EPA
This Fact Sheet Explains
• Interim proposed plan to address
ground-water contamination
• Site location and description
• Site background and activities
• Risk assessment results
• Alternatives considered to address site
contamination
• U.S. EPA's proposed cleanup plan
• How to learn more about the site
You are Invited to a
Public Meeting
U.S. EPA will hold a public meeting
to explain the Proposed Plan for the
Sauget Area 2 Site. Oral and writ-
ten comments will also be accepted
at the meeting.
Date: June 24, 2002
Time: 7:00 p.m.
Place: Sauget Village Hall
2897 Falling Springs Road
Sauget, IL
For special needs or accommodations,
please contact Stuart Hill
at (312) 886-0689.
Public Comment Period
The U.S. EPA will accept written
comments on the Proposed Plan dur-
ing a 30-day comment period from
June 17 to July 17, 2002. A pre-
addressed comment form is provided
in this Proposed Plan.
ooooo -
United States
Environmental Protection
Agency
Office of Public Affairs
Region 5
77 W. Jackson Blvd.
™'C.yO, Illinois 60604
Illinois, Indiana,
Michigan, Minnesota,
Ohio, Wisconsin
U.S. EPA Issues Proposed Plan for
interim Ground-water Cleanup At
Sauget Area 2 Site
Cahokia, East St. Louis, & Sauget, Illinois June 2002
Interim Alternative Proposed
to Address Ground-water
Contamination
While the United States Environmental
Protection Agency (U.S. EPA) stud-
ies long-term clean up options at
the Sauget Area 2 Site in Cahokia,
East St. Louis, and Sauget, Illinois,
an interim ground-water clean-up
plan will be implemented to reduce
the risk of contamination reaching
the Mississippi River. A preferred
alternative is identified in the Site's
Proposed Plan1 that will address the
discharge of contaminated ground
water into the Mississippi River. The
final ground-water clean-up plan
for the Site will be selected once the
Remedial Investigation/ Feasibility
Study (RI/FS) is completed in 2004.
This Proposed Plan was developed
by U.S. EPA in consultation with
Illinois Environmental Protection
Agency (IEPA). Public comments on
the Proposed Plan and the informa-
tion that supports it are an important
contribution to selecting a clean-up
plan. Based on new information or
public comments, U.S. EPA and IEPA
may select another interim action
alternative. The public is encouraged
to review the Focused Feasibility
Study and other pertinent documenta-
tion contained in the Administrative
Record at the Site's information reposi-
tory and U.S. EPA Region 5 office (see
back page). The Focused Feasibility
/American
Bottoms
Wastewater
Treatment
V. 1 I.
FIGURE 1
Site Location Map
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Study evaluates potential alternatives to address the discharge
of contaminated ground water to the Mississippi River.
Site Location and Description
The Sauget Area 2 Site is located just east of St. Louis, Missouri
within the boundaries of Cahokia, East St. Louis, and Sauget,
Illinois. The 312-acre Site is located in the floodplain on the
east bank of the Mississippi River. The Site is located west
of Route 3 (Mississippi Avenue), north of Cargill Road, and
south of the MacArthur bridge railroad tracks (see site loca-
tion map).
The Site as a whole consists of five inactive disposal areas
(disposal sites O, P, Q, R, and S). Of these disposal sites, three
are closed landfills (disposal sites P, Q and R), one consists of
four closed sludge lagoons (disposal site O), and one is a waste
disposal site (disposal site S) associated with an abandoned
solvent reclamation facility. The Sauget Area 2 Site is the loca-
tion of a release of hazardous substances resulting from the
treatment and disposal of industrial, municipal, and chemical
wastes.
The Sauget Area 2 Site is immediately west and downslope to
the Sauget Area 1 Site. The Sauget Area 1 Site consists of six
known disposal areas adjacent, or in close proximity, to Dead
Creek, segments of Dead Creek that were altered as a result of
industrial waste disposal ( Dead Creek Segments A through
F), and releases from these waste disposal areas. These
releases have commingled and migrated along Dead Creek to
a perennial wetland and into ground water.
Land uses surrounding the site include four commercial
establishments north of the Site, and residential areas located
over half-mile east of disposal sites P and O. There are no
residences within or adjacent to the Site.
