ANALYSIS OF BROWNFIELDS ALTERNATIVES

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1 ANALYSIS OF BROWNFIELDS CLEANUP ALTERNATIVES BLUE ISLAND NORTHEAST MIXED-USE COMMERCIAL PARK MARSHFIELD AVENUE PCBS CLEANUP (FORMER BLUE ISLAND LANDFILL) BLUE ISLAND, COOK COUNTY, ILLINOIS USEPA COOPERATIVE AGREEMENT #BF PREPARED FOR: CITY OF BLUE ISLAND SOUTH GREENWOOD AVENUE BLUE ISLAND, ILLINOIS PREPARED BY: V3 COMPANIES 120 NORTH LASALLE STREET, SUITE 1550 CHICAGO, ILLINOIS AUGUST 2010

2 TABLE OF CONTENTS 1.0 INTRODUCTION BACKGROUND Site Description History of the NE Park Parcels Proposed Redevelopment of Eastern Parcel SUMMARY OF SITE CHARACTERIZATION Recent and Historical Subsurface Investigations Background Prior Investigations at the NE Park Site Geology and Hydrogeology Site Geology Site Hydrogeology CLEANUP ALTERNATIVES ANALYSIS Cleanup Goals Soil Cleanup Alternatives Analysis No Action Source Removal ping In-Situ Soil Remediation Methods Proposed Remedial Action Remediation Costs Cleanup Schedule...9 FIGURES Figure 1 Figure 2 Figure 3 Site Location Map Soil Boring/Monitoring Well Location Map PCBs Soil Remediation Site TABLES Table 1 Table 2 Site Wide Soil Analytical Results (PCBs) Boring BI-GP-29 Delineation Soil Analytical Results (PCBs) Analysis of Brownfield Cleanup Alternatives Blue Island Northeast Mixed-Use Commercial Park USEPA Cooperative Agreement #BP August 2010 i

3 1.0 INTRODUCTION This Analysis of Brownfield Cleanup Alternatives (ABCA) was prepared by V3 Companies (V3) on behalf of the City of Blue Island (the City), Illinois, under the South Suburban Mayors and Managers Association (SSMMA) Brownfield Revolving Loan Fund (RLF), formally known as USEPA Cooperative Agreement #BF This ABCA report was prepared to identify and evaluate cleanup alternatives to mitigate potential risks to human health and the environment from identified environmental impacts at a particular area of the Blue Island Northeast Mixed-Use Commercial Park (NE Park), which was historically known as the former Blue Island, and which is located at the southeast corner of the intersection of Vincennes Avenue and 119 th Street in Blue Island, Illinois (refer to Figure 1 Site Location Map, attached). The specific area to be cleaned up (the PCB Soil Remediation Area, or Site ), is located on the east side of the East Parcel of the former landfill (refer to Figure 2 - Soil Boring/Monitoring Well Location Map, attached). The cleanup described in this ABCA will be funded in part by a grant/low interest loan from the SSMMA Brownfield RLF, which is capitalized by a grant from the USEPA. The purpose of the cleanup is to position the property for redevelopment as commercial property. The initial step in the remediation process is to prepare a list of cleanup alternatives, and evaluate these alternatives based on a number of factors, including cost. Cleanup alternatives and estimates are provided in this report, and are based on previous site assessment data and assumptions noted herein. 2.1 Site Description 2.0 BACKGROUND The PCB soil contamination Site lies completely within the smallest parcel of the NE Park, which consists of about 2.9 acres. This is the easternmost portion of the East Parcel of NE Park, and it lies along Marshfield Avenue. The approximate address of this parcel and the Site is S. Marshfield Avenue (Figure 2). The easternmost parcel that contains the Site is vacant and has no structures or current use. The Site lies within the larger property known as the NE Park, which is an 87-acre former landfill that was closed in The NE Park was accepted as a donation by the City in The NE Park became a redevelopment priority of the City when it adopted the Blue Island Plan for Economic Development in The Plan recognized the strong development potential of the NE Park based on its transportation and market assets. In 2006, the City entered the path to redevelopment of the NE Park by enrolling the entire property in the Illinois EPA s voluntary Site Remediation Program (SRP). The SRP provides a clearly structured process through which an owner may move a property through the steps of site assessment and cleanup in a manner that is protective of human health and the environment. 2.2 History of the NE Park Parcels The NE Park was used from at least 1897 to 1952 for clay brick making, and clay-earth was excavated from the site in places to a depth of 46 feet or more. In 1952, the NE Park was sold Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

