983663
Final
Hegeler Zinc Superfund Site
Operable Units 1 and 2
Hegeler, Vermilion County, Illinois
Record of Decision (ROD)
U.S. Environmental Protection Agency Region 5
77 W. Jackson Blvd.
Chicago, IL 60604
June 2023
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TABLE OF CONTENTS
Section Page
PART I - DECLARATION 4
1.1- Site Name and Location 4
1.2 - Statement of Basis and Purpose 4
1.3 - Assessment of Site 4
1.4 - Description of Selected Remedy 5
1.5 - Statutory Determinations 7
1.6 - Data Certification Checklist 7
1.7 - Authorizing Signature 8
PART II - DECISION SUMMARY 9
2.1 - Site Name, Location, and Brief Description 9
2.2 - Site History and Enforcement Activities 9
2.2.1 Site History 9
2.2.2 Previous Investigations and Response Actions 10
2.2.3 Enforcement History 12
2.2.4 Supplemental Remedial Investigation/Feasibility Study (SRI/FS) 13
2.3 - Community Participation Activities 13
2.4 - Scope and Role of Operable Unit or Response Action 13
2.5 - Site Characteristics 14
2.5.1 Conceptual Site Model for Hegeler Zinc Site 14
2.5.2 Site Topography 15
2.5.3 Geologic/Hydrogeologic Setting 16
2.5.4 Regional Hydrogeology 16
2.5.5 Nature and Extent of Contamination 17
2.6 - Current and Potential Future Land and Resource Uses 22
2.7 - Summary of Site Risks 23
2.7.1 Human Health Risks 23
2.7.2 Ecological Risks 30
2.7.3 Basis for Action 34
2.8 - Remedial Action Objectives 34
2.9 - Description of Alternatives 40
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2.9.1 Common Elements of Alternatives 40
2.9.2 Description of Alternatives 47
2.10 - Summary of Comparative Analysis of Alternatives 50
2.10.1 Overall Protection of Human Health and the Environment 52
2.10.2 Compliance with Applicable or Relevant and Appropriate Requirements 52
2.10.3 Long-term Effectiveness and Permanence 53
2.10.4 Reduction of Toxicity, Mobility, or Volume through Treatment 53
2.10.5 Short-term Effectiveness 53
2.10.6 Implementability 54
2.10.7 Cost 54
2.10.8 State/Support Agency Acceptance 54
2.10.9 C ommunity Acceptance 54
2.11- Principal Threat Waste 55
2.12 - Selected Remedy 55
2.12.1 Summary of Rationale for the Selected Remedy 55
2.12.2 Summary of Selected Remedy 56
2.12.3 Summary of Estimated Remedy Costs 58
2.12.4 Expected Outcomes of Selected Remedy 58
2.13 - Statutory Determinations 60
2.14 - Documentation of Significant Changes 62
PART III - RESPONSIVENESS SUMMARY 63
ATTACHMENT 1: FIGURES
Figure 1: Site Location Map
Figure 2: Topographic Location Map
Figure 3: Hegeler OU3 Features
Figure 4: Hegeler Zinc Superfund Site
Figure 5: Site-Specific Features Map
Figure 6: OU1 Conceptual Site Model
Figure 7a: Revised Human Health Risk Assessment Conceptual Site Model OU1
Figure 7b: Ecological Conceptual Site Model for OU1
Figure 7c: OU2 Conceptual Model Site Waterways
Figure 8a: On-Site Soil and Sediment Sampling Locations with Exposure Areas
Figure 8b: OU1 Human Health Risk Assessment Exposure Areas
Figure 9: OU2 Sediment and Surface Water Locations
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Figure 10: Sediment Remediation Areas
Figure 11: Surface Water and Groundwater Exceedance Areas Conceptual Layout
Figure 12: Areas Requiring Institutional Controls for Soil
Figure 13: OU1 Remedial Alternative 2 Conceptual Layout
Figure 14: OU1 Remedial Alternative 3 (Selected Remedy) Conceptual Layout
Figure 15: OU1 Remedial Alternative 4 Conceptual Layout
Figure 16: OU1 Remedial Alternative 5 Conceptual Layout
ATTACHMENT 2: TABLES
Table A-l: Conceptual Site Model for OU2 Human Receptors
Table A-2: Human Health Risk Assessment Chemicals of Concern Summary OU1
Table A-3: Summary of Reasonable Maximum Exposure (RME) Cancer Risks, Hazard Indices
and Chemicals of Concern OU1 and OU2
Table A-4: Carcinogenic & Non-Cancer Toxicity Data
Table A-5: Summary of Affected Media, Receptors, Pathways, and COCs/COECs OU1
Table A-6: Applicable or Relevant and Appropriate Requirements (ARARS)
Table A-7: Comparison of COEC and RGs in Sediment - OU1 versus OU2
Table A-8: Remediation Goals for Groundwater
Table A-9: Summary of Proposed Remedial Alternatives
Table A-10: Chart Comparing Cleanup Options with the 9 Superfund Remedy Selection Criteria
Table A-l 1: Estimated Costs for Alternatives
ATTACHMENT 3: ADMINISTRATIVE RECORD INDEX
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This Record of Decision (ROD) documents the remedy selected for the Hegeler Zinc Superfund
Site ("Hegeler Zinc Site" or "Site") located in Vermilion County, Illinois. This ROD selects a
final remedy for slag, soil, and sediment at the Site, and interim remedies for groundwater and
surface water. The ROD is organized in three sections: Part I contains the Declaration for the
ROD, Part II contains the Decision Summary, and Part III contains the Responsiveness Summary.
PART I - DECLARATION
This section summarizes the information presented in the ROD and includes the authorizing
signature of the United States Environmental Protection Agency (EPA) Region 5 Superfund and
Emergency Management Division Director.
1.1 - Site Name and Location
Hegeler Zinc Superfund Site
Operable Units 1 and 2 (OU1 and OU2)
SEMS Site ID# ILN000508134
Danville, Vermilion County, Illinois
1.2 - Statement of Basis and Purpose
This decision document presents the Selected Remedy for the Hegeler Zinc Site in Vermilion
County, Illinois. The remedy was developed in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA)
as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to
the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). Specifically, this decision document has been prepared in compliance with CERCLA
Section 117 and NCP Section 300.430(f). This decision document explains the factual and legal
basis for selecting the remedy for OU1 and OU2 at the Site. This decision is based on the
Administrative Record file for the Site. The Administrative Record file is available for review
online at www.epa.gov/superfund/hegeler-zinc and at the following locations:
Danville Public Library EPA Region 5 Records Center
319 N. Vermilion St. 77 W. Jackson Blvd. (SRC-7J)
Danville, IL 61832 Chicago, IL 60604
(217) 477-5228 (312)353-1063
The State of Illinois has indicated its intent to concur with the Selected Remedy. The State's
concurrence letter will be added to the Administrative Record upon receipt.
1.3 - Assessment of Site
The response action selected in this ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances into the
environment.
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1.4 - Description of Selected Remedy
Contaminated materials within OU1 and OU2 of the Hegeler Zinc Site pose risks to human and
ecological receptors. EPA's Selected Remedy, Alternative 3, addresses the contamination by
excavation of soils and sediments, consolidation of these materials with the on-site slag pile and
capping all in place. Excavated soil and sediment that exceeds the toxicity characteristic leaching
procedure (TCLP) criteria will be disposed of off-site. EPA is currently evaluating its existing
policy on human health risks from lead contamination in soil. Should the lead policy change,
EPA will determine if a change to the cleanup level for lead in soil is needed at this Site.
The Selected Remedy includes interim measures to prevent exposure to contaminated
groundwater and surface water. EPA expects that contaminant concentrations within
groundwater and surface water at the former smelter property, which is the main part of OU1,
will decrease after consolidation of Site contamination under a low-permeability cover. EPA
may select a Site groundwater and surface water remedy in a separate decision after evaluating
the performance of the remedy at OU1.
EPA has not identified any principal threat wastes at OU1 and OU2 of the Site. Although some
of the waste materials at the Site exceed TCLP levels and are therefore considered
characteristically hazardous, the waste materials at the Site have impacted groundwater only at
low levels, and groundwater contamination appears to be limited to the former smelter property.
Currently, none of the contaminated slag, soils and sediments on OU1 are contained or covered.
As the impact to groundwater is low, even under these uncontrolled conditions, EPA believes
that the wastes can be reliably contained.
The major components of the Selected Remedy for OU1 and OU2 of the Site are as follows:
¦ Pre-design investigations and pre-construction activities.
¦ Demolish remnants of existing buildings and the kiln and consolidate brick and concrete
with slag pile and dispose of rest of debris off-site;
¦ Reroute a small portion of the unnamed tributary to Grape Creek (creek) on OU1 to
create a 100-foot buffer between the creek and the slag pile;
¦ Excavate and relocate a small portion of the slag pile to create a 100-foot buffer between
the south creek and the slag pile consolidation area;
¦ Excavate OU3 residential soil pile (9,500 CY includes 2 feet of soil below the pile) and
consolidate with the slag pile.
¦ Excavate sediment and soil based on table below:
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Media
l-\ca\ alion
Depth
Quantity
l-stimated to he
Rcmo\ ed
1 Sackll II Co\ cr
Disposal
OU1 Sediment
exceeding Eco
RGs
0.5 foot
525 CY
None. This may
be revised
during remedial
design.
Consolidate with
slag pile.
OU1 Sediment
exceeding HH
RGs
1.0 foot
276 CY
None. This may
be revised
during remedial
design.
Consolidate with
slag pile.
OU2 Sediment
exceeding Eco
RGs
0.5 foot
4,016 cy
None. This may
be revised
during remedial
design (RD).
Off-site
disposal. Off-
site disposal of
OU2 sediment
may be revised
during remedial
design resulting
in some or all of
OU2 sediment
being
consolidated
with the slag
pile.
OU1 Soil
Exceeding Eco
RGs
0.5 foot
29,072 cy
Backfill with
topsoil. May be
modified during
RD.
Consolidate with
slag pile.
OU1 Soil
Exceeding HH
RGs
2 feet
49,046 cy
Cover with clay
and topsoil.
Consolidate with
slag pile.
¦ Cover slag pile consolidation area with a low-permeability soil cover to prevent
infiltration and provide a direct-contact barrier for potential human and ecological
receptors.
¦ Restoration of disturbed areas with hydroseeding and wetlands restoration if required.
¦ Monitoring of groundwater and surface water and possibly sediment and fish tissue.
¦ Institutional controls for all areas where contamination remains above human health or
ecological risk levels or which contain remedy components.
¦ Five year reviews
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1.5 - Statutory Determinations
The Selected Remedy is protective of human health and the environment, complies with federal
and state applicable or relevant and appropriate requirements (ARARs) (unless justified by a
waiver), is cost-effective, and utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable.
The Selected Remedy does not satisfy the statutory preference for treatment as a principal
element because the large volumes of relatively low-level metals-contaminated soils, sediment,
and slag at the Site do not lend themselves to any cost-effective or practical treatment. However,
excavated materials that exceed TCLP criteria (therefore considered hazardous waste) will be
treated off site to reduce the mobility of the contaminants prior to disposal in an appropriate off-
site landfill.
Because this remedy will result in hazardous substances, pollutants, or contaminants remaining
on OU1 and OU2 of the Site above levels that allow for unlimited use and unrestricted exposure,
a statutory review will be conducted within five years after initiation of the remedial action to
ensure that the remedy is, or will be, protective of human health and the environment.
1.6 - Data Certification Checklist
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record file for this Site.
Information Item
Section(s) in ROD
COCs and their respective concentrations
Section 2.5.5
Baseline risk represented by the COCs
Section 2.7
Cleanup levels established for the COCs and the basis for
these levels
Section 2.8
How source materials constituting principal threats are
addressed
Section 2.1 1
Current and reasonably anticipated future land use
assumptions and current and potential future beneficial uses
of groundwater used in the baseline risk assessment and
ROD
Sections 2.6 and 2.12.4
Potential land and groundwater use that will be available at
the Site as a result of the Selected Remedy
Sections 2.6 and 2.12.4
Estimated capital, annual operation and maintenance
(O&M), and total present worth costs, discount rate, and the
number of years over which the remedy cost estimates are
projected
Sections 2.9.2 and 2.12.3
Key factor(s) that led to selecting the remedy (i.e., describe
how the Selected Remedy provides the best balance of
tradeoffs with respect to the balancing and modifying
criteria, highlighting criteria key to the decision)
Sections 2.10, 2.11 and
2.12
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1.7 - Authorizing Signature
EPA, as the lead agency for the Hegeler Zinc Superfund Site (ILN000508134), formally
authorizes this ROD.
X Douglas Ballotti June 7,2023
Douglas Ballotti, Director Date
Superfund & Emergency Management Division
Signed by: DOUGLAS BALLOTTI
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PART II - DECISION SUMMARY
2.1 - Site Name, Location, and Brief Description
The Hegeler Zinc Superfund Site (ILN000508134) is located six miles south of Danville in
Vermilion County, Illinois. (Figures 1 and 2). The Site encompasses approximately 149 acres
which were primarily used for zinc smelting and sulfuric acid operations. The Site is located in a
rural area surrounded by mixed land uses including commercial, agricultural, and residential.
The village of Hegel er, the nearest residential area, is directly east of the Site.
The Site consists of OU1 and OU2 with one remedy being selected in this ROD to address both
OUs. OU1 of the Site encompasses the former 149-acre zinc smelter facility and surrounding
areas, including approximately 2,000 feet of the unnamed tributary to Grape Creek (creek)
(Figures 2, 4 and 5). OU2 of the Site encompasses approximately 4,000 feet of the creek (starting
at the former zinc smelter facility fence line to the confluence with Grape Creek) and the
"KIK Culvert" on property adjoining OU1 to the east that was formerly operated by KIK Custom
Products ("KIK property") (Figure 2). Remediation work under the Resource Conservation and
Recovery Act (RCRA) is taking place on parts of the KIK property. Site features include the
7.3-acre slag pile, contaminated soils, former settling ponds, impacted areas of the KIK property,
the KIK Culvert, and a creek that runs through OU1 and becomes OU2 as it exits the former zinc
smelter facility fence line to Grape Creek (Figures 2, 4 and 5).
EPA is the lead agency for the Site, and the Illinois EPA serves as the support agency. The
selected remedial action is expected to be funded through federal remedial action funding with
associated state cost share.
2.2 - Site History and Enforcement Activities
2.2.1 Site History
Hegel er Zinc began operations in 1906 under the name of Hegel er Brothers and became known
as Hegeler Zinc in 1913. During its years of operation, Hegel er Zinc produced various grades of
zinc slab and rolled zinc products, as well as sulfuric acid and cadmium. The sulfuric acid was
produced from sulfur gas collected from the zinc ore before smelting. Around the time Hegeler
Zinc operations began, three residential neighborhoods - Hegeler, East Hegeler, and Tilton -
were developed to the east and north of Hegeler Zinc, and residential dwellings were built there
in the early 1900s.
In 1942, during World War II, the Defense Plant Corporation, a U.S. General Services Agency
(GSA), built on-site cadmium capacity and rented the cadmium units to Hegeler Zinc. The
cadmium process was added to the roasters to collect and pass fumes through electrical
precipitation units where cadmium collected as dust. Following collection, the cadmium dust was
sent offsite to cadmium smelters. The company also operated its own local coal mine to charge
its smelting furnaces.
Zinc smelting operations were shut down in November 1947. During the time of operations
(from 1906 until 1947), process stacks emitted gases and particles. Particulate smelter emissions
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typically contain the following metals derived primarily from ore: arsenic, cadmium, copper,
lead, and zinc. Windblown emissions are believed to have deposited particulates to surface soils.
The smelting operation also resulted in large amounts of slag stored in piles on-site. Slag is a
waste residue produced by the smelting process and is often associated with cinders and
incombustible pieces of coal (clinkers) used to create heat for the smelting process. After the slag
piles had grown very large, a zinc oxide plant was built that used electrolysis to reprocess the
slag and recover more metals from the material. The slag material contains unburned residues
and metals such as lead, arsenic, cadmium, and zinc. The reprocessed slag pile that currently
remains on-site occupies 7.3 acres and is 53 feet above grade. The slag pile also contains wood,
brick, and concrete debris that appear to be from building demolitions.
Zinc rolling and sulfuric acid production operations continued until at least 1954. In August
1954, Hegeler Zinc dissolved and quitclaim-deeded the operations to its sole stockholder,
National Distillers and Chemical Corporation (National Distillers). The following year, National
Distillers sold the zinc rolling mill operations to Peterson Filling and Packaging. The facility was
then used to package insecticides, shaving products, and other items. In 1956, Illinois Fireworks
Company purchased the remaining National Distillers property for the manufacturing of
fireworks until 1987. Temporary small wooden huts and inoperable tractor trailers positioned
throughout the Site were utilized to store fireworks. Many of these buildings and trailers remain
on-site. National Distillers later became Quantum Chemical Corporation, which then became
Millennium Petrochemicals (Millennium) in 1997.
In 2005, the Hegeler Zinc Superfund Site was listed on the National Priority List.
2.2.2 Previous Investigations and Response Actions
In 2003, EPA listed the Site in its CERCLA Information System database. Between 2000 and
2021, Illinois EPA, EPA, and the potentially responsible party (PRP) conducted environmental
studies at the Site that identified metals in groundwater, soil, and sediment and pesticides in
sediment as the primary contaminants.
Several previous investigations have been conducted at the Site by the Illinois EPA, U.S. EPA
and the PRP:
State of Illinois
¦ 2000 - Illinois EPA Pre-Comprehensive Environmental Remediation, Compensation, and
Liability Information System Assessment (Illinois EPA 2000)
¦ 2001 - Illinois EPA Integrated Assessment (Illinois EPA 2001)
¦ 2002 - Illinois EPA Expanded Site Inspection (Illinois EPA 2002)
U.S. EPA
¦ 2003 - Site Assessment Report (Weston 2003)
¦ 2005 - Site listed on National Priorities List (NPL)
¦ 2007 - Remedial Investigation (Weston 2007)
¦ 2010 - Preliminary Phase 1 and 2 Groundwater Data Assessment and Phase
Recommendations (CH2M 2010)
¦ 2015 - Human Health Risk Assessment, Operable Unit 1 (CH2M 2015)
¦ 2019 - Baseline Ecological Risk Assessment (BERA), Operable Unit 1 (CH2M 2019)
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¦ 2019 - 0U1 Human Health Risk Assessment (HHRA) (CH2M 2019)
¦ 2019 - Supplemental Remedial Investigation, Operable Unit 1 (CH2M 2019)
¦ 2019 - KIK Ecological Risk Assessment (ERA) Technological Memorandum (CH2M
2019)
¦ 2019 - Human Health Risk Assessment for KIK Property (CH2M 2019)
¦ 2021 - Final Feasibility Study for Operable Unit 1 (CH2M 2021)
PRP
¦ 2009 - Initial Site Characterization Report for Pesticides and Metals in Waterway
Sediments (Shield 2009)
¦ 2009 - KIK OU2 Initial Site Characterization Repot (Shield 2009)
¦ 2012 - Baseline Ecological Risk Assessment (BERA) Operable Unit 2 (AECOM 2012)
¦ 2014 - Final Human Health Risk Assessment (HHRA) Operable Unit 2 (AECOM 2014)
¦ 2018 - KIK Field Investigation Report (AECOM 2018)
¦ 2020 - Human Health Risk Assessment OU2 (2014) Re-evaluated (AECOM 2020)
¦ 2021 - Feasibility Study Report for Operable Unit 2 (AECOM 2021)
Details regarding the most significant investigations are presented below. More information
regarding Site history can be found in the Remedial Investigation (RI) and Feasibility Study (FS)
Reports and other associated Site documents.
Initial investigations were conducted by Illinois EPA as part of a CERCLA integrated
assessment at the Site in May 2001. The objective of the integrated assessment was to develop a
preliminary determination of nature and extent of contamination to serve as a baseline or basis
for subsequent investigations. Soil, sediment, waste (slag pile), and residential soil samples were
collected using x-ray fluorescence (XRF) and analysis by a laboratory.
In 2003, EPA completed the Site Assessment Report (Weston 2003) at the Site. In May 2003,
EPA installed a six-foot-high chain link fence including signage around the former zinc smelting
area to prevent trespassers from coming into contact with the contaminated soil and waste
material. During the initial Site Assessment, samples were collected from soil, slag, sediment,
surface water, and groundwater and analyzed for volatile organic compounds (VOCs), semi-
volatile organic compounds (SVOCs), pesticides, polychlorinated biphenyls (PCBs), metals, and
perchlorate. Perchlorate was investigated due to historical fireworks manufacturing operations at
the facility.
In 2005, the Hegeler Zinc Superfund Site was listed on the National Priority List.
EPA conducted RI fieldwork at the Site between April and May 2006, with additional sampling
in November 2006. EPA completed the RI for the Site in 2007 (Weston 2007). The RI included a
Baseline Human Health Risk Assessment (BHHRA) and a Screening Level Ecological Risk
Assessment (SLERA). The objective of the RI was to characterize the nature and extent of
contamination at the former Hegeler Zinc smelter facility. At the time, the Site had not yet been
divided into separate Operable Units (OUs). Based on the RI findings and conclusions, EPA
determined that a Supplemental Remedial Investigation (SRI) was needed to address data gaps
associated with the former Hegeler Zinc property before preparing a FS.
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2.2.3 Enforcement History
After completion of the 2007 RI, EPA conducted negotiations with the PRPs for completion of
the next steps in the Superfund process. In 2009 EPA and the PRPs divided the Site into three
separate OUs (Figure 41)
¦ OU1 consists of soil, slag, creek (surface water and sediments), and groundwater
impacted by the former Hegeler Zinc operations within the facility footprint.
¦ OU2 consists of site-impacted creek (surface water and sediments) exiting the EPA-
constructed fence for approximately 4,000 feet until it merges with Grape Creek. OU2
also includes water and sediment within the KIK Culvert. See figures 2 and 4.
¦ OU3 is the residential area referred to as the Village of Hegeler located east of the former
Hegeler Zinc property (Figure 3) which was remediated under a separate ROD and is not
part of this remedial action.
In July 2009, an Administrative Order on Consent (AOC) was signed by EPA, KIK Custom
Products, Inc. (KIK), GS A, and the current Site property owner. The AOC required the PRPs to
prepare a BERA and FS report for OU2. The OU2 AOC addressed metals and pesticide impacts
on sediment and surface water in the KIK Culvert and the creek exiting the fence line to the
former smelter facility for approximately 4,000 feet where it merges with Grape Creek. Grape
Creek was sampled under the AOC but does not need remediation. Voyant Beauty is the current
owner of the adjacent facility to the east of the smelter facility, formerly owned by KIK Custom
Products (aka the KIK property).
EPA also negotiated a second AOC with GSA and Millennium (a subsidiary of Lyondell) for an
SRI and FS at OU1 and OU3, but Millennium filed for bankruptcy under Chapter 11 in January
2009, before the AOC was finalized. In August 2009, EPA initiated the work Millennium would
have performed at OU1 and OU3. A bankruptcy settlement with Lyondell was approved in April
2010. As part of the bankruptcy settlement, the United States received partial payment by
Millennium for claims relating to the anticipated cleanup costs for the Site.
The OU3 residential area east of the former zinc smelter facility was addressed by a September
2014 Record of Decision, resulting in the cleanup of thirty-nine (39) properties exceeding
cleanup levels for either arsenic or lead in the village of Hegeler. This remediation work was
completed in 2016 (Figure 3). Contaminated material from the residential properties was
stockpiled within the fenced property at the facility. The stockpile will be addressed as part of
this Record of Decision (see green polygon at NW end of OU1 in Figure 5 for location of
stockpile).
1 The OU boundaries defined in the 2009 AOC have changed based on the data collected during the SRI. Refer to Site
Characteristics Section, for the discussion on how EPA's current understanding of the site boundaries has evolved.
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2.2.4 Supplemental Remedial Investigation/Feasibility Study (SRI/FS)
Between 2009 and 2021, EPA conducted various supplemental investigations in and around the
footprint of the former zinc smelter facility including collection of soil, groundwater, surface
water, and sediment data.
The PRPs conducted the OU2 SRI and FS to determine the nature and extend of metals and
pesticides contamination in the KIK Culvert, the creek and Grape Creek and refined the sediment
remediation footprint (Figure 2).
The significant findings and conclusions from the characterization activities completed during
the RI and SRI and the remedial alternatives considered in the OU1 and OU2 FS Reports are
summarized in this ROD. Additional details are contained in the Final RI and SRI Reports and
FS Reports and other documents in the Site's Administrative Record.
2.3 - Community Participation Activities
EPA has conducted community outreach for the Hegeler Zinc site throughout the Superfund
process. Most recently, the public was made aware of the Proposed Plan via a mailed fact sheet
and an advertisement placed in the Danville Commercial News on November 29, 2022. A public
hearing was held to discuss the Proposed Plan and document the public's comments and
questions from 5:30 to 8:00 p.m. on December 7, 2022 at the Danville Area Community
College's Bremer Conference Center. A small number of local residents were in attendance.
This meeting coincided with the EPA's open comment period for the Proposed Plan, held from
December 1 to December 31, 2022. Members of the public were advised that they could submit
comments on the Proposed Plan in a number of ways: (1) using the comment form on EPA's
webpage at www.epa.gov/superfund/hegeler-zinc; (2) submitting a written comment via email to
safakas.kirstin@epa.gov: (3) submitting a written comment by mail to U.S. EPA Region 5, Re:
Kirstin Safakas, 77 West Jackson Boulevard (RE-19J), Chicago, Illinois 60604-3590; or (4)
leaving a verbal comment by voicemail at 312-919-4621. As noted in the Responsiveness
Summary, which is provided in Part III of this Record of Decision, EPA received comments from
four individuals during the public comment period.
The RI Report, FS Report, Proposed Plan, 2006 Final Community Involvement Plan and other
related documents for the Site are in the Administrative Record file, which is and will remain
available to the public at the following locations: the agency's information repository maintained
at the EPA Region 5 Records Center, located at 77 West Jackson Boulevard (7th Floor) in
Chicago, Illinois; a local information repository located at the Danville Public Library, 319 N.
Vermilion St. in Danville, Illinois; and online at www.epa.gov/superfund/hegeler-zinc under
"Site Documents & Data".
2.4 - Scope and Role of Operable Unit or Response Action
On September 26, 2014, EPA issued a ROD to address OU3 residential soils associated with the
Site in the Hegeler residential area located east of the former Hegeler Zinc property. In July
2016, EPA completed the cleanup of thirty-nine properties with soil concentrations above the
selected cleanup levels for lead at 400 milligrams per kilogram (mg/kg) and arsenic at 35 mg/kg.
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All contaminated soils excavated from the residential area were characterized as non-hazardous
and stockpiled for consolidation on the former zinc smelter property inside the EPA-constructed
fence (Figure 5). The stockpile was dormant-seeded and covered with an erosion control blanket
and will be addressed in this Record of Decision.
OU1 and OU2 are the subject of this second ROD for the Site. EPA's overall strategy for
cleaning up the remaining Operable Units at the Site, is to address the contaminated soil, slag,
and sediment associated with the former zinc smelting site and surrounding area (OU1), and
contaminated sediment in the creek (OU2) simultaneously to bring risk to human health and the
environment down to protective levels before selecting a final remedy for groundwater and
surface water. The selected remedy includes interim remedies for surface water and groundwater
to prevent human exposure to these media after this source control remedy is implemented. EPA
considers the surface water remedy interim based on groundwater/surf ace water interaction.
These interim remedies give EPA time to evaluate the impact of the selected source-control
remedy on contaminant concentrations in groundwater and surface water before deciding if there
is a need for a final remedy.
EPA expects that the selected response action will be the final action for contaminated soil,
sediments and slag at OU1 and OU2, and notes that the cleanup level for lead in soil at
commercial/industrial properties is considered final.
EPA's primary response action is to excavate, contain, and cover the low-level threat waste at
the Site so that current and future unacceptable risks to human health and the environment are
significantly reduced to protective levels. EPA defines low-level threat wastes as those source
materials that generally can be reliably contained and that could present only a low risk in the
event of release. They include source materials that exhibit low toxicity, low mobility in the
environment, or are near health-based levels. The selected response action is expected to also
reduce to acceptable levels the risks associated with future exposure to groundwater and surface
water.
Containment of low-level threat waste is considered by EPA to be a preferred technology for
metals-in-soil sites in many cases. Containment of low-level threat waste has been identified by
EPA as a presumptive remedy for metals-in-soil sites because it repeatedly has been shown to be
an effective remedy at other CERCLA sites. Presumptive remedies were developed by EPA to
streamline the selection of cleanup methods for certain categories of sites by narrowing the
consideration of cleanup methods to treatment technologies or remediation approaches that have
a proven track record in the Superfund program. EPA has determined that it is appropriate to
apply the presumptive remedy for metals-in-soil at this Site based on the soil and contaminant
characteristics found at the Site and guidance provided in the directive entitled Presumptive
Remedy for Metals-in-Soil Sites (EPA 540-F-98-054).
2.5 - Site Characteristics
2.5.1 Conceptual Site Model for Hegeler Zinc Site
A Conceptual Site Model (CSM) is a three-dimensional "picture" of Site conditions that
illustrate contaminant sources, release mechanisms, exposure pathways, migration routes, and
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potential human and ecological receptors (USEPA 1999). A CSM has been developed based on
the RI and SRI investigations and integrating technical information from a variety of sources,
including physical characteristics of the site, nature and extent of contamination, and
contaminant fate and transport pathways. A graphic depiction of the CSM for the Hegeler Zinc
Site is provided in Figure 6. Flow charts depicting the conceptual site model for OU1 human
receptors, OU1 ecological receptors, and OU2 ecological receptors are provided in Figures 7a,
7b, and 7c, respectively. The conceptual site model for OU2 human receptors is depicted in
Table A-1.
The COCs identified at the Site are metals and pesticides. The CSM indicates that the primary
sources of contamination at the Site were former smelter operations (including stack emissions,
contaminated soils, settling ponds and a 7-acre pile of slag) and sediments contaminated with
metals and pesticides in the creek.
The following migration routes have been identified for OU1 and OU2:
¦ Surface water runoff (overland flow)
¦ Infiltration
¦ Groundwater discharge to the creek
¦ Aerial deposition
¦ Redistribution
The current sources of metals contamination are the 7-acre slag pile and site-wide soil
contamination. Physical transport, chemical leaching and infiltration of contamination from the
soils/slag are the most significant potential transport mechanisms. Figures 6, 7a, and 7b display
potential migration routes for metals.
Metals in surface soil tend to be immobile. The contaminants are strongly sorbed to soil, are
relatively insoluble in water, and are nonvolatile. However, they can be transported with the soil
by erosion, surface water runoff and leaching to groundwater. Metals can be released from the
soil through infiltration into groundwater, groundwater discharges to the fire pond and the creek,
impacting surface water and sediments. The uncovered slag pile and other surface soil
exceedance areas associated with former industrial areas, present a primary exposure pathway
via runoff to the adjacent creek and its contributing branches, resulting in contamination of
sediment and surface water.
Pesticides are a Chemicals of Ecological Concern (COECs) in sediment. The potential
mechanisms for pesticide migration include erosion and runoff from soils or any undocumented
spill or release. Wind-blown particles may also be deposited directly in the waterways or on
surface soil that could then be eroded and runoff into the waterways.
2.5.2 Site Topography
The topographic relief in Vermilion County is low to moderate. There is minimal topographic
gradient on the Site, except for the manmade slag pile, which is approximately 53 feet above grade
at its highest point (Figure 5). The Site's topography has been altered by industrial activity, storage
of slag, and creation of drying beds and settling ponds.
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2.5.3 Geologic/Hydrogeologic Setting
The regional geology at the Site is composed of unconsolidated manmade or reworked geological
materials (fill) overlaying Quaternary-aged deposits, which is underlain by Pennsylvanian-aged
bedrock (Kosanke et al. 1960). Fill of varying thickness covers the majority of OU1 and includes
material deposited or reworked by human activities since the zinc smelter facility operated in the
early 1900s. Fill consisting of unconsolidated slag, construction debris, and reworked geological
materials generally ranges from 1 to 3 feet thick. Deeper deposits of fill, extending up to 11.5
feet bgs, are located east of the slag pile, along the creek, and along roads where slag was used
for construction.
2.5.4 Regional Hydrogeology
Hydrogeology is composed of two water-bearing zones at the Site, Zone 1 and Zone 2. The
uppermost, unconsolidated fill and quaternary deposits (Upper Zone 1) within the underlying
weathered bedrock (Lower Zone 1) make up Zone 1. Upper Zone 1 is found within 5 to 28 feet
bgs and Lower Zone 1 is found from 28 to 80 feet bgs. Zone 2 is defined as the unweathered
bedrock water-bearing unit from 80 to 170 feet bgs where water flows primarily through coal
seams. Geochemical data and hydraulic data collected as part of the Phase 3 SRI indicate that
Upper and Lower Zone 1 are hydraulically connected and that little to no hydraulic
communication occurs between Lower Zone 1 and Zone 2.
The State of Illinois classifies groundwater based on potential use and assigns different cleanup
standards to aquifers based on this classification. During the RI, EPA collected data to assess the
classification of the shallow aquifer in accordance with the requirements of Illinois
Administrative Code (IAC) Title 35, Part 620. Based on the 2019 SRI, EPA found that Zone 1
and Zone 2 meet the requirements of Class I Potable Resource Groundwater (35 IAC 620.210
Subpart B). Therefore, EPA evaluated the shallow aquifer as a Class I potable resource
groundwater aquifer for the interim groundwater remedy. The Class I classification may be re-
evaluated during the remedial design or during the decision-making process for a final
groundwater remedy.
The Site includes various surface water bodies (Figures 2 and 5) including settling ponds, a fire
water pond, Lake Harry and the creek. In general, the OU1 creek channels are straight and
appear to have been created to drain surface water runoff from the Site and surrounding farm
fields. The creek that transects the former smelter facility near the slag pile originates from the
North Branch, which originates 1 mile north of the Site, and the South Branch, which originates
1 mile south of the Site. The South Branch joins the North Branch just north of the slag pile, and
then the creek flows northeast and eventually converges with Grape Creek. Another mile
downstream, waters from Grape Creek either enter Tilton Lake or follow the creek south through
Tilton, Illinois, into the Vermillion River.
In the central portion of the Site, the KIK culvert (located on the KIK property) discharges to the
creek on the former smelter facility property and then flows to the northeast.