Site Background and Activities
The Site is located in an area that was historically used for
heavy industry, including chemical manufacturing, metal
refining and power generation, and waste disposal. Hazardous
substances have been found on the Site, in the ground water
underneath the Site, and in Mississippi River surface water,
sediments, and fish tissue from samples collected adjacent to
the Site. Currently the Site is used for heavy industry, ware-
housing, bulk storage (coal, refined petroleum, lawn and gar-
den products, and grain), wastewater treatment, hazardous
waste treatment, waste recycling, and truck terminals.
The five disposal areas and the activities that have taken place
are described below.
• Disposal Site O - Between approximately 1966 and
1978, the four lagoons were used to dispose of sludge
from the Village of Sauget wastewater plant. In 1980,
the Village of Sauget closed four sludge lagoons at
disposal site O by stabilizing the sludge with lime and
covering it with approximately two feet of clean, low-
permeability soil. Currently, the former lagoons are
vegetated.
Disposal Site P - This disposal site was operated by
Sauget and Company from 1973 to approximately 1984.
It was an lEPA-permitted landfill, which was used for
municipal and industrial waste disposal.
Disposal Site Q - Between the 1950s and the 1970s the
disposal site Q landfill accepted municipal waste, septic
tank pumpings, drums, organic and inorganic wastes,
solvents, pesticides, and paint sludges, plant trash,
waste from other industrial facilities, and demolition
debris. In 1995, U.S. EPA removed drums that were
exposed in the riverbank in the southwestern portion
of disposal site Q. In 1999/2000, U.S. EPA removed
3,721 drums and 17,032 tons of soil from two ponds in
the southeast corner of disposal site Q.
Disposal Site R - Industrial Salvage and Disposal, Inc.
operated the landfill at this site for Monsanto from 1957
to 1977. Hazardous and non-hazardous bulk liquid
and solid chemical wastes from two of Monsanto's
plants were disposed at this disposal site. A two- tr
eight-foot thick clay cover was installed in 1979
cover the waste, limit infiltration through the landfill
and prevent direct contact with the landfill material. In
1985, a 2,250-foot-long rock embankment was installed
along the Mississippi River downslope of the disposal
site to prevent erosion of the riverbank and minimize
the potential for the release of waste material from the
landfill. On February 13,1992, the State of Illinois and
Monsanto signed a consent decree requiring further
remedial investigations and feasibility studies by
Monsanto. The results of the RI/FS for disposal site R
were submitted to IEPA in 1994.
In 2000 and 2001, ground-water sampling by Solutia
found high levels of contamination at disposal site R.
Disposal Site S - In the mid-1960s, wastes from th
former Clayton Chemical property, now owned by
the Resource Recovery Group, was allegedly disposed
of in a shallow, on-site excavation, now designated as
disposal site S. This site is a potential waste and/or
drum disposal area.
The ground-water contamination downslope of Sauget Area
2 disposal sites O, Q (Dog Leg), R and S; Sauget Area 1 dis-
posal sites G, H, I and L; the W.G. Krummrich Plant and other
industrial facilities is discharging to the Mississippi River and
contaminating the river sediment. This contaminated ground
water exceeds IEPA water quality standards. Ground water is
not a source of drinking water for area residents.
On September 13, 2001, U.S. EPA proposed adding the Site
to the National Priorities List (NPL) of Superfund sites.
The sites on the list are eligible for further investigation
and cleanup under the federal Superfund program.
^ Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requires publication of a notice and a
Proposed Plan for the site remediation. The Proposed Plan must also be made available to the public for comment. This Proposed Plan fact sheet
is a summary of information for the Sauget Area 2 Site. Please consult the Administrative Record for more detailed information. See back page for
additional details.
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Based on Solatia's 2000 ground-water testing at disposal
site R, U.S. EPA requested that Sauget Area 2 Sites Group
prepare a Focused Feasibility Study to address the ground-
water contamination at disposal site R.
Risk Assessment Results
Several studies have been conducted to determine the current
and future effects of contaminants on human health and the
environment from exposure to contaminants from disposal
site R that can be found in the soil, surface water and ground
water. A risk assessment is an analysis of the potential adverse
human health and ecological effects caused by hazardous sub-
stance releases from a site in the absence of any actions to con-
trol or mitigate exposure to these hazardous substances.