4 to John Sexton Contractors which operated a landfill/burn pit at the site from 1952 to This open dump accepted household rubbish, including materials that contained hazardous wastes. The landfill ceased waste disposal operations in The property was historically an unpermitted landfill because its use and eventual cessation of operations pre-dated the Illinois solid waste regulations. The NE Park area remained vacant and unused between 1966 and The former owners reported that they topped the entire landfill area with at least 6 feet of clay cover material during this time. In 1995, after performing the equivalent of All Appropriate Inquiry, the City of Blue Island accepted the entire NE Park property as a donation from Eileen Sexton. For periods between 1995 and the present, the City has leased portions of the West Parcels of the NE Park to companies that performed low intensity functions on the land: Between 1997 and the present, the City has leased several acres in the southern portion of the West Parcels to Baja Construction, which built the batch concrete plant now vacant on the property, and to Prairie Concrete which purchased Baja s operations. From 2000 to the present, the City has leased land to Vulcan Materials, allowing Vulcan to extend a concrete and asphalt recycling operation from their privately owned property on 119 th Street and adjacent to the northern boundary of the West Parcels. Vulcan built no structures on the land and has not used it regularly since From 2004 to the present, the City has leased several acres in the northern portion of the West Parcels to Kloos Piping, which uses the land for the outdoor storage of sewer pipes and water mains. Between 2004 and 2007, the City leased land to Fredrick s Brothers, a landscaping company, allowing Fredrick's Brothers to extend their operations on privately owned property on 119 th Street and adjacent to the northern boundary of the West Parcels, by storing plant materials and pulverizing soil on City-owned land. In 2007 Christy Weber Landscaping purchased Fredrick s Brothers and continued its lease with the City. In 2000, the soccer fields were constructed in the southwestern portion of the NE Park, using fill provided by the Metropolitan Water Reclamation District (MWRD) in the form of bio-solids (sludge). MWRD provided a document affirming that the material was clean and posed no risk to human health or safety. The City has never leased any part of the East Parcel of the NE Park (including the Site), nor conducted any use there. 2.3 Proposed Redevelopment of Eastern Parcel The Eastern Parcel of the NE Park (Figure 2) is likely to be developed for a combination of commercial and industrial uses. With an interior space of approximately 25 acres and the logistical advantages of the NE Park, most of the Eastern Parcel properties will probably become part of the City s planned industrial development. However, since the property containing the PCB Remediation Site (Figure 2) is approximately one-half mile from an expressway ramp and a major shopping center, it is considered a likely target for commercial use. Furthermore, this property will necessarily be the gateway to the entire Eastern Parcel development. Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

5 3.0 SUMMARY OF SITE CHARACTERIZATION 3.1 Recent and Historical Subsurface Investigations Background Through a competitive Request for Qualifications/Proposals process, the City selected V3, a qualified environmental engineering and consulting firm, to perform a broad scope of environmental services leading to the full characterization and initial correction of environmental impacts at the NE Park, under the direction of the SRP and, as appropriate, the USEPA. Since 2006, the City, through the services of its consultant V3, has conducted a Phase I Environmental Site Assessment (ESA), performed four Phase II ESAs, and overseen a geotechnical investigation across the entire NE Park. The issue currently being addressed is the presence of PCB soil contamination (the PCB hot spot ) at the Site-specific area that is the subject of this ABCA (refer to Figure 3 PCBs Soil Remediation Site, attached). The PCB hot spot was discovered during one of V3 s Phase II ESAs. Per a standing agreement between the Illinois EPA and USEPA Region V, oversight for the cleanup of PCB contamination is provided by the USEPA rather than IEPA. Accordingly, the City has approached the USEPA on the matter of this PCB contamination. Through its contractor V3, the City submitted a Quality Assurance Project Plan (QAPP) to the USEPA Region V office for conducting characterizing the PCB contamination at the Site. The QAPP was approved by the USEPA on July 31, The QAPP includes V3 s Standard Operating Procedures (SOPs), such as field procedures, field equipment and laboratory testing methods. With this approval, the City authorized V3 to prepare and implement a PCB Delineation Work Plan (PDWP), with input and technical review provided by USEPA Region 5. The PDWP is based on protocols described in 40 CFR (determination of the number of samples to collect and sample locations) and 40 CFR (sample size and procedures to collect a sample) for the delineation of PCBs-impacted soils. The PDWP was approved by USEPA on August 3, 2009, and is discussed in more detail below in Section The purpose of the PCB delineation work is to characterize the degree and extent of the PCB soil contamination prior to remediation. This and other subsurface data provide the basis for developing the ABCA and the USEPA-required PCB Cleanup Notification Plan (Cleanup Plan), for implementing the preferred cleanup alternative. This ABCA and the Cleanup Plan are being submitted to USEPA Region V for review and approval. If Region V does not provide adverse comment to this plan after 30 days, it will become a self-implementing plan, and V3 will carry out the remediation on the City s behalf. Additionally, V3 will develop and implement a site-specific Health and Safety Plan (HASP), to guide field personnel during the remediation work. All remediation workers will be required to follow the procedures in the plan. Special attention will be paid to monitoring landfill gases during the remediation activities Prior Investigations at the NE Park V3 Investigation Reports Phase I Environmental Assessment Blue Island Industrial Park, V3 Companies, October 13, 2006 Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

