United Slates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-86/040
September 1986
Superfund
Record of Decision;
Metamora Landfill, Ml
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TECHNICAL REPORT DATA
(PttflJt rtfld IflltfUct/OrtS art tht rtlltnt btlMr corn"trt'rt,)
,. AE'O..T NO. 12. 3. RECIPIENT'S ACCesSION NO.
EPA/ROD/ROS-86/040
.. TITL.E AND SUITITL.E 5. REPORT DATI!
SUPEFUND RECORD OF DECISION C:".n~ember 30. 1986
Metamora Landfill, MI s. PERFORMING ORGANIZATION COOE
1. AUTHOR/51 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING OJillGANIZATION NAME AND ADDRESS 10. PROGRAM EL.EMENT NO.
", CONTRACT/GRANT NO,
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVEREO
U.S. Environmental Protection Agency '!:'~""" ~nn
401 M Street, S .w. I.. SPONSORING AGENCY CODE
washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
18. ABSTRACT -
The Metamora Landfill site is located in Metamora Township, Lapeer County, MI. The
SO-acre landfill was previously used for gravel mining and in 1966 as a privatel~owned,
unregulated dump. In 1969 it was upgraded to meet existing standards, and licensed to
receive general refuse. The, site accepted both municipal and industrial waste until its
closure in 1980. While undocumented, it is likely that the previous owner disposed of
waste and drums in unlined excavations (former mining pits or borrow areas). In 1981
approximately eight drums were discovered durinq borrow excavations for a nearby sol id
waste transfer station. The, Michigan Department of Natural Resources (MDNR) samc1ed
seven of these drums and identified the presence of VOCs, and other orqanics. A 1982
MDNR study concluded that as many as 35,000 drums, some containing liquid waste, miqht
be present in five disposal areas around the site. The survey concluded that area on~
(16,000 drums) and area four (10,000 dr urns) contained about 74% of the total estimated
number of burial drums. While each of the five disposal areas was initially consiner~0,
areas two, three, and five were eliminated due to the inability to confirm drum presence
at inaccessible depths. Remedial actions for ground water, which poses a public h~a1th
threat, and soil have not been addressed due to insufficient data detailinq the extent
of contamination. Based on an estimated 26,000 drums and associated waste material
between drums in areas one and four, the total estimated waste volume requiring discosal
(See Attached Sheet)
11. KEY WOJIIIDS AND DOCUMENT ANALYSIS
~. DESCJIIIIPTORS b.IDENTIFIERS/OPE'" ENDED TERMS C. COSATI Field/Group
Record of Decision
Metamora Landfill, MI
Contaminated Media: qw, soil
Key contaminants: VOCs, TCE, PCE, heavy ..
metals
'8. DISTRIBUTION STATEMENT 19. SECuAITY CLASS / TlIII Rrponl 21. NO. OF PAGES
None '1
20. SECURITY CL.ASS ITllil papi 22. PRICE
Non@
!,. ,- 2220-1 (R.... .-11)
p"avlous aOITION II O.SOloaTa
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EPA/ROD/R05-86/040
Metamora Landfill, MI
16.
ABSTRACT (continued)
is 18,150 cubic yards.
and heavy metals.
Th~ recommended alternative for this operable unit is the excavation of areas one and
four, and thermal destruction of all waste at a compliant RCRA offsite incinerator. The
estimated 30-year present worth cost is $41,500,000.
Th~ primary contaminants of concern include:
VQCs, PCE, TCE,
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Record of Decision
Re~edial Alternative Selection
SITE: Metamora Landfill, t1etamora, Lapeer County, r1ichigan
DOCUMENTS REVIEWEO
I am Daslng n~ ueC1Sl0n primarily on the following documents describing
the analysis of the cost-effectiveness of remedial alternatives for the
M2t~mora Landfill:
IJ
- Hetamora Landfill Phased Feasi bil ity Study - August 19R6
- Metamora Landfill Site Characterization Report - February 1986
- Summary of Remedial Alternative Selection
- Responsiveness Summary
- August 18, 1986 letter, Seth Phillips, MDNR to John Tanaka, U.S. EPA
DESCRIPTION OF SELECTED REMEDY
The recommended remedy for the Metamora site is to excavate disposal
areas one and four, and dispose of all waste at an off-site RCRA compliant
incinerator. The estimated present worth cost of the alternative is
$41.5 million. The actual excavation of the material is expected to take
approximately six to eight months to complete. Oisposal of the material
will depend on the availability of RCRA compliant facilities. No operation
~nd maintenance will be required to effect the remedy.
J~CLARATIONS
Consistent with the Comprehensive Environmental Response Compensation
~nd Liability Act of 1980 (CERCLA), and the National Contingency Plan (40
eFR Part 300), ! have determi ned that the chosen remedy at the t.1etamora
Landfill is a cost-effective remedy and provides adequate protection of
public health and the environment. The State of Michigan has been consulted
~.nd agrees wi th the approved remedy.
I have also determined that the action being taken is appropriate
when balanced against the availability of Trust Fund money for use at
other sites. In addition; the off-site transport and destruction of
:xcavated waste is more cost-effective than other remedial action, is
..:cessary to protect public health, welfare or the environment, and is
~~nsistent with the anticipated final remedy.
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_/-
The Michiga~ nepartment of Natural Resources, through a Cooperative
Agreement with the U.S. EPA, is undertaking additional Remedial Investiga-
tion/Feasibility Study activities to evaluate the necessity for soil,
ground water, and other remedial action. If additional remedial actions
are necessary, a separate Record of Decision will be prepared for approval.
Date
Valdas V. Adamkus
Regional Adminis
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
METAMORA LANDFILL
SITE LOCATION AND DESCRIPTION
The Metamora Landfill is located in Metamora Township, Lapeer County,
Michigan, approximately one-half mile northeast of the village of Metamora,
and 20 miles east-southeast of Flint, MI (Figures 1 and 2). The sitp is
an 80-acre closed landfill that accepted industrial and municipal waste
between 1966 and 1980. As ~any as 35,000 drums ~ay be buried in the
landfill. The area was previously used for gravel mining, which accounts
for the many steep excavation faces and borrow pits'on the site. A
gravel mining operation continues immediately south of the site, and a
licensed solid waste transfer station currently operates in the western
area of the site. The surrounding land use is both residentia1 and
agricultural. About 60 people use ground water downgradient of the site.
The Village of Metamora's 1982 estimated population was 596 people.
SITE HISTORY
The landfill began operations in 1966 as a privately owned, unregulated
open dump. In 1969, the landfill was upgraded to meet existing standards,
and licensed to receive general refuse. Two fires at the landfill were
documented in 1972 and 1979. The 1972 fire reportedly burned out of
control for three days, perhaps fueled by waste materials in the landfill.
The site accepted both municipal and industrial waste until its closure
in 1980. No records have been discovered that indicate the disposal
practices of the former operator. However, it is likely that waste and
drums were disposed of in unlined excavations (former mining pits or
borrow a rea s) .
PREVIOUS SITE INVESTIGATIONS
In 1981. approximately eight drums were unearthed in area four (Fig. 3)
during borrow excavations for the nearby solid waste transfer station.
The Michigan Department of Natural Resources (MDNR) sampled seven of
these drums and identified (but did not quantify) the presence of methylene
chloride, methyl chloroform, dichloroethylene, and styrene, and found up
to 40 mg/kg lead. In 1982, the MDNR conducted a magnetometer survey
which concluded that as many as 35,000 drums, some containing liquid
waste, might be present in five disposal areas around the. site (Fig. 3).
The survey concluded that area one (16,000 drums) and area four (10,000
drums) contained about 74% of the total estimated number of buried drums
in the landfill. Hazardous chemicals in buried drums from areas one and
four were confirmed from limit~d test pit excavations done by the MDNR in
June and September 1982 (Table 1). .
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MET AM ORA, MICH.
N4252,5-W831517.5
1968
PHOTORE1.JIS:D 19SC:
DMA 4~69 IV NE-SERIES VB62
o APPROXIMATE LOCATIONS OF NEAREST
DOMESTIC WATER SUPPLY WELLS
12000
14000 FEET
FIGURE 2
SITE LOCATION MAP
E.CJORDANCO
10
4465-92
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Table 1
Summary of Liquid and Solid Drum Samples
Concentration
Compound Oetected Range Area ~1at ri x
Ethyl benzene * NO-27 1 Solid
II II 750-25,OuO 1," L.lquid
Tol u en e * NO-100 1 Solid
II 1,200-13,000 1,4 Liquid
Trichloroethylene * NO-2.7 1 Sol i d
II NO-20 1,4 Liquid
1,1,1-Trichloroethane * NO-1.6 1 Solid
II ND-20 1,4 Li qu i d
Tetrachloroethylene NO-3.5 1 Sol i d
II NO-65 1,4 Liquid
Xylenes ND-100 1 Solid
II 2,000-80,000 1,4 Liquid
PCBs NO-l. 7 4 Sol i d
Hexachlorobenzen~ ND-3.2 4 Sol i d
1,2,4-Trichlorobenzene NO-3.3 4 Sol i d
Octachlorocyclopentadiene NO-0.28 4 Solid
1,3- and 1,4-Dichlorobenzene 20-22 4 \~ater
Chlorofonn NO-lSO 4 Li qu i d
1,1-Dichloroethane * ND-240 4 Liquid
1,2-Dichloroethylene NO-25 4 Liquid
1,2-0ichloroethane * NO-300 4 Liquid
Notes:
1. All values in parts per million (ppm)
2. NO = Not detected
3. * = Also detected in ground water
4. Fo'r complete data, see LC. Jordan Site
February 1986.
