United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-86/037
September 1986
&EPA
Superfund
Record of Decision
Burrows Sanitation, Ml
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TECHNICAL REPORT DATA
(Please read Instructions on the ,evene before completing)
1. REPOAT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R05-86/037
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECIS ION September 30, 1986
Burrows Sanitation Site, MI 6. PERFORMING ORGANIZATION CODE
7. AUTHOR/S) 8. PERFORMING ORGANIZATION REPORT NO.
g. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. A8STRACT -
The Burrows Sanitation site is a ten acre site located on 54th Avenue in Hartford ..
Township, Van Buren County, Michigan. This site was used for dewatering and disP8sing
of metal hydroxide sludges, waste coolants, and soluble oils. Located within a
three-quarter mile radius of the site are approximately 150 people living in thirteen
permanent residences and a trailer park. These homes obtain water from private wells.
Access to the site is restricted by a snow fence, but some sections of the fence are in
poor condition, allowing sportsmen and skiers easy access. Two wetland areas, the East
Westland and the Northwest Wetland, are located on the eastern and northwestern edges of
the site. The Northwestern Wetland was created artificially by the construction of an
earthen dam. In July 1984, under a CERCLA Administrative Order by Consent, responsible
parties excavated and removed sludges and contaminated soils from four onsite waste
disposal areas. Sampling of these areas indicates that the former source materials were
removed so they no longer present a potential health threat via direct contact or
ingestion. Wastes similar to the excavated wastes remain in the newly identified Spill
Area No. 2. Principal contaminants include chromium, copper, lead, nicke 1, zinc, and
cyanide. Test results also indicate that the surface water and sediments in the
Northwest Wetland and drainage canal have been impacted by the site. In addition,
onsite monitoring wells indicate a limited chemical plume or plumes related to site
(See Attached Sheet)
17. KEY WORDS AND DOCUMENT ANAL YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Burrows Sanitation Site, MI
Contaminated Media: ground water, surface
water, soil, sediment
Key contaminants: heavy metals, inorganics
1B. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Report) 21. NO. OF PAGES
None 52
20. SECURITY CLASS IT/,is pagel 22. PRICE
None
.
!,. 1'0'''' 2220-1 (R.... 4-77)
,"".YIOUI EOITION IS OeSOL.ETE
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EPA/ROD/R05-86/037
Burrows Sanitation Site, NY
16.
ABSTRACT (continued)
activities. Residential wells in the site vicinity have not been impacted
by site contaminants.
The cost-effective remedial action selected for this site includes:
purge and treat the contaminated ground water for approximately 3 years,
drain the artificial Northwest Wetland; remove and treat approximately 250
cubic yards of metal hydroxide sludge from Spill Area No. 2 and the
Northwest Wetland; and dispose the treated waste at an offsite RCRA
facility. Total estimated capital cost for the selected remedial action
ranges from $1,256,700 to $1,335,400 depending on the distance to the
offsite RCRA facility with O&M costs of $115,000.
~
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site:
Burrows Sanitation, Hartford, Van Buren County, Michigan
Documents Reviewed
I have reviewed the following documents describing the analysis of the cost-
effectiveness of remedial action alternatives for the Burrows Sanitation Landfill.
o Remedial Investigation Report, Burrows Sanitation
o Feasibility Study, Burrows Sanitation Landfill
o Public Comments and Recommendations
o Responsiveness Summary
Landfill
Description of Selected Remedy
o Purge and treat for approximately 3 years the contaminated groundwater.
o Drain the artificial Northwest Wetland.
o Remove and treat approximately 250 cubic yards of metal hydroxide sludge
from Spill Area No.2 and the Northwest Wetland. Dispose the treated
waste at an off-site RCRA facility which is in compliance with the EPA
po 1 i cy .
Declarations
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), 42 U.S.C. 9601 et ~., and the National Contin-
gency Plan (40 CFR Part 300), I have determined that the above multi-action
remedy is a cost-effective remedial measure which attains or exceeds applicabl
or relevant and appropriate Federal public health and environmental requiremen.
that have been identified at the site, and provides adequate protection of
public health, welfare and the environment. I have also determined that the
actions described herein are cost-effective when compared to other remedial
actions reviewed, in accordance with the National Contingency Plan. The State
of Michigan has been consulted, and their comments have been incorporated into
the Record of Decision. In addition, the groundwater and Northwest Wetla~d
remedies will require future operation and maintenance to ensure the continued
effectiveness of the remedy. These activities will be considered part of the
approved action and eligible for Trust Fund monies for a period not to exceed
5 years.
I have also determined that the multi-action remedy has been approved for
funding from the Hazardous Substance Response Trust Fund.
~
~~~er ~llqK'.
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SIIMMARY OF REMEnIAL ALTERNATIVE SELECTION
1.
RIJRROWS SANITATION
SITE LOCATION AND nESCRIPTION
The Rurrows Sanitation (~urrows) site is locaterl on 54th Avenue in Hartforrl
TO''lnship, \fan Ruren r.ounty, Michigan (Figure 1). It comprises approximately
ten acres in a rural area one mile northeast of Hartford. The site occupies
the southeast quarter of the northeast quarter of Section la, Township 3 South,
Range 1~ West. Rurrows was placerl on the National Priorities List (NPL) in
Septemher 19A4.
There are approximately 150 people living in thirteen permanent residences and
a trailer park locaterl within a 1/4 mile radius of the site. All the homes
ohtain water from private wells that vary in depth from 45 to 100 feet.
A large numher of hardwoorl trees exist within the site bounrlaries. In addition,
the site exhibits some evirlence of wilrllife. Access to the site was unrestricted
until 19A4which permitted hunters, cross-country skiers, anrl nature enthusiasts
to frequent the area. A snow fence harrier was constructed around the site in
early 19R4, hlJt some sections of the fence are in poor condition allowing easy
access.
There are two wetland areas, the East Wetlanrl anrl the Northwest Wetlanrl, along
the eastern anrl northwestern edges of the site. The Northwest Wetlanrl was
artifically createrl hy the construction of an earthen dam. The wetlanrl areas
are interconnecterl and drained hy a drainage canal known as the noyle Orain
which flows along the northern perimeter of the site. The noyle ~rain enters
the Paw Paw River ahout 3/4 mile to the southwest of the site. .
The on-site waste disposal areas identified prior to the Remedial Investigation/
Feasibility Study (RI/FS) inclurled the following:
o Spi 11 Area
o "'ashout Areas
o Cyani de Trail
o Unlined Pits
No.1 to n
- locaterl at the northwest area of the site. The
Spill Area was approximately ISO feet hy 40 feet
with a slope towarrls the northwest.
- locaterl in the northeast portion of the site.
There was an 'Ipper ~Iashout Area anrl a Lower
Washout Area. The total of both washout areas
was approximately 3n,OOO square feet.
- locaterl in the southcentral anrl southeast por-
tions of the site. The Cyanide Trail was about
400 feet by 30 to 40 feet with a gentle slope towarrls
the east.
locaterl in the central part of the site. The pit
areas varied from ahout 20 feet to 100 feet by
100 feet.
Sludges and contaminated soils were removed from these previously irlentifierl
waste disposal areas in 1qA4. These areas are referred to collectively
-------
. .,
S/-rt!!
Loc:tf!a-l-i 0,.,
- p
'--Stoughton ~:
. 1 Corners \,
s .. 2 './..
.~'
.
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- - (Ij~ :. ~ ~.T~tler!>wlt - ~ .. .-:
..::::J ~.. -, f"., .. . 10 "-, ' ~ -. AVfNClf
~ OtSOClSlI.. .' ~R" . / ,UD ; " .,~ - .; 11
~~. ::.' '... '"'. c -
..' ",/ . -:;;::~,' .... ; 0 -~
~... ~" .. ,-', : .. -~. - - ~
,- i .1',/ .. ~ . 'Q' ~ . ,
--~-'---~:~.. ~... " Cit-.Pits- .
~ . . ",' ,. - ~ '. : ':. - :...
- -. ,~,'. .. ::. * - '''' :-- - -.. .- ~. - --
. ;- ;:I':~:-: . - .\' " i .
«' ',~t-~.~~~ '.~~'--' .._~ I PVT 11.3'.1 _/ \
. S-'LL (";;--;4 ~~---- - I \
,-, 'a -----<, V) SITE BOUNOARY
I .AREA r:._) \ 14 \
No. 2 I \ I
I PIT III I
.. \; ., CAS T
"-_/ . I J WETLAND
r:~~~~~ TRAIL /
,_/ /----', '~-----) I
~--- ------- h
a-JIl-JIl- -IJ'
DOYLE DRAIN
NDRTHWEST
WETLAND
SEDIMENTS
-.-
o
,
'........
--
--
--
/
/
"
--
--
o
o
I
o
NORTH
100 .200 ..300
. . I
.seAL E, FT:
FIQ.
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-3-
"
o In 1QA?, the MDNR installerl three monitoring wells anrl performerl a
limited hydrogeological investigation of the site. The investigation
indicaterl ground water contamination at the site. In arldition to
previously discovered conta~inants, styrene was also found in a water
sample from one well (MDNR 1) at a concentration of 110 ugf1. The
source of the styrene was never determinerl.
o In March 1q~3, the I/nited States tnvironmental Protection Agency (J:PA)
Field Investigation Team (FIT) contractor installed seven adrlitional
monitoring wells at the site.
o I n October 19A3, the MnNR su rvayerl the site and rli scovererl a black
tarry material in Pit No.4.
o In January 19A4, a toxicologist with the HnNR rleterminerl that the
metal hydroxide sludges on the surface of the site were at levels
considered hazarrlous to hu~ans upon direct rlermal contact and
inhalation.
o In February 1QA4, the EPA Technical Assistance Team (TAT) contractor
conrlucted an inspection of the site. Ouring the inspection,
samples were collected from the pits, Spill Area, "/ashout Area,
Cyanide Trail anrl noyle nrain.
o In June 19R4, the EPA issuerl a unilateral CERCLA Section 10~(a)
Arlministrative Orrler to the identifierl potentially'responsihle
parties (PRPs) to excavate and remove sludges and contaminated soil
from the site. The PRPs were Elmer Rurrows, nuane anrl Evelyn Funk,
nouglas anrl Georgia MacKinder, Auto Specialties Manufacturing Company,
Ou-Wel Products, Inc. anrl Whirlpool Corporation.
o In July 19R4, nuane and tvelyn Funk, Whirlpool Corporation,
Prorlucts, Inc. and Automotive Specialties Manufacturing Co.
in a CERClA Section 106 (a) Administrative Order by Consent
and remove sludges and contaminated soil from the site.
nu-\.Ie 1
agreed
to excavate
o I n ~1arch 1 9RS, the PRPs were gi ven the opportunity to perform
the RIfFS and, subsequently, declined.
o In August 19A5, EPA authorized Work Assignment No. RO-Sl76.5
to the REM II Team to implement the RIfFS.
o In November 1QR5, EPA initiated the RIfFS.
III.
CI/RRENT SITE STATI/S
A RIfFS at the Rurrows site was authorizerl by EPA on August 16, 19R5. The
purpose of the RI was to rletermine the thoroughness of previous clean up
activities, to evaluate the nature and extent of ground water contamination anrl
the residual soil contamination, to characterize pathways of contaminant migra-
tion off-site, and to rletermine risks to human health anrl the environment from
the contaminants.
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-4-
The RI field activities hegan in Nove~her 1qR5 and included the following:
o sa~pling and analysis of on-site and off-site soils,
0 sa~pling and analysis of on-site and off-site ground water,
o sa~pling and analysis of surface water and sediments,
o a hydrogeological study, and
o an Endangerment As~essment.
Six chemicals (chromium, copper, lead, nickel, zinc and cyanide) were selected
as representative of the former on-site sludges and were the focus of the
characterization of soils, sediments, surface water, and ground water at or
near the Rurrows site. These six chemicals are designated as the inorganic
indicator chemicals (indicator chemicals). The range of concentrations of
these chemicals found in various environmental media at and near the Rurrows
site are summarized in Table 1. The contaminants identified on-site are defined
as hazardous suhstances under Section 101 (14) of CERCLA.
The following sections present the finding of the RI as to existing conditions.
A.