6 Preliminary Investigation Report Blue Island Industrial Park, V3 Companies, September 28, 2007 Summary Report 2006 Subsurface Investigations Blue Island Industrial Park (Former Blue Island ), V3 Companies, August 24, 2007 HGA Analysis October 2008 Blue Island Industrial Park (Former Blue Island ), V3 Companies, November 25, 2008 Other Notable Reports Boring Logs Letter, Schleede-Hampton Associates, Inc., March 22, Blue Island/Rock Island Future Use Geotechnical Report, Eldredge Engineering, May 31, Report of Soils Exploration, Division Street Reconstruction, Blue Island, Illinois, Testing Service Corporation, May 2, Summary V3 Phase I ESA V3 conducted a Phase I Environmental Site Assessment (ESA) of the 87-acre NE Park in October The following Recognized Environmental Conditions (RECs) pertaining to the NE Park were identified: 1. Historic Crude Oil ASTs and USTs 2. Historic Fuel Oil Tank 3. Former Railroad Tracks 4. Nature and Characteristics of -Related Wastes 5. Nature and Characteristics of Leachate, Groundwater, and Methane Gas 6. Potential that has been compromised (via soil erosion, potential wetlands, open water areas, and installation of underground utilities) 7. Nature and Characteristics of Surface Fill Materials 8. Potential Environmental Impacts from Off-Site Operations Summary V3 Prior Phase II ESAs In addition to the Phase I ESA, V3 conducted three rounds of Phase II ESAs and oversaw a geotechnical investigation on behalf of the City, all during the period of August 2006 to March A total of 108 soil borings have been advanced at the Site as part of these environmental and geotechnical investigations (Figure 2). Analytical results indicated that concentrations of several types of chemical compounds exceeded the IEPA Remediation Objectives (ROs) in different areas of the NE Park. PCBs concentrations exceeded IEPA industrial/commercial and residential ROs of 1 milligram per kilogram at several locations across the NE Park [refer to Table 1 - Site Wide Soil Analytical Results (PCBs), attached]. At the remediation Site (Figure 3), PCBs concentrations exceed the Toxic Substances Control Act (TSCA) hazardous level of 50 ppm, in one sample collected from soil boring BI-GP-29 (4-6 ). The PCBs concentration in this sample, which was collected from landfill materials, was 169 milligrams per kilogram [refer to Table 2 Boring BI-GP-29 Delineation Soil Analytical Results (PCBs), attached]. This hot spot of a hazardous substance represents a threat to human health that must be remediated according to USEPA PCBs regulations. Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

7 Characterization of the PCB Soil Remediation Site On August 13, 2009, V3 performed a PCBs delineation investigation to determine the vertical and horizontal extent of contamination at soil boring BI-GP-29 (Figure 2), as outlined in the PDWP. The focus of the PCBs delineation investigation was to: Determine the vertical and horizontal extent of TSCA level PCBs encountered in soil boring BI-GP-29 (Figure 3); Collect sufficient data to aid V3 in developing a remediation plan for the PCBs impact at this location; Receive approval from the USEPA to conduct a self-implementing cleanup of TSCAlevel PCBs contaminated soil. Analytical results indicate that PCBs were detected in some samples at concentrations exceeding IEPA industrial/commercial ROs, but did not exceed TSCA hazardous levels (Table 2). Details of the PCB delineation work and results are presented in the Cleanup Plan, which is available for public review at the City s document repositories for this project. 3.2 Site Geology and Hydrogeology Site Geology The bedrock geology below the Site is the Silurian Racine Formation. The Racine Formation is described as a dolomite, pure, gray, thin-bedded to massive; local reef structures; local areas of brownish gray, argillaceous dolomite. The Racine Formation is typically encountered in the area at approximately feet deep and is about 230 feet thick. The rock units underlying the Racine Formation are typical of Northeastern Illinois Silurian sequence and include: Joliet Formation, Kankakee Formation and Edgewood formation to a depth of approximately 400 feet. Silurian rocks are underlain by the Maquoketa Shale Group and other Ordovician rocks to about 900 feet deep. Soil borings advanced during recent and historical site investigations offer a fairly good understanding of subsurface conditions in the upper-most 60 feet of the Site. Three basic units are present at the NE Park. Fill (varied, silt and clay matrices typical) Materials (clay, wood, plastic, metal, paper) Gray silty clay with sand and gravel The surface fill across the Site generally consists of concrete and asphalt debris, metal scrap, glass, bricks, gravel and clayey/silty matrices. The fill averages approximately 2 to 9 feet thick. In the landfill area, this fill material comprises the landfill cap. Beneath the cap, the landfill materials consists of loose, wet clay with glass, wood, metal and paper to approximately 42 feet deep. Occasional pockets of landfill gases were encountered at various depths across the NE Park. Beneath the landfill materials, a dark gray silty clay with sand and gravel (native soil) was encountered to the explored depths of 42 to nearly 60 feet deep (depending on the portion of the landfill one is speaking of). The clay is very hard and is often described as hard pan. Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

