EPA Region 5 Records Ctr.

Illinois EnvironmentalProtection Agency

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Record of Decision SummaryInterstate Pollution Control Super-fund Site

Rockford, Illinois

I. Site Location and Description

The Interstate Pollution Control Inc. site ("the IPC site ") is located in an industrial area in the southcentral part of Rockford, Wmnebago County, Illinois north west of Magnolia Peoples Avenue. TheNational Superfund Wastelan Database identification number for the she is ELT 18001 1975. Thesmall (approximately 2.8 acre), irregularly-shaped site measures approximately 850 feet along thenorth boundary line and 270 feet along the east boundary line.

The Remedial Investigation/Feasibility Study ("RI/FS") of this former waste recyclcr/transporter sitewas conducted by the Potentialry Responsible Parties ("PRPs") under the oversight of the IllinoisEnvironmental Protection Agency ("Dlinois EPA") (the lead agency). All RI/FS activity was fundedby the PRPs and conducted consistent with a Partial Consent Decree with the State of Illinois.

During IPC's operation of the she h contained, at various times, at least six under ground storagetanks, one large above ground storage tank, an unlined surface impoundment, a gas fired incinerator,and several structures. IPC's operation at the site included transporting and bulking of waste oils,solvents and cyanide waste for incineration, resale and/or off-site disposal Also during IPC'soperation of the site support service was provided to two sister companies; a portable toilet businessand a Roto-Rooter franchise. Prior to IPC's operations the site was extensively quarried andbackfilled with various materials including a large quantity of foundry sand, following filling of thequarry and immediately prior to IPC's operations the site was the location of an auto salvage yard.

II. Site History and Enforcement Activities

The Illinois Environmental Protection Agency ("Illinois EPA"), U.S. Environmental ProtectionAgency ("U.S. EPA"), and other state and federal agencies began to investigate and evaluate the siteconditions in 1 979. In 1 985, the U.S. EPA conducted a preliminary field investigation of the she andthe adjacent Peoples Avenue Landfill and, in 1987, evaluated the site under the Hazard RankingSystem ("HRS"). The Site received an HRS score of 46.01 and was placed on the National PrioritiesList ("NPL") on June 24, 1988.

In 1991, private parties negotiated a Partial Consent Decree with the Illinois EPA and the AttorneyGeneral of the State of Illinois. The Partial Consent Decree required that the private parties("Respondents") undertake a Remedial Investigation/Feasibility Study ("RI/FS") at the site. The RIWork Plan was completed in 1992, and the field investigations were conducted in 1993-1994. Thefinal RI Report was submitted in 1 997 .

Significant removal actions have occurred at the IPC site on two different occasions. The incineratorwas removed between 1976 and 1979. Interstate Pollution Control, Inc. conducted a partial cleanupof the site in 1979 and 1980, in response to an Illinois Pollution Control Board Order. During this

1 RELEASABLENflV 0 1 2002

REVIEWER MD

REGIONS77 WEST JACKSON BOULEVARD

CHICAGO. IL 6060«590

REPLY TO 1>« ATTENTION OF

SR-67October 29, 2002

Mr. Clarence L. SmithDivision of Remediation ManagementBureau of LandIllinois Environmental Protection Agency1021 North Grand Avenue EastP.O. Box 19276Springfield, IL 62794-9276

OCT 3 0 2002

. 0*0RELEASABLE

NDV 0 1 2002

REVIEWER MDSubject: Clarification of U.S. EPA's Position With Regard to the Record of Decision

for the Interstate Pollution Control (IPC) Site In Rockford, Illinois

Dear Mr^mith:s

In September of 1999, the U.S. Environmental Protection Agency (U.S. EPA) reviewed theRecord of Decision (ROD) for the Interstate Pollution Control (IPC) Site in Rockford, Illinois.The IPC ROD requires the implementation of Alternative #2, Institutional Controls andEngineered Barrier, and Monitored Natural Attenuation qfGroundwater, with the Soil VaporExtraction component of Alternative #3 maintained as a contingent remedial option. Asdescribed in the ROD, "the engineered barrier will be installed over the site to prevent directcontact with site contaminants, serve as an impermeable barrier to limit exposure to soil vapors,prevent fugitive dust emissions, and reduce storm-water infiltration through site fill, therebyreducing potential releases to groundwater." The ROD further explains that groundwatercontamination beneath the IPC site will be remediated through monitored natural attenuation. Agroundwater monitoring program will be implemented to "provide an indication of theeffectiveness of the engineered barrier in preventing surface water infiltration and provide data toassess the rate of monitored natural attenuation of contaminants in groundwater." Quarterly andannual site inspections will be performed to ensure the integrity of the site fence and thecondition of the engineered barrier and the monitoring well system. Groundwater data will beevaluated to gage the effectiveness of the remedy. If VOC concentrations do not decrease (andthe lack of a decrease is not attributable to upstream sources), the implementation of a Soil VaporExtraction system may be considered.

U.S. EPA supports the actions that were selected in the ROD for the IPC Site. 'However, U.S.EPA elected not to fully concur with the IPC ROD because of the identification of monitored

Pruned with Vegetable Oil Bisect |r*» on 100V Recycled P*P*r ISO% PostcomumiO

natural attenuation as the remedy for groundwater. U.S. EPA has determined that the IPCRemedial Investigation and ROD did not provide the necessary information to demonstrate thatnatural attenuation is occurring at the IPC Site. In addition, the ROD did not providejustification to show that the estimated cleanup time for groundwater (> 200 years) is reasonablewhen compared to an active groundwater treatment approach. However, U.S. EPA does notoppose the cleanup plan outlined in the ROD because U.S. EPA recognizes that the IllinoisPollution Control Board has the authority to manage areas of groundwater contamination by useof Groundwater Management Zones. The IPC Site is in an area of widespread groundwatercontamination and is part of the Southeast Rockford Study Area. U.S. EPA agrees mat, inconjunction with source control, it is acceptable to monitor and administratively manage the areaof contaminated groundwater at the IPC site and between the IPC Site and the Rock River.

U.S. EPA expects that Illinois EPA will coordinate with the potentially responsible parties forthe PC Site and will proceed with implementation of the remedy. Please contact me at (312)353-6553 if you have any questions concerning U.S. EPA's position on the IPC ROD.

Sincerely,

Wendy L' CarneyChief, Remedial Response BranchSuperftind Division

cc: T. Van Donsel, SFDC. Melodia, ORCT. Ayers, IEPA

Declaration for Record of Decision•

Statutory Preference for Treatment as aPrinciple Element is not met

and Five Year Site Review is Required

Interstate Pollution ControlRockfbrd,IL GC8& &

Statement of Basis and Purpose lUJNOtSgBft

This decision document presents the selected remedial action for the Interstate Pollution Control site,in Rocfcford, Illinois which was chosen in accordance with the Comprehensive Environmental Response andCompensation Act rCERCLA"X as amended by the Supernmd Amendment and Reauthorization Act ("SARA")and, to the extent practicable the National Contingency Plan, This decision is based on the administrative recordfile for this site.

The U. S. Environmental Protection Agency concurs with the selected remedy.

Assessment of the Sife

The response action selected in this Record of Decision is necessary to protect the public health orwelfare or the environment from actual or threatened releases of hazardous substances into the environment.

Description of the Selected Reined v

This is the final action for the she. This action will address soil contamination and sources of continuinggroundwater contamination. This action addresses the principal threat remaining at the site by cappingcontaminated soils preventing further migration of contaminants to groundwater, placing institutional controlson future uses of the site and, monitored natural attenuation of contaminants currently in the groundwater. Asinstitutional controls and natural attenuation are key components of the remedy long-term management andmonitoring of the site will be required.

Statutory Determinations

Part 1: Statutory Requirements - The Selected Remedy is protective of human health and theenvironment, complies with Federal and State requirements that are applicable or relevant and appropriate tothe remedial action, is cost-effective, and utilizes permanent solutions and alternative treatment (or resourcerecovery) technology to the maximum extent practicable.

Part 2: Statutory Preference for Treatment - The remedy does not satisfy the statutory preferencefor treatment as a principle element of the remedy for the following reasons:

a) The largest quantity of material containing hazardous substances at the she is foundry sandfill which is not amenable to in-siru treatment and has been found to be technically impracticable toremove for ex-siru treatment or off-site disposal.

b) The fill contains a limited quantity of solvents (less than 2,000 pounds) distributed atrelatively dilute concentrations. The solvent-contaminated fill, which would be amenable to thepresumptive remedy of Soil Vapor Extraction ("SVE"), contains solvents *t concentrations which arenot believed to present a threat to groundwater following construction of the containment (i.e.impermeable barrier) remedy. Verification that the solvent contaminated fill is not a continicontributor of contaminants to groundwater will be a component of the five year review.

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QPNMFWFR Mr

e) Soil Vapor Extraction as a component of a final remedy curies the risk of inducing landfillgas migration into the IFC lite from the adjacent Peoples Avenue Landfill While this potentiallandfill gas migration is believed to be manageable this Record of Decision defers implementation ofthe SVE component of me remedy until me cap component isin place and functioning. Deferralofafinilo^isionastoiniplcaentitticnoftheSVBconipooentoftfacicmedy to the five year review willallow for adequate assessment of the landfill gas threat and more accurate costing of the SVEcomponent considering potential landfill gas effects on the SVE emission control equipment and / orthe engineering feasibility and cost of precluding landfill gas migration.

Part 3: Five-Year Review Requirements - Because this remedy wfll result in hazardous substances,pollutants, or contaminants remaining on-she above levels that allow for unlimited use and unrestrictedexposure, a statutory review will be conducted within five years after initiation of remedial action to ensurethat the remedy is, or will be, protective of human health and the environment

ROD Data Certification Check List

The following information is included in the Decision Summary section of this Record of Decision, Additionalinformation can be found in the Administrative Record file for mis site.

Chemicals of concern and their respective concentrationsBaseline risk represented by the chemicals of concern.Cleanup levels established for chemicals of concern and the basis for these levels.How source materials constituting principle threats are addressed.Current and reasonably anticipated future land use assumptions and current and potential futurebeneficial uses of groundwater used in the baseline risk assessment and ROD.Potential Land and groundwater use that will be available at the site as a result of the Selected Remedy.Estimated capital, annual operation and maintenance (O&M), and total present worth cost, discountrate, and the number of years over which the remedy cost estimates are projected.Key factors) that led to selecting the remedy (i.e. describe how the Selected Remedy provides the bestbalance of tradeoffs with respect to the balancing and modifying criteria, highlighting criteria key tothe decision).

Signature (Director, Illinois EPA) Date

Signature (Assistant Administrator / Regional Administrator)

Record, of Decision SummaryInterstate Pollution Control Superfund Site

Rockford, Illinois

L Site Location and DescriptionThe Interstate Pollution Control Inc. she ("the EPC site ") is located in an industrial area in the southcentral part of Rockford, Winnebago County, Illinois north west of Magnolia Peoples Avenue. TheNational Superfund Wastelan Database identification number for the she is ILT18001 1975. Thesmall (approximately 2.8 acre), irregularly-shaped site measures approximately 850 feet along thenorth boundary line and 270 feet along the east boundary line.

The Remedial Invcstigatioo/FeasMity Study ("RI/FS") of this former waste recyckr/transporter shewas conducted by the Potentially Responsible Parties ("PRPs") under the oversight of the IllinoisEnvironmental Protection Agency CUKnois EPA**) (the lead agency). All RI/FS activity was fundedby the PRPs and conducted consistent with a Partial Consent Decree with the State of Illinois.

During IPC's operation of the she it contained, at various times, at least six under ground storagetanks, one large above ground storage tank, an untined surface impoundment, a gas fired incinerator,and several structures. IPC's operation at the she included transporting and bulking of waste oils,solvents and cyanide waste for incineration, resale and/or off-she disposal Also during IPC'soperation of the she support service was provided to two sister companies; a portable toilet businessand a Roto-Rooter franchise. Prior to IPC's operations the she was extensively quarried andbackfilled with various materials including a large quantity of foundry sand, following filling of thequarry and immediately prior to IPC's operations the site was the location of an auto salvage yard.

II. Site History and Enforcement Activities

The Illinois Environmental Protection Agency (Illinois EPA"), U.S. Environmental ProtectionAgency (<eU.S. EPA**), and other state and federal agencies began to investigate and evaluate the siteconditions in 1979. In 1985, the U.S. EPA conducted a preliminary field investigation of the she andthe adjacent Peoples Avenue Landfill and, in 1987, evaluated the site under the Hazard RankingSystem ("HRS")- The She received an HRS score of 46.01 and was placed on the National PrioritiesList ("NPL") on June 24, 1988.

In 1991 , private parties negotiated a Partial Consent Decree with the Illinois EPA and the AttorneyGeneral of the State of Illinois. The Partial Consent Decree required that the private parties("Respondents") undertake a Remedial Invcstigation/Feasibflity Study ("RI/FS") at the site. The RIWork Plan was completed in 1992, and the field investigations were conducted in 1993-1994. Thefinal RI Report was submitted in 1997.

Significant removal actions have occurred at the IPC site on two different occasions. The incineratorwas removed between 1976 and 1979. Interstate Pollution Control, Inc. conducted a partial cleanupof the she in 1979 and 1980, in response to an Illinois Pollution Control Board Order. During this

RELEASABLENOV 0 1 2002

REVIEWER MD

partial cleanup of the sheseveral bulk tankers containing wastes, approximately 180 yds3 of materialfrom the surface impoundment, and approximately 120yds1 of cyanide contaminated were removed.Reportedly, 1200 drums of contaminated materials were also removed from the Site during thiscleanup. The surface impoundment was backfilled and graded,

On August 6, 1991, the U.S. EPA issued a Unilateral Administrative Order ("UAO") to IPC and agroup of potentially responsible parties ("Respondents") to conduct additional removal activities atthe site. Beginning in 1992, the Respondents to the UAO fenced the she, removed over 1,400 tonsof solid and hazardous waste (including visibly stained soils), demolished and removed all above-ground and underground ffl"Vs apri gignjfirant physical structures, msfoli*** a clay cover over theformer impoundment, and substantially cleared the site

mrnated rmrf. tb?m 2.Q inflfion pOWds of SOfrJ ^"4 hftTftrdnus waste. Thesel* constituted principal threats at the she, and were removed, treated, destroyed or disposed

of prior to the initiation of the RI/FS.

