PB94-964138
EPA/ROD/R05-94/265
April 1995
EPA Superfund
Record of Decision:
Auto Ion Chemicals, Inc.
(O.U. 2), Kalamazoo, MI
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DECLAR-\TION ,-,. ~/ if
SELECTED REMEDIAL ALTERNATIVE
FOR TIlE
AUTO ION SCPERFUND SITE
OPERABLE UNIT 2
KALAMAZOO. ~nCHIGAN
StatC::l11c::nt of Basis and Purpose
This decision document presents the selected remedial action for the Auto Ion site (Operable
Unit 2). Kalamazoo, Michigan which was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended
by the Superfund Amendments and Reauthorization Act (SARA) of L 986, and, to the extent
practicable. the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based on the administrative record for this site.
Assessment of the Site
U,S. EPA has detennined that conditions at the Auto Ion site pose no current or potential
unacceptable risk to human health or the environment. While the Auto Ion site does exhibit
elevated levels of heavy metals and some organics, calculations of potential future risk
indicate that the contamination will not likely pose an unacceptable risk to human health or
the environment. Accordingly, no active remediation for the groundwater operable unit is
necessary to ensure protection of human health and the environment. U.S. EPA will
however. establish Alternate Concentration Limits (ACLs) for groundwater, monitor
groundwater to ~nsure t:.at the ACLs are not exceeded, and use instititutional controls to help
assure that groundwater beneath the site does not pose a risk to human health or the
environment.
Description of the Selected Remedy
The purpose of this remedy is to establish Alternate Concentration Limits (ACLs) for
groundwater and institute a groundwater monitoring program that will ensure that
groundwater does not pose a risk to human health or 'the environment. It should be noted
that the soil cleanup conducted in 1993 will have a significant impact on groundwater quality
due to the fact it removed the vast majority of the source to further groundwater '
contam ination.
The major components of the selected remedy include:
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Establishment of Alternate Concentration Limits (ACLs);
Monitorin!! of ground water to ensure ACLs are not being exceeded.
Devdopment of a Remedial Action Plan for groundwater.
Statl/torv Detenn inations
The selei,:ted remedy is protective of human health and the environment and complies with
Section I ~ \(d)(2)(B)( ii) of CERCLA for the establishment of ACLs for groundwater and is cost
effective, This remedy does not satisfy the statutory preference for remedies that reduce the
toxi(ity. mobility. or volume through treatment as a principal element because treatment was not
found to be practicable.
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 because this remedy will result in hazardous substances remaining on site above
health-based levels.
u. S. EP A has determined that its response at this site is complete. Therefore, the site now
qualifies for inclusion on the Construction Completion List.
State Concurrence
The State of Michigan does not concur with the selected remedy.
Concurrence is attached to this ROD.
The Letter of Non-
Valdas V. Adamku
Regional Administ tor
9/2~/'14
Date
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TABLE OF CONTENTS
Page
,-\,
Sik L\I,:a{lllll
8, Site History
C, Highlights of Community Participation
4
D, Summary of Current Site Condition
4
E, Summary of Site Risks
6
F. Scope of the Remedy
9
G. Description of Alternatives
9
H. Summary of Comparative Analysis of Alternatives
11
(, The Selected Remedy
14
J. Statutory Detenninations
15
K. SUlnmary
18
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. '
SlJMMARY OF REMEDIAL ALTERNATIVE SELECTION
A, SITE LOCATION AND DESCRIPTION
The: Auto.lon site: is located at 7.+ Mills Street in a commercial/industrial district of northeast
Kalamazoo, The site covers approximately 1.5 acres and is located along the north bank of
the Kalamazoo River.
B, SITE HISTORY
The City of Kalamazoo operated a coal burning electrical generating station on the site
between 191.+ and 1956. The Auto Ion Chemical Company purchased the property in 1964
and operated a waste treatment facility for electroplating wastes. Waste treatment operations
included cyanide destruction and precipitation of heavy metals with the disposal of heavy
metal sludges in an on-site lagoon. During these operations. poor waste handling practices
resulted in multiple spills onto the surface soil at the site as well as illegal discharges to the
Kalamazoo River and city sewers. Due to the poor waste handling practices, the State of
Michigan refused to renew Auto Ion's license to operate in 1973. The facility was then
abandoned by the Auto Ion Co.
In 1982. U.S. EPA pro~()sed the Auto Ion site for inclusion on the National Priorities List
(NPL). and in 1983. the Auto Ion site was officially placed on the NPL and designated a
Superfund site.
In 1985. U.S. EPA entered into an agreement with the Potentially Responsible Parties
(PRPs) for the Auto Ion site to conduct a removal action at the abandoned facility. The
removal action consisted of containerizing and off-site disposing of hazardous materials (Le.,
plating wastes) leti at the site. In 1986, the building was razed by the City of Kalamazoo.
Pursuant to a June 18, 1986, Administrative Order by Consent between U.S. EPA and a
group of 23 PRPs, a Remedial Investigation/Feasibility Study (RI/FS) was conducted by the
PRPs in 1987 and placed in the Administrative Record on August 7, 1989. The RI included
the collection of soil, sediment, groundwater and surface water samples from the site and the
adjacent Kalamazoo River. The RI Report, released in December of 1988, desc'ribes the
nature and extent of organic and inorganic contamination found at the Auto Ion site.
Following issuance of the RI Report, U.S. EPA determined that the most prudent way to
address contamination at this site was to fIrst remove the soil in the unsaturated zone because
it was acting as a source of further groundwater contamination and then address the
groundwater contamination as a separate operable unit.
