present RI/FS
reported rate of withdrawal of 35,000 gallons per month has not kept up with the present
presumed infiltration and the IEPA permit requirement for the Site regarding the leachate
levels which are two feet below the level in Gl ID. Further, as reported to IEPA, the
volume of leachate actually extracted and removed from the Site for 1997 was 63,000
gallons for the year, not per month. Reference Number Two. Given the reliance on
Village Wells Three and Five, the Village comments that leachate withdrawal should be
on-going during the pre-design studies at a much greater rate.
USEPA Response: Due to the unacceptable infiltration rate and leachate volume being
generated, USEPA will expeditiously pursue implementation of the selected remedy, which
includes an upgraded leachate collection system.
The USEPA will note in this ROD the 63,000 gallons removed in 1997. WMII claims that this
was an abnormally low yearly rate, and that the 1998 rate is closer to 1,000 gallons per week.
57. The Village questions the inclusion of the capital costs of Well No. 7 and the costs the
Village will incur upon capping Well No.4. They are not part of the RD to be undertaken
and their inclusion appears to make those alternative remedies which essentially
recommend doing nothing as having done something positive to ameliorate the threat to
the public drinking water.
H.O.D. Responsiveness Summary; September, 1998 21
-------
USEPA Response: The inclusion of groundwater monitoring alternative capitals costs of
installing Village Well Seven and capping Village Well Four was for reference purposes, and
was not intended to overemphasize the groundwater monitoring component of the No Further
Action alternative or of the selected remedy.
58. Some of the previous Site investigations noted at Page 1-8 were undertaken by WMII
during the courre of litigation with the Village regarding the Site. Much earlier in this
Site investigatory process, the Village had offered to provide to USEPA data and analysis
done by independent consultants and certified laboratories obtained in the course of
litigation. We were informed that USEPA would generate its own data and analysis
outside the framework of litigation, an understandable point of view. We are, therefore,
somewhat disconcerted to find that the RI/FS contains citation to and reliance on data and
reports generated by WMII in the course of that same litigation. In view of our
consultant's review and concurrence with the selected remediation remedies, there
appears to be little cause for concern over this problem. However, for the record, our
available data and scientific analysis did not support statements or inferences made in the
RI/FS such as posiiing the existence of a continuous clay diamict with no pathway for
transmission or the finding of no organics of concern in the deep sand and gravel beneath
the Site. Often, even with split samples, our results would differ. Based on the limited
data and sampling sites available, the Village disagrees with sweeping statements which
are then used to support an argument that landfill is not responsible for adjacent
contamination. The Village states in response to the assertion at Page 1-12 of the FS that
the conclusion that "the downward migration of VOC's from the surficial sand through
the clay diamict does not appear to be occurring" was not supported by the independent
consultants of the Village and data generated by them in the course of Site litigation.
Again, in view of the USEPA decision to clean up the Site and the specific
recommendations of remedies, the continual caveat in the FS that the vinyl chloride may
not be coming from the landfill (Page 2-3 of the FS) may not be important, but the
Village wishes to emphasize just as continually that its independent data and the
interpretation of Site data by qualified groundwater scientists and landfill experts did not
support this conclusion.
USEPA Response: The USEPA acknowledges differences in opinion between the Village and
WMII on the characteristics and dynamics of the Site. Since WMII was the only PRP to agree to
conduct the RI, USEPA reviewed related WMII documentation. WMII's position that the vinyl
chloride contamination is probably not Site-related was considered and rejected in USEPA's
decision to move forward with the selected remedy.
59. In somewhat the same vein, the Village comments that the use of one or two additional
sampling wells as part of the pre-design investigation study to define the very existence of
a contaminant plume in an area where the groundwater flow direction has been affected
by the zone of influence of a nearby pumping Village well seems chancy. The odds of
hitting such a plume with only two wells is not particularly large.
H.O.D. Responsiveness Summary; September, 1998 22
-------
USEPA Response: The USEPA will thoroughly evaluate the Pre-design Investigation Work
Plan, especially with respect to the number and location of wells to be installed.
60. Enclosed herewith and adopted by the Village as part of its Comments is the report of Dr.
Alphonse Zanoni to the Village. (Reference Three). We have attached Dr. Zanoni's
Curriculum Vitae as Reference Four. His outstanding credentials and long involvement
with the Site give great merit to the few Additional suggestions he makes. He has been
extremely instrumental in reassuring the Village that the USEPA selected remedies, if
fully and actively implemented, will substantially ameliorate the situation. As indicated
before, his and the Village's acceptance and approval of the cleanup program, including a
reduced cap and the selected GW2 monitoring plan, is based on the ongoing active
removal of leachate and landfill gas from the Site. Without such an active extraction
program to reduce the mass of contaminants within the landfill, the groundwater
monitoring plan and the cap selected are not adequate.
USEPA Response: The USEPA has responded separately to Dr. Zanoni's comments below.
The USEPA acknowledges Dr. Zanoni's concurrence with the preferred alternative of the
Proposed Plan. The active leachate and gas collection system is part of the selected remedy.
