EPA Region 5 Records Clr.

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First Five-Year Review Report

Evergreen Manor Groundwater Contamination Site

Winnebago County, Illinois

CERCLIS ID#ILD984836734; Site SPILL # 05MZ

December 2008

Prepared By:

U.S. EPA Region 5 Superfund Division

77 West Jackson Boulevard Chicago, IL 60604-3590

Approved by: Date:

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Table of Contents

Table of Contents ii

List ofAcronyIlls iv

Executive Summary vi

Five-Year Review Summary Form. vii

I. Introduction 1

II. Site Chronology 2

III. Background 3

Physical Characteristics 3 Land and Resource Use :3 History of Contamination 4 Initial Response 4 Basis for Taking Action 5

IV. Remedial Actions 5

Remedy Selection 5 Remedy Implementation 6 Institutional Controls 7 System Operations/Operation and Maintenance (O&M) 9

V. Progress Since Last Five-Year Review 9 Protectiveness Statements from the Last Review 9 Issues and Recommendations from the Last Review 9

VI. Five-Year Review Process 11

Administrative Components 11 Community Notification and Involvement 12 Document Review 12 Data Review 12 Site Inspection 13

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Table of Contents (Continued)

VII. Technical Assessment 14

Question A: Is the remedy functioning as intended by the decision documents? 14

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAGs) used at the time of the remedy selection still valid? .15

Question C: Has any other information come to light that could call into question the protectiveness of the remedy? 15

Technical Assessment Summary 16

VIII. Issues 16

IX. Recommendations and Follow-up Actions 17

X. Protectiveness Statements 18

XI. Next Review 18

Tables

• Table 1 - Chronology of Site Events 2

Attachments

• Attachment 1 - Site Map 18 • Attachment 2 - Memorandum documenting EPA decisions 19 • Attachment 3 - Communications Plan with Winnebago County 22 • Attachment 4 - Public Notice Advertisement 26 • Attachment 5 _ Monitoring Well data from RD Report 27 • Attachment 6 - Vertical Aquifer Profile data from RD Report 28

111

ARAR

CD

CERCLA

CFR

CIC

EPA

ESD

FYR

Ie

MCL

MW

NCP

NPL

O&M

PCOR

PRP

RA

RAO

RD

RIlFS

ROD

List of Acronyms

Applicable or Relevant and Appropriate Requirement

Consent Decree

Comprehensive Environmental Response Compensation and Liability Act

Code of Federal Regulations

Community Involvement Coordinator

United States Environmental Protection Agency, Region 5

Explanation of Significant Difference

Five-Year Review

Institutional Control

Maximum Contaminant Level

Monitoring Well

National Oil and Hazardous Substances Pollution Contingency Plan

National Priorities List

Operation and Maintenance

Preliminary Close-Out Report

Potentially Responsible Party

Remedial Action

Remedial Action Objective

Remedial Design

Remedial Investigation/Feasibility Study

Record of Decision

IV

RPM Remedial Project Manager

SDWA Safe Drinking Water Act

UUIUE Unlimited Use or Unrestricted Exposure

VOC Volatile Organic Compound

v

Executive Summary

The Evergreen Manor site is a narrow, two-mile long area oflow level groundwater contamination in Winnebago County, Illinois, just north of the Village of Roscoe. The primary contaminants found in groundwater at the site are trichloroethylene (TCE) and tetrachloroethylene (PCE), with low levels ofother Volatile Organic Compounds (VOCs) also detected.

In May 1999, three potentially responsible parties (PRPs) signed an Administrative Order on Consent (AOC) to finance a Non-Time Critical Removal Action that connected 281 residences to the North Park Public Water District. U.S. EPA completed the public water hookup in 1999 and 2000, and the private wells at the affected homes were permanently sealed according to state code.

A Record of Decision (ROD) was issued in September 2003 to address residual groundwater contamination at the site. The selected remedy called for local groundwater use controls, Monitored Natural Attenuation, in-home vapor intrusion monitoring, and contingency actions should groundwater or vapor monitoring warrant their deployment.

U.S. EPA allowed the PRPs to conduct the Remedial Design (RD) under an Administrative Order separate from the Remedial Action (RA) in order to establish whether vapor intrusion was a valid concern at the site. No samples from the RD investigation contained contamination exceeding the remedial standards set forth in the ROD. Because all monitoring points that still have detectable groundwater contamination are below remedial standards, the remedy is essentially complete.

The remedy is currently protective of human health and the environment in the short-term. Contaminant concentrations are below levels that would preclude Unlimited Use or Unrestricted Exposure (UU/UE), and residences originally affected by the plume have been connected to the public water supply.

Long-term protectiveness of the remedy will be ensured by the implementation of a groundwater monitoring plan and EPA's authority to execute contingency actions if contaminant concentrations rebound. Because sampling indicates that the groundwater already meets the cleanup standards for UUIUE, the ICs for groundwater required by the ROD are no longer necessary to ensure protectiveness. Nevertheless, local ordinances are already in-place that serve as contingency measures by limiting well installation and the use ofgroundwater in the affected area. EPA also required Waste Management and Ecolab to develop a Communication Plan, which compels them to keep Winnebago County representatives apprised of the status of the remedy, thereby ensuring that the county's restrictions on well drilling target affected areas. In the unlikely event that contaminant concentrations rebound, the existing ICs and the Communication Plan work together to ensure long-term protectiveness.

