United States
Environmental ProtllClion
Agency
0Iflce of
Emergenc:y and
Remedial Response
EPAIROO/R05-87/051
September 1987
3EPA
Superfund
Record of Decision:
Liquid Disposal, MI
U.S. EnvironmentiJi Protectioi'l Agenc~.
Region III Information ResourCQ.
Center (3PM52) ~. ,/ .:
841 Chestnut Street v. ...~'...,-a~
Philadelphia, fA 19101 .iiE.:~~ .
Hazardous Waste Collection
InforrpationReaource.Center
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
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-------
"'
TECHNICAL REPORT DATA
(",.,. ,. 1",auc,ioIu 011 the ,..me be/tift comp/.ttIt8J
1. "'PORT HO. 12. ~. "ICI~IIHT"S ACCISSION NO.
EPA/RO~/R05-87/05l
.. TIT'" AHD SU8TIT", I. "I~O"T OAT I
SUPERFUND RECORD OF DECISION ~eDtember 30. 1987
Liquid Disposal, MI 8. ~I"'OAMIHG OAGANIZATIOH COOl
First Remedial Action - Final
7. AUTHD..car .. 'IA'OAMING OAGANIZATION AE'OAT NO.
18. ~'A'O"MIHG OAGANIZATION NAM' AHD AOOAISS 10. 'AOGRAM 1L.IiMINT Ng.
11. CONTRA", rtQ..AN Ng.
12. SPONSORIHG AGIHCV NAM' AHD ADDAISS 1~. Tv~e 0' AIPOAT AND ,eAIOO COVIAIC
U.S. Environmental protection Agency P;nal ROD ReDort
401 M Street, S.W. ,.. S~OHSOAIHG AGINCV COOl
washington, D.C. 20460 800/00
,.. SU....IMIHTAAV NOTI.
, ACT
Liquid Disposal, Inc. (LDI) is a 6.8-acre site located in a residential/light
industrial area in Shelby Township, Michigan. LDI is bordered by the Clinton River and
its flood plain, the Shadbush Tract Native Study Area and automobile junkyards. The
site was first used as a source of sand .and.gravel prior to becoming a landfill around
1964. Between.. 1968 and 1982, LDI operated as a commercial incinerator of liquid waste.
During this time, the site contained a large volume of hazardous substances stored in
the waste oil and scrubber lagoons, ash sludge piles, above and below ground storage
tanks and in 55-gallon drums. Since 1982, EPA has completed four immediate removal
actions. As a result of these actions, no surface waste sources exist at the site.
However, several hundred waste sample jars, old incinerator parts, emptied tanks, woode
pallets, miscellaneous containers and other debris remain onsite. Currently, on and
offsite soil and ground water (the upper aquifer) are contaminated with a wide variety
of organic and inorganic chemicals. Onsite concentrations are generally higher than
offsite. The primary contaminants of concern include: VOCs, semi-volatile organics,
PCBs, barium, cadmium and lead.
The selected remedial action for this site includes: onsite land disposal of all
existing debris and equipment; onsite solidification/fixation of soil and waste: ground
water pump and treatment using air stripping and ion exchange with discharge' to Clinton
. (~"u" ~ - ~h......t- \
7. KIV WORDS AHD DOCUMINT AHA I. vals
L DUCR'I'TOA. b.IDINT"I'ASlO~IN INDID TEAMS c. COSA TI FieldlClOup
Record of Decision
. Liquid Disposal, MI
First Remedial Action - Final
Contaminated Media: soil, gw
Key contaminants: VOCs, semi-volatile
organics, PCBs, barium, cadmium, lead
1L DISTAlaUTIOH STATIMINT 'e. SICUAITY CIoASS (ThU R.portl 21. NO. 0.. PAGIS
None 63
20. SICUAIT\' CIoASS (Thu pqel 22. PAlce
None
.,. ,- mo-1 (I... .-77)
"...VIOUS .OITIO.. IS O.SO".T.
-~~ ~\ ,:!..~:,:.~ :..;:~~~~:};:~~~i=.]::'l.,;7;"J~~:::.~::;'::;~~-~~.~.(;:i!~;.~~:::~;~~~j~;::lit:.~.~;-~'i.:;'€![..-:-::;~;.:.~;::~;:;~~.t.:::;:l':.~i..~.::;"":7.;;:-'.~.~~S~'.'~::,:":;:~...~~~~~~:~~~~..~-;..~(~!.~~~~;.!~;;:~';:';-'t:,:-:.~:;~.;.~.:~~..~~';~~-~...
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INSTRUCTIONS
1.
RIPORT NUI8IR
Insal 'he ~PA nparl number u it Ipparl on die cower of I'" publk:alion.
UAVI..ANIe
RICIPIINTS ACCISIIOlit NUM8lR
R......t for 11M '" r.u:h npan m:ipilnl.
TlTLI AND aueTITl.I
Tide shouid indica Ie o:leuly and brieny Ihe subj«1 o:ovcr.a~ I)l'lIw n:porl. ;lnd be lIi~I,l;ay",1I prumin",ntly. ~'.uhlill"" I"II~II. m ~n';lI~r
type or olherwia subordinale illO main lille. When a reporl il prepared in mon than ".... VUIURW, r"'p~.al 'II'-' prill"''' ..t"", ;11111 V.,III"""
number lAd iadIacIe sublide for 1118 specific lille,
2.
3.
..
I.
RIPORT DATI ,
Each repart shall carry 1 dal8 inclicatinl It lasl monlh and yeu. Indk:alc ttlc h;a.' Ihu p'upc' ;lulh..,.,,,,11 I",rrll~ Ih;&t III.:nll"y ,h", m;&,..,
concept or Ih. research and are sumctendy spet:d1c and prel:ist: 10 be I&SI.-II ;I!> Inllu unlftel "ur ~"C;ilut:'"tI.
'(b) IDENTlnERS AND OPEN.ENDED TERMS. Ua idenliflen for project n;all1\', o:udc nam.:... O:'Iulpl1hlnll.l':"lInillun, 0:1.:. l.iw"I"""'
ended terms wriuen in descriptor form for 111- slIbjecU for which no ck.."ICriplor I/),ists. ,
H
(c) COSA n I'IELD CROUP. field and poup assipments... 10 be tlkl:n !'rom lhe 1965 ('051\ II Suhj\:<;t ('OIt"'"u'y lill. Sin",.. Ihe ma.
jority of documents an multidisciplinary in RlIUR, the PriIllll7 "ield/Group ;as...ipllnenU\' will III: '1"",.111: lIi"""I'hn"" ;1m n" hum;an
endea¥Or, or IYpe or physical object. The applicalioa.sJ wiD be CIOIWCIi:n:nc:ed with ",-,,'unlJary I j",III'( ;ruul' ;I"ltI"III"'lIh Ih;at ",.11 "IIUII"
the primary poSlinICSJ.
18. DISTRIBUTION STATEMINT
Denol. releasabilil)' 10 the publie or limilinon for rea...ons other lhan wl:urily fur ""ample "R.:I",OI'\: 1:IIIIIIIII",d:' ('..", ;III!, .I~;&iJ;&'IIIII)' 'It
1118 public. wilh address ;and pnl:e.
c.)
1...2G. SECURITY CLASSIFICATION
DO NOT submil classifted reports 10 Ihe Nalional TCl:hnicallnforrnatiun !iII",M:C.
21. NUMBER OF PAGIS
lnan lhe tolll number or paps, includinl this one lAd unnumbered pap", bUI ul:ludt: di\lrlbUliun lI\t, I' ;any.
2Z. ,..ICI
Inan Ihe price III '" lhe Nalional fechnica1lnformalion So:ml:e ur lilt: Coyemmenl Printinr 01'01:11. iJ knuwn.
I'A ,- 2220-1 (R... 4-m (R._..)
, ,
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EPA/ROD/R05-87/05l
Liquid Disposal, MI
First Remedial Action - Final
16.
ABSTRACT (continued)
River: and construction of a slurry wall and impermeable cap containment
system. The estimated capital cost of this remedial action is $21,743,100
with present worth O&M of $316,600.
o
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE NAME AND LOCATION
Liquid Disposal, Inc. (LDI), Utica, Michigan
PURPOSE
..
This decision document represents the selected remedial action for the
LDI site in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act as amended by the Superfund Amendments
and Reauthorization Act, the National Contingency Plan, 40 CFR Part 300,
and Agency 9uidance.
BASfS
The attached index identifies the items which comprise the administrative
record for the LD! site. The administrative record includes the documents
upon which the selection of this remedial action 1s based.
DESCRIPTION OF SELECTED REMEDY
The recommended remedy for the LDI site is to dispose of all existing
debris and equipment on-site, treat soil/waste using solidification/fixation
technology, and treat ground water using air stripping and ion exchange
technology. In addition, a slurry wall with an impermeable cap will be
constructed. The estimated present worth cost of the alternative is
$22,400,870. Treatment of the soil/waste is expected to take about one
year. Ground water remediation is estimated to last three years on-site,
and nine years off-site.
The recommended remedy requires periodic operation and maintenance to
maintain its effectiveness. The attached Summary of RI~medial Alternative
Selection explains in detail the selected alternative, and the tasks
associated with the selected alternative.
...~.
-------
DECLARATION
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant
and appropriate, and is cost-effective. This remedy satisfies the preference
for treatment that reduces toxicity, mobility, or volume as'a principal
element. Finally, it is determined that this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent
practicable.
9-3D - <69-
.OM
Date
Adamkus
,..,.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
LIQUID DISPOSAL, INC.
UTICA, MICHIGAN
SITE LOCATION
liquid Disposal, Inc. (LOr) is located about 20 miles north of Detroit,
on Ryan Road, City of Utica, Shelby Township, Michigan, in a residentia1/
light industrial area. The 6.8 acre site is bordered by the Clinton
River and its floodplain to the north, the Shadbush Tract Nature Study
Area to the east, and automobile junkyards to the south and west (Figure 1).
SITE HISTORY
The site area was first used as a source of sand and gra~e1 prior to
becomi ng a 1 andfi 11 around 1964. LOI operated frOM appr9x imate1y January
1968 to January 1982 as a commercial incinerator. of. 1 iquid waste. The
major site features included a high temp~rature incinerator, a waste
liquid lagoon, a scrubber water lagoon: aAd nUMerous above and below
ground storage tanks (Figure 2 and.Tables 1 a.nd 2). LDI was permanently
closed in January 1982 after two workers. were killed in an industrial
accident. Just prior to the accident, the site contained a large volume
of hazardous substances stored in the waste oi 1 1 agoon, above and below
ground storage tanks, and 55-gallon drums. In addition, the scrubber
lagoon and aSh sludge piles contained hazardous waste. Since LOI was
closed, U.S. EPA has completed four immediate removal actions:
..
1. May - June 1982 - A PCB-contaminated oil spill from the waste liquid
lagoon occurred. The spill traveled along a small creek which fed into
the Clinton River. About 200 gallons of oil and 750 cubic yards of
contaminated sediment and debris were recovered.
2. July - August 1982 - Site safety and security were improved, and
action was taken to abate liquid losses from the overflowing waste liquid
and scrubber lagoons. A leachate collection system was constructed to
prevent scrubber lagoon leachate from migrating off-site.
3. April 1983 - April 1984 - An extensive surface cleanup was undertaken.
The waste liquid and scrubber lagoons were drained, capped, and' seeded,
and all drums were removed for off-site disposal. Approximately 1.3
. million gallons of liquid, 15,000 cubic yards of solids,.and 1800 drums
were removed from the site.
4. July 1985 - April 1986 - Flammable liquids and sludges in 22 above
ground and 8 below ground tanks were incinerated off-site, and the leachate
collection system installed during the July 1982 removal action was repaired.
-------
- 2 -
As a result of the four removal actions, there are no longer any surface
waste sources at the site. However, several hundred waste sample jars
are currently stored in the existing office building. These jars are
samples of waste submitted to LDI by various generators in order to get
approval for incineration. Some parts of the old incinerators are still
on site. The tanks that were emptied and removed during the fourth
removal action are currently located in the southwest corner of the site.
Also, a number of wooden pallets, miscellaneous containers, and other
debris remains on-site.
In September 1983, the Michigan Department of Natural Resources (MDNR),
through a cooperative agreement with U.S. EPA, initiated a Remedial
Investigation and Feasibility Study (RI/FS) at LDI. The purpose of the
RI/FS was to define the sources and extent of on- and off-site contamina-
tion, establish the human health and/or environmental risks posea by the
site, and ident;Jy required remedial action (final remedial action). The
final RI report was ,completed in May 1987.
0'
In general, the RI concluded that on- and off-site_soil and ground water
in the upper aquifer is contaminated with a wide variety of organic and
inorganic chemicals. On-site concentrat1QnS a~e generally higher than
off-site. There are no current users of ground water downgradient of the
site. . ,
'.9.
The RI report stated that insufficient: evidence was currently available
. to fully evaluate the effect of LDI on the bedrock aquifer. The bedrock
aquifer has likely ~een unaffected by contaminants leaching from surface
waste sources. However, chemical data collected during the RI had anomalous
results. Also, the public has stated its concern regarding the possibility
of past injection of hazardous substances from the LDI production well
into the bedrock aquifer. Three potential sources of bedrock aquifer
contamination were discussed in the RI Report: 1) injection into the
production well; 2) contaminants from the surface reaching the bedrock
aquifer via a poorly sealed production well; and 3) natural causes. Such
occurrences could explain the anomalous RI data. An analysis of these
possible causes of bedrock aquifer contamination is presented in the
following text.
Hydrogeology - Drilling logs and personal observations by field personnel
established that the upper (surficial) aquifer was underlain by an extremely
impermeable silt/clay layer that ranged between 90-136 feet in thickness.
During bedrock monitoring well drilling, this layer was observed to be dry
. between about 40 and 70 feet at downgradient boring number 10. Therefore,
there was strong evidence that surficial contaminants did not reach the
bedrock aquifer.
Bedrock Aquifer Contaminants -
Four monitoring wells were screened in
..
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TABLE .1
INVENTORY OF TANKS AND ONSIT£ CONTAINERS AT LDI (1982)
(See F 19ure Z. )
Total Ez1at1ng
T a.nk Capac1ty Quantity D1rection of Secondary
Number Material (gallona) (gallons) Flow Containment
1 Unknown 50,000 48,063 Underground Underground
2 UnknOlln 20,000 20,000 Unde rground Underground
3 Unknown 20,000 10,040 Unde rground Underground
4 UnknOlln 20,000 14,100 Underground Underground
5 Unknown 20,000 8,824 (2 ft aolids) Unde rground
6 Unknown 20,000 20,000 (3 tt solids)' Underground
7 Unknown 20,000 18,731 (3 tt solids) Underground
8 UnknOlln ' 20,000 19,443 (8 tt soUda) Underground
9 Unknown 17,300 2,422 Ior.tb Earthen Dike
10 Unknown 17,300 10,795 Kortb Earthen Dike
11 Unknown 17,300 17,000 North Earthen Dike
12 PCB 011s 17,300 .11,000 North Earthen Dike
13 Removed by Owner, 6,500 0' North None
Waste-01l Sludge
14 Removed by Owner, 8,000. .' ° East None
..
soUda . .'
15 Reaoved by Owner, 6,500 0 !ut P10ll intercepted
vaatewater b7 incinerator pit
16 Removed by Owner, 8,000 ° East None
oil-water
17 Empty 10,000 0 North Flow intercepted
by incinerator pit
18 Sol1ds 10,000 10,000 East Flow intercepted
by incinerator pit
19 Empty 10,000 ° East Flow intercepted
by incinerator pit
20 Empty 500 0 Horthesat Flow intercepted
by incinerator pit
21 SoUds 5,000 1,250 North Earthen Dike
22 Empty 3,000 0 !forth Eartben Dike
23 Empty 1,000 0 Hortb Earthen Dike
24 Empty 500 0 North Earthen Dike
25 Empty 500 0 North Earthen Dike
26 Fuel-gasoline 500 0 North Hone
27 D1eael-tuel 250 0 Hortheeat None
. 28 Removed-GnknOlln 2,100 O' Northeast Flow 1nterception
oil/pa1nt by 1ncinerator pit
29 UnknOllnOl1 560 560 Southeut Screenhouse sump
30 SoUds 10,000 2000 None Incinerator pit
Total Volume: 342,100 220,228
Source:
Jo1nt Mich1gan Department ot Natural Resources, U.S. EaY1roa8edtal
Protect1on 1sency, L1quid D1poaal, Inc. Site Inventory, October 15, 1982.
-..-..... ..-.-.....-....-...,.......
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TABLE ~
INVENTORY OF WASTE DRUHS AND MISCELLANEOUS
CON7AINERS AT LDI (1962)
(Set8 Fieur. Z. )
Site
Area
Container
Type
Haterial
Numbe r of
Containers
Estllll8ted Total
Quantity (gall(
A
200 gal tUlk
area at ub pl1e
B
30 pl. cans/f1ber
drwu of vater-
reactive materials
C 3,000 gal. unloading
pi t 1n tront or lab
D Staged druma
E Staged druma
F Staged drUIDs
G Staged d ruma
H Staged drUIDs
I St.ageeS acid druma
J Dr'WIIS
It StageeS drUIDs
L D r'UIIIS
H 1 gal. aaetal cans
II Ash P1le
0 Ash P1le
P Bottles & jars
Q Druma
R Bottles & jars
S Waste lagoon
T Incinerator pit
U Scrubb8 r 18&0011
V Waste stabilizat10n ponds
V Crude leachate collect10n
system
X Leachate III&I1hole
y 4-1nch production vell
Source:
011s, 8011ds
Chrom1c aC1d,
(aluminU8-tr1-chloride)
1 overpack
Unknown ...page
Isocyanate solids
Isocyanate solida
Empty
Unknown liQu1ds
Pain t
Unknown liQ~ida
PCB vastes'
UIIkD~
UnknCNn
Waate toluene, acetone
ketone
Barrels, so11ds, fly ash
Barrela, solida, fly ash
Hisc. lab vast.es
Oily l1Quid
S&IIples/lab vaste8
Water/oil sludge
Runoff-
Water/011 metallic
alUd ge
Sludge from acrubber lagoon?
23
50 Jars
73 _tal drWDa
55 gal. drums
12 fiber drums
944
263
80 ;
.-
55 -
96
154
22
5
5
15
50
12
100
Joint. Michigan Departll8nt of lIIItural R..OUJ"O", U.S. Ezw1roll88Dtal
Protection Agency, Liquid Disposal, Inc. Site Inventory, October 15, 1982.
v through Y not on original site inventory.
... ._~ --. .- _.~.~ ._~. - - . .-. .~. ~-- .---- ~. .---. ...,.-.' h -., '-'---.--' .,"-. ~~-:- . . -
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- _..- . . -
5,060
3,120
Varies
49,500
, 16,500
3,025
14,850
1,650
1,100 :
~
250
275
20
864 cubic yards
588 cubic yards
20
660
660
8Ji9,OGO cubic yards
sl udge q
5,000
16,000 cubic yards 0
2,200 cubic yards
'-"...-,',-. .,....., .''''~; ,'; .....:.,..- '.""""",,,,,-,,..-";:.~'.... ''':''''..',-- ,.",,--.'.' '~~",....'.'....." ':.. """""'~'.-
.........: -.-'. .~,""... ",' ,
-------
- 3 -
the bedrock aquifer and available for sampling. These were labeled 10.
