905R90105
Agency Review Draft
FEASIBILITY STUDY REPORT
G&H LANDFILL SITE
Shelby Township, Michigan
WA 12-5170.0/Contract No. 68-W8-0040
May 30, 1990
This document has been prepared for the U.S. Environmental Protection Agency
under Contract No. 68-W8-0040. The material contained herein is considered
confidential and is not to be disclosed to, discussed with, or made available to any
person or persons for any reason without the prior express approval of a responsible
official of the U.S. Environmental Protection Agency.
GLT959/019.51-1
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CONTENTS
1 INTRODUCTION 1-1
Site Background 1-2
Site Investigations and Reports 1-7
EPA Removal Actions 1-12
Remedial Investigation 1-15
Risk Assessment 1-17
2 REMEDIAL GOALS 2-1
NCP and CERCLA Goals 2-1
Remedial Goals for the G&H Site 2-2
Operable Units for the G&H Site 2-3
Potential ARARs for the G&H Site 2-4
3 ALTERNATIVES ARRAY 3-1
General Response Actions 3-2
Range of Alternatives 3-2
Initial Evaluation of Alternatives 3-3
4 TECHNOLOGY SCREENING AND DEVELOPMENT 4-1
Initial Technology Development 4-1
Detailed Technology Screening and Evaluation 4-2
Technology Evaluation Summary 4-18
5 ALTERNATIVES EVALUATION 5-1
Detailed Alternative Descriptions 5-1
CERCLA Requirements for Alternative Evaluation 5-11
Detailed Evaluation of Alternatives 5-14
Comparative Analysis of Alternatives 5-16
Appendix A Initial Technology Screening A-l
Appendix B Containment Analysis B-l
Attachment B-l
Appendix C Groundwater Collection Analysis C-l
Appendix D Treatment Systems Analysis D-l
Appendix E Vehicular and Construction Accidents E-l
Appendix F Cost Estimate Tables F-l
Attachment F-l
FIGURES Follows
Page
1-1 Flow Diagram of Alternatives Selection Process 1-1
1-2 Site Location 1-2
1-3 Site Features 1-2
1-4 Potentiometric Surface of the Upper Aquifer 1-15
1-5 Geologic Cross Section 1-15
GLT959/039.51
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FIGURES (Continued) Follows
Page
1-6 BETX Concentrations in Subsurface Soil 1-15
1-7 Source Area Cross-Section 1-15
1-8 Extent of BETX and Chlorinated Volatile
Compounds in Groundwater in the Upper Aquifer 1-16
1-9 Summary of Risks 1-18
3-1 Alternatives Development 3-3
3-2 Approximate Extent of Hotspots 3-7
5-1 Alternative 3A, Soil Clay Cover 5-4
5-2 Alternative 3B, Soil Clay Cover and Vertical
Barrier 5-5
5-3 Alternative 4A, Groundwater Treatment with Source
Containment 5-9
5-4 Alternative 6A, Source Removal and Treatment 5-10
TABLES
1-1 Summary of Risks 1-18
2-1 Potential ARARs for the G&H Landfill Site 2-6
3-1 G&H Alternatives Development—Initial Evaluation
Summary 3-3
4-1 Applicable Technologies and Process Options 4-2
4-2 Technology Evaluation for Preliminary Alternatives 4-18
5-1 Detailed Evaluation of Alternatives 5-14
GLT959/039.51
GLT959/039.51 ii
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Chapter 1
INTRODUCTION
This report summarizes the results of the Feasibility Study (FS) completed at the
G&H Landfill site, Macomb County, Michigan. CH2M HILL performed the work
authorized by the U.S. Environmental Protection Agency (EPA) under Contract
No. 68-W8-0040, Work Assignment No. 12-5L70.0.
The G&H Landfill site is on the National Priority List (NPL) of uncontrolled
hazardous waste sites. Sites on the NPL are eligible for remedial action under the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 1980. The authority to list, investigate, and remedy hazardous waste
sites under CERCLA was extended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986. The EPA is authorized to act when there is an
actual or substantial threat of release of hazardous substances into the environment,
or there is a release or substantial threat of release into the environment of any
pollutant or contaminant that may present an imminent and substantial danger to
public health or welfare [CERCLA Section 104(a)(l)]. Pursuant to Section 105 of
CERCLA and to Section 311(c)(2) of the Clean Water Act, the National Contingency
Plan (NCP) [40 CFR Part 300] was prepared to establish procedures and criteria for
responding to releases of hazardous substances. Section 300.430 of the NCP outlines
the Remedial Investigation/Feasibility Study (RI/FS) procedure for determining the
nature and extent of contamination at a site and the appropriate remedy for that site.
The draft RI Report, completed in March 1990, investigated the nature and extent of
chemical contamination at the G&H Landfill site and evaluated the risks posed to
human health and the environment.
This FS report documents the development of remedial action alternatives for the
G&H Landfill site. The EPA will use this information to recommend a remedial
action alternative in accordance with the NCP. Figure 1-1 shows the process by
1-1
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Site
Conditions
Chapter 1
Introduction
Superfund
Program
Goals
Alternative
Development
Applicable
Technologies
C/5
W
LU
8
CE
0.
in
8
Screening
Criteria
H
Site Specific
Goals For
Selected
Operable Units
H
ARARs
Chapter 2
Remedial Goals
Response
Actions
Initial
Evaluation
of
Alternatives
• EFFECTIVE (Meet Site-Specific
Goals?)
• IMPLEMENTABLE (Meet ARARs?
Practical?)
• COST
Range of
Alternatives
Chapter 3
Alternatives
Array
Screening
Criteria
> EFFECTIVE
i IMPLEMENTABLE
'COST
Selected
Technologies
Assembled
Alternatives
Chapter 4
Technology
Screening
and Development
Detailed
Alternatives
Chapter 5
Alternatives
Evaluation
FIGURE 1-1
FLOW DIAGRAM OF ALTERNATIVES
SELECTION PROCESS
G & H LANDFILL FS
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AGENCY REVIEW DRAFT
which remedial alternatives were developed along with the Feasibility Study (FS)
chapter where supporting information can be found. Specific criteria were used to
evaluate remedial technologies and the potential effectiveness of each remedial
alternative. Following screening, several alternatives underwent detailed analysis.
SITE BACKGROUND
This section describes the G&H Landfill site and its history. Previous site
investigations and emergency actions implemented at the site are also discussed.
SITE DESCRIPTION
The G&H Landfill site is located in the northeast quarter of Section 19, Shelby
Township, Macomb County, Michigan (Figure 1-2). It is approximately 3 miles
northwest of Utica. The site operated as a waste oil reclamation facility from 1955 to
1967 and a landfill from approximately 1955 to 1973. The landfill is currently closed
to disposal activities.
Since the mid-1950s, the area has changed from a rural setting to a residential area.
Aerial photographs taken in 1955 indicate that most of the land in the vicinity was
used for farming or sand and gravel mining. Presently there is a residential area east
of Ryan Road and a new housing development north of 23 Mile Road. The
Rochester-Utica State Recreational Area, managed by the Michigan Department of
Natural Resources (MDNR), lies just south of the site along the Clinton River.
The site boundaries are currently defined by the site fence as shown in Figure 1-3.
Approximately 60 acres of the site lie between an abandoned Conrail Railroad right-
of-way and 23 Mile Road (Figure 1-3). This area is bordered on the east by two
commercial facilities: a portable sanitation manufacturer and a petroleum products
distributor. An inactive automobile salvage yard, located directly north of the
commercial area, is included in the site. Although this area was not used for
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/ PIPE LINE AND
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AUTOMOBILE
DISPOSAL
YARD
APPROXIMATE LIMITS OF
LANDFILL AREAS
i - ABANDONED RAILROAD
NOTE: Location of all structures and site
features are approximate.
0 60Q
SCALE IN FEET
FIGURE 1-2
SITE LOCATION
G & H LANDFILL FS
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(TRACKS REMOVED)
ROCHESTER - UTICA STATE
RECREATION AREA
NORTHERN BOUNDARY
SANITARY SEWER
WATER LINE
• -V
GAS SERVICE LINE
FIGURE 1-3
SITE FEATURES
G & H LANDFILL FS
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AGENCY REVIEW DRAFT
landfilling, it is littered with the remains of automobiles, trucks, and construction
equipment. Another 40 acres of the site are southwest of the railroad grade. This
area is bounded on the south by wetlands and woodlands and on the west by the
Clinton River. A small pond fed by surface runoff exists north of the Phase III
Landfill.
The Detroit Metropolitan Water and Sewer District has a north-south pipeline
easement in the western portion of the site (see Figure 1-3). The easement is for a
96-inch-diameter waterline and a 24-inch near-surface interceptor sewer. The
waterline, constructed in 1967 by the trench and fill method, serves as the main
distribution line from Lake Huron to Detroit. The interceptor, which serves Shelby
Township, is connected to a 96-inch-diameter regional interceptor beneath the site.
The regional interceptor serves Oakland County and connects to the Sewer District's
main treatment plant. This large interceptor was constructed in 1971 by tunneling
and is approximately 40 feet below the surface.
Various abandoned facilities intersect the site (see Figure 1-3). An abandoned
railroad right-of-way, formerly part of the Conrail system, runs through the site in a
northwest to southeast direction. A spur line right-of-way runs northward on the
western edge of the site. The Clinton-Kalamazoo Canal, an abandoned navigation
project, runs east to west through the woodlands south of the site and turns
northward along the western edge of the site. The canal is a 20-foot-wide ditch filled
with debris in the Phase III Landfill. The ditch carries water intermittently. The
woodland area to the south contains many abandoned sand- and gravel-mining
trenches.
The site contains three distinct landfilled areas (Figure 1-3):
• Phase I Landfill—44 acres
Phase II Landfill—17 acres
Phase III Landfill—8 acres
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Differential settling of the landfills has resulted in uneven terrain with numerous
depressions on the landfill surfaces. The landfill surfaces are at approximately the
same elevation as 23 Mile Road. The Phase I and II Landfills are covered with
grasses, weeds, scrub brush, and small trees; the Phase III Landfill has little
vegetation. Refuse is exposed at the surface of all three areas. The Phase II Landfill
has a steep southern slope that terminates in woodlands to the south, and the
Phase III Landfill has a steep slope to the west and south that terminates in
woodlands and swamp. An oil seepage area is located south of the east portion of
the Phase I and II Landfills, and there are leachate seeps along the Phase III Landfill
at the west boundary of the site (see Figure 1-3).
EXISTING ENVIRONMENT
Several distinct types of vegetation are present at the G&H Landfill and adjacent
areas. The Phase I and Phase II Landfill surfaces are characterized by a mixture of
herbaceous species typical of disturbed sites. Some small trees and shrubs are
present in the central portion of the Phase I Landfill. There is limited vegetative
cover on the Phase III Landfill; however, a wet, wooded parcel is located between it
and the Clinton River. A woodland with oak trees is also located immediately south
of the Phase II Landfill.
A wetland south of the Phase I Landfill contains narrow excavations from the mining
of sand and gravel. The standing water in these excavations has a layer of oil on the
surface, from oil seeping from the landfill area to the north. Vegetation in the area
includes cattails, various shrubs, and trees. The wetland area extends south past the
Clinton-Kalamazoo Canal near Ryan Road. Ponded water is present in the unused
canal, and a marshy area with aquatic and emergent vegetation is found nearby. The
land slopes steeply south of this wetland area. Further south, an oak-hickory
woodland present on the slope grades into a wooded area with elm, cottonwood, and
box elder trees adjacent to the Clinton River.
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Wildlife habitat types at the G&H Landfill and adjacent areas include old field on the
landfills and upland woodlands. Wetland habitat types include woodland, shrub/scrub,
and marsh.
A variety of wildlife is found at the G&H Landfill site and the habitat adjacent to the
Clinton River. Mammal species include deer, raccoon, muskrat, red fox, opossum,
woodchuck, and red squirrel. Birds found in the area include hawks, owls, great blue
herons, wood ducks, mallards, Canada geese, orioles, cardinals, meadowlarks, doves,
and various other species commonly found in a rural or suburban environment. The
variety of bird species present reflects the variety of habitat types.
The Clinton River is located south and west of the G&H Landfill. The river provides
habitats for fish species including northern pike, walleye pike, white sucker, common
shiner, and carp. Crayfish and snapping turtles are also found in this river as well as
the ponds between the site access road and the Clinton Kalamazoo Canal southeast
of the Phase I Landfill.
SITE HISTORY
Waste disposal operations at the site began in the mid-1950s and ended in 1973. The
site accepted municipal refuse and liquid and solid industrial wastes including oils,
solvents, paint residues, and industrial process muds. Separate areas in the Phase I
Landfill were identified as receiving solid and liquid wastes, in bulk and drums
(Michigan Water Resource Commission [MWRC] 1965 and 1967). These areas
(Figure 1-3), which are now covered with fill, include:
Oil Pond No. 1
Oil Pond No. 2
• Rubbish Area (now referred to as the Codisposal Area)
• Paint, Varnish, and Solvent Ponds
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AGENCY REVIEW DRAFT
A fish pond also existed in the northern part of the Phase I Landfill. Records do not
indicate that wastes were disposed of there.
From approximately 1955 to 1967, the G&H Industrial Fill Company operated a
waste oil recovery system at the site. Bulk waste oils from various industrial sources
were transported to the site in railroad tanker cars and tanker trucks. Records
indicate that an estimated 600,000 gallons of waste oil was accepted monthly at the
site (MWRC 1967); however, the time frame over which this volume was accepted is
not known.
Waste oil delivered to the site by rail was a heavy black slurry with the appearance
and odor of petroleum (MWRC 1967). The oil was discharged through concrete
flumes into Oil Pond No. 2 where heavier constituents were allowed to settle. The
upper layer of oil was then pumped to Oil Pond No. 1. Waste oil delivered to the
site by truck was described as a light gray water and oil mixture having a milky
viscosity and petroleum odor (MWRC 1967). The oil was discharged to Oil Pond
No. 1, where it mixed with the oil recovered from Oil Pond No. 2. After the heavier
constituents settled, the upper layer of oil was collected and sold as industrial oil.
Personnel familiar with the waste oil recovery operations estimated that
approximately 50 percent of the waste oil delivered to the site was recovered in this
manner.
Besides being used as an oil reclamation facility, the site was used as a sanitary
landfill and was referred to as the Shelby Township dump (MWRC 1967). MWRC
personnel noted that large volumes of rubbish were disposed of daily, backfilling was
done using a crawler-type tractor, while other earthmoving activities were done using
a dragline crane. Codisposal of liquids and refuse is suspected to have occurred in
the southeastern area of the Phase I Landfill before the 1967 MWRC Consent Order
(see Figure 1-3).
The landfill apparently operated under various State permits from 1967 until it closed
in 1973. By 1970, the Phase I Landfill contained refuse to a depth of 20 feet, and the
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AGENCY REVIEW DRAFT
ponds that had been used for oil reclamation and liquid waste disposal were covered.
The Phase II Landfill was nearing completion at that time, and the site was permitted
to expand landfilling to the Phase III area. Although plans for the Phase III Landfill
originally proposed rerouting the Clinton-Kalamazoo Canal, the canal was not
rerouted and is now filled with refuse beneath the Phase III Landfill. Landfill
operations ceased in 1973. A final closure plan for the site (i.e., grading, capping,
planting vegetation, groundwater monitoring) was neither prepared nor implemented.
SITE INVESTIGATIONS AND REPORTS
From 1965 to the present, six site investigations and reports have been completed.
MWRC conducted investigations in 1965 and 1966. The EPA completed a Field
Investigation Team assessment in 1982, Remedial Action Master Plan (RAMP) in
1983, and Stage I and II of the RI in 1987. MDNR completed a Supplemental
Investigation in 1989.
PRE-1982 INVESTIGATIONS
Beginning in the early 1960s, residents complained to the Macomb County Health
Board (MCHB) about sewage odors emanating from the Clinton-Kalamazoo Canal
south of the site. A site inspection by MCHB did not locate the source of the odors;
however, the MCHB apparently notified MWRC regarding this incident. Following
repeated complaints, joint site surveillance by MCHB and MWRC discovered
groundwater seeps south of the railroad tracks that emitted a strong chemical odor.
In July 1965, MWRC conducted a groundwater and surface water investigation at the
site (MWRC 1965). At that time the site was accepting solid and liquid waste. Most
of the liquid wastes were wastewater containing oils, oil sludges, and soluble oils.
Drums were also accepted at the site, and three distinct ponds for the disposal of
paints, varnishes, and chemical solvents were noted at that time.
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The field survey and hydrological study indicated that groundwater contaminants from
the site were migrating south from the site and emerging in surface waters. Surface
water and groundwater samples were collected at that time, and some were found to
contain high phenol and chloroform concentrations.
As a result of the 1965 investigation, a Consent Order was issued by the Macomb
County Circuit Court in May 1966 prohibiting the disposal of paints, varnishes, paint
thinners, and lacquer. However, the disposal of waste oil and process sludges was not
prohibited at that time.
In November 1966, MWRC initiated another site investigation to substantiate that
disposal of waste oils was also a source of groundwater contamination (MWRC 1967).
At that time, groundwater seep south of the railroad tracks flowed into an
impoundment, possibly a trench left from sand and gravel mining. Overflow from the
impoundment discharged into an outlet at its western end and flowed southward into
the Clinton-Kalamazoo Canal. The water reportedly had a strong medicinal odor,
and heavy deposits of iron and oil-like substances were observed on bank vegetation.
The investigation concluded the following:
• Groundwater flow was generally to the south.
• Seepage from the oil ponds was contaminating groundwater, which then
migrated beyond the boundaries of the landfill property.
• Groundwater and surface water contamination was increasing due to
paints, lacquers, and thinners even though these materials were no
longer being accepted at the site.
Based on the 1966 MWRC investigation findings, the Macomb County Circuit Court
issued a Consent Order banning the disposal of any liquid industrial wastes, muds, or
sludges. Since October 2, 1967, there has been no documented disposal of any liquid
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industrial waste at the G&H Landfill site. However, the site continued to operate as
a sanitary landfill.
The State of Michigan took samples from the site between 1973 and 1979. Results
from these samples indicated potential contamination of the Clinton River by leachate
seeps west of the Phase III Landfill and by oil seeps south of the Phase I Landfill.
FIELD INVESTIGATION TEAM ASSESSMENT—1982
In 1982, FIT personnel under the direction of the EPA conducted a hydrogeological
investigation at the site (EPA 1982). The primary objective of the assessment was to
determine the lateral and vertical extent of groundwater contamination and
contamination of the Clinton River adjacent to the site. Data collected by this
investigation was used to calculate a Hazard Ranking Score for the site.
The investigation determined that inorganic and organic contaminants were present in
groundwater, surface water, and subsurface soil at the site. The calculated Hazard
Ranking Score led to placing the site on the NPL in September 1983.
REMEDIAL ACTION MASTER PLAN—1983
The RAMP, based on a site visit and document review, was prepared in 1983 (EPA,
1983). The plan identified the scope of practical remedial investigation activities,
recommended initial remedial measures for the site, and developed a site chronology.
STAGE I AND II REMEDIAL INVESTIGATION—1983 TO 1987
The purpose of Stage I of the RI, conducted from 1983 to 1985, was to determine
offsite releases. Stage II activities were conducted from 1985 to 1987 to better define
contamination sources and releases attributable to those sources (EPA 1987).
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Stage I and II investigations identified the:
• Contaminant sources in the Phase I Landfill
Oil Pond Nos. 1 and 2
— Several drum disposal areas
— Solvent codisposal area
• Contaminant releases:
— Oil floating on groundwater, migrating southward and discharging
to the Oil Seepage Area, where it continues to migrate offsite in
surface waters
— Volatile organic compounds [primarily benzene, ethylbenzene,
toluene, and xylene (BETX compounds)] migrating southward in
groundwater
— Leachate seeps west of the Phase III Landfill discharging to
wetlands on the edge of the Clinton River
— Polychlorinated byphenyl (PCB)-contaminated sediments
downgradient of the oil seepage area
— PCB- and polynuclear aromatic hydrocarbon (PNA)-
contaminated surface soils onsite
— Methane levels in the soil gas above the lower explosive limit
(along the northern boundary of the site)
The EPA in consultation with MDNR concluded that additional data were required
to complete a risk assessment and feasibility study for the site.
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SUPPLEMENTAL INVESTIGATION—1988 TO 1989
A Supplemental Investigation (concurrent with Phase III RI activities) was conducted
by MDNR (MDNR November 1989). The primary objective of this investigation was
to collect additional data that "could be incorporated into the Phase III analysis and
the RI Report."
The supplemental investigation included:
• A limited soil-gas survey
• Installing eight deep aquifer (lower sand unit or bedrock) monitoring
wells and eight leachate monitoring wells, and collecting and analyzing
two rounds of water samples from the wells
• Performing in situ hydraulic conductivity tests on the eight deep aquifer
wells
• Installing nine gas probes in landfill waste
• Collecting and analyzing surface water and sediment samples
• Collecting and analyzing surface soil from the landfills and adjacent
roads
The Supplemental Investigation Report summarized and presented the data collected
but did not evaluate nor draw conclusions from the data. Some of the data presented
in the Supplemental Investigation Report have been used in this report to evaluate
the site.
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STAGE III INVESTIGATION—1987 TO 1989
The EPA and MDNR decided that additional information was necessary to prepare a
risk assessment and feasibility study on the site. During Stage III, surface and
subsurface soil, sediment, groundwater, residential well water, surface water, leachate,
soil gas, and ambient air were sampled.
Information from all of the previous investigations was used to prepare the RI report.
The RI report is summarized in the following sections.
EPA REMOVAL ACTIONS
Since 1982, four emergency removal actions have been conducted at the G&H
Landfill site by the EPA, through the Emergency and Enforcement Response Branch
(EERB), formerly known as the Emergency Response Section (ERS). The first three
removal actions are complete and an On-Scene Coordinator's (OSC) Report was
prepared (EPA 1986). The fourth removal action has been completed, but the OSC
report has not been completed.
ACTION NO. 1—1982
At the request of MDNR, removal action No. 1 was initiated in June 1982 to prevent
public access to the Oil Seepage Area and prevent migration of PCB-contaminated
oil. A chain-link and snow fence was constructed around the Oil Seepage Area, and
three overflow dams were installed to direct the flow of surface water around the Oil
Seepage Area.
ACTION NO. 2—1983
During the winter of 1982-83, the oil seeps extended beyond the fenced area.
Removal action No. 2 was initiated in July 1983 to correct this condition. A
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AGENCY REVIEW DRAFT
temporary oil skimmer was installed to prevent floating oil from migrating, clay
barriers were constructed in the path of new oil seeps, and the fence was extended
around the perimeter of the new oil seeps.
ACTION NO. 3—1986
In April 1986, MDNR requested another emergency remedial action because the clay
barriers and site fence constructed in 1983 were no longer preventing either migration
of oil or public access to the oil. Removal action No. 3, initiated in May 1986,
consisted of the following activities:
• Onsite trails were blocked with earth berms, a gate was installed across
the main site entrance along Ryan Road, and warning signs were
posted.
• Isolated oil seepage areas were connected by excavating a collector
trench. A steel sheetpile barrier was constructed on the downgradient
edge of the trench to prevent oil from migrating in groundwater beyond
the collector trench. The collector trench and barrier directed seepage
flow to one discharge point, where a series of pipe underflow dams and
filters were constructed to prevent migration of oil from the collection
trench. A chain-link fence was installed around the perimeter to
prevent public access.
• A pole barn was constructed to store PCB-contaminated wastes
recovered during this action and future oil-recovery actions (Figure 1-3).
The storage building is 40 by 80 feet, has a concrete floor with 6-inch
curbing around the perimeter of the floor, and contains three
5,800-gallon tanks.
• Oil was recovered from the collector trench and stored in tanks inside
the storage building. Oil recovery was accomplished using a vacuum
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truck. High viscosity oils remaining in the trench were hydraulically
pushed to the collection point using a trash pump and hose nozzle
attached to a backhoe bucket.
ACTION NO. 4—1987
Removal action No. 4, initiated in July 1987, consisted of the following work:
• A 3-mile-long chain-link fence was installed around the site perimeter
and portions of the recreational area south of the site. The fence is
now considered the site boundary.
• A temporary treatment system, composed of a utility shed and aerator,
was installed at the discharge point of the Oil Seep Area.
• Oils were periodically recovered and stored. A vacuum truck could not
collect the oil because the oil had a tar-like crust from exposure to air.
The oil was collected by scooping it up with a backhoe and placing it on
the edge of the collector trench, allowing the liquid fraction to run off
into a collection pit, and then collecting the liquid portion with the
vacuum truck. Sludges and solids that accumulated in the storage area
were covered with a tarp.
• In April 1989, approximately 2,400 gallons of collected oil were
transported to a thermal destruction facility in Chicago.
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REMEDIAL INVESTIGATION
HYDROGEOLOGIC FEATURES
There are three stratigraphic units within the surficial deposits. The upper sand unit
is 7 to 46 feet thick, but may be absent in some areas. The upper sand unit contains
the upper unconfined aquifer. A lacustrine/till unit overlies the lower sand unit which
constitutes the lower confined aquifer. Groundwater flow of the upper unconfined
aquifer is primarily south-southwesterly, except in the western portion of the site
where flow is more westerly toward the Clinton River. The potentiometric surface of
the upper aquifer is presented in Figure 1-4. A geologic cross section of the site is
presented in Figure 1-5. Contamination from the site has not been detected below
the lacustrine/till unit. A detailed summary of the site hydrogeology is presented in
the RI report.
SUBSURFACE SOIL CONTAMINATION
The areas of the highest chemical contamination in the subsurface soil are in the
Phase I Landfill, primarily near the oil ponds and the suspected Codisposal Area (see
Figures 1-6 and 1-7). Subsurface soils in or near the Phase II and III landfills also
show contamination but to a lesser extent. Soils in the commercial area to the east
indicate that contamination may extend offsite.
Many organic contaminants were detected in the subsurface soil. BETX compounds
showed the greatest areal extent of contamination. PNAs and PCBs were the other
organic compounds most often detected and at the highest concentrations. Many
inorganic analytes were detected above background concentrations in or near the
three landfill areas.
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GH14B
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North
APPROXIMATE
SCALE IN FEET
A
I
LANDFILL BOUNDARY
U.S. EPA SITE FENCE/BOUNDARY
GATE
DITCH, STREAM, OR RIVER
TRAIL
FORMER CONRAIL RAILROAD
GRADE AND RIGHT OF WAY
(TRACKS REMOVED)
GROUNDWATER ELEVATION
(MEAN SEA LEVEL DATUM
AT MONITORING WELL)
INTERPRETED
GROUNDWATER
ELEVATION CONTOURS
(2 FOOT INTERVALS)
INFERRED GROUNDWATER
ELEVATION CONTOUR
A i
CROSS SECTION PRESENTED
.J IN FIGURE 1-5
NOTE: RLlOx is screened in the refuse and may
indicate leachate level rather than
water table level.
o
o
FIGURE 1-4
POTENTIOMETRIC SURFACE OF
THE UPPER AQUIFER (JULY 24,1989)
G & H LANDFILL FS
-------
SOUTH
A
720-1
AUTOMOBILE
^,^, DISPOSAL YARD ^
700 -
680 -
660 -
o
I
LU
640 -
620 -
600 -
580 -J
NORTH
A'
23 MILE T720
ROAD
GH27
CLINTON-
KALAMAZOO
CANAL
GH44
GH18
UPPER
SAND
UNIT
UPPER
SAND
UNIT
-700
-680
-660
t"
§
-640
-620
I- 600
O
200
HORIZONTAL
SCALE IN FEET
LEGEND ed on tnese
n borings.
it the specific
SILTY SAND water levels
] locations.
FINE SAND Conditions at
MEDIUM-CC
ID
1
"^ UPPER AOL
'^' WATER LEV
(7-24-89)
FIGURE 1-5
GEOLOGIC CROSS SECTION A - A'
G & H LANDFILL FS
-------
GH14A,B,C
North
t
•/' xx":V" ^
;] / j ' •>-•"*"'"• •.
.;."" "' '*' '* *'
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A L01
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APPROXIMATE
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LEGEND
: . ,: : : < < '• - > > '• :• x •: • LANDFILL BOUNDARY
, , , x US EPA SITE FENCE/BOUNDARY
X ""'"•• x * * U.O. tr rt wl I ^ i tl1! v t/DV^wiiL^rtn i
ff
o' GATE
& .-••• .....'• DITCH, STREAM, OR RIVER
<
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. ^ FORMER CONRAIL RAILROAD
j i ; • ""• GRADE AND RIGHT OF WAY
(TRACKS REMOVED)
*•£.
g
BETX 100
(30-31)
MONITORING WELL
BORING (B)
TEST PIT (TP)
TOTAL BENZENE, ETHYLBENZENE
TOLUENE & XYLENES COMPOUND
SAMPLE INTERVAL (FEET)
o
x
o
d
BETX CONCENTRATIONS (MG/KG)
> 10,000
: :
:; ;:;:. 100 TO 10,000
j :./ I :% I 10 T0 100
f .' .' .' .' <1TO10
B B. CROSS SECTION LOCATION
| | (Figure 1-7)
NOTE: The letter "A" has been added to Phase II test
pits to differentiate from Phase III test pits.
FIGURE 1-6
BETX CONCENTRATIONS
IN SUBSURFACE SOIL
G & H LANDFILL FS
-------
Northwest
B
710 —i
700 —H
690 —I
W)
5
LLI
£ 680
I
UJ
670 —I
660 —I
650 —I
TP23
TP13
Southeast
B'
TP12
r— 710
\— 700
h- 690
680 LL
O
I
Ul
— 670
h- 660
'— 650
m
ob
o
LU
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X
0)
HORIZONTAL
SCALE IN FEET
FIGURE 1-7
SOURCE AREA CROSS SECTION B-B'
SHOWING TOTAL BETX CONCENTRATION
G&HLANDFILLFS
-------
AGENCY REVIEW DRAFT
SURFACE SOIL CONTAMINATION
Surface soils on the Phase I Landfill were contaminated with PNAs and PCBs.
Surface soil samples collected from the Phase II and III landfills did not indicate
contamination.
GROUNDWATER CONTAMINATION
The approximate vertical extent of BETX, PNA, and chlorinated VOC contamination
in the groundwater contamination appears to be limited to the base of the refuse and
top of the upper sand unit. The approximate horizontal extent of BETX
contamination is downgradient of Oil Pond No. 1 and the suspected Codisposal Area
(see Figure 1-8). The highest concentrations of chlorinated VOC contamination are
adjacent to the old solvent ponds. Chlorinated VOCs were detected around the sheet
pile wall in the Oil Seep Area and near the Oil Storage Building. PNA groundwater
contamination in the same areas appears to follow the same paths as BETX
migration; but the PNA .contamination covers less area (see Figure 1-8) and is found
in lower concentrations than the BETX contamination.
RESIDENTIAL AND COMMERCIAL WELL SAMPLING
BETX and chlorinated VOC contamination was detected in residential and
commercial well water in the vicinity of the site. The contaminants detected in these
wells are consistent with the type of waste encountered at the site.
SURFACE WATER AND SEDIMENT CONTAMINATION
Separate phase liquids and contaminated groundwater from the Phase I Landfill area
are the source of sediment and surface water contamination in the Oil Seep Area.
BETX and PNA compounds were detected in surface water downgradient of the Oil
Seep Area. Sediment in and downgradient of the Oil Seep Area was contaminated
primarily with PNA compounds.
1-16
-------
North
t
300
APPROXIMATE
SCALE IN FEET
LEGEND
•••••••••«•••• LANDFILL BOUNDARY
X X X X U.S. I
^ GATE
-------
AGENCY REVIEW DRAFT
RISK ASSESSMENT
A risk assessment was performed and presented in the RI to evaluate the potential
risks to public health or the environment under the no-action alternative (i.e., if no
remedial action is taken). The risk assessment identified ways that people or wildlife
could contact contaminants from the site. Potential exposures to contaminants from
existing site uses and possible future uses were evaluated as part of the assessment
process.
Under existing site conditions, onsite chemical exposure can occur by direct contact
with contaminated media or by release of volatile compounds and inhalation by site
visitors. Potential exposure pathways offsite include transport off site, release of
contaminants to the groundwater and exposure through the use of groundwater as a
water supply source, release of volatile compounds from the site and inhalation by
offsite residences. People could be exposed through direct contact with contaminated
water and sediment when engaged in recreational activities in areas adjacent to the
site. People that consume contaminated wildlife could also be exposed. Terrestrial
wildlife could be exposed through direct contact with contaminated media at the site,
and aquatic organisms in the Clinton River or Clinton-Kalamazoo Canal could be
exposed to contaminants migrating from the site to the river and canal.
Carcinogenic health effects are measured by the calculated excess lifetime cancer risk.
The excess lifetime cancer risk is the probability that additional cases of cancer will
be caused by exposure to site contamination, compared to the normal probability of
developing cancer. For example, a one-millionth (1 x 10"6) excess lifetime cancer risk
means that for every million people exposed to a carcinogen over their lifetimes, the
average incidence of cancer will increase by one case.
For the G&H Landfill site, risks from exposure to contaminants having
noncarcinogenic health effects were evaluated by comparing an estimated intake of
contaminant to an intake level representing the threshold or reference dose. The
1-17
-------
AGENCY REVIEW DRAFT
ratio of estimated intake to reference dose is called a hazard index. If the hazard
index exceeds one, it indicates the potential of adverse effects.
The risks from exposure related to the G&H Landfill site are summarized in
Table 1-1. Figure 1-9 identifies the levels of risk in different areas associated with
groundwater at the site. The areas where maximum contaminant levels (MCLs) or
maximum contaminant level goals (MCLGs) are exceeded are outlined in Figure 1-9.
The exposures of greatest concern based on the quantitative risk characterization
include:
• Direct contact with surface soil on the Phase I Landfill
• Direct contact with sediments in the Oil Seep Area
• Ingestion of oil seep water
• Dermal exposure to the oil seep water
• A residential use of onsite groundwater as a drinking water source
Qualitative evaluations were performed for potential exposures to recreational users
of the Clinton River and the Clinton-Kalamazoo Canal. These are potential pathways
that could not be quantitatively evaluated. Their qualitative evaluations conclude that
potential exposure pathways may exist to recreational users of the Clinton River and
to people who consume terrestrial or aquatic wildlife.
GLT959/011.51
1-18
-------
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Table
SUMMARY
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HUMAN HEALT
Site visitors come
sparsely distributed in the
Phase I Landfill.
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direct contact with
surface soils, onsit
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APPROXIMATE
SCALE IN FEET
• LANDFILL BOUNDARY
x x x U.S. EPA SITE FENCE
GATE
DITCH, STREAM, OR RIVER
TRAIL
FORMER CONRAIL RAILROAD
GRADE AND RIGHT OF WAY
(TRACKS REMOVED)
EXCEED MCL OR NON-ZERO MCLG
• FINAL MCL OR MCLG EXCEEDED
O PROPOSED MCL OR MCLG
EXCEEDED
AREA WHERE GW
CONCENTRATIONS
EXCEED MCLs OR NON ZERO
MCLG
2x10'J-
HI = 1.0-
EXCESS LIFETIME CANCER RISK
INGESTION BY AREA OR WELL
HAZARD INDEX
GR13
,-7
FIGURE 1-9
SUMMARY OF RISKS
GROUNDWATER
G & H LANDFILL FS
-------
yO S»SIH WHS SJ19SS9010
-------
AGENCY REVIEW DRAFT
Chapter 2
REMEDIAL GOALS
This chapter presents general and site-specific goals for the site. General remedial
goals are defined by the NCP and CERCLA (as amended by SARA) and are
applicable to all Superfund sites. These goals relate to the statutory requirements for
development of the remedy. Site-specific goals relate to specific contaminated media,
such as groundwater and soil, and potential exposure routes; they also identify target
remediation areas and concentrations. Site-specific goals require an understanding of
the contaminants in their respective media and are based on the risk to the public
health and the environment and applicable or relevant and appropriate requirements
(ARARs). These goals are as specific as possible without limiting the range of
alternatives that can be developed for detailed analysis.
NCP AND CERCLA GOALS
The NCP states "The national goal of the remedy selection process is to select
remedies that are protective of human health and the environment, that maintain
protection over time, and that minimize untreated waste" (40 CFR 300.430).
The statutory scope of CERCLA was amended by SARA to include the following:
• Refinement of the objectives for the degree of remedial action cleanup
in that remedial actions "shall obtain a degree of cleanup of hazardous
substances, pollutants, and contaminants released into the environment
and of control of further releases at a minimum which assures
protection of human health and the environment" (Section 121 (d)).
• Preference for the selection of remedial actions "in which treatment
that permanently and significantly reduces the volume, toxicity, or
2-1
-------
AGENCY REVIEW DRAFT
mobility of the hazardous substances, pollutants, and contaminants is a
principal element" (Section 121(b)). An explanation must be published
if a permanent solution using treatment or recovery technologies is not
selected.
• Requirements that the selected remedy comply with or attain the level
of any "standard, requirement, criteria, or limitation under any Federal
environmental law or any promulgated standard, requirement, criteria,
or limitation under a State environmental or facility siting law that is
more stringent than any Federal Standard, requirement, criteria, or
limitation" (Section 121(d)(2)(A)).
These constitute the general goals for remedial action at all CERCLA sites.
REMEDIAL GOALS FOR THE G&H LANDFILL SITE
The following goals were selected by the EPA for the G&H Landfill site based on
identified contaminants, estimated risks, and migration pathways:
• Prevent direct contact with contaminated media: soil, sediment, landfill
contents, groundwater, leachate, oil seeps, and surface water
• Control leaching of hazardous substances from the landfill contents and
oil-saturated soil to groundwater
• Control or reduce the volume of contaminated groundwater to prevent
ingestion of groundwater with contaminants that exceed the MCLs,
exceed non-zero MCLGs, have total excess lifetime cancer risks of
1 x 10"4 to 1 x 10"6, or have a hazard index that exceeds 1
2-2
-------
AGENCY REVIEW DRAFT
• Control migration of separate phase liquids (oils) containing hazardous
substances
• Provide remedies that allow eventual achievement of groundwater
standards that are applicable or relevant and appropriate
• Prevent release of groundwater contaminants at concentrations that
would exceed cause surface water concentration limits for protecting
aquatic life in the Clinton River or nearby wetlands
• Reduce or contain the volume or mass of contaminated source
materials: soil, landfill contents, buried waste oils, and other buried
wastes
• Minimize long-term site management and maintenance requirements
The above goals are generally listed in order of increasing complexity and are
interdependent. For example, controlling or reducing the volume of contaminated
groundwater will help to control migration of contaminants in soil, leachate, and oil.
Controlling groundwater will also limit future surface water and sediment
contamination. Reducing the mass of contaminated source materials may reduce the
volume of groundwater that would need to be treated and may reduce long-term site
management needs.