III. Community Participation

The RI/FS Report and Proposed Plan for the IPC she in Rockford, EL were made available to thepublic in July of 1999. They can be found in the Administrative Record file and informationrepository at the Illinois EPA's Bureau of Land division file in Springfield, IL and at the RockfordPublic Library, 215 North Wyman St. Rockford, IL. The notice of the availability of these twodocuments was published in the Rockford Register Star on Jury 9, 16, and 23, 1999. A publiccomment period was held from July 10 to September 10, 1999. An extension to the public commentperiod was requested. As a result, the comment period was extended to September 17, 1999. Inaddition, a public hearing was held on August 10, 1999 starting at 7:00 PM at the Holley Center,2000 Christina Street in Rockford, IL to present the Proposed Plan to a broader community audiencethan those that had already been involved at the she. At this hearing representatives of the IllinoisEPA answered questions about the remedial alternatives and the preferred option presented in theProposed Plan. Illinois EPA's response to the comments received during this period is included inthe Responsiveness Summary, which is part of this Record of Decision ('ROD").

IV. Scope and Role of Operable Unit or Response Action

The remedial action described in this ROD addresses remaining soil and groundwater contaminationat the she. Soil contamination at the site poses a current and potential risk to human health becauseU.S. EPA's acceptable risk range is exceeded for dermal contact whh soils, ingestion of soil,inhalation of dust, inhalation of contaminants which can volatilize to air, and concentrations ofcontaminants in groundwater are greater than the maximum contaminant levels for drinking water.This action presents the final response action anticipated for the she and addresses the principlethreats by installation of an impermeable barrier over the she, placing institutional controls on futureshe uses, reinforcing existing city and state groundwater use restrictions, and addressing groundwatercontamination resulting from this site by implementation of a monitored natural attenuation program.

V. Site Characteristics

The site is located m an area that has been heavily industrialized since the turn of the century.Historic industrial activities in the area include metal casting, plating, machine tooling, textilemflmyfilH'tiiPT|£j ^pthff^^^ning and printing operations. Aerial photographs and maps from tfrg carryto mid-1900s indicate there were several major quarries in the site vicinity. Most of these quarrieshave since been filled A 1918 topographic map indicates a quarry existed beneath most of the IPCsite. Later aerial photographs show those portions of the quarry under the site being completely filledby 1943.

The closest residential area to the IPC site is located approximately 600 feet to the north(hydraulicaUy up-gradient to cross gradient of the site). Other residential areas are locatedapproximately 2,700 feet to the east of the site, and 2,300 feet to the southeast. Blackhawk Park islocated approximately 700 feet to the northwest of the she. None of these areas has been impactedby the IPC rite. Please see the attached map entitled IPC She Area for a better understanding of thesite location and to support the following discussion of the regional environmental setting.

The IPC site is surrounded by significant industrial facilities. The Gunhe Foundry, located northeastof the site, has been m operation for at least 80 years. A pond located immediately north of the IPCsite had been used by the foundry for the discharge of storm water and cooling water from castingoperations. At the time of the RJ field activities, the pond was still receiving some discharge fromthe Foundry and contained a considerable volume of water. Since that time, an independent wastedisposal company has acquired the property, and the foundry stopped discharging to the pond Thedisposal company has been using the property to store construction equipment, and has been slowlyfilling the pond with what appears to be construction debris. The pond is now dry, and the east halfof the pond has been fifled level with surrounding grade. The RI Report documents the current statusof the pond, which can no longer be considered a aipnjfir*nt environmental feature. Consequently,the former pond does not warrant further discussion.

A former pet food plant, located immediately southwest of the site, processed meat and produced petfood from the turn of the century until the 1980s. Several areas on the property may have beenexcavated and then filled with solid fill materials.

The Peoples Avenue Landfill is located immediately southeast and south of the she. This propertywas originally a sand and gravel quarry. The City of Rockford (the City) used the quarry for wastedisposal from 1942 until 1972, receiving residential, commercial and industrial wastes. Methane gasgenerated by the landfill was detected in the basement of the adjacent pet food plant (venting pipesconstructed later within the landfill alleviated the gas problem at the plant).

In 1957, the City installed a public supply well (Municipal Well No, 14) near the southeast corner ofthe Peoples Avenue Landfill This well was abandoned in 1971 (prior to the start of IPC operations)because of deteriorating water quality (significant increases in chloride, manganese, sodium,ammonia, alkalinity, hardness and dissolved minerals). The deteriorating water quality was attributedto the landfifl. Furthermore, the pet food plant had four wells prior to 1966. In 1965, taste and odor

problems became apparent in the well water. The deterioration in water quality was believed to bethe result of contamination by the adjacent Peoples Avenue landfill.

The former Mattison Machine Wbrics is located approximately 1,000 feet northeast (ie., up-gradient)of the site. Illinois EPA records indicate that perchloroethyiene (PCE) is present in gxoundwaterbeneath the facility. Ongoing monitoring by Mattison Machine Works indicates that a phone ofvolatile organic compounds (VOCs), including PCE, trjchloroethykne (TCE), and 1,1,1-trichk>roethane (1,1,1-TCA), is passing beneath the Mattison property from another up~gradientsource. The maximum detected VOC concentrations included PCE at 10,600 Mg/L, TCE at 1,500Mg/L, and 1,1,1-TCA at 800 g/L. It is important to note that these concentrations are significantlygreater than the concentrations of these same constituents m groundwater beneath the IPC site.

Of particular relevance to the remedial action described in this ROD isthefictthatthelPCsiteisencompassed by the much larger Southeast Rockfbrd Study Area, The Southeast RockfordGroundwater Contamination ("SER") site began with the discovery of VOCs in groundwater withina residential area of nearly two square miles. That discovery prompted the U.S. EPA to ultimatelyextend water mains and connect 526 residences to City water at a cost of approximately $4 millioaThe SER Site was then added to the NPL. After further Illinois EPA study, the SER Site wasexpanded to a ten square mile study area ("SER Study Area") which incorporates almost 20% of theCity and includes the IPC site (see the attached IPC Site Area figure). Studies have since indicatedthe widespread presence of chlorinated solvents in groundwater within this ten square mile area, inconcentrations varying from less than 10 ppb to over 10,000 ppb. As a result of the widespreadgroundwater contamination, the City closed several immfcrpal wells in this general area.

On September 29, 1995, the Illinois EPA issued a Record of Decision ("ROD") which addressedgroundwater contamination at the SER She. The ROD defined the SER Site boundary as the areawithin the 10 ng/L contour line of the main VOC plume (approximately 1200 feet southeast of theIPC site at the closest point). It must be noted, however, that the Illinois EPA and the U.S. EPA hadnot independently investigated groundwater conditions in the general up-gradient vicinity of the IPCsite which, as noted earlier, exhibit elevated concentrations of VOCs.

Within the SER site, the Illinois EPA selected groundwater use restrictions as the appropriategroundwater response action. The selected response action includes groundwater monitoring for atleast 205 years, installation of water mains in the affected areas, connecting additional residences andbusinesses to City water, and implementation of institutional controls. The Illinois EPA stated that,with this groundwater response action, contaminants would be removed from groundwater by naturalattenuation. The City of Rockford is pursuing a tax program to assume the responsibility to addressgroundwater concerns area wide. This program includes institutional controls on groundwater useand operational components of water treatment to remove VOCs from city water.

The IPC site is located approximately 1,600 feet east of the Rock River, outside the limits of the 500-year Soodplain. The she is generally flat, and there is little runoff from the property. Most surfacewater (rainwater and snow-meh) accumulates in shallow puddles and eventually evaporates or

infiltrate into the subsurface soils. In areafe surrounding the site, suffice water drains to storm sewercatch basins.

•

Fill is present across most of the site and extends to depths of up to 46 feet Most of the on-she fillconsists of fine black sand believed to be foundry sand. The £U also includes wocd, glass, concrete,brickandslag. Deposits of medium to coarse sand, and sand and gravel occur beneath the ffiL Theseout-wash deposits extend to a depth of about 100 feet Finn to very dense sift, clayey silt or sfliy claylayers are faterbedded within the sand and gravel deposits in the site vicinity. The bedrock surfaceis approximately 1 SO to 200 feet below groundwater surface.

As the primary sources of contamination had been previously removed, as discussed in Section IIabove, the following conceptual she model for soils and groundwater was developed and used forthe RI and carried through the Baseline Risk Assessment. Terrestrial and aquatic biota were notconsidered at risk fiom the site and were not carried forward. Surface soft, sub-snrnro soil, sedimentin the adjacent quarry pit, and groundwater were investigated during the sampling portion of the RIwhich was conducted in 1993 and 1994. As no ongoing air releases were occurring at the site, butwere possible during past operation of the incinerator, sampling of off-she surface soils wasconducted to assess impacts; none were found. A total of 23 new or existing shallow and deepmonitoring wells were utilized to assess she impacts on groundwater. The near-surface unconfinedaquifer is the aquifer of concern; consequently, monitoring wells were not installed in the deepaquifers located below the confining silty stratum at this site. The general direction of groundwaterflow is southwest to west southwest towards the Rock River. The groundwater flow velocity in thesurficial aquifer in the she study area ranges from 0.75 to one foot per day (300 -400 feet per year).One of the most notable outcomes of the groundwater portion of the investigation was verificationthat a plume of chlorinated volatile organic compounds, at substantially higher concentrations thanoccur on site is approaching the site from the north east This phime is expected to reach the EPC shein 15 to 45 years.

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Specifically to assess contaminated dcepr and shallow groundwater impacts on the Rock River two(2) shallow and two (2) deep monitoring weUs were installed down-gradient of the site, in closeproximity to the river. Only vinyl Morijg (mavfonim detected f

t?4n i gaT) were Certified at VWJQ above Wf A. Neither of these

ian iliHnts could be fatty attributed to the IPC site because of the close proximity and Tip-gradientlocation of Peoples Avenue Landfill and the nearly ubiquitous nature of these two contaminants inthe Southeast Rockford area.

Groundwater supplies in Winnebago County are obtained from aquifers in both the glacial driftdeposits and bedrock. Frinc^aquifos within the glacial drift are gencralh/ Innfted to major bedrockvalleys with thick sand and gravel deposits. Although then are industrial and municipal wells whichdraw water from the drift aquifers, the Gakna*Plattevule bedrock formation is the primary source ofpotable groundwater for domestic use.

Water supplies delivered by pipe mains are available from the public utfltty for the entire IPC she RIstudy area, including the residences north of the site and Blackhawk Park. A well inventory indicatesthat all recorded wcDs located down-gradient of the site have either been abandoned or no longerexLtt and that there are no consumers of well water who might be impacted by groundwatercontamination at the she and contamination originating up-gradient of the site.

No wetland areas are threatened as a result of IPC site activities or the groundwater plume whichextends beyond the property boundary, and no other critical habitats have been identified. Theecobgicai risk assessment concluded that contaminant levels detected at the site are unlikely to posea high ecological risk to local flora and fauna; no adverse impacts were observed at the site duringa reconnaissance; and no state or federal threatened or endangered species are likely to be affectedby site contaminants

Seventy three (73) chemicals of potential concern ("COPC's) detected in she soils were selected forthe risk assessment. These included 1 1 volatile organic compounds ("VOCs"), 29 semi-volatileorganic compounds C'SVOCs"), 14 pesticide/PCB compounds and 18 trace metals, and cyanide.At total of 33 chemicals detected in on-she groundwater (shallow and deep) were selected asCOPCs. These included 1 1 VOCs, 10 SVOCs, one pesticide/PCB compound, 1 1 trace metals, andcyanide.

The following table summarizes those COPCs found to be risk drivers in the risk assessment

Risk Dnyinfl hemteteof Poterti al Cono«n_

CmOnwtnChromium (Vrt) Cadmium

nnylGHortdt1.1|T«noNoroelh«w

IChtartd*

There is no evidence to indicate that Resource Conservation and Recovery Act ("RCRA") listedwastes were handled at the facility during its operation and no characteristic wastes were left on-siit following the previously discussed removal actions.

VI. Current and Potential Future Site and Resource Uses

The DPC site is currently unused property zoned for general industrial use only. The site is securedby a chain link fence and locked gate with no on-ske activity. The property is the subject of aDeclaration of Restriction filed with the Winnebago County Recorder which contains the followingpertinent language "The following restrictions are hereby placed upon the use of the aforesaid realproperty (also described herein as "the site") and shall run with the land, so as to prohibit to-wit: a)all residential development of the site; b) all public access to the site except for general industrial use;c) all unpermitted treatment, storage or disposal of waste on the site; and d) all uses of groundwaterat the site; all of the above except as required by the Illinois Environmental Protection Agency or theUnited States Environmental Protection Agency." This Declaration of Restriction was filed March10, 1995.

In addition to the above, the selected alternative would require additional Declarations of Restrictionto include at a minimum the following: insurance of protection of construction workers during futureon-she excavation or other penetrations of the impermeable barrier by requiring appropriate OSHAtraining of construction workers, appropriate and applicable health & safety plans during constructionactivities, compliance with Applicable or Relevant and Appropriate Requirements 'XARARs") relativeto soil management, maintenance of the impermeable barrier and asphah armor layer, and furtherobligating adherence to the existing enforced local and state groundwater use restrictions. Theimpermeable barrier portion of the selected alternative includes asphalt paving as the uppermost layer,this asphah cover serves not only as an armor protection for the impermeable layer but would alsoprovide for surface use of the property by vehicles. Likely future uses of the site for parking of trucksor heavy equipment would not be incompatible with the remedy and is consistent with currentadjacent land use and zoning. Additionally, if conducted consistent with the indicated Declarations

of Restriction, construction of TOnmeraaTbuMngs would not be prohibited by the selected remedialalternative nor inconsistent with current area land use and zoning.

VIL Summary of Site Risks

The baseline risk assessment estimates what risk the site poses if no action were taken. It providesthe basis for taking action and identifies the contaminants and exposure pathways that need to beaddressed by the remedial action. This section of the ROD summarizes the results of the ba^linT riskassessment for rt»«* site.

The reader is referred to the previously presented table Exposure Pathways Quantitatively Assessedin the Baseline Risk Assessment in Section V - Site Characteristic of this ROD and the attached tableentitled Concentration Range of Risk Driving Chemicals of Potential Concern. The more significantrisk driving carcinogenic chemicals in site soils were found to be chromium (VI), vinyl chloride, asuite of poty-nuclear aromatic hydrocarbons, and r-aHfldnnv the non-carcinogenic soil risk waspredominantly from 1,1-dicbloroethaue. Unacceptable risk prcwited by carcinogenic chemicals inon-site shallow groundwatcr was presented by vinyl chloride and poh/Hoiclear aromatk hydrocarbons,with non-carcinogenic risk being presented by manganese, vinyl chloride, and 1,2-dichloroethene.Please see the attached Risk Tables - 1, 2, &3 detailing the risk driving contribution of aQ chemicalsincluding the less significant chemicals and each chemicals contribution to the overall site risk.