VI

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Five-Year Review Summary Form

Site IDEYIIFlC \TION

NPL status: 0 Final 0 Deleted IRI Other (specify) Superfund Alternative Site

Remediation status (choose all that apply): 0 Under Construction IRI Operating 0 Complete

Multiple OUs?* 0 YES IRI NO Construction completion date: 0 I/28/2004

Has Site been put into reuse? 0 YES 0 NO IRI NOT APPLICABLE I I

RE\ IE\\ ST \Tl S

Lead agency: IRI EPA 0 State o Tribe 0 Other Federal Agency

Author name: William 1. Ryan

Author title: Remedial Project Manager IAuthor affiliation: U.S. EPA Region 5, SFD

Review period: 05/13/2008 to 1112008

Date(s) of Site inspection: OS/21/2008

Type of review: IRI Post-SARA o Pre-SARA o NPL-Removal only o Non-NPL Remedial Action Site o NPL State/Tribe-lead o Regional Discretion

Review number: IRI I (first) 0 2 (second) 03 (third) o Other (specify)

Triggering action: o Actual RA On-site Construction at au # o Actual RA Start at OU# IRI Construction Completion o Previous Five-Year Review Report o Other (specify)

Triggering action date (from WasteLAN): 01/28/2004

Due date (jive years after triggering action date): 01/28/2009

Site name (from WasteLAN): Evergreen Manor Groundwater Contamination

EPA ID (from WasteLAN): CERCLIS ID# ILD984836734; Site SPILL # 05MZ

* ["OU" refers to operable unit.] ** [Revi"w period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

Vll

Five-Year Review Summary Form (Continued)

Issues:

There are currently no issues at the Evergreen Manor site. The Remedial Design Report indicates contaminant concentrations are below levels that would preclude UU/UE.

Recommendations and Follow-up Actions:

None

Protectiveness Statement:

The remedy is currently protective of human health and the environment in the short-tenn. Contaminant concentrations are below levels that would preclude UUIUE, and residences originally affected by the plume have been connected to the public water supply.

Long-tenn protectiveness of the remedy will be ensured by the implementation of a groundwater monitoring plan and EPA's authority to execute contingency actions if contaminant concentrations rebound. Because sampling indicates that the groundwater already meets the cleanup standards for UUIUE, the ICs for groundwater required by the ROD are no longer necessary to ensure protectiveness. Nevertheless, local ordinances are already in-place that serve as contingency measures by limiting well installation and the use of groundwater in the affected area. EPA also required Waste Management and Ecolab to develop a Communication Plan, which compels them to keep Winnebago County representatives apprised of the status of the remedy, thereby ensuring that the county's restrictions on well drilling target affected areas. In the unlikely event that contaminant concentrations rebound, the existing ICs and the Communication Plan work together to ensure long-tenn protectiveness.

Other Comments:

Evergreen Manor is a Superfund Alternative (SA) site. Superfund Alternative sites are eligible to be placed on the National Priorities List (NPL) but are not listed. At these sites the U.S. EPA acts in accordance with the practices nonnally followed at sites listed on the NPL, and strives for equivalency in the absence of an NPL listing to ensure that settlements covering SA response actions achieve cleanup levels equivalent to those required at NPL sites. U.S. EPA provides the States, Tribes, Federal natural resource trustees, and communities the same opportunity for involvement as that provided at NPL sites, and U.S. EPA's enforcement posture at SA sites is equivalent to its enforcement posture at NPL sites.

Vlll

Five-Year Review Report

I. INTRODUCTION

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

The Agency prepared this Five-Year Review pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) §121 and the NCP. CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the Site, the President shall reviel1' such remedial action no less often than each five years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, ifupon such reviel1' it is the judgment of the President that action is appropriate at such Site in accordance with section [104j or [106j, the President shall take or require such action. The President shall report to the Congress a list offacilitiesfor which such reviel1' is required, the results ofall such reviel1's, and any actions taken as a result ofsuch reviel1's,

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

Ifa remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the Site above levels that allowfor unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation ofthe selected remedial action.

The U.S. EPA Region 5 has conducted this Five-Year Review of the remedial actions implemented at the Site. The review was conducted between May 2008 and November 2008. This report documents the results of the review.

This is the first Five-Year Review for this Site. The triggering action for this review was the signing of the Preliminary Construction Completion Report (PCOR) on January 28,2004, as recorded in the U.S. EPA's WasteLAN database.

This Five-Year Review is a Policy review. Policy reviews are not required under CERCLA, but are performed as a matter of EPA policy. These reviews are triggered by the date that remedial action construction is completed at a site. Policy reviews are required for sites where (1) a pre­SARA remedial action leaves hazardous substances, pollutants, or contaminants onsite; or (2) a pre or post-SARA remedial action will allow for unlimited use and unrestricted exposure, but requires five years or more to complete. Evergreen Manor is a type 2 policy review.

II. SITE CHRONOLOGY

Table 1 - Chronology of Events

Event Date

Contamination discovered after mortgage lender requires a well test in the Evergreen Manor subdivision

1990

IEPA conducts groundwater investigations and determines the source is an industrial area near the intersection of Route 251 and Rockton Road

1990 - 1995

U.S. EPA completes an engineering evaluation/cost analysis to evaluate options to address the contaminated drinking water supplies

1998

Site proposed to NPL July 28, 1998

U.S. EPA issues an action memorandum for a Non-Time Critical Removal Action (NTCRA) to connect 281 residences to the North Park Public Water District

March 1999

Waste Management, Regal-Beloit, and Ecolab, sign an Administrative Order on Consent to finance the NTCRA

May 1999

U.S. EPA carries out the public water hookup under the NTCRA

1999 - 2000

ROD Signature September 2003

Preliminary Close Out Report January 28, 2004

Ecolab and Waste Management sign an Administrative Order on Consent for Remedial Design

September 29,2004

RD Complete May 24,2006

Consent Decree for Remedial Action lodged with the court May 29,2008

III. BACKGROUND

Physical Characteristics - The Evergreen Manor Groundwater Contamination site is defined by a narrow plume of shallow groundwater contamination located approximately 1.5 miles northwest of the historic Village of Roscoe in Winnebago County, Illinois. The source of the contamination is an industrial area located near the intersection of IL Route 251 and Rockton Road. The site includes four residential subdivisions affected by contaminated groundwater: Hononegah Heights, Tresemer, Old Farm and Evergreen Manor (Attachment 1). The area was farmland prior to development, and is bounded to the south by the Rock River and to the west by the Hononegah Forest preserve. To the north and east are agricultural fields and a gravel pit/concrete mixing facility owned by Roscoe Rock and Sand, Inc.

