'.'f,^"^* "RECORDS CENTER REGION 

FINAL CLOSE OUT REPORT 

416803 

A & F Material Reclaiming, Inc. 

Greenup, Illinois 

I. INTRODUCTION 

This Final Close Out Report documents that the U.S. Environmental Protection Agency 

(EPA) completed all response actions for the A tS: F Materials Reclaiming, Inc site (Site) 

in accordance with Close Out Procedures for National Priorities List Sites (OSWER 

Directive 9320.2-22, May 2011). 

II. SUMMARY OF SITE CONDITIONS 

Background 

The A & F Material Reclaiming site is located on approximately four acres of land on the 

western border of the Village of Greenup, in east central Illinois. The site, which lies on 

the west side of the village, is bounded by open farmland and woodland, the local 

wastewater treatment plant and private residences; fairgrounds lie to the southwest 

{Figure 1). The site has a slope toward the Embarras River, which lies about 600 ft to the 

north, and drainage from the site reaches the river by way of a ditch along a former 

railroad right-of-way west of the site and east of the municipal wastewater treatment 

plant. The local wastewater treatment plant has several lagoons and the plant discharges 

the treated water into the ditch along the railroad right-of-way. 

Three distinct aquifers exist at the site: alluvium till, present at or near ground surface; 

sand and gravel, present at shallow depths below ground surface and bedrock. The 

shallow aquifer is a poor water producer and is not used as a source of water supplies. It 

does, however, furnish recharge to the underlying sand and gravel. The alluvium forms 

an essentially level surface and contains groundwater at shallow depths, in the range of 8 

to 12 feet below grade. According to the measured water levels, groundwater flow is 

directed downslope to the west and north of the Site. The sand and gravel outwash 

aquifer is a regionally significant unit, is present beneath the entire site and receives 

recharge from the overlying alluvium. In the outwash sand and gravel aquifer, 

groundwater flow is generally downslope from the highlands east of the site and tlow in 

the level section of the studv area is directed northward toward the Embarras River. 
Discharge is direcied toward the Embarras Ri\er. The bedroc< aquifer is not significant 

in the area of the site. Fhe lagoons constructed on site during operation of the facilit> 

were exca\ated into the unsaturated portion of the ailu\ial aquifer. Water contained in 

the fractured section of the Pennsytvanian bedrock is present under strong artesian 

conditions. Recharge of tlie bedrock aquifer probahl\ occurs from oserlying units 

located elsewhere, where water le\eis are higher than those ohserved in the study area. 

Based upon water level data from ihe remedial inxc^ligation: neither of the unconsolidated aquifers encountered on site discharges to the draina.;e ditch. 

The historic use of the site has been for industrial purposes. However, there has not been 

any industrial use at the sile since the facility closed in I9S0. C'uiTent land use for the 

surrounding area is residenlial. commercial and recreational f f:iirgrounds are located 

southwest of the sitoV The groundwater aquifer vinderlying th^i site is currently not used 

as a drinking water source 

The A & F Material Reclauning facility began operations in March 1977 as a rec\cling 

plant and ceased operations in 1^80. The facility processed waste materials such as oil. 

sludge, caustics and sult\inc acid into fuel oil and fire retardanl chemicals. There \^erc 

numerous violations oTihe operating pennits issued b> ihc Illinois Environmental 

Protection Agency (Illinois EPA). Within a year of operating, tour storage lagoons 

overfiowed. contaminalmg the surrounding soil and water drainage pathway to the 

EmbaiTas River. !n addition, some of the steel storage tanks failed on several occasions. 

releasing their contents on the site. These tanks held mixtures of waste oils, sludges, 

spent caustics, spent acids, contaminated water and other waste products. 

From December 1980 through December 1982. there were sevifral removal actions at the 

site in which contaminated soils, sediments, tanks and buildings were removed and 

disposed off-sile. These actions included lowering the level ot \vastes in ihe lagoons. 

diking, trenching and remov ing drums and wastes off-site. In addition, a temporary cap 

was placed over a portion of the consolidated sludge on-site. 

In December 1982. the Sile was included on the proposed National Priorities List (NPL). 

The site was finalized on this list on September 8. ]983. In November 1983. an Initial 

Remedial Measure was imjilemented to address remaining site contaminants in tanks and 

drums. The remaining wastes on-site included about 153.000 gallons of contaminated 

liquids in tanks. 16.000 gallons of contaminated oil in tanks and 20 drums with unknown 

contents. All tanJ< liquids, oils and drums were disposed off-siie at an approved facilil> 

through the Initial Remedial Measure. 

