United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
. EPAIRODIR05-90/144
September 1990
C O?'1' l
oEPA
Superfund
Record of Decision:
Metamora Landfill, MI
. ~S'...
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
EPA Report Collection
Information RlsourcEJ Centf.j~
US E~A ft~~B@Y1 ~
Phn~~~~'~BIDn ~~ 1~~@1
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50272.'01
REPORT DOCUMENTATION I,. REPOATNO.
PAGE EPA/ROD/R05-90/144
I ~
:L A8dP8nf' t.cc888an ...
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4. T1tI8 tnd ......
SUPERFUND RECORD OF DECISION
Metamora Landfill, MI
Second Remedial Action
7. Au--...
s. A8pan 0-
09/28/90
II.
II. ParfanNng OrIarUllion ~ No.
8. Parfonnlno Or;alNz8llon N8m8 and ---
,0. Proj8ctIT88IrJWortI UnIt No.
". c-8ICt(C) Of cnnt(GI No.
(e)
(G)
I~ Sponaonng Organlzdon N8m8 and ~
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
IS, Type of A8pan' P8riod Co-.d
Agency
800/000
16.
15. Suppl.........,-
III. ......C1 (Unl: :zoo .~I
The 160-acre Metamora Landfill site is an inactive, privately owned landfill in
Metamora Township, Lapeer County, Michigan. Both wetland and woodland areas are
present onsite. The site is underlain by a.shallow glacial deposit aquifer, a lower
sand and gravel unit ("the intermediate aquifer"), and the Marshall Sandstone bedrock
aquifer. Landfill operations began in 1955 as an open dump, and the facility was
upgraded in 1969. Industrial and municipal wastes, including approximately 35,000
jrums, were accepted until the landfill closed in 1980. In 1981, the State sampled
seven drums and identified several hazardous materials. A 1986 Record of Decision
(ROD) for Operable Unit tl (OU1) called for the excavation and disposal of the waste
drums offsite at a RCRA incinerator. This ROD addresses ground water contamination of
the shallow aquifer, as well as the generation of leachate at the landfill (OU2). A
third ROD will address onsite contaminated subsurface soil (OU3). The primary
contaminants of concern in the landfill affecting debris and ground water are VOCs
including benzene, PCE, TCE, and xylenes; and metals including arsenic and barium.
The selected remedial action for this site includes pumping and treatment of ground
water using precipitation/ flocculation to remove inorganic contaminants followed by
(See Attached Paae)
17. DocumentAn8/y818 L ~_. -
Record of Decision - Metamora Landfill, MI
Second Remedial Action
Contaminated Media: deb~is, gw
Key Contaminants: VOCs (benzene, PCE, TCE, xylenes), metals (arsenic)
b. 1d8n1I"''''~ T-
Co COSATI ~
,8. AYllIlDlllty 818--'
18. SecurIty CI8u (11118 Aapo")
None
2IL Seautty ClaM (1hI8 p.l
None
21. No. of P88M
39
22. Pr1~
I
(SM ANSI.Z38.1I1
,..77)
SM/M/TUCIJ- on ".-
(Fomwrty NTlW51
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EPA/ROD/R05-90/144
Metamora Landfill, MI
Second Remedial Action
Abstract (continued)
air stripping and carbon adsorption to remove organics, and reinjection of treated
water into the shallow aqui:er: of:site treatment and disposal of secondary waste
streams including flocculation sludge and spent carbon; capping the landfill area
using a multi-layer clay cap as :equired by the State, and collection and flaring of
landfill gases; monitoring ground water: implementing institutional controls such as
deed and ground water use restrictions, and site accress restrictions such as
fencing. The estimated present worth cost for this remedial action is $19,354,050,
which includes an annual O&M cost of $856,944 for 20 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific cleanup goals for ground water
are based on Michigan Act 307 rules as well as MCLs and include benzene 1.0 ug/l
(State), PCE 0.7 ug/l (State), TCE 3.0 ug/l (State), xylene 20 ug/l (State), and for
arsenic the more stringent 0: 0.02 ug/l (State) or background.
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Record of Decision
Remedial Alternative Selection
SITE:
Metamora Landfill, Metamora, Lapeer County, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Metamora Landfill Site, in Metamora, Lapeer County,
Michigan, which was chosen 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 oil and Hazardous Substances Pollution
contingency Plan (NCP). This decision is based on the
administrative record for the site. The State of Michigan
concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF SELECTED REMEDY
This groundwater and landfill Operable Unit is the second of
three operable ~nits for the site. Operable Unit One is for
source control of the two drum disposal units. The Record of
Decision for Operable Unit One was signed on September '30, 1986.
The remedial action is currently underway. Operable Unit Three
and will be the final remedy will address subsurface soils
primarily in the two drum disposal areas.
The selected Remedy consists of the following:
-Groundwater treatment through extraction utilizing
precipitation/flocculation, air stripping, and recha~~"
of the treated groundwater back into the shallow
aquifer. '."
-containment of the Landfill contents through a 90
centimeter clay cover meeting the requirements of
Michigan Act 64, utilizing a passive gas collection
system and flaring.
The ~emedial Action for Operable Unit Two will address
groundwater contamination, exposure to contaminated soils and
potential contamination caused by leachate from the landfill.
The response action will address the principal threats causej
the site, such as groundwater contamination of the shallow
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aquifer, and the reduction of leachate from landfill contents
into the shallow aquifer.
DECLARATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as a principal element.
Because this remedy will result in- hazardous substances
remaining on-site above health-based levels, a review will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Da~P7
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0:
1.0.
2.0.
2.1.
2.2.
3.0.
4.0.
5.0.
5.1.
5.5.1.
5.1.2.
5.1.3.
5.1.4.
5.1.5.
5.1.5.
6.0.
6.1.
6.2.
6.3.
6.4.
6.4.1.
6.4.2.
6.4.3.
6.4.4.
6.5.
6.5.1.
6.5.2.
7.0.
7.1.
7.2.
7.3.
8.0.
8.1.
8.2.
8.3.
9.0.
10.0.
11.0.
~ OF a::HIBnS
Page
SrTE LOCAT!CN AND DESCRIPTION.......................1
SI'I'E ~........................................1
PREV10US SITE INVESTIGA!!ONS........................1
~............ ...... ...............2
COMMUNITY PARX!CIPA!!CN.............................3
SCOPE AND ROLE OF THE OPERABLE UNIT.................3
SUMMARY OF SI'I'E ~CS.....................3
~ OF RI. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
SOIL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
I.EAaM'E~ SOILS. . . . . . . . . . . . . . . . . . . . .4
. . .4
SED~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
~Ac:E: ~........... . . . . . . . . . . . . . . . . . . . . . . . . . . . .5
SOILS c:x::NrAMINM'ED wrm EIJRNED WASTE. .
~. . . . . . . . . . . . . . . . . . . . . . . . . . .
..........5
..........5
SUMMARY OF SITE RISRS...............................5
~ OF CCNCERN.............................5
~ ~.......
'It>XICI'IY ~.......
SUMMARY OF SITE RISK CiARACTERIZATION.
..................... .6
......................7
......
....8
~ 'It> SOIIS................................... 8
:E:XPCE;URE 'It> ~ ~ INGESTIOO........... 8
~ 'IO ~ ~ ~.............8
~ 'IO ~ ~ ~...........8
~ RISRS............
.................9
:E:XPCE;URE 'IO TEMFORARY FO:>LS....
~ oro IEACiM'E , lEAOiATE a:m'.
.................9
SOIIS. . . . . . . . .9
DESCRIPTtON OF ~.........................9
~ ~...........................11
INlDFIIL ~........
. . . . . . . . . . . . . . . . . . 13
~OR ARARs.............
. . . . . . . . . . . . . . . . . . . . . .14
~ OF cx::MPARATIVE ANALYSIS OF AI1I'ERNM'IVES. . . .15
. . . . . . . . . . . . . . . . .16
.................17
THRESHOLD CRXTERIA...........
PRIM1\RY BAL\NCING CRXTERIA...
MDDIFVING CRXTERIA.................................19
THE S~l~ REMED¥................................19
~ ~ONS...........................21
~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24
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SUMMARY
RECORD OF DECISION
OF REMEDIAL ALTERNATIVE
FOR THE
METAMORA LANDFILL SITE
METAMORA, TOWNSHIP
METAMORA, MICHIGAN
SEPl'EMBER 1990
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SELECTION
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TAIU OF a::tmmS (cxntirued)
Attactunent 1............ STATE OF MIonGAN ~ OF ~
Attad'me1t
Attachment
2.............................RESPONSIVENESS ~
3. . . . . . . . .. . . . .. . . . . . . . . .~ RE'X:DRD rnI:JE::)( - No-r
IYtL
Lo.A..cI~d.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
METAMORA LANDFILL
1.0
SITE LOCATION AND DESCRIPTION
The Metamora Landfill is located in Metamora Township, Lapeer
County, Michigan, approximately one-half mile northeast of the
Village of Metamora, and 20 miles east-southeast of Flint, MI
(Figure 1). The site is an 80-acre closed landfill that
accepted industrial and municipal waste between 1955 and 1980.
As many as 35,000 drums may be buried in the landfill. The area
was previously used for gravel mining, which accounts for the
many steep excavation faces and borrow pits on the site. A
gravel mining operation continues immediately south of the site,
and a licensed solid waste transfer station currently operates in
the western area of the site. There are two areas on the
Metamora Site that are considered to be wetlands according to
Michigan Act 203, P.A. 1979. The surrounding land use is both
residential and agricultural. About 60 people use ground water
downgradient of the site. The Village of Metamora's 1982
estimated population was 596 people. Fifteen homes have been
built within a one mile radius of the landfill since the 1980
census. There is a shallow and intermediate aquifer present
above the bedrock aquifer (the Marshall Sandstone aquifer). The
Marshall Sandstone is the primary aquifer for domestic wells in
the Metamora area, although a few domestic wells obtain water
from the lower sand gravel deposits above the bedrock. Very few
water wells have been completed in the surficial glacial
deposits.
