United States
Environmental Protection
Agency
Office of
Emergency end
Remedial Response
EPA/ROD/R05-85/020
August 1985
Superfund
Record of Decision
Verona Well Field, Ml
(Second Remedial Action, 08/12/85)
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1. REPORT NO.
EPA/ROD/R05-85/020
4. TITLE AND SUBTITLE
TECHNICAL REPORT DATA
(Please read Instructions on the rel'erse before completing)
2. 3. RECIPIENT'S ACCESSION NO.
~UPERFUND RECORD OF DECISION
verona Well Field, MI
5. REPORT DATE
Au ust 12, 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT ",o.
9. PERFORMING ORGANIZATION NAME ANO AODRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
Agency
13. TYPE OF REPORT AND PERIOD COVERED
Fina R
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Verona Well Field is located approximately 1/2 mile northeast of Battle Creek,
Calhoun County, Michigan. The well field consists of three wells west of Battle Creek
River and 27 wells, with a major pumping/water treatment station, east of the river.
The Verona Well Field provides potable water to 35,000 residents of Battle Creek, and
part or all of the water supply requirements for two major food processing industries
and a variety of other commercial and industrial establishments. In 1981, county
health officials discovered that water from the Verona Well Field was contaminated with
volatile hydrocarbons The Michigan Department of Natural Resources inve t' t d
. ' s 19a e
potential sources of the contamination, and identified the Thomas Solvent Company facil
i tie s, the Grand Truck marshaling yard, and the Raymond Road Landfill as possible
sources of the volatile hydrocarbons.
An IRM was signed in May 1984 that provided for the installation of interceptor
wells and air stripping to prevent further deterioration of the well field. This
second remedial action is a source control measure that includes construction of a
grOUnd water extraction well system to contain and collect contaminated ground water
in the vicinity of the Thomas Solvent Company's Raymond Road facility. Contaminated
ground water will be pumped to the existing Verona Well Field air stripper for treatmen
In addition, air extraction wells will be installed to enhance the volatilization of th
VOCs from the contaminated soils. The next operable unit will address source control
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Fidd,Gr,',.:,
Record of Decision
Verona Well Field, MI
Contaminated Media: gw, soil
Key contaminants: VOCs, hydrocarbons, TCE,
PCE, solvents, toluene
21. NO. OF PAGES ..-
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS I fllI'S Reportl
None 42
20 SECURITY CLASS IT/:is ,~Jg,.: 22. PRICE
None
,
,
I
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EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDIT!ON 15 OBSOLETE
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INSTRUCTIONS.
1.
REPORT NUMBER
Insert the l,PA report number as it appears on the cover of the publkation.
2.
3.
LEAVE BLANK
RECIPIENTS ACCESSION NUMBER
Reserved for use by ea.:h report redpien!.
4.
TITLE AND SUBTITLE
Title should indicate dearly and brielly the subje.:t .:overage of the rl'port, and be disl'l;l)'l'd pruminl'ntly, S,'I slIhlilk, if IIsl'd, In smalk-r
type or otherwise subordinate it to main title, When a report is prepared in mOll' th;tn ,Hll' vulllme, rq"'al Ihl' primary litk, add v"I~llI1l'
number and include subtitle for the specific title,
5.
REPORT DATE
Each report shall carry a date indicating at least monlh and year, jndi,'ate the h;lsis on whi.:h it wa.s s,",eded (1',,1:,, dal.. "1i,~SIl", Jal.. "1
approval, date o{ preparation, ere.),
6.
PERFORMING ORGANIZATION CODe
Leave blank,
7.
AUTHOR!SI
Give name(s) in l'0nventional order (Jolin R, Doc, J, Rob..rt Do(', "/('.}. List authuc's affiliatlun if it differs fwm the' pl'rfucminj: "'j:ani-
zation.
8.
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Insert if performing organization wishes to assign this number,
9,
PERFORMING ORGANIZATION NAME AND ADDRESS
Give name, street, city, state, and ZIP code, Lisl no more than two 'levels of an organizaliunal hircardlY,
10, PROGRAM ELEMENT NUMBER
Use the program element number under whkh the report was prepared, Subordinale numbl'rs In;,)' be indll,kd In parl'nlh,'",s,
11. CONTRACT/GRANT NUMBER
Insert contract or grant number under whkh report was prepared,
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP code,
13, TYPE OF REPORT AND PERIOD COVERED
Indicate interim final, etc_, and if appli.:able, dates covered.
14. SPONSORING AGI:NCY CODE
Insert appropriate code.
15. SUPPLEMENTARY NOTES
Enter information not included elsewhere but useful, such as:
10 be published in, Supersedes, Supplements, etc,
Prepared in .:oop.:raliun with, rran.s)alllll. III,l'rl''''III,'d ;11 ""11 1<'1 l'lI'" ,01,
16. ABSTRACT
Include a brief (200 words or less) factual summary of the most signifi,'anl Infurma t ion ,.unlail1l'd III 1 Ill' "'I'0rl. II 1IIl' Il'I'"" '"III,IIIIS J
significant bibliography or literature survey, mention it here,
17. KEY WORDS AND DOCUMENT ANAL YSIS
(a) DESCRIPTORS - Se!c.:t from the Thcsaurus of Enginecrir.~ alld SCll'lIllrll' rerilis the proper aull",rll,'d Il'lIlIs IllJt luellllly I Ill' llI:qor
concept of the resear.:h and are suffkiently ,pe.:ific and precise to be us.:U JS .nun entnes ror eJIJlo~ln~,
(b) IDENTIFIERS "\~D OPFN-I:.:"DED TERMS - Use identifiers for prO)el't nJIlI" , ,ude names, l'Ljlllpll1,'nt ,"'slcn,dors, ,'Ie, L'sL' "PL''''
ended terms written in d.:>niptor form for those subjects for which no lk"rlptur <:.\I\h,
(c) COSATll'ILLD GROUP -I icld and group assignments are to be lakL'n frum tll.: 1%5 COSi\ 11 Suhl"l'! Call'~!lTY List. Sinn' tilL' m,l'
jority of documents are multidis.:iplinary in nature, the Primary licldiCr"up ~"I~nmellt(,) will bc 'I"'llll' eli'll!,IIIIC, :trl'~ 01 IIUI",III
endeavor, or type of physi.:al object. The applieation(S) will be L:fo».rckrl'lIccd wllh ,cl''''lllar> I ll'ld '( .r"lIl' ,"SI~I1I"l'lIts 111:11 Il "I I "II, 'Il
the primary posting(s),
18, DISTRIBUTION STATEMENT
Denote releasability to the public or lil1llt:Jtlun for reasons uth.:r Ihan selurlty fur c\aml'lL: "l{l'kJ'l' ('III'''"ll'd,'' ( Ill' ,IIi' ,1\;111.11,,111; I..
the public:, w.th address Jnd prl':c,
19, & 20. SECURITY CLASSIFICATION
DO NOT submit clJsSlfied report> to thl' ~,Itlollal Tc.:hni.:allnfurmatiun serVile,
21, NUMBER OF PAGES
Insert the total number of page\, including thl' one and unnumbered pagL'S, hut L'\Lludl' dl\lrthullUII II,!. II Jny,
22, PRICE
Insert the prke ,d by thc ~ational fcchnicallnformJtlon SL'fLllL' ('r thl' C"'l'rnl1\L'JlI 'Prtlltlllg OtrilC, It Io.n""n,
EPA Form 2220-1 (Rev, 4-77) (Reverse)
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Verona Well Field, MI
at the Thomas Solvent Annex and the Grand Truck marshaling yard.
Total
capital cost for the selected remedial alternative is estimated to be
$1,660,000 with O&M costs approximately $90,000 for the first two years
of operation and $46,000 for each year thereafter.
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RECORD OF DECISION
REMEDIAL ACTION SELECTION
Site Verona Well Field
---- Battle Creek, Calhoun County, Michigan
Documents Reviewed
This decision is based on the following documents describing the analysis of
cost-effectiveness of remedial action alternatives for the source control
operable unit at the Thomas Solvent Company Raymond Road facility.
- Phased Feasibility Study, Verona Well Field, Battle Creek, Michigan
U.S. EPA, June 17, 1985
- Technical Memorandum, Phase II Water Quality Sampling, Verona Well
Field, Battle Creek, Michigan, U.S. EPA, May 17, 1985
- Technical Memorandum, Phase II Drilling and Soil Sampling, Verona
Well Field, Battle Creek, Michigan, 11.5. EPA, May 17, 1985
- Summary of Remedial Alternative Selection
- Responsiveness Summary
.
- Memorandum from Steve Rothblatt, Chief, Air and Radiation Branch to
Richard Bartelt, Chief, Emergency and Remedial Response Branch
- Memorandum from Robert B. Schaefer, Regional Counsel and Basil G.
Constantelos, Director, Waste Management Division to Valdas V.
Adamkus, Regional Administrator
- Letter from Richard A. Johns, Chief, Michigan Department of Natural
Resources, Ground Water Quality Division to U.S. EPA
- Memorandum from Jack Kratzmeyer, Remedial Project Manager, Waste
Management Division to File
Description of Selected Remedy
Construct a ground water extraction well system to contain and collect
contaminated-ground water in the vicinity of the Thomas Solvent Company's
Raymond Road facility. . Contaminated ground water will be pumped to the
existing Verona Well Field air stripper for treatment. In conjunction with
the pump and treat system, air extraction wells will be installed to enhance
the volatilization of the VOCs from the contaminated soils. .