Risk Ch^yflffffrization Sumrpory: For carcinogens, risks are generally expressed as the incrementalprobability of an individual's developing cancer over a lifetime as a result of exposure to thecarcinogen. Excess lifetime cancer risk is calculated from the following equation:

Risk-CDIxSF

where:risk = a unitless probability (e.g., 2 x 10'5) of an individual's developing cancerGDI • chronic dairy intake averaged over 70 years (mg/kg-day)SF *• slope factor, expressed as (mg/kg-day)-!.

These risks are probabilities that usually are expressed in scientific notation (e.g., 1x10*). An excesslifetime cancer risk of 1x1 O*6 indicates that an individual experiencing the reasonable maximumexposure ("RME") estimate has a 1 in 1,000,000 chance of developing cancer as a result of site-related exposure. This is referred to as an "excess lifetime cancer risk" because it would be in additionto the risks of cancer individuals face from other causes such as smoking or exposure to too muchsun. The chance of an individual's developing cancer from all other causes has been estimated to beas high as one in three. U.S. EPA's generally acceptable risk range for she-related exposures is 1CT*to

The potential for noncarcinogenic effects is evaluated by comparing an exposure level over a specifiedtime period (e.g., life-time) with a reference dose ("RfD") derived for a similar exposure period. AnRfD represents a level that an individual may be exposed to that is not expected to cause anydeleterious effect The ratio of exposure to toxichy is called a hazard quotient ("HQ"). An HQ of lessthan 1 indicates that a receptor's dose of a single contaminant is less than the RJED, and that toxic

8

noncarcmogenic effects from that chrmfad are unlikely. The Hazard Index ("HT) is generated byadding the HQs for all chemkaXX) of concern that affect the same target organ (e.g., fiver) or thatact through the same mechanism of action within a mfdhiTp or across all media, to which a givenindividual may reasonably be exposed An HI of less than 1 indinatrs that, based on the sum of allHQ's from different contaminants and exposure routes, toxic noncardnogenic effects from allcontaminants are unlikely. An HI greater than 1 indicates that site-related exposures may present arisk to tmm*«* health.

The HQ is calculated as follows:Non-cancer HQ - CDI/RfD

where: GDI = Chronic dairy intakeR£D = reference dose.

GDI and RfD are expressed hi the same units and represent the same exposure period (Le^ chronic,subchronic, or short-term).

The response action selected in this ROD is necessary to protect the public health or welfare or theenvironment from actual or threatened releases of hazardous substances into the environment.

VUI. Remedial Action Objectives

Remedial action objectives provide the foundation upon which remediation alternatives aredeveloped. Remedial action objectives should refect U.S. EPA's remedy selection expectations, aspresented in CERCLA and the National Contingency Plan ("NCF')- CERCLA establishes apreference for remedial actions which permanently and significantly reduce the volume, toxicity ormobility of hazardous substances, pollutants and contaminants. 42U.S.C. §9621(b). Furthermore,CERCLA states that U.S. EPA shall select a remedial action that is protective of human health andthe environment, that is cost effective, and that utilizes permanent solutions and alternative treatmenttechnologies or resource recovery technologies to the maximum extent practicable. 42 U.S.C.§962 l(b). The NCP provides that where practicable, U.S. EPA expects to treat princfrk threats,employ engineering controls (e.g. containment) for low-level threats or where treatment isimpracticable, use institutional controls to supplement engineering controls, consider using innovativetechnology, and restore usable groundwaters to beneficial uses wherever practicable. The remedialaction objectives should reflect the reasonably anticipated or intended future use of the land 40 CF.R.§300.430(a)(l)(iif). As the existing Declaration of Restriction prohibits residential development ofthe site, and considering the physical nature and setting of the site, remediation to protect future siteworkers and trespassers, along with mitigation of groundwater contaminant source material areappropriate. Active restoration of groundwater is not practicable in-light of the ubiquitous nature ofgroundwater contamination in the region and to maintain consistency with remedial action objectivesestablished for the adjacent SER NPL she.

The following Remedial Action Objectives were established for the IPC site:

• Mitigate the potential risk of exposure to on-site workers and possible trespassers via dermalcontact ingestion or inhalation of hazardous substances from surface soils to protective levels.

• Mitigate the potential for incremental releases of hazardous substances from site soils to areagroundwater.

• Restore the aquifer to drinking water standards within a time frame consistent with theregional approach to nearly ubiquitous chlorinated VOC contamination.

The risk identified in the risk assessment relate to three exposure pathways:

1) dermal contact with and/or ingestkm of contaminants in soil;2) inhalation of contaminants in soil (Le. dust) ft"d volatilization of contaminants from soil to ambient

air followed by inhalation;3) ingestion of contaminants in groundwater or the inhalation of contaminants following

volatilization from water during showering or bathing.

Because of the existing state and local prohibitions of groundwater use in the area of the site exposurepathway number 3 need not be addressed by the Remedial Action Objectives. The first RemedialAction Objective addresses exposure pathways number 1 and 2. The second Remedial ActionObjective will reduce the dependence on monitored natural attenuation of groundwater and timepenod for natural attenuation to occur.

EX. Description of Alternatives

The Feasibility Study ("FS") presented three remedial action alternatives for detailed review. Inaddition the FS evaluated an excavation alternative and found excavation to offer minimal additionalrisk reduction and technically impracticable. Implementation of the excavation alternative wasestimated to require construction and operation of the SVE component of Alternative #3 to reduceVOC emission during excavation activity, placement of sheet piling around the entire 2.8 acre site,removal of an estimated 86,000 yds3 of predominantly foundry sand fill material, and the replacementof an equivalent quantity of off-site fill material. This alternative would not address similar foundrysand fill material underlaying adjacent properties on all sides of the EPC site and would have resultedin a "clean island" concept at the site. The foundry sand contaminants ubiquitous to the area of thesite are more appropriately managed with the regional approach taken at the adjacent SER site; theexcavation alternative was not carried forward through full detailed review. Active groundwater pumpand treat alternatives were rejected early in the FS process based on the SER - ROD and the IPC sitessimilar characteristics including the hydrogeologic setting, contaminants of concern, groundwater use,and physical limitations. The EPC - FS did not exhaustively evaluate the groundwater pump and treatoption but rather relied on site similarity and the detailed analysis made during the SER - RI/FS andROD. The three remedial action alternatives carried through full evaluation were:

Alternative #1 - No Action beyond Maintenance of Existing Institutional Controls;

Alterative #2 - Institutional Controls, Engineered Barrier, and Monitored Natural Attenuationof Groundwater; and

10

Alternative #3 . Institutional Controls,-*!} Engineered Barrier, Soil Vapor Extraction("SVE"), and Monitored Natural Attenuation of Groundwater.

•

These three alternatives are further described below:

Common Elements: All three remed'fl) alternatives include the common element of maintainingexisting institutional control (deed restriction prohibiting residential development). AdditionallyAlternatives #2 and #3 include the common elements of further institutional controls includingadditional property owner implemented deed restrictions to insure protection of construction workersduring future on-rite excavation by requiring appropriate OSHA training of construction workers,appropriate health & safety plans during construction activities, compliance with ARARs relative tosoil management, and further obligating adherence to the existing State of Illinois and City ofRockfimigroundwatcr use restrictions, implementationand monitored natural attenuation of groundwater.

Alternative #1: No Action - This is the baseline condition required by the NCP for comparisonpurposes, and assumes that no remedial measures would be implemented at the she. The existing sitesecurity fence and existing deed restriction' would remain under this alternative. The deed restrictionalready in place prohibits residential development of this property.

This alternative relies solely on existing institutional controls to prevent contact with sitecontaminants. The calculated Reasonable Maximum Exposure ("RME") scenario risks for thisalternative are unacceptable due primarily to the presence of metals in soils.

Alternative #2: Institutional Controls and Engineered Barrier - This alternative includes an arrayof institutional controls, the construction of an engineered barrier over the Site, and monitored naturalattenuation of groundwater. The institutional controls will include maintenance of the existing sitesecurity fence, property owner implementation of deed restrictions, utilization of existing State andCity of Rockford groundwater use restrictions, and routine groundwater monitoring by the PRPs. Theengineered barrier will consist of an impermeable geosynthetic liner overlain by asphalt pavementThe barrier will be graded to promote drainage. Groundwater contamination beneath the IPC site willbe remediated over time through monitored natural attenuation. The ongoing occurrence of naturalattenuation is supported by information in the RI - Soil Gas Survey effort which found significantdepletion of soil oxygen concentrations in the area of soil and groundwater contamination. Thedepletion of soil oxygen is a clear indication mat aerobic microbial activity is occurring and the RIfurther indicated that several non-chlorinated organic substrate compounds (e.g. methane) existed inthe soil gas fraction. These organic substrates are conducive to aerobic co-metabolism of chlorinatedVOCs. The depletion of soil oxygen is, in certain areas of the site, creating an anaerobic environmentwhich is equally conducive to microbial degradation of chlorinated VOCs. While less clearlyconfirmed by the RI data the likelihood of the on-going occurrence of anaerobic degradation in theseareas is supported by the presence of the anaerobic degradation products of chlorinated VOCs in soilgas (e.g. vinyl chloride). Both degradation mechanisms are well recognized for their capacity toprovide natural attenuation. While no site specific modeling of natural attenuation was conducted atthe IPC site, the site is within the original study area of the SER site where this modeling wasconducted Monitored natural attenuation was the selected groundwater remedy for the SER site and

11

no specific diflEereoces between the ten (10) square mile SER ate study area and the included IPC siteare apparent from the RI data. The monitoring program win include not only wells in close proximityto tbe she but will also include monitoring of the two wells (MW-IPC13(S) & MW-IPC12(S)) nearthe Rock River, and down gradient of the site. Monitoring of MW-IPC13(S) & MW-IPC12<S) isincluded to insure no adverse release is occurring to that natural resource during the post-closuremonitoring period and to verify the monitored natural attenuation remedy is protective of the RockRiver.

Alternative #3: Institutional Controls, Engineered Barrier and SVE - This alternative will includeall of the elements of Alternative #2 (i.e., implementing institutional controls, installing theengineered barrier, and monitored natural attenuation of groundwater), as well as the installation ofa SVE system in the general area of the former surface impoundment The SVE system would beoperated to remove volatile organic compounds from the subsurface soil reducing the potential forcontinued migration of soil contaminants to groundwater. An exacerbating factor exist relative todesign and operations of the SVE component of mis alternative because of the existence of thePeoples Avenue Landfill site immediately south of the IPC she; this will be discussed further inSection XX following.

X. Comparative Analysis of Alternatives

Nine criteria are used to evaluate the different remediation alternatives individually and against eachother in order to select a remedy. The nine evaluation criteria are (1) overall protection of humanhealth and the environment; (2) compliance with ARARs; (3) long-term effectiveness andpermanence; (4) reduction of toxicity, mobility, or volume of contaminants through treatment; (5)short-term effectiveness; (6) implementabiliry; (7) cost; (8) State/support agency acceptance; and (9)community acceptance. 40 C.F.R. §300.430(e)(9)(iii). This section of the Proposed Plan profiles therelative performance of each alternative against the nine criteria, noting how it compares to the otheroptions under consideration. The nine evaluation criteria are discussed below. The "DetailedAnalysis of Alternatives" can be found hi the FS.

1. Overall Protection of Human Heattb and the Environment determines whether an alternativeeliminates, reduces, or controls threats to public health and tbe environment through institutionalcontrols, engineering controls, or treatment Alternative #1 is not protective of human health, nor doesit satisfy the remedial action objectives established for the site. This alternative was therefore notconsidered further. Alternatives #2 and #3 effectively eliminate the majority of the human health risksposed by the site, and restrict access to the regionally contaminated groundwater during the period ofmonitored natural attenuation. Therefore, bom Alternatives #2 and #3 fully satisfy the remedial actionobjectives, and are protective of human health and the environment.

2. Compliance with ARARs evaluates whether the alternative meets Federal and State environmentalstatutes, regulations, and other requirements that pertain to the site or whether a waiver is justified.Both Alternatives #2 and #3 are expected to meet State and Federal ARARs. A list of the ARARsidentified for the selected remedy can be found in the attached ARAR Tables 1 through 7 andare summarized in Section XE following.

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3. Long*term Effectiveness and Permanence considers the ability of an alternative to maintainprotection of human health and the environment over time. Alternative #2 does not remove or treatthe risks posed by she soils, and does not actively treat contaminated groundwater. However, theprincipal threats at the Site have already been eliminated as a result of the previous removal activities.The nrmnt-fihpitinn* nTVOT. contaminant* in anils is heBewed to he sufficiently low SO as not to present

a continuing source of groundwatcr contamination, after implementation of Alternative #2, and thesesoil VOCs will degrade overtime as substantiated by soil gas information indicating bio-degradationis occurring and the presence of the break-down products of chlorinated organics.

The concentrations of VOC and SVOC contaminants in groundwater will decline over time throughmonitored natural attenuation.

Alternative #3 offers the same long-term effectiveness as described for Alternative #2, and offerssomgwhat **riy»ncrd pCTp^^qn^ fry mnovipg residual VQC cnnfamttmntB *" rite soils. However, themetals will remain on-site.

The long-tenn effectiveness ofboth Alternatives #2 and #3 can be optimized through effective designand implementation of routine maintenance, and can be verified through the regular site inspectionsand the CERCLA mandated five year review process. These will ensure that the alternatives willremain effective in the long term.

4. Redaction of Toxkhy, Mobility, or Volume of Contaminants through Treatment evaluates analternative's use of treatment to reduce the harmful effects of principal contaminants, their ability tomove in the environment, and the amount of contamination present Alternative #2 does not usetreatment technologies to reduce the toxicity or volume of the residual contaminants in site soils, butdoes allow naturally occurring biological processes to continue the degradation of VOCs. Alternative#3 uses SVE treatment technologies to remove VOC contaminants in site soils. Off-site treatmentand/or destruction have already been used to mitigate the principle threats posed by wastes formerlypresent on the site. With both Alternatives #2 and #3, contaminated groundwater would not betreated. However, the concentrations of VOC and SVOC contaminants in groundwater would declineover time through monitored natural attenuation. Both Alternatives #2 and #3 reduce the mobilityof site contaminants to groundwater by preventing infiltration of rain water and snow melt waterthrough site soils.

