948116 PROPOSED PLAN

NORTH SHORE AVENUE STATION FORMER MGP SUPERFUND ALTERNATIVE SITE , COOK COUNTY, ILLINOIS

EPA Region 5 July 2019

I. INTRODUCTION

The U.S. Environmental Protection Agency (EPA) seeks public review and comment on the proposed no action remedy presented in this Proposed Plan for the North Shore Avenue Station Former Manufactured Gas Plant (MGP) site (Site) and provides the rationale for this preference. The Site is located adjacent to 6659 North Kedzie Avenue in Chicago, Cook County, Illinois. This proposed no action remedy applies to the surface water and sediments in a 500-foot stretch of the North Shore Channel.

EPA is issuing this Proposed Plan as part of its public participation responsibilities under Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and Section 300.430(f)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This Proposed Plan summarizes the results of the sediment and surface water investigations conducted for the North Shore Channel. These documents and other Site documents which support the proposed no action remedy are contained in the Administrative Record located in the Site repository at the Chicago Public Library, Northtown Branch at 6435 North California Avenue, Chicago, Illinois and the EPA Region 5 Office (contact information provided in Section VII).

The EPA will accept public comments from July 20, 2019 through August 19, 2019. Comments may be submitted by mail, email, or by phone. EPA, the lead agency for Superfund activities at the Site, in consultation with the Illinois Environmental Protection Agency (Illinois EPA), the support agency, may modify the no action remedy presented in this Proposed Plan based on new information or public comments. Therefore, the public is encouraged to review and comment on the proposed action for the North Shore Channel. EPA, in consultation with Illinois EPA, will select a final remedy for the North Shore Channel documented in a Record of Decision (ROD) after careful review and consideration of new information raised and comments provided during the thirty-day public comment period.

II. SCOPE AND ROLE

In 2017, EPA determined that no further CERCLA investigation or response was warranted for the upland parcels (Main, Pond, East, South and MWRD [Metropolitan Water Reclamation District]) of the MGP site. Illinois EPA remediated soil contamination at the Main, Pond, East and South parcels between 2001 and 2002, and determined that there was no release from the MGP to the MWRD parcel. EPA, in consultation with Illinois EPA, has determined that no CERCLA remedial action is warranted for the North Shore Channel based on the sediment

1 analytical results from the Remedial Investigation (RI). Contaminants identified in sediment are associated with urban runoff, and not MGP-related (i.e., not a CERCLA release).

III. SITE BACKGROUND

The North Shore Avenue Station MGP site is located adjacent to 6659 North Kedzie Avenue in Chicago, Cook County, Illinois. The geographical coordinates of the Site are 42.00197 North latitude and -87.710679 West longitude. In 2017, EPA reviewed prior work done and investigations completed at the North Shore Avenue State MGP site and determined that the upland parcels (Main, Pond, East, South and MWRD) of the Site could be referred to Illinois EPA, as no further cleanup or investigation was needed by EPA at the Site. EPA removed the upland parcels of the Site from the Superfund program, reducing the area of the North Shore Avenue Station MGP Site to the North Shore Channel only, which includes surface water and sediments. The remaining portion of the Site (see Figure 1) consists of an approximate 500-foot stretch of the north-to-south flowing North Shore Channel adjacent to the street address noted above.

Figure 1 – North Shore Avenue Station Former MGP Site Location

The North Shore Avenue MGP Site is located within and along the border with the Village of Lincolnwood. However, since the Channel is associated with the former adjacent upland parcels, the Site is considered to be within the limits of the City of Chicago. The site is also within the Chicago Area Waterway System (CAWS). The 1.4-acre channel Site is approximately 90 feet wide and is bordered to the east and west by steep, wooded channel banks. The North Shore Avenue Station MGP Site is not listed on the Superfund National Priorities List (NPL) but is being addressed using the Superfund Alternative Approach.

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Cook County includes approximately 1,635 square miles, of which 945 square miles are land and 690 square miles are water. The population of Cook County is approximately 5,194,675 people (2010 Census). Land use is mainly urban and densely populated.