Oisposal Areas
During the course of the RI data collection activity, a previously unidentified
spill area, Spill Area No.1, was discovered. Rlue-green sludge residues not
visihle at the surface were ohserved in shallow shovel-dug excavations at a
depth of one to two inches. The extent of the Spill Area No.2 is shown in
Figure 2. One horing, SL?'02, was located within Spill Area No. ? at the transi-
tion zone with natural soils (Tahle ~). This sample had a similar composition
to previously collected samples from the on-site sludges. The test results for
the unexcavated areas did not indicate any other on-site areas of heretofore
undiscovered waste deposition.
Some vegetative stress was ohserved in the trees and shruhs growing in the
Spill Area No. ? as evidenced by the lower density of vegetation than sur-
rounding areas. This lower density of vegetation is considered to he the
result of surface soil wash covering the area during anrl subsequent to disposal
activities.
The indicator chemicals occur naturally as the components of soils in the site
vicinity. Concentrations of these co~pounds measured in on-site soils in the
excavated and unexcavated areas were interpreted in the context of their hack-
ground range. The test results for the indicator chemicals at representative
hackground locations are shown in Table 2.
1. Perimeter of Excavated Areas
In the majority of on-site soil samples the residual concentrations were compar-
able to natural hackground concentrations in all locations (e.g., pit areas and
unexcavated areas). Approximately 15 percent of the soil samples exhibited
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Table 1
SUMMARY OF INORGANIC INDICATOR CHEMICAL CONCENTRATIONS
FOUND IN ENVIRONMENTAL MEDIA
BURROWS SANITATION LAMDFILL SITE
(Sa.pled between Nove8ber 20. 1985 and May 20, 1986)
Surface (1) Ground (2) Ground (I)
Waste Source(]) SoHs At Sedt.nts Water In Water In
Solh In Perl.eters Sot 11 In Background In Wetlands Wet1ands Water Nearby
Matertah Excavated of ExCivated Unucavlted Sot Is and Ooyle and Ooyle In On-Site Residential
Areas Areu Aren Dnln Ora In We11s We 11 s
.g/lIg . pp8 .g/ilg. PP8 .g/ilg. PP8 .!I/kg . pp8 8g/kg. pp8 8g/lIg . PP8 8g/l. pp8 8g/1. pp8 8g/l. PP8
Chro.tU8 960 - 84,000 NO - 1800 NO - 1650 ND - 16]0 NO - 14 ].8 - 861 ND - 5.100 ND - 0.11] ND
Copper 2900 - 15,000 NO - 1400 "D - 260 NO - 1160 NO - 20 6 - 286 0.001 - 1.520 ND - 0.15] NO - 0.012
Lead 26 - 1,200 NO - 92 "0 - 45.3 ND - 136 NO - 66 "0 - 56 "D - 0.809 ND - 0.119 NO - 0.00]
Ntckel 1500 - 40,000 NO - 900 "D - 266 "0 - 81 NO - 20 NO - 165 NO - 1.840 NO - 0.200 NO
Ztnc 520 - 13,000 13- 128 11.5 - 107 7.3 - 71 "0 - 100 8.7 - 213 0.020 - 1.620 0.130 - 7.229 NO - 0.316
Cyanide 0.9 - 63 NO - 1.8 "0 "0 - 11 "0 - 1. 7 NO NO NO - 0.010 "0
NO . Not Detected at Instru.ent Detection Level
(1) Based on Total Concentrations of Che.tcal tn Water
(2) Based on Dissolved Concentrations of Che.lcal tn Water
(3) Based on co.poslte sa.ples of wastes by EDI, July 1984
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Table 2
BACkGROUND SOIL DATA
INORGANIC INDICATOR CHEMICALS
(Sa.pled between Oeceaber II, 1985 and Oece8ber 20, 1985)
units are In .g/kg . Pp8
PARAMETERS SOUTH NORTH EAST WEST
AND 200-400 ft 1-3 .t1e 200-400 ft 1-3 .Ile 200-400 ft 1-3 .t1e 200-400 ft 1-3 .11e
DEPTH SL601 SL602 SL703 SL607 SL60B SL104 SL605 SL606 SL702 SL603 SL604 SUOl
ChrolllU8
0.0-1.5 ft 6.2 1"01 (4.2) 2.3u 2.2u 8.1 2.2u 2.2u 8.7 (2.4) (2.4) 9.5
1.5-3.0 ft 7.3 4.9 7.7 6.9 2.1u 11.0 Z.2u 2.Zu 14.0 8.1 6.0 7.4
3.0-4.5 ft (5.1) 4.3 14.0 7.9 2.3u 14.0 2.1u Z.2u 13.0 9.2 8.4 13.0
4.5-6.0 ft 11.0 4.8 12.0 8.9 2.4u 9.1 2.1u 2.2u 11.0 8.5 13.0 12.0
~
.0- .5 ft 16.61 (5.21 19.2) (6.01 1.6u 17.0 (6.1) 1"]1 (8.3) 14.9) (6.9) 17.6)
1.5-3.0 ft 1.1 (5.4 7.8) 111.0 1.6u (11.0) 12.8} 1.9 15.0 9.S) (8.6) 9.4)
3.0-4.S ft (6.3) f4.7) 11.0 14.0) 1.7u 20.0 1.6 5.0) 16.0 (12.0) 15.0 (12.0)
4.5-6.0 ft (6.3) 4.5) 19.0 13.0) 1.8u (14.0) (3.5 5.6) 16.0 (12.0) 19.0 (11.0)
lead
0:0:1.5 ft 6.7 13.0 12.0 9.1 16.0 66.0 16.0 8.9 8.1 30.0 29.0 9.9
1.5-3.0 ft 20.0 3.6 5.2 12.0 2.7u 6.1 6.5 2.7u 12.0 6.7 7.9 7.0
3.0-4.5 ft 6.5 2.7u 6.0 14.0 2.8u 8.0 - 4.3 3.3 6.5 11.0 22.0 9.4
4.5-6.0 ft 5.7 2.8u 5.4 11.0 3.0u 5.7 2.7u 3.4 5.6 11.0 12.0 9.5
Nickel
o:o:T:"s f t (5.4) 3.8u 4.2u 4.Ou 3.8u (7.41 3.9u 3.9u (6.6) 4.0u 4.Ou (9.31
1.5-3.0 ft 16.6) 4.9u (8.21 (7.8} 3.7u 110.0 3.8u 3.8u 112.0) 19.11 (4.6) (10.0
3.0-4.5 ft 4.6) 3.8u p2.0 p1.0 4.Ou 20.0) 3.7u 3.8u 15.01 8.4 (16.0) (14.01
4.5-6.0 ft 8.4) (4.8) 14.0 13.0 4.2u 15.0) 3.7u 3.9u (14.0 (11.0) (16.0) (14.0
Zinc
0:0:1.5 ft 31.0 23.0 35.0 19.0 r.8} 100.0 15.0 18.0 26.0 14.0 18.0 39.0
1.5-3.0 ft 34.0 22.0 28.0 31.0 1.1 40,0 (11.0} 15.7} 54.0 25.0 23.0 39.0
3.0-4.5 ft 26.0 12.0 41.0 43.0 1.4 49.0 f5.3 8.9 47.0 33.0 34.0 6!\.0
4.5-.6.0 ft 30.0 (10.0) 52.0 54.0 1.2u 37.0 7.1 (9.7 49.0 32.0 45.0 51.0
Cyanide"
0.0-1.5 ft 0.56u 0.55u 0.6u 0.57u O.SSu 0.59u 0.56u 0.56u 0.58u 0.57u 0.51u 0.58u
I.S-3.0 ft 0.56u 0.56u 0.62u 0.57u 0.53u 0.61u 1.1 0.S4u 0.61u 0.56u 0.56u 0.58u
3.0-4.5 ft 0.6u 0.54u 0.6u 0.6u 0.57u 0.62u 0.5Ju 0.55u 0.59u 1.7 0.58u 0.59u
4.5-6.0 ft 0.57u 0.S1u 0.61u 0.6u 0.6u 0.6u 0.97 0.56u 0.S9u 0.S6u 0.59u 0.6u
Notes:
u . Indicates the ele.ent ~as analyzed for but not detected. The detection 11.lt value preceeds u (e.g. IOu).
() . Indicates the result Is a value 9reater than or equal to the InstrU8ent detection 11.lt but less than the contract required detection
limit (e.g. (10»
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- 5 -
higher concentrations of one or more indicator chemicals than the upper li~it
of background concentrations (background). Most perimeter saMples slightly
exceeded hackgrounrl. r.oncentrations ahove hack ground were found mostly at the
perimeters of and within the excavated areas. The elevated concentrations were
generally confined to the upper soil layer and were within one foot of the
ground surface (Table 3 and Figure 3).
Additionally, soil samples fro~ central locations in Pits No.1 and 4 were
tested for pri ority pollutant organi c compounrls. The pu rpose of thi s test i ng
was to assess the composition of a black tarry material founrl in certain areas
of the site. The priority pollutant analyses did not reveal the presence of
detectable organic compounds.
Visual observations by RI field personnel further support that no significant
quantities of wastes re~ain at the excavation perimeters. Limited a~ounts
(a few shovel fulls) of waste residue were visually noted along the r.yanirle
Trail Area excavation (Sa~p1e No. SL003 CN). ~inima1 waste residue was visually
noted on the peri~eter of the other excavations. The test results for the
indicator chemicals in soils adjacent to all the excavated areas are shown in
Tah1es 3 and 4. Collectively and individually, the results for the soil samples
within the excavation peri~eters are below levels which would be indicative of
the presence of significant quantities of waste materials. Rased on the test
results discussed above and on the visually ohserved condition of the soils at
the excavation perimeters of the Cyanide Trail Area, Pits, Washout and Spill
Areas, the RI concluded that the former waste source materials in these areas
have heen removed hy the past removal activities so that they are no longer a
potential human health threat via direct contact and ingestion.
2. Excavated Areas
Elevated concentrations of the indicator cheMicals were measured at various
locations in the Cyanide Trail and Pits excavations. There appears to he a
trend toward a lower percentage of elevated concentrations in the interior of
the excavated areas than at the perimeters. Results for sample points within
the Washout and Spill Area excavations were within or only slightly exceeded
the hackground range. The test results for the indicator chemicals in soils
within the excavations are shown in part in Tah1e 5 and in Tah1e n.
At the on-site soil sample points where elevated indicator chemical concen-
trations were found, the highest concentrations ahove background were measured
in the samples collected from the ground surface to a one foot depth.
All results for soils helow a two foot depth were within background range.
The concentration distributions ohserved in the shallow soil profile, and the
results shown for soils at deeper depths (to the water table) appear to
indicate that the soils immediately underlying the former waste materials
effectively retarded migration of contaminants, and that the deeper soils have
re~ained largely unaffected hy the surface disposal activities. Since wastes
have been removed fro~ the site, except for Spill Area No. ?, future deterio-
ration of the quality of these soils is unlikely.
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Table 3
COMPOSITE SOil SAMPLE DATA ADJACENT TO EXCAVATED AREAS
INORGANIC INDICATOR CHEMICAlS
(Sa.pled on Nove8ber 23. 1985 and Nove8ber 24. 1985)
units are In .g/kg
PARAMETERS Sl005 Sl006 Sl007 Sl008 Sl009 SlOlO SlOll Sl012 SlOl3 SL014
A 8 A 8 A 8 A 8 A 8 A 8 A 8 A 8 A 8 A 8
CHROMIUM 303 4.4u 214 119 228 16.2 25.0 8.66 881 336 64.1 70.0 346 74.4 94.6 9.82 1120 181 28.4 9.58
COPPER 66.6 8.8u 80.2 29.2 35.8 9.3u (13.2) 9.9u 157 42.3 9.2u 9.2u 93.0 9.1u 15.4 8.7u 260 17.6 9.5u 9.0u
LEAD 3.87u 1.6u 21.7 4.92 11.1 7.31 11.7 7.48 45.3 14.7 6.87 4.05 14.1 10.8 12.4 4.2 20.0 8.0 6.88 8.18
NICKEL 120 (12.6) 266 50.9 40.1 (20.9) (25.0) (21.6) 97.4 32.9 (17.3) (12.7) 97.0 29.2 75.2 (14.2) 95.0(14.2) (18.4) 24.8
ZINC 45.7 13.2 50.6 31.5 44.8 36.0 37.5 32.8 73.9 30.6 38.1 31.2 59.4 36.4 35.3 11.5 64.6 32.4 27.3 29.3
CYANIDE 6.9u 5.5u 5.8u 5.7u 6.1u 5.8u 7.3u 6.2u 5.6u 5.6u 5.8u 5.8u 5.7u 5.7u 5.7u 5.5u 6.5u 5.9u 5.9u 5.6u
pH,Extrac-
table 6.8 5.4 6.9 6.8 5.5 4.6 5.2 5.4 7.4 6.8 7.1 6.0 5.7 7.6 7.0 7.1 6.8 5.5 6.3 5.9
7.80 7.10 6.50 6.80
Total Yolatl1e
Solids S 1.0 0.6 1.6 1.1 2.8 1.5 8.0 1.9 1.8 1.1 0.3 1.4 1.2 2.0 1.2 1.7 3.8 0.8 2.0 0.9
1.90 1.40 2.00 1.00
Notes:
r-= o' to 1 It depth
8 . 1 to 2 ft depth
u . Indicated ele.ent was analyzed for but not detected. The detection 11.lt value preceeds u (e.g. IOu).
