First Five-Year Review Report for Interstate Lead Company Superfund Site City of Leeds Jefferson County, Alabama September 29, 2006


Five-Year Review Report

First Five-Year Review Report

Interstate Lead Company Superfund Site
City of Leeds
Jefferson County, Alabama

September 29, 2006

PREPARED BY:

U. S. Army Corps of Engineers
Mobile District
Mobile, Alabama

REVIEWED AND REVISED BY:

U. S. Environmental Protection Agency
Region 4
Atlanta, Georgia

Acting Director, Waste Management Division
US EPA, Region 4

for

Approved by:

Date:

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TABLE of CONTENTS

List of Acronyms	i

Executive Summary	ii

Five-Year Review Summary Form	iv

I.	Introduction	1

II.	ILCO Site Chronology	2

III.	Background	5

Physical Characteristics	5

Landforms	5

Surface Water	5

Geology	6

Regional Geology	6

Site-Specific Geology and Soil	6

Ground water	6

Regional Hydrogeology	6

Site Hydrogeology	7

Ground Water Movement Patterns	7

Ground Water Gradients	8

Sub-Site Specific Hydrogeology at OU-1	8

Land and Resource Use	9

History of Contamination	10

Initial Response	10

Basis for Taking Action	11

IV.	Remedial Actions	14
Remedy Selection	14
Remedy Implementation	21
Institutional Controls	25
Systems Operation/Operations and Maintenance (O&M)	25

V.	Progress Since Last 5-Year Review	26

VI.	Five-Year Review Process	26
Administrative Components	26
Community Involvement	26
Document Review	26
Data Review	26
Site Inspection	34
Interviews	35

VII.	Technical Assessment	36
Question A: Is the remedy functioning as intended by the decision documents? 36
Question B: Are exposure assumptions, toxicity data, clean up levels and remedial
action objectives (RAOs) used at the time of the remedy still valid?	36
Question C: Has any other information come to light that could call into question
the protectiveness of the remedy?	40
Summary of Technical Assessment	40

VIII.	Issues	40

IX.	Recommendations and Follow-up Actions	41

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X.	Protectiveness Statements	43

OU-1	43

OU-2	43

OU-3	44

Overall Protectiveness	44

XI.	Next Review	44

LIST of TABLES

TABLE 1: ILCO SITE CHRONOLOGY	2

TABLE 2: GROUND WATER PERFORMANCE STANDARDS for OU-1 & OU-2	13
TABLE 3: SELECTED CHEMICALS of POTENTIAL CONCERN FOR OU-3 ILCO

SUPERFUND SITE	14

TABLE 4: QUANTITIES OF EXCAVATED AND DISPOSED MATERIAL	24
TABLE 5: LEAD CONCENTRATION IN SURFACE WATER, ILCO SUPERFUND

SITE (OU-3)	27
TABLE 6: LEAD CONCENTRATIONS IN SEDIMENT ILCO SUPERFUND SITE

(OU-3)	27

TABLE 7: SITE INSPECTION ATTENDEES	34

TABLE 8: COMPARISON OF ORAL TOXICITY VALES	3 8
TABLE 9: COMPARISON OF ROD PERFORMANCE STANDARDS TO CURRENT

MCLs	39

TABLE 10: ISSUES	40

TABLE 11: RECOMMENDATIONS and FOLLOW-UP ACTIONS	41

ATTACHMENTS

ATTACHMENT

1 -

SITE MAPS

ATTACHMENT

2-

SITE LAYOUT

ATTACHMENT

3 -

DOCUMENTS REVIEWED

ATTACHMENT

4-

ARARs

ATTACHMENT

5 -

FIVE-YEAR REVIEW SITE INSPECTION REPORT

ATTACHMENT

6 -

CHRONOLOGY OF REMEDIAL ACTIONS - LEED





ENVIRONMENTAL

ATTACHMENT

7 -

SITE INSPECTION PHOTOGRAPHS

ATTACHMENT

8 -

FIVE-YEAR REVIEW INTERVIEWS

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LIST OF ACRONYMS

AAC

Alabama Administrative Code

ACL

Alternate Concentration Limit

ADEM

Alabama Department of Environmental Management

ARAR

applicable or relevant and appropriate requirement

AWQC

ambient water quality criteria

BAT

best available technology

BCT

best conventional technology

BDAT

best demonstrated available technology

CAA

Clean Air Act

CERCLA

Comprehensive Environmental Response, Compensation and Liability Act

CFR

Code of Federal Regulations

USACE

U.S. Army Corps of Engineers

CWA

Clean Water Act

DOJ

Department of Justice

DOT

U.S. Department of Transportation

EPA

U.S. Environmental Protection Agency

ESD

Explanation of Significant Difference

HSWA

Hazardous and Solid Waste Amendments

ILCO

Interstate Lead Company

LDR

Land Disposal Restrictions

MCL

Maximum Contaminant Level

MCLG

Maximum Contaminant Level Goal

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NPDES

National Pollution Discharge Elimination System

NPL

National Priorities List

O&M

operation and maintenance

OU

Operable Unit

RAO

Remedial Action Objective

RCRA

Resource Conservation and Recovery Act

ROD

Record of Decision

SARA

Superfund Amendments and Reauthorization Act

SDWA

Safe Drinking Water Act

SOW

Scope of Work

TBC

to be considered

TCLP

Toxicity Characteristic Leaching Procedure

TSD

treatment, storage and disposal

i

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EXECUTIVE SUMMARY

Cleanup of the Interstate Lead Company Superfund Site (ILCO), Leeds, Alabama, is being
accomplished through three Operable Units (OUs). OU-1 is comprised of seven satellite sites in
the vicinity of the ILCO facility, and addresses soil, sediment and ground water contamination.
OU-2 is comprised of soil and ground water contamination at the Main Facility and ground
water at the ILCO Parking Lot. OU-3 is comprised of contamination of surface water, sediment
and biota in Dry Creek and the Un-named Tributary. The United States Environmental
Protection Agency (EPA), Region 4, signed Records of Decision (RODs) for each of these OUs,
and subsequent remedial actions have been implemented. The milestone of construction
completion was achieved on November 29, 2005, with the completion of the Preliminary
Close-Out Report. The trigger for this Five-Year Review was the initiation of remediation on
January 25, 2000

OU-1: The implemented soil remedies at the ILCO Parking Lot, Gulf/BP Service Station, J&L
Fabricators, Connell Property, Fleming's Patio, Acmar Church of God, and City of Leeds
Landfill are protective of human health and the environment. The remedies requiring the
excavation of the contaminated soil and sediment above the action levels, removed the principal
threat, and are expected to function as intended by minimizing the migration of contaminants to
ground water and surface water.

The selected ground water remedy for J&L Fabricators, Fleming's Patio, and the Connell
Property is monitored natural attenuation. The remedies for these properties are expected to be
protective of human health and the environment upon completion, and in the in the interim
exposure pathways that could result in unacceptable risk are being controlled. Additional
sampling of ground water at Fleming's Patio is necessary to confirm that the soil excavation was
effective in removing source material in this area. However, a declaration of restrictive
covenants which prohibits the use of ground water for potable use has been placed on the
property.

The selected ground water remedy for the City of Leeds Landfill, pump and treatment system,
has not been installed. During the RD Studies designed to estimate the volume of contaminated
soil to be removed, it was determined by a statistical analysis of the data that no remediation is
required to meet the performance standards. An evaluation of the ground water data also
indicates that MCLs have not been exceeded for the area. The appropriate decision document
will be prepared by EPA to document the change from the original remedy. Therefore the City of
Leeds Landfill is protective of human health and the environment.

OU-2: The soil remedy for the ILCO Main Facility has been successfully implemented and is
protective of human health and the environment. Additional ground water monitoring is
necessary at the ILCO Main Facility to confirm that the soil excavation was effective in
removing source material in this area. The pump and treat remedy has not been installed,
however, recent ground water data (since 2004 when a substantial portion of the soil remediation
had been completed) indicates that lead is not present in the ground water at concentrations
exceeding the 15 |ig/l performance standard at the main facility or the Parking Lot. Continued
ground water monitoring is necessary to support future decisions regarding implementation of
the pump and treat system.

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OU-3: Because sufficient data is not available, a protectiveness determination cannot be made at
this time until further information is obtained. Further information will be obtained by sampling
Dry Creek and the Un-named Tributary. Institutional controls are also necessary for these areas
and need to be in place to ensure protectiveness of the remedy. Institutional controls are no
longer required at the Leeds Municipal Landfill because the cap was not installed as identified in
the ROD. The need for institutional controls at the Leeds Municipal Landfill will be addressed in
a future decision document.

Overall Protectiveness:

All remedies that have been implemented for OU-1, OU-2, and portions of OU-3 are protective
of human health and the environment. A protectiveness determination at portions of OU-3, Dry
Creek and the Un-named Tributary cannot be made until additional sampling data has been
collected and evaluated.

111

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN): Interstate Lead Company Superfund Site
EPA ID (from WasteLAN): ALD041906173

Region: 4	State: AL	City/County: Leeds/Jefferson

SITE STATUS

NPL status: Ex] Final I I Deleted I I Other (specify)

Remediation status (choose all that apply): n Under Construction Q] Operating [><]
Complete

Multiple OUs. ^Yes n Construction completion date: November 29, 2005
Has site been put into reuse? I I Yes No

REVIEW STATUS

Lead agency: ^]EPA QStateQ Tribe QOther Federal Agency:

Author name: Ernest R. McCollum	Affiliation: U.S. Army Corps of Engineers

Review period: June 15, 2004 - March 15, 2006

Date of Site Inspection: 01 /11 / 2006
Type of Review:

^Post-SARA I iPre-SARA Q]NPL Removal Only
I iNon-NPL Remedial Action Site NPL State/Tribe Lead
I I Regional Discretion

Review Number: £3 I (first)

Triggering action:

1X1 Actual RA On-site Construction at OU-2	Q Actual RA Start at OU-

I I Construction Completion	Q Previous Five-Year Review

Report

CH Other (specify)

Triggering action date (from WasteLAN): January 25, 2000
Due date (fiveyears after triggering action date)'. January 25, 2005

iv

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FIVE-YEAR REVIEW SUMMARY FORM, cont'd.

Issues:

Monitoring wells are not being properly maintained.

Surface water is ponding near the ILCO Parking Lot.

An Operation and Maintenance Plan has not been prepared for the Site.

Foundation drains may not have been installed properly on the Connell Property and water is
collecting in the basement.

Trench erosion may be occurring at the Acmar Church of God.

Additional ground water sampling is necessary at Fleming's Patio, the ILCO Main Facility,

ILCO Parking Lot, and the City of Leeds Landfill to support a final decision regarding
implementation of ground water pump and treat system and potential ROD changes.

Sufficient sampling data is not available from the Un-Named Tributary and Dry Creek to make a
protectiveness determination.

Site-wide ground water data needs to be evaluated to ensure that soil excavations continue to be
protective of ground water.

Institutional controls for the Un-named Tributary and Dry Creek need to be implemented, as
required by the OU-3 ROD.

The MCLs for arsenic and cadmium have been lowered and an evaluation has not been done on
the impact to the ground water remedies. ROD components that have either changed, or are no
longer necessary have not been administratively addressed.

v

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Recommendations and Follow-up Actions:

Issue

Recommendations/
Follow-up Actions

Party
Responsible

Oversight
Agency

Milestone
Date

Affects
Protectiveness?
(Y/N)

Current

Future

Monitoring wells are not
being properly
maintained.

Repair, paint, check
locks.

PRP

EPA/State

December
2006

N

N

Surface water is ponding
near the ILCO Parking
Lot.

Pump out water, dry site
and add additional fill
material to direct run off
to ditches.

PRP

EPA/State

February
2007

N

N

An Operation and
Maintenance Plan has
not been prepared for the
Site.

Finalize the draft O&M
plan.

PRP

EPA/State

January
2007

N

Y

Trench erosion may be
occurring at the Acmar
Church of God.

Determine if contractor
omitted replacement
foundation drains and
correct problem, if
necessary.

PRP

EPA/State

December
2006

N

N

Additional ground water
sampling is necessary at
Fleming's Patio, the
ILCO Main Facility,
ILCO Parking Lot, and
the City of Leeds
Landfill to support a
final decision regarding
implementation of
ground water pump and
treat system and
potential ROD changes.

Inspect for erosion and
fill where necessary.

PRP

EPA/State

September
2007

N

N

Sufficient sampling data
is not available from the
Un-Named Tributary
and Dry Creek to make a
protectiveness
determination.

Collect additional ground
water monitoring data.
Evaluate the data and
prepare a decision
document to support
ROD changes or direct
the PRPs to install ground
water pump

PRP

EPA/State

December
2009

N

Y

Site-wide ground water
data needs to be
evaluated to ensure that
soil excavations
continue to be protective
of ground water.

Collect additional
sampling data from the
Un-Named Tributary and
Dry Creek.

PRP

EPA/State

June 2007

N

Y

vi

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Issue

Recommendations/
Follow-up Actions

Party
Responsible

Oversight
Agency

Milestone
Date

Affects
Protectiveness?
(Y/N)

Current

Future

Institutional controls for
the Unnamed Tributary
and Dry Creek need to
be implemented, as
required by the OU-3
ROD.

Assess current ground
water conditions and
determine if sufficient
source material has been
removed. Continue to
maintain institutional
controls.

PRP

EPA/State

June 2007

The MCLs for arsenic
and cadmium have been
lowered and an
evaluation has not been
done on the impact to
the ground water
remedies.

Implement institutional
controls.

PRP

EPA/State

December
2007

ROD components that
have either changed, or
are no longer necessary
have not been
administratively
addressed.

Evaluate impact of
lowered MCLs and
determine appropriate
next steps.

PRP

EPA/State

December
2007

Monitoring wells are not
being properly
maintained.

Review current
groundwater conditions
and determine appropriate
next steps.

PRP

EPA/State

December
2007

Protectiveness Statements:

OU-1: The implemented soil remedies at the ILCO Parking Lot, Gulf TBP Service Station, J&L
Fabricators, Connell Property, Fleming's Patio, Acmar Church of God, and City of Leeds
Landfill are protective of human health and the environment. The remedies requiring the
excavation of the contaminated soil and sediment above the action levels, removed the principal
threat, and are expected to function as intended by minimizing the migration of contaminants to
ground water and surface water.

The selected ground water remedy for the City of Leeds Landfill, pump and treatment system,
has not been installed. During the RD Studies designed to estimate the volume of contaminated

vii

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soil to be removed, it was determined by a statistical analysis of the data that no remediation is
required to meet the performance standards. An evaluation of the ground water data also
indicates that MCLs have not been exceeded for the area. The appropriate decision document
will be prepared by EPA to document the change from the original remedy. Therefore the City of
Leeds Landfill is protective of human health and the environment.

OU-3: Because sufficient data is not available, a protectiveness determination cannot be made at
this time until further information is obtained. Further information will be obtained by sampling
Dry Creek and the Un-named Tributary. Institutional controls are also necessary for these areas
and need to be in place to ensure protectiveness of the remedy. Institutional controls are no
longer required at the Leeds Municipal Landfill because the cap was not installed as identified in
the ROD. The need for institutional controls at the Leeds Municipal Landfill will be addressed in
a future decision document.

Overall Protectiveness: All remedies that have been implemented for OU-1, OU-2, and portions
of OU-3 are protective of human health and the environment. A protectiveness determination at
portions of OU-3, Dry Creek and the Un-named Tributary cannot be made until additional
sampling data has been collected and evaluated.

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ILCO SUPERFUND SITE
LEEDS, ALABAMA
FIRST FIVE-YEAR REVIEW

I. INTRODUCTION

The purpose of the Five-Year Review is to determine whether the remedies at a site are
protective of human health and the environment. The methods, findings, and conclusions of
reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports
identify issues found during the review, if any, and identify recommendations to address them.

The U.S. Environmental Protection Agency (EPA) is preparing this Five-Year Review report
pursuant to CERCLA §121 and the National Contingency Plan (NCP). CERCLA §121. states:

If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such
remedial action no less often than each five years after the initiation of such remedial
action to assure that human health and the environment are being protected by the
remedial action being implemented. In addition, if upon such review it is the judgment of
the President that action is appropriate at such site in accordance with section [104] or
[106], the President shall take or require such action. The President shall report to the
Congress a list offacilities for which such review is required, the results of all such
reviews, and any actions taken as a result of such reviews.

The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after the initiation of the selected remedial action.

There are three operable units (OUs) associated with the Interstate Lead Company (ILCO) site.
OU-1 is comprised of seven satellite sites in the vicinity of the ILCO facility, and addresses soil,
sediment and ground water contamination at these satellite sites. OU-2 is comprised of the soil
and ground water contamination at the ILCO Main Facility and ground water at the ILCO
Parking Lot. OU-3 is comprised of contamination of surface water, sediment and biota in Dry
Creek and the Un-named Tributary. EPA signed Records of Decision (RODs) for each of these
OUs, and remedial activities are ongoing in each of the OUs, as described further in this report.

This review was conducted by the U.S. Army Corps of Engineers (US ACE), on behalf of EPA,
from December 2005 through January 2006. This Five Year Review report documents the results
of the review, which is the first five-year review for the Site. The triggering action for this
statutory review is the initiation of the remedial action on January 17, 2000. The five-year
review is required because hazardous substances, pollutants, or contaminants remain at the site
above levels that allow for unlimited use and unrestricted exposure.