Declarations -
~
Consistent with the Comprehensive Environmental Response Compensation and
Liability Act of 1980, and the National Contingency Plan (40 CFR Part 300),
J have determined that installation of a ground water pumping system, and
air extraction wells is a cost-~ffective remedial action and provides
adequate protection of public health, welfare and the environment. The
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State of Michigan has been consulted and agrees with the approved remedy.
In addition, the action will require future operation and maintenance
activities to ensur~ the continued effectiveness of the remedy. These
activities will be considered part of the approved action and eligible
for Trust Fund monies for a period not to exceed 1 year.
I have determined that the action being taken is consistent with perma-
nent remedy at the site. and is a~propriate when balanced against the
availability of Trusr Fund monies for use at other sites.
Additional feasibility studies at the Verona Well Field site will be com-
pleted in a series of operable units. If additional remedial action(s)
are determined to be necessary. a Record of Decision will be prepared for
approval of the future remedial action(s).
f,f2!~s.
Date r
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Executive Summary
This Record of Decision (ROD) describes the selection of the remedial
alternative to address the environmental threats presented by the contami-
nation located at the Raymond Road facility of the Thomas Solvent Company
near Battle Creek, Michigan. Response activities at the Raymond Road
facility represent a single operable unit in a complex situation involving
two additional ground water plumes that comingle with the one originating
at the Raymond Road facility.
The remedial alternative selected through this ROD addresses two discrete
environmental problems at the Raymond Road facility: the contaminated
ground water plume and soil contamination. As proposed in this ROD, the
remedial alternative selected for the ground water is a pump and treatment
system that would extract 400 gallons per minute of contaminated ground
water which would be treated in a pre-existing air stripping facility and
released to the Battle Creek River. It is anticipated that this pumping
program will remove 68~ of all the volatile contaminant mass contained in
the ground water after 3 years operation. The cost of this system will be
approximately $1,400,000.
The alternative selected to remedy the contaminated soils found on the
Raymond Road facility is in-place treatment of these soils through enhanced
volatilization. This alternative has had limited use in past applications
and can be classified as lIinnovative technologyll. Enhanced volatilization
essentially consists of the placement of several wells directly into the -.
contaminated soils. They are then connected to a vacuum pump which draws
air through the soils. The air is captured and treated to remove the
volatiles. The estimated cost of this system is S413,000 and is axpected
to result in complete removal of the volatile contaminant mass from the
soils in six months to a year.
.
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Summary of Remerlial Alternative Selection
Verona Well Fiel~
Th~as Solvent Raymond Road
Operable Unit
Site Location and Description
The Verona Well Field is locate~ approximatp.ly 1/2 mile northeast of 8attle
Creek, Calhoun County, Mic~igan (see Figure 1). The well fiel1 incorporates
property on both sides of the 9attle Creek River. The area north and east
of the well field is essentially rural. land use to the south and west is
light to heavy industrial, with a residential area directly south, and the
Gran1 Trunk Western Railroad (Grand Trunk) marshalinQ yard adjoining the
well field on the east.
The well field consists of three wells west of the Battle Creek River (in
Bailey Park), and 27 wells, with a major punpinq/water treatment station,
east of the river (see Figure 2 for well placement). The Marshall sa~dstone
formation is the principal aquifer for the well field. Water trans~ission
through the ~'arshall formation occurs primarily through fractures in the
sandstone of the formation.
The Verona Well Field provides potanle water to 35,000 residents of ~attle
Creek, and part or all of the water supply requirements for two major food.
processing industries and a variety of other co~rcial and industrial -
esta~lish"ents. A review of the monthly pu~ping data for the last two
years indicates that the City requires an avera~e supply of water eaual to
approximately 10 MGO (million qallons/day) with additional supplies needed
to meet a peak demand eaualling 19 ~D.
Site History
During August 1981, while conducting routine testing of private water
supplies, the Calhoun County Health DepartMent discovered that the water
supply from the Verona Well Field was slightly contaminated with volatile
organic co~ounds (VOCs). Followup testing by the Calhoun County Health
Depar~ent and the Michigan Department of Public Health (MQPH) revealed
that ten of the City's 30 wells contained detectable levels of volatile
compounds. .The ~PH then began weekly sampling of the well field.
During that same period, the ~DPH began sampling private residential wells
in the area to the south of the well field. To date, approximately ~O
private wells have been found to contain varying concentrations of contami-
nants. Several of the private wells have total VOC contamination levels on
the order of 1,000 ug/l (micrograms per liter, or parts per billion); the
private well with the highest reported level h~d a dichloroethylene concent-
ration of 3,qOO ug/l. Because of the threat posed by the private well
contami~ation, EPA i~lemente~ a bottlerl water program for the area residents,
during tne time a water supply system was being constructed to provide City
water to the affected area. The systeM was completed in December 1983, and
the EPAls bottled water prograM was discontinued.
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2000
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SCALoE IN FEET
FIGURE 1
"ICINITY MAP
Tt10MAS SOLVENT
R~YMOND AO~D '£~SIBIL''''
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FIGURE 2 NATED VOlATILES
TOTAL CHl~~TIOH MAP .
ISOCONCEH
AIIGUS T . 19~=VESTJGATION
R[H(DIAL FIELD
VERONA WELL MICHIGAN
.. BATTLE C:U:CtIJ85-UZ
J4. DRAWING.
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The Verona Well Field was listed as a National ?riorities List site in July
1982 (Group 4). Since then several stu~ies, investiqations and activities
have been conducted in the area.
The ~ichiga" Department of Natural Resources (MDNR) investigated potential
sources of the contamination, and identified the Thomas Solvent Company
facilities, the Gran~ Trunk marshalinq yard, and the Raymond Road Lan~fill
as possible sources of the volatile hydrocar~ons. The EPA Technical
Assistance Tea~ (TAT) conducterl a ground water survey during the spring of
19~?, and further concluded t~at the source of contamination was most
likely in the vicinity of t~e Thomas Solvent facilities. T~e U.S. Geological
Survey (USGS) initiated a hydrological investigation under contract with
the City of Battle Creek in lq~2. The study examined the geology and
ground water flow patterns in the vicinity of the Verona Well Field. The
USGS has prepared a ground water flow model (1985) to evaluate the effects
of pumping Verona wells on ground water flow. The U.S. Environmental
Protection Agency (EDA) began ~hase I of a remerlial investigation (RI) in
November 1qq3. The purpose of the ~I was to identify the sources of contami-
nation to the well field.
By January 1984, all but six of the City's 30 water supply wells in the
Verona Well Field were contaminated with VOCs from the advancing ground
water plume. Under these conrlitions, it was apparent that there would not
be ft sufficient supply of uncontaminated water to ~eet the City's peak
demand in the summer of 1984. In response, EPA initiated a focused feasi-
bility study (FFS) in February 1984 to address the water supply problem, -.
while the remedial investigation on the sources of contamination proceerled.
.
The FFS resulted in a ~ecord-of-necision by Region V, EPA in May 1994 that
recommended the installation of three new water supply production wells,
and the use of selected existing Verona wells to fo~ a blocking well system
t~ halt the spread of contamination to t~e northernmost Verona wells. The
purge water from the blocking wells would be treated by an air stripper to
be constructed at the well field.
The blocking wells were started up immediately in May 1984, with temoorary
carbon adsorption beds providing treatment until the air stripper could be
constructed. Construction of the air stripper was completed in August 1984.
Since operation of the barrier wells began in May 1984, the advance of the
contaminant plume further into the well field has been halted. The City
currently can provide 22 ~D of uncontaminated water from existing and new
wells. This amount is sufficient to meet the peak demand of lq MGD. In
its Record-of-Decision, EPA determined that the harrier system should be
maintained for a period of five years. This means the City will have.
adequate supplies of uncontaminated water to meet established demand, until
the time that final remedial measures are implemented.
.
.
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The results of the Phase 1 remedial investigation were publishe~ in tec~nical
memoran~um in Nove~ber 1Q84. The results confirmed that the Thomas Solvent
facilities were Major sources of groun1 water contamination, and a1so,
identified an unknown source of perchloroethylene (PCE) from a location
east of the well field.
Phase 11 of EPAls remerlial investigation was initiated in July 1984 to
characterize in greater detail the extent of VOC contamination at the
ThoMas Solvent facilities, and to investigate the source of the eastern
plume of PCE.
In February 1Q95, EPA determined t~at source control measures at the Verona
Well Field site should be carried out in separate operable units. This
decision was consistent with the National Contingency Plan (NCP) revisions
proposed February 12, 198~, which state that operable units can and should
be~in before selection of a final remedial action, if they are cost-effective
and consistent with a permanent remedy [40 CFR 300.68(d}(3}].
Source control at the ThoMas Raymond Road facility was identified as the
first operable unit that should be conducted at the Verona Well Field site.
This operable unit was selected first hecause of the relative magnitu~e of
contaMinaton at the Raynond ~oad facility.
The ground water beneath and surroun~in~ the Thomas Raymond Road facility
is contaminate~ at levels exceeding 100,000 ppb V~Cs. This is approxiMately
100 times more concentrated than levels in the majority of the plume. A
seoarate organic phase liquid has also been observed at one location on the
Thomas Raymond Road property.
The ThOMas Solvent Company operations at the Raymond Road facility consisted
of the packaging an~ distribution of liquid solvent commercial products, as
opposed to liquid wastes, with the exception of minor amounts of reclaimed
acetone. Consequently, as the owner/operator Thomas Solvents is considered
the only potentially responsible party for the contamination at the Ray~ond
Qoad facility. The generators of the reclaimed acetone hauled by Thomas
are unknown, and since this activity represented a ninor portion of Thomas
Solvent business (less than 5'), enforcement efforts have been directed at
Thomas as owner/operator.
