Unit!1d States
Environmental Protection
. Agency. ..
Office 01 .
Emergency and .
Remedial -Response ..
EPAIROD/ROS-89/110
September 1989
(;
Ift~PA
'.8
Superfund . ..
.. Record of Decision:
. . .
. .
CemeteryD.ump, MI
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Hazardous Waste Collection
Information Resource Center.
US EPA Region 3 .
Philadelphia, PA 19107
EPA Report C~;jat~!on
Information Resouf~e Comer
u~ EPA Region 3
Philadelphia, PA 1~1(j]1
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50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R05-89!1l0
I ~
3. Rec:ip/enra Accession No.
4. Tide IIId SubdUe
SUPERFUND RECORD OF DECISION
Cemetery Dump, MI
Second Remedial Action - Final
7. Author(a)
5. Report Date
09/29/89
/
6.
8. Performing Organization RepL No.
9. Performing Orgainlzation Name and Addre..
10. ProjectlTasklWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
1 ~ Sponaorlng Organization Name and Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460..
13. Type 01 Report & Period Covered
Agency
800/000
14.
15. Supplementary Notea
16. Abalrac1 (Umlt: 200 worda)
The 4-acre Cemetery Dump site is a former sand and gravel pit in Rose Township, Oakland
County, Michigan. During the late 1960s or early 1970s, approximately 300 to 600.drums,
containing paint sludges, solvents, PCBs, and oils, were illegally dumped and buried
on site. A 1985 Record of Decision (ROD) addressed the soil cleanup which included
excavation and offsite disposal of visually-contaminated soil and drum fragments. Soil
which was not visually contaminated was sampled and backfilled with clean soil into the
excavated areas. Subsequent soil and ground water sampling indicated that zinc
contaminants in the ground water exceed the Federal secondary MCL, a nonenforceable'
standard based on taste and odor; not protection of health. Zinc contamination, however,
is most likely a result of monitoring well construction materials. No other contaminants
exceed Federal or State environmental standards.
The selected remedial. action for this site is no further action because previous
remedial activities appear to provide adequate protection to human health and the
environment. Ground water will be monitored annually, and a 5-year review will' be
performed to ensure that the site continues to pose no threat to human health and the
environment. There are no costs associated with this no action remedy.
17. Document Analyala L Deacriptol'l
Record of Decision - Cemetery Dump, MI
Second Remedial Action - Final
Contaminated Media: none
Key Contaminants: none
b. IdentifieralOpen-Ended Terma
c. COSATI Reid/Group
18. Availability Statement
19. Security Claaa (Thia Report)
None
21. No. 01 Pages
26
20. Security Class (Thia Page)
Nl1nA
22. Price
I
(See ANSI Z39.18)
See Instructions on RevefB8
272 (4-77)
(Formerty NTIS-35)
Department 01 Commerce
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DEX:IN
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Attachments:
~. . .
nsi veness SUrrrnary
Mninistrative Record Index
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c,
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ROSE 'IGJNSHIP CEMErERY SI'IE
ROSE 'IGJNSHIP., MIOilc;a.N.
SlJM1Z>,RY OF REMEDIALAi}:t~VE SELEX:TICN
SEPID1BER 1989
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Site DescriPtion and Historv .
'!he Canetery Site is located in the NE 1/4 of Section 27, Rose Township
(T4N,R7E), Oakland county on Rose Center Road approximately 35 miles northwest
of Detroit. '!he 4-acre site is a fonner sam anj gravel pit which has been
baCkfilled and is generally clear with low brushy vegetation am grass cover
(see figures 1 and.2). Five dcmestic wells are located within 800 feet of the
. site perilneter which all derive drinking water fran the same lD1Confined
aquifer. 'D1e same aquifer is continuous in the Ceretery site area and is used
as an area-wide water 5\.I.Wly.
Michigan Department of Natural Resources (M['NR) and united States
Environmental Protection h;]ency (U.S. EPA) first learned aOOut the site frem
citizen reports alleging that approximately 300 to 600 barrels were dumped and
buried in an old sand and gravel pit (Cemetery Site) in the late 1960's or
early 1970 'So ~ently, the original site owner was approached by 'I\.1cker
Ford (a waste hauler) during this time period to bury sare 500 dI1..m\s at the
Ceretery Site. '!he site owner allegedly refused, rot the drums were disp:>sed
of anyway. 'D1e disp:>sal of the hazardous wastes at the Canetery Site was an
illegal dumping incident. Consequently, no records are available descrjping
the disposed materials.
'!he parcel of land was subsequently sul:x:1ivided am sold, am 4 residences were
built on the site. Portions 9f dnnns were observed on the surface of the site
and area residents have ret:erted the discovery and reroval of dnJm fragments
and waste depJsits encountered during gardening am other activities.
In Septenber 1981, approximately 20 to 30 barrel fragments were excavated and
transported off-site. Analysis of the barrel contents iIxlicated the presence
of paint sludges, solvents, polychlorinated biP1enylS (PCBs) and oils.
'!he site. was placed on the National Priorities List in 1982. 'D1e M['NR entered
into a Cooperative Agrearent with U.S. EPA to corXiuct the Rare:tial
Investigation/Feasibility Study (RI/FS) anj Phased Feasibility Study (PFS).
'!he PFS led to an operable unit Record of Decision (RCD) signed in septenber,
1985. 'D1e oPerable unit Rate:lial Action (RA) began in 1988, and involved
excavation of drum fragments and associated contaminated materials. The
excavated soils were divided into a visually contaminated pile am a oon-
visuailY contaminated pile. Visually contaminated soils and dnJm fragrrents
were loaded into trucks at a staging area in preparation for disposal.
~raximately 10,000 cubic yards of visually contaminated soils were excavated
fran the. site an:l disposed of at a facility licensed to accept hazardous
waste. soils excavated that did not appear to be visually contaminated were
stockpiled on plastic sheeting at various locations on the site, anj
subsequently sampled. '!he Post-Renediation Site Assessment (PRSl>.) was
performed after the operable unit RA in early to mid 1989 and consisted of
sampling existin; nmitoring wells an:! private wells. In Septanber 1989, the
excavated pits were baCkfilled usi~ the stockpiled soils along with the clean
inp:)rted soils.
camt.mitv Relations Historv
In 1985, two repositories were set up in the area:. Rose Township Hall, 2006
Rose Center Road, anj the Holly Library, 1116 rbrth Saginaw, Holly, Michigan.
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~
-. -~.
SCURC:t: USGS CUIDS
HIGHLAND,'" IM8
WEST H1GHLAHC,'"
FIGURE
1
1183
.,
~,.,.~ . -,.. .....,~..,
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FIGURE 2
DRUM DISPOSAL AREA
a'€TEAY 8ITt
ROSE TOWNs... MO«1AH
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0-0
/()
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., tIUu.,. 01 -. IUlfttrllC.8L '-II
&DCA'- '" --.. WlU. _'AU""
"U CGIIM'.. "'WIt( ...-.-, '0 1IoYICII.""
&DCA'- '" ..""...... WILl. -raun..
~ - 1111.15 '''''''''''''.- '-'."'"
10(.8'- 00 .' ~ U'"" UNa,. -...1ILt
IAOU.. ....",..,- -. "'-'.-11
........
...,
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n.....r:-r.00 'Ir,
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10(.8'- 01 -ocr .,.. '""
f) ...,
&DCA,'" CIf ""C48 - --..
ellOt-OO. --.. &DCA'''' or "'''1£ "LU
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Ii
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-2-
Copies of the PFS were made avai lab Ie to the cOl11nuni ty on July 22, 1985. The
MI:NR issued a press release on July 26, 1985 which annotmCed the availability
of the study, opp:)rtuni ty to ccmnent, and the schedule for the p..1blic meeting.
'D1e pJblic meeting .was held on August 1, 1985 at. tile Rose Township Hall.
TO start the final RCD process, M[I.zR issued a ptess release on August 9,1989.
This p..1b!ication provided notice of the August 23, 1989 Public Hearing and the
period for sutrnission of caments. On August 19, 1989 the Prop:>sed Plan was
distributed and placed into the rep:>sitories. The Public Hearing was held at
the Rose Township Hall. Generally, the level of concern over the Prop:>sed
. Plan was' low. ThE!ir main concern had to do with the delisting process. Many
People from the meeting expressed desire to accelerate the process and free
their :propertyfran the stigrra associated with the SUperfund site. The p.Iblic
. cornnent period' was from August 14 through 5eptenber 11, 1989. A response to
. corrmentsreceived during the carnnent period is included in the Responsiveness
. SlmmaIy. 'The Mninistrati ve . Record has been placed in the rep:>si tory .
, .
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" SITE Q1ARAcrERIsrICS
'. ,
Site Geoloqy
, '. . .' .
SUbsurface cOnditions at the Cenetery site can be described as glaciofuvial
,sediments CClTt'rlsed of interbedded water land depJsits of sand and gravel, silt:
and sand, and localdep:;sits of glacial till. ,. The subsurface soils
encountered during the drilling of boreholes at the site consisted primarily
of fine to coarse silty sarxl and gravel. The overall formation appears to be
a coarse textur!:!t:l glacial till, with a matrix that has variable aIT"OUl1ts of
,cobbles and boulders. Except for sp:>radic occurrences of non-sorted clayey or
silty lenseS and a lack of stratification, it resanbles an outwash depJsit.
"There is no evidence of a contiIulous naturally occurring barrier. This is
cri tical to assessing the hazardous, p:>tential of wastes renaining at the site
because there is no subsurface layer to prevent migration of any renai.ning
,buried wastes to the water table.
Site Hvdrooeoloqy
The Canetery Site lies within the headwater of the Shiawassee River Basin.
The closest surface water 1:x:d:y is Buckhorn Creek, located approximately 0.5
miles north of the site, which flows northeast for approxirnately 1 mile where
it discharges into Lake Braner.
The depth of the water table at the site is estimated to range fran 35 to 40
feet. The contour of the water table is flat directly beneath the site which
may be due to the very high permeability of the soils. The water table
gradient apparently irx:reases shaI1>ly to the east of the site and tends to
parallel the groun::l surface top:>grat:t1y which would nean that groundwater flows
generally east-north easterly (see figure 3). Because of the flatness of the
water table in the site area, it is p:>ssible the direction of groundwater flow
may change in response to slight seasonal variations in water table
elevations.
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_.:-:'~~
FIGURE 3
WATER TABLE MAP
Cemetery Site
Rose Township, Michigan
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Post-Remediation Site Assessment
The Post-Remediation Site Assessment (~) was cOnducted fran early to mid
1989 to determine what residual contandnation was left after the initial
action at the site an:} to determine whether further action was necessary. As
part of the ~ report, a risk assessment was done to evaluate the level of
risk to the htnnan health and to the environment. Field activities, conducted
by the MJ:NR, Michigan Department of Public Health (MDPH) and the U.S. EPA took
place between 1980 and 1989, an:} involved gro\ID:1water and soil sampling in the
area. '!his allowed the MJ:NR an:} the U.S. EPA to gather sufficient data to
determine if the level of contamination at the site would have an adverse
impact on the pmlic health, welfare or the environment. '!his section
Stm1T\arizes a ITUlch nore detailed analysis presented in the PR.St\ rep::>rt.
A) Gro\ID:1water:
The grolII1dwa.ter investigation involved COllecting samples fran six
private wells in addition to eleven nonitoring wells ratory contamination or well-specific factors. In
any event, the contaminant- concentrations are all below the heal th based
levels. -
B) SOils:
'lbree types of soil samples were collected for analysis (see figure 5 for
the sampling locations an:l Table 1 for the sumnary of the data).. first,
ten backgrourx1 (BS) soil samples were collected fran areas surrounding
the site to detennine levels of constituents which may be naturally
occurring in the area. 5ecorxily, fifty < 50) soil samples were co llected
fran the bottan of the excavations (ES) to see if any contaminants have
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--. UI8f_" --... -" - _n.
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.,. ==.,.~,~~"., -.-
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- III' H' ~-
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----: .f1!U ,..
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"::::r '-'. -. - 881- ~...;a ~
:, .- .w::r: ::::& = :.-=:. _.' ~
18111 .C_. .... " 2
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'CAlI" FlU
fIGURE 4
GROUNDWATER SAMPLE LOCATION MAP
Cemetery Site
Rose Township, Michigan
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TAiLE
ORGAMIC AID I.otGAMIC AMALTTES
DETECTED AT TME lOSE TOWMSMIP CEMETEI' SITE.
POST-IEMEDIATIOI ~LI.G
NuMber of Loc.tions
An8lyt~ Concentr.tion S~led for ANI'J"Sis
Envi rorwenul P08itiw
Nedi UII A".IYt~ "ini- 1iC..i... ..~."b Total D~tection
-=====- ==- ====
GII
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TABLE 1
(Continued)
Wu.ber of locations
SMDled for ANI on is
,-tti",.
Detection
Erwir~t81
"edi ua
ANIYte Concentration
ANI Yte
~ini.u. Maaf.u.
-===- ~
Meenb
fotal
-
lb'Iitoring ~tallCW !5l!. ~ ~ 11
"-III
Aluai- 275 1
Arsenic 7.7 17.1 12.1, 2
lar i ua 28.3 21.3 16lo 10
talciua 9910 "'000 92100 11
OIr08iua. toul 8.1 1
Iron 174 1'91 1,38 3
lead 5.2 110 57.6 2
Magnes i U8 21000 1,1000 327"00 11
...,..... 17.5 233 68.9 8
Potns".. 1100 2620 11080 7
SOdi \81 2930 31900 9680 11
Zinc 111 2TOOO 5130 11
SOIL
Sac:kgrOU"d Volatile ~ ~ ~ 10
S~les (IS)
Methylene chloride . .. 7.0
Selllivoliti Ie 10
Di.n.octylphthallte 170
Pestic:ide/PCS 10
lIonecMtKted
Meul/CII ~ ~ ~ 10
Aluail'Ul 5880 16600 9810 10
Ant '.an, 10.5 47.1. 26.0 10
Arseni c: 3.2 18.9 11.7 10
Ia,.h.. 21.1 215 67.9 10
"ryllf~ 0.62 0.82 0.72 2
CaItIi ua 1.3 5.1 3.1 10
Calct\8 1150 31300 8510 10
l2\,.i\8, tote I 8.3 29.3 16.1 10
Coba It 2.' 10.4 6.2 10
Capper 7.1, 25.6 14.7 10
Iran 6810 23 7"00 13100 10
LHd 6.8 13.7 10.3 10
...... i \.III 961, 11900 4210 10
...,.enese 146 415 309 10
Mercury 0.27 0.73 0.51, 10
Ifctel 4.4 24.7 12.7 10
PotllsiUl 381 23/.0 1090 10
Sodi\8 2lo1. 392 326 10
Venacli U8 13.7 37.3 23.6 1D
Zinc 29.0 ' 66.1 1,3.5 10
,,-
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:
TAILE 1
(CCII"It inued)
WU8be~ of Loc.tions
Anel'ite Concent~.tiCll"l S_led fo~ AneIY$is
Emfir~tal 1'08. tfw
Medii... Anel'ite, "I"i- "..i- ...."b Total Oetectton
~ -===== -=-
Eaeav.tion Vol.tilt !B.£g !B.£g !B.£g 50
Verlf ieat ion
~Ies (ES) Aceton. 31.0 150 71.7 ,
CerDari disulfide 2.0 3.0 2.5 2
OIlorofo1'8 1.0 2.0 1.7 ,
1.1.1-T~ichlo~oeth.ne 1.0 1
Toluene 2.0 26.0 11.8 9
Ethylbenzene 0.7 2.0 1.2 , , ,
Xylenes. toul 2.1 10.0 '''0 5
S..ivolat II es 3J.c
"'_I 62.0 1
Oi-n-butylphth81.te 1'0 190 165 2
bis
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TAiLE 1
(Cont irued)
Mumber of LOC8tions
&1\81 Yt. Conc8f'ltr8t i on S8MDled for Anelysis
Envir~t.1 Positive
l8edi U8 ANIYte "inl- ""1- ...."b Toul Oetection
~ -===- =
Potenti81 Vol.tile- ~ ~ ~ 1zd
I8ctfill
S8llPies US) Methyl- c:tIloride 6.0 "-.0 2'.0 10
Se.i -vol.tH e "
laoptororw 310 1
Oi-n-octylphth.l.te 70.0 150 110 2
Pesticide/PCB ,
4,4-00E 25.0
4,4.00T 35.0
c-.dli ol'd8ne 160
Aroclor 1254 240
"'t8I1C11 519 !!IIL9 519 '
Ahai,.. 4700 6lo8O 5370 ,
Ant I..,.,. 24.5 "-.1 32.8 ,
Ara."ic . 1.' 10.' 7.7 ,
..rha 16.7 30.1 20.9 ,
C8c81 un 2.9 3.3 3.1 ,
Celcil.lll 1 13000 192000 163000 ,
QlrC8iun, toul 10.8 15.7 12.5 ,
C0b8lt 3.8 5.5 4.8 ,
C~r 17.0 22.' 18.9 ,
Iron 10500 12300 11400 ,
Le8d 1.1 18.' 8.' "
IC8gnes i un 30000 50000 37'500 ,
lCM'Igenese '59 581 525 ,
...rcury 0.5' 0.84 0.65 ,
lIictel 12.5 11,.2 13.3 ,
POUII I un 711, 1280 1010 ,
Sod i UII '35 1 0i00 615 ,
V8Ndil.lll ".6 15.6 15.0 ,
Zinc "., 82.S 56.3 ,
."
,....
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T AILE
1 (continued)
!2!f.!
. D8U '1OUr'C" inctu::» ,"CU'dMte,. IlIIIpt.. c:ottected in "'rc:tt, 1989 by We,.Z't'\ and aolt ~Ies
c:ollected In &>«-''', ,- by OI_ic:.t Welte lCaNe-nt. Ire. lefer to ~ic:.. A through E
to deterwine tot.t --tyt.. Wtd detection tl.iU.
b Arft~tfc _en WI c:.tcutated by ireol"pOr.ting deu only frC18 1~les ""'ere the 8Nllyte was
detect8d. TItuI. ~t. VIIt"" fo,. --(ytal not detected ...re not ireluded. Dat. frC18 trip
btenb. ...ta btenb end _t lcate I~(" ...,.a .tlO not fncll.ded in the -en. loth ~I i f ied
dIIU end det. ~tified a. ..ti.ted ...re uaed in the c:.lc:ul.tions.
c: Soit IlIIIpt.. frC18 liat"" ES toc.tions lent to ..Hen for toul organic c~ analysis were not
analyzed for the I_ivolatile frac:tion.
d Votatite orvenic: c:tt_ial --lysil I118S perfol"'Nd on three i~.o...lt s~les frCIII foyr potential
b8c:kfitt (lIS) loc.tions. The IlIIIples in other analyte frac:tions were cOIIpOSite IlIIIples (three
;rao I~les) frC18 four (8IS) loc.tions.
..
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TABLE
2
. ELEMENTAL COMPOSITION OF. SOILS. .
REMEDIAL INYESTUiATION/FEASJBJlirv STUDY
ROSE TOWNSHIP - DEMODE ROAD SITE, .MICHI&ANa
Background Concentrations of Backgr9und: Concentrations
of Elements in Soil s at
Elements in U.S. Soils Cma/ka)b the Rose TownshiD Site Cma/ka)e
Median Ranae' . ' .
Element Ranae Median
,. I
Aluminum 70-100,000 66,000 0-7,4'55 . 4,246.2
Antimony O.2-10d 1 - - - . 0
Arsenic 1-50c 5 1.0'-13..5". 3.5
Barium 15-5,OOOc 554 18-87 42
Beryllium 0.01-40 6 0 -1. 0.'. 0.44
Cadmium 0.01-7 0.06 0-0. J' 0.13
Chromium 1-15,OOOc 53 4-1f.$', 7.7
Coba 1t <3-70 10 0-6.'5.' 3.5
Copper <1-300 25 4-27.5 12.3
Iron 100-100,000 25,000 2,854-13.265 6,603
Lead 2-200c . 10 4-15.;' 9.5
Manganese <1-7,000 560 21. 5-1, 179 313.6
Mercury 0.01-4.6 0.112 0-0.1.' : 0.02
Nickel <5-70 20 2.8-13 6.8
Selenium 0.1-2c 0.3 0-0..1 . 0.1
S 11 ver 0.01-5c 0.05 0-0.7: 0.1
Thallium 0.1-0.8d 0.2 -.- - °
Tin 2-200c 10 0-6.0 1.0
Vanadium <7-500 76 0-16.5 7.2
Zinc <25-2,000 54 12.5~35 23.8
a Table taken from RI/FS - Rose Township-Demode Road Site, Michigan.
b Source for all data except those marked: Ure, A.M. and M.L. Berrow, 1982.
The Element Constituents of Soils in Environmental Chemistry, H.J.M.
Bowen, ed., 2:94-204.
c Lindsay, Willard l., 1979. Chem1cal Equilibria in Soils, Wiley
Interscience, New York, pp. 7-8. ' .
d Bowen, H.J.M., 1982. Environmental Chemistry.
london, pp. 203-204.
e Based on statistical analysis of the following surface soil grab sample
population: SEDA-I0, 13, 14, 15, 16, 20, 21, 22, 27, 28, 33, 40, 46.
The Royal Soc. of Chemistry.
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rem:iined.' Finally, a caTTfX)si,te of 'five (5) grab samples for inorganics
anCl a grab sample for orgariicsand vOlatile organics were taken fran each
non-visually contaminated sOil' stockpile to determine if these soils are
acceptable for use as backfill iTE,terial (NS samples).
. ,
several. consti tuents of the pe.st{cide.s/FCB organic chanical fraction were
detected in NS arx1 FS soil sanPles.'. lvDst consistently identified were
the PCBs, particularly ARCX:LOR 1254. '!he maximJrn PCB concentration
detected in soils is ~roximately ten fold less than the Toxic
SUbstances Control 1v:t (TSO\) cleaJ1UP level guideline of the 10 m;/kg.
. DDr anCl its metarolites (IDE andDI;IDJ',were identified in t'w'O soil
samples, YJhile the pesticide ganma-chlordane was identified in one soil
sanple. . ~ "
For reasons' of suspect laOOratmy or. samPling artifact, low sample
concentrations, low frequency of ocd1rreiice in soil samples arrl their
absence in grQtIl'Xjwater samples, volati Ie' anCl sani -volati Ie organic
c~unds' were not considered tO~E;!present appreciable residual site
contamination. . ' ",,'
Risk Assessrrent
.
Based on the location of contaminated media at the site and current land use
act i vi ties at the site, two IX>tential pathways exist for contaminant expJsure.
1)
Direct expJsure to contaminated soils; and
2)
, '
ExpJsure via groumwater should contaminants leach to the aquifer and
migrate to private wells. "
, ,
GroL1I1dwater has not been impacted by site contamination. Low levels of
organic canp:n.mjs caTl'lDIlly associated with. analytical laOOratories (toluene,
rrethy1ene chloride, I=hthalates) were identified in sane residential well
samples. Based 'on their in:ansistent presence in groL1I1dwater sanp1es fran
past sampling events, their absence in, soil sanp1es, anCl their presence in
laroratory rnet:lx)d blanks, these CCtTp:>Uoos were not considered to be
characteristic of groundwater quality. In addition, average toluene
concentrations in grCllID:1water samples fran danestic wells «1.0 ug/l) are far
below prop::>sed federal staOOards (Prop::>sed M:L, 2000 ug/l). Similarly, lead
was identified in:onsistently in groLIOO\.1ater anCl soil sanples, arrl not
considered representative of site contamination. Elevated zin: concentrations
identified only in ITDJ'litoring well sanples are rrost likely related to well
construction materials.
Potential health risk resulting fran direct contact with soils was also
estimated to be low. PCBs were consistently identified in soil sanp1es iran
the excavation. 'As established under the Toxic SUbstarx:es control 1v:t (TSCA),
contamination of soils with PCBs ItUSt be renediated to specified cleanup
levels. CUrrently, these levels are 10 rrg/kg arx1 25 rrg/kg for unrestricted
am restricted access sites, respectively. '!he maxilrum PCB concentration
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detected in ES soil was awroximately 10-fold less than the 10 zrg/kg
guideline. DIJr is very imrobile am was found in extremely low
concentrations. 'l11erefore, the p:>tential for migration to groL1I1dwater is very
low. The only p:>tential for any risk 'w'Ould be fran dermal contact with the
soi 1. Wi tJl the backfilling of the excavations, the p:>tential pathway would be
eliminated.
The site is restricted to sane extent by fencing, thus limiting expJsure
p)tential to a p)p..llation of p)tential trespassers, which is assuned to be
very small.
In sumnary, the risk assessment concluded that there is a minimal risk to the
human health or the envirorment. '!herefore, it was concluded that taking no
further action is the preferred alternative.
IbcuIrentation of Sicmificant Char1sed plan.
The selected Renedv
.
The findings of the PRsa. show that the previous ranedial action was adequate
to ensure protection of human health am the envirornnent, and that no
unacceptable risk remains at the site. For backfilling of the pits tllat were
present at the site, the stockpiled soils have been used in such a manner tllat
the low levels of R:Bs found in one of the soil samples were sand\.riched in the
middle between the tW'O layers of clean soil ~rted fran the outside source
areas. This provided an added measure of protectiveness at no additional
cost. It is also reccmrerxied that the fence now in existence stay up for the
additional protection for at least five years. '!he site will be revisited
after five years to ensure that the site continues to p:>se no threat to the
human health and the environment. In the interim, the private wells and the
rronitoring wells, previously .scmpled, will be rronitored annually. At the same
ti.rre, the delisting process will be started since no contaminants were left at
the site abOve the health based levels. '!he continuance of the rronitoring
program will be assessed after five years, am every five years thereafter
until both U.S EPA in. consultation with MrNR is c~letely satisfied that the
site p)ses no risk to human health am the envi ronment.
StatutOry Determinations
Cost effectiveness and utilization of pennanent solutions and alternative
treatment technologies, while awlicable, do not need to be developed for the
no further action alternative.
Protection of Human H~~ 1 th and the Envi ronment/ARARs
Lead for one of the rronitoring well samples exceeded the primary M:L of 50 FP:J
..".
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but it is inconsistent with the past findings an::l the subsequent sampling
produced a lead concentration below that of the M:L. Furt.henrore, soil toring
data on the contaminated rroni tor ing well revealed lead concentrations wi thin
the background range for soils in the vicinity of e1e site. For these
reasons, lead is not considered a threat to human health an::l the envirornneI1t.
"
Zinc in sane groundwater rroni toring well samples exceeded the Federal
secondary M:L of 5000 ~ for drinking water. However, this is a non-
enforceable standard based on taste an::l odor, not protection of health.
Furthernore, the elevated concentrations in rroni toring well samples are
probably related to the use of galvanized pipe for construction of these
wells.
Other than the secondary M:L for zinc, no Federal or State enviroI1ITe1tal
standards are exceeded at the site. 'D1erefore, awlicable or relevant and
awropriate requiranents (ARARs) have been met.
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cormn.mity Relations Responsiveness SUIrrnary
Rose 'Ibwnship Cemetery Site
Rose Township, Michigan
septanber, 1989
G
... ']he: p.1l1X)se of this coomunity relations respon.siveness SUIm1ary is to doCl'!T'P-l1t
the' <;:ormunity relations activities along with citizen CorrtreTlts and Agency
resp:mses. 'Ihe Michigan Department of Natural Resources (l"IrnR) has been..
. ,.r~sp:;nsible for conducting a coordinated cornm.mity relations program for ttris
.. si~e.
.: .. .The' selected renedy of no further action was presented in the August 14, 1989
. .. Prpp:;sed Plan and at the pJblic hearing. '!here has been no negative p,1blic
r€QCtion to the selected remedy before or during the conment period. The
state of r-tichigan concurs with the Agency's decision.
,,:CQ-MJNITY RErATIOOS
"Th~ dates of the pJblic ccmrent period, the date and the location of a pJbJ ic
'. h~ing were announced through a legal notice in the local newspap:r.
. .: . .
i The Rose Township Cemetery Site PrOI=Osed Plan, which includes a descr:?,"- ior. of,
the investigation findings and conclusions was available along with the
. AdnUnistrati ve Record at the Rose Township Hall, Rose Township, Michigan ,-'_'ld
:the Holly Library, Holly, Michigan. .
!he pJblic hearing was held at the Rose Township Hall at 2006 Rose Center Road'
on Wednesday , August 23, 1989 to discuss the Remedial Investigation and the
. preferred alternative. ~roxiroately thirty people were at the hearing.
Following presentations by MrNR, several people expressed ccmnents.
cOmrents raised during the pJblic ccmrent period, which are relevant to tll£!
. Prop:;sed Plan, are sumnarized below. 'D1e CCallient period was held from Allgus":
14 to 5eptanber 11, 1989.
sur-i'~Y OF pnFU':r:c a::M1ENI'S MID ~ FF.~
Cooment: several ccmnenters wanted to know when the excavated pits from :.'1e
first operable unit remedial action will be backfilled.
EPA Resoonse: Just recently the excavated pits have been backfilled ar.d
leveled off to original contours.
Cotlll~ It: ()1e coomenter wanted to know what ranained 30 feet 1.D1derground, and
surmised that there are barrels urder t.heI'e.
EPA ReS1:X':)J1.Se: At the lx>ttan of all the excavations, MrNR screened for ;,ny
metals using a metal detector. After the testing, it was determined tJl..l.
. there were no Iretal objects hJried to a depth of 50 feet. Also, soil tor::~s
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were taken to the depth of 75 feet and no contaminants were detected above the
heal th based levels.
Ccmnent: One of the carmenters wanted to find out why the suspect laboratory
samples weren't resaI1i>led.
EPA Res1:XJl1Se: '!he trip blank sanples are taken to see if arr:l contamination
originates fran the field or fran the lal:x:>ratory. If the trip blank san;:>les
show similar type of contamination as the actual field samples, then it can be
stated with confiderx:e that the contamination originated fran the lal:x:>ratory.
Ccmnent: One of the ccmnenters was concerned about the DDI' that was found
after all the excavation was done.
EPA Resoonse: DUI' is very imrobile and was found in extremely low
concentrations. '!herefore, the pJtential for migration to groundwater is very
low. '!he only pJtential for any risk 'WOuld be fran dermal contact with the
soil. With the backfilling of the excavations, the pJtential pathwaywquld be
eliminated.
Ccmnent: One ccmnenter askE!C\if a site can be delisted while a ITCnitoring
program is corxh1cted by the MrnR.
EPA Resronse: '!he deletion process can start when based on a remedial
investigation, EPA, in consultation with the State, has determined that the
release pJses no significant threat to p.lblic health and the environment and,
therefore ,taking of retaiial measures is not awropriate. 'DUs is the case
at the site and therefore, the deletion process can be initiated while the
rroni toring program is conducted by the MrNR.
Cooment:
the site.
AlX>ther carmenter was concerned al:x:>ut the R:Bs that were found at
EPA Resronse: '!he PCB concentration levels are far below the cleanup levels
established under the Toxic SUbstances Control kt. Also, the low levels
found will be saoowiched in the middle by the i1rq:x)rted clean soil during the
backfi lling of the pits. R:Bs are very imrobile and the risk assesszrent
coocludes that e>qX)SUI'e to these low levels does not pJse a risk to htman
health.
CCITtTeI1t: 01e camenter wanted to know why the site is still on the National
Priori ties List when the site is no longer a problen. .
EPA Resronse: Mrj sites that are on the National Priori ties List hqve to
undergo a fonnal deletion process before they are raroved fran the list. .
Cooment: One of the ccmnenters asked why MLNR is continuing to test the wells
for five years when the site is no longer a problen.
EPA Resoonse:
'!he current data in:iicate that the site IX) longer pJses any
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risk to the human health or the environment. TIle additional rronitoring will
provide extra assurances and confirmation to tllat effect. As always, it is
of the utrrost ilTp:)rtance to J:oth U.S. EPA and MCNR tl1at public health is well
protected.
Q
Ccmnent: Another cam-enter was concerned about low levels of chromium and
nickel found in the background soil samples.
EPA Resoonse: Low levels of chromium and nickel are naturally occurring in
the area at levels far below the health based levels.
Ccmnent: O1e ccmnenter wanted to know why the resp:>nsible parties were not
actively pJIsued and held liable for any costs incurred at the site.
EPA Resoonse: Both U.S. EPA and MI:NR will be looking at theIX>ssibility\of
recovering the fu:rns. Evidence regarding the liability and solvency of
IX>tentially resp::>nsible parties is currently being evaluated.
Comnent:
One of the ccmnente~ wanted to extend the ccmnent period.
EPA Resoonse: After further cc:mm..mication with the ccmnenter, the request for
extension to the ccmnent period was withdrawn. The corrmenter was apprised of
the ccmnent period during the deletion process, and was supplied with the EPA
gUidance on the NPL deletion process.
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ATrnCHMENI' III
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