United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-91/182
September 1991
<&EPA Superfund
Record of Decision:
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REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. Redplenl'8 Acc:8uIon No.
PAGE EPA/ROD/R05-91/182
... 1118 and SW1II8 5. Report Dete
SUPERFUND RECORD OF DECISION 09/30/91
Berlin & Farro, MI 6.
First Remedial Action - Final
7. Auflor(8) 8. Performing Organization RepI. No'
8. P8rf0nnlng Org8lnlz81lon ...... and Add- 10. ProJactlTlI8uWork Unit No.
11. ConInIcI(C) or Gr8nt(G) No.
(C)
(G)
1~ ~ng Org8nlz8tlon""'" and ~ 13. Type of Report . Period Coftf8d
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Buppl8m8nt8ry No'"
16. Abenct (Umlt: 200 _nI8)
The 40-acre Berlin & Farro site is a former liquid incineration and landfill facility
in Gaines Township, Genesee County, Michigan. Land near the site consists of
woodland and agricultural areas. In addition, the site overlies two aquifers, which
provide well water to the approximately 80 permanent homes located within a 1/2 mile
radius of the site. From 1971 to 1975, Berlin and Farro Liquid Incineration, Inc.,
used the site to accept and store industrial wastes prior to incineration, and
disposed of crushed drums in a 1.1-acre onsite landfill. During this period, the
owners failed to comply with air emission standards, onsite storage volume limits,
and permit standards that prohibited onsite disposal of wastes other than solid
wastes. The facility also operated two unauthorized waste storage lagoons and two
unlined storage lagoons; illegally buried five tanks of wastewater; buried liquid
wastes; operated underground storage tanks; poured liquid wastes into subsurface
agricultural drains; and dumped thousands of gallons of barrelled wastes into two
onsite pits. In 1975, Berlin and Farro's permits were revoked; however, illegal
dumping of industrial waste into the lagoons apparently continued after the site was
closed. Several separate clean-up actions were undertaken by the PRPs, the State,
(See Attached Page)
17. Document An8Iy818 L D88c:rIpIo18
Record of Decision - Berlin & Farro, MI
First Remedial Action - Final
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), metals (arsenic,
b. Id8ntlll8r8lOp8n-EncI8d T- chromium, lead)
0. COlA 11 FlllcWroup
18. Av1l18b11ty St8t8m8nt 18. S8a8ity CI... (Thi8 Report) 21. No. of P811"
None 72
20. SecurIty CI... (Th18 Page) n PrIce
Nnnp
.1 ,'''
/10272-101
"
(1188 ANSl-Z38 8)
SHtMIrucII- on Re-
(Formeriy NTls.35)
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EPA/ROD/R05-91/182
Berlin & Farro, MI
First Remedial Action - Final
Abstract (Continued)
and EPA during the early to mid-1980's. These activities included, but were not limited
to, removing lagoon sludge, the incinerator facility, five underground tanks, an
agricultural drain and paint sludge trench, surface debris, drums, waste piles and soil,
and 1,000,000 gallons of contaminated water; backfilling the lagoons and old drum
landfill; and constructing settling ponds. This Record of Decision (ROD) addresses the
final remedy for contaminated soil, sediment, and ground water at the Berlin and Farro
site. The primary contaminants of concern affecting the soil, sediment, and ground water
are VOCs including benzene, PCE, TCE, toluene, and xylenes; and metals including arsenic,
chromium, and lead.
The selected remedial action for this site includes excavating, partially treating using
solidification, and consolidating (in an onsite RCRA containment cell) contaminated soil
and sediment from the central site area and sediment from an offsite drain (treatment of
the materials will remove free liquids and render characteristic waste and
non-characteristic RCRA waste); collection and treating leachate from the call;
backfilling, covering with soil and revegetating the excavated onsite areas; regrading
the excavated areas of the drain; pumping and treatment of ground water from the shallow
portion of the aquifer using a system of collection trenches, followed by treatment using
air stripping and onsite discharge to the drain; treating off-gas emissions from the
ground water treatment system; monitoring ground water; and implementing institutional
controls including deed restrictions. The estimated present worth cost for this remedial
action is $8,119,300, which includes an annual O&M cost of $233,100 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil and sediment clean-up goals are
based on State health-based standards and include benzene 0.02 mg/kg, lead 20.8 mg/kg,
toluene 16 mg/kg, and xylenes 6 mg/kg. Chemical-specific ground water clean-up goals are
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DECLARATION FOR THE RECORD OF DECISION
..
site Name and Location
Berlin and Farro site
Swartz Creek, Michigan
..
statement of Basis and Purpose
This decision document represents the selected remedial action for
the Berlin and Farro site, Swartz Creek, Michigan, which was chosen
in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to
the extent practicable, the National oil and Hazardous Substances
Pollution Contingency Plan (NCP).
This decision is based upon the contents of the administrative
record for the Berlin and Farro site.
The state of Michigan concurs with the selected remedy.
Assessment of the site
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of Remedy
This final remedy addresses remediation of ground water, soil and
sediment contamination by eliminating or reducing the low level
threat posed by contaminated soil and sediment through containment
on-si te and the threat from contaminated ground water through
treatment.
The major elements of the selected remedy include:
* Excavation, partial treatment, and containment of
approximately 48,000 cubic yards of contaminated soil and
sediment from on site locations and sediment from Slocum Drain
in an on-site RCRA Subtitle C/Act 64 cell, with treatment of
any leachate collected from the cell:
* Back-filling, covering with topsoil and revegetating the
excavated on-site areas and regrading the excavated areas
of Slocum Dr-ain:
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* Extraction of contaminated ground water and treatment of
the ground water by air stripping on site and treatment of the
off gases;
* Site deed restrictions to prevent installation of drinking
water wells or other intrusive activity at the site; and
* Ground water monitoring to assess the state of the
remediation.
statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volu~e as a principal element. As
this remedy will result in containment of waste on-site and
initially result in hazardous substances remaining on-site above
heal th-based levels during the remediation of ground water, a
review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
BERLIN AND FARRO SITE
SWARTZ CREEK, MICHIGAN
I.
SITE NAME. ~CATION AND DESCRIPTION
The Berlin and Farro facility is a fenced 40-acre site situated in
a primarily rural area approximately 3\ miles south of the town of
Swartz Creek in Gaines Township, .Genesee County, Michigan (Figure
1). The street address of the site is 8322 South Morrish Road,
Swartz Creek, Michigan. Primary land use in the area consists of
agricultural row crops and small deciduous woodlands. The property
is zoned for residential and agricultural use. Residences are
located within about 500 feet of the northeast and southeast
boundaries of the site. Approximately 80 permanent residences are
located within a \ mi~ radius of the site. There are no known
endangered species or critical habitats within close proximity of
the site.
The site ground surface is flat to gently rolling with 0 to 6
percent slopes. Ground surface varies from elevation 812 to 822
feet, mean sea level. Surface water runoff generally flows
westward toward Slocum Drain with lesser amounts of runoff flowing
eastward toward vincent Drain and then Kimball Drain. Slocum and
Kimball Drains are excavated d~tches used to convey runoff to help
drain surrounding farmJand. Agr1cultural drain tiles (buried clay
pipe) are also used in the area to drain surface water infiltration
from farm fields. The tiles discharge into the drains.
The site also contains several bodies of water which have resulted
from surface cleanup activities (Figure 2). The South Lagoon and
the Tank Excavation Area. ponds retain water year round. Two
settling ponds constructed to reduce off-site runoff, retain water
for much of the year. In addition, there are three marshy areas
created by prior cleanup activities at the site which retain
standing water during parts of the year, especially during rainy
seasons. These marshy areas are not classified as wetlands.
.
The site geology is characterized by glacial till overlying
bedrock. The glacial till is approximately 120 to 150 feet thick
and is comprised primarily of clay with intermittent water-bearing
sand lenses up to 10 feet thick.
The glacial till overlies the Saginaw formation, a typically
fractured sandstone, which is the uppermost bedrock. Two units are
recognized in the glacial till; an upper unit to a depth of about
50 to 70 feet and a lower unit to a depth of about 130 feet. Both
units have sufficient permeability to be considered aquifers. The
upper till unit has been divided into two zones defined as the
shallow zone and the intermediate zone. The shallow zone extends
to a depth of about 30 feet. The intermediate zone extends from 30
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VICINITY MAP
BERLIN AND FARRO
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differences in water level variation in the geology with depth.
Wells in the glacial till water-bearing sand lenses typically have
yields of 5 to 20 gallons per minute. Test wells at the site
generally have yields lower than 5 gallons per minute. The upper
portion of the bedrock at the site is primarily sandstone. Wells
in the bedrock aquifer have yields of 1~ to 20 gallons per minute.
Residents near the site obtain ground water from wells in glacial
till aquifers and from the underlying bedrock. There are 115
. residential wells within one mile of the site. Approximately 1/3
of the residential wells draw water from the glacial till aquifers.
At least one well in the area draws water from the shallow portion
of the aquifer. The remaining residential wells draw water from.
the bedrock.
v
Groundwater migrates both laterally and vertically in the upper
glacial till. The direction is generally radial away from a
mounded area in the north central part of the site and otherwise in
a westerly direction. The ground water migrates laterally in the
upper till at a rate of approximately 7 ft/yr. A vertical ground
water migration rate of 0.8 feet per year is considered
representative of the upper glacial till. Vertical migration is
impeded by low permeability clay zones between the shallow and
intermediate zones. The intermediate ground water migrates
primarily to the northwest and west. A lateral migration rate of
2 ft/yr is considered represe~tative of this zone.
Lateral ground water migration in the lower glacial till is
considered to be negligible due to the over consolidated nature of
the clay till and the low frequency of permeable zones.
The bedrock aquifer is part of the regional ground water flow
system. Lateral ground water migration is to the northwest toward
regional surface water drainage systems such as the west branch of
Swartz Creek and the Flint River. A lateral migration rate of
approximately 20 ft/yr is representative of the bedrock aquifer.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Berlin and Farro Liquid Incineration, Inc. began operations at the
site in April, 1971. The facility was permitted to accept
industrial waste for incineration, to store waste prior to
incineration, and to operate an on-site 1.1 acre landfill for
disposal of crushed used drums. Numerous violations of permit
requirements were cited during the period of operation, until
September 1975 when Berlin and Farro lost its operating permit for
the incinerator. Permit violations included failure to comply with
air emission standards and on-site storage volume 1 imi ts, and
failure. to meet permit standards prohibiting on-site disposal of
wastes other than solid wastes. The facility also operated two
unauthorized waste storage lagoons and two unlined storage lagoons,
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5
"
operated underground storage tanks, poured, 1 iquid wastes into
subsurface agricultural drains and dumped thousands of gallons of
barrelled wastes into two pits. These permit violations and
unpermitted activities led to the revocation of Berlin and Farro's
incinerator and landfill permits on September 16, 1975.
From 1975 until 1978, while the permit revocations were under
appeal, Berlin and Farro was permitted by the State of Michigan
("state") to transport industrial wastes for other generators, but
not to transport wastes to its own site. Michigan Department of
Natural Resources ("MDNR") investigations indicated that illegal
dumping of industrial wastes into the lagoons apparently continued
after ,1975. In 1978, Berlin and Farro's appeal of its permit
revocation failed.
Limited cleanup activities were conducted by Berlin and Farro under
a plan submitted to MDNR from 1978 until 1980, when Berlin and
Farro filed for Chapter 11 Bankruptcy.
In 1978 and 1981, ownership of the property was transferred to the
State for nonpayment of property taxes. Ten acres of the site
remain under the jurisdiction of the Genesee County Circuit Court
as a result of a lawsuit filed by the state. The site was placed
on the National Priorities List on September 8, 1983 and ranked
number 13 on that list (48 Fed. Reg. 40658).
The United States Environmental Protection Agency ("U. S. EPA")
identified over 125 generators through review of site records. u.S.
EPA, the State, and certain settling Potentially Responsible
Parties (IPRPs") undertook surface cleanup actions intermittently
from December 1981 through October 1984. Primary remediation
activities through 1984 included:
o
fencing of the site,
o
removal of north and south lagoon sludges,
backfill of north lagoon and part of the south lagoon,
o
o
removal of the incinerator facility,
o
construction of the east and west settling ponds,
removal of 5 underground tanks,
o
o
removal of drums and buried drums from the old drum
landfill and two small nearby drum burial areas,
"
o
backfilling of the old drum landfill,
o
excavation and removal of the N-S agricultural drain and
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6
..
removal of surface debris, drums, waste piles and soils,
..
removal and disposal of over 1 million gallons of
contaminated water recovered during remedial operations,
,
J
o
performance of a hydrogeologic study, and
performance of a Focused Feasibility study of soil
contamination.
o
In April 1981, the facility was declared a toxic substances
emergency site by the State Toxic Substance Control Commission.
The Michigan state Legislature subsequently appropriated funds to
continue cleanup at the site. By December 1981 the State had
removed 15,300 cubic yards of lagoon sludge contaminated primarily
with hexachlorocyclopentadiene (C-56) waste to off-site disposal
facilities. .
Because MDNR's funding for the project was exhausted, in June and
July 1982, U.S. EPA performed an emergency response action at the
site. At that time, U.S. EPA installed a fence around the
property, and excavated and removed approximately 30 drums that
were not secured in the landfill.
In October 1982, MDNR removed five tanks containing approximately
10,000 gallons of liquid waste, and removed 580 cubic yards of
contaminated soil and began a hydrogeologic study under a Superfund
cooperative agreement. Beginning in April, 1983, the State resumed
its activities at the site under order of the Genesee County
Circuit Court. The State treated storm water runoff from the site
and continued excavation and off-site disposal of drums from the
landfill, and of contaminated soils, lagoon liquids and sludges,
and debris. Approximately 18,000 cubic yards of contaminated soils
were shipped off site and approximately 4,000 drums were excavated
and characterized. The drums contained, among other hazardous
substances, C-series chlorinated organic compounds, polychlorinated
biphenyls (PCBs), benzene and ethylbenzene. .
In August 1983, MDNR again exhausted its funding for the site while
it was still in the middle of its cleanup activities. At that
point, MDNR had excavated, but not yet disposed of, roughly 4,000
drums containing hazardous liquids, solids and sludges from the
landfill. Because many of the drums were bulging or leaking, and
contained highly flammable toxic substances, U.S. EPA performed
another emergency resporise action to stabilize the materials and
complete safe disposal of these wastes. This removal action took
place between August 29 and October 28, 1983.
On March 22, 1984, a group of PRPs agreed to perform a voluntary
partial cleanup, under an agreed work plan, which was based in
large part on the U.S. EPA's August 31, 1983 Focused Feasibility
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7
by 87 PRPs, which was entered on March 14, 1985, after the partial
surface cleanup had been completed. Under the work plan, the PRPs
removed solid waste, liquid waste and contaminated soil from the
drum landfilli removed waste and contaminated soil from the paint
sludge trenchi removed waste and contaminated soils from the
agricultural drains i removed some of the piles of soil contaminated
withC-series wastei and removed waste and contaminated soil from
several identified hot spots. Under the agreement the PRPs also
reimbursed U.s. EPA and the state of Michigan for a portion of past
costs incurred up to that time. .
The PRP-financed cleanup removed more than one million gallons of
liquid waste and 75,000 tons of orums and contaminated surface
soils and soil piles from several areas. The cleanup activities
ended in October 1984. .
Pursuant to a consent-Decree signed in January 1986 and entered
June 5, 1986, a group of 77 PRPs agreed to perform the Remedial
Investigation/Feasibility study (RI/FS) for the Berlin and Farro
site. The RI/FS was intended to quantify through field sampling
and analysis the residual contamination at the site and to identify
appropriate remedial alternatives.
. .
Most of the wastes originally disposed of at the site were removed
during the above response actions. constituents remain in site
media but no previously unknown waste disposal areas have been
identified on-site during the RI. The RI conducted for the site
was initiated in March 1986 and continued intermittently through
January 1989. A post-screening investigation (PSI) was initiated
in October 1988 to obtain additional data for the FS detailed
analysis. The PSI was essentially complete as of April 1989.
