Superfund Record of Decision Southeast Rockford Groundwater Contamination Site Rockford IL


                                    EPA/ROD/R05-95/277
                                    1995
EPA Superfund
     Record of Decision:
     SOUTHEAST ROCKFORD GROUND WATER
     CONTAMINATION
     EPA ID:  ILD981000417
     OU02
     ROCKFORD, IL
     09/29/1995

-------
-------
will be conducted within five years after commencement of groundwater remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment.

Mary A. Gade, Director Date
Illinois Environmental Protection Agency
-------
The United States Environmental Protection Agency (U.S. EPA) concurs with the State of Illinois in the
selected ground water response action for the Southeast Rockford Ground Water Contamination Site in Rockford,
Illinois.

Valdas V. Adamkus Date
Regional Administrator
-------
RECORD OF DECISION SUMMARY

GROUNDTCATER RESPONSE ACTION
SOUTHEAST ROCKFORD GROUNDWATER CONTAMINATION SITE
ROCKFORD, IlilNOIS

I. Site Location and Description

The Southeast Rockford Groundwater Contamination Site is located in a residential and commercially zoned area
in the southeast portion of Rockford, Illinois. When the site was originally listed on the National
Priorities List (NPL), the nature and extent of groundwater contamination was largely unknown. As
groundwater data from residential and monitoring wells has been collected, the project "study area" was
initially expanded from the original NPL description to include an area of about five sguare miles. The
study area was later expanded to an area of ten sguare miles with boundaries that now include Broadway to the
north, Sandy Hollow Road to the south, Mulford Road to the east and the Rock River to the west. The original
site boundaries and current study area are noted on page 2. The Illinois Environmental Protection Agency
(IEPA) and the United States Environmental Protection Agency (USEPA) understand the current site boundaries
to be the groundwater contaminant plume of chlorinated volatile organic compounds (VOCs) that was defined in
the Remedial Investigation (RI). This groundwater plume is noted on page 3.

The study area is a predominantly suburban residential area with scattered industrial, retail and commercial
operations throughout. Most of the building structures at this site are one or two story residential
dwellings, but several industrial areas also exist next to residential areas along Harrison Avenue. There is
a substantial number of commercial and retail operations along Alpine Road, Eleventh Street and Kishwaukee
Street. The topography of the site is essentially flat-lying, with gradual sloping towards the Rock River.
The four major identified source areas of groundwater contamination at the site are noted on page 3. Other
groundwater plumes in the study area were investigated, but were not determined to be sources of chlorinated
VOCs found in residential wells.

Because of a relative abundance of groundwater resources, the City of Rockford's primary source of potable
water is groundwater. The Rock River to the west of the site is not used as a source of drinking water.
IEPA estimates that there are currently fewer than 600 residential wells within and adjacent to the site
boundaries. A smaller number of businesses with potable use wells are present at the central portion of the
site along Eleventh Street north of Sandy Hollow Road.

The site was proposed for inclusion to the NPL on June 24, 1988 and was formally added to the NPL on March
31, 1989 as a State-lead, federally funded Superfund site. The USEPA identification number for this site is
ILD981000417.

II. Site History and Enforcement Activities

To date, the actual site activities that led to groundwater contamination problems at this site are largely
unknown. Site investigation work performed during the RI noted four primary source areas of groundwater
contamination. Of these four source areas, aerial photographs have been useful in identifying the periods
during which one former disposal area was operated. The figure on page 3 notes the location of the four
source areas.

The disposal area (noted as "Area 7" throughout this document) apparently began operating in the early to
mid-1950s and continued through 1970. Although it is not precisely known what volume and time period
hazardous wastes were disposed of in Area 7, limited investigations have revealed that most hazardous waste
disposal activities occurred in the late 1950s to early 1960s during the property ownership of George
Johnson. Site investigations at Area 7 have revealed that chlorinated solvents, waste oils and fuels, paint
sludges, tank bottoms, hospital wastes and general refuse were disposed of in this landfill. The primary
method of disposal appears to have been direct discharge of liguids or sludges into an old creek ravine which
has since been covered. Since the site was operated before the effective date of the Resource Conservation
and Recovery Act (November 19, 1980), actual types of disposal methods were determined by witness
information.

Another source area of contamination identified in the RI report was at the Swebco Manufacturing facility
designated as "Area 4" This area appears to be a location where spills and discharges of waste solvents and
-------
oils occurred over recent years.

The former Rockford Varnish facility comprises "Area 11" . Like Area 4, this area appears to have been the
location of several spills and discharges. The facility has been abandoned for years and the time period of
any spills and discharges is not known.

"Area 9/10" is located north of the Ninth Street-Harrison Road intersection. Site investigations have
indicated a large plume of groundwater contamination downgradient from an old industrial area. The smaller
size of this plume indicates that groundwater contamination may be coming from a spill area or a location
where chlorinated solvents were dumped on the ground surface. The precise location of the source area
responsible for groundwater contamination here is unknown.

Although VOCs were initially detected in several City of Rockford municipal wells as early as 1981, IEPA
became aware of a VOC problem in residential wells in 1984. Following an October, 1984 study by the Illinois
Department of Public Health (IDPH), high levels of chlorinated solvents were found to be present in several
residential wells. These solvents included 1,1,1-trichloroethane, trichloroethene and tetrachloroethene.
IDPH took an additional 337 water samples from residential wells between 1985 and 1989 to better determine
how many residents were affected. The Illinois State Water Survey (ISWS) also performed a regional
groundwater investigation. This investigation noted widespread residential and municipal well
contamination. As a result of general groundwater contamination in Rockford, the City closed several
municipal wells in southeast Rockford.

In August, 1989, the USEPA sampled 112 residential wells around the site to determine if immediate removal
actions were warranted. Later that year, USEPA initiated a time critical removal action what included bottled
water for residents whose wells showed VOC levels greater than or egual to 25% of the Removal Action Level
(RAL). The same residents received point-of-use carbon filters in December 1989 as another interim measure.
USEPA ultimately extended municipal water mains and provided service connections to city water for 283
residents as a time critical removal action. This action was completed in late 1991.

IEPA began an operable unit groundwater RI and Feasibility Study (FS) that included sampling of 117
residential, commercial and industrial wells. The objective of this sampling event was to determine how many
homes had wells with VOC levels below RALs, but above Maximum Contaminant Levels (MCLs). A Proposed Plan,
outlining 264 homes to be hooked up to municipal water and the installation of a temporary granulated
activated carbon (GAG) unit at one municipal well that had been closed due to unsafe levels of VOCs was made
public in March 1991. This GAG unit was installed ensure sufficient capacity for residents added to the
city's water supply system. Between USEPA's time critical removal action and IEPA's Operable Unit RI/FS, a
total of 547 homes were hooked up to municipal water. All residents who received connections were reguired
to have their wells abandoned in accordance with State law. A Record of Decision (ROD) for this Operable
Unit was signed on June 14, 1991. Construction of the service connections and GA unit was initiated
immediately and carried out under USEPA' removal program so that the project could be completed on a shorted
timeframe. A Remedial Action Report certifying that the selected remedy for the Operable Unit RI/FS was
operational and function, was signed on December 21, 1992.

After the threat of exposure to groundwater contaminants was greatly reduced by the above-mentioned actions,
the next phase the project involved an inclusive groundwater RI/FS. The objective of the groundwater RI was
to characterize the nature and extent groundwater contamination as well as to provide information source
areas that were responsible for contaminants in and around residential wells abandoned in previous IEPA/USEPA
actions. It was decided to conduct the RI in phases since locations of the source areas were not known at
that time.

It is likely that a great deal of the groundwater contamination the Site results from historical waste
disposal operations. As result, information on potentially responsible parties (PRPs) associated with this
site was difficult to obtain. Analytical data from initial residential well sampling and the first phase of
the groundwater RI/FS gave a preliminary understanding of the nature and extent of groundwater contamination.
These data were useful the USEPA in an ongoing enforcement information gathering process that began with
CERCLA Section 104 (e) Information Reguest Letters being sent to a number of companies within the study area.
Several responses documented historical releases of chlorinated solvents similar to the contamination found
in groundwater at the site. On the basis of this information, USEPA issued Special Notice of Liability
Letters to a group of PRPs on January 31, 1992. This PRP group included the following companies:

Borg-Warner Corporation
Erhardt & Leimer, Inc.
Estwing Manufacturing Company
-------
Gordon Barrels Company
Rockford Products Corporation
Sundstrand Corporation
Suntec Industries, Inc.

In addition to information obtained from the Section 104 (e) process, eyewitness accounts of waste disposal at
Area 7 have recently surfaced. USEPA and the United States Department of Justice (USDOJ) are currently
evaluating this information. The enforcement information gathering process continues at the site.

III. Highlights of Community Participation

The RI report for the Southeast Rockford Groundwater Contamination sine was released to the public in
February 1995. The public comment FS and Proposed Plan were made public on July 10, 1995. These two
documents are available for public review in both the administrative record and the information repositories
maintained at the Rockford Public Library-Main Branch and the Ken-Rock Community Center and Rockford Public
Library-Rock River Branch, respectively. The notice of availability for the FS and Proposed Plan was
published in the Rockford Register Star on July 10, 1995. A public comment period was held from July 14, 1995
to August 16, 1995. In addition, two public meetings were held on August 1, 1995 and two public hearings
were held on August 9, 1995. At these meetings, representatives from IEPA, USEPA and IDPH were available to
answer guestions about the problems at the site and the remedial alternatives under consideration. A
response to the comments received during the public comment period is included in the Responsiveness Summary,
which is part of this Record of Decision. This decision document presents the selected remedial action for
groundwater portion of the Southeast Rockford Groundwater Contamination Site in Rockford, Illinois chosen in
accordance with CERCLA, as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986, the
Illinois Environmental Protection Act and, to the extent practicable, the National Contingency Plan. The
decision for this site is based on the administrative record.

IV. Scope and Role of Response Action within Site Strategy

As with many Superfund sites, the environmental problems at the Southeast Rockford site are complex. As a
result, IEPA and USEPA organized the work into three operable units, as follows:

Operable Unit One: Initial Contamination in Residential Wells

Operable Unit Two: Present and Future Contamination in
Potable Use Wells and Contamination of
the Groundwater Aguifer

Operable Unit Three: Contamination in Soils (Source Control)

As previously discussed, IEPA and USEPA implemented a remedy for Operable Unit 1 in a ROD dated June 14,
1991. Contaminated groundwater is the primary threat at this site because of the direct ingestion of
drinking water from wells that contain contaminants above health-based levels.

The second operable unit, the subject of this ROD, primarily addresses future contamination in all drinking
water wells within and adjacent to the site, as well as site-related chlorinated solvent contamination of the
groundwater aguifer as a whole. In addition, it will finalize temporary measures (e.g. the GAG unit) as
noted in operable unit 1. Although source control is a component of the selected remedy outlined in this
ROD, the source control technology will be selected in operable unit 3. Source control implemented at the
completion of operable unit 3 will finalize groundwater response actions taken in this ROD and will bring
these actions into compliance with State groundwater protection laws.

Operable unit 3 will be the final response action for this site.

V. Summary of Site Characteristics

Field activities for the RI were conducted from January 1993 to January 1994. These activities included the
performance of soil borings and test pits, installation and sampling of new monitoring wells, sampling of
existing private and ISWS monitoring wells, collection of surface soil samples, a geophysical survey,
sampling of residential wells and indoor air, and soil gas surveys at 14 suspected source areas. These
activities and their corresponding number of sampling points (where applicable) are noted below:

Soil borings (55) Geophysical Survey
-------
Subsurface Soil Samples (116) Residential Wells Sampled (24)
Test Pits (2) Residential Indoor Air Samples (20)
Monitor Well Installations (77) Soil Gas Points (515)
Monitor Well Samples (233)
Surface Soil Samples (10)

The RI concluded that there are four source areas that impact the major plume which constitutes the site (see
page 2). Although several other plumes of contamination were identified, source areas that were found to
have the greatest impact on groundwater guality include; Area 4, Area 7, Area 9/10 and Area 11. A brief
description of each source area and the degree to which it impacts the major plume of contamination is noted
as follows:

Area 4: Located at Marshall Street and Alton Avenue, high concentrations of 1,1,1-trichloroethane (TCA) were
found in soils beneath a parking lot at the Swebco facility. Significant groundwater contamination
downgradient from this facility as well as high levels of TCA, a noncarcinogen, in soil gas were noted in
the RI report. Soil contamination at up to 360 parts per million (ppm) covers approximately 3,750 ft2 and
appears to extend to a depth of 32 feet. Assuming a thickness of 8 feet, the volume of highly contaminated
soil was estimated at 1,100 yd3 with a weight of TCA at 977 pounds. As TCA from the contaminated soils are
water soluble, contaminants from Area 4 are highly mobile in groundwater as evidenced by high levels of TCA
in downgradient wells (Ippm). Residential air sampling has shown migration of TCA vapors from Area 4 into
nearby basements, but at levels which are more of a long-term health concern.

