United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-93/230
September
SEPA Superfund
Record of Decision
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50272.1 01
REPORT DOCUMENTATION 11. AEPORTNO.
PAGE EPA/ROD/R05-93/230
4. TItle and Subtitle
SUPERFUND RECORD OF DECISION
Adams Plating, MI
First Remedial Action - Final
7. Authorts)
2.
3. Recipients A_slon No.
5.
Report Date
09/29/93
6.
8.
Performing Organization Rapt. No.
9.
Performing Organization Nama and Add-
10
Project TukIWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nama and AddrMa
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Raport & Period Covar8d
Agency
800/800
14.
15. Supplementery Notes
PB94-964121
16. Abstract (Umlt: 200 word8)
The 1-acre Adams Plating site is an active electroplating operation in Lansing
Township, Ingham County, Michigan. Land use in the area is mixed commercial,
industrial, and residential. The estimated 1,800 residents per square mile around the
site receive their water from the municipal system which serves Lansing, and no private
wells exist in the area of the site. Before 1965, the Adam$ Plating Company(AP~)
building was occupied by a dry cleaning establishment, which stored solvents in ~
SOO-gallon underground storage tank at the site. APC removed this tank in the 19S0s
because of leakage. In 1965, APC purchased the site and primarily has been involved in
chrome, nickel, copper, tin, and brass electroplating and anodizing. This process
includes degreasing and removing dirt from metal using solvents and acids, and rinsing
off the film after electroplating. Prior to 1971, wastewater from the electroplating
process was discharged to an underground clay tile drain system. In this process,
wastewater was discharged near a partially buried drum, referred to as the "green
water" drum, then flowed through a clay tile drain into the municipal sewer system. In
1971, APC was connected directly to the municipal sewer system. Prior to 1980, APC was
cited several times for violations of city codes regulating discharge of untreated
(See Attached Page)
17. Documant Analysis a. Descriptors
Record of Decision - Adams Plating, MI
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: VOCs (TCE, toluene),
chromium)
other organics (PARs), metals (arsenic,
b.
IdentifieralOpen-Ended Terms
c.
COSATI Field/Group
18. Avaliability Statamant
19. Security CI88s (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
58
22. Price
(See ANSI-Z39.18)
SMllnstructions on R8V-
OPTIONAL FORM 272 (4-77)
(Formerly N11S-35)
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L.~
EPA/ROD/ROS-93/230
Adams Plating, MI
First Remedial Action - Final
Abstract (Continued)
waste to the municipal sewer and, as a result, began pretreatment of onsite wastewater.
The wastewater was stored onsite in a partially buried metal dipping tank, and pumped
through an onsite pretreatment system prior to discharge to the municipal sewer system.
This 800-gallon tank was removed at an unknown date because of leakage. Wastewater is now
held in two 1,000-gallon holding tanks at the southwest corner of the APC building. In
1980, the owner of an adjacent property received "green water" in his basement as a result
of a broken clay pipe. The State investigated the site and documented that wastewater and
plating waste had migrated from the former tile drain, contaminating the site. In 1981,
at the State's suggestion, APC pumped wastewater from the basement and later installed a
subsurface collection drain system to reduce the concentration and volume of contamination
reaching the adjacent house. In 1984, EPA inspected the site and found contamination of
soil by metals, VOCs, and PAHs originating from site electroplating activities, by past
fuel or coal storage and disposal, and possibly from the former dry cleaner. This ROD
addresses the onsite contaminated soil and debris as the first and final action for the
site. Ground water was not evaluated as a drinking water source because ground water at
the site was not foun~ in useable quantities for drinking water purposes and all residents
and businesses in the neighborhood are connected to municipal water. The primary
contaminants of concern affecting the soil and debris are VOCs, including TCE and toluene;
other organics, including PAHs; and metals, including arsenic and chromium.
The selected remedial action for this site includes constructing a temporary fence around
the site and demolishing onsite buildings as needed; excavating approximately 4,700 yd3 of
contaminated soil from around the buildings to a depth of 10 feet; testing the soil using
TCLP for metals; pretreating the soil off site by fixation and/or stabilization, if
necessary, to a level below LDR requirements; disposing of excavated and any pre-treated
soil offsite in a RCRA landfill; removing onsite subsurface debris, including clay tiles,
PVC pipe, collection systems, and underground storage tanks, followed by offsite disposal
of these materials in a RCRA landfill; backfilling excavated portions of the site with
clean soil and reseeding; installing vertical barrier walls around the buildings to
isolate the residual low-level contamination under the buildings; collecting, treating,
and disposing of approximately 10,000 gallons of water collected during excavation
offsite; monitoring ground water and air, if necessary; and implementing institutional
controls, including deed and land use restrictions. The estimated present worth cost for
this remedial action is $1,800,000, which includes an estimated annual O&M cost of $34,400
for 30 years.
PERFORMANCE STANDARDS OR GOALS: .
Chemical-specific soil and debris cleanup goals are based on background levels, and
include chromium 26.1 mg/kg and arsenic 6.7 mg/kg. Soil will be excavated to a maximum
depth of 10 feet because the Risk Assessment assumed a maximum construction depth of
current/future buildings to 10 feet. Final soil remedial concentrations will attain a
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DECLARATION
SELECTED REMEDIAL ALTERNATIVE
for the
Ad~m~ Plating ,Company Site
Site Name and Location
Adams Plating Company Site
Lansing, Ingham County, Michigan
Statement of Basis and Purcose
This decision document represents the selected remedial action
for the Adams Plating Company (the site), in Lansing, 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 on the Administrative Record for the site.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
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
The selected remedy is the final remedy for the site. The remedy
addresses the threats posed by contaminated soils at the site.
The major components of the selected remedy include:
.
Excavation of contaminated soils and off-site disposal
in a Michi~an Act 641/RCRA Subtitle D landfill.
Collection and treatment of water from
excavation/dewatering, activities.
.
.
Replacement of the excavated soil with clean fill and
installation of vertical barriers to reduce the
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c-
o
2
.
Land use restrictions including deed restrictions on
installation of wells and excavation of contaminated
soils if necessary.
Groundwater monitoring to evaluate the effectiveness of
the soil remediation and to monitor for continuing
sources.
.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and" the
environment, complies with Federal and State environmental
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
technologies to the maximum extent practicable. This remedy may
not satisfy the statutory preference for treatment as a principle
element of the remedy since soils will only be treated if
determined to be characteristic hazardous waste. Treatment of
excavated soils may be required if it is determined they are
RCRA, or Michigan Act 64, characteristic hazardous wastes. u.S.
EPA dete~ined excavation and off-site disposal of contaminated
soils is a cost effective remedy which will be protective of
human health and the environment and which will meet legally
applicable or relevant and appropriate Federal and State
environmental requirements. .
Because this remedy will result in hazardous substances remaining
on-site, a review will be conducted within five years after
commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
./\
"
9'b;h~
. Date
~
~'v ldas V.
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STATE OF MICHIGAN
';;
NA1URALRESOUACES
~
JERRY C. BARTNIK
LARRY OEVUYST
PAUL EISELE
JAMES P. HILL
DAVID HOW
JOEY M. SPANO
JORDAN 8. TATTER
8
JOHN ENGLER. Governor
DEPARTMENT OF NATURAL RESOURCES
51-. T. Muon 8udCIlno. P.O. 80s 30028. Lanamo. MI .811Oi
ROLAND "AIUIU. Dlr_r
September 29~ ~993
Mr. Valdas V. Adamkus~ R-19J
Administrator~ Region 5
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago~ Illinois 60604-3590
Dear Mr. Adamkus:
The Michigan Department of Natural Resources (MDNR), on behalf of the State of
Michigan, has reviewed the Record of Decision (ROD) for the Adams Plating
Company Superfund site~ Ingham County, Michigan, which we received on
September 23~ 1993. We are pleased to inform you that we concur with the
remedy outlined in the ROD for this site.
The major components of the final site remedy as specified in the ROD include:
- .
* Excavation of contaminated soils to eliminate site-specific health risks
and off-site disposal of the soils in a Michigan Act 641/RCRA Subtitle 0
landfill.
* Replacement of the excavated soil with clean fill and installation of
vertical barriers to reduce the potential for recontamination of the clean
fill from remaining sources.
* Collection and treatment of groundwater from construction/dewatering
activities.
* Land-use restrictions which prohibit installation of wells and preclude
direct contact exposure to contaminated soils remaining on site.
* Groundwater monitoring to evaluate the effectiveness of the soil
reBediation and to check for continued migration from remaining sources.
The MOHR also concurs with the analysis of the legally applicable or relevant
and appropriate require8ftts (ARARs) that are contained in the Statutory
Determinations section of the ROD. However, additional ARARs will need to be
considered during implementation of the re88dia1 action and include the.
Michigan Water Resources Commission Act, 1929 PA 245, as amended, and the
Mineral Well Act, 1969 PA 315. Other applicable state regulations include the
Michigan Occupational Safety and Health Act, 1974 PA 154, and the Michigan
Vehicle Code (MeLA 257.722). The U.S. Envirollllental Protection Agency (EPA)
has informed staff of the.MONR. that even though these regulations are not
specifically listed in the ROD, if they are an AlAR, they will be complied
with during implementation. of the reledial action.
~
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Q
.'
Mr. Valdas V. Adamkus
-2-
September 29, 1993
If you have any questions regarding this site, please contact Ms. Sally Beebe,
Superfund Section, Environmental Response Division, at 517-373-4110, or you
may contact me.
8
Sincere~
,d $)- r . ~
Russell J. Harding
Deputy Director
517-373-7917
cc: Mc.;...Juac Mayka, EPA. .
Mr. Steve Padovani, EPA
Mr. Alan J. Howard, MOHR
Mr. William Bradford, MOHR
Mr. Scott Cornelius, MOHR
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v
RECORD OP DECISION
DECISION SUMMARY
ADAMS PLATING COMPANY StJPE1U'tJND SITE
LANSING, MICHIGAN
Prepared by:
U.S. EnviromILental Protection Agency
Region V
Chicago, Illinois
September, 1993
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I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.
XII.
R.OD StJMKAR.Y
ADAMS PLATING COMPANY S'D'PER.PtJND SITE
LANSING, MICHIGAN
TABLE OF CONTENTS
SITE NAME, LOCATION, AND DESCRIPTION................. 3
SITE HISTORY AND ENFORCEMENT ACTIVITIES.............. 9
HIGHLIGHTS OF COMMUNITY PARTICIPATION................ 12
SCOPE AND ROLE OF RESPONSE ACTION. . . . . . . . . . . . . . . . . . . .. 13
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . ~ . . . . . . 13
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 21
DESCRIPTION OF REMEDIAL ALTERNATIVES. . . . . . . . . . . . . . . . . . 30
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES. .. 39
THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 43
STATUTORY DETERMINATIONS SUMMARY. . . . . . . . . . . . . . . . . . . .. 49
DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . . . . . . . . . 54
RESPONSIV'EN'ESS S~Y......................... '. . . . . . . .55
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3
RECORD OP DECISION
ADAMS PLATING COMPANY SITE
I.
SITE NAME, LOCATION AND DESCRIPTION'
The Adams Plating Company Site (the Site) is located at 521
Rosemary Street in Lansing Township, Ingham County, Michigan. The
Si~e is approximately 1-acre in size and is located in the east
half of the northwest quarter of the northeast quarter of Section
18, Township 4 North, Range 2 West. Figure 1 depicts the location
of the Site. Within the neighborhood, the Site boundaries are
Rosemary Street to the east, Grace Street to the west,
approximately 100 feet south of Genesee Street which is to the
south and Saginaw Street to the north.
The Site is physiographically located in the south-central part of
Michigan's Lower Peninsula. The Site lies at approximately 850
feet above mean sea level (MSL). The topography of the area is
flat or gently rolling as a result of glacial and post-glacial
erosional processes. The Site is located on ground moraine and
till plain approximately one-half mile north of the Lansing
Moraine. Regionally, the Site lies near the center of a l-mile
radius bend of the Grand River. The river lies about 1 mile north,
1.25 miles south and 2 miles east of the Site. The slope between
the Site and the river is less than one percent in all directions.
No perennial surface water bodies or wetlands are present on or
near the Site. The nearest water body is a small pond located
approximately 3,000 feet southwest of the Site. Surface water
drainage is northeast, east and southeast, following the general
topography of the Site and surrounding area.
PopulatiOl1
The population density is approximately 1,800 people per square
mile around the Site. The area surrounding the Site is
characterized by a densely-populated mix of commercial, industrial
and residential properties. Large commercial and public properties
within a half-mile radius of the Site include automobile plant
operations, a cemetery, several schools, three local parks, a golf
course and a hospital. The block on which the Site is located
contains numerous private residences and several small service
businesses, such as. a. warehouse company (William E. Walter
Mechanical Contractor) and a fire extinguisher recharging company
(De Lau Fire and Safety Company). The nearest private dwelling is
within 25 feet of the Site. Directly across the street from the
Site and to the east lies the General Motors Oldsmobile Productio~
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llirb :ich
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'Vater Tank' .
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. Water Tank
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SOURCE: USGS, L.8nIing North end Lansing South, MI, 7.5 minute toPOgrIPhic quadrangle. 1973.