FIRST OPERABLE UNIT RECORD OF DECISION:
The First Operable Unit Record of Decision (ROD) of excavation and off-site disposal of
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~fichigan concurred with this remedy.
Tl1i~ illitial \}perable unit addressed the source of further groundwater contamination. The
rell1ed: ~eb:ted addressed the principal threats at the site by removing and off-site disposing
lit all ~l)ils (ontalllinated above site-specific cleanup standards located in the unsaturated
!lllle, ,-\""(llrding to the ROD. all excavated soils were (0 be disposed of at a Resource
C\lllseT\atil)1l and Reco\ery Act (RCRA) landfill and where appropriate. the soil was to be
stabilized before land disposal. Areas of excavation on-site were to be backfilled with clean
,>oils,
The FS Repon for Operable Unit I evaluated several alternatives which would appropriately
address the risks posed by the contaminated soil. Six alternatives were developed and
e\ aluated in detail: I) no action. 2) stabilization/capping, 3) vadose zone excavation/disposal,
~) selected vadose zone excavation/disposal, 5) vadose zone excavation/stabilization/disposal.
6) selected \adose zone excavation/stabilization/disposal. The six alternatives were evaluated
against the nine criteria as detailed in Section H of this ROD. Based on the consideration of
the requirements of CERCLA, the detailed analysis of alternatives in the FS Report, and
public comments. U.S. EPA, with the concurrance of MDNR, detennined that Alternative 6:
selected vadose zone excavation/stabilization/disposal was the most appropriate remedy for
the tirst operable unit at the Auto Ion site. U.S. EPA's approval of the FS Report for the
first operable unit satisfied the requirement of completing the RI/FS for this operable unit.
FIRST OPERABLE UNIT REMEDIAL ACTION:
Following issuance of the First Operable Unit ROD, U.S. EPA and 42 PRPs entered into a
Consent Decree signed May 15, 1990, to conduct a Remedial Design and Remedial Action
(RA.'RD) for the First Operable Unit. The design report was completed by the PRPs and
was amended and approved by U.S. EPA on March 16, 1993.
On-site remedial activities began on April 19, 1993. Soil was excavated in the vadose zone
that was contaminated with organics and inorganics above the site-specific cleanup standards
calculated for the Auto Ion site. The site-specific cleanup standards were established at a
carcinogenic risk level of 10.6 or the average background level, which ever was higher. All
soil contaminated with RCRA designated FOO6 metals (i.e., electroplating waste) were
disposed of at Envirosafe Services of Ohio, Inc., a RCRA subtitle C facility in Oregon,
Ohio. All other contaminated soil was disposed of at either Forest Lawn Landfill, in Three
Oaks, Michigan or, the Browning-Ferris Industries C & C Landfill in Marshall, Michigan,
both are RCRA subtitle D facilities. Excavation and off-site disposal of the fonner Auto Ion
basement floor and the demolition debris inside the former basement was conducted. A total
of 11,850 tons of non-hazardous soiVdebris were removed from the site and 12,393 tons of
hazardous (RCRA-FOO6) soil/debris were removed for a combined total of 23,243 tons. A
silty/clay and sand soil mixture was used to backfill all excavation areas on-site and a layer
of topsoil and seed were then applied. A final inspection was conducted by U.S. EPA, U.S.
Army Corps of Engineers, MDNR, and the PRPs' consultant on November 5, 1993. U.S.
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o
EPA appro,,~d the PRPs' tinal RA Report for operable unit I on August 3. 1994. U.S. EPA
approval of this document satisfied the requirements of completing the RD/RA for the first
uperable unit.
DE.\IU;-';STRATION OF QAiQC FROM THE CLEANUP ACTIVITIES (OU 1):
Thc rcmedial a(tiun (onducted for the tirst operable unit complied with all U.S. EPA quality
assuran(e and quality control (QA/QC) procedures and protocol. Only U.S. EPA analytical
methods were used. The QA/QC program utilized throughout the remediation activities for
the first operable unit was complied with adequately. This program enabled U.S. EPA to
lktennine that all analytical results are accurate enough to assure satisfactory execution of the
reilledial action consistent with the first operable unit ROD.
MONITORING RESULTS FOR OPERABLE UNIT 1:
During all stages of the first operable unit remedial action, the PRPs' consultant, with
oversight by U.S. EPA. conducted confinnatory sampling to ensure that the remedial action
objectives were met. The results showed that the cleanup levels were achieved.
Documentation of the complete results and accuracy of the confmnatory sampling program is
contained in the Auto Ion Operable Unit I Remedial Action Repon.
SUMMARY OF OPERATION AND MAINTENANCE FOR OPERABLE UNIT 1:
The site remains fenced and "no trespassing" signs have been posted on the perimter of the
site. Final grading and seeding of the site was completed in November 1993. Site
inspections will be conducted by the PRPs every 60 days, or more frequently, if needed to
ensure the integrity of the fencing, signage and the vegetative cover.