5. Short-term Effectiveness considers the length of time needed to implement an alternative and therisk the alternative poses to workers, residents, and the environment during implementation.Construction of Alternative #2 would take approximately one to three months, and could be completedwithin one construction season. During this period, construction workers and the community couldpotentially be exposed to site contaminants. However, the construction workers will be working undera site-specific health and safety plan which will specify appropriate dermal and inhalation protection;exposure to the community will be short-term and will be addressed through the exercise ofappropriate safety precautions and construction controls.

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Construction of Alternative #3 is expected to take two to four months, and could be completed in oneconstruction season. During the construction period, construction workers and the community couldpotentially be exposed to site contaminants as discussed in Construction of Alternative #2. Duringoperation of the SVE system, vapors may be released to the atmosphere, and spent carbon andcondeiisate may require hmdlii^ These rides will be minimizedthrough site-specific heahh and safety plans, the exercise of appropriate safety precautions, andcompliance with approved material handling plans.

A summary of the length of time needed to implement each alternative is presented in the table -Summary Table of Alternative Cost and Time to Complete presented at the end of thissection of the ROD.

6. Implementabiliry considers the technical and administrative feasibility of implementing thealternative such as relative availability of goods and services. Both Alternatives #2 & #3 are readilyimplementable, and can be constructed using standard construction techniques and materials.However, construction of both are weather dependent and must be undertaken during the summerconstruction season. After construction the SVE system can be operated year round.

The implementability of the SVE component of Alternative #3 is to some extent in question becauseof the exacerbating presence of the adjacent Peoples Avenue Landfill and evidence that methanemigration from that source is already occurring toward the IPC site; a final decision on theimplementability of Alternative #3 can not be made until such time as a design study, including a pilottest of SVE technology has been conducted

7. Cost includes estimated capital and operation and maintenance cost as well as present worth cost.Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Costestimates are expected to be accurate within a range of+50 to -30 percent

The Net Present Worth of the three evaluated alternatives is as follows:Alternative #1 not applicableAlternative #2 $2,328,000Alternative #3 $4,661,000

A summary of capital and operation and maintenance cost for each alternative is presented in the table- Summary Table of Alternative Cost and Time to Complete presented at the end ofthis section of the ROD and the Cost Tables 1 through 3 attached.

8. State/Support Agency Acceptance considers whether the U.S. EPA agrees with the State analysesand recommendations of the RI/FS and the proposed plan, U.S. EPA has reviewed this Record ofDecision and supports the Preferred Remedial Alternative.

9. Community Acceptance considers whether the local community agrees with the State's analysesand preferred alternative. Comments received on the proposed plan are an important indicator of

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community acceptance. The proposed plan, presented in a formal public bearing, indicated thatAlternative #3 was the option preferred by the Illinois EPA and U.S. EPA with Alternative #2 as acontingent remedy if the SVE component of Alternative #3 wasfbundtobetecbiiicallyirnpracticable.Comments received from the PRPs (during the public comment period) evaluated, among otherfactors of the preferred option, the potential for migration of VOCs to groundwater. Thesecomments present a •persuasive argument that after implementation of Alternative #2 (theimpermeable bonier alternative) the potential for continued migration of VOCs to groundwater willbe sufficiently reduced so as not to require the SVE component of Alternative #3. Additionally thecomments received present a substantial case that, following construction of the impermeable barrier,VOCs in site soil wfll not constitute an inhalation hazard via their volatilization to mnhicnt air.

Summary Table of Alternative Cost and Time to CompleteAlternative*

Estimated Capitol Cost

Estimated Annual O&M Cost:

Estimated Present Net Worth:

Estimated Time to Construct:

Estimated Cleanup Time for Soils:

Estimated Cleanup Time for Gioundwater

Alternative #1

$0

SO

$0

0

Not Applicable

>200 Years

Alternative #2

$985,000

$1343.000

$2,328,000

1-3 Months

Not Applicable

>200 Years

Alternative #3

$1,634,000

$3,027,000

$4,661,000

2 - 4 Months

5 Years

>200 Years

XL Principle Threat WasteAll materials that met the definition of principle threat waste were removed from the site during thevarious removal actions discussed in Section n above.

XII. Selected Remedy

Summary of the Rational for the Selected Remedy:

The selected remedy for the IPC site is Alternative #2: Institutional Controls and EngineeredBarrier, and Monitored Natural Attenuation of Groundwater as discussed generally above inSection DC with the SVE component of Alternative #3: maintained as a contingent remedial option.The decision to implement the SVE component will be made following implementation ofAlternative #2 and a demonstration period (at the Frve Year Review) and will be based on statisticalanalysis of site groundwater contamination trends.- The PRPs will provide to the Illinois EPA asummary report of groundwater monitoring data containing a statistical analysis of this data 90 daysprior to each Five Year Review. If during each Five Year Review cycle spasttcally significantdecreases in on-she and down gradient concentrations of trichloroethene and 1,1,1-trichloroethanein shallow groundwater are not verified (which cannot be attributed to upgradient sources), the SVE

15

design pilot test wfll be implemented. Tbe final decision to implement the S VE remedy componentwill be made by the Illinois EPA based on performance of the SVE design pflot test indicating thatthe SVE remedy can be safely implemented considering the landfill gas concerns relative to theadjacent Peoples Avenue Landfifl. Tins is a change from the Preferred Alternative presented in theproposed plan; In the Site Alternative #3 was the preferred alternative. This change in picfuiedalternative is based on full consideration of public comment received on the proposed plan. Thischange could have been reasonably anticipated from the analysis of alternatives presented in theproposed plan and specifically the discussion relating to nip risk associated with operation of the SVEcomponent.

The selected alternative, with the condngentirnplftmenratiMiofthe SVE component provides the bestbalance of trade-offs with respect to the balancing and modifying criteria in that:

• Long Term Effectiveness is plausible in that the principle threat has been removed from the siteand following consideration of a supplemental evaluation of the site contaminants likelihood ofmigration to groundwater. This supplemental evaluation is contained in PRP comments receivedduring the public comment period and is included in the Administrative Record. Verification ofLong Term Effectiveness of the selected alternative wfll be a primary subject of the Five YearReview;

• Reduction of Toxicity, Mobility, or Volume Through Treatment may not be required (base onpublic comment received during the comment period) to achieve the Remedial Action Objectives.The need for additional reduction in toxfcity, mobility, or volume of site contaminants throughtreatment will be evaluated during the Five Year Review;

• Short Term Effectiveness is provided by the impermeable barrier component and theimplementation of the Institutional Controls components of the alternative and need not be delayedto determine the iroplementabOity of the SVE component;

• Implemcntability of the Selected Alternative can be achieved. The onplementabflity of the SVEcomponent is the subject of significant question as discussed above and in the proposed plan. Ifthe long term effectiveness of Alternative #2 is found lacking, at any Five Year Review, theimplementability of the SVE component will be further evaluated wfth-out delaying constructionof the readily implementable barrier and institutional control components of the remedy,

• Cost of the selected alternative is reasonable considering the substantial risk reduction that willbe achieved;

• U.S. EPA acceptance of the selected alternative has been acquired; and

• Community acceptance of Alternative #3 was the subject of significant and persuasive comment.Alternative #2 was accepted by the public based on the comment received by Illinois EPA.

Description of the Selected Remedy:

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Based on the rational presented above Alternative 91 with contingent addhkta of the SVE componentof Alternative #3 following any five year review is the selected remedy for the IPC site. Alternative#2 consist of the following major remedy components:

• Institutional Controls. Maintain the existing Declaration of Restriction already filed with the Winnebago CountyRecorder which contains the following pertinent language The following restrictions arehereby placed upon the use of the aforesaid real property (also described herein as "the she")and shall run with the land, so as to prohibit to-wit: a) all residential development of the site;b) all pubfic access to the site except for general industrial use; c) all unpennitted treatment,storage or disposal of waste on the site; and d) all uses of groundwater at the she; all of theabove except as required by the Illinois Environmental Protection Agency or the UnitedStates Env^nmenlal Protection Agency." This Declaration of Restriction was filed March10,1995.

- Attach additional Declaration^) of Restriction to the property including: noting thepresence of hazardous substances on the site and the requirement that no excavations orother penetrations of the impermeable barrier be allowed unless the construction workers aretrained consistent with 29 CFR 1910.120 ("OSHA") and work under an adequate health andsafety plan; that all soil spoil material be managed consistent with a soft management planconsistent with all applicable state and federal laws applicable at the time and that this soilmanagement plan be specific to any planned on-site construction activity, and furthermorethat each specific soil management plan be endorsed by a person qualified to write such plansand that each specific soil management plan be provided to the Illinois EPA 30 days priorto initiation of construction activity; that the engineered barrier be maintained consistent withan inspection, mafoTenancc, and corrective action plan to be developed as part to the remedialdesign and approved by the Illinois EPA.

- Implement a Groundwater Management Zone for the area of site impacted groundwater.

- Maintain the existing she security fence to enforce hem b of the above Declaration ofRestriction.

-Supplement existing warning signs around the she perimeter discouraging trespassers andnoticing a prohibition of unauthorized excavation.

- Employing existing City of Rockford ordinances and State requirements that restrict theinstallation of potable groundwater wells within contaminated groundwater, and withinminimum setback zones from primary sources. Compliance with these ordinances and Staterequirements will be reviewed as part of U.S. EPA's mandatory five-year review of CERCLAsites.

17

• Support Illinois EPA's public education efforts in the SER Area. The ROD for the SERsite mdfc*te« that the Illinois EPA will rigorously educate the public about the potential risksassociated with using contaminated groundwater in southeast Rockford, and will discouragethe use of groundwater for drinking and bathing.

Engineered Barrier Over The Entire Site- The engineered barrier will be installed to:

Prevent direct contact with site contaminants, serve as an impermeable barrier to limitexposure to soil vapors, prevent fugitive dust emissions, and reduce storm-water infiltrationthrough she fiH, thereby reducing potential releases to groundwater.

The engineered barrier would be installed in addition to the cap which had been constructedover the former surface impoundment. This existing cap was installed in 1992 as part of aremoval action, and consists of six inches of compacted clay.

The engineered barrier wffl be comprised of a flexible membrane finer, with an overlyingasphalt surface. From top to bottom, it win generally consist of an 8-inch thick asphaltpavement, underlain by 12 inches of granular base course, a 40 mil flexible membrane liner("FML"), and a variable thickness grading layer. Geotextik fabric is included in the costestimate for the engineered barrier as an option to be placed above the FML as furtherprotection dependent upon the aggregate size reasonably available for the granular basecourse. The barrier win have a center crown, and will be sloped at a 1 to 1.5 percent gradeto promote sheet runoff from the asphalt surface. The underlying FML will also be slopedat a 1 to 1.5 percent grade to promote drainage of any water that passes through the asphaltsurface. Drainage holes wfll be provided between the asphalt surface and FML along the sheperimeter to minimize the accumulation of moisture between the two barriers. Clean runoffwill flow to the railroad right-of-way immediately south of the she. A swale will be formedin the asphalt pavement along the north edge of the site to direct surface water runoff towardsSeminary Street. The asphalt pavement and granular base course will support heavycommercial truck traffic, thereby facilitating use of the IPC she for limited commercialpurposes.

The FML will serve as the primary impermeable barrier, reducing the infiltration through theshe surface. The U.S. EPA Hydrologic Evaluation of Landfill Performance ("HELP") model,versions 3.01 and 3.07, were used to model the infiltration through the she surface underexisting conditions and under the new impermeable barrier scenario. The HELP model(Appendix D) indicates that, under current conditions, 6.2 inches of precipitation (472,000gallons) infiltrates annually through the ground surface at the she. The HELP model predictsthat installation of the engineered barrier would reduce infiltration to 0.00014 inches annually(11 gallons). Thus, the engineered barrier reduces infiltration by approximately 99.998percent. The reduction in infiltration is achieved primarily via the FML in conjunction withregrading of the site to promote efficient drainage, and installation of the relativelyimpermeable asphalt surface, which further sheds surface water. The clean runoff from the

18

impermeable barrier wfll be routed to the City of Rockford storm sewer system catch basinlocated on Seminary Road, and to the railroad right-of-way located immediately to the southof the site.

The site wffl be ckared prior to installing the engineered barrier. The six on-site groundwatermonitoring wells will be abandoned in accordance with the Illinois Water Well ConstructionCode. Trees and brush win be cleared, chipped and evenly spread over the site. Thedisconnected overhead electrical Ones, poles and transformers on the north side of the site wfllbe removed and disposed of properly. The personal protective equipment ("PPE"), generatedduring the 1994 remedial investigation and currently stored othaite in dnims, wfll be removedftomthe drums and disposed of off-site as sofid waste. Investigation-derived waste ("IDW),also generated during the 1994 remedial investigation and currently stored on-site in drums,will be removed from the drums and buried below the grading layer in the formerunderground storage tank ("UST") excavation. Hie USTs were removed in 1991 as part ofa removal action, and the excavation was lined with geotextfle and backfilled with cleangranular material from an off-site source. Existing debris, consisting of piles of concrete,miscellaneous construction debris, and other solid material that is currently on the groundsurface and that may interfere with subsequent grading or cover placement, wfll also be buriedin the former UST excavation. Excess granular material wfll be reused as the grading layerfor the new impermeable barrier. The emptied drums wfll be rinsed and recycled off-site asscrap steel

During site grading, the surface of the fill wfll be compacted to provide an adequate surfacefor the FML. This compaction wfll also minimize potential settlement from later constructionactivities and future site operations. The surface for the FML will be cleared of rock, sticks,or debris that could damage the FML. Wood chips from shredded trees and bushes wfllcovered with a thin layer of fill so that the liner would not be punctured.

' Monitored Natural Attenuation of site contaminantsGroundwater contamination beneath the IPC she wfll be remediated through monitorednatural attenuation. The Illinois EPA and U.S. EPA adopted this approach for the SER site,noting that the aquifer will not be actively restored to drinking water quality. Illinois EPA andU.S. EPA noted that passive restoration wfll occur over an extended period of time, with onlya small incremental reduction of groundwater contaminants expected on an annual basis.