Comments from Dr. Alphonse Zanoni (submitted as part of the Village of Ant loch
comments)
61. For the capping component of the preferred alternative, it is important that the landfill
cap be properly maintained in future years. While new refuse has not been added to the
Site for 15 years, the previously deposited refuse is still undergoing decomposition, and
producing leachate and gas. Differential settlement will continue to occur at the Site in
future years, but at a lesser rate in comparison to past years. A properly maintained
landfill cap will minimize the amount of precipitation that enters the refuse mass
through infiltration. As noted in the FS, it is expected that approximately 1.6 inches
per year of precipitation will infiltrate the landfill soil cap and enter the refuse mass.
Under steady state conditions, even this controlled level of infiltration has the potential
to produce approximately 6,000 gallons per day of leachate. It is of interest to the
Village to ensure that the landfill cap be maintained in the best possible condition in
future years. As noted in the FS, quarterly inspections to assess Site conditions will be
conducted in the future. I recommend that the inspection reports be submitted to the
Village of Antioch to ensure that future maintenance of the landfill cap occurs when
needed.
USEPA Response: The USEPA selected remedy calls for proper installation of cap
improvements, proper maintenance and inspection, and proper reporting to ensure that the
remedy is effectively working. Since it is not known at this time which entities will be
performing the RD/RA, it is premature to discuss the distribution of remedial reports. Should
one or more PRPs perform the RD/RA, the PRP(s) performing the RD/RA may work with other
H.O.D. Responsiveness Summary; September, 1998 23
-------
PRPs to develop a PRP distribution list for remedial reports. Should USEPA or one or more of
its contractors perform the RD/RA, USEPA will discuss the distribution of remedial reports with
interested PRPs.
62. For the gas collection/treatment and leachate collection components of the preferred
alternative, I believe the Village is best served by the installation of an active system
for the management of gas and leachate that will continue to be generated at the Site. I
concur with the FS that the G3 and LC4 alternatives should be considered together
"because the required construction for wjch of these alternatives is similar." As was
noted previously, given the estimated 1.6 inches per year of infiltration through the
landfill cap, leachate will be continuously generated at the Site. While the
concentration of leachate constituents will continue to decrease with time, it will take
many years before the leachate constituents ameliorate to the level that they will no
longer pose a potential hazard to the groundwater aquifer which serves the Village's
public water supply source. An active leachate extraction system as presented in Figure
12 of the FS should provide the Village a level of protection of its water supply source
that is not available at the present time, and approaching the level of protection that
would certainly be there if a municipal landfill were being Designed and sited today.
Since the decomposition process will continue for many years into the future, though at
a continuously reduced rate, landfill gas also needs to be actively managed for many
years. Again, as noted in the case of the leachate extraction system, an active gas
management system would be an integral part of a modern municipal landfill design
today.
Of some concern to me is that in the FS, reference is made to the proposed pilot/pre-
design studies, and that the results of these studies "may indicate that the fully active
system proposed under G3 is not necessary, and that G2 is sufficient to address the
landfill gas (LFG) at the Site." I believe that it is in the best interest of the Village that
an active LFG and leachate extraction system be constructed and operated at the Site.
While pilot/pre-design studies are certainly beneficial, the scope of this effort cannot
equal what could be accomplished at the Site with a full, in-place gas/leachate
management system of the type depicted in Figure 12 of the FS. I want to stress that
my overall concurrence of the USEPA-recommended plan noted at the beginning of this
statement is predicated on the assumption that an active LFG and leachate collection
system is constructed at the Site. An in-place system of this type, even if not fully
used, will provide the Village's public water supply source with an added level of
protection.
Finally, I concur with the statements in the recommended remedial actions for active
LFG and leachate management that following construction of the necessary facilities,
that they be properly operated and regularly maintained. The Village should receive
the monthly inspection and monitoring reports to ensure that these requirements are
properly satisfied.
H.O.D. Responsiveness Summary; September, 1998 24
-------
USEPA Response:
The USEPA selected remedy calls for proper implementation and operation and maintenance
(O&M) of the active, dual gas and leachate extraction system. Before USEPA considers a
lesser system as a result of pilot/pre-design studies, USEPA must be assured that the lesser
system will be protective of human health and the environment. If USEPA is not convinced of
this, it will not approve a lesser system.
Since it is not known at this time which entities will be performing the RD/RA, it is premature to
discuss the distribution of remedial reports. Should one or more PRPs perform the RD/RA, the
PRP(s) performing the RD/RA may work with other PRPs to develop a PRP distribution list for
remedial reports. Should USEPA or one or more of its contractors perform the RD/RA, USEPA
will discuss the distribution of remedial reports with interested PRPs.
63. Leachate treatment at a licensed POTW is a common method of disposing leachate
generated at a municipal landfill site. Understandably, the leachate characteristics must
meet the industrial discharge requirements that are in force at the POTW in question.