On September 12, 1984. a Partial Consent Decree was entered nto by four of the 

potentially responsible parties (PRPs) which outlined a remedial action plan that included 

a phased approach for cleaning up the Site. The first phase included the remedial 
investigation (RI) and the feasibility study (FS); the second phase was an immediate 

removal action to address the threatened release of contaminates from the two lagoons; 

the third phase involved removal and disposal of contaminated soils and sediments, 

removal and disposal of the buildings and equipment, final site grading, air monitoring, 

and site security and the final phase of the remedial action plan involved closure and 

groundwater monitoring requirements. 

Remedial Investigation/Feasibility Studv 

The remedial investigation report did not include a formal baseline risk assessment. 

Since the lagoon sludge, wastewater and oil, along with tank waste, were removed under 

the Interim Remedial Measure, they posed no enviromnental impacts or adverse health 

effects to the neighboring community. The primary concerns associated with the site 

were with respect to the soil, sediment, groundwater and surface water. 

Soils in the area of the tank farm were contaminated and posed an environmental threat. 

Several sediment samples taken from the drainage ditch showed low levels of 

polynuclear aromatic hydrocarbons (PAHs), but sediments from the nver did not have 

any substannal contamination. Neither the drainage ditch nor the river showed any 

contamination above background levels. 

Data from groundwater wells showed elevated levels of sulfate, total dissolved solids 

(TDS), and oil and grease. Addifionally, several metals were detected at levels higher 

than background and in some cases higher than the Illinois EPA standard for 

groundwater. Because of the dilution effect between the groundwater and surface water, 

it was expected that the contaminated groundwater would not cause contamination in the 

river. Also, the planned removal of contaminated materials from the site would remove 

the primary source of contamination to the groundwater. The remedial investigation 

concluded there was a high flow rate through the sand and gravel aquifer, which would 

allow for rapid flushing of any residual contaminants. 

ROD Findings 

EPA issued an EDD for Operable Unit 1 (GUI) on June 14. 1985. that addressed the soil, 

sediments, building and equipment. EPA then issued an EDD for Operable Unit 2 (0U2) 

on August 14. 1986. that addressed groundwater. 
The selected remedy forOl'l included: 

• .All soils, surface and subsurface, contaminated above the recommended action levels 

were to be removed and disposed at an olT-site facilitv: 

• Facility equipment and building structures were to be cleaned, dismantled, removed 

and disposed at an off-site facility; 

• Site grading to eliminate ponding; 

• .Maintenance of a vegetative cover to prevent erosion and 

• Groundwater monitoring to confimi that no further soil removal was required. 

The selected remedv for 01.^2 included: 

• Establishing a groundwater monitoring program to lest vshtther all residual 

groundwater contamination remaining after the cleanup would steadily decrease to 

safe levels bv natural dilution and purging to the Embarras RiNcr without causing 

violation of the water quality standards of the river: 

• Establishing adequate institutional controls so that drinking water wells are not placed 

in the contaminated groundv\ater areas during the period of natural dilution and 

purging and 

• Establishing procedures for regular review of monitoring data until safe levels are 

reached or data contradicting the teasibility study conclusicns demonstrates the need 

to reevaluate the remedv. 

On May 24. 2010. an Explanation of Significant Differences (ESD) was signed by EP.A. 

The purpose of the ESD was to eliminate iron, manganese, sullate and total dissolved 

solids (TDS) as site contaminants of concern from the groundwater cleanup remedy 

selected in the 1986 ROD. With the elimination of iron, manganese, sulfate and TDS as 

site contaminants of concern, the action levels identified in the 1986 ROD for these 

contaminants are no longer applicable or relevant and appropriate. 

Design Criteria 

The groundwater monitoring program was agreed to b\ the Consenting Defendants in 

1988 and documented in the August 1988 Remedial Action Pla:i as required bv the 

.August 14. 1986. ROD for 0U2. ['ndcr the plan, several additional monitoring wells 

were installed and a few existing wells were abandoned. Tvven A parameters listed in the 

1986 ROD were to be periodiealiy monitored until their concentrations dropped below 

their specific action level a.- specified in the ROD. The action levels v\ere based upon 

Maximum Contaminant Levels (MCLs) and Secondarv Maximum Contaminant Levels 

(SMCLs) of the Safe Drinking Water Act. Elimination of a parameter in a given well 

could occur when thai parameter had not been detected above ihe action limits tor a 

specified period of time per the procedures in the .August |988 Remedial .Action Plan. 
The Consent Decree was entered on October 5. 1989. EPA approved the design, 

including plans and specifications for well placement, project health and safety plan, and 

qualit>' assurance project plan in May 1990. Well construction was completed and a final 

inspection was conducted on July 9, 1990. 

