Explanation of Significant Differences Old American Zinc Plant Site Fairmont City and Washington Park, Illinois St. Clair and Madison Counties


Explanation of Significant Differences

Old American Zinc Plant Site
Fairmont City and Washington Park, Illinois
St. Clair and Madison Counties

June 2019

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I. INTRODUCTION TO THE SITE AND STATEMENT OF PURPOSE

A. Site Name, Location, and Brief Description

The Old American Zinc Plant Site (IL000034355) ("Site" or "OAZ Site") is located in
Fairmont City and Washington Park, St. Clair and Madison Counties, Illinois, and
consists of an approximately 132-acre Facility Area where former zinc smelting
operations were conducted, and areas surrounding the Facility Area where elevated
concentrations of metals associated with the historic smelter operations were found in
various media. The Site includes the following areas: the Facility Area; residential,
commercial, and vacant properties around the Facility Area; alleyways owned by the
Village of Fairmont City that have been filled or surfaced with slag; drainage ways that
receive drainage from the Facility Area; and shallow groundwater within and
immediately adjacent to the Facility Area. Figure 1 provides a Site Location Map.

The U.S. Environmental Protection Agency (U.S. EPA) is the lead agency for the
implementation of the remedial action. The Illinois Environmental Protection Agency
(IEPA) serves as the support agency for Site activities, as described in the National
Contingency Plan (NCP), 40 C.F.R. § 300.500 - 300.515.

B. Statement of Purpose and Statutory Basis

This decision document sets forth the basis for issuing an Explanation of Significant
Differences (ESD) to the September 11, 2012 Record of Decision (ROD) for the OAZ
Site. U.S. EPA is issuing this ESD in accordance with Section 117(c) of the
Comprehensive Environmental Response, Compensation, and Liability Act, as amended
(CERCLA), 42 U.S.C. § 9617(c), and Section 300.435(c)(2)(i) of the NCP, 40 C.F.R. §
300.435(c)(2)(i).

An ESD is appropriate when the lead agency determines that the remedial action at a site
differs significantly in scope, performance, or cost from the selected remedy, but the
change to the remedial action does not fundamentally alter the selected remedy. The
purpose of an ESD is to describe the differences between the remedial action being
undertaken and the remedial action set forth in the ROD, and to explain the reasons such
changes are being made.

U.S. EPA, in consultation with IEPA, has determined that the adjustments to the remedial
action selected in the ROD that are described in this ESD are significant but do not
fundamentally alter the overall remedy for the site. Specifically, U.S. EPA is issuing this
ESD to document an increase in the estimated cost of the remedial action selected in the
ROD. Cost estimates presented in a ROD are expected to be accurate within a range of
+50% to -30%. Since issuance of the ROD for the OAZ Site, the estimated cost of the
remedial action has increased 291% above the cost estimate in the ROD, representing a
significant difference. This ESD also clarifies certain aspects of the ROD and adds
institutional controls (ICs) and engineering controls for additional areas of the Site,
namely for two areas containing structures such as building slabs and a parking lot which
are expected to remain in place under the selected remedy.

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This ESD serves to document the above changes to the remedial action and provide an
explanation for the significant differences.

This ESD, and all the technical information and data relating to it, shall become part of
the Administrative Record for the Site in compliance with Section 300.825(a)(2) of the
NCP, 40 C.F.R. § 300.825(a)(2). The Administrative Record for the OAZ Site is
available for viewing at the following information repository locations:

• Fairmont City Library Center
2870 N. 44th Street
Fairmont City, IL 62201
(618) 482-3966

• Fairmont City Village Hall
2601 North 41st Street
Fairmont City, IL 62201

• U.S. EPA, Region 5
Superfund Records Center

77 W. Jackson Blvd., 7th floor
Chicago, Illinois 60604

II. SITE HISTORY, CONTAMINATION, AND SELECTED REMEDY

A. Site History

The OAZ Site includes a former zinc smelter facility located in Fairmont City, St. Clair
County, Illinois. U.S. EPA has identified the following potentially responsible parties
(PRPs) for the Site: 1) Blue Tee, Inc. ("Blue Tee"), corporate successor to historical long-
term (> 50 years) owner-operator; 2) XTRA Intermodal, Inc. ("XTRA"), one-time
lessor/current owner of Site property (since 1976); and 3) federal General Services
Administration (GSA), successor to lessee and one-time principal operator of the Site
facility during and after World War II.

In addition to the closed metals processing facility (the "Facility Area"), which
encompasses approximately 132 acres, the OAZ Site includes adjacent residential and
other areas where Site contamination exists. Most of the Site contamination is located
within St. Clair County, Illinois. However, the results from U.S. EPA's remedial design
(RD) sampling indicate that some Site contamination is located within Madison County,
Illinois. The dividing line between these two counties is shown in Figure 1.

The Facility Area was historically used as a primary zinc smelter between 1916 and 1953
and produced slab zinc, zinc carbonate, cadmium, lead, and sulfuric acid. The primary
residue generated during the smelter's operation was slag which was poured along the
northern and western boundary of the Facility Area in a molten state and allowed to cool
over time. According to historical aerial photographs, the slag piles were located along
the western and northern boundaries of the Facility Area and originally encompassed

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more than 15 acres. The vitrified slag was allegedly transported to areas outside the
Facility Area by employees from the village, local business personnel, and area residents,
for use as fill and surfacing material.

The zinc furnace operations ceased in 1953, with subsequent operations limited to
roasting ores for other smelter facilities and the production of sulfuric acid. These
roasting operations continued until 1967 when American Zinc discontinued all
operations. Based on aerial photographs, all buildings and other facilities associated with
former smelting operations were razed between 1967 and 1978.

XTRA leased the Facility Area property from American Zinc (now Blue Tee Corporation
or Blue Tee) between 1976 and 1979 and purchased the property in 1979, including the
clinker and other smelter residues, minerals or metals located on the property. From 1976
to sometime after 2003, XTRA operated a transport trucking terminal on the Facility
Area which included the lease, storage, and maintenance of a diverse fleet of over-the-
road trailers, intermodal (also known as "piggy-back") trailers, and intermodal
equipment. Beginning in 1976, XTRA ground and redistributed the stockpiled slag across
the Facility Area to build up and level the Facility Area for its trucking operations.