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II. ILCO SITE CHRONOLOGY

Table 1 provides a chronology of events that have occurred during the history of the Site.

TABLE 1: ILCO SITE CHRONOLOGY

ACTION

BY

DATE

Hazardous Waste Stored On-Site

ILCO

1973-1984

Chapter 11 Bankruptcy Petition

ILCO

August 20, 1982

Stream/Sediment Sampling

ADEM

July/August 1983

Ecological/Biological

ADEM

February/March 1984

Emergency Removal Action at Acmar Church of God Site

EPA

April 1984

Site Screening Study

EPA

July 1, 1984

Sampling Investigation

EPA

February 1985

EPA filed complaint against ILCO for violations of Clean
Water Act, RCRA, and CERCLA

EPA

March 1985

Interim Status Closure Plan

ILCO

April 10, 1985

Placed on National Priorities List

EPA

June 1986

Remedial Investigation Work Plan

Ebasco/ESE

January 1, 1987

Pre-Final Remedial Design Specifications

GeoSyntec

March 1, 1987

Chapter 11 Reorganization

ILCO

June 11, 1987

Phase I Remedial Investigation

Ebasco/ESE

October 1, 1987

Phase II Remedial Investigation

Ebasco/ESE

April 1, 1988

Final Draft, Qualitative Risk Assessment

ESE

May 1, 1988

Site Investigation Report

ESE

June 1, 1988

Atl. ILCO RI Report

ESE

August 1, 1988

RI Report Vol. I of II

ESE

September 1, 1988

F/S Report Vol. II of II

ESE

September 1, 1988

Appendix B- Qualitative Risk Assessment

ESE

September 1, 1988

Appendix E- XRF Data

ESE

September 1, 1988

Treatability Study on Main Site Soil

EPA

1988

Tributary Sediment Removal Plan

Dames& Moore

February 8, 1989

Final Qualitative Risk Assessment

Ebasco/ESE

May 1, 1989

Proposed Plan- Parking Lot & Main Facility

EPA

August 1, 1989

2

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ACTION

BY

DATE

Down Stream Water Study Plan

Dames& Moore

September 21, 1989

Assessment Report for Soil, Surface Water and Ground water

Dames& Moore

September 29, 1989

Final RI Report

Ebasco/ESE

October 1, 1989

Final RI Report, Vols.- 2,3,4,5& 6

Ebasco/ESE

November 1, 1989

Initiated OU-1 Remedial Investigation/Feasibility Study

CH2MHill

1989

Consent Decree

DoJ

March 26, 1990

Treatability Study Report for Stabilization/Solidification at
ILCO

Kiber

April 22, 1990

Treatability Study Work Plan

CH2MHill

July 1, 1990

Final Report- Tributary Sediment Removal

Ebasco/ESE

November 20, 1990

Final Revised Community Relations Plan

Dynamac

November 19, 1990

ILCO Draft Cleanup Criteria for Ground water

EPA

November 30, 1990

RCRA Facility Assessment Report

A. T. Kearney

December 1, 1990

State of Alabama vs. ILCO

DoJ

December 10, 1990

Addendum to Assessment Report

Ebasco/ESE

December 18, 1990

Additional OU-1 Remedial Investigation Studies

EPA

1990

2nd Chapter 11 Bankruptcy Petition

ILCO

July 22, 1991

OU-1 Remedial Investigation/Feasibility Study Completed

CH2MHill

July 1991

OU-1 Record of Decision

EPA

September 30, 1991

Administrative Order to Cease Removal of Equipment

DoJ

June 3, 1992

Bench Scale Treatability Study

RECRA Env.

August 20, 1992

Final Soil & Debris Treatability Study Report

Kiber

February 1, 1993

Final Supplemental Removal Addendum to the Community
Relations Plan

EPA

April 1, 1993

Draft Work Plan for In-House RI (OU-2)

EPA

May 1, 1993

Work Plan for In-House RI (OU-2)

EPA

September 1, 1993

RI/FS Statement of Work to Bechtel

EPA

September 9, 1993

ILCO Well Completion Report

Bechtel

March 1, 1994

RI Report

EPA

May 1, 1994

ILCO Superfund Site Biological Assessment Report

EPA

June 1,1 994

Unilateral Administrative Order to Maintain 24 Hour
Security

DoJ

June 1,1 994

3

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ACTION

BY

DATE

Baseline Risk Assessment for ILCO Superfund Site

ICF Kaiser

June 17, 1994

Decision to make un-named Tributary and Dry Creek OU-3

EPA

July 7, 1994

Comments on Proposed Plan for OU-2 and Amendments to
OU-1 ROD

Leed Env.

August 1, 1994

Comments on Proposed Plan, OU-2 Ground water Issues

Langan Env.

September 1, 1994

Soil RAO's for Ground water

EPA

September 1, 1994

ILCO Resolution, dated September 31, 1994

Leeds 2000

Steering
Committee

September 30, 1994

Record of Decision for OU-2 and Amended OU-1 ROD

EPA

October 13, 1994

SOW Treatability Studies, revised January 95

Leed Env.

December 1, 1994

Hydrologic Delineation of Well Head Protection, City of
Leeds, AL

Geological
Survey of AL

January 1, 1995

Administrative Order, by Consent

DoJ

February 5, 1995

Report on Additional Ecological Assessment of Streams

EPA

April 1, 1995

Proposed Remedial Action Plan

EPA

July 1, 1995

Treatability Evaluation Report

RMT/Kiber

July 1, 1995

Focused Feasibility Study Report, ILCO Superfund Site
OU-3

Bechtel

July 21, 1995

Treatability Evaluation Report Appendices, Revised

RMT/Kiber

September 1, 1995

Record of Decision OU-3

EPA

September 25, 1995

Summary of Remedial Alternative Selection for OU-3, ILCO
Superfund Site

EPA

September 29, 1995

Treatment Evaluation Report for Composite 2A

Kiber

October 1, 1995

Draft Final Soil Washing Terramet Leaching Supplemental
Treatability Study

COGNIS

November 28, 1995

Amended Proposed Remedial Action Plan

EPA

May 1, 1996

Amended FS Addendum for ILCO OU-1 and OU-2

Bechtel

May 21, 1996

Remedial Options Review

RMT

July 1, 1996

Summary of Remedial Alternative Selection for Amendment
to RODs of OU-1 and OU-2

EPA

August 27, 1996

Consent Decree

DoJ

April 22, 1997

Pre-Design Field Investigation Report

GeoSyntec

October 1, 1997

Design Criteria Report to Meet RAOs

GeoSyntec

November 1, 1997

4

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ACTION

DATE

ILCO Site Remediation Group- Intermediate Design

GeoSyntec

February 1, 1998

Pre-Final Design Package- Design Criteria Report,
Supplemental

GeoSyntec

March 1, 1998

Final Design Report

GeoSyntec

February 1, 1999

ACL Demonstration and Proposed Ground water Monitoring
Plan

ILCO Site
Remediation
Group

February 2, 1999

RMT starts Remedial Action (RA)

RMT

January 2000

RMT released from contract

ILCO Group

June 2001

RMT Mixing Protocol for Lead Impacted Material

RMT

February 21,2000

Final Revised Remedial Action Work Plan

ENTACT

January 16, 2002

Remedial Action Report ILCO Superfund Site

ENTACT

February 3, 2006

III. BACKGROUND

PHYSICAL CHARACTERISTICS. The ILCO Site is located approximately 15 miles east of
Birmingham, in Leeds, Jefferson County, Alabama (see Figure 1-1, Site Location Map). The
ILCO Site consists of the ILCO Main Facility and seven satellite sites located in and around the
City of Leeds, where lead-contaminated wastes from the ILCO Main Facility were disposed.

The ILCO Main Facility is located at 1247 Borden Avenue on the southwestern side of the City
of Leeds. The ILCO Main Facility (including the ILCO Parking Lot across the street) occupies
approximately 11.5 acres of real property, most of which is owned by ILCO with a portion
owned by Interstate Trucking Company, Inc., an affiliated company.

The satellite sites include the ILCO Parking Lot, located across the street from the ILCO Main
Facility; the Gulf/BP Service Station, located in the center of Leeds on U.S. Highway 78; J&L
Fabricators, located east of Leeds on U.S. Highway 78; Fleming's Patio, located west of Leeds
on Alaska Avenue; the Connell Property, located east of Leeds in St. Clair County; the Acmar
Church of God, located off Acmar Road in Moody, Alabama; and the City of Leeds Municipal
Landfill, located off Dunavant Road at the end of Peach Street.

LANDFORMS. The ILCO Site is located in the Appalachian Valley and Ridge Physiographic
Province, within the Cahaba Valley. The area is characterized by series of linear, sub-parallel
ridges, developed on the underlying structurally deformed rock sequences, and separated by
valleys of varying widths. Topographic relief in the area is moderate to high, with rapid changes
of several hundred feet being a common feature.

SURFACE WATER. Three significant surface water bodies are present in the Leeds area.
These are the Cahaba River, located to the north of the City of Leeds; the Little Cahaba River,
which runs through Leeds; and Dry Creek, a stream that runs near the ILCO Main Facility and

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ILCO Parking Lot and flows into the Little Cahaba River in the vicinity of the wastewater
treatment plant. The general orientation of the major streams and rivers is parallel to the major
topographic structures. A smaller surface water body, identified as the Un-named Tributary to
Dry Creek, flows north, generally along the western boundary of the ILCO Main Facility,
crosses Borden Avenue, and ultimately drains into Dry Creek. The Un-named Tributary has in
the past received run-off water from the ILCO Main Facility that was highly contaminated with
lead. Even though ILCO conducted a soil and sediment removal from the tributary in August
1990, the stream is still contaminated. Surface water and sediment contamination associated with
the ILCO Main Facility is being addressed under OU-3.

GEOLOGY.

REGIONAL GEOLOGY. The suite of rocks in the Cahaba Valley is typical of the Valley and
Ridge and consists of sandstones and shales, commonly interbedded, as well as limestone and
dolomitic limestone. The regional structure is typically characterized by northeast-southwest
trending layers of rock, which are locally steeply inclined and frequently folded and faulted. The
larger structures generally dip to the southeast at angles up to 45 degrees and are intensely
fractured and jointed.

SITE-SPECIFIC GEOLOGY AND SOIL. The ILCO Main Facility is underlain by a veneer of
unconsolidated material, consisting of weathered light-brown to dark-gray, sandy, silty, clayey
alluvium that generally ranges from 5 to 20 feet thick. The Floyd Shale lies directly beneath the
alluvium along the southeast border of the property; the contact between the Floyd Shale and the
Hartselle Sandstone is in the same area. The Hartselle Sandstone is overlain by alluvium in the
southeastern portion of the property and in the area previously occupied by the battery cracking
building. The remainder of the ILCO Main Facility is underlain by the Pride Mountain
Formation, which extends to the northwest in the vicinity of Dry Creek.

GROUND WATER

REGIONAL HYDROGEOLOGY. Generally, ground water is available, in some quantity, in
four different horizons or formations in the Leeds area. These zones are not necessarily, in
themselves, major regional aquifers, but rather represent hydrogeological conditions or situations
in which a completed well may produce water more significantly than in others, such as massive
shale formations, etc. The more shallow zones are usually unconfmed, with the lower units
sometimes occurring under confined conditions, depending on the geology of the overlying
material. Because of the degree of fracturing observed in the area, it is conceivable that all zones
may, to a certain extent, be interconnected in some areas.

These zones include the following:

Surficial Aquifer - Consists of a thin layer of unconsolidated alluvial deposits
that covers most of the valley. The maximum thickness is 20 feet. It is separated
from the shallow aquifer system by a silty clay at some locations and is a very
poor source of water to wells. Water occurs under unconfmed conditions.

Shallow Aquifer - Consists of weathered to consolidated material in the upper
part of the bedrock and is generally no more than 30 feet thick. It is separated

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from the underlying rock in some areas by a dense, dark-gray clay and is a very
limited source of water to wells. Water occurs under unconfined conditions.

Fort Payne Chert Aquifer - Provides some of the water supply to the City of
Leeds. City wells are installed to depths of 150-300 feet and located .
approximately one-half mile to the northeast of the ILCO Main Facility and the
ILCO Parking Lot. The Fort Payne Chert Aquifer behaves similarly to a confined
aquifer because of the lower permeability of the overlying formations. However,
these lower permeability formations do not prevent the movement of
contaminants into the Fort Payne Chert Aquifer.

Ordovician Undifferentiated Aquifer - Consists of 1,000 feet of crystalline
limestone. Two springs in this formation provide part of the water supply to the
City of Leeds. The Weems Spring is located off Cemetery Road approximately 5
miles southeast of the Acmar Church of God satellite site in Moody, Alabama,
north of Leeds. The Rowan Spring is located in Leeds at the intersection of
Highway 119 and President Road.

SITE HYDROGEOLOGY. Ground water at the ILCO Main Facility occurs in the
unconsolidated alluvium and underlying weathered zone of shales and generally occurs in
unconfined conditions in the area. Water levels range from 4 feet to almost 50 feet below land
surface. At the ILCO Main Facility, ground water tends to flow toward Dry Creek and its
Un-named Tributary to the north and northwest of the area with infiltration into the underlying
weathered shallow aquifer, which is in the Floyd Shale, the Hartselle Sandstone, and the Pride
Mountain Formation. Data and information from monitoring well GM-2B, a deep well, indicates
that water-bearing zones occur in joints and fractures deep in the shale under partially confined
conditions.

GROUND WATER MOVEMENT PATTERNS. Based on water elevations and data
interpretations, ground water is moving generally to the northwest in the shallow and
intermediate ground water zones, with small localized differences in direction. The pattern of
movement in the deep zone is more difficult to determine, based on ground water elevations
alone. Based on measured water levels, it appears to be moving north or to the northeast, perhaps
under the influence of a large, pumping municipal water supply well used by the City of Leeds,
approximately one-half mile away. The contaminant pattern, however, indicates that it is moving
in a direction much like ground water in the shallow and intermediate ground water systems. The
possibility exists that a strong influence on flow patterns and contaminant distribution in the
deep zone is being exerted by a fault identified at the ILCO Main Facility. This is further
supported by the potential for impact on the local ground water system by the Lehigh quarry,
west of the ILCO Main Facility and south of Leeds. Several facts are pertinent. One, the quarry
is de-watered at a rate of approximately 1,000 gallons per minute, based on statements by the
quarry superintendent. Also, it is possible that the quarry is located on or closely within the
influence of the fault identified at the ILCO Main Facility. The tremendous ground water
withdrawal, which has depressed the water table by approximately 200 feet in the vicinity of the
quarry, could be de-watering the fault as far away as the ILCO Main Facility. This scenario is
further corroborated by the strong vertical downward gradient observed in the monitoring wells
along the spur adjacent to Dry Creek, where heads measured in the deep wells are approximately

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60 feet lower than in the shallow and intermediate wells. Further investigation is warranted to
conclusively define ground water movement patterns in the deep ground water system.

GROUND WATER GRADIENTS. Average ground water gradients across OU-2 were
determined for each of the three ground water zones from measured water levels. These
gradients were determined across the known affected portions of the aquifer in the regions of the
aquifer for which remediation, is anticipated. Based on these measurements, gradients of 0.016,
0.034 and 0.045 were calculated for the shallow, intermediate and deep zones, respectively.

SUB-SITE SPECIFIC HYDROGEOLOGY AT OU-1. The ground water monitoring at the
satellite sites was conducted in the local surficial aquifers found in that particular area. The rock
formations found in these surficial aquifers vary from sub-site to sub-site. The hydrogeological
discussion and the ground water remediation at the Parking Lot will is addressed in Operable
Unit 2.

The Gulf Station ground water occurs in weathered shales and Ordovician-age
limestones at 4.5 to 14.5 feet below land surface (bis). Ground water is
unconfined and flow is to the northwest, discharging from fractures in the
limestone into the Little Cahaba River. Ground water flow is shallow and to the
northwest. Water yield from these rocks varies, ranging from poor to good, as
determined by slug tests. The hydraulic conductivity of the two wells tested was
0.92 ft/d (3.3 x 10"4 cm/sec) and 35.2 ft/d (1.2 x 10"2 cm/sec). The difference in the
two hydraulic conductivities is thought to be due to fractures encountered in one
of the wells. This well produces the most water. An average hydraulic
conductivity of 18 ft/d was used. The ground water flow velocity was estimated to
be approximately 8 ft/d to the northwest.

At J&L Fabricators ground water generally occurs under unconfined conditions
from 4.5 to 7.5 feet bis in the weathered Floyd Shale. The ground water flow is to
the southwest toward dry creek from the alluvium and the Floyd Shale. The
average hydraulic conductivity of these rocks, as determined from a slug test, is
0.94 ft/d (3.3 x 10"4 cm/sec)), indicating a very poor water-yielding unit. The
ground water flow velocity was estimated to be approximately 0.22 ft/d, with
flow to the southwest.

