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U.S. EPA’s Proposed Lead Cleanup Changes at Illinois Superfund Sites
The Illinois EPA is alerting Illinois residents of upcoming changes U.S. EPA intends to make at multiple Superfund Sites in Illinois where lead in soil is a primary concern and targeted for cleanup. These changes stem from U.S. EPA’s October 2025 Residential Soil Lead Directive. Illinois EPA estimates more than 10 sites across Illinois will be affected, specifically at former smelter and mineral beneficiation sites.
The Illinois EPA disagrees with the changes U.S. EPA is preparing to make for the following reasons:
- The remediation actions will result in mismatched cleanups between neighboring properties and across communities
- The directives are less protective than Illinois cleanup standards
- Decisions are being made without adequate public participation
The U.S. EPA has started issuing Explanations of Significant Differences (ESDs) that modify previously agreed-upon cleanup decisions, documented in a Record of Decision (ROD). The ESDs will detail the changes for each site. Each affected site will have a separate ESD describing its specific proposed changes. Illinois EPA has already received three ESDs and anticipates receiving more for Superfund Sites throughout Illinois. Those three ESDs recieved are for ASARCO in Taylor Springs (Montgomery County), Matthiesen and Hegeler in LaSalle (LaSalle County) and New Jersey Zinc in Depue (Bureau County).
(Map below highlights Superfund Sites that could be impacted by the Changes from the U.S. EPA Directive)
Impact of Changes
Illinois EPA is concerned that the proposed federal changes may lead to inconsistent levels of protection and reduced public involvement, including:
Shallower, Potentially Less Protective Soil Cleanup
U.S. EPA is proposing to reduce the maximum soil excavation from 24 inches to 12 inches, even though existing RODs selected a maximum of 24 inches as the protective depth. Leaving deeper contamination in place may expose current and future residents, particularly during typical activities like installing fences, planting trees, or digging for household projects.
The current cleanup concentration is 400 milligrams per kilogram (mg/kg) or 400 parts per million (ppm). Based on the new Directive, U.S. EPA is revising the screening value down to 200 ppm. This is a more stringent and protective cleanup value. However, this will be offset by less soil being cleaned up at deeper depths.
Higher Allowable Lead Levels Than Illinois Standards
Illinois’ public health regulations define an elevated blood lead level as 3.5 µg/dL and consider this blood lead level to indicate “lead poisoning.’ Using 3.5 µg/L to calculate a soil cleanup value results in a soil level of 100 ppm to be protective.
The new federal directive uses 5 µg/dL, which generates a screening level of 200 ppm, which is less protective and does not necessarily protect against lead poisoning as defined in Illinois regulations. Illinois EPA maintains that cleanup levels in Illinois must continue to be based on the lower, more protective criteria.
Reduced Re-evaluation of Previously Cleaned Properties
U.S. EPA has indicated it may not reevaluate properties previously cleaned under older, less protective lead levels. Illinois EPA disagrees, noting that this decision could leave some properties with unsafe conditions if more protective standards are not applied consistently.
Greater Reliance on Institutional Controls and Property Restrictions
Under the proposed approach, more contamination may be left in place, meaning residents could face:
Expanded land-use restrictions
Possible lead exposure and disruption if digging deeper than 12 inches
Restrictions on locations of future gardens or play areas
Property-specific notices or covenants about disturbing soil (i.e. planting trees, building a structure)
If contaminated soil is excavated by a resident, the resident automatically becomes a generator of at least solid, if not hazardous, waste which must be managed in accordance with Federal, State and local requirements
Illinois EPA also notes that U.S. EPA has temporarily paused recording institutional controls and sampling results on property deeds, which could leave future homeowners unaware of the level of lead or remediation on the property, and could affect property values.
Use of ESDs Limiting Public Participation
Illinois EPA strongly disagrees with using ESDs for major cleanup changes. ESDs do not require a public comment period, whereas ROD amendments do. Given the magnitude of the changes (shallower excavation, higher allowable lead levels, and increased reliance on deed restrictions) Illinois EPA believes these are fundamental remedy changes that require public input before adoption.
What this could mean for Illinois residents
If U.S. EPA’s proposed changes move forward:
- Cleanups may remove less contaminated soil than Illinois now considers protective.
- Properties may be left with higher remaining lead levels than Illinois now considers protective.
- Residents could face new property restrictions dictating what can and can’t be done on the property.
- Residents are responsible for managing impacted soils they disturb or remove from their yards in accordance with Federal, State and local environmental requirements.
- Impacts on property value via what is recorded on the deed.
- Cleanups in the same neighborhood may differ depending on timing, creating inequitable outcomes.
Health Risks
Lead exposure poses a health hazard, particularly to children, if ingested or inhaled in sufficient quantities. Lead enters the body through breathing contaminated dust, by swallowing contaminated soil, and by eating food not thoroughly washed that has been grown in contaminated soil.
Exposure to contaminated soil is more dangerous to young children because of their frequent hand-to-mouth activity and their increased susceptibility to lead. Dust from contaminated soil can be tracked into the house on shoes and can end up on indoor surfaces and toys.
Lead can affect almost every organ and system in the human body. The most sensitive area of the body is the central nervous system, particularly in children. Unborn children can be exposed to lead through their mothers. Harmful effects include premature births, smaller babies, decreased mental ability in infants, learning difficulties, and reduced growth in young children. These effects are more common after exposure to high levels of lead.
To learn more about the health risks and ways to reduce your exposure to lead and other contaminants, visit the Illinois Department of Public Heath, by clicking here.
Illinois EPA's Response
Because the U.S. EPA is the lead agency responsible for the management and implementation of Superfund cleanups, the Illinois EPA has thoroughly reviewed the proposed Explanation of Significant Differences (ESD) changes and communicated its perspectives to the U.S. Environmental Protection Agency.
As the U.S. EPA issues new ESDs, the Illinois EPA continues to advocate for cleanup approaches that best protect public health and the environment while meeting or exceeding Illinois’ standards.
For more information contact:
Morgan Schaab
Illinois EPA | Office of Community Relations