Investigation Report,
Table 1 shows that a variety of organic chemicals were detected in high
concentrations in liquid and solid samples from the drums, including the
carcinogens 1,2-dichloroethane, and 1,1,1-trichloroethane, tetrachloroethylene,
. tri chl oroethyl ene, and hexachlorobenzene. '
"
In the summer of 1985, the MONR initiated pre-remedial investigation
activities at the site, during which soil borings were taken and thirteen
ground water monitoring wells emplaced. That work determined that the
site geology is variable, but generally consists of unconsolidated sand
and gravel that is 250-300 feet thick in some locations, underlain by a
clay/till unit. Ground water occurs at an average depth of about 100 feet
below ground surface, with the deep aquifer at about 300 feet. Ground
water flows from the south-central part of the site to the northwest and
northeast (Fig. 4). Sampling results from the investigation confinned
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MAGNETIC ANOMALIES
PREVIOUSLY-EXISTING
SITE WEU,S
"SHAL.LOW" WELLS,
THIS INVESTIGATION
"DEEP" (SOIL) WELLS,
THIS INVESTIGATION
FIGURE 4
SITE AREA
s
INTERPRETIVE WATER TABLE ELEVATION
SURFICIAL AQUIFER
#1." INFERRED ELEVATION
Q~iI OF THE WATER T~E
, I\i C5-'!6'85-MS!.. DATUM
E.CJORDANCO
-------
. ~::. _-.L', ,,;.'...:' 'h'; '0,: ;"'I.\':i~.','.~.:.( --;-.~,j"~. ;1.:Z":--:'~'~.....:..J'. :'''''::~~l~'''-:';~l~':-:'::~'::'}'\-'::':-:--'''.AJ.~~! ..::"~ ....:-k~~.. ~'''.' ...,..'..':...,.'':':,......' ':..:"",,,,:.,,.\.:,~,!,,,' :;." I :", ~.:. ',.:... , " .' :"., : ~i"" ..,_>.10 .~.:. ',:1". "\._~'...:':\~'...~".t;:::.-:..'..=-~'.~/~'~~~i.....'- '...;.....=t.1-'::'.,:::=.:.:...~:-.!.~{ ;-....
-3-
the the existence of organic and inorganic ground water contamination.
Monitoring wells MW-4 and ~1W-8, located in the immediate vicinity of area
4, and monitoring wells HW17s and 17d, located adjacent to area 1, all
showed contamination by volatile organic compounds (Table 2).
Table 2
Summary of ~1onitoring Well Sampl ing
Compound Detected
Benzene
Ethyl benzene *
Methylene chloride
Toluene *
Trichloroethylene *
Trichlorofluoromethane
Trans-1,2-Dichloroethane
1,1,1-Trichloroethane *
1,1-Dichloroethane *
1,2-Dichloroethane *
Diethylphthalate
Di octyl phtha 1 ate
Bis(2-ethylhexyl)phthalate
Di-n-butlyphthalate
Notes:
Concentration
Range
(All ~Jell s)
NO-23
ND-1500
ND-79
ND-660
ND-13
ND-200
ND-360
ND-12
ND-95
ND-46
ND-9.6
ND-410
ND-240
ND-38
Well s Detected
4, 17s
17s, 17d
4, 11, 14s, 15s, lSd, 17s
17s, 17d
8
8, 14s, 14d, 15s, lSd, 17d
4, 8
8, 14s, 15s
8, 14s, 15s, 17s
8, 17s
8, 14s
17s
15s, 17s
11, lSd
1. All results in micrograms per liter (ppb)
2. ND = Not detected
3. * = Also detected in drum samples
4. Table shows significant organic data only -
E.C. Jordan Site Investigation Report, Feb.
for complete data see
1986
Some of the same hazardous substances were detected in drum samples
(Table 1) and in ground water samples near drum disposal areas one and
four (Table 2). Therefore, it is very likely that hazardous substances
in suspected drum disposal areas one and four have migrated into the
ground water. The pre-RI work is summarized in the report entitled,
USite Investigation Final Report" (E.C. Jordan, February 1986).
"
RISK TO RECEPTORS VIA PAT~JAYS
The primary public health threat posed by the Metamora site is consumption
of contaminated ground water by downgradient residential users.. Approximately
60 residents are potentially affected by migrating pollutants in ground
water. Benzene, 1,2-dichloroethane, and trichloroethylene, which are
known or suspected human carcinogens, have been d~tected in on-site
-------
-.1-
monitoring well samples in concentrations that exceed the lxlO-6 acceptable
risk level established by U.~. EPA. The carcinogens chloroform, hexachlo-
benzene, and tetrachloroethylene have also been found in excavated waste
samples, and might migrate into the ground water. No contaminants have
as yet been detected in downgradient residential water samples, but
future contamination is very possible since the buried drums are probably
in poor condition (rusted and/or leaking). The ongoing Remedial Investi-
gation/Feasibility Study will better define the hydrogeology and the
existence of anJ' ::'!"~,.:n' ~...'. :=~'"",; ~s) in ground water. Direct contact
with contaminated soils is currently not a threat since the waste is
buried beneath at least 10 feet of fill dirt. No air emissions have been
detected in the vicinity of the disposal areas. However, if the site
were used in the future, and the fill covering the drums became exposed,
the drums and their contents could present an inhalation and direct
contact hazard.
ENFORCEMENT
On June 20, 1985, Notice Letters that described the upcoming Remedial
Investigation and Feasibility Study were sent to nine Potentially Responsible
Parties (PRPs). On April 29, 19A6, Notice Letters were sent to ten PRPs
offering them the opportunity to undertake the Agency's remedy for this
operable unit. To date, PRPs have shown little or no interest in partici-
pating in the remedial process. On July 28, 1986, Region V EPA, through a
joint memorandum from the Hazardous Waste Enforcement Branch and the
Office of Regional Counsel, terminated the PRP negotiations for the
operable unit. Therefore, Region V EPA has recommended the use of the,
Hazardous Substance Response Trust Fund, as described in CERCLA, Section
111, to fund the project. Two PRPs did, however, provide written comments
on the public comment draft PFS, but still 'did not demonstrate a willing-
ness to participate in the project. Theirs and other public comments are
summarized in the attached Responsiveness Summary.
PHASED FEASIBILITY STUDY METHODOLOGY AND APPROACH
In response to the potential health threat posed by the site, a Phased
Feasibility Study (PFS) was initiated, the objective of which was to
formulate remedial alternatives that were protective of public health and
the environment. To this end, source control remedial alternatives (as
defined in the National Contingency Plan, 40 CFR Part 300.68(d)) that
dealt with the five identified drum disposal areas were examined in
detail. Management of migration remedial alternatives were not deemed
necessary at this time since, based on the most recent monitoring well
samples, contaminants had not migrated a significant distance from their
original locations.
The PFS then analyzed which source control remedial alternatives were
most appropriate. The study initially considered each of the five disposal
areas thought to be a source of contamination. Three of the disposal
areas (2, 3, and 5) were inaccessible due to the depth (from 27 up to 80
feet) at which materials were disposed (Fig. 3), so the presence of
buried drums in these areas was not confirmed. Areas 2, 3, and 5 also
-------
.~'.... '.' ,~". '.... .~.,'.. ~ . '-.:. .-1... ~ ",".J.',~,"~"';""..c" .::,'..~.....~7.....' ~......,,~.:.;;,.~ ..'- ;',:"",,,,,,,,.~'-''''''''''.'''..i"..',,,,,,,,,,,,,'.;'..~...':;,\"..... .~; ~~....;. :.J",,',-'-:., ~_.-......",.; '" ."'....--.-.. '~'.. -: '''I._~ . ~'.":''''''. ."'."""" ,~- :',:,,"".! ',...... '....-...~ 1..:L...~-.~;A;-""J,...JL'....:
-5-
were suspected of containing metallic municipal waste, which may have
biased the magnetometer survey performed in these areas. hiven the
limited information available for areas 2, 3, and 5, and the anticipated
depth of burial, it was not possible to accurately predict the cost of
remedial action alternatives in these areas. On the other hand, no
municipal waste was believed to have been disposed of in areas one and
four, and the existence of drums in these areas was confirmed hy limited
excavations- Therafnre, the PFS developed source control remedial action
alternatives lor d1sposal areas one and four only, in which it was estimated
by the t1DNR magnetometer survey that the maj ori ty of the drums (26,000
out of 35,000, or 74%) existed. Therefore, although areas 2, 3, and 5
may also contain hazardous waste, the PFS examined the known disposal
areas (one and four) believed to be major sources of contamination at the
site. The RI/FS will investigate areas 2, 3, and 5 in detail and propose
appropriate remedial alternatives if necessary.