The potential pathways of contaminant migration include groundwater and void spaces in soils (e.g. soil gas).
Surface migration of contaminants is not likely given that most of Area 4 is paved. A table noting Area 4
contaminants and maximum concentrations in both subsurface soils and groundwater is presented on page 9.

Area 7: The most significant source of groundwater contamination in Southeast Rockford. Area 7 was found to
contain extremely high levels of chlorinated and non-chlorinated solvents including TCA (380ppm),
tetrachloroethene (PCE) at 260ppm, trichloroethene (TCE) at 130ppm and xylene (210ppm). Toluene,
ethylbenzene and various degradation products of chlorinated solvents were also found. PCE and TCE are
classified as probable carcinogens. Downgradient monitoring wells have shown significant groundwater
contamination from Area 7 migrating far beyond Eleventh Street. Primary groundwater contaminants associated
with this area include TCA (8ppm) , cis-1,2-dichloroethene (5.9ppm), PCE (1.2ppm) and TCE (0.65ppm) in nearby
downgradient monitoring wells. TCA, PCE and TCE were also found in soil gas at combined levels of up to 5.59
parts per billion (ppb). Based on field screening methods, soil contamination exists to depths of over 47
feet below ground. The volume of soils contaminated with TCA over (O.lppm) was estimated at 260,000yd3
(13,500 pounds of TCA) in the portions of Area 7 that were sampled. Final waste volume estimates in Area 7
will be higher considering that the disposal area extends much farther to the north. Contaminants found in
this area are water soluble and highly mobile in groundwater as evidenced by analyses of groundwater in
downgradient wells. A table noting Area 7 contaminants and maximum concentrations in both subsurface soil
and groundwater is noted on page 9.
-------
VOC Contaminant Concentration Ranges - Area 4

Contaminant Concentration Range Concentration
in Soils (ppb) in Groundwater (ppb)

Benzene BDL-2J BDL
1,1-Dichloroethane BDL 26J
1,1-Dichloroethene BDL 10J
1,2-Dichloroethene(total) BDL 25J
Chlorobenzene BDL-2J BDL
Tetrachloroethene BDL-1J BDL
Toluene BDL-41 43J
1,1,1-Trichloroethane BDL-360,000 1,000
Trichloroethene BDL 28J
Xylene BDL 28J

VOC Contaminant Concentration Ranges - Area 7

Contaminant Concentration Range Concentration Ranges
in Soils (ppb) in Groundwater (ppb)

1,1-Dichloroethane BDL-240J BDL-220J
1,1-Dichloroethene BDL-11J BDL-180J
Chloroform BDL-2J BDL-23
1,2-Dichloroethane BDL-180 BDL-13
1,2-Dichloroethene(total) BDL-49,000 BDL-5,900
Ethylbenzene BDL-31,000 BDL-210
Tetrachloroethene BDL-260,000 BDL-1,200
Toluene BDL-23,OOOJ BDL-170
1,1,1-Trichloroethane BDL-380,000 BDL-8,000
1,1,2-Trichloroethane BDL-7J BDL
Trichloroethene BDL-130,000 BDL-650
Vinyl Chloride BDL BDL-75
Xylene BDL-210,000 BDL-1,100

Contaminants included in these tables include chlorinated VOCs and
the more common non-chlorinated VOCs. Semivolatiles have been
found at both source areas, but were not found to have a
significant impact on groundwater quality. These contaminants
include low concentrations of naphthalene, methylnaphthalene,
phthalates, polyaromatic hydrocarbons, PCBs and pesticides. Areas
4 and 7 were not completely sampled. These source areas will be
further characterized in operable unit 3 (source control).

Notes: BDL - Below Detection Limits
J - Estimated Values
-------
Surface soil samples at Area 7 (inclusive of Ekberg Park) have shown only trace levels of contaminants.
Residential air sampling around Area 7 found only trace levels of contaminants in basements and no
correlation between Area 7 site contaminants and low levels of basement air contaminants was drawn.

The potential pathways of contaminant migration from Area 7 are through groundwater and void spaces in soils.

Area 9/10: An unknown source of groundwater contamination is present in the vicinity north of the Harrison
Avenue/Ninth Street intersection. Downgradient monitoring wells have shown elevated levels of
1,1-dichloroethane (2.1ppm), TCA (0.61ppm) and chloroethane (O.Sppm). 1,1-dichloroethane is a possible human
carcinogen. As is the case in other source areas, these contaminants are highly mobile in groundwater.
Since the location of this source has not yet been identified, potential migration pathways cannot be
determined, although high soil gas readings on an adjacent property might indicate a vapor migration pathway
through soils. The table on page 11 presents a summary of Area 9/10 groundwater contaminants and respective
maximum concentrations.

Area 11: Located east of Eleventh Street and Harrison Avenue, Area 11 is the site of the former Rockford
Varnish facility. Contaminants found in soils near Area 11 include xylene (2,300ppm), toluene (l,400ppm),
ethylbenzene (590ppm) and benzene (l.Sppm) at depths of beyond 40 feet. Benzene is a known human carcinogen.
Chlorinated solvents were not found at Area 11, however the high levels of the above compounds may have
masked the presence of chlorinated solvents in the analyses (e.g. an undiluted concentration of 0.86ppm TCA
from a nearby monitoring well). Area 11 does appear to be a significant source of non-chlorinated VOCs in
groundwater as evidenced by analyses from monitoring wells close to the source area. Contaminants associated
with Area 11 are highly mobile in groundwater. A vapor migration pathway through soils is likely, but has
not been established. A table listing Area 11 contaminants and maximum concentrations in various media are
noted on page 11.

Several other source areas were identified in the RI. These other source areas did not evidently contribute
to the major plume of contamination noted on page 2. Non-contributing source areas found in the RI will be
addressed by other State/Federal environmental programs. The primary constituents of major plume include
TCA, TCE, and PCE plus the degradation products associated with these compounds. Xylene, toluene and
ethylbenzene are also prevalent in portions of this plume and may have fostered accelerated anaerobic
degradation of chlorinated solvents in localized portions of the plume. The RI found site-related
groundwater contaminants present in the upper sand and gravel aguifer, permeating to depths of up to 220 feet
below ground into bedrock. Limited investigations on bedrock characteristics have shown extensive
fracturing. Using reasonable assumptions, groundwater modeling was used to predict future contaminant
concentrations within the plume and to project general plume migration directions.
-------
VOC Contaminant Concentrations ) Area 9/10

Contaminant Concentration Range Concentration Ranges
in Soils (ppb) in Groundwater (ppb)

Chloroethane N/A BDL-500
1,1-Dichloroethane N/A BDL-2,100
1,1-Dichloroethene N/A BDL-410
1,2-Dichloroethane N/A BDL-6J
1,2-Dichloroethene(total) N/A BDL-210
Ethylbenzene N/A BDL-19
Tetrachloroethene N/A BDL-50J
Toluene N/A BDL-420
1,1,1-Trichloroethane N/A BDL-1,400
1,1,2-Trichloroethane N/A BDL-60J
Trichloroethene N/A BDL-140
Vinyl Chloride N/A BDL-14
Xylene N/A BDL-77
VOC Contaminant Concentrations - Near Area 11

Contaminant Concentration Range Concentration Ranges
in Soils (ppb) in Groundwater (ppb)

Benzene BDL-1,500 BDL-23J
Ethylbenzene BDL-590,000 BDL-2,OOOJ
Tetrachloroethene BDL-46 BDL
1,1,1-Trichloroethane BDL-3J BDL-860
Trichloroethene BDL BDL-170J
Toluene BDL-1,400,000 BDL-310,000
Xylene BDL-2,300,000 BDL-9,500

Since the location of Area 9/10 is unknown, contaminant ranges in
soils were not available. Source data for Area 11 is incomplete.
Area 9/10 and Area 11 will be fully characterized in operable unit
3 (source control).

Notes: BDL - Below Detection Limits
J - Estimated Values
N/A - Not Available

All mass and volume figures noted in Section V are rough
estimates and will be refined in the upcoming source area
investigations to be taken in operable unit 3.
-------
TOTAL RISKS AND HAZARD INDEX AT ALTERNATIVE CLEANUP LEVELS
SOUTHEAST ROCKFORD GROUNDWATER CONTAMINATION
Chemical
Concentration
Total Hazard Index
Total Cancer Risk
Methylene Chloride 0.005
1,1-Dichloroethene 0.004
1,1-Dtchloroethane 0.7
Cis-l,2-Dichloroethene 0.01
Trans-l,2-Dichloroethene 0.01
Chloroform 0.00015
1,2-Dichloroethane 0.005
1,1,1-Trichloroethane 0.01
Trichloroethene 0.005
Tetrachoroethylene 0.005

Modified cleanup levels in italics and bold
TOTAL
HAZARD
INDEX
2.9E.03
1.4E-02
6.9E-01
2.9E-02
1.5E-02
4.4E-04
1.7E-01
2.2E-02
1.7E-02
2.1E-02
TOTAL
CANCER
9.8E-01 RISK
7.9E-07
6.IE-05
5.3E-07
2.5E-05

2.0E-06
5.1E-06
9.5E-05
-------
VI. Summary of Site Risks

A human health risk assessment was performed at selected residential wells at the site. The objective of
this assessment was to evaluate current and future exposures associated with potable groundwater usage at the
site in the absence of groundwater remediation. This risk assessment analyzed the toxicity and degree of
hazard posed by site groundwater contaminants and described the probable routes by which they come into human
contact. The complete risk assessment for the site may be found in Section 6 of the RI.

Separate risk estimations were made for site-related compounds that can cause cancer (carcinogens). Risk
estimated for carcinogens was assessed as the additional possibility of developing cancer due to a thirty
year exposure to these compounds in groundwater averaged over a lifetime of seventy years. The National
Contingency Plan (NCP) establishes acceptable levels of risk for Superfund sites ranging from 1 in 10,000 (1
x 10-4) to 1 in one million (1 x 10 excess cancer cases. "Excess" means the number of cancer cases in
addition to those that would ordinarily occur in a population of that size due to non site-related factors.
For non-cancer cases in compounds, a risk estimation known as the "hazard index" is used. Typically, hazard
indices below 1 indicate that no adverse health effects are expected, while values greater than 1 are
indicative of possible adverse health effects. The "Contaminants of Concern" evaluated in the risk
assessment are noted below:

Methylene chloride Chloroform
1,1-Dichloroethene 1,2-Dichloroethane
1,1-Dichloroethane 1,1,1-Trichloroethane
cis-1,2-Dichloroethene Trichloroethene
trans-1,2-Dichloroethene Tetrachloroethene

Twenty-four residential wells were sampled in the RI to determined if the contaminant plume had migrated into
areas where resident wells still existed. The wells that were sampled were located the margins of the plume
and were expected to have the higher concentrations of site-related contaminants. Concentration range of
these contaminants in residential wells are noted on page 13

To evaluate potential current and future threats to human health risk estimates were developed for domestic
usage of groundwater downgradient from identified source areas. Exposure routed considered in this scenario
include:

1. Ingestion of groundwater from residential wells.

2. Dermal contact with groundwater from residential wells through showering.

3. Inhalation of site-related contaminants which volatilized
from residential wells during and immediately after showering.
-------
CHEMICALS DETECTED IN RESIDENTIAL WELLS
Compound
Frequency of
Detection
(24 wells total)
Methylene Chloride 2/24
1,1-Dichloroethene 5/24
1,1-Dichloroethane 12/24
C-l,2-Dichloroethene 5/24
Trans- 1,2-Dichloroethene 1/24
Chloroform 8/24
1,2-Dichloroethane 2/24
1,1,1-Trichloroethane 20/24
Trichloroethene 20/24
Tetrachloroethene 15/24
Range of
Detected
Concentrations
Cg/D

0.2J - 0.4J
0.3J - 5
0.1J - 15
1-10
0.2J
0.2J - 0.5J
0.5J - 0.6J
0.6J - SOD
0.2JB - 8
0.2J - 4
Range of
Detected
Concentrations
(ms/1).

0.00021 - 0.00041
0.0003J - 0.005
0.0001J - 0.015
0.001 - 0.010
0.0002J
0.0002J - 0.0005JD
0.0005J - 0.0006J
0.0006J - 0.050D
0.0002JB - 0.008
0.0002J - 0.004
Range of
Detection
MCL
Limits
C
2
1
1
1
1
1
1
1
1
1
g/D
- 10
- 5
- 5
- 5
- 5
- 5
- 5
- 5
- 5
- 5
Cg/D
_
0.007
-
0.07
0.01
0.10*
0.005
0.2
0.005
0.005
Illinois
Groundwater
Qualily Standards
Class I (mg/1)
_
0.007
-
0.07
0.01
-
0.005
0.2
0.005
0.005
Notes:
*: For trihalomethanes
Table does not include detections for field blanks, trip blanks, or duplicate samples.
J: Estimated Value
B: Blank Contamination
D: Dilution
-------
Risks associated with inhalation of indoor air potentially impacted by vapor migration from groundwater
and/or soils near identified source areas were gualitatively evaluated in this risk assessment. These risks
will be evaluated in the upcoming source area RI.