The parcels directly adjacent to and east and west of the Site are zoned by the Village of Lincolnwood as public open space. More specifically, Park No. 538 Kedzie Avenue is the boundary between the Village of Lincolnwood and City of Chicago. The area surrounding the Site is primarily residential. West Ridge Elementary School, Jewish Child & Family Services facilities, Congregation Beth Itzchok, and various commercial facilities are all located approximately 0.25 miles from the Site.

Chicago Area Waterway System Background

CAWS is an entirely engineered waterway, with water depth and flow controlled by a series of locks. Land use within the CAWS basin is generally urban with extensive industrial development. The basin includes the City of Chicago and 31 suburban municipalities. Flow in the CAWS is dominated by treated wastewater from five large water reclamation plants serving 5 million residents and an additional industrial load of approximately 4.5 million population equivalents. According to the Metropolitan Water Reclamation District (MWRD), approximately 70% of inflow to CAWS is from the water reclamation plants.

CAWS was developed with a combined sewer system that accepts both storm water and sanitary waste. After rainstorms, the capacity of the sewer system can become overwhelmed and combined sewer overflows can occur. Specifically, 15 combined sewer outfalls are present upstream of the Site that discharge to the North Shore Channel. According to MWRD, from the period dating from April 1, 2016 to April 1, 2018 there were 291 combined sewer outfall overflow events at combined sewer outfalls located upstream from the Site.

IV. SITE HISTORY

As noted above, the North Shore Avenue Station MGP Site currently includes only the North Shore Channel. The North Shore Channel is a drainage canal built between 1907 and 1910 to flush sewage through the North Branch of the to the Chicago Sanitary and Ship Canal. Historical fire insurance maps, historical topographic maps, and historical aerial photographs indicate that no MGP-related operations occurred on the North Shore Channel or directly adjacent to the Channel. Additionally, there are no indicators of conveyance to the North Shore Channel from the former MGP operations located on the former upland parcels.

Former MGP Facility Site History – Upland Parcels

The former MGP facility, located on the former upland parcels associated with the North Shore Avenue MGP Site, was initially developed in 1926 by The Peoples Gas Light and Coke Company (PGL) as a storage facility for manufactured gas. The five former upland parcels are referred to as Main, Pond, East, South and MWRD. Historical records indicate that a 15,000,000 cubic-foot gas holder was constructed and formerly located adjacent to North Kedzie Avenue (see Figure 2). The northern portion of this gas holder was located on the former Main Parcel and the southern portion was located on the former Pond Parcel. Additional features of the former MGP facilities included 13 tar tanks near the gas holder, two 12,000-gallon tar underground 3

storage tanks (UST), an oil UST, a transformer house, a compressor building, a boiler room, an exhauster house, and several storage rooms. Manufactured gas was only stored at this location; therefore, residuals, such as tar-like material typically associated with MGPs were not produced. However, historic documentation indicates that a tar/oil seal was used on the facility’s gas holder which could have resulted in residual impacts on the Main Parcel.

PGL conducted the remediation of MGP impacted soil on the former upland Main Parcel and Pond Parcel from June to October 2001 under the Illinois EPA voluntary site remediation program. The remedial action included site preparation, waste characterization, air monitoring, excavation, confirmation soil sampling, water management, demobilization, and site restoration. Approximately 26,000 tons of soil were removed from the former upland Main and Pond Parcels and disposed of at a permitted facility. Approximately 1, 137 tons of material in the vicinity of the former gas holder was disposed of as hazardous waste and disposed of at a Resource Conservation and Recovery Act Subtitle C permitted facility. The remaining soil was disposed of as special waste at a permitted facility. Excavation included removal of the tar tanks and valve/weir boxes surrounding the concrete gas holder foundation. Illinois EPA issued a comprehensive No Further Remediation (NFR) Letter for the Main Parcel in 2002 and for the Pond Parcel in 2003. Both NFR Letters restrict the land use to industrial/commercial and require compliance with a City of Chicago groundwater use restriction. This restriction ensures that groundwater is not used as a potable water source.