Soil an~ ground water contamination were not addressed by the PFS. This
was because insufficient information was available to determine the
extent of contamination. Therefore, reasonable cleanup targets could not
be ac~urately established. The RI/FS, scheduled for completion in FY '88,
will establish cleanup targets for ground water and soil.
Some material between the drums may be highly saturated with hazardous
chemicals from leaking drums. For the purpose of the PFS, this interstitial
material was considered to be waste, rather than soil. This waste material
, would be disposed of along with drummed material. Based' on an estimate
of 26,000 drums and associated "interstitial" waste material, the total
estimated waste volume requiring disposal during this operable unit is
18,150 cubic yards (see Table 3 for calculations).
ALTERNATIVES EVALUATION
Using the response objective of source control of areas one and four as a
guideline, potential remedial alternatives were assembled and screened.
The following alternatives were eliminated during the screening process
using the NCP criteria of cost, acceptable engineering practice, and
effectiveness at addressing the site problem.
1. On-site incineration alternatives would involve the construction of a
facility on-site. A key factor in the decision not .to evaluate on-site
incineration alternatives in detail was the additional time necessary to
implement such a remedy. Due to the time needed to construct a facility,
and the statutory requirements of Michigan Act 64 (Hazardous Waste Management"
Act), actual incineration of excavated waste under the on-site option
would take an estimated 21 to 27 months longer than an off-site incineration
alternative. Act 04 establishes a procedure whereby State technical standards
are applied on a site-specific basis. This process is extremely lengthy
and State technical standards are applied strictly. The process has seldom
resulted in the construction of an incinerator on-site; incinerator
construction has been authorized only once since 1979. Table 4 outlines
the necessary activities and time frames for both the on-site and off-site
incineration scenarios.
-------
Table 3
Estimate of ~aste Volume to be Excavated and Disposed
Assumptions:
1. Number of drums in area one = 16,000
., NIII"her"~ rirums in arp~ four = 10,000
3. All drums uncrushed
4. Volume of one drum = 7.35 cubic feet
5. Interstitial waste material volume equal
to volume of drums
Calculations:
DRUMS:
Solids:
7.35 cubic feet cubic yard
21,000 drums x --------------- x .------------- = 5,717 cu. yd.
drum 27 cubic feet
Liquids:
7.35 cubic feet cubi c ya rd
5,000 drums x --------------- x ------------- = 1,361 cu. yd.
drum 27 cubic feet
INTERSTITIAL WASTE:
Interstitial Waste Volume = Volume of Drums
= 7,078 cu. yd.
- 14,156 cu. yd.
4,000 cu. yd.
18,156 cu. yd.
Total Excavated Waste
Waste From Storage/Staging Area
Total Waste for Disposal
-------
" T "J'; ,,' ,
. ~'. -.: ..,' ,.:, . . .,' :'- \'.
,.' : ,~" #;.':".:.: :.:',-' ~".~:-:.', '.~~,.~~-:~tf:~~~~;~:':'~~:.:i~.~~'c:,>.:~'j:'0:'~"~:~,:/~:j:::~~\:i-;~~~i,r:}11~~:~;~;r~~:,:~;.!',~':['~'~: .--;~ ':~'\~.:' :,[: ~:~~:<:_i:.~'.~~~ '~::'.::!:!':~ .~;..::~r:.;~;''''~~'''':';I~::-~..::: ~.. "~-" '-~:<~- :::.'~ ~"" :,
-6-
Table 4
Implementation Time for On-site vs. Off-site Incineration
Implementation Time (months)
On-site Off-site
Act i vity:
. '7' ..;st Pi ts 3-4 3-4
...
2. Remedial Des i gn 6-8 6-8
3. Prepare Act 64 Application 3-6 N/A
4. t1DNR Technical Review 3 N/A
5. Site Review Board Review 3.5 N/A
6. Procure Contractor 3-6 3-6
7. Construct Facility 6-8 N/A
8. Construction Inspection and 1 N/A
Certification
9. Revi~w Operating License Ap p 1 i c. 3.5 N/A
10. Tri al Burn and Review 1-2 N/A
11. Excavate and Test Waste 3-4 3-4
12. Begin Incineration
Total Time to Begin Incineration 36-49 15-22
Table 4 demonstrates that the off-site incineration alternative can he
implemented at least 21 to 27 months sooner than the on-site option. The
on-site alternative requires many more review steps than off-site incinera-
tion, which means that there are more ways that the project could he
further delayed. Therefore, the estimate of 21 to 27 months is the
minimum delay expected.
v
Besides having serious schedule implications, the on-site alternative has
real environmental impacts associated with it as well. The drums in
areas one and four are known to contain hazardous materials in relatively
high concentrations. The Site Investigation report (E.C. Jordan., February
1986) has demonstrated that these drums are probably leaking their contents
into the upper ground water aquifer which is currently used as a drinking
water source. Ground water in the vicinity of the site generally moves
to the northeast and northwest. (Off-site ground water flow must be further
defined). Assuming that ground water flow continues in these directions
beyond the site boundary, approximately 60 people within one mile of the
site are in the path of a potential contaminant plume. (T~e current data
neither confirm nor deny the existence of a contaminant plume). If
off-site ground water flow turns out to have a western component, the
supply wells for the Village of Metamora, (located approximately one-half
mile to the west of the site), which serve about 600 additional residents,
may also be impacted. If no plume currently exists, and contamination is
conf1ned to the area immediately adjacent to the source ~aterial, timely
implementation of source control may prevent a contaminant plume from
forming.
-------
.-.., ...', ,-..r."_. ..",.....~,""" O',;,,,'"...~... .--"...., -r,... .",:';""-O,""'''''''U-:.''''''''''''''''' "",""_..-""'''r""~--""",,,,,,,,,,,,,",-.".,,......N;,..-:_.'I#~;>,,,,,,,,_,''l;;'_h,..-,-....' ,." ....~"".,-.. .... .-.
.....".'.", ,'..'-"..""",,,. ..""'.#, ,.',...
-7-
At a minimum, the implementation of source control will prevent further
degradation of the drinking water aquifer. Much greater expense will be
incurred in order to extract and treat contaminated ground water if
contaminants continue to enter the soil and ground water. The current
monitoring well network may not detect an off-site plume. Therefore, the
minimum 21 to 27 month time delay associated with on-site incineration
could prove to have significant adverse environmental effects.
In light OT the above issues, and the fact that the project was designed
as a source control remedial alternative requiring more immediate attention,
it was decided that on-site incineration was not an implementable alternative
at this time. Therefore, it was not carrierl through to the detailed
alternatives analysis.
2. Solidification and/or chemical fixation technologies were screened
out due to the high volatile organic content of the waste. The intent of
this technology would be to create a non-leachable material to reduce the
toxicity and/or mobility of the waste. Lime and inert organic polymers
have been used in the past. However, fixation technologies have been
generally used for wastes containing PCBs, metals, and some semi-volatile
compounds. The high volatile content of the waste makes this particular
technology inapplicable for this operable unit.
3. Landfarming would involve the mixing or dispersion of was~es into a
soil-plant system, the objective .of which would be microbial stabilization,
adsorption, and' immobilization of the waste. Landfarming was not considered
in detail because of the heterogeneous nature of the waste, which would
make the determination of the effectiveness and applicability of this
technology very difficult. Furthermore, landfarming is a relatively
untested technology for hazardous waste disposal.
4. Recycling was ruled out du~ to the heterogeneous waste stream, which
1 imits the technology's applicability and effectiveness. Recycling has
been normally applied to well-d~;~ned homogeneous industiial waste streams,
and cannot be aepended on to adcioess a significant volume of waste during
this operable unit.
DEiAILED ALTERNATIVES ANALYSIS
After the alternatives screenin~ Droces: wa~ ccm~ieteG, :ne following
~lternatives were examined in detail.
o
1. On-site RCRA landfill
2. Off-site RCRA landfilling
3. Off-site incineration
4. Combination off-site incine:-atiofi
and off-site landfill
... No action
;C,i'; of the alternatives excep'~ "V~ :-:c. ~::tion involve tr,:: excavation and
:es:ing of waste in areas one a~~ ~c~r, and the construc~ion of two
-------
-R-
temporary staging and testing areas on-site. The cost of these activities
(total - $ 3.63 million) is the same for each alternative except no
action (see Tables 5 and 6 for detailed costs).
