United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EB93-964105
EPA/ROD/R05-92/198
July 1992
c/EPA Superfund
Record of Decision:
Bofors Nobel (Amendment),
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REPORT DOCUMENTATION \1. REPORTNo. I ~ 3. Recipient's Accession No.
PAGE EPA/ROD/ROS-92/198
4. TItle 8nd Subtl1le 5. Report Date
SUPERFUND RECORD OF DECISION 07/22/92
Bofors Nobel (Amendment), MI 6.
First Remedial Action (Amendment) - Final
7. Aulhor(s) 8. Pltrformlng Organiza1l0n RepL No.
8. Pltrtonnlng Org8Iniza1l0n Name 8nd Add- 10. Projec1lTuklWork Unit No.
11. Contr8ct(C) or Grant(G) No.
(C)
(G)
1~ SponaorIng Organlz8llon Nune 8nd AdcIr.- 13. Type of Report & PerIod Covered
U.S. Environmental Protection Agency 800/000
401 M Streetr S.W.
Washington, D.C. 20460 14.
15. SUppl8m8ntUy No...
PB93-964105
1L Ab81r8ct (Umlt: 200 _rda)
The 8S-acre Bofors Nobel site contains an active specialty chemical production plant in
Egelston Township, Muskegon County, Michigan. Site features include an unused
landfill, an active ground water pumping and treatment system, and 10 abandoned sludge
lagoons. Onsite wetlands lie within the floodplain of Big Black Creek, which runs
through the southern portion of the site. The site overlies a lacustrine aqui fer I a
potential drinking water source, which has been contaminated as a result of site
activities. From 1960 to 1976, the plant produced alcohol-based detergents, saccharin,
pesticides and dye intermediates, discharging sludge, wastewate r, and waste liquids
into the 10 onsite lagoons. Subsequent state investigations identified eight of the
onsite lagoons as potential sources of ground water contamination. In 1976, the state
restricted wastewater discharge from the site, and a ground water pump and treatment
system was installed to pretreat waste prior to discharge to the POTW and to treat
contaminated ground water in the lacustrine aquifer. This ROD amends a 1990 ROD
written by the state, which consisted of onsite incineration and onsite landfilling of
lagoon area soil, construction of RCRA-type secure landfill cells to hold
non-incinerated material and ash from the incinerated sludge, and construction of an
(See Attached Page)
17. Documen1 AnaIy8I8 .. De8crlptora
Record of Decision - Bofors Nobel (Amendment), MI
First Remedial Action (Amendment) - Final
Contaminated Media: soil, sludge
Key Contaminants: VOCs (benzene)
b. 1den1lfi8nlOpen-Ended Tenna
c. COSAl1 ReIdIGroup
18. AV8II8bl1ty St8temenI 19. Security CI... (This Report) 21. No. 01 Psges
None 22
I 20. Security CI... (This Page) ~ Price
Nonp
272 (4-77)
(See ANSl-Z38.18)
See InsltUcli- on lie.,.,.,
(Fonnerty ~)
DepaI1ment 01 Commerce
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"
EPA/ROD/R05-92/198
Bofors Nobel (Amendment), MI
First Remedial Action (Amendment) - Final
Abstract (Continued)
onsite ground water treatment facility with extraction and onsite treatment of
contaminated ground water. Since that time, an EPA predesign site investigation was
conducted as part of the remedial design which revealed that a larger volume of
contaminated material was present at the site than was originally believed, and that
there would be inconsistent treatment of contaminated material with the same level of
risk. Additionally, the cost and logistics involved in incineration were greater than
originally believed, and the large increase in volume would also significantly lessen the
effective reduction in risk achieved by incineration. A subsequent final ROD will
address other contaminated soil and establish clean-up criteria for ground water. This
ROD Amendment replaces incineration as the treatment technology for soil and sludge. The
primary contaminants of concern affecting the soil and sludge are SVOCs, benzidine and
dichlorobenzidine.
The selected amended remedial action for this site includes excavating and containing
approximately 767,000 cubic yards of untreated sludge and soil in onsite RCRA-type secure
landfill cells constructed as part of the original remedial action; expanding and
upgrading the unused landfill adjacent to the lagoon area to meet the requirements of a
RCRA-type landfill; storing lesser contaminated material in the unused landfill;
installing extraction wells downgradient of the unused landfill as a tertiary leachate
containment system; and monitoring the landfill and existing leachate collection system.
This ROD Amendment does not address any issue associated with ground water treatment.
The estimated present worth cost for this amended remedial action is $45,498,216, which
includes an annual O&M cost of $89,030 for 3 years.