20, 3D, and the old LOI production well used for incinerator process
water. Well 20, the upgradient well, showed the lowest level of inorganic
contaminants. Wells 10, 3D, and the production well, which are down gradient ,
showed significantly higher levels of inorganic chemicals, particularly
chlorides, sodium, and other minerals. However, highly mineralized ground
water in the bedrock aquifer is common in Shelby Township.
One possible explanation for the high levels of downgradient contaminants
is injection of contaminants (such as from the old scrubber lagoon) into
the production well. It is not known whether this actually occurred. If
injection did occur, the contaminants may have traveled further than 50
feet (which would be the calculated distance traveled according to ground
water flow velocity given in the RI report) due to potential mounding of
the injected fluid.
Another theory presented in the RI Report was that contaminants ~ay have
flowed by gravity from the surface along the production well casing.
This assumes that the casing was poorly sealed. If this happened,
contaminants probably would not have reached monitoring-wells 10 or 3D
due to the slow ground water flow velocity in.the ~edrock aquifer.
Finally, it was possible that the data were merely indicative of natural
conditions in the bedrock aquifer. The RI report discussed a possible
natural geologic source of brine frbm,shale layers above and below the
bedrock. . ... .
..
-. .
Since there is strong evidence that surficial contaminants have little or
no chance of migrating through the impermeable, thick silt/clay layer,
and no concrete evidence of injection into the bedrock aquifer is available,
this Record of Decision only addresses the upper aquifer contamination.
It is considered a final remedy, but in order to respond to public concerns
and definitively characterize the aquifer, confirmation sampling will be
performed during remedial design as part of this remedy.
U.S. EPA also evaluated whether confirmation sampling for dioxin contamination
would be necessary during the remedial design phase of the project. During
the RI, MDNR collected 5 surface soil samples for dioxin analysis. Dioxin was
undetected in all but one sample, in which the concentrations detected were
at levels which the RI Report concluded were not significant. Also, U.S. EPA
believes that solidification treatment will be acceptable for treatment of
dioxin. Thus, no additional confirmatory sampling is needed.
ENFORCEMENT
. .
U.S. EPA has identified approximately 850 potentially responsible parties
(PRPs) for the LOI site. The major source of information used to formulate
the PRP list was business records recovered from the old LDI office
building. Notice Letters pursuant to the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) were first sent to the
facility president, vice president, and bankruptcy trustee offering them
the opportunity to perform the RI/FS. Notice Letters and CERCLA Section
104(e) information requests have since been sent to all known PRPs. U.S.
EPAls National Enforcement Investigation Center (NEIC) has compiled the.
documents received from the information requests along with the site
records. All records were arranged in individual generator folders and
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- 4 -
microfilmed. NEIC also prepared a draft transactional data base (TDB)
from these records. The TDB shows each generator's individual transaction
(waste shipment), the volume, cost, and major waste type sent for that
shipment. A separate report shows the total waste volume contributed,
and the relative and cumulative percent of waste shipped by each generator.
A PRP Steering Committee has been established, and is very active in the
enforcement process. U.S. EPA has held extensive discussions with the
PRP Steeri ng Committee and has provided them wi th the TDB and other
techn'ical information as requested.
On August 21, 1987, Special Notice Letters pursuant to Section 122(e) of
the Superfund Amendments and Reauthorization Act (SARA) of 1986 were sent
to all PRPs. The deadline for receipt of a "good faith offer" to conduct
the remedial design and remedial action is October 26, 1987. U.S. EPA is
currently negotiating with PRPs for them to conduct the remedial tlesign
and remedial acti~n discussed in this Summary of Remedial Alternative
Selec~ion and the Record of Decision. : w
COMr-tJNITY RELATIONS HISTORY
During the active life of the facility, 'numerous complaints were made by
local residents regarding odors, noi~e, off-site discharges, and general
dissatisfaction with the incinerator operation. MDNR established a
Citizens Information Committee during t,he 'Ri/FS to disseminate pertinent
project information and r,eports to the affected community and elected
officials. Public meetings have been held at regular intervals during
the RIfFS. A public meeting was held on August 27, 1987 to discuss the
public comment draft FS. The public comment period was originally
established between August 19 and September 9, 1987. On September 2,
1987. U.S. EPA. in response to a request by PRPs, extended the public
comment period to September 18, 1987. The attached responsiveness summary
addresses specific questions and comments raised at the August 27, 1987
meeting and during the public comment period.
~
SUMMARY OF THE ENDANGERMENT ASSESSMENT
An endangerment assessment (EA) was performed as part of the remedial
investigation to quantitatively determine the public health and
environmental risks posed by the site. Due to the large number of chemicals
detected at the site, each chemical was not quantitatively assessed. The
first step of the EA was the selection of chemicals of concern. A selected
group of chemicals was chosen to be representative of the chemicals
. 'causing the greatest pub'Hc health or environmental risk b'ecause of
concentration, frequency of detection, mobility and persistence in the
environment, and/or toxicity. The selected chemicals of concern are
shown in Table 3.
Once the chemicals of concern were established, an exposure assessment
. .~-'~...~.:"'~='~':'
-------
Table 3
Chemicals of Concern for the LOI Site
Volatile Urganic Compounds
1. Chloroform
2. 'Methylene chloride
3. Trichloroethylene
4. Tetrachloroethylene
5. 2-Butanone
6. Benzene
7. Toluene
1.
2.
3.
4.
5.
Semi-volatile Organic Compounds
Benzo(a )pyrene
Bis(2-ethylhexyl)phthalate
Phenol
Napthalene
Fluoranthene
, ,
1.
Pesticides/Polychlorinated biphenyls (PCB~)
PCBs
Inorganics
1. Bar; urn
2. Cadmium
3. Lead
Notes:
S = Oetected in Soil
6W = Detected in Ground Water
Mat r; x
S, GW
S, GW
S, GW
S
S, GW
S, GW
S, G\~
- .0-
S
'S, (~W
S, GW
S, GW
S
..
s
S, GW
S, GW
S, GW
-------
- 5 -
was performed to determine the potential for receptors (human or
environmental) to come into contact with these chemicals. Present and
future exposure was evaluated for both the most probable and realistic
. worst case exposure scenarios. The exposure assessment concluded that
public health was threatened by conditions presented ~n the realistic
worst case scenario. The routes of exposure causing elevated public
health risks were: 1) direct contact with on-site surface and subsurface
soil; 2) future ingestion of ground water; and 3) direct contact with
off-site soil and leachate. The only potential environmental risk to the
Clinton River or its floodplain was acute or chronic toxicity to wetland
organisms from iron and/or cyanid~ in ground water. (The floodplain area
assessed includes the Rochester-Utica State Recreation Area and the
Shadbush Tract Nature Study Area).
For complete details, the reader is referred to Chapter 7 of the Remedial
Investigation Report (May 1987, E.C. Jordan Co.).
RESPONSE OBJECTIVES
- ~.
Based on the findings of the endangerment assessment, the following
response objectives were developed in the feasibility study:
. - .
o control the public health risk due to dire~t contact with on- and
off-site soils
.." .
o control the public health and ~~vir~nmental risk due to direct contact
with polychlorinated biphenyls (PCBs), polynuclear aromatic hydrocarbons
(PAHs), and inorganic chemicals in leachate .
~
o control the environmental risk due to runoff of hazardous substances
in on-site soil and leachate
o control the potential public health risk posed by the use of ground
water as a drinking water source
o control future impacts of on-site ground water migration to wetlands
o control the public health risk due to inhalation of chemicals volatilized
from or adsorbed on soil
Also, the presence or absence of bedrock aquifer contamination will be
confirmed through additional monitoring well drilling and sampling.
. . These response objectives, when attained through remedial. action, will
provide protection of public health and the environment.
TECHNOLOGY SCREENING
With the response objectives identified, the FS then evaluated appropriate
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- 6 -
remedial technologies to attain these objectives. A total of 66 treatment
and containment technologies were initially identified for screening.
Treatment technologies were defined as those which reduce the mobility,
toxicity, and/or volume of the hazardous waste. Containment technologies
were defined as those which reduce the hazard by controlling the threat
of release or direct contact. The screening process was necessary to
reasonably limit the number of technologies required for detailed examination.
In ~rder to be evaluated further, the technology had to be:
o capable of meeting or contributing to the respons~ objectives;
o applicable to controlling or treating chemical types identified in the
RI and EA;
o appropriate for controlling or treating a chemically mixed waste
stream; and
'"
o
applicable to site conditions.
A second screening was performed based ,on technology performance (action
accomplished), reliability (proven operation); implementability (ease of
construction), and applicability t~ site condltions. After this screening,
21 technologies were retained for~he development of alternatives. Only
the 21 technologies which passed "flie screening process were used to
formulate remedial alternatives. "
..
TARGET CLEANUP LEVELS
Target cleanup levels (TCLs) are quantitative, chemical-specific estimated
cleanup goals. As with the endangerment assessment, a screening process
was instituted to define the most critical chemical TCLs. The following
criteria were used to establish TCLs:
o Baseline (present) risk level - TCLs were developed for only those
chemicals which posed a "significant" risk as defined in the EA. The
baseline risk level is defined as the risk resulting from exposure to
chemicals currently found at the site.
o Treatability - different classes of compounds may have a different
response to a given treatment technology. For example, air stripping ;s
effective for volatile organic compounds, but not inorganic compounds.
. Therefore, two or more types of treatment may be necessary for a given
medium to meet the identified target risk levei. .
o Location - Since the risks have been evaluated based on location (i.e.
on-site vs. off-site), the TCLs for each location may be different. The
TCLs were established so that each location would meet the response
objectives after remediation.
o Frequency of detection - A compound detected with a much smaller
frequency than other compounds may not require its own TCL. If the
chemical's detection was ~n isolated occurrence, these results were
carefully evaluated for accuracy prior to establishing a TCL for that
chemical.
-"'" .. .~~..... ~...-----.......---..-......-.-_.. .
--.-""""'~---""""""'''7''.~~7-' --_._-_.~-- -.'--"""--.- .".--_..__. -- ..--..
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-------
- 7 -
o Chemical class - All compounds that posed a significant fisk were
evaluated in the screening process. However, if a chemical was represented
by another higher risk chemical of the same class, it may have been
possible to establish one TCL for the higher riSk chemical. This assumes
that the deleted chemical would be treated as effectively as the selected
chemical.
TCLs were established for each of the compounds that met the above criteria.
Both carcinogenic and non-carcinogenic risks were evaluated. TCLs'for
carcinogens in soil and ground water were calculated assuming a one in
one million (1 x 10E-06) health risk. In other words, the attainment of
all TCLs for a particular medium (i.e. ground water or soil) would result
in a cancer risk of no greater than one in one million. MCLs for the
organic chemicals of concern were not used since none were final at the
time the EA was prepared. MCLs for trichloroethylene and benzene have
since been promulgated. In this situation, where complex mixtures of
carcinogens exist, U.S. EPA uses the approach in the "Superfund Public
Health Evaluation Manual" (U.S.EPA, October 1986), to reduce the "additive
risk from the chemicals of concern to an acceptable level. The Regional
policy to reduce the. unit cancer health risk to 1 x 10E.06to receptors
lies within the range of protection specified i~ the NCP. .
For non-carcinogens in ground water, Maximum Contaminant Levels (MCLs),
which are enforceable Federal standardsifdr drinking water, were used
(when available) as the TCLs. Non-c:arcinogeni.c soil TCLs were set using
risk based calculations that assumed a "ri.s.k ratio" of less than one.
The risk ratio was defined as the'-bOdy.dose level divided by the relevant
standard, criterion, or guidance Jevel~ Body dose (human intake) levels
were then calculated based on several factors, including concentration,
50i1 contacted (or ground water ingested), percent absorption, and body
weight. A risk ratio of greater than one was considered "significant",
and less than one "insignificant" for the purpose of the EA analysis.
The attainment of these TCLs would result in no adverse health affects.
The method used is deta'i1ed in the Superfund Public Health Evaluation
Manual. The reader is encouraged to refer to the EA (Chapter 7 of the RI
report) for complete details.
..
Some background (upgradient) concentrations of lead in soil and methylene
chloride in ground water, were found to be higher than the on-site or
downgradient concentrations. It was theorized (but not confirmed) that
this was due to other potential sources of contamtnation in the area,
such as surrounding landfills, the auto junkyards, or the asphalt plant
south of the site. The purpose of this project is to remediate the risks
posed by the LDI site. Therefore, if background or upgradient concentrations
are documented to be higher than the calculated TCL, the TCL will be
. raised to the lowest background concentration." If this is not done, the
TCLs may be unattainable. The decision to adjust TCLs will occur during
the remedial action phase of the project. The TCLs for all compounds are
shown in Table 4.
It is important to note that soil/waste and ground water TCLs are not
equal to absolute level of cleanup to be achieved during the remedial
action. A wide variety of hazardous substances were detected during the
RI. The FS used certain chemical data in order to arrive at TCLs.
-------
Table 4
Target Cleanup levels (TCls) for the lOI Site
Ground Water
Chemi.ca 1 TCl (ug/l) Source
Bari um 1000 MCl
Cadmi um 10 MCl
Chloroform 0.1 Risk Calculation
Benzene 0.2 II II
Methylene chloride 1 II II
Trichloroethylene (TCE) 0.8 II II
- .'
Soils
-
Chemical TCl (ug/g) ~ So~rce
Trichloroethylene (TCE) 77 Risk Calculation
Tetrachloroethylene (PCE) 16 ,II, ' II
Benzo(a)pyrene 0.4 ' -, If II
PCBs 1 II II
lead 20 II II
Notes:
..
1. ug/l = microgram per liter (part per billion)
2. ug/g = microgram per gram (part per million)
3. MCl = maximum contaminant level
4. All risk calculations are for carcinogenic risk
except for lead.
-------
- 8 -
Du~ing implementation of the remedial action, it is not likely that these,
exact concentrations will be found. In order to account for this
variability, the goal of the remedial action is to achieve an additive
excess cancer risK 1 x 10E-06 or less, and a risK ratio of one or less
for non-caricinogens. In order to achieve this, confirmation sampling
will be performed during the remedial action. The level of remediation
will be based on chemicals of concern (Table 3) actually present
in a given sample. Sample results will be corrected for bacKground
conditions and contaminants from sources other than LDI. In this way,
the large number of known chemicals of concern can be taken into account.
Hence, the remedial action will be guided by actual conditions, while
ensu~ing that a protective level in soil/waste and ground water is met.
Although some degree of flexibility will be possible, as a minimum,
chemical-specific standards such as MCLs must be attained (unless background
or other source contamination is higher than MCLs).
ALTERNATIVES DEVELOPMENT AND EVALUATION
Using the previo~sly established response objectives and target cieanup
levels, the FS then ~ssembled the identified technologies into site
a 1 ternat i ves (combi nat ions of techno 1 ogi es to remedi ate 'th'e site). The
site was divided into three areas requiring remediation: ~
"
o
o
o
on-site debris, buildings, structures';, equipment, and refuse
on- and off-site soil/waste.' '
on- and off-site ground water
~
The following assumptions are commdn to-.afl alternatives discussed in
t his Summa ry .
1. Leachate control will be addressed through the control of soil/waste
,and ground water.
2. Remediation is required in all areas within the site boundary. This
is because no identifiable pattern of chemical contamination, either over
a certain source area or with depth, was found during the RI.
3. Off-site soil requiring remediation will be treated and/or contained
in the same manner as on-site soils (except alternative 2). This includes
the soils from the access road.
4. The FS cost estimates assume that discharge of treated ground water is to
the Clinton River. However, the possibility of discharge to a publicly owned
treatment works will be evaluated during remedial design.
, '5.
On- and off-site ground water will be treated using the same treatment system.
6. The waste sample jars located in the office building will be removed
and disposed of at an off-site RCRA approved incineration facility.
7. Further study of the bedrock aquifer will be performed as discussed in this
Summa ry .
After consideration of the response objectives and screening of the
technologies, seven alternatives were assembled and examined in detail.
With the exception of alternative 1 (no action), all of the alternatives
are considered final remedies for the site. The major components of the
-------
- 9 -
alternatives are shown in Table 5.
DESCRIPTION OF ALTERNATIVES
Alternative 1
Description - No remedial action would take place under this alternative.
It i~ primarily included as a baseline scenario to which other alternatives
can be compared. ' It is not protective of public health or the environment.
Performance Goals - Since this alternative does not utilize any treatment.
there are no performance goals.
Alternative 2
Description - The major components are on-site land disposal of debris/
equipment (into the 'existing incinerator pit), a slurry-wall and impermeable
cap containment system, and an air stripping/ion exchange ground water
extraction and treatment system. A slurry wall 'is.-a low-permeability
fixed wall installed to contain and/or..divert ground water flow. The
wall will be trenched and keyed into-the existing highly impermeable
silt/clay layer that lies about 3~feet below the ground surface. The
trench will be backfilled with cle..an, sotl' mixed with bentonite, Portland
Cement, or other suitable materia1. The'slurry wall will form an impenneable
ground water barrier around the entire site, roughly following the existing
fence li'ne.. Excavated soils during slurry wall construction will be sent
to a compliant RCRA landfill for disposal. The cap system, which will be
constructed after the slurry wall, consists of a 24" compacted clay layer
and a synthetic liner. The combination of the slurry wall and cap will
prevent any significant surface or ground water infiltration, so that
contaminants are contained within the site.
..
Air stripping involves passing a stream of air over the contaminated
water using a blower system. This action physically removes VOCs from
the water by volatilizing them into the air stream, which is then treated
using vapor phase activated carbon. Ion exchange is a reversible process
in which an interchange of ions occurs between a solution and an essentially
insoluble solid resin in contact with the solution. Toxic ions are
removed from the aqueous phase by being exchanged with non-toxic ions
held by the ion exchange material. Ion exchange will treat inorganics in
the ground water.
No direct treatment of soil/waste is included in this alternative.
Performance Goals - Since there is no treatment of soil/waste, this
alternative will not meet soil/waste TCLs. The ground water treatment
system will meet the TCLs. The air stripper must use an air emission
control device. In the past, activated carbon has met the State of
Michigan requirement for best available control technology (BACT). The
emission control system must also be monitored for specific compounds
during operation. Activated carbon, if selected for use, can be regenerated
(incinerated) at an off-site facility, which makes this essentially a
destruction technology.
-------
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-------
- 10 -
Time to Meet Performance Objective - It is estimated that the construction
of the slurry wall/cap containment system, including the installation of
a ground water extraction and treatment system, will take 1 year. The
estimated time for ground water remediation (i.e. time to reach the
ground water TCLs) is 9 years. On-site ground water pumping is expected
to last only 3 years since the slurry wall/cap containment system will
prevent significant volumes of surface or ground water from entering the
enclosed site.