I. On-site RCRA Landfill - This alternative would involve the construction
of a double lined RCRA Subtitle C facility on the site. approximately one
acre in size. The alternative would include provisions for leachate
collection and disposal. general operation and maintenance. such as
sampling and testing. and cap repair or replacement. Liquids would be
solidified prior to disposal. but no waste treatment would take place.
Long-term monitoring would also be an integral part of the remedy. Such
a landfill would be easily constructed, and reasonably protective of
public health and the environment. Detailed costs are shown in Table 7.
2. Off-site RCRA Landfill - Under this alternative, all waste would be
transported and disposed of at an off-site compliant RCRA landfill.
Liquids would be solidified (but not treated) prior to disposal. The
land~ill chosen could be expected to provide adequate protection of
public health and the environment. Operation and maintenance would he
the responsibility of the disposal facility. Detailed costs are shown in
Table 8.
3. Off-site Incineration - All waste would be transported to and disposed
of at an off-site incinerator. Depending on the waste characteristics,
several different commercial incinerators might be used (e.g. liquids and
solids might go to separate facilities). This remedy would offer a
significant volume reduction of liquids, rerluced waste mObility and
toxicity. and long-term reliability, protection, and effectiveness.
Detailed costs are shown in Table 9.
4. Combination Off-site Incineration and Off-site Landfill - Liquid
waste would be disposed of at an off-site incinerator, and solid waste
would be taken to a compliant off-site RCRA landfil'. (See the above
discussions for the elements of this remedy). Detailed costs are shown
in Table 10.
5. No action - Under this alternative. no remedial activity would take
place. No money would be spent for this alternative. It was included
primarily to compare remedial alternatives to baseline conditions.
Table 11 shows the present worth and relative costs (as compared to the
on-site landfill) of the alternatives.
-------
TABLE S
STAGING/STORAGE AREA COSTS
Access road and fencing around storage area
$ 4,400
Berms - 4'high, separating storage areas
4,800
Liner
38,300
Gravel working surface
14,500
Surface water control - drainage
ditch, pond, piping, treatment
7.500
Subtotal
$69,500
Mobilization
3,500
Contingency
17,000
$90,000
Total
. ~
;;
. . .."
J.. uo. l.\. .:,.J.
0011. 0.0
-------
TABLL 6
EXC"; VATION A::D C:i..l...'='...l.CTER l Z..;T:OS
TESTn;G COSTS
Excavat.ion
Excavation Equipment - grappler,
loaders, dozer
On-Sit.e transport. equipment -
t.ank t.ruck, fork lift.s
Labor - 10 people
Supervision
Cover soil over excavated areas
Charact.erization Testin~
1 chemist. and 3 t.echnicians
On-site laboratory
Total Cost.
Su"BTOTAl
Mobilization
Decontamination
Facilities
Contingency
TOTAl
~obilization
Protective Equipment.
a:ld Continge!:lcy
TOTAl
Ex::avOlt.ion
Characterizat.ion Testing
~:e~~ckz (ass~~e$ :~00 cverpac~s & $80 each)
1. 86.103:
001:2.0.0
Te:.;!.
,...., ,..".'"
.., ~ -' ,
811,000
698,000
150,000
17.000
,52, 115 ,000
106,000
127,000
$530.000
$2,878,000
$274,000
61,000
$335,000
$10,000
117.000
$462,000
S2,8i8,000
462,000
200.0eO
S3,540,000
-------
TABLE 1
COSTS FOR ON-SITE DISPOSAL
Caoital Costs
Site Preparation
. Liner
Leachate Control
Cap
Access road and fence
Leachate storage and treatment
. Monitoring wells
Solidification of liquids (assume 5000 drums)
Placement of waste
SUBTOTAL
Mobilization
Engineering &
Contingency
Permitting
TOTAL
Annual Costs
Sampling and Testing
Maintenance
TOTAL
Cat) Ret)lacemen: Costs
Cap
Mobilization
Engineering
Contingency
TOTAL
u
1.B6.103'i'
0013.0.0
535.400
'\"0.000
74.100
17,800
14.000
19.800
47.900
375.000
259,000
$1,093,000
55,000
382,000
100,000
$1.630,000
$26,000
~
$28,000
. .
$17,800
1,900
8.000
$27,700
-------
~ '-'. -',: : /.:;: .":...-'-" ,~::..:' .~~.~~. I.'::..: .:
~ ..,:..- :"':'::.' ::..;:/;- ,.~:, ~ :::': , "~'. -~..>. .: :.""-
, '......:. ". ... '('.... ;"'..' :<.:. :.:::>:.'~ .::; ':>l:}~''';~:':'~':~~~~ :.::l-::~~¥~:.:;.::/..:'t.,..,\\.;'.\:.~i:':.;::'.':'-:;':;~"'}:'~~~:"-,i'.....~:~:~i.- i......~~.,;r:~::...~~;-i1..: :..;:: ~\ '-r:.I\ .~': "./':':..:..
.. ".
TABLE 7
(cont.)
Total Cost
In present worth, amortized at 10 percent for 30 years
Staging Area Costs (Table 5 )
Excavation and Testing Costs (Table 6
On-Site Disposal Costs
Capital Cost
Annual Cost
Replacement Cost
)
TOTAL
.
v
~.B6.103T
0013.1.0
$90,000
3,540,000
1,630,000
264,000
80,000
$5,604,000
-------
---.-- - -.- - - -.- - -_.-- _._---_.- ~..~-_._- - .
TABLE 8
COSTS FOR OFF - S HE DISPOSAl
PCB < 50 ppm 50 P"Om < PCB < 500 ppm
Solids Liquids Solids Liquids
. (per cv) (per drum) (per cv) (per drum)
Testing 5121 5151 602 1062
Testing at landfill 21 21 102 172
Trucking 21 8 64 20
Solidification 75 75
Landfilling3 200 60 330 107
Subtotal $235 $160 $464 $325
Contractor fee 60 40 136 95
Total 5295 $200 $600 $420
lAssumes compositing 80 drums of liquids or 100 cubic yards of solids.
2Assumes compositing 10 drums of liquids or 20 cubic yards of solids.
3These are average costs. Prices will vary depending on the type of waste.
Tot.al Cost
. .
In present worth, amortized at 10 percent for 30 years.
S:.aging Area Costs (Table S :)
Excavation and Testing Costs (Table 6 )
Off-Site Disposal Costs
8C~ of total volume PCB < 50 ppm
Solids - 12,240 cy
Liquids - 4,000 dr~s
20~ of total volume - 50 ppm < PCB < 500 ppm
Solids - 3,060 cy
Liquids - 1,000 drums
StaSing area materials - 4,000 cy
$ 90,000
3,540,000
3,610,000
800,000
Total
1,840,000
420,000
1. 180 ,000
$11,480,000
"
-. .' ,;.' il '.' .,.
_....,..~--
0015.0.0
-------
TABLE 9
COSTS FOR INC I~:ERA TI ON
PCB < 50 pum 50 ppm < PCB < 500 '.:)!)m
Solids Liquids So lids Liquids
(per cv) (per drum) (per cv) (per drum)
Testing $91 $91 $ 222 $ 192
Trucking 51 16 51 16
Incineration 11203 2104 2800 400
SUBTOTAL $1180 $235 $2873 $435
Contract.or fee -1!:Q 65 857 130
TOTAl $1520 $300 $3730 $565
lAssumes
2Assumes
3Tb.is is
"This is
compositing 20 drums of liquid~ or 20 cubic yards of solids.
composit.ing 10 drums of liquids or 20 cubic yards of solids.
a base price. The price will increase depending on t.he t.ypes of wastes.
an average price. The actual price may range from $105 to $840/drum.
..
Tot.al Cost.
In present worth, amortized at 10 percent for 30 yea=s.
.
Staging Area Costs (Table 5)
Excavation and Test.ing Costs (Table C )
Incineration Costs
80% of t.ot.al volume - PCB < 50 ppm
Solids - 12,240 cy
Liquids - 4,000 drums
20% 0: total volume - 50 ppm < PCB < 500 ppm
Solids - 3,060 cy
Liquids - 1,000 drums
St.aging area materials - 4000 cy
$ 90,000
3,540,000
18,600,000
1,200,000
11,410,000
570,000
6.080.000
TOTAL
$41.[.90,000
\,
1. 86 . 103T
0016.0.0
-------
.: -:,-;,.: '. t..:. J :;:- ~::'-'. :,', :~'.',~.::1;.~:-_;j:.~\. ~:"!' .:. :.--.~I 'J.-::.::';',,:':"':':~'::.;)::.~:"_~ :.\~..':::.. -.: .~:~ .~::;4' :.~ ..::: ~,;:~:.C4":':..::.:.~;' :'':'L'...~:~lQ::.;,-:~-.~ i.L.,-:-"L:_,'.~-:":'::',,,~-:,:~~:;,:;;,:;:,;:-,,:::':';-,'-":';6:;::.~~;.~:,:.r ;':~~'. -~:"':~'~:.:.: .;.. ;.~." .....~-;,' .. ::- ~ :-."",,~ .:~ ',. -. ...I,.~:_, .