OPERABLE UNITS FOR THE G&H LANDFILL SITE
Operable units are defined as environmental media or site areas that can be
evaluated or treated separately. Two operable units are proposed for the G&H
Landfill site:
2-3
-------
AGENCY REVIEW DRAFT
• Soil, sediment, and landfill contents
• Groundwater, leachate, and oil
The two operable units are based on the stated goals and the types of remedial
actions and construction activities that would be associated with each unit. The soil-
sediment-landfill contents operable unit consists primarily of solid material that would
probably be handled by earthwork for grading and capping, or excavating and staging
for disposal or treatment. The groundwater-leachate-oil operable unit, which consists
of liquids, would probably be controlled using hydraulic collectors and barriers like
extraction wells, pumps, cutoff trenches, and slurry walls. For the purposes of this FS,
the term "oil" is used to describe separate phase non-aqueous liquids. Contaminated
liquids could then be contained and collected for treatment.
Surface water contamination around the G&H Landfill site is primarily the direct
result of contaminants migrating in groundwater and discharging at the oil and
leachate seeps; therefore, surface water is considered part of the groundwater-
leachate-oil operable unit.
Landfill gas is a byproduct of the landfill contents, and any action to vent or control
gas emissions will depend upon actions implemented to control or reduce releases to
groundwater. Landfill gas will be considered part of the soil-sediment-landfill
contents operable unit, and remedial actions involving gas will be included with this
operable unit.
POTENTIAL ARARS FOR THE G&H LANDFILL SITE
This section presents the standards, requirements, criteria, and limitations under
federal and state environmental laws, and regulations that may be applicable or
relevant and appropriate requirements under CERCLA for remedial action at the
site. ARARs guide the identification of general response actions and evaluation of
the applicability of some technologies and process options.
2-4
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AGENCY REVIEW DRAFT
According to EPA interim guidance for compliance with ARAR determination:
"Applicable requirements" means those cleanup standards, standards of
control, and other substantive environmental protection requirements,
criteria, or limitations promulgated under Federal or State law that
specifically address a hazardous substance, pollutant, contaminant,
remedial action, location, or other circumstance at a CERCLA site. . . .
"Relevant and appropriate requirements" means those cleanup
standards, standards of control, and other substantive environmental
protection requirements, criteria, or limitations promulgated under
Federal or State law that, while not "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site, address problems or situations
sufficiently similar to those encountered at the CERCLA site that their
use is well suited to the particular site (U.S. EPA 1987).
Applicable implies that the jurisdictional prerequisites of a requirement are satisfied
by a circumstance of the site or a remedial action. Relevance and appropriateness
can be judged by comparing the characteristics of the remedial action, the hazardous
substances in question, or the physical circumstances at the site to those addressed by
a requirement and the origin and objective of the requirement. For example, while
RCRA regulations are not applicable to closing undisturbed hazardous waste in place,
the RCRA requirement for closure by capping may be deemed relevant and
appropriate.
Relevant and appropriate requirements must be complied with to the same degree as
applicable requirements. However, there is more discretion in the determination of
relevance and appropriateness. It is possible for only part of a requirement to be
considered relevant and appropriate and for the rest to be dismissed. Furthermore,
some requirements may be considered relevant, but judged to be not appropriate.
Nonpromulgated advisories, policies, or guidance issued by federal or state agencies
do not have ARAR status; however, they may be considered by the EPA while
2-5
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AGENCY REVIEW DRAFT
determining necessary cleanup levels for the protection of public health and the
environment.
Potential ARARs and other advisories to be considered for the G&H Landfill site are
listed in Table 2-1. ARARs are identified in three classes: chemical-specific,
location-specific, and action-specific. How the potential ARARs in Table 2-1 apply or
are classified for the site is described in the comments column for each law,
regulation, or standard listed. The list of ARARs will be further refined after specific
technologies have been identified. Key issues for developing remedial actions are
discussed below.
CHEMICAL-SPECIFIC ARARS
Chemical-specific ARARs include laws and requirements that regulate the release to
the environment of specific substances having certain chemical or physical
characteristics or materials containing specified chemical compounds. They are
important in determining the extent of remediation as well as determining the
residual levels of contaminants allowable after treatment. The Safe Drinking Water
Act (40 CFR 141) is an example of a chemical-specific ARAR.
LOCATION-SPECIFIC ARARS
Location-specific ARARs relate to the geographic position of the site and
surrounding areas. There are several location-specific ARARs that may be applicable
to remedial action at the site. For example, areas along the west side of the Phase III
landfill are located within the 100-year flood plain of the Clinton River.
Requirements of RCRA—40 CFR 264.18(b) and Executive Order 11988, Protection
of Flood Plains, may be applicable. The main requirements are to prevent erosion
and minimize the effects on flood plain hydraulics.
2-6
-------
d
£
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3
Table 2-1 (Page 1 of 9)
POTENTIAL ARARs FOR THE G&H I
Revised 11/2/89
Comment
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1
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generated in the course of remedial action.
Regulates the construction, design, monitoring
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ties. Administered by MDNR under Act 64.
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Table 2-1 (Page 5 of 9)
POTENTIAL ARARs FOR THE G&]
Revised 11/2/89
Comment
Description
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closure (Subtitle C or Subtitle
t« h
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RCRA in the state under this act.
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Table 2-1 (Page 7 of 9)
POTENTIAL ARARs FOR THE G&H L/
Revised 11/2/89
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Table 2-1 (Page 8 of 9)
POTENTIAL ARARs FOR THE G&H LAN
Revised 11/2/89
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-------
AGENCY REVIEW DRAFT
ACTION-SPECIFIC ARARS
Action-specific ARARs define treatment and disposal procedures for hazardous
substances, and control construction activities to limit potential releases of hazardous
substances to the environment during remedial action work. The following are
examples of key action-specific ARARs:
RCRA, Subtitle D (Solid Waste)
RCRA, Subtitle D may be considered relevant and appropriate because the
G&H Landfill site operated from 1967 to 1973 as the Shelby Township dump under a
State of Michigan license. RCRA, Subtitle D may be relevant and appropriate for
the Phase II and III Landfill areas because there is no documented disposal of RCRA
hazardous wastes.
RCRA, Subtitle C (Hazardous Waste)
RCRA, Subtitle C may be relevant and appropriate for the Phase I Landfill area and
the oil seep caused by activities in the Phase I area. It may also be relevant and
appropriate for "hot spots" in the Phase II and III Landfill areas. An example "hot
spot" is the leachate seep located at the south end of the Phase III Landfill.
Hybrid Closure, Proposed Standard (March 1987)
The Proposed Amendments for Landfills, Surface Impoundments, and Waste Piles:
40 CFR Parts 264, 265, and 270 dated March 19, 1987 (Hybrid Closure Rule) will
need to be considered for site actions involving the removal and treatment of some
wastes while leaving others in place. Wastes could be left in place if exposure
pathways are controlled so that the wastes pose no threat to human health or the
environment. Some RCRA design features may be excluded if hybrid closure actions
would restrict exposure pathways in ways comparable to a RCRA action.
2-7
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AGENCY REVIEW DRAFT
Land Disposal Restrictions
Land disposal restrictions (40 CFR 268) prohibit land disposal of certain wastes
unless contaminants in the Toxicity Characteristic Leaching Procedure (TCLP) extract
are below the concentrations listed in 40 CFR 261. Land disposal of nonliquids is
also prohibited if they contain halogenated organic compounds (HOCs) in
concentrations greater than 1,000 mg/kg (California list wastes). Incineration is
required for these wastes. Treatment standards to be met prior to land disposal have
not yet been developed for ignitable hazardous wastes. Rendering the waste
nonignitable may suffice.
GLT959/001.51
2-8
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AGENCY REVIEW DRAFT
Chapter 3
ALTERNATIVES ARRAY
This chapter presents the results of the development and initial evaluation of a range
of remedial action alternatives. This effort uses and adds to the Alternatives Array
Memorandum (EPA January 1990), which was prepared while RI work was in
progress. The Alternatives Array Memorandum presented a range of potential
alternatives and a preliminary evaluation of them based on their ability to achieve
remedial goals, meet ARARs, and their implementability.
This chapter reduces the number of alternative actions that will be analyzed in detail
while preserving a range of choices. This was done to focus the effort of analyzing
and screening remedial technologies on fewer remedial actions, thereby reducing that
effort and more efficiently arriving at feasible alternative actions. This is consistent
with the streamlined approach to developing and screening alternatives described in
the NCP [(FR8702) CFR 300.430(a)(l)].
Those alternatives which survive the initial evaluation in this chapter will be analyzed
in detail in Chapter 5. The array of alternatives was developed by:
• Identifying general response actions that could achieve the remedial
goals for the two operable units
• Combining general response actions in various ways to develop a range
of potential remedial action alternatives
• Evaluating the relative effectiveness, implementability, and costs of the
potential remedial action alternatives
3-1
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AGENCY REVIEW DRAFT
GENERAL RESPONSE ACTIONS
General response actions satisfy remedial goals (see Chapter 2) by either reducing
contaminant levels, controlling releases and migration of contaminants, or reducing
the likelihood of contact with existing contaminants. The following response actions
were identified for the two operable units selected for the site:
• No Action
• Institutional Controls
• Containment
• Removal
• Treatment
• Disposal
RANGE OF ALTERNATIVES
The range of alternatives must satisfy the requirements of the NCP (300.430(e)), and
include at a minimum:
• A no-action alternative
• At least one alternative that provides containment of the waste with
little or no treatment, but protects human health by preventing potential
exposure or reducing the mobility of the contaminants in the waste
• An alternative that would eliminate the need or significantly reduce the
need for long-term management at the site
• At least one alternative that would use treatment as a principal element
to reduce toxicity, mobility, or volume of the contaminants
3-2
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AGENCY REVIEW DRAFT
Preliminary remedial alternatives were developed by combining general response
actions in various ways (see Figure 3-1).
INITIAL EVALUATION OF ALTERNATIVES
The initial evaluation of alternatives assesses an alternative's strengths or weaknesses
relative to others. The primary focus is to identify those alternatives that are "not
effective, not implementable, or whose costs are grossly excessive for the effectiveness
they provide" [(FR8714) CFR 300.430(e)].
The NCP defines the three initial evaluation criteria as follows:
• Effectiveness—An alternative's overall performance in eliminating,
reducing, or controlling the current and potential risks posed by the site,
both during implementation and over time
• Implementability—The degree of difficulty associated with construction
of the alternative, including technical, administrative, and logistical
problems that affect the time necessary to complete the remedy
• Cost—Construction costs and the costs of operating and maintaining
the remedy over time
The initial evaluation of potential alternatives is presented in Table 3-1. A brief
description, the rationale for their development, and overall assessment of the
alternatives are provided below.
3-3
-------
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Alt. 2 components as above.
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established technology. Would require impi
quantities of soil to the site for a low-permeal
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Minimizes public health risks associated with
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tenance.
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Contaminants below the groundwater table
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te, size re- of treatment (e.g., immobilization
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Capital cost: S250M to $800M
sment for based on contaminated volume
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associated with identification of "hotspc
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duction, and other physical activities needed
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-------
AGENCY REVIEW DRAFT
ALTERNATIVE 1—NO ACTION
Under the no action alternative, no further action would be taken onsite. The public
health and environmental risks identified in the risk assessment would continue to
exist, and there would be no reduction of toxicity, mobility, or volume of site
contamination.
This alternative was developed because it is required by the NCP to be used as a
baseline for comparison to other alternatives. It will be evaluated further in
Chapter 5.
ALTERNATIVE 2—INSTITUTIONAL CONTROLS
Institutional controls are response actions that involve legal property and groundwater
use restrictions, alternative water supplies, and monitoring site related contaminants.
Alternative 2 would include:
• Periodic inspection and maintenance of the existing perimeter fence
• Deed restrictions on future land and groundwater use
• Periodic monitoring of groundwater and seeps that could trigger
additional actions
• Periodic monitoring of commercial and residential water supply wells or
installing connections to municipal water in the area along Ryan Road
where wells have been contaminated or could be contaminated in the
future
Under this alternative, public health would be protected by controlling direct access
to onsite contaminants. The public health would be protected by providing
3-4
-------
AGENCY REVIEW DRAFT
alternative water supplies. The environmental risks identified in the risk assessment
would remain. There would be no reduction in the toxicity, mobility, or volume of
site contamination.
This alternative was developed to provide a relatively low cost, easily implemented
alternative that provides some protection of public health. Because of the importance
of access restrictions and continued monitoring at the site, this alternative will be
evaluated further, primarily to determine an adequate scope of monitoring. The
components of this alternative will be included with all remaining alternatives;
however, monitoring requirements will change from one alternative to the next
depending on the degree of protection and corresponding reduction in long-term site
management provided by each alternative.
ALTERNATIVES 3A AND 3B—CONTAINMENT
In addition to the components of Alternative 2, Alternatives 3A and 3B would
include:
• 3A—grading or capping the Phase I, II, and III Landfills
• 3B—3A plus installing vertical barriers (e.g. slurry walls) around buried
landfill waste
Under these alternatives, the reduction in public health risks would be greater than
the reduction under Alternative 2 because the likelihood of direct contact with site
contamination would be reduced. Environmental risks would be reduced further by
limiting the leaching of contaminants from buried waste to groundwater and
subsequently offsite. There would be no reduction of the toxicity or volume of site
contamination.
Alternatives 3A and 3B were developed to provide a containment alternative as
required by potential ARARs and to provide a relatively low cost and easily
3-5
-------
AGENCY REVIEW DRAFT
implemented alternative that limits contaminant migration. Containment technologies
will be evaluated in Chapter 4 by:
• Comparing the effectiveness of site grading, single layer caps, and
multilayer caps
• Comparing the effectiveness of the types of vertical barriers and their
locations to the effectiveness of containing site contamination
ALTERNATIVES 4A AND 4B—GROUNDWATER TREATMENT
The components of Alternative 3B would be included as part of this alternative,
however, the details of containment (i.e., grading plans, type of cover, location of
vertical barriers) would likely be modified to enhance the collection of groundwater
and liquid wastes. In addition to these components, Alternatives 4A or 4B would
include:
• 4A—a groundwater extraction system and an onsite treatment plant or
discharge to a publicly owned treatment works (POTW)
• 4B—4A (with modification of the containment system) plus enhanced
recovery or in situ treatment of oily waste and soil, such as an injection
system to flush contaminants from high concentration source areas or
in situ biological treatment
Under these alternatives, public health and the environment would be protected more
than by Alternatives 3A and 3B because the toxicity or volume of hazardous
substances would be reduced by treatment of groundwater and control of migration of
contaminated groundwater.
Alternatives 4A and 4B were developed to provide alternatives of moderate relative
cost that include more control of contaminant migration and groundwater treatment.
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These alternatives will be further evaluated in Chapter 5. The technology screenings
and evaluations in Chapter 4 will focus primarily on the effectiveness of:
• Containment and groundwater collection components and their location
for recovery of contaminated groundwater
• Treatment and disposal options to remove contaminants from
groundwater
• In situ methods for collecting or treating oil-contaminated waste or soil
ALTERNATIVES 5A AND SB—SOURCE REMOVAL
In addition to the components of Alternative 4A, Alternatives 5A and 5B would
include:
• 5A—removal of identified hazardous substance source areas or
"hotspots" (Figure 3-2) and disposal onsite in a RCRA landfill cell
• 5B—removal of all landfill materials and disposal onsite in a RCRA
landfill cell
Hotspots are shown in Figure 3-2. These areas were identified using physical and
chemical data obtained from test pits and borings during the RI. Because of the
heterogeneous nature of the landfills and the inherent limitations of the RI, it is likely
that the actual extent of hotspots in the landfill differ from those shown. The
estimated volume of landfill waste in the hotspots is about 800,000 cubic yards.
Offsite disposal of waste was not included in the alternatives for the following
reasons:
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• Licensed RCRA facilities located within 200 miles of the site do not
have the capacity to accommodate the volume of waste that would be
generated by removal of material from the hotspots.
• Disposal of waste would require treatment or a treatability variance
under the RCRA Land Disposal Restrictions described in Chapter 2. A
variance could be difficult to justify or obtain for waste that fails to
meet TCLP regulated limits under 40 CFR 261.
• The transport of large quantities of waste would impose an accident
risk. About 52,000, 20-ton trucks would be needed to transport the
800,000 cubic yards to RCRA facilities located from 50 to 500 miles
from the site.
Under the source removal alternatives, public health and the environment would be
protected more than by Alternatives 4A and 4B because contaminant sources would
be placed in RCRA-compliant landfill cells. This would reduce the potential for
migration of contaminants. The toxicity and volume of contamination would not be
reduced, except for groundwater treatment.
Alternatives 5A and 5B were developed to provide additional protection against
groundwater contamination and contaminant migration. The benefit of additional
protection is offset by the alternatives' high cost and difficult implementation. Under
both alternatives, the groundwater treatment would be required for a time period that
cannot be accurately estimated. Both alternatives would require long-term monitoring
of the site.
Alternatives 5A and 5B will not be evaluated further; rather, another set of
alternatives that incorporates treatment of the removed wastes has been included in
the alternatives array. Under these new alternatives (6A and 6B), the concepts of
removal and disposal of waste will be evaluated.
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ALTERNATIVES 6A AND 6B—SOURCE REMOVAL AND TREATMENT
In addition to the components of Alternative 4A, Alternatives 6A and 6B would
include:
• 6A—removal and treatment of materials from identified hazardous
substance source areas "hotspots" (Figure 3-2) and disposal onsite in a
RCRA landfill cell
• 6B—removal and treatment of all landfill materials and disposal onsite
in a RCRA landfill cell
Under the source removal and treatment alternatives, public health and the
environment may be protected more than by Alternative 4A because the toxicity,
mobility, and volume of site contamination would be reduced. It is possible that the
removal of some hazardous substances may leave enough contaminants behind such
that the remaining risks are not changed. In this case, reducing the toxicity, mobility,
and volume does not necessarily increase protectiveness. This may also be true for
Alternative 6B, if all the landfill contents are removed, treated, and placed in an
RCRA type landfill and oil or separate phase solvents remain below the water table
to act as continuing sources of hazardous substances.
Alternatives 6A and 6B were developed to provide additional protection of public
health and the environment by treatment of contaminant sources. Both alternatives
would require the components of Alternative 4A for an indefinite time period that
cannot be accurately estimated. Alternative 6B may reduce to a greater extent, but
not eliminate, the need for maintenance or monitoring at the site.
Both alternatives would be very costly and difficult to implement. Both pose risks to
workers and potential risk to the public if airborne releases occur. Alternative 6A
will be evaluated further to meet the requirement of reducing potential future site
management. Technology screening will focus primarily on the effectiveness of
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various types of treatment. Alternative 6B will be eliminated from further
consideration because of potential risks during construction and the higher cost,
estimated to range from $800 million to $2.6 billion (Table 3-1), compared to the
effectiveness provided.
GLT959/003.51
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Chapter 4
TECHNOLOGY SCREENING AND DEVELOPMENT
This chapter presents the results of the development and evaluation of a range of
remedial technologies for each general response action. The goal was to develop a
list of feasible technologies that could be incorporated into the range of preliminary
alternatives developed in Chapter 3. The technology development process consisted
of two steps:
• Identifying specific technologies and process options that may achieve
the purpose of each general response action identified in Chapter 3.
This step, referred to as initial technology screening, identifies
potentially applicable technologies and eliminates technologies and
process options that are clearly not compatible with site conditions.
• Screening the potentially applicable technologies and process options on
the bases of their effectiveness, implementability, and relative cost. This
step, referred to as detailed screening of technologies, reduces the
number of technologies to be retained for remedial alternatives.
INITIAL TECHNOLOGY DEVELOPMENT
Identified in Chapter 3 were general response actions that satisfy the remedial goals
outlined in Chapter 2, by reducing either contaminant levels or the likelihood of
contact with existing contaminants. Actions included treatment, disposal,
containment, excavation and removal, and institutional controls. Although some
response actions may meet the goals alone, combinations of response actions may
meet the goals more effectively.
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During the initial technology development and screening, specific technologies were
listed by operable unit for each response action. For instance, biological and physical
treatment are two possible groundwater treatment technologies. Each technology
may have several process options. Process options refer to the specific material,
equipment, or method used to implement a technology. For example, air stripping is
a process option of the physical treatment technology for groundwater.
During the initial phase of technology screening, process options were screened on
the basis of their compatibility with characteristics of the site and contaminants.
During the initial screening, process options were addressed independently and
without considering the potential disadvantages when applied in combination. Process
options clearly unworkable or inappropriate for the site were eliminated. Process
options remaining after the initial screening were evaluated further during the second
screening. The initial technology screening step for the G&H Landfill site is
documented in Appendix A. Initial technology screening results are summarized in
Table 4-1.
DETAILED TECHNOLOGY SCREENING AND EVALUATION
Incorporating all technologies and process options that survive initial screening into
detailed alternatives would result in a cumbersome number of combinations. To keep
the number of combinations manageable, technologies that survived initial screening
were reevaluated based on their effectiveness, implementability, and relative cost. In
cases where several process options have similar evaluations, a single process option
considered representative for the technology was selected. Identifying a
representative process option for each technology was not intended to limit the
process options that could be employed in the remedial design or action, but to
provide a basis for comparing a manageable number of alternatives.
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DETAILED SCREENING CRITERIA
During detailed screening, emphasis is placed on implementability and effectiveness.
Cost is used in cases where the evaluation of the first two criteria did not result in
excluding a process option or technology. The analyses performed to evaluate the
technologies and process options in terms of the detailed criteria are documented in
Appendixes B, C, and D.
Implementability
Implementability is evaluated in terms of technical and institutional feasibility.
Implementability issues include:
• Compliance with preliminary location, action-specific and chemical
specific ARARs
• Availability and capacity of offsite treatment, storage, and disposal
services
• Constructibility with respect to site conditions
• Time required to implement the process option and achieve beneficial
results
Effectiveness
Process options associated with a technology are evaluated on the basis of their
effectiveness in protecting human health and the environment and in satisfying one or
more of the remedial objectives. Effectiveness pertains to:
• The reliability and performance with respect to contaminated media
and site conditions
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• The ability of a process option to handle the estimated areas or
volumes of contaminated media and to prevent or minimize the release
of hazardous substances
• The degree of protection of human health and the environment during
construction and operation
Relative Cost
Cost screening considered general capital, and operation and maintenance costs for
technology options but did not develop site-specific, detailed cost estimates. Process
options were eliminated from further consideration if the relative cost was considered
to be significantly higher, while relative effectiveness or implementability was not
significantly different.
DETAILED SCREENING RESULTS BY GENERAL RESPONSE ACTION
Institutional Controls and Monitoring
Access Restrictions. Access restrictions include restrictive covenants on the landfill
property deed to prevent site use or development and to restrict vehicular access to
the site. Deed restrictions notify any potential purchaser that the land was used for
waste disposal. Land use is restricted to ensure the maintenance and integrity of the
waste containment systems. Vehicular access to the landfill areas could be restricted
by maintaining the existing site fence and locking gates at entrances or other potential
access points.
Access restrictions reduce the likelihood of exposure through trespassing, future
development, or excavation at the site. The effectiveness of access restrictions
depends upon continued enforcement and maintenance. They are subject to changes
in political jurisdiction, legal interpretations, and regulatory enforcement. Access
restrictions can provide low-cost protection against uncontrolled direct contact with
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the landfill contents, but these restrictions alone may not be effective for long-term
protection of human health and the environment. A variety of access restrictions may
be required to effectively implement other technologies and will be retained for that
purpose.
Use Restrictions. Groundwater use restrictions are a low-cost and readily
implementable way to limit exposure to contaminants. Some, such as aquifer use
restrictions are voluntary and are not enforceable. The restrictions would prohibit the
use and installation of production wells in all potentially contaminated areas.
Groundwater use restrictions are subject to differing legal interpretations and
changing political jurisdictions. Thus they may have limited long-term effectiveness,
but are retained for use in detailed alternatives.
Monitoring. Groundwater monitoring can be used to evaluate the effectiveness of
remedial actions in controlling releases from the site. It is also necessary for effective
enforcement of institutional controls such as groundwater use restrictions. Monitoring
is also part of the regulatory requirements for the closure of solid and hazardous
waste landfills and is used to determine the need for additional actions. Thus, it is
retained for the detailed alternatives.
Alternative Water Supplies. The MDNR currently estimates that 50 to
60 commercial and residential water supply wells are being operated in the area east
of the site along Ryan Road. The MDNR and U.S. EPA have monitored both
commercial and residential wells in this area over the past 5 years. The MDNR has
also supplied bottled drinking water to the commercial establishments with
contaminated wells along Ryan Road, over the same time period.
Municipal water lines exist at the site. The cost to connect 60 businesses and
residences to the water main would be about $90,000. The annual cost of quarterly
monitoring of 60 wells for VOCs and supplying bottled water to five businesses and
residences would be about $120,000. The cost for one year of residential and
commercial well monitoring would exceed the cost of constructing connections,
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therefore the option of supplying municipal water for both wells currently affected
and wells potentially affected by site contamination in the future will be retained for
incorporation into alternatives to reduce long-term groundwater monitoring costs.
Containment
Containment technologies that survived initial screening (Table 4-1) are:
• Surface controls
• Soil cover
• Single layer cap
• Multilayer cap
• Vertical barriers
The containment technologies were separated into two groups, before the detailed
analysis presented in Appendix B was performed. The two groups were selected
because they help to achieve remedial goals in two ways:
• Caps and covers prevent direct contact with and limit percolation
through the landfill contents and contaminated soil.
• Vertical barriers limit lateral groundwater flow through and control
leaching of hazardous substances from the oil saturated soil and landfill
contents.
Caps and Covers. Cap and cover technologies include surface controls, soil covers,
single layer, and multilayer caps. The effectiveness of capping and cover technologies
was evaluated against current site conditions using the water balance method to
estimate quantities of generated leachate (Appendix B). The implementability of
caps and covers was evaluated based primarily on the ability of options to meet either
RCRA Subtitle C or D landfill closure regulations.
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Surface controls would consist of grading, vegetation, and surface water diversion.
These activities are intended to promote surface water runoff and minimize erosion.
Surface controls are needed at the site, because the current landfill covers do not
promote runoff or prevent erosion. Surface controls would be required for all
capping and cover options, however they will not be considered alone for the
following reasons:
• Existing landfill covers are too thin to meet minimum RCRA Subtitle D
closure regulations as enforced by the MDNR.
• Existing covers cannot be adequately sloped (2 to 3 percent) by
reshaping existing cover material.
• The Phase I Landfill is covered by material that is too sandy to limit
infiltration and is contaminated by PCBs and pesticides.
A soil cover or single layer cap would consist of grading the site to promote runoff
and minimize erosion. Imported soil would be used. A soil cover or single layer cap
would meet RCRA Subtitle D closure requirements if the imported soil is classified as
a cohesive or fine grained soil (ML, SC, CL, or CH) as defined by the Unified Soil
Classification System (USCS), is a minimum of 2 feet thick, and if the cover is graded
to 2 percent minimum slopes (State of Michigan Solid Waste Rules R 299.4305).
This soil cover and single layer cap combination is estimated to reduce percolation
through the landfill contents by about 60 percent (Appendix B). This combination
can also be designed to meet Michigan solid waste rules for RCRA Subtitle D closure
and is therefore retained for incorporation into detailed alternatives.
Multilayer caps consist of a low permeability barrier layer covered with other layers
serving various functions. Three multilayer cap options were evaluated and
conceptual sections are shown in Appendix B. Of the three options, the soil-drain-
Flexible Membrane Liner (FML) cap would not meet the Michigan State Hazardous
Waste Rules R 299.9619 for the RCRA Subtitle C closure requirement of a 3-foot
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thick layer of compacted clay. The effectiveness of the FML acting as a single barrier
layer is difficult to predict and the long-term reliability is unknown, therefore the soil-
drain-FML option is not retained.
The other two options, the soil-clay cap and the soil-drain-composite cap are proven
to be effective and estimated to reduce current site percolation by 80 and 95 percent
respectively (Appendix B). Both options can be designed to meet the minimum
RCRA Subtitle C closure requirements as enforced by the MDNR (R 299.9619).
These options are carried forward to be incorporated into assembled alternatives.
The soil-drain-composite cap also meets current EPA guidance for design of RCRA
hazardous waste disposal facilities (EPA, 1989). This cap option is costly to construct
and maintain compared to the soil-clay cap. Maintaining the drainage and FML
layers at an the G&H landfill site where settlement is expected may be difficult. The
current EPA guidance is primarily intended for permitting new RCRA facilities and
may not be as useful for containing old, uncontrolled landfills in place.
The steep slopes along the western side of the Phase III Landfill will also require
special measures to establish vegetation and prevent erosion for all capping and cover
options. The Michigan Subtitle D requirement of 1-vertical to 4-horizontal maximum
slope could not be met without adding material to the toe or cutting material from
the top of the slope. These actions would cause further encroachment on the flood
plain and destruction of the wetlands or require handling landfill refuse. The current
1-vertical to 2-horizontal maximum slopes could be stabilized by stapling or nailing
erosion control mats before seeding. This would allow a vegetative cover to be
established and meet the intent of Rule R 299.4305 by minimizing erosion and
maintenance.
Leachate seeps occur along the toe of the Phase III Landfill and may damage a cap.
A toe collector drain could be installed to collect leachate and protect the slope by
preventing seepage through the cap. The toe drain could be used to divert the
leachate for collection and treatment.
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Vertical Barriers. Three vertical barrier options were retained after initial screening:
• Slurry walls are constructed by excavating a trench which is kept filled
with a bentonite slurry. The slurry provides temporary stabilization of
the trench walls. The trench is backfilled using a mixture of soil-
bentonite or soil-cement-bentonite.
• Vibrating beam walls are constructed by advancing a vibrating steel
beam into the ground and injecting a bentonite or bentonite-cement
slurry as the beam is withdrawn. The wall is constructed by successive
placement of sections side-by-side.
• Grout curtains are constructed by temporarily installing vertical pipes in
the ground and injecting a bentonite-cement grout through them. The
grouted holes are typically staggered with a three row deep spacing in
an attempt to ensure continuity.
Slurry walls are considered to be the most effective of the three. Reported in-place
permeabilities of slurry walls range from 10"9 to 10~5 centimeters per second (cm/sec).
The effectiveness of vibrating beam walls and grout curtains is questionable because it
is difficult to achieve continuity of the barrier. Vibrating beam walls and grout
curtains have limited performance records, while slurry walls have been effectively
used at other hazardous waste sites. All vertical barriers will have to be designed
using a slurry or grout mixture that minimizes degradation caused by site
contaminants, especially the separate phase oil and liquids found immediately
downgradient from the landfill sources and Oil Seep Area.
The implementability of the three options is similar. The relative cost varies from low
for vibrating beam walls, medium for slurry walls, to high for grout curtains. Based
on proven effectiveness and mid-range cost, slurry walls are carried forward as the
representative vertical barrier option for the site. Grout curtains may be applicable
for short horizontal segments of the vertical barrier where sewer and water pipelines
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cross the alignment. Additional methods to isolate these pipelines should be
considered in the future based on results of studies being performed by the Detroit
Metropolitan Water and Sewer District.
The effectiveness of a slurry wall or any vertical barrier is determined in large part by
its vertical and horizontal alignment. In the G&H landfill areas, a low permeability
silt or silty-clay layer exists at a depth of 20 to 45 feet below ground surface, except
along the toe of the Phase III Landfill where the silt layer is near the ground surface.
This relatively shallow depth makes constructing a wall keyed into the underlying silt
layer feasible and helps to achieve the containment goal of minimizing long-term
management costs by lowering the quantity of contaminated groundwater that would
require removal and treatment. For this reason, only vertical walls keyed into the
underlying silt will be considered at the site.
Three horizontal alignments were considered for the landfill walls (Appendix B); an
upgradient wall, a downgradient wall, and a circumferential wall. An upgradient wall
would be used to divert uncontaminated groundwater around the site source areas.
This type of wall is only effective at sites where steep gradients occur, allowing gravity
drainage to a lower elevation. The relatively flat hydraulic gradients at the site would
make an upgradient wall ineffective without excessive pumping downgradient from
the wall. A downgradient wall would contain contaminated groundwater from
discharging to the Clinton River valley, however excessive pumping would also be
needed for it to be effective and prevent overtopping.
Only a circumferential alignment would achieve the site remedial goals of controlling
leaching of hazardous substances from the landfill contents and oil-saturated soil, and
reducing the volume of groundwater requiring pumping to lower long-term site
management costs. An alignment was selected to bound the north, south and east
sides of the landfill area and include the Oil Seep Area to effectively seal off these
source areas from the upper aquifer. The selected alignment, shown in Appendix B,
excludes the west side of the Phase III Landfill where the underlying silt outcrops at
the ground surface.
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The wall alignment would require gradient control wells within the circumference to
prevent over topping and maintain groundwater flow into the wall. Gradient control
wells within the alignment also help to increase the wall's reliability by decreasing the
potential for chemical degradation of the barrier. The gradient control wells
combined with the circumferential wall should also reduce the leachate seepage along
the toe of the Phase III Landfill, possibly eliminating the need for a toe drain
collector. Groundwater levels upgradient from the wall, along 23 Mile Road, would
likely rise and diversion or control measures may be needed.
The largest source of water moving through the waste materials in the landfills is
infiltration through the existing covers rather than lateral groundwater flow in the
saturated zone (Appendix B). For this reason, vertical barriers alone would not
greatly reduce groundwater extraction and treatment requirements. Landfill caps in
conjunction with vertical barriers could greatly reduce groundwater extraction costs
and provide an effective site containment system, therefore vertical barriers will only
be considered in combination with caps in assembled alternatives.
Removal
Removal technologies are grouped by the two operable units for detailed screening
and evaluation. The groundwater-leachate-oil removal technologies primarily involve
collecting, handling, and routing of liquids. The soil-sediment-landfill contents
removal technologies involve physical excavation and handling of mostly solid
materials.
Groundwater-Leachate-Oil Removal. Two technologies for this operable unit were
carried through initial screening; groundwater removal using either wells or drains and
enhanced oil recovery (EOR) or soil flushing. Wells or pipe and media drains are
commonly used to collect groundwater. EOR and soil flushing are unproven or
experimental techniques that would also require wells or drains to inject soil washing
agents and collect the emulsions. Both technologies would require further handling
and treatment of extracted liquids.
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Extraction wells or horizontal pipe and media drains placed in trenches are effective
options for collecting contaminated liquids at the site. Both options will be carried
forward for incorporation into alternatives. Generally wells are less costly and easier
to implement. Wells also offer flexibility by allowing either adding or abandoning
wells as the plume configuration changes with extraction time. Wells will be used as
the primary method of groundwater, leachate, and oil removal in the assembled
alternatives. The best site application for a horizontal pipe and media drain would be
along the toe of the Phase III Landfill to collect leachate, as described with the
containment technologies.
Wells can be used at the site to help meet remedial goals and support other remedial
technologies. Gradient control wells are needed with vertical barriers, as described
with the containment technologies, to both control groundwater levels within and
upgradient of the wall. Gradient control wells would be designed to withdraw
minimal volumes of water to minimize pumping and treatment costs. Active
extraction wells could be used to remove contaminated groundwater identified as
presenting risks outside the vertical barriers. These wells would be designed to
extract water from the aquifer to treat and remove contaminants and eliminate
identified risks as quickly as possible.
Two EOR options were carried through initial screening; thermal and chemical EOR.
Thermal EOR has been used by the petroleum industry to extract heavy oils from
deep reservoirs by injecting steam to drive the oil to pumping wells. The shallow
conditions at the site, the lack of an overlying confining layer that would trap the
steam to build up pressure, and the high energy costs make thermal EOR impractical
for the site.
Chemical EOR or soil flushing involves injecting water, surfactants, solvents, or other
agents into the oil and solvent contaminated soil to drive the emulsified liquids to
extraction wells or other collectors. The problems with soil flushing are that the
heterogeneous nature of the landfill contents may trap the emulsions and the
heterogeneous nature of the separate phase liquids at the site may cause adverse
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reactions with the flushing reagents. The emulsions created may greatly increase the
volume of contaminated liquids requiring treatment and the emulsions may
complicate the treatment processes needed.
Soil flushing may have limited applications for the oil saturated sand and gravel near
the railroad grade and the Oil Seep Area. Extensive field testing would be required
to evaluate its effectiveness. Since the effectiveness cannot be evaluated and costs for
treating emulsions cannot be estimated, soil flushing and chemical EOR will not be
carried forward for assembly into alternatives. If EOR or other similar technologies
are developed in the future, they should be reconsidered as potential methods to
reduce long-term site management costs.
Soil, Sediment, Landfill Contents Removal. Removal would be accomplished using a
variety of excavating and earthwork equipment, including backhoes, front-end loaders,
draglines, and dozers. Excavating the landfill contents is technically possible although
cost would far exceed typical excavation costs because of the lower productivity and
higher costs due to health and safety requirements.
Environmental controls would be required to prevent vapors from being released to
the atmosphere and to control rainwater runon and runoff around open excavations.
The excavated material may require special staging and treatment to be handled or
stored. Occupational Health and Safety Administration (OSHA) health and safety
requirements would apply to all activities. Actual excavation may require supplied
breathing air (Level B) because of the high potential for encountering solvent vapors,
decomposed drums, and other hazardous materials.
Excavation is carried forward for incorporation into alternatives involving contaminant
source area removals. The goal of source removal is to lower long-term site
management costs, however the savings cannot be quantified. The capital costs would
be very high, because the oil and solvent contaminated source areas identified in the
RI are large, estimated to have a volume of 800,000 cubic yards. The environmental,
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AGENCY REVIEW DRAFT
worker safety, and public health risks presented by excavating large volumes of
hazardous materials at the site would also be very high.
Treatment and Disposal
Treatment and disposal technologies are grouped by operable unit for detailed
screening and evaluation. Groundwater leachate and oil treatment and disposal
involves handling primarily liquids. Soil, sediment, and landfill contents treatment and
disposal requires handling predominately solid materials.
Groundwater-Leachate-Oil Treatment and Disposal. A large number of treatment
technologies and associated process options were retained and considered applicable
for this operable unit (Table 4-1). Only two disposal technologies were considered
applicable; discharge and reinjection. Discharge would be either to the Clinton River
or the local sanitary sewer. Reinjection would require using injection wells to
discharge treated water back into the aquifer. Treatment goals or levels would
depend on the method of disposal used and associated discharge requirements.
Discharge or reinjection requirements control the effectiveness of treatment
technologies for the site, since discharge limits are defined by state and federal codes
or by the local publicly owned treatment works (POTW). Both discharge and
reinjection are equally effective and implementable technologies. The State of
Michigan requires a state permit for reinjection under Act 245 of 1929 as amended by
Water Resources Commission Act, Parts 4, 9, 21 and 22 and that treated water
usually meet drinking water standards before being reinjected into the aquifer. This
is a very stringent treatment requirement and the relative treatment cost would be
much higher than discharge to either the Clinton River or a POTW, therefore
discharge is selected as the representative disposal technology for assembled
alternatives.