Alternative 3
Description - The major components are off-site land disposal of debris/
equipment at a sanitary landfill, off-site land disposal of soil/waste at
a RCRA comp1iant'landfi11, and an activated carbon/flocculation and
precipitation ground'water extraction and treatment syst~. Activated
carbon selectively adsorbs contaminants. It is' widely used as a treatment
medium for a variety of organic compounds. Flocculation involves the
addition of a chemical to agglomerate (pr~cipitate) small, unsett1eab1e
particles into larger, settleable ones. Actiyated carbon is proposed for
vac treatment, and f1occu1ation/preci:pitationfor inorganics treatment.
Performance Goals - Excavation of'soi1!waste will be performed until the
TCLs are achieved. Sampling of the soil/waste left in place is envisioned
to confirm that this goal fs met. The ground water treatment system will
meet the ground water TCLs. Sludge from the flocculation/precipitation
process wi 11 be generated, and wi 11 most 1 ikely requi re further treatment
or disposal at a RCRA facility.
..
Time to Meet Performance Objective - The excavation of soil/waste, including
off-site land disposal, is expected to take about 3 years. Installation
of the ground water extraction and treatment system will take about 6
months. The estimated time to reach the ground water TCLs is 9 years.
Alternative 4
Description - The major components are off-site disposal of debris/
equipment at a sanitary landfill, on-site incineration of soil/waste, and
an ultra violet (U/V) ozonation and flocculation/precipitation ground
. water extraction and treatment systelT1. A mobil.e incinera1:ion unit will
. be brought to the site for soil/waste treatment. The U/V ozonation
-------
- 11 -
process involves the simultaneous application of ozone and ultraviolet
light. Ozone is a highly reactive oxidizing agent, which will destroy
certain organic compounds in the presence of ultraviolet light. Conventional
U/V ozonation techniques involve bubbling ozone into a liquid solution
containing the waste. The mixture is then exposed to ultraviolet light
, in a mixing tank. U/V ozo~ation is proposed for VOC treatment, and
flocculation/precipitation for inorganics treatment.
Performance Goals - On-site incineration will meet the soil TCls. A
destruction removal efficiency (ORE) of 99.99% will be required for all
compounds with the exception of PCBs, which must have a ORE of 99.9999%.
Ash from the incineration process will retain most of the metals from the
soil/waste, and may require treatment or disposal at a RCRA facility.
Since incineration of soil does not greatly reduce its volume, the disposal
cost of the ash is significant if it must go to a RCRA facility. Incinerator
air emissions must meet the standards defined in RCRA Part 264 (miniMum
OREs, HCl limits, particulate emission limit). The ground water treatment
system will meet TCl$. Sludge from the f1occu1ation/precjpitation process
may fequire treatment or disposal at a RCRA facility. --
Time to Meet Performance Goals - A mobile incinerator is envisioned for
soil/waste incineration. It is estimat~dthatlO years will be required
to incinerate the volume of sail/waste proposed for treatment. The worst
case scenario is 15 years. Actual burn times are directly related to the
capacity and feed rate of the prop~~ed incineration unit, which is unknown
at thi s time. An est imated 6 months w}l1 be necessary to install the
ground water extraction and treatment system and dispose of the debris/
equipment off-site. The estimated time to reach the ground water TCls is
9 years.' .
~
Alternative 5
Description - The major components are off-site disposal of debris/
equipment at a sanitary landfill, vacuum extraction combined with
solidification/fixation for soil/waste, and an air stripping and ion
exchange ground water extraction and treatment system. Vacuum extraction
involves the installation of about 85 on-site wells primarily screened in
the unsaturated zone. These wells are connected to a vacuum system that
induces a flow of air across the soil/waste. This' action volatilizes
VOCs into the air stream, which is treated by an activated carbon system
(located on the surface prior) to discharge into the atmosphere. After
VOC treatment, the solidification/fixation operation will begin. The
. 'material will be excavated, then slurried with the solidification agent,
and finally replaced in the excavation from which it was taken. Vacuum
extraction will treat VOCs in the soil/waste, while solidification is
primarily for inorganics. Similarly, air stripping is for VOCs in ground
water, and ion exchange will treat inorganics (see alternative 2, for a
description of ion exchange).
Performance Goals - Vacuum extraction of soil/waste is expected to meet
TCLs for VOCs. Subsequent solidification/fixation converts the waste
into an easily handled solid material with reduced hazards from
-------
- 12 -
volatilization and leaching. The inorganic and PCB chemical TCLs for
soil/waste will be achieved through solidification/fixation. Air stripping
and ion exchange will meet the ground water TCLs. The ground water
treatment system must have an air emission control device such as activated
carbon (see discussion in alternative 2).
Time to Meet Performance Goals - The off-site disposal of debris/equipment,
and installation of the vacuum extraction and ground water extraction and
treatment systems is expected to take 6 months. Approximately one additional
mon~h will be required to set up the solidification/fixation equipment,
which must be done after vacuum extraction. The estimated time for vac
treatment using vacuum extraction is 2 years, after which solidification/
fixation is estimated to take 1 year to accomplish. The estimated time
to reach the ground water TCLs is 9 years.
Alternative 6
Description - The major components are off-site disposal of debris/equipment
at a sanitary landfill, on-site biodegradation and solfqffication/fixation
of soil/waste, and biological ground water extractjon and treatment with
flocculation/precipitation. The theory.of biodeg'radation involves altering
the soil envi ronment to promote mi crob; a~ catabol ism of organi c contami nants , ".
which results in the breakdown and detoxification of the contaminants. . ;
The biodegradation of soil/waste can be done either in-situ or using
excavation and mixing methods.T,helatter method is better suited for ~
the site conditions since the subsurface physical and chemical conditions
vary considerably. In this scenario, the soil/waste will be excavated
and mixed in a slurry, then treated. Following biotreatment, the soil/waste
will be solidified to treat the inorganic contaminants. Biotreatment of
ground water is a much more proven technology. Activated s'ludge, extended
aeration, contact stabilization, and rotating biological disks are some
of the methods that may be considered. Flocculation/precipitation (described
in alternative 3) is proposed for inorganics treatment.
Performance Goals - The biological treatment of soil/waste will be designed
to meet TCLs for vacs. Solidification of the soil/waste after biological
treatment will bind inorganic contaminants and PCBs into a solidified and
unleachable mass, thereby significantly reducing or eliminating the
chance of exposure. Therefore, the soil/waste TCLs for inorganics will
be achieved using solidification technology. Ground water biological
treatment will also meet TCls. Sludge from this process will be generated
that may require further treatment or disposal at a RCRA facility.
Time to Meet Performance Goals - The off-site'disposal ~f debris/equipment,
and installation of the soil/waste biodegradation, solidification/fixation,
and ground water extraction and treatment systems is estimated to last 8
months. The estimated time to reach the ground water TCLs is 9 years.
Alternative 7
Description - The major components are on-site land disposal of debris/
equipment, on-site solidification/fixation of soil/waste, on-site ground
water extraction and treatment using air stripping and ion exchange
. ~.. -. ... .
. . ~ "'". ... ~.. ......' ,".,
. - -.-..-,.... .-
.". ---- r------ -.'
.: - .
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. -.' . - .
-------
- 13 -
techno10gy.'and a slurry wall and impermeable cap containment system.
Although solidification has been typically used for inorganics treatMent.
it is proposed for both organic and inorganic chemical treatment in this
alternative. As discussed in the feasibility study. there have been
recent developments in the use of solidification agents for organic
treatment. including some proprietary additives. Since the mass of
organic contaminants in the soil is very small in comparison to the soil
mass. pre-treatment for VOCs may not be required. However. careful bench
and/or pilot scale testing must be done prior to implementing this method.
Slurry wall/cap construction is described in alternative 2. However. in
this alternative. the excavated soil/waste during slurry wall construction
will be placed on-site for later solidification/fixation. The slurry
wall/cap containment system is being used in this alternative as a Means
to protect the solidified soil/waste from degradation by upgradt~nt
ground water that is slightly contaminated with chemicals not attributable
to the LOI site. .
.'
Air stripping and ion exchange is described ift" a1t~rnative 2.
Performance Goals - The on-site solidific~tion of soil/waste is expected
to achieve VOC. PCB. and inorganic chemical TCLs through the immobilization
and reduced leachability of chemic'cih in t.hesolidified mass. No residual
material will be generated by thi.s:'prQcess. The ground water treatment
system will also meet TCLs. Depending on the type of air emission control
technology used. there may be some amount of material (such as activated
carbon) requiring peri~dic treatment or disposal.
Time to Meet Performance Goals - The on-site disposal of debris/equipment.
and installation of the ground water extraction and treatment system and
solidification/fixation system is expected to take 6 Months to complete.
Slurry wall construction will begin prior to soil/waste solidification
since excavated slurry wall soils will be solidified on-site. The slurry
wall construction time is estimated to be 6 months. Actual treatment
(solidification) of the soil/waste is estimated to require 1 year to
accomplish. On-site ground water pumping is expected to last only 3
years since the slurry wall/cap containment system will prevent significant
volumes of surface or ground water from entering the enclosed site. The
estimated time to reach the ground water TCLs is 9 years.
..
EVALUATION OF ALTERNATIVES
Each of the seven alternatives was evaluated using a nUM~er of evaluation
factors. The regulatory basis for these factors comes from the National
Contingency Plan and Section 121 of SARA (Cleanup Standards). Section
121(b)(l) states that. II Remedial actions in which treatment which permanently
and significantly reduces the volume. toxicity or mObility of the hazardous
substances. pollutants. and contaminants is a principal element. are to
be preferred over remedial actions not involving such treatment. The
offsite transport and disposal of hazardous substances or contaminated
materials without such treatment should be the least favored alternative
remedial action where practicable treatment technologies are available."
Section 121(b)(1) also states that the following factors shall be addressed
-------
: ::.-.." '...., . :-~-
- 14 -
during the remedy selection process:
(A) the long-term uncertainties associated with land disposal;
(B) the goals, objectives, and requirements of the Solid Waste
Disposal Act; ,
(C) the persistence, toxicity, mobility, and propensity to
bio~ccumulate of such hazardous substances and their constituents;
(D) short- and long-term potential for adverse health effects from
human exposure;
(E) long-term maintenance costs;
(F) the potential for future remedial action costs if the alternative
remedial action in question were to fail; and
(G) the potential threat to human health and the environment associated
with excavation, transportation, and redisposal, or containment;
Section 121 of SARA. also requires that the selected r~~dy is protective
of human health and the environment, is cost-effective~.and uses permanent
solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent pra.c~icable. .
" .
In addition to the factors 1 isted ..in Section'.121 of SARA, alternatives
were evaluated using current U.S.EPA guidance, including: "InteriM
Guidance on Superfund Selection o:fRemedy.r dated December 24, 1986 and
"Additional Interim Guidance for FY'87 Records of Decision" dated July
24, 1987. In the July,' 24, 1987 guidance, the following nine evaluation
factors are referenced:
..
1.
Compliance with applicable, or relevant and appropriate requirements
(ARARs)
Reduction of Toxicity, MObility, or Volume
Short-Term Effectiveness
Long-Term Effectiveness and Protectiveness
Impl ementabi 1 i ty
Cost
Community Acceptance
State Acceptance
Overall Protection of Human Health and the Environment
2.
3.
4.
5.
6.
7.
8.
9.
The analysis in the following section was performed using the above
factors.
Alternative 1 - This alternative is undesirab~e since it" is not protective
of pUblic health and the environment. It will not meet the contaminant
specific ARARs, such as MCLs for ground water quality, nor reduce the
mobility, toxicity, or volume of the hazardous substances present at the
site. Hazardous substances present in soil and ground water are likely
to continue to migrate and potentially cause additional public health and
environmental threats. The alternative is not a permanent remedy. The
alternative is included primarily as a baseline alternative, and is not
acceptable to local residents or the State of Michigan.
-- ... - 0'- ..-. .---~.- .
~. 0"". " .
- ----:::'; --. -'.'r,-
. .. _. ,.- .:-:":' ~ . .
. :~:-;. --- c.""'- ":' I. '~o' -. ,.- -- .~..
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- 15 -
Alternative 2 - This alternative is primarily a containment option.
Neither the volume nor toxicity of the soil/waste will be reduced, although
its mobility will be reduced by the slurry wall. It is protective of
public health and the environment over the short term, but lacks any
treatment for soil/waste. Hazardous substances will remain untreated
on-site, so the alternative is not a permanent remedy. Some short-term
impact may result from the excavation of soil/waste during slurry wall
construction. However, this can be minimized through limiting the area
of open excavation and covering it to reduce dust and volatile chemical
emissions. Although slurry walls have been successfully constructed,
long-term performance data are not available. Additional remedial action
costs may be incurred if the slurry wall fails (leaks or degrades due to
sOil/waste contaminants).
The ground water treatment system will reduce the mobility, toxicity, and
volume of hazardous substances in ground water. and will meet Federal and
State ARARs. This portion of the alternative will be fQllj protective of
public health and the environment. .
In summary. the alternative provides a fajr degree of public health and
environmental protection. However. since'the soil/waste is not treated,
it is not a permanent remedy which usesperma~ent solutions and alternative
treatment technologies or resource recovery. activities to the maximum
extent pract i cab 1 e. as is preferref(by.$ARA.
..
Alternative 3 - Although this remedy does not treat the soil/waste, it
will meet ARARs for land disposal. The ground water treatment system
will meet Federal and State ARARs. This alternative is protective of
public health, but does not actually treat the excavated soil/waste
(estimated volume = 136.650 cubic yards). There will be no reduction in
the toxicity or volume of the waste. and the mObility of redisposed waste
will depend on how well the disposal facility is constructed. Although
the alternative will essentially remove the source of contamination from
the LDI site, there is a potential for the waste to cause a contamination
problem at the off-site facility at which it is eventually disposed.
This is inconsistent with the goals of SARA and the Solid Waste Disposal
Act, which call for treatment whenever feasible. SARA specifically
states in Section 121 that off-site land disposal without treatment is
the least preferred alternative. The alternative is readily implementable
from a construction standpoint, but the RCRA Land Disposal Restrictions
. (40 CFR Part 268) may effectively preclude its selection. The alternative
. may have significant air emission impacts due t~ the large number of
truckloads of hazardous waste that must be transported off-site. Both
the State and local residents have expressed concern regarding excavation
and redisposal of hazardous waste in landfills. Finally, the estimated
cost of the alternative exceeds that of other alternatives that treat the
soil/waste.
Alternative 4 - This alternative will attain all identified Federal and
State ARARs, including the MCLs for ground water, NPDES permit requirements,
RCRA requirements for incineration, the Michigan Hazardous Waste Management
Act (Act 64), Michigan Water Resources Commission Act 245, and the Michigan
Air Pollution Act (Act 348). It uses treatment as a principal element
-------
-16-
for all contaminated media. It will pe~manently dest~oy most organic
chemicals in soil/waste, but is also the most expensive option. Incineration
of soil is a proven technology for organics, so the alternative has a
very good rating for long-term protectiveness. The mobility and toxicity
of the soil/waste is significantly reduced, and the volume is slightly
reduced. The incinerated soil/waste will produce an ash which may be
high in metals content, requiring further treatment or disposal at a RCRA
facility. Incineration on-site should be relatively easy to implement,
although there may be some problem acquiring a mobile incinerator.
However, the level of treatment afforded by incineration, while desirable,
particularly for PCBs, is not cost-effective for the LDI site contaminants.
The RI concluded that there was no clearly identifiable pattern or "hot
spots" of contamination at the site. Due to the non-uniform and unpredictable
waste distribution, the cost-effectiveness of selectively incinerating
certain waste types or site areas could not be determined. Therefore,
the FS assumed that the entire soil/waste volume on-site would require
incineration (125,000 cubic yards). Thus, an alternative type o.f treatment
was further ana~yzed in the FS. .
Although the alternative is considered a permanent remec~, it is estimated
that soil/waste incineration of the 136,650 cubic yards ~f waste (125,000
cubic yards from on-site plus 11,650 cubic yards from off-site) will take
10 years (based on a 16 hr/day operatioIT~5 days/week). A very negative
public reaction is anticipated to the selection of an alternative using
on-site incineration, since numerous. complaints were received by local
res i dent s du ri ng LD I IS operati ng ~.eri od ~ ,. .
..
Alternative 5
This alternative also uses a high degree of treatment for soil/waste and
ground water. It will attain all identified Federal and State ARARs,
including RCRA requirements, MCLs for ground water, NPDES permit requirements,
the Michigan Hazardous Waste Management Act (Act 64), Michigan Water
Resources Commission Act 245, and the Michigan Air Pollution Act (Act
348) .
Vacuum extraction for soil treatment is currently considered an innovative
technology. However, it has been proven for VOC treatment at several hazardous
waste sites. The mass of VOCs in the soil/waste is less than 1~ of the mass of
the entire soil mass. Therefore, it may not be costeffective to use vacumm
extraction for pre-treatment. Also, the State of Michigan has serious concerns
about the effectiveness of vacuum extraction technology for this site. Soil
conditions (moisture, permeability, uniformity, and other physical parameters)
. directly affect vacuum extraction treatment e~ficiency. .A permeable and
homogeneous material such as sand is a good medium for vacuum extraction.
The soil at the site is very heterogeneous due to natural sands and
gravels, the presence of old landfill materials, and solidified material
in the waste oil and scrubber lagoons (from the previous removal actions).
Under favorable site conditions, vacuum extraction reduces the mobility,
toxicity, and volume of hazardous substances by extracting and transferring
them to a treatment system, in this case activated carbon. The carbon can
be regenerated (incinerated) for reuse.
.'~ ~ ..~~ .,.:~ ,~-;.~~~:;.; ..:_~:.~;':~i.;.~~:':;: ~::~=..~~:;;',:~.;~~~~ :-:::::.::.~~'~~: .~:~;.~~~; ~~~: .:.!~.~":~ ~-~: ~:-;.~.~-.~,~; .~: "':'.~-:....,~. ~,: :'.::.;:.;":\:; ,~~~_.~--~ :,~~-=::: ::~-::;',~-:=~~:;..~~::'~ ;~.:~.-:,::;, ~':'~~.:~..~'.~~'."..:.~~. :.~:::;, :;~ ~. :..~..' .:;:~':':_- :..-:~~:~;-.:~~ ~~:: "". ...
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- 17 -
Solidification/fixation is used for non-volatile organic (including PCBs)
and inorganic contaminants. The closure requirements outlined in RCRA
Part 264 are ARARs., and will be met by this alternative. The alternative
will reduce the mobility and toxicity of hazardous substances in the
soil/waste, but will increase the volume by an estimated two times.
Overall, the alternative is protective of public health and the environment.
It will reduce the primary risks posed by the site through treatment of
the hazardous substances involved. The risks posed by the soil/waste
will be reduced to the TCLs in about three years. The long-term risk
posed by contaminants remaining in the soil/waste will be minimal due to
the elimination of direct contact and threat of leaching of hazardous
substances from the solidified soil/waste. The alternative will be
readily constructable since standard equipment and materials are used.
particularly for the ground water extraction and treatment and
solidification/fixation systems. Vacuum extraction will require"a.
specialized contractor with expertise in the process. but the materials
will not be difficult to obtain. Pilot and/or bench sc~l~.tests will be
required to determine the proper type of solidification/fixation agent
for the soil/waste. The estimated cost of alterna~ive 5 is approximately
the same as alternative 7. given the +50/-30% accuracy of the FS cost
estimates. ~ .~
..