Human Health Risks
A Human Health Risk Assessment was prepared for disposal
site R using historical site data. Potential carcinogenic (cancer
causing) risks for on-site workers and areas residents consum-
ing fish are within the acceptable risk range. For noncarcino-
genic hazards, the values are also within the acceptable risk
range.
Ecological Risks
In June 2001, a Baseline Ecological Risk Assessment was pre-
pared for surface water and sediment in the Mississippi River
adjacent to disposal site R. Surface water, sediment and fish
tissues samples were collected in October and November 2000
as part of a Baseline Ecological Risk Assessment (Menzie-
Cura, 2001). The risk assessment identified fish species at
risk from exposure to sediment, fish prey at risk from expo-
sure to surface water, and a number of compounds found in
sediment, surface water and fish tissue that were not found in
reference areas.
Based upon review of the currently available data for the Site
and the findings from the Baseline Ecological Risk Assessment,
it is U.S. EPA's current judgement that the preferred interim
action identified in the Proposed Plan is necessary to protect
public health or welfare of the environment from actual or
threatened releases of hazardous substances into the environ-
ment.
Summary of Cleanup Alternatives
Based on the currently available ground-water and sediment
information, U.S. EPA directed the Sauget Area 2 Sites Group
to conduct a Focused Feasibility Study to address the dis-
charge of contaminated ground water to the Mississippi River.
The primary objective of an interim cleanup is to protect the
Mississippi River from adverse impacts due to the discharge
of contaminated ground water from the Site. The Focused
Feasibility Study Report presents a detailed evaluation of the
remedial alternatives for the interim ground-water cleanup.
Three alternatives were reviewed: no action; physical barrier;
and a hydraulic barrier. These alternatives are described
below.
Alternative A - No Action
Estimated Capital Cost2: $0
Estimated Operation & Maintenance (O&M) Cost3: $0
Estimated Present Worth Cost: $0
Estimated Construction Timeframe: None
Regulations governing the Superfund program require that
the No Action alternative be evaluated at every site to estab-
lish a baseline for comparison. Under this alternative, no
action would be taken to prevent the discharge of contami-
nated groundwater to the Mississippi River.
Alternative B - Physical Barrier, Ground-water Extraction,
Ground-water Quality Monitoring, Ground-water Level
Monitoring, Sediment Toxicity Monitoring, and Institutional
Controls
Estimated Capital Cost: $6,802,897
Estimated O&M Cost for 30 years (Present Value):
$19,783,469
Estimated Present Worth Cost (Present Value): $26,586,366
Estimated Construction Timeframe: 12 months
Physical Barrier - A 3,500-foot long, "U"-shaped, fully pen-
etrating, jet grout barrier wall will be installed between the
downslope boundary of Sauget Area 2 disposal site R and the
Mississippi River to abate the discharge of impacted ground
water to the river. It will extend along the entire 2,000 feet
north/south length of disposal site R with the arms of the "U"
extending approximately 750 feet to the east (upslope), past
the eastern boundary of disposal site R and terminating before
the floodwall. Three ground-water recovery wells will be
installed inside the "U"-shaped barrier wall to control ground
water discharging to the wall.
Groundwater Extraction - Extracted ground water will be
routed to the American Bottoms Regional Treatment Facility
via subsurface pipeline installed in existing pipeline ease-
ments. The pipeline will connect with the Village of Sauget
trunk sewer leading to the PChem Plant. From the PChem
Plant the discharge will be routed to American Bottoms
Regional Treatment Facility for wastewater treatment and
ultimately discharged to the Mississippi River. A discharge
permit will need to be obtained from American Bottoms in
order to discharge pumped water to the Publically Owned
Treatment Works (POTW). A State permit may also need
to be obtained from the IEPA for the new wastewater source
tributary to the POTW, and the American Bottoms discharge
permit to the Mississippi River will need to include the
proposed groundwater discharge. To obtain this permit,
a demonstration will need to be made that constituents in
the pumped ground-water will not pass through the POTW
without treatment and/or will not interfere with treatment
plant operation. Based on the findings of this demonstration,
the actual technologies and sequence of technologies used
for treatment may change and will be determined during the
remedial design.