However, reinjection may be viable if the state requires less stringent treatment for
maintaining the wetlands in the Clinton River valley near the site. The state may
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AGENCY REVIEW DRAFT
require less stringent treatment based on local hydrogeologic conditions presented in
the RI Report. Reinjection may also be useful for soil flushing or chemical EOR
described with the experimental removal technologies, that could be tested in the
future. The state would have to approve treated water and the associated treatment
levels for this use. Reinjection should be considered further for disposal, wetland
protection, and possibly other uses during design and the remedial action
implementation.
Discharge to the Clinton River or the sanitary sewer (POTW) are the disposal
options carried forward to the assembled alternatives. Both options are effective,
implementable, and cost about the same. Both should be considered during design.
More detailed descriptions of each option are given in Appendix D. The potential
advantage of discharge to the sewer line is that the POTW may require less stringent
treatment, however the Detroit Metropolitan Water and Sewer District only accepts
discharges on an individual case basis and will not set specific criteria for approval at
this time. Discharge to the Clinton River must meet the requirements of the NPDES
permit system. Discharge levels are determined by the state to ensure compliance
with state and federal water quality criteria. Effluent concentrations can be estimated
based on known criteria for NPDES discharge limits (Appendix D), therefore
discharge to the Clinton River is selected as the representative disposal option.
The effluent concentrations estimated in Appendix D for obtaining a NPDES permit
for disposal to the Clinton River were used to evaluate treatment technologies for
extracted groundwater. Effluent concentrations and treatment goals will depend on
the actual disposal option selected during design, as discussed previously. All the
technologies and associated process options listed in Table 4-1 are applicable and
should be considered further in design, especially if required treatment or effluent
levels change.
The goal of the treatment evaluation in the FS is to select a representative system
that would meet NPDES permit requirements for cost estimating purposes. Each of
the applicable groundwater treatment technologies and process options listed in
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AGENCY REVIEW DRAFT
Table 4-1 are described and evaluated in Appendix D. Based on that evaluation, a
system combining physical and chemical treatment processes was selected as being
representative for estimating costs of the assembled alternatives. The representative
system consists of the following processes:
Flow and strength equalization, followed by
Oil/water separation, followed by
Precipitation, followed by
Media filtration, followed by
Air stripping, followed by
Carbon adsorption
The other groundwater treatment processes listed in Table 4-1 should be considered,
along with possibly other newer and less proven processes, during design. Of the
processes listed in Table 4-1, two innovative processes; ozone with ultraviolet (UV)
light and reactor based biological treatment may be effective for meeting the final
established treatment goals and possibly simplify the site treatment system.
Applications of both processes are described in Appendix D.
Ozone/UV oxidation is an emerging process and appears to have the same relative
cost as other processes, although limited data from commercial operations exist.
Reactor based biological treatment is being studied at the site as part of an EPA
research and development program. EPA field testing, to be completed in 1990,
should provide useful data on biological treatment.
In situ biological treatment is a new technology with a very limited performance
history. Oxygen and nutrients are added to the underlying soil and aquifer to
stimulate microbial activity and degrade organic contaminants. In situ treatment can
be coupled with extraction and reactor based treatment or done independently. In a
typical system, groundwater is extracted, mixed with nutrients and oxygen, and
reinjected into the aquifer. Both long-term pilot and bench-scale studies are required
to evaluate the effectiveness and use of in situ treatment at the site. The
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AGENCY REVIEW DRAFT
effectiveness and the cost to test in situ treatment cannot be evaluated at this time,
therefore it will not be assembled into alternatives for detailed evaluation. This
experimental technology, like EOR and soil flushing described with removal
technologies, may be useful for reducing long term site management costs and should
be reconsidered as in situ treatment develops in the future.
Soil-Sediment-Landfill Contents Treatment and Disposal. Two treatment
technologies and onsite disposal were carried through initial screening (Table 4-1).
Onsite disposal in a RCRA type landfill was selected over off site disposal because of
the large volume of excavated source materials that would require disposal. The
minimum estimated volume for source areas removal is 800,000 cubic yards and off
site RCRA landfill capacity for this volume is currently unavailable. Offsite disposal
may be available for smaller quantities of material, especially groundwater treatment
residuals. This should be considered for the groundwater-leachate-oil operable unit.
Constructing an onsite RCRA-type landfill would require an area large enough to
accept a minimum of 800,000 cubic yards. Additional property may be required for
construction and for staging or treating excavated materials. RCRA siting criteria
may not be met because of the permeable site soil and high water table. Treated
landfill wastes may also not meet RCRA land disposal restrictions and waivers may
be required.
The two landfill treatment technologies carried through initial screening were,
solidification/fixation/stabilization and thermal treatment. Both are described, along
with associated processes, in Appendix D. Both are considered viable and necessary
to effectively immobilize or destroy hazardous substances in the excavated soil,
sediment, and landfill contents for RCRA land disposal. Both technologies will be
used in alternatives involving source area removal. These treatment technologies are
also applicable to residuals derived from groundwater, leachate, and oil treatment.
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AGENCY REVIEW DRAFT
TECHNOLOGY EVALUATION SUMMARY
The results of detailed technology screening and evaluation are summarized in
Table 4-2. The selected representative technologies and process options are listed
along with other technologies or processes that show the greatest potential for
attaining remedial goals. The technologies' applicability to site conditions presented
in Chapter 1 and the array of alternatives presented in Chapter 3 are also discussed
in Table 4-2. This array is the basis for developing assembled alternatives for detailed
evaluation in Chapter 5.
GLT959/026.51
4-18
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)LOGY EVALUATION FOR PRELIMINARY AL
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AGENCY REVIEW DRAFT
Chapter 5
ALTERNATIVES EVALUATION
Chapter 5 describes detailed remedial alternatives for the G&H Landfill site.
Detailed descriptions of remedial alternatives were developed from the preliminary
alternatives developed in Chapter 3 and the technologies evaluated in Chapter 4.
Alternatives 5A, 5B, and 6B involving removal and treatment of large volumes of
contaminated soil and landfill contents, were eliminated in Chapter 3, based on
preliminary screening criteria. Alternative 4B, Groundwater Extraction and
Treatment with Source Containment Experimental Technologies, cannot be evaluated
effectively in this chapter; however, this alternative could be reconsidered in the
future. The remaining alternatives, listed in Table 4-2, form the basis for assembling
the detailed alternatives evaluated in this chapter.
This chapter also presents the detailed evaluation of remedial alternatives retained
from Chapters 3 and 4 based upon seven criteria and the comparison of the
alternatives against the criteria. The purpose of the detailed analysis is to provide
sufficient information to adequately compare alternatives, demonstrate satisfaction of
the CERCLA remedy selection requirements, and ultimately to assist the EPA with
its selection of the overall site remedy.
DETAILED ALTERNATIVE DESCRIPTIONS
ALTERNATIVE 1—NO ACTION
Alternative 1, the no action alternative, assumes that no further action or
maintenance will be conducted at the site. Under this alternative, the public health
and environmental risks quantified in the baseline risk assessment would exist (RI
Report, 1990).
5-1
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AGENCY REVIEW DRAFT
The following chemical exposure pathways were identified under existing site
conditions:
• Onsite
— Direct contact between contaminated media and site visitors
- Inhalation by site visitors of released volatile compounds from
the Phase I Landfill area
— Direct contact between contaminated media and wildlife
• Offsite
— Release of contaminants to groundwater, and subsequent
transport offsite and use by residents or workers as a drinking
supply source
— Release of volatile organic compounds to air and inhalation by
residents or workers
— Release of contaminants to groundwater and surface water and
subsequent transport offsite, and direct contact by aquatic
organisms in the Clinton River or Clinton-Kalamazoo Canal
The existing landfill covers are not graded to promote surface runoff. The Phase I
Landfill cover consists of 0 to 3 feet of silty sand that is contaminated with PCBs and
pesticides. The Phase II and III Landfill covers consist of 1 to 3 feet of silty clay that
is severely eroded in some locations.
There is an oil seepage area located just south of the Phase I Landfill. This area has
been subject to a variety of emergency actions by the U.S. EPA At present, a
5-2
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AGENCY REVIEW DRAFT
collector trench and sheet pile wall direct the seepage to a single discharge point.
The trench contains a mixture of oil and water.
There are leachate seeps along the western slope of the Phase III Landfill. These
seeps are not controlled, and they discharge to wetlands and the Clinton River.
A groundwater contamination plume has been identified (Figure 1-8). Contaminant
loading to groundwater under existing conditions occurs by leaching induced by
infiltrating precipitation and by contact between groundwater and buried waste. An
estimated 7 to 7.7 inches per year of precipitation infiltrates the landfill covers, with
an estimated 30 to 35 gpm loading rate of leachate to groundwater for the entire
landfill area. An estimated 10 to 100 gpm of groundwater flows beneath the landfill
area. Several areas in the Phase I Landfill were identified as having buried waste in
direct contact with groundwater; however, the amount of groundwater flowing
through the buried waste and the magnitude of associated contaminant leaching could
not be quantified.
ALTERNATIVE 2—INSTITUTIONAL CONTROLS
Alternative 2 consists of providing public water supply connections to residents and
businesses east of the site, monitoring groundwater, and maintaining access
restrictions. This alternative would limit direct contact by the public with
contaminated media.
The State of Michigan has already provided public water supply connections for about
44 residences east of Ryan Road. This alternative would provide such connections to
an additional 55 residences, and to 6 businesses. Groundwater use restrictions in the
area would be implemented in conjunction with the public water supply connections;
however, enforcement of such restrictions is likely to be difficult.
A semi-annual groundwater monitoring program for the site would be established. A
network of existing monitoring wells would be selected to track contaminants in
5-3
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AGENCY REVIEW DRAFT
groundwater, and provide warnings if contaminants migrate further or if contaminant
levels increase significantly. Based on the results of groundwater monitoring,
additional site remedies could be implemented in the future. For cost estimating
purposes, it was assumed that 40 samples would be analyzed for organic compounds
twice a year. In addition, it was assumed that dedicated sampling equipment would
be installed in 40 wells.
Public access restrictions would be maintained by imposing and enforcing deed
restrictions on the site property and by maintaining the existing site fence. Semi-
annual inspections of the site would be made to assess damage to the fence.
ALTERNATIVE 3A—CONTAINMENT WITH SOIL-CLAY COVER
Alternative 3A consists of constructing a new multilayer cover over the Phase I, II,
and III Landfills (82 acres) (Figure 5-1) as well as implementing the institutional
controls of Alternative 2. Remedial goals addressed under this alternative include
preventing direct contact with contaminated media, controlling the leaching of
hazardous materials from landfill contents and oil-saturated soils, and reducing the
volume of contaminated groundwater.
Components of the soil-clay cover would include a grading layer, a 3-foot thick clay
barrier layer, and a 3.5-foot thick protective layer. An estimated 750,000 cubic yards
of fill for the grading and protective layers and 380,000 cubic yards of clay would be
required. It is unlikely that a local fill or clay source (i.e. within 10 miles) would be
available for quantities of this magnitude. The cover would be vegetated with prairie
grasses.
Leachate that surfaces on the west sideslope of the Phase III Landfill will be collected
with a pipe and media drain that drains to a sump. An estimated 1 gallon per minute
of leachate will be collected at steady state. The leachate will be pumped to a
storage tank located on the railroad grade, and a vacuum tanker truck will
5-4
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TOE DRAIN
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FIGURE 5-1
ALTERNATIVE 3A,
SOIL-CLAY COVER
G & H LANDFILL FS
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AGENCY REVIEW DRAFT
periodically haul the leachate offsite to a nearby industrial wastewater treatment
facility.
Small amounts of methane were detected at the site. Methane gas would be vented
to allow gas pressures to dissipate before damaging the cap and to reduce the
tendency for horizontal gas migration beyond the property.
It was assumed that the cap would be planted with prairie grass because prairie grass
mixtures would be adaptable to low-nutrient sandy soil that is commonly available in
this part of Michigan. The prairie grass mixture would include flowering species to
provide an aesthetically pleasing cover. Prairies require annual controlled burns to
maintain diversity of species; however, such burns may not be permittable due to
potential safety hazards (e.g. underground fire fueled by methane) or due to nuisance
smoke. The prairie could be maintained by mowing, but the dominant grass species
would eventually take over. In this case, the prairie grass would remain functional,
but it would lose its aesthetic appeal.
The soil-clay cover could meet the current requirements of Michigan State Hazardous
Waste Rules R 299.9619 and RCRA Subtitle C closure requirements 40 CFR 264.310.
However, the soil-clay cap would not meet current RCRA Subtitle C closure
guidelines. Other multilayer covers were evaluated and screened, with the advantages
of each described in Appendix B, and detailed cost estimates provided in Appendix F.
ALTERNATIVE 3B—CONTAINMENT WITH VERTICAL BARRIER AND SOIL-
CLAY COVER
Alternative 3B consists of constructing a slurry wall vertical barrier around the buried
waste at the site in addition to the components of Alternative 3A (Figure 5-2). The
groundwater gradient inside the slurry wall would be controlled by groundwater
extraction wells. Collected groundwater would be treated before discharge. In
addition to meeting remedial goals addressed by Alternative 3A, this alternative
would meet the goals of controlling the migration of separate phase liquids containing
5-5
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SOIL-CLAY COVER
VERTICAL BARRIER
TOE DRAIN
AREAS WHERE GW CONCENTRATIONS
EXCEED MCLs OR NON ZERO MCLG
GRADIENT CONTROL WELLS
AND HEADER
FLOW DIRECTION OF COLLECTED AND
TREATED WATER
FIGURE 5-2
ALTERNATIVE 3B
SOIL-CLAY COVER AND
VERTICAL BARRIER
G & H LANDFILL FS
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AGENCY REVIEW DRAFT
hazardous substances and preventing the release of groundwater contaminants at
concentrations exceeding protective limits. Alternative 3B would slightly reduce the
mass of contaminated materials at the site by treating some contaminated
groundwater.
The slurry wall would be approximately 7100 feet long, and it would be keyed at least
3 feet into the underlying silt and clay layer. Estimated depths to the silt and clay
layer vary from 0 to 45 feet, with an estimated average depth of 34 feet. A
geotechnical investigation would be conducted before construction to confirm the
depth to the underlying silt and clay along the alignment and to provide more grain-
size data to be used for backfill mix design. Based on the proposed wall alignment
and the limited working space in some areas, it was assumed that a remote,
centralized backfill mixing pad would be required. Also, remote hydration ponds for
slurry mixing will likely be required.
It was assumed that the slurry wall will be constructed through areas where contact
with organic compounds in groundwater is unavoidable. It was also assumed, based
on RI data, that separate phase liquids and highly contaminated soil would not be
encountered during construction. For the slurry wall to be constructible and effective,
the slurry and the backfill must be compatible with those organic compounds which
contact the wall. A compatibility study would be conducted before construction of the
slurry wall. The study would likely consist of long-term (6 month minimum)
permeability tests of candidate backfill materials. The permeate used for such tests
would be groundwater samples collected from various areas along the proposed wall
alignment, or would be made synthetically based on groundwater contaminant
concentrations. In addition, separate phase liquids may be used under the worst case
scenario that they may contact the slurry wall at some time in the future.
The type of backfill required to meet compatibility requirements will govern the cost
of the wall. The least expensive wall would consist of a standard soil-bentonite
backfill using excavated trench spoils. The most expensive wall would likely be a
cement-bentonite backfill with special additives (e.g. attapulgite) to the slurry to
5-6
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AGENCY REVIEW DRAFT
reduce shrinkage in the event of contact with organic contaminants. Another option
would be to install a geomembrane in the slurry trench; however, the use and
effectiveness of geomembranes as vertical barriers is not well documented.
Cement-bentonite will likely be required at utility crossings and steep grade crossings.
Special construction techniques, such as high-pressure grout injection, will be required
at the water main and sewer interceptor crossings. Additional slurry walls, grouting or
other methods may be necessary to isolate these utilities.
Groundwater extraction wells will be installed inside the slurry wall to produce and
maintain an inward hydraulic gradient. This will prevent overtopping of the wall and
reduce the likelihood of slurry degradation due to contact with high concentrations of
VOCs. It was assumed that the soil-clay cover would be required to meet state and
federal regulations. A soil-clay cap will reduce the amount of surface water
infiltration by approximately 80 percent.
Groundwater collection rates were estimated for startup conditions and steady state
conditions (Appendix C). Approximately 30 gallons per minute will be collected at
startup, and 10 gallons per minute will be collected at steady state. It was assumed
that the leachate collection system would be connected to the gradient control header
line (Figure 5-2).
The groundwater treatment system components were selected based on the influent
concentrations presented in Appendix D. Experience obtained during groundwater
remediation indicates contaminant concentrations often are different from predicted
concentrations once the collection system has been operated for a period of time.
Because of this, the actual design of the treatment system should be based on analysis
of groundwater samples taken in the design investigation during pumping of the
extraction wells.
The treatment process, described in detail in Appendix D, is summarized below. An
equalization tank in provided as a pretreatment step to equalize flow and to lessen
5-7
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AGENCY REVIEW DRAFT
the effects of any unexpected slug loads on the downstream treatment processes. A
conventional API oil separator is currently proposed as a pretreatment step to
remove the nonaqueous phase liquids. Collected oil will be disposed of at an offsite
incinerator.
Conventional precipitation, flocculation, and clarification is proposed to remove
metals.
Clarifiers create sufficient residence time to allow solids to settle out of solution.
After settling, clarified water is drained from the top and solids withdrawn from the
bottom as sludge. After thickening and dewatering of sludge onsite, the sludge will
probably be disposed of in an offsite RCRA landfill. Sludge generation rates are
estimated to be 1.4 to 4.2 cubic feet per day.
Filtration would be the final step of metal and total suspended solids (TSS) removal.
Metals would be captured as residual suspended solids in the effluent. Removal of
volatile organic compounds and ammonia would be accomplished in a countercurrent
packed tower air stripper. pH neutralization can be done after air stripping to allow
ammonia removal in the stripper. The final step in the treatment process is carbon
adsorption for removal of pesticides and PCBs. Two carbon units in series are used.
Carbon from the vessels will need to be periodically replaced and regenerated.
Figure D-l (Appendix D) shows the conceptual design of the treatment system
including equalization, oil removal, precipitation/flocculation/clarification, filtration, air
stripping, carbon adsorption, and further settling of the sludge from the clarifier. The
treatment system would be housed inside a building near the concrete slab off the
main site entrance road. It was assumed that discharge of treated water to the
Clinton River will be permitted.
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AGENCY REVIEW DRAFT
ALTERNATIVE 4A—GROUNDWATER TREATMENT WITH SOURCE
CONTAINMENT
Alternative 4A consists of installing a site perimeter groundwater collection system in
addition to implementing the components of Alternative 3B (Figure 5-3).
Groundwater would be extracted from areas with contaminant levels greater than
established MCLs or non-zero MCLGs, and the water treatment system of
Alternative 3B would be upgraded to treat a higher inflow rate. In addition to
meeting remedial goals addressed by Alternative 3B, this alternative would meet the
goals of controlling the volume of contaminated groundwater at the site, providing a
remedy that allows eventual achievement of groundwater standards (in non-source
areas), and preventing the release of groundwater contaminants at concentrations
exceeding protective limits. Alternative 4A would also provide a slight reduction in
the mass of contaminated materials at the site by treating contaminated groundwater.
Approximately 14 groundwater extraction wells would be installed and connected to
the treatment plant by a header (Figure 5-3). These wells would collect an estimated
30 gallons of groundwater per minute, in addition to the water collected by the
hydraulic gradient control wells. The combined estimated flow for treatment is
approximately 60 gallons per minute at startup and 40 gallons per minute at steady
state.
The groundwater treatment system for Alternative 4A is the same as proposed for
Alternative 3B, although the size of the units will be different based on different
estimated influent flow rates. The amount of sludge generated from the precipitation/
clarification process is estimated to range from 5.6 to 8.4 cubic feet per day. It was
assumed that a discharge permit would be obtained and treated water would be
discharged to the Clinton River.
5-9
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GRADIENT
CONTROL
WELL-
-HEADER
1
cr
(3
s
s
o
'.'.DRAINAGE'.-.-.•
CHANNEL •.•.••
North
t
400
APPROXIMATE
SCALE IN FEET
CURRENT U.S. EPA SITE FENCE (MAY NEED
TO BE RELOCATED DURING REMEDIALACTION)
GATE
DITCH, STREAM, OR RIVER
TRAIL
RAILROAD GRADE (TRACKS REMOVED)
SOIL-CLAY COVER
VERTICAL BARRIER
TOE DRAIN
AREAS WHERE GW CONCENTRATIONS
EXCEED MCLs OR NON ZERO MCLGs
GRADIENT CONTROL WELLS
AND HEADER
EXTRACTION WELLS AND HEADER
FLOW DIRECTION OF COLLECTED
AND TREATED WATER
FIGURE 5-3
ALTERNATIVE 4A
GROUNDWATER TREATMENT
WITH SOURCE CONTAINMENT
G & H LANDFILL FS
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AGENCY REVIEW DRAFT
ALTERNATIVE 6A—SOURCE REMOVAL AND TREATMENT
Alternative 6A consists of removing and treating those areas of the site that have
been identified as hotspots or highly contaminated areas. The components of
Alternative 4A will be implemented with this alternative because some source
material will remain onsite and because the removal and treatment action will require
an estimated 20 years to complete. Details describing excavating and treating
contaminated refuse and soil are presented in Appendix D. In addition to the
remedial goals met by Alternative 4A, this alternative addresses the remedial goal of
reducing the mass and volume of contaminated soil, buried waste oil, and other
buried waste.
The identified hotspots comprise an estimated 800,000 cubic yards (Figure 5-4).
Excavation would be performed using conventional earth moving equipment.
Excavated areas would be graded and capped with a soil/clay cover. It was assumed
that the processing of the waste would be done at a central location inside a building
with specially constructed ventilation. Processing is assumed to include screening,
sorting, and crushing oversized material. Some additional conditioning or dewatering
may also be required. Continuous air monitoring during excavation and processing
will be required.
After processing, the waste will be incinerated onsite. Because mobile incineration
units have a small throughput (in the range of 4 tons per hour), it was assumed that
two such incinerators would be used. It was estimated that it would take 20 years for
the incinerators to treat the 800,000 cubic yards of waste. It would be possible to
reduce this time by constructing a larger onsite incinerator or using additional mobile
incinerators.
An onsite RCRA-type landfill cell would be constructed to contain residual ash and
sludge. The estimated residual volume is 400,000 cubic yards. Assuming that the
residuals are placed 25 feet thick on average in the cell, the landfill would require an
area of approximately 10 acres (Figure 5-4).
5-10
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LEGEND
LANDFILL BOUNDARY
CURRENT U.S. EPA SITE FENCE (MAY NEED TO
BE RELOCATED DURING REMEDIALACTION)
GATE
DITCH, STREAM, OR RIVER
TRAIL
RAILROAD GRADE (TRACKS REMOVED)
SOIL-CLAY COVER
VERTICAL BARRIER
TOE DRAIN
AREAS WHERE GW CONCENTRATIONS
EXCEED MCLs OR NON ZERO MCLGs
GRADIENT CONTROL WELLS
AND HEADER
EXTRACTION WELLS AND HEADER
"HOTSPOr AREA TO BE EXCAVATED
AND TREATED, THEN GRADED AND
CAPPED WITH A SOIL-CLAY COVER
FLOW DIRECTION OF COLLECTED
AND TREATED WATER
NOTE:
' *• ,O- RCRA-Type landfill cell is shown to indicate approximate area
^ requirements. Actual location would be determined during design.
o
o
_l
CD
North
t
400
APPROXIMATE
SCALE IN FEET
FIGURE 5-4
ALTERNATIVE 6A
REMOVAL AND TREATMENT
G & H LANDFILL FS
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AGENCY REVIEW DRAFT
The groundwater treatment system for Alternative 6A is the same as proposed for
Alternative 4A. The only difference is that both collected oil and precipitation sludge
will be treated and disposed of onsite. The oil would be incinerated with source area
soils. Sludge from the precipitation/clarification process would be solidified and
disposed of onsite in the RCRA cell.
CERCLA REQUIREMENTS FOR ALTERNATIVE EVALUATION
Specific CERCLA requirements of the remedial alternatives that must be addressed
in the ROD and supported by the FS report are:
• Protection of human health and the environment
• Attainment of ARARs or provision of grounds for invoking a waiver
• Cost-effectiveness
• Use of permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable
• Satisfaction of the preference for remedies that use treatment that
reduces toxicity, mobility, or volume as a principal element
In addition, Section 121 of CERCLA, as amended by SARA, emphasizes evaluation
of long-term effectiveness and related considerations for each remedial action. The
following issues must be considered:
• The long-term uncertainties associated with land disposal
• The goals, objectives, and requirements of the Solid Waste Disposal Act
5-11
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AGENCY REVIEW DRAFT
• The persistence, toxicity, and mobility of hazardous substances and
constituents and their tendency to bioaccumulate
• The short- and long-term potential for adverse health effects through
human exposure
• The long-term maintenance costs
• The future remedial action costs if the selected alternative were to fail
• The potential threat to human health and the environment associated
with excavation, transportation, and redisposal or containment
The NCP (40 CFR 300.430) defines seven criteria that are to be evaluated in the
detailed analysis of alternatives. The seven criteria evaluated for each alternative in
this FS are:
• Short-term Effectiveness—The impact an alternative will have on
human health and the environment during construction and
implementation, until remedial response objectives are met.
• Long-term Effectiveness—The effectiveness of a remedial action in
terms of the risk remaining at the site after response objectives have
been met. The focus of this evaluation is the effectiveness of the
controls that will be applied to manage risk posed by treatment
residuals or untreated wastes.
• Reduction of Toxicity, Mobility, or Volume—This criterion is used to
evaluate statutory preference for remedial actions that employ
treatment technologies that permanently and significantly reduce
toxicity, mobility, or volume of the hazardous substance as their
principal element. This preference is satisfied when treatment is used
5-12
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AGENCY REVIEW DRAFT
to reduce the principal threats at the site through destruction of toxic
contaminants, irreversible reduction in contaminant mobility, or
reduction of total volume of contaminated media.
• Overall Protection of Human Health and the Environment—
Assessment of whether an alternative meets the requirement that it be
protective of human health and the environment. The overall
assessment of protection is based on a composite of factors assessed
under other evaluation criteria, especially long-term effectiveness and
permanence, short-term effectiveness, and compliance with ARARs.
• Implementability—The technical and administrative feasibility of
implementing an alternative and the availability of various services and
materials required for implementation.
• Estimated Cost—The capital costs, annual operation and maintenance
costs are estimated. These costs for each alternative are compared by
estimating the total present worth of each alternative.
• Compliance with ARARs—The compliance of each alternative with
applicable or relevant and appropriate standards, requirements, criteria
or limitations under federal and state environmental laws as defined in
CERCLA Section 121.
In addition to the seven criteria above, Section 121 provides for state involvement in
remedy selection and Sections 113 and 117 of CERCLA provide for public
participation during remedy selection. These last two criteria will be evaluated
following receipt of comments on the FS report and will be addressed in the
Responsiveness Summary and the ROD.
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AGENCY REVIEW DRAFT
DETAILED EVALUATION OF ALTERNATIVES
The detailed evaluation of alternatives for each of the seven criteria listed above are
presented in Table 5-1.
Evaluation of short term effectiveness included calculations of the incidence of
vehicular and construction related accidents. The calculation methodology and
accident rates used are presented in Appendix E. The values presented in the
detailed evaluation tables represent the expected number of injuries or deaths that
would occur during the construction of the alternative. Values less than 1 can be
interpreted as a probability of injury or death. For example, 0.02 injuries represents a
2 percent chance of an injury occurring during construction.
Potential ARARs are presented in Table 2-1. The ARAR issues potentially affecting
the feasibility of an alternative are summarized in Table 5-1.
Cost estimates were prepared using information currently available to aid in the
evaluation of alternatives. Final project costs will depend on actual labor and
material costs, actual site conditions, productivity, competitive market conditions, final
project scope, final project schedule, the firm selected for final engineering design,
and other variable factors. As a result, final project costs will vary from the estimates.
Because of these factors, funding needs must be carefully reviewed before specific
financial decisions are made or final remedial action budgets are established.
The cost estimates in this FS are order-of-magnitude estimates with an intended
accuracy range of +50 percent to -30 percent. This range applies only to the
alternatives defined in this chapter and does not account for changes in the scope of
the alternatives. Each selected technology or process is intended not to limit
flexibility during remedial design but to provide a basis for making FS cost estimates.
The final remedial actions and cost estimates will be refined during remedial design.
5-14
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Evaluation
Criteria
Short-Term
Effectiveness
-"Protection of
Community During
Remedial Action
Alternative 1
No Action
No action taken.
A
action
with
Instment
lnstituticative 3B-
have mi5 are ex~
nity.
not expi
crease t
Alternative 6A
Source Removal
During excavation of the source materials, VOC emissions
would be expected. The air would be monitored throughout
the excavation period. Excavation would cease if potentially
harmful VOC concentrations are detected. Open areas
would be covered or foams would be used to mitigate VOC
emissions to surrounding areas. Onsite treatment of exca-
vated waste material is also expected to cause VOC and
dust emissions. Other construction activities associated
with earthwork and groundwater extraction and treatment
would be expected to be similar to activities associated with
Alternatives 3B and 4A.
Protection of
Workers During
Remedial Action
Time Until Remedial
Objectives Are
Achieved
Institutic
ing are
mat risl>
protectic
necesss
tivities,
level C.
lnstitutkc°nstruc-
monrtoritreatment
plemenf1"16"1 ac'
uire about
red to re-
i ground-
owMCLs/
ry wall is
Health and safety protective level B will probably be re-
quired for excavating source materials. Levels B and C are
likely to be required for onsite treatment of excavated ma-
terials. Health and safety plan enforcement during excava-
tion in this high hazard environment is very important to
protect workers. Based on typical construction-related acci-
dent rates, 12 injuries and 2.7 x 10~1 deaths would be ex-
pected during excavation of contaminated refuse and soil.
Other construction activities associated with earthwork and
groundwater extraction and treatment would be expected to
be similar to Alternatives 3B and 4A.
Design, procurement, and construction of source removal
and other RA activities are expected to require about 20
years. Time required for groundwater extraction and treat-
ment is similar to Alternative 4A.
- Environmental
Impacts
Long-Term
Effectiveness
- Magnitude of
Residual Risk
Existing average percolation
through the site covers is es-
timated to be 7 inches per
year or 35 gpm. Leaching of
BETX, PNA, and other con-
taminants to groundwater
would continue indefinitely.
Future risks to site visitors
from direct exposure to con-
taminated soil and sediment
would result in up to a 9 x
10'5 excess lifetime cancer
risk.
Minimalud9efrom
effects i601 Plant
menting6068831?-
monitoriWetlands
ay be af-
sxtraction,
downs are
id treated
I to main-
PercolaB except
covers^8 outside
for No ,would be
taminariCLGsDe-
continu^ is shut
site visit
though i
through
Similarto Alternatives 3B and 4Aforgroundwater extraction
and treatment, and earthwork activities. VOC emissions to
air are not expected to cause environmental impacts if
proper monitoring and mitigative measures are implemented
during source removal work. Soil erosion and runoff control
measures are also required to minimize contaminated runoff
reaching the Clinton River and adjacent wetlands.
Similar to Alternative 4A. The added benefit of removing
source areas to lower long-term residual risk cannot be
quantified or evaluated.
GLO 65561 .FS.R4 G4H AH. Eval.Tabte 5-29-90 SUM
Table 5-1
Detailed Evaluation of Alternatives
Page 1 of 3
-------
Evaluation
. Criteria
Implementabllity
- -Technical Feasibility
Alternative 1
No Action
A
action
with
Availability of Serv-
ices and Materials
, 4.
Instit
•or landfill
No techiundwater
Pected- nandreli-
nent sys-
alogy and
Mechani-
cted. The
Id include
ell pumps
nt system
processes
ssary.
. are avail-
s'3™6^ 3A and
restrictic
Alternative 6A
Source Removal
Similar to Alternative 4A for groundwater treatment and
landfill earthwork. Thermal treatment of the landfill contents
and contaminated soil can be performed; however, many
technical problems would be expected during operation.
Mechanical breakdowns and materials handling problems
would slow the production rate. Solidification or fixation of
ash may increase the volume of waste material for onsite
landf filing. An onsite RCRA-type landfill can be constructed;
however, siting criteria for low-permeability underlying soil
and depth to water table would not be met.
Services and materials are available, similar to other alter-
natives.
Administrative
Feasibility
Compliance
with ARARs
Contaminant concentrations
in groundwater exceed
MCLs/MCLGs. The rele-
vancy and appropriateness
of current RCRA and Michi-
gan standards are to be
evaluated by the EPA and
MDNR.
Monitor!
require
MDNR;
Same a.
ance with
ntaminant
slurry wall
duced to
>efore the
down.
Similar to Alternative 4A, plus an air emission permit would
be required for onsite thermal treatment of excavated ma-
terials.
Expected to be in compliance with ARARs; however, RCRA
treatment requirements for land disposal of excavated soil
and refuse may difficult to meet and may require waivers. Air
emissions may also require work shut downs to meet permit
requirements.
Cost
- Capital Cost $0
- Annual Operation $0
and Maintenance
- Present Worth (at $0
5% over 30 years)
$460,000.000
$720,000
$470,000,000
GLO 65561 .FS.R4 G&H Alt. Eval.Tabte 5-29-90 SLM
Table 5-1
Detailed Evaluation of Alternatives
Page 3 of 3
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AGENCY REVIEW DRAFT
Unit prices were developed in accordance with the Superfund Cost Estimating Guide
(CH2M HILL 1987) and are based on construction cost data (Means 1989),
engineers' cost estimates for similar work, quotes from vendors and contractors, and
engineering judgment.
The cost estimates consist of total capital costs which include costs for construction,
allowances, contingencies, permitting and legal advice, and services during
construction; as well as present worth of operating and maintenance (O&M) costs
determined over a 30-year period at a 5 percent discount rate. Allowances account
for known items to be included in the final design but not quantified in the FS cost
estimates. Contingencies, such as bid and scope contingencies, account for
unforeseeable circumstances. Permitting and legal costs account for legal fees to
obtain licenses and construction permits and to negotiate contracts. Costs for services
during construction account for administration, construction oversight, and additional
design costs during construction.
Bid and scope contingencies are not uniform for all alternatives. Bid contingencies
address costs associated with constructing a given project, such as general economic
conditions at the time of bidding, adverse weather conditions, strikes by material
suppliers, and geotechnical unknowns. Scope contingencies address changes that
occur during final design and implementation. Scope contingencies include provisions
for items such as inherent uncertainties in characterizing wastes or waste volumes and
regulatory or policy changes that may affect FS assumptions. Scope contingencies
also depend on the performance history or complexity of the remedial technology.
Detailed cost estimates are presented in Appendix F. The cost estimates are
summarized on Table 5-1.
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AGENCY REVIEW DRAFT
COMPARATIVE ANALYSIS OF ALTERNATIVES
The comparative analysis presented here is intended to identify differences between
the alternatives and highlight the detailed evaluations presented in Table 5-1.
SHORT-TERM EFFECTIVENESS
Protection of Community During Remedial Action
Effects on the community during remedial actions are related to the amount of truck
traffic needed to import soil and the amount of earth moving during landfill cap or
cover construction. The truck traffic will cause nuisances from noise and dust and
increase the risk of vehicular accidents. Based on vehicular accident rates for state
trunk highways in the southeastern Michigan area and 1.81 million trucking miles,
9.7 accidents and 2.9 x 10"2 deaths would be expected during earthwork construction
activities for Alternative 4A. Rail service may be available for importing some of the
soil needed for Alternatives 3A, 3B, 4A, and 6A and may decrease the truck traffic
required for construction. The feasibility of rail service for transporting soil to the
site should be considered during design.
Alternatives 3B, 4A, and 6A involve excavating below the existing ground surface.
Based on RI data, it is not expected that hazardous substances will be encountered
during slurry trench excavation for these alternatives. Source removal excavation for
Alternative 6A involves handling large volumes of hazardous substances. Gases could
be emitted during any subsurface excavation and should be expected during source
removal activities in Alternative 6A. The air would be monitored during excavation.
When predetermined VOC concentrations are detected downwind, excavation would
cease and VOC suppressing foams would be applied or other mitigative action would
be taken.
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AGENCY REVIEW DRAFT
Protection of Workers During Remedial Action
Adverse health effects on workers during cap and cover construction are not expected
to be great for Alternatives 2 through 4A since hazardous substances are not
expected to be exposed. Based on typical construction accident rates, 0.56 injuries
and 1.3 x 10"2 deaths would be expected during construction of Alternative 4A
Alternative 6A poses additional risks to workers involved with excavating and
handling hazardous substances during the source removal activities. Hazardous
substances exposure risks to workers during excavation would be manageable using
proper OSHA health and safety procedures. OSHA health and safety protective levels
B and C would probably be necessary.
Time Until Remedial Objectives Are Met
The time required for design and construction ranges from 1 to 4 years for
Alternatives 2 through 4A. Most of the time required for construction is associated
with hauling soil and site earthwork. Alternative 6A is expected to require from 15 to
20 years to excavate, treat, and dispose of the source materials and complete the
landfill closure earthwork activities. Alternatives 3A through 6A require 2 to
2.5 years for design review activities and contracting requirements before the start of
construction.
Groundwater standards under Alternatives 1 and 2 will continue to be exceeded
indefinitely. The time until groundwater standards are met is difficult to estimate and
assumed to be at least 30 years for Alternatives 3A and 3B. The active groundwater
extraction system, located outside the slurry wall alignment, for Alternatives 4A and
6A is expected to remove VOCs to below standards in less than 30 years, and the
majority of VOCs outside the slurry wall may be removed within 5 years.
Groundwater contamination in areas under the landfills or within the slurry wall
alignment are expected to exceed standards under all alternatives.
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AGENCY REVIEW DRAFT
Environmental Impacts
The substantial earthwork involved in constructing the landfill covers and caps of
Alternatives 3A through 6A creates the potential of adverse environmental impacts
from soil erosion and siltation in the Clinton River and nearby wetlands. Potential
siltation can be mitigated through proper placement of silt curtains and regular
inspection during construction to maintain their effectiveness. Alternative 6A also
creates the potential for contaminated runoff associated with source removal
excavation and proper runoff control would be even more critical.
The slurry wall and groundwater collection system of Alternatives 4A and 6A may
cause water table drawdowns in the wetlands near the Clinton River during low-flow
conditions. The drawdowns are expected to be small and wetlands are not expected
to be significantly affected. Treated groundwater could be used to maintain wetlands,
if needed.
Discharge of treated groundwater to the Clinton River for Alternatives 3B through
6A would be expected to meet Michigan discharge standards. The standards are set
to be protective of aquatic life, therefore environmental impacts are not expected. In
the event of treatment system malfunctions, the groundwater collection system would
be automatically shutdown and discharges would cease until repairs could be
performed.
