United States
Environmental Protection
Office of
Emergency and
Remedial Response
EP/VROD/R05-84'003
February 1984
5EFA
Superfund
Record of Decision:
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"
G.
TECHNICAL REPORT DATA
(Please ,ead Instructions on the ,evene befo,e completing)
,. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R05-84/003
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION: 02/2Q/R4
Berlin & Ferro Site, MI 6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT ~O.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Reoort
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES
16. A8STRACT
The Berlin & Ferro Liquid Incineration site occupies 40 acres approximately
3.5 miles south of the City of Swartz Creek, Michigan. A liquid waste incinerator
was operated at the site from 1971 until the late 1970's, during which time liquid
wastes were incinerated, stored in open lagoons and underground tanks and poured into
agricultural drains. Solid wastes, contained primarily in crushed drums, were buri
in various on-site locations.
The selected alternative to mitigate the uncontrolled hazardous waste problem
at the Berlin & Ferro site involves four areas. They are: excavation of the existing
drum landfill and dis~osal of sludge, crushed drums, liquid wastes and visibly con-
taminated soil at a RCRA facility; solids to be landfilled and liquids to be inciner-
ated. Also, excavation of the paint sludge trench and disposal of sludges and
visibly contaminated soil at a RCRA facility. Also, excavation of the agricultural
drains leaving the site and miscellaneous areas of visible contamination, and dis-
posal of wastes, sludge and visibly contaminated soil at a RCRA facility. Supplementa
sampling will be performed to determine if waste has migrated below visibly contam-
inated areas.
(Key Words are on attached page.)
17. KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Berlin & Ferro Site, MI
Contaminated media: sw, soil, sludge/drum
wastes, air
Key contaminants: PCBs, solvents, paint
sludges, VOCs, C-46, C-58, C-56, C-66,
metal hydroxides
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (ThiS Repo,t) 21. NO. OF PAGES
None .j::,
20. SECURITY CLASS (This page) 22. PRICE
None
EPA form 2220-1 (R.... "-77)
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INSTRUCTIONS
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REPORT NUMBER
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2.
3.
LEAVE BLANK
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Reserved for use by ea,'h report recipient,
4.
TITLE AND SUBTITLE
Title should indicate dearly and briefly the subject ,'overa!!" of the report. and be disl,lay,'d promin,'nlly. S,', suhlilk. if uso,',I, in smali,'r
type or otherwise subordinate it to main litle. When a report is prepared in mor,' than un,' vulum,'. "'",'al Ih,' primary ,ill,'. .l\ld v,'hun,'
number and include subtitle for the spec:ific title.
REPORT DATE
Each report shall carry 8 dale indic:atinl at least month and year. Indkate the hasis 011 whidl il w..' ",'Ie,'t,'d (q:.. Jilt.. j,rin"c'. c/Qtc' or
IIPP'OI1I1I, dDte of preptlflltion, rtc.).
.5.
8.
PERFORMING ORGANIZATION CODE
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7.
AUTHORISI
Give name(s) in ".:>nventional order (John R. DoC', J. Rob,'" Doc', <'Ie). List author's affiliallun if;1 ,Iiff,'r, frum III,' perfmminj! '''j!ani-
Zltion,
8.
PERFORMING ORGANIZATION REPORT NUMBER
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9.
PERFORMING ORGANIZATION NAME AND ADDRESS
Give name, street, c:ity, state, and ZIP code. List no more than two levels of an orj!anizalional hireardlY.
10. PROGRAM ELEMENT NUMBER
Use the program element number under which the report was prepared, Subordinate numb<'r' III..)" be illdu,"''' IIlp..r"lIlh,'"",
11. CONTRACT/GRANT NUMBER
Insert conUact or grant number under which report was prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP code.
13. TYPE OF REPORT AND PERtOD COVERED
Indicate interim final. etr., and if applicable, dates covered,
14. SPONSORING AG~NCY CODE
Insert appropriate code.
16. SUPPLEMENTARY NOTES
Enter information not included elsewhere but useful, such as:
To be published in, Supersedes, Supplements. etc.
Prepared in Io.'oopcr..tion with. 'I ral"lalioli of. p''''',,'ulnl al nll,'nt'IU,' ul.
18. ABSTRACT
Include a brief (200 words or less) factual summary of the mosl sillnilkanl infurmallnn ,'untain,'" III II". "'1'''''' II Ih,' rfPHlI ,""I'"'" a
silnificant bibliography or literature survey, mention it here.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS - Select from the Thesaurus of Engineerir.1I and Seielltilk Tefl'" the pruper aUlh"rll"<.I I,'''''' Ihal Idenllfy Ihe nl..jm
concept of the research and are sufficiently specific and precise to be u>cd a' II1<.1ex cntric~ fur e.lal"I',nj!.
(b) IDENTIFIERS AND OPEN-ENDED TERMS - Use identifiers for project nam", code namc,. "4u1pmcnl <.I""j!nalors, ,'1.... U'" "I>en.
ended terms written in descriptor form for those subjects for which no descriptor exists.
(c) COSATI FIELD GROUP -!'ield and grOI!P assilnments are to be taken from the 1965 ('05"1'1 Suhj,'''' ('a"'I'my List. Sinc~' the nla.
jority of documents are multidisciplinary in nature, the PrimOiry held/Group assignmcnth) will be ,p,:dfi,' <.Ii'....plin,', area nf hUlllan
endeavor. or type of physical object. The applicationls) will be crosHcferenced with ",,'un<.lary I iddl<;ruup a"'I'"IIICII" Ihat ....ill filII"..
the primary postinlls).
18. DISTRIBUTION STATEMENT
Denote releasabilit)' to the public or limitation for reasons other than sccurity for example "Kelca'" (;IIhlllll"'I." ('il" an)' a."il"h.lil)' III
the public, with address and pllce, .
19.8120. SECURITY CLASSIFICATIDN
DO NOT submit classified reports to the National Tel.:hnicallnformation scrvil.:e.
21. NUMBER OF PAGES
Inserlthe total number of pages, including this one and unnumbered page" but exdude di,tributiun li,I, il any.
22. PRICE
Insert the price set by the National fechnicallnformation Scrvil.:e ur the Go.ernment Printing OlTicc, if knuwn.
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16.
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Abstract (Continued)
Key Words:
Excavation, RCRA Location Criteria, Off-Site Disposal,
Supplemental ROD, Hydrogeologic Factors, Organics,
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ROD ISSUES ABSTRACT
Site:
Berlin & Farro Liquid
Incineration, Michigan
Region:
v
AA, OSWER
Briefing Date:
February 15, 1984
SITE DESCRIPTION
The Berlin & Farro Liquid Incineration site occupies 40 acres
approximately 3.5 miles south of the City of Swartz Creek, Michigan. A
liquid waste incinerator was operated at the site from 1971 until the
late 1970's, during which time liquid wastes were incinerated, stored
in open lagoons and underground tanks and poured into agricultural
drains. Solid wastes, contained primarily in crushed drums, were
buried in various on-site locations. Significant site features pre-
sently include drum landfills, "north" and "south" lagoons, metal
hydroxide settling ponds, a 0.2-acre paint sludge trench, subsurface
agricultural drains, the foundations of the liquid incinerator tnat has
been removed, an area of contaminated soil at the former site of
several underground tanks, and numerous isolated pockets of liquids,
paint sludges and solvents.
SELECTED ALTERNATIVE
The selected alternative to mitigate the uncontrolled hazardous
waste problem at the Berlin & Farro site involves four areas. They
are: excavation of the existing drum landfill and disposal of sludge,
crushed drums, liquid wastes and visibly contaminated soil at a RCRA
facility; solids to be landfilled and liquids to be incinerated. Also,
excavation of the paint sludge trench and disposal of sludges and
visibly contaminated soil at a RCRA facility. Also, excavation of the
agricultural drains leaving the site and miscellaneous areas of visible
contamination, and disposal of wastes, sludge and visibly contaminated
soil at a RCRA facility. Supplemental sampling will be performed to
determine if waste has migrated below visibly contaminated areas.
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Berlin & Farro Liquid
Incineration, Michigan
February 15, 1984
Continued
ISSUES AND RESOLUTIONS
1.
Removal of additional contaminated soil
under the wastes was not approved since
no data on the extent of contamination
existed. If significant soil contamination
is found after these wastes are removed a
supplemental ROD will be prepared.