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The settling ponds cover approximately 3.34 acres and are ephemeral, only containing water
after rain events. Based upon site topography, there is the potential for surface water runoff to the
settling ponds from the slag pile to the north.
The fire water pond spans approximately 1.5 acres and was built in approximately 1920 as a
place to store coal from the Hegeler Mine to prevent spontaneous combustion from igniting coal.
The fire water pond is approximately 20 feet deep and has steep embankments with an
approximate 10-foot elevation change to the water's surface. The bottom of the fire water pond is
approximately 30 feet below the surrounding ground surface elevation. The fire water pond is
not connected to other Site surface water features. Due to the depth and shallow water table, it is
assumed groundwater is discharging to the fire water pond. Based upon Site topography, there is
potential for surface water runoff to the fire water pond from the northeast, east, south, and
southwest.
Lake Harry, located in the southwest portion of the KIK property, is a manmade lake created by
KIK in 1989. Clay and soil were excavated from the location of Lake Harry to use as cover
material for the RCRA surface impoundment on the KIK property (Figure 5). Lake Harry is
approximately 15 feet deep and is not connected to other Site surface water features. Based upon
Site topography, there is potential for surface water runoff to Lake Harry from immediately
adjacent areas including from the heavily vegetated area to the north, the closed RCRA surface
impoundment to the northeast, and the farmlands to the south and east. As shown in Figure 5, the
drainage ditch to the south of, and immediately adjacent to, the settling ponds intercepts surface
water runoff from the slag pile.
The KIK Culvert is an approximately 700-foot-long ditch with shallow water and minimal
northwesterly flow on the northwestern portion of the KIK property. The width of the stream
within the culvert varies from 4 to 16 feet and the banks of the culvert are vegetated with grasses,
saplings, and trees. Source water from the KIK Culvert includes reverse osmosis backwash and
stormwater discharged from the former KIK Custom Products facility under National Pollution
Discharge Elimination System (NPDES) permit IL0004162 at outfall 001 and an upstream
stormwater basin at outfall 002. Water from outfall 001 is free of process wastewater and is
monitored for flow rate, pH, total residual chlorine, total suspended solids, and chloride. The two
outfalls discharge an average of 0.035 million gallons of water into the KIK Culvert each day.
The creek exiting the OU1 fence line (Figures 2 and 10) is a 4,000 feet long portion of an
unnamed tributary to Grape Creek that flows through agricultural and residential areas to the
confluence with Grape Creek. This stretch of the tributary is largely channelized and features
some deeper pooled areas, vegetated sand bars, and depositional point bars. The tributary
channel is approximately 10 to 15 feet wide in agricultural and residential areas. The banks of
the tributary are vegetated throughout and strewn with debris in some areas. Tile drains
discharge surface water from the eastern farm fields in two locations and a secondary channel
discharges into the stream approximately 200 feet downstream of the railroad crossing.
2.5.5 Nature and Extent of Contamination
The 2007 RI and subsequent SRI determined that the primary sources of metals contamination
are associated with the contaminated slag and soils from the former Hegeler Zinc smelter facility
operation.
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Soil
Ninety-nine surface soil (0-2 feet bgs) and 77 subsurface soil samples (greater than 2 feet bgs)
were collected during the RI and SRI between 2006 and 2017. Total metals, SVOCs, Polycyclic
Aromatic Hydrocarbons (PAHs), total organic carbon (TOC), PCBs, pesticides, VOCs, mercury,
and perchlorate were analyzed. The primary contaminants frequently found exceeding EPA
industrial screening levels in soils were lead and mercury (Table 1). Arsenic exceeded Illinois
EPA's Tiered Approach to Corrective Action Objectives (TACO) criteria (Table 1).
Table 1 - Summary of Maximum Concentrations of Metals in Soil
that Exceeded Human Health Screening Criteria
Contaminant
# Samples
collected during
RI and SRI
(2006 -2017)
Maximum
Concentrations
(mg/kg)
EPA Industrial
Regional Screening
Level (mg/kg)
unless noted
Arsenic
176
113
11.3*
Lead
176
40,200
800
Mercury
141
297
46
* Illinois EPA Background TACO
Metals concentration are the highest in the slag pile and within the EPA constructed fence as
well as portions of the adjacent KIK property. Metals concentrations were generally less than
screening criteria in the adjacent farm fields/tree areas and in the eastern portions of the KIK
property. VOCs, SVOCs, and PAHs concentrations were generally less than industrial screening
levels. Perchlorate was not detected.
Agricultural Fields
Agricultural surface soil data was collected to assess if agricultural fields adjacent to OU1 have
been contaminated by Site activities by either windborne particle deposition or track out of
contaminated materials. A total of twenty-two surface soil samples were analyzed with an XRF
field instrument for concentrations of lead and eight soil samples were analyzed at a laboratory
for total metals. Samples were collected from 0 to 0.25 feet bgs within a 200 feet radius from the
Site perimeter during the RI. None of the soil samples collected during the RI contained metals
exceeding Illinois EPA's TACO industrial/commercial screening levels. The BHHRA identified
no human health risk drivers in the agricultural fields, removing them from further
investigations.
Settling Ponds
The settling ponds are frequently dry; therefore, the laboratory analytical results of the settling
pond samples were compared to both soil and sediment screening levels. Eight soil samples were
collected from 0 feet bgs to the water table in the settling ponds. None of the samples collected
from the settling ponds during the RI exceeded the lead industrial regional screening level (RSL)
for human health. The samples were also below the adjusted noncarcinogenic hazard quotient of
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1 for additive effects of the hematological system for antimony and zinc. Six sediment samples
and one soil sample were collected from 0 to 0.5 feet bgs in the settling ponds and compared to
ecological screening levels. Ecological screening levels were exceeded in all samples with
analytical results indicating maximum concentrations of cadmium (108 mg/kg), lead (729
mg/kg), manganese (381 mg/kg) and zinc (17,800 mg/kg). Surface water samples collected from
the settling ponds were not included in the risk assessment. The settling ponds are different
chemically and hydrologically than the other waterways and would not be representative of
ecological exposure conditions elsewhere on-site. Although the surface water samples from the
settling ponds were not included for RG development, RGs proposed in the 2021 technical
memorandum would be applicable to the settling ponds. Furthermore, the high invertebrate
toxicity observed in these samples may be a result of the acidic nature of the ponds.
Sediment
During the RI and SRI sediment samples were collected upgradient and downgradient of Site
waterways to determine vertical extent of contaminant concentrations. Sediment samples were
also collected from the settling ponds, fire water pond, KIK Culvert, and the creek.
¦ Fourteen sediment samples were collected from the settling ponds, fire water pond and
the creek in OU1 and compared to human health screening criteria. Analytical results
indicate that the cadmium screening criteria was exceeded in two samples with
concentrations ranging from 0.73 mg/kg to 834 mg/kg.
¦ Twenty-eight samples were collected from OU1 and compared to ecological screening
criteria. Analytical results indicate that the cadmium screening criteria was exceeded in
sixteen samples with concentrations ranging from 0.53 mg/kg to 834 mg/kg; lead
screening criteria was exceeded in eleven samples with concentrations ranging from 13.8
mg/kg to 729 mg/kg; and zinc was exceeded in seventeen samples with concentrations
ranging from 100 mg/kg to 44,000 mg/kg. Sediment samples were analyzed for metals,
VOCs, SVOCs, PCBs, pesticides, and perchlorate.
¦ Of the eighty-four sediment samples collected in the creek downstream of the former zinc
smelter facility sixty-three contained metals at concentrations above ecological screening
levels, indicating impact from material produced at the Site. No unacceptable human
health risks were identified by the HHRA for recreational adolescent receptors exposed to
OU2 Waterway sediment and surface water, or the future industrial worker or the future
recreational adolescent receptors exposed to KIK Culvert sediment and surface water,
thus sediment samples collected from OU2 waterways were compared to ecological
screening levels. Antimony, arsenic, cadmium, copper, iron, lead, manganese, mercury,
nickel, silver, and zinc exceeded screening criteria. Cadmium, silver, and zinc exceeded
criteria most frequently in the creek.
¦ Elevated concentrations of pesticides, and metals were detected in sediment samples
collected from the KIK culvert and are summarized in Table 2. Pesticides exceeding
ecological screening criteria include: 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, aldrin, alpha-
chlordane, dieldrin, endosulfan I, endrin, heptachlor, heptachlor epoxide, and
methoxychlor. Detected concentrations of pesticides were highest in the KIK Culvert and
decreased downstream with distance from the culvert. VOCs and perchlorate were not
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detected. The extent of pesticide contamination from the KIK culvert and downgradient
of the Site are addressed in the OU2 BERA/FS.
¦ Table 2 - Summary of Maximum Concentrations of Metals and Pesticides in Sediment
that Exceeded Human and/or Ecological Screening Criteria
Contaminant
# Samples
Minimum
Maximum
collected during
Concentrations
Concentrations
RI and SRI
(2006 -2017)
(mg/kg)
(mg/kg)
Cadmium
60
0.13
834
Silver
60
0.023
12
Zinc
60
41
44,000
4,4'-DDD
24
0.0017
130
4,4'-DDE
24
0.0017
8.7
4,4'-DDT
24
0.0005
41
Groundwater
Groundwater at the Site has been characterized as two separate water-bearing units: Zone 1
(Upper Zone 1 and Lower Zone 1) and Zone 2. Upper Zone 1 maximum concentrations of total
metals in groundwater are summarized in Table 3. Upper Zone 1 maximum concentrations of
dissolved metals in groundwater are summarized in Table 4. Groundwater was not identified as a
complete ecological exposure pathway because drinking water is supplied by a water utility. All
screening criteria exceeded below were for human health.
In Upper Zone 1 (5-28 ft bgs), dissolved metals exceeding screening criteria included aluminum,
arsenic, beryllium, cadmium, chromium, iron, lead, manganese, nickel, thallium, vanadium, and
zinc. During the SRI, sixty-six groundwater samples were collected from thirty-four Upper Zone
1 monitoring wells. The highest metals concentrations in Upper Zone 1 were consistently located
in the central and northeastern portions of the Site (slag pile extending to the KIK property).
In Lower Zone 1 (28-80 ft bgs), dissolved metals exceeding screening criteria included
antimony, arsenic, iron, lead, manganese, selenium, and thallium. Other than iron and
manganese, exceedances of screening criteria were infrequent. Iron and manganese impact the
most monitoring wells, but these metals are associated with weathered shale bedrock, the
geology in which the Lower Zone 1 wells are screened.
Perchlorate was detected in groundwater monitoring well 6 during the SRI at 5.81 |ig/L, which is
below the maximum contaminant level (MCL) of 15 |ig/L.
In Zone 2 (80-170 ft bgs), dissolved metals exceeding screening criteria included
arsenic, barium, cadmium, iron, lead, manganese, and thallium. Based upon hydraulic and
geochemical data collected during the SRI, the concentration of metals detected in Zone 2
groundwater monitoring wells are due to naturally occurring contamination from coal deposits
and/or local mine-workings and not Site-related (Phase 3 Groundwater Data Results-OUl of the
Hegeler Zinc Superfund Site, Danville, Illinois [CH2M 2011]). The elevated barium
concentrations detected in the Zone 2 monitoring wells are not present in the Zone 1
groundwater samples and groundwater derived from coal layers may also contain naturally
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occurring concentrations of manganese, as a result of oxidation of sulfide minerals in coal (Stone
and Snoeberger 1978; Banasczak 1980).
Table 3 - Summary of Maximum Concentrations of Total Metals in
Groundwater from Upper Zone 1
Contaminant
# Samples
Minimum
Maximum
collected during
Concentrations
Concentrations
RI and SRI
(2006 -2017)
Og/L)
Og/L)
Aluminum
104
13.2
442000
Antimony
104
2.4
14.3
Arsenic
104
0.27
188
Barium
104
7.5
15000
Beryllium
104
0.089
40.3
Cadmium
104
0.02
629
Chromium
104
0.29
4660
Cobalt
104
0.14
595
Copper
104
0.66
14300
Iron
104
34.4
981000
Lead
104
0.16
2990
Manganese
104
1.8
25700
Vanadium
104
0.15
610
Zinc
104
2.1
58300
Table 4 - Summary of Maximum Concentrations of Dissolved Metals in Groundwater from
Upper Zone 1
Contaminant
# Samples
Minimum
Maximum
collected during
Concentrations
Concentrations
RI and SRI
Og/L)
Og/L)
(2006 -2017)
Aluminum
104
2.7
448000
Antimony
104
2.5
10.6
Arsenic
104
0.21
19.1
Barium
104
9.6
14500
Beryllium
104
0.35
38.2
Cadmium
104
0.058
589
Chromium
104
0.067
248
Cobalt
104
0.08
160
Copper
104
0.084
254
Iron
104
131
192000
Lead
104
0.12
33.8
Manganese
104
2.2
912000
Vanadium
104
0.05
293
Zinc
104
0.49
46000
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Surface Water
Surface water samples were analyzed for dissolved and total metals, PCBs, pesticides, SVOCs,
VOCs, mercury, and perchlorate. Detected concentrations of the following dissolved or total
metals exceeded screening levels in surface water: aluminum, beryllium, cadmium, cobalt,
copper, iron, lead, manganese, mercury, nickel, selenium, silver, and zinc. Aluminum cadmium,
manganese, and zinc exceeded criteria most frequently. Highest metals concentrations were
found in the settling ponds and creek adjacent to the settling ponds.
¦ Ten surface water samples were collected, analyzed, and compared to human health
screening criteria. Analytical results indicate that the cadmium screening criteria was
exceeded in four samples and that concentrations ranged from 0.14 |ig/L to 465 |ig/L for
total cadmium and 0.14 [ig/Lto 510 [ig/L for dissolved.
¦ Nineteen surface water samples were collected, analyzed, and compared to ecological
screening criteria. Analytical results indicate that aluminum screening criteria was
exceeded in 3 samples and concentrations ranged from 13.1 |ig/L to 367000 |ig/L.
Cadmium screening criteria was exceeded in 4 samples and concentrations ranged from
0.14 |ig/L to 510 |ig/L. Lead screening criteria was exceeded in 1 sample and
concentrations ranged from 1.3 |ig/L to 24.7 |ig/L. Manganese screening criteria was
exceeded in 2 samples and concentrations ranged from 1.4 |ig/L to 11500 |ig/L. Zinc was
exceeded in 5 samples and concentrations ranged from 6.1 |ig/kL to 64,600 |ig/kL.
Metals in the upgradient creek (North and South branches), and Lake Harry were
generally below screening levels. Pesticides were detected above screening levels in the
KIK Culvert and the creek. Perchlorate was not detected in surface water.
Based on the above findings, the OU1 boundary as defined in the 2009 AOC was expanded
beyond the EPA-constructed fence. The footprint of the contamination related to the former zinc
smelter activities includes portions of the adjacent KIK poperty, the fire water pond, and other
areas needing soil remediation (Figure 5).
2.6 - Current and Potential Future Land and Resource Uses
Current Land Use
The 149-acre former smelter facility property of the Site is currently zoned industrial, and is a
vacant property owned and managed by an individual. The vicinity around the Site consists of
mixed land uses, including commercial/industrial, agricultural and residential. The former
Hegeler Zinc property is bordered by agricultural properties to the north, west and south. The
adjacent KIK property location is on the historic Hegeler Zinc smelter facility operations
footprint. The village of Hegeler is east of the Site. Based on the presence of the large-scale slag
pile and extensive amount waste materials present, EPA concluded that residential land use in
OU1 is not reasonably anticipated. Use of the KIK property would also not be reasonably
foreseeable as residential or recreational, based upon the presence of active industry and the
RCRA impoundment. Therefore, on-site residential and recreational land uses were not
evaluated.
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Future Land Use
Future land use at the Site is not expected to differ significantly from current land use, which is
industrial. After implementation of the Selected Remedy, land use at the Hegeler Zinc Site is
anticipated to be industrial. The risk assessments for this Site assume only commercial/industrial
or trespasser future land use, not on-site residential or recreational use. There are no current local
regulations preventing potable use of site groundwater so a future scenario in which industrial
workers use potable groundwater was assessed in the human health risk assessment.
Groundwater
The Hegeler and Tilton neighborhoods are served by public water supply corporation Aqua
Illinois, which obtains drinking water from Lake Vermilion. Five private residential wells were
identified within the 1-mile buffer south and southeast of the Site. The direction of regional flow
of groundwater cannot be determined due to the limited extent of the groundwater well network.
EPA will conduct further groundwater investigations to determine if the five wells are located
upgradient or downgradient of the Site during the pre-design investigations. EPA will make a
decision after this remedy is implemented regarding whether or not a ROD to address
groundwater contamination would be appropriate.
The Site Zone 1 and Zone 2 aquifers are both classified as IL Class I potable resource aquifers by
IL EPA. Because contaminants in Zone 2 are not Site-related it is not included in the interim
groundwater remedy. The Site Zone 1 aquifer is considered a potential future drinking water
source.
2.7 - Summary of Site Risks
2.7.1 Human Health Risks
The potential risk to human health by contaminants detected in media (soil, slag, sediment,
surface water, and groundwater) was evaluated in two OU1 HHRAs to determine the current and
future risks to human health from contamination associated with the former zinc smelter
operations. The results of the HHRA for the portion of the OU1 not located on the KIK property
includes Exposure Areas 1, 2, and 3 from the OU1 HHRA (Figure 8a). Exposure Area 4 of the
HHRA OU1 includes the fire water pond and KIK property (Figure 8b). Note that Exposure Area
4 in the HHRA extends past the fire water pond, but the remedial alternatives (Figure 13) only
extend a small portion past the access road surrounding the fire water pond. The portion of OU1
that is located on the KIK property and that includes the fire water pond was addressed in a
separate HHRA. Lake Harry was also addressed in the HHRA but is not discussed in this risk
assessment section since the remedial design does not include it. The potential risk posed to
human health by contaminants (metals and pesticides) detected in sediment associated with the
OU2 SRI and OU2 HHRA are also summarize below.
Summary of OU1 Human Health Risk Assessment
First, the exposure areas, types of human receptors at the Site, reasonable exposure scenarios,
and pathways of concern are explained based on the CSM (Figures 6, 7a, 7b, and 7c and Table
1). Second, human health risk assessment chemicals of concern are summarized in Table A-2. As
defined in the Risk Assessment Guidance for Superfund: Volume 1 Human Health Evaluation
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Manual, Part D (EPA 540-R-97-033, January 1998), these COCs are the "risk drivers." Third, a
brief summary of the carcinogenic and non-carcinogenic toxicity data used to calculate the risk
of each COC and the primary target organs and health effects of concern for non-carcinogenic
COCs is shown. Fourth, the overall combined risks reflecting total exposure to COCs in a given
medium and pathway of exposure are quantified (Table A-3). Finally, a discussion of the
assumptions and procedures that introduce the greatest amount of uncertainty in the HHRA, as
well as their effect on the estimates of potential risk, is evaluated.
Exposure Areas
For purposes of conducting the OU1 HHRAs, the Site was subdivided into four exposure areas
as shown on Figure 8a. Note that Figure 8b is the fourth exposure area and was analyzed in a
separate HHRA. This was done to facilitate risk-based decisions for portions of the Site where
different exposure patterns may occur, by current or future receptors, and where different levels
of contaminants are present.
Exposure Area 1—The areas at the northwestern and northeastern edges of the Site,
where relatively little industrial activities historically occurred.
Exposure Area 2—The heavy industrial areas of the former zinc smelter activities,
including the area to the south of the main slag pile where the settling ponds are present.
This area does not include the KIK property.
Exposure Area 3—The main slag pile.
Exposure Area 4 - The KIK property and fire water pond
Each exposure area was evaluated separately in the HHRA, except for groundwater, which was
evaluated sitewide within the on-site area.
Human Receptors, Reasonable Exposure Scenarios, and Pathways of Concern
Based on the current and reasonably foreseeable future Site conditions, the following potential
current and future human receptors were identified and evaluated for Exposure Areas (EA) 1, 2,
and 3. See the CSM from the HHRA OU1 (Figure 7a (fore EAs 1-3) and Figure 7d (for EA4)).
Current On-site Trespassers—Adolescent trespassers (ages 6 to 16) who may contact surface soil
(0-2 feet bgs) in Exposure Areas 1-4: sediment in the settling ponds, fire water pond, and creek in
Exposure Areas 2 and 4: and surface water in settling ponds, fire water pond, and the creek in
Exposure Areas 1, 2, and 4.
¦ Body weight of the adolescent trespasser (44.3 kilogram) is the average of the mean
values for boys and girls for the ages 6 through 16.
¦ It was assumed that an adolescent trespasser would frequent the site 1 day per week and
be exposed to sediment and soil for 4 hours (and surface soil for 1 hour) each day they
were on-site from the age of 6 to 16.
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¦ The dermal surface area of a trespasser exposed to contaminated soil and sediment media
was assumed to include the head, hands, forearms, and lower legs. For surface water it
was assumed that feet would be exposed in addition to the other body parts listed above.
¦ The averaging time for cancer was calculated as the product of 70 years assumed human
lifetime. Age-dependent adjustment factors were applied to chemicals that act through
mutagenic mode of action to address susceptibility associated with early age exposure.
Future On-site Industrial Workers—Industrial workers who may contact on-site total soil (0-10
feet bgs) in Exposure Areas 1-4; sediment in the settling ponds, fire water pond, and creek in
Exposure Areas 1, 2 and 4; surface water in settling ponds, fire water pond, and the creek in
Exposure Areas 1, 2 and 4; and sitewide groundwater. Although it is unlikely that site
groundwater will be used as a drinking water source in the future, future potable use of on-site
groundwater by on-site industrial workers was evaluated since there are no current local
regulations preventing potable use of site groundwater. Since site-related chemicals are
inorganics (and are not volatile), inhalation exposures from groundwater use are not a concern.
¦ Average body weight was assumed to be 80 kilograms for an industrial worker.
¦ It was assumed that a future industrial worker would be on-site for 250 days per year (8
hours per day) for 25 years.
¦ Surface area of body parts exposed to soil includes the head, hands, and forearms.
¦ The averaging time for cancer was calculated as the product of 70 years assumed human
lifetime.
Future On-site Construction Workers—Construction workers who may contact total soil (0-10
feet bgs) in Exposure Areas 1-3, sediment in the creek in Exposure Areas 1 and 2, and surface
water in settling ponds and the creek in Exposure Areas 1 and 2 during future site
redevelopment/construction activities. Construction worker contact with sediments and surface
water in the fire water pond is expected to be infrequent and not significant.
¦ Average body weight was assumed to be 80 kilograms for an industrial worker.
¦ It was assumed that the future construction worker would be on-site for 250 days per year
(8 hours per day) for 1 year.
¦ Surface area of body parts exposed to soil includes the head, hands, and forearms.
¦ The averaging time for cancer was calculated as the product of 70 years assumed human
lifetime.
Current/Future Offsite Residents - Adult and child residents who may contact groundwater
through potable household use (including showering/bathing) from offsite wells, and vapor
intrusion from groundwater to indoor air (assuming that offsite groundwater may be
impacted by migration of site groundwater).
Summary of Chemicals of Concern
In general, COCs are identified when the potential excess lifetime cancer risk (ELCR) for a
receptor group exceeds EPA threshold values (a total ELCR of lxlO"4 or a target organ-specific
hazard index (HI) of 1). If a medium-specific ELCR or target organ-specific HI exceeds EPA
Hegeler Zinc ROD
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threshold values, individual chemicals contributing an ELCR >lxl0"6 or hazard quotient (HQ)
>0.1 to the target organ HI are identified as COCs for that exposure medium. Therefore, a
contaminant was carried through risk assessment as a COC if it posed an ELCR greater than
EPA's acceptable risk range for cancer risks. Additionally, lead is identified as a COC on an
industrial property if there is a 5% probability that a fetus' blood lead level will exceed a 5 |ig/dL
blood lead target level, as predicted in pregnant on-site workers via the Adult Lead Model.
Table 5 below summarizes the media and associated COCs for each exposure area. In general,
the COCs include cadmium, lead, antimony, and zinc (except for groundwater which has a larger
list of COCs). There are no soil COCs identified in Exposure Area 1 (surrounding agricultural
land). Table A-2 provides details of each COC and the target organ it affects, the frequency of
detections, the minimum concentration, maximum concentration, and exposure point
concentration that was used to calculate the associated risks and hazards. Table A-3 is a
summary of the risks and hazards for each receptor in each exposure area and a list of which
COCs are contributing to those risks and hazards that contribute to total risks and hazards to
exceed the EPA threshold values.
Table 5 - Summary of Media and Associated COCs for each Exposure Area*
Media
Chemicals Of Concern (COCs)
Total Soil (0-10 feet bgs)
Lead—Exposure Areas 2, 3, and 4
Antimony and zinc—Exposure Area 3
Sediment (0-1 feet bgs)
Cadmium - Exposure Areas 1 and 2 waterways
Surface Water
Cadmium - Exposure Area 2 waterways and settling ponds
Groundwater (on-site)
Aluminum, antimony, arsenic, barium, beryllium, cadmium, chromium,
cobalt, copper, iron, lead, manganese, vanadium, zinc- Exposure Areas 1, 2,
3 and 4
Groundwater (offsite
residential use)
Antimony, arsenic, cadmium, chromium, and zinc
Groundwater vapor
intrusion (industrial and
residential)
No COCs
*No COCs were present at the Fire Pond or Lake Harry for human health risk
Toxicity Assessment (Carcinogenic and Non-Carcinogenic Toxicity Data)
A summary of carcinogenic and non-carcinogenic toxicity data used to calculate the risk of each
COC listed above is in Table A-4. Non-carcinogenic effects are evaluated by comparing intakes
of each COC over a specified time period (chronic or subchronic) with reference doses for
similar exposure periods. The inhalation exposure pathway was evaluated, but site related COCs
are inorganics (and are not volatile); therefore, inhalation exposures from groundwater use and
soil vapor exposures are not a concern. Therefore, toxicity data related to oral and dermal
exposures is more relevant to this site.
Risk Characterization
Table A-3 is a summary of the cancer risks and hazards (non-cancer health effects) and the
COCs driving the risks/hazards. As shown in this table, the adolescent trespasser is below the
Hegeler Zinc ROD Page 26
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ELCR for cancer risks but above the hazard index of 1 in Exposure Area 1 (HI: 2) and Exposure
Area 2 (HI: 27). They are below the thresholds of the ELCR and hazard index in Exposure Area
3.
The future industrial worker is above the threshold of 1 for the hazard index (non-cancer health
effects) in Exposure Area 2 (HI: 7). On-site groundwater use by the future industrial worker
would exceed the ELCR and hazard index of 1. The ELCR is 2E-02 and the HI is 279 if potable
groundwater is used in the future for this receptor.
The future construction worker exceeds the hazard index of 1 in Exposure Areas 1 (HI: 8), 2 (HI
54), and 3 (HI: 3), but is below the ELCR of lxlO4
Uncertainty Assessment of QUI Human Health Risk Assessment
These potential risks and hazards should not be considered as representative of the actual risk
and hazard to potentially exposed individuals because they were estimated by making numerous
conservative assumptions (that is, assumptions that overestimate potential exposure and potential
risk). Thus, they have uncertainty associated with them. Some of the assumptions have a firm
scientific basis while others do not. In regulatory risk assessment, the methodology dictates that
assumptions err on the side of overestimating potential exposure and risk. This HHRA follows
EPA guidance and estimates ELCRs for a theoretical reasonable maximum exposure (RME)
individual. For example, the industrial worker is assumed to dermally contact soil for 250 days
per year for 25 years. Actual risks are likely to be less than the potential risks presented in this
HHRA.
The future soil exposure scenario introduces additional conservatism by assuming that the
subsurface soil will become surface soil during future construction activities, and that future
receptors may come in contact with the soil currently situated at 0 to 10 feet bgs. During many
construction projects, clean fill material such as topsoil is placed over the soil that is disturbed
during excavation. The topsoil material generally is needed to support growth of grass and other
landscape plants. If clean fill material is used, potential future soil exposures by industrial
workers were overestimated.
The data set for soil at the site represents a compilation of several sampling events. These subsets
consist of samples that were collected at various times for different investigations. Combining
these data sets introduces some uncertainty in the HHRA. The degree of potential overestimation
or underestimation of risk resulting from combining all of the data is unknown but is not
expected to be significant since all data were validated prior to use. The sampling that was
conducted at the site generally focused on areas of known or suspected impact from historic site
use, based on previous sampling information and observations during previous construction
activities. Therefore, the uncertainty in sampling and the possibility of missing a location
impacted by site constituents is expected to be minimal. The uncertainty associated with the data
analysis is minimal, as the data were fully validated before use in the HHRA.
The HHRA uses an approach for calculating EPCs which differs from the approach used by
Illinois EPA. Illinois EPA does not calculate a UCL in those cases when the sample size consists
Hegeler Zinc ROD
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of 8 or more samples, but there are only 5-7 detections. Illinois EPA recommends a minimum of
8 to 10 detections in the data set to provide greater confidence and less uncertainty in the
calculated UCL. In instances where 8 to 10 detections were not available, the HHRA used the
maximum detected (if less than 4 detections) per ProUCL guidance or calculated the UCL based
on 4 or more detections. There may be less confidence in EPCs calculated with fewer than 8
detections.
It should be noted that Illinois EPA uses an approach for estimating construction worker
exposures that differs from the approach used by EPA. Either approach may result in risks to
construction workers being over- or underestimated. In accordance with EPA's risk assessment
guidance, EPA generally uses the 95 percent upper confidence limit (UCL) of the arithmetic
mean, as calculated by ProUCL statistical software, as the exposure point concentration (EPC).
In accordance with 35 IAC Part 742.225(b)(3), Illinois EPA does not allow averaging sample
concentrations for the construction worker population, nor does it allow other representations of
the mean to be used as the EPC for construction workers. Instead, Illinois EPA uses the
maximum detected concentration as the construction worker EPC. However, due to the ubiquity
and prevalence of contamination at the Site, either approach generally results in the same COCs
and areas with elevated risks for the construction worker.
It should be noted that Illinois EPA uses a different (lower) ELCR threshold than EPA when
identifying COCs; Illinois EPA's ELCR threshold is lxlO"6. If Illinois EPA's threshold had been
used for the selection of COCs, arsenic would be a COC in soil for Exposure Area 1 through 3
and chromium a COC in surface water (settling ponds) in Exposure Area 2.
Lead was identified as a COPC in various exposure media (soil, sediment, surface water, and
groundwater). However, risk evaluation of lead was conducted only for soil due to limitations in
available exposure models. However, comparisons to risk-based screening levels provide a
semiquantitative evaluation of potential risks:
¦ In waterway sediment at Exposure Area 2, the average detected concentration was 296
mg/kg, which is below the industrial RSL of 800 mg/kg; therefore, not quantifying lead
exposures from sediment does not significantly affect risk estimates.
¦ In surface water in Exposure Area 2 waterways, the average detected concentration was
6.3 |ig/L, which is below EPA's drinking water action level of 15 |ig/L; therefore, not
quantifying lead exposures from surface water does not significantly affect risk estimates.
¦ In on-site groundwater, concentrations ranged from 0.16 to 2,990 |ig/L, with an average
detected concentration of 105 |ig/L and exceeding the EPA's drinking water action level
in 24 samples.
The receptors and pathways evaluated for the portion of OU1 on the adjacent KIK property are
the same as those assessed in the HHRA for the main portion of OU1. Based upon detected
chemicals in groundwater and seasonal variations in groundwater; similar to the main portion of
OU1, construction worker inhalation exposures to VOCs in trench air from shallow ground water
and direct exposure to groundwater in trenches was not quantitatively assessed. Only two VOCs
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were detected in groundwater at low concentrations below its tapwater RSL; therefore, inhalation
of volatiles in trench air is an insignificant pathway for construction workers.
The large number of assumptions made in the risk calculations potentially could introduce a
great deal of uncertainty. Although it is theoretically possible that this approach leads to the
underestimation of potential risk, the use of numerous upper-bound assumptions almost certainly
results in overestimates of potential risks. Any one individual's potential exposure and
subsequent potential risk are influenced by their individual exposure and toxicity parameters and
will vary on a case-by-case basis. Despite inevitable uncertainties associated with the steps used
to estimate potential risks, the use of numerous health-protective assumptions will most likely
lead to an overestimate of potential risks associated with site exposures.
Summary of OU2 Human Health Risk Assessment
See Table A-l for Conceptual Site Model for OU2 human receptors. The potential risk posed to
human health by contaminants detected in the sediment associated with the KIK Culvert, the
creek and Grape Creek was evaluated in the 2014 OU2 HHRA and in the 2020 OU2 HHRA
technical memorandum.
¦ KIK Culvert is within the secured area of the facility. There are no current recreational
exposures and limited current worker exposures to the surface water and sediment to the
culvert.
The tributary and much of Grape Creek are remote or inaccessible, but recreational exposures are
possible. A small portion of Grape Creek runs through a residential area. For the purpose of
conducting the HHRA, the tributary and Grape Creek were divided into exposure areas as
follows and also depicted in different colors in Figure 9.
Tributary - remote/inaccessible/undesirable - depicted in blue
Grape Creek runs through residential areas - depicted as purple
Grape Creek runs through commercial areas - depicted as orange
Grape Creek less developed area - depicted in yellow
The risk evaluation indicated that potential human health risks due to exposure to detected metals
and pesticides from both sediment and surface water were within acceptable risk levels for both
the recreational adolescent and industrial worker in all exposure areas. There were no
unacceptable cancer risks or noncancer hazards in surface water or sediment associated with the
OU2 investigation.
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2.7.2 Ecological Risks
Summary of OU1 Ecological Risks
See Figure 7b for ecological receptors and pathways at OU1.
Based on the weight-of-evidence evaluation, eight COECs (aluminum, antimony, cadmium, lead,
manganese, mercury, vanadium, and zinc) were identified across all assessment endpoints for
terrestrial and aquatic habitat receptor exposure scenarios at OU1. Table A-5 attached to this
ROD summarizes affected media, receptors, pathways, and COECs based upon the results of
ecological risk assessments.
Aluminum, lead, manganese, vanadium, and zinc are considered COECs for terrestrial plants.
Zinc was the only metal that is considered a COEC for soil invertebrates. Cadmium, lead, and
zinc are considered the COECs for benthic invertebrates. A potential for risk was indicated from
two lines of evidence for aluminum, cadmium, and lead (surface water and tissue screening).
Therefore, the metals are considered the COECs for the site based on effects in fish and water
column biota.