,\'.":.:.,:.a.-'....:
TABLE .1D
COSTS FOR DISPOSAL/INCI~~RATION
Incinerat.e Landfill
Liquids - Per Drum Solids - Per CY
50 ppm < 50 PPM <
~r~ (' c;rr PCB < 300 pnm PCB < 50 npm PCB < 500 ppm ~
T~sting $91 $20' 123 60~
'Test.ing a t. Landfill 23 102
Trucking 16 16 21 64
Landfilling4 200 330
Incineration 2105 4005
SUBTOTAL $235 $435 $235 $464
Cont.ract.or Fee ~ ~ 60 136
TOTAL $300 $565 $295 $600
lAssumes composit.ing 20 drums of liquids.
'Assumes compositing 10 drums of liQuieds or 20 cubic yards of solids.
3Assumes composit.ing 100 cubic yards of solids.
4Tbese are average cost.s. Prices will vary depending OD the type of wast.e.
&This is an average price. The actua: price may range from $105 t.o $840/d~um.
Tot.al Cost.
II) present worth, amort.i:ed at. IC pe::>'~:J:. for 30 ye2.rs.
St.aging Area Cost.s (Table S )
Excavation and Tes~ing Cos~s (Tabl~' : .~
Incineration of Liquids
80% of t.otal volume - PCB < 50 ppm
4000 drums
20% of t.ot.al volume - 50 ppm < P:B (5C~pp~
1000 drums
Landfilling of Solids
80% of t.otal volume - PCB < 5C' ppn
12,240 cy
20% of total volume - 50 ppm < PCB <500ppm
3,060 cy
S~aging Area Mate=ials
~,OOO cy
$90,000
$3,540,000
1,200,000
570,000
n
3,610,000
1,840,000
1.180.000
TOTAL
$1:,030,000
: .86. 103T
QOl7.D.D
-------
-9-
Table 11
Present Worth and Relative Costs of Alternatives
Alternative
Present Worth *
Relative
Cost
1. On-site RCR~ land~;"
2. Off-site RCR~ landfilling
3. Off-site incineration
4. Combination off-site incineration
and off-site landfill
5. No act ion
$ 5.6 mil 1 ion
$ 11.1 II
$ 41. 5 II
$ 12.0 ..
1.0
2.0
7.4
2.1
$ 0
* Present worths calculated using a 10% interest rate and 30 year project
period.
ENVIRONMENTAL IMPACTS
Many of the positive and adverse impacts of the alternatives were similar.
For example, all of the alternatives, except for no action, would require
excavation of areas one and four, causing some temporary noise and dust
impact due to heavy equipment at the site. The no action alternative
might allow hazardous chemicals to further migrate in the environment,
potentially contaminating residential wells. No adverse long-term environ-
mental or public health impacts are expected from the implementation of
the alternatives retained for detailed screening. The specific positive
and adverse environmental impacts of each alternative are discussed in
the sections entitled, "Alternative Screening Process" and "Recommended
Alternativell.
CONSISTENCY WiTH OTHER ENVIRONMENTAL LAWS
All of the alternatives examined in detail were designed to be fully
compliant with applicable environmental laws. The Resource Conservation
and Recovery Act (RCRA) entered prominently into the analysis. The
on-site iandfill alternative would meet all requirements of the RCRA
regulations at 40 CFR Part 264, Subpart N, as well as the requirements of
tne Toxic Substances Control Act (TSCA), 15 U.S.C., Section 2605(e), if
concentrations of polychlorinated biphenyls (PCBs) were high enough to
require a TSCA-regulated facility. However, it is expected that the
majority of waste at Metamora will not require a TSCA-regulated facility.
All off-site alternatives would involve only those facilities in compliance
with RCRA and/or TSCA. The recommended alternative would fully compiy
with all applicable State (notably Act 64) and Federal statutes.
~'-..-"""''' '""" "~I"". -'t'" ; ~"'~'':";-;t'' -"; .:.-. ,-- ,; .' -." ~. - "'. ----.... ~ '<"1, ".-.-"'"":"';-:',', ....,;.-:"'t5."7.r-;.:" .-: .-.:,.. ~--,;" i". -; """';':;,"::~""'::':."":-:'~"."~' r;;-...'{.~.':":t:;,;'---r''''f'';:...''!""';'':~~'';.''''of,,-\~'''~.T..:.."'':'...'r:''''{.:;'';.:''''-:.--:~;"'"':''i''.'J>I.:..'''~''"'';;~'':'''':''::~~:T?;~,'':'Y;:r:.::-''-'''"';-~''''' ":--
-------
-10-
ALTERNATIVE SCREENING PROCESS
The detailed screening process used to select the remedy was consistent
with the NCP, 40 CFR Part 300.68(h), U.S. EPAls most recent guidance
concerning the selection of off-site remedial alternatives, and other
AQP"'~v Qllidarrop ~s appropriatp. In addition, consideration was given to
the expected CERCLA reauthorization statutory language which stresses the
selection of permanent remedies, such as thermal destruction. The NCP
criteria used in the detailed alternatives analysis were:
1. Consideration of established technology and innovative and alternative
technology where appropriate.
2.. Detailed cost estimation, including operation and maintenance (O&M)
cost s.
3. Evaluation of engineering implementation, reliability, and construct-
ability.
4. An assessment of the degree of protection afforded by a given alterna-
tive, including the attainment of relevant Federal standards.
5.
6.
An analysis of any adverse environmental impacts.
Consistency of remedial action with final remedy.
7.
Cost-effectiveness of the alternative.
A summary of the alternatives with respect to the above criteria is
presented in Table 12.
The National Contingency Plan, 40 CFR Part 300.68(j) states that, "the
appropriate extent of remedy shall be determined by the lead agency's
selection of a cost-effective alternative that effectively mitigates and
minimizes threats to and provides for protection of pUblic health and the
environment," and that the lead agency shall consider, "cost, technology,
reliability, administrative and other concerns, and their relevant effects
on public health and the environment". The fol-lowing alternatives were
screened out based on the aforementioned criteria.
1. The on-site RCRA landfill was not selected for several reasons. Due
to the relatively permeable nature of the native soils, the site would
not be an ideal location for a hazardous waste landfill. Any breach in
the containment liner would allow contaminants to easily migrate into the
underlying ground water aquifer, which could then contaminate residential
water supplies. A corrective action program for ground water would be
very expensive since the upper and lower aquifers are about 100 and 300
, feet below ground surface, respectively. Installing extraction wells,
pumping, and treating ground water at these depths would be very'time and
capital intensive. Although the alternative offers greater protection of
pUblic health and the environment than no action, it does not utilize any
treatment of the waste that reduces its volume, toxicity, or mobility.
The on-site landfill alternative, though technically feasible, also suffers
...~.;o,.....~ -~. .;'""1"""~""''''';'1 ;''t''II'":! '-,n~.,r.'.'''',,' 'l.'f.:'I.'""F-''''' "': !.'" ..:...~-...,....~....; "'. ~~;""" V'r.',,~'!;" ,:".r'''":~;'''-,'-'''~-':r;,;K''"~':: ~:,,;'1:::"~:;"", :':.'::-. '-:'.~~'~'."E,',~-:-~'~"":'.'!".J~l..~.'~~~~':.~~?q~~;\"i"~'"'T;"~:-:;.":T~'\'.~;~';l,'-;",.~",:,_"..;,~.::",q ry\'~1:""'.' ~~.-:;~~". .::,,:..:.' r-:.'.."', ~~..=-'-",'':;'-,~ ::~..:'Y ~'r..:,
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-11-
from problems regarding implementability (see discussion re: on-site
incineration, p.5).
u
2. The off-site landfill alternative was also screened out. The alterna-
. tive requires a significant RCRA landfill volume (over 18,000 cubic
yards), and capacity in compliant facilities is currently severely limited.
~ delay in the actual disposal of staged waste may occur while waiting
for a facility to come into compliance. Additional negative aspects of
the alternative were its reliance on proper operation and maintenance to
preserve the integrity of the remedial action, and use of non-destructive
disposal technology. (The volume, toxicity, and mobility .of the waste
would not be reduced).
3. The combination off-site incineration and off-site landfill alternative
provides significant additional benefits over exclusively 1 and fill ing.