( ). Indicates the result was7 a value greater than or equal to the InstrU8ent detection 11.lt but less than the contract required detection 11.lt
(e.g (10»).
o . Dupl1ute
Cyanide Trail: SLOOI. SL002, SL003 I SL004
Pit No.1: SL005 I SL006. Pit No.2, 3 I Washout Areas: SL007, SlOOB, Sl009, SLOI0
Pit No.5: SLOll. Pit No.4: SL012. SpIll Area: SL013 I Sl014.
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FIGURE 3
See Figure 1-3
Rerredial Investigation Report-Burrows Sanitation
August 19, 1986
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Table 4
COMPOSITE SOIL SAMPLE DATA
ADJACENT TO CYANIDE TRAIL AREA
INORGANIC INDICATOR CHEMICALS
(Sampled between November 21, 1985 and December 18, 1985)
units are in my/kg
PARAMETERS Sl004 Sl003 Sl002 SL003 SLOOI SUOl
0-1 Ft 1-2 Ft 0-1 Ft 1-2 Ft 0-1 Ft 1-2 Ft CN 0-1 Ft 1-2 Ft 3.5-5 Ft
CHROMIUM 7.5 (~.5) 79.0 8.1 1,650.0 14.0 3,410.0 14.0 6.1 6.6
COPPER 24.0 (5.2) (10.0) (7.4) 47.0 (8.2) 3,950.0 24.0 (7.2) (11.0)
lEAD 6.7 2.8u 11.0 5.5 18.0 5.2 37.0 6.3 (2.8) 7.4
NICKEL 26.0 (12.0) (12.0) (12.0) 80.0 (16.0) 3,650.0 (21.0) (17.0) (8.2)
ZINC 24.0 15.0 27.0 20.0 107.0 25.0 678.0 29.0 17.0 37.0
CYANIDE 0.56u 0.56u 0.63u 0.63u 0.63u 0.59u 60.0 0.57u 0.54u 0.57u
pH, 5.6 5.8 5.2 4.9 5.7 5.3 * 6.6 7.1 6.7
Extractable
Tota 1 Yo lat 11 e
Sol ids (I) 1.3 0.3 6.7 4.5 5.9 2.3 * 2.0 0.6 0.7
Notes:
Sl003CN was a blue green sample of mixed waste and soil located in the Sl002 sample area.
* = parameter was not tested
( ) = Indicates the result was a value greater than or equal to the instrument detection limit but less than
the contract required detection limit (e.g. (10)). . .
u = Indicates element was analyzed for but not detected. The detection limit value preceeds u (e.g. IOu).
-------
Table 5
0-6 FT MEDIUM DEPTH SOIL SAMPLE DATA
INORGANIC INDICATOR CHEMICALS
(Sampled between December 13, 1985 and December 20, 1985)
units are in mg/kg
PARAMETERS
AND DEPTH SL 208 SL 209 SL 210 SL 201 SL 202
CHROMIUM
0.0-1.5 ft (5.0) 21.0 (5.3) 2.3u 1,630.0
1.5-3.0 ft (3.9) 13.0 12.0 (2.6) 41.0
3.0-4.5 ft (4.9) 8.3 6.2 (4.1) 33.0
4.5-6.0 ft 6.4 9.4 (3.8) 6.7 (4.0)
COPPER
0.0-1.5 ft (4.7) (8.3) (9.1) 1.7u 1,160.0
1. 5 - 3 . 0 ft (4.1) (8.2) (6.0) 1.7u 38.0
3.0-4.5 ft (7.0) (7.5) (5.1) 1.7u 41.0
4.5-6.0 ft (10.0) (9.4) (4.6) (6.6) (3.4)
LEAD
0.0-1.5 ft 4.0 7.5 7.1 3.8 41.0
1. 5 - 3 .0 ft (2.9) 5.7 4.5 4.4 5.7
3.0-4.5 ft 3.3 5.8 5.2 4.0 11.0
4.5-6.0 ft 5.1 6.4 3.5 4.2 4.2
NICKEL
0.0-1.5 ft 4.0u (10.0) (4.4) 4.0u 81.0
1. 5 - 3 . 0 ft (4.2) (6.7) (8.6) 4.0u (14.0)
3.0-4.5 ft 4.0u (5.3) (4.5) 4.1u (18.0)
4.5-6.0 ft (4.9) (7.4) 4.3u 4.2u (4.0)
ZINC
0.0-1.5 ft 22.0 45.0 25.0 (2.5) 77.0
1.5-3.0 ft 15.0 52.0 42.0 (6.5) 34.0
3.0-4.5 ft 16.0 27.0 20.0 (11.0) 51.0
4.5-6.0 ft 20.0 34.0 16.0 20.0 17.0
CYANIDE
0.0-1.5 ft 0.57u 0.57u 0.6u 0.57u 6.5
1. 5 - 3 . 0 ft 0.58u 0.57u 0.60u 0.57u 0.S7u
3.0-4.5 ft 0.57u 0.58u 0.59u 0.58u 0.92
4.5-6.0 ft 0.57u 0.58u 0.62u 0.60u 0.54u
Notes:
u = Indicated element was analyzed for but not detected. The detection
limit value preceeds u (e.g. IOu).
( ) = Indicates the result was a value greater than or equal to the instrument
detection limit but less than the contract required detection limit
(e.g. (10)).
-------
Table 6
DEEP BORING SOIL SAMPLE DATA
INORGANIC INDICATOR CHEMICALS
(Sampled between December 18~ 1985 and December 19, 1985)
units are in mg/kg
PARAMETERS SL SL SL SL SL SL SL SL SL
AND DEPTH 301 302 303 304 30S 306 307 308 309
CHROMIUM
3.S-S.0ft 6.6 22.0 16.0 7.0 (3.4) 8.2 12.0 104.0 7.3
8.S-10.0ft 18.0 7.0 7.9 13.0
13.S-1s.0ft (4.4)
18.S-20.0ft 12.0
COPPER
3. S- S. Oft (ll.O) 22.0 16.0 (lO.O) (S.S) (7.8) lS.0 52.0 16.0
8.S-10.0ft 2S.0 16.0 (l4.0) 19.0
13.S-1S.0ft (10.0)
18.S-20.0ft 20.0 "
LEAD
3.5-5.0ft 7.4 10.0 9.4 4.3 4.9 5.2 8.3 19.0 7.8
8.5-10.0ft 12.0 4.8 7.7 11.0
13.S-1s.0ft 5.2
18.S-20.0ft 7.6"
NICKEL
3.S-S.0ft (8.2) (20.0)(19.0) (8.1) 4.Su (9.7) (ll.O) 74.0 (11.0)
8.S-10.0ft (18.0) 62.0 (9.9) (12.0)
13.S-1s.0ft (6.1)
18.S-20.0ft (19.0)
ZINC
3.S-S.0ft 37.0 S4.0 67.0 17.0 14.0 19.0 43.0 47.0 48.0
8.S-10.0ft 78.0 46.0 42.0 9S.0
13.S-1S.0ft 27.0
18.S-20.0ft S8.0
CYANIDE
3.S..;.S.Oft 0.S7u 0.S7u 0.S9u 0.S8u 0.64u 0.63u 0.S6u 1.1 0.S6u
8.S-10.0ft 0.60u a . S 4u -- 0.6u O.S4u
13.S-lS.0ft 0.S2u
l8.S-20.0ft O.S8u
Notes:
u = Indicated element was analyzed for but not detected. The detection
limit value preceeds u (e.g. IOu).
( ) = Indicates the result was a value greater than or equal to the
instrument detection limit but less than the contract required
detection limit (e.g (10)).
-- - Sample was not taken
-------
- r:; -
Soil samples were collected from four random locations in the Ilpper and Lower
l~ashout Areas to assess t~e oil and grease-like material observed in these
areas. Oil and grease were present in all of the samples tested at concentrations
ranging from 51 to 2q4 mg/kg. Previous analysis of t~e discolored sand in the
Washout Areas has indicated that the oil is a paraffinic suhstance which does
not contain organic priority pollutants or other hazardous constituents.
1.
Endangerment Assessment-nisposal Areas
The Endangerment Assessment indicated that exposure routes in the surface soils
can occur via dermal ahsorption and direct or inadvertent ingestion of
contaminated soil. Systemic toxicity is not expected hy dermal exposure due to
the typically low rates of dermal ahsorption of metals, particularly in the
form in which metals primarily occur in surface soils (liganrl complexes).
Rased on available studies of human sensitivity, dermatitis and sensitization
are also not expecterl to result from contact with contaminants at the concentra-
tions in the soil at the Rurrows site (Endangerment Assessment, Chapter 7,
Remedial Investigation Report, August lQ, lQR6).
Spill Area No.2 had a similar composition and visual appearance to the wastes
that were formerly present in the excavated areas. r.onsequently, it was assu~ed
that the wastes in Spill Area No.2 had similar concentrations of contaminants
as those rletected in samples of wastes from other locations on the site. It is
difficult to quantify the potential chronic health risks associated with exposure
to contaminants in Spill Area No. ? since it is only a small area within the
site anrl exposure under these conc1itions is likely to he intennitte!1t. Iising
worst case exposure assumptions (maximuM contaminant concentration and upper
hound incidential ingestion rate of 100 mg of soil), it is estimated that an
arlult woulrl ingest significant amounts of chromium anrl lead per exposure event
when compared with estimated normal intakes via other routes of exposure.
However, the likelihood that such intermittently high intakes would actually
occur and the associated toxicological significance with regarrl to chronic
healt~ effects are not conclusive.
Acute risks to human health due to ingestion of chromium and copper, the only
indicator chemicals with established acute health criteria were evaluaterl.
The estimated I-day most prohahle and worst case exposure event for a lO-kg
chi 1 d were compared with the I-day IISEPA Health Advi sory val ues for these
chemicals. Most-prohable exposure estimates were derived using the geometric
mean waste concentrations and a lower-hound soil ingestion rate of 100 mg/visit.
Horst-case estimates were derived using the maximum waste concentrations and an
upper bound ingestion rate of 500 mg/visit. Roth the most-probahle (0.15
mg/kg) and worst-case (4.2 mg/kg) estimates of exposure to chromium in soil at
Spill Area No. 7. for a 10-kg child exceeds the I-day health advisory for ingestion
of chromium. The worst-case (0.75 mg/kg) estimate of exposure to copper in
wastes at Spill Area No. ? exceeds the I-day health advisory for ingestion of
copper, although the most-prohable (0.0r:; mg/kg) estimate of exposure does not.
These results suggest that even a single visit to the Rurrows site and suhsequent
contact with contaminated soils in Spill Area No.2 may pose unacceptahle
health risks hased on consideration of acute and suhchronic health effects.
-------
-7-
The Endangerment Assessment concluded that a health risk from direct contact or
ingestion of soil does not exist outside of Spill Area No.2. The RI determined
that the residual metals concentrations were within natural background levels
in 85 percent of the samples tested; the other 15 percent of the samples were
between background levels and the maximum concentrations shown below:
Concentrations (mg/kg)*
Chemical
Burrows
Background
Geometric
Mean
Burrows
Endangerment
Assessment
Geometric
Mean
Burrows
Endangerment
Assessment
Maximum
Chromium
Copper
~~
Nickel
Zinc
4
6
9
4
21
19
11
13
11
31
1,650
1,160
136
266
107
* Includes all samples collected on-site from a depth of 0-1.5 feet.