8 3.2.2 Site Hydrogeology The shallow Silurian dolomite groundwater aquifer can be encountered in some areas of the Site at approximately feet deep, within native soils (not the landfill materials). This aquifer is a limited source of water supply for private and non-community services within the area. Above that depth are thinner, less continuous seams of sand and gravel that produce a limited amount of perched groundwater. It is apparent that shallow groundwater zones (those within first 10 feet of the subsurface) are not suitable for water supply development and are not representative of a local groundwater system at this depth. Based on topography and physical setting, Site groundwater flow within near surface sediments is assumed to follow regional topography and generally flow to the south. Groundwater monitoring wells installed adjacent to the landfill encountered a shallow zone of perched water that is present within discontinuous, localized coarse-grained soils (e.g. 1-inch thick seams), at approximately 30 feet deep. Distinct, continuous saturated soil layers were not observed during drilling and sampling activities. In the deepest on-site boring (nearly 60 feet deep), groundwater was not encountered. The saturated zone directly beneath the Site is classified as a Class II: General Resource Groundwater, in accordance with Title 35: Environmental Protection, Subtitle F: Public Water Supplies, Chapter I: Pollution Control Board Part 620b: Groundwater Classification (non-potable water. In addition, the City maintains a groundwater ordinance prohibiting the installation of water wells and the use of groundwater resources for public consumption. 4.0 CLEANUP ALTERNATIVES ANALYSIS As previously mentioned, the area of concern for PCB contamination (the Site) lies completely within the smallest parcel of the NE Park, which consists of 2.9 acres. This is the easternmost of the NE Park East Parcels and it lies along Marshfield Avenue. The approximate address of this parcel and the Site is S. Marshfield Avenue (Figure 2). The maximum dimensions of the PCB Remediation Site are 20 feet by 20 feet in area and up to 16 feet deep, based on data obtained during the PCBs delineation work (Figure 3). However, the actual size and shape of the remediation area, and the resulting volume of contaminated soil generated, depend on conditions encountered in the field during the soil remediation activities. 4.1 Cleanup Goals The area impacted with PCBs will be remediated until soil characterization samples indicate that PCBs are < 1 part per million (ppm) in remaining soils. Upon reaching <1 ppm PCBs in soil, V3 will collect final verification soil samples. 4.2 Soil Cleanup Alternatives Analysis The alternatives that V3 considered for mitigating the risks associated with the PCBcontaminated soil are discussed below No Action A no-action alternative must be considered as part of the ABCA process. Because of the desire to redevelop the property and the Federal requirement that PCB levels of this magnitude in soil Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

9 must be removed from the Site, the no-action alternative was eliminated from further consideration Source Removal Source removal includes the excavation, loading, transportation and disposal of PCBcontaminated soils. This method is proven and provides 100 percent certainty in its effectiveness. Based on these factors alone, the source removal method is deemed appropriate to mitigate PCB-contaminated soils at the Site, and is discussed further in Section 4.3 below ping ping of contaminated soil is often a viable remedial alternative that addresses direct contact and ingestion risks posed by contaminated soil. ping can be used on its own or in concert with source removal methods. ping materials can vary depending on site considerations, and can include asphaltic paving; layers of geotextile materials; clean fill materials with a clean soil and vegetated layer; or concrete slab building foundations. The placement of a cap over contaminated soil minimizes the surface exposure to the soil; prevents the vertical migration of water through contaminated soil, which minimizes the generation of contaminated leachate that migrates to ground water; and creates a land surface that supports other uses. ping is often an integral component in Brownfield remedial actions. However, PCBs-contaminated soils at the Site are shallow and would be disturbed during site grading and construction activities, which would require the developer to remediate contaminated soils before proceeding with site development work or capping. Additionally, Federal regulations require that soil containing the levels of PCBs detected at the Site can not be left in place, and therefore must be removed from the Site. Therefore, the remedial capping method was eliminated from further consideration In-Situ Soil Remediation Methods In-situ soil remediation methods (e.g., soil vapor extraction, chemical oxidation, bioremediation. electrical resistivity heating, just to name a few) are not suitable to mitigate PCB-contaminated soils because in-situ remediation methods are generally ineffective at treating or destroying PCBs in soil, due to the chemical and physical properties of PCBs. Moreover, while there may be other in-situ treatment methods that research studies have shown to be promising, the cost and uncertainty of these methods far outweigh the potential for obtaining successful results that meet the regulatory cleanup criteria for the Site. Therefore, insitu soil remediation methods were eliminated from further consideration. 4.3 Proposed Remedial Action On the basis of effectiveness and technical feasibility, V3 recommends source removal as the most appropriate method to remediate PCB-contaminated soils at the Site. Although the area of concern has been identified, V3 will perform self-implementation by adhering to the site characterization protocol outlined in CFR (determination of the number of samples to collect and sample collection locations), (sample size and procedure for collecting a sample), and (compositing samples). After the PCBs Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