As noted in the FS, approximately 35,000 gallons per month are currently extracted
from the Site. The Village should be aware that following construction of the active
leachate extraction system, the quantity and characteristics of leachate generated at the
Site will probably change. It is not possible at this point to estimate the extent to which
the leachate quantity will approach the steady state value of approximately 180,000
gallons per month that would result with complete capture of the estimated infiltration
value of 1.6 inches per year referred to previously in this statement. Obviously, the
POTW which will receive the leachate in the future should be prepared to handle the
potential changes in leachate quantity and quality noted above.
USEPA Response: For the leachate treatment component of the selected remedy, USEPA
allows for an alternate POTW to be used if the current POTW (the Fox River Water
Reclamation District) cannot properly treat the leachate.
64. For the monitored, natural attenuation component of the preferred alternative, one of
the first concerns I expressed publicly is the close proximity of the Site to the Village's
public water supply source. Virtually all current landfill siting criteria would not allow
the construction of a municipal sanitary landfill at this location. For this reason, I view
this remedial action to be of great import to the Village of Antioch, since it directly
relates to the future quality of the community's public water supply source. It is known
that natural attenuation can reduce the impact of leachate which migrates downgradient
from the landfill. The greater the distance between the origin of the leachate and the
water supply source, the greater is the level of protection afforded by the mechanism of
natural attenuation. In the case of the Village of Antioch, active community water
supply wells VW3 and VW5 are a relatively short, downgradient distance from the
southwest corner of the Site. Hence, the proposed groundwater monitoring plan
H.O.D. Responsiveness Summary; September, 1998 25
-------
presented in Figure 15 of the FS, showing sampling wells downgradient of the
southwest corner of the Site, is highly beneficial to the Village of Antioch. I concur
with the sampling plan described in the FS (pages 3-21 to 3-23) and recommend that the
Village aggressively monitor this remedial action in future years to ensure that the
Proposed Plan is followed in all respects. In addition, I recommend that the Village of
Antioch ask that the following four anaiytes be monitored quarterly for the full 30-year
period: nitrate, chloride, conductivity, and total organic carbon. These anaiytes will
serve as possible "tracers" of leachate migration and degree of natural attenuation. The
result of this additional monitoring data could serve to alert the community at some
point in the future that other measures may have to be taken to maintain the quality of
the Village's public water supply.
USEPA Response:
The USEPA is aware of the proximity of Village Wells Three and Five to the Site, and is also
aware of the importance of implementing a meaningful groundwater monitoring plan to alert
USEPA and others to possible drinking water safety concerns. The groundwater monitoring
plan in the GW2 component of the selected remedy is a suitable plan that will be refined during
the RD.
The USEPA will evaluate the list of monitored, natural attenuation parameters in the
groundwater monitoring plan during the RD. Nitrate, conductivity, and total organic carbon
are already included as monitored, natural attenuation parameters in the GW2 component of
the selected remedy.
Comment from the Unitecj gtates Army Corps of Engineers (USAGE)
65. The USAGE does not anticipate that implementation of the Proposed Plan would impact
any Chicago District planning projects, and does not feel that implementation of the
Proposed Plan would have any significant or long-term adverse environmental effects.
If wetlands exist at the project area, a permit application (Section 404) should be
submitted to the Chicago District's regulatory functions (CO-R) branch.
USEPA Response: The USEPA appreciates the comment from USAGE. Implementation of
the selected remedy is not expected to impact the wetlands adjacent to the Site; therefore, a
permit application should not be required.
H.O.D. Responsiveness Summary; September, 1998 26
-------
APPENDIX B: ADMINISTRATIVE RECORD INDEX
-------
NO.
1 00/00/00
2 08/24/82
3 11/00/85
4 11/15/85
5 11/18/85
6 11/19/85
7 12/20/85
8 01/08/86
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
H.O.D. LANDFILL SUPERFUND SITE
ANTIOCH, LAKE COUNTY, ILLINOIS
ORIGINAL
JUNE 30, 1992
AUTHOR
Ruddy, W. &
D. Yeskis;
U.S. EPA
Molenhouse,
R., Waste
Management
Antioch
Townspeople
Barker, F.,
U.S. EPA
Rohr, J. &
J. Horns y;
Waste
Management
Grigalauski,
C., Waste
Management
Kuykendall,
R., IEPA
Metcalfe, J.
U.S. EPA
RECIPIENT
Yeates, T.,
FIT
Amendola, H.
Pollution
Control
Commission
Wyer, R.,
U.S. EPA
Wyer, R.
Wyer, R.,
U.S. EPA
Nelson, D.,
Waste
Management
Record
TITLE/DESCRIPTION
Request for FIT
Services
Permission to Release
Leachate Analysis
Various Letters in
Support of H.O.D. Land-
fill Listing on NPL
DRAFT--HRS Scoring
Sheets
Comments to Proposed
Listing of H.O.D. Land-
fill to NPL
Cover Letter to Revisions
of Comments to Proposed
Listing of H.O.D. Land-
fill to NPL
Response to Concerns re:
H.O.D. Landfill Proposed
NPL Listing
Meeting with Waste
Management en January 8,
1986
PAGES
1
55
9 02/28/86
Henderson, D.