The above concentrations define the cleanup criteria for residual contaminated
soils at the Burrow site. Soils exceeding the maximum concentrations values
listed above will need to be remediated to eliminate the potential exposures.
B.
Surface Water and Sediments
There are two wetlands adjacent to the site, the East Wetland and Northwest
Wetland. The East Wetland is located upgradient from the site and shows slight
evidence of stress on trees. The Northwest Wetland receives water from the
East Wetland via the Doyle Drain. Approximately 90 percent of the hardwood
trees in the Northwest Wetland have been heavily stressed by the increased
water depth. The stress in each wetland area is related to an earthen dam
which obstructs the natural drainage of the Northwest Wetland.
Test results for the indicator chemicals in surface water and sediment are
shown in Tables 7 through 10. These results indicate that surface water and
sediment in the Doyle Drain and the Northwest Wetland adjacent to the site have
been impacted within thirty feet by prior disposal activities. Indicator
chemicals in the surface water adjacent to the site were measured at concen-
trations exceeding Michigan Surface Water Criteria (Table 11). These criteria
are based on the ability to support aquatic life. The surface water samples
adjacent to the site in the Northwest Wetland (SW005, SW006) represent a limited
fluid quantity (a few inches of standing water) in direct contact with the
sediments. This limited quantity of fluid is considered to be representative
of sediment fluids rather than the remaining volume of wetland waters.
Oil and grease were found in surface waters in the Doyle Drain and Northwest
Wetland. The oil and grease found in the Washout Areas soils may have migrated
through the ground into the water at the Doyle Drain. Previous analyses of
-------
Table 7
SURFACE WATER DATA
(Sampled on December 12, 1985 and Decemb~r 13, 1985)
units are in ug/l for metals and cyanide (Total)
PARAMETERS SW SW SW SW SW* SW SW
001 002 003 004 005 006 007
CHROMIUM 4.0u 14.0 (8.2) 36.0 5700.0 867.0 4.0u
COPPER (9.6) 6.6 (11.0) 149.0 1520.0 647.0 (6.5)
LEAD 9.3 5. Ou 9.6 5.0u 105.0 809.0 5.0u
NICKEL 7.Ou 7.Ou 7.0u (34.0) 1840.0 193.0 7.0u
ZINC 56.0 26.0 43.0 59.0 1020.0 1620.0 20.0
CYANIDE 10.Ou 10.Ou 10.0u 10.Ou 10.0u 10.0u 10.0u
Units in mgjl
OIL & GREASE u u 3.0 3.0 6.0 34.0 2.0
Total Suspended
Solids 206.0 38.0 252.0 10.0 1720.0 6.0 38.0
Total Dissolved
So 1 ids 178.0 436.0 224.0 148.0 2960.0 308.0 270.0
Notes:
u 2 Indicated element was analyzed for but not detected. The detection limit
value preceeds u (e.g. 10u).
( ) 2 Indicates the result was a value greater than or equal to the instrument
detection limit but less than the contract required detection limit (e.g
*
(10)).
= SW005 may not represent surface water because of its high solid content.
-------
Table 8
ADDITIONAL SURFACE WATER SAMPLES
AT NORTHWEST WETLAND
(Sampled May 20, 1986)
Units in ug/l
Parameter
(Total) swooa SW009 SW010 SW011 SW012 SW013 SW014
Chromium 23 63 8u 8u 13 8u 8u
Copper (18) 28 11u 11u (12) llu 11u
Lead 11 8 6 7 10 7 9
Nickel 20u S2 20u 20u 20u 20u 20u
Zinc 31 34 (13) (16) 22 (18) (19)
-------
Table 9
SEDIMENTS DATA
INORGANIC INDICATOR CHEMICALS
(Sampled on December 12, 1985 and December 13,
units in mg/kg (ppm) unless noted
1985) -
PARAMETER SO SO SO SO SO SO SO
001 002 003 004 005 006 007
CHROMIUM (7.8) 242.0 (6.1) 867 .0 351. 0 42.0 (3.8)
COPPER (19.0) (50.0) (14.0) 286.0 81.0 47.0 (6.0)
LEAD 19.0 56.0 9.3 22.0 12.0 43.0 3.2u
NICKEL (9.9) (21.0) 5.9u 165.0 101. 0 (19.0) 4.5u
ZINC 47.0 110.0 27.0 213.0 84.0 85.0 (8.7)
CYANIDE 1.1u 2.9u 0.85u 0.93u 0.72u 1.8u 0.64u
OIL & GREASE 166.0 312.0 188.0 179.0 126.0 236.0 95.0
TOTAL. VOLATILE 78~ 40~ 63~ 62~ 82~ 46~ 82~
SOLIDS
Notes:
u
8 Indicated the e~ment was analyzed for but not detected. The detection
limit value preceeds u (e.g. IOu).
() = Indicates the result was a value greater than or equal to the instrument
detection limit but less than the contract required detection limit (e.g
(10)).
-------
Table 10
ADDITIONAL SEDIMENT SAMPLES
AT NORTHWEST WETLAND
(Sampled on May 20, 1986)
Units in mg/kg
Parameter
(Tota 1 ) SD008 S0009 SD010 S0011 S0012 SD013 S0014
Chromium 21u 102 18u 49 7 20u 14
Copper 28u (48) 25u 22u 7.3u 27u llu
Lead 12 26 13 36 8 22 32
N f c ke 1 52u (43) 4Su 40u 13u SOu 20u
Zinc 23u 19u 20u (32) 6u 22u (17)
4t
-------
TABLE 11
COMPARISON OF EXPOSURE POINT CONCENTRATIONS IN SURFACE WATER
IN THE NORTHWEST WETLAND ADJACENT (WITHIN 30 FT) TO THE SITE
TO MICHIGAN SURFACE WATER CRITERIA (MSWC)
Wetland Water Wetland Concentration
~a Concentration (ug/liter) MSWC Ratio
Chemical (ug/liter) Geometric Mean Maximum Geometric Mean Max imum
Chromium 69 44 867 0.64 13
Copper 28 62 2.314 2.2 83
Lead 5 14 809 2.8 160
Nickel 106 42 673 0.40 6.3
Zinc 130 89 2.100 0.68 16
a
All criteria are for continuous exposure
.
-------
-8-
odorous discolored sand in the Washout areas have indicated that the oil is a
paraffinic substance which does not contain organic priority pollutants or
other hazardous constituents.
1.
Endangerment Assessment-Surface Water and Sediments
:~
The Endangerment Assessment has identified the potential aquatic life exposure
in the surface water near the site as potentially impacted by the waste disposal
practices. The estimated concentrations of the indicator chemicals in the
Northwest Wetland were compared to the Michigan Surface Water Criteria for the
protection of aquatic life. These criteria vary with the hardness of the
surface water. A hardness value of 190 mg/1 (as CaC03) was calculated for the
Northwest Wetland. Maximum surface water concentrations and the geometric mean
concentrations of copper and lead in this wetland exceed the Michigan criteria
for all of the indicator chemicals. Based on the available data, it was concluded
that the Northwest Wetland is not likely to support a wide diversity of aquatic
1 i fe.
Runoff from the site and ground water discharge to the wetlands are no longer
expected to be significant sources of contamination because no additional
contamination has been introduced to the site. Consequently, the concentrations
in the Northwest Wetland are not expected to increase over time. However, .
metals are not biodegradable so little reduction in contamination can be
expected in the future.
Concentrations of the indicator chemicals in the Northwest Wetland water sampled
farther from the site were lower than the Michigan Surface Water Criteria, .with
the except ion of 1 ead. The geometric mean and maximum concentrations for 1 ead,
8.6 and 10 ug/liter respectively, both exceed the criteria of 5 ug/liter. The
Endangerment Assessment in the RI reported that concentrations of lead in
"unpolluted" surface water could range from 1 to 55 ug/liter with a median of 4
ug/1, indicating that concentrations of lead in the Northwest Wetland areas not
adjacent to the site may be due to natural background. This has been supported
by another sample from an independent wetland located nearby (50001).
Additional sediment sampling will be conducted to determine the presence of any
isolated "hot spots" that may exist at the base of two spill areas in the
wetland during the remedial design activity (Figure 2). The cleanup criteria
will be the same as that defined in Section III. A. However, the
concentrations of the indicator chemicals in the Northwest Wetland and Doyle
Drain sediments collected during the RI were significantly lower than the
maximum concentrations measured in the surface soils at the Burrows site.
Based on these results, the direct contact and ingestion of exposed sediments
near the site will not pose risks to human health.
C.
Ground Water
The subsurface soils underlying the Burrows site are generally comprised of
coarsely stratified glacial outwash sands with occasional interbedded silt and
clay lenses. The thickness of the glacial deposits at the site is approximately
150 to 160 feet. The Mississippian age Coldwater Formation bedrock underlying
the glacial deposits is comprised of shale with thin limestone layers.
-------
-q-
The unconfined aquifer underlying the site is a primary drinking water supply
for nearhy residents. Water level measurements obtained at on-site monitoring
wells in .June 1qAn indicated the depth to the water table from the ground surface
varied from approximately 1.5 feet near the wetland areas to greater than
30 feet in the southern and central portions of the site. The local ground
water flow at the site is to the northwest, southwest, and west (Figure 4).
Residential wells in the site vicinity have not been impacted hy contaminants
at the site. r.oncentrations of indicator chemicals (hoth total and dissolved)
measured in off-site residential wells are shown in Tahle 1~. r.omparahle
indicator chemical concentrations were found in hoth upgradient and downgradient
wells. The measured concentrations in all tested residential wells were helow
Safe nrinking Water Act Primary and Secondary Standards or applicahle state
drinking water standards.
Two upgradient and two downgradient residential wells within 1/2 mile of the
site were also tested for priority pollutants. A trace level of methylene
chloride (3.2 ug/l) was detected in the sample collecterl from the upgradient
Minshall Well. The trace level of methylene chloride is well below the lifeti~e
health arlvisory allowahle concentration of 350 ug/1. Methylene chlorirle, a
common laboratory contaminant, was also found in the field hlank sample at
7 ug/l. The detection of this chemical is most likely a result of procedural
contamination and not representative of actual conrlitions at this upgradient
well location. No other volatile organic compounds, semi-volatile organic
compounrls, pesticides or PCRs were detected in any of the samples from the
residential well locations.
r.oncentrations of indicator chemicals measured in on-site monitoring wells were
above those found in residential wells in vicinity and indicate a limited
chemical plume or plumes related to the site activities (Figure 5). Test
results for the indicator chemicals in the ten on-site monitoring wells are
shown in Tahles 13 and 14 (Figure 3).
Total concentrations of one or more indicator chemicals measured in five on-site
monitoring wells exceeded Safe nrinking Water Act Standards or other applicable
state drinking water standards. nissolved concentrations of indicator chemicals
measured in on-site wells were lower than the total concentrations. nissolved
concentrations of inorganics measlJred in three on-site wells exceeded the
lowest value of Safe nrinking Water Act Primary and Secondary Maximum Contaminant
Level~ (MCLs) or proposed Recommended Maximum Contaminant Levels (RMCL). The
MCLs for chromium (50 ug/1) and zinc (5000 ug/1) were exceeded in Well EnI-14
(lOA ug/1 chromium and 7229 ug/1 zinc), located just downgradient of the unlined
Pits excavations. The RMCL for lead (20 ug/l) and MCL for zinc were exceeded
in Well EnI-13 (fiO ug/l lead and 630n ug/l zinc), located downgradient of the
Cyanide Trail. Zinc is a secondary MCL which is not a health hased standard.
The MCL for chromium and RMCL for lead were also exceeded in MW-n23 (113 ug/l
chromium and 11q ug/l lead), located near the lower Washout Area at the site's
east houndary. However, the installation and development of Ml4-n23 may have
heen inadequate and these results are questionahle.