2.0
SITE HISTORY
The landfill began operations in 1955 as a privately owned,
unregulated open dump. In 1969, the landfill was upgraded to
meet existing standards, and licensed to receive general refuse.
Two fires at the landfill were documented in 1972 and 1979. The
1972 fire reportedly burned out of control for three days,
perhaps fueled by waste materials in the landfill. The site
accepted both municipal and industrial waste until its closure in
1980. No records have been discovered that indicate the disposal
practices of the former operator. However, it is likely that
waste and drums were disposed of in unlined excavations (former
mining pits or borrow areas) .
2.1
PREVIOUS SITE INVESTIGATIONS
In 1981, approximately eight drums were unearthed in the
Northwest area of the site (Figure 2) during borrow excavations
for the nearby solid waste transfer station. The Michigan
Department of Natural Resources (MDNR) sampled seven of these
drums and identified (but did not quantify) the presence of
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methylene chloride, methyl chloroform, dichloroethyl ene, and
styrene, and found up to 40 mg/kg lead. In 1982, the MDNR
conducted a magnetometer survey which concluded that as many as
35,000 drums, some containing liquid waste, might be present in
five disposal areas around the site (Fig. 2). The survey
concluded that area one and four contained about 74' of the total
estimated number of buried drums in the landfill. Hazardous
chemicals in the buried drums from areas one and four were
confirmed from limited test pit excavations done by the MDNR in
June and September 1982.
In the summer of 1985, the MDNR initiated pre-remedial
investigation activities at the site, during which soil borings
were taken and thirteen ground water monitoring wells installed.
That work determined that the site geology is variable, but
generally consists of unconsolidated sand and gravel that is 250-
300 feet thick in some locations, underlain by a clay/till unit.
Ground water occurs at an average depth of about 100 feet below
ground surface, with the deep aquifer at about 300 feet. Ground
water flows from the south-central part of the site to the
northwest and northeast (Fig. 2). Sampling results from the
investigation confirmed the existence of the organic and
inorganic groundwater contamination. Monitoring wells MW-4 and
MW-8, located in the immediate vicinity of area 4, and monitoring
wells MW-17s and 17d, located adjacent to area 1, all showed
contamination by volatile organic compounds. The pre-RI work is
summarized in the report entitled "Site Investigation Final
Report" (E.C. Jordan, February 1986)
In the fall of 1986, the MDNR initiated the Remedial
Investigation/Feasibility Study (RI/FS) at the site. A Phased
Feasibility Study was completed in August, 1986, which cumulated
in a Record of Decision (ROD) for Operable Unit One signed on
September 30, 1986. The 1986 ROD called for the excavation and
disposal of all waste at an off-site RCRA compliant incinerator.
To date, 22,000 drums have been excavated from the site.
Excavation is planned to be complete by the end of September
1990.
The Remedial Investigation report was completed in March, 1989.
A Feasibility study for the Metamora Landfill site was completed
in April 1990.
The FS presented several groundwater remedies and landfill
alternatives that will be explained in detail under the
Description of Alternatives section of this document. A more
detailed analysis of all alternatives is found in "Feasibility
study Final Draft Report" (E.C. Jordan, April 1990).
2.2
ENFORCEMENT
On April 29, 1986, Notice Letters were sent to ten Potentially
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Responsible Parties (PRPs) offering them the opportunity to
undertake the Agency's remedy for operable unit one. The PRPs
declined and negotiations were terminated. Therefore the
remedial action became a state lead, Fund financed project.
Through PRP searches and evidence uncovered during the
implementation of Operable Unit One, approximately 70 PRPs have
been identified. Special Notice letters will be sent in October
1990.
3.0
COMMUNITY PARTICIPATION
Community Relations activities have been conducted by the State.
Project updates have been sent out regularly. The Public was
given the opportunity to comment on the Proposed Plan and the
Feasibility Study, for this operable unit, from July 12, 1990 to
August 28, 1990. A Public meeting was also held to discuss the
proposed remedial action for the site. Oral and written comments
were recorded, summarized and addressed in the Responsiveness
Summary of this document. The provisions of Sections
113(k) (2) (B) (i)-(v) and 117 of CERCLA have been satisfied.
An information repository has been established at the Lapeer
Library, Metamora Branch, 4024 Oak Street, Metamora, MI 48455.
According to Section 113(k) (1) of CERCLA, the Administrative
Record has been made available to the public at the Lapeer
Library.
4.0
SCOPE AND ROLE OF THE OPERABLE UNIT
The Remedial Action selected in this ROD (hereafter referred to
as "Operable Unit Two") will address groundwater contamination,
exposure to contaminated soils and potential contamination caused
by leachate from the landfill. The response action will address
the principal threats caused by the site, such as groundwater
contamination of the shallow aquifer, and the production of
leachate from the landfill. The operable unit two remedy will
include a cap of the landfill and a groundwater pump and treat
system. Since wastes will remain on-site, periodic monitoring
will need to be maintained, as well as a review of conditions
after 5 years.
5.0
SUMMARY OF SITE CHARACTERISTICS
The RI and FS Reports have adequately described the current
conditions of the Metamora Landfill Site. The final RI Report
was issued in March 1989 and the Final Draft FS was issued in
March 1990. Field work for the RI began in October 1986 and was
completed in June of 1988. The objectives of the RI were to
evaluate the extent of contamination on-site, define pathways 0:
contaminant migration and assess potential impacts on potential
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receptors, identify features that would affect contaminant
migration, containment or clean-up, and assess public health and
environmental hazards.
The results of the RI are summarized below:
-The geology of the Metamora Site consists of sands and
gravels with interbedded tills and silt layers which impede
vertical groundwater flow. Groundwater is flowing primarily
toward the north or northwest.
-The upper aquifer at the site has been contaminated by
chemicals which have migrated from the drum areas and the
landfill. The horizontal extent of groundwater
contamination extends at least 550 feet from the northern
boundary of the landfill. Since the furthest down gradient
wells are contaminated, a model was run to estimate the
extent of the plume. The numerical model estimated that
contaminated groundwater may extend 2,500 to 3,500 feet
north of the northern landfill boundary.
-It does not appear that the chemicals in the upper aquifer
have migrated into deeper water-bearing zones. Even so,
MDNR will periodically monitor these zones in the future.
-Soil samples contaminated with leachate from the landfill
were anal/zed during the RI, and several organic chemicals
were detected. No site-related contaminants were identified
in surface water or sediments collected from temporary pools
which exist around the site.
5.1.1
soil
The chemical data on soils around the drum areas indicates that
they have not been severely contaminated by waste contained in
the drum areas. It is likely, however, that soils directly
beneath the drum areas and soils mixed with the drums contain
high concentrations of chemicals. In general, the concentratic~s
of inorganics detected in soil samples around the drum areas wer0
comparable to those expected in background Michigan soils.
5.1.2
Leachate-Contaminated Soils
Leachate seeps are commonly visible around the Landfill. Twe: '.,
organic chemicals were detected in these soils. Inorganic
concentrations were also comparative to background with the
exception of Zinc (Table 1).
5.1.3
Sediments
Two common laboratory artifacts were detected in sediment sa~;
collected around the Metamora Site. It is unlikely these are
4
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INOItANICS II lEACHAIE-CONTAMINATED SOil
"tTANORA lANDfill Silt, "(I.~A 1000SHIP, "'CNIG.I
I~I. loc.'lon: SI-1 Sl.1 Sl-J IlO-1 cJACI'c.oJID
',a"Ie .~,. 10 f'('.~IIO (OUP Sl-1) r;UTlATlON
"U.09' "(I ~ 7'9 "(I-09J ,,"tt
Al~I'" 1,060 1.1I~0 I, ~90 1,610 1,110 - 10,1'\0
AISUIC ~.8 n.1 '.8 6.' 0.1 - 88
''''~ 10 18 11 10.4 ~_l - 1"11
(AO"I~ l.~ l.~ 1.1 1.9 0.1 - ).~
(AlCI~ " ,000 ~J,600 51,100 n,600 IA
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(OiAll 1.9 1 ).6 '.6 l.~ . 1).0
(OPPU 6.4 ,.~ 1.6 8 1.1 . 81.'
"011 Il,OOO 10,600 9,600 ",900 l,JlO . lIJ900
If AD 6.' J 6.' J 4.8 J 6.9 J 1.1' 6.0
""N(lI'" .,100 11,900 16,800 11, '00 ..
"ANGANUI 10~ 111 1~6 116 J1.0 - 81\.0
WIUH ~.I '.6 , 9 1.6 . ".0
"OUSSI~ I'D I" 119 181 IA
V.llAOI~ 8.' 11.' 10.6 11 II'
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l. Ch~lc.la which ~r. no. ~'.c'~ In .'1 ..-pl., .r. no. II'I~ (Ib, I., '., .., I., A., TI, end CI').
J. J. en .,'I"I~ value.
'. Oa.h~ II~. Indlc... ene8y.. v.. nol del.cl~.
,. '.c..round conc~lr.llon 'ent. '.porl~ by MD., (11111/87) '0' "Ichl.an loll..
6. WA' no. av.ll.bl..
. .
"
.
-------
. :
-:
site related. Inorganics detected in sediments were also
comparable to background levels.
5.1.4
Surface Water
No site-related organic chemicals were found in surface water
samples and inorganic concentrations were comparable to
background levels.
