-------
Risks associated with inhalation of indoor air potentially impacted
by vapor migration from groundwater and/or soils near identified
source areas were qualitatively 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 quantify the toxic effects of a chemical on
human health. They ore 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:
CU mid
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 B1 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
14

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of concern are noted in Table 6-4 of the RI report. The compounds
methylene chloride, trans-I,2-Dichloroethene, chloroform and 1,2-
dichloroethene were not detected above required laboratory
detection limits.
No residential wells that were sampled had total carcinogenic risks
exceeding 1 x 1CT4, which is the upper limit identified in the NCP.
Four wells had total carcinogenic risks in the 1 x 10"s range and
nine homes has carcinogenic risks in the range of 1 x 1CT®. All
other wells had total carcinogenic risks below 1 x 10"6. The
primary contaminant contributing to total carcinogenic risks was
l, 1-dichloroethene with ingestion being the dominant exposure
pathway contributing to risks. Hazard indices for sampled wells
were all below l, 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.
TTn /"i oy-f* t n f* t a & ^ n V* a vAt** *i n f* Vi at "V i L» oo « « onftfliiTi f*	o ts f* n rs	Wa
uiiCcXi l.a.xriuX6s innex>6nu xn eric xr~L-SJv. ciss6ssiiiviil. piocsss Cu>rniOL 00
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 adequately 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 Suoerfund (December
1989) .
15

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VII. Description of Alternatives
•
Alternative
1 :
•
Alternative
2a;
•
Alternative
2b:
•
Alternative
3 a:
•
Alternative
3b:
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 GAC unit at UW3 5. They include the following:
No Action
Use Restrictions
Limited Act ion
Groundwater Extraction and Air Stripping
with Offsite Disposal
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 quarterly 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 xf 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 quarterly 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 quarterly monitoring components of Alternative
1. Usage of groundwater will be restricted within the modeled 7 0
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
16

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i '! j) SI
1
V /\ Harrison Ave
Harriion Avenue ^
2Sw Ave
II
iiM
Lfl I
ill!
[I
Limbic Road
11

Sandy Hollow Road
LEGENO
-BUFFER ZONE
-PROJEC1EO 3 Mi CONCENTRAriOM LME
COMBMCO CONCENTRATIONS Of UirCA ANO U-DCA
NOTEi
AREAS PROPOSED FW CONWCIBM 10 fUBLK WATER SUPHr
RCLUOCS RESBEMCtS WThM PROJECTED S CONCENTRATION L»€
um VI1MH THE BUFFE* ZONES
BUFFER ZOtC
r • MOO
800 e
*00
State Route 20 runs E-W just
to the south of the site.
t
USE RESTRICTIONS

-------
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 GAC 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).
IS

-------
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
(WCHD) 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
T mr-i I flfnaTl ^ ai +¦ h 1 o v>£\nrt/-s/"Nt t«n i 1 a eein	¥- V* *"s +~ ~- v	i *r"i —» 4— tn	i —» 1 i' ^ r
xuipxcuicriueQ xn Liiis xrciueQy win assuz/e uricix cne yrounuwausr cjuol± 1cy
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.
19

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3

LEGENOi
~ POTENTIAL SOURCE
INVESTIGATION AREA
P Pumping Well
icm-ci
I fmt

-------
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 aquifers 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
quality 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
aquifer_ 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 aquifer restoration is a remedial action
objective in this ren.edy, 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 quali ty
standards set forth in 35 IAC 620 are met. The monitoring program
will be consistent with 35 IAC 620.505 and 35 IAC 620.51.0- 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 quality standards of 3 5 IAC 3 02
and 3 5 IAC 3 04. The treatment works process would be operated
21

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under the supervision of a certified operator pursuant to 3 5 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 equalization 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 woula
apply. Full-scale groundwater extraction and treatment in
aquifer would be sought in this remedy to achieve State wat-»r
quality standards and the standards of the Safe Drinking Water A "
in the shortest period of time. This remedy seeks to aggressive. .
remediate site-related groundwater contaminants while assuming t h.'
source controls are to be implemented at a later date.
Twenty-two groundwater extraction wells will be installed in fiv
separate nests throughout the site as part of Alternative 3a (s —
map on page 23) . To achieve treatment of groundwater to State a:. •
Federal drinking water standards, these wells would intercept .
estimated 211 billion gallons of contaminated groundwater at t:
combined rate of 5, 347gpm for approximately 75 years when the N!
for TCA is reached (see assumptions of Alternative 2a regard!; :
extended treatment times for compounds other than TCA and DCA
Off-gas treatment (carbon treatment) of organic emissions from a.
stripping operations at two extraction wells located at Harris..
Avenue and Kinsey Street would be necessary because of locally hi:•
concentrations of Area 11-related contaminants in the plume.
Two well nests located east of Twentieth Street would be complet-- i
in the sand/gravel and bedrock aquifers at depths ranging from 1""
feet to 204 feet below ground surface. Pumping rates for the nes-
of five wells near Area 7 and the four wells just east of Twentief *.
Street would be 70gpm and 25Ggpm, respectively. The other thr- •
well nests would be completed in the sand/gravel aquifer at deptr..¦
ranging from 90 to 133 feet below ground surface. Pumping rates f :
the four extraction wells located just west of Eleventh Stre~*
would be 250gpm, while the two well nests (nine wells tota.
closest to the Rock River would be rated at 333gpm.
22

