United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-86/034
June 1986
Superfund
Record of Decision:
Forest Waste, Ml
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TECHNICAL REPORT DATA
(PletIJe ,ead I"structio"s 0" the ,evene before completi"I)
1. FlEI'OIllT NO. \2. 3. RECIPIENT'S ACCESSION NO.
~PA/ROD/R05-86/034
.. TITLE AND SUBTITLE 5. REPORT DATE
~UPERFUND RECORD OF DECIS ION June 30 1986
Forest Waste, MI &. PERFORMING ORGANIZATION CODE
7. AUTt40RISI 8. PERFORMING ORGANIZATION REPORT NO.
II. I'ERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EI..EMENT NO.
11 :CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
~. S. Environmental Protection Agency Final ROD ReDOr t
401 M Street, S.W. ,.. SPONSORING AGENCY CODE
Washington, D. C. 20460 800/00 -
15. SUPI'LEMENTARY NOTES
1&. A8STRACT
The Forest Waste Disposal Site is located at 8359 East Farrand Road, Otisville,
Michigan, approximately 12 miles northeast of Flint, and approximately 2 miles northwest
of the City of Otisville. The total site area is approximately 112 acres. The site has
a landfill with a surface area of approximately 15 acres, and nine surface impoundments
with a collective surface area of approximately one acre. From 1973 to 1978, the site
received general refuse, industrial and liquid waste, PBBs, ana PCBs. IJrummeO wastes
from various sources were disposed of in the landfill area, and waste oils, metallic
sludge s, paint and resin wastes, and spent sulfuric acid were disposed in the onsite
lagoons. Currently, onsite soils and sediments are contaminated with priority pollutant
.compounds and various organic and heavy metal compounds.
The selected source control remedial alternative includes excavation, treatment and
~~sposal of 4000 yd3 of contaminated sludges, sediments and soils in an offsite
~CRA-permitted landfill, and removal, treatment and disposal of 110,000 gallons of
aqueous lagoon wastes at a RCRA treatment facility. The estimated capital cost for this
remedy is $1,295,000 with no annual O&M costs.
17. KEY WORDS AND DOCUMENT ANALYSIS
Ia. DESCFlIPTOFlS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Forest Waste, MI
Contaminated Media: soil, sediment, gw
~ey contaminants: paint sludges,
waste oils, heavy metals, acids,
PCBs, PBBs, inorganics, VOCs.
'Bo DISTRIBUTION STATEMENT 19. SECURITY CLASS (Tllis R,porr) 21. NO. OF PAGES
None 62
20. SECURITY CLASS (Tllis PilI') 22. PRICE
None
I!'. '01111 2220-1 (R.... .-77)
P"EVIOUS EDITION " 08.01.ETE
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INSTRUCTIONS
1,
REPORT NUMBER
Inserllhe lPA reporl numtK'r as it appears on the coyer of tht public:alion.
LEAVE 8LANK
2.
3,
RICI,.ENTS ACCESSION NUM8ER
Reserved for Use by each reporl re.:ipient,
TITLE AND SU8TITLE
Title should indicate dcarly and briefly Ihe subjfl.'l I:overa,c I)flhc n:port, and be disl'lay~'d prulllin\'nlly, S\'r suhlilk, ifu~~'d, ... ~lIIali~'r
type or otherwise subordinale it 10 main lille. When a rcport is prcpared in mon° Ihan un\' V.,IUIIIC, r\'I"'allhc prilllary hiI.'. a.hl v.,I:.!n",
number and include subtitle for the specific tille,
4.
I.
RIPORT DATE
Each report shall carry a date indicatinlat least monlh' and year, Indkale Ihe hash uu ~'hidl ir "as ....'IC\'I\'d (c'./t.. Jtllc' "J ;$1"C', elG(c' "J'
qproN/, """ 01 pr~ptI",tion, tic.).
,.RFORMING ORGANIZATION COOE
Leave blank.
I.
7.
AUTHORISI
Give namelsl in c.>nvcntional order (John R, Doe, J. Ro/x." Doc'. ('(('./. lisl authur's aUilialluu if il .liff\'rs I'rullllh\' ,,,..rl'ullllina: ."PIII'
ation.
I.
,.RFORMING ORGANIZATION REPORT NUM8ER
Insert if perform in. orpniulion Wishes to ani", IhlS number,
t.
,.RFORMING ORGANIZATION NAME AND ADDRESS
Give name, street, city, state, and ZIP code. lisl no more Ihan Iwo leveb of an ura:anilaliunal hirelirdlY,
10. PROGRAM ELEMENT NUMBER
Use the propam element number under which the report was prepared. Subordinalc numbers ilia)' b.: indu.I~,.IIIII'ar\'lIIh.,....,s.
11. CONTRACT/GRANT NUM8ER
Insert conuact or granl number under which reporl WIIS prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP code,
13. TY'I OF REPORT AND 'IRIOD COVERED
Indicale interim final, etr., and if applicable, dates covered.
14, SPONSORING AGkNCY CODE
Insert appropriate code.
11. SUPPLEMENTARY NOTES
Enter information nOI included elsewhere but useful, such liS:
To be published in, Supersedes, Supplements, eiC.
Prepllfed in cooperalion with, '-""1\1011111" 01, l'rc....'"I.''' OIl ...."".,.,,,,,, of.
11. ABSTRACT
Include a brief (200 words or Itssl factual summary of Ihe mosl sillnilkllnllllformalinn ~'u"laln~'II"1 II", "'1"111. 11111., r"'"1I1 ,'0"101"" a
sipificanl bibliography or lilerature survey, mention II herc.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS. Seleci from Ihe Thcsaurus of t::nginecrinf and Scientific Terllls the pruper authorl"'.1 1"lIn' Ihall.lenlll'y the nlajnr
concepl of Ihe research and are 5ufficiently spe':lfic iind prel:isc 10 tK' USl:.I as In.lc.' enltlc. lur catal"j:I"j!.
(b) IDENTIFIERS AND OPEN.ENDED TERMS. Use idenlifiers for pro)cl:l nam.., .:ude namcs, c4ulpml:nl .lcslj!nalurs, ell:. Us.: "pen.
ended terms wrillen in descriptor form for those subjects for which no dcs.:riplur eAisb.
(c) COSATlI.ILlD GROUP. Held and group IIssiJnments are to be Iilken from the 1965 {'OS"'II Suh,~,.:1 ('al.'!!"ry !.iSI. Sinl:c Ihe nla.
jority of documents are multidisciplinary in nature, the Prim:ary Held/Group iI\Sillnml:nUs) will 01: 'l}Cull<' IIi" Iplinc, ar~'a III' hUlllan
endeavor. or Iype of physical object. The application Is) will be cro»"ct'l:rcnl.'Cd wilh 'II:~'unliary II\'I~I/( illlup assll!lIlIIcllh Ihal \0\'111 1'11110\0\ .
the primary posling(S).
11. DISTRI8UTION STATEMENT
Denote releasability 10 Ihe public or limil:alion for reasons other thlln securily fur uilmple URckas.: I:"hlllll,'d," ( lie allY a.ail..lI.hl)' III
the public, with address ilnd pnl:e. .
11, & 20, SECURITY CLASSIFICATION
DO NOT submil classified reports 10 Ihc Nalional Technicillinformatiun service.
21. NUMBER OF PAGES
Insert the t01l1 number of pages, including Ihis one and unnumbered palle', bUI e"l:lulle IIlslnbuliun Ilsl, II any.
22, 'RICE
Insert Ihe price sel by the Nahonal rechnicallnformahon Service ur Ihe Governmenl Prinllng Office, It knuwn.
I'. ,- 2220-1 IR.., .-77) (R...,..)
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Record of Decision
Operable Unit Alternative Selection
Forest Waste Disposal Site
Genesee County, Michigan
Documents Reviewed
Site:
I am basing my decision on the following documents describing the analysis
of cost-effectiveness of remedial alternatives for the Forest Waste Disposal
Site: .
- Site Lagoons Phased Feasibility Study, Forest Waste Disposal Site,
Otisville, Michigan, CH2M Hill, April 8,1986
- Summary of Remedial Alternative Selection
-
Responsiveness Summary
- Memorandum from Robert B. Schaefer, Regional Counsel and Ba~i1-t.
Constantelos, Director, Waste Management Division, to Valdas V. Adamkus,
Regional Administrator, "Request for Concurrence on the Record of Decision
for an Operable Unit Remedial Measure at the Forest Waste Disposal Site,
Otisville, ~1ichigan", June 27,1986.
Description of Selected Remedy
Excavate, treat, and dispose of offsite, at a Resource Conservation and
Recovery Act (RCRA) permitted, double-lined landfill facility, approxinately
4,000 cubic yards of contaminated sludges, sedimen~, and soil. Remove,
treat, and dispose of offsite, approxi~ately 110,000 gallons of aqueous
lagoon wastes at a RCRA treatment facility.
-
Declarations
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, and the National Contingency Plan (40 CFR Part 300),
. I have determined that excavation, treatment, and offsite disposal at a
RCRA permitted facility of contaminated sludges, sediment, and soil; and
removal, treatment, and offsite disposal at a RCRA treatment facility, of
aqueous lagoon wastes, is a cost-effective source control operable unit
remedial measure and provides adequate protection af public health, welfare,
and the environment. The State of Michigan has been consulted and agrees
with the approved remedy.
I have also determined that the action being taken is consistent with
permanent remedy at the site, and is appropriate ~hen balanced against the
availability of Trust Fund monies for use at other sites.
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-2-
In the event that~ at the time the Forest Waste operable unit is ready for
construction, the cost of transporting the waste to the nearest RCRA disposal
facility in compliance with the Off-Site Policy exceeds the cost estimate
in the Phased-feasibility Study by greater than 50%. I will reconsider
the Record of Decision to determine if the selected alternative still
represents the cost-effective remedy and take appropriate action at that
time. The State of Michigan will be consulted in the event that I reconsider
my decision.
The U.S. Environmental Protection Agency (U. S. EPA) is continuing its
remedial investigation/feasibility study (RI/FS) of the Forest Waste Disposal
Site, to evaluate the nature and extent of contamination at the site. in
order to evaluate potential remedial actions. Following the evaluation of
additional remedial action(s), a Record of Decision will be prepared for
approval of the future remedial action(s).
A;-
---:J;;:; ~; /9 g b
Date
-
..
:..,;. '-....
-
,
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~.!.!at i'y_e~umma r1-
Site Location and Description
The Forest Waste Disposal Site is located at 8359 East Farrand Road.
Otisvi11e. Michigan. The site is in the southeast corner of Section 8.
Forest Township (TN9. R8E). Genesee County. Michigan. as shown in Figure 1.
The site is approximately 12 miles northeast of Flint. and approximately 2
miles northwest of the City of Otisvi11e. A schematic map of the site is
shown in Figure 2.
The total site area is approximately 112 acres. The site has a landfill
with a surface area of approximately 15 acres. and nine surface impound-
ments (hereinafter lagoons) with a collective surface area of approximately
one acre.
~he site is in a sparsely populated area. The area surroundin~ the site is
.about 50 percent agricultural and 50 percent undeveloped. ~n,e'timated 20-
30 households are within a quarte~ mile of the site. ~
The site is generally flat except for slight irregularities in the land
surface where wastes were deposited. Grass and weeds. low shrubs. and a
few scattered trees describe the vegetation at the site. There is a tree
line to the east. north. and west. and cropland to the north and northwest.
A marshy region lies east of the site. Butternut Creek flows past the
southeast corner of the site and continues southwest. discharging into the
Flint River.
Boring logs from residential and groundwater monitoring well installations
indicate approximately 150 feet of drift overlying bedrock in the vicinity
of Forest Waste Disposal. The drift in the area, composed of sand and
gravEl in a clay matrix. is typical of morainal deposits. The ~edrock is
comprised of interbedded sandstone and shale with some limestone and coal.
The boring logs from monitoring/observation well installations indicate
that the site-specific geology consists of a layer of clay with silt. sand.
and some gravel varying from 7 to 13 feet in thi:kness. underlain by a 10 to
20 foot layer of sand with some ~ilt and clay. This sand layer is underlain
by varying amounts of sand. silt. and some gravel in a clay-rich matrix.
The thickness and continuity of these generalized horizons will be better
defined following completion of remedial investigation activities at the
site.
Static groundwater level measurements in shallow monitoring wells onsite
range from 8 to 30 feet (approximate average 17 to 18 feet) below the ground
surface. and indicate that shallow groundwater flow in the area of the
lagoons is toward the east.
-------
I
I
I
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1\"CHIG':-:~"' ;:!J ~ 1
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I.JCIA'~A S c.'1::) I
,
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75
0~.-: :
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--
~'l~':.J Cth,n:.\
FOREST ~,
WASTE SITE-V~
\ L":" r :
-
:~:
~i
..
....~ -~" , ..-.......... t
SCALE iN ~J::~~S
FIGURE 1
LOCATION t..~AP - -
FOREST WASTE CIS '.'.
r ~:: ;.: :. ~. - ..;~.;. -:: . -, . : ~ .
-------
. ----'," ~_..__.. --'-'-'-------- - -.--.---------------..---- --
i I----~
I 1
\ I
\ I
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\ I
\ (
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'J
GENERAL
DIsPOSAL
AREA
ILANDFILLI
>
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a::
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LU
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C
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cfr
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SURFACE
IMPOUNOMEN~
LAGOON NO.1;-~
- ..,J
,--"\
LAGOON NO.2 I J
'- -""
,..."""
, I LAGOON NO.5
'--
,. ....
I I LAGOON NO.8
--
,.. ~ ,--8IIIIrrI
LAGOON NO.3 I \ ,- _I LAGOON NO.7
,-_J ,--,
r -. l- _I LAGOON NO.8
LAGOON NO. . I 'r - - ,
1- J l - - J LAGOON NO. I
.
.
.~
to . ~
APPROXiMATE STUDY
AREA 60UNDARY
c;::J
~~
a
II .
----,~- - --------_..-J \.._----,-----___....J-_I';'---~'--
-- - - - - - - - - - F;;-R~OROAO -- -- - - -...... ,----- - - - -.,\ I'
:~
~
o 300'
. I
SCALE IN FEET
FIGURE 2
SCHEMATIC SITE MAP
FOREST WASTE '='ISPOSAllAGOO~S PFS
-------
.
8-6-75
I I --- OW 35
\ I ( .........
15, I \ .
. I I OW 55
: I GENERAL' e
4-451:' DISPOSAL' LAGOONS
~ II AREA 8 84035
. 8 90, I \ , ' ffi 0 6-45
o 5 84-80
86-651 I e
. I ~ \ 84-1 5 e 86-:
1584-5 ~ " .
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85-2
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I I . 85-90
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., 184-70
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5-651 I
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, II
11,_....
1'- -., 1
II '~.:O N . SHALLOW WE LL
I I 0
I I
I I 0 DEEP WELL
I" FOGE5T
5-35 I \ ! ~
.1__' WASTE 0 100
DISPOSAL het!
---
- --
--
--
---
--
----------"--
- - -- ~------
-------
----.:...-
FIGURE 5 - MONITORING WELL -:
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-2-
Four of the-nine. lagoons still contain liquid (lagoon Nos. 2, 3, 4, and 8).