5.1.5
Soils Contaminated with Burned Waste
Because drums containing burned wastes were found close to drums
containing chlorinated wastes, there was a possibility of dioxins
and dibenzofurans being present in the burned materials. Since
the highest TCDD-equivalent at the Metamora Site was estimated at
0.105 ppb, it appears that further investigations of dioxins or
dibenzofurans at Metamora site is not necessary.
5.1.6
Groundwater
34 organic chemicals and 12 inorganic chemicals were detected in
the shallow aquifer. Only one intermediate well was found to be
affected, but this is attributed to cross contamination. The
bedrock aquifer exhibited no signs of site-related contamination.
This includes both monitoring wells and five downgradient
domestic wells. The concentrations of all contaminants is found
in Table 2.
6.0
S~YOFSIn~s~
6.1
Contaminants of Concern
CERCLA requires that u.s. EPA protect human health and the
environment from current and potential exposure to hazardous
substances found at the Site. The basis for this response action
is the presence of VOCs exceeding Michigan Act 307 groundwater
standards, Federal MCLs and health-based risk levels in
groundwater which has the potential to serve as a source of
drinking water for the affected area.
As part of the RIIFS for the Site, u.S. EPA has prepared a
baseline risk assessment. The baseline risk assessment is based
on unaltered conditions at the Site as contemplated by the No
Action Alternative. The baseline risk assessment determines
actual or potential risks or toxic effects the contaminants of
concern at the Site pose under current conditions.
Table 3 lists the contaminants of concern. Arsenic, barium,
benzene, 1,2-dichloroethane, trichloroethene and vinyl chloride
exceeded their respective MCLs. All of these chemicals which
exceed their MCLs were designated as contaminants of concern.
addition, three other compounds which are carcinogens, 1,1-
-
5
-------
TABLE 1
o.CI.I[ [II(MI[IIS I. I(A(IIII(-(0.'1"11I11(0 SOilS
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. .
-------
. ..
-:
contaminant
Acetone
Benzene
Benzoic Acid
Bis(2-EH) phthalate
Bromochloromethane
2-Butanone
Butylbenzylphthalate
Chlorobenzene
Chloroethane
Chloroform
Delta-BHC
l,l-Dichloroethane
1,2-Dichloroethane
l,l-Dichloroethene
1,2-Dichloroethene
Diethylphthalate
2,4-Dimethylphenol
Di-N-Butylphthalate
Ethylbenzene
Heptachlor
2-Hexanone
Methylene Chloride
4-Methylene-2-Pentanone
2-Methylphenol
4-Methylphenol
Napthalene
Pentachlorophenol
Phenol
Toluene
1, 1, 1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylene
TABLE 2
ORGANIC GROUNDWATER CONTAMINATION
IN THE SHALLOW AQUIFER
METAMORA LANDFILL
(ppb)
Minimum
1.0
1.9
7.0
2.0
Maximum
190
20
240
390
1.0
89
50
2.0
17
2.0
0.071
55
24
2.1
270
6.2
23
3.0
2,800
0.1
24
60
140
16
110
2.6
130
24
670
17
6.0
14
6.0
2.0
10
3.0
1.0
1.9
1.0
1.3
7.0
1.3
1.2
2.0
9.0
2.0
1.0
0.07
1.0
2.0
2.0
5.0
12
2.0
5.0
2.6
1.0
2.8
1.0
1.3
1.0
12,000
-------
Contaminant
Acetone
Benzene
Benzoic Acid
2-Butanone
Butylbenzylphthalate
1,1-Dichloroehtane
1,2-Dichloroethane
1,2-Dichloroethene
Ethylbenzene
Methylene Chloride
4-Methylene-2-Pentanone
Pentachlorophenol
Toluene
1,1,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylene
Contaminant
Acetone
Methylene Chloride
Toluene
" '
:.
TABLE 2 (continued)
ORGANIC GROUNDWATER CONTAMINATION
IN THE INTERMEDIATE AQUIFER
METAMORA LANDFILL
Minimum
5.0
Maximum
100
1.0
12
100
4.0
9.0
7.0
97
35
14
96
160
77
12
44
47
95
2.0
4.0
3.0
31
16
5.0
1.0
3.0
19
1.0
1.0
ORGANIC GROUNDWATER CONTAMINATION
IN THE BEDROCK AQUIFER
METAMORA LANDFILL
Minimum
4.0
3.0
1.0
Maximum
13
4.0
2.0
-------
. ..
0:
TABLE 2 (Continued)
INORGANIC GROUNDWATER CONTAMINATION
METAMORA LANDFILLL
Contaminant
Arsenic
Barium
Beryll ium
Cadmium
Chromium
Copper
Iron
Lead
Nickel
Selenium
Silver
Zinc
SHALLOW
AQUIFER
min. max..
2.1 260
53.8 2180
9.0
6.5
9.0
33
18,700
44
260
4.2
21.2
138
3.0
5.4
5.0
14.5
0.7
6.0
1.0
0.9
47,500
INTERMEDIATE
AQUIFER
min. max.
2.0 10.1
54.7 118
BEDROCK
AQUIFER
miD.....
14.3
107
IM2L.
34.1
126
378
--------------------------------------------------------------------------
194
0.7
2030
6.2
159
A complete table of groundwater sampling data in found in the RI report.
-------
T Ai3LE 3
COI'."'I.IIS O. COICIII
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-------
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. '.
dichloroethane, l,l-dichloroethene and 1,1,2-trichloroethane were
also included. The remaining chemicals, all non-carcinogens,
were reviewed for possible inclusion by considering the
frequency of detection and assessing the relative toxicity by
using a dose-response value such as U.S. EPA risk reference dose
(RfD) .
Table 4 identifies the concentration of the contaminants
concern to potential ARARs.
of
6.2
Exposure Assessment
There are three known contaminant sources at the Metamora Site;
Drum disposal area 4, located in the northwest corner of the
site; drum disposal area 1, located in the north-central portion
of the site; and the landfill which is situated in the northeast
corner. The distribution of chemical contaminants at the
Metamora Landfill Site indicates that both drum areas and the
landfill are contributing contaminants to the groundwater. The
drum areas can be considered specific sources and the landfill
can be considered a non-point source. At this time, there is
insufficient data to confirm specific point sources from the
landfill. These chemicals move through the soil under gravity,
or they percolate down through the soil (due to precipitation) in
a continuing series of cycles of adsorption to soil and
extraction into water. After the chemicals reach the aquifer,
they are transported downgradient by groundwater flow.
The Risk Assessment has identified the following routes of
exposure:
- ingestion of groundwater;
- inhalation of volatilized contaminants during showering or
bathing;
- dermal absorption of contaminants during showering or
bathing; and
- dermal adsorption and ingestion of leachate-contaminated
soil.
The area around the Metamora Landfill is primarily agricultural.
Thirteen residential homes and a Boy Scout camp are located
within a one-half mile radius of the site. The residential area
near the site is considered typical and likely at any point in
time to consist of a mix of adults and children. Additionally,
the Boy Scout camp provides an area that short-term visitors
would inhabit in the summer. Because the site is not restricted
it may be accessed by the population. Portions of the site are
highly attractive areas for dirt bike riding and other
recreational activities. No endangered species are located in
6
-------
-.------
. .
TA!U 4
COMPARISON or KAXIKUK CROUNDWATER 'CONCENTRATIONS
TO POTENTIAl. A1WU FOR INGESTION
S MAUOW AQtJ 1 F'Dl ,UJKE
KETA.'10RA lANDFILL S lTE. 1'.tTA.'10AA TO'olNSHIP, KICHICAN
-
. -
~ '..
KAX. KAX.
CONCEN. USEPA EXCEEDS
NO. TRATION MCt. \JSEPA
D£TEC'TA!l.E (u&ll) (u&ll) MCt.
Arsenic 21/43 260 50 YES
!ar1WA 39/43 2,170 1,000 YES
!eruene 4/43 11 5 YES
l,l-Dichloroethane 25/43 55 NA NA
l,2-D1chloroethane 15/43 19 5 YES
. 2.1
l,l-D1chloroethylene 2/43 7 NO
1.2-01chloroethylene 7/43 270 701 YES
£thylberuene 5/43 2,800 NA NA
Trichloroethylene 6/43 14 5 YES
1.l,2-Trichloroethane 5/43 6 NA NA
Vinyl Chloride 6/43 6 2 YES
Xylene 5/43 12,000 NA NA
HA - Not Ava11able!Not Applicable
1
Met. for l,2.Cichloroethene 1. . proposed .tandard.
-------
. :
.:
the vicinity of the site.
As stated before, only the shallow aquifer is shown to be
contaminated. Because contamination was detected in the
northern-most monitoring wells, it was assumed that
contamination has migrated north of these well locations. The
northern-most extent of contamination was estimated by using a
three-dimensional dispersion model for slug input. The model
estimated that the plume may extend 2,500 to 3,500 feet north of
the northern landfill boundary (Figure 3). Figure 4 presents a
cross-sectional view of this interpretation.
6.3
Toxicity Assessment
Using data generated during the RI, u.s. EPA conducted a site-
specific baseline risk assessment to characterize the current
threat to human health from ingestion of contaminated
groundwater and exposure to leachate contaminated soils. The
results of the risk assessment establish acceptable levels for
the contaminants of concern in groundwater.
Toxic substances may pose certain types of hazards to human and
animal populations. Typically, hazards to human health are
expressed as carcinogenic and non-carcinogenic toxic effects.