The toxicity assessment involved an analysis of the toxicological properties of the Contaminants of Concern.
Two types of toxicity values are used to guantify the toxic effects of a chemical on human health. They are
the chemical's cancer slope factor and the chemical's reference dose. Slope factors estimate excess lifetime
cancer risks associated with exposure to potential carcinogens and are multiplied by the estimated intake of
a potential carcinogen to provide an upper-bound estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper-bound" reflects the conservative estimate of the risks
calculated from each slope factor. Use of this approach makes underestimation of the actual cancer risk
highly unlikely. Slope factors are derived from the results of human epidemiological studies or chronic
animal bioassays to which animal-to-human extrapolation and uncertainty factors have been applied.
Reference doses (RfDs) indicate the potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. RfDs are estimates of lifetime daily human exposure levels that include
sensitive populations. Estimated intakes of contaminants from groundwater were compared with the RfD. As
was the case with slope factors, RfDs are derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied. These factors help ensure that the RfDs will not underestimate
the potential for adverse noncarcinogenic health effects to occur.

With respect to the Contaminants of Concern, a table of the carcinogenicity classification is provided below:
Compound

Methylene Chloride
1,1-Dichloroethene
1,1-Dichloroethane
cis-1,2-Dichloroethene
trans-1,2-Dichloroethene
Chloroform
1,2-Dichloroethane
1,1,1-Trichloroethane
Trichloroethene
Tetrachloroethene
Carcinogenicity Classification

B2
C
C
D
(no data)
B2
B2
D
C-B2
C-B2
USEPA separates chemicals into five distinct categories ranging from Group A (known human carcinogens) to
Group E (noncarcinogens). Group Bl indicates limited human data is available to characterize a specific
compound as a probable carcinogen, while B2 indicates sufficient evidence of carcinogenicity in animals but
with little or no evidence in humans. Group C indicates a possible human carcinogen and Group D notes that a
chemical is "not classifiable as to human carcinogenicity". The health effects of these chemicals
of concern are noted in Table 6-4 of the RI report. The compounds methylene chloride,
trans-1,2-Dichloroethene, chloroform and 1,2-dichloroethene were not detected above reguired laboratory
detection limits.

No residential wells that were sampled had total carcinogenic risks exceeding 1 x 10-4, which is the upper
limit identified in the NCP. Four wells had total carcinogenic risks in the 1 x 10-5 range and nine homes has
carcinogenic risks in the range of 1 x 10-6. All other wells had total carcinogenic risks below 1 x 10-6.
The primary contaminant contributing to total carcinogenic risks was 1,1-dichloroethene with ingestion being
the dominant exposure pathway contributing to risks. Hazard indices for sampled wells were all below 1,
indicating that the increased risk from exposure to noncarcinogenic contaminants is minimal. At one
location, the Safe Drinking Water Act Maximum Contaminant Level (MCL) for TCE was exceeded. Table 6-19 and
Table 6-20 of the RI report note total cancer risks and hazard indices for each household.

Uncertainties inherent in the risk assessment process cannot be fully eliminated. The assumptions that have
been made tend to be conservative, resulting in what may be an over-estimation of the actual risk from
groundwater at the site. Types of uncertainty include scenario uncertainty (information used to define
site-specific exposures and doses), parameter uncertainty (assumptions/parameters used in concentration, dose
and risk calculations) and model uncertainty (future exposure estimates based on scientific projections.
Parameter uncertainty appears to have had the greatest impact in this risk assessment because of a rather
incomplete data set (23 residential wells sampled out of an estimated 600) and the lack of slope factors for
site-related contaminants that have not been adeguately assessed.
Investigations performed to date do not indicate that site-related groundwater contaminants are adversely
-------
impacting the environment. Although an ecological assessment relative solely to groundwater impacts has not
been performed at this site, the most probable location of environmental exposure would be the Rock River.
Current site data indicates that the site plume has not reached the river. Groundwater modeling estimations
discussed later in this text note that the plume may have a minimal impact on the river. Endangered species
or habitats of endangered species affected by site-related groundwater contaminants have not been identified
in the RI.

The human health risk assessment for this site was prepared in accordance with all USEPA risk assessment
guidance documents including the Risk Assessment Guidance for Superfund (December 1989).

VII. Description of Alternatives

Five response action alternatives were considered in the FS to address groundwater contamination at the
Southeast Rockford Site. All remedies assume further source control and the continued operation of the GAG
unit at UW35. They include the following:

! Alternative 1: No Action
! Alternative 2a: Use Restrictions
! Alternative 2b: Limited Action
! Alternative 3a: Groundwater Extraction and Air Stripping with Offsite Disposal
! Alternative 3b: Groundwater Extraction and Air Stripping with Onsite Discharge

Alternative 1 - No Action

The "No Action" alternative is used to establish a baseline for comparison with other alternatives. This
alternative's inclusion in the analysis of remedial alternatives is mandated by CERCLA. No response measures
would be implemented in this alternative, however pursuant to CERCLA Section 121(c) (e.g. source materials
being left in place) groundwater monitoring will be necessary and as such, was included as a component of
this alternative. Under this alternative, groundwater will be monitored at selected existing and new
monitoring wells on a guarterly basis for the next 205 years. Groundwater modeling has shown that contaminant
levels for TCA in the plume will remain at levels above its MCL of 200ppb for 205 years assuming that source
areas will undergo remediation. Other groups of compounds such as the dichloroethenes and vinyl chloride may
necessitate a further time extension for monitoring if the concentrations of them in groundwater are expected
to degrade at levels below their respective MCLs.

Cost estimates have included the installation and sampling of four pairs of new groundwater monitoring wells
and one additional well upgradient of a large area of existing residential wells. 35 existing monitoring
wells would be monitored on a guarterly basis for 205 years. The overall costs of Alternative 1 (No Action)
are noted below:

CAPITAL CONSTRUCTION COST $34,000
ANNUAL O&M COST $55,000
PRESENT WORTH COST (at 5% for 205 years) $1,124,000

Alternative 2a - Use Restrictions

This alternative includes controls to restrict public usage of (and therefor exposure) to site-related
contaminated groundwater in conjunction with the guarterly monitoring components of Alternative 1. Usage of
groundwater will be restricted within the modeled 70 year TCA/DCA contaminant plume plus a "buffer zone" by
providing all households and businesses with potable use wells an opportunity to hook up to city water (see
map on page 17). Because of their prevalence in groundwater at the site, TCA and DCA were modeled to
simulate a lifetime exposure. Other less common (and more toxic) groundwater compounds, while not having
been modeled in the RI, are expected to exist within this 70 year TCA/DCA plume and buffer zone. The use of
these contaminants in groundwater modeling will result in a conservative determination as to the number of
hookups that would be offered in this remedy.

As long-term monitoring of the plume may indicate that additional wells could become contaminated by
site-related compounds at levels possibly causing adverse health effects, additional homes and businesses may
receive hookups at a later date. Water main extensions on streets where private wells are present in areas
adjacent to the site were included in this remedy because of the potential for future hookups. The basis for
future hookups will be either MCLs, or a periodic evaluation of the groundwater modeling program that
-------
determined the area of initial hookups in this remedy, whichever is more protective of human health.

Further remediation at the identified source areas and the continued use of the GAG unit installed at the
municipal well identified in operable unit 1 were included in this alternative but no costs were provided
because additional work is needed at the source areas to quantify contamination and select appropriate
treatment technologies. All homes and businesses receiving hookups set forth by this remedy will be
compelled to abandon their potable use wells in accordance with State laws. Water quality for those
receiving hookups would be guaranteed by the City of Rockford's extensive monitoring program.

The primary goal of this alternative is the protection of human health. The aquifer will not be actively
restored to drinking water quality, but passive restoration is expected to occur over an extended period of
time. As such, the principal component of treatment in this remedy will be natural attenuation. Groundwater
modeling performed in the RI shows that over time, site-related compounds will degrade in groundwater
assuming that the continued contribution of these compounds from identified source areas is eliminated.
With future source area remediation being a component of the selected remedy, at least 211 billion gallons of
groundwater would undergo treatment by natural attenuation. Because restoration of the aquifer is expected
to be a long-term action in this remedy, only a small incremental reduction of site-related groundwater
contaminants is expected on an annual basis.

Since the sand/gravel and bedrock aquifers are used for potable purposes, groundwater at the site is in the
"Class I" category under State law. Complete aquifer restoration is a remedial action objective in this
remedy and restoration of site-related groundwater contaminants to MCLs and State groundwater quality
standards will be sought through natural attenuation in this remedy and by more active means in the upcoming
source control remedy (operable unit 3).

This remedy will rapidly eliminate current and potential human health risks to site-related contaminants for
homes and businesses that accept hookups provided by this remedy. Although acceptance of a hookup is not
guaranteed, a rigorous education effort will be implemented to convince individuals of the protectiveness of
this remedy. Education efforts have been largely successful in the past where hookups to city water were a
main component of past remedies (operable unit 1) at this site. Institutional controls that can be
implemented to further compel those refusing hookups will include a formal notification from the Winnebago
County Health Department (WCHM) that the particular property has a contaminated well from site-related
compounds. All property transactions in Winnebago county require well inspections and in the event of a
contractual property transaction, this notification would be provided to both the owner of property with the
contaminated well as well as the potential buyer. A list of those refusing hookups after the remedy has been
fully implemented will be submitted to the WCHD.

Given that source controls will be taken at a later date, actions implemented in this remedy will assure that
the groundwater quality standards set forth in 35 IAC 620 are met. The monitoring program will be consistent
with 35 IAC 620.505 and 35 IAC 620.510.

In addition, a Groundwater Management Zone (GMZ) as defined in 35 IAC 620.250 will be defined at each
identified source area upon completion of the source control remedy. At the edge of each GMZ, a point of
compliance for groundwater contaminant levels will be established. A remedial alternative to reasonably
address groundwater contamination at that point will be defined in the upcoming source control remedy.

This remedy complies with the Safe Drinking Water Act. Modeling estimations have noted that the time at
which this remedy will be compliant with this law will exceed 205 years.

Cost estimations for this remedy include all aspects of the monitoring components of Alternative 1, 21,000
feet of 8" water main, and 400 city water service connections. The overall costs of Alternative 2a (Use
Restrictions) is noted below:

CAPITAL CONSTRUCTION COST $2,016,000
ANNUAL O&M COST $65,000
PRESENT WORTH COST (at 5% for 205 years) $3,314,000

Alternative 2b - Limited Action

The "Limited Action" alternative entails all of the elements of Alternative 2a mentioned above, plus a
provision to perform active groundwater extraction and treatment on a portion of the site plume. Under this
alternative, contaminated groundwater from identified source areas primarily responsible for contaminants in
residential wells abandoned in previous actions (see Section II of this document) would be remediated.
-------

A nest of four groundwater extraction wells would be located along Seventeenth Street between Harrison Avenue
and Reed Avenue (see map on page 20). Each well rated at 250gpm (l,000gpm total) would be completed in the
sand/gravel and bedrock aguifers in 400 foot spacings at depths ranging from 154 feet to 185 feet below
ground surface. Assuming source control, pumping would continue for a period of 125 years at which time the
MCL for TCA would be achieved (a similar conclusion about extended treatment times for compounds other than
TCA/DCA drawn about monitoring can made here also). The technology selected for treatment of the groundwater
was air stripping. Off-gas treatment was not determined to be necessary in the air stripping process and
treated effluent meeting State water guality standards would be discharged into a nearby storm sewer.

In addition to the protectiveness of human health inherited from Alternative 2a, the main objective of this
remedy is to achieve aguifer restoration in a shorter period of time. Principal components of treatment in
this remedy include natural attenuation and active remediation of groundwater. Based on future source area
remediation in this remedy, the volume of contaminated groundwater to be actively treated would exceed 66
billion gallons. The remainder of groundwater would be treated by natural attenuation. Reduction rates of
site-related groundwater contaminants are somewhat higher than in Alternative 2 because active groundwater
treatment is being sought in this remedy. These rates are still expected to be low because only a portion
of the plume is being treated. Since complete aguifer restoration is a remedial action objective in this
remedy, restoration of site-related contaminants to MCLs will be sought through natural attenuation and
active means as well as by additional active means in the upcoming source control remedy of operable unit 3.

Institutional controls relative to residential hookups (mentioned in Alternative 2a) would be applicable in
this remedy also.

Assuming source controls will be taken at a later date, actions implemented in this remedy will assure that
groundwater guality standards set forth in 35 IAC 620 are met. The monitoring program will be consistent
with 35 IAC 620.505 and 35 IAC 620.510. GMZs as defined in 35 IAC 620 will be defined at each identified
source area upon completion of the source control remedy. A treatment technology to reasonably address
groundwater contamination at a point of compliance defined at the edge of the GMZ will be established in the
upcoming source control remedy.

The remedy complies with the Safe Drinking Water Act. Modeling estimations have noted that the time at which
this remedy will be in compliance with this law will exceed 125 years.