In 2007, EPA conducted a SLERA as part of the OU1 RI, which indicated site-related
contamination poses potential risks to ecological receptors. In 2012 EPA performed a BERA to
evaluate the potential effects of soil-associated chemicals on terrestrial and aquatic habitat
receptors inhabiting the Site. The BERA field investigation included the following:
Collecting surface soil, sediment, and surface water samples for physical/chemical analysis.
Collecting terrestrial plants, soil invertebrates, and resident fish samples from some of the soil
and sediment sample locations for tissue sample chemical analysis.
Submitting representative solid media samples for toxicity testing. Some soil samples were
subjected to rye grass and earthworm bioassays, while some sediment samples were tested using
two benthic macroinvertebrates (midge fly larvae and amphipods).
In 2017, EPA collected soil, sediment, and groundwater samples from the adjacent KIK
property, and the 2019 ecological technical memorandum concluded that all COECs identified in
the 2012 OU1 BERA and displayed in Table A-5, attached to this ROD, should also be
considered for the KIK property during the feasibility process.
For additional information please see the 2012 Final Baseline Ecological Risk Assessment OU1
(prepared by CH2M Hill), the 2019 Final, Revision 1, Baseline Ecological Risk Assessment
OU1 (prepared by CH2M) and the 2021 Final Ecological Risk Preliminary Remediation Goals
for Hegeler Zinc Superfund Site, Operable Units 1 and 2, Vermilion County, Illinois (prepared
by CH2M Hill) which can be accessed on EPA's website for this project (Search in your brower
for Hegeler Zinc Superfund Site, Danville, IL or
https://cumulis.epa. gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.scs&id=0508134&
doc=Y&colid=70252®ion=05&tvpe=SC).
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Uncertainty Analysis
Uncertainties are inherent in all risk assessments. The nature and magnitude of the uncertainties
depend on the amount and quality of data available, the degree of knowledge concerning site
conditions, and the assumptions made to perform the assessment. As such, there are uncertainties
with each line of evidence used in the BERA. The following is a summary of site-specific
uncertainties related to the data collection and analytical methods. However, there are more
uncertainties inherent to a BERA based on using literature-based toxicity values and
bioaccumulation factors that are not discussed here but are discussed in the actual BERA.
Soil Sampling Depths - Soil samples used in the BERA were collected across a range of soil
profile depths (i.e., 0 to 6 inches bgs, 0 to 0.3 foot bgs, and 0 to 2 feet bgs). Aggregating across
these soil profile depths may lead to either overestimating or underestimating the EPC.
Additionally, the 0- to 2-foot bgs interval may include soils deeper than may be relevant for
ecological receptors, and inclusion of these data may bias the UCL and, therefore, COEC
determinations.
Undetected Constituents - Several constituents were analyzed for and not detected in medium
specific samples. Because the constituents were not detected, they are assumed to not be present
in site-specific media. There is some uncertainty associated with this assumption, because some
reporting limits were higher than the screening values (for example, aluminum in surface water,
mercury in soil, etc.). However, because standardized analytical methods were used and the
sample reporting limits were not elevated relative to the method reporting limits for the vast
majority of samples and analytes, this uncertainty is considered low.
Test Duration—The use of the 10-day duration for the sediment toxicity tests may
underestimate potential effects from longer-term exposure.
Tissue Depuration—It is important to note that field-collected fish and invertebrate tissue were
not depurated prior to analysis. Therefore, tissue concentrations for the organisms could reflect
higher concentrations than what have only bioaccumulated into tissue. However, undepurated
prey reflects actual conditions and what wildlife would consume. Furthermore, assumptions
made regarding the potential incidental ingestion of sediment and/or soils were made for
wildlife receptors based on their feeding habits and prey types. Additionally, the undepurated
concentrations, as well as accounting for the incidental sediment and/or soil ingestion
assumptions in the dose estimates is a conservative approach that most likely overestimated
potential exposures.
Summary of OU2 Ecological Risks
See Figure 7c for ecological receptors and pathways at OU2. In 2012, the PRPs (KIK and GSA)
conducted a BERA, which evaluated potential risks to community-level receptors (e.g., fish,
benthic invertebrates) and higher trophic level receptors. For purposes of conducting the
ecological risk assessment, the sediment areas were divided into three areas, as discussed below
and depicted on Figure 2 (KIK Culvert, unnamed tributary exiting from fence to the confluence
of Grape Creek, and Grape Creek).
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The data collected for the BERA came from several sources and include sediment, surface water,
pore water, and fish tissue analytical chemistry, as well as sediment toxicity testing results.
Analytical chemistry results were compared against medium-specific screening values to assess
the potential ecological risks to community-level receptors and were incorporated in the food
web models to assess potential risks to wildlife.
KIK Culvert
The results of the sediment toxicity tests conducted in the KIK Culvert indicate the potential for
impact to the benthic community. The most likely ecological risk drivers and at-risk receptors
consist of the following COEC/receptor combination with Lowest Observable Effects
Concentration (LOEC)-based HQs above 1:
¦ Belted kingfisher - copper, lead, zinc, 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, and endrin
¦ Mink - 4,4'-DDD, 4,4'-DDE, and 4,4'-DDT
¦ Muskrat - copper and zinc
¦ Bullfrog - 4,4'-DDD, 4,4'-DDE, and 4,4'-DDT
¦ Northern water snake - 4,4'-DDD, 4,4'-DDE, and 4,4'-DDT
Unnamed Tributary to Grape Creek (creek)
The results of the BERA for the unnamed tributary (creek) show the highest potential for risk to
ecological receptors is closest to the EPA-constructed fence and generally decrease with distance
up to the confluence with Grape Creek. Ecological risks are low in Grape Creek: thus, no
remedial response is anticipated for Grape Creek. Table 6 summarizes the media and associated
COECs for each exposure area in OU2.
Table 6 - Summary of Media and Associated COECs for each OU2 Exposure Media
Media
COECs
Sediment
Metals: cadmium, copper, lead, mercury, and zinc
Pesticides: 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, alpha-
chlordane, dieldrin, edosulfan I, endrin, gamma-chlordane
Surface Water
Metals: cadmium, copper, and zinc
Pesticides: 4,4'-DDD, 4,4'-DDE, Aldrin, alpha- chlordane, gamma-
chlordane, heptatchlor epoxide
Uncertainty Analysis
The following is a summary of site-specific uncertainties related to the data collection and
analytical methods. However, there are more uncertainties inherent to a BERA based on using
literature-based toxicity values and bioaccumulation factors that are not discussed here but are
discussed in the actual BERA.
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The screening values used in this evaluation are based on direct or indirect toxicity, and do not
consider bioaccumulation or bioavailability. This limitation may result in an under-estimate of
potential risks. However, a food web model was used to assess potential bioaccumulation issues
in the food chain so the impact of this uncertainty on risk characterization is limited.
Due to a lack of screening values, it was not possible to fully evaluate some COECs. A fish
tissue Toxicity Reference Value (TRV) and an acute surface water screening value for iron were
not identified for use in the evaluation of fish tissue and pore water data, respectively. Therefore,
there are some uncertainties about the potential for risks to the fish and benthic invertebrate
communities due to exposure to iron. Iron concentrations in bulk sediment were evaluated so the
lack of an acute screening value in the pore water evaluation is expected to have a minimal
impact on the characterization of risks to the benthic community.
For the purposes of the chronic surface water evaluation in the OU2 Waterway, average and
maximum EPCs for total recoverable metals were calculated using data collected in different
years (2006 and 2010). Combining the datasets may result in some uncertainties if the results are
different over time. Both surface water data sets were collected during similar seasons (spring)
and results are generally similar between the different years; however, concentrations are
generally slightly higher in 2006 than in 2010. This may indicate that metals concentrations in
the OU2 Waterway are decreasing over time.
Similarly, the sediment data set considered for the KIK Culvert and OU2 Waterway included
samples collected between 2001 and 2011. It is expected that the more recently collected
samples (i.e., those collected between 2009 and 2011) are more representative of current
conditions. Therefore, exceedances based on historic data may not accurately reflect current
risks.
The basis of the bulk sediment screening values typically does not include freshwater mussels
(Order Unionoida). Therefore, the literature was reviewed to further evaluate the potential for
impacts to freshwater mussels due to exposure to COECs and to assess whether the bulk
sediment screening values used in the BERA are expected to be protective of the freshwater
mussel community. It is not clear whether mussels would be more or less sensitive to the COECs
in OU2 than the receptors that provide the basis of the surface water and sediment screening
values. Although there is some data comparing responses between mussels and surrogate species,
these studies are generally limited to water-only exposures and generally do not include other
benthic invertebrates like the amphipod or midge.
Metals are naturally occurring elements that may be present within portions of OU2 at levels
consistent with local background conditions and OU2 may be impacted by metals and pesticides
from a variety of upstream local sources (e.g., historic local agricultural uses, local industry).
Sediment samples collected from background locations and upstream areas provide information
on levels of COECs typical for the local area. In order to evaluate OU2 conditions relative to
upstream and background conditions, average and maximum EPCs from various datasets were
compared to assess the general level of contribution from upstream exposure areas. The initial
background evaluation considered the potential contribution of the Background dataset against
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both the OU2 Waterway and KIK Culvert sediment datasets. Greater than 50% of the iron and
silver EPCs from the OU2 Waterway and the silver EPC from the KIK Culvert could be related
to the Background dataset. The silver EPCs in the Background dataset were higher than those in
the OU2 Waterway dataset. These results indicate that regional levels of iron and silver may
explain a significant portion of these COECs in OU2. It may be noted that samples representing
potential pesticide contributions from the fields alongside the unnamed tributary have not been
collected so it is unknown if there are non-point sources of these COECs along the OU2
Waterway. Greater than 50% of most of the metals EPCs from the OU2 Waterway and the KIK
Culvert could be related to the OU1 Settling Ponds dataset.
For additional information please see the 2012 Baseline Ecological Risk Assessment Report -
Final Hegeler Zinc Superfund Site Operable Unit 2 Danville, IL, the 2019 Ecological Risk
Update Hegeler Zinc Superfund Site, Operable Unit 1 - technical memorandum for data
collected on KIK Property (OU2) (prepared by CH2M Hill) and 2021 Final Ecological Risk
Preliminary Remediation Goals for Hegeler Zinc Superfund Site, Operable Units 1 and 2,
Vermilion County, Illinois (prepared by CH2M Hill). (Search in your browser for Hegeler Zinc
Superfund Site, Danville, IL or
https://cumulis.epa. gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.scs&id=0508134&
doc=Y&colid=70252®ion=05&tvpe=SC ).
2.7.3 Basis for Action
The response action selected in this ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances into the
environment.
2.8 - Remedial Action Objectives
Remedial Action Objectives (RAOs) are goals for protecting human health and the environment.
RAOs are developed to address the contaminant levels and exposure pathways presenting
unacceptable current or potential future risk to human health and the environment. RAOs were
developed with consideration to the contaminant levels and exposure pathways found to present
potentially unacceptable risk to human health and environment as during the RI and SRI and
identified under the risk assessment section of this ROD.
Future industrial worker, trespasser, construction worker, offsite residential receptors
(groundwater only), and aquatic and terrestrial habitats are the human and ecological receptors
used to develop the Site RAOs. The media with unacceptable human and ecological risks include
the slag pile, sediment, soil, groundwater and surface water.
The following are the RAOs for the soil and sediment final remedy and the groundwater and
surface water interim remedy.
Slag and Soil
Protect trespassers and construction and industrial workers from direct contact, ingestion, and
inhalation of slag and soil with concentrations of COCs exceeding human health RGs (0 feet bgs
to the water table [approximately 5 to 10 feet bgs]).
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Reduce unacceptable risk to human and terrestrial receptors from surface soil (0 to 2 feet bgs)
with concentrations of COECs exceeding ecological RGs.
Minimize migration of COCs to groundwater from slag and soil that may cause the groundwater
to exceed the RGs.
Prevent migration of COCs from slag and soil to sediment and surface water that may result in
exceedance of sediment or surface water RGs.
Sediment
Protect trespassers and construction workers from direct contact, ingestion, and inhalation of
sediment (0 to 1 foot bgs) with concentrations of COCs exceeding human health RGs.
Protect aquatic ecological receptors from exposure to concentrations of COECs that exceed RGs
in sediment (0 to 0.5 feet bgs).
Reduce risk to acceptable levels (i.e., below the applicable RGs) in the benthic invertebrate
community due to exposure to sediment related COECs.
Reduce risk to acceptable levels (i.e., below the applicable RGs) to fish and wildlife receptors
due to exposure to sediment related COECs.
Reduce the potential downstream migration of sediment related COECs.
Prevent the migration of COCs from sediment to surface water.
Groundwater
Prevent human exposure to contaminated groundwater at the former smelter property and
adjacent areas.
Minimize the migration of COCs in groundwater to sediment or surface water above acceptable
levels.
Surface Water
Reduce migration of COCs and COECs to surface water that contribute to surface water PRG
exceedances.
Final and Interim Remedial Goals/Cleanup Levels
The cleanup levels or remedial goals (RGs) for the Site are the same as the preliminary remedial
goals (PRGs) developed in the OU1 and OU2 feasibility studies and presented in the Proposed
Plan. The RGs for the Site are based both on protective risk-based concentrations associated with
current and reasonably anticipated future land uses and a review of federal and state ARARs.
During the Remedial Design, these goals will also be used to define the extent of contaminated
media requiring remedial action. ARARs are provided in Table A-6, attached to this ROD. The
current and reasonably anticipated future land uses are anticipated to be commercial/industrial
for the former zinc smelter operations area. During the Remedial Design, these RGs are used to
define the extent of contaminated media requiring remedial action.
There are promulgated chemical-specific ARARs for groundwater and surface water that were
considered along with risk.
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Soil
Human Health Remedial Goals (RGs) for Soil
As displayed in Table 7 below, EPA is using the human health RG of 98 mg/kg for antimony and
33,000 mg/kg for zinc, which would apply to Exposure Area 3. EPA is also using a human health
RG of 800 mg/kg for lead in soil, which would apply to Exposure Areas 2, 3, and 4. All human
health RGs would be protective for either future industrial or construction workers. Because no
ELCR is applicable for antimony and zinc, RGs for these COCs would be selected based on
adjusted noncarcinogenic HI of 1. The lead human health RG is the industrial RSL.
Table 7 - Remedial Goals in Surface and Subsurface Soil
coc
Receptor
Exposure
Area
Target
Organ
HI = 1
(mg/kg)
Background
(mg/kg)
RG
(mg/kg)
Basis
Antimony
Construction
workers
Exposure
Area 3
142
3.3
98
HI = 0.7 for
construction
worker*
Zinc
Construction
workers
Exposure
Area 3
106,182
60.2
33,000
HI = 0.3 for
construction
worker*
Lead
Construction
workers
Exposure
Areas 2, 3,
800
Lead
and 4
20.9
800
Industrial
Lead
Industrial
workers
Exposure
Area 3
800
RSL
* RGs for antimony and zinc are adjusted for a total HI=1 for additive effects on the
hematological system.
Ecological Remedial Goals for Surface Soil
Table 8 below lists the ecological RGs for the six COECs (aluminum, antimony, lead, mercury,
vanadium, and zinc) in surface soil (0 to 2 feet bgs) and are based on the lowest conservative
ecological screening levels presented in the OU1 BERA. The RG for vanadium is the TACO
background level for counties outside metropolitan statistical areas in Illinois. No screening level
for aluminum is applicable; therefore, no numeric ecological RG is selected because aluminum is
not bioavailable (available for uptake) to ecological receptors under most natural pH conditions
(pH 5.5-8). Slag present in surface soil has resulted in acidic pH conditions (pH < 5.5) at some
sample locations; therefore, it is assumed that the risk from potentially bioavailable aluminum at
these locations will be addressed by addressing risk for the other slag-related metals. The
ecological RGs for soil apply to the Site including the adjacent KIK property.
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Table 8 - Ecological Remedial Goa
s in Surface Soil
COEC
Screening
Level
Terrestrial
Plant
(mg/kg)
Screening
Level Soil
Invertebrate
(mg/kg)
Background
(mg/kg)
RG
(mg/kg)
Basis
Aluminum
NA
NA
9,200
NA
Assuming risk will be
addressed by addressing
other metals (same
approach as OU3)
Antimony
5
78
3.3
5
Lowest screening level
Lead
120
1,700
20.9
120
Lowest screening level
Mercury
0.3
0.1
0.05
0.1
Lowest screening level
Vanadium
2.0
42
25
25
Background
Zinc
160
120
60.2
120
Lowest screening level
Surface Water and Sediment
Human Health Remedial Goals for Surface Water
OU1 surface water human health RG exceedances are limited to the settling ponds and the creek
(exposure area 2) located immediately adjacent to the settling ponds (see Table 9 below).
No unacceptable human health risks were identified by the HHRA for the current/future
recreational adolescent exposed to OU2 surface water, or the future industrial worker or the
future recreational adolescent exposed to KIK Culvert sediment and surface water. Therefore,
human health based RGs are not warranted for OU2.
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Table 9 - Human Health
Remedial Goals for OU1 Surface Water
coc
Receptor
Exposure Area
Target Organ
HI = l2
(Hg/L)
Illinois
General Use
Standards3
RG
(Mg/L)
Basis
Cadmium
Trespassers
Exposure Area 2
(Settling ponds
and creek)
31
NA
16
HI = 1 for
construction
worker
Cadmium
Construction
worker
Exposure Area 2
(Settling ponds
and creek)
16
Cadmium
Industrial
worker
Exposure Area 2
(Settling ponds
and creek)
135
Human Health Remedial Goals for Sediment
Cadmium was identified as a contaminant of concern for trespassers and construction workers
that would be exposed to OU1 creek sediment (see Table 10 below).
No unacceptable human health risks were identified by the HHRA for the current/future
recreational adolescent exposed to OU2 sediment, or the future industrial worker or the future
recreational adolescent exposed to KIK Culvert sediment and surface water. Therefore, human
health based RGs are not warranted for OU2.
Table 10 - Human
Tealth Remedial Goals for OU1 Sediment (0-1 ft bgs)
COC
Receptor
Exposure Area
Target
Organ
HI = l4
(mg/kg)
RG
(mg/kg)
Basis
Cadmium
Trespassers
Exposure Area 1
(creek)
270
83
HI = 1 for
Cadmium
Construction workers
Exposure Areas 1 & 2
(creek)
83
construction worker
2 Surface water RGs are based upon risks calculated in the 2019 OU1 HHRA. There were not cancer-based risks in
surface water at the Site, therefore developing RGs based on a Target ELCR is not appropriate.
3IAC Title 35, Subtitle C, Chapter I, Part 302, Illinois Water Quality Standards General Use - Subpart B, Section
302.208; Human Health Standards
4 Sediment RGs are based upon risks calculated in the 2019 OU 1 HHRA. There were not cancer based risks in
sediment at the Site, therefore developing RGs based on a Target ELCR is not appropriate.
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Developing a Common Set of Site-Specific Ecological RGs for Surface Water and Sediment
The Site was broken up into three OUs by the PRPs in 2009. During the FS process, a different
ecological RG for sediment was developed for OU1 (sediment on former smelter property) and
OU2 (KIK culvert and the creek outside the OU1 property). It is important to note that the
distinction between the portions of the creek (sediment, surface water, and aquatic habitat) were
administrative rather than ecological. Aquatic receptors within the creek are mobile and likely
use waters in both OUs. Additionally, because of the proximity of the two OUs, the same aquatic
receptors are anticipated to be present in both OUs. Due to the chemical and physical similarities
in the two OU data sets, EPA developed a common set of site-specific RGs for surface water and
sediment using the combined data set applicable to the creek (sediment and surface water)
documented in the January 15, 2021, Final Ecological Risk Preliminary Remedial Goals for the
Hegeler Zinc site Tech memorandum. Refer to sediment remediation area footprint in Figure 10.
Surface Water — Ecological Remedial Goals
The following surface water RGs were based on the chronic standard of Illinois General Use
Water Quality Standards (IAC Section 302.208 (e)) for Waters of the State for which there is no
specific designation (35 111. Adm. Code 303.201) and will be protective of aquatic life in the
waterways.
¦ Aluminum (dissolved) - 400 [j,g/L
¦ Cadmium (dissolved) - 1.4 [j,g/L
¦ Lead (dissolved) - 25 [j,g/L
¦ Manganese (dissolved) - 2,431 [j,g/L
¦ Zinc (dissolved) - 45 [j,g/L
Sediment — Ecological Remedial Goals
The common set of RGs for sediment were developed by refining the data set, identify relations
between chemical data and toxicity data, and performing concentration-response modeling.
Table A-7, attached to this ROD, compares the COECs and RGs in sediment developed in the
OU1 and OU2 feasibility studies. The analysis of the data sets determined that pesticides and
metals are co-mingled within the sediment. The co-occurring nature of the COECs in sediment,
allows for the application of a single RG to represent metals risk and another single RG for
pesticides risk. A list of RGs for sediment are listed in Table A-7.
Sediment RGs were based on site-specific sediment toxicity testing. The RGs developed will be
protective of the benthic invertebrate community against toxic effects from pesticides and
metals, as discussed in more detail in Section 5 of this ROD. The following RGs, based on the
EC 10, are for sediment:
¦ Total DDx (as the sum of 4,4'-DDT, 4,4'-DDD, 4,4'-DDE) - 0.96 milligrams per
kilogram
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¦ PECQtotai (as the sum of PECQcd, PECQcu, PECQzn) - 5.7 (unitless5)
Table 11 - Sediment Ecological RGs
Pesticides
Total DDx
0.96 mg/kg
Metals
PECQtotai
5.7 (unitless)
This suggests that the toxic effects from individual metals or pesticides may not fully separate
from one another since they co-occur.
Groundwater
Human Health Remedial Goals for Groundwater
For groundwater, RGs were established for the purpose of defining the extent of contaminated
groundwater to which the groundwater RAO would apply assuming the groundwater is Class I.
The list of 14 RGs for groundwater are listed in Table A-8, attached to this ROD. Since Illinois
EPA currently classifies the groundwater at the Site as an Illinois Class I potable resource
groundwater aquifer, the Illinois Class I standards were compared to the federal MCLs. In
general, the Illinois Class I standards were found to be either equal to or more stringent than the
MCLs. The more stringent of federal MCLs or Illinois Class I standards are RGs for the COCs in
groundwater. For aluminum, the RG is based on EPA RSL for residential tap water with an HI =
1, since neither MCL nor Illinois Class I groundwater standards are available. All of the
groundwater RGs in Table A-85, attached to this ROD, applies to exposure areas 1, 2, and 3;
only RGs for antimony, arsenic, cadmium, lead, and zinc apply to exposure area 4.
There are no COECs for groundwater, therefore, there are no ecological RGs for groundwater.
2.9 - Description of Alternatives
2.9.1 Common Elements of Alternatives
Remedial action alternatives are typically composed of a number of individual remedial action
components. This section describes the remedial action components that are common to the
Selected Remedy and the other remedial alternatives that were considered for the site (except for
the "no-action" alternative). However, the scale and cost of the components will be different for
each alternative. The purpose of presenting the components here as a group is to limit
redundancy in the subsequent discussion of the individual alternatives.
5 The PEC quotient represents a sample concentration divided by a benchmark concentration, and by definition, the
resulting quotient is unitless.
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These common components are listed below.
Predesign Investigations
¦ Additional sampling of OU1 media to delineate and refine excavation boundaries and
volumes of individual soil and sediment RG exceedance areas.
¦ Identification of Threatened and Endangered (T&E) species and migratory birds at or
near the Site.
¦ Evaluation of the presence of wetlands within OU1.
¦ Survey areas of OU1 with slag-dominated surface soils/lack of vegetation, to determine if
further remediation is warranted.
¦ Evaluate OU1 property boundaries and staging pile location.
¦ Review OU1 topographic survey data through light detection and ranging (LIDAR).
¦ Sampling in OU1 areas where soil metals data were less than human health RGs but
failed the TCLP for cadmium and/or lead.
¦ Establish current groundwater conditions to use as baseline to compare groundwater
conditions in the future.
¦ Private wells within an approximate 1-mile radius of the Site will be evaluated for
impacts from contaminated Site groundwater. Predesign groundwater sampling will
evaluate the current groundwater concentrations and determine if the private wells are
located upgradient or downgradient of the site.
¦ An OU2 baseline monitoring program will be conducted prior to the implementation of
the remedy including the collection of sediment chemistry samples, surface water
chemistry samples, sediment toxicity testing samples, and fish tissue samples. This
additional sampling will provide updated OU2 information that was collected between
2001 and 2016.
¦ Cultural Resources Survey of borrow areas once they are established.6
Pre-Constraction Activities
¦ Preparation of site-specific plans.
¦ Subcontractor submittals.
¦ Identifying substantive requirements of ARARs and non-environmental permitting (as
necessary).
¦ Community Involvement Plan/Public meetings.
6 See May 15, 2020 letter from SHPO in Appendix B of 2021 OU1 FS Report
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¦ Modeling may be required during the remedial design for the OU1 creek reconfiguration
to ensure 100 feet between the creek and slag pile consolidation area.
¦ Subcontractor mobilization and demobilization.
¦ Installation of temporary facilities.
Buildings and Kiln Demolition
¦ A site reconnaissance will be performed to identity the conditions, materials, number of
buildings requiring demolition, and estimate the volume of construction debris to be
disposed of.
¦ The volume of asbestos-containing material (ACM) on-site will be determined during a
site survey prior to building demolition.
¦ For cost-estimating purposes, it is assumed that wood and metal demolition debris would
be characterized as nonhazardous waste or Universal Waste and sent off-site for recycling
or disposal. ACM will also be sent off-site for disposal. Demolition debris such as brick
and concrete would be consolidated and covered with the slag pile.7
Creek Rerouting
¦ A portion of the OU1 creek may be rerouted to the north to create a 100-foot buffer
between the creek and the slag pile consolidation area.
¦ Create a temporary diversion for the creek to allow for sediment removal and rerouting.
¦ Excavate a new creek channel with an assumed depth of 7 feet (assume collection of
confirmation samples from base and side slopes of new channel). The assumed depth of
the creek channel excavation was based on a review of aerial imagery and topographic
data of the site. Modeling would be required during the remedial design for the creek
reconfiguration.
Slag Pile Relocation
¦ To maintain a 100-foot buffer from the creek, slag located within 100 feet of the south
branch of the creek will be excavated and relocated to another area of the slag pile (4,625
cubic yards [cy]). The remainder of the slag pile outside the 100-foot buffer from the
south branch of the creek is assumed to remain in the current location. During excavation,
this area of the slag pile would be sloped to an assumed 3 horizontal to 1 vertical and
stabilized.
7 Page 3-14 of 2021 OU1 FS Report
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Excavation and Consolidation
¦ 0U1 excavated materials (slag, soil and sediment) will be consolidated on-site with the
slag pile.
¦ Excavate OU3 residential soil pile and consolidate with slag pile (9,500 CY includes 2
feet of soil below the pile), see Figure 5.
¦ Remove OU1 sediment exceeding ecological RGs in the creek (525 CY), fire water pond
(1,140 CY), and settling ponds (1,551 CY) via dredging or excavation.
o For cost-estimating purposes, it is assumed the creeks and settling ponds would be
excavated, and the fire water pond would be hydraulically dredged. For cost-
estimating purposes, it was assumed 0.5 foot of sediment would be removed;
however, additional sediment sampling would be conducted as a part of the
predesign investigation to further delineate sediment impacts above RGs and meet
the sediment RAO. Sufficient sampling would be completed to ensure the top 0.5
feet of sediment remaining in the creek post-remedy was less than the ecological
RGs.
¦ Operate a water treatment system for the duration of dredging the fire water pond and 1
month after completion of dredging to treat weep water.
¦ Excavate OU1 sediment exceeding human health RGs in the OU1 creek (276 CY).
o For cost-estimating purposes, it is assumed 1 foot of sediment would be removed;
however, additional sediment sampling will be conducted as a part of the
predesign investigation to further delineate sediment impacts above RGs and meet
the sediment RAO. Sufficient sampling would be completed to ensure the top foot
of sediment remaining in the creek post-remedy is less than the human health
RGs.
¦ Removed OU1 sediment would be dewatered and consolidated with the slag pile.
¦ Collect and verify OU1 soil and sediment confirmation samples to verify that OU1 soil
and sediment contamination exceeding the RGs has been removed.
¦ Excavated soil and sediment that exceeds the toxicity characteristic leaching procedure
(TCLP) criteria will be disposed of off-site.
¦ Covering subsurface soil with 24 inches of compacted clay and 6 inches of topsoil where
soil exceeding human health RGs is left in place. While not triggered by an ARAR,
subsurface soil with concentrations of COCs below human health RGs would be covered
with 18 inches of compacted clay and 6 inches of topsoil to match original grade. Soil
would be graded for positive stormwater runoff and minimize ponding. For cost-
estimating purposes, areas with no subsurface soil concentrations above human health
RGs will be backfilled to match surrounding grade. This may be revised during the
remedial design with an evaluation of site grading and potential site reuse.
¦ Excavation of OU2 sediment exceeding Ecological RGs in the KIK Culvert and the OU2
creek (4,016 cy) and off-site disposal. Off- site disposal of OU2 sediment may be revised
during remedial design resulting in some or all of OU2 sediment being consolidated with
the slag pile.
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o The entire length and width of stream will be excavated. This includes sediment
extending from the base of one bank to the base of the opposing bank and will
include areas that are not necessarily covered with water during normal base flow
conditions but may be covered with water under flooding conditions.
o Excavation will be conducted to hardpan (the native material beneath soft
sediment), which is generally composed of till. Bedrock is potentially exposed
within the channel at a few locations. The average channel base width along the
creek and KIK Culvert is approximately 13 feet and the average sediment
thickness is approximately 1.5 feet.
o Turbidity controls (e.g., cofferdams) will be used to minimize resuspension and
downstream transport of sediment during excavation. The excavation will occur
in sections, which will be defined by cofferdams located at the up and
downstream side of the excavation area. Streamflow on the upstream side of the
excavation area will be rerouted to the downstream side of the excavation area,
and water within the excavation area water will be routed to a water treatment
area and treated before being discharged to a POTW.
o Mechanical removal (e.g., with a backhoe or clam shell bucket) with stabilization
of sediment will be conducted in a staging area by gravity de-watering and mixing
sediment with Portland cement at a rate of 5 percent of the total volume of
excavated sediment. If transported off-site, the dewatered sediment will be
transported to a licensed Subtitle D off-site disposal facility by trucks over local
streets, requiring a comprehensive health and safety plan, roadway permits, access
agreements, and haul-out decontamination procedures. The stream will be
restored through natural processes and no habitat restoration is included in this
alternative. A thin layer of sand may also be added to the channel bottom post-
excavation to reduce residual concentrations.
o Air monitoring and dust control measures may also be required for fugitive dust
resulting from the open-air exposure of sediments during removal and dewatering
activities.
o No long-term operations and maintenance are anticipated for OU2 sediment. Post-
removal confirmation surface sediment and surface water sampling may be
conducted at the baseline sampling locations two years post-remediation to assess
the presence of residual contamination resulting from the resettling of the
suspended sediment. In addition, long-term monitoring of sediment chemistry,
surface water chemistry, sediment toxicity testing, and fish tissue may also be
conducted to monitor the performance of the remedy. Two sampling events have
been assumed for costing purposes. The scope and duration of the long-term
monitoring program will be established in consultation with U.S.EPA and Illinois
EPA. s
8 2021 OU2 FS Alternative 3, Section 3.2.3.
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Covering of Slag Pile Consolidation Area
¦ A low-permeability soil cover will be installed over the slag pile consolidation area to
prevent infiltration and provide a direct-contact barrier for potential human and
ecological receptors. The slag pile consolidation area cover would have a minimum
separation distance of 100 feet from the creek. For cost estimating purposes, it is
assumed that the cover would include a 24-inch compacted clay (barrier) layer, a 6-
inch topsoil (erosion) layer, and vegetative cover. Alternatively, a multilayer cover
composed of a 12-inch base layer of compacted clay, a geosynthetic clay liner, 60-mil
high-density polyethylene geomembrane, a 6-inch common fill layer, and a 6-inch
topsoil layer with a vegetative cover can be considered as equivalent protection. The
cover would be crowned and graded to promote stormwater runoff with perimeter
drainage swales to collect and distribute stormwater to the existing creek. The
following assumptions were used for the slag pile consolidation area remedy:
o No bottom liner is necessary because of the presence of clay underneath the
source materials. Recent groundwater data indicates minimal migration of
potentially site-related metals into the Lower Zone 1 portion of the aquifer.
Additionally, based upon hydraulic data the metals detected in Zone 2
monitoring wells do not appear to be associated with contamination from the
Site.
o Cover slope estimated: 4 to 6 percent. This slope would be sufficient to
maintain positive drainage and minimize erosion potential.
o The sides of the existing slag pile would be sloped to an assumed 3 horizontal
to 1 vertical and stabilized, but this will be further evaluated during remedial
design.
o The perimeter drainage swales would be designed to manage runoff during the
peak discharge of a 25-year, 24-hour storm event.
o Temporary stormwater retention ponds would be included as necessary during
the construction phase for settlement of fugitive particles and energy
dissipation during a 2-year, 24-hour storm event. The existing settling ponds
may be used as stormwater retention ponds.
o Perimeter site access roads would be constructed to facilitate O&M equipment
(for example, mowers, small earth-moving or regrading equipment, etc.).
o The cost estimate includes mowing four times per year and 6 events each for
reseeding and erosion repairs for the consolidation area cap.9
Restoration
¦ Areas with constructed covers, and most disturbed areas, would be hydroseeded with
native plants to establish vegetative cover and reduce potential erosion. Wetlands
9 Alternative 3 Cost Estimate in Appendix D of the 2021 OU1 FS Report.
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restoration would be conducted if required, as approximately 0.3 acre of wetland are
identified on-site. No restoration is assumed in the settling ponds or fire water pond.
Groundwater, Surface Water, Sediment, Fish Tissue and Long-Term Monitoring (LTM)
¦ Under current conditions, minor impacts to surface water were identified based on
marginal surface water RG exceedances. By consolidating contaminated soil, covering
the slag pile consolidation area, and removing sediment from the creek, settling ponds,
and fire water pond, it is expected that the surface water RGs will be met. The remedial
alternatives for groundwater and surface water are considered to be interim remedies.
Groundwater and surface water quality improvement and the ability to meet the chemical
specific ARARs will be evaluated by LTM plan and EPA five-year reviews.