. Lagoons No.2, No.3, and No.4 have liquid depths of approximately 6
inches. Lagoon No.8 has a liquid depth of approximately 1/2 to I-foot.
The remaining five lagoons are dry or contain only residual sludge. Sludge
thicknesses.in Lagoon Nos. 2 through 9 generally vary between 6 inches and
2 feet, with a common thickness of about 1 foot. The existing topography
in the lagoon area is shown in Figure 3.
In addition to waste disposal, the site was simultaneously used as an
airport. Structural features on the site include an office building,
airplane hangar, and a mobile office trailer used for RI activities, as
well as a concrete runway and a grass runway.
Site' History
Forest Waste Disposal is now closed. It was originally licensed to acccept
general refuse on September 13, 1968. However, the holder of the license,
Ronald Ferguson of Richfield Disposal, never operated the site. An Order
of Determination was issued by the Michigan Depart~lent of Natural Resources
(MDNR) Water Resources Commission on December 21, 1972 to property owners
Walter and Elaine Rix to receive limited types of liquid industrial waste
in accordance with Michigan Act 245, Public Acts of 1929, as amended. :
Subsequently, under Michigan Act 87, P.A. 1965, licenses were Jssued to the
property owners to receive general refuse, and industrial aod"11quid waste
from December 10, 1973 to September 1, 1978. During this time, the landfill
was also granted permission to accept, on occasion, hazardous wastes [i.e.,
polybrominated biphenyls (PBB), polychlorinated biphenyls (PCB)] under MDNR
and Genesee County Health Department (GCHD) supervision. The exact date on
which the Forest Waste Disposal Site began accepting waste is not known,
but it is thought to be no sooner than when the licenses were issued.
In 1974, the facility accepted sludge and residual waste from the Agrico
Chemical Warehouse of Bridgeport, Michigan. Likewise, PCB and PBB were
disposed of at the site in 1975.
In 1975, Mr. Rix died and ownership of the landfill was assumed by
Mrs~ Rix, who currently resides in Florida. The site license was
rev;;ewed for'renewal in 1978; the GCHD did not grant renewal due to
operational and various other violations. As a result, Mrs. Rix was
ordered to properly phase out the site according to the guidelines
established under the Michigan Solid Waste Management Act.
During operation of the site, incoming wastes to the landfill were not
screened by the facility owner. Drummed wastes from various sources,
including Berlin and Farro Incineration, were disposed of in the landfill
a'rea. The waste fill is covered, although refuse and rusty drums are
exposed in some places.
Michigan DNR files indicate the lagoons originally accepted metallic'
sludges, which were to be pretreated before receipt onsite, and acidic and
basic liquids, which were to be neutralized before shipment to the site.
-------
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SCALE IN fEET
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LAGOON NO.8; ';, - .' .,' ,
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-------
-3-
Several type~ of wastes have been documented as being accepted at the site
and are suspected of being disposed of in the onsite lagoons. They are as
follows:
Waste Oils
Plating Waste
Metal Sludges
.Brewery Waste
Sewage Sludge
Resin and Paint
Wastes
Septic Tank Waste
Phosphate-Zinc Wastes
Spent Sulfuric Acid
Caustic Pipe Cleaning Water
Sauerkraut Brine
Fly Ash
Among these wastes suspected of being disposed of in the onsite lagoons are
wastes currently listed in the Resource Conservation and Recovery Act (RCRA)
regulations 40 CFR Part 261 Subpart D as hazardous. Information about.
lagoon waste is not complete enough to determine the specific U.S. Environ-
mental Protection Agency (U.S. EPA) hazardous waste number of the suspected
listed wastes. However, waste such as electroplating waste and spent
sulfuric acid were likely disposed of in the lagoons, and these particular
wastes may be listed wastes. MDNR file information indicates the facility
operator mixed different waste streams in some of the lagoons.
In December 1982, the Forest Waste Disposal Site was proposed for inclusi~n
on the Superfund National Priorities List (NPL). On September,g, 1983, the
site was listed as final on the NPL. . ~ ,."
In January 1984, a Remedial Action Master Plan (RAMP) for the Forest Waste
Disposal Site was completed by U.S. EPA contractors. Th~ RAMP 1s a plan
for undertaking Remedial Investigation (RI) activities and identifying
appropriate initial remedial actions at a site.
On March 7. 1984, the U.S. EPA issued a unilateral consent order. pursuant
to the Comprehensive Environmental Response Compensation and Liability Act
(CERCLA) 106, 42 U.S.C. 9606, to Mrs. Elaine Rix. instructing her as owner
of the site to construct a fence around the perimeter of the contaminated
areas of the site as an initial remedial measure. In response to the
order, Mr. David Newland, attorney for Mrs. Elaine Rix, stated that the
owner did not possess sufficient funds to complete construction of the
fence.
In Summer of 1984, a fence surrounding the site was installed by the U.S.
EPA Superfund Environmental Services Division, Spill Response Section. The
fence was constructed as an initial remedial measure, to alleviate the
public health threat posed by the presence of hazardous materials on site.
To date, this has been the only response action taken at the site.
In Fall of 1984, RI field work commenced at the site.
field activities is targeted for Fall, 1986.
Current Site Status
Completion of RI
Pertinent information about the nature and extent of contamination within
and surrounding the site lagoons includes:
1) analytical results from lagoon samples collected and
analyzed by MDNR in 1978 and 1979 following site closure
(see Tables 1 and 2).
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Table 2
ANAL YTICAL RESIIL TS OF SURFACE IMPOUNDHENT SAMPLINf;
AT FOREST WASTE DISPOSAL
PCB Isomer SI #1* 51 #2* SI !l3*
Aroclor - 1260 (ug/L) KO.1 K1.5 KO.l
Aroclor - 1254 (ug/L) KO.l K1.5 KO.l
Aroclor - 1242 (ug/L) KO.l 37 KO.1
K = less than
*Identity of surface impoundments
Hazardous Material Control, MDNR,
Environmental Lab.
sampled is unknown. Sampled by Oil and
on 9-18-79; Anaysis by the MDNR
:.,;. ... ~ ...
-
,
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-4-
-
2) analytical results from additional lagoon sludge and water
samples collected by MDNR and U.S. EPA in 1983 (see
Tables 3 and 4). and
3) analytical results from U.S. EPA Superfund RI activities.
RI field activities addressing the lagoons were completed during October
1984. Activities included collecting aqueous lagoon samples. lagoon sludge.
sediment, and soil samples. and an oil sample from lagoon No. 8's water
surface.
Samples collected and analyzed in initial RI activities include:
o Composite sediment samples from lagoon Nos. 2, 3. and 4.
A grab sediment sample from lagoon No.8
o
Aqueous lagoon grab samples from lagoon Nos. 2, 4, and 8
o An oil sample from above the aqueous layer in lagoon No.8
o
Composite soil samples from dry lagoon Nos. 1, 5, 6, 7. and 9
-
Additional RI activities were conducted during the Summer ~t '985. These
included sampling of surface soils from areas considered. to represent
background conditions. These samples locations are shown in Figure 4.
Analysis of the samples collected during the RI indicates the presence of
several priority pollutant compounds in the aqueous lagoon samples and the
lagoon sediment samples. Results of these analyses are presented in Tables
5 through 9. For comparison. inorganic constituent concentrations reported
in the background surface soil samples are presented in Table 10. Priority
pollutant organic compounds were not detected in these soil samples.
Organic compounds detected in the aqueous samples include trans-l. 2-dichlo-
roethene. methylene chloride. 2.4-dimethy1 phenol. isophorone. and several
phthalate compounds. Inorganics detected incluc2 antimony. arsenic. barium.
and ~inc.
Analysis of soil samples from the dry lagoons did not detect organic priority
. pollutant contamination. Results from organic analysis of sediment samples
are questionable based on quality assurance/quality control review comments
regarding the useability of these laboratory data. The organic lagoon
sediment sample data, therefore, are not emphas~~ed ~n the public hea1th
evaluation of the site lagoons. Inorganics reported at relatively high
concentrations in both sediment and soil include antimony. barium. chromium,
lead, nickel and zinc.
The Forest Waste Disposal Remedial Investigatio~ (RI) is not yet complete
and the extent of site contamination is not yet fully defined. RI data to
date, however, indicate that the lagoon wastes are a source of contamination
.to the underlying groundwater. Low level amounts of volatile organic
compounds have been detected in the shallow aquifer underlying the lagoons
(see Table 11). Figure 5 illustrates the locations of the monitoring
wells.
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F.~ Tu.lelty
T~.t 11....118 (011111)
Araentc
ft.r 1U8
(:.d.1u8
Chn»ha
I.eod "
ttel"cury
5denlU8
51 her
O..anle "nalyala
~.ulu ('III/I)
1,1,1 ... Trichloroethane
Trlehluruethene
Tet r8chluroethene
kOlfne
Ethylbenzene
Toluene
Xylene
5t y rene
BII n-ethyl huyJ) Phthalate
DI-n-Oetyl Phthalate
Butyl Benzyl Phthalate
.
RCIIA relulatlooa, 100 en Part 261.
aaar.ctert8llc
a
01 lP To.le ItI
S.O
100.0
1.0
S.O
S.O
0.2
1.0
S.O
NOTES:
BlanIL apaee Indlcatee a_pia not ...eIY&8d.
Indlcetee coapound ...alyz&4 'or but not detected.
Indlcatea the coapound ..a detected at a concentration
I[
fal>le
I.A(~" '" SLUDer: ,,"II 0 I.
SAJt\'U.S C:UI.U!t.'"f.O BY II.S.
',.
..LE IIt:~;III.T~
V.I'" AllII HIJIIR, 190)
Sludge Sa"'l'led F....
I..Roon No.
..!.. 2... ) ~ ~
I/o
~
'. .
""J I. I/o
. ;'2.S 11.6
2S
110
26
)00
9100
1,600
S,/oOO
S,OOO
Ie.. then tha qll8RUUcetloo 1I.lt aheM>.
., . -
~
2.20
6
Oil Sampled
.~rum ".Ruun
No. K
110,000
180,000
/08,0001(
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Table 4
AQUEOUS LAGOON SAMPLES
COLLECTED BY U.S. EPA AND MONR, 1983
...t,
Inorganic
Compounds (mg/L) Lagoon No. 2 l.agoon No.4 Lagoon No.8 Blank
Aluminum NO 1,000 400 ND
Antimony 39 29 28 NO
Arsenic 15 15 210 NI>
B.n 1um 320 300 NO NO
lIoron 200 Nt) , 340 NO
<;hromium NO Nt) 12 NO
Iron 10,000 2,600 3,500 770
Lead 25 25 25 450
Mang,mese 450 76 260 NO
Zinc 1,300 13 13 110
Nil - Indicates not detected.
,~ .
'., .
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-------
----
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-
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-- -
GENERAL
D I &f'OIA L
AREA
(LANDFILLI
"
""
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" -
~~ \I
'\~ U
~~ n
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~
\\
\\
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--- -'.-'------
SL.OC4
8i
-
SL003 .
!
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I'~"---~'--
-_-J"--- ---" .,.
~ ------- ---- II
...J ... - - - - - - '-\ ,- -
II -_.".~-- - ----
- - _J' - - = = -=.,-- - - -F-ARAAND ROAD
- --
----
@
300'
o I
.
SCALI!. IN FEn
L.;:"::::-ND
. ::~vJ1
SURFACE
I MPO UN OMEN TS
r--.
LAGOON NO.1, J
.... -' ,.. --. 8
1 ILAGooN NO.
,--" ;~
LAGOON NO. 2 I J I I LAGoo,. NO. .
t.--", .....~
,.. --. ~-) LAGOON NO, 7
031 \ ,_-
LAGOON N. '- _J r- -, LAGOON NO. .
,.--- l__'
LAGOON No..' I r --] LAGOON NO.'
I_J l_-
SL.01S.
. ...... ~
. "
APPROXIMATE STUDY
AREA BOUNDARV
o SL.O,4
CJ
~ c:::::J
OCATION
SOIL SAMPL.E L.
~~GC~~ER6uND SOl L SAMPLE
LOCATION MAP. --"'\' < =
.<;rc: ::>t
-------
T.hle 5
ORCA" I C
AQlIF.O\l5 I....GOON RF.5IJl.T5
LACOO" "0. I 2 " " R
Sample l.tIc.tlan: U:J'O'lOl LCI()I,Ol 1£10',01 n LeIOBOl Le'J5101 SVCl~102
UIlI Number: F.RRSO ERRS2 ERBS" EB6S6 EA6~R F.ACl01
Orgenlc Compounde (ug/I)
V"lat \1".
Trnn~-I,2-Dlchloroethene ~O J
Helhyh'ne L1>lorlde SIt 50 J 1,000 J 5 J 5 J
Aretooe 1"0 B ISO n 6,000 B 170 10 J
1-lIutonone
T"tal Volelllee 2'''' 200 7,000 170 52 5
Adds
1 ,"-Dlmelh,lphenol "0 J
!lenzolc Ac Id 100 J
Toul Add8 "0 ° 100 0 ° 0 ~
B8ne/Helluel..
hophorone 10 J
111'( 1-elhylhe"yl )phth.lele 10 J 10 J
III-n-blllyl phthelote 100 J 10 J 10 J
Plelhyl phth.lete "0 J 10 J 1,1
Tr.t 0 I n/"a t.() ''0 0 100 60 61
Hm'IfTTF.5:
J: Indlcstu an ".tl.eted value (c","po"nd detected helow quantlflc.tlon limit)
0: Analyle haa been 'ollnd In the loborolory blank 88 _II aa Ihe aallple.
IndIcate.. p08elble conta.lnatlon.
1I(1I"f.: S.lIple.. LCQSl01 and 5W'JS102 ere field blenka.
All 01'8enlc compound. on the 1I5r. h..ve "een anelyzed for. . .
nlank apnces Indlcale Ihe compo"nd vn~ not found '01' Ihal anmple. '.
* Hazardous Substance List I ~. .
. '., I
-------
:able 6
AQUEOUS ~GOON INORGANICS
UGOON NO:
Sample Location:
ITR NUI:lber:
2
LG10201
ME2732
l.
LG10l001
tiE2733
l.
LG10l00lD
ME2734
8
LG10801
ME2735
LG95101
ME ~ 7 36
SW95102
~2745
Inorganic
Compounds (UR!l)
Aluminum
Antimony
Arsenic
Barium
Iron
Lead
Manganese
Zinc
873 1oJ.5 126
22
10.3
300 316 246 116
1,138 705 385 636 165 15
10
300 71 60 142
966 610 34 1,760 11 11
NOTE:
Sample Sw95102 and LG95101 are field blanks.
All inorganic compounds on the HS~have been analyzed for.
Blank spaces indicate the compound va. not found for that sample.
Lead and cyanide data vere unusable.
* Hazardous Substance Li st
-
.
.,.