2.
Hydrogeologic concerns were considered in
the selection of a cost-effective alter-
native. These concerns may be beyond
the RCRA location criteria used at the
time this ROD was signed for siting land-
fills. Ground water was near the surface and
in the wastes. Subsurface soils had highly
permeable lenses providing a migration path-
way. This condition was considered in the
alternatives evaluation and in the selection
of off-site disposal since the cost differ-
ence between on- and off-site was
insignificant.
3 .
Several off-site options were evaluated for
disposal of liquid wastes. Incineration of
wastes containing ooth organics and PCBs
(less than 500 mg/l) was considered,
although not required by EPA regulations.
Incineration was less than 5% more expensive
than disposal at a RCRA approved facility.
The additional cost was determined to be
off-set by the improved long-term environ-
mental protection.
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"
KEY WORDS
. Excavation
. Supplemental ROD
. Contaminated Soil
. RCRA Location
Criteria
. Hydrogeologic
Factors
. Incineration
. Liquid Wastes
. Off-site Disposal
. Organics
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Record of Decision
Remedial Alternative Selection
Site: Berlin' Farro Liquid Incineration
SWartz Creek, Michigan
D:lc\.ments Reviewed.
I have reviewed the following docunents describing the analysis of. cost- .
effectiveness of remedial alternatives for the Berlin & Farro site:
- fbcused Feasibility Study, Berlin & Farro Hazardous Waste Site,
SWartz Creek, Michigan, CH2M-Hill, August 31, 1983
- SUmnary of Remedial Alternative Selection
- letter fran Ronald Skcx:g, Director, Michigan Department of Natural
Resources
- Berlin & Farro Hazardous Waste Site Air Monitoring and Sampling
SUpervision, April-June 1983, Swanson Environmental, Inc.
- Public ocmments and recommendations
- Responsiveness Summary
Description of selected Remedy
o Excavate the existing drum landfill, paint sludge trench, agricultural
drains, and miscellaneous contaminated areas to remove sludge,
liquid, crushed drums and visibly contaminated soiL
o Separate PCB solid wastes fran non-PCB solid wastes. Transport
wastes to off-site approved disposal facilities.
o Transport PCB liquid wastes, if any to approved off-site incinerator.
o R.Inp non-PCB liquid wastes fran the drum landfill (approximately
1.6 million gallons) and transport to an approved off-site incinerator.
o Backfill the areas with uncontaminated relatively ~rvious soil
if no additional remedial actions are needed, or install a temporary
cap over the excavated areas pending determination of extent of
contaminated soil below the areas and selection of an appropriate
remedy.
Declarations
Coosistent with the Canprehensive Environmental Response Canpensation, .
and Liability Act of 1980 (CERCIA), and the National Contingency Plan
(40 CFR Part 300) I have determined that the excavation and off-site
disposal or destruction of hazardous substances in the drum landfill,
paint sludge trench, agricultural drains and miscellaneous contaminated
areas is a cost-effective remedy necessary to prevent or minimize the
release of hazardous substances so they 00 not migrate to cause harm to
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I have also dete~ined that the action being taken is consistent with
permanent remedy at the site, and is appropriate when balanced against the
availability of 'Ih1st Fund JI01ies for use at other sites. In additioo, the
off-site transport, destructioo, and secure disposition is roore cost-
effective than other .remedial actioos.
The State has also requested approval of excavation and dispoSal of
contaminated soil under the landfill, paint sludge trench, agricultural
drains, and several other areas of contamination. I have determined that
sufficient data are not available to undertake those actions at this t~.
However, I am approving the rE!IIDval of the drun landfill, hazardous wastes
in the paint sludge trench and agricultural drains and identified contaminated
areas plus visibly contaminated soil in these areas since delay would
create an unnecessary threat to public health or the environment. Specifically,
there is a significant risk that organic wastes will volatilize at a high rate
if not rE!nDVed prior to warmer weather, posing a threat to nearby residents.
Following campletioo of this action, the State will conduct field
testing to determine the extent of contaminated soil below the landfill,
paint sludge trench, agricultural drains, and in several isolated areas of
contaminatioo. EPA and the State will evaluate the additional data and I
will make a further determinatioo on the app~opriate remedy for those areas.
"2-/7 7 / if V-
t8tf I
~~~
Lee M. Thanas
Assistant Administrator
Office of Solid waste & ~ergency
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PURPOSE
ISSUES
ASSISTANT ADMINISTRATOR
RECORD OF DECISION
BERLIN AND FARRO LIQUID INCINERATION SITE
o
To select the appropriate remedial action at the Berlin and
Farro Liquid Incineration site that is consistent with the
requirements of CERCLA and the NCP. The Assistant
Administrator for Solid Waste and Emergency Response has
been delegated the authority for that approval.
'0
There is a high degree of public and Congressional concern
that the schedule for implementation of remedial actions
will be delayed. Due to the high volatility of the hazardous
organic chemicals disposed on the site, it is technically
advantageous to implement this project during cool weather.
This necessitates that work begin on the site within the
next few weeks.
o
Given the history of State actions at the site, OERR is
concerned regarding State management of this project under
the cooperative agreement. HSCD has recommended to Region
V that the Corps of Engineers provide Federal oversight
during the remedial activities.
SITE HISTORY AND RESPONSE ACTIONS
o
The Berlin and Farro waste disposal facility is located in
Swartz Creek, Michigan. The site was used for incineration
and/or disposal of hazardous wastes between 1971 and 1981.
The facility operated under a State permit during some of
this time, however the operating permit was revoked after
numerous violations were documented. Title to the site
was deeded to the State in 1981 for non-payment of back
taxes.
o
The approximately forty acre site is a former industrial
waste disposal facility. The original site included a
deteriorated incinerator, 2 large sludge lagoons, 5 underground
waste storage tanks, a drum landfill, a paint sludge trench,
4 subsurface contaminated agricultural drains and numerous
other smaller isolated disposal areas.
In 1981, the site was declared a toxic waste emergency by
the Governor of Michigan. Approximately 4.5 million dollars
In State funds has been spent for cleanup actions and
enforcement efforts at the site. Most of these funds
became available through ~ special appropriation for the.
site approved by the state legislature.
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o
Most of the State funds have been used for excavation and
off-site disposal of lagoon sludges contaminated with
hexachlorolyclopentadiene (C56). The majority of this
work was done under Genesee County court orders issued to
the State in November 1982 and April 1983. The work was
conducted by the Michigan Department of Natural Resources
(MDNR) and was outside the approved scope of the Superfund
Cooperative Agreement. . .
o
EPA has spent approximately 1.04 million dollars for emergency
response actions at the site. These actions included
fencing, runoff control~ and off-site disposal of 3,600
drums which had been excavated by the MDNR and left 0" the
surface of the. landfill.
o
A Supe~fund cooperative agreement was awarded to the MDNR
in July 1982 for remedial activities at the site. The
amount of the award was $1,033,844. The scope of work
included a remedial investigation, feasibility study and a
remedial action to excavate and dispose of 4 underground
waste storage tanks and adjacent contaminated soils. (A
ROD was approved for this remedial action in October 1982.)
The MDNR has removed the underground tanks and contaminated
soils ($746,000) and conducted a preliminary hydrogeologic
study ($125,000). The report is not conclusive and additional
studies must be conducted to define the hydrology at the
site and the extent of ground water contamination.
ENFORCEMENT STATUS
o
Negotiations with potential responsible parties (PRP's)
have been ongoing since October 18, 1983. A "final" meeting
was held on February 14, 1983, to determine whether the
PRP's, EPA and the State could agree to a settlement prior
to approval of the ROD. If a settlement agreement is not
reached, a CERCLA Section 106 order will be issued to the
PRP's. If a positive response to the order is not received,
OWPE will give an enforcement release for fund obligation.
PROPOSED REMEDIAL ACTION
o
The Focused Feasibility Study (FFS) was conducted to evaluate
source control measures in the major areas contributing to
off-site migration. These were:
o Drum landfill (33,000 drums, 1.6 million gallons of
liquid waste, 24,000 cubic yards of solid wastes)
o Paint Sludge Trench . (3,900 cubic yards solid wastes)
o Agricultural Drains (3,300 cubic yards of solid wastes)
o Isolated Areas of Contamination (2,000 cubic yards
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o
The following options and costs were evaluated for solid and
liquid wastes after screening of preliminary alternatives:
Alternatives
Estimated cost ($M)
On-Site landfill for solids and
solidified liquids.