¦ For purposes of the cost estimate, it was estimated that up to 20 wells would be
monitored for groundwater COCs quarterly during the first 2 years, annually from years 3
to 5, and once every 5 years as a part of five-year reviews. Baseline and LTM
groundwater sample results will be used to determine if source controls implemented
during the soil and sediment remedial action are resulting in decreasing groundwater
concentrations for COCs. Surface water samples would also be collected for surface
water COCs and COECs. Surface water sampling would be completed at the same
frequency and concurrently with the groundwater sampling. Specific groundwater and
surface water sampling locations would be determined during development of the LTM
monitoring plan. The LTM frequency may also be further refined during preparation of
the LTM monitoring plan. Figure 11 shows the groundwater and surface water RG
exceedance areas.
¦ Sediment and fish tissue samples will be collected as part of the LTM plan to confirm the
sediment is not being re-contaminated due to runoff or other deposition or presenting
unacceptable risk to aquatic receptors. The frequency of sample collection will be
determined during development of the LTM plan.
Institutional Controls
¦ A Groundwater Management Zone (GMZ) would be established by the Illinois EPA
where groundwater exceeds applicable water quality criteria. An environmental covenant
will prohibit the installation of wells unless associated with investigation or remediation
and require a Groundwater Management Plan for any excavation that may expose
groundwater. A groundwater IC would be in place to restrict groundwater use. The
boundary of the groundwater IC would be surveyed with a metes-and-bounds description
and survey plate.
¦ A soil IC also would be in place to address the slag pile consolidation area and areas with
surface or subsurface soils above human health RGs. The ICs would be filed at the
county deed records office. Figure 12 shows estimated soil IC control areas.
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¦ Property restrictions across OU1 are also needed to prohibit future residential and
recreational land use because the residential and recreational receptors were not evaluated
during the HHRAs. In addition, commercial uses were not evaluated in the HHRAs. The
typical exposure scenarios for commercial land use are similar to industrial, but
depending on the specific commercial use, there may be children present occasionally or
often (e.g., if used as a daycare center or restaurant). Therefore, property restrictions
across OU1 are needed to prohibit future commercial use as a daycare center. These
restrictions will be filed at the county deed records office.
Five-Year Reviews
¦ The NCP, 40 CFR 300.430(f)(4)(ii), requires that periodic reviews be conducted 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 (UU/UE). These reviews are conducted no less often than every 5
years after the selected remedial action is initiated. The Five-Year Review will evaluate
groundwater and surface water quality improvement and will evaluate the ability of the
remedy to meet the respective RGs and comply with the corresponding chemical-specific
ARARs within a reasonable period of time.
2.9.2 Description of Alternatives
EPA developed a range of remedial alternatives to address potential risks at the Site. A summary
of proposed remedial alternatives is provided in Table A-9, attached to this ROD. EPA was
required to evaluate "No Action" as the basis of comparison for the other alternatives. All the
other alternatives included "active" measures to remediate the Site. It is important to note that
removal of sediment exceeding ecological and human health RGs, the sediment remediation
footprint noted on Figure 10, is a common element in each of the "active" remedial alternatives
(Alternatives 2 through 5). In addition, the groundwater and surface water interim remedies, and
a covering installed over the slag pile consolidation area is a common element for all "active"
remedial alternatives. Details of the slag pile consolidation area varies by alternative, therefore
would be further developed in the remedial design phase. The remedial alternatives present a
range of cleanup alternatives developed for soil to achieve the RAOs.
The groundwater and surface water interim remedies would protect human health and the
environment in the short term through the implementation of ICs to restrict groundwater and
former settling ponds' surface water use. Groundwater and surface water monitoring would be
conducted following implementation of the source control measures provided by the other
alternatives, to evaluate the impact of those source control measures on groundwater and surface
water concentrations over time.
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Alternative 1: No Action
Regulations governing the Superfund program require that the "No Action" alternative be
evaluated to establish a baseline for comparison. Under this alternative, EPA would take no
action at the Site to prevent exposure to the contamination. The "No Action" alternative would
leave affected soil, sediment, surface water, and groundwater contamination. The potential for
human and ecological receptors to be exposed to COCs and COECs would not be addressed.
Estimated Capital Cost: $0
Estimated Annual O&M Cost: $0
Estimated Present Worth: $0
Estimated Soil Excavation: 0 cy
Remedial Action Construction Timeframe: None
Alternative 2: Cover of Surface Soil above Human Health RGs; Excavation of Surface Soil
above Ecological RGs (0.5 ft bgs) outside the Human Health excavation footprint.
In addition to the common elements described in Section 2.9.1, the unique components of
Alternative 2 are listed below. The boundaries of the sediment and soil remediation areas are
displayed on Figure 13 along with the estimated footprint of the slag pile consolation area.
¦ Covering surface soil areas with concentrations of COCs exceeding human health RGs.
These areas would be covered with 24 inches of compacted clay and 6 inches of topsoil.
Soil would be graded for positive stormwater runoff and to minimize ponding.
¦ Excavating the surface soil with detected concentrations of COECs exceeding ecological
RGs and limited vegetation to 0.5 foot bgs. These areas would be backfilled with 6 inches
of topsoil to match original grade.
¦ Maintain the existing clean soil cover (minimum 2 feet) over the subsurface soil human
health RG exceedances.
Estimated Capital Cost: $23.4 Million
Estimated Annual O&M Cost: $1.5 Million
Estimated Present Worth Cost: $25.3 Million
Estimated Soil Excavation: 29,027 cy
Estimated Remedial Action Construction Timeframe: 2 years
Alternative 3: Excavation of Surface Soil above Human Health RGs (up to 2 feet bgs),
Excavation of Surface Soil above Ecological RGs (0.5 foot bgs) outside of the Human Health
RG excavation footprint (EPA '.s Selected Remedy).
In addition to the common elements described in Section 2.9.1, the unique components of
Alternative 3, the Selected Remedy, are listed below. The boundaries of the sediment and soil
remediation areas are displayed on Figure 14 along with the estimated footprint of the slag pile
consolidation area.
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¦ Excavating 0U1 surface soil with detected concentrations of COCs exceeding human
health RGs to 2 feet bgs (49,046 cy). Covering subsurface soil with 24 inches of
compacted clay and 6 inches of topsoil where soil exceeding human health RGs is left in
place. While not triggered by an ARAR, subsurface soil with concentrations of COCs
below human health RGs would be covered with 18 inches of compacted clay and 6
inches of topsoil to match original grade. Soil would be graded for positive stormwater
runoff and minimize ponding.
¦ Excavating OU1 surface soil with detected concentrations of COECs exceeding
ecological RGs and limited vegetation to 0.5 foot bgs (29,072 cy). These areas would be
backfilled with 6 inches of topsoil to match original grade.
¦ Consolidating all excavated soils with the slag pile.
Estimated Capital Cost: $27.3 Million
Estimated Annual O&M Cost: $1.6 Million
Estimated Present Worth Cost: $29.3 Million
Estimated Soil Excavation: 78,118 cy
Estimated Remedial Action Construction Timeframe: 3 years
Alternative 4: Excavation of Surface Soil above both Human Health and Ecological RGs (up
to 2 feet bgs).
In addition to the common elements described in Section 2.9.1, the unique components of
Alternative 4 are listed below. The boundaries of the sediment and soil remediation areas are
displayed on Figure 15 along with the estimated footprint of the slag pile consolidation area.
Excavating the surface soil with detected concentrations of COCs exceeding human health RGs
and COECs exceeding ecological RGs to 2 feet bgs (351,857 cy). These areas would be
backfilled with topsoil to match original grade.
Covering subsurface soil with detected concentrations of COCs exceeding human health RGs
with 24 inches of compacted clay and 6 inches of topsoil. Subsurface soil with concentrations of
COCs below human health RGs would be covered with 18 inches of compacted clay and 6
inches of topsoil to match original grade. Excavated areas with concentrations less than human
health RGs will be backfilled to original grade. Soil would be graded for positive stormwater
runoff and minimize ponding.
Estimated Capital Cost: $66.1 Million
Estimated Annual O&M Cost: $6.8 Million
Estimated Present Worth Cost: $72.4 Million
Estimated Soil Excavation: 351,857 cy
Estimated Remedial Action Construction Timeframe: 5 years
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Alternative 5 — Excavation of Surface Soil above Ecological RGs (up to 2 feet bgs);
Excavation of Soil above Human Health RGs inside the Ecological footprint below 2 feet to 10
feet bgs).
In addition to the common elements described in Section 2.9.1, the unique components of
Alternative 5 are listed below. The boundaries of the sediment and soil remediation areas are
displayed on Figure 16 along with the estimated footprint of the slag pile consolidation area.
Excavating the surface soil with detected concentrations of COCs exceeding human health RGs
to 10 feet bgs or to the water table and COECs exceeding ecological RGs to 2 feet bgs (351,857
cy).
Excavating the subsurface soil with detected concentrations of COCs exceeding human health
RGs to 10 feet bgs (73,651 cy), or to the water table, from the former industrial areas. For deeper
excavation (greater than 5 feet bgs), it is assumed that excavation would occur with a side slope
of 2 horizontal to 1 vertical (or approved alternative method).
Excavation areas would be backfilled with clay in 6-inch compacted lifts to 6 inches below
surrounding grade. Topsoil would be placed in the upper 6 inches.
Estimated Capital Cost: $72 Million
Estimated Annual O&M Cost: $2.1 Million
Estimated Present Worth Cost: $74.4 Million
Estimated Soil Excavation: 425,508 cy
Estimated Remedial Action Construction Timeframe: 5 years
2.10 - Summary of Comparative Analysis of Alternatives
Section 121(b)(1) of CERCLA presents several factors that EPA is required to consider in its
assessment of alternatives. Building upon these specific statutory mandates, the NCP articulates
nine evaluation criteria to be used in assessing the individual remedial alternatives. The purpose
of this evaluation is to promote consistent identification of the relative advantages and
disadvantages of each alternative, thereby guiding selection of remedies offering the most
effective and efficient means of achieving site cleanup goals. While all nine criteria are
important, they are weighed differently in the decision-making process depending on whether
they evaluate protection of human health and the environment or compliance with federal and
state ARARs (threshold criteria); consider technical or economic merits (primary balancing
criteria); or involve the evaluation of non-EPA reviewers that may influence an EPA decision
(modifying criteria). These nine criteria are described below. A chart comparing cleanup options
with the Nine Superfund Remedy Selection Criteria is presented in Table A-10.
Explanation of the Nine Evaluation Criteria
Threshold Criteria
1. Overall Protection of Human Health and the Environment addresses whether a
remedy provides adequate protection of human health and the environment and describes
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how risks posed by the site are eliminated, reduced, or controlled through treatment,
engineering, or institutional controls. This criterion also incorporates an evaluation of
climate resilience.
2. Compliance with Applicable or Relevant and Appropriate Requirements
addresses whether a remedy will meet the applicable or relevant and
appropriate federal and state requirements, known as ARARs.
Primary Balancing Criteria
3. Long-Term Effectiveness and Permanence refers to expected residual risk and the
ability of a remedy to maintain reliable protection of human health and the environment
over time, once cleanup levels have been met.
4. Reduction of Toxicity, Mobility or Volume Through Treatment addresses the
statutory preference for selecting remedial actions that employ treatment technologies
that permanently and significantly reduce toxicity, mobility, or volume of the hazardous
substances as their principal element. This preference is satisfied when treatment is used
to reduce the principal threats at the site through destruction of toxic contaminants,
reduction of the total mass of toxic contaminants, irreversible reduction in contaminant
mobility, or reduction of total volume of contaminated media.
5. Short-Term Effectiveness addresses the period of time needed to implement the remedy
and any adverse impacts that may be posed to workers, the community and the
environment during construction of the remedy until cleanup levels are achieved. This
criterion also considers the effectiveness of mitigative measures and time until protection
is achieved through attainment of the RAOs.
6. Implementability addresses the technical and administrative feasibility of a remedy from
design through construction, including the availability of services and materials needed to
implement a particular option and coordination with other governmental entities.
7. Cost includes estimated capital costs, annual O&M costs and total present worth of
capital and O&M costs, including long-term monitoring. The total present worth cost is
calculated using a discount rate that takes into account the time value of money.
Modifying Criteria
8. State Agency Acceptance This criterion considers the state's position and key concerns
about the preferred alternatives and other alternatives identified in the Proposed Plan.
9. Community Acceptance This criterion considers the community's support of,
reservations about, or opposition to the Selected Remedy and other alternatives identified
in the Proposed Plan.
Based on the comments received during the public comment period, the community generally
expressed support for the selected remedy for the Site. EPA's response to the public comments is
included later in this ROD, in Part III - Responsiveness Summary.
Threshold Criteria
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2.10.1 Overall Protection of Human Health and the Environment
EPA is required to select remedies that will protect human health and the environment.
Alternative 1, No Action, would not provide improvement over current conditions, would not
provide risk reduction, and would not be protective of human health or the environment. Thus, it
is not eligible to be selected and therefore is not discussed further in this ROD.
For all remaining alternatives, all the RAOs for soil, slag and sediment would be achieved
immediately upon completion of the construction work, and the RAOs for groundwater and
surface water would be achieved upon successful implementation of groundwater ICs.
Alternatives 2, 3, 4, and 5 would be protective of aquatic ecological receptors with the
excavation of sediment in the sediment remediation footprint area. These alternatives include a
GMZ and ICs, which would prevent ingestion of contaminated groundwater.
Alternatives 2, 3, 4, and 5 would be protective of human health by preventing direct contact,
inhalation, and ingestion of slag and soil exceeding human health RGs through consolidation
backfilling with compacted clay and topsoil. The thickness of clay will vary by alternative and is
dependent upon whether subsurface soils are present at concentrations above human health RGs.
The low-permeability cover over soil exceeding human health RGs reduces infiltration of
precipitation through contaminated media, thereby reducing contaminant migration to
groundwater and subsequent discharge to surface water.
Although Alternatives 2 and 3 physically remove concentrations of COECs in surface soil with
concentrations greater than ecological RGs in the top 0.5 foot, the remedy would result in
substantial reductions in surface soil COECs concentrations and backfill of excavated areas.
Alternative 4 and 5 would be protective of terrestrial receptors by preventing direct contact with
surface soils above human health and ecological RGs through more extensive excavation. The
migration and monitoring of Site related COCs is not anticipated to be impacted by any varying
climatological factor(s), and, thus, Alternative 2 through Alternative 5 are resilient to climate
change.
2.10.2 Compliance with Applicable or Relevant and Appropriate Requirements
This criterion assesses whether each alternative complies with federal and state regulatory
requirements that are either applicable or relevant and appropriate, known as ARARs. Federal
regulatory requirements are selected as ARARs unless an applicable state requirement is more
stringent than its associated federal requirement. In addition to ARARs, EPA can also consider
other "to-be-considered" (TBC) non-promulgated advisories or guidance issued by the state or
federal government, when determining the necessary level of cleanup for protection of human
health and the environment.
The primary ARARs for the alternatives under consideration are state and federal regulations
relating to hazardous waste identification, management, and disposal as well as state regulations
regarding groundwater quality and institutional controls. Alternatives 2, 3, 4, and 5 would meet
all federal and state ARARs.
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Key action specific ARARs and TBCs include the following: Resource Conservation and
Recovery Act (RCRA) Hazardous Waste Management Regulations (40 CFR Parts 260-262),
General Use Water Quality Standards (35 IAC Part 302), General Effluent Standards (35 IAC
Part 34), Emission Control Methods (40 CFR Section 61.150(a)(l)(i)-(v)), and Landfill Closure
Performance Standards (40 CFR Section 264.11 l(a)-(c)).
Alternatives 2 through 5 include an interim groundwater and surface water remedies consisting
of monitoring and ICs to prevent exposure to contaminated groundwater and surface water.
MCLs and/or Illinois Class I groundwater standards have been identified as potential ARARs for
the groundwater COCs. However, interim remedies under CERCLA are not required to comply
with ARARs as long as the final remedy will achieve them. The interim remedy for groundwater
is not expected to achieve the MCLs and/or Illinois Class I groundwater standards. The final
groundwater remedy, when selected in the future, is expected to comply with the substantive
requirements of the federal and state regulations that are applicable or relevant and appropriate to
the final selected remedial action.
Balancing Criteria
2.10.3 Long-term Effectiveness and Permanence
Alternatives 2 through 5 will all require long-term O&M and ICs to maintain the integrity of all
covered areas. Since ICs are only required on the slag pile consolidation area and the soils
beneath paved areas on the adjacent property in Alternative 5, this alternative has the greatest
long-term effectiveness and permanence and most flexibility for potential redevelopment of
areas of the site. Future residential land use, recreational land use, and commercial land use as a
daycare at the Site would be prohibited in Alternatives 2 through 5.
2.10.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Alternatives 2 through 5, reduce the mobility of the COCs and COECs through containment
under a low-permeability cover. The contaminants at the Site are most prone to migration when
exposed to erosion or infiltration of water through slag. As a result, the isolation of process
materials and soil in place through consolidation beneath an engineered cover is expected to
effectively address the mobility of contaminants. None of the alternatives contain a treatment
component to reduce toxicity, mobility, or volume because the large volume of relatively low-
level metal-contaminated soil at the Site does not lend itself to any cost-effective treatment.
2.10.5 Short-term Effectiveness
Alternative 2 would pose the lowest short-term risk to the community since it has the shortest
construction duration at 2.5 years and smallest imported borrow material quantities for the
construction of the cover. Alternative 3, the Selected Remedy, has similar short-term
effectiveness with an increased construction duration of 3 years. In addition, traffic impacts
under the Selected Remedy are similar to Alternative 2, although potential dust generation is
increased due to the excavation of surface soils.
Alternatives 4 and 5 would pose the highest short-term risk to the community due the increased
construction durations of 5 years and material-handling quantities, which would result in
significant traffic impacts to the surrounding community. However, the short-term risk
associated with Alternative 5 is slightly higher than Alternative 4 because the excavation
Hegeler Zinc ROD Page 53
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quantities are greatest and this increased excavation volumes would potentially result in
additional noise, increase traffic, and potential dust-borne releases.
Overall, Alternatives 2 and 3 present the lowest degree of short-term risk to the construction
workers and the surrounding community from dust, noise, and traffic due to shorter construction
duration. Therefore, Alternatives 2 and 3 have greatest degree of short-term effectiveness.
2.10.6 Implementability
Alternatives 2 through 5 are implementable using similar technologies and readily available
standard construction equipment. The technologies incorporated into these alternatives are
proven remedial options and have been implemented successfully on environmental cleanup
projects throughout the county. However, due to the increased quantities of required backfill
materials in Alternatives 4 and 5, borrow sources may be located farther from the Site in order to
obtain sufficient quantities. In addition, Alternative 5 would require the excavation of an
additional 73,651 cy of soil compared to Alternative 4 and an additional 347,390 cy of soil
comparted to Alternative 3, the Selected Remedy.
2.10.7 Cost
This criterion evaluates the capital and annual O&M costs of each alternative and uses the
estimated total present value costs of each to compare costs among alternatives with different
implementation times. A summary of the estimated cost of each alternative is shown in
Table A-l 1, attached to this ROD.
Alternative 2 is the least expensive action remedial alternative. Alternative 3, the Selected
Remedy, is slightly higher because surface soils would be excavated and consolidated on-site.
Alternatives 4 and 5 are the most expensive alternatives with each alternative increasing in cost
within the same order of magnitude and are the most expensive alternatives. Both Alternative 4
and Alternative 5 would excavate surface and subsurface soil. Alternative 5, the highest cost
alternative, would excavate the highest quantity of soil.
The final cost estimates for the Selected Remedy will be developed and refined during the
remedial design process.
Modifying Criteria
2.10.8 State/Support Agency Acceptance
This criterion considers the state's position and key concerns about Alternative 3, the Selected
Remedy, and other alternatives identified in the Proposed Plan.
As the state support agency, the Illinois EPA supports the selection of Alternative 3 for OU1 and
OU2 of the Site and has stated its intent to concur with the Selected Remedy. EPA will update
the administrative record upon receipt of a formal concurrence letter from the Illinois EPA.
2.10.9 Community Acceptance
This criterion considers the community's support of, reservations about, or opposition to
Alternative 3 and other alternatives identified in the Proposed Plan.
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Based on the comments received during the public comment period, the community generally
expressed support for Alternative 3 as the Selected Remedy for the Site. EPA's response to the
public comments is included later in this ROD, in Part III Responsiveness Summary.
2.11 - Principal Threat Waste
The NCP establishes an expectation that EPA will use treatment to address the principal threats
posed by a site wherever practicable (NCP Section 300.430(a)(l)(iii)(A)). The "principal threat"
concept is applied to the characterization of "source material" at a Superfund site. Source
material includes or contains hazardous substances, pollutants or contaminants that act as a
reservoir for migration of contaminants to ground water, surface water or air, or acts as a source
for direct exposure. EPA has defined principal threat wastes as those source materials considered
to be highly toxic or highly mobile that generally cannot be reliably contained or would present a
significant risk to human health or the environment should exposure occur. Low-level threat
wastes are those source materials that generally can be reliably contained and would present only
a low risk in the event of release. Low-level threat wastes include source materials that exhibit
low toxicity, low mobility in the environment, or are near health-based levels.
EPA has not identified any principal threat wastes at the Hegeler Zinc Site. Although some of the
waste materials at the Site exceed TCLP levels and are therefore considered characteristically
hazardous, the waste materials at the Site have impacted groundwater only at low levels, and
groundwater contamination appears to be limited to the former smelter property. Currently, none
of the contaminated process wastes at the former smelter property are contained or covered. As
the impact to groundwater is low, even under these uncontrolled conditions, EPA believes that
the wastes can be reliably contained.
2.12 - Selected Remedy
This section describes EPA's Selected Remedy and explains the rationale for that preference.
EPA's Selected Remedy is Alternative 3: Excavation of Surface Soil above Human Health RGs
(up to 2 feet bgs); Excavation of Surface Soil above Ecological RGs (0.5 foot) outside of the
Human Health RG excavation footprint.
Based on the evaluation of the various remedial alternatives summarized in Section 2.10,
Summary of Comparative Analysis of Alternatives, EPA believes that Alternative 3 is the most
appropriate cleanup alternative for the Site.
2.12.1 Summary of Rationale for the Selected Remedy
Based on the information currently available, EPA believes that the Selected Remedy meets the
threshold criteria and provides the best balance of tradeoffs among the alternatives with respect
to the balancing and modifying criteria. The interim surface water and groundwater remedy is
not required to meet ARARs so long as the final groundwater/surface water remedy will meet
ARARs. EPA expects the selected remedy to satisfy the following statutory requirements of
CERCLA § 121(b): (1) be protective of human health and the environment; (2) comply with
Hegeler Zinc ROD Page 55
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ARARs (or justify a waiver); (3) be cost-effective; (4) utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable; and
(5) the preference for treatment as a principal element or explain why the preference for
treatment will not be met.
The selected remedy will provide long-term and permanent protection again exposure to Site-
related contaminants by the combination of soil and sediment excavation, containment, and
cover, coupled with appropriate ICs. The selected remedy does not incorporate the preference for
treatment as a principal element because the large volume of relatively low-level metals-
contaminated soils at the Site do not lend itself to any cost-effective treatment. EPA has not
identified any principal threat wastes at the Site.
2.12.2 Summary of Selected Remedy
The details of Selected Remedy are in Section 2.9 and displayed on Figure 14.
The major components of the Selected Remedy, Alternative 3, for OU1 and OU2 of the Hegel er
Zinc Site are as follows:
¦ Pre-design investigations and pre-construction activities.
¦ Demolish remnants of existing buildings and the kiln and consolidate brick and concrete
with slag pile and dispose of rest of debris off-Site;
¦ Reroute a small portion of the unnamed tributary to Grape Creek (creek) on OU1 to
create a 100-foot buffer between the creek and the slag pile;
¦ Excavate and relocate a small portion of the slag pile to create a 100-foot buffer between
the south creek and the slag pile consolidation area;
¦ Excavate OU3 residential soil pile (9,500 CY includes 2 feet of soil below the pile) and
consolidate with the slag pile.
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¦ Excavate sediment and soil based on table below:
Media
l-\ca\ alion
Depth
Quantity
l-stimated to he
Rcmo\ ed
IJacklill Co\ cr
Disposal
OU1 Sediment
exceeding ECO
RGs
0.5 foot
525 CY
None. This may
be revised
during remedial
design.
Consolidate with
slag pile.
OU1 Sediment
exceeding HH
RGs
1.0 foot
276 CY
None. This may
be revised
during remedial
design.
Consolidate with
slag pile.
OU2 Sediment
exceeding Eco
RGs
0.5 foot
4,016 cy
None. This may
be revised
during remedial
design (RD).
Off-site
disposal. Off-
site disposal of
OU2 sediment
may be revised
during remedial
design resulting
in some or all of
OU2 sediment
being
consolidated
with the slag
pile.
OU1 Soil
Exceeding Eco
RGs
0.5 foot
29,072 cy
Backfill with
topsoil. May be
modified during
RD.
Consolidate with
slag pile.
OU1 Soil
Exceeding HH
RGs
2 feet
49,046 cy
Cover with clay
and topsoil.
Consolidate with
slag pile.
¦ Cover slag pile consolidation area with a low-permeability soil cover to prevent
infiltration and provide a direct-contact barrier for potential human and ecological
receptors.
¦ Restore disturbed areas with hydroseeding and restore wetlands if required.
¦ Monitoring of groundwater and surface water and sediment and fish tissue.
¦ Implement institutional controls for all areas where contamination remains above human
health or ecological risk levels or which contain remedy components.
¦ Review remedy every five years
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2.12.3 Summary of Estimated Remedy Costs
The time to complete construction would be approximately 3 years, at an estimated total present
worth cost of $27.3 Million. A detailed cost estimate for the Selected Remedy is included in
Table A-l 1. The information in the cost estimates is based on the best available information
regarding the anticipated scope of the remedial alternatives. This is an order-of-magnitude
engineering cost estimate that is expected to be within +50 to -30 percent of the actual project
cost. Changes in the cost elements are likely to occur as a result of new information and data
collected during the engineering design and remedy implementation. Changes outside of the +50
to -30 percent range in the remedial action cost may be documented in the form of a
memorandum in the Administrative Record file, an Explanation of Significant Differences, or a
ROD amendment.
2.12.4 Expected Outcomes of Selected Remedy
The primary objectives for the Selected Remedy are to reduce the potential for direct exposure to
process residues and contaminated soils, prevent COCs from being transported from process
residues to other areas or media via storm water run-off, and prevent infiltration of process
residues to groundwater through the placement of a low-permeability cover system over the
process residues and affected media.
At the completion of the source control remedial action (i.e., when construction of the slag pile
consolidation area cover is complete), the Site will still be subject to use restrictions, including
prohibitions against on-site installation of drinking water wells and any disturbance of the
consolidation area cover that would interfere with the containment of the waste remaining on-site
or with maintenance of the remedy. These use restrictions are necessary because there will be
wastes left on-site. Future human health and ecological risks will be reduced to acceptable levels
once construction of the remedy is complete. The estimated time for completion of this remedy is
2 years for design (1 year of pre-design studies and one year for design) and 3 years to complete
construction, followed by long-term operation and maintenance and implementation of
institutional controls. Upon construction completion, the Site land will be ready for
industrial/commercial re-use. Groundwater and surface water estimated time for beneficial re-use
will be determined in a subsequent ROD as these are interim remedies.
After completion of the remedial action, the former smelter facility property will remain
industrial.
Cleanup Levels (Remediation Goals)
The cleanup levels for the Hegeler Zinc OU1/OU2 Site are the same as the preliminary
remediation goals (PRGs) developed in the FS and presented in the November 2022 Proposed
Plan. PRGs are considered preliminary until final cleanup levels are selected in a ROD. The final
cleanup levels for the OU1/OU2 Site are based both on protective risk-based concentrations
associated with current and reasonably anticipated future land uses (described earlier in this
ROD) and a review of federal and state ARARs.
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Soil Cleanup l.e\els
mu ku
Antimony
98 (HH)/5 (Eco)
Zinc
33,000 (HH)/120 (Eco)
Lead
800 (HH)/120 (Eco)
Mercury
0.1 (Eco)
0.2
Vanadium
25 (Eco)
Ol'l Sediment Cleanup l.e\el
mu ku
('admium
S3 (Mil)
Ol 2 Sediment
niu ku
Pesticides
0.96
Metals
5.7 (unitless)
Oi l Surface W ater Cleanup l.e\el
uu 1.
Cadmium
16 (HH)
Ol 2 Surface W ater Cleanup l.e\el
uu 1.
Dissolved Aluminum
400(Eco)
Dissolved Cadmium
1.4 (Eco)
Dissolved Lead
25 (Eco)
Dissolved Manganese
2,431 (Eco)
Dissolved Zinc
45 (Eco)
Groundwater remediation goals (RGs) are in Table A-8.
The interim groundwater remedy will comply with those substantive federal and state
requirements that are applicable or relevant and appropriate to the limited scope of the action.
The interim groundwater remedy includes ICs to prevent exposure to contaminated groundwater
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until groundwater can be further evaluated and a final remedy selected. Groundwater monitoring
will be conducted following implementation of the source control measures provided by the
other areas' alternatives, to evaluate the impact of those source control measures on groundwater
concentrations over time. The metals detected in Zone 2 groundwater monitoring wells are due
to naturally occurring contamination from coal deposits and/or local mine-workings and not Site-
related, therefore EPA is not restoring Zone 2 groundwater to its beneficial use due to natural
causes as per 35 Illinois Administrative Code (IAC) 620.410(a). The ability to meet the
groundwater chemical specific ARARs and will be evaluated by LTM and EPA during the five-
year review.
Anticipated Community Impacts
The Selected Remedy is recommended because it is expected to achieve long-term risk reduction
through excavation of contaminated soils and isolation by covering the subsurface soil above
human health RGs and an on-site slag pile consolidation area under a low-permeability cover.
This action will protect human receptors from direct contact with affected surface soils and
subsurface soils with physical and institutional controls and will serve to reduce risk to
ecological receptors from contact with surface soil. The excavation of sediment remediation
footprint will protect human receptors from direct contract with affected sediment and will
address ecological concerns.
2.13 - Statutory Determinations
Under CERCLA §121 and the NCP §300.430(f)(5)(ii), the lead agency must select remedies that
are protective of human health and the environment, comply with applicable or relevant and
appropriate requirements (unless a statutory waiver is justified), are cost-effective, and utilize
permanent solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. In addition, CERCLA includes a preference for remedies that
employ treatment that permanently and significantly reduces the toxicity, mobility or volume of
hazardous wastes as a principal element and a bias against off-site disposal of untreated wastes.
The following sections discuss how the Selected Remedy meets these statutory requirements.
Protection of Human Health and the Environment
The Selected Remedy provides overall protection of human health and the environment from
impacted soils and groundwater. Protection of human health and the environment will be
achieved through excavation, consolidation, and containment of contaminated materials; or via
disposal at an off-site hazardous waste landfill in the event that excavated materials fail TCLP
analysis. Institutional controls will be implemented to restrict land use where contamination is
left behind and to restrict groundwater use at the former smelter property. The Selected Remedy
will reduce exposure levels to protective ARAR- or risk-based cleanup levels, reducing risks to
within EPA's generally acceptable risk range of 10"4 to 10"6 for carcinogenic risk and below the
HI of 1 for non-carcinogens. The Selected Remedy also will provide adequate protection of the
environment.
No unacceptable short-term risks are anticipated by implementation of the remedy. Some short-
term risks will be created by excavation and transportation of contaminated material, but these
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risks can be minimized through proper mitigative measures during construction. For example,
EPA will work with the local community to develop a transportation plan that will strive to
minimize adverse impacts related to truck traffic during Village cleanup.
Compliance with Applicable or Relevant and Appropriate Requirements
The Selected Remedy will comply with federal and state ARARs. Compliance with ARARs is
discussed above in Section 2.10 and the ARARs for this action are provided in Table A-6. Table
A-6 also includes information regarding TBCs that do not constitute ARARs but will be
appropriately considered during implementation of the remedy.
Cost-Effectiveness
In the EPA's judgment, the Selected Remedy is cost-effective and represents a reasonable value
for the money to be spent. In making this determination, the following definition was used: "A
remedy shall be cost-effective if its costs are proportional to its overall effectiveness." (NCP
§300.430(f)(l)(ii)(D)). This was accomplished by evaluating the "overall effectiveness" of those
alternatives that satisfied the threshold criteria (i.e., were both protective of human health and the
environment and ARAR-compliant). Overall effectiveness was evaluated by assessing three of
the five balancing criteria in combination (long-term effectiveness and permanence; reduction in
toxicity, mobility, and volume through treatment; and short-term effectiveness). Overall
effectiveness was then compared to costs to determine cost-effectiveness. The relationship of the
overall effectiveness of this remedial alternative was determined to be proportional to its costs
and hence this alternative represents a reasonable value for the money to be spent.
The estimated present worth cost of the Selected Remedy is $29,300,000. Although Alternative 2
is $4,000,000 less expensive, this alternative would be difficult to implement due to reduced
constructability. EPA believes that the Selected Remedy's additional cost for stabilization
provides a significant increase in protection of human health and the environment and is cost-
effective. EPA also believes that the Selected Remedy has similar effectiveness as Alternatives 4
and 5 at a significantly lower cost.
Preference for Treatment as a Principal Element
The Selected Remedy does not follow the statutory preference for treatment as a principal
element because the large volume of relatively low-level metals-contaminated soils, sediment
and slag at the Site do not lend itself to any cost-effective or practical treatment. However,
excavated materials that exceed TCLP criteria (therefore considered hazardous waste) will be
treated off site to reduce the mobility of the contaminants prior to disposal in an appropriate off-
site landfill.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource
Recovery Technologies) to the Maximum Extent Practicable
EPA has determined that the Selected Remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in a practicable manner at the
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Site. Of those alternatives that are protective of human health and the environment and comply
with ARARs, EPA has determined that the Selected Remedy provides the best balance of
tradeoffs in terms of the five balancing criteria, while also considering the statutory preference
for treatment as a principal element and bias against off-site disposal of untreated wastes and
considering state and community acceptance.
The Selected Remedy provides long-term and permanent protection against exposure to
contaminated materials by excavating contaminated materials and isolating them by covering the
subsurface soil above human health RGs and an on-site slag pile consolidation area under a low-
permeability cover. The contaminated materials will be consolidated and contained under a low-
permeability cap, a technology proven to be effective in the long-term in the containment of
waste and the prevention of infiltration. This action will protect human receptors from direct
contact with affected surface soils and subsurface soils with physical and institutional controls
and will serve to reduce risk to ecological receptors from contact with surface soil. The
excavation of sediment remediation footprint will protect human receptors from direct contract
with affected sediment and will address ecological concerns. No unacceptable short-term risks
are anticipated by implementation of the remedy. Some short-term risks will be created during
implementation of the remedy, but these risks can be minimized through proper mitigative
measures during construction. There are no implementability issues as the remediation
technologies are regularly used at similar sites throughout the country.