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P
IIOCKF

ira:
i
LCI
LliU	C3
1
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i
I rK XrfxN >¦! f 1--C- r—i , J-	-	
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tmot HOUA* KM
LEGEND.
~
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POTENTIAL SOURCE
INVESTIGATION AREA
Pumping Wall
tout.
0 1000 FmI
FULL-SCALE GROUNDWATER EXTRACTION/TREATMENT

-------
In addition to the protectiveness of human health elements from
Alternative 2a, the main objective of this remedy is to achieve
aquifer 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 aquifer 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 quality
standards set forth in 35 IAC 620 are met. The groundwater
monitoring program will be consistent with 35 IAC 620.505 and 3 5
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 quality
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 3 5 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
Vsia o V» i	/-s "F _ a i t" o	a va 4- t	f-lm <5 maf-ori al x*7 ill Vso
v v 0XXoL£-'£•' CUi U «L w JL L w X. UX JL Gy CI 1C X. Gt> «L LJXX f wXX JL	Hid w C JL -L.u JL W J- J» JL XJ t5
manifested and transported to an approved regeneration facility
pursuant to RCRA requirements. Residuals excluding spent carbon
A-	•—*	mm
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 equalization basins, six air stripping units,
and one GAC off-gas treatment unit. The overall costs of
Alternative 3a are noted on the following page:
24

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CAPITAL CONSTRUCTION COST
ANNUAL Q&M COST
present WORTH COST (at 5% for 75 years)
$8,276,000
$2,174,000
$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 150psi booster
pumps to deliver treated groundwater to the nearest municipal water
main capable of handling the average design flow of effluent frci
each treatment system.
Cost estimations for this remedy include the well construction ana
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 costir, i
purposes, it was assumed that treated groundwater sold to the crv
would generate $0.50 of revenue per 1000 gallons treated over t:.-
life of the 75 year pumping effort. The overall cost
Alternative 3b (Groundwater Extraction and Air Stripping wr. .
onsite discharge) is noted below:
CAPITAL CONSTRUCTION COST	$14,314,000
ANNUAL G&M COST	$310,000
PRESENT WORTH COST (at 5% for 75 years) $20,362,000
c?£ tins 0a^si11e	a s ^3£ .^^11esnxsits
The Superfund program requires evaluation of alternatives based
nine criteria by which technical, economic and practical factor-1
associated with each response action alternative must be judge.i
The nine criteria are categorized into three groups: threshc. :
ym -m 4— y.	y "| *ti -jj w*	j2| I T"l f* T T™1 f"T ' f* "V T f~" Ci y T 2S n jfiA/i -i j \Z" t	"j Oi y "1 3	*7* *" *3>
JL JU %w* JLi CL f L/ JLi JL liLCL jr Ca JL CaJL	<4 iM Vmt JL Jm> x3» Jm JL C*	XV* U lw X *L» Y -JL 11M X	-•* JL CA ¦	* •
nine evaluation criteria are summarized as follows;
Threshold Criteria - These must be satisfied in order for tr.
alternative to be eligible for a final remedy selection.
1. Overall Protection of Human Health and the Environment - Tr. . -
criteria addresses whether a remedy provides adequate protection ¦. :
human health and the environment and describes how risks pose 2
through each exposure pathway are eliminated, reduced, :
controlled through treatment or engineering/institutional controls
25

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2. Compliance with Applicable or Relevant and Appropriate
Requirements (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 pcsed 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 !:e 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
26

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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 adequate 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 aquifer 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 required 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 quality 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.
27