On-Site landfill for solids and
on-site treatment of liquids
$ 8.86
$ 9.58
~
Off-Site Disposal of Solids and Liquids
$ 9.08
o
On-site disposal is slightly less expensive than off-site
disposal; however, the high ground water table and permeable
soils cause off-site disposal to be a more cost-effective remedy
for this site.
o
The off-site alternative includes incineration of all
liquid wastes, thereby providing permanent destruction of
these wastes.
o
Public comments received generally support the proposed
alternative. No COmments recommended a different alternative,
although some questioned the phased approach of the site
cleanup.
o
The recommended cost effective remedial alternative is off
site disposal of solid and liquid wastes. The solid wastes
will be disposed in RCRA approved facilities and the liquid
wastes will be incinerated.
o
The estimated cost for this alternative is $9.08 M. The
actual amount of funding to be initially obligated will be
less than this amount because the MDNR has received a low
bid of 6.28 M for the total project. (See next bullet).
,
The MDNR has submitted a cooperative agreement amendment
request for funding to implement the recommended remedial
actions. The MDNR completed design work for the proposed
project in November 1983, and has formally advertised for
a contractor. Upon award of the cooperative agreement
amendment, the MDNR will sign the contract (6.28 M) for
implementation of the approved remedial actions.
o
o
A bill to appropriate the required State 10% cost share was
signed by the Governor in January 1984.
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FUTURE REMEDIAL ACTIVITIES
o
Upon completion of this remedial action, the following
Federal lead remedial planning activities will be conducted:
Remedial investigations, including contaminated
ground water and soils characterization, will be
completed. Estimated cost - $161,000.
A feasibility study will be conducted to evaluate
alternatives for final site cleanup. Estimated
cost - $131,000.
o
Based on the recommendations in the feasibility study, a ROD
may be prepared for additional source control and/or off-site
remedial actions.
NEXT STEPS
Action
Date
o
o
Approve ROD (AA-OSWER)
Issue CERCLA 106 (Region V)
February 17, 1984
March 9, 1984
Febr1.lal'}
1~, 1"04.
o
Enforcement release (OWPE)
o
Amend cooperative agreement
(OERR/GAD)
March 9, 1984
o
Initiate remedial action
( MDNR)
March 12, 1984
o
Initiate additional remedial
planning activities (Region V)
March 1984
o
Complete remedial action
. (MDNR)
August 10, 1984
o
Complete remedial planning
activities and prepare
ROD for recommended remedial
actions (Region V)
December 1984/
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&mnary of Remedial Alternative Selection
Berlin' Farro Liquid Incinerator
SWartz Creek, Michigan
Site tccation and Description
'!he Berlin' Farro Liquid Incineration uncontrolled hazardous waste
site, occupies apprOKimately 40 acres and is located 3 1/2 miles south of
the city of swartz Creek, Gaines Township, Genesee County, Michigan at
8322 Morrish Road (see Figure 1). '!he surficial geology of the area consists
of glacial fill, characterized as a heterogeneous mix of sand, silt, clay,
gravel, and boulders. Bedrock is encountered at depths ranging fran 125
to 156 feet. land use patterns in the area con~ist of agricultural rClvl
crops, small deciduous woodlands, and a residential area northeast of the
site. ApprOKimately 150 people reside within a 1/2 mile radius of the
site. DJe to the potential for hazardous emissions (specifically cyanide),
the majority of these people were evacuated during excavation operations
conducted by the Michigan Department of Natural Resources (MOOR) during
the sumner of 1983 and have since returned to their residences.
Residential and commercial wells exist in both the bedrock and uncon-
solidated geologic formation mentioned above. The direction of ITDvement
in the bedrock aquifer is generally to the northwest. DJe to the complexity
of the geologic and hydrologic conditions in the unconsolidated materials
(e.g. discontinuous bearing sand bases interspersed in a mix of silt,
clay, gravel, and boulders), ground water roovement is not limited to ooe
direction .
The scope of Focused Feasibility Study (FFS) covers the solid and liquid
hazardous materials contained on site in the drum landfills (large 1.23 acre
area and two small .09 and .08 acre areas), a paint sludge trench (.2
acres), two subsurface agricultural drains containing apprOKimately 3,300
cubic yards of contaminated soil, and numerous small, isolated burial
areas containing drums, liquids, paint sludges, and solvents with an estimated.
voll.lne of 2,000 cubic yards (see Figure 2). Surface water resources which
have been affected are the Slocum and Kimball Drains, which receive surface
water fran Berl in and Farro and empty into Swartz Creek. These surface
water resources are not used for drinking water but are used for recreation
purposes.
Site History
In April of 1971, Charles J. Berlin of Gaines Township obtained a
permit fran the State Air Pollution Control Carmission (APCC) to install a
waste incinerator at 8322 South ~rrish Road. This pecnit allowed -trial-
operation of the incinerator under specified air emis.sions restrictions
and allowed for storage on site of up to 40,000 gallons of waste. Within
six roonths, pecnission was obtained to bury solid wastes (particularly
elJi)ty barrels) on the southwest corner of the site. The Berlin and Farro
Liquid Incineration Canpany (Berlin and Farro) was fonned in April 1972
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IEALIN-FARRO TOXIC WAS;E'
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VICI~ITY MAP
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LOCATION AND VICINIT'-
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In E 'LAN AND POllU'1ON SOURCES
-------
-2-
QJring 1973, several canplaints were lodged against Berlin and Farro,
primarily ccncerning SI1Dke, odors, and other air pollution problems attributed
to operation of the incinerator. These complaints resulted in action being
taken against Berlin and Farro by both the State and Gaines TOwnship.
QJring a site inspection in July 1973, a county sanitarian found numerous
liquid-filled drums in the landfill area, in violation of the landfill
permit. The County Health Department and MINR ordered imnediate rerooval
of these druns. 'Ibis inspection record shows liquids were being improperly
handled at the Berlin and Farro site as early as July 1973, indicating the
potential for ground water contamination existed at least as early as
that date.
Sanetime in 1974, two unauthorized lagoons were constructed on site
capable of storing up to 2.5 million gallons of liquid wastes. The county,
in March 1974, discovered unauthorized ponds of oil and many Overturned
barrels which had spilled their contents on site. Berlin and Farro was
cited for gross noncompliance and ordered to correct the problem. The
State and County were able to document repeated contamination of Slocum
Drain and adjoining drainageways throughout 1974.
The MDNR conducted a site inventory in August 1975 and discovered
approximately 2,300 drums of liquid and solid wastes at the site. There
were also nearly 1,000 empty drums, with additional druns accumulating at
a rate of approximately 100 per week. In September 1975, the MOOR issued
a "cease and desist- order against Berlin and Farro, but waste continued
to be shipped to the site. One week later, Gaines Township obtained a
temporary restraining order which shut down the operation. As far as is
known, the landfill area of the site was not used again after 1975.
Berlin and Farro resumed operations in April 1976 under several
stringent conditions imposed by MrNR. In spi te of these condi tions, Slocum
Drain was found to be recontaminated in June and the lagoons on site were
still in existence and full throughout 1976. In July 1977, C-56
(hexachlorocyclopentadiene) was discovered in underground storage tanks on
site: it was also subsequently found in Slocum Drain early in 1978. At
this time, PCB's were also discovered in the site lagoons.
Berlin & Farro submitted a cleanup plan to the State in July 1978 and
initiated sane cleanup work that month. The State sued Berlin and Farro,
et al., in February 1979, seeking to expedite site cleanup work, and in
June a preliminary injll"lction was obtained against Berlin and Farro. The
lagoons were capped and sane wastes were rerooved. Cleanup work stopped in
late 1979. Title to a portion of the site was deeded to the State in 1980
for nonpayment of back taxes. Title to the remainder of the site was
deeded to the State in 1981 for the same reason.