Groundwater monitoringAt a minimum quarterly groundwater monitoring wfll be conducted. The monitoring data willprovide an indication of the effectiveness of the engineered barrier in preventing surface waterinfiltration and provide data to assess the rate of monitored natural attenuation ofcontaminants in groundwater. However, ft is important to note that groundwater qualityupgradient of the site is highly variable. Several distinct plumes have been identified that willmigrate through the area over an extended period of time. The source, or sources, of theseplumes have not been identified. Groundwater monitoring will be a key component in

19

determining the effectiveness of the impermeable hairier, discussed above, and the decisionat each five year review as to the need to impfcment the contingent option of SVH in additionto the remedy. In order to insure that monitored natural attenuation of groundwatercontinues to be protective of the Rock River, the two shallow monitoring weDs (MW-EPC-12(S) & MW-IPO13(S)) win remain as part of the post-closure groundwater monitoring

For cost ggtjrnaring purposes, the feasibility study assumed that six existing monitoring wells,located upgradient and down gradient of the site, wfll be sampled annually for the 30 yearpost-closure period, and that groundwater samples wffl be analyzed for inorganics on theTarget Anatyte List (TAL"), and VOCs and SVOCs on the Target Compound List (TCL").This ROD requires that a minimum of eight monitoring wells be included in the post-closuremonitoring program and that these weus wfll be sampled at a minimum quarterly. Thischange is not inconsistent with the -30/+SOH accuracy cost estimate indicated by FSguidance.

Quarterly & Annual InspectionFollowing completion of construction activities, site inspections will be performed on aquarterly basis to document the integrity of the existing site security fence and engineeredbarrier, the effectiveness of the institutional controls, and the condition of the monitoring wellsystem. On a yearly basis and consistent with the inspection, maintenance and correctiveaction plan to be developed as part to the remedial design and approved by the Illinois EPAthe pavement wfll be inspected and damaged areas wfll be repaired. Cracks in the pavementwill be filled and the entire surface will be sealed. Results of the inspections will bedocumented in inspection reports submitted to the Illinois EPA.

Contingent SVE enhancementIf, at each five year review cycle, incremental decrease of TOE and 1,1,1-TCA concentrationsare not discemable in groundwater, and this lack of incremental decrease cannot be attributedto up-gradient sources, the implementation of the SVE pilot test wffl be performed. This SVEpilot test win be conducted to acquire not only the standard SVE design parameters of blowersize, vacuum well spacing, projected emission rates, etc, but also to determine the overallviability of the SVE component considering the evidence of landfill gas migration containedin the RI. Further discussion as to the implementabQity of the SVE contingent remedy canbe found above in Section X.6 Iinplementabflity. Key to determining the viability of the SVEcomponent wiD be assessing the viability of passive air wells between the IPC site and PeoplesAvenue Landfill to break the SVE vacuum there by precluding or reducing landfill gasencroachment toward or onto the IPC site (note that technologies other than passive air wellsmay be available or developed prior to the five year review and should also be consideredduring the SVE pilot test).

If implemented, the SVE component of the remedy would consist of a series of gas extractionwells under vacuum created by one or more blowers. The exact number and location of

20

vacuum wefts required to implement an effective program can only be determined followingassessment of the pflot teat results; however the FS projected a series of 32 wells connectedto one blower house. The blower house would contain not only the SVE blower but also amoisture knock-out tank to remove entrained soil moisture and two in-line vapor phasegranular activated carbon units to reduce air emission of VOCs to acceptable limits. Whflenot specificaDy «farM«»d in the FS an additional standard component of SVE blower systemsis a muffler system to reduce noise emission, mis component must be considered duringdesign of the system and installed if appropriate. If implemented the SVE component wouldhave a projected operational period of five (5) years.

Summary of the Estimated Remedy Cost:

Capitol cost for the selected remedy is estimated to be $985,000; Year 1 Operation &Maintenance Cost are estimated to be $87,155; Total Present Worth Cost are estimated tobe $2*328,000. Detailed cost information on all of the above remedy components can befound in the attached Capitol Cost, Year 1 Operation & Maintenance Cost, and Summary andTotal Present Worth Cost tables which are attached.

Expected Outcomes of the Selected Remedy:

Availability of Site for Productive Reuse: The land currently occupied by the EPC sitewould be available for development, consistent with the institutional controls component ofthe remedy, immediately following completion of the impermeable barrier. Completion of theimpermeable barrier, dependent 19011 construction constraints, could reasonably be expectedto be completed whim 3 months of remedial construction start. Groundwater use, becauseof existing local ordinances and state set-back requirements is not anticipated; the remediationof groundwater impacted by releases from the 1PC site, by monitored natural attenuation, isexpected to require in excess of 200 years. This period will likely be extended forgroundwater b the area of the site because of the plume of contaminants migrating towardthe she from up-gradient sources as identified in the RJ and as discussed previously inSection VI above.

Cleanup Levels: Because the selected remedy is a containment remedy with monitorednatural attenuation no specific cleanup levels for groundwater are specified in this ROD. Ifthe contingent remedy SVE component of the selected remedy is implemented specificcleanup levels may be specified at that time. However, since the singular intended purposeof the SVE component is to reduce the soil VOC sources of groundwater contamination,operation of the SVE system to sustained asymptotic removal rates is the expectation of thisRecord of Decision.

It should be noted that the selected remedy may change somewhat as a result of the remedial designand construction processes. Changes to the selected remedy described in the ROD will be

21

documented using a technical memorandum in the Administrative Record, and an Explanation ofSignificant Difference ("BSD"), or a ROD amendment.

XIIL Statutory DeterminationsUnder CERCLA §121 and the NCP; the lead agency must select remedies that are protective ofhuman health and the environment, comply with ARARs (unless a statutory waiver is justified), arecost-effective, and utilize permanent solutions and alternative treatment technologies or resourcepynvi^y technologies to the maximum gxtent practicable Tn addition, CERCLA includes a preferencefor remedies that employ treatment that permanently and significantly reduces the volume, toxicity,or mobility of hazardous wastes as a principal element and a bias agamst off-site disposal of untreatedwastes. The following sections discuss how the selected remedy meets these statutory requirements,

Protection of Human Health and the Environment:

As a result of the various removal actions discussed in Section El above, construction of theimpermeable barrier, maintenance of existing and placement of additional institutional controls on thesite, and monitored natural attenuation of groundwater the selected remedy will adequately protecthuman health and the environment. Exposure levels will be reduced to U. S. EPA's generallyacceptable risk range of 10"* to 10* for carcinogenic risk and below the HI of 1 for non-carcinogens.The implementation of the selected remedy win not pose unacceptable short-term risk or cross-mediaimpacts and there is no evidence to indicate that ecological risks currently exist at the site or will becreated by the selected remedy.

The various removal actions taken at the she have effectively removed all principle threats from wasteat the site. The impermeable barrier wffl serve to protect site workers from dermal contact withcontaminated soils, effectively eliminate volatilization of contaminants to the breathing zone, andsignificantly reduce infiltration of precipitation and snow melt through the contaminated soils. Toinsure that protection is maintained by the impermeable barrier this unit is armored with asphaltpaving and the institutional controls portion of the selected remedy contains adequate provisions formaintenance of this armor layer; requires that any future excavation through the impermeable layerbe performed by construction workers property trained to work with contaminated soils and inenvironments potentially containing VOCs by requiring that such work be performed by workerstrained consistent with 29 CFR 1910.120; and requires that any excavation of soil is managed incompliance with all applicable state and federal laws. An existing Declaration of Restriction attachedto the deed of the property prohibits residential development of the site in the future.

Compliance with Applicable or Relevant and Appropriate Requirements:

The selected remedy consisting of an impermeable barrier, institutional controls, monitored naturalattenuation of groundwater, and the contingent SVE component arc expected to comply with allARARs identified for the alternative. No waiver of ARARs is required for the selected alternative.The ARARs are presented below and in more detail in the ARAR Tables 1 through 7 attached.

Chemical, Location, and Action-Specific ARARs include the following:

22

•Safe Drinking Water Act MCL (40 CFR Part 141), which specify acceptable concentration levelsin groundwater that serves as a potential drinking water aquifer

•dean Water Act FWQC (40 CFR Part 403).

•Clean Water Act National Pollution Discharge Elimination System ("NPDES") Permit Program(40 CFR 122)

•RCRA Subtitle D requirements for lagoon closure (40 CFR 264.), which specify a cap with apermeability less than or equal to the permeability of any bottom liner or natural subsoils present

at the site.

'Post-Closure and Monitoring requirements for 30 years (40 CFR 264).

•RCRA requirements for waste management (40 CFR 264,268,270).

•Clean Air Act National Emission Standards (40 CFR 61, 63)

•Clean Air Act Implementation of State Plans (40 CFR 52)

•Federal Water Pollution Control Act Discharge to POTW requirements (40 CFR 403)

•Illinois Groundwater Quality Standards (35IAC 620)

•Illinois Ambient Air Quality Standards (35 212 & 215)

•Illinois Organic Material Emission Standards and Limitations (35IAC 215)

•Illinois Standards for New Solid Waste Landfills (351AC 811)

•Illinois Air Pollution Permits & General Standards (35IAC 201)

•Illinois Air Pollution Alternative Control Strategies (351AC 202)

•Illinois Water Pollution Introduction & Pretreatment Programs (35IAC 301, 310)

•Illinois Water Pollution Sewer Discharge Criteria (35IAC 307)

•Illinois Sound Emission Standards and Limitations (351 AC 900 & 901)

•Illinois Standards for Owners and Operators of Hazardous Waste Treatment, Storage, andDisposal Facilities (35IAC 724, 725)

23

•Illinois Dcpt Of Public Health, minois Water Well Construction Code (Section 920)

•Illinois Environmental Protection Act Title IV, Section 14.1

•Illinois Public Water Supply regulations (35IAC 653)

Other Criteria, Advisories, or Guidance To Be Considered ("TBCs") for This Remedial Action:

•HEnois Tiered Approach to Clean-up Objectives (35IAC 742)

•City of Rockford, Water Division Ordinance, Section #31-10

In implementing the selected remedy, the Illinois EPA, and U.S. EPA have agreed to consider anumber of non-binding criteria that are To Be Considered ("TBC"). These include the guidanceon designing RCRA caps, Draft RCRA Guidance Document, Landfill Design, Liner Systems andFinal Cover, issued June 1982. The guidance on A^giting RCRA caps includes specifications tobe followed in constructing and Tnnmt«mmg a RCRA cap.

Cost-Effectiveness:

In the Illinois EPA's judgment the Selected Remedy is cost-effective and represents a reasonablevalue 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(0(1 )(ii)(D)). This was accomplished by evaluating the "overall effectiveness" of thosealternatives that satisfied the threshold criteria (Le., were both protective of human health and theenvironment and ARAR-compliant). Overall effectiveness was evaluated by assessing three of thefive balancing criteria in combination (long-term effectiveness and permanence; reduction intoxicity, mobility, and volume through treatment; and short-term effectiveness). Overalleffectiveness was then compared to costs to determine cost-effectiveness. The relationship of theoverall effectiveness of this remedial alternative was determined to be proportional to its costs andhence this alternative represents a reasonable value for the money to be spent

The estimated total present worth cost of the selected remedy is $2,328,000. Alternative #3 is$2,333,000 more expensive, achieves minimal additional short-term risk reduction, and may notbe implementable, therefore the selected remedy is cost-effective. If at the five year review it isdetermined that the selected remedy is not effective in prohibiting further migration of VOCs fromsite soil to groundwater this ROD provides for the implementation of the SVE component ofAlternative #3. As part of that five year review, cost effectiveness of the SVE component, alongwith implcmentability will be revisited if implementation is anticipated.

Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)Technologies to the Maximum Extent Practicable ("MEP"):

While the selected remedy does not adhere with the preference for treatment as a principleelement of the remedy, contingent pro vision'is contained in the selected remedy to implement a

24

treatment alternative (e.g. SVE) if the impermeable barrier is found to not provide adequateprotection of groundwater at the time of the five year review. Information presented during thepublic comment period pleads a persuasive case that active remediation of soil VOCs is likely notrequired to effectively eliminate site soils from further contribution to groundwater contaminationand may not meet the cost-effectiveness requirement of remedy selection. Excavation and on-shetreatment of site soils was evaluated and found to be impracticable.

Utilization of Permanent Solutions and Alternative Treatment Technologies (or ResourceRecovery Technologies) to the Maximum Extent Practicable

The Illinois EPA has determined that the selected remedy represents the maximum extent towhich permanent solutions and treatment technologies can be utilized in a practicable manner atthe site. Of those alternatives that are protective of human health and the environment and complywith ARARs, the Illinois EPA has determined that the selected remedy provides the best balanceof trade-offs in terms of the five Kaiar^tng criteria, wbUe also considering the statutory preferencefor treatment as a principal element and bias against off-site treatment and disposal andconsidering U.S. EPA and community acceptance.

Previous removal actions at the site remediated source materials constituting principal threats atthe site. The selected remedy satisfies the criteria for long-term effectiveness by placing animpermeable barrier over residual soil contamination; implementing institutional controls toprohibit residential development, restrict contact with site soils, and preclude use of on-shegroundwater (use of off-she contaminated groundwater is prohibited by existing state Law & localordinances); and monitored natural attenuation of groundwater consistent with the regionalapproach taken at the SER she. If the impermeable barrier and monitored natural attenuationapproach to reducing or precluding continued she contributions to groundwater contanunationare found inadequate at the five year review this ROD provides for implementation of the SVEcomponent remedy to actively treat residual VOC contamination in she soils.

Preference for Treatment as a Principal Element

This ROD provides for implementation of the SVE component if the impermeable barrier is foundinsufficient. The selected remedy in this ROD does not contain an active current treatmentcomponent. The statutory preference for remedies that employ treatment as a principal element isnot satisfied, however, based on the technical impracticability of excavation for treatment and thehigh probability of success for containment and natural attenuation of the remaining lower levelthreats at this she, active treatment is not currently warranted; if the impermeable barrier is foundinsufficient in protecting groundwater the selected remedy allows implementation of the SVEcomponent and at that time the statutory preference for remedies that employ treatment as aprincipal element would be satisfied.