-------
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-------
Table 12
WATER SAMPLE DATA FOR
RESIDENTIAl WELLS
INORGANIC INDICATOR CHEMICALS
(Sampled between Oecember 4. 1985 and Oecember 11. 1985)
Units are in ug/l
Kaucher Heinisch V. Mobl1e Minshall Larson Prouty Mackinder
Home
PARAMETERS RWOOI RW002 RW003 RW004 RW005 RW006 RW007
T D T D T D T D T D T D T D
CHROMIUM K8 K8 K8 K8 K8 K8 K8 K8 K8 K8 K8 K8 K8 K8
COPPER 11.8 K6 K6 K6 K6 K6 K6 K6 10.5 K6 K6 K6 K6 K6
LEAD 2.7 K2 K2 K2 K2 K2 K2 K2 K2 K2 K2 K2 K2 K2
NICKEL K15 K15 U5 K15 K15 K15 K15 K15 105 K15 K15 K15 K15 K15
ZINC 357 60.7 44.1 K40 K40 K40 357 159 101 K40 122 105 376 368
CYANIOE K5 K5 K5 K5 K5 K5 K5 K5 K5 K5 K5 K5 K5 K5
Notes:
T D Total
D = Dissolved
K = Less than the value indicated
-------
DOYL E DNAIN'
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PO~TULATeD AR~AL DISTRIBUTION
01= THE CONTA/I4/NATED PLUII4S0
F/~U~£ 5
-------
Table 13
WATER SAMPLES FROM ON OR NEAR SITE MONITORING WELLS
INORGANIC INDICATOR CHEMICAlS AND SUSPENDED SOliDS
(SI.pled between Janulry 6. 1986 and Januny 8. 1986)
units Ire In ug/I unless noted
PARAMETER EDI 11 ""02 I MW023* MW022 MDHRI EDI 13 ED I 14 MDNR 2 MDNR 3 EDI 12
T 0 T D T D T D T D T D T D T 0 T 0 T 0
CHROMIUM IOu IOu 20 IOu 250 260 IOu IOu IOu IOu IOu IOu 460 100 20 IOu IOu IOu IOu IOu
COPPER 20u 20u 20u 20u 210 140 20u 20u 20u 20u 20u 20u 20u 20u 30 20u 20u 20u 20u 20u
LEAD 93 5u 16 5u 124 150 5u 5u 5u 5u 90 60 12 5u 30 5u 8 5u 106 5u
NICKEL 40u 40u 40u 40u 350 390 40u 40u 40u 40u 40u 40u 40u 40u 40u 40u 40u 40u 180 120
ZINC 3.420 180 140 20u 900 1.090 130 60 60 40 8590 6300 5720 4380 2190 440 270 80 17300 1810
CYANIDE IOu IOu IOu 10 IOu IOu IOu IOu IOu IOu IOu IOu IOu IOu IOu IOu IOu IOu IOu IOu
&
SOLIDS. Suspended 332 910 2.864 938 166 36 370 120 46 1.550
(.g/l)
Notes:
u . Indicates the el88ent .as analyzed for but not detected. The detection 11.lt vilue preceeds u (e.g. IOu).
T . Total
o . Olssohed
* . Not properly s..pled. Res..pllng Ind testing .15 perfor.ed (See Table 1-13b).
-------
Table 14
ADDITIONAL GROUND WATER SAMPLE DATA
(Sampled April 24, 1986)
units are in ug/l (otherwise indicated)
:tMW 023 EDI 14 Fire Station*
PARAMETERS Total Dissolved To ta 1 Dissolved Total Dissolved
Chromium 204 113 437 108 (5) (4)
Copper 224 153 49 (3) (9) (1.7)
Lead 164 119 99 5u 5.1 5u
N i c ke 1 277 200 66 (29) 18u 18u
Zinc 2,401 878 24,910 7,229 0.7u (5)
Total Suspended Solids 627 mg/l 535 mg/l 215 mg/1
Notes:
* . Water sample was taken at the fire station in Hartford. The water was
used for drilling during the installation of monitoring wells MW021,
MW022 and MW023.
u . Indicates the element was analyzed but not detected. The detection
limit value precedes u.
( ). Indicates the result was a value greater than or equal to the
instrument detection limit but less than the contract required
detection 1 imit.
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-10-
r.omparison of January lqRn test results with historical rlata for the previously
existing on-site wells indicates that there has heen a rlownward trenrl in metal
contaminant concentrations in the ground water heneath the unlined Pits. This
trend suggests that percolation of concentraterl fluirls to the grounrl water zone
may have occurred dlJring the early stages of waste rleposition. A compilation
of historical rlata suggests a trend toward increasing concentration in the
ground water a short distance rlowngradient form the former waste rlisposal areas.
Ni ne pri ority poll utant organi c chemi ca 1 s were detected in grounrl water sampl es
from the 10 sampled on-site wells. Three of these chemicals were found in
lahoratory blank samples or at comparahle concentrations in the field hlank
samples and are not considered to be representative of actual ground water
quality. The other priority pollutant organic chemicals were measured at the
detection limit or trace levels (below 10 ug/1) in the ground water samples and
were not detected in the blanks. Some of these chemicals (l,l,l-trichloroethane,
lindane, acetone and hutyl benzyl phthlate) have heen rletected at trace levels
in grounrl water in previous site investigations. The low organic chemical
concentrations measured were not consistent to enable irlentification of any
data trends (Remedial Investigation Report, August 1Q, 19Afi, Tables n-18).
The organic chemical concentrations measured in the on-site ground water are
below water quality standards for chemicals for which standards are avail-
able. 1,1,1-trichloroethane was rletected in wells MnNR-3, EnI-14 and HW-n~1 at
a concentration of 5 ug/l. The Safe nrinking Water Act proposed MCL for.
1,1,I-trichloroethane is 200 ug/l. The herbicide lindane was rletected in wells
EnI-11, EnI-1~, MW-021, Mw-n~~ anrl MW-n?3 at concentrations of n.1R ug/l. The
Safe nrinking Water Act Mr.L for lindane is 4 ug/l; a proposed RMr.L of O.~ ug/l is
pending.
No elevated levels of indicator chemicals were founn in the nowngradient
residential wells when comparen to the upgradient well concentrations.
Therefore, there are no current unacceptahle exposures to site contaminants hy
local residents drinking ground water.
1. Endangerment Assessr1ent-r,round ~'ater
The Endangerment Assessment has inentified human ingestion of contaminated
ground water as a potential exposure route. As has heen noted previously.
ground water is the only source of drinking water for residents in the
area.
In order to assess the potential ground water contamination hazard that the
site could represent., a hypothetical estimate of the configuration of plumes
emanating from the site under worst case conrlitions was made using existing
hydrogeologic data anrl the Vertical and Horizontal Spread (VHS) 50 Fed. Reg.
4RA8fi (November 27. 1qR5) model. The VHS model estimates are worst case rlue
to the assumptions that the source of contaminants has persisted for an infinite
time and there is no sorption, precipitation or degradation. The plumes indi-
cated hy this model are conceptual and additional field data would he requirerl
to confirm the presence of the plumes.
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- 11 -
The VHS contaminant transport model was used to determine the potential impact
of the on-site ground water contamination to nearby residential wells at the
Burrows site. All of the 13 houses and 25 mobile homes within 3/4 mile of the
site use- private wells for their water supply. These wells are screened at
depths of between 60 and 90 feet. Only three residential wells are considered
to be downgradient from the site (Larson, Kaucher and MacKinder). Therefore,
under current ground water conditions these wells, which are located within at
least 1,200 feet of the site, are the potential receptors of ground water
contaminants. The model predicts that a metal contaminant plume has extended
into the vicinity of one off-site downgradient residence (Larson). The Larson
Well is screened between 91 and 96 feet, whith is at a depth nearly 40 feet
below the vertical component of the plume.
Residential well pumping in some ground water aquifers can create a cone of
depression drawing contaminants toward the well screen. This is not likely to
occur at the Larson well or other area wells due to the high permeability of
the site aquifer. Calculations of anticipated drawdown from a residential well
show that pumping at 1000 gallons per day, which is two times the average daily
residential water use, results in a drawdown of less than 2.0 feet at the well
location. In addition, the horizontal stratification of the glacial outwash
materials would restrict downward migration of contaminants.
Based on the VHS model, three theoretical flow lines define the waste loading-
areas on-site. The flow lines identified from Figure 3, connecting the potential
receptor wells to the contaminant sources, are as follows:
Flow Line I - from the Cyanide Trail to Larson Well;
Flow Line II - from Pit No.1 to Kaucher Well, and
Flow Line III - from Pit No.2 to MacKinder Well (Figure 5).
All of the flow lines originate from the East Wetland and terminate at
the Paw Paw River.
Although the downgradient residential wells are not currently contaminated,
future potential exposures through new drinking water wells installed within
the ground water contamination is possible. Since none of the indicator
chemicals found are carcinogenic, the FS has recommended the current lowest
regulated concentration for each chemical to be the cleanup criterion. For
example, lead has two drinking water standards (RMCL 20 ppb and MCL 50 ppb);
therefore, the RMCL for lead will be the clean-up criterion for lead. Table 15
summarizes the regulated concentrations for the remaining indicator chemicals.
IV.
ENFORCEMENT ANALYSIS
. The identified potentially responsible parties (PRPs) for the Burrows site have
received notice letters and been given the opportunity to perform the Remedial
Design and Remedial Action (RO/RA) phase of the project. In July, 1986,
notice letters were sent to Duane and Evelyn Funk, Elmer Burrows, Du-Wel Products,
Inc., Whirlpool Corporation and Auto Specialties Manufacturing Company. A
notice letter was also sent in August, 1986 to Douglas and Georgia MacKinder,
the current property owners of the Burrows site. Mr. Elmer Burrows has not
responded to the letter and Mr. Douglas MacKinder has declined to participate
in the RD/RA. All other PRPs attended a meeting to discuss the RI/FS on
-------
Table 15
HUMAN HEALTH STANDARDS AND CRITERIA FOR SELECTED INDICATOR CHEMICALS AT THE BURROWS SITE
Safe Drinking Water Act Acceptable
Standards or Criteria (ug/liter)~ Uealth Advisory for Health Advisory for
Chronfc Intake 70-kg Adult (ug/litert 10-kg Child (ug/litert
Primary Secondary Proposed for Oral Exposure
Chemical MCl MClc MCl or RMCL .(mg/day t longer-Term lifetime I-day 10-day
Chromi um 50 120 (RMCl) 103 (CrIll)
0.35 (CrVI) 840 120 1,400 1,400
Copper 1,000 1,300 (RMCl) 7 1,300
lead 50 20 (RMCl) (50 ug/1)d 20 ug/dayf 20 ug/dayf
Nickel 0.7 150 1,000
Zinc 5,000 14. ge
a 40 CFR, Ch. 1, Parts 141 and 143, and 50 FR 46936-47025.
b Obtained from EPA's Health Effects Assessment Documents.
c Based on taste and odor.
d The Health Effects Assessment suggests use of the primary MCl for lead and does not provide an oral AIC.
e Additional exposure beyond background dietary exposure.
f Based on a sensitive subpopulation (fetuses and infants under two years of age).
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-12-
September 9, 1986. The PRPs have raised technical
their comments are addressed in the Responsiveness
with PRPs will commence following the selection of
Record of Decision.
concerns wi th the RIfFS and
Summary. Any negotiations
the remedial action in this
V.
ALTERNATIVES EVALUATION
The Feasibility Study (FS) was initiated to evaluate the appropriate remedial
action at the Burrows site. The RI and Endangerment Assessment determined that
based on the criteria summarized in Section III above, response actions are
warranted for the following impacted environmental media:
o Wastes in Spill Area No.2,
o Northwest Wetland surface water and sediments, and
o Ground water.
Based on the identification of these sources, impacted media, and potential
receptors, the FS screened several alternatives which would be appropriate for
the Burrows site. The screened alternatives are presented in Table 16.
Subsequently, these alternatives were proposed for detailed evaluation based
on the following parameters:
1.
2.
3.
4.
5.
6.
7.
Constructability
Re 1 i ab il ity
Implementation
Cost
Level of protection
Vol ume reduction
Adverse envi ronmental
impact s
This Record of Decision addresses multiple environmental media and as the
assembled technologies are not similar for each media, the format of this
summary is divided into the following categories, which includes the
assembled alternative.