Fleming's Patio ground water occurs in dolomites and cherty clay underlying the
fill material. The ground water is unconfined. Water levels range from about 1.5
to 83.5 feet bis. Ground water flow has been modified by the presence of a
recharge mound in the low permeability clayey chert zones and dolomitic
materials underlying the fill at the site. Surface water run-off flowing down
Alaska Avenue and from adjacent uplands percolates rapidly into the highly
permeable fill material. The water contained in the fill material then slowly seeps
downward into the underlying rock, forming a water table recharge mound. This
mound flows from the fill area toward the northeast in the northern section of the
sub-site and to the southwest in the southern section of the sub-site. The average
hydraulic conductivity of these rocks, as determined from slug tests, is 2.45 ft/d
(8.6 x 10"4 cm/sec), indicating a poor water-yielding unit. The ground water flow
velocity from the fill area, which appears to be underlain by a ground water

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recharge mound, was estimated to be approximately 6.53 ft/d to the northeast and
10.9 ft/d to the southwest due to the mounding effect.

Ground water on the Connell property is unconfined and occurs in the surficial
aquifer and the shallow weathered zone of the fractured Floyd Shale. Water levels
range from 3 to 12 feet bis. Groundwater flow is toward the northwest at depths
of about 9 feet below land surface with discharge into a marshy area. In the
northwest comer of the property, ground water levels exceed land surface
elevations, during periods of heavy precipitation. Ground water seepage occurs
during these periods of heavy precipitation. The average hydraulic conductivity of
these rocks, as determined from slug tests, is 0.93 ft/d (3.3 x 10"4 cm/sec),
indicating a very poor water-yielding unit. The ground water flow velocity is
estimated to be approximately 0.95 ft/d.

Ground water at the City of Leeds landfill occurs in clay and along fractures in
the underlying steeply inclined Floyd Shale. Water levels range from
approximately 6.5 to 25 feet bis. Based on the ground water elevations from the
three onsite monitor wells. Ground water appears to flow to the west-northwest
generally conforming to the contours of the land. The average hydraulic
conductivity of these rocks, as determined from slug tests, is 2.6 ft/d (9 x 10"4
cm/sec), indicating a poor water-yielding unit. The ground water flow velocity
was calculated to be approximately 2.95 ft/d, to the west-northwest.

At the Acmar Church of God, ground water flow is through the shales and poorly
sorted, silty sandstones, with the associated coal beds, of the Pennsylvanian-age
Pottsville Formation. Water levels in the two onsite wells range from 37 to 45 feet
bis. No ground water was encountered in the upper silty sand and shale. It is
impossible to determine the direction of ground water flow based on the ground
water levels of only two on-site wells; however, it is expected that ground water
flow follows the topographic slope to the northwest and southeast. The Weems
Spring is located approximately 5 miles southeast of the site. No other springs
have been observed in the vicinity of the site. The depth to ground water exceeds
40 feet at the site. The average hydraulic conductivity of these rocks, as
determined from slug tests, is 8.5 ft/d (3 x 10"3 cm/sec), indicating a low to
moderate water-yielding unit. The availability of only two wells at the sub-site
allowed the calculation of an approximated ground water flow velocity of 3.4 ft/d
in a southwesterly direction; it is likely to be as much as 25 to 50 percent greater
on the steep slopes of the ravine above which the site is located.

LAND AND RESOURCE USE. ILCO operated a secondary lead smelting and lead battery
recycling business from approximately 1970 to 1992 at the ILCO Main Facility. In March 1992,
ILCO ceased operating pursuant to an order of a state court of Alabama.

The ILCO Main Facility is bordered by an abandoned foundry and a wooded area to the south,
an Un-named Tributary to Dry Creek to the west, Borden Avenue and the ILCO Parking Lot to
the north, and another business to the east (see Figure 1-2, Site Layout). The area is primarily
industrial with a few residences within a half-mile radius. Property use has remained unchanged
since the RODs were signed. At this time, future land use at the main facility and the satellite

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sites is expected to be similar to the current use. Any deviations from the current use on
properties would have to comply with any restrictive covenants or deed restrictions (land or
ground water use) that have been placed on the property. Also, ground water is not used as a
source of drinking water around the ILCO Site or at the satellite sites.

HISTORY OF CONTAMINATION. ILCO manufactured refined lead alloys through the
smelting and refining of lead-bearing scrap materials. The primary materials reclaimed by ILCO
were discarded lead-acid automobile and industrial batteries. The used batteries were cracked
and the lead plates and lead oxides were smelted in a blast furnace. Furnace slag was produced
as a by-product and is regulated under the Resource Conservation and Recovery Act (RCRA) as
a characteristic hazardous waste due to its lead content.

Wastewater treatment sludge and bag house dust were also generated. Wastewater treatment
sludge is a RCRA regulated hazardous waste and bag house dust is a RCRA listed hazardous
waste (K069). ILCO stored furnace slag, battery chips, and wastewater treatment sludge in piles
on the ILCO Main Facility. Furnace slag generated by ILCO was used as fill material at the
ILCO Main Facility and at the satellite sites. Wastewater treatment sludge and battery casings
were also disposed of at the ILCO Main Facility and at some of the satellite sites.

In the early 1980s, EPA and the Alabama Department of Environmental Management (ADEM)
conducted sampling inspections of the ILCO Main Facility and found the facility to be in
violation of the Resource Conservation and Recovery Act (RCRA) interim status standards for
hazardous waste storage and disposal, and the National Pollutant Discharge Elimination System
(NPDES) discharge permit standards under the Clean Water Act.

INITIAL RESPONSE. In April 1984, EPA conducted an emergency removal action at the
Acmar Church of God site, and approximately 5,000 cubic yards of waste material and soil was
removed from the site during the immediate removal action. The waste material and soil was
transported to the Chemical Waste Management disposal facility in Emelle, Alabama.

When ILCO ceased operations in March 1992, EPA initiated a removal action to mitigate
imminent threats associated with the abandoned ILCO Main Facility. During the removal action
at the ILCO Main Facility, approximately 5,368 tons of lead contaminated slag, found stored in
different areas around the facility, were removed to a permitted hazardous waste landfill.
Approximately 200,000 gallons of lead contaminated sludge found in the onsite wastewater
treatment system was removed, stabilized, and stockpiled onsite with contaminated soil
excavated from the facility.

Acid from several impoundments was collected and treated in the onsite wastewater treatment
system, in addition to approximately 15,000,000 gallons of wastewater. The battery cracking
building, the furnace building, and the small slag vault were demolished and decontaminated due
to extensive lead contamination. The contents of the small slag vault were removed and
stockpiled onsite with the contaminated soil. Waste encountered during the demolition of the
furnace building included lead waste, bag house dust, and a sulfur residue from the emissions
system. The lead waste was stockpiled inside a building onsite. The bag house dust was placed
into two roll-off boxes, covered, labeled K069, and also stored inside a building onsite. The
sulfur residue found inside the duct pipe was placed on the contaminated soil stockpile. During
the demolition of the battery cracking building, process soil from the battery cracking operation

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were removed and stockpiled inside a building onsite. The process soil consisted of a mixture of
battery chips and contaminated soil.

BASIS FOR TAKING ACTION. Based on the historical information relating to the ILCO Site
and sampling results from the OU-1 RI, the primary contaminant at the site is lead. Soil
Remedial Action Objectives (RAOs) for the Protection of Ground water were issued by EPA in
September 1994. For soil with a low pH (< 5.0 standard units) the selected soil RAO is 150
mg/Kg lead. For soil with a normal pH (> 5.0 standard units) the selected soil RAO is 1,000
mg/Kg lead. Although lead is the primary contaminant other inorganic chemicals were detected
at the site in excess of background conditions. The secondary contaminants of concern include
antimony, arsenic, cadmium, chromium, and nickel. These contaminants were present in ground
water and soil from the site.

The following chemicals were identified as chemicals of potential concern in surface soil at the
ILCO Main Facility (OU-2): Aluminum, Antimony, Arsenic, Barium, Beryllium, Cadmium,
Chromium, Cobalt, Copper, Iron, Lead, Manganese, Nickel, Thallium, Vanadium, and Zinc. The
identification of chemicals of potential concern for surface soil was based on a comparison to
offsite concentrations and identification of essential plant and animal nutrients.

Data collected for surface and subsurface soil, sediment, surface water, and ground water during
the OU-2 RI was summarized in the Baseline Risk Assessment (BRA). This was supplemented
to some degree by data from other investigations (e.g., the removal action and the OU-1 RI).
From these data, Chemicals of Potential Concern (CPC) were selected for detailed evaluation in
the BRA. Lead was selected as a chemical of potential concern based on ILCO Main Facility
operations and investigations. Primarily based on a comparison to background data and an
evaluation of essential nutrients, additional metals were also identified as chemicals of potential
concern (i.e., were identified as potentially toxic chemicals present above naturally occurring
levels). A small number of organic chemicals detected in ground water were also identified as
chemicals of potential concern.

The decision to make the Un-named Tributary and Dry Creek a separate OU, or OU-3, was
formalized on July 7, 1994. Investigations of the creeks and waterways started in July and
August 1983 when ADEM conducted a stream and sediment sampling investigation. Additional
investigations were performed and these investigations culminated in the signing of the OU-3
ROD on September 25, 1995. Table 3 contains selected chemicals of potential concern for OU-3,
other than lead.

Exposure assessment is the estimation of the frequency, duration, and routes of exposure to
humans. Whether a chemical is actually a concern to human health and the environment depends
upon the likelihood of exposure, i.e., whether the exposure pathway is complete. A complete
exposure pathway (a sequence of events leading to contact with a chemical) is defined by the
following four elements:

a source and mechanism of release from the source,

a transport medium (e.g., surface water, air) and mechanisms of migration

through the medium,

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the presence of a receptor at the exposure point, and

a route of exposure (ingestion, inhalation, dermal absorption).

If all four elements are not present, the pathway is not complete. Although the pathways differ, at
each sub-site, the principle potential pathways of exposure for all of the ILCO sub-sites is direct
contact with contaminated soil or sediment, contaminated ground water consumption, and
inhalation of contaminated dust. The residential scenario poses potential for the greatest
exposure. The industrial/commercial scenario assumes a more limited exposure during a working
day, with reduced exposure to outside soil. The recreational scenario results in increased
exposure of children to contaminants in areas that are not expected to become residential.

OU-1 is comprised of the following:

ILCO Parking Lot (sub-site lb) - source (soil, slag, battery casings).

Gulf Service Station (sub-site 2) - source (soil, sediment), and ground water.

J&L Fabricators (sub-site 3) - source (soil, sediment) and ground water.

Fleming's Patio (sub-site 4) - source (soil, slag, treatment sludge, battery casings),
and ground water

The Connell property (sub-site 5) - source (soil, slag) and ground water.

City of Leeds landfill (sub-site 6) - source (soil, slag, treatment sludge, battery
casings) and ground water.

Acmar Church of God (sub-site 7) - source (soil, slag, treatment sludge) and
ground water.

At OU-1, the residential scenario was used to evaluate the Connell property, Fleming's Patio,
J&L Fabricators, the Gulf Service Station, and the Acmar Church of God. Exposure was
assumed to occur for 365 days/yr for 30 years. Ingestion of water is assumed to be 2 liters/day
for an adult and 1 liter/day for a child. Ingestion of soil is assumed to be 0.1 grams/day for an
adult and 0.2 grams/day for a child. Inhalation of soil is assumed to be 1.4 m3/hour for an adult
and 0.33 m3/hour for a child. Completed pathways were determined to exist at all OU-1
locations.

OU-2 is comprised of the following:

ILCO Main Facility - soil and ground water,

ILCO Parking Lot - ground water.

OU-3 contains the following:

Dry Creek and Un-named Tributary - surface water, sediment and biota.

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TABLE 2: GROUND WATER PERFORMANCE STANDARDS for OU-1 & OU-2

AMENDMENT TO RECORDS of DECISION for OU-1 & OU-2

GROUND WATER PERFORMANCE STANDARDS

Contaminant of Concern

Performance Standard (ppb)

OU-1- Satellite Sites



Antimony

5.0

Arsenic

50.0

Cadmium

10.0

Chromium

50.0

Copper

1,300.0

Lead

15.0

Nickel

100.0

OU-2 ILCO Main Facility and Parking Lot

Antimony

6.0

Arsenic

50.0

Benzene

5.0

Beryllium

4.0

Cadmium

5.0

Lead

15.0

Manganese

510.0

Nickel

100.0

1,2,4-Trimethylbenzene

51.0

1,3,5-Trimethylbenzene

41.0

13

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TABLE 3: SELECTED CHEMICALS of POTENTIAL CONCERN FOR OU-3 ILCO

SUPERFUND SITE

Chemical

Frequency
of Detection

Mean
Sample Size

Arithmetic
Mean

Range of
Detection
Limits

Range of
Detected
Concentrations

Background
Comparison
Values

In the
Vicinity of
the ILCO
Site

SEDIMENT SAMPLES

Antimony

2/21

4.94

3.5-20

15-26

ND (4.0)

Arsenic

21/21

11.6

4.8-26

Barium

17/17

43.5

12/120

Cadmium

12/17

3.2

0.3-0.48

0.68 - 12

ND (0.38)

Copper

21/21

6.4-48

29.2

Lead

21/21

1,010

65- 5,400

85.8

Manganese

17/17

422

30- 1,700

1,660

Mercury

2/21

0.062

0.05-0.2

0.07-0.25

ND(0.065)

Zinc

21/21

85.6

38-190

180

Downstream
from the
ILCO Site

SURFACE WATER SAMPLES

Lead

4/4

157

46 - 260

Zinc

4/4

7.8

60-81

164

NU- Not used; chemical was detected in all samples.
ND - Not detected; detection limit shown in parentheses.

IV. REMEDIAL ACTIONS

REMEDY SELECTION. The OU-1 ROD for the ILCO Superfund Site was signed on
September 30, 1991. The ROD for OU-2 and the Amendment to the ROD for OU-1 was signed
on October 13, 1994. The ROD for OU-3 was signed on September 25, 1995. The Summary of
Remedial Alternative Selection for Amendment to Records of Decision for Operable Units One
and Two, ILCO Superfund Site, was signed on August 27, 1996.

SELECTED REMEDY FOR OU-1 (September 30,1991): OU-1 is comprised of the seven
satellite sites listed below.

The selected alternatives for soil contamination are as follows:

The ILCO Parking Lot and Fleming's Patio:

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Excavation and solidification/stabilization of soil with lead concentrations
exceeding 300 mg/kg; replacing the treated soil back into the excavated areas;

Removal of battery casings and other debris;

Solidification of battery casing material that can be sufficiently crushed and
replacing the solidified material onsite. Off-site disposal of other debris;

Revegetation of excavated areas;

Institutional controls, consisting of access and deed restrictions, and
Long-term ground water monitoring; and

Semi-annual sampling and analysis of existing monitor wells for the primary
metals associated with automotive batteries.

The Gulf Service Station, J&L Fabricators, the Connell property, and the Acmar Church
of God:

Excavation of soil with lead concentrations exceeding 300 mg/kg;

Transportation of the excavated soil to the Parking Lot where a centrally located
treatment unit will be located;

Treatment of contaminated soil with a successfully demonstrated solidification
and stabilization process;

Placement of the solidified material into the ILCO Parking Lot sub-site (if treated
wastes are placed at the Parking Lot, then the sub-sites from which the material
originate would not need 5 year reviews, Subtitle D Closure, or deed restrictions.
Instead, these sub-sites can be backfilled with clean fill and revegetated.) or
replacement of the solidified material into its original excavation if there are
space limitations in the Parking Lot;

Removal of sediment exceeding 50 mg/kg lead, dewatering, and transport and
treatment along with the soil for sediment at the gulf station; and

Temporary relocation at the Connell property and the Acmar Church of God if
necessary.

The Leeds Municipal Landfill:

Construction of a multilayer compacted clay and geomembrane cap that would
cover areas with soil exceeding 300 mg/kg of lead; and

Institutional controls consisting of access and deed restrictions to protect the
integrity of the cap system, and long-term ground water monitoring.

15

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The selected alternatives for ground water contamination are as follows:

Gulf Service Station and Acmar Church of God:

No ground water remediation activities will be conducted at these sub-sites since
no contamination was detected; and long term ground water monitoring will be
conducted.

J&L Fabricators, Fleming's Patio, and the Connell property:

No ground water remediation activities wall be conducted at these sub-sites.
Contaminants would naturally attenuate or lessen with time; and long term ground
water monitoring will be conducted.

City of Leeds Landfill:

Extraction of contaminated ground water;

Treatment onsite with a mobile chemical/physical treatment unit;

Discharge of the ground water onsite into the adjacent drainage way (surface
outfall); and ground water monitoring during and after extraction is finished.

Statutory Determination: The selected remedy is protective of human health and the
environment, complies with federal and state requirements that are legally applicable or relevant
and appropriate to the remedial action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent practicable, and satisfies
the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element.