Berlin and Farro apparently continued to haul wastes to the site until
JUly 1981, well after their operating permit had been revoked. In May 1981,
the site was declared a toxic waste emergency by the State TOxic Substance
Control Commission (TSCC). Subsequently, the Michigan state legislature.
appropriate $850,000 to conduct cleanup at the site. In November 1981 and
December 1981, an action was conducted by the State to remove 15,300 cubic
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-3-
In June 1982, acting on a request by the MrNR, u.s. EPA evaluated data
supplied by the State which indicated a potential fire hazard existed in
the landfill area at the site. These data reported flash point values of
sane wastes to be below 100°F, and sane PCB wastes in excess of 10,000
ppn. This cxmbination of factors led u.S. EPA to conclude an inminent
threat to human health and the environment existed at this site. During
June and July 1982, U.S. EPA, Region V conducted an immediate rencval
action at the Berlin and Farro landfill to fence the site and to excavate
and remove aprproximately 30 drums not secured in the landfill. The approximate
cost of this activity was $90,000.
Q'\ July 30, 1982, a Superfund cooperat i ve agreement was awarded to the
~ for $1,033,844. The Scope of ~rk of the cooperative agreement included
a hydrogeological study, waste characterization, a feasibility study,
underground tank rem::>val, and lagoon capping.
In OCtober 1982, under the cooperat i ve agreement, the MDlR began the
hydrogeologic study (contracted with D'Appolonia). The MOOR also began
removal of five buried tanks containing approximately 10,000 gallons of
C-56 contaminated liquid and removal of a total of 3,010 cubic yards of soil
surrounding the tanks. This cleanup action was completed in June 1983.
In late 1982, the Michigan state legislature approved an additional
$3,300,000 for cleanup activities. In January 1983, under a Genesee Oounty
Circuit Court order the MCNR began excavating lagoon sludges until work
was postponed in March 1983, due to bad weather. Between April 1983 and
July 1983, the MDNR spent $2,800,000 for removal and off-site disposal of
lagoon slud;es. The MrNR also spent approximately $350,000 for the excavation
of approximate 3,600 druns in the landfill areas. The drums were sampled
for waste characterization. By mid-July 1983, all of the available State
funds had been utilized and the 3,600 excavated drums remained in piles on
the surface of the landfill.
In July 1983, the u.s. EPA Region V determined that it was necessary
to undertake emergency actions at the site and requested Headquarters
approval of immediate removal funds. On August 17, 1983, $350,000 was
approved for the removal of the 3,600 druns pi led on the surface of the
site. W,rk began on August 29, 1983, and consisted of rem::>ving the solid
material from the druns, mixing the contents with on-site soils to raise
the flash point and loading this material into lined and covered d\.I'IIP
trucks for off-site disposal. The flammable materials found in the drums
had a lower flash point than originally anticipated and consequently, the
project scope had to be expanded and additional funding was necessary. On
OCtober 14, 1983, an additional $560,000 was approved and the imnediate
removal work was completed on OCtober 28, 1983.
The scope of remedial activities conducted by the MOOR at the site has .
been modified continuously throughout the course of the cleanup, and has
been perhaps I1I)St significantly impacted by a second Genesee County court
ruling made on April 16, 1983. This court ruling ordered the MOOR to
oammence clean up activities immediately in the sludge lagoon area because
this area was felt to represent the I1I)St serious potential for contamination.
This order caused other site work, including the hydrogeologic study, to
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,..
-4-
and immediate removal activities conducted during the summer 1983. Field
work for the hydrogeologic study was finally completed in early August
1983. The results of the draft report indicate that further ground water
work is necessary to complete the hydrogeologic study.
Additional studies are also necessary to characterize other areas of
contamination on the site~ A.feasibility study addressing the remainder of
the site is also planned.
CUrrent Site Status
Significant site features presently include drum landfills, "north"
and "south" lagoons, metal hydroxide settling ponds, a O.2-acre paint.
sludge trench, subsurface agricultural drains, the foundations of the
liquid incinerator that has been renoved, an area of contaminated soil at
the former site of several underground tanks, and numerous isolated pockets
of liquids, paint sludges, and solvents. The areas covered by the Focused
Feasibility Study included the drum landfills, the .2 acre paint sludge
trench, two of the four subsurface agricultural drains, and the numerous
isolated pockets of liquids, paint sludges, and solvents. See Figure 2
for reference.
The following items were specifically exclud~ fram the FFS scope:
o TWo agricultural drains, one that drains north into the landfill,
and another that drains south into the north lagoon. These drains
were not included in the FFS because they drain towards contaminated
area and are not likely to contribute to off site contamination.
o
Contaminated soil and ground water at the site in general. For
example, the FFS identified remedial actions for the contents of
the drum landfill and soil immediately beneath the landfill:
contaminated ground water and contaminated soil adjacent to the
landfill will be considered in later studies.
o The lagoon areas and metal hydroxide settling Ponds.
o COntaminated sediments in the existing on site stormwater retention
poods and in Kimball and Slocum Drains. .
o
COntaminate9 soil in the areas where buried tanks have been
renDVed .
Each of the above areas will be covered in the subsequent RI/FS.
the areas covered in the FFS is described below. .
Each of
Phasing of FFS Activities
As described above, the FFS evaluated several areas of the si te including
the drum landfill, paint sludge trench, agricultural drains, and several
isolated areas of contamination. The alternatives develoPed in the FFS
evaluate remedial actions dealing with the canbined wastes fran these are~s.
In order to develop and evaluate alternatives, voll.l'ne estimates of various
types of contaminated material were made using available data. These
estimates included voll.l'ne and type of wastes in the drum landfill and volume
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,.
;'5-
This approach was judged to be reasonable since it was not possible to
detennine the extent of contamination under the landfill, paint sludge trench
or agricultural drains without first excavating the drums and sludge to
expose the subsurface area for further sanpling. 1herefore, the alternatives
described in the FFS and the following sections of this docunent are based
on these estimated volll'nes. However, since the available data were not
adequate to detennine the extent of subsurface soi 1 contamination, EPA and
the State have determined that the recannendation of the FFS should be
m:x1ified to irrplement the remedial action in phases. The first phase will
include excavation and off-site disposal of the drum landfill, sludges in
the paint sludge trench, agricultural drains, miscellaneous contaminated
areas, and visibly contaminated soil. Existing data can adequately define
the extent of this activity. Removal of the landfill and sludges is required
to allow the State to conduct the necessary sampling in the subsurface
soils and detennine the actual extent of contamination. These new data
will be evaluated and the reccmnendation of the FFS may be revised if
necessary. Then, if appropriate, a new Record of Decisioo will be prepared
to approve the addi tional measures to deal wi th the soils under the drum
landfill, paint sludge trench, agricultural drains, and additiooal isolated
contaminated areas.
The decisioo to proceed with the drum landfill at this tUne is also
based on the need to canplete the remedial actioo prior to the elevation
of air temperatures during suntner rronths. The organic wastes contained in
the landfill will volatilize at a higher rate as air temperatures increase.
If the remedial action is implemented during cooler months, the risks
related to exposure of surrounding populations to volatilized organic
contamination will be lessened.
Drum Landfill
The drum landfill consists of a large area (1.09 acres) and two small
areas (0.04 acres and 0.06 acres) shown in Figure 2. The landfill contains
nestly crushed drums buried 5 to 10 feet below the existing ground surface.
These crushed drums typically contain waste sludge or contaminated solids,
and each drum occupies about one-third the volll'ne of a full 55-gallon
drum. Based on test pits, the MDNR estimates that approximately 33,000
crushed drums are contained in the landfill.