PERFORMANCE STANDARDS OR GOALS:
EPA has determined that landfilling of contaminated soil and sludge
provides the equivalent level of protection to human health and the
site-related risks as that provided by the remedy in the 1990 ROD.
criteria will be addressed in a subsequent final ROD.
without treatment
environment from
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vL}' g - -t--? z..
.'
DECLARATION FOR THE AMENDMENT TO THE RECORD OF DECISION
PURPOSE
This decision document presents the amendment to the Record of
D~cision (ROD) for Operable Unit #1 (OU #1) at the Bofors Nobel
site, in Muskegon, Michigan, 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 Contingency Plan (NCP).
BASIS
The decision to amend the ROD is based upon the administrative
record. The index attached to the amended ROD identifies the items
that comprise the administrative record upon which the sel~ction of
the remedial action is based.
:..i'
DESCRIPTION OF THE AMENDMENT
The remedy selected in the ROD for OU #1 was a final remedial
action for the lagoon area soils and an interim action for site
ground water. The remedy consisted of on-site incineration and on-
site landfilling for the lagoon area sludges, on-site landfilling
of lagoon area soils, construction of an on-site ground-water
treatment facility with extraction and on-site treatment of
contaminated ground. water. The amendment to the ROD eliminates
incineration as a treatment technology for the site. All hazardous
material will be placed in the on-site landfill that will be
constructed as part of the remedial action selected in the ROD.
STATUTORY DETERMINATIONS
The selected remedy" in this amendment 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 0 However, because treatment
of the principal threats of the site was not found to be
practicable or cost-effective, this remedY does not satisfy the
statutory preference for treatment as a principal element. Because.
this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted within fiv~
years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and
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"
The State of Michigan concurs on the selected remedy in this
amendment.
1
.Q.~, ,.).1 ) I;di'l-~
?/ D E
ar/4 dtZL/"
Valdas'V. Adamkus
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.'
IN'l'RODUCTION
;.I.
The Bofors Nobel (Bofors) site is located 6 miles east of downtown
Muskegon on Evanston Road in Egelston Township, Muskegon County,
Michigan (see Figure #1). This 8S-acre site includes a currently
operating specialty chemical production facility, an unused
landfill, a currently operating ground-water pumping and treatment
system, and 10 abandoned sludge lagoons. The southern portion of
the site is bounded by Big Black Creek. There are wetlands within
the Big Black Creek floodplain on either side of the creek (see
Figure #2).
The 'Record of Decision (ROD) for operable unit '1 (OU '1) was signed
on september 17, 1990. It addressed contamination in the lagoon
sludges, in the soils under and around the lagoons, and in ground
. water (see Figure #3). Sludge remediation was addressed through
on-site incineration and on-site landfilling. Soil remediation was
addressed through on-site landfilling. An interim action for
ground-water was addressed through construction of an on-site
ground-water treatment facility and upgrading the existing pumping
and treatment system. The ground-water remedy was an interim
action because no risk based cleanup numbers were available under
Michigan Act 307 at the time the ROD was signed. The ground-water
extraction well system provides containment of ground water and
hal ts any potential migration of> contaminated ground water off.
site. This document amends the OU #1 ROD and provides for
elimination of incineration as a treatment technology for the site,
All hazardous material that was originally intended for
incineration will be placed untreated in the on-site landfill,
This amendment is based on information from the United states Army
Corps of Engineers (Corps) pre-design study, 30% design document
for incineration and landfilling operations, and the Feasibility
Study for OU '1. The information contained in these documents
indicates that incineration is impracticable and not cost-effective
in dealing with the contamination in the lagoon area soils at this
si te "
The lead agency for the remedial actio~ at this site is the United
States Environmental Protection Agency (U.S. EPA). The State of
Michigan Department of Natural Resources (MDNR) is the support
agency. This ROD amendment will become part of the Administrative
Record File.
Under CERCLA ~ 117 and section 300.435(C) (2) (ii) of the NCP, the
lead agency is required to propose an amendment to the ROD and
allow the public the opportunity to comment on the proposed changes
if the differences in the remedial action alter the basic features
of the ROD. A public meeting for the original ROD was held on
August 1, 1990. The proposed amendment to the ROD was made
available to the public 'on April 6, 1992. The public meeting was
held April 16, 1992, at the Egelston Township Hall, Muskegon,
Michigan. A response to the comments received during this period
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FIGUP.Z it 1
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is included in the Responsiveness Summary, which is part of this
Amendment to the Record of Decision.
The information repositories for this site are located at:
Ege1ston Township Hall
5382 East Apple Avenue
Muskegon, MI 49442
Hackley Library
316 West Webster street
Muskegon, MI 49440
The administrative record, which contains the information upon
which remedy selection is based, is available at:
Hackley Library
3~6 West Webster street
Muskegon, MI 49440
SITE HISTORY
:,1
From 1960 to 1976, the plant produced alcohol-based detergents,
saccharin, pesticides, herbicides, and dye intermediates. The
lagoons were used for wastewater and sludge disposal until 1976.