10 impacted soils are removed, soil verification samples will be collected. Soils impacted with hazardous levels of PCBs (according to the Toxic Substances Control Act [TSCA]), will be excavated and segregated from those soils with non-tsca level PCBs. Under V3 s direction, the remediation contractor will excavate, transport and appropriately dispose of PCB-impacted soils as depicted in the area shown in Figure 3. Soil impacted with TSCA level PCBs will be disposed as a TSCA waste (hazardous waste) at a disposal facility approved to accept TSCA level PCB wastes while soils with non-tsca level PCBs will be disposed as non-tcsa waste (special waste) at a disposal facility approved to accept special non-hazardous remediation wastes. All PCB waste (> 50 ppm and < 50 ppm) disposal will be conducted in accordance with Part (a)(5). Groundwater/leachate was not encountered until approximately 20 feet bgs in previous soil borings, and is not expected to be encountered during remediation activities. However, if encountered, groundwater/leachate will be pumped out of the excavation using a pump truck. Based on analytical results, the leachate will then be transported by a licensed special waste hauler for disposal at licensed special waste facility. The area impacted with PCBs will be remediated until soil characterization samples indicate that PCBs are < 1 ppm in soil. Upon reaching <1 ppm PCBs in soil, V3 will collect final verification soil samples. Soil samples will be analyzed using U.S. EPA Method The verification sampling will be conducted in accordance with Subpart O Sampling to Verify Completion of Self-Implementation Cleanup and On-Site Disposal of Bulk PCB Remediation Waste and Porous Surfaces in Accordance with (a) (6). 4.4 Remediation Costs The estimated programmatic and remediation costs are summarized in the following table. Scope of Services Estimated Costs Programmatic Activities Project Management, City and Regulatory Agency Meetings & Communications $35,600 USEPA Reporting (ABCA; 30-Day Notification; Closure Report) $39,900 Illinois EPA Reporting (HPESA; Amended Investigation Report & Closure Report) $ 4,600 Total Programmatic Activities Estimated Cost $80,100 Remediation Activities PCBs Delineation Remedial Investigation $11,800 Community Involvement $ 3,400 Contractor Bidding/Selection/Contract Execution /Mobilization Activities $ 8,300 Field Oversight/Verification Sampling/Backfill Activities $37,200 Contracted Services (Soil Excavation/Disposal/Laboratory Analysis) $28,400 Total Remediation Activities Estimated Cost $89,100 Total Estimated Cost $169,200 Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

11 4.5 Cleanup Schedule Pending USEPA and public approval, V3 and the City owner tentatively plan on conducting the PCBs remediation in the beginning September During the USEPA 30-day review process, V3 will request bids from several remediation contractors. Once selected, contract negotiations will commence and a contract will be finalized in order to meet the cleanup schedule. The USEPA Region V will be contacted once a remediation contractor has been selected and will also be provided with a schedule after the 30-day notification period. It is anticipated remediation will begin within one to two weeks following the 30-day notification period. Analysis of Brownfield Cleanup Alternatives USEPA Cooperative Agreement #BF Blue Island Northeast Mixed-Use Commercial Park August 10,

12 FIIGURES

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16 TABLES

17 TABLE 1 - SITE WIDE SOIL ANALYTICAL RESULTS (PCBs) BLUE ISLAND NORTHEAST MIXED-USE COMMERCIAL PARK BLUE ISLAND, ILLINOIS Industrial-Commercial Exposure Route-Specific Values for Soils East Parcel Phase II ESA V3 8/3/2006 8/3/2006 8/3/2006 8/3/2006 8/9/2006 8/9/2006 8/9/2006 3/3/2008 3/3/2008 3/3/2008 3/3/2008 3/4/2008 3/4/2008 3/4/2008 3/4/2008 3/4/2008 Industrial- Commercial Construction Worker BI-SB-05 (1-3) BI-SB-05 ( ) BI-SB-06 (1-3) BI-SB-06 (49-51) BI-SB-08 (1-3) BI-SB-08 (49-50) BI-SB-09 (1-3) BI-GP-29 (4-6) BI-GP-29 (12-14) BI-GP-30 (10-12) BI-GP-30 (34-36) BI-GP-31 (2-4) BI-GP-31 (10-12) BI-GP-31 (28-30) BI-GP-32 (16-18) BI-GP-33 (8-10) Chemical Name Ingestion Inhalation 1-3 ft ft 1-3 ft ft 1-3 ft ft 1-3 ft 4-6 ft ft ft ft 2-4 ft ft ft ft 8-10 ft mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg PCBs (8082) PCBs 1 h -- c,h 1 h -- c,h * Aroclor 1016 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < < < < < < < < < < < < < < < Aroclor 1221 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < < < < < < < < < < < < < < < Aroclor 1232 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < < < < < < < < < < < < < < < Aroclor 1242 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * <0.019 <0.019 < <0.018 <0.018 <0.019 < < < < < < < < < Aroclor 1248 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < <0.019 <0.019 <0.018 <0.018 <0.019 < < < < < < < < < Aroclor 1254 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * <0.019 <0.018 <0.018 < <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 Aroclor 1260 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * <0.019 <0.019 <0.019 <0.019 <0.018 <0.018 <0.019 <0.160 < <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 Part 742 Notes * indicates that the ADL is less than or equal to the specified remediation objective. V3 Table Notes: 0.11 Indicates exceedance of Tier 1 residential and/or commercial/industrial objectives 0.11 Indicates detection limit exceeds Tier 1 commercial/industrial objectives indicates chemical not analyzed or not sampled See attached for notations Ingestion Inhalation ADL N:\2006\06039\Calculations & Data\Environmental\Tables\PCBs\PCBs_Delineation.xls Site Wide -PCBs Page 1 of 6 9/3/2009