Alternative 6
"...",:,',
This alternative wi11 attain all identified Federal and State ARARs,
including RCRA requirements, MCLs for ground water. NPDES permit requirements.
the Michigan Hazardous Waste Management Act (Act 64); Michigan Water
Resources Commission Act 245, and the Michigan Air Pollution Act (Act
348). It also uses an innovative technology for soil/waste treatment
(biodegradation). Biodegradation will reduce the mObility. toxicity, and
volume of organic chemicals in soil/waste and ground water. Solidification/
fixation is required to treat inorganics and PCBs. The mobility and
toxicity of these compounds will be reduced, but the volume of the sOil/waste
will increase by an estimated two times. Biodegradation has been tried
on a very limited scale in hazardous waste soil treatment applications.
It is a proven technology for water treatment. Short-term impacts include
potential air emissions during excavation for the'soi1/waste biotreatment
and/or solidification process. The bench scale study (during remedial
design) will assess the potential for. volatilization of chemicals during
excavation. The long-term risk posed by contaminants remaining in the
. sOil/waste will be minimal due to the elimination of direct contact and
. threat of leaching of hazardous substances from the solid'ified soil/waste. .
The closure requirements outlined in RCRA Part 264 are ARARs, and will be
met by this alternative.
The alternative is readily implementab1e, although the,ground water
treatment and soil/waste biotreatment processes require pilot and/or
bench scale tests. A specialized contractor will be needed to
-------
- 18 -
implement the alternative and optimize.the treatment systems.
Properly designed, alternative 6 will be protective of public health and
the environment. However, it is the second most expensive alternative
evaluated. Also, biological treatment of a mixed stream of hazardous
substances in soil has not been well documented. Given the uncertain
likelihood of success and its relatively high cost, the alternative is
not recommended for selection.
Alternative 7
This alternative will attain all identified Federal and State ARARs,
including RCRA requirements, MCLs for ground water, NPDES permit
requirements, the Michigan Hazardous Waste Management Act (A~t64),
Michigan Water Resources Commission Act 245, and the Michigan Alr. Pollution
Act (Act 348).' It uses treatment as a principal elem~nt (as do alternatives
4, 5, and 6). Solidification/fixation of soil/waste Wjthout pretreatment
for VOCs is proposed. Although there are high concentrations of certain
VOCs in the soil/waste, the total VOC mass ;s relatively small compared
to the mass of the entire soil/waste., -The proper solidification/fixation
agent (or combination of agents) must be found during pilot and/or bench
scale studies. The remedy will reduce the mobility and toxicity of the
waste by greatly reducing or e1;~inatin~.the ability for hazardous chemicals ~
to leach out of the solidified mass..-.H6wever, hazardous chemicals still
remain in that mass. The soTidification/ fixation process will increase
the volume of soil/waste by an estimated two times.
The closure requirements outlined in RCRA Part 264 are ARARs, and will be
met by this alternative. Specific RCRA closure requirements are discussed
in the Recommended Remedy section.
In addition to the treatment components of the remedy, alternative 7
includes the construction of a slurry wall and impermeable cap. This
system will contain the hazardous substances within the site. The slurry
wall/cap system will also protect the solidified soil/waste from degradation
by upgradient ground water that is slightly contaminated with chemicals
not attributable to the LDI site. .
Short-term impacts include potential air emissions during excavation for
the slurry wall and/or the on-site solidification process. The bench
scale study will be designed to assess the potential for volatilization
of cheMicals during excavation. It is estima~ed that 18 months (6 months
installation and 1 year treatment time) will be required to meet the
soil/waste TCLs. Of the soil/waste treatment options evaluated, this is
the shortest time frame for that process (since no VOC pre-treatment is
proposed) .
Alternative 7 will be protective of public health and the environment.
Its cost is nearly equal to alternative S, given the accuracy of the FS
cost estimates. Alternatives 5 and 7 are the least expensive alternatives
that use some type of treatment for all contaminated media. Alternative
7 has been endorsed by the State of Michigan. Some concerns regarding
"-"--- -._-~.-- '-'-_.'-'--_'~_-R' ~ - .,~ .---.. '.~...-_..._.-:~.~-.. --.-.,.
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- 19 -
the solidi fication/fixation process were raised at the August 27, 1987
- Public Meeting. U.S. EPA's response to these concerns is detailed in the
Responsiveness Summary.
RECOMMENDED REMEDY
The recommended remedy for selection and implementation is alternative 7.
Alternatives I, 2, and 3 clearly do not meet the preferences mandated by
SARA since they do not use treatment as a principal element of the remedy.
Alternative 1 leaves the site essentially unchanged, which is unacceptable
from a public health and environmental standpoint. It will not meet
Federal or State ARARs. Alternatives 2 and 3 merely contain the soil/waste
without treatment, which is counter to the preferences established in Section
121(b) of SARA for implementation of remedial action. Alternativ:es
4, 5. 6. and 7 all use treatment as a principal element of the remedy. Alter-
native 7 is considered the most cost-effective alternative!
.-
Protect i veness
- -.
Alternative 7 provides a high degree of;tr~atment of the hazardous substances
present at the site. It will be both a: source-control measure (through
the remediation of soil/waste) and- -a In-anagement of migration remedy
(ground water). Therefore, the al~erriative- will reduce the threat of
direct contact with hazardous substanc~, 'and the future threat of ingestion
of contaminated ground water. The soil/waste may be solidified using a
pozzalan-type material (e.g. fly ash) and/or a cement based agent (e.g.
Portland Cement). The exact solidifying agent or combination of agents
will be determined during bench and/or pilot scale tests during the
remedial design. In addition, the potential for volatilization of chemicals
during the solidification/fixation process will be assessed.
Although hazardous substances in the soil/waste will be solidified to
significantly reduce their-mobility and toxicity, they will not be
permanently destroyed. Section 121(c) of SARA requires that the selection
of a remedial action which results in any hazardous substances remaining
at the site must be reviewed no less than every five years after initiation
of such remedial action. This is to ensure that the selected remedial
action continues to be protective of human health and the environment.
The recommended alternative (No.7) will require such review.
Consistency with Other Laws
. Alternative 7 is designed to meet all applicable, or relevant and
appropriate requirements (ARARs) of Federal and State statutes. The
federal ARARs include RCRA (42 U.S.C. 9 6901 et seq. and 40 CFR Part
264), OSHA (29 CFR Part 1910), the Clean Water Act (40 CFR Parts 122, 125
& 403), and the Toxic Substances Control Act (TSCA, 40 CFR Part 761).
State ARARs include the Michigan Hazardous Waste Management Act (Act 64),
the Michigan Solid Waste Act (Act 641), the Michigan Air Pollution Act
(Act 348), and the Michigan Water Resources Commission Act (Act 245).
..
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- 20 -
The following specific ARARs will be met by alternative 7.
RCRA: :
Alternative 7 involves placement and treatment of soil and debris wastes.
Placement of wastes or treated residuals is prohibited under RCRA Land
Disposal Restrictions (LOR) unless certain treatment standards are met.
LDR standards have not been promulgated for soil and debris wastes~ but
when published, may be applicable or relevant and appropriate. Despite
the absence of specific treatment standards, the treatment method employed
as part of this remedial action satisfies the statutory requir~ent to,
1I...substantially diminish the toxicity of the waste or substantially
reduce the likelihood of migration of hazardous constituents from the
waste so that short-term and long-te~ threats to human health and the
envirorment are minimized. II (Section 3004(m) of the Hazardous and
Sol id Waste Amendments). .
~
Other RCRA requi!ements are discussed below.
o Corrective Action' provisions of Subtitle C regarding-liazardous Waste
Management.
o Part 264.116 - A survey plat indica-Hog th.e location and dimensions
of the hazardous waste closure area will be submitted to the local zoning
authority, or the authority with jurlsdictionover land use. The plat
will also be submitted to the U.$~"~PA R'e.gi'ona1 Administrator and the
Director of the MDNR." . .
o Part 264.14 and 264.117(b) and (c) - ~ 24-hour surveillance of the
site will be maintained during closure activities to prevent unauthorized
access. The use of the facility area must be restricted so that the
containment system and the monitoring system are not disturbed.
..
o Part 264.310 - The cover system must be designed to meet the performance
standards referenced in this section.
o Part 264.114 - All debris/equipment must be properly decontaminated
prior to disposal. In addition, construction equipment must be
decontaminated prior to leaving the site.
o Part 264.91-264.101 - MCLs will be used as minimum ground water quality
requirements, except if background levels exceed the MCL.
Occupational Safety and Health Administration:
o The selected remedial action contractor must develop and implement a
health and safety program for his workers, if such a program does not
already exist. All on-s;te workers must meet the minimum training and
medical monitoring requirements outlined in 40 CFR 1910.
Clean Water Act:
o The treated ground water discharge to the Clinton River will meet the
technical requirements of Section 402 of the Clean Water Act (National
Pollutant Discharge Elimination System). Specific chemical discharge
-T~_. _. --.... -~-'~-'-"--"'-'-"",-,.,.---.-., --.--- --..... "'.""-'_-~"'''.'
.":0-<""',--"-:'7""" --- '-""'''-.'' --. -. ... ..- ---. -.."- . ".-"" . On
"'., . "'.:~ -' .. - .
-------
- 21 -
standards will be developed for the ground water treatment system that
will ensure protection of water quality and aquatic life in the Clinton
River. Additional NPOES requirements are discussed under the heading,
"Michigan Water Resources Commission Act."
Toxic Substances Control Act:
If PCBs are found in concentrations of 50 parts per million (ppm) or
more, the following requirements of 40 CFR Section 761 will be met. (To
date; no PCBs greater than or equal to 50 ppm have been detected at the
site.)
o Section 761.60(a)(4) requires that such material be disposed of at a
TSCA approved incinerator or landfill.
o Section 761.79 outlines the requirements for decontamination af PCB
containers and e~uipment.
o
Section 761.180 outl ines record keeping and monitorirny.requi rements.
Michigan Hazardous Waste Management Act:
." "
o The alternative will meet the technical requirements of this Act.
Many of these are similar to the RCRArequirements.
~
Michigan Air Pollution Act:
o The treated air emissions from the air stripper will meet the technical
requirements of Michigan Air Pollution Act, including the requirement for
best available c.ontrol technology. Activated carbon has met this
requirement for past remedial actions in Michigan.
Michigan Water Resources Commission Act:
o The State of Michigan, as an authorized state, manages the NPOES
program pursuant to the Clean Water Act, and the Water Resources Commission
Act. The requirements of the State NPOES program will be followed.
Summary Discussion
Considering the various evaluation factors found in SARA and the National
Contingency Plan, alternative 7 offers the most cost-effective solution to
the contamination problem at the site. The principal threats posed by the
.site are direct contact with on- and off-site spils and leachate, and
. future ingestion of ground water." In order to remedy these threats,
alternative 7 uses treatment as a principal element to the maximum exte~t
practicable. Solidification/fixation of on- and off-site soils will
eliminate or greatly reduce the possibility for contaminants to leach
into ground water. In addition, the slurry wall and impenmeable cap
system will reduce surface water and ground water from contacting the
solidified mass, thus adding to its long-tenm stability and protectiveness.
Ground water contaminants (both on- and off-site) will be removed and
destroyed during activated carbon regeneration. While alternatives 4 and
6 provide a higher level of soil/waste treatment, the solidification/
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- 22 -
fixation unit cost ($125/cubic yard) is approximately four and two times
less expensive than incineration ($480/cubic yard) and biodegradation
($250/cubic yard), respectively. Although cost is not the deciding
factor during remedy selection, the objectives of the remedial action can
be accomplished with alternative 7 at a lower cost than alternatives 4
and 6. Alternative 5 also provides additional soil/waste treatment (of
VOCs) compared to alternative 7 at a cost roughly comparable to alternative
7. One reason for not selecting this alternative (which includes vacuum
extraction treatment of soil/waste VOCs) is the questionable likelihood
of success of vacuum extraction given the site soil conditions. Also,
solidification/fixation is expected to be effective for treatment of the
relatively low mass of organic contaminants found in the sOil/waste.
Based on the above analysis, the recommended alternative is fully protective
of public health and the environment, cost-effective, utilizes treatment
technologies to the maxi~um extent practicable, and will attain ~ll
applicable, or relevant and appropriate Federal and State requirements.
Operation and Maintenance
The recommended alternative requires certain annual 'operation and
maintenance (0 & M) activities in order~t~ensure that the TCLs are
achieved and maintained throughout the life of the project. After the
construction of the ground water andsoi1 /wa ste treatment faci 1 i ti es, and
the slurry wall/cap system, the fo)-lowing ."n~" & M tasks must be performed:
."
..
Activity
Years
1.
2.
3.
4.
5.
6.
Ground water monitoring
Cap mai ntenance
On-site ground water pumping
Water treatment system
Off-site ground water extraction
Fencing and security
1 through 30'
1 through 30
1 through 3
1 through 9
1 through 9
1 through 30
Ground water monitoring is required in order to assess the effectiveness
of the ground water extraction and treatment and the slurry wall/cap
systems. Cap maintenance is needed to make minor repairs to the clay cap
to prevent erosion and large surface cracks from developing. On-site
ground water pumping is required to maintain the water level within the
slurry wall/cap system and to prevent ground water mounding. The water
treatment system cost includes electricity, chemicals, and general 0 & M.
Offsite ground water extraction includes electricity and general 0 & M.
. Finally, fencing and security 0 & M is needed t~ ensure t~at the treatment
- systems and associated "equi pment are not di sturbed or vandal ized.
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- L3 -
SCHEDULE
The following are the key milestones for implementation of the remedial
action:
o Approve remedial action (sign ROD)
o Amend cooperative agreement for remedial
design (RD) and remedial action (RA)
o Start RD
a Complete RD
o Begin RA
~. ," ".- .
. ...
"-,:. .
Sep. 1987
Nov. 1987
Dec. 1987
Dec. 1988
Apr. 1989
."
..
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LIQUID DISPOSAL. INCORPORATED
C()1MUNITY RELATIONS RESPONSIVENESS SUMMARY
INTRODUCTION
The United States Environmental Protection Agency (U.S. EPA) and the
Michigan Department of Natural Resources (MDNR) have completed a Remedial
Investigation and Feasibility Study (RI/FS) regarding the Liquid Disposal.
Inc. (LOI) site at 3901 Hamlin Road in Utica. Michigan. In the RI/FS.
U.S. EPA and MDNR have collected information on the nature and extent of
contamination at LOI, have evaluated alternatives for appropriate remedial
action at LOI, and have proposed a remedial action for LOI. Throughout
this process, several public meetings have been held in which U.S. EPA
and MONR discussed the RI/FS progress and received comments and questions
from the public. .
The RI/FS has been, undertaken under the authority of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reaut.hori zati on Act of 1986
(SARA), and federal regulations entit)ed the National Oi1 and Hazardous
Substances Pollution Contingency Plan (N"CP).' Under CERCLA, comments
received from the pUblic are considered in U.S. EPA's selection of the
remedial action for each site. This document summarizes the public
comments recei ved and provides 'responses as to how the comments were
considered in the selection of the remedial action for LDI.
..
The responsiveness- summary has three sections:
Section 1. Overview. This section briefly presents the u.s. EPA's
proposed plan for remediation at LOI.
Section 2. Background of communit? Involvement and Concerns. This
section provides a brief history 0 community interest and concerns raised
during remedial planning activities at the site.
Section 3. Summary of Public Comments Received During Public Comment
Period and U.S. EPA Responses. Both oral and written comments are
grouped by issues, followed by U.S. EPA responses to these comments.
The detailed transcript of the Feasibility Study public meeting and the
written comments are not included in the report. They are available for
public inspection from U.S. EPA Region V in ~hicago, I1)inois and the
repository at the Shelby Township Library, Utica, Michigan. A summary of
the major comments and suggestions made at the public meeting is appended
to this Responsiveness Summary.
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-2-
1 .
OVERVJEW
On August 19, 1987, U.S. EPA and MONR presented to the public for comment
the draft Feasibility Study report for the lDI site. In the FS report,
U.S. EPA and MDNR analyzed different methods for cleaning up contamination
related to the lOI site, with a detailed analysis of seven remedial
alternatives. U.S. EPA and MONR proposed remedial actions which included
the foll owi ng:
1. No remedial action. The principal element of this alternative is
monitoring the site. This alternative is primarily included as a baseline
scenario to which other alternatives can be compared. It is not protective
of public health or the environment.
2. On-site land disposal of debris/equipment into
pit, a slurry 'wall and impermeable cap containment
stripping/ion exchange ground water extraction and
the existing incinerator
sy~tem, and an ai r
treatment system.
3. Off-site land disposal of debris/equipment' at a sanitary landfill,
off-site land disposal of soil/waste .at.,a RCRA compliant landfill, and an
activated carbon/flocculation and precipitation groundwater extraction
and treatment system. ...'
4. Off-s ite di sposal of deb ri slequi"pment at a sani tary 1 andfill, on-s ite
incineration of soil/waste, and an ultraviolet (U/V) ozonation and
flocculation/precipitation groundwater extraction and treatment sy"stem.
..
5. Off-site disposal of debris/equipment at a sanitary landfill, vacuum
extraction combined with solidifiation/fixation for sOil/waste, and an
air stripping and ion exchange ground water extraction and treatment
system.
6. Off-site disposal of debris/equipment at a sanitary landfill, on-site
biodegradation and solidification/fixation of soil/waste, and biological
ground water extraction and treatment with flocculation/precipitation.
7. On-site land disposal of debris/equipment, on-site solidification/fixation
of soil/waste, on-site ground water extraction and treatment using air
strfpping and ion exchange technology, and a slurry wall and impermeable
cap containment system.
U.S. EPA received several comments from the public at the August 27, 1987
public meeting in Utica, and received additional comments from individuals,
Potentially Responsible Parties (PRPs), a representative of thirteen
PRPs, and the PRP Steering Committee.
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-3-
2. COMMUNITY INVOLVEMENT ACTIVITIES
Chronology of Community Relations Activities
The chronology of community relations activities at the Liquid Disposal,
Incorporated site is as follows:
July 21, 1982 Letter to residents of Shelby Township (Progress Report #1)
announcing MONR request for U.S. EPA response to contamination at LOI.
August 17, 1982 Progress Report #2 - U.S. EPA approves $250,000 for response
action at LOI. LOI is proposed on interim NPL.
September 22, 1982 Progress Report #3 - discusses completion of limited
emergency action.
October 21, 1982 ~rogress Report #4 - U.S. EPA annou~es first public
meeting at LOI.
January 28, 1983 Progress Report #5 (H!3ndout at 'public meeting) - describes
phase one Remedi all nvest i gat ion wo rk'. '00 .
. .
April 25, 1983 Progress Report #6 ~o describes removal action at LOI.
May 25, 1983 Progress Report. 17 - armounces that U.S. EPA is funding more
removal work and alloting $385,000 for RI.
..
August 15, 1983 Progress Report #8 - announces formation of Citizens
Information Committee, more removal work, and the September 1983 public
meet i ng .
September 15, 1983, Public Meeting to announce local call-in center and
discuss action on LOI.
May 16, 1984 Progress Report #9 - provides update of RI and announces more
remova 1 we rk .