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Land and Resource Use - Land use in and around the site is residential, agricultural, commercial and industrial. The land from Hononegah Road to the Rock River is residential. Directly north of Hononegah Road is commercial property with a strip mall. Between the strip mall and Rockton Road, on the west side ofIL Route 251, most of the land is active farmland. This area also includes the sand and gravel quarry/cement mixing facility owned by Roscoe Rock and Sand, Inc. To the east of IL Route 251, from Hononegah Road to Rockton Road, land use is mixed commercial, light industrial and residential. This area includes the Ecolab facility, the Waste Management Transfer Station, and Regal Beloit, as well as other companies. In the northeast quadrant of IL Route 251 and Rockton Road most of the land is light industrial and is occupied by an industrial park.

History of Contamination - Contamination was discovered in 1990 when a mortgage company required a homeowner to sample their well and found VOCs above drinking water Maximum Contamination Limits (MCLs). Subsequent groundwater investigations linked the contamination to an industrial area located near the intersection of IL Route 251 and Rockton Road. Between 1993 and 1995 IEPA collected more residential well samples and installed 24 groundwater monitoring wells. Sampling showed that the groundwater contained TCE and PCE, and linked the contamination to former waste disposal areas at three companies:

I. Waste Management, which purchased property in the late 1980s or early 1990s from AAA Disposal, where a landfill was covered with soil and granted closure by IEPA in 1977. Soil samples collected from the property contained low levels of TCE (13 uglkg), I, I-dichloroethane (8 uglkg), cis-I ,2-dichloroethene (15 uglkg) and PCE (6.8 uglkg); and higher levels of benzene (1,000 uglkg), toluene (940 uglkg) and xylene (7,300 uglkg).

2. Regal-Beloit, which discharged wastewater to a septic field and 5 underground storage tanks that were closed under the IEPA RCRA program in 1987. Soil samples collected from the Regal Beloit property contained low levels of TCE (7 uglkg) and I, 1,1­trichloroethane (2 uglkg).

3. Ecolab, which operated a wastewater lagoon that was removed under IEPA oversight in 1979. Groundwater monitoring well MW-103, which is immediately downgradient of Ecolab, had the highest concentrations of PCE (40 ug/L) and 1,1,1- trichloroethane (16 ug/L) detected at the site.

Initial Response - In 1998, U.S. EPA completed an engineering evaluation/cost analysis to assess options for addressing the contaminated drinking water supplies. In March 1999, U.S. EPA issued a memorandum for a Non-Time Critical Removal Action (NTCRA) to connect 281 residences to the North Park Public Water District.

The memorandum supporting the NTCRA cites the following criteria for implementation:

Conditions at the Evergreen Manor Site present a threat to public health or welfare as specified in Section 300.415(b)(2) ofthe National Contingency Plan

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(NCP).

(a) Actual or potential contamination ofdrinking water supplies or sensitive ecosystem.

us. EPA and IEPA analytical results indicate that 108 residential wells are contaminated with TCE in excess ofthe MCL and 4 wells are contaminated with PCE in excess ofthe MCL. Us. EPA estimates that a total of250 residential wells are contaminated or are at risk offuture contamination.

(b) The unavailability ofother appropriate federal or state response mechanisms to respond to the release.

This factor supports the action proposed by this memorandum at the Evergreen Manor Site because the IEPA does not have the resources to conduct a response action itselfand has requested us. EPA's assistance. IEPA has fully supported Region 5's efforts to mitigate the threats to public health, welfare, and the environment at the Evergreen Manor Site as an NTC removal action.

Given the Site conditions, the nature ofthe hazardous substances on Site, and the potential exposure pathways to nearby populations described in Section II and III above, actual or threatened releases ofhazardous substances from this Site, ifnot addressed by implementing the response action selected in this Action Memorandum, may present an imminent and substantial endangerment to public health and welfare and the environment. The implementation ofthe response action selected in this Action Memorandum will mitigate the actual or threatened releases ofhazardous substances from this Site. The presence ofTCE and PCE in residential well samples, at levels in excess ofthe MCLs, represents an imminent and substantial endangerment to local residents.

In May 1999, the PRPs signed an Administrative Order on Consent (AOC) to finance the NTCRA. U.S. EPA completed the public water hookup in 1999 and 2000, and the private wells at the affected homes were permanently sealed according to state code.

Basis for Taking Action - EPA's 2000 and 2002 groundwater sampling showed that TCE and PCE were present in the groundwater above the federal maximum contaminant levels (MCLs) for drinking water, as specified in the Safe Drinking Water Act, 42 U.S.c. §§ 300f-300j-11. Using EPA's then current recommended carcinogenic toxicity values for TCE and PCE, the remaining concentrations ofTCE and PCE corresponded to an excess lifetime cancer risk of2 x 10 A. This risk is slightly above EPA's generally acceptable risk range of I x 10 A to 1 x 10 -6. Low levels of benzene, ethyl benzene, toluene, x.ylenes, acetone, methylene chloride, Freon 113 (I, I ,2­trichloro-l,2,2-trifluoroethane), 2-butanone (methy ethyl ketone), 1,1, I-trichloroethane (1, 1,1­TCA), cis-l ,2-dichloroethene (cis-l ,2-DCE), 1,1-2-4 dichloroethene (l, I-DCE) and 1,1­dichloroethane (l, I-DCA) were also detected in the groundwater.