SECOND OPERABLE UNIT:
The RI Repon issued in December 1988, describes the results of the RI conducted.in 1987
which covered both the first and second operable units. A Sediment Toxicity Evaluation was
(onducted by the PRPs in October 1992 to detennine what, if any, impact to biota. was .
occuring in the Kalamazoo River as a result of groundwater discharges from the Auto Ion
site to the river. The FS Repon for the second operable unit was completed by the PRPs
and was modified and approved by U.S. EPA on March 4, 1994. The FS Repon evaluated
several alternatives which would appropriately address the groundwater contamination
situtation at Auto Ion. Four alternatives were developed and evaluated in detail: 1) no
action, 2) natural attenuation/institutional controls, 3) groundwater containment/treatment, 4)
groundwater extraction/treatment. The four alternatives were evaluated against the nine .
criteria as detailed in Section H of this ROD. Based on the requirements of CERCLA, the
detailed analysis of alternatives in the FS Repon, and public comments, U.S. EPA has
detennined that Alternative 2: natural attenuation/institutional controls is the most appropriate
remedy for the second operable unit at the Auto Ion site. On August 4, 1994, U.S. EPA
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modified and approved the PRPs' phase I work plan for the installation of monitoring wells.
l'. S. EPA' s approval of this document satisfied the requirement of completing the RIfFS for
[his operabk unit. Work began on aquifer characterization for well installation on August
I:'. lQ4~
Sl'~I~IARY OF OPER~TION AND MAINTENACE FOR OPERABLE UNIT 2:
Uperation and ~laintenance for groundwater at this site will involve routine monitoring to
ensure [hat k"els remain below established ACLs. Institutional controls will also be
established at the site to further assure that groundwater beneath the Auto Ion site is not used
as a sour(e for drinking water in the future.
SlT~IMARY OF FIVE-YEAR REVIEW STATUS FOR OPERABLE UNIT 2:
As part of this second operable unit ROD, a Five-year Review of the site through routine
groundwater monitoring, as deemed prudent by U.S. EPA, in consultation with MDNR, is
required.
The reason for including the Five-year Review in this ROD is that groundwater contaminants
will remain at levels in excess of some Federal and State regulatory limits.
PROTECTIVENESS:
With the inclusion of the requirements of this ROD, all the completion requirements for this
site will be met as specified in OSWER Directive 9320.2-3A. Confmnatory sampling of soil
has verified that the ROD cleanup objectives for soil have been achieved. Establishment of
ACLs. institutional comrols, and routine groundwater monitoring, will meet the objectives of
the ROD for groundwater by providing assurance that groundwater beneath the site does not
pose any threats to human health and the environment. .
C. COMMUNITY PARTICIPATION
The Responsiveness Summary in Section L discusses the involvement of the community
during the RIfFS and remedy selection process and shows that the public participation'
requirements of CERCLA Sections I 13(k)(2)(i-v) and 117 of CERCLA have been met at this
site. The decision is based on the Administrative Record.
D. SUMMARY OF CURRENT SITE CONDITIONS
The Auto Ion site is currently a vacant fenced parcel of land on the north bank of the
Kalamazoo River (see Figure A). Topography is relatively flat and vegetation consists of a
grass cover and a row of mature trees along the river's edge. Most of the site lies within the
IOO-year floodplain for the Kalamazoo River.
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Th~ nearest residences are located approximately 500 feet north of the site. There are
approximately 2,300 people living within a li2-mile radius of the site. The drinking water
~l1pply for all residents in Kalamazoo is provided through a municipal system which utilizes
grl1l1l1dwater wells located outside of the area of influence of the Auto Ion site. There are
~e\ eral busin~sses located within a 500 foot radius of the site. including the Conrail facility
\ 111 AutO Ion' s eastern border and the fOnTIer Production Painting Company on the site' s
\~ e~tc:m borda. Both of these facilities are listed on Michigan's Act 307 list of sites of
el1\ iron mental contamination. The stretch of river in front of the AutO Ion site is also a
ponion of the Kalamazoo River! Allied Paper Superfund site.
GEOLOGY:
Si{~ g~ology consists primarily of an unconsolidated glacial deposit of sand with varying
amounts of gravel (see Figure B). This unconsolidated deposit is approximately 110 feet
deep and overlies a shale bedrock. There are also two layers of low penneability deposits
within the unconsolidated deposit. One is a 1-4 foot thick black organic deposit containing
varying amounts of silt, clay and peat, and the other is a 5-7 foot thick layer of gray clay
pres~nt at about 16 to 18 feet below grade in the northwest quarter of the site. Groundwater
beneath the site typically flows laterally in a southward direction toward and into the
Kalamazoo River. The water table is generally found at approximately 10 feet below grade.
Under high surface water conditions on the Kalamazoo River, groundwater flow can reverse
itself and tlow northward under the site away from the river. This condition is common
along the edges of rivers, but usually is a temporary seasonal condition that does not extend
very far away from the river's edge. Groundwater flow velocity is relatively slow,
averaging approximately 3 feet per month. Groundwater is the source of drinking water for
the City of Kalamazoo. The nearest active well field is located approximately 1.5 miles
north/northeast of the Auto Ion site and is in the opposite direction of typical groundwater
tlow.
HYDROLOGY:
The Kalamazoo River, in the area of the Auto Ion site, is approximately 5 feet deep and 110
feet wide. The average flow rate is approximately 850 cubic feet per second. At this rate, it
takes approximately 3 to 4 minutes for the river to traverse the 250 foot frontage of the Auto
(on site. The Kalamazoo River is a gaining stream and it flows in a northwesterly d~ction
after passing the site and empties into Lake Michigan approximately 80 miles downstream at
Saugatuck, Michigan. The Kalamazoo River is used for recreational purposes (Le., fishing,
canoeing). .
ENVIRONMENTAL SAMPUNG:
Groundwater samples were collected from six on-site monitoring wells, and one off-site
background well, on three different dates all before the soil cleanup was conducted in 1993.