B. Site Contamination and Enforcement Actions

Initial investigations of the Site were conducted by IEPA in 1994 in response to citizen
complaints of blowing dust from the Facility Area resulting from grinding of vitrified
slag by XTRA for use as structural fill for its operations. An additional investigation was
conducted by Ecology & Environment for U.S. EPA in 1999 that included the collection
of soil and sediment samples from the Facility Area and adjacent residential properties.
The sampling conducted by U.S. EPA and IEPA found heavy metals in Facility Area
slag, soils, stream sediments, and adjacent residential properties at levels greater than
background or risk-based screening levels.

Based on these sampling events, U.S. EPA requested that PRP Blue Tee perform a time-
critical removal action (TCRA) at the Site. On July 21, 2000, U.S. EPA signed the initial
Action Memorandum to conduct a time-critical removal action. PRP Blue Tee entered
into an Administrative Settlement Agreement and Order on Consent (AOC) with U.S.
EPA on March 22, 2002, under which Blue Tee agreed to conduct a TCRA to address
soils containing lead concentrations above the action level of 400 milligrams per
kilogram (mg/kg) for residential properties and 1,000 mg/kg for commercial/industrial
properties. Vacant lots were also sampled as part of the TCRA and a removal action was
taken at vacant lots located adjacent to residential areas if the vacant lots had soil lead
concentrations greater than 1,200 mg/kg.

The 2002-2003 TCRA included the sampling of 462 residential, commercial/industrial
and vacant properties for lead, arsenic, cadmium and zinc. Of the 462 properties sampled
during the TCRA, 209 properties were found to have soil lead concentrations greater than
the U.S. EPA-approved action levels. Of these, soil removal actions were performed on
152 properties. The remaining 57 properties were composed of 49 vacant lots with soil
lead concentrations less than 1,200 mg/kg, and eight residential properties where

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permission to conduct the removal action was not granted by the property owner. The
excavated soils from the TCRA were placed in a temporary stockpile located on the north
side of the Facility Area immediately south of the existing slag piles.

On June 6, 2005, PRPs Blue Tee and GSA entered into an AOC to conduct a Remedial
Investigation and Feasibility Study (RI/FS) for the OAZ Site. U.S. EPA issued a
Unilateral Administrative Order to PRP XTRA on June 6, 2005, directing XTRA to
participate and cooperate with the PRPs performing the RI/FS under the AOC. An RI was
conducted at the Site from May 2006 to January 2008. Additional properties within the
adjacent residential area were sampled to conduct a Human Health Risk Assessment. A
portion of the village alleyways were also sampled.

Based on the findings of the investigations, U.S. EPA issued a ROD on September 11,
2012. The major components of the selected remedy in the ROD include: excavation of
contaminated soil inside and outside of the Facility Area; consolidation of excavated soil
into an area on the facility property; capping the consolidated contaminated soil with a
24-inch low permeability, compacted soil barrier layer and a 12-inch vegetation cover
system; implementing ICs; establishing a groundwater management zone; and conducting
groundwater monitoring. The contaminants of concern (COCs) at the Site are lead,
arsenic, cadmium, zinc, and manganese.

In 2014, U.S. EPA entered into an AOC with PRPs Blue Tee and GSA for conducting the
RD of the selected remedy. In the 2015 pre-design investigation, additional data was
collected from the Facility Area and from 14 adjacent residential, commercial, and/or
vacant properties in order to complete the RD. However, in 2016, the entity responsible
for financing PRP Blue Tee's work at the Site filed for bankruptcy and stopped paying
for the work, and PRP Blue Tee ceased performance of the RD. On December 6, 2016,
U.S. EPA notified the PRPs that U.S. EPA was taking over the work in order to complete
the RD at the Site.

On April 7, 2016, U.S. EPA published Superfund's National Priorities List (NPL) Final
Rule in the Federal Register (81 FR 20252). This final rule added the OAZ Site to the
NPL.

After U.S. EPA took over the RD work, U.S. EPA identified some data gaps in PRP Blue
Tee's work. U.S. EPA decided to expand the scope of the sampling effort in the adjacent
residential area and conducted additional sampling of more than 400 residential
properties and alleyways in 2017 and 2018.

On May 10, 2018, U.S. EPA approved an Action Memorandum to conduct a second
TCRA at the Site. The 2018 TCRA addressed approximately 65 properties which
contained lead- and arsenic-contaminated slag, and 4 village-owned alleyways
contaminated with slag.

C. Selected Remedy

The following are the major components of the remedy selected in the ROD:

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•	Excavation of all Facility Area source materials and affected soils exceeding the
residential human health Cleanup Levels (CLs) and consolidation in a 3 5-acre
consolidation area located on the Facility Area.

•	Excavation of buried tarry materials on the Facility Area and characterization
prior to transport off-site for disposal.

•	Excavation of affected grey powdery materials in a low-lying unvegetated area to
a depth of 1 foot, and consolidation of this material in the 3 5-acre consolidation
area.

•	Excavation of above-ground and subsurface demolition debris and concrete
outside the 35-acre consolidation area, with crushing of the concrete above and
below grade, as necessary, for cover system stability before construction of the
cover system.

•	Excavation of affected soils from the identified residential, commercial/industrial
or vacant properties or village alleyways (collectively known as "surrounding
properties") with COCs above the applicable residential or commercial/industrial
human health CLs and consolidation of these excavated soils within the 35-acre
consolidation area, followed by backfilling with clean fill and restoring the
properties.

•	Excavation of affected sediments within ditches or Rose Creek exceeding the
applicable human health or ecological CLs and consolidation of these affected
sediments within the 35-acre consolidation area.

•	Installation of a cover system across the 35-acre consolidation area that consists
of a 24-inch low permeability, compacted soil barrier layer with a hydraulic
conductivity no greater than lxlO"7 with a 12-inch vegetated layer (total cover of
36 inches).

•	Use of available on-site borrow soils meeting applicable CLs from areas outside
the 35-acre consolidation area to reduce the required volume of off-site imported
fill needed to construct the cover system.