SCALE 1 :24,000
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OUAORANGL.E L.OCATION
FIGURE 1
SITE LOCATION MAP
AdamS Plating
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5
Platizlg Operations
The Adams Plating Site (the Site) is an active electroplating
operation. The plating building at the Site consists of a one-
story building that houses the office, plating process lines and
wastewater pretreatment system. Figure 2 shows the Site layout
and features surrounding the plating building. The office and
metal polishing area are located along the north wall of the
plating building. The wastewater pretreatment system is located
near the east wall.
Outside the building, a gravel parking area is situated to the
east. Another gravel parking area is located behind the building
to the west. Two 1., OOO-gallon underground wastewater holding tanks
are ,located near the southwest corner of the building. A ground'
water collection system exists just north of the Meyer house at 51.0
Grace Street. Ground water in this area is collected by perforated
polyvinyl chloride (PVC) pipes. Ground water drains by gravity in
these pipes from west to east to another PVC pipe that runs north
and drains to a concrete sump located in the backyard of a house
located at 517 Rosemary Street. Ground water collected in the
concrete sump is pumped northward into the underground wastewater
holding tanks before disposal through the pretreatment system.
After pretreatment, the water is discharged to the sanitary sewer.
- .
Another ground water collection system exists near the northwest
corner of the plating building. A partially buried drum referred
to as the Agreen waterA drum is located near the northwest corner
of the building. Slotted PVC drain pipes connect to this drum from
all directions. The exact location and configuration of the PVC
drain pipe is unknown. However, based on conversations with the
owner, it appears that two or three short sections of PVC pipe
extend westward in the vicinity of the green water drum. The
purpose of this system is apparently to collect ground water near
the northwest portion of the plating building. The ground water in
the drum is also routed through the wastewater pretreatment system
and discharged to the sanitary sewer.
The nature of the activities and operations and the chemicals used
in the electroplating process have changed from t~e to t~e. In
the recent past, the plating shop has primarily been involved in
chrome, nickel, copper and occasionally tin electroplating and
anodizing. CUrrently, chromium, brass, nickel and copper
electroplating are all performed. The electroplating process
consists of three basic steps:
1.
Pretreatment includes the removal of dirt and oil from the
, surface of the piece to be plated and preparation of the piece
for electroplating. Typical pretreatment solutions include
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516
PVC Pipe
Groundwater /'
Collectors ~
Sump .
510
500
I Shed I
I Gar. I
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Adams,
Plating :
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Genesse Street
503
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Sanitary
Manhole
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Wastewater
Pretreatme
System
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2.
Electronlating involves the application of metal to the piece.
A direct current is passed between an anode and the metal part
(the cathode), resulting in the deposit of metal ions onto the
piece.
3.
Post-Treatment consists of rinsing, converting, and drying the
electroplated pieces. The rinse water is used to remove film
that is left on the surface of the piece.
The spent plating baths are subject to electroplating categorical
pretreatment standards for facilities discharging less than 10,000
gallons per day (gpd). The pretreatment system is designed for a
28,800 gpd effluent and discharges to the City of Lansing POTW.
The pretreatment system is designed to treat for chromium, tin,
copper, zinc, nickel and cyanide. The pretreatment system was not
designed to treat for organic compounds. The most current estimate
of flow through the pretreatment system was 4,512 gpd.
Approximately 978 gpd (.68 gpm) was estimated to be from the ground
water collection systems. The pretreatment system generates
approximately one and one-half 55-gallon drums of pretreatment
solids per month. Due to the generation of these solids, Adams
Plating Company has provided notification that it is a small
quantity generator for RCRA-listed waste resulting from wastewater
treatment sludges from electroplating operations (waste code F006) .
Limited 1nformation is available on how wastes were managed in the
past and how these management practices led to contaminant releases
at the Site. The contamination at the Site is believed to have
originated as a result of the electroplating process. It is not
clear from which step in the electroplating process the
contamination originated. In addition, no information indicates
RCRA listed wastes were released along with the waste stream from
the electroplating process.
In conjunction with the electroplating process, degreasing of
pieces to be electroplated is also conducted. Al though the
pretreatment step is designed to clean pieces before plating, the
pieces also may require an initial cleaning in order to improve the
efficiency of the pretreatment process and prolong the life of the
solutions. OVer the years, a number of volatile organic compounds
(VOC) have been used in the degreasing process, although no used
solvents are listed on the RCRA hazardous waste notification fo~,
such as acetone, methylene chloride, carbon tetrachloride, and
1, 1, 1-trichloroethane (1,1, 1-TCA) . The owner had reportedly
stopped using 1,1, 1-TCA 3 years ago; however, .containers of spent
l,l,l-TCA were still located on Site during the last Site visit on
July 26, 1992. Approximately 4 gallons per year of acetone are
currently used at the facility for degreasing operations.
CUrrently, solvent wastes are not produced because they are spent
in the process or reused. No information is available on how
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8
Area Water Use
All resident~ and businesses in the vici~ity of the Site receive
their water from the municipal system, which serves the Lansing
area. Municipal water is supplied by the Lansing Township Water
District wells or by the City of Lansing Board of Water and Light
wells. Municipal wells are installed within the bedrock aquifer
(Saginaw Formation) and are typically at least 300 to 400 feet
deep. The Lansing Township Well No.4 is the water supply well
closest to the Site and is .located approximately 1,200 feet
northwest of the Site. Records indicate that no private wells
exist in the area of the Site. Surficial deposits of sand and
gravel are used for private wells in isolated residential areas of
Lansing Township, but not within a 2-mile radius of the Site. All
private wells screened in the surficial deposits are located beyond
the Grand River.
Geology/Hydrogeology
There are two shallow saturated sand units approximately 0.5 to 9
feet thick which are located approximately 10 and 20 below ground
surface (bgs). These sand units are continuous under the Site, but
appear to pinch out to the west of the Site. The upper sand unit
exhibits unconfined to semi-confined characteristics, and the lower
sand unit exhibits .confined aquifer characteristics. A third sand
unit is located approximately 30 feet bgs, but this sand unit is
not water bearing and is referred to as the ndryn sand unit. Silts
and clays are consistently located between and interbedded with the
sand units. Bedrock was encountered at approximately 70 feet bgs.
The bedrock encountered was the very upper portion of the sandstone
in the Saginaw Formation. The top of this formation was
encountered in all deep borings, but ground water at this level was
not observed.
A vertical hydraulic connection between the upper and lower
saturated sand units was not observed by direct measurements.
However, the presence of contaminants in the lower saturated sand
unit indicated that leaky confining conditions or preferentially
induced flow paths may be present. The saturated sand units are
not hydrau~ically connected to the bedrock aquifer at the Site
because of the thick clay deposits, up to 50 feet thick, between
the sand units and the bedrock. The presence of the ndryn sand
unit between the saturated sand units and bedrock also indicates
the existence of a hydralllic barrier that separates the two in the
vicinity of the Site...
The depth to ground water in both saturated sand units ranges from
4 to 18 feet bgs. Ground water in the upper sand unit flows away
from the highest elevation near the southwest corner of the APC
building in a semi-radial pattern to south,. southeast, east,
northeast and north. Groundwater flow in the lower saturated sand
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v
9
flow velocity in the upper sand unit ranges from 0.02S to 0.134
feet per day (ft/day). The average ground water flow velocity in
the lower sand unit ranges from 0.012 to 0.89 ft/day.
Based on a computer model, the potential ground water yield from
the saturated zones in the immediate vicinity of the Site is
insufficient to reasonably support the installation and use of
private wells. Based on this predicted yield, neither the upper or
lower sand units will likely be used in the future for domestic
water supply wells in the immediate vicinity of the Site.
Therefore, contamination at the Site is primarily a source control
problem.
II.
SITE HISTORY AND ENFORCEMENT ACTrvITIES
Before 1965, the APC building was occupied by a dry cleaning
establishment, Verrakleen, which was owned and operated by Norris
and Irene Williams. A dry cleaning fluid known as Stoddard
Solvent, which consists of a mineral spirit that contains
chlorinated hydrocarbons, paraffins, and aromatic hydrocarbons, was
reportedly stored in a SOO-gallon underground storage tank (UST) 'at
the site, but the tank was removed in the mid-19S0s because of
leakage. The for.mer location of the tank is not known; however,
based on results of soil analyses conducted in 1981, the tank may
have been-J..ocated immediateJ..y south of the existing APC buiJ..ding.
In 1964, the property was transferred to James and Sheila Adams,
and t~ey began to operate the plant as an electroplating business.
In 1984, ownership was transferred to the current owner, Steve
Adams, their son. .
Before 1971, wastewater was discharged to a clay tile drain system.
The'wastewater apparently was discharged near the green water drum
located near the northwest corner of the building (see Figure 2) .
From the green water drum area, wastewater flowed south through the
old clay tile drain. Near the Meyer house, the tile drain turned
east and connected to the municipal sewer system along
Rosemary Street. In 1971, APC reportedly was co~ected directly to
the municipal sewer east of the building beneath Rosemary Street.
Wastewater apparently flowed from the green water drum area through
the clay tile drain, which runs east to west just no~th of the APC
building (see Figure 2). '
In the early 1980s, pretreatment of wastewater began. Wastewater
was then stored before treatment in 'a plank-covered, partially
buried, metal dipping tank ~ediately south of the APC building.
This 800-gallon tank was removed on an unknown date because of
leakage. Wastewater, primarily from the PVC collection system, is
now held in two 1,000-gallon holding tanks beneath a concrete slab
at the southwest corner of the APC building. Collected wastewater
is pumped through an on-site pretreatment system before being
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Before 1980, APC was cited several times for violations of city
codes regulating the discharge of untreated wastes to the municipal
sewer.
In late July 1980, the owner of the property 50 ft south of the
site, hired a backhoe operator to remove a tree from his property
in preparation for placing the foundation slab for a new warehouse.
An old tile drain was broken as the tree was uprooted. The old
tile drain was not repaired and the hole was backfilled. Later
that month, green water began to enter the basement of the Meyer
house at 510 Grace Street through a drain being used to discharge
sanitary wastewater. The green water flow into the basement
recurred during periods of heavy rainfall in the autumn and winter
of 1980. The green water flow rate reached a maximum of 500
gallons per day (gpd) in February 1981. Initially, the water was
pumped out of the basement and discharged to a small fruit and
vegetable garden immediately south of the Meyer house.
ICHD inspected the Meyer basement and collected samples of the
green water for analysis. The analyses indicated 130 to 150 parts
per million (ppm) of total chromium in the water. At the
suggestion of ICHD, James Adams arranged to pump the water from the
basement and transfer it by tank truck to the underground
wastewater holding tanks at the APC building for pretreatment.
- '
In the following months, the ICHD and the Michigan Department of
Natural Resources (MDNR) implemented a limited boring and hand-
auger program to investigate the site area. On March 2 and 3,
1981, James Adams excavated a hole in the Meyer backyard to expose
the tile drain. James Adams had the tile drain exposed in order
to plug it to prevent wastewater from entering the Meyer basement.
James Adams then installed a collection and pumping device in the
trench. He plugged the end of the tile drain near the Meyer house
and periodically pumped the water out of the trench into a tank
truck. Samples of this liquid were found to contain up to 160 ppm
total chromium. It was suggested to Mr. Meyer that any liquid
pumped from his basement in the future be pumped directly into the
collection device in the trench.
ICHD subsurface investigations indicated that plating waste had
migrated through a sand lens to some extent and was not confined
entirely to the tile drain system. ICHD therefore urged James
Adams to install a subsurface interceptor and collector system
between the APC building (the suspected source area) and the
basement of the Meyer,. house. In October 1982, Adams installed a
subsurface collection drain immediately north of the Meyer house.
The collection system was designed to collect seepage from both the
broken tile drain and the contaminated sand lens. The collection
system drained by gravity to a 20-cubic-foot (ft3) concrete sump in
the backyard at 517 Rosemary Street about 30 ft south of the APC
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1..:..1
11
the two 1,CCC-gallon concrete wastewater holding tanks.
collection system is still in operation.
While the collection system appears to reduce the concentration and.
volume of contamination reaching the Meyer house, local and state
agencies continued to express concern over the extent of
contamination and the integrity of the wastewater holding tank
system. In response to this concern, u.s. EPA conducted a detailed
site review and filed an inspection report in October 1986. The
Site was proposed for the National priorities List (NPL) in June
1988. The Site received a Hazard Ranking System (HRS) score of
35.57.
This
On April 14, 1988, SAIC inspected the APC site to determine its
compliance with U. S. EPA Categorical Standards and the City of
Lansing Industrial Pretreatment Program. The inspection was
conducted for u.S. EPA, and representatives of MDNR and the City of
Lansing attended. The report prepared by SAIC included several
recommendations to bring APC'S activities into compliance with the
requirements of its National Pollutant Discharge Elimination System
(NPDES) permit.
In March 1989, the APC site was placed on the National priorities
List. The U. S. EPA conducted the RI in two phases. Phase I of the
RI began ~n August 1989. .
The Phase I RI included ambient air monitoring, a trench
investigation, a soil investigation (surface and subsurface),
monitoring well installation, a groundwater investigation
(including groundwater sampling, preliminary groundwater flow
determination, and hydraulic conductivity tests), a surface water
investigation, and a basement investigation. Phase I RI field
activities were conducted from August to September 1989.