The MDNR also reports the following landfill data:
o Approximately 35 percent of the crushed drums in the landfill
contain solids with high PCB coocentrations (greater than 50 ppm).
o The landfill contains approximately 1.6 million gallons of liquid
wastes.
o Approximately 1 percent of the drums in the landfill are full and
intact and may contain additional liquid wastes.
o The landfill could contain small quantities of liquid wastes with
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"::6-
The total volume of solid waste in the drum landfill, including drums
and visibly contaminated, soil, is estimated at 28,000 cubic yards. One
thousand cubic yards of solid waste with PCB concentrations greater than
50 ppn are estimated. The remainder of solid waste, 27,000 cubic yards,
is estimated to have less than 50 ppn PCB. Available data indicates that
soil contaminated by vertical migration of liquid wastes may exist. several
feet below the site. Additional testing will be required to determine the
actual extent of contamination.
tUring the excavation conducted by the MrNR, 100 drum COtIpOsites of
sludge/solids, liquids, and oils were collected and analyzed. The ~
documented the maximun concentrations of canpounds, in parts per million
(ppn) :
TABLE 1
Max imum Concentrat ion of Drum Canpos i te Samples
Sample Category
Hexachlorobutadiene (C46)
Hexachlorocyclopentadiene (C56)
Octachlorocyclopentene (C58)
Hexachlorobenzene (C66)
PCB's Arochlor 1242
Arochlor 1248
Arochlor 1260
Sludge/
Solid(p~)
14
861
699
110
3500
35
7200
Oil(p~)
2.0
10.0
5.2
29.7
.5
250.0
9.0
Liquids(p~)
650
11 ,000
15,000
120
7300
2400
Paint Sludge Trench
The paint sludge trench is located near the Berlin & Farro property
line in the southeast portion of the site and occupies 0.2 acres. Based on
visual observations fran representative test excavations, the MrNR reports
that sludge and contaminated soil extend 10 feet below (maximlltl) the existing
ground surface. The total volume of sludge and visibly contaminated soil,
based on a lo-foot~p excavation, 25 feet wide at the bottan and 300
feet long, and having side slopes inclined at 45 degrees, is estimated at
3,900 cubic yards.
Agricultural Drains
~ subsurface agricultural drains are located in the eastern portion
of the site. One drain is 1,200 feet long and consists of 4-inch-diameter
perforated plastic pipe. The other drain is 600 feet long and consists of
4- to lo-inch-diameter clay pipe. The drains are currently filled with
solid and liquid wastes, and the ends of the drains are plugged. Based on
visual observations fran representative test excavations, soil backfill
surrounding the drains is contaminated. The vol\De of pipe and visibly
contaminated soil is estimated at 3,300 cubic yards. The estimate is
based on a 5-foot-deep excavation,S feet wide at the bottan and 1,800
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!'
-7-
Miscellaneous Contaminated Areas
tUnerous small, isolated burial areas containing druns, drun fragments,
liquids, paint sludges, and solvents have been identified by the MOOR
using geophysical techniques. Sane of these areas are expected to contain
hazardous solid wastes and are identified with asterisks in Figure 2.
Because the depth and areal extent of miscellaneous contaminated
areas are not clearly defined, volume calculations have been estimated.
'the volt.me of contaminated wastes and visibly contaminated soils is estimated
to be two thousand cubic yards. Additional sampling will be required to
determine if soils surrounding these areas are contaminated.
Routes of Exposure
'the potential routes of exposure to the hazardous substances on-site
are ground water, surface water, and air. As discussed earlier, two aquifers
are affected by the releases at this site. The upper aquifer consists of
glacial till, which is a heterogeneous mix of sand, silt, clay, gravel, and
boulders. Within the till, lenses of sand and gravel occur, with water
bearing capacity for domestic uses. Due to complex geologic and hydrologic
conditions in this formation, ground water novement is not limited to one
direction. Thus, there is a potential for contamination of the wells
which exist in this aquifer.
'the uppennost bedrock unit which occurs under the glacial materials
is t~ Saginaw Formatioo, encountered at depths ranging fran 125 to 156
feet. The Sag inaw is canposed of sandstone, shale, coal, and limestone.
Beneath the Saginaw lies the Michigan Formation, consisting of shale,
dolanite, and gypsum. Ground water occurs in both formations and is utilized
for residential and carmercial purposes. 'the bedrock formations are recharged
by water which infiltrates through the highly permeable overlying glacial
materials. Ground water novement is in a northwesterly direction, toward
wells which exist in the area. l'b off-site ground water contamination has
been documented: txYwever, the presence of high concentrations of wastes at
the site are a source of potential contamination due to infiltration through
the wastes into the ground water.
Surface water resources which have been affected are the SlocllTl and
Kimball Drains, which receive surface drainage fran Berlin and Farro and
ent>ty into Swartz Creek (see Figure 2). These surface water resources are
not used for drinking water purposes, but do serve a recreational function.
DJe to the volatile nature of the hazardous wastes on-site, releases of
air contaminants into the surrounding environment is a major concern,
particularly during cleanup operations. During the past cleanup activities,
air monitoring stations were established around the perimeter of the site.
f)'aforcement
Negotiations for voluntary inplementation of the selected remedial
alternative by the potentially responsible parties (PRPs) are ongoing. A
proposed Consent Decree was subnitted by the PRPs on January 11, 1984. 'the
Consent Decree includes a cleanup work plan developed by CEOOS Environmental,
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..
-8-
informed the PRPs that all of the terms of the Consent Decree must be agreed
to, except for the scope of work, 00 or' before the date of the award of the
Cooperative Agreement. If EPA is unable to reach final agreement within
this time frame, or if settlement discussions becane unproductive and EPA
terminates the discussions wi th the PRPs, Regional Counsel will recannend
that an en,forcement release be given.
Alternatives Evaluatioo
On August 31, 1983, a FOcused Feasibility Study was completed that
evaluated a limited number of alternative remedial measures for the drum
landfill, paint sludge trench, two agricultural drains, and seven small
miscellaneous contaminated areas. Detailed analyses and presentations of
remedial investigatioo data were beyond the scope of the FFS. A hydrogeologic
study initiated by the M~ under the Superfund cooperative agreement was
underway at the time of the FFS. 'Ihe data that were available as a result
of the oo-going study and other prior data were utilized for the FFS.
This included the following: '
o The preliminary logs of soil test borings made in the vicinity of
the drum landfill and the paint sludge trench;
o The logs of backhoe pits made at the landfill, the agricultural
drains, and potentially a clay borrow area located north of the
drum landfill;
o Atterberg limits, hydrometer and mechanical grain size analyses,
permeability, and compaction tests on soil;
o A portioo of the data from a geohydrological study of the entire
site, which'was still in progress;
o Soil resistivity, magnetometer, and ground penetrating radar surveys;
o Tbpographic maps;
o U.S. EPA priority pollutant scans on selected soil and ground water
samples, sludge contained in crushed drums in the landfill, liquids
contained in the landfill and north lagoon, liquids in the agricultural
drains, and soil backfill around the agricultural drains;
o Analytical test results for PCB's and chlorinated organics for
sludge samples fran the paint sludge trench.
'!'he conclusions derived from this remedial investigation data were
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~
-9-.
Alternatives and Initial Screening
There are several possible remedial actions for each contaminated area
and each type of hazardous waste found oo-site, as indicated below.
PCB and Non-PCB Solid wastes
Contaminated Area
Remedial Actioo Alternatives
Ikun Landf ill and Paint
Sludge Trench--32,600
Cubic yards
o No act ion
o Containment within a slurry trench
& cap
o Disposal in new landfill on-site
o Disposal in an existing landfill
off-site
Agricultural Drains and
Miscellaneous COntaminated
Areas--S,300 Cubic yards
o No action
o Flushing and cleaning (agricultural
drains only)
o Disposal in a new landfill on-site
o Disposal in an existing landfill
off-site
Non-PCB Liquid Wastes
Contaminated Area
Remedial Action Alternatives
Liquids contained in the
~um Landfill--l.6 million
gallons
o No ac:tioo
o On-site treatment
o On-site solidification
o Off-site disposal
Potential alternatives were discussed with EPA and MDNR during the
project kickoff meeting to develop all reasonable alternatives. These
alternatives were included in the FFS and initial screening further reduced
the list of alternatives to those that were subsequently evaluated for
cost-effectiveness. A discussion of remedial action alternatives that
were dropped in the initial screening process follows.
The no-action alternative for PCB and noo-PCB solid waste and for noo-PCB
liquid waste was elUninated during the initial screening process because of
the loog-term potential for additiooal cootamination of the soil, ground
water and surface water off-site. Factors contributing to this potential
contamination include: .
o A shallow ground water table that is in contact wi th wastes in the.
dnun landfill, paint sludge trench, agricultural drains, and .
miscellaneous contaminated areas:
o Sand lenses in the subsurface profile that cause a relatively high
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-10-
o '!be absence of any liner or leachate barrier on the bottan or
sides of the drum landfill, paint sludge trench, and miscellaneous
contaminated areas:
o The ProxUnity of Kunball and Slocum Drains.
The initial screening process also eliminated the slurry trench
containment alternative for the drum landfill and the paint sludge trench.