•	Grading of excavated areas to sustain positive drainage.

•	Implementation of land use restrictions to maintain commercial/industrial land
use on the 35-acre consolidation area on the Facility Area.

•	Implementation of land use restrictions to maintain commercial/industrial land
use on select commercial/industrial and vacant surrounding properties that are not
likely to be used for future residential development.

•	Implementation of groundwater restrictions to prohibit well installation and use of
shallow affected groundwater.

•	Surface water monitoring to verify the effectiveness of the remedy on reducing
transport of COCs via stormwater run-off to the man-made ditches.

•	Groundwater monitoring to ensure that COCs in shallow groundwater are not
migrating off the Facility Area at concentrations exceeding upgradient
concentrations. If a statistically significant increase in groundwater concentrations
is observed over time, the remedy will be re-evaluated.

6

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•	Implementation of land use controls to record the presence of buried waste and
prohibit the disturbance of the cover system.

•	Implementation of long-term operation and maintenance activities to maintain the
integrity of the cover system and other components of the remedy.

•	Establishment of a groundwater management zone pursuant to regulations in the
Illinois Administrative Code related to Groundwater Quality (35 IAC, Subtitle F,
Chapter I, Part 620).

•	Pre-remedial design activities necessary for development of the RD including, but
not limited to: 1) confirmation of the downgradient extent of the shallow
groundwater exceedances of applicable Illinois Class I standards, Illinois Class II
standards, or federal maximum contaminant levels and/or to obtain statistically
supportable background metal concentrations; 2) soil sampling of the 29
residential, commercial/industrial or vacant properties sampled as part of the
TCRA or RI that require additional data to determine if action is required as part
of the final remedy, or where access was previously denied during the TCRA and
RI.

•	Obtaining access agreements from all affected property owners in order to
implement the selected remedy.

•	Installation of temporary fencing around the work areas for public safety.

•	Location, marking, and notation of all utilities prior to any intrusive activities.

•	Control of fugitive dust from the work areas during remediation through the use
of misters or water spraying for worker protection and to prevent air-borne
migration of metals via dust to the surrounding community.

•	Use of best management practices and engineered controls (i.e. silt fencing,
diversion ditches, etc.) to control erosion and surface water run-on and run-off in
work areas in accordance with the site-specific Erosion Control Plan and
Stormwater Pollution Prevention Plan to be generated as part of the pre-
mobilization activities.

•	Use of an appropriate level of personal protective equipment during work
activities based on previous experience with investigations conducted at the Site
and in accordance with a site-specific Health and Safety Plan.

Specific actions prescribed under the selected remedy are detailed in the ROD.

III. BASIS FOR HI! DOCUMENT

The purpose of this document is to explain the difference in cost in the selected remedy
for the OAZ Site, add ICs for the Site buildings and parking lot, and clarify certain
aspects of the selected remedy.

U.S. EPA took over work from PRP Blue Tee during the RD phase. U.S. EPA developed
and finalized a Basis of Design Report (BODR) for the Facility Area and a BODR for the
Surrounding Properties. The BODRs were based on both the Draft Final Remedial
Design Report developed by PRP Blue Tee and the ROD. Both BODRs developed by
U.S. EPA assumed that U.S. EPA, rather than a performing PRP, would conduct the

7

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remaining work at the Site. U.S. EPA determined that the cost estimate developed by
PRP Blue Tee during the FS, which was then included in the ROD, was missing several
components and underestimated several other components. The differences in the cost
estimates are detailed in Section IV below. The Administrative Record has been updated
to include these documents and other relevant documents supporting this ESD.

Further descriptions of the changes are provided below. With these changes, the selected
remedy will continue to be protective and meet applicable or relevant and appropriate
requirements. In addition, all remedial action objectives remain unchanged and will
continue to be met. Because contamination will remain onsite at levels that do not allow
for unrestricted use and unlimited exposure, five-year reviews of the selected remedy for
the Site will be required.

IV. DESCRIPTION OF SIGNIFICANT DIFFERENCES

The ROD cost estimate projected that the selected remedy would cost $11,335,000, and
that the RD would cost $100,000, for a total cost of $11,435,000. The recent BODRs
contain revised cost estimates based on new and/or updated information. The BODRs
estimate that the remedial action will cost an estimated $44,365,441 to implement, 291%
greater than the original cost estimate.

There are several reasons why the final remedial design cost estimate is significantly
higher than the ROD cost estimate. One of the major reasons is that several of the
components needed to implement the remedy were either underestimated or not
considered in the ROD cost estimate1 developed by PRP Blue Tee during the FS.

The major components that were either not considered or underestimated in the ROD cost
estimate that are driving the increase in cost are: remediation of the surrounding
properties; slag removal, hauling, and placing in the consolidation area; clay/borrow
removal, hauling, placing, and compaction in consolidation area and other on-site areas;
topsoil purchase and placing across the Site; clearing and grubbing; and project and
construction management costs. Table 1 contains a detailed breakdown of the cost
changes and shows which remedy components were either underestimated or not
included in the ROD cost estimate. The overall remedy has not changed except for the
additional ICs and remedy clarifications described in this ESD.

Another reason why the cost estimate in the final remedial design is higher than the ROD
cost estimate is because the design process revealed new information that, when
incorporated in the cost estimate, increased the estimated cost of the remedy. Pre-design
activities were conducted at the Site to further characterize the Facility Area and the
surrounding properties. The results indicate that the top soil needed as part of the Site
remedy is not available on site, as anticipated in the ROD, and will need to be purchased
and transported to the Site. The ROD also underestimated the amount of top soil that will
be required. Additionally, the ROD cost estimate did not take into account the amount of

1 It should be noted that estimated costs for several major remedy components of the other alternatives
evaluated in the ROD were also either underestimated or not considered. Therefore, costs for all the
original ROD alternatives (except the No Action alternative) would increase significantly.