PRPs who performed response work at the site, and additional PRPs
identified by U.S. EPA, were sent a general notice letter on July
20, 1990. That letter indicated, among other things, that a period
of negotiations concerning the remedy to be performed at the site
was initiated, as required by the 1986 RI/FS consent decree. That
period was extended, pursuant to court order, into January 1991.
III.
COMMUNITY RELATIONS HISTORY
..
A Proposed Plan for this remedial alternative was released July 11,
1991. This documents and all supporting documents are available to
the public in the administrative record maintained in the U. S. EPA
Docket Room in Region 5 the information repositories at the Swartz
Creek Public Library in Lansing, Michigan and the Gaines Township
Hall. The notice of availability for the Proposed' Plan was
published in the Flint Journal on July 8, 1991. A sixty day public
comment period was held from July 11, 1991 through September 9,
1991. In addition, a public meeting was held on August 8, 1991.
At this meeting, representatives of the u.S. EPA and MDNR answered
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.
,.
8
under consideration and accepted formal comments from the Public
regarding the proposed alternative and other alternatives analyzed
in the FS. A response to these comments and to written comments
received during the comment period is included in the
Responsiveness Summary, which is part of this Record of Decision.
This decision document presents the selected remedial action for
the Berlin and Farro site, in Swartz Creek, Michigan.
The RI/FS Report and a Proposed Plan for the Berlin and Farro site
were previously released to the public on July 20, 1990. A fact
sheet summarizing this Proposed Plan and remedial alternatives was
released to the public on August 2, 1990. These documents were
made available to the public in both the administrative record and
the information repository maintained in the EPA Docket Room in
Region 5, at the Perkins Public Library in Swartz Creek, Michigan,
and at the Gaines Township Hall. The notice of availability for
the RI/FS Report and the Proposed Plan was published in the Flint
Journal on July 20, 1990. A sixty day public comment period was
held from July 20, 1990 through September 19, 1990. On September
7, 1990 U.S. EPA sent a letter to all persons on the site mailing
list informing them about a change in its preference among the
various alternatives under consideration, subject to review of
public comments.
\J
In addition, public meetings were held on August 9 and September
12, 1990. At these meetings, representatives from EPA and the MDNR
discussed the Proposed Plan and answered questions about conditions
at the site and about the remedial alternatives under
consideration. A response to the comments received during this
comment period are included in the Responsiveness Summary, which is
part of the Record of Decision.
At the start of the 1990 public comment period, U.S. EPA proposed
a remedial alternative which addressed both groundwater and soil
contamination at the Berlin and Farro Liquid Incineration site
("Berlin and Farro"), Swartz Creek, Michigan. The alternative, as
specified in the proposed plan, called for on-site incineration of
contaminated soils and for the extraction of contaminated
groundwater with treatment via air stripping. On-site incineration
was projected to last for approximately 1 year and extraction and
treatment of the groundwater was projected to last for at least 30
years. In addition, the Berlin and Farro proposed plan required
groundwater monitoring and long-term maintenance of the air
stripper. .
Initial written comments received by the U.S. EPA and those voiced
at the August 9, 1990 public meeting in Swartz Creek left no doubt
that most concerned members of the public were strongly opposed to
on-site incineration.
d
The strong opposition to the proposed plan expressed early in the
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9
.
meeting, led the U. S. EPA and the MDNR to alter the preferred soil
cleanup plan. This opposition was based on the short term risk
presented by the estimated 380 days of operation of the on-site
incinerator. In addition, information was provided indicating that
much of the volume of soil proposed to be remediated was to be
treated based only on metals contamination. Incineration is not
generally considered an effective treatment for metals, and in
fact, may produce treatment residuals that could require
significant additional treatment. The new plan called for the
removal of excavated soils to a licensed off-site facility for
treatment and disposal. This plan retained the use of an air
stripper for treatment of contaminated groundwater.
A second public meeting was held on september 12, 1990. At this
meeting representatives from U.S. EPA and MDNR discussed the
changes that the Agencies were considering based on public comment.
During this 1990 pu~ic comment period U. S. EPA continued
negotiations with potentially responsible parties (UPRPSU)
regarding cleanup options at Berlin and Farro as required under the
terms of the RI/FS Consent Decree (UDecreeU). U. S. EPA made it
clear that at the end of the public comment period, following
response to all comments, the terms of the Decree would be met and
it intended to sign a ROD as early as the last week of September
1990. PRPs filed for and were granted an order which enjoined the
U. s. EPA from issuing a ROD as planned. The Court ruled on
September 27, 1990 that terms of the Decree would not be fulfilled,
and a ROD could not be issued, until an additional sixty day period
of negotiations had been held.
. .
U.S. EPA and MDNR determined, based on information developed and
clarified during these extended negotiations that a remedial
action to address soil contamination other. than the previously
proposed options is most appropriate for Berlin and Farro.
This Record of Decision (ROD) presents the selected remedial action
for the Berlin and Farro site, in swartz Creek, Michigan based on
the Agencies response to public concerns expressed. during the
comment period. The selected remedial action will be chosen in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amenoed by the
Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to
the extent practicable, the National oil and Hazardous Substances
Pollution Contingency Plan (NCP). The decision for this site is
based on the administrative record.
IV. SCOPE AND ROLE OF REMEDIAL ACTIVITIES
This ROD addresses the final remedy for treatment of sediment,
soil, surface water, and ground water contamination at the Berlin
and Farro site. The principal remaining threats at the site are
considered to be the contaminated soil, sediments and contaminated
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10
The selected remedial alternative will address all remaining
principal threats at the site. Remaining concerns to be addressed
by the remedy include contamination in on-site surface water and
shallow ground water (through collection and treatment) and six
general areas where significant soil and sediment contamination
exists (through excavation and disposal). The four areas
containing contaminated soils of concern are: the central site
area; the former metal hydroxide ponds, the south transportation
area, and the old drum landfill area. The two areas containing
. contaminated sediments of concern are: the on-site drainage ditch
and ponds, and Slocum Drain (see Figures 3 and 4).
The final remedy for the site is intended to address the entire
site with respect to the threats to human health and the.
environment indicated in the site risk assessment. The findings of
the risk .assessment are included in the RI/FS Report and are
summarized in a later section of this ROD.
v
v.
SUMMARY OF SITE CHARACTERISTICS
Residual levels of contaminants were detected in on-site soils.
Locations of soil with residual constituents are linked to prior
site disposal areas and activities. Site related constituents in
soil primarily include hexachlorobenzene (C66), volatile organic
compounds (VOCs), other semi-volatile organic compounds and to a
limited extent, metals. C-6~ and other C-series compounds are
generally in the upper 5 feet of soil. The lateral extent of the
C-series compound contamination is shown in figure 3. VOCs
generally occur in the upper 10 feet of soil near the old site
operation areas. Soils along the south transportation route showed
the greatest number of metals above background levels. Soil
analyses are summarized in Table 1-2.
Additional investigation was conducted to assess the
characteristics and extent of soil contamination in the former
metal hydroxide settling ponds. Several test pits were excavated
and soil samples were collected and analyzed. These data were used
to determine the total lateral extent of soil contamination.
site-related constituents are present in sediments in drainageways
and ponded water areas. Sediment constituents are similar to soil
constituents. The extent of C-58 and C-66 in sediments is shown in
figure 4. VOCs and metals are also present in the sediments but
are less widespread than in the soils. Sediment analyses are
presented in Table 1-3.
Site related organic constituents are present in shallow zone
ground water in isolated sandy zones in locations near old
facilities and within the upper 18 feet of the soil profile. No
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FEAsmlllTY STUO't
BERlIN AND FAnno AI , FS
ESIIMA'EI> EX1["r OF
C-SEnq:s lNOlCAron
COMPOUNDS IN SEDIMENTS
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('
-0 Draft kiln. ...ro n
O SectIon I
Rewl.lon I
00 Zl O~mber I,.,
~~ 'ale I 01) !
90 TAIBIZ 1-2
ZC SU"'MARY 01' SOIL ANALYSES
);>)>
.e:
=
-------
Consdtuentl
Semi-YoIatile OrpnICI (cant.
Benzoic Add
But,benz,lphthal...
Chr,sene
Dlbenzo'uran
1.2-DlcHorobenzene
I,J-Dlchlorobenzene
DI-n-8ut,lphthalate
DI-n-Oc:t,lphthalate
811(2-£ th,lhe.,I) Phthalate
Fluorentllene
Fluorene
~ Ii HeuchlorobenzeneCCU)
HeucHorobutadiene(C")
He.echioroqdopentadleM(C")
2-Methylnapthalene
Nepthalene
Octadlloroqdopenteneec,a)
Phenanthrene
P"ene
~;
'""
o
09,
?Z
0Q.
r-/ C
t- ~
,~. 7
, r-'
&- -'
-.,
..
Cent"" Site ,,~.
Ranie in Hit
I Hlt.l Conttntratlon
, AnaI...-. ~
TA8U! 1-2
SUMMARY OP SOIL ANALYSES
, Hltsf
, Anal,,"
Old Drum Landfill A~.
Raft8te in "I'
Concrntration
~
, Hltsf
, Analpes
Main Site ,,~.
Ranae In Hit
Concrntr8tion
i!Jl!c,d
2/17 1'23-1,900 NT 0/'
2/17 2JOJ-,.I008 NT II'
1'17 1973 NT 0/'
1'17 II OJ NT 0/'
1'17 101J NT 0/'
1'17 I.~ NT 0/'
./17 27738-1.'00 NT 2/'
2/17 ))0-1.'00 NT 0/'
7'17 8)3-1.700 NT ,/,
1/17 19&3 NT 0/'
1'17 1703 NT 0/'
. -I.'
'/17 104.900 " '. . NT 0/'
1'17 1.,3 NT 0/'
1/17 2.000 NT 0/'
2/17 )23-1,200 NT 0/'
2/17 '73-'.700 NT 0/'
1'17 1'.'00 NT 0/'
2/17 10U-"0 NT 0/'
1/17 ,9OJ NT 0/'
In
.oo-t JO
IIOJ-IIOO
Dra.e 8«lIn 6: F.ro n
Section 1
Re..I.lon .
2Z December ".,
Pale Z 0' )
. .
. .
.
~
Ranae In Hit
I Hlesf ConcrntratJon
, Analpet ~
01'
0/'
0/'
0/'
0/'
0/'
0/'
0"
2/'
0/'
0/'
0/'
0/'
0/'
0/'
0/'
I"
0/'
0"
"-"0
.,
-
-------
COMdtUfftb
"~"''''nor~
Aluminum
Arwnlc
8arl.....
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manlanne
Mft'C\II"
Nickel
~I~um
511.~
Thallium
Yanaell.....
Zinc
C,anl.
!!m!1
, ."'t7
0/0
AlO
_;;0
£10
Zc
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Dralt 8~lIn . '.ro n
5KUon I
R~.lslOft ..
22 ~mber I,.,
Pal~ , 01 ,
TA8Le 1-2
SUMMARY OP SOIL ANAL no
. I
Centr81 SI~ A~a
Ran1~ in Hit
c.-nlration
~
Old Dnn LanclllII A~a
RanKe T.;"Hlt
Conttnl..lion
~
MaIn Site Area
R.. In Hit
Conc:rntntlon
1!!!rl!!d
~
R.,. In Hit
I Hltll Conc:rntntlon
'AnalY'" ~
I Hlul
, AnaI~
, Hltll
, Analwws
, Hltll
I AnaI~
17/17 1,700-2',200 NT
16117 '.'~I }C.>.L. NT
17/17 "-17' NT
1/17 1.1 NT
1"17 """ NT
16117 2-lt NT
17/17 ..,-n NT
17/17 7,100-2Y,'4J0 NT
~0/17 ,.J-..I ~l NT
.7/17 I "~Ol NT
0/17 NT
17/17 I.I-U NT
0/17 NT
1/17 1.1-202 NT
0/17 NT
17/17 10-110 NT
17/17 . 20-220 NT
7/17 0.22-'.7 NT
," ',200-',270 ",
,,, '.1-1.7 ",
"~ "-1" ",
0/' 0/'
JI, 10-27 ",
,,, ).1-7.t ,,,
,,, II-It ,"~
,,, 12,JOo-20,]OO ",
J/, ).7-lt ,,,
,,, JOW20 ,,,
0/' ,"
,,, '.1-)1 ",
0/' ,,,
II' I" 0"
0/' 0'"
,,, 22-" ",
,,, 17-" ",
0/' . 0"
..
,
-
1,170-1",000
'.2-M
82-1)1
10-17
, U-IJ
7.2-10
1'''00-22,100
'.'-17
21'-'"
0.02l~.Mt
7.]-lt
0.2~.'10
2t-"
,,-111
See Append1. L 0' the RI and the 5uppl~mental RI lor complete data IllIlnl
8 0nI, r~lult. Irom "CC Haurdoua Substance Lbt teltinllnciudedJ taraet screenl not Included.
NT Not telt~d.
Not detKeeL
J Indlcatel an e.tlmated ..Iue. Uwd either wilen ettlmatlnl a concentration lor tentadyel, ldentilled compoundlwhere a III ratio It allUlMcI, or when the
man lpectral data IndlC8t~1 the prewnce o' . compound .hft'~ lhe ~Iult II 1"1 lhan lhe delKIlon 1I",lt but I~at~ than Zero.
8 The anal,te II .ound In the blank al .~II a. the sample and thUt Indicate. ponlble blank cvntamlnatlon.
Central 51t8 Area Include- 580)0, 580n, 580)), 51\0", 5807288,5807'",58''' (' 'd, 5809t (20 18)88,58"',580",58~1 (2 't)88, 58"1
() 11),580" (I 11)",580')') (20 11),580" (U 11)",58100,58101 (J 11)",58101 (7 It), 58102 U It" 58102 (6 II',
5810J U It', 5810' (t Id, 581" U It', 5810t (12 It) 'or YOI'.
8 85YO", pe9tlddr' and metall not completed.
M81n Site Ar~8Indude- 580n, S80n. 58082 (29 It)U, 58012 (n It) lor YOI'.
Old Drum LandlUI Area andude- 58077"
-------
, . ..
Dr.lt 8erlln . F..,. n I
SKtlon I ,
Rewilion I \
/ .-0 22 December "It
08 P.. I 01 ,
TABLe I.'
~;;o
Qo SUMMARY 01' seDIMENT A"ALYSI!S
.2:: c:
):.. ~:~ 0thI!r
r- Qt.Slte Ponds Ot-Slte a..... Ofl~ltePond "1nornta
SIocUIII Oraln a DII~I - SlIe M.IhL.A~~ a Dit~!- 1CImb8l1 DnIRt- ~-
."'<, RanKe RAn«e ltanr.r. It",,«e It-Ite ItM1lte
In Hit In llit In lilt In lIit In Hit In Hit
ConceIt- (Anc:eft- CGnorn- (Anc:eft- ~ ~
, HIts! .atlon , IUts! .atlon , HIts! .atlon , HIts! Iratlon , Hlul .at.. 'HI- ..tkIn
CAlnstltvenb 'AnelP"!. ~ ' Anal,teS ~ , Anal,teS ~ , Anal~ ~ , "nel~ ~ , Anel~ ~
Volat11e 0rJ.~
Acetone 1/" 1)1 0/' 0/' 0/' 0/7 0/2 .
Benzene 1/" ,:I 1/. J:I 0/' 0/' 0/7 0/2
2-8utanone 2/" 1':1 0/1 0/' 0/' 0/7 0/2
Carbon Disulfide 1/" 27 0/1 0/' 0/' 0/7 . 0/2
Chlorobenzene 0/" 1/1 190 0/' 0/' 0/7 0/2
Chloro'Of'm 0/" 0/. 0/' 1/' ,1:1 0/7 0/2
Chloromethane 0/" 0/1 1/' I)] 0/' 0/7 .' 0/2
Trens-I,2-Dlchloroethene 0/1' 1/1 ' 0" 0/' 0/7 . 0/2
I.I-Dlchloroethane 0/1) 2/1 '-7 0/' 0/' 0/7 . 0/2
1,2-Dlchloroethane 0/1) 1/1 7 0/' 0/' 0/7 0/2
-------
.