Five-Year Review Requirements

Because this remedy will result in hazardous substances, pollutants, or contaminants remainingon-she above levels that allow for unlimited use and unrestricted exposure, a statutory review will

25

be conducted within five years after initiation of remedial action to ensure that the remedy is, orwill be, protective of human health and the environment

XIV. Documentation of Significant ChangesThe proposed plan was released for public comment in July of 1999. The plan identifiedAlternative # 3, impermeable barrier, institutional controls, soil vapor extraction ("SVE"), andmonitored natural attenuation of groundwater as the preferred alternative for remediation.Alternative #2, impermeable barrier, institutional controls, and monitored natural attenuation ofgroundwater was also considered and was presented to the public as a contingent remedy if SVEproved to be not implementable due to adverse impacts by landfill gas encroachment toward thesite from the near-by Peoples Avenue T-anHfiii During the public comment period, newassessment of soil data from the RI was presented which indicates that the SVE component ofAlternative #3 may not be necessary to achieve the remedial objectives for the site. Based on thisnew information, summarized in the responsiveness summary vw* available in the administrativerecord file for the she, the Illinois EPA and U.S. EPA decided to select Alternative #2,impermeable barrier, institutional controls, and monitored natural attenuation of groundwater,with SVE component of Alternative #3 as a contingent component as the selected remedy for theIPC site; a final decision on implementation of the SVE is deferred to the five year review. TheIllinois EPA and U.S. EPA believe that this change in the selected remedy, from that proposedcould have been reasonably anticipated based on information presented in the proposed plan andcontained in the admirdstrative record fik for the site. During the five year review the quarterlygroundwater monitoring data wOl be evaluated statistically to determine if Alternative #2 isadequately mitigating the site's contribution to groundwater contamination. If the groundwatermonitoring data fails to show mitigation of the site's contribution, implementation of the SVEpilot test will be implemented. If a decision to implement the SVE component is made by IllinoisEPA and U.S. EPA this decision will be documented in a ESD prior to implementation and thisESD and information supporting the decision will be incorporated into the administrative recordfile for the she.

26

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Risk Table-1

Chemical Rbk Driven forth* Soil Pathway*

Currant On-«ite Worker

Cancer Rtok* = 5 K iff* to 5 x 1(T*

RMERIek Driven

Chemical*

Chromium (VI)Vinyl chloridePNAsCadmiumAraenteCtKMOfurniPCBs

Rtok

3KKT4 (59%)2X104 (32%)2x10* (3%)1x10T* (3%)9x10* (2%)4x10* (1%)2 x 10* (<1%)

NoncancerKH*silto20

RME HI Drivers

ChemteaJ*

1,1-Otehfcjtoethane

HI

16 (90%)

Future Resident

Adult Cancer RWc" * « x 10* to 1 x 10*

RMeRlekOrfvere

CWmical*4

Chromium (VI)Vinyl chloridePNAftAraentoCadmiumPCDtCHorofbrmBeryHum8l«C2-ethylh«xyH)phtha(atelaleViltt tfelAf Ae1^ !/ ^

Methylene chloride

Rtolc

5X10*4 (51%)3 x Iff4 (28%)1x1<r*(13%)SxKT8 (3%)2x10* (2%)9x10* (2%)8x10* (1%)5X10* (1%)3X10* (<1%)2X10* (<1%)1 x 10* (<1%)

ChBd Nencancer HI' « 72 to 126

RUB HI Driver*

Chemical*

1,1-OiohlQfoelhaneTrichtoroetheneCadmiumManganeseChromium (VI)Copper

* The range given is for the MLE and RME scenario* respectively* Exposure to VOCs such as vinyl chloride and 1.1-dichtoroethane is via thei

Exposure to the other chemicals is via ingesten and dermal absorption of aductpaitidtt.

HI

107 (85%)4 (3%)4 (3%)3 (2%)1 (1%)1 d%)

nhaldtofl pathway.9l and inhalation of

Risk Table - 2

Chemical Risk Drivers for the Shallow Groundwater Pathways(Future Resident Population)

Shallow Upgradicnt Groundwater

Adult Cancer Risk* « 3 x 101* to 4 x Iff*

RME Risk Drivers

Chemical*

1.1-DfchloroetheneTetrachloroetheneBsp-ethylhexyljphthalateArsenic1 , 1 -Trlchloroethane

Risk

2 x 10-* (60%)6x10" (16%)5x10* (12%)4x10* (11%)1 x NT* (<1%)

Child Noncancer HI* » 2 to 9

RME HI Drivers

Chemical'

Manganese1.2-Dfchtoroethene

H|

6 (67%)1 (11%)

Shallow Site Oroundwater

Adult Cancer Risk* -3x10^103x10^

RME Risk Drivers

Chemical*

Vinyl chloridePNAs1,1-Dichloroethene*ArsenicTetr«chkxoethenec

Risk

2x10* (86%)2x10" (8%)9x10* (4%)7X1Q-8 (3%)5x10* (<1%)

Child Noncancer HI* = 7 to 23

RME HI Drivers

Chemical'

Manganesevinyl chloride1,2-Ofchloroethene*

HI

16 (70%)4 (17%)2 (9%)

* The range given is for the MLE and RME scenarios, respectively.' Exposures to these chemicals are via the ingestion pathway .c The incremental risk (i.e., site risk minus upgradient risk) is insignificant (i.e.. cancer risk < 10"*

or HI < 1 .0) for this chemical.

Risk Table-3

Chemical Risk Drivofs for the OMP Groundwater Pathway*(Future Resident Population)

Deep Upgradlent Groundwatar

Adult Cancer Risk* « 2 x 10* to 3 x KT*

RMERfek Drivers

Chemical*

1,1-CNcttkxoethanaTetrachloroeihaneBls(2-«thylhexy1)ptithaJate1,2-Otchlofoethane1.1.2-Trichlaroethane

Rlak

3x1(T* (82%)4 x to* (12%)2x10* (5%)2x10* (1%)1 x 10* <<1%)

Child Noncancer HI' = 2 to 7

RUE HI Drfvara

Chemical'

Manganese1 ,2-DichloroetheneTricNoroethene

HI

4 (57%)1 (14%)1 (14%)

OMP Site Groundwater

Adutt Cancer Ri$k* » 1 x 10* to 2 x 10"

RMERtekOrtvtfE

Cftaniicaf

1>DichJoroethenee

1,1.2-Trichtofocthana*ratrachioroetnene

Riak

2 x ID"4 (99%)1x10* (1%)1x10* (1%)

Chad Noncancer HP = 3 to 14

RME HI Driwa

Chemical"

AcetoneManganese6

HI

7 (50%)4 (29%)

* The range given is for the MLE and RME scenarios, respectively.b Exposures to these chemicals are via the ingestion pathway.c . The incremental risk (i.e., site risk minus upgradient risk) is insignificant (i.e., cancer risk < 10"*

or Hi < 1.0) for this chemical.

COST TABLE-1

Capitol Cost Estimate for Alternative #2Institutional Controls and Engineered Barrier

Item Description

Ground-water Monitoring Capitol COM

Ground- water monitoringGround-water Monitoring Ctpitol Cost

(GMCC) Subtotal

Management CostDesign and PlanningCQA/CM

Contingency

Total Ground-water Monitoring Capitol Cost

Enghmred Barrier Capitol CostMobilization/DemobilizationSite PreparationClearing. Grubbing, and ChippingWell AbandonmentRemove Utility PolesRemove Old Fence (not perimecer fence)Remove & dispose of tiresDrum ConsolidationFormer LIST ExcavationPlace Cone, Rubble in Excavation, BackfillDispose of TransformersGrading Layer (1% slope)Geotnembrane (40 mil HDPE)Geotextile ( 1 0 oz., non- woven)Granular Subbase (12 in sand)Asphalt, (surface and base course) (9 in thick)

Engineered Barrier Capitol Cost (EBCC) subtotal:

Management CostDesign and PlanningCQA/CM

Contingency

Total Engineered Barrier Capitol Cost

TOTAL ALTERNATIVE « CAPITOL COST

Quantity

0

15%25%

15%

1I

2.8410

411

175840840

34,700

122,000122,000

6,90013,700

15%25%

15%

Unit

0

GMCC SubtotalGMCC Subtotal

GMCC Subtotal

lump sumlump sum

AcresftEa

tump sumlump sum

drumsCuYdCuYd

EaCuYdSqFtSqFtton

SqYd

EBCC subtotalEBCC Subtotal

EBCC Subtotal

UnitPrice

SO.OO

$0$0

so

5%$25,000J3,000

$25$500

$1,500S2JJOO

$50$4$8

$2400$15$.48$25$14$20

$636,000$636,000

$636,000

Cost

SO

soso$0

$30307$25,000$8.400

$10.250$2,00051 ,500$2.500$8,750$3,360$6,720$7,500

$70.300$58^60$30,500$96,000

$274,000

Subtotal

SO

$0so$0

$0

$636,000

$95,000$159,000

$95,000

$985,000

5985,000

COST TABLE-2

Year One - O * M Cost for Alternative #2Institutional Controls and Engineered Barrier

Item Description

Ground-water Monitoring Year 1 OAM CoatGround-water SamplingChemical AnalysisData Analysis / ReportingQuarterly cite inspectionDeep Monitoring Well ReplacementShallow Monitoring Well Replacement

Ground-water Monitoring year 1 O&M(GMY1) Subtotal

Contingency

Total Ground-water Monitoring Year 1 OAMCost

Engineered Barrier Year 1 O&M CostAnnual asphalt patchingFML replacement (including design A planning)Asphalt replacement (including design &planning)

Engineered Barrier Year 1 O&M (EBY 1 ) Subtotal

Contingency

Total Engineered Barrier Year 1 O&M Cost

Total alternative 2 year 1 O&M Cost:

Quantity

]614

0303

25%

15%

10%

25%

Unit

roundsampleroundroundwellwell

(OMY1) Subtotal

lump sum

EBYl subtotal

UnitPrice

$2,500$1,500$1,000$1,000

$10,00055,000

53,000$201,708

$356,200

$48,705

Cost

$2^00$9,000$1,000$4,000$3,300$1,650

$3,000$10.085

$35,620

Subtotal

$21,450

$5.000

$16,450

$48,705

$12,000

$60,705

$87,155

COST TABLE - 3

SUMMARY ANDTOTAL PRESENT WORTH COST

TOTAL CAPITAL COST

PRESENT WORTH COSTPresent Worth O&M Cost: Ground-water Monitoring

Present Worth O&M Cost Engineered Barrier

TOTAL PRESENT WORTH O&M COST

TOTAL PRESENT WORTH COST (Capitol + Total Present Worth O&M Cost)

ESTIMATEDCOST

$985,000

$410,000$933,000

$1343,000

$2328,000

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In-the Matter of:

Interstate Pollution ControlSuperfund Site

Proposed Remedial Alternative

(Illinois EPA File No. 347-99)

Responsiveness Summary

L Responsiveness Summary Overview

In accordance with the Comprehensive Environmental Response, Compensation and Liability Act("CERCLA") §117,42 U.S.C Section 9627, and National Contingency Plan §300.430(f)(3)(I)(F)(and 300.430(fK5)(iiiXB) the Illinois Environmental Protection Agency ("Illinois EPA") and theUnited States Environmental Protection Agency ("U.S. EPA") held a public comment period fromJuly 10,1999 September 10,1999, to allow interested parties to comment on the "Proposed Plan -Interstate Pollution Control Site, Rockford, Illinois'* (July 1999). Illinois EPA presented theProposed Plan at an evening public meeting on August 10,1999 at the Hblfey Center, 2000 ChristinaStreet in Rockford, IL.

This responsiveness summary has been prepared to meet the requirements of CERCLA§113(k)(2)(iv) as amended by the Superfund Amendments and Reauthorization Act of 1986("SARA") which requires a response "... to each of the significant comments, criticisms, and new datasubmitted in written or oral presentations** on a Proposed Plan for remedial action. Thisresponsiveness summary documents the Illinois EP A's responses to concerns expressed by the public,potentially responsible parties CTRPs") and governmental bodies, in comments received regardingthe proposed plan for the remedial action at the Interstate Pollution Control OTPC") site. Thesecomments were considered prior to selection of a final remedy for the IPC site. The remedy isdetailed in Illinois EPA's Record of Decision ("ROD"), with U.S. EPA's concurrence.

Repository

A local information repository was established in 1992 prior to commencement of the RemedialInvestigation/Feasibility Study ("RI/FS") at the IPC site. This information repository is located atthe Rockford Public Library, 215 North Wyman St Rockford, IL. The information in this repositoryincludes:

Complaint (Civil Action No. 91C20136) People of the State of Illinois, V. 52 entitiesPartial Consent Decree for Remedial Investigation and Feasibility StudyAll Workplan documentsCommunity Relations Plan for Remedial Investigation/Feasibility StudyRemedial Investigation ReportFeasibility Study ReportProposed Plan - Interstate Pollution Control She, Rockford, Illinois

Administrative Record

The complete adnrinistratrve record is housed at the Rockford Public Library, 215 North Wyman St.Rockford, IL and at the Illinois EPA Bureau of Land - Division File, 1021 North Grand Avenue East,Springfield, EL.

II. Questions and Comments Received During the Public Meeting

The public meeting was structured such that Illinois EPA gave an overview presentation of theproposed plan then opened the floor for a public question-and-answcr and comment session. As anote three people attended the public meeting, all of which represented the Potentially ResponsibleParties ("PRPs") for the site. For an exact transcription of the public meeting and the issues raised,

and addressed, during the meeting please refer to the attached Report of Proceedings taken at thehearing of the Interstate Pollution Control Superfund Site Proposed Remedial Alternative. Thefollowing summary questions/comments (presented in italics) were raised at the public meeting,followed by the Illinois EPA's summary response:

WU1 operation of the soil vapor extraction ("SVE") system induce further migration of landfillgas (e.g. methane) Jrom Peoples Avenue LandJUl onto the IPC site? Tins is a possibility and is thereason that the proposed plan contains a contingent option to not implement the SVE component ofthe remedy. The decision to not implement the SVE component would be made after the designeffort pilot test and be based on demonstration of uncontrollable adverse impacts from landfill gas.

Is the Illinois EPA aware of the plume of chlorinated organic solvents, moving from unidentifiedupgradient sources, toward the /PC site; and will the SVE component be expected to remediatethese as they move under the site. Yes we are aware of the upgradient phone; and no, the SVEcomponent of this remedy is intended only to remediate volatile organks in soils at the IPC shethereby removing she contaminants as a source of ongoing contribution to groundwatercontaminatioa

Will the SVE remedy component have an adverse affect on the current anaerobic degradation ofsolvents which is occurring at the site? There may be a change from anaerobic to aerobic vadosezone conditions however, there are recognized aerobic degradation mechanisms and in fact theseaerobic mechanisms can actually benefit from the presence of certain, organic substrates such asmethane contained in the landfill gas.