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clay needed to grade the Site, nor that the clay located on site will need to be excavated in
the location of the consolidation area and that excavation of contamination will be needed
in order to retrieve the clay. The sampling results from the surrounding properties also
increased the number of such properties that need remediation, although the ROD cost
estimate appears to not have included the cost of remediating surrounding properties or
minimally included them as part of the excavation costs. The cost estimate in the BODR
for the Surrounding Properties, which addressed approximately 67 surrounding properties
and 9 alleyways, is provided in Table 2 and resulted in an average per-property
remediation cost of $55,000 (see footnote 3 of Table 1). The cost estimate in the BODR
for the Surrounding Properties Addendum 1, which addressed approximately 84
properties and 1 alleyway, is provided in Table 3. However, U.S. EPA estimates that an
additional 41 surrounding properties not included in either the BODR for Surrounding
Properties or its Addendum 1 will likely need to be remediated. These additional
properties will be included in a future addendum to the BODR but are already included in
the revised cost estimate described in this ESD, shown in Table 1.

Though the ROD cost estimate did not include specific details, U.S. EPA assumes that
PRP Blue Tee, when developing the cost estimate, used lower labor rates than what
would be required if U.S. EPA implemented the remedy. The selected remedy had been
expected to be implemented by PRPs but is now expected to be implemented by U.S.
EPA.

The ROD cost estimate also did not include the line items associated with the cost of
project management and construction management to oversee the implementation of the
remedial action (see Table 1). These line items include contractor general and
administrative costs, contractor fee, program support, and professional liability insurance.
These costs are generally estimated to be about 11 percent of the construction costs for
the remedial action.

The ROD estimated the timeframe to implement the remedy to be 10 months. However,
based on the BODRs and the likelihood that U.S. EPA will need to incrementally fund
the cleanup work, U.S. EPA now estimates that the remedy will take 26 to 48 months to
complete.

The buildings currently located on the Facility Area portion of the Site, as well as the
current parking lot around the main building, were built by PRP XTRA and are not part
of the original smelter facility. Thus, demolition of the buildings and removal of the
parking lot was not (and still are not) included as part of the selected remedy. However, it
is likely that contamination is located beneath the buildings and parking lot. Therefore,
ICs are required to ensure that building slabs/foundations and the parking lot around the
main building remain in place and in intact condition to serve as engineering controls to
prevent human exposure to the underlying contamination. The ICs and engineering
controls for these areas of the Site will serve to prohibit the disturbance and/or removal of
the existing building foundations/slabs and parking lot without prior written approval of
the U.S. EPA (in consultation with IEPA) or unless addressed by an approved Soil
Management Plan. The specific areas of PRP XTRA's buildings and parking lot are
shown in Figure 2. The two purple-outlined areas are where the newly-required ICs and

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engineering controls have been added to the selected remedy. Figure 2 also shows the
approximate location of the consolidation area, outlined in blue, where ICs were already
required by the ROD (i.e., maintain commercial/industrial land use, record the presence
of buried waste and prohibit the disturbance of the cover system). The recording of an
environmental restrictive covenant in accordance with the Illinois Uniform
Environmental Covenants Act, noting the presence of buried waste and provisions to
prevent disturbance of the cover system and/or engineering controls, is required for not
only the consolidation area but also the two specified areas containing existing buildings
and a parking lot.

In addition to the changes described above, this ESD also clarifies other aspects of the
ROD, as follows:

•	The ROD calls for the excavation of affected soils from the identified residential,
commercial/industrial or vacant properties or village alleyways (surrounding
properties) with COCs above the applicable residential or commercial/industrial
human health CLs and consolidation of these excavated soils within the 3 5-acre
consolidation area, followed by backfilling with clean fill and restoring the
properties. This remedy component has not changed. However, the ROD
specifically identified some affected properties, which were listed in Table 1 of
the ROD. To clarify, that list was not intended to be exhaustive of all properties to
be sampled or remediated at the Site. During the RD, additional properties in the
project area were sampled and found to require remediation, and additional
properties remain to be sampled, some portion of which are likely to require
cleanup. This ESD clarifies that the list in Table 1 of the ROD was the list of
identified properties at the time the ROD was issued that needed sampling and/or
remediation. The intent of the ROD-selected remedy was to address all impacted
surrounding properties. The revised cost estimate in this ESD addresses an
estimated 193 properties and 10 alleyways that will likely need to be cleaned up
during the remedial action. The final number of properties requiring remediation
will not be known until all remedial design sampling is complete.

•	In the ROD, one portion of the remedy description states that the borrow materials
would come from areas "outside" the 35-acre consolidation area, but other
sections of the ROD state that the use of available on-site borrow soils meeting
applicable CLs would be used to the extent practicable to construct the cover
system. The original intent of the selected remedy is reflected in language
contained in the FS and the Proposed Plan, with neither document specifying that
the materials would come only from outside the consolidation area. PRP Blue Tee
(who prepared the FS and the Draft Final Remedial Design Report prior to
ceasing work at the Site) anticipated that borrow materials would be retrieved
from under the location of the consolidation area, and this assumption is detailed
in the FS Report and Draft Final Remedial Design Report. This ESD therefore
clarifies and revises the 8th remedy-component bullet in Section II.C ("Selected
Remedy") above. Instead of saying, "Use of available on-site borrow soils
meeting applicable CLs from areas outside the 35-acre consolidation area to
reduce the required volume of off-site imported fill needed to construct the cover
system," the corrected wording of that remedy component is as follows:

10

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o Use of available on-site borrow soils meeting applicable CLs to reduce the
required volume of off-site imported fill needed to construct the cover
system.

V.	SUPPORT AGENCY COMMENTS

IEPA, as the support agency, has reviewed and supports the modifications to the remedy
described in this ESD. Appendix A contains IEPA's written concurrence with this ESD.

VI.	STATUTORY DETERMINATIONS

With the changes described in this ESD, the remedy for the OAZ Site will continue to
comply with Section 121 of CERCLA. The modified remedy will be protective of human
health and the environment, complies with the federal and state requirements which are
applicable or relevant and appropriate to the remedial action (or justifies a waiver), and is
cost-effective. Since wastes will be left in place at the site above concentrations that
allow for unlimited use and unrestricted exposure, five-year reviews will be conducted to
ensure that the remedy remains protective of human health and the environment, in
accordance with CERCLA Section 121 and the NCP.