.
On April ~, lq8~, Thomas Solvent Company filed a voluntary petition under
Chapter 11 of the Bankruptcy Code in the Ran~ruptcy Court for the Western
District of Michigan. That proceedinq is still pending, but holds little
possibility for any substantial recovery of funds or for any significant
contribution to any settlement of this matter. In the bankruptcy action
there are four primary claimants: U.S. EPA, the State of Michigan, and two
separate groups of local residents who are claiming various injuries. In
the agQregate, the claims against the estate of the bankrupt amount to well
over $100,000,000.00, and the assets that have been included in the estate
aMoun~to less than S4~O,OOO.OO The ban~rupt has ceased all operations at
the Raymond Road facility, and apart from th~ possibility of a s~ll mone-
tary recovery, it is almost certain that ThoMas Solvent COMpany will make
no significant contribution to any settlement of this matter.
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Current Site Status
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The Thomas Raymond Road facility consists of an office, garage, warehouse,
loading docks~ and 21 underground storage tanks. Figure 3 shows the loca-
tion of tanks, buildings and property boundaries. The facility was used
for the storage, transfer and packaginy of chlorinated and nonchlorinated
solvents.
Ground water monitoring wells and borings were installed during the site
investigations at the locations shown in Figure 4. Measurements of the
levels of soil and water contamination are available for these well
locations. In the discussion that follows, well locations will refer to
the wells designated on Figure 4.
Besides the underground tanks, solvents were handled on the site at four
main locations. These locations are listed below:
o Within the tank truck loading/unloading area.
was installed in this area.
Well B-14
o Within the warehouse where drums were filled using the
feed lines from each of the underground tanks.
o At the south dock where filled drums were stored for
loading onto semi-trailers. Borings B-l1 and 8-12 were
located near the loading areas.
o At the east dock where drums were occasionally stacked.
-
..
As shown in Figure 3, the chlorinated solvent tanks (tanks 6. 7 and 8) are
located north of the warehouse in the vicinity of Well 8-17. Trichloro-
ethylene. PCE. and 1.l,I-TCA were stored in these tanks. These compounds
and their "breakdown products" have been found in the Verona Well Field.
The a~uifer in the area of the Verona Well Field consists of two units:
a shallow sand and gravel deposit overlying the sandstone bedrOCk of the
Marshall Formation. The Verona Well Field is developed in the bedrock.
8ased on hydraulic conductivity tests of the sand and the bedrock. there
does not I~pear to be a significant conductivity barrier between the two
units. Therefore, the two units are considered to be in direct hydraulic
connection, ~nd contaminants are free to pass from one unit to the other.
The contaminants have migrated from the sand and gravel at the Thomas
Raymond Road facility into the bedrock within the well field. At the
Thomas Raymond Road property, the sand and gravel deposits vary from 13
feet to a maximum of 45 feet at Well 8-18. The ground water is estimated
to flow at 1-2 ft./day across the property to the northwest.
During the Rl soil samples from the unsaturated zone were obtained from
borings.8-11 through 8-18. The vertical distribution of total vacs is
shown in Figure 5. The cross-section on Figure 5 encircles the warehouse
and doCk area where solvents were mainly handled on the property (see the
lower right corner of Figure 5 for detail). The unsaturated zone soil
contamination at Well 8-14 is relatively uniform throughout the depth of
the unsaturated zone. The same is true for contamination at Boring B-13.
and in general at Borings B-12, 8-15, and 8-16.
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FIGURE 4
REMEDIAL INVESTIGATION WEll LOCATIONS
THOMAS SOL VENT
RAYMOND ROAD FEASIBILITY STUDY
-------
SOUTH DOCK
T
TANI< TRUCK UNlOADING AREA
- -
EAST DOCK
UNDERGROUND T ANI< AREA
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SECTION X-X'
nPiCAL WEll DETAIL
18OI8T0MI0 IIUMICIPAL
weLL WELL
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SOliD CASINO
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VERTICAL ".
TOTAL V'
'HOUAS so
AAYUOHO Al
~1.UTlON OF
...lITY S'UDY
-------
-5-
This type of contaminant distribution would be likely to result from spillage
during surface hanrllin9 of solvents on and around t~e dock area. T~e soil
contaninatio" is much less at borings 8-11 and 8-18 which are in the under-
ground tank area, where solvents were not handled at the surface. In t~is
area, leaka~e fro~ the tanks woulrl be expected to move directly to the
ground water.
Each of the 21 underground tanks were tested for leaks in March 1qq4 by the
Th~as Solvent Company. As part of the leak testing each tank was filled
with mineral spirits after the tanks had been emptied as specified in the
Preliminary Injunction against Thomas Solvent issued on February 23, 19~4,
by the Calhoun County Circuit Court. Nine of the 21 tanks ha1 a "'e~s'Jrable
loss rate (>0.05 gallons/hr). The test results are given in Table 1.
Tab 1 e 1
UNDERGROU~ID TAtJK LF.AKAGE RATES
Tank Number
Contentsa
leakaqe ~ate
(gal/hr)
0.55fi
0.119
0.073
0.067
0.232
0.069
0.066
0.086
0.181
-
..
1
2
5
6
8
11
16
18
20
Hexane
Ethyl acetate
Toluene
Trichlorethylene
1,1,1 Trichlorethane
to1ethanol
Active Thinner
~300 ~ineral Spirits
Di esel Fuel
aReflects tank contents at ti~e of testing. Hay not agree with
contents shown on Figure 3.
A contour mao of the concentration of total VOCs in the unsaturated zone
soils is shown in Figure 6. The total ~ass of VOCs within the 10-ppb
contour line is approximately 1700 pounds. The total mass of VOCs outside
of that centour is only one pound. Consequently, the overwhelminq majority
of the total VOCs in the unsaturated zone (16q9 of 1700 pounds) is located
1n a relat1~e'y confined area defined by the 10-ppb contour '1ne.
A map of the total VOC concentration in the qround water 1n the vicinity of
the Tho~as Raymond Road facility is shown in Figure 7. The highest observed
ground water concentration has been at Well. 8-18, which then follows ground
water flow to the northwest towards Well W-16. The peak in ground water
concentration (at Well 8-19) does not coincide with the peak 1n the unsatu-
rated lone so1' contamination, which was between borings 8-13 and 8-1~.
Th1s 1s because of the different sources of contamination 1n the area.
Contamination between 8-13 and 8-1~ is fr~ solvents spilled at the surface,
which have then migrated through the unsaturated zone to the water table.
The source of contamination to the ground water at Well 8-18 1s from leakage
from the underground tanks, and also ~igration from the upgradient sources,
such as 8-14.
-------
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RAYMOND
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FIOURE 6
TOTAL YOC'S
IN UNSATURATE
~:~OAS SOL VENT D ZONE SOIL
NO "OAO F
EA$'8111TY STUDY
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FIGURE 7
TOTAL YOC"S
IN GROUNDWATER
THOMAS SOLVENT
RAYMOND ROAD FEASIBILITY srUDv
-------
-6-
The vertical extent of ground water contamination is shown by the concen-
tration contours for 1,2-DCE in Figure 8. The highest concentration is
within the sand and gravel at 8-18. Downyradient of well W-16, the plume
drops into the bedrock, and the concentration in the sand and gravel
unit decrease's.
The estimated mass of contaminants in the ground water is given in Table 2.
Table 2
Mass of VOCs in Ground Water
Southern Plume (Saturated Zone)
Raymond Road Facility Property
(Saturated Zone)
5,700 lbs.
440 lbs.
Raymond Road Facility Vicinity
(Saturated Zone)
A separate organic-phase liquid has also been observed at Well 8-18. This
organic phase consists of up to 10-20 percent chlorinated solvents.
Accumulation of this organic phase has been limited primarily to 8-18,
which has been pumped several times to recover the solvent layer. The
source of the organic-phase liquid appears to be a highly concentrated
suspension in the upper portion of the saturated zone.
3,900 lbs.
-
The compounds that have been detected at the Thomas Raymond Road facility
during the site investigations are listed below.
Table 3
Chlorinated Hydrocarbons
Methylene chloride
Chloroform
Carbon tetrachloride
1.2-Dichloroethane (I.2-DCA)
l,l.l-Trichloroethane (l.l,l-TCA)
Vinyl chloride
1.l-D1chloroethylene (l.l-DCE)
trans'-l,2-Dichloroethylene (t';'1.2-DCE)
Trichloroethylene (TCE) ,
Tetrachloroethylene, co~only called perchloroethylene
(PCE)
Aromatics
Benzene
':.Toluene
Xylene
Ethyl Benzene
Napthalene
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VERTICAL DISTRIBUTION OF
l,2-DICHLOROETIfYLENE
Tat ,.nn.._,,,. fA Tl:"n
-------
-7-
Ketones
Acetone
Methyl ethyl ketone (MEK)
Methyl isobutyl ketone (MIBK)
Of the contaminants found at the site, the chlorinated hydrocarbons are the
most environmentally significant. They are very mobile, and are slow to
degrade when they are in soil or ground water. This accounts for the wide.
extent of the chlorinated hydrocarbon plume. Several of the chlorinated
hydrocarbons are known or suspected care; nogens.