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IV. REMEDIAL ACTIONS

Remedy Selection - A Record of Decision (ROD) was issued in September 2003 to address the residual groundwater contamination at the site. U.S. EPA developed the following Remedial Action Objectives (RAOs) for the site to address the risks identified in the risk assessment and the streamlined risk evaluations. These RAOs are based on current and reasonably anticipated future land and groundwater use:

1. Return the groundwater to a useable source of drinking water. This will be done by restoring the groundwater to drinking water standards for TCE, PCE and any other site­related chemicals found during Remedial Design/Remedial Action (RD/RA). Because the groundwater contains more than one contaminant, groundwater contaminants will also be reduced to concentrations that correspond to a total excess lifetime cancer risk of 1 x 10 -4 and a non-cancer hazard index less than 1.0. Drinking water standards and risk­based levels for site-related chemicals will be attained at all points throughout the aquifer within a reasonable time frame for the site.

2. Prevent people from using the contaminated groundwater as a source of drinking water until the groundwater is restored to drinking water standards and acceptable risk-based levels.

3. Verify that new and existing private wells are not impacted by the groundwater contamination during the groundwater cleanup.

4. Minimize the spread of groundwater contaminants.

5. Verify that potential site-related risks from the vapor intrusion pathway remain below a total excess lifetime cancer risk of 1 x lOA and a non-cancer hazard index of 1.0.

6. Verify that TCE, PCE and any other site-related groundwater contaminants do not impact the Rock River as the groundwater flows into the river.

Remedy Implementation - Subsequent to the 1999 - 2000 removal action that connected affected residences to the public water supply and the signing of the ROD in 2003, questions remained as to whether contaminant concentrations at the site warranted the implementation of an invasive vapor intrusion study at properties with inhabited buildings. Pursuant to these concerns, on September 29,2004, EPA signed an AOC with Ecolab and Waste Management for RD only. This allowed the PRPs to reinvestigate the site to determine if a complete vapor intrusion pathway (as defined by the OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils) existed at the site before agreeing to a remedial action that could include vapor intrusion monitoring.

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The PRPs submitted a Remedial Design Work Plan on May 26,2005, which EPA approved on June 7, 2005. They proceeded to conduct the RD investigations, and submitted a Remedial Design Report to EPA on February 13, 2006. The investigation re-sampled 24 existing monitoring wells and completed three vertical aquifer profiles through the center of the inferred plume. Sample results from the monitoring wells and vertical aquifer profiles indicated no contamination exceeding the remedial standards set forth in the ROD remained at the site. The Remedial Design Report thus concluded that a definable groundwater contamination plume no longer exists and that the vapor intrusion pathway is incomplete. EPA concurred with these findings on May 24, 2006, and will not require the respondents to develop a vapor intrusion monitoring program as part of the remedial action.

To support these decisions, EPA submitted a memorandum to the file on December 6, 2006. This memorandum documents the actions that EPA has undertaken or approved since the ROD was signed, and substantiates non-significant changes to the selected remedy, which include waiving the requirement to monitor the indoor air quality at a statistically significant number of homes (approximately 25) throughout the area four times a year (winter, spring, summer and fall) to verify that potential risks from site-related vapors remain below a total excess lifetime cancer risk of 1 x 10 -4 and a non-cancer hazard index of 1.0. This memorandum can be found in Attachment 2.

The respondents to the September 29,2004 AOC, Waste Management and Ecolab, have now signed a Consent Decree for cost recovery and remedial action, which EPA lodged with the court on May 29, 2008. The Consent Decree requires the implementation ofa long-term monitoring plan to demonstrate the effectiveness of natural attenuation.

Because the 2005 remedial design investigation concluded that all monitoring points with detectable groundwater contamination were below remedial standards, the remedy is essentially complete. The BIOSCREEN model employed by U.S. EPA in developing the ROD predicted that under appropriate conditions the contaminant levels could be below remedial standards in as little as 1.5 to 3 years, so these observations were not unanticipated. Nevertheless, long-term monitoring is required to ensure that contaminant concentrations remain below remedial standards until such time that U.S. EPA determines that the site requires no further action.

Institutional Controls - Institutional controls (lCs) are implemented at most Superfund sites to ensure the long-term protectiveness of the remedy. ICs are non-engineered instruments, such as administrative and legal controls, which help to minimize the potential exposure to contamination and protect the integrity of the remedy. ICs are required for any areas that do not allow UU/UE.

Pursuant to the anticipated need for ICs at the Evergreen Manor site, the ROD specifies the following with regard to groundwater:

EPA will use local government controls to limit the use ofcontaminated groundwater as a }vater supply until the cleanup is complete. Winnebago

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County has two ordinances that accomplish this (Winnebago County Code Article III. November 1999). Section 86-111 ofthe code requires all properties within 200 feet ofa public water supply to connect to the water supply instead ofdrilling a well. The areas where groundwater contaminants are still above drinking water standards are serviced by the North Park water supply so EPA does not expect any new wells to be permitted in these areas. In areas where municipal water is not available and where it is uncertain whether groundwater contaminants are still above drinking water levels. Section 86-114 ofthe code applies. This section ofthe code requires property owners to obtain a well permit for a new well or for well repairs. On the permit. the county can notify the applicant that the well is located in a contaminated area and can recommend that the l1'ell be sampledfor contaminants. Ifcontaminants are detected, the county can recommend that a home treatment unit be installed. The county can also recommend that new and re-drilled wells be installed below the zone ofcontamination so that only clean water comes into the wells; and can notify EPA when a new permit is issued in the area.

EPA has determined that Institutional Controls are no longer necessary at the Evergreen Manor site, however, because sampling data from the Remedial Design Report indicate contaminant concentrations throughout the plume are below levels that would preclude UU/UE.

Nevertheless, local ordinances that limit well installation and groundwater use in the affected area are already in-place (cited above in language from the ROD). In addition, through the September 29,2004 AOC, EPA required Waste Management and Ecolab to develop a Communication Plan, which requires the PRPs to keep Winnebago County representatives apprised of the status of the remedy, thereby ensuring that the county's restrictions on well drilling target affected areas. In the unlikely event that contaminant concentrations rebound, the existing local ordinances and the Communication Plan work will work together to ensure long­term protectiveness. The Communication Plan can be found in Attachment 3.