What is the Illinois EPA's intended schedule for execution of the Record of Decision ("ROD")and when will negotiations start on the Remedial Design/Remedial Action ("RD/RA") effortstart? It is our intention to complete this ROD by September 30,1999 and open negotiations towardRD/RA immediately following.

Would the Illinois EPA accept information from outside sources to support the identification ofPotentially Responsible Parties for the RD/RA effort? Yes.

III. Written Comments Received During the Public Comment Period

Technical comments on the Proposed Plan were received from representatives of the PRP groupduring the public comment period and are summarized in italics below, followed by the Illinois EPA'sresponse.

A series of comments challenged the Proposed Plan's indication that "principal threat* wastesremain at the site following past removal actions. The Illinois EPA acknowledges the positivebenefits of the removal actions and agrees that "principal threat" wastes do not remain at the she.The ROD reflects this acknowledgment.

An assessment of soil data, gathered during the RI, utilizing the approach contained in theIllinois EPA's rieredApproach to Cleanup Objectives ("TAW) 35 LAC Part 742 was provided

as a comment. This assessment indicates that the on site volatile organic compounds ("VOCs")currently represent a threat to industrial and commercial "workers via the inhalation pathway;additionally this assessment indicates that, following construction of the impermeable barrier noVOCs represent a source of further contamination of groundwater. The Illinois EPA has reviewedthis assessment of data and acknowledges the information presented As TACO is not an Applicableor Relevant and Appropriate Requirement ("ARAR") for this action, but rather information thatshould be considered in the analysis of a site (commonly known as To Be Considered) the finalselection of a remedial option cannot be based solely on this analysis; however the TACO analysispresents a reasonable case that the SVE component of the remedy may not be required to removethe ongoing source of groundwater contamination. In acknowledging this comment the Illinois EPAhas selected Alternative #2 as the preferred remedial action while maintaining the SVE componentof Alternative #3 as a contingent remedy enhancement if protection of groundwater is notdemonstrated during each five year review cycle.

A series of comments provide opinion that site soils may not represent a significant past or futurecontributor to groundwater contamination and any positive benefits from the SVE component ofthe remedy could be negated by movement of recognized upgradient groundwater sources ofchlorinated solvents under the site. The Illinois EPA appreciates the concern however does feelthat the site, as it currently exist, is a source of groundwater contamination. In fact the TACOanalysis substantiates that the site, in it's current uncontained situation, is a potential source ofVOC's to groundwater. As to concern that upgradient sources may negate the positive benefits ofthe SVE component, this concern is out weighted by the ability to remove sources of potentialgroundwater contamination.

Several comments reiterated and expanded on the concerns relative to inducement of landfill gas("LEG") migration onto the IPC site and it's potential impacts on the SVE component. DUnoisEPA has previously acknowledged this concern in the proposed plan and believes that both theproponent and contraindicating positions are both speculative absent the performance of a pilot testto support design and selection of operational parameters for an SVE system. The Illinois EPA hasmaintained the SVE component as a contingent remedial option with the implementation decisiondependent upon performance of an adequately designed pilot test definitively verifying an inabilityto safely implement the SVE component.

muiii-ragc runL.u-8/10/99 _

BEFORE THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY0

IN THE NATTER Of: )INTEBSTATE POLLUTION CONTROL ) Illinois

SUTERfUND SITE PROPOSED ) EPA File O47-99

REMEDIAL ALTERNATIVE. )

REPORT OF PROCEEDINGS taken at the

hearing of the above-entitled Batter, held at

2000 Christina street, Rockford, Illinois,

before Hearing Officer John William, reported by

Janice H. Heinemaon, CSX. RMR-CRR, « notary public

within and for the County of Ou Pag* and state of

Illinois, on the 10th day of August. 1999.

commencing at the hour of 7:00 p.m.

APPEARANCES:

MR. JOHN WILLIAMS. IEPA Hearing Officer;

MR. RICH LANGC, Bureau of Land, Division of

Remedial Management, National PrioritiesList. Project Manager;

MR. HARK BR1TTON, Comjnity Relations.

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1 HEARING OFFICER WILLIAMS: Let the record

2 show thai this is a public hearing before the *3 Illinois Environmental Protection Agency in the4 matter of Interstate Pollution Control Supcrfund5 Site Proposed Remedial Alternative. Illinois EPA6 File No. 347-99.7 Good evening, ladies and gentlemen.8 Welcome to this hearing. My name is John Williams,9 and I'm the hearing officer for these proceedings.

10 I will introduce the other members of the Illinois1) Environmental Protection Agency, Illinois EPA.12 staff at the conclusion of this statement13 This hearing is being held by theu Illinois EPA Bureau of Land, SOU Federal Site15 Remediation Section for the purpose of providing an16 opportunity for the public to understand and17 comment on the proposed remedial alternatives forIS the Interstate Pollution Control Superfund Site19 locTed in the southeast Rockford area of Winnebago20 County, Illinois.21 The hearing is being held under the12 provisions of the Illinois EPA Procedures for23 Informational and Quasi-legislative Hearings, 3524 Illinois Administrative Code, part 164. Copies of

Page 41 allowed after the Illinois ERA'S speakers have nude2 their presentations. The hearing officer may limit3 the number of questions per person until everyone4 has had a chance to speak. This question period5 may be extended, if necessary, by the hearing6 officer. Also, a further question period may be7 allowed after all the public comments have been8 made if time permits.9 Those persons asking questions or

10 making comments will, first, please state theiri l name and, if applicable, any governmental body,12 association or organization that they represent for13 the hearing record. If you are representing14 yourself only, you can state that you are an15 interested citizen or an area resident.16 Questions asked of the speakers must,17 firstly, be framed as a question; second, relevant18 to the subject presented; and third, not19 repetitious. Arguing or dialogue with any speaker20 will not be allowed. Questions will be directed to21 the hearing officer, that is, myself; and I will11 then direct the speaker to respond as necessary.23 The Illinois EPA will listen to all24 relevant comments and accept all relevant documents

Page 31 thcc procedures can be obtained from me upon2 request.3 After the presentation by the speakers4 for the Illinois EPA Bureau of Land, who will5 describe ihe proposed remedial alternatives, and6 the public question period, any person who wishes7 10 make oral comments, that is, testify, may do so8 as long as the states are relative to the issues9 which are being addressed at the hearing; and they

10 have indicated that they wish to comment on their11 registration card12 Persons asking questions or making13 comments will initially be limited to five minutesI •> until everyone who wishes to ask questions or make)5 comments has had a chance to speak. If you have16 lengthy comments to make, please submit them to men in writing before the close of the comment period18 and I will ensure that they are included in the19 hearing record as exhibits. There are also public20 comment forms at the registration table for your21 convenience if you wish to use these. Otherwise,22 comments written on standard 8.5 by 11 -inch paper23 will be acceptable.24 A 30-minute question period will be

Page 51 or data as exhibits into the hearing record. Once2 the hearing is adjourned today, I will hold the3 hearing record open until September the 10th, 1999.4 During this time, all relevant written5 comments, documents or data will be accepted and6 entered into the hearing record as exhibits.7 Please send all written comments.8 documents or data to John Williams, No. 21,9 Illinois Environmental Protection Agency, 1021

10 North Grand Avenue East Post Office Box 19276,11 Springfield. Illinois, 62794-9276.12 Written comments need not be notarized13 as to the facts asserted and should be postmarked14 on or before midnight September the 10th, 1999.15 Copies of the hearing agenda, public comment forms.16 are available for your record at the registration17 area. Anyone who fills out a registration card18 will receive a copy of the Responsiveness Summary,19 the Agency's response to public comments and final20 decision when this document becomes available.21 Please check the box on the registration card if22 you wish to make oral comments. If you wish to23 make oral comments but have a time constraint,24 please let the Agency staff at the registration

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i table know, and I will endeavor to call upon you to7 testify as early as possible.

If you require any further information4 after this hearing is over, please contact me at5 telephone number area code 217-782-5544 or Mark6 Britton at area code 211-524-7342. The telephone7 number for anyone who is hearing impaired, that is,8 the TDD number, is area code 217-782-9143 and we9 will be glad to help you.

10 Because a verbatim record of this11 hearing is being made, I would request that you12 keep conversation and noise levels to a minimum so13 that the court reporter can hear and transcribe the14 proceedings.15 On behalf of Director Thomas V.16 Skinner, the Illinois EPA staff present, and17 myself, I wish to thank you for attending and your18 participation at this hearing.19 I shall now introduce the Illinois20 EPA staff present. My name is John Williams, and21 I'm the hearing officer for the Illinois EPA, On22 my left is Rich Lange, Bureau of Land, Division of23 Remedial Management, National Priorities List And24 he's the project manager for this project

PageSI MR. MOVER; Okay.2. MR. LANGE: In fact, all of the overheads3 arc taken directly out of the Feasibility Study.4 MR. MOVER: Okay. 1 don't need to see5 them.6 MK. LANCE: And I thank Montgomery Watson7 for providing such nice material to work with.8 The gist of it is Interstate Pollution9 Control respondents performed the Feasibility Study

10 under Illinois EPA's oversight That Feasibility11 Study resulted in three alternatives, the no action12 beyond maintenance of existing institutional13 controls alternative; institutional controls and anH engineered barrier, Alternative 2; and the15 institutional controls and engineered barrier and16 soil vapor extraction, SVE.17 The common elements of the three18 alternatives include maintaining existing19 institutional controls, a deed restriction20 prohibiting residential development and maintenance21 of the site security fence. Additionally,22 Alternatives No. 2 and No. 3 include the common23 element of further institutional controls,24 including additional deed restrictions to ensure

Page?1 concerning Interstate Pollution Control Superfund2 Site. On my right is Mr. Mark Britton, Community3 Relations, who is the community relations officer4 for this project and for this area concerning thisJ matter.6 At this time I will introduce7 Mr. Rich Lange, who will give a presentation on the8 proposed alternatives by the Illinois Environmental9 Protection Agency Bureau of Land.

10 HEARING OFFICER WILLIAMS: Go ahead,11 Mr. Lange.12 MR. LANGE: This presentation can be13 extremely brief or we can go through it step byM step. Since the three people in attendance areis functioning counterparts with the Interstate16 Pollution Control Potentially Responsible Panics17 Committee and prepared the bulk of the originalIS documents from which my overheads were plagiarized,19 I really see no need to go through them at length.20 If you want to see the show, I can give it to you21 but-

l MR. MOVER.- Not unless anything is changed23 I mean.24 MR. LANGE: I have changed nothing, Scott.

Page 91 protection of construction workers during future2 on-sitc excavation by requiring OSHA training of3 construction workers, appropriate health and safety4 plans during construction activities, compliance5 with ARARs relative to soil management, and further6 obligating adherence to existing enforced local7 and -1 left it out of the proposed plan, but8 there is also — state ground water use9 restrictions. So those are the common elements of

10 Alternatives 2 and 3.11 The Risk Assessment conducted as a12 portion of the Remedial Investigation Feasibility13 Study process, as required by the NCP. indicated14 that Alternative 1 did not sufficiently mitigatel 5 the risk and was rejected and was not considered as16 a viable option for selection as a final remedy.17 Alternative 2. the institutional18 controls and the engineered barrier, the array of19 common elements, institutional controls and an20 engineered barrier consisting of a impermeable21 gcosynthctic liner overlain by asphalt pavement.22 The barrier will be graded to promote drainage.23 Ground water contamination beneath the FPC site will24 be remediated over time through monitored natural

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1 HEARING OFFICER WILLIAMS: Yes. Could you

2 state your name and who you represent3 MR. DKINIS: Jon Dfldnis. I'm with4 Dflcinis Consulting, Inc.5 HEARING OFFICER WILLIAMS: Yes.

6 MR. DflUNiS: And I represent the IPC1 steering committee.8 HEARING OFFICER WILLIAMS: Okay. Go ahead9 MR-DDONIS: I just have a simple

10 question. Is the State doing anything with11 People's Avenue Landfill to control gas?12 MR. LANCE: There is no active effort to13 control gas there, Jon, to ray knowledge. I believe14 there are some investigative activities, current15 starus of potential progress, no knowledge. We can16 get some more information out of Springfield forl? you if you are interested in that.18 HEARING OFFICER WILLIAMS: Anymore19 qv^stions?20 MR.MOVER: Anymore?21 MR. DKINIS: No. I don't have any right21 now. I'm trying to think of a few.23 MR. MOVER; Okay. My name is Scott Moyer.24 I'm with Hamilton Sunstrand. I am the chair of the

Page 16.1 vapor extraction system. I would expect review and2 approval of the pilot test design documents,3 oversight of the pilot test, and review and4 approval of the ultimate design if it's found to be5 practical.6 MR. MOVER: A second question.7 HEARING OFFICER WILLIAMS: YcS, go ahead.8 MR. MOVER: Scott Moycr again. Would the9 pilot test be based on this air curtain injection

10 that you propose that it's currently running as the11 SVE is being done?12 MR. LANCE: It would be conjecture on my13 pan. But in discussion with more than one expert,u I would anticipate a pilot test that 1 could15 support would be done with one or more extraction16 wells ran without the vacuum breaker, the air17 relief system in place for a period of time. And18 those arc sometimes hours, sometimes a few days,19 but very seldom longer than a couple days. Then20 install the vacuum breaker passive air/active air21 injection component, perform a second blower test22 on the same well, and look at the results for23 ultimate decision.24 It may be that the concern of landfill

Page 151 technical committee for the PRPs. I guess my2 question would revolve around the pilot test in3 that what does the Agency envision would be a4 representative test for this site in terms of5 duration, time of year, pumps, equipment, whatever6 is needed.7 MR. LANGE: Generally the design of a pilot8 test would be left to those people familiar with9 the design and implementation of SVE remedies.

10 There is no Illinois EPA standard operating11 procedure for implementation of soil vapor12 extraction pilot tests. If the project remains13 that of Rich Lange, which I conjecture it probably14 will for some period of time, I would expect15 whoever the design contractor for remedying16 implementation to propose a pilot test for our17 review and approval. That would include not only18 number of wells, location of wells specific to the19 site, if there are believed to be seasonality20 influences, it should all be incorporated into the21 proposal, which would be submitted for Agency2: review and approval. You know, you design a pilot23 test, you implement the pilot test, and you use24 that information to design the full-scale soil

Page 171 gas encroachment and migration is overstated. It2 may be that it's understated. U may be that with3 proper operational parameters on an SVE extraction4 system we don't need this vacuum breaker system.5 It may be that we do. We are going to have to look6 at both components I believe independently to7 really tell — or both steps independently, with8 and without, to make a logical decision.9 MR. MOVER: Question three.

