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Interstate Lead Company
National Information
Photos/Multimedia
Remediated area of the Acmar Church, one of the seven satellite sites included as part of the ILCO Superfund site.
- Additional Site Photos
- Site Video
Additional Resources
- Site Cleanup Terms - can be found in EPA's glossary
- EPA Guides to Cleanup Technologies
- Superfund Community Involvement (PDF) (17 pp, 130K, About PDF)
Site Summary Profile
EPA ID: ALD041906173Location: Leeds, Jefferson County, AL
Lat/Long: 33.688880, -086.633330
Congressional District: 06
NPL Status: Proposed: 09/18/85; Final 06/10/86
Affected Media: Debris, Ground water, Sediment, Soil, Surface water
Cleanup Status: Physical cleanup activities have started.
Site Reuse/Redevelopment: Interstate Lead Co. Main Facility is currently unused
Site Manager: Charles King (king.charlesl@epa.gov)
Site Background
The Interstate Lead Co. (ILCO) site is located approximately 15 miles east of Birmingham, in Leeds, Jefferson County, Alabama. The site consists of the ILCO Main Facility and seven satellite sites located in and around the City of Leeds, where lead-contaminated wastes from the ILCO Main Facility were disposed. The ILCO Main Facility is located on the southwestern side of the city. The ILCO Main Facility (including the ILCO Parking Lot across the street) occupies approximately 11.5 acres of real property, most of which is owned by ILCO with a portion owned by Interstate Trucking Company, Inc., an affiliated company.
The satellite sites include:
- the ILCO Parking Lot, located across the street from the ILCO Main Facility;
- the Gulf/BP Service Station, located in the center of Leeds on U.S. Highway 78;
- J&L Fabricators, located east of Leeds on U.S. Highway 78;
- Fleming's Patio, located west of Leeds on Alaska Avenue;
- the Connell Property, located east of Leeds in St. Clair County;
- the Acmar Church of God, located off Acmar Road in Moody, Alabama; and
- the City of Leeds Municipal Landfill, located off Dunavant Road at the end of Peach Street.
The ILCO facility 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 the seven satellite sites in and around the City of Leeds. The area is primarily industrial with a few residences within a half-mile radius. ILCO ceased operations in March 1992 and declared bankruptcy shortly thereafter.
Threats and Contaminants
In the early 1980s, EPA and the Alabama Department of Environmental Management conducted sampling inspections of the ILCO Main Facility and found the facility to be in violation of the Resource Conservation and Recovery Act interim status standards for hazardous waste storage and disposal, and the National Pollutant Discharge Elimination System discharge permit standards under the Clean Water Act.
The primary contaminant at the site is lead. The secondary contaminants of concern include antimony, arsenic, cadmium, chromium, and nickel. These contaminants were present in ground water and soil from the site.
The principle potential pathways of exposure for all of the ILCO sub-sites is direct contact with contaminated soil or sediment, contaminated ground water consumption, and inhalation of contaminated dust.Site Cleanup Plan
Due to the size and complexity of the site, EPA identified three operable units (OUs): OU-1 (soil, sediment and ground water contamination in the seven satellite sites in the vicinity of the ILCO facility); OU-2 (soil and ground water contamination at the Main Facility and ground water at the ILCO Parking Lot); OU-3 (contamination of surface water, sediment and biota in Dry Creek and the Un-named Tributary).
The Record of Decision (ROD) for OU-1 was issued in 1991. The cleanup approach included numerous different components that varied depending upon the seven satellite areas being addressed. Major components of the cleanup approach for the ILCO Parking Lot and Fleming's Patio satellite areas include:
- Excavation and solidification/stabilization of soil with lead concentrations exceeding 300 mg/kg and replacing the treated soil back into the excavated areas.
- Removal of battery casings and other debris.
- Solidification of battery casing material that can be sufficiently crushed and replacing the solidified material on site.
- Off-site disposal of other debris.
- Revegetation of excavated areas.
- Institutional controls, consisting of access and deed restrictions.
- Long-term ground water monitoring.
- Semi-annual sampling and analysis of existing monitor wells for the primary metals associated with automotive batteries.