System Operation and Maintenance (O&M) - The site does not require any O&M. O&M is an important component of most Superfund response actions to ensure that the remedy performs as intended. O&M typically includes maintaining engineered containment structures (e.g., fences, slurry walls, groundwater extraction wells, and landfill covers) or contaminant remediation systems. Because the Evergreen Manor remedy does not involve the installation of any engineered systems to achieve remedial standards, a review of Operation and Maintenance is unnecessary.

V. PROGRESS SINCE LAST FIVE-YEAR REVIEW

This is the first five-year review for the site.

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VI. FIVE-YEAR REVIEW PROCESS

Administrative Components - EPA notified the State of the Five-Year Review start on May 13, 2008. The review was conducted by William J. Ryan, Remedial Project Manager (RPM) for the Site.

The Evergreen Manor Five-Year Review included the following components:

• Community Notification • Document Review • Data Review • Site Inspection • Five-Year Review Report Development and Review

Community Involvement - Activities to involve the community in the Five-Year Review process were initiated in April 2008 by the Community Involvement Coordinator (CIC) for the Evergreen Manor Site. A notice was published in the Rockford Register Star on May 5, 2008. No one in the community voiced any interest or concern regarding the Five-Year Review process subsequent to the publication of the notice. A copy of the Public Notice Ad is included as Attachment 4.

A second notice will be sent to the same local newspaper when the Five-Year Review for the Site is complete. The Five-Year Review will be available to the public at the Roscoe Branch Library, 5562 Clayton Circle, Roscoe, IL 61073, (815) 623-6266.

Document Review - This Five-Year Review included a review of the following documents:

• Enforcement documents (Administrative Order on Consent, Consent Decree, Statement of Work)

• Design documents (Remedial Design Investigation, Remedial Design Report) • Decision documents (ROD and Memorandum to the File)

Data Review - The data reviewed for this Five-Year Review are those collected for the Remedial Design investigation. These data indicate contaminant concentrations are currently below levels that would preclude UU/UE. Groundwater samples were obtained from the 24 monitoring wells IEPA installed in 1995 and three vertical aquifer profiles. VOCs were screened using analytical method SW-846 82608. A summary ofVOCs detected in monitoring well samples is presented in Attachment 5, and a summary of VOCs detected in the vertical aquifer profiles is presented in Attachment 6.

Site Inspection - The RPM inspected the Site on May 21, 2008. He was accompanied by attorneys from Office of Regional Counsel (ORC) and the Department of Justice (DOJ), and their expert witness. ORC and DOJ were investigating the site in connection with developing the Consent Decree.

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Interviews/Public Meeting - Interviews for this Five-Year Review were not conducted. Subsequent to the newspaper notice, no member of the community or any other individual voiced an interest in being interviewed or participating in a public meeting.

VII. TECHNICAL ASSESSMENT

Question A: Is the remedy functioning as intended by the decision documents?

YES - The review of documents, ARARs, risk assumptions, and the results of the site inspection indicate that the remedy is functioning as intended by the ROD.

Question 8: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still vaUd?

YES - The exposure assumptions used to develop the Human Health Risk Assessment included both current exposures and potential future exposures. There have been no changes in the toxicity factors for the contaminants of concern that were used in the revised baseline risk assessment. These assumptions are considered to be conservative and reasonable in evaluating risk and developing risk-based cleanup levels. No changes to these assumptions or the cleanup levels developed from them are warranted. There has been no change to the standardized risk assessment methodology that could affect the protectiveness of the remedy.

Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

• NO - Sampling data from the Remedial Design Report indicate contaminant concentrations are currently below levels that would preclude UU/UE.

Technical Assessment Summary

According to the data reviewed, and the site inspection. the remedy is functioning as intended by the ROD. There have been no changes in the physical conditions of the site that would affect the protectiveness of the remedy. ARARs cited in the ROD have been met. There have been no changes in the toxicity factors for the contaminants of concern that were used in the revised baseline risk assessment, and there have been no changes to the standardized risk assessment methodology that could affect the protectiveness of the remedy. There is no other information that calls into question the current protectiveness of the remedy.

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VIII. ISSUES

There are currently no issues at the Evergreen Manor site. Data from the Remedial Design Report indicate contaminant concentrations are currently below levels that would preclude UU/UE.

IX. RECOMMENDATIONS and FOLLOW-UP ACTIONS

None.

X. PROTECTIVENSS STATEMENT

The remedy is currently protective ofhuman health and the environment in the short-term. Contaminant concentrations are below levels that would preclude UUIUE, and residences originally affected by the plume have been connected to the public water supply.

Long-term protectiveness of the remedy will be ensured by the implementation of a groundwater monitoring plan and EPA's authority to execute contingency actions if contaminant concentrations rebound. Because sampling indicates that the groundwater already meets the cleanup standards for UU/UE, the ICs for groundwater required by the ROD are no longer necessary to ensure protectiveness. Nevertheless, local ordinances are already in-place that serve as contingency measures by limiting well installation and the use of groundwater in the affected area. EPA also required Waste Management and Ecolab to develop a Communication Plan, which compels them to keep Winnebago COWlty representatives apprised of the status ofthe remedy, thereby ensuring that the county's restrictions on well drilling target affected areas. In the unlikely event that contaminant concentrations rebound, the existing ICs and the Communication Plan work together to ensure long-term protectiveness.

XI. NEXT REVIEW

The next Five-Year Review for the Evergreen Manor Groundwater Contamination Superfund Site is required five years from the signature date of this review.