Figure 2 – Former Manufactured Gas Plant Structures

PGL conducted the remediation of MGP impacted soil on the East Parcel in 2001 and 2002 under the Illinois EPA voluntary site remediation program. The remedial action included

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excavation and disposal of approximately 3,600 tons of soil and disposal at a permitted facility. Illinois EPA issued a comprehensive NFR Letter for the East Parcel that allowed future residential land use or industrial/commercial land use.

PGL removed urban fill from the former South Parcel in 2001, as soil investigation activities yielded no evidence of MGP residuals. PGL excavated and disposed 19,576 tons of non- hazardous soil at a permitted facility under the Illinois EPA voluntary site remediation program Illinois EPA issued a comprehensive NFR Letter in 2001 for the South Parcel that allowed future residential land use or industrial/commercial land use.

The former MWRD Parcel has not been investigated. A review of historical fire insurance maps, historical topographic maps, and historical aerial photographs indicate that no MGP-related operations occurred on the MWRD Parcel. Additionally, there are no indicators of conveyance from the Main Parcel, where manufactured gas was stored, through the MWRD Parcel to the Channel Parcel. V. SITE CHARACTERISTICS

River Characteristics

The North Shore Channel is generally straight, except for four major bends. Each bank has about a 10- to 15-foot wide submerged shelf, which transitions into a steep earthern side slope. The Wilmette Controlling Works regulates the amount of flow allowed down the North Shore Channel to Lake Michigan. Specific water velocity in the vicinity of the Site is not available, but the velocity at the Wilmette Controlling Works ranged from an average of 21.8 cubic feet per second (CFS) to 51.4 CFS.

The North Shore Channel in the area of the Site typically consists of up to 4 feet of black sandy sediment material below the surface water that is generally loose, saturated, and has grain sizes ranging from coarse to fine.

Underlying the sediment material is a native silty clay unit. The native silty clay unit consists of brown to gray silty clay with trace fine to coarse sand and fine gravel. This unit was encountered in all soil probes advanced across the Site to the depth of probe termination. This unit resembles the Carmi Member of the Equality Formation, as well as the hydrogeologic setting designated by the Illinois State Geological Survey (ISGS). The Carmi Member of the Equality Formation commonly has thin laminations and is locally varved.

Investigation Results

Historical Release Evaluation

Based on a review of available historic records, the North Shore Channel was not used as part of the former MGP operations and there was no conveyance from the MGP to the North Shore Channel. The former MGP facility located on the upland parcels was a storage, regulation, and distribution facility only, and did not produce or manufacture gas.

As discussed previously, the former upland MGP parcels were remediated to remove MGP source material associated with gas storage and/or to address urban fill. Pre-remediation 5

groundwater data was compared to the CAWS surface water screening criteria1 to evaluate the potential for upland groundwater to reach the surface water interface (GSI) at the Site. This groundwater to surface water interface is called GSI. Using multiple conservative assumptions, the modeled groundwater concentrations at the North Shore Channel GSI do not exceed the CAWS criteria.

Sediment Sampling Investigation

A sediment investigation was performed in the North Shore Channel in December 2006 and January 2007, and included sediment borings within the North Shore Channel, as well as immediately upstream and downstream. A total of 23 sediment borings (see Figure 3) were advanced to depths of 6 to 10 feet below top of sediment (btos). Borings were terminated at the native silty clay unit. Of the 23 sediment borings advanced, five sediment samples were collected and submitted to a laboratory for chemical analysis. Samples were chosen for analysis based on observations in the field; including observation of sheen, petroleum odors; or field equipment readings during the investigation.

Figure 3 – Sediment Boring Observations

1 The CAWS screening criteria were found or calculated from Illinois Administrative Code (IAC) Title 35, Subtitle C, Chapter I, Part 302 Water Quality Standards. The CAWS Screening Criteria are protective of recreational users and aquatic life and wildlife (IAC Title 35, Subtitle C, Chapter I, Section 302.402 and 302.407). 6

Two of the 23 boring locations encountered sediments with an observation of sheen and one location exhibited petroleum odors. These observations appear as isolated occurrences along the length of the Site and one of the observations was present near the combined sewer system outfall (see Figure 3).