TABLe 8-'
SUMMARY OF seDIMENT A"AL Y5e5
Or.,. Berlin a ,.... n
SectlOft 8
R..I,IOft I
22DKem_lm
P... 2 01 .
~
0ft.S1~ Ponds o....sl~ A N~ar or'-Slte Ponds YInmnt a
51oo1m Dr.1n A Dltdlr.s Sit. Mush, I\~ A mtettes KImbell Or.'" ~M8Id-
R~ R.vtft~ Ranlt~ Ranlt~ Rii;; R~
In Hit In lilt In lIit In Hit In III t In Hit
c-c- Conc'II'n- c-c- c-c- eanc:-- c.nc-.
, Hltt/ tr.t. , Hitsl trat. , Hit" tratlon , Hittl trat. ,Hltt/ ..tIon 'HI'" .atlon
, A..I"",, Hl!!d , "..I,.. ~ , A..I"e8 BI!d 'A..I,.. ~ , A..I,.. Rl!!d 'A..I,.. .Hl!!d
CcJnstltuenu
SemI-YoIatl~ (qenla (con".
I,'-Dlchlorobenzene 0/.,
I,t-Dlchlorobenzene 0/"
Dlethylphthall'e 1/.,
DI-n-8utylphthll." '/1'
DI-n-Octyiphthill" 0/.,
BIs(2-ethylheayl)ph"""" ""
Pluorenthene 0/.,
Phenanthrene 0/"
'pyrene 0/"
'Pentlchlorophenol .81.,
Oct.chlorocyclopentene(C'I) "1'
'H...chlorobenzene(~) loll'
'.
PfltIcWrt
''''-00£
''''-DDT
0/"
0/1'
-c
o
00
?O~
90
zc
~>
rC
-I
-<
'.,00
120-1,&00
110-2,-
1,c00
&0-2,,00
"J-II,UD
1/'
1/.
0/.
0/.
0/.
0/.
1/.
1/.
1/.
01.
1/.
1/1
0/.
oil
7 ,'"
I ,7'OJ
',7'0
l,nOJ
',t)O
",000
'IJ-I2,ooo
0/' 0/'
0/' 0/'
0/' 0/'
0/' 2/'
0/' 0/'
01' ",
01' 0/'
0/' 0/'
0/' 0/'
0/' 0/'
0/' ..' 0/'
1/' J7J '"
I"-IIOJ
'90-1',0008
2IJ-15J .
0/'
01'
II'
1/'
U
71
017 012
017 . 0/2
217 ltO'-I,&OO 0/2
117 1,200 0/2
1/7 200J 0/2
2/7 "'-'70 012
1/7 '1' 1/2 'IOJ
0/7 . ,'t
017 . 1/2 t7IJ
0/7 . "2
0/7 . 0/2
1/7 21 "2
0/7
0/7
.
0/2
0/2
<:
I'
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I
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i
I
"
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I.
I
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,.
,
,
I
i
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.
-------
Conttltufllb
~talt/Inar~'"
Aluminum
Antlmon,
Arleftlc
Barium
B~r,lIIu",
Cadmium
Chromlunt
Cobalt
C~
Iron
bad
ManiaMIe
Muc:ur,
N Iclc~1
~I~nlunt
511.er
Th8l11um
\J
08
~7V
C) ()
zc.
»»
.-e:
-,
or.'t RerUn. '81f8 FS .
~_IOft 1
R~.I.IOft I
JZ ~mW I,.,
'..Jol.
TABU! 1-'
SUMMAR Y OF SEDIMEHf AHAL YSI!5
~
~I" Pondl o...sl.. a ...... OI...sUe PGnch YIncent a
5..... Dr.I~ a DltdIf"~ 51te M.th, I\n~ Dlh:hr. IUmMll Dr.~ ..--~-
It 1If'Itt! It~ R_It" ~ It8nKe Rartlt!
In Hit In tlit In Hit in tilt In Ilit In lilt
~ Canor.n- ~ ec.nc-- ~ c:-c:.--
'Hittl tn-.. , HIW ..-.. '"Itl/ er.-. 'HlW ..-.. ,HlW ..-.. , HI'" .._..
I AnaIP"!. JmII'W , Anal~ 'pa/lcd 'A..lpes ~ , "..I~ lma/1cd , Anal~ l~ I AMI,," ~
"'" "tlo-t7,loa .,, 11,100-t7 poo '"~ ',lto-19,2OO '"~ ',MO-I7,200 '17 2,220-11,JOG 2/2 2,JJO-10,700
I/n I.J 0/' t/' "'-1.1 0/' 117 1.&1 0/2
II/n U-t9 .,, t.5-,.' ," 1.'-'" '"~ ,-'-., ~'17 Ie&-" 2/2 ...".,
It/n "-Jlo ./. 7)-170 ," '7-110 '" "-100 717 ,..IJO 2/t 2'-1)0
0/., 1/. 1.0 aI, a" 017 0/2
J'IJ o.7"-JO 2/. 1.1-'" t/, 0.2U.CUIJ 0/' 117 0-'12 0/2
IJ/IJ 7.I-JUR 1/. 2O-7J ", II-JJ ,"~ II-JJ '17 '.7-17 2/2 '.2-27
n/n '-lJ 1'1 '.2-1' ", t.2-1.7 ," t.'-'.' J17 2-'-).1 1/2 ..,
n/IJ '-7"8' 1'1 "-I to ", '.'-21 ." '.7-U 717 '.'-19 2/2 t.2-I1
n/" 1,I00-"1,aao 1/. 1.,2OO-Jl,2OO ", ',010-21,'00 ," .,JIO-2I,loo '17 '."'-12,JOO 2/2 ''''0-85,100
Itll' '-'-II 1'1 ,.," I '"~ ..'-11. ," ,-t, '17 '.7-10 1/2 10.'
n/n Ilt-t,JlO ./1 1'0.-'0 '" .J-no ", "-)70 '17 "-J77 2/2 "J-22 I
J/n 0.0)-0.07) 0/. 2/' 0.027-0.0' 0/' 117 OAt' 0/2
"'I) '-'-2" ./. II'" ,,, 12"" ," , .t-28 '17 U-" 2/2 '.2-1'
J/IJ I -'-t.' 0/' t/, o.u-O.n 0/' 117 0.'. 0/2
I/IJ 1~lO .0/. 2/' 1,,"-1"'0 0/' 1/7 I.IJO 0/2
-------
QInIt~
Metall/lnort."" (cont'd)
Slocum Drain
~~
In iii t
. eo.--
, tnnl .allon
, Analpn! Jma/8cd
Tin
Vanadium
Zinc
CJanide
I/n
II/I'
n/I)
'/1'
2.1
'.2-"
"-1,100
0.22-"
TARL~ 1-'
SUMMAR Y OF 5eOlMeNT ANAL YSI!5
o.slte Punch
a Olt~I
"~e
In lIit
c:o.-n-
, Hltsl .allon
, Anal,.. !m.,.d
o...5lt11! . Nf'..8r
511e Man"r A_r!,~
R~nr.f!
In lilt
c:o.-n-
I tnttl ..tlon
I Anal"es ~
0/1
1/1
1/1
'/1
2/'
'"~
'"~
2"
).0-'-'
1'-"
"-I"
O.ZZ-O.'
Other
Off-Slte rnnds
Oltc:lt!!-
~,,«e
In llit
ec-:-
I HlnI tratlon
I Anal,.. ~
,
0"
",
",
0/'
10--'
"-200
Ylnmnt.
Kimball Dral",
R~
In lilt
CcInotn-
, HIts! .atlon
, Anal~ 1....Jk8J
1/7
7/7
7/7
2/7
2.oJ
"-'1
2'-9)
0."-1.1
Ora" 8...lIn . Farro '5
Secllon I
R~.I.lon I
21 ~c~mber I'.,
Pale' 01 ,
~-
R.an«e
In flit
eonc--
, HI'" ...allon
, Anal,," ~
0/2
2/2
2/2
0/2
11-)7
"-71
JI-"
U-2.o
1.1-'-'
~
Sre Appendll L o' the Itl and the Supplemental Rllor Complete Oata LI.tlns
. . Onl, re"'''1 from HaurdDu. Sub,tance U,t testlnalncluded, tarlet screens not Included.
R . Indicate, .plke IImple recO'ler, II not within cantroillmits.
NT. Not Te.ted.
-. Not ~tected.
. .
B . Anal,te I. found In blank a. wll a. the IImple. Indicate' poulble blank contamination.
J. Indicate. an e.tlmated nlue. Uwd either .hen eltlmatl"l a concentntlon lor tentatlyel, ldentilled compound. where 8 hi ratio I. .'lUmed, or when the
man .peetral datA Indlcatrl the pr~wnce o' . compoUnd where the rr",lt II letS than the detection limit but Kreater than zero.
Slocum Drain Aru Include.. 5E0002, Go,, oo:m. 00', 00', 012. 072, Ol9, 0)0, 0)00,0'1, OJ 10, and 0)).
On-Site rond. and Dllchel Include.. Sl!DOII, 019.020,021,021,02',02'0. and 02'.
On-Slle and Ne., 511e Marth, Area Include". 51!DOI', OUt 027. 0,.. and "'0.
OIl-SIt~ Pond. and Oltche.lnclude.. 5EOOl), OIJO. 0", 016. and 017.
Vincent and Kimball Drain. Includel 5EOOO', 007,008,009,010, Oil, and 0J2.
-------
~
'. br." Berlin' ,... FS
Section I L
R"lslGft I
ZZ Decembet ...t .
--0 P... , 01 Z ;~
o
00 TA8U! 1-'
~~
£10 SUMMARY ()P CROUND WAftR ANAL Y5I!S
~~
c: North c-tral 0thK Site 8ftII
-) Old nn.n IAnclftIl SUe A~a Hrar Site A~ ~ ~
-<:. !CI8d8I Zane~ jC1ae1al lane,} tC1ae1a1 A Bedr'odt z-II Claclal 8eckodc
Il8n&e In . Ilanlte In 1l8n~ In -~... ~...
lilt lilt lIit ftlt lilt
Concen- ~ Conc:Jftt- ~ ~
, "ihi ...tlon , "I'" ..atlon , IIlhI ....Ion , "IW . .etlon , HI'" .etlGn
CoMtltuenb , A..IY'd!. i'JIl!l ' A..I~ !!Il!l ' A..I~ Srl!l , 1'..1.- 1!Il!l , A..I~ Hm
Yolatlle ~
Acet- ,/)2 '2-210 0/7 0/.' 0/' 0/'
8enzene ,/)2 22-1' "7 120-1'0 0/.9 0/' . 0/'
2-8utanone 1/'2 I' 0/7 0/.9 0/' 0/'
Chloroethane 0/)2 2/7 91-1'0 1/89 12 0/' 0/'
Chloroform 0/'2 0/7 ".9 1-)2 0/' . 0/.
T,ans-I,2-0IchIOl'oethene (IDe!) 12/)2 '-1700 0/7 0/.9 0/' . 0/'
I,I-Dlchloroethene eoce) "J2 17-120 0/7 0/.9 0/' 0/'
1,l-DlchloroethaM 9/J2 12-" 0/7 0/.9 0/' . 0/.
1,2-Dlchloroeth8n8 "J2 22-122 0/7 0/.9 0/' . 0/.
ethylbenzene J/J2 "-77 0/7 0/.' 0/' 0/'
2-He.anone 0/12 0/7 0/89 0/' . 0/.
Methylene Chloride 6"2 U-IU z/7 22 0/" 0/' . 0/.
Tetrachloroethene (pC!) 0/J2 0/7 . 0/.' 0/' 0/'
Toluene "J2 '20-1,200 0/7 0/.' 0/' 0/.
Vln,1 Chloride 7/J2 23-I,too 0/7 0/89 0/' . 0/'
Totel X,lene. 0/'2 0/7 0/.' 0/' . 0"
,",,1-YoI8U,"
DI-n-8utylphth8la.. "21 1J-9J 0/' 0/89 0" . 0/2 .
81t(Z..e th,Ihe.,IJphtha18.. o/ZI 0/' 0/89 0/' . '1/2 1-"
-------
Dr.lt Ber"" . P.. J
S~tlon I
"0 RnlllC118 I '~
() 22 December I,., I
, (:') . P.p 2 01 Z.
- "'~ TABle I'"
.; ","
'\"0 SUMMARY 01' CROUND WAnR ANAL no
.." C
.. I
,f
£... ~ North Crntral Ot'- SIff! aM
~r-:
~ Old nn- Landfill 511~ ",,,. H"a, Sll~ ",,,. Bac:tranund 8adIan-d
~ (CI8c181 Z_s) (Clacial Z~.J (CIac181 81 ~~_CI!'!.!I Cl8clal Bedrock
R~~ In ltan"f'I" Ran"" in -~.. -A.8ttte ..
Ilit lIit llit Hit flit
~ C~ c:onc-- ~ ConoM-
, HlhI trat- , Hlttf tr. t ICII8 , Hltt! tra'lCII8 , HI'" ........ IHihI ...a '1CII8
CoMtltumb I An8ly~ ~ , ANilpn ~ I Analpn J!!!Jl!I I AnalPd !!!!1m , Analywt 1!!!Il!l
...I.JItwx..8IIk:I
Aluminum ,'n 0.1I7-1."R 71' 0.'1'-0.902 19/.7 O.I"-'.H 71' O.77-U 0/'
Ar~lc ",n O.ool-O.OJ 71' 0.01'-0.01' n/.7 0.00'-0.0" J/' O.olt-o.o'l ," 0.07'-0.077
Barium 17/n O.I-O-'U '" 0.1'1-1.1 "'.7 0.100-0.'" ", 0.)11-1.1)' '" O.II'-o.JlO
C.dmlum ,'n 0.00022-0.00' II' 0.007 7/17 0.002'-0.00" 0/' 0/'
Chromium ,'n 0.010-0.0,. 0/' 12/.7 O.OIl-o.'JO 0/' II' 0.012
Cobalt oln 0/' "17 0.021-0.0)) 0/' . 0/'
Copper 1/2' 0.0" II' O.OlJ 0/.7 0/' 0/'
IrC118 17/2' 0."''''.' ," 0.0"-'." n/.7 0.0"-'.01 '" 0.0)0-2.0' '" 0.17'-0.1'0
Le.d 1/2' 0.00 I 0/' 1'7' 0.00' II' 0.0" II' 0.00'
M8"1.MIe 2"2' 0.011-0."0 "~I 0.0'7-1.1 ""7 0.010-1.1 '" 0.01'-0.0'1 '" 0.0"-0.051
Nlck~1 ,'n 0.022-0."1 ," 0.011-0.097 27/87 0.011-0-'90 II' 0.0" II' 0.027
SII"er 2/" 0.01)-0.0" 2/' 0.01)-0.0 It "'7 O.OII-o.ou 71' 0.012-0.01. 0/'
Zinc 7/2' O.on-O.IIO 2/' 0.02'-0.01) 20/17 0.012-0.2" II' 0.021 II' 0.7)0
NOTP-S,
S- Appendl. L o' t'" II .nd 1M 5dppletMnt.1 II 'or comp~te ... IIIlIn&.
8OnI, re.ultt 'rom heurdout tUbst.nee LI.. Te.tlnclnclu*ell"rpt ICI'Hft notlnd_d.
. . Not ~tKt~
, . lnellc:.t~. an mlm.~ ".Iue. Used either ....... e.llm.tlnK 8 canc:entr.tlon for tent.tI"el, Idrntlfl~ compoundl where . hi ,..10 I. ..1UIMd, or .tten the
mau ~',.I .ta lnella'e. the prewnce 0'. compound ..here the re.ult 1.k!1I than lhe det~tlon limit but ,re.ter than ,erGo
Olel Drum lanelflll Are. Include.. MWOl2, 021, on, 029, on, 0", O"D, H, "D,", U, ", ", JO, 'I
Nonh Cent,al Site Area Include. MWooI, "',0"
Other 5118 anel Nea, Site Are..lncl_.. MWOOJ,', J,', 7,',10, II, n, I', I', ", 17, I', I' 70,22, 2J, It, 2', 27, 71,)0, JI, n,JJ, »,)1. Jt. ".","
B8CkKround Clad.llncl_.. MW002," I. OU
B8clrlrouncl Bedrock Incl_1t MWOOI
-------
.