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Attachment 1 Site Map (Figure 2.1 from the RD Report)

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Attachment 2 Memorandum Documenting EPA Decisions

Date: December 6, 2006

Subject: Evergreen Manor Groundwater Contamination Site

From: William J. Ryan, Remedial Project Manager Remedial Response Section #6, SR-6J

Through: Richard C. Karl, Director Superfund Division, S-6J

To: Site File

This memorandum documents the actions that EPA has undertaken or approved since the Record of Decision (ROD) was signed on September 30, 2003, and substantiates two non-significant changes. The selected remedy requires: 1) Monitored Natural Attenuation (MNA) of contaminated groundwater until federal Maximum Contaminant Levels (MCLs) and Illinois primary drinking water standards for trichloroethene, tetrachloroethene, and other site-related chemicals are reached; 2) institutional controls to lifnit the use of contaminated groundwater until the cleanup is complete; 3) monitoring a statistically significant number of homes for the effects of vapor intrusion; and 4) contingency actions should site conditions deteriorate.

EPA signed an Administrative Order on Consent (AOC) with Ecolab and Waste Management of Illinois on September 29, 2004 to perform a Remedial Design (RD). The statement of work for the RD required the respondents to conduct studies that­would provide the information necessary for the design and implementation of the Remedial Action (RA). This information included the current extent of the contaminant plume and an evaluation of the potential for vapor intrusion. EPA authorized a phased approach to determining the need to perform vapor intrusion monitoring by including the following language in the statement of work:

EPA will not require Respondents to perform vapor intrusion monitoring at properties with inhabited buildings if, after an acceptable subsurface investigation is performed in accordance with this SOW and the OSWER draft guidance on subsurface vapor intrusion, it is demonstrated to EPA's satisfaction that there is an incomplete vapor intrusion pathway, as defined by the OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils. EPA reserves the right to re-evaluate the need for vapor intrusion monitoring at properties with inhabited buildings at the site if at any time EPA determines there is a complete vapor intrusion pathway.

The basis for EPA's decision to allow a phased approach to initiating a vapor intrusion 12

monitoring program lies in the uncertainty that then surrounded the remaining contaminant concentrations and the horizontal and vertical extent of the groundwater contamination within the plume. This was especially true for groundwater near the vadose zone within the residential area that could pose the greatest risk to residents through vapor intrusion. Additional uncertainties existed because EPA's feasibility study vapor intrusion investigation was a one-time sampling event at only four homes in the area, where sample size, property and construction-specific factors, and seasonal variations were not considered. Given the degree of uncertainty, EPA deemed it appropriate that the respondents be given an opportunity to demonstrate whether a complete vapor intrusion pathway was present.

The respondents submitted a Remedial Design Work Plan on May 26,2005, which EPA approved on June 7, 2005. The respondents conducted the RD investigations and a Remedial Design Report was submitted to EPA on February 13, 2006. The investigation re-sampled 24 existing monitoring wells and completed three vertical aquifer profiles through the center of the inferred plume. Sample results from the monitoring wells indicated no contamination exceeding the remedial standards set forth in the ROD. Volatile organic compounds were also detected in the vertical aquifer profile groundwater screening samples, but none of the detected concentrations exceeded the MCL. The Remedial Design Report thus concluded that a definable groundwater contamination plume no longer exists and that the vapor intrusion pathway is incomplete. EPA concurred with these findings on May 24, 2006, and will not require the respondents to develop a vapor intrusion monitoring program.

As required by the Remedial Design Work Plan, the respondents developed a Monitored Natural Attenuation Plan for the site, which has yet to be formally approved by EPA. Because all monitoring points that still have detectable groundwater contamination are below remedial standards, the remedy is essentially complete. The BIOSCREEN model employed in developing the ROD predicted that under appropriate conditions the contaminant levels could be below remedial standards in as little as 1.5 to 3 years, so these observations were not unanticipated.

EPA believes that the site must be adequately monitored for a period sufficient to ensure that the remedy remains protective, but is prepared to excuse the demonstration that subsurface conditions will support natural attenuation, and the careful tracking of progress toward completion, necessary for a standard MNA remedy. Because the ROD remains in effect, the provisions for the implementation of contingency actions will protect human health and the environment should monitoring indicate that conditions are deteriorating.

Summary

• On September 30, 2003 EPA signed a ROD for MNA with concurrent vapor intrusion studies

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• On September 29, 2004 EPA signed an Aoe for RD, which approved a phased approach to developing a vapor intrusion monitoring plan

• On May 24, 2006 EPA concurred with the findings of the Remedial Design Report that remedial standards have been attained, a definable groundwater plume no longer exists, and that the vapor intrusion pathway is incomplete

• Because the vapor intrusion pathway is incomplete, EPA will not require the respondents to develop a vapor intrusion monitoring program

• Because all monitoring points with detectable groundwater contamination are currently below remedial standards, EPA will excuse the demonstration and tracking that MNA normally entails, and simply require monitoring to ensure that the remedy remains protective

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Attachment 3 Communications Plan

COMMUNICATIONS PLAN EVERGREEN MANOR SITE

ROSCOE TOWNSHIP, WINNEBAGO COUNTY, ILLINOIS NOVEMBER 2004

INTRODUCTION

The Evergreen Manor Site (Site) is located in Roscoe Township, Winnebago County, Illinois. Volatile Organic Compounds (VOCs) were identified in groundwater from a private well in 1990. A series of investigations were undertaken at the Site following the initial discovery of VOCs (or constituents of concern) in groundwater by the Illinois Environmental Protection Agency (lEPA) and the U.S. Environmental Protection Agency (U.S. EPA). In 1999 to 2000 U.S. EPA set-up the connection of homes in the Site to the municipal water supply to prevent the use of groundwater for potable purposes. In September 2003 the U.S. EPA issued a Record of Decision (ROD) to address remaining groundwater issues at the Site. Two responsive PRPs (the Respondents) agreed to an Administrative Order on Consent (AOC) for Remedial Design in September 2004.

In accordance with the requirements ofthe AOC, this Communications Plan's objective is to establish a procedure for the flow of information between the Respondents and Winnebago County (County) and to establish the pertinent points of contact by and between the Respondents and the County.

