Interstate Lead Company

Interstate Lead Company
Site ID: ALD041906173
Location: Leeds, Jefferson County, AL
Congressional District: 06
NPL Status: Proposed: 09/18/85; Final 06/10/86
Project Manager
Site Repository:
Leeds Public Library
802 Parkway Dr. SE
Leeds, AL 35094
Documents:

• Site Profile
• Administrative Record Index (All PDF): Final (2 pp., 70K), OU1 (48 pp., 1.6M), OU3 (8 pp., 389K),
  OU1/2 Amend. (6 pp., 242K)
• Additional Site Documents including Five Year Reviews, Records of Decisions (ROD) and Explanation of Significant Differences (ESD).

Site Background:
The ILCO facility, located in Leeds, Alabama, was operated as a secondary lead smelter and lead battery recycling facility from 1970 to 1992. From approximately 1970 to 1984, the company reportedly used lead-contaminated materials such as blast furnace slag, battery casings, and wastewater treatment sludge as fill material at seven satellite sites in and around the City of Leeds which are known as the: ILCO Parking Lot, Gulf/BP Service Station (currently operated as a BP Service Station), J & L Fabricators, Flemmings Patio, the Connell Property, the City of Leeds Landfill, and the Church of God of Prophecy in Acmar, herein referred to as the Acmar Church of God. The ILCO main facility is bordered by an abandoned foundry and a wooded area to the south, an unnamed tributary to Dry Creek, to the west, Borden Avenue and the ILCO Parking Lot to the north and another business to the east. The area is primarily industrial with a few residences within a half-mile radius. The Interstate Lead Company ceased operations in March 1992 and declared bankruptcy shortly thereafter

Cleanup Progress: Threat Mitigated by Physical Clean-up Work
The operator of the ILCO facility refused to conduct an RI/FS; therefore, EPA performed a fund-lead RI/FS. ILCO ceased operations in 1992, and abandoned the ILCO facility. Shortly thereafter, EPA initiated a fund-lead emergency removal action to mitigate the imminent threat associated with the abandoned ILCO main facility. EPA issued RODs for each of the 3 operable units comprising the Site. The estimated cost of implementing the selected remedies is approximately $60,000,000. As the State of Alabama did not have sufficient resources to fund the state cost share, a fund-lead cleanup was not an option. Based upon ILCO's operating records, EPA identified approximately 979 PRPs who sent spent batteries or other lead bearing waste material to the Site. EPA issued notice letters to these PRPs in the fall of 1993. Special Notice Letters were issued to large quantity generators in the fall of 1995. On September 30, 1996, the Region requested DOJ to concur in a settlement with 20 generator PRPs at the ILCO site. Under the terms of the proposed settlement, the settling defendants will conduct RD/RA for the entire Site including all seven satellite sites, and will reimburse the United States for $1,823,644 of $16,683,773 in past response costs. Also, the ILCO PRPs will reimburse the United States for future oversight costs related to the Consent Decree in excess of $300,000. Under the guidance on orphan share compensation dated June 3, 1996, the Region, with Headquarters concurrence, has agreed to compensate the Settling Defendants by giving them a credit of $14,860,125 against outstanding past costs which represents 25% of the estimated future cleanup costs. This settlement is one of the first to provide for compensation to settlors under the orphan share reform in accordance with the recently issued guidance. In addition, proceeds from deminimis settlements will be split between EPA and the Settling Defendants 50-50 with EPA's share to be applied against outstanding past costs. Based upon deminimis settlements totaling over $1.8 million, the PRPs were wired over $900,000 in May 1999.

The Remedial Design (RD) for the ILCO Superfund site was approved on March 12, 1999. In coordination with the Alabama Department of Environmental Management, EPA modified the RD document to include groundwater monitoring. The Record of Decision (ROD) calls for a pump and treat system, but the ROD does allow for groundwater monitoring to see if a technical impracticability waiver is needed. However, if groundwater monitoring continues during the Remedial Action (RA) at the site, the levels may meet the action levels specified in the ROD. The levels of lead in groundwater are vastly lower from the levels found during the Remedial Investigation (RI) since a removal action has contained the source and since the sampling protocols have changed to a slow purge technique. Lead is not currently detected above action levels in groundwater in any of the wells at the site. There are several metals still above Maximum Contaminant Levels (MCLs), but the concentrations of these contaminants are approaching the MCL. The PRP group requested a ROD amendment to change the groundwater cleanup levels in a document submitted separately from the RD, but EPA previously directed the PRPs in the comments on the Pre-Final Design to include groundwater monitoring in the final design. ADEM has participated throughout this entire process.

The Remedial Action Workplan was approved in January 2000. RMT, Inc. was contracted by the Settling Defendants to conduct the remedial action for OU 1 and Ou 2. A preconstruction meeting was held on January 19, 2000. RMT, Inc. is bringing the soils from the satellite sites to the main facility for treatment. Contaminated soil from the satellite sites and the main facility are being stabilized and rendered non-hazardous.

Due to continuous disagreements between the PRPs and their contractor, the PRPs informed EPA on June 6, 2001, that RMT, INC had been directed to demobilize from the site(s). A steering group representing the PRPs selected ENTACT of Irving, Texas as the new supervising contractor to complete the remediation required at the site(s). ENTACT did a good job getting up to speed quickly continuing to make progress with the remedation activities at the site. The remedial action report addressing the remediation of all contaminated soil at the site above action levels was approved by EPA in September 2006.

EPA is currently reviewing groundwater data submitted by the PRPs to determine if natural attenuation or a technical impracticability waiver is more appropriate than the pump and treat system selected in the ROD. Any deviation from the ROD will be documented by Fact Sheet, ESD, or ROD Ammendment as appropriate. The next five-year review is scheduled for 2011.