United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EPAIROD/ROS.881062
March 1988
3EPA
Superfund
Record of Decision:
"i
I
S
Forest Waste Disposal, MI
U.S. Environmental PrDtection Agency
Region III Information Resource
Center (3PM52)
841 Chestnut Street .,
Philadelphia, fA 19101 ~ii~~
.;,
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
EPA Report Collection
li1Jt~lI'lriU~tiGn Res~Q.Cr~@ (bM~~:r
U$ EPA R&gl~n ~
Philadelphia! PA 1~~@'lf
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50272.101
REPORT DOCUMENTATION \1. REPORTNO. T 2-
PAGE .EPA/ROD/ROS-88/062
I. RecIpient. ACC888Ion No.
4. TlII8 IUIII SubIlIl8
SUPERFUND RECORD OF DECISION
Forest Waste Disposal, MI
Second Remedial Action
7. AuII1or(.)
5. R8port Data
3/31/88
IL
a. Performing Organlzallon Rept. No.
t. Performing Orgalnlzallon Nan8 IUIII Add....
10. ProjectlTuklWork Unit No.
11. Contnct(C) or Grant(G) No.
(C)
(G)
12. Sponaortng Organlzallon Nama and Addr8M
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
11. Typa of Report. Period Covered
Agency
800/000
14.
15. Supplemantary No-
.
1IL Abalr8ct (Umlt: 200 word.)
The Forest Waste Disposal site consists of an 11-acre, abandoned municipal
and industrial waste landfill and 9 surface impoundments. It is located in
Genesee County, Michigan, 20 miles northeast of Flint, and is surrounded by
agricultural land and undeveloped woodlands and wetlands. An estimated 20
to 30 households are located within a quarter mile of the site. Wetlands in
the site vicinity drain into Butternut Creek which eventually discharges
into the Flint River. The site is underlain by two drinking water aquifers
Forest Waste Disposal conducted landfill operations from 1972-1978,
receiving limited types of liquid industrial waste, general household
refuse, and drummed waste until 1978. Specific waste material found within
the landfill includes PBB-contaminated feed, septic sludge, and drums
containing primarily solid and liquid VOCs in high concentrations. The
operator also was suspected of discharging liquid wastes into the landfill
and onto the ground. In 1982, the site was placed on the NPL. This
remedial action addresses the landfill and contaminated ground water on the
east end of the site. Contamination from the nine waste lagoons is
considered to be the primary source affecting ground water and is addressed
tSee Attached Sheet)
17. Document AnalyaJ. L Deacrlpt018
Record of Decision - Forest Waste Disposal, MI
Second Remedial Action
Contaminated Media: gw, soil
Key Contaminants: VOCs (Toluene, TCE), Organics, (Pesticides, PAHs, PBBs), Metals
(arsenic, lead)
b. Idenlifier8l0pen-Ended Tenna
.
c. COSA TI Reid/Group
18. AvllilabiMty Statement
111. SeCl8ity Cla88 (1h1. Report)
None
20. Security Cla88 (Thl. Page)
Nnn""
21. No. 01 Pege.
137
22. PrIce
(See ANSl-Z3I1.18)
See/nalnJCtJona on Rew,..
OPTIONAL FORM 272 (4.77)
(Formerty NTI~35)
Department 01 Commerce
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EPA/ROD/R05-88/062
Forest Waste Disposal, MI
Second Remedial Action
16.
ABSTRACT (continued)
"
in a previous remedial action, which includes: offsite treatment and
disposal of lagoon liquid, with onsite treatment and offsite disposal of
lagoon sediment, sludge and soil. The primary contaminants of concern
affecting the soil and ground water are VOCs including toluene and TCE;
other organics including pesticides, PARs and PBBs; and metals including
arsenic and lead.
The selected remedial action for this site includes: removal and either
onsite or offsite incineration of approximately 4,000 drums and 1,000 yd3
of associated contaminated soil; installation of a containment system
including a RCRA cap, slurry wall, dewatering system and a leachate
collection system; and treatment and disposal of collected leachate. The
ground water remedy includes: deed restrictions to prevent use of the
ground water asa drinking water source; access restrictions; and ground
water monitoring. The estimated present worth cost for this remedial
action is $23,820,000 with an annual O&M of $440,500.
PERFORMANCE STANDARDS OR GOALS: The remediation of the landfill will
prevent migration of contaminants to a drinking water aquifer in excess
of MCLs, lifetime health advisories, and noncarcinogenic reference doses,
and will result in an excess lifetime cancer risk range of 10-4 to 10-7.
The remedial action also will prevent migration to surface water bodies
in excess of Federal and State water quality criteria. Cleanup goals for
individual chemicals were not specified.
INSTITUTIONAL CONTROLS: Deed restrictions will be implemented to prevent
use of the ground water onsite and from areas adjacent to the site as a
drinking water source.
KEYWORDS: Air Monitoring; Alternate Closure; Arsenic; Capping;
Carcinogenic Compounds; Containment; Deed Restriction; Direct Contact;
Ground Water; Ground Water Monitoring; Inorganics; Leachate
Collection/Treatment; Lead; MCLs; Metals; O&M; Onsite Treatment;
Organics; PARs; Pesticides; RCRA; RCRA Landfill Specifications; State
Criteria; Soil; Solvents; Slurry Wall; TCE; Toluene, VOCs; Water Quality
Criteria; Wetlands; Woodlands.
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Declaration for the Record of Decision
v
Forest Waste Disposal
Otisville. Michigan
PURPOSE
This decision document represents the final selected remedial action for
the Forest Waste Disposal site in Otisville, Michigan. It was developed in
accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent practicable, the
National Contingency Plan (40 CFR Part 300).
The State of Michigan has been consulted on the selected remedy and opposes
the remedy.
BASIS
The selection of remedy is based upon the Forest Waste Disposal Site
.Administrative Record. The attached index identifies the items which
comprise this record.
DESCRIPTION OF SELECTED REMEDY
.
The final remedial action addresses two !ite operable units: the landfill
soil and source materials, and contaminated groundwater on the east end of
the site.
The landfill operable unit remedial action consists of the following:
Removal and offsite treatment of areas of concentrated drums
and associated saturated contaminated soils;
Installation of a Resource Conservation and Recovery Act (RCRA)
cap over the landfill;
Installation of a soil-bentonite slurry wall vertical barrier with
a dewatering system surrounding the landfill;
Collection and treatment of the groundwater from the dewatering
system;
Access restrictions on the Forest Waste property and areas
immediately surrounding the site;
Installation of fence around the landfill area; and
Groundwater monitoring around the landfill.
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-2-
- The groundwater operable unit remedial action consists of the following:
Access restrictions which include prevention of drinking water
wells in the shallow aquifer on the site or in adjacent areas; and
~
Groundwater monitoring to assess the changes in location and
concentration of the contaminant plume.
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. As mandated by CERCLA and as amended
by SARA, the remedy. satisfies the preference for treatment th~t reduces
toxicity, mObility, or volume of hazardous substances as a principal.
element. Finally, this remedy utilizes pennanent solutions to the maximum
extent practicable. .
Because this remedy will result in hazardous substances remaining onsite
above health-based levels, a review will be conducted every 5 years after
commencement of remedial action to ensure that the remedy continues to
provide adequate protection of human health and t1e environment.
.
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Su..ary of Re.edial Alternative Selection
Forest Waste Disposal
Ot1svflle. Michigan
SITE LOCATION AND DESCRIPTION
The Forest Waste site is in the rural southeast corner of Section 8, Forest
Township (T9N, R8E), Genesee County, Michigan. It is 20 miles northeast of
nint, and 2 miles northwest of the City of Otisvi11e (Figure 1). In 1982,
the population within a 3-mi1e radius of the site was estimated at 3,120 by
the Michigan Department of Natural Resources (MDNR). Otisvi11e had an
estimated population of 720. An estimated 20-30 households are within a
quarter mile of the site.
The site is generally flat except for slight irregularities in the land
surface suggesting waste disposal. Vegetation consists of grass and weeds,
low shrubs, and a few scattered trees. Land surrounding the site is
approximately 50 percent agricultural and 50 percent undeveloped (woodlands
and wetlands). Butternut Creek flows past the southeast corner of the
site, continuing southwest and discharging into the Flint River.
Physical features of the site include a landfill and nine surface
impoundments, or, lagoons, that were used for waste disposal. The landfill
area occupies approximately 11 acres of the lIZ-acre property. It is
covered wi th vegetati on and native. soil, a1 though refuse and rusty drums
are exposed in some places. The nine 1agdons have a collective surface
area of about 1 a~re. A s~hemati~ site map is presented in Figure 2.
.
The regional geography of Forest Township is typical of glaciated areas,
characterized by morainal deposits. The topography of Forest Township is
hilly in the east, grading to a slightly undulating and, in places, flat
surface in the west.
, The surficial geology in the vicinity of the Forest Waste site is primarily
derived from Wisconsin Age glacial deposits, and generally consists of
layers of medium sand with fine gravel, alternating with layers of silty
clay morain~l till deposits.
Bedrock in the site vicinity is reported to be the Pennsylvanian Age
Saginaw formation. Generally, the Saginaw formation is a series of
irregular aquifers. Bedrock described in residential well drilling logs is
predominantly sandstone, with interbedded layers of shale and limestone
ranging from 1 to 39 feet thick. Generally, these interbedded layers of
shale and limestone are less than 20 feet thick, averaging about 9 feet in
thickness.
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FOREST ~
WASTE SITE -:--v*
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SCALE IN MILES
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FIGURE 1
LOCA TION MAP
FOREST WASTE DISPOSAL SITE
FOREST WASTE RI
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SCHEMATIC SITE MAP
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2
Three hydrogeologic units, occurring at different elevations beneath the
site, have been identified in the saturated glacial deposits. These are:
o Shallow Aquifer: An unconfined aquifer consisting of
approximately 20 feet of fine to medium sands, and located
approximately 10 to 30 feet below ground surface.
o Till Aquiclude: A low permeable confining unit, consisting of
10 to 30 feet of glacial till, and located approximately 20 to 35
feet below ground surface.
o Deep Aquifer: An aquifer consisting of 7 to 27 feet of medium-
coarse gravel, and located approximately 40 to 60 feet below
ground surface.
The shallow aquifer unit, in general, is a very fine to medium-grained sand
containing some silt, with only the lower half of the sand layer being
saturated.
The shallow groundwater flows toward the east at the northern portion of
the site and toward the southeast at the southern portion of the site as
shown in Figure 3. In general, this flow is directed toward and discharges
to the marshy region and Butternut Creek.
. .
Horizontal hydraulic gradients are relatively flat in the western half of
the site, with values of 0.0007 ft/ft in tne north (in the vicinity of the
landfill) increasing to 0.005 ft/ft in the south. The gradients vary
between 0.004 and 0.007 ft/ft over the easterE half of the site.
The estimated hydraulic conductivities for the shallow aquifer are between
5 x 10-4 em/sec and 1 x 10-3 em/sec. These fall within the expected range
of hydraulic conductivities of silty sands to clean sands. .
Average linear groundwater velocities for the western half of the site
range from about 2 ft/yr in the north (in the vicinity of the landfill) to
about 17 ft/yr in the south. Velocities for the eastern half of the site
vary from about 13-24 ft/yr. These velocities are based on an average
hydraulic conductivity of 1 x 10-3 em/sec and an assumed effective porosity
of 0.30.
The effect of the landfill on groundwater elevation, direction, and
velocity can be estimated, but cannot be fully assessed because of the lack
of information on the groundwater beneath the landfill. Water levels
measured in monitoring wells adjacent to the landfill indicate that a
groundwater mound may be present, but does not extend beyond the estimated
landfill disposal area boundaries.
The shallow aquifer appears to be continuously underlain by a silt or clay
till of low hydraulic conductivity whose thickness ranges from 15 to 27
feet. Most of the low hydraulic conductivity materials in this confining
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LEGEND
o Mo.1, M-z. OW01, DW.Z. OWo3. OWo! PRE.PHASE I MONITORING WEI.I.S
o MWac PHASE I MONITORING WEI.I.S
o MW85 PHASE II MONITORING WELI.S
o MW86 PHASE III MONITORING WELLS
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ELEVATION OF CONTOUR L.INE
MEASURED GROUNDWATER ELEVATION (FT)
1/2 FTCONTOUR (ONLY AT 808.5)
INFERRED CONTOUR LINE
GROUNDWATER ELEVATION CONTOUR LINE
DIRECTION OF POTENTIAl. GROUNDWATER FI.~\V
808
10&.25
Note: Contour Intent.' - 1 ft.
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500'
I
250' .
SCALE IN FE ET
FIGURE :3
GROUNDWATER ELEVATIONS IN
THE SHALLOW AQUIFER
MAY 12,.1986
FOREST WASTE RI
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3
layer are clay tills, but a predominantly silt till is present in the upper
9 feet near the northwest corner of the site.
The hydraulic conductivity values for the till, calculated from falling
head permeability test, range from 1 x 10-7 to 5 x 10-8 em/sec. Based on a
hydraulic conductivity of 1 x 10-7 em/sec, an assumed effective porosity of
0.30, and a vertical hydraulic gradient range of 0.4 to 0.8 ft/ft, the
average downward groundwater velocities range from 0.14 to 0.28 ft/yr.
The deep aquifer varies from 7 to 27 feet in thickness. The composition
varies from a slightly silty, fine to coarse sand to a relatively clean
sand and gravel. In general, the deep aquifer groundwater flows toward the.
southeast in the western portion of the site and toward the southwest in
the eastern portions of the site as shown in Figure 4. Horizontal
hydraulic gradients for both flow paths are similar, ranging from 0.001 to
0.003 ft/ ft.
Water levels in the deep aquifer are consistently 11 to 15 feet lower than
those in the shallow aquifer. Downward vertical gradients between the two
aquifers range from 0.4 to 0.8 ft/ft. The differences in both the water
levels and the flow directions of the upper and lower aquifers indicate
that the hydraulic connection between aquifers is. limited.
In situ hydraulic conductivity testing determined that hydraulic
conductivities of the deeper aquifer range from 1 x 10-3 em/see to 7 x 10-
5 cm/sec. Based on a hydraulic conductivity of 1.3 x 10-3 em/sec, an
assumed effective porosity of 0.30, and a '~orizontal hydraulic gradient of
0.001 to 0.003 ft/ft, the groundwater velocities range from 4 ft/yr to 13
ft/ yr .
.
The Forest Waste Disposal site lies just west of a marshy area. Surface
water bodies include a small lake 1/2-mile north of the site and a small
residential pond southeast of the site. Surface drainage across the site
is southeast to Butternut Creek. The marshy area west of the site also
. drains into Butternut Creek, which flows past the. southeast corner of the
site (approximately 1,000 feet from the eastern site boundary). Butternut
Creek flows southwest for 8 miles before discharging into the Flint River.
Residential wells in the vicinity of the site draw water predominantly from
the bedrock sandstone aquifer. The location of residential wells in close
proximity to the site and where known, the approximate well screen depth,
are shown in Figure 5.
SITE HISTORY
Previous Activities
Forest Waste Disposal is now closed. It was first operated as a sanitary
landfill in 1972. An Order of Determination was issued by the Michigan
Department of Natural Resources (MDNR) Water Resources Commission on
December 21, 1972, to property owners Walter and Elaine Rix to receive
limited types of liquid industrial waste in accordance. with Michigan Act
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4
245. Public Act 1929. as amended. Subsequently. under Michigan Act 87.
P.A. 1965. licenses were issued to the property owners to receive general
refuse. and industrial and liquid waste from December 10. 1973 to September
1. 1978. During this time. the landfill was also granted permission to
accept. on occasion. hazardous waste [i.e.. polybrominated biphenyls (paB).
polychlorinated biphenyls (PCB)] under MDNR and Genesee County Health
Department (GCHD) supervision. The exact date on which the Forest Waste
Disposal site began accepting waste is not known. but it is thought to be
. no sooner than when the licenses were issued. In 1974. the facility
accepted sludge and residual waste from the Agrico Chemical Warehouse of
Bridgeport. Michigan. Likewise. PCB and PBa were disposed of at the site
in 1975.
In 1975. Mr. Rix died and ownership of the landfill was assumed by Mrs.
Rix. who currently resides in Florida. The site license was reviewed for
renewal in 1978; the GCHD did not grant renewal due to operational and
various other viol ations. As a result. r~rs. Rix was ordered to properl y
phase out the site according to the guidelines established under the
Michigan Solid Waste Management Act.
During operations of the site. incoming wastes to the landflill were not
screened by the facility owner. Drummed wastes from various sources.
including wastes transported to the site by Berlin and Farro Incineration.
were disposed of in the landfill area. The waste fill is covered. although
. refuse and rusty drums are exposed in some places.
.
.
MDNR files indicate the lagoons originallyJaccepted metallic sludges. which
were to be pre-treated before receipt onsite. and acidic and basic liquids.
which were_to be neutralized before shipment to the site.
Among the types of wastes which have been documented as being accepted at
the site. those suspected of being disposed of in the onsite lagoons
include the following: waste oils. septic tank waste. plating wastes.
phosphate zinc wastes. metal sludges. spent sulfuric acid. and paint
wastes. MDNR file information indicates that incoming wastes were not
screened by the facility owner and that the operator often mixed different
waste streams in some of the lagoons. The operator was also suspected of
discharging liquid wastes into the landfill area and onto the ground.
In December 1982. the site was placed on U.S. EPA's National Priorities
list (NPl) of abandoned or uncontrolled hazardous waste sites eligible for
investigation and cleanup under the Superfund Program.
In January 1984. a Remedial Action Master Plan (RAMP) for the Forest Waste
Disposal Site was completed by U.S. EPA contractors. The RAMP is a plan
for undertaking Remedial Investigation (RI) activities and identifying
appropriate initial remedial actions at a site. .
In 1984. the U.S. EPA constructed a fence around the site and posted
warning signs. The fence was installed to serve as a deterrent to
trespassers and thus help prevent humans from coming into direct contact
with hazardous substances at the site.
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LEGEND
o M.1. M.2. OW01. OWo2. OW03. OW-5 PRE.PHASE I MONITORING WELLS
o MW84 PHASE I MONITORING WELLS
o MW85 PHASE II MONITORING WELLS
o MW86 PHASE III MONITORING WELLS
"
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8Qg
808.25
ELEVATION OF CONTOUR LINE
MEASURED GROUNDWATER ELEVATION 1FT)
1/2 FT CONTOUR 10NL Y AT 808.5)
INFERRED CONTOUR LINE
. .
GROUNDWATER ELEVATION CO';HO'UR LINE
DIRECTION OF POTENTIAL GROUNOWATER FLOW
Nou: Conrour InreN.' - 1 h,
@
o
L
500'
j
250'
SCALE IN FEET
FIGURE +
GROUNDWATER ELEVATIONS IN
THE SHALLOW AQUIFER
MAY 12, 1986
. FOREST WASTE RI
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:;:<~ (' #~\)'D\J~t'H \ ':-':, ~-I~~"'1igHi",~~~-i22'~2~'~ ---~~- ~ II "
,- . ~ I""" ... -, . - ---- ~- . '0'0 .--
.. ' " ,-.' " A'~ .. . - -~
. , . . ,.,m . .
, .' -' \. '. "90,
-------
@
o 150
l .
SCALE IN fEET
I:
-
!
1.
!
--
LEGEND
'tJ. TEST PIT eXCAVATION
,~ eXPOSED DRUM SAMPLING AREA
U
F'jv(~ "
-------
5
In June 1986, U.S. EPA selected a cleanup alternative for the site lagoon
source materials. The lagoon cleanup action is in Remedial Design phase.
The selected lagoon remedial alternative is removal and offsite treatment
and disposal of lagoon liquids; and removal, onsite treatment, and offsite
disposal of contami nated 1 agoon sediment, sl udge, and soil.. Construction
for lagoon cleanup is scheduled for Summer 1988.
In 1987, ownership of the FWD site was assumed by MDNR because of tax
payment delinquency by the previous site owner.
Current Site Status
In December 1983, a Remedial Investigation (RI) was initiated to define the
nature and extent of contamination at the site and characterize the
potential threats to public health and the environment from the site. RI
field activities were performed in three phases and were completed in April
1987. The RI included geophysical and hydrogeologic investigations to
define the site hydrology and hydrogeology and to better identify areas of
suspected drum burial in the landfill. Environmental sampling was also
performed to determine the type, extent, and magnitude of contamination at
the site.
The results of the RI are described in the RI report, dated August 28,
1987. This report also summarizes site data collected previous to the RI,
by the Genesee County Health Department ~GCHD), MDNR, and U.S. EPA.
The site Feasibility Study (FS) was completed January 20, 1988. The FS
documents in detail the development and evaluation of an array of remedial
action alternatives for the FWD site.
.
Site Characterization
The following discussion briefly summarizes the nature and extent of
contamination according to the respective media sampled during RI
investigations.
1 .
Landfill Contents
In general, five classifications of contaminant sources were
encountered during the landfill investigation: bulk wastes,
drummed liquids and solids, PBB-contaminated cattle feed, agricultural
chemical warehouse fire debris, and contaminated soil. It should be
emphasized that the landfill is incompletely characterized. Fifteen
test pits were excavated over the II-acre landfill area. The intent of
the investigation was not to fully establish the nature and extent of
contamination, but to verify some of the manifest and disposal file.
information for the site.
Buried drums were discovered at several test pit locations
(Figure 6). The drums contained primarily noncorrosive
volatile organic compounds (solid and liquid) in" high concentrations.
. _AU. _...-..... .'.....,~...."- ,,'-'.".,,\-""~'."-~. 'J- "".~,,;,,~"::~":':"i.'-."""_--::'~"'~.'.-v'-....~"'.',;~'.'.7"" ".-:'-;-'.,,',
;':~:-"i;' ,:::"..".-'-." ~:;-.:., ~7~' ;. ''''''', ~ ';f' ;~ (."'" .. ._.,..~ ';", ~:-."-:~'~-=;":''':':-~'=.''', ~~,....- . ~~-::':-., :.~'.'; ":,.- :::.~l"::'~7':if'. .~:':-::'.; :"r- '.~-~ "-;:'~::. ~'.''',",," .:-,.;-::-.
-~. ."; '.." '. ",'
-------
6
Test pit soils surrounding the drums were also found to be
contaminated with the same constituents present in the drums,
but at somewhat lower concentrations. This suggests that either
past disposal practices included the dumping of noncontainerized
liquids and sludges, or drum leakage has occurred. One perched
water sample taken from a test pit excavation also contained similar
volatile contaminants as discovered in the drummed solids and
liquids and test pit soils.
Cattle feed contaminated with PBB was found where indicated by
rmNR file infonnation.
2.
Groundwater
Two general areas of the shallow aquifer appear contaminated,
southeast and east of the landfill and southeast and east of the
lagoons. The area southeast and east of the landfill is
characterized by relatively high specific conductance values. This is
likely due to past brine disposal in that area of the site. In
addition, the shallow aquifer east of the lagoons contains areas of
relatively high pH (greater than 9) and several organic compounds
(trans-l,2-dich10roethene, 1,1 ,1-trich10roethane, toluene, 1,1-
dich10roethane~ and trich10roethene). The deep aquifer contained
several inorganic constituents at elevated levels above background;
however, no patterns or plumes were identified. Sporadic low
concentrations of organics were detected in the deep aquifer; however,
the types and distribution of constifuents did not reveal any patterns
of contamination. .
.
Table 1 lists the 18 organic constituents detected in groundwater
samples from both the shallow and deep aquifers at the site.
It is not apparent that the site contaminants found in the
landfill and the lagoons can account for the detection of organics in
the deep aquifer. Furthermore, the inconsistency in detection of
contaminants in the two aquifers suggests that contamination of the
shallow aquifer has not affected the deep aquifer. This is also
supported by the hydrogeologic characteristics (flow direction and
horizontal gradients) of the two aquifers and the confining unit
between them. However. interaction between the two aquifers is not
impossi b1e.
The nature of the release to the shallow groundwater suggests the site
lagoons are the source of this contamination. Several volatile
compounds found in the lagoons were also found in the shallow
groundwater to the east and southeast. The extent of this r~lease is
limited to onsite areas. RI data from monitoring wells surrounding the
landfill have indicated that waste releases from the landfill have not
affected groundwater downgradient from the landfill.
Residential drinking water wells wer~ sampled during the site RI.
No hazardous substance list organic compounds were detected in
-------
..V,J 'Y'.r\'
\ I '\ULt.I- I II /30/87
.,
.,
. '1
. ..
"
. " . i
" ..::.]
'. t'
. ,: ~
" .j
" .~
, '" ~
Monitoring Wells
West 0' The landfl"
en en
or- ('of
I I
~ ~
en en
..- .,.
I I
~ .,.
o co
"
Constituent
",.;
. ,
Benzene
" .
, .,
, ,
'j
,-~/.)
:'.-. ~:
I, I, I-Trichloroethane
I, I-Dichloroethone
Trons-Dichloroethene
.~" .
~'. :...: ~
. ~":;
,\,'~
Meth)'fene Chloride
T etrochloroethene
Toluene
,
Trichloroethene
-
Acetone
2-Butanone
2-HelCanane
--1-
'"
';1
Benzoic Acid
~.' "j
Phenol
.-;:,
;~ .
~.~
2-Meth)fphenol
4-Meth)fphenol
'",.
,.
":"J
1, 2-Diphen)'fhYdrazine
Bis (2-Eth)'fhex)'l) Phthalate
x X X
j
::i
Di-n-Oct)'lphthalate
.,
.:
en en en
It) 10 f')
I I I
.,. .,. It)
co co co
en VI
10 10
I I
It) 10
co CD
ena (:)
,.... " QJ
I I ~
10 'v
COU) ,
, ,
..
,.' ,.;
: 1';(
I:::
:,
:,';"i I'",::
,:", '.
I'::,
..
':. .,
'",: .:
'::',,':
',':",
k'I<:\
"'~ '.,
X
I X
. ,
. '
'"
Monitoring
Wells West O.
The lagoons
~ ~ ~ ~ ~ ~
I I I I t I
~ ~ ... It) 10 ~
a 0 co co co 0
..,
, .
,.
Note: Table entries reptesent organic constituents detected in a sample 'rom any
one of three phases 0' sampling, Shaded areas represent deep monitoring wells.
,!
X
, Source: forest Waste Site Remedial Investigation Report, August 1987.
. ,
'.,
, .
.
X
X X
;--
1--
x
. /~
,'.'
':',:
;,
."
"
X
X
X
X
X
X
X
X
Monitoring Wells
East 0' The lagoons
en en
N f')
I I
... ...
co co
X
X
X
X
X
X X
en en en
or- N .,.
I I I
It) It) It)
co co co
en en en en
N f') .,. It)
I I I I
10 10 10 10
co co co co
fi1 ~
"~ ,~
X
X
X
"
X
X
1-
1--1--_-
)(
x
TABLE 1
ORGANIC CONSTITUENTS
DETECTED IN THE GROUNDWATER
AT THE FOREST' WASTE SITE
fOREST WASTE fS
-------
7
the residential well water. Inorganic concentrations detected do
not suggest that the wells have been affected by the site.
Surface So i 1 s
3.
Inorganic constituents of primary concern in the landfill surface
soil included barium, lead, and nickel. Organic compounds, such
as polycyclic aromatic hydrocarbons (PAHs) and pesticides (DOT, DOE
endosu1fan, and dieldrin), were present throughout the landfill area.
PBBs were present in the northern surface portion of the landfill,
coinciding with the reported disposal area of contaminated cattle
feed. The peripheral areas of the landfill contained elevated
levels of arsenic (above background) and chlordane.
4.
lagoon liquids, Soil, Sediment, and Sludges
The constituents found in the lagoons are described in detail
in the Forest Waste RI report (August 28, 1987). The remedial
alternative for the lagoons has already been selected and design
is underway. Therefore, further discussion of the findings for
this docume~t is not necessary.
5.
Offsite Surface Water and Sediments
.
The type and distribution of c~pound~ detected in the offsite
surface water and sediments did not reveal any pattern of
contami nation. One surface water location has a number of
inorganic constituents that exceeded Federal Ambient Water
Quality Criteria. It is likely that the higher concentrations
of inorganics merely reflected the poorer quality of water
in the wetland area and the possible entrainment of suspended
solids in the shallow sample. .
RISK ASSESSMENT SUMMARY
A baseline risk assessment was performed as part of the FWD RI (Chapter 6)
to evaluate potential site hazards to pUblic health and the environment
assuming no remedial action is taken at the site. The risk assessment
included the following:
o Identification of potential
a Toxicity Assessment
o Exposure Assessment
o Risk Characterization
chemicals of concern
The potential chemicals of concern were identified in a conservative
fashion at this site. Distribution of site contaminants identified in the
RI was somewhat sporadic, indicating areas of discrete contamination as
opposed to area-wide contamination. Therefore, any chemical detected at
the site having a critical toxicity value .(i.e., cancer potency factor or
.:... .-,'~ -::r""--v.". .." -.' ¥':-:; ::-~.A¥"" .....--.-: -:J"'" -..., -- ~.- ~. ¥~.';. -""'.--"H ',":Y'''' ''''. "" ~., ".-',7"". . ~- ~ :.. .,
."", .:--- ..:, ""'''','': '-....';-~ ", -,""~'~""', ~ ,""'.
-------
8
reference dose) was identified as a potential chemical of concern. Six
additional chemicals, without critical toxicity values, were identified as
potential chemicals of concern, based on critical toxicity values. of
similar chemicals. Po1ybrominated biphenyl (PBB) was also identified as a
potential chemical of concern because of its persistence. and identification
as a potential carcinogen by the National Toxicology Program. Table 2
lists the FWD site potential contaminants of concern. .
Potential chemicals of concern were then described in terms of their
toxicological properties in a toxicity assessment.
In the exposure assessment, potential pathways by which humans and wildlife
populations could be exposed were identified. A pathway is considered
complete if all the following elements are present: A contaminant source,
a mechanism for chemical release, an environmental transport medium and
exposure point, and a feasible route of exposure. Exposure pathways are
considered for current and future land use conditions.
The exposure pathways of greatest interest under current land use
conditions are:
o Exposure of trespassers by direct contact with exposed
wastes and contaminated soil onsite
o Exposure of terrestrial .wi1d1ife by direct contact with
exposed wastes and contaminated soi1.onsite and by
contaminant uptake through the food chain
o Exposure of wildlife populations ~hat come into contact
with surface water/sediment contaminated by discharges
(runoff and groundwater) from the site
.
o Exposure of downgradient groundwater users from ingestion of
contaminated groundwater
Under a future land use for the site the exposure pathways of interest
include:
o Exposures from residential development associated with
direct contact with soil and groundwater use
o Exposures from commercial development associated with
direct contact with soil and from groundwater use
A Risk Characterization was performed in which public health and
environmental risks to potentially exposed populations were presented. The
public health evaluation was performed for each exposure media and
included: 1) a comparison of esti~ated intakes (of contaminated media) to
acceptable intakes for noncarcinogenic chemicals; and 2) an estimation. of
excess lifetime cancer risk from exposure to carcinogens. Due to the
sporadic nature of the contaminant results, maximum detected contaminant
concentrations were used in thi.s assessment. Under current land use
-------
Table
2
POTENTIAL CONTAMINANTS OF CONCERN
FOREST WASTE DISPOSAL SITE RISK ASSESSMENT
------------------------------------------------------------
CHEMICAL
------------------------------------------------------------
Ac:etone
Antimony
Arsenic:
8arium
8enzene
8eryllium
8is(2-ethylhexyl)phthalate
2-eutanone
Cadmium
Chlordane
Chromium
Copper
Cyanide
DOE #
DOT
1,1-DiC:hloroethane
Dieldrin
Lead
Manganese
Merc:ury
Methylene Chloride
2-Methyl Phenol
4-Methyl Phenol
Nic:kel
PAHs*
pee **
Phenol
Selenium
Silver"
Tetrac:hloroethene
Toluene
1,1,1-TriC:hloroethane
rl"'ichlol"'oethene
Vanadium
Zinc:
.
,j
------------------------------------------------------------
*PAHs which are cons~del"'ed carcinogenic assessed as a group:
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene',
chrysene, dibenzo(a,h)anthl"'ac:ene, and indeno(1,2,3-C:d)
pyrene.
# DDE assessed based on CDT criteria
** pee lacks numerical criteria. Addressed ~ualitatively.
.-,
.-. '. "'~_.~ r, - +.' . ~,r'. .-
. . - , ~ . ''''.' - :':"' ..y.'-'":"
. '". - , ..- ---;' .'. ....;~ '",..
:: :.~. -~. ."." -.."
. . ." . -,
". ",' ,."' .;
-------
,-
9
conditions, public health effects of concern were identified relative to a
direct contact exposure to landfill surface soil and surface drums in the
landfill area. Long-term exposures to landfill surface soil by trespassers
could result in a reference dose (Rfd) exceedance from lead ingestion and a
cancer risk greater than 1 x 10-6 from po1yaromatic hydrocarbons (PAH).
Figure 7 illustrates the areas of concern under a current land use trespass
setti ng for long-term exposures..
An acute exposure threat, furthermore, exists from the landfill via a
direct contact threat from highly concentrated contaminant source materials
identified on the landfill surface. An estimated 100-200 drums are exposed
at the landfill surface. Samples taken during the RI identified high
contaminant concentrations in drums. Results of a liquid sample from a
surface landfill drum, for example, detected a single chemical (toluene) at
34 percent by weight. .
Under current land use conditions, there is no public health threat from
the contaminated groundwater onsite. There are no current users of this
onsite groundwater, and groundwater transport modelling has shown, under
conservative modelling conditions, that the contaminants will not reach the
current offsite groundwater users. The suspected source of this
contamination, the onsite lagoons, is scheduled for complete cleanup in
1 ate 1988. .
Under future land use conditions, residential and commercial/industrial use
of the site was considered. In t~is setting, similar to the current land
use setting, long-term exposure to landft11 surface soil could result in
reference dose (Rfd) exceedances from lead ingestion and a cancer risk
greater than I_x 10-6 from PAHs. Also similar to the current land use
setting, surface exposed drums present an acute direct contact public
health threat. Figure 8 illustrates the areas of concern under a future
land use residential setting.
.
Under future land use conditions, the onsite contaminated shallow
groundwater may be used for drinking water. Using maximum detected
contaminant concentrations, the excess lifetime cancer risk under a
residential drinking water scenario is 1 x 10-5. No reference doses are
exceeded under the drinking water scenario.
A significant threat to the groundwater also exists from the landfill waste
material, particularly the drummed wastes. These wastes are in an.
uncontained situation; leachate generation and liquid waste releases may
eventually result in groundwater contamination. Due to the high
concentrations of wastes in the landfill, an uncontrolled release may
result in contamination to current offsite, as well as future onsite,
groundwater drinking wells.
Based on the RI data, exposures to contaminants in surface water and
sediments under a current use scenario would be of limited concern. The
population at risk is small, and releases of contaminants to this media is
undocumented. Under a future use scenario, current groundwater
contaminants which would eventually discharge to nea~by surface water
"', .-. ",':'. /f:O. . :" ; r:'....-:-..-. '::.".';';"-', ":".;~::".:' ~.~{'."\'~., 7"" ~.- ",:,.. : ":." . .;":. - :'.:~'. _..-r;::.:-~~:"'- ':'::~ :-.:::; ;"':'",;".'_.~ -:-:- '::.":-';-:-:
: -:. -",' :-;;.::~~::::- ('.."'::7,. ..' -,,:' ::~"": .- -, '. - :"-~':Y:'.-"" '.',':: : .~:;-.: ';'.:~ -: ~~:~;::. :...: .~':_' ;O;.:~,:"'..::~,,~::.,::;...:..,,: i'~
-------
--
/ SLOO1', - O:"*'-SLOO2
I Oa . 10.8 ' ,. 1er9
. SL011 DDT D.
I (D,.ldrinl 2. 10.7 0 ) ( . ,.Idnnl
o (Chlord.n.1
SLOO3
\4. 10-8
10..ldtlnl
SLooa
, . 10"0
(PAM's) I
GENERAL
DISPOSAL \
AREA
(LANDFILLI
\ ~~0~~.9 SL012.s I
\ 18i 2. 10 Gt I
~iSI2E!PI (PAM'sl
(, ;7~:fD Gt I
~eAOI I
"
SL013 (Phase II .J
3 . 10'"
10DT)
>
cC
~
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~
a:
CI
w
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cfr
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'~ -
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,p
~
~
\\
. \\
~
o SL010S
. .10'
(Chlord.n.1
SL012 0
3.,0.8
(Chlordan. I
SURFACE
IMPOUNDMENTS
LAGOON NO.1 ;-~
_-J
SL015
2 . 10.a 0
(Chlordlnel
--""'\
I ILAGOON NO. 5
'--
,.~
1 I LAGOON NO. .
--
,... ~ ,-----
LAGOON NO. 3 I \ 1- _1 LAGOON NO. 7
,--_J r--'
,.-. l- _,LAGOON NO. 8
LAGOON NO..' I r--,
(_J \. - _J LAGOON NO. t
1--"\
LAGOON NO. 2 I )
'- -'"
" -
o SL013 (Phas, II)
3 It 10-8
( Chlordane I
APPROXIMATE STUDY
AREA BOUNDARY
CJ
~ c:::J
a
II
____I~_---------_.-J '-------- .,'
------------- - --______1"---'''--
fARRA;:;DRO"AD--------'---------' ~
, I
@
o 300'
. . j
SCALE IN FeET
LEGEND" FIGURE 7
. INDICATES A CONTAMINANT . AREAS OF CONCERN
CONCENTRATION WHICH EXCEEDS CURRENT LAND USE
A REFERENCE OOSE (NONCARCIN. TRESPASS SETTING
OaEN) OR CANCER RISK 10
,~''': ":7':'" ,,;e'-, "''C,' "7'.'~'.Y> ;":,~~:":"~,,." E ASSUMED EXPOSuRE FOREST WASTE R'
. ~ 7:~~ ~.\":~ ;'. ~,~~.,~, .:'~':.:\: -..:~~:?..:~~~~(~,~..~: .~.~.:-:~:, ,". ',' '.':~:'- .~ -..,.;,.:.... .'.~'~.'.'.;': ".' c-. .~;. .. .
,""; , .;'''''~'.:''.Y'~ ".>. '.~"~' :~." -
..'J:'"
. :'~"~:-'~~,":,-. ~~r;.'~'. ~ ",":'-:-'-;:--" :;. ~.'.
-------
----~
105LOO1 51.011 "'" '51.002
7 . 10.7 2. 10~O 1 . 10"
f (Dieldrin' IClllordIIne,) IDDT, Dieldrin'
05L003
3 . 10'7 I
t IDitldrinl 51.008
7 . 10~.
, IPAM's) (
GENERAl.
DISPOSAl. I
AREA
I I1.ANDF I 1.1.)