A ground-water extraction and treatment system was installed in
1976. The site was placed on the National priorities List in March
1989. The MDNR, with review by1J.S. EPA, conducted a Remedial
Investigation from the winter of 19~7 to the summer of i989. The
ROD for OU *1 for the site was signed on September 17, 1990,. which
addressed source control in the lagoon area through construction of
a ground-water treatment facility, incineration of the lagoon
sludges (approximately 108,000 cubic yards)", and construction of
RCRA-type secure landfill cells to hold non-incinerated material
(approximately 426,500 cubic yards) and the ash from the
incinerated sludges.
REASONS FOR ISSUING THE ROD AMENDMENT
Following the signing of the ROD on september 17, 1990, the Corps
was tasked by the U.S. EPA to perform the Remedial Design for OU #1
. at Bofors. As part of the design effort, a pre-design site
investigation was performed to refine the Feasibility study
estimate of the horizontal and vertical extent of contamination at
the site and to establish design parameters for the incineration
technology. Information gathered during this pre-design
investigation has provided critical data which has caused the u.S.
EPA to re-evaluate the use of incineration as a treatment
technology at the site. Reasons for this re-evaluation include
that a much larger volume of contaminated material is present at
the site than was originally believed, that there. would be
inconsistent treatment o.f contaminated material with the same level
of risk, and that the cost and logistics involved in incineration
are. much greater than originally believed. Further, the large
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increase in vOlume'significantly lessens the effective reduction in
risk achieved by incineration of those materials the ROD determined
should be incinerated.
The soil borings taken as part of the pre-design site investigation
established that the volume of contaminated soil that would need to
be contained in the on-site landfills is approximately. 697,000
cubic yards. The original estimate from the Feasibility Study
report was 334,700 cubic yards. This large difference is' due to
the fact that in the Feasibility study, an assumption was made that
the contamination in soils around most of the lagoons only extended
to a depth of five feet. Soil borings taken during the pre-design
study indicated that most of the soil around the lagoon area was
contaminated down to the water table. In addition, the pre-design
investigation found that three hot spots (localized areas of highly
contaminated soils) identified in the Feasibility Study for OU #2
are actually contiguous to the contaminated soil in au #1
(identified as HS1, HS2, and HS3 in Figure #4). OU'2 will address
the contaminated soils in the operating plant area and establish
the 'final clean-up objectives for ground water at the site. The
division of the site into operable units was based on the need to
subdivide the site into more manageable components and to address
the greatest threat to human health and the environment first. It
was not based on any physical requirements associated with the
site. The new information from thEfpre-design study indicates that
the contamination from the hot spots would be better defined as
part of the soil contamination from au #1 and should be treated
with that material. The additional volume of soil from the hot
spots is approximately 70,000 cubic yards. consequently, this
would bring the total volume of contaminated soils that would need
to be placed in the on-site landfills to approximately 767,000
cubic yards.
The. evaluation of remedial actions in the Feasibility Study and ROD
defined the principal threat wastes as site material containing the
.highest concentration of the "chemicals of concern". Based on
information from the Feasibility Study report, the determination
was made that incineration of 108,000 cubic yards of selected
sludges and berms would reduce the overall amount of contamination
at the site by approximately 64%. The pre-design study conducted
by the Corps has found that the Feasibility study report
underestimated the volume of contaminated soils at the site. The
Feasibility study identified 188,000 cubic yards of soil with a
risk greater than 10-2 (1 in 100 additional risk of cancer). The
estimate from the pre-design study was that there are approximately
390,000 cubic yards of soil with a risk greater than 10'. The pre-
design study also found that there were a total of approximately'
697 , 000 cubic yards of contaminated soil that would need to be
contained in the on-site landfill. cells instead of only 334,70~
cubic yards as identified in the Feasibility Study. Based on this
information, only 38% of the contaminant mass would be destroyed by
incineration instead of 64% as estimated in the ROD. The majority
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DCI A.D II.aIDI.1 .OT '''OT CI.TI.AnD I. fl'"
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AR IS ACID RECovERY BORING DRILLED
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AND THE DATA SHOUlD BE CONSIDERED
ACCURATE ONLY TO THE DEGREE IMPL.IED
BY THIS METHOD.
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of site contamination pursuant to the original ROD, approximately
58%, is in the site soils (as opposed to the sludges) and was to be
contained without treatment in the on-site landfills. For this
reason, 'incineration of site sludges is not an effective
remediation strategy to reduce the overall amount of contamination
at the site. '
u.s. EPA policy (November 1991) recommends that risk levels playa
major consideration in determination of principal threat wastes.