'!be prUnary reason for its elimination was extraordinarily high capital and
O&M costs. O&M costs include the treatment of liquid waste collected over
a 30-year project life, estUnated at 80 million gallons.
In the initial screening process, cleaning and flushing the agricultural
drains was considered inadequate and eliminated, since liquid wastes and
sane solid wastes inside the pipes would be removed: however, contaminated
soil surrounding the pipes would remain. These contaminants would continue
to leach to the local ground water and surface water, and threaten public
health and the environment.
After the initial screening process, the following remedial action
alternatives remained:
PCB and Non-PCB Solid wastes
Contaminated Area
Drum Landfill, Paint
Sludge Trench,
Agricultural Drains,
and Miscellaneous
Contaminated areas--37,900
CUbic yards
Remedial Action Alternatives
o Disposal in a new landfill on-site
o Disposal in an existing landfill
off-site
- Facility A (In-State)
- Facility B (Out-of-State)
Contaminated Area
Non-PCB Liquid wastes
Remedial Action Alternatives
Liquids contained in the
Drum Landfill--l.6 million
gallons
o No action
o On-site treatment
- Discharge to Slocum Drain
- Discharge to Fl int, HI, SI'P
o On-site solidification
o Off-site disposal
- Facility A (In-State)
- Facility B (Out-of-State)
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"-11-
Evaluation of Alternatives
As noted, the initial screening process eliminated the no-action,
slurry trench, and the cleaning and flushing remedial action alternatives.
Screening also eliminated all but ooe alternative for ~ solid wastes-
off-site disposal at Facility B. Disposal of ~ wastes on-site would
require construction of a disposal facility in CXI1pliance with 'ISCA for ~
concentrations between 50 ppn and 500 ppn. Incineration would be required
for wastes above 500 ppn. Off-site disposal was the only alternative that
would allow disposal at a facility permitted to receive ~ oontaminated
wastes. '!he cost of ~ disposal at Facility B is estimated at $4.6 million.
After initial screening, several viable options for non-~ solio and
liquid wastes remained, as listed above. EPA first evaluated the costs of
these options. These costs are arrayed in Tcsble 2. For solids, consideration
of costs led to elimination of the alternative of disposing of the wastes
at Facility B for which costs are markedly higher than either on-site
disposal or off-site disposal at Facility A. '!he costs of the remaining
alternatives, on-site disposal or off-site disposal at Facility A, are
virtually indistinguishable, given the statistical confidence limits of the
cost estimates.
For liquids, consideration of costs resulted in the elimination of the
two alternatives requiring on-site treatment and discharge. Each of these
alternatives was two to three times the cost of the other disposal alternatives.
EPA next considered the environmental effectiveness of the remaining
alternatives. For solids, the relative effectiveness of on-site versus
off-site disposal is a close call, since either method would involve disposal
in a secure facility designed to comply with RCRA requirements. However,
two factors suggest that off-site disposal is the more effective alternative.
First, the high ground water table and permeable subsurface soils characteristic
of the Berlin and Farro site are generally not suitable for construction of
an on-site disposal facility, so long as there is another viable cost-
effective alternative for disposal. AlttDugh an on-site facility would be
designed to guard against releases, these hydrogeologic characteristics
would multiply the adverse effects of any failure of the facility. Second,
removal to an off-site facility can be accamplished faster than construction
and disposal on-site. '!'he presence of volatile carpounds, such as C-56, in
the sources designated for removal, and experience at the site, derra1strate
a need for expeditious rem:wal. Warmer weather will cause these CCIIp:)Unds
to volatilize at a higher rate, presenting a tangible health threat to nearby
residents. Indeed, it was similar conditions that caused ~ to evacuate
the area during reaDVal operations conducted in the BUIlDer of 1983.
Theref~, in light of the camparabl, costs of on-site and off-site
disposal, and the predicted greater effectiveness of off-site disposal, off- .
site disposal is a more cost-effective remedy, and is the recamnended
alternative for solids.
The scime considerations discussed above dEm::lnstrate that off-site
disposal of liquids is more effective than on-site dispoal. Additionally,
disposal of liquids in a landfill either on- or off-site, would require
solidification of the wastes. EPA's experience with such methods is that
solidification does not necessarily stabilize liquids containing organic
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-12-
wastes is off-site transport and incineration at Facility C. Since the
costs of this alternative are comparable to the costs of on-site or off-
site disposal, it is the most cost-effective alternative and is recammended.
EPAls analysis was generally confi~ by the analysis performed in
the FFS. The criteria used in the FFS to evaluate alternatives might have
understated to sane degree the effectiveness of on-site disposal. However,
the analysis in the FFS does demonstrate the closeness of on- and " off-site
remedies, and supports EPAls selection of the cost-effective alternative.
The cost-effectiveness evaluations used in the FFS are described below.
Evaluation Procedures
A cost-effectiveness ranking procedure was used that considered level
of cleanup provided, construction time required, camlunity acceptance,
public health and environmental impacts during construction,. technical
feasibility, land use ~acts, risk of failure, and oompatibility with
other remedial actions. This evaluation procedure is described in an
article entitled "Evaluating Cost Effectiveness of Remedial Actions At
Uncontrolled Hazardous waste Sites-Draft Methodology Manual," prepared for
the Municipal and Environmental Research Laboratory, U.S. EPA, by Radian
Corporation, January 10, 1983 (DON 83-203-007-60-70).
The following steps summarize the evaluation procedure.
1.
Remedial action alternatives were listed in the evaluation
table (Table 2), along with effectiveness measures, and
weighting factors. weighting factors shown are those
suggested by Radian Corp.
2.
Initial costs and the present worth of O&M costs were
estimated for each alternative and listed in the table.
3.
Alternatives were evaluated using each effectiveness measure, then
ranked on a scale of 1 to 5 (with 5 being the best score).
4.
Scores for each effectiveness measure were multiplied by the
appropriate weighting factor, then added for each alternative.
This produced the "total weighted efficiency rating."
It is recognized that this evaluation and ranking procedure, as does
every other available evaluation procedure, requires subjective judgment.
Scores for each alternative have been assigned based on engineering judgment.
Nevertheless, if consideration of factors other than cost is to be included
in the evaluation process, a certain amount of subjective judgment is
required. A detailed description of this procedure is included in the FFS.
Estimated costs and alternative scores selected for the Berlin & Farro
site are shown in Table 2 and discussed below.
Estimated Costs
Cost estimates have been prepared for remedial action alternative" .
evaluations based on available information. The final cost of the project
will depend upon actual labor and materials unit costs, material quantities,
-------
'lilli'
llflelc"., "~lln9
If' c'; ~ 'veness. Husure ...stDres
ht "latd Cost
(~1".1~~5- of d.!>J'!~~)
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Solids
HeN on-site Llndlill 4 1 ., -1 2 " 4 19.2 ] 3.24 0.1,: ].4
. £lIsting Off-site IIndflll (he lilt. A) 5 5 !J " 5 5 5 5 16.] ].81 0 ].81
hitting Oil-sit.. lindflll (he lilt y n) 5 " !I " 5 5 5 5 15.0 2 11.18 0 II.ld
lIquids
on-site TreltMent Strea. III sch~"!le 4 ] J .1 -1 4 4 4 19.0 5 1.58 0 1.58
on-site Solldlflcltlone 4 7. ] ] 2 2 ] 4 16.2 ] 0.86 0 .06
On-site TreltMent. flint SIP Discharge 5 J 4 J 4 4 4 4 21.4 4 1.59 0 1.59
Ofl-slte Uisposil (facility A) 5 ,. 5 4 5 5 5 5 26.] .56 0 .56 '1
.1
Iff-site Disposil (fie IIlty CJ 5 5 5 4 5 5 5 5 26.3 .58 0 .58
i _. -.---- --_. -- --
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c"l..~utlons Ind "'nlenanu' 1:0\'.\ h"vl! '..'rn se",u',llc,' 'n'", 1111,11 (fI~.ls. 54.6 1I""on.
d"resenl ""rtb v.lue, dClf's nllt 'n,lutl,! "'-0 sol id 'PIIIOV",. (IIsl 0' I" U ,'clllOval h (,511I1dtr.d at
el Altern.1t1ve SCore tI..s we",hl"" fII(IIIr, (holhl"'e: IIl!w Oll-',It,~ I.",rtllll: 4 x 1.1 x.5. ]xfi...'4x 1.1 . 4 x .5 . 19.2).