VII.	PUBLIC PARTICIPATION COMPLIANCE

U.S. EPA will make this ESD available to the public by placing it in the Administrative
Record which is available at the information repository locations listed above in Section
I.B. In coordination with IEPA, U.S. EPA also will ensure that a notice that briefly
summarizes this ESD and provides a basic reason for the remedy changes is published in
a newspaper of local circulation after the ESD is approved. By so doing, U.S. EPA will
meet the public participation requirements of Section 300.435(c)(2)(i) of the NCP, 40
C.F.R. § 300.435(c)(2)(i). EPA has allocated funds for placing such a notice.

VIII.	AUTHORIZING SIGNATURE

Approved by:

6/14/2019

X			

Douglas Ballotti, Director

Superfund & Emergency Management Divisi...

Signed by: brown.jaime@epa.gov

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FIGURES

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iChlcago

Site
Location

25 CJylds St

Fairmont City

Maple

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Washington
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Forest Btvd

Watts Ave

Linden Ave

Audubon Ave

Audubon Ave

	

1,600

	I

Legend

County Boundary

[	] Facility Area Boundary

Surrounding Properties Boundary (Approximate)

Notes:

1 Basemap provided by ArcGIS Online World Street Map.

Figure 1

Site Location Map

Old American Zinc Plant Superfund Site
Fairmont City, Illinois

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TABLES

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Old American Zinc Plant Superfund Site
Table 1: Remedial Action Cost Estimate Comparison

Item

Qty

ROD Cost Estimate

Remedial Design Cost
Estimate

Difference ($)

% Change

Pre-construction Activities

Implementation Plans/Submittals

$ 120,000

$ 50,000

$ (70,000)

-58%

Post Design Support

$ 556,300

100%

Pre-construction Meeting

$ 5,075

100%

Construction Activities

Mobilization/Site Setup

$ 181,500

$ 109,245

$ (72,255)

-40%

Survey I

$ 116,000

$ 138,240

$ 22,240

19%

Cone Penetration Test (CPT)

$ 130,800

100%

Temporary Facilities

$ 83,835

100%

Install/Maintain erosion controls

$ 61,295

100%

Clearing & Grubbing

$ 658,625

100%

Air Monitoring

$ 229,000

100%

Stormwater Management

$ 87,500

$ 442,092

$ 354,592

405%

Culvert Installation

$ 24,960

100%

Culvert Installation

$ 5,250

100%

Wheel Wash Decon Pad

$ 13,800

100%

Construction Entrance Stabilization

$ 143,000

100%

Double Swing Gate

$ 7,356

100%

Double Sliding Gate

$ 24,752

100%

Permanent Fencing

$ 123,596

100%

Temporary Fencing

$ 48,400

100%

Decommissioning Wells

$ 6,600

100%

Well Installation

$ 36,000

$ 30,600

$ (5,400)

-15%

Intial Well Monitoring

$ 15,531

100%

Pulverizing Concrete Foundations

$ 190,000

100%

Slag Removal Continuous Operation

$ 4,732,750

$ 3,123,600

$ (1,609,150)

-34%

Clay Removal to Stockpile

$ 2,093,473

100%

Slag Haul and Place in Consolidation Area

$ 3,548,434

100%

Clay Haul and Place in Consolidation Area

$ 566,000

$ 2,415,546

$ 1,849,546

327%

Compact Clay

$ 445,606

100%

Grade Site using Clay

$ 62,650

100%

Stockpile Management

$ 925,650

100%

Topsoil Layer

$ 1,415,000

$ 6,531,360

$ 5,116,360

362%

Seed, Mulch, Erosion Matting

$ 52,500

$ 311,000

$ 258,500

492%

Landscape Warranty

$ 37,320

100%

Site Cleanup

$ 24,736

100%

Final Survey

$ 15,097

100%

Confirmation/Verification Sampling

$ 168,000

$ 82,655

$ (85,345)

-51%

Demobilization

$ 75,000

$ 50,127

$ (24,873)

-33%

Post Construction Activities

Institutional Controls

$ 12,000

$ (12,000)

-100%

Non-Hazardous Waste T&D

$ 13,500

100%

Long Term Groundwater and Surface water monitoring

$ 495,929

100%

Long Term Maintenance

$ 1,133,000

$ 781,351

$ (351,649)

-31%

Final Report

$ 60,000

$ (60,000)

-100%

Payment and Performance Bond

$ 368,550

$ 601,410

$ 232,860

63%

Contingency

$ 1,474,200

$ 3,608,458

$ 2,134,258

145%

Subtotal:

$ 10,598,000

$ 28,266,254

$ 17,668,254

167%

Project Management/Construction Management

Project Management

$ 1,413,313

100%

Construction Management

$ 1,695,975

100%

Oversight Costs

$ 737,100

$ (737,100)

-100%

Total Capital Cost of Facility Area:

$ 11,335,100

$ 31,375,541

$ 20,040,441

177%

Surrounding Properties Construction Cost Estimates

RA Cost Estimate in BODR Surrounding Properties Remedial Design1

$ 4,054,900

100%

RA Cost Estimate in BODR Surrounding Properties Remedial Design Addendum2

$ 6,680,000

100%

RA Cost Estimate for Additional Surrounding Properties3

$ 2,255,000

100%

Subtotal of Surrounding Properties:

$ 12,989,900

100%

Selected Remedy Cost Estimate:

$ 11,335,100

S 44.365.441

$ 33,030,341

291%

+20%

S 53,238,530

-15%

S 37,710,625

' See Table 2 for detailed cost estimate from BODR Surrounding Properties Remedial Design
' See Table 3 for detailed cost estimate from BODR Surrounding Properties Remedial Design Addendum 1

' Assumes construction cost of $55,000 per property average based on Final Basis of Design Report for Surrounding Properties. Assumes 40% of unsampled properties (~41 properties) need to be remediated

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Table 2: Remedial Action Cost Estimate in Basis of Design Report - Surrounding Properties Remedial Design

Old American Zinc Plant Superfund Site Surrounding Properties
St. Clair County, Illinois

Item

Qty

Unit

Unit Price

Total (Rounded)

Notes

Work Plan, HASP/AHAs, schedule, training, premobilization submittals, performing initial borrow

source sampling. Includes costs for submittal reviews and revisions. Pricing based on recent

Pre-construction Activities

29,432

29,400

project experience.