The first samples were collected in November of 1987, the second in March of 1988 and the
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last in December of 1990. Site related inorganics and organics were detected in these weUs.
A number of these contaminants exceed ~-laximum Contaminant Levels (MCLs) and/or
~[ichigan Act 307 Type-C levels. The majority of site-related contaminant levels decreased
ht:(\\ t:eri eal'h sampling event. This contaminated groundwater discharges into the Kalamazoo
Ri\ er. The rate of discharge is relatively slow due to the low water table gradient. On
.I\~rJgt:. 5.U~ gallons of groundwater discharge into the river per each complete passage of
the ri\ er. The a\erage dilut~on ratio of surface water to groundwater is approximately
70.UUO to I.
Sediment samples from the river were collected and analyzed on two separate occasions.
The first set of samples. collected during the RI. were collected at twenty-two different
IUl'atiuns upstream. adjacent to the site. l/2 mile downstream and I mile downstream of the
site. Analysis of these samples indicated that some site-related organics and inorganics were
detected at levels above upstream levels. Sediment samples were also coUected from
locations upstream. adjacent to and immediately downstream of the Auto Ion site in October
of 1992 during the sediment toxicity evaluation. Some site-related organics and inorganics
were detected in excess of upstream samples. Surface water samples from the Kalamazoo
River were coUected on three separate occasions. Once in October 1987, again in November
1991 and then during the sediment toxicity evaluation in October 1992. Several site-related
inorganics were detected at levels in samples downstream of the site in excess of levels
upstream during the 1987 sampling event. The 1991 samples did not show any increase in
contaminant levels between upstream and downstream samples except for silver which was
detected near the detection limit. Some site-related organics and inorganics were detected in
excess of upstream samples during the 1992 sampling event.
E. SUMMARY OF SITE RISKS - (See Glossary for definitions of tenns used in this
sectiun)
Based on analytical data collected during the RI, a baseline risk assessment was perfonned
using site related contaminants. The baseline risk assessment assumes no corrective action
will take place and that no site-use restrictions or institutional controls such as ground water
use restrictions or construction restrictions will be imposed. The risk assessment detennines
actual or potential carcinogenic risks and/or toxic effects the chemical contaminants at the
site pose under current and future land use assumptions using a four step process. The four
step process includes: contaminant identification, health effects assessment, exposure
assessment and risk assessment.
1. Contaminant Identification
The levels of contamination found in groundwater at the site can be found in Section 3.4 of
the RI or Section 1.2.4 of the FS. Indicator parameters or chemicals of potential concern
were selected based on their toxicities, level of concentration and wide spread occurrence.
The chemicals of potential concern are listed in Table 1.
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o
T ABLE I
CHE.\lICALS OF CONCERN
AUTO ION SITE
I:'-:ORGA!'.lCS
ORGANICS
Arsc::nic
:'-:id,c::1
Barium
Copper
~ad
Cadmium
:\kn.:ury
Cyanide
Chromium III
Chromium VI
Silver
Bis( 2 -ethy Ihex y I)-phthalate
Trichloroethylene
I ,2 - Dichloroethane
Vinyl Chloride
2. Human Health Effects
The health effe,cts for the contaminants of concern may be found in Section 6.6 of the
Baseline Risk Assessment.
3. Exposu re Assessment
The baseline risk assessment examined the risk to human health from the ingestion of
groundwater. This evaluation was requested by U.S. EPA to detennine any potential risk in
the unlikely event that groundwater beneath the site were to be used as a drinking water
source. The results of this evaluation are listed below under 4a and 4b.
4. Risk Characterization (See Glossary for definition of tenns used in this section)
For each potential human receptor, site-specific contaminants from the ingestion of
groundwater route of exposure were evaluated. Both non-carcinogenic health effects and
carcinogenic risks were estimated.
a.
Non-Carcinogenic Health Risks
The hazard index for humans ingesting groundwater beneath the site over a lifetime
(i.e., 70 years) exceed the acceptable hazard index of 1.0. For potential use of the
groundwater under the site, the hazard index value is 15.
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b. Carcinogenic Health Risks
The potential excess lifetime cancer risk posed by the ingestion of contaminated
groundwater beneath the site exceeds the acceptable risk range of I X I Q4 to
I X 10°. The estimated excess cancer risk to humans ingesting groundwater from
heneath the Auto Ion site over a lifetime (i.e.. 70 years) is approximately 1.2 X 1O.j.
5. Groundwater Use Scenario:
Although the baseline risk assessment indicates that there is a potential risk to human health
as a n~~ult of drinking groundwater from beneath the Auto Ion site, it must be noted that this
s.:cnario is highly unlikely for the following reasons:
. d.
a.
The drinking water source for the City of Kalamazoo is supplied by
groundwater wells outside the influence of the Auto Ion site. In a January 24,
1994 letter. the City of Kalamazoo documented its intention to U.S. EPA to
avoid the installation of any new wells in the vicinity of the site.
b.
The County of Kalamazoo must evaluate a set of criteria before pennitting any
new wells. Included in this criteria is a review of any potential sources of
contamination that could potentially contaminate a well. In the case of the
Auto Ion site, there is documented groundwater contamination beneath the site
and there are two Michigan Act 307 sites adjacent to Auto Ion. These facts
clearly indicate that the site area is a poor candidate for the installation of new
drinking water wells.
c.
Michigan Act 399 prohibits the development of drinking water wells within the
lOO-year floodplain for any rivers of the State. Much of the Auto Ion site sits
within the lOO-year floodplain for the Kalamazoo River.