Wastewater discharges from the air stripping process would be subject to the National Pollutant Discharge
Elimination System (NPDES) of 40 CFR Part 122, which in Illinois is implemented pursuant to 35 IAC 309.
Treated effluent from the four extraction wells would be subject to the water guality standards of 35 IAC 302
and 35 IAC 304. The treatment works process would be operated under the supervision of a certified operator
pursuant to 35 IAC 312 and the air stripper process would be subject to 40 CFR Part 264, Part AA under the
authority of the Resource Conservation and Recovery Act (RCRA), which limits organic emissions. Residues
from the treatment processes would be tested to determine if they are RCRA hazardous pursuant to 40 CFR Part
261 in order to determine proper disposal methods. Treatment process residuals outlined in this remedy are
not expected to be generated.

Cost estimations for this remedy include all aspects of the components outlined in Alternative 2a (Use
Restrictions) plus costs associated with the construction of four groundwater extraction wells, an
egualization basin and an air stripper treatment process. The overall cost of Alternative 2b (Limited Action)
is noted below:

CAPITAL CONSTRUCTION COST $3,002,000
ANNUAL O&M COST $351,000
PRESENT WORTH COST (at 5% for 125 years) $10,021,000

Alternative 3b - Groundwater Extraction and Air Stripping with Offsite Disposal

Under this remedy, all of the elements of Alternative 2a would apply. Full-scale groundwater extraction and
treatment in the aguifer would be sought in this remedy to achieve State water guality standards and the
standards of the Safe Drinking Water And in the shortest period of time. This remedy seeks to aggressive
remediate site-related groundwater contaminants while assuming the source controls are to be implemented at a
later date.

Twenty-two groundwater extraction wells will be installed in five separate nests throughout the site as part
-------
of Alternative 3a (s map on page 23). To achieve treatment of groundwater to State and Federal drinking
water standards, these wells would intercept estimated 211 billion gallons of contaminated groundwater at the
combined rate of 5,347gpm for approximately 75 years when the M for TCA is reached (see assumptions of
Alternative 2a regarding extended treatment times for compounds other than TCA and DCA Off-gas treatment
(carbon treatment) of organic emissions from and stripping operations at two extraction wells located at
Harris Avenue and Kinsey Street would be necessary because of locally high concentrations of Area 11-related
contaminants in the plume.

Two well nests located east of Twentieth Street would be completed in the sand/gravel and bedrock aguifers at
depths ranging from 1 feet to 204 feet below ground surface. Pumping rates for the nest of five wells near
Area 7 and the four wells just east of Twentieth Street would be 70gpm and 250gpm, respectively. The other
three well nests would be completed in the sand/gravel aguifer at depth ranging from 90 to 133 feet below
ground surface. Pumping rates for the four extraction wells located just west of Eleventh Street would be
250gpm, while the two well nests (nine wells total closest to the Rock River would be rated at 333gpm.

In addition to the protectiveness of human health elements from Alternative 2a, the main objective of this
remedy is to achieve aguifer restoration in the shortest period of time. Principal treatment components of
this remedy include natural attenuation and active remediation of groundwater. Based on future source area
remediation, the estimated volume of contaminated groundwater to be treated will exceed 211 billion gallons.
Reduction rates of site-related groundwater contaminants are the highest in all remedies that were evaluated.

Since complete aguifer restoration is a remedial action objective in this remedy, restoration of site-related
contaminants to MCLs will be sought through natural attenuation and active means as well as by additional
active means in the upcoming source control remedy of operable unit 3. Institutional controls relative to
residential hookups (mentioned in Alternative 2a) would be applicable in this remedy also.

Assuming source controls will be taken at a later date, actions implemented in this remedy will assure that
groundwater guality standards set forth in 35 IAC 620 are met. The groundwater monitoring program will be
consistent with 35 IAC 620.505 and 35 IAC 620.510. GMZs as defined in 35 IAC 620 will be identified at each
identified source area upon completion of the source control remedy. A treatment technology to reasonably
address groundwater contamination at a point of compliance defined at the edge of the GMZ will be established
in the upcoming source control remedy.

This remedy complies with the Safe Drinking Water Act. Modeling estimations have noted that the time at
which this remedy will be in compliance with this law will exceed 75 years.

Wastewater discharges from the air stripping processes would be subject to the NPDES program of 40 CFR Part
122, which in Illinois is implemented pursuant to 35 IAC 309. Treated effluent from the twenty-two
extraction wells would be subject to the water guality standards of 35 IAC 302 and 35 IAC 304. The treatment
works process would be operated under the supervision of a certified operator pursuant to 35 IAC 312 and the
air stripper process would be subject to 40 CFR Part 264, Part AA under RCRA. As spent carbon from the
off-gas treatment subprocess at two extraction wells would be shipped off-site for regeneration, this
material will be manifested and transported to an approved regeneration facility pursuant to RCRA
reguirements. Residuals excluding spent carbon would be tested to determine if they are RCRA hazardous
pursuant to 40 CFR Part 261 in order to determine proper disposal methods. Residuals excluding spent carbon
are not expected to be generated in this remedy.

Cost estimations for this remedy include all aspects of the components outlined in Alternative 2a (Use
Restrictions) plus extra costs associated with the construction of twenty-two groundwater extraction wells,
six egualization basins, six air stripping units, and one GAG off-gas treatment unit. The overall costs of
Alternative 3a are noted on the following page:

CAPITAL CONSTRUCTION COST $8,276,000
ANNUAL O&M COST $2,174,000
PRESENT WORTH COST (at 5% for 75 years) $50,723,000

Alternative 3b - Groundwater Extraction and Air Stripping with Onsite Discharge

This alternative is identical to Alternative 3a, with the exception that treated effluent (which would meet
standards set forth in the Safe Drinking Water Act) would be distributed to the city's municipal water supply
system and sold for potable reuse.
-------
In addition to the components of Alternative 3a, this alternative would entail the construction of a
distribution system to deliver potable water from treatment units at each of the five extraction well nests
to the city's water supply system. This distribution system would include all necessary piping and six
ISOpsi booster pumps to deliver treated groundwater to the nearest municipal water main capable of handling
the average design flow of effluent from each treatment system.

Cost estimations for this remedy include the well construction and treatment components of Alternative 3a
plus all elements of the distribution system mentioned above. Since treated groundwater meeting Federal
drinking water standards will be sold to the city a significant offset in treatment costs was assumed. For
costing purposes, it was assumed that treated groundwater sold to the city would generate $0.50 of revenue
per 1000 gallons treated over the life of the 75 year pumping effort. The overall cost to Alternative 3b
(Groundwater Extraction and Air Stripping with onsite discharge) is noted below:

CAPITAL CONSTRUCTION COST $14,314,000
ANNUAL O&M COST $310,000
PRESENT WORTH COST (at 5% for 75 years) $20,362,000

VIII. Summary of the Comparative Analysis of Alternatives

The Superfund program reguires evaluation of alternatives based on nine criteria by which technical, economic
and practical factors associated with each response action alternative must be judged The nine criteria are
categorized into three groups: threshold criteria, primary balancing criteria and modifying criteria. The
nine evaluation criteria are summarized as follows:

Threshold Criteria - These must be satisfied in order for an alternative to be eligible for a final remedy
selection.

1. Overall Protection of Human Health and the Environment - This criteria addresses whether a remedy
provides adeguate protection of human health and the environment and describes how risks posed through each
exposure pathway are eliminated, reduced, controlled through treatment or engineering/institutional controls.

2. Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs) - This criteria addresses
whether a remedy will meet all of the ARARs of other Federal and State environmental laws and/or justifies a
waiver.

Primary Balancing Criteria - These criteria are used to weigh major tradeoffs among evaluated alternatives.
They include:

3. Long-Term Effectiveness and Permanence - A criteria concerned with the residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment over time, after cleanup goals
have been met.

4. Reduction of Toxicity, Mobility or Volume through Treatment) The anticipated performance of the treatment
technologies a remedy may employ.

5. Short-Term Effectiveness - Addresses the period of time needed to achieve protection and any adverse
impacts on human health and the environment that may be posed during the construction and implementation
period until cleanup goals are achieved.

6. Implementability - The technical and administrative feasibility of a remedy, including the availability
of materials and services needed to implement a particular remedy.

7. Cost)Includes estimated capital and operation and maintenance costs also expressed as net present worth
costs.

Modifying Criteria - These criteria are usually taken into account after public comment is received on the FS
report and the Proposed Plan. They include the following:

8. State/Support Agency Acceptance - Reflects aspects of the preferred alternative and other alternatives
that the support agency favors or objects to, and any specific comments regarding State ARARs or the proposed
use of waivers.
-------
9. Community Acceptance - Summarizes the public's general response to the alternatives described in the
Proposed Plan and in the FS report based on public comments received. Evaluations under this criteria will
not be completed until after the public comment period has ended.

An assessment of the relative performance of all five alternatives by highlighting the key differences among
the alternatives in relation to the nine evaluation criteria is presented below:

Overall Protection of Human Health and the Environment

Alternatives 2a, 2b, 3a and 3b all provide protection of human health by virtually eliminating current and
future exposures to site-related contaminants in groundwater at levels above MCLs. This was accomplished by
offering municipal water service connections to all individuals with potable use wells having exceedances of
MCLs in the current plume as well as those wells inside a 70 year modeled plume and buffer zone. This
modeling was performed to assess future exposures to site-related groundwater contaminants. Alternative 1
provides no protection of human health.

Alternatives 2a, 2b, 3a and 3b all provide adeguate protection of the environment through varying degrees of
natural attenuation and active treatment/future containment. Groundwater modeling has shown that the
contaminant plume will not have an appreciable effect on the Rock River whether or not active groundwater
extraction and treatment measures are implemented as long as future source control measures are part of any
remedial alternative.

Compliance with Applicable or Relevant and Appropriate Requirements

All of the evaluated alternatives, with the exception of Alternative 1, would comply with chemical-specific,
action-specific and location-specific ARARs provided that future source area remediation is undertaken and
that aguifer restoration is a remedial action objective. These two assumptions mere made for Alternatives
2a, 2b, 3a and 3b. ARARs would be attained on the shortest timeframe (75 years) for Alternatives 3a and 3b.
ARARs would be attained in 125 years for Alternative 2b, while 205 years would be reguired for Alternative 2a
to meet ARARs.

Long-Term Effectiveness and Permanence

Alternatives 2a, 2b, 3a and 3b will eliminate the residual risk associated with contaminated groundwater if
identified private well owners accept hookups as noted in the four above-mentioned remedies. The city has an
extensive monitoring program designed to control water guality in their distribution system, which will
replace current and future-contaminated residential and commercial wells as a source of potable water.
Alternative 1 does not provide any measure of long-term effectiveness or permanence.

Reduction of Mobility, Toxicity, or Volume through Treatment

Alternatives 3a and 3b offer the greatest reduction of mobility, toxicity and volume of groundwater
contaminants through treatment. Similar results are expected with Alternative 2b, but to a lesser degree for
reductions in mobility and volume. When implemented, the source control components of Alternatives 2a, 2b,
3a and 3b will generally have a greater impact on reduction of mobility, toxicity and volume of groundwater
contaminants through treatment. Alternative 1 offers no reduction in mobility, toxicity or volume of
groundwater contaminants through treatment.

Short-Term Effectiveness

Implementation of any alternative involves a small measure of human risk. Alternative 1 offers only a
minimal amount of risk (e.g. exposures to groundwater contaminants or construction hazards aspart of drilling
activities of new monitoring wells). Alternative 2a offers a slightly higher risk (e.g. construction
activities associated with watermain extensions and service connections). Alternative 2b has a somewhat
higher short-term risk (e.g. additional construction activities associated with the installation of
extraction wells and treatment units). Alternatives 3a and 3b possess the highest short-term risks (e.g.
construction activities of more extraction wells and treatment units). Short-term environmental risks
exist, such as an inadvertent creation of a conduit for downward flow of contaminants associated with
drilling activities in all of the evaluated alternatives. On the whole, the probability of this occurring is
minimal.

Alternative 1 can be implemented most readily (six months), followed by Alternatives 2a and 2b (18 months).
Alternative 3a would take about two years to implement, while Alternative 3b would take about 2.5 years.
-------
Implementabili ty

Materials, labor and equipment needed to implement all of the alternatives are readily available and
construction/installation techniques are fairly routine. Alternative 1 possesses the hiqhest deqree of
implementability followed by Alternatives 2a, 2b and 3a. Alternative 3b would be the most difficult to
implement based on additional water main constructions for water distribution from six treatment units and
the modifications that would be necessary in the city's water distribution network to accept this water.

Cost

Present net worth costs for the evaluated alternatives ranqe from $1,124,000 in Alternative 1 to $50,723,000
in Alternative 3a. A rather complex network of extraction wells and an exceedinqly hiqh volume of
contaminated qroundwater treated over an extended period of time are responsible for the hiqher costs of
Alternative 3a.

State/Support Agency Acceptance

USEPA Reqion V, as desiqnated support aqency for this site, concurs with the Illinois Environmental
Protection Aqency's recommendation of Alternative 2a (Use Restrictions) as the selected remedy for the
Southeast Rockford Groundwater Contamination Site.