Preparation of QAPP/QAPP Amendment, sample collection, and laboratory analysis. Assume 20

Correlation Study

50,000

samples. To be performed concurrent with preconstruction activities.

Coordination Meeting

2,522

2,500

Coordination meeting with city, county, and township representatives.

Mobilize and demobilize equipment and materials to site and prepare staging areas. Document

existing condition of haul routes with photos and videos. Pricing based on recent project

Mobilization

86,746

86,700

experience.

Setup Facilities

48,982

49,000

Setup construction trailer, temporary SESC measures, facilities, stockpile areas, parking areas.

Assume three (3) public meetings throughout the course of construction. Each meeting included

Community Relations, three (3) mtgs

5,728

5,700

labor for preparation and attendance.

Labor, equipment, and materials to conduct air monitoring at residential properties and the FA,

Air Monitoring

155

385

59,700

throughout the project construction.

Document existing property condition with digital photos and videos. Attendees include owner's

representative, contractor, and landscaping subcontractor to prepare plant inventory. Assumes

Initial Preconstruction Meeting

566

38,500

one meeting with Village to go over all alleyways.

Document Property Owner approval of the work to be performed. Attendees include owner's

Second Preconstruction Meeting

293

19,600

representative, contractor, and landscaping subcontractor to prepare plant inventory.

Clear & Grub grasses and root systems, removal of trash, debris, shrubs, swing sets, benches,

Clearing and Site Preparation at Properties

934

62,600

and other obstructions.

Transport Yard Waste to FA - Mixed

1,200

Transport of trees, shrubs, miscellaneous wood, metal, and debris. Assume 0.5 ton per property.

Tree Removal (2"-4" dia)

796

2,400

Based on actual costs incurred on a similar project (USS Lead).

Excavation with a small excavator and some by hand. Signage and protective measures for

pedestrian traffic on sidewalks or streets, as required. SESC measures as required. Assumes

Excavation

12,130

BCY

739,900

overexcavation of some properties based on COC concentrations.

High visibility fencing for excavations completed to 30 inches, and XRF screening results are

Demarcation Fabric

17,100

above screening criteria. Estimated based on COC concentrations at maximum sample depth.

Transportation of soil to the Facility Area. Conversion from BCY to TN based on what is being

Transport Excavated Material to FA

16,980

84,900

seen on other similar projects in the region.

Assumes 2.5 acre footprint, covered with 4-in of topsoil and a single seeding of completed

Stabilize Stockpile

92,452

92,500

stockpile.

Includes assistance with QA/QC sampling, purchase/delivery, installation, compaction, and

Backfill - General

5,760

BCY

276,500

density testing of general backfill. Includes additional fill material for overexcavation.

Backfill - Topsoil

5,580

BCY

340,400

Includes assistance with QA/QC sampling, purchase/delivery, and installation of topsoil.

Backfill - Select Topsoil

BCY

3,100

Includes assistance with QA/QC sampling, purchase/delivery, and installation of select topsoil.

Placed before the CA-6 material in alleyways where excavation depth exceeds 18 inches.

Backfill - CA-1 Aggregate

194

9,500

Assumed 6-inch depth.

Includes assistance with QA/QC sampling, purchase/delivery, installation, compaction, and

Backfill - CA-6 Aggregate

1,340

65,700

density testing of gravel (IDOT CA-6).

Street Sweeping

5,623

39,400

Performed from start of excavation through topsoil placement.

Landscape - Supply/Plant Perenials

100

4,200

HCSS Estimate

Landscape - Supply/Plant Shrubs

139

11,400

HCSS Estimate

Landscape - Supply/Plant Trees

527

1,600

Based on RSMeans

Includes 6-week maintenance/watering period for each property (for up to a total of 10 watering

Restoration - Seeding Application and Maintenance

312

MSF

765

238,700

events per property).

Allowance for reseeding and trees for replacement. Assume 12% of total landscaping/seed

Landscape Warranty/Replacement

30,703

30,700

placement costs.

Restoration - Wood Mulch

1,200

Placement in garden areas, 3-inches thick.

Restoration - Rock Mulch

138

1,400

Placement in garden areas with existing rock mulch, 3-inches thick.

Restoration - Weed Block

2,200

0.29

600

Place beneath wood mulch and rock mulch.

Restoration - Drain Tile Repair

3,500

17,500

Allowance

Assume 10 feet of repair at each property where access will occur from/over sidewalk (assumed

Restoration - Concrete Repair

150

559

83,900

30 properties). Assume 6-inches thick and 4.500 PSI

Restoration of any damaged asphalt during backfill and restoration activities. Assume 3-inches

Restoration - Asphalt

2,500

15,000

thick. IDOT A-3 surface material.

Fence Replacement - Chain Link

170

5,800

Assume 2 8-ft panels replaced at 15% of properties

Document issues identified during work, outstanding punch list items, and substantial

completion at the property. Attendees include owner's representative, contractor, and

landscaping subcontractor to prepare plant inventory. Assumes one meeting with Village to go

Post Construction Meeting

276

18,500

over all alleyways.

Analytical Sampling

1,223

14,700

Initial and QA/QC samples for general backfill, topsoil, etc.

XRF Rental

3,000

21,000

XRF rental for duration of project.

Demobilization

34,804

34,800

Payment and Performance Bond

2.50%

2,577,300

64,400

Contingency

15%

2,577,300

386,600

Escalation - Project to be executed in 2019

3,028,300

90,800

SUBTOTAL CONSTRUCTION

3,119,100

Optional Items

Utility Locates

TBD

260

Unit pricing for utility locating, if determined necessary by owner's representative.

Unit pricing for surveying, if determined necessary by owner's representative. Assumes a

Surveys

TBD

409

minimum 10 by-10 foot grid and then use of a level and rod to measure elevations.