Like the chlorinated hydrocarbons the aromatic compounds are mobile,
but they are more biodegradable. Consequently, there has been limited
migration of aromatics from the site because the compounds are degraded as
they migrate from the source. Benzene is the only aromatic that is known
to be a carcinogen.
The ketones are very mobile, but they also biodegrade rapidly and are
relatively non-toxic.
Enforcement
Current State and Federal enforcement activities are focused on two identi-
fied potentially responsible parties (PRP's): Thomas Solvent Company and
Grand Trunk Rail Road. Both PRP's declined to conduct the RIfFS in April_-
1983, and both declined, in April 1984, to undertake the immediate removal
action at the Verona Well Fie1d.(insta11ation of a temporary purge system).
Specific administrative actions to force PRPs to perform the initial remedia
measures were not taken because the nature of the problem at the well field
dictated that EPA act quickly.
In February 1984, Thomas Solvent Company was ordered by EPA through a
unilateral section 106 CERCLA Administrative Order to purge a separate
organic phase liquid from ground water beneath the Company's main facility
at Raymond Road. Thomas complied with the Order and purged 500 gallons of
contaminated water.
The layer of contamination was not wide spread, but periodic purging is
required, and was continued by Thomas until March, 1985. The buildup of
this organic phase liquid (greater than 1.0 foot) has been limited to a
single well (B-18) on the property except for one observation in February
1985, when about 3 feet was observed in a monitoring well located approxi-
mately 20 feet west (direction of Verona Well Field) of Well B-18. It was
this observation, in part, that has caused initial State and Federal source
control actions to focus on the Thomas Solvent Raymond Road facility.
In January 1984, the Michigan Attorney General filed a civil complaint in
State court for injunctive relief against Thomas to clean up soil and
ground water contamination at both Thomas facilities upgradient of Verona
Well Field. An order has been entered in that proceeding in favor of the
State, and Thomas subsequently filed a Chapter 11 petition under the
Bankruptcy Code placing the Company's viability as a responsible party in
question. -
-------
-8-
EPA has filed a claim in the continuing bankruptcy proceeding for costs
incurred for remedial action at the Verona Well Field.
Grand Trunk i.s the landow~er of the Tho~as Annex, and owner/operator of a
marshaling y'ard east of the well field. Data obtained during the remedial
investigation has positively identified one area within the marshaling yard
as a source of contaminants that are migrating to the Verona Well Field.
Two other areas within the marshaling yard were tentatively identified as
potential sources of contaminants to the well field, but monitoring wells
have not yet been installed to verify these areas as sources.
EPA has pre~ared a work plan for additional remedial investigation activities
that the Agency believes are necessary to fully identify and characterize
the sources of contamination which exist at the marshaling yard. Discussions
will be initiated with Grand Trunk to determine its interest in performing
the investigations outlined in the work plan.
Alternatives Evaluation
During the initial stage of this phased feasibility study (PFS), potential
remedial technologies were screened according to the following factors:
1) suitability for site conditions and contaminant characteristics;
2) effectiveness of achievable cleanup or control; 3) level of demonstrated
performance under similar conditions; and 4) relative cost.
The purpose of technology screeniny was to assemble potential remedial
action alternatives that would ~eet the objectives of this operable unit,
namely:
o To remove, contain, or destroy contaminants in the unsaturated-
zone soils on the Thomas Raymond Road property, and
o To remove contaminants froln, and minimize continued migration of
contaminants from the highly contaminated ground water surrounding
the site.
After the screening, six alternatives were judged to meet the objectives of
the project and were evaluated further: ' .
ALTERNATIVE '1
Install an extraction well system at the Thomas Raymond
Road site. Pump the contaminated ground water via a
transfer pipe to the existing Verona Well Field air
stripper. Discharge the treated water to the Battle
Creek River.
ALTERNATIVE '2 - Install a clay cap over the contaminated soil area.
AlTERNATIVE 13 - Install a system of air extraction wells in the unsaturated
zone to induce a flow of air through the soil in-situ to
remove the VQts.
.
ALTERNATIVE '4 - Install a piping sys~em and berm configuration to allow
-------
-9-
flooding of the contaminated soil area with unconta~inaterl
water. The clean water would infiltrate into and percolate
through the contaminated soil. The VOCs are washed from the
soils into the ground water which is captured by the pu~ping
system.
ALTERNATIVE *5 - Excavate contaminated soils and dispose in an onsite
disposal facility.
ALTERNATIVE '6 - Excavate contaminated soils and transport to an offsite
facility for disposal.
Ground water pumping and treatment as described in Alternative 1 is the only
contaminated ground water option that was retained for detailed alternatives
evaluation. The reason for this is that the site geology precludes t~e use
of passive physical vertical barriers since the only available natural
confining unit is a shale formation located at a depth of 140 feet. ~
natural confining unit is needed to key the barrier into, at a depth
accessible by trenching equipment. The shale formation is ton deep for the
trench excavation and backfilling necessary for installation of a vertical
barrier.
-
.
Each of the remaining five remedial action alternatives considered includes
the ground water pumping and treatMent actions contained in Alternative 1;
the remaining alternatives differ primarily in their approach to the
contaminated soils at the site.
Alternative 1:
Alternative 1 is designed to pump conta~inated ground water from the Thomas
Raymond Road site vicinity to the existing air stripper at the Verona Well
Field. The site vicinity, as defined in the section on Current Site Status,
includes the area defined by the 1 x 105 ppb total VOCs concentration
contour shown on Figure q. Extending the ground water pumping system
beyond the site boundaries to include this area provides the following
benefits: .
. About 68 percent of the contaminant mass (3900 of 5700 total
pounds, see p. 6 above) in the southern plume is contained
within this area, while only 8 percent of the contaminant mass
is in the ground water directly beneath the Raymond Road facility
property.
. The ground water pluMe in this area is contained in the sand and
gravel unit of the aquifer rather than the bedrock. Soil conditions
in this unit allow removal of contaminants at a moderate pUMping
~ate. nowngradient of this area, the plume migrates into the sand-
Stone bedrock, which has less favorable pUMping characteristics.
A number of pumping schemes were 'analyzed during the PFS, and it was determin~~
that a total pUMping ratp. of 400 gpm would produce the radius of influence
necessary to contain and collect the highly contaminated groun~ water in the
-------
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EXTRACTION WELL LOCAnONS
THOMAS SOlVENT
- - ... -..-.. ......, ...... .nV'
-------
-10-
vicinity of the site. An evaluation of higher pumping rates indicated that
cleanup time would not be reduced, because hi9her pu~ping rates would cause
upward flow of uncontaminated water fro~ t~e san~stone aquifer. This would
serve only to dilute the contaminated groun~ water and increase the volume
of water that must be pu~ped to remove the mass of contaminants.
A pumping rate of 400 gpm allows the use of t~e existing air stripper at
the Verona Well Field for water treat~ent, since that syste~ h~s sufficient
unused treatment capacity to accomodate an additional 400 gp~. The option
of installing a new 400 gpm air stripper at the Tho"as Ray~ond Road site
was considered, but was dropped when preliminary cost inforMation indicated
that costs for a new stripper greatly exceeded the cost of a transfer pipe
to the existing air stripper at the Verona Well Field.
During approxiMately the first four weeks of operation of the ground water
extraction syste~, the concentration of VOCs in the ground water Du~pe1 from
the ThoMas Ray~ond Road site are expected to exceed levels appropriate for
river discharge, even after treatment in the air stripper. To Drovi~e
additional treatment during this initial high concentration perio~, a
temporary granular activated carbon syste~ will ~e installed upstream of
the air stripper to reduce contaminant levels prior to stripping.
Several different treat~nt methods are possible for treating qrounrt water- .
contaminated with vol~tile organic compounds. These inc'lJde chemical
oxidation, biological degradation, stipping with air and/or stean, and
granular activated carbon adsorption. In most cases where contamination is
limited to VOCs the selection narrows quickly to air stripping or granular
activated carbon adsorption. The other methods have been shown to be either
ineffective or too costly for use in this application. Since the optimu~
gro'Jnd water extraction rate of 400 gpm can be handled at the existi~g
stripper, no capital costs for treatment are incurred, which offers a clear
cost advantage over carbon adsorption as a stand-alone technology.
~
For this alternative, minimal action would be taken in response to the
unsaturated zone soil contamination. Natural leaching froM rainwater infil-
tration, and volatilization to the atmosphere will reduce VOC concentrations
in the unsaturated zone 50115.
.
Table 4
Cost for Alternative' 1
Ground Water pumping
Capital Cost
Annual 0 & M
Present Worth
(3 years)
The annual operation and maintenance costs include the estiMated costs for
replacement, IS needed, of the vapor ~hase carbon in the emission control
system use1 with the existing air stripper.
Sl,~48,OOO
$ qO,OOO
Sl,404,Ono
Air stripping is designed to remove VOCs froM water by transferring the
-------
-11-
contaminant mass from the water to an air stream. and therefore use of this
treatment method will result in a VOC air emission. A vapor phase carbon
adsor~tion (i.e.. Best Available Control Technology) system was installed
as part of the IRM, to treat and control the VOC emissions from the air
stripping of the purge water from the blocking well system. Region V's Air
Management Division staff has modeled the additional emissions resulting
from treatment of Thomas Raymond Road ground water at the existing air
stripper. The present air stripper emissions were used as baseline conditions.
and additive cancer risks as specified below were calculated for a number
of operatiny periods for the Thomas Raymond Road extraction well system.
Additional Peak Cancer Risk
Existing Verona Well Field
Air Stripper
1.1 x 10-7 Baseline
2.7 x 10-7
*Raymond Road ground water, Day 1
. .