The sediment samples sent to a laboratory for chemical analysis were analyzed for the following MGP constituents of potential concern (COPCs): semi-volatile organic compounds (SVOCs) and petroleum volatile organic compounds (PVOCs). The purpose of the chemical analysis was to determine if impacts found in the North Shore Channel were related to the former upland MGP facility or associated with impacts found in urban waterways throughout the CAWS. The concentrations were compared to several screening criteria, including ecological screening levels and background screening levels, to make this determination, and the results are summarized below. Sediment samples were not compared to human health screening levels as the depth of the water in the North Shore Channel in the area of the Site is deep (minimum of 7 feet and maximum of 12 feet) and people are not exposed to the sediment (further discussed in Section III).

Sediment Samples - Chemical Analysis Evaluation

Total PAHs in sediment were compared to published ecological screening levels, both the threshold effect concentration (TEC) and the probable effect concentration (PEC). The North Shore Channel provides a variety of ecological habitat for aquatic birds, mammals, fish, and benthic invertebrates. Benthic invertebrates that live in the surficial sediment of the North Shore Channel (0 to 6 inches btos) were considered to be the ecological receptors with the most potential exposure to the MGP COPCs detected in the sediments. For this reason, the screening level ecological risk assessment focused on this ecological receptor group.

The TEC is the level below which adverse effects on benthic dwelling organisms are not expected to occur and the PEC is the level above which adverse effects on benthic dwelling organism are expected to occur more often than not. The total PAH (TPAH-13) results are the sum of 13 individual PAH compounds: acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene, fluoranthene, fluorene, naphthalene, phenanthrene, and pyrene. The total PAH results in all five sediment samples exceed the PEC and the TEC screening levels. Investigation results are presented in the Remedial Investigation Report contained in the Administrative Record.

The individual compounds of benzene, toluene, ethylbenzene, and xylene (BTEX) were compared to their respective Equilibrium Partitioning Sediment Quality Guidelines (EQP-SQP). The TEC-PEC screening levels do not allow for comparison of the individual BTEX compounds, therefore the EQP-SQP guidelines are utilized as screening levels. The EQP-SQP guidelines are similar to the TEC-PEC screening levels in that they measure potential for adverse effects on benthic dwelling organisms. The toluene concentration in one sample and the xylene concentration in three samples exceed their respective EQP-SQP. No other BTEX concentrations exceed the EQP-SQP. Investigation results are presented in the Remedial Investigation Report contained in the Administrative Record.

In order to determine whether the above screening level exceedances found at the Site were related to background (ambient) conditions or were related to the historic MGP operations, the 7

Site data were also compared to results from sediment samples that were collected in ambient areas throughout the CAWS. Ambient areas are portions of the river system that are unaffected by former MGPs and are representative of urban background. The TPAH-13 concentrations in many of these ambient areas also exceeded the ecological screening levels, regardless of proximity to former MGPs. The TPAH-13 concentrations at the Site were compared to the calculated upper tolerance limits (UTLs) developed for the ambient sediment data set from two other MGP sediment sites located in the CAWS (Bubbly Creek and the North Branch of the Chicago River). The ambient UTLs represent an upper concentration limit of TPAH-13 below which a sediment sample is considered to be consistent with ambient concentrations.

The TPAH-13 concentrations at the Site did not exceed the ambient UTLs for the North Branch of the Chicago River Site in any of the samples collected and analyzed for the Site. The TPAH- 13 concentrations were compared to the Bubbly Creek ambient UTLs (which have a range of values, unlike the North Branch of the Chicago River Site). The TPAH-13 concentrations at the Site do not exceed the most applicable ambient UTL for the Bubbly Creek Site. Investigation results are presented in the Remedial Investigation Report contained in the Administrative Record.

The chemical analysis evaluation indicated that the TPAH-13 concentrations do exceed published ecological screening levels. However, these constituents are typically present in urban waterways, like CAWS, and their presence can be associated with former MGPs or a result of historical urban sources (e.g., stormwater runoff, surface runoff, direct atmospheric deposition, and small but persistent discharges). Based on the comparison to samples collected in ambient areas of the CAWS, the elevated levels observed at the Site are below concentrations observed in ambient CAWS areas unaffected by MGPs. However, additional evaluations to verify whether the detected chemicals were from ambient background sources were also conducted, as noted in the next section.