Community Acceptance

The public has been qiven the opportunity to review and comment on the FS report and Proposed Plan within a
thirty day public comment period. Two public meetinqs and two formal public hearinqs were held for the
qeneral public to ask questions and provide comments that relate to all of the evaluated alternatives.
Community acceptance of the preferred remedy has been qenerally favorable. All comments, written and oral,
compiled durinq the comment period for the FS and Proposed Plan as well as responses to these comments are
noted in the Responsiveness Summary (see Attachment A).

IX. The Selected Remedy

Based on the consideration of the requirements of CERCLA, the detailed analysis of alternatives and public
comments, both IEPA and USEPA Reqion V have determined that Alternative 2a is the most appropriate
qroundwater response remedy for the Southeast Rockford Groundwater Contamination Site. This alternative
essentially restricts the usaqe of qroundwater as a potable water source at the site. In addition, with
source controls beinq a component of Alternative 2a, this remedy will offer a combination of natural
attenuation and probable containment as a remedy to site-related contaminated qroundwater in the sand/qravel
and bedrock aquifers.

A summary of the major components of the selected remedy is shown below. In-depth discussions of these
components were presented in Section VII (paqes 16 throuqh 19) of this document.

! Groundwater Monitorinq for 205 years
! Water Main Installations
! Service Connections for Selected Private Potable-Use Wells
! Future Service Connections for Remaininq Potable-Use Wells
! Continued Operation of GAG Unit at Municipal Well UW-35
! Future Source Control Measures at Four Identified Source
Areas of Groundwater Contamination
! Institutional Controls

Given that future source controls are assumed in this remedy, the actual deqree to which qroundwater is
remediated under this remedy is dependant on the extent to which the four identified source areas are
remediated. These further actions are necessary to assure that the selected remedy meets the two threshold
criteria of remedy selection. Aquifer restoration will take place over an extended period of time under this
remedy.

lEPA's basis for remediation qoals are ARARs that include the Safe Drinkinq Water Act, and the Illinois
Groundwater Protection Act. Correspondinq risks associated with hypothetical exposures to a mixture of
detected qroundwater contaminants at ARAR concentrations (or risk-based concentrations in the absence of an
ARAR concentration) were calculated. Total cancer risks at (1.3 x 10-4 only sliqhtly exceeded USEPA's
acceptable risk ranqe of 1 x 10-6 to 1 x 10-4. Althouqh this findinq indicated a minimal residual risk
-------
outside of the acceptable risk range, USEPA guidance states that compliance with chemical-specific ARARs is
generally considered protective. A similar calculation was likewise performed to compare hypothetical
noncarcinogenic risks to ARAR concentrations. A calculated hazard index of 1.8 was only slightly over the
hazard index cutoff of 1, thereby indicating a slight residual risk. Because both of these calculations
indicated residual risks present, alternative cleanup levels were developed for this remedy. These
alternative cleanup levels are presented in Appendix A.
Capital cost assumptions for Alternative 2a are presented below:
Component
Monitoring Well
Installations
Quantity
Unit Cost
$2,778
Total Direct
Capital Cost

$25 000
Water Main
Installations

City Water Service
Connections

Future Service
Connections

Operation of GAG Unit
at Municipal Well UW-35

Source Control Measures
(Operable Unit 3)

Institutional Controls
21,000'
400
$50/LF
$1,000
Total Direct Capital Costs
Engineering/Design Costs @15%
Contingencies @15%
Other Indirect Costs (Legal Fees
and Regulatory License Costs)
Total Indirect Capital Cost

TOTAL CAPITAL COST:
$1,058 000
$400 000
0

$1,483,000

$222,000
$222,000

$89,000

$533,000

$2,016,000
-------
The annual operation and maintenance (O&M) costs for Alternative 2a are presented below:
Component
Unit Cost
Total Direct
Annual O&M Costs
Present Worth O&M
Annual Costs
Groundwater
Monitoring
at 35 wells
$300
$42,000
$840,000
Water Mains
O&M

City Water Service
Connections

Future Service
Connections
5. Operation of GAG Unit
at Municipal Well UW-35

6. Source Control Measures
(Operable Unit 3)

7. Institutional Controls
0

$8,400
$168,000
Total Direct Annual/Periodic
Present Net Worth O&M Costs
$1,038,000
Administrative, Insurance,
Tax and License Costs @10% of
Direct Annual O&M Costs

Maintenance Reserve and
Contingency Costs @15% of
Direct Annual O&M Costs
$5,200 $52,000
$7,800 $156,000

Total Indirect Annual/Periodic
Present Net Worth O&M Costs $260,000

TOTAL ANNUAL/PERIODIC PRESENT
NET WORTH COSTS $1,298,000
Total costs for Alternative 2a are defined as the total of the
capital costs plus annual/periodic present net worth costs.

TOTAL CAPITAL COSTS $2,016,000
TOTAL ANNUAL/PERIODIC PRESENT NET WORTH COSTS $1,298,000

TOTAL PRESENT WORTH COSTS FOR ALTERNATIVE 2a $3,314,000
-------
The selected remedy for this site is the same preferred alternative presented in the Proposed Plan developed
and issued by the IEPA. Details regarding components of this remedy may be altered as a result of the
remedial design and actual number of water service hookups that will be performed. Under a fund-lead
pretext, the IEPA will continue to provide direct oversight of design, construction and long-term remedial
action aspects as sought by this selected remedy.

X. Statutory Determinations

The selected remedy satisfies the requirements of Section 121 of CERCLA, which are to protect human health
and the environment; comply with ARARs; be cost effective; utilize permanent solutions and alternate
treatment technologies to the maximum extent practicable; and satisfy the preference for treatment as
principle element of the remedy.

Protection of Human Health and the Environment

Implementation of the selected remedy will reduce and control potential risk to human health from exposure to
site-related groundwater contaminants both now and in one lifetime by providing individuals with potable-use
wells with a safe and reliable alternative source of drinking water. The remedy will reduce risk to within
the acceptable range of 1 x 10-4 to 1 x 10-6 excess cancer risk and hazard indices for noncarcinogens will be
less than one. To the extent that groundwater monitoring indicates future unacceptable risks associated with
exposure to groundwater contaminants, additional hookups to city water will be providing under this remedy.

The selected remedy will reduce and control potential groundwater risks to the environment through future
source control component of this remedy. Groundwater modeling as performed in the indicates that the
environment (e.g. the Rock River) will not impacted significantly if source controls are implemented at each
of the identified source areas. Source area controls will implemented at Area 4, Area 7, Area 9/10 and Area
11 as part operable unit 3.

No unacceptable short-term risk or cross-media impacts will caused by implementation of the selected remedy.

Compliance with ARARs

With respect to hazardous substances, pollutants, or contaminants that will remain on site, Section 121 (2)
(A) of CERCLA required that the selected remedial action be compliant with all applicable or relevant and
appropriate requirements or a waiver must justified. The selected remedy will comply with Federal ARARs
State ARARS (where State ARARs are determined to be more stringent). ARAR waivers required at this time have
not been identified. "To Be Considered" (TBC) criteria are included in the discussion of ARARs; however TBCs
are not ARARs. They may be used to design a remedy or set up cleanup levels if no ARARs address the site or
if existing ARARs do not ensure protectiveness. TBCs may include advisories or guidances, for example.

A listing and brief discussion of the three major groups of ARARs that will be attained by the selected
remedy is provided here.

Chemical-Specific APARs: Chemical-specific ARARs regulate the release of specific substances to the
environment that have certain chemical and toxicological characteristics.

! Safe Drinking Water Act (SDWA) National Primary Drinking Water
Standards (40 CFR Part 141), MCLs are applicable and proposed
MCLs are to be considered.

! Safe Drinking Water Act (SDWA) National Primary Drinking Water
Standards (40 CFR Part 141) non-zero MCLGs are applicable and
non-zero proposed MCLGs are to be considered.

! Illinois Groundwater Quality Standards (35 IAC 620.410) are
applicable groundwater standards.

Location-Specific ARARs: Location-specific ARARs are those requirements that relate to the geographic
location of the site.

! Federal Endangered Species Act of 1973, as amended. This Act
requires that actions must be performed to conserve endangered or
threatened species located in and around the site. Activities
-------
carried out under any action must not destroy or adversely modify
the critical habitat upon which endangered species depend.

Action-Specific ARARs: Action-specific ARARs are requirements that define acceptable treatment and disposal
requirements for hazardous substances. Substantive requirements of the following may be ARARs.

! Resource Conservation and Recovery Act (RCRA) at 40 CFR Part 261
is applicable for identification of hazardous wastes (e.g. spent
carbon from GAG at UW-35) for identifying proper disposal of
wastes and may be relevant and appropriate for sampling
activities; delegated program in Illinois is implemented at 35 IAC 721.

! Resource Conservation and Recovery Act (RCRA) at 40 CFR Part 262
is applicable for generators of hazardous waste (if procedures
outlined in 40 CFR Part 261 characterize spent carbon noted above
as a hazardous waste) if such materials are disposed of offsite;
delegated program in Illinois is implemented at 35 IAC 722.

! Resource Conservation and Recovery Act (RCRA) at 40 CFR Part 263
is applicable for transporters of hazardous wastes (e.g if
procedures noted in 40 CFR Part 261 characterize spent carbon as
a hazardous waste; the delegated program in Illinois is
implemented at 35 IAC 723.

! Resource Conservation and Recovery Act (RCRA) at 40 CFR Part 264
is applicable for groundwater monitoring and storage or treatment
of hazardous wastes (e.g. spent carbon) if generated; delegated
program in Illinois is implemented at 35 IAC 724, Subpart F.

! Illinois Groundwater Quality Standards at 35 IAC 620, Subpart E
are applicable for the groundwater monitoring component.

! Illinois Solid Waste and Special Waste Handling Regulations at 35
IAC 808 and 35 IAC 809 are applicable for off-site special waste
hauling (if spent carbon wastes are characterized as special wastes).

! Illinois Water Well Construction Code at 77 IAC 920 is
applicable for the construction and abandonment of soil borings
and monitoring wells.

Cost Effectiveness

IEPA and USEPA agree that the selected remedy affords overall effectiveness proportional to cost. Costs of
the selected remedy were greater than the "No Action" alternative, but the No Action alternative offers no
general degree of effectiveness, thereby ruling it out in a cost/effectiveness analysis. A cost versus
effectiveness comparison of the selected remedy to remedies that advocated more aggressive groundwater
treatment showed that the selected remedy was found to be generally as effective but implementable at one
third the cost of the next costliest alternative. By comparison, costs of the selected remedy were only 7%
of the most expensive alternative (Alternative 3a).

The decision to provide water mains without service connections in areas adjacent to the site was based on
groundwater modeling that predicted that the plume could move into areas of potable-use wells at contaminant
concentrations above health concern. While resulting in a higher initial capital cost, overall costs of
constructing an entire water main system to serve this area would be significantly less than constructing one
incrementally as modeling predicted slow movement of contaminants into these areas. The same criteria was
employed to justify mains/hookups at homes and businesses not currently affected by groundwater contaminant
levels above MCLs.

In summary, the cost comparison of passive groundwater treatment in the selected remedy versus active
treatment of Alternatives 2b, 3a and 3b, determined that the added expenses of active groundwater treatment
remedies to justify a shorter timeframe for ARARs to be met was unnecessary.

Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery
-------
Technologies to the Maximum Extent Practicable

The selected remedy meets the statutory requirement to utilize permanent solutions and treatment technologies
to the maximum extent practicable in a cost-effective manner.

Of the four remedies that complied with the threshold criteria, the IEPA and USEPA have determined that the
selected remedy represents the best compromise among the five balancing criteria. With the hookup provisions
of Alternatives 2a, 2b, 3a and 3b, these four remedies were found to have an equally high degree of long-term
effectiveness and permanence. Remedies that advocated active groundwater extraction/treatment (Alternatives
2b, 3a and 3b) provided a greater degree of contaminant mobility and volume reduction through treatment than
the selected remedy. This however, was somewhat offset by the selected remedies' greater short-term
effectiveness and implementability.

The cost criteria of the four remedies meeting the threshold criteria had a significant impact on the remedy
selection process. Remedies that sought active groundwater treatment had only a slight advantage over the
selected remedy with short-term effectiveness and implementability criteria factored in. Given that the
selected remedy could be implemented at less than one-third the cost of the limited groundwater
extraction/treatment remedy cost was a decisive factor in determining that Alternative 2a represented the
best tradeoff among alternatives that satisfied the threshold criteria.

If reference to how community acceptance was factored in the decision making process, the responsiveness
summary of the previous operable unit indicated widespread concern that not enough was being done to address
residential wells that become contaminated in the future. The selected remedy included provisions to address
these concerns through groundwater modeling that maximized the number of residential hookups. In addition,
hookup criteria in the selected remedy was extended to businesses (e.g. restaurants) that distributed well
water to clients. These concerns were noted by several Rockford businesses in the responsiveness summary of
the first operable unit and were addressed in the selected remedy.