Raymond Road ground water after 1st Month
3.1 x 10-8
2.6 x 10-7
*Raymond Road ground water, 1st Month
*During the initial four weeks of operation, in addition to vapor-phase
carbon adsorption a water-phase carbon adsorption system will be located
upstream of the air stripper. -.
4
The results of the modeling indicate that with continued use of vapor phase
carbon adsorption control, the excess cancer risk due to VOC emissions does
not exceed 1 x 10-6.
Extraction well '5 (see Figure 9) would be located in the area around Well
B-18, where the separate organic-phase liquid has been observed. An organic-
phase recovery well would be installed adjacent to the extraction well to
capture any organic liquid floating on the water table.
ALTERNATIVE 2:
q
Alternatiye 2 consists of the installation of a clay surface cap over the
area of contaminated soils to reduce infiltration into the contaminated
soil 1n the unsaturated zone. The ground water pumping and treatment scheme
for this alternative is the same as that described for Alternative 1.
The cap would be designed to reduce infiltration through the unsaturated
zone by at least 90 percent, allowing approximately 1 inch per year of'
percolation. The effectiveness of a cap is a function of its ability to
isolate the contaminant mass in the unsaturated zone soils from rainfall
infiltration, thereby reducing the mass of vacs that is leached into the
ground~ater. The cap would also restrict the release of vacs to the
atmosphere.
-------
-12-
Table 5
Cost for Alternative * 2
Surface Cap
I
. '
Capital Cost
Annual a & M
Present Worth
(3 years)
$291,000
$ 19,000
$324.000
The rate at which contaminants are released to the ground water has an
effect on the rate of ground water cleanup. Since the cap would drastically
restrict leaching out of the unsaturated zone immediately, the reduction of
contaminant mass in the ground water would be relatively rapid. The mass
of VOCs in the ground water would decrease to less than 100 1bs. in about
one year. After 3 years the ground water concentration would level off at
approximately 100 ppb.
However, a critical fact in the capping alternative is that the mass of
contaminants remaining in the unsaturated zone after three years would be
virtually the entire 1700 1bS. of VOCs. In other words, capping does
nothiny to actually treat the soil contaminants.
ALTERNATIVE 3:
.
Alternative 3 is designed to reduce the mass of contaminants in the
unsaturated zone by inducing a f10~! of air through the soil to volatilize
the contaminants. Once volatilized the VOCs would be removed from the air
stream by vapor phase activated carbon.
An array of overlapping air extraction wells, installed in the unsaturated
zone. would be connected by an airtight transfer line to a vacuum pump.
Table 6
Cost for Alternative' 3
Enhanced Volatilization
Capital Cost
Annual 0 & M *
Present Worth
(3 years)
$413,000
o
$413,000
*Cost estimate is based on contractor start-up and operation of enhanced
volatilization system. Estimate of vapor-phase carbon replacement cost
for this system is included in capital cost.
.
In order to monitor the effectiveness of this treatment method, soil gas
samples would be collected from the air extraction wells discharge line.
When soil gas samples show the concen~ration to be below detection limits,
soil cores would be taken for analysis.
-------
-13-
Alternative 3 is a systeM that essentially transfers the VOCs from the soil
to the air. That air stream will be then treated with vapor-phase carbon
adsorption prior to discharge to the atmosphere.
Based on the. available operating experience reported for this treatment
method for VOCs, complete removal of contaminant mass from the unsaturated
zone is expected to occur within a year. Because this alternative will
actually remove the VOCs from the soils in a relatively short time, in
evaluating its impact on ground water cleanup it is considered functionally
equivalent to excavation of the soil from the contaminated area. .
The reduction in ground water concentration would be similar to that for the
surface cap alternative. Within 3 years, the ground water concentration
would decrease to 100 ppb.
The total mass of VOCs remaining would be controlled by the mass in the
ground water, since the 1700 lbs of VOCs in the unsaturated zone are expected
to be removed at the start of the enhanced volatilization system. After
1-1/2 years, the total mass of VOCs remaining would be approximately 100 lbs.
(2 percent of the initial total mass of 5600 1bs).
ALTERNATIVE 4:
Alternative 4 is designed to reduce th~ level of contamination in the
unsaturated zone by washing the VOCs from the unsaturated zone soils into the
ground water. Treatment would be provided by the ground water extraction_,
system. '
A number of berms would be built over the contaminated soils forming enclosed
collection basins. Clean water would be pumped into each basin, and allowed
to percolate through the contaminated soil. As the clean water percolates
through the contaminated soil, the VOCs would be "washed" into the ground
water which would be collected by the ground water extraction well system.
Each bermed area would receive 100 inches of water each year.
Table 7
Cost for Alternative' 4
50i1 Washing
4
Capital Cost
Annual 0 & M
. Present Worth
(3 years)
$58,000
S 6,000
$69,000
It i5 anticipated that the ground water concentration would decline more
slowly for this alternative than for others. Projections indicate that the
ground water concentration would reach 100 ppb after approximately 8 years.
By comparison, under the natural recharge conditions in Alternative 1, the
ground water concentration would reach 100 ppb after 5 years.
-------
-14-
The benefit of rapidly leaching the VOCs out of the unsaturated zone into
the ground water is realized in the total contaminant mass removed. The
total mass remaining (soils and ground water) would be less than 100 lbs.
(2 percent of the initial 5600 lbs) after 8 years.
I
. .
ALTERNATIVE 5:
Alternative 5 is desi~ned to reduce the leaching of contaminants from the
unsaturated zone into the ground water by excavation and disposal of the
contaminated soil in an onsite disposal facility. A double-lined landfil"
consistent with the 1984 RCRA Amendments, would be constructed on or near
the Thomas Raymond Road property. Any leachate collected from the landfill
would be treated at the existing Verona Well Field air stripper.
The volume of contaminated soil to be excavated is approximately 4,400 cubic
yards. This is based on excavation of soil with a contaminant concentration
of 100 ppb. (See Figure 10). The 100 ppb level was selected because
99 percent of the mass of VOCs in the unsaturate~ zone is within the 100 ppb
contour.' Soil would have to be excavated at a 2:1 slope to prevent sidewall
collapse of the excavated area; and excavation would be to the depth of the
water table. At the 2:1 slope, an additional 4900 cubic yards of uncontami-
nated soil would also have to be excavated, resulting in a total of 9300
cubic yards of soil requiring disposal in the onsite facility.
Table 8
.
Cost for Alternative' 5
Soil Excavation with Onsite Disposal
Capital Cost
Annual 0 & H
Present Worth
$1,632,000
$ 26,000
$1,677,000
After construction the onsite landfill would require closure under RCRA as
a disposal facility. Ground water monitoring would be required at the site
following closure.
For this alternative, the total mass of VOCs remaining is a funcition of
the mass in the ground water since the vacs in the excavated soil are
isolated io the onsite landfill. The ground water concentration would
decrease to 100 ppb after about 3 years. After 1.5 years the total contam-
inant mass remaining (entirely in ground wate~) would be approximately 100
lbs (2 percent of the initial total mass of 5600 lbs); however, 1700 lbs of
vacs would remain onsite in the disposal facility.
ALTERNATIVE 6:
This alternative is similar to Alternative 5, with the exception that
excavated soil would be transported to an offsite disposal facility. Two
potential disposal sites that are being upgraded to comply with the RCRA-
Amendment requirements for double-lined containment have been identified.
The two sites are Wayne Waste Disposal, Belleville, HI and Fondessy
Enterprises, Oregon, OH. Wayne Waste -is approximately 120 miles from Battle
-------
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SCALI IN FlU
FIGURE) 0
Al TERNATlViS I AND 7
AREA OF EXCAYATION AND
ON-PROPERTY DISPOSAL
THOMAS SOlVENT
RAYMOND ROAD fEASIBILITY SfUDY
-------
-1~-
Creek, and Fon~essy is 180 miles away. For those haul distances, each
truck could ~e expected to ~ake one round trip per day. Assu~ing 30 cuhic/
yards per tr~ck load and a total excavated volume of Q300 cubic yards of
soil, approximately 300 truck loarts would be necessary to transport the
soils.
Table 9
Cost for Alternative * 6
Soil Excavation with Offsite Disp~sal
Capital Cost
Annual 0 & M .
Present Worth
(3 years)
$2,471,000
$ 0
$2,471,000
.Operation and Maintenance Costs for offsite disposal facility are inclu~ert
in initial disposal charge.
Impact on the ground water cleanup would be identical to that described for
Alternative 5.
-
Summary:
Each of the alternatives evaluated has the sam@ grou"rt water extraction
syste~ as described for Alternative 1. The difference between alternatives
lies in the approach to t~e contaminate~ soils in the unsaturated zone.
Eac~ of the soil alternatives would move the conta~inants out of the unsatu-
rated zone at different rates. The rate at which conta~inants leach into
the groundwater has an effect on the rate of qround water clean up.
The effectiveness of each alternative can be evalu~ted based on the total
mass Of VOCs re~aining in the unsaturated soil zone and the grounrl water.
The total VOC mass re~aining in the syst~ with time for each alternative
is plotted in Figure 11. Alternatives 3, 5 and 6 will remove the mass of
contaminants from the site more quickly than the other alternatives.
Alternativ~ 4 is the next ~ost effective. _lternative 1 would initially
reduce the total mass of VOCs at the sa~e rate as Alternative 4, because
the removal rate i5 controlled initiallv ~y the large ~ass of V~Cs in the
ground water. Eventually, removal by Alternative 1 worsens, as the removal
rate be~ins to be controlled by the contaminant mass re~ainin9 in the
unsaturated zone soils.