AMENDED REMEDY FOR OU-1 (October 13,1994):

The major components of the Amended Remedy for Operable Unit-1 include:

Excavate contaminated soil with lead concentrations exceeding 300 mg/kg;

Excavate and dewater sediment at the Gulf/BP Service Station with lead
concentrations exceeding 50 mg/kg;

Transport all contaminated soil and dewatered sediment to the ILCO Main
Facility for treatment by acid leaching (or solidification/stabilization if acid
leaching does not meet performance standards during the treatability study);

Remove slag, battery casings, and other contaminated debris from the satellite
sites and transport to the ILCO Main Facility;

Package and ship slag that can be recycled to an offsite permitted facility for
recovery of lead using a secondary smelter; non-recyclable slag will be
solidified/stabilized and disposed offsite in a permitted hazardous waste landfill,
if acid leaching is implemented; if solidification/stabilization is implemented,

16

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non-recyclable slag will be solidified/stabilized to pass TCLP and disposed in the
onsite containment cell at the ILCO Main Facility;

Package and ship battery casing components and battery chips that can be
recycled to an offsite permitted facility for recovery of lead using a secondary
smelter; non-recyclable components that fail TCLP will be disposed offsite in a
permitted hazardous waste landfill and non-hazardous, non-recyclable
components will be disposed offsite in a non-hazardous landfill, if acid leaching
is implemented; if solidification/stabilization is implemented, non-recyclable
components will be solidified/stabilized to pass TCLP, if necessary, and disposed
in the onsite containment cell at the ILCO Main Facility;

Decontaminate/treat debris using specific best demonstrated available
technologies (BDAT) based on the type of debris and the type of contaminants
present in the debris; recycle decontaminated debris that can be recycled and
dispose of decontaminated debris that cannot be recycled offsite in a
non-hazardous landfill; debris which cannot be decontaminated will be disposed
offsite in a permitted hazardous waste landfill; decontaminate any remaining
buildings and/or structures onsite;

Backfill excavated areas at the ILCO Parking Lot with treated (i.e., clean) soil
from the acid leaching process (or clean fill if solidification/stabilization is
implemented instead of acid leaching);

Backfill excavated areas at the other satellite sites, excluding the City of Leeds
Municipal Landfill, with clean fill;

Re-vegetate excavated areas once backfilled;

Temporarily relocate Connell Property residents and Acmar Church of God
congregation, if necessary; and

Monitor air emissions from the satellite sites during remedial action activities.

EPA did not amend the selected OU-1 soil (source) remedy for the City of Leeds Municipal
Landfill or any of the selected OU-1 ground water remedies.

SELECTED REMEDY FOR OU-2 (October 13,1994): OU-2 is comprised of the soil and
ground water at the ILCON Main Facility and ground water at the ILCO Parking Lot.

The selected alternatives for soil contamination are as follows:

Conduct a Site-specific field-scale treatability study to determine the
effectiveness of the acid leaching process on the types of soil at the ILCO Site
during the design phase;

If the treatability study concerning the acid leaching of contaminated soil and
other waste fails to meet the required performance standards in a cost effective

17

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and timely manner, Alternative S-3, Solidification/Stabilization, will be
implemented;

Excavate contaminated soil, treat soil to established performance standards onsite
by acid leaching, if determined to be effective during the Treatability study,
otherwise treat soil to established performance standards onsite by solidification/
stabilization

If acid leaching is implemented, backfill excavated areas onsite with treated (i.e.,
clean) soil. If solidification/stabilization is implemented, dispose of treated (i.e.,
stabilized) soil in an onsite engineered containment cell and backfill excavated
areas with clean fill. Grade and revegetate excavated areas once backfilled;

Decontaminate/treat debris using specific best demonstrated available
technologies (BOAT) based on the type of debris and the type of contaminants
present in the debris; recycle decontaminated debris that can be recycled and
dispose of decontaminated debris that cannot be recycled offsite in a
non-hazardous landfill; debris which cannot be decontaminated will be disposed
offsite in a permitted hazardous waste landfill; decontaminate any remaining
buildings and/or structures onsite;

Package and ship slag that can be recycled to an offsite permitted facility for
recovery of lead using a secondary smelter; non-recyclable slag will be solidified/
stabilized and disposed offsite in a permitted hazardous waste landfill, if acid
leaching is implemented; if solidification/stabilization is implemented,
non-recyclable slag will be solidified/stabilized to pass the Toxicity Characteristic
Leaching Procedure (TCLP) test and disposed in the onsite containment cell;

Package and ship battery casing components and battery chips that can be
recycled to an offsite permitted facility for recovery of lead using a secondary
smelter; non-recyclable components that fail TCLP will be disposed offsite in a
permitted hazardous waste landfill and non-hazardous, non-recyclable
components will be disposed offsite in a non-hazardous landfill, if acid leaching
is implemented; if solidification/stabilization is implemented, non-recyclable
components will be solidified/stabilized to pass TCLP, if necessary, and disposed
in the onsite containment cell;

Send roll-off boxes of bag house dust (K069) offsite to a RCRA permitted
Treatment, Storage, and Disposal (TSD) facility. Treatment and disposal of the
bag house dust shall comply with all pertinent ARARs, including Land Disposal
Restrictions (LDRs);

Monitor air emissions from OU-2 during remedial action activities;

The selected alternatives for ground water contamination are as follows:

Conduct additional ground water investigations on operable unit two during the
design phase to fill data gaps and determine the technical practicability of
restoring the ground water aquifer to its beneficial use;

18

-------
Pump contaminated ground water from the shallow, intermediate, and deep zones
of the aquifer, where technically practicable, using a ground water extraction
system of trenches and wells;

Treat the ground water contaminated with inorganics to established performance
standards via precipitation/flocculation using the existing on site water treatment
plant (with necessary renovation), if available;

Segregate ground water in the shallow extraction system from the intermediate
and deep ground water for treatment of both free phase and dissolved phase
hydrocarbons. Shallow ground water will pass through an organics treatment
system before entering the treatment train for inorganics shared with ground
water extracted from the intermediate and deep zones;

Discharge treated ground water effluent, meeting applicable requirements, to the
unnamed tributary adjacent to the ILCO Main Facility; and

Implement institutional controls, as necessary, for both ground water usage and
land usage at OU-2.

SELECTED REMEDY FOR OU-3: OU-3 is comprised of the Dry Creek and Un-named
Tributary. During the approximate period July 10, 1990 through September 18, 1990, 737 tons of
soil and sediment were excavated from the Un-named Tributary during an ILCO removal action.
Six hundred and seventy seven tons were shipped off-site as hazardous waste and 60 tons were
stockpiled at the on-site slag pile.

The major components of the selected remedy for OU-3 include:

Monitored natural attenuation (e.g., dilution, flushing, burial, etc.) of the
contaminated sediment

Recommending to the Alabama Department of Public Health (ADPH) that a
fishing advisory be issued for the unnamed tributary and Dry Creek near the
ILCO Main Facility

Posting of warning signs along the Un-named Tributary and Dry Creek to indicate
the presence of contaminated sediment and the fish advisory

Annual surface water; sediment, and biota monitoring

Five-year reviews as required by CERCLA devaluate the effectiveness of the
selected remedy.

SUMMARY OF REMEDIAL ALTERNATIVE SELECTION for AMENDMENT to
RECORDS of DECISION for OPERABLE UNITS ONE and TWO (August 27,1996):

AMENDED REMEDY FOR OU-1:

19

-------
The major components of the amended remedy for OU-1, as set forth in the ROD
Amendment, include:

capping of the City of Leeds Municipal Landfill,

excavation of the contaminated soil and sediment, above established cleanup
levels, from all other satellite sites,

transportation to a centralized location, preferably the ILCO Main Facility, for
treatment by solidification/stabilization,

removal of slag, battery casings, and other contaminated debris from all other
sites and transport to a centralized location for control by either recycling, or
treatment by solidification/stabilization, and off site disposal in a Subtitle D (or
state approved) landfill, is required,

backfilling of excavated areas, revegetation, and air monitoring is also required.

The ROD Amendment does not alter the previous remedy for ground water and provides for a no
further action with monitoring remedy for the Gulf/BP Station and Acmar Church of God, and a
Monitored natural attenuation remedy for J&L Fabricators, Fleming's Patio, and the Connell
Property; pump and treat for the City of Leeds Municipal Landfill.

AMENDED SOIL REMEDY FOR OU-2:

The major components of the remedy for OU-2, as set forth in the ROD Amendment,
include:

excavating contaminated soil at the ILCO Main Facility for treatment by
solidification/stabilization,

excavation of contaminated debris and control by either recycling, treatment by
solidification/stabilization,

shipment and disposal of treated material off-site at a permitted RCRA Subtitle D
(or state approved) landfill,

the contingent solidification/stabilization treatment technology is being required
because the acid leaching treatment was not fully effective, and

backfilling of excavated areas, revegetation, air monitoring, and institutional
controls are also required.

The remedy for the contaminated ground water at this OU was not amended and required pump
and treatment to established performance standards for both the ILCO Main Facility and the
ILCO Parking Lot.

20

-------
Institutional controls (deed restrictions) to prohibit future construction, development,
redevelopment, residential use or ground water use at the ILCO Main Facility and Parking Lot
have been placed in the deeds.

REMEDY IMPLEMENTATION. Pursuant to a 1997 Consent Decree (Consent Decree), the
ILCO Site Remediation Group (Group) performed a pre-design field investigation and a
remedial design. EPA approved the Group's remedial design on March 12, 1999. These remedial
actions were performed at OU-1 and OU-2.

The Group selected RMT, Inc., to perform remedial activities at the site. During the period from
January 17, 2000, to July 2, 2001, RMT, Inc. performed remedial activities at the site, which
included the excavation, treatment, and off-site disposal of 220,242.65 tons of soil and debris.
Due to continuous disagreements between the Group and RMT; RMT was released from its
contract and demobilized from the site during the period July 2-10, 2001.

The Group retained ENTACT, Inc. to complete remedial activities at the site. ENTACT, Inc.
submitted a Final Revised Workplan on January 16, 2002. Remedial activities continued until
June 6, 2002 at which time ENTACT temporarily demobilized from the site.

During the period November 2002 to September 2004, nearly a two year hiatus, AGC performed
supplemental sampling operations at the Main Site and at Industrial Development Board of
Leeds' property, adjacent to the Main Site, to delineate additional areas of lead impacted soil.

From August 23, 2004 until October 21, 2005 ENTACT excavated soil from the grids identified
by the AGC sampling operations as containing lead impacted soil.

The following remedial activities were accomplished by RMT and ENTACT:

OU-1: Seven Satellite Sites

ILCO Parking Lot - Montgomery Oil. The remedy for impacted soil, debris, and other
material is excavation, treatment to performance standards by solidification/stabilization and
disposal in an off-site permitted Subtitle D landfill.

July 7, 2000 through June 21, 2001 - RMT excavated, treated and disposed
off-site treated soil. Excavated areas were backfilled, graded and seeded.

Transportation of excavated materials to a central location for solidification/
stabilization, if necessary.

January 10, 2002 - March 25, 2002 - Excavated, treated and disposed off-site the
treated soil, performed confirmation samples and backfilled and graded excavated
areas.

Connell Property. The remedy for impacted soil, debris, and other material is excavation,
treatment to performance standards by solidification/stabilization and disposal in an off-site
permitted Subtitle D landfill.

-------
July 6, 2000 through September 21, 2000 - RMT excavated, treated and disposed
off-site treated soil. Excavated areas were backfilled, graded and seeded.

July 2000 - October 2000 - AGC conducted supplemental sampling

June 9, 2001 - RMT installed a drive way culvert.

Fleming's Patio. The remedy for impacted soil, debris, and other material is excavation,
treatment to performance standards by solidification/stabilization, and disposal in an off-site
permitted Subtitle D landfill.

May 25, 2000 through December 31, 2000 - RMT excavated, treated and disposed
off-site treated soil. Excavated areas were backfilled, graded and seeded.

July 2000 - October 2000 - AGC conducted supplemental sampling

April 26, 2001 - June 6, 2001 - RMT excavated additional contaminated soil,
transported excavated soil to Main Site for treatment, and disposed off site treated
soil.

August 6, 2001 - February 14, 2002 - ENTACT excavated contaminated soil,
treated and disposed off site the treated soil. Conducted verification sampling and
backfilled excavated areas.

March 21-22, 2002 - ENTACT conducted a subsurface soil investigation on the
Patrick Property south of Fleming's Patio and the Shelborne property to determine
if the property contained lead contaminated soil.

J&L Fabricators. The remedy for impacted soil, debris, and other material is excavation,
treatment to performance standards by solidification/stabilization and disposal in an off-site
permitted Subtitle D landfill.

July 2000 - October 2000 - AGC conducted supplemental sampling.

August 2, 2000 - May 18, 2001 - RMT excavated, treated and disposed off-site
treated soil. Excavated areas were backfilled, graded and seeded.

December 4, 2001 - December 21, 2001 - ENTACT excavated contaminated soil,
treated, and disposed off site the treated soil. Parking area was backfilled with
gravel and restored to original grade.

April 4- 5, 2002 - ENTACT excavated contaminated soil from two interior areas
of the building. The excavated areas were backfilled and concrete floor slabs
repaired.

Acmar Church of God. The remedy for impacted soil, debris, and other material is excavation,
treatment to performance standards by solidification/stabilization and disposal in an off-site
permitted Subtitle D landfill.

-------
May 22, 2000 through June 12, 2000 - RMT excavated, treated and disposed
off-site of treated soil. Excavated areas were backfilled, graded and seeded.

July 2000 - October 2000 - AGC conducted supplemental sampling.

May 18,2001 - June 6, 2001 - RMT excavated additional contaminated soil and
dumped tires. Excavated soil were transported to the Main Site for treatment and
disposed off site

January 4, 2002 - April 1, 2002 - ENTACT performed characterization sampling
during 4-7 January 2002. Initiated excavation of slope south of the church on 4
March 2002. Excavated soil were hauled to main site for treatment and off-site
disposal. Excavated tires were hauled to main site for sizing and disposal with
treated soil.

February 11, 2004 - April 20, 2004 - EPA conducted soil and tire removal at the
site and AGC performed confirmation sampling. Excavated material was stored at
the ILCO Main Site.

OU-2: ILCO Main Facility.

January 25, 2000 through June, 13, 200 - RMT excavated, treated and disposed
off-site treated soil and debris from the small stockpile, Interstate Trucking
Building, large stockpile, and slag vault located at the Main Facility.

Early 2001 - RMT constructed storm water retention pond to contain storm water
run-off

April 15, 2001 - June 6, 2001 - RMT excavated, treated and disposed off site
contaminated soil from the process area.

July 2-10, 2001 - RMT demobilized from site, replaced by ENTACT.

July 23 - August 14, 2001 - ENTACT mobilizes on-site.

August 14, 2001 - October 22, 2001 - ENTACT starts screening, treating and
disposal off site of existing soil stockpiles. Conducted pilot testing for treatment
of contaminated soil, battery casings, and oversize debris.

October 11, 2001 - June 7, 2002 - ENTACT excavated, treated and disposed off
site the treated soil, conducted verification sampling and backfilling of excavated
area. Performed grubbing and clearing operations in areas west and south of Main
Facility.

January 22, 2002 - April 5, 2002 - ENTACT loaded out K069 baghouse dust and
lead slag buttons for off-site disposal.

23

-------
January 30, 2002 - April 11, 2002 - ENTACT started decontamination procedures
on the maintenance building and on-site concrete foundations. Collected and
disposed of contamination and storm water.

April 3, 2002 - Pre-final inspection of site

April 15, 2002 - June 10, 2002 - ENTACT initiated temporary demobilization, but
was stopped when additional areas requiring excavation were discovered. After
excavation completed temporary demobilization.

November 2002 - September 2004 - AGC conducted supplemental soil sampling
activities on site and adjacent to the Main Site.

August 23, 2005 - October 21, 2005 - ENTACT excavated the contaminated soil
identified during the supplemental soil sampling. These soil and the stockpiled
material from the Acmar Church of God were shipped off-site for disposal.

TABLE - 4 QUANTITIES OF EXCAVATED AND D]

[SPOSED MATERIAL

Site Name

RMT
Jan 2000 -
Jul 2001
Quantity (tons)

ENTACT
Jul 2001-
Jun 2002
Quantity (tons)

ENTACT
Jul 2005 -
Nov 2005
Quantity (tons)

Total
Quantity
(tons)

Main Site









Soil/Debris

97,118.19

97,020.62

6,980.49

201,119.30

Debris

5,409.53





5,409.53

Acmar Church of God

1,064.10

4,000.90



5,065.00

Fleming's Patio

31,864.26

19,438.89



51,303.15

Connell Property

3,009.25





3,009.25

J&L Fabricators

13,010.45

4,943.90



17,954.35

Montgomery Oil



997.55



997.55

ILCO Parking Lot

68,766.87

2,452.84



71,219.71

Total

220,242.65

128,854.70

6,980.49

356,077.84

OU-3: Dry Creek and Un-named Tributary: During the approximate period July 10, 1990
through September 18, 1990, 737 tons of soil and sediment were excavated from the Un-named
tributary during an ILCO removal action. Six hundred and seventy seven tons were shipped
off-site as hazardous waste and 60 tons were stockpiled at the on-site slag pile.

Other components of the remedy for all sites, such as dust control, erosion and sedimentation
control, air monitoring, and health and safety were implemented as outlined in the remedial
design.

24

-------
This remediation was completed on November 29, 2005, with the Final Site Inspection. The
Final Remedial Action Report was completed in February 2006.