The original ROD defined the principal threat wastes only as site
material containing the highest concentration of the "chemicals of
concern". An evaluation of site materials identified in the
Feasibility study using levels of risk to identify principal threat
wastes revealed that, in addition to the 108,000 cubic yards of
contaminated sludges and berms, there are an additional 188,000
cubic yards of contaminated soils with a risk equal to that posed
by site sludges and berms. The incineration strategy as outlined
in the original ROD did not address this additional 188,000 cubic
yards of contaminated soils.' Because this volume of soils was to
be landfilled without treatment, the inc'ineration of the sludges
alone would not significantly add to the reduction of the overall
site risk and would not provide any additional benefit to the site.
In addition, information from the pre-design study conducted by the
Corps indicates that the actual amount of material with a risk
equal to site sludges is much '>larger than predicted in the
Feasibility study report. The current best estimate of material,
both soils and sludges, with a' risk greater than 10.2, is
approximately 497,000 cubic yards. Treatment of this volume of
material by incineration is considered impracticable and not cost-
,effective. This volume of material would require approximately 5
years just to conduct the actual incineration. Additional time
would be required to construct the incinerator and to conduct the
trial burn. The cost to incinerate 497,000 cubic yards of material
is estimated at $114,000,000. This would bring the estimated total
cost to remediate OU #1, including contingencies, to approximately
$221,000,000. .
The pre-design study included, a sub-scale incineration
investigation conducted by' the U. s. 'EPA Incineration Research
Facility in Jefferson, Arkansas. The preliminary results indicate
that there are several waste related issues' that were unknown
during the preparation of the Feasibility Study. Some of the
sludge from the site has a higher BTU value (energy content) and
water content than previously identified. An increase in either
BTU or water content can decrease the amount of material that can
be incinerated per hour and~ therefore, increase the amount of time
and the cost to incinerate the sludge. Alternatively, the BTU and
water content of these sludges may be reduced by mixing with either
other sludges or dirt with lower BTU and water content to produce
a single material with more homogeneous values. 'Pre-mixing of all
sludges would produce a feed with homogeneous characteristics but
the difficulty of handling, mixing and storage of 108,000 cubic
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yards of material. prior to the incineration makes this option
impracticable. The space available on site is limited and the
sequencing required to construct the various landfill cells makes
it difficult to identify a suitable area large enough to store this
volume of material. The storage space required for 108,000 cubic
yards is equivalent to two football fields piled 32.5 feet high.
The sludge is thixotropic and becomes more .fluid with hand1,ing. It
would be difficult to pile the material to any significant height
without measures to stabilize the mass. An additional concern is
the potential air emissions which could be released from the sludge
during handling. Mixing would greatly increase the risk of any
potential releases.
:.1
The wide variance in BTU and water contents cause an additional
concern with establishing criteria for the test burn of any
incinerator that would operate at the site. Selection of which
sludge or mixture of sludges used during the test burn would
establish the operation and compliance criteria for the incinerator
for the life of the project. Variability in feed material would
make it very difficult to optimize facility operations and could
mandate several test burns to establish criteria for the various
sludge types.
The pre-design study conducted by the Corps evaluated the placement
of the landfill cells, on-site 'incineration facility ~ and the
ground-water treatment facility .';I'he following summarizes the
findings of the Corps I pre-design study. The constricted nature of
the site would increase the difficulty of sequencing construction
of the various facilities, construction of the various landfill
cells, and construction of facilities for temporary storage of
sludge prior to incineration. Factors that would make
implementation of the remedial action very difficult include: 1)
the incinerator can not be constructed on site until an initial
area has been cleaned and compacted to support its foundation; 2)
the incinerator would occupy space that would otherwise be used in
landfill cell construction; 3) it would be necessary to construct
temporary storage facilities to house sludge prior to incineration
(generally a two day supply); and 4) it would be necessary to
construct temporary storage facilities to house ash from the
incinerator prior to landfilling. Delays in incinerator operation
would delay final closure of the landfills since ash from the
incinerated sludges would be placed in one of the on-site landfill
cells.
When the information gathered during the pre-design study indicated
that the use of incineration was no longer an appropriate remedial
action for OU #1, the U.S. EPA re-evaluated the spectrum of.
potential alternatives included in the Feasibility Study. This
list of the potentially applicable technologies which could be used.
to deal with the contaminants at the site is presented in Section
2.4 and Appendix D of the OU '1 Feasibility Study. The list
includes 11 methods of containment, 15 methods of incineration,
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various disposal options, as well as biological remediation, soil
vapor extraction, chemical extraction, soil washing, soil flushing,
~ehalogenation, low temperature thermal desorption (LTTD) ,
sOlidification/stabilization, microencapsulation, vitrification,
and in-situ vitrification.