A.
No Action Alternative (All Environmental Media)
Evaluation of the "No Action" alternative is required under Section 300.68 (9)
of the National Contingency Plan (NCP). This alternative would involve no
remediation of the ground water, Spill Area No.2 and the Northwest Wetland and
presents a baseline against which the adequacy the other actions can be
measured. This alternative would not be protective of public health and the
environment becquse it would not address the existing environmental degrad-
ation. If No Action was selected, the site would be ineligible for deletion
from the National Priorities List (NPL) as provided in the National Contingency
Pl an .
-------
Table 16
Tota 1
Present
Capital O&M Worth
ALTERNATIVE Cost(S) Cost(U ~
No Action (551. NW51. GW1) 0 0 0
5pill Area No.2 Wastes
0 Clay Cover/Revegetation (552) 29.100 29,200 58.300
o Excavate/Off-site Landfill
Disposal (553)
at 130 mi 159.100 0 159.100
at 830 mi 237.700 0 237.700
o Fence/Land Use Restrictions (S54) 31.000 29.200 60.200
Northwest Wetland Sediments
0 Cover/Revegetate (NWS2) 18,200 1.900 20.100
o Dredge Sediments/Solidify
Off-site Landfill Disposal (NW53)
at 130 m; 294.300 0 294.300
at 830 mi 480.700 0 480,700
o Dredge Sediments/On-site Land 88.600 11.600 100.200
Application (NWS4)
0 Drain Wetland (NWSS) 42,700 1.900 44.600
Ground Water
0 Extraction Wells/Above Ground 1.055,000 115,000 1.170.000
Treatment/Discharge to Surface
Water (GW2)
0 Extraction Wells/Direct Discharge 1.243.000 75.000 1.318.000
to POTW (GW3)
0 Monitor Migration of Chemical 14.900 38.700 53.600
Plumes (GW4)
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- 13 -
B.
Remedial Alternatives for Spill Area No.2
1.
Clay Cover/Revegetate
Soil placement over the type of wastes present in Spill Area No.2 and
revegetation has demonstrated performance, reliability and implementability.
The clay material is not avail able at the site and would be secured off-site.
Covering the contaminated wastes with 0.5 feet of clay after cutting ground
surface vegetation would minimize direct exposure of the public to the contami-
nants. Capital, Operation & Maintenance (O&M) and Total Present Worth costs
are present in Table 16.
The topography of the Burrows site prohibits this alternative from being an
effective remedy. Because of the steep slope, surface erosion could create
gullies which may penetrate the clay cap. This would destroy the integrity
of the cap of its ability to isolate the source from direct contact and to
prevent additional leachate from the waste entering into the ground water. The
ground water depth varies from 1 to 30 feet under Spill Area No.2. Capping
the sludge would not assure the protection of ground water since the water
table could intersect the sludge during wet seasons thereby permitting the
additional introduction of waste leachate into the aquifer.
2.
Excavated Wastes and Soil/Off-Site Disposal
Excavation, transportation, and disposal technologies at an off-site RCRA
landfill have demonstrated positive technical performance, reliability, and
implementability. The wastes would be solidified and treated for fixation
prior to disposal at a facility in compliance with the EPA Off-site Policy,
50 Fed. Reg. 45933 (November 5, 1985).
The excavation, treatement, and disposal of the sludge from the Spill Area
No.2 is the cost effective remedy which would address all potential exposure
routes. The removal of the visible sludge and the residual contaminated soils
to the established criteria in Section III. A. above, would eliminate the
potential threat for direct contact and ingestion to human health. The removal
of the sludge would also assure no further introduction of leachate into the
aquifer. Future land usage would be unrestricted. O&M costs would not be
required for this alternative. The two costs generated for this alternative
are based on the distance to two disposal facilities. The 830 mile distance
was the closest RCRA permitted facility in compliance with the EPA Off-site
Policy at the time of the FS publication. A closer facility, CECOS, in
Williamsburg, Ohio, is currently in compliance with the Off-site Policy. Use
of this facility could reduce transportation costs by more than half. Table 16
contains Capital and Total Present Worth Costs.
3.
Fence/Land Use Restriction
Installation of a chain-link fence has demonstrated performance, reliability
and implementability.
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-14-
The installation of a fence around the spill area would isolate the source
from potential direct contact and ingestion. However, the further introduction
of waste leachate into the ground water would not be prevented. Consequently,
this renedy is not appropriate for the Burrows site. Table 16 contains Capital,
O&M, and Total Present Worth Costs.
C.
Remedi al Alternatives for Northwest Wetl and
The Northwest Wetland was artificially created by a presently abandoned dirt
road, which lacks a culvert. The road has been breached and could eventually
be severely eroded.
1.
Soil Cover/Revegetate
This alternative would require the covering of the contaminated sediments
with one foot of fertile soil. Implementation of this alterative would
be subject to meeting the criteria of Federal Executive Order for Wetlands
(EO-11990) as set forth in the Wetlands Assessment.
,
The covering of the contaminated sediment with clean soil could potentially
remove the threat to aquatic life by virtue of extending the shoreline into the
wetland. However, the intergrity of the cover could be destroyed by burrowing
animals or a rise in the water level in the wetland. Table 16 contains Capital,
O&M, and Total Present Worth Costs.
2.
Dredge/Off-s ite Di sposal
u
Excavation, transportation and disposal technologies at an off-site RCRA
landfill have demonstrated positive technical performance, reliability and
imp1ementability. Solidification and fixation of Northwest Wetland sediments
would require bench scale studies. Dredging the contaminated sediments must
meet the Section 404 of the Clean Water Act and Michigan wetland permit
requirements. Approximately 350 cubic yards of wetland sediments would be
renoved. Some of the contaminants would likely be resuspended in the water
column, resulting in an increased exposure in the short-term. However, the
long term concentrations of contaminants in the water column would be reduced.
No O&M costs would be associated with this alternative. Table 16 summarizes
the cost for this alternative. The two costs generated for this alternative
are based on the distance to two disposal facilities. The 830 mile distance
was the closest RCRA permitted facility in compliance with the EPA Off-site
Polity at the time of the FS publication. A closer facility, CECOS, in
Williamsburg, Ohio, is currently in compliance with the Off-site Policy. Use
of this facility could reduce transportation costs by more than half.
The RI did not find any concentrations of contaminants which are of potential
threat to human health. However, during the predesign phase of the Remedial
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-15-
Action, additional samples would be collected to define potential areas of
human health threat at the base of the spill areas. These areas are expected
to be m i n i mal ins i ze . .
These contaminated sediments which could potentially impact aquatic life may
extend up to 30 feet into the wetland. The excavated contaminated sediment
would need to be solidified and chemically treated before disposal. The resulting
waste would approximately double the volume to 700 cubic yard, thereby eliminating
the cost effectiveness of the remedy when compared with the other potential
remedies for this site.
3.
Dredge/On-Site Land Application
Under this alternative, the dredged sediment from the Northwest Wetland would be
applied on-site after pretreatment. On-site land application of the sediments
in the previously excavated areas would offer some positive environmental
benefits. By revegetating these areas with shallow rooted trees or shrubs,
plant uptake of metals would be mostly concentrated in the wood. Metals would
be either attenuated in the on-site soils or removed in a manner that protects
the food chain. The addition of fertilizers may help stimulate plant growth-
and speed up the process of site recovery. Site revegetation would promote a
healthy wildlife environment.
On-site land application of the dredged sediments will require an applicabi-
lity demonstration study. The land treatment demonstration would assure
minimal impact on local ground water and would have to comply with the Michigan
permit requirements for operating a land application facility.
The waste application rate, cover crop, maintenance and monitoring are design
related issues that need to be addressed. The facility would be a one time use
facility and would be closed immediately after final waste material application.
All equipment used during land application procedures would be decontaminated
prior to removal from the facility.
Annual inspections of the site would be performed for a minimum five years, but
possibly up to thirty years, after closure to monitor vegetation performance
and surface erosion. Ground water testing would be performed on samples
collected annually during the initial five years after closure. Indicator
metals (chromium, copper, lead, nickel and zinc) would be tested to evaluate
whether any significant leaching of the land application materials has occurred.
This alternative technology has potential application at the Burrow site.
However, this remedy would require further study before implementation. The
site access would have to be limited and future residential development would
be restricted. The total present worth of this alternative exceeds the cost of
other potential remedies, consequently, it is not considered applicable. Table
16 summarizes the costs for this alternative.
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-16-
4.
Drain Wetland
Technologies to drain the Northwest Wetland have demonstrated technical perfor-
mance, reliability and implementability. A one-time discharge from the Northwest
Wetland (approximately 4x106 gallons of water) can be implemented by controlled
removal of the small earth dike at the outlet of the wetland.
The weighted average concentrations of indicator metals (based on 10 sample
analysis results) in the wetland water are below Michigan Surface Water Criteria
or do not exceed background. Therefore, discharge water quality would comply
with NPDES permit requirements.
The increased water level in the wetland due to earth fill over the discharge
channel has been the prime cause of stress on the trees in the wetland. This
alternative would reduce water levels and thereby allow natural remediation of
the habitat. Reducing the water level would mitigate the potential threat of
wetland water coming in contact with the contaminated sediments and would
eliminate the potential impact on future aquatic life. Because the potential
impact of water in contact with sediments would be eliminated, no further action
on the sediments would be necessary.
Reducing the water level would result in an increased potential for human
contact with the sediments; however, the Endangerment Assignment indicates
that human contact with the sediments is not harmful. There would be no
adverse effect of this technology on aquatic life since no aquatic life is
currently present in the Northwest Wetland. A permanent naturally occurring
wetland would remain to foster future aquatic life conditions in the vicinity
of the current wetland.
Draining the wetlands would result in drying of the surface materials and
may result in reintroduction of the contaminants into the environment via
windblown dust or surface runoff. Neither exposure route would be
significant. Windblown dust would contain lower levels of contaminants
than the sediments themselves, which are not harmful to the public via ingestion
at their current concentrations. Surface runoff would be minimal due to the
essentially flat ground level and long distance (over 1000 feet) to the wetland
area which would remain after draining the present high water level wetland.
The draining of the wetland would effectively eliminate the potential impact to
aquatic life. The wetland was artificially created by an earthen dam (dirt
road) across the Doyle drain, which was installed by a previous owner for
access. The road was constructed without a culvert for drainage and resulted
in the development of a eutrophic wetland. This wetland currently does not
appear to support aquatic life. However, should the conditions change and the
'wetland becomes capable of supporting aquatic life, potential exposure threats
would exist in the surface water adjacent to the site. Allowing the wetland to
drain would restore the wetland to its smaller natural size and thereby remove
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-17-
the potential for aquatic exposure to the contaminated sediments. As discussed
previously, the concentrations detected during the RI did not present a potential
human health threat. However, additional samples will be collected at the base
of the spill areas to assure no IIhot spotsll exist in concentrations which may
cause a human health threat. Any IIhot spotsll found will be dredged, treated, and
landfilled with waste from the spill areas. Table 16 summarizes the cost for
this alternative.
C.
Ground Water
1.
Extraction Wells/Above Ground Treatment/Discharge to Surface Waters
Ground water extraction and on-site treatment technologies have demonstrated
performance, reliability, and implementability. The targeted levels defined
in the Section III. C. above are achievable with current technology.
The water treatment system would include chemical addition and flash mixing
in a flocculation tank, and a package precipitation unit. Since public
access to the treatment unit would be restricted, no public health risks
associated with this treatment are anticipated. Sludge dewatering is
currently planned for this treatment process. The dewatered sludge would
be temporarily stored on-site, and subsequently sent to a RCRA-permitted
and compliant landfill. The sludge might require treatment to immobilize
the toxic metal constituents prior to disposal. The contaminated ground water
would be treated to meet the NPDES discharge criteria prior to its discharge
into the Doyle Drain.
This alternative is the cost-effective alternative. It would achieve the
defined action levels in approximately two years. The extraction of the
contaminated ground water to the cleanup levels defined in Section III. C.
above would effectively assure the protection of current and future consumers
who depend upon this aquifer for a drinking water source. The plume would be
purged and thereby eliminate any further threat to current and future consumers.