RESPONDENTS

The Respondents have agreed to undertake the design of the remedial action selected for the Evergreen Manor Site as set by the ROD.

RESPONSIBILITIES

The Respondents will evaluate the nature and extent ofVOCs in groundwater at the Evergreen Manor Site as part of the Remedial Design process and will communicate relevant results to Winnebago County. All communication will be sent to the County's designated representative using the contact information provided in Appendix A. The County's designated representative will distribute the information to the appropriate internal County departments, including the Winnebago County Health Department (WCHD) and the Winnebago County Regional Planning and Economic Development Department (WCRPEDD).

INITIAL COMMUNICATION

The Respondents shall provide Winnebago County with maps showing the Evergreen

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Manor Site and copies of the following documents specified in the AOC Statement of Work at Section II (2)(A). As part of the Communication Strategy, the respondents have provided WCHD and WCRPEDD with:

• A copy of the ROD [Record ofDecision]

• Maps showing the maximum concentrations and extent ofVOCs detected at the site from 1990 to 2002 (e.g., Figures 1-2, 4-4, 4-7, 5-10 and 5-11 from the Groundwater Data Evaluation report); in 2000 and 2002 (e.g., Figures 4-4, 4-5, 4­6 and 4-7 in the Groundwater Data Evaluation Report); and the boundaries of the study area. The Respondents will send updated, EPA-approved maps to the County as additional groundwater data is collected and analyzed.

• B0;lerplate language that the Winnebago County Health Department can use to noury nL . well applicants and applicants for wells repairs located within the study area (a copy of a draft letter reviewed and approved by WCHD is provided in Appendix B).

• A request that the Winnebago County Health Department notify the Respondents (with a copy to U.S. EPA) when the County issues a permit for a new well or well repairs in the study area, along with other relevant information about the well (e.g., location of well, well depth, well boring log and other well construction information, owner's name, and other contact information).

• A request that the Winnebago County Health Department notify the Respondents (with a copy to U.S. EPA) of any amendments or proposed amendments to Winnebago County Code Article III, Water Supply and Service, November 1999. To that end, the first three items noted above were provided to the County by Federal Express Courier on November 10, 2004. The latter two items, namely requests for notification by the County, are made herein by submission of this report.

PERIODIC COMMUNICATION

Respondents shall provide Winnebago County with updated maps showing the Evergreen Manor Site boundaries as those maps are developed and submitted to the U.S. EPA. In order to administer this undertaking, the County's identified point of contact (see Appendix A) will appear as a cc on updated map submissions to the U.S. EPA.

AS-NEEDED COMMUNICATION (ALERTS)

Respondents shall contact Winnebago County in the event that one of the following occurs:

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• An abandoned or un-permitted water well is discovered by the Respondents in apparent violation of County ordinances (i.e., requiring County enforcement)

• A contingency action is implemented (per the AOC) due to changes in the known horizontal or vertical extent of groundwater or soil gas impacts, or changes in chemical concentrations in groundwater or soil gas, or changes in the boundaries of the study area (i.e., Site boundaries).

WINNEBAGO COUNTY

By this report, the Respondents request that the Winnebago County Health Department notify the Respondents (with a copy to u.S. EPA) when the County issues a permit for a new well or well repairs in the study area, along with other relevant information about the well (c.g., location of well, well depth, well boring log and other well construction information, owner's name, and other contact information).

Respondents further request that the Winnebago County Health Department notify the Respondents (with a copy to u.S. EPA) of any amendments or proposed amendments to Winnebago County Code Article III, Water Supply and Service, November 1999.

All communication should be sent to the Respondents' designated representative using the contact information provided in Appendix A. In addition, contact information for u.S. EPA's copies is provided in Appendix A.

RESPONSIBILITIES

Winnebago County is responsible for the enforcement of the following Winnebago County Code, Article III ordinances:

• Section 86-111: Requires all properties within 200 feet of a public water supply to connect to the water supply instead of drilling a well.

• Section 86-114: Requires property owners to obtain a well permit for a new well or well repairs, and allows Winnebago County to condemn water supplies that exceed health standards.

• Sections 86-108 and 86-109: May allow the Winnebago County Health Department to condemn water supplies that are contaminated.

The Winnebago County Department of Planning and Economic Development administers the Subdivision Ordinance (which regulates land division and assigns addresses to properties within the unincorporated areas of the county) and prepares zoning recommendations for the Zoning Board of Appeals and County Board to carry out the County land use plan.

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The Winnebago County Health Department provides services including environmental health and pollution control designed to protect, promote and maintain the health of Winnebago County residents. The WCHD inspects wells and issues well permits.

INITIAL COMMUNICATION

Respondents request that electronic maps, CAD drawings and GIS data be provided so that the Respondents may create maps and layouts that are accurate and readily transferable to the County in electronic form. This information shall include property boundaries and associated PINs.

The Respondents have already received information from the County and this task is near completion at the date of issue of this report.

PERIODIC COMMUNICATION

Respondents request that Winnebago County provide updated electronic property maps with PINs annually. The map updates will be used to identifY new development in the area of the Evergreen Manor Site.

AS-NEEDED COMMUNICATION (ALERTS)

Respondents request that Winnebago County contact the Respondents in the event that one of the following occurs:

• An abandoned or unpermitted water well is discovered by County personnel within the historic Site boundaries as modified by the U.S. EPA-approved Remedial Design drawings

• An application for a well permit (new well or well repair) is received for any location within the historic Site boundaries as modified by the U.S. EPA-approved Remedial Design drawings

• A zoning hearing or development plan is submitted for review within the historic Site boundaries as modified by the U.S. EPA-approved Remedial Design drawings (where such plan may include the installation of water wells

• Any other situation where the use of groundwater for residential water supply may be identified or anticipated.