18 TABLE 1 - SITE WIDE SOIL ANALYTICAL RESULTS (PCBs) BLUE ISLAND NORTHEAST MIXED-USE COMMERCIAL PARK BLUE ISLAND, ILLINOIS Industrial-Commercial Exposure Route-Specific Values for Soils East Parcel Phase II ESA V3 3/4/2008 3/4/2008 3/4/2008 3/6/2008 3/6/2008 3/6/2008 3/6/2008 3/6/2008 3/7/2008 3/7/2008 3/7/2008 3/10/2008 4/1/2008 4/1/2008 Industrial- Commercial Construction Worker BI-GP-34 (14-16) BI-GP-34 (18-20) BI-GP-35 (22-24) BI-GP-36 (18-20) BI-GP-36 (26-28) BI-GP-38 (8-10) BI-GP-38 (22-24) BI-GP-39 (20-22) BI-GP-40 (4-6) BI-GP-40 (18-20) BI-GP-41 (20-22) BI-GP-42 (22-24) BI-B-20 (38-40) BI-B-29 (32-34) below Chemical Name Ingestion Inhalation PCBs (8082) PCBs 1 h -- c,h 1 h -- c,h * Aroclor 1016 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1221 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1232 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1242 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1248 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1254 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1260 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Part 742 Notes * indicates that the ADL is less than or equal to the specified remediation objective. V3 Table Notes: 0.11 Indicates exceedance of Tier 1 residential and/or commercial/industrial objectives 0.11 Indicates detection limit exceeds Tier 1 commercial/industrial objectives indicates chemical not analyzed or not sampled See attached for notations Ingestion Inhalation ADL ft ft ft ft ft 8-10 ft ft ft 4-6 ft ft ft ft ft ft mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < <0.019 <0.019 < < < < < < < < < < < < <0.019 < <0.160 <0.160 <0.160 <0.160 < <0.160 <0.160 <0.160 <0.160 <0.160 <0.019 <0.019 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.019 <0.019 N:\2006\06039\Calculations & Data\Environmental\Tables\PCBs\PCBs_Delineation.xls Site Wide -PCBs Page 2 of 6 9/3/2009

19 TABLE 1 - SITE WIDE SOIL ANALYTICAL RESULTS (PCBs) BLUE ISLAND NORTHEAST MIXED-USE COMMERCIAL PARK BLUE ISLAND, ILLINOIS Industrial-Commercial V3 West Parcel Phase II ESA OSE Exposure Route-Specific Values for Soils 11/13/2006 8/2/2006 8/2/2006 8/3/2006 8/3/2006 8/3/2006 8/3/2006 8/9/2006 8/9/ /13/ /13/ /14/ /14/ /14/ /14/ /15/ /15/ /15/2006 Industrial- Commercial Construction Worker BI-SB-01 (1-3) BI-SB-01 (60-61) BI-SB-02 (3-5) BI-SB-02A (55-56) BI-SB-03 (3-4) BI-SB-03 (24-26) BI-SB-04 (1-3) BI-SB-07 (5-7) BI-SB-07 (55-56) BI-1A (.5-3.0) BI-1B (25) BI-2A (3) BI-2B (23) BI-3A (1) BI-3B ( ) BI-4A (1.5-3) BI-4B (24) BI-5 (5.5) Chemical Name Ingestion Inhalation PCBs (8082) PCBs 1 h -- c,h 1 h -- c,h * Aroclor 1016 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1221 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1232 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1242 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1248 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1254 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1260 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Part 742 Notes * indicates that the ADL is less than or equal to the specified remediation objective. V3 Table Notes: 0.11 Indicates exceedance of Tier 1 residential and/or commercial/industrial objectives 0.11 Indicates detection limit exceeds Tier 1 commercial/industrial objectives indicates chemical not analyzed or not sampled See attached for notations Ingestion Inhalation ADL 1-3 ft ft 3-5 ft ft 3-4 ft ft 1-3 ft 5-7 ft ft ft 25 ft 3 ft 23 ft 1 ft ft ft 24 ft 5.5 ft mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg <0.98 <0.92 <0.93 <0.94 <1 <1 <0.92 <0.96 <1 < < < < < < < < < < < < < < < < < < < < < < < < < < < <0.019 <0.019 <0.019 <0.019 <0.019 <0.019 <0.019 <0.018 < <0.019 <0.019 < <0.019 <0.019 <0.019 <0.018 < < < <0.019 <0.019 <0.018 < <0.019 <0.019 <0.019 <0.019 <0.019 <0.019 <0.018 < N:\2006\06039\Calculations & Data\Environmental\Tables\PCBs\PCBs_Delineation.xls Site Wide -PCBs Page 3 of 6 9/3/2009