Sodium levels in the area of the Auto Ion site are well above U.S. EPA health
based criteria for drinking water. This may be a result of the use of road-salt
in the area. Even absent the facts listed above, groundwater would likely be
unfit for potable use due to these excessive sodium levels.
6. Environmental Risks
A sediment toxicity evaluation was conducted in the Kalamazoo River, proximal to the Auto
Ion site in October 1992. The purpose of this investigation was to evaluate the aquatic
sediments and its indigenous fauna for potential impact of contaminants originating from the
Auto Ion site through groundwater seepage.
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{)
Ri\'~r sediments were collected and characterized/analyzed for physical. chemical and
biological components. In addition. toxicity evaluations were carried out by employing two
a4uatic organisms. The results of this study are as foHows:
;.I,
Th~ macroinveI1ebrat~ community indigenous to the Kalamazoo River in the
area of the Auto Ion site is quite diverse. abundant and is typical of this type
of habitat.
b.
The best water quality. evaluated from the use of the Shannon-Weaver
function and the Hilsenhoff Biotic Index. is adjacent to the Auto Ion property.
c.
Sediment toxicity evaluation carried out with Hyalella and Chironomus showed
no statistically significant
(p = 0.05) effect in survfval for either species compared to the control.
However. a statistically significant (p = 0.05) effect was observed in reduced
weight for both species at one location adjacent to the site, which was partially
attributed to upriver contamination rather than groundwater effects from the
Auto Ion site alone.
The sediment toxicity results confinned the contention that the area "logically" to be
impacted by groundwater from Auto Ion did not elicit an adverse effect in either species. It
was therefore concluded from the interpretation of physical, chemical and biological data that
00 adverse effect is demonstrated from the Auto Ion site on the indigenous fauna of the
Kalamazoo River.
F. RATIONALE FOR ACTION AND SCOPE OF TIlE SELECTED REMEDY
This ROD addresses the final remedy for the Auto Ion site. The only possible threat
remaining at the site is the contaminated groundwater. The selected remedial alternative
will address the only possible remaining threat at the site. The source to funher groundwater
contamination was eliminated by the soil remediation conducted in 1993.
G. DESCRTPTION OF ALTERNATIVES
Alternative I - No Action
. Estimated Cost: $0
. Estimated Years to Attainment of Cleanup Goals (assume either Michigan Act 307 Type C
~kanup levels or EPA Maximum Contaminant Levels "MCLs"): 50 to 60 years
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This alternative involves no cleanup action for contaminated groundwater at the site. This
alr~rnariv~ would allow contaminated groundwater to naturally attenuate and improve over
rime. Th~ inclusion of the no-acrion alternative is required by CERCLA and the NCP to
gi\ c L' S. EPA a basis for comparison with other alternatives.
AI!c:l1larj\c' ~ - :\'atural Att~nuation/Institutional Controls
. Estimat~d Cost: 5565.000
. Es[ill1ar~d Y ~ars to Attainment of Cleanup Goals (assume either Michigan Act 307 Type C
(kanup levels or EPA's MCLs): 50 to 60 years
This alternative involves the continued periodic monitoring of groundwater at the site while it
is allowed to naturally attenuate. It also includes institutional controls (i.e., deed restrictions)
to help assure that groundwater at the site is not used for drinking water purposes. Alternate
Concentration Limits (ACLs). which are site specific chemical concentrations allowable in
groundwater. would be established. ACLs are established by developing baseline
groundwater quality levels for groundwater at the site and then employing a statistical
analytical method to dett:rmine what level of contamination would cause a statistically
significant impact to the Kalamazoo River. If future groundwater sampling confmns a
statistically significant increase in the concentrations of the contaminants, U.S. EPA would
then make a decision regarding the need to implement a subsequent active remediation of
groundwater (e.g.. pump and treat the groundwater).
Altcrnative 3 - Groundwater Containment via Low Flow Extraction/Metals
Treatment/Filtration/Discharge to POTW.
. Estimated Cost: 55,650,000
. Estimated Years to Attainment of Cleanup Goals (assume either Michigan Act 307 Type C
cleanup levels or EPA's MCLs): 50 to 60 years
This altern?tive is both a containment and treatment alternative which involves pumping
groundwater at a rate to depress the water table (5 to 20 gpm). This would prevent
groundwater movement off-site into the Kalamazoo River. The collected groundwater would
possibly require pre-treatment on-site to remove some of the heavy metals before it could be
discharged to the City's sewer system.
Alternative 4 - High Flow Groundwater Extraction/Metals
Treatment/Filtration/Discharge to a P01W
. Estimated Cost: $7,070,000
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J
. Estimated Y ~ars to Attainment of Cleanup Goals (assume Michigan Act 307 Type-C
(: I~anup levels or EP A' s MCLs): 50 to 60 years
Tl1i.., Jlt~mJti\'e is similar to Alt~mative 3 ~xc~pt that this alternative involves a faster
pumping rat~ to more vigorously restore the aquifer (10 to 30 gpm). This alternative would
,:aplllr~ 311 impacted groundwater on-site using a combination of extraction wells. subsurface
,Jrains. amI, or hanging walls. The collected groundwater would possibly require pre-
treatm~nt on-site to remove som~ of the heavy metals before it could be discharged to the
City's s~w~r system.
H. SillvlMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The relative perfonnance of each remedial alternative was evaluated in the FS and below
using the nine criteria set forth in the NCP at 40 C.F.R. 9300.430. An alternative providing
the "best balance" of trade-offs with respect to the nine criteria is detennined from this
evaluation.