Carcinogenic risk, numerically presented as an exponential factor
(e.q., 1 x 10-6), is the increased chance a person may have in
contracting ca~cer in his or her lifetime. For example, a 1 x
10-6 risk due to a lifetime of drinking water that contains the
contaminants of concern means that a person's chance of
contracting cancer is increased by 1 in 1 million. The u.s. EPA
attempts to reduce risks at Superfund sites to a range of 1 x 10-
4 to 1 x 10-6 (1 in 10 000 to 1 in 1 million), with emphasis on
the lower end (1 x 10-~) of the scale. For this operable unit, a
risk of 1 x 10-6 is determined to be protective of human health.
The Hazard Index is an expression-of non-carcinogenic toxic
effects and measure whether a person is being exposed to adverse
levels of non-carcinogens. Any Hazard Index (HI) value greater
than 1.0 suggests that a non-carcinogen presents a potentially
unacceptable toxic effect. HIs are calculated using U.S. EPA-
verified reference doses, which are derived from no adverse
effect levels from animal experiments using safety factors tha~
range from 100 to 1,000. Thus hazard indices that only slight~:
exceed 1.0 do not cause as great a concern as those that excee~
1.0 by multiple orders of magnitude. In addition, HIs are more
significant if all of the contaminants posed risks that affec~,- :
the same target tissues.
Based on toxicological studies, 1,2 Dichloroethane,
Tetrachloroethene, and Trichloroethylene are classified as Gr~
82- Probable Human Carcinogens. There is sufficient evidence
carcinogenicity in animals but inadequate evidence of
7
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MAXIMUM fS'TAB~IS""EC ANO EST:1.IUE:
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$0,," 10.'''C
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,
-------
. .'
0'.
carcinogenicity in humans. 1,1 Dichloroethane and 1,1,2-
Trichloroethane are classified as Group C - Probable Human
Carcinogens. There is limited evidence of carcinogenicity in
animals. Arsenic, Benzene and vinyl Chloride are classified as
Group A- Human Carcinogens.
6.4
Summary of Site Risk Characterization
The Risk Assessment and an Ecological Risk Assessment performed
during the RI arrived at the following conclusions:
-No risks to human health were found due to dermal
adsorption or ingestion of leachate-contaminated soils.
-The ingestion of contaminated groundwater was found to pose
a potential risk to human health.
-Very little risk was associated with bathing in
contaminated groundwater, or inhaling contaminants while
showering with contaminated groundwater.
-The only potential ecological risk associated with the site
was direct contact or ingestion of leachate-contaminated
soils by terrestrial organisms.
Table 5 summarizes the quantitative risk estimates by media and
exposure scenario for the Metamora Landfill Site.
6.4.1 EXDosure to Soil - The Hazard Index for both scenarios was
less than 1.0, and estimated incremental cancer risks did not
exceed U.S. EPA's target range for either scenario. Cancer risk
under the worst-case assumptions is below U.S. EPA's target
range.
6.4.2 EXDosure to Groundwater throuqh Inqestion - Lifetime
incremental cancer risks exceed the upper bound of the U.S. EPA
target range for both scenarios. The majority of the risk is
attributed to vinyl chloride and arsenic. The quantitative risk
assessment results indicate that non-carcinogenic risks posed by
the most-probable scenario are not significant. In the realistic
worst-case scenario, however, the HI exceeds 1.0. The HI is 3.2
with 47 percent of the risk attributed to barium.
6.4.3 Exposure to Groundwater through Bathinq - The bath
scenario contributes a negligible level of risk relative to
ingestion. Carcinogenic risks are at the low end of the U.S. EPA
target range for both scenarios.
6.4.4
risks
level
risks
EXDosure to Groundwater throuqh Showerinq - Inhalation
due to the shower scenario exposure contributes a smaller
of risk relative to ingestion. Inhalation carcinogenic
due to showering are at the mid to high end of the U.S. E;~
8
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FIGURf 4
MAXIMUM ESTABLISHED AND ESTIMATEO HORIZONTAL EXTENT OF
ORGANIC CONTAMINATION IN THE SHAllOW AOUlFfJt
(CROSS SECTIONAL VIEw,
METAMORA lANDFILL ~,
... . _.... . , '''A'' 0 . ....., 0' ORGANIC CO'''AM'''A''OH
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. "
target range for both scenarios.
6.5
Environmental Risks
There are four areas which are considered sources of potential
exposure to contaminants originating from the Metamora Landfill
Site (Figure 5):
- The siltation pond
- Temporary pool areas
- Open field areas
- Forested areas
There appears to be relatively little risk for organisms
inhabiting the siltation pond or forested areas. only the
wildlife migrating onto the landfill site and coming into contact
with leachate-contaminated soil are at potential risk.
Table 6 identifies media of exposure, route of exposure and
populations exposed. The summary of exposure for fauna is as
follows:
-Dermal contact with, or ingestion of contaminated surface
water from the temporary pools; and
-Dermal contact with, or ingestion of, leachate contaminated
soil and leachate in the open field areas of the landfill.
6.5.1 EXDosure to TemDorarv Pools - Toxicity to freshwater
organisms could be occurring in the temporary pool due to
exposure to copper; however since these pools are temporary and
copper is not site related, the overall risk is minimal.
Terrestrial organisms may also be exposed to the copper via
ingestion or dermal contact, however toxicity data on wildlife is
lacking, making a risk determination impossible.
6.5.2 EXDosure to Leachate and Leachate-Contaminated Soils - Due
to the limited information available on the toxicity of
contaminants on wildlife, magnitude of risk cannot be determined.
There is a potential risk for terrestrial organism due to
exposure to Polyaromatic hydrocarbons (PAHs) in leachate soils.
Information suggests that avian embryos exposed to high levels of
PAHs such as those detected in the soil may experience toxic and
adverse sublethal effects.
7.0
DESCRIPTION OF ALTERNATIVES
The FS, based on the findings of the RI and Risk Assessment, has
identified and evaluated an array of remedial alternatives that
could be used to mitigate or correct the contamination problems
9
-------
--... ... .-..-----
I
..--------. .
" 0
, -
t,Uu: 5
RISK ASSESSKENT SUMMARY
K£"IAMOU. LANDFILl. SIT£. K£TAMOU. TO."NSHIP. KICHICAN
-
. -
. '. .
sumaary of Furure Potential
Incr~Dtal Carcioogen1c Risk
Seenad.o
~~st.Probable Case
Realistic Vorst.Case
Orinking Vater
hth1ng
Sho..,.r1ng
5.1 £.4
9.9 £.7
6.5 £.5
2.0 £.3
8.9 £.6
1.3 £.4
SuaDAry of Future Poteneial
Non~arciDogeui~ H&%ard Index
SceT'lari0
Host.Probable Case
~ea115t1c Vorst.Case
Orinking Yater
hthing
Sho..,er1ng
2.0 £.1
1.6 £.3
4.6 £.2
3.2 £...0
5.7 £-2
1.1 £...0
Summary of CurTent Potential
l~re.enta1 Carc1nogeni~ Risk
SceT'la~10
Most.Probable Case
~ealistie Vorst.Case
SoU Contact
1.1 £.10
1.8 £.08
Summary of Current Potential
Non~arc1nogenic Ka:ard Index
SceT'lar10
Most.Probable Case
Bealist1c Vorst.Case
SoU Contact
1.6 £.06
1.8 t.Ol.
-------
. .
0'.
, ,
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KE'I' III
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A SURFACE WATER/SEDIMENT SAMPLE
. LEACHATE SAMPLE
::~r1
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~ FORESTED AREA FIGURE 5
D FIELD/OPEN AREAS NATURAL ENVIROANMSEI,.NET~~6
THE METAMOR . ~....
r\ TEMPORAR'I' PONDED AREAS OCATIONS OF SURFACE WATERlSEDI!~E,~ S'
t!tVt.u";, MONITORINC WElL ANOlLEACHATE.CONTAMINATED SOl SAt." L-
sa.; + SOIL BORINC E.C_C~.;': . ~ -
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TABU
6
PRIMARY ROUT£S or EXPOSUR£ rOR ORCANISMS ON OR
NEAR THE HETA.'10RA lANDFIl.l. SIT£
HETAMORA LANDFIl.l. 5IT£, M£TAMORA TOUNSHIP, MICHICAN
MEDIA .. -=
OF EXPOSURE .
. ROUTE OF EXPOSURE
POPULATIONS EXPOSED
$011
Dermal contact vith
cont~inated soil/
organic lutter.
Burrov1ng ma~als.
reptiles, a~phibians.
invertebrates. and
dust-bathing birds.
Soil
Ingestion of cont&~inated
soil/organic matter.
Earthvorms and insects.
Soil
Consumption of ani~als
that have contact v1th
contaminated soil/
organic matter.
Predatory and omnivorous
m.~als, birds. reptiles.
amphibians, and insects.
Surface 1.;ater/
Leachate
De~al contact vith
contaminated vater.
Terrestrial animals.
reptiles, and amphibians.
Surface \.iaur/
l.eachate
Ingestion of cont.~inated
vater.
Most terrestrial animals.
Surface \';ater
Ingestion of reptiles,
birds and ~a"~als
cont.~inated as above.
Mammals and birds.
-------
.
. .
at the site. Since the Site is a large municipal type landfill,
the development of a complete range of options is not practical
because remedies involving treatment of wastes, or removal of the
entire site are very expensive and difficult to implement at
sites such as this. The alternatives have been separated into
two categories; 1) Groundwater (GW) Alternatives that address
the contaminated groundwater at and near the site, and 2)
Landfill (LF) Alternatives that address landfill closure.
Applicable or relevant and appropriate requirements (ARARs), such
as Federal and State regulations governing proper landfill
closure, must be considered in evaluating each of the
alternatives. The alternatives considered for the Site are
presented within the FS and are summarized below. For a more
detailed description of the alternatives, please refer to the FS
Report.