, 51.020 /
6. 10" 51.012
'0IBi.12E)P, 2. 10.5. (
'\ IPAM'.)
( 51.014 I
" D'}RfD.
~EAD' I
5LOI3IPII8.e f) '" I
3 . 10.10 ..J .
IDDT'
>-
i
~
a::
a
1M
>
:
" ,,0
'", .
"\. II
~ .
'~ a
\p
~
~
\\
. \\
cfr
o 5L010
. . 10.7
(Chlo'dane'
51.012
3 . 10.7
IChlo,danelO
51.015
2.'0.7
IClllo'd.ne) 0
SURFACE
IMPOUNDMENTS
MWS4.35
LAGOON NO.1 -'-', 1 . 10.5
I . .
'- - - ~ ITCE, pce. MC. eenzenel
( ,LAGOON NO.5
'"'-
,.~
I I LAGOON NO. .
--
1--"
LAGOON NO. 2 , J
'--
- "'"\ .--~
LAGOON NO. 3 I .J ,- -1 LAGOON NO. 7
'- r--,
. r - (- _I LAGOON NO. .
LAGOON No..1 I r--J
(_J l - - LAGOON NO.1
.
MWS5-1
2. 10.v
(TCEI
.~
SLOI3IPII8.e If'
o 3 . 10.7. '
IChlordane'
APPROXIMATE STUDY
AREA BOUNDARY
C:J
~~
Cl
n .
---_J\- - ---------...J \.._----------':-_-----_J'~'---_J"--
---- -- ---------- -------~
FARRAND ROAD f'--_._----~\(
@
o 300'
. ,
. 5CALe IN FEET
LEGEND
.
INDICATES A CONTAMINANT
CONCENTRATION WHICH EXCEEDS
A REFEReNCE DOSE (NONCARCIN.
OGEN) OR CANCER RISK 10-6
UNDER THE ASSUMED eXPOSURE
CONDITION$.
FIGURE ..s;,-
AREAS OF CONCERN
FUTURE LAND USE
RESIDENTIAL SETTING
FOREST WASTE RI
::: ~:.:~:;~t?T~:}~1;)::S?:::'!~:~~T.'~~:':'~:~~-;;:.
..~ :~~'::",:.'."
'<::':;: ".~.
- ~ :"', ...,.-. ,.{ ':;00';-' ,'.
-------
10
bodies, are not likely to cause a public concern. If, however, a release
of landfill contaminants to the groundwater were to occur in the future, as
this groundwater release discharged to nearby surface water bodies, an
unacceptable threat to public health and the environment may result.
Table 3 lists groundwater contaminants detected in the RI compared to Safe
Drinking Water Act Maximum Contaminant Levels (MCLs) and Maximum
'Contaminant Level Goals (MCLGs). In one case, a compound detected from
groundwater samples exceeds the MCL. Trichloroethene (TCE) was detected at
11 ug/l. The MCL for TCE is 5 ug/l.
Tables 4A and 48 list the calculated contaminant concentrations of
groundwater from the contaminant plume on the eastern edge of the site,
before it would discharge to the nearest surface water body. These
calculations are based on maximum and mean contaminant concentrations
detected. These contaminant concentrations are compared to Federal Ambient
Water Quality Criteria (AWQC) for the protection of freshwater aquatic life
and State of Michigan Surface Water Quality Guidelines Levels for
Protection of Aquatic Life. If this plume is allowed to discharge to the
nearest surface water body, it does not appear likely that these criteria
will be exceeded.
For complete details of the Risk Assessment, Chapter 6 of the Remedial
Investigation (August 28, 1987) and Appendices A and C of the Feasibility
Study (January 20, 1988) should be consulted.
COMMUNITY RElATIONS
.
.J
The Superfund activities at the Forest Waste Disposal Site have been
followed closely by the local community and press. The MDNR currently has
the lead role in community relations activities at the site. The State and
the U.S. EPA have worked together to keep communication with the community
open and frequent.
There is an active mailing list of local citizens who receive updates about
site activities. 'Newsletters are periodically mailed to the citizens,
updating them on recent site activities. Nine newsletters to date have
been sent to the community.
A Citizens Information Committee (CIC) has been formed by the State. This
is a group of local citizens and Federal, State, County and local officials
with high interest in site activities. This group meets periodically to
receive information about site activities and exchange information about
community concerns. The committee members serve as liaisons between the
local citizens, and MDNRand U.S. EPA.
There have been periodic meetings held at the site to keep the public
informed of the site activities. The initial meeting was an RI/Fy kick off
meeti ng hel d f1ay 9, 1984. A more recent meeti ng was hel dafter '
finalization of the RI Report on October 1, 1987. At this meeting the
\.-:- "~ ._~. -,--,......- ';.".4":-"''':'_'~':'.''': .,-. "
. ;.". :.:;: ;.I',r.::.',~:-" -:.7-:-;--, :;:;:. :.'~~r~ :"':-"'-:-7:':.,~;.'.:.' .:'~~' -~.:::,---. .:-0,.. ;. . -' ~ .
" ;' .-..; :~~-':'~'~::; _,-7:.-:': .~." :t"~~.;~" ,..: . ~.-.."; ;:_''::'' ~-,~' :0.,:-:: -""_n.; .'"":; ~.:....;-- ',.~.:'.' -': . : .'~~:-~ D:;-;:'~:!~'; (:~~<:~:.:::~~:.~. ,0'
-------
hbll. 3
FOREST WAS1E DISPOSAL SI1E
SUMMAnV OF COMPARISON .oF MONI10RING WELL DA1A 10 STANDARDS, CRITERIA. AND GUIDELINES
Well
Che..ical
MCL
MCLG
Benzene
Trans 1.2-DiChloroethene
Methylene chloride
Tetrachloroethane
Trichloroethene
II
Highest
Reported
Concentration
MWB~-l
Tran. 1.2-Dichloroethene .
Trichloroethene .
II II
II II
II
II
;.
MWB4-3
Benzene'
Methylene chloride'
Tetrachloroethane'
Trichloroethene
MWB4-1
Methylene chloride
-------------------------------------------------------------------
.
Indicate. highe.t detected concentration found in ground Hater.
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public was provided with a handout which outlined the general categories of
remedial response activities under consideration for the final action at
the site.
A public meeting was held on February 17, 1988, to discuss the public
comment draft FS. The public comment period was held January 29 through
February 27, 1988. The attached responsiveness summary addresses speci fi c .
comments and questions raised at the February 17, 1988, meeting and during
the pUblic comment period.
ENFORCEMENT
u.s. EPA has identified approximately twenty-five Potentially Responsible
Parties (PRPs) for the Forest Waste Disposal site. U.S. EPA identified the
PRPs on the basis of site records and responses to information requests
submitted pursuant to Section 104 (e) of CERCLA.
A PRP steering committee has been established since May 1986 when the PRPs
were noticed for the operable unit'lagoon remedial action. The PRPs have
been active in exchanging information about the site since that tfme. The
PRPs have reviewed and commented on the U.S. EPA RI report, as well as
conducted and submitted their own FWD Endangerment Assessment and
Feasibility Study. Two meetings discussing approaches to site remediation
were held with the PRPs prior to issuance of the U.S. EPA Public Comment
Dra ft FS.
.
.
On January 13, 1988, representatives frori1 U.S. EPA and r1DNR met with the
PRPs in Lansing, Michigan to discuss the PRP recoamend proposal in the
Geraghty and Hiller Feasibility Study, dated December 181.-1987 for a
combined remedial action on the site lagoons, landfill, and groundwater.
The PRP proposal included: fence, site restrictions, groundwater
monitoring, pumping lagoon liquids for offsite treatment and disposal at a
RCRA facility, backfill lagoons and cover with a low permeability cap,
removal and offsite disposal of approximately 100 surface drums in the
landfill, and cover landfill with a low permeability cap. At that meeting,
U.S. EPA provided the PRPs with an updated outline of site remedial action
goals, and alternatives currently under consideration in the draft U.S. EPA
FS. This outline was also supplied to the public repository.
The discussions at this meeting focused on the protection needed for the
site shallow aquifer. The Agencies maintained the position that this
aquifer is a drinking water aquifer. The Agencies also expressed concerns
that the PRP proposed landfill action would not provide adequate protection
to the shallow aquifer.
Discussions at this meeting also focused on the preference cited in CERCLA
121(b). U.S. EPA representatives explained that the preference was for
treatment of hazardous substances to significantly and permanently reduce
their toxicity, mobility, and volume, and that conta'inment remedies, which
reduce mobility of hazardous substances to the groundwater do not satisfy
this preference. U.S. EPA indicated that the PRP proposal does not satisfy
this preference.
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12
u.s. EPA also stated that the lagoon operable unit remedy configuration was
not negotiable. This remedy was selected by U.S. EPA in June 1986 and is
currently in design phase. Several discussions with the PRPs about this
remedy took place before and immediately after the remedy was selected.
The PRPs were again offered the opportunity to undertake the lagoon remedy
as configured in the June 1986, ROD.
w
On January 22, 1988, representatives from U.S. EPA and MDNR met with the
PRPs in Chicago, Illinois. The PRPs presented a new site cleanup proposal
(dated January 21, 1988) which included: fence, site restrictions, removal
of approximately 100 surface landfill drums for offsite disposal, cover
landfill with a low permeability cap, construct slurry wall around landfill
perimeter, construct dewatering system at site perimeter with onsite
treatment and discharge, 30-year long-term maintenance of cap and periodic
groundwater monitoring, and pumping and treating shallow aquifer in. the
eastern area of the site. The PRP proposal also included a lagoon
remediation for offsite RCRA disposal of liquids, offsite RCRA disposal of
six inches of lagoon solids, and covering lagoons with a low permeability
engineered cap.
The above comment from the January 13, 1988, meeting on lagoon cleanup was'
reiterated to the PRPs by U.S. EPA.
Concerns from the Agencies about the January 21, 1988, PRP proposal were
expressed, and included:
.
1.
A concern about the ability of a slurry wall to contain wastes
asso~iated with drums at the site.
2.
3.
A concern about meeting the CERClA 1211b) preference for treatment.
A concern that the containment system be maintained beyond 30
years.
The PRPs expressed concerns and an opposition to any landfill excavation.
The PRPs expressed concerns about short-term risks from landfill
excavation. The PRPs expressed concerns about defining the limits of a
partial landfill excavation.
On January 28, 1988, Special Notice letters pursuant to Section 122 (e) of
SARA of 1986 were sent to the PRPs. '
The most recent negotiations with the PRPs was held February 23, 1988, in
Chicago, Illinois and included representatives from U.S. EPA, MONR, and the
PRPs. The PRPs reiterated the merits of their January 21, 1988, proposal.
MDNR representatives discussed their concerns about the unknown extent of
drum excavation in the U.S. EPA preferred Alternative SRCVT. The PRPs
reiterated their concern about any landfill excavation activity.
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13
The January 21.1988. PRP proposal is considered a good faith proposal. The
moratorium for initiation of remedial action at the site will extend until
June 8. 1988.
DOCUMENTATION OF SIGNIFICANT CHANGES (SECTION 117~
The incineration treatment component of the selected. landfill remedial
action. Alternative SRCVT. and landfill A1ternativesRDN and RDF was scoped
in the FS and Proposed Plan to be implemented at a compliant offsite RCRA
incinerator. Cost information available at the time of the FS suggested
that use of an offsite incinerator would be less costly than use of an
onsite incinerator for the volumes of waste proposed in these alternatives
(see page 5-6 of the FS). Recent cost information has suggested that an
onsite incineration may be less costly than offsite incineration for the
volumes of waste slated for incineration in Alternatives SRCVT. RON. and
RDF.
These remedies are best configured to allow for the option of incinerating
these wastes onsite or offsite. depending on which option is less costly at
the time of remedy implementation. The short-term risks to the community
during onsite incineration are manageable and balance against the risks to .
the community during the offsite transport of wastes in the offsite
incineration option. An onsite incineration option was fully developed and
presented to the public for comment in Alternative RTD. No comment
specifically directed to onsite incineration was received during the Public
Comment Peri od .
.
."
The selected landfill Alternative SRCVT will be
onsite or offsite incineration of the excavated
bidding and award of this construction job. the
option may be incorporated into the remedy.
configured to include
drunmed wastes. In the
less costly incineration
AlTERNATIVES DEVELOPMENT
Remedial Action Goals
General remedial action goals outlined in the National Contingency Plan
(NCP) (40 CFR Part 300) and CERCLA as amended by SARA were reviewed. and
FWD site specific goals were established. In evaluating the findings of
the RI and Risk Assessment. two separate areas of concern. or operable
units. were identified at the site: 1) soil and landfill contents; and 2)
groundwater at the ~astern end of the site. Specific goals for each of
these two operable units follow. .
The specific remedial action goals for the soil and landfill contents
operable units are:
o Prevent direct contact exposure to soil or landfill sources that
contain contaminant levels in excess of target concentrations for:
Noncarcinogenic health effect protection (based on reference
doses)
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14
Excess lifetime cancer risk in the range of 10-4 to 10-7
o Prevent migration of contaminants from the soil or sources in
the landfill to a drinking water aquifer that would contaminate
groundwater to concentrations:
Greater than the MCLs
Exceeding the lifetime health advisories
Exceeding levels for noncarcinogenic health effect protection
(based on reference doses)
- Resulting in an excess lifetime cancer risk range of 10-4 to 10-7
o Prevent migration of contaminants from the soil and sources in the
landfill to a surface water body that would result in contamination
to levels greater than the Federal Ambient Water Quality Criteria or
State of Michigan Surface Water Quality Guideline levels for the
Protection of Aquatic Life.
o Control future release of contaminants to ensure protection
of human healt~ and the environment (SARA Section 121 (d))..
o Consider a preference for remedies that permanently and
significantly reduce toxicity.'mobili~. or volume of hazardous
substances through treatment to the greatest extent practicable
Sec 121( b).
.
(SARA
The specific remedial action goals for the groundwater operable unit are:
o Assure the quality of groundwater in drinking water aquifers
and prevent migration of contaminants to a drinking water aquifer
that would contaminate groundwater to concentrations:
Greater than the MCLs
Exceeding the lifetime health advisories
Exceeding levels for noncarcinogenic health effect protection
{based on reference doses)
Exceeding a lifetime cancer risk of range 10-4 to 10-7
o Prevent migration of contaminants to surface water body that
would result in contamination to levels greater than the Federal
Ambient Water Quality Criteria or State of Michigan Surface Water
Quality Guide1.1ne levels for the Protection of Aquatic Life.
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-------
"
15
The identified shallow and deep aquifers, as well as the bedrock
aquifer underneath the FWD site, are considered drinking water aquifers.
The shallow aquifer is not currently used as a drinking water source. This
aquifer, however, if unaffected by the site contaminants, would be of
sufficient quality and quantity to be used as a drinking water source.
Technology Screening
Appropriate remedial technologies process options were screened in the FS.
Fifty-five soils and landfill contents operable unit remedial technology
process options were initially identified for screening. Thirty-four
groundwater operable unit remedial technology process options were
initially identified for screening. These process options were evaluated
relative to their ability to achieve the remedial action goals, ability to
meet Federal and State applicable or relevant and appropriate regulations,
and implementability relative to site conditions. Twenty-seven soil and
landfill operable unit process options, and sixteen groundwater operable
unit process options remained after initial screening.
A second screening of technology process options was performed based on
technology performance (action accomplished), reliability (proven
operation), imp1ementability (ease of construction), safety associated with,
construction and operation, and relative costs. After this screening,
thirteen soil and landfill contents operable unit remedial process opti~ns,
and seven groundwater operable unit remedial process options were retained
for development of remedial alternatives. Only technologies which survived
screening were used to formulate r~edia1 alternatives.
.
."
Al ternatives Development
Using the established remedial action goals, the FS then assembled the
identified technologies into operable unit remedial alternatives
(combinations of technologies to remediate the operable units).
Alternatives which encompass a range of choices for remediating the
operable units were developed. This range included, for each operable
unit, to the extent feasible:
'0 A no action alternative.
o At least one alternative that involves containment of waste
with little or no treatment, but provides protection of human
health and the environment by preventing potential exposure
or by reducing the mobility of the waste.
o Treatment alternatives ranging from one that would eliminate
the need for long-term management (including monitoring) at the
site to one that would use treatment as a principal element
to reduce the toxicity, mobility, or volume of contaminants.
-------
\
16
Description of Alternatives
The remedial alternatives are organized into two groups: a list of eight
alternatives to address the soil and landfill contents operable unit, and
list of four alternatives to address the groundwater operable unit.
All alternatives developed include implementation of the lagoon operable
unit selected remedy.
1.
Landfill Soil and Source Material
A1 ternative NA - - No Action
Total Present Worth:
Construction Cost:
Present Worth O&M Cost':
Annual O&M Cost:
Time to Implement:
$0
$0
$0
$0
none
Alternative NA assumes that no further corrective actions take place and
that no restrictions are placed on future uses at the site. The fence that,
was installed in 1984 will remain onsite. Repair and maintenance of the
fence will be continued by MDNR. This a]ternative also recognizes that
liquids, soil, sediment, and sludges associated with the lagoon wastes will
be removed as planned for in the lagoon operable unit selected remedy.
This alternative is considered as q baseline scenario to which other
alternatives can be compared. ..1
.
Alternative SR - Site Restrictions
Total Present Worth:
Construction Cost:
Present Worth O&M Cost
Annual O&M Cost:
Ti me to Impl ement:
$1,430,000
$74,000
$1,390,000
$202,500
3 Months
The major components of Alternative SR are:
limitations), fence, and monitoring.
access restrictions (deed
"'
Deed limitations would be placed on the Forest Waste property and areas
immediately surrounding the site. The deed limitations would prohibit
excavation of soil and/or landfill contents that might occur during future
property development. The fence that was installed onsite in 1984 will
remain. Regular repair and maintenance of the fence wi'll be performed by
r~DNR.
Contaminant migration from the soil and landfill contents would be. assessed
through a groundwater monitoring program.
Eight new monitoring wells (five shallow, three deep) would be installed
around the landfill perimeter. A total of'21 wells (15 shallow, 6 deep)
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-------
17
would be sampled and analyzed to detect changes in the groundwater
characteristics under the landfill area.
Sampling and analysis of groundwater would be performed quarterly during
the first 5 years and semiannually thereafter. Samples would be analyzed
for CLP organic and inorganic parameters. PBBs. dioxins. and conventional
parameters such as chloride. sulfate. nitrate. nitrite. specific
conductivity. and alkalinity. Water levels of the monitoring wells would
be taken at the time of sampling and gradients would be calculated and
compared to existing data.
Alternative SRC - Site Restrictions with Soil Cover
Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Annual O&M Cost:
Time to Implement:
$2.070.000
$663.000
$1.390.000
$206.500
2-3 Weeks
The major components of Alternative SRC are: access restricti9ns (deed
limitations). fence. monitoring. and soil cover. Access restrictions.
fence. and monitoring are similar to Alternative SR. Alternative SRC adds
a soil cover over the contaminated soils and landfill area.
.
A 2-foot minimum thick soil cover ~ould be placed over the landfill and
associated contaminated soil to prevent di~ect contact with the
contaminated materials. The cover would not be designed to prevent
infiltration of precipitation into the landfill. The cover would consist
of onsite borrow soil. Prior to placing the cover. the landfill area would
be graded to fill existing depressions. eliminate any sharp grade changes.
and improve surface runoff. After placement. the cover would be seeded and
shaped to maximize evapotranspiration and minimize water ponding over the
contaminated area.
Maintenance and repair of the soil cover would be needed periodically.
Alternative SRCV - Site Restrictions with Cap and Vertical Barrier
Tota 1 Present Worth:
Construction Cost:
Present Worth O&M Cost:
Annual O&M Cost:
Time to Implement:
$9.700.000
$8.006.000
$1.554.000
$250.000
12 r~onths
The major components of Alternative SRCV are: access restrictions.{deed
limitations). fence. monitoring. RCRA cap. and vertical barrier.
Access restrictions and monitoring are similar to Alternative SRC. A new
fence would be installed around the landfill area to protect the cap and
. . -.... ,.- .....~. ..-. .... - .... ._.~ "'r-''''--''.-'''"1.,,:r.-.'''' ~ '7!:.~'''': -.-".. .. . ,':;:r~'~'::~~. ,--"-:-~:'..r:', ::.::..:~~ .~~. -:. "'-:r:;;:; 7:<:": -. .:~;:':,::,-:> ':,'. .:-.~~' (,~,,-,:-:,-;._'~~;~:':" :_~~t.:. ..": :.., ~":''',:,'-''.;:.?'-', :~~:~:: .{. :." -'.~::~~ .::''''~i"f~'~'~';::;:';~:':;':J':': :';~:..~:~L'...~. '''''''~'::;:;:, -~:
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18
prevent access to gas vents and groundwater monitoring manholes.
of the fence would be buried.
The foot
Alternative SRCV uses a multilayer cap and adds a barrier around the
landfill perimeter. The cap and vertical barrier are intended to
effectively contain the contaminants by preventing infiltration into the
landfill area and contaminated soil (cap). and restricting groundwater
movement within the landfill (vertical barrier).
The RCRA cap would be constructed as specified in RCRA regulations and
guidance. A gas collection system for the cap would be installed.
A soil-bentonite slurry wall vertical barrier would be constructed in the
native soil surrounding the contaminated area. The wall would be
approximately two feet wide and 35 feet deep. The bottom of the wall would
be keyed into the low penneability glacial till layer underlying the site.
A dewatering system would be installed inside the wall to lower the water
level under the landfill. creating a head differential toward the landfill
and collecting any releases of liquid wastes inside the landfill. No
adverse effects to the wetlands east of the site is anticipated from this
dewatering and groundwater diversion. .
Operation and maintenance for Alternative SRCV would include routine
monitoring and ~eriodic repair of the cap. vertical barrier, and gas
collection system. Groundwater collected from inside the landfill
(leachate) would be periodically collected and properly disposed of or
treated. Proper treatment or disposal of the landfill leachate would be
.J
determined in design activities after leachate quality is determined.
.
Alternative SRCVT - Site Restrictions with Cap and Vertical Barrier,
Source Drum Removal, and Treatment
Total Present Wo.rth:
Construction Cost:
Present Worth O&M Cost:
Annual O&M Cost:
Time to Impl ement:
$22,530.000
$20.837.000
$1,554.000
$250.500
12 r10nths
The major components of Alternative SRCVT are: access restrictions.
monitoring. fence, RCRA cap. vertical barrier, limited drum removal and
incineration. All components of this remedy. with the exception of the
drum removal and incineration. are similar to Alternative SRCV.
Prior to the containment activity, the areas of the landfill with.
concentrated drummed wastes would be excavated. and drummed wastes would be
incinerated onsite or transported offsite for RCRA incineration. 50ils
saturated with contamination from the excavated drums would also pe
incinerated onsite or transported offsite for RCRA incineration. The drum
removal activity would be limited in scope and would not include excavation
of the entire 11 acre landfill.
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\
19
An estimated 4,000 drums of waste and 1,000 cubic yards (4,000 drums) of
contaminated saturated soil would be excavated from the landfill for
treatment. The exact extent of the area of concentrated drums would be
determined in remedial design phase. The FS estimate for the number of
drums is conservative, based on currently available information. The cost
estimate for this remedy, therefore, is conservative. In remedial design,
the cost estimate for this remedy would be more refined.
Air monitoring would be conducted during excavation and the potential
onsite incineration to evaluate exposure risks from fugitive dust generated
during excavation and to assure compliance with air quality standards.
Stormwater runon/runoff would be controlled during excavation through
grading, the construction of berms, etc., as necessary to minimize the
amount of stormwater drainage that contacts contaminated excavation
materials and to ensure that any contaminated stormwater is collected and
disposed of with the excavated drums.
Alternative RON - Removal, Source. Drum Treatment, and Onsite Disposal
Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Annual O&M Cost:
Time to Implement:
$29,620,000
$28,681,000
$746,000
$102,000
5 Years
.
The major components of Alternative RON are: complete waste removal,
onsite or offsite incineration of drummed wastes, redisposal of remaining
wastes in onsite RCRA-type landfill, and RCRA landfill monitoring.
Approximately 200,000 cubic yards of material would be excavated from the
landfill area, resulting in a volume of 260,000 cubic yards of loosened
material. Air. monitoring and stormwater drainage controls would be
performed during excavation as described in Alternative SRCVT. It is
estimated that approximately 4,000 drums of waste materials would be
encountered. The drums would be incinerated onsite or transported offsite
for RCRA incineration treatment.
Remaining bulk waste would be treated as necessary onsite to remove free
liquids, redisposed into a RCRA-type landfill, and covered with a RCRA cap.
The newly constructed landfill cell would be located within the previous.
area of waste disposal. Groundwater monitoring would be performed as
required by RCRA post-closure requirements.
Operation and maintenance would include leachate collection and disposal,
periodic groundwater monitoring, repair of the landfill cap, and gas
monitoring. .
..-..~-,.'" '''''-'.i.;.''--~:''''_:'-..--''~' t--.;"'~~".:""~.. '''.,i~'''':.',,_.'--.' or,:" ."
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20
A1 ternative RDF -Removal, Source Drum Treatment, and Offsite Di sposa1
Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Annua10&M Cost:
Time to Imp1 ement:
$61,920,000
$61,899,000
$0
$0
2 Years
Components of Alternative RDF are similar to Alternative RON, with the
exception of the disposal facility. Materials slated for disposal would be
taken to an offsite RCRA-approved landfill.
There would be no long-term operation and maintenance activities for this
alternative.
Alternative RTD - Removal, Treatment and Disposal
Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Annual 0&", Cost:
Time to Implement:
$130,500,000
$66,364,000
$63,888,000
$16,742,000
5 Years
The major components of Alternative RTD are: 1} removal of all
contaminated landfill materials, 2) treatment of all combustible excavated
materials in an onsite RCRA-type incinerator, 3} dewatering, as necessary,
of the noncombustible excavated materia1s.~nsite, and 4} disposal, as
necessary, of treatment residuals and untreated materials in an onsite
RCRA-type landfill.
.
The operation and maintenance would be as described in the Alternative RDN.
The onsite treatment system would require trained operators. During
excavation and treatment, appropriate air monitoring and, as necessary, air
controls would be exercised. Stormwater drainage controls would also be
exercised.
2.
Groundwater
Alternative NA - No Action
Total Present Worth: $0
Construction Cost: $0
Present Worth O&M Cost: $0
Annual O&M Cost: $0
Time to Implement: none
This alternative is described under the soil and landfill content~ operable
unit section. No further action is taken to address the contaminants
currently identified in the groundwater on the eastern side of the site.
The identified contaminants would be allowed to migrate with groundwater
flow. Any change in groundwater quality would be due to natural dilution,
- .'.. ':-""~';"'."';':-"'~" ""':'-~"''''''''-'_'I''---'''' ;-.~. ~'. . ~",." ., ,- ."-:_-:~'---"'.-'-
, .
-------
21
adsorption and biological degradation. No monitoring would be performed,
therefore, no further information about groundwater quality would be
gained.
. Al ternative SR - Site Restrictions
Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Annual O&M Cost:
Time to Implement:
$1,290,000
$24,000
$1,254,000
$189,500
2-3 Weeks
The access restrictions component would be as described in the soil and
landfill contents Alternative SR. Deed restrictions would be implemented
to specifically prevent installation of new drinking water wells in the
shallow aquifer at the site or in adjacent areas.
Changes in the location and concentration of the groundwater contamination
would be assessed through a groundwater monitoring program. RI data
collected on the groundwater to date indicate that with one exception, all
groundwater remedial action goals are currently being met relative to the
quality of affected groundwater (see Remedial Action Goals Section). The
exception met is.a sample of groundwater from onsite monitoring well number'
MW85-1 that detected trichloroethane (TCE) at 11 ug/1. The MCL for TCE is
5 ug/1. The monitoring would be configured such that if groundwater
quality at the site boundary is anticipated to exceed any of the
groundwater remedial action goa1s,'a remedjal action plan for groundwater
cleanup will be developed.
.
The monitoring program would include two new monitoring wells (deep)
installed downgradient of the plume. A total of 14 wells (9 shallow,S
deep) would be sampled and analyzed to detect plume movement or changes in
the concentrations. In addition, a newly installed or currently available
upgradient background well would be sampled to establish background
groundwater quality. .
Sampling and analysis of groundwater would be performed quarterly during
the first 5 years and then the program would be reevaluated for changes in
analyses and sampling frequency. Samples would be analyzed for CLP organic
and inorganic parameters and for conventional parameters such as chloride,
sulfate, nitrate, nitrite, specific conductivity, and alkalinity. Water
levels of the monitoring wells would be take at the time of sampling and
gradients would be calculated and compared to existing data.
Annually, the quarterly results of the sampling and analysis program would
be averaged and compared to the groundwater remedial action goals. At the
site boudary (monitoring well nos. MW85-1S and MW85-2S), if on an a~erage
annual basis, the quality of the groundwater is greater than MCLs,
exceeding lifetime health advisories, exceeding levels for noncarcinogenic
health effect protection (based on reference doses) or exceeding a lifetime
cancer risk range of 10-4 to 10-7; or offsite, upgradient of the wetlands,
(monitoring well nos..MW86-4S, MW86-3S, and MW86-2S) if on an average
.' -f "-'~.,~1';'l;j~.~;'':',;~.n.,,:~~ "~~:,::;1"':'_~ -.:." '-::-{.'';t~:~~_:'~~'~:' j ~~~.-
. -.:": ~~,:---.:~~.':',if.;:.:..:~: ~~i'tY:'~":~~~.-~:':'~;~:.. ",~~ '~':-:"':;'.;'. ;;'~,~";..~\': 7'.~ ~~:>-;..-:.::;;...;. r.o' '~:'-<' -. . - .,':':'~"/;:~; ","; ;: ~:~:~:'..'< :.':' ~:', ':':::.. ;;~..::.;:.. . ,( ~:. 'S'Y:~~;~:::
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22
annual basis the quality of the groundwater is greater than Federal Ambient
Water Quality Criteria or State of Michigan Surface Water Quality Guideline
Levels for the Protection of Aquatic Life, a plan for further groundwater
remedial action would be evaluated.
Alternative CTGD - Collection, Onsite Treatment, and Discharge.
Total Present ~~orth:
Capital Cost:
Present Worth O&M Cost:
Annual O&M Cost:
Time to Implement:
$3,760,000
$326,000
$3,306,000
$465,000
15 Years
The major components of Alternative CTGO are: collection of contaminated
groundwater from the shallow aquifer, treatment of that water as necessary
to meet NPOES discharge permit requirements, and discharge of the water to
the Butternut Creek.
The groundwater collection system would consist of groundwater extraction
wells. Collection pipes from the wells would discharge to a common sump.
Water would be treated, as necessary, with granulated activated carbon to
assure compliance with NPDES permit discharge limits. The water would then.
be discharged to the Butternut Creek.
Alternative CTP - Collection and Offsite Treatment
Total Present Worth:
Capital Cost:
Present Worth O&M Cost:
Annua 1 O&M Cos t
Time to Impl ement:
.
$2,550,000
$20S,OOO
$2,319,000
$329,500
15 Years
. -
The major components of Alternative CTP are collection of contaminated
groundwater from the shallow aquifer and offsite treatment of the water at
a Publicly Owned . Treatment Works (POTW).
Collection of groundwater of Alternative CTP is similar to Alternative
CTGO. This alternative adds onsite groundwater storage prior to transport
offsite and treatment at a POTW. The pOSSibility exists that pretreatment
prior to discharge to the POTW will be required for compliance with POTW
local limits and Federal and State pretreatment regulations.
SUMMARY OF CIltPARATIYE ANAlYSIS OF Al TERHATIYES
Each of the alternatives were evaluated using a number 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){I) states that, "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 dispo.sal of hazardous substances or
"":'- :-r,..: ~'_,;.':--;""'.;o:'"""';-:":.-7~-;'~'~':':";"-:-~.~7.~'::-~;....'.;'.";~j~~-~~:::'~'''Y~~~'';'.!~'-';~-: <'~"i;;"'7~-''=.'':--'K'~-'P':;~~<;,::Y~~=-';::!'"':'0:~~~-'''-f~ '.~- ~:'~~~-"':'.~:~_1...- ."~':s:.~.~~:;:;:~ :."';-'~.' '=-"''''-'.: " ":7;"~~-;:';- "",...'''",'.:.:.:- -. . .-- ". ..~..--.>.
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.
23
contaminated materials without such treatment should be the least favored
alternative remedial action where practicable treatment technologies are
available.8 Section 121(b)(1) also states that the following factors shall
be addressed during the remedy selection process:
( A)
( B)
( C)
( D)
( E)
( F)
( G)
''''.'- . ~ .,.. "M,- : 1":,,"" ' ~
the long-term uncertainties associated with land disposal;
the goals, objectives and requirements of the Solid Waste Disposal
Act; .
the persistence, toxicity, mobility, and propensity to bioaccumulate
of such hazardouS substances and their constituents;
short- and long-term potential for adverse health effects from
human exposure;
long-term maintenance costs;
the potential for future remedial action costs if the alternative
remedial action in question were to fail; and
the potential threat to human health and the environment associated
with excavation, transportation, and redisposal, or containment.
Section 121 of SARA requires that the selected remedy is to be protective
of human health and the environment, cost-effective, and use permanent
solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
Alternatives were evaluated using current U.S. EPA guidance, including:
II Interim Guidance on Superfund Sel ection of Remedy" dated .December 24, 1986
and" Addi tional Interim Guidance fo"r FYI 87..1 Records of Deci sion I dated Jul Y
24, 1987. In the July 24, 1987, guidance, the following nine evaluation
factors are referenced:
.
1.
Overall Protection of Human Health and the Environment addresses
w et er or not a reme y provl es a equate protectlon, and describes how
risk are eliminated, reduced or controlled ~hrough treatment,
engineering controls, or institutional controls.
Compliance with ARARs addresses whether or not a remedy will meet all
OTthe appllcable or relevant and appropriate (ARARs) requirements of
other env~ronmental statutes and/or provide grounds for invoking a
waiver. (See discussion below).
2.
3.
Long-term effectiveness and permanence refers to the ability of a
remedy to malntaln rellable protectlon of human health and the
environment over time once cleanup goals have been met.
4.
Reduction of toxicity, mobility, or volume is the anticipated
performance of the treatment technologles a remedy may employ.
Short-term effectiveness involves the period of time needed to achieve
protectlon and any adverse impact on human health and the environment.
that may be posed during the construction and implementation period
until cleanup goals are achieved.
5.
- ::',. '. ...~....'::-- .""'''.-;-:.' .. .:u ,.:"., . - :~-:-~"r;:~';"';-:~::-- ~.,. .,;~;" ;~:~~'::'.3.:::~:-;'R'T~:;;:;:;.~:f~~~~.~::TS"'1;'.::?~-:~~~~~'';.~;'.~::.:..:.:..~~~~~ >~~~'~~~-;;':Y~_-:-::':~::'~.'~ ';,~::..-."
.' ".:'. - ~ :~'i ,:.': ';'.~' ~:~:: -::: -: ;:\.'~:' ;".~ ~:: ~J'''' ~:: .
-------
24
6.
Imp1ementabi1ity is the technical and administrative feasibility of a
remedy, including the availability of goods and services needed to
implement the chosen solution.
7.
Cost includes capital and operation and maintenance costs.
Support Agency Acceptance indicates whether, based on its review of the
RITFS and Proposed Plan, the support agency (MDNR) concurs, opposes, or
has no comment on the preferred alternative.
8.
9.
Community Acceptance indicates the public support of a given remedy.
This criteria is discussed in the Responsiveness Summary.
The analysis that follows was performed using the above factors as they
apply to each of the developed alternatives.
I.
A.
So i 1 and La nd fi 11 Contents
A1 ternatives Eva1 uation
A1 ternative NA
No protectiveness is provided by this remedy since no further action takes
place at the site. Short-term unacceptable risks remain from the
contaminated landfill surface soil, both to trespassers under the current
use scenario, and residents under a future use scenario. Short-term acute
unacceptable risk from drummed waste on the landfill surface also remain
under both current use and future use scenarios. The unacceptable 10ng-
term release of contaminants from the landfill to the groundwater also
remains. This long-term risk-to groundwater threatens current groundwater
users and future residential onsite users of the groundwater, as well as
surface water bodies near the site, which receive groundwater discharge.
No treatment to reduce toxicity, mobility, or volume of hazardous
substances is included as part of this remedy. This alternative does not
afford any permanence. The remedy will not meet the identified Federal and
State ARARs for the landfill.
.
No construction activities are associated with this
there are no construction imp1ementabi1ity issues.
no time to implement. This remedy is not supported
Michigan.
remedy. Therefore,
Th i s remedy wi 11 ta ke
by the State of
The estimated capital cost of this remedy is $0. The total present worth
is $0. Estimated annual operation and maintenance (O&M) cost is $0.
A1 ternative SR
.
Some short-term protectiveness is provided by this remedy by reducing the
threat of direct contact-risks from the landfill soil and surface
materials. This method of providing protectiveness, however, is not
reliable, since prevention of trespassers in current and future use
scenarios cannot be assured. The long-term risk of a. release of landfill
~- ~ .~ ~~. ~-~~~~~~_.~~~~~~.~,~:... .:--'-.';", :;~:;r;.' ': ~'::: ',."'r~
r"""-."---,,,,,,-,,,'(" .,
..~.<.,;... '~-"-;-"~T''?';'' '';-'-'-. 7\
. . . ...-.:":',-' ',,', , .' . .
..~ ;-.:~~:..~~-,..~ ';J..:~,:'~'-:
; , :..~.'.:~:~ - i,. ..: :!¥''-';r': ~~~. -.- '~::::'..~;.7}~ ,': :':~..'~'r
-------
25
wastes to the groundwater is not mitigated. The groundwater monitoring
will only provide the information that a release has occurred, should that
be the case. No treatment to reduce toxicity, mobility, or volume of
hazardous substances is included as part of this remedy. This alternative
does not afford any permanence. Protection of human health and the
environment provided by this remedy is not adequate. This remedy will not
meet the identified Federal and State ARARs for the landfill closure.
This remedy can be easily implemented within a few weeks. Activities
necessary to implement the remedy will not increase risks of exposure to
the community or workers. This alternative is easy to maintain and is
easily modified. This remedy is not supported by the State of Michigan.
The estimated capital cost of this remedy is $74,000. The total present
worth is $1,430,000. The estimated annual O&M cost is $202,500.
Alternative SRC
Short-term protectiveness is provided with this remedy by reducing existing
risks from direct contact threats from landfill soil and surface materials.
These materials are covered with a minimum of two feet of soil. This
method should be reliable in alleviating the direct contact threat to
trespassers. Deed restrictions, furthermore, may reduce trespassing. The
long-term risk of a release of landfill waste to the groundwater is not,
however, mitigated. Surface precipitation would be able to percolate
through the cover, and serve as a potential solvent for landfill wastes.
resulting in generation of 1eachat~. Such leachate, and liquids wastes
currently in the 1andfH1, may migrate to.; and contaminate groundwater.
The groundwater monitoring will provide information that a release has
occurred, .shou1d that be the case. No treatment to reduce toxicity,
mobility. or volume of hazardous substances is included in this remedy.
This alternative affords little permanence. Adequate protection of human
health and the environment is not provided by this remedy. This remedy
does not meet the identified Federal and State ARARs for the landfill. In
particular, the soil cover does not comply with RCRA 40 CFR Section 264.310
and Michigan Act 64 requirements for cover at final hazardous waste
landfill closure.
.
This remedy can be easily implemented with some quality control in
approximately three months. Risks to the surrounding community during
construction are negligible, and risks to construction workers are minimal.
This alternative requires minimal maintenance. Modifications to the remedy
would be simple, potentially requiring some cover alterations. This remedy
is not supported by the State of Michigan.
The estimated capital cost of this remedy is $663,000. The total present
worth is $2,070,000. The estimated annual O&M cost is $206,500.
Alternative SRCV
This remedy provides short-term protectiveness by eliminating direct
contact threats from landfill soil and surface materials with a RCRA cap
"-'-.'.,,:.. .''''''~:..r.",'':-'~''j''''''',;;';'"7:-P ...: ,"
4:: . - : ..~.., ~'t->"":' . -: 'i "".:' -:;;:;0': ~';'-:'.'~ ~:... . - ". :-. "': ".--~...:-:-:-.-;-: ;..:-~ - .:,: ..-: ~:.-~_-:"",.'::~.~7..~~~ ':'::::.",:'-'. ':.:-' . .:' ~,--.--""- -", . ':':-;' .;" -~ ? ~'''''':.~!'': \...: -~.
.~~ ,.:-':. "'~" ~":'-:~:: .~\;~:~..~ :~.:~':':~.7~~"~
-------
26
and deed restrictions. The cap is a reliable method to prevent trespassers
from the direct contact threat of landfill surface materials. The 10ng-
term risk of a release of landfill waste to the groundwater is mitigated
with the cap, slurry wall, and dewatering system combination. This
system serves to fully contain the landfill wastes. The possibility of
containment system failure exists if highly concentrated organic solvents
contact the slurry wall or underlying till and compromise the integrity of
the system. A properly designed leachate collection system should,
however, lessen such contact. The RCRA cap serves to significantly reduce
precipitation infiltration to the landfill, ultimately reducing the
potential for generation of landfill leachate. The slurry wall will fully
surround landfill source materials. The wall keys into the lower
permeability till layer underneath the site. The wall will prevent the
possibility of upgradient groundwater from coming into contact will
landfill source materials. The wall will contain liquid and solid
materials inside the landfill, and the dewatering system will actively
collect any liquids (leachate and liquid wastes released from drums) inside
the containment system. Collected liquids will be properly treated and
disposed of. The groundwater monitoring system will identify if a release
outside of the containment system (in the case of failure) has occurred.
Treatment of the liquids from the dewatering system, although not specified,
until the Remedial Design phase, will likely include some reduction of the
hazardous substance toxicity, mobility, or volume. This remedy is
primarily a containment remedy. Treatment is provided only to the liquids.
If properly operated and maintained, this remedy will provide adequate
protection of public health and the environment. There are reliability
concerns about the system's ability to contain high concentrations of
solvent type wastes associated with the drums. This remedy will meet the
identiJied Federal and State ARARs for the landfill.
This remedy can be constructed in approximately twelve months. The cap and
vertical barrier require some technical ability to implement and quality
control is necessary for an effective action. Construction workers and
equipment are available for implementation. Risks to the surrounding
community during construction are negligible, and risks to construction
workers are minimal since wastes remain in place. Maintenance of the cap
and slurry wall should be routine. Leachate and landfill gas collection,
and treatment, will be necessary over an indefinite period of time.
Modifications to the remedy would be difficult, due to the complex cap and
subsurface slurry wall. This remedy is not supported by the State of
Hichigan.
The estimated capital cost of this remedy is $8,006,000. The total present
worth is $9,700,000. The estimated annual O&M cost is $250,000.
A1 ternative SRCVT
This remedy provides the short-term and long-term containment
protectiveness as described in Alternative SRCV. In addition, the
reliability and long-term effectiveness of the containment system is
greatly increased because areas of concentrated drummed wastes are removed
and thermally destroyed. The known complete, or a precise percentage, of
.
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27
drums removed will not be known, since the entire landfill will not be
excavated. Drum removal reduces the likelihood of containment system
failure, and reduces the stress on the leachate collection system in
handling high contaminant concentrations from drum. releases. This remedy
provides additional treatment which significantly and permanently reduces
toxicity, mobility, and volume of hazardous substances. Drummed wastes
from concentrated disposal regions are destroyed offsite or onsite by
incineration. These drummed wastes contain high concentrations of toxic
contaminants which are relatively easily solubilized in water, therefore,
mobile in the environment. A principal element of the threat at the site
is treated with a permanent remedy. This remedy will provide adequate
protection of pUblic health and the environment. This remedy will meet the
identified Federal and State ARARs for the landfill.
This remedy can be implemented in approximately twelve months, including a
concurrent 5 month time frame for drum removal and onsite incineration or
offsite transport and incineration. In addition to cap and vertical
barrier installation concerns, precise definition and removal of
concentrated drum areas will present some implementability issues. Drum
excavation requires significant quality control. Construction workers,
equipment, and offsite treatment capacity are available. Additional risk
to workers beyond Alternative SCRV stems from drum excavation. Risk to the
surrounding community stems from offsite transport of drummed wastes or the
onsite incineration of drummed waste. Maintenance of the cap and slurry
wall should be routine. Leachate and landfill gas collection and treatment
should be less .than that in Altern~tive SRCV. r.todifications to the remedy
would be difficult due to the complex cap.~nd subsurface slurry wall. The
State of Michigan does not support this remedy. This remedy is also not
supported by the surrounding community residents. (See attached
Responsiveness Summary). .
.
The estimated capital cost of this remedy is $20,837,000. The total
present worth is $22.530,000. The estimated annual O&M cost is $250,500.
Al ternative RDN
This alternative provides reliable short-term protection by eliminating
direct contact threats from landfill soil and source materials with an
onsite RCRA landfill which will properly cover wastes. The long-term risk
of a release of landfill waste to the groundwater is mitigated with a.
combination of drum removal and offsite or onsite incineration and
disposal, and redisposal of all remaining landfill hazardous substances and
contaminated soil in an onsite RCRA-type cell. The onsite landfill can be
built in the previously located area of contamination, therefore, RCRA Land
Ban regulations for treatment may not apply. Such containm~nt is
considered very reliable: the RCRA cap prevents precipitation percolation
and leachate generation, the landfill cell contains non-drummed wastes in a
double lined system with leachate collection. The leachate collection
system will provide for active collection and treatment of leachate, as
needed. A groundwater monitoring program will identify. if a release from
the containment system has occurred. This' remedy provides thermal
destruction treatment of all drummed waste in the landfill. This
:..~. '.-', ':":~~-':';.~'7:..-,:'.;!'::,,::~':.~'-~"" - n
".'"?"" -. -;0;-::. .:'~":~":.:':-.- ~'.-:'.-:-: ~,..:::~:. ':~.~'- :;:'~"- ~:~~.;I ~-~ ~.-:::-'~~:,"c..-.--
)-<:~ ~:'::,:,,~,~.':::::r2':~~::~r~~j~' .:~~~'~:.Y~'. .~;. ~..
~~'.'; '., ",..".:-.. ".-: :.;..~-.-:~::,'~~.'..
-.. " , -.- ,~"r "
"
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28
alternative utilizes treatment for destruction of toxicity, mObility, and
volume of a principal element of the threat. This remedy requires some
maintenance, but affords a high degree of permanence. This remedy will
provide adequate protection of public health and the environment. This
remedy will meet the identified Federal and State ARARs for the landfill.
This remedy can be implemented in' approximately five years. This
alternative requires complete waste excavation from the landfill, resulting
in significant waste handling issues, and requiring considerable technical
ability and quality control to assure complete waste removal. Careful
design and quality control for building the onsite RCRA-type cell will be
needed. Exposure risks to the workers stem from the significant waste
handling and extensive waste excavation. The significant amount of waste
handling extends risks to the surrounding community in addition to the
risks from offsite transport of drummed wastes or onsite incineration of
drummed waste. Construction workers, equipment, and treatment capacity are
available. Maintenance of the RCRA-type cell should be routine and would
include periodic cap replacement. Leachate and landfill gas collection and
treatment will be necessary for an indefinite period of time. Leachate
quantity should be less than in Alternatives SCRV and SRCVT. Modifications
to the remedy would be difficult due to the engineered onsite RCRA-type
cell. The State of Michigan supports this remedy. The surrounding
community residents also support this remedy.
The estimated capital cost of this remedy is $28,681,000. The total
present worth is $29,620,000. The estimated annual O&M cost is $102,000.
.
Al ternative ROF
.~
This alternative provides reliable short and long-term protectiveness by
complete excavation and offsite removal of landfill wastes. All direct
contact and groundwater contamination threats from the landfill are
completely removed. This remedy also provides onsite or offsite thermal
destruction treatment of all drummed waste in the landfill and, therefore,
provides a similar degree of treatment and permanence as Alternative RON.
Long-term management of the non-drummed wastes is the responsibility of the
offsite land disposal facility. This remedy will provide adequate
protection of public health and the environment. This remedy will meet the
identified Federal and State ARARs for the landfill.
This remedy can be implemented in approximately two years. As with
Alternative RON, this remedy requires complete excavation of landfill
wastes, resulting in significant waste handling issues, and requiring
considerable technical ability and quality control to assure complete waste
removal. Exposure risks to the workers and surrounding community stem from
the significant waste handling and extensive waste excavation. Risks to
the community also exist because of the extensive offsite transport.
necessary for approximately 260,000 cubic yards of material. If onsite
incineration is employed, there would be short-term risks from this
treatment. No long-term maintenance activities are required for this
remedy since the offsite disposal facility is responsible for long-term
monitoring. Workers and equipment are readily available for this
~. .;~. :~:;;~~~ I' .:::;~~~ ~.~..- ~~,
......~ to-: ~..;
-':: ,
~,~:<..: /';!"--:. .~~:"":~:"-,~:,~,'-';:~;.-:,:;:: '. t"
..:"'-:-.;,:-~:'::"'."<:.! '::'.',';"':'~~"~"'" ~ .
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29
alternative, but the large landfill capacity needed for this volume of
waste may present some difficulties. The RCRA Land Ban regulations for
treatment prior to land disposal may apply, presenting potential serious
implementability issues, and additional costs than configured in the FS.
If no treatment is provided to wastes transported offsite for disposal,
this alternative is not preferred relative to CERCLA Section 121 direction.
There will likely be difficulties finding a land disposal facility in
Michigan willing to accept the PBB wastes. There may also be some
difficulty finding a landfill to accept the low level dioxin contaminated
wastes. The State of Michigan supports this remedy.
The estimated capital cost of this remedy is $61,899,000. The total
present worth is $61.920.000. The estimated annual O&M cost is $0.
Alternative RTD
This alternative provides reliable short and long-term protection with
complete landfill waste excavation. onsite thermal destruction of all
combustible materials in an onsite RCRA-type incinerator, onsite dewatering
treatment of non-combustible materials, and disposal. as necessary. of
treatment residuals and untreated materials in an onsite RCRA-type
landfill. The direct contact threat and the long-term groundwater threat
are mitigated. Onsite thermal treatment of all combustibles significantly
destroys the toxicity, mobility, and volume of hazardous substances. This
remedy provides the maximum amount of permanence, and practically
eliminates the potential for future ~xposure. This remedy will provide
adequate protection of public health and th~ environment. This remedy will
meet the identified Federal and State ARARs for the landfill.
.
This remedy will take approximately 5 years to complete and will be very
difficult to implement. Complete landfill excavation and waste sorting
will present significant waste handling issues. Considerable technical
ability and quality control will be needed to assure complete waste
removal. Careful design and quality control for building the onsite RCRA-
type incinerator and RCRA-type landfill will be needed. Operation of the
incinerator will be lengthy and will require careful quality control and
skilled operators. Equipment and specialists for onsite incinerator are
available, but limited. This alternative will require careful and
significant coordination with Federal. State and local authorities for
environmental regulation. This alternative presents exposure risks to the
workers and surrounding community during waste excavation and incinerator
operation. Long-term maintenance and operation of the RCRA-type disposal
cell should be routine, and less significant than the O&M in Alternatives
SRCV. SRCVT, and RDN. Modifications to this remedy would be difficult.
The State of Michigan has no comment on this remedy.
The estimated capital cost of this remedy is $66.364,000. Total present
worth is $130,500,000. The estimated annual O&M cost is $16.742.000.
: :~ . .'~'. .". ';:"i::~' "~~ '.\:'~ ?::~:~r;'.": '::.,,~:,~:::;: ::. ~'~:'~~":.':". :<'.:.('.{'~~~T~~~
.-- .-~'-'\.--- '.~" -..,." . -< .
.:::~' -.:'. .:~.'.> ""~::;.i'~ J~~", ~~~:;,:'.~~ ':.-.: .~;: ~~::- -'~~'.-~-~" ~~
.-.. .--:;, ~-'-'."'-,
. ."
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30
B.
Landfill Evaluation Summary
1. Overall Protection of Human Health and the Environment -
The Alternatives NA, SR, and SRC do not provide adequate human health
and environmental protection, therefore, are not eligible for further
consideration.
Alternative SRCV is configured to provide adequate protection, but
reliability concerns relative to the containment system for drummed
materials makes the protectiveness of this alternative somewhat
questionable.
waste
All remaining alternatives provide reliable protection, although they do so
through different combinations of treatment, containment, and institutional
controls. The greater degree of treatment, the less reliance on
containment and institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements -
All protective alternatives are designed to attain the applicable or
relevant and appropriate requirements of other Federal and State
envi ronmenta1 laws.
3.
Long-Term Effectiveness and Permanenc~ -
.
Alternative RTO offers the greatest degree of
wastes at the site. All wastes which cariJbe,
maximum amount of hazardous substance~ at the
cannot be treated and treatment residuals are
management of waste.
permanent management for the
are treated, destroying the
site. .On1y wastes which
left onsite for long-term
Alternatives RDN and RDF provide similar degrees of permanent and long-
term effective waste management. All drummed wastes are thermally
destroyed, and all remaining wastes are contained in a RCRA land disposal
cell which provides effective waste containment.
Alternative SRCVT provides permanent treatment for drummed wastes in
concentrated disposal regions, as well as associated saturated contaminated
soils. Permanent treatment for twice the volume of waste than in
Alternatives RON and RDF is proposed (4,000 drums of waste plus 4,000 drum
volumes of contaminated soil). The remaining wastes are managed with a
RCRA cap/slurry wall containment system. Such containment is less
effective over the long-term for waste containment than a RCRA cell.
Alternative SRCV relies entirely on the RCRA cap/slurry wall containment
for long-term effectiveness. Drummed wastes, which are not removed, may
cause some problems for the containment system over the long-term.
- -- -~~- ~. - r _-_'on. ~..._. --'u-. --- '~-'.~ ."'~' "------~ . ~- -.-~ '---'-'-"""-""""'-"""'''-''-''''---'-'--''.'- ',....-..- _-_''' ".,.. . ,. '-'-p' ~... ..-." .. ._.h- ... "_u_, . '''.n
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31 .
4.
Reduction of Toxicity, Mobility, or Volume -
Alternatives SRCVT, RON, ROF, and RTO offer treatment which provides
reduction of toxicity, mobility, and volume of hazardous substances as a
principal element.
. Alternative RTO offers the greatest degree of permanent and significant
reduction in toxicity, mobility, and volume of the hazardous substances
through treatment. Large volumes of waste (estimated at over 100,000 cubic
yards) would be incinerated.
Alternative SRCVT offers thermal treatment for an estimated 8,000 drums
(4,000 drums of waste plus 4,000 drum volumes of contaminated soil) or
2,000 cubic yards of material. The waste of concern in the landfill is
permanently treated. Landfill leachate would also likely be permanently
treated. .
Alternatives RON and ROF offer permanent treatment (incineration) for an
estimated 4,000 drums or 1,000 cubic yards of material. The waste of
concern in the landfill is permanently treated. Landfill leachate would
also likely be permanently treated.
Alternative SRCV does not offer reduction in hazardous substance toxicity, .
mobility, or volume as a principal element of the remedy. Landfill
leachate only would likely be permanently treated.
.
5.
Short-Term Effectiveness -
.J
Alternatives SRCV and SRCVT are most attractive in the short-term
effectivene~srespect of time to implement. Both alternatives are
estimated to take one year to impl ement. Al ternative SRCV woul d requi re no
waste excavation, therefore, no short-term human health or environmental
effects exist in that sense. Alternative SRCVT would require aboveground
waste handling of 2,000 cubic yards of material, and would include adverse
short-term effects regarding the offsite transport or onsite incineration
of this waste.
Alternatives RON, ROF, and RTO would required significant amounts of above-
ground waste handli ng and associated adverse short-term impacts. All
require complete landfill excavation (estimated to be 260,000 cubic yards
of material after excavation) with some waste sorting (Alternatives RON and
ROF to sort drums) to great amounts of waste sorting (Alternative RTO to
sort combustible from non-combustible materials). Alternative ROF also
includes offsite transport of all wastes from the landfill (estimated at
208,000 cubic yards. of waste), thus short-term effects exist from much
truck traffic and. some risks to the community exist during offsite
transport. If drums were incinerated offsite, Alternative RON would
include short-term adverse impacts from waste transport of an estimated
1,000 cubic yards of material. If Alternatives RON or ROF included onsite
incineration, there would be short-term adverse effects from short-term
operation of -an onsite incinerator. Alternative RTO would include adverse
short-term effects from long-term operation of the onsite incinerator.
',. '-'" ,~"."'<,-!r.",-.~.."'.~rr'~:f":>'~-"~-::'":':"'.: + .:' .
. ,",~. -':-:" ~'~.--.~;~.~;-;':,'~~"-.' <"-~"'7~ "----;.-= ': '.-~r':-:--::'7.=~:"1::-.":7_.~.-:-..~'':'.-'~:.~: ~""~-::-" .: :-.:: .':'"::, .'~ S?~.::~~.:~~? :'-:+.::~ :~~:~.~...' '::~~;''"::~~', ::.:~";\:':.~~~::!'.\:~'.~::~:..: J~'.:~':"~;.~
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32
Time to implement for Alternatives ROF. RON. and RTO are respectively 2
years. 5 years. and 5 years.
6.
Implementability -
Alternative SRCV would be the easiest to implement of all protective
alternatives because it requires no aboveground waste handling and relies
only on readily available materials and services. Some quality control
would be required in construction. Alternative SRCVT would additionally
require some landfill intrusive investigation to identify concentrated
areas of drum disposal, and aboveground handling of an estimated 2,000
cubic yards of material. Services and materials for this alternative
should also be readily available. There may be some difficulty identifying
a compliant offsite RCRA incinerator for the 8,000 drums of material. If
the drummed wastes are treated onsite, some careful qual ity control will be
needed for building and operating the incinerator.
Alternatives RON, ROF, and RTD require careful quality control in waste
excavation and sorting. There may be some difficulty in identifying a
compliant offsite RCRA incinerator for the estimated 4,000 drums in
Alternatives RON and ROF. Alterative RTO would require some quality
control in building the onsite RCRA incinerator, however, materials and
services should be readily available. Likewise, some quality control for
the potential onsite incinerator in Alternatives RON and ROF would be
needed. There would likely be some difficulty in identifying a compliant
offsite RCRA landfill disposal facility for the large amount of waste in
Alternative ROF (estimated at 208,000 cubic yards of waste). Additionally
identification of a land disposal facility willing to accept the PBB and
low'level dioxin contaminated wastes would likely be difficult. Materials
and services for Alternative RTO should be available, but the long-term
operation of the onsite incinerator would require significant quality
control and technical skill.
.
7.
Cos t -
Alternative RTO is by far the most expensive alternative with an estimated
present worth cost of $130,500.000. Alternative ROF is also clearly more
expensive than the balance of protective alternatives with an estimated
total present wOr'th cost of $61.920.000.
Alternatives RON and SRCVT are in the middle range of costs for protective
alternatives, with estimated total present worth costs of $29,620,000 and
$22,530,000, respectively.
Alternative SRCV is at the lower range of costs for protective
alternatives, with an estimated total present worth of $9,700,000.. The
cost difference between Alternatives SRCV and SRCVT is an estimated
$12,830,000. This additional cost provides permanent treatment for a waste
of ,concern at the site (drummed wastes) and long-term effectiveness for
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33
Alternative SRCVT. It should be noted that a permanent treatment
(incineration) for this waste of concern, is not available at any lesser
cost.
Alternatives which do not provide adequate protection at the site have
estimated total present worths of approximately $2 million and less.
8.
State Acceptance -
The State of Michigan will support Alternative RON and prefers Alternative
ROF. Alternatives NA, SR, SRC, SRCV, and SRCVT are not supported by the
State of Michigan.
9.
Community Acceptance -
Local community residents support the above State of Michigan position.
PRPs for the site support Alternative SRCV, and are opposed to Alternatives
SRCVT and RON.
II. Groundwater
A.
Alternatives Evaluation
Alternative NA
.
No public health risks currently exist from the onsite contaminated
groundwater, since there are no users of t~is water and migration of
contaminants to offsite groundwater users is highly unlikely. However,
this alternative provides no protection against future use of onsite
groundwater and provides no information about the change in groundwater
quality geo~raphically and over time, and the threat this change may pose
to public health and environment. This alternative provides no treatment
to reduce contaminant toxicity, mobility, or volume. This remedy is not
permanent. This remedy may not meet the identified Federal and State ARARs
for the groundwater. There are no limitations for.use of the shallow
aquifer as a drinking water source, and without monitoring, compliance with
the Safe Drinking Water Act MCLs is unknown. 'This remedy is not protective
of public health and the environment.
No construction activities are associated with this
there are no construction implementability issues.
no time to implement. This remedy is not supported
Michigan.
There are no costs associated with this remedy.
remedy, therefore,
This remedy will take
by the State of
Alternati ve SR
No public health risks currently exist from onsite contaminated groundwater
since there are no users of this water, and migration of the contaminants
to current offsite groundwater users is highly unlikely. This alternative
provides protection to future users of onsite groundwat~r with deed
",.:..... "-:--;':" ~ :."'.::'- ..-,-::-:; ._':;.'~'r' . ~A~'''.::;:J~,~~':~:,~.rr~~,:~,":~.~:r-::7;:~.j7!::::-:""-:~ .~-'t"~"';':..;'.:;;;?,"'d: .~.....--:.---:-;t.;"0;~'~.~:-~-T-.~~:. -:--. '.-'-:": ~.: """A_'!T ,""::"~ T'~.-;r~:!":.t:. .; -"'.;':" ;~~ ':~'~-.. -:'~ :-;,'~,:: .~=:-~
. :;~:~r ~",":-:"'...' ."
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34
restrictions that prevent use of this water as a drinking water source.
Enforcement of the deed restrictions should be implementable because the
site is currently under MDNR ownership and because of the low potential for
development of site property. The monitoring component of this remedy
provides information about changes in groundwater quality geographically
and over time. If a threat to public health and the environment is posed
by changes in groundwater quality, it will be identified and a remedial
action plan can be evaluated. This alternative provides no treatment to
reduce contaminant toxicity, mObility, or volume other than alterations
that may occur naturally through dilution, adsorption, and biological
degradation.
The suspected source (lagoons) for the groundwater contamination will be
completely removed in the lagoon operable unit remedial action currently in
design phase. Current groundwater contaminants should eventually discharge
to nearby surface water bodies, resulting in background groundwater quality
in the currently affected aquifer area. If the discharge of contaminants
to surface water bodies occurs in an environmentally acceptable fashion,
this alternative affords a high degree of permanence for groundwater
protection at the site. This remedy will meet the identified Federal and
State ARARs for the groundwater at the site. This remedy is protective of ,
public health and the environment.
Deed restrictions and installation of additional monitoring wells can be
easily and quickly implemented. Equipment and workers for this remedy are
-easily available. Groundwater will be easy to monitor. Modifications, if
necessary, could be easily implemented. Tpis remedy is not supported by
the State of Michigan.
The estimated capital cost for this remedy is $24,000. Estimated total
present worth is $1,290,000. Estimated annual O&M cost is $190,000.
.
Alternative CTGD
The public health and environmental risks are mitigated in this alternative
with groundwater collection, onsite treatment with granulated activated
carbon, and discharge of the treatment effluent to Butternut Creek, such
that NPDES discharge permit requirements are met. The spent carbon will
eventually be disposed of offsite. This alternative uses treatment to
reduce contaminant mobility and volume. This remedy will provide permanent
cleanup of the groundwater by completely removing the groundwater
contaminants. The reliability of this alternative is high. This
alternative provides adequate protection of public health and the
environment. All identified Federal and State ARARs for groundwater
cleanup are met by this remedy.
This alternative is quickly and easily constructed. Some technica\ ability
is required. Equipment and construction workers are readily available. .
Some administrative coordination to obtain the NPDES permit will be
required. The time of system operation, until the cleanup goals are met,
is estimated to be 15 years. No risks to surrounding community, and
negligible risks to site workers, exist with this remedy. Modifications
-.¥: .I~-,:,;:-.:~",:,":-.,.....~ .--~ :' .-.~ :::~.. ~ ..::: ~ :'" ;---::}'.:- ':~ ;~ .>--.~:: '.~ -:: -.;' :~.
. ~ ~ - '..~.;"._'~.:: .:.~: :,~:~~.:-:-":\~:/:-':~:':~-~'.::~ ~~?1;:~.~7~:~'::~":~ :;~'~'\~,~':=,-::':;,~C~'.~.;'" i~'~::.;'?r:"':~~~~-=:T :~::!:;,~:;~:;.~':t.;":..:,,,- .""",,:::,,~,~.;.,:~~::. ,;. '7 .
-.;. ._,....,..,...
'. . ,
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35
to this system are relatively easy.
remedial alternative.
The State of Michigan supports this
The estimated capital cost for this remedy is $326,000. Total present
worth is $3,760,000. Estimated annual O&M costs are $465,000.
Alternative CTP
Public health and environmental risks are mitigated by this alternative
with groundwater collection and offsite treatment and disposal at a
Publicly Owned Treatment Works (POTW). The treatment at the POTW will
significantly reduce the toxicity, mobility, and volume of groundwater
contaminants. This alternative will provide permanent cleanup of
groundwater by completely removing the groundwater contaminants. The
reliability of this alternative is high. This alternative provides
adequate protection of public health and the environment. All identified
Federal and State ARARs for groundwater cleanup are met by this remedy.
This alternative is easily and quickly constructed, requiring some
technical ability. Equipment and construction workers are readily
available. Significant administrative coordination with State regulatory
programs and the local POTW will be needed. The possibility exists that no
local POTW would be willing to accept the site groundwater. The time of
system operation "(groundwater pumping) until cleanup goals are met is
estimated to be 15 years. Risks to site workers and surrounding community
exist from necessary collection and transport of water. Modifications to
the treatment will be very difficul~ sinceJthe site waste stream is mixed
with others at the POTW facility. The State of Michigan has not supported
this remedial alternative.
.
The estimated capital cost for this remedy is $205,000. Total present
worth is $2,550,000. Estimated annual O&M cost is $330,000.
B. Groundwater Evaluations Summary
1.
Overall Protection of Human Health and the Environment -
Alternative NA does not afford adequate protection of human health and the
environment, and is not eligible for further consideration.
The three remaining alternatives afford adequate protection, although they
do so through different combinations of treatment, engineering, and
institutional controls.
2.
Compliance with Applicable or Relevant and Appropriate Requirements -
All protective alternatives are designed to attain the applicable Qr
relevant and appropriate requirements of other Federal and State
environmental laws.
3.
Long-term Effectiveness and Permanence -
. -. . ...~.~~- ~:...~ -- ... . .'" "'::~: '''~', ~'n..~. '~.:"~~' ..~.. '.;~~' ~'..~:: .~:~:~:". .~~~~:.~ . -.. :~ '--':.~-:~':~_-:~~; ., ::~."~'" .-:-:'" ~~.~.~~.: :', --.:. .":'-".~:~:.:~ '.::~ > ~ ,
. .:~.~~ ~~.' :r:'~~' ~:~:~:,:;:.~~.~~ ~S:::~; -"::-~. "-'~,~~:,-'.~~';.~~~"1~":~ !'~ '~~i::':.7.::-:'~:;~?~
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36
All protective groundwater alternatives are designed to assure complete
groundwater cleanups in an environmentally sound fashion.
4.
Reduction of Toxicity, Mobility, or Volume -
Alternatives CTGD and CTP provide for collection and the treatment of
contaminated groundwater, and in that sense provide for reduction in the
mobility and volume of the hazardous substances. Ultimate land disposal of
the spent carbon which has collected the hazardous substances in
Alternative CTGD, however, would yield no reduction in contaminant
toxicity. Treatment of groundwater offsite at a POTW would offer reduction
in contaminant toxicity.
5.
Short-Term Effectiveness -
Alternative SR requires little/no construction and waste handling,
therefore, provides the least amount of adverse short-term impacts of the
protective groundwater alternatives. Alternatives CTGD and CTP both would
require construction, and handling of contaminated groundwater.
Alternative CTP additionally would require transport of the contaminated
groundwater through the community.
6.
Imp1 ementabi 1 i ty -
Alternative SR is the easiest to implement of the protective groundwater
alternatives because it requires little/no construction. Alternative CTP
has potentially serious imp1ementa~i1ity issues relative to locating a
local POTW willing to accept the Forest Waste groundwater.
.
7.
Cost -
Alternatives CTGD and CTP have high range associated costs with estimated
total present worths of $3,760,000 and $2,550,000, respectively.
Alternative 5R is the least costly protective groundwater alternative with
an estimated total present worth of $1,290,000.
8.
State Acceptance -
The State has supported only Alternative CTGO.
9.
Community Acceptance -
No groundwater alternative was expressed as preferred by local community
residents. PRPs for the site maintain no groundwater cleanup is necessary
at this site.
SELECTED REMEDY AND STATUTORY DETERMINATIONS
I.
landfill 50i1 and Source Material
The selected remedy for landfill soil and source materials is Alternative
SRCVT. This alternative is protective of human health and the environment,
.:-- . " "':'~,:"" ~-..; ~ ': ':-:~:-"'-:': u.- .';!'-" ';-:V .
. ~"- .::--~~:~_.-:.-,-'')'':'::' :"7' ~ ,~,~,:'r;""',,,,--'."""~":-:' -.. - l(:~.",.-~....:;:--' ~- ~ .~.~;. "-:~I~'~:" ":'-;'.' ~ ",'\"j,"'
. :". -.. ".\. -.--:" -,""' .
,",. ...- "." - ::-: -. ~
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37
attains applicable or relevant and appropriate requirements promulgated
under Federal and State environmental laws. and is cost-effective.
Treatment which permanently and significantly reduces the volume, toxicity.
and mobility of hazardous substances is a principal element of the remedy.
Finally, this alternative utilizes permanent solutions to the maximum
extent practicable. This alternative represents the best balance of the
factors for selecting an appropriate landfill remedy at the site.
A.
Protection of Human Health and the Environment
Alternative SRCVT provides protection of human health and the environment
with a combination of treatment. containment. and institutional controls.
Short-term protectiveness is provided with the landfill RCRA cap and deed
restrictions. The cap is a reliable method to alleviate the direct contact
threat from the landfill surface materials to persons entering the site.
The long-term risk of release of landfill waste to the groundwater is
mitigated with the cap. slurry wall. and dewatering system combination.
This system serves to fully contain landfill wastes. The RCRA cap serves
to significantly reduce precipitation infiltration to the landfill.
ultimately reducing the potential for generation of landfill leachate. The
slurry wall will fully surround landfill source material. The wall keys
into the lower permeability till layer underneath the site. The wall will
prevent the possibility of upgradient groundwater from coming into contact
will landfill source materials. The wall will contain liqui~ and solid
materials inside the landfill. and the dewatering system will actively
collect any liquids (leachate and l.iquid wastes released fram drums) inside
the contained system. Collected liquids will be properly treated and
disposed of. The groundwater monitoring system will identify if a release
outside of the containment system (in the case of failure) has occurred.
.
In addition. removal and treatment of concentrated areas of drummed waste
will ensure the reliability of the containment system and provide
significact long-term effectiveness.
The short-term impact of limited landfill excavation and onsite
construction are manageable and can be reasonably accomplished in an
environmentally sound fashion. Likewise. the offsite transport or onsite
incineration of the estimated 2.000 cubic yards of material present
manageable short-term impacts.
B. Attainment of Applicable or Relevant and Appropriate Requirements
( ARAR t
Alternative SRCVT will meet all ARARs of Federal. and more stringent State
environmental laws. See discussion below.
C.
Cost-Effectiveness
This alternative affords a high degree of effectiveness by pro.viding
protection against direct contact threats and a threat of releases to the
groundwater. The containment portion of this remedy will be reliable in
the long-term, as concentrated areas of wastes. which. may compromise the
- 4.",:-, .-. '." .'"'-' ..--'" '.~-~."
" "'.U_:"-;-'- :"-'...--,,"r...--.-.:..,,:,~..-.:."'::, ~,:r,:,.''':-7":M:';'.::: -. :', -M~'.~_--:':.""7'-!'::..~-~''''' ....~.. ::'-':-::-.'.:.:'-'-;'""-7':';" ---. ~... :-.' .,.
.y- :--:::' ~.., "",-:': '.;-"~"'''''-::i > '." ,.;... " .' h'~., .~:M~.:'"
.-. - .- " " ..,,- ...- .' .'" .
. . .
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38
containment system if left in place, are removed and permanently treated.
Although Alternative SRCV provides identical containment of landfill wastes
and has an estimated total present worth of $9,700,000, Alternative SRCVT
with an estimated total present worth of $22,530,000 is the cost-effective
alternative. Potential future costs with Alternative SRCV are likely if
concentrated drummed wastes cause containment fail ure. The additional cost
of Alternative SRCVT provides permanent treatment of drummed waste insuring
the integrity of the containment system. This degree of treatment cannot
be gained for any lesser costs. The wastes of most concern in the
landfill, due to their toxic, mobile nature, are treated.
Alternative NA, SR, and SRC are less costly than Atlernative SRCVT,
however, none of them provide adequate public health and environmental
protection. Future costs are likely with all of these remedies. None of
these remedies provide a cost-effective solution to the problem. "
Alternative RON provides treatment similar to Alternative SRCVT. Less
waste is treated in Alternative RON since saturated soils are not treated
but complete landfill excavation insures locating and removing all drums.
The containment system is more secure, and the estimated total present
worth ($29,620,000) is a higher cost than Alternative SRCVT. Short-term
impacts and implementability issues are, however, greater than Alternative
SRCVT. The greater cost is due primarily to more sophisticated
. containment. The containment, however, is for less.mobile wastes, since
drummed wastes are removed. The additional long-term benefits gained in
Alternative RON are not commensurate with the additional cost for this
remedy. .J
Alternatives ROF" and RTO require significantly greater costs (estimated
total present worths of $61,920,000 and $130,500,000, re~ectively) and
significantly greater implementability issues than Alternative SRCVT,
without commensurate gains in overall effectiveness.
.
D. Utilization of Permanent Solutions and Alternative Treatment
Techno1og1es to the Maxlmum EXtent Practlcable
Alternative SRCVT focuses on providing permanent and significant treatment
of the wastes of concern (drummed wastes) at the site. Identification,
excavation, and" treatment of these wastes can be practicably done. The
volume of waste to be handled is relatively small- 2,000 cubic yards.
Alternatives which provide gredter degrees of permanence present
significant waste handling and implementability issues which render such
alternatives not practicable. All of the more permanent remedies require
complete landfill excavation and above-ground management of approximately
260,000 cubic yards of waste. Time frames associated with more permanent
alternatives are 2 to 5 years, as compared with Alternative SRCVT, which is
estimted to take one year to implement. Alternatives which do not provide
source treatment (Alternatives NA, SR, SRC, SRCV) afford little permAnence.
No alternative is widely accepted by all parties involved in the site. The
State and local community, as well as the PRPs oppose Alternative SRCVT.
Their issues with the selected alternative are very different (see
., 'n.:' ~':::,~-._~;,:,-. .",:~'.:~r,"":,: """"'~:-T~ ~::v::. ~,~"',..::,,,":,~....-...-." ,; -~-:':. 'f ,~...,:,~.,...; '\--;""7--:--:::1" '-.~ :""':~. '";"""::"~:'"""",-..-:,->:;r~:-;-f"o. .~. :::,'''''''-~~'''M'''~~r.-'''"':I,'' 7'.'.' v, ..' ','
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39
Responsiveness Summary). Such lack of support presents implementability
issues for this alternative.
E.
Preference for Treatment as a Principal Element
Concentrated areas of wastes of concern in the landfill are permanently
treated (incinerated) to reduce the toxicity, mobility, and'volume of the
hazardous substances. The preference for treatment as a principal element
is met with Alternative SRCVT.
2.
Groundwater
The recommended remedy for selection and implementation for the groundwater
is Alternative SR. This alternative is protective of human health and the
environment, attains Federal and State requirements promulgated under
environmental laws that are applicable or relevant and appropriate. and is
cost-effective. Treatment solutions which permanently and significantly
reduce toxicity, mobility, and volume of hazardous substances are not a
principal element of of this groundwater remedy. This alternative does
provide a permanent solution to the groundwater contamination. This
alternative represents the best balance among the factors for selecting an
appropriate groundwater remedy at the site.
A.
Protection of Human Health and the Environment
.
No public health risks currently exist from onsite contaminated groundwater
since there are no current users of this water, and migration of the
contaminant~ to current offsite groundwater users is highly unlikely. This
alternative provides protection to future ~sers of onsite groundwater with
deed restrictions that prevent use of this water as a drinking water
source. The monitoring component of this remedy provides information about
changes in groundwater quality geographically and over time. If a threat
to public health and the environment is posed by changes in groundwater
quality, it will be identified and a remedial action plan will be
evaluated. Modelling information has indicated that a current onsite
contamination will discharge to offsite groundwater at concentrations that
are well within all remedial action goals.
The suspected source (lagoons) for the groundwater contamiantion will be
completely removed in the lagoon operable unit remedial action currently in
design phase. Current groundwater contaminants should eventually discharge
to nearby surface water bodies, in an environmentally sound fashion
resulting in background groundwater quality in the currently affected
onsite aquifer area.
The monitoring component of this remedy will include quarterly sampling and
analysis of groundwater during the first 5 years. The program would then
be reevaluated to determine if changes in analyses and sampling frequency
are necessary. Samples will be analyzed for CLP organic and inorganic
parameters and for conventional parameters such as chloride, sulfate,
nitrate, nitrite, specific conductivity. and alkalinity.
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~' :' .:v .:~ ~.. .~ ~.~~~ ~~ ~~ :.:~:., ~~.:~:...: '::-..-~::~:~: ~~.~ ~.::'~;;ft~.~.;::::/ ~:~~:.~.;. ~:~:~r. .,~ '. . ~~::".~~:;. ..:- ~ .'~:--"~ ~.; .-~ .~;~:'-""::7:.\' ~~~:~ ~::~
-------
.
40
Annually, the quarterly results of the sampling and analysis program will
be averaged and compared to the groundwater remedial action goals. At the
site boundary (monitoring well nos. r1W85-1S and MW85-2S), if on an average
annual basis, the quality of groundwater is greater than MCLs, exceeding
lifetime health advisories, exceeding levels for noncarcinogenic health
effect protection (based on reference doses) or exceeding a lifetime cancer
risk range of 10-4 to 10-7; or offsite, upgradient of the wetlands,
(monitoring well nos. ~~86-4S~ MW86-3S, and MW86-2S) if on an average
annual basis the quality of the groundwater is greater than Federal Ambient
Water Quality Criteria or State of Michigan Surface Water Quality Guideline
Levels for the Protection of Aquatic Life, a plan for further groundwater
remedial action will be evaluated.
The minimal construction and operations of this alternative present no
adverse short-term impacts.
B.
Attainment of Applicable or Relevant and Appropriate Requirements
Alternative SR will meet all ARARs of Federal, and more stringent State
environmental laws. See discussion below.
c.
Cost-Effectiveness
This alternative affords a high degree of effectiveness by providing
protection against use of onsite groundwater with deed restriction and
assuring the contaminants discharge to offsite areas in an environmentally
sound fashion, (ie., consistent with the groundwater remedial actions
goals) with the monitoring program. The estimated total present worth cost
of $1,290,000 is on the low range of the alternatives developed in the FS.
The no action alternative, witHia total present worth of $0, is not
acceptable as a cost-effective alternative because it does not provide
adequate public health and environmental protection.
Alternatives CTGO and CTO include active construction and waste handling,
and have respective estimated total present worth costs of $3,760,000 and
$2.550,000. The additional adverse short-term impacts of waste handling,
and additional costs associated with these alternatives are not necessary
to provide pUblic health and environmental protection. These alternatives
are not cost-effective.
.
O. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
Alterntaive SR provides a permanent solution to the onsite contaminated
groundwater problem. Over time, through dilution and adsorption, the
minimally contaminated onsite groundwater should reach background levels as
the contaminants discharge to the nearest surface water body in an.
environmentally sound fashion. Since the source of this groundwater
contamination (lagoons) is. being completely removed in the lagoon operable
remedy, no future contribution to this contaminant plume will occur.
". . ",;,:: F~~.:~;";"""::" :- -:-~::: :;'~,',-::~~' ':<~< .',,:; 'i~. :.~. J;'~::;.T':.2.' .':-r''''':_~:'' ,"-': .' . ~V'~')"\~:-:'; ~f:~::~ -::.'.: ;-;~'i.:',~'":':'?;~~"";'-~'-:':_){'~"'-~<'~'~".:-~':-":-:~.;r!~- "..., : .~~. '. '." -'J::,>, -'~ ~'7'.,;-;.;......., 'r.: -~ '-, ".,,-: "".: :-.r" ~.¥..: ~ "-'~ ,....:, -...,- - -:- ...... "'f .
,. '''';' .k'''''' ..---..... '--:-.':
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.,
41
Alternatives CTGD and CTP also provide permanent remedies, and do so
through treatment processes. The actual amount of hazardous substances
treated in these remedies, however, is very sm~ll. These remedies also
present implementability issues and adverse short-term impacts. The
additional cost and implementability issues, with no gain in overall
protectiveness or permanence, make selection of these alternatives not
practicable.
E.
Preference for Treatment as a Principal Element
The groundwater Alternative SR does not use treatment as a principal
element. Use of treatment provides no gain in overall protectiveness or
permanence for the groundwater cleanup, therefore, is not worthwhile. The
overall site remedy. including the landfill cleanup, however, does provide
treatment as a principal element.
State Issues
The landfill soil and source materials, and groundwater operable unit
recommended alternatives are both opposed by the State of Michigan. The
protection provided by landfill operable unit Alternative SRCVT is not
viewed by the State as adequate. The groundwater Alternative SR is not
acceptable to the. State. The State maintains that the releases to the
onsite groundwater merit active groundwater cleanup. The State of Michigan
position and the U.S. EPA response is discussed in detail in the
Responsiveness Summary. .J
.
ATTAINMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS OF
ENVIRONMENTAl LAWS -
1.
Landfill Soil and Source Materials ARARs
Alternative SRCVT is desi~ned to meet all applicable, or relevant and
appropriate requirements (ARARs) of Federal. and more stringent. State
environmental laws. The Federal ARARs include the Resource Conservation
and Recovery Act (RCRA) (42 USCA Section 6901 et ~ and 40 CFR Part 260-
271). the Clean Water Act (40 CFR Parts 122. 125. ana 131). the Safe
Drinking Water Act (42 USCA Section 300(f) et ~ and 40 CFR Part 141). the
Clean Air Act (42 USCA Section 7401 et ~ and 40 CFR Parts 50 and 61), and
the Occupational safety and Heal th Admi n1Strati on Act (40 CFR 1910).
Potential State ARARs include the Michigan Hazardous Waste Management Act
(Act 64), the Liquid Industrial Waste Removal Act (Act 136), the Air
Pollution Act (Act 347), the Mineral Well Act (Act 315), and the Water
Resources Commission Act (Act 245).
A.
Federal Resource Conservation and Recovery Act
RCRA regulations will be applicable to the waste removed from the landfill
for incineration treatment. All such material will be considered to be
hazardous waste as defined in the RCRA regulations, 40 CFR Part 261
"Identification and Listing of Hazardous Wastes", unless proven otherwise,
. ",. -r,' ~ :'" '-~..-;:::::::';'-~-:;.::"~.~'.~' ~"~'.::':~- ~ :i:~' r: .~::.: ::;-::' .-;~-;::~-:' ~i' ~-.: ~~. ;;7~::=:~~~;E'~~"'r:~) ~
. (::;~r~~:: ~~. ':-':~~; >~' :.: ':---:~'~-;~~i::..~ ]~~::~:~~:"~:~--;';~\:'~:~:~::'~'~:~.'~ ~.':.:'::~~:~"::.;::':-. '/::-:"~ ~.;:: :' ~. -~ ;:." ,":',: ':'.':.~. ~.:~ -.~~:~.;~ ':,:'.~~":'
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42
or unless the waste is regulated by another statute such. as the Toxic
Substances Control Act.
After removal and treatment/disposal of drum wastes and contaminated soils,
the FWD landfill area will be closed~ Because disposal of hazardous waste
at the FWD landfill occured prior to the effective date of the RCRA
regulation, the RCRA closure regulations are not applicable. However, they
are considered relevant and appropriate. The relevant and appropriate
requirements of RCRA Subtitle C regulations, will be met by the selected
remedy.
RCRA closure and post-closure requirements for all hazardous waste
management facilities are outlined in 40 CFR Subpart G. Section 264.310 of
RCRA Subpart N specifies the performance-based requirements for a cover at
final landfill closure. The cover system in Alternative SRCVT will be a
cap as prescribed in RCRA guidance and will comply with RCRA regulations.
The cap will minimize migration of liquid through the landfill, function
with minimum maintenance, promote drainage, minimize erosion, accommodate
settling, and be less than or equal to the permeability of natural subsoils
present.
After closure is completed, the substantive monitoring and maintenance
post-closure requirements contained in Section 264.117 through 264.120 of
Subpart.G will be conducted. The facility will be closed according to the
standards in Subpart G Section 264.111 - Closure performance standards.
After tbe closure activities have concluded, a survey plat, as prescribed
in Subpart G Section 264.116, indicating the location and dimensions of the
disposal area will be submitted to the local zoning authority, or to the
authority with jurisdiction over local land use, and the Regional
. Administ!ator (Michigan State Director).
.
The drum wastes and contaminated soils removed from concentrated regions of
the landfill prior to closure must be properly disposed of or .
decontaminated as required in Subpart G Section 264.114. If incinerated
offsite these wastes will be staged and repackaged onsite, and transported
offsite for incineration at a RCRA treatment facility operating in
compliance with 40 CFR Sections 264.340 through 264.351. The excavated
waste will also be handled as regulated by Part 262 - Standards Applicable
to Generators of Hazardous Waste, and Part 263 - Standards Applicable to
Transporters of Hazardous Waste. If incineration is onsite, it must.
operate in compliance with the technical requirements.of Subpart 0 Sections
264.340 through 264.351.
B. Michigan Hazardous Waste Management Act (Act 64t
To the extent that Act 64 is more stringent than the Federal RCRA
regulation, Act 64 will be followed.
Rules 301(4) and 304 (1) (c) of Act 64 require that a generator use a
licensed transporter or generator-owned licensed vehicle for transport of
hazardous waste offsite.
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43
Regarding manifesting. a Michigan Department. of Natural Resources manifest
will be used and mailed to MDNR as outlined in Rule 304. Rules regarding
use of the hazardous waste number will be followed as outlined in Rule
304(2). 305(1)(e). and 306.
Wastes accumulated onsite for less than 90 days must be stored in
containers with secondary containment equivalent to that of a permitted
facility under 40 CFR 264.175. Containers must be labeled with the
hazardous waste number.
The following rules for transporter standards will apply under Act 64:
requirements for transporter business and vehicle licenses (Rule 403 and
406). use of Michigan manifest form (Rule 409(1)) and liability insurance
( Ru 1 e 711).
Transporters must comply with generator requirements when they mix small
quantities (Rule 401(3) and 405 (2)). Mixing. combining. and commingling
of managed hazardous waste (greater than 1000 kg) is prohibited without
approval from the MDNR.
The following transporter vehicle requirements will be followed: Rule 406
vehicle labeling. operation and maintenance requirements. and
identification numbers; compliance with Act 300 Michigan Vehicle Code;
Act 207 Fire Prevention Act; Act 181 Motor Carrier Safety Act; and the
Hazardous Material Transport Act (Rule 408 (1)). and Rule 408 Provisions
for a Fire Marshall Inspection.
.
. .J
Rule 410 of Act 64 outlines the procedures to be followed in the event of
waste discharge during transport.
Rule 409(2) requires transporters to document communications with
generators on the manifest. if waste cannot be delivered.
Relative to landfill closure provisions. Act 64 Rule 619 specifies closure
standards. including a minimum cover requirement. and requirements for
venting which will be followed.
C. Michigan Liquid Industrial Waste Removal Act (Act 136)
This Act requires the use of a licensed liquid industrial waste hauler to
remove any industrial liquid wastes offsite. similar to the requirements of
RCRA Part 263. To the extent these requirements are more stringent than
RCRA. they will be complied with for handling offsite disposal of liquid
waste from the landfill.
D.
Federal Clean Air Act
The Clean Air Act (CAA) identifies and regulates pollutants that cbuld be
released during earth-moving activities associated with the partial
excavation and slurry wall construction and potential onsite incineration
of SRCVT. The CAA Section 109 outlines the criteria pollutants for which
National Ambient Air Quality Standards have been established. CAA Section
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" ". :~'- .. ~~-:=:': --:;--'.'"." . .: ~ ,,,:~.~:--.:"';..:~7 ~.:".::;.\.~::. ~-..., ~." .~-.'-::"
'-.:.~'..~'~<'.~ :'-::~;K~:~;J~~.7' '.~'.'~: '>~\-:::-~.:' .:-~~.,~~-~~.::.
-------
44
112 identifies pollutants for which there are no applicable Ambient Air
Quality Standards, those substances regulated under the Federal National
Emission Standards for Hazardous Pollutants. The CAA is an ARAR and the
regulations standards will be complied with during implementation of SRCVT.
E.
Michigan Air Poll ution Act (Act 348)
Under this Act, the Michigan Air Quality Division, through Rule 901,
exercises its authority to ensure that a person does not cause or permit
the emission of an air contaminant in quantities that will cause,
"injurious effects to human health or safety, animal life, plant life or
significant economic value" or "unreasonable interference with the.
comfortable enjoyment of life and property. II This Act is an ARAR which has
more stringent emissions controls for air contaminants than the Federal
Clean Air Act. and the substantive technical requirements will be complied
with during landfill excavation and potential onsite incineration.
F.
Federal Occupational Safety and Health Administration Act (OSHA)
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 site workers must meet the minimum training and medical
monitoring requirements outlined in 40 CFR 1910. OSHA will also be
complied with when implementing the groundwater remedial activity.
.
2.
Groundwater/Surface Water ARARs
,J
Alternative SR is designed to meet all applicable, or rel evant and
appropriate requirements of Federal, and more stringent, State
environmental laws. Three groups of Federal environmental standards and
criteria are considered ARARs for the groundwater at the FWD site: Safe
Drinking Water Act Maximum Contaminant .Limits (MCls). RCRA Groundwater
Protection Standards. and Clean Water Act Ambient Water Quality Criteria.
These are ARARs for groundwater protection underneath the landfill for the
landfill operable unit remedy, as well as for the affected groundwater in
the groundwater operable unit remedy. The CWA regulation is likewise an
ARAR for protection of surface water relative to the landfill and
groundwater operable unit remedies.
Potential State ARARs for the regulation of groundwater at the site include
the Michigan Water Resources Commission Act and the Mineral Well Act.
Michigan environmental law regulating surface water includes the Michigan
Water Resources Commission Act. -
A.
Federal Groundwater ARARs
Maximum Contaminant Levels established under the Safe Drinking Water Act
are ARARS at this site. MCLs are the maximum contaminant concentrations
allowed in a regulated public water supply. These levels apply at the
point of distribution ("at the tap") to public water systems having at
least 15 service connections or regularly serving at least 25 individuals.
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. .. "
45
Levels are based on a chemicals toxicity, treatability (including cost
considerations), and analytical limits of detection.
MCLs are relevant and appropriate at FWD for groundwater protection because
the aquifers underneath the site are defined as drinking water aquifers,
and MCLs are the enforceable drinking water standard for public water
supplies. Since MCLs apply to water at the point of use, these levels are
appropriate for establishing water quality in the drinking water aquifers
at the site. Groundwater tapped for drinking water generally has minimal
or no treatment. These standards will be applied to the groundwater itself
to ensure safe levels in the groundwater underneath the site.
The groundwater cleanup levels are also consistent with Maximum
Concentrations Limits or health based Alternate Concentration Limits under
RCRA Subpart F. Specifically, the protection provided for groundwater in
the site remedies is consistent with RCRA Subpart F Section 264.100.
Corrective action program, which serves as the ARAR. The point of
compliance for groundwater protection is established onsite. For the
groundwater plume to the east, the point of compliance is at monitoring
well Nos. MW85-1S and MW85-2S. For the landfill, the point of compliance
is at the physical landfill perimeter.
ality Criteria (AW C
The CWA is an ARAR at this site since site groundwater eventually
discharges to the surface water body (wetlands) east of the site. The
AWQC are established for protection of freshwater aquatic organisms. AWQC
will be met at the point the groundwater discharges to the closest surface
water body. Monitoring shallow groundwater, upgradient at the surface
water body, will assure compliance with AWQC before it discharges to the
wetlands.
.
C.
Potential State Groundwater ARARs
i. Water Resources Commission Act (Act 245)
Act 245 is not a groundwater ARAR at this site. Its purpose is to prevent
discharges into the groundwater. U.S. EPA is not discharging into the
groundwater. hence the Act is not applicable.
Similarly, Act 245 is not relevant or appropriate to establishing cleanup
levels at the site. There are no promulgated regulations u.S. EPA can
consider in setting cleanup standards. Additionally, the objectives of the
Act and rules, which are to define and limit discharges, vary significantly
from U.S. EPA's objectives to cleanup the site.
i1.
Mineral ""ell Act (Act 315)
Act 315 and the Administrative Rules require that test wells be permitted,
constructed properl y, recorded, and properl y pl ugged upon abandonment. .
This Act is an ARAR and treatment of all test wells will be dictated by it.
-------
. ... ..,
46
State Surface Water ARAR - Water Resources Commission Act (Act 245).
Act 245 establishes surface water standards. The more stringent
promulgated State standards, relative to the CWA AWQC, will be met for any
discharges to the nearest surface water discharge point.
Summary Discussion
Considering the various evaluation factors in SARA Section 121 (b) and the
National Contingency Plan, Alternative SRCVT for the landfill and
Alternative SR for the groundwater offer cost-effective solutions to the
contaminant problems onsite. Both remedies satisfy Federal and State
ARARs.
Alternative SRCVT provides adequate protection of human health and the
environment, and utilizes treatment, which permanently and significantly
reduces toxicity, mobility, and volume of hazardous substances, as a
principal element. This alternative utilizes long-term onsite management
of some wastes in a reasonable fashion, and presents no major engineering
implementability issues.
Alternative SR provides adequate protection of human health and the
environment. The minimal groundwater contamination problem is handled with
a deed restriction/monitoring alternative which incurs little cost and is
easily implemented. ..J
.
OPERATION AND MAINTENANCE
The recommended landfill Alternative SCRVT requires some annual operation
and maintenance (O&M). Maintenance of the landfill cap and slurry wall
will be required periodically over time. Operation of a collection and
treatment system for landfill leachate and gas will be needed over time.
Maintenance of a site fence will be needed. Operation of a groundwater
monitoring program to identify potential groundwater releases from the
~lurry wall/cap containment system will be required over time.
The recommended groundwater remedy, Alternative SR, will require operation
of a groundwater sampling and analysis monitoring program. Over time it is
anticipated that the monitoring program can be abandoned as groundwater
contamination attenuates and is no longer detected, due to dilution and
adsorption.
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FOREST WASTE DISPOSAL
OTISVILLE. MICHIGAN
RESPONSIVENESS SUMMARY
INTRODUCTION
The United States Environmental Protection Agency (U.S. EPA), with the
Michigan Department of Natural Resources (MDNR), has completed a Remedial
Investigation and Feasibility Study (RIfFS) regarding the Forest Waste
Disposal (FWD) site located at 8359 East Farrand Road, Otisville, Michigan.
During the RIfFS, information was collected on the nature and extent of
contamination at FWD (RI), and alternatives for appropriate remedial action
at FWD were developed and evaluated (FS). Throughout this process, several
public meetings have been held near the site in which U.S. EPA and MDNR
discussed the RIfFS progress and exchanged information with the public. At
the conclusion of the FS, a Proposed Plan was finalized by U.S. EPA, after
discussion with MDNR, which identified recommended alternatives for
remedial action at the FWD site. U.S. EPA recently held a public comment
period from January 29, 1988, to February 27, 1988, for interested parties
to comment on U.S. EPAls Proposed Plan and Feasibility Study for addressing
contamination problems at the Forest Waste Disposal Site. At a public
meeting on February 17, 1988, U.S. EPA presented its Proposed Plan for the
Forest .Waste Disposal site.
The purpose of this Responsiveness Summary is to document the comments
received during the public comment period, and U.S. EPAls responses to the
comments. All of the comments summarized in this document were cons i dered
prior to U.S. EPAls final decision.
.
The responsiveness summary is divided into the following sections:
I. Responsiveness Summary Overview. This section briefly outlines the
proposed remedlal alternatlves as presented in the Feasibility Study (FS),
including the recommended alternative.
II. Background on Community Involvement. This section provides a brief
history of community interest and of concerns raised during planning
activities at the site.
III. Summary of Public Comments Received During Public Comment Period and
U.S. EPA Responses. Both oral and wrltten comments are grouped by issues,
followed by U.S. EPA responses to these comments.
I. OVERVIEW
On January 29, 1988, U.S. EPA made available to the public for review and.
comment the Public Comment Draft Feasibility Study (FS) report for the
Forest Waste Disposal Site. In the FS report, methods for cleaning'up the
landfill soil and source materials, and the groundwater on the east end of
the site were developed and evaluated. Eight alternatives to address the
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...:.:'.,~-- -',~~
", " .
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....... ............. .'--"<1. .."...--
, .~....-"" ~"'~ ~
2
landfill soil and source materials, and four alternatives to address the
groundwater were presented. The proposed remedial alternatives include the
following:
Landfill Soil and Source Materials
1. Alternative NA - No Action.
This alternative assumes that no further corrective actions take place at
the site and that no restrictions are placed on future use at the site.
This alternative is primarily included as a baseline scenario to which
other alternatives can be compared.
2. Alternative SR -
Site access restrictions, fence, and groundwater monitoring.
3. Alternative SRC -
Site access restrictions, fence, groundwater monitoring, and soil cover.
4. Alternative SRCV -
Site access restrictions, fence, groundwater monitoring, RCRA impermeable
cap, slurry wall vertical barrier, and landfill dewatering and treatment.
5. Alternative SRCVT -
Site access restrictions, fence, groundwater monitoring, limited landfill
drum excavation and offsite incineration, RCRA impermeable cap slurry wall
vertical barrier, and landfill dewatering and treatment.
.oJ
.
6. A1tern~tive RDN-
Complete landfill waste excavation, offsite incineration of aJ1 drums,
build onsite RCRA-type hazardous waste landfill, redisposal of remaining
landfill wastes in onsite landfill, RCRA impermeable cap, and groundwater
monitoring.
7. Alternative RDF -
Complete landfill waste excavation, and complete offsite waste disposal at
a RCRA hazardous waste disposal facility.
8. Alternative RTD -
Complete landfill waste excavation, treatment of all combustible wastes in
an onsite RCRA-type incinerator, dewatering of the non-combustible waste
onsite, build onsite RCRA-type hazardous waste landfill, redisposal of
treatment residuals and untreated wastes in onsite landfill, RCRA
impermeable cap, and groundwater monitoring.
Groundwater
1. Alternative NA -
No action. This alternative is as described above.
. 2. Alternative SR -
Site restrictions and groundwater monitoring.
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3
Collection of contaminated groundwater, treatment of water onsite with
granulated activated carbon, and discharge of treated water to Butternut
Creek.
4. Alternative CTP -
Collection of contaminated groundwater, and transport and offsite treatment of
groundwater at a Publicly Owned Treatment Works (POTW).
After careful evaluation, U.S. EPA selected Alternative SRCVT for the landfill
soil and source materials and Alternative SR for the groundwater.
Numerous parties submitted formal written comments to U.S. EPA during the
public comment period. Those parties include:
1) Numerous area residents (approximately 75)
2) Michigan Department of Natural Resources
3) Michigan State Congressional Representative Nate
4) Michigan Department of Public Health
5) Mr. Ronald Willson, resident of Owosso, Michigan
6) Forest Waste Coordinating Committee representing
Respons i b1 e Parties (PRP)
7) U.S. Fish and Wildlife Service
Yon kers
the Potentially
One area resident also submitted a verbal comment over the telephone during
public comment period. Formal comments were also submitted at the public
meeting by Mr. Wayne Desjarlais, Mr. Mich~e1 Borges, Mr. Gary Palmer, State
Representative Nate Yonkers, and Ms. Diane Roulette.
.
II. BACKGROUND ON COMMUNITY INVOLVEMENT at the Forest Waste Disposal Site.
The planning process for the RI at the Forest Waste Disposal Site began in
Winter, 1983. The Michigan Remedial Action Program Community Involvement
strategy was applied to this site. The State of Michigan has had the lead
role for site Community Relations. A site specific Community Relations Plan
(CRP) was formed in Winter, 1983.
Also in Winter 1983 a Citizens Information Committee (CIC) was formed. The
CIC is a group of local citizens and State, County, and local officials with
high interest in site activities. The U.S. EPA participates in CIC-meetings.
The CIC serves as a liaison between the U.S. EPA and local citizens, to keep
local citizens advised of 'Superfund activities at the site. The CIC has held
meetings periodically.
A mailing list of all interested persons was completed early in the RI,
compiled from names provided by the CIC and attendance lists at public
meetings. To date, nine progress reports have been developed and distributed
to the community. The mailing list includes approximately 200 surrounding'
residents. The progress reports summarize site activities, findings, and
future plans. .
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4
Five open public meetings have been held to present and explain site
activities to the community and receive community response to these
activities.
The first public meeting was held in May, 1984, at the start of the RIfFS, to
explain the Superfund program and the scope of the RIfFS. There were
approximately 50 attendees at the meeting. Community concerns expressed at
that time included testing of residential drinking wells and private ponds,
and the past role of the Genesee County Health Department and MDNR in
regulating the site. Initial RI work included collecting water samples from
private ponds of surrounding residents. MDNR also collected a composite fish
sample from a private pond adjacent to the site.
The second public meeting was held May 16, 1985, (100 attendees plus local
press) and served to provide an update for citizens on the status of the
RIfFS. The community expressed concern about the seemingly slow progress
towards cleanup at the site. The community also expressed concerns about
testing of their drinking wells. In .Summer 1985, drinking water from several
residents wells surrounding the site was sampled. No evidence of
contamination was found.
The third public meeting was held April 21, 1986, and included approximately
40 attendees. This meeting was held to present to the public the findings of
the Phased Feasibility Study (PFS) which developed and evaluated remedial
action alternatives for cleanup of the site lagoons. The U.S. EPA recommended
alternative for complete offsite disposal of lagoon waste was well received by
the local citizens. Some citizens expressed concerns at that meeting that
they had been dealt with unfairly in the pas~, The U.S. EPA recommended
alternative was selected, as documented in the June 30, 1986, Record of
Decision.
.
The fourth public meeting was held October 1, 1987. Approximately 50 people
attended. U.S. EPA and MDNR presented to the public the findings of the final
RI Report. At that meeting, the public was also informed of the upcoming FS
process of developing and evaluating remedial alternatives for complete site
cleanup.
A brief outline of final site remedial action alternatives under consideration
at that time was presented to the public. The public was requested to submit
comments on the outline at either the meeting or later. Only one comment was
received on the outline. This comment was relative to a proposed final
groundwater cleanup alternative to collect contaminated groundwater and
discharge it to Butternut Creek without treatment. A verbal comment was made
at the meeting that such a transfer of contaminated groundwater did not make
sense. The PRPs had representatives at the public meeting.
At this meeting .a schedule for the selected lagoon cleanup was also presented.
The public expressed interest in seeing action taken at the lagoons in a
timely fashion. .
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5
"
The final Public Comment Draft Feasibility Study (FS) was released on-
January 29, 1988. At a public meeting on February 17, 1988, U.S. EPA
summarized the findings of the FS and presented its Proposed Plan of
recommended cleanup actions. Representatives from MDNR presented the State
position that the U.S. EPA proposed alternatives do not provide enough cleanup
action at the site, and presented their preferred alternatives of Alternative
RDN for the landfill soil and source materials, and Alternative SR for the
contaminated shallow groundwater at the site. .
The community response at the public meeting focused heavily on the lack of
action at the site lagoons and the long timeframes associated with complete
site cleanup. Community residents were notably upset and emotional about such
lack of action. Comments made by meeting attendees on the final FS
presentation supported the MDNR recommended alternative for the landfill. The
community also expressed concerns about implementing a site cleanup
alternative if the U.S. EPA and MDNR could not come to an agreement on degree
of cleanup. Specific responses to comments made are presented in Section III
of this Responsiveness Summary.
III. SUMMARY TO COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
U.S. EPA'S RESPONSE TO COMMENTS.
Comments raised during the Forest Waste Disposal Feasibility Study public
comment period are summarized below. A number of comments were submitted
during the public comment period which are not relevant to the selection of
remedy and are not comments, criticisms, or new data regarding the proposed
plan or proposed findings under Section 121(d)(4) of CERCLA. Therefore, per
Section 117(b), it is not appropriate to respond to such comments in the Final
Plan or Record of Decision. Such comments will, however, be addressed through
an appropriate communication medium.
.
Three general categories of comments were submitted during the public comment
period. These include: .
. 1) Comments that the U.S. EPA recommended remedy is inappropriate
because it provides too much protection,
2) Comments that the U.S. EPA recommended remedy is inappropriate
because it does not provide enough protection, and
3) Comments that the U.S. EPA recommended remedy is appropriate.
Comments are organized and paraphrased in order to effectively summarize and
respond to them in this document. The reader is referred to the actual
reports and comments in the Administrative Record.
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1
(PRP) Representatives -
(,
Comments submitted by the PRPs argue that the U.S. EPA preferred landfill
alternative, Alternative SRCVT, is inappropiate because it goes beyond actions
necessary to adequately protect human health and the.environment.
The PRPs directed their comments toward the U.S. EPA and MDNR recommended
alternatives. U.S. EPA will not respond to comments characterizing the MDNR
alternative as the recommended alternative because it is not the U.S. EPA
recommended alternative.
I.A.
Comment
The U.S. EPA ignored the results of the risk assessment process. The U.S. EPA
has failed to base remedial decisions on the statutorily mandated requirements
of risk and cost effectiveness.
1. The risk assessment process is mandated by SARA. Under SARA Section
l05(a}(8}(A) and the NCP, the U.S. EPA must perform a formal Endangerment
Assessment to assess the risk posed at a Superfund site before identifying and
selecting the appropriate final remedial alternative.
2. The U.S. EPA and PRP FWCC concluded that the Forest Waste Disposal site
poses minimal immediate or future threat to the environment and to nearby
residents, and there are extensive clay d~posits underlying the site that
provide an excellent natural containment: Both groups concluded that even an
unremediated site would pose little future risk.
.
3. The U.S. EPAls formal Endangerment Assessment concluded that there is no
likely risk of contamination reaching the residential wells in the
neighborhood because there is no direct pathway. U.S. EPA has acknowledged
that no groundwater contaminants have been detected coming from the landfill
area and no residential wells have been affected by the site~ The U.S. EPA
Fact Sheet acknowledged that most private wells draw water from aquifer
below the shallow surface aquifer shown to be co~taminated. Existing local
wells are not thought to be in jeopardy of being impacted by groundwater
contamination detected east of the lagoons.
"
4. The U.S. EPA Endangerment Assessment concluded that the. only present risk
from the site was caused by direct ingestion of contaminated surface soils in
the landfill area, and that a potential future risk existed with respect to
the shallow aquifer, assuming no remediation of the landfill took place.
This analysis ignored that the shallow aquifer is not being used to supply
residential wells downgradient of the landfill and lagoon area. The U.S. EPA
Fact Sheet acknowledged that both onsite soils and the groundwater have
documented contamination and this contamination poses little immediate threat
to the public. .
5. The U.S. EPA fact sheet acknowledged that the most significant current
risk for exposure to contaminants is the risk of direct exposure to waste
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2
materials from trespassers coming onto the site.
site was fenced earlier.
Because of this, the entire
6. An MDNR representative indicated that the formal Agency Endangerment
Assessment would not necessarily be the basis for selecting a remedy for the
site, and that other factors would be considered.
I.A.
Response
The U.S. EPA Baseline Risk Assessment in Chapter 6 of the RI (August 1987) and
the PRP Endangerment Assessment (EA) performed by life Systems (October 1987)
are both in the Administrative Record (AR) for final remedy selection at the
Forest Waste site. Both have been carefully reviewed and considered by U.S.
EPA in final remedy selection. The quantitative methods and conclusions in
both these studies are similar.
Both of these studies evaluated the potential hazards to public health and the
environment using current site data under the No Action alternative, which
assumes no corrective actions take place and no restrictions are placed on
future use of the site. This evaluation was done as directed in the U.S. EPA
Superfund Public Health Evaluation Manual (1986), and presents an evaluation'
of the No Action alternative as required under Section 300.68(f)(1)(V) of the
NCP"
In evaluating the No Action alternative, both studies evaluated the use of
onsite contaminated shallow aquifer. as a future drinking water supply. This is
appropriate because the shallow aquifer, if unaffected by site contaminants,
would be of sufficient quality and quantity to be a drinking water supply.
U.S~ EPA recognizes that the current shallow groundwater contamination appears
to be from the lagoons, and not the landfill. U.S. EPA considers this aquifer
to be a drinking water aquifer.
This risk assessment analysis did not ignore that the aquifer is currently not
being used to supply downgradient residential wells~ U.S. EPA acknowledges
that most private wells in the area draw water from below the shallow
contaminated aquifer. However, in evaluating the No Action alternative, an
assessment of the risk of using of this.groundwater is appropriate. It is
significant to note that the commentors (PRPs) performed the same type of No
Action assessment in their EA. In addition. consistent with U.s. EPA
Groundwater Protection Strategy (August 1984). the shallow groundwater at the
site should be protected for its highest beneficial use. In this case, that
highest beneficial use is as a drinking water source.
Both the U.S. EPA and PRP EAs, utilizing current groundwater contamination to
date, concluded that under a future residential land use scenario, the shallow
aquifer groundwater would present potential human health concerns. Under the
same exposure scenario, both studies also concluded that human contact with
landfill soils would present human health concerns. '
Both EA studies identified that under current land use conditions of
occasional trespassing, no human health risk due to currently contaminated
groundwater exists. Current groundwater contamination is limited to onsite
.
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3
areas, and there are no drinking water wells onsite. Both the U.S. EPA
(Appendix C of FS) and the PRPs (EA) modelled current groundwater
contamination, concluding that migration of the present degree of
contamination will not present risks to surrounding surface water bodies or
current residential wells.
()
The primary difference in conclusions between U.S. EPAls EA and the PRPsl EA,
is that U~S. EPA identifies the landfill as an area of concern under a current
land use trespass setting due to soil and source materials on the landfill
surface. The U.S. EPA is concerned about a soil sample with lead
concentration which, under a trespass exposure setting, exceeds the lead
reference dose for chronic exposure. The PRP EA did not identify the lead
contaminated soil of concern because lead does not have an acceptable
subchronic intake value. Since current land use conditions at the site are
those of trespass, the PRP position apparently is that an evaluation for lead
cannot be done because the trespass scenario is a subchronic exposure
scenariO: The PRPs apparently believe that evaluation of lead potential
effects in a trespass scenario cannot be gained with a comparison to chronic
reference doses as done by U.S. EPA. U.S. EPA maintains that its evaluation
is useful.
More importantly, U.S. EPA identifies the landfill as an area of concern under
current land use conditions due to hazardous waste source materials on the
surface. Data from the landfill test pit investigation indicate that exposed
drums on the landfill surface contain hazardous substances that could result
in a direct and acute exposure threat through dermal absorption or incidental
ingestion (page A-5 of U.S. EPA FS).
.
. .
U.S. EPA maintains that currently the Forest Waste site poses min.imal risk to
the surrounding community. The most significant risk is from trespassing on
the site landfill which could lead to ingestion or dermal absorption of
hazardous substances. The entire site is fenced to discourage such
trespassing. Currently, offsite releases and risks from the site are minimal.
However, U.S. EPA does not feel that an unremediated site would pose little
future risk.
"
U.S. EPA evaluation of risk at the site extends beyond that done by the PRPs
in their EA. The U.S. EPA recognizes that the nature of waste disposal in the
landfill, and the types of wastes in the landfill, present a risk for future
releases (pages 6-34 and 6-35 of the FS) of contamination to the environment.
The quantitative evaluations done in the U.S. EPA and PRP EA were based on
current releases of contaminants to the environment. Future releases also
present future risks from the site, especially relative to the drummed wastes
in the landfill.
The U.S. EPA FS, on pages A-5 and A-6, crudely models a future release of
contaminants from drummed landfill wastes. Such a release could seriously
affect shallow groundwater quality and after a long period of time ~estimated
100 years), if left unchecked, may reach a residential drinking water wel,.
U.S. EPA has used the baseline risk assessment (Chapter 6 of RI), landfill
test pit investigation transport and fate evaluation (Appendix A of FS), and
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4
the PRP EA to identify current and future releases of hazardous waste from the
site that may be of concern. Such evaluations were critical in determining
what needs to be done at the site to provide public health and environmental
protection. Protectiveness is an essential requirement for Superfund
remedial actions. The risk evaluations were used to define specific remedial
action goals for site cleanups (page 2-1 to 2-5 of FS).
In addition, the remedial action goals presented refiect other requirements of
remedy selection: cost effectiveness, preference for treatment, utilization of
permanent solutions to the maximum extent practicable, and compliance with
applicable or relevant and appropriate requirements (ARARs) of environmental
laws. So, while the risk evaluation (EA) is most certainly considered in
remedy selection, it is not the only factor considered.
The formal EA performed by U.S. EPA is not as a result of CERCLA Section
105(a)(8)(A) mandate which requires that U.S. EPA develop "criteria for
determining priorities among releases or threatened releases throughout the
United States for the purpose of taking remedial action". Such a determina-
tion for priority to take remedial action at Forest Waste was already done
when the site was evaluated under the Hazardous Ranking System, and placed on
the Superfund National Priorities List.
The selected landfill remedy was based on a balanced evaluation of
effectiveness, implementabi1ity, and ~ost, and is more elaborately defined and
explained in the attached Record of Decision. The effectiveness evaluation is
closely tied to the risks posed by the site. A combination of landfill waste
treatment and inp1ace containment wi"th a ca.p and slurry wall is thought to be
both protective and cost-effective. The natural underlying clay deposits
will be used as a component of the U. S. EPA remedy, but wi 11 not be sol el y
relied upon to provide protection and meet all the remedial action goals.
.
I.B.
Comment
U.s. EPA bases its risk assessment regarding the drums on an erroneous
scenario and unsubstantiated fear.
1. The U.S. EPA developed their preferred landfill alternative apparently by
focusing on an unsubstantiated fear that 4,000 drums filled with hazardous
liquids are buried in the landfill, are ready to burst simultaneously, and may
release contaminants into the groundwater at some future date, giving rise to
an unacceptable exposure risk.
2. The available data suggest the drums for the most part were crushed before
they were buried at the site or have deteriorated naturally. '
3. U.S. EPA assumed that half of the estimated 4,000 drums in the landfill
were filled with liquids, therefore, their scenario that 4,000 drums filled
with hazardous liquids are buried in the landfill ready to burst.
simultaneously, is erroneous.
4. U.S. EPA's own test pit data revealed only 3 drums out of 43 discovered
conta i ned suffici ent 1 i qu'ids to extract samp1 es for. testing.
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~:1:~:-? .';:~}~
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5
I.B.
Response
A full characterization of the nature and volume of the landfill drummed waste
was not done in the U.S. EPA Forest Waste RI. ~'agnetometer surveys were run
over the landfill, file information about past land disposal practices was
reviewed, and a landfill test pit waste characterization was performed. This
RI information was evaluated, and manipulated with assumptions, to help
evaluate risk at the site and to help develop and evaluate remedial
alternatives. Full drummed waste characterization can only be accomplished
with complete landfill excavation to identify all drums and by employing an
accompanying intense sampling plan. U.S. EPA is fully aware of the
limitations of the information, but believes that the information has been
useful in remedy selection.
It is apparent from the landfill test pit investigation that there are
accumulations of drums in the landfill with high concentrations of hazardous
waste (see the FS, Appendix A). Some drums are partially exposed and some are
lying on top of the landfill surface. Most of the drums from the test pitting
investigation were partially full, although some of the drums were completely
full. Few, if any, drums from the test pitting investigation were completely
empty and crushed. Some of the drums had associated liquids in them, but no
drums, other than the staged drum in area 16, were identified as full of
liquid. If U.S. EPA had chosen to, more than 3 of the 43 discovered drums
could have been sampled for liquids.
.
Most of the drums identified were nqt fully intact. The drums were generally
deteriorated and semi-crushed, but for the.most part still contained
appreciable quantities of materials. These materials were predominantly high
in concentrations of volatile organic compounds, which are generally soluble
in water by nature, and are thus environmentally mobile.
~
The estimate for volume of drums in the landfill was developed using available
information described on pages F-3 through F-S of the FS. The limitations of
this estimate are presented in Appendix F. The estimate that one-half of the
drums contain liquids is presented on page 4-2 of the FS, and was based upon
field observation. More importantly, however, this estimate is presented to
allow a~ evaluation of remedial measures for the drummed wastes. Liquid and
solid wastes have different acceptable waste handling methods with different
associated costs. Some estimate of the quantity of liquid and solid drummed
waste was needed in order to develop remedial alternatives for the drummed
waste. Such a characterization was not a critical basis upon which U.S. EPA
assessed risk from the drummed waste in the landfill.
The crude transport and fate release scenario on pages A-5 through
A-6 of the FS presents a possible risk release scenario that illustrates that,
with no action taken in the landfill, future release of drummed hazardous
substances to the environment may take place, presenting an unacceptable
public health and environmental threat. The scenario that a drum of liquid.
with concentrations of volatile organic compounds, as measured in RI sample
DWll, may release to the Forest Waste shallow aquifer, is reasonable based on
data from the site. The current condition of waste containment at the
landfill would not prevent such a release to the aquifer. Drum failure,
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;, :"".-~ :.,:.-:.:'"~" ~ .
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6
furthermore, is possible given the acidic pH values of some wastes identified
in the landfill, as well as natural oxidation processes. Although evidence
that such a release has occurred is not apparent, the possibility that such a
release could happen is reasonable.
Thjs scenario modelled the hypothetical release from one drum. Appendix A of
the FS points out that if more than one drum would fail, the possible impact
to the shallow aquifer could be greater.
U.S. EPA does not think 4,000 drums filled with hazardous liquids are ready to
burst simultaneously and release to the aquifer. Rather, Appendix A indicates
that a release from the drums in the landfill, causing significant public
health and environmental concern, may occur if the site is not remediated.
The U.S. EPA preferred landfill Alternative SRCVT was developed based on
guidance to array alternatives within a treatment range ("Superfund Select~on
of Remedy Guidance", December 24, 1986). Alternative SRCVT provides
treatment to reduce toxicity, mobility, and volume of highly concentrated,
mobile waste, but does not eliminate the need for long-term management. For a
full understanding of the development of Alternative SRCVT, refer to Chapters
2, 3, and 4 of the FS.
I.C.
Comment
The U.S. EPA has misconstrued the permanency preference of SARA Section 121.
1. The U.S. EPA decision-making process at.~his site has ignored the fact
that Section 121 of SARA expresses a preference, not a requirement. The U.S.
EPA based their proposed remedy on the concept that this preference is
mandatory.
.
2. The portrayal of the U.S. EPA recommended landfill remedy is estimated to
include treatment of 8,000 drums of material, or 2,000 cubic yards of material
which comprises less than 1% of the total volume of the landfill. The U.S.
EPA proposed remedy of permanent volume reduction of approximately 1% of the
hazardous constituent volume cannot be considered a "significant reduction of
- vol iJme". The treatment portion of the U.S. EPA proposed remedy was questioned
to be a "principal. element of the remedy.
3. In selecting the recommended landfill Alternative SRCVT, "U.S. EPA has
chosen to allow an undetermined source of unknown drummed waste, comprising
less than 1~ of the total volume of the landfill to drive its remediation
proposal without any evidence of imminent threat to human health or the
environment at the expense of increased risk of exposure to workers and the
cOllll1unity. II Page 18 of "Comments Submitted on Behal f of the Forest Waste
Coordinating Committee for the Forest Waste Disposal Superfund Site",
February 27, 1988 ("PRP Comments").
4. U. S. EPA's decision at Forest Waste should be compared with the recent
U.S. EPA ROD at the Waste Disposal Engineering (WOE) site. The concept of
partial or total drum removal is inconsistent with the approaches used at WOE,
the Newport Dump, and the Volney Landfill Superfund sit~s, as well as numerous
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7
closed municipal landfills in the State of Michigan. U.S. EPA should examine
the Michigan policy regarding closure of former municipal landfills, which
generally has preferred containment.
S. U.S. EPA has failed to perform the final balancing test of remedy
selection. Section 121 requires a balancing among the factors of
protectiveness, the degree of potential reduction in volume, toxicity, or
mobility, and cost-effectiveness. U.S. EPA has totally overlooked or ignored
the fact that Alternative SRVC fully satisfies SARA Section 121 because it
provides for significant reduction in mobility, together with some treatment,
is more cost-effective, and is fully protective. U.S. EPA's own conclusion is
that Alternative SCRV is fully protective and attains ARARs.
I.C.
Response
u.S. EPA is fully aware that CERClA Section 121(b) states a preference, and
not a requirement, for treatment remedies. In addition to the preference for
treatment as a principal element of a remedy, Section 121 of CERClA also
mandates utilization of permanent solutions and alternative treatment
technologies to the maximum extent practicable. At Forest Waste, however,
significant and permanent treatment as a principal element is practicable, and
is a component of the alternative that provides the best balance of the nine
evaluation criteria for the site.
~ternative SRCVT was deieloped as an alternative which provides some
treatment to significantly and permanently reduce toxicity, mobility, and
volume of waste, but does not eliminate the need for long-term management at
the site. The treatment portion intentionally focuses on those wastes that
present a significant environmental threat. The wastes associated with drums
at the site, due to their physical and chemical nature. are a more signif1cant
environmental threat than other wastes at the site. Drum wastes contain high
concentrations of toxic, highly mobile contaminants (primarily volatile
organic compounds). The concentrated areas of drums in the landfill (" hot
spots") constitute the waste of concern in the landfill.
.
Although the perceAtage volume of the drummed landfill waste may be small, the
nature of this waste indicates that it presents a greater environmental threat
than other landfill wastes. Site records indicate that large portions of
the landfill contain general household refuse (roughly one-half of the
landfill area). Other types of wastes known or thought to be disposed of in
the landfill (i.e., PBB-contaminated feed and septic sludge), due to lower
toxicity and mobility, do not present as great environmental threats as the
drummed waste (See Figure 1-2 of PRP EA, October 9, 1987). It is also
significant to note that the incineration treatment intended for the drummed
waste is known to be effective and efficient on such highly concentrated
organic wastes. While the commenter chooses to limit the interpretation of
treatment benefits gained in Alternative SRCVT to a miniscule total landfill
waste volume reduction, U.S. EPA notes that an identified waste medium of
concern (drummed wastes) will be treated (incinerated) to gain significant
and permanent reduction of the toxicity, mobility and volume of that'waste
medium of concern. Such a treatment component,of the preferred remedy-rs-
clearly-a principal element of the remedy. At this site it does not make
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~~.1.' -~-,-.:.o'...'u...........,' """
~. ..."""..;,~.\-..,...............,.,..~ o~~. -~, ~....-.... ,,"'.....~....-, - .
8
sense to apply a shortsighted application of benefits gained from the
treatment in Alternative SRCVT to that of only volume reduction of total
landfill waste. Benefits gained should be evaluated in light of permanent and
significant reduction of toxicity, mobility, and volume of the waste being
treated to enhance the long-term effectiveness afforded by the remedy. It is
interesting to note that the commenter does not provide any comment on the
toxicity and mobility reductions gained in Alternative SRCVT, both of which
are significant and permanent. ----
While the precise number of drums in the concentrated areas of the
landfill is unknown at this remedy selection stage, the current
information and estimates available identify the drum areas as areas of
concern, due to the nature of the contaminants (concentrated toxic, mobile
contaminants) and the insecure current disposal situation of these wastes.
explained above, in the case of drum failure, (which, based on the data, is
possible) a release of waste to the environment (groundwater) may present an
unacceptble public health and environmental threat.
As
It is important to point out that evidence of a current release of waste to
the groundwater within the landfill perimeter exists. Page A-5 of the FS
explains that during the test pitting activity, a perched water sample taken
from landfill test pit No.5 contained high concentrations of Hazardous
Substance List (HSL) constituents also found in a liquid drum waste sample
taken from the same test pit. This information suggests that drum failure has
already occurred and that it is only a matter of time until the solubilized
contaminants percolate to the groundwater.
While the groundwater monitoring scheme surrounding the landfill indicates
that contaminants have not yet migrated to the groundwater outside the.
landfill perimeter, the current insecure disposal situation would not prevent
such a migration. Furthermore, the groundwater flow rate Tn the landfill area
is low (estimated to be 2 feet per year) thus, detection of a release by the
slightly removed groundwater monitoring scheme will take some time. The
nearest monitoring well downgradient of shallow aquifer flow is approximately
100 feet from the landfill.
.
The containment provided by the cap and slurry wall in Alternative SRCVT will
help control migration of released wastes from the landfill area. The drum
excavation and treatment is provided to remove those wastes which may not be
reliably contained by the cap and slurry wall system (see Response to Comment
II.B.) The treatment, furthermore, will significantly and permanently
remediate these wastes of concern. An expounded rationale for the remedy
selection is documented iD the attached Record of Decision (ROD) where the
final balancing of the nine evaluation criteria is presented.
The ROD and FS recognize that there is a risk of exposure to the workers and
the community during excavation activities. U.S. EPA does not, however,
suspect there to be risk of explosion or uncontrolled reaction during
excavation, based on the current information on the wastes. The greatest risk
appears to be from release of volatile compounds to the air. Some air
releases were observed with air monitoring. equipment during the landfill test
pit investigation. Such releases, however, were not detected several feet
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9
away from the excavations, as ambient air apparently rapidly diluted the
release.
Safety plans, prescribing worker protective equipment and air monitoring
schemes, will be applied at the time of remedy implementation. The risks of
drum excavation can be safely managed, and such risks balance against the
benefits gained from drum excavation and treatment.
The remedy selection process at a Superfund site is complex. This process
requires careful site-specific data collection in a RI, and application of
evaluation criteria to an array of alternatives which address site-specific
conditions in a FS. Simple application of other remedies selected at other
Superfund sites as a grounds for selecting the remedy at Forest Waste, is not
appropriate. While partial or total drum removal was not considered
appropriate at the Waste Disposal Engineering (WDE) Site, the Vol ney Landfill,
and the Newport Dump, the Administrative Records for those sites support the
remedies selected based on site-specific determinations. At Forest Waste the
treatment is practicable.
All three of these landfills have characteristics different from Forest Waste.
All of these landfills are much larger than the Forest Waste landfill, ranging
from 39 acres to 114 acres. None of these landfills appear to have an
identifiable concentration of drums or hazardous materials that could be
safely excavated. .
The ROD for the Volney landfill states that "no known hot spots of hazardous
material have been identified in the, landfill" (page 2 of the Declaration for
the Record of Decision, July 31, 1987). Th~~Newport Dump ROD provides no
description of conce.ntra.tions of hazardous materials, and the site history
section describes the site only as a municipal Jandfill. Forest Waste, on the
other hand, was permitted to accept liquid industrial wastes (See page 1-2 of
U.S. EPA RI). The WDE ROD does describe a concentrated area of hazardous
wastes, but, due to the known presence of incompatible wastes, excavation of
these potentially reactive wastes was considered a severe safety risk (page 26
of WDE ROD, December 31, 1987). Forest Waste, as decribed above, does not
have a disposal history of or known disposal locations of reactive wastes, and
the risks of uncontrolled releases during landfill excavation are minimal.
.
Superfund reme~y selections do include actions where partial waste
excavation and treatment is a principal component of the remedy. 'The
RODs for the Metamora Landfill Site in Metamora, Michigan, and the
Spiegelberg Site in Livingston County, Michigan, are submitted to the
Forest Waste Administrative Record to provide examples of decisions where "hot
spot" treatment has been determined to be appropriate. .
Applying closure procedures for Michigan municipal landfills as a
proper remedial action at Forest Waste is also not appropriate, based on
reasoning outlined above. The Forest Waste site has been
determined to be a priority for remedial action under the Superfund
Program. This site is listed on the National Priorities List for
Superfund cleanup. Closing the site as a municipal landfill would
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10
not provide adequate public health and environmental protection,
particularly relative to protection of release of wastes from the
landfill to the groundwater.
U.S. EPA recognizes that Alternative SRCV satisfies all ARARs and
provides adequate public health and environmental protection, if it
performs as intended. Other containment systems installed. similar to
that in Alternative SRCV, however, have been known to fail when
contacted with concentrated wastes. Comments received during public
comment period seriously question the ability of the containment
system to adequately manage the concentrated organic wastes
associated with the drums. This information has caused U.S. EPA to
reevaluate the FS claim that Alternative SRCV is fully protective.
r
U.S. EPA does not fully agree with the comment that Section 121 requires a
balancing among the factors of protectiveness. degree of PDtential reduction
in volume. toxicity. and mObility. and cost effectiveness. Section 121
mandates that a protective and'cost effective remedy be selected. In
addition. Section 121 mandates that a remedy which utilizes permanent
solutions and alternative treatment teChnologies or resource recovery
technologies. to the maximum extent practicable. be selected. In remedy
selection. U.S. EPA balances a series of considerations (the nine criteria) to
provide for a remedy which satifies the statutory mandates. This balancing
has been considered and is documented in the site Record of Decision. U.S.
EPA recognizes that Alternative SRCV provides reduction of mObility of
hazardous substances. though it notes that this is through waste containment
(cap and slurry wall) and not permanent treatment. as is the stated preference
of Section 121. Although treatment at Superfund sites is ooly a preference.
Alternative SRCV does not provide ~uch treatment as a principal element. and
U.S. EPA believes that treatment of a principal element of the threat at this
site is practicable.
.
U.S. EPA does not agree with the commenter that Alternative SCRV is mOre cost
effective than Alternative SRCVT (See cost-effectiveness discussion in comment
I.D., below). The permanent treatment and reliable protectiveness of
Alternative SRCVT makes it mOre cost effective than Alternative SRCV.
1.0.
Comment
The U.S. EPA proposed landfil! alternative is not cost-effective. The U.S.
EPA has paid only superficial attention to the SARA and NCP requirements that
cost-effectiveness be evaluated in selecting an appropriate remedy.
I. The recognized U.S. EPA policy that the cost of a remedy must be
proportional to its effectiveness has not been followed at the Forest Waste
Site. According to the I985 NCP. during the initial screening of
a I ternatives. a comparison of incrementa I benefits achieved for incremental
costs should be done. The 1987 Draft NCP reiterates the current NCP's.
endorsement of evaluating incremental cost and benefits. The U.S. EPA Remedy
Selection Guidance underscores the importance of assessing cost when comparing
alternatives that yield similar results.
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-------
11
2. A U.S. EPA official made a comment to the FWCC that clearly implied that
as long as a site is relatively small and the cost of the remedy under
consideration does not "shock the conscience", i.e., over $40-50 million, it
will be deemed acceptable. This approach ignores the 1987 Draft NCP's
requirements of measuring proportional benefit derived from incremental
increases in cost. .
3. Excerpts from Senator Bentsen's Senat~ floor debate in the Superfund
amendments were provided on pages 22 and 23 of "PRP comments". The PRPs
e~phasized that Senator Bentsen's comments indicate that cost is a
consideration in the determination whether or not"a "permanent" remedy is
practicable. The PRPs claim that Senator Bentsen's comments imply that there
, is a requirement for an analysis of cost and benefits of various alternatives.
4. The u.s. EPA preferred landfill alternative is inconsistent with
cost-effectiveness requirements of SARA and the NCP because it
completely mischaracterizes the incremental benefit gained by expending $18
million to destroy 1% of the volume. Such a situation is a classic example of
why U.S. EPA mandated a cost-effectiveness screening criteria for use at all
Superfund sites. A final selected remedy must stop short of requiring huge
monetary expeditures for incidental benefits.
the
5. If U.S. EPA intends to formulate remedies at all Superfund sites
similar to the Forest Waste landfill preferred alternative, it is evident that
$8.5 billion will not remediate very many sites.
.
6. The additional $18 million cost," increas~d short-term exposures to the
community and workers during landfill wasteOOhandling and transport, and
increased difficulty in implementability and maintanence requirements makes
Alternative SRCVT less appropriate than the FWCC January 21, 1988, proposal or
Alternative SRCV.
7. U.S. EPA's proposed landfill remedy is not cost-effective just because
U.S. EPA describes it so. Perfunctory and conclusory statements of
cost-effectiveness and inclusion of extremely costly alternatives in order to
make another, less expensive, alternative appear cost-effective should have no
place in U.S. EPA decision-making.
8. The PRPs questioned as illogical the implication in the Remedy Selection
Guidance that if a site is large and complex, treatment would not be
considered.
9. The additional cost to implement the U.S. EPA landfill Alternative SRCVT
($22.5 million) is at least $18 million more than the cost to implement the
PRP January 21, 1988, remedy ($4 million). The PRP remedy is fully
protective, complies with the cleanup standards of Section 121, and complies
with ARARs. The U.S. EPA conclusion to spend this additional money ~o remove
and treat drummed waste representing 1% of the total landfill mass is .
arbitrary and capricious, and is not otherwise in compliance with the law.
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12
I.D.
Response
u.s. EPA paid careful attention to the cost-effectiveness requirement in the
remedy selection process for Forest Waste. Throughout the decision making
process the degree of effectiveness provided by different technologies and
remedial alternatives was compared and, where a lesser cost option provided
the same degree of effectiveness. the greater cost option was eliminated from
consideration. It must be kept in mind. however. that permanent treatment
options, which require no long-term residual management of the treated waste.
are expensive.
The cost-effectiveness evaluation began in Chapter 3 of the FS. where
remedial technologies were screened based on technical and relative cost
criteria. Technologies which cost more and provide no incremental
effectiveness were screened out. As alternatives were assembled in Chapters 4
and 5 of the FS, cost information was developed, and an array of alternatives
was developed with the most cost-effective components selected for the
alternatives. Implementability and effectiveness were also considered in
assembling alternatives.
The range of alternatives prescribed in the U.S. EPA Superfund Selection of
Remedy Guidance (December 24. 1986), were developed in the FS: no action,
containment option, and a range of treatment options that include an
alternative that would eliminate the need for long-term management and an
alternative that would provide some treatment. Extremely costly alternatives
(over $50 million) were developed as a result of the guidance that
alternatives be developed which require no ~esidual risk management. The
alternatives range was useful in identifying and quantifying increased costs
associated with greater degrees of risk management. The landfill alternatives
developed in-detail in the FS varied in the degree to which they involved the
long-term management of residual risk, with no two alternatives managing risk
in an identical fashion. Table 5-4 of the FS describes the varying degrees of
risk management gained with each of the landfill alternatives.
The commenter simplifies the incremental benefit gained in Alternative SRCVT
as costing $18 million to destroy lS of the landfill waste volume. The
analysis is ill-contrived in two senses. First, to simplify the benefits
gained in the treatment portion of Alternative SRCVT to a reduction of 1% of
the landfill waste volume is inaccurate, since the real gain is destruction of
hazardous substances and the reduction of toxicity and mobility of the waste
(see Comment I.C. above). Second, in identifying $18 million as the cost for
the treatment portion of Alternative SRCVT. the commenter has calculated the
difference between their cost estimate of the January 21, 1988, proposal and
U.S. EPA's cost estimate of Alternative SRCVT, implying that the only
difference between the two is the treatment portion in Alternative SRCVT, and
that the two cost estimates were calculated in an identical fashion.
There are a number of differences between the PRP and U.S. EPA remedies, a
most significant difference being the cap configuration. The PRP cap would
cost less money than the U.S. EPA cap. Perhaps more importantly, inadequate
information has been provided,on the assumptions and source information for
the PRP cost estimate. Appendix D of the U.S EPA FS provides the information
.
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13
on how U.S. EPA costs were configured. A comparison of the costs for these
two remedies simply is not reasonable. The concerns U.S. EPA has with
selection of the PRP remedy are described below in Response to Comment 1.1.
A reasonable estimate for the additional cost of the treatment component of
Alternative SRCVT is easily derived from the U.S. EPA FS by comparing the
costs of Alternative SRCV and SRCVT. This additional cost for permanently
treating concentrated areas of mobile, toxic waste, likely to release to the
environment, is $13 million. Gaining a permanent and complete treatment of
this waste of concern cannot be done less expensively. The risk from that
waste is completely managed. Given the direction in CERCLA Section 121{b) for
preference of treatment remedies and the mandate to select permanent solutions
to the maximum extent practicable, inclusion of such a treatment option in the
FS, and selection of an alternative incorporating such a treatment option is
consistent with the direction given in the law.
Guidance for balancing the costs of treatment options, which are
consistently more expensive than containment op~ions, is given in U.S. EPA
Remedy Selection Guidance December 24, 1986 (OSWER Directive No. 93555.0-19):
"Cost is an important factor when comparing alternatives of similar results
{i.e., cost may be used to discriminate among treatment alternatives, but not.
between treatment and nontreatment alternatives)." Dismissal of Alternative
SRCVT in deference to Alternative SRCV should not have been, and was not done.
Complete rationale for selecting Alternative SRCVT is provided in the attached
ROD, and balances the nine evaluation criteria.
U.S. EPA believes that the selection "of Alternative SRCVT .is consistent with
Senator Bentsen's Senate floor statements. Cost was considered in determining
the practicable extent to which permanent solutions and treatment could be
utilized in a cost-effective manner. The incremental costs of treating wastes
and providing containment beyond that in Alternative SRCVT were determined as
to be impracticable and to outweigh the risk management benefits and,
therefore, were not preferabl e.
.
Short-term risks to the community were considered in the selection of
Alternative SRCVT (see Response to Comment I.C.)
Implementability difficulties were also considered in the selection of
Alternative SRCVT. Complete definition of concentrated drum areas, beyond
that done in RI phase. can reasonably take place in design phase. Handling
and treatment of an estimated 2,000 cubic yards of material (8,000 drums) is
not a significant implementability issue.
U.S. EPA believes the maintenance of Alternative SRCVT will be less than that
required in the PRP January 21, 1988, proposal. Concentrated mobile waste
will be removed from the landfill and completely treated. The need for long-
term onsite management of this waste will be eliminated.
The misinterpretation by the commenter of an U.S. EPA official statement that
cost evaluations are reduced to an evaluation of threshold
acceptability (i.e., over $50 million is unacceptable) is just that, a
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14
misinterpretation. Cost is carefully considered on a site specific basis as
balanced against effectiveness and implementability.
u.s. EPA recognizes the cost of the Forest Waste landfill remedy and
limitations of the Hazardous Waste Trust Fund. The Fund. however. is
not the only means to finance cleanup; enforcement actions are also an
integral part of the CERClA program. U.S. EPA does not feel it is
appropriate to arbitrarily cap remedy costs based on the size of the
Trust Fund. Rather. specific directions given in the law and NCP drive
the remedy selection process.
The Remedy Selection Guidance (OSWER Directive 9355.0-19) states that
the nature of some sites (e.g.. large complex landfills) would preclude the
use of alternatives which would involve treatment of the source as a principal
element. This guidance reflects the fact that identification of
concentrations of source materials. suitable for permanent treatment. is
sometimes difficult or impossible at large complex sites. This would make
source treatment options impracticable.
Specific responses to comments on the 1987 Draft NCP are not provided. The
Draft NCP is not out for public review or Agency use. This document is still
undergoing revision. and is not intended to be used as direction for remedy
selection. This document was not relied upon in reaching a decision on the
Forest Waste remedy.
I.E.
Comment
.
The U.S. EPA proposed landfill remedy. which includes excavation and
incineratton of drums. would set an unwise new precedent for addressing the
problem of municipal landfills.
..J
1. Requiring partial or complete excavation of the tens of thousands of
landfills across the country to eliminate Nhot spots" was not the intent of
SARA. The excessive costs required to excavate landfills in search of the
"hidden drum" is a waste of economic resources and defies economic sense. It
is not "practicable" to provide the proposed treatment portion of the U.S. EPA
recommended alternative.
2. The only.way to effectively and efficiently remediate sites such as Forest
Waste is through containment and institutional controls. SARA did not intend
to eliminate engineered and institutional controls. Use of containment can be
a protective and cost-effective remedy.
3. The concept of total or partial drum removal is inconsistent with the
approach recently used at other Superfund sites such as the Waste Disposal
Engineering (WOE) site. Newport Dump. and the Volney landfill. as well as at
numerous closed municipal landfills in the State of Michigan. .
I.E. Response
As described in the Response to Comment I.C., U.S. EPA does not consider
Forest Waste Disposal a municipal landfill. This site was licensed to accept
-------
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15
industrial wastes and had a number of operational violations during its time
of operation. Concentrated areas of hazardous waste have been identified in
the Forest Waste 1 and fill .
FWDS has been identified as a priority site of concern for the Superfund
Program by its listing on the National Priorities List (NPL). Application of
municipal landfill closure activities to this site is not appropriate and is
not sufficient to fulfill all the requirements of CERCLA.
Sites. eligible for Superfund (Section 104) remedial actions must be identified
as a priority through the NPL listing procedure. The Superfund program does
not have the authority. nor was it intended to. evaluate and remediate every
landfill in the country.
At Forest Waste. the treatment component selected is practicable.
Concentrated areas of toxic. mobile. hazardous wastes have been identified.
and can be reasonably defined in the design for cleanup. U.S. EPA is not
searching for "hidden drums" at Forest Waste. rather it is focusing on
concentrated waste disposal areas. Leaving such waste in the landfill
presents reliability concerns about the ability of a cap and slurry wall to
control releases to the groundwater. Excavation and treatment of the.
manageable estimated 8.000 drums of hazardous materials and contaminated soils
is a practicable approach for gaining long-term effectiveness and permanent
treatment as a principal element of the remedy. Containment and institutional
controls are an important part of the landfill remedy. however. U.S. EPA
chooses not to rely on these controls at this site because it is practicable
to perform more active measures.' .-
.
Comparison of remedial action at the WDE site. Newport Dump. and Volney
Landfill are addressed in the Response to Comment I.C.
I. F. Comment
The U.S. EPA proposed landfill alternative fails to adequately consider health
and safety risks to workers and the surrounding neighborhood. These short-
term risks include the potential for air emissions created during excavation
of drums from the landfill and from proposed transport of hazardous materials
removed from the site.
1. The Superfund statute states a preference for permanent remedies. but does
not eliminate the need for thorough evaluation of risks associated with such
remed i es.
2. While the U.S. EPA FS noted there were short-term risks in a partial drum
remediation. this awareness was not reflected in the final selected
alternative. The U.S. EPA has not articulated why the gained treatment in
Alternative SRCVT outweighs. on balance. the increased health and safety risk
to workers and the community.
3. U.S. EPA has not ignored workers and community safety issues at other
Superfund sites. The WDE site is a specific example of such a site..
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16
4. The U.S. EPA did not quantitatively discuss the risk associated with the
landfill excavation activities and waste transport.
I.F.
Response
The health and safety risks associated with drum excavation and offsite
treatment have been considered by U.S. EPA. Table 5-4 of the FS. for example,
recognizes and describes these risks. The U.S. EPA perspective on this risk,
its relative magnitude at this site and the WDE site, and U.S. EPA intentions
to manage this risk. are expounded in the Response to Comment I.C.
A specific quantification of this risk was not done because information from
the site specific test pitting activities indicates that risk from air
emissions is very low. and data to quantify it are not available. The risk
from transport of wastes through communities similiar to Forest Waste has been
observed as minimal. and data to reasonably quantify this risk at Forest Waste
are not available. These risks are. however.. viewed as small and manageable.
The long-term risk of leaving the areas of concentrated drum wastes in place
is not viewed by the U.S. EPA as acceptable. Permanent treatment of these
wastes is most certainly practicable in this case and provides unqualified
permanent management of these wastes. The short-term risk incurred during
handling of this waste simply is not significant enough to warrant
unacceptable long-term permanent management of this waste. (See also Response
to Comment I. B.). .
I.G. Comment
.
. -
The U.S. EPA Proposed Plan is inconsistent with the NCP's requirement for a
detailed evaluation.
1. The NCP requirement of detailed analysis of alternatives is wholly lacking.
from the U.S. EPA's FS. Instead of a detailed analysis. U.S. EPA's FS is
replete with conclusory tables and summaries.
2. U.S. EPA has failed to provide a description of its proposed partial
remediation of drummed wastes. U.S. EPA has provided no detail on how it will
conduct remediation of the 4.000 drums. No scope of the partial drum removal
aspect of U.S. EPA's remedy has been defined, and no explanation of the basis
for determining completion of that remedy was provided.
3. Such lack of detail deprives the public of information needed in order to
reasonably analyze the Agency's proposal. The public was not provided with a
meaningful opportunity to evaluate the Proposed Plan and has been deprived of
procedural due process.
I.G. Response
The U.S. EPA disagrees with the commenter that a detailed analysis of the
final set of assembled alternatives was not done. Beginning on page 5-9 of
the FS. a detailed evaluation of landfill alternatives is presented. The
entire Chapter 6 of the FS provides detailed evaluation of the groundwater
..
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17
alternatives. A detailed description of the assembled alternatives begins
in Chapter 4 of the FS for the landfill alternative. All of the NCP
required analyses in Section 300.68(h) are in these chapters of the FS,
including: a detailed description of the alternatives, detailed cost
estimates, evaluations of implementability, reliability, and
constructability, the effectiveness of public health and environmental
protection, compliance with ARARs, an analysis of advanced technologies
(incineration), and an analysis of adverse environmental impacts. The FS
was carefully composed to not be conclusory, and the evaluations presented
describe why and how certain evaluation criteria are met. For example,
Table 5-4 describes the short- and long-term public health and
environmental risk management provided by Alternative SRCVT. Short-term
risks are reduced with a landfill cap and deed restrictions which prevent
direct contact exposures. The long-term risk of release of wastes to the
groundwater is reduced with concentrated drummed waste removal and
treatment, and cap and slurry wall containment of the remaining wastes.
As stated in the Response to Comment I.B., a full characterization of the
nature and volume of drums in concentrated drum disposal regions of the
landfill was not done in the RI, nor is such a characterization necessary
for remedy selection. With the current information available, a
conservative estimate of the number of drums was developed as presented in
Appendix F of the'FS. This estimate is 4,000 drums. Alternative SRCVT was
configured in the FS to include excavation of these 4,000 drums and an
additional 4,000 drums of contaminated soils. Based on drum removal
experience, this additional removal .of a volume of 4,000 drums of soil is
reasonable. The exact extent of waste exca~ation will not be known until
this remedy is actually implemented. To define the drum excavation and
staging design prior to the remedy selection, in order to assure complete
information about all alternatives under consideration, is not appropriate.
A more precise definition of the areas of drum removal will be identified
in the remedial design stage.
.
u.S. EPA recognizes the limitations in the current information about the
number of drums to be removed. The cost estimate for this remedy is
understood to be crude (an expected accuracy of +50% to -30%) and is based,
to some degree, on the estimated number of drums for removal. U.S. EPA is,
nonetheless, ready to make a remedy selection decision based on this
information. All of this information, and its limitations, has been
presented in the remedy selection proposal. The public has peen provided
with sufficient information to comment on the proposed alternative.
There is some concern in any remedy selection process that the cost
information developed is based on grossly inaccurate information and
assumptions, and a remedy is selected as cost-effective with very poor cost
information. U.S. EPA is currently selecting Alternative SRCVT as ~ cost
effective remedy for the Forest Waste landfill based on the $22.8 million
cost estimate with an expected accuracy of +5~ to -30%. During the design
phase, this cost estimate will improve, and after bids from contractors'
regarding the cleanup activities are reviewed, the U.S. EPA will have a
very good estimate of the cost of imp1ementfng Alternative SRCVT. If at any
time, the cost-effectiveness determination of this remedy is called into.
question, U.S. EPA will reevaluate .it as the proper remedy for the site.
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\
18
I.H. Comment
u.s. EPA's Proposed Plan fails to adequately analyze the nine criteria set
forth in the newly revised NCP.
1. The PRPs evaluated the U.S. EPA proposed landfill alternative and the PRP
January 21. 1988. proposed landfill remedial alternative in light of language
from the draft NCP.
2.
Both remedies are protective of human health and the environment.
3.
The PRP remedy complies with all ARARs.
4. Both remedies fully satisfy the 1987 Draft NCP long-term effectiveness
criteria.
5. Both remedies meet Section 121 by significantly reducing mobility.
The U.S. EPA preferred landfill remedy overreaches the preference for
treatment in Section 121 at the expense of cost-effectiveness.
6. The U.S. EPA Proposed Plan ignores significant risks of potential harm to
workers and neighbors during excavation. removal. and transport of drums.
7. The containment and treatment
implemented. For most Superfund
even when there are greater risks
Forest Waste.
remedy proposed by the PRPs is easily
sites. containment is the preferred remedy
of.contami~ation than those present at
.
8. Language for remedy selection from the draft NCP (page 40 "PRP cumments")
was extracted and applied to the Forest Waste remedy selection process. The
conclusion of such application is that U.S. EPA must reevaluate its selected
ROD remedy based on the cost-effectiveness argument and must select either the
PRP proposed alternative or the U.S. EPA FS Alternative SRCV.
1.1. Comment
The PRP proposed remedy is fully' protective.
1. The PRP's landfill remedy is virtually identical to the U.S. EPA FS
Alternative SRCV.
2.
The multiple layers of protection of the PRP remedy are described:
a)
Virtually all rainwater would be prevented from infiltrating the
1 andfi 11 ;
b)
Installation of the
the upgradient side
would be allowed to
slurry wall will prevent groundwater from entering
of the landfill and nothing within the ~andfill
leave the encapsulated area;
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19
c)
The 15-20 feet of clay underneath the landfill serves as an excellent
f1 oor;
d)
If water or leachate moves underneath the cap, extraction wells would
collect and cleanup the water or leachate. This aspect of the
proposal provides greater certainty than the result the U.S. EPA is
hoping to achieve through drum excavation. liquids from the landfill.
are treated on an as needed basis over time; and
e)
Monitoring wells surrounding the landfill perimeter outside the slurry
wall would monitor the system's performance. The natural site
conditions of thick, well-defined clay layers and slow groundwater
movement would allow ample time to respond should releases be detected.
3. Selection of the PRP remedy over the U.S. EPA remedy eliminates the
short term risks of exposure during excavation. The cost savings are also
substantial.
4. U.S. EPAls Site Selection Guidance acknowledges the effectiveness and
appropriateness of the type of remedy the PRPs propose when it states that
such groundwater treatment remedies would "achieve adequate protection".
5. The U.S. EPA FS concluded that Alternative SRCV is fully protective.
U.S. EPA Alternative SRCV complies with SARA, the NCP, and attains ARARs.
These conclusions apply to the PRP landfill remedy.
The
.
6. The cost-effectiveness advantage" of Alternative SRCV and the PRP remedy
confirm that either approach would be the only acceptable remedies for the
site because they alone satisfy aT1 relevant statutory and regulatory
authority. One of these two alternatives should be selected for
implementation at Forest Waste.
I . H. a nd I. I.
Response
As stated below, U.S. EPA has not used the 1987 Draft NCP as guidance for
remedy selection at Forest Waste. . This document is not final and. is still
undergoing review and potential revisions before its release. The U.S. EPA
remedy was evaluated in light of current U.S. EPA guidance (OSWER Directive
No. 9355.0-19 -Additional Interim Guidance for FY '87 Records of Decision",
July 24, 1987), the current NCP, and CERClA as amended by SARA.
The U.S. EPA recognizes that there is some merit to the PRP January 21, 1988,
proposal in light of some of the evaluation criteria. However it, or
Alternative SRCV, are not the preferred remedy for selection. These remedies
are not acceptable based on concerns over the ability of the cap and slurry
wall containment system to reliably manage, over the long-term, concentrated,
highly mobile, ~oxic wastes in the areas of the landfill where drums were
disposed. Neither of these remedies meet the CERClA Section 121 treatment.
goal and mandate to utilize permanent solutions to the maximum extent
practicable.
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20
The PRP remedy and Alternative SRCV are significantly different in terms of
the cap configuration. The PRP cap is not configured in accordance with RCRA
guidance to include soil, synthetic membrane, and clay. This difference is
significant in the PRP alternative, where the containment system is heavily
relied upon to manage the wastes. The PRP cap is not as reliable as the
Alternative SRCV or SRCVT cap in preventing precipitation infiltration into
the landfill. '.
The U.S. EPA has concerns about the long-term effectiveness of the PRP
Alternative in protecting public health and the environment. U.S. EPA finds
this alternative, and Alternative SRCV, less appropriate than Alternative
SRCVT, because they both rely heavily on the containment system to manage the
drummed wastes. The long-term effectiveness of the PRP alternative or
Alternative SRCV is not adequate.
The U.S. EPA recognizes that Alternative SRCV and the PRP Alternative comply
with ARARs.
The Section 121 preference for treatment is not met by the PRP al ternative or
Alternative SRCV. U.S. EPA recognizes that the containment system of these
alternatives will help reduce contaminant mobi.lity to the groundwater, but
such reduction of mobility is not due to treatment of. hazardous substances,
and therefore does not ful fill the preference for treatment. Alternative
SRCVT practicably meets this treatment preference with permanent and
significant treatment of concentrated, mobile toxic wastes. This permanent
treatment cannot be achieved in any. less expensive fashion. Alternative SRCVT
is cost-effective. .-
.
The short-term risks to the community during-the drum excavation and treatment
portion of Alternative SRCVT are minimal and manageable (See Response to
Comments I.C. and I.F., above).
Containment remedies are selected at Superfund sites, based on site specific
evaluations, when they meet the statutory requirements for remedy selection,
and when treatment and more permanent solutions are not practicable.
Containment exclusively at Forest Waste is not the preferred alternative.
Risks at this site are not appropriately managed with containment alone.
Containment alone, furthermore, does not meet the Section 121 preference for
treatment. Treatment as a principal element is practicable at this site.
The till floor underneath the landfill will serve well to manage the remaining
wastes in the landfill after drum excavation. U.S. EPA does not believe,
however, that this floor should be relied upon as a component of a containment
system for concentrated drummed wastes.
The commenter has quoted the Remedy Selection Guidance (OSWER Directive
9355.0-19) out of context when stating it claims that groundwater treatment.
remedies would "achieve adequate protection" at Forest Waste. When reviewing
the entire document, it is clear that the guidance is explaining when
alternatives, which include treatment of the source as a principal element,
can be eliminated from consideration. The guidance directs that such
alternatives can be screened when effectiveness, implementability, and cost.
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'\
21
factors point to treatment as impracticable. In such cases source treatment
would be screened, and protection would be achieved typically with containment
and groundwater actions. . At Forest Waste, exclusive groundwater actions are
not the preference, because effectiveness, implementability, and cost factors
support source treatment as manageable and practicable.
I.K. Comment
u.s. EPA should have addressed groundwater cleanup action levels in its
proposed plan.
1. u.s. EPA has failed to identify any specific target cleanup levels (TCLs)
which would trigger the need for evaluation of future groundwater issues.
2. U.S. EPA has failed to identify any specific TCls in the event future
groundwater remediation is necessary.
3. U.S. EPA is required to identify its proposed cleanup levels in order to
permit public review and comment. Not doing so constitutes a denial of due
process under the U.S. Constitution and is a violation of SARA, the NCP, and
the Administrative Procedures Act (APA).
4.
The ROD should not identify TCLs for this si~e.
5. Haximum contaminant levels (MCls) should be selected as TCLs for this
site. This is U.S. EPAls national policy as expressed in numerous U.S. EPA
guidance documents and memoranda. Other en~ironmental regulatory programs
adopt MCLs as policy as well.
.
I. K.
Response
The proposed plan (page 11, last paragraph) describes that a plan for further
groundwater remedial action will be developed for the groundwater plume to the
east, if the monitoring program indicates that concentrations of contaminants
in the groundwater at the site boundary exceed the groundwater remedial action
goals. The groundwater remedial action goals are presented on the top of page
.2-4 of the FS. The shallow aquifer at Forest Waste is a drinking water
aquifer, and the goals for its protection include maintaining groundwater
contaminant concentrations less than MCLs, lifetime health advisories, levels
of noncarcinogenic health effect protection (based on reference doses), a
lifetime cancer risk range of 10-4 to 10-7; and maintaining groundwater
quality so that discharge of groundwater to surface water will not exceed
Ambient Water Quality Criteria. This information was provided to the public
for review and comment. .
Many of these goals point to contaminant specific groundwater Target Cleanup
Levels (HCLs, lifetime health advisories, health effect protection ~ased on
references doses). The other goals will require careful evaluation of all
contaminant data (lifetime ~ancer risk range) and some modelling of
groundwater data, to predict discharge concentrations to the surface water
(compliance with Ambient Water Quality Criteria (AWQC) at the nearest surface
water discharge point).
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. . . :",' 'i.7/:,."')., "".,; ~~: ~ ::\. ,-;..-;< .~...: 'J. -. .-.: .~.;:~. .,,- . '; -: ~.::.:'~ -".: - . ~.: -~: :.. ;": .. .'C' "':.
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\
22
In the event that future groundwater remediation is necessary around the
landfill, it is clear in the FS that the cleanup levels required will be the
goals described above. Specific cleanup levels for groundwater around the
landfill, beyond the guidance on page 2-4 of FS, were not presented in the
Proposed Plan because there are currently no identified releases of
contaminants around the landfill.
The groundwater TCls identified in the ROD are consistent with those presented
in the FS. MCls will be included among the TCls, however, they will not be
the on1 y TCls.
U.S. EPA agrees with the commenter that MCls are appropriate for use as a TCl
at this site, because the groundwater is a drinking water aquifer. U.S. EPA
also recognizes that not all contaminants have MCls, therefore, other types of
health advisories will be used to set cleanup levels. Additionally, because
multiple contaminants are frequently encountered at Superfund sites, a
cumulative cancer risk level based on all suspected carcinogenic contaminants
at the site will be held as a groundwater cleanup goal. Finally. because this
groundwater discharges to surface water, use of AWQC will be evaluated in
setting groundwater cleanup levels as well.
I.L. Comment
Groundwater remediation is not necessary at this site because of the low level
of site-derived constituents and the absence of a completed pathway. both
confirming a lack of risk to human health ~nd the environment.
1. Only the shallow aquifer in a 1 imited area immediately downgradient from
the lagoons has shown any evidence of site-derived constituents.
.
2. The shallow aquifer is not a drinking water aquifer. The hydrogeology of
this aquifer does not meet the minimum requirements of the Michigan Department
of Public Health Water Supply System Specifi~ations for Replacement Wells.
Test data from the site show that the shallow aquifer could not sustain a
minimum pumping rate. of 5 gallons per minute and the System Specifications
require that a well installed into and aquifer of the type at Forest Waste
cannot have a pumping rate of less than 5 gallons per minute. The average
depth to water in this aquifer is 12-20 feet, and the system specifications
require that the aquifer must permit at least 25 feet of blank casing below
the ground surface.
3. The PRPs offered to undertake groundwater remediation in their
January 21.1988, proposal in an effort to reach a settlement with U.S. EPA
and MDNR regarding this site.
4. The U.S. EPA Proposed Plan and PRP FS concluded that groundwater
remediation was not necessary at the site because of the low levels 'of site~
derived constituents present and the absence of a completed pathway. both of
which confirm a' lack of risk to human health and the environment.
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23
I.L. Response
The selected groundwater remedial action at Forest Waste is Alternative SR-
Site Restrictions. This alternative includes access restrictions to the site,
deed restrictions to prevent installation of drinking water wells on the site
or in adjacent areas, and a montoring program to identify changes in location
and concentration of groundwater contaminants. To date, only low levels of
contaminants have been identified in Forest Waste groundwater. With one
exception, all RI data have indicated that the current quality of onsite
groundwater meets all of the groundwater remedial action goals. (Data have
been collected by MDNR subsequent to RI activities. These data are discussed
in the Response to Comment II.K.) The one exception includes a detection of
trichloroethene (TCE) in an onsite well at 11 ug/l. The MCL for TCE is 5
ug/l .
The RI data indicate that groundwater contamination is limited to onsite
areas. Conservative groundwater contaminant modelling indicates that as the
current degree of contamination migrates offsite, contaminants will dilute,
and the remedial action goals at the site boundary will be met relative to
both groundwater and surface water protection. The suspected source of the
groundwater contamination, the site lagoons, will be remediated under a
previously selected operable unit remedy of complete lagoon removal, scheduled
for action this const~uction season. No significant increases in current
onsite groundwater contaminant concentrations are, therefore. expected.
Because offsite releases of groundwater contamination appear to be under
control, the selected groundwater remedy a~~resses adequately the onsite
releases with institutional controls. The selected monitoring program will
confirm site cleanup goals. If the manitoring program indicates unexpected
levels of contamination will migrate offsite, a further plan for cleanup will
be evaluated.
.
Contrary to comment, the U.S. EPA has not concluded that groundwater
remediation is not necessary because of the low levels of site derived
constituents and the absence of a completed pathway. Under the No Action
alternative. onsite shallow groundwater could be used as drinking water. This
alternative therefore, would not be protective. Institutional controls are
necessary to prevent the use of this groundwater as drinking water.
Furthermore. a monitoring program, coupled with the option to take further
action, is necessary at this site to assure protection to surrounding surface
water bodies.
U.S. EPA maintains that the shallow aquifer has adequate quality, if
unaffected by site-derived contaminants, and quantity to serve as a drinking
water source. Therefore, it is a drinking water aquifer. Although Michigan
Department of Public Health regulations may help prevent its use as a drinking
water source, such regulations do not redefine this environmental resource, or
the necessary protection for it. It is also important to note that although
the average depth to water in this aquifer is 12-20 feet, there are onsite
areas where the aquifer would permit 25 feet of blank casing below the ground,
and in these areas. the Michigan System Specifications would not prevent use
of the onsite aquifer. U.S. EPA recognizes that the pumping rate of the
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24
onsite aquifer does not meet minimum Michigan System Specifications
requirements.
It should also be noted that the groundwater action at this site is
configured to comply with the relevant and appropriate regulation under
RCRA for groundwater protection, as discussed in the attached ROD.
The groundwater remediation component of the PRP January 21, 1988 proposal,
although somewhat incomplete, does appear to provide adequate public health
and environmental protection, and does appear acceptable to the U.S. EPA.
Reservations concerning the landfill remediation component of the PRP
proposal are outlined above in the response to comments I.H and 1.1.
I.M. Comment
U.S. EPA selection of remedies for both the onsite landfill and lagoons has
been based on incomplete analyses of available data.
1. U.S. EPA's remedy selection was based on:
a. An inadequate assessment of the groundwater pathways;
b. An inadequate assessment of potential contaminant migration;
c. An inadequate definition of hydrostratigraphic units;
d. Poor analysis and use of geophysieal dat~J;
.
e. Poor analysis and use of available test pit data;
f. Poor timing and inefficiencies in implementing the RI/FS;
g. A cost estimate based on tenuous assumptions;
h. lack of consideration of important historical perspective which can be
gained fr~m existing site conditions; and
i. Consideration of non-existent and/or hypothetical risks which may be
posed at the. site.
2. The documents submitted by the PRPs have been clearly underutilized by
U.S. EPA.
I.M. Response
U.s. EPA has carefully considered all comments made and documents submitted
by the PRP FWCC. These documents include. but are not limited to. the
comments submitted on behalf of the FWCC (February 27, 1988) and the .Tech-
nical Comments on the U.S. EPA Remedial Investigation Report (December 17.
1987). the FWCC FS (December. 1987), and Endangerment Assessment
(October, 1987). These, and all documents considered in the remedy
selection, are included in the site Administrative Record.
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\
25
Many of the comments submitted in the documents (above) focus on the site
lagoon wastes and suggest an appropriate remedy for the lagoons. The lagoon
remedy selection has already been made and is documented the ROD for the
lagoon operable unit (June 30, 1986). As these recent documents were
submitted after selection of the lagoon remedy, they obviously were not
considered in the lagoon remedy selection.
The PRP comments on the RI focus heavily on the limited extent and current use
of the onsite shallow aquifer as a drinking water source. The PRPs also focus
heavily on the fact that the shallow aquifer is underlain by low permeability
glacial deposits which are continuous over the site, and serve to separate the
shallow from the deeper aquifer in the area of the site.
u.s. EPA recognizes the regional setting of the shallow onsite aquifer
depicted graphically in Figures 3 and 4 of the PRP FS (December 17, 1987).
On such a large, regional scale, the shallow onsite aquifer does appear
relatively small, as would almost any geologic unit when placed in a
comparatively larger regional setting. U.S. EPA also recognizes that there is
a low permeability till layer underneath the shallow aquifer that potentially
acts as an aquiclude (page 4-3 of the RI) and that there is probably limited
. hydraulic connection between the shallow and deep aquifers (page 4-5 of the
RI).
u.s. EPA also recognizes that currently there are no users of the onsite
aquifer as a drinking water source. U.S. EPA does, however, believe that the
presentation of residential well locations ~how in Figures 1 and 4 of the PRP
FS is misleading. The PRP document apparently presents only locations of
residential wells for which they could find available wen logs. A visit to
the site area makes it clear that several more residences with drinking water
wells are closer to the site than deplcted in the PRP FS. These residence
locations are illustrated in Figure 3-6 of the RI. Perhaps more importantly,
the PRP analysis of percentage of residential wells in the different aquifers
under the site is based on incomplete information. U.S. EPA, on the other
hand, recognizes that well logs are not available for many of the residences
surrounding the site, and the possibility that these residences use the
shallow aquifer certainly exists. U.S. EPA does not believe that the current
incomplete well log information should be used to calculate the percentage of
residential wells in different aquifers under the site.
.
The PRPs argue that the risks posed by Forest Waste ar~ non-existent and/or
hypothetical. As described in the Response to Comment 1.8., the U.S. EPA and
PRP Endangerment Assessments were used to evaluate risks for the site, and
compare site Remedial Action Goals (Chapter 2 of the Rl). Limited current use
of the onsite shallow aquifer does not dismiss the need to protect it from
current and future releases of site contaminants, in order to protect both
public health and the environment.
It was noted by the PRPs that unfiltered groundwater samples were analyzed in
the RI (page 6 of the PRP RI Comments). Although collected, these data were
not used to assess risk at the site. Filtered groundwater sample analyses
were used in the U.S. EPA Risk Assessment (Chapter 6 of the RI).
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26
The PRPs express concern about the interpretation of groundwater flow in the
deep aquifer as presented in the U.S. EPA RI. U.S. EPA acknowledges that the
interpretation of this flow is somewhat uncertain. However. the remedy for
Forest Waste is configured to protect the shallow onsite aquifer. and
conclusive information on deep aquifer flow is not needed for proper remedy
selection. In the RI. investigation of the deep aquifer was done primarily to
determine if it was impacted by site contaminants. The site has not been
shown to have affected the deep aquifer. Similarly. the PRP concern (page 7 of
the PRP RI Comments) about the description of hydraulic conductivity
measurements in the deep aquifer as presented in the U.S. EPA RI is not
significant in remedy selection for the site.
The PRP objection pertaining to interpretation of geophysical data presented
in the U.S. EPA RI is also not a significant concern. As mentioned in the RI
(pages 3-2. 4-7. 4-8). the resistivity survey provided preliminary information
regarding the geologic conditions which was then used to select monitoring
well locations for the RI sampling efforts. Interpretations of the data also
identified a potential contaminant plume. underlying the entire landfill area
and extending offsite to the east and southeast (Figure 4-7 of the RI) as
well. Chemical analyses of monitoring well samples taken over the entire area
identified a much smaller plume. primarily southeast of the lagoons.
characterized by'detected organic contaminants and high inorganic constituent
concentrations relative to background levels (Figures 4-11. 4-12. 4-14. 4-15.
4-16 of the RI). This area is also characterized by high specific conductance
readings (1000 umhos. Figure 4-10 of the RI). It is this smaller area that is
identified as the groundwater plum~ at tha"site for which groundwater remedial
action is considered under the groundwater operable unit in the FS.
.
The PRP comments (on pages 11-13 of their RI Comments) which question the
extent of constituents detected to date in the shallow aquifer were
considered. These comments support the selection of the groundwater
Alternative SR - site restrictions and groundwater monitoring.
The uncertainities associated with. and the use of, test pitting data are
explained in the Response to Comments I.B.. I.C., and 1.0.
Order-of-magnitude cost estimates (+50~ to -30~) have been properly calculated
with available information in order to support selection of the remedy for
this site.
The PRP comment that U.S. EPA based the selected remedy on .poor timing and
inefficiencies in implementing the RIIFS" is not explained. U.S~ EPA
maintains that the selected remedies for the site: the fence (1984), the
lagoon operable unit (1986), and the landfill and groundwater operable units
(1988), were all selected as soon as proper information was available. This
phased approach to remedy selection allowed the U.S. EPA to make steady
p~ogress towards complete site remediation at an accelerated pace.
The PRP comment that U.S. EPA based the selected remedy on .lack of
consideration of the historical perspectiv~ which can be gained from existing
site conditions" was also not explained. U.S. EPA maintains that there are
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27
current releases of hazardous substances to the environment from Forest Waste,
and the site must be remediated to prevent further site releases.
I.N. Comment
The U.S. EPA RI does not indicate whether former site operations have impacted
surface water conditions in the area of the site.
I.N. Response
The effect of site operation on the quality of surface water near the site was
thoroughly investigated in the RI. The type and distribution of organic and
inorganic compounds detected in the surface water did not reveal any patterns
of contamination. The investigation was inconclusive with regard to directly
linking site contaminants to degradation of nearby offsite surface water.
1.0.1
Comment
The Forest Waste Coordinating Committee (FWCC) state they have
been denied due process of law because the comment period of 30 days was
too short to review and analyze "large amounts of technical data and
Agency analysis which were developed over two years." They claim the
length of the comment period precluded any meaningful opportunity to
provide effective comments. The" FWCC cite a 1981 U.S. EPA guidance
document that suggests a 60 day comment period for complex issues or
lengthy documents. That guidance document also outlines a procedure for
public participation and states that AgencYjofficials "must avoid
advocacy and precommittment to a parti cul ar alternative. II
.
1.0.1 Response
The National Contingency Plan (NCP) is the promulgated implementing
regulation for SARA. At 40 CFR Section 300.67(d) it requires a public
comment period of not less than 21 days. The comment period in this case
was 30 days, beginning January 29, 1988, and ending February 27, 1988.
40 CFR Section 300.67(d) also states that public meetings should be held
during the public comment period in most instances. SARA Section 117
also states that there should be an opportunity for a public meeting at
or near the facility and a transcript of the meeting should be kept.
The U.S. EPA and HDNR held a public meeting at the Forest Township Hall
in Otisville, Michigan, near the site, on February 17, 1988, and a
transcript was made of the meeting.
An Endangerment Assessment (EA) on the FWD site was prepared by the FWCC
based on the information they had available, and submitted for inclusion
in the site Administrative Record (AR). The FWCC EA is dated.
October 9, 1987.
The U.S. EPA Remedial Investigation (RI) report, the basis for the
Feasibility Study, was available for public review in early September
1987. The FWCC has submitted comments on the U.S. EPA RI, dated
December 12, 1987. The FWCC drafted their own Feasibility Study, dated
". .'.-."0'.,-,-,... ,"-"""~'. -~'-.'-:;--"""'; ''''''''.-
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. \
28
December 18, 1987, based on U.S. EPA's RI and has submitted it to the
U.S. EPA for inclusion in the site AR.
SARA Section 117(a) requires that a Proposed Plan be made available to
the public. The U.S. EPA's Proposed Plan was made available to the
public on January 29, 1988. By definition, the preferred alt~rnative in
the Proposed Plan is a statement of preference for a particular remedy,
subject to change based upon publ ic convnent. .
U.S. EPA has complied with the requirements of SARA and the NCP regarding
public participation. SARA and the NCP are controlling, as the statute
and implementing regulations, over any pre-SARA guidance document
regarding public ~articipation.
The FWCC has been actively involved with this site since nay 1986. They
met with the U.S. EPA on numerous occasions prior to the signing of the
lagoon operable unit ROD in June 1986. Similarly they met with U.S. EPA
on November 24, 1987, January 13, 1988, and January 22, 1988, prior to
the public comment period for the Proposed Plan and Feasibility Study,
which was released for public comment January 29, 1988. They also met
with the U.S. EPA February 23, 1988, and have spoken with U.S. EPA
technical and legal representatives at their will. It is therefore the
conclusion of the .U.S..EPA that the FWCC was not denied due process based
on a 30 day comment period, particularly in light of their access to the
U.S. EPA. .
.
I. 0.2 Comment
.j
The FWCC claim they have been denied due process because the proposed
plan was not sufficiently detailed, thus precluding meaningful evaluation
of the Proposed Plan and preferred alternative. They state that the plan
did not outline the technical boundaries or operative rules for the
partial remediation, it did not outline cleanup levels for the work, and
there was no substantive analysis regarding the proposed alternatives..
1.0.2 Response
The partial remediation as described in the U.S. EPA FS includes
excavation of an estimated 0.8 acres, an estimated 4000 drums of waste,
and an equal volume of associated contaminated soils. The limitations
and usefulness of these estimates are discussed in the Responses to
Comments I.B., II.A., II.C. The exact location of the partial excavation
and drum removal will be determined during remedial design. The comment
regarding cleanup levels is discussed in the Response to Comment I.K.
The response to the concern about lack of sufficient detail in the.
Proposed Plan and FS is discussed in the Response to Comment I.G. The
U.S. EPA believes there is sufficient detail in the FS and Proposed Plan
to evaluate the alternatives. Additionally, the Administrative Record
for this ROD has been available to the public and the FWCC at the Forest
Township library in the Otisville, Michigan., It contains all of the
information U.S. EPA considered in evaluating the alternatives and
developing the Proposed Plan.
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29
1.0.3 Comment
The FWCC was denied due process because SARA does not require a formal
hearing regarding remedy selection.
1.0.3 Response
There was a public meeting held at the Forest Township Hall in Otisville.
Michigan. on February 17. 1988. The public and the FWCC were given an
opportunity to comment during the meeting.
I. P.
Comment
The PRPs submitted for U.S. EPA review and consideration a Feasibility
Study for the FWD site prepared for them by Geraghty and Miller Inc..
(G&M) dated December 18. 1987. Response to this document is not required
because it was not submitted during the January 29-February 27. 1988.
Public Comment Period. and it does not comment on the U.S. EPA Proposed
Plan or Feasibility Study. A response is. however. provided below due to
the misleading characterizations presented in the Geraghty and Miller
study.
I. P . Response
The G&M FS presents an array of remedial alternatives which incorporate
remediation of the onsite surface impoundme~ts. Presentation and
evaluation of such remedies serve no useful purposes at this point in
remedy selection~ The surface impoundment remedial action fur FWD was
selected in June 1986. and is now in design phase.
The G&M FS starts with an introduction in Chapter 1 and a statement of
remedial action goals and a technologies screening in Chapter 2. The
presentation of goals is confusing. Specific cleanup levels or goals for
the waste media of concern are not presented. as in Chapter 2 pages 2-3
and 2-4 of the U.S. EPA FS. A discussion and complete listing of
applicable or relevant and appropriate (ARARs) Federal and State
environmental laws is also missing from the G&M FS. Mention of the
preference for. treatment and mandate for permanent solutions to the
maximum extent practicable in CERCLA Section 121 is wholly lacking.
.
v
The technologies screening presented in the G&MFS is lacking detail and
conclusory. Cursory descriptions in Table 2 of the G&M FS do not serve
to adequately provide screening for technologies. Figures 2-3. 2-4. 3-4.
and 3-5 of the U.S EPA FS by comparison provide proper and complete
detail. The G&M FS. furthermore. arbitrarily screens partial drum
excavation without supplying the basis for the screening on effectiveness
and cost grounds. .
The alternatives array portion of the G&M FS is also confusing and
incomplete. The rationale regarding the protectiveness provided by the
arrayed alternatives is not presented. Specific remedial action goals
. -:-_-;:'i~.' ~'P~"'~--:.;' '. .'. '_":"::'::~.~"..' -~"-..:~':.. ..~';:}:~ .',~.'~ :.-::~-;;::::;.":.~T~:-:"':'~:P~~;}~'~v:::'';'!'~-:~':.7:;~~;::~~~,,:~' :._;.~:::'~.:~.~.~:~.~ ?;r{,.~:..::~.~-t::_~.,~. ..7",:'.", '-~~:~:~~\-:f'::'"~~~:'~::.';~;?~:,-::: ;:~,~).~~p';:~~~~~!; .~~~.~:.~: ~~- ~::')'>:;::""".-"~'- :'~ ." -',; :~~,; '::r.'~'
-------
30
were not presented, therefore, a comparison of goals met by alternatives
arrayed was not possible. The descriptions of alternatives are cursory,
and the effectiveness and implementability benefits and issues for each
alternative are seriously lacking detail. One of the many major
implementability issues ignored in the G&M FS are those associated with
offsite land disposal, due to RCRA Land Ban. By comparison, Chapters 4,.
5, and 6 of the U.S. EPA FS clearly explain the rationale for.
alternatives arrayed, provide complete details of alternatives
descriptions, and provide careful evaluations of alternatives relative to
evaluation criteria.
A central risk management judgement made in the G&M FS to which U.S. EPA
takes exception is the assessment that protection of the shallow
groundwater aquifer is not needed, since no existing groundwater pathways
are complete, and no probability exists for future completion (page 38 of
G&M FS). U.S. EPA believes the shallow groundwater should be provided
protection consistent with the groundwater remedial action goals on page
2-4 of the U.S. EPA FS. (See Response to Comment I.l.)
Chapter 4 of the G&M FS is lacking detail and conclusory. The risk
management judgement that the G&M FS Alternatives AA-3 is protective is
not supported in the FS. U.S. EPA, furthermore, disagrees that such an
alternative provid~s adequate protection.
.
.J
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to
The above parties have submitted comments that argue that the U.S. EPA
preferred landfill alternative,. Alternative SRCVT, is inappropriate because
it does not provide a fully protective remedy. Some parties a1so
preferred, over the U.S. EPA preferred groundwater alternative, Alternative
SR, a purge and treatment groundwater alternative, such as Alternative
~TGD, which was evaluated in the U.S. EPA Feasibility Study.
Note: The State of Michigan has requested in its formal comments that all
previous Feasibility Study and Proposed Plan comments from the MDNR and
other State agencies be incorporated into the Administrative Record for the
site. Comments submitted on final U.S. EPA documents are included in the
Administrative Record and are considered in remedy selection. To the
extent that comments on draft U.S. EPA documents are considered prior to
the finalization of the document, they have been embodied in the
Administrative Record available for public comment. Draft documents and
comments on such documents are not independently considered in final remedy
selection and, therefore, are not appropriate for inclusion in the
Administrative Record. Comments on Feasibility Study and Proposed Plan
draft documents from the State will not be included in the Administrative
Record. The full set of comments submitted by the State during the public
comment period is included in the Administrative Record and the comments
have been addressed in this Responsiv~ness Summary.
.~
.
Comments
II.A Comment
Various locations in the Public Comment Draft Feasibility Study and
Proposed Plan should be clarified to explain that Alternative SRCVT is
configured to include excavation of only 0.8 acres of the 11 acre landfill.
It should also be clarified that such an approach to site cleanup would
remove an unknown percentage of drums in the site landfill. The FS
misrepresents Alternative S~CVT.
1. Since the percentage of drums removed is unknown in Alternative SRCVT,
the long-term effectiveness provided by this alternative should be
described as unknown.
2. The Proposed Plan fails to articulate the limited and uncertain extent
of drum removal in Alternative SRCVT.
3. The Public Comment Draft FS deliberately misleads the public with
regard to protectiveness of Alternative SRCVT.
4. A bias for Alternative SRCVT is evident in the Public Comment Draft FS.
-------
6
8. Originally envisioned, Alternative SRCVT was not going to assure
complete removal of drums in the landfill.
II.C. Response
As indicated in the Response to Comment II.A. U.S. EPA recognizes the need
to collect more information about the nature of drummed waste in the
landfill. Alternative SRCVT is intended to identify, and remove' and treat
all concentrated areas of drummed waste in the landfill. Excavated
portions of the landfill in Alternative SRCVT will not necessarily be
limited to centers of high magnetic anomalies. As explained in the
response to comment II.A., the 0.8 acre area of the landfill was used in
the FS primarily as an aid to estimate the number of drums in concentrated
disposal regions. Although U.S. EPA does not have a good estimate of the
cost of the necessary waste characterization, $100,000 to $250,000 is not
an unacceptably large sum of money for this task. .
The commenter's suggestion to investigate magnetic anomalies in seven acres
of the landfill is well taken. U.S. EPA appeals to the commenter (MDNR) to
specifically identify the anomalies they are concerned about. At this
time, U.S. EPA intends to investigate those anomalies greater than 4,000
gammas from the Keck 1984 magnetometer survey and greater than 500 gammas
from the U.S. EPA 19a5 magnetometer survey, as identified in Figure 4-8 of
the RI. Data collected to date suggest that this would identify areas of
concentrated drum disposal.
.
In Alternative SRCVT, U.S. EPA does not intend, to excavate the entire
landfill, or investigate areas of the landfil'" without suggestion of
drummed waste disposal. U.S. EPA recognizes the limitations of using
magnetometer data to identify-areas of drummed waste disposal. The
magnetometer data along with other information which suggest drum disposal
regions (file information, test pit logs, air photos) will be used to
direct further investigation in remedial design to identify drum disposal
regions. It should be noted that, to date, most information gathered about
drum disposal regions coincides with magnetic anomalies from magnetometer
surveys~
Full characterization of the entire landfill will not take place in the
design of Alternative SRCVT, and because of that, removal of all drums in
the landfill cannot be assured with this alternative. U.S. EPA agrees with
the commenter that AlternativeSRCVT was not intended to assure complete
drum removal.. This alternative in the FS development process was, in fact,
in response to the commenter's (MDNR) suggestion in their review of the
draft FS. As mentioned in the Response to Comment II.A., information
collected in the RI indicated that there are concentrated areas of drums in
the landfill, thus development of a partial landfill excavation
alternative, such as Alternative SRCVT was possible.
The limitations and benefits of the slurry wall containment system are
presented in the Response to Comment II.C. U.S. EPA has.concerns about use
of the containment system to assure long term protection of public health
and the environment, without removal of concentrated drummed wastes, and
-------
7
therefore has selected Alternative SRCVT. U.S. EPA intends to adequately
define these source materials in remedial design. Bulk wastes in the
landfill, based on site file information and test pit sample analyses of
these wastes, do not appear to be of the same toxic, highly mobile nature
as the drummed waste. The wastes, therefore, are not targeted for full
characterization and excavation. These wastes will be managed with the
containment system component of Alternative SRCVT.
As explained in the Response to Comment II.A., Alternative SRCVT was
developed based on available information to aid in the remedy selection
process. Test pit data were used in the FS to develop Alternative SRCVT,
and calculate a cost estimate for it. How that information was used, and
the assumptions associated with the use of that information is presented in
the FS. The FS did not "mi suse" RI data. A more preci se vol ume estimate
of the number and types of drums in the landfill will evolve through the
remedial design and action activities in Alternative SRCVT.
ILD. Comment
The drummed wastes in the Forest Waste Disposal landfill discovered during
the RI landfill test pit investigation included a surprisingly high number
of intact drums, and a high percentage of drums with liquids in them.
1. The limited test'pit RI data indicates that approximately half of the
Forest Waste landfill drums contain liquid waste, generally solvents.
2. The statements in the FS that test"pit soi~s surrounding the drums were
found contami~ated with the same constituents present in the drums, and
that these data suggest that either past disposal practices included
dumping of unconta~nerized liquids and sludge or drum leakage has occurred,
is supported.
.
3. The statement in the FS that about one-half of the drums in the
. landfill contain liquid (page 42) is thought to be a prudent evaluation.
II. D. Response
The purpose of the test pit investigation, as emphasized in Response I.B.,
was to confirm certain historical information regarding past disposal
practices at the site, not to characterize the landfill wastes.
The' findings of the test pit investigation revealed the presence of buried
drums in the landfill, some. c.ontaining liquids. These findings, albeit not
anticipated from historical file information, were useful in developing
remedial alternatives addressing the threat to human health and the
environment from these contaminant sources.
.
The test pit findings regarding contaminated soil adjacent to the buried
drums support the removal and complete treatment of an additional volume of
associated contaminated soil along with drum removal in the SRCVT
alternative. Removal of this contaminated soil is also accomplished in the
complete removal alternative RDN, RDF, and RTD; however, c~mplete treatment
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-------
8
of this highly contaminated soil is performed only under Alternatives SRCVT
and RTD. Alternatives RDN and RDF provide for onsite or offsite
containment of this material without treatment. To generalize that half of
the burred drums in the landfill contain organic solvents is a
misinterpretation of the FS assumptions regarding the drummed materials.
The assumption that half of the drums contain liquids was necessary to
assign costs to remedial action alternatives that involve handling (drum
staging and ultimate treatment and disposal) the drums once removed from
the landfill. This ass.umption was not used as a basis for quantifying
risks associated with drummed materials at the site.
Refer to Response 1.8. for additional clarification of FS assumptions and
test pit investigation results.
II.Eo Comment
Failure to investigate and excavate readily identifiable areas of drum
concentrations in the seven acre area of the landf111 with magnetic
anomalies does not comply with Section 121 of SARA which states a
preference for treatment technologies and permanent solutions to the
maximum extent practicable.
1. The U.S. EPA landfill remedy does not go far enough. A complete
excavation of the waste in the landfill is necessary. If it is not done,
we are just inviting problems in the future.
II. E. Response
.
.~
As explained in the Response to Comment II.C. U.S. EPA intends to identify
readily identifiable areas of drum concentrations in an approximate seven
acre ~rea of the landfill with magnetic anomalies. As explained in the
Response to Comment II.C., the treatment component of Alternative SRCVT
. will provide significant and permanent treatment of toxicity, mobility, and
volume, of the wastes of concern, and therefore clearly meets the CERClA
Section 121 preference for remedies that employ treatment as a principal
el ement.
U.S. EPA does not feel that complete excavation of waste in the landfill is
necessary. Treatment of the waste of concern, coupled with secure onsite
containment of the less mobile remaining waste, provides adequate
protection of public health and the environment.
II.F. Comment
During design phase investigation, after proper landfill waste
characterization, the current estimate of 4,000 drums of waste within
concentrated drum areas may be exceeded. If that occurs, the difference in
total cost between Alternatives SRCVT and RDN dramatically decreases as the.
number of drums increases. At the conclusion of design data collection, if
~he cost of Alternative SRCVT approaches the cost of Alternative RDN, U.S.
EPA should consider implementation of Alterna~ive RDN.
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. .
9
The MONR favors selection of an alternative with at least the
protectiveness of Alternative RON as do approximately 75 community
residents. The MONR cannot concur with the current U.S. EPA recommended
landfill Alternative SRCVT.
1. U.S. EPA should commit to do additional test pitting in the suspect 6
acres to determine the absence or presence of additional drums. If
additional drums are not found, then the U.S. EPA remedy would be confirmed
as fully protective. If additional drums are encountered, then U.S. EPA
should commit to their removal from the landfill. If, as described above,
the costs of Alternative SCRVT approach the costs of Alternative RON, U.S.
EPA should consider implementation of Alternative RON. If U.S. EPA would
adopt this approach, it appears to provide a suitable compromise between
u.s. EPA and MDNR, and would assure implementation of a fully protective
remedy at this site. .
2. The comment in the FS that Alternative RON eliminates risks associated
with exposure and significantly reduces the potential for release and
migration of contaminants, since contaminated materials are removed from
their uncontrolled situation and disposed of in a more secure storage
situation, is strongly supported.
3. A constructed RCRA type facility with a leachate collection system
would likely have a high degree of longer term protection than the proposed
slurry wall.
.
II.F. Response
.j
U.S. EPA intends to do the degree of landfill waste characterization
necessary to identify concentrated areas of drummed waste disposal in the
landfill. See Response to Comment II.C.
U.S. EPA cannot necessarily support the comment that if greater than 4,000
drums of waste are found in concentrated drum disposal regions of the
landfill, the total cost difference between Alternatives SRCVT and RON
dramatically decreases. It should be noted that as greater than 4,000
drums of waste are found, the costs of both Alternatives SRCVT and RON will
increase, since both remedies assume incrneration treatment for the
identified drums, the cost of which will increase as the number of drums
increases.
A careful cost evaluation of both of these alternatives would need to be
done at the time the new information is available before the claim made by
the commenter is refuted or supported. No such careful cost evaluation was
submitted by the commenter. If, after remedial design, however, there is
. reason to believe the cost difference of these two alternatives is
dramatically less than as presented in the FS, a carefully reevaluation of
the estimated costs of these two alternatives can be done.
At this point in time, no commitment can be made to select Alternative RON
over Alternative SRCVT based on the potential cost reevaluations.
-------
10
Alternative SRCVT has been selected as the most appropriate cost-effective
alternative based on consideration of the nine evaluation criteria. New
cost information in remedial design may require a reevaluation of the cost
effectiveness finding of Alternative SRCVT, however such a reevaluation
. must consider all of the nine evaluation criteria.
u.s. EPA recognizes that Alternative RON provides significant long term
risk reduction relative to potential releases and migration of
contaminants. U.S. EPA also recognizes that a RCRA-type cell provides
greater protection than the proposed slurry wall. Given, however, the
nature of the remaining landfill wastes after the drum excavation in
Alternative SRCVT, the proposed containment system of cap and slurry wall
will provide adequate public health and environmental protection. In
addition, the waste handling issues associated with excavation and"
redisposal of all wastes in the 11 acre landfill, present significant
implementability issues associated with Alternative RON. The
implementability issues, along with the additional cost of Alternative RON,
make it less attractive for selection than the protective Alternative
SRCYT.
u.s. EPA recognizes that the State does not concur with the recommended
landfill Alternative SRCVT, and recognizes the limitations this places on
U.S. EPA's ability to use Hazardous Waste Trust Fund monies to clean up the
site, since a 10% cost share match is needed from the State before remedial
actions using Hazardous Waste Trust Funds monies can commence.
.
II .G. Comment
..1
Alternative RON and RTO are not clearly portrayed in the FS.
1. The FS fails to clarify that Alternative RON provides complete drum
removal with a known remaining risk associated with the rest of the
landfill waste which will be removed and placed in a RCRA-type cell onsite.
2. The descriptions of RON on pages 4-20 and 4-21 and RTO on pages 4-21
and 4-22 of the FS are uncl ear. What is the basi s of waste quanti ty
calculation? What will happen to the former landfill area? Is this meant
to be clean closure?
II.G. Response
The FS assumes that excavation of drums and highly contaminated associated
soil from areas identified by high magnetic readings will remove the
principal threat to public health and the environment associated with
releases from drummed liquids in the landfill. This is a component of
Alternative SRCYT. The alternative recognizes that risks do remain at the
si te but are adequately addressed by the sl urry wall, cap, and 1 ong- tenn
groundwater monitoring around the landfill.
The number of drums removed under Alternative SRCYT is based on calculated
drum densities from test pits in areas that had high magnetometer readings.
This information is summarized in Appendix F. Orum densities in areas not
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-------
2
5. Alternative SRCVT should be described to reflect accurately that only
0.8 acres of the 7 acre area of magnetic anomalies will be excavated and
that no attempt will be made to locate any additional drums or to excavate
the outer margins of the 0.8 acre area if drums are still visible.
6. The effectiveness of Alternative SRCVT has been misrepresented in the
FS because it assumes all drums will be removed from the landfill.
II .A. Response
The precise and specific definition of the landfill areas which will be
excavated in Alternative SRCVT is not yet defined. As was stated in the
Response to Comment I.B., a full characterization of the nature and volume
of landfill drummed waste was not done in the site RI. Information was
collected in the RI to aid in arraying a range of remedial alternatives,
and to aid in developing and evaluating those alternatives in an FS. The
RI and FS then are used to support and facilitate the site remedy
sel ecti on.
The information that has been developed on the site indicates that there
are concentrated areas of drummed waste disposal in the landfill. Figure
1-2 of the Endangerment Assessment, dated October 9, 1987 (performed by
Life Systems, Inc. for the PRPs) presents an interpretation of the drummed
wastes locations in the landfill, based on site records, site geophysical
surveys, test pit logs, air photos, and interviews with persons involved
with the site. This figure agrees with Figures 4-8 and 4-9 of the U.S. EPA
RI which suggest locations of concentrated areas of drummed waste disposal.
In general, the U.S. EPA RI landfill test pi t investigation confirmed a
relationship between high magnetic anomalies from magnetometer surveys at
the site, and concentrated areas of drummed waste disposal. An exception
to this relationship was test pit data from test pit No. 03, which
contained heavy metal soft drink machines and general refuse in an area of
relatively high magnetic anomaly. Information which indicates that there
are concentrated areas of landfill drummed waste disposal allowed
Alternative SRCVT to be developed. Assumptions nonetheless were needed to
develop a reasonable cost estimate for this alternative.
A critical component of the Alternative SRCVT cost estimate is the number
of drums in concentrated disposal regions. This was conservatively
estimated to be 4,000 as presented in Appendix F of the U.S. EPA FS. This
estimate of the number of drums was generated by identifying an area
(number of square feet) of the landfill with strong magnetometer readings,
and multiplying that area by the concentration of drums observed in strong
magnetic anomaly areas during the test pit investigation. The area of the
landfill with strong magnetic anomaly readings is approximately 0.8 acre.
This area is not meant to represent which, and only which, areas of the.
landfill will be addressed during Alternative SRCVT remedial design and
action. The 0.8 acre area aided in estimating the number of drums in the
landfill for a cost estimate.
.
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3
Further information will be developed in remedial design to define the
areas of concentratea-Qrummed waste disposal in the landfill. See Response
to Comment I.C. above. The 0.8 acre identified in the FS to aid in cost
estimating does not define the scope of excavation in Alternative SRCVT.
The intention of Alternative SRCVT is to completely remove concentrated
areas of drummed waste. This alternative will not, however, assure
complete removal of all drummed wastes because complete landfill excavation
will not take place, and removal of all drums from the landfill cannot be
assured unless the full landfill is excavated. The FS clarifies this in
several locations, including page 4-9 and Table 5-4. A clarification
addendum to the FS was also developed which clarifies this point. Finally,
the Proposed Plan on page 7 describes the drum excavation of Alternative
SRCVT as the excavation of areas of the landfill with concentrated drummed
waste, and further clarifies that the drum removal activity will be limited
in scope to excavation of approximately 0.8 acres of the 11 acre landfill.
(It should, however, be mentioned again that the 0.8 acre served primarily
as a means to estimate the number of drums in concentrated drums regions).
Both the FS and Proposed Plan clearly articulate the limited extent of drum
removal. The uncertainty associated with not excavating the full landfill
areas is obvious from the description of this alternative as a partial
landfill removal.
The effectiveness of Alternative SRCVT is portrayed fairly in the FS. No
FS alternatives are described in exact or quantified measures of
effectiveness and Alternative SRCVT, likewise, cannot be so described.
Table 5-4 does, however, describe how"effecttveness is gained with this
alternative, and carefully explains-that concentrated areas of drummed
materials will be removed and treated, thus gaining long term
effectiveness. This is a fair ~ortrayal and is not misleading. Although
not quantified, the long term effectiveness of this alternative is not
, unknown. .
.
.
U.S. EPA disagrees with the commenter that presentation of Alternative
SRCVT in the FS and Proposed Plan is misleading. U.S. EPA maintains that
the descriptions and evaluations of this alternative are objective and
without bias. The cornmenter claim of a biased presentation of Alternative
SRCVT is not supported wi th detail, therefore, is re'sponded to in no
greater detail.
II .B. Comment.
There are limitations to the proposed slurry wall and the use of the
existing underlying natural clay in Alternative SRCVT.
1. If free, highly mobile solvents were generated in the landfill, the
slurry wall system keyed into the underlying clay could not be relied ~n to
direct such concentrated waste liquids to a leachate collection system.
This is because the underlying clay is unengineered. The condition of the
underlying clay is unknown, however, it is most probably not a smooth,
sl opi ng cl ay surface that will di rect 1i qui ds ,to the proposed recovery
-------
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4
wells. Since many of the wastes are known to have been deposited in dug
pits, the likely configuration of the clay surface is uneven and pitted,
allowing for ponding and pooling of liquids on its surface.
2. Solvents of the type found at this site are known to penetrate clays.
Such penetration would reduce or mitigate the containment provided by the
underlying clays in U.S. EPA remedy. At the Clare, Michigan Superfund
site, similar solvents have penetrated through more than 16 feet of tight,
natural cl ays.
3. Slurry walls are not meant to contain concentrated solvent waste, but
only to manage contaminated groundwater that is essentially water-based.
Slurry walls do not effectively contain concentrated organics.
4. The proposed depth and width of the slurry wall are not adequate.
5. The statement in the FS that the cap is a vertical barrier, and that
monitoring reduces the threat of contaminant migration, but does not
eliminate it, is supported.
6. A slurry wall and cap in not reliable is preventing releases from drum
rupture. Drum releases result from corrosion of drums.
7. The long-term residual risk discussion of Alternative SRCVT on Table
5-4 of the FS shoul d read that liThe verti cal barri er wi 11 reduce and
control migration of released contamin~nts," not "protect against migration
of released contaminants". ."
.
11.8. Response
The drums containing high concentrations of organic material were found in
test pits dug in areas of high magnetometer readings in the landfill.
Under the selected remedy, Alternative SRCVT, drummed wastes in these areas
will be removed from the landfill. The remainder of the landfill will be
capped and contained using a soil-bentonite slurry wall keyed into the
underlying clay layer. Long-term monitoring of the groundwater around the
containment system is also a component of the selected remedy. Groundwater
monitoring should signal a release of contaminants to the groundwater out
side the containment system in the event of component failure.
The design of the alternative components as presented in the report is
adequate for consideration as a remedial action alternative in an FS.
Design details, such as those requested in the comment will be addressed
during the remedial design. The slurry wall's extraction system will be
designed to maintain a negative head within the slurry wall to keep any
contaminant releases away from the wall. Placement of the extraction wells
within the containment system will consider the irregularities in the clay
surface to minimize ponding and pooling of liquids on its surface. Special
admixtures may be considered for. use in the slurry wall design that promote
fiocculation and swelling of the bentonite mixture, reducing the
permeability of the wall in the presence of aqueous organics. The
components of Alternative SRCVT reduce the risks associat~d with wastes in
-------
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~.. ~'.~ , .
..,,,-~. .-< ..........- '-J ._",,-.-. - ~~.
5
the landfill by removal of a principal threat (drummed materials in areas
of high magnetometer readings), secure containment of remaining wastes,
(cap, slurry wall extraction system) and long-term groundwater monitoring
around the entire engineered system.
II. C. Comment
Additional waste characterization should be done to locate and quantify the
drummed bulk waste in the landfill to complete a proper design of the
landfill remedy. As currently presented, the Proposed Plan calls for
excavation of only 0.8 acres of an 11 acre landfill. This estimate is
based on a remedial investigation (RI) waste characterization designed only
to collect qualitative information on the nature of drummed and bulk wastes
in the landfill.
1. The lack of additional waste characterization in the landfill might
allow concentrated wastes to be missed. Any remaining concentrated wastes
would have a high likelihood of penetrating the vertical wall barrier.
Adequate source removal is imperative.
2. The estimated cost of the additional waste characterization is
approximately $100,000-$250,000 or approximately one percent or less of the
total cost of Alternative SRCVT.
3. U.S. EPA does not wish to characterize at a relatively low cost, the
remaining portions of the seven acres of magnetic anomalies to determine
where drum concentrations are located.' ."
.
4. The statement in the FS, uThe intent of the (landfill pit)
investigation was not tolFully establish the nature and extent of
contamination..." is fully supported.
5. Magnetometer - gradiometer data have limitations in identifying
locations of drums. They identify ferro-magnetic objects, which mayor may
not. be drums. The lack of a significant magnetometer anomaly does not
necessarily indicate that quantities of drums are not present. The drums
in a small magnetic anomaly may be more deeply buried than drums in a large
magnetic anomaly since depth of burial is a significant factor in the size
~f an anomaly. Drums, furthermore, may even be of non-ferrous materials.
U.S. EPA plans to excavate the centers of high magnetic anomalies as the
complete drum removal in Alternative SRCVT.
6. The FS used RI landfill test pit waste characterization data to cost
out a removal option and therefore misused information gained from the
landfill test pit data. The test pits were not intended to provide volume
estimates of the number and types of drums in the landfill.
7. Based on information collected in the RI, it is likely that up to seven
acres of the eleven acre landfill contain high concentrations of drummed
waste.
-------
11
investigated in the form of test pits are not known but are assumed to be
"much lower than those in areas of high magnetometer anomalies. Alternative
RDN would remove all waste materials from the landfill including all drums
encountered during excavation. Since areas outside of those with high
magnetometer readings will be excavated, additional drums may be
encountered, although the number of additional drums is assumed to be small
and not have a significant impact on the cost of the alternative.
The additional risk reduction from implementing this alternative instead of
SRCVT is a result of removal of all contaminated materials from their
uncontrolled situation and either treatment (in the case of drummed
materials) or secure containment in an onsite RCRA-type landfill.
The waste volume estimate assumptions for Alternatives RD and RTD are
presented in Appendix F. (This appendix summarizes all available
information regarding waste types and volumes at the site in the form of
interviews, phone calls, file records, and documents from the U.S. EPA and
MDNR). After excavation, the former landfill will either be filled in with
clean fill material, graded, and revegetated or will be used to facilitate
an onsite RCRA-type landfill.
A clean closure remedial action returns a site to near original conditions,
such that constituent residuals are no longer a threat to public health and
the environment. . The only Forest Waste alternative that could be
considered "clean closure" is the RDF alternative with offsite disposal
(Alternative RDF, presented in Chapter 5).
.
II.H. Comment
.~
The contaminated groundwater at this site should be characterized as waste,
not hazardous waste on page 4-9, -bullet" 2 of the FS. There is nothing to
indicate that the contaminated groundwater is a RCRA hazardous waste.
JI. H. Response
U.S. EPA agrees with this comment.
The contaminated groundwater at Forest Waste contains low levels of
hazardous substances. Since the source of this contamination (the onsite
lagoon waste) is not a documented RCRA listed waste, and the contaminated
groundwater does not display any RCRA characteristics, and the contaminated
groundwater is not waste product from a Superfund site, the groundwater
should not be characterized as a hazardous waste. Page 4-9 of the FS,
which describes the groundwater as a hazardous waste is not correct. . A
licensed hazardous waste hauler would not have to transport this
groundwater if it were transported offsite.
11.1 Comment
Comment on long-term operations and maintenance (O&M).
. -.:,~,-,~""'''!"""~'--~!::'''''''''.~'';:- .,' .~ -:..~ ;i-'
-------
12' .
1. Who is responsible for long term maintenance of any 1and~i11 remedy
into perpetuity?
2.
Who pays for 5-year reviews?
3. What is the definition of the long-term maintenance cost (page 5-1 of
the FS)?
4.
The O&M costs of Alternatives SRCV and SRCVT in the FS are very low.
5. The present-worth cost analysis distorts the true cost of long-term O&M
for Alternatives SRCV and SRCVT, which the State would have to pay.
6.
Periodic replacement and repair of the sl urry wall will be needed.
7. The annual 0&" cost estimate and present worth of O&M for groundwater
A1 ternative SR do not accuratel y ref1 ect the "True Cost" of groundwater
monitoring. The monitoring for the groundwater in Alternative SR would be
for an indefinite period of time.
II. I. Response
As recognized by the commenter, the State of Michigan is responsible for
long-term operations and maintenance (O&M) of the landfill if no
responsible party assumes this responsibility. If, under a consent
agreement, or unilateral enforcement action, responsible parties conduct
the O&M actions, then the State of Michigan will not need to do them. In a
similar fashion, the State or responsible parties conduct and pay for the
five year reviews.
.
-
Long term maintenance costs cited on page 5-1 of the FS refer to the costs
of maintaining the waste management system over time once it is
constructed. In Alternative SRCVT, for example, that would include
maintenance of the cap and slurry wall and operation of the dewatering
system and monitoring system.
The commenter charges that the O&M costs presented in the FS for
Alternatives SRCV and SRCVT are low and distort the two costs. Per U.S.
EPA guidance, costs for all remedies were calculated over a 30 year period,
using a present worth analysis with a 10 percent discount rate and no cost
adjustments for inflation. (See page 1-2 of the FS). Such present worth
analysis allows for cost comparison of all alternatives with varying
degrees of O&M. O&M costs for greater than 30 years are recognized, but
not calculated in FS analyses. The O&M costs for Alternatives SRCV and
SRCVT were calculated in this fashion, accounting for long term costs of
the cap, landfill dewatering collection system and water treatment, and
groundwater monitoring. Repair and replacement of the slurry wall was not
calculated because it should not be needed within 30 years. U.S. EP~
recognizes the limitations of this present worth cost analysis, but
believes it is useful and applies it in all Superfund FS cost analyses.
"", :.::: '.,.' -."';'.~ -r;::-..~~"."-;.- --.-:"" ~;; " .:."'-":'<''!..-;:o.'"''",",,:P';'.''''''''' «:". '," ". ,....... '-~.D~-1.' --:."'-; --;"':""".-..r>.'.~' "~-'~:' .p;'\.-.-:-:,-.-:"-;- ~-,., -'...'
-------
\
13
The costs for groundwater Alternative SR were calculated per U.S. EPA
guidance as described above. While the length of time for this monitoring
is currently unknown, it will not be endless. Since the source of this
groundwater contamination will be completely removed in the lagoon operable
unit cleanup~ the levels of contamination in the groundwater will
eventually drop to a point where monitoring is no longer needed.
II.J. Comment
The analysis to consider the potential for future remedial action costs in
the case of remedial action failure was not done on the FS. This analysis
is required by CERCLA Section 121(b).
II.J. Response
The requirement in CERCLA 121(b)(1)(f) is that, as alternatives are
assessed in the remedy selection process, consideration be given to "the
potential for future remedial action costs if the remedial action in
question were to fail". The potential for future costs is discussed in the
FS in the implementability, technical feasibility, reliability discussion
on Table 5-5. The less reliable an alternative is in performing.over time,
the higher the potential for future remedial action costs. This
reliability discussion is more fully developed in the ROD. ihis evaluation
does not require that specific cost estimates be developed as "future
remedial costs". Such costs estimates would require so many assumptions
that they would serve no useful purpose.
.
II.K. Comment
The MDNR cannot concur with the U.S. EPA recommended groundwater
Alternative SR. Ronald Willson and the Michigan Department of Public
. Health also do not support the U.S. EPA recommended groundwater
al ternative.
1. Groundwater quali.ty on the Forest Waste Di sposal si te has been
adversely affected and cannot be fully utilized in its currently degraded
condition.
2. Recent data collected by MDNR show that the MCL for trichloroethene was
again exceeded (beyond the one time in the RI field work) with a value of
5.5 ug/l from a well at the eastern site boundary. Since these data
indicate that the remedial action goals have been exceeded at the site
boundary, a plan for further groundwater remedial action should be
developed as described in the Proposed Plan. The MDNR data were collected
subsequent to the start of the comment period on the FS and Proposed Plan.
3. The new data also exceed MCLGs and proposed MCLGs. An excess cancer
risk of 10-6 was also exceeded. .
4. The U.S. EPA recommended groundwater Alternative SR would allow further
degradation of groundwater downgradient of the contaminated plume, and
eventually discharge contamination to surface water. This concept of cross
.' -;:;-~-'-.'.: '.:-' ...":<.. 7 :"~.::'v':;:';-~'.~.-;.~: :-~":."~~'~: :.-:;" ';. '. ~.::.;.~¥. .~, \~ '.\ ",. '. ';:.7_~-,~s--::~r :'':',.~'~:';-~::::~ :'~~"'~'-- '''', ':- '~'.~ '. :."'.:~.... :~~'--~.:.-'" ..":--::'::' ~ ~:;:, :<',~".>"..-;:
... - .r: -..,..,:.....,-: ,:<,~~:;",~.:.:.-., ~., ".-;,"'
", .. . . ,',f'",'. ,..t' " -. ..
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\
14
media transfer is contrary to MDNR efforts to remediate sites where
contaminated groundwater vent to other media. This violates Part 22 of
Michigan's Water Resources Commission Act which prohibits degradation of
State groundwater because by not performing groundwater cleanup, further
degradation of groundwater downgradient of the contaminant plume will
occur.
5. The Michigan Department of Public Health (MDPH) commented that
supplying Maximum Contaminant Levels (MCLs) in groundwater contamination
situations is a new approach by U.S. EPA, and expressed some concerns about
this approach. The MCLs have been developed to describe clean water with
regard to a single contaminant, not to describe when waste water or
contaminated water with potentially several contaminants present might be
safe to drink.
The MDPH is concerned with applying MCLs to' drinking water from domestic
wells. The policy of MDPH is that the presence of environmental
contaminants in domestic wells in unacceptable. Presence of contaminants
in water wells would result in the MDPH issuing health advisories to those
affected areas.
6. MDNR prefers Alternative CTGD for the groundwater.
7. The FS does not indicate (page 4-14) that the groundwater Alternative
SR does not meet the remediation goals. Specifically, a Maximum
Concentration Level (MCL) is exceeded in a drinking water aquifer and the
Part 22 nondegradation policy of Act 245 (Water Resources Commission Act)
is not canpli ed wi th..
II .K. Response
.
U.S. EPA recognizes the MDNR reservations about selection of Alternative SR
for the groundwater. However, U.S. EPA, maintains that Alterna~ive SR is a
cost-effective alternative that provides adequate public health and
environmental protection. The Agency agrees that onsite shallow
groundwater should not be used as a drinking water source. U.S. EPA,
recogniz~s that an RI data point indicates trichloroethene exceeded the MCL
onsite. The de~d restrictions component of this remedy will prevent onsite
groundwater use as drinking water, thus providing adequate protection and
assuring compliance with the Safe Drinking Water Act ARAR.
The monitoring component, and trigger for further action, will assure that
unacceptable levels of contaminants will not migrate offsite.
The specific remedial action goals for groundwater at the site are stated
on page 2-4 of the FS. U.S. EPA has not limited the goals to attainment of
MCLs in the groundwater but has included other health advisories, the. 10-4
to 10-7 cancer risk range, and goals for surface water protection in light
of Ambient Water Quality Criteria. U.S. EPA, recognizing the MDPH comment
that MCLs have been developed to describe cl~an water with regard to a
single contaminant, has included other health advisories and the cancer
risk range as cleanup goals. It should be noted that thjs groundwater
.', :~:"". :::.~ i,~" 'r::~."":' .":1;~::~:~'''':::~,.'.:~~':''):::'~:'.':-~;;-:~';~'.~':~j;;.;~::'::::":":> ~:''''''.~-.-:~.';r:.;,{::'';~-::.}\'~<::iF:':.'::;i';~~;:~~?..-:~f~:7f.~"., '~'~'~\'~7~~."'-'~:~:'\F.:;"~ :.~~ :~.: ;::t:.-"':,r;:.~~}:f'. ~-~:.~~~~.~ :,~/~~:;=,. :..~-':.: ........~~'.. "'>,""'-: :;: ,.' <-.-:': ~'.~': " "';.'" ~<,'..'..
-------
15
cleanup Alternative SR is for "a drinking water aquifer that could be, but
is not currently, used as a drinking water supply source. This alternative
is not for application to current use domestic wells. The domestic wells
in the area have been shown, via modelling, to be well protected against
migration of site contaminants.
MCLGs and the Part 22 of Michigan Water Resources Commissions Act (Act 245)
non-degradation policy are not groundwater cleanup goals at the site. As
is current U.S. EPA policy, MCLs, as opposed to MCLGs, are generally the
relevant and appropriate standard for Superfund groundwater cleanups (See
letter to Honorable James J. Florio from Lee M. Thomas, Administrator of
U.S. EPA, May 21, 1987). Act 245 is not an ARAR for groundwater. See
Response to Comment II.M.4.
The new data submitted by the State has been reviewed and considered. A
complete package of the data analysis, including quality control/quality
assurance information was not, however, provided. Several compounds were
i denti fi ed on the data summary as "Compound i denti ty not confi rmed by
second independent techniquell, including the offsite detection of 1,1,
dichloroethane. The quality of these data is not known and is
questionable.
Assuming nonetheless, that the data is accurate, it does not provide
information that groundwater Alternative SR is not protective or does not
meet ARARs. .
.
The cost and implementability factors of Alternative CTGD make it a less
attractive alternative for selection than Alternative SR. .
11.L. Comment
There are concerns about contaminated groundwater discharging to the
surface waters east of the site.
1. The recent MDNR sampling detected low level organics in offsite wells
located directly in the wetland east of the site, which drains into.
Butternut Creek.
2. The recent data indicate that groundwater is moving faster than
previously thought.
3. Additional monitoring wells downgradient of detected offsite
contamination must be installed to adequately monitor the groundwater and
assure that surface water Ambient Water Quality Criteria are not being
exceeded.
4. The data which indicate that low level organics have been detected in
offsite wells located directly in the wetlands suggest the modelling on
contaminant flow to surface water (done in the FS) is incorrect. This
modelling suggested offsite surface water bodies will not be adversely
affected by migration of groundwater contaminants. Surface water has
already been adversely affected by migration of onsite groundwater.
-------
16
II.l. Response
The MDNR groundwater data submitted to the U.S. EPA on February 26, 1988,
have not been reviewed for quality control methods used during sampling and
analysis. Such quality control information has not been submitted to U.S.
EPA by MDNR. Without this review the validity of the data is questionable.
Assuming the data are acceptable for use in evaluating groundwater quality,
the organic concentrations detected in the offsite monitoring well (2.0
ug/l cis-l,2-dichloroethene and 1.8 ug/l l,l-dichloroethane) are well below
the MClG (70 ug/l) for cis-l,2-dichloroethene and calculated health
advisory concentration (4200 ug/l, based on reference dose) for
l,l,dicloroethane. The concentrations detected in the onsite wells were
generally below those detected in the wells during the RI sampling efforts
for which a full risk assessment had been performed.
The current placement of offsite monitoring wells for use in the long-term
monitoring program is adequate to monitor site groundwater migrating to the
east. The monitoring performed in the selected remedy will be used to
evaluate changes in groundwater quality resulting from migrating
contaminants. Monitoring requires that if such significant changes occur,
additional remedial action on the groundwater will be evaluated.
The U.S. EPA realizes the crudeness of ' the groundwater model used and
presented in Appendix C-3. The purpose of the model was to estimate the
concentrations of certain chemical constitu~~ts in the groundwater
discharging to the wetlands and to compare these estimated concentrations
to Federal and State limits. This information was used by U.S. EPA to help
evaluate the groundwater alternatives in the FS. The limitations and
assumptions of the model are clearly presented in the Appendix C-3
discussion.
.
II.M. Comments on Applicable or Relevant and Appropriate Regulations
(ARARS)
II.M.l. Comment
It is speculative that landfill Alternatives NA, SR, and SRC comply with
the Safe Drinking Water Act (SDWA).
II.M.l. Response
Currently the groundwater, including shallow aquifer groundwater, has not
been impacted by landfill contaminants. Currently, therefore, groundwater
quality around.the landfill is less than SDWA Maximum Contaminant levels
(MCls). In landfill Alternative NA, long-term compliance with the SDWA
would not be known, because potential future releases of landfill wastes to
the groundwater would not be identified. In landfill Alternatives SR and
SRC, however, potential future releases of landfill waste to the
groundwater could be identified via the monitoring component of these.
alternatives. Once such releases are identified a plan to remediate such
releases would be evaluated to assure compliance with the SDWA. In this
sense, landfill Alternatives SR and SRC c-omply with the SD~A.
-------
\
17
ILM.2. Corrment
Landfill Alternatives NA, SR, and SRC would not comply with Michigan Act
641 of 1978 as amended (Michigan Solid Waste Management Act).
n .M.2
Response
Michigan Act 641 of 1978 was designed to regulate and manage solid waste,
not hazardous waste regulated by other statutes. This Act is less
stringent than RCRA, which is an ARAR, and therefore is not an ARAR at
this site. U.S. EPA agrees that these alternatives do not comply with
RCRA.
n .M.3. Corrment
Landfill Alternatives NA, SR, and SRC would not be in compliance with the
Part 22 Groundwater Rules of Act 245 of 1929, because with these
alternatives, groundwater would undoubtedly be impacted and degraded,
contrary to these rules.
II.M.3. Response
Part 22 Groundwater Rules of Act 245 is not an ARAR at this site. Part 22
prohibits degradation of Michigan's water quality. Part 22 defines
degradation as any change above background which is determined by the Water
Resources Conmiss;on to be a deterioration of groundwater quality. The
purpose of Part 22 is to prevent discharges into the groundwater.- U.S. EPA
is not discharging into the groundwater of Michigan, it.is proposing a
cleanup action. Hence, these rules are not applicable to the groundwater
cl eanup acti on.
.
Part 22 is not relevant and appropriate to establishing cleanup levels at
the site. There are no promulgated regulations that serve as cleanup
standards within the Act or the Rules. Also, the objectives of these rules
is to prevent a deterioration of groundwater through degradation. Part 22
provides for nondegradation of groundwater quality in usable aquifers,
defines the requirements for hydrogeological study before permitting a
discharge into groundwater, establishes groundwater monitoring requirements
for new and existing groundwater discharge and establishes a procedure for
obtaining variances from these rules. The objectives of these rules, which
are to define and limit discharges into groundwater, vary significantly
from the objectives of the remedial activity proposed by U.S.EPA at this
site, which are to control an existing hazardous waste site, and are
therefore. not relevant and appropriate. For further discussion of this
issue see Kelley v Chemcentral/Grand Rapids, No. 80-30139-CE State 01
Michigan. Circuit Court of Kent County. (May 3, 1984).
. -' ~ '.',0' r.,"',..,. :'It..CI:",'...;;.,." .';"1': ::;".;<"" ::":-..", ;""01'. ':";.~T.":":""';~. -.-::-- ;"', .:-';"";'~7"'~,;~~:","1.":~>:';'~ :.;-':".,.;M..;Z'.~' ~: ...:...~ :'~<-:;,.,~;":":-,~,:'",,:: '. ':.. :...-: '.
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-------
'\
18
II.M.4. Coment
In landfill Alternatives SRCV and SRCVT, the Federal RCRA Land Ban
Restrictions prohibiting placement of regulated liquids in an landfill
would be IIrelevant and appropriate". These alternatives do not comply with
the Federal RCRA Land Band ARAR.
II .M.4 Response
Landfill Alternatives SRCV and SRCVT comply with the Federal Land Ban. The
Land Ban prohibits the land disposal of regulated liquid wastes in
landfills. It is designed to preclude the placement of liquid waste in
landfills after November 1986. Alternative SRCV does not require placement
of liquid wastes in a landfill. Alternative SRCVT includes the excavation
'of wastes, thermal destruction of all excavated waste, and proper disposal
of the waste residue. No liquid waste will be land disposed with either
Alternative SRCV or SRCVT, so they both comply with the Land Ban.
II .M.5. Comment
In landfill Alternatives SRCV and SRCVT, the in place waste containment
component of these remedies would not provide for a do~ble lined system for
placement of hazardous waste. Use of a double liner in these alternatives
is relevant and appropriate under Michigan's Hazardous Waste Management
Act, and RCRA. Si nce these al ternaUves do not provi de for a doubl e 1 i ner,
they do not comply with the Michigan Hazardous Waste Management Act (Act 64
of 1979). .
.
II.M.5. Response
Landfill Alternatives SRCV and SRCVT outline in-place closure of the
landfill. RCRA is relevant and appropriate for both these alternatives.
RCRA does not require the use of the double-lined system for placement of
hazardous waste when final closure is implemented. See 40 CFR Section
_264.310. Michigan Act 64 adopts by reference 40 CFR Section 264 Subpart N
~~~~~u~~~~r~~t~~~sS~~~~0~n~6~R~~~) r:~u7~~h~f~u~:m~~~s~~~~ ~ ~~~p~;~O~~j).
they meet the requirements of both RCRA and Act 64.
II.M.6. Coment
Groundwater Alternatives NA and SR do not comply with the State of Michigan
Surface Water Quality Guideline Levels for Protection of Aquat)c Life and
the Federal Ambient Water Quality Criteria for the Protection of Freshwater
Aquatic life ARARs, since contaminant transport modelling indicates levels
of cyanide 500 feet from the site (in the nearest surface water body)
exceed these guidelines.
.~-.- -"':' " > ~':'~.:.'~'; ,~,-; :: ..~: ::~. ;,~.tW; .:r;....~~,::,~'.'. ;, ._'.:':':~::: :.: "'7-~:-~~;,:~: '.
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19
II.M.6. Response
U.S EPA believes that, to date", no information indicates that release of
site contaminants in excess of Federal Ambient Water Quality Criteria or
State of Michigan Surface Water Quality Guideline Levels for protection of
Aquatic Life have migrated to the nearest surface water body. Groundwater
contaminant transport modelling, presented in Appendix C, Page C-4 of the
U.S. EPA FS, furthermore, indicates that current concentrations of onsite
groundwater contaminants should not exceed the Federal AWQC or State of
Michigan Guidelines as they discharge to the nearest surface water body.
When the maximum current onsite groundwater, contaminant concentration for
cyanide is used in this modelling, the modelling indicates standards for
cyanide may be exceeded in the nearest surface water body. However, when
the mean concentration detected in cyanide analyses are used in the
modelling, the modelling indicates standards for cyanide will not be
exceeded. U.S. EPA believes that the contaminant modelling using mean
contaminant concentrations is a better method to predict discharge
contaminant concentrations to the nearest surface water body. U.S. EPA,
therefore, believes that over time the ARARs for regulation of the nearby
surface water quality will be met with groundwater Alternative SR.
More importantly, however, groundwater Alternative SR is configured so that
if the predictive modelling was not accurate and the monitoring program
indicates surface water standards will be exceeded as groundwater
discharges to the nearest surface water body,.4 plan for further
groundwater remedial action will be evaluated. Federal AWQC and State
Surface Water Guidelines will be complied with in groundwater Alternative
SR. Since monitoring data is not collected-in Alternative NA, compliance
with surface water ARARs will be unknown.
.
II .M. 7.' COlTlTlent
Groundwater Alternatives NA and SR do not comply with the Safe Drinking
Water Act because the MCL for trichloroethane has been exceeded onsite.
II.M.7. Response
Currently offsite there are no releases of contaminants to the groundwater
in excess of SDWA MCLs. RI data has indicated that only one sample of
groundwater from onsite has concentrations that exceed SDWA MCLs. Although
data collected by MDNR subsequent to the ~I indicates another sample of
onsite groundwater exceeds SDWA MCLs, the quality of this data is unknown.
(See Response to Comment II.K.)
The onsite groundwater will not be used as a drinking water source. The
deed restrictions component of Alternative SR will prevent this from .
happening. The groundwater monitoring .component of Alternative SR will,
furthermore, identify if offsite releases of groundwater contaminants in
excess of SDWA MCLs will occur. If such releases offsite are likely to
occur, a plan for further groundwater remedial action will be evaluated.
Alternative SR assures that groundwater with contaminant concentration in
excess of MCLs will not be used as. a drinking water source, and therefore
L'-....'~.~:I-~"'~.""'-""': ... ,.-:-~~,:-..",,,,,:..-.....,..~_"":....-_._,.,,,. '.';'"."
... 7>: . -:<~'r~ ,-"- ~-::?:'" - :t.',""~'''-'', - ',' _\'.~.' . . o. ~.. -;. ~\'. ",'''' ~.:.!'.I".. ."~'~:'u;~:-; '7'-:
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20
complies with the SDWA. Alternative NA makes no such assurances, and
therefore does not comply with the SDWA.
II.M.B. Comment
Groundwater Alternatives NA and SR do not comply with the Michigan Water
Resources Commission Act (Act 245 of 1929) because uncontrolled continued
migration of groundwater contamination would allow impact of previously
uncontaminated groundwaters to the State, degrading the groundwater.
Part 22 of this Act provides for nondegradation of groundwater quality in
usable aquifers.
II.M.B. Response
Part 22 of Act 245 of 1929 is not an ARAR at this site. See discussion at
response to Comment II.M.3.
II.M.9. Comment
If a release from the remaining landfill wastes to the environment occurs
after the partial drum removal in Alternative SRCVT is performed,
Alternative SRCVT would not comply with the Part 22 Groundwater Rules of
Act 245 of 1929 as amended (Water Resources Commission Act). These rules
prohibit the degradation of the State's groundwater.
II.M.9. Response
.
. .
Part 22 of Act 245 of 1929 is not an ARAR at this site. See discussion at
response to Comment II.M.3.
II. N. Comment
Comment on the deed restrictions of groundwater Alternative SR.
1. The deed restrictions component of groundwater Alternative SR should
include restrictions for installing a drinking water well in any aquifer in
the restricted area, not just the shallow aquifer. This will prevent
cross contamination from the shallow aquifer to deeper aquifers during
drill 1n9.
2. The deed restrictions must extend to onsite and affected offsite areas
from shallow aquifer contamination.
3. Deed restrictions require the cooperation of affected property owners,
not just the local government.
II.N. Response
The comment made that deed restrictions in groundwater Alternative SR
should include restrictions to install drinking water wells in any aquifer
in the restricted area, not just the shallow aquifer, is valid. The
comment will be incorporated into the selected remedy. .
"~:::;:J;~:~ ::~, :. ~-';'-::'~;'~,~ "~::~:'~:f:;.-~'~~~~~~.~~~~.:::. ~;:?::~.:.:~.-: "~".::':"~?-:;?:;.;~t:.~;.~::.~ ~.?~:~~.. ~:;:~-;~,~,'::'~.'~'-::~:'..:-:~';~.T:~: ~~....: '~7. .~:'-~ ":-""~ :~. - .~'~ :~. "~'''f:-~ .:
'--:"-," '. -.-.~...-:-..:-:. 7'_.-' _::"."',r:- ,-:
.- :"",- ., '''''-~1~..~ -,.- ~'.'_. 'I'...'.
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21
The deed restrictions component of groundwater Alternative SR is most vital
to the onsite areas. If remedial action goals are exceeded at the onsite
boundary, a plan for further groundwater action will be evaluated. The
onsite deed restrictions component will be easily enforced because the
State of Michigan owns the site property, and can be depended upon to
assure enforcement by the deed restrictions. Cooperation of the onsite
local property owners should also be easily gained.
The deed restrictions component of groundwater Alternative SR does extend
to adjacent site areas (see page 4-23 of FS), although such component of
the remedy is not as important as the onsite deed restrictions component
because the remedy is configured so that these offsite areas will not
become contaminated. This component of the alternative is precautionary
and not vital for protection of human health and the environment. U.S. EPA
recognizes that cooperation of adjacent property owners will be needed and
anticipates their cooperation.
11.0 Comment
The fourth paragraph of Part IV, Scope of the Feasibility Study, on page 4
of the Proposed Plan' states that the shallow aquifer east of the landfill
is contaminated. While this is true, the contaminated groundwater is
immediately east of the lagoons. The lagoons are the suspected source of
groundwater contamination.
.
.J
11.0. Response
The referenced statement (Proposed Plan, page 4, part IV, fourth paragraph,
risk sentence) should read, "The shallow aquifer east of the lagoons
appears to have been affected by site contaminants". The RI data indicate
and the FS maintains that the source of this contamination is from the
lagoons on the east half of the site.
II.P. Comment
1. Assuming the modelling in the FS is correct, no domestic water supply
wells will be adversely affected by the movement of the groundwater
contaminant plume. However, in c~se the modelling is erroneous or the
plume does not behave as expected, an option should be included in the
final remedy to provide alternative drinking water supplies, should the
need arise.
2. The FS Report does not include any provision for periodic sampling of
domestic water wells near the Forest Waste Disposal site. If the site.
monitoring shou1d indicate a release of contaminants, it is requested that
the MDPH Groundwater Quality Control Section staff be notified promptly.
II.P. Response
The selected groundwater Alternative SR is configured SUCB that if the
contaminant plume does not behave as expected, and the quality of offsite
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22
groundwater will exceed the groundwater remedial actions goals, a remedial
action plan to clean up the groundwater will be evaluated. If at any time
there is suspicion that domestic water supply wells may be adversely
affected by movement of the groundwater contaminant plume, alternative
drinking water supplies will be seriously considered as part of a future
remedial action plan. The MDPH Groundwater Quality Control Section staff
will be promptly noti fi ed if groundwater contami nati on above the remedial
action goals is detected offsite.
!!,:",Q. C ommen t
Air Issues:
1. During removal of drums in the Alternative SRCVT, ambient air
monitoring for VOCs will be required.
2. If an onsite RCRA landfill is constructed, ambient air monitoring for
VOCs will also be required during disposal of waste in an onsite landfill.
3. In the cases of an onsite RCRA landfill or a slurry wall, TSP
monitoring and dust control measures will be required. VOC monitoring of
the landfill vent.s will be required after they have been installed.
4. Dust suppression may be needed for Farrand Road if heavy vehicle
traffic is expected. .j
.
5. In executing cleanup activities at the site, there must be compliance
with Rule 901 of Act 348 eState of Michigan).
6. MDNR requests a review of the cleanup work plan to determine the
adequacy of the air monitoring program and control measures. A plan must
provide for immediate data on total VOCs and a separate portion to
determine the levels of specific compounds at the property line.
7. Given the isolation of the site, TSP Monitoring using high volume
samplers is not necessary. Monitoring using a portable, instantaneous
readout instrument will be acceptable.
8. The u.s. EPA selected alternative for the groundwater will likely not
have any significant impact on air quality.
9. It may be necessary to provide treatment of any gas collected in a
landfill gas collection system.
.!l.:9. Response
Ambient air monitoring and air quality monitoring will be performed during
all remedial actions to evaluate exposure risk to workers and nearby
offsite residents. Air monitoring of any onsite treatment or disposal
facilities will b~ performed as routine operation and maintenance of that
facility. Compliance with all Federal and State air q~ality laws is
': ~...: ..""". '. .,..-...~..;-:-.-,s...,...-.-~.: 1~" ;:r.--.:' .""', ".;--. . ".t;"" ''':i'.;.~:," ::~ :~-'.;;, ;' .,'{
; :':':.:;:-~~'7":":r-~::-'/!"'."~" C;":::".;:':"'':''~~'i'.''71''':'''-'":.:V:'';':''''.' ";":.';""''V..~;~n.?::'.' >;:"'~_:.'"7.'''.:'''' "J".',.~~:;"~'~':'T.'."~:..-".".!,:,~'.~r. .:" ~ ,':.~ ''''''"ow -;~" .-." - '.".~':....'~,\' ~.~ ",' . .... .
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23
recognized as an ARAR for the site as shown in Tables 5-7 and 6-4 and as
discussed in the Forest Waste ROO. Comments 8 and 9 are recognized. As
appropriate, MoNR will be offered the opportunity to review the cleanup
work plan.
II .R. Comment
Property Compensation:
1. Groundwater Alternative SR is going to require the affected property
owners be compensated for deed restrictions and long-term use monitoring
wells on their property.
2. Groundwater Alternatives CTGo and CTP will require compensation of
affected property owners for use of their property to operate the
groundwater collection and treatment systems necessary.
II .R. Response
It is the U.S. EPAIs position that restrictions and/or activities designed
to protect human health or the environment are valid exercises of its
authority and do not constitute a taking.
II . T. Comment
MoNR commented that there were a number of substantial differences between
the Agency Review Draft of the FS and the Public Comment FS, and that such
changes require a reevaluation of the various alternatives, and more than a
cursory review of the document.
.
1. What new information prompted the change in the number of estimated
drums in the Agency Review Draft from 1000 drums to 4000 drums in the
Public Comment Draft FS?
2. Between Agency Review Draft and Public Comment Draft, the soil and
landfill contents quantity changed from 247,000 to 208,000 cubic yards.
Between drafts, the cost of treatment and disposal of bulk solids, bulk
solids with PCBs, and drummed solids dropped from $30,000,000 to
$12,800,000.
II.T. Response
Changes to the Agency Review Draft FS were made in response to comments
made by the U.S. EPA and MDNR during the review period and because of
further evaluation of existing data and information about the site.
.
No unew" information was obtained regarding the number of drums in the
landfill. It has been reported in the file (Task Technical Memorandum No.
3 - Technical Memorandum of Magnetometer Survey, October 28, 1985) that
1,000-3,000 drums were disposed of in the landfill. The 1,000 number was
used in the draft FS report. The revised number (4,000) ,was calculated
using actual field data from the test pit investigation and magnetometer
. - - .-- - '-_4U- -- -- - - .-- - .-.'--0- ~ ,-- ..,-. "." ,.. ..C'<' -,..~ "~..,,.....--,,.... 'n:-.,-:--- ~:. :,- . --. '" - ""-:::"''''-'''.~';'\'':--~:'.:-':;'''''''''.-:::~~-''''''---.'=''':~ .., "::"'.-;-:- :~':C:"?'-"':'.:-.~:;-"'iy"~;:":,,'-"',~":.;~::,~1.~'}:-'::-:~.::_'.;.;:'.-"~ ":'''f,; 1"~"';,'~:;:'~'~~~;:~:"''::::F...jc:::
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24
surveys. Because the drum quantity became a larger issue during the review
period, closer examination of this number was warranted. Likewise,
revisions to the volume of bulk wastes in the landfill were made after
closer examination of the site information regarding disposal areas and
depths gathered during the field efforts.
The discrepancy noted in Comment II.T. refers to the present worth order-
of-magnitude cost for RCRA disposal of bulk solids from the landfill
reported as $30,000,000 in the Agency Review Draft FS and $12,800,000 in
the Public Comment FS report. A calculation error was discovered during
the review period which prompted the revised cost.
II. U. Comment
Comments on longer-term residual risk of landfill Alternatives SR and SRC:
1. The long-term future risk potential in landfill Alternative SR is not
reduced by groundwater monitoring as stated in Table 5-4 of the FS. Risk
reduction would only occur if additional remedial measures were implemented
as a result of groundwater monitoring.
2. Why does Table 5-4 of the FS state that "Risk due to future potential
releases in the landfill are not reduced" in Alternative SRC, but II Future
risk potential is reduced through grou.ndwater monitoring" in Alternati-ve
SR? Alternative SR is less protective than Alternative SRC.
.
3. Landfill Alternatives SR and SRC should not be described as providing
any future risk reduction to groundwater through contaminant leaching on
Table 5-4 of the FS.
II.U. Response
To clarify statements made in Table 5-4 regarding the long-term residual
risk associated with landfill Alternatives SR and SRC:
The potential for future releases of contaminants in the landfill and
migration to groundwater is the same for both Alternatives SR and SRC since
there is no remedial action on the landfill that prevents releases.
However, future risks to public health with future use scenarios from
releases are reduced through groundwater monitoring in both alternatives.
The statement made regarding future risks to groundwater through
contaminant leaching is correct and recognized in this response.
Installation of a groundwater monitoring program requires that future
remedial action will be evaluated if such a release is detected by the
monitoring.
II. V. Comment
The cost of Alternative SRCVT in the FS ($22,530,000) is incorrect. This
cost is based on an estimate for the number of drums in the landfill which
is based on incomplete information.
~:~ -:1': :~:.~ .--.:;..,:~~.~. ::t: ';".:."~. :,:~: ~~:"f:~':-:~~;;:::"~:,:' :::i,' ::. :~';.': "~::;:.:-' -~ -::~".:' -.;,.:--~~~!".;..~.~:::)." :->-:'~'., '-; .,::,~ . ..-;.':. ;"":c",:'-,;;;':-.}:"V':;'.: ':;: '7~~.
-::~:.: ':<: '" ...~:.... ~'L~':':" '.;~.t )-",':~;':'. .,'.:.:' '.~ : ""'~' ":.,' : . .~. --':-;-',- .'.:t'~ . ,_:,'~'11- .~-: ::"-'~ :'-,r":
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25
1. The U.S. EPA contractor CH2M Hill developed a cost range for various
areas of drum removal up to 7 acres. This range of cost was $22,530,000 -
$28,467,000.
2. The range of costs developed for the different sizes of. landfill
acreage to be excavated must be explained so that the public can adequately
evaluate Alternative SRCVT.
II.V. Response
The number of drums used as a basis for the Alternative SRCVT cost estimate
uses all available information regarding reported number of drums disposed
of at the site, areas of concentrated drums disposal based on the
magnetometer surveys, and drum densities determined from the RI test pit
investigation. The degree of confidence in this estimate is sufficient for
use as a basis for an FS cost estimate.
The order-of-magnitude cost in present-worth dollars of Alternative SRCVT
is S22,530,000. This estimate is accurate within +50% to -3~ of this cost
and is based on the assumption made from available information at the time
of the FS. Therefore, the range of costs for this Alternative is
$15,771,000 to $33,795,000. The range presented in Comment II.V.
($22,530,000 to $28,467,000) is a misinterpretation of a draft cost figure
generated by U.S. EPAls contractor, submitted to U.S. EPA and MDNR on
1-20-88. The figure was intended to illustrate the cost relationships
between alternatives SRCV, SRCVT; and RDN. 1he cost figure shows that as
larger areas of the landfill are excavated, beyond the areas of highly
concentrated drum disposal, the cost of Alternative SRCVT quickly
approaches that of the complete removal Alternative RON. The only
interpretation that should be made from this draft figure is that if
si gni fi cantl y 1 arger areas of the 1 andfi 11 requi re excavati on and drum
removal based on more complete and detailed information generated during
the remedial design at the site, the cost effectiveness of the SRCVT
alternative should be reevaluated.
.
II . W. Comment
Appendix E, -Detailed Cost Estimate", is confusing. It is unclear from
this Appendix how the costs for/each individuai alternative were developed.
1. Are the costs for materials excavation in the options presented in
Table 5-3 constant?
II.W. Response
Several of the remedial technologies presented in this FS are used in.more
than one alternative. For this reason, Appendix E detailed cost tables are'
organized by remedial technology rather than by alternative. The advantage
of this is in having the reader evaluate the costs for a technology once on
one specific table, instead of on each alternative cost table on which it'
would appear. As explained on pages 5-10 and 6-2, costs for an alternative
are obtained by adding the specific .cost of the individual technologies
'--"",. -: . """'-:-;~~7~~~""'-.-'" :;'. ,;:', .~ ~'~. ;-:,r -:'.~~~:-:T~'.~~:;'~'::':~': :';~~.:;.:'.:. ~':--~'~:.?:~~-.~."'. '::".;.:.;:--. :-~~.:~::_:::-:,~:~;:'~ ..:~. _:: ;;:-:~:~7~:~::~-.:. P ," '.'-:' - '.'~'-.: :':i;' ::-",..' .:~ :~.".-:... ,'':OJ.
: ~~[_J'>:'- "',,- -. ''''.~ --:.:
;., ',--- -.."~" --"-".~
..' ,..: ,I ~..'-
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26
appropriate to the alternative. The components or technologies used in
each alternative are listed for each alternative on Table 5-6 (soil and
landfill contents) and 6-3 (groundwater). .
The treatment and disposal costs for the soil and-landfill contents
presented in Table 5-3 are based on complete removal of all landfill
wastes. Therefore, excavation costs are constant for each option
($12,693,000, see Appendix E detailed cost table).
II .X. Conment
MDNR and Ron Willson conment that they believe U.S. EPA has not complied
with the spirit or content of CERCLA Section 121(f) concerning State
involvement. MDNR believes they have not had meaningful involvement in
selection of remedial actions to be undertaken in their State. They
believe they were not afforded a reasonable opportunity to conment on the
Feasibility Study.
1. The State had no opportunity to provide conments on the Public Review
Draft FS prior to U.S. EPA's development of their Proposed Plan, because
they received the Proposed Plan prior to receipt of the Public Comment
Draft FS. .
2. A decision by U.S. EPA to propose Alternative SRCVT was made before
the Public Comment Draft FS was finished and current cost information was
available. When cost information was available, it was not objectively
evaluated using criteria of effectiveness, implementaMlity, and cost.
"The costs which are used do not match the effectiveness claimed by this
document." (page 6 of January 28, 1988 memo from Kathy Shirey to Brian
Monroe) . .
II .X. Response
.
U.S. EPA strongly disagrees with the MDNR and Ron Willson comment that the
State of Michigan has not had meaningful involvement in selection of
remedial actions to be undertaken at Forest Waste, and that the State was
not afforded a reasonable opportunity to comment on the Feasibility Study.
The sChedule for the FS was developed in conjunction with MDNR
representatives, and agreed upon by both U.S. EPA and MDNR in spring 1987.
This schedule included FS milestone deliverables, Agency review periods for
deliverables, and interim meeting dates. The schedule was successfully
executed and included intense and frequent involvement with MDNR
representatives. A summary of the formal milestone involvement POiRts
follows. Weekly/daily telephone communication between the State and U.S.
EPA took place during the entire FS development period. .
The State was afforded the opportunity to review and comment on a techno-
logies screening, remedial action goals, and rough ARARs FS deliverable in
late May 1987. On May 29, 1987, these deliverables were discussed in a
meeting with MDNR, U.S. EPA, and U.S. EPA consultant repr.esentatives. The
State's comments were incorporated to their satisfaction.
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27
The State was afforded the opportunity to review and comment on an
alternatives development FS deliverable in mid-September 1987. This
deliverable and potential State ARARs were discussed in a meeting with
MDNR, U.S. EPA, and U.S. EPA consultant personnel on September 23, 1987.
The State comments were incorporated to their satisfaction.
An official request for ARARs identification for the current assembled
alternatives at Forest Waste was ~ent to the State on October 5, 1987. A-
respons~ to this request was received within approximately 30 days, and
incorporated into the FS.
The Agency review draft of the FS, December 2, 1987, was sent to the State
for comment and review. Comments were received in early January 1988 and
incorporated into the Public Comment Draft FS. A final meeting to discuss
these comments was held with MDNR, U.S. EPA, and U.S. EPA consultant
personnel in January 5, 1987. At this meeting potential remedy selection
options were discussed in depth. U.S. EPA made clear what their preferred
alternative was at that time.
Concurrent with the Public Comment Draft FS, MDNR was provided a copy of
the draft Proposed Plan for the site on January 20, 1988. On January 21,
1988, a letter was- received from the State strongly opposing the
recommended alternatives for selection in the Proposed Plan. Intense
discussions between U.S. EPA and MDNR persisted for several days. -
Invnedi atel y pri or to the rel ease of the Proposed Pl an was the fi rst
communication that the State made to u.S. EPA claiming a lack of meaningful
involvement. On January 29, 1988, the Proposed Plan was released for
public comment, incorporating to the extent possible the State comments and
identifying the State concerns. The Proposed Plan recommendations were
carefully considered by U.S. EPA using the final information about all
alternatives developed in the FS, including final cost information, prior
to its rel ease.
.
u.S. EPA feels that they made every effort to involve the State in the FS
development and remedy selection process and that these efforts were
successful. While we recognize and regret that the State does not support
our selected remedy, this fact does not constitute a denial of State
involvement in these processes.
II.Y. Comment
Editorial Remarks
1. The last sentence on page 1-8 of the FS, "Observations during the
landfill investigation suggest that localized perched water zones exist in
the landfill area", should add at its end, "rather than a continuous:
uni form groundwater mound".
2. The FS should clarify on page 1-12, first sentence, that some nearby
residential wells are in the drift aquifers.
"..- - !'~::':.-~~.i; .""- .->\". . -~ -"~'~'-' .:~ ''''," "::-'7'[~'~_",~-r:'".'t:-....,,:/;~;' ."'-7';~'~~:';~:':-;.-~".~'i":;-';;""!- "'.:: ::......t;. ". ",' ~J:;':",--:'7?",-,,:-,-.-;..,~;...t:-:.:'e .-:;....:- . ';"\;':"".~;,. 7'O;-,~ ~:~:;, r~:1"~' .;--~ ;-"-::,:' "-'--::"':-' :1. -""-:.:;: - ...~. ~. : ~ " ;:.~,:~;;...,,,,~,:":: ~-~.:: '.:::' ~,,,.:::;, ";, ..'~.;,:::: . - .; ~ ',. '...
-------
28
3. The FS should clarify on page 4-12 that while a cap and slurry wall
reduces contaminant mobility, such a reduction does not come through
treatment of the hazardous waste but rather through containment.
4."GAC.. should not be abbreviated in the FS.
5.
U12 mgU should be spelled out in the FS.
II.Y. Response
Y.I. The editorial comment is correct and recognized.
Y.2. Complete information regarding well screen depths for all area
drinking water wells was not available at the time of the report.
Therefore, the possibility exists that some residential drinking water
wells near the site are screened in the upper sand and gravel aquifer,
referred to as the "shallow aquifer".
Y.3. The editorial comment is correct and recognized.
Y.4. The definition of GAC is given on page 4-7. This abbreviation is
well known and acceptable for use in referring to "granular activated
carbon" systems. The abbreviation is used to condense the otherwise
wordi er-text.
.
..
Y.5. The second sentence on page 4-7 should read, "The plume volume of 12
million gallons 'CMG) h estimated based...".
. ILZ. Comment
Bulk wastes containing dioxin at Forest Waste may not be accepted by some
RCRA facilities, even though dioxin concentrations in this waste is so low,
disposal of the waste' is not banned by law. This is an imp1ementability
issue for any alternative where land disposal of this waste is considered.
II .Z. Response
ihis potential imp1ementabi1ity issue for the low level dioxin contaminated
wastes in the landfill was not identified in the FS. This issue has been
considered by U.S. EPA in remedy selection for the landfill and is
recognized in the ROD. This issue makes the landfill Alternative RDF, the
only alternative that would provide for offsite disposal of this waste,
less attractive for selection. Alternative RDF is not the selected
landfill remedial action.
II .AA. Comment
In groundwater Alternative CTGD, it may be necessary to provide additional
treatment for the metals in the GAC system proposed for groundwater
treatment before water is discharged to Butternut Creek. .
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29
II .AA. Response
This stipulation regarding additional unit processes in treating the site
groundwater to the required quality (NPDES limits) prior to discharge is
clearly made in the onsite groundwater treatment summary discussion on page
3-19 and is re-emphasized in the detailed description of Alternative CTGD
on page 4-24.
II.BB. Comment
Groundwater Alternative SR should include a shallow well upgradient of the
lagoons in the monitoring program (See Figure 4-9 of FS).
II .BB. Response
The comment to include a shallow well upgradient of the lagoons in the
monitoring program for groundwater Alternative SR is recognized. It is
assumed that a well in the location is desired to establish background
conditions in the shallow aquifer during the monitoring program, since an
explanation is not provided in the comment. Long-term groundwater
monitoring programs for each groundwater alternative (SR, CTGD, and CTP)
will include a suitable existing upgradient monitoring well, or a new
shallow upgradient well will be installed for.Jthis purpose.
II .CC. Comment
.
Figure C-4 and page C-3-4 should clarify that the pictured drinking water
receptor is r.ot a well that exists now, but rather a possible future well.
II .CC. Response
v
At the time of the FS, information regarding well screen depths was not
available for all area drinking water wells. The Genesee County Health
Department provided well screen depth information for some area wells for
use during the RI (See figure 3-6, Forest Waste RI). Figure 3-4 and Page
C-3-4 identify the nearest resident whose well, if screened in the upper
sand and gravel aquifer, could be in the path of a migrating contaminant
pl urne. ..
II . DD. Comment
Comments on modelling in Appendix C:"
1. The input values for modelling reflected in Tables C-6 and C-7 should
be provided, as well as the source of that input data.
2. The parameter pH needs to be" modelled in Appendix C to determine its
value as contaminated groundwater discharges to the nearest surface water
body. .
. ..:_!':
:' '. . ~';_:':"-'~'::-. .-'~: """, ~-;:-::'....- :;~'..~-" - ~ :-:':-' :~~-..r;.~": ~t., .:: :"'"0.:: ?:.~;:;,.~-:. ::":':~ ~~;,:::~~.~. : :~~., ;..'.;-:;":',;.':7.~?:~;:f\:.: ;':';:."~'.~;"~J" ~:',~,-:'~'.~..'~':~~ :.~,.-~:~:~..;;-;: 'I: '. ' ;:-,>:",:~:.~:;:'T'.-;'~~'. "~~:":"::'~~:<-.-;. ~~;'.~:...:~; "':':'..-~"~'''',:,' .r.;.... ..- .:~ '"; . :";,
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30
II . DD . Re s po n s e
The twelve wells used to establish maximum and mean input values for the no
action. alternative groundwater modelling are shown in Figure C-5, as
described on page C-3-4 of the FS. The maximum and calculated mean values
from these wells for each constituent are presented in the second column of
Tables C-6 and C-7, respectively.
The groundwater modelling presented in Appendix C-3 estimates the
concentration of groundwater constituents at the nearest surface water
discharge point (wetlands east of the site) using the set of input
concentrations from 12 wells assumed to be in the migrating plume. The
model is based on simple deletion of unreactive constituents in water and
assumes one dimensional flow and complete mix conditions at the point of
discharge. Use of this model to estimate pH in the discharge would be
impossible from a practical standpoint due to the highly reactive nature of
the hydrogen ion in the presence of other cations and anions in the
groundwater and in the soil through which it migrates.
Maximum and mean pH values that correspond to the input data used in the
modelling are 10.6 and 7.8, respectively. The mean value is well within
the acceptable pH range for the protection of aquatic life, 6.5 - 9.0
(Ambient Water Quality Criteria Goldbook, based on Quality Criteria for
Water Redbook, 1976). The maximum value was measured in MW84-2,
approximately 700 feet from the wetland. Gr.oundwater pH is expected to be
lowered into the neutral range as at migrates and is buffered through
reactions wHh natural soil constituents. Monitoring groundwater for the
changes in pH is a component of the se1 ected remedy.
.
Groundwater pH from the four offsite wells (MW86-2, 86-3, 86-4 and 86-5)
was also measured during the sampling efforts and their pH values are 7.4,
7.2, 7.6, and 8.2 respectively. These values are all within the neutral pH
range discussed above.
The selected groundwater remedy provides for monitoring the groundwater at
the offsite and onsite location to detect changes in the chemical
concentrations as well as pH. If significant changes in the quality of the
water are found through monitoring remediation reevaluated.
II. EE. Comment
Permits Issues
1. If an alternative is .chosen which would involve discharge to Butternut
Creek, an Inland Lake and Streams Permit (1972 PA 346, as amended) will be
necessary for construction activity below the ordinary high water mark of
the watercourse.
2. Any alterations or occupation of the floodplain of Butternut Creek
requires review and permitting under the Floodplain Regulatory Authority
(1929 PA 245, as amended by PA 347, as amended) from the local soil erosion
" ":',., -:7-,:"'J' 7'~~"~""~'':: '~'~~-r~'."":::--':"":-~~.: '-:; .:~ ~.~..!:-
. . ...:' '\;. ~~' .':' , . .'::"/., ?:'7:~' ,'':"-':.y.~'.~ ~.":~:: ~ <. ~ .. '.> :-~ :,,:" ;:"""..:.:',' : ".' :-.:, ~;:-.'f;'.,,';,!~;::'.- .~ ::.:,-;, 7::,"'..::~:~:;"~~'~'~! ; ';":..: r:':.').\, :::.;:: ::;-; '."':' ..' :p.:""-=:~'~-';~: :-..~,~;~';'::~'~~-":: ::.' :..~' ';..;',~;.-t.....-...;...:~:"
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31
control office. A permit for any earth changes within 500 feet of a
waterbody one acre in size or larger will be necessary for several of the
alternatives discussed in the FS.
3. A permit under the Soil Erosion and Sedimentation Control Act (1972 PA
347, as amended) from the local soil erosion control office for any earth
changes within 500 feet of a waterbody of one acre in size or larger will
be necessary for several of the alternatives discussed in the FS.
II. EE. Response
Section 121 (e) of CERCLA states that no Federal, State or local permit is
required for the portion of a Superfund remedial action (RA) conducted
entirely onsite. U.S. EPA will, however, assure that all substantive
technical requirements of a permit will be met for onsite actions. The
exemption for a permit does not extend to portions of an RA conducted
offsite.
If the selected remedy included a discharge to Butternut Creek, or
alterations or occupation of the floodplain of Butternut Creek, the above
cited permit(s) (1 and 2) would be obtained. If future groundwater
remedial action or treatment for the landfill dewatering system wnl
require such activities near Butternut Creek, appropriate permit(s) will be
obtained. -
.
The selected landfill Alternative SRCVT will require earth changes of one
acre or. larger in size. Such earth changes will be conducted onsite and
only the substantive technical requirements of the permit in the Soil
Erosion and Sedimentation Control Act, will be followed. Similarly, other
alternatives in the FS with earth changes greater than one acre would be
conducted entirely onsite, and only the substantive technical requirements
of the permit would be followed. No other alternative is,' however,
selected for implementation.
II.FF. Comment
POTW Issues
v
The proposed discharge of purged groundwater to the Cfty of Flint POTW
would be regulated under their Industrial Pretreatment Program. The City
of Flint (POTW) superintendent should be contacted early in the planning
stages for any proposed discharge to their treatment facility.
1. The POTW presently incinerates sludge but is considering a land
application program. The effects of the site groundwater on that p~ogram
should be evaluated.
2. The treatment facility has a primary treatment retention basin that
discharges periodically during wet weather.. This must be taken into
account for any proposed trucking of groundwater to the POTW.
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32
II.FF. Response
These implementability issues regarding the use of a POTW are recognized.
Alternative CTP is not, however, the selected groundwater alternative. If
use of a POTW is anticipated for treatment of water from the landfill
dewatering system, the suggested coordination will be followed.
II. GG. COllll1ent
The lagoon liquids and solids should be removed now. After that is done,
U.S. EPA will need to study the site again to determine what to do on the
rest of the site.
II.GG. Response
The lagoon liquids and solids are scheduled for removal this construction
season as the earlier selected (June 30, 1986) lagoon operable unit remedy.
The remaining operable units of concern at the site, the landfill and
contaminated groundwater to the east, have been carefully studied as
sUllll1arized in the RI report. Removal of the lagoon liquids and solids will
have no effect on the condition of the site landfill. Selection of
Alternative SRCVT for the landfill based on current information, therefore,
is appropriate. The lagoon cleanup will prevent any further contribution
to the groundwater contamination on the east~end of the site, but will have
no effect on the current degree of that groundwater contami.nation. U.S.
EPA was fully ~ware of the effects of the removal of the source of
groundwater contamination when it selected groundwater Alternative SR.
Selection of the groundwater alternative at this time, therefore, is also
appropri ate.
.
II.HH. COllll1ent
A fence should be put around monitoring well QW-3S. This well is
contaminated and, when it is sampled, contaminated groundwater is brought
up to the surface and people can corne in contact with it. People may get
sick. A fence around the Borges property is also needed since the wetlands
on this property is contaminated. .
II .HH. Response
The fence surrounding the Forest Waste site was constructed to discourage
trespassers from entering the site and coming into direct contact with
hazardous substances on the surface of the site (lagoon wastes, landfill
surface soil and waste). Direct contact with these substances present an
unacceptable public health threat. The area surrounding monitoring well
QW-3S and. the wetlands to the east do not present this unacceptable public
health threat, therefore, do not need to be fenced. When well OW-3S is
sampled the water will be collected and brought onsite for proper
discharge.
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33
II. II. Comment
The cost difference between Alternatives SRCV and SRCVT is $13 million.
The cost difference between Alternatives SRCVT and RON is $7 million. The
cost difference between Alternatives RON and ROF is $30 million. If there
is a goal for cost effectiveness, these comparisons should be evaluated.
II.II. Response
u.s. EPA recognizes the relative cost differences between the three
alternatives. Selection of a cost effective remedy, however, depends on
more than just absolute differences in cost. It is also depends on
evaluation of costs as they relate to relative effectiveness of
alternatives. Remedy selection furthermore, is based on an evaluation of
the effectiveness, implementability, and cost considerations. As
documented in the ROD, Alternative SRCVT is a cost effective remedy which
best balances the nine evaluation criteria.
II.JJ. Comment
u.s. EPA and MONR should immediately negotiate and reach a common
understanding as to what remedy should be implemented at the site.
results should be reported to the community.
The government officials involved in this project should work together.
The government offici~ls are not honest, cooperative, or reasonable.
The
.
-
II.JJ. Response
U.S. EPA has been working closely with MONR to resolve the issues
associated with the landfill and groundwater remedy selections. U.S. EPA
has included an official response to the State's concerns in this
Responsiveness Summary. Many of the State's concerns have been
acknowledged, and a commitment to address those concerns has been made.
v
u.S. EPA stands ready to address numerous State concerns with landfill
Alternative SRCVT, and is ready to fully fund the design and fund 90% of
the remedial action costs for this remedy. U.S. EPA is also ready to
negotiate with the State for a more expensive alternative than SRCVT
wherein U.S. EPA will contribute 90% of the costs of the components of that
remedy which are similar to Alternative SRCVT, and the State will pay the
full costs of additional measures the State desires. Even under that cost
share scenario, the State is very likely to contribute far less money to
the landfill cleanup than U.S. EPA.
The differences in the groundwater alternatives supported by each of the
Agencies are somewhat more difficult to resolve. U.S. EPA is however,
continuing discussions with the State. Some fundamental differences
between U.S. EPA and MONR on the Forest Waste site remedy selection do
exist, due to some fundamental differences in the Agenci~s' approaches to
waste management. All individua1.s involved in the project are, however,
.' ~~'.- ::.:~'":.-.. ';'.~"':.:"..~".~'
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,
.,
34
working hard with the utmost cooperation and reasonableness to try to reach
a resolution.
u.s. EPA assures that their cOl111lunications with the State, the public, and
all others involved in the Forest Waste project have been fully honest.
I I.KK. COlll11ent
Michigan State Congressional Representative Na~e Yonkers wants to know what
needs to be done to get the Forest Waste Project moving more quickly than
it has in the past.
A community resident suggested U.S. EPA seek help for speeding up site
cleanup fram Nate Yonkers.
II.KK. Response
u.S. EPA recognizes the concerns of the local citizens and Representative
Yonkers in gaining expeditious cleanup of the Forest Waste Site. u.S. EPA
shares that concern. .
It must be kept in mind that the Superfund program is dealing with a
nation-wide problem of hazardous waste which has been created over decades
of time. Over 900 sites have been identified on the Superfund National
Priorities List (NPL) as priority sites for.remedial cleanup action in the
U.S. Many of those sites have not even initiated the study phase (RI)
which began at Forest Waste in 1984. Forest Waste, in fact, has received
early attention for action under the Superfund Program. The early fencing
action helps discourage trespassers and helps prevent human contact with
wastes on the site surface. The lagoon cleanup, currently in design phase,
will provide a major remedial cleanup at the site. Currently the site
presents no pUblic health or environmental risks to the surrounding
community if individuals do not enter the site.
Forest Waste will continue to receive priority action for cleanup. We are
not, however, optimistic that the pace of progress will quicken and have no
suggestions for "help from Representative Yonkers that would quicken that
pace for Forest Waste cleanups within the Superfund program. Site cleanup
action is currently progressing as fast as possible within the constraints
of the program. .
.
'J
II . LL. Comment
Residential Well Issues
.
1. All residential drinking water wells should be tested more than once a
year.
2. All residential drinking water wells less than 100 feet in depth,
should be replaced by U.S. EPA. U.S. EPA has spent a lot of money on
monitoring wells. It is the commun~ty's money. .
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35
II.LL. Response
It is clear from the Forest Waste RI/FS that contaminants from the site
have not reached, and will not reach, surrounding residential wells any
time in the near future. A thorough groundwater monitoring scheme is,
furthermore, part of the Forest Waste selected remedy to assure that
surrounding wells will remain unaffected by site contaminants. The
selected remedies for the site provide protection to residential wells from
the current and future releases of site contaminants. Therefore, at this
time. U.S. EPA does not believe there is any need to or justification for
replacing residential drinking water wells.
Visiting of residential wells can be done by the Genessee County Health
Department. The commenter's concern about sampling has been forwarded to
them.
II .MM. Comment
Farrand Road should be paved at the expense of PRPs. Spills may happen
when site cleanup is underway and it will be difficult to clean up on a
gravel road. .
.
. -
II .MM. Response
Responsible parties under the Superfund law are not responsible for the
road conditions near Superfund NPL sites. If during necessary offsite
transport of hazardous wastes from the Forest Waste site, spills occur on
Farrand Road, proper cleanup of the spill will be done by the transporter.
Although spills may be difficult to clean up on a gravel road such as
Farrand, they can be done properly. Hazardous waste transporters,
futhermore. are require~ by regulation to take precautions to reduce the
likelihood of spills.
()
:.;
II . NN. Comment
Approximately eight families around the site should be relocated.
cost less money than cleaning up the site.
It would
II.NN. Response
A buyout and relocation of the approximately eight families around the
site without any other action would provide minimal long-term protection to
public health and the environment from the Forest Waste Site. This ~ction
would provide no active waste management, and would do practically nothing
towards meeting the site remedial action goals stated on page 2-3 and 2-4
of the U.S. EPA FS. This action would not be cost effective or protective
and is not acceptable for selection.
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. '.~ '~,7~,:: ::' :.~;t.~:,~~~~::.~~~{[Zr::~ ~~7~,~ \:.-:::~':.;~~
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36
II .00. Comment
Contaminated water is migrating onto the Borges property to the east, into
the pond on the property, then into Butternut Creek, then into Mott Lake,
then into Lake Huron. At least three more wells on the northeast side of
the Borges property are needed.
II .00. Response
The extent of contamination in the shallow aquifer has been adequately
identified through the groundwater sampling efforts performed during the
RI. Evaluation of the site hydrogeology indicates that the shallow
groundwater migrates and discharges to the wetlands east of the site.
However, surface water drainage patterns indicate that these wetlands are
also fed by wetlands and drainage areas that are north and northeast of the
site. Sampling and analysis of surface water east of the site did not
reveal any patterns of contamination.
Chemical constituent concentrations in fourteen monitoring wells (twelve
are east and southeast of the lagoons) will continue to be monitored in the
selected remedy. U.S. EPA believes this number is adequate to provide
information regarding changes in groundwate~.quality as the plume migrates
offsite to the east.
.
II .PP. Comment
Taxes should not be charged on the Borges property.
II.PP. Response
Issues concerning local property taxes should discussed with the local
taxing body. . U.S. EPA has no authority regarding property taxes.
II. Q9. COlmlent
Tracking devices such as radioactive or colored dyes should be used to
track groundwater flow.
~. Response
Introducing radioactive agents into a drinking water aquifer would present
unnecessary risk to human health and the environment. Tracking groundwater
flow with dye requires long-term (in excess of 15 years) data collection
which would delay the implementation of a remedy at the site. The site
hYdrogeology has been adequately characterized from RI data.
II .RR. Comment
During cleanup will residents be relocated?
If so, how long will it be?
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'-
37
Will residents be compensated for the inconvenience? Who will guard
property during relocation?
II .RR. Response
Relocation of residents is not anticipated during Forest Waste remedy
implementation. If it is needed, these issues will be discussed and
resolved.
II .SS. Cooment
This contamination is a very grave problem.
11.55. Response
u.s. EPA recognizes the risk from the Forest Waste site (Chapter 6 of the
RI) and has selected landfill Alternative 5RCVT and groundwater Alternative
5R to effectively manage these risks.
II.TT. Comment and Response
A letter dated January 21, 1988, from Gary E. Guenther, Chief,
Environmental Response Division, MDNR to Basil u. Constantelos, Chief,
Waste Management Division, U.S. EPA, was submitted during Public Comment
Period. The March 1, 1988, letter from Mr. Constantelos responding to the
January 21, 1988, correspondence from Mr. Guenther will serve as a response
to this cOlll11ent.
.
lJ
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., . . ..
III. Comments from the U.S. Department of the Interior - Fish and Wildlife
Services (Fwsl
The FWS concurs with the U.S. EPA recommended landfill Alternative SRCVT, and
with the recommended groundwater Alternative SR.
II I. A. Comment
U.S. EPA should assure appropriate measures will be taken to protect biotic
resources of surface waters if the groundwater Alterative SR monitoring shows
contaminated water is discharging to surface water bodies.
III. A. Response
U.S. EPA.recognizes the support of the FWS.
Groundwater Alternative SR is configured such that if unanticipated offsite
migration of contaminants is detected, which would exceed Ambient Water
Quality Criteria if released to the wetlands east of the site, a plan for
groundwater remedial action will be evaluated.
I II. B. Comment
The Endangered Species Act of 1973, as amended, requires that federal agencies
obtain from FWS information concerning any species, listed, or proposed to be
listed, which may be present in the area of a proposed action. The FWS
checked their files and there are no species present in the project area that
are federally listed,.or proposed to be federally listed, as endangered or
threa tened. . .-
.
III. B. Response
u.S. EPA recognizes the above information provided by the FWS.
l,
iJ
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-------
ADMINISTRATIVE RECORD
GUIDANCE DOCUMENTS USED
o
Title
-
Letter to Honorable J. F1 orio
Interim Guidance on
Compliance with Applicable
or Relevant and Appropriate
Requirements
Hazardous Waste Management
System Land Disposal Restrictions
Final Rule 40 CFR Part 260 et seq.
Ambient Water Quality Criteria
for Pol ynucl ear Aromatic Hydro-
carbons. Office of Water
Regulations and Standards, Criteria
and Standards Division.
EPA 440/5-80-069
Federal Register Part V, National
Oil and Hazardous Substances
Contingency Plan
National Priorities List. . 876
Current and Proposed Sites In
Order of Ranking and By State
Guidance on Feasibility Studies
Hazardous Waste Engineering
Research Laboratory, Cincinnati,
Ohio
i./
Memorandum: RCRA Region V Policy
on Groundwater Restoration at
Solid Wast~ Management Units
Record of Decision: Spiegelberg
Landfill, Livingston County,
Michigan
Record of Decision: Metamora
Landfill, Metamora, Michigan
Resource Conservation and Recovery
Act 40 CFR Part 260 et ~
Chemical. Physical and Biological
Properties of Compounds Present
Author
Lee Thomas
J.W. Porter
u.S. EPA
u.S. EPA
U.S. EPA
.J
u.s. EPA
U.S. EPA
B. Constantelos
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
Date
5[21/87
7/9/87
11/7 /87
Oct. 1980
Jul y 16, 1983
.
Oct. 1984
April 1985
June 16, 1987
Sept. 1986
Sept. 1986
9/85
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: ."T."'~'. '.::-.?'''' .::
-------
. . .
Ti t 1 e
Endangerment Assessment Handbook
at Hazardous Waste Sites
Guidance on S/F Selection of Remedy
Additional Interim Guidance for 187
RODs
Guidance on Feasibility Studies
Under CERCLA
Comprehensive Environmental
Response, Compensation and
Li abil i ty Act
Community Relations Guidance for
Evaluating Citizens Concerns
at Superfund Sites
CERCLA Compliance with Other
Environmental Statutes
User1s Guide to the Contract
Laboratory Program
Delegation of Remedy Selection to
Regions (Under Delegation #14-5)
Superfund Public Health
Evaluation Manual
Procedures for Planning and
Impl ementi n9 Off-site Response
Actions
participation of Potentially
Responsible Parties in Develop-
ment of Rls and FSs
Guidance on Feasibility Studies
Under CERCLA
Gui dance on Remedi al Investi gations
Under CERCLA
Remedial Action Costing Procedures
Manual
- 2 ~
Author
U.S. EPA
J.W. Porter
J.W. Porter
U.S. EPA
Executive Order
12316
U.S. EPA
(OSWER 9230.0-04)
U.S. EPA
(OSWER 9234.0-02)
U.S. EPA
(OSWER 9240.0-01)
., .
U.S. EPA
(OSWER 9260.1-09)
U.S. EPA
(OSWER 9285.4-01)
U.S. EPA
(OSWER 9330.2-01)
U.S. EPA
(OSWER 9340.0-01)
U.S. EPA
(OSWER 9355.0-056)
U.S. EPA
(OSWER 9355.0-068)
U.S. EPA
(OSWER 9355.0-10)
Date
8/85
12/24/86
7/24/87
4/85
1980
10/17/83
10/2/85
10/1/84
.
3/21/86
11/7/86
5/6/85
3/20/84
6/1/85
6/1/85
9/1/85
'- -"; ,II "...~~~'-:.."': ""'.-"~!":~.', 'J~--::':'':''',-~:;' :"".",,"~'~;~' ~'t."_"-\7 ~-";..' ""P~~""'~':"':'':''',7. ':'; ;'~""- ':.~-'::-" "~.;"; ;"".''':- .""''';
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.' ... .
- 3 -
Ti t 1 e Author Date
t.
Interim Guidance on .Superfund U.S. EPA 12/24/86
Section of Remedy (OSWER 9355.0-79)
Remedial Action at Waste Disposal U.S. EPA 10'/1/84
Sites Handbook (Revised) (OSWER 9380.0-04)
Procedures for Identifying U.S. EPA 2/1/82
Responsible Parties: Uncontrolled (OSWER 9834.3)
Hazardous Wastes - Superfund
Policy on Enforcing Information U.S. EPA 9/10/84
Requests in Hazardous Waste Cases (OSWER 9834.4)
Participation of Potentially U.S. EPA 3/20/84
Responsible Parties in Develop- (OSWER 9835.1)
ment of Remedi al Investigation
and Feasibility Studies
General Toxicology Handbook U.S. EPA 9/20/85
(OSWER 9850.2)
Discharge of Wastewater from U.S. EPA 4/15/86 .
CERCLA Sites into POTWs
.j
Covers for Uncontrolled U.S. EPA 9/1/85
Hazardous waste Sites
Handbook for Stabilization/Soli- U.S. EPA 6/1/86
dification of Hazardous Waste
Administrative Records for U.S. EPA 5/29/87
Decisions on...CERCLA
Response Actions
Mobile Treatment Technologies U.S. EPA 9/1/86
for Superfund Wastes
U.S. EPA Groundwater U.S. EPA 8/1984
Protection Strategy
Other guuidances used are cited within the Administrative Record
documents.
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