Threshold Criteria
The following two threshold criteria, overall protection of human health and the
environment, and compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) or invoking a CERCLA waiver are criteria that must be met in order for an
alternative to be selected.
I. Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether a remedy
eliminates, reduces, or controls threats to human health and to the environment.
Due to institutional controls and state law, as well as the fact groundwater beneath the
Auto Ion site is not likely to be used as a source for drinking water, an actual risk to
human health via ingestion of groundwater does not exist. The sediment toXicity
evaluation for this site demonstrated that the discharge of contaminated groundwater
to the Kalamazoo River is not having a 1etrimental impact on aquatic life in the river.
Continued natural attenuation of groundwater remains as protective of both human
health and the environment as are the two active groundwater alternatives. Therefore,
all four alternatives' are protective of human health and the environment. However,
Alternative 1 does not provide for any monitoring of groundwater and therefore it
would not be possible to detennine if there were excessive levels of contamination
entering the river at some point in the future. Also, Alternative 1 does not provide
for institutional controls which will ensure groundwater is not used as a drinking
water source. Therefore, while this alternative is still protective, it does not provide
infonnation on the level of protectiveness over time.
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2. Complianc~ with Applicable or Relevant and Appropriate Requirements
This (riterion ~valuates whether an alternative. meets ARARs set forth in federal. or
inore stringent state. ~nvironmemal standards pertaining to the site or proposed
Jdions or invoking a CERCLA waiver.
Be(Juse the ;-";l) Action alternative does not involve conducting any remedial action at
the site. no AR~Rs analysis is necessary for Alternative 1. Alternatives 2. 3. and ~
are expected to be in compliance with ARARs. Alternative 2 does not evaluate the
same ARARs as does Alternatives 3 and ~ because the establishment of ACLs under
Section l21(d)(2 )(B)(ii) of CERCLA waives other Federal and State ARARs relating
to groundwater quality.
Primary Balancing Criteria
3. Long- Tenn Effectiveness and Pennanence
This criterion refers to expected residual risk and the ability of an alternative to
maintain reliable protection of human health and the environment over time once
clean up levels have been met.
Alternatives I and 2 will be effective in the long-tenn because risk evaluations have
detennined that continued natural attenuation of groundwater poses no risk to human
health and the environment. However, because Alternative I does not include
groundwater monitoring or institutional controls, it does not provide long-tenn
effectiveness to the same degree as Alternative 2. Alternatives 3 and 4 would also be
effective in the long-tenn because they involve a complete cessation of groundwater
discharges to the river and provide for treatment of the contaminated groundwater.
4. Reduction of Toxicity, Mobility, or Volume through Treatment
This criterion evaluates treatment technology perfonnance in the reduction of
chemical toxicity, mobility, or volume. This criterion addresses the statutory .
preference for selecting remedial actions which include, as a principal element,
treatment that pennanently and significantly reduces the volume, toxicity, or mobility
of the hazardous substances, pollutants, and contaminants.
Alternatives I and 2 do not include treatment as an element of each remedy and
therefore they do not meet this criteria. Alternatives 3 and 4 do provide treatment of
the contaminated groundwater before discharge to a P01W and therefore, both of
these alternatives do meet this criteria.
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5. Shon-Tenn Effectiveness
Shon-tenn effectiveness considers the time to reach cleanup objectives and the risks
<111 alternative may pose to site workers. the community. and the environment during
remedy implementation until deanup goals are achieved.
The estimated time to reach cleanup objectives for all alternatives is approximately 50
to 60 years. The slow desorption rate for some metals bound to clay/silt panicles
(ontrels this rate of decrease for contaminant levels in the aquifer. Use of an active
pump and treat system will remove contaminants more rapidly in the early period of
the cleanup. However, with time. the rate of contaminant reduction will decrease and
the time to reach the low cleanup levels. established by Michigan Act 307 or U.S.
EPA's MCLs, will be approximately the same as calculated for allowing groundwater
to naturally attenuate.
There are no risks to workers, the community or the environment under Alternative 1
because there would be no contact with contaminated groundwater. The only
expected contact with contaminated groundwater under Alternatives 2, 3 and 4 is for
workers who install monitoring wells, purge wells and other extraction devices and
then sample the wells. Any hazards related to this work can be addressed by
adherence to a health and safety plan. No impact to the environment is expected for
any of the alternatives.
6. Implementability
This criterion addresses the technical and administrative feasibility of implementing an
alternative, and the availability of various services and materials required for its
implementation.
All the alternatives are implementable and can be readily constructed with technology
. and materials presently available. Alternatives 3 and 4 have a disadvantage in that a
large volume of river water would likely be included in the extracted groundwater due
to the site's location next to the Kalamazoo River. This.would reduce the number of
pore volumes removed from the impacted groundwater. For every gallon of river
water extracted, one less gallon of impacted groundwater would be extracted and
treated.
7. Cost
This criterion compares the capital, O&M, and present worth costs of implementing
the alternatives at the site. Table 2 shows the Cost Summary.
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TABLE 2
COST SUMMARY
AUTO ION SITE
OPERABLE UNIT 2
Alternative ~:
Capital Costs 0 & M Costs Present Worth
SO SO SO
$210.000 S21. 700 $565.000
$635.000 $391,000 $5,650,000
$456.000 $514,000 $7,070,000
Altt:mative I:
Altcmati\ c 2:
Alternative 3:
Modifying Criteria
8. State Acceptance
The State of Michigan is not in agreement with the selection of Alternative 2 for
remediation of groundwater at the Auto Ion site and has provided U.S. EPA with a
letter of non-concurrence. Comments from MDNR are also included in the
Responsiveness Summary.