~.r, 8,,118 a,."."
SectlOll I
R~..lslOft I
2J ~umblr I,.,
'a,e I 01 J
.
"
TABU! 1-'
SUMMARY OF SURFAce .Anlt ANALYSU
CGnIdturn'.
On-Slte .ondI o...51te . ~- OII-SI~ .oneII YInmnI a
sa.- DraIn aDl'~- Slar Manlty A~ . Oltchrt 1t"",1 Dr""'- ...~--
R~ Ita~ It.n~ Ita. It.. It..
In Hi' In iii' In ..., In tti, In Hat In HI'
COftOl!lt8 eanc-- c-.. Cana!.... Caner.... eo.-....
, HI'" era''''' , HI'" era'''' , HI'" ...,.... , HI'" tra'. , HI,., ...,.... , HI'" ... ,...
f A"'~ i!Jl!l , A"'''' i!rl!J , A_yln .Bl!J , Anal... 1!IL!l 'AMI... Bm ,Anal... Mm
~a'lle COll8~
tr8nt-I.2-DlchI..,hene
''It
IJ-JO
Oil
0/'
01'
on
0/2
SetnI-YoI8tUe Or.-lcs
8ltU-eth,IMarIJph'h8la,. 1'1. " 2/1 IJ 1/' I' 1/'
Oct8ch1orocrclopen--CC'I. 2/.. o.I).O.IU III a.oJ-O.n 0/' 0/6
H~.ad"oroWnftne(C". "I. o.MoO." 7/1 0.16-1.6 0/. 0/6
Heaachloroe8h8ne Illt .)1 0/1 0/. 2/6
a-17
7J
IJ
2/7
017
0/7
J/7
1/1
0/2
0/2
a/I
.
.
,.,
1J.a
-c
0°
- 0
~;.v
C)o
Z C~
» »
r- ~:.::
-~
-<
-------
CGftlldturntl
M~taltll........CI
Aluminum
Antlmon,
An~nlc
88,lum
C8dmlum
Chromium
Cobalt
Copp«
Iron
L~8d
"8nI8..
M«cur,
Nldlel
"
,0
00
22;;0
C).
-0
ZC
1>)>
.rr-
.'~
")
. .
Or.lt 1t,,11ft A '.r. PS
SKtlOtl I
RnlliOtlI
J1 Dt'umbtr Itlt
'.I~ 2 01 J
..
.
TAIIU 1-'
SUMMARY OF SURFACI! ."nR "NAL YSD
o.sl- 'ondl o.sl- . ~.. 0If.S1- 'Old y..... .
Slocum ~'!- . DII~' Si~ Menhr A..... .- . Dltc:fwo'- 1t.......IOnI... ~-
R.~ R.. R.n~ R... - Ii... R.,.
In llil In iii I In lilt In lIit In HII In lIit
Caner... Cena!... C-... c.nc-. ~ CGnortt-
I Hlttl tnt"'" , Hittl ....t.. , Hittl k.t"", , Hlttl t,.tiaft 'HI'" tnt'" , HI'" tnllan
I Ane1pet ~ , "MI,," ~ , "MI,," ~ , "Mlpes ~ , AIIIII... i!W!J , AMI,.. 1'!!Jl!J
II/lt o.em4.' &I. 1.III-M2 2/t 1.13 '" 0.1 JI-O.coc C/7 o.27,.2.J 1/2 t.77
2/.. 0.023 oIl 'II' o.on II' 0.0'13 117 0.0'1.1 012
"It 0.00'1-o.OK2 0/1 'II' 0.002J ", 0.00'1-0.02 717 0.0022-0.01. 112 1.001'
tilt 1.13-0.11' 7/1 0.1.0.82 'lIt O.IJ '" O.II~," 217 0.13-0.21 1/2 1.1"
2/lt 0.0013 oIl 2/. 0.0013 2/, 0.0013.0.'"'" 1/7 0.0013 012
"it 0.01-0.01' "1 0.1.0.027 'II' 1.01J-G.0It ", 0.01..0.0" 017 "2
2/lt O.OlJ oIl 2/' O.OlJ 2/' 0.02J-o.O' 1/7 0.022 0/2
lilt 0.023 2/1 0.012-0.01& 2/. 0.02J '" O.OlJ-O.o, 117 1.02.1 012 -.
12/lt 0.I&"'.2t "1 0.J02",." .,. I.J02-2.J2 '" 0.111-2.21 717 o.H-O.8 212 0."'-1.21
2/lt 0.002-0.002' oIl 2/. 0.002-0.00' ", 0.002-0.0" JI7 0.002-0.021 012
12/lt 0.0"-2." II. 0.011-0."1 .,. O.OII-o.On ", 0.0""-''' 717 0.0'11-0.171 212 0.0)7.0.'"
III' 0.0002' oil II. 0.000)2 0/' 117 O.GOO'lI .1/2 0.001'
-------
-0
o.
00
;0;0
QO
~~
r-t:
~
-<
Dr... Berlin. '8rf8 FS
S~tlon I
R..lslon I
2l o.c."'Mt I'" .
Pap) 01 )
I
'I
.,
TABle 1-'
SUMMARY Of'SURFACE WATER ANALYSES
c..tltutft'.
..~...",..pIIIa
S~lenlum
Silwer
Zinc
C,.....
On-SI~ PCIIIdI OIt-SI~ . N... 01'-51.. Ponch YInoMt 8:
SIoc:wII Dr~ . DU~!.- Site M_sh, Ar:w;~ a DltchP.~ It'''''IIJraI~- 88C.!tw..J4-
It~ It.. Rilnce Ita. R.. R..
In llit In lIit In lIit In llit In Hit In Hit
C----- c-or.. c-... Conomo ~ Cenortt-
, HltJ ...t'" , HI.., ....Ian , Hit" Intloft , HltJ tntlan 'HI'" ....... , HI'" tntlon
, AMlWRI t!Im , A-WRI i!!Jl!I , An8I,.. ~ , AMI... !!!!Il!J , AMI,.. i!!Jl!l. , AMlWRI J1!!JrL!I
JIlt o.oon 0'8 2/. 0.002J I" ..rAnJ .n 0.0022 012
I'" 0.0'1 018 0/. 0" On 1'2 .
I'lt '" 1'8 0.0" 2/. 0.277-0.28' ." 0.0""'.2' I" 1.2" 01J
"It 8.021-0.0" 0/8 2/. 0.012-0.0" "~I 0.01&-0.'" ,n "021-0.0" 1/2 0.0 It
~
See Ap~. L .f lhe RI end SuppletMft'" RI I. Complete Data Llltln,o
. . Not ~tect~d.
, J. IndlC8t~1 8ft ~.tlma~ ...IIIe. U~ either whe.. e,tl",atlnl . COMftIt,.t'" l.t...l.tl..l, ""tlrlecl compoundl wMn . 18. ntle It ....., ., wilen the
: malt 'peetral .t. Indlc:at~. the pretence .1 . compound where the ",""t 1,1", h.. the detection 1I",lt "'t ,....t« t"'" aero.
Slocum Drain A....Ind~ 5!OOO2. .." 00'0, oeM, "', 012, 022, 029, 0)0, OJOO, 0)1, OJID,.... 0)).'
~Slte Ponell ancI Oltdln Indude. 5£0018,019,020,021,02), on, 02tO,.'" 02&.
~Slt. and Ne_-SI.. Mar., A....lndudell S£OOI., 02', 027, 0,., end 0,.0.
Oft-Site Pondland Oltchellndudell SEOOI', OUO, 0", 01&, ."'017.
YI~nt and Kimball Dr.lrtl A....lndudel 5EDOO&, 007, 008, GOt, 010, 011 end 0)2.
eackaround A....Indudet8 5EOOOI,.nd 028.
of
-------
- --.. ----.-..-...... ...a
. -- .-..---- -.'.' .. --. -..... -
#. . --. .. ." .....
Draft Berlin and Farro FS
Section 1
Revision 1
22 December 1989
Page 1 of 1
TABLE 1~
SUMMARY OF RESIDENTIAL WELL ANALYSES
I Hits/ Range in Hit
Constituents , Analyses . Concentration (mRlI)
MetalsflnorRanics.
Aluminum ~0/140 0.027-1.314
Arsenic 3'/140 0.006-0.221
Barium ~0/140 0.022-0.328
Cadmium 2/40 . 0.002-0.004
Chromium 19/140 0.002-0.006
Copper 32/40 0.006-0.290
Iron 39/40 0.01111-6.69
Lead 27/110 0.002-0.023
Manganese ~0/140 0.007-0.4'6
Nickel 12/40 0.010-0.077
'Tin 7/140 0.012-0.028
Zinc ~0/40 0.010-0.737
NOTES:
. Onl)' metals/inorganics detected in well water presente~'
I
,
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.--
.
/ . , ,:) .,.:~
C.l C"
Z. c.
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r- -
~
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.
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. - -
I .
ec:..ou.8.'~
r
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-
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.... .....
..,... .,.. 01'.
........-. ___1
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..... t --I
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..
F1:ASIIIlm snJD't
IIE"'''.ANO FARRO IIIJ9
ESTNAJED EXTENT OF
VOl"TU OfIOANIC NJICA1UA
(X)MI'(UIJ9 .. CJROUNO _TEft
J
OWl
...
a
-------
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----.--. .-..--.--.-. ---
.._--- --..-..--.
. ,. OJI
~,~ -. -./~4 -~~__:"~'_h."-- .._,-_.",~t --,.'" ...,.:;,"-.::"".,?', ." -..' .. ". '," ,':' ",.,..,0,71 ~:h_#, .. ".,:~.:
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. (.,,-' "tf ::-,..-.,. -. .. "'0' ... (-" "", '" "', '., ":;' ''', '; " ", ,.' :-' ~
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'. J -,, J" ..---.J, :/,' ,_... -..,....' -"" -':'-'''')'' '::.! .' ,: \... '.... ([9~~ ~~IJ*, " ' . . ., ':..
::.- .1: I " i~ -..:.r ,............' \. j . ,.. ,- - , ~? ,,~. ., fD~:' . ,"
-.--::,' ,)~~ .=~', ,;: _..~~ '-~Y:'-w" .>.{ ,~ /:~.t, ,~.,:': ,:..:';'. '.. [;'0 -:'~~'~~)" ~~.~. ~-~:;.j~~b::;'.,. ,:.:-:.:,: '...'
.- --:,;-,y.. t.,-.ttRt\ov -. (...... '''' ...' ... i .. ..., ~ . :.. ~~' ... ..
!WOJ.:";~U'~"::"" . '~... '--J ~.\.~ -..-.- /~....~=::(..,,/.:, L.~)(' -:,.. ~~~J::1J::-:'liJ..:;'_- '~.
"":-'" 't~~~.....,.J .-:~;:A- __1..:- .. ".--"-" .. '-- I"... c_---" -, ..
,..,'" " r"'~oo' -. '; I . '. ", ... ,. .- "-. .i -/""."u ,..,~ 'J .....l U ~ D..
' . /;~":;'/, ~~_. ~.' T: _:-- ',,-' -. -. -. . -. -',.. .. .. '''..., le-' '-~. :-'
.- ,. D~;o'.,<, .' '~"_.. ... "',... . .. /'\1' .. ,..
- .//-/ oj. ... ,\,,,~ &.a-~. I -'1... ~ ('--." '---. ~. 0:. ...
".., '7'/ ,-. -' ~ ,..;;. C~ . ',-l...J '. - '... , .'. ..- ... --. -.'\... .- '--:,' ",' ~
~"'71~..t ,_,"'!0~~: '. .~~'~1/1\~--""" ~~..r.;:-:--:~;. (,::.-C _.._~:...::;;.:'."~~ ,
.- 8 -:;:::'.:.~;.::::.:- ---::::-.'/ . ~ - :..,";'';C vi.' /" -'..".' ~":..l./~,.: _. ~-/]~ '~'... "... :., ..~ -.
....' : ,,' '-:--. -. / --- -.. , . ... , ":,'...' ... '\.. / ',' .~,.,.,.. -1..-
,;. "'- ,':::'.: "- '''':,';;.' -., . ,n, --"'......' : -". '~" ~..'- ~o...::.,;,;;... .....;:".. .
/- ... -- ' , '" - . - .,,/ "-:----' -'-~ ~... :u~V~:".... i\ . :~J\- -!~'O~~
~\...~'" ,d- '~~'~';:"~.~',-,:~~';;~IS::,:S)~"-", --, ," ',' "','
':'., \. (). . :.:.1, '-~::- ."... .,'\. ... -.... ... . il r
"~ .. -".,,' -"". ",",'" , .'--.... . ~ I -f
\'~~l;:>::- (~i~~ -. ,-,_.,.........~'~ ;\-~\~\~..!. '... \,\ >j','. .:, ' , " .'(; . ,""'\
:,) -... .J:} ,_. , -. \ ,--.. "I -., .... . ' . '. ...-:;-): ]
" ''1 J '-" . I.. ~i/.. '-'... } . .. '''', rJ,L1(c( -. ~~. :.
~:~.~;._~~~>;,-~_:-. ..::_~::-,,~:;;.-..;::;.,\,::. . -'!. " ""~:j;; . ,'~, -; '\.:
~.\-r::\ ",) _.: ,.\. "'''':''." ""''','.. ..;, ... '....- i., ... ,-., -. " ... I ..., -. ...'"
. ... ---.---.---------. ......-.--..-.... ---------.--
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....... ......... - .......... ......... -
... ...... ... .... """"-'\. ...... .... ""1.M"I8'
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....... aND 'AI88O .",
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OF~-SJTE SURFACE WATER/.sEOIM!:NT
SAMPI-E i-OCAT/ON5
POOR QUAUTt
-------
i
15
site-related constituents. Chemicals detected in shallow ground
water are primarily VOCs. C-series compounds were not shown to be
present in the ground water above the detection limit. VOCs, being
relatively more mobile than the C-series compounds, were found in
shallow ground water within 18 feet of the surface. The extent of
VOC indicator chemicals in ground water is shown in Figure 5.
Seven metals were detected in the shallow zone ground water above
the background concentrations. Five other metals not detected in
background wells were also detected in shallow zone ground water.
Shallow ground water analyses are summarized in Table 1-4. .
Constituents were detected in surface water in several drainageways
and ponds. The constituents were primarily C-58, C-66 and semi-
volatile organic compounds. Locations of surface water samples are
presented in Figure 6. Surface water analyses are presented in
.Table 1-5.
Off-site soil testing was limited since Berlin and Farro
operational activities were confined to the site. Those off-site
samples tested for target screen (organic) compounds did not
indicate contamination and analyses for the Hazardous Substance
List (HSL) were not done off-site. Sediments containing site
related constituents migrated off-site and were detected in Slocum
Drain and Vincent Drain. Off-site sediment constituents were
similar to those detected in on-site soils and sediments except at
the manhole northeast of the site fence line where 4,4-DDE and 4,4
DDT were detected. These compounds commonly detected in soils in
agricultural areas were not associated with known disposal
activities at the site. . .
Ground water from the 38 off-site residential wells tested did not
indicate site-related constituents . Site-related organics were
detected in on-site monitoring wells near the southwest boundary
but off-site investigations in this area did not identify off-site
presence of organic contaminants. Comparison of ground water
samples obtained from off-site residential wells with the up
gradient residential background wells indicated that nine metals
were detected above the maximum background levels. Three other
metals were detected in residential wells but were not in the
background wells. A summary of inorganic constituents found in the
residential wells is presented in Table 1-6.
Surface water containing site-related constituents was limited to
near-site.areas; C-66 and C-58 were the most consistently detected
compounds, at concentration of less than 1 ug/l. Off-site surface
water sample locations are shown in Figure 7.
Until remediation occurs, ground water contamination may migrate
off-site, contaminated sediments in drainageways may increase in
-------
22
and contamination may be absorbed in surface water flowing above
these sediments. This contaminated ground and surface water may
create pathways for exposure to contamination through ingestion and
dermal contact. contaminated soil and sediment may create pathways
for exposure through'dermal contact, ingestion and inhalation.
VI.