Attorney
Wyer, R.,
U.S. EPA
Comments on Behalf of
Village of Antioch to
Waste Management's
Comments re: Proposed
NPL
19
H.O.D. ARI; September 28, 1998
1 Of 15
-------
10
11
12
13
DATE
11/19/86
01/30/87
02/19/87
03/24/87
14 04/06/87
AUTHOR
Dikinis, J.,
U.S. EPA
Ecology and
Environment,
Ruddy, W., .
U.S. EPA
Homsy, J.,
Waste
Management
Ecology and
Environment,
Inc.
RECIPIENT
Diefenbach,
R., U.S. EPA
U.S. EPA
Cowles, R.,
IEPA
Constantelos,
B., U.S. EPA
U.S. EPA
TITLE/DESCRIPTION PAGES
Decision and Reasons for 1
ESI
Work Plan for the H.O.D. 136
Landfill Site
Status of Site 1
History, Issues and
Courses of Action for
ESI
Work Plan for the H.O.D.
Landfill Site- -Revised
55
15 04/20/87
Borchardt, W. ,
Ecology and
Environment,
Inc.
File
Work Plan Addendum:
Sample Plan
• 16 04/23/87
Landman , B . ,
U.S. EPA
17 04/23/87 Adamkus, V.,
U.S. EPA
18 05/04/87 Yeskis, D.,
U.S. EPA
19 10/15/87 Yeskis, D.,
U.S. EPA
20 11/16/87 Yeskis, D.,
U.S. EPA
21 12/22/87 Gelting, K.,
Waste
Management
Homsy, J.,
Waste
Management
Homsy, J.,
Waste
Management
Pile
Gelting, K.,
Waste
Management
Gelting, K.,
Waste
Management
Yeskis, D.,
U.S. EPA
Draft Letter re: WMI's . 4
Objections to ESI
Notice of ESI Implemen-
tation
Meeting with Represen-
tatives from Waste
Management on April 23,
1987
Cover Letter to Soil
Data
Cover Letter to Boring
Data
Transmittal of 3 Letters
re: Groundwater Monitor-
ing, Hydraulic Testing
& ESI Data
H.O.D. ARI; September 28, 1998 2 of 15
-------
NO. BATJ£
AUTHOR
RECIPIENT
22
23
24
25
26
27
28
29
30
31
32
12/29/87
01/13/88
01/22/88
02/04/88
02/05/88
03/28/88
04/04/88
07/07/88
08/29/88
12/19/88
01/10/89
Gel ting, K. ,
Waste
Management
Yeskis, D. ,
U.S. EPA
Gelting, K. ,
Waste
Management
Gelting, K. ,
Waste
Management
Yeskis, D.,
U.S. EPA
' Gelting, K. ,
Waste
Management
Yeskis, D.,
U.S. EPA
Yeskis, D.,
U.S. EPA
Rohr, J. &
C . Lowri ;
Waste
Management
Yeskis, D.,
U.S. EPA
Gelting, K. ,
Waste
Yeskis, D. ,
U.S. EPA
Gelting, K. ,
Waste
Management
Yeskis, D. ,
U.S. EPA
Yeskis, D.,
U.S. EPA
Gelting, Y.. ,
Waste
Management
Yeskis, D.,
U.S. EPA
Gelting, K. ,
Waste
Management
Gelting, K. ,
Waste
Management
Nadeau, P.,
U.S. EPA
Myers, R. ,
U.S. EPA
Yeskis, D. ,
U.S. EPA
TITLE/DESCRIPTION PAGES
Expanded Comments on 3
Water Quality Results
Drum Inventory
Drum Disposal
Soil Sampling Results
Addressing Concerns in
Letters of December 7,
1987 & December 29, 1987
re: Sampling w/ Attached
Water Level Table
Additional Information
for ESI
Request for Well
Sampling
Cover to Sampling and
Request for Use of
Downhole TV
Request for Withdrawal
from NPL Listing
Review of H.O.D. Land- 36
fill Hydrogeological
Investigation and Com-
munication with Waste
Management w/ Attachments
ESI Sampling Information 2
Request
Management
H.O.D. ARI; September 28, 1998 3 of 15
-------
AUTHOR
RECIPIENT
TITLE /DESCRIPTION
PAGES
33
02/13/89
34
35
36
37
38
39
40
41
42
43
44
04/14/89
05/19/89
06/19/89
09/22/89
09/22/89
09/22/89
09/22/89
12/26/89
00/00/90
02/00/90
04/12/90
Yeakis. D.,
U.S. EPA
Myers, R.,
U.S. EPA
Gelting, K.,
Waste
Management
Yeskis, D.,
U.S. EPA
Ecology and
Environment,
Inc.
Ecology and
Environment,
Inc.
Ecology and
Environment,
Inc.
Ecology and
Environment,
Inc.
Kelly, J.,
U.S. EPA
U.S.