,AS\\IIIIt'S hr... lindf fli 'n built 1111 \ I I..
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,.
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and other variable factors. Project feasibi 1 i ty and funding needs must be
carefully reviewed before specific financial decisions are made, to help
assure proper project evaluation and adequate funding.
'Ihe estimates presented herein are .order-of-magnitude" as defined by
American National Standards Institute (ANSI) Z94.2 and the American Association
of Cost Engineers. It is no~lly expected that an estUnate of this type
will be accurate within + 50 percent and - 30 percent. 'these percentages
should be viewed as statistical confidence limits and must not be confused
with contingencies.
Alternative Scores
Scores of 1 and 5 in Table 2 represent the extremes for the alternatives:
1 is the worst and 5 is the best. Intermediate values between the 1 and 5
were used to rate an alternative relative to the others for that particular
effectiveness measure. Intermediate values are subjective, based on experience
and engineering judgment.
Scores were assigned in terms of the Berlin & Farro site. For example,
when comparing the level of cleanup for off-site and on-site disposal
alternatives, in both cases, the wastes are contained in hazardous waste
landfills and are relatively isolated fram t~e environment. However,
wastes remain on-site with the on-site alternative, and there will always
be a potential for future contamination since the wastes would be contained
in permeable ground water recharge areas. Q1-s i te al terna t i ves were,
therefore, ranked lower. Similarly, when impacts of failure are compared,
the risk of failure for wastes contained off-site is lower. Although the
risk of failure for each alternative should be the same, the impact of
failure is greater for on-site disposal since the containment structure
would be in contact with ground water at the site. Thus, on-site alternatives
were ranked lower.
Level of Cleanup Provided
'I'he level of cleanup is based on rerooval of the contaminants fram the
site with 1 given to no removal and 5 given to complete removal. Even
though the contaminants will be contained in a hazardous waste landfill,
on-site disposal alternatives were ranked lower than off-site alternatives
because the contaminants remain on-site and, given the hydrogeologic conditions
at the site (e.g. the on-site landfill would be in direct contact with the
ground water) there would always be a potential for future contamination
of the ground water.
Catstruction Time Required
A 5 was assigned to alternatives that could achieve the quickest (3
to 5 months) mitigation of continued migration of wastes fram the site and
a 1 to those that would take longer than 5 years. Rem:>val to Facility A
or Facility C was considered the quickest (3 ItO'Iths), whereas removal to
Facility B was expected to take ~re time (9 to 12 months) because of the
considerably longer haul. Q1-site disposal and treatment alternatives are
expected to be the loogest (1 to 3 years) because of the construction time,
permitting that may be necessary for the new landfill, on-site treatment
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ecmmunity Acceptance
'!'hose alternatives that had no long-term impact on the CXImIunity were
assigned a 5 whereas those that caused a continued or permament change to
the normal way of life were assigned a 1. Off-site disposal alternatives
were assigned a 5 because, once the wastes are rerroved, the si te can
potentially be reclaimed. Q1-site disposal alternatives allow ally limited
reclamatial, and a new hazarodus waste landfill ai-site would likely have
psychological inpacts. Q1-site disposal alternatives were given a 3.
Health and Environmental 1mpacts During Construction
A 1 would be assigned to alternatives with severe health and environmental
impact during construction and a 5 to those with none. All the alternatives
have sane health and environmental impacts during construction, so none was
assigned a 5. Alternatives for solid wastes were all rated the same-4.
Q1-site treatment alternatives for liquid wastes were considered to have a
greater impact on health and the environment than off-site disposal because
of waste gases from the air stripper, and because the on-site treabnent
system is more complex than the relatively simple pumping at liquid waste
materials.
Technical Feasibility
Those alternatives that are relatively simple, easily designed and
constructed, and are proven methods were assigned a 5, whereas complex,
difficult, and unproven methods were given a 1. The off-site alternatives
were given a 5 because existing facilites are experienced in the treatment
of wastes and have a history of performance. Q1-site alternatives were
rated less because there is no history and there is a potential for problems
during the initial operation. Q1-site solidificat-ion was rated the lowest
because of the lack of knowledge of the long-term leaching properties of
solidified liquid wastes.
Land Use Impacts
Those alternatives that completely prevent the desirable use of the
site were given a 1 and those that allowed the unrestricted use of the site
were assigned a 5. Off-site alternatives were ranked a 5 because after the
site has been reclaimed use of the land would be essentially unrestricted.
Q1-site alternatives would restrict the future use of the site and were
ranked lower.
Risk of Failure
Those alternatives with a high risk of failure (the possibility of
failure coupled with the consequences of failure) were given a 1. '!hose
alternatives considered fail-safe were given a 5. Off-site alternatives
were assigned a 5 because with the waste off-site the possibility of failure
and consequences of failure are nonexistent, relative to the Berlin and
Farro site. Q1-site alternatives were therefore, ranked lower than off-sHe
alternatives since the possibility of failure does exist when the wastes are
contained on site.
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..
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Ocmpatibility with Other Remedial Activities
A 5 was given to those alternatives that were campletely compatible
with other activities and a 1 given to those that campletely interfered or
caused a loss of eoonany. For the rost part, all alternatives were relatively
canpatible. O'I-site alternatives created sane disruptioo during coostruction
and were ranked lower.
Community Relatioos
A public meeting was held 00 June 6, 1983, at the Gaines Township Hall
at the start of the Focused Feasibility Study. The purpose of the FFS,
expected aCCCl'lplistJnents, the alternatives likely to be analyzed, other actions
planned for the site, and other issues raised were discussed. A subsequent
meeting was held 00 September 14, 1983, to present the draft FFS and to solicit
Clalments. verbal carments received at the meeting supported the selected
alternatives. Various types of media (eg. newspaper ads, fact sheets,
radio) were utilized to notify the public of these meetings. Representatives
of u.S. EPA, State and local goverrunents and the OCIII'IIJnity were all well
represented. Copies of the FFS were provided, with a thirty (30) day
cxmnent period. A camprehensive Carmunity Relatioos Program is planned for
the FFS ~lementatioo. A copy of the responsiveness summary is attached.
Potentially Responsible Party Oamments
The potentially responsible party (PRPs) submitted a cleanup work plan
developed by CECOS Environmental Inc. to EPA and the State. This plan has
been reviewed to determine if any technical c..ClII~ents differ fran the
proposed renedial action recarrnended by EPA and the State. It was determined
that the CEODS plan is technically consistent with the proposed actioo
since all proposed remedial activities are also included in the CECOS plan,
and since the CECOS plan recarrnends the remedial alternative adopted in
this Record-of-Decision. The major difference is that the CECa) plan
includes additiooal cleanup activities that are not recommended by EPA and
the State at this tUne. As noted earlier, these additiooal activities will
be addressed in a future RI/FS.
Consistency with Other E)1virauuental Requirements
The proposed actioo will not require on-site treatment, storage, and
disposal of hazardous wastes. Therefore, there are no issues involving the
coosistency of Cl'l-site actions with RCRA. Off-site disposal of wastes will.
be in accordance with the approt)riate RCRA regulations for the transportatioo
and disposal of hazardous wastes. This will include manifesting of wastes
and shipment to a RCRA approved facility. Disposal of PCB wastes will be
at a TSCA permitted facility. Residual contaminated soil that may be found
under the dnm landfill or other areas will be managed in future remedial
actioos. Appropriate RCRA technical regulatioos will be used if remedial
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!"
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Reca.llended Al ternat i ve
Section 300.68 of the National Oil and Hazardous Substances Contingency
Plan (NCP) states that the appropriate extent of remedy shall be determined
by the lead agency's selection of the remedial measure which the agency
determines is cost-effective (i.e. the lowest cost alternative that is
technologically feasible and reliable) and which effectively mitigates and
minUnizes damage to and provides adequate protection of public heaith,
welfare, or the environment. Based on the evaluation of the cost and
effectiveness of each proposed alternative, the comments received from the
public and the Mt'NR, the follC7tiing alternative has been determined to be
cost-effective as defined by the NCP: .
o Excavate the existing dnm landfill and dispose of sludge, crushed
. dnms, liquid wastes and visibly contaminated soil at an approved
off-site facility.
o Excavate the paint sludge trench and dispose of sludges and visibly
contaminated soil at an approved off-site facility.
o
Excavate the agricultural drains leaving the site and miscellaneous
areas of visible contamination, and dispose of wastes, sludge and
visibly contaminated soil at an approved off-site facility.