LONG-TERM EFFECTIVENESS
Magnitude of Residual Risk
The residual risk presented by landfills is typically quantified by the amount of
percolation through the landfill covers. Current percolation into the landfills is
estimated to be 30 to 35 gpm for No Action and Alternative 2. Cap options for
Alternatives 3A through 6A are estimated to reduce percolation by 60 to 90 percent.
Lower percolation would result in a lower contaminant mass leached to the
5-18
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AGENCY REVIEW DRAFT
groundwater. The actual reduction in contaminant mass loading is difficult to
estimate, because the total contaminant mass available for leaching to groundwater
throughout the landfills is unknown. The added benefit of removing identified source
areas for Alternative 6A to lower long term residual risk cannot be quantified,
because other contaminant masses may remain and act as continuing sources of
contaminants.
Some oil- and solvent-saturated soil was found below the water table in RI test pits.
This zone would continue to leach contaminants to groundwater independent of
percolation rates through the landfill covers. Leaching of contaminants from this
zone would be similar to current conditions for Alternatives 1, 2, and 3A.
Alternatives 3B, 4A, and 6A would limit future migration of contaminants from this
zone using a slurry wall with gradient control wells.
Groundwater contaminants outside the landfill areas for Alternatives 1, 2, 3A, and
outside the slurry wall alignment for Alternative 3B would be allowed to migrate and
disperse, presenting risks to the wetlands along the Clinton River (Table 1-1) and the
commercial area along Ryan Road. Alternatives 4A and 6A would remove
contaminated groundwater from outside the slurry wall alignment, until contaminant
concentrations are below risk levels.
Adequacy and Reliability of Controls
All action alternatives leave landfill materials in place and rely on institutional
controls to prevent development of the landfill areas and restrict groundwater use.
All action alternatives also include groundwater monitoring to detect concentrations
that could cause risks to public health or the environment. The probability of
increased groundwater use in the area is not considered great, because public water
supplies are available and current groundwater users are being connected to public
water lines. The property to the south of the landfill area is owned by the Michigan
DNR as part of the Rochester-Utica State Recreation Area. Development of this
property is unlikely.
5-19
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AGENCY REVIEW DRAFT
The landfill cap and cover options for Alternatives 3A through 6A are considered
effective and reliable for reducing percolation, assuming proper long-term
maintenance. Monitoring and fence maintenance for all the action alternatives are
considered reliable if properly managed. The reliability of the slurry wall for
Alternatives 3B through 6A needs to be tested during design to evaluate compatibility
with the oil and other separate phase liquids. Slurry walls with gradient control wells
are considered reliable if properly designed, constructed, and maintained. The long-
term performance of the slurry wall is difficult to monitor and leakage is difficult to
detect. The slurry wall could be repaired by replacing segments or possibly by
grouting segments of the alignment found to be leaking.
REDUCTION OF TOXICITY, MOBILITY, AND VOLUME OF CONTAMINANTS
All alternatives allow for natural degradation of contaminants in the landfill contents,
which is likely occurring and is expected to continue, though degradation rates are
unknown. No treatment processes are used in Alternatives 1 and 2.
Only minimal volumes of leachate and groundwater are treated to control gradients
for Alternatives 3A and 3B, with very little reduction in toxicity, mobility, and volume
of hazardous substances. The active groundwater extraction and the physical/
chemical treatment system included in Alternatives 3B, 4A, and 6A are estimated to
remove 130 pounds of VOCs in the first year of operation. The amount of VOCs
removed will likely decline in succeeding years. The treatment system is assumed to
remove 90 percent of the VOCs from treated groundwater. Approximately 6 to
9 cubic feet of sludge containing metals, TSS, and oil would be produced per day.
Small volumes of oil and other separate phase nonaqueous liquids that would
probably require offsite thermal treatment are expected to be produced by the
treatment system.
Alternative 6A includes removing and treating 800,000 cubic yards of contaminated
soil and refuse for onsite disposal in a RCRA type cell. The organic contaminants in
the source material would probably require thermal treatment to meet land disposal
5-20
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AGENCY REVIEW DRAFT
requirements under RCRA. The percentage of the total organic contaminant mass of
source materials destroyed is unknown. The ash produced from thermal treatment
would probably require additional fixation or solidification before disposal because it
would probably be contaminated with metals. The volume of residual ash and sludge
from the thermal treatment process to be disposed of onsite in the RCRA-type cell is
estimated to be about 400,000 cubic yards.
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The overall protection of human health and the environment is closely related to an
alternative's long-term effectiveness and mitigative measures implemented during
construction to minimize environmental impacts and risks to local residents or
workers. Differences between the alternatives occur in the magnitude of residual risk
presented and the reliability of controls.
No Action and Alternative 2 allow leaching of contaminants to groundwater at
current rates, which presents potential risks indefinitely into the future for aquatic life
in the wetlands south of the landfills. Current and future risks to commercial and
residential groundwater users along Ryan Road would be removed by providing
municipal water supplies in Alternative 2.
Alternatives 3A and 3B would greatly reduce leaching of contaminants to
groundwater; however, the VOCs in groundwater presenting risks south and east of
the landfill areas would continue to migrate and disperse. Alternative 4A would add
groundwater extraction to these areas to reduce the risks. Alternative 6A includes
source removal excavation which reduces the toxicity, mobility, and volume of source
areas, but creates risks to the public health and the environment during
implementation.
5-21
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AGENCY REVIEW DRAFT
IMPLEMENTABILITY
Technical Feasibility
No major technical feasibility problems are expected for Alternatives 2 through 4A.
The slurry wall's feasibility for Alternatives 3B, 4A, and 6A will depend on
compatibility testing with the separate phase oil and other liquids. Possibly, more
costly slurry wall materials, such as cement colloid, would be needed for some
segments of the wall. The slurry wall may also cause groundwater levels up gradient
along 23-Mile Road to rise, requiring additional controls or diversion.
The technical feasibility of Alternative 6A source removal activities is less proven, but
generally requires the use of established technologies. Additional environmental
controls are needed to prevent harmful VOC releases to air and control contaminated
runoff during excavation. Thermal treatment of the soil and landfill contents can be
accomplished; however, materials handling problems and mechanical breakdowns may
slow progress. Solidification or fixation of the residual ash may increase the volume
of waste materials being landfilled. An onsite RCRA type landfill can be constructed;
however, limited site working space is available for staging equipment and stockpiling
materials.
Availability of Services and Materials
Services and materials are available for all the action alternatives. Large quantities
(approximately 1.73 million tons) of cover and capping soil are required to grade and
cover the 82-acre landfill area for Alternatives 3A through 6A. The large quantities
of soil may require haul distances of over twenty miles and add road repair costs.
Rail service may be available for the site and may help reduce problems associated
with hauling.
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AGENCY REVIEW DRAFT
Administrative Feasibility
No major administrative feasibility problems are expected for the alternatives.
Monitoring and site restrictions will require regular review by the MDNR and local
officials. Discharge permits are required for treated groundwater for Alternatives 3B
through 6A, An air emission permit would be required for on site thermal treatment
of excavated soil and refuse for Alternative 6A. A permit would also be required to
construct the RCRA cell for Alternative 6A.
COMPLIANCE WITH ARARS
The MDNR and U. S. EPA are considering the relevancy and appropriateness of
current RCRA and Michigan standards for landfill closures. No Action and
Alternative 2 would not meet current RCRA Subtitle C or D requirements as
enforced by the MDNR under Michigan State Hazardous Waste Rules (R 299.9619)
or Michigan State Solid Waste Rules (R 299.4305). Alternatives 3A through 6A
would be designed to meet either landfill closure rule.
The MDNR and U. S. EPA are also considering the relevancy and appropriateness of
using MCLs/MCLGs as groundwater cleanup standards. None of the alternatives
would clean up groundwater to below MCLs/MCLGs in areas under the landfills or
within the proposed slurry wall alignment. Alternatives 4A and 6A would extract
groundwater outside the slurry wall alignment until clean up standards are met.
Alternative 6A is generally expected to be in compliance with ARARs, however
RCRA treatment requirements for land disposal of excavated soil and refuse may be
difficult to meet and may require waivers. Air emissions during excavation and during
operation of the thermal treatment plant may exceed permit limits and require work
shut downs to meet permit requirements. An onsite RCRA-type landfill can be
constructed; however, siting criteria for low permeability underlying soil and depth to
the water table under the cell would be difficult to meet.
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AGENCY REVIEW DRAFT
COSTS
The summary of costs is presented in Table 5-1. Present worth costs increase
significantly between Alternatives 2 and 3A because of the soil cover materials
required. Costs for Alternatives 3B and 4A are higher than Alternative 3A to include
the groundwater treatment system. Present worth costs for Alternative 6A are
significantly higher to include the source removal and disposal activities.
GLT959/038.51
5-24
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APPENDIXES
GLT959/040.51
-------
CONTENTS Follows
* Page
Appendix A—Initial Technology Screening
Figures
A-l Soil, Sediment, and Landfill Contents
Operable Unit Initial Technology Screening A-3
A-2 Groundwater, Leachate, and Oil Operable Unit
Initial Technology Screening A-3
Appendix B—Containment Analysis
Figures
B-l Grading Plan with 2 Percent Grade B-5
B-2 Typical Multilayer Cap Sections B-8
B-3 Areas with Groundwater in Direct Contact
with Buried Waste B-12
B-4 Vertical Barrier Alignment B-15
Tables
B-l Current Site Conditions and Their Affect
on Capping Technologies B-5
B-2 Summary of Capping Options B-ll
Attachment B-l Water Balance Calculations
Tables
1 Calculation of Potential Evapotranspiration
2 Water Balance Calculations—Phase I Landfill
3 Water Balance Calculation—Phase II and III Landfill
4 Water Balance Calculation—Soil Cover
5 Water Balance Calculation—Soil-Clay Cap
6 Water Balance Calculation—Soil-Drain Composite Cap
7 Summary of Generated Leachate
8 Reduction of Generated Leachate
Appendix C—Groundwater Extraction Analysis
Tables
C-l Summary of Conceptual Model Components
and Aquifer Properties C-l
C-2 Estimated Well Yield C-6
GLT959/041.51
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CONTENTS (Continued) Follows
Page
Appendix D—Treatment Systems Analysis
Figures
D-l Groundwater Treatment D-24
Tables
D-l Summary of Contaminant Concentrations—Groundwater/
Leachate/Oil Operable Unit D-5
D-2 Specific Pollutant Prohibitions—City of Detroit
Water and Sewerage Department D-15
D-3 Comparison of Maximum and Mean Groundwater
Concentrations to State and Federal Guidelines
or Criteria—No Action Alternative D-16
D-4 Comparison of Maximum and Mean Groundwater
Concentrations to State and Federal Guidelines
or Criteria—Groundwater Collection and Discharge D-18
Appendix E—Vehicular and Construction Accidents
Tables
E-l Estimated Construction Related Deaths and Injuries E-2
E-2 Estimated Vehicular Related Deaths and
Total Accidents E-2
Appendix F—Detailed Cost Analysis
Attachment F-l Detailed Cost Estimate Tables
Tables
F-l Summary of Costs
F-2 Cost Sensitivity Analysis
Alternative 2—Institutional Controls
Alternative 3A—Soil-Clay Cover
Alternative 3B—Soil-Clay Cover and Vertical Barrier
Alternative 4A—Groundwater Extraction and Treatment
with Source Containment
Alternative 6A—Source Removal and Treatment
GLT959/041.51
GLT959/041.51 ii
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Appendix A
INITIAL TECHNOLOGY SCREENING
GLT984/040.51-1
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AGENCY REVIEW DRAFT
Appendix A
INITIAL TECHNOLOGY SCREENING
This appendix presents the results of the initial development and evaluation of a
range of remedial technologies for each operable unit. These technologies will be
evaluated in detail later and incorporated into the remedial alternatives. The
technology development process consisted of the following steps:
• Listing general response actions identified in Chapter 3 that could
achieve the remedial action goals for the soil/sediment/landfill contents
and the groundwater/leachate/oil operable units.
• Identifying specific technologies and process options that may feasibly
achieve the purpose of each general response action. This step,
referred to as initial technology screening, identifies potentially
applicable technologies and eliminates technologies and process options
that are not compatible with site conditions.
• Evaluating and screening the potentially applicable technologies and
process options on the bases of their effectiveness, implementability,
and relative cost. This is referred to as detailed screening of
technologies and is documented in Appendixes B, C, and D.
GENERAL RESPONSE ACTIONS
General response actions identified in Chapter 3 describe those actions that will
satisfy the remedial goals outlined in Chapter 2 by either reducing contaminant levels
or reducing the likelihood of contact with existing contaminants. They include actions
such as treatment, containment, removal, disposal, and institutional controls.
Although some response actions may meet the goals alone, combinations of response
A-l
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AGENCY REVIEW DRAFT
actions may meet the goals more effectively. The combining of response actions into
remedial alternatives is discussed in Chapter 3.
The following general response actions were identified for both operable units:
• No action
• Institutional controls and monitoring
• Containment
• Removal
• Treatment
• Disposal
INITIAL TECHNOLOGY DEVELOPMENT AND SCREENING
Several technologies may be identified for each response action, and numerous
process options may exist for a particular technology. Technologies are general
categories capable of achieving a response action. Process options refer to specific
materials, equipment, or methods used to implement a technology. For example,
surface controls, caps, vertical barriers, and horizontal barriers are possible
technologies for the containment response action for the soil/sediment/landfill
contents operable unit. Regrading and covering with soil are process options within
the surface controls technology.
Technologies and process options are first evaluated for applicability. Process options
or technologies that are limited by physical site conditions or waste characteristics are
eliminated from further consideration. This screening step eliminates those
technologies and process options that:
A-2
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AGENCY REVIEW DRAFT
• Will not achieve remedial action goals
• Will fail to meet federal or state ARARs
• Are impractical or difficult to implement given site contaminants and
physical conditions
Figures A-l and A-2 illustrate the initial evaluation of technologies and process
options for the soil/sediment/landfill contents and groundwater/leachate/oil operable
units. The evaluation relied on previous analyses and experience from other studies.
During the initial screening, process options were addressed independently and
without considering potential disadvantages when applied in combination. The figures
briefly describe the technologies and process options and their applicability to the site.
Applicable technologies and process options are retained and evaluated in detail.
DETAILED TECHNOLOGY SCREENING
Incorporating all process options that survive initial screening (Table 4-1) into
detailed alternatives would result in a cumbersome number of combinations. To
reduce the number of alternatives, process options that survived initial screening were
reevaluated based on their effectiveness, implementability, and relative cost. In cases
where several process options have similar evaluations a single process option
considered representative for each technology was selected. Identifying a
representative process option for each technology was not intended to limit the
process options that could be employed in the remedial design, but to provide a basis
for comparison of a manageable number of alternatives.
During detailed evaluation and screening, emphasis was placed on effectiveness and
implementability. Relative cost was used in cases where the evaluation of the first
two criteria did not result in the exclusion of a process option or technology. The
A-3
-------
GENERAL RESPONSE
ACTION
REN
SCREENING COMMENTS
NO ACTION
Required by NCP for detailed analysis of alternatives.
INSTITUTIONAL CONTROLS
Potentially applicable.
Potentially applicable.
0.
O
u.
Q
co
U-
CONTAINMENT.
Potentially applicable for controlling runoff and reducing infiltration if
low permeability soil is used.
Potentially applicable for upgrading existing capped areas.
Not applicable. Not likely that asphalt will provide long-term cap
integrity.
Not applicable. Not likely that asphalt will provide long-term cap
integrity.
Not applicable. High potential for landfill settlement which would
likely crack the concrete.
Potentially applicable for controlling infiltration and runoff.
Potentially applicable for controlling infiltration and runoff.
Potentially applicable for controlling infiltration and runoff.
Not applicable. Integrity of grouts and slurry difficult to establish.
Liner installation woula require excavation of entire landfill areas.
Storage space for 3.2 Million CY is not available onsite.
Potentially viable for entire landfill area.
Potentially viable for entire landfill area.
Continued on
Sheet 2 of 3
TECHNOLOGY NOT RETAI
FIGURE A-1 (Sheet 1 of 3)
SOIL, SEDIMENT, AND
LANDFILL CONTENTS OPERABLE UNIT
INITIAL TECHNOLOGY SCREENING
G & H LANDFILL FS
-------
GENERAL RESPONSE
ACTION REMEDh
SCREENING COMMENTS
Continued from
Sheet 1
CONTAINMENT
Not applicable. Sealants and stabilizers not likely to provide
long-term cap integrity.
Potentially applicable. Likely used in conjunction with a cap or cover.
Not applicable. Stabilizers not likely to provide long-term cap
integrity.
Potentially applicable. Likely used in conjunction with cap or cover.
Potentially applicable. Likely used in conjunction with cap or cover.
Potentially applicable. The slurry must be compatible with the waste
oil and solvents present.
Potentially applicable, continuity of wall is difficult to assess, leakage
may occur.
Potentially applicable, continuity of curtain is difficult to assess,
leakage may occur.
REMOVAL
a:
a
o
<
8
_j
CD
Potentially applicable. Leakage may occur between joints of piles.
Not applicable. Integrity and continuity of barrier difficult to assess.
Potentially applicable.
TECHNOLCX3Y NOT RETAI
FIGURE A-1 (Sheet 2 of 3)
SOIL, SEDIMENT, AND
LANDFILL CONTENTS OPERABLE UNIT
INITIAL TECHNOLOGY SCREENING
G & H LANDFILL FS
-------
GENERAL RESPONSE
ACTION
REMI
SCREENING COMMENTS
'otentially viable for excavated landfill contents, sediments, and soil.
TREATMENT-
'otentially viable for excavated landfill contents, sediment, and soil.
Jot applicable for the oil and solvent saturated landfill contents, soil,
,nd sediment.
'otentially viable for excavated landfill contents, sediments, and soil.
'otentially viable for excavated landfill contents, sediments, and soil.
tot applicable for landfills because of heteroqenity of soijs and
efuse. May be applicable to oil saturated soil near the Oil Seep Area
ind along the railroad grade (See Figure A-2).
Jot applicable. Difficult to implement and achieve good mixing in situ.
^ot applicable. Difficult to implement in landfill.
Q_
o
Jot applicable to heterogenous wastes in landfills. May be applicable
o oil saturated soil near the oil seep area and along the railroad
jrade (see Figure A-2).
Jot applicable to heterogenous wastes in landfills. May cause landfill
ires.
DISPOSAL
Jot applicable. May cause landfill fires if high air extraction rate is
ised. vapor extraction applicable only to VOCs. Semi-VOCs and
noiganic contamination would remain.
'otentially viable. May require a waiver to FtCRA siting requirements,
lecause of the high water table at the site, permeable site soil, and
-pcation near the Clinton River flood plain and associated wetlands.
"he landfill contents and contaminated soil may also require
extensive treatment to meet RCRA land disposal restrictions.
Mot applicable for the large quantity of landfill contents and
contaminated soil. Offsite disposal of 800,000 to 2,600,000 C.Y. at a
3CRA licensed facility is unavailable. May be viable for smaller
quantities of ash or sludge residues from treatment processes.
Q
§
(/)
LL
8
l/l
$
TECHNOLOGY NOT RETAIf
FIGURE A-1 (Sheet 3 of 3)
SOIL, SEDIMENT, AND
LANDFILL CONTENTS OPERABLE UNIT
INITIAL TECHNOLOGY SCREENING
G & H LANDFILL FS
-------
GENERAL RESPONSE
ACTION
REME!
SCREENING COMMENTS
NO ACTION
lequired by NCP for detailed analysis of alternatives.
INSTITUTIONAL CONTROLS
AND MONITORING
'otentially applicable for residents using domestic wells located east
f Ryan Road and industries along Ryan Road.
'otentially applicable.
'otentially applicable.
§
X
o
-------
GENERAL RESPONSE
ACTION REME_
SCREENING COMMENTS
'otentially applicable. Likely to be used in conjunction with other
-eatment processes.
'otentially applicable. Likely to be used in conjunction with other
reatment processes.
'otentially applicable. Likely to be used in conjunction with other
reatment processes.
'otentially applicable. Likely to be used in conjunction with other
reatment processes.
o
HI
_1
tf
Q
tr
o
»
§
d
TREATMENT-
'otentially applicable. Likely to be used in conjunction with other
treatment processes.
Jot applicable. May not remove organics from groundwater.
'otentially applicable.
tot applicable. Contaminants of concern adequately removed by air
.tripping without addition of steam.
'otentially applicable for metals removal, will require sludge handling
ind disposal.
tot applicable. Does not work well for complex waste streams.
^otentially applicable, especially if used in conjunction with ultraviolet
ight.
vlot applicable. Not suitable for most contaminants onsite.
tot applicable. Difficult to implement and not applicable for most
;ontaminants.
Continued on
Sheet 3 of 3
TECHNOLOGY NOT RETAII
FIGURE A-2 (Sheet 2 of 3)
GROUNDWATER, LEACHATE, AND
OIL OPERABLE UNIT
INITIAL TECHNOLOGY SCREENING
G & H LANDFILL FS
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AGENCY REVIEW DRAFT
detailed evaluation and screening of technologies are documented in Appendixes B,
C, and D. Results are summarized in Chapter 4.
GLT959/006.51
A-4
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Appendix B
CONTAINMENT ANALYSIS
GLT984/040.51-2
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AGENCY REVIEW DRAFT
Appendix B
CONTAINMENT ANALYSIS
INTRODUCTION
This appendix presents the results of the detailed evaluation and screening of
applicable containment technologies and process options. Containment technologies
that survived the initial screening (see Appendix A) are:
• Surface controls
• Soil cover
• Single layer cap
• Multilayer cap
• Vertical barriers
CONTAINMENT GOALS
Remedial goals that pertain primarily to containment are:
• Prevent direct human contact with contaminated media
• Control leaching of hazardous substances from the landfill contents and
oil-saturated soil to groundwater
• Control migration of separate phase liquids (e.g., floating oil) containing
hazardous substances
• Control contaminated groundwater to prevent ingestion of groundwater
with contaminants that exceed the MCLs or non-zero MCLGs, have a
total excess lifetime cancer risk of 1 x 10"4 to 1 x 10"6, or a hazard index
of one or more
B-l
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AGENCY REVIEW DRAFT
• Prevent releases of contaminated groundwater that would cause the
contamination levels in the Clinton River or nearby wetlands to exceed
surface water criteria for protection of aquatic life
OBJECTIVE AND APPROACH
The objective of the screening of technologies and process options was to reduce their
number for subsequent assembly into alternatives. This was done so that a
manageable number of alternatives could be considered during detailed analysis of
alternatives. The screening criteria used were effectiveness, implementability, and
relative cost. Effectiveness pertains to the ability to protect human health and the
environment and to satisfy remedial goals. Implementability is associated with
compliance with ARARs, constructability, and time period. Relative cost includes
capital, operational, and maintenance costs.
The containment technologies under consideration would help to achieve the
remedial goals in two ways. Capping technologies would prevent direct human
contact with contaminated surface soil and control leaching of hazardous substances
from contaminated source areas. Vertical barriers would control lateral migration of
hazardous substances in groundwater, control the volume of contaminated
groundwater that exceeds health-based criteria, and prevent releases of contaminated
groundwater to surface water bodies.
CAPPING TECHNOLOGIES
The selection of capping technologies focused on those technologies that could meet
the intent of the regulations and demonstrate some degree of protection of human
health and the environment. Capping effectiveness, estimated in terms of a reduction
in generated leachate, will be compared to current site conditions.
B-2
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AGENCY REVIEW DRAFT
CLOSURE REGULATIONS
Either RCRA Subtitle C or D closure regulations will likely be enforced at the site.
It is possible that a combination of closure regulations could be used for the various
landfills onsite. The State of Michigan has the authority to enforce either regulation
under Act 64 (corresponding to a Subtitle C closure) or Act 641 (corresponding to a
Subtitle D closure). This section outlines the requirements for both types of closure.
Subtitle C Closure
RCRA regulatory requirements 40 CFR 264.310 stipulate that the landfill cover must:
• Provide long-term minimization of migration of liquids through the
closed landfill
• Function with a minimum of maintenance
• Promote drainage and minimize erosion or abrasion
• Accommodate settlement and subsidence so that its integrity is
maintained
• Have a permeability less than or equal to the permeability of any
bottom liner system or natural subsoil present
In addition to the requirements of 40 CFR 264.310, Michigan State Hazardous Waste
Rules R 299.9619 stipulate that the landfill cover must meet the following criteria:
• It must have a minimum 3-foot-thick layer of compacted clay. The clay
must be classified as CL or CH under the Unified Soil Classification
System (USCS), and 25 percent of the soil particles must be less than
5 microns in size. The clay must be compacted to no less than
B-3
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AGENCY REVIEW DRAFT
90 percent of the maximum dry density as determined by the modified
Proctor test, and it must have a moisture content within the range of
-2 to +5 percent of the optimum moisture content. The permeability
coefficient of the compacted clay barrier must be 1.0 x 10"7 cm/s or less.
• At least 2 feet of topsoil and subdrainage material must be placed over
the compacted clay barrier to protect it from the effects of temperature,
erosion, rooted vegetation, and burrowing animals.
• Shallow-rooted vegetation must be established and maintained to
prevent erosion.
• A venting system must be installed to prevent the accumulation of gas
beneath the clay barrier.
Subtitle D Closure
State of Michigan Solid Waste Rules R 299.4305 stipulate that a sanitary landfill
cover must meet the following criteria:
• It must have a minimum 2-foot-thick layer of compacted soil. The soil
must be classified as ML, SC, CL, or CH under USCS. The soil must
be compacted to no less than 90 percent of the maximum dry density as
determined by the modified Proctor test, and it must have a moisture
content within the range of -2 to +5 percent of the optimum moisture
content.
• Slopes must not exceed 1 vertical to 4 horizontal or as necessary to
establish vegetation. Slopes must not be less than 2 percent. Post-
construction settlement must be monitored for 5 years and the cover
maintained to compensate for settlement.
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AGENCY REVIEW DRAFT
• Landfill gases must be controlled and prevented from migrating.
CURRENT SITE CONDITIONS
In general, the landfill covers do not promote surface runoff or prevent erosion under
current site conditions. Current site conditions and their corresponding effect on
capping technologies are summarized in Table B-l.
SURFACE CONTROLS
Surface controls would consist of grading, vegetation, and diversion systems. These
activities are intended to promote surface runoff and minimize erosion. Surface
controls will be incorporated with other capping technologies; however, they will not
be considered alone as potential alternatives for the following reasons:
• Existing landfill covers are not thick enough throughout the entire
landfill to meet minimum State of Michigan regulations.
• Existing covers could not be adequately sloped (to 2 percent or
3 percent) by reshaping the existing cover material.
• The Phase I Landfill cover is too sandy to minimize infiltration and is
contaminated with PCBs and pesticides.
Site Grading Plan
A conceptual site grading plan was prepared to estimate volumes of soil required to
grade the site to drain (Figure B-l). This plan was developed only to estimate
potential quantities of materials for cost estimating and implementability
considerations. The following assumptions were used in developing the grading plan:
• Minimum slope (except for swales) = 2 percent and 3 percent
B-5
-------
Table B-l
CURRENT SITE CONDITIONS AND THEIR AFFECT ON CAPPING
TECHNOLOGIES
Current Site Conditions
Affect on Capping Technologies
The site area is relatively flat. Local
drainage is primarily north to south with
a grade ranging from 0.5 to 1 percent.
The surface soils of property
surrounding the site are primarily sand
and silty sand. Drainage ditches onsite
and nearby do not grade evenly and
contain ponded areas.
Drainage ditches on and nearby the site
would require upgrading to control
runon and runoff.
Available onsite soil consists of sand
and silty sand; clay would have to be
imported.
The Phase I Landfill cover consists of
zero to 3 feet of silty sand. The cover
contains numerous depressions and
reverse drainage slopes. Cover soils are
contaminated with PCBs (detected
concentrations were in the range of 200
to 2,000 ng/kg) and pesticides (detected
concentrations were in the range of 10
to 500 jig/kg).
Existing cover is poorly designed and
maintained to promote runoff and
reduce infiltration; it would not meet
Subtitle C or D closure requirements.
If cut and fill techniques are used on
the existing cover to improve grading,
the potential for health and
environmental risks would exist from
airborne releases.
The Phase II and III Landfill covers
consist of 1 to 3 feet of silt or silty clay.
Both landfill covers contain depressions
and reverse drainage slopes. Sideslopes
of both landfills are steep (ranging from
1V:2H to 1V:5H) and severely eroded.
Existing cover is poorly maintained to
promote runoff and control erosion;
would not meet Subtitle C or D closure
requirements.
Sideslopes steeper than IV: 3H would
require special construction to control
erosion.
The west Sideslopes of the Phase III
Landfill terminates in wetlands near the
100 year flood stage water level.
Reducing the slope would involve
further encroachment on the flood
plain or excavation of landfill contents.
GLT959/032.51
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AUTG&108SLE
DISPOSAL
YARD
SCALE IN FEET
FIGURE B-1
GRADING PLAN WITH
2 PERCENT GRADE
G & H LANDFILL FS
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AGENCY REVIEW DRAFT
• Minimum drainage channel or swale slope = 0.5 percent
• Maximum sideslope = 1V:2H
• No grade cuts allowed into existing Phase I Landfill cover or any landfill
contents; grade cuts up to 1 foot allowed in the Phase II and III Landfill
covers
• Swales allowed over the landfills to reduce fill quantities
The grading plan was developed by initially laying out drainage channels. Grade
contours were then established for both 2 percent and 3 percent slopes. The low
points of the drainage channels were placed at existing site elevations, or above those
elevations as necessary to meet the assumption that grade cuts would not be allowed
(elevations were based on the 1984 site topography map). It may be necessary to
provide a lining for drainage channels to minimize leakage through these areas of
concentrated surface runoff. Drainage channels will require erosion protection.
The estimated quantity of soil required to grade the site varies from 220,000 cubic
yards for a 2 percent slope to 300,000 cubic yards for a 3 percent slope. Average fill
heights for the Phase I Landfill would be 2.5 feet (2 percent grade) to 3.5 feet
(3 percent grade), and for Phases II and III Landfills it would be 1 foot (2 percent
grade) and 1.5 feet (3 percent grade).
Vegetation
Landfill cover vegetation should:
• Be locally adaptable, perennial plants that are resistant to drought and
temperature extremes
• Be capable of thriving in low-nutrient soil
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AGENCY REVIEW DRAFT
• Be shallow-rooted to the extent that it does not disrupt the integrity of
any underlying low-permeability layers
• Be dense enough to limit erosion
• Be capable of surviving with little maintenance
Another site-specific consideration for the G&H Landfill is the residential setting of
the site area. An aesthetically pleasing landscape should be developed. A prairie
with wildflowers could be established at the site to meet those criteria and
considerations. A prairie would be cost effective because it would eliminate the need
for importing large quantities of topsoil and it could be maintained without annual
site fertilization.
A prairie would require annual controlled burns to maintain diversity of plantlife, in
particular the wildflowers. A controlled burn may not be allowed because of
potential hazards of underground fire caused by landfill gases and because it would
create nuisance smoke for neighbors for the duration of the burn. If burning at the
site is not allowed in the future, the prairie could be maintained by mowing; however,
plant diversity would be lost and dominant plant species would eventually take over
the site. For cost estimating purposes, it was assumed that a prairie would be
established.
SOIL COVER
A soil cover would consist of grading the site per the site grading plan using imported
soil. Vegetation and drainage channels (swales) would be incorporated into the final
grading plan to promote runoff and minimize erosion. Runon from north of the site
would be diverted and discharged to the wetlands south or west of the site.
A soil cover would meet Subtitle D closure requirements if the imported soil were
classified ML, SC, CL, or CH under USCS and if the cover were constructed to
B-7
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AGENCY REVIEW DRAFT
2 percent minimum grades. The requirement for maximum 1V:4H slopes could not
be met on the west side of Phase III Landfill without adding material to the toe or
cutting material from the top of the landfill. These actions would either cause further
encroachment on the flood plain and destruction of wetlands or require removal
technologies. The intent of the requirement for a maximum allowable slope is to
provide a slope that can be vegetated and maintained, thus minimizing erosion.
Vegetation could be established on a 1V:2H slope by stapling or nailing erosion
control mats to the sideslopes before seeding, and provisions could be made for long-
term site maintenance. Thus, 1V:2H slopes could be designed to meet the intent of
minimizing erosion and maintenance.
A soil cover would reduce the possibility of direct contact with contaminated surface
soil or landfill waste, and contaminant transport by wind or runoff. In addition, the
cover would reduce leachate generation by increasing the soil moisture storage
capability of the surface and increasing runoff. Based on the water balance model, it
is estimated that total leachate generation could be reduced approximately 60 percent
(see Attachment B-l).
SINGLE LAYER CAP
A single layer cap would be a soil cover using clay (note that sandy clay or silt could
be used to meet the requirements assumed for the soil cover). A single layer cap was
not carried forward because it is considered under the soil cover technology.
MULTILAYER CAP
A multilayer cap consists of a low permeability barrier layer covered with other layers
serving various design functions. Figure B-2 presents conceptual sections of the three
types of multilayer caps retained following initial screening. All three multilayer caps
would have a gas venting system to prevent pressure from landfill gas from damaging
the cap.
B-8
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AGENCY REVIEW DRAFT
It was assumed that the site would require grading to minimum 3 percent slopes
before installation of a multilayer cap. A 3 percent minimum grade would be
consistent with guidelines for RCRA Subtitle C closure requirements (EPA 1989). It
was estimated that 300,000 cubic yards of soil would be imported to the site to
achieve a minimum grade of 3 percent (see "Site Grading Plan").
Soil-Clay Cap
The soil-clay cap (Figure B-2a) would meet minimum requirements for Subtitle C
closure; however, it would not meet established RCRA guidelines. The cap would
consist of a 3-foot-thick clay barrier overlain by 3.5 feet of fill. In addition to the
estimated 300,000 cubic yards of fill required to establish a 3 percent grade,
approximately 280,000 cubic yards of clay and 330,000 cubic yards of fill would be
required.
The clay barrier would be compacted to achieve a permeability of 1 x 10"7 cm/s or
less. However, soft subgrade conditions may limit the compactive effort applied
during construction, and settlement could distort and crack the clay barrier. The clay
barrier would not have the required permeability if these conditions occurred.
Assuming that an average permeability of 2 x 10"7 cm/s could be achieved, the
leachate generated could be reduced by approximately 80 percent (see
Attachment B-l).
The 3.5 feet of fill would protect the clay barrier from damage caused by frost
penetration, desiccation, burrowing animals, and deep roots. The fill should consist of
enough fine-grained soil to retain and provide moisture for vegetation.
Soil-Drain-FML Cap
A soil-drain-flexible membrane lining (FML) cap (Figure B-2b) would consist of a
flexible membrane liner overlain by a 1-foot drainage layer and 2.5 feet of fill. The
soil-drain-FML cap would not meet minimum state requirements of a 3-foot-thick
B-9
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AGENCY REVIEW DRAFT
compacted clay barrier. It would, however, meet the intent of this requirement if it
could be constructed to achieve a permeability of 1 x 10"7 cm/s or less.
A properly installed FML is nearly impermeable, and as such would practically
eliminate leachate generation. However, the reliability of an FML acting as the only
barrier is unknown. Improperly welded seams or ruptures could greatly reduce the
FMLs effectiveness, and large settlements could cause rips. In addition, the longevity
of FMLs is unknown. Because their reliability is unknown, the long-term permeability
cannot be predicted, so a water balance was not estimated for the soil-drain-FML cap
option.
Soil-Drain-Composite Cap
A soil-drain-composite cap (Figure B-2c) would be the same as the soil-drain-FML
cap except that the barrier layer would consist of a 3-foot-clay layer combined with
the FML. The soil-drain-composite cap would meet both Subtitle C regulations and
guidelines (U.S. EPA 1989). This is the most effective cap because it combines the
flexibility and low permeability of the FML with the longevity of clay. Leaks through
the FML would be impeded by the clay. Based on the water balance model, it is
estimated that leachate generation could be reduced by more than 95 percent (see
Attachment B-l).
The drainage layer over the FML allows water that infiltrates the surface to drain
laterally. This limits the hydraulic head acting on the barrier layer, thus reducing the
rate of percolation through the barrier. A drainage layer also prevents the cover soil
from becoming saturated to the surface, causing muddy and unstable conditions. The
drainage layer could consist of sand, gravel, and perforated pipe, or a geosynthetic
drain.
The overlying fill functions in the same manner as the soil-clay cap. The fill layer
would be only 2.5 feet thick, provided the drainage layer contained 1-foot of sand and
gravel. If a geosynthetic drain were used, the fill layer would have to be 3.5 feet thick
B-10
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AGENCY REVIEW DRAFT
to provide frost protection. A geotextile filter would be placed between the fill and
sand to prevent migration of fines into the drain. A geotextile would also be placed
on top of the FML to protect it from damage during construction.
SUMMARY OF CAPPING TECHNOLOGIES
All capping options consist of earthwork construction, a relatively low-technology
process making use of commonly available construction equipment, personnel, and
materials. Table B-2 summarizes the estimated quantities, times to construct, and
capital costs of the capping options. These estimates were made to assess differences
between each capping option, and it was assumed that each capping option is a
sitewide action (i.e., the same cap over all the landfills) and the only action taken.
All capping options are subject to the following additional considerations:
• Periodic inspections and maintenance to upkeep vegetation, correct
grade reversals caused by settlement, cracks caused by desiccation and
frost action, and holes from burrowing animals will be required.
Maintenance procedures would range from relatively simple and
inexpensive for the soil cover to more difficult and costly for the soil-
drain-composite cap.
• Construction in this growing residential area will create public
inconveniences. Increased truck traffic will cause traffic problems in the
area; Ryan Road and 23 Mile Road are 2-lane streets. In addition,
roadways may be damaged due to repeated heavy truckloads. It may
be feasible to construct a spur line on the existing railroad grade for
hauling materials to the site; however, this consideration is outside the
scope of the FS. Construction could also cause noise and dust problems
for neighbors, but this problem is manageable. Any such public
inconveniences will last as long as the construction takes.
B-ll
-------
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PPING OPTIONS(a)
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Imported soil requirements:
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Time to construct = 0.5 year
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-------
AGENCY REVIEW DRAFT
Three capping options were retained for assembly into alternatives:
• Soil cover, because it meets Subtitle D closure regulations, reduces
leachate generation by an estimated 60 percent, and has a lower relative
cost
• Soil-clay cap, because it may be permitted under a Subtitle C closure,
reduces leachate generation by an estimated 80 percent, and has a mid-
range cost
• Soil-drain-composite cap, because it meets Subtitle C closure regulations
and guidelines and reduces leachate generation by an estimated
95 percent, and has a relatively high cost
The soil-drain-FML cap was not carried forward because its reliability is unknown,
thus its effectiveness could not be estimated. In addition, it would be similar in cost
to the soil-clay cap and would therefore fall within the range of costs for the caps
being carried forward.