'\ - 4
;
-------
Table 7
LAGOON SEDl~l~ INORG~lCS
LAGOO:-i NO: 2 3 4 8 8
Sample Location: SD10201 SD10301 SD10401 SD10801 SDI080lD SD95202
IIR Number: ME2764 ME2763 ME2762 1'.£2765 1"J:2767 1"J:2766
Inorganic Compounds
(mg/kg dry weight)
Aluminum 3,930 4,370 25,200 9,570 8,450 204
An :.1J:Iony 101 5.1 13 1.7 1.8
Arsenic 6 11 23 20 26 1
Bariw: 8,210 792 6,190 97 180
Ber)"1l1w: 0.43 0.32
Cadmium 0.46 1.4 0.8 0.089 0.065 0.14
Chromium 1,210 102 550 12 22 S..9
Cobalt 13 7.9 13 7.3 6 -
~
Copper 61 275 116 13 14
Iron 11,000 28,300 15,400 17,200 ' 17~aOO 325
.~.
Lead 4,770 364 1,270 37 59
Cyanide 0.65
Manganese 108 612 200 226 170 5.7
tHckel 58 2,500 44 14 14 4.9
Selenium 0.21 1.2 0.29 0.15 0.12
Silver 0.72 0.6
Tin 50 5.9 1.8 1.3 12
Vanadium 14 14 20 18 14
Zinc 12,iOO 459 1,380 88 177 - ,
I. -
;
NO'l'E: Sample SD95202 is a field blank.
All inorganic compounds on the HS~have been anal::ed for.
Blank spaces indicate the co~pound was not found f2r that sa~ple.
* Hazardous Substance List
-------
Table 8
ORGANIC SOIL RESULTS
-
Lagoon So.:
Sa..::rp Ie S\II:Iber:
O'!R Su:nber:
units:
7
SLl0701
£8925
ug/kg
9
SLlC901
£8926
ug/kg
SL950001
£8814
ug/kg
SL95002
£8927
ug/kg
Organic
Compounds
Volatile
2 J
58 B
U8
38
It J
5 B,J
41 B
7 B
Benzene
~ethylene chloride
Acetone
2-Butanone
It-Methyl-2-Pentanone
1, 1, 1-Trichloroethane
60 B
4 J
Base/Neutral and Acid
Compounds
B1s(2-Ethylhexyl)pbthalate
D1-n-butyl phthalate.
Fluoranthene
Py-rene
Chrvsene
Benzo(b)!~uoranthene
Benzo(k)fluoranthene
Benzo(a)anthracene
Benzo(a)PYTene
Indeno(l,2,3-cd)pyrene
D1benzo(a,h)anthracene
Benzo(g,h,i)perylene
Butylbenzylphthalate
88 J,B
2,100 J
140 J,B
93 J
180
330
530 B
500
-
.
.,.
,- .
Samp I e SU::!be r:
on NU::!ber:
i.!nits:
SLl0701
£8932
ug/ltg
SL10901
£8933
ug/kg
SL9S0001
£8815
ug/kg
St9S002
£89310
ug/ka
Pesticide/PCBs/PBBI
!Jieldr1'n
£ndosul!an
4,4-DDI
1o,Io-DDE
sulfate
PBBs
~O"I!s:
J: Indicates an est~ted value (compound detected belo~ ~uantif1cation l~it)
B: Analyte haa ~een found in the laboratory blank as well as the sample.
Indicate. poI.ible contamination.
SOTE:
Samples LG9S101 and SW9S102 are lield blankl.
All organic COQPo~~da en the HSL have been analyzed fer.
Blank spaces indicate the compound ~8S not fc~d for that
* Hazardous Substance List
sample.
-------
,
Tal>l. 9
lNOllr.ANIC SOIL Rt:SIIlTS
teRn,," "0.: I 1 S 6 J 'I
~nmp I. NtD8""- r : SL'l5000 I 5L'15002 51.10101 51.1010lD 51.10\01 SLI 0601 SLI 0701 S\.IoqOI
Ill! II...."".: 11[2115 HEl161 HF.7H\ HF.2251> HEl1H II[ 1758 11£77\'1 MY "~o
1111 It !' : ",,/10.11 '"II'''' ...,. "'8/"8 818/"11 ../"8 88"" ../"8 ../~II
Inu'R8nlc ~
Com f\und!t
AllIllltnua 205 1'15 10, Joo 9,\80 B,ISO J,OIO 10,8100 11,100
~nt ..onny 1.9 2.J 1.'1 J.I 78 . 2. 7
Arq..nt~ 0.8 0.'110 JO 21 n 21> 1J 1)\
Bar I"'" 5.1> S.S 51 SJ 50 1,1090 ',080 H
\\,500 1,1'10 15
Cnl.. It 7. \ 11.1 J.8 102 IS 8
(:nprrr 1.\ 2'1 20 446 II) H
Ir(to J07 JlO 18,100 1",200 20,700 1,170 11 , JOO 71 . ~oo
I...nd 6.2 6.5 IS J,010 5,170 16
Cyan'"'' 1.7 0.74 711
H3n«"nrri~ 5.4 S.II J58 J7J 1004 277 212 J57
ttrr('ury 0.4" 0."4
IIlcbl '1.1 10.'1 11 18 IS 1,\60 104 111
Splrollsm 0.11 0.62 0.\19' D.JI> 0.8" 0.17 O. ~
~; II Vl'r 1.5 0.1>8
Thn III... J. J 12 1.6 2.6
Tin 6.2 2.2 J.I>
~.n.dl"'" I' 14 21 :71 20 24
71ne } 4.S 41> I., 51 2,6"0 18,400 110
*
III.rr:;: ~\1 h1O'~"ntc ('o'"rfJ"nt1~ In rh~ n~.. hnvr. 1.p.,." IInn1Y7f'" (or.
Only ronltlvp ,..""lt8 .r. '''rortf'd. Immd In that ....pl..
81,."k !:rftr"" Inf11cate thf! c"",pound wal ont
* Hazardous Substance List
\~ '
,
'.. .
..' r". I
-------
-
Table 10
lNORCAtiIC CC:-;STITL'ENT CC'SC::::TRATIONS
IN BACKGRO~~D SOIL S~~PLES COLLECTION AlGuST 1985
-
. I\EPORIED
Sa...-ple Location: SL001 SL003 SL004 SL014 SL01S
Inorganic
Co::pounds Concentrations
(~g/kg) ~!.3.;{ic:um M in iJ::um
Aluminum 3,230 2,130 2,760 2 , 710 3,450 3,450 2,130
Anti:::ony
Arsenic 4 1.8 4
Baricm 36 54 36 30 34 54 30
Beryllium 0.26 0.26
Cadmium
Calcium 2,000 413 753 575 717 2,000 413
Chromicm 7.7 4.6 3.7 6.1 7.7
Cobalt 4.8 3.8 2.2 5.5 .5.5 -
Copper 10 5.1 6.2 4.7 7.3 . ,~'.10 4.7
Iron 8,000 5,700 5,960 4,630 8,040 '.' 8,040 4,630
Lead 18 8.2 8.3 6.4 7.9 18 6.4
~.agne s icm 1,060 265 658 449 958 1,060 265
~.anganese 322 1,010 429 290 368 1,010 290
~ercury
Sickel 4.2 4.8 4.1 6.3 6.3
Potassi1:Jll 694 694
Silver 1.9 2.4 2.4
Scdit;!ll 1,900 1,360 1,900
'.anadi1.:l:) 7 11 5.6 8 6.2 13 13 5.6
Zinc . 38 l'~~ 36 23 32 106 23
NOTE:
All concentrations reported ir. ':e r:',g.
Blank spaces indicate cet::pcun'~ ': ': ,j",tected.
Sar.:ple locations used to est1=c:~;; ~.::~ground
are shown in Figure 4.
concentrations
-------
-
Table 11
Summary of Volatile Organic Compound (VOC)
Contamination in Groundwater Samples
VOC Contaminant
Monitoring Well
I I
OW-3S
MW85-1S
MW85-2S
3.4, 8.9
2- Butanone
\
8J, 2.6 J
l,l-Dichloroethane
Trans - l,2-Dichloroethane
3.4 J
29
100
l,l,l-Tricholoroethane
130
Toluene
30, 9
Notes:
All concentrations in ug/liter.
Data generated during 1985 RI activities
J indicates an estimated value (compound detected below
quantification limit).
~
MW84-4S
68 J
:" ... - ..
I i
MW84-2SI
22 J \.
I
I
\
\
\ -,-
\
I
!
I .
-------
-5-
Threat to Public Health
In order to assess the human health threat posed by the site contaminants,
carcinogenic~otency factors (CPF) and acceptable daily intake (AD!) values
were evaluated. These values were obtained from various U.S. EPA offices
such as the Office of Emergency and Remedial Response, the Environmental
Criteria and Assessment Office, and the Carcinogen Assessment Group. The
values were then utilized in two different exposure scenarios: a resi-
dential scenario and a recreational scenario. The residential scenario
presents more frequent human exposure to site contaminants than the recre-
ational scenario.
The AD! and CPF values were used assuming different ingestion rate values
of contaminated lagoon sediments/soils for adults and children in the
residential and recreational scenarios. An ingestion rate of 0.1 g/day was
assumed for a 70 kg adult. Ingestion rates of 0.1 g/day, 1.0 g/day and
10 g/day were assumed for a 10 kg child.
Three of the chemicals found in the Forest Waste Site lagoons are suspected
or proven human carcinogens (trichloroethene, tetrachloroethene, and benzene).
For each identified carcinogen, an excess lifetime cancer risk is calculated.
Excess lifetime cancer risk is defined as the incremental increase in the~
probability of developing cancer compared to the background.p~~bability .
(i.e., if no exposure to site contaminants occurred). For ~ample, a 10-6
excess lifetime cancer risk would "r.epresent the risk resulting from an
exposure that is associated with an increase in cancer incidence by one
case per million people exposed.
Cancer risks under the residential and recreational scenarios were derived
based on conservative assumptions regarding sediment intake. The residential
scenario assumes frequent exposure to the sediments throughout a lifetime and
for a 10 kg child. Lifetime average sediment ingestion rate is estimated for
70 year lifetime. Sediment exposure is assumed seven days per week, six
months per year.
The recreational scenario assumes intermittent exposure to the sediments
for a 10 kg child and for a 70 kg adult. Sediment exposure is assumed two
days:per week~ 6 months per year.
The organic analysis data, generated by MDNR in 1983, from lagoon No.2
for the three carcinogens, was used to derive excess lifetime cancer risk
values. This represents the highest concentrations of carcinogens detected
in lagoon sediments.
Under the residential scenario, the excess lifetime cancer risk from exposure
to carcinogens ranges from 2 x 10-7 to 5 x 10-8. Under the recreational
scenario, the excess lifetime cancer risk from exposure to these carcinogens
ranges from 6 x 10-10 to 1 x 10-9.
The Agency currently uses a risk of cine in one million (10-6) as a target
acceptable level of risk for water supply sources. This target risk level
is not exceeded using worst case generated data by the waste source in the
Forest Waste Lagoons.
-------
-6-
-
For chemicals not considered carcinogens. estimated daily intakes of contami-
nants are compared to acceptable intakes (maximum dose tolerated) esta-
blished for each chemical. Acceptable intakes have been developed for
chronic exposure (AIC) and for subchronic exposure (AIS). The AIC is an
estimate of exposure level which would not be expected to cause adverse
effects when exposure occurs for a significant portion of the lifespan.
assumed to be 70 years. AIS is an estimate of an exposure level which
would not be expected to cause adverse effects when exposure occurs during
a limited time interval (i.e., for an interval which does not constitute a
significant portion of the lifespan-lO to 90 days). The acceptable
intakes can be expressed for a 70 kg adult or a 10 kg child. These serve
as measures of the potential for toxic effects and are consistent with U.S.
EPA guidelines.
Because exposure to lagoon wastes would be intermittent under a recreational
use of the site, the daily intakes were compared to subchronic intakes
(AIS) under the recreational scenario for children and adults. Table 12
presents a summary of the chemicals which exceed the AIS for a 70 kg adult
for each lagoon. Table 13 presents a summary of the" chemicals which exceed
the AIS for a 10 kg child for each lagoon.
.
lJ.nder a residential use of the site, human exposure to lagoon wastes would
likely be more consistent and constant than exposure under a:~etreational
use of the site. The daily intakes. therefore, under the " residential scenario
for both children and adults, were compared to the chronic acceptable intakes
(AIC). Table 14 presents a summary of chemicals which exceed the AlC for a
70 kg adult for each lagoon. Table 15 presents a summary of the chemicals
which exceed the AIC for a 10 kg child for each lagoon.
The public health threat due to the noncarcinogens in the lagoo~s
at the Forest Waste Disposal Site can then be summarized as follows:
o
If the site is used for recreatlonal purposes, protection of the
public health against toxicity of noncarcinogens, as measured by
comparison of projected contaminant intak~ to acceptable intakes,
would be a concern, especially for children. Lagoons Nos. 2, 3,
4, 6, "7, and 8 appear to be of greatest concern due to levels of
metals found in the sediment.
o
If the site is used for residential purposes, protection of the
public health against toxicity of noncarc~nogens, as measured by
comparison of projected contaminant intake to acceptable intake,
would be a concern, especially for childre1. Lagoons Nos. 2, 3,
4,6, 7. and 8 are of greatest concern due to levels of metals
found in the sediment.
-------
Table 12
-
FOREST WASTE:
RECREATIONAL USE SUMMARY
Com arison
Intake
Chemicals Which Exceed the
lagoon Subchronic Acceptable Intake at 0.1 g/Day
1 None
2 Lead
3 None
4 lead
-
5 None
. ". -..
. .
6 Chromium (+6). lead
7 Lead
8 Lead
9 None
-
,
-------
FOKt:SI WASTE:
1'able 13
--RECIU::ATIONAL USE SUHHARY
Com arl~on of Dail
.... t.
Inlake t.o Acce t.able Intake Subchrontc (10 k
Child)
lagoon
0.1 gldaY.
None
2
Barium, Lead
)
Lead, Nickel
4
Barium, Lead
s
None
6
Chromium (+6), Lead
7
Barlum, Lead
8
Lead
9
None
Chemicals Which Exceed the Subchronlc Acce table Intake at:
1. 0 g/day
. 10 glday
None
Barium, Lead
Antimony, Barium,
Chromium (+6), Lead, Zinc
Antimony, Barlum, Cadmium
Qlromlum (+6), Copper, Lead, Nickel,
Zinc
Barium, Lead, Nickel
Antlolony, Barium, Cadmium,
Chromium (+6), Copper, Lead,
Nickel, Zinc
~tanganese
Barlum, Chromium (~6), Lead
Antimony, Barium, Cadmium,
Chromium (+6), Copper, Lead, Nickel,
Zinc
Lead
Lead
Jla rlum , Chromium (+6),
Copper, Lead, Nickel, Zinc
Barium, Cadmium, Chromium (+) and +6).
Copper, Lead, Nickel, Silver, Zinc
Antimony, Barium, lbromium (+6),
Lead, Zinc
Antimony, Barium, Cadmium,
Chromium (+6), Copper, Lead,
Zinc
Nickel ,
Lead
Barium, Lead
,~ .
,
,"'. .
Barium, Be,-yillum, Lead,
Cyanide
Lead
. It"-
. I
-------
Lagoon
1
2
3
4
5.
6
7
8
9
-
Table 14
..