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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 as
part 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.
Imp1ementabi1ity
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 highest
degree 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 range from
$1,124,000 in Alternative 1 to $50,723,000 in Alternative 3a. A
rather complex network of extraction wells and an exceedingly high
volume of contaminated groundwater treated over an extended period
of time are responsible for the higher costs of Alternative 3a.,
State/Support Agency Acceptance
USEPA Region V, as designated support agency for this site, concurs
with the Illinois Environmental Protection Agency's recommendation
of Alternative 2a (Use Restrictions) as the selected remedy for the
Southeast Rockford Groundwater Contamination Site.
28

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Community Acceptance
The public has been given the opportunity to review and comment on
the FS report and Proposed Plan within a thirty day public comment
period. Two public meetings and two formal public hearings were
held for the general public to ask questions and provide comments
that relate to all of the evaluated alternatives. Community
acceptance of the preferred remedy has been generally favorable.
All comments, written and oral, compiled during 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 Region V have determined that Alternative 2a is the most
appropriate groundwater response remedy for the Southeast Rockford
Groundwater Contamination Site. This alternative essentially
restricts the usage of groundwater as a potable water source at the
site. In addition, with source controls being a component of
Alternative 2a, this remedy will offer a combination of natural
attenuation and probable containment as a remedy to site-related
contaminated groundwater in the sand/gravel 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 (pages 16 through 19) of this document.
•	Groundwater Monitoring for 2 05 years
•	Water Main Installations
•	Service Connections for Selected Private Potable-Use Wells
•	Future Service Connections for Remaining Potable-Use Wells
•	Continued Operation of GAC Unit at Municipal Well UW-3 5
•	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 degree to which groundwater 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.
IEPA's basis for remediation goals are ARARs that include the Safe
Drinking Water Act, and the Illinois Groundwater Protection Act.
Corresponding risks associated with hypothetical exposures to a
mixture of detected groundwater 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 slightly exceeded USEPA's acceptable risk range of 1 x 1CT6 to
29

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1 x ICT4. Although this finding 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 l, 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 Quantity
Unit Cost
Total Direct
Capital Cost
1. Monitoring Well 9
Installations
$2,778
$25,000
2. Water Main
Installations 21,000'
$5Q/LF
$1,058,000
3. City Water Service
Connections 400
$1,000
$400,000
4. Future Service
Connections 0
0
0
5. Operation of GAC Unit
at Municipal Well UW-35 0
0
0
6. Source Control Measures
(Operable Unit 3) 0
0
0
7. Institutional Controls 0
0
0
Total Direct Capital Costs
$1,483,000
Engineering/Design Costs @15%
Contingencies @15%
Other Indirect Costs (Legal Fees
and Regulatory License Costs)
$222,000
$222,000
$89,000
Total Indirect
Capital Cost
$533,000
TOTAL CAPITAL
COST:
S2.016.000

30

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The annual operation and maintenance (O&M) costs for Alternative 2a
are presented below:
Component Unit Cost
Total Direct Present Worth O&M
Annual O&M Costs Annual Costs
1. Groundwater
Monitoring $300
at 35 wells

$42,000
$840,000
2. Water Mains
O&M

0
0
3. City Water Service
Connections

0
0
4. Future Service
Connections

0
0
5. Operation of GAC Unit
at Municipal Well UW-3 5

0
0
6. Source Control Measures
(Operable Unit 3)

0
0
7. Institutional Controls

$8,400
$168,000
Total Direct Annual/Periodic
Present Net Worth O&M Costs
$1,038,000
Administrative, Insurance,
Tax and License Costs @10%
Direct Annual O&M Costs
of
$5,20 0
$52,000
Maintenance Reserve and
Contingency Costs 315% of
Direct Annual O&M Costs

$7,800
¦•$156, 000
Total Indirect Annual/Periodic
Present Net Worth O&M Costs
$260,000
TOTAL ANNUAL/PERIODIC PRESENT
NET WORTH COSTS
SI,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
31

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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,
construetion 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
n ^ a 1 f- a v*T"i afa ^ voai" rn ont" t~o "H ti	"i o a	f-Viai ma v i mn m
IvjL d JL l. vi JL XJLcl I— w L. X. © ct L- ll X1L. L. AiX J. wy J* fci o L- w	XII lei .X. J. HIU.Ill S-X.C- S »»
practicable; and satisfy the preference for treatment as i
principle element of the remedy.
Protection of Human Health and the Environment
Implementation of the selected remedy will reduce and contra.
potential risk to human health from exposure to site-relate-:
groundwater contaminants both now and in one lifetime by providir. :
individuals with potable-use wells with a safe and reliat . -¦
alternative source of drinking water. The remedy will reduce r: *
to within the acceptable range of 1 x 1CT4 to 1 x 10 "6 excess cane •:
risk and hazard indices for noncarcinogens will be less than or,"
To the extent that groundwater monitoring indicates futu:--
unacceptable risks associated with exposure to groundwat
contaminants, additional hookups to city water will be provia-- :
under this remedy.
The selected remedy will reduce and control potential groundwat- :
risks to the environment through future source control componer/ :
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 ea ¦
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 contaminar.*
that will remain on site, Section 121 (2) (A) of CERCLA requir--
that the selected remedial action be compliant with all applicat.
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 trie:
32