After the Phase I RI field investigation, the Technical Assistance
Team (TAT), a contractor to U.S. EPA's Emergency Response Section,
was tasked by U.S. EPA to conduct an assessment of the residential
area near the APC site. On November 28, 1989, TAT collected four
basement water samples and one soil sample from nearby residences.
The analytical results were forwarded to the Agency for Toxic
Substances and Disease Registry (ATSDR) for evaluation of potential
or existing health threats. Based on this evaluation, U.S. EPA
determined that no emergency removal action was required.
In March 1991, U.S. EPA began work on Phase II of the RI and the
FS. Phase II RI field activities were conducted from March to July
1992. The Phase II RI included a contaminant source investigation
consisting of shallow soil, soil gas, and groundwater sampling, and
a geologic and hydrogeologic investigation consisting of shallow
and deep soil borings, temporary piezometer installation,
monitoring well installation, groundwater sampling, slug tests, and
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12
The RI was published in March 1993 and included a Baseline Risk
Assessment. The FS was completed in July 1993 and provided to the
public for review and comment on August 19, 1993. The FS contained
ten remedial alternatives.
III.
HIGHLIGHTS OF COMHCNITY PARTICIPATION
A community relations plan was developed in 1989 and again in 1991
to. address community concerns and to plan an information strategy
for the Site. u.S. EPA has held four public meetings to keep the
public informed about the activities at the Site and the MDNR
generated a series of Progress Reports for the Site to assist u.S.
EPA with community relations. The meetings occurred on the
following dates:
.
May 18, 1989 - information meeting to discuss the planned
investigation;
May 27, 1992 - information meeting to discuss phase I RI
findings;
. April 21, 1993 - briefing on recently completed RI Report;
.
September 8, 1993 - briefing on proposed plan.
U.S. EPA has also sent out fact sheets at various times during the
RI/FS process.
.
As part of its community relations program, u.s. EPA has maintained
two information repositories in Lansing, Michigan at the Lansing
Public Library, 401 South Capitol and the Lansing Township Hall,
3209 West Michigan. Documents and reports regarding the Site
prepared by U. S . EPA and the MDNR are contained in these
repositories.
u.s. EPA notified the local community, by way of the proposed Plan,
of the recommendation of a remedial .alternative for the Site. To
encourage public participation in the selection of a remedial
al ternati ve, U. S. EPA scheduled a public comment period from August
19 through September 17, 1993. On September 8, 1993, U. S. EPA held
a public meeting to discuss the recommended remedial alternative
and the other alternatives identified and evaluated in the FS. A
transcript of the meeting is included as part of the Administrative
Record for the Site. " u.S. EPA's responses to comments received
during this public meeting and to written comments received during
the public comment period are included in the Responsiveness
summary which is attached to this ROD.
Advertisements were placed in the Lansing State Journal concerning
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13
The public participation requirements of CERCLA Sections 113 (k) (2)
(B) (i-v) and 117 were met in the remedy selection process.
IV.
SCOPE AND ROLE OF RESPONSE ACTION
u.s. EPA identified contaminated surface and subsurface soils as
posing potential risks to human health. Potential exposure routes
include ingestion, dermal contact and inhalation of contaminated
soils at the Site by residents, trespassers, and construction
workers. Soils contributing to risk ( "hot spots") that are
accessible to human contact around buildings on the Site represent
a principal threat. Remediation of contaminated soils under
buildings is not necess~ry because building foundations act as a
cap and significantly reduce potential exposure routes to
contaminated soils.
u. S . EPA developed remedial obj ecti ves to address these risks,
namely prevent human ingestion, dermal contact and inhalation of
contaminated soils contributing to unacceptable risk at the Site.
The remedial objectives are based on the data obtained during the
RI. The main component of this remedial action includes excavation
of contaminated soils around buildings at the Site which contribute
to Site specific risk, disposal of the excavated soils in an off
Site landfill and ground water monitoring to monitor the migration
of residual contamination fram the Site in the direction of the
public water supply wells.
V.
StD!MAR.Y OF SITE CHARACTERISTICS
In March of 1993, an RI Report was completed for the Site. The
purpose of the RI was to determine the nature and extent of
contamination and potential exposure pathways from surface soils,
subsurface soils, ground water, surface water and basement water.
Samples, referred to as "sediment samples" in the RI, were
collected from a concrete sump and green water drum associated with
the PVC pipe collection system and old tile drain system (see
Figure 2). For simplicity, these samples are grouped into the
category of surface soil samples throughout this ROD. Trench
excavations, where soil samples were collected, were conducted to
determine the location and condition of the old clay tile drain
network suspected of being used for disposal of contaminated waste
water. For simplici~y, trench soil samples are grouped into the
category of subsurface soil samples throughout this ROD. Surface
water samples were collected from man-made ground water collection
systems and standing puddles rather than fram natural surface water
bodies. The RI report should be consulted for a more thorough
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14
Metal CODt::lmirnitiOD
Metals are the most significant contaminant at the Site in terms of
frequency of detection and highest concentrations in all media
sampled. Metals selected in the RI to delineate the spacial
distribution of contamination include chromium, copper, nickel and
zinc. Selection of these metals was based on the history of the
Adams Plating Facility operations and their consistently elevated
levels (above background) throughout the Site. The following are
the maximum concentrations of target metals in various media at the
Site:
(mg/kg) (mg/kg) (ug/l) (ug/l) (ug/l)
Surface Subsurface Ground Surface Basement
Soil Soil Water Water Water
Chromium 6,976 1,180 29,800 21,500 7,960
Copper 372 1,810 220 1,560 25
Nickel 229 880 852 387 74
Zinc 358 1050 872 567 93
The old tile drain system and the soils and ground water directly
around it appear to be the areas most affected by inorganic
contamination at the Site. Inorganic contaminant concentrations
tend to decrease with distance radially from the old tile drain
system. In general, the highest concentrations of inorganic
contaminatlon were also detected in soil and water samples
relatively close to the old tile drain system. Chromium appears to
be the most widespread. The concentrations are frequently elevated
above background (1.1..4 mg/kg) and commonly at concentrations above
'other inorganics associated with the plating process. The highest
chromium concentrations for the Site overall were detected in soil
samples from the concrete sump (6,21.4 mg/kg) and green water drum
(6,976 mg/kg) associated with the PVC pipe collection system and
old tile drain system. In addition, the highest concentration of
chromium in surface water (21.,500 ug/l) was detected in a sample
collected from the green water drum. The highest chromium
concentrations in subsurface soils (1.,180 mg/kg) and ground water
(29,800 ug/l) were detected in samples collected relatively close
to the "Tn connection in the old tile drain system near the south
west corner of the Adams Plating building. Elevated concentrations
of inorganics also detected in subsurface soil samples include lead
at 244 mg/kg, mercury at 2.1. mg/kg, and cyanide at 1.28 mg/kg.
Relatively high chromium concentrations were detected in water
samples collected from two basements just southeast (3,61.0 ug/l)
and southwest (7,960 ug/l) of the Adams Plating building (house 517
and 510 on Figure 2). Again, the house closest to the old tile
drain system showed higher chromium, as well as copper (25 ug/l),
nickel (74 ug/l) and zinc (93 ug/l), concentrations.
Two 'forms of chromium are present at the Site: trivalent chromium
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15
operations, including the Adams Plating Company, use hexavalent
chromium baths. Hexavalent chromium was analyzed for in ground
water samples at the Site. However, the analytical methods for
analyzing hexavalent chromium do not provide reliable quantitative
results. At the Adams Plating Site, for example, hexavalent
chromium was detected in three monitoring wells. However, in one
well the hexavalent chromium concentration was greater than the
total chromium concentration. Although the analytical method for
analyzing hexavalent chromium does not provide reliable
quantitative results, it does confirm the presence of hexavalent
chromium at the Site.
Organic" Cont"~mination
Volatile organic compounds (VOCs) were detected in all media
sampled. VOCs detected in soils include 1,1-DCA (2 to 5,300
ug/kg), 1,1,1-TCA (0.7 to 5,300 ug/kg), chloromethane (2,700 to
4,200 ug/kg), 2-butanone (3 to 4,200 ug/kg), methyl ethyl ketone
(MEK) (4,200 ~g/kg), ethylbenzene (8 to 1,200 ug/kg), bromomethane
(2,520 ~g/kg), acetone (2 to 850 ug/kg), toluene (2 to 610 ug/kg),
methylene chloride (3 to 26 ug/kg), 1,1-DCE (4 to 20 ug/kg),
chloroethane (4 to 8 ug/kg), 2-hexanone (480 ug/kg) carbon
tetrachloride (65 ug/kg), carbon disulfide (12 ~g/kg), and
trichloroethene (TCE) (2 ug/kg). Methylene chloride, acetone, and
l,l,l-T~ are three degreasing agents known to have been"used at
APC.
VOCe in ground water include 1,1-DCE; 1,1-DCA; 1,1, 1-TCA: and
tol~ene each in the range of 1 to 3,800 ug/l. The highest
concentration of all the VOCs was that of 1,1,1-TCA at 3,800 ug/l,
1,1-DCA at 840 ug/l and 1,1-DCE at 30 ug/l. Other VOCs such as
chloroethane, 1,2-DCA and 1,1,2-TCA were detected in low
Goncentrations. Semi-VOC concentrations were generally low and
ranged from 1 to 7 ug/l.
DistributiOD or COD~mi n~ntB
The areal extent of inorganic and organic contamination at the Site
is consistent, namely contamination was detected primarily around
the old tile drain system, between the APC building and the
warehouse just south of the APC building and just to the south of
the warehouse. Contamination generally decreases in concentration
with distance from these areas. The areal extent of contamination
in ground water is also roughly defined by the same area as the
soil contamination. "" However, the areal distribution of ground
water contamination extends approximately 50 to 100 feet farther to
the north, south, east and west than the area of soil
contamination. For example, elevated ground water concentrations
of chromium were detected in monitoring wells at the north, south,
east and west edges of the Site, with the highest concentration of
chromium (3,850 ug/l) being at the south edge. Concentrations of
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16
the same as background levels. Concentrations of inorganic and
organic contamination detected in wells around the perimeter 'ofthe
Site were generally just above MCLs, but orders of magnitude less
than wells located on-Site.
Vertically, the organic and inorganic contaminant distribution
indicates that contaminants have migrated to the upper and lower
sand units (10 to 20 feet bgs) and that these sand units are the
preferred pathways of contaminant transport. Concentrations of
organic and inorganic contaminants in ground water and soil
generally decrease dramatically fram the upper to the lower sand
uni t . Al though both organic and inorganic contaminants are present
in the sand units, organic contaminants, not inorganic contaminants
are more frequently detected in the till units.
The upper 10 feet of soil, which includes the upper sand layer, is
generally considered to contain the maj ority of Site related
contamination. Below 10 feet, concentrations of contaminants were
low and the frequency of detection of contaminants was limited.
For example, chromium was detected an order of magnitude (lOx)
above background (11.4 mg/kg) at only three locations. These
values are 189 mg/kg, 148 mg/kg and 112 mg/kg and are located next
to one another along the southern wall of the Adams Plating
building. Total VOCs ranged in concentration from 2 to 11,760
ug/kg in fhirty-five soil samples below 10 feet. However, total
VOCs above 1 mg/kg were detected at only one location near the
northwest corner of the Adams Plating building (12 mg/kg). Total
VOCs above 1.00 ug/kg were detecte.d in nine samples from areas
primarily close the perimeter of the Adams Plating building and
warehouse. The following summarizes maximum contaminant
concentrations below 10 feet:
Maximum Contaminant Concentrations (mg/kg)
in Soils Below 10 Peet
12
TOTAL SVOCs
.02
TOTAL METALS
CHROMIUM
TOTAL VOCs
Maximum
Concentration
224
189
Frequency
of Detection
98
1
3"
3-
..
- Greater than lOO.ug/kg
- Greater than 100 mg/kg.
and zinc.
= l'Ox above chromium background (11.4 mg/kg)
Includes chromium, copper, nickel
8
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17
Co.at;:.lmi n.::lnt Sources
Based on the areal and vertical distribution of contaminants in
soil and groundwater at the APC site, VOCs and inorganic analytes
related to the electroplating operations most likely originated
from the APC building and its associated former clay tile drains,
most notably the clay tile drain that runs south to Meyer's house
and turns east toward Rosemary Street, and the clay tile drain that
runs east toward Rosemary Street adjacent to the north wall of the
AFC building. Other probable source areas include the green water
drum area near the northwest corner of the APC building and the
area beneath the warehouse where the tile drain was broken in 1980.
Present operations at the APC facility and the two 1,000-gallon
wastewater holding tanks may also be sources of contamination.
VOC~ and SVOCs may have also originated from the dry cleaning UST
containing Stoddard Solvent, which consisted' of a mineral spirit
that contains chlorinated hydrocarbons, paraffins, and aromatic
hydrocarbons. Other VOCs and SVOCs detected in this area may be
related to storage and disposal of fuel oil and coal used in the
past for heating purposes.