Thi$ alternative provides for the disposal of liquids at a RCRA compliant
incinerator and solid waste at a RCRA compliant landfill. The alternative
is clearly more desirable than the off-site landfill since it incorporates
incineration rather than land disposal of 5,00G drums of liquid waste at
an incremental cost of $535,000. However, this option suffers from the
same negative aspects as the off-site landfill alternative due to its use
of non-destructive disposal technology, and its reliance on compliant
RCRA landfill facilities. The alternative is about three and one half
times cheaper than total incineration. However, the benefits gained from
thermal destruction of the solid material, which constitutes the majority
of the waste in areas one and four, outweigh the increased cost (see
Recommended Alternative section).
4. No action was not selected since the site clearly poses a potential
threat to public health and the environment.
RECOMMENDED ALTERNATIVE
Rased on the factors discussed in the previous section, the recommended
alternative for this operable unit is the excavation of areas one and
four, and thermal destruction of all waste at a compliant RCRA off-site
incinerator. Although it is the most expensive remedy ($41.5 million),
it is also the most protective of public health and the environment. The
main sources of hazardous substance~ will be removed, and thermal destruction
significantly reduces the volume, toxicity, and mobility of the liquid
wastes. The volume, toxicity, and mObility of any inorganic solid wastes
will be reduced to a lesser degree. Thermal destruction of these wastes
will still leave a significant amount of ash for disposal, and most
heavy metals, if present in the waste, will remain in the ash. However,
high concentrations of heavy metals in the waste are not expected.
'I
The recommended alternative is both cost-effective and consistent with a
permanent remedy since the waste is being permanently removed from the
site. .It is also consistent with the Agency.s May 6, 1985 off-site
pOlicy (Memorandum from Jack W. McGraw, Acting Assistant Administrator).
In aodition, the recommended alternative will be easily engineered and
constrL:ted, and readily accepted by the public. In light of the above
-------
-12-
factors, and U.S. EPAls trend toward the selection of permanent remedies,
the additional cost of incinerating all of the waste for an anditional
$29.5 million, rather than incinerating only liquids, is justifierl.
It is estimated that 18,150 cubic yards of liquid and solid waste will be
incinerated, including 4,000 cubic yards from the staging areas. The
estimated total cost of this alternative is $41,500,000, assuming a 10%
inte~~st rate and 30 year project period (Table 10). For cost purposes,
the PF$ assumed that the nearest disposal facility (Chemical Waste Manage-
ment facility in Chicago, Illinois) would be available. The unit disposal
costs in Table 8 reflect this assumption.
n
COt1~1UNITY RELATIONS
The local community has been interested in the Metamora site since at
least the late 1970's. At that time, their concerns centered around
blowing trash, odor, and the height of the landfill. Local interest
heightened in the early 1980's when buried drums were found at Metamora,
. and the site was included on the National Priorities List. In March of
1984, six local residents met with the MDNR and Michigan Department of
Public Health to express their concerns regarding Metamora as a hazardous
waste site. The MDNR then established a Citizen's Information Committee
(CIC) to keep the affected public informed of project details. The CIC
has met regularly .during the course of the project. The meetings have
included discussions regarding the RI/FS and the PFS.
The PFS was published for public comment on August 4, 1986. On August
18, 1986 a public meeting was held to discuss the findings of the Phased
Feasibility Study and the recommended alternative. In general, public
concern centered around the acquisition of site access to perform the
operable unit (which has since been obtained), and the availability of
CERCLA funds to to implement the remedy (due to the lack of CERCLA reauthor-
ization. The public comment period ended on August 25, 1986. The attached
Responsiveness Summary details the comments received during the public
comment period.
,
OPERATION AND MAINTENANCE
The recommended alternative involves no operation and maintenance at the
site in order to implement the remedy and maintain the protection of
public health and the environment. The selected off-site disposal facilities
would be responsible for operation and maintenance of their own facilities,
and would be RCRA-regulated.
-------
.. '.., ~<. .. ..
... .
, "',,'o.,... .. '..,
~. ,,' ';,' ,';.;":"':1 :w:.....~~~.:-...,.I..~».:-: J.'l:..';..}:"":".~':!.:::';.\.';.:~':' .....''';':';.~.;. r~''':.,-.i.....l.':,;.-:J:;; j) ~:::'''':...;:;:'- ../...'; ~""--:":'~~," -'..;.";'",.:':":'1 ~', .. =..:., ''''~:.' . . ..:..; .'.:- :.'C....~"~"\ ;""",.;..:',".:...t....~ :...:,:,::.: .=-t'..~;., :.;. :I.:";';S,;\~.:..:-.:;:.:~,...
-13-
SCHEDULE
The following are the key milestones for implementation of the remedial
action.
',>
-Approve Remedial Action (sign ROD)
-Amend Cooperative Agreement for Design
and Construction
-Start Design
-Complete Design
-Start Construction
-Complete Construction (begin incineration)
09/15/86
10/15/86
10/31/86
03/31/86
11/01/87
05/31/88
FUTURE ACTIONS
This Record of Decision (ROD) recommends the selection of the excavation
of areas o~e and four with off-site thermal destruction. However. the
possibility exists that at the time of implementation of the selected
alternative. the cost of waste disposal will change the recommended
(cost-effective) alternative. If'such a situation arises. this ROD may
be amended.
In onjer to complete the site response. an RIfFS has been initiated to
study the potential impacts of contaminated soil. ground water. and other
media. Test pits in areas' one and four have been proposed in order to
better define the number. condition. and contents of buried drums. The
field work for the test pits is expected to begin in November or December
of 1986. The data from the test pits will be used duri ng the remedi al
design for this operable unit so that better cost estimates for the
project may be made. This will allow potential remedial action contractors
to submit more accurate bids for the construction of the operable unit.
The RI/FS. which will evaluate alternatives for final site remediation.
is scheduled for completion during the second quarter of FY 188. Another
Record of Decision package shall be prepared for any additional remedial
action recommended as a result of the RI/FS. or if test pit information
warrants re-evaluation of this Record of Decision.
-------
METAMORA LANDFILL PHASED FEASIBILITY STUDY
Responsiveness Summary
Introduction
A public comment period was in effect from August 4. 1986 until Au~ust 25.
1986 to provide for public review of a Phased Feasibility Study (PFS) for
the Metamora Landfill Superfund site. The PFS has been prepared to
evaluate existing information on the known and ~~Z~~~~~- -~yU~G. vf
drums of chemical wastes at the site and to determine if the drums pose a
more immediate threat to public health or the environment which should be
addressed prior to the completion of a full RI/FS. Copies of the Phased
Feasibility Study were. available for public review of the Metamora branch
of the Lapeer County Library. In addition. a Citizen's Information
Committee meeting and a public meeting were held during the public
comment period~ These meetings were conducted to give staff from the
Michigan Department of Natural Resources and the U.S. Environmental
Protection Agency the opportunity to explain to local residents and other
interested parties the PFS and its recommendations. and to answer questions
and receive comments.
Back~round
The Metamora Landfill is a closed municipa~ lau~~ill. approximately 80
acres in size. of which about 50 acres have been used for disposal of
both municipal and industrial chemical wastes. The site is located on
Dryden Road approximately a quarter-mile east of t~e Village of Metamora
in Lapeer County. This site currently appears on both the national
Priority List (~~L) for the federal Superfund program ane the state list
0.£ sites or environmental contamination promulgated under the Michigan
Environmental Response Act (Act 307 of 1982). Inclusion on these lists
makes this site eligible for federal and state funding to investigate the
nature and. extent of contamination at the site, to determine an effective
and appropriate method of resolving the contamination. ane to implement
the appropriate remedy.
A full-scale Remedial Investigation and Feasibility Study under provisions
of the Federal Superfund program, is just beginning at the site. The
. Michigan Department of Natural Resources. however. has conducted certain
investigatory activities at the site since 1981. Two large areas of
shallow drum disposal have been confirmed through magnetometer studies
and limited excavation of drums. Sampling of these drums revealed
various materials including solvents. C-58. toluene, ethyl benzene and
perchloroethylene. The excavated drums were in poor condition.
The MD~~., in the fall of 1985. commissioned its site contractor to
conduct a Phased Feasibility Study focusing on. the two known barrel
disposal areas. It was felt by staff that these areas posed the greatest
potential threat of on-going release of contaminants to th~ env~ronment.
particularly the groundwater. The purpose of the study was to determine.
i: cleanup or control measures should be implemented prior to the completion
0: the fu~l site investigation in order to minimiz~ further environmental
contamination and threat to public health.
-------
In August, J986, the DNR and U.S. EPA released tbe draft Phased Feasibilitv
Study. The draft Phased Feasibility Study evaluated five different.
clean-up options using criteria such as engineering constructability,
reliability, implementability, clean-up level achievable, and other
environmental impacts. The report includes the recommendation that the
drums buried in the two known disposal areas be excavated, removed from
the site, and that wastes be disposed of, as appropriate, through a
combination of properly constructed and licensed hazardous waste Jandfills
and incinerators~ The cost estimate for this work was $12 million.
