PUBLIC HEALTH ASSESSMENT
VELSICOL CHEMICAL CORPORATION (ILLINOIS)
MARSHALL, CLARK COUNTY, ILLINOIS
CERCLIS NO. ILD000814673
The Velsicol Chemical Corporation (VCC) site is approximately 1 mile north of the City of Marshall, Clark County, Illinois. The site was used to produce a variety of resins, solvents, rubber extenders and termiticides. Hazardous wastes generated from various manufacturing activities at the site were stored in on-site impoundments. In the past, overflow from these impoundments resulted in releases of these wastes to an unnamed tributary of East Mill Creek.
The available information indicates that the site currently poses no apparent public health hazard. Human exposure to contaminated media is not occurring at levels of health concern. Although past exposure to contaminated tributary sediment suggests a low increased risk of developing cancer over a lifetime, current and future exposure to both contaminated sediment and fish completed pathways should not present any adverse health effects.
Members of the community were concerned that chemicals found at the site were acutely toxic to a passerby. However, the data indicated that acute toxicity was unlikely. Another community concern was about the safety of eating contaminated fish from the unnamed tributary. The Public Health Assessment considers that persons who consume or consumed fish from the unnamed tributary should not experience adverse health effects from the three organochlorines detected in the fish sampling. Also, there was community concern about contaminated groundwater migrating into the unnamed tributary. This situation existed prior to remedial activities, but the unnamed tributary's condition has improved and contamination has been contained on-site.
Until remediation is complete, institutional controls that prevent future use of on-site contaminated aquifers and restrict site access to the public should be continued. Because there is no indication that human exposure to site contaminants at levels of public health concern is occurring or has occurred in the past, the site is not being considered for follow-up activities at this time. However, the site will be reevaluated by the Illinois Department of Public Health and the Agency for Toxic Substances and Disease Registry if new data suggest that exposure to significant levels of hazardous substances is occurring.
In cooperation with the Illinois Department of Public Health (IDPH), the Agency for Toxic Substances and Disease Registry (ATSDR) will evaluate the public health significance of this site. More specifically, IDPH and ATSDR will determine whether health effects are possible and will recommend actions to reduce or prevent public health effects. ATSDR, located in Atlanta, Georgia, is a federal agency within the U.S. Department of Health and Human Services and is authorized by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (ATSDR) to conduct health assessments at hazardous waste sites.
The Velsicol Chemical Corporation (VCC) site is located in east-central Illinois, approximately 1 mile north of the City of Marshall, Clark County, along State Highway Route 1 (Figure 1). According to the U.S. Public Land Survey Grid, the site is located in the southwest 1/4 of Section 12, Township 11 North, Range 12 West of the 2nd Principal Meridian (Figure 2). The site is approximately 420 acres, of which 86 acres were utilized for the production facility and on-site ponds. Most of the remaining acres were leased by VCC for crop farming. A railroad right-of-way borders the southern boundary of the property, an unnamed tributary to East Mill Creek flows westerly through the southwestern corner of the property, a county road borders the western property boundary, and Interstate 70 borders part of the northern property boundary.
In 1982, the VCC was identified as a federal superfund project and subsequently placed on the National Priority List (NPL). Thereafter, the Illinois Environmental Protection Agency (IEPA) entered into a cooperative agreement with the United States Environmental Protection Agency (USEPA) to conduct a state-lead, federal Remedial Investigation and Feasibility Study (RI/FS). The results of the 1986-1987 RI showed contamination of: groundwater underneath the facility, soils in the plant area, on-site impoundment water and sediments, creek water and sediments, and off-site groundwater, subsurface soil, creek water and sediment, and fish. The contaminants included volatile and semi-volatile organic and inorganic compounds, including pesticides and heavy metals. Remedial action is currently underway at the site.
The VCC once operated a production facility that was built during the mid-1930s for the production of petroleum derivatives from petroleum by-products. Finished products included a variety of resins (styrene/vinyl toluene copolymer and methycyclopentadiene/dicyclopentadiene monomers), solvents and rubber extenders. An agricultural line that produced chlordane was added in 1946. The manufacturing operations at the facility remained virtually unchanged until 1979, when VCC discontinued resin production. Manufacturing of technical grade chlordane was the sole product of the facility from 1980 to 1987 when USEPA and VCC reached an agreement cancelling the registration of products containing chlordane and heptachlor.