Five-Year Review Requirements
Because this remedy will result in hazardous substances, pollutants, or contaminants remaining
on-site above levels that allow for unlimited use and unrestricted exposure, a statutory review
will be conducted within five years after initiation of remedial action, and every five years
thereafter, to ensure that the remedy is, or will be, protective of human health and the
environment.
2.14 - Documentation of Significant Changes
The Proposed Plan for the Hegeler Zinc Site was issued for public comment from December 1 to
December 31, 2022. The Proposed Plan identified Alternative 3 as the preferred alternative.
CERCLA Section 117(b) and NCP Section 300.430(f)(5)(iii) require an explanation of any
significant changes from the remedy presented in the Proposed Plan that was published for
public comment. EPA received comments from four individuals during the public comment
period. EPA reviewed all written and verbal comments submitted during the public
comment period and determined that no significant changes to the remedy, as originally
identified in the Proposed Plan, were necessary or appropriate, as set forth below.
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PART III - RESPONSIVENESS SUMMARY
In accordance with CERCLA Section 117, 42 U.S.C. Section 9617, EPA released the Proposed
Plan and Administrative Record for the Hegeler Zinc Site on December 1, 2022, and held a
public comment period from December 1 through December 31, 2022, to allow interested parties
to comment on the Proposed Plan. On December 7, 2022 EPA held an in-person public meeting
to at the Danville Area Community College to discuss the Proposed Plan, answer questions and
accept public comments verbally or in writing. The presentation from the public meeting was
available to the public throughout the comment period and contained all information that was
presented during the in-person public meeting.
This Responsiveness Summary provides both a summary of the public comments EPA received
regarding the Proposed Plan and EPA's responses to those comments. EPA received written
comments via the comment form available on EPA's web page, via handwritten mailed
correspondence, via electronic mail, and verbally as recorded by a court reporter at the public
meeting on December 7, 2022. EPA received comments from four concerned citizens.
EPA is required by law to consider and address only those comments that are pertinent and
significant to the remedial action being selected. EPA is not required to address comments that
pertain to the allocation of liability for the remedial action nor potential enforcement action to
implement the remedial action, as these matters are independent of the selection of the remedial
action and EPA's Proposed Plan. Additionally, EPA is not required to reprint verbatim the
comments received and may paraphrase where appropriate. In this Responsiveness Summary,
EPA has included large segments of the original comments. A written transcript of the comments
provided during the public meeting is also included in the Administrative Record. The
Administrative Record index is provided in Attachment 3.
Public Comments and EPA Responses
1) One commenter, a landowner with property downstream of the Site along the Creek
stated that, as a lifelong resident of the area, when the commenter was approximately 17
years old, the riverway was always orange and the commenter was told not to play in it.
The commenter inquired whether or not it was alright for children to play in the water
and also expressed that they would love for the water to be tested behind the commenters
property to see if it is vile.
EPA Response: Thank you for your comment. Surface water and sediment samples were
collected from the unnamed tributary to Grape Creek and from Grape Creek in
commercial, residential, and less developed areas on behalf of U.S.EPA as part of the Site
Assessment (SA) in 2002, as a part of the RI in April 2006, May 2006, and November
2006, and in April 2010 as part of the U.S.EPA's OU1 sampling efforts. Shield
Environmental Associates sampled on behalf of KIK in July 2009, October 2009, and in
April 2010. AECOM conducted sediment sampling on behalf of KIK in May 2011 to
support the OU2 BERA. The data produced from these sampling events was reviewed
during the HHRA produced by AECOM (Human Health Risk Assessment, OU2, Hegeler
Zinc Superfund Site, May 2014) and again in the 2020 HHRA update.
Hegeler Zinc ROD
Page 63
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As part of the Human Health Risk Assessment, EPA evaluated the health risks associated
with surface water and sediment for adolescents ages 7 to 16 that may use water bodies
for swimming, playing, or general recreation. The HHRA used conservative assumptions
to determine excess cancer risk and non-cancer hazards for adolescents recreating in the
KIK Culvert, Grape Creek, and an unnamed tributary to Grape Creek.
Excess cancer risk is the likelihood that an individual will contract cancer in their lifetime
in addition to the background cancer rate. Non-cancer hazards are expressed as a hazard
index (HI), which reflects the potential for non-cancer health effects to occur. EPA has
established as acceptable a target excess cancer risk range of one in ten thousand to one
in one million (10-4 to 10-6). The target HI for non-cancer hazards is one; when the HI is
less than or equal to one, no adverse non-cancer effects are expected.
Excess cancer risk and non-cancer His are within the target ranges for adolescent
recreators in all evaluated exposure scenarios at KIK Culvert, Grape Creek, and the
unnamed tributary. Therefore, no adverse health effects are expected for adolescents ages
7 to 16 that play in the waterbodies in OU2.
2) One commenter inquired if the symbols in Figure 8 or 9 of the Proposed Plan were
testing locations all the way down the stream where there had been sampling in the
Creek. The commenter also expressed that the legend was illegible and inquired if there
is sampling data available for the locations indicated on Figure 9.
EPA Response: Figure 8 and 9 of the Proposed Plan were reviewed and it is Figure 9 the
commenter is referring to. Figure 9 in the Proposed Plan is from the Human Health Risk
Assessment, OU2, Hegeler Zinc Superfund Site, May 2014. The icons along the Creek
are indeed surface water and sediment sample locations, where surface water sample
locations are denoted with pink triangles and sediment sample locations are denoted with
green circles. Analytical data for these surface water and sediment samples are included
in the 2014 Human Health Risk Assessment as Appendix A.
Additionally, the Proposed Plan figures have been added to the Administrative Record as
a separate document to increase legibility and image quality.
3) The Illinois Department of Natural Resources (IDNR) Abandoned Mined Lands
Reclamation Division (AML) submitted three comments
a. The first comment identified two abandoned underground coal mine shafts that
are located within the fenced area of the Hegeler Zinc Superfund Site. The IDNR
AML installed reinforced concrete caps with mine marker plates to the main shaft
and air shaft as part of a reclamation project (AML-GVeE-9506) completed in
1995/1996. Due to the inherent safety hazards associated with abandoned mine
shafts, the AML requested that the mine shafts and reinforced concrete caps
remain in their current condition and not be impacted by on-site remedial
corrective actions. The IDNR AML indicated that any alteration to the shaft
concrete caps could jeopardize the integrity of the mine shafts resulting in an
increased safety hazard. The commentor also requested EPA contact IDNR AML
Hegeler Zinc ROD
Page 64
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if it is believed that remedial corrective actions may impact the mine shaft
locations.
b. Contaminated sediments in an unnamed tributary to Grape Creek will be removed
from 0 - 0.5 feet as part of the proposed remedial action plan. Based on the
proposed remedial action plan figures, it appears impacted creek sediments will
be removed from the Hegeler site to a culvert location at W. Ross Ln in Tilton,
IL. This portion of the unnamed tributary includes a section of the creek channel
that borders an abandoned mine site known to AML as the V-Day Mine. AML
performed reclamation activities along the east side of the creek channel to
address a mine refuse pile and associated Acid Mine Drainage (AMD). On
December 7, 2022 AML inspected the V-Day Mine site and determined that
additional reclamation activities may be required by AML to address exposed
mine refuse material and acid mine drainage discharges adjacent to and
potentially including the east bank of the creek channel. The proposed remedial
action plan does not include a detailed description of the sediment removal
corrective actions. Since it is unclear if the sediment removal corrective actions
might impact the eastern side of the creek channel and associated V-Day Mine
problem areas, the commenter would like to discuss future remedial actions at that
location with USEPA to coordinate future corrective actions and AML
reclamation activities.
c. The text portion of figures and tables in the Proposed Plan on the Hegeler Zinc
Superfund Site website are very blurry and difficult to interpret. USEPA may
wish to consider providing a more legible copy of the maps, figures, and tables.
EPA Response: Thank you for your comments, (a) EPA will ensure that the mine shafts
and reinforced concrete caps remain in their current condition and not be impacted by on-
site remedial corrective actions, (b) EPA will contact AML when our design contractor is
on-board and participate in a site visit with representatives of AML so that they can show
EPA and our contractor where AML's concerns are. (c) Thank you for pointing this out,
updated maps were posted to the website during the public comment period.
4) A commenter indicated that the Village of Tilton will be removing approximately 26
cubic yards of sediment build-up that is potentially restricting high water flows
immediately upstream of Washington Avenue Bridge in Tilton. The commenter inquired
whether the EPA has any concern about the Village implementing removal of this
sediment and using it as fill material in a deactivated sewage treatment plant sludge
lagoon along Songer Cemetery Road in Tilton.
EPA Response: The Washington Ave. bridge in Tilton is outside the boundaries of this
Superfund Site. EPA has no knowledge of, or opinion on, the sediment referenced in this
comment.
5) A commenter wanted to know if there had been consideration during the planning
process to cover the site with impermeable material then cap with topsoil and vegetation
in order to minimize potential for excavation dust and drainage pollution. In addition, the
Hegeler Zinc ROD
Page 65
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commenter wanted to know if installation of solar panels anchored to concrete slabs
could be an acceptable future use at this site.
EPA Response: Alternative 2 in the Proposed Plan included capping all soils on OU1
with an impermeable cap, which was not the selected remedy because it is not as
effective under the long-term and permanent protection criteria as the excavation and
backfilling in Alternative 3, the proposed remedy in the Proposed Plan.
Regarding future use of the Site, EPA foresees commercial/industrial use after the
remedy is installed. Such uses may be subject to zoning, permit, etc., requirements.
Specifics and details on what those future uses may be are not known at this time , and
thus EPA is not in a position to comment on particular future uses.
6) A commenter expressed inability to attend the public meeting but lives on Alpha Drive in
the local community and inquired what does this action mean for homeowners in the
area.
EPA Response: EPA completed a residential soil cleanup in Hegeler just east of the
former zinc smelter facility in 2016. The selected remedy in this ROD as proposed in the
proposed plan is for OU1 (former zinc smelter facility) and OU2 (sediment in un-named
tributary to Grape Creek). EPA expects limited impacts to the community, which may
include increased truck traffic and construction noise. If you have any further questions
or concerns, please contact Beth Reiner, EPA Remedial Project Manager at
Reiner.Elizabeth@epa.gov or 312-886-0170.
Hegeler Zinc ROD Page 66
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ATTACHMENT 1
FIGURES
-------
IOWA
Chicago o
Peoria
O
T ILLINOIS
f— Site Location
Springfield o
O
Indianapolis
INDIANA
Saint Louis ojf
I
MISSOURI
Louisville— |
/ Jyv
KENTUCKY
3 r-»» • -¦
0 70 140
1 I I Miles
1.5
_J
LEGEND
Site Location
~
x *- Fence
Approximate Historic Boundary of the Former Zinc Smelting Operations
Image source: NGS USA Topographic Maps
Figure 1
Site Location Map
OU1, Hegeler Zinc Superfund Site,
Vermilion County, Illinois
cti2m-
UAMIU.B-w
South Danville
£ t Central
li f«rk
USEPA-constructed fence
Hcjfeter
iiulgiuta
-------
lwlnc| I
Sch S .
Isoqr*
Vermilion-
Heighu
^liHSis| ¦«" "
. DANVILLE
21 Dodg$p» Park
Q -
^ . aS Dougtas
=5 ----- Park 2
DAK VIL
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Itaft i?[a Seh
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T
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Central
Park
Radio To
tWiTYj .
KIK Cuive
-M.ne UuiT>f>5- fjfl
RftJiaimed
Strip Mine
Mc Millar; Sck • (
St«a8« *1
.-— Belgian-
Map Area Shown in Red
¦ : :•¦: :
6*9
est
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—sT
- -1-"^ y
sat *«
m
yt+6
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Di.mp
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i
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ra.tti
Legend
Area of Investigation
Stream in Culvert
Grape Creek
Stream Outside Project
QU2 Creek and
KIK Culvert
0 500 1.000
4,000
3 Feet
x — x — OU1 Boundary/ Fence
.Copyright:© 2013 National Geographic Society, i-cubea
AICOM
OPERABLE UNIT 2
FEASIBILITY STUDY
DANVILLE, IL
60504794
Date: 08/2016 DRAWN: JRM
TOPOGRAPHIC LOCATION MAP
FIGURE 2
Path: K:\PROJECTS\60504794\900-GIS\Feasibility Study Report-Figure 1 - HZ FS Site Location.mxd
-------
LEGEND
[™J OPERABLE UNIT BOUNDARY
WATERWAY
WATERWAY TUNNELED
100
I
200
_l
FIGURE 3
HEGELER OU3 FEATURES
OU3 HEGELER ZINC SUPERFUND SITE
DANVILLE, ILLINOIS
CH2MHILL
RDD \\BALDUR\PROJ\HEGELERSRIFS 395101\MAPFILES\SUPP RI\FIG1-2 OU3 FEATURES SRI.MXD MSCHROCK5/31/2012 1:00:12 AM
-------
Figure 4
|
Hegeler Zinc Superfund Site
Danville, Illinois
N
A
425212.5 0
Legend
Operable Unit 1 (OU1)
Operable Unit 2 (OU2)
Operable Unit 3 (OU3)
425 Feet
The downstream extent of OU 2 is
shown in Figure 2.
State of Illinois
-------
LEGEND
Former Structure
~ Existing Building
x Fence
1 1 1 Former Railroad
Creek in Culvert
Creek
Former Settling Pond
KIK Property Areas addressed by RCRA Programs
OU3 Residential Soil Pile Can Area TTUA Interceptor
NWI Freshwater Emergent Wetland Can Area Grid 213 Interceptor Trench
NWI Freshwater Pond Can Crusher Area
NWI Riverine Closed Surface Impoundment
Former Land Treatment Area
TTUA
0 150 300
I Truck Scale I i I
Figure 5
Site-specific Features Map
OU1, HegelerZinc Superfund Site
Vermilion County.; Illinois
~ Slag Pile
WDC1 VS01\GISPROJ\H\HEGELERSRIFS 395101\MAPFiLES\2019\SiTE FEATURES 2019.MXD GTWIGG 10/7/2020 11:57:08AM
Ck\2Ml
-------
Dustand'FLfm^Em mission^
Roasting Oven
'*\
Former Zinc
i^rmen. KiIns/Srrielting Fumaces
- . a
m missions
Residential Area
Wind Blown'
Particulates1
KIK CustomiRroducts^Inc
I InMroathoro'H:>sna a:Ranrnr^ (7nno 9\:
SOUTHWEST
NORTHEAST
Wind Blown
Particulates
Former Zinc Roasting Oven
Slag Pile
Creek
Groundwater Contaminant Plume
' \\ - / VI. - •' ,( ¦- " \\ o " - " - ¦' ,, - II \* " .1 — r/ ¦
Creek
Dust and Fume Emmissions
==^ i^ f = ^ ^ ^
\\V//^\v// ^// \\^//^W// ^// \\"V //^\\ // ^// ^//AQ ^// v\^ //Ow/ ^ w •
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%;i ££il|/«cHn v I l!iB» 8 8 •*)!!»» Wh, t mirSfii SB- ? «%?« Jfv %,i T® * £
Groundwater Discharge
to;Sijrface Water (6reek)
wrW v
'»'Ki /<>¦
4„ // '" t.4 » » « '" ^
¦ w - ^ »- ¦ :. ' :. Weathered Bedrock (Lower Zone 1)
\\V // \\ // ^ li \\V // \\ // ^ n //^\\ // ^ a //^\\ // ^ // vv^ //^\\ // ^ // ^ //^\\ // ^ // //^\\ // ^ a //^\\ // ^ // vv^ //^\\ // ^ ii ^ //^\\ // ^ ii ^ //^\\ // ^ // ^ //^\\ ii //^\\ ii ^ ii ^ //^\\ // ^ // \*i
Creek Bed Sediment »
%*'f IKi*,
LEGEND
Surface Runoff
Groundwater Flow
Surface Water Flow
Creek in Culvert
EPA Fence
Infiltration and Leaching of Contaminants from Soil/Slag to Groundwater
Note: Conceptual site model is not to scale
. ••¦'M
FIGURE 6
Conceptual Site Model
OU1, Hegeler Zinc Superfund Site
Vermilion County, Illinois
e4i2m
ES032212224741MKE USEPA_Hegeler-Zinc_Cross_Section_v10.ai 10/17/2019 tdaus
-------
Primary Source
Primary
Release
Mechanism
Secondary
Source
Secondary
Release
Mechanism
Overland Flow,
Runoff
on-site slag
pile, residual
materials and
fill, historical
releases of
organics during
maintenance
and repair, the
manufacture of
pyrotechnics,
and sulfuric
add.
Leaching
and runoff
of soil, slag
and
residual
materials
Surface Soil
(on-site)
Leaching
Particulate
Emission
Subsurface Soil
Leaching
Legend
(1) X - Potentially complete exposure pathways Identified.
(2) Volatilization during use and indoor air vapor intrusion is an insignificant pathway,
as only low concentrations of a few volatile organic compounds (VOCs) were
detected in soil and groundwater during historic sampling.
(3) Institutional controls will be implemented at the site prohibiting future residential
land use.
(4) Sediment at settling ponds at Exposure Area 2 can be exposed during summer
months; therefore, it was treated as soil for exposure purposes.
P = Exposures associated with potable groundwater use.
Exposure Media
Exposure
Route
Potential Human Receptors
On-site
Current
Future
Adolescent
Trespasser
Industrial
Workers
Construction
Workers
Surface Water
~ (settling ponds
and waterway)
Ingestion
Dermal Contact
Dermal Contact
Ingestion
Dermal Contact
Ingestion
Dermal Contact
Groundwater
(on-site)
Ingestion (P)
Dermal Contact (P)
Inhalation (P)
X
X
(2)
Figure 7 a
Revised Human Health Risk Assessment
Conceptual Site Model for Hegeler Zinc OU1
Vermilion County, Illinois
-------
Source
Environmental
Transport
Pathways
Exposure Media
Figure 7b Ecological Conceptual Site Model
OU1, Baseline Ecological Risk Assessment, Hegeler Zinc Site
Hegeler, Illinois
Exposure
Receptors
Route
Ingestion
Direct Contact
Root Uptake
£ <">
92. <"
Sfi =*"
<1 s
(/) Q)
3-
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3
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—
X
—
—
X
X
X
—
X
X
—
0
0
0
—
—
X
inhalation
Foliar Uptake
0
0
0
—
—
0
Ingestion
Direct Contact
Root Uptake
X
X
—
—
X
X
X
X
X
0
"
0
0
0
"
"
0
Ingestion
Direct Contact
Root Uptake
X
X
—
0
X
X
X
X
X
X
X
X
0
0
—
—
X
Ingestion
X
X
X
X
X = Pathway evaluated quantitatively
O = Pathway evaluated qualitatively
- = Pathway not applicable to receptor group
-------
FIGURE 7c
HEGELER ZINC 0U2 CONCEPTUAL MODEL
SITE WATERWAYS
RECEPTORS
Revised by AECOM
August 16, 2010
-------
Imagery Source: ©2017 Google™ with modificationssfirpm CH2M!
[HZW20"3l
IHZ3S2301
IHZ-SS309]
HZ-SS317'
[HZ!iSS202|
HZ-SS032
[HZ-SS029
y—HZ-SS316
10'MHZ-S5323
HZ-SS325
X A
HZ-SS279
|^HZgS3245
¦HzSsSslW
^HZ^j5321 |
MHZ?SS053ft
fHgSS322%^r
[HZ-SS328;
HZISS052]
rHZ^S319!
[HZ-SS233
HZ-SD20
'>JttBi»HZ^SD33 —.
¦HZSD211
[HZ-SD31 mil
>HZ?SD57^j
!HZ-jSb48^.|.
HZ-SD32
BflB Si
KIK Property Ditch
HZ-SS312
'HZiSSl13
^MHZ|SS,12?. -H
f^p|si3S|4
_Sl| ¦
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HZ-SS130
[HZ-SD62]
HZ-SS135,
LEGEND
¦ 1 1 Former Railroad
x *- Fence
Stream in Culvert
Stream
Former Structure
~ Existing Building
inn J Approximate OU1 Boundary
Human Health Exposure Areas
Exposure Area 1
Exposure Area 2
Exposure Area 3
® Sediment Sample Location
~ Soil Sample Location
[_J OU3 Residential Soil Pile
Settling Pond
Slag Pile
Figure 8a
Onsite Soil and Sediment
Sampling Locations with
Exposure Areas
Hegeler Zinc Superfund Site
Vermilion County, Illinois
Ffc\ENBG\00_PROJVH\HEGELERSRIFS_395101\MAPFlLES\2019\QNSrTE_SC>IL_SED_LOCS_2019_NOEAS.MXD GTW1GG 9/16/20195:04:51 PM
chZrn
-------
EXPOSURE AREAI1
EXPOSURE AREA 2
. ** 1
¦T^TV
KIK PROPERTY CULVERT
FIRE WATER POND
KIK CUSTOM PRODUCTS, INC
AREA 4
SETiTIIING PONDS
Imagery Source: ESRI World Imagery (Clarity) online mapping service.
LEGEND
Former Settling Pond
~ Slag Pile
Former Structure
~ Existing Building
* *- Fence
= Former Railroad
OU3 Residential Soil Pile
Creek in Culvert
Creek
Human Health Exposure Areas
Exposure Area 1
~ Exposure Area 2
Exposure Area 3
Exposure Area 4
Figure 8b
OU1 Human Health Risk
Assessment Exposure Areas
OU1, HegelerZinc Superfund Site
Vermilion County, Illinois
150
I
Feet
cil2wi
R:\ENBG\00 PROJ\H\HEGELERSRIFS 395101\MAPFILES\2018\EXPOSUREAREAS.MXD GTWIGG 3/30/2020 9:54:58 AM
-------
X208
HZ-SD03
HZ-SD66
HZ-SW01
HZ-SW01 -10
HZ-SD07
HZ-SD67
HZ-SD40
HZ-SW03-10
HZ-SW03
SD-105 —
Im" ifl
S061
HZ-SD68 I
HZ-SD1Q
HZ-SW04-10
HZ-SW05-10
HZ-SD16
Mi 4 HIIIUIKI'
|,w_
!;'«mWnnfn -
HZ-SD69
HZ-SW05
HZ-SW12-10
HZ-SD3jT
HZ-SD43
HZ-SW12
HZ-SD44
HZ-SD45
HZ-SD46
HZ-SD47
Warren
Legend
Surface Water Samples
A 0U2 Surface Water Locations
/\ Additional Available OU2 Surface Water Locations
Sediment Samples
OU2 Sediment Locations
0 Additional Available OU2 Sediment Locations
Hegeler Zinc Site OU2
Danville, IL
AZCOM
Stream Section
m Grape Creek/Less Developed Areas
Grape Creek/Commercial Areas
Grape Creek/Residential Areas
II Creek
Fence Line
Vermilion
OU1 Boundary
Stream Outside Project
Champaign
Sediment and Surface
Water Locations
KIK Culvert
Stream in Culvert
DATE: July 2013
Drawn By: IV! F
Project Number: 60161489
Douglas
Path: U:\GIS\Misc\Hegeler_Zinc_OU2\Human_Health_Risk_Assesment_Figures\Hegeler_Zinc_Fig_2_Sed_Sarmp_Loc_lnset_20130731 .mxd
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Sediment Remediation Area
" Culvert
Creek
Fence
Source: Bing Maps Hybrid 2016
Hegeler Zinc Site
Vermillion County, Illinois
Figure 10
Sediment Remediation Areas
lb
TETRA TECH
Prepared For: EPA
|Prepared^By^
Date Saved: 2/14/2022
EPA Contract No.: 68-HE-0519-D0005
TO-TOLIN: 0072-0001CJ108
Coordinate System: NAD 1983 StatePlane Illinois East FIPS 1201 Feet
Projection: Transverse Mercator
Datum:North American 1983 Units: Foot US
-------
Imagery Source: ESRI World Imagery (Clarity) online mapping service
iKIKiRRORERW^CULVERTj
~ RE WATER POND
KIKCUSTOM PRODUCTS, INC
immmes.±x. 1i
Notes:
1. Sediment data has been collected within the KIK Culvert and downstream of the EPA fence.
This data was not screened against PRGs, and is not included on this figure because these |
areas are included in the OU2 FS.
LAKE HARRY
LEGEND
1 1 1 Former Railroad * Fence
Settling Pond Creek
~ Slag Pile Creek in Culvert
Groundwater Exceedance Area Former Structure
Surface Water Exceedance Area ~ Existing Building
OU3 Residential Soil Pile
Figure 11
Surface Water and Groundwater
Exceedance Areas
Conceptual Layout
Hegeler Zinc Superfund Site
Vermilion County, Illinois
Ctl2M-
DEN R:\ENBG\00 PROJ\H\HEGELERSRIFS 395101\MAPFILES\2019\REMEDIAL GWSW.MXD GTWIGG 3/30/2020 10:14:11 AM
-------
LEGEND
¦ ¦ ¦ Former Railroad
~ Slag Pile (see note 1)
Creek
Creek in Culvert
x * Fence
Former Structure
~ Existing Building
Remedial Alternative 2 Soil Institutional Control
Areas (in addition to the yellow polygons)
Remedial Alternatives 2, 3, and 4
Soil Institutional Control Areas
~ Remedial Alternatives 2, 3, 4, and 5
Soil Institutional Control Areas
Figure 12
Areas Requiring Institutional
Controls for Soil
HegelerZiric Superfund Site
Vermilion County, Illinois
Ctl2M-
DEN R:\ENBG\00 PROJ\H\HEGELERSRIFS 395101\MAPFILES\2019\INSTITUTIONALCONTROLS SOIL.MXD GTWIGG 3/27/2020 1 0:09:57 AM
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B R E S U ME D: C O A1 IffivliN Era HWET»
jKIK'PRORERTiYiCULVERT,i
KIKCCUSTOM PRODUCTS, INC
< ¦
FIRE WATERIROND:
LAKE HARRY
Imagery Source: ESRI World Imagery (Clarity) online mapping service.
I Notes:
|l. Sediment data has been collected within the KIK Culvert and downstream of the EPA fence
These areas are addressed in the OU2 FS.
. . ...
LEGEND
«= Former Railroad * * Fence Surface Soil Remediation Area
~ (Excavate to 0.5 ft)
Slag Pile Former Structure
. . Surface Soil Remediation Area
Creek | | Existing Building , (Cover with Minimum of 2 ft of Clean Soil)
Creek in Culvert OU3 Residential Soil Pile Sediment Remediation Area
Relocated Creek Location
(Excavate/Dredge to 0.5 ft)
DEN \\DC1VS01\GISPROJ\H\HEGELERSRIFS_395101\MAPFILES\2019\REMEDIAL_ALT2.MXD GTWIGG 10/5/2020 1:15:01 PM
Sediment Remediation Area
(Excavate/Dredge to 1 ft)
Creek Bed Remediation Area (Reroute)
Cover Slag Pile and Additional
Excavated Soil
Area of Slag to be Relocated
Figure 13
OU1 Remedial Alternative 2
Conceptual Layout
HegelerZinc Superfund Site
Vermilion County, Illinois
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KIK CUSTOM PRODUCTS, INC.
FIRE WATER POND
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.-y,
Notes:
1. Sediment data has been collected within the KIK Culvert and downstream of the EPA fence
These areas are addressed in the OU2 FS.
LEGEND
1 1 1 Former Railroad
~ Slag Pile
m Creek
Creek in Culvert
Relocated Creek Location
* * Fence
Former Structure
~ Existing Building
OU3 Residential Soil Pile
Surface Soil Remediation Area
(Excavate to 0.5 ft)
Surface Soil Remediation Area
(Excavate to 2 ft)
Sediment Remediation Area
(Excavate/Dredge to 0.5 ft)
Sediment Remediation Area
(Excavate/Dredge to 1 ft)
Creek Bed Remediation Area (Reroute)
I Cover/Cap Slag Pile and Additional
Excavated Soil
Area of Slag to be Relocated
Figure 14
01)1 Remedial Alternative 3
(Selected Remedy)
Conceptual Layout
Hegeler Zinc Superfund Site
Vermilion County, Illinois
chzm-
DEN WDC1 VS01\GISPROJ\H\HEGELERSRIFS 395101\MAPFILES\2019\REMEDIAL ALT3.MXD GTWIGG 10/2/2020 2:18:08 PM
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[SHHFjTd
f KIKiRRORERW^CULVERTj
KIK CUSTOM PRODUCTS, INC
FIRE WATER POND
LAKE HARRY
.
Notes:
1. Sediment data has been collected within the KIK Culvert and downstream of the EPA fence.
These areas are addressed in the OU2 FS.
2. Soils beneath paved areas and active buildings on the KIK Property will not be excavated.
LEGEND
111 Former Railroad
~ Slag Pile
x x Fence
Creek
Creek in Culvert
Relocated Creek Location
Former Structure
I | Existing Building
I Ecological RG Remediation
Area (Excavate to 2 ft)
Sediment Remediation Area
(Excavate/Dredge to 0.5 ft)
Sediment Remediation Area
(Excavate/Dredge to 1 ft)
Creek Bed Remediation Area (Reroute)
I Cover/Cap Slag Pile and Additional
Excavated Soil
Area of Slag to be Relocated
OU3 Residential Soil Pile
Figure 15
OU1 Remedial Alternative 4
Conceptual Layout
HegelerZinc Superfund Site
Vermilion County.; Illinois
Ctl2M-
DEN R:\ENBG\00 PROJ\H\HEGELERSRIFS 395101\MAPFILES\2019\REMEDIAL ALT4.MXD GTWIGG 3/30/2020 10:18:15 AM
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iRESUMEBfCQalllMINEiSTOlJ
iKIKiRRORERW^CULVERTj
KIK CUSTOM PRODUCTS, INC
TAKE HARRY
Notes:
1. Sediment data has been collected within the KIK Culvert and downstream of the EPA fence.
These areas are addressed in the OU2 FS.
2. Soils beneath paved areas and active buildings on the KIK Property will not be excavated.
LEGEND
111 Former Railroad
~ Slag Pile
x x Fence
^^^Creek
Creek in Culvert
Relocated Creek Location
Former Structure
I I Existing Building
OU3 Residential Soil Pile
¦Ecological RG Remediation Area
'(Excavate to 2 ft)
¦Surface and Subsurface RG
¦Remediation Area (Excavate to 4 ft)
¦Surface and Subsurface RG
iRemediation Area (Excavate to 5 ft)
Surface and Subsurface RG
Remediation Area (Excavate to 6 ft)
^Surface and Subsurface RG
Remediation Area (Excavate to 8 ft)
Surface and Subsurface RG
Remediation Area (Excavate to 10 ft)
^Sediment Remediation Area
|l(Excavate/Dredge to 0.5 ft)
Sediment Remediation Area
(Excavate/Dredge to 1 ft)
Creek Bed Remediation Area (Reroute)
¦Cover/Cap S lag Pile and Additional
lExcavated Soil
Area of Slag to be Relocated
Figure 16
OU1 Remedial Alternative 5
Conceptual Layout
HegelerZinc Superfund Site
Vermilion County.; Illinois
Ctl2M-
DEN R:\ENBG\00 PROJ\H\HEGELERSRIFS 395101\MAPFILES\2019\REMEDIAL ALT5.MXD GTWIGG 3/30/2020 10:19:34 AM
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ATTACHMENT 2
TABLES
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Table A-1
Conceptual Site Model for OU2
Human Receptors
HegelerZinc Superfund Site OU2
Danville, Illinois
Scenario
Timeframe
Medium
Exposure
Medium
Exposure
Point
Receptor
Population
Receptor
Age
Exposure
Route
On-Site/
Off-Site
Type of
Analysis
Rationale for Selection or Exclusion
of Exposure Pathway
Current/ Future
Sediment
Sediment
Waterway (a)
Recreational User
Adolescent
(7-16 years)
Ingestion
On-site
Quant
Waterway in some areas is accessible for public access.
Dermal
On-site
Quant
Surface Water
Surface Water
Waterway (a)
Recreational User
Adolescent
(7-16 years)
Ingestion
On-site
None
Incidental ingestion expected to be negligible.
Dermal
On-site
Quant
Waterway in some areas is accessible for public access.
Current
Sediment
Sediment
KIK Culvert
Recreational User
Adolescent
(7-16 years)
Ingestion
On-site
None
Culvert is located in a secure area of the facility that is fenced
and monitored.
Dermal
On-site
None
Surface Water
Surface Water
KIK Culvert
Recreational User
Adolescent
(7-16 years)
Ingestion
On-site
None
Dermal
On-site
None
Sediment
Sediment
KIK Culvert
Industrial Worker
Adult
Ingestion
On-site
None
Current worker exposures are limited to annual cleaning, and
personal protective equipment is used (b).
Dermal
On-site
None
Surface Water
Surface Water
KIK Culvert
Industrial Worker
Adult
Ingestion
On-site
None
Dermal
On-site
None
Future
Sediment
Sediment
KIK Culvert
Recreational User
Adolescent
(7-16 years)
Ingestion
On-site
Quant
While future exposures are unlikely, there are no controls in
place to prevent potential future exposure. Incidental ingestion
expected to be negligible.
Dermal
On-site
Quant
Surface Water
Surface Water
KIK Culvert
Recreational User
Adolescent
(7-16 years)
Ingestion
On-site
None
Dermal
On-site
Quant
Sediment
Sediment
KIK Culvert
Industrial Worker
Adult
Ingestion
On-site
Quant
Dermal
On-site
Quant
Surface Water
Surface Water
KIK Culvert
Industrial Worker
Adult
Ingestion
On-site
None
Dermal
On-site
Quant
Notes:
(a) - The Grape Creek waterway, including its tributary, has been divided into several exposure areas, as described further in the text.
The recreational user will be evaluated in each exposure area, with exposure frequency being specific to each area.
(b) - Sediment is removed annually from the culvert by a wastewater contractor. A vacuum truck is used to remove the sediment and the process takes about two hours. The workers must
follow KIK Danville Health and Safety policies and procedures and are required to wear a Tyvek suit, rubber boots, gloves, and eyewear protection during the cleaning (Chris Outman,
personnel communication, 1/21/13).