Geological
Survey
Pachowicz, T. ,
U.S. EPA
Gelting, K.,
Waste
Management
Record
Yeskis, D.,
U.S. SPA
Gelting, K.,
Waste
Management
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
PRPs
Response to Request of
January 10, 1989 for
Sampling Activities of
April 19, 1988
Cover Letter and Comments
re: Yeskis' December 19,
1988 Memorandum
Request for Review of
Certain Statements in
February 5, 1988 Letter
Response to Concerns of
May 19, 1989 Letter
Expanded Site Inspec- 155
tion Report for H.O.D.
Landfill- -Vol. 1
Expanded Site Inspec- 302
tion Report for 'H.O.D.
2
U.S. EPA
Expanded Site Inspec- 538
tion Report for H.O.D.
Landfill --Vol. 3
Expanded Site Inspec- 444
tion Report for H.O.D.
Landfill --Vol. 4
Notice of Potential 6
Liability
Determination of Hydrau- 33
lie Properties in the
Vicinity of a Landfill
Near Antioch, IL
NPL Conditions at Site 31
Scope of Work for 52
Conducting a Remedial
Investigation and Feasi-
bility Study at H.O.D. .
Landfill
H.O.D. ARI; September 28, 1998 4 of 15
-------
HSU. DATE AUTHOR
45 08/20/90 U.S. EPA
RECIPIENT
TTTT.t; /pESCRIPTION PAGES
Administrative Order on 40
Consent re: RI/FS for
H.O.D. Landfill Site
46
47
02/24/92 U.S. EPA
06/30/92
Traub, J.,
U.S. EPA
PRP List
Attached
PRPs
Demand Letter for Past
Costs at H.O.D. through
August 19, 1990
General Notice of
Potential Liability and
Demand for Reimbursement
of Past Costs
20
UPDATE «1
OCTOBER 8, 1992
DATE
AUTHOR
00/00/00 Warzyn,
Inc.
08/00/92 Warzyn,
Inc.
08/00/92
08/00/92
Warzyn,
Inc.
Warzyn,
Inc.
RECIPIENT
Waste
Management
of North
America, Inc.
Waste
Management
of North
American, Inc.
Waste
Management
of North
American, Inc.
Waste
Management
of North
American, Inc
TITLE/DESCRIPTION
MAPS: Preliminary Site 10
Evaluation Report
Work Plan (PSER/TS): 145
Vol. l of 3
Work Plan (PSER/TS): 456
Vol. 2 of 3
Work Plan (PSER/TS): 269
Vol.3 of 3
H.O.D. ARI; September 28, 1998
5 Of 15
-------
DATE
09/00/92
09/00/92
11/18/92
11/18/92
12/00/92
03/00/93
03/00/93
AUTHOR
Warzyn, Inc./
Haste
Management
of Illinois,
Inc.
Warzyn, Inc./
Haste
Management
of Illinois,
Ecology and
Environment,
Inc.
Ecology and
Environment,
Inc.
Warzyn, Inc./
Haste
Management
of Illinois,
Inc.
Haste
Management
of North
America-
Midwest ;
et al.
Warzyn, Inc./
Haste
Management
of Illinois,
Inc.
04/07/93 U.S. EPA
UPDATE *2
JANUARY 9, 1997
RECIPIENT
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
Public
TITLE/DESCRIPTION PAGES
Data Management Plan 10
RI/FS: Quality Assur-
ance Project Plan
Volume 1 of 2: Text,
Tables and Figures)
RI/FS Oversight and
Review: Quality Assur-
ance Project Plan
RI/FS Oversight and
Review: Work Plan
Addendum 1
RI/FS: Quality Assur-
ance Project Plan Volume
2 of 2: Appendices (A-E)
Leachate Treatability
Study for the H.O.D.
Landfill
RI/FS: Final Health and
Safety Plan
Environmental News
Release: "Environmental
Investigation Starts at
H.O.D. Landfill"
390
210
18
231
35
228
H.O.D. ARi; September 28, 1998
6 Of 15
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NO. DATE
9 10/00/93
10
11
12
10/00/93
10/00/93
10/30/93
DATE
03/00/93
AUTHOR
Warzyn, Inc./
Waste
Management
of Illinois,
Inc.
Warzyn, Inc./
Waste
Management
of Illinois,
Inc.
Warzyn, Inc./
Waste
Management
of Illinois,
Inc.
USDHHS/USPHS/
ATSDR; Illinois
Department of
Public Health
AUTHOR
Warzyn, Inc.
10/00/93 Warzyn, Inc.
10/00/93 Warzyn, Inc.
10/00/93 Warzyn, Inc.