Labor, equipment and materials to shape/compact stockpile and removal/placement of poly

Excavated Soil Staging Pile Management

122,400

sheeting on working face, as determined necessary by owner's representative.

Project Management/Construction Management

Administration/Contractor Oversight

25%

3,119,100

779,800

CM, H&S, and CQM onsite, PM time

Owner's Representative Markup

3,119,100

156,000

per contract rates

Total Capital Cost:

4,054,900

CLASS 2 RANGE:

20%

4,865,900

-15%

3,446,700

This construction cost estimate is not an offer for construction and/or project execution. The construction cost estimate for this Design is an Association for the Advancement of Cost Engineering (AACE) Class 2 estimate and is assumed to represent the actual
total installed cost. The estimate above is considered control-level cost estimating, suitable for use in project budgeting and planning. This estimate has been prepared with partial design and engineering calculations. The level of accuracy for the class of
estimate defines the upper and lower ranges of the cost estimate. It is based upon the level of design detail and uncertainty associate with that level of detail. For a Class 2 estimate, the accuracy range is +20% to -15%. It would appear prudent that internal
budget allowances account for the highest cost indicated by this range as well as other site specific allowances. The cost estimate has been prepared for guidance in project evaluation and implementation from the information available at the time of the
estimate. The final costs of the project will depend on actual labor and material costs, competitive market conditions, implementation schedule, and other variable factors. As a result, the final project costs will vary from the estimates presented herein.
Because of this, project feasibility and funding needs must be carefully reviewed prior to making specific financial decisions to help ensure proper project evaluation and adequate funding.

Page 1 of 1

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Table 3: Remedial Action Cost Estimate in Basis of Design Report - Surrounding Properties Remedial Design Addendum 1

Old American Zinc Plant Superfund Site Surrounding Properties, Addendum 1
St. Clair County, Illinois

Item

Qty

Unit3

Unit Price

Total (Rounded)

Notes

Preconstruction Activities

Correlation Study

Coordination Meeting

Setup Facilities

Community Relations, three (3) mtgs

Air Monitoring

Initial Preconstruction Meeting

Second Preconstruction Meeting

Clearing and Site Preparation at Properties

Transport Yard Waste - Mixed
Tree Removal (2"-4" dia)

42 TN
19 EA

Demarcation Fabric

Transport Material to Facility

Stabilize Staging Pile

Backfill - General
Backfill - Topsoil
Backfill - Select Topsoil
Backfill - CA-1 Aggregate
Backfill - CA-6 Aggregate
Street Sweeping

Landscape - Supply/Plant Perenials
Landscape - Supply/Plant Shrubs
Landscape - Supply/Plant Trees

Landscape - Warranty/Replacement

Restoration - Seeding and Maintenance
Restoration - Wood Mulch
Restoration - Rock Mulch
Restoration - Weed Block
Restoration - Drain Tile Repair

Restoration - Concrete Repair

Restoration - Asphalt
Fence Replacement - Chain Link

Post Construction Meeting
Analytical Sampling

85 EA
28 EA

Demobilization

Payment and Performance Bond

Contingency

2.50%
15%

LS
of

165 DY $

58,167 SF

33,930 TN $

1 LS

11,278 CY

11,838 CY

204 CY
LS

722 TN

7 MO

150 EA

216 EA

19 EA

1 LS

645 MSF

5,513 SF
CY

5,513 SF

7 EA

5,000 SF
205 LF

415 $

527 $

283 $

1,024 $

9 $
885 $

24,235 BCY $ 61 $

2.01 $

76,103 $

48 $

60 $

75 $

- $

52 $

6,758 $

43 $

137 $

528 $

68,232 $

810 $

1 $

- $
0.29 $
3,782 $

550 $

10 $
32 $

270 $
1,150 $

3,000 $

4,373,200 $
4,373,200 $

Assume that properties in the addendum will be performed under the same Work Pan, Health
and Safety Plan/Activity Hazard Analyses, schedule, training, premobilization submittals, etc. as
the properties included in the Revised Final Design. Per email from U.S. Environmental Protection
Agency (EPA) on 5/2/2019, assume the same RA Contractor will remediate the properties and
alleyways included in Revised Final Design and the properties and alleyways included in
Addendum 1 under a single mobilization.

Assume that properties and alleyways in the addendum will be performed under the correlation
study completed for the properties included in the Revised Final Design.

Coordination meeting with city, county, and township representatives. Per email from EPA on
5/2/2019, assume the same remedial action (RA) Contractor will remediate the properties and
alleyways included in Revised Final Design and the properties and alleyways included in
Addendum 1 under a single mobilization. Additional meeting(s) for the properties and alleyways
included in Addendum 1 are not needed. Estimated costs for this meeting were included in the
Revised Final Design and therefore are excluded from the addendum.

Mobilize and demobilize equipment and materials to site and prepare staging areas. Document
existing condition of haul routes with photos and videos. Per email from EPA on 5/2/2019,
assume the same RA Contractor will remediate the properties and alleyways included in Revised
Final Design and the properties and alleyways included in Addendum 1 under a single
mobilization. Estimated costs for mobilization were included in the Revised Final Design and
therefore are excluded from the addendum.

Setup construction trailer, temporary soil erosion and sedimentation control measures, facilities,
stockpile areas, parking areas. Per email from EPA on 5/2/2019, assume the same RA Contractor
will remediate the properties and alleyways included in Revised Final Design and the properties
and alleyways included in Addendum 1 under a single mobilization. Estimated costs for facilities
setup were included in the Revised Final Design and therefore are excluded from the addendum.

Assume three (3) public meetings throughout the course of construction. Each meeting included
labor for preparation and attendance. Per email from EPA on 5/2/2019, assume the same RA
Contractor will remediate the properties and alleyways included in Revised Final Design and the
properties and alleyways included in Addendum 1 under a single mobilization. Estimated costs
for these meetings were included in the Revised Final Design and therefore are excluded from
the addendum.

Labor, equipment, and materials to conduct air monitoring at residential properties and
68,500 alleyways included in the addendum and the Facility Area throughout the project construction.