FOREST WASTE: - RESIDENTIAL USE SUMMARY
Comparison of Daily Intake to Acceptable Intake
Chronic (70 kg Adult)
Chemicals Which Exceed the
Subchronic Acceptable Intake at 0.1 g/Day
None
Lead
None
Lead
None
Chromium (+6), L.ead~' ..,
.
Lead
None
None
-
,
-------
~'ORESl' WASTE:
Table 15
.-RESIUENTIAL USE SUMMARY
Intake to Acce tahle Intake Chronic (10 k
Child)
Lagoon
0.1 g/day
Chemicals Which Exc~ed the C11ronlc Acce table Intake at D811
1.0 g/day
of:
10 gidDY
None
None
Barium, Chromium (+6), Lead, tlang~nese
2
Barium, C11romlum (+6).
Lead
Antimony, lIarium,
Chromium (+6). Lead, Zinc
Antimony, Barium, Cadmium
Chromium (+e,), Copper, Lcad, Z Ine
]
Lead,
Barium, Chromium (+6). Lead. Nickel
Antimony, narLum, Cadmium,
(''hroDllum (+6), Copper. Lead,
NLckel, Zinc
Hanganes(',
4
Barium, Chromium (+6). Lead
Barium. Chromlulu (+6). Lead
Antimony, (llIrlum, Cadmium,
Chromium ("6). Copper,Leml, Zinc
s
None
Lead
BarLuD1. Beryllium, Chromium (+6),
Lead. Manganese
(,
Chromium (+6), I.ead
Barium, ChromLum (+3 and +6).
Copper. Lead. Nickel. Zinc
Barium.
Copper.
SLIver.
Cadmium, C11romlum (+3 and +6),
Le;}J, tlanganese, Nickel,
Zinc
"
Antimony. BarLum. Cadmium,
Chromium (+6). Copper, Lead,
Zinc
NIckel,
1
Barium. C11romlum (+6). Lead
Antimony, 8arium. Chromium (+6).
Lead. Zinc
I". .
Barium. Chromium (+6), Lead
II
Lead
Lead
9
None
Lead
88r1\lIn, Beryllium, tead,
Chromium (+6). tead. Man~ancse,
Cyanide
, 0'"
-------
-8-
-
Ten alternatives for remediation of the lagoons solids were assembled using
appropriate remedial technologies. Four alternatives for remediation of
the lagoon liquids were assembled using appropriate technologies. These
two groups of alternatives were evaluated separately, in terms of technical
implementability, public health and environmental protection, and compati-
bility with the final remedy. A summary of this evaluation is presented in
Tables 16a and 16b.
Three alternatives for remediation of lagoon solids, and one alternative
for remediation of lagoon liquids were advanced for detailed analysis
and further screening. The one advanced alternative for remediation of
lagoon liquids was combined with each of the three advanced alternatives
for remediation of the lagoon solids.
Treatment and discharge at an offsite RCRA-permitted treatment facility
was the alternative for remediation of the lagoon liquids which was advanced.
This alternative will attain relevant and applicable environmental standards.
This is the only alternative which can be implemented quickly and easily.
All other alternatives have institutional and/or practical concerns which
may prohibit or delay timely implementation of the alternative.
Treatment and discharge of liquids at Publicly Owned Treatment'Works (POTW)
may be impossible to implement because a POTW which would ~. wj~ling to
accept the waste may not be available. Onsite treatment. and surface water
discharge would be difficult and impractical to implement for such a small
quantity of waste. Direct discharge to surface water may be undesirable for
implementation because applicable and relevant discharge standards may not
be attainable.
Each of the three assembled alternatives are described below.
Alternative 1.
Excavation, Treatment, and Offsite Disposal
All contaminated sludges and sediment from lagoon Nos. 2,3,4,6,7, and 8
would be excavated, treated onsite (solidified), and disposed of offsite at
a RCRA-permitted facility. Lagoon Nos. 1, 5, and 9 would receive no action.
AqueOus lagoqn wastes would be removed, then treated and disposed of offsite
at a RCRA-permitted facility. The total depth of waste in the lagoons is
shallow (maximum of 3 feet), therefore, the lagoons will not require back-
filling. .
This alternative is an offsite measure whic~ uses a RCRA facility.
alternative attains applicable Federal public health standards.
This
Alternative 2.
Excavation, Treatment, Replacement, Low-permeability Cap
All contaminated sludges and sediment from the lagoon Nos. 2, 3, 4, 6, 7,
and 8 would be excavated and treated. Lagoons Nos. 1, 5, and 9 would.
receive no action. The treatment would involve precipitation and solidi-
fication by mi~ing appropriate amounts of limestone (CaC03) or calcium
hydroxide (Ca(OH)2)' portland cement, and flyash to the contaminated solids,
as they are being excavated. The liming would ~aintain alkaline conditions
and serve to kee~ the metals in the waste precipitated.
-------
-7-
Based on information presented above, and consideration of inorganic compound
concentrations in lagoon sludges, sediments and soil, relative to values
reported in background soil samples, 0.1 gram/day of soil is considered an
appropriate ingestion rate to determine a level of cleanup for the Forest
Waste Disposal Site lagoons to adequately protect public health. Considering
the 0.1 gram/day ingestion rate, lagoon Nos. 2, 3, 4, 6, 7, and 8 have
exposed sludges, sediment, and soil with metals concentrations that would
exceed subchronic and chronic acceptable intakes if ingested under recrea-
tional or residential scenarios. Sludges, sediment, and soil from lagoon
Nos. 2, 3, 4, 6, 7, and 8 are, therefore, the materials from the lagoons
which will be addressed in the selected operable unit remedial action.
As mentioned in the "Current Site Status" section above, there is a known
release of volatile organic compounds from the lagoon waste to the groundwater.
The groundwater in the area serves as a drinking water source to surrounding
residents. Residents are currently using deeper separate aquifers as their
drinking water sources. The lagoon wastes, nonetheless, present an actual
and potential further threat to public health and the environment relative
to their connection to the groundwater. .
Enforcement Analysis
-
Twelve Potentially Responsible Parties (PRPs) were noticed to ~~dertake the
operable unit remedy. Eight of the twelve expressed interest in negotiating
a settlement. These eight partie~.were forwarded a copy ~f the PFS on
April 14, 1986. A draft Administrative Order on Consent ~as mailed to the
PRPs on April 23, 1986.
The intia1 negotiations meeting took place April 28, 1986 at the U.S. EPA
office in Chicago. A sixty day negotiations period ended on June 13, 1986.
A settlement between the Agency and PRPs was not reached.
Alternatives Evaluated
The National Contingency Plan (NCP) states that 0~erable unit remedial
actions are appropriate if such measures are cos~-effective, and are
conststent wi~h the permanent remedy at the site [40 CFR 300.68 (c) (3)J.
Remeaial actions, according to the NCP, must prevent or minimize the release
of hazardous substances or pollutants or contami~ants, so that they do not
. migrate to cause substantial danger to present 0; future public health, or
welfare, or the environment [40 CFR 300.68(a)(1 )J.
Source control remedial action operable units for the lagoon wastes were
developed and evaluated. Remedial actions to address the groundwater
contamination were not developed as part of this operable unit because the
nature and extent of groundwater contamination is not yet fully defined
(see "Current Site Status" section above). Upon completion of Rl activities
and definition of the groundwater contamination, an evaluation of groundwater
remedies will be made.
-------
A 1 ternat i ve
---- --_.---- -
2)
Excavation - Treatment
(Precipitation and
Soldification) - Offsite
Landfill Disposal
(RCRA ~pproved landfill)
Table 16-A
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
Technical
. ----- _._--
...t,
Effectively prevents
direct contact and
release to the environ-
ment. The useful life
of precipitation treat-
ment is likely short
because mixing of
wastes at offsite
facility does not allow
treatment effectiveness
to be maintained.
Bench-scale and pilot
scale testing of
precipitation treatment
may delay implementa-
tion of this alterna-
tive. Safer in the
event of release than
onsite facility, be-
cause offsite facility,
is sited specifically
for wJste disposal.
Environmental
p_u_b~i~ _H_e~a_l t~Jj1ji i tut i ~~~1.
Short-term disturbance due
to excavation and truck traffic.
No adverse environmental effects
anticipated. Contaminants
removed and estimate direct con-
tact exposure risks reduced to
below ADI. Wil1 require gene-
rator 10. No zoning or land use
changes required. Current
U.S. EPA policy requires that
contaminated materials for
offsite disposal be considered
as though they were hazardous
wastes and, therefore, be taken
to a 'permitted hazardous waste
(RCRA) facility.
,: .
,
1-, .
.
C()f.\.si ~.te.n.c~ ~i_t_h-
Permanent- Remedy
Very likely to be compat-
ible with any permanent
remedy for the ent ire
site.
I
I
i
I
I
I
I
I
I
I
I
I
I
I
j'
I
-------
Alternative
1 )
Excavation - Treatment
(Solidification) - Off-
site landfill disposal
(RCRA approved landfill)
Table 16-A
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
Technical
....,.
Effectively prevents
release to the envi-
ronment. The techno-
logies are well
demonstrated and O&M
is provided by offsite
facility. Thi s
alternative can be
implemented relatively
easily and quickly.
Safer in the event of
release than onsite
facility, because
offsite is sited
specifically for
hazardous waste dis-
posal.
Environmental
Public Health, Institutional
Short-term disturbance due to
excavation and truck traffic.
No adverse environmental
effects anticipated. Contami-
nants removed and estimated
direct contact exposure risks
reduced to below ADI. Will
require generator 10. No
zoning or land use changes
required. Current U.S. EPA
policy requires that contami-
nated material for offsite
disposal be considered as
though they were hazardous
wastes and, therefore, be
taken to a permitted hazardous
waste (RCRA) facility.
'.- .
-.
, -, .
..
Consistency with
Permanent Remedy
Very likely to be compatible
with any' permanent remedy
for the entire site. .
-------
Table 16-A
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
I
Effectively prevents direct
contact with relatively
high metal concentrations
associated with lagoon slu-
dges, sediment, and soil
Effective indefinitely with
little or no maintenance.
Metal concentrations are
reduced through dilution
with clean soil and, thus
potential impacts are
reduced. Relatively easy
and timely to implement.
Requires testing of onsite
soil for determination of
I ~~p1ication rates and land
~ea requirements.. Ongoing
----------------- monitori n~equi red.
A 1 ternat ive
Technical
..-t.
7)
Excavation - Land
Application (On-
site)
Environmental
Public Health, Institutional
Contaminants not treated. Di-
rect contact exposure risks and
mobility are reduced through
concentration reduction (mixing
with soil). However, contami-
nants are dispersed over larger
area. Also, area where con-
taminated materials are applied
may be designated as hazardous
waste management facility.
(Continued)
Consistency with
Permanent Remedy
Potential for conflict with
permanent site remedy.
Costly as an interim m~asure
if permanent site remedy
requires further action on
wastes.
8)
In-place Precipita-
tion - Native Soil
Cover
Same comments as 6, except
that this alternative
involv0.s t:w additional
uncertai nt ics of treatment
effect i veness with mate-
rials mixed in-place.
Contaminants treated to reduce
mobility. Soil cover is ex-
pected to reduce estimated
direct contact exposure risks
to below ADI. Area where
materials are covered may
be designated as hazardous
waste facility and will be
regularly'monitored.
; '*. .
.
Potential for conflict with
permanent site remedy. How-
ever, proper design could
allow consideration of this
alternative as an effective
interim measure if permanent
site remedy require further
action on wastes.
-------
Alternative
9)
In-place Precipi-
tation - Low-
permeability Cap
10)
Low-Permeability
Cap
-------..----
11)
No fiction
Table 16-A
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
Technical
Same commen~s as 5, except
this'alternative involves
the additional uncertain-
ties of treatment effect-
iveness with materials
mixed in-place.
Capping would effectively
prevent direct contact and
reduce infiltration. Cap-
ping is a well demonstrated.
technology. Implementation
would be relatively easy
and quick. Requires on-
going maintenance and
monitoring.
No Action
Environmental
Public Health, Institutional
Contaminants treated and capped
to reduce mobility. Capping
is expected to reduce esti-
mated direct contact exposure
risks to below ADI and reduce
potential for contaminant
migration with infiltrating
water. Area maybe designated
as hazardous waste facility and
will be regularly monitored.
Contaminants not treated to
reduce mobility. Capping is
expected to reduce estimated
direct .contact exposure risks
to below ADI and reduce poten-
tial for contaminant migration
with infiltrating water. Area
where materials are capped may
be designated as hazardous waste
facility and will be regularly
moni tored.
See "Threat to Public Health"
section .for public health and
environme(ttal evaluation.
I ~, .
.
(Continued)
Consistency with
Permanent Remedy
Potential for conflict with
permanent site remedy.
However; proper.design could
allow consideration of,this
alternative as an effective
interim measure if permanent
site remedy requires further
action on wastes.
Potential for conflict with
permanent site remedy.
However, proper design could
allow consideration of this
alternative as an effective
interim measure if permanent
site remedy requi res further
action on wastes.
Incompatible with objective
of permanent remedy to
reduce threat of site
hazardous substances to
present or future puhlic
hea lth.
I
I
!! .
I I
-------
Alternative
4) Excavation - Treatment
(Precipitation and
Solidification) - Onsite
Landfill Disposal
(RCRA-type landfill)
Table 16-A
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
-Technical
Effectively prevents
direct contact and
release to the environ-
ment. The technologies
are well demonstrated.
I Requires ongoing main-
tance and monitoring.
Very slow and difficult
to implement due to de-
sign and construction
of onsite RCRA landfill
and bench-and pilot-
scale testing of pre-
cipitat i on treatment.
Site is poor location
for hazardous waste
landfill because water
table is shallow; sur-
face water bodies and
residents are rela-
t i ve 1y n('<1 r. Econoll1i es
of scale would not be
gained for small waste
quantity.
Environmental
Public Health, Institutional
Disturbance due to excavation,
construction, and truck traffic.
No adverse environmental effects
'anticipated. Contaminants
isolated and estimated direct
contact exposure risks reduced
to below ADI. Landfill area
would be designated as hazardous
waste landfill. Very cumbersome
monitoring and technical re-
quirements of RCRA permitting.
(Actual permitting would not be
require~.)
"
I ~. .
.
(Continued)
Consistency with
Permanent Remedy
Great potential for compat-
ibility conflict with I
permanent remedy. Ineffic- I'
ient to consider as a
temporary alternative.
Costly as an interim 'I
alternative if permanent
site remedy requires further
action on wastes. i
-------
A lternat i ve
5)
Excavation - Treat-
ment (Precipitation
and Solidification)
- Replacement -
Low-permeability
Cap
------.---.------
6)
Excavation - Treat-
ment (Precipitation
and Solidification)
- Replacement -
Native 50il Cover
Table 16-A
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
Technical
....,.
Capping would effectively
prevent direct contact
and reduce infiltration.
Capping is a well demon-
strated technology. Bench
and pilot-scale testing is
required to estimate effec-
tiveness of treatment
(precipitation and solidi-
fication) technologies for
reducing metal mobilities
and may delay implementa-
tion. Effectiveness of
treatment is not known.