Residential wells of immediate potential threat will be monitored regularly
until the conclusion of the extraction program. A temporary on-site treatment
facility would remove contaminants from the ground water with solid waste
residuals being disposed at an off-site RCRA facility in compliance with the
EPA Off-site Policy. Table 16 summarizes the cost for this alternative.
2.
Extraction Wells/Direct Discharge to POTW
This alternative differs from the previous alternative only in the disposal of
the contaminated ground water. Under this alternative, sewer lines would be
installed from the Burrows site to a mainline for the Hartford POTW.
The extraction of the contaminated ground water to the cleanup levels defined
in Section III. C. above would effectively assure the protection of current and
future consumers who depend upon this aquifer for a drinking water source. The
plume would be purged and thereby eliminate any further threat to current and
future consumers. Residential wells of immediate potential threat will be
monitored regularly until the conclusion of the extraction program.
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"
-18-
At the publication of the FS, it had not been determined whether or not the POTW
would accept the contaminated ground water. It has now been determined by
communication with the POTW, that the POTW will not accept industrial wastes
into its treatment system. Table 16 summarizes the cost for this alternative.
This remedy is not cost effective when compared with the other evaluated altern-
atives.
3.
Monitor Migration of Chemical Plumes
Ground water monitoring would involve installation of four additional monitoring
wells and periodic analyses of water samples from a total of seven monitoring
wells. This technology has demonstrated performance, reliability, and imp1ement-
ability. Sampling and analysis of ground water are standarized procedures.
Monitoring of ground water would not improve the ground water conditions at the
site. In the long-term, if this alternative were selected and the site were to
be used for a private residence, the water quality in an on-site well would
likely exceed Safe Drinking Water Act standards and thereby pose a long-term
health risk to users.
The selection of this remedial action would not effectively assure the protection
of potential drinking water supplies in the area. New drinking water wells
installed within the aquifer might initially achieve drinking water standards;
but might deteriorate as the plume migrates toward the Paw Paw River. The
monitoring program would assist only in establishing additional information.
Therefore, even though this alternative is the lowest cost, it may never achieve
the defined cleanup levels and may result in reevaluating other potential
remedial actions. Since the cleanup criteria has been defined for this drinking
water source and since the extent of the contamination can be defined in the
design phase, this remedy is not considered appropriate.
V.
COMMUNITY RELATIONS
Copies of the FS were made available to the community on August 20, 1986. The
Hartford Library in Hartford served as the local repository. The EPA issued a
press release on August 20, 1985, announcing the availability of the study for
public comment. The public comment period was extended from September 10 to
September 15, 1986, at the request of the PRPs. MDNR issued a press re1 ease on
September 8, which stated MDNR would accept comments until September 20. Only
the PRPs submitted comments. These comments are addressed in the attached
Responsiveness Summary.
i-J
VI I.
RECOMMENDED ALTERNATIVE
The Nation~ Oil and Hazardous Substances Contingency Plan (NCP) 40 CFR Part
300.68(j) states that the appropriate extent of remedy shall be determined by
the lead agency's selection of the remedial measure which the agency determines
is cost-effective (Leo, the lowest cost alternative that is technologically
feasible and reliable), which effectively mitigates and minimizes damage to and
provides adequate protection of public health, welfare or the environment.
Based on the evaluations presented in the RIfFS, state and federal environ-
mental requirements and public comments, the recommended alternative for this
site was chosen.
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-19-
In summary, the Endangerment Assessment has defined three receptor pathways
that must be remedied in order to meet the intent defined of the NCP and for a
permanent remedy at this site. The defined pathways are:
1)
Human contact and ingestion of sludges and contaminated
soils at the site,
2)
3)
Human ingestion of ground water, and
Potential aquatic life exposure in surface water.
The recanmended multi-action remedy is considered to be a final remedy
for all the impacted environmental media. Upon achieving the criteria
defined in Section III above, Burrows would meet the criteria for NPL
deletion as set forth at 40 CFR 300.66 (c)(7). This multi-action remedy
includes:
1 )
Excavate, treat, and dispose of sludge and contaminated
soils/sediments which exceed the defined site specific
criteria at an off-site RCRA facility in compliance with
the EPA Off-site Policy.
2)
Confirm the theoretical extent of ground water contamination,
which will then be purged until the lowest regulated concentration
plus one equal volume has been achieved and treated on-site with the
treated water discharged into the Doyle Drain.
Drain the Northwest Wetland to remove the exposure to potential
aquatic life caused by surface water in contact with contaminated
sediment.
3)
The above multi-action remedy would elimate all apparent exposure routes
and the need for land use restrictions. The estimated total present
worth costs are summarized below and will be refined during the pre-design
act i vity.
RECOMMENDED MULTI-ACTION REMEDY
Sp i 11 Area
No.2 Wastes
Capi tal
Cost ($)
159,000
237,700
O&M
Cost ($)
o
o
Total Present Worth
Cost ($)
159,100
237,700
o at 130 mi
o at 830 m;
Northwest Wetl and
.Sediments
o Drain Wetland
42,700
o
42,700
Ground Water
o Extraction wells/
Above Ground
Treatment/Discharge
to Surface Water
1,055,000
115,000
1,170,000
~
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"
-20-
VIII. CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
All the detailed alternatives were designed to be fully compliant with
applicable environmental laws. The following Federal and State require-
ments may be applicable for the recommended alternative.
A. Federal Laws and Regulations
Department of Transportation (DOT)
Hazardous Materials
Transportation Rules
Fresh Water Quality Criteria (FWQC)
Nati onal Poll utant Di scha rge
Elimination System (NPDES)
Resource Conservation
and Recovery Act (RCRA)
Executive Order (EO)
for Wetl ands( 11990)
Clean Water Act (CWA)
Section 404
B. Michigan Law and Regulations
Michigan Drinking Water Standards
(DWS), Safe Drinking Water Act,
399 P .A. 1986
Michigan Solid Waste Management Act,
641 P .A. 1978
Michigan Water Resources Commission Act,
245 P.A. 1929
Hazardous Waste Management Act,
64 P.A. 1979
'-J
Mineral Well Act}
315 P.A. 1969
Inland Lakes & Streams Act,
346 P.A. 1972 as amended
Wetl and Protection Act,
203 P.A. 1979
The CERCLA Off-site Policy, 50 Fed. Reg. 45933 (November 5, 1985), prohibits
the use of any facility that has RCRA violations. or other environmental
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conditions that affect the satisfactory
the off-site facility \'tt1ich is selected
as the contaminated soils and sediments
this policy.
operation of the facility. Therefore,
for the disposal of the sludges as well
would have to be in compliance with
Drainage of the Northwest Wetland would meet the requirements for EO-11990,
CWA Section 404, FWQC, and NPDES. The Wetlands Assessment attached to this
document demonstrates compliance with EO-11990. Drainage of the Northwest
Wetland may result in defining a point discharge requirement for NPDES.
Calculations, based on available data, indicate that the surface water
would meet this criteria with the exception of lead. However, the natural
occurring lead concentrations for surface water appear to be higher than
the NPDES requirements.
The ground water purge and treatment system will primarily be subject to the
requirements of MOWS and NPDES. The recommended level of cleanup will meet or
exceed all requirements. The recommended alternative for this site meets the
cleanup criteria set by the State of Michigan and would fully comply with all
applicable federal standards.
I X.
SCHEDULE
Contingent upon available funding, the following schedule of activities for the
recommended alternative has been proposed.
Approve Remedial Action
Design Award (notice to
Design Completion
Start Construction
Complete Construction
(Sign ROD)
proceed issued)
9/30/86
FY 1987 Q1
FY 1988 Q1
FY 1988 Q2
FY 1989 Q4
X.
FUTURE ACTIONS
Upon completion of the remedial actions the site will be proposed for
deletion from the NPL.
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cm1HIINITY RI:LATIONS RFSPONSIVENFSS Sm1MARY
RIJRROWS SAN IT A TI ON LANOF I LL
HARTFORn TOWNSHIP, MICHIGAN
INTRonUCTION
This "Community Relations Responsiveness Summary" c10cuments citizens' concerns
and issues raised during the planning and preparation of the Feasibility Study
(FS) for the remedial actions at the Rurrows Sanitation Lanrlfill Site (Rurrows
site). The comments were received by mail at the EPA's regional office located
at 230 South nearborn Street in Chicago, Illinois. Announcement of the comment
period was via press release and written notices sent by the EPA and the Michigan
Oepartment of National Resources (MONR) to residents on the site mailing list.
This summary is also intended to document, for the public record, the EPA
response to the comments presented during the public comment period on the FS.
The FS was completed on August lq, 19R~. Copies of the document were made
available to the public on August ?n, lQR6. A puhlic meeting was not held
during the comment period due to the apparent minimal interest generated hy
the RIfFS. The FPA and MONR marle an effort to contact adjacent landowners
and local neighhors hy individual letters regarding the FS and proposed remedies.
The puhlic comment period concluded Septemher ?O, lqR~. The F.PA received two
sets of written comments from firms representing the potentially responsible
parties. One set was submitted by Fred C. Hart Associates, Inc. on behalf of
Auto Specialties Manufacturing Company, nu-We] Products, Inc. and Whirlpool
Corporation. The other comments were submitted by Michael t~. Retz on behalf of
nuane and tvelyn Funk. ~1nNR al so provided comments.
r,OM~1ENTS
nisposal Areas
Comment:
The alternative selected for "Spill Area No. ?" in the FS
is excavation with subsequent disposal at an off-site
facility. To be cost-effective, the disposal site selection
~ould he made at the actual time of disposal.
Response:
The excavation, treatment and off-site disposal of the
sl udge from the Spi 11 Area No.2 has heen se1 ecterl as the
recommended alternative in the September 30, lQR6, Record of
necision (ROO) for the Rurrows site.
Two costs were generated for this alternative based on the
distance to two disposal facilities. The R30 mile distance
was the closest RCRA permitted facility in compliance with
the EPA Off-site Policy at the time of the FS puhlication.
A closer facility is currently in compliance with the nff-
site Policy. The final site selection will be made during
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Comment:
Response:
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Wetlands
Comment:
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the remedi al action and will be based on compl i ance with
EPA's Off-site Policy.
The first area of claimed contamination, "spill area number
2", was not discovered through analytical testing; rather,
it was apparently discovered late in the remedial investi-
gation portion of the study as a result of visual observ-
ation. There is no indication in the RIfFS study that
either the lateral extent or the depth of the area of
contamination was ever determined; rather, the areal extent
of the area has been determi ned "by guess and by golly II and
the extent of contamination contained within the spill area
has been determi ned on the basi s of the II assumpt i on" that
lithe wastes in spill area number 2 had similar concentrations
of contaminants as detected in samples of wastes from other
pits, spill and washout areas...."
Although Spill Area No.2 was discovered relatively late in
the remedial investigation, it was identified by analytical
testing. Soil sample number SL202 and sediment sample
number SD006 contained concentrations which would not be
expected in the natural media. EPA also concluded that
based on other sample results from the Burrows site that a
visual inspection would adequately define the vertical and
horizontal boundaries of the contamination. After the
sludge has been removed, additional samples will be collected
for analysis and levels exceeding the defined criteria in .
the Record of Decision will also be removed.
The quotation regardi ng "assumption" and "simil ar concen-
tration" is in reference to the potential threat to receptors
discussed in the Endangerment Assessment. To properly
assess the threat of direct contact or ingestion of the
sludge, EPA assumed the concentration of the contaminants
were equal to the concentrations determined from previous
samples collected into the pits. The low concentration of
SL202 was diluted by the sampling technique and would not
be representative of the potential threat. Therefore,
rather than collecting a sludge sample from Spill Area No.2,
EPA used samples of similar composition from the former sludge
in the pits to define the potentjal health hazard.
Justification for draining the Northwest Wetland as part of
the remedial action for this site has not been provided.
As specifically stated in the FS, this area is presently
eutrophic and as such, not currently capable of supporting
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Response:
C orTJlTlent :
Response:
Ground Water
Comment:
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aquatic life. The limiting factor in the suitahility of the
wetlands to support aquatic life is not the impact of past
operations at the Rurrows site but the eutrophic conrlitions
noted in the FS. Although there may be henefits to draining
this area from a general environmental stanrlpoint, the
justification for these actions to be funderl as part of the
remedy for the Rurrows site is lacking. The FS states on
page 11 of Section 1 that prior rlisposal activities have
had a "1 imiterl" impact on surface water and serliments.