May 24,1984 Public Meeting to give an update r~port on tank removal.
March 15, 1985 Progress Report #10 - discusses RI and more removal work.
September 3, 1985 Progress Report #11 - provides RIfFS Update and report
on tank removal.
February 3, 1986 Progress Report #12 - provides update to announce Toxic
Substances Control Commission meeting in Shelby Township with
focus on LOI.
September 11,1986 Progress Report #13 - provides update on initial RI
findings for LOI.
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-4-
January 3D, 1987 Progress Report #14 announces February 19, 1987 public
meet i ng to s'"'1Il1ari ze R I fi ndi ngs for LO I.
February lq, 1987 Public P1eeting to discuss LDI RI report and discuss work
at the nearhy G&H site.
August 19, 1987 Public Comment Period begins.
August 20, lQ87 Progress Report #15 - summarizes LDI FS.
August 27, 1987 Public Meeting regarding public comment on LDI FS.
September 18, 1987 - Public Comment Period ends.
u.s. EPA originally established a public comment period from August 19, 1987
to September 9', 1987. Several PRPs requested an exte~sion of the public
comment period for. up to 30 additional days. In respon~e to the PRP
requests and site specific circumstances, 11.5. EPA, orr.September 2,1987,
extended the public comment period from the 21 . days specified in the NCP
to 30 days, with the public coment peri,od ending September 18, 1987. A
further extension of the public comment .perjod was not feasible in light
of U.S. EPA's and MDNR's mutual desire to implement remedial action
for the LDI site as qui ck ly as pr-act i cat,te, and Congress I des ire to
expedite superfund cleanups,as -evidenced by the cleanup schedules of
Section 116 of CERCLA.
..
..
3.
SUMMARY OF PUBLIC CDr1MENTS RECEIVED DURING PUBllC COMMENT PERIOD AND
U~S. EPA'S RESPONSES
Comments raised during the LnI Feasibility Study public comment period
are summarized below. In addition to these comments, there were a number
of comments submitted on liability for remediation of the sites. These
comments are not considered to be germane to the selection of the reMedy
and are beyond the scope of this Responsiveness Summary.
Issue: The PRP Steering Committee, their technical consultant and
several PRPs commented that the Remedial Investigation (RI) fails to
adequately characterize the site.
Comments:
1. The RI failed to meet its objectives as ~ result of. poor quality
contractor work, poor laboratory analysis, and a disjointed work plan.
2. Several different U.S. EPA contractors worked on the RI (GMC,
Associates, Ecology and Environment, E.C. Jordan).
3.
The RI Report prepared by GMC is completely inadequate.
4. The E.C. Jordan RI did not identify off-site contaminant pathways
and levels.
'.. .~ .~- - ~.' ~;"1:~:r;-~ '~"'.~.:...;:;.~:;.' j- ..,.~:..~.- ':'=,' ';,'...." .~:' ..':'~$; ",,' ''''.:',;''-:-: . : ~.: ~.:.... ":.." :~- ..-.",..,. ,,'-~'. .~"'~-:-~~ "< ~.: ~ ~~~~:..~-~~ ~.~ ;.,'.;;. ..:,~;~~~..';:. :':'~'::~t.~:..- "i;~':.~r~,~~~~.;~5~:~'" ,.. ::.':'I.;'..:.:_..~.':..~'. ~:-~~~:'~~'-;:" ~,~. : ~":'. .'.,:.~~'. ~.;... ";:'.:~'::~1: ..: ,",.'"," ."-:: -".
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-5-
5. There is no adequ~te analysis of LOI's contribution to ground water
or off-site conta~ination.
6. Shallow background wells shown to be unaffected by the site (2s,
5s, and 13s) should be used as representative of background.
7.. There are sources upgradient of LDI t~at have impacted shallow ground
water quality.
8. The E.C. Jordan RI does not adequately assess background ground water
quality.
9. The E.C. ,Jordan RI fai ls to measure the impact on the env.ir.on~ent of
junkyards, landfills, and industrial facilities surrounding the'
site. .
- .'-
10.
The E.C. Jordan RI lacks quantitative chemical da~a.
. -.
11. The Laboratory Data Audit r~ethodol0.9Y and Results prepared by the
PRP consultant, Fred C. Hart, shows much of the laboratory data used by
E.C. Jordan is invalid as a result~f failur-e to follow QA/QC procerlures.
12.
The consultants used by U.S-~ EPA-dfd not audit their entire data base.
..
13. The data validati'on procedures used by E.C. Jordan were not described.
None of the worksheets or checklists were suhMitted to determine auditing
procedures for data reviewers.
14. Different sa~pling ~ethods and techniques used by different EPA
contractors resulted in an inconsistent approach to data collection to
characterize the site.
15.
16.
lOI RI samples were sent to different laboratories.
E.C. Jordan audited only some data collected by GMC.
17.
Several groups of samples were not audited at all.
18. E.C. Jordan assessed the effect of laboratory contamination samples
in a manner different from EPA data validation protocol. Due to the
presence of several common laboratory contaminants on-site, sample data
was rejected by E.C. Jordan for common laboratory contaminants if co~pounds
were found in over 80% of the saMples from a particular round of samples.
EPA protocol for evaluating method blank contaminants is that the concentra-
tions of laboratory conta~inants in the sample must be at least ten times
the concentration of the laboratory contaminants in the method blank in
order for the data to be used.
19. The rationale for the chemical groupings for~ed, based on ~bi11ty
for chemicals found at LOI, was not presented in the E.C. Jordan RI.
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-6-
20. There is a lack of replicate ground water sampling. making time
and spatial comparisons difficult.
21. There is not one complete round of sampling data for both organic
and inorganic parameters from all existing on-site and off-site wells.
22. More emphasis should have been placed on the potential fill area
identified upgradient of the site in the LDI RI geophysical investigation.
23. Many of the figures in the RI Report are essentially useless due
to poor graphic design.
24. On the map showing boring locations. two boring locations were
1 abel ed B-112.
25. Soil data interpretation was difficult because the quantity and
variability ?f the data.
26. E.C. Jordan' detennined some soil sampling data'-was invalid. The
GMC audit and Hart audit of this data sug9~ted that.some of this data
was valid. Some on-site soils data wereinvali~ated by E.C. Jordan.
These soils were not resampled. ~""
27. On the shallow water table'mapdrawn"in the E.C.' Jordan RI. contour'
1 ines were improperly drawn in~.the v1~i'nity of wells 21s and 20s and
where contour lines cross the .Clinton River.
~
28. The potentiometric surface map for the deep aquifer in the E.C.
Jordan RI relied on use of an estimated hydraulic head in the production
well. The methodology for estimation was not expl,ained.
29. The fact that the data base shows a great deal of variability from
location to location and with time, is the result of the inclusion of
invalid data or exclusion of valid data.
30. Due to lack of site knowledge, unnecessary assumptions about the
site have been made and has resulted in a great deal of variability in
the data provided.
Response:
u.s. EPA maintains that the LOI RI was properly conducted. The RI Report
provided adequate infonnation to 1.) determine the nature and extent of
contamination, 2.) define the pUblic health and envir.onmental hazards
posed by the site, and 3.) array and evaluate remedial alternatives for
the site.
The RI Report was built on a sound data base. Large amounts of quantitative
data were collected from soil, leachate, ground water, surface water,
sediment, and biota, on and near the site. This information is summarized,
presented, and evaluated in Chapter 6 of the E.C. Jordan RI Report. It
. -.. -. . " .
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-7-
is presented in tabular form in Appendices H through S of the Jornan RI
Report. Not all samples collected prorluced usable data, but adequate
resampling was done in order to fill,any significa~t data gaps.
Work on the LOI RI was performed with major support from three different
contractors: GMC Associates, Ecology and Environment (E&E), and E.C.
Jordan. All RI work performed by these contractors was executed only
after work plan documents were reviewed and approved by MDNR and
U.S. EPA. The planning documents for all RI tasks performed are in the
site Administrative Record. In review of these documents, \J.S. EPA and
MONR assured the sampling and analysis procedures used at the site were
adequate to build a comparable data base for the site. Although different
contractor personnel were used for the LDI RI, careful quality control of
their work was exercised by U.S. EPA and MONR. Any contractor work
deemed inadequate by MONR or U.S. EPA was not used in the final RI Report
or for remedy selection.
The draft RI'RepQrt prepared by GMC was considered incomplete by MONR and
U.S. EPA. Furthermore, portions of the GMC RI work w~re deemed inadequate
by U.S. EPA. These portions of the C1MC work were not" considered in the
LDI remedy selection process. Portions of theGMC RI work considered
acceptable are incorporated in the &.e~ JOrdan RI Report. Comments
raised on the GMC draft RI Report are not ,addressed in this Responsiveness;
SUl!lTlary. Responses are provided only on cOl!lT1ents on the final RI t which'
..
includes useful information ge,~rated py GMC.
The LOI RI established releases of site contaminants to the ground water
and soils. 50i1 contamination was documented with comparison of on- and
off-site soil samples to established background soil conditions. Rackground
soil conditions were determined as described on pages 6-21 and 6-22 of
the E.C. Jordan RI Report. Concentrations of contaminants in on-site
soil were found in a complex distribution. However, on-site soil
contamination distribution was usually indicative of activities that
took place at those locations (page 6-96 of the RI Report). Off-site
soil contamination was documented and was found in off-site areas that
would appear to intercept off-site contamination, based on surface runoff
patterns, ground water flow and discharge patterns, and direction of
prevailing winds (for airborne contaminated soil particles). (Page 6-98
of,the RI Report).
Releases of contaminants from LOI to the ground water were established
as described on page 6-101 of the RI Report. Background ground water
quality (unaffected by any potential sources) could not be established
due to the potential contributiuon from sources surrounding the site.
The other potential sources were not quantiified since it was outside
the scope of the RI. The actual level of ground water remediation
will consider (and not provide a greater degree of remediation than),
the ground water quality upgradient of LOI considering such Ubackground"
(upgradient) wells as 2s, 5s, and 13s, which are affected by contamination
fro~ sources other than LOI.
The quality of the data in the final LOI RI was assured by use of
!J.S. EPA contract laboratory program (CLP) including specified protocol
- for saMple collection, tracking, and analysis, and data audits. The RI
samples were collected and tracked as prescribed in the RI planning
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-8-
documents. Samples were analyzed by different laboratories, all of
which are in the U.S. EPA CLP. Laboratories in the U.S. EPA CLP have
been approved for use by U.S. EPA and provide specified sample analyses
per approved U.S. EPA protocol. Laboratories in the CLP are required
to provide rigorous quality control/quality assurance checks on the
data they produce. The different laboratories in the CLP provide U.S.
EPA with high quality, comparable data.
All LOI RI sampling data was audited with established U.S. EPA protocol
for data evaluation, with one exception to this established protocol.
Sample data with common laboratory blank contaminants was evaluated as
described in comment 18 above, and as described on page 6-5 of the RI
Report. U.S. EPA considers this method reasonable for the LOI RI.
Data generated by GHC was audited by GMC. If the data was determined
unusable by ,the GMCaudit, it was not used. If the data was determined
useable without qualification by GMC it was used. If the data was
determined usable with qualification by GMC it was ~~~reviewed by E.C.
Jordan. All sampling data generated by MDNR and E&E'was reviewed by
E.C. Jordan. tlse of the specified EPA protocol" for data review (with
the above-mentioned exception) assu~eq tha~ the data audit process was
consistently applied by MDNR consultants., All review sheets from the
performed data audits are incTud.d in the'LOI Administrative Record.
U.S. EPA maintains that all d~~ta used..y.n the LDI RI are valid data.
As described on page 2-3 of the RI, all data generated during the RI was
conducted by laboratories in the U.S. EPA Contract Laboratory Program
and was validated according to specified U.S. EPA protocol. Historical
data generated previous to the RI, are the only data presented in the
RI Report not validated.
..
Contrary to PRP comment, the rationale for the chemical groupings of
organic chemicals detected at LOI, is presented on page 6-2 of the RI.
The chemical groupings' were established by an analysis of the organic
chemical structure in relation to potential adsorption. The grouping
presented by Hart (page 12 of their "Review of the GMC Associates and
E.C. Jordan Draft and Final Remedial Investigation Reports'.) do not
coincide with the grouping in the E.C. Jordan RI because the ~art
groupings were based solely on Koc values.
There is a voluminous amount of RI data that have been collected since
RI field work commenced in April 1984. A phased approach for the
hydrogeologic i'nvestigation was performed.. Ground water monitoring
well data is available from seven discrete sampling events (May 1984,
June 1984, November 1984, December 1984, April 1985, November 1985, and
February 1986). (See page 6-68 of the RI.) The data base has been es-
tablished over nearly two complete years. Although one complete round
of sampling from all wells for all parameters has not been performed,
U~S. EPA believes that the existing data adequately characterize ground
water quality in the upper aquifer on-site and off-site.
. ~ ,~. . - -'., --- -. -- - ........--
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-9-
RI field activities have also included numerol/S soil safTIples. Hand auger
borings, with fTlultiple safTIples per boring, were conducted at numerous
locations on- and off-site. Deep profile borings were also conducted
on-site. U.S. EPA also believes that the nature and extent of contami-
nation has. been adequately defined by this sampling for the purpose of
remedial alternative selection.
Regarding the RI Report figures, U.S. EPA believes that their quality was
more than adequate to present the data in an organized and meaningful
way. In reference to Figure 6-5, which shows two locations labeled
8-112. the figure is in error. The B-112 boring designation in the
incinerator pit is the correct designation. The R-112 boring designation
immediately south of the waste oil lagoon is incorrect. This designation
should be deleted from Figure 6-5, as it does not represent anything.
Examination of the geologic cross section C-C' on Figure 6-7 illustrates
proper use of the correct R-112 boring. The incorrect 8-112 designation
was not used in the RI Report for any data interpretation. .
U.S. EPA acknowledges that the 645 foot contour line on Figure 6-33 has
been misaligned. However, this error does not affect arty of the concllJ-
sions in either the RI Report or the FS. The: estimated" head in the
production well used in Figure 6-34 was based onp.rofessional judgment.
U.s. EPA maintains that the variability of ~he data from the LDI RI
reflects the site conditions from'l~cation tb location and with time.
Lack of a clearly distinct pattey:n, of so..11s contamination is expected
at a site like LDI. The incineration, gravel excavation. and landfilling
activities that took place while the site was active. as well as
significant manipulations of the site in the subsequent removal
activities. account for the random distribution of contaminants at the
site. A significant amount of good quality data were collected in the
LOI RI. The RI adequately characterized the site.
. .
..
Issue: The Steering Committee. their technical consultant, and other PRPs
commented that the Endangerment Assessment (EA) in the RI report fails
to properly evaluate the risks posed by the site. They also commented
that the EA used unrealistic assumptions to establish the risk posed by
the site. and/or methods used in the EA were incorrect.
Comments:
1. The assumption of future human ingestion of downgradient groundwater
is improper to assess the risks posed by site contaminants. State and
local law would preclude the installation of a supply well downgradient
of the site. It is unrealistic, arbitrary anQ capricious to assume that
there may be future human receptors.
2. Maximum Contaminant Levels (MCLs) and cancer advisories are inapplicable
and/or inappropriate to downgradient groundwater.
3. The aquifer downgradient of the site would be classified as Class III
by U.S. EPA. and therefore drinking water standards are neither applicable
nor relevant and appropriate.
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-10-
4. The EA is not adequate because it did not consider environmental fate
and transport. Specifically, the EA ignored factors such as dispersion,
adsorption, volatilization, biodegradation, chemical degradation, and
travel time of groundwater contaminants.
5. The EA ignored typical or normal range of background levels for
organic and inorganic chemicals in the soils.
6. The EA does not address whether off-site surface soil contamination
is' from sources other than LDI.
7. The assumption of the number and frequency of children and adults
entering the site, and offsite exposure in the nature area is unrealistic.
8. The EA does not address land use limitations in the area; specifically,
the potential for ho~es being built in the floodplain or wetlands is not
addressed.
9. The EA does not consider other potential ,sources of stressed vegetation
off-site. , -,
10. The assumption of future ingesti~~~of downgradient groundwater is
not appropriate since the upper aquifer has~been classified as unusable
by the Macomb C01Jnty Hea 1 th Department... .
, .'
11. The EA did not follow the procedures in the Superfund Public Health
Evaluation Manual.
'-~. :.
..
12. Phenol, methylene chloride, 2-butanone, and toluene should not have
been included as indicator cheMicals.
13. The validity of the data presented in some EA tables cannot be
determined.
14. The source of data for the assumption of future groundwater ingestion
is not noted. Therefore. the validity of these concentrations for use in
the EA cannot be determined.
15. The EA uses data with estimated concentrations to calculate exposure
to indicator chemicals. The use of estimated values is not authorized by
the Superfund Public Health Evaluation Manual and contravenes accepted
scientific methodology.
Response:
Contrary to the Steering Committee and PRP corrments. !J.S. EPA would not
classify the shallow aquifer as a Class III aquifer. Contaminants from
the LDI site have been released to the shallow aquifer. making it
unacceptable for drinking water use. Without contamination from the LDI
site, water from the aquifer could be potable. The EA therefore illustrated
the impact of site contaminants to the shallow aquifer with a scenario in
which humans drink the contaminated ground water. Since the aquifer
would be usable if not contaminated by the LDI site. such an ingestion
scenario is an appropriate means to evaluate human health and environmental
" .":'. \..:... """..;.~.'.:~~!:: ;:.~';:;'.:;..,~.;. :': ..:,;-t.'~"-;."" .;;" :: ~::..:-;~,'.~ ..'!~ ~~.-;,;-,;,- ..":'~ - ~;.;..::,~:;:';.~ ::;,--.~-.. :;'.:.-~':'~.~"~r ..~-' ..~. ~;.....~.....' ."!<....-, ':.~T.~';~';:.~ :-.. '.t. -:;;':'i.-.'"""-,,
:-j.~';'.. :':.~-"'7;'~-. -~~. "'::;":~:::.~::: :i~-"~~~"~~' ;..: :,~ : ...~,.,' .:"'" .';.-r,"'; '-~.' ',.. ..: ...'
. "'"'. ~.' +'.-... ''''. ',' ...
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-11-
risks posed by the site.
unacceptable risks.
This scenario illustrated that the site posed
In determining an appropriate cleanup action for ground water at LDI, U.~.
EPA has selected a remedial action consistent with the direction given in
Sections 104 and 121 of CERClA as amended by SARA. The selected ground-
water remedy provides adequate protection of public health, welfare and
the environment. Cleanup levels were chosen based on a risk calculation
consistent with the procedure outlined in the Superfund Public Health
Evaluation Manual (Page 50 of the FS). The ground water cleanup levels
were chosen to assure adequate protection of public health and the
environment.
According to 40 CFR 264 Subpart F, when there is a release of hazardous
waste from a facility, U.S. EPA is authorized under Subtitle C of RCRA
to require cleanup of that ground water to background, MCls (if greater
than background), or Alternate Concentration limits. If background
concentrations are greater than other ARARs, the clean up levels for
those particular constituents are the background levels.
Furthermore, the selected ground water remedial action is one in which the
mobility, toxicity, and volume of the hazardous substa~2es is pernanently
and significantly reduced. Such treatment r-emedi.es are preferred over
those remedial actions not involving t~eatment (Section 121).