CODt".::Imin.=:lted Soil Areas aDd Volumes
Two different soil areas and volumes were estimated for soils
requiring remediation. One estimate included only those
contaminated soils that contribute to Site-specific health risks
associated with inhalation, dermal contact and ingestion of
contaminated soils (Site-specific. risk approach) and assumes that
Site related contaminated soils do not have the potential to
adversely affect any ground water. drinking source. The second
estimate includes all Site related contaminated soils which have
the potential to affect any ground water (i. e., ground water
protection) .
The estimate of volume for the Site-specific risk approach is 4,700
cubic yards (yd3). The target area under this approach is shaded
in Figure 3. This estimate includes only soils around the existing
on-Site structures that contain contaminants exceeding Site-
specific acceptable risk levels of lxlO. for carcinogenic risk and
a hazard index ratio of 1 for noncarcinogenic risks. The maximum
depth for potential exposure is considered to be 10 ft bgs based on
what is determined to be a reasonable scenario in the risk
assessment. The average depth for the Site, however, is considered
to be 6.3 ft bgs based on the distribution of contaminants in soil.
The area is estimated to be 20,000 ft2 with the average estimated
depth of 6.3 ft bgs yielding an estimated volume of 4,700 yd3 of
soil requiring remediation.
The volume estimate for the ground water protection scenario is
approximately 37,500 yd3. The target area under this approach is
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Adams
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Warehouse
511
503
500
Genesse Street - -
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Figure 3 Area for Remediation
Alternatives 3-9
Adams Plating
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15
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FIgUre 4 Area for Remediation
Alternative 10 - Michigan Type B
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20
all contaminated soils that ~ave the potential to adversely affect
any ground water. Soil areas were determined to have the potential
to adversely affect ground water if contaminant concentrations in
soils exceed Michigan Act 307 Type B cleanup levels which were
derived using a standard exposure scenario. Soils under the
existing on-Site structures, which are assumed to be contaminated,
were included in this estimate. Vertically, at each RI boring
location, the sample from the greatest depth exceeding Type B
levels was used as a base depth. All base depths were added
together and averaged to estimate an average depth of contamination
for the Site. Under this scenario, contaminated soils include an
estimated area of 90,720 ft2 with an average estimated depth of 1.1..5
ft bgs yielding a volume of approximately 37,500 yd3 of soil
requiring remediation.
These volumetric estimates are derived from two approaches for
addressing soil contamination at the Site. The State requested that
U.S. EPA evaluate a groundwater protection approach using Michigan
Act 307 Type B cleanup levels. In addition, U.S. EPA evaluated a
Site-specific risk approach. U.S. EPA considers the Site-specific
cleanup approach preferable to the ground water protection approach
for three primary reasons: 1.) it is not necessary to remediate
soil to Type B groundwater protection standards because no
groundwater ingestion exposure pathway exists and there is little
or minimal- potential for the bedrock aquifer to be impacted by
Site-specific contamination, 2) cleaning the Site up to Type B
ground water protection levels would require remediating a large
volume of soils that U.S. EPA has determined currently do not pose
a health hazard, and 3) the ground water protection approach would
require the demolishing of buildings which. are acting as caps
limiting exposure to contaminated soils.
Hazardous Waste Classification of Soils
The Site contaminated soils have not been classified as RCRA listed
or characteristic hazardous wastes, or hazardous wastes under
Michigan I s Act 64, to date. However, a portion of the contaminated
soils at the Site have the potential to be characteristic for
metals.
No conclusive proof to support the classification of contaminated
soils at the Site as RCRA listed hazardous waste exists. While the
APC is a small quantity generator of RCRA-listed waste (wastewater
treatment sludges from.electroplatiilg operations, waste code F006) ,
no information is available concerning how these wastes were
managed or suggesting the F006 waste is the source of the
contamination at the Site.
The RI defines the APC' s wastewater as rinse water from the
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21
drain tile system that apparently. leaked. Despite its high
chromium concentration, rinse water from electroplating operations
is not a listed waste. It is possible other electroplating wastes
such as plating baths (F007) and residual sludges from plating
baths (FOOS) may have been improperly disposed of at the Site, but
no information is available concerning the management of these
types of wastes and nothing suggests that RCRA listed wastes were
released along with the rinse water.
The RI also states that acetone, methylene chloride, carbon
tetrachloride and 1,1,1-TCA were used as degreasing solvents at
this Site although no used solvents are listed on the RCRA
hazardous waste notification form. The presence of these
constituents is not conclusive proof that listed solvents were
improperly disposed of at the Site. It is not anticipated that the
limits for volatile organic characteristic waste will be exceeded
because most of the volatile constituents in the solvents used at
the Site are not identified characteristic parameters under the
Toxicity Characteristic Rule.
Neither the EP Toxicity or the Toxicity Characteristic Leaching
Procedure (TCLP) analysis were performed on samples of Site soils.
Because of this, it is uncertain whether contaminated soils at the
Site can be classified as RCRA characteristic hazardous waste, or
hazardous- wastes under Michigan I s Act 64. The contaminated soils
in the tile drain system at the Site may contain chromium at
concentrations high enough to be classified as hazardous waste
based on the RCRA characteristic of toxicity for metals.
Therefore, soils shall be tested under the TCLP for metals as part
of any intrusive remediation approaches.
Soils at the Site are not likely to be characteristic for VOCs. In
addition to acetone; methylene chloride; and 1,1,1-TCA; other VOCs
detected in the subsurface soils at the Site include up to 1,200
"g/kg of ethylbenzene; up to 2,520 "g/kg of bromomethane; and
4,000 "g/kg or more of 1,1-DCA, methyl ethyl ketone (MEK),
chloromethane, and 1, 1, 2 - TCA. Of these VOCs , onl Y MEK is a
characteristic parameter, and the highest concentration of MEK
detected in on-Site soils (4,200 ~g/kg) is not likely to exceed the
regulatory threshold. If the soils are not characteristic wastes
because of the VOCs, then treatment of Site contaminated soils for,
VOCs will not be necessary prior to disposal in a ,solid waste
(Subtitle D) landfill.
VI.
StDSHARY 01' SITE R.ISES
In order to characterize the current and potential threats to human
heal th and the environment that may be posed by the contaminants at
the Site, a Baseline Risk Assessment (RA) was prepared according to
u.S. EPA's Risk Assessment Guidance for Superfund (RAGS): volumes
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22
Chemicals of Potential ConCen1
In order to calculate risks to human health and the environment
posed by the Adams Plating Company Site, chemicals of potential
concern were identified. Chemicals of potential concern are
defined as chemicals that are potentially site-related and whose
data are of sufficient quality for use in the quantitative risk
assessment. Chemicals of potential concern were identified based
on sampling of surface soil, subsurface soil and water in
basements. The Site history, analytical methods, quantitation
limits, data qualifiers, concentrations in blanks and background
concentrations were evaluated as described in RAGS. A summary of
chemicals of potential concern based on this evaluation is
presented in Table 1. This is the same as Table 1- 2 of the
Baseline Risk Assessment.
The chemical database was further organized by grouping the data
according to medium- specific exposure areas and identifying medium-
specific background samples. The data for each exposure area were
then evaluated according to the following four primary criteria:
(1) identification of exposure areas and identifying background
sample locations, (2) comparison with background levels,
(3) frequency of detection, and (4) essential human nutrient value.
Based on the methods and criteria discussed above, chemicals of
potential concern were identified. These chemicals generally
include the following: .
Chemicals positively identified in at least one sample in
a given medium and chemicals with certain identities but
uncertain concentrations
Chemicals detected at concentrations
concentrations in blank samples
, .
above
their
Chemicals detected at concentrations
naturally occurring concentrations
above
their
Exposure Assessment
The exposure assessment identifies potential receptors and complete
exposure pathways, and estimates chemical intakes for potentially
exposed populations.
potentially exposed populations include on-Site residents, on-site
trespassers, and construction workers. Subpopulations of
particular concern are limited primarily to children who may
trespass on Site or children, elderly individuals, or pregnant
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TABLE 1
-~
CHEMICALS OF POTENTIAL CONCERN AT THE APC SITE
GROUND
MEDIA SOn. WATER
VOC
1,1,2.- TCA - X
ACETONE X X
cm..oROE11lANE X X
I,I-DCA X X
I,2.-DCA - X
I,2-DCE X X
l,2.-DCE (Total) X X
l,2.-DIcm..oROPROPANE X -
ETBYLBENZENE X -
ME'IBYLENE CHLORIDE X -
TOUJENE X X
1,1,1-TCA X X
TCE X X
EYLENES (Total) X X
SVOC
ANTHRACENE X -
BENZO(a)ANTBRACENE X -
BENZO(a)PYRENE X -
BENZO(b)n.uORATHENE X -
BENZO(k)FLUORATBENE X --
BENZO(g,h,i)PERYLENE X -
BIS(2-ETBYLBEXYL)PBTBALATE X X
CBRYSENE X -
Dl-o-BtTI'YL PII'I'IIALATE X -
,
DI-o-OCI'YL PII'I'IIALATE X -
FLUORA'I'BENE X -
n.uORENE X -
INDENOU,2,3-c,d)PYRENE X -
2-METBYLNAPIlTBALENE X -
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TABLE 1 (Continued)
CHEMICALS OF POTENTIAL CONCERN AT Tl:tE APC SITE
GROUND
MEDIA SOn.. WATER
PHENAN11IRENE X -
PYRENE X -
INORGANIC COMPOUND
ANTIMONY X -
ARSENIC X X
BARIUM - -
BERYLLIUM - X
CADMIUM X -
CHROMIUM (01 AND VI) X X
COBALT X X
COPPER X -
MANGANESE X X
-
MERCURY X -
NICKEL X X
sn..VER X -
VANADIUM - X
ZINC X -
Notes:
- = Chemical ~ not of poteDtial coocem in 11m media
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25
Potential receptors may be exposed to contaminants in soils,
groundwater, and homegrown fruits and vegetables. Soil exposure
include direct ingestion, dermal contact, and inhalation of soil
particulate. Exposure to groundwater is assumed to take place when
groundwater floods area basements during periods of heavy rain.
Exposures include dermal contact and inhalation of VOCs released
from the groundwater. Ingestion of groundwater was not evaluated
because all residents and businesses in the vicinity of the Site
receive their water fram the municipal system, and the potential
gr.ound water yield fram the saturated zones in the immediate
vicinity of the Site is insufficient to reasonably support the
installation and use of private wells. A maximum depth of 10 feet
bgs was assumed for exposure to subsurface soils. A depth of 10
feet bgs was assumed to be a reasonable estimate of the depth to
which soils would be excavated during construction activities. It
was assumed that 10% of the total chromium present in samples
consisted of chromium VI in order to evaluate risk from chromium VI
because no reliable analytical methods for measuring chromium VI
were available. Finally, potential receptors may be exposed
through ingestion of contaminants in homegrown fruits and
vegetables.
For each exposure pathway evaluated, carcinogenic. and
noncarcinogenic health risks were characterized for the reasonable
max~um exposure scenario. In general, the standard and default
exposure assumptions recommended by u.s. EPA guidance were used, as
well as conservative estimates and best professional judgement. . In
general, exposure is averaged over a 70-year lifetime for cancer
risk estimates, exposure duration for noncarcinogenic effects is
assumed to be 30 years, contact rates for exposure to chemicals in
soils are 200 mg soil/day for children and 100 mg/day for adults
for the ingestion route, the daily contact rate for exposure to
chemicals in air is 20 rtf/day for adults and 22 rtf/day for children,
and the average body weight for an adult, a child 1- to 6-years
old, and a child 7- to 15-years old is 70 kg, 15 kg and 37 kg
respectively. In addition, the methods and assumptions used in the
exposure assessment are presented in Section 7.2 of the RI report.
Estimated exposure intakes are presented in Appendix H-5 of the RI
report.
Toxicity Assessment:
Available toxicity factors of carcinogenic and noncarcinogenic
chemicals of potential concern are discussed and presented in
Section 7.3 of the RI.. report. The chemicals of potential concern
selected for the RA for the Site have a wide range of carcinogenic
and noncarcinogenic effects associated with them. The reference
dose (RfD) values and slope factors (SF) were key dose-response
variables used in the quantitative RA. The RfD, expressed in units
of milligrams per kilogram per day (mg/kg/day), for a specific
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~'"
26
risk over a lifetime of exposure. The RfD value is used to assess
noncarcinogenic effects. The SF, expressed in units of (mg/kg/day)-
1, provides a conservative estimate of the probability of cancer
development from a lifetime of exposure to a particul~r level of a
potential carcinogen. Brief toxicity summaries of the chemicals of
potential concern that may present the greatest carcinogenic risks
and are present at the highest concentrations at the Site are
presented in Section 7.3 of the RI report. These chemicals include
arsenic; carcinogenic PARs; chromium; copper; 1,1-DCA; 1,1,1-TCA;
and zinc. Risks from exposure to chemicals of potential concern
without RfDs and SFs are not quantified in the RA. Instead, they
are discussed in the RA qualitatively.
Toxicological profiles for all chemicals of potential concern are
presented in Appendix H-3 of the RI report.
Risk
CbaracterizatioD
Because media at the Site were divided into exposure areas, several
possible methods exist for combining medium-specific data to
evaluate overall Site risk.