20 TABLE 1 - SITE WIDE SOIL ANALYTICAL RESULTS (PCBs) BLUE ISLAND NORTHEAST MIXED-USE COMMERCIAL PARK BLUE ISLAND, ILLINOIS Industrial-Commercial OSE West Parcel Phase II ESA V3 Exposure Route-Specific Values for Soils 11/15/ /15/ /15/ /15/ /16/ /16/ /16/ /16/ /16/ /16/ /16/ /16/2006 2/25/2008 2/25/2008 2/26/2008 2/26/2008 Industrial- Commercial Construction Worker BI-6 (5.5) BI-7A (1) BI-8A ( ) BI-8B (12-14) BI-9 (5) BI-10 ( 5) BI-11 (4) BI-12 (4) BI-13 (6) BI-14 (6) BI-15 (6) BI-15 (Duplicate) BI-GP-16 (0-2) BI-GP-17 (10-12) BI-GP-18 (37-39) BI-GP-19 (34-36) Chemical Name Ingestion Inhalation Ingestion Inhalation ADL PCBs (8082) PCBs 1 h -- c,h 1 h -- c,h * Aroclor 1016 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1221 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1232 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1242 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1248 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1254 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1260 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Part 742 Notes * indicates that the ADL is less than or equal to the specified remediation objective. 5.5 ft 1 ft ft ft 5 ft 5 ft 4 ft 4 ft 6 ft 6 ft 6 ft 6 ft 0-2 ft ft ft ft mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg <0.9 <0.98 <1.1 <0.9 <0.92 <0.91 <0.98 <0.94 <0.91 <0.92 <0.95 < < < < < < < < < < < < < < < < < < < < <0.160 <0.160 <0.160 < <0.160 <0.160 < V3 Table Notes: 0.11 Indicates exceedance of Tier 1 residential and/or commercial/industrial objectives 0.11 Indicates detection limit exceeds Tier 1 commercial/industrial objectives indicates chemical not analyzed or not sampled See attached for notations N:\2006\06039\Calculations & Data\Environmental\Tables\PCBs\PCBs_Delineation.xls Site Wide -PCBs Page 4 of 6 9/3/2009

21 TABLE 1 - SITE WIDE SOIL ANALYTICAL RESULTS (PCBs) BLUE ISLAND NORTHEAST MIXED-USE COMMERCIAL PARK BLUE ISLAND, ILLINOIS Industrial-Commercial Exposure Route-Specific Values for Soils West Parcel Phase II ESA V3 2/26/2008 2/26/2008 2/27/2008 2/27/2008 2/27/2008 2/27/2008 2/27/2008 2/28/2008 2/28/2008 2/28/2008 2/28/2008 2/28/2008 2/28/2008 2/29/2008 3/3/2008 3/3/2008 Industrial- Commercial Construction Worker BI-GP-19 (44-46) BI-GP-19 (64-66) BI-GP-20 (44-46) BI-GP-20 (62-64) BI-GP-21 (46-48) BI-GP-21 (54-56) BI-GP-22 (10-12) BI-GP-23 (48-50) BI-GP-23 (54-56) BI-GP-24 (10-12) BI-GP-24 (16-18) BI-GP-25 (10-12) BI-GP-26 (8-12) BI-GP-27 (38-40) BI-GP-28 (4-6) BI-GP-28 (40-42) Chemical Name Ingestion Inhalation PCBs (8082) PCBs 1 h -- c,h 1 h -- c,h * Aroclor 1016 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1221 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1232 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1242 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1248 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1254 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1260 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Part 742 Notes * indicates that the ADL is less than or equal to the specified remediation objective. V3 Table Notes: 0.11 Indicates exceedance of Tier 1 residential and/or commercial/industrial objectives 0.11 Indicates detection limit exceeds Tier 1 commercial/industrial objectives indicates chemical not analyzed or not sampled See attached for notations Ingestion Inhalation ADL ft ft ft ft ft ft ft ft ft ft ft ft 8-12 ft ft 4-6 ft ft mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 < < <0.160 <0.160 <0.160 <0.160 < < N:\2006\06039\Calculations & Data\Environmental\Tables\PCBs\PCBs_Delineation.xls Site Wide -PCBs Page 5 of 6 9/3/2009

22 TABLE 1 - SITE WIDE SOIL ANALYTICAL RESULTS (PCBs) BLUE ISLAND NORTHEAST MIXED-USE COMMERCIAL PARK BLUE ISLAND, ILLINOIS Industrial-Commercial Exposure Route-Specific Values for Soils West Parcel Phase II ESA V3 3/3/2008 3/11/2008 3/11/2008 3/11/2008 3/11/2008 3/12/2008 Industrial- Commercial Construction Worker BI-GP-28 (54-56) BI-GP-44 (14-16) BI-GP-47 (18-20) BI-GP-48 (14-16) BI-GP-49 (12-14) BI-GP-50 (18-20) Chemical Name Ingestion Inhalation Ingestion Inhalation ADL PCBs (8082) PCBs 1 h -- c,h 1 h -- c,h * Aroclor 1016 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1221 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1232 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1242 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1248 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1254 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Aroclor 1260 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * Part 742 Notes * indicates that the ADL is less than or equal to the specified remediation objective ft ft ft ft ft ft mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg < < < < < < < < < < < < < < < < < < < < < < < < < < < < < < <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 <0.160 V3 Table Notes: 0.11 Indicates exceedance of Tier 1 residential and/or commercial/industrial objectives 0.11 Indicates detection limit exceeds Tier 1 commercial/industrial objectives indicates chemical not analyzed or not sampled See attached for notations N:\2006\06039\Calculations & Data\Environmental\Tables\PCBs\PCBs_Delineation.xls Site Wide -PCBs Page 6 of 6 9/3/2009