Sediment Samples - Forensic Data Evaluation

Additional forensic evaluation of the data was conducted to determine if the Site data was related to typical urban background conditions or was related to the MGP Site. Urban PAHs originate from many potential sources, both petrogenic and pyrogenic. Pyrogenic PAH source examples include coal tar, creosote, roadway pavement, high temperature combustion of motor oils, and power plant fuels. Examples of petrogenic substances include crude oil and refined crude oil products, such as gasoline, heating oil, waste oils, and diesel soot. A variety of methods were used to distinguish between petrogenic and pyrogenic sources of PAHs by evaluating the pattern of PAHs.

An initial preliminary forensic evaluation concluded that the sediment samples collected from the Site contained mixed hydrocarbon sources that included both pyrogenic and petrogenic substances. The identified petrogenic source material included various weathered petroleum products, including light, middle, and heavy distillates, as well as heavier material, such as some residual oils and asphalt. The identified pyrogenic material included tar-like substances with a range of concentrations of total PAHs and PAHs present in a pyrogenic pattern. This potential tar material required more evaluation, as noted in the following paragraph.

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A second forensic evaluation was conducted to expand on the findings from the preliminary forensic evaluation. In the second forensic evaluation, the PAH profiles of the field samples were compared to a limited number of standards that have been collected from MGP source materials (unrelated to the Site). This second, expanded forensic evaluation suggested that the PAH profile in the North Shore Channel was consistent with the PAH profile of urban waterways. To further evaluate the similarity of Site sediments to urban waterways, the evaluation was expanded to include a comparison of the ambient sediments collected from the CAWS (Bubbly Creek and the North Branch of the Chicago River). This expanded evaluation indicated that all five Site samples have similar concentrations of PAHs and compositions of petrogenic and pyrogenic PAH sources consistent with the concentrations and compositions of the ambient samples. There is no physical or chemical evidence to indicate that Site sediment samples are impacted by fresh or weathered MGP material originating from the former North Shore Avenue MGP, and the tar- like substance that was initially identified in the preliminary forensic evaluation was determined to be non-MGP-related.

The composition and concentrations of PAHs present in the sediment samples collected at the Site are consistent with ambient sediments collected from the North Branch of the Chicago River and Bubbly Creek. Based on the visual and olfactory observations from the site investigation and forensic chemical analyses of PAH in five sediment samples, there is no physical or chemical evidence to indicate that Site sediment samples are impacted by fresh or weathered MGP material originating from the former North Shore Avenue MGP.

VI. SUMMARY OF SITE RISKS

The Baseline Risk Assessment (BLRA) in the 2019 remedial investigation (RI) Report consisted of a streamlined human health risk assessment (HHRA) and a screening level ecological risk assessment (SLERA). A streamlined BLRA was completed, since no impacts related to the MGP Site were documented in the surface water and sediment within the North Shore Channel.

Human Health Risk Assessment

The streamlined HHRA evaluated potential risks to recreational users of the Channel, as those users have the greatest exposure to the sediment and surface water. The North Shore Channel is currently used primarily as a recreational water body for boating, including motor boating, kayaking, canoeing, and sculling.

The exposure assessment evaluated the completeness of the sediment exposure pathway including: the accessibility of the water body to people; the depth of water (to determine whether peoples may way in the water body); accessibility of soft sediment; use of the water body; and the presence of tars in sediment or sheen on the water. The water depth in the North Shore Channel ranges from 7 feet to 12 feet, which prevents people from being exposed to the sediment. The exposure pathway is therefore considered incomplete, as people are not exposed to the sediment. While there have been chemicals detected in the North Shore Channel, without exposure to the chemicals in the sediment, people would not be at risk to the chemicals detected in the sediments. The contaminants identified in sediment are associated with urban runoff, and not MGP-related (i.e., not a CERCLA release).

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Recreational anglers may use the North Shore Channel to fish, however, the sediment COPCs do not bioaccumulate in fish. Therefore, exposure to PAHs and PVOCs is not expected if anglers consume fish from the North Shore Channel. Further, based on a review of the data collected, there is no indication that the concentrations of PAHs and PVOCs detected in the sediments are related to the former MGP operations and are associated with urban background.