9. Community Acceptance
Comments have been submitted by the community, local government officials, and
potentially responsible parties (PRPs). Comments and responses to those comments
are described in the Responsiveness Summary.
I. THE SELECTED REMEDY
Based upon considerations of the requirements of CERCLA, the NCP and balancing of the
nine criteria, the U.S. EPA has detennined that Alternative 2 is the most appropriate remedy
for the site. The components of the selected remedy are described below.
Establishment of Alternate Concentration Limits (ACLs) - The selected remedy will
develop ACLs consistent with Resource Conservation and Recovery Act (RCRA)
guidance. The ACLs will then be used as action levels for monitoring groundwater
discharging from the site into the Kalamazoo River.
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J'
Groundwater Monitoring - To establish ACLs. baseline groundwater levels will be
detennined through sampling of monitoring wells for 4 consecutive quaners over a I
~ear period. The frequency. timing. and protocol for sampling will be developed
after ROD signature with the objective of gathering representative data of
groundwater quality and its variation over a I year period. A statistical test which
a~.\:punts for the \ariation of the data shall be employed to measure compliance. and
shall ht: C4ui\ akm t'? or the same as. the method outlined in 40 CFR Part 264.97(h).
The monitoring wells used to detennine and subsequently verify groundwater quality
w ill be located within the area of known groundwater contamination in the direction
of groundwater tlow. The number of monitoring wells designated for sampling as
well as the frequency of sampling and the parameters sampled will be detennined
after ROD signature. Following establishment of the ACLs, groundwater will be
sampled routinely to detennine if any ACLs are being exceeded in groundwater. The
frequency and duration of sampling and the parameters sampled will be detennined
after ROD signature.
Institutional Controls - Institutional controls (i.e., deed restrictions) will be
implemented to limit the use of groundwater beneath the site.
Remedial Action Plan - In the event an ACL is exceeded at the 95 % confidence level
for a period to be detennined after ROD signature, then a Remedial Action Plan
(RAP) shall be implemented to address the ACL exceedance. The RAP will be
developed after ROD signature and will consist of pre-detennined response actions to
address ACL exceedances. The RAP shall be designed to confmn an exceedance
and. if detennined to be necessary by U.S. EPA, a remedy will be selected to
mitigate an impact to the Kalamazoo River. Examples of potential responses include,
but are nOt limited to, confinnational sampling, increased sampling frequency,
detennination of impact to the Kalamazoo River through surface water, sediment and
biota sampling, or installation of a groundwater extraction system.
J. STATUTORY DETERMINATIONS
u. S. EP A's primary responsibility at Superfund Sites is to undertake remedial actions that
protect human health and the environment. Section 121 of CERCLA has established several
additional statutory requirements and preferences. These include the requirement that the
selected remedy, when completed, must comply with all applicable, relevant and appropriate
requirements (" ARARs") imposed by Federal and State environmental laws, unless the
invocation of a waiver is justified. . The selected remedy must also provide overall
effectiveness appropriate to its costs, and use pennanent solutions and alternative treatment
technologies, or resource recovery technologies, to the maximum extent practicable. Finally,
the statute establishes a preference for remedies which employ treatment that significantly
reduces the toxicity, mobility or volume of contaminants.
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1.
Protection of Human Health and the Environment
Due to the fact that there is a liery low potential that groundwater beneath the site
\.\. ould be used as a drinking water source. it is not practicable to restore groundwater
to bendicial use as a drinking water source. The discharging groundwater also has
no detectabk impact ~:m the Kalamazoo River. The major source of further
groundwater contamination was eliminated in 1993 during the cleanup of soils in the
vadose zone at the site. This is expected to result in a significant decrease in the
k\ds of contamination in groundwater in the future. particularly after one pore
volume of groundwater has moved out of the site (estimated to take 5 years). For
these reasons. allowing groundwater to continue to naturally attenuate would be
protective of human health and the environment. The establishment of ACLs for
groundwater. which includes routine monitoring, would assure that the levels of
contamination in groundwater do not pose a risk to the Kalamazoo River in the
future. In the event groundwater monitoring indicates a statistically significant
increase above ACLs, U.S. EPA will select a remedy from the RAP to address any
potential. impacts.
2. Compliance with ARARs
The selected alternative will, in accordance with Section 121(d)(2)(B) of CERCLA,
establish ACLs in lieu of compliance with other potential Federal and State water
quality criteria ARARs. Compliance with all other ARARs will be required. Section
300.430(e)(2)(i)(E) of the NCP further explains that "If, however, a situtation fulf1lls
the CERCLA statutory criteria for ACLs, including a rmding that active restoration of
the groundwater to MCLs or non-zero MCLGs is deemed not to be practicable,
documentation of these conditions for the ACL is sufficient and additional
documentation of a waiver of the MCL or MCLG is not necessary.
3. Cost Effectiveness
Cost effectiveness compares the effectiveness of an alternative in proportion to its cost
of providing environmental benefits. Table 3 lists the costs associated with the
implementation of the selected remedy.
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TABLE 4
T~ltal c:stimatt:d 120sts for the sele(ted remedy at the Auto Ion site (Operable Unit 2):
Alternati\ e
Total
Capital Cost
Total
O&M. 30 Yr.