SUMMARY,OF SITE RIS~S
During 'the RI an analysis was conducted to estimate the health or
. environmental problems that could result if the contaminated soil
. and sediments and the contaminated ground water were left
untreated. This analysis, commonly referred to as a baseline risk
assessment, is documented in ~ections 5 through 9 of the RI Report.
During the course of an RIfFS the u.S. EPA requires that a risk
assessment be prepared according to u.S. EPA policy and guidelines.
At Berlin and Farro, PRP contractors prepared a risk assessment
under the 1986 Consent Decree for the Remedial Investigation and
Feasibility study. This risk assessment provides u.S. EPA with a
basis for selection of a remedy which would be protective of public
health, welfare, and the environment. The risk assessment,
prepared by the PRP contractor, utilized available information and
is consistent with the u.s. EPA policy and, guidance available at
the time.
The u. S. EPA, under the guidance, commonly uses a "residential
scenario" (Le., unrestricted use of the site) when quantifying
risks. Although the site is not currently used for residential
purposes, the property is zoned for residential use and there are
no assurances that land usage may not change in the future. It is
not inconsistent with the NCP for soil at a site that is not
currently residential but may potentially have future residential
uses to be cleaned up to levels appropriate to residential use.
Changes in Risk Assessment Guidance have occurred subsequent to
preparation of the risk assessment for the Berlin and Farro site.
The new guidance, Risk assessment Guidance for Superfund, was
issued in September 1989 and specifically states:
"Following the date of its publication, this manual is
intended to be used as guidance for all human health risk
assessments conducted as part of the Superfund remedial
investigations and feasibility studies. Issuance of this
manual does not invalidate human health risk assessments
completed before (or in progress at) the publication date
and based on previously released Agency guidance.
The use of average and worst case exposure scenarios and soil
ingestion rates developed for the Berlin and Farro risk assessment
are consistent with this guidance. The use of such scenarios is
recommended in the Superfund Public Health Evaluation Manual
-------
23
calculate both best estimates and conservative upper bound
estimates for all exposure point chemical concentrations. "A range
of possible soil ingestion rates is recommended, "... soil
ingestion rates can vary from 0.1 - 5 grams per day, with higher
values representative of pica behavior."
In assessing possible exposure pathways, the focus was on the
health effects associated with direct exposure to the contaminants
as a result of the soil coming in contact with the skin or from
direct ingestion of the soil by a child playing in the area, and by
ingestion of and dermal exposure to contaminated ground water and
surface water. Exposure through inhalation of volatile compounds
and dust from contaminated soil wa~ also considered. These
exposure scenarios are reasonable, especially in light of the
selected alternative which would permit the site to be returned to
full use.
Indicator chemicals were selected from the large number of
contaminants which were detected on site in order to facilitate the
risk assessment. The analysis focused on a number of indicator
chemicals which were determined to be of greatest concern because
of their toxicity, level of concentration, and wide spread
occurrence. Toxicities of these compounds are discussed in the FS.
In ground water the indicator chemicals are methylene chloride,
1,2-dichloroethane (1,2 DCA), vinyl chloride, l,l-dichloroethene
(DCE) , trans-l,2-dichloroethene (t-DCE), be,nzene, and
trichloroethene. The soil and sediment indicator compounds were C-
66 and C-58. The volatile organic compounds are generally mobile
in soil due to high vapor pressures and high water solubility.
They have limited capacity to adsorb to soil particles. The C-
series compounds have limited mobility due to their strong tendency
to adsorb to soil and sediments. It is likely that migration from
the source will occur primarily through soil erosion or
anthropogenic transfer. .
The RI risk assessment used standard conservative assumptions
concerning intake and exposure. Conservative assumptions are
generally appropriate to assure protection of public health and the
environment, because there is some. uncertainty inherent in any
evaluation of risk. Cancer potency factors (CPFs) have been
developed by EPA's Carcinogenic Assessment Group for estimating
excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. CPFs, which are expressed in
units of (mg/kg-day)-l,are multiplied by the estimated intake of a
potential carcinogen in mg/kg-day and the expected duration of
chronic exposure, to provide an upper-bound estimate of the excess
lifetime cancer risk assoc'iated with exposure at that intake level.
Values for these parameters are included in the RI Report. The
term "upper bound" reflects the conservative estimate of the risks
calculated from the CPF. Use of this approach makes
-------
24
potency factors are derived from the results
epidemiological studies or chronic animal bioassays
animal-to-human extrapolation and uncertainty factors
applied.
Reference doses (RfDS) have been developed by u.s. EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.q~ the
amount of a chemical ingested from contaminated drinking water) can
be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.q., to account for the use of animal
data to predict effects on humans). These uncertainty factors help
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur.
of human
to which
have been
Maximum individual risks calculated for the indicator chemicals in
ground water are as follows:
methylene chloride
6.5 X 10-5
1.4 X 10-5
1,2-dichlorethane
. vinyl chloride
1,1-dichlorethene
6.0 X 10-3
1.8 X 10-4
trichloroethene
2.0 X 10-4
1.6 X 10-6
benzene
If on-site water bearing units from the shallow portion of the
aquifer were to be used as a domestic drinking water supply in the
future under .the upper bound exposure scenario tworst case) the
incremental lifetime cancer risk would be 6 X 10-and would exceed
the highest level of the acceptable cancer risk range described in
the NCP. This represents a reasonable, conservative exposure
scenario, since the remedial objective is to return the aquifer at
the site to beneficial use Drinking water or other wells could
therefore be installed in the upper 30 feet (the shallow aquifer).
~his worst case is determined using the highest contaminant levels
detected. This risk is due largely to the presence of indicator
chemical vinyl chloride which was detected in two wells near the
old drum landfill at concentrations up to 1,400 ug/l. No
calculated incremental non-carcinogenic hazard index exceeds the
acceptable level of 1. Technology for treatment of contamination
to address cancer risks will also necessarily treat contamination
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25
EPA and the state have determined that treatment of the
contaminated ground water in the shallow portion of the aquifer to
the following levels will reduce the excess cancer risk from
exposure to each chemical in thl ground water in the shallow
portion of the aquifer to 1 X 10- and any non-carcinogenic health
risks will be reduced to acceptable levels:
methylene chloride 5.0 ug/l
1,2-dichloroethane 0.4 ug/l
vinyl chloride 0.02 ug/l
1,1-dichloroethene 7.0 ug/l
benzene 1.0 ug/l
trichloroethene 3.0 ug/l
These cleanup levels were determined following standards set forth
in Rule 299.5709 of the Michigan Environmental Response Act (Act
307) for compliance with type B criteria for ground water in
aquifers and are based on individual risk fpr each compound.
These levels cannot always be conclusively reached in practice
because of practical limitations imposed by the available
analytical procedures. The risk-based levels may be below the
current analytical detection levels for these indicator chemicals.
Therefore, the cleanup levels for these indicator chemicals will be
determined by the available analytical procedures or the risk-based
levels defined above, which-ever is higher. Method detection
limits ("MDL") applied here based on Analvtical Detection Level
Guidance for Environmental Contamination Response Activities under
Act 307 Rules (memorandum of James G. Truchan, MDNR, April 1, 1991)
using best practical judgement based on the capabilities of the
reference method and capabilities of government and commercial
labs.
Based upon the health based standards and MDLs as shown by MDNR
guidance for the implementation of. Act 307 Rules the following
cleanup levels are established subject to possible revision if
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26
methylene chloride 5 ug/l (1 X 10-6)
1,2-dichloroethane 1 ug/l (MDL)
vinyl chloride 1 ug/l (MDL)
1,1-dichloroethene 7 ug/l (1 X 10-6)
benzene 1 ug/l (1 X 10-6)
trichloroethene 3 ug/l (1 X 10-6)
Treatment of the ground water will continue until
concentrations of indicator compounds reach these standards.
th E:: .
The upper bound scenario for soil exposure is based on residential
use of the site area. People would be exposed through dermal
exposure, direct ingestion and inhalation of the contaminated soil.
This scenario assumes, among other residential activities, that a
basement, 8 feet deep would be excavated and the soils spread onto
the ground surface around the residence. Under this exposure
scenario, significant volumes of 5011 would be exposed, and would
present a cancer risk of 5.8 X 10- that is significantly greater
than the risk level of 1 X 10-4. When that risk level is exceeded,
the NCP (300,430(e) (2»presumes that cleanups will reduce risks to
the 1 X 10-6level. Al though this risk is due largely to the
presence of arsenic, lead, and C-66; benzene, ethylbenzene,
toluene, and xylene also contribute to the overall risk. People
would be exposed through dermal exposure and direct ingestion of
the contaminated soil and sediment.
. The concentrations of any hazardous substances, pollutants, and
contaminants remaining in the soil and sediments at and adjacent to
Berlin and Farro at the conclusion of the remedial work shall not:
1. Pose an excess lifetime carcinogeRic risk for children
and adults greater than 1.0 X 10- ;
2. Present a maximum chronic Hazard Index for children
and adults greater than 1; and
3. Exceed any federal or state ARARs including MCLs.
Based on currently available information, U. S. EPA and the state
have ide~tified several contaminants as among the primary
contaminants at the site and as suitable preliminary indicators of
the levels of concentration of all of the hazardous substances,
pollutants, and contaminants in the soil and in the sediment.
EPA and the state have determined that by disposing of and treating
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the concentrations shown in the following table, the excess
lifetime cancer risk from exposure to eacechemical in the soil and
sediment will be reduced to 1 X 10- or background and non-
carcinogenic health risks will be reduced to acceptable levels or
background:
arsenic 10.6 Dg/kg
lead 20.8 Dg/kg
benzene O. 02 Dg/kg
ethylbenzene 1.4 Dg/kg
toluene 16.0 Dg/k9.
xylene 6.0 mg/kg
C-66 1.4 mg/kg
CERCLA requires the adoption of promulgated state cleanup standards
if those standards are applicable, or relevant and appropriate
requirements that are more stringent than equivalent Federal
requirements. soil cleanup levels at Berlin and Farro meet the
requirements. for cleanup under Michigan Act 307. Levels for
. arsenic and lead ~re based on natural background as determined in
the FS. Background levels were determined through a statistical
method that uses the concentrations from actual background samples
and calculates the mean plus three times the standard deviation to
arrive at target cleanup levels. Benzene and C-66 soil cleanu%
levels are health based and reduce risk to less than 1 X 10- .
Cleanup levels for ethylbenzene, toluene, and xylene contamination
have been determined by application of Rule 299.5709 provides for
establishing standards to prohibit levels of contamination which
impart adverse aesthetic characteristics to ground water. Those
standards were established using U.S. EPA Method 140.1 of the.
"Methods for. Chemical Analysis of Waste and Water" (March 1979)
(EPA-600-4-79-020) (40 CFR 143.4 (b) (7» .. The proposed secondary
maximum contaminant levels identified in the 1990 Proposed Plan
have not been finalized and are therefore inappropriate for use in
establishing ARARs for these constituents.
These cleanup levels, determined in accordance with Rule 299.5711
:of Michigan Act 307 for compliance with type A or type B criteria
for soils, will bring the probability of contracting cancer as a
result of exposure to the contamination in the soil and sediments
to within the accepted range for materials of this nature.
Compliance may be demonstrated by leachate testing or by cleanup of
the contaminated soils to a concentration no greater than 20 times
the Type A or Type B criterion for that compound in ground water
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The upper bound scenario lor surface water did not identify any
risks in excess of 1 X 10- . As a result, surface water will not be
addressed in the remedy, except as an adjunct to remediating
contaminated sediments.
Actual or threatened releases of hazardous substances from this
site, if not addressed by the selected alternative, may present an
imminent and substantial endangerment to public health, welfare or
the environment.
. VII.
DESCRIPTION OF ALTERNATIVES
The alternatives analyzed for the remedial action at the Berlin and
Farro site are presented below. These are numbered to correspond
with the numbers in the RI/FS Report. The alternatives which have
been assembled to include remedial activities which address both
the ground. water contamination and the contaminated soil and
sediment are as follows:
o Alternative 1:
o Alternative 2:
o Alternative 3:
o Alternative 4:
o Alternative 5:
o Alternative 6:
No Action.
Institutional Controls.
Containment to include capping, silt barriers,
and slurry wall.
Excavation o{ soil and sediment with greater
than 1 X 10-. risk and disposal off site and
capping of the untreated lower risk area.
contami~ated ground water with greater than
1 X 10- risk will be extracted and treated by
air stripping to meet cleanup levels in the
intermediate zone.
Excavation o{ soil and sediment with greater
than 1 X 10- risk and incineration on site
followed by capping of the untreated lower risk
area and extraction and air stripping of the
contami~ated ground water with greater than
1 X 10- risk to meet cleanup standards in the
intermediate zone.
Excavation o~ s011 and sediment with greater
than 1 X 10- risk and stabilization with
fly ash and disposal on site and extraction
and air stripping of contaminated ground water
with risk greater than 1 X 10-6to meet cleanup
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o Alternative 'A:
o Alternative 7:
o Alternative 'A:
o Alternative 8:
o Alternative I:
29
Excavation o£ soil and sediment with greater
than 1 X 10- risk and disposal off site with
treatment by stabilization and extraction and
air stripping of the contaminated ground water
with risks greater than 1 X 10-6to meet
cleanup standards in the intermediate zone.
Excavation 0i soil and sediment with greater
than 1 X 10- risk and stabilization by the
Hazcon process prior to disposal in an on-site
cell and extraction and air stripping of the
contaminated ground water with risks greater
than 1 X 10-6fo meet cleanup standards in the
intermediate.
Exc~ation o£ soil and sediment with greater
than 1 X 10- risk and stabilization by the
Hazcon process prior to disposal in an on-site
cell and extraction ~f ground water with
greater than 1 X 10- risk to meet cleanup
standards in the intermediate zone followed by
treatment in a POTW.
Excavation of Slocum Drain sediments with
greater than 1 X 10-6risk, stabilization of
those sediments with Class. C fly ash followed
by capping along with the on-site 1 X 10-6risk
soil and sediment, and extraction and air
stripping of the contaminated ground water with
risks greater than 1 X 10-6to meet cleanup
levels in the intermediate zone.
Excavation of Slocum6Drain sediments with
greater than 1 X 10- risk, stabilization of
these sediments with Class C fly ash followed
by capping along with the on-site 1 X 10-6risk
soil and sediment, and extraction and air
stripping of the contaminated 9iound water
with risks greater than 1 X 10- to meet
cleanup levels in the shallow zone of the
aquifer.
Common Elements
Except for alternatives 1, 2, and 3, all of the alternatives now
being considered contain one or more common elements. Alternatives
4, 5, 6, 6A, " 8, and 9 include extraction of contaminated
groundwater and air stripping before discharge to the surface
water. The common element in the soil and sediment alternative is
the volume of material to be treated. Alternatives 4 and 5 propose
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.
30
yards of material. This volume is composed of Central site area
soil and sediment contaminated to 1 X 10-4risk level. Alternative
6, 6A, 7, and 7A have elements which excavate and treat an
estimated 38,000 to 48,000 cubic yards of soil and sediment with
risk levels exceeding 1 X 10-6. Alternatives 8 and 9 include the
excavation and treatment of Slocum Drain sediments followed by
capping along with 1 X 10-6soils on site. Each alternative also
includes long term groundwater monitoring consistent with
requirements of RCRA Subpart F, 40 CFR 1264.100. These monitoring
activities will be conducted to gauge the effectiveness of the
selected remedy. In addition, the State, which owns the site, will
place a deed restriction on the site to prohibit soil excavation
and construction of buildings or wells at the site pending
completion of the ground water remedy.
ALTERNATIVE 1:
NO ACTION
capital Cost: $25,000
Annual Operation and Maintenance
O&M Present Worth (PW): $75,000
Net PW: $100,000
(O&M) Costs:
$5,000
..
The Superfund program requires that the "No Action" alternative be
evaluated at every site to establish a baseline for comparison.
Under this alternative, U.S. EPA would take ~o further action to
prevent exposure to the soil, sediment, or groundwater at the site
or to prevent migration of the contamination off site. However,
long term monitoring of the site would be necessary to monitor
contaminant migration. Monitoring can be implemented by using
previously installed monitoring wells and residential wells.