Exposure pathways for chemicals of potential concern associated
with each pathway were evaluated quantitatively to estimate the
risks associated with human exposure to chemicals of potential
concern at the Site. As a part of this assessment, risks. from
noncarcinogenic and carcinogenic effects were estimated separately
because they are thought to operate under different mechanisms of
action and are not necessarily comparable. The noncarcinogenic and
carcinogenic risks were estimated in terms of hazard index (HI) and
excess lifetime cancer risk (ELCR) values, respectively. .
The HI for noncarcinogenic risks is the ratio of an exposure level
to an RfD. The ELCR for carcinogenic risks is obtained by
multiplying the estimated exposure level by the SF. An HI of 1.0
or less is considered acceptable as the RfD represents a "an
acceptable" exposure level. An ELCR of lE~06 is considered as the
point of departure for determining acceptable risks.
The possibility of exposure to multiple chemicals of potential
concern was considered in the RA because such exposure is possible
in various exposure scenarios. Under such a situation, chemicals
. of potential concern may affect a receptor in an additive,
synergistic, or antagonistic manner. Additive impact of exposure
to multiple chemicals.. of potential concern was assumed in the RA.
HIs and ELCRs for individual chemicals of potential concern in an
exposure area were summed to produce total HIs and ELCRs associated
wi th exposure to all chemicals of potential concern in that
scenario. summaries of noncarcinogenic and carcinogenic risks by
medium. and route of exposure in terms of reasonable maximum.
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27
Based on total estimated exposures and current toxicity
information, total carcinogenic risk levels to expo~ed populations
from chemicals of potential concern at the Adams Plating Company
Site range from 3X10~ to 5x10~. These risk levels exceed the less
stringent end of the target risk range (1xlO~). These exceedances
are primarily caused by resident, trespasser and construction
worker inhalation of arsenic and chromium VI in subsurface soils
during construction digging. The spacial distribution of the
exceedance area is shown in Figure 5 as Area 1. Unacceptable risk
was generally not associated with Area 2 in Figure 5. The only
noncarcinogenic risks (HI) that exceed 1 are those related to
residential ingestion of surface--soil (child risk of 4.6) and
dermal contact with surface soil (child risk of 4.6 and adult risk
of 2.7). Again, these risks are within Area 1 of Figure 5. These
risks from exposure to surface soil primarily result from the
presence of antimony, chromium III, and chromium VI. Carcinogenic
exposure from ingestion of homegrown fruits and vegetables ranges
from 3E-06 to 1E-05. These risks primarily result from the
presence of PARs.
In Area 2 of Figure 5, a carcinogenic exposure from ingestion of
homegrown fruit from a pear tree is 3E-06. However, this risk was
based on uptake models from the agricultural industry and not on
actual sample data from the fruit. U. S. EPA may evaluate the need
for the chemical analysis of pears from the tree and its fate
during the remedial design.
Based on sampling results and the Risk Assessment, U.s. EPA
determined risks associated with the contaminated water in the
basements were outside of the risk range; and therefore, not of
concern.
Ecological. RA
currently, no data indicates that biological receptors are
experiencing adverse effects from on-Site contaminants. On-Site
vegetation may be uptaking and accumulating contaminants; -however,
no vegetative stress was observed on Site. Likewise, terrestrial
species and birds may be exposed to contaminants through dermal
contact with soils,. ingestion of contaminated vegetation, or
ingestion of soil indirectly. However, the Site is located in a
developed residential and industrial area. No threatened,
endangered, or sensitive environments were identified at or seen
near the Site. Based on available information, it was assumed that
chemicals of potentiaa concern at the Site pose minimal risks to
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I>'
TABLE 2
SUMMARY OF NONCARCINOGENIC RISK
BY MEDIUM AND EXPOSURE ROUTE
I GOUTE I RESIDENT ~ TRESPASSER I CONSTRUCTION
MEDIUM I I WORKER
CHR.D ADULT CHILD ADULT
, 'Ingestion 4.6£+00 5.0E-Ol 2.7E-02 1.4E-02 NA
Surface
Soil DennaI
Contact 5.1£+00 3.3E+00 2.3E-02 1.8E-Ol NA
Ingestion NA NA NA NA 6.4E-03
Dennal
Subsurface Contact NA NA NA NA I.SE-02
Soil Inha1ation 3.8E-Ol 7.4E-02 1.9E-02 9.2E-03 1.9E-Ol
Ingestion
of Produce 2.9E-Ol 1.6E-Ol 1.3E-02 1.1£..02 NA
Dermal
Grouadwater Contact 5.8£..03 9.8E-04 NA NA NA
InbaIation 1.7E-04 1.4E-05 NA NA NA
TABLE 3
SUMMARy OF CARCINOGENIC RISK
BY MEDIUM AND EXPOSURE ROUTE
I ~UTE I RESIDENT TRESPASSER
MEDIUM CONSl'RtJC110N
CHILD ADULT TOTAL CHILD ADULT TOTAL WORKER
Ingestion 4£-11 2£-11 6£-11 3£-11 4£-13 7£-13 NA
Surface
Soil Dermal
Contact 5£-11 1E-I0 2E-I0 3£-12 5£-12 8£-12 NA
Ingestion NA NA NA NA NA NA 1E-88
Dermal
Subsurface Contact NA NA NA NA NA NA 3E-08
. ,. . ." ......... ... .' . .." .. .... :
Soil ".'. .'.'.".', '..
. . . . .. "' ... . .' . . . ." ... I::::,~: " ' , ' ..' , , , ..
. . . .. . . ':::2E;os,:::,'
,/hahllllltiOD':", )::3E;04:::, ,,::~,::::, ':::::::5£;:04::::,:" :: m;;os 2AS.. '3RS
,..', . .:,:.,
Ingestion
of Produce 3E-06 8E-06 1E-05 2E-07 3£..07 SE-07 NA
~
Grouadwater Contact 1E-07 9E-08 2E-07 NA NA NA NA
Inba1ation 4E-08 4E-08 8E-08 NA NA NA NA
-------
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Plating
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503
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Genesse Street
o
FIgUre 5 Soli Exposure Areas
Adams Plating
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"'-
30
DESCRIPTION OP ALTERHATIVES
VII.
Ten alternative remedial options for protecting human health and
the environment from contamination associated with soil
contamination at the Site were developed and evaluated for the
Adams Plating Company Site. These alternatives are presented in
more detail in the Feasibility Study document which is available in
the information repositories and the Administrative Record file for
the Site.
All the Alternatives involving an action, with the exception of
Alternative 10, were developed to remediate contaminated soils that
contribute to Site-specific risk identified in the RA. Alternative
10 involves remediating contaminated soils to assure that
contaminants in soils do not pose a threat of aquifer contamination
(cleanup to achieve Act 307 Type B ground water protection
standards). With the exception of Alternatives 1, 2 and 9, the
Alternatives involve excavation, capping or a combination of
excavation and capping of contaminated soils. For Alternatives
that include excavation, the differences between them result from
the amount of material to be excavated and whether the contaminated
soils will need to be treated in-situ or off-Site to meet RCRA land
disposal restrictions prior to disposal in a Subtitle D landfill.
For Alternatives that include capping, the differences are in the
cap design. Alternative 9 primarily involves in situ stabilization
and solidification of contaminated soils with the resulting
material being left in place. Alternative 1: No Action and
Alternative 2: institutional controls and monitoring are the other
two approaches considered. Institutional controls and ground
water monitoring are also included in Alternatives 3 through 9.
All remedial alternatives are described in more detail below.
ten alternatives are as follows:
The
Alternative 1:
Alternative 2:
Alternative 3:
Alternative 4:
Alternative 5:
Alternative 6:
Alternative 7:
. Al ternati ve 8:
No Action
Institutional Controls
Soil Cover
Multilayer Cap
Soil Excavation with Off-Site Disposal
Soil Cover and Soil Excavation with Off-
Site Disposal
Multilayer Cap and Soil Excavation with
Off-Site Disposal
In Situ. Fixation and Stabilization and
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31
Alternative 9:
Partial Soil Excavation with Off-Site
Disposal and In Situ Stabilization and
Solidification with Soil Cover
Alternative 10:
Relocation of Residences and Businesses,
Demolition of Buildings, and Soil
Excavation with Off-Site Disposal
The costs presented for each alternative include capital costs
(such as equipment, labor and other construction expenses to put
the remedy in place) and operation and maintenance (O&M) costs
(su'ch as monitoring the ground water or maintaining the cap).
These costs are then presented as a net present worth. This is a
method of economic calculation that estimates the total amount of
money which would need to be invested today, assuming a 30 year'
project life, in order to cover initial construction costs as well
as future maintenance costs.
A summary of the maj or Federal and State Applicable or Relevant and
Appropriate Requirements (ARARs) which apply to the Site is
provided in the Statutory Determinations Section of this ROD.
Additional informat:ion concerning ARARs also is provided in the FS
and the Proposed Plan previously issued. The two major ARARs for
the Alternatives are: Michigan Act 307 and RCRA.
.................********.*.*..******....***..*..***....**.*.....
Alternative 1:
No Action
Superfund regulations contained in the National Contingency Plan
(NCP) require that a" -no action- alternative be considered at every
site. This alternative serves as the baseline to which all other
al ternati ves can be compared. Under this remedial al ternati ve, no
active remedial action or institutional action would be taken
regarding the Site.
Timeframe:
capital Costs:
o & M Costs:
Net Present Worth:
Not Applicable
$0
$0
$0
.****......*.*...*.*****.*************.*********.***..***...*.**.
Alternative 2: Xnstitutional Controls
The primary objectives of institutional controls such as land use
(deed) restrictions, access restrictions (fencing), and groundwater
monitoring are to (1) prevent human exposure to on-Site chemicals
by preventing intrusive type of, acti vi ties such as digging or
installing residential wells and (2) monitor groundwater quality
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32
This alternative may involve the following components utilizing
. State or local authorities to the degree they are appropriate:
Restricting soil excavation in deeds for areas warranting
remediation
Restricting installation of residential water wells in deeds
for areas warranting remediation
Constructing permanent
contaminated areas
fences
to prevent
access
to
the
Monitoring groundwater to characterize contaminant migration
from soil to groundwater and to assess continued sources
Alternatives 3 through 9 may also include institutional controls.
Institutional controls for Alternatives 3 through 9 are slightly
modified as follows and would be used to the degree necessary:
Restricting
remediated
soil
excavation
in
deeds
for
areas
to
be
Restricting installation of 'residential water wells in deeds
for areas to be remediated and for some off-site residential
areas
.
Constructing temporary fencing around areas during remediation
Monitoring groundwater to evaluate the effectiveness of soil
remediation .
T~eframe for remedial
Capital Costs:
o & M Costs (Annual):
o & M (30 yrs at 10%):
Net Present Worth:
action:
2-3 weeks
$750
$34,400
$324,250
$325,000
*****************************************************************
Alternative 3: Soil Cover
This alternative involves placing a soil cover over the
contaminated soil area to prevent human contact with the
contaminated soil (see area shaded in Figure 3). In backyard
areas, the noncompacted soil caver would consist of 8 inches of
clean fill overlain by 4 inches of topsoil. The topsoil would be
reseeded with a mixture of grasses to limit wind and water erosion
and to increase the transpiration o~ water from underlying soils.
In the gravel Parking area, new gravel would be placed over the
soil caver. The soil and gravel in the parking area would be
slightly compacted and would become more compacted as the parking.
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33
T~eframe for remedial
Capital Costs:
o & M Costs (Annual):
o & M (30 yrs at lOt):
Net Present Worth:
action:
3-5 weeks
$ 19,000
$ 35,200
$331,000
$350,000
*****************************************************************
ALterna ti ve 4: Xul tilayer Cap
This alternative involves constructing a multilayer cap over the
contaminated soil areas (see shaded area in Figure 3). A
multilayer cap consists of a single barrier layer in combination
with other layers to secure the barrier layer or promote drainage.
The barrier layer for a multilayer cap can consist of any number of
different types of materials. An imper.meable prefabricated clay
liner composed of sodium bentonite clay with an extremely low
hydraulic conductivity (2 x 10-10 centimeter per second) would be
installed first. A 10-inch-thick concrete cap would be constructed
on top of the prefabricated clay liner to minimize the infiltration
of precipitation in the contaminated soil at the Site. In this
case, the prefabricated clay liner would act as a backup for the
concrete cap in case the cap is damaged. A temporary fence would
be constructed during remedial activities and would be taken down
upon completion of these activities.
This Alternative, and Alternative 3, assumes that contaminated
soils at the Site are not classified as RCRA or Michigan Act 64
hazardous waste. Soils at the Site may be classified as RCRA
characteristic hazardous waste during design (see Summary of Site
Characteristics Section of this ROD). .If soils are classified as
RCRA hazardous waste, the described cap would not meet RCRA
requirements. The construction of a RCRA cap at the Site would be .
extremely difficult to implement because of the Site's physical
setting and its close proximity to residential areas. Therefore,
a RCRA cap was not retained for further consideration as a remedial
alternative.
Timeframe for remedial action: 6~8 weeks
Capital Costs: $i60,000
o & M Costs (Annual): $ 35,000
o & M (30 yrs at 10%): $340,000
Net Present Worth: $500,000
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"'"
34
Alternative 5: Soil Excavation with Off-Site Disposal
Under this alternative, approximately 4700 yd3. of contaminated
soils contributing to Site specific risk would be excavated from
the Site and disposed of in an off-Site solid waste (Subtitle D)
landfill. Excavation and disposal would include old clay tiles,
the PVC collection system which includes the 2-1,000 gallon
underground tanks, and concrete sumps.