Total
Present Worth
2
5210.000
$21. 700
$355.000
The selected remedy for this site is cost effective because it provides the greatest
o\erall effectiveness proportionate to its costs when compared to the other alternatives
evaluated. the net present worth being $565.000. The selected remedy results in a
reduction of contamination in groundwater in approximately the same length of time
as Alternatives 3 and 4 while remaining equally protective of human health and the
en v ironment.
4.
Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedy represents the maximum extent to which permanent solutions and
treatment technologies can be used in a cost-effective manner at this site. Of those
alternatives that are protective of human health and the environment and that comply
with ARARs. U.S. EPA has determined that the selected remedy provides the best
balance in terms of long-term effectiveness and permanence, reduction of toxicity,
mobility. or volume of contaminants, short term effectiveness, implementability, and
cost. taking into consideration State and community acceptance.
The institution of ACLs, ground water monitoring, and restriction of groundwater use
through implementation of institutional controls, will provide the most permanent
solution practical, proportionate to the cost.
5.
Preference for Treatment as a Principal Element
Based on current information, U.S. EPA believes that the selected remedy is
protective of human health and the environment and utilizes permanent solutions to
the maximum extent possible. The remedy, howeyer, does not satisfy the statutory
preference for treatment of the hazardous substances present at the site as a principal
element because such treatment was not found to'be practical or cost effective.
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K. S LI}.-UvIAR Y
Th~ sdected remedy will satisfy the statutory requirements established in Section 121 of
CERCLA. as amended by SARA. (0 protect human health and the environment. will comply
\~ Ilh .-\RA.Rs (by means of complying with ACLs established consistent with CERCLA). will
pm~ id~ overall effectiveness appropriate to its costs. and will use permanent solutions to the
maXimum ext~nt practicable. .
Tr~atl1l~nt is not a component of the selected remedy because an attempt to treat the
hazarduus substances present at the site in groundwater would not provide a sufficiently
signifkanr additional decrease in risk presented by the site to justify the increased cost of
impkm~nting such treatment. .
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.0
GLOSSARY
"'\1111,1 i~'ahk or R~le\'ant and Appropriate Requi r~ments ,
S~'~lllIn I ~ lid) of CERCLA requires that rern~dial actions meet I~gally applicable or relevant
.llId .lpprl1pnale requirements I AR-\Rs) of other environmental laws, ugally "applicable"
r~quireillenh are those deanu~tandards. standards of control. and other substantive
ell\ inHlmental protection requirements. criteria or limitations promulgated under Federal or
State law that specitically address a hazardous substance. pollutant. contaminant. remedial
aL,tiun. location. or other circumstances at a CERCLA site. "Relevant and appropriate"
requirements are those r~quirem~nts that. while not legally applicable to the remedial action.
address problems or situations sufficiently similar to those encountered at the site that their
USe is well suited to the remedial action.
:'-lon-promulgated advisories or guidance documents issued by federal or state governments
("to-b~-considered or TBCs") do not have the status of ARARs; however, where no
applicable or relevant and appropriate requirements exist, or for some reason may not be
sufficiently protective. non-promulgated advisories or guidance documents may be considered
in detennining the necessary level of clean up for protection of human health and the
env ironment.
Baseline Risk Assessment
The baseline risk assessment is an analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of any actions to control or mitigate
these r~leases. The baseline risk assessment assumes no corrective action will take place and
no site-use restrictions or institutional controls such as fencing, ground water use restrictions
or construction restrictions will be imposed. There are four steps in the baseline risk
assessment process: data collection and analysis; exposure assessment; toxicity assessment;
and risk characterization.
Cancer Potencv Factors (CPFs)
Cancer potency factors (CPFs) have been developed by EPA's Carcinogenic Assessment
Group for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs, which are expressed in units of (mg/kg-day)'I, are multiplied
by the estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with exposure at that intake level. The
tenn "upper bound" reflects the conservative estimate of the risks calculated from the CPF.
Use of this approach makes underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human epidemiological studies or
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~
Excess Lifetime Cancer Risks
E\I..\:~~ lifetlmc (ancer risks an:: the sum of all ex(ess cancer lifetime risks for all
,lll\l.lIlIin;lnh for a given sccnario. EXI.'e~s Lifctime Cancer Risks are determined by
1llllhipl:-- ing the intake k\el by the (anCer potency factor for each contaminant of concern and
~lIllIlI1illg across all n:le\ant chemicals and pathways. These risks are probabilities that are
gt:naall:-- expre~~ed in scien~ifl.s. notation (e.g, I X 10'°). An excess lifetime cancer risk of I
'\ I U" indicates that a person' s chance of contracting cancer as a result of site related
exposure a\ eraged over a 70-year lifetime may be increased by as much as I in one million.
Hazard Index (HD
The Hazard Index (HI). an expression of non-carcinogenic toxic effects, measures whether a
pason is being exposed to adverse levels of non-carcinogens. The In provides a useful
reference point for gauging the potential significance of multiple contaminant exposures
within a single medium or across multiple media. The In for non-carcinogenic health risks
is the sum of all contaminants for a given scenario. Any Hazard Index value greater than
1.0 suggests that a non-carcinogen potentially presents an unacceptable health risk.
Reference Doses (RIDs)
Reference doses (RfDs) have been developed by U.S. EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting non-carcinogenic effects. RIDs,
which are expressed in units of mg/kg-day. are estimates of average daily exposure levels for
humans. including sensitive individuals. Estimated intakes of chemicals from environmental
media (e.g.. the amount of a chemical ingested from contaminated drinking water) can be
compared to the RtD. RfDs are derived from human epidemiological studies or animal
studies to which uncertainty factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors help ensure that the RIDs will
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