Thermal treatment by LTTD was eliminated from further
consideration. The results from the treatability study performed
as part of the Feasibility study show that LTTD failed to
adequately treat. all contaminants of concern at the site and
achieve appropriate clean up standards. In addition, the cost of
implementing LTTD treatment was shown to be similar to
incineration.
SOlidification/stabilization technologies were eliminated because
a review of treatability data from the Feasibility Study (Appendix
E) showed that contaminants of concern would leach through the
~olidified or stabilized matrix at elevated concentrations. This
rendered the technology ineffective as a stand-alone treatment.
The use of sOlidification/stabilization technologies or of a
dewatering agent in conjunction with landfilling of the sludges was
also considered. . The purpose of a dewatering agent would be to
remove residual moisture from sludges and help prevent the
potential formation of leachate. Discussions with the Corps and
experts on this type of technoloqy pointed out that it would be
impracticable to trea't the organic ..chemicals of concern at this
site by sOlidification/stabilization and the liner/leachate
collection systems of the landfill cells would actually provide the
necessary protection of the ground water from the contaminants
contained within the landfill cells. Potential technical
difficulties were also identified which included clogging of the
leachate collection system, a significant increase in the volume of
material to be placed in the landfill cells, and an increase in air
emissions. Because of the extremely large volume of waste that
would need to be contained in the landfill cells, the contingency
.space would be limited. Any nonessential increase in the amount of
material to be contained in the cells would have an adverse impact
on landfill construction and could increase operation and
maintenance (O&M) costs. The interaction between the dewatering
'agent and sludge cculd generate sufficient heat to increase air
emissions during the landfilling process. The benefit gained by
use' of a dewatering agent would not provide any significant
reduction. in site risks which would not be otherwise provided by
landfilling of the. untreated sludges. For these reasons, the use
of a dewatering agent was not considered appropriate for the site.
Soil 'washing technology was also dismissed as a treatment prior to
landfilling. Treatability studies indicated that this technology
was not technically effective or cost-effective in remediating
soils at the site to risk-based levels.
None of the technologies considered for treating the sludges and
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. .
soils prior to landfilling were able to achieve cleanup goals in
treatability studies performed. Further problems were identified in
the re-evaluation of various treatment technologies that resulted
from the pre-design study. The added costs of' these treatment
technologies would not provide significant additional risk
reduction at the site over landfilling alone.
In summary, the use of on-site incineration was determined
inappropriate and not cost-effective. This was due to the lack of
significant risk reduction from implementation of this technology,
and the significant engineering and logistical problems associated
with the construction' of the remedy. In addition, none of the
other remedial technologies considered were suitable for the site.
DESCRIPTION OF THE NEW ALTERNATIVE
Estimate of the cost and time required to
Amendment alternative of landfilling:
implement the ROD
capital:
Annual Operation & Maintenance (O&M):
Present Net Worth:
Implementation Time (Total Action):
()
$44,583,522
$89,030
$45,498,216
3 years
:J
This ROD Amendment does not address any issue associated with
ground water or deal with the design of the ground-water treatment
facility. The capital costs associated with the construction of
that facility are currently estimated at approximately $11,000,000.
The cost of ground-water treatment is not reflected in this ROD
Amendment. The total estimated capital cost of OU 'I, including
implementation of this amendment and construction of the ground-
water treatment system, will be approximately $56,000,000.
The ROD for OU 'I called for incineration of approximately 108,000
_cubic yards of contaminated sludges and berms with a risk of
greater than 10-2. The resultant ash would then be contained in on-
site landfill cells. This remedy fa.ils to provide consistent
treatment to approximately 400,000 cubic yards of soils with the
same risk level. Por this reason, incineration does not provide
any additional reduction in site risks associated with the
conta~inated sludges and soils in the lagoon area.
The U.S. EPA has determined that landfilling of the sludges and
soils without treatment provide the equivalent level of protection
to human health and the environment from site related risks as that
provided by the remedy in the original ou 'I ROD. The untreated
sludges and soils will be contained in on-site RCRA-type secure
landfill cells constructed as part of the ~riginal remedial action
at the site. Additional information concerning the design
requirements for these cells is contained in the original ROD. The
landfill cells include two liner and leachate collection systems.