Because this alternative would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
years. .
ALTERNATIVE 21
INSTITUTIONAL CONTROLS
Capital Costs: $200,000
Annual O&M Costs: $15,000
O&M PW: $225,000
Net PW: $425,000
This alternative would not require implementation of remedial
actions to address ground water or soil contamination. Deed
restrictions would be imposed to prevent excavation in areas of
contamination. Ground water use restrictions would be implemented
in the affected areas to prevent the use of contaminated ground
water for drinking or agricultural purposes. These institutional
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31
related risks. A long term monitoring program as described in
Alternative 1 would also be implemented. Deed and ground water
restrictions can be implemented by state and local authorities.
The alternative also provides institutional controls and additional
fencing at Slocum Drain. The major components of the institutional
controls are:
II
Use of additional fencing around the impacted open
areas of Slocum Drain to restrict access, thereby
reducing potential exposure and risk to human health,
and
Use of deed restrictions to limit the development and
use of land and groundwater on the Berlin and Farro
Site.
II
Because this alternati~ would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
years.
ALTERNATIVE 3:
CONTAINMENT
Capital Costs: $5,540,000
Annual O&M Costs: $100,000
O&M PW: $1,505,000
Net PW: $7,045,000
The response actions and technologies specified in this alternative
are primarily to confine, impede, and/or isolate constituents
within the affected media. The contaminated areas of concern are.
the soil and sediment in the Central Site area, the sediments in
Slocum Drain, and the groundwater in the Old Drum Landfill area and
northern Central site area.
The principal containment technologies include slurry walls and
multi-media capping. Slurry walls will be constructed around the
Central site area and the Old Drum Landfill area down to the lower
till. Fourteen hundred feet of soil/bentonite slurry wall
approximately 3 feet wide and 70 feet deep will be located to
'surround and contain the contaminated groundwater areas.
Two multi-media caps will be constructed to cover the areas bounded
-by the slurry walls. The capped area over the Old Drum Landfill
area is approximately 6 acres. The capped area over the Central
Site area is approximately 17 acres. The caps will consist of a
base of 2 ft (minimum) of compacted clay overlain with a 40 mil
high density polyethylene geomembrane. An infiltration drainage
zone consisting of 1 ft of sand will be constructed on top of the
geomembrane. The sand will be covered with 1\ ft of uncompacted
clay.to form a root growth zone. A ~ ft thiC?k topsoil zone will be
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32
mulched. New monitoring wells will be installed to determine the
effectiveness of the containment system. That monitoring system
will be operated for 30 years. The installation of silt barriers,
slurry walls, and multimedia cap is expected to be completed within
1 year.
Because this alternative would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
years.
This alternative also includes use of the institutional controls
described in Alternative 2.
ALTERNATIVE ..:
AIR STRIPPING AND EXCAVATION WITH OFF SITE DISPOSAL
Capital Costs: $5,795~00
Annual O&M Costs: $175,000
O&M PW: $1,625,000
Net PW: $7,420,000
This alternative consists of two components: contaminated soil and
sediment are disposed of off site iri a RCRA cell and contaminated
groundwater is treated on ,site and discharged to Slocum Drain.
Extraction trenches are planned in the vicinity of the Old Drum
Landfill and north of the Central Site area near MW-44. A riser
and pump will be used to extract groundwater from the 3 ft wide by
25 ft deep gravel filled trench. The trenches will have a
bentonite floor and a clay cap. The water will be treated in a
polypropylene tripack tower designed to process approximately 10 to
20 gallons per minute (gpm) of groundwater. Emissions from the air
stripper will be treated to meet Federal and State standards.
Water treated to meet permit standards will be discharged to Slocum
Drain through piping installed for that purpose. All air and
'surface water discharges would comply with state and federal
standards.
Tentative maximum base limits (TMBL) for surface water discharges
under a NPDES permit as provided by MDNR Surface Water Quality
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33
Compound
~ (ug/l)
vinyl chloride
methylene chloride
1,1-dichloroethene
benzene
toluene
ethylbenzene
barium
cadmium
cyanide
lead
hexachloroethane
hexachlorobenzene
pH
3.0
5.0
2.6
5.0
10.0
30.0
0.5
151.0
4.0
27.0
0.1
0.0019
6.5-9.0
These limits have been provided for screening of alternatives and
do not necessarily represent the effluent limits that will need to
be met in order to meet NPDES requirements. Actual limits will be
provided during the design.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the ground water at
the site and its environs would continue for at least 5 years after
the remedial action cleanup goals have been met.
A contingency has been made for non-continuous air stripper
operations due to expected low, long-term extraction rates. Two
25,000 gallon storage tanks, insulated and equipped with warmers,
will be erected on-site. These will be used for ground water
storage in compliance with state and federal standards, until an
adequate quantity of water is available for periodic air stripper
operation.
The extraction and air stripping treatment of the ground water to
meet health based cleanup levels in the lower portion of the
aquifer is assumed to take 10 years for cost projections. An
estimated 13.5 million gallons of ground water will be treated'
"during that period. The actual time required to reach the
necessary cleanup standards may be considerably longer. Ground
water monitoring will continue for a 30 year period to determine
-the effectiveness of treatment.
Central site area soil arid sediment and Slocum drain sediments
contaminated to levels which represent 1 X 10-4 risk will be
excavated and transported to a RCRA facility for treatment by
solidification and disposal. Soil in the Central Site area will be
excavated, as well as sediment remaining in the South Lagoon and
tank excavation pond.
o 'The Central site area soil not planned for removal and treatment
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34
The bare areas of the site and the cap will have \ ft of topsoil,
and will be seeded, fertilized and mulched.
The removal and off-site disposal of the soils and the installation
of silt barriers and~clay caps is expected to take approximately 1
year. An estimated 15,000 to 18,000 cubic yards of soil and
sediment may be excavated for treatment, although the precise
volume cannot be determined until the excavation and sampling to
demonstrate attainment of cleanup levels is completed. Costs
presented in the FS used a volume of 15,000 cubic yards.
This alternative also includes use of the institutional controls
described in }lternative 2.
Because this alternative would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
years.
ALTERNATIVE 5:
AIR STRIPPING AND ON SITE INCINERATION
Capital Costs: $7,020,000
Annual O&M Costs: $175,000
O&M PW: $1,625,000
Net PW: $8,645,000
This alternative is similar to Alternative 4, with the exception
that soil and sediment with a risk of greater than 1 X 10-4and
contaminated Slocum Drain sediments will be excavated and
incinerated on-site in compliance with all federal and state
requirements, and the treated materials will be placed into the
Central Site area excavation. The need for further treatment of
incineration residuals will be dependent on the nature of the
residuals. Capping of remaining soil containing residual chemicals
and site revegetation is utilized to minimize migration of site
constituents and to reduce exposure risks.
This alternative also utilizes extraction trenches for ground water
collection and air stripping for on-site treatment of ground water
to permit standards, with discharge of the treated water to Slocum
Drain.
The ground water remediation time is the same as estimated for
al ternative 4. The same institutional controls and monitoring
would also be applied. Soil remediation, including excavation,
transportation, and incineration is expected to take about 1 year.
Because this alternative would result in contamination remaining on
site, CERCLA requires that the site be reviewed at least every five
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35
ALTERNATIVE I'
AIR STRIPPING, SOLIDIFICATION, AND ON SITE DISPOSAL
capital Costs: $7,770,000
Annual O&M Costs: $220,000
O&M PW: $2,645,000
Net PW: $10,415,000
This -alternative integrates on-site treatment and on-site
containment of soil anf sediment, that have a potential risk
- greater than 1 X 10- under the future residential expos~re
scenario. Groundwater will be collected from extraction trenches
as presented in alternative 4. The ground water is treated on-site
by air stripping to meet permit standards and discharged to Slocum
Drain.
Soil and sediment wi~ contaminant concentrations which represent
greater than 1 X 10- risk levels will be solidified with Class C
fly ash and placed in an on-site RCRA cell. The waste will be
staged wi thin the area of contamination for treatment before
disposal in the on-site cell. The solidification process will
increase the volume by a 2.2 to 1 ratio. An estimated 38,000 to
48,000 cubic yards will be treated, although the precise volume
cannot be determined until the excavation and sampling to
demonstrate attainment of cleanup levels is completed. The volumes
to be treated may be greater than the 42,500 ~ubic yards estimated
in the FS due to increases caused by inclusion of cleanup standards
for VOCs. Cost of the remedy is approximated using the volumes in
the FS. The cell after capping will cover approximately 3~ acres.
The construction of a liner, the solidification of the soils and
sediments, and the construction of a multi-media cap is expected to
be completed within 2 years. The extraction and air stripping
treatment of the contaminated ground water to meet cleanup levels
is assumed to take 20 years, but will continue until cleanup levels
are met. It is estimated that 27 million gallons of ground water
will be treated during a 20 year period.
This alternative also includes institutional controls.
Because this alternative would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
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36
ALTERNATIVE .sA:
AIR STRIPPING, EXCAVATION, AND OFF SITE DISPOSAL
Capital Costs: $10,915,000
Annual O&M Costs: $190,000
O&M PW: $2,185,000
Net PW: $13,100,000
This alternative meets the same soil and sediment and ground water
remedial objectives as alternative 6. The ground water component
of the alternative includes the same pump and treat elements as
Alternative 4.
Soil and sediment with contaminant levels at greater than
1 X 10-6 will be excavated and treated by solidification and
disposed of off-site.- Volume estimations are the same as for
Alternative 6. The excavated area will be back filled with clean
fill and revegetated. Treatment and disposal will be at a RCRA
compliant facility.
Ground water treatment is projected to continue for 10 years, but
will continue until cleanup levels are reached. Removal and off-
site disposal of the soil and sediment will be completed within 1
year although this time may be longer if larger than anticipated
volumes of material must be removed.
This alternative will permit the site to be returned to productive
use after the conclusion of the ground water treatment and
monitoring program.
ALTERNATIVE 7:
AIR STRIPPING, EXCAVATION, AND SOLIDIFICATION ON-SITE
capital Costs: $8,990,000
Annual O&M Costs: $220,000
O&M PW: $2,645,000
Net PW: $11,635,000
This alternative is the same as Alternative 6 except that it
incorporates innovative technology for the treatment of sediment
and soil. Soil and sediment will be excavated and treated and
disposed of on site. All soil and sediment with contaminant levels
greater than a 1 X 10-6risk will be included for treatment as in
Alternatives 6 and 6A.
The process uses Portland cement with a chemical additive to
encapsulate organics and solidify the soil and sediment. The
treated material will be treated on-site and disposed of in the
same way as Alternative 6. The waste will be staged within the
area of contamination for treatment before disposal in the on-site
cell. The bulking ratio for the treated material is estimated to
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37
treated volume will require a disposal cell about 25 percent
smaller than for the solidification alternative using fly ash.
The time for completion of the soil and sediment component of this
alternative is the same as for alternative 6- approximately 2
years. Ground water objectives are projected to be reached in
about 10 years, but treatment will continue until cleanup levels
are met. .
Because this alternative would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
years.
ALTERNATIVE 7A:
POTW, EXCAVATION, AND SOLIDIFICATION ON SITE
Capital Costs: $8,880,000
Annual O&M Costs: $230,000
O&M PW: $2,730,000
Net PW: $11,610,000
This alternative treats the sediment and soil in the same manner as
Alternative 7. Ground water in this alternative is extracted and
stored as in Alternative 4, and treated off site at the Genesee
County Water Drain Commission (POTW). Extracted ground water will
be trucked to the POTW. Pretreatment standards, which for organic
compounds are determined on a case by case basis, will be met.
The ground water treatment is planned to continue for as long as
necessary to meet the cleanup levels (estimated for planning
purposes to be 10 years).
Because this alternative would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
years.
ALTERNATIVE 8:
AIR STRIPPING AND MULTIMEDIA CAP
Capital Costs: $3,290,000
Annual O&M Costs: $220,000
O&M PW: $2,640,000
Net PW: $5,930,000
. This alternative integrates on-site solidification of sediments
using fly ash and on-site containment of soils and treated
sediments, tpat have a potential excess carcinogenic risk greater
than 1 X 10-tunder the future residential scenario. The excavated
sediments from Slocum Drain (approximately 1,500 cubic yards) and
the Central site area sediments will be treated in the Central Site
area ponds by Class C fly ash sOlidification/fixation process. The
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38 .
6, together with the treated sediments, will be contained with a
multi-media cap as in Alternative 3. Groundwater is collected and
treated as presented in alternative 6 and 7 where the period of
treatment is planned for 10 years.
Because this alternative would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
years.
ALTERNATIVE 'I
AIR STRIPPING AND MULTIMEDIA CAP
Capital Costs: $3,290,000
Annual O&M Costs: $255,000
O&M PW: $4,160,000
Net PW: $7,450,000
This alternative is similar to alternative 8 except that the ground
water exposure point is in the shallow portion of the aquifer.
Under this exposure scenario, remediation by ground water
collection from extraction trenches is planned for 30 years,
although treatment will extend until cleanup levels are reached.
It is estimated that approximately 3 million gallons per year of
ground water would be treated during a 30 year period.
Because this alternative would result in contaminants remaining on
site, CERCLA requires that the site be reviewed at least every five
years.
,
VIII.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
The Nine Evaluation Criteria
The FS examined eleven alternatives, and evaluated them according
to the evaluation criteria outlined in the NCP. . From these
alternatives the u.s. EPA has selected a remedy that combines the
the soil and on-site sediment excavation element of Alternative 6
and the off-site sediment excavation and the ground water.treatment
elements of Alternative 9. For the selected alternative
approximately 48,000 cubic yards of on-site contaminated soil and
sediment and Slocum drain sediments will be disposed of on-site in
a cell which will meet the applicable or relevant and appropriate
technical requirements of the Resource Conservation and Recovery
Act (nRCRAn) Subtitle C and Michigan Act 64. The proposed cell
will have more long-term effectiveness and permanence than the
engineered cell described for Alternative 6 in the FS Report.
Treatment will be required for materials which exhibit the
characteristic of RCRA hazardous waste. Excavation, treatment and
disposal of these materials in this manner will reduce carcinogenic
risk levels to less than 1 X 10-6 and risk of non-carcinogenic
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39
Ground water contaminated to 1 X 10-Erisk levels will be collected
and treated in an on-site air stripper (Alt. 9). Of the ground
water alternatives, only the preferred alternative
and Alternative 9 utilize the more protective point of compliance.
Use of this point of compliance is essential for protection from
exposure to contaminated ground water under a residential exposure
scenario which considers the shallow portion of the aquifer a
usable source of drinking water. Alternatives 4, 5, 6, 6A, 7, 7A
and 8 reduce the risk of exposure by applying the same cleanup
. standards, but at a point of compliance deeper in the aquifer.
The cost of the preferred remedy is estimated to be:
Capital Costs: $4,767,300
Annual O&M Costs: $280,700
O&M PW: $3,352,000
Net PW: $8,119,300
Based on current information, this combination .of alternatives
appears to provide the best balance of trade-offs among the
alternatives with respect to the nine criteria that EPA uses to
evaluate alternatives. This section profiles the performance of
the preferred alternative against the nine criteria and explains
the rationale for the selection of the final remedial action. These
nine criteria are:
1) Overall Protection of Human Health and Environment addresses
whether or not a remedy provides adequate protection and describes
how risks posed through each pathway are eliminated, reduced, or
controlled through treatment, engineering controls or institutional
controls.
2) Compliance with ARARs addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate requirements
of other Federal and state environmental statutes and/or provide
grounds for invoking a waiver.
3) Long-term Effectiveness and Permanence refers to the magnitude
of residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once the
cleanup goals have been met.
4) Reduction of Toxicity, Mobil! ty, or Volume Through Treatment is
-the anticipated performance of the treatment technologies that may
be employed in a remedy.
5) Short-term Effectiveness addresses the period of time needed to
achieve remediation levels set out in the ROD, as well as the
remedyts potential to create adverse impacts on human health and
the environment that may result during the construction and
implementation period, until cleanup levels are achieved.
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6) Implementability is the technical and administrative
feasibility of the remedy, including the availability of materials
and services needed to implement the chosen solution.