Preference for Treatment as a Principal Element

There will be some treatment of contaminated groundwater as a side benefit to GAG treatment at the municipal
well, however in a general sense, the preference for active treatment of groundwater as a principal element
in the selected remedy is not met by this portion of the overall site remedy. It has been noted that
site-related groundwater contaminants will undergo treatment by means of natural attenuation in the selected
remedy, which will be made more effective because the source areas will undergo remediation in the future.
Since future source area remediation is part of the selected remedy, options to treat site-related
contaminants at their respective source areas through active means (such as source reduction) or through
engineering controls (such as source containment) remain open and will be addressed more thoroughly in a
subsequent Record of Decision that will address source control.

As summarized in the cost effectiveness portion of this section, IEPA and USEPA found that the additional
costs of implementing active groundwater treatment methods did not justify the attainment of ARARs on a
shorter timeframe (70 years rather than 205 years), when human health and the environment was adequately
protected.

XI. Documentation of Significant Changes

The Proposed Plan for the Groundwater Response Action at the Southeast Rockford Groundwater Contamination
Site was issued for public comment on July 14, 1995. The Proposed Plan identified Alternative 2a (Use
Restrictions) as the preferred alternative. The public comment period ended on August 16, 1995. IEPA reviewed
all written and verbal comments submitted during the public comment period. Upon review of these comments,
it was determined that no significant changes to the remedy, as originally identified in the Proposed Plan,
were necessary.
-------
State of Illinois
ENVIRONMENTAL PROTECTION AGENCY

Mary A. Gade, Director 2200 Churchill Road, Springfield, IL 62794-9276

The Administrative Record File for the Southeast Rockford Groundwater Contamination Superfund project is on
microfiche in the main branch of the Rockford Public Library (215 N. Wyman). Ask the reference librarian at
that library for assistance.

ADMINISTRATIVE RECORD FIIiE INDEX
SOUTHEAST ROCKFORD GROUNDWATER CONTAMINATION PROJECT
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Update No. 9
July, 1995

The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), requires the establishment of an Administrative
Record upon which the President shall base the selection of a response action (SARA; Sec. 113 (k) (1)).

The Illinois Environmental Protection Agency (IEPA) has compiled the following official Administrative Record
File Index for the Southeast Rockford Groundwater Contamination National Priorities List site located in
Winnebago County, Illinois. This index, as well as the Administrative Record File itself, will be updated by
the IEPA.

Please contact Virginia Wood (P.O. Box 19276, 2200 Churchill Road, Springfield, Illinois 62794-9276,
telephone 217/785-1269) for more information concerning this index.
-------
NO. DOCUMENT TITLE

1. Operable Unit Project
Plans:
Work Plan
Health & Safety Plan
Quality Assurance Project
Plan
Sampling & Analysis Plan
Community Relations Plan

2. Memo from D. Dollins re:
Update on Actual Number
of Private Wells Sampled
in Operable Unit Remedial
Investigation (RI)

3. Validated Raw Data From
Operable Unit RI Private
Well Sampling

4 Final Operable Unit RI
Technical Memorandum
(Includes map packet)

5a. Phase I Project Plans
Work Plan
Health & Safety Plan
Appendices
Community Relations Plan
5b. Quality Assurance Plan
Appendices
Sampling & Analysis Plan
Appendices

6. Operable Unit
Feasibility Study Report
(Includes map packet)

7. Proposed Plan-Operable Unit

8 . Declaration for the Record
of Decision—Operable Unit
Appendix: Responsiveness
Summary and Attachments

9. Technical Memorandum for
Phase I Field Activities
ISSUE
DATE
AUTHOR
6/06/90 CDM/IEPA
NO. OF
PAGES
57
60
192

74
22
6/20/90
IEPA
8/03/90
9/27/90
3/12/91
CDM/IEPA
CDM/IEPA
CDM/IEPA
290
296
3/06/91

3/91

6/91

5/91

10/92
CDM/IEPA

IEPA

IEPA/USEPA

IEPA

CDM/IEPA
10. Technical Memorandum Soil 8/92 CDM/IEPA
Gas and Geophysical Investi-
gation of Potential Source
Area 7.
70
57
41
30
92
235
80
101

92
11

627

761
IPrevious indices listed this document with 137 pages. The
larger number were pages counted to indicate space needed
on microfiche. For example, horizontal pages are counted
as 1 1/4 pages, and fold out maps are counted as 2 pages.
The actual number of pages, however, is 76.
-------
11. Southeast Rockford Ground- 10/92 CDM/IEPA 1242
water Contamination Phase II
RI (Remedial Investigation)
Work Plan and Sampling Plan
For Soil Gas Survey

312. Operable Unit Remedial 12/1992 USEPA 151
Action Report

313. Phase II Remedial 4/93 CDM/IEPA 136
Investigation/Feasibility
Study Work Plan
4/93 CDM/IEPA 231
314. Phase II Sampling and
Analysis Plan

315. Phase II Quality Assurance 3/93 CDM/IEPA 425
Project Plan

316. Letter from Valdas V. Adamkus 1/12/93 USEPA 2
(USEPA Regional Administrator) (Out of
to Charles E. Box (Mayor of date
Rockford) and Mary A. Gade order)
(IEPA Director)

17. Final Remedial Investigation 1/95 CDM/IEPA 1687
Report (3 volumes including
appendices).
2Previous indices listed this document with 185 pages. The
larger number were pages counted to indicate space needed
on microfiche. For example, horizontal pages are counted
as 1 1/4 pages, and fold out maps are counted as 2 pages.
The actual number of pages however is 124.

3In previous indices, the document that is now #16 was listed
as #12. Since the documents were not placed on microfiche in
that order, the numbers assigned five documents (#12, #13,
#14, #15, #16) were changed to reflect the actual order in
which they were placed on microfiche. In addition, previous
indices for this administrative record had placed three
documents (#13, #14, #15) indifferent order (#15, #13, #14).
This index has been changed to reflect the actual order in
which the documents were placed on microfiche.
18. Public Comment Feasibility 7/95 CDM/IEPA 252
Study

19. Proposed Plan—Groundwater 7/95 IEPA 20
Response Action
-------
In the Matter of:

Southeast Rockford Groundwater
Contamination Superfund Site

Groundwater Remedy

Proposed Plan

(Illinois EPA File No 427-95)

Responsiveness Summary

OVERVIEW

In accordance with Section 117, 42 U.S.C. Section 9617, of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) of 1980, the Illinois Environmental Protection Agency (Illinois EPA
or Agency) and the United States Environmental Protection Agency (USEPA) held a public comment period from
July 14, 1995 through August 16, 1995, to allow interested parties to comment on the "Proposed Plan -
Groundwater Response Action, Southeast Rockford Groundwater Contamination Site, Rockford, Illinois" (July
1995).

Illinois EPA, with USEPA, presented the Proposed Plan at two public meetings on August 1, 1995, and two
formal public hearing sessions on August 9, 1995. Both the public meetings and public hearings were held in
Rockford at the Ken-Rock Community Center, with sessions repeated afternoon and evening for the convenience
of the public.

The purpose of this responsiveness summary is to document the Agency's responses to comments received during
the public comment period. These comments were considered prior to selection of a final remedy for
groundwater contamination at the Southeast Rockford Site. The remedy is detailed in Illinois EPA's Record of
Decision, with USEPA's concurrence.

BACKGROUND OF COMMUNITY INVOLVEMENT
AND CONCERNS

BRIEF HISTORY OF COMMUNITY INTEREST. The Illinois EPA (Agency) has been responsible for conducting community
relations during the investigation for the drinking water operable unit (Operable Unit 1) and during Phase I
and Phase II of the Remedial Investigation are Groundwater Feasibility Study (Operable Unit 2). The Agency
will continue this role through the completion of the source area investigations and feasibility studies
(Operable Unit 3).

The site first came to the attention of the Illinois EPA with a citizen's complaint that plating waste had
been dumped in an abandoned well. Subseguent tests of nearby private wells did not detect plating wastes but
did find chlorinated solvents commonly used in industry for such things as degreasing machinery. A meeting
held in 1984 by The Illinois Department of Public Health and the Illinois EPA drew a crowd of approximately
200. Ongoing concern, however, did not appear to surface until the site was placed on the National
Priorities List in 1989, and financial institutions began refusing home mortgage and improvement loans in the
area.

During the first operable unit, many citizens resisted the idea of connections to the public water supply,
because, in order to receive the hookup, they had to sign an agreement to be annexed into the City of
Rockford if their property became contiguous to city property. That issue is no longer a major concern,
since nearly all of the area proposed for public water connections has now been annexed by the City of
Rockford.

KEY ISSUES. The main issues raised during the groundwater feasibility study and proposed plan comment period
are summarized below.

Issue #1. Residents who live in the area where the proposed plan calls only for the extension of water mains
and not the constructions of service lines are concerned that their well water may be unsafe and that the
-------
remedy may not protect them.

Issue #2. Several residents who live in the area where the proposed plan calls only for the extension of
water mains and not the construction of service lines think that the plan is unfair because the dividing
lines are drawn in the middle of streets with those on one side and not the other receiving service
connections. In addition, residents who look at the maps note that the dividing lines between those
receiving public water connections and those who do not is irregular. These residents assert that since the
dividing line does not reflect the natural flow of groundwater that the lines are arbitrarily drawn.

Issue #3. Residents who live in the area where mains and service connections will be provided are concerned
that they will have to pay for the mains and connections if their wells fail before construction begins in
late 1996. One woman has called the Agency since the public hearing saying that her well has collapsed. She
is not allowed to drill a new well and cannot afford the public water supply connection since she lives on
less than $500 per month.

Issue #4. A number of people are concerned about methods of paying for the investigations and remedies
Several citizens expressed concern that responsible parties be found and made to pay. One woman on the TCE
registry who is experiencing persistent bladder infections also wants responsible parties to pay for her
medical bills.

Business groups and the City of Rockford, on the other hand, are proposing that the City assume the liability
for past, present, and future costs so the Rockford industries do not become involved in extensive and costly
litigation to determine liability. Under the City's plan, costs would be paid by funds raised by the special
taxing district for area industry.

Issue #5. Business groups are concerned that the proposed remedy was based on the assumption of source area
control, and the type of source area remedy will not be decided upon until after source area investigations
are complete. Without knowing the type of source area control, the future costs are open-ended at this
point. This uncertainty may make it difficult to convince industries to accept the concept of a special
taxing district on industry as a sustainable method of paying for the remedy.

Issue #6. A number of people expressed concern about the proposed monitoring reguirements Business groups
expressed concern that 200 years of monitoring is an excessive reguirement. Many residents, on the other
hand, expressed the need for continued sampling of monitoring wells at a freguency that would detect the
movement of contaminated groundwater before it reaches their private wells.

Issue #7. The majority of respondents supports the proposed plan and asked guestions about conditions of the
public water hookups (e.g., may I keep my pump?). They urged that the connections be made as soon as
possible.

MODIFICATIONS. The Illinois EPA recognizes that this site covers a large area. The mailing list includes
over 4,000 addresses which cover a number of different neighborhoods as well as varying interest groups. In
order to be responsive to this large and varied group of citizens, the Illinois EPA made a number of
modifications designed to interact with people in smaller groups where it was easier to focus on the specific
concerns of a particular group. Detailed listing of community relations activities can be found in
Attachment A. The following activities are among the more major modifications.

(1) Shortly after the site was finalized on the National Priorities List, the USEPA began testing private
wells as pan of a removal action and providing bottled water to those who met the criteria Citizens became
alarmed about the safety of their water, and rumors abounded about the Agencies alleged role in denial of
home mortgage and home improvement loans. There were also suspicions that the Illinois EPA and USEPA were in
conspiracy with the City of Rockford to force public water connections and thereby annexation into the City.
Southeast Neighborhood Development (SEND) focused media attention on this anger, fear, and suspicion, holding
a public meeting attended by 200.

Illinois EPA Response: The Illinois EPA met with leaders of SEND and solicited their help in holding a
series of nine public meetings in which the USEPA removal action staff participated to disseminate
information and respond to concerns. These meetings were attended by a total of more than 500 people. The
Illinois EPA has continued to work with SEND throughout the process.

(2) At several points in the process, public officials reguested notification of major events and releases
of information before the news is published in the newspaper.
-------
Illinois EPA Response: The Illinois EPA has notified local, state, and federal officials before major
releases of information, usually offering officials an opportunity for a private briefing. The Illinois EPA
continually updated the list of contacts as the study area expanded and new officials were elected.

(3) When the investigative work identified Area 7 as a major area of concern, leaders of the nearby Pine
Manor Association expressed a need for detailed information about investigative results and plans. They were
especially concerned about the basement air sampling.

Illinois EPA Response: The Illinois EPA regularly briefed Pine Manor Association leaders prior to monitoring
well installation and other work in Area 7 and wrote fact sheets, updates and letters focusing on work
conducted in Area 7, including basement air sampling. Upon reguest, Illinois EPA held a small informal
meeting for the residents of Pine Manor Subdivision to focus on results of work conducted in
Area 7.