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stringent) . ARAR waivers required at this time have not been
identified. ,rTo 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 4 0 CFR Part 261
is applicable for identification of hazardous wastes (e.g. spent
carbon from GAC at UW-35) for identifying proper disposal of
waof aa	mai/ VtA va "1 ca-fra-ri	at" o 4"t* caaHrtT^l "1 T"i*T
tZar V* fcmr CU JLVJL !>¦ »4hnL jF mm	JL» Cm* .aiw >!j2 \r JL nn' €3»JL 1UL (wit p 
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•	Resource Conservation and Recovery Act (RCRA) at 40 CFR Part 263
is applicable for transporters of hazardous wastes (e.g if
procedures noted in 4 0 CFR Part 261 characterize spent carbon as
a hazardous waste; the delegated program in Illinois is
implemented at 3 5 IAC 72 3.
•	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 92 0 is
applicable for the construction and abandonment of soil borings
and monitoring we11s.
Coat 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
implement able 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.
34
-------
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
W a 2a cjt f"m i f 4 r< a ri t* t mn	eal	4 ^ys	cs es
Sa* X X w w X X d X X Ci» wl d. Id JL X X «X» X. X OL X X !¦« X i 1 Ga> l*» w E X %• X X w X- w i [lw vX j 
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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 USEFA 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 o£ 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.
36
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State of Illinois
W 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 FILE 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. 0. Box 19276, 2200 Churchill
Road, Springfield, Illinois 62794-9276, telephone 217/785-
126 9) for more information concerning this index.
NO. DOCUMENT TITLE
ISSUE
DATE
NO. OF
AUTHOR PAGES
1. Operable Unit Project
6/06/90 CDM/IEPA
Plans:
Work Plan
Health & Safety Plan
Quality Assurance Project
57
60
192
Plan
Sampling & Analysis Plan
Community Relations Plan
74
22
2. Memo from D. Dollins re:	6/20/90
Update on Actual Number
of Private Wells Sampled
in Operable Unit Remedial
Investigation (RI)
IEPA
1
(MORE)
PriaM m Recycled Hper
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Administrative Record Page 2
NO. DOCUMENT TITLE
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
10.	Technical Memorandum Soil
Gas and Geophyrical Investi-
gation of Potential Source
Area 7.
ISSUE
DATE
8/03/90
9/27/90
3/12/91
3/06/91
3/91
6/91
5/91
10/92
8/92 .
AUTHOR
CDM/IEPA
CDM/IEPA
CDM/IEPA
NO. OF
PAGES
290
296
CDM/IEPA
IEPA
IEPA/USEPA
IEPA
CDM/IEPA
CDM/IEPA
70
57
41
30
92
235
80
101
92
11
18
29
6.27
761
lPrevious indices listed this document with 13 7 pages. The
larger number were pages counted to indicate space needed
on microfiche. For example, horizontal pages are counted
as 1 l/4 pages, and fold out maps are counted as 2 pages.
The actual number of pages, however, is 76.
(MORE)
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Administrative Record Page 3
ISSUE
NO. DOCUMENT TITLE	DATE
11. Southeast Rockford Ground- 10/92
water Contamination Phase II
RI (Remedial Investigation)
Work Plan and Sampling Plan
For Soil Gas Survey
312.	Operable Unit Remedial	12/1992
Action Report
313.	Phase II Remedial	4/93
Investigation/Feasibility
Study Work Plan
4/93
314.	Phase II Sampling and
Analysis Plan
315.	Phase II Quality Assurance 3/93
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).
NO. OF
AUTHOR	PAGES
CDM/IEPA	1242
USEPA	151
CDM/IEPA	136
CDM/IEPA	231
CDM/IEPA	4 25
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.
3 In 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) in different order (#15, #13, #14} .
This index has been changed to reflect the actual order in
which the documents were placed on microfiche.
(MORE)
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Administrative Record Page 4
ISSUE	NO. OF
NO. DOCUMENT TITLE	DATE	AUTHOR PAGES
18. Public Comment Feasibility 7/95	CDM/IEPA 252
Study-
lS. Proposed Plan--Groundwater 7/95	IEPA	20
Response Action
####
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lit the Matter of:
Southeast Rockford Groundwater
Contamination Superfund Site
Groundwater Remedy
Proposed Plan
(Illinois EPA File No, 427-95)
Responsiveness Summary
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1
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 I, 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 w-atrr
operable unit (Operable Unit 1) and during Phase I and Phase II of the Remedial Investigation and
Groundwater Feasibility Study (Operable Unit 2). The Agency will continue this role through tnc
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 v. asu-
had been dumped in an abandoned well. Subsequent tests of nearby private wells did not detect
plating wastes but did find chlorinated solvents commonly used in industry for such things .»>
degreasing machinery. A meeting held in 1984 by The Illinois Department of Public Health and she
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 v.ate?
supply, because, in order to receive the hookup, they had to sign an agreement to be annexed ;nto
the City of Rockford if their property became contiguous to city property That issue is no lonueT
a major concern, since nearly all of the area proposed for public water connections has now beim
annexed by the City of Rockford.
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2
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 iate 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 requirements
Business groups expressed concern that 200 years of monitoring is an excessive requirement. Many
residents, on the other hand, expressed the need for continued sampling of monitoring wells at a
frequency 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 questions about
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3
conditions of the public water hookups (e.g., may I keep ray 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 part 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 requested 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
request, 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
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4
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 requested. 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 questions 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-trichloroethane is 200
parts per billion. There is no standard for 1, l-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 11th 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 11th
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.
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5
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 quarterly. 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
questions 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.
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6
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 ug/1, or ppb)
1,2-DCA
1,1,1-TCA
PCE
TCE
3200 block, 8th Street
ND
2
4
1
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 ugA 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 weiis 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: Seweli Street and Hamilton Street.
(in ug/1 or ppb)
1,2-DCA
1,1,1-TCA
PCE
TCE
3100 block, Seweli
ND
ND
ND
ND
1700 block, Hamilton
ND
0.8
ND
ND