7) Cost includes estimates
maintenance costs.
of
capital
and
operation
and
8) state Acceptance indicates whether, based on its review of the
RI/FS and Proposed Plan, the state concurs with, opposes, or has no
comment on the preferred alternative.
9) Community Acceptance will be assessed in the Record of Decision
following review of the public comments received on tpe RI/FS
report and the Proposed Plan.
B.
Comparative Analysis
Overall Protection of Human Health and Environment. All of the
alternatives, with the exception of the "no action" and limited
action alternatives, would provide protection of human health and
the environment by eliminating, reducing, or controlling risk
through treatment, engineering controls, institutional controls, or
a combination of these measures. The selected alternative disposes
of contaminated soil and sediment with risk levels above 1 X 10-6
(the most conservative end of U. S. EPA' s generally acceptable
range) in a hazardous waste cell thereby reducing the risk of
adverse health effects associated with ingestion and direct
contact. The selected alternative wjll excavate soil and sediment
contaminated at greater than 1 X 10-crisk levels and dispose of it
in an on-site disposal cell. The selected alternative treats the
areas of contaminated ground water to levels which reduce the risk
through consumption of ground water to health based standards.
The selected alternative combines the ground water remedy using the
shallow portion of the aquifer as the point of compliance, and a
soil and sediment remedy Whic~ addresses all contamination posing
a risk greater than 1 X 10- (the most conservative end of u.s.
EPA's generally acceptable risk range).
Of the ground water alternatives, only the selected alternative
and Alternative 9 utilize the more protective point of compliance.
Use of this point of compliance is essential for protection from
exposure to contaminated ground water under a residential exposure
scenario which considers the shallow portion of the aquifer a
usable source of drinking water. The selected remedy treats the
ar~as of contaminated ground water to levels which reduce the risk
through consumption to health based standards or method detection
limits. Alternatives 4, 5, 6, 6A, 7, 7A and 8 reduce the risk of
exposure by applying the same cleanup standards, but at a point of
compliance deeper in the aquifer. Alternative 3 reduces ground
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41
provides less certainty over the long term than the treatment
alternatives. All of the treatment alternatives are combined with
institutional controls, which further reduce the risk of ingestion
or direct contact with contamination, although they do not
eliminate the risk. Alternative 2, which provides only for
institutional controls, provides inadequate overall protection from
such exposure. Alternative 1 provides no protection.
The selected alternative and Alternative 6 excavate and dispose of
all contaminated soil and sediment posing a risk in excess of 1 X
. 10-6 on-site. Alternative 6 however disposes of waste in an
engineered cell and does not provide ~or a full Subtitle C/Act 64
cell. The selected remedy is an improvement on, and a natural
extension of the cell components described in the FS. Alternative
6A excavates all ~ontaminated soil and sediment posing a risk in
excess of 1 X 10- and transports them to an off-site facility for
disposal. Alternatives 7 and 7A also treat all soils and sediments
that pose risk in excess of 1 X 10-6Alternatives 4 and 5 provide
protection by treating soils and sediments that pose risks in
excess of 1 X 10-4and relying on containment to protect against
risks below that level. Alternatives 8 and 9 provide protection by
relyinq only on 1 imi ted partial treatment and cappinq of the
remaining contaminated soils and sediments."
Because the "no action" and institutional controls only
alternatives are not sufficiently protectiv~ of human health and
the environment, these alternatives will not be considered further
in this analysis as options for the site.
Compliance with ARARs. The site was never an operating RCRA
facility. site records do not demonstrate that the materials
received and disposed of at the site during its operation are
listed RCRA wastes. RCRA Land Disposal Restriction (LDRs) are
nonetheless applicable or relevant and appropriate for certain of
the alternatives if the materials to be excavated are found to be
characteristic wastes. If the wastes are determined to be
characteristic, and the wastes are not able to be treated to meet
the LDR treatment standard, a treatability variance will be
obtained.
The state of Michigan has promulgated rules pursuant to Michigan
Environmental Response Act (Act 307). The substantive provisions
of Part 6 and Part 7 of the rules establish general standards for
cleanup of sites of contamination in Michigan. These substantive
provisions are considered to be an ARAR for this response action.
These rules provide, among other things, that remedial actions be
protective of human health, safety and welfare and the environment.
The MDNR's rules establish criteria for three acceptable cleanup
types which could be applied to satisfy the substantive
requirements of Part 7. Under the rules, a Type A cleanup
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generally achieves specific standard risk-based cleanup levels, and
a Type C cleanup is based on a site-specific risk assessment that
considers specific criteria.
Under the NC~, U.S. EPA is responsible for determining how this
ARAR applies to the site. Because these new rules are the central
element of a regulatory program of substantial importance to the
state, U.s. EPA asked the state to provide its interpretation of
how the Act 307 rules apply to the site. The state provided an
explanation to U.s. EPA detailing that only those remedies
(including the selected remedy) which dispose of all materials
which exceed Type B cleanup standards in a cell that satisfies
Michigan Act 64 and RCRA minimum technology requirements meet the
Type C criteria for remediation of soil and sediment at the site.
The state further explained that only the selected alternative and
Alternative 9 meet the-Type B criteria for remediation of ground
water at the site. While U.s. EPA is responsible for determining
whether a remedy complies with ARARs, it is noted that t~e
substantive provisions of the Act 307 rules are new, and are of
great importance to the state's regulatory program. U.s. EPA has
examined this ARAR and has determined that the state's.
interpretation is reasonable. .
All alternatives would be designed to meet their respective
applicable or relevant and appropriate requirements of Federal and
state environmental laws. The selected remedy and alternatives 6A,
7, and 7A may require a waiver from the siting requirements since
space requirements exceed the 100 foot limit from the property
boundary and the depth to the water table is slightly less than the
minimum 10 foot separation limit. Off-site disposal of soil,
sediment and treatment residuals would trigger RCRA land disposal
restrictions (LDRs) to the extent those materials were
characteristic wastes. The excavation and on-site disposal of
Slocum Drain sediments and site soils does not constitute
"placement" triggering RCRA land disposal restrictions since the
activities merely consolidate materials within the same area of
contamination (Figure 3). The LDR requirement that characteristic
waste be treated to remove that characteristic will nonetheless be
complied with as relevant and appropriate. These requirements are
well-suited to help prevent leaching of contamination from an on-
site containment cell. Tables in the FS discuss in more depth the
ARARs that would be met for each remedial alternative.
Long-term effectiveness and permanence. Long-term effectiveness
of the selected alternative is high for soils and sediments and
groundwater. Hazard$ posed by the contaminated soil and sediment
are reduced through on-site containment in a disposal cell which is
designed to meet the technical requirements of RCRA subtitle C and
Michigan Act 64 for a hazardous waste containment cell. This cell
includes a leachate collection and treatment system. In addition,
treatment of contaminated soils and sediments to remove. free
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43
the possibility of leachate migration. The selected remedy for
contaminated ground water provides long term effectiveness and
permanence by removing contaminants from the groundwater by air
stripping, controlling the off-gas contaminants rather than
releasing them to the atmosphere, and properly handling treatment
residues. Long-term effectiveness is maximized by using the most
protective point of compliance.
Alternative 4 and Alternative 6A would remove waste to a
permitted, off-site landfill, and contain the residual
contamination thereby reducing the long term exposure risks from
that waste at the site. Alternative 6A removes the larger volume.
As with all containment cells for long-term effectiveness the
containment system may require continued maintenance. While the
off-site disposal option reduces the on-site risks, off-site
disposal without treatment is the least preferred option under
CERCLA. Moreover, off-site disposal of a large volume of material
poses significant transportation risks.
The cap, silt barriers, and slurry wall that would be implemented
in Alternative 3 would provide long term reductions in the amount
of water that otherwise would pass through the contaminated soil
and would reduce the potential for eXPQsure through ingestion and
dermal contact. The alternative's effectiveness would be evaluated
through long-term monitoring. The cap, silt barriers, and slurry
wall would require long-term maintenance, and portions might need
to be replaced in the future.
Alternative 5 provides permanence and effectively reduces risk by
destroying the organics through incineration 01 contaminated soils
and sediments with risks in excess of 1 X 10- . The technology is
less effective in the treatment of metals.
Alternative 6, Alternative 7, and Alternative 7A would stabilize
contaminated soil and sediment by addition of chemical additives in
processes to reduce the mobility of the contaminants. The
technology is. considered to have good long-term reliability. Both
yield treated soil and sediment with a moderate to high compressive
strength and low leachability potential.
Alternatives 5, 6, 7, and 7A include capping components to further
reduce risk from exposure to contaminated soil and sediment and to
reduce the potential of leaching of hazardous constituents from
-material remaining on site. For continued long-term effectiveness
and permanence maintenance of the cap would be required. It should
be noted that the containment ~reas provided in these alternatives
do not include the double liner/double leachate collection system
that is part of the selected remedy.
Long-term effectiveness for containment of the soils and sediments
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44
Partial treatment and multi-media capping of the affected areas,
combined with institutional controls, will reduce the probability
of exposure to site constituents. Permanence can be expected for
the cap if maintenance and renewal requirements are followed.
The ground water components of Alternatives 4 through 9 can be
expected to provide long-term effectiveness and permanence. At
completion, ground water at the point of compliance in the shallow
portion of the aquifer is expected to have contam~nant
concentrations below the health based standards for a 1 X 10-~isk
level or method detection limits for a future drinking water
ingestion scenario. However, the selected alternative and
Alternative 9 have a higher effectiveness and permanence because of.
their focus on the shallow aquifer. The selected remedy provides
long-term effectiveness and permanence by removing contaminants
from the ground water by air stripping and control of the off-gas
contaminants rather than release to the atmosphere.
Ground water monitoring is planned to continue for 30 years.
The overall remaining risk of this scenario is low assuming the
deed restrictions are maintained and enforced. The permanence and
long-term effectiveness of the se1ecte~ alternative and of
A1 ternative 9 for ground water is also greater because these
minimize the amount of residual and/or untreated waste. The
effectiveness and permanence of the deed restrictions are likely to
be high because the property. is owned by the S~ate.
Reduction of Toxicity, MObility, or Volume of the contaminants
Through Treatment. The selected alternative and alternatives which
may require treatment through removal of free liquids and
stabilization of characteristic materials, reduce mobility and
toxicity in contaminated soils and sediments by encapsulation and
bonding of metals and reduction of the leachability of all
substances. The toxicity of some of the metals will be reduced due
to bonding to the pozzo1an material. Moreover, with
solidification, all of the substances and metals will be
encapsulated in a hard, solidified mass and exposure to the
substances will be highly unlikely; therefore, the toxic effects of
the substances will be reduced. VOCs can be released during the
excavation and solidification. These releases can be controlled
through collection and treatment if emission standards are being
exceeded to reduce toxicity. In addition, the collection system in
the containment cell will capture leachate from the cell, and thus
reduces the mobility of the contaminants. Treatment of the
leachate will also serve to reduce the toxicity of the
contaminants.
Al ternatives 3 and 4 do not provide for reduction of toxicity,
mobility or volume through treatment although some reduction in the
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4S
Alternative 6, Alternative 7, and Alternative 7A reduce contaminant
mobility through stabilization with chemical additives. Volume
is increased by the addition of significant quantities of
stabilizing materials. AlternativeS reduces the toxicity,
mobility and volume of some of the site constituents, but may tend
to concentrate the metals in the incinerator ash.
Alternatives 8 and 9 provide response actions and utilize
technologies which reduce the toxicity or mobility associated with
each site media. On-site treatment reduces the mobility of the
contaminants in the limited volume of sediments that are treated.
The ground water treatment element of assembled alternatives 4
through 9 will significantly reduce the mobility, toxicity and
volume of contamination in the ground water by removing the
volatile organics from the ground water followed by collection and
treatment of the process off-gases. The selected remedy and
Alternative 9 provide the greatest extent of reduction by utilizing
a point of standards application in the shallow zone of the
aquifer. Since Alternative 3 does not provide treatment for ground
water, there will be no reduction in the toxicity, mobility, or
volume of contamination.
Short-term effectiveness. The selected alternative requires no
transportation of hazardous materials through local neighborhoods
or over public highways. The process is performed on site so that
exposure of workers, the public, and the environment to
contaminated materials can be minimized through go~d engineering
practice. soil and sediment remediation is estimated to be
complete within one year. Although there is some short-term risk
associated with the construction of the disposal cell and the
excavation and disposal of the contaminated soil and sediment,
these risks will be managed through careful engineering practice.
The VO.C emissions that might occur during excavation. can be
controlled by working during the cooler months.
Al ternatives 4 and 6A require transportation of excavated materials
through local neighborhoods and over public highways. The short-
term risks related to these activities can be reduced by
establishing and following a project specific safety plan in
-addi tion to strict adherence to all local, state and federal
regulations regarding the transportation of hazardous materials,
but those risks may still be significant.
.
soil and sediment remediation is estimated to be complete within
one year, although for off-site disposal that tin.e is dependent on
the disposal facility's capacity for stockpiling waste delivered
for disposal.
Alternative 3 has some short-term effects since excavation for the
slurry wall will provide a potential for exposure to contaminated
materials. construction of the alternative would not require
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46
extended time periods. All other alternatives which involve
excavation and treatment of soils should be completed in a matter
of months and represent some short-term effects due to the need for
excavation and treat~ent on site. Alternatives involving caps for
containment also pose transportation risks for delivery of
materials to the site. There is a potential for exposure of the
public and the on-site workers to contaminated materials during the
excavation, during anyon-site treatment, and during transportation
off-site depending upon the details of the alternative. Management
practices would be implemented for all such alternatives to
minimize these exposure pathways and risks. .
Under Alternative 5, risks associated with the operation of the
incinerator will be controlled through precise operation and
monitoring of the facility. These controls will be required during
the estimated two years of operation.
Time of implementation may be as long as 30 years for ground water
cleanup and during treatment some small risk can be expected during
the operation of the collection system and the air stripping
facility.
standard safety precautions will be taken during implementation to
minimize potential short-term impacts of these Alternatives,
including proper covering of trucks, dust control, air monitoring
and personal protective equipment.
Implementabili ty. The selected al ternative uses common
construction equipment and readily available technologies. The
technologies for Alternative 3 are readily implement able , requiring
the use of proven, readily available engineering and construction
expertise. Implementability of Alternative 4 and Alternative 6A
may be significantly limited by the availability of disposal
capacity at RCRA compliant facilities. The solidification
technologies used for the selected. al ternative, Alternative 6,
Alternative 7, Alternative 7A, Alternative 8, and Alternative 9,
and the incineration technology used for Alternative 5, are readily
imp1ementable.
The ground water treatment component for Alternatives 4 through 9
depend on proven and readily available equipment and expertise.
The collection and transport systems may require innovative design
features but would be implementable.
Imp1ementabi1ity of access restrictions and other institutional
controls is high because the state owns the property, so that
there is no need to require a private landowner to agree to such
controls.
Cost. So that direct comparisons can be made all costs.are based
on the treatment volumes determined in the FS. The present-worth
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47
independently using unit costs from the FS where larger volumes are
to be treated:
*Alternative 3
*Alternative 4
*Alternative 5
Alternative 6
Alternative 6A
Alternative 7
Alternative 7A
*Alternative 8
*Alternative 9
Selected Alternative
**Proposed Plan Alternative
***Proposed Plan Alternative
$ 7,045,000
$ 7,940,000
$ 8,645,000
$11,140,000
$13,100,000
$12,360,000
$12,395,000
$ 5,930,000
$ 7,450,000
$ 8,119,300
$19,594,000
$19,166,000
* = does not treat or contain all 10~ contaminated soil
** = soil incineration - July 20, 1990
*** = off-site disposal of soil - September 12, 1990
Two additional alternatives which were included as part of the
detailed analysis, were also considered by u.S. EPA. These are:
in-situ vitrification (ISV)
off-site incineration
$ 23,000,000 to $31,000,000
> $150,000,000
Of those alternatives that relied primarily on containment
(Alternatives 3, 8, and 9), Alternative 8 is the least expensive.
Of those al ternati ves that treated the lesser volume of waste,
(Alternatives 4 and 5) Alternative 4 costs less.