-,
The EA provided an adequate analysts Qf site conditions and an adequate
measure of threat to public healtiias a result of site conditions in the
absence of remedial action. Thi~'i~for~a~ion was "adequate to develop
and evaluate "reMedial alternatives.themical transport and transforma-
tion pathways of contaminants are discussed in Section 7.4 of the RI.
Factors such as adsorption, degradation, and chemical reaction for
organic contaminants were qualitatively discussed~and travel time of
groundwater contaminants was quantitatively discussed [Tables 7-3 and 7-4).
Adsorption and fixation considerations for inorganic contaminants are
presented on page 7-17 in the RI Report. The scenario was appropriate for
evaluating inpacts of the site to human health and the environMent, and
was useful in developing and evaluating remedial alternatives. The
exposure scenarios used in the EA were developed based on the present
contaminant concentrations in both onsite and offsite downgradient
groundwater. The present conditions were assumed to reflect the
concentrations which have been detected in ground water already off site,
based on someone ingesting these waters. The future conditions reflect
existing conditions beneath the site which are likely to migrate offsite
in the future without remedial measures being taken. Since we cannot
know whether the concentration of chemicals in the contaminated plumes
are adequately reflected by the existing monitoring well data, it is
not an unreasonable assumption to look at th~ concentrations currently
under the site and assume these could represent future concentrations
migrating offsite. When representing worst case conditions, looking at
the highest existing concentrations is not necessarily incorrect or
inappropriate.
The EA was done as directed by the Superfund Pub1i.c Health Evaluation
Manual (SPHEM). Chapter 7 of the RI and Chapters 1, 2, and 3 of the FS
present the baseline public health evaluation and the remedial alternatives
perfonmance goals, respectively.
Indicator compounds were chosen based on the four step process outlined
on pages 7-2 and 7-3 of the RI. While it is true that the EA did not utilize
..
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-12-
the worksheets provided in the SPHEM to quantitatively score the inrlicator
chemicals. professional judgeMent. based on knowledge of the chemicals'
physical/chemical characteristics. relative toxicities. concentration de-
tected in various media. and representation of various approximate mobility
categorizations were used to identify the indicator chemicals. The selection
process for indicator chemicals as outlined in the SPHEM is a general guide-
line which considers these same characteristics and allows one to assign a
quantitative score to the chemicals found at a particular site. This process
is consistent with the guidance provided in the SPHEM. and resulted in the
inclusion of phenol. methylene chloride. 2-butanone and toluene as four of
the chemicals of concern or indicator chemicals at the LOI site.
All of the data that were used in the LOI EA were determined to be acceptahle
for use. A portion of the acceptable data was qualified as estimated
because it did not entirely meet all of the rigorous quality assurance
and quality control requirements of the U.S. EPA Contract Laboratory
Program. The specific reasons for qualifying the data are documented in
the LOI administrative record and was considered before datawe're used.
The SPHEM does:not preclude the use of acceptable estimated data.
The purpose of the LnI RI and EA was to detenmine the nature and extent of
contamination at the site and to define the public health and environmental
hazards posed by the site (p. 2-3 of the RI). Hazards from the LOI site
have been determined to exist due to co~tamination from the site that has
remained within the property boun~aries. and contamination from the site
that has migrated off the property boundaries. Although it is recognized
t~roughout the RI report that oth.r pot~ntial sources of environmental
contamination exist near the lOI site. the LOI RI and EA did not quantify,
and evaluate these other sources. Such an exercise was not within the
scope of the LOI RI and EA and was not ,necessary to evaluate remedial
actions for the site. However. background soil contamination and upgradient
ground water quality was quantitatively assessed.
.'
~
A proper quantification of the LDI contaminant contribution to the environment
(groundwater and soil) was done by comparing contaminant concentrations
in the groundwater and soil unaffected by the site ("background") to
contaminant concentrations in groundwater and soil affected by the site.
When apparent. contaminant contributions from other sources were identified.
Likely transport mechanisms of contamination from the LOI site were also
presented in the RI and EA.
To determine background soil concentrations. soil samples were drilled in
areas suspected to be unaffected by the site and analyzed for organic and
inorganic constituents (p. 6-21 and 6-22 of RI). Information was gathered
concerning common concentration ranges for inorganic constituents of
natural soils and established extreme ranges for inorganic constituents
in natural soils (p. 6-22 of RI). It was also determined in the RI,
through the examination of hand auger sampling results, that background
levels of naturally occurring organic chemicals were very low (page 7-18
of RI).
These background soil concentrations were compared to analyses of soil
from onsite and offsite soils likely affected by the LOI site. Such
comparison helped determine a release from the site. The data were also
. . """': :.~.; .: ":..Z~.:i:-~ ~';" :-:~.;.~:'~:~7';:; :"~-,:~'-.--=.:;-~....~-::.~-. ';~;';;;:.:-:~~.;'~-::,.:. -::~.: ~-~~:_,::~; .:~:; »,: ~:~.~"..,~:''';;::'~.;~~.:~ ~:- .':.::": ::';:r~"." .~:'.:<:~:::: ::', ~..:..~-.:-~.:~ --. -:.....-::.~~'.:::;:;..: '... :..::~- -:;...:.: ...-.~::~:::-.~:.~-':~~- ..~.'- ..::_---
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-13-
evaluated in light of site usage and transport of contaminants from the
site. Although onsite soil contamination was very complex, the chemicals
found at specific locations were usually indicative of activities that
took place at those locations (pages 6-96 and 6-98 of the RI). Offsite
so1.1 contamination was found in areas likely affected by LOI due to
transport mechanisms such as surface runoff, deposition of airborne
contaminated soil particles (incinerator discharge) and groundwater
seepage (pages 6-98 and 7-19 of the RI).
To determine contaminant contribution from the LOI site to the groundwater,
background groundwater quality was cOl'1pared to downgradient groundwater quality
in the shallow aquifer. The RI hydrogeologic investigation established
groundwater flOW directions and rates in the site vicinity. The background
groundwater ana lyses suggest that upgradi ent groundwate".. contami nat i on
sources do exist (p. 6-101 of RI). Much infor.mation does, however,
establish that LDI is contributing to shallow groundwater contamination.
That information includes: 1) concent~ations are higher in downgradient
wells than upgradient wells; 2) the wells with the poorest water quality
are directly downgradient from, and.;n. close'. proximity to, LDI; 3) there
is a significant increase in thery~mber of chemicals from upgradient to
downgradient wells (page 6-101 6fRI).~ a~d 4) the chemicals found
downgradient from LDI.are also found, to serious degrees, in the sub-
surface material at L~I.
~
While it is the opinion of the PRP Steering Committee and their consultants
that the exposure scenarios presented in the LOI Endangerment Assessment
are unrealistic, the U.S. EPA I'1aintains that such scenarios were appropriate
for the LDI site specific evaluation of the no action alternative or
baseline risk assessment. Consistent with the U.S. EPA approach to
EAs, the baseline risk assessment was done assuming no corrective action
and no restrictions for future use of the site. Current site usage and
surrounding populations and area usages were carefully considered (page
7-35 of RI) by the U.S. EPA in the configuration of the LOI EA exposure
scenarios. .
Although the PRP Steering Committee maintains that types of institutional
controls are adequate to protect public health, U.S. EPA maintains that such
means are not necessarily protective. Although the State or local government
. may have some type of "institutional control".to discou~age parties from
installing a water supply well, we are not convinced that institutional
controls are perManently enforceable. More often than not, we must
depend on town planning officials or water department officials to discourage
well drilling. Even if Macomb County classified the aquifer as unusable,
the contamination from the LDI site must be addressed. Section 121 of
SARA states that remedial actions that permanently reduce the mObility,
toxicity or volume of contaminants are preferred over those that do not,
i.e., those that rely on institutional controls. We are also required to
meet ARARs.
The shallow aquifer has not been classified as unpotablp. by the '.'acomb County
Health Department. This-COmment by the Steering Committee appears to be a
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-14-
misinterpretation of the RI Report, which stated that the upper aquifer was
not protected, and ground water in the bedrock aquifer has been reported to
be salty. : In fact, it is known that the upper aquifer is currently used by
some residents in Shelby Township.
According to 40 CFR 264 Subpart F, when ther is a release of hazardous waste
from a facility, U.S. EPA is authorized under Subtitle C of RCRA"to
require cleanup of that groundwater to the appropriate levels as defined
in Part 264.94. In addition, specific U.S. EPA pOlicy in Region V is not to
waive RCRA requirements solely because ther are no current or projected plans
or intentions to use the aquifer as a source of drinking water.
The assumptions used in the EA about the population exposed to contaminants
at the site are reasonable yet conservative estimates. These assumptions
were determined based on best professional judgement, knowledge about the
site, and the U.S. EPA Public Health Evaluation Manual. The baseline study
is an analysis.of site conditions in the absence of remedial action. The
fact that a flood plain or wetland presently exists near-the site, although
hopefully considered, does not preclude people from bu~Tding in such an
area. The baseline analysis does not attempt ~o _~bsolutely define or
predict the numbers of people exposed. - " ""
.-
The stressed vegetation was properly discussed on page 7-49 of the RI.
The clear connection between LOI1eachage seep north of the site and the
stressed vegetation is presented~~ The reason for stressed vegetation NE
of LOI is less clearly due to site conditions. Chemicals from the LOI
site, runoff containing road salt or oil, and changes in the wetland water
levels, are presented as potential causes for the stress.
..
Issue: The Steering Committee submitted an Endangerment Assessment (EA),
prepared by Fred C. Hart Associates Inc. (Hart), for the Liquid nisposal,
Inc. site.
Response:
The Agency is not obligated to review and comment on the Hart EA, but only
to respond to comments on the Agency EA. However, the Agency did review the
Hart EA, and because of significant differences in the conclusions of the
two, is providing comments regarding inadequacies in the Hart EA.
The authors attempted to follow guidance presented in U.S. EPA's
Superfund Public Health Evaluation Manual (SPHEM); however, several
inconsistencies and omissions are noted which materially affect
conclusions drawn in the document.
1. Data Base for the EA. The authors reported that they used only
data validated by their own QA/QC audit. Reported maximum concentra-
tions for various contaminants differ from those in the Remedial
Investigation (RI) report prepared by E.C. Jordan. Hart did not use
data flagged with "J" or estimated values. Nothing in the SPHEM or
U.S. EPA guidance directs the PHE preparer to disregard estimated data.
. ... I. .. J'~'i..~": ,J;'':' ",_";E".i::.~ '::s~'~;~:;;..-;,~ .i~7"'.;.;.";'i''..:' ::'.- L .:.: :"a':'.~: _::..: ;-.;~:~. ::':'. .-','" .'.::~''- ...;~;. :.,~ .:.;... --': ":''*' "..'. ~ ..:.:-;;: .::..: -;. ~.._~~:":':.~..::.-:'.~-~~ :-::::, :'::':"'::-'~.: ::~:~'~.:.:::-: :..';~...~: ':....:;7: ':. : ;: = ,:,-: '-'.. ~.~'. a ... -:.;. ,... ....~- :. .:...~~ ~..: -;- ~.,:.:. -~: :'~. ..' . .
-------
-15-
In another section of the docUMent (p. 25), groundwater results are
summarized using only data generated when all monitoring wells were
sampled. No clear rationale is presented as to why other data cannot
be utilized as representative of maximun and average concentrations.
A worst case scenario, inherent in the PHE process, cannot be calculated
by arbitrarily eliminating data; nor can risks associated with short-term
exposure to contaminants at their highest calculated concentrations be
properly evaluated, if data are omitted~
2. Indicator Chemical Selection. Hart presented a data table (Table
2-3) that summarized the indicator chemical selection process outlined
in the SPHEM. Worksheets 3-2 through 3-4 from which the summary table
was prepared are not part of the document and should be. We cannot
comment on the acceptability of the chosen indicator chemicals without
them. Indicator chemicals, by their very nature, understate overall
risk because not every chemical present on the site is evaluated.
Incorrect selection of indicator chemicals can further magnify ~his
problem.
.'
3. Exposure Pathways. This is the least complete se~tion of the EA.
There is no attempt by the authors to integrate_~ite history and
disposal operations into possible eXP9stlre pathways. The exposure
pathways are overly simplified; e.g/, .the term "Direct Contact" in
the context of contaminated soils. is. not defined. One cannot determine
if the term refers to dermal absorption and direct ingestion versus
dermal absorption alone. The o:irexp'G6~re pathway is similarly vague.
One cannot determine if the.pathway"'describes only on-site conditions,
or both on and off-site conditions. Hart's review of the site has
ignored the fact that the subsoils will continue to he a $ource of
leaching contaminants to the ground water, which will allow the
additional ~igration of contaminants from the LOI site.
, .
..
The most significant deficiency is the elimination of the groundwater
pathway. The authors eliminate this pathway by citing the existence
of institutional controls. This argument overlooks potential future
uses or a worst case scenario. The U.S. EPA's Groundwater Protection
Strategy regarding Class III aquifers is also cited as a reason the
aquifer will never be used as a drinking water source. This statement
made here and repeated often in the document is in error and demonstrates
complete misunderstanding of the groundwater strategy. An aquifer'
is not classified either upgradient or downgradient of any source,
but is classified instead on naturally occurring background parameters,
such as total dissolved solids. Clearly there are upgradient users of
the aquifer as reported on page 53 of the docu~nt. A more probable
classification of the aquifer is, therefore, Class 2A ~ current use
but not a sole source drinking water aquifer. The aut~ors fail to
note that the probable source of the high concentrations of total
dissolved solids is the LDI site. Hart's emphasis on institutional
controls precluding placement of downgradient drinking water wells
ignores their own assessment that chemicals of concern
have migrated offsite and interact with the atmosphere both at the
base o'f the hill downgradient from LDI and with surface water in the
Clinton River. Both mechanisms provide unacceptable cross-media
transfer of contaminants from the site, which was not considered by
Hart.
-------
-16-
4. Surface Water Model. The surface water model was well developed
in the document. However, Hartis reliance on analysis results from
MW4M as the only possible contaminants downgradient of the site is
flawed. We cannot depend upon results from just one point downgradient
from an unpredictable contaminant source such as a landfill/hazardous
waste disposal facility. Also, Table 3-3 inappropriately compares
model results with drinking water standards. The appropriate standards
would be Ambient Water Quality Criteria.
5. Calculations of Body Dose Levels. Table 3-4 presents the
parameters and assumptions used to calculate body dose levels.
U.S. EPA notes the following differences in assumptions from the
PHE prepared by E.C. Jordan:
a. Contaminants in off-site soils south of the site were elimlnated
because they were .attributed to auto salvage yard operations.
."
b. Frequency of exposure was reduced for both child and adult in
both the most probable and realistic worst.casestenarios although
the durati on of exposure was 1 onger. ~. -'",
c. The skin surface area for chfldreh and ~dults in contact with
contami nants is reduced, yi e 1 di~9' much" Jess amounts of soil
absorbed. No rationale is prese-nted-.for this variable by the
authors and there is no guidance for it in the U.S. EPA Exposure
Assessment Manual. .
..
6'. Risk Characterization. The authors have multipl ied "each exposure
point concentration by 0.15, severely reducing doses based on an
unsupported reference (Hawley, 1985). This is not U.S. EPA guidance
nor is it found anywhere in the SPHEM or Exposure-Assessment Manual.
Soil matrix effects, which the reference cites, are already considered
by using specific skin absorption rates for different classes of chemicals.
It is extremely unlikely that a board certified toxicologist would
make such an assumption for every type of contaminant at the site.
7. Risk" Management. No such section belongs in the EA or PHE.
Instead, efforts should be concentrated on assessing the human and
environmental impacts of the site.
In summary, the Fred C. Hart, Inc. EA is flawed. While some sections
follow U. S. EPA guidance, other sections do. not, are incomplete, are
missing or go beyond the scope of a public health evaluation. The
E.C. Jordan EA remains an acceptable characterization of the risk
posed by the LOI site.
Issue: The Steering Committee commented that there ;s no definition of a
permiUtent remedy in CERCLA as amended, and that in-situ containment is a
permanent remedy, and preferable to soil solidification.
-.....------_._-_.__.._~,... ~ -_..~.-.. ~ -
. ... - - --- ~. -. - .
-n""_"-r-' --."--:""-----' -- _..
-------
-17-
COl1lnents: .
1. The soil solidification process is undefinerl. therefore. the preference
for solidification is arbitrary and capricious.
2.
The only choice supported by the record is soil contain~ent.
3. . In-situ containment is a permanent re~edy since it significantly
reduces the mobility of any contaminants at the site.
Response:
The soil soldification process is described in the FS. Containment using
only a cap is not protective. since contaminants in soil and/or.ground
water will still be able to migrate off-site. Also. such an alterative
does not meet the preferences for treatment or permanence~ and only
reduces the mobility of soil contaminants. Solirlification agents such as
pozzalan. fly ash. and proprietary additives.were_discussed. During
remedial design. bench scale and/or pilot tests will be performed to
determine the best type(s) of solidification/fixation agent to use for
the LOI site.
. ..
. .
The preference for solidificatiol'!:~fs rtot,'arbitrary and capricious since
CERCLA as amended by SARA. prefers remedies utilizing treatment to
permanently and significantly reduce mobility. toxicity or volume of the
contaminants to the ~aximu~ extent practicable. and directs that in .
assessing alternatives. the potential for future remedial action costs
be evaluated if the alternative in question were to fail.
The selected alternative is not considered permanent because hazardous
substances will remain at the site. By the same token. containment alone
would not be considered permanent. However. the selected alternative is
more protective. and more preferable. than containment alone because it
will reduce both the ~obility and toxicity of the contaminants. versus
only mobility when containment is used alone. Additionally. although
slurry wall containment is considered a proven technology. long term
effects of untreated hazardous substances on the slurry wall are not
know~. Therefore. a greater potential for future remedial action costs
exists if containment is used without treatment of the contaminants.
Issue:
Ground water treatment and discharge
COOIIIent s:
1. The decision to include onsite groundwater treatment in all the
alternatives is inappropriate as the Agency failed to adequately consider
the availability ofoa publicly owned treatment works (POTW) system to
treat the groundwater.
2. One representative of an environmental organization requested that
groundwater discharge not be to the Clinton River.
~
-------
-18-
Response:
Discharge to a POTW was mentioned as an option on page 3 of the FS
Executive Summary. The FS developed cost estimates for discharge to the
Clinton River since a higher level of treatment (and thus a more detailed
analysis) was assumed to be required for a river discharge. U.S. EPA
b~lieves that discharge to a POTW may be a viable alternative. Therefore.
this option will be further evaluated during the remedial design phase
of the project. The requirements of the Detroit Water and Sewerage
Oepartment for discharge of water to the municipal system will be met if
their POTW is used. Nevertheless. the on-site treatment options examined
in the FS are still appropriate since the POTW would require pretreatment
prior to accepting discharged ground water. .