RemediaJ Construction Activities 

EPA signed the Preliminary Close-Out Report, documenting that all construction 

activities for the final operable unit at the site had been completed, on September 24, 

1992. With the signing of the May 24, 2010 ESD all groundwater cleanup levels have 

been attained and therefore groundwater monitoring will no longer be required. 

Community Relations Activities 

A communit)' relations plan was developed to assess the community's informational 

needs related to the site and to outline community relations activities to meet these needs. 

Residents and community' officials were interviewed and their concerns were 

incorporated into this plan. Through a cooperative agreement with EPA, Illinois EPA is 

the lead agency responsible for the community relations program. 

As part of the community relations program, two information repositories are maintained: 

Greenup Township Public Library, 101 North Franklin Street, Greenup, Illinois and the 

EPA, Region 5, Records Center, 7"" Floor, 77 W. Jackson Boulevard. Chicago, Illinois. 

All formal reports submitted by the PRPs have been made available at these locations. 

The repositories also contained documents prepared by EPA including fact sheets, the 

Proposed Plan and the ROD. 

EPA held a public meeting to discuss the recommended remedial alternatives and the 

other alternatives addressed in the Proposed Plan and to seek public comment. 

i n . MONITORING RESULTS 

Long-term ground water monitoring began in 1990 to determine if the groundwater 

contamination was attenuating through the use of natural processes. Between 1990 and 

1999, sixteen of the twenty monitoring parameters were eliminated, as their 

concentrations had dropped below their respective action levels. Following the March 

1999 sampling event, only four of the original twenty parameters were monitored: iron, 

manganese, sulfate and total dissolved solids. 
The action levels for these four parameters are SMCLs. which are non-enforceable 

guidelines regulating contaminants that may cause cosmetic or aesthetic etTccls in 

drinking water. Rev iew ot groundwater data by EP.\ concluded that these constituents 

are naturally occuiTing. do not pose a risk to human health and the environment and are 

stable or decreasing in concentration. 

On May 24. 2010. an ESD was signed by EPA eliminaiing iron, manganese, sulfate and 

total dissolved solids (1 DS) as site contaminants of concern trom the groundwater 

cleanup remedy. With the elimination of iron, manganese, sul ate and TDS as site 

contaminants of concern, the action levels identified in the 1986 ROD for these 

contaminants are no longer applicable or relevant and appropriate. Therefore, all 

groimdwater cleanup levels have been attained and groundwater monitoring will no 

longer be required. 

IV. SUMMARY OF OPFRATION AND MAINTENANCE 

Operation and maintenance activities are no longer required at the sile. 

V. DEMONSTRATION OF CLEANUP ACTIV ITY Q t ALITV ASSURANCE AND 

QUALITY CONTROL 

The U.S. Army Corp of Engineers (USACE) was retained b\ FPA to oversee well 

construction. The remedial action plans and specifications for well constniction and 

groundv\ater and surface water monitoring were carefiilly rev iewed by EP.A and L^SACE 

for compliance with all EPA quality assurance'quality control (O.VQC) procedures and 

standard engineering and construction practices. Onlv EPA analytical methods were used. 

or where other more appropriate Federal standards or methods •:-'xisted. these were used. 

All procedures and protocols followed tor groundwater and surt^ace water sample 

analyses during this remedial action have been documented in the Quality Assurance 

Project Plan approved as part of the plans and spccificalions during the design phase. The 

USACE documented compliance during construction. 
VI. FIVE-YEAR REVIEW 

Five-year reviews were completed for the A & F Reclaiming site on September 27, 2000, 

September 29, 2005 and June 30, 2010. The June 30, 2010 five-year review concluded 

that the site remedy was protective of human health and the environment. 

Cleanup goals for soil and groundwater have been achieved. Hazardous wastes no longer 

remain on-site that would prohibit unlimited use or unrestricted exposure. Therefore; 

five-year reviews are no longer required at the A & F Material Reclaiming Superfiind 

site. 

VII. SITE COMPLETION CRITERIA 

This site meets all the site completion requirements as specified in OSWER Directive 

9320.2-09-A-P, Close Out Procedures for National Priorities List Sites. The site remedy 

is protective of human health and the environment. All remedial action activities have 

been completed. All groundwater cleanup levels have been attained and groundwater 

monitoring will no longer be required. The 1986 ROD specified that "institutional 

controls will be required until groundwater quality returns to background levels or below 

the State and Federal criteria." Because groundwater cleanup levels have been attained, 

EPA no longer requires that institutional controls be maintained at the site. 

Approved By: 

' Cc..*-'^^' / C J ^ /0~L/ , 

Richard C. Karl, Director Date 

Superfund Division 

U. S. EPA, Region 5 
Figure 1 - A & F Material Reclaiming Inc., Greenup, IL - Site Map 

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