The estimated area requiring remediation is shaded in Figure 3.
The area shaded in Figure 3 is the a~ea estimated to contain the
Site related contamination in soils above background based on the
RI and all soils responsible for Site-specific carcinogenic risks
greater than 1x10~ or a hazard index ratio of 1.0 for exposure
from ingestion, dermal contact or inhalation based on the RA. It
is expected that the soil would be excavated to about 10 feet bgs
in the area where the clay tile is located and only excavated to
about 3 ft bgs along the edges of the area to be remediated. The
excavated portion of the Site would be backfilled with clean soil,
reseeded in the residential areas and covered by gravel in the
parking area.
vertical barrier walls would be installed along .the west and south
walls of the APC building and along the .west and north walls of the
warehouse to protect the clean backfilled soil from
recontamination.
The excavated soil would be disposed of in a solid waste (Subtitle
D) landfill, bu~ may require treatment prior to disposal. Soils
would be tested using the TCLP for metals prior to disposal. TCLP
results would be used to determine if excavated soils are RCRA, or
Michigan Act 64, characteristic hazardous wastes because of the
metals in the soils. Soils which are found to be RCRA, or Michigan
Act 64, characteristic hazardous wastes are subject to RCRA and
would be treated before disposal in the Subtitle D landfill. If
treatment for the characteristic wastes is necessary, the soils
would be treated using fixation and stabilization methods to a
level below LDR requirements such that the material no longer
exhibits the characteristic which caused it to be a RCRA, or
Michigan Act 64, hazardous waste.
Water collected during the excavation procedure would be
containerized, tested, and treated off-Site before disposal. Off-
Site treatment and .disposal would be conducted at an NPDES
permitted treatment facility in the LanSing area. The volume of
water estimated to be encountered during excavation is about
10,000 gallons.
Material handling equipment would be used to diminish air dispersal
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".\. .
'.
.'
.
..
35
excavating contaminated soils. Dust suppressants
monitoring may also be used during excavation.
and
air
A temporary fence would be constructed and will be in place during
the time remediation activities are conducted and would be taken
down upon completion of these activities.
Timeframe for remedial
Capital Costs:
o & M Costs (Annual):
o & M (30 yrs at 10%):
Net Present Worth:
action:
6-8 weeks
$ 1,500,000
$ 34,400
$ 325,000
$ 1,800,000
......................*..*..*.....**....*.********.***..*...*.***
Alternative 6: Soil Cover
Disposal
and
Soil
Excavation
with
Off-Site
This alternative is a combination of Alternatives 3 and 5 and would
involve placing a soil cover over less contaminated portions of the
area shaded in Figure 3 and excavation of about 2,000 yd3 of
contaminated soil in the other areas. The depth of excavation is
estimated to range from 3 to 10 feet bgs. The contaminated soils
south of the APC building would be excavated and would include old
clay tiles, the PVC collection system which includes the 2-1000
gallon underground tanks and concrete sumps. The excavated area
would be backfilled with clean soil and reseeded. The soil cover
would be placed over the parking area and along the east and west
sides of the area requiring remediation. A vertical barrier,
described in Alternative 5, would be installed along the west and
south walls of the APC building and along the west and north walls
of the warehouse to'protect clean fill from recontamination.
Disposal of excavated materials would be addressed in the same way
as described in Alternative 5. Water, and particulate and organic
volatilization emissions resulting from excavation activities would
also be addressed in the same way as described in Alternative 5.
The water volume produced during excavation j,s estimated to be
approximately 10,000 gallons.
A temporary fence would be constructed and will be in place during
the t~e remediation activities are conducted and would be taken
down upon completion of these activities.
T~eframe for remedial
capital Costs:
o & M Costs (Annual):
o & M (30 yrs at lOt):
Net Present Worth:
action:
6-8 weeks
$ 805,000
$ 35,400
$ 335,000
$ 1,150,000
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36
Alternative 1: Multilayer Cap and Soil Excavation with Off-Site
Disposal
This alternative is similar to Alternative 6, but would involve a
multilayer cap, as described in Alternative 4, instead of a soil
cover over portions of the residential area and the gravel parking
area. Under Alternative 7, about 2,700 yd3 of soil would be
excavated, which is slightly more than Alternative 6.
Di~posal of excavated materials would be addressed in the same way
as described in Alternative 5. Water, and particulate and organic
volatilization emissions resulting from excavation activities would
also be addressed in the same way as described in Alternative 5.
The water volume produced during excavation is estimated to be
approximately 10,000 gallons.
A temporary fence would be constructed and will be in place during
the time remediation activities are conducted and would be taken
down upon completion of these activities.
Timeframe for remedial
Capital Costs:
o & M Costs (Annual):
o & M (30 yrs at lOt):
Net Present Worth:
action:
6-8 weeks
$ 1,200,000
$ 35,000
$ 340,000
$ 1,500,000
*****************************************************************
Alternative 8: xn Situ p~ticn and Stabilization
Excavation with Off-Site Disposal
and
Soil
As indicated in Alternative 5, soils which are RCRA characteristic
wastes will be treated to meet land disposal restrictions prior to
disposal. Alternative 8 was developed to evaluate the option of
treating the soils on-Site prior to excavation and disposal.
Under Alternative 8, in situ fixation and stabilization would be
performed on contaminated soils shaded in Figure 3 before
excavation of the contaminated soils. After mixing, treated
contaminated soils would be excavated and transported to an off-
Site solid waste (Subtitle D) landfill for disposal. Approximately
6,000 yd3 of treated soil would be excavated under this alternative.
Old clay tiles, the PVC collection system which includes the 2 -1000
gallon underground tanks, and concrete sumps would be excavated and
disposed of along with the contaminated soil. A vertical barrier,
described in Alternative 5, would be installed along the west and
south walls of the APC building and along the west and north walls
of the warehouse. The excavated area would be backfilled with
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37
Volatilization of organics, air dispersal of dust particles and
groundwater collection procedures during the excavation would be
handled as described in Alternative 5. The ground water volume
produced during excavation is estimated to be approximately 10,000
gallons.
A temporary fence would be constructed and will be in place during
the time remediation activities are conducted and would be taken
down upon completion of these activities.
Timeframe for remedial
Capital Costs:
o & M Costs (Annual):
o & M (30 yrs at 10%):
Net Present Worth:
action:
$
$
$
$
10-15 weeks
1,500,000
34,400
342,000
1,850,000
.....................**************************************.*****
Alternative 9: Partial Soil Excavation with Off-Site Disposal and
~ Situ Stabilization and Solidification with Soil
Cover
This alternative uses partial excavation (to 3 ft bgs) of
approximately 2,200 yd3 of soils with off-Site treatment (if
necessaryr and disposal in a solid waste (Subtitle D) landfill
followed by in-situ stabilization and solidification of the
remaining contaminated soils down to 10 feet bgs in the area shaded
in Figure 3. The top 3 feet of soil would be excavated to allow
enough room for the backfilling of clean soil. Old clay tiles, the
PVC collection system which includes the 2-~OOO gallon underground
tanks, and concrete sumps would be excavated and disposed of along
with the soil.
After excavation, soils to be stabilized and solidified would be
replaced using injectors or tillers that simultaneously inject and
mix stabilization reagents with the soils. After solidification,
sample cores of the stabilized material would be collected for TCLP
analysis to determine the success of the treatment process.
Monitoring the stabilization and solidification process may be
required for 5 years based on vendor specifications. One or 2 feet
of soil cover would be placed over the solidified area to prevent
surface erosion and to restore the area. The soil cover would be
reseeded or covered by gravel as previously described in
Alternative 5.
Volatilization of organics, air dispersal of dust particles and
groundwater collection procedures during the excavation would be
handled as described in Alternative 5. The ground water volume
produced during excavation is estimated to be approximately 10,000
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38
A temporary fence would be constructed and will be in place during
the time remediation activities are conducted and would be taken
down upon completion of these activities.
$
$
$
$
10-15 weeks
1,100,000
37,400
390,000
1,500,000
Timeframe for remedial
Capital Costs:
o & M Costs (Annual):
o & M (30 yrs at lOt):
Net Present Worth: .
action:
*****************************************************************
Alternative 1.0: R.elocation of R.esidences and Businesses, Demolition
of Buildings, and Soil Excavation with Off-Site
Disposal
Under Alternative 10, contaminated soils that have the potential to
adversely affect any ground water would be excavated, treated, if
necessary, and disposed of in an off-Site solid waste (Subtitle D)
landfill. The estimate of this area is shaded in Figure 4. About
37,500 yd3 of soil would be excavated from the entire area down to
an approximate depth of 10 feet. The excavation and disposal
procedures _would be similar ,to the procedure described in the
discussion for Alternative 5.
Ten residences and three businesses in this area would be relocated
and all buildings would be demolished. The procedure for building
demolition would be typical construction demolition. The only
precaution taken would be to separate aboveground components such
as walls and roofs from below ground components such as basements,
footings, and floor slabs. The below ground components would be
steam cleaned and aboveground and below ground components would
both be disposed of in a construction debris (MDNR-Type III)
landfill.
All utility lines, fences, trees, and shrubs in the area would be
removed. All old clay tiles, the PVC collection system which
includes the 2-1000 gallon underground tanks, and concrete sumps
would be excavated and disposed of along with the contaminated
soil.
volatilization of organics, air dispersal of dust particles and
water collection procedures during the excavation would be handled
as described in Alternative 5. The volume of water estimated to be
encountered during excavation is about 50,000 gallons.
Excavation, treatment, and off-Site disposal for this alternative
is preferred over in situ treatment of soils for several reasons.
First, in situ treatment would require more equipment, stagi.ng, and
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39
the entire area into a solidified mass that would not be suitable
for the residential environment.
Timeframe for remedial action:
(includes relocation
and remediation)
Capital Costs:
o & M Costs. (Annual) :
o & M (30 yrs at 10%):
Net Present Worth:
12-28 weeks
$
$
$
$
7,700,000
o
o
7,700,000
[[[
VIII.
StD!MAR.y OF COMPARA'1'IVE ANALYSIS OF AL'1'BRNA'1'IVES: '!'BE NINE
CRI'l'ERIA
In accordance with the NCP, the relative performance of each
alternative is evaluated using the nine criteria [Section
300.430(e) (9) (iii)] as a basis for comparison. An alternative
providing the "best balance" of tradeoffs with respect to the nine
criteria results from this evaluation.
Threshold Criteria
Overall Protection of H1DII8J1 Health and the Environment: determines
whether an alternative eliminates, reduces, or controls threats to
human health and the environment.
Compliance with Applicable or Relevant and Appropriate Requirements
(ARAR.s): evaluates whether the alternative meets federal and state
environmental laws pertaining to the site.
Balancina Criteria
Long-'1'er.m Bffectiveness and Per.manence: considers the ability of
an alternative to protect human health and the environment over
time.
Reduction of '1'oxicity, Kobility or Volume Through Treatment:
evaluates an alternative's use of treatment to reduce the harmful
nature of contaminants, their ability to move in the environment,
and the amount of contamination present.
Short-'1'er.m Bffectiveness: considers the length of time needed to
implement an alternative and the risks it poses for workers,
residents and the environment during implementation.
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40
Cost: evaluates estimated capital and operation and maintenance
(O&M) costs, as well as present-worth costs.
Hodifvina Criteria
State Acceptance: considers whether the state agrees with U.S.
EPA's analysis and recommendations as presented in the RI/FS and
the Proposed Plan.
community Acceptance: considers the public's response to the
alternatives described in the proposed Plan and the FS. Specific
responses to public comments are contained in the Responsiveness
summary attached to this ROD.
EVALUATION OF THE ALTERNATIVES AGAINST THE NINE CRITERIA
The following analysis evaluates the ten alternatives under each of
the nine evaluation criteria.
1) Overall protection of human health and the environment. All
Alternatives, with the exception of Alternatives 1. and 2, would be
expected to provide protection of human health and the environment
by reducing or eliminating exposure pathways. Alternatives 5, 8
and 1.0 would be expected to provide overall protection of human
health and the environment through reduction in the accessibility
and mobility of the contaminants through excavation and/or
treatment. Alternatives 3, 4, 6, 7, and 9 would be expected to
provided overall protection of human health and the environment
through reduction in the accessibility and mobility of the
contaminants through various combinations of excavation, treatment
and/or cap placement.
2) compliance with ARAR.s: With the exception of Alternatives 1.
and 2, all alternatives would meet ARARS, unless it is determined
that the contaminated soils are RCRA, or Michigan Act 64,
characteristic hazardous wastes. RCRA LDR treatment requirements
may be applicable under Alternatives 3. through 1.0 if it is
determined that contaminated soils are RCRA, or Michigan Act 64,
characteristic hazardous wastes. Soils will be tested to see if
this is the case. If so, and placement is involved in the
Alternative, they will be treated to comply with RCRA Subtitle C
and Michigan Act 64 requirements. If the soils are RCRA
characteristic hazardous wastes, then Al ternati ves 3, 4 and 6 would
not meet RCRA or Michigan Act 64 requirements and a waiver would be
required to implemen\: these remedies. Michigan's Act 307 is a
comprehensive law and regulation which applies to the Site.