No surface water samples were collected as multiple lines of evidence, including the sediment sample results, indicated that the site was impacted by MGP residuals.

Screening Level Ecological Risk Assessment.

The North Shore Channel provides a variety of ecological habitat for aquatic birds, mammals, fish, and benthic invertebrates. Benthic invertebrates that live in the surficial sediment of the North Shore Channel (0 to 6 inches below top of sediment) were considered to be the ecological receptors with the most potential exposure to the MGP COPCs (i.e., PAHs and PVOCs) detected in the sediments. For this reason, the screening level ecological risk assessment focused on this ecological receptor group.

Based on the screening assessment performed using the limited available sediment data for the North Shore Channel in the area of the Site, MGP COPC concentrations were above ecological effects-based concentration limits. This indicates the concentrations of the MGP COPCs could potentially cause toxicity to sensitive ecological receptors, such as benthic invertebrates. However, in comparison to ambient concentrations of the PAHs developed for areas of the CAWS that are unaffected by past MGP operations, the sediment conditions at the Site and downstream of the Site, are comparable to ambient conditions. As noted previously, there is no indication that the concentrations of MGP COPCs detected in the sediments are related to the former MGP operations, and they are more likely associated with urban background. Therefore, whereas the sediments in the area of the Site pose a potential risk to benthic invertebrates, the level of risk present in the North Shore Channel at the Site does not depart from ambient conditions that are known to occur in the CAWS. The former MGP is not contributing incremental risk to the North Shore Channel above what is present in ambient conditions.

VII. SUMMARY OF THE PROPOSED ACTION

EPA proposes No Further Action for the North Shore Avenue Station Former MGP Site based on the findings of the RI, which indicate that MGP contaminated sediments are not present within the North Shore Channel.

The former MGP facility located on the upland parcels was a storage, regulation, and distribution facility only, and did not produce manufactured gas. There are no documented historical conveyances from the former MGP facility to the North Shore Channel. During the site investigation, no MGP impacts (i.e., tar) were observed in the soil borings advanced across the Site. Concentrations of contaminants of concern are lower than concentrations observed throughout CAWS. A forensic evaluation was conducted on the sediment samples collected near the Site which concluded that the samples were consistent with samples collected throughout CAWS and specifically with ambient (background) samples collected from two additional MGP Sites in CAWS. The forensic evaluation further concluded that there was no physical or chemical

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evidence to indicate that Site sediment samples are impacted by fresh or weathered MGP material originating from the former North Shore Avenue MGP. Therefore, EPA proposes that no further action be required at the North Shore Avenue Station Former MGP Site. EPA in consultation with the State may modify the proposed no action remedy presented in this Proposed Plan based on new information or comments received during the public comment period.

VIII. COMMUNITY PARTICIPATION

EPA and Illinois EPA provided information to the public regarding the cleanup of the North Shore Avenue Station Former MGP Site through the Administrative Record file, the Site information repository maintained at the Chicago Public Library, Northtown Branch at 6435 North California Avenue, Chicago, Illinois, announcements published in the newspaper, and community interviews (conducted as part of the site community involvement plan). Based on the current level of community interest, EPA is willing to host an availability session to discuss this proposed action if members of the public request one. EPA and the State encourage the public to gain a more comprehensive understanding of the Site and the Superfund activities that have been conducted. The dates for the public comment period and the locations of the Administrative Record files are provided on the front page of this Proposed Plan.

The Administrative Record file and other relevant reports and documents are also available for public review at the EPA Region 5 office at the following location:

EPA Region 5 Records Center 77 West Jackson Boulevard – 7th Floor Chicago, IL 60604

Hours: Monday to Friday: 8:00 am – 4:00 pm

For Further Information on the North Shore Ave, Station Former MGP Site, please contact:

Sarah Rolfes Heriberto Leon Remedial Project Manager Community Involvement Coordinator 312-886-6551 312-886-6163 [email protected] [email protected]

U.S. EPA – Region 5 77 W. Jackson Blvd Chicago, IL 60604

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