Treatment does not address
organic contaminants. Re-
quires ongoing maintenance
and monitoring.
Environmental
Public Health, Institutional
.
Contaminants treated and capped
to reduce mobility. Capping
is expected to reduce estimated'
direct contact exposure risks to
below ADI and reduce potential
for inorganic and organic con-
taminant migration with infil-
trating water. Area where
materials are placed and capped
may be designated as hazardous
waste facility and will be re-
gularly monitored.
Soil cover and grading
effectively prevent direct
contact and prmnote surface
water runoff. Bench and
pilot-scale testing is
required to estimate
effectiveness of treatment
(precipitation and solidi-
fication) technologies for
reducing metal mobilities
and may delay implementa-
tion. Effectiveness of
treatment is not known.
Treatment does not address
organic contaminants.
Requires on-going main-
tenance and monitoring.
Contaminants treated and covered
to reduce mobility. Soil cover
is expected to reduce estimated
direct contact exposure risks to
below ADI. Area where materials
are placed and covered may be
desi9nated as hazardous waste
facility ~~d will be regularly
moni tored~
-. .
I . # .
..
(Continued)
Consistency with
Permanent Remedy
Potential for conflict with
permanent site remedy.
However, consolidation pf
waste reduces construction
costs and would allow con-
sideration of this alterna-
tive as effective interim
measures if permanent site
remedy requi res further
action on wastes.
Potential for conflict with
permanent site remedy. How-
ever, consolidation of
wastes reduces construction
costs and would allow con-
sideration of this alterna-
tive as effective interim
measure if permanent site
remedy requires further
action on wastes.
-------
Alternative
3)
Excavation -.Treatment
(Solidification) - On-
site Landfill Disposal)
(RCRA-type landfill)
Table 16-A
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
Technical
Effectively prevents
direct'~ontact and
release to the envi-
ronment. The tech-
nologies are well
demonstrated. Requires
ongoing maintenance and
monitoring. Very slow
and difficult to imple-
ment onsite RCRA land-
fill. Site is poor
location for hazardous
waste landfill because
water table is shallow;
surface water bodies
and residents are
relatively near.
Economies of scale
would not be gained for
small waste quantity.
Environmental
Public Health. Institutional
Disturbance due to execavation.
construction. and truck traffic.
No adverse environmental effects
anticipated. Contaminants iso-
lated and estimated direct
contact exposure risks reduced
to below ADI. Landfill area
would be rezoned and designated
as hazardous waste landfill
Very cumbersome monitoring
and technical requirements at
RCRA permitting. (Actual per-
mitting would not be required.)
"
1'*, .
.
(Continued)
Consistency with
Permanent Remedy
Great potential for compat-
ibility conflict with
permanent site remedy.
Costly as an interim alter-
native if permanent si~e
remedy requires further
action on wastes.
-------
Alternative
1 )
Treatment and Dis-
charge at Offsite
RCRA F ac il ity
Table 16-8
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
Technical
"'1.
Demonstrated and effective
treatment of aqueous
wastes. Relatively quick
and easy to .implement.
2)
Treatment and Ois-
charge at Publicly
Owned Treatment
Works (POn~)
--- -.--... -.-.---.----.--- ----
3)
Onsite Treatment
(Precipitation
and Filtration) -
Surface Water Dis-
charge
Demonstrated and effective
treatment of organics in
domestic and industrial
wastewater. Inorganics
transferred to POTW sludge.
Relatively easy and quick
to implement after recei-
ving approval from the
POTW. Approval process
from POTW may delay imple-
mentat i on of remed i a 1
actions on contaminated
_~.1_u5!.quire
. : ~ .... ; ., ..
Environmental
Public Health, Institutional
Attains applicable and relevant
discharge standards. Existing
NPDES and RCRA permits. Some
short-term disturbance due to
increased truck traffic,
(Approximately 16 tank trucks
re u ired) .
Attains applicable and re1evant
discharge standards. Existing
NPOES permit. Would require
permit or approval from porw
for di scharge to system. Some
short-term disturbance due to
increased truck traffic.
(Approximately 16 tank trucks
required). A RCRA permit by
rule requirement may apply to
a POTW.
._._._-_.- --
Would attain applicable and
relevant discharge standard
and criteria. Would require
achieving technical requirements
of NPDES permit. May require
easements for discharge line
to surface water.
Consistency with
Permanent Remedy
Compatible with permanent
site remedy.
;
t
Compatible with permanent
site remedy.
---
Compatible with permanent
site remedy.
-------
A lternat i ve
- - - - - - --.- - -
4)
Direct Discharge
to Surface Water
Table 16-8
SUMMARY OF SOLIDS ALTERNATIVE SCREENING
Technical
- - - ----_.-
No treatment'. rel ies on
assimilitive capacity of
receiving waters.
Requires monitoring of
discharge. . Implementa-
tion would require achie-
ving technical require-
ments of NPDES permit and
coordination of discharge
rate with flow in the
flow in the receiving
stream. If NPDES per-
mitting process or dis-
charge rate with flow
in the receiving stream
are delayed. remedial
action on contamination
sludges and sediment.
may be de 1 ayed.
Environmental
'publ.i_c- -H-e~aJ::fh-~-fn-s-fi t_ut i on~
Might not attain applicable
and relevant discharge stand-
.ards and criteria. Would re-
quire compliance with technical
requirement of NPDES permit.
Easements may be required for
temporary pipeline to suitable
discharge point. May violate
technology requirements of
Clean Water Act.
'0- .
I ~. .
.0
(Continued)
Consistency with
:~er-rriine-rif -R-em'~
Compatible with permanent
site re~edy.
t'
-------
- 9 -
. The treated solids would then be replaced into two of the existing lagoons,
which would be lined with a layer of crushed limestone. The replaced
solids would be covered with a layer of crushed limestone and capped. The
cap would be constructed of compacted clay and a synthetic membrane to
reduce infiltration and promote surface runoff. The total depth of waste
in the lagoons is shallow (maximum Of 3 feet), therefore, the excavated
lagoons which remain empty will not require backfilling.
The aqueous lagoon wastes would be removed, then treated and disposed of
offsite at a RCRA-permitted facility.
-
This is an onsite source control alternative which meets CERCLA goals.
Alternative 3.
In-Place Treatment, Native Soil Cover
All contaminated sludges and sediment from the lagoon Nos. 2,3,4,6,7,
and 8 would be treated in-place. Lagoon Nos. 1, 5, and 9 would receive
no action. The treatment would involve adding powdered limestone (CaC03)
or calcium hydroxide (Ca(OH)2), as necessary, to adjust the pH of
lagoon solids. The liming would maintain alkaline conditions, and serve to
keep the metals in the waste precipitated. -
After liming, the treated materials would
layer of crushed limestone. A geotextile
limestone, and native soil cover would be
surface water runoff.
be graded and cover~d.with a
fabric would be praced over the
graded and contoured to promote
The aqueous lagoon wastes would be removed, then treated and disposed of
offsite at a RCRA-permitted facility.
This is an onsite source control alternative which meets CERCLA goals.
Alternative 4.
No Action
In this Alternative there would be no remediation of the site lagoons.
envi!onmental and public health risk posed by the lagoons would remain.
The
. .
This is the no action alternative.
In accordance with the NCP, Section 300.68(f)(1), to the extent possible
and appropriate, at least one remedial alternative in each of the following
categories was developed:
(i)
Alternatives for treatment or disposal at an offsite facility
(Alternative No.1);
( i i )
Alternatives that attain applicable or relevant and appropriate
Federal public health and environmental requirements (Alternative
No.1) ;
(iii)
Alternatives that exceed applicable or relevant and appropriate
Federal public health and environmental requirements (No alter-
native was developed for this category.);
-------
- jJ-
(i v)
Alternatives that do not attain applicable or relevant and
appropriate Federal public health and environmental requirements,
but will reduce the likelihood of present or future threat from
the hazardous substances and provide significant protection to
public health and welfare and the environment (Alternative
Nos. 2 and 3);
(v)
No action alternative (Alternative No.4).
RCRA is the Federal environmental law which is applicable or relevant and
appropriate to the Forest Waste Disposal operable unit remedial action.
Alternative No.1 is an offsite alternative (i) that attains applicable or
relevant and appropriate Federal public health and environmental require-
ments (ii). It was not appropriate to develop an alternative which exceeds
Federal public health and environmental requirements. The developed alter-
natives cover a range of remediation of the site lagoon wastes, including
complete removal of the appropriate lagoon wastes. Remediation of the
lagoon wastes beyond complete removal is inappropriate because it would
provide no further protection of public health and the environment.
Alternative Nos. 2 and 3 fall into category iv above. The no action
alternative was considered in the final analysis of alternatives.
Community Relations
.,'
. ".. ..
The Superfund activities at the Forest Waste Disposal Site ~ave been followed
closely by the local community and press. The MDNR currently has the lead
role in community relations activities at the site. The ,State and the
Agency have worked together to keep communication with the community open and
frequent.
There is an active mailing list of local citizens who receive updates about
site activities. Newsletters are periodically mailed to the citizens,
updating them on recent site activities.
A Citizens Information Committee (CIC) has been formed by the State. This
is a group of local citizens and Federal, State, County and local officials
with. high interest in site activities. This group meets periodically to
receive information about site activities and exchange information about
community concerns. The committee members serve as liaisons between the
local citizens, and MDNR and U.S. EPA.
Copies of the Phased Feasibility Study (PFS) wer2 made available to the
community on April 14, 1986. The Forest Township Library, in the Forest
Township Hall, served as a repository for two copies of the study.
The MDNR issued a press release in the Flint Journal on April 15, 1986,
which announced the availability of the study and the April 14 - May 5
public comment period. The press release announced a public meeting which
was held in the Forest Township Hall on the evening of April 21,1986. A
CIC meeting was held the afternoon of April 21, 1986, to present the PFS to
the committee members. The CICmeeting and the evening public meeting were
both well-attended. The community was receptive to the presentation of the
PFS and supported the recommendation for action on the lagoons.
-------
-11-
Some citizens_expressed concerns that they had been dealt with unfairly in
past occurences at. the Forest Waste Disposal Site. The offsite disposal
of site lagoon wastes was expressed by some citizens as the only acceptable
option for remedial action on the lagoons.
The Responsiveness Summary to the public comment is attached to this
Narrative Summary.
Selection Process
The three developed alternatives. along with the no action alternative.
were further evaluated. The appropriate cost-effective remedial measure
was selected in accordance with the selection process outlined in Section
300.68 (i)(1) and (2) of the NCP. This selection was based partially on
considerations of cost. technology (technical implementability). and reli-
ability. Ability to protect public health was also considered in the final
selection process. Finally. consistency with a permanent remedy for this
operable unit remedial action was considered in accordance with Section
300.68 (c)(1) of the NCP.
Table 17 summarized the capital. annual operations .and maintenance (O&M).
and present worth costs for each of the three developed alternatives. The-
costs represent an order of magnitude estimate and have an estimated accuracy
of +50 and -30 percent. The estimated present worth. of all ~l~~rnatives .
was based on a 3D-year period and 10-percent interest rate. '~or Alternative
No.1. a RCRA permitted disposal facility located approximately 100 miles
from the Forest Waste site. Wayne Disposal. was used to p~oject costs for
off-site disposal of sludges and sediments. If this facility is not in
compliance with the U.S. EPA Off-Site Policy when the Forest Waste remedial
design is completed. costs for Alternative 1 will likely increase for one
of two reasons. First, the wastes could be treated and then stored on site
until the facility came into compliance. This could increase the cost of
the alternative because of increased waste handling by an estimated two
percent. Alternatively. a facility which is farther away from the site
than Wayne Disposal is. but which is in compliance with the Off-Site Policy.
could be used for waste disposal. This could potentially double the cost
of Alternative,No. 1 because of the greater transportation distance.
. .
During the early stages of the alternatives revie\1. the no action alterna-
tive was eliminated from further consideration. This decision was based
upon an evaluation of the public health risks imposed by .the materials in
the lagoons at the Forest Waste Disposal Site. These materials have been
shown to pose an unacceptable public health risk. thus warrant implementa-
tion of a remedial action. The no action alternative. therefore. is not
appropriate.
The remaining three alternatives were compared in terms of the following
five screening criteria: ability to protect public health. technical
implementability. reliability. relative economic costs. and consistency
with a permanent remedy. Table 18 summarizes the evaluation of the
developed alternatives.
The three alternatives. ranked in descending order of ability to protect
public health. are Alternative No.1, No.2. and No.3. Alternative No.1
is an offsite alternative. therefore. removes the waste from the site
and surrounding area. This eliminates the risk ~ssociated with direct
-------
Screening
--(ri terfa
---
Table 18 - Evaluation of Developed Alternatives
....t,
Developed Alternatives
Alternative No." 1
Excavation of Solids. Off-site
Disposal at RCRA Facility
Excavation of Liquids. Off-site
Disposal at RCRA Facility
Alternative No.2
Excavation of Solids, Chemical
Treatment, Combining, Replacement
in two lagoons, low-permeability
Excavation of liquids. Off-site
Disposal at RCRA Facility
Alternative No.3
In-place Chemical Treatment
of Solids, Native Soil
Cover
Excavation of liquids.
Off-site Disposal at RCRA
Facil ity
---------------- ----------------
Abil ity to
Protect Public
I~ea It h
Excavation and off-site disposal
of contaminated solids and
liquids substantially reduces
risk associated with direct
contact of contaminated materials
and potential leaching of
contaminants to the groundwater.
Treatment and capping of solids Treatment and covering of
reduces the potential for direct solids reduces the poten-
contact exposure to contaminated tial for direct contact
materials and potential leaching exposure to contaminated
of contaminants to the ground- materials and may reduce
water. potential leaching of
contaminants to the ground-
Action for liquids as described water. Action for liquids
in Alternative No.1. as described in Alternative
No.1.
. .
'.
Imp1ementability
(continued on
next page)
Excavation, transport, and dis-
posal can be implemented very
eas ily and qui ck 1y with convent-
tional construction methods.
Construction tilne is about
1 month after completion of
Ot'S i yn lIC ti vit i ps.
I "
I
, .
I., .
.
I
Treatment, excavation, and
placement of treated solids in
two lagoons can be implemented
easily and qu~ckly with con-
ventional construction and
agricultural methods.
Installation of low-permeability
qp-reqlli res stri ct quality
,-nnt. "01.
Treatment and covering of
contaminated solids in- .
place can be implemented
easily and quickly with
conventional construction
equipment. Implementation
time following ~--;gn
activities is c 1 to 2
months.
-------
Implementability
(continued)
Table 18 - Evaluation of Developed Alternatives - continued
Developed Alternatives
....,.
Alternative No.1
Design may require 3-12 months.
Require compliance with simple
Michigan Act 64 technical
requirement.
Alternative No.2
Implementation time following
design activities is about
3 months. Design may require
up to 12 months. Action for
liquids as described in
Alternative No.1. Require
compliance with extensive
Michigan Act 64 and SWMA tech-
nical requirements.
Alternative No.3
Design may require up to
12 months. Action for
liquids as described
in Alternative No.1.
Require compliance with
extensive Michigan SWMA
technical requirements.