RECIPIENT
U.S. EPA
TITLE/DESCRIPTION
EASES
U.S. EPA
U.S. EPA
U.S. EPA
UPDATB J3
MARCH 11, 1997
RECIPIENT
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
RI/FS: Technical Memo- 132
randum #1 - Investigation
Results and Analysis
Report (Volume 1 of 3:
Text, Tables, Figures
and Drawings)
RI/FS: Technical Memo- 197
randum #1 - Investigation
Results and Analysis
Report (Volume 2 of 3:
Appendices A-L)
RI/FS: Technical Memo- 378
randum #1 - Investigation
Results and Analysis
Report (Volume 3 of 3:
Appendices M-P)
Public Health Assessment
TTT^Ff /DESCRIPTION
Final Site Health and
Safety Plan
Ecological Assessment
Preliminary Screening
Screening Report
Technical Memorandum #1:
Investigation Results
and Analysis Report,
Volume 1 of 3 (Text,
Tables and Figures)
Technical Memorandum #1:
Investigation Results
and Analysis Report,
Volume 2 of 3 (Appen-
dices A-L)
60
286
44
133
196
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SJL. DATE AUTHOR RECIPIENT
5 10/00/93 Warzyn, inc. U.S. EPA
TITLE/DESCRIPTION
PAGES
01/27/94
02/04/94
02/17/94
03/25/94
10
04/12/94
Micke, F. ,
U.S. EPA
Kuyawa, L.,
Haste
Management
Hamper, M.,
Warzyn, Inc.
Packowicz, T.,
Ecology and
Environment,
Inc.
Palco, C.,
IEPA
Kuyawa, L.,
Waste
Management
Micke, P.,
U.S. EPA
Micke, P.,
U.S. EPA
Micke, P.,
U.S. EPA
Micke, P.,
U.S. EPA
Technical Memorandum #1: 386
Investigation Results
and Analysis Report,
Volume 3 of 3 (Appen-
dices M-P)
U.S. EPA's Comments on 4
the Ecological Assessment
Preliminary Screening
Report for the H.O.D.
Landfill Site
WMI's Review Comments on 4
the Ecological Assessment
Preliminary Screening
Report and Technical
Workplan for the H.O.D.
Landfill Site Baseline
Risk Assessment
WI's Transmittal of 34
Response to Technical
Memorandum #1: Comment
E&E's Review of WMI's 5
Responses to U.S. EPA's
Comments on Technical
Memorandum #1
lEPA's Comments on WMI's 2
Response to Comments for
Technical Memorandum #1
PPDATK «4
MAY 21, 1997
DATE
01/00/97
01/00/97
AUTHOR
Montgomery
Watson/Waste
Management
of Illinois,
Inc.
Montgomery
Watson/Waste
Management
of Illinois,
Inc.
RECIPIENT
U.S. EPA
U.S. EPA
TITLFi /DESCRIPTION PAGES
Remedial Investigation/ 180
Feasibility Study for
the H.O.D. Landfill
Site: Volume 1 of 3
(Text, Tables and
Figures)
Remedial Investigation/ 329
Feasibility Study for
the H.O.D. Landfill
Site: Volume 2 of 3
(Appendices A-N)
H.O.D. ARI; September 28, 1998
8 Of 15
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DATE
01/00/97
AUTHOR
Montgomery
Watson/Waste
Management
of Illinois,
Inc.
RECIPIENT
U.S. EPA
OPDATK *5
JUNE 13, 1997
TITLE/DESCRIPTION £&£££
Remedial Investigation/ 393
Feasibility Study for
the H.O.D. Landfill
Site: Volume 3 of 3
(Appendices O-S)
NO. DATE AUTHOR
1 00/00/00 Burton, T. ,
et al
08/19/82 Adams, L.,
Antioch
Reporter
02/11/83
07/24/84
02/25/87
11/05/93
05/18/94
Shea, P.,
Ecology and
Environment,
Inc.
Ecology and
Environment,
Inc.
The News-Sun
(Lake County)
07/23/93 Schmidt, A.
Warzyn, Inc.
U.S. District
Court/Nor them
District of
Illinois
Kuyawa, L.,
Waste
Management,
Inc.
RECIPISNT
Public
Public
U.S. EPA
U.S. EPA
Public
Micke, F.
U.S. EPA
Consenting
Parties
Micke, F.,
U.S. EPA
TITLE/DESCRIPTION
Newspaper Article re:
Federal Indictment
of H.O.D. Operations
Manager
Newspaper Article:
"COD Level "Unusually
High;' Well Four
Already Polluted?"
Preliminary Assessment
for the H.O.D. Landfill
Site
Site Inspection Report
for the H.O.D. Landfill
Site
Newspaper Article:
"EPA Eyes Antioch Site
for Superfund"
Letter Forwarding
Attached Analytical
Results for the Village
of Antioch Well No. 4
Consent Decree
PAGES
1
Letter re: WMI's Response
to U.S. EPA Comments on
the Baseline Risk Assess-
ment Workplan
16
32
35
H.O.D. ARI; September 28, 1998
9 Of 15
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NO.
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
9 06/10/94 Micke, F.,
U.S. EPA
10 02/14/97 Linnear, D.,
U.S. EPA
11 02/26/97 Blair, T.,
Montgomery
Watson
Kuyawa, L.,
Haste
Management,
Inc.
Leibrock, M.,
Waste
Management,
Inc.
U.S. EPA
Letter re: U.S. EPA's
Approval of the Baseline
Risk Assessment Technical
Workplan
Letter re: U.S. EPA's
Approval of the Remedial
Investigation Report
for the H.O.D. Landfill
Site
Letter Forwarding
Attached Alternatives
Array Document and Formal
Request for ARARs and
TBCs
11
UPDATE »6
DATE
10/07/93
DATE
08/31/94
AUTHOR
Ecology and
Environment,
Inc.