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Table A-2. HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF CONCERN
SUMMARY
HEGELER ZINC OPERABLE UNIT 1
DANVILLE, ILLINOIS
Exposure Point
Chemical of
Concern1
Target Organs2
Units
Frequency of
Detection
Minimum
Concentration
Maximum
Concentration
(Qualifier)
Exposure Point Concentration4
Value
Statistic3
Method3
Exposure Area 1
Sediment - Waterways
cadmium
Urinary, Musculoskeletal
mg/kg
7/7
5.30E+00
5.43E+02
J+
5.40E+02
Maximum Detected Concentration
(5)
Exposure Area 2
Total soil
Lead
NA
mg/kg
80/80
7.90E+00
4.02E+04
J
2.1E+03
Mean Concentration
(3)
Surface Water -
Waterways
cadmium
(dissolved)
Urinary, Musculoskeletal
M9/L
5/5
3.80E-01
J
3.48E+02
3.5E+02
Maximum Detected Concentration
(5)
Surface Water -
Settling Ponds
cadmium
(dissolved)
Urinary, Musculoskeletal
M9/L
3/3
2.25E+01
5.10E+02
5.1E+02
Maximum Detected Concentration
(5)
Sediment - Waterways
cadmium
Urinary, Musculoskeletal
mg/kg
15/15
9.40E+00
8.34E+02
2.4E+02
95% Adjusted Gamma UCL
(2)
Exposure Area 3
Total soil
Antimony
Hematologic
mg/kg
9/16
5.40E-01
J
3.7E+02
J+
2.9E+02
99% KM (Chebyshev) UCL
(1)
Zinc
Immune, Hematologic
mg/kg
16/16
6.11E+01
J
4.69E+04
J
3.3E+04
99% Chebyshev (Mean, Sd) UCL
(1)
Lead
NA
mg/kg
16/16
1.21E+01
J
2.11E+03
J
2.1E+03
Mean Concentration
(3)
Exposure Area 4
Total soil Lead
NA
mg/kg
119/119
6.10E+00
3.20E+04
7.10E+02
Mean Concentration
(3)
Onsite
Groundwater
Aluminum
(Dissolved)
Neurological
M9/L
36/91
2.70E+00
J
4.48E+05
4.5E+05
99% KM (Chebyshev) UCL
(1)
Antimony
Hematologic
M9/L
8/91
2.40E+00
1.43E+01
J
1.4E+01
KM H-UCL
(4)
Arsenic
Cardiovascular, Dermal
M9/L
66/91
3.10E-01
J
1.88E+02
1.9E+02
KM H-UCL
(4)
Barium
(Dissolved)
Urinary
M9/L
79/91
9.60E+00
J
1.45E+04
1.5E+04
95% KM (Chebyshev) UCL
(1)
Beryllium
Gastrointestinal
M9/L
27/91
8.90E-02
J
4.03E+01
J
4.0E+01
95% KM Approximate Gamma UCL
(2)
Cadmium
Urinary, Musculovascular
M9/L
46/91
3.00E-02
J-
6.29E+02
6.3E+02
95% KM Approximate Gamma UCL
(2)
unromium
(Evaluated
as
hexavalent
chromium)
Hematologic
M9/L
67/91
3.10E-01
J
4.66E+03
4.7E+03
95% KM (Chebyshev) UCL
(1)
Cobalt
Thyroid
M9/L
63/91
1.40E-01
J
5.95E+02
6.0E+02
95% KM (Chebyshev) UCL
(1)
Copper
Gastrointestinal
M9/L
70/91
7.00-01
J-
1.43E+04
J+
1.4E+04
95% KM (Chebyshev) UCL
(1)
Iron
Gastrointestinal
M9/L
88/91
3.44E+01
J
9.81 E+05
J+
9.8E+05
KM H-UCL
(4)
Lead
NA
M9/L
68/91
1.60E-01
J
2.99E+03
J
1.0E+02
Mean Concentration
(3)
Manganese,
dissolved
Neurological
M9/L
86/91
2.20E+00
J+
9.12E+05
9.5E+05
KM H-UCL
(4)
Vanadium
Dermal, Hematologic
M9/L
35/91
1.50E-01
J
6.10E+02
6.1E+02
KM H-UCL
(4)
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Table A-2. HUMAN HEALTH RISK ASSESSMENT CHEMICAL OF CONCERN SUMMARY
HEGELER ZINC OPERABLE UNIT 1
DANVILLE, ILLINOIS
Page 2 of 3
Exposure Point
Chemical of
Concern1
Target Organs2
Units
Frequency of
Detection
Minimum
Concentration
Maximum
Concentration
(Qualifier)
Exposure Point Concentration4
Value
Statistic3
Method3
Zinc
Immune, Hematologic
M9/L
90/91
2.10E+00 I
5.83E+04 I
5.8E+04
95% KM (Chebyshev) UCL
(1)
Offsite Residential Use
Groundwater
Antimony
Hematologic
M9/L
1/25
1.60E+01
J
1.60E+01
J
2.9E+01
95% Chebyshev (Mean, Sd) UCL
(1)
Arsenic
Cardiovascular, Dermal
M9/L
20/25
2.80E-01
J
1.40E+01
1.2E+02
95% Chebyshev (Mean, Sd) UCL
(1)
uaumium
(dissolved)
Urinary, Musculovascular
M9/L
10/25
1.70E-01
J
3.50E+02
5.4E+01
95% H-UCL
(4)
uiiomium
(dissolved)
(Evaluated
as
hexavalent
chromium)
Hematologic
M9/L
5/25
1.40E+00
J
5.70E+02
J
1.5E+01
95% Student's-t UCL
(6)
Zinc
Immune, Hematologic
M9/L
13/25
1.10E+01
J
2.80E+04
1.5E+04
95% Student's-t UCL
(6)
Abbreviations:
COC
Chemical of Concern
ELCR
Excell lifetime cancer risk
EPA
U.S. Environmental Protection Agency
EPC
Exposure Point Concentration
KM
Kaplan-Meier
mg/kg
Milligrams per kilogram
NA
Not Available
M9/L
Micrograms per liter
95 UCL
One-sided 95 percent upper confidence limit of the mean
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Table A-2. HUMAN HEALTH RISK ASSESSMENT CHEMICAL OF CONCERN SUMMARY Page 3 of 3
HEGELER ZINC OPERABLE UNIT 1
DANVILLE, ILLINOIS
Notes:
1 Chemicals of Concern (COCs) were identified for the exposure scenario exceeding EPA's acceptable target risk levels (ELCR greater than 10-4 and target organ-specific HI greater than
(a) Cancer: If the cumulative ELCR exceeds 10-4 for a receptor, COCs were identified as individual chemicals greatly contributing the unacceptable risk (i.e., a COPCs with an ELCR
greater than 10-6 for the environmental medium).
(b) Non-Cancer: If a target organ HI exceeds 1, COCs were identified as chemicals with an individual HQ greater than 0.1 contributing to the target organ HI exceeding 1 for the
environmental medium driving the risk.
(c) For surface water and groundwater, either the dissolved or total metals is shown, whichever has the highest EPC.
2 See the references at the bottom of this page for more information on where target organ information came from.
3 Method (Statistic) Codes are defined as follows (some method codes may not be used in the table):
(1) Distribution tests are inconclusive (data are not normlal, log-normal, or gamma-distributed).
(2) Anderson-Darling and/or Kolmogorov-Smirnov Tests indicate data are gamma distributed.
(3) The mean concentration was used for lead.
(4) Shapiro-Wilk W/Lilliefors Test indicates data are log-normally distributed.
(5) The maximum detected concentration was used as the EPC because there were insufficient detections or samples (minimum of 4 detections and 8 samples).
(6) Shapiro-Wilk W/Liliefors Test indicates data are normally distrubted.
4 Ambient air EPC is calculated using a Particulate Emission Factor (PEF) of 1.65 x 109 m3/kg (for Industrial Worker) and 8.86 x 106 (for Construction Worker) as shown below;
derivation of PEF is presented in the report referenced below.
Concentration in ambient air (MG/M3) = Concentration in soil (MG/KG) x [1/PEF (M3/KG)]
References:
CH2M Hill. 2019. "Revised Human Health Risk Assessment, Hegeler Zinc Superfund Site, Operable Unit 1." Danville, Vermilion County,
Illinois. September.
CH2M Hill. 2019. "Humnan Health Risk Assessment for KIK Custom Products." Danville, Vermilion County, Illinois. September.
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Table A-3. Summary of Reasonable Maximum Exposure (RME) Cancer Risks, Hazard
Indices and Chemicals of Concern 0U1 and OU2 Page 1 of 3
Human Health Risk Assessment
HegelerZinc Superfund Site OU1, Vermilion County, Illinois
Carcinogenic
Hazard
Noncarcinogenic
Receptor
Exposure Area
Medium
Exposure Route
ELCR
COCs(a)
Index
COCs (b,c)
Lead Conclusion
Current
Exposure Area 1
Surface Soil
Ing/Derm/lnh
5E-07
0.01
Not a COPC
Trespasser
(Table 9.1)
Surface Water (Waterways)
Ing/Derm
3E-07
0.5
Not a COPC
(Adolescent)
Sediment (Waterways)
Total
Derm
3E-07
1E-06
2
2
Urinary (2): cadmium (Table 10.1)
Not a COPC
Exposure Area 2
Surface Soil
Ing/Derm/lnh
1E-06
0.4
<5% above target BLL
(Table 9.2)
Surface Water (Waterways)
Ing/Derm
9E-07
10
Urinary (10): cadmium (Table 10.2)
EPC < EPA's DWAL
Surface Water (Settling Ponds)
Ing/Derm
1E-05
15
Urinary (15): cadmium (Table 10.2)
Not a COPC
Sediment (Waterways)
Derm
2E-06
1
EPC < industrial soil RSL
Total
2E-05
27
Exposure Area 3
Surface Soil
Ing/Derm/lnh
3E-06
0.4
<5% above target BLL
(Table 9.3)
Total
3E-06
0.4
Future
Exposure Area 1
Total Soil
Ing/Derm/lnh
3E-06
0.02
Not a COPC
Industrial Worker
(Table 9.4)
Surface Water (Waterways)
Derm
5E-08
0.1
Not a COPC
(Adult)
Sediment (Waterways)
Total
Derm
2E-07
3E-06
0.4
0.5
Not a COPC
Exposure Area 2
Total Soil
Ing/Derm/lnh
9E-06
0.7
COC: >5% above target BLL
(Table 9.5)
Surface Water (Waterways)
Derm
2E-07
2
Urinary (2): cadmium (Table 10.3)
EPC < EPA's DWAL
Surface Water (Settling Ponds)
Derm
2E-06
3
Urinary (3): cadmium (Table 10.3)
Not a COPC
Sediment (Waterways)
Derm
9E-07
0.3
EPC < industrial soil RSL
Total
1E-05
7
Exposure Area 3
Total Soil
Ing/Derm/lnh
1E-05
0.9
COC: >5% above target BLL
(Table 9.6)
Total
1E-05
0.9
Onsite
Groundwater
Ing/Derm
2E-02
arsenic
279
Cardiovascular (7): arsenic
COC: EPC > EPA's DWAL
(Table 9.7)
chromium (Cr6+)
(Table 10.4)
Dermal (9): arsenic, vanadium
Gastrointestinal (20): beryllium,
copper, iron
Hematologic (3): antimony, zinc
Immune (2): zinc
Neurological (20): aluminum,
manganese
NOE (32): chromium
Thyroid (21): cobalt
Urinary (173): barium, cadmium
(Table 10.4)
Total
2E-02
279
Future
Construction Worker
(Adult)
Exposure Area 1
(Table 9.8)
Total Soil
Surface Water (Waterways)
Sediment (Waterways)
Total
Ing/Derm/lnh
Derm
Derm
4E-07
3E-09
1E-08
4E-07
0.1
1
7
8
Urinary (7): cadmium (Table 10.5)
Not a COPC
Not a COPC
Not a COPC
Exposure Area 2 Total Soil Ing/Derm/lnh 1E-06
(Table 9.9) Surface Water (Water Ways) Derm 1E-08
Surface Water (Settling Ponds) Derm 1E-07
Sediment (Water Ways) Derm 5E-08
3 none
20 Urinary (20): cadmium (Table 10.6)
28 Urinary (28): cadmium (Table 10.6)
4 Urinary (3): cadmium (Table 10.6)
COC: >5% above target BLL
EPC < EPA's DWAL
Not a COPC
EPC < industrial soil RSL
1 of 2
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Table A-3. Summary of RME Cancer Risks, Hazard Indices and Chemicals of Concern
OU1 page 2 of 3
Human Health Risk Assessment
HegelerZinc Superfund Site OU1, Vermilion County, Illinois
Receptor Exposure Area Medium
Exposure Route
ELCR
Carcinogenic
COCs (a)
Hazard
Index
Noncarcinogenic
COCs (b,c)
Lead Conclusion
Total
1E-06
54
Exposure Area 3
(Table 9.10)
Total Soil
Ing/Derm/lnh
2E-06
Hematologic (2): antimony, zinc (Table
10.7)
COC: >5% above target BLL
Total 2E-06 3
Notes:
Chemicals of Concern (COCs) were identified for the exposure scenario exceeding the EPA's acceptable target risk levels (ELCR greater than 10~4and target organ-specific HI greater than 1).
(a) Cancer: If the cumulative ELCR exceeds 10"4for a receptor, COCs were identified as COPCs with an ELCR greater than 10~6 for the environmental medium).
(b) Noncancer: If a target organ HI exceeds 1, COCs were identified as chemicals with an individual HQ >0.1 for that target organ for the environmental medium driving the risk.
(c) The numbers in parentheses indicate target organ-specific HI.
BLL = blood lead level
COC = chemical of concern
COPC = chemical of potential concern
DWAL = drinking water action level
ELCR = excess lifetime cancer risk
Gl = gastrointestinal
HI = hazard index
NOE = no observed effect
2 of 2
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Appendix A-3. Summary of RME Cancer Risks, Hazard Indices and Chemicals of Concern
Human Health Risk Assessment OU2 Page 3 of 3
KIK Custom Products Inc, Danville, Illinois
Receptor
Medium
Exposure Route
ELCR
Carcinogenic
COCs (a)
Hazard
Index
Noncarcinogenic
COCs (b,c)
Lead Conclusion
Current/Future
Industrial Worker
(Adult)
Surface Soil
Surface Water (Fire Pond)
Sediment (Fire Pond)
Total
Ing/Derm/lnh
Derm
Derm
2E-05
1E-09
1E-07
2E-05
0.2
0.000007
0.01
0.3
<5% above target BLL
Not a COPC
Not a COPC
Current/Future
Trespasser
(Adolescent)
Surface Soil
Surface Water (Lake Harry)
Sediment (Lake Harry)
Total
Ing/Derm/lnh
Derm
Derm
3E-07
7E-09
8E-08
4E-07
0.005
0.0001
0.001
0.007
Not a COPC
Not a COPC
Not a COPC
Future
Industrial Worker
(Adult)
Total Soil
Groundwater
Surface Water (Fire Pond)
Sediment (Fire Pond)
Total
Ing/Derm/lnh
Ing/Derm/lnh
Derm
Derm
4E-05
1E-04
1E-09
1E-07
2E-04
0.5
4
0.000007
0.01
4E+00
Urinary (2) cadmium (Table 10.1)
<5% above target BLL
Not a COPC
Not a COPC
Not a COPC
Future Table 9.4
Construction Worker
(Adult)
Total Soil
Ing/Derm/lnh
5E-06
COC: >5% above target BLL
Current/Future
Offsite Resident
(Adult and Childf
Tables 9.5,9.6
and 9.7
Ing/Derm/lnh
Chromium (Table 10.4)
Urinary (10) cadmium (Table 10.3) COC: >5% above target BLL
Blood (4) antimony, arsenic zinc (Table
10.3)
Notes:
Chemicals of Concern (COCs) were identified for the exposure scenarios exceeding EPA's acceptable risk levels (ELCR > 104 and target organ-specific HI > 1).
(a) Cancer: If the cumulative ELCR exceeds lO^for a receptor, COCs were identified as COPCs with an ELCR greater than 10"6 for the environmental medium.
(b) Noncancer: If a target organ HI exceeds 1, COCs were identified as chemicals with an individual HQ > 0.1 for that target organ for the environmental medium driving the risk
(c) The numbers in parentheses indicate target organ-specific HI.
(d) Reported HI value is from the most sensitive receptor (child)
COC = chemical of concern
COPC = chemical of potential concern
ELCR = excess lifetime cancer risk
Gl = gastrointestinal
HI = hazard index
NOE = no observed effect
-------
Table A-4
CARCINOGENIC & NON-CANCER TOXICITY DATA
Hegeler Zinc
Danville, Illinois
Page 1 of3
Chemical
of Potential
Concern
Chronic/
Subchronlc
Oral RfD
Oral Absorption
Efficiency for Dermal
(1)
Absorbed RfD for Dermal (2)
Primary
Target
Organ(s)
Combined
Uncertainty/Modifying
Factors
RfD:Target Organ(s)
Value
Units
Value
Units
Source(s)
Date(s)
(MM/DD/YYYY)
M'-doo
Chronic
3.0E-05
mg/kg/day
70-90%
3.0E-05
mg/kg/day
Hepatic
300
PPRTV
9/20/2017
4,4'-DDD
Subchronlc
3.0E-05
mg/kg/day
70-90%
3.0E-05
mg/kg/day
Hepatic
300
PPRTV
9/20/2017
4,4'-DDT
Chronic
5.0E-04
mg/kg/day
70-90%
5.0E-04
mg/kg/day
Hepatic
100/1
IRIS
10/18/2018
M'-DOT
Subchronlc
5.0E-04
mg/kg/day
70-90%
5.0E-04
mg/kg/day
Hepatic
100
ATSDR
9/2002
MLPHA-CHLORDANE
Chronic
5.0E-04
mg/kg/day
70-90%
5.0E-04
mg/kg/day
Hepatic
300/1
IRIS
10/18/2018
ALPHA-CHLORDANE
Subchronlc
6.0E-04
mg/kg/day
70-90%
6.0E-04
mg/kg/day
Hepatic
100
ATSDR
5/1994
ALUMINUM
Chronic
1.QE+00
mg/kg/day
100%
1.0E+00
mg/kg/day
Neurological
100
PPRTV
10/23/2006
ALUMINUM
Subchronlc
1.QE+00
mg/kg/day
100%
1.0E+00
mg/kg/day
Neurological
30
ATSDR
9/2008
ANTIMONY
Chronic
4.0E-04
mg/kg/day
15%
6.0E-05
mg/kg/day
Hematologic
1000/1
IRIS
10/18/2018
ANTIMONY
Subchronlc
4.0E-04
mg/kg/day
15%
6.0E-05
mg/kg/day
Hematologic
1000
PPRTV
7/29/2008
ARSENIC
Chronic
3.0E-04
mg/kg/day
95%
3.0E-04
mg/kg/day
Cardiovascular, Dermal
3/1
IRIS
10/18/2018
ARSENIC
Subchronlc
NA
NA
NA
NA
NA
NA
NA
NA
NA
BARIUM
Chronic
2.0E-01
mg/kg/day
7%
1.4E-02
mg/kg/day
Urinary
300/1
IRIS
10/18/2018
BARIUM
Subchronlc
2.0E-01
mg/kg/day
7%
1.4E-02
mg/kg/day
Urinary
300
ATSDR
8/2007
BERYLLIUM
Chronic
2.QE-Q3
mg/kg/day
0.7%
1.4E-05
mg/kg/day
Gastrointestinal
300/1
IRIS
10/18/2018
BERYLLIUM
Subchronlc
5.QE-Q3
mg/kg/day
0.7%
3.5E-05
mg/kg/day
NOE
100
HEAST
7/1997
BROMODiCHLOROM ETHANE
Chronic
2.QE-Q2
mg/kg/day
100%
2.0E-02
mg/kg/day
Urinary
1000/1
IRIS
10/18/2018
BROMODiCHLOROM ETHANE
Subchronlc
8.QE-Q3
mg/kg/day
100%
8.0E-03
mg/kg/day
Reproductive
100
PPRTV
9/16/2009
CADMIUM
Chronic
1.0E-03
mg/kg/day
0.1%
1.0E-06
mg/kg/day
Urinary
10/1
IRIS
10/18/2018
CADMIUM
Subchronlc
5.0E-04
mg/kg/day
0.1%
5.0E-07
mg/kg/day
Musculoskeletal
100
ATSDR
7/1997
CADMIUM (water)
Chronic
5.0E-04
mg/kg/day
0.1%
5.0E-07
mg/kg/day
Urinary
10/3
IRIS
10/18/2018
CADMIUM (water)
Subchronlc
5.0E-04
mg/kg/day
0.1%
5.0E-07
mg/kg/day
Musculoskeletal
100
ATSDR
7/1997
CHLOROFORM
Chronic
1.0E-02
mg/kg/day
100%
1.0E-02
mg/kg/day
Hepatic
100/10
IRIS
10/18/2018
CHLOROFORM
Subchronlc
1.0E-01
mg/kg/day
100%
1.0E-01
mg/kg/day
Hepatic
100
ATSDR
9/1997
CHROMIUM (III)
Chronic
1.5E+00
mg/kg/day
1.3%
2.0E-02
mg/kg/day
NOE
100/10
IRIS
10/18/2018
CHROMIUM (III)
Subchronlc
1.SE+00
mg/kg/day
1.3%
2.0E-02
mg/kg/day
NOE
1000
HEAST
7/1997
CHROMIUM (VI)
Chronic
3.QE-Q3
mg/kg/day
2.5%
7.5E-05
mg/kg/day
NOE
300/3
IRIS
10/18/2018
CHROMIUM (VI)
Subchronlc
5.QE-Q3
mg/kg/day
2.5%
1.3E-04
mg/kg/day
Hematologic
100
ATSDR
9/2012
COBALT
Chronic
3.0E-04
mg/kg/day
100%
3.0E-04
mg/kg/day
Thyroid
3000
PPRTV
8/25/2008
COBALT
Subchronlc
3.0E-03
mg/kg/day
100%
3.0E-03
mg/kg/day
Thyroid
300
PPRTV
8/25/2008
COPPER
Chronic
4.QE-Q2
mg/kg/day
100%
4.0E-02
mg/kg/day
Gastrointestinal
NA
HEAST
7/1997
COPPER
Subchronlc
1.0E-02
mg/kg/day
100%
1.0E-02
mg/kg/day
Gastrointestinal
3
ATSDR
10/2004
DELTA-BHC
Chronte/Subchronlc
NA
NA
NA
NA
NA
NA
NA
NA
NA
[XELDRIN
Chronic
5.0E-05
mg/kg/day
100%
5.0E-05
mg/kg/day
Hepatic
100/1
IRIS
10/18/2018
DIELDRIN
Subchronlc
1.0E-04
mg/kg/day
100%
1.0E-04
mg/kg/day
Neurological
100
ATSDR
9/2002
QAMMA-CHLORDANE
Chronic
5.0E-04
mg/kg/day
80%
5.0E-04
mg/kg/day
Hepatic
300/1
IRIS
10/18/2018
SAMMA-CHLORDANE
Subchronlc
6.0E-04
mg/kg/day
100%
6.0E-04
mg/kg/day
Hepatic
100
ATSDR
5/1994
4EPTACHLOR
Chronic
5.0E-04
mg/kg/day
100%
5.0E-04
mg/kg/day
Hepatic
300/1
IRIS
10/18/2018
HEPTACHLOR
Subchronlc
1.0E-04
mg/kg/day
100%
1.0E-04
mg/kg/day
Immunological
300
ATSDR
8/2007
rIEPTACHLOR EPOXIDE
Chronic
1.3E-05
mg/kg/day
100%
1.3E-05
mg/kg/day
Hepatic
1000/1
IRIS
10/18/2018
HEPTACHLOR EPOXIDE
Subchronlc
1.3E-05
mg/kg/day
100%
1.3E-05
mg/kg/day
Hepatic
1000
HEAST
7/1997
IRON
Chronic
7.0E-01
mg/kg/day
100%
7.0E-01
mg/kg/day
Gastrointestinal
1.5
PPRTV
9/11/2006
IRON
Subchronlc
7.0E-01
mg/kg/day
100%
7.0E-01
mg/kg/day
Gastrointestinal
1.5
PPRTV
9/11/2006
LEAD
Chronlc/Subchronlc
NA
NA
NA
NA
NA
NA
NA
NA
NA
MANGANESE
Chronic
2.4E-Q2
mg/kg/day
4%
9.6E-04
mg/kg/day
Neurological
1/1
IRIS
10/18/2018
MANGANESE
Subchronlc
1.4E-01
mg/kg/day
100%
1.4E-01
mg/kg/day
Neurological
1
HEAST
7/1997
MERCURY
Chronic
3.0E-C4
mg/kg/day
7%
2.1E-05
mg/kg/day
Immune, Urinary
1000
IRIS
10/18/2018
MERCURY
Subchronlc
2.QE-03
mg/kg/day
7%
1.4E-04
mg/kg/day
Urinary
100
ATSDR
3/1999
NICKEL
Chronic
2.QE-Q2
mg/kg/day
4%
8.0E-04
mg/kg/day
Body weight
300/1
IRIS
10/18/2018
NICKEL
Subchronlc
2.0E-02
mg/kg/day
4%
8.0E-04
mg/kg/day
Body weight
300
HEAST
7/1997
PERCHLORATE
Chronic
7.0E-C4
mg/kg/day
100%
7.0E-04
mg/kg/day
Thyroid
10/1
IRIS
10/18/2018
PERCHLORATE
Subchronlc
NA
NA
NA
NA
NA
NA
NA
NA
NA
SELENIUM
Chronic
5.QE-Q3
mg/kg/day
30-80%
5.0E-03
mg/kg/day
Dermal, Hematologic, Neurological
3/1
IRIS
10/18/2018
SELENIUM
Subchronlc
5.QE-Q3
mg/kg/day
30-80%
5.0E-03
mg/kg/day
Dermal, Hematologic, Neurological
3
HEAST
7/1997
SILVER
Chronic
5.QE-03
mg/kg/day
4%
2.0E-04
mg/kg/day
Dermal
3/1
IRIS
10/18/2018
SILVER
Subchronlc
5.QE-Q3
mg/kg/day
4%
2.0E-04
mg/kg/day
Dermal
3
HEAST
7/1997
VANADIUM
Chronic
5.0E-03
mg/kg/day
2.6%
1.3E-04
mg/kg/day
Dermal
100/1
IRIS
10/18/2018
VANADIUM
Subchronlc
1.QE-C2
mg/kg/day
2.6%
2.6E-04
mg/kg/day
Hematologic
10
ATSDR
9/2012
ZINC
Chronic
3.0E-01
mg/kg/day
100%
3.0E-01
mg/kg/day
Immune, Hematologic
3/1
IRIS
10/18/2018
ZINC
Subchronlc
3.0E-01
mg/kg/day
100%
3.0E-01
mg/kg/day
Hematologic
3
ATSDR
9/2005
-------
Table A-4
CARCINOGENIC & NON-CANCER TOXICITY DATA
Hegeler Zinc
Danville, Illinois Page2of3
Chemical
Chronic/
Oral RfD
Oral Absorption
Absorbed RfD for Dermal (2)
Primary
Combined
RfD:Target Organ(s)
of Potential
Subchronlc
Efficiency for Dermal
Target
Uncertainty/Modifying
Concern
Value
Units
(1)
Value
Units
Organ(s)
Factors
Source(s)
Dats(s)
(MM/DD/YYYY)
(1) Source: Risk Assessment Guidance for Superfund. Volume 1: Human Health
Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment) Final.
Section 4.2 and Exhibit 4-1. USEPA recommends tftat the oral RfD should not be adjusted to
estimate the absorbed dose for compounds when the absorption efficiency Is greater than 50%.
Constituents that do not have oral absorption efficiencies reported on this table
were assumed to have an oral absorption efficiency of 100%.
(2) Adjusted based on RAGS Part E.
The toxicity values for Chlordane were used for alpha- and gamma-Chlordane.
The toxicity values for hexachlorocyclohexane, technical were used for delta-BHC.
The toxicity values for Mercuric chloride were used for Mercury.
The toxicity values for Chromium (III) were used for Chromium In soil and sediment.
The toxicity values for Chromium (VI) were used for Chromium In surface water and
ATSDR = Agency for Toxic Substances & Disease Registry Minimal Risk Levels
HEAST = Health Effects Summary Tables
IRIS = Integrated Risk Information System
PPRTV = Provisional Peer-Reviewed Toxicity Value
CNS = Central Nervous System
G! = Gastrointestinal
NOE = No Observed Effect
NA = Not Available
-------
Table A-4
CARCINOGENIC & NON-CANCER TOXICITY DATA
Hegeler Zinc
Chemical
of Potential
Concern
Oral Cancer Slope Factor
Oral Absorption
Efficiency for Dermal
(1)
Absorbed Cancer Slope Factor
for Dermal (2)
Weight of Evidence/
Cancer Guideline
Description
Oral CSF
Value
Units
Value
Units
Source(s)
Date(s)
(MM/DD/YYYY)
M'-DDO
2.4E-01
(mg/kg/day)'1
100%
2.4E-01
(mg/kg/day)'1
B2
IRIS
10/18/2018
M'-DDT
3.4E-01
(mg/kg/day)'1
70-90%
3.4E-01
(mg/kg/day)'1
B2
IRIS
10/18/2018
ALPHA-CHLORDANE
3.5E-01
(mg/kg/day)'1
80%
3.5E-01
(mg/kg/day)'1
Known/likely human carcinogen
IRIS
10/18/2018
ALUMINUM
NA
NA
NA
NA
NA
NA
NA
NA
ANTIMONY
NA
NA
NA
NA
NA
NA
NA
NA
ARSENIC
1.5E+00
(mg/kg/day)'1
95%
1.5E+00
(mg/kg/day)'1
A
IRIS
10/18/2018
3ARIUM
NA
NA
NA
NA
NA
D
NA
NA
BERYLLIUM
NA
NA
NA
NA
NA
NA
NA
NA
SROMODICHLOROM ETHANE
6.2E-02
(mg/kg/day)'1
100%
6.2E-02
(mg/kg/day)'1
B2
IRIS
10/18/2018
CADMIUM
NA
NA
NA
NA
NA
NA
NA
NA
CHLOROFORM
3.1E-02
(mg/kg/day)'1
100%
3.1E-02
(mg/kg/day)'1
likely to be carcinogenic to humans
Cal/EPA
10/18/2018
CHROMIUM (ill)
NA
NA
NA
NA
NA
NA
NA
NA
CHROMIUM (VI) (3)
5.0E-01
(mg/kg/day)'1
2.5%
2.0E+01
(mg/kg/day)'1
Known/likely (inhalation) cannot determine (oral)
Cal EPA
10/18/2018
COBALT
NA
NA
NA
NA
NA
NA
NA
NA
COPPER
NA
NA
NA
NA
NA
NA
NA
NA
DELTA-BHC
1.8E+00
(mg/kg/day)'1
100%
1.8E+00
(mg/kg/day)'1
B2
IRIS
10/18/2018
DIELDRIN
1.6E+01
(mg/kg/day)'1
100%
1.6E+01
(mg/kg/day)'1
B2
IRIS
10/18/2018
GAMMA-CHLORDANE
3.5E-01
(mg/kg/day)'1
80%
3.5E-01
(mg/kg/day)'1
Known/likely human carcinogen
IRIS
10/18/2018
HEPTACHLOR
4.5E+00
(mg/kg/day)'1
100%
4.5E+00
(mg/kg/day)'1
B2
IRIS
10/18/2018
4EPTACHLOR EPOXIDE
9.1E+00
(mg/kg/day)'1
100%
9.1E+00
(mg/kg/day)'1
B2
IRIS
10/18/2018
IRON
NA
NA
NA
NA
NA
NA
NA
NA
LEAD
NA
NA
NA
NA
NA
NA
NA
NA
MANGANESE
NA
NA
NA
NA
NA
D
IRIS
10/18/2018
MERCURY
NA
NA
NA
NA
NA
NA
NA
NA
NICKEL
NA
NA
NA
NA
NA
NA
NA
NA
PERCHLORATE
NA
NA
NA
NA
NA
NA
NA
NA
SELENIUM
NA
NA
NA
NA
NA
NA
NA
NA
SILVER
NA
NA
NA
NA
NA
NA
NA
NA
VANADIUM
NA
NA
NA
NA
NA
NA
NA
NA
ZINC
NA
NA
NA
NA
NA
NA
NA
NA
(1) Source: Risk Assessment Guidance for Superfond. Volume 1: Human Health Definitions: Cal/EPA = California Environmental Protection Agency
Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment) Final. IRIS = Integrated Risk Information System
Section 4.2 and Exhibit 4-1. USEPA recommends that the oral slope factor should not be adjusted to NA = Not Available
estimate the absorbed dose for compounds when the absorption efficiency is greater than 50%.
Constituents that do not have oral absorption efficiencies reported on this table
were assumed to have an oral absorption efficiency of 100%.
(2) Adjusted based on RAGS Part E.
(3) This chemical operates with a mutagenic mode of action (USEPA 2005) and would exhibit a greater effect in early-life versus later-life exposure.
Chemical-specific toxicity data are not availablefor childhood and early-life exposures; thus, EPA (2005) default age-dependant adjustment factors (ADAF) will be applied to the slope factor as follows:
AGE
AGE ADAF
0-<2
10
2-«16
3
16-«26
1
The toxicity values for Chbrdane were used for alpha- and gamma-Chlordane.
The toxicity values for Chromium (ill) were used for Chromium in soil and sediment.
The toxicity values for Chromium (VI) were used for Chromium in surface water and groundwater.
Weight of Evidence definitions:
Group A chemicals (known human carcinogens) are agents for which there is sufficient evidence to support the causal association between exposure to the agents in humans and cancer.
Group B1 chemicals (probable human carcinogens) are agents for which there is limited evidence of possible carcinogenicity in humans.
Group B2 chemicals (probable human carcinogens) are agents for which there is sufficient evidence of carcinogenicity in animals but inadequate or a lack of evidence in humans.
Group C chemicals (possible human carcinogens) are agents for which there is limited evidence of carcinogenicity in animals and inadequate or a lack of human data.
Group D chemicals (not classifiable as to human carcinogenicity) are agents with inadequate human and animal evidence of carcinogenicity or for which no data are available.
Group E chemicals (evidence of noncarcinogeniciy in humans) are agents for which there is no evidence of carcinogenicity from human or animal studies, or both.