Alternatives 3 through 9 meet the Site-specific re~irements in Act.
307.' Alternative 10 meets specific cleanup standards for the
protection of ground water presented in Act 307.A further
explanation of Michigan Act 307 and the other ARARs, inc:luding
RCRA, for this Site can be found in the Statutory Determinations
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3) Long-term effectiveness and permanence: Alternatives 5, 8 and
10 would be effective in the long-term. . The Site contamination is
located in a mixed residential and industrial neighborhood..
Because residents live directly next to the contaminated soils, the
potential is high for human contact with the contamination.
Alternatives 5, 8 and 10 would reduce the amount of contamination
on-Site via transportation off -Site to a secure landfill. Although
the volume of contamination from the Site would not be reduced, the
contamination in the soils would be effectively isolated from the
environment and human contact by the secure off-Site landfill.
Those soils which are determined to be RCRA, or Michigan Act 64,
characteristic hazardous wastes would be treated prior to disposal
as well to further limit their mobility and toxicity. In addition,
even though Alternatives 5 and 8 would not remove soils assumed to
be contaminated from under buildings located in the area affected
by Site contamination, the contaminated soils under the buildings
at the Site are effectively isolated from the environment and human
contact by the buildings' foundations. Installation of vertical
barriers would protect the clean backfilled soils from potential
recontamination from any potentially contaminated soils under the
buildings. If any of the buildings within the target area of
contamination shown in Figure 3 are abandoned or demolished in the
future, options for remediation of contaminated soils under the
buildingCs) would be evaluated by U.S. EPA during a five year
review of the Site. The long-term effectiveness of these
alternatives would be a function of the long-term integrity of the
off-Site landfill. The long-term integrity of an off-Site
permitted secure landfill is expected to be greater than other
containment options evaluated in this ROD.
Alternatives 1 and 2 do nothing to prevent exposure to soil
contamination or mobility of the contaminants. Alternatives 3 and
4 offer some degree of long-term effectiveness by covering the
problem with soil, but covers require perpetual maintenance.
OVertime, the natural weathering process, as well as everyday
residential and industrial activities may affect the integrity of
the cover. Degradation of the covers' integrity may be accelerated
if administrative controls, such as restrictions on digging, are
not obeyed or become invalid. If the effectiveness of the cover
fails, exposure to contaminated soils once again becomes a
potential health concern. If the cover alternative fails, a new
cover would need to be constructed or another remediation option
evaluated. In either case, this would be disruptive to local
residents and businesses, create another potential Short-Term
health risk, and cost additional money.
Alternatives 6 and 7 offer better long-term effectiveness than
Alternatives 1, 2, 3 and 4 because they require the elimination of
some contaminated soils through excavation, similar to Alternative
5, 8 and 10. However, the same problems as indicated above would
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42
Alternative 9 would be effective over the long-term because the
potential for inhalation of contaminated soils is reduced by
treatment and covering. However, the permanence of the integrity
of soils treated in-situ has not been determined.
4)
R.eduction in toxicity, mobility or volume through treatment:
For all alternatives, no treatment process is used to address soil
contamination unless it is determined that they are RCRA
characteristic hazardous wastes. There is no reduction in
toxicity, mobility or volume through a treatment process for
Al ternati ves 1, 2, 3, and 4. Varying degrees of treatment may
apply to Al ternati ves 5 through 10 which would minimize the
toxicity and mobility, but not volume, if it is determined that the
contaminated soils are RCRA, or Michigan Act 64, characteristic
hazardous wastes.
5) Short-term effectiveness: For Alternatives 5 through 10, there
could be dust emissions during excavation activities to which
workers and the surrounding community could be exposed. To address
this threat, dust control measures would be implemented during
excavation activities and workers would wear protective clothing to
reduce the risks associated with remediation. There would also be
a higher than usual volume of construction traffic because of the
transport. 6f materials either to or from the Site.
Alternatives 3 through 7 would take the least amount of time to
implement (3-8 weeks). Alternatives 8 and 9 would take slightly
more time to implement than Alternatives 3 through 7 (10-15 weeks) .
Alternative 10 would require a significantly greater amount of time
than all other alternatives (12-28 months) .
6) Implementability: All the alternatives are technically
feasible in theory because the technology exists for the various
remedy components including excavation, capping and in-situ
solidification. In practice, Alternative 5 is fully implementable.
Alternatives relying on a cap (Alternatives 3, 4, 6 and 7) for the
primary remediation technology assume that contaminated soils at
the Site are not classified as RCRA, or Michigan-Act 64, hazardous
waste. Soils at the Site may be classified as RCRA, or Michigan
Act 64, characteristic - hazardous waste (see summary of Site
Characteristics Section of this ROD). If soils are classified as
hazardous waste, and the soils are not treated to render them non-
hazardous, the cap design would need to follow RCRA and Michigan
Act 64 specifications.., The construction of such a cap at the Site
would be extremely difficult to implement because of the Site's
physical setting and close proximity to residential areas.
Alternatives 8 and 9 would be extremely difficult - to implement
because the work would require large support areas to operate on-
Site equipment. On-Site equipment is also large and the equipment
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requiring remediation at the Site have limited accessibility and
open space due to the close proximity of businesses and residential
housing.
Administratively, Alternative 10 would be difficult to implement
because it requires relocation of ten residences and three
businesses and complete demolition of the buildings on Site. The
area targeted for cleanup under Alternative 10 is based on State of
Michigan standard cleanup levels which protect groundwater. u.S.
EPA has determined that no groundwater drinking water pathway
exists and the potential is extremely low for any off-site
groundwater drinking sources to be affected by soil contamination
at the site.
7) Cost: The capital costs, operation and maintenance costs and,
net' present worth of each remedial alternative are listed after
each alternative description above. Cost-effectiveness is
discussed in the Statutory Determinations section below. In
general, Alternative 1 is the cheapest $0, Alternatives 2 through
4 ranged from $325,000 to $500,000, Alternatives 5 through 9 ranged
from $1.2 million to $1.9 million and Alternative 10 was the most
expensive at $7.7 million. The cost for Alternative 5 ($1.8
million) was approximately in the mid range of these cost values.
8) State Acceptance: The State of Michigan concurs with the
selected remedy for this Site.
9) CODIIILUZ1i ty Acceptance: Communi ty acceptance is assessed in the
attached Responsiveness Summary. The Responsiveness Summary
provides a thorough review of the public comments received on the
Proposed Plan,' and the Agency's responses to. those comments. Since
issuance of the Proposed Plan for public comment, the general
public views on the selected remedy ranged from appreciation to
concern over leaving some contamination behind, the restrictions of
institutional controls and depressed real estate values of homes in
the area. In general, however, the public agrees that the action
should be taken.
IX.
'1'BE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, as amended
by SARA, the NCP, the detailed analysis of alternatives and public
comments, u.S. EPA has selected Alternative 5, as the remedial
action for the Adams Plating. Company Site. Given the available
information, the Agency believes that this alternative is
protective of human health and the environment, complies with
ARARs, provides the best balance of trade-offs under the nine
criteria and also represents a cost-effective solution.
Alternative 5 involves the excavation and off-Site disposal of an
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44
specific levels from around the buildings on-Site. The chemical
levels are described below, but, in general after completion.of the
remedial action the concentrations in soils will attain, for each
contaminant, a Site-specific risk of 1x10~ carcinogenic risk or a
hazard index ratio of 1.0 or less for exposure due to ingestion,
dermal contact or inhalation, as calculated in the RA or
background, whichever is higher.
Excavated portions of the Site will be backfilled with clean soil.
The installation of .vertical barrier walls around building
foundations that will be in direct contact with clean backfilled
soil will protect the clean backfilled soils from potential.
recontamination, assuming that a continuing source of contamination
exists beneath these buildings. Institutional controls limiting
digging and restricting installation of water wells around the Site
may be implemented.
A ground water monitoring program will be established to monitor
the migration of contamination from the site in the direction of
the public water supply.
The estimated capital costs are $1,500,000 and the net present
worth is $1,800,000. Estimated Operation and Maintenance costs are
$34,400 annually.
Rationale for Selection
Alternative 5, will provide a permanent, long-term solution which
is protective of. human health and the environment, is fully
implementable and is cost effective. The contaminated soils
removed from the Site will be placed in a secure landfill, where
the potential for migration of the contaminants into the air is
significantly reduced and the ability for direct contact with
contaminants is reduced to acceptable levels. The other
alternatives were not protective or not fully implementable and/or
were not as effective over the long-term.
Alternatives 1, 2, 3, 4, 6, and 7 can be implemented relatively
easily and quickly. However, these alternatives leave at least a
portion of the contaminated soil untreated and in-place and
therefore do not fully provide for long-term effectiveness.
Al ternati ves 1 and 2 do nothing to prevent exposure to soil
contamination or mobility of the contaminants. Alternatives 3 and
4 offer protection by covering the contamination with soil or
cement, but covers require perpetual maintenance to maintain their
integrity. Inadequate maintenance and industrial and residential
activities over such a cap at the Site could compromise its
integrity. This would possibly result in cap reconstruction or
evaluation of another option sometime in the future. This would be
disruptive to local residents and businesses, create another
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45
Alternatives 6. and 7 eliminate some contaminated soils by
excavation. However, the same problems as indicated above would be
encountered for the capped portions of the contaminated soils.
Alternative 8 and 9 would be protective of human health and the
environment because they reduce the potential for inhalation of
contaminated soils, assuming soils are. determined to require
treatment. However, these alternatives would be extremely
difficult to implement because the work would require large support
areas to operate on-site equipment. In addition, for Alternative
9, the long-term effectiveness and permanence of a remedy involving
soils treated in-situ has not been-determined.
Alternative 10 would provide a permanent, long-term solution which
is protective of human health and the environment. However, use of
groundwater protection standards (Type B) was determined to not be
appropriate for the Site for two primary reasons: 1) it is not
necessary to remediate soil to Type B groundwater protection
standards because no groundwater ingestion exposure pathway exists
and because there is little or no potential for the bedrock aquifer
to be impacted by Site-specific contamination and 2) cleaning the
Site up to Type B ground water protection levels would require
remediating a large volume of soils that pose a relatively limited
health hazard. The buildings overlying contaminated soil act as a
cap eliminating potential exposure routes to contaminated soil.
The lack of exposure routes to soil contaminants under buildings is
a Site-specific characteristic that makes the Site-specific
approach appropriate in this case. In addition, Alternative 10
would be difficult to implement because it requires relocation of
ten residences, three businesses and complete demolition of the
buildings at a cost considerably more than Alternative 5 ($7.7
million for Alternative 10 versus $1.8 million for Alternative 5).
Performance Standards
The estimated area requiring remediation is shaded in Figure 6.
The areas targeted for remediation contain Site related
contamination in soils significantly above background and, based on
the RA, are the areas contributing to unacceptable health risks at
the Site.
Contaminated soils will be excavated vertically down to a maximum
depth of 10 feet bgs, or to analyte specific levels (cleanup
levels), whichever is encountered first based upon the average soil
background level plus three times the standard deviation. Ten feet
was determined in the RA to be the maximum exposure depth and is
determined to be a reasonable exposure assumption. Therefore,
contamination below 10 feet, as described in Section V of this ROD,
will not be excavated. Horizontally, excavation limits will be
based on analyte specific levels. The following are the
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N 0
I I Shed I
I Gar. I
I" "I- ~
Cr 17.4
I Gar. I EJ
IAs 2.9\-
Cr 11.3 527
-IAs 1.31
Cr 13.8
Adams
Plating
-IAs 2.31
Cr 10.7
- I j CD
CD 516 e
e -
en
CiS ~
Q) ca
fiJ E
.... Q)
~ -I~ 2~:gl en
o
.a:
Warehouse
511
-
IAs 2.11 IAs 3.7\ IAs 6.6\
Cr 13.5 Cr 146 Cr 20.9
503
500
IAs 3.81
Cr 21.0
-
lAB 1.61
Cr 17.9
Genesse Street
o
Figure 6 SOil Concentrations of Arsenic and Chromium
Outside the Remediation Area
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47
ANALYTE
CLEANUP STANDARD
26.1 mg/kg
Chromium (total)
Arsenic
6.7 mg/kg
These two analytes were chosen for two primary reasons: 1) based on
the RI, they accurately represent the distribution of contamination
at the Site, and 2) based on the RA, the majority of risk is driven
b~ these two analytes. If chromium and arsenic cleanup levels are
met through the remedial action described in Alternative 5, Site
specific risk will be eliminated. .
The cleanup levels for chromium and arsenic were based on the
average soil background levels (chromium - 11.4 mg/kg, arsenic -
1.9 mg/kg) plus three times the standard deviation (chromium - 4.9,
arsenic - 1.6), as presented in the RI. Background averages were
limited to four samples. Therefore, additional background samples
may be required during design in order to establish a more
meaningful statistical average. In addition, based on data from
the RI, Figure 6 shows concentrations of chromium and arsenic in
subsurface soil samples collected outside the target cleanup area.
Anomalous areas above the analyte specific cleanup levels, such as
shown on the south edge of the warehouse, will require confirmatory
sampling -for arsenic and chromium at a minimum during design.