VERTICAL BARRIER
CURRENT SITE CONDITIONS
Groundwater in the upper aquifer becomes contaminated as it passes through the site
and migrates toward the Clinton River. This is caused by vertical percolation of
water through the waste mass to the upper aquifer and by groundwater flow through
zones of buried waste. Groundwater flow beneath the site in the upper aquifer was
estimated to range from 40 to 180 gpm (see Appendix C). Based on a comparison of
upper aquifer groundwater contours and the depth of buried waste at the site,
groundwater is in direct contact with waste in several locations of the Phase I Landfill
(see Figure B-3).
B-12
-------
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-------
AGENCY REVIEW DRAFT
A landfill cap by itself would reduce but not eliminate the rate of vertical percolation
through the buried waste mass. Also, a cap would not prevent all direct contact
between buried waste and groundwater. A vertical barrier is required to achieve this.
Vertical barriers are low-permeability walls constructed below ground surface to
reduce the quantity and velocity of groundwater flow.
ALIGNMENT AND ANCILLARY REMEDIAL MEASURES
The effectiveness of a vertical barrier is determined in large part by its horizontal and
vertical alignment, as well as the ancillary remedial measures applied in conjunction
with it.
Vertical Alignment
There are two choices for vertical alignment: a hanging wall or a keyed-in wall.
A hanging wall is effective at controlling contaminants that float on the groundwater,
such as petroleum products. The sheet pile wall already installed south of the oil
seepage area is an example of a hanging wall. A hanging wall would be used only as
a downgradient interceptor. In typical applications, the vertical barrier is keyed into a
low-permeability subsoil to minimize groundwater flow beneath the wall and contain
contaminants that mix with groundwater and sink to the bottom of the aquifer.
The containment goals for this site include control of both separate phase oil and
contaminated groundwater. Although a hanging wall may be effectively incorporated
into an oil phase collection system, it would not be effective for containing other site
contaminants that are mixing with groundwater and migrating offsite. For this reason
a keyed-in vertical barrier was retained for evaluation. The vertical barrier would be
keyed into the silt and clay layer, which underlies the site.
B-13
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AGENCY REVIEW DRAFT
Horizontal Alignment
There are three choices for horizontal alignment: upgradient wall, downgradient wall,
and circumferential wall.
An upgradient wall would divert uncontaminated groundwater around the site. This
type of placement is effective at sites where there is a relatively steep hydraulic
gradient so that water can be collected at the upgradient location and drained by
gravity to a lower elevation. Because the site and hydraulic gradient are flat, this type
of wall alignment by itself would not be effective because groundwater would
eventually flow around the backside of the wall.
A downgradient wall would be used as a barrier to contain contaminated groundwater
as it leaves the site. This placement would not limit the amount of uncontaminated
groundwater entering the site, and it could raise the water table in the zone of buried
waste without a properly designed extraction system. To be effective, the wall would
require collection and treatment of all groundwater leaving the site.
A circumferential wall would provide complete containment of landfill contents and
oil-saturated soils at the site. It would limit migration of groundwater onto the site,
through the waste, and offsite. To be effective, some groundwater extraction would
be required to prevent water from rising inside the wall and causing overtopping or
reverse gradient conditions.
At this site, a circumferential slurry wall would be most effective at achieving the goal
of containing contaminated groundwater. In addition, the extraction rates associated
with the required control of hydraulic gradients would be minimized by using a
circumferential wall because groundwater entering the site would be reduced. For
these reasons a circumferential horizontal alignment was retained for further
evaluation.
B-14
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AGENCY REVIEW DRAFT
Although several circumferential alignments were considered during the study, only
one was retained (Figure B-4). It was selected because:
• It would encircle all known waste sources at the site and could
effectively seal them off from the upper aquifer.
• It would encircle most of the groundwater contaminant plume (as
identified in the RI) with contaminant levels greater than established
criteria (i.e., MCLs, MCLGs, etc.).
Ancillary Remedial Measures
Some ancillary remedial measures implemented in conjunction with the vertical
barrier would be required to achieve containment goals. For example, groundwater
extraction would be required to prevent buildup of head that could result in
contaminated groundwater overtopping the barrier. Additional remedial measures
could be implemented to improve the performance of the barrier. For example, a
cap could be installed (although it would not be required) to minimize infiltration of
water and thus minimize required extraction rates.
The groundwater table upgradient of the barrier will likely rise; however, the amount
of rise and the area of mounding cannot be predicted at this time. This could
potentially create problems in the residential area just north of the site. Various
measures could be implemented if necessary to control such a groundwater mound:
• An upgradient drain or line of extraction wells could withdraw water
from the area and divert it to the Clinton River.
• One or more overflows could be installed at the ponds north of the site
and a culvert could drain water from the area to the Clinton River.
B-15
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AGENCY REVIEW DRAFT
Extraction of groundwater from the inside of the barrier would be required to prevent
the eventual rise of water and overtopping of the barrier by contaminated
groundwater. Extraction would increase the effectiveness of the barrier by creating
an inward hydraulic gradient. This would increase the reliability of groundwater
containment and decrease the potential for chemical degradation of the barrier.
It has been estimated that the groundwater extraction rate for gradient control is
2 gpm, and that 30 gpm of water infiltrates through the landfill surface (see
Appendix C, Section Vertical Barriers). Thus, surface infiltration is a primary route
of water to the waste mass. A cap in conjunction with the vertical barrier could
greatly reduce groundwater extraction and treatment requirements. Since it is likely
that a landfill cap will be required at the site to meet closure regulations, it has been
assumed that a soil-clay cap will be installed in conjunction with a vertical barrier.
TECHNOLOGY SCREENING
Comparison and Screening
Potential vertical barrier technologies include slurry walls, vibrating beam walls, and
grout curtains.
Slurry walls are constructed by excavating a trench that is kept filled with a bentonite
slurry. The slurry provides temporary stabilization of the trench walls. The trench is
backfilled using a mixture of soil-bentonite or soil-cement-bentonite.
Vibrating beam walls are constructed by advancing a vibrating steel beam into the
ground and injecting a bentonite or bentonite-cement slurry as the beam is withdrawn.
The wall is constructed by successive placement of sections side-by-side.
Grout curtains are constructed by temporarily installing vertical pipes in the ground
and injecting a bentonite-cement grout through them. The grouted holes are typically
staggered with a three row deep spacing in an attempt to ensure continuity.
B-16
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AGENCY REVIEW DRAFT
Slurry walls effectively retard the migration of groundwater and have reported
in-place permeabilities in the range of 10~9 to 10~5 cm/s. The effectiveness of vibrating
beam walls and grout curtains is questionable because it is difficult to ensure
continuity of the barrier. Vibrating beam and grout curtain technologies have limited
performance experience, whereas slurry walls have been used effectively at other
hazardous waste sites. The effectiveness of each technology may be reduced by
exposure to organic compounds at the site, which could increase permeability.
The implementability of the three technologies is similar. Each method would require
a specialty contractor, and each would require similar quantities of imported
bentonite. Vibrating beam walls would require the least amount of area to construct,
and slurry walls would require the most. There is enough available area onsite to use
any of the technologies; however, there are limitations on using landfilled areas for
bentonite slurry hydration ponds. Construction time for a slurry wall and grout
curtain would be similar, whereas a vibrating beam wall could be constructed in less
time.
The costs of the technologies vary from relatively low for a vibrating beam wall to
relatively high for a grout curtain. The cost of a slurry wall would be somewhere
between these two. Based on this initial evaluation, the slurry wall technology was
retained for further evaluation because it would provide the most reliable barrier at a
relatively middle range cost.
Slurry Wall
Soil-bentonite (SB) slurry walls typically have a lower permeability and would cost less
than soil-cement-bentonite (SCB) slurry walls. SCB slurry walls have a higher
strength that may be required at road or driveway crossings, buried utility line
crossings, or steep (greater than 2 percent) grade crossings. Since a SB slurry wall
provides lower permeability at a reduced cost, it is considered more suitable for the
site than an SCB slurry wall.
B-17
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AGENCY REVIEW DRAFT
The effectiveness of a slurry wall depends on various factors:
• Its dimensions and configuration and use of ancillary groundwater
control methods (i.e., diversion and extraction)
• Backfill composition and characteristics (i.e., gradation, water content,
presence of deleterious materials or organic compounds)
• Method of construction (primarily the mixing and placement phase)
• Post-construction conditions, such as high hydraulic gradients across the
wall or attack by organic compounds in the groundwater
The slurry wall would be keyed 3 feet or more into the till unit underlying the sand
and silty sands that comprise the upper aquifer. Native soils excavated from the
upper sand unit would consist primarily of sand and silty sand with some gravel.
Depending on the fines content of the upper sands, it may be necessary to import
clay to the site to increase the fines content of the soil-bentonite backfill and reduce
permeability.
The slurry wall construction operation requires area to locate slurry hydration ponds
and to mix backfill materials. The use of hydration ponds at the site would be limited
to areas outside the landfill boundaries. Remote mixing of backfill or use of a
pugmill would be necessary for construction of a wall through the wetlands on the
south side, unless a path approximately 50 to 100 feet wide is cleared through the
area.
In areas of high organic concentrations, such as downgradient of the oil seepage area,
the SB slurry wall may be subjected to shrinkage and dehydration. This could cause
degradation of the wall during its service life or prevent the initial swell of the
bentonite required to hold the trench open during construction. Compatibility testing
of the SB mixture and the anticipated waste stream should be performed before
B-18
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AGENCY REVIEW DRAFT
construction to design a mixture that functions properly and maintains its integrity.
The wall could be further protected during its service life by minimizing contact with
contaminants through the use of extraction wells or drains.
SUMMARY OF VERTICAL BARRIER TECHNOLOGY
A slurry wall will be retained for incorporation into alternatives. The slurry wall
could encircle the known buried waste at the site and be keyed into the underlying silt
and clay. The estimated length and square footage of the slurry wall are 7,100 feet
and 240,000 square feet, respectively.
Groundwater extraction and treatment will be required in conjunction with the slurry
wall to prevent overtopping. It is assumed that a landfill cap will be constructed
because it reduces the extraction volume and because it will likely be required to
meet ARARs. An estimated 10 gpm of groundwater will be extracted and treated
under steady state conditions.
GLT959/030.51
B-19
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AGENCY REVIEW DRAFT
Attachment B-l
WATER BALANCE
This section presents the assumptions, calculations, and results of water balance
models for the Phase I, II, and III landfills. Percolation estimates obtained from the
models were then used to predict quantities of leachate produced and to compare the
relative effectiveness of different cover options. The following conditions were
investigated:
• Current site conditions (no action)
• Soil cover option
• Soil-clay cap option
• Soil-drain-composite cap option
CLIMATIC DATA
One set of climatic data were used in the water balance model for each percolation
estimate. Recorded mean monthly precipitation and temperature data for the 30-year
period from 1950 to 1980 were obtained from the Pontiac Hospital Weather Station
approximately 10 miles from the site (NOAA 1982).
Potential evapotranspiration (PET) rates were estimated using the temperature data,
heat index, and length of days for the site latitude of 43° north (Thornthwaite and
Mather 1957). The calculation of PET is given in Table 1.
-------
ATTACHMENT B-1
TABLE 1
CALCULATION OF POTENTIAL EVAPOTRANSPIRATION FOR THE G&H LANDFILL SITE
Site Latitude (degrees) = N43
PARAMETER
Temperature
Heat Index
Unadjusted PET
Day Length
(in 12 hour days)
PET
JAN
22.4
24.30
0.00
FEB
24.7
24.60
0.00
MAR
34.1
0.10
0.00
30.60
0.00
APR
47.2
2.21
0.04
33.60
1.34
MAY
58.4
5.10
0.09
37.80
3.40
JUN
67.9
8.12
0.13
38.40
4.99
JUL
72.1
9.60
0.14
38.70
5.42
AUG
70.5
9.03
0.14
36.00
5.04
SEP
63.5
6.66
0.11
31.20
3.43
OCT
52.3
3.43
0.06
28.50
1.71
NOV
39.5
0.76
0.02
24.30
0.49
DEC
27.8
23.10
0.00
ANNUAL
48.4
45.0
NOTES:
1. Reference: Thornthwaite and Mather. Instructions and Tables for Computing Potential Evapotranspiration and the
Water Balance. Publications in Climatology. Volume'X, Number 3. Drexel Institute of Technology. 1957.
2. Weather data obtained from Pontiac State Hospital weather station for the period 1951 through 1980.
3. Temperature expressed in degrees Fahrenheit, potential evapotranspiration (PET) expressed in inches.
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AGENCY REVIEW DRAFT
ASSUMPTIONS AND CALCULATIONS
The water balance was estimated using the Water Balance Method (U.S. EPA 1975),
which accounts for precipitation, evapotranspiration, surface water runoff, infiltration,
soil moisture storage, and percolation. Besides the assumptions inherent to the water
balance model (U.S. EPA 1975), specific assumptions were required for each water
balance calculation.
For the purpose of estimating the water balance for existing site conditions, the site
was separated into two parts. This was done because the Phase II and III landfills
have similar existing cover characteristics that are different from the Phase I Landfill.
The primary difference is in the type of cover material, which affects the soil moisture
storage at field capacity. Although the Phase II and III landfills have steep sideslopes
that would promote significant runoff, the water balance calculation herein considers
the top landfill surface. Since all three landfills have numerous surface depressions
and reverse slopes, the same runoff coefficient was selected for all three.
For the purpose of estimating the water balance for the various capping options, the
site was considered as a whole. This was done because the assumed conditions for
any capping option would hold regardless of which site area is being considered.
The water balance method was modified for the soil-clay cap and soil-drain-composite
cap to include the saturated permeability of the barrier layer as a limiting factor on
the net percolation. For the soil-clay cap option, it was assumed that if excess water
(i.e., water that infiltrates the surface soil cover but not the underlying clay barrier)
becomes available for any month, it will be added as additional infiltration the next
month. This assumption is reasonable because it has the effect of keeping the upper
soil layer saturated for a longer period of time. For the soil-drain-composite cap
option, it was assumed that excess water will be removed from above the clay barrier
by the drainage layer.
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AGENCY REVIEW DRAFT
Specific assumptions and calculations are given below for existing site conditions and
each grading and capping condition.
PHASE I LANDFILL—EXISTING SITE CONDITIONS
1. Soil moisture storage at field capacity = 3 inches (silty sand with
shallow rooted vegetation)
• Existing cover is predominantly silty sand to sandy silt that is
zero to 3 feet thick.
• Vegetation is mostly weeds and grasses; it is not dense.
2. Runoff coefficient = 0.05 (lawns, sandy soil with less than 2 percent
grade)
• Landfill is not graded to promote runoff. There are numerous
depressions and reverse slopes.
3. See Table 2 for water balance calculation.
PHASE II AND IH LANDFILLS—EXISTING SITE CONDITIONS
1. Soil moisture storage at field capacity = 4 inches (silty clay with shallow
rooted vegetation)
• Existing covers are predominantly silty clay that is 1 to 3 feet
thick.
• Vegetation on the Phase II Landfill is mostly weeds and grasses;
it is not dense. The Phase III Landfill is not vegetated.
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ATTACHMENT B-1
TABLE 2
WATER BALANCE CALCULATION FOR EXISTING CONDITIONS AT THE PHASE I LANDFILL
Soil Water Storage (inch) = 3
PARAMETER
PET
P
C(R/0)
RO
I
I-PET
SUM NEG(I-PET)
ST
DEL ST
AET
PERC
JAN
0.00
1.55
0.05
0.08
1.47
1.47
0.00
3.00
0.00
0.00
1.47
FEB
0.00
1.36
0.05
0.07
1.29
1.29
0.00
3.00
0.00
0.00
1.29
MAR
0.00
2.25
0.05
0.11
2.14
2.14
0.00
3.00
0.00
0.00
2.14
APR
1.34
2.87
0.05
0.14
2.73
1.38
0.00
3.00
0.00
1.34
1.38
MAY
3.40
2.75
0.05
0.14
2.61
-0.79
-0.79
2.29
-0.71
3.32
0.00
JUN
4.99
3.52
0.05
0.18
3.34
-1.65
-2.44
1.29
-1.00
4.34
0.00
JUL
5.42
2.82
0.05
0.14
2.68
-2.74
-5.18
0.50
-0.79
3.47
0.00
AUG
5.04
3.05
0.05
0.15
2.90
-2.14
-7.32
0.24
-0.26
3.16
0.00
SEP
3.43
2.36
0.05
0.12
2.24
-1.19
-8.51
0.15
-0.09
2.33
0.00
OCT
1.71
2.31
0.05
0.12
2.19
0.48
0.00
0.63
0.48
1.71
0.00
NOV
0.49
2.31
0.05
0.12
2.19
1.71
0.00
2.34
1.71
0.49
0.00
DEC
0.00
2.15
0.05
0.11
2.04
2.04
0.00
3.00
0.66
0.00
1.39
ANNUAL
29.3
1.5
20.2
7.7
AVERAGE DAILY PERCOLATION PER ACRE = 570.6 gpd/acre
NOTES:
1. Reference: U.S. EPA. Use of the Water Balance Method for Predicting Leachate Generation from Solid Waste Disposal
Sites. EPA/530/SW-168. October 1975.
2. The parameters are:
T = mean monthly temperature
PET = potential evapotranspiration
P = mean monthly precipitation
C(R/0) = surface runoff coefficient
R/0 = surface runoff
I = infiltration
ST = soil moisture storage
DEL ST = change in soil moisture storage
AET = actual evapotranspirat ion
PERC = percolation
3. All parameters are expressed in units of inches, except temperature which is in degrees Fahrenheit.
-------
AGENCY REVIEW DRAFT
2. Runoff coefficient = 0.05 (lawns, medium soil with less than 2 percent
grade)
• Landfills are not graded to promote runoff. There are numerous
depressions and reverse slopes.
3. See Table 3 for water balance calculation.
SOIL COVER
1. Soil moisture storage at field capacity = 10 inches (clay loam with deep
rooted vegetation)
• Cover would consist of clay loam at least 3.5 feet thick.
• Site would be vegetated with prairie grasses.
2. Runoff coefficient = 0.15 (lawns, heavy soil with 2 percent grade)
• Minimums slope on landfill would be 2 percent. Minimum slope
of lined swales would be 0.5 percent.
3. See Table 4 for water balance calculation.
SOIL-CLAY CAP
1. Soil moisture storage at field capacity = 10 inches (same as the regrade
and cover option)
2. Runoff coefficient = 0.18 (lawns, heavy soil with 3 percent grade)
-------
ATTACHMENT B-1
TABLE 3
WATER BALANCE CALCULATION FOR EXISTING CONDITIONS AT THE PHASE II AND III LANDFILLS
Soil Water Storage (inch) = 4
PARAMETER
PET
P
CCR/0)
RO
I
I-PET
SUM NEG(I-PET)
ST
DEL ST
AET
PERC
JAN
0.00
1.55
0.05
0.08
1.47
1.47
0.00
4.00
0.00
0.00
1.47
FEB
0.00
1.36
0.05
0.07
1.29
1.29
0.00
4.00
0.00
0.00
1.29
MAR
0.00
2.25
0.05
0.11
2.14
2.14
0.00
4.00
0.00
0.00
2.14
APR
1.34
2.87
0.05
0.14
2.73
1.38
0.00
4.00
0.00
1.34
1.38
MAY
3.40
2.75
0.05
0.14
2.61
-0.79
-0.79
3.26
-0.74
3.35
0.00
JUN
4.99
3.52
0.05
0.18
3.34
-1.65
-2.44
2.13
-1.13
4.47
0.00
JUL
5.42
2.82
0.05
0.14
2.68
-2.74
-5.18
1.06
-1.07
3.75
0.00
AUG
5.04
3.05
0.05
0.15
2.90
-2.14
-7.32
0.61
-0.45
3.35
0.00
SEP
3.43
2.36
0.05
0.12
2.24
-1.19
-8.51
0.45
-0.16
2.40
0.00
OCT
1.71
2.31
0.05
0.12
2.19
0.48
0.00
0.93
0.48
1.71
0.00
NOV
0.49
2.31
0.05
0.12
2.19
1.71
0.00
2.64
1.71
0.49
0.00
DEC
0.00
2.15
0.05
0.11
2.04
2.04
0.00
4.00
1.36
0.00
0.69
ANNUAL
29.3
1.5
20.9
7.0
NOTES:
AVERAGE DAILY PERCOLATION PER ACRE = 518.6 gpd/acre
1. Reference: U.S. EPA. Use of the Water Balance Method for Predicting Leachate Generation from Solid Waste Disposal
Sites. EPA/530/SW-168. October 1975.
2. The parameters are:
T = mean monthly temperature
PET = potential evapotranspiration
P = mean monthly precipitation
C(R/0) = surface runoff coefficient
R/0 = surface runoff
I = infiltration
ST = soil moisture storage
DEL ST = change in soil moisture storage
AET = actual evapotranspiration
PERC = percolation
3. All parameters are expressed in units of inches, except temperature which is in degrees Fahrenheit.
-------
ATTACHMENT B-1
TABLE 4
WATER BALANCE CALCULATION FOR THE SOIL COVER OPTION
Soil Water Storage (inch) = 10
PARAMETER
PET
P
C(R/0)
RO
I
I -PET
SUM NEG(I-PET)
ST
DEL ST
AET
PERC
JAN
0.00
1.55
0.15
0.23
1.32
1.32
0.00
8.59
1.32
0.00
0.00
FEB
0.00
1.36
0.15
0.20
1.16
1.16
0.00
9.74
1.16
0.00
0.00
MAR
0.00
2.25
0.15
0.34
1.91
1.91
0.00
10.00
0.26
0.00
1.65
APR
1.34
2.87
0.15
0.43
2.44
1.10
0.00
10.00
0.00
1.34
1.10
MAY
3.40
2.75
0.15
0.41
2.34
-1.06
-1.06
8.99
-1.01
3.35
0.00
JUN
4.99
3.52
0.15
0.53
2.99
-2.00
-3.06
7.40
-1.59
4.58
0.00
JUL
5.42
2.82
0.15
0.42
2.40
-3.02
-6.09
5.46
-1.94
4.34
0.00
AUG
5.04
3.05
0.15
0.46
2.59
-2.45
-8.53
4.28
-1.18
3.77
0.00
SEP
3.43
2.36
0.15
0.35
2.01
-1.43
-9.96
3.71
-0.57
2.58
0.00
OCT
1.71
2.31
0.15
0.35
1.96
0.25
0.00
3.96
0.25
1.71
0.00
NOV
0.49
2.31
0.15
0.35
1.96
1.48
0.00
5.44
1.48
0.49
0.00
DEC
0.00
2.15
0.15
0.32
1.83
1.83
0.00
7.27
1.83
0.00
0.00
ANNUAL
29.3
4.4
22.2
2.8
AVERAGE DAILY PERCOLATION PER ACRE = 204.6 gpd/acre
NOTES:
1. Reference: U.S. EPA. Use of the Water Balance Method for Predicting Leachate Generation from Solid Waste Disposal
Sites. EPA/530/SW-168. October 1975.
2. The parameters are:
T = mean monthly temperature
PET = potential evapotranspiration
P = mean monthly precipitation
C(R/0) = surface runoff coefficient
R/0 = surface runoff
I = infiltration
ST = soiI moisture storage
DEL ST = change in soil moisture storage
AET = actual evapotranspiration
PERC = percolation
3. All parameters are expressed in units of inches, except temperature which is in degrees Fahrenheit.
-------
AGENCY REVIEW DRAFT
3. Allowable percolation per month = 0.46 inches
• Compacted layer of clay protected from frost would have a
minimum saturated permeability of 2 x 10"7 cm/s.
• Vertical hydraulic gradient of 2.2 to account for 3.5 feet of head
build-up in soil overlying the 3-foot-thick clay barrier.
4. See Table 5 for water balance calculation.
SOIL-DRAIN-COMPOSIXE CAP
1. Soil moisture storage at field capacity = 10 inches (same as the regrade
and cover option)
2. Runoff coefficient = 0.18 (lawns, heavy soil with 3 percent grade)
3. Allowable percolation per month = 0.10 inch
• Composite barrier of compacted clay and FML would have a
minimum saturated permeability of 1 x 10"7 cm/s.
• Vertical hydraulic gradient of 1
4. See Table 6 for water balance calculation.
COMPARISON OF WATER BALANCE ESTIMATES
Assuming that the landfill contents are saturated, all percolation results in leachate
generation. The quantity of generated leachate can be estimated using the area over
which any given percolation rate occurs. The relative effectiveness of each cover
-------
ATTACHMENT B-1
TABLE 5
WATER BALANCE CALCULATION FOR THE SOIL-CLAY CAP OPTION
Soil Water Storage (inch) = 10
PARAMETER
PET
P
C(R/0)
RO
I (+ EXCESS WATER)
I -PET
SUM NEG(I-PET)
ST
DEL ST
AET
PERC
ALLOWABLE PERC
EXCESS WATER
JAN
0.00
1.55
0.18
0.28
1.27
1.27
0.00
8.61
1.27
0.00
0.00
0.00
0.00
FEB
0.00
1.36
0.18
0.24
1.12
1.12
0.00
9.72
1.12
0.00
0.00
0.00
0.00
MAR
0.00
2.25
0.18
0.40
1.85
1.85
0.00
10.00
0.28
0.00
1.57
0.46
1.11
APR
1.34
2.87
0.18
0.52
3.46
2.12
0.00
10.00
0.00
1.34
2.12
0.46
1.66
MAY
3.40
2.75
0.18
0.50
3.91
0.51
0.00
10.00
0.00
3.40
0.51
0.46
0.05
JUN
4.99
3.52
0.18
0.63
2.94
-2.06
-2.06
8.13
-1.87
4.81
0.00
0.00
0.00
JUL
5.42
2.82
0.18
0.51
2.31
-3.11
-5.16
5.96
-2.17
4.48
0.00
0.00
0.00
AUG
5.04
3.05
0.18
0.55
2.50
-2.54
-7.70
4.62
-1.34
3.84
0.00
0.00
0.00
SEP
3.43
2.36
0.18
0.42
1.94
-1.50
-9.20
3.98
-0.64
2.58
0.00
0.00
0.00
OCT
1.71
2.31
0.18
0.42
1.89
0.18
0.00
4.16
0.18
1.71
0.00
0.00
0.00
NOV
0.49
2.31
0.18
0.42
1.89
1.41
0.00
5.57
1.41
0.49
0.00
0.00
0.00
DEC
0.00
2.15
0.18
0.39
1.76
1.76
0.00
7.34
1.76
0.00
0.00
0.00
0.00
ANNUAL
29.3
5.3
22.6
1.4
AVERAGE DAILY PERCOLATION PER ACRE = 102.7 gpd/acre
NOTES:
1. Reference: U.S. EPA. Use of the Water Balance Method for Predicting Leachate Generation from Solid Waste Disposal
Sites. EPA/530/SW-168. October 1975.
2. The parameters are:
T = mean monthly temperature
PET = potential evapotranspiration
P = mean monthly precipitation
C(R/0) = surface runoff coefficient
R/0 = surface runoff
I = infiltration
ST = soil moisture storage
DEL ST = change in soil moisture storage
AET = actual evapotranspiration
PERC = percolation
3. All parameters are expressed in units of inches, except temperature which is in degrees Fahrenheit.
-------
ATTACHMENT B-1
TABLE 6
WATER BALANCE CALCULATION FOR THE SOIL-DRAIN-COMPOSITE CAP OPTION
Soil Water Storage (inch) = 10
PARAMETER
PET
P
C(R/0)
RO
I
I-PET
SUM NEG(I-PET)
ST
DEL ST
AET
PERC
ALLOWABLE PERC
SUBDRAINAGE
JAN
0.00
1.55
0.18
0.28
1.27
1.27
0.00
8.19
1.27
0.00
0.00
0.00
0.00
FEB
0.00
1.36
0.18
0.24
1.12
1.12
0.00
9.30
1.12
0.00
0.00
0.00
0.00
MAR
0.00
2.25
0.18
0.40
1.85
1.85
0.00
10.00
0.70
0.00
1.15
0.10
1.05
APR
1.34
2.87
0.18
0.52
2.35
1.01
0.00
10.00
0.00
1.34
1.01
0.10
0.91
MAY
3.40
2.75
0.18
0.50
2.26
-1.15
-1.15
8.92
-1.08
3.34
0.00
0.00
0.00
JUN
4.99
3.52
0.18
0.63
2.89
-2.11
-3.25
7.26
-1.66
4.55
0.00
0.00
0.00
JUL
5.42
2.82
0.18
0.51
2.31
-3.11
-6.36
5.32
-1.94
4.25
0.00
0.00
0.00
AUG
5.04
3.05
0.18
0.55
2.50
-2.54
-8.90
4.12
-1.20
3.70
0.00
0.00
0.00
SEP
3.43
2.36
0.18
0.42
1.94
-1.50
-10.39
3.56
-0.56
2.50
0.00
0.00
0.00
OCT
__
1.71
2.31
0.18
0.42
1.89
0.18
0.00
3.74
0.18
1.71
0.00
0.00
0.00
NOV
0.49
2.31
0.18
0.42
1.89
1.41
0.00
5.15
1.41
0.49
0.00
0.00
0.00
DEC
0.00
2.15
0.18
0.39
1.76
1.76
0.00
6.92
1.76
0.00
0.00
0.00
0.00
ANNUAL
29.3
5.3
21.9
0.2
2.0
AVERAGE DAILY PERCOLATION PER ACRE = 14.9 gpd/acre
NOTES:
1. Reference: U.S. EPA. Use of the Water Balance Method for Predicting Leachate Generation from Solid Waste Disposal
Sites. EPA/530/SU-168. October 1975.
2. The parameters are:
T = mean monthly temperature
PET = potential evapotranspiration
P = mean monthly precipitation
C(R/0) = surface runoff coefficient
R/0 = surface runoff
I = infiltration
ST = soil moisture storage
DEL ST = change in soil moisture storage
AET = actual evapotranspiration
PERC = percolation
3. All parameters are expressed in units of inches, except temperature which is in degrees Fahrenheit.
-------
AGENCY REVIEW DRAFT
option can then be estimated by comparing the reductions of generated leachate.
The results of the water balance calculations are summarized in Tables 7 and 8.
Table 7 presents the estimated reduction of generated leachate, in percent, between
the existing site conditions and the various cover options for both the Phase I Landfill
(Table 7a) and Phase II and III Landfills (Table 7b). The full area of the Phase I
Landfill was used; however, only the tops of the Phase II and III Landfills were used
because it was assumed that percolation falling on the sideslopes would run off.
Table 8 presents the estimated reduction of generated leachate, in percent, for
various combinations of cover options. For example, if a soil cover were constructed
on the Phase II and III Landfills, and a soil-drain-composite cap were constructed on
the Phase I Landfill, the estimated reduction of generated leachate would be
89 percent (Table 8a).
GLT959/029.51
-------
ATTACHMENT B-1
TABLE 7
SUMMARY OF GENERATED LEACHATE
Table 7(a). Phase I Landfill.
I
| CONDITION
I
I
I
| Phase I, Existing
I
I
| Soil Cover
I
I
[Soil-Clay Cap
I
1
|Soi I -Drain-Composite Cap
AREA
(acres)
44
44
44
44
PERCOLATION
(in/yr) |(gpy/acre)
t
7.7
2.8
1.4
0.2
GENERATED
LEACHATE
(Hgal)
209,101 9.20
76,037
38,018
3.35
1.67
5,431 0.24
REDUCTION OF |
LEACHATE |
I
I
I
0%|
I
I
64% |
. i
I
82% |
I
I
97% |
Table 7(b). Phase II and III Landfills.
I
| CONDITION
I
i
1 '
|Phase II and III, Existing
1
1
|Soil Cover
i__
1
|Soil-Clay Cap
I
1
|Soi l-Drain-Composite Cap
AREA
(acres)
14
14
14
14
PERCOLATION
(in/yr) |(gpy/acre)
i
7.0
2.8
1.4
0.2
190,092
..
76,037
38,018
5,431
GENERATED
LEACHATE
(Mgal)
2.66
1.06
0.53
0.08
REDUCTION OF |
LEACHATE |
I
i
1
0%j
I
1
60% |
I
1
80% |
I
1
97% |
-------
ATTACHMENT B-1
TABLE 8
REDUCTION OF GENERATED LEACHATE FOR DIFFERENT COMBINATIONS OF COVER OPTIONS
Table 8a. Soil Cover Option for the Phase II and III Landfills
Combined with All Other Options for the Phase I Landfill.
I
I
| CONDITION
I
|
I
| Exist ing
I
I
| Soil Cover
I
I
(Soil-Clay Cap
I
I
|Soil-Drain-Composite Cap
GENERATED LEACHATE
PH. II & III| PH. I
(Mgal) | (Mgal)
. I
2.66
.
1.06
1.06
1.06
TOTAL
(Mgat)
9.20 | 11.86
I.
I
3.35 | 4.41
1
1.67
0.24
2.74
1.30
REDUCTION |
OF ' |
LEACHATE |
I
I
I
0%|
I
I
63% |
1
1
77% |
1
1
89% |
Table 8b. Soil-Clay Cap Option for the Phase II and III Landfills
Combined with All Other Options for the Phase I Landfill.
1
1
| CONDITION
1
|
1
(Existing
1
1
(Soil Cover
1
1
(Soil-Clay Cap
1
1
|Soi l-Drain-Composite Cap
GENERATED LEACHATE
PH. II & III
(Mgal)
..
2.66
0.53
0.53
.
0.53
PH. I
(Mgal)
9.20
3.35
1.67
0.24
TOTAL
{Mgal)
11.86
3.88
2.21
0.77
REDUCTION |
OF |
LEACHATE |
1
. 1
1
0%|
1
1
67% |
1
1
. _i
1
93% |
Table 8c. Soil-Drain-Composite Cap Option for the Phase II and III Landfills
Combined with All Other Options for the Phase I Landfill.
1
1
| CONDITION
1
1
1
(Existing
I
1
(Soil Cover
I
1
|Soi l-Clay Cap
I
1
|Soi I -Drain-Composite Cap
GENERATED LEACHATE
PH. II & III
(Mgal)
2.66
0.08
0.08
0.08
PH. I
(Mgal)
9.20
.
3.35
1.67
0.24
TOTAL
(Mgal)
11.86
3.42
1.75
.
0.32
REDUCTION |
OF |
LEACHATE |
I
I
1
0%|
1
1
71 %|
I
I
85% |
I
I
97% |
-------
Appendix C
GROUNDWATER EXTRACTION ANALYSIS
GLT984/040.51-3
-------
AGENCY REVIEW DRAFT
Appendix C
GROUNDWATER EXTRACTION ANALYSIS
INTRODUCTION
This appendix presents the equations, assumptions, and methodology used to evaluate
techniques to remove contaminated groundwater and leachate from the upper aquifer
at the site and to estimate extraction quantities for treatment alternatives. Separate
phase oils are also expected to be mixed with extracted groundwater from the landfill
area. The estimates were calculated using analytical formulas while considering
components of the conceptual model of site hydrogeology and results of the aquifer
property testing conducted during the remedial investigation. A summary of the
conceptual model and results from aquifer testing are presented in Table C-l.
APPLICABLE TECHNOLOGIES
Groundwater collection at the G&H Landfill site could be accomplished by two
methods, extraction wells and/or media drains. These two methods were evaluated on
the bases of their relative effectiveness, implementability, and cost. The most
important site-specific physical factors that were considered while evaluating these
two methods include: the relatively thin, heterogeneous and anisotropic nature of the
upper aquifer; the permeable character of the soils; and the nature and concentration
of the contaminants at the site. Both methods would require long term separation,
collection, and treatment of separate phase oils and oily sludge. Treatment and oil
separation processes are described in Appendix D.
The main disadvantage of using extraction wells to collect contaminated groundwater
at the G&H Landfill site is the thin, heterogeneous and anisotropic nature of the
upper aquifer. These site specific properties have a major effect on extraction wells
by limiting flow rates and producing non-uniform capture zones around highly
C-l
-------
Table C-l
SUMMARY OF CONCEPTUAL MODEL COMPONENTS
AND AQUIFER PROPERTIES
I. Model Components
A. Heterogeneous, anisotropic aquifer
B. Groundwater flow at the site is from the north-northeast to the south-
southwest in the upper aquifer
C. Groundwater from the upper aquifer discharges to the Clinton River
along the western flank of the site, to the wetlands in the vicinity of the
Oil Seep Area, and to the Clinton-Kalamazoo Canal south of the Oil
Seep Area
D. Groundwater collection will occur under steady-state conditions
II. Aquifer Properties
A. The saturated horizontal hydraulic conductivity at the site ranges from
3.5 x 10~2 to 3.5 x 10"8 cm/s, with a logarithmic average of
1.8 x 10~3 cm/s, as defined by in situ hydraulic conductivity testing.
B. The saturated thickness of the upper aquifer ranges from 18 to 28 feet,
with a saturated thickness of 20 feet being used in the calculations.
C. Transmissivity of the upper aquifer ranges from 15 to 15,000 gpd/ft,
with a average of 780 gpd/ft.
D. The specific yield and effective porosity of the upper aquifer of 0.30.
III. Miscellaneous
A. Site Dimensions
1. North-South 1,500 feet
2. East-West 2,900 feet
GLT959/036.51
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AGENCY REVIEW DRAFT
contaminated target areas. The main advantages of using extraction wells to collect
contaminated groundwater at the site include: it is a proven technology for collecting
groundwater, it is easily implemented, and because the flow rates are expected to be
low, inexpensive, small-diameter extraction wells could be installed.
The main disadvantages of using media drains to collect contaminated groundwater at
the site are: the difficulty of implementing the technology since most of the target
areas are within the Phase I Landfill refuse, the ineffectiveness of drains at collecting
the highly viscose oily sludges (the gravel in the drains would probably become
clogged), and the high cost relative to installing small diameter extraction wells.
Media drains may be more effective than extraction wells at collecting leachate in the
area between the Phase III Landfill and the Clinton River where the upper aquifer is
absent. However, the steep slopes at this side of the site may prohibit installation of
a drain.
DEVELOPMENT OF GROUNDWATER FLOW MODEL
EXISTING GROUNDWATER FLOW CONDITIONS
Existing groundwater flow conditions at the G&H Landfill site were identified to
evaluate the various groundwater extraction concepts and to estimate groundwater
extraction and treatment quantities.
Groundwater contours across the site were generated using groundwater elevation
measurements obtained on July 24, 1989. These measurements were then used to
estimate the quantity of groundwater presently moving through the upper aquifer at
the site.