(4) The Rockford business community expressed an interest in current information on the project Illinois EPA
Response: In addition to sending interested parties the regular fact sheets, the Illinois EPA has also given
presentations to the Environmental Committee of the Rockford Chamber of Commerce when reguested. During the
first round of meetings in 1989, the Illinois EPA also held a special meeting for area businesses to discuss
their particular concerns.

SUMMARY OF COMMENTS AND RESPONSES

CONCERNS ABOUT THE PROPOSED REMEDY

Comment: The community had many guestions about the method of deciding who would receive public water
connections and who would not.

Response: Decisions about who would and who would not receive public water connections were based upon a
computer prediction or model. The method for making this prediction is as follows: Sample results from
monitoring and private wells, along with information on the groundwater direction, groundwater movement
rates, and other site characteristics, were fed into a computer. The computer used this data to give a
picture of predicted areas of groundwater contamination over a 70-year lifetime, assuming that remedies for
source areas would be provided later. The Illinois EPA and USEPA chose to base public water connections on
the area predicted, within the next 70 years, to have a total of at least five parts per billion of two of
the most common solvents in the Superfund area: 1,1,1-trichloroethane and 1,1- dichloroethane. The USEPA
public water supply standard for 1,1,1-trichioroethane is 200 parts per billion. There is no standard for
1,1-dichloroethane. As the Illinois EPA gathers more information from regular monitoring well sampling in
the future, it will refine the model (prediction) making it increasingly accurate as time passes.

Comment: A citizen, in the "mains only" area with a business in the 3300 block of llth Street, stated that
the southern boundary of the hookup area did not make sense. Specifically, the boundary between those who
will receive public water and those who will not, runs down the middle of llth Street. In addition, this
boundary jogs north for one half block, west for three blocks, then south for one block, etc. This line does
not reflect the reality of groundwater flow.

Response: The Agency acknowledges that groundwater does not move at right angles as streets do. The
zig-zagged lines in that area represent the limits of the buffer zones that were added to the area predicted
to have a total of at least five parts per billion of the two of the most prevalent contaminants (mentioned
above) within the next 70 years. In general, the Illinois EPA added a one block buffer zone to the predicted
area of contamination. In places where there were fewer monitoring wells to sample and thus a weaker data
base, the Illinois EPA added two or more blocks for a buffer zone as a precaution. The buffer zone has a zig
zag boundary because the buffer zone additions were made by city blocks as a practical measure since water
mains are laid down the streets.

The Agency can understand why a division down the middle of the street seems unfair, but a dividing line must
be drawn somewhere, and the nature of a boundary is that those on one side would receive connections, and
those on the other side would not.

Question: Will citizens in the "mains only" zone be forced to wait until contamination actually reaches
their well before they will be given a free connection to the Rockford Public Water Supply?

Response: No, they won't. The Illinois EPA plans to sample monitoring wells guarterly. If contaminants
reach the monitoring wells at concentrations of concern, the Illinois EPA will offer public water supply
-------
connections to those residents with private wells in the path of groundwater flow before the contamination
reaches their private wells. The criteria for future hookups will be the same as that used by the Agency to
justify the hookups in the area slated to receive them next year.

Question: Does the Illinois EPA know if the water in the "mains only" area is safe to drink?

Response: From all the available data, it is safe to drink. The groundwater contamination will move over
time, but the computer model predicts it will not move into the area designated "mains only" in harmful
concentrations for 70 years. Monitoring wells will be placed in your area that will provide continually
updated information about contaminant levels and movement. If future sampling results indicate contamination
is moving into unanticipated areas and poses a potential health threat to residents in the "mains only" area,
potentially affected residences will be connected to the City water supply at that time. If residents have
guestions about particular sample results, they should contact staff assigned to this project. Names and
numbers are listed at the end of this document.

Question: How can the Illinois EPA know if a water from a specific well is safe if it has never been
tested?.

Response: While not all private wells have been sampled in the area, numerous wells have been sampled.
Because of Illinois EPA's knowledge about the direction and rate of area groundwater flow and information
about the geology beneath ground surface, every well in the area does not have to be tested in order to make
a judgement about the safety of its water. Refer to the map of anticipated movement of contamination
(attachment B). All the information gathered to date indicates that those outside of the large white plume
area will not have more than a total of five parts per billion of two of the most prevalent chemicals within
the next 70 years. The federal drinking water standards for one of the chemicals is 200 parts per billion.
The other chemical does not have a drinking water standard.

The Illinois EPA will continue to monitor groundwater regularly. If, contrary to predictions, sample results
show that contamination is unexpectedly moving into areas which were predicted to be unaffected, those with
wells that are in the newly threatened area will be offered a public water supply connection at that time.

Question: Which wells have been tested in the 3300 block of 9th Street area? Who conducted the testing and
when? Where is the report?

Response: The Illinois EPA last sampled wells in the area in the summer of 1993. Results for several
locations in that area for some of the chemicals of concern are shown in the following table. The 3200 block
of 8th Street and the 3000 block of 9th Street will be offered public water connections under this Record of
Decision.

(in ugl, or ppb) 1,2-DCA 1,1,1-TCA PCE TCE
3200 block, 8th Street ND 2 41
3000 block, 9th Street ND 2 ND 1
3200 block, 9th Street ND 2 0.3 2

Drinking Water Standard 5 200 5 5

ND means "not detected" and ug/1 or ppb means micrograms per liter or parts per billion.

This information, with other soil and water sampling results, is contained in the Remedial Investigation
Report on file at the Ken-Rock Community Center and the Rock River Branch of the Rockford Public Library.

Question: Which wells were tested on South Potter Street. If any have been tested what were the results?

Response: While there were no wells sampled on Potter Street, there are sample results for two locations
near Potter. Results for some of the contaminants of concern are shown for these locations: Sewell Street
and Hamilton Street.

(in ug/1 or ppb) 1,2-DCA 1,1,1-TCA PCE TCE
3100 block, Sewell ND ND ND ND
1700 block, Hamilton ND 0.8 ND ND

Drinking Water Standard 5 200 5 5
-------
ND means "not detected" and ug/1 or ppb means micrograms per liter or parts per billion.

CONCERNS ABOUT CONDITIONS AND SCHEDUIiE OF HOOKUPS

Question: What is the planned schedule for public water supply hookups?

Response: Actual connections will probably be made in late 1996. There are several steps that must be taken
before work can begin. The Record of Decision on the groundwater remedy must be approved by USEPA and
Illinois EPA. After the decision has been made, those parties identified as responsible parties for the
contamination will be given an opportunity to conduct the work themselves. If these parties refuse or are
unable to do the work, the USEPA and the Illinois EPA can then conduct the work. If the responsible parties
conduct the public water connections, their work will be overseen by the Illinois EPA and USEPA to ensure
that it meets all standards and reguirements.

The City of Rockford may provide hookups earlier at residents' expense, but neither the Illinois EPA nor the
USEPA can reimburse these costs.

Question: How many complaints would it take to speed up the process, because several have private wells that
are going bad.

Response: It is not a matter of number of complaints. There is a specific process that the USEPA and the
Illinois EPA are legally obligated to follow. Once the Record of Decision has been approved and filed, the
parties identified as responsible will be given an opportunity to perform their work. See the response to
the previous guestions.

Question: May residents remove the pumps from their wells before their wells are plugged (cemented in
place)?

Response: Yes.

Comment: There are residents on fixed incomes in the "mains only" area who believe that their well water is
bad, but who would find it difficult to pay for the service connection from the street to their house.

Response: There are several reasons one might consider water "bad". According to the City of Rockford, even
city water can discolor water filters. This discoloration is due to the naturally-occurring iron and
manganese deposits present in the groundwater beneath Rockford. The guantities of iron and manganese found
in Winnebago County groundwater are considered to be a possible aesthetic concern (appearance, smell, or
taste) and not a health concern; conseguently, iron and manganese do not have to be removed. People with
iron and manganese problems in their private well water may experience similar problems with the Rockford
public water supply. If residents prefer, they may remove these minerals from their water by special filters
in their house.

A second reason a resident may consider their private well water "bad", is bacterial contamination. The City
water supply is treated and regularly tested for bacteria so bacteria should not be a problem with the public
water supply. If residents have a guestion about possible bacterial contamination of their private well,
they should contact the Winnebago County Health Department and arrange to have samples from their well
analyzed for bacteria.

Under the Superfund program, the Illinois EPA and the USEPA may only provide public water connections to
those whose wells meet criteria for the chemicals of concern outlined in the Record of Decision, which in
this case are specific volatile organic compounds. Problems with bacteria or minerals, such as iron and
manganese, in private wells are the responsibility of individual well owners.

Question: If a private drinking water well in the area of proposed public water supply connections fails,
will the Illinois EPA and USEPA pay for connecting the residence to the public water supply even if the
connection is made several months before the rest of the connections are constructed?

Response: The Illinois EPA and USEPA are not currently aware of a viable way to fund public water
connections for individuals who live in the area designated for public water connections whose wells fail
before the contract for the total work is signed. Both Agencies are continuing to explore possible solutions
to this problem with the City of Rockford and private organizations. If a solution is found, it will be for
a limited number of people only.
-------
Question: With all the budget cuts being proposed and made by Congress, will the Illinois EPA and the USEPA
have the funds to carry out this proposal?

Response: The Illinois EPA cannot guarantee funding will be available in the future. The proposed Illinois
EPA and USEPA remedy will be chosen in late September of this year. If responsible parties are unable or
unwilling to do the work, then the Agencies would request federal funding from the Superfund program. If
changes are made in the funding mechanisms of the Superfund program, it is possible that insufficient funds
or no funds will be available. If funding is available, the Illinois EPA and the USEPA are committed to doing
the work if potentially responsible parties are unwilling or unable to conduct the work themselves.

CONCERNS ABOUT LONG TERM MONITORING AND COMPUTER MODELING

Comment: One group commented that the computer modeling (prediction) on which future actions are to be based
may be inadequate to determine future contamination and subsequent health risk.

Response: The Illinois EPA agrees with this assessment which is why the proposed plan provides quarterly
sampling of monitoring wells to check the accuracy of the computer prediction. A model is only a tool by
which the Agency attempts to evaluate information from which decisions may be made. As the Illinois EPA
continues to regularly monitor for groundwater contaminants, Agency staff will have much more data with which
to revise and improve the model. If future sampler results indicate an unanticipated level of contamination
in drinking water wells representing an unacceptable health threat, connections to public water will be
provided at that time.

Comment: Planning based on 70-year lifetime risk may not be protective since there is no comprehensive
health study of residents.

Response: The Illinois EPA used a 70-year lifetime model for exposure to contaminants since the USEPA
guidance documents use a 70-year lifetime for assessing possible effects of exposure to carcinogens
(chemicals and other substances that cause cancer). The Agencies agree that knowledge about the effects of
these chemicals is not complete. Much of the current information on possible health effects from
contaminants is based upon animal studies (since experimentation on human beings is not allowed) and on
exposure to chemicals in the workplace. Workplace exposures usually involve healthy adults exposed for eight
hours a day. In order to gather more information about the effects of chemicals on the general public, one
must study a large number of people who have been exposed and record their health over a long period of
time—even a lifetime. This kind of data is difficult to obtain.

To further our knowledge about trichloroethylene, a National Trichloroethylene (TCE) Registry has been
developed in a joint effort between the Agency for Toxic Substances and Disease Registry and the U.S. Dept.
of Health. This is a national ongoing study of residents in seven areas in the United States who have been
exposed to TCE in their drinking water. Participants will be followed for a lifetime, and southeast Rockford
has the most participants in this study. Since this study has only been made for several years, there is not
enough information to draw definite conclusions about the possible health effects of specific levels of
contaminants.

Comment: Some business groups stated that 70 years of monitoring would be more reasonable/appropriate than
205 years for two reasons.

(1) According to the Illinois EPA, the 70-year plume was based on assumptions most protective of human
health, and (2) the monitoring time frame would be based on the same life expectancy assumption as was used
to designate the plume area.

Response: The Illinois EPA and USEPA conclude that 205 years is an appropriate time frame for projected
monitoring. The Record of Decision designates that the groundwater will be treated by natural attenuation.
Natural attenuation refers to the process by which contamination in groundwater is reduced by natural
breakdown of compounds, dilution and other natural processes.

Results from modeling (predicting) normal breakdown of volatile organic chemicals in groundwater (i.e., in
the absence of air and sunlight) show that it would take at least 205 years for the chemicals at the
concentrations found in the most highly contaminated areas of the site to break down into harmless products,
assuming a remedy for the source areas. Naturally, future monitoring data will give an increasingly clearer
picture of the rate of contaminant breakdown thereby tracking the progress of treatment by natural
attenuation. The length of time for monitoring, as well as the sampling frequency, may decrease if sample
results show that overall contaminant concentrations are less than anticipated or concentrations are stable.
-------
Monitoring will nevertheless continue as long as groundwater contamination exists at concentrations exceeding
health levels.