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All landfill cells will be upgradient of the ground-water
extraction wells which are used to maintain capture of contaminated
ground water at the site. All ground water passing under the
landfill cells will be captured by this extraction system. Because
contaminants will remain in the aquifer after conclusion of the
remedial action for this operable unit, the extraction system is
scheduled to. remain in operation perpetually or until ground-water
cleanup criteria are reached. These cleanup criteria will be
established as part of the ROD for OU #2. However, regardless of
the status of the ground-water treatment system, the landfill and
leachate collection system will be continually monitored. If
leachate is detected and collected it will be treated in the
ground-water treatment system.
Should leachate form despite infiltration protection provided by
the cap, it would be trapped by either the primary or secondary
liner and leachate collection systems of the landfill cells and
then be treated at the on-site ground-water treatment facility.
Should the primary liner and leachate collection system (typically
consisting of a graded filter layer, a geotextile layer, a drainage
layer, an impermeable flexible membrane liner such as 60 millimeter.
thick high density polyethylene, and 5 feet of compacted clay with
a permeability of not greater than 10-7 cm/sec) fail, leachate would
be trapped by the secondary liner and leachate collection system
(typically consisting of a drainag~ layer, an impermeable flexible
membrane liner such as 60 millimeter thick high density
polyethylene, and 3 feet of compacted clay with a permeability of
not greater than 10-7 cm/sec). Should the entire multi-layer liner
and collection systems of the RCRA type landfill cell fail, the
leachate would be captured by the 'ground-water extraction system
and treated along with contaminated ground water in the ground-
water treatment facility.
Since landfilling is a component of the original ROD, capital and
O&M costs for the landfill are accounted for in the original cost
~stimate of the Feasibility Study and is a factor for both the
remedy selected in the original ROD and this ROD amendment. The
cost estimate proposed for the Remedial Action in the original ROD
was approximately $72,000,000. During early stages of the design,
errors in the estimate were identified by the Corps and the working
estimate for the design rose to between $100,000,000 and
$120,000,000. The current cost estimate to incinerate 108,000
cubic yards of contaminated sludge (without evaluating the impact
of the engineering design issues identified in the pre-design study
such as higher BTU content and higher water content of some of the
sludges) is expected to be approximately $30,313,000. This cost
includes mobilization, trial burns, demobilization, process area
foundation, and incineration of 116,452 tons of sludge at a cost of
$220/ton. For all construction activities, the Corps estimates
that an additional 43% of the remedial action costs should be added
to the total cost. This 43% accounts for cost growth,
contingencies, oversight and administration. This brings the
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projected cost of incineration and handling of the resultant ash to
$43,476,000.
',I
. .
One of the purposes of the pre-design investigation was to
establish what was the actual extent of contaminated soils around
the lagoons. These volumes were only estimates in the original
ROD. Any additional volumes of contaminated soil identified in the
pre-design investigation would need to be contained in the landfill
cells which would be constructed on-site. The cost associated with
this increased volume of material identified during the pre-design
would be the same for either the remedial action or the amendment
alternative and is therefore not reflected in the cost of this'
amendment. This would mean that the total cost savings of
instituting this amended remedy would be approximately $43,476,000.
Because of the uncertainties involving incineration of the lagoon
sludges identified in the pre-design study, it is very likely that
additional costs associated with either incineration or material
handling would be identified prior to the conclusion of the design
or during the start up of the system.
The three hot spots identified in the Feasibility study for the
proposed OU #2 ROD will be included for disposal along with the
soils and sludges of OU #1. The volume of soil from the three hot
spots is estimated at approximately 70,000 cubic'yards.
<=>
The volume of soils and sludges required to be landfilled on-site
is approximately double the volume anticipated in the original ROD
for au #1. Because of this large increase in volume, it will not
be possible to construct a landfill within the confines of the
lagoon area that will be large enough to hold the entire mass. The
unused landfill adjacent to the lagoon area but still within the
boundary of OU #1 will be expanded and upgraded to meet the
requirements of a RCRA type landfill and used to hold the
additional material (see Figure'#S). only the lesser contaminated
material will be placed in this landfill. In addition, a series of
-extraction wells will be installed downgradient of this landfill
and connected to the ground-water treatment facility. These wells
will provide a tertiary containment system should a future problem
occur in the leachate collection system for this landfill cell.
The removal of incineration as a treatment technology has led to a
re-evaluation of two ARARs for the proposed action of landfilling
without treatment of lagoon area soils and sludges. The U.S. EPA
now considers that discrete portions of both RCRA and MI Act 64 are
~elevant and appropriate at the site. Specifically, those
substantive portions of RCRA and MI Act 64 which deal with the
design and construction of the cover, liner and leachate collection
systems for the landfill cells that will be built on-site are
relevant and appropriate for the site. No other portions of the
regulations are considered appropriate for the Bofors site.
Because the design requirements of the MI Act 64 liner and leachate
collection systems are more stringent than those of RCRA, the u.s.