-------
Table A-5 Summary of Affected Media, Receptors, Pathways, and COCs/COECs
Adapted from Feasibility Study Report OU1
Hegeler Zinc Superfund Site, Vermilion County, Illinois
Media
Receptors
Pathways
COCs/COECs
Soil/Slag
Surface Soil (0-2 ft bgs)a and unsaturated subsurface
soil (> 2 ft bgs): future construction workers exposure
area 3
Human health exposure via dermal
contact, ingestion, and inhalation
pathways
Antimony and zinc
Surface Soil (0-2 ft bgs)a and unsaturated subsurface
soil (> 2 ft bgs): future construction workers and/or
industrial workers exposure areas 2, 3, and 4
Lead
Surface Soil ( 0-2 ft bgs): terrestrial habitat receptors:
plants, soil invertebrates, terrestrial mammals and
birds, amphibians and reptiles
Ecological exposure via direct contact or
ingestion pathways
Aluminum, antimony, lead, mercury,
vanadium, and zinc
Sediment
0-1 foot bgs: trespassers (exposure area 1 creek) and
construction workers (exposure areas 1 and 2 creek)
Human health exposure via dermal
contact, ingestion, and inhalation
Cadmium
0-0.5 ft bgs: aquatic habitat receptors: fish and water
column biota, benthic invertebrates, semi-aquatic
mammals and birds, amphibians and reptiles
Ecological exposure via direct contact or
ingestion pathways
Aluminum, cadmium, lead, manganese,
and zinc
Groundwater
Onsite industrial worker and offsite residents exposure
areas 1, 2, and 3
Human health exposure via drinking
water or household use or industrial use
inhalation pathways
Total and dissolved metals: aluminum,
antimony, arsenic, barium, beryllium,
cadmium, chromium, cobalt, copper, iron,
lead, manganese, vanadium, and zinc
Onsite industrial worker and offsite residents exposure
area 4
Total and dissolved metals: antimony,
arsenic, cadmium, chromium, lead, and
zinc
Surface Water
Trespassers, construction and industrial workers
exposure area 2 settling ponds and creek
Human health exposure via dermal
contact, ingestion, and inhalation
pathways
Total and dissolved cadmium
Aquatic habitat receptors: fish and water column
biota, benthic invertebrates
Ecological exposure via direct contact or
ingestion pathways
Dissolved metals: aluminum, cadmium,
lead, manganese, and zinc
Notes:
Shaded rows identify media affected for ecological receptors.
Human Health Exposure Areas are shown on Figure 2-5 of this report.
COC = chemical of concern
COEC = chemical of ecological concern
ft bgs = feet below ground surface
a COCs identified in total soil (0-10 feet bgs) for future industrial workers and construction workers were also identified as COC for surface soil (0-2 feet bgs) since
surface soil is included within the total soil depth interval.
Page 1 of 1
-------
Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
C'lit'iiiical-specific ARARs.'THL \
Soil and Sin"
IAC Title 35, Part 742, Appendix A, and
Appendix B, Table B & E TACO
TACO establishes a framework for determining soil and groundwater remediation
objectives and standards, and for establishing institutional controls. Tier 1
remediation objectives are set at
10 ELCR and hazard index = 1 values. Section 742.900(d) Tier 3 remediation
objectives allows cleanup levels within the ELCR range of 10 to 10 .
TBC
TACO is a voluntary program and is not required (Part 742.105
(a)). It provides guidance for development of site-specific soil and
groundwater remediation objectives. It may be considered in
establishing PRGs. The PRG for vanadium in soil is the TACO
background level of counties outside metropolitan statistical areas
in Illinois.
Sediment
EPA Regional Screening Level Table for
Chemical Contaminants at Superfund
Sites - Soil
Screening levels developed using risk assessment guidance from the EPA
Superfund program. They are risk-based concentrations derived from standardized
equations combining exposure information assumptions with EPA toxicity data.
Screening levels are considered to be protective for humans over a lifetime,
however, screening levels do not address non-human health endpoints, such as
ecological impacts.
TBC
Levels may be considered for use as initial cleanup goal.
EPA Region 5 RCRA Ecological
Screening Levels
Presents screening values for freshwater sediments.
TBC
Levels may be used for developing PRGs for soil ecological risk.
Development and Evaluation of
Consensus-Based Sediment Quality
Guidelines for Freshwater Ecosystems.
MacDonald D.D., C. G. Ingersoll,
T. A. Berger
Presents sediment quality guidelines for freshwater ecosystems.
TBC
Site-specific sediment cleanup objectives are being developed for
the site in accordance with the CERCLA process and as described
in the report.
NOAA Screening Quick Reference Tables
Compilation of screening level assessment benchmarks for multiple media types.
TBC
Levels may be used for developing PRGs for soil ecological risk.
Croundwalcr
35 IAC Part 620: Groundwater Quality
These regulations provide the standards for groundwater quality in Illinois.
Applicable
Groundwater is classified as Class I
Surface Water
35 111. Adm. Code 303.201. Surface \\ aler
Remedial Goals
Surface waler remedial goals were based on the chronic standard of Illinois
General Use Water Quality Standards (IAC Section 302.208 (e)) for Waters of the
State for which there is no specific designation.
Applicable
Prolecli\ e of aquatic life in the waterways.
Location-specific ARARs. TBC \
National Historic Preservation Act,
Section 106
54 USC § 306108
Requires federal agencies to consider the effects of federally funded projects on
historic properties and to afford the Advisory Council on Historic Preservation an
opportunity to comment on such projects prior to the expenditure of any Federal
funds on the undertaking.
Not a
CERCLA
ARAR but
will be
followed.
The presence of historic resources, including archeological sites,
was evaluated during the remedial design. The 111 inoi s Hi storic
Preservation Agency was consulted ana concurred that no historic
properties within OU1 will be affected. The SHPO has required
that a survey be conducted of any borrow areas once they are
identified (Appendix B).
Illinois Endangered Species Protection
Act
IAC Title 17 Part 1075, Endangered
Species
Prohibits actions that are likely to jeopardize the continued existence of listed
species or result in the destruction or adverse modification of critical habitat. If
remediation is within critical habitat or buffer zones surrounding threatened or
endangered species, mitigation measures must be taken to protect the resource.
Not a
CERCLA
ARAR but
will be
followed.
Based on a review performed in 2011, no threatened or endangered
species or their habitats were observed onsite. An updated
threatened and endangered species review will be conducted during
the remedial design. If threatened or endangered species are
identified as potentially present in areas where remedial actions
will occur, measures will be specified to confirm the presence, and
avoid or mitigate the adverse effects.
765 ILCS 122: Illinois Uniform
Environmental Covenants Act
The purpose of an environmental covenant is to ensure that land use restrictions
and engineering controls designed to control the potential environmental risk of
residual contamination will be recorded in the land records and enforced over
time, perpetually if necessary, while allowing that real estate to be conveyed from
one person to another subject to those controls.
TBC
Applicable to groundwater while levels exceed acceptable risk.
Applicable to the slag pile consolidation area. May also be
applicable to other areas of the site if residual contamination
remains onsite at levels that do not allow for unlimited use and
unrestricted exposure after cleanup.
PAGE 10F 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
ILR10
IEPA implements the NPDES program and the associated stormwater
management requirements.
Substantive
Requirements
Applicable
Applicable to runoff from construction activities that disturb more
than 1 acre of land. Substantive requirements of NPDES Permit
No. ILR10 General Permit for Stormwater Discharges from
Construction Site Activities would be met.
17 IAC 3700 and 3706
Construction in Floodplains
The substantive requirements of an Illinois DNR Office of Water Resources
floodway construction permit will need to be met for work occuring in the creek.
Substantive
Requirements
Applicable
Applicable to work within the channel and/or floodplain of the
creek within this Site falls within Illinois DNR jurisdiction with
respect to the Rules for Construction in Floodway s of Rivers,
Lakes, and Streams (17 IAC 3700).
Even if a floodplain is not identified on Federal Emergency
Management Agency (FEMA) maps, Illinois DNR still has
jurisdiction based on drainage area. The drainage area of Grape
Creek and tributaries at the downstream end of the site is
approximately 4.2 square miles. Illinois DNR has jurisdiction on
streams with a drainage area greater than 1 square mile in an urban
area such as this.
Action Specific. 1R. 1 Rs
l-'ederal
Section 401 of the CWA, proper
discharge limits for water generated
during wet dredging.
Section 404 of the CWA, proper
management of dredging activities.
Authorizes the discharge of dredged or fill material into waters (including
wetlands) of the United States by establishing performance standards and
conditions to protect the aquatic environment. US ACE and EPA regard the use of
mechanized earth-moving equipment in waters of the United States as resulting in
a discharge of dredged material unless project-specific evidence shows that the
activity results in only incidental fallback.TNIo discharge of dredged or fill material
may be permitted if: (l) a practicable alternative exists that is less damaging to the
aquatic environment, or (2) the nation's waters would be significantly degraded.
Requires that steps be taken to avoid to the extent practicable, adverse effects,
especially on aquatic ecosystems and to provide compensation for any remaining
unavoidable impacts. Consultation regarding threatened and endangered species
also may occur
Establishes site-specific constituent limitations designed to protect surface water
quality. Types of discharges regulated under CWA include discharge to surface
water or ocean, indirect discharge to POTW, and discharge of dredged or fill
material into Waters of the United States.
Establishes performance standards and water quality standards for the discharge of
dredged or fill material into U.S. waters that may impact habitat and adversely
affect the biological productivity of wetlands/aquatic ecosystems by smothering,
by dewatering, by permanently flooding, or by altering substrate elevation or
periodicity of water movement
Applicable
Grape Creek, the Unnamed Creek (Tributary), and KIK Culvert are
considered to be waters of the United States due to the connection
to the Vermillion River. KIK Culvert and the Un-named creek will
be dredged as part of the remedy. A riparian zone and wetlands
may exist along the unnamed creek and/or near the settling ponds,
Lake Harry, and the fire water pond. Per US ACE Regulatory
Guidance Letter 85-07, the EPA will be the lead agency at this
CERCLA site in determining which water bodies are regulated, and
if so what measures are appropriate for compliance with the
regulations. If regulated, suostantive requirements are likely to
include measures to minimize resuspension of sediments and
erosion of sediments during excavation of sediments or creek
realignment. Mitigation measures may also be required for
regulated wetlands, if present, or for the pond, if altered.
401 will require proper discharge limits for water generated during
wet dredging. 404 will require proper management of the dredging
activities.
Federal Water Pollution Control Act as
amended by the CWA of 1977, Section
401 Water Quality Certification
Requires compliance with discharge limitations for discharge to waters, including
water quality effluent limits and water quality standards.
Applicable
Compliance with CWA Section 401 requirements is mandatory for
all projects regulated under Section 404, and substantive
requirements are applicable for actions involving rerouting of the
stream and disturbances such as excavation or dredging of
sediment.
IVaste Characterization under the
Resource Conservation and Recovery Act
(RCRA)
PAGE 2 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
RCRA Hazardous Waste Management
Regulations
40 CFR Parts 260 - 262
These regulations provide definitions of terms, general standards, and overview
information
applicable to the hazardous waste management system, identify those solid wastes
which are
subject to regulation as hazardous wastes and which are subject to the notification
requirements
of section 3010 of RCRA, and establish standards for generators of hazardous
waste as defined by
40 CFR 260.10.
Applicable
Should Hazardous Waste be generated and not excluded due to
being regulated
under Section 404 of the Clean Water Act (35 IAC 721 .104(g)),
these regulations
will provide requirements for subsequent treatment, storage, and
disposal of
the waste.
40 C.F.R.§ 262.11(a), (b), and (c)
Characterization of solid waste (all
primary and secondary wastes) (for waste
excavated from Site)
Must determine if solid waste is a hazardous waste using the following method:
• Should first determine if waste is excluded from regulation under 40 C.F.R.§
261.4; and
Must then determine if waste is listed as a hazardous waste under subpart D
40 C.F.R.§ 261.
Relevant
and
Appropriate
Generation of solid waste as defined in 40 C.F.R.§ 261.2
40 C.F.R.§ 262.11 (d)
Must determine whether the waste is (characteristic waste) identified in subpart C
of 40 C.F.R.§ 261 by either:
(1) Testing the waste according to the methods set forth in subpart C of 40
C.F.R.§ 261, or according to an equivalent method approved by the Administrator
under 40 C.F.R.§ 260.21; or
(2) Applying knowledge of the hazard characteristic of the waste in light of the
material^ or the processes used.
Relevant
and
Appropriate
Generation of solid waste which is not excluded under 40 C.F.R.S
261.4(a)
40 C.F.R.§ 264.13(a)(1)
Characterization of hazardous waste (all
primary and secondary wastes) (for waste
excavated from the Site that exceeds
TCLP criteria)
Must obtain a detailed chemical and physical analysis on a representative sample
of the waste(s), which at a minimum contains all the information that must be
known to treat, store, or dispose of the waste in accordance with pertinent sections
of 40 C.F.R.f 264 and 268.
Relevant
and
Appropriate
Generation of RCRA hazardous waste for storage, treatment or
disposal
II ash' Storage — Primary II aste (e.g..
excavated soils, sediments, sludge, debris)
and Secondary Wastes (e.g.. treatment
residuals and wastewaters)
40 C.F.R.§ 262.17(a)(5)(i)(A) and (C)
Temporary on-site storage of hazardous
waste in containers
A generator may accumulate hazardous waste at the facility provided that:
• container is marked with the words "hazardous waste";
and
the date upon which accumulation begins is clearly marked and visible for
inspection on each container.
Relevant
and
Appropriate
Accumulation of RCRA hazardous waste on site as defined in 40
C.F.R.§ 260.10
PAGE 3 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
40 C.F.R.§ 265.171 - Use and
management of hazardous waste in
containers
If container is not in good condition (e.g., severe rusting, structural defects) or if it
begins to leak, must transfer waste from this container to a container that is in
good condition.
Relevant
and
Appropriate
Storage of RCRA hazardous waste in containers
40 C.F.R.§ 265.172
Must use container made or lined with materials compatible with waste to be
stored so that the ability of the container to contain is not impaired.
Relevant
and
Appropriate
Storage of RCRA hazardous waste in containers
40 C.F.R.§ 265.173(a) and (b)
Containers must be closed during storage, except when necessary to add/remove
waste.
Container must not be opened handled and stored in a manner that may rupture
the container or cause it to leak.
Relevant
and
Appropriate
Storage of RCRA hazardous waste in containers
Waste t ransportation — Primary and
Secondary II astes
40 C.F.R.§ 262.10(h).
Transportation of hazardous waste off-site
- action specific
Must comply with the generator standards of Part 262 including 40 C.F.R.§
262.20-23 for manifesting, Sect. 262.30 for packaging, Sect. 262.31 for labeling,
Sect. 262.32 for marking, Sect. 262.33 for placarding,
Not
CERLA
ARAR but
will be
followed.
Preparation and initiation of shipment of hazardous waste off-site -
49 C.F.R.§ 171.1(c)
Transportation of hazardous materials off-
site- action specific
Shall be subject to and must comply with all applicable provisions of the HMTA
and HMR at 49 C.F.R.§ 171-180 related to marking, labeling, placarding,
packaging, emergency response, etc.
Not
CERLA
ARAR but
will be
followed.
Any person who, under contract with a department or agency of the
federal government, transports "in commerce," or causes to be
transported or shipped, a hazardous material
40 C.F.R.§ 261.4(d)(l)(i)-(iii)
Transportation of samples (i.e.,
contaminated soils and wastewaters) -
action specific
Are not subject to any requirements of 40 C.F.R.Parts 261 through 268 or 270
when:
• the sample is being transported to a laboratory for the purpose of testing; or
• the sample is being transported back to the sample collector after testing.
the sample is being stored by sample collector before transport to a lab for testing
Not
CERLA
ARAR but
will be
followed.
Samples of solid waste or a sample of water, soil for purpose of
conducting testing to determine its characteristics or composition
40 C.F.R.§ 261.4(d)(2)(i) and (ii)(A) and
(B)
In order to qualify for the exemption in paragraphs (d)(l)(i) and (ii), a sample
collector shipping samples to a laboratory must:
• Comply with U.S. DOT, U.S. Postal Service, or any other applicable shipping
requirements or
• Assure that the information provided in (1) thru (5) of this section
accompanies the sample and package the sample so that it does not leak, spill,
or vaporize from its packaging.
Package the sample so that it does not leak, spill, or vaporize from its packaging
Not
CERLA
ARAR but
will be
followed.
Samples of solid waste or a sample of water, soil for purpose of
conducting testing to determine its characteristics or composition
II ash' Management — Remedial. 1 ction
Implementation
35IAC Part 212.301: Visible and
Particulate Matter Emissions, Subpart K:
Fugitive Particulate Matter Particulate
emissions prohibitions - action specific
Prohibits emission of fugitive particulate matter from any process including
material handling
Applicable
Site materials that may become emissions
PAGE 4 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
Dredging and Discharges of Pollutants
into \avigable Waters
National Pollutant Discharge Elimination
System (NPDES), 33 U.S.C 1342 and 40
CFR Part 122
Regulates discharges of pollutants to navigable waters
Applicable
Contaminated material remains on-site that may impact surface
water run-off
Stormwater discharges associated with construction activity
disturbing 1 acre ofland or more.
35 IAC Part 302: Water Quality Standards
Subpart B: General Use Water Quality
Standards
Establishes general use standards to protect Illinois water for aquatic life, wildlife,
agricultural use, primary and secondary contact uses, most industrial uses, and to
ensure the aesthetic quality of the aquatic environment
Applicable
Point source discharges of water to waters of the state such as to
Grape Creek are prohibited from violating water quality standards.
Treatment of such water may be necessary to comply.
IAC Title 35, Part 304 Effluent
Standards, Subpart A General Effluent
Standards
Prescribes the maximum concentrations of various contaminants that may be
discharged to the waters of the State. Subpart A contains general effluent
limitations.
Applicable
Point source discharges of water to waters of the state such as to
Grape Creek are required to comply with general effluent
limitations. Treatment of such water may be necessary to comply.
(ieneral Standards . \sbestos
Demolition. Collection. Packaging and
Disposal
40 CFR § 61.150(a)
Activities potentially causing asbestos
emissions - action specific
Discharge no visible emissions to the outside air during the collection, processing
(including incineration), packaging and transporting of any asbestos-containing
material generated by the source or use one of the emission control and waste
treatment methods specified in paragraphs (a)(1) through (4) of this section.
Applicable
Owner or operator of any source covered under the provisions of §
61.145 Standardfor demolition and renovation
40 CFR § 61.15 0(a)( 1 )(i) - (v)
Emission control methods - action
specific
Adequately wet asbestos-containing waste material as follows:
• Mix control device asbestos waste to form a slurry; adequately wet other
asbestos-containing waste material; and
• Discharge no visible emissions to the outside air from collection, mixing,
wetting, and handling operations, or use the methods specified by § 61.152
to clean emissions containing particulate asbestos material before they
escape to, or are vented to, the outside air; and
• After wetting, seal all asbestos-containing waste material in leak-tight
containers while wet; or, for materials that will not fit into containers
without additional breaking, put materials into leak-tight wrapping; and
• Label the containers or wrapped materials specified in paragraph (a)(l)(iii)
of this section using warning labels specified by Occupational Safety and
Health Standards of the Department of Labor, Occupational Safety and
Health Administration (OSHA) under 29 CFR 1910.1001(j)(4) or
1926.1101(k)(8). The labels shall be printed in letters of sufficient size and
contrast so as to be readily visible and legible.
For asbestos-containing waste material to be transported off the facility site label
containers or wrapped materials with the name of the waste generator and the
location at which the waste was generated.
Applicable
Owner or operator of any source covered under the provisions of §
61.145 Standardfor demolition and renovation
PAGE 5 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
40 CFR § 61.150(a)(2)(i) and (ii)
Emission control for processing - action
specific
Process asbestos-containing waste material into nonfriable forms as follows:
(i) Form all asbestos-containing waste material into nonfriable pellets or other
shapes;
Discharge no visible emissions to the outside air from collection and processing
operations, including incineration, or use other method specified in § 61.152 to
clean emissions containing particulate asbestos material before they escape to, or
are vented, the outside air.
Applicable
Owner or operator of any source covered under the provisions of §
61.145 Standardfor demolition and renovation
40 CFR § 61.150(a)(3)
Emission control for asbestos-containing
waste after demolition
Adequately wet the asbestos-containing waste material at all times after
demolition and keep wet during handling and loading for transport to a disposal
site.
Asbestos-containing waste materials covered by this paragraph do not have to be
sealed in leak-tight containers or wrapping but may be transported and disposed of
in bulk.
Applicable
Facilities demolished where RACM (as defined in 40 CFR §
61.1411 is not removed prior to demolition according to
|6L 145(c^l)(i)-(iv) or for facilities demolished according to §
40 CFR § 61.150(b)(l)-(3)
Disposal of asbestos-containing waste
material - action specific
All asbestos-containing waste material shall be deposited as soon as practicable by
the waste generator at:
A waste disposal site operated in accordance with the provisions of § 61.154, or
An EPA-approved site that converts RACM and asbestos-containing waste
material into non asbestos (asbestos-free) material according to the provisions of §
61.155.
The requirements of paragraph (b) of this section do not apply to Category I
nonfriable ACM that is not RACM.
Relevant
and
Appropriate
Owner or operator of any source covered under the provisions of §
61.145 Standardfor demolition and renovation
IAC Title 35, Part 228.141 Asbestos
Requirements to limit asbestos emissions from a variety of sources including
demolition.
Applicable
Fifty-nine site structures were evaluated for the presence of ACM
in 2006. ACM was identified in several structures and quantities
estimated. The remedial design would include proper identification,
removal, and handling of ACM.
Standards for Denudition and
Renovation. \ctivity
40 CFR § 61.145(a)
Prior to the commencement of the demolition or renovation, thoroughly inspect
the affected facility or part of the facility where the demolition or renovation
operation will occur for the presence of asbestos, including Category I and
Category II nonfriable ACM.
The requirements of paragraphs (b) and (c) of § 61.145 apply to each owner or
operator of a demolition or renovation activity, including the removal of RACM.
NOTE: Thq Notification requirements of paragraph (b) of § 61.145 are considered
"administrative' and therefore not identified as ARARs. However, some of the
information included in the notice, for example a description of work to be
performed and methods to be employed, work practices and engineering controls
used to comply with the requirements of Subpart M, including asbestos removal
and waste-handling emission control procedures should be included in the
CERCLA decision document (e.g., ROD, Action Memorandum) and/or a
subsequent Remedial Action or Removal Action Work Plan.
Applicable
Demolition or renovation of a facility which may cause a
disturbance of friable asbestos material and exceed the thresholds
in 40 CFR 61.145(a)(1)
PAGE 6 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
40 CFR§ 61.145(a)(1)
In a facility being demolished, all the requirements of paragraphs (b) and (c) of §
61.145 apply, except as provided in paragraph (a)(3) of § 61.145, if the combined
amount of RACM is
(i) At least 80 linear meters (260 linear feet) on pipes or at least 15 square
meters (160 square feet) on other facility components, or
(ii) At least 1 cubic meter (35 cubic feet) of facility components where the
length or area could not be measured previously.
NOTE: Thq Notification requirements of paragraph (b) of § 61.145 are considered
"administrative' and therefore not identified as ARARs.
Applicable
Demolition of a facility which may cause a disturbance of friable
asbestos material
40 CFR § 61.145(c)(l)(i)-(iv)
Remove all RACM from a facility being demolished or renovated before any
activity begins that would break up, dislodge, or similarly disturb the material or
preclude access to the material for subsequent removal.
RACM need not be removed before demolition if:
(i) It is Category I nonfriable ACM that is not in poor condition and is not
friable.
(ii) It is on a facility component that is encased in concrete or other similarly
hard material and is adequately wet whenever exposed during demolition;
or
(iii) It was not accessible for testing and was, therefore, not discovered until
after demolition began and, as a result of the demolition, the material
cannot be safely removed. If not removed for safety reasons, the exposed
RACM and any asbestos-contaminated debris must be treated as asbestos-
containing waste material and adequately wet at all times until disposed of.
They are Category II nonfriable ACM and the probability is low that the materials
will become crumbled, pulverized, or reduced to powder during demolition.
Applicable
Demolition or renovation of a facility which may cause a
disturbance of friable asbestos material and exceed the thresholds
in 40 CFR 61.145(a)(1)
40 CFR § 61.145(c)(6)(i)-(iv)
For all RACM, including material that has been removed or stripped:
(i) Adequately wet the material and ensure that it remains wet until collected
and contained or treated in preparation for disposal in accordance with §
61.150.
(ii) Carefully lower the material to the ground and floor, not dropping,
throwing, sliding, or otherwise damaging or disturbing the material.
(iii)Transport the material to the ground via leak-tight chutes or containers if it
has been removed or stripped more than 50 feet above ground level and
was not removed as units or in sections.
RACM contained in leak-tight wrapping that has been removed in accordance
with paragraphs (c)(4) and (c)(3)(i)(B)(3) of § 61.145 need not be wetted.
Applicable
Generation of RACM (as defined in 40 CFR § 61.141), from
demolition or renovation of a facility
PAGE 7 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
40 CFR § 61.145(c)(7)(i)-(ii)
The owner or operator need not comply with paragraph § 61.145(c)(2)(i) and the
wetting provisions of § 61.145(c)(3).
Shall remove facility components containing, coated with, or covered with RACM
as units or in sections to the maximum extent possible.
NOTE: Under § 61.145(c)(7)(iii), must record the temperature in the area
containing the facility components at the beginning, middle and end of each
workday and keep daily temperature records available for inspection.
Recordkeeping requirements are generally considered "administrative' and
therefore not identified as ARARs.
Applicable
Removal of RACM (as defined in40 CFR § 6L141) when the
temperature at the point of wetting is below 0°C (32 °F)
Cupping . 1 sbcstos 11 astc In Place
40 CFR § 61.151 (a)( 1 )-(3 )
Standards for inactive asbestos waste
disposal sites - action specific
Must comply with one of the following:
• Either discharge no visible emissions to the outside air from an inactive
disposal site subject to this paragraph; or
• Cover the asbestos-containing waste material with at least 15 centimeters
(6 inches) of compacted non asbestos containing material, and grow and
maintain a cover of vegetation on the area to prevent exposure of the
asbestos-containing waste material; or
Cover the asbestos-containing waste material with at least 60 centimeters (2 feet)
of compacted non asbestos containing material, and maintain it to prevent
exposure of the asbestos-containing waste
Relevant
and
Appropriate
Closure of an area that received asbestos- containing waste
materials - relevant and appropriate
40 CFR § 61.151(b)(1)
Warning signs for disposal site - action
specific
Display warning signs at all entrances and at intervals of 100m (328 feet) or less
along the property line of the site or along the perimeter of the sections of the site
where asbestos-containing waste material was deposited.
Relevant
and
Appropriate
Closure of an area that received asbestos- containing waste
materials that does not include a natural barrier to adequately deter
access by the general public - relevant and appropriate
40 CFR § 61.151 (b)( 1 )(i)-(iii)
The warning signs must:
Be posted in such a manner and location that a person can easily read the legend;
and
Conform to the requirements for (20"xl4") upright format signs specified in 29
CFR 1910.145(d)(4) and this paragraph; and
Display the legend as prescribed in § 61.15 l(b)(l)(iii) located in the lower panel
with letter sizes and styles of visibility at least equal to those specified in §
61.151 (b)( 1 )(iii).
Relevant
and
Appropriate
Closure of an area that received asbestos- containing waste
materials that does not include a natural barrier to adequately deter
access by the general public - relevant and appropriate
40 CFR § 61.151(b)(2)
Fence for disposal site - action specific
Fence the perimeter of the site in a manner adequate to deter access by the general
public.
Relevant
and
Appropriate
PAGE 8 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
40 CFR § 61.151 (e)( 1 )-(3 )
Deed notice for asbestos waste disposal
site - action specific
Record, in accordance with State law, a notation on the deed to the facility
property and on any other instrument that would normally be examined during a
title search; this notation will in perpetuity notify any potential purchaser of the
property that:
• The land has been used for disposal of asbestos-containing waste material;
and
• The survey plat and record of the location and quantity of asbestos
containing waste disposed of within the disposal site required in §
61.154(f) have been filed with the Administrator; and
• The site is subject to 40 CFR part 61, Subpart M.
NOTE: Recordation of deed notice that informs potential purchaser on the waste
disposal site is considered a substantive requirement for post-closure.
Relevant
and
Appropriate
Closure of an inactive disposal area that received asbestos
containing waste materials - relevant and appropriate
C appinx II aste in Place — La ml fill
C 'losure and Post C Insure
Area of Contamination Policy, discussed
in the NCP and various EPA guidance
documents/memoranda
Consolidation of waste within an area of contamination does not constitute
placement of waste and does not trigger application of RCRA land disposal
restrictions or other RCRA requirements, such as closure and post-closure
requirements.
TBC
Consolidation of waste within an area of contamination
40 C .F .R. § 264.111 (a) - (c)
Must close the unit in a manner that:
Relevant
and
Appropriate
Closure of a RCRA hazardous waste management unit
Landfill closure performance standard
• minimizes the need for further maintenance; and
• controls, minimizes or eliminates, to the extent necessary to protect human
health and the environment, post -closure escape of hazardous waste,
hazardous constituents, leachate, contaminated run -off, or hazardous
waste decomposition products to ground or surface waters or to the
atmosphere; and
complies with the relevant closure and post -closure requirements of 40 C.F.R.§
35 IAC 724.118(b) (Subpart B: General
Facility Standards, Location Standards -
Floodplains)1
A facility located in a 100-year floodplain must be designed, constructed,
operated, and maintained to prevent washout of any hazardous waste by a 100-
year flood.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste management unit
35 IAC 724.195 (Subpart F: Releases
from Solid Waste Management Units,
Point of Compliance)
The Agency must specify the point of compliance at which the groundwater
protection standard of Section 724.192 applies and at which monitoring must be
conducted. The point of compliance is a vertical surface located at the
hydraulically downgradient limit of the waste management area that extends down
into the uppermost aquifer underlying the regulated units.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste management unit
-i
The floodplain ARAR will be relevant and appropriate if it is determined that the site or part of the site is in the 100 yearfloodplain, which is not yet determined.
PAGE 9 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
35 IAC 724.197(a), (c-f), (h), and (i)
(Subpart F: Releases from Solid Waste
Management Units, General Groundwater
Monitoring Requirements)
724.197(a) - The groundwater monitoring system must consist of a sufficient
number of wells, installed at appropriate locations and depths to yield groundwater
samples from the uppermost aquifer that fulfill the following requirements: 1)
They represent the quality of background water, 2) They represent the quality of
groundwater passing the point of compliance; and 3) They allow for the detection
of hazardous waste or hazardous constituents that have migrated to the uppermost
aquifer.
724.197(c) - All monitoring wells must be cased in accordance with this section.
724.197(d) - The groundwater monitoring program must include consistent
sampling and analysis to ensure a reliable indication of groundwater quality below
the waste management area. The program must include procedures and techniques
for the following: 1) Sample collection; 2) Sample preservation and shipment; 3)
Analytical procedures; and 4) Chain of custody control.
724.197(e) - The groundwater monitoring program must include sampling and
analytical methods that are appropriate for groundwater sampling and that
accurately measure hazardous constituents in groundwater samples.
724.197(f) - The groundwater monitoring program must include a determination
of the groundwater surface elevation each time groundwater is sampled.
724.197 (h) and (i) - Specifies the statistical methods that may be used in
evaluating groundwater monitoring data and performance standards for each
statistical method.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste management unit
35 IAC 724.198
Detection Monitoring Program would be appropriate for defining responsibilities
for the ongoing groundwater monitoring.
Relevant
and
Appropriate
Long-term groundwater monitoring will be conducted after the
remedy is constructed to determine if the source control measures
have a positive effect on groundwater contamination levels.
IAC Title 35, Part 724.211(a) and (b)
(Subpart 7G: Closure and Post-Closure
Care, Closure Performance Standard)
The owner or operator must close the facility in a manner that does the following:
(a) The closure minimizes the need for further maintenance.
(b) The closure controls, minimizes, or eliminates, to the extent necessary to
adequately protect human health and the environment, post-closure escape of
hazardous waste, hazardous constituents, leachate, contaminated run-off, or
hazardous decomposition products to the ground or surface waters or to the
atmosphere.
Relevant
and
Appropriate
The substantive requirements of 35 IAC 724.211 (a) and (b) will be
met to protect human health and the environment.
IAC Title 35 Part 724.212(a) and (b)
(Subpart G: Closure and Post-Closure
Care, Closure Plan: Amendment of Plan)
Requires owners of hazardous waste facilities to submit a written closure plan (the
approved plan becomes a condition to any RCRA permit). The closure plan
describes the steps necessary for final closure. 724.212(a) (2), 724.212(b) (2), and
724.212(b) (4) are substantive requirements.
Relevant
and
Appropriate
The substantive requirements of 35 IAC 724.212 (a) and (b) are
relevant and appropriate to the conditions at Site, but a formal
Closure Plan required for owners of hazardous waste management
facilities is not applicable to former landfill sites being addressed
through the CERCLA process. The substantive requirements of 35
IAC 724.212 (a) and (b) will be met through the CERCLA process
IAC Title 35, Part 724.192 (Subpart F
Releases from Solid Waste Management
Units, Point of Compliance (similar to 40
CFR 264.95)
Point of Compliance: The Agency must specify the point of compliance at which
the groundwater protection standard of Section 724.192 applies and at which
monitoring must be conducted. The point of compliance is a vertical surface
located at the hydraulically downgradient limit of the waste management area that
extends down into the uppermost aquifer underlying the regulated units.
Relevant
and
Appropriate
Establishes where monitoring of the site disposal cell must be
conducted.
PAGE 10 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
IAC Title 35 Part 724.214 (Subpart G:
Closure and Post-Closure Care, Disposal
or Decontamination of Equipment,
Structures, and Soils)
All contaminated equipment, structures, and soils must be properly disposed of or
decontaminated.
Relevant
and
Appropriate
Decontamination would be completed in compliance with this
subpart.
IAC Title 35 Part 724.215 (Subpart G:
Closure and Post-Closure Care,
Certification of Closure)
Owner or operator must submit to the Agency, by registered mail, a certification
that the hazardous waste management unit or facility, as applicable, has been
closed in accordance with the specifications in the approved closure plan. The
certification must be signed by the owner or operator and by an independent
registered professional engineer.
Relevant
and
Appropriate
The substantive requirements of 35 IAC 724.215 will be met by the
Remedial Action Completion Report (RACR) completed through
the CERCLA process. The 60-day limit is not relevant and
appropriate, because it is not appropriate for a CERCLA site.