----
Reliability
Solids and liquids excavation,
transport, and disposal are
operationally routine. Solidifi-
cation treatment has proven
preformance for stabilizing
\'/aste. Perf(.H'illdnC(~ is demon-
strated for excavation and trans-
port. Ultimate disposal of
liquid wastes at a RCRA treatment
facility and solidified waste at
a RCRA landfill are considerable
reliable.
Precipitation (liming) and
solidification have proven
performance for adjusting pH and
eliminating free liquids, respec-
tively. Effectiveness of pH
adjustment for reducing metals
mobility in specific Forest
Waste Lagoon wastes is undemon-
strated and requires bench-scale
testing for determination.
Proposed.treatment would do
little tq impair leachability of
organic ~Ompounds. RCRA cap
would provide reliable protection
against direct contact threat and
effectively serve to prevent
water from percolating to the
wastes. Per,odic maintenance
and monitoring are required.
Action for liquids as described
Alternative No.1.
Precipitation (liming) has
proven performance for
adjusting pH. Effective-
ness of lime addition for
reducing a metal mobili-
ties in specific Forest
Waste Lagoon wastes is
undemonstrated and re-
quires bench-scale testins
for determination. Pro-
posed treatment would do
little to impair 1eacha-
ab1ity of organic com-
pounds. Soil cover would
serve to provide protec-
tion against direct
contact threat, but woulrl
do little to prevent water
from percolating to the
wastes. Periodic main-
tenance and monitoring
an~ rf'quired. Action for
liquids il5 rlf'scribed in
-------
Relative
Economic Costs
Total Capital
Annual 0 & M
Present Worth
Table 18 - Evaluation of Developed Alternatives - continued
Developed Alternatives
...,.
Alternative No.1
$1,295,000
$ -0-
$1,295,000
Alternative No.2
$646,000
$ 1,000
$656,000'
Alternative No.3
"
$417,000
$ 500
$422,000
Consistency with
Final Remedy
Removal and off-site disposal of
contaminants would be consistent
with the final site remedy.
This remedy serves to substan-
t i ally reduce the threat of site
hazardous substances to present
or future public health. The
wastes would be contained in a
well-suited disposal facility.
'"
Alternative No.2 serves to
somewhat reduce the threat of
site ,hazardous substances to
present or future public health.
Potential threat to groundwater
remains.
The possibility of further
remedial action on the lagoon
wastes in the final site
remedy does exist. Potential
further action on the site
lagoons wastes may require
abandonment and destruction of
structures in Alternative No.2
(eg. R~~A cap, lined lagoons).
I.. .
.
.
Alternative No.3 would
serves to somewhat re-
duce the threat of site
hazardous substance to
present or future public
health. Potential threat
to groundwater remains.
The possibility of further
remedial action on the
lagoon wastes in the final
site remedy does exist.
Potential future action
on the site lagoon wastes
may require abandonment
and destruction of struc-
ture in Alternative No.3
(eg. native soil cover).
-------
.- ~2-
contact of contami.nated materials to the surrounding community and eliminates
the potential for contaminants to further leach to the groundwater at the
site. Alternatives No.2 and No.3 reduce, but do not eliminate, the public
health risk associated with direct contact of contaminated materials to the
surrounding community. Alternative No.2 reduces, but does not eliminate,
the potential for contaminants to further leach to the groundwater at the
site. Alternative No.3 somewhat reduces the potential for contaminants to
further leach to the groundwater at the site.
The three alternatives, ranked in descending order of implementability, are
Alternative No.1, No.3, and No.2.
Alternative No.1 can be implemented very quickly and easily with conventional
construction methods. Construction time is about one month after c0mpletion
of design and administrative requirements. Results are realized as contami-
nants are removed from the site. Design and administrative requirements
may require up to 3 to 12 months. .
Treatment and covering of contaminated lagoon sediment in Alternative No.3
can be implemented quickly and easily with conventional construction methods.
Construction time after design and administrative requirements is about 1-to
2 months. Design and administrative activities may require up to 12 months.
T~eatment, excavation, and replacement of lagoon sediments ih. A~ternative
No.2 can be implemented easily and quickly with conventional construction
and agricultural methods. Installation of the low-permeability cap requires
strict quality control and would be somewhat difficult to -implement.
Design and administrative activities may require up to 12 months. Actual
construction time is estimateed to be approximately 3 months.
As described below in the "Consistency with Other Environmental Laws" section,
Michigan Hazardous Waste Management Act Act 64 imposes permitting requirements
when treating, storing, and/or disposing of hazardous wastes as defined by
Act 64. The lagoon sediments from lagoon No.4 are the only wastes being
addressed in this operable unit that are described as hazardous under Act 64.
The NCP states that State permits are not required for Fund-financed remedial
actions [40 CFR Section 300.68 (a)(3)]. The admi~istrative protocols
associated with gaining Act 64 permits for treating, storing, and/or
disposing of lagoon No.4 sediments are, therefore, not concerns associated
with any of the three developed alternatives. It is, however, the intention
of the CERCLA program to comply, as appropriate, with all the technical
requirements of any State permits when implementing Fund-financed remedial
actions. If the technical requirements of State permits are substantially
more stringent than Federal requirements and would involve substantial
additional costs, compliance would likely not be appropriate. The technical
requirements of applicable and/or relevant Michig3n environmental laws are
not more stringent than applicable and/or relevant Federal requirements for
the Forest Waste operable unit. These technical requirements of State
permitting, therefore, merit consideratio~ in an evaluation of the implement-
ability of alternatives.
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-L~-
In Alternative No.1. the wastes from lagoon No.4 could be handled as
described only after meeting the technical requirements of an Act 64
treatment facility permit. The solidification in this alternative is
considered to be a form of treatment under Act 64. The Act 64 requirement
expected to be of concern involves an evaluation of the potential air
emissions problem associated with the proposed treatment and an evaluation
of protection measures proposed to deal with this potential problem.
In Alternative No.3. lagoon No.4 sediments are not removed during treatment
or disposal. therefore. since these wastes were disposed of prior to 1980.
Act 64 regulations and associcated permitting requirements are not applicable.
These wastes would. however. need to be disposed of in accordance with the
technical requirements of the Michigan Solid Waste Management Act (SWMA).
This waste would be considered non-inert material under the SWMA. therefore.
require disposal in a type II landfill. This would require the installation
of a single liner and a leachate collection system. Alternative No.3 does
not meet the technical requirements of the SWMA. and this would likely delay
and/or prevent smooth implementation of this remedy.
In Alternative No.2. the treatment of lagoon No.4 sediments would also
require compliance with the technical requirements of an Act 64 treatment--
facility permit. Furthermore. an evaluation of the waste after. treatment
would also be needed before the waste was land disposed in l~g~p Nos. 2
and 4. If the waste remained characterized as hazardous. t~~. technical
requirements of an Act 64 disposal' facility permit would need to be met.
This would involve the installation of a double liner and leachate
collection system. If the waste after treatment was no longer charac-
terized as h.azardous. the technical requirements of the SWMA for land
disposal of waste would need to be met. As in Alternative No.3. this
would require installation of a single liner and a leachate collection
system. Alternative No.2 does not meet the technical requirements of
Act 64 and/or the SWMA. and this would likely delay and/or prevent smooth
implementation of this remedy.
It also merits consideration in an evaluation of implementability of
alternatives. the State and community support of each of the alternatives.
The State of ~fchigan has indicated strong support for the selection of
Alternative N~. 1. The State has indicated that ~lternative Nos. 2 and 3
do not provide adequate protection of public hea1~h and the environment.
and therefore. are not cost-effective.
The community, likewise. has indicated strong support for selection of
Alternative No.1 (see "Community Relations" section above and the Respon-
siveness Summary). The community has indicated that. in their opinion,
onsite disposal of the waste does not provide adequate protection of public
health and the environment.
~
The three alternatives, ranked in descending order of reliability. are,
Alternative No.1. No.2, and No.3. Alternative No.1 incorporates the use
of operationally routine waste handling technologies. The solidificaiton
treatment has proven performance for stabilizing waste. Ultimate disposal
of solidified wastes at a RCRA landfill is considered reliable. Treatment
and disposal of liquid wastes at a RCR~ treatment facility is considered
reliable.
-------
-i'~-
The precipitation treatment in Alternatives Nos. 2 and 3 has proven per-
formance for adjusting pH and eliminating free liquids, but the effective-
ness of pH adjustment for reducing metals mobility in Forest Waste Lagoon
wastes is undemonstrated and requires bench-scale testing. The success of
this proposed treatment is, therefore, unknown. Furthermore, the proposed
treatment would do little to impair the leachability of organic compounds
to the groundwater.
In Alternatives No.2 and No.3, respectively, the low-permeability cap and
native soil cover would provide reliable protection against direct contact
threat. The low-permeability cap would effectively serve to prevent water
from percolating to the wastes. The native soil cover would do little to
prevent water from percolating to the wastes.
The alternatives, in ascending order of capital costs and present worth are
Alternatives No.3, No.2, and No.1 (see table 17). Alternative No.1 has
no associated operations and maintanence (O&M) costs. Alternative No.3
has estimated annual O&M costs of $500. Alternative No.2 has estimated
annual O&M costs of $1,000.
All three alternatives serve to reduce the threat of site hazardous substances
to present or future public health to varying degrees. Alternative No.1 is
clearly the most consistent of the three alternatives with ~ p~~manent remedy.
Alternative No.1 more effectively reduces the public healtH-threat than
Alternative Nos. 2 or 3. In Alternative Nos. 2 and 3, a ~otential threat
to the groundwater remains. In Alternative No. I, the waste is removed
from the site, therefore, the potential threat to the groundwater from the
waste is eliminated.
Alternative Nos. 2 and 3 also may require abandonment and destruc~ion of
remedial action structures in the permanent remedy. If further onsite
treatment or offsite treatment/disposal options are choosen in the permenant
remedy, the lined lagoons may be abandoned and the multi-layer, low-perme-
ability cap may be destroyed from Alternative No.2. Likewise, implementation
of these types of permanent remedies would require destruction of the
native soil cover in Alternative No.3. .
-
Alte~native N~. I, therefore, is the alternative ~ost consistent with a
permanent remedy.
Recommended Alternative
The National Oil and Hazardous Substances Contingency Plan (NCP) [40 CFR
Part 300.68(i)(1)] states that the appropriate extent of remedy shall be
determined by the lead agency's selection of a cost-effective remedial
alternative that effectively mitigates and minimizes threats to and provides
adequate protection of public health and welfare and the environment. The
NCP also states that the selected remedy should attain or exceed applicable
or relevant and appropriate Federal public health and environmental require-
ments that have been identified for the specific site. Based on the
considerations outlined in the NC? and presented in the "Selection Process"
section above, Alternative No.1 was selected as the appropriate cost-effec-
tive remedial alternative.
-------
-
Table 17 - Costs Summary
Alternative No.1 Alternative No.2 Alternative No.3
Capital Costs $1,295,000 $646,000 $417,000
Annual O&M $0 $1,000 $500
30 yr. Present Worth $1,295.000 $656,000 $422,000
:..;.. .. - ~
~
.
D
-------
-!f>-
Alternative"Ho. 1 is superior to Alternative Nos. 2 and 3 in terms of ability
. to protect public health, implementability and reliabilty. Alternative
No.1 is also clearly the most consistent with a permanent remedy at the
site of the three developed alternatives. Finally, Alternative No.1 attains
applicable or relevant and appropriate Federal public health and environmental
requirements (RCRA). Based on these strengths, Alternative No.1 was selected
as the appropriate cost-effective alternative.
Consistency with Other Environmental Laws
There are two environmental laws which raise important issues concerning
Alternative No.1. These laws are the Federal Resource Conservation and
Recovery Act (RCRA) and the Michigan Hazardous Waste Management Act (Act 64
of 1979).
The NCP [40 CFR 300.68 (i) (1)] states that a selected remedial action alter-
native should attain or exceed applicable or relevant Federal public health
and environmental requirements. The NCP [40 CFR 300.68 (i) (6) (1)] states
that State standards will be considered in developing remedial alternatives,
but these standards need not be used if the rationale for not using such
standards is presented.
It is U.S. EPA policy that CERCLA remedial actions comply with ,relevant and
applicable environmental and public health standards and reQui~ments.
"Applicable" standards are defined" as those standards that would be legally
applicable if actions were not unde~taken pursuant to CERCLA. "Relevant"
standards are those encountered at. a CERCLA site although'they would not be
legally applicable.
rl
The following is a discussion of the Federal RCRA regulations in reference
to the Forest Waste operable unit.
The U.S. EPA considers all wastes from a CERCLA site to be a hazardous
waste, as defined in the RCRA regulations 40 CFR Part 261 "Identification
and Listing of Hazardous Wastes", unless proven otherwise or unless the
waste is regulated by another statute such as the Toxic Substances Control
Act. " The Forest Waste Oi sposa 1 1 agoon wastes are regul ated by RCRA. Two
Subparts of Part 261, Subpart C - Characteristics of Hazardous Waste" and
Subpart D - "Lists of Hazardous Waste" respectively define the two groups of
RCRA hazardous wastes: characteristic hazardous waste and listed hazardous
waste. In order to determine a CERCLA waste is not a characteristic or
. listed hazardous waste, it must be demonstrated as excluded in accordance
with RCRA regulations 40 CFR Part 260.22 - "Petitions to amend Part 261 to .
exclude a waste at a particular facility". If a CERCLA site is known or
suspected to have accepted a listed hazardous waste, then the effort to
exclude the CERCLA waste as hazardous is generally more intensive than if
there were no evidence which would indicate specific listed ~/astes were at
the CERCLA site. Listed hazardous wastes are suspected of, although not
specifically known to have been, disposed of in the Forest Waste Oisp05al
lagoons (i.e., electroplating waste and spent sulfuric acid). Since a
representative characterization of the lagoon ~Iastes has not been performed,
the wastes in lagoon Nos. 2, 3, 4, 5, 7, and 8 would all be considered RCRA
hazardous wastes. RCRA is then relevant and/or applicable to Alternative
No.1 because it includes handling and disposal of RCRA hazardous waste.
-------
-16-
Alternative No.1" has RCRA issues relative to the associated free liquids
left with the waste solids, after the bulk of the liquids have been separated
from the solids. The Hazardous and Solid Waste Amendments (HSWA) of 1984
prohibit the placement of bulk or noncontainerized liquid hazardous waste, or
hazardous waste containing free liquids, in a landfill, whether or not
sorbents have been added. No associated free liquids, therefore, can be
left with solid waste before landfilling. The waste, furthermore, must be
treated beyond the addition of sorbents so that it is chemically or physically
stabilized.
The solidification treatment proposed in this alternative includes mixing
appropriate amounts of solidifying agents such as fly ash and portland cement
to the lagoon sediments as they are being excavated. It is expected that
this treatment will effectively eliminate the associated free liquids,
therefore, properly solidify the waste. Bench scale testing will be required
to determine the appropriate combination and quantity of solidification
additives to effectively treat the lagoon sediments.