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Attachment 4 Public Notice Advertisement

EPA Starts its Review of the Evergreen Manor Groundwater Contamination

Superfund Site Roscoe Township, Illinois

The U.S. Environmental Protection Agency, with assistance from the Illinois Environmental Protection Agency, will start a Five-Year Review of the Evergreen Manor Groundwater Contamination Superfund site. The site comprises an area of groundwater contaminated by volatile organic compounds in unincorporated Roscoe Township in Winnebago County, Illinois. When it was discovered in 1990, the contaminated groundwater emanated from an industrial area near the intersection of Route 251 and Rockton Road, and extended southeast under residential areas to its discharge point at the Rock River. This review will examine the site's history and provide the public with a comprehensive summary of the remedial actions taken by the U.S. EPA to address threats to human health and the environment.

This is the ftrst Five-Year Review of the Evergreen Manor Groundwater Contamination Superfund site, and is required to ensure the selected cleanup plan continues to protect human health and the environment. This review has a January 28, 2009 completion date.

Site information can be found in the information repository located at:

The Roscoe Branch Library 5562 Clayton Circle Roscoe, IL 61073

(815) 623-6266

Public comment is encouraged. The public can direct any site-related questions, comments, or requests for additional information to either EPA team member listed below:

William Ryan Janet Pope Remedial Project Manager Community Involvement Coordinator

EPA Region 5 (SR-6J) EPA Region 5 77 W. Jackson Blvd. 77 W. Jackson Blvd. Chicago, IL 60604 Chicago, IL 60604

(312) 353-4374 (312) 353-0628 ryan. williamj@epa.gov pope.janet@epa.gov

Toll free (800) 621-8431,10 a.m. to 5:30 p.m. weekdays

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I

/

Attachment 5 Monitoring Well Data (Figure 5.2 from the RD Report)

MW-103S 311/1994 21111995 2/lf1995 12/111900

u L

5,7 3.0 17.0 434

MW·03 4116!ZOO2 5/26,12005

I f:-,7"'-;-"TC=A---+-'2~.lL+--'1.,!l!/l".•:-cJs--i,2·DCE PeE TCE TolueM

1.1 0.1 J 7.2J 0.5

0.62 JK.l.65 J 029 JJO.25 J

4,614.8 NO(1)IND{1)

I LEGENO·

1300ft

2.4f2 1,ij

5/5 1.1J 1.5JU O.45J 1.7/1.7 2,3

41'f4.4 2.8 1,1,1-'i('"A ... TCe 0.5 l--:L-,_'.J;.:==--:c,--,-J,- 0::.":.::0':.;.5_-1---"::0:.(1:.)_ Toluene 0.5

NO(O.5) ~ r\;Trifl;otrlctllorcethane (Fmo" .1:~) L..\, d;;;;;;;::::;:;;;;:;;;;:;::~~:~~ ~~~TION

iI~~~~~~SAMPLE UNIT (MICROGRAMS PER liTER)SAMPLE RESULT SAMPLE ANALYTE

O.31J/O.31J SAMPLE RESULTIDUPLlCATE SAMPLE RESULT NO NOT DETECTED

NO(O.S) NOT DETECTED ABOVE THE REPORTING LIMIT STATED IN. PARENTHESeS

J ESTIMATED VALUE NO DATA IN HISTORIC DATABASE

EXISTING MONITORING WELL VOCs VOLATILE ORGANIC COMPOUNDS AND IDENTIFIER NORL NONE OF THE OETeCTED CONCENTRATIONS EXCEEDED

THE LABORATORY REPORTING LIMITS figure 5.2 MEASUREMENT LOCATION SURFACE WATER ELEVATION

SUMMARY OF DETECTED VOCs IN MONITORING WELL GROUNDWATER SAMPLES NOTE:

EVERGREEN MANOR SITE THIS FIGURE ONLY INCLUDES THOSE ANALYTES WHICH ARE LISTED IN TABLE 1 OF THE 'SOW' (ATTACHMENT II OF THE AOe) AND WHICH HAD DETECTED Roscoe, Illinois CONCENTRATIONS GREATER THAN THE lASORA.TORY REPORTING LIMITS.

34891.QO(OO8)GN-COOO4 APR 2312007

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Attachment 6 Vertical Aquifer Profile Data (Figure 5.3 from the RD Report)

r

I ../

o 500 1000R

!wow I

6I1121lO5 61.12IlO5 61fl2OCJ5 53-57 73-77 ...'" 1IfN.",i).iS.D 12 2.. 0 •

O.96J 12 11 1.'

GI3I2OO5~ --. \43-47 73-77

O.73J o,f14J 2.7 0,57J

LEGEND:

EXISTING MONITORING WELL LOCATION AND IDENTIFIER NOTE:

THIS AGURE ONLY INCLUDES THOSE ANAlYrES WHICH ARE LISTED IN TABlE 1 sa·1lZ1 VERTICAl PROFILE GROUNDWATER OF THE ·SOW" (ATIACHMENT II OF THE AOC) AND WHICH HAD DETECTED

SCREENING lOCAnON CONCENTRATIONS GREATER THAN THE lABORATORY REPORTING UMITS.

SAMPLE DEPTH (FEET BELOW GROUND SURFACE)

h~~~~~~f SAMPLE UNIT (MICROGRAMS PER LITER)SAMPLE RESULT figure 5.3 ANAlYTE

SUMMARY OF DETECTED VOCs IN VERTICAL1.911.9 SAMPLE RESULTIDUPLICATE SAMPLE RESULT

ND(1) NOT DETECTED ABOVE THE REPORTING PROFILE GROUNDWATER SCREENING SAMPLES LIMIT STATED IN PARENTHESES EVERGREEN MANOR SITE ESTIMATED VALUE Roscoe Township, Illinois

34891-oo(OOS)GN·COOO5 APR 2312007

=...r:::=:::;:::;;;;:;;::;= ~::~~~ ~~~TION

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