The discharge 'of treated groundwater to the Clinton River if chosen must
also meet the substantive requirements of the National ~ollution Discharge
Elimination Systems (NPDES) program establis~ed under the Clean Water Act
(CWA). These limitations were created to restor~.and maintain the chemical.
physical. and biological integrity of. t.he nation's waters. The water
must be treated using the best availibJ~technology (BAT) and/or must not
exceed water quality based standards. We fully expect that the treatment - ,
technology will be adequate to remove co~taminants from the water so as ~
not to exceed these limits. Th~'trea~ed water will be monitored to
assure removal of contaminants of cancern.
. .
Issue: The PRPs commented that the statutory provisions and agency remedy
selection procedures have resulted in denial of the PRP's right to due
process under the law.
Comments:
1. U.S. EPA proceedings provide no avenues for PRPs to be heard on the
administrative record. except for an opportunity granted the general
public at large. to submit written statements to U.S. EPA and attend a
public meeting prior to the final decision.
2. U.S. EPA has failed to submit to PRPs sufficient information necessary
for them to provide comments in a meaningful and timely manner before remedy
selection.
3. The only portion of the Administrative R~cord made.available to the
PRPs is the draft RIfFS, the RI/FS and the U.S. EPA Proposed Plan.
4. The PRPs have sent a Freedom of Information Act request for all
information in the administrative record but have not been provided all
of the information.
,. . ," ~:..:; ~;,:~~~-::;~~:'~:.:~-~;";:~' ~::;:_'.':~; ~k:::"-'~:"': .':~ :.;;:~"; :~~ - .,---::::.;-~': .::;:~::~ . ~:'.,;o- ":'~". ~. ~"~'" '1:. ~,'.: ..." ."" ....~~" . .:. ~...:. :.. ....' . "... '.: ..
-------
-19-
5. For the PRPs to be afforded the opportuni ty to be heard at a meani ngful
time and in a meaningful manner, the PRPs must be given the opportunity
to: a) review all evidence and data collected by U.S. EPA in its decision-
making process; b) submit independent documentary and oral evidence;
c) depose and examine government witnesses involved in remedy selection
procedures and studies; and d) present oral and written arguments to a
neutral and detached decision maker.
6. The PRPs contend they have not been able to have an expert observe
the drilling, development and installation of monitoring wells and
collection of groundwater and soil samples.
7. The short comment period will neither allow PRPs sufficient time to
perform their own studies and analysis, nor to submit independent..evidence.
Response:
.-
U.S. EPA procedures allow all members of the public the opportunity to be
heard via the Administrative Record. Section 117" of CERCLA requires U.S.
EPA to provide for public participation... '.The PRPs, as members of the
public, are afforded the same opportunity to cOmment at the public meeting
and to submit written canments as the rest of -the public. However,
CERCLA also provides PRPs with addHiona} opportunities to negotiate with
U.S. EPA regarding the private undertaking or the financing of the remedial
action selected by U.S. _EPA after consideration of public comments. The
negotiation procedures a-re detailed in Section 122 of CERCLA.
~
U.S. EPA has responded to approximately one hundred (100) Freedom of
Information Act (FOIA) requests from PRPs and their insurers regarding the
LDI site. Moreover, U.S. EPA and MDNR have provided one representative
of the PRP Steering Committee with all non-privileged technical data
related to the RIfFS. Also, in September 1987, U.S. EPA placed the
Administrative Record in the repository at the Shelby Township Library
for public review. The Administrative Record contains approximately one
hundred fifty documents, and, as stated above, the PRPs were provided
previously with RIfFS documents.
The procedures provided in CERCLA, and followed by U.S. EPA regarding
LDI, do provide PRPs with due process under the law and a meaningful
opportunity to participate in the remedy selection process. The PRPs are
provided with the opportunity to participate in the building of the
-Administrative Record, upon which the remedial action is selected and
. judicial review will be based. Section 113(k)(2)(B) of CERCLA provides
that such participation is to include, at a minimum, the following:
(1)
Notice to potentially affected persons and the public which
shall be accompanied by a brief analysis of the plan and
alternative plans that were considered;
A reasonable opportunity to comment and provide information
regarding the plan;
(i 1)
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-20-
(~i~) An opportunity for a public meet~ng ~n the affected area,
in accordance w~th Sect~on ll7(a)(2) (relating to public
part~cipation);
( ~ v)
A response to each of the significant comments, criticisms,
and new data submitted in wr~tten or oral presentations; and,
(v)
A statement of the basis and purpose of the selected action.
u.s. EPA has followed each of these procedures which afford the public and
thus the PRPs, with a meaningful opportunity to participate ~n the decision
making process.
Moreover, ~1l3(k)(2)(e) provides that the development of an Admi'n~strat~ve
Record and the selection of response act~on under CERCLA shall not'include
an adjud~catory hearing, and the procedures of 113(k)(2)(b) outlined above
do not ~ ncl ude the r'~ ght to depose government witnesses~ 0.'
The PRPs have had the opportunity to observe a substantial amount of the
field work at LOI, includ~ng observat~on..of drilling act~vities performed
by Ecology and Env~ronment. The following personnel from Fred C. Hart
Assoc~ ates have observed fiel d work.. conducted".by MONR/U.S. EPA:
..
1. Mr. Triolo
2. Matthew Brill
3. Jim Braun
4. Vanessa OeVillez
12/19/85 .~': .
1/15 -1/17/86'
. 1/21 - 1/22/86 and 1/27 -
1/22 - 1/24/86
1/31/86
As stated above in Sect~on 2, U.S. EPA originally provided the pUblic
with a 2l-day public comment period, which is the length of time required
by the NCP. However, in response to PRP's requests for additional t~me for
public comment and to site specific circumstances, U.S. EPA, on September 2,
1987, extended the period to an amount beyond that required by the NCP.
Comment was extended from 21 to 30 days, with the period thus ending on
September 18, 1987.
Issue: The PRPs assert that U.S. EPA, in its remedy selection process, has
failed to follow current statutory procedures for the selection of a remedy.
Comments:
"I. U.S. EPA has not followed the procedures fQr public participation
. which are found at ~113(k)(2)(B) (i)-(v) cited above, particulary by
announcing the proposed plan without significant input from anyone but
its contractors and employees.
2. The PRPs assert that denial of access to the decision making process
is contrary to U.S. EPA policy on public participation.
3. The PRPs request an additional public comment period and technical
exchanges between U.S. EPA and PRPs.
4.
The time period for public comment is wholly inadequate and unreasonable.
.-. -_..-~.."..7'--' '----""j-"..'-"""".'----,
.. .'-."'. - -' ...,'. .....:' {. ..: .;'....., ..." ';..' 'I !~. ---.. '.- .". '..-- .1: . .~, ~'.' ,"r... ...., .. .
_.~ ';-, ~ . .... .
. .-r.--<~ --. ._-.- -
.- ..- - . -.
..,.,. "
... ." ..' ,~ . '.. ..- ,", -..'
-------
-21-
~sponse :
U.S. EPA has provided the PRPs with all the procedures specified for
public participation in 9113(k)(2)(B)(i)-(v), and in so doing has afforded
the PRPs witt1 an opportunity to participate in the decision making process.
Specifically, on August 19, 1987, U.S. EPA provided the PRPs, as members
of the public, with notice of the proposed plan and alternatives considered.
In fact, to hasten PRP receipt of the FS report, U.S. EPA sent the PRPs'
contractor a copy of the report by overnight mail on August 19, 1987.
U.S. EPA provided the PRPs with an analysis of the proposed plan in a
written submittal received by the PRPs in August 1987, in oral presentations
at a'pub1ic meeting held August 27,1987, and at a meeting of U.S. EPA
and PRPs on September 8, 1987.
U.S. EPA has provided the PRPs with a reasonable opportunity to comment
and provide information regarding the proposed plan in a 30-day public
comment period. As stated above, the public comment period was originally
to be 21 days, the length specified in the NCP. However, in response to
PRP requests and site specific circumstances, U.S. EPA extended the
public comment period to 30 days, with the period thus closing on
September 18, 1987. 'An additional period of time beyoncLthe extension
already granted is not feasible because of U.S..EPA and MDNR's mutual
desire to begin remediation of LDI as soon as practi-cab1e, and Congress'
desire to expedite cleanups, as evidenc~..by the cleanup schedules of
Section 116 of CERCLA. U.S. EPA held a public meeting regarding the
Feasibility Study and the proposed plan on Aug'ust 27,1987.
This document includes U.S. EPA re~ponses to each of the significant
comments, criticisms and new data submitted in the public comment period.
The statement of the basis and purpose of the selected remedial action is
included in the Record of Decision. Thus, U.S. EPA has complied with all
requirements for public participation [9113(k)(2)(B)J. Regarding technical
exchanges between the PRPs and U.S. EPA, U.S. EPA is willing to discuss
the Record of Decision, and design and implementation of the remedial
action with the PRPs and their technical consultants.
~
Contrary to their assetion, the PRPsare afforded an opportunity to
participate in the decis~on-making process when U.S. EPA announces the
proposed plan prior to formal public comment. The decision-making process
is not completed at the time of announcement of the proposed plan.
Rather, announcement of the proposed plan signals the initiation of a
significant phase in the decision making process, that of public comment,
to be followed by U.S. EPA consideration of. and response to, those comments.
Regarding LDI, the decision on remedy selection has been made only after
soliciting comments from PRPs and other members of the public, and after
. . considering such comments.
Moreover. involvement of the PRPs in the decision-making process at the
time of public comment is wholly consistent with U.S. EPA policy on public
participation. For LDI. U.S. EPA has in fact set forth the
alternatives at hand and sought public comment on them before a decision
was made on a proposed plan.
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-22-
Issue: The Steering Committee, their technical consultant and othe~
PRPs commented that the remedy selection process in the FS igno~es the
requirement for considering cost-effectiveness, and that improper
alternatives were analyzed.
Comments:
1. Vacuum ext~action evaluated in alternative 5 is illogical and not
cost~effective since the technology was not required in alte~native 7.
2. The FS does not explain why Alternative 5 requires a "clean cove~"
after solidification, while Alternative 7 requires a slurry wall and a
RCRA cap with a synthetic liner.
3. Alternative 2 provides the same environmental benefits as Alternatives
3, 4, 5, 6, and 7.
4.
. . .
Soil flushing should have been considered further. ....
5. Solidification plus a slurry wall and containment system is
unnecessary dupl ication. , "
6. Alternative 2 meets the goals of"SARA because it reduces the mobility
of soil contaminants. Also, Alte~!\ative'? 'may release volatile contaminants, ..
and therefore may not actually me~t th~ preference for reduced mobil ity,
toxicity, or volume. .
E..esponse:
The FS followed the procedures outlined in the U.S. EPA's "Guidance on
Feasibility Studies under CERCLA." This process included the identification
of response objectives, technology screening, selection of target cleanup
levels, and alternatives development, screening and detailed analysis
. (see the Summary of Remedial Alternative Selection). The appropriate
extent of remedial action and of alternative selection is discussed in the
NCP, 40 CFR Part 300.68(j), and in Section 121 of SARA.
The Steering Committee, their technical consultant, and other PRPs disagree
with the findings of the EA, particularly with the ground water exposure
assessment. This has led to the PRPs' conclusion that ground water remedial
action is unnecessary since they believe no human exposure pathway exists.
U.S. EPA maintains that the exposure scenarios detailed in the E.C. Jordan
. . EA are appropriate. (See the discussion in this Responsiveness Summary
and Chapter 7 of the RI Report). The FS therefore evaluated remedial
alternatives for ground water as well as for soil/waste. Remedial
action is necessary to protect pUblic health and the environment.
Vacuum extraction was included in Alternative 5 as a means of pre-
treating VOC contaminated soils prior to solidification/fixation.
Due
. - ~ -- --:-.- ~- ,,-. -,,--..,...... -
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-------
-23-
. .
to the relatively low mass of VOCs in soil, it was felt that
solidification/fixation would be effective by itself. The comparison
of the two alternative treatment schemes helped U.S. EPA to make a
determination that alternative 7 was cost-effective and protective of
human health and the environment. Neither the NCP nor CERCLA (as amended
by SARA) requires that ~ cost-effective alternatives be evaluated,
but rather that a cost-effective alternative be selected.
The slurry wall and impermeable cap have been combined with solidification/
fixation in alternative 7 in order to provide an effective treatment and
containment remedy. Solidification/fixation of sOil/waste alone was not
recommended since ground and surface water could potentially, over time,
reduce the effectiveness of the technology. The slurry wall/containment
system will reduce the likelihood of degradation, as well as provide an
extra measure of'pro~ection against off-site contaminan~ migration.
..
Alternative 7 requires an impermeable cap in order to mai"ntain the effective-
ness of the slurry wall. Without such a cap, the vdlume of material
within the confines of the slur~ wall wouJd n~ed to be dewatered for an
indefinite time period. The addition of an impermeable cap reduces the
dewatering operation to an estimated three ye~rs.
Soil f1 ushi ng was not carr; ed throu'gh t{) the detai 1 ed sc!"eeni ng p!"ocess
since it requires pumping, collection, and circulation of large quantities
of ground water. The upgradient ground water is slightly contaminated,
and would have an unknown effect on the system local ground water system
(see p. 80 of the FS). Furthermore, as pointed out on page 45.of the FS
prepared by the Steering Committee's technical consultant, soil flushing
would be difficult to implement during cold weather conditions in the
~
area.
The FS states that alternative 2 provides, "...environmental benefit
similar to other alternatives (except no action), but has fewer adverse
environmental effects than alternatives involving on-site excavation
or groundwater dewatering, due to the reduced potential for soil erosion
and destruction of wetlands habitat." The Steering Committee argues
that, since alternative 2 is less costly than alternatives 3, 4, 5, 6,
and 7, 'alternative 7 should not be the recommended remedy. Alternative 2
is beneficial from the standpoint of reduced on-site excavation risks, but
does not meet the preferences for treatment and permanence discussed in
.' SARA. Specifically, alternative 2 does not uti,lizeany treatment of
soil/waste, which is counter to the preference for treatment as a principal
element, and the preference for permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Alternative 7 meets the preference for treatment mandated by SARA since
it will significantly reduce the mObility and toxicity of contaminants
in soil/waste, and significantly reduce the mobility, toxicity, and
volume of the contaminants in ground water.
In summary, alternative 7 has been developed and evaluated pursuant to the NCP,
CE~CLA as amended by SARA, and appropriate Agency guidance and policy.
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-24-
Issue:
The PRPs submitted a Feasibility Study {FS}, prepared by
Fred Hart, Inc., for the Liquid Disposal, Inc., site.
Response:
u.S. EPA has reviewed the subject document and includes the
following comments:
The public comment period is intended for receipt of public comments
on the Agency's proposed remedial action so that the comments may be
considered in the decision making process. The Agency is not obligated
to review and comment on the Hart FS, but only to respond to comments
on the Agency FS. However, the Agency did review the Hart FS, and,
because of significant differences in the conclusions of the two, is
providing comments regarding inadequacies in the Hart FS...
The objectives of the LDI remedial action as stated in the. Hart FS on
page 10 are incomplete. It is the determination of U.S..EPA that existing
and future potential threats to pUblic hea1tha'nd the environment are
posed by leachate and ground water, as well as on-site and off-site soils.
{see pages 29-30 of E.C. Jordan FS}. Th~RartFS is incomplete in that
response object i ves fo r ground water. and leac~ate are not presented.
Furthermore, the level of c1eanup..iar soiJs' that is presented in the
Hart FS in Appendix A is not adequate for protection of public health
and the environment. U~S. EPA maintains that soils cleanup levels
shall be to a} concentrations of carcinogenic compounds such that
cummu1ative cancer risk will not exceed lO-6~ and b} concentrations of
noncarcinogens will be such that the risk ratio is less than one,
utilizing the reasonable, yet conservative, soil ingestion scenario presented
in the E.C. Jordan EA. Furthermore, all so;ls for which the LDI site
is the source of contamination will be remediated, regardless of proximity
to active junkyards or oth~r uncontrolled areas in the vicinity of LDI.
~
The identification and screening of remedial technologies presented for
soils alone {pages 11-18 of the Hart FS} are inadequate. A number
of potential soils remediation technologies are not presented, particularly
treatment remediation technologies including biological processes,
physical processes, chemical processes, and thermal processes. However,
Table 3-1 of the E.C. Jordan FS presents a comprehensive list of potential
technologies.
. The criteria for screening the technologies in-the Hart ~S, however, are
not explained. Screening of technologies based on reliability, construct-
ability, implementabi1ity, and applicability is done in Table 2-2 of the
Hart FS, but no definition of these screening criteria is presented. An
evaluation of the Hart FS, Table 2-2, for example, reveals that the
reliability screening criteria were not applied to the remedial action
goal stated earlier in the Hart FS. Reliability for different, less
protective goals, are discussed in Table 2-2 (Hart).
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-------
-25-
Furthermore,.at the conclusion of the Hart technologies screening, it is
not clear which technologies are screened out and which are acceptable
for further consideration.
The alternatives array process on pages 19-21 of the Hart FS is done
without regard to recent U.S. EPA guidance and the rationale for
assembling the alternatives is not given. Because it is not clear
whic~ technologies are considered appropriate from the previous
technologies screening section, the assembling of the alternatives in
Section 2.3 (Hart FS) appears arbitra~y.
The E.C. Jordan FS, on the other hand provides an explanation of the
technologies screening criteria on page 42 and properly applied
in Section 3.2. In addition, the arrayed alternatives in the three
types of remedia~ion categories are described on pages 72-73: no action,
containment, andtrea.tment. This is as di rected in the lnt.erim Guidance
on Superfund Selection of Remedy, December 24, 1986 OSWER'Directive
#9355.0-19. The screening of technologies (Section 3.2) 1s comprehensive
and c1ea~. The alternatives array rationale (pages.73 to 80) is also clear.
~. OJ' . .
The alternatives assembled in the Hart. FS are described and evaluated
in Section 3, pages 22-34. The descriptions of the alternatives do not
provide adequate detail for eva1ua.~ion c!"iJ:eria for these a1.ternatives.
Furthermore, the evaluation cr'ite~raare not presented or described in
the Hart FS. The cost information presented on the alternatives in
Section 4.0, pages 35-42., of the Hart FS is inadequate. The estimated
accuracy of the cost estimates is not stated. The data used to determine
the cost estimates is not referenced. The level of detail needed for
evaluating alternatives for the LDI site is presented in Section 5, pages
82-158, of the E.C. Jordan FS.
..
Finally, the summary statements presented in Section 5.0, pages 43-46, of
the Hart FS do not equitably reflect the screening criteria presented
in its study (technical evaluation, institutional requirements, public
health evaluation, environmental evaluation, and cost). The environmental
evaluation consideration of soils excavation and associated organic
vapor and dust generation is emphasized. A statement of comparative
public health protection, technical feasibility, and institutional
requirements is not presented in the Hart FS. A determination of an
appropriate cost-effective remedial action is not possible with such an
asymmetric evaluation of the evaluated alternatives.
In contrast, Section 5.9, pages 158-166, of the E.C. Jordan FS presents a
summary and comparative analysis of all developed remedial alternatives
1n light of all utilized evaluation criteria (engineering evaluation,
public health evaluation, environmental evaluation. ARARs evaluation,
and cost).
The comprehensive evaluation by E.C. Jordan leads to recommendation of
Alternative 7 as the appropriate cost-effective remedy.