In the past, hazardous wastes generated from various manufacturing activities at the site were stored in on-site impoundments. Overflow from these impoundments resulted in releases of these wastes into an unnamed tributary of East Mill Creek during the time that the ponds were in operation. The contents of Hex Ponds, some contaminated plant area soils and contaminated sediments from Ponds 2 and 4 were transferred to the 5/6 Pond, stabilized with cement and fly ash, and capped with 1 to 1.5 feet of clay. The stabilization program began in 1983 and was completed in 1984. The temporary clay cover has been in place over the 5/6 Pond since 1985.
The final RI report for the site was issued in February of 1988 and a FS report was released in July of 1988. VCC discontinued the facility's operation as of August 30, 1988. After its closure, VCC removed all chemicals from the facility and demolished the remaining structures. A Record of Decision (ROD) was signed on September 30, 1988 that recommended the following remedial actions:
- Excavate 24 inches of sediment from the unnamed tributary between the plant site and VCC's western property boundary. Additional sediments in the unnamed tributary will be excavated as determined on the basis of additional sampling until background concentrations of chlordane are reached. The unnamed tributary will be backfilled with clay and replaced with a new excavated channel. In addition, any excavation beyond the western VCC property boundary will focus on stream sections with sediment build-up (1).
- Excavate plant production site soils to predetermined depths, backfill with clean soil (clay), regrade the plant site to provide effective surface water drainage, and establish a vegetative cover over all regraded areas. Remove soil from plant area "hotspots" that will be uncovered by structure demolition. Eliminate unnecessary service roads (1).
- Excavate 6 inches of sediment from the base of Ponds 2 and 4, backfill each impoundment with clean soil, grade the area to provide surface water drainage (1).
- Place all excavated material from the plant site, the unnamed tributary, and Ponds 2 and 4 into the 5/6 Pond, treat the excavated material by stabilization, and provide a Resource Conservation and Recovery Act (RCRA) multimedia cap over the regraded 5/6 Pond (1).
- Construct a groundwater collection drain (interceptor trench) east of the 5/6 Pond and the production area. Remove and treat groundwater on-site using granulated activated carbon until clean-up objectives are met. Effluents from the treatment system will be discharged into the unnamed tributary. The potential exists at this time for the use of a mechanically sound (i.e., meeting all applicable Underground Injection Control regulations) deep injection well, which was previously used by VCC for disposal of some process water, for direct disposal of contaminated surface water through the initial remedial construction phase. The clean-up levels for the contaminated groundwater will be based on the Ambient Water Quality Criteria (AWQC) or Illinois State general use water quality standards (1). Meeting these clean-up criteria will protect aquatic life from toxic substances and ensure that recreational fishing, consumption of fish, and swimming be maintained.
- An on-site management program with crop restrictions for the agricultural fields controlled by VCC. This remedial action includes implementation of a regular program of pH (acidity) testing and application of ground limestone to maintain a pH of 6.5 or above. Land use restrictions will allow only the growth of corn, soybeans, or wheat. No vegetable crops for direct human consumption will be grown. The land may be used for forage crop production, but no direct grazing of livestock will be allowed (1).
- Evaluation of the effectiveness of the remedial actions through proposed quarterly monitoring for the Hazardous Substance List (HSL) compounds for a nominal 30-year period, and reporting on shallow and deeper groundwater at the perimeter of the site, effluent from the groundwater at the facility, and the cover systems (particularly over the 5/6 Pond unit). The groundwater treatment unit effluent will be monitored on a monthly basis for the HSL compounds for 10 years and its need will be reassessed thereafter (1).
- Access and land use restrictions (1). All the remedial action activities mentioned were essentially completed in 1992. These were the following:
- On-site and off-site creek sediment removal and stabilization on 5/6 Pond.
- Realignment and design of a new on-site creek channel.
- Test Plot Compaction work on 5/6 Pond was completed the week of August 24, 1992.
- The North Stormwater Pond was completed for remedial action activities.
- Pond #4 was completed for remedial action activities.
- Pond #2 is approximately 90% completed for remedial action activities (2).
As of September 1994, all contaminated material requiring remediation has been excavated and stabilized in the 5/6 Pond. Also, Velsicol has completed the RCRA-like cap for 5/6 Pond. The wastewater treatment facility for groundwater remediation has been constructed and in operation. It will discharge into the local sanitary wastewater facility. An Operation and Maintenance (O&M) Plan has been submitted by Velsicol and presently is being reviewed by the IEPA concerning long-term activities at the site. A final O&M document as well as deed restrictions outlined in the Consent Decree should be revised (10).