The remedial action also includes installation of a temporary cap if
it is determined that additional actions are needed to address contaminated
soil under the areas. If no additional actions are needed, the areas will
be backfilled with uncontaminated, relatively impervious soil.
The reccmnended action is considered a source control measure as
defined in section 300.68(e) of the NCP. The objective of the action is
to remove potential sources of continUed migration of wastes from the site.
This includes liquid and solid wastes, sludges and visibly contaminated
soils. Residual contamination that may exist beyond these areas will be
investigated in a future RI/FS to be conducted by EPA. That RI/FS will
determine if additional remedial actions are needed to address remaining
soil and ground water contamination on-site and will develop the appropriate
level of cleanup. Determining the appropriate extent of future remedial
act ions was beyood the scope of the FFS.
The evaluatial of alternatives for source control measures determined
that off-site disposal of the hazardous wastes was IIDre cost-effective than
feasible ai-site alternatives. O't-site disposal of solid and liquid waste
was found to be slightly more expensive (less than 5 percent IIDre, see
Table 2). Given the statistical confidence limits of these estimates,
the costs of aI-site and off-site disposal are nearly indistinguisable.
flbrever, off-site disposal was determined to be IIDre cost-effective when
the effectiveness measures were considered. O't-site treatment of liquids
required solidificatioo which has not been proved reliable. This could
result in leaching of organics over time if wastes are left oo-site. In
additioo, although construction of an oo-site disposal facility would be .
in ccmpliance with appropriate RCRA regulations, the high ground water
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-17-
construction of a land disposal facility. The risk of failure for an
on-site facility should be the same as for an off-site facilitY1 however,
the Unpact of failure of an on-site facility would be greater due to the
unsuitable hydrogeologic conditions docunented in the MINR's hydrogeologic
investigation. Finally, the shorter time needed to disPJSe of the wastes
off-site (3 mcnths versus 1 to 3 years) also points to off-site disposal
as a DDre effective alternative, particularly since the wastes will be
renDYed prior to warmer weather, which would cause organic wastes to volatize
at a higher rate. Therefore, the increased effectiveness associated with
off-site disposal outweighs the slight increase in cost if any, of off-site
cxmpared to on-site disposal.
Off-site disposal of all solid wastes will be at approved facilities.
Non-PCB wastes will be disposed at a facility that ccmplies with RCRA~ PCB
solid wastes will be disposed at a facility pemitted by TSCA. Additionally,
EPA will review the facility selected by the State to ensure that conditions
similar to those present at Berlin and Farro do not exist. Sanples collected
by MOm indicated small quanties of liquid PCB wastes. Since data did not
indicate an estimatable quantity of liquid PCBs, no alternative for these
wastes were evaluated. ft:Iwever, the cost estimates for each alternative
includes a contingency for disposal of liquid PCB wastes, if found. Liquid
PCB wastes will be incinerated, as will non-PCB liquid wastes.
The recommended remedy also includes off-site disposal of liquid wastes
fram the drum landfill. Table 2 shows that off-site disposal of liquids is
less costly than on-site alternatives. The FFS recommended off-site disposal
at Facility A as the cost-effective method of disposal for liquid wastes.
However, the factors used to evaluate alternatives did not distinguish
between the effectiveness of disposal and destruction. Disposal of wastes,
even when in confo~ce with appropriate regulations, leave the wastes in
the environment with the possibility of future release. Destruction by
incineration will pe~ently remove wastes from the environment and eliminate
any possibility of future migration. Off-site disposal at Facility A is
slightly less expensive than off-site incineration at an approved facility
(less than 5 percent difference in cost, see Table 2). However, the cost
of incineration is still lower than on-site disposal of liquids, and when
considering the higher level of protection provided by destruction rather
than disposal, incineration of liquid wastes is DDre cost-effective than
other methods of off-site disposal.
The est imated costs for the reccmnended act ion are:
Site Area
Estimated Cost
[hm Landfill
Non-PCB Sol id Waste
Non-PCB Liquid Waste
PCB SOlid wastes
$2,955,813
564,800
4,608,737
Total truu Iandfill
8,129,350
Paint Sludge Trench, Agricultural Drain
and miscellaneous areas
$ 953,856
'Ibtal Estimated COst
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Schedule
- OCmplete Enforcement Negotiations
- Approve Remedial Action (Sign ROD)
- Issue CERCIA 106 Order
- Enforcement Release
- ~d Cooperative Agreement
- Start Construction*
- Ccmplete Construction
February 14, 1984
February 15, 1984
February 17, 1984
March 9, 1984
March 9, 1984
March 12, 1984
August 10, 1984
* Design CXJnpleted by the ML'NR at its o.m expense in November 1983.
E\Jture Actions
An additional remedial investigation/feasibility study will be oonducted to
determine the extent of soil and ground water contamination for those areas
of the sites not yet addressed. This activity will be a federal-lead
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.
. .
,
- .
Responsiveness Summary
Public Comments on Focused Feasibility Study, Berlin & Farro, Swartz Creek, Michigan
~
The Focused Feasibility Study (FFS) for the Berlin & Farro hazardous waste
site near Swartz Creek, Michigan was completed on August 31, 1983. Copies
of the FFS were made available at the Gaines Township Hall near the site
and mailed out to interested parties by the Michigan Department of ~atural
Resources (MOHR). A public meeting was held at the Gaines Township Hall on
September 14, 1983, to present the FFS and solicit comments. Verbal comments
received at the meeting supported the selected alternatives.
Written comments were received from six parties: a Michigan State SenatQr,
the MONR and four businesses. Region V is reviewing and responding to the
comments from all the parties.
A summary of the significant comments and responses are presented below.
Several commenters stated that the Agency could not prepare a feasibility
study covering only a portion of the site. The comrnenters feel that all
remedial investigation work must be completed and then one study prepared.
The Agency.s response is that the National Contingency Plan (NCP) does not
call for a feasibility study for an entire site. The NCP calls for.an eval-
uation of alternatives for hazardous substances. The Agency has decided
that discrete areas with hazardous substances may be investigated, remedial
alternatives evaluated, and remedies implemented while other areas at a
site are still in the planning phase~ This allows for an acceleration in
implementing remedial measures to limit exposure or threat of exposure to a
health or environmental hazard. A FFS is the evaluation of alternatives
for these discrete areas of hazardous substances.
Several commenters felt that the hydrogeological investigation must be
complete before a decision can- be made regarding on-site disposal methods.
The Agency's response is that while the hydrogeological study was not com-
plete when the FFS was finalized there was sufficient data available from
the hydrogeological study on which to base decisions regarding alternative
evaluation and selection.
Several commenters felt that the -off-site disposal facilities should be
identified and arrangements made for disposal capacity. The Agency.s
response is that the selection of the off-site disposal facility will be
made by the cleanup contractor bidding on the project, subject to Agency
and MOHR approvals. Disposal facilities are not identified in the FFS
since competition among cleanup contractors and disposal facilities is
encouraged to provide the lowest cleanup cost while still protecting public
health and the environment.
One commenter felt that the FFS adequately addressed the needs for remedial
-------
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US ENVIrlON~:N~~L ?~O~~CT!ON
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that tec~~s= of t~e nat~re 07 t~~C-5o ~at2rial a: :~e s; t2, c;2~n ~p
should reS~1r.e s:c,'1 :~ ~:.:<2 ad'/ant:.ge of c:cl te:nper:.tt.:res.
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In addition, ! believe the people who live near t~e site have had to
li'le 'r'iith t~e :.mcer::.inties ataut ~:1e safety of t:;e site anc its affec':,S
on their health Tar too long. It has ::een mere then ten ye~rs since
efforts be,=an ::J close the Berlin and Farro dis:osal faci1 it:; and t:J
cle""n U"" +'~e ""'"o=> T..IS "'"-e to ':'nl's:n ";"0 J''''o" ;;5 t""'l'CI.1y c::,,'::,1,/
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and efficientiy as possible. There is no lenser an; eXCL1se fQr:2ia~/.
I urge you to gi'/e this your ifi:media:e attention 50 that rE~ec:ial ','Iork
can begin and :;'1S situation can finally ~e resolved.
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