The Groundwater Alternatives that are presented below consist of
a no action alternative and pump and treat alternatives. Each of
the groundwater treatment alternatives consists of an extraction
and recharge system. The groundwater extraction system will
capture contaminated groundwater and pump the water to the
treatment system. The recharge or injection system would consist
of injecting the treated water back into the shallow aquifer
through the use of injection wells to be placed up gradient, side
gradient and down gradient of the landfill, which will facilitate
the movement of contaminated groundwater to the extraction wells
and prevent spreading of the contaminated area beyond existing
limits. The treatment of the inorganic contaminants would occur
first and then the water will be pumped to the organic treatment
system. The residuals will be tested to determine whether they
exhibit the RCRA toxicity characteristic (TC) for constituents
regulated by the Land Disposal Restrictions (LDRs). LDR
notification and certification requirements (and manifesting
requirements) will be met to ship any characteristic wastes off-
site. The off-site treatment and disposal facility will treat
and dispose of the waste in accordance with RCRA subtitle C
requirements, including LDRs. A map showing the preliminary
design of the extraction/injection system is illustrated in
Figure 6.
For all groundwater alternatives, there is a 20 year or 40 year
time frame for pumping and treating groundwater. There is some
increase in cost between the 20 and 40 year cleanup time frame.
The NCP states that the goal of Superfund's approach to
contaminated groundwater is to return usable ground waters to
their beneficial uses within a time frame that is reasonable
given the circumstances of the site. The Metamora shallow
aquifer falls under the NCP's groundwater class II B; groundwater
potentially used as drinking water. EPA's preference is for
rapid restoration of contaminated groundwater that can be used
for drinking water wherever practical. Therefore the 20 year
time frame for remediation is preferred by EPA. A shorter time
10
-------
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WEU.. SE.R.::': ;.
-------
.
D .
frame will reduce the potential for human exposure by ingestion
and be protective to human health and the environment.
7.1
GROUNDWATER ALTERNATIVES
Alternative GW-1:
No Action
The Superfund program requires that the "no action" alternative
be evaluated to establish a baseline for comparison. If no
action is taken at the site, the contaminants in the shallow
groundwater will continue to disperse until they are degraded by
natural mechanisms and dilution. This no action alternative
requires the installation of 10 additional monitoring wells. If
the No-Action alternative is selected, a five-year review of the
site will be required under Section 121(c) of SARA because the
alternative results in hazardous contaminants remaining in the
groundwater. ARARs regarding groundwater contamination would not
be met.
Estimated Construction Cost:
Estimated Annual 0 , M Cost:
Estimated 20 Year Present Worth:
$ 109,080
$ 124,000
$ 2,015,000
Alternative GW-2:
Groundwater Extraction, Ion Exchange,
UV/Oxidation, Recharge
The groundwate~- extraction component is identical for each of
the pump, treat, and discharge alternatives. It is estimated
that the extraction and injection system would utilize six
recovery wells encircled by six injection wells. The total flow
rate would be 210 gpm. Approximately four years would be
required to recover one pore volume. It is estimated that five
groundwater pore volumes will be required to achieve the Target
Clean-up levels (Table 7), therefore operating time would be
approximately 20 years. Ion exchange is utilized for the
inorganic treatment method. The collected water would be pumped
through a resin-filled column. An interchange of ions between
the insoluble resin and contaminants would occur resulting in the
removal of inorganic contaminants from the groundwater. Spent
resin would be reduced by proper off-site treatment or disposal
in compliance with Michigan Act 64/RCRA regulations. The water
would then be pumped to the UV/Oxidation organic treatment
system. UV/Oxidation chemically oxidizes organic compounds in
water with a combination of ultraviolet light (UV), ozone andie:'
hydrogen peroxide. No secondary waste stream is created. ARAr ~
would be met.
Estimated Construction Cost:
Estimated Annual 0 , M Cost:
Estimated 20 year Present Worth:
$ 2,976,920
$ 997,307
$15,405,538
11
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TABLE 7
CLEAN-UP GOALS FOR GROUNDWATER
METAMORA IANDFILL
(ppb)
Contaminant
* Arsenic
Barium
* Benzene
2-Butanone
1,1-Dichloroethane
* 1,2-Dichloroethane
1,1-Dichloroethene
trans-1,2-DCE
cis-1,2-DCE
Ethylbenzene
* Tetrachloroethene
* 1,1,2-TCA
* Trichlorethene
* Vinyl Chloride
Xylene
Michigan
Act 307
0.02
5000
1.0
350
700
0.4
0.06
140
1.0
30
0.7
0.6
3.0
0.02
20
MCL
MCLG
o
5000
o
5000
5.0
5.0
7.0
100
70
700
5.0
5.0
5.0
2.0
10,000
o
7.0
100
70
700
o
3.0
o
o
10,000
;"
Clean-up
Goal
0.C2/BKG
5000
1.0
350
700
0.4
0.06
100
1.0
30
0.7
0.6
3.0
0.02
20
-------------------------------------------------------------
* = carcinogen
MCL = Federal Safe Drinking Water Act, Maximum Contaminant Level
MCLG = Maximum Contaminant Level Goal
Act 307 = Mic~igan's Act 307, Type B, 1X10-6 Levels or Human Life
Cycle Safe Concentration Levels
BKG = Background Concentration
This chart is not conclusive, as it represents only the
contaminants identified as the contaminants of primary concern at
the time the RI was conducted.
If the best available detection limit is higher than the Clean-~p
Goal, then the detection limit will replace the stated Clean-up
Goal.
If background concentration is higher than the Clean-up Goal, t~0~
background concentration will replace the stated Clean-up Goal.
-------
. .
. .
Groundwater Extraction,
Precipitation/Flocculation, UV/Oxidation,
Recharge
This alternative utilizes the precipitation/flocculation
technology for the removal of inorganic contaminants.
Precipitation is a physiochemical process by which a substance
in solution is transformed into the solid phase. Flocculating
aids may be added to increase floc size and promote settling.
Treatability testing and trial batches prior to system design and
during start-up must be performed to determine optimum operating
conditions. The sludge end-product of this procedure would be
reduced by proper off-site disposal in compliance with Michigan
Act 64/RCRA regulations. This alternative is identical to
Alternative 2 for the organic treatment method (UV/Oxidation) and
the extraction/injection system. ARARs would be met.
Alternative GW-3:
Estimated Construction Cost:
Estimated Annual 0 & M Cost:
Estimated 20 year Present Worth:
$ 3,213,170
$ 812,073
$13,333,366
Alternative GW-4:
Groundwater extraction, Ion Exchange, Carbon
Adsorption, Recharge
This alternative is identical to GW-2 for the inorganic treatment
method (Ion Exchange) and the extraction/injection system.
However, this alternative utilizes Carbon Adsorption for the
treatment of organic contaminants. The water is pumped through a
packed column, the organic constituents adsorb to internal pores
of a carbon granule packing. Over time, the carbon packing will
lose treatment capacity and will require regeneration or disposal
at an off-site RCRA permitted facility. ARARs would be met.
Estimated Construction Cost:
Estimated Annual 0 & M Cost:
Estimated 20 Year Present Worth:
$ 2,759,064
$ 846,191
$13,304,445
Groundwater Extraction,
Precipitation/Flocculation, Carbon
Adsorption, Recharge
This alternative is id~ntical to Alternative GW-3 for inorganic
treatment (Precipitation/Flocculation) and Alternative GW-4 for
organic treatment. This alternative also utilizes the same
extraction/injection system as alternative GW-2. ARARs would be
met.
Alternative GW-5:
Estimated Construction Cost:
Estimated Annual 0 & M Cost:
Estimated 20 Year Present Worth:
12
$ 2,995,314
$ 660,957
$11,232,273
-------
Alternative GW-6:
. ..
.
0.'\
Groundwater Extraction, Ion Exchange, Air
Stripping, Recharge
The inorganic treatment method will be Ion Exchange as described
in Alternative GW-2. The organic treatment method will be Air
Stripping which is a mass transfer ot VOCs trom the liquid
(water) phase to the gas phase. Air stripping occur. in a packed
tower, contaminated groundwater enters the top ot the column
while air is blown in from the bottom. Air exiting from the top
of the column (the "off-gases") contains VOCs stripped from the
groundwater. The off-gases will be captured on granulated carbon
to meet state and Federal air stripper emission ARARs. Spent
carbon will be regenerated or disposed of at a RCRA permitted
facility. This alternative also utilizes the same
extraction/injection system as alternative GW-2. ARARs would be
met.
Estimated Construction Cost:
Estimated Annual 0 & M Cost:
Estimated 20 Year Present Worth:
Alternative GW-7:
$ 2,318,204
$ 770,512
$11,920,377
Groundwater Extraction,
Precipitation/Flocculation, Air Stripping,
Recharge
The inorganic treatment method will be Precipitation/
Flocculation as described in Alternative GW-3 and the organic
treatment will be Air Stripping as described in Alternative GW-6.
This alternative also utilizes the same extraction/injection
system alternative GW-2. ARARs would be met.
Estimated Construction Cost:
Estimated Annual 0 & M Cost:
Estimated 20 Year Present Worth:
7.2
LANDFILL ALTERNATIVES
Alternative LF-1:
No Action
$ 2,554,454
$ 585,278
$ 9,848,205
The Superfund program requires that the "no action" alternative
be evaluated to establish a baseline for comparison. Under this
alternative, no further action would take place other than
continuing on-site 'inspections and a groundwater monitoring'
program. ARARs would not be met.
Estimated Construction Cost:
Estimated Annual 0 & M Cost:
Estimated 20 Year Present Worth:
Alternative LF-2:
$
$
$
28,080
14,000
243,294
Act 64 Cover, Passive Gas Collection, Flaring
The landfill cover will comply with Michigan Act 64 requiremen~~
13
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. .