10 HEARING OFFICER WILLIAMS- Go ahead.

11 MR. MOYER: What I understand from the12 regional contamination within the area other than13 IPC is that it was estimated that there is aN groundwater plume approaching IPC from the Matteson15 or Madison — 1 forget what it is — machine works16 facility. And that with an SVE system in place,17 I'm concerned that we are going to get into pilot18 texts that may not represent what the future may19 hold in terms of what they are pulling off the20 groundwater in the future in the Vadose zone.21 MR. LANGE: There is what you are talking22 about, Jon, or one drawing of it. We acknowledge33 its existence. The State docs not intend to24 remediate groundwater with this SVE component. We

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Page 181 ait looking for the SVE only to approach soil2 contaminants. If it's under operation of the SVE3 system, it becomes apparent that the soils have4 been remediated and it's an ongoing groundwater5 source. I suspect that the ROD will be written in6 such a fashion as to call a stop to it. If it's7 not, it would be appropriate at that point for8 somebody to come in and present some evidence and9 convince us that a ROD amendment is appropriate,

10 that we are no longer remediating volatile11 contaminated soils, but we are remediating volatile12 contaminated groundwater.13 MR. MOVER: Right.M MR. LANGE: Which is not going to be the15 intent of this ROD. It's not the intent of the16 proposed plan. If we were remediating groundwater17 with no remediation of soils component, we would beis in noncompliance with the Record of Decision or at19 leart in noncompliance with the proposed plan which20 is essentially going to be the Record of Decision21 barring public comment that sways our current22 preference.23 HEARING OFFICER WILLIAMS: Anymore

24 questions?

Page 201 introduce oxygen to the area, 1 have reduced my2 effectiveness of removing chlorinated solvents due3 to partition coefficients, whatever is left on the4 soil, because the anaerobic bugs are not chewing5 them away. And I can understand that that is6 potentially occurring now because I have7 sistcr-and-daughtcr breakdown components in the$ soil as it is. So 1 don't know - honestly don't9 know what that may hold in the future.

10 MR. LANGE: 1 will -n MR. MOVER: i don't know if a pilot test12 for two days will show that, and that's what I'm13 concerned about14 MR. LANCE: I will offset that by personal15 experience. TCA. TCE and pcrchlorocthylcnc do16 degrade in an aerobic environment, that they do17 deplete soil oxygen and generate carbon dioxide18 along with the breakdown products. There was no19 attempt In the RI to validate any of this20 information. It's a new concern, was not presented21 in the evaluation of the alternatives in the FS or22 validated in the Rl to my knowledge. It is a23 concern. It's a matter of record. We will put it24 into the consideration of the SVE component of the

Page 191 MR. MOVER: I may, but I'm waiting for Jon.2 MR. LANGE: Walter, you have got to have at3 least one question to validate your existence.4 MR. BUETTNER: Not yet.5 MR. MOVER: Well, I •• This may not be a6 question, but it's more of a comment7 MR. LANGE. That's all right.8 MR MOVER: For SVE and for the pilot test,9 I'm concerned that you may potentially enter carbon

10 units for air emission, and that if that should11 occur that the methane with its chemical make-up as12 it is it's much more mobile than the chlorinatedn components of the soil vapor gas, and it doesn'tu take a lot of history to tell you that methane willi< really mess up a carbon unit a lot quicker than16 soil vapor extraction. That's the bij concern I17 have with methane in terms of if we actually get18 into carbon units with this thing.19 The second thing I have a concern with20 is that if it goes to air injection it can: 1 potentially turn this anaerobic environment into22 aerobic especially in the winter months. And with23 chlorinated solvents, they do break down more24 readily in an anaerobic environment So if I

Page 2!1 remedy, Scott.2 MR. MOVER: Anaerobic - Anaerobic3 degradation has to be occurring here because of4 essentially vinyl chloride showing up. 1 don't5 know if that's important right now, and it probably6 isn't. But I don't know what that's going to do if7 I introduce a more free-flowing system with8 introducing oxygen.9 MR. LANOE: Yes. And I'm not sure. Scon,

10 that this will be an active air injection system or11 a passive air injection system. I have been led to12 believe that passive air might be sufficient just13 on a thumbnail guess. That would depend a lot on14 the gas permeabilities of the soil and so on, which15 would be a component of data collection during the16 pilot test study design.17 MR. MOVER: Can 1 ask Jon a question real18 quick?19 (Discussion outside the record.)20 MR. DIKIN1S: This might be a two-part21 question. Rich, you arc talking about the22 upgrading groundwater plumes. And if I understand23 you correctly, you arc saying that, okay, we24 recognize that we have a long-term groundwater

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1 problem. So really the test of sv efficiency is ,2 going to be in the .soil, not, you know, beneficial3 impact oo groundwaters as you have these plumes4 coming through, but what's left in the soils.5 MR. LANCE: That is the intent of the6 remedy selection, Jon, is to remove the sink source7 to groundwatcr - further groundwater contamination8 at the ffC site, not to remediate groundwater with9 this remedy but to remediate those soils,

10 chlorinated solvents in particular, to reduce their11 rebound and continued source contamination12 groundwater.13 MR. DIKING; So the second port of my14 question, I know you were wrestling with this, is15 now are you going to judge, you know, what16 standards are going to apply? Or what do you seei 7 are the logical, you know, criteria for soil18 cleanup?19 MR. LANCE: There arc two alternatives20 that I believe are available. They have not a21 clean-up objective, as it were, has not been set.22 I will be going in the very near future to or what23 used to be called clean-up objectives team, it's24 got a new name now, to discuss this issue with

Page 241 HEARING OFFICER WILLIAMS: All right.2 MR. DIKIN1S: Let's say after the pilot3 test the system needs to be supplemented with4 vacuum relief or other safeguards. Is there5 anything in mind that would change the cost6 effectiveness equation? 1 mean we are already in7 the Feasibility Study. You are looking at an8 incremental cost of S2.3 million to deal with, you9 know, VOCs in soils. Is there anything that would

10 trigger a Revaluation of cost effectiveness if the11 costs go up significantly?12 MR. LANCE: There is guidance on13 substantial cost changes from the remedy as14 proposed in the proposed plan, validated in the15 ROD Exactly what that number is I don't recall.16 That would be one trigger. There are probably17 others that do not come to mind, Jon.18 It's not uncommon as a remedy design19 progresses for anybody, anybody, to come up with a20 new mousetrap that will achieve the same arithmetic21 mitigation better or at a substantially reduced22 cost. And those can be incorporated in a ROD23 amendment or an explanation of significant24 difference depending on the magnitude of the remedy

Page 231 them. I would propose to them that we go for2 asymptotic removal rates on the gases coming out of3 the SVE blowers. When we have achieved that4 asymptotic removal, we shut the system off some5 period of time, one month, three months, six6 months, ruin it back on and look for rebound.7 Generally you will experience one or more rebounds8 on an SVE system. When our rebounds are9 insignificant, we will be done.

10 Another alternative that's far less11 preferable to me is to set some soil numbers after12 we have achieved asymptotic gas removal, going13 through the rebound sequence the number of14 iterations of whatever is appropriate, determined15 on the performance on the removals, and then do a16 soil sampling verification of that to some federal17 or state senate numbers. That's the least18 preferable to me. Those are the two clean-up19 objectives that ] see coming out driving the SVE20 remedy, Jon. My preference would be to go to2) asymptotic removal, shut down, look for rebound,22 and until we get to a point of diminishing return23 stay in that sequence.24 MR. DK1NIS: I have another question.

Page 251 change. The State, U.S. EPA. is not opposed to a2 new mousetrap that will mitigate risk and treat -3 remove contaminants from the site. We want to4 reduce the time period of the natural attenuation,i and we sec as an ongoing source of material here,6 as a continuing — a continuing source of7 groundwatcr contamination, which can be gotten hold8 of.9 But we move forward on this Record of

10 Decision, this proposed plan through public comment11 through a Record of Decision, and at some point12 after that somebody comes up with a new and13 marvelous idea that will achieve those goals at14 less cost or more convenience or whatever the15 advantage is, it's totally within anybody's rights16 to request a revisit of a ROD. 1 think — I don't17 know that we could just carte blanche deny18 reviewing and seriously considering an alternative19 remedy.20 HF.ARJNCl OmCRR WILLIAMS: YcS, go ahead.21 MR. BUETTNERi Walter Bucttner with22 Montgomery Watson. Rich, you — In the SV623 system, if I recall correctly, you envisage that24 the pilot system would initially consist of running

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1 the system with one or two extraction wells for a2 couple days and then installing the vacuum release3 system and running it for a couple days?4 MR. LANGE: Along that general line, yes,$ Walter.6 MR. BUETTNER: As a comment, it would

7 appear to me that right now according to the Ri8 that methane from People's Avenue Landfill seems to9 be approaching the boundaries of the IPC site or it

10 may have already reached h.11 MR.LANGE- Yes.

12 MR. BUETTNER: And as an engineer, I would13 be concerned that running a pilot test for only oneH or two days may not give you enough air flow15 through the soil to determine whether or not you16 actually truly are inducing more migration ofn methane onto the site. It may have to nin for18 considerably longer. And my concern, of course, is19 that running in that direction, as you stated20 earlier, if you actually draw methane onto the21 site, you have essentially - You have let the cat22 out of the bag already. Once the methane is on the23 site and you have induced it on the site, you have24 a problem there already from the operation of the

Page 281 positives or false negatives, which would have to2 seriously look at that information. J am not going3 to as a project manager Supersede a design4 consultant's request to gather information which5 would possibly result in a faulty design and a6 faulty remedy.7 I don't think that a small quantity8 of soil methane, soil gas containing methane,9 methane only, induced flow into the IPC site is

10 letting the genie out of the bottle. If somebody11 feels otherwise and can validate that with12 experience, with published reports, whatever, I13 will listen to it and entertain it. But 1 don't14 think five or ten parts per million or five or ten15 percent methane on a short period of time — You

have to realize methane is also very biodegradable.17 Certain of the aerobic and anaerobic biodegradation18 regimes that are out there actually use methane as19 a comctabolite to enhance biodegradation of20 chlorinated solvents. So we bring it over there,21 it ain't going to last very long, personal opinion.22 If you have got information to validate otherwise,23 then put it into the soup.24 MR. MOVER: Real quick question.

Page 271 SVE system from future operation.2 So again, it's more of a comment right3 now. 1 would like to get your response, though.•» What arc your thoughts on the length of time and5 have we potentially caused a worse probably running6 the pilot test in such a way that it could7 potentially induce more methane onto the site?8 MR. LANGE: The specific parameters of the9 pilot tests I would defer to those people who

10 design pilot tests. There will logically be a soili) sampling regime looking for gas permeabilities ofn soils, so on and so forth. Prior to installation13 of the SVE well, those who are knowledgeable at14 designing $ve systems and SVE pilot systems can15 project within reasonable limits the areas of16 influence that they expect. You put in a series of17 gas piezometers, fire up the blower, and look for18 influence at distance. With that information, you19 can model the final design.20 If the preliminary model outputs in21 the design of the pilot test would indicate that

three days is better than two or five days is23 better than TWO or nine days is better than two or24 representative, more likely to avoid false

Page 291 HEARING OFFICER WILLIAMS: Go ahead.2 MR MOVER: When is the Record of Decision3 going to come out? When are you going to notice4 PRPs, and when do you feel the time frame is going5 to kick in for the next start of the RI phase?6 MR LANGE: Our intention currently is to7 issue a Record of Decision yet this federal8 quarter, September 30. On the — It used to be9 SPMMS. I'm not sure what .the name for that is

10 either, but we have an RDRA negotiation start11 October 1. So we will be coming to those peoplen that served on the last committee for aid and13 succor in gathering up any more PRPs, we may or -14 may do any additional PRP work and we may open up15 negotiation to those who will step forward and are16 willing to talk to us. So it's conceivable we17 could be into preliminary design work in spring if18 we can get reasonable movement on negotiation and a19 decree.20 MR. MOVER: One last thing ] think. The21 current IPC PRP group would be willing to assist22 you in the names and addresses of those individuals23 we feel are responsible for the site. And I only24 say that because names of companies have come and

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1 gone since the original PRP search, and they may2 not be the same. And some, in fact, have gone out3 of business. So I think of the PRP group that4 currently exists, they have the most factual5 information they would be willing to share with the6 Agency in terms of potential liability to this7 site.8 MR. LANGE: We would look forward to that9 assistance.

10 MR. MOVER: rm just asking you to give me11 a call when that comes to be.12 MR. LANGE: When we have Our RDRA

13 negotiations Stan October 1, probably about14 October 2 or 3 I will give you a call, Scott.15 MR MOVER: Okay. Sounds good.

16 MR. LANGE: And if it includes enough17 support information for our attorneys to go knock18 on those people's doors, we'll take good19 information from wherever we can get it.20 MR. MOVER: Okay.

21 HEARING OFFICER WILLIAMS: Okay. Anymore22 questions?23 (No response.)

HEARING OFFICER WILLIAMS: Any other

I2

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STATS OF aOJSOSPage 32

COUNTY OF DU I'AGG )

I, JANICE H. HEINEMANK CSR. RMR-CRR.do hereby certify that I am a court reporter doingbusiness in the State of Illinois, that I reportedin shorthand the testimony given at the hearing ofsaid cause, and that the foregoing is a true andcorrect transcript of my shorthand notes so takenas aforesaid

J*ucc H. Ikiwmam. «*. RMft-CM

License No. 084-001391

Page 311 comments?2 (No response.)3 HEARING OFFICER WILLIAMS: Okay. There

4 being no further questions or comments, I'm going5 to proceed to close the hearing.6 The hearing record will remain open•> until September the 10th, 1999, for written8 comments. Written comments need not be notarized,9 as I have said, should be postmarked by midnight

10 September 10, 1999, mailed to myself. My name and11 address appear on the copies of hearing agenda, and12 they are also on the comment forms there. So if13 you wish to take those and use them to send in yourM comments, I would appreciate it.15 And thank you very much on behalf of16 our Director for coming here to this hearing this17 evening and for your information and all your18 participation in the hearing. Thank you. Hearing19 is now dosed. Records remain open until20 September the 10th.21

2 • « •

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Heincmann & Associates630.986.S486

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Hcincmann & Associates630.986.5486

Index Page 4

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8/10/99- zone

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Hcincmann & Associates6S0.986.S486

Index Page 5