A site visit was conducted on June 6, 1991, by Cary Ware of the Illinois Department of Public Health (IDPH) Champaign regional headquarters. At the time of the visit, the site was undergoing remediation as evidenced by the number of contractor's personnel and equipment observed on-site, or what was once the plant manufacturing and operating areas (Production Facility - Figure 3). All the production facility buildings and equipment have been removed. The entire on-site perimeter was fenced and separated from the VCC agricultural field surrounding most of the northern and westerly side of the former manufacturing plant area. The entrance gate was open and an access road led to the contractor's office trailer. Another gate (closed) was erected behind the contractor's trailer. Personnel were burning construction debris at the entrance of this area. Two heavy duty vehicles were observed compacting the soil at the former production facility. These vehicles were operated by two personnel wearing white Tyvek-like protective suits. No respiratory equipment was being used. There was some dust observed during the operation. Mr. Ware detected a pesticide-like odor while driving on the access road (on-site) east of the former production facility.
The most recent site visit was conducted by Cary Ware on October 5, 1994. Although a couple mobile offices, storage shed, and a few work vehicles (pickup trucks, earth movers) remained on the site, no personnel were present. The access road around the perimeter of the 5/6 Pond had recently been seeded with grass. The walls and top of the 5/6 Pond were covered with grass. No ponding of water on the site was observed. Unlike the site visit aforementioned, no pesticide-like odor was detected on or around the site. The area that was the 2 and 4 Ponds was covered with a variety of grasses. Except for groundwater monitoring wells, 5/6 Pond, and equipment, no signs of a former production facility remain.
According to the 1990 Census Population Data for Illinois Counties and Incorporated Places, Clark County had a population of 15,841 in 1990 (3). Marshall had a population of3,555. Paris (population of 8,987) is the nearest major town, located approximately 12 miles north of Marshall on US Route 1. The city of Marshall is approximately 0.25 mile south of the Velsicol site.
The land use in the immediate vicinity of the site includes the following: agricultural, residential/commercial, and municipal. A brief description of each category follows:
- Agricultural - The site is surrounded by agricultural land. About 334 acres of land are located to the north and west of the former production facility. It was generally leased by the VCC to area crop farmers.
- Residential/Commercial - There are five residences within 0.50 miles west of the site along
Township Road. Most of the residences immediately west of the site obtain their drinking water
from Marshall's Municipal Water Supply because the glacial deposits yield insufficient water to
support domestic water needs in the immediate vicinity of the site. Although some of the
residences have a private well on their property, reports indicate that the well water is not used
for drinking. The exceptions are the two closest residences located about 1,800 feet northwest of
the 5/6 Pond who do use private wells (a well survey conducted by Aware, Inc. in September of
1979) as potable water supplies; however, these wells were sampled by the IEPA in May of 1982
and found not to be impacted by the site (4).
A fertilizer storage facility is located approximately 0.5 mile south of the site and west of Route 1. A Wal-Mart retail facility is approximately 1 mile south of the site.
- Municipal - Marshall obtains its drinking water from a well field located approximately 2.3 miles north of town.
The natural resources in the area include the Wabash River, fertile soils, and recreational waterways. Lincoln Trails State Park is approximately 5 miles south of Marshall. A tributary to Mill Creek has been damned up to form a recreational reservoir. An unnamed tributary to East Mill Creek flows westerly through the southwest corner of the site. It is not used as a drinking source but may be used for livestock watering and swimming by the local population. Fishing is also a recreational activity in the unnamed tributary and East Mill Creek. Several sand and gravel pits and quarries are within the flood plain or on bluffs overlooking Big Creek 1 mile east of the site.
The Marshall municipal wells tap a permeable sand and gravel aquifer contained in a partially buried bedrock valley associated with Big Creek. The aquifer is 200 feet wide and trends northwest - southwest and is located more than 1 mile east of the site. There are no known major consumers of groundwater from bedrock in the vicinity of the site.
The State of Illinois maintains databases for cancer incidences and birth defects. Information from the Illinois State Cancer Registry is available for the years 1985 through 1992. No health outcome data have been generated for this site due to the small population surrounding the site. Large study populations are usually necessary to provide significant health outcome statistics.
During public meetings and a hearing, local officials and the public expressed community concerns. These concerns will be addressed individually in the Community Health Concerns Evaluation Section.
- Concern about chemicals at the site that may be acutely toxic to a passerby.
- Contamination of fish in the nearby creek and the subsequent eating of the fish.
- Groundwater contamination migrating into the unnamed tributary (5).
As of October 1994, no additional community health concerns have been expressed (10).