Results of the confirmatory sampling will be used to evaluate and
determine the necessity for excavating these areas and
verify/establish excavation depths. Confirmatory soil sampling
will also include qualitative analyses for hexavalent chromium to
provide assurance that soils posing an unacceptable risk due to
chromium are excavated and removed.
All old clay tiles, the PVC collection system, the 2-1000 gallon
underground storage tanks connected to the PVC collection system
and concrete sumps in the target remediation area will be excavated
and disposed of along with the contaminated soil. Also, the garage
at 516 Grace Street may need to be demolished so that the soil
beneath it can be excavated. Demolition and reconstruction of the
garage may be more cost effective than excavating around the garage
and stabilizing its foundation. A temporary fence will be
constructed and will be in place during the time remediation
activities are conducted and will be taken down upon completion of
these activities.
Soils assumed to be contaminated under buildings located in the
area affected will not be removed because the contaminated soils
under the buildings at the Site are effectively isolated from the
environment and human contact by the buildings' foundations and
will be isolated from clean backfill by vertical barrier walls.
However, if any of the buildings within the target area of
contamination shown in Figure 6 are abandoned or demolished in the
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48
for remediation of contaminated soils under the building(s) would
be evaluated by U.S. EPA during a five year review of the Site.
Five year reviews will also include an evaluation of the
effectiveness of deed restrictions, if needed, with an update on
the business status of the Adams Plating Company, if still in
operation.
Contaminated materials from the Site will be disposed of in a solid
waste (Subtitle D) landfill. However, soils requiring remediation
shall be tested using the TCLP for metals. Soils which are
determined to be RCRA, or Michigan Act 64, characteristic hazardous
wastes are subj ect to RCRA and/or Michigan Act 64 and will be
treated before land disposal. If treatment is necessary, the soils
will be treated using fixation and stabilization methods to a level
below LDR requirements such that the material no longer exhibits
the characteristic which caused it to be a RCRA, or Michigan Act
64, hazardous waste. Characteristic hazardous waste that has been
treated to meet the treatment standard is no longer considered
hazardous after the characteristic is eliminated. The waste can
therefore be disposed of in a solid waste (Subtitle D) landfill.
Water collected during the excavation procedure will be
containerized, tested, and treated off-Site before disposal. The
volume of-water estimated to be encountered during excavation is
about 10,000 gallons.
Excavated areas will be backfilled with clean soil and vertical
barrier walls will be installed at least along the west and south
walls of the APC building and along the west and north walls of the
warehouse. Backfilled material along with vertical barrier (s) will
at least be capable of reducing the possibility of recontamination
of the fill area. In addition, backfill material should limit
downward migration of precipitation in order to reduce the
potential for mobilization of residual contaminants that may be
left below excavation depths. The type and hydraulic conductivity
of backfill material and vertical barrier(s) will be established
during design.
Ground water contamination was detected at this Site in exceedance
of Michigan's Type B cleanup criteria. However, since the ground
water was not found in useable quantities or quality and a
connection to a drinking water aquifer was not established at the
Site, it is not appropriate to remediate the ground water. To
assess potential con~aminant migration in what ground water is
present at the Site, a ground water monitoring program will be
established to monitor the migration of contamination from the Site
in the direction of the public water supply wells. If U.S. EPA
determines that contamination from the Site poses an unacceptable
threat to the bedrock aquifer, or that the remedy is no longer
protective of human health and the environment, additional
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49
for a period of 30 years, unless the trend in contaminant
concentrations indicates that this specified length of time is not
required.
Material handling equipment will be used to diminish air dispersal
of particulate materials and volatilization of organics when
excavating contaminated soils. Dust suppressants and air
monitoring may also be used during excavation.
x.
STATUTORY DETERHINATIONS
The selected remedy must satisfy the requirements of Section 121
(a-e) of CERCLA, as amended by SARA, to:
e.
Protect human health and the environment;
Comply with ARARs;
Be cost effective;
Use permanent solutions and alternative treatment or
resource recovery technologies to the maximum extent
practicable; and
Satisfy the preference for treatment as a principal
element or provide an explanation as to why this
-preference is not satisfied.
a.
b.
c.
d.
The implementation of Alternative 5 at the Adams Plating Company
Site satisfies the requirements of CERCLA, as amended by SARA, as
detailed below:
a.
Protection of Human Health and the Environment
This selected remedy provides for the protection of human
health and the environment.
Implementation of the selected remedial alternative will
reduce and control potential risks to human health and the
environment posed by exposure to site contaminants by
excavating waste materials, soils above human health-based
criteria and containing this material in an off-site landfill.
The risk will be reduced to a risk level less than ~x20~ for
carcinogens and a Hazard Index for non-carcinogens of one.
b.
Camcliance with ARARs
The selected remedy will comply with all Federal and/or State,
where more stringent, ARARs. The following ARARs will be
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50
1.
Chemical-sDecific ARARs
Chemical-specific ARARs regulate the release to the
environment of specific substances having certain chemical
characteristics. Chemical-specific ARARs typically determine
the extent of clean-up at a site. By removal of the source
and continued monitoring, u.s. EPA believes that all chemical-
specific Federal and State ARARs will be met.
Federal ARARs
'Resource Conservation and Recovery Act Land Disposal
Restrictions (LDR) regulations (40 CPR 268) and waste
characterization requirements (40 CPR 261) are applicable
,requirements for the contaminated soils if these are'
determined to be RCRA characteristic hazardous wastes. The
Site contaminated soils have not presently been classified as
RCRA listed or characteristic hazardous wastes. However, a
portion of the contaminated soils at the Site have the
potential to be characteristic for metals. The classification
of RCRA listed and characteristic hazardous waste as related
to the Site is discussed below.
No conclusive proof to support the classification of
contaminated soils at the Site as RCRA listed hazardous waste
exists. While the APC is a small quantity generator of RCRA-
listed waste (wastewater treatment sludges from electroplating'
operations, waste code F006), no information is available
concerning how these wastes were managed or suggesting the
F006 waste is the source of the contamination at the Site.
The RI defines the APC's wastewater as rinse water from the
electroplating operations that was discharged into a
preexisting drain tile system that apparently leaked. Despite
its high chromium concentration, rinse water from
electroplating operations is not a listed waste. It is
possible other electroplating wastes such as plating baths
(F007) and residual sludges fram plating baths (FOOS) may have
been improperly disposed of at the Site, but no information is
available concerning the management of these types of wastes
and nothing suggests that RCRA listed wastes were released
along with the rinse water.
The RI also states that acetone, methylene chloride, carbon
tetrachloride and 1,1,1-TCA were used as degreasing solvents
at this Site although no used solvents are listed on the RCRA
hazardous waste notification form. The presence of these
constituents is not conclusive proof that listed solvents were
improperly disposed of at the Site. It is not anticipated
that the limits for volatile organic characteristic waste will
be exceeded because most of the volatile constituents in the
solvents used at the Site are not identified characteristic
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,
51
Neither the EP Toxicity or the Toxicity Characteristic
Leaching Procedure (TCLP) analysis were performed on samples
of Site soils. Because of this, it is uncertain whether
contaminated soils at the Site can be classified as RCRA
characteristic hazardous waste. The contaminated soils in the
tile drain system at the Site may contain chromium at
concentrations high enough to be classified as hazardous waste
based on the RCRA characteristic of toxicity for metals.
Therefore, soils shall be tested under the TCLP for metals
prior to all intrusive remediation approaches. Soils which
are characteristic hazardous wastes are subject to RCRA ARARs
and will be treated before land disposal. For most
characteristic waste with concentration-based treatnient levels
(such as the wastes at the APC site), the LDR treatment
standards are set at the characteristic level that defines the
waste as hazardous. For example, the TCLP treatment level for
chromium is 5.0 milligram per liter (mg/L). Chromium-
contaminated soils removed from the ground must be treated to
the level at which the TCLP analysis is less than 5.0 mg/L
before they can be land disposed. Characteristic hazardous
waste that has been treated to meet the treatment standards is
no longer considered hazardous after the characteristic is
eliminated. The waste can therefore be disposed of in a solid
waste (Subtitle D) landfill. . 0
Soils at the Site are not likely to be characteristic for
VOCs. In addition to acetone; methylene chloride; and 1,1.,1-
TCA; other VOCs detected in the subsurface soils at the Site
include up to 1,200 ~g/kg of ethylbenzene; up to 2,520 ~g/kg
of bromomethane; and 4,000 ~g/kg or more of 1,1-DCA, methyl
ethyl ketone (MEK) and chloromethane. Of these VOCs, only MEK
is a characteristic parameter, and the highest concentration
of MEK detected in on-Site soils (4,200 ~g/kg) is not likely
to exceed the regulatory threshold. If the soils are not
characteristic wastes because of the VOCs, then treatment of
Site contaminated soils for VOCs will not be necessary prior
to disposal iri a solid waste (Subtitle D) landfill. If so,
then they will be needed to be treated first to eliminate the
characteristic which made them a RCRA hazardous waste.
State ARARs
Michigan Act 307 - - The State of Michigan has identified the
Michigan Enviromnental Response Act (referred to as "MERA",
"the ACT" or "Act 307") and its implementing rules as ARARs
for this Site. u.s. EPA finds that only Rules 705 (2) and (3),
707 715, 717 (2), 719 (1) and 723 qualify as ARARs in
compliance with Section 121 (d) (2) of CERCLA. These rules
provide for the selection of a remedy which attains a degree
of cleanup which conforms to one or more of three levels of
cleanup - Type A, B or C. A Type A cleanup generally achieves
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52
B level meets specific cleanup levels in all media (R299.5709-
57~5 and 5723) and a Type C cleanup is based on a site
specific risk assessment [R299.57~7 (2)] and 57~9 (~)].
u.s. EPA's selected remedy will attain soil cleanup standards
adopted on a Site-specific basis for this Site in compliance
with Act 307 and its implementing rules in accordance with the
Type C cleanup requirements[R299.57~7(2) and 5719(~)]. It
should be noted that the Site-specific cleanup standards meet
the Type A requirements (background) for particular
contaminants.
u.S. EPA does not consider the other provisions of Act 307 and
its implementing rules identified by the State as ARARs
because they are either procedural, not more stringent or do
not establish cleanup standards. Additionally, u. S. EPA
believes that even if certain of these provisions were
considered ARARs [e.g. the considerations listed in Section'
299. 57~ 7 (3)], the remedial actions and cleanup standards
selected for this Site are in compliance with these State-
. identified ARARs since they have been selected in accordance
with CERCLA and the NCP.
Michigan Air Pollution Act 348 The selected remedy
involves excavation and construction activities which may
release contaminants or particulate into the air. This 'act is
relevant and appropriate. This act is also referenced in Act
307 under a Type B (R299 .57~5) for air quality. Measures will
be taken to ensure that these requirements are complied with
during the excavation activities.
2.
Location-Sgecific ARARs
Location-specific ARARs are those requirements that relate to
the geographical position of a site. For example, federal and
state ARARs exist for sites where remedial activities would
impact wetlands, floodplains, critical habitats, wilderness
areas, fault zones, or areas of historic or significant
cul tural artifacts. The nearest wetland is located about 1.5
miles southwest of the Site. Therefore, anticipated
remediation activities at the Site will not impact this
wetland and potential ARARs related to wetlands (Executive
Order ~~990 - Protection of Wetlands, and Section 404 of the
Clean Water Act) are not applicable or relevant and
appropriate. Potential ARARs relating to the impact or
management of floodplains (Executive Order 11988 - Floodplain
Management, 33 Code of Federal Regulations (CPR) 209
Navigation and Navigable Waters; and Sections ~008 and 4004 of
RCRA - RCRA Criteria for.. Classification of Solid Waste
Disposal Facilities) are not ARARs as the Site is not located
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54
Adams Plating Company Site. Of the alternatives that are
protective of human health and the environment and comply with
ARARs, U. S . EPA has determined that the selected remedy
provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence, reduction of toxicity, mobility
or volume through treatment, short-term effectiveness,
implementability, cost and State and community acceptance.
Therefore, the selected remedy represents the maximum extent
to which permanent solutions and treatment can be practicably
used. The .cont~nation in the soils can reliably be
controlled over t~e at a secure landfill. Treatment may be
required if soils are found to exhibit RCRA, or Michigan Act
64, hazardous waste characteristic properties.
e.
Preference for Treatment as a Principal Element
Treatment options were evaluated for contaminated soils and
were found to not be cost-effective or easily implementable
based on Site-specific factors. Containment of treated
contaminated materials, as well as contaminated materials not
requiring treatment, in a secure landfill is considered a safe
and reliable option when coupled with institutional controls
and -monitoring, particularly when the cost of other
alternatives are factored in. Excavated materials will be
treated if they are determined to be RCRA, or Michigan Act 64,
characteristic hazardous wastes prior to disposal in the
landfill. If the excavated material is not found to require
treatment, this alternative will not meet the preference for
treatment as a principal element.
XI.
DOC'DKBNTA'.rION OF SIGNIFICANT CHANGES
The Proposed Plan for the Adams Plating Site was released for
public comment in August 1993. The Proposed Plan identified
Alternative 5, soil excavation and off-site disposal, as the
recommended alternative. U..S. EPA has reviewed all written
and verbal comments submitted during the public comment
period. Upon review of these comments, it was determined that
no significant changes to the remedy, as it was originally
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