AUTHOR
ICF Kaiser
Engineers ,
Inc.
JULY 28, 1997
RECIPIENT
U.S. EPA
UPDATB «7
NOVEMBER 5, 1997
RECIPIENT
U.S. EPA
TITLE /P^iSCTIPTION
Community Relations
Plan for the H.O.D.
Landfill Site
TITLE/DESCRIPTION
Baseline Risk Assess-
ment for the H.O.D.
Landfill Site
PAGES
28
PAGES
175
08/11/97
10/02/97
Murawski, R.,
U.S. EPA
Podowski, A.,
U.S. EPA/
Technical
Support
Section
Leibrock, M.,
Waste
Management
of Illinois,
Inc.
Murawski, R.,
U.S. EPA
Letter re: (1) the Draft
Baseline Risk Assessment
and (2) the Alternatives
Array Document for the
H.O.D. Landfill Site
Memorandum: TSS' Review
of WMII's August 19, 1997
FAX Transmission re:
(1) Nutritional Screening
(2) Recalculation of Risk
for Antimony, and (3)
T-test Results for Arsenic
and Magnesium at the
H.O.D. Landfill Site
H.O.D. ARI; September 28, 1998
10 Of 15
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NO. BATE
4 10/24/97
Foster, S.,
The Weinberg
Group Inc.
10/28/97
10/29/97
DATE
12/15/97
Leibrock, M.,
Haste
Management
of Illinois,
Inc.
Murawski, R.,
U.S. EPA
AUTHOR
Murawski, R.,
U.S. EPA
RECIPIENT
Leibrock, M.,
Waste
Management
Inc.--Midwest
Group
Murawski, R.,
U.S. EPA and
G. Ratliff,
IEPA
Leibrock, M.,
Haste
Management
of Illinois,
Inc.
UPDATE »8
DECEMBER 30, 1997
RECIPIENT
Leibrock, M.,
Haste
Management
of Illinois,
Inc.
TITIifl /DESCRIPTION PAGES
Letter re: Weinberg 12
Group's Responses to
U.S. EPA's Comments on
the Baseline Risk
Assessment for the
H.O.D. Landfill Site
Letter re: HMII's Final 14
Responses to U.S. EPA/
IEPA's Comments on the
Baseline Risk Assessment
Report for the H.O.D.
Landfill Site
Letter re: U.S. EPA's 2
Final Approval of the
August 31, 1994 Draft
Baseline Risk Assessment
for the H.O.D. Landfill
Site
TI7TLF- /DESCRIPTION PAGES
Letter re: U.S. EPA's 2
Positions on Issues
Raised by WMII at the
December 4, 1997
Meeting and Submission
of the Draft Feasibility
Study for the H.O.D.
Landfill Site
07/10/97
AUTHOR
Blair, T.;
Montgomery
Watson
UPDATK *9
MARCH 12, 1998
RECIPIENT
Murawski, R.,
U.S. EPA
TITLE/DESCRIPTION PAGES
Letter Forwarding 10
Attached Tables re:
Potential Federal and
State (1) Chemical-
Specific ARARs, (2)
Location-Specific ARARs,
and (3) Action-Specific
ARARs for the H.O.D.
Landfill Site
H.O.D. ARI; September 28, 1998
11 Of 15
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NO. DATE
AUTHOR
RECIPIENT
TI TT.F. /DE SCRIPT ION
PAGES
09/10/97 Ratliff, G.,
IBPA
Murawski, R.,
U.S. EPA
3 10/08/97 Murawski, R.,
U.S. EPA
Leibrock, M.,
Wast_ Management
of Illinois,
Inc.
DATE
AUTHOR
12/18/97 Murawski, R. ,
U.S. EPA
UPDATE ilO
APRIL 21, 1998
RECIPIENT
File
03/23/98 Murawski, R.,
U.S. EPA
Leibrock, M.,
Waste
Management
of Illinois,
Inc.
PPDATB ill
JUNE 8, 1998
Letter re: IEPA's
Comments on the Alterna-
tives Array Document
and Potential ARARs for
the H.O.D. Landfill Site
Letter re: Potential
ARARs for the H.O.D.
Landfill Site w/Attached
Tables of:(l) Potential
Chemical-Specific ARARs,
(2) Location-Specific
ARARs and (3) Action-
Specific ARARs
10
l'S /DESCRIPTION PAGES
Memorandum re: U.S. 2
EPA's December 17, 1997
Meeting with Village of
Antioch Officials
Concerning the H.O.D.
Landfill Site
Letter Forwarding 22
Attached U.S. EPA and
IEPA Comments on the
February 1998 Draft
Feasibility Study for
the H.O.D. Landfill
Site
04/22/91
AUTHOR
U.S. EPA/
OSWER
RECIPIENT
U.S. EPA
TITm/DESCRIPTION
Memorandum re: Role of
the Baseline Risk Assess-
ment in Superfund Remedy
Selection Decisions
(OSWER Directive 9355.