In order to demonstrate that the lagoon sediments contain no associated
free liquids, the Paint Filter Test, as referred to in RCRA regulations,-
40 CFR Section 264.314, will be performed. Passage of this test will be -
necessary before the lagoon sediments can be place in an offsite landfill~
;
. ,.4
It is expected that the proposed treatment will sufficientlY"chemically/
physically stabilize the waste. This determination will be made at the time
of disposal by the landfill owner/operator and the RCRA p,ermitter. If there
is some question as to the waste being properly stabilized, a strength test,
currently being reviewed by U.S. EPA Headquarters as part of the hazardous
waste guidance, may be performed. The strength test under review is an
American Society of Testing Materials unconfined compressive strength test
which requires withholding 50 pounds per square inch (psi) of pressure.
Material which passes this test is thought to be properly stabilized.
Passage of this test is not expected to be necessary because an understanding
of the treatment outlined in this alternative should convince the landfill
owner/operator and RCRA permitter that the waste will be properly stabilized.
In t~e future., RCRA may require the proposed Toxicity Characteristic Leaching
Procedure (TLCP), as described in January 14, 1985, Federal Register 40 CFR
Part 260 for all RCRA land-disposed waste. This leaching test will indicate
if the waste has been properly stabilized in terms of leachability of
certain target contaminants. This test may be required by RCRA prior to
land disposal of the wastes in remedy. If passage of the proposed TCLP is
necessary at the time of construction activities, it will be necessary to
do a bench-scale study of the solidified waste. It is expected that the
treated waste in this alternative will pass the TCLP.
RCRA standards are applicable and relevant to Alternative No.1. All RCRA
technical standards would be met in this alternative, and this alternative
would be in full compliance with RCRA.
D
MDNR is seeking final authorization by U.S. EPA to administer a state
hazardous waste management program considered equivalent to the Federal
RCRA program. Rule changes to Michigan Act 64 have been made to obtain
final authorization from U.S. EPA. Michigan's RCRA equivalent hazardous
-------
-17-
waste management program regulates the generation, transport, storage,
treatment, and disposal of hazardous waste. The following is a discussion
of the applicability of Act 64 to the Forest Waste Disposal operable unit.
-
Currently, a determination of whether or not Act 64 "listed hazardous
wastes" were disposed of in the lagoons cannot be made, since specific
industrial sources of such wastes are not known. Therefore, whether or not
a lagoon ~aste is considered "hazardous" under Michigan Act 64, depends
on whether or not the waste has hazardous characteristics as defined in
Act 64. U.S. EPA lagoon sludge sampling data collected in 1983 are the
only data currently available to make that determination. EP toxicity
testing results from the 1983 sampling indicated that only the lead value
in a sample from lagoon No.4 exceeded its EP toxicity limit. Based on
this datum, and assuming the sludges from the lagoons are not corrosive,
reactive, or ignitable, Michigan could consider only lagoon No.4 sludges a
"hazardous" waste regulated under Act 64.
Institutional permitting requirements are part of Act 64 requirements.
Section 300.68(a)(3) of the NCP states that State environmental permits are
not required for fund-financed CERCLA remedial actions. It is, however,
the intention of the CERCLA program to comply, as appropriate, with all --
technical requirements of State permits when implementing Fund-financed
remedial actions (see "Selection Process" section abQve, p.12).Jhe technic~l
requirements of applicable Act 64 permits will, therefore, b~ satisfied in
implementing Alternative No.1. . . .
The waste from all lagoons. except No.4, could be handled as described in
Alternative No.1. without the need for an onsite treatment facility permit.
However, lagoon No.4 would require satisfaction of these technical permitting
requirements for the site. since it contains a hazardous waste, and solidi-
fication is considered to be a form of treatment under Act 64. These technical
requirements should be relatively easily satisfied. They would include
evaluation of the potential air emissions problem associated with the
proposed treatment and an evaluation of protective measures proposed to
deal with this potential problem.
Act 64 standards are applicable and relevant to Alternative No.1. All Act
64 technical standards would be met, and this alternative would be in full
compliance with Act 64. Other environmental laws applicable to Alternative
No.1 are summarized in Table 19.
u
d
Operation and Maintenance (O&M)
The selected remedy has no associated operation and maintenance costs.
State Agreements
Section 104(c)(3) of CERCLA sets forth the State financial responsibilities
in remedial actions provided under CERCLA. The State financial responsibilities
in the proposed remedial action would include payment or assurance of
payment of 10 percent of the costs of remedial action.
The Director of the Michigan Department of Natural Resources has sent the
Region V Regional Administrator a letter acknowledging the State financial
obligations in this remedial action.
-------
Law
FEDERAL
Federal Resource
Conservation and
Recovery Act (RCRA)
National Environmental
Policy Act
(NEPA)
STATE
Michigan Hazardous
Waste Management
Act
~
,
Michigan Solid
. Waste Management
Act .
f~i chi gan DNR,
~nvironmental
Protect i on Act
-
Table 19 - Applicable Environmental Laws
Source of Regulation
Applicability
. RCRA Sections 3001, 3004
3005; 40 CFR 264, and 265
HSWA of 1984
Regulates the generation
transport, storage, treat-
ment, and disposal of hazard-
ous waste in the course of
remedial action. RCRA
requirements may apply to the
stockpiling, transport, and
disposal of excavated soils.
Administered by Michigan
Department of Natural
Resources (MDNR) under
Michigan Act 64.
CERCLA actions are exempted
from the NEPA requireme~t
because EPA's decisionmaking
process in s,~1ecting a .
remedial action alternative
is the functional equivalent
of the NEPA analysis.
Federal Register,
Janua ry 14, 1985
40 CFR Part 260
NEPA Section 102(2)(c)
State of Michigan
Act 64 of 1979 as
Amended
Regulates the generation,
transport, treatment,
storage, and disposal of
hazardous waste. Michigan is
seeking authorization to
administer RCRA in the State
under Michigan Act 64 rule
changes.
State of Michigan
Act 641 of 1978
as amended
Regulates disposal of
nonhazardous solid
waste.
Michigan Environmental
Protection Act 127 of
1970 as amended
This act states that no
one can pollute, impair,
destroy, or cause harm to
the environment. The MDNR
would determine whether
the proposed cleanup levels
are consistent with this
act.
C>
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-
Community Relations Responsiveness Summary
Forest Waste Disposal Site
Otisville, Michigan
Introduction
The U.S. Environmental Protection Agency (U.S. EPA) has been, and continues
to, gather environmental information about the Forest Waste Disposal Site in
Otisville, Michigan as part of a Remedial Investigation (RI). Upon comple-
tion of the RI, a Feasibility Study (FS) will be conducted to evaluate and
recommend remedial measure(s) for the entire site. The U.S. EPA has con-
ducted a Phased Feasibility Study (PFS), using information gathered on the
lagoon liquids, sludges, and associated sediment and soil, to evaluate
operable unit remedial response actions and recommend a course of action
for the lagoon wastes.
As part of the RI/FS and PFS processes, public meetings were held to explain
the intent of the project, to describe the results, and to receive comments
from the public. Public participation in Superfund projects. 1s:required by
the National Oil and Hazardous Substances Contingency Plan (~CP). Comments
received from the public are considered in the selection of the remedial
action for the site. The State of Michigan currently has ,the lead role for
Community Relations at the Forest Waste Disposal Site.
The PFS has been made available for public comment. This Responsiveness
Summary summarizes the comments received and describes how they were
incorporated into the decisionmaking process.
Public Involvement Activities
The planning process for the RI at the Forest Waste Disposal Site began in
the Winter of 1983. A Citizens Information Committee (CIC) was formed at
that ~ime by ~he State of Michigan. The CIe is a group of local citizens
and ~tate, County and local officials with high iGterest in site activities.
The U.S. EPA participates in CIC meetings. The purposes of the CIC are:
u
1) to ensure the community representatives are informed about Forest Waste
site activities,
d
~
2) to ensure local citizens have a consistent and easily accessible means
of receiving up-to-date information about the site,
3) to advise U.S. EPA and Michigan Department of Natural Resources (MDNR)
project staff regarding local concerns.
The CIC has held and will continue to hold meetings periodically (1-4
times/year). as appropriate. It has served its purposes well.
Three open public meetings have been held fo present and explain site
activities to the community and receive community response to these
activities.
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-2-
The first public meeting was held in May 1984, at the start of the RIfFS,
to explain the Superfund program and the scope of the RIfFS. There were
approximately 50 attendees at the meeting. Community concerns expressed at
that time included testing of residential drinking wells and private ponds,
and the past role of the Genesee County Health Department and MDNR in
regulating the site. Initial RI work included water samples from private
ponds of surrounding residents. MDNR also collected a composite fish sample
from a private pond adjacent to the site.
The second public meeting was held May 16, 1985 (100 attendees plus local
press) and served to provide an update for citizens on the status of the
RIfFS. The community expressed concern about the seemingly slow progress
towards cleanup at the site. The community also expressed concerns about
testing of their drinking wells. In Summer of 1985 drinking water from
several residents' wells surrounding the site were sampled. No evidence of
contamination was found.
The PFS was completed in April 1986. The U.S. EPA recommended that removal,
treatment, and disposal of lagoon liquids and contaminated sludges, sediment
and soil at offsite RCRA permitted facility is an appropriate, cost-effective,
operable unit remedial response action. . -
~he 21-day public comment period to review the PFS was cond~c~~9 from
April 14, 1986 through May 5, 1986. The Forest Township Library, in the
Forest Township Hall, served as a'repository for two copies of the study.
MDNR issued a press release in the Flint Journal on April 15, 1986 announc-
ing the availability of the study, the public comment period, and the
April 21, 1986 public meeting to present the findings of the PFS and provide
an RIfFS update.
The public meeting on the evening of April 21, 1986 included approximately
40 attendees. A CIC meeting was held in the afternoon of April 21. The
community was receptive to the presentation of the PFS and supported the
recommendation for action on the lagoons. Some citizens expressed concerns
that they had been dealt with "unfairly" in past occurrences at the site.
This appears to be related to the way hazardous wastes have been handled in
their neighborhood. The recommended alternative of the PFS, offsite disposal
of the site Tagoon wastes, was expressed by some citizens as the only
acceptable option for remedial action on the lagoons.
Other community relations activities at the Forest Waste Disposal Site
include public distribution of six fact sheets. There;s an active mailing
list of approximately 200 surrounding residents who receive these fact
sheets. The fact sheets summarize site activities, findings, a~d future plans.
h
Comments and Responses
Three parties submitted written comments on the PFS.
Comment No.1: A resident adjacent to the Forest Waste Disposal Site is
pleased that cleanup action on the lagoons is proposed. The Genesee County
Health Department supports the selected alterna~ive as the most appropriate
means to address the cleanup of the lagoon area.
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-3-
Response: Tne U.S. EPA acknowledges the support of the community resident
and the Genesee County Health Department.
Comment Nos. 2 through 7 were submitted by common counsel for the Forest
Waste Coordinating Committee, which is comprised of a number of the
Potentially Responsible Parties (PRPs) for the site.
Comment No.2: The phased approach towards site remediation at the Forest
Waste Disposal Site is inappropriate. The risk assessment presented in
Chapter 2 of the Phased Feasibility Study (PFS) does not establish a
significant health or environmental risk to warrant or justify immediate
remedial action. The intake of contaminants by human population, resulting
from ingestion of lagoon sediment, is the only potential route of exposure
of lagoon contaminants quantitatively assessed and estimated in the PFS.
The PFS fails to consider that the fence surrounding the site adequately
protects against the public health threat of direct ingestion of lagoon
sediments.
Response: Pursuant to Section 300.68 (c)(1) of the NCP, the operable unit
remedial action on the Forest Waste Lagoons is proposed at this time. The
phased approach towards site remediation is appropriate. The Agency is
acting within its authority to select an operable unit remedial. action for-
the site lagoon_s, and to implement this remedy before selection.-of final'
remedial action. =-- ,..&
Chapter 2 of the PFS establishes that a remedial response action on the
lagoons is appropriate. Consistent with Section 300.68 (a)(1) of the NCP,
the proposed remedial action is "consistent with permanent remedy to prevent
or minimize the release of hazardous substances of pollutants or contaminants
so that they do not migrate to cause substantial danger to present or future
public health or welfare or the environment".
Chapter 2 of the PFS does not intend to "establish a significant health or
environmental risk to warrant or justify immediate remedial actionll as the
commenters charge. Chapter 2, rather, characterizes the potential adverse
effects to human health or the environment, posed by the hazardous substances
in the site lagoons, assuming no further remedial action and no restrictions
are placed on'the future use of the property (See page 2-1 of PFS).
As the commenters mention, the PFS quantitatively assesses the public health
effects of exposure to lagoon contaminants from direct ingestion of lagoon
sediments. The conclusion of the quantitative assessment is as follows:
(,
If the site is used for recreational and/or residential purposes,
protection of the public health against toxicity of noncarcinogens,
as measured by comparison of projected contaminant intake to .
acceptable intake, would be a concern, especially for children.
The PFS also presents an array of potential direct contact exposure pathways
(i.e., human ingestion, human inhalation, human dermal absorption, wildlife
ingestion, etc.) of lagoon contaminants to the surrounding public and
environment (See Table 2-1 of PFS).
It is not possible, practical, or necesary to giv~ an in-depth quantitative
assessment of the public health and environmental impacts of exposure via
all these pathways. Specific infor~ation about ~~e site contamination and
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-4-
a body of sClentific information to determine public health and environmental
effects from site contaminants via all these pathways has not been developed.
Acknowledgement of these potential exposure pathways, without quantitative
assessment, is appropriate and valid.
The PFS also presents the lagoon wastes as a threat to the public health
and the environment relative to their connection to the groundwater (See
page 2-2.of PFS). Current data indicate that the lagoons have releasea-
contaminants to the groundwater. The extent of the existing groundwater
contamination and the potential for future contaminant contributions are not
yet fully defined. Additional field activities are scheduled to better
define these issues. The PFS, therefore. did not present a quantitative
assessment of the public health and environmental impacts of contaminant
release to the groundwater. This release, and potential for further release.
does clearly merit mention in a characterization of the adverse human
health and environmental effects of lagoon contaminants.
The PFS adequately considers the adequacy of the fence surrounding the site
and determines that remedial response actions beyond fencing are appropriate.
The fence surrounding the site serves to reduce, rather than prevent exposure
of site contaminants to the public (See page 2-4 of PFS). There is much-
evidence that unauthorized personnel~ve violated the fence a~d entered the
site, despite efforts by U.S. EPA and MONR to discourage such occurrences~
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Residents adjacent to the site have reported to U.S. EPA'and MONR observing
unauthorized personnel and vehicles inside the fence. The fence gates and
locks have shown signs of obvious tampering. Tracks from unauthorized
vehicles have been observed onsite by U.S. EPA and MONR.
The fence does very little to prevent exposure of site contaminants to the
environment. Wildlife freely enter and leave the site. As mentioned above,
current data indicate that the lagoons have released contaminants to the
groundwater. Remedial action(s) beyond fencing is appropriate, recognizing
the presence and utility of the fence. .
Section 300.68 (c)(3) of the NCP states "Implementation of operable units
may begin before selection of an appropriate final remedial action if such
measures are 'cost-effective and consistent with a permanent remedy." Chapters
3. 4, 5, and 6 of the PFS established the recommended alternative as cost-
effective and consistent with the permanent remedy.