Drinking Water Standard
5
200
5
5
ND means "not detected" and yg/1 or ppb means micrograms per liter or parts per billion.
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7
CONCERNS ABOUT CONDITIONS AND SCHEDULE 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 Dlinois 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 requirements.
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 questions.
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 quantities 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; consequently, 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.
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8
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 question 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
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9
groundwater contaminants, Agency staff will have mucb more data with which to revise and
improve the modeL If future sample 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 (Le., 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
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10
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 ma;
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 thai
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. Thm
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;
end of O'Conner Street and at the intersection of Mayflower and Alpine have not been sampled V;
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
quarterly monitoring if the potentially responsible parties are unable or unwilling to do *o.
Question: What will happen when the Sundstrand plume and the plume to the south (Area 7) come
together? Where will they go?
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11
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 nest year. After the studies have been completed, the Illinois a
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 suppiv
connections under the conditions described in the Record of Decision. The city would pay for thii
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, aloaf
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 oa 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.
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12
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?
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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 question. 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.O. 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
P O 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 those who sent in
13
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comments, for their interest and participation.
Illinois Environmental Protection Agency
2200 Churchill Road
P. O. Box 19276
Springfield, Illinois 62794-9276
Phone (217) 782-3397
Signed:
John D. Williams
Illinois EPA Hearing Officer
Date:
In. /9ftT
14
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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 project to update them.
*	Illinois EPA established repositories at the Ken-Rock Community Center 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 pm, 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).
15
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The Illinois EPA and USEPA held a series of informational meetings to answer questions
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).
Illinois 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 ce/tifying 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).
16
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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 request, 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).
17
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ATTACHMENT B
-

Seward Ave
i /\ Hiniwi Ave.
25th Ave
Haitison Avenue
III

ill— .
Ill
m

r
ii it ini ii r C
¦n«tKma»*
Lindale Road
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^Sandy Hollow Road
IEOENO
MAMS ONLY
-BUFFER ZONE
- PROJECTED 9 m* CONCENTRATION IKE
COMBMEO CONCENTRATIONS OF I.M-TCA AND H OC*
NOT Ei
AREAS PROPOSES FOB CONNECTION TO PUBLIC WATER SUPPLY
tKLUOES RE9BENCE5 ¦ITMN PROJECTED t P9» CONCENTRATION LME
AND aiTHM THE SUFFER ZONES
BUFFER ZONE
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BOO 0	*00
State Route 20 runs E-W just
to the south of the site.
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