IAC Title 35 Part 724.216 (Subpart G:
Closure and Post-Closure Care, Survey
Plat)
IAC Title 35, Part 724.409 (Subpart N:
Landfills, Surveying and Recordkeeping)
No later than the submission of the certification of closure of each hazardous
waste disposal unit, the owner or operator must submit to any local zoning
authority or authority with jurisdiction over local land use and to the Agency and
record with land titles, a survey plat indicating the location and dimensions of
landfill cells or other hazardous waste disposal units with respect to permanently
surveyed benchmarks. This plat must be prepared and certified by a professional
land surveyor. The plat filed with the local zoning authority or the authority with
jurisdiction over local land use must contain a note, prominently displayed, that
states the owner's and operator's obligation to restrict disturbance of the
hazardous waste disposal unit in accordance with Subpart G of this Part.
Relevant
and
Appropriate
The substantive requirements of 35 IAC 724.216 and 35 IAC
724.409 will be met by the RACR completed through the CERCLA
process. As part of the implementation of any of these alternatives,
a survey plat indicating the location and dimensions of the waste
area and cover limits will be submitted to the appropriate local
authority with jurisdiction over local land use and to Illinois EPA.
The plat will be prepared and certified by a professional land
surveyor. Along with the survey plat institutional controls will be
established to prohibit disturbance of the cover and to control the
land use in the survey area. The timeframe for submission may not
be appropriate for a CERCLA site.
IAC Title 35 Part 724.217 (Subpart G:
Closure and Post-Closure Care, Post-
Closure Care and Use of Property)
Requires a Post-Closure Care Period of at least 30 years after completion of
closure for the unit, security requirements, post-closure use of property on or in
which hazardous wastes remain after closure must never be allowed to disturb the
integrity of the final cover unless the Agency determines it is necessary for
reasons listed in the regulations, and all the post-closure care activities must be in
accordance with the provisions of the approved post-closure plan as specified in
Section 724.218.
Relevant
and
Appropriate
The substantive requirements of 35 IAC 724.217 for Post-Closure
Care and Use of Property will be addressed in the O&M Plan
developed through the CERCLA process. The O&M Plan will
include descriptions of the long-term O&M, post-closure care
property-use restrictions, and institutional controls. The remedy
would also be subjected to the Five-Year Review process under
CERCLA. An assessment of the ongoing post-closure/O&M
activities would be completed at that time.
IAC Title 35 Part 724.218 (Subpart G:
Closure and Post-Closure Care, Post-
Closure Care Plan; Amendment of Plan)
The owner must have a written post-closure plan that must identify the activities that
will be carried on after closure and the frequency of these activities (including
planned monitoring activities and frequencies, planned maintenance activities, and
name, address, ancTphone number of the person or office to contact). The relevant
and appropriate requirement in 724.218 is:
724.218(b)(1) and (b)(2) - the post-closure plans must incorporate monitoring and
maintenance activities that comply with the substantive requirements of 724
Subparts F and N.
Relevant
and
Appropriate
The substantive requirements of 35 IAC 724.218 for post-closure
care and use of the remediated portions of the site will be addressed
in the O&M Plan. The selected remedy will also be subjected to the
Five-Year Review. Incorporating monitoring and maintenance
activities to comply with Subpart F will be determined if relevant
and appropriate in the final groundwater remedy.
PAGE 11 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
IAC Title 35 Part 724.219 (Subpart G:
Closure and Post-Closure Care, Post-
Closure Notices)
Requires certification of closure from the owner or operator of a disposal facility
to submit to the Agency, to the County Recorder, and to any local zoning authority
or authority, a record of the type, location, and quantity of hazardous wastes
disposed (for hazardous wastes disposed of before January 12, 1981, the owner or
operator must identify these items to the best of the owner or operator's
knowledge and in accordance with any records). In addition, the owner or operator
is required to record a notation on the deed to the facility property (or on some
other instrument that is normally examined during title search) that will in
perpetuity notify any potential purchaser of the property that the land has been
used to manage hazardous wastes; its use is restricted; and the survey plat and
record of the type, location, and quantity of hazardous wastes disposed, and filed
with the Agency, the County Recorder, and any local zoning authority or authority
with jurisdiction over local land use.
Relevant
and
Appropriate
The substantive requirements of 35 IAC 724.219 for post-closure
notices will be met by preparing a RACR completed through the
CERCLA process. The report will contain information
documenting the activities completed and approved
deviations/changes implemented. This report will provide surveyed
locations of the cover construction, surveyed locations of
monitoring wells, and document any waste generated and disposed
offsite, as well as all other pertinent remedy related documentation.
A description of the institutional controls applied will also be
included within the report. A summary of compliance with the
substantive requirements of 35 IAC 724.219 indicating that waste
will be left in place and the location of that waste from the RACR
will be summarized in a deed notation that travels in perpetuity
with the land. The deed notation will be recorded in the form of a
Uniform Environmental Covenants Act with the appropriate
authority and the Agency. The timeframe for submission may not
be appropriate for a CERCLA site.
IAC Title 35 Part 724.220 (Subpart G:
Closure and Post-Closure Care,
Certification of Completion of Post-
Closure Care)
After completion of the established post-closure care period for each hazardous
waste disposal unit, the owner or operator must submit to the Agency, by
registered mail, a certification that the post-closure care period for the hazardous
waste disposal unit was performed in accordance with the specifications in the
approved post-closure plan.
Relevant
and
Appropriate
The substantive requirements of 724.220 will be met through the
submission of routine O&M reports, as well as Five-Year Remedy
Reviews, which will evaluate and document the effectiveness of the
remedy and post-closure care. The timeframe for submission may
not be appropriate for a CERCLA site.
IAC Title 35, Part 724.410(a)(l-4)
(Subpart N Landfills, Closure and Post-
Closure Care)
At final closure of the landfill or upon closure of any cell, the owner or operator
must cover the landfill or cell with a final cover designed and constructed to do the
following:
(1) Provide long-term minimization of migration of liquids through the closed
landfill.
(2) Function with minimum maintenance.
(3) Promote drainage and minimize erosion or abrasion of the cover.
(4) Accommodate settling and subsidence so that the cover's integrity is
maintained.
Relevant
and
Appropriate
The final cover should comply with regulatory guidance for
hazardous waste caps to prevent teachability and the performance
criteria identified in 35 IAC 724.410(a)(l-4). Periodic maintenance
as described in the O&M Plan would be implemented to correct
any settling or subsidence occurrences and to facilitate any needed
repairs to the cover. Because this site is inactive, protected by a
security fence, and owned by a single landowner, formal
institutional controls and cover repair and maintenance, as needed,
can be easily implemented and enforced.
IAC Title 35, Part 724.410(b)(l, 4, 5, and
6) (Subpart N Landfills, Closure and Post-
Closure Care)
After final closure, the owner or operator must comply with all post-closure
requirements contained in Sections 724.217 through 724.220, including
maintenance and monitoring throughout the post-closure care period (specified in
the permit under Section 724.217). After final closure, the owner or operator must
do the following:
(1) Maintain the integrity and effectiveness of the final cover, including making
repairs to the cap as necessary to correct the effects of settling, subsidence,
erosion, or other events.
(4) Maintain and monitor the groundwater monitoring system and comply with all
other applicable requirements of Subpart F of this Part.
(5) Prevent run-on and run-off from eroding or otherwise damaging the final
cover.
(6) Protect and maintain surveyed benchmarks.
Relevant
and
Appropriate
The substantive requirements of 35 IAC 724.410 for post-closure
care and use woulcf be addressed in the O&M Plan as part of the
CERCLA process. The O&M Plan will provide detail on inspection
and maintenance of the final cover, groundwater monitoring, and
run-on/run-off controls to prevent erosion or damage. The remedy
will also be subjected to the Five-Year Review process under
CERCLA. An assessment of the ongoing post-closure/O&M
activities would be completed at that time and revisions
implemented as necessary. Incorporating monitoring and
maintenance activities to comply with Subpart F will be determined
if relevant and appropriate in the final groundwater remedy.
40 C.F.R.§ 264.301(g)
Run-on/run-off control systems for
landfill cover - action specific
Run-on control system must be capable of preventing flow onto the active portion
of the landfill during peak discharge from a 25-year storm event.
Relevant
and
Appropriate
Construction of a RCRA hazardous waste landfill cover.
40 C.F.R.§ 264.301(h)
Construction of a RCRA hazardous waste
landfill cover - action specific
Run-off management system must be able to collect and control the water volume
resulting from a 24-hour, 25-year storm event.
Relevant
and
Appropriate
Construction of a RCRA hazardous waste landfill cover.
PAGE 12 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
40 C.F.R.§ 264.117(c)
Protection of closed landfill - action
specific
Post-closure use of property must never be allowed to disturb the integrity of the
final cover, liners, or any other components of the containment system or the
facility=s monitoring system unless necessary to reduce a threat to human health
or the environment.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste landfill
40 C.F.R.§ 264.310(a)(l)-(4)
General post-closure care for closed
landfill - action specific
At final closure of the landfill or upon closure of any cell, the owner of operator
must cover the landfill or cell with a final cover designed and constructed to:
• Provide long term minimization of migration of liquids through the closed
landfill;
• Function with minimum maintenance.
• Promote drainage and minimize erosion or abrasion of the cover; and
Accommodate settling and subsidence so that the cover's integrity is maintained.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste landfill
40 C.F.R.§ 264.310(b)(1), (5) and (6)
Owner or operator must:
• maintain the effectiveness and integrity of the final cover including making
repairs to the cap as necessary to correct effects of settling, erosion, etc.
• prevent run-on and run-off from eroding or otherwise damaging final cover;
and
protect and maintain surveyed benchmarks used to locate waste cells.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste landfill
40 C.F.R.§ 264.119(a)
Post-closure notices for closed landfill -
action specific
Must submit to the local zoning authority, or authority with jurisdiction over local
land use, and to the Regional Administrator a record of the type, location, and
quantity of hazardous wastes disposed of within each cell of the unit.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste landfill
40 C.F.R.§ 264.116
Must submit to the local zoning authority, or the authority with jurisdiction over
local land use, and to the Regional Administrator, a survey plat, prepared and
certified by a professional land surveyor, indicting the location and dimensions of
hazardous waste disposal cells with respect to permanently surveyed benchmarks.
The plan must include a prominently displayed note stating the owner of operator's
obligation to restrict disturbance of the hazardous waste disposal unit in
accordance with the applicable 40 CFR 264 Subpart G regulations.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste landfill
40 C.F.R.§ 264.119(b)(l)(i)-(iii)
Must record, in accordance with State law, a notation on the deed to the facility
property - or on some other instrument which is normally examined during a title
search - that will in perpetuity notify any potential purchaser of the property that:
• The land has been used to manage hazardous wastes;
• its use is restricted under 40 C.F.R.§ Part 264 Subpart G regulations; and
the survey plat and record of the type, location, and quantity of hazardous wastes
disposed within each cell or other hazardous waste disposal unit of the facility
required by Sections 264.116 and 264.119(a) have been filed with the local zoning
authority, or the authority with jurisdiction over local land use, and with the EPA
Regional Administrator.
Relevant
and
Appropriate
Closure of a RCRA hazardous waste landfill
PAGE 13 OF 14
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Table A-6: Applicable or Relevant and Appropriate Requirements (ARARs)
Hegeler Zinc Superfund Site
Regulation
Requirement
ARAR
Status
Analysis
(irountl W ater
40 C.F.R.§ 264.97(c)
77 IAC Part 920: Illinois Water Well
Construction Code - action specific
All monitoring wells must be cased in a manner that maintains the integrity of the
monitoring well bore hole; this casing must be screened or perforated and packed
with gravel or sand, where necessary, to enable collection of groundwater
samples; the annular space above the sampling depth must be sealed to prevent
contamination of groundwater and samples.
Relevant
and
Appropriate
Construction of RCRA groundwater monitoring well
IAC Title 35, Part 620.250, Establishment
of Groundwater Management Zones
The purpose of a GMZ is to manage groundwater while mitigating impairment
caused by the release of contaminants from a site. Presents requirements for
establishment and evaluation of GMZs while groundwater standards are not being
met.
Applicable
A GMZ would be established and maintained until groundwater
standards are met.
Notes:
ACM = asbestos-containing material
ARAR = applicable or relevant and appropriate requirement
CERCLA = Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
CFR = Code of Federal Regulations
CWA = Clean Water Act
ELCR = excess lifetime cancer risk
EPA = U.S. Environmental Protection Agency
FS = feasibility study
GMZ = groundwater management zone
IEPA = Illinois Environmental Protection Agency
IHPA = Illinois Historic Preservation Agency
ILCS = Illinois Compiled Statutes
IWQS = Illinois water quality standards
MCL = maximum contaminant level
MCLG = maximum contaminant level goal
PAGE 14 OF 14
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Table A-7. Comparison of COECs and RGs in Sediment - OU1 versus OU2
Adapted from Ecological Risk Preliminary Remediation Goals Operable Units 1 and 2
HegelerZinc Superfund Site, Vermilion County, Illinois
Ecological RGs Sediment (mg/kg)
OU1 RAS - Sitewide
(includes creek, KIK culvert,
fire water pond, settling
COEC
ponds, and Lake Harry)
OU2 FS-KIK Culvert
OU2 FS-OU2 Tributary
Metals
Aluminum
No RG value proposed (see
note 1)
-
-
Cadmium
4.98
21.3
19
Copper
-
87.9
146
Iron
No RG value proposed (see
note 2)
Lead
128
60
421
Manganese
1,100
-
No PG value proposed (see
note 2)
Mercury
-
-
4.2
Silver
-
No RG value proposed (see
note 2)
No RG value proposed (see
note 2)
Zinc
459
1,990
3,711
Pesticides
4,4'-DDD
0.013
0.57
4,4'-DDE
0.013
0.066
4,4'-DDT
0.0062
0.5
Alpha-Chlordane
0.0024
0.026
Beta-BHC
Pesticides not evaluated in
No RG value proposed (see
note 2)
-
Dieldrin
OU1 BERA
0.0036
-
Endosulfan 1
0.0015
-
Endosulfan II
No RG value proposed (see
note 2)
-
Endrin
0.84
-
Gamma-Chlordane
0.0046
0.028
Notes:
- : compound not identified as a chemical of potential ecological concern in the BERA
Note 1: No screening level for aluminum is available; therefore, no numeric ecological PRG for aluminum was proposed.
It is assumed the risk for aluminum will be addressed by addressing risk for the other metals.
Note 2: RG not derived due to lack of toxicity reference values or lack of correlation between sediment concentration
and sediment toxicity test response.
BERA = baseline ecological risk assessment
COEC = chemical of ecological concern
FS = feasibility study
mg/kg = milligrams per kilogram
RG = remediation goal
RAS = remedial alternatives screening
Page 1 of 1
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Table A-8. Remediation Goals (RG) for Groundwater
Adapted from Feasibility Study Report OU1
Heqeler Zinc Superfund Site, Vermilion County, Illinois
Residential Tapwater RSL
Target ELCR b
Target Organ
Drinking Water
10"4
10"5
10"6
_Q
H
II
X
MCLc
Illinois Class 1d
RG e
COCs
Exposure Area a
(Hg/L)
(Hg/L)
(m-s/l)
(Hg/L)
(Hg/L)
(Hg/L)
(Hg/L)
Basis
Aluminum
Exposure Areas 1, 2, and 3
NA
NA
NA
20,000
NA
NA
20,000
Residential tap water RSL HI = 1
Antimony
Exposure Areas 1, 2, 3, and 4
NA
NA
NA
8
6
6
6
MCL and Illinois Class 1
Arsenic
Exposure Areas 1, 2, 3, and 4
5.2
0.52
0.052
6
10
10
10
MCL and Illinois Class 1
Barium
Exposure Areas 1, 2, and 3
NA
NA
NA
3,800
2,000
2,000
2,000
MCL and Illinois Class 1
Beryllium
Exposure Areas 1, 2, and 3
NA
NA
NA
25
4
4
4
MCL and Illinois Class 1
Cadmium
Exposure Areas 1, 2, 3, and 4
NA
NA
NA
9
5
5
5
MCL and Illinois Class 1
Chromium
Exposure Areas 1, 2, 3, and 4
NA
NA
NA
NA
100
100
100
MCL and Illinois Class 1
Cobalt
Exposure Areas 1, 2, and 3
NA
NA
NA
6
NA
1,000
1,000
Illinois Class 1
Copper
Exposure Areas 1, 2, and 3
NA
NA
NA
800
1,300
650
650
Illinois Class 1
Iron
Exposure Areas 1, 2, and 3
NA
NA
NA
14,000
NA
5,000
5,000
Illinois Class 1
Lead
Exposure Areas 1, 2, 3, and 4
NA
NA
NA
15
15
7.5
7.5
Illinois Class 1
Manganese
Exposure Areas 1, 2, and 3
NA
NA
NA
430
NA
150
150
Illinois Class 1
Vanadium
Exposure Areas 1, 2, and 3
NA
NA
NA
86
NA
49
49
Illinois Class 1
Zinc
Exposure Areas 1, 2, 3, and 4
NA
NA
NA
6,000
NA
5,000
5,000
Illinois Class 1
Notes:
COCs are identified in the HHRAs (CH2M 2019e and 2019f).
The groundwater is classified as Class I per the SRI Report (CH2M 2019a).
a Exposure Areas are shown on Figure 2-5.
b EPA Tapwater RSLs (May 2019). Available on line: https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables.
c EPA maximum contaminant levels. Available online: https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations.
d 35 Illinois Administrative Code (IAC) 620.210 and 35 IAC 620.410 Class I groundwater quality standards.
e RGs are applicable to the onsite and offsite areas.
Definitions:
Hg/L = microgram per liter
COC = chemical of concern
ELCR = excess lifetime cancer risk
EPA = U.S. Environmental Protection Agency
HHRA = human health risk assessment
HI = hazard index
MCL = maximum contaminant level
NA = not applicable
RG = remediation goal
RSL = regional screening level
Page 1 of 1
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TableA-9.Summaryof RemedialAlternatives Adapted
from Feasibility Study Report 0U1
HegeterZinc Superfund Site, Vermilion County, Illinois
Media
Alternative 1
Alternative 2
Alternative 3, the Selected Remedy
Alternative 4
Alternative 5
Existing Structures
No Action
Building demolition, consolidation of brick
and concrete with slag pile and offsite
disposal for wood, debris, and metal.
Building demolition, consolidation of brick
and concrete with slag pile and offsite
disposal for wood, debris, and metal.
Building demolition, consolidation of brick
and concrete with slag pile and offsite
disposal for wood, debris, and metal.
Building demolition, consolidation of brick
and concrete with slag pile and offsite
disposal for wood, debris, and metal.
Soils/Slag
No Action
Excavate OU3 Residential Soil Pile,
consolidate with slag pile.
Excavate OU3 Residential Soil Pile,
consolidate with slag pile.
Excavate OU3 Residential Soil Pile,
consolidate with slag pile.
Excavate OU3 Residential Soil Pile,
consolidate with slag pile.
Cover surface soil areas with detected
concentrations of COCs exceeding human
health RGs in exposure areas 2, 3, and 4 with
2 feet of compacted clay and 6 inches of
topsoil. Excavate surface soils in non-
vegetated areas with detected concentrations
of COECS exceeding ecological RGs to 0.5 feet.
Consolidate excavated materials with slag
pile. Backfill excavated areas with 0.5 feet of
topsoil to original grade.
Excavate surface soil areas with detected
concentrations of COCs exceeding human
health PRGs in exposure areas 2, 3, and 4 to
2 feet. Excavate surface soils in non-vegetated
areas with detected concentrations of COECS
exceeding ecological RGs to 0.5 feet.
Consolidate excavated materials with slag
pile. Cover subsurface soil areas with detected
concentrations of COCs exceeding human
health RGs with 2 feet of compacted clay and
6 inches of topsoil. Remainder of excavated
areas will be backfilled to the original grade.
Excavate surface soil areas with detected
concentrations of COCs exceeding human
health RGs in exposure areas 2, 3, and 4 and
COECs exceeding ecological RGs to 2 feet bgs.
Consolidate excavated materials with slag
pile. Cover subsurface soil areas with detected
concentrations of COCs exceeding human
health RGs with 2 feet of compacted clay and
6 inches of topsoil. Backfill remaining
excavated areas to the original grade.
Excavate surface soil areas with detected
concentrations of COCs exceeding human
health RGs in exposure areas 2, 3, and 4 and
COECs exceeding ecological RGs to 2 feet bgs.
Excavate subsurface soil (> 2 feet bgs)
exceeding human health PRGs in exposure
areas 2, 3, and 4. Consolidate excavated
materials with slag pile. Backfill excavated
areas to the original grade.
A soil IC would be in place for the slag pile
consolidation area and areas with soil
concentrations above human health RGs.
Because of the land uses evaluated in the
human health risk assessments (HHRAs),
property restrictions across OU1 are also
needed prohibiting future residential land
use, future recreational land use, and future
commercial use as a daycare center.
A soil IC would be in place for the slag pile
consolidation area, areas with subsurface soils
above human health RGs, and the paved
areas of the KIK property.
Because of the land uses evaluated in the
HHRAs, property restrictions across OU1 are
also needed prohibiting future residential
land use, future recreational land use, and
future commercial use as a daycare center.
A soil IC would be in place for the slag pile
consolidation area, areas with subsurface soils
above human health RGs, and the paved
areas of the KIK property.
Because of the land uses evaluated in the
HHRAs, property restrictions across OU1 are
also needed prohibiting future residential
land use, future recreational land use, and
future commercial use as a daycare center.
A soil IC would be in place for the slag pile
consolidation area and the paved areas of the
KIK property.
Because of the land uses evaluated in the
HHRAs, property restrictions across OU1 are
also needed prohibiting future residential
land use, future recreational land use, and
future commercial use as a daycare center.
Cover slag pile.
Cover slag pile.
Cover slag pile.
Cover slag pile.
Sediment
No Action
Remove sediment exceeding human health
PRGs in the exposure areas 1 and 2 in the
creek via dredging or excavation.
Remove sediment exceeding human health
PRGs in the exposure areas 1 and 2 in the
creek via dredging or excavation.
Remove sediment exceeding human health
PRGs in the exposure areas 1 and 2 in the
creek via dredging or excavation.
Remove sediment exceeding human health
PRGs in the exposure areas 1 and 2 in the
creek via dredging or excavation.
Remove sediment exceeding ecological RGs
in the creek, the fire water pond, and the
settling ponds via dredging or excavation.
Remove sediment exceeding ecological RGs
in the creek, the fire water pond, and the
settling ponds via dredging or excavation.
Remove sediment exceeding ecological RGs
in the creek, the fire water pond, and the
settling ponds via dredging or excavation.
Remove sediment exceeding ecological RGs
in the creek, the fire water pond, and the
settling ponds via dredging or excavation.
Creek rerouting to the north of the slag pile.
Creek rerouting to the north of the slag pile.
Creek rerouting to the north of the slag pile.
Creek rerouting to the north of the slag pile.
Relocate portions of the slag pile within
100 feet of the south branch of the creek.
Relocate portions of the slag pile within
100 feet of the south branch of the creek.
Relocate portions of the slag pile within
100 feet of the south branch of the creek.
Relocate portions of the slag pile within
100 feet of the south branch of the creek.
Sediment and fish tissue long-term
monitoring.
Sediment and fish tissue long-term
monitoring.
Sediment and fish tissue long-term
monitoring.
Sediment and fish tissue long-term
monitoring.
Groundwater and
Surface Water
No Action
Groundwater and surface water long term
monitoring and ICs for groundwater.
Groundwater and surface water long term
monitoring and ICs for groundwater.
Groundwater and surface water long term
monitoring and ICs for groundwater.
Groundwater and surface water long term
monitoring and ICs for groundwater.
Notes:
COC = chemicals of concern
COEC = chemical of ecological concern
bgs = below ground surface
IC = institutional control
OU = Operable Unit
RGs = remediation goals
Page 1 of 1
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fable A-10. Chart comparing cleanup options with the Nine Superfund Remedy Selecl
tion Criteria
1 auluulion ( riknon
AlkllKlllW 1
Alknuiliw 2
\lk'l"IKlll\ C 3*
AlkTiuiliw 4
Alknuiliw 5
Overall Protection
of Human Health
and the
Environment
O
•
•
•
•
Compliance with
ARARs
O
•
•
•
•
Long-term
Effectiveness and
Permanence
O
•
•
•
•
Reduction of
Toxicity, Mobility,
or Volume through
Treatment***
O
©
©
©
©
Short-term
Effectiveness
O
•
•
•
•
Implementability
•
•
•
•
•
Alternative Cost
$93,000
$25,286,000
$29,344,000
$72,372,000
$74,398,000
State Acceptance
O
O
•
O
O
Community
Acceptance
O
O
•
O
O
® Meets criterion © Partially meets criterion O Does not meet criterion
*EPA's Selected Remedy
** The OU2 Alternative 3 - sediment excavation and off-site disposal alternative [the Capital costs ($' 1,406, 324) and Periodic and 5 year O&M Costs ($
164,448) and total estimated cost $1,570,772] these estimated costs will be included under each action alternative and the Selected Remedy.
-------
Table A-ll. Estimated Costs for Alternatives
Alternate e
Capital
C osl
(Mi.M
Periodic
C'osls
Present Worth
Alternative 1 - No Action
$0
$0
$120,000
$93,000
Alternative 2- Cover of Surface Soil with HH PRG exceedances;
Excavation of Surface Soil 0.5 feet with Ecological exceedances outside
the HH excavation footprint, Cover slag pile consolidation area, ICs and
LTM
$23,338,000
$1,528,000
$823,000
$25,286,000
Alternate e 3- 1 Aca\alion of Surface Soil abow 1 lunian 1 Icallh
PRGs (up lo 2 iLvl litjs). l\ca\alion of Surface Soil abo\c Lcolouical
PR< is (<> 5 fool) oulsidc of ihc 1 lunian 1 Icallh PRCi c\ca\alion
footprint. ( o\cr Sknj Pile ( onsolidalion Area: ICs and 1.1 \ 1
S2 7.302.1 ii id
SI.M5.M "I
SS23.HIKI
S:^.344.(i(i(i
Alternative 4- Excavation of Surface Soil above both Human Health
and Ecological PRGs (up to 2 feet bgs); Cover Slag Pile Consolidation
Area; ICs and LTM
$66,174,000
$6,836,000
$823,000
$72,372,000
Alternative 5- Excavation of Surface Soil above Ecological PRGs (up
to 2 feet bgs); Excavation of Soil above Human Health PRGs inside the
Ecological footprint below 2 feet to 10 feet bgs); Cover Slag Pile
Consolidation Area; ICs and LTM.
$71,959,000
$2,140,800
$823,000
$74,398,000
EPA 's Selected Remedy is shaded.
Each action alternative costs would include 0U2 FS sediment remediation cost $1,406,324 and (remediation cost plus baseline and long-term monitoring)
for a total estimated cost of $1,570,772.
-------
ATTACHMENT 3
ADMINISTRATIVE RECORD (AR) INDEX
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR THE
HEGELER ZINC SITE OU1 AND OU2
DANVILLE , VERMILION COUNTY, ILLINOIS
ORIGINAL
November 30, 2022
SEMS ID:
NO. SEMS ID DATE AUTHOR
RECIPIENT TITLE/DESCRIPTION
PAGES
366880 02/01/07 Weston
U.S. EPA Remedial Investigation Hegeler 627
Zinc Site Danville, Vermillion
County, IL [Redacted]
902007 12/01/09
Shield U.S. EPA Hegeler Zinc Superfund Site OU2
Environmental Initial Characterization Pesticides
and Metals in Waterway Sediment
5424
442989 09/01/12 AECOM
U.S. EPA Baseline Ecological Risk
Assessment - Final Hegeler Zinc
Superfund Site OU2
1075
4 934817 07/01/16 AECOM
U.S. EPA Feasibility Study Work Plan -
Final Hegeler Zinc Superfund Site
OU2
63
5 939844 02/01/18 AECOM
U.S. EPA Field Investigation - Final
Hegeler Zinc Superfund Site OU1
929
948891 08/01/19 CH2MHILL U.S. EPA
Baseline Ecological Risk 1650
Assessment - Hegeler Zinc Site
Operable Unit 1 - Final Rev 01
948880 08/14/19 CH2MHILL U.S. EPA
Technical Memorandum -
Ecological Risk Update - Hegeler
Zinc Superfund Site OU1
151
951804 10/01/19 CH2MHILL U.S. EPA
Final Supplemental Remedial
Investigation - Hegeler Zinc
Superfund Site OU 1 Vermilion
County, IL
3,830
-------
NO. SIMS II) DATE AUTHOR
RECIPIENT TITLE/DESCRIPTION PAGES
9 959530 06/10/20 AECOM U.S. EPA
10 963501 01/15/21 CH2MHILL U.S. EPA
11 963509 01/20/21 CH2MHILL U.S. EPA
12 969738 10/01/21 AECOM U.S. EPA
Revised Hegeler Zinc OU2 50
HHRA Update Finalized in May
2014 and Re-evaluated in 2020
Final Ecological Risk Preliminary 178
Remediation Goals Hegeler Zinc
Superfund Site - Operable Unit 1
and Operable Unit 2 - Vermilion
County, IL
Final Hegeler Zinc Superfund Site 14
OU1 Feasibility Study Remedy
Modifications - Alternatives 2 and
3 Vermilion County, IL
Final Feasibility Study -Hegeler 280
Zinc Superfund Site OU2
Danville, IL
13 952600 11/28/22 U.S. EPA
General Public Final Proposed Plan for the
Hegeler Zinc Superfund Site -
Operable Units 1 and 2
76
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR THE
HEGELER ZINC SITE OU1 AND OU2
DANVILLE, VERMILION COUNTY, ILLINOIS
UPDATE 1
DECEMBER, 2022
SEMS ID:
NO. SEMS ID DATE AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
1 358851 03/01/10 CH2M HILL
U.S. EPA Final Baseline Ecological Risk
Assessment Work Plan, Sampling
& Analysis Plan
65
2 903607 03/02/10 U.S. EPA
File
Memo Regarding Comments on
Initials Site Characterization
Report Pesticides & Metals in
Waterway Sediments - Dec. 2009
for OU2
3 903600 04/26/10 U.S. EPA
File
Letter Regarding Path Forward
for Baseline Ecological Risk
Assessment Deliverables OU2
4 440818 05/01/10 Enviro
Systems, Inc.
U.S. EPA Toxilogical Evaluation of
Sediment Samples in Support of
Final Baseline Ecological Risk
Assessment
258
5 977612 05/14/10 CH2M HILL
U.S. EPA Recommendations for Phase 2
Groundwater Investigations
6 977613 07/08/10 CH2M HILL
U.S. EPA Preliminary Phase 1 and 2
Groundwater Data Assessment
and Phase Recommendations
15
919428
10/01/10
U.S. EPA
Publication U.S. EPA Fact Sheet- EPA to
Host Open House Former Smelter
Site
412000
10/08/10
U.S. EPA
File
U.S. EPA Memo Regarding
Approval for Initial Revision of
Addendum No. 3 to First
Revision of QAPP
-------
NO,
9
10
11
12
13
14
15
16
SIMS II) DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
451900 11/01/10 AECOM U.S.
Baseline Ecological Risk 104
Assessment - Field Sampling Plan
Addendum - Sediment Sampling
Toxicity Testing Program
903608 12/02/10 U.S. EPA File U.S. EPA Memo Regarding 1
Comments on Baseline Ecological
Risk Assessment Field Sampling
Plan Addendum - Sediment
Sampling and Toxicity Testing
Program, OU2
412004 01/28/11 AECOM
U.S. EPA Baseline Ecological Risk
Assessment, Field Sampling Plan
Addendum - Sediment Sampling
& Toxicity Testing Program -
Analytical Methods & Reporting
Limits
412006 02/01/11 U.S. EPA
File
U.S. EPA Memo Regarding
Approval for Initial Revision of
Addendum to First Revision of
QAPP
417664 02/17/11 U.S. EPA
File
U.S. EPA Memo Regarding
Comments for Initial Revision of
Addendum #2 to Quality
Assurance Project Plan for OU1
and OU3
412005 03/17/11 U.S. EPA
File
U.S. EPA Letter Regarding
Review and Approval of OU2
Baseline Ecological Risk
Assessment Field Sampling Plan
Addendum (Submitted 11/22/10)
and Supplemental Information on
02/18/2011
412007 04/01/11 AECOM
U.S. EPA Baseline Ecological Risk
Assessment Field Sampling Plan
Addendum - Sediment Sampling
& Toxicity Testing Program
203
426647 02/01/12 AECOM U.S. EPA U.S. EPA - (Remedial Action 1,684
Contract) Baseline Ecological
Risk Assessment (BERA) Hegeler
Zinc OU 1 (Final)
-------
NO,
17
18
19
20
21
22
23
24
25
26
27
SIMS II)
DATE
AUTHOR
RECIPIENT TITLE/DESCRIPTION PAGES
527404 03/19/12 AECOM
U.S. EPA AECOM Memo - OU2 Land
Uses and Re-Use Assessment
[Redacted]
14
977610 04/19/13 CH2MHILL U.S. EPA
Phase 4 Groundwater Data
Results - OU1
25
913225 05/23/14 AECOM
U.S. EPA Final Human Health Risk
Assessment (HHRA) OU2
137
493595 10/22/15 U.S. EPA
File
Environmental Indicator Work
Sheets - Superfund Long-Term
Human Health Protection Work
Sheet
928178 11/01/15 CH2MHILL U.S. EPA
Human Health Risk Assessment,
OU1
601
935633 03/28/17 U.S. EPA
AECOM
Email Regarding U.S. EPA
Comments on OU2 Feasibility
Study Report
936872 10/27/17 AECOM
U.S. EPA
Quality Assurance Project Plan-
OU1
1,740
963508 01/23/20 CH2MHILL U.S. EPA
Technical Memo OU1 Remedial
Alternatives Screening Report and
OU2 Feasibility Study Report
Comparison
963601 01/27/21 CH2MHILL U.S. EPA
Final Feasibility Study - OU1
235
978571 12/01/22 U.S. EPA
File
U.S. EPA Proposed Plan- OU1
and OU2
76
978550 12/01/22 U.S. EPA
File
Fact Sheet - Proposed Plan
Released: Public Comment Period
Open
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR THE
HEGELER ZINC SITE OU1 AND OU2
DANVILLE , VERMILION COUNTY, ILLINOIS
UPDATE 2
JANUARY 30, 2023
SEMS ID: 954550
NO. SEMS ID DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
1 954551 12/07/22 U.S. EPA General Public Hegeler Zinc Site Proposed Plan 5
-Public Comment Session
Transcript
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