Alternatives 1, 3 and 4 are the only alternatives that result in actual
treatment of the VOCs in the unsaturated zone. The VOts are captured on
Yapor-~hase carbon. and subsequently are incinerated during the activated
carbon regeneration process. Alternatives 2. 5 and 6 are intended to
safely secure and isolate the VOt conta~ination. hut provide no real treat-
~ent. Alternative 2 isolates the conta~inated soil in place. Alternatives
5 and 6 remove and secure the conta~inated soil; one on the site property,
and the ot~er at another location.
-------
"
.000
3000
i
i
2000
.000
.
.
FIGURE 11
I
. .
o
o
.000
11M! (daYS)
2ODO
- .
..
SOIL
WASHING
(ALl 'I)
3000
FIGURE 11
Total Contaminant Mass Remc
Summarv of AttematiYes
Thomas Solvents
Raymond Rood Feasibility StudY
-------
-Hi-
Alternatives 2 and 5 would he the most complex alternatives to install.
Construction of the onsite landfill would be difficult hecause of the
limited area of the property. Installation of Alternative 2 would be
difficult due to the narrow range of clay moisture content reQuired to
contruct an effective cap.
Alternative~'3, 5 an~ fi will result in air emissions of the VOCs. Volatile
contaminants in Alternative 3 would be controlled as a single point source
emission, which would facilitate treat~ent. Alternatives 5 and 6 would
result in t~e uncontrolled release of VOC emissions during excavation.
Alternatives 1, 2, 5 and 6 are demonstrated technologies. r,round water
pumping and treat~ent have been used successfully in hazardous waste
applications. Conditions at the site are suitable for the use of ground
water pu~ping. Long-term experience with synthetic membrane, dou~le-lined
landfills in hazardous waste applications is limited. However, this design
is considered to be state of the art and with proper cap maintenance, leachate
production is not expected. long-term experience with surface caps in
hazardous waste applications is limited.
Alternatives 3 and 4 respresent innovative technologies. The enhanced
volatilization process has been used in some hazardous waste applications,
but long term experience in a variety of applications is limited.
Summa ry of Costs
Alt. 1 Al t. 2 Al t. 3 Alt. 4 Alt. 5 Al t. 6
Capital Cost,$ 1,248,000 291,000 413,000 58,000 1,632,1)00 2,471 ,000
Annual 0 & H, $ 90,000 19,000 0 6,000 26,00(') 0
Present Worth,S 1,400,000 324,000 413,000 69,000 1,677,000 2,471 ,000
(3 years)
Community Relations
Copies of the Phased Feasibility Study (PFS) were made available tot~e
community on June 17, lq~~. Two locations served as repositories within
the co~unity: ~attle Creek City Hall and Willard library. EPA placed an
advertisement in the c~unity's daily newspaper advising the public of the
start of the three week public comment period and schedule for a public
meeting. .
The public meeting was held July 2, 1985 at the Battle Creek City Hall.
Approximately 30 residents attended the meeting. Representatives of the
EPA, State and local governments were present. The EPA made a presentation
that described the alternatives that had been evaluated in the PFS. In
addition, EPA responded to general questions regarding the project.
The only alternative that received an endorsement at the meeting was
Alternative 3, which was supoorted by the City. Several residents did not
think that three weeks was an adequate period of time in which to review
the PFS. EPA agreed to extend the co~nt period an additional two weeks.
The responsiveness summary is attached to this summary.
-------
-17-
Consistency With Other Envi~~n~~- Laws
The NCP [40 CFR 300.68] establishes the process for determining appropriate
remedial actipns at Superfund sites. As a general rule. EPA will pursue
remedies that meet the standards of applicable or relevant Federal public
health or environmental laws.
Other environmental laws which may be applicable or relevant to the reme-
dial alternatives evaluated in the PFS are the Resource Conservation and
Recovery Act (RCRA) and the Clean Water Act. Since source control at the
Thomas Raymond Road facility is the first operable unit at the Verona Well
Field site, and does not constitute the final remedy, the RCRA 40 CFR Part
264 regulations for closure and ground water protection do not apply.
Final closure of the Thomas Raymond Road site. and the level of ground water
cleanup to be attained by the proposed ground water extraction system will
be evaluated in the final remedy operable unit.
However, the alternatives that include excavation of contaminated soils
(Alternatives S & 6) constitute management of hazardous waste and conse-
quently the technical standards for onsite and offsite landfill design
have been applied.
v
All of the remedial alternatives considered include the extraction of
contaminated ground water from the Thomas Raymond Road site, treatment atj~e
existing Verona air stripper, and discharge to the Battle Creek River. The
Clean Water Act provisions for regulatiny the discharge of wastewaters are
administered by the State through the National pollutant Discharge Elimination
Systeln (NPDES) program. Under that program, the State establishes effluent
discharge limits based on two different criteria: 1) ambient water quality,
and 2) technology. Water quality based effluent limits are derived for
each contaminant by reviewing acute and chronic toxicity data and then
calculating allowable levels in the receiving stream. In addition, for
toxic pollutants. the best available technology economically achievable
(BAT) must be used. For the treatment of VOC-contaminated water air strip-
ping is considered as BAT.
The MONR Toxic Chemical Evaluation Section has evaluated the expected
discharge from the Verona air stripper and has proposed water quality based
effluent limits. The expected initial discharye from the air stripper
would exceed these proposed water quality based effluent limits. Therefore,
during the initial 4-week operating period, a temporary carbon adsorption
system will ~e used to pre-treat the 400 gpm flow from the Thomas Ray~ond
Road ground water extraction system. In this way, the technical requirements
of the Clean Water Act for wastewater discharges will be met, since the
discharge will be treated with BAT, and meet water quality based effluent
limits.
4
The present operation of the Verona air stripper results in an air emission
of VOCs: To control these emissions, a vapor-phase carbon adsorption system
was installed as part of the IRM. Region V1~ Air Managenent Division has
modeled the emissions from the vapor-phase carbon adsorption system for
the present operating conditions, and also after treatment of ground water
from the Thomas Raymond Road facility is begun. The excess cancer risk
-------
- 18 -
presented by the existing air stripper operation is 1.1 x 10-7. After
treatment at the air stripper of ground water pumped from the Thomas Raymond
Road facili~y is started the risk will be 3.7 x 10-7. The risk levels are
considered 'acce~table, and do not re~resent a substantial threat to public
health.
Recommended Alternative
It is the reco~nendation of this docu~ent, based on the evaluation of the
cost and effectiveness of each proposed alternative, the comments received
from the public and the MONR, and State and Federal environmental require-
ments, that Alternative 3, enhanced volatilization be selected as the
cost-effective alternative.
The NCP proposed rule [40 CFR 300.68(i)(1)] states that the appropriate
extent of remedy should be determined by the lead agency's selection of a
cost-effective remedial alternative which effectively mitigates and minil~izes
threats to and ~rov;des adequate protection of public health, welfare and
the environment. The NCP further directs that in selecting the appropriate
extent of remedy, the lead agency should consider cost, technology, reliabi-
lity, administrative and other concerns, and their relevant effects on
public health, welfare and the environment [300.68(i)(2)].
An operable unit, in addition to meeting the requirements of cost-effective-
ness, must also be consistent with a final per~anent remedy [300.68(d)(3)].,
Table 10 provides summary information comparing the alternatives for these
criteria to permit the selection of a "cost-effective alternative" as
defined in the NCP.
.
Although Alternative 3 is not the lowest cost alternative, it provides an
increased measure of environmental protection. Alternative 3, along with
Alternatives 1 and 4 are the only proposed alternatives that actually
remove and treat the contamination from the unsaturated zone; VOCscaptured
on liquid and vapor-phase activated carbon are thermally destroyed during
the regeneration process.
Implementation of Alternative 3 does not require the physical removal of
the contaminated 5011. Consequently, exposure of the public to uncontrolled
VOC emissions in an urban setting, that would occur during implementation
of Alternat1ves 5 and 6 is not a factor.
Alternative 3 does transfer the VOCs from the' soil in a concentrated form
to different media (i.e.. air and water); however, these concentrated waste
streams will be controlled as point source emissions, which can be adequately
treated prior to discharge to the atmosphere and surface water.
Alter~atiYe 3 contains the following groundwater extraction system:
o Installation of nine groundwater extraction wells in the vicinity
of the Thomas Raymond Road facility. The total groundwater pumping
rate would be 400 gpm.
o Installation of an 8-inch diameter transfer pipe with an in-line
booster pump from the extraction wells at Raymond Road to the air
stripper at the Verona Well Field (approximately one mile).
-------
.
'1'8 b 1 e .hl
SUMMARY OF ALTERNATIVES ANALYSIS
'ec:I8letil
Concoem.
1:a.I...-nt.l
.Dd Public
"'.Ub Concen.
1..UtuU..1
IS8U@.
COII.I.tency
.Itb 'Ina' R...ar
alternau..
*
Coat CSI,aDO) ."
Capita' ]-rr
. .
,. GrOWldw.ter "'1., '1,2.' ~ '1,.. ......trated 58811 Inerea.. In S\ilject to .urface Mould contribute
Onl, tecbnolocn dlscb8rge, to ail' "ateI' and all' dls- to Hpal re8ed,
and surface "ateI'. charva atandard,
Continued fU9ltlw.
e.I..lon. froe alt.