INSTITUTIONAL CONTROLS. Institutional controls (deed restrictions) have been placed on
the following properties associated with the ILCO Site: (1) Fleming's Patio (Shelborne
Property); (2) J&L Fabricators; (3) Industrial Development Board of the City of Leeds (IDE); (4)
the ILCO Property; and (5) the ILCO Parking Lot. The declarations of restrictions for each
property indicate that: (1) no construction, development, redevelopment, or other action that will
in any way disturb the property will be allowed; and (2) no drilling of any kind, including for
water, shall be allowed, and the ground water shall not be used for potable water. Deed
restrictions for the J&L Fabricators, IDB Property, the ILCO Parking Lot, and ILCO property
also indicate that the properties cannot be developed or utilized for residential use.

Currently institutional controls are not yet in place for Dry Creek and the Un-named Tributary.
The institutional controls will be addressed by the PRPs during an upcoming phase the ground
water/surface water sampling and remediation activities which are on-Going. Institutional
controls for Dry Creek and the Un-named Tributary are expected to be put in place by the PRPs
within the next year. Institutional controls are no longer required at the Leeds Municipal Landfill
because the cap was not installed as identified in the ROD. The rational for the post ROD change
will be discussed by EPA, in an appropriate decision document.

SYSTEMS OPERATION/OPERATIONS AND MAINTENANCE (O&M). Currently there
is not an O&M Plan prepared for the ILCO Site. If an O&M Plan was in-place it should, at a
minimum, address the following items:

Periodic inspections of the excavated and backfilled areas to insure the problems
with erosion are not becoming issues.

The City of Leeds Landfill cap should also be periodically inspected to insure that
settlement of the cap and erosion of the side slopes is not becoming a problem.
Monitoring wells should be inspected at each inspection to insure that the locking
covers are secure, casing and bollards should be painted regularly, and the areas
around the wells mowed to facilitate locating the wells.

The results of the periodic inspections should be forwarded to the appropriate
agencies and other interested parties.

At the ILCO main Site the haul roads should be maintained to allow for minimal
traffic during inspections.

Discussions with Leeds Environmental indicates that approximately $25,000.00 was spent on
inspections, fence repair and similar items during the two year construction hiatus while
additional sampling was being conducted to delineate additional areas for remediation.

When the ground water remedy is implemented additional system operations and O&M will be
required, along with an appropriate O&M manual for the ground water treatment systems.

Ground water monitoring at OUs 1 and 2 has not been conducted on a regular basis. Refer to
Section VI - Data Review to examine the erratic nature of the sampling dates. No sample data
has been collected at OU-3 since the January 2000 Baseline sampling event.

-------
V. PROGRESS SINCE LAST 5-YEAR REVIEW

This was the initial 5-Year Review of the ILCO Site.

VI. FIVE-YEAR REVIEW PROCESS

ADMINISTRATIVE COMPONENTS. EPA arranged for USACE to conduct the initial
Five-Year Review at the ILCO Superfund Site. The review team was lead by Mr. Charles L.
King, Remedial Project Manager for the ILCO Site. The Site Inspection was lead by Mr. Ernest
R. McCollum and was attended by personnel from ADEM.. The primary activities associated
with this review include:

Document Review;

Data Review;

Site Inspection;

Local Interviews; and

Five Year Review Report Development and Review

COMMUNITY NOTIFICATION AND INVOLVEMENT A public notice announcing
initiation of the first five year review for the ILCO site was published in the Leeds News on
September 21, 2006. Upon signature, the report will be placed at the following repositories for
the site: Leeds Public Library in Leeds, Alabama, and the EPA Region 4 office in Atlanta,
Georgia. A copy of the notice is provided in Attachment 6 of this report.

DOCUMENT REVIEW. The documents reviewed for the preparation of this Five-Year Review
are listed in Attachment 3, List of Documents Reviewed.

DATA REVIEW. All soil above the lead action limits, 1000 mg/kg at the ILCO Main Site and
surface soilwith arsenic concentrations exceeding 30 mg/kg; was excavated, treated and disposed
of in an approved landfill. At the satellite sites, soil contaminated with lead above 300 mg/kg
was excavated, treated and disposed of in an approved landfill. The excavated areas were
backfilled with clean soil. Confirmation sampling data in the Remedial Action Report, February
3, 2006, confirms that the areas were remediated to below the selected action limits.

In January 2000 a baseline sampling event for surface water, sediment and biota was conducted
for OU-3, the Un named Tributary and Dry Creek. The samples were collected just prior to the
start of remedial actions at OU-1 and OU-2.

Electro-shock sampling methods were employed in an effort to secure fish samples, but no fish
were collected. There is no baseline data for biota from this sampling event.

Corresponding surface water and sediment samples were collected from nine sampling locations
along the Un named Tributary and Dry Creek. The results of the baseline sampling are presented
in Tables 4 and 5. No surface water, sediment or biota samples have been collected since the
January 2000 event. Based on this data and risk calculations a clean-up level of 158.7 ppm was
selected.

-------
TABLE 5 - LEAD CONCENTRATION IN SURFACE WATER,
ILCO SUPERFUND SITE (OU-3)

Location

Date

Lead (mg/L)

DC1

01/07/2000

0.003U

DC2

01/07/2000

0.003U

DC3

01/07/2000

0.003U

DC3 (dup)

01/07/2000

0.003U

UT1

01/07/2000

0.003U

UT2

01/07/2000

0.003U

UT3(1)

01/07/2000

0.011

UT4

01/07/2000

0.003U

UT5

01/07/2000

0.023 U

U- not detected above the listed reporting limit
(1) Sample was collected after a rain event.
DC- Dry Creek
UT- Un-named Tributary

TABLE 6 - LEAD CONCENTRATIONS IN SEDIMENT
ILCO SUPERFUND SITE (OU-3)

Location

Date

Lead (mg/Kg)

Total Solids (%)

DC1

01/12/2000

15.9

80.4

DC2

01/12/2000

109.0

52.4

DC3

01/12/2000

326.0

48

DC3 (dup)

01/12/2000

294.0

46.2

UT1

01/12/2000

22.5

73.7

UT2

01/12/2000

23.7

73.6

UT3(1)

01/12/2000

47.9

62.9

UT4

01/12/2000

58.5

80.1

UT5

01/12/2000

518.0

68.9

3C- Dry Creek

UT- Un-named Tributary

27

-------
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02/01/88

07/15/90

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4/16/97

2/19/98

11/8/99

1/6/00

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6/30/04

7/25/05

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28

-------


















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Date

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02/01/88

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07/15/93

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29

-------
The four graphs above represent the conditions at the ILCO Main Facility. The analytical history
of some of the wells are represented by the graphs for wells GM-1 and GM-2B. These wells had
high levels of lead contamination at the initial sampling and have concentrations of lead that
have varied considerably but are generally in excess of the 15 |ig/L performance standard.

The graph for well GM-13S is representative of a number of the wells. The initial sampling event
indicated an elevated level of lead, but subsequent sampling events have indicated steadily
declining concentrations of lead in the ground water.

Other wells are represented by the graph of well MW-8. The initial sampling event detected
levels of lead above the 15 |ig/L performance standard. Subsequent sampling events have
detected varying concentrations of lead in the ground water. The detected concentrations of lead
vary from below the detection limit to near or above the performance standard.

The ROD mandated a pump and treat system for the ILCO Main Site. During discussions with
the PRP Contractor it was indicated that EPA is considering the PRP's request to replace the
current selected remedy for addressing ground water (pump and treat) with another remedy
(alternate concentration limits or monitored natural attenuation). The review of the ground water
monitoring data for the ILCO Main Site indicates that since the soil removal, lead has not been
found in the ground water at the main facility or the ILCO Parking Lot above the action level of
15 |ig/l. The concentraton of other primary inorganic constituents in ground water have
decreased over time and are present at concentrations above their respective performance
standards only in the vicinity of the battery breaker. EPA expects to evaluate the PRP's results
from past and several future ground water sampling events, to determine the effectiveness of the
source removal that has occurred. Based on the results of the ground water sampling events, EPA
in consultation with the Alabama Department of Environmental Management, will determine if
the installation of the pump and treatment will still be required or if the ROD should be amended
and another remedy for the site should be pursued. EPA expects to have enough data to make
this decision before the next five year review is required.

CONNELL PROPERTY

WELL

LEAD

DATE

3/1/1987

2/1/1988

6/12/90- 8/8/90

6/24/97- 7/2/97

11/11/1999

1/5/2000

GC-1

15UG/L

59J

GC-2

15UG/L

GC-3

15UG/L

34J

3.8U

GCS-1

15UG/L

49 J

GCS-2

15UG/L

38J

NT = Not Tested

U = Not detected above the listed Reporting Limit (15 |ig/L)

J = Constituent concentration is estimated
G = Elevated Reporting Limit

The data for the Connell Property indicates that monitored natural attenuation is occurring at the
site. All of the wells except GC-2 had initial lead concentrations above the 15 |ig/L performance
standard followed by decreasing concentrations in later sampling events.

-------
FLEMING'S PATIO (lead in GW, ng/L)

DATE

GF-2A

GF-2B

GF-3

GF-5

GF-6*

GF-7

GFS-1

GFS-2

3/1/1987

8J

6J

5UJ











2/1/1988

20UJ

8UJ

5UJ







10J

43J

6/12/90-
8/8/90

30UJ

6UJ

4UJ

9UJ

180J

6

4UJ



6/24/97-
7/2/97

9.1

92.9

3U

23.5



9.3

3U



11/11/1999







NM-D









12/9/1999

NM-T

3U













1/8/2004

3U

3U



NT









6/29/2004

3U

3U



29









7/26/2005

3UJ



3U

23J









Bold = Concentration exceeds criteria	NT = Not tested

J = Constituent concentration is estimated	U = Not detected above level indicated

NM-T = Well not sampled due to high turbidity * = Well abandoned during 2000 remedial activities

At Fleming's Patio the data from one of the monitoring wells (GF-5) indicate that contaminated
ground water continues to leave the site, and additional monitoring and evaluation is needed.
Based on the results of the evaluation, ground water and soil remediation may be required. The
majority of the ground water data was collected prior to the soil remediation activities in the
area. Additional ground water monitoring to evaluate the effectiveness of the soil remediation is
required for this site. In the short term, protection is achieved by a deed restriction prohibiting
the use of ground water

J&L FABRICATORS (lead in GW, mg/L)

WELL NUMBER

DATE

GJ-1

GJ-1D

JG-2

GJ-3

JGS-3

GJ-4*

03/01/87

39J



6J

91J





02/01/88

10UJ

10

10UJ

20UJ

2U



6/12/90-
8/8/90

2U

3U

2U

2U

2U

96J

6/24/97-
7/2/97

3U









7

11/11/99

3U









4

12/09/99













01/07/04

3U











01/08/04













06/28/04

3U











06/29/04













07/26/05













Bold = Concentration exceeds criteria	J = Constituent concentration is estimated

31

-------
NM-T = Well not sampled due to high turbidity NT = Not tested

U = Not detected above level indicated	* = Well abandoned during 2000 remedial activities

The furnished ground water monitoring for J&L Fabricators is very minimal. Well GJ-1 is the
only well with enough sampling data to allow the formation of any conclusion as to what is
occurring in the aquifer. Based solely on well GJ-1, it appears that monitored natural attenuation
is occurring at the site.

GULF/BP STATION (lead in GW, mg/L)

WELL NUMBER

DATE

GG-1

GGS-2

GG-2

GG-3

03/01/87

63J



75 J



02/01/88

30UJ

27J

20UJ



6/12/90- 8/8/90

2U

20UJ



7

6/24/97- 7/2/97

3U

3U

3U

3U

Bold = Concentration exceeds criteria	J = Constituent concentration is estimated

NM-T = Well not sampled due to high turbidity NT = Not tested

U = Not detected above level indicated	* = Well abandoned during 2000 remedial activities

The furnished data for the Gulf/BP Station has relatively few sampling events but appears to
support the NFA ground water remedy.

CITY OF LEEDS LANDFILL (lead in GW, ng/L)

WELL NUMBER

DATE

GL-1

GL-2

GJ-3

07/16/90



24

44

07/19/90

6UJ





04/28/97

3U

3U



04/29/97





3U

03/13/98

3U

3U



11/11/99

3U





12/08/99



3U

3U

01/06/04

3U



3U

06/28/04

3U



3U

Bold = Concentration exceeds criteria	J = Constituent concentration is estimated

NM-T = Well not sampled due to high turbidity NT = Not tested
U = Not detected above level indicated

The monitoring well data appears to indicate the concentration of lead in the ground water has
diminished to well below the performance standard, 15 |ig/L, since the initial sampling of the
wells. It appears that monitored natural attenuation is occurring at this site.

32

-------
ACMAR CHURCH OF GOD (lead in GW, ng/L)

WELL NUMBER

DATE

GA-1

GA-2

6/12/90- 8/8/90

6

10

6/24/97- 7/2/97

3U

3U

11/12/99



NM-T

01/06/04



3U

06/28/04



3U

Bold = Concentration exceeds criteria	J = Constituent concentration is estimated

NM-T = Well not sampled due to high turbidity NT = Not tested
U = Not detected above level indicated

Although the number of sampling events is low, the concentration of lead in the ground water
appears to be well below the performance standard of 15 |ig/L. This data supports the NFA
ground water remedy.

ILCO PARKING LOT (lead in GW, ng/L)

WELL NUMBER

DATE

GP-1B

GP-2A

GP-3A

GPD-1

GPS-2

3/1/1987

31J

40U



3 90J



2/1/1988

85

36

22



3300J

6/16/1990









11,000J

6/16/1990







13J



7/11/1990

5J

19







7/12/1990





230J





7/13/1993





2.5U





7/14/1993

2.5U

26



80

83

4/21/1997

3U

3U







4/22/1997







3U



4/25/1997





3U





4/30/1997









3.8

2/18/1998







3U

3U

3/2/1998



3U







3/10/1998











3/12/1998





3U





11/10/1999









3U

1/6/2000









3U

33

-------
Bold = Concentration exceeds criteria J = Constituent concentration is estimated

NM-T = Well not sampled due to high turbidity NT = Not tested
U = Not detected above level indicated

The ground water monitoring results reflect the same patterns as those from the Main Facility.
The above chart reflects the same patterns as those exhibited at the Main Facility. The ROD
mandated a pump and treat system for the ILCO Parking Lot. During discussions with the PRP
Contractor it was indicated that EPA is reviewing the selected remedy and pump and treat may
be replaced with another remedy. The review of the ground water monitoring data for the ILCO
Parking indicates that additional regularly scheduled sampling events are required until the final
ground water remedy is selected and installed.

SITE INSPECTION. The Site Inspection was conducted on January 11, 2006. The attendees
met at the ILCO Main Site at 10:00 AM. The site inspection attendees are listed in Table 6.

TABLE 7: SITE INSPECTION ATTENDEES

Name

Representing

Telephone No.

E-mail Address

Ernest R. McCollum

Corps of Engineers

(251)690-3113

Ernest.R.McCollum@sam.usace.army.mil

Sarah Gill

ADEM

(334) 271-7734

sgill@adem.state.al.us

C. H. Cox

ADEM

(334) 271-7786

chc@adem.state.al.us

Chris Allen

Black & Veatch

(770) 521-8113

allencj@bv.com

The site inspection team initiated the site inspection by touring the ILCO Main Site. Mr. Chris
Allen pointed out the locations of the structures which had been demolished as a part of the site
remediation. Mr. Allen also pointed out the stockpile area where soil and debris from off-site
were stockpiled while awaiting treatment. The excavated areas around the demolished structures
are not grassed, but are not showing signs of significant erosion at this time. The haul roads, not
surfaced with crushed rock, are being maintained by mowing and are in usable condition during
periods of dry weather. The rock surfaced haul roads are in acceptable condition and are suitable
for light use during wet weather. Numerous ground water monitoring wells were observed at the
site. The protective outer casings and bollards need to be wire brushed and painted to restore
their visibility.

The ILCO Parking Lot was observed after the inspection of the ILCO Main Facility. At the time
of the site inspection, the ILCO Parking Lot had the appearance of a man-made wetland. Much
of the site was covered with standing water and various plants. Due to the conditions at the ILCO
Parking Lot no attempt was made to walk the site.

The City of Leeds Landfill was inspected after viewing the ILCO Parking Lot. The guard shack
and gate to the facility are in poor condition and the site is not secured. It appears that the site
was capped and the slopes vegetated. The condition of the slopes was difficult to determine
because of all the dead kudzu and other vegetation on the slopes. The site has become an
unregulated "stump dump" and C&D landfill. There was evidence of recent dumping at the site
(fresh tire tracks after an overnight rain). Much of the top of to cap is covered with stumps,
limbs, woody debris and C&D material. There is also evidence of pushing material off the top of
the cap and down the slopes.

-------
J&L Fabricators was inspected after the Leeds landfill. This site was in very good condition. The
backfill around the edge of the building is in good condition with no evidence of settlement. The
Parking Lot backfill is in good condition, also. The berms between the Parking Lot and the
drainage ditches around the sides and back of the site are in good condition and appear to be
performing as design to prevent storm water run off from the site entering the drainages.