This impact is limited to within 30 feet of the site border~
which serves as a "mixing zone". Hhereas, the average concen-
tration of suhstances of concern in the wetland area are
below Michigan Surface '-later Oua1 ity Criteri a or background
levels (lead). These concentrations are acceptable under
Michigan Rule 57 (upon which the Michigan Surface ~ater
Ouality Criteria are haserl), which makes allowance for a
"mixing zone".
The EPA acknow1erlges that the Northwest Wetlanrl does not
appear to be capable of currently supporting aquatic life
because of the present eutrophic conditions anrl prior dis-
posal which has had limited impact on the wet1anrl. However,
it is also the responsibility of the EPA to protect potential
aquatic life which may depend on the wetlanrl in the future,
should environmental conditions change and he come capahle
of supporting such aquatic life.
... the single highly-elevated contaminant levels founrl
in the surface water of the northwest wetlands was ohtainerl,
if the RIfFS rearls correctly, by having one of the samplers
stanrl on the sedimented soils in order to make a depression
for purposes of water collection. The water which then
collected in his footprint was sampled. What the report
does not state, however, is exactly where that boot harl
been immediately prior to its pivotal role in what purports
to be a "scientific" saMpling technique.
The water sample collecterl within the footprint was not a
"scientific" sampling technique and was not depended upon
as an accurate representation. An additional set of samples
were collected unrler hetter rlefined procedures which elimi-
nated the potenti al of i nrli rect contami nat ion. Ilnrler the
redefined procerlure the second set of serliment samples
still showed the presence of contamination.
The analysis performed in identifying risk to receptors of
area groundwater is inadequately presented in the RIfFS due
to the lack of site and constituent-specific hydrogeologic
information. The FS presents a potential scenario of
migration of source constituents which is extremely conserv-
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ative (VHS Model) and, as presented in the FS, is inadequate
to evaluate or select a final remedial action for this
media. The data provided on current on-site ground water
concentrations is extremely limited and needs to he further
developed so that a realistic assessment of potential risk
can be made. The present analysis utilizes one point in
space and an aquifer permeahility which is higher than
physically measured to define a three-dimensional "plume".
No verification data is presented to confirm the presence
of the "plume" or to calihrate the model to site-specific
conditions. The FS clearly states that the design of the
extraction system is a "key element" of remedial response
actions and recommends the installation of additional
monitoring wells to define the "plume". nue to the fact
that the "contaminant plumes" identified by EPA are relatively
dilute and that existing groundwater supplies have not heen
impacted, no imminent hazard has heen identified and
sufficient time is availahle to properly evaluate groundwater
conditions through continued or expanded monitoring. This
will provide more reliable information on concentration
trends than the theoretical, conservative approach presented
in the FS. The FS clearly states (Section 1, pg. 17) that
the "plumes indicated hy this model are conceptual and
additional field data would he required to confirm the presence
(emphasis added) of the plumes". As presented, the method-
ology presented in the FS only indicates the area of
potential concern and warrants additional investigation
prior to the selection of a remedial alternative. The
limited datahase is presently inadequate to determine the
necessity for or properly design and cost a groundwater
remediation system; this was not the intended use of the
VHS model. The VHS model is intended to identify areas of
potential concern and allow plume investigation to proceed
in a focused, phased approach, not as a suhstitute for site-
specific solute transport models. As utilized in the
RIfFS, the required model verification data is lacking;
the collection of these data is deferred to the design
phase of the remedial alternative. Logically, these data
should he collected as part of the Remedial Investigation
so that the Feasibility Study can he developed on actual
conditions. In its present form, the groundwater remedial
analysis is a theoretical exercise and is inadequately
supported to meet the intent of the RIfFS process. The
development of proper design parameters would require
aquifer testing including pump and slug tests. It is likely
that the concentrations encountered in such a study would
present significantly different site conditions than those
utilized in the FS to develop and evaluate remedial
alternatives. The conclusion presented in the RI that the
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Response:
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model presents IIworst case II conditions is also unsupported.
At least one additional sa~p1ing location would be required
to substantiate this conclusion. As such, the analysis of
the applicability and potential cost of alternatives
evaluated in the FS is flawed. For exa~p1e, the feasibility
of direct discharge to the POTW or surface water cannot be
adequately evaluated without reasonable esti~ates of flow
and constituent concentrations. As presented by EPA at our
meeting, direct sewer discharge has he en totally c1is~issed
due to lack of POTW treatment capacity. This decision
cannot be made without reasonable anrl supportable estimates
of groundwater withdrawal rates anrl quality, and an
investigation of POTW capability and cost.
The EPA recognizes the advantages in further defining the
extent of ground water conta~ination at the Rurrows site
and supports further definition of the p1u~e during the
re~edial design stage. However, EPA is basing the rlecision
to pu~p and treat the ground water on the existence of
conta~ination. First, the presence of contaminated ground
water has been established hy sa~pling ~onitoring wells
with the boundaries being theoretically defined through
conservative and IIworst casell assu~ptions. The conta~inants
sampled, no matter how IIre1ative1y di1utell, are a potential
health hazard to any new drinking water wells developed
within this potential Class I aquifer. Further, the site
will not be eligible for deletion from the NPL until the
cleanup criteria are achieved. EPA has determined that as
long as this potential threat to future ground water users
exists, the selected alternative will not change. Adequate
info~ation was available to select an appropriate remedy
and meet the criteria required under the NCP. Consequently,
any addit i ona1 monitori ng to defi ne the plume ~ay he con-
strued as unnecessary remedial investigation. The design
proposed in the FS was hased on the plume defined by the
model as a cost comparison mechanism for +50% to -30% as
defined in the NCP. The placement of more monitoring wells
during the remedial design stage is appropriate because
more specifics of the plume boundary will be necessary to
rlevelop an effective purge system. The site specific
Record of necision has defined the cleanup levels for
ground water and the additional ground water data collected
during the design stage will be used to design an effective
site-specific purge system.
"
The POTW was not dis~issec1 from the decision process. The
Record of necision considered this alternative. Further,
the FS presented cost estimates hased on the proposed purge
syste~. tinder this alternative, sewer lines would be
installed from the Rurrows site to a ~ainline for the
Hartford POTW. At the publication of the FS it had not
heen determined whether or not the POTW would accept the
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Comment:
Response:
Comment:
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Response:
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contaminated grounrl water. It has now heen determined by
communication with the POTW that the POTW will not accept
industrial wastes into its tre~tment system. Further, this
~lternative is not a cost-effective alternative.
The MnNR suggested the fo 11 owi ng concept of "mil estones"
he incorporated into the purging remedial action to achieve
acceptahle ground water quality.
1)
Purging the grounrl water until rlrinking water levels
are achieved at all monitoring wells.
?)
Purging a volume of water equal to that in No.1 or until
all monitor wells are less than levels of detection.
3)
EPA and MnNR determining after completion of No.1 and No. ~
above whether additional purging is necessary.
It is EPA policy to define a clean up level for
any remedial action when it is intended to be the final
remedy. EPA will be able to accomodate Michigan's request
because the cleanup criteria for the ground water have heen
defined as the lowest regulated concentration for the
particular indicator chemical. The purging of one addi-
tional volume can also be justified hecause although
definition of the plume will he further defined during the
remedial design phase, the exact extent of the plume can
never he completely defined. This additional volume of
purging will assure no elevated levels remain in the ground
water to threaten human health. IteM number 3 will be
accomplished through the amended risk assessment which will
be required hefore determining that no further repsonse is
appropri ate.
... the "plume" of contaminated ground water which the
EPA would expect to find were sample wells to he sunk
appears to he haserl on a modeling technique which mayor
may not bear any relationship whatsoever to the actual
conditions found on site. Indeed, the RI/FS study clearly
indicates that the contaminated ground water plume projection
conta i ned in the R I /FS report const itutes a "worst-casp.
scenario", with suhstantial possibility that true site
conditions are suhstantially different from those projected
by the VHS modeling technique.
The EPA agrees that the morlel represent the "worst-case
scenario". However, the Agency has concluded the purging
of the contaminated ground water would still he the selected
alternative even if the actual boundaries were known at this
time. Therefore, F.PA has rlefined the cleanup levels and
will continue to define the actual extent of the plume
under the remedial design phase prior to designing and
implementing the detailed purge system.
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Alternative Selection
Comment:
For all alternatives presented, no concise summary of scores
for evaluation criteria is presented. The narrative format
utilized represents ~ suhjective methodology and provides
no insight as to how the technologies evaluated scored on a
comparative hasis with respect to the identified criteria.
Response:
For example, the utilization of alternative water sources
(bottled water, new well installation) was discussed as
nonapplicable due to "no imminent h~zard potential" on
tahle 2-2, however, treatment of groundwater is selected as
a component of the selected alternative to "eliminate the
potential risk to current anrl future groundwater users".
In light of the extremely limited number of downgradient
receptors to groundwater, the utilization of alternative
water supplies appears to he more feasible than presented
in the FS. Since alternative water supplies were not
evaluated and direct discharge to the POTU and the potential
for on-site use of groundwater have been summarily dismissed, -
no comparison of relative costs and henefits can be made.
The selection of a specific methodology of groundwater
treatment is arhitrary at this time and does not meet the
intent of the FS process.
Section IV of the Feasibility Study (FS) presents a detailed'
evaluation of each alternative for final remedy. As defined
in the RIfFS guirlance, the alternatives were evaluaterl on
established technical criteria, environmental criteria anrl
cost factors. Each alternative was closely scrutinized baserl
on the indivirlual points in each evaluation criteria. The
across-the-board application of t~ese criteria to the
alternatives was in effort to objectively compare the
alternatives.
Each alternative was singularly analyzed to determine its
technically feasibility, the adverse and heneficial environ-
ment effects, and the total rlollar cost. There has heen no
attempt hy the Agency to rate or score each alternative.
The evaluation was rlevised to rlemonstrate whether or not
the specific criteria set forth in the NCP was met. Rased
on the most favorahle evaluation, an alternaive was chosen
as the recolTIITIended remedial action.
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This analysis is most effective and efficient method to
evaluate the identified alternatives and choose a recolTIITIended
action. A scoring system was not constructed for comparison
purposes due to the questionahle accuracy of such a system
and the helief the such a potentially complex and elaborate
scoring system would not only be cost prohibitive but would
he no more effective than the present method. In addition
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to the concerns presented, the Agency has settled on a
nationwirle approach in evaluating alternatives as rliscussed
in EPA's Guirlance on Feasibility Studies IInder CERCLA
(June 19A5).
In reference to the selection of purge and treatment of
ground water, EPA has established up front that the contami-
nated ground water at the site presents a potential health
risk to present and future users of grounrl water rlrawn from
the shallow aquifer. With this in mind, extraction of
contaminated ground water was determined to he a necessity
and not a dehatahle issue. The FS evaluated two courses of
action in regards to treatment of ground water, those heing
on-site treatment or removal to the POTW for treatment.
nue to the refusal of the local POTW to accept industrial
waste, on-site treatment is felt to be the most feasible
alternative.
General
Comment:
F.PA should use a Negotiation necision noculTlent (Nnn) rather
than a Record of necision (ROn) for its decision at this site
Response:
Consistent with the EPA Fehruary ~7, 19A5, Guidance nocument
"Preparation of necision nocuments for Approving Fund-
Financed and Potentially Responsible Party Remedial Actions
IInder CERCLA", a ROD is requirerl for all remedial actions
financerl with monies from the Trust Fund. A ROn has heen
preparerl selecting the cost-effective remedy for the Rurrows
site and estahlishing the cleanup criteria for the remedy.
While negotiations are underway, a Nnn sets out the approved
range of negotiating flexibility. It is an internal Agency
document which is not released to the public. A Non is
virtually identical to a ROn, except that it may provide for
this flexibility in negotiating the remedy. As the RI/FS
is completed and the cleanup criteria are established, such
flexibility is not necessary.
(;
The cleanup levels in the ROn lTIust be met hy EPA or hy the
PRPs. The ROO sets forth the remedy EPA will implement. EPA
expects any remedy proposed by PRPs to be equivalent or
hetter than the remedy in the ROn.
. "
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