Groundwater Quality Monitoring - Ground-water samples
will be collected downslope of the barrier to determine if con-
2 Capital cost is the cost of construction.
3 O&M refers to the operation and maintenance activities conducted at a site, both during and following cleanup actions, to ensure that the cleanup
methods are working properly.
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taminants are migrating through, past or beneath the barrier
wall to the Mississippi River.
Ground-water Level Monitoring - Ground-water level moni-
toring will ensure acceptable performance of the physical
barrier.
Sediment and Surface Water Monitoring - Sediment and sur-
face water samples will be collected in the plume discharge
area to determine the effect of any contaminants migrating
through, past or beneath the barrier wall and discharging to
the Mississippi River. Impact will be determined by compar-
ing constituent concentrations to site-specific, toxicity-based,
protective concentrations derived from data used in the
Menzie-Cura Baseline Ecological Risk Assessment.
Institutional Controls - Institutional controls will be utilized 3
to limit fishing in the discharge area by limiting site access,
posting warning signs, and implementing a public education
program.
Alternative C - Hydraulic Barrier, Ground-water Extraction,
Ground-water Quality Monitoring, Ground-water Level
Monitoring, Sediment Toxicity Monitoring, and Institutional 4
Controls
Estimated Capital Cost: $539,603
Estimated O&M Cost for 30 years (Present Value):
$49.798,596
Estimated Present Worth Cost (Present Value): $50,338,199
Estimated Construction Timeframe: 6 to 12 months
5.
This alternative includes ground-water extraction, ground-
water water quality monitoring, water level monitoring,
sediment and surface monitoring, and institutional controls
previously discussed under Alternative B.
The only difference between Alternative B and C is that
ground-water wells would be installed under Alternative C
instead of a barrier wall. Three ground-water recovery wells
will be installed downslope of Site R to abate discharge of con-
taminated ground water to surface water to the point where
the impact on the Mississippi River is reduced to acceptable
levels.
Evaluating the Alternatives
The U.S. EPA used nine criteria, which are required by law
and described below, to evaluate the different remediation '•
alternatives individually and against each other in order to
select a remedy. The evaluation criteria are:
1. Overall Protection of Human Health and the
Environment addresses whether an alternative
eliminates, reduces or controls threats to public
health and the environment through institutional
controls, engineering controls, or treatment.
2. Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) evaluates
whether the alternative meets Federal and State
environmental statutes, regulations, and other
requirements that pertain to the site, or whether
a waiver is justified. ARARs are of three types -
chemical specific, location-specific, and/or action-
specific. Chemical-specific ARARs are numerical
values that establish the acceptable amount or
concentration of a chemical that may be found
in, or discharged to the ambient environment.
Location-specific ARARs are restrictions placed
on the concentration of hazardous substances
or the conduct of activities solely because they
are located in specific locations. Action-specific
ARARs are usually technology- or activity-based
requirements or limitations on action taken with
respect to hazardous wastes.
Long-term Effectiveness and Permanence refers to
expected residual risk and the ability of a remedy
to maintain reliable protection of human health
and the environment over time once cleanup goals
have been met.
Reduction of Toxicity, Mobility, or Volume
Through Treatment is the anticipated performance
of the treatment technologies a remedy may
employ to reduce the harmful effects of principal
contaminants, their ability to move in the
environment, and the amount of contamination
present.
Short-term Effectiveness involves the period
of time needed to implement the remedy and
any adverse impacts on human health and the
environment that may be posed during the
construction and operation of the remedy until
cleanup goals are achieved.
Implementability is the technical and
administrative feasibility of implementing the
remedy from design through construction and
operation, including the availability of services
and materials, administrative feasibility, and
coordination with other governmental entities.
Cost includes annual operation and maintenance
costs.
State/Support Agency Acceptance indicates
whether, based on its review of the Remedial
Investigation and Proposed Plan, the support
agency concurs, opposes, or has no comment on
the proposed alternative.
Community Acceptance considers whether the
local community agrees with U.S. EPA's analyses
and Preferred Alternative. Community input
received during the public comment period and
the public meeting on this Proposed Plan will be
included in the Record of Decision.