The Connell Property was inspected after J&L Fabricators. The excavated and back filled areas
around the dwelling and in the yard appeared to be in good condition, except for the area around
the basement door. This area was very wet and showed evidence of recent soil removal and
grading. Mr. Connell approached the team and expressed his anger over two issues. Mr. Connell
stated that the remediation contractor did not reinstall the foundation drains around the basement
walls when he back filled around the basement and now he had water in his basement. The
recent excavation was an attempt to restore drainage for the basement. Also, he had been
informed by letter that the monitoring wells on his property would be abandoned and nothing
had happened. Ms. Sarah Gill, ADEM, stated that the contractor performing the abandonment
had not been complying with ADEM standards. ADEM is working to get the well abandonment
back on track.

The Acmar Church of God was the next stop for the inspection team. The ILCO Parking Lot and
area around the buildings is in good condition except for an area of ponded water adjacent to the
steep slope. It appears that someone has tried to ditch from the ponded water to the edge of the
slope, which is starting to cause minor erosion in the slope. The sloped area from the church yard
and ILCO Parking Lot to the creek appears to be in good condition and is covered with
vegetation.

The Gulf Service Station is a fenced area adjacent to the service station. The gate was not locked
when we arrived at the site. The backfill appears to be in good condition with no signs of
settlement and the side slopes do not appear to be affected by erosion. The top of the back fill is
covered with a thin layer of gravel size crushed rock and the site is vegetated with grasses and
brushy plants.

The final area inspected was Fleming's Patio. The Parking Lot area is well graded and covered
with crushed rock. The other excavated areas are grassed and well maintained with no evidence
of erosion.

INTERVIEWS.

INTERVIEW DOCUMENTATION FORM

The following is a list of individuals interviewed for this five-year review. See the attached contact records,

Attachment 8, for a detailed summary of the interviews

Name

Title/Position

Organization

Date

Sarah Gill

Environmental Eng.

ADEM

15 Mar 2006

Jeffrey A. Leed

Environmental Eng.

Leed Environmental, Inc.

16 Mar 2006

-------
VII. TECHNICAL ASSESSMENT

QUESTION A: IS Till REMEDY FUNCTIONING AS INTENDED BY THE DECISION
DOCUMENTS?

The review of documents, ARARs, risk assumptions, and the results of the site inspection
indicates that the soil/sediment remedy is expected to be functioning as intended by the RODs,
as amended. Additional ground water monitoring will be conducted and the results evaluated to
confirm that the remedy is functioning as intended. The excavation, stabilization/solidification,
and off-site disposal of contaminated soil and sediment has achieved the remedial objective of
removing the primary source from the site. The removal of the primary source of contamination
is expected to reduce or minimize the migration of contaminants to ground water and surface
water and prevent direct contact with, or ingestion of, contaminants in soil and sediment.

There is no system optimization required for the soil remedy, as there is nothing to optimize. At
the satellite sites, contaminated soil have been removed so there is no possibility for direct
contact with or ingestion of contaminated soil. At the ILCO Main Site, soil were remediated to
1,000 mg/kg lead, the industrial reuse criteria and 30 mg/kg arsenic. At the Main Site, soil with
concentrations of lead greater than 300 mg/kg, the residential clean up standard, are present The
ILCO Main site is secured with a locked fence to prevent unauthorized access and possible direct
contact with contaminated soil.

The final ground water remedy, pump and treat, prescribed in the ROD for the ILCO Main
Facility, Parking Lot, and the City of Leeds Landfill has not been installed at this time and
evaluation is not possible. The remedy selected for the Connell Property, J&L Fabricators and
Fleming's Patio, MNA with monitoring is working as intended.

Institutional controls (deed restrictions) have been placed on the following properties associated
with the ILCO Site: (1) Fleming's Patio (Shelborne Property); (2) J&L Fabricators; (3) Industrial
Development Board of the City of Leeds (IDB); and (4) the ILCO Property. The declarations of
restrictions for each property indicate that: (1) no construction, development, redevelopment, or
other action that will in any way disturb the property will be allowed; and (2) no drilling of any
kind, including for water, shall be allowed, and the ground water shall not be used for potable
water. The declarations of restrictions for the J&L Fabricators, IDB Property and ILCO property
also indicate that the properties cannot be developed or utilized for residential use. Currently
Institutional Controls (ICs) are not yet in place for Dry Creek and the Un-named Tributary. The
ICs will be addressed by the PRPs during an upcoming phase the ground water/surface water
sampling and remediation activities which are on-going. ICs for Dry Creek and the Un-named
Tributary are expected to be put in place by the PRPs within the next year. The Institutional
controls are no longer required at the Leeds Municipal Landfill because the cap was not installed
as identified in the ROD. The rational for the post ROD change will be discussed by EPA, in an
appropriate decision document (ESD or ROD Amendment).

QUESTION B: ARE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEAN UP
LEVELS AND REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF
THE REMEDY STILL VALID?

-------
Since the RODs for this site have been issued, updates to the ground water MCLs for arsenic and
cadmium have been made (noted in Table 9). The MCL changes could alter the scope of the
remedy at the site. Until the results from several recent (post-soil removal) iterations of ground
water monitoring events are evaluated it cannot be determined if the remedial action objectives
identified in the RODs are still valid. After EPA has evaluated sufficient ground water data from
the site and compared it to the current MCLs, the RAOs that are still valid will be noted. If the
initial RAOs are no longer valid, revised RAOs and if necessary, remedy modifications will be
documented in the appropriate post ROD change format. The evaluations and the appropriate
decisions are currently expected to be implemented and documented in the next scheduled five
year review for this site. All cleanup levels in the ROD were met during cleanup activities.

There have been several changes in the Chronic Oral Reference Dose (RfD) and in the listed
Oral Slope Factors for Chemicals of Concern (COCs) since the signing of the RODs. Table 8:
Comparison of Oral Toxicity Values lists the changes between the ROD values and the current
values listed in IRIS. The changes do not affect the efficacy of the soil remedy because the
contaminated soil were excavated to the appropriate levels for the selected use or reuse, treated
and disposed of off-site.

Table 9: Comparison of ROD Performance Standards to Current MCLs, indicates only two
important changes in the standards since the signing of the RODs. The MCL for cadmium has
decreased from 10 ppb to 5 ppb. The change of primary importance to the ILCO site occurred on
23 January 2006 when the MCL for arsenic changed from 50 |ig/L to 10 |ig/L, this is a major
change to the clean-up level.

The exposure assumptions for the Baseline Risk Assessment and the Human Health Risk
Assessment for the ILCO Main Site have remained unchanged. The primary focus of the risk
assessment for the main site was the trespasser and that would still be correct at this time. The
ILCO site has been remediated to 1,000 mg/Kg of lead, which is the industrial clean up standard
for soil with a pH >5 and to 150 mg/Kg for soil with a pH <5. At the main facility soil containing
arsenic at concentration above 30 mg/kg were also excavated in accordance with the 1996
Amended ROD.

Ground water exposure pathways remain intact at this time, however based on data since the soil
excavation activities concentrations of COCs in ground water appear be reducing due to source
removal and monitored natural attenuation.

Land use has remained unchanged and no new exposure pathways have been opened.

With soil and sediment remediation completed, the ARARs for soil and sediment contamination
cited in the amended RODs have been met. The implementation of the ground water remedy will
be required to determine if the ARARs for ground water contamination, cited in the RODs, will
be met.

-------
TABLE 8: COMPARISON OF ORAL TOXICITY VALES

ROD VALUES

CURRENT VALUES

COC

Chronic

Oral
Reference
Dose (RfD)
(mg/kg-
day)

Oral
Slope
Factor
(mg/kg-
day)"

Weight-

of-
Evidence
Class

Chronic

Oral
Reference
Dose
(RfD)
(mg/kg-
day)

Oral
Slope
Factor
(mg/kg-
day)"

Weight-

of-
Evidence
Class

Antimony

4E-04

-

-

-

-

-

Arsenic

3E-04

1.75+00

A

-

1.5E+0

-

Benzene

4E-03

2.9E-02

A

-

1.5 to
5.5E-02

-

Beryllium

5E-03

4.3E+00

B2

2E-03

-

B1

Cadmium

5E-04

*

*

-

-

B1

Chromium III

1E+00

*

*

1.5E+0

-

D

Chromium IV

5E-03

*

*

3E-03

-

A

Manganese

5E-03

*

D

1.4E-1

-

-

Nickel

2E-02

*

*

-

-

-

1,2,4-

T rimethylbenzene

5E-04 #

*

*

5.0E-02 A





1,3,5-

Trimethylbenzene

4E-04 #

*

*

5.0E-02 A

_



Unless noted all values listed are from IRIS

*	= No value listed in ROD

- = No change from original criteria

#	= Environmental Criteria and Assessment Office (ECAO)
A = Toxicity Value listed on Region 9 PRG List

Documents and Databases reviewed include the following:

•	National Primary Drinking Water Regulations- List of.Drinking Water
Contaminants and MCLs

•	National Secondary Drinking Water Regulations

•	Region 9 PRG List

•	2004 Edition of Drinking Water Standards and Health Advisories

•	Integrated Risk Information System (IRIS)

38

-------
TABLE 9: COMPARISON OF ROD PERFORMANCE
STANDARDS TO CURRENT MCLs

AMENDED GROUND WATER PERFORMANCE STANDARDS FOR

OU-1 AND OU-2 vs. CURRENT MCLs



ROD



Contaminant

Performance Standard

Current MCL

of Concern

(ppb)

(ppb)

OU-1 Satellite Sites

Antimony

6.0

6.0

Arsenic

50.0

10.0

Cadmium

10.0

5.0

Chromium

50.0

100.0

Copper

1,300.0

1,300.0

Lead

15.0

15.0

Nickel

100.0

100.0*

OU-2 ILCO Main Site and Parking Lot

Antimony

6.0

6.0

Arsenic

50.0

10.0

Benzene

5.0

5.0

Beryllium

4.0

4.0

Lead

15.0

15.0

Manganese

510.0

50.0**



ROD



Contaminant

Performance Standard

Current MCL

of Concern

(ppb)

(ppb)

Nickel

100.0

100.0*

1,2,4-Trimethylbenzene

51.0

j 2 CM -)

1,3,5-Trimethylbenzene

41.0

12 WW

*Nickel was remanded from the MCLs on 2/9/95, however EPA is reconsidering the
status of nickel and is using the former MCLG of lOOppb as an MCL.

** Manganese is a Secondary Drinking Water MCL

- This is an Unregulated contaminant with no MCL or HA according to the 2004 Edition
of Drinking Water Standards and Health Advisories.

A This is an Unregulated Contaminant with no MCL, it does have a one-day HA for a 10-
kg child of 10 mg/L according to the 2004 Edition of Drinking Water Standards and
Health Advisories.

# - Region 9 PRG for Tap Water.

39

-------
QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD
CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY?

No other information is available that questions the protectiveness of the remedies. No new
ecological risks have been noted And known ecological risks were addressed in the various
biological and risk assessments performed for OU-3.

Further more, there have been no weather or other natural disasters that have affected the remedy
for soil and sediment.

SUMMARY OF TECHNICAL ASSESSMENT. The soil remedy for the ILCO Main Site and
Satellite sites has removed the contaminated soil above the action levels, the principal threat at
the site and is expected to perform as intended. The pump and treat ground water remedy for the
ILCO Main Site, Parking Lot and the City Of Leeds Landfill has not been implemented and
MCL changes, arsenic in particular, will require treatment to lower standards than required by
the ROD. Only baseline samples have been collected as a part of the remedy selected for OU-3.
It is not possible to analyze the effectiveness of this OU3 remedy until additional sediment and
surface water samples have been collected . Currently Institutional Controls (ICs) are not yet in
place for Dry Creek and the Un-named Tributary. The ICs will be addressed by the PRPs during
an upcoming phase the ground water/surface water sampling and remediation activities which
are on-going. ICs for Dry Creek and the Un-named Tributary are expected to be put in place by
the PRPs within the next year. The Institutional controls are no longer required at the Leeds
Municipal Landfill because the cap was not installed as identified in the ROD. The rational for
the post ROD change will be discussed by EPA, in an appropriate decision document (ESD or
ROD Amendment).

VIII. ISSUES

Table 10 provides a summary of the issues at the ILCO Site that were identified during this
Five-Year Review.

TABLE 10: ISSUES

Issue

Currently Affects
Protectiveness
(Y/N)

Affects Future
Protectiveness
(Y/N)

Monitoring wells are not being properly maintained.

Surface water is ponding near the ILCO Parking Lot.

An Operation and Maintenance Plan has not been prepared for the Site.

Foundation drains may not have been installed properly on the Connell
Property and water is collecting in the basement.

Trench erosion may be occurring at the Acmar Church of God.

Additional ground water sampling is necessary at Fleming's Patio, the
ILCO Main Facility, ILCO Parking Lot, and the City of Leeds Landfill
to support a final decision regarding implementation of ground water
pump and treat system and potential ROD changes.

-------
Sufficient sampling data is not available from the Un-Named Tributary
and Dry Creek to make a protectiveness determination

N

Y

Site-wide ground water data needs to be evaluated to ensure that soil
excavations continue to be protective of ground water

N

Y

Institutional controls for the Un-named Tributary and Dry Creek need to
be implemented, as required by the OU-3 ROD.

Y

Y

The MCLs for arsenic and cadmium have been lowered and an
evaluation has not been done on the impact to the ground water
remedies.

Y

Y

ROD components that have either changed, or are no longer necessary
have not been administratively addressed.

N

N

IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS

TABLE 11: RECOMMENDATIONS and FOLLO

W-UP AC!

[TONS

Issue

Recommendations/
Follow-up Actions

Party
Responsible

Oversight
Agency

Milestone
Date

Affects
Protectiveness?
(Y/N)

Current

Future

Monitoring wells
are not being
properly
maintained.

Repair, paint, check
locks.

PRP

EPA/State

December
2006

N

N

Surface water is
ponding near the
ILCO Parking Lot.

Pump out water, dry
site and add
additional fill
material to direct
run off to ditches.

PRP

EPA/State

February
2007

N

N

An Operation and
Maintenance Plan
has not been
prepared for the
Site.

Finalize the draft
O&M plan.

PRP

EPA/State

January
2007

N

Y

Trench erosion
maybe occurring at
the Acmar Church
of God.

Determine if
contractor omitted
replacement
foundation drains
and correct
problem, if
necessary.

PRP

EPA/State

December
2006

N

N

41

-------
Additional ground
water sampling is
necessary at
Fleming's Patio, the
ILCO Main Facility,
ILCO Parking Lot,
and the City of
Leeds Landfill to
support a final
decision regarding
implementation of
ground water pump
and treat system and
potential ROD
changes.

Inspect for erosion
and fill where
necessary.

PRP

EPA/State

September
2007

N

N

Sufficient sampling
data is not available
from the Un-Named
Tributary and Dry
Creek to make a
protectiveness
determination.

Collect additional
ground water
monitoring data.
Evaluate the data
and prepare a
decision document
to support ROD
changes or direct
the PRPs to install
ground water pump
and treat system.

PRP

EPA/State

December
2009

N

Y

Site-wide ground
water data needs to
be evaluated to
ensure that soil
excavations
continue to be
protective of ground
water.

Collect additional
sampling data from
the Un-Named
Tributary and Dry
Creek.

PRP

EPA/State

June 2007

N

Y

Institutional
controls for the
Un-named Tributary
and Dry Creek need
to be implemented,
as required by the
OU-3 ROD.

Assess current
ground water
conditions and
determine if
sufficient source
material has been
removed. Continue
to maintain
institutional
controls.

EPA

EPA/State

June 2007

H

Y

The MCLs for
arsenic and
cadmium have been
lowered and an
evaluation has not
been done on the
impact to the
ground water
remedies.

Implement

institutional

controls.

PRP

EPA/State

December
2007

Y

Y

42

-------
ROD components
that have either
changed, or are no
longer necessary
have not been
administratively
addressed.

Evaluate impact of
lowered MCLs and
determine
appropriate next
steps.

EPA

EPA/State

December
2007

Monitoring wells
are not being
properly
maintained.

Review current
groundwater
conditions and
determine
appropriate next
steps.

EPA

EPA/State

December
2007

X. PROTECTIVENESS STATEMENTS

OU-l: The implemented soil remedies at the ILCO Parking Lot, Gulf/BP Service Station, J&L
Fabricators, Connell Property, Fleming's Patio, Acmar Church of God, and City of Leeds
Landfill are protective of human health and the environment. The remedies requiring the
excavation of the contaminated soil and sediment above the action levels, removed the principal
threat, and are expected to function as intended by minimizing the migration of contaminants to
ground water and surface water.

-------
OU-3: Because sufficient data is not available, a protectiveness determination cannot be made at
this time until further information is obtained. Further information will be obtained by sampling
Dry Creek and the Un-named Tributary. Institutional controls are also necessary for these areas
and need to be in place to ensure protectiveness of the remedy. Institutional controls are no
longer required at the Leeds Municipal Landfill because the cap was not installed as identified in
the ROD. The need for institutional controls at the Leeds Municipal Landfill will be addressed in
a future decision document.

Overall Protectiveness:

All remedies that have been implemented for OU-1, OU-2, and portions of OU-3 are protective
of human health and the environment. A protectiveness determination at portions of OU-3, Dry
Creek and the Un-named Tributary cannot be made until additional sampling data has been
collected and evaluated.