0-30)
10
H.O.D. ARI; September 28, 1998
12 Of 15
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NO, BATE
AUTHOR
2 02/00/98 Montgomery
Watson
RECIPIENT
U.S. EPA
TITLE/DESCRIPTION PAGES
Draft Feasibility Study 230
for the H.O.D. Landfill
Site
3 04/00/98 Montgomery
Watson
U.S. EPA
Draft Final Feasibility
Study for the H.O.D.
Landfill Site
205
04/00/98
Montgomery
Watson
U.S. EPA
Deep Groundwater Tech-
nical Memorandum for
the H.O.D. Landfill Site
18
04/23/98
Blair, T.,
Montgomery
Watson
Murawski, R.,
U.S. EPA
Letter re: MW's Response
to U.S. EPA/IEPA's
Comments on the February
1998 Draft Feasibility
Study for the H.O.D.
Landfill Site
38
05/20/98
Murawski, R. ,
U.S. EPA
Leibrock, M.,
Waste
Management
of Illinois,
Inc.
Letter re: U.S. EPA/
IEPA's Comments on the
April 1998 Draft Final
Feasibility Study for
H.O.D. Landfill Site
06/00/98
06/03/98
AUTHOR
Montgomery
Watson
Blair, T.,
Montgomery
Watson
06/25/98 Montgomery
Watson
06/30/98 Murawski, R.,
U.S. EPA
UPDATE »12
JULY 13, 1998
RECIPIENT
U.S.EPA
Murawski, R.,
U.S. EPA
Murawski, R.,
U.S. EPA
Leibrock, M.,
Waste
Management '
Of Illinois
TITVi /DESCRIPTION PAGES
Final Feasibility Study 229
for the H.O.D. Landfill
Site
Letter re: MW's Response 8
to U.S. EPA's May 20, 1998
Comments on the April
1998 Draft Feasibility
Study for the H.O.D.
Landfill Site
Final Addendum to the
Final Feasibility Study
for the H.O.D. Landfill
Site
Letter re: U.S. EPA's
Approval of the June 1998
Final Feasibility Study
for the H.O.D. Landfill
Site
93
H.O.D. ARI; September 28, 1998 13 of 15
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NO.
1 09/00/93
AUTHOR
U.S. EPA/
OSWER
07/00/98 U.S. EPA
UPDATE *13
JULY 23, 1998
RECIPIENT
U.S. EPA
Public
TITLE/DESCRIPTION
PAGES
Quick Reference Fact 15
Sheet: Presumptive Remedy
for CERCLA Municipal
Landfill Sites (EPA 540-
F-93-035; PB 93-963339)
Proposed Plan for the 12
H.O.D. Landfill Site
NO. DATE
1 08/18/98
08/00/98
08/17/98
AUTHOR
L&L Reporting
Service, Inc.
NO. DATE
1 07/29/98
AUTHOR
Ryder, K.,
U.S. Army
Corps of
Engineers/
Chicago
District
Henderson, D.,
Village of
Antioch
Ahlers, W.,
Antioch
Community
High School
District 117
UPDATE »14
AUGUST 21, 1998
RECIPIENT
U.S. EPA
UPDATE
AUGUST 28, 1998
RECIPIENT
U.S. EPA
U.S. EPA
08/06/98 Gustafson, C., Murawski, R.
Trevor, WI & G. Blum;
Resident U.S. EPA
Blum, G.,
U.S. EPA
TTTLB/DESCRIPTION PAGES
Transcript of August 78
11, 1998 Proposed Plan
Public Meeting for the
H.O.D. Landfill Site
TITLE/DESCRIPTION PAGES
Public Comment Sheet re: 1
USAGE'S Comments on
U.S. EPA's Recommended
Cleanup Plan for the
H.O.D. Landfill Site
Village of Antioch's 35
Comments on the RI/FS
for the H.O.D. Landfill
Site w/ Attachments
Memorandum: Citizen's 8
Questions and Public
Comments Concerning the
H.O.D. Landfill Site
Letter re: School 42
District's Comments on
the Proposed Plan for
the H.O.D. Landfill
Site w/ Attachments
H.O.D. ARI; September 28, 1998 14 of 15
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DATE
08/19/98
08/20/98
AUTHOR
Leibrock, M.,
Waste
Management
of Illinois,
Inc.
Osmond, T.,
Antioch
Township
08/20/98 Sippy, K.,
Abbott
Laborato: ies
RECIPIENT
Murawski, R.,
U.S. EPA
Blum, G.,
U.S. EPA
Muno, W. &
G. Blum;
U.S. EPA
TITIiFi /DESCRIPTION
Letter re: WMI's
Comments on U.S. EPA's
Cleanup Plan for the
H.O.D. Landfill Site
Letter: Township's
Environmental Concerns
Regarding the Sequoit
Creek Channel by
Pedersen Marina
E-Mail Transmission re:
Comments on U.S. EPA's
Recommended Cleanup
Plan for the H.O.D.
Landfill Site
PAGES
H.O.D. ARI; September 28, 1998
15 Of 15
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