A U.S. EPA policy decision which followed the release of the draft PFS
has caused a change in the cleanup alternative now being recommende~. In
an effort to move away from landfilling of wastes whenever possible, the
directive from U.S. EPA headquarters was to favor another alternative
evaluated in the PFS which involves incineration of all waste materials
rather than a combination of landfilling and incineration. The estimated
cost for this option is $41 million. This policy decision was received
prior to meetings MDNR and EPA staff held with the Citizen's Information
Committee and the public meeting held during the public comment period.
All commenters were aware of this modification in the report recommendations.
Comments and Responses
Written comments on the Phased Feasibility Study for the Metamora Landfill
were received from two parties: Sea Ray Boats, Inc. and Chrysler Corporation.
The commenters provided a large quantity of information to support two
primary contentions. These are:
1.
No imminent threat to public health or the environment exists.
,..
,
-.
Insufficient information exists to properly evaluate the specific
remed~al alternatives discussed in the PFS nor to support selection
of the alternative recommended.
Their conclusion offered in comment is that the decision to pursue the
partial cleanup recommended in the PFS is premature and should not be
\:.ndertaken.
Comment:
No imminent threat to public health or the environment exists.
Response: While complete investigation of the Metamora site needs to be
rione, a number of investigation efforts since 1980 have provided significant
information and understanding of the site. The magnetometer survey
conducted at the site identified five areas of significant magnetic
anomoly, indicating the presence of large quantities of buried metals.
Limited excavation-and sampling has been done in areas 1 and 4. These
areas do not appear to be in the area of refuse disposal so potential
interferences from othe~ sources is thought to be a remote possibility.
~
"
T~e limited excavation and sampling work performed in these areas found
no other items disposed except drums of chemical wast~. Samples collected
from thesE drums indicated a number of organic chemicals capable of
-------
migrating through soils to the groundwater. Drums encountered were in
varying states of integrity with some of them clearly having lost materials
to the surrounding environment.
Groundwater monitoring wells installed in 1985 have shown the presence of
some of these chemicals in the groundwater in concentrations which exceed
established federal criteria for carcinogenicity. Concentrations exceeding
these criteria have also been found in drum samples collected from these
areas.
Available evidence indicates that groundwater on the site is being
contaminated as a result of losses from the drum areas. Although complete
detailed definition of the nature and extent of contamination and the
environmental characteristics of the site is needed, and is proceeding
under the auspices of the remedial investigation, there is sufficient
evidence to believe that these drum areas have caused environmental
contamination and, if left alone, would continue to contaminate the
environment.
Residences near the site rely on groundwater for their water supply.
Wells near the site utilize the surficial, contaminated aquifer as well
as the bedrock aquifer in which contaminants have not yet been identified.
The continued loss of contaminants to the surficial aquifer presents a
future threat to some area water supplies.
Based on this information it is appropriate to eliminate the continuing
loss and prevent the development of a groundwater problem that will be
more significant, costly, and harder to control and clean up in the
future.
Comment: Insufficient information exists to properly evaluate the
specific remedial alternatives discussed in the PFS nor to support
selection of the alternative recommended.
Response: The waste characterization information used to evaluate the
remedial alternatives discussed in the PFS was based on a combination of
specific information already collected at the Metamora site and the
broader history of cleanup experiences of DNR and EPA at large disposal
sites. While the real cleanup cost to clean up the two drum areas may
show significant variation from the estimates presented in the PFS, cost
recovery actions are based on actual expenditures rather than estimates
developed during the planning process.
J
Commenters are correct in stating that additional information is needed
prior to the actual removal activity commencing. As discussed during the
public meeting on this report, a limited excavation and sampling activity
to provide such information is planned in these two areas for late fall
of 1986. In addition, further magnetometer work will be performed during
1986 to better define area #4. These efforts will provide information
necessary to determine the details of how to proceed with the excavation/
removal work in a safe and efficient manner. This work will also enhance
the quality of currently existing information. However, until a full
""'''''''':''''~'~ ~_. . ..". "",' .~..,. ~ "'.~'\' -'.....", ,"."'} ~-~" -,.' ~. !'o'J: 'I" ". ."..~~,,,~,,,:,,...,,,)..."';.. -t~-."""""'-:.r'~. .1''''J, ~ n."~''''''~'''''-~''r-.t.:....~~..~.-.::'1''f:-''''''''~~'':I~I'I;.~~~'..:ror''1''''':r~~'''.~tr'".:n':t.".":..."<-r~J.J'!'\~..'~n.~::r~":':1~7"II.."""".i'~/1'I':".j": ~'~-,"~!"''','
-------
excavation is completed, any waste characterization effort will be
subject to question Bnd will generate estimated costs which will likely
be erroneous.
u.s. EPA has recently established cleanup policies which further directed
the selection of remedial alternatives. These policies encourage destruction.
detoxification and volume reduction of cleanup wastes. Elimination of
land disposal approaches to waste management is directed. Given this
policy, the only viable alternatives involve total incineration of the
excavated wastes. As discussed in the PFS report, consideration of an
on-site incinerator was not thought to be viable, leaving off-site
incineration as the only viable remedial response.
The remaining comments and questions were voiced at the two meetings that
were held in the community during the public comment period. Some of the
comments and questions do not directly relate to the PFS or the cleanup
recommendations.
Comment: Because of abnormalities in laboratory results of tests on
nearby drinking water wells, not enough follow-up sampling of homes and
areas in question is being done.
Response: The Lapeer County Health Department and the Michigan Department
of Public Health are jointly conducting a series of tests of private
domestic wells around the landfill site. In two subsequent rounds of
sampling, trace levels of certain organics appeared in some of the
samples. Follow-up sampling of the wells in question and others in the
area revealed that these trace levels were not found in any locational
pattern, and subsequent sampling never duplicated a finding of the same
organic in the same well. Trace levels were also detected in field
blanks. Because of these factors, it was determined by the county and
state health departments that the trace levels found were due to contami-
nation of the original laboratory bottles rather than any real contamination
of local wells. It is felt that the follow-up sampling that has been
done is sufficient to show these wells to be free of contaminants. The
Lapeer County Health Department and Michigan Department of Public Health
will continue a cooperative well sampling program which involves sampling
of selected area wells on a semi-annual basis and other wells on an
annual basis.
Comment: The barrel staging areas shown on the site map should be
relocated to spots where air emissions to surrounding areas would be
minimized.
Q
Response: The location of barrel staging areas shown on the map are only
general approximateions. The commenter is correct that staging areas
should be designed and located so as to minimize air emissions or other
potential release of contaminants to the environment. An important
consideration is minimizing the distance between excavation area and
staging area, since loss of materials is most likely during excavation
and transport. Staging areas will be located with these factors in mind.
"
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Comment: Since obtaining site acc~~s seems to be such a long process,
why don't you start now to seek a site access agreement for the drum
excavation?
(,
Response: Obtaining site access can be , time-consuming process and one
that is essential befo.re any particular actions can be taken at a site.
Site access agreements generally cannot be negotiated until the proposed
actions are well defined. In other words, a "generic" access agreement
to cover any and all s:tt.. wo:'C'1c i~ T'ot u-II~'ly possible. The MDNR will
begin negotiating an access agreement with the site owner as soon as
possible, as the scope of work for the actual excavation takes shap~.
'"
Comment: There is concern that Mr. Parrish. the site owner, is still
"messing around" in the landfill site, possibly hauling more materials
(particularly rubble) to the site.
Resnonse: While the owner, still operates a licensed transfer station at
the site, any further disposal of wastes at or in the landfill would be
illegal. Neither MDNR or EPA staff have seen evidence that further
disposal has taken place at-the site over the past couple years. Local
residents who suspect any illegal activity are asked to bring any evidence
of such activity to the attention of MDNR as quickly as possible.
Question: Why hasn't more really been accomplished at the landfill site
since 1981?
Response: Funding 1s a primary constraint in taking action at sites such
as Metamora Landfill. Until the early 1980's, there was no state or
federal program in existence to deal with such circumstances. In late
1984, state funds under the Michigan Environmental Response Act (Act 307,
P.A. 1982) were allocated for some preliminary hydrogeological investigations
and this work has taken place. Funding under the Federal Superfund
program for comprehensive site investigations became available in summer
1985. After resolving contracting issues and site access issues, this
full-scale Remedial Investigation/Feasibility Study is about to proceed.
The preliminary hydrogeological investigation has helped to justify the
drum removal action proposed by the Phased Feasibility Study. Funding to
implement this excavation is again the issue as the U.S. Congress debates
reauthorization of the Superfund progr~.. The drum removal is not likely
to proceed until funding is available through a reauthorized Superfund
program.
v
Ouestion: What safety precautions will be taken during drum excavation?