XI. NEXT REVIEW

The next 5-Year Review should be scheduled within five years from the completion of this
review. The report should be completed before September 2011.

44

-------
Alter US.G-S. 7.5 fMt. Tops Quod., leeds, /J atoms, 1998, Phoio fievrted l?9S, Contour kifervai 20fe&

N

A

noun nrui Site (ocnJion Map

CUIMTi

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ATTACHMENT 1
SITE LOCATION MAP

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After U5.G.S- 7,5 Mtl Topo Qtiod-, leeds, fiiabcma, f 998, P/toto ¦(
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ATTACHMENT 2
SITE LAYOUT

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ATTACHMENT 3
DOCUMENTS REVIEWED

1.	EPA Superfund Record of Decision: Interstate Lead Company (ILCO) EPA ID:
ALD041906173, OU 1, Leeds, Al, 09/30/1991.

2.	EPA Superfund Record of Decision: Interstate Lead Company (ILCO) EPA ID:
ALD041906173, OU2, Leeds, Al, 10/13/1994.

3.	EPA Superfund Record of Decision: Interstate Lead Company (ILCO) EPA ID:
ALD041906173, OU 3, Leeds, Al, 09/25/1995.

4.	Administrative Order on Consent for Treatability Study, 02/15/1995.

5.	Consent Decree, 03/29/1990.

6.	Consent Decree, Interstate Lead Company (ILCO), Superfund Site, Leeds, AL.,
04/22/1997.

7.	Summary of Remedial Alternative Selection for Amendment to Records of Decision for
Operable Units One and Two, EPA, August 27, 1996.

8.	Soil Remedial Action Objectives for Protection of Ground water, EPA, September, 1994.

9.	Final Revised Remedial Action Workplan for the Interstate Lead Company (ILCO)
Superfund Site, Leeds, Alabama, ENTACT, January 16, 2002,

10.	Final Report for the Tributary Sediment Removal Plan, Phase I, Secondary Lead Smelter
Facility, Leeds, Jefferson County, Alabama, Prepared for Interstate Lead Company, Inc.,
Dames & Moore, November 20, 1990.

11.	OU-3 Monitoring Report, Surface Water, Sediment, and Biota, Sampling and Analysis
Results (Baseline Sampling Event January 2000), GeoSyntec Consultants, September
2000.

12.	Baseline Risk Assessment for the Interstate Lead Company (ILCO) superfund Site,
Leeds, Alabama, Operable Unit 2, ICF Kaiser, June 17, 1994.

13.	Remedial Action Report, ILCO Superfund Site, Leeds, Alabama, February 3, 2006.

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ATTACHMENT 4
APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs).

The following ARARs were compiled from the previous decision documents prepared and
issued to implement remedial actions at this site. Certain provisions of these statutes and
regulations are considered ARARs at the Site.

Applicable requirements are those cleanup standards, control standards, and other substantive
environmental protection requirements, criteria, or limitations promulgated under Federal or
state law that specifically address a hazardous substance, pollutant, contaminant, remedial
action, location or other circumstance at a Superfund site.

Relevant and appropriate requirements are those cleanup standards, control standards, and
other substantive environmental protection requirements, criteria, or limitations promulgated
under Federal or state law that, while not "applicable" to a hazardous substance, pollutant,
contaminant, remedial action or other circumstance at a Superfund site, address problems or
situations sufficiently (relevant) to those encountered and that are well suited (appropriate) to
circumstances at the particular site.

Chemical Specific ARARs are specific numerical quantity restriction on individually listed
chemicals in specific media.

Location Specific ARARs are restrictions placed upon the concentration of hazardous
substances or the conduct of activities on the basis of location.

Action Specific ARARs are technology or activity based requirements or limitations or actions
taken with respect to clean-up.

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CHEMICAL SPECIFIC ARARs
ILCO SUPERFUND SITE



CITATION

EXPLANATION

OU-2

R&A

Safe Drinking Water Act, MCLs and
MCLGs

Alabama Primary Drinking Water
Standards

AL Admin. Code 335-7-2

Maximum contaminant levels (MCLs)
and maximum contaminant level goals
(MCLGs) promulgated under the Safe
Drinking Water Act and Alabama's
Primary Drinking Water Standards set
for potential sources of drinking water.

R&A

Clean Water Act, Ambient Water
Quality Criteria - 40 CFR Part 131

Alabama Water Quality Standards
AL Admin. Code 335-6-10

Federal Ambient Water Quality Criteria
are developed as guidance for the states
to develop ambient surface water
quality standards that will be fully
protective of human health and the
environment. Alabama's Water Quality
Standards set forth numerical and
narrative standards for ambient ground
water and surface water in the State of
Alabama.

A

Clean Water Act - NPDES

40 CFR Parts 122, 125,129,133, and

136.

Alabama Pollution Discharge
Elimination System Regulations

AL Admin Code 335-6-6

NPDES requirements regulate the
discharge of any pollutant or
combination of pollutants to water of
the United States from any point source.

OU-3



Alabama Water Quality Standards
AL Admin Code 335-6-10

To comply with these standards
portions of the Un-named Tributary,
Dry Creek and the Little Cahaba River
would require draining and re-routing
prior to sediment removal, thus
destroying the diverse habitat. EPA
invoked a waiver pursuant to CERCLA
Section 121(d)(4)(B) for the Alabama
Water Quality Standards.

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I LOCATION SPECIFIC ARARs

ILCO SUPERFUND SITE

CITATION

EXPLANATION

OU

-1

Resource Conservation and Recovery Act-
Location Requirements

RCRA location requirements mandate that
TSD facilities located within a 100-year
floodplain must be designed, constructed,
operated, and maintained to avoid washout.

Resource Conservation and Recovery Act

RCRA Subtitle D; requirements for the 1
closure of municipal landfills. |

Fish and Wildlife Coordination Act

Requires adequate protection of fish and
wildlife if any stream or other body of
water is modified. Additionally, actions in
wetlands are required to avoid adverse
effects, minimize potential harm, and
restore and preserve natural and beneficial
values.

OU - 2 & OU - 3

Alabama Water Use Classification
Regulations AL Admin. Code 335-6-11

Identifies surface water utilization
classifications for the State of Alabama

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ACTION SPECIFIC ARARs
ILCO SUPERFUND SITE

CITATION

EXPLANATION

RCRA Compliance Monitoring Program
40 CFR Section 264.99

Establishes criteria for monitoring ground
water quality when contaminants have been
detected.

Federal Ambient Water Quality Criteria

Lists maximum allowable concentration of
contaminants for the protection of aquatic
life.

RCRA Land Disposal Restriction (LDRs)
40 CFR 268 .

Established restrictions on the placement of
RCRA hazardous wastes. The LDRs are ,
only applicable if the contaminated soil is
excavated and removed from the site, or
excavated, treated, and then replaced in a
way that constitutes placement.

Resource Conservation and Recovery Act
40 CFR Part 258

Alabama Solid Waste Regulations
AL Admin. Code 335-13

These regulations set forth the criteria for
municipal solid waste landfills.

Resource Conservation and Recovery Act
Parts 261,262, and 264.

Alabama Hazardous Waste Regulations
AL Admin. Code 335-14

These regulations address the treatment,
storage and disposal of hazardous wastes
including the following: the definitions of
those solid wastes which are subject to
regulation as hazardous, decontamination
of debris, storage of hazardous waste, and
treatment of hazardous waste.

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ATTACHMENT 5
FIVE-YEAR REVIEW SITE INSPECTION REPORT

I. SITE INFORMATION

Site Name: Interstate Lead Company

Date of Inspection: January 11, 2006

Location and Region: Leeds, AL; IV

EPA ID: ALD041906173

Agency, office, or company leading the five-
year review: Corps of Engineers	

W eather/temperature:
Cloudy/ 50°	

Remedy Includes: (Check all that apply)

1X1	Landfill cover/containment	[X] Monitored natural attenuation

[X]	Access controls	Q Ground water containment

fc\]	Institutional controls	I I Vertical barrier walls

I I	Ground water pump and treatment

~	Surface water collection and treatment

I I	Other

Attachments: 1^1 Inspection team roster attached Site map attached	

II. INTERVIEWS (Check all that apply)

1. O&M Site Manager:	 	 	

Name	Title	Date

Interviewed Q at site Q at office QU by phone Phone no.

Problems, suggestions; Q Report attached

2. O&M staff 		 	 	

Name	Title	Date

Interviewed ~ at site ~ at office O by phone Phone no.

Problems, suggestions; Q Report attached

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices,
emergency response offices, police department, office of public health or environmental
health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all
that apply.

Agency: Alabama Department of Environmental Management

Contact: C. H. Cox Environmental Engineer Jan. 11,2006 (334)271-7786

Name	Title	Date	Phone No.

Problems, suggestions; Q Report attached

4. Other interviews (optional) I I Report attached.

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III. ON-SITE DOCUMENTS & RECORDS VERIFIED

1. O&M Documents

I I O&M Manual	Q Readily available Q Up to date Q N/A

I~1 As-built drawings	Q Readily available O Up to date Q N/A

( [Maintenance logs	Q Readily available Q Up to date Q N/A

Remarks: An O&M Manual has not been prepared.

2.	Site-Specific Health and Safety Plan Q Readily available Q Up to date Q N/A
l~~l Contingency plan/emergency	I I Readily available I 1 Up to date I I N/A.

response plan

Remarks: No Safety Plan or Contingency/Emergency Response Plan was available on-site.

3.	O&M and OSHA Training	|~] Readily available.^ Up to date Q N/A
Remarks: No O&M or OSHA documents»were on-site.

4.	Permits and Service Agreements

I I Air discharge permit	Q Readily available Q Up to date N/A

~Effluent discharge	Q Readily available Q Up to date ^ N/A

QWaste disposal, POTW	Q Readily available Q Up to date ^ N/A

QOther permits	 Q Readily available Q Up to date N/A

Remarks: None of the sites produce any discharge, therefore no permits are required.

5.	Gas Generation Records	I I Readily available I I Up to date I I N/A
Remarks: The City of Leeds Landfill cap isn't equipped with gas vents.

6.	Settlement Monument Records	I I Readily available I I Up to date I I N/A
Remarks: No settlement monuments were noted.

7.	Ground water Monitoring Records	^ Readily available Q Up to date Q N/A
Remarks: Ground water monitoring records were made available, in a concise, single

format, on or about 1 March 2006.

8.	Leachate Extraction Records	I I Readily available I I Up to date 1X1 N/A
Remarks: Leachate is not generated.

9.	Discharge Compliance Records

|~~1 Air O Readily available Q Up to date ^ N/A
QWater (effluent) Q Readily available Q Up to date ^ N/A
Remarks '	

10.	Daily Access/Security Logs Q Readily available Q Up to date Q N/A
Remarks: The site is secured with a locked fence and is closed. Only authorized personnel
have access to the site and no logs are maintained.	

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	IV. O&M COSTS	

1. O&M ORGANIZATION

~ State in-house	~ Contractor for State

I I PRP in-house	^ Contractor for PRP

I I Federal Facility in-house	Contractor for Federal Facility

Other: No O&M is being conducted at this time.

2. O&M COST RECORDS

I I Readily Available	Q Up to date

I I Funding mechanism/agreement in place

Original O&M cost estimate	 Q] Breakdown attached

Total annual cost by year for review period

From: July 2002

To: January 2005

$25,000.00

~

Breakdown attached

Date



Date

Total Cost





From

To





~

Breakdown attached

Date



Date

Total Cost



From

To





n

Breakdown attached

Date



Date

Total Cost





From

To





~

Breakdown attached

Date



Date

Total Cost



From

To





~

Breakdown attached

Date



Date

Total Cost



3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS [^Applicable ~ N/A

A. Fencing	

1. Fencing damaged O Location shown on site map Q Gates secured Q N/A
Remarks: Fence is in good repair and is performing its' intended purpose.

B. Other Access Restrictions	

1. Signs and other security measures n Location shown on site map Q N/A
Remarks: Signs are spaced at intervals on Main Facility fence. See photographs.

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C. Institutional Controls (ICs)

1. Implementation and enforcement

Site conditions imply ICs not properly implemented Q Yes ^ No Q] N/A
Site conditions imply ICs not being fully enforced G Yes ^ No Q N/A

Type of monitoring (e.g., self-reporting/drive-by)
Frequency 	

Responsible Party/agency
Contact

Name	Title	Date Phone no.

Reporting Up to date	~ Yes Q No ^ N/A

Reports are verified by lead agency	Q Yes D No ^ N/A

Specific requirements in deed or decision documents have been met ^ Yes Q No D N/A
Violations have been reported	~ Yes ~ No ~ N/A

Other problems or suggestions:	Q Report attached

Remarks: ICs are in-place at The following: Fleming's Patio (Shelborne property), J&L
Fabricators, City of Leeds Landfill, and The ILCO property. Restrictions are: (1) no
construction, development, or redevelopment that will in any way disturb the property (2)
no drilling of any kind will be allowed. Also, J&L Fabricators, City of Leeds Landfill and

ILCO Property can not be developed or utilized for residential use.	

2. Adequacy	£><] ICs are adequate Q ICs are inadequate Q N/A

Remarks

D. GENERAL	

1.	Vandalism/trespassing I I Location shown on site map I I No vandalism evident
Remarks: Unregulated C&D dumping at City of Leeds landfill may be considered
vandalism and trespassing.

2.	Land use changes on site Q N/A

Remarks: No changes in land use were observed at any site.

3.	Land use changes off site N/A

Remarks 	

VI. GENERAL SITE CONDITIONS
A. Roads Applicable I I N/A	

1. Roads damaged I I Location shown on site map CXI Roads adequate l~l N/A
Remarks

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B. Other Site Conditions

Remarks

	VII. LANDFILL COVERS E3 Applicable ~ N/A	

A. Landfill Surface	

1. Settlement (Low	O Location shown on site map Q Settlement not evident

spots)

Areal extent 	;	 Depth 	

Remarks: No settlement was noted, but top of cap is covered with stumps and woody
debris.

2.	Cracks	Q Location shown on site map Cracking not evident

Lengths	 Widths	 Depths	

Remarks 			

3.	Erosion Q Location shown on site map Erosion not evident
Areal Extent	 Depth	

Remarks: Top and side slopes covered with debris and dead vegetation.

4.	Holes \_\ Location shown on site map Q Holes not evident
Areal Extent	 Depth	

Remarks: Numerous tire ruts are present from apparently unauthorized use.

5.	Vegetative cover Q Grass Q Cover properly established I I No signs of stress
I I Trees/Shrubs (indicate size and location on a diagram)

Remarks: Cover appears to be predominantly kudzu and weeds.

6.	Alternative cover (armored rock, concrete, etc.) Q N/A
Remarks: None observed at Leeds Landfill.

7. Bulges	I Location shown on map. IXI Bulges not evident

8.	Wet areas/water damage Q Wet areas/water damage not evident
153 Wet areas	^ N/A

I I Ponding	^ N/A

~ Seeps	N/A

153 Soft sub-grade: Numerous tire ruts in roads and other areas.

9.	Slope Instability	153 No evidence of slope instability.	

B.	Benches	I 1 Applicable 153 N/A 	

C.	Letdown Channels 1 1 Applicable IXl N/A

D. Cover Penetrations I I Applicable 153 N/A

E. Gas Collection and Treatment	I I Applicable 153 N/A

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F.	Cover Drainage Layer I I Applicable 1^1 N/A	

G.	Detention /Sedimentation Ponds U Applicable N/A

H.	Retaining Walls	I I Applicable 1^1 N/A

VIII. VERTICAL BARRIER WALLS ~ Applicable |^| N/A

IX. GROUND WATER/SURFACE WATER REMEDIES ^Applicable ~ N/A

A.	Ground water Wells, Pumps and Pipelines Applicable I I N/A	

B.	Surface Water Collection Structures, Pumps and Pipelines I lApplicable N/A

C.	Treatment System I I Applicable EX] N/A	

D.	Monitoring Data 153 Applicable I I N/A	

E.	Monitored Natural Attenuation D*] Applicable I I N/A	

I.	Monitoring Wells (monitored natural attenuation remedy)	

E*] Properly secured/locked 1 1 Functioning I I Routinely sampled I I Good

	Condition I I All required wells located E<] Needs maintenance	

X. OTHER REMDIES

XI. OVERALL OBSERVATIONS

A.	Implementation of Remedy		

The soi| remedy is designed to protect the public from direct contact with or ingestion of

contaminated soil and sediment. This was accomplished by the excavation, stockpiling and
treatment (solidification/stabilization) of contaminated soil from the Main Site, Parking Lot,
Acmar Church of God, Gulf Service Station, Fleming Patio, J&L Fabricators, and Connell
Property. The contaminated debris place in the City of Leeds Landfill was capped. The
soil remedy is functioning as design and is protective.

The only ground water remedy in place is the No Further Action at the Gulf Service Station
and the Acmar Church of God. The pump and treat remedies for the City of Leeds Landfill,
ILCO Main Site and Parking Lot have not been installed. MNA is the remedy specified in
the ROD for the remaining sites. Apparently EPA is evaluating if MNA and pump and
treat will remain as the ground water remedy for the selected site.	