-------
-26-
Issue: The Stee~ing Committee commented that the Feasibility Study
(FS) applies inappropriate and i~relevant requi~ements, which has
resulted in -a remedy that is not cost-effective and is inconsistent with
U.S. EPA policy.
COl11Tlents:
1. The selection of remedial action must be guided by applicable and
re1eyant or appropriate requirements (ARARs).
2. The recommended remedy is not cost-effective, as required by the
National Contingency Plan (NCP). °
3. Maximum Contaminant Levels (MCLs), Cancer Assessment Group (CAG)
numbers, and Risk Reference Doses (RFDs) are not ARARS for the site.
4. The upper aquifer downgradient of the site is not, and will never
be a source of drinking water. Therefore, it should be:.cJassified as a
Class III aquifer, and thus drinking water standards are.not ARARs.
Response:
. --
. .
Section l21(d) of CERCLA requires th~t the level of cleanup at a site attain 0- :
ARARs. The selected remedial actiohOat LDI is protective of human health ..
and the envi ronment and attai ns al-}'ARARs.' ~-
o -
As described in the Record of Decision, the groundwater cleanup level
will be such that under a reasonable yet conservative groundwater
ingestion scenario. Concentrations of carcinogenic compounds will be
such that the cumulative cancer risk will not exceed 10-6, and
concentration of non-carcinogens will be such that the risk ratio (as
described in the EA) will be less than or equal to one. The soil cleanup
level will be based on a reasonable yet conservative soil dermal contact
scenario. The resultant concentrations of carcinogens in unremediated
soils will be such that the cumulative cancer risk will be less that 10-6
and concentrations of noncarcinogens in unremediated soils will be such
that the risk ratio will be less than or equal to one. Maximum Contaminant
Levels (MCLs), Cancer Assessment Group (CAG) numbers, and Risk Reference
Doses (RFDs) are all used to help detennine protectiveness for the site.
As explained above. contra~ to PRP and Steering Committee comments,
U.s. EPA would not classify the shallow aquifer as a Class III aquifer.
.The quality of the water in this aquifer, if no~ affected.by the site,
. would be such that the groundwater could be potable. For this reason,
U.S. EPA based cleanup levels for this aquifer on a reasonable yet
conservative human ingestion scenario of the groundwater.
D
The selection of the remedy is based on a number of evaluation criteria.
Compliance with ARARs is one of these criteria. Other criteria include
effectiveness, engineering constructability, engineering implementability,
engineering reliability, public health evaluation, environmental impacts
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-------
-27-
evaluation, and cost (page 82 and 83 of the FS). Section 121 of
CERCLA also states a preference for remedies which provide permanent and
significant reduction of mobility, toxicity, or volume of hazardous
substances. The selected alternative will provide protection of public
health and the environment. and provides the best balance of strengths
relative to the above evaluation criteria. This remedy also provides for
reduction of mobility. toxicity. and volume of hazardous substances at
the site. The public health and envi~onmenta1 benefits yielded from this
remedy justify the costs of the remedy. The selected alternative is
cos t-effect i ve.
Issue:
One citizen requested a different ground water treatment scheme.
Comments:
1. The private citizen suggested that activated carbon. rather tnan
air stripping. be~used for ground water treatment.
..
Response:
..
In regard to changing Alternative 7. groundwater treatment, to using
carbon adsorption rather than air stripp'ing, we. have reviewed both
t~eatment methods.
Although both methods of treatment~"Woulq b'e effective at the LDI site,
ai~ str~pping was selected primarily because it is expected to be equally
as effective as activated carbon at a lower cost. Each system will
require activated carbon, but the annual operation and maintenance (0 & M)
cost of the vapor phase carbon for the air stripper is estimated to be
less than the 0 & M cost for water phase activated carbon. This is
because the vapor phase carbon would be treating strictly stripped
contaminants, while the water phase carbon would act as a filter for
ground water contaminants of concern as well as other chemicals present.
Over the life of the project (estimated to be 9 years), the cost of
frequent changes of water phase carbon could be significant.
..
Issue: Hydro-Geo Chem, Inc. under contract to Hexcel Corporation, submitted
an alternative for U.S. EPA consideration.
A
The essential features of the alternatives were described by Hydro-Geo
Chem, Inc. as: .
1) debris decontamination and off-site land ~isposa1 to. address
debris/equipment
2) on-site treatment with vacuum extraction, soil flooding, excavation
and relocation of off-site soils and capping to address soil/waste; and
3) on-site treatment with carbon absorption and flocculation/precipitation
to address groundwater.
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-28-
Response:
The alternative presented by Hydro-Geo Chern, Inc. (HGC) has been reviewed.
The a1ternafive contains elements already 'evaluated in detail in the FS,
as well as a new element, soil flushing, to address the response objectives
enumerated in the FS.
On-site disposal of debris/equipment was selected primarily because it
was felt to be the most cost-effective method. The estimated capital costs
were $79,750 for on-site disposal versus $247,500 for off-site disposal.
Vacuum extraction was not recommended because of disfavorab1e site
conditions. The heterogeneous nature of the soil/waste would make vapor
extraction difficult to design and implement.
The relative merits of air stripping versus carbon adsorption are discussed
elsewhere in this Summary. Ion exchange ($130,100) was deemed to be more
cost-effective t~an flocculation/precipitation ($284,000), since both
technologies could meet the response objectives.
.'
Soil flushing (flooding) was not examined in det~it,for reasons explained
on page 80 of the FS. Also, the Steering Committee's consultant noted
that cold weather conditions would make;t~is technology difficult to
implement.
Hydro-Geo Chern has fonnulated a reaso'nable 'alternative that util ized
similar components of E.C. Jordan alternative number 5. U.S. EPA believes
that, when all appropriate rernedy selection factors have been weighed"
Alternative 7 remains the most cost-effective (see Summary of Remedial
A1t.rnative Selection).
~
Issue:
Comments from U.S. Fish and Wildlife Service
Corrments:
1. It is the opinion of the U.S. Fish and Wildlife Service that the 1 mg
PCB/KG soil dry weight TCl is too high and if implemented will lead to
direct and adverse impacts to resident and migratory wildlife at the
site. In consideration of bioaccumu1ation by invertebrates (earthworms)
and other organisms on up the food chain, the TCl should be set at 0.1
mg PCB/Kg soil dry weight and, to provide for a margin of safety,the
val ue shou1 d be changed to 0.05 mg PCB/Kgsoi 1 dry wei ght.
2. U.S. Fish and Wildlife Service expressed concern that inappropriately
. 'high detection levels were employed in analysis' of on-site soil samples
for polychlorinated dioxins/furans. They also suggested that off-site
soil samples for polychlorinated dioxins/furans be taken.
L;
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-------
-29-
Response:
U.S. EPA believes that the RI evaluated the potential ~e1eases of poly-
chlorinated dioxins/furans adequately. The analytical detection limits
for dioxin/furan isomers were at, or below, 1 ug/kg in soils. While
significantly lower detection limits are achievable in wate~ samples, it is
difficult to routinely analyze for dioxins/furans in soils below the 1 ug/kg
1 eve L
Soil samples analyzed for dioxins/furans were collected from on-site areas
expected to have the highest potential for contamination. The analyses did
not reveal the presence of significant releases of these contaminants.
Consequently, extensive off-site sampling efforts were not deemed necessa~y.
The U.S. Fish an~ Wildlife Service (FWS) has raised a valid concern 'regarding
bioaccumu1ation of PCBs by invertebrates as a rationale ,for, proposing a more
stringent TCL. The issue of appropriate clean up levels-for PCBs in soils
has been debated extensively within, and outside,. t~e Agency. The Agency, has
evaluated the health and envi~onmenta1 impacts of PCBs. The U.S. EPA Office
of Health and Envi~onmental Assessment (~ijEA) developed draft health advisories.
fo~ PCBs in soils. The OHEA assessment concludes that a level of 1 to 6 ppm '
PCBs in soil could be associated with a 1 x 10~5 level of oncogenic ~isk in ~
humans. The placement of a 10 inct}-cap of.,'c1ean soil on top of soil containing
1 to 6 ppm PCBs could reduce the. oncogenic risk by an order of magnitude.
The Agency strives to consistently provide this level of protection, if
practicable and cost-effective.
While there are uncertainties regarding the environmental impacts of PCBs in
soils, the Agency does not feel that more stringent clean up 1e~e1s are
justifiable. The soils on site will be capped with a RCRA compliant cap.
Off-site soils, once they are excavated to the target clean up level, will be
backfilled with clean soil and compacted. These measures are designed to
afford protection of human health, and significantly reduce the likelihood of
exposure of resident and migratory wildlife.
Issue:
"
One PRP commented that it was his unde~standing that U.S. EPA and MDNR were
withholding information.
COlTlTlents:
1. U.S. EPA and MDNR have technical information which concludes that there is
no realistic risk from soil exposure and no risk of exposure down gradient from
the site. U.S. EPA was requested to review all allegedly withheld information
prior to the Record of Decision and justify why such data was not considered
for the selection of Alternative 7 or other alternatives beyond what has
a1ready.been accomplished at the site.
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-30-
Response:
u.s. EPA has not withheld information regarding the selection of the LDI ~emedy.
All available chemical data relevant to this Record of Decision have been
made a part of the administrative record. The data have been used to analyze
the alternatives discussed in the FS. The risks from soil and gr~undwater
exposure are discussed in the Endangerment Assessment (Chapter 7 of the RI
Report). U.S. EPA is unaware of any other technical information which would
indi~ate that there is no realistic risk from soil exposu~e and no risk of
exposure downgradient of the site.
Issue: The Steering Committee and its technical consultant commented that
the risks and benefits of excavation and solidification have not been
adequately compared.
Comments:
1. The FS did not consider the risks due to: 1) disturbance of soil and
release of chemicals into the air; 2) exposure of wastes ~o increased
precipitation which could increase migration .of ch~icaB from the site;
3) volatilization of chemicals from the dewatering operation; 4) exposure of
workers to chemicals during excavation;.- aod 5). risk of accidents during the
operation of heavy equi pment. .
2. The process by which soil sol.j:d..ificat..10n is to take place is not defined.
Therefore, the decision to use. this t~chnology is arbitrary and capricious.
..
Response:
Chapter 5 of the FS qualitatively discussed the risks of exposure from
excavation of soil/waste in those alternatives requiring such activity
(Nos. 3, 4, 5, 6, and 7). In order to insure protection of public health
during excavation, a bench and/or pilot scale test will be performed during
remedial design. The purpose of this test is to identify the proper
solidification/fixation agent and to evaluate the potential for the release
of chemicals into the air during excavation and solidification/fixation.
Based on information gathered during these tests, the Agency will implement
excavation and solidification to minimize any adverse impacts. In addition,
Occupational Safety and Health Administration requirements for worker
protection and safety will be followed.
A
l.
As discussed in the FS, as well as elsewhere in this Responsiveness Summary,
. the specific details of the process by which soil solidification will
occur will be determined during Remedial Design. The Agency's selection
of soil solidification as part of the remedy, with specifying all
engineering aspects, is neither arbitrary nor capricious. Due process
has been afforded the PRPs as well as the public to comment on the
treatment technology for the site. The Agency is not required to fully
11
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-------
-31-
engineer and design each alte~native prjor to selecting an approp~iate
remedy. In enacting SARA, Congress specifically recognized in Section
117 that the: Agency would make adjustments and changes du~ing the
implementation of Records of Decision. To the extent that significant
changes which negatively impact any of the selection criteria arise during
design or implementation, the Agency will seek additional public comment.
All other changes occuring during design and implemenation will be'handled
in accordance with the provisions of Section 117(c).
Issue:
"
An affidavit by a former E.C. Jordan employee was included in the Steering
Committee's comments regarding a November 5, 1986 meeting between U.S.
EPA, MONR, and E.C. Jordan. It states that the U.S. EPA and MONR instructed
E.C. Jordan to change their assumptions in the EA in order to justify
remedial action. (Note: Technical comments in the affidavit have been
addressed elsewh~re in this Summary). .
Comments:
. ..
1.
A former E.C. Jordan employee claims that U.s.. ,EPA and MDNR told E.C.
Jordan not to include a list of nat~rar'y occurring organic chemicals in
the EA because it would not help justify remedial action at the site, and
that U.S. EPA and MONR al so stat.ed that tlTey did not want to further
weaken the case for remedial action since so much removal activity had
taken place. '~-:~' .
..
2.
A former E.C. Jordan employee claims that U.S. EPA instructed E.C.
Jordan to assume exposure so that more work could be done at the site.
f-1
Response:
U.S. EPA and MONR did instruct the former E.C. Jordan employee to change
his assumptions in the EA. However, the rationale for U.S. EPA and MDNR's
instructions is quite different from that represented by the former E.C.
Jordan employee. Contrary to the assertion of the former E.C. Jordan
employee, U.S. EPA and MDNR requested changes in the EA because the former
E.C. Jordan employee had greatly mischaracterized the present and future
potential risks associated with the site. In particular, U.S. EPA and
MDNR requested that assumptions be changed for the following reasons:
~
1) E.C. Jordan's assumption of no exposure to site contaminants would
not provide adequate protection of human health and the environment.
2) The Superfund Public Health Evaluation Manual provides that potential
exposure to contaminants in the environment may be assumed to present an
adequate assessment of risk. To do otherwise could seriously underestimate
the risk of human contact with contaminants, and thus human endangerment.
u.S. EPA is unaware of any request to not include a list of naturally occurring
organic chemicals in the EA. In fact, the background concentrations of organics
were evaluated in the FS in order to determine the appropriate extent of remedial
action. .
-. - . ._- - ,...
- - .- . _. . -. - . _... . '.. . --
-------
-32-
Finally. U.S. EPA is unaware of any statements made by U.S. EPA or MDNR
personnel. regarding the need for certain assumptions in the endangerment
assessment. solely for the pu:-pose of justifying remedial action.
.'
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SUMMARY OF PUBLIC MEETING COMMENTS
On August 27, 1987, the Michigan Department of Natural Resources and the U.S.
Envi~onmental Protection Agency held a meeting in Shelby Township, Michigan, to
~eceive comments on a draft Feasibility Study for the Liquid Disposal, Inc.
Supe~fund site. The following represents a summary of major comments and
suggestions made at that meeting or ~eceived in writing:
Comments:
1.
Concern was expressed over the presence of contaminants in the deep aquifer
at the site and the possible ways that the aquifer became contaminated.
Commenter recalled operational practices at LDI that appeared to allow ai~
emissions to bypass the air pollution control equipment. Ca~ we prosecute
the owners a~d operators for violations of this sort? It was suggested
that the Shelby Township Police Department and local courts probably have
documentation of complaints and violations. - .'
2.
3.
Commenter was concerned about "shortcuts" bei' ng--taken in the construction of
the proposed slurry wall in order to 'cut costs. Commenter questioned both -
EPA and DNR staff on whether or notEPA was being pressured to reduce.
spending in the Superfund progr'ams below funding levels allocated by Congress.
. . " . ~
4.
Commente~ was worried, as a. t~-~payer, that the public is paying twice for
other's mistakes; in the form of health effects and secondly in paying fo~
site cleanup. Is the EPA aggressively pursuing responsible parties to
pay for cleanup?
A numbe~ of cammenters were concerned about the proposed discharge
to the Clinton Ri'ver of the purged and treated ground water. The Clinton
River is too easily viewed as the catch-all for all pollutants. If a
su~face water discharge is established, strict and appropriate discharge
limits must be set in an NPDES permit. Suggestion was made to fully
investigate the cost-effectiveness of the proposed groundwater treatment
system with discharge to the Clinton vs. discharge to the Detroit sewer
system with reduced or no treatment.
5.
6.
It was suggested that, rather than solidifying the contaminated soils at
the site now, to merely contain the contaminants with the slurry wall and
cap. In a few years, as technologies such as biodegradation advance, the
government could go back and fully treat the soils to remove or detoxify
contaminants. Solidifying solids seems to.eliminate any future option for
a more permanent remedy.
7.
How will the integrity of the proposed clay cap be protected, especially in
light of the problems being experienced with the cap at the G&H Landfill?
8.
The carbon adsorption system for groundwater treatment proposed in alternative
#3 would be a better choice than the air stripping system proposed in
alternative #7. Commenter suggests that the low levels of organics present
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in the groundwater would be effectively removed and since the carbon can be
reclaimed. the additional cost would be negligible.
9.
Commenter is concerned about community reaction to her working with school
children in the Shadbush Environmental Center east of the LDI site. and
wanted a letter stating that it was safe to use the site.
Response:
1 .
The deeper aquifer does indeed show some contamination. principally by brine.
The presence of the brine is not fully understood. Brine is naturally
occurring in that aquifer and the bedrock aquifer has likely been unaffected
by surface waste sources. However. th~ public has stated its concern that
past injection of hazardous substances into the deeper aquifer. from an
LDI production well could have occurred. In order to respond to public
.concerns and definitively characterize the bedrock ~quifer. confirmation
sampling will be performed during remedial design. -..
2.
. . -. .
EPA enforcement has focused primari ly on ident ifyi ng parties that mi ght
bear responsibility under Superfund f~r site cleanup. EPA is now negotiating
with over 800 separate parties. which sent waste to LDI. We hope that as a.
result of these negotiations. pri.vate parties will pay for the site cleanup
and reimburse the State and F~deral government for money spent to date. .
Prosecution for permit vio.lationsts difficult under air pollution control
statutes and would be especailly difficult many years after a facility is closed.
Staff were not aware of any such problem and cited examples that would
contradict the assertion of footdragging on spending.
3.
4.
Yes; currently EPA is negotiating with over 800 companies for cleanup of
the site.
5.
We recognize the concern over the proposed discharge to the Clinton River,
especially in light of the heavy recreational use made of the River. The
possibility of discharging treated groundwater to the Detroit sewer system
will be fully investigated in the design phase of this project. The Detroit
Water and Sewerage Department has been contacted. and that office has
p~ovided certain guidelines and requirements that would affect such a discharge. 4
6.
~
The proposed soil cleanup approach--solidifying and isolating--is considered
a permanent remedy. Land use restrictions may need to be in place for many
years. Leaving the soils untreated as suggested seems presumptuous with
regard to how technologies will advance and with regard to the availability
of funding at a later date to pay for further remedial work.
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7.
The clay cap proposed at LOI will be significantly different from the "cap"
at G&H. "The cap proposed at LOI will consist of a series of clay and
artificial liners, all designed and installed with detailed specifications.
Top soil will be placed on top of the cap, and a vegetative cover will be
established.
8.
u.s. EPA has evaluated both air stripping and carbon adsorption as potential
methods for treating the groundwater. Both carbon adsorption and air
stripping can meet the response objectives. The estimated capital costs
of air stripping and carbon adsorption are $146,000 and $72,100, respectively.
However, the operation and maintenance costs are $43,800 and $72,600,
respectively. Since the system is expected to operate for about nine
years, U.S. EPA believes that air stripping will be the most cost-effective
method for treating extracted ground water in the long run.
".
9.
The Michigan Department of Public Health, Center for Environmental Health
Sciences is reviewing the data on soil contaminants a~d- will provide the
letter concerning the use of the site. The letter wfll detail any restrictions
on use or precauti na ry measures that should "be t~ken.
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