Implementation of the operable unit remedial response, prior to selection
of the final remedial measure, is appropriate. There is full definition of
the lagoon wastes, which is a major source of contamination at the site.
Current data indicate that the lagoon contaminants have been released to
the groundwater. To alleviate this and other act~al or potential further
releases of lagoon contaminants to the environment and surrounding public,
the operable unit remedial action should be implemented prior to selection
of the final remedy.
~
Comment No.3: The recommended alternative is inappropriate and not cost-
effective. Selection of the recommended alternative is inconsistent with
the NCP due to the following:
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1)
Section~00.68 (e)(2) of the NCP mandates that the following, as
appropriate, shall be considered in determining whether and what type
of remedial actions will be considered at a site:
ii)
iv)
Routes of exposure
Hydrogeological factors
vf Current and potential groundwater use
vi 1)
The extent to which the source can be adequately identified
and characterized
The PFS did not evaluate the above considerations.
2)
The recommended alternative is not cost-effective because its cost is
double that of Alternative 2 and three times that of Alternative 3.
Response: The purpose of the PFS is to evaluate remedial technologies in
order to recommend an appropriate, cost-effective operable unit remedial
measure. The PFS concludes that the recommended alternative is appropriate
and cost-effective.
The four factors which the commenters charge have not been torts1dered, have,
indeed, been adequately considered. The routes of exposure of contaminants
(ii) are comprehensively discussed in Chapter 2 of the PFS. The appropriate
hydrogeologic factors about the site (iv) are mentioned i'n Chapter I, pages
1-7 and 1-8 of the PFS. Mention of residential wells on page 1-7 indicates
that the groundwater in the area is used (v) for drinking water. The lagoon
wastes are the source of contamination and are adequately identified and
characterized (vii) in Chapter 1 of the PFS. Records concerning the
composition of the source are available and are summarized on page 1-8.
Analytical data about the source were collected from 1978 through 1984 and
are summarized on pages 1-8 through 1-22.
Chapters 3,' 4, 5 and 6 of the PFS established th2 recommended alternative
as cost-effective.
.
Clearly, factors other than cost merit considera~ion in a cost-effectiveness
determination. The commenters' conclusion that Alternative No.1 is not
cost-effective becase its economic costs (i.e., present worth value) exceed
those of Alternative~ Nos. 2 and 3, is not valid. In accordance with the
NCP [Section 300.68(i)], other factors were considered and evaluated in the
cost-effectiveness evaluation of alternatives. Section 300.68 (i)(2) states:
'.-
"In selecting the appropriate extent of renedy from among alter-
natives that will achieve adequate protection of public health
and welfare and the environment in accordance with 300.68 (i)(1),
the lead agency will consider cost, technology, reliability, .
administrative and other concerns, and their relevant effects on
public health and welfare and the environment."
Alternative Nos. 1, 2, and 3, which were developed and analyzed in Chapter 6
of the PFS, were the remedial alternatives considered.
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Technology,-reliability, and administrative concerns are valid cost-
effectiveness considerations. If anyone of these components is poor or
complicated, additional unexpected costs can be incurred. Alternative No.1
is clearly superior to Alternative Nos. 2 and 3 in terms of technology and
reliability.
Alternative No.1 uses the most simple, straight-forward technology of the
three alternatives. Conventional construction methods are used in implementing
this remedy and results are realized within approximately one month after
initiation of construction. Alternatives Nos. 2 and 3 are more complex and
require more time than Alternative No. I, and may be difficult to implement
due to Michigan law regulations.
All three alternatives involve the handling and disposal of hazardous and/or
solid waste. The Michigan Hazardous Waste Management Act (Act 64) and the
Michigan Solid Waste Management Act (SWMA) regulate the waste handling and
disposal procedures proposed in the three alternatives. The technical
requirements of these two laws must be satisfied or delays in implementation
can be expected. '
Both of these laws impose permitting requirements. The NCP states that -
State permits are not required for Fund-financed remedial actions [40 CFR
Section 300.68 (3)]. It is, however, the intention of the £ERClA program
to comply, as appropriate, with all the technical requiremi~ts of any State
permits when implementing Fund-financed remedial actions'. If the technical
requirements of State permits are substantially more stringent than Federal
requirements and would involve substantial additional costs, compliance
would likely not be appropriate. The technical requirements of applicable
and/or relevant Michigan environmental laws are not more stringent than
applicable and/or relevant Federal requirements for the Forest Waste operable
unit. The technical requirements of the two State laws are not met for
Alternative Nos. 2 and 3 as written, and this may prevent and/or delay
smooth implementation of these alternatives. All technical requirements of
Act 64 are easily met for Alternative No.1. The SWMA is not applicable to
Alternative No.1.
The ~agoon sediments from lagoon No.4 are the only wastes being addressed
in t~is operable unit that are defined as hazardous under Act 64. Data
collected to date indicate that wastes from lagoon No.4 only have hazard-
ous waste characteristics (ie.: E.P. Toxicity results from sampling
indicates lead exceeds specific E.? Toxicity li~it of 5.0 mg/l).
Act 64 impacts the implementation of Alternative No.1 to a slight degree.
Wastes from lagoon No.4 can be handled as described after meeting the
technical requirements for a treatment facility permit under Act 64. The
solidification is considered to be a form of treatment under Act 64. The
requirement would involve an evaluation of the potential air emissions
problem associated with the proposed treatment, and an evaluation of pro-
tective measures proposed to deal with this potential problem.
In Alternative No.2, the treatment of lagoon No.4 sediments would also
require compliance with the technical requirements of Act 64 for a treat-
ment facility. Furthennore, an evaluation of the waste after treatment
would also be needed before the waste was land disposed in lagoon Nos.
2 and 4. If the waste remained characterized as hazardous, the technical
requirements of an Act 64 disposal facility would need to be met. This
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would irnolve the installation of a double liner and leachate collection
system. If the waste, after treatment, was no longer characterized as
hazardous, the wastes would need to be disposed of in accordance with
the technical requirements of the SWMA. This waste would be considered
non-inert material and, therefore, require disposal in a type II landfill.
This would require the installation of a single liner and leachate collec-
tion system. Alternative No.2 obviously does not meet the technical
requirements of Act 64 and/or SWMA.
In Alternative No.3, lagoon No.4 sediments are not removed during treat-
ment or disposal. Therefore, since these wastes were disposed of prior
to 1980, Act 64 regulations and associated permitting requirements are
not applicable. These wastes should be handled in accordance with the
technical requirements of the SWMA. As in Alternative No.2, this would
require installation of a single liner and leachate collection system.
Alternative No. 3 o~iously does not meet the technical requirements of the
SWMA.
Alternative Nos. 2 and 3 require operations and maintanence (0 & M), which
incur 0 & M costs indefinitely. Alternative No.1 has' no 0 & M.
Alternative No.1 incorporates the use of operationally routine waste
handling technologies. The solidification treatment has prov~n,9ftrformance'
for stabilizing waste. Disposal of the solidified waste wilt-be in a RCRA-
compliant facility which is considered a highly reliable disposal option.
A double-liner and leachate collection system will insure proper contain~ent
of the waste. '
Alternative Nos. 2 and 3 incorporate the use of less routine waste hand-
ling technologies than Alternative No.1. The intention of the preci-
pitation'treatment in these alternatives is to pr~ent solution of metals,
but not organic contaminants, to the groundwater. Alternative No.2 pro-
vides for a solidification treatment, but Alternative No.3 does not. In
both alternatives, the waste is land disposed onsite in an area poorly
suited for land disposal. The groundwater table onsite is shallow (8 to 30
feet below the ground surface). A surface water tody, Butternut Creek, is
appro~imately 2500 feet east of the lagoons, and residents are adjacent to
the sTte. The'land disposal option in Alternative Nos. 2 and 3 do not
provide for a double liner and leachate collection system, and in fact,
provide for no physical barrier underneath the lar.d disposed waste. Alter-
'native No.2 depends solely on the precipitation/ solidification treatment
and cap to prevent further groundwater contamination. Alternative No.3
depends solely on the precipitation treatment to pr~ent further groundwater
contamination.
In a complete cost-effectiveness analysis, Alternctive No.1 is clearly
superior to Alternative Nos. 2 and 3 in terms of technical implementability
and reliability. In order to approach the standard of reliability proJided
in Alternative No. I, Alternative Nos. 2 and 3 wo~ld need to pr~ide far
a double-liner and leachate collection system. This would require an
increase in capital costs likely exceeding the estimated additional costs
of Alternative No.1. Even with a double liner and leachate collection
syste~, Alternative Nos. 2 and 3 would not pravid2 the reliability of
Alternative No.1 because of the poor suitability of the site for land
disposal. The technical implementability of Alte~native Nos. 2 and 3
would, furthermore, become significantly more complex with the addition of
a double liner and leachat~ collection system.
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The technology (excavation and transport) in Alternative No.1 has been
demonstrated and is considered reliable. Alternative Nos. 2 and 3 rely
on a treatment techology which has not been tested on the Forest Waste
lagoon wastes. This treatment technology, furthermore, addresses only
the inorganic waste contaminants. The known organic wastes would be
unaffected by the treatment.
In a complete cost-effectiveness analysis, Alternative No.1 is a cost-
effective remedial measure. Demonstrated easily implemented technology and
superior reliability associated with this alternative support its selection.
Comment No.4: The selection of Alternative No.1 ignores the U.S. EPA
Offsite Response Action Policy (hereafter, Offsite Policy) [Federal
Register, Volume 50, No. 214, pages 45933-45937]. Lack of consideration
of treatment and recycling/refuse technologies, onsite remedies, and
permanent solutions render selection of Alternative No.1 inconsistent
with the Offsite Policy.
Response: The Offsite Policy establishes U.S. EPAls policy for consider-
ation of treatment technologies for response actions, whenever feasible,
and establishes criteria for selecting any offsite storage, treatment, -
or disposal facility necessary in CERCLA actions. The purpose .of this
policy is to foster the use of more permanent solutions to Qa~~tdous
substances, including permanent methods for managing hazardOUs substances.
The policy does not necessarily endorse onsite remedies as the commenters
claim.
A detailed discussion of potential treatment and recycling technologies
for site remediation is presented in Chapter 3 and screened in Chapter 4
of the PFS. In Chapter 5, a solidification treatment technology is
incorporated into Alternative No. I, a chemical precipitation/solidi-
fication treatment is incorporated into Alternative No.2, and a chemical
precipitation treatment technology is incorporated into Alternative No.3.
Offsite treatment and discharge of lagoon liquids is incorporated into
all three alternatives. These considerations of treatment and recycling
technologies are in accordance with the Offsite Policy. The goal to
fosttr more permanent solutions to hazardous substances is achieved by
selection of Alternative No.1 which incorporates the use of solidification
treatment technology for the lagoon sludge and an offsite RCRA treatment
technology for the lagoon liquids.
The offsite disposal facility to be used in Alternative No.1 will comply
with the applicable technical requirements of RCRA, pursuant to the Off-
site Policy. Selection of such a facility fosters the use of more perma-
nent methods of managing hazardous substances. The onsite land disposal
options incorporated in Alternative Nos. 2 and 3 do not provide for
facilities which are in compliance with the technical requirements of RCRA,
and further requirements of the Offsite Policy, and in this sense do .
not foster the use of more permanent methods of ~anaging hazardous sub-
stances. This renders support of the selection of Alternative No.1 over
Alternative Nos. 2 and 3.
The selection of Alternative No.1 clearly considers and follows the Off-
site Policy. Selection of this alternative fosters the use of more
permanent solutions to hazardous substances.
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Comment No: 5: The PFS does not discuss or consider the problem of locating
an offsite RCRA landfill facility which is capable of handling the waste in
the geographic proximity of the site.
Response: The PFS costs are based on an offsite RCRA landfill facility
approximately 100 miles from the site, Wayne Disposal in Bellville, Michigan.
Currently Wayne Disposal is not in compliance with Offsite Policy. It is
expecteG, however~ that at the time of remedy implementation, Wayne Disposal
will galn compliance with the Offsite Policy, and therefore, render itself
available to accept the Forest Waste Disposal lagoon wastes.
If this facility is not in compliance with the Offsite Policy at the time
of remedy implementation, disposal of the waste at a compliant facility a
greater distance from the site may be considered. A cost evaluation of the
use of such a facility will be made at that time to determine if the facility
can be used at a cost within the order-of-magnitude cost estimate presented
in the PFS. If not, U.S. EPA, in conjunction with the MDNR, will decide
whether to spend additional funds to take the waste to the more distant
facility or to keep the waste at the site until Wayne Disposal comes into.
compliance. Remediation for the liquids and the treatment for the solids
can be accomplished without landfill availability. -
Comment No.6: Alternative Nos. 2 or 3, or some stmi1ar ~em~dja1 action,
are more appropriate than Alternative No.1. Alternative ~oi. 2 and 3
are cost-effective remedial measures. .
Response: The discussion of the cost-effectiveness of Alternative No.1,
presented in the Response to Comment No.3, supports the selection of
Alternative No.1 over Alternative Nos. 2 and 3.
Comment No.7: Alternative Nos. 2 and 3 have been improperly dismissed
from consideration based upon illusory regulatory problems. These
problems are as follows:
1.
Alternative Nos. 2 and 3 do not attain all applicable Federal
requirements.
-
; 2.
Alternative No.2 may violate RCRA regulations.
Alternative Nos. 2 and 3 must obtain disposal facility permits
under Michigan's Hazardous Waste Management Act.
3.
Res~onse: Alternative No.1 was chosen as the cost-effective remedial
actlon over Alternative Nos. 2 and 3 based on considerations of technical
implementability and reliability as presented in the Response to Comment
No.3. Alternative No.1 was also chosen over Alternative Nos. 2 and 3
because it better protects public health and the environment and it is
more consistent with permanent remedy at the site. Alternative Nos. 2
and 3 were not dismissed from consideration based on illusory regulatory
problems. .
The statement in the PFS that implementation of Alternative Nos. 2 and 3
would require disposal facility permits under the Michigan Hazardous Waste
Management Act (Act 64) is incorrect. Likewise, the statement in the PFS
that implementation of Alternative No.1 would require an onsite treatment
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facility permit under Act 64 is also incorrect. As mentioned in the Response
to Comment No.3, Section 300.68 (a) (3) of the NCP indicates that State
permits are not required for Fund-financed CERCLA remedial actions.
However, as also mentioned in the Response to Comment No.3, it is the
intention of the CERCLA program to comply with the technical requirements
of State permits. The technical requirements of Act 64 are easily met in
Alternative No.1. The requirements of Act 64 and/or the SWMA are not met
in Alternative Nos. 2 and 3. While this fact would not make these alter-
natives impossible to implement, it does render them less desirable and
more difficult to implement than Alternative No.1. The State can exercise
the option to withhold their support and 10 percent cost share for any
alternative. If a g~ven alternative does not comply with the technical
requirements of State permits, as is the case in Alternative Nos. 2 and 3,
it is likely that the State would withhold their support and 10 percent
cost share. Without the State cost share, a Fund-financed remedy cannot be
implemented. .
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