B.	Adequacy of O&M		

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ATTACHMENT 6
CHRONOLOGY OF REMEDIAL ACTIONS

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ATTACHMENT 6
CHRONOLOGY OF REMEDIAL ACTIONS

TABLE 11: CHRONOLOGY OF EVENTS
ILCO SUPERFUND SITE, LEEDS, ALABAMA

Date

Activity

January 17, 2000

RMT mobilized personnel and equipment to the Site. Site preparation activities were
initiated which included the installation of support facilities, utilities and laydown areas:
establishing erosion, sedimentation and dust control measures; constructing temporary
access roads for trucks and equipment; clearing and grubbing excavation and
treatment areas; and identifying the locations of on-site utilities.

January 25, 2000 to
February 2, 2000

RMT excavated, treated and disposed ofl-site impacted soils/debris from the small
stockpile at the Main Facility.

January 20, 2000 to
March 13, 2000

RMT excavated, treated and disposed off-site impacted soils/debris from the Interstate
Trucking Building at the Main Facility.

February 1, 2000 to
June 27, 2000

RMT excavated, treated and disposed off-site impacted soils/debris from the large
stockpile at the Main Facility.

March 2, 2000 to
June 13, 2000

RMT excavated, treated and disposed off-site impacted soils/debris from the slag vault
at the Main Facility.

May 22, 2000 to
June 12, 2000

RMT excavated, treated and disposed off-site impacted soils from the Acmar Church ol
God. Excavated areas were backfilled, graded and reseeded.

May 25, 2000 to
December 31, 2000

RMT excavated, treated and disposed off-site impacted soils from Flemmings Patio.
Excavated areas were backfilled, graded and reseeded.

July 6, 2000 to
September 21, 2000

RMT excavated, treated and disposed off-site impacted soils from the Connell
Property. Excavated areas were backfilled, graded and reseeded.

July 7, 2000 to
June 21, 2001

RMT excavated, treated and disposed off-site impacted soils from the ILCO Parking
Lot and Montgomery Oil. Excavated areas were backfilled, graded and reseeded.

July 2000 to
October 2000

AGC conducted supplemental sampling at J&L Fabricators, Acmar Church of God,
Connell property, and Flemmings Patio.

August 2, 2000 to
May 18, 2001

RMT excavated, treated and disposed off-site impacted soils from J&L Fabricators.
Excavated areas were backfilled, graded and reseeded.

Early 2001

RMT constructed the stormwater retention pond at the Main Facility to contain
stormwater run-off from the Site.

April 15, 2001 to
June 6, 2001

RMT initiated grading activities in the process area at the Main Facility for the
installation of erosion and sedimentation controls. Excavated soils from the process
area were treated and disposed off-site.

April 26, 2001 to
June 6, 2001

RMT remobilized to Flemmings Patio for additional excavation ol impacted soils. The
excavated soils were treated at the Main Facility and disposed off-site, and the site was
backfilled and reseeded.

May 18, 2001 to
June 6. 2001

RMT remobilized to the Acmar Church of God for additional excavation ol impacted
soils and tire removal. Excavated soils were treated at the Main Facility and disposed
off-site, and the site was backfilled and reseeded.

June 9, 2001

RMT remobilized to the Connell Property to install a culvert in the driveway.

July 2-10, 2001

RMT demobilized from the Site.

July 17, 2001

ENTACT held a pre-construction meetinq held at the Site.

July 23, 2001 to
August 14, 2001

ENTACT initiated re-mobilization ol field support personnel and equipment to the Site.
Site preparation activities included establishing erosion, sedimentation and dusf conlrol
measures; identifying locations of on-site utilities; clearing and grubbing excavation
areas at the Main Facility and Satellite Sites; establishing support facilities and work
zones at the Site; and initiating perimeter air monitoring activities using high-volume air
samplers at the Main Facility.

August 14, 2001 to
October 22, 2001

ENTACT initiated soil screening, treatment and loadout ol existing soil stockpiles at the
Main Facility. Conducted pilot tests for the treatment ol impacted soil and battery
casinq/oversize debris at the Main Facility.

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TABLE 11: CHRONOLOGY OF EVENTS
ILCO SUPERFUND SITE, LEEDS, ALABAMA

Date

Activity

August 6, 2001 to
February 14, 2002

ENTACT excavated, treated and disposed ofl-site impacted soils from Flemmings Patio
and the Shelborne Property. Verification sampling was conducted at the Shelborne
House on August 23, 2001, at Flemmings Patio on September 26, 2001 and at the
Flemmings Patio Parking Lot/Shelborne Property on October 26, 2001. Backfilling
activities were initiated at Flemmings Patio on September 26, 2001 and at the
Flemmings Patio Parking Lot/Shelborne Properly on February 6, 2002. The excavated
areas were graded and reseeded prior to demobilization from the Satellite Site.

October 11, 2001 to
June 7, 2002

ENTACT excavated, treated and disposed ofl-site impacted soils from the Main Facility.
Excavation activities were initiated on October 11, 2001 beginning with the area located
to the west of the Interstate Trucking Building concrete pad, then the slag vault,
wastewater treatment plant, and treatment/staging area. Confirmation sampling of the
excavations was initiated on February 14, 2002. Backfilling activities began on
February 27, 2002. Grading activities were started on April 8, 2002 The site was
revegetated beginning on April 2, 2002. Clearing, grubbing and excavation of the
forested areas south and west of the Main Facility was initiated on April 17, 2002.

December 4, 2001 to
December 21, 2001

ENTACT excavated, treated and disposed ofl-sile impacted soils from J&L Fabricators.
Excavated areas were backfilled with gravel and the parking lot was restored to its
original qrade.

January 4, 2002 to
April 1, 2002

ENTACT excavated, sampled, treated, and disposed off-site impacted soil at the
Acmar Church of God. Characterization sampling of lesl pits was conducted from
January 4-7, 2002. Excavation activities were initiated on March 4, 2002 on the slope
to the south of the church building. Excavated areas were backfilled and graded. The
site was revegetated on April 1, 2002. Tires removed during excavation were sized at
the Main Facility for disposal with treated soils.

January 10, 2002 to
March 25, 2002

ENTACT excavated, treated and disposed off-site impacted soils from the ILCO
Parking Lot and Montgomery Oil. Excavation was initiated on January 18, 2002 at the
Parking Lot and February 4, 2002 at Montgomery Oil. Confirmation samples were
collected on February 18, 2002. Montgomery Oil was backfilled with gravel and both
properties were regraded for drainage. The Parking Lot was revegetated on February
28, 2002 and Montgomery Oil on March 25, 2002.

January 22, 2002 to
April 5, 2002

ENTACT loaded out K069 dust and lead/slag buttons at Main Facility to Doe Run for
recycling.

January 30, 2002 to
April 11, 2002

ENTACT initiated decontamination of the Maintenance Building and concrete building
foundations at the Main Facility. Collected decontamination and stormwaters were
disposed off-site at the Villaqe Creek POTW on April 4-5, 2002.

March 21-22, 2002

ENTACT conducted a subsurface soil investigation of the Clayton Patrick Properly
located to the south ol the Flemmings PatkVShelbome Property Satellite Site was
conducted to determine if lead-impacted soils were present on the properly.

April 4-5, 2002

ENTACT remobilized to J&L Fabricators to excavate impacted soils from two interior
areas in the J&L Building. Excavated areas were backfilled and concrete slabs were
completed to building qrade.

April 3, 2002

The pre-final inspection of the Site was conducted by ENTACT, AGC, Leed
Environmental, and Black and Veatch.

April 15. 2002 to
June 10, 2002

ENTACT initiated temporary demobilization activities after the pre-final inspection.
Additional excavation work at the Main Facility was discovered and demobilization
activities were postponed until the week of June 3, 2002. Temporary demobilization
was complete by June 10, 2002, as approved by U.S. EPA on June 6, 2002.

July 2002 to
January 2005

American Environmental Engineering, Inc. performed periodic erosion and
sedimentation control measure inspections ot the Main Facility.

Table 11-2

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TABLE 11: CHRONOLOGY OF EVENTS
ILCO SUPERFUND SITE, LEEDS, ALABAMA

Date

Activity

November 2002 to
September 2004

AGC performed supplemental soil sampling actvities at and adjacent to the Main
Facility.

February 11, 2004 to
April 20, 2004

U.S. EPA conducted soil and tire removal activities at the Acmar Church of God. AGC
performed confirmatory samplinq of the excavated soil surface in April 2004.

July 20, 2005

ENTACT held a pre-construction meetinq held at the Site.

July 25, 2005 to
August 23, 2005

ENTACT initiated re-mobilization of field support personnel and equipment lo the Site.
Site preparation activities included establishing erosion, sedimentation and dust control
measures; identifying locations of on-site utilities; clearing and grubbing excavation
areas at the Main Facility; and establishing support facilities and work zones at the Site.

August 2, 2005 to
October 21, 2005

ENTACT demolished the Maintenance Building, guard house, stormwater retaining
wall, and concrete/brick wall along Borden Avenue and disposed of the demolition
debris at an off-site landfill.

August 23, 2005 to
October 21, 2005

ENTACT excavated soils from the additional identified grids at the Main Facility and
adjacent properties. These soils and the soils excavated from the Acmar Church of
God were disposed off-site. The excavated areas were graded and the off-site areas
were backfilled. All excavated areas were reseeded prior to demobilization from the
Site.

October 13, 2005 to
November 2005

ENTACT repaired and/or installed the perimeter fence at the Main Facility along Borden
Avenue, Leaf Avenue and to enclose the Industrial Development Board of Leeds'
property.

October 5. 2005 to
October 21, 2005

ENTACT repaired Ihe erosion area along Borden Avenue at the stormwater culverts.

October 19, 2005

The pre-final inspection of the Site was conducted by ENTACT. AGC. U.S. EPA, and
ADEM.

November 29, 2005

The final inspection of the Site was conducted by the representatives of the Group,
Black & Veatch, ADEM, and ENTACT.

Table 11 -3

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ATTACHMENT 7
SITE INSPECTION PHOTOGRAPHS

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SIGN ON MAIN GATE

LI









ILCO SUPERFUND SITE MAIN GATE

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MONITORING WELLS AT MAIN SITE

LEAD SMEL TER AREA

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BACKFILLED VAULT/SUMP AT MAIN SITE

INTERSTATE TRUCKING AREA, MAIN SITE

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EROSION CONTROL MEASURES,UN-NAMED TRIBUTARY

EROSION CONTROL, UN-NAMED TRIBUTARY

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ILCO MAIN SITE LOOKING AT PARKING LOT AREA

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J&L FABRICATORS



J&L, CLEAN BACKFILL AND BERM TO PREVENT EROSION

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J&L, BERM ALONG CREEK AT BACK OF SHOP

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CORNER WHERE FOUNDATION DRAIN SHOULD BE

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CONNELL PROPER!-EXCAVATED AREA BEHIND HOUSE

ACMAR CHURCH-AREA OF PONDED WATER

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ACMAR CHU RCH-REMEDlA TED AREA

ACMAR CHURCH-START OF EROSION FROM DRAINING

PONDED WATER

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ACMAR CHURCI URIPRAPPED SLOPE DRAIN

L(X)KJNG DOWN SLOPE DRAIN

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ACMAR CHURCH-MONITORING WELL

BP STATION-UNSECURED GATE

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BP STATION-REMEDIATED AREA

BP STATION

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FLEMMINGS PATIO/SI IELBORNE PROPERTY

CITY OF LEEDS LANDFILL

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LEEDS LANDFILL-STUMPS AND MIXED DEBRIS

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ATTACHMENT 8
FIVE-YEAR REVIEW INTERVIEWS

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INTERVIEW RECORD

Site Name: ILCO Superfund Site

EPA ID No.: ALD041906173

Subject: Five-Year Review

Time: 0900

Type: 1X1 Telephone I I VisiT
Location of Visit:

Date: 3/15/06

Other

I I Incoming LJ Outgoing

Contact Made By:

Name: Ernest R. McCollum Title: Geologist	Organization: USACE, Mobile

Individual Contacted:

Name: Sarah Gill

Title: Eng.

Organization: ADEM

Telephone: (334)271-7734
Cell Phone:

E-Mail Address: sgill@adem.state.al.us

Street Address: 1400 Coliseum Blvd.
City, State, Zip:

Montgomery, A1 36130

Summary of Conversation

1.	What is your overall impression of the project?

The soils remedy at the Main Site has worked well. The is no active groundwater
remediation, at this time. There is on-going groundwater monitoring. The PRP would
like to have an alternative remedy to pump and treat. Alternate Concentration Limits
(ACLs) were investigated but rejected by EPA. With the soils remediation complete the
final groundwater remedy needs to be selected and put into operation.

2.	Have there been routine communications or activities conducted by your office
regarding the site?

Communications have been quite good, I feel like I have been kept in the loop
and that I am well informed.

3.	Have there been any complaints, violations, or other incidents related to the site
requiring a response by your office?

Nothing recently, site fences and other access controls were repaired just prior to
the Final Site Inspection.

4.	Do you have any comments, suggestions, or recommendations regarding the site's
operation or management?

No, not at this time.

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INTERVIEW RECORD

Site Name: ILCO Superfund Site

EPA ID No.:ALD041906173

Subject: Five-Year Review

Time: 10:30

Type: I' I Telephone"
Location of Visit:

Date: 3/16/06

I I Incoming I I Outgoing

Visit

Other

Contact Made By:

Name: Ernest R.
McCollum

Title: Geologist

Organization: USACE, Mobile

Individual Contacted:

Name: Jeff Leed

Title: Env. Engineer

Organization: Leed
Environmental, Inc.

Telephoned 10) 670-7310

Cell Phone:

E-Mail

Address:jleed@leedenvironmental.com.

Street Address: 2209 Quarry Drive
City, State, Zip:

Reading, PA 19609

Summary of Conversation

What is your overall impression of the project?

The ILCO Site Remediation Group (Group) encountered a number of significant
challenges related to the development and implementation of the remedy for the site.

With the cooperation and assistance of all parties involved, the Group has met the
challenges and has successfully completed the soil portion of the remedy for the site. The
Group anticipates that the remaining unresolved issues, as described below, can be
resolved quickly so that the monitoring and operation and maintenance phases of the
project can proceed to completion.

What does the monitoring data show? Are any trends evident in the data?

The monitoring data collected during the implementation of remedial activities at the
ILCO Main Facility, ILCO Parking Lot, and satellite sites indicate that the performance
standards for soil were achieved in all locations except for several areas. In those areas
and with EPA's approval, the Group implemented institutional controls (deed restrictions)
with the property owners.

Regarding ground water, the Group believes that the indicator parameter (lead) is not
present in the ground water at concentrations above the performance standard at the
ILCO Main Facility, ILCO Parking Lot, and the satellite sites (except for one well at the
Fleming's Patio satellite site where the concentration of lead is slightly above the
performance standard and the property owners have executed a deed restriction which
prohibits the use of ground water for potable water). At the ILCO Main Facility and
ILCO Parking Lot, the Group also believes that: (1) the primary inorganic constituents in
the ground water have decreased significantly since the remedial investigation was

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INTERVIEW RECORD

Site Name: ILCO Superfund Site

EPA ID No.:ALD041906173

Subject: Five-Year Review

Time: 10:30

Date: 3/16/06

performed, (2) the primary inorganic constituents above their respective performance
standards are present only at two monitoring wells in the immediate vicinity of the former
battery breaker at the ILCO Main Facility, and (3) the primary inorganic constituents are
not migrating in the ground water

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INTERVIEW RECORD

Site Name: ILCO Superfund Site

EPA ID No.:ALD041906173

Subject: Five-Year Review

Time: 10:30

Date: 3/16/06

Is the remedy functioning as expected? How well is the remedy performine?

Yes, the remedy is functioning as expected. Improvements in ground water quality have
been observed, as noted above, in the absence of a ground water pumping and treatment
remedy.

Is there a continuing O&M presence and have there been any excess or unexpected
O&M costs?

Because the remedy for the ILCO site does not involve any operating machinery,
operating systems, etc., the Group does not envision a continuous O&M presence at the
site. Instead, the Group envisions periodic inspections and maintenance of the: (1)
security fence, concrete foundations, access roadways, vegetation, erosion and
sedimentation controls, and institutional controls at the ILCO Main Facility and Industrial
Development Board of the City of Leeds' property; (2) vegetation and erosion and
sedimentation controls at the ILCO Parking Lot; and (3) inspections of institutional
controls at J&L Fabricators and Fleming's Patio. These items will be addressed in the
Group's O&M Plan, which is currently being prepared. To date, the Group has not
incurred any excess or unexpected O&M costs.

Do you have any comments, suggestions, or recommendations regarding the
project?

Yes. The ground water remedy that EPA selected for the ILCO Main Facility and ILCO
Parking Lot, based upon data collected during the remedial investigation more than 10
years ago, involves pumping and treatment of ground water. Based upon more recent
data collected by the Group, the Group believes that: (1) ground water pumping and
treatment is not necessary; and (2) ground water conditions will continue to improve due
to naturally occurring conditions. The Group hopes, and is optimistic, that EPA will
promptly make a formal change to the ground water remedy, implement a ground water
monitoring remedy, and promptly delist the sites where performance standards have been
achieved.

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