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EPA will defer to the state design requirements as specified in the
appropriate sections of MI Act 64.
EVALUATION OF ALTERNATIVES
:..1
The following section outlines the nine criteria that were used to
evaluate the original selected remedy and the amended remedy.
Based on current information, the amended remedy provides the best
balance of benefits measured against the nine evaluation criteria.
This section profiles the performance of the amended remedy against
the nine criteria, noting how it compares to the original ROD
remedy.
Overall Protection of Human Health and the Environment
Both the remedy selected in the original ROD and this amended ROD
provide protection of human health and the environment. The
incineration strategy as outlined in the original ROD does not deal
with site soils posing the same risk as the site sludges nor does
it destroy a major portion of site contaminants. The remedy
selected in the original ROD. relies on containment of these
materials to provide. overall protection. Both remedies rely on
containment and long-term operation and maintenance of both the
landfills and the ground-water treatment system to provide overall
protection of human health and th~ environment. For this reason,
the reduction of site risks provided., by the remedy selected in the
original ROD and this amended ROD is expected to be equivalent.
compliance with ARARs
Both remedies are expected to comply with all state and Federal
ARARs. The substantive portions of both RCRA and MI Act 64 that
deal with the design and. construction of the cover, the liner, and
the leachate collection and monitoring systems for the landfill
cells are both relevant and appropriate for the site.
Lonq~Term Effectiveness and Permanence
Although incineration of some of the material at the site would
provide a permanent remedy for treated materials, the original ROD
,remedy did not call for the incineration of all OU #1 soils with a
risk of greater than lX10.2, and it addressed only a portion of the
heavily contaminated sludges. A significant volume pf material
with a risk level above lxlO'2 was intended to be 1andfi11ed in the
original ROD. The significantly greater volume of contaminated
soils with a risk level greater than lxlO'2 found in the pre-design
study significantly lessens the effective overall reduction of risk
,at the site that would have been achieved by incineration of the
materials originally selected for treatment in the ROD. In effect,
the long-term effectiveness of both the remedy selected in the
original ROD and the amended ROD are expected to be equivalent.
Long-term effectiveness of both remedies is dependant on
maintaining the integrity of the RCRA-type secure landfill cells
and the' continued operation of the ground-water extraction and
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treatment system. .
Reduction of Toxicity, MObility, or Volume throuqh Treatment
The original ROD called for incineration of site sludges which
would reduce the toxicity, mobility and volume of those materials.
However, site soils with risks equivalent to site sludges were to
be contained in landfill cells under the original remedy, and
therefore risks associated with the principal threat wastes would
not have been addressed for the overall remedy. This amended ROD
does not require treatment of any of the material at the site
because treatment is not cost-effective. Consequently this
criterion is not satisfied for this ROD Amendment remedy.
Short-Term Effectiveness
On-site containment is a component of the original ROD and this ROD
Amendment. However, the elimination of incineration as a component
of this ROD Amendment is expected to reduce overall short-term
impacts at the site. Elimination of incineration should also
reduce the time required to implement the remedial action at the
site. It was estimated in the ROD for OU #1 that it would require
5 years to complete the selected remedy. This estimate 'included
the incineration of the sludges, construction of the landfill
cells, filling and closure of the landfill cells, and construction
of ' the ground-water treatment facility. It is estimated that the
amended remedy, together wi th completion of the ground-water
treatment facility, will require 3 years.
Implementability
Implementation of the amended remedy is expected to be easier than
the original selected remedy. Issues associated with the
substantive regulatory requirements for the incinerator would be
eliminated while issues associated with construction sequencing,
material handling, and mixing of the sludges should be simplified.
Cost
~he estimated costs for the soil. and sludge components of each
alternative are in the following chart: '
ALTERNATIVE
CAPITAL COST
ANNUAL O&M COST
PRESENT NET WORTH
original ROD
$88,059,522
$89,030
$88,974,216
ROD Amendment
$44,583,522
,$89,030
$45,498,216
The amended remedy is less expensive and provides tpe
reduction of risk at the site. Implementation of,
remedy is estimated to constitute an overall
approximately $43,476,000 in capital costs. .
same overall
the amended
savings of
State Acceptance
The State of Michigan concurs on the selected' remedy in this
Amendment to the Record of Decision.
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community Acceptance
There were several comments received from the community during the
public comment period. These comments and the U. S. EPA I S responses
are contained in the attached Responsiveness Summary.
STATUTORY DETERMINATIONS
:.1
The amended remedy complies with the requirements of CERCLA 9 121
by controlling site risks posed by ground water, air, or direct
contact with hazardous site materials through the containment of
site soils and sludges. This action will not cause any
unacceptable short-term risk or cross-media impacts. The amended
remedy complies with all State and Federal ARARs. There are no
chemical, action or location-specific ARARs identified for this
action that were not identified and discussed in the original ROD.