The site was divided into 5 separate flow channels based on groundwater elevations
and interpolated contours (refer to Figure 3-9, RI). The flow through each channel
C-2
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AGENCY REVIEW DRAFT
(Q) was calculated using the following derivation of Darcy's Law (Freeze and Cherry,
1979):
Q = TxixL
where:
T = transmissivity of the aquifer
i = hydraulic gradient
L = width of the aquifer perpendicular to the direction of groundwater
movement
The transmissivity is calculated using the following equation:
T = kxb
where:
K = hydraulic conductivity of aquifer materials (3.5 x 10~3 ft/min)
b = saturated thickness of the aquifer (20 feet)
T = Kxb
T = (3.5 x 10-3 ft/min) x (20 ft) = 7.1 x 10'2 ft2/min
The hydraulic gradient (i) of each flow channel was estimated from the groundwater
elevations of monitoring wells measured on July 24, 1989. The hydraulic gradient is
equal to the change in hydraulic head divided by the distance over which the change
occurs:
i = 695 ft - 685 ft = 0.0067
1500ft
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AGENCY REVIEW DRAFT
The width (L) of each respective flow channel was then used to calculate the flow-
through the channel (Q).
Q = T xi xL
Q = (7.1 x ID'2 ft2/min)(0.0067)(575 ft) = 0.30 ft3/min
Q = (0.30 ft3/min)(7.481 gal/ft3) = 2 gpm
To estimate the total quantity of groundwater moving through the upper aquifer at
the site both the high and low sitewide hydraulic conductivities were used. The
procedure was repeated for all flow channels to bracket a range, 40 to 180 gpm of
groundwater moving through the upper aquifer beneath the site.
Recharge
Groundwater recharge rates for the site were estimated using a soil water balance
(Appendix B) which accounts for incident precipitation, evapotranspiration, surface
runoff, and soil moisture storage (U.S. EPA 1975). Percolation was estimated to be
approximately 7 in/yr. This would result in an average percolation rate over the
landfilled areas (assumed to be about 82 acres) of 30 to 35 gpm.
Boundary Conditions
Along the western flank of the G&H Landfill site the upper aquifer is absent. A
potential result of this boundary condition could be a non-uniform cone of depression
or capture zone when pumping near the boundary. Another potential result could be
smaller extraction rates.
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AGENCY REVIEW DRAFT
EQUATIONS USED IN GROUNDWATER
EXTRACTION CALCULATIONS
EXTRACTION WELLS
In addition to the extraction of contaminated water for treatment, extraction wells can
be used to control hydraulic gradients and groundwater flow directions in and around
the G&H Landfill site to contain the contaminants. The yield of individual wells will
depend on hydraulic conductivity, saturated thickness of the aquifer, effective porosity,
and the radius of the well. The water table drawdown caused by the operation of
extraction wells will depend on the drawdown of individual wells, the well construction
specifications, the spacing of wells, and the presence of no flow boundary conditions
near wells along the west side of the site. All wells on the site will fully penetrate the
upper aquifer with either a 5- or 10-foot screen length and a radius of 2 inches.
Specific Capacity
Yields to wells were calculated using estimates of specific capacity which is defined as
the yield to a well per-foot of drawdown. Specific capacities were estimated from the
transmissivity of the aquifer using the following equation (Walton 1970):
Sc = T/([264 log (Tt/2693 R^)] - 65.5)
where:
Sc = specific capacity in gallons per minute per-foot of drawdown (gpm/ft)
T = transmissivity of the aquifer (gpd/ft)
t = time since pumping began (minutes)
RV = the radius of the well (feet)
Sy = specific yield
Sc = 763 ([264 log (763 x 525,600/2693 x (.25)2 x 0.3)] - 65.5)
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AGENCY REVIEW DRAFT
Sc = 0.40 gpm/ft of drawdown
In the case of an unconfined aquifer, specific yield (Sy) is assumed to be the effective
porosity of the aquifer.
The specific capacity estimates were calculated using a well radius of 0.02 foot, an
effective porosity of 0.30, and a time since pumping began of 1 year (525,600
minutes). The values of transmissivity in the calculations of specific capacity were
taken as the product of the aquifer's hydraulic conductivity and the saturated
thickness of the aquifer at the well screen (this value would be equal to the original
saturated thickness of 20 feet minus the drawdown at the well). The estimates of
specific capacity and the resulting well yields at various drawdowns in the wells are
summarized in Table C-2. From these well yields groundwater extraction estimates
for remedial alternatives were derived (Figures 5-2, 5-3, and 5-4).
Radius of Influence and Well Spacing
Several methods (Theis 1935, Theim 1906, Powers 1981, and Todd 1980) were used
to determine the area which would provide inflow to an extraction well in a uniform
groundwater flow field. Todd's radius of influence equation which includes the effects
of recharge was used to estimate the radius of influence from a pumping well. A
constant discharge pump test would be required during remedial design to more
accurately estimate the radius of influence. The following two equations were used
(Todd 1980):
R0 =
where:
R0 = distance in feet from the well at which there is no drawdown
Q = flow rate of the extraction well in ft3/min (0.27 ft3/min)
W = the rate of recharge in ft/mm (1.6 x 10"6 ft/min)
C-6
-------
Table C-2
ESTIMATED WELL YIELD
Well
Drawdown (ft)
Saturated
Thickness (ft)
Transmissivity
(gpd/ft)
Specific
Capacity
(gpm/ft)
Well
Yield (gpm)
K = 1.8 x ID'3 cm/s
1
2
3
5
10
13.5*
15
19
18
17
15
10
6.5
5
725
687
649
573
382
248
191
0.4
0.4
0.4
0.3
0.2
0.2
0.1
0.4
0.8
1.1
1.7
2.3
2.0
1.4
* A drawdown at the well of 13.5 feet reflects two-thirds drawdown of the aquifer,
representing the point of maximum well efficiency.
GLT959/037.51
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AGENCY REVIEW DRAFT
therefore:
R0 = [(0.27 ft3/min)A> x 1.6 x 10^ ft/min)]1/2
R0 = 232ft
9 U 2 Tj2 _ /"W//'9'K'VP2 P 2\ I TC\/f*rV\\nn/D /DM
*•• fio - n. — ^W/ZJv)^lx - J\.o ) T [VJ/^TCIvJJlin^.Ko/.KJJ
where:
H0 = height of the water table in feet (28 feet) at a distance R0 from
the well in feet (232 feet)
H = height of the water table in feet, at a distance R (100 ft) from
the well
W = rate of recharge in ft/min (1.6 x 10"6 ft/min)
K = hydraulic conductivity of the aquifer in ft/min (5.6 x 10"3 ft/min)
R0 = distance in feet from the well at which there is no drawdown
(232 ft)
Q = flow rate of the extraction well in ft3/min (0.27 ft3/min)
(28 ft)2-H2 = (1.6 x 10-6 ft/min)/(2 x 5.6 x 10"3 ft/min) x [(100 ft)2 - (232 ft)2 +
(0.27 ft3/min)/(7t x 5.6 x lO"6 ft/min) x In (232 ft/100 ft)]
H = 27.9 ft so s(drawdown) = 28.0 ft - 27.9 ft = 0.10 ft
Based on the specific capacity estimates, a flow rate of about 2 gpm per well,
associated with % drawdown of the aquifer for maximum well efficiency, can be
expected. To produce overlapping cones of depression and effective capture of
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AGENCY REVIEW DRAFT
contaminated groundwater, extraction wells will be placed about 200 feet apart. Due
to the close spacing of the wells, the method of images was applied to determine the
cumulative drawdown in each well. Using this method, the drawdown in each well is
assumed to be the drawdown of the individual well plus the drawdown caused by the
other pumping wells.
The active extraction alternative evaluated for the site targets four moderately- to
highly-contaminated areas according to risk. Based on this evaluation, about
25 extraction wells pumping at a rate of 2 gpm each would be required to collect
contaminated groundwater from these four areas.
Vertical Barriers
Potential leakage through a slurry wall was estimated to maintain a 1 to 2-foot
hydraulic head difference between the inside and outside of the slurry wall. These
calculations are used to estimate the total pumping rate necessary to achieve
containment of contaminants. The slurry wall is assumed to be 2 feet thick, 18 to
28 feet deep, and have a hydraulic conductivity of 1.0 x 10* cm/s (3.3 x lO"8 ft/s).
Leakage through a slurry wall (Q) was estimated using a form of Darcy's Law
(Powers 1981):
0 = K x X (H22 - H!2)/2L
where:
K = hydraulic conductivity of the aquifer in ft/s (3.3 x lO^ft/s)
X = length of the slurry wall in feet (7,350 ft)
H2 = hydraulic head outside the slurry wall in feet (20 ft)
H! = hydraulic head inside the slurry wall in feet (18 ft)
L = thickness of the slurry wall in feet (2 ft)
Q = 3.3 x 10-8 ft/s x 7,350 ft x (20 ft2 - 18.5 ft2)/22 ft x 7.481 gal/ft3
x 60 s/min = 1.6 gpm
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AGENCY REVIEW DRAFT
Leakage through the various vertical barriers evaluated was about 2 gpm.
A series of low-flow rate wells located inside the perimeter of the slurry wall can be
used to achieve the desired hydraulic head (inward gradient) within the wall. Again,
due to the close spacing of the wells, the method of images was used.
Recharge rates to groundwater within the slurry wall were estimated using a soil
water balance (U.S. EPA 1975) to determine total pumpage required for containment
of contaminants. Percolation was estimated to be approximately 7 in/yr. This would
result in average percolation within the slurry wall (assumed to be about 82 acres) at
of about 30 to 35 gpm.
To contain contaminants within the various slurry walls proposed, about 30 to 35 gpm
would have to be extracted from the upper aquifer at the site. If placed
approximately 200 feet apart, about 30 to 50 small diameter wells pumping at a rate
of 0.6 gpm would be needed. (A slurry wall around the site may also have an effect
on reducing the amount of leachate generated from the Phase III Landfill).
Media Drains
In the previous discussion of applicable technologies, media drains were considered to
be ineffective due to the viscous nature of the oily sludge contamination at the site,
the location of targeted collection (Phase I Landfill), and the cost of installation in
comparison to small diameter wells. However, using a media drain was evaluated to
collect leachate between the Phase III Landfill and the Clinton River (Figures 5-2,
5-3, and 5-4).
The flow of groundwater to a media drain on the western flank of the site was
estimated based on the results of the water budget (refer to Figure 3-9, RI). Flow
channel No. 1, which encompasses about 95 percent of the Phase III Landfill,
discharges to the wetlands and Clinton River at an estimated rate of 2 to 9 gpm. A
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AGENCY REVIEW DRAFT
media drain installed at the toe of the slope on the western edge of the Phase III
Landfill should be able to handle this flow.
SUMMARY
EXTRACTION TECHNOLOGY
Based on the extraction technology evaluation, wells were chosen to be the most
effective, implementable, and cost effective way to control hydraulic gradients and
extract contaminated groundwater at the G&H Landfill site. For the collection of
leachate along the western flank of the Phase III Landfill, either a toe drain or
extraction wells could be used. The installation of a toe drain in this location would
be a problem given the steepness of the slope and that a portion of the embankment
is landfilled waste.
EXTRACTION CONCEPTS AND QUANTITIES RATES
Two groundwater extraction goals have been identified; extraction of groundwater for
hydraulic gradient control, and active extraction of contaminated plumes to the east
and south of the Phase I Landfill. Extraction rates for hydraulic gradient control are
on the order of 30 to 35 gpm. Extraction rates associated with active collection of
groundwater contaminant plumes are on the order of 15 to 20 gpm.
REFERENCES
Freeze, R. A,, and Cherry, J. A. Groundwater. Prentice-Hall, Inc. 1979.
Powers, J. P. Construction Dewatering. John Wiley and Sons. 1981.
Theim, G. Hydrologiskhe Methoden. Gebhardt. 1906.
C-10
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AGENCY REVIEW DRAFT
Theis, C. V. The relation between the lowering of the piezometric surface and the
rate and duration of discharge of a well using groundwater storage. Am. Geophys.
Union Trans. 16(1935): 519-524.
Todd, D. K. Groundwater Hydrology. John Wiley and Sons. 1980.
U.S. EPA. Use of the Water Balance Method for Predicting Leachate Generation from
Solid Waste Disposal Sites. SW-168, 1975.
Walton, W. C. Groundwater Resource Evaluation. McGraw-Hill Book Company.
1970.
GLT959/035.51
C-ll
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Appendix D
TREATMENT SYSTEMS ANALYSIS
GLT984/040.51-4
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AGENCY REVIEW DRAFT
Appendix D
TREATMENT SYSTEMS ANALYSES
INTRODUCTION
This appendix presents a discussion of treatment technologies for the two operable
units, groundwater/leachate/oil and soil/sediment/landfill contents. The purpose of
this appendix is to provide supporting documentation for Chapters 4 and 5,
technology screening and development and alternatives evaluation. Based on the
remedial action objectives developed for each operable unit, contaminants of concern
and extent of contamination for each operable unit were identified, and estimated
influent concentrations to the groundwater treatment system were determined.
Initial technology screening presented in Chapter 4 eliminated process options clearly
inappropriate for the site. A detailed screening and evaluation of treatment
technologies was completed for each operable unit. Process options which survived
screening were combined into appropriate treatment systems for each alternative.
These combinations provide a basis for the development, description, evaluation, and
feasibility-level cost estimate for each alternative.
GROUNDWATER / LEACHATE / OIL OPERABLE UNIT
REMEDIAL OBJECTIVES
The remedial objectives for the groundwater/leachate/oil operable unit are:
• Prevent the ingestion of groundwater with contaminants that exceed the
MCLs, have a total excess lifetime cancer risk of greater than 1 x 10"6
or have a hazard index greater than 1
D-l
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AGENCY REVIEW DRAFT
• Provide remedies that achieve groundwater standards that are
applicable or relevant and appropriate
• Prevent the release of groundwater contaminants at concentrations that
would cause contaminant concentrations in the surface water to exceed
criteria for the protection of aquatic life in the Clinton River or the
adjacent wetlands and Clinton-Kalamazoo Canal
• Control migration of oil to the extent necessary to protect public health
and the environment
The area defined as onsite includes the entire area inside the fence (Figure 1-3).
Contamination in groundwater from monitoring wells in onsite Areas 1 through 5,
identified in the RI, currently exceeds the MCLs, MCLGs, risk criteria, and hazard
indexes (Figure 1-9). The commercial and industrial wells in Area 5 (identified as
GR) are not considered onsite wells and are not addressed as part of the
groundwater/leachate/oil operable unit. Remedial options for these wells are
discussed at the end of this appendix. Compounds with concentrations that exceed
carcinogenic risk through ingestion criteria (i.e., greater than 1 x 10~6) based on the
upper 95 percent confidence limit of the arithmetic mean concentration by area were
identified. These compounds are arsenic, benzene, bis(2-chloroethyl)ether,
1,1-dichloroethane, n-nitrosodiphenylamine, vinyl chloride, bis(2-ethymexyl)phthalate,
and trichlorethene. No individual chemical in the groundwater exceeded the
noncarcinogenic risk hazard, although the sum of the risk hazard for Area 1
exceeded 1. Compounds with concentrations that exceed MCLs based on the
contaminant concentration by area are arsenic, benzene, vinyl chloride, barium,
chloroform, trichloroethene, lead, and chromium.
The onsite area including Phase I, II, and III Landfills with groundwater
contamination encompasses about 150 acres and extends about 20 feet below the
water table, 30 feet below the ground surface to the confining till unit.
D-2
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AGENCY REVIEW DRAFT
Compounds with concentrations that exceed the carcinogenic risk criteria or
noncarcinogenic risk hazard based on upper 95 percent confidence limit of the
arithmetic mean concentration in the oil seep water include PCBs,
bis(2-ethylhexyl)phthalate, and butylbenzyl phthalate. Oil-contaminated soil and
refuse has been identified in most of the Phase I Landfill (44 acres) up to 10 feet
below the refuse in the upper sand unit. The estimated volume of soils and refuse
contaminated with oil is 800,000 cubic yards. Floating oil has been identified in
monitoring wells hydraulically downgradient from the Phase I Landfill and is
discharged into ponds in the Oil Seep Area. The extent of the floating nonaqueous
phase oil layer in the Phase I Landfill is not known.
Discharge of groundwater to the wetlands and the Oil Seep Area would exceed
federal or state surface water quality criteria for several contaminants. It is assumed
that the groundwater is not diluted before discharge to these areas. Contaminants
which exceed the criteria include both volatile and semi-volatile organic compounds,
4,4'-DDT, Arochlor-1254, ammonia, and inorganic analytes.
INFLUENT CONCENTRATION ANALYSIS
Onsite Groundwater and Leachate
The major contaminants identified in the groundwater during the RI include BEXT
compounds, chlorinated VOCs, and PNAs. 4,4'-DDD was detected in one well and
4,4'-DDT in another well. Arochlor-1254 was detected in four wells. Inorganic
analytes were found in concentrations higher than detected in background wells.
The BEXT plume in the upper aquifer extends from the Phase I Landfill to the main
site entrance road south of the Oil Seep Area. The chlorinated VOCs in the upper
aquifer were found in several discrete areas, the Phase I Landfill, just north of the Oil
Seep Area, southeast of the Phase I Landfill along the railroad tracks, and south of
the main site entrance road. PNA contamination in the upper aquifer extends from
Oil Pond No. 1 south to the Oil Seep Area, and is present at one location in the
D-3
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AGENCY REVIEW DRAFT
center of the Phase III Landfill. BEXT compounds were found in the three leachate
wells west of the Phase III Landfill. Vertically, contamination is confined to the base
of the refuse and the upper aquifer.
Groundwater collected from all site areas will be treated at a central treatment
facility. Contaminant concentrations often are different from predicted concentrations
and may change over the course of treatment. Because of this, the treatment system
should be designed to accommodate changing conditions. Due to the difficulty in
identification of actual influent concentrations, and the changing conditions at the site,
a detailed estimation of loadings based on concentration and flow rates from the
individual site areas was not considered valuable in estimating influent concentrations
to the treatment system.
Estimated means and ranges of groundwater influent concentrations to the treatment
system are based on results from groundwater samples from monitoring wells in
Areas 1 through 5 sampled during Round 1 and 2 of the Stage III RI. All wells, a
total of 94, and 126 samples were used to determine mean and range concentrations
to use as representative groundwater influent concentrations. Wells were screened in
the landfill refuse to collect leachate, and in the aquifer to collect groundwater.
Three wells along the western edge of the Phase III Landfill that are included were
screened in the upper aquifer and collected groundwater and leachate, although it is
not possible to quantify amounts of each. Leachate wells and wells with nonaqueous
phase layers were not analyzed for conventional parameters including BOD. These
values are presented in Table 1.
Oil
A separate nonaqueous phase oil layer was collected from several monitoring wells in
the Phase I Landfill area. This oil layer discharges in the Oil Seep Area. A 2- to
4-inch thick oil layer is present on top of the pond water. BETX compounds, PNAs,
and Arochlor-1254 were found in oil layers in the wells and were also identified in the
oil layer on the oil seep ponds.
D-4
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AGENCY REVIEW DRAFT
A summary of the contaminants and ranges detected for the media associated with
this operable unit are found in Table D-l.
SECONDARY SCREENING OF TECHNOLOGIES
Treatment technologies were initially screened (Appendix A) to remove those clearly
inappropriate technologies for the types of materials and contaminants to be treated.
The groundwater treatment technologies which remained after screening were:
• Physical Treatment
— Flow and Strength Equalization
— Oil-Water Separation
— Flotation
— Media Filtration
— Adsorption
— Air Stripping
• Chemical Treatment
— Precipitation
— Oxidation
• Biological Treatment
— Reactor-based Biological Treatment
— In situ Biological Treatment
• Thermal Treatment
— Incineration
D-5
-------
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AGENCY REVIEW DRAFT
Process options associated with a technology were evaluated on the bases of their
effectiveness in protecting human health and in satisfying the remedial objectives,
implementability, and relative cost.
Physical Treatment
Flow and Strength Equalization. Use of storage basins or tanks to provide storage to
regulate the flow through the treatment system is a common pretreatment option.
Mechanical mixing is usually provided to stabilize the influent concentration. This
results in a more uniform loading to the treatment plant, which improves the
efficiency, reliability and control of downstream treatment processes, and lessens the
effects of slug loads to the system. At this site, the groundwater and leachate flow
and particularly leachate contaminant concentration are expected to vary with time.
It is expected that water from dewatering operations will also need to be treated at
certain stages of construction. This option is easily implementable, and is retained as
a pretreatment process option.
Oil-Water Separation. An oil-water separator removes nonaqueous phase liquids
from groundwater. Floating non-aqueous phase layers were seen in onsite monitoring
wells. Usually this is done with gravity separators in which oil products float to the
surface and are skimmed off while the water flows out of the unit through outlets in
the bottom of the chamber. Usually, the longer the retention time in the chamber,
the greater the amount of oil collected. Coalescing filters can also be used to
decrease high concentrations of oil to very low concentrations, although operating
costs are very high.
Oil-water separators are easily implementable and have proved effective in
wastewater treatment. Some maintenance is required to collect and dispose of the
oil. If the oil cannot be reused, it will probably need to be incinerated. Depending
on the discharge requirements, subsequent treatment may be needed to remove
dissolved oil from the groundwater. Technologies for dissolved oil removal are
discussed below. The use of oil-water separation was retained for further
D-6
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AGENCY REVIEW DRAFT
consideration. It will most likely be used as a pretreatment step in combination with
other treatment technologies.
Flotation. Flotation technologies rely on the release of very small bubbles into
solution that attach to and buoy small particles to the surface. The most common
application is dissolved air flotation in which air is dissolved into the pressurized
influent. As the pressurized water enters the flotation tank, pressure is reduced and
the excess dissolved air comes out of solution in the form of small (80 \im) bubbles
which float to the surface. As the bubbles rise, they attach to small particles and
sludge floes, floating them to the surface. The floating sludge is skimmed off with a
float collector. The oil and sludge which is skimmed off would probably require
offsite disposal and/or treatment. Polymer additions are often used to improve the
solids capture. Flotation technology would be used at the site to remove dissolved oil
and suspended solids from the groundwater. Flotation is established and reliable and
so retained for further consideration.
Media Filtration. Filtration is a physical separation used to remove suspended solids
by passing the waste stream through a porous filter media, typically sand or
anthracite. The filters are regularly backwashed by reversing the flow through the
media to prevent clogging and maintain flow. Filtration is often used after
precipitation to improve solids removal. Thus it was retained for use with other
groundwater treatment technologies.
Adsorption. Both granular and powdered activated carbon have been successfully
used to remove VOCs, semi-VOCs, and some inorganic contaminants. The
contaminants are removed by physical and chemical forces that cause the
contaminants to adsorb onto the carbon. The efficiency of the removal of organic
chemicals depends largely upon the solubility of the contaminants and the surface
area of the carbon. The pH, ionic strength, and competition between contaminants
for adsorption sites can affect the effectiveness, but removal to concentrations below
detection limits are feasible for many organic contaminants. Bench or pilot scale
studies are necessary to predict removal efficiency. When the carbon approaches its
D-7
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AGENCY REVIEW DRAFT
maximum adsorption capacity, it must be regenerated or replaced. Several carbon
units can be placed in a series or in parallel to decrease the load on each column and
increase the life of the carbon. Activated carbon units have moderate maintenance
demands and need to be monitored frequently for their performance.
Activated carbon units are readily implementable. Mobile units are available, and
could effectively remove most of the contaminants detected in the groundwater.
Carbon adsorption is more expensive than other technologies for VOC removal. It
could be readily exhausted by high suspended solids and oil, therefore pretreatment is
often necessary. Because of the semivolatile organic contaminants (SVOCs) in the
groundwater, carbon adsorption was retained as a process option to be used as a final
step for removal of SVOCs in conjunction with other technologies for VOC removal.
Air Stripping. Air stripping is widely used to remove VOCs and ammonia from
water. Air stripping removes contaminants by creating a large interface between the
air and the water to facilitate the transfer of contaminants from the water to the air.
The advantages of employing an air stripper as a remedial technology include its
simple design and operation, high removal efficiencies for volatile chemicals, and low
maintenance requirements. Disadvantages include the discharge of contaminants to
the atmosphere if no vapor phase treatment is used and the low removal rates for
nonvolatile chemicals.
A common type of air stripper is a packed tower in which water trickles down
through a porous media and air is blown upward across the water to strip out the
volatile chemicals. Removal efficiencies of 80 to 90 percent or more are common for
many VOCs and ammonia with this method. Regular maintenance to remove
precipitates and biological growth from the media and to maintain pumps and
blowers is required. The vapor discharge from the packed tower can be collected and
treated if necessary. In Michigan, treatment of discharged air is usually required to
meet the requirements of the Air Pollution Act. This technology was retained for
further consideration.
D-8
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AGENCY REVIEW DRAFT
Chemical Treatment
Precipitation. Chemical precipitation is a common and effective treatment to remove
metals from wastewater. Precipitation reactions are induced by changes in pH or by
adding reactive chemicals. Lime or sodium hydroxide is typically added to the water
along with a flocculating agent in a rapid mix tank to raise the pH and precipitate the
ionic species. Slow mixing in the flocculation chamber allows the particles to
agglomerate into a settleable size. These particles are removed from the liquid by
clarification. Removal of metals as hydroxides and sulfides is a common application
of this technology.
Bench and pilot scale tests would be required to determine optimum pH, reaction
times, reagent amounts, and sludge production. Further onsite treatment of the
sludge prior to offsite disposal would include thickening the sludge to reduce sludge
volume and the water content. Drying beds, gravity thickeners, belt filters, pressure
filters, or centrifuges can be used to reduce sludge volume prior to offsite disposal.
Sludge produced from the precipitation will have to handled as a hazardous waste
unless it is demonstrated to be nonhazardous. Precipitation is a proven technology
for metals removal, could be easily implemented, is readily available, and therefore
was retained as a treatment technology.
Oxidation. Chemical oxidation is a process in which oxidation-reduction reactions are
used to raise the oxidation state of at least one reactant and lower the oxidation state
of another. Typically, a strong oxidant such as ozone or chlorine gas is mixed with
the waste stream to oxidize chemicals in the stream to completion (water and carbon
dioxide) or to a chemical form more treatable by another process. Chemical
oxidation is often used for cyanide, but has also been effective for treating phenols
and pesticides.
A major limitation of chemical oxidation is that incomplete oxidation may yield toxic
byproducts that need further treatment. The process does not perform well with
complex waste streams and the oxidants used tend to be hazardous chemicals
D-9
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AGENCY REVIEW DRAFT
themselves. Thus, the implementation and maintenance tend to be difficult.
Laboratory and pilot tests are needed to determine correct oxidants and feed rates.
For these reasons the oxidation process alone was not retained for further
consideration.
A combination of ozone with ultraviolet radiation (UV) is an innovative oxidation
technology which has been demonstrated to oxidize organic contaminants including
PCBs, pesticides, and chlorinated solvents. The UV light and ozone induce
photochemical oxidation of organic compounds. High concentrations of suspended
solids can impair system performance. Ozone/UV oxidation appears to be
comparable in cost to other onsite treatment technologies, although there is limited
operating data from hazardous waste site operations. It is being used more frequently
in commercial operations. Because it is an emerging technology for groundwater
treatment and is less demonstrated than other technologies, it was not retained for
further consideration. It should be reconsidered during predesign or design phases as
more information becomes available.
Biological Treatment
In biological treatment, microbes use the organic chemicals as a carbon source for
new cell mass while degrading the chemicals to innocuous products such as water and
carbon dioxide.
Reactor-Based Biological Treatment. Reactor based biological systems for
groundwater treatment typically rely on microbes suspended in the activated sludge or
fixed to a surface (e.g., trickling filters). In either case sufficient time is provided for
the microbes to perform the desired breakdown of contaminants into innocuous
products. Limitations of biological systems, especially at a site with varying influent
concentrations, include their greater sensitivity to slug loads (i.e., influents of high
contaminant concentration) and toxic metals or organics which can inhibit biological
growth, especially in suspended growth systems.
D-10
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AGENCY REVIEW DRAFT
Concentrations of organic compounds in the groundwater at the G&H Landfill may
be too low (the BOD is 2 to 13 mg/1) to sustain bacterial growth. However, the
addition of landfill leachate (which typically has much higher BOD concentrations
than groundwater) to the groundwater might support a fixed-film biological system.
Leachate from hazardous landfills has been found to have BOD concentrations
ranging from 42 to 11,000 mg/1. The volume of leachate from extraction wells
screened in the upper aquifer is not expected to be large but cannot be estimated
accurately at this time.
Primarily due to the low BOD concentrations in the groundwater, biological treatment
may not be applicable. However, some compounds may appear resistant to
biodegradation by wastewater treatment plant water microbial populations used to
measure BOD. The use of properly selected or engineered microbial populations
under controlled conditions may degrade these otherwise refractory wastes. Some
compounds may still be resistant to biodegradation even with the use of other
microbes and the addition of another carbon source to sustain bacterial growth.
Predesign studies on influent concentrations from the well extraction system may
indicate that BOD results are higher than previously determined from onsite
monitoring wells. The U.S. EPA plans to conduct a Superfund Innovative Technology
Evaluation Program (SITE) demonstration at the site in the summer of 1990, in which
a mobile suspended fixed film biological system using naturally occurring bacteria will
be used to degrade organics in the groundwater. The results from this demonstration
should be used to further evaluate the feasibility of biological treatment at the site.
In situ Biological Treatment In situ biological treatment uses microbes to degrade
organic chemicals in groundwater and soils. The treatment of contaminated soils on
which organic contaminants may adhere is a benefit of in situ biological treatment
over reactor based biological treatment. Subsurface microbial activity is often limited
by available oxygen. With in situ biological treatment, microbial activity and the
subsequent degradation of organic biodegradable contaminants is stimulated through
the addition of oxygen into the aquifer. Nutrients such as nitrogen and phosphorus
D-ll
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AGENCY REVIEW DRAFT
are also added to promote growth. An additional carbon source such as methane or
acetate may be added.
In a typical in situ treatment system, groundwater is extracted, mixed with nutrients
and oxygen, and reinjected into the aquifer. The permeability of the upper aquifer
would be suited to in situ biodegradation, although the aquifer is heterogeneous and
anisotropic and movement of nutrients and oxygen in the aquifer might be difficult to
control and monitor. Other disadvantages include the long time frame required for
cleanup and no inorganic analytes would be removed.
As previously indicated, BOD concentrations in the groundwater are very low, but
traditional BOD measurements are not always a good indicator of biodegradability of
compounds. This technology is relatively new with little data in the literature. Both
pilot- and bench-scale studies will be required to determine whether in situ
biodegradation can be used to treat the groundwater and soil contaminants at the
site.
Thermal Treatment
Incineration. Incineration of the nonaqueous phase oil liquid is an applicable process
option. Although incineration is effective for destroying organic chemicals in oil,
implementation of onsite incineration would be difficult because permitting requires
extensive pilot testing which may require several years. Because of the substantial
mobilization, testing, and startup costs, an onsite incinerator is probably not cost-
effective for treatment of the small volumes of oil which are expected to be collected.
The moderately high cost of incineration is also a disadvantage. For volumes of oil
less than a few thousand gallons, shipment of oil to an offsite incinerator is
considered more practical. The oil would probably need to be analyzed by the facility
before they would accept it for incineration. No commercial treatment, storage and
disposal (TSD) RCRA facilities have been located in Michigan which have an onsite
incinerator.
D-12
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AGENCY REVIEW DRAFT
Disposal
Discharge to the Clinton River. Discharge of the treated groundwater to the Clinton
River would constitute a point source discharge according to the Michigan
Administrative Code, Water Resources Commission General Rules, Part 21. The
discharge must meet the requirements of the NPDES permit system as administered
by the state. Discharge levels are determined by the state to ensure compliance with
state and federal water quality criteria. A pipeline would be installed from the onsite
treatment plant to the river. This would be easy to implement and the risk to public
health or the environment would be small, provided the discharge meets federal and
state surface water quality criteria. Because effluent concentrations can be estimated
based on known criteria for discharge limits, this disposal option was retained as the
representative discharge option for groundwater treated at the onsite treatment
facility.
Discharge to the Publicly-Owned Treatment Plant The Detroit Water and Sewage
Department (DWSD) has a north-south pipeline easement in the western portion of
the site, including a 24-inch near-surface interceptor sewer. The interceptor, which
serves Shelby Township, connects into a 96-inch diameter regional sewer beneath the
site. This regional sewer serves Oakland County and discharges to the main
treatment at the plant in the city of Detroit. The treatment at the plant consists of
secondary treatment using an activated sludge process. Sludge from the treatment
plant is incinerated or landfilled. The design capacity is 1.2 billion gpd, and is
currently operating at 700 mgd.
Recent communication with the City of Detroit POTW indicates that acceptance of
discharge from the site will decided on a case-by-case basis. Discharge to the POTW
must meet the regulations of City Ordinance No. 23-86 which establishes
pretreatment criteria, discharge prohibitions, and permit requirements. Both a
narrative and chemical specific prohibitions are included. Some of the pollutants
prohibited in the narrative include:
D-13
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AGENCY REVIEW DRAFT
• Any pollutant which will cause interference or will pass through the
POTW
• Any substance which will cause a fire or explosion, or will be injurious
in anyway to persons, the POTW or operations of the POTW
• Any solid or viscous substance which would cause obstruction to sewer
flow
• Any wastewater with a pH less than 5.0 or more than 10.0
• Any wastewater with toxic substances in sufficient concentration to
cause interference, or will pass through or constitute a hazard to
humans or animals
• Any substance which would cause the POTW's effluent or sludge to be
unsuitable for reclamation processing
• Any pollutant which constitutes a slug
• Any floating fats, oil or grease sufficient to cause interference or pass
through the POTW
• Any substance which will cause the POTW to violate its NPDES permit
• Any wastewater having a temperature which will inhibit biological
activity at the POTW
A toxic pollutant means pollutant designated toxic by EPA under the provisions of
the Clean Water Act, or included in the MDNR Critical Materials Register.
Chemical specific pollutant prohibitions are established for fats, oil and grease, total
suspended solids (TSS), BOD, phosphorous, heavy metals, cyanide, PCBs, and
D-14
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AGENCY REVIEW DRAFT
phenolic compounds (Table D-2). Criteria for PCBs was exceeded for maximum and
mean estimated groundwater influent concentrations and for phenolic compounds for
maximum estimated groundwater influent concentrations. Therefore, pretreatment of
the groundwater prior to discharge to the POTW will probably be required. Sampling
and inspection requirements are also included in this ordinance.
Implementation of this option (discharge to POTW) is contingent upon approval from
the POTW. Based on a permit application and baseline monitoring report, the
DWSD will issue industrial wastewater permits to users. There is not enough
information on the effluent concentrations from the treatment system to obtain
approval or disapproval for discharge to the POTW at this time. Discharge of treated
groundwater to the POTW was retained for use in the alternatives.
Reinjection. Reinjection of treated groundwater to the aquifer would require
obtaining a state permit (Michigan Administrative Code, Water Resources
Commission General Rules, Part 21) prior to discharge. Discharges to groundwater
must meet more stringent water quality standards than discharges to surface water.
The State of Michigan defines acceptable discharge limits based on health risks. The
limits are approximately 10 to 20 percent of the concentrations set in the drinking
water standards. A hydrogeological study is required to determine if discharge will be
allowed and monitoring is required. More information is needed on the effluent
concentrations from the treatment system before approval for reinjection to the
aquifer can be obtained. Also, more stringent effluent criteria would probably be
required. Due to these uncertainties and limitations, this option was not considered
in the alternatives.
DISCHARGE CRITERIA
Discharge to the Clinton River
Several remedial alternatives include extraction and treatment of groundwater with
discharge to the Clinton River. The Clinton River is not currently a protected public
D-15
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29-May-90
Table 2
SPECIFIC POLLUTANT PROHIBITIONS
CITY OF DETROIT WATER AND SEWERAGE DEPT.
ORDINANCE NO. 23-86
Constituent
Fats, oil or grease (1)
TSS
BOD
Phosphorus
Arsenic
Cadmium
Copper
Cyanide
Iron
Lead
Mercury
Nickel
Silver
Chromium
Zinc
Aroclor 1260
PCBs
Phenolic compounds (2)
Concentration
Limitiation
(mg/l)
2000
10000
10000
500
1
2
4.5
2
1000
1
0.005
5
2
25
15
0.0005
0.001
0.5
Onsite Monitoring
Maximum
(mg/l)
16
NA
13
2.5
0.316
0.004
0.023
NA
131
0.185
0.0009
0.109
0.009
0.17
1.73
ND
0.0095 +
1.039 +
Wells
Mean
(mg/l)
3
NA
2.7
0.38
0.033
0.003
0.013
NA
11
0.005
0.0001
0.023
0.005
0.008
0.154
ND
0.0011
0.0105
Limitations based on composite samples
(1) Limitation is based on the average of all samples collected within a 24-hour period
(2) Limited to compounds which cannot be removed by the POTW
(3) Includes the sum of 2,4-dimethylphenol, 2-methylphenol, 4-methylphenol, and phenol
NA = Not analyzed
ND = Not detected
+ = Criteria exceeded
-------
AGENCY REVIEW DRAFT
water supply source. All waters in the state are designated and protected for
agricultural, navigation, industrial water supply, warmwater fish, other indigenous
aquatic life and wildlife, and total-body contact recreation from May 1 to October 31.
Discharges must achieve applicable water quality criteria for the particular
classification of river. Water quality criteria include the Clean Water Act Federal
Water Quality Criteria for the protection of human health from the ingestion of
aquatic organisms, the Federal Water Quality Criteria (FWQC) for the protection of
aquatic organisms, and Michigan Water Quality Standards, including the Rule 57
Guidelines. Table D-3 presents the estimated organic and inorganic chemical
concentrations in the influent to the groundwater treatment system and the federal
and state water quality criteria for each chemical. Based on comparison of estimated
influent concentrations to water quality criteria, treatment of groundwater before
discharge to the river appears to be necessary.
The state will not specify effluent limits for a particular discharge until the application
for a permit is made. The state has indicated, however, that along with effluent
standards, best available treatment technologies will apply as well. According to
informal discussions with the state, application of best available treatment is generally
confined to conventional technologies commonly used in water and wastewater
treatment. In addition, according to state water quality standards, after mixing,
carcinogens discharged to the river will not create a level of risk to the public health
greater than 1 in 100,000.
Maximum and average influent concentrations from monitoring wells and three
leachate wells from the five onsite areas were used to estimate influent concentrations
to the treatment system and to determine which effluent criteria was exceeded.
Three alternatives include groundwater extraction and treatment, 3B, 4A, and 6A.
Alternative 3B, in which the estimated influent flow to the treatment system is
30 gpm for 3 years and 10 gpm for an unknown period, and Alternatives 4A and 6A,
in which the estimated influent flow to the treatment system is 60 gpm for 3 years and
40 gpm for an unknown period were used to estimate the contaminant concentration
D-16
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-------
AGENCY REVIEW DRAFT
in the Clinton River after mixing. For cost estimating purposes, the total time that
groundwater needs to be treated was estimated to be 30 years.