Document existing property condition with digital photos and videos. Attendees include owner's
44,800 representative, contractor, and landscaping subcontractor to prepare plant inventory.

Document Property Owner approval of the work to be performed. Attendees include owner's
24,100 representative, contractor, and landscaping subcontractor to prepare plant inventory.

Clear & Grub grasses and root systems, removal of trash, debris, shrubs, swing sets, benches, anc
86,000 other obstructions. Clearing and grubbing is not required for the alleyway.

400 Transport of trees, shrubs, miscellaneous wood, metal, and debris. Assume 0.5 ton per property.
16,800 Based on actual costs incurred on a similar project (USS Lead).

Excavation with a small excavator and some by hand. Signage and protective measures for
pedestrian traffic on sidewalks or streets, as required. SESC measures as required. Assumes
L,478,100 overexcavation of some properties based on contaminant of concern (COC) concentrations.

High visibility fencing for excavations completed to 30 inches, and XRF screening results are
116,900 above screening criteria. Estimated based on COC concentrations at maximum sample depth.

Transportation of soil to the Facility Area. Conversion from bank cubic yards (BCY) to ton (TN)
271,400 based on what is being seen on other similar projects in the region.

Labor, equipment, and materials to slope, shape, and manage material from addendum
properties and alleyways in the staging pile at the Facility Area. Assumes 5 acre footprint with 4
inches of topsoil placed over staging pile before hydroseeding. Includes costs for additional
topsoil and hydroseed of excavated material from properties included in addendum. Assumes
hydroseeding will be conducted under same hydroseeding event as properties in Revised Final
76,100 Design.

Includes assistance with quality assurance/quality control (QA/QC) sampling, purchase/delivery,
installation, compaction, and density testing of general backfill. Includes additional fill material
541,300 for overexcavation.

710,300 Includes assistance with QA/QC sampling, purchase/delivery, and installation of topsoil.

15,300 Includes assistance with QA/QC sampling, purchase/delivery, and installation of select topsoil.

Placed before the Illinois Department of Transportation (IDOT) CA-6 material in alleyways where
excavation depth exceeds 18 inches. Assumed 6-inch depth.

Includes assistance with QA/QC sampling, purchase/delivery, installation, compaction, and
37,500 density testing of gravel (IDOT CA-6).

Performed from start of excavation through topsoil placement for properties and alleyways
47,300 included in addendum.

6,500 Heavy Construction Systems Specialists (HCSS) Estimate
29,600 HCSS Estimate
10,000 Based on RSMeans.

68,200 Based on RSMeans. Assume 12% die off. Includes perennials, shrubs, trees, and seeding

Includes 6-week maintenance/watering period for each property (for up to a total of 10 watering
522,500 events per property).

5,500 Placement in garden areas, 3-inches thick.

Placement in garden areas with existing rock mulch, 3-inches thick.

1,600 Place beneath wood mulch and rock mulch.

26,500 Allowance

Assume 10 feet of repair at each property where access will occur from/over sidewalk (assumed
35,200 30 properties). Assume 6-inches thick and 4,500 pounds per square inch

Restoration of any damaged asphalt during backfill and restoration activities. Assume 3-inches
50,000 thick. IDOT A-3 surface material.

6,600 Assume 2 8-ft panels replaced at 15% of properties

Document issues identified during work, outstanding punch list items, and substantial
completion at the property. Attendees include owner's representative, contractor, and
landscaping subcontractor to prepare plant inventory. Assumes one meeting with Village to go
23,000 overall alleyways.

32,200 Initial and QA/QC samples for general backfill, topsoil, etc.

21,000 X-ray fluorescence (XRF) rental for properties and alleyways included in addendum.

Per email from EPA on 5/2/2019, assume the same RA Contractor will remediate the properties
and alleyways included in Revised Final Design and the properties and alleyways included in
Addendum 1 under a single mobilization. Estimated costs for demobilization were included in
the Revised Final Design and therefore are excluded from the addendum.

109,300

SUBTOTAL CONSTRUCTION

5,138,500

Page 1 of 2

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Table 3: Remedial Action Cost Estimate in Basis of Design Report - Surrounding Properties Remedial Design Addendum 1

Old American Zinc Plant Superfund Site Surrounding Properties, Addendum 1
St. Clair County, Illinois

Item

Qty

Unit3

Unit Price

Total (Rounded)

Notes

Optional Items

Utility Locates

TBD

260

Unit pricing for utility locating, if determined necessary by owner's representative.

Unit pricing for surveying, if determined necessary by owner's representative. Assumes a

Surveys

TBD

409

minimum 10 by-10 foot grid and then use of a level and rod to measure elevations.

Labor, equipment and materials to shape/compact stockpile and removal/placement of poly

Excavated Soil Staging Pile Management

122,400

sheeting on working face, as determined necessary by owner's representative.

Project Management/Construction Management

Administration/Contractor Oversight

25%

5,138,500

1,284,600

CM, H&S, and CQM onsite, PM time

Owner's Representative Markup

5,138,500

256,900

per contract rates

Total Capital Cost:

6,680,000

CLASS 2 RANGE:

20%

8,016,000

-15%

5,678,000

a EA = each; LS = lump sum; TN = tons; DY = days; BCY = bank cubic yards; SF = square feet; CY = cubic yards; MO = months; MSF = thousand square feet; LF = linear feet

Page 2 of 2

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APPENDIX A
Illinois EPA Concurrence Letter

-------
Appendix A
Illinois EPA Concurrence

With the changes described in this Explanation of Significant Differences, the remedy lor
the Old American Zinc Site will continue to comply with Section 12] of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERC'LA).
The modified remedy will be protective of human heahh and the environment, complies
with the federal and state requirements which are applicable or relevant am! appropriate to
the remedial action (or justifies a waiver), and is cost-effective. Since wastes will be left in
place at the site abtne concentrations that allow for unlimited use and unrestricted
exposure, five-year reviews will be conducted to ensure that the remedy remains protective
of human health and the environment, in accordance with CERC'LA Section 121 and the
National Oil and Hazardous Substances Pollution Contingency Flan (NCP).

)

John J. Kim, Acting Diiector

Date

Illinois Environmental Protection Agency

-------