The amended remedy is cost-effective. This Amended Remedy reduces
costs associated with constr.uction sequencing, material handling
and temporary storage of the sludge as well as eliminating the
capital and operational costs of the incinerator. It reduces the
overall cost of the remedial action for this operable unit by
approximately $43,476,000 and provides equivalent reduction of site
risks as the original ROD.
The amended remedy provides the Best balance of trade-offs with
respect to the evaluation criteriar Treatment of the principal
threat wastes was found to be not cost-effective and impractical
based on the volume of these materials and the limited number of
applicable technologies that could potentially treat the
contaminants of concern at the site. This action does not satisfy
the preference for treatment as a principal element of the remedy.
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. '. . ~('~-L~
. ,\\""J
". VY ~
NATURAL RESOURCES ~t\ \1\.
COMMISSION \y
LARRY DEVUYST ) .
PAUL EISELE
GORDON E. GUYER JOHN ENGLER, Governor
JAMESP.HILL DEPARTMENT OF NATURAL RESOURCES
DAVID HOLLI
O. STEWART MYERS
JOEY M. SPANO
STATE OF MICHIGAN
. .
IS
Stevens T. Mason Building. P.O. Box 30028. Lansing. MI 48909
ROLAND HAAIIES. Director.
July 13, 1992
Mr. Valdas V. Adamkus, R-19J
Administrator, Region S
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Ch;cag~'Ir?linoiS 60604-3590
Dear M\J~kUS: .
SUBJECT: Bofors-Nobel Superfund Site
Muskegon County, Michigan
The Michigan Department of Natural Resources (MDNR), on behalf of the State of
Michigan, has reviewed the proposed amendment to the Record of Decision (ROD)
for Operable Unit One at the Bofors-Nobel s,ite. The original ROD called for:
* Upgrading of the existing groundwater extraction and treatment system;
* Excavation and treatment, via on-site incineration of approximately 101,000
cubic yards of the most contaminated sludges and soils from the lagoon
.area; ,
* Disposal of approximately 372,000 cubic yards of the less contaminated
sludges and soils and treatment residuals in an on-site Michigan Hazardous.
Waste Management Act, 1979 PA 64, as amended, cell.
The MDNR understands that the proposed ROD amendment would:
* Eliminate treatment 9' the more contaminated soils and sludges via on-site
,incineration in favor of disposal, without treatment, of' all contaminated
so;ls and sludges in an Act 64 cell.
The U.S. Environmental Protection Agency {EPA} reevaluated treatment of the
more contaminated waste after a pre-design study performed by the Army Corps
of Engineers and their subcontractor, SEC-Donahue, indicated that the extent
of contamination in the area surrounding the lagoon area had been under-
estimatedin the ROD.
. .
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, .
R 1026
2192
OJ
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Mr. Valdas V. Adamkus
-2-
July 13, 1992
The pre-design study found that the volume of higher risk soils and sludges
was approximately 390,000 cubic yards. Incineration of the 101,000 cubic
yards of soils and sludges as originally planned would provide inconsistent
treatment of site risks as soils of equally high contamination would remain
untreated. Treating all of the more contaminated soils would more than double
the cost of the remediation.
~t
During the reevaluation of the remedy for the site, the EPA and staff of the
MDNR revisited other treatment alternatives that might be applied to the waste
at the Bofors-Nobel site prior to disposal in the on-site hazardous waste
cell. Our staff's research found that, because of unique contaminants and
site conditions, none of the treatment options or combinations of options
considered would be practicable for application" at this site. Among the site
specific conditions that make other alternatives not practicable are: the
nature of the contaminants, their concentrations, the volume of contaminants,
the matrices contaminated and the physical limitations of the site.
It is the position of the MDNR that the ROD amendment will be protective of
human health and the environment as long as the hazardous waste cell is
properly maintained. The MDNR would prefer to treat the waste found at the
Bofors-Nobel site prior to containment on-site; however, we recognize that the
prohibitive cost of treatment makes this impractical. The MDNR, therefore,
concurs with the amendment to the lagoon area Operable Unit ROD.
Sincerely.
V "~
'-, '\ " L.--
~""J "es F. 1 eary
De uty Director
5 -373-7917
cc: Mr. James Mayka, EPA
Mr. Douglas Ballotti, EPA
Mr. D. Hank Ellison, EPA
Mr. Alan J. Howard~ MDNR
Mr. William Bradford, MDNR
Mr. Gerald Heyt, MDNR
~
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request 01
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All supplemental material is. however. contained in the administrative record
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