I. Cappln, Wltb Ground- 1,5J9 1,73' De8oD.tl'ate4 I,olate. unsatur- See altematl.. I III CJht conf ltct
"ahr P\uiipln9 tecbnolocn. ated tOM contYI- IInai ~cJr
Difficult con- naUon fl'Oll ground-
.tnact Ion. ".tel'. Does not
Require, 10ftIJ- cleanup unsaturated
t.... 0'" tOIle. "-ping
syst.. protect.
groundwater
~ Dlbanc:ed Vol.UU"- 1,111 2,020 lanow.U.. Rt8O¥es cont..lna- See altematl.. , Mould contribute
tlon Nlth Groundwater tecbnolocn. tlon froe unsatu- to f lnal r~.d,
Pu8pln9 Good IIkellbood reted tone. PwIp-
of suc:ce.s In9 SJ.t.. protect.
9roundwater
". SoU ....hl... IIlth 1.506 I,.n I......U.. AftNWes cont..lna- See Altematl.. I Mould contribute
Groundwater Pu8plnt tecbaolocn. Uoa froe unS8tu- to llnal re8ed,
Good UkeUbood reted ton.. Pu8p-
of 8UCCIeS. In9 .,st.. protect.
'Jroundvater
5. £:IIe..aUon to ~.It. 2.110 5,011 o.an.trated All' ..1..I0ft8 dur- See aUemathe ,. 1119ht conflict
Landfill Nltb Ground- tecbDolocn In9 e.ca.atloo. COD- A18O, landfill sub- "ilh final re.4,
"aler Pullplng t..lnent. ar. 1.0- Ject to Jl:U re-
lated (roe ground- quir_nta
.ater, but not 1'8-
.owed (roe alt..
"-Pln9 .,.t- pro-
teet. groundwater
6. £:IIc..atIOll to Off.lte 5,719 J,875 De8on.tntecl All' ..Isslon. dur- s.e Altematlw. I Mould contribute
Disposal NI tb GrouDC1- tecbnolocn In9 e.ea.atIOll. COD- Also. operations to final ~d,
".ler Pu8plnlJ t..lnant. .re re- slbject to lieU
.owed hoe .U. ".ste QeMralor
requlreHftts
.J-,e.r present vorth cost. * 'l11e capital and prescnt w::>rth costs shown for each alternative include the
CYR./Ol~-l for the groundwater plUTping system of Alternative 1. costs
- _0.- - .. ----.-
~
-------
- 19 -
o During the first 4 weeks of operation, an activated carbon system
would be used to pretreat the 400 gpm of initially high concentra-
tion water from Raymond Road, before treatment in the air stripper.
The elements qf unsaturated zone soil treatment follow:
. .
o Installation of eight air extraction wells across the contaminated
. soil zone.
o Installation of a vacuum pump and header piping to evacuate
the wells. The vacuum pump would discharge to a vapor phase
carbon system prior to discharge to the atmosphere.
The recommended action is considered a source control measure as defined
in Section 300.68(e) of the NCP. The objective of the action is to treat
the contaminants in the soil on the Thomas Raymond Road property, and
minimize continued migration of the highly contaminated ground water
surrounding the site.
The capital cost estimate for Alternative 3 is $1,660,000. The annual
operation and maintenance costs for the first two years of operation would
be $90,000. After year two, the annual 0 & M costs would decrease to
$46,000. The length of time that this system will operate will be deter-
mined by the final remedy.
Operation and Maintenance
The operation and maintenance activities required for Alternative 3 are
as follows:
Routine inspection of and readings from the air extraction vacuum pump and
the vapor-phase carbon adsorption system would be necessary. The air
delivered from the air extraction wells to the carbon adsorption system
would be monitored weekly for the first 3 months. Thereafter, monitoring of
the air would be monthly.
The effectiveness of the system would be determined by monthly monitoring of
a permanent soil gas sampling system.
o FaciJity inspection
o Sampling and analysis
$6,000
18,000
o Maintenance
6,000
o Electric power
o Vapor phase carbon replacement
5,000
o D:ganics disposal
Subtotal
30~ Contingency
Total
30,000
4,000
$69,000
21,000
$90,000
The above costs include the 0 & M activities that would be required for the
ground water extraction system.
-------
a.
-20-
The groun~water extraction wells and also the monitoring wells would
require sampling. The Dropose~ sa~pling schedule is shown below:
Sampling Schedule
Period. I. FreQuency * Samples
. Pre-Operati on Twi ce 36
Start-up - 2 Weeks Every 2 days 126
2 Weeks - 2 Months Weekly 1(\8
2 Months - 1st Year ~onthly 162
Year 1 - Completion Quarterly 72
Changes in this schedule mig.,t be made based on the results of the monitoring.
In addition to the water quality sampling, water levels will he measured on
the same frequency at all the wells in the site vicinity.
Superfund response activities can be divided into two phases for the purposes
of determining Fund eligibility: remedial action and post-closure. Only.
costs incurred during the remedial action phase are eligible for funding
under Superfund. The remedial action phase may include activities that
normally are considered operation and maintenance costs, for instance, i~'
cases where construction itself will not result in achieving cleanup goals.
In general, the following criteria have been used to distinguish remedial
actions from post-closure activities:
..
o Remedial actions include measures that control contamination
at or near the source of release,
o Have a definable endpoint based on contaminant levels, and
are of limited duration (usually less than 5 years).
Cleanup with Enhanced Volatilization is expected to be complete within 3
years after the initial contruction is comoleted. T"erefore, based on the
criteria above the capital costs and 0 & M costs can be considered a neces-
sary part.of the remedial action and are eligible for the Fund.
()
Schedule
Approve Remedial Action (sign ROO)
Award Superfund State Contract
for Construction
Complete Desi gn
. Start Construction
Complete Construction
08/09/135
09/16/85 "
09/30/RS
10/14/85
01/14/86
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-21-
Future Actions
The remedial investigations at the Thomas Solvent Raymond Road and Annex
facilities h4ve been completed. A work plan for additional remedial
investigation'activities at the GTRR marshaling yard has been prepared.
Discussions with GTRR will be initiated to determine their willingness to
perform the investigations.
Additional feasibility studies will be completed in a series of operable
units. The next operable unit will address source control at the Thomas
Solvent Annex and the GTRR marshaling yard. After that operable unit is
implemented. the final remedy for the well field itself will be evaluated.
-
.
-------
Community Relations Responsiveness
Verona Well Field
Thomas Solvent Raymond Road
Operable Unit
Summary
I
. .
Introduction
This "Community Relations Responsiveness Summary" documents citizens con-
cerns and issues raised during the public comment period on the phased
feasibility study (PFS) for source control remedial action at the Thomas
Solvent Company.s (Thomas) Raymond Road facility.
Concerns Raised During the Comment Period
The PFS was completed on June 17. 1984. Copies of the PFS were made
available to the community on the same day. A public meeting was held at
the Battle Creek City Hall on July 2. 1984 to present the PFS and solicit
public comment. The public comment period was originally scheduled to
close July 8. 1984. but in response to public comment the deadline was
extended to July 20. 1985.
Approximately 30 residents attended the public meeting. After the Agency's
presentation. 6 attendees asked 4uestions and provided comments regarding-.
the proposed alternatives. The Agency subsequently received 10 written
statements regarding the proposed remedial action alternatives. Written
comments include letters from a public interest group. and several area
residents. The following discussions address the most prevalent concerns
expressed by the commentators. Where similar comments have been received
on the same topic. the comments have been summarized and paraphrased to
identify the specific issue. The intent has been to present the full range
of topics and details of the overall comments without lengthy repetition.
.
Questions and comments offered during the comment period were in two main
categories:
o General comments
o C~ents relating to specific technical issues.
r .
o
GENERAL COMMENTS
Issue:
Length of Public Comment Period
Many of the area residents have stated that a 3-week public comment is an
inadequate time in which to review the phased feasibility study.
1.
Comment: The feasibility report is being presented for public
comment with far too short a period for review. An extension
of the deadline to July 20. 1985 is requested.
-------
-2-
2. Response: There appeared to have been some confusion on the part
of several residents, as to when the public comment had officially
started. A number of residents, in their written comments indicated
that .the time period of July 2 - July 8, 1985 was insufficient. That
part~~ular time period referenced, marks the length of time from
the date of the public meeting to the end of the comment period.
In fact, however, the official comment period had started two weeks
earlier on June 17, 1985.
A public notice, announcing the start of the comment period on June
17, 1985, and also, the locations where reports would be available
for review, appeared as an advertisement in the Battle Creek Enquirer
on June 5, 1985. Also at an informal small group meeting held with
area residents on the night of June 13, 1985, the remedial project
manager indicated to those in attendance that the phased feasibility
study would be available for their review on June 17, 1985.
. '
However, at the request of a resident at the public meeting, U.S.
EPA extended the comment period (from July 8 to July 20) to allow
the public more time to review the phased feasibility study.
Region V EPA follows a procedure for community relations and publi~
involvement that is set forth in federal Superfund guidance. The
National Oil and Hazardous Substance Contingency Plan (NCP), which
contains the regulations for implementing the Superfund law, says-'
"... response personnel should to the extent practicable,... be
sensitive to local community concerns (in accordance with applicable
guidance)." [Subpart F 300.61] The guidance is contained in
"Community Relations in Superfund: A Handbook."
...
According to the guidance, a minimum 3-week public comment period
on the feasibility study must precede the selection of an alter-
native. This guidance applies to all Superfund sites, and was not
applied arbitrarily to the Verona Well Field site.