15 there any possibility of evacuating nearby residents as was aone at
Berlin and Farro?
Resnonse: Safety precautions, both for workers and nearby reside~ts, are
important considerations prior to implementing waste excavations such as
proposed at this site.' There is the potential for the release of air
emissions, an~, depending on the types of materials present, the potential
for fire ana explosion. There are many precautionary measures that can
be employed to reduce these risks. ~irst, both test pitting operations
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-------
Comment:
-------
Additional on-site remedial actions should ~ave been considered.
Response: The on-site incineration alternative was screened out early in
the Phased Feasibility Study (PFS) process for the reasons stated in the
Summary of Remedial Alternative Selection discussion. However, after the
PFS had been published for public comment, additional information
regarding the cost of on-site incineration became available. Specifically,
the Spiegelberg, Michigan PFS estimated that the on-site incineration
alternative would cost more than off-site incineration for that project.
Using the methodo.ogy for the Spiegelberg site, a cost estimate of both
on- and off-site incineration for the Metamora Landfill project was made.
This analysis showed that on-site incineration at Metamora may be more
expensive to implement than off-site incineration. The estimates are not
necessarily within the +50/-30 % range developed for the alternatives
retained for detailed screening in the PFS, but the estimate provides
additional justification for not examining on-site incineration in detail.
Furthermore, the concerns regarding the time to implement the on-site
alternative are still valid. Nevertheless, the Region has decided to
examine the on-site incineration alternative to the same level of detail
(+50/-30 % cost accuracy) as the PFS alternatives retained for detailed
screening in order to ensure the accuracy of the above-mentioned cost
estimate. The revised cost estimate will be done during the remedial
design phase of the project.
~
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STATE O~ MIC~!GAN
"'ATUAAL RESOURCES COMMISSION
T"'O~AS J ANOEASOllo
~,"':;~ENE J FLUHARTY
'ROON E GUYER
""'I' KAMMER
STEWART MVERS
OAVIO 0 OLSON
RAYMONO POUPORE
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JAMES J. BLANCHARD. Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS 1 MASON BUILOING
BOX 30028
LANSING. 11.11 '8909
~oacJQi*~
Gordon E. Guyer. Director
August 18. J Q~n
\)
Mr. John Tanaka
U.S. EPA - Region V
230 South Dearborn
Chicago. Illinois
60604
Dear John:
Per our telephone discussion of August 13. 1986. this letter is to'
provide a detailed explanation of the complexities and legal problems
associated with the construction permit/operating license requirements of
the State's Hazardous Waste Management Act, 1979. P.A. 64. as amended and
the administrative rules promulgated thereunder (henceforth Act 64)..
Act 64 establishes a two tiered permit program for the establishment of
new treatment. storage and disposal facilities (TSDF's). The technical
requirements are similar to those under RCRA but the permit system is
very different and more involved. Act 64 requires a construction permit
for the construction of new TSD's and subsequently an operating license
prior to commencement of facility operations.
..
Construction permits under Act 64 are issued by the Director of the DNR
as direc~ed solely by the decision of a Site Review Board as constituted
under Act 64. Act 64 Sections 17-20 describe the Site Review Board
structure, responsibilities and time lines. The Site Review Board is a
nine member panel consisting of the directors of three state agencies
(D~~. State Police and Public Health), two independent academicians (one
geologist and one chemical engineer) and four temporary members appointed
to serve on individual boards as follows: two from the municipality where
the facility is proposed to be located and tWo from the county (one of
which lives in the municipality) where the facility is proposed to be
located. This structure means that four votes are local and normally
opposed to siting the facility. Since five votes are needed to approve
~ construction permit, denial is almost assured by struccure alone.
J
IAe Board is permitted to review a construction permit application for
any and all matters of .concern to the community and is permit~ed to add
stipulations to construction permits to address these concerns. Histori-.
cally, these additions have been lengthy. involved and expensive even on
permits eventually denied by the board. In addition. many of the stipu-
lations established by these Boards have involved both technical and
R102e
lISE ":;~,€::'"~L:
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!-I.r. Tanaka
August 18, ]986
Page 2
non-technical factors such as limiting hours and days of operation,
landscaping, training and alarms for local communities, etc.
The Board is also charged with evaluating the consistency of new propos-
als with the State Hazardous Waste Management Plan as adopted by the
Hazardous Waste ~fanagement Planning Committee and the Natural Resources
Commission. Hence, any facility which they feel does not adequately
resolve concerns relating to technical, social, aesthetic, environmental
or Management Plan considerations ~ey ~p ~~~~P~. ~ ~ DNR hes no ~iscre-
tion in carrying out decisions of this board.
n
'.L'h~ process proceeds as follows:
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Mr. TanakCl
August 18, 19R6
Page 3
v
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"
2.
- the proper feed rates, treatment techniques, operating
conditions
- whether the chemicals, etc. will have any detrimental
effects on the materials used to construct the facility
and if so, the method for controlling the effect.
- whether the hazardous waste contains any constituents or
contaminants which might interfere with the intended
treatment process (incineration) or decreases its effec-
:iveness ane jf ~~ ~~~ ~~el' ~fec~s will hp controlled.
J,
A complete application form signed by the facility operator and
the owner of title in fee simple of the property where the
facility is proposed.
The DNR-Hazardous Waste Division reviews the application to deter-
mine if it is administratively complete. If not, no further review
occurs. If so, internal technical review begins.
Within 120 days of receiving a complete application, the Director of
DNR must either deny the application or recommend its approval. If
denied, no further action occurs until a resubmittal is made. If
recommended for approval the application is referred to the Site
Review Board for review. They have 120 days to recommend approval
or denial of the application. They have at times, however, exceeded
,this timetable at their discretion. As pointed out earlier, the
board may add requirements onto the facility as part of its deliber-
ations. The Board then recommends approval or denial to the DNR
Director who is bound by their decision.
3.
4.
Following issuance of a construction permit, the facility may be
constructed. No operation may begin until a subsequent operating
license is obtained from the DNR Director. A separate application
is required which contains:
A.
All the information required in the construction permit
application
B.
Revisions to the closure/post-closure cost estimate and plans
c.
A certification of the facility's capability to operate as
planned (sealed by 'an RPE)
t.
Proof of financial capability (closure/post closure financial
assurance and liability insurance)
.
-.
Proof of issuance of all other necessary environmental permits
....
.
~ .
A license fee
~
\.:S,
A signed application form similar to the construction permit
application
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Mr. Tanaka
August 18, 1986
Page 4
s.
The Department determines if the application is complete
returns it without technical review. If it is complete,
140 days to review the application and either deny it or
operating license.
and if not,
the DNR has
issue the
It is important to note that specific waste information is required to
support these applications. Because of the 90 day storage limitations of
RCRA and Act 64, excavation of the waste to develop highly detailed
information is not t'c.!.z~~:~ ,'. !.., ~L... .:>peration it ready to begin.
Hence, if after construction based on test pitting, we begin excavation
and find additional waste types or characteristics, we have to go through
the process again for the additional wastes and develop additional
technical information. It is also possible as a result of such an event
that we may find some of the wastes not ameanable to incineration in the
incinerator as constructed requiring either an additional incinerator or
off-site management of those wastes.
~
"
There are several issues to take particular note of in this process.
The requirements that the title owner of the property be a party to the
permit and license applications requires that some form of legal rela-
tionship be established between the operator agency (DNR) and the title
holder of the property (Mr. Russel Parrish.) Since Mr. Parrish is also a
~RP for this site this means establishing a relationship with a PRP which
our attorneys are unlikely to permit. This will likely mean that no
application could ever be submitted.
Also of interest, the financial requirements of the act for closure and
liability insurance must be complied with. It is unclear in the current
liability market that liability insurance is obtainable and many legal as
well as cost problems are associated with the allowed closure financial
mechanisms.
Some historical perspective on the site review board may also be useful
to you. This board has been convened to review five construction permit
applications since 1979. Two have been approved. However, those were
captive facilities proposed at the outset of the program. Only one of
them has ever been placed in operation, that being the Dow Chemical
Company Salzburg Road landfill. Being in Midland with several local
~embers on the board, this case may not be representative. The other
facility approved was a small captive one waste stream incinerator which
,;'as never constructed. Local awareness of this proposal was low and
little controversy resulted.
z
Sases which have been before the board process and denied include: The
3tablex Corporation waste trearment facility, the ERES Corporation
incinerator complex and the Environmental Management Systems Landfill
~ite. These cases involved ,lengthy deliberation and board imposed
2odifications or. the permits prior to ultimately denying each for a
variety of reasons, many of which were non-technical in nature. Each of
',~hese denials has been challenged in the courts although none of them
have been resolved. However, it became clear that obtaining a construc-
~ion permit through this mechanism was nearly impossible and no one has
actually submitted a complete application to attempt to secure such a
~
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