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Fold on Dashed Lines, Tape, Stamp, and Mail
Name
Address
City
Zip
State
Stuart Hill
Community Involvement Coordinator
Office of Public Affairs (P-19J)
U.S. EPA - Region 5
77 W. Jackson Blvd.
Chicago, IL 60604
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Comment Sheet
U.S. EPA is interested in your comments on the cleanup alternatives indicated in the Proposed Plan. U.S. EPA will consider
public comments before selecting a final cleanup remedy for the Sauget Area 2 site. Please use the space below to write your
comments, then fold and mail this form. Comments must be postmarked by July 17, 2002. If you have any questions about the
comment period, please contact Stuart Hill at (312) 886-0689, or through U.S. EPA's toll-free number at
1-800-621-8431. Those with electronic capabilities may submit their comments to U.S. EPA via the Internet at the following
e-mail address: hill.stuart@epa.gov.
Name
Address
City State.
Zip
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FIGURE 2
Evaluation Table
Alternative A
Alternative B
Alternative C
Overall Protection of Human Health and the Environment
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) - (Chemical-specific)
Long-term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume Through
Treatment
Short-term Effectiveness
Implementability
Annual Costs
\ ^^ate/Support Agency Acceptance
Community Acceptance
= Fully Meets Criteria
= Partially Meets Criteria
= Does Not Meet Criteria
(with waiver)
(with waiver)
$0
$26,586,366
$50,388,199
U.S. EPA anticipates the State of Illinois to concur with
Preferred Alternative.
Community acceptance of the recommended alternative will
be evaluated after the pulic comment period ends and will
be described in the Responsiveness Summary section of the
Interim Action ROD.
Preferred Alternative
The Preferred Alternative for the Site is Alternative B, which
includes a physical barrier, ground-water extraction, ground-
water water quality monitoring, water level monitoring, sedi-
ment and surface monitoring, and institutional controls. This
alternative is preferred because it will achieve substantial risk
'eduction through the containment and extraction of contami-
ated ground water downslope of disposal site R, thereby
reducing contamination entering the Mississippi River. In
the short term, the Preferred Alternative will prevent or abate
actual or potential human and ecosystem exposure to hazard-
ous substances, pollutants and contaminants. In the long
term, the operation of a barrier may achieve acceptable chemi-
cal-specific containment levels downslope of the barrier.
The Preferred Alternative is an interim cleanup of contaminat-
ed ground-water at the Site. This limited-scope action would
only address the discharge of contaminated ground water
into the Mississippi River in the vicinity of Site R. Operation
of the physical barrier and ground-water extraction system
will provide additional information to be used in developing
options for a final long-term comprehensive ground-water
cleanup. A final cleanup to fully address other threats posed
by conditions at the Site will taken upon the completion of the
Site's RI/FS.
The Next Step
U.S. EPA will consider public comments received during the
public comment period before selecting the ground-water
interim action at the Site. The interim action will be described
in a decision document called a Record of Decision (ROD).
U.S. EPA will make the ROD available for public review in the
information repository and at U.S. EPA's Region 5 office. U.S.
EPA will answer public comments received during the pub-
lic comment period in a document called a Responsiveness
Summary, which is part of the ROD.
U.S. EPA and the Sauget Area 2 Sites Group are currently
finalizing plans to collect the data needed to prepare the
Sauget Area 2 RI/FS Report. As noted earlier this RI/FS will
be completed in 2004.
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For Additional Information
If you would like additional information about the Proposed Plan for the interim groundwater action at the Sauget Area 2
Site, please visit the information repository at:
Cahokia Public Library District
140 Cahokia Park Drive
Cahokia, IL 62206
An Administrative Record file, which contains detailed information upon which the selection of the recommended alternative
will be based, is available at the Cahokia Library and at the U.S. EPA Region 5 office in Chicago. For additional information
on the Sauget Area 2 site, please contact:
Stuart Hill (P-19J)
Community Involvement Coordinator
(312) 886-0689
hill.stuart@epa.gov
Mike Ribordy (SR-6J)
Remedial Project Manager
(312) 886-4592
ribordy.mike@epa.gov
U.S. EPA Region 5
77 West Jackson Boulevard
Chicago, IL 60604
Toll Free: 1-800-621-8431
http://www.epa.gov
EPA
U.S. Envirionmental Protection Agency
Region 5
Office of Public Affairs (P-19J)
77 W Jackson Blvd.
Chicago, Illinois 60604
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