Issue: Evacuation Plan
A number of area residents have asked about plans for the safety of
re~;dents during the clean-up. .
Conwnent: Has EPA prepared an evacuation plan for relocation of
area resident during the remedial action?
~
Res~onse: The need for an evacuation plan will be addressed
dur1ng preparation of the construction site health and saf~ty
plan. Implementation of the Enhanced Volatization alternative
does not require the physical removal of the contaminated
soil. Construction will be limited to the installation of
ground water and air extraction wells. The necessary connection
piping will be installed below ground. As a result of remedial
action VOCs from the soil will be transferred from the contami-
nated soil to different media (i.e., air and water); however,
these waste streams will be controlled as point source emission,
which can be adequately treated prior to discharge to the
atmosphere and surface water.
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COMMENTS ON SPECIFIC TECHNICAL ISSUES
Iss~e:
I .
Treatment of Excavated Soils
The comment was made that the phased feasibility study did not
ade4uately evaluate technologies for treating (decontaminating)
excavated soils prior to disposal in a landfill.
Comment: Excavation for treatment should not have been eliminated
from consideration in the phased feasibility study.
Response: Technologies for treating excavated soils were considered
in the phased feasibility study during technology screening. The
technologies available for treatment of excavated soils are similar
to those for treatment of soils in-place. In addition, excavated
soils can be thermally treated by incineration.
Generally speaking, the advantages of excavating soils prior to
treatment over in-place treatment are that; 1) treatment takes place
in process equipment, where the environment can be better contr~11ed,
2) better mixing of contaminants and reactive agents can be achieved,
and 3) treatment can be more easily verified. The PFSconsidered
soil washing, drying, chemical degradation, biological degradatlon
and incineration.
.
At many sites, there may be some treatment effectiveness benefits
to washing soils after excavation as opposed to in-place treatment
due to better control of the treatment process. However, for the
homogenous soils at the Thomas Solvent's Raymond Road facility,
in-place treatment will result in a similar degree of contaminant
removal as treatment after excavation. Chemical and biological
. degradation were eliminated from further consideration, because the
breakdown products of the chlorinated hydrocarbons are themselves
toxic compounds.
Comment: A properly run incinerator is not subject to the criticisms
leveled against chemical and biological degradation, namely failure
~o effectively remove contaminants and dangerous after-products.
~ .
Response: Incineration will destroy organic contaminants like
those present in the soils at the Raymond Road site. However,
there is limited off-site incinerator capacity nationwide, for the
treatment of contaminated soils. Considering off-site incinerator
capacities, and scheduling coordination with other users of the
incinerator facilities, off-site incineration of the excavated soil
could be expected to take years to complete.
~
Another consideration ;s the amount of auxiliary fuel required to
incinerate soil. Wastes with a heating value of 4,000 to 5,000
Btu/lb generally do not require additional fuel to sustain
combustion. Since the soils at the site are primarily sands and
gravels, they would provide little combustible material for fueling
incineration. The cost of fuel oil necessary to heat up the soils
and maintain desired incineration temperatures would make this
alternative prohibitively expensive.
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Comment: The PFS gives implicit approval for incineration, since
it is the recycling method used for granular activated carbon.
Response: Incineration of excavation soils varies from the thermal
degradation process used to regenerate activated carbon; the goal,
removal of volatile contaminants is achieved via both methods. The
process of regenerating activated carbon drives off the adsorbed
contaminants which are then treated in an after burner and reacti-
vates the carbon for reuse. This system concentrates and consoli.
dates the contaminants for efficient, timely and cost-effective
destruction, with no end product for disposal.
Soil incineration with the same destruction removal efficiency
requires extremely high temperatures for substantial soil volume,
resulting in much greater energy expenditures and generates waste
material which requires controlled disposal.
Comment: A description of the organic phase liquid observed at
the site would be appropriate.
Res~onse: The separate organic phase liquid was first discovered
on ebruary 10, 1984 during sampling by U.S. EPA of monitoring well
8-18. The major chemical constituents of this organic phase liquid
are as follows:
- .
acetone 2.6 grams/liter
2-butanone 0.5 "
l,2-dichloroethane 1.1 "
1,1,1 trichloroethane 30.7 "
trichloroethylene 44.3 "
tetrachloroethylene 56.2 grams/liter
carbon tetrachloride 0.9 grams/liter
benzene 1.2 "
toluene 48.2 "
ethYl benzene 7.8 "
O-xylene 13.3 "
The organic phase liquid is limited in extent to the area in the
vicinity of monitoring well B-18. Based on the results of vertical
sampling in the area, it appears that the organic phase liquid
originates from a high concentration suspension of the solvents
in the capillary fringe between the unsaturated and saturated zones.
.
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Comment: If VOCs are dangerous in the water, why should they be
less dangerous in the air?
RespQnse: The contaminated groundwater from the Thomas Raymond
Road facility wil1 be pumped from the site to the exiting Verona
air stripper for treatment. The objective of ground water treatment
by air stripping is to transfer the VOCs from the contaminated
groundwater into an air stream. The exiting air stream emissions
from the air stripper will be controlled by a vapor-phase carbon
adsorption system.
The Air Management Division, Region V, EPA has modelled the expected
air emissions from the Verona air stripper after ground water
pumping from Raymond Road begins, and calculated the excess cancer
risk attributable to these emissions. The analysis has assumed
that 90 percent removal of VOCs can be achieved with vapor-phased
carbon adsorption.
In order to establish baseline conditions, the risk from inhalation
due to the current operation of the Verona air stripper was
determined. Based on the expected emission rate from the air
stripper for different periods during the operation of the Thomas
Raymond Road pum~ing system, the air dispersion model calculated
the peak VOC concentration and also the location downwind where.
the peak concentration will occur. The peak risk from the ongoing
air stripping is 1.1 x 10-7 (approximately 1 in 10,000,000) at a
point 160 to 180 meters last of the air stripper. This means that
a person breathing the air at the peak concentration location, for
a 70 year lifetime would have a 1 in 10,000,000 additional risk of
contracting cancer. .
.
The introduction of groundwater from the Thomas Raymond Road site
for treatment at the air stripper represents an additional risk
that must be accounted for.
The concentration of the ground water delivered from the Raymond
Road pumping system can be characterized for three distinct operating
periods: 1) first day's operation, 2) first month's, and 3) after
the first month. The additive peak cancer risks from inhalation of
emissions from the air stripper during these operating periods
were calculated. The estimated peak risk is 2.7 x 10-7 during the
first day, 3.1 x 10-8 for the first month and 2.6 x 10-7 after the
first month until completion of the project.
These calculated health risks are extremely conservative in that,
they assume the ground water concentration for the applicable day
or days would exist for 70 years. The cumulative "average" lifetime
cancer risk has been estimated to be 3.7 x 10-7. As a guideline
.for risk management related to Superfund actions, U.S. EPA has
.determined that excess cancer risks resulting from proposed cleanuQs
should not exceed a 1 x 10-6 (1 in 1,000,000) risk. The 3.7 x 10-7
risk presented by air emissio~s from the Verona air stripper during
the Thomas Raymond Road cleanup are considered acceptable, and do
not represent a substantial threat to public health.
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Comment:
Landfills have been demonstrated not to work.
Response: Transferring waste from one site to another is also a
conc~~n of the U.S. EPA. The most recent policy on offsite land-
fills is meant to assure that future problems will not arise at
such landfills. New landfill cells must be specially constructed
with a double liner and double leachate collection system. affsite
disposal facilities must be checked for compliance with current
U.S. EPA regulations before any Superfund waste can be disposed of
at the facility.
Comparison of the performance of existing landfills to new double-
lined RCRA-permitted facilities is not valid. Until recently.
existing facilities have been accepting high concentrations of
liquid wastes. The 1984 Amendments to RCRA have banned landfilling
of liquid hazardous wastes. Leachate generated at a facility con-
taining these types of liquid wastes may contain elevated concen-
trations of contaminants. Double-lined cells are the state-of-the
-art in landfill design and. with proper cap maintenance. leachate
production is not expected.
Comment: What data already exist concerning the effectiveness of
Aenhanced" volatilization?
-"
.
Response: The enhanced volatilization process has been used suc-
cessfully in a number of hazardous waste applications; however.
long-term experience in a variety of situations is limited. U.S.
EPA recognizes that this process is appropriately classified as
innovative technology. However. this process has been successfully
used to recover vacs from soils contaminated by leaking underground
storage tanks. Terra Vac. Inc.. one of the firms developing this
new technology has reported the recovery of carbon tetrachloride.
methylene chloride. hexane. acetone. methanol and gasoline in appli-
cations in a variety of hydrogeological settings.
It is important to recognize that the cleanup of the Thomas Raymond
Road facility will not rely on the use of enhanced volatilization
as a stand-alone technology. The ground water pump and treat system
wilJ capture and treat the contaminated ground water in the vicinity
of the Raymond Road site. If no further response action were
taken beyond ground water pumping and treatment, the mass of vacs
in the unsaturated zone soils would eventually be removed as a
result of the natural recharge resulting from.normal rainfal'. The
contaminants would be leached into the ground water, where they
would be contained by the ground water extraction system and treated
at the Verona air stripper. However, remedial action for vac
contamination of ground water is a long-term operation. When a
considerable amount of contamination remains in the unsaturated
~zone, continued contaminant transport to the ground water by
percolation will extend the time for cleanup to be achieved. U.S.
EPA is recommending the use of enhanced volatilization in conjunctic
with ground water pumping in an effort to shorten the time for clean
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