Of those alternatives that treated the greater volume of waste on-
site using solidification, Alternative 6 was the least expensive.
Of the remaining alternatives that treat the greater volume of soil
(ISV, on-site incineration (the Proposed Plan Alternative) and off-
site incineration, and off-site treatment/disposal), the off-site
treatment and disposal alternative and the on-site incineration
alternative are the least. expensive. Cost differentials were
determined based on the calculations provided in addition to the FS
and are included in the administrative record.
state Acceptance. The State of Michigan supports the selected
remedial alternative and agrees with EPA that the selected
alternative complies with the Act 307 rules.
community Acceptance. Community acceptance of the selected
alternative has been evaluated in the Responsiveness Summary which
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48
community generally favor remedies which include removal of all
waste from the Berlin and Farro site. u.s. EPA however, must
consider the impact of its remedial activities in the broadest
sense because it is obligated to provide protection of human health
and the environment equally in all communities. In so doing, u.s.
EPA uses appropriate evaluation criteria, to balance long-term and
short-term effects of cleanup activities. Because analysis using
these criteria indicates the effects of the on-site remedy on the
local community are not measurably greater than the effects on
another community in which the waste would be disposed if one of
the off-site remedies were implemented, u.s. EPA can not justify an
off-site remedy in response to community comments.
IX.
THE SELECTED REMEDY
u.s. EPA believes that-the selected remedy, a combination of the
soil and on-site sediment excavation component of Alternative 6 and
the off-site sediment and the ground water components of
Alternative 9, is the most appropriate solution for the site
because of its performance against the nine evaluation criteria
previously discussed. The major components of this combined
remedial alternative include the following:
o
Excavation of contaminated soil and sediment above cleanup
levels from the central site 9rea and sediment from Slocum Drain
(approximately 48,000 cubic yards).
o
Disposal of the excavated materials in a containment cell to be
constructed on site, with treatment of the materials to remove
free liquids and to render characteristic waste
non-characteristic.
o
Treatment of any leachate collected from the containment cell.
Back-filling, topsoil cover, and revegetation of the excavated
on-site areas and regrading of the excavated areas of Slocum
Drain.
o
o
Extraction of contaminated ground water from the shallow
portion of the aquifer through a system of collection trenches
and treatment of the ground water by air stripping, including
control of the off gases and proper management of all residuals.
site deed restriction that prevent installation of drinking
water wells on the site during the remediation.
o
o
Ground water monitoring to assess the state of the remediation
and assure containment of the plume of contamination.
The goal of the ground water element of this remedial action is to
restore ground water to its beneficial use, which is, at this site,
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49
the remedial investigation and on a careful analysis of all
remedial alternatives, u.s. EPA and the state of Michigan believe
that the selected remedy will achieve this goal. It may become
apparent, during implementation or operation of the ground water
extraction system, that contaminant levels have ceased to decline
and are remaining constant at levels higher than their remediation
goal. In such a case, the system performance standards and/or the
remedy may be reevaluated. .
The operating system may include:
a)
discontinuing operation of extraction trenches in areas
where cleanup. goals have been attained1
alternating pumping at trenches to eliminate stagnation
points 1 and
b)
c)
pulse pumping to allow aquifer equilibration and
encourage adsorbed contaminants to partition into ground
water. .
The goal of the soil and sediment element of this remedial action
is to dispose of and appropriately treat those materials which are
demonstrated to exceed contaminant levels which pose unacceptable
risks to human health and the environment.
The selected remedy will include ground water extraction for an
estimated period of 30 years, durinq which the system's performance
will be carefully monitored on a regular basis and adjusted as
warranted by the performance data collected during operati~n.
The estimated cost for this remedy is as follows:
capital Costs: $4,767,300
Annual O&M Costs: $233,100
O&M PW: $3,352,000
Net PW: $8,119,300
A detailed summary of the costs is shown. in the table below.
COST
Annual
Element CaDital QiH O&M PW Net PW
~nstitutional $167,700 $15,000 $230,600 $398,300
Control
Trenches 326,500 2,000 20,800 347,300
Ground water 401,800 93,200 1,432,700 1,834,500
treatment &
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50
Ground water &
surface water
monitoring
374,500
82,500
1,268,200
1,642,700
Landfill
Construction
' 771,000 15,400 15,400 786,400
2,725,800 25,000 384,300 3,110,100
$4,767,300 $233,100 $3,352,000 $8,119,300
Excavation
Total
z.
DOCUMENTATION OF SIGNIFICANT CHANGES
A Proposed Plan was released for public comment in July 1990. The.
Proposed Plan identified on-site incineration of approximately
38,000 cubic yards of contaminated soil and sediment and ground
water extraction and t~atment to be appropriate for the Berlin and
Farro Site.
During the public comment period residents near the site and
potentially responsible parties expressed strong opposition to the
use of on-site incineration. This opposition was based on the
short term risk presented by the estimated 380 days of operation of
the on-site incinerator. In addition, information was provided
indicating that much of the volume of soil proposed to be
remediated was to be treated based only on metals contamination.
Incineration is not generally considered an effective treatment
with metals, and in fact, may produce treatment residuals that
could require significant additional treatment. As a result, U.S.
EPA, in consultation with MDNR, considered excavation and off-site
disposal of the contaminated soil and sediment.
After evaluation of all current information including uncertain
implementability due to questionable availability of adequate
disposal capacity, the advisability of using hazardous waste
disposal capacity for materials with relatively low levels of
contamination, and the transportation risks associated with off-
site disposal, u. S. EPA has selected excavation and on-site
disposal as the alternative which best addresses the soil and
sediment contamination at the site and meets the requirements of
the NCP and of Michigan Act 307. The selected alternative will
provide protectiveness and long term effectiveness equivalent to
that which would be provided by an off-site facility since the
technical design requirements are the same for both.
The selected alternative for soils and sediments incorporates the
excavation element of alternative 6 in the FS and disposal in an
on-site cell which will meet the technical requirements of RCRA and
Michigan Act 64 and is considered a logical outgrowth of that
al ternative. The solidification prior to disposal will be required
if the excavated soils exhibit characteristics of RCRA hazardous
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the NCP off-site disposal of hazardous substances or contaminated
materials without treatment should be the least favored alternative
where practicable treatment technologies are available.
XI.
STATUTORY DETERMINATIONS SUMMARY
1. Protection of Human Health and the Environment
The selected remedy provides adequate overall protection of human
health and the environment, by removal and off-site treatment and
disposal of contaminated soils and sediments and by pumping and
treating the ground water. Institutional controls will be
implemented during remediation to assure protection until
confirmation sampling and analyses indicate that a health based
cleanup has been achieved.
Any short term risks associated with excavation and transportation
of contaminated soils and sediments (dust generation) will be
minimized by the use of standard construction practices. Air
monitoring will be conducted to assess possible exposure during
remedial action.
No environmental impacts have been identified for the site. This
is largely due to the fact that impacts from the site have been to
the ground water, soil, and sediment in the site areas where
. disposal activities took place. .
2.
Attainment of ARARs
The selected remedy will be designed to meet all applicable or
relevant and appropriate requirements (ARARs) of Federal and more
stringent state environmental laws. The following discussion
provides the details of the ARARs that will be met by the selected
alternative.
Action-specific ARARs:
Clean Water Act (CWA) of 1977, as amended [33 V.S.C.
1251)
40 CFR 122 and 40 CFR 12S - The National Pollutant
Discharge Elimination system (NPDES), which specifies the
scope and details of the NPDES permit applications,
including limitations, standards, and other permit
conditions which are applicable to all permits including
specified categories of NPDES permits, Also specifies
schedules of compliance and requirements for recording
and reporting monitoring results. Administered by MDNR
under Michigan Public Act 245, Part 21. The substantive
requirements of these parts will apply to the ground
water to be discharged after treatment in the air
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Ac~ 348 of ~he Public Ac~. of 1965, as amended:
Po11u~ioD Ac~
Air
Part 2 - Air Use Approval, which specifies information
required for a permit to install, construct, reconstruct,
relocate, or alter any process, fuel burning or refuse
burning equipment, or control equipment which may be a
source of air contamination. The substantive
requirements of this part will apply to construction of
the air stripper.
Parts 3, 7 and 9 - Emissions, which specifies emission
limitations for particulates, fugitive dust, VOCs, and or
contaminants which may be injurious to or adversely
affect human health or welfare, animal life, vegetation,
or property, or interfere with normal use and enjoyment.
The substantive requirements of these parts will apply to
the operation of the air stripper and construction and
excavation activity performed to implement the
remediation of contaminated soil and sediment.
Part 10 - Intermittent Testing and Sampling, which may
require performance of acceptable performance tests. The
substantive requirements of this part will apply to the
air stripper.
Resource Conservation and Recovery Act, subtitle C (RCRA),
19761 V.S.C. 69011 Michigan Hazardous Waste Managemen~ Ac~,
PA 64
40 C.F.R. 264 - Subpart F - Ground Water Protection
Standards, which provide technical requirements for long-
term monitoring. These requirements will apply while the
ground water treatment element is active and for at least
the first five year review period following completion of
the ground water cleanup.
40 C.F.R. 262 Regulations for Hazardous waste
Generators, Michigan Hazardous Waste Management (MHWM)
rules, Part 3, R299. 9301 - Generators of Hazardous
Waste, provide requirements for the shipment of wastes to
treatment, storage or disposal facilities. These
requirements may apply to off-site shipment of treatment
residuals.
40 C.F.R. 263 - Department of Transportation (DOT)
Hazardous Materials Transportation Act, 49 U.S.C. 1801;
MHWM Rules, Part 4, R299. 9401 to 9412; Transporters of
~azardous Waste, require record keeping, reporting, and
manifesting of waste shipments. These requirements may
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<;
40 C.F.R. 264 - Subpart B - General Facility Requirements,
which establish substantive requirements for. security,
inspection, personnel training, and materials handling are
relevant and appropriate for on-site activities involving
excavations and handling of hazardous soils and sediments.
40 C.P.R. 264 - Subpart D - Contingency Plan and Emergency
Procedures, which establish substantive requirements for
- emergency planning are relevant and appropriate for on-site
activities involving excavation and handling of hazardous
soils and sediments.
40 C.F.R. 264, Subpart G - Closure and Post-closure, which
establishes substantive requirements for closure performance
and equipment decontamination, is relevant and appropriate for
on-site activities involving handling of hazardous soils and
sediments, and the construction and maintenance of the on-site
containment cell and cap.
40 C.F.R. 264, Subpart Nl MHWM Rules, Part 6, R. 299.9619-22 -
Landfills, which establish standards for construction of
hazardous waste landfills are relevant and appropriate to
construction of the on-site cell an~ cap.
40 C.F.R. 268 - Landfill Disposal Restrictions, which may
require that wastes meet identified treatment standards before
they can be land disposed are applicable to any treatment
residues to be land disposed off-site and are relevant and
appropriate to the .extent that contaminates soils and
sediments to be put in the on-site cell exhibit any of the
characteristics of hazardous wastes under 40 C.F.R. Part 261.
Chemical-SDecific ARARs:
Clean Water Act (CWA) of 1977, as amended [33 V.S.C.
1251]
40 CFR 129 - Toxic Pollutant Effluent Standards, which
establish toxic pollutant effluent standards and
prohibitions of specific compounds for specified
facilities discharging into navigable waters. 40 CFR
129.104 sets the ambient water criterion in navigable
waters. These requirements may apply to the discharge of
treated ground water after treatment in the air stripper.
Clean. Air Act of 1963, as amended [42 0.8.0. 7401]
40 CFR 50 - National Primary and Secondary Ambient Air
Quality Standards, which establish national primary and
secondary ambient air quality standards. The appendices
provide methods and procedures for measuring specific air
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of the air stripper.
40 CFR 61 - National Emission Standards for Hazardous Air
pollutants, which identifies substances that have been
designated hazardous air pollutants, and for which a
. Federal Register notice has been published, and specifies
prohibited activities, describes procedures for
determining whether construction or modification is
involved, prescribes methods of applying for approval,
and covers the manner in which start-up notification is
to be provided. The substantive requirements of this
part may apply to operation of the air stripper.
Act 245 of the Public Acts of 1929, as amen~e~: Water
Resources Commission Act
Part 4, Rule 57 - Water Quality Standards (Surface Water
Quality Standards), which establishes limits for all
waters of the. State for the following components:
dissolved solids, pH, taste and odor producing
substances, toxic substances, total phosphorous and other
nutrients, and dissolved oxygen. These requirements will
apply to the discharge of ground water after treatment in
the air stripper.
Rule 98 - Antidegradation, requires maintenance and
protection of existing waters when water quality is
better than water quality standards. These requirements
will apply to the discharge of ground water after
treatment in the air stripper.
Part 22 - The State has identified this rule as an ARAR.
The State concurs with the remedy selected, and has
stated that in applying Act 307 requirements to the
ground water treatment, the remedy selected will satisfy
the requirements of Act 245. The United states disagrees
that Act 245, as interpreted and applied by the state in
this matter, is an ARAR. This issue is the subject of
litigation in u.s. v. Akzo coatings of America, appellate
case numbers 89-2902 and 80-2137, and may be reassessed
after a decision has been rendered.
Act 348 of the Public Acts of 1965, as amen~e~:
Pollution Act.
Air
Part 3 Emission Limitations and Prohibitions
Particulate Matter, which establishes standards for the
density of emissions and emission of particulate matter.
These standards will apply to operation of the air
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Ac~ 307, Micbigan Environmental Response Ac~. The rules
promulgated pursuant to ~he Act set requirements for
evaluating remediation of hazardous waste sites in
Michigan. There are three types of remediation specified
by this act: Type A, B, and C. The Type C substantive
requirements apply to the soil and sediment remedy and
Type A and Type B substantive requirements apply to the
ground water remedy.
Ac~ 3.7 of ~b. Public Ac~. of 19721
Sedimenta~ion Control Ac~
80i1 Erosion and
Part 17 - soil Erosion and Sedimentation Control -
Establishes general soil erosion and sedimentation
control procedures and measures. Also, specifies earth
change requirements and soil conservation district
standards and specifications. The substantive
requirements of this part may apply to the soil and
sediment remediation.
3.
Cost-EffectiveneS8
The selected remedy provides overall cost-effectiveness. A high
degree of permanence is achieved by excavation,treatment, and on-
site disposal o~ the contaminated soil and sediments in a hazardous
waste cell and by extractir.m and treatment of the contaminated
ground water and of any leachate from the containment cell. The
selected remedy can be implemented at a cost 27-58 percent less
than other remedies which address the 1 X lO-6risk level soil and
provide effectiveness and permanence equal to that provided by off-
site remedies.
4.
utilization of Permanen~ Solutions and Alternative. Treatment
Technologies or Resource Recovery Technologies ~o ~be
Maximum Extent Practicable
The selected remedy provides the best balance with respect to the
nine evaluation criteria as described in section IX of this Record
of. Decision. Treatment technologies are utilized to the maximum
exten~ practicable by excavation, and on-site treatment when
required and disposal of the contaminated soil and sediment in a
secure cell were any leachate will be collected and treated, and by
treatment of contaminated ground water by pump and treat, which
includes treatment of stripped volatiles. This alternative is
further balanced with respect to the nine criteria because a
permanent solution which utilizes treatment technologies is being
selected. The ground water monitoring component of the selected
remedial action will assure that concentrations of contaminants do
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56
5.
preference for Treatment as a Principal Element
By treating the contamination in the ground water and soil where
required for on-site disposal, and treatment of any accumulated
leachate, the selected remedy satisfies the statutory preference
for remedies that employ treatment of the principal remaining
threat which permanently and significantly reduces toxicity,
mobility, or volume of hazardous substances as a principal element.
The selected remedy reduces the principal threats at the site,
direct contact with and ingestion of contaminated soil and sediment
by the use of on-site containment in a hazardous waste disposal
cell, with some .treatment. Treatment of all of the remaining
threats due to soil and sediment contamination at the site was not
found to be appropriate based on site-specific risk factors.
Treatment is a principal element of the ground water remedy which
reduces the risk of-exposure through ingestion and direct contact
with the contamination in the ground water by use of pump and treat
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