CONCERNS ABOUT REMAINING GROUNDWATER CONTAMINATION

Question: Will the groundwater contamination be allowed to spread?

Response: Source area investigations and remedies are included in the third and last operable unit. In
part, this operable unit will consider whether some type of containment mechanism will be appropriate in
conjunction with other remedies (for the soil and other source material) to restrict the contamination and
keep it from spreading. Additional public water hookups will be performed if it is determined that
groundwater contamination is spreading farther than anticipated. Next year, the Illinois EPA and the USEPA
will propose a remedy (which may include containment) to the public for comment.

Question: How will future contamination of the groundwater be stopped?

Response: State and federal laws that are in place today do not allow the dumping onto the soil or into
surface waters chlorinated solvents such as those contaminating the groundwater at this site. Under the
Resource Conservation and Recovery Act (RCRA) , facilities that generate any type of hazardous chemicals in
amounts of 100 kilograms per month or more must comply with certain rules and regulations about storage,
transport and disposal. These rules do not allow facilities to openly dump wastes in the manner that
occurred in the past. Of course, these laws may be changed by acts of the State legislature or the Congress.

Question: Is the Illinois EPA monitoring the groundwater contamination? Monitoring wells at the end of
0'Conner Street and at the intersection of Mayflower and Alpine have not been sampled for over a year.

Response: Illinois EPA has not sampled these monitoring wells since the summer of 1993. The process for the
regular monitoring of wells is part of the remediation proposal and is not yet in place. After a remedy is
selected, potentially responsible parties will be given an opportunity to perform the monitoring on a regular
basis. The Illinois EPA will conduct guarterly monitoring if the potentially responsible parties are unable
or unwilling to do so.

Question: What will happen when the Sundstrand plume and the plume to the south (Area 7) come together?
Where will they go?

Response: Judging from the groundwater movement, the plume from the Sundstrand property may move initially
toward the northwest, then westerly, and, eventually, southwesterly toward the Rock River. Sundstrand
currently maintains a groundwater contamination containment system. Whether or not the plume from the
Sundstrand plant joins the Area 7 plume in the future will be dependent upon how effective this containment
is.

CONCERNS ABOUT REMAINING SOURCE AREAS

Question: What are the plans for source area cleanup.

Response: The groundwater remedy described in the Record of Decision includes a provision that source areas
will be remedied. Investigations to further characterize these areas will begin late this fall. A study of
possible remedies for the sources will begin later this year and continue through early next year. After the
studies have been completed, the Illinois EPA and USEPA will submit the studies, along with a preferred
alternative, to the public for comment.

Comment: Is Area 7 is an "orphan" site meaning can potentially responsible parties be identified for
Area 7?

Response: The U.S. Dept. of Justice and the USEPA are in the process of identifying those parties who may be
potentially responsible for the contamination at this part of the site. The USEPA will decide whether or not
there are financially viable potentially responsible parties.

Comment: Business groups support the City of Rockford's effort to negotiate a settlement with the federal
government. In this proposed settlement, the City would construct the public water supply connections under
the conditions described in the Record of Decision. The city would pay for this work by collecting revenue
through a special service taxing district on industry. The business groups would support this special taxing
district if there is reasonable certainty that further significant costs (e.g. remedies for the source areas)
-------
will not be incurred. They encourage the USEPA, the U.S. Department of Justice and the Illinois EPA to work
with the City of Rockford to determine a reasonable cleanup plan for Area 7.

Response: In 1996, after investigations of source areas are complete, the Illinois EPA and the USEPA will
complete a study of remedies (including a remedy for Area 7). This study, along with a preferred
alternative, will be submitted to the public for comment. The City of Rockford, business groups, and the
general public will be welcome to comment on the proposed remedies at that time.

HEALTH CONCERNS

Comment: Just because levels of volatile organic compounds found in residential basements do not exceed that
found in the average urban household (from the use of cleaning solvents and other household products) does
not mean the levels are safe. Citizens should be educated.

Response: The commenter is correct in that levels of safety should not be determined only by what is
commonly found in households. The Illinois Department of Public Health (IDPH) not only compared levels found
in the southeast Rockford basement air samples to levels found in the average urban household, but they also
evaluated the possible effects these levels may have on human health. Based upon that assessment, IDPH
concluded that none of the homes-sampled demonstrated air concentrations above levels of health concern.

With current information, it is impossible to determine whether VOCs found in residential basements were due
solely to the presence of common household products or whether there was some contribution from groundwater.
Regardless of the source of VOCs, the concentrations found were below levels of concern and were similar to
those found in the average urban household.

If a school or a civic group would like to have a presentation on risks associated with exposures to these
types of solvents - and how to reduce such exposures - the Illinois Department of Public Health has offered
to do such a presentation. Feel free to contact Ken McCann at IDPH at 217/782-5830.

Question: Is it safe for children to play in Ekberg-Pine Manor Park?

Response: Yes, it is safe. Air samples taken in park areas showed that the air met occupational health
standards, as well as guidelines developed to protect the general public (including children) against adverse
health effects during short-term and long-term exposures.

OTHER CONCERNS

Question: What is the relationship between the public water supply connections the City of Rockford is
constructing and those proposed by the Illinois EPA and USEPA? Are their connections based upon contaminated
groundwater also?

Response: There is no relationship between the ongoing Rockford public water supply connections and those
connections proposed by Illinois EPA and USEPA. The City's connections are based on their own criteria and
are not based on perceived human health threats.

Comment: There was some confusion about the difference between "pumping" wells and "monitoring" wells.

Response: Monitoring wells will be part of an ongoing effort to regularly sample (test) the water for VOCs.
The pumping wells that were mentioned in one or more of the remedial options would be for pumping water to
the surface for treatment. Since the chosen remedy does not include groundwater treatment, no pumping wells
will be needed.

Question: In general, how bad is the groundwater pollution in Winnebago County?

Response: There are a number of areas in Winnebago County experiencing groundwater contamination. The
Illinois Department of Public Health has provided such a summary to the person who posed this guestion.
Others who are interested should contact either the Illinois Department of Public Health or the Illinois EPA
contacts below.

ADDITIONAL INFORMATION

Public Hearing Process, Hearing Record, Hearing Exhibits, Transcript
-------
John Williams
Agency Hearing Officer
Illinois EPA
P. 0. Box 19276, 2200 Churchill Road
Springfield, IL 62794-9276
217/782-5544
Technical Questions about the Final Groundwater Remedy

Paul Takacs
Project Manager
Illinois EPA
PO Box 19276, 2200 Churchill Rd.
Springfield, IL 62794-9276
217/785-1269
Turpin Ballard
Remedial Project Manager
USEPA, Region 5 Mail Code HSR-6J
77 West Jackson Blvd.
Chicago, IL 60604
312/353-6083
Health Questions
Ken McCann
Toxicologist
Illinois Dept. of Public Health
525 West Jefferson, 3rd Floor
Springfield, IL 62761
217/7882-5830
Additional Copies of
Responsiveness Summary

Virginia Wood or Carol Fuller
Office of Community Relations
Illinois EPA
P.O. Box 19276, 2200 Churchill Rd.
Springfield, IL 62794-9276
217/785-1269 (Wood)
217/524-8807 (Fuller)
The Illinois Environmental Protection Agency Director, Mary A. Gade, the Bureau of Land staff, and the
Illinois Environmental Protection Agency Hearing Officer thank those individuals and groups who attended the
meetings and hearings, as well as those who sent in comments, for their interest and participation.
Singed:
John D. Williams
Illinois EPA Hearing Officer

Date:
Illinois Environmental Protection Agency
2200 Churchill Road
P.O. Box 19276
Springfield, Illinois 62794-9276
Phone (217) 782-3397
-------
Attachment A

Community Relations Activities at Southeast Rockford Groundwater Contamination Superfund Site.

Community relations activities conducted by the Illinois Environmental Protection Agency (Illinois EPA) at the
Southeast Rockford Groundwater Contamination Superfund site included:

• Illinois EPA conducted community interviews with local officials and community leaders
(February, August, and October 1989, and March 1991) .

• Illinois EPA prepared a community relations plan (March 1989, and May 1990)

• Illinois EPA prepared and mailed a background fact sheet (October 1989).

• Illinois EPA held a news briefing on the project (October 1989).

• Illinois EPA held a series of nine public meetings to explain the status of the project, the
Superfund process, and planned action (October 1989) .

• Illinois EPA, in cooperation with the Rockford Chamber of Commerce, held a meeting for
businesses to explain the project, the Superfund process, and planned action (October 1989)

• Illinois EPA conducted a private well survey and obtained access for private and industrial
well sampling A project update was given during the survey (March through June 1990)

• Illinois EPA issued a news release announcing private well samples to be taken for operable
unit (June 7, 1990).

• Illinois EPA issued a news release announcing results of operable unit private well samples
(October 29, 1990).

• Illinois EPA regularly telephoned and met with local officials and community leaders through
out the proj ect to update them.

• Illinois EPA established repositories at the Ken-Rock Community Cemer and the Rock River
Branch of the Rockford Public Library (October 1989).

• Illinois EPA held a public comment period on the Operable Unit #1 Remedial Investigation/
Feasibility Study (RI/FS) from March 18 until 5:00 p.m, April 23, 1991. Also, Illinois EPA
prepared and mailed a fact sheet summarizing Operable Unit #1 RI/FS to a mailing list of
more than 4,000 residents and businesses (March 1991); placed an advertisement in the
local newspaper announcing the comment period and public hearing (March 16, 23, 30,
1991), and issued a news release publicizing the public hearing (April 15, 1991).

• The Illinois EPA and USEPA held a series of informational meetings to answer guestions
about the operable unit feasibility study and proposed plan (April 3, 4, 9 10 and 11, 1991) .

• Illinois EPA issued a news release announcing the public hearing to be held on April 17, 1991
and a media briefing on April 17, 1991

• Illinois EPA held a public hearing to receive comments on the operable unit feasibility study
and proposed plan (April 17, 1991).

• A transcript of the above hearing was placed in the repositories (May 1991).

• Illinois EPA issued a news release announcing the beginning of Phase I of the remedial
investigation (May 14, 1991) .

• Illinois EPA prepared and distributed a fact sheet describing planned work for Phase I of the
remedial investigation (May 14, 1991).

Illinois EPA and USEPA signed Record of Decision for Operable Unit 1 (June 14, 1991).
-------
Illinois EPA and USEPA issued a news release announcing the operable Unit Record of
Decision (June 26, 1991).

Illinois EPA issued a news release announcing the completion of Phase I remedial
investigation field work (October 1991).

llinois EPA released a fact sheet describing the results of Phase I of the remedial
Investigation (October 1992) .

Illinois EPA issued a news release announcing results of Phase I investigation and public
meetings (October 27, 1992)

Remedial Action Report certifying that the selected remedy for Operable Unit I was
operational and complete (November 19, 1992).

Illinois EPA issued a news release and held a media briefing to announce field work for Phase
II of the remedial investigation (June 1993).

Illinois EPA prepared and released a letter describing round two of private well sampling and
work to be conducted in Phase II of the remedial investigation (July 1993).

Illinois EPA prepared and released a separate letter to residents living near Area 7 describing
the work to be conducted in the Ekberg-Pine Manor Park area (June 1993).

Illinois EPA prepared and released a status report on the project (December 1994).

Illinois EPA prepared and released a fact sheet describing the results of the entire Phase II
remedial investigation (February 1995).

Illinois EPA prepared and released a fact sheet to residents around Area 7 describing results
of investigations completed at Area 7 (February 1995) .

Illinois EPA issued a news release announcing Phase II investigation results and public
meetings (February 1995).

Illinois EPA notified local officials, community groups, neighborhood association leaders,
and legislative and congressional staff prior to public releases of information. These
notifications were followed by personal briefings when desired (February 1995).

Illinois EPA, on reguest, gave periodic presentations to the environmental subcommittee of
the Rockford Chamber of Commerce, updating them on the project.

As needed, Illinois EPA obtained access for the 77 monitoring wells installed; permission to
sample an additional 160 privates residential, industrial, and State Water Survey wells; access
from property owners in 1992 and in 1993 for soil gas surveys, 55 soil borings, two test pits,
and for two rounds of basement air sampling in about 20 homes.

Illinois EPA also wrote individual letters to all who gave access for monitoring wells
installation and environmental sampling to convey the results found on the owner's property.

Illinois EPA published a display advertisement in the Rockford Register Star (July 10, 17,
and 24, 1995) announcing the public comment period and hearing for the groundwater
remedy the advertisement also described the feasibility study and proposed plan.

Illinois EPA held comment period on groundwater feasibility study and proposed plan (July
14 through August 16, 1995).

Illinois EPA issued news release announcing comment period, public meetings and public
hearing (July 19, 1995).

Illinois EPA held informational meetings in Rockford to discuss groundwater feasibility study
and proposed plan. (August 1, 1995 at 2:00 pm and 6:30 pm).
-------
Illinois EPA held public hearing to receive oral comments on the groundwater feasibility and
proposed plan. (August 9, 1995 at 2:00 pm and 6:30 pm).

-------