To determine which federal and state effluent criteria were exceeded, the
concentration of contaminants after mixing in the Clinton River was calculated. For
toxic substances, the state specifies that 25 percent of the receiving water design flow
can be used for determining effluent limitations. The design flow is equal to the most
restrictive of the 12 monthly 95 percent exceedance flows. Effluent concentrations
determined after mixing the effluent in the Clinton River apply to chronic water
quality criteria, and not acute water quality criteria. Calculated concentrations after
mixing were compared with chronic water quality criteria. Acute water quality criteria
were compared directly with the maximum and mean concentrations of the estimated
groundwater influent. The design flow was given as 71 cfs. The concentration in the
river after mixing was determined from the following equation:
C(SW) = C(GW) x Q(GW)/Q(SW)
where:
C(SW) = concentration of contaminant in the Clinton River
following dilution
Q(SW) = low design flow rate for the Clinton River x 0.25
C(GW) = maximum or mean contaminant concentration in the
groundwater
Q(GW) = collection and discharge rate of groundwater
For example:
C(GW), maximum benzene concentration = 1,500 u.g/1
Q(GW) = 30 gpm
Q(SW) = 71 cfs x 0.25 x 7.481 gal/ft3 x 60 sec/min = 7,967 gpm
C(SW) = 1,500 jig/1 x 30 gpm/7,967 gpm = 5.6 jig/1
D-17
-------
AGENCY REVIEW DRAFT
This method assumes that discharge is directly to the Clinton River and mixing occurs
instantaneously. It also assumes that the initial river concentrations are zero. The
initial influent concentrations are estimated and the range of variation with time is
expected to be great. It is likely these concentrations will change with time, but this
was not estimated since the effects of continued leaching from the landfill cannot be
quantified.
The estimated BOD in the collected groundwater was also compared to the effluent
limits generally applied to wastewater treatment plants (40 CFR Part 35,
Appendix A). Bioassays will probably be required to determine treated groundwater
effluent toxicity before discharge to the Clinton River.
Discharges of untreated groundwater collected by the onsite collection system
exceeded the federal or state water quality criteria or discharge standards for the 60,
40, or 30 gpm influent groundwater flow rate after mixing for either maximum or
mean groundwater concentrations for vinyl chloride, 4,4'-DDT, Arochlor-1254,
arsenic, and ammonia. Maximum or mean groundwater concentrations of 4,4'-DDT,
Arochlor-1254, arsenic, and ammonia exceeded federal or state criteria or standards
for the 10 gpm influent groundwater flow rate. Arochlor-1254, aluminum, chromium,
and zinc exceeded federal acute water quality criteria for maximum groundwater
concentrations. In addition, vinyl chloride and arsenic will probably exceed the 1 in
100,000 carcinogenic risk in the surface water after mixing for both alternatives.
Therefore, treatment of the groundwater before discharge to the Clinton River will be
necessary (Table D-4).
GROUNDWATER TREATMENT SYSTEM
This section combines the technologies and process options surviving secondary
screening into an appropriate treatment system for each alternative. The purpose is
to develop a conceptual design for each alternative that is used to develop a detailed
description, evaluation, and an order of magnitude cost estimate for each alternative.
A treatment system which is capable of meeting the discharge requirements already
D-18
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AGENCY REVIEW DRAFT
discussed is described below. The State of Michigan will determine the final
discharge requirements for discharge to the Clinton River. The DWSD will establish
discharge limits to the POTW. The ability of the proposed treatment system to meet
the final limits for discharge to either the Clinton River or the POTW needs to be
reconsidered during predesign and design phases. Treatment of the groundwater
before discharge to POTW will probably be less extensive than treatment before
discharge to surface water.
The treatment systems presented are representative of available technologies and
process options. Efforts were made previously to screen those technologies and
process options not likely to work. Technologies and process options not included in
this treatment system may be equally effective and deserve consideration during the
predesign and design phases. The systems presented here are not intended to
exclude other technologies from consideration but to present a reasonable treatment
system for each alternative so that a fair comparison of alternatives can be made.
As noted in the preceding section, the discharge of untreated groundwater collected
by the proposed groundwater extraction system to the Clinton River would result in
surface water quality criteria being exceeded. The concentrations of vinyl chloride,
4,4'-DDT, Arochlor-1254, arsenic, chromium, aluminum, zinc, and ammonia in
extracted groundwater will need to be lowered before discharge to Clinton River.
Although these chemical specific criteria must be met before discharge, the
application of best available treatment technology and the cleanup goals identified in
the State of Michigan Environmental Response Act must also be considered.
The evaluations of the groundwater treatment systems were limited by several factors.
It is expected that TSS from the extraction wells would be fairly low (<50 mg/1),
although no actual TSS values were determined in groundwater samples. It is also
difficult to predict the volume of oil that will be extracted from the extraction wells
and the proportion of the oil existing as free product or emulsified in the water. In
addition, BOD concentrations may be higher than previously measured if a significant
D-19
-------
AGENCY REVIEW DRAFT
amount of leachate from the Phase III Landfill toe or the extraction wells is collected
and treated at the proposed treatment plant.
A flow and strength equalization tank is proposed both to equalize flow and strength
variations and to lessen the effects of any unexpected slug loads to protect the
downstream treatment system. At this site, influent flow and concentrations are
expected to vary with time. This tank also provides some storage during maintenance
and repair of the treatment system.
Although low concentrations of oil and grease were measured in the groundwater,
wells with separate nonaqueous phase oil layers were found in the Phase I Landfill.
Oil and grease were not measured in these samples but levels in the extracted
groundwater are expected to be high. Therefore, oil removal was included in the
treatment system. Removal of oil is necessary to protect the downstream treatment
processes, particularly to prevent fouling of the activated carbon system as well as to
prevent discharge of oil to the Clinton River. Offsite treatment is required for the oil
from the oil and water separation unit except for under Alternative 6A in which the
oil may be treated in the onsite incinerator used to treat contaminated soil and
refuse.
Precipitation, flocculation, and clarification are processes used in combination to
remove metal contaminants from wastewater. Lime or caustic soda can be used to
raise the pH, causing the metals to precipitate out of solution. Lime is less expensive
than caustic soda, although it is more difficult to use. Lime is normally fed as a
hydrated lime slurry. The material is stored dry and slurried before it is mixed with
the influent water. The slurry is introduced to the groundwater in a completely mixed
tank with an approximate 30-minute retention time. Caustic soda is available in a
liquid form or as a dry solid, is highly soluble in water, and handling and feeding are
convenient.
Lower concentrations of metals in the effluent can be obtained using sulfide
precipitation than with hydroxide precipitation. Sulfide precipitation is generally more
D-20
-------
AGENCY REVIEW DRAFT
difficult to implement. In addition, H2S gas may be generated, posing a health and
safety hazard. Sulfide precipitation will need to be considered further if the state
requires lower effluent limits than may be obtainable with hydroxide precipitation.
In an anoxic environment such as in the groundwater, chromium generally will be
found in its reduced state as the trivalent ion which can be precipitated as a
hydroxide. If chromium is found as the hexavalent ion, a chemical reducing agent,
such as sodium bisulfite can be added to the water to reduce it to the trivalent state.
Arsenic requires the formation of floe to be removed from the water. Iron can be
added to water to increase the removal of arsenic. Since relatively high
concentrations of iron are already present in the groundwater, iron addition should
not be necessary. Traditional precipitation/flocculation/clarification may not remove
arsenic to levels low enough to meet water quality criteria. Although effluent
concentrations of arsenic could exceed the U.S. EPA water quality criteria of
0.0175 ng/1 it is assumed that obtaining this level of arsenic in the effluent would not
be required because it is below analytical detection limits of standard methods of
analysis. Reducing arsenic to such low levels may result in higher operation and
maintenance costs. Additional, nonconventional treatment such as treatment with
activated alumina may be required to achieve very low arsenic concentrations in the
effluent.
Following the addition of precipitants, coagulants are added to neutralize the formed
particles' charges so that the particles can come into contact to create larger particles
for better settling. Alum or lime are commonly used as coagulants. Thus, lime can
function for both pH adjustment and as a coagulant. An essential part of any
chemical precipitation system is stirring or agitation to increase particle contact
(flocculation). During the flocculation process the water is mixed slowly to promote
agglomeration of the destabilized solid particles. Polymers can be used to increase
particle size and settling rates.
D-21
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AGENCY REVIEW DRAFT
Treated groundwater containing precipitants is clarified by creating sufficient
residence time to allow suspended particles to settle out of solution. After settling,
clarified water would be drained off the top for filtration, and sludge would be
withdrawn from the bottom.
The sludge from the clarifier would also need to be disposed of offsite after further
treatment onsite. Further onsite treatment would consist of thickening the sludge to
reduce the water content and sludge volume. Several sludge thickening methods are
available. One option is the gravity sludge thickener. A gravity sludge thickener is
similar to a solids contact upflow clarifier with a steep sloped bottom and a scraper
on the bottom that slowly rotates and further settles the sludge. The degree of
settling depends on the type of sludge. It may be possible that a gravity thickener
could increase the solids concentration from 2 percent to 10 percent. The simplest
method for sludge dewatering would be to construct drying beds for the sludge.
Drying beds can be used following thickening in a gravity sludge thickener. The beds
would consist of a foot of sand with an underdrain system. Sludge would be placed
on the beds for a few weeks to a few months. Evaporation and drainage would
reduce the water content. After drying, the sludge would be scraped off the beds and
disposed of. The success of this option is dependent on weather conditions. Covers
would have to be constructed over the drying beds to prevent rain from wetting the
sludge. Pilot testing would have to be done to determine its dewatering effectiveness
on metal sludge.
The third alternative for sludge disposal involves onsite dewatering using belt filters or
pressure filtration. Thickening before pressure filtration may not be necessary.
Thickening before dewatering would probably be required for belt filtration. While
onsite dewatering would be more expensive to implement and complex to operate, if
this procedure is performed, the dewatered sludge could be disposed of in a landfill
as a solid. It is assumed that disposal in a RCRA-type landfill will be required.
Both belt and pressure filtration subject the sludge to pressures sufficient to drive
water out of the sludge, producing a sludge with 30 to 50 percent solids. The filtrate
D-22
-------
AGENCY REVIEW DRAFT
would be recycled through the treatment plant. If onsite dewatering can produce a
sludge with 40 percent solids, the volume of solids to be landfilled would be an
estimated 1.4 ft3/day to 8.4 ft3/day (10 to 60 gpm flow rates).
Bench- and pilot-scale precipitation tests would be needed to determine optimum pH,
reaction times, reagent amounts, sludge production and to verify actual removal of
the metal contaminants.
Filtration would be the final step of metal removal. Precipitated metals not removed
in the clarification stage would be captured. Filter beds consist of granular media
such as sand or anthracite which trap suspended solids. Suspended solids can foul
downstream treatment processes such as the air stripper or carbon adsorption units.
Filters are generally controlled by adjusting the flow rate or controlling the head on
the filter. When a filter is first used, most of the suspended solids are captured in the
media pores near the surface. As the pore space fills, suspended solids move deeper
into the media bed. Eventually, the clean media is used up. At this point, the filter is
backwashed with water and air for a short time under a high flow rate. During
backwash suspended solids are flushed off the media and directed back to the
clarifier. Design of filter parameters such as media type and size, bed depth, loading
rates, and frequency of backwash need to be determined after pilot testing.
Air stripping would be used to remove VOCs including vinyl chloride and ammonia.
In this process, air is brought into contact with contaminated water, allowing the
VOCs and ammonia to transfer to the air. Ammonium ions exist in water in
equilibrium with ammonia. As the pH of the water is increased above 7, the
equilibrium shifts and the ammonium is converted to ammonia. The ammonia may
be removed by agitating the water in the presence of air. The pH would have already
been increased in the precipitation step.
Air stripping is commonly performed in a countercurrent packed tower.
Contaminated water is pumped to the top of the tower where it is distributed over a
bed of packing to break the water stream into small drops to increase the air-water
D-23
-------
AGENCY REVIEW DRAFT
interface. Typical packing material is irregular shaped plastic pieces, 1 to 3 inches in
diameter. Because ammonia is less volatile than the VOCs, the removal of ammonia
would control the design parameters of the air stripper. Treatment of the
contaminated air prior to discharge may be needed, although the final decision would
rest with the State of Michigan. Vapor-phase carbon adsorption can be used for
treatment of the VOC contaminated air, if required. Neutralization of pH, which is
usually following filtration, can be performed after air stripping to allow removal of
ammonia in the air stripper.
Carbon adsorption is reliable and effective in removing trace concentrations of
volatile and semi-volatile organic compounds and some heavy metals. Carbon
adsorption units can be designed to treat low concentrations without reducing the
effectiveness of the treatment. The PCBs and pesticides can be effectively removed
using granular activated carbon. Although activated carbon could be used instead of
air stripping to remove VOCs, it is less effective on vinyl chloride; therefore, the
additional air stripping step is needed.
Bench-scale testing to determine operating capacity and contact time to determine
absorber size and optimum system configuration needs to be done before design.
For purposes of the FS, a system of two carbon vessels in series is assumed. When
breakthrough occurs in the first vessel, the second vessel is put on line and a
replacement vessel is used for the secondary vessel. Carbon from the vessels will
need to be periodically replaced and regenerated.
The proposed treatment system (Figure D-l) consists of a flow and strength
equalization tank, oil and water separation unit, precipitation/flocculation/clarifier
unit, filter bed, air stripper, and an activated carbon system. The handling and
disposal of sludge from the sedimentation unit and disposal of oil collected from the
oil/water separation unit are also part of the proposed system. VOC emissions from
the treatment units will need to be addressed. Control of the emissions may be
required during the design phase.
D-24
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AGENCY REVIEW DRAFT
SOIL/SEDIMENT/LANDFILL OPERABLE UNIT
REMEDIAL OBJECTIVES
The remedial objectives for the soil/sediment/landfill operable unit are to:
• Control leaching to groundwater of contaminants from the landfill
contents and oil-saturated soil to protect public health and the
environment
• Protect public health by preventing exposure to landfill refuse, surface
soil, and sediment
• Reduce or contain the volume or mass of contaminated source
materials including soil, landfill contents, buried waste oils, and other
buried waste
Based on the baseline risk assessment, the following solid media are of concern:
• Landfill contents including oil-saturated refuse and soil
• Sediments and oil-saturated soil in the Oil Seep Area
• Surface soil in discrete areas of the Phase I Landfill
Compounds identified as exceeding carcinogenic risk criteria through ingestion based
on the upper 95 percent confidence limit of the arithmetic mean concentration are
PNAs and PCBs.
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CHARACTERISTICS AND QUANTITY OF
SOIL/SEDIMENT/LANDFILL CONTENTS
Contamination of soil, sediment, and landfill contents resulted from the operations at
the G&H Landfill. The volume and characteristics of the media that make up the
soil, sediment, landfill operable unit are described in this section.
Landfill Contents
The RI indicates that landfill contamination is located primarily in the Phase I
Landfill. The test pit investigation found that large areas of the Phase I Landfill
refuse are underlain by sand and gravel saturated with oil and solvents. The overlying
refuse was also found to be mixed with oily material at some locations, especially the
southeastern portion of the Phase I Landfill. Visual observations of soil borings and
test pits concluded:
• Oily waste and oil-saturated soil is present in most of the Phase I
Landfill.
• Landfill refuse and the underlying soil is saturated with oil at the
codisposal area and at the locations of two former oil ponds.
• Soils are oil-saturated or contain oily sludge up to 10 feet below the
landfill refuse over most of the Phase I Landfill. In many locations, the
lower 1 to 5 feet of landfill refuse is also saturated with oil.
• In some areas, landfill refuse and soil is stained dark gray or black but
not saturated with oil. This indicates that oily soils may have been
mixed with nonoily soil and refuse, or that the materials may have been
burned.
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A typical profile of the Phase I Landfill refuse, from top to bottom is described as
follows:
• 5 to 10 feet of residential or light commercial waste that has undergone
various degrees of decomposition. It consists mainly of paper, household
garbage and trash in plastic bags, wood, and lumber, appliances, auto
parts, and tires. It is mostly dry or slightly moist, with some wet zones.
• 5 to 10 feet of industrial waste consisting of metal shavings and
miscellaneous parts, wire, rolls of fabric, wood, and 55-gallon drums. It
is usually dry at the top and wet at the bottom. If oil is present, it is
usually floating on the groundwater and mixed into the lower portion of
the refuse.
2 to 10 feet of oily soil.
Analytical results from samples collected in the oily soil and refuse showed that large
areas of the Phase I Landfill are contaminated with BETX, PNAs, chlorinated VOCs,
and PCBs in the mg/kg range. Inorganic analytes were also found in concentrations
above background levels. Test pit samples were also analyzed for incineration
parameters.
The volume of oil and contaminated soil in the entire Phase I Landfill is about
1,700,000 cubic yards. The areal extent of contamination in the Phase I Landfill is
presented in Figure 3-2. "Hot spots" identified using physical and chemical data are
represented as shaded areas on this figure. Due to the heterogeneous nature of the
landfill and the limited extent of the remedial investigations, it is likely that the actual
extent of hotspots differ from those shown. Based on the known site conditions, the
volume of landfill waste in the hotspots is estimated to be 800,000 cubic yards.
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Surface Soil
During the interim RI, samples were collected from the uppermost 3 feet at 23 soil
boring locations. Two groups of compounds, PNAs and PCBs, were frequently
detected in surface soil. Surface soil samples were taken during the Stage III
investigation but the analysis was limited to PCBs and pesticides.
PNAs were detected in soil on the Phase I Landfill and the Oil Seep Area. PCB
contamination appears to be limited to 3 areas in the Phase I Landfill: near oil pond
No. 2, by the site entrance, and near the center of the site. The extent of surface soil
contamination is not fully known, although based on the RI data it appears limited to
portions of the Phase I Landfill.
Sediment
The baseline risk assessment indicated that only the sediment in the area of the oil
seep is of concern. Sediments from the Oil Seep Area contain BETX, PNA, and
PCBs. The volume of contaminated sediment and soils associated with the Oil Seep
Area is estimated to be 7,000 cubic yards.
SECONDARY SCREENING OF TECHNOLOGIES
Treatment technologies were initially screened (Appendix A) to remove those clearly
inappropriate for the types of materials to be treated. The soil treatment
technologies and associated process options that remained after primary screening
were:
• Solidification/fixation/stabilization
— Sorption
- Pozzolanic agents
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• Thermal treatment
— Low-temperature thermal treatment (volatilization)
— High-temperature thermal treatment (incineration)
• In situ treatment
— Enhanced oil recovery
Soil flushing
Mobilization of sludges with steam
These potentially applicable technologies are analyzed in more detail in the following
sections.
Solidification/Fixation/Stabilization
The purpose of these processes is to immobilize the toxic constituents of the wastes.
This is done by changing the constituents into immobile (insoluble) forms, binding
them in an immobile, insoluble matrix and/or binding them in a matrix which
minimizes the potential for contact with percolating groundwater. Selection of a
solidifying agent should be made with the aid of a laboratory testing program
designed to evaluate the effectiveness of a number of different agent/concentration
combinations. The quality of leachate generated from solidified waste in the
laboratory or pilot tests can be used as a measure of effectiveness. Long-term
monitoring would still be required. Solidification, fixation, and stabilization processes
would most likely be used for treatment of source areas within the Phase I Landfill,
sediments, or prior to land disposal. Solidification, fixation, and stabilization
processes would be needed to help meet treatment requirements imposed by the land
disposal restrictions under the Hazardous and Solid Waste Amendments (HWSA) of
RCRA. These regulations restrict land disposal of various classes of hazardous wastes
unless the wastes or treated waste residues meet the specified treatment standards.
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These processes can be performed in situ or in tanks or containers. The effectiveness
of in situ techniques that rely upon in-place mixing may be limited, given the large
volume, depth, and thickness of waste materials.
Wastes can also be excavated, mixed with the solidification/fixation/stabilization
material, and disposed of in either onsite or offsite landfills. There is little
information available on its effectiveness on refuse waste. Offsite land disposal of
treated or untreated soil or sediment would probably be subject to RCRA land
disposal restrictions. Land disposal restrictions prohibit land disposal of certain listed
wastes after November 8, 1990, unless constituents in the Toxicity Characteristic
Leaching Procedure (TCLP) extract are below specified concentrations. Disposal
onsite in a RCRA unit may also be subject to the land disposal restrictions.
Sorption. This process improves the handling characteristics of wastes by eliminating
free liquids. Sorbents include a variety of natural and synthetic solid materials.
Commonly used natural sorbant materials include flyash, kiln dust, vermiculite, and
bentonite. Synthetic sorbant materials include activated carbon product which sorbs
dissolved organic contaminants, Hazorb (a Dow Chemical product) which sorbs water
and organic contaminants, and Locksorb (a Radecca Corp. product) which reportedly
effectively sorbs all emulsions.
Liquid immobilization depends on added ingredients. The process may be suitable
for organic and inorganic contaminants. The quantity of sorbant required varies
widely depending on the nature of the liquid phase, the solids content of the waste,
and moisture level in sorbant.
The following are advantages of this technology: materials are plentiful and
inexpensive, waste handling is improved, minimal pretreatment is required, and the
products' bearing strength after treatment is adequate for land disposal.
The following are disadvantages: additives increase waste volumes, leachate control is
highly variable, free water may be released under pressure and there is temperature
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sensitivity. This process results in high concentrations of contaminants at the surface
of the material and contaminants may leach. The treated material is permeable.
The long-term effectiveness of this process as applied to organic wastes is not known.
Sorption could be used in conjunction with land disposal. This technology would not
reduce toxicity, would increase overall volume, and the reduction of mobility is limited
with time. A major limitation of this technology is that leaching of waste constituents
while reduced, is not eliminated. U.S. EPA generally has not considered the use of
sorbents acceptable as a means of treatment. Because of the heterogeneity of the
landfill contents, sorption would be ineffective because it depends on thorough
mixing. This technique may be more applicable for soils and sediments than the
landfill contents, although it was not retained for further consideration because of its
unknown effectiveness on organic wastes.
Stabilization. Stabilization techniques using pozzolanic or silicate-based agents treat
wastes and contaminated soils by the addition of large amounts of siliceous materials
combined with a setting agent such as lime, cement or gypsum. This treatment results
in a dewatered, stabilized, solidified product. Mobility is reduced through the binding
of hazardous constituents into a solid mass with low permeability that resists leaching.
This process is used for sludges and contaminated soils. Contaminants can include
metals, waste oils, and solvents. Materials such as borates, sulfates, and
carbohydrates interfere with the process. Long-term stability and resistance is good
for some wastes but unknown for others.
Stabilization has been most successful when applied to inorganic waste streams. Data
suggests that silicates used with lime, cement, or other settling agents can stabilize a
wider range of materials including oily sludges and sludges and soils contaminated
with solvents, than cement-based technologies. Several vendors use proprietary
organophilic compounds as additives to bind organic compounds to the solid matrix.
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Critical parameters in stabilization treatment include selection of stabilizing agents
and other additives, the waste-to-additive ratio, mixing, and curing conditions. All
these parameters are dependent on the chemical and physical characteristics of the
waste.
Stabilization is easily implemented with commercial cement mixing and handling
equipment or in situ using earthen pits and earthmoving equipment. Costs depend
largely on reagent mixture ratios and sampling and analysis requirements for quality
control. However, costs are generally low compared to other waste treatment
technologies.
There may be many limitations in applying this treatment technology to landfill
contents. The heterogeneity of the landfill contents may require extensive handling to
ensure uniform mixing. Additionally, the volatiles present in the oily waste may
volatilize as a result of the heat of the solidification reaction.
This process may be applicable to contaminated soils and sediments but was not
retained because of its limited effectiveness on organic solvents. It has been retained
for treatment of inorganic residuals from other treatment processes such as (e.g.,
incinerator ash) to address land disposal restriction treatment requirements.
Thermal Treatment
In thermal treatment, organic contaminants are removed or destroyed by heating.
Several types of thermal treatment units are available, but the principal is to volatilize
the soil contaminants or destroy them in an after burner, if needed. Low-temperature
volatilization units can be used for volatile-chemical contamination, whereas high-
temperature treatment (i.e., incineration) can be used to destroy all organic
contaminants.
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Thermal treatment is often considered for remedial actions because it effectively and
reliably destroys organic contaminants. Inorganic contaminants would not be
destroyed.
High-Temperature Thermal Treatment. High-temperature thermal treatment is the
use of high temperatures as the principal means of destroying or detoxifying
hazardous wastes. Several high-temperature thermal process options have been used
to treat contaminated soils. They include:
• Rotary-kiln incinerators
• Fluidized-bed incinerators
• Infrared reactors
In addition, standard refractory-lined or waterwall incinerators are commonly used for
the incineration of solid refuse waste, such as that found in the Phase I Landfill
source areas.
The advantages of high temperature thermal treatment include:
• Volume reduction (dependent on waste type)
• Detoxification
• Materials recovery
Thermal treatment essentially destroys the original organic waste completely. The
destruction efficiency achieved for properly incinerated waste streams often exceeds
the 99.99 percent requirement for hazardous wastes. Hydrogen chloride emissions
are controlled with wet or dry scrubbers. Available air pollution control technologies
can effectively treat particulate emissions.
A common unit used for incineration of bulk soils is the rotary kiln. Although there
are distinct advantages to other units, such as lower air emissions with the infrared
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unit, the rotary kiln has the longest performance record and, therefore is considered
the representative option for the purpose of technology description in this FS.
A rotary kiln incinerator destroys the organic contaminants by thermally oxidizing
them to inert components. Oxidation occurs in a long, inclined, rotating cylinder
through which the soil passes. The cylinder is rotated about an inclined axis to
agitate the soil for greater oxidative efficiency, and to promote transport of solids
through the kiln. The temperature within the refractory-lined kiln is normally
maintained in the range of 1,500°F to 2,000°F.
Solids travel to the low end of the kiln, where they are discharged to an ash sump. In
offsite incineration, ash disposal is part of the incineration service. If incineration is
performed onsite, ash characteristics and disposal must be considered. The ash must
be tested to determine whether it should be managed as a hazardous waste. Ash that
passes cleanup criteria may either be disposed of onsite or held until delisted for
offsite disposal. Because inorganic compounds such as heavy metals may concentrate
in the ash and may leach from the material, stabilization or some form of
solidification may be necessary prior to disposal.
Hot gases (temperature at 1,800°F to 2,200°F) and suspended particulates in the gas
pass into a second combustion chamber (called the afterburner) designed for
complete combustion of the organic offgases. Offgas must be treated to remove
particulates or acid forming compounds before release to the atmosphere. This is
often done with venturi scrubbers or electrostatic precipitators.
For several decades, rotary kilns have been in use for incineration of industrial wastes,
for production of cement and other mineral aggregates, and for other thermal
processing. The technology is commercially available from a number of vendors in
the United States.
Offsite incineration would involve hauling contaminated wastes to a RCRA-permitted
incinerator facility. For landfill contents or hotspots, the offsite incineration option
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may be difficult to implement because of the low capacity at permitted facilities and
high cost. No TSD facilities have been identified in Michigan which have an onsite
incinerator. The nearest permitted incinerators are in the Cleveland, Ohio area or
Chicago, Illinois.
Offsite incineration of the oil seep sediment may be more implementable than for
landfill contents and hotspots. Risks associated with incineration can be managed and
controlled however, offsite incineration would pose additional risks associated with
waste transport.
Onsite incineration involves the temporary placement of a mobile or transportable
incinerator at the site or construction of an onsite unit to burn contaminated soil or
sediment. In the past 5 years, portable units have been constructed on trailers so that
small rotary kilns can be transported to appropriate sites.
A mobile rotary kiln system is usually mounted on several heavy duty trailers and
requires about 1 to 2 acres for setup. Trial burns, to meet the substantive
requirements of RCRA, must be conducted at startup to determine operating
parameters such as temperature, auxiliary fuel, waste federates, and residence time;
and to obtain performance data such as chlorine and paniculate emissions, ash
contents, and destruction and removal efficiencies for principal organic constituents.
The feed rate depends on the moisture and heating value of the waste material. A
portable rotary kiln can typically incinerate 2 to 5 cubic yards of solids per hour. The
incineration system would be dismantled after the wastes are treated.
Onsite incineration is a complex option to implement. Siting, permitting,
mobilization, and startup could take 1 to 2 years. Operation requires trained
personnel and continuous monitoring, and extensive material preparation and
handling is necessary. Incineration residues such as ash, particulates, and process
water would all require disposal. The release of dust and VOCs resulting from
material handling would require control.
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Selection of offsite versus onsite incineration will depend on several factors including
transportation costs, capacity of an offsite incinerator to handle the volumes of soils
to be treated, permitting and mobilization time and cost associated with onsite
incineration, availability of trained personnel to operate an onsite incinerator, and
necessity for the treatment of off-gases, ash, and scrubber water at the onsite facility.
In general, offsite treatment is more cost effective for smaller quantities of soil, while
onsite treatment is most cost effective for larger quantities of soil. Onsite incineration
for major excavated oil- and solvent-contaminated source areas with subsequent
disposal of ash in an onsite RCRA cell will be retained for incorporation into
alternatives.
Low-Temperature Thermal Treatment. Low-temperature thermal treatment is the
process by which volatile organic compounds are driven off by heating contaminated
soils to temperatures above the individual compound's latent heat of vaporization.
Destruction is not the ultimate objective of this treatment; the solid contaminants are
transferred to a gas phase which is treated by carbon absorption or a combustion
afterburner.
One form of low-ternperature thermal treatment is asphalt incorporation.
Incorporation of soil contaminated with petroleum-based compounds into hot asphalt
mixes is a recently developed remedial technology. The mixture is heated by
conveyance through a dryer where average temperatures range from 260°C to 427°C.
During drying, some of the more volatile compounds are volatilized while the heavier
hydrocarbons remain in the asphalt mix. In effect, asphalt incorporation volatilizes
some of the constituents while the other contaminants become encapsulated and
solidified in the asphalt product. The asphalt in turn is used in construction.
A variation of this treatment is referred to as roasting. The process of roasting
includes all the components of asphalt incorporation, however, the contaminated soil
matrix is not incorporated into asphalt. Rather, the material is conveyed through
dryers, more volatile compounds are emitted and less volatile compounds are retained
in the soil.
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One other design for a low temperature thermal treatment processes soils through a
pug mill or rotary drum system equipped with heat transfer surface. An induced
airflow conveys the desorbed volatiles to an air treatment system. This type of system
may be used to remove volatile organic compounds with Henry's Law constants
greater than 3 x 10~3 atm m3/mole.
A mobile system of this type is in use. This system employs a process in which solids
with organic contaminants are heated in the presence of water, driving off the water
and organic contaminants and producing a dry solid containing trace amounts of the
organic residue. The dryer is a rotary kiln. The operational temperature is between
SOOT and SOOT.
In general, the landfill contents' high volume and heterogeneity may serve to limit the
application of offsite or onsite treatment. The material would have to be
preprocessed to a more uniform size. The high volume would result in a long period
of operation.
The use of asphalt incorporation or roasting is limited by several factors including
availability of nearby asphalt plant, construction demands for the asphalt, the volume
processed, and acceptability of the use of waste incorporated asphalt. Even if an
asphalt plant is nearby, the willingness of the facility to accept the waste is a major
uncertainty, particularly due to the PCB contamination.
The contaminants present in the landfill and sediment include compounds of low
volatility such as PCBs and PNAs. These chemicals would not be removed from the
soil and their toxicity or volume would not be reduced without further treatment.
The application of mobile treatment systems has the following limitations: organics
present need to have boiling points less than SOOT; the waste needs to contain less
than 10 percent total organics and less than 60 percent moisture. The heterogeneity
of the landfill soils and the presence of low volatile compounds such as PCBs and
PNAs are limits to this systems application.
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Low-temperature thermal treatment, either onsite or offsite, is not appropriate
because of capacity, processing, and effectiveness concerns.
In Situ Treatment
Enhanced Oil Recovery. The oily wastes at the G&H Landfill are made up of oil that
will flow readily and oily sludges that are highly viscous. To mobilize oily sludge, both
soil flushing and steam mobilization can possibly be used. These experimental
technologies may be viable for reducing the long-term site management costs.
Without pilot testing and further information, it is difficult to determine the
implementability and effectiveness of these technologies at the site.
In situ soil flushing is a process applied in situ to unexcavated soils using a solvent or
surfactant (or water) to enhance the contaminant solubility, which results in increased
recovery of contaminants in the leachate or groundwater. The system consists of
extraction wells drilled in the contaminated soils zone, reinjection wells upgradient of
the contaminated area, and a wastewater treatment system. The technology is most
often used to remove volatile organics from permeable soils.
Following treatment, groundwater is reinjected upgradient of the extraction wells and
leaches through the contaminated soils. The leachate is then collected, treated, and
re-injected back into the system, creating a closed loop system. Nontoxic or
biodegradable surfactants or chelating agents may be added to the water to be
injected to help solubilize the contaminants. The type of washing fluid used is
contingent upon the nature and number of contaminants present.
Four factors determine the effectiveness of the soil flushing process:
• Waste type
• Soil characteristics
• Site hydrology
• Flushing fluid selection
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Soil flushing has the greatest potential for success on soils contaminated with only a
few specific chemicals. Effectiveness of treating soils with multiple chemicals is
limited. Successive treatments with a change of formulation may be required for
these soils. Unfavorable soil conditions include:
• Variable soil conditions
• High organic content
• Low permeability
• Soil/solvent reactions
Site hydrology must be such to permit recapture of flushed contaminants and soil
flushing fluids. Flushing fluids must be selected to avoid high toxicity or volatility,
difficult surfactant recovery, and reduction of soil permeability. Problems with the
formation and subsequent treatment of large volumes of emulsions may be a concern.
Removal of the contaminants from the collected groundwater is often difficult once
they have been mobilized in the recovered fluids.
Characteristics of contaminated soils at the G&H Landfill that limit the application of
this technology include the presence of multiple categories of chemicals, soil
permeability, heterogeneity of the landfill contents, and landfill size.
Flushing is an experimental technology that may not be effective or appropriate for
this site. It could be tested at the site to determine its effectiveness and long term
operations and maintenance requirements. This technology can be potentially applied
with simpler or more conventional containment and treatment technologies.
The use of steam to mobilize thick, highly-viscous petroleum (i.e., tar sands) from oil
reservoirs has been used in the petroleum industry for a number of years. The basic
concept for the G&H Landfill would be to mobilize the waste oil sludges found 15 to
20 feet below ground surface within the Phase I Landfill by introducing steam under
pressure. The pressurized steam would reduce the viscosity of the sludges and push
them from the soil pores. Once mobilized, the sludges could be collected with
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extraction wells and run through an oil/water separator. The permeable nature of the
soils at the G&H Landfill site would require the installation of a low-permeability
barrier (landfill cap). This low-permeability cap would contain the steam, allowing
the treatment cell of interest to be pressurized which would drive the thick, viscous oil
sludges from the soil matrix and prohibit the migration of the contaminant laden
steam.
TREATMENT OF SOIL/SEDIMENT/LANDFILL CONTENTS
Technologies that are retained into alternatives include enhanced oil recovery with
soil flushing or steam injection and in situ biological treatment in Alternative 4B.
These are unproven, experimental technologies that cannot be evaluated in the FS
without extensive testing to determine their effectiveness at the site. These
technologies need to be evaluated further during predesign and design phases as
more information becomes available. They are potentially effective at lowering long
term site management costs. Although described in the alternative, because of the
previously mentioned factors, detailed cost estimates for these innovative technologies
were not developed.
Alternative 6A includes excavation of hot spots in the Phase I Landfill and treatment
and disposal in an onsite RCRA landfill cell and would require treatment of these
soils and refuse to meet RCRA land disposal requirements. An estimated
800,000 cubic yards of soil and refuse would need to be treated. Onsite incineration
is incorporated into the alternative for the treatment of these source area materials of
mixed soil and refuse. Wire and drums may have to be separated from the source
area materials as they can interfere with the operation of the incinerator.
OFFSITE GROUNDWATER RESIDENTIAL AND INDUSTRIAL WELLS
Contamination was identified in several off site commercial, industrial, and residential
wells east of the site. Contamination in groundwater from individual, commercial,
and industrial wells exceeds the carcinogenic risk criteria for ingestion compounds,
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1,1-dichloroethane, 1,1-dichloroethene, benzene, trichloroethene, and vinyl chloride.
Current MCLs or MCLGs exceeded in individual, commercial, and industrial wells are
vinyl chloride, benzene, and trichloroethene. No risk criteria were exceeded in
sampled residential wells east of Ryan Road.
Chlorinated VOCs, 4-nitrophenol, benzene, and xylene were detected in water from
one or more offsite commercial and industrial wells. Low concentrations of
chlorinated VOCs were identified in several residential wells east of Ryan Road from
sampling performed in 1984. The organic contamination at the residential wells
cannot be definitely attributed to the site; however, the types of contaminants
detected in these wells are consistent with the waste types found at the site.
Contamination detected in wells in the industrial and commercial area west of Ryan
Road is probably site-related.
Approximately 44 residences east of the site are connected to the municipal water
system. Businesses east of the site do not use their wells for drinking water and have
been supplied with bottled drinking water by MDNR. The only remedial action
proposed for these offsite contaminated wells is connection to alternative water
supplies. Water used in the residences and commercial and industrial facilities must
meet drinking water quality criteria. A Shelby Township waterline is located along
Ryan Road and connections to the city water supply can easily be made.
REFERENCES
Ardie, Judy L., Michael M. Arozarena, and William E. Gallagher. A Handbook on
Treatment of Hazardous Waste Leachate. EPA 600(8-87/006. February 1987.
Metcalf and Eddy, Inc. Wastewater Engineering: Treatment/Disposal/Reuse. McGraw
Hill. 1979.
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Nyer, Evan K. Groundwater Treatment Technology. New York: Van Nostrand
Reinhold Co., Inc. 1985.
Peters, Robert William, and B. M. Kim, ed. Separation of Heavy Metals and Other
Trace Contaminants. AICHE Symposium Series No. 243, Vol. 81. American Institute
of Chemical Engineers. 1985.
U.S. EPA. Treatability Manual EPA 600/8-80-042. Washington, DC: U.S.
Government Printing Office. July 1980.
U.S. EPA. Cost of Remedial Actions Computer Model 1988.
U.S. EPA. Technology Screening Guide for Treatment of CERCLA Soils and Sludges.
EPA 540/2-88/004. September 1988.
U.S. EPA. Guidance on Remedial Actions for Contaminated Groundwater at
Superfund Sites, Interim Final. EPA/540/G-88/003. December 1988.
USGS. Water Resources Data—Michigan. 1987.
GLT984/002.51
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Appendix E
VEHICULAR AND CONSTRUCTION ACCIDENTS
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Appendix £
VEHICULAR AND CONSTRUCTION ACCIDENTS
INTRODUCTION
The RI estimated carcinogenic and noncarcinogenic health risks to potential receptors
at the G&H Landfill. These health risks were intended to identify the magnitude of
the risks and assumed no remedial action would take place. The FS developed
remedial alternatives to reduce these risks. However, other types of risk may be
introduced to the site as part of the remedial action. Specifically, there are risks to
workers associated with any construction project or with the transport of large
quantities of materials across public roads. This appendix presents estimates for the
number of construction worker injuries and deaths associated with onsite construction
and the number of injuries and deaths associated with material transportation.