23 TABLE 2 - BORING BI-GP-29 DELINEATION SOIL ANALYTICAL RESULTS (PCBs) BLUE ISLAND NORTHEAST MIXED-USE COMMERCIAL PARK BLUE ISLAND, ILLINOIS Industrial-Commercial Phase II ESA V3 East Parcel PCBs Delineation V3 Exposure Route-Specific Values for Soils 3/3/08 3/3/08 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 8/13/09 Industrial- Commercial Construction Worker BI-GP-29 (4-6) BI-GP-29 (12-14) BI-GP-29-AB34 ( ) BI-GP-29-AB34 ( ) / BI-GP-29-AB34 ( ) BI-GP-29-CD34 ( ) BI-GP-29-CD34 ( ) / BI-GP-29-CD34 ( ) BI-GP-29-CD12 ( ) BI-GP-29-CD12 ( ) BI-GP-29-CD12 ( ) BI-GP-29-AB12 ( ) BI-GP-29-AB12 ( ) / BI-GP-29-AB12 ( ) BI-GP-29-AB12 ( ) Duplicate Ingestion Inhalation Ingestion Inhalation ADL 4-6 ft ft ft ft ft ft ft ft ft ft ft ft ft ft ft Chemical Name mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg PCBs (8082) Aroclor 1016 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < < < < < 0.09 < < 0.1 < < < 0.15 < 0.09 < < 0.1 < 0.1 Aroclor 1221 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < < < < < 0.09 < < 0.1 < < < 0.15 < 0.09 < < 0.1 < 0.1 Aroclor 1232 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < < < < < 0.09 < < 0.1 < < < 0.15 < 0.09 < < 0.1 < 0.1 Aroclor 1242 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < < < < < 0.09 < < < < 0.15 < 0.09 < < 0.1 < 0.1 Aroclor 1248 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < < < < < 0.09 < < 0.1 < < < 0.15 < 0.09 < < 0.1 < 0.1 Aroclor 1254 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * < < Aroclor 1260 (Using value for PCBs) n 1 h -- c,h 1 h -- c,h * <0.160 <0.160 < < < < 0.09 < < 0.1 < < < 0.15 < 0.09 < < 0.1 < 0.1 Part 742 Notes * indicates that the ADL is less than or equal to the specified remediation objective. V3 Table Notes: 0.11 Indicates exceedance of Tier 1 residential and/or commercial/industrial objectives indicates chemical not analyzed or not sampled See attached for notations N:\2006\06039\Calculations & Data\Environmental\Tables\PCBs\PCBs_Delineation.xls Soil -PCBs Page 1 of 1 9/3/2009

24 Chemical Name and Soil Remediation Objective Notations (For INDUSTRIAL-COMMERCIAL and CONSTRUCTION WORKER Remediation Objectives) a. Soil remediation objectives based on human health criteria only. b. Calculated values correspond to a target hazard quotient of 1. c. No toxicity criteria available for this route of exposure. d. Soil saturation concentration (C[sat]) = the concentration at which the absorptive limits of the soil particles, the solubility limits of the available soil moisture, and saturation of soil pore air have been reached. Above the soil saturation concentration, the assumptions regarding vapor transport to air and/or dissolved phase transport to groundwater (for chemicals which are liquid at ambient soil temperatures) have been violated, and alternative modeling approaches are required. e. Calculated values correspond to a cancer risk level of 1 in 1,000,000. f. Deleted from 742. g. Chemical-specific properties are such that this route is not of concern at any soil contaminant concentration. h. 40 CFR 761 contains applicability requirements and methodologies for the development of PCB remediation objectives. Request for approval of a Tier 3 evaluation must address the applicablity of 40 CFR 761. i. Soil remediation objective for ph of 6.8. If soil ph is other than 6.8, refer to Appendix B, Tables C and D in this Part. j. Ingestion soil remediation objective adjusted by a factor of 0.5 to account for dermal route. k. Deleted from 742. l. Potential for soil-plant-human exposure. m. The person conducting the remediation has the option to use: (1) TCLP or SPLP test results to compare with the remediation objectives listed in this Table; (2) the total amount of contaminant in the soil sample results to compare with ph specific remediation objectives listed in Appendix B, Table C or D of this Part (see Section ); or (3) the appropriate background value listed in Appendix A, Table G. If the person conducting the remediation wishes to calculate soil remediation objectives based on background concentration, this should be done in accordance with Subpart D of this Part. n. The Agency reserves the right to evaluate the potential for remaining contaminant concentrations to pose significant threats to crops, livestock, or wildlife. o. For agrichemical facilities, remediation objectives for surficial soils which are based on field application rates may be more appropriate for currently registered pesticides. Consult the Agency for further information. p. For agrichemical facilities, soil remediation objectives based on site-specific background concentrations of Nitrate as N may be more appropriate. Such determinations shall be conducted in accordance with the procedures set forth in Subparts D and I of this Part. q. The TCLP extraction must be done using water at a ph of 7.0. r. Value based on dietary Reference Dose. s. Value for Ingestion based on Reference Dose for Mercuric chloride (CAS No ); value for Inhalation based on Reference Concentration for elemental Mercury (CAS No ). Inhalation remediation objective only applies at sites where elemental mercury is a contaminant of concern. t. For the ingestion route for arsenic for industrial/commercial, see 742, Appendix A, Table G. u. Value based on Reference Dose for thallium sulfate (CAS No ). v. Deleted from 742. w. Value based on Reference Dose adjusted for dietary intake. x. For any populated areas as defined in Section , Appendix A, Table H may be used. y. Value based on maintaining fetal blood lead below 10 ug/dl, using the USEPA adults Blood Lead Model. IC-CW-Notations 9/3/2009

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