In 1994, EPA amended the cleanup approach for OU-1. Major modifications included:
- Use of acid leaching instead of solidification/stabilization for treatment of the excavated soils from the satellite sites (if acid leaching meets performance standards during the Site-specific treatability study to be conducted).
- Selection of an alternative location where contaminated material from the satellite sites will be taken for treatment.
These are discussed in more detail in the 1994 ROD which also identifies the cleanup approach selected for OU-2 (see below).
The ROD for OU-2 was issued in 1994. The cleanup approach addressed the soil and ground water at the ILCO Main Facility and ground water at the ILCO Parking Lot.
Major components of the cleanup approach for soil identified in the 1994 OU-2 ROD included:
- Excavate contaminated soil, treat soil to established performance standards onsite by acid leaching, if determined to be effective during a treatability study, otherwise treat soil to established performance standards onsite by solidification/stabilization.
- If acid leaching is implemented, backfill excavated areas onsite with treated (i.e., clean) soil. If solidification/stabilization is implemented, dispose of treated (i.e., stabilized) soil in an on-site engineered containment cell and backfill excavated areas with clean fill. Grade and revegetate excavated areas once backfilled.
- Decontaminate/treat debris using specific best demonstrated available technologies based on the type of debris and the type of contaminants present in the debris; recycle decontaminated debris that can be recycled and dispose of decontaminated debris that cannot be recycled offsite in a non-hazardous landfill; debris which cannot be decontaminated will be disposed offsite in a permitted hazardous waste landfill; decontaminate any remaining buildings and/or structures onsite.
- Package and ship slag that can be recycled to an off-site permitted facility for recovery of lead using a secondary smelter; non-recyclable slag will be solidified/stabilized and disposed offsite in a permitted hazardous waste landfill, if acid leaching is implemented; if solidification/stabilization is implemented, non-recyclable slag will be solidified/stabilized to pass the Toxicity Characteristic Leaching Procedure (TCLP) test and disposed in the on-site containment cell.
- Package and ship battery casing components and battery chips that can be recycled to an offsite permitted facility for recovery of lead using a secondary smelter; non-recyclable components that fail TCLP will be disposed offsite in a permitted hazardous waste landfill and non-hazardous, non-recyclable components will be disposed offsite in a non-hazardous landfill, if acid leaching is implemented; if solidification/stabilization is implemented, nonrecyclable components will be solidified/stabilized to pass TCLP, if necessary, and disposed in the onsite containment cell.
- Send roll-off boxes of baghouse dust (K069) offsite to a RCRA permitted Treatment, Storage, and Disposal (TSD) facility. Treatment and disposal of the baghouse dust shall comply with all pertinent regulations and requirements, including Land Disposal Restrictions (LDRs).
- Monitor air emissions from OU-2 during remedial action activities.
Major components of the cleanup approach for ground water identified in the 1994 OU-2 ROD included:
- Conduct additional ground water investigations on OU-2 during the design phase to fill data gaps and determine the technical practicability of restoring the ground water aquifer to its beneficial use.
- Pump contaminated ground water from the shallow, intermediate, and deep zones of the aquifer, where technically practicable, using a ground water extraction system of trenches and wells.
- Treat the ground water contaminated with inorganics to established performance standards via precipitation/flocculation using the existing on-site water treatment plant (with necessary renovation), if available.
- Segregate ground water in the shallow extraction system from the intermediate and deep ground water for treatment of both free phase and dissolved phase hydrocarbons. Shallow ground water will pass through an organics treatment system before entering the treatment train for inorganics shared with ground water extracted from the intermediate and deep zones.
- Discharge treated ground water effluent, meeting applicable requirements, to the Un-named tributary adjacent to the ILCO Main Facility.
- Implement institutional controls, as necessary, for both ground water usage and land usage at OU-2.
The ROD for OU-3, comprising the Dry Creek and Un-named Tributary, was issued in 1995. Major components of the cleanup approach included:
- Monitored natural attenuation (e.g., dilution, flushing, burial, etc.) of the contaminated sediment.
- Recommending to the Alabama Department of Public Health that a fishing advisory be issued for the Un-named Tributary and Dry Creek near the ILCO Main Facility.
- Posting of warning signs along the Un-named Tributary and Dry Creek to indicate the presence of contaminated sediment and the fish advisory.
- Annual surface water; sediment, and biota monitoring.
- Five-Year Reviews as required by the Superfund law to evaluate the effectiveness of the selected remedy.
The cleanup approach for OU-1 was amended again 1996, along with the cleanup approach for soil for OU-2 in a ROD Amendment.
Cleanup Progress
In April 1984, EPA conducted an emergency removal action at the Acmar Church of God site; approximately 5,000 cubic yards of waste material and soil were removed.
When ILCO ceased operations in March 1992, EPA initiated another removal action to mitigate imminent threats associated with the abandoned ILCO Main Facility. Removal activities ranged from removal of over 5,000 tons of lead-contaminated slag to a permitted hazardous waste landfill to collection and treatment of acid stored in several on-site impoundments.
In 2000-2001, 220,243 tons of soil and debris was excavated, treated and disposed of off-site.
In 2004-2005, lead impacted soil located in grids identified by sampling operations was excavated.
Institutional controls (ICs), such as deed restrictions, have been placed at several properties. ICs may be placed on additional properties in the future.
The 2006 Five-Year Review for the site concluded the following:- Soil cleanup approaches implemented for OU-1 are considered to be protective of human health and the environment. They have removed the principal threat, and are expected to function as intended by minimizing the migration of contaminants to ground water and surface water.
- The ground water cleanup approach implemented for several OU-1 properties (J&L Fabricators, Fleming's Patio, and the Connell Property), monitored natural attenuation is expected to be protective of human health and the environment upon completion. In the interim exposure to contamination that could result in unacceptable risk is being controlled.
- A determination was made that the ground water cleanup approach, a pump and treatment system, selected for another OU-1 property, the City of Leeds Landfill, will not be needed based upon further review.
- The soil cleanup approach for the ILCO Main Facility, part of OU-2, has been successfully implemented and is protective of human health and the environment.
- Additional ground water monitoring is necessary at the ILCO Main Facility to confirm that the soil excavation was effective in removing source material in this area.
- The pump and treat cleanup approach for the ILCO Main Facility has not been installed. However, recent ground water data (since 2004 when a substantial portion of the soil remediation had been completed) indicates that lead is not present in the ground water at concentrations exceeding the performance standard at the main facility or the ILCO Parking Lot.
- A protectiveness determination cannot be made at this time for OU-3 until further information is obtained.
Site cleanup activities are being led primarily by PRPs with oversight by EPA.
Enforcement Activities
Based upon ILCO's operating records, EPA identified approximately 979 PRPs who sent 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, EPA Region 4 requested that the Department of Justice concur in a settlement with 20 generator PRPs at the ILCO site. Under the terms of the proposed settlement, the settling defendants were to conduct the Remedial Design/Remedial Action for the entire site including all seven satellite sites, and were to reimburse the United States for a portion of past response costs. Additionally, the ILCO PRPs were to reimburse the United States for future oversight costs related to the Consent Decree in excess of $300,000.
See the ILCO Site Chronology in the 2006 Five-Year Review for a list of major enforcement actions.Community Involvement
EPA has conducted a range of community involvement activities at the ILCO site to solicit community input and to ensure that the public remains informed about site activities throughout the site cleanup process. Outreach activities have included public notices and information meetings on cleanup progress and activities.
Future Work
EPA is currently reviewing ground water 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 OU-2 ROD. Any deviation from the OU-2 ROD will be documented by Fact Sheet, Explanation of Significant Differences, or ROD Amendment as appropriate.
The next Five-Year Review is scheduled for 2011.Site Administrative Documents
Site Repository
For more information or to view any site related documents, please visit the site information repository at the following location. As new documents are generated, they will be placed in the information repository for public information.
Leeds Public Library802 Parkway Dr. SE
Leeds, AL 35094
Administrative Record Index
- Final (PDF) (2 pp, 70K, About PDF)
- OU-1 (PDF) (48 pp, 1.6MB, About PDF)
- OU-3 (PDF) (8 pp, 389K, About PDF)
- OU-1/2 (PDF) (6 pp, 242K, About PDF)
For documents not available on the website, please contact the Region 4 Freedom of Information Office.