CONSTRUCTION DEATHS AND INJURIES
Based on information from the National Center for Health Statistics and the Bureau
for Labor Statistics, the National Safety Council estimates that the death rate for
construction workers is 34 per 100,000 workers (National Safety Council - Accident
Facts, 1989 edition). It is estimated in the same report that there is a 14.5 percentage
rate of occupational related injuries and illnesses each year.
The approach used in this FS was to estimate the size of the construction crew and
the length of remediation to calculate total worker years and the corresponding
statistical chance of death or injury. For example in Alternative 6A—Source
Removal and Treatment, it was assumed 40 workers would be onsite for 20 years.
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40 workers x 20 year = 800 worker years
and
800 worker years x (34 deaths/100,000 workers/years) = 2.7 x 10'1 deaths
A similar calculation was performed for worker injuries. Table E-l summarizes the
worker injury rate and death rate for each alternative. It is emphasized that these are
total numbers for the remediation, not per worker.
TRANSPORTATION DEATHS AND INJURIES
Based on 1988 records from the Michigan Department of Transportation Traffic
Engineer, the death rate due to accidents on state trunk highways in Macomb County
was 1.6 per 100 million vehicle miles and the total accident rate was 538 per 100
million vehicle miles. Several alternatives involve the transportation of significant
amounts of materials across state roads. The approach used in this FS was to
estimate the number of truckloads and the mileage covered with each load to
calculate the total mileage traveled as part of the remediation. Death and injury
estimates were based on this mileage. For example, Alternative 3A estimated
1.73 million miles, based on 35,000 truck loads (50 tons each) with a 50-mile round
trip, would be traveled while bringing soil to the site for grading, earthwork, and cap
construction.
1.73 million miles x (1.6 deaths/100 million miles) = 2.8 x 10'2 deaths
A summary of the expected transportation related deaths and injuries is presented on
Table E-2.
GLT984/004.51
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Table E-l
ESTIMATED CONSTRUCTION RELATED
DEATHS AND INJURIES
Alternative
1.
2.
3A.
3B.
4A.
6A.
No Action
Institutional Controls
Containment — Covers
Containment — Covers with
Vertical Barriers
Groundwater Extraction and
Treatment with Source
Containment
Source Removal
Deaths
-
4.5 x 10-4
1.0 x 10'2
1.3 x 10'2
1.3 x 1(T2
2.7 x 10'1
Injuries
-
0.019
0.44
0.54
0.56
12.00
-Death and injury rates for these alternatives are orders of magnitudes lower
because of the relatively minor amounts of construction work required.
GLT984/003.51
-------
Table E-2
ESTIMATED VEHICULAR RELATED
DEATHS AND ACCIDENTS
Alternative
1. No Action
2. Institutional Controls
3A. Containment — Covers
3B. Containment — Covers with
Vertical Barriers
4A, Groundwater Extraction and
Treatment with Source
Containment
6A. Source Removal
Deaths
-
-
2.8 x 1(T2
2.9 x 10-2
2.9 x 10-2
2.9 x lO'1
Accidents
-
-
9.3
9.7
9.7
9.7
-Death and accident rates for these alternatives are orders of
magnitudes lower because of the relatively minor amounts
of construction work required.
GLT984/005.51
-------
Appendix F
DETAILED COST ANALYSIS
GLT984/040.51-6
-------
AGENCY REVIEW DRAFT
Appendix F
DETAILED COST ANALYSIS
INTRODUCTION
This appendix presents the assumptions used to develop the scope and to estimate
the capital and operation and maintenance (O&M) costs of each alternative that
underwent detailed evaluation. This information supplements the descriptions and
costs presented in Chapter 5.
Cost estimates were prepared to aid in the evaluation of alternatives using
information currently available. Final project costs will depend on actual labor and
material costs, site conditions, productivity, competitive market conditions, final
project scope, final project schedule, the firm selected for final engineering design,
and other variable factors. As a result, final project costs will vary from the estimates.
Because of these factors, funding needs must be carefully reviewed before specific
financial decisions are made or final remedial action budgets are established.
The cost estimates are order-of-magnitude estimates with an intended accuracy range
of +50 percent to -30 percent. This range applies only to the defined alternatives
and does not account for major changes in the scope of the alternatives. The
remedial action scope and cost estimate will be refined during final design. Unit
prices were developed in accordance with the Superfund Cost Estimating Guide
(CH2M HILL 1987) and are based on construction cost data (Means 1990),
engineers' cost estimates for similar work, quotes from vendors and contractors, and
engineering judgment.
F-l
-------
AGENCY REVIEW DRAFT
OVERVIEW OF COST ESTIMATES
The cost estimates were intended to provide a measure of total resource costs. They
include total capital costs and annual O&M costs. The total alternative cost is
represented as the total present worth.
TOTAL CAPITAL COSTS
Capital costs are direct and indirect costs required to initiate and install a remedial
action. They include only expenditures incurred to design and implement a remedial
action (e.g., installation of a cap) and exclude costs required to maintain the action
throughout its lifetime.
Direct costs are expenditures necessary for installation of remedial actions, such as
costs for construction, site development, and buildings and services. Construction
costs include costs necessary to construct or implement the action, such as those for
materials, labor, and equipment. Expenditures for items such as site preparation for
remedial action equipment, installation of monitoring wells, or excavation of
contaminated materials are also construction costs.
Indirect capital costs are not incurred as part of actual remedial actions but are
ancillary to direct or construction costs. Indirect capital costs consist of engineering,
supervision during construction, licensing, permitting, or other services necessary to
carry out a remedial action, and bid and scope contingencies that attempt to reduce
the possibility of a cost overrun. Bid contingencies account for unexpected costs
associated with constructing a given project, such as general economic conditions at
the time of bidding, adverse weather conditions, and strikes by material suppliers.
Scope contingencies cover changes that invariably occur during final design and
implementation. Scope contingencies include provisions for such items as inherent
uncertainties in defining waste volumes and regulatory or policy changes that may
affect FS assumptions. U.S. EPA and State of Michigan administrative costs are also
indirect costs, but they are not included in this cost estimate.
F-2
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AGENCY REVIEW DRAFT
ANNUAL OPERATING COSTS
Annual operating costs for a remedial action include the costs incurred each year
following construction or installation of a project. For the purposes of economic
analysis, annual O&M costs are assumed to be paid at the end of the year in which
they occur.
ECONOMIC ANALYSIS
The present worth analysis provides a method for comparing costs that occur over
different time periods by discounting future expenditures to the present year. Present
worth calculations were based on a 30-year period using 3, 5, and 10 percent discount
rates. O&M costs may be incurred beyond the 30-year planning period, but 30 years
was used for comparison purposes. Future costs were not escalated to account for
inflation.
COST ESTIMATE ASSUMPTIONS
To develop the FS cost estimates, numerous assumptions were made involving the
physical site characteristics and nature and extent of contamination. The major
assumptions are discussed briefly herein.
HEALTH AND SAFETY
The level of protection for workers was assumed to range from modified Level D
(i.e., standard work conditions) to Level B. Net productivity multipliers (NPM) were
used to estimate remedial productivity reductions that occur due to required special
health and safety precautions. The NPRs corresponding to each level of protection
and category of work are:
F-3
-------
AGENCY REVIEW DRAFT
• Heavy Equipment Operation (with air bottle on equipment, if needed)
Level D = 1.1
Level C = Level B = 1.7
• Manually Intensive Labor (e.g. drilling, clearing, etc.)
Level D = 1.3
Level C = 1.7
Level B = 2.4
Costs for a contractor's health and safety program were assumed to include:
• Pre- and post-construction medical examinations, and annual medical
examinations if needed
• 40-hour health and safety training course
• 8-hour onsite health and safety meeting
• Annual 8-hour refresher health and safety training
• Weekly tracking of site activities and review of site safety logs by
certified industrial hygienist
WATER SERVICE LINE CONNECTIONS
Costs for connecting water service lines were based on costs reported by Shelby
County DPW for similar work already done in the area. The water main is already
installed, so connections would involve trenching from the main to each residence.
Based on 1988 information received from MDNR, there are 54 residences in the
F-4
-------
AGENCY REVIEW DRAFT
neighborhood east of the site and 6 commercial buildings that are not currently
connected to public water.
GROUNDWATER MONITORING
Although groundwater monitoring requirements and needs are likely to change in the
future (especially for those alternatives that control contaminant loading to
groundwater), it was assumed that a groundwater monitoring program would be
implemented for the 30-year planning period. It was also assumed that 40 samples
would be analyzed for TCL organic compounds on a semiannual basis. It was
assumed that a dedicated groundwater monitoring system would be used because of
the cost savings (i.e., less manpower to collect samples and no field blanks required)
provided over a continued period of sampling.
AIR MONITORING DURING CONSTRUCTION
Onsite air monitoring will likely be required for activities that disturb the existing
Phase I Landfill cover or bring buried waste to the surface because of the potential
release of VOC and paniculate contaminants to the air. Continual air sampling for
particulate was assumed to be performed during any site regrading activities or
excavation. The air monitoring was assumed to consist of three samples: one upwind
and two downwind.
LANDFILL COVER
After clearing site vegetation, the site will be regraded to better conform to final
contours. It was assumed that cut and fill activities would not be allowed on the
Phase I Landfill. The initial lift was assumed to be placed under Level D conditions,
and the rest of the cover was assumed to be constructed under normal construction
conditions.
F-5
-------
AGENCY REVIEW DRAFT
It was assumed that all soil required would be supplied from an offsite source. Price
quotes from local aggregate suppliers were used to develop costs for soil delivered to
the site. Haul distances range from 20 to 30 miles one way, and the maximum
allowable truckload weight is 50 tons. Local roads could be damaged by increased
heavy traffic; however, damage and associated costs to repair could not be quantified
and were not included in the cost estimates.
Grading fill quantities were estimated using quantity takeoffs from the conceptual site
grading plan. Soil quantities for the cover were estimated using the assumed cover
cross section multiplied by the site area of approximately 80 acres. Maximum frost
penetration was assumed to be 3.5 feet, and it was assumed that prairie grass would
be used for site vegetation. Use of erosion control mats was assumed for slopes
greater than 3H:1V and for drainage channels. It was assumed that a rip rap blanket
would be constructed at the toe of the Phase III Landfill.
It was assumed that passive gas vents could be used to control methane generated at
the site. Each vent was assumed to have an effective radius of influence of 150 feet.
Vents would be constructed of 3-inch PVC, and they would have an average depth of
20 feet. Gas vent installation was assumed to be Level C work.
Maintenance costs for the soil cover were based on the following assumptions:
• Biannual inspections by an engineer
• Annual prairie grass maintenance would be equal to 10 percent of
initial seeding costs
• Annual repair costs to correct cracks, fill in erosion, or reestablish
grades would be equal to 1 percent of the capital cost of the cover
F-6
-------
AGENCY REVIEW DRAFT
LEACHATE COLLECTION
It was assumed that pipe and media drain could be used on the western slope of the
Phase III Landfill to collect leachate. The system was sized to collect up to 10 gpm;
however, it was assumed that steady state leachate collection would be 1 gpm. It was
assumed that leachate would be collected in a sump, pumped to a storage tank on the
railroad grade, and periodically hauled to an industrial treatment facility using a
6,000-gallon vacuum tanker truck.
SLURRY WALL
The cost per square foot of the slurry wall assumes that 25 percent of the wall will be
constructed under Level C conditions. The backfill will be mixed at a central mixing
station (remote from the trench) for 40 percent of the wall. Remote mixing was
assumed to limit the amount of tree clearing and grubbing south of the site to a
20-foot wide path along the wall alignment. If a 50-foot wide path will be allowed,
costs would be reduced by approximately $.40/ft2.
It was assumed that contaminated soil or waste will not be excavated during
construction of the slurry wall. Thus, there is no provision for disposal of hazardous
materials. It was assumed that trench spoils would be mixed with bentonite and
backfilled, and that the backfill mixture would require 10 percent by weight of
bentonite to meet permeability requirements. Also, it was assumed that a special
colloid (such as attapulgite) would be required in areas where the wall will be
constructed through groundwater contaminated with VOCs.
Predesign costs for the slurry wall were assumed to consist of:
• A geotechnical exploration of 72 borings that are 35 feet deep on
average (one boring per 100 feet of wall alignment)
• Compatibility testing of 10 specimens
F-7
-------
AGENCY REVIEW DRAFT
GRADIENT CONTROL AND GROUNDWATER EXTRACTION
It was assumed that 6-inch diameter stainless steel wells equipped with
1/2-horsepower submersible pumps would be used for gradient control inside the
slurry wall or groundwater extraction outside the slurry wall. A pitless adapter and
throttling valve will also be installed at each well. The required well spacing was
estimated to be 150 feet on center. It was assumed that groundwater would be
pumped to an onsite water treatment plant through a flexible plastic header buried
4 feet below ground surface.
It was assumed that operating the gradient control system would require one day per
week labor. For the groundwater extraction system, an extra 1/2 day per week was
assumed. Power costs were based on the assumption that the pumps will run
50 percent of the time. Maintenance costs were assumed to be 5 percent of capital
cost per year.
WATER TREATMENT
Water treatment components were selected in Appendix D. Influent concentrations
were estimated based on RI sampling results from monitoring wells that are screened
in the areas of known groundwater contamination. The treatment system
components were sized based on the following estimated influent rates:
• Alternative 3B—30 gpm during startup and 10 gpm steady state
• Alternatives 4A and 6A—60 gpm during startup and 40 gpm steady
state
Operational costs for the treatment plant consist of labor costs for an operator and
supervisor, analytical costs, equipment repair and maintenance costs, chemical costs,
carbon regeneration costs, and costs for offsite disposal of residuals. The O&M costs
F-8
-------
AGENCY REVIEW DRAFT
assumed that water would be treated to standards that meet an NPDES permit for
discharge to the Clinton River.
EXCAVATION AND INCINERATION
It was assumed that 800,000 cubic yards would be excavated and incinerated onsite to
remove oil- and solvent-saturated soils and landfill contents. This volume was
estimated using test pit and boring information from the RI. Costs for excavation
include purchase of earthmoving equipment, material processing equipment, a
centralized storage and processing building, and labor and supervision.
Because soil and landfill contents contain some PCB contamination, an afterburner
temperature of 2,200°F was assumed. The following average parameters were
assumed for the contaminated soil:
• Moisture content = 19 percent
Btu = 1,800
• Ash content = 60 percent
Costs for the incinerator include allowances for a test burn, labor for 24-hour
operation and supervision, 20 percent downtime for repair and maintenance,
treatment of scrubber blowdown, daily analytical testing of waste, ash, and water.
COST ESTIMATE RESULTS
Detailed cost estimates are provided in Attachment F-l. A summary of costs is given
in Table F-l.
F-9
-------
AGENCY REVIEW DRAFT
SENSITIVITY ANALYSIS
The cost estimates given in Table F-l are dependent on the assumptions previously
discussed. A sensitivity analysis was done to examine how much the estimated cost
would change if key assumptions were changed.
DISCOUNT RATE
The present worth of O&M costs is a function of the assumed discount rate. The
Office of Management and Budget has directed that federal projects use discount
rates of 3, 5, and 10 percent. The present worth of each alternative using these rates
was done in the detailed cost estimates in Attachment F-l.
TYPE OF LANDFILL COVER
Alternatives 3A through 6A assume that a soil-clay cap will be constructed at the
landfill. However, a different type or combination of types of landfill cover may be
selected by EPA. Costs of both the soil cover option and soil-drain-FML cover
option were estimated assuming that they would be constructed over the entire
landfill area (i.e., 82 acres). This will provide a full range of costs associated with
covering the site. The resulting changes in costs of the alternatives is given in
Table F-2.
EXCAVATED VOLUMES
The cost of excavating and incinerating contaminated soils and landfill contents
depends to a large degree on the quantity of material. For that reason, the material
quantities were varied to provide a range in costs. The range consists of:
• Low estimate = "codisposal area" = 500,000 cubic yards
Total Present Worth (at 5 percent discount rate) = $350,000,000
F-10
-------
AGENCY REVIEW DRAFT
High estimate = Phase I Landfill and Oil Seepage Area
= 1,700,000 cubic yards
Total Present Worth (at 5 percent discount rate) = $960,000,000
GLT984/006.51
F-ll
-------
Attachment F-l
DETAILED COST ESTIMATE TABLES
GLT984/040.51-7
-------
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30-May-90
Page 1 of 2
ALTERNATIVE 2 - INSTITUTIONAL CONTROLS
Unit
Description Quantity Unit Price
CAPITAL COSTS
INSTITUTIONAL CONTROLS
Residential Water Line Hookup 60 EACH $1,500.00
Dedicated Monitoring System 40 WELLS $1,150.00
ALLOWANCES
Mobe/Demobe(5%)
Field Detail AllowanceO 0%)
CONSTRUCTION SUBTOTAL
CONTINGENCIES
Bid(15%)
Scope(25%)
CONSTRUCTION TOTAL
OTHER
Administrative (5%)
Services During Construction (8%)
TOTAL IMPLEMENTATION COST
ENGINEERING
WP/CMP/HSP/O&M/QAPP 5 EACH $10,000.00
Design/Plans and Specifications 3 SHEETS $18,000.00
Cost
$90,000
$46,000
$6,800
$13,600
$23,400
$39,000
$10,900
$17,440
$50,000
$54,000
Subtotal
$136,000
$20,000
$156,000
$62,000
$218,000
$28,000
$246,000
$104,000
TOTAL CAPITAL COST
$350,000
-------
30-May-90
Page 2 of 2
ALTERNATIVE 2 - INSTITUTIONAL CONTROLS
Unit
Description Quantity Unit Price
OPERATION AND MAINTENANCE COSTS
SITE FENCE
Inspection - Technician 48 HR $40.00
Repair 1 LS $1,000.00
GROUNDWATER MONITORING
Sampling 2 ROUNDS $81,000.00
Maintenance 1 LS $4,600.00
ANNUAL O&M SUBTOTAL
SCOPE CONTINGENCY (25%)
ANNUAL O&M COST
Cost Subtotal
$1,920
$1,000
$3,000
$162,000
$4,600
$167,000
$170,000
$43,000
$213,000
Description
TOTAL CAPITAL COST
ANNUAL OPERATION AND MAINTENANCE COST
TOTAL PRESENT WORTH COST OF ALTERNATIVE
Present Worth of Costs over 30 Years (a)
3%
$350,000
$4,175,000
$4,525,000
5%
$350,000
$3,274,000
$3,624,000
10%
$350,000
$2,008,000
$2,358,000
(a) Present worth is calculated using 3, 5, and 10 percent discount rates to compare relative escalation
of costs. General price inflation is not accounted for.
-------
30-May-90
Page 1 of 2
ALTERNATIVE 3A - SOIL-CLAY COVER
Description
CAPITAL COSTS
HEALTH AND SAFETY
INSTITUTIONAL CONTROLS
Residential Water Line Hookup
Dedicated Monitoring System
SITE PREPARATION
Remove and Reset Fence
Remove Fence
Demolish and Dispose of Buildings
Brush and Small Tree Clearing
SOIL-CLAY COVER
Grading Fill
Clay Barrier
Common Fill Cover
Prepare Surface and Seed
Drain Channels
Passive Gas Vents
PHASE III LANDFILL WEST SLOPE
Slope Protection
Leachate Collection and Storage
ALLOWANCES
Mobe/Demobe (5%)
Field Detail Allowance (10%)
CONSTRUCTION SUBTOTAL
CONTINGENCIES
Bid(15%)
Scope(25%)
CONSTRUCTION TOTAL
OTHER
Administrative (5%)
Services During Construction (8%)
TOTAL IMPLEMENTATION COST
ENGINEERING
WP/CMP/HSP/O&M/QAPP
Predesign Investigation
Design/Plans and Specifications
TOTAL CAPITAL COST
Quantity
1
60
40
1,700
2,100
1
61
302,000
382,000
446,000
79
10,700
44
139,000
1
5
1
32
Unit
LS
EACH
WELLS
LF
LF
LS
ACRES
CY
CY
CY
ACRES
LF
EA
SF
LS
EACH
LS
SHEETS
Unit
Price
$168,000.00
$1,500.00
$1,150.00
$8.40
$1.70
$7,750.00
$2,015.00
$8.20
$13.30
$7.50
$1,660.00
$6.00
$1,800.00
$1.50
$107,000.00
$30,000.00
$50,000.00
$18,000.00
Cost
$168,000
$90,000
$46,000
$14,280
$3,570
$7,750
$122,920
$2,476,400
$5,080,600
$3,345,000
$131,140
$64,200
$79,200
$208,500
$107,000
$597,230
$1,194,460
$2,060,400
$3,434,000
$961 ,500
$1 ,538,400
$150,000
$50,000
$576,000
Subtotal
$168,000
$136,000
$149,000
$11,177,000
$316,000
$1,792,000
$13,736,000
$5,494,000
$19,230,000
$2,500,000
$21,730,000
$776,000
$22,456,000
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30-May-90
Page 2 of 2
ALTERNATIVE 3A - SOIL-CLAY COVER
Description Quantity
OPERATION AND MAINTENANCE COSTS
SITE FENCE
Inspection - Technician 48
Repair 1
GROUNDWATER MONITORING
Sampling 2
Maintenance 1
LEACHATE TREATMENT
Offsite Treatment 520,000
Maintenance 1
SOIL-CLAY COVER
Inspection - Engineer 32
Prairie Maintenance 1
Cover Repair 1
ANNUAL O&M SUBTOTAL
SCOPE CONTINGENCY (25%)
ANN UAL O&M COST
Unit
HR
LS
ROUNDS
LS
GALLON
LS
HR
LS
LS
Unit
Price
$40.00
$1 ,000.00
$81 ,000.00
$4,600.00
$0.13
$2,100.00
$65.00
$9,100.00
$112,000.00
Cost
$1 ,920
$1,000
$162,000
$4,600
$67,600
$2,100
$2,080
$9,100
$112,000
Subtotal
$3,000
$167,000
$70,000
$123,000
$362,000
$91 ,000
$453,000
Description
TOTAL CAPITAL COST
ANNUAL OPERATION AND MAINTENANCE COST
TOTAL PRESENT WORTH COST OF ALTERNATIVE
Present Worth of Costs over 30 Years (a)
3%
$22,456,000
$8,879,000
$31,335,000
5%
$22,456,000
$6,964,000
$29,420,000
10%
$22,456,000
$4,270,000
$26,726,000
(a) Present worth is calculated using 3,5, and 10 percent discount rates to compare relative escalation
of costs. General price inflation is not accounted for.
-------
30-May-90
Page 1 of 3
ALTERNATIVE 3B - SOIL-CLAY COVER AND VERTICAL BARRIER
Description
CAPITAL COSTS
HEALTH AND SAFETY
INSTITUTIONAL CONTROLS
Residential Water Line Hookup
Dedicated Monitoring System
SITE PREPARATION
Remove and Reset Fence
Remove Fence
Demolish and Dispose of Buildings
Brush and Small Tree Clearing
LANDFILL COVER
Grading Fill
Clay Barrier
Common Fill Cover
Prepare Surface and Seed
Drain Channels
Passive Gas Vents
PHASE III LANDFILL WEST SLOPE
Slope Protection
Leachate Collection and Storage
VERTICAL BARRIER
Prepare Alignment
Slurry Wall
Gradient Control Wells
Pumps and Controls
Header
WATER TREATMENT PLANT
Treatment Building and Utilities
Equalization Tank
Oil/Water Separator and Storage
Precipitator/Clarifier
Granular Filter
Air Stripper
Chemical Feed Unit
Granular Activated Carbon Unit
Sludge Thickener
Sludge Dewatering Unit
Piping
Instrumentation and Control
WATER DISCHARGE
Piping
Concrete Apron
Quantity
1
60
40
1,700
2,100
1
61
302,000
382,000
446,000
79
10,700
44
139,000
1
1
242,300
48
48
7,600
1
1
1
1
1
1
1
2
1
1
1
1
960
1
Unit
LS
EACH
WELLS
LF
LF
LS
ACRES
CY
CY
CY
ACRES
LF
EA
SF
LS
LS
SF
WELL
EACH
LF
LS
EACH
LS
EACH
EACH
EACH
EACH
EACH
EACH
EACH
LS
LS
LF
EACH
Unit
Price
$236,000.00
$1 ,500.00
$1,150.00
$8.40
$1.70
$7,750.00
$2,015.00
$8.20
$13.30
$7.50
$1,660.00
$6.00
$1 ,800.00
$1.50
$107,000.00
$42,500.00
$6.00
$4,600.00
$1 ,600.00
$5.40
$82,000.00
$10,000.00
$35,000.00
$60,000.00
$25,000.00
$35,000.00
$15,000.00
$25,000.00
$7,500.00
$35,000.00
$68,000.00
$55,000.00
$10.00
$12,000.00
Cost
$236,000
$90,000
$46,000
$14,280
$3,570
$7,750
$122,920
$2,476,400
$5,080,600
$3,345,000
$131,140
$64,200
$79,200
$208,500
$107,000
$42,500
$1 ,453,800
$220,800
$76,800
$41,040
$82,000
$10,000
$35,000
$60,000
$25,000
$35,000
$15,000
$50,000
$7,500
$35,000
$68,000
$55,000
$9,600
$12,000
Subtotal
$236,000
$136,000
$149,000
$11,177,000
$316,000
$1,835,000
$478,000
$22,000
-------
30-May-90
Page 2 of 3
ALTERNATIVE 3B - SOIL-CLAY COVER AND VERTICAL BARRIER
Unit
Description Quantity Unit Price
ALLOWANCES
Mobe/Demobe(50/o)
Field Detail Allowance(12%)
CONSTRUCTION SUBTOTAL
CONTINGENCIES
Bid(15%)
Scope{25%)
CONSTRUCTION TOTAL
OTHER
Administrative (5%)
Services During Construction (8%)
TOTAL IMPLEMENTATION COST
ENGINEERING
WP/CMP/HSP/O&M/QAPP 5 EACH $30,000.00
Predesign Investigation 1 LS $280,000.00
Design/Plans and Specifications 68 SHEETS $18,000.00
TOTAL CAPITAL COST
Cost
$717,450
$1,721,880
$2,517,900
$4,196,500
$1,175,000
$1 ,880,000
$150,000
$280,000
$1,224,000
Subtotal
$2,439,000
$16,786,000
$6,714,000
$23,500,000
$3,055,000
$26,555,000
$1,654,000
$28,209,000
OPERATION AND MAINTENANCE COSTS
SITE FENCE
Inspection - Technician
Repair
GROUNDWATER MONITORING
Sampling
Maintenance
SOIL-CLAY COVER
Inspection - Engineer
Prairie Maintenance
Cover Repair
GRADIENT CONTROL WELLS
Operator - Technician
Power
Equipment Maintenance
48
1
2
1
HR $40.00
LS $1 ,000.00
ROUNDS $81,000.00
LS $4,600.00
$1,920
$1,000
$162,000
$4,600
$3,000
$167,000
32
1
1
416
14,000
1
HR
LS
LS
HR
KW-HR
LS
$65.00
$9,100.00
$112,000.00
$40.00
$0.10
$16,900.00
$2,080
$9,100
$112,000
$16,640
$1 ,400
$16,900
$123,000
$35,000
-------
30-May-90
Page 3 of 3
ALTERNATIVE 3B - SOIL-CLAY COVER AND VERTICAL BARRIER
Description
WATER TREATMENT
Operator - Technician
Supervisor - Engineer
Power
Chemicals
Carbon Regeneration
Equipment Maintenance
Effluent Testing
Sludge Disposal
Oil Disposal
ANNUAL O&M SUBTOTAL
SCOPE CONTINGENCY (25%)
ANNUAL O&M COST
Quantity
1,040
192
16,000
1
15,000
1
12
25
8,400
Unit
HR
HR
KW-HR
LS
POUNDS
LS
EACH
CY
GALLON
Unit
Price
$40.00
$65.00
$0.10
$1,500.00
$2.00
$39,600.00
$1 ,500.00
$200.00
$3.00
Cost
$41 ,600
$12,480
$1 ,600
$1,500
$30,000
$39,600
$18,000
$5,000
$25,200
Subtotal
$175,000
$503,000
$126,000
$629,000
Description
TOTAL CAPITAL COST
ANNUAL OPERATION AND MAINTENANCE COST
TOTAL PRESENT WORTH COST OF ALTERNATIVE
Present Worth of Costs over 30 Years (a)
3%
$28,209,000
$12,328,000
$40,537,000
5%
$28,209,000
$9,669,000
$37,878,000
10%
$28,209,000
$5,930,000
$34,139,000
(a) Present worth is calculated using 3,5, and 10 percent discount rates to compare relative escalation
of costs. General price inflation is not accounted for.
-------
30-May-90
Page 1 of 3
ALTERNATIVE 4A - GROUNDWATER EXTRACTION AND TREATMENT
WITH SOURCE CONTAINMENT
Description
CAPITAL COSTS
HEALTH AND SAFETY
INSTITUTIONAL CONTROLS
Residential Water Line Hookup
Dedicated Monitoring System
SITE PREPARATION
Remove and Reset Fence
Remove Fence
Demolish and Dispose of Buildings
Brush and Small Tree Clearing
LANDFILL COVER
Grading Fill
Clay Barrier
Common Fill Cover
Prepare Surface and Seed
Drain Channels
Passive Gas Vents
PHASE III LANDFILL WEST SLOPE
Slope Protection
Leachate Collection and Storage
VERTICAL BARRIER
Prepare Alignment
Slurry Wall
Gradient Control Wells
Pumps and Controls
Header
GROUNDWATER EXTRACTION WELLS
Extraction Wells
Pumps and Controls
Header
WATER TREATMENT PLANT
Treatment Building and Utilities
Equalization Tank
Oil/Water Separator and Storage
Precipitator/Clarifier
Granular Filter
Air Stripper
Chemical Feed Unit
Granular Activated Carbon Unit
Sludge Thickener
Quantity
1
60
40
1,700
2,100
1
61
302,000
382,000
446,000
79
10,700
44
139,000
1
1
242,300
48
48
7,600
16
16
4,200
1
1
1
1
1
1
1
2
1
Unit
LS
EACH
WELLS
LF
LF
LS
ACRES
CY
CY
CY
ACRES
LF
EA
SF
LS
LS
SF
WELL
EACH
LF
WELL
EACH
LF
LS
EACH
LS
EACH
EACH
EACH
EACH
EACH
EACH
Unit
Price
$236,000.00
$1 ,500.00
$1,150.00
$8.40
$1.70
$7,750.00
$2,015.00
$8.20
$13.30
$7.50
$1,660.00
$6.00
$1 ,800.00
$1.50
$107,000.00
$42,500.00
$6.00
$4,600.00
$1 ,600.00
$5.40
$3,500.00
$1,600.00
$5.40
$107,000.00
$20,000.00
$63,000.00
$90,000.00
$35,000.00
$50,000.00
$15,000.00
$25,000.00
$7,500.00
Cost
$236,000
$90,000
$46,000
$14,280
$3,570
$7,750
$122,920
$2,476,400
$5,080,600
$3,345,000
$131,140
$64,200
$79,200
$208,500
$107,000
$42,500
$1,453,800
$220,800
$76,800
$41 ,040
$56,000
$25,600
$22,680
$107,000
$20,000
$63,000
$90,000
$35,000
$50,000
$15,000
$50,000
$7,500
Subtotal
$236,000
$136,000
$149,000
$11,177,000
$316,000
$1,835,000
$104,000
-------
30-May-90
Page 2 of 3
ALTERNATIVE 4A - GROUNDWATER EXTRACTION AND TREATMENT
WITH SOURCE CONTAINMENT
Unit
Description Quantity Unit Price
WATER TREATMENT PLANT (CONTINUED)
Sludge Dewatering Unit 1 EACH $35,000.00
Piping 1 LS $91,000.00
Instrumentation and Control 1 LS $73,000.00
WATER DISCHARGE
Piping 960 LF $10.00
Concrete Apron 1 EACH $12,000.00
ALLOWANCES
Mobe/Demobe(5%)
Field Detail Allowance(12%)
CONSTRUCTION SUBTOTAL
CONTINGENCIES
Bid(15%)
Scope(25%)
CONSTRUCTION TOTAL
OTHER
Administrative (5%)
Services During Construction (8%)
TOTAL IMPLEMENTATION COST
ENGINEERING
WP/CMP/HSP/O&M/QAPP 5 EACH $30,000.00
Predesign Investigation 1 LS $350,000.00
Design/Plans and Specifications 74 SHEETS $18,000.00
TOTAL CAPITAL COST
OPERATION AND MAINTENANCE COSTS
SITE FENCE
Inspection - Technician 48 HR $40.00
Repair 1 LS $1,000.00
GROUNDWATER MONITORING
Sampling 2 ROUNDS $81,000.00
Maintenance 1 LS $4,600.00
Cost
$35,000
$91,000
$73,000
$9,600
$12,000
$730,600
$1,753,440
$2,564,100
$4,273,500
$1,196,600
$1,914,560
$150,000
$350,000
$1 ,332,000
$1,920
$1,000
$162,000
$4,600
Subtotal
$637,000
$22,000
$2,484,000
$17,094,000
$6,838,000
$23,932,000
$3,111,000
$27,043,000
$1 ,832,000
$28,875,000
$3,000
$167,000
-------
30-May-90
Page 3 of 3
ALTERNATIVE 4A - GROUNDWATER EXTRACTION AND TREATMENT
WITH SOURCE CONTAINMENT
Description
SOIL-CLAY COVER
Inspection - Engineer
Prairie Maintenance
Cover Repair
Quantity
32
1
1
Unit
HR
LS
LS
Unit
Price
$65.00
$9,100.00
$112,000.00
Cost
$2,080
$9,100
$112,000
Subtotal
$123,000
GRADIENT CONTROL/EXTRACTION WELLS
Operator - Technician
Power
Equipment Maintenance
WATER TREATMENT
Operator - Technician
Supervisor - Engineer
Power
Chemicals
Carbon Regeneration
Equipment Maintenance
Effluent Testing
Sludge Disposal
Oil Disposal
ANNUAL O&M SUBTOTAL
SCOPE CONTINGENCY (25%)
ANNUAL O&M COST
624
40,000
1
1,040
192
32,000
1
30,000
1
12
85
8,400
HR
KW-HR
LS
HR
HR
KW-HR
LS
POUNDS
LS
EACH
CY
GALLON
$40.00
$0.10
$22,100.00
$40.00
$65.00
$0.10
$3,000.00
$2.00
$53,000.00
$1 ,500.00
$200.00
$3.00
$24,960
$4,000
$22,100
$41,600
$12,480
$3,200
$3,000
$60,000
$53,000
$18,000
$17,000
$25,200
$51,000
$233,000
$577,000
$144,000
$721 ,000
DESCRIPTION
TOTAL CAPITAL COST
ANNUAL OPERATION AND MAINTENANCE COST
TOTAL PRESENT WORTH COST OF ALTERNATIVE
Present Worth of Costs over 30 Years (a)
3%
$28,875,000
$14,132,000
$43,007,000
5%
$28,875,000
$1 1 ,083,000
$39,958,000
10%
$28,875,000
$6,797,000
$35,672,000
(a) Present worth is calculated using 3,5, and 10 percent discount rates to compare relative escalation
of costs. General price inflation is not accounted for.
-------
30-May-90
Page 1 of 2
ALTERNATIVE 6A - REMOVAL AND TREATMENT
Description
CAPITAL COSTS
HEALTH AND SAFETY
EXCAVATE AND PROCESS
Site Facilities
Excavating Equipment
Process Equipment
Health and Safety Equipment
Air Monitoring
Operation and Maintenance
INCINERATE
Mobile Incinerator
Facilities
Start Up
Permitting
Scrubber Slowdown Treatment Unit
Health and Safety Equipment
Operation and Maintenance
ONSITE RCRA-TYPE LANDFILL
Lining
Multilayer Cap
Haul and Compact Ash
ALLOWANCES
Mobe/Demobe (5%, see *)
Field Detail Allowance (12%,see *)
ALTERNATIVE 4A CONSTRUCTION SUBTOTAL
CONSTRUCTION SUBTOTAL
CONTINGENCIES
Bid (20%)
Scope (30%)
CONSTRUCTION TOTAL
Quantity
1
1
1
1
20
20
20
2
1
1
1
1
20
20
432,000
432,000
400,000
Unit
LS
LS
LS
LS
YEAR
YEAR
YEAR
EACH
LS
LS
LS
LS
YEAR
YEAR
SF
SF
CY
Unit
Price
$3,260,000.00
$410,000.00
$998,000.00
$629,000.00
$179,000.00
$60,000.00
$1,368,000.00
$4,500,000.00
$1,798,000.00
$536,000.00
$370,000.00
$3,180,000.00
$219,000.00
$9,888,000.00
$5.00
$3.40
$4.00
Cost
$3,260,000
$410,000
$998,000
$629,000
$3,580,000
$1,200,000
$27,360,000
$9,000,000
$1 ,798,000
$536,000
$370,000
$3,180,000
$4,380,000
$197,760,000
$2,160,000
$1 ,468,800
$1,600,000
$1,107,000
$2,658,000
$52,691,000
$79,037,000
Subtotal
$3,260,000
$34,177,000
$217,024,000
$5,229,000
$3,765,000
$17,094,000
$263,455,000
$131,728,000
$395,183,000
OTHER
Administrative (5%)
Services During Construction (8%)
TOTAL IMPLEMENTATION COST
$19,759,000
$31,615,000
$51,374,000
$446,557,000
-------
30-May-90
Page 2 of 2
ALTERNATIVE 6A - REMOVAL AND TREATMENT
Description Quantity Unit
Unit
Price
CAPITAL COSTS
ENGINEERING
Predesign Investigation (l°/o,see *)
Design (5%, see *)
Cost
Subtotal
$1,576,000
$7,882,000
$9,458,000
TOTAL CAPITAL COST
$456,015,000
* Line items with annual cost and health and safety line item not included in calculation.
OPERATION AND MAINTENANCE COSTS
ALT. 4A ANNUAL O&M SUBTOTAL
SCOPE CONTINGENCY (25%)
$577,000
$144,000
ANNUAL O&M COST
$721,000
Description
TOTAL CAPITAL COST
ANNUAL OPERATION AND MAINTENANCE COST
TOTAL PRESENT WORTH COST OF ALTERNATIVE
Present Worth of Costs over 30 Years (a)
3%
$456,015,000
$14,132,000
$470,147,000
5%
$456,015,000
$1 1 ,083,000
$467,098,000
10%
$456,015,000
$6,797,000
$462,812,000
(a) Present worth is calculated using 3, 5, and 10 percent discount rates to compare relative escalation
of costs. General price inflation is not accounted for.
------- |