. .
consisting of a minimum of 90 centimeters of clay, a 12 inch
drainage layer" and a 12 inch layer of soil. The passive
collection system would capture off-gases generated by waste
decomposition. Gravel-filled trenches and a piping network would
be constructed to collect gas by natural mechanisms. The off-
gases would be destroyed by flaring. ARARs would be met. A
preliminary design of the landfill cap is shown in Figure 7.
Estimated Construction Cost: $ 5,395,596
Estimated Annual 0 , M Cost: $ 271,666
Estimated 20 Year Present Worth: $ 9,505,845
Implementation Timeframe: Construction of landfill cap and
passive gas collection system approximately 6 months to a
year to complete. Construction of flaring system 1-2 months.
Alternative LF-3:
Act 64 Cover, Active Gas Collection, Flaring
The landfill cap is the same design as described above. However,
this alternative considers an active off-gas collection system.
The active system involves the construction of extraction wells
to draw gas from the landfill and a piping network. The off
gases would then be destroyed by flaring. ARARs would be met.
Estimated Construction Cost: $ 5,716,035
Estimated Annual 0 & M Cost: $ 305,801
Estimated 20 Year Present Worth: $10,352,539
Implementation Timeframe: Construction of landfill cap and
Active gas collection system 9-15 months. Construction of
flaring system 1-2 months.
7.3 The FS identifies the potential applicable or relevant and
appropriate requirements (ARARs) for each of the alternatives
mentioned in sections 7.1 and 7.2 above. The major ARARs for
groundwater remedial actions are the Federal Safe Drinking Water
Act, Rules of Michigan's Act 307, promulgated July 11, 1990. The
Federal Safe Drinking Water Act is relevant and appropriate to
any groundwater contamination, assuring that no groundwater
suitable for drinking water supplies exceeds the Maximum
Contaminant Levels or Maximum Containment Level Goals. The
substantive provisions of Parts 6 and 7 of the rules promulgated
under the Michigan Environmental Response Act (Act 307) are
considered an ARAR for the remedial action to be undertaken at
this site. These rules provide, inter alia that remedial action
be protective of human health, safety and the environment, (Rule
299.5705(1». The rules specify that this standard is achieved
by a degree of cleanup which conforms to one or more of three
cleanup types (Rule 299.5707(2». A type A cleanup generally
achieves cleanup to background (Rule 299.5707); a type B cleanup
meets specified risk-based levels in all media (Rule 299.5709);
and a type C cleanup is based on a site-specific risk assessment
which considers specified criteria. u.s. EPA has decided that
14
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+
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the selected remedy will meet the criteria for a type B cleanup
for the groundwater. The EPA has further decided that for the
containment of the landfill wastes, the selected remedy will meet
the criteria for a type C clean-up since no "hot spots" of wastes
were discovered during the RI; so containment by capping is the
most feasible approach to address the release of contaminants
from the landfill. LDRs are applicable to the disposal of any
sludges or residuals produced by on-site treatment. The state
has identified Act 245 part 22 as an ARAR, and has stated that in
applying Act 307's requirements to the treated groundwater to be
reinjected to the aquifer, the remedy selected will satisfy the
requirements of Act 245. The United States disagrees that Act
245, as interpreted and applied by the State in this matter, is
an ARAR. This issue is the subject of litigation in U.s. v. Akzo
Coatinas of America, appellate case numbers 89-2902 and 89-2137,
and may be reassessed after a decision has been rendered.
Nonetheless, it is the State's judgement that the selected
remedial action for this site will provide for attainment of all
ARARs including the Michigan Water Resources Commission Act and
Part 22 Rules. The remedial action will halt the migration of
contaminated groundwater and restore the aquifer to a usable
condition. In addition, the purged water will be treated prior
to reinjection and then hydraulically contained by the purge
wells in a manner that will prevent degradation of groundwater
quality, consistent with the Water Resources Commission Act and
Part 22 Rules. For the landfill containment remedial actions,
the major ARAR of concern is Michigan's Act 64. Act 64 is
relevant and appropriate since it addresses the closure of the
landfills that have accepted hazardous wastes for disposal, such
as this Site.
8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives for the Metamora Landfill Site have been
evaluated within the FS using nine criteria. The nine criteria
are summarized as follows:
Overall Protection of Human Health and the Environment -
addresses whether or not a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced or controlled through treatment, engineering
controls, or institutional controls.
Compliance with ARARs (Applicable or Relevant and Appropriate
Requirements) - addresses whether or not a remedy will meet all
of the applicable or relevant and appropriate requirements of
other Federal and State environmental statutes and/or provide
grounds for invoking a waiver.
Lena-Term Effectiveness and Permanence - refers to the ability 0:
15
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. ,
a remedy to maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
..,
Reduction of Toxicitv. MObility. or Volume - is the anticipated
performance of the treatment technologies a remedy may employ.
Short-Term Effectiveness - addresses the period of time needed to
achieve protection, and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
Imolementability - is the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement a particular option.
~ - includes estimated capital and operation and maintenance
costs, and net present worth costs.
State Acceotance - indicates whether, based on its review of the
RI/FS and Proposed Plan, the State concurs in, opposes, or has no
comment on the preferred alternatives at the present time. The
State's acceptance is addressed later within this ROD.
Communitv Acceotance - will be addressed later within the
Responsiveness Summary.
The FS describes in detail how all the alternatives stand
seven of the nine evaluation criteria (excluding state
acceptance and community acceptance). State and community
acceptance will be discussed later in this ROD.
up to
The following briefly describes how the alternatives for the
Metamora Landfill Site stand up to the nine criteria.
8.1
Threshold criteria
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT: Each of
the groundwater treatment alternatives, with the exception of the
no action alternative, would provide protection of human health
and the environment by reducing and/or eliminating the
contaminants in the shallow aquifer in a timely manner. Public
health risks due to the potential ingestion of groundwater from
the shallow aquifer would be reduced to target clean-up levels
and the potential of the lower aquifers being impacted would be
eliminated. Alternatives 2-7 are equally protective.
Both Landfill alternatives 2 and 3 would reduce the release of
landfill leachate into the shallow aquifer. In addition, the
potential risks to terrestrial organisms posed by contact with
leachate-contaminated surface soil will be eliminated. The no
action alternative would not achieve the above. Alternatives 2
and 3 are equally protective.
16
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, .
. .
Since the no action alternatives are not protective, they will
not be considered further.
COMPLIANCE WITH ARARS: All groundwater treatment alternatives
would meet their respective applicable or relevant and
appropriate requirements of Federal and State environmental laws.
Federal drinking water standards would be achieved. The
treatment systems would be designed and operated in compliance
with ARARs.
Both landfill alternatives will meet the Michigan Act 64 closure
requirements and RCRA closure requirements by reference.
8.2
Primary Balancing Criteria
LONG-TERM EFFECTIVENESS AND PERMANENCE: Long-term protection of
human health and the environment will be provided by all the
groundwater treatment alternatives. The groundwater will be
restored to the target clean-up levels and no unacceptable
residual risk will remain in the groundwater. The Ion Exchange
inorganic treatment method would require the regeneration of
contaminated resin. The Precipitation and Flocculation inorganic
treatment method produces residual sludge which would require
offsite disposal or destruction. Carbon adsorption and Air
Stripping treatment methods would require the regeneration of
spent carbon. The UV/Oxidation treatment method produces no
secondary waste stream. All the alternatives mentioned above are
equally effective.
The landfill cap would reduce future contaminant migration into
the shallow aquifer by restricting infiltration of precipitation.
In addition, the management of landfill gas would reduce long-
term public health risks by reducing gas emissions to the
atmosphere. The landfill cover and gas cOllection/flaring system
will require long-term maintenance to ensure system
effectiveness. Since hazardous substances are remaining on-site,
a five-year review will be required under the Superfund program
to ensure protection of public health and the environment.
REDUCTION OF TOXICITY. MOBILITY OR VOLUME: The toxicity and the
volume ot the inorganic contaminants in groundwater would be
reduced with the Ion Exchange and Precipitation/Flocculation
treatment methods. Any residual wastes from these treatments
would be treated off-site. The UV/Oxidation treatment component
(GW-2 & GW-3) does not produce a secondary waste stream requiring
disposal or an air emission to treat and, therefore, would not
cause exposure risks from residuals. The Carbon Adsorption and
Air Stripping treatment methods (GW-4,5,6,7) would require the
regeneration of spent carbon. The toxicity of the organic
contaminants would be permanently reduced by the UV/oxidation
organic treatment method; and by thermal regeneration of the
17
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~
..
carbon in the Carbon Adsorption method and the carbon adsorption
unit on top of the air stripper. All of the above alternatives
are equally protective.
Since capping addresses waste through containment rather than
destruction or treatment, this criteria is not applicable to the
Landfill alternatives.
SHORT-TERM EFFECTIVENESS: It is not anticipated that the
installation and implementation of the groundwater extraction,
treatment and recharge system will impact the community or
workers. Standard health and safety measures shall be followed
by the workers. The construction timeframes of the treatment
facilities of each technology is as follows:
6-8 months
6-8 months
4-6 months
1 month
1 month with a start up
period of 2-4 weeks
It is estimated that it will take 20 years for the groundwater to
reach target clean-up levels. Alternatives 6 and 7 best meet
this criteria.
UV/Oxidation
Carbon Adsorption
Air Stripping
Ion Exchange
Precipitation/Flocculation
Landfill Alternative construction timeframes are presented in
Section 7.2 of this document.
IMPLEMENTABILITY: Each of the groundwater treatment alternatives
are easily implemented and require conventional and readily
available materials. For the Carbon adsorption technology, if
vinyl chloride is present, carbon utilization will increase
sUbstantially in order to meet target clean-up levels.
Precipitation/flocculation technology is fully developed and
commonly available for many metals. The effectiveness of this
technology in achieving target clean-up levels for arsenic and
barium can not be fully assessed without bench scale testing.
Reducing these chemicals to part-per-billion concentrations may
not be practical or cost effective using this technology.
Treatability studies are necessary prior to full-scale treatment.
Air Stripping requires the placement of a carbon adsorption unit
to catch_ott-gases. A treatability study i~ also required for
the UV/Oxidation technology.
Both landfill cap options are proven to be implementable. The
active gas recovery system is more difficult to implement than
the passive system.
COSTS: The cost estimates were prepared using costs considered
appropriate for typical construction operations. It is intended
for use in comparing the relative costs of preliminary remedial
18
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. .
. .
alternatives. Actual construction costs may vary from those
identified in section 7 of this document.
Maintenance is based on a 20-year design life of equipment,
systems and the landfill cap system. Because of the inherent
unknown timing of maintenance activities, these costs have been
proportioned on an annual basis over the anticipated design life.
Actual annual costs may vary from those identified in section 7
of this document.
The proposed alternatives are compared to each other with regard
to the criteria listed above and then when two or more remedies
achieve the same goal (ie., achieve ARARs), cost can become a
determining factor. Overall, Groundwater alternative 7 and
Landfill alternative 2 are most cost effective.
8.3
Modifying criteria
These two criteria reflect the comment and concerns of the State
and local communities on the alternatives presented to address
the Metamora Landfill contamination.
STATE ACCEPTANCE
The state of Michigan concurs with the selected remedy for the
Metamora Landfill Site (Attachment 1).
COMMUNITY ACC~PTANCE
The comments and concerns from the public regarding the Metamora
Landfill Site are addressed within the Responsiveness Summary
which is Attachment 2 to this ROD.
9.0
THE SELECTED REMEDY
Based on the findings of the RI/FS and the documents within the
Administrative Record and the results of the public comment
period, the selected remedy for the Metamora Landfill Site is
Groundwater Alternative 7 and Landfill Alternative 2. The
Selected Remedy components to be implemented include:
*
The precipitation/flocculation treatment method will
require a bench scale test during the design to
determine if the target clean-up levels can be
achieved. If it is determined that it is not
technically practical or cost effective then Ion
Exchange will be the selected inorganic treatment
method.
*
Installation, operation and maintenance of a networi
groundwater extraction wells designed to capture a:.
19
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"
,"
contaminated groundwater within and downgradient from
the Facility.
.
Installation, operation and maintenance of the
groundwater treatment system and treatment of extracted
groundwater to reduce concentrations of hazardous
substances, pollutants and contaminants prior to
discharging such extracted groundwater into the
aquifer as described in Alternative GW-7.
contamination in the Aquifer will be reduced to the
target clean-up levels that corresponds to Michigan Act
307 type B clean-up standards. Groundwater will be
pumped and treated until contaminants do not exceed an
individual excess cancer risk of 1 x 10-6 based on
Michigan Act 307 Type B clean-up and a hazard index
value greater than 1 (or comparable Michigan Act 307
HLSC). If MCLs or non-zero MCLGs are more stringent
than the Michigan Act 307 values, than they are the
clean-up levels. If background or best available
detection limit values are higher than the clean-up
levels, than they will substitute for the clean-up
levels. Collectively, these values will comply with
the 10-4 to 10-6 risk level as required by the NCP.
Monitoring of groundwater to detect hazardous
substances, pollutants and contaminants that may be
pre~ent and to document the effect of the remedial
action herein on groundwater quality.
.
*
Installation of an Act 64 Cover.
.
Installation, operation and maintenance of a landfill
passive gas collection and flaring system.
.
Installation of fencing to restrict access to areas of
the site where certain remedial measures are to be
installed.
*
Establishment of institutional controls, 1ncluding deej
restrictions to limit use of groundwater at and down
gradient from the site and to assure that future use ~~
the Site will not damage or otherwise impair the
effectiveness of the cap, gas collection and flarinq
system and groundwater extraction and injection wel:s
Estimated Costs:
.
Media
Groundwater
Landfill
Total
Cacital Cost
$ 2,554,454
S 5.395.596
$ 7,950,050
Annual Cost
$ 585,278
S 271.666
$ 856,944
Present Wo:~:-.
$ 9,848,205
S 9.505.84:
$19,354,05-
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10.0
STATUTORY DETERMINATIONS
The selected alternatives for the Metamora Landfill Site, as
listed in Section 9.0 of this ROD, meet the statutory
requirements in that they are protective of human health and the
environment, attain ARARs, utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable and have a
preference for treatment as a principal element, as described
below:
Protection of Human Health and the Environment:
The selected remedy, a combination of a groundwater and landfill
alternative, will be protective of human health and the
environment through reduction of leachate formation, and
extraction and treatment of contaminated groundwater.
Protectiveness will be achieved by capping the landfill and
assuring proper maintenance and management of landfill gases.
The cap will alleviate the direct contact threat from the site's
contents and will also help in reducing leachate generation,
thereby reducing the amount of contamination reaching the shallow
aquifer. Since untreated wastes will remain within the site, a
review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
Protectiveness will also be achieved by extraction, treatment and
injection of contaminated groundwater. Groundwater will be
pumped and treated until contaminants do. not exceed an
individual excess cancer risk of 1 x 10-6 based on Michigan Act
307 Type B clean-up and a hazard index value greater than 1 (or
comparable Michigan Act 307 HLSC). If MCLs or non-zero MCLGs are
more stringent than the Michigan Act 307 values, than they are
the clean-up levels. If background or best available detection
limit values are higher than the clean-up levels, than they will
substitute for the clean-up levels. Collectively, the clean-up
levels will comply with the 10-4 to 10-6 risk range as required
by the NCP. Treatment of the groundwater will eliminate the risk
posed by ingestion of contaminated groundwater and prevent
contamination from impacting the deeper aquifers.
No short-term risks or cross-media impacts will be caused by
implementation of this remedy.
Attainment of ARARs:
The selected remedy will be designed to meet all
or relevant and appropriate requirements (ARARs)
more stringent State environmental laws. A list
ARARs for the Metamora site is listed within the
the applicable,
of Federal and
of the probable
FS. The prima:~
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ARARs that will be achieved by the selected remedy are as
follows.
Landfill Remedy Requirements:
Federal
RCRA Closure regulations (40 CFR 264.110 At ~).
Air emissions from flaring CAA (40 CFR 50).
state
Capping requirements as stated by Michigan Act 64.
Monitoring, collection, or treatment of emissions
depending on the actual landfill gas constituents as
required by Michigan Act 348.
Subparts G, Closure and Post Closure and N, Landfills
of RCRA as referenced by Michigan Act 64.
Limitations of fugitive dust as required by BACT R336
rules 701 , 702.
Michigan Air Pollution Control Commission General Rules
(R336 Part 9).
Groundwater Remedy Requirements:
Extraction-
Construction and use
water as required by
399.
of wells for the supply of potable
SDWA (40 CFR 141) and Michigan Act
Recharge-
Federal
Groundwater recharge quality as required by SDWA (40
CFR 141.11-141.16) MCLs.
state
Mi Act 245 of 1929 (The Water Resources Commission
Act), Part 21, states the effluent discharge permitting
and monitoring requirements. (See Page 15, Section 7.3
of this ROD regarding MI Act 307 satisfying the
requirements of MI Act 245).
Treatment System-
Federal
Air emission standards as required by CAA Regs (40 CFR
50) .
Environmental Performance of Miscellaneous Treatment
units as required by RCRA (40 CFR 264 Subpart X), RCRA
Standards for Chemical, Physical and Biological
treatment units (40 CFR 265 Subpart Q).
Deed notices as required by RCRA closure regulations
(40 CFR 264.119).
Disposal of spent carbon or sludge from inorganic
,.;;:,;'
22
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treatment as required by RCRA (40 CFR 263), DOT (49 CFR
Parts 107, 171.1-171.5).
state
Air emission standards as required by Michigan Air
Pollution Control Regulations (R336, Part 201).
Disposal of spent carbon or sludge from inorganic
treatment as required by Act 64 and Michigan
transportation regs.
Deed notices as required by Act 64.
Clean-up Levels-
Federal
Groundwater remediation clean-up levels as required by
SDWA - Maximum Contaminant Levels (MCLs) (40 CFR
141.11 - 141.16).
State
Michigan Act 307 Type B (Michigan Environmental
Response Act), requires remediation of groundwater to
1x10-6 for carcinogens and for non-carcinogens, levels
representing the human life cycle safe concentration
will not be exceeded.
Cost Effectiveness:
The Selected Remedy for the Metamora Landfill Site is considered
cost effective when compared to the alternatives not chosen,
which have had a similar degree of protectiveness to the
environment and to public health. The alternatives yield results
similar to the Selected Remedy, but were not as inexpensive as
the Selected Remedy. The total cost of the Selected Remedy for
the Metamora Landfill Site is estimated at approximately 19.3
million dollars.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recoverv Technoloqies to the Maximum
Extent Practicable:
The alternative chosen represents the best balance of
alternatives evaluated to address the contamination problems
found at the Metamora Landfill Site. By extracting, treating and
recharging the contaminated groundwater, the potential health
threats to neighboring residents will be drastically reduced, if
not totally eliminated. Also, the potential of contamination
spreading to the lower aquifers is eliminated. The capping
alternative chosen is not permanent, and will require appropriate
amount of monitoring and maintenance to assure the effectiveness
of the cap. Capping the Landfill will reduce the risk of direct
contact with leachate contaminated soils and reduce the further
23
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. "
production of leachate that would further impact the shallow
aquifer. The Selected Remedy represents the maximum extent to
which permanent solutions and treatment can be practicably
utilized for this action. Due to the quantity of the Landfill
contents and the level of risk posed by them, alternatives
involvinq treatment or removal of these wastes were deemed
impracticable and were not carried forward. Treatment of the
identified source areas is beinq conducted in the onqoinq
Remedial Action at the Site.
Preference for Treatment as a PrinciDal Element:
Inqestion of contaminated qroundwater was identified in the
Remedial Investiqation as beinq the principal threat posed by
the Metamora Landfill Site. Direct contact with leachate
contaminated soils was also identified in the RI as an ecoloqical
risk. Thouqh treatment of the Landfill contents was deemed
impracticable, as described in the previous paraqraph, the
Selected Remedy does qive preference to treatment in that the
qroundwater contamination will be addressed via treatment
technoloqy. The qroundwater will be extracted and treated by air
strippinq and precipitation flocculation (GW Alternative 7) and
the Landfill will be capped with an Act 64 cover, passive qas
collection and flarinq (LF Alternative 2).
11.0
SUMMARY
The presence of qroundwater contamination and siqnificant
leachate production from the landfill at the Metamora Landfill
Site, requires that remedial action be implemented to reduce the
risk to public health and the environment. The U.S. EPA
believes, based on the RI/FS and the Administrative Record, that
the selected alternative provides the best balance of trade-offs
amonq alternatives with respect to the criteria used to evaluate
the remedies. Based on the informa~ion available at this time,
the U.S. EPA believes that the sel~:ted remedy will be
protective of human health and the environment, will attain ARARs
and will utilize permanent solutions and alternative treatment
technoloqies or resources recovery technologies to the maximum
extent practicable.
The total estimated cost for the remedial action at the Metamora
Landfill site is as follows:
Media
Groundwater
Landfill
Total
CaDital Cost
$ 2,554,454
$ 5.395.596
$ 7,950,050
Annual Cost
$ 585,278
$ 271.666
$ 856,944
Present Worth
$ 9,848,205
$ 9.505.845
$19,354,050
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ATTACHMENT 1
...~ ~cc. COMMI....
fMOWA8 J MC~
".J\I.!N( J ~IHC.UIT'
QOIIOO8I . 011'"1111
all III , KAa8lllII
IU wooo. !III" 8QIIj
o ,TEw.,.T '" 'liS
IU 'WOOOC ~"'"
STAT! Of MICHIGAN
e
JAMES J. BlAACHAAO. Govtmor
DEPARTMENT OF NATURAL RESOURCES
If TfV'!N6 , MASOfI IIUI..OIIiIO
~o to. ...
LJ.N II 1IfQ. 101' ....
o..~o , ""Let. 0ncIDt
September 27, 1990
Mr. Valdas Adamkus, Regional Administrator
U.S. Environmental Protection Agency
Region V, 5RA-14
230 South Dearborn Streit
Chi:ago, l11ino;s 60604
Dear Mr. Adamkus:
The Michigan Department of Natural Resources (MOHR), on behalf of the State of
Michigan, has reviewed the proposed Record of Decision (ROD) for the Metamora
Lanljfi11 Operable Unit 2, Lapeer County, which we received Septetllber 21, 1990.
Michigan concurs with the action described in the proposed ROO consisting of
grolJndwater extraction and treatment, containNnt of the landfl1l.
ins~lllation and operation of a passive g&S collection system, and
1ns~itutionll controls.
We ilgree that the groundwater treatment systell must I\eet the cleanup goals for
the indicator compounds that are shown on Table 7 in the proposed ROD. These
groundwater cleinup 90al$ are consistent wah Type B cleanup criteria for our
Act 307 Rules. The groundwater precipitation/flocculation cleanup method will
require a bench scale test during remedial design to determine if target
cleitnup levels can be achieved. If the bench scale test shows that
precipitation/flocculation treatment is not technically feasible or cost
effl!ctive, then ion exchange will be the selected llethud for inorganic
treittment.
The Water Resources Commission Act and the Part 22 Rules Ire applicable or
rell!vant and appropriate requirements (ARAR's) for this remedial action. It
;s the Dtpart8ent's judgement that the selected remedial action will provide
for attainment of all ARAR's. including the Water Resources Commission Act and
Part 22 Rules.
We (:oncur w1th the remaining elements of the selected remedy outlined in the
ROD. These 1ncludH:
a.
installation, operation, and maintenance of a groundwater extraction well
network to capture all contaminated groundwater w1thin and downgrad1enl
of Metamora landfill;
b.
installation, operation, and maintenance of a groundwater treatment
system to reduce concentrations of groundwater contaminants prior to
discharging back to the aquifer, and groundwater monitoring of the
shillow and deep aquifers;
"line
~".
D'
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o ~()
Mr. Valdas Adamkus
-2-
September 27. 1990
c.
installation of an Act 64 cover on the landfill;
d.
installation, operation, and maintenance of I landfill passive gas
collection and flaring system;
installation of a six-foot chain link fence around the perimeter of the
landfill, in addition to posting warning signs around the fence
perimeter; and .
e.
f.
placement of deed/use restrictions to limit the use of groundwater and to
restrict future land use that may impair the groundwater/landfill
treatment systems.
If JOU or your staff have Iny questions, please contact Mr. Gary Hoffmaster at
517-373-8195, or you may contact me directly.
Sincerely,
D'~~
Deputy Director
517-373-7917
cc:
Mr. Jonas Dikinis, EPA
Ms. Linda Hachowicz, EPA
Dr. James Truchan, MOHR
Mr. William Bradford, MONR
Mr. Peter 011i1.. MDHR
Mr. Gary Hoffmaster. MDNR/Metamora Landfill File
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~~
Met.am:lra Lan:!fill Site
MetaIlDra, Michigan
'the u.S. Errvi..ronmental Protectioo JIqercf (U.S. EPA) has gathered Wormatioo
00 the types ard extent of CD'\taminatioo foun:i, has evaluated remedi.al
treaSUreS, ard has recx:rrmerded remedial actions to adiress the oontami.natioo
foun:i at ard near the Metarrora Lan:ifill, located in the village of Metamora,
r"'~r eo.mty, Michigan. As part of the remedial action precess, a public
zreetirq was held at the Met.aItcra Tomship Hall 00 August 1, 1990, ard was
atte.rded by a1:olt 35 pec.ple. 'the purpose of the meetin; was to eJCPlain the
intent of the project, to describe the results of the Feasibility St:lz!y (FS),
ard to receive cxmnerrts fran the public. A cx:urt reporter was present to
I'e(X)rd the ploc-iirgs of the public meetin;. A copy of the transcript is
iIx:100ed in the 1dmi.nistrative Reoord.
Public participatioo in SUperfurd projects is required by the SUperfurd
Amerdments ard Reauthorizatioo Act of 1986 (SARA). O:mrents received fran the
p.Jblic are cxrISidered in the selectioo of the ~iA' actioo for the site.
'!he Responsiveness SUITInaIy serves t\IIO p.u:pcs~: To provide the u.s. EPA with
information about the oamuniq preferences ani corcems regardin:;J the
remedial al te.rnati ves and to show merri::e.rs of the oamuni ty hew their cxmnents
are incorporated into the decision-makirg precess. O:mnents not directly
relaUd to the selecti~ of the remedial alternatives have rot been aQ1resse:1
wi thin this Responsiveness SUITInaIy, which inclujes all cx:mnents relatinq to
q::erable unit one.
'Ibis ck:x::l.m3nt sunwnarizes the oral cxmnents received at the August 1, 199()
p.Jblic meetirq, ani written cxmnerrts received durirq the public cx:mtent pe.ricd
I'\.l1'U"li.n; fratl July 12, 1990, t.hI"cu3h August 28, 1990. Please refer to ~
A for a list of cx:mnentors.
'!he cx:mrents fran the oamunity have been suamarized ani Iespollded to as
follows:
Ccmne.nt t 1:
I live near the Met..aIICra Ianclfill. 'the way the gI'O.D'dwater sanples have been
oollected can not have possibly given Yo.l the informatioo you need. 'the
oontaminaticn is headirq for Jftj shallow well and the T "'r-r Q:Junty Health Dept
"is not really ~ about the water testin; out here because this is the
rNR's project." Can't the health dept. receive sate m:nies fran the
SUperfurd. I think Yo.l should let us Jcno.i mre about this before you present
a solution. We can't approve of satet.h.in; we Jcno.i nothin:;) about.
~spallse '1:
'n1e Mr:NR am U.S. EPA will OOntirJue to m:nitor your shallow well. StOJ.ld your
water bea:Ire unfit for
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provided for yt11 at no oost. '!his R:>D will clirect1y ad:1ress the
c:x:rrt:.amination within the gI"OJTdwater an:!, if installed Properly, shcW.d
prevent any contamination fran reachi.rq the residential wells. DJe to d1ange:s
in staff, c:x::I!'m.Jnications with the cx::rmun.i ty have been erratic. MI:NR and u. S .
EPA have and will be \IIOrkiIJ;J with the cxmrunity t.hrcu3h cantinJed meet.irqs
with ~ citizens.
O:mnent '2:
'!he Met.aJoora Lardfill site was listed in 1984 an:! sir£,e that time we have had
eart.hm::w~ equipnent on our Property clear~ trails an:! locatiCl'\S for
IOCni tor~ wells. After whid1 the tNR performed various tests on cur
prc::perty, ooe of whid1 involved actual c1ynami tirg. Olrrently, we have the
daily roar and snell of diesel engines diggirg barrels of toxic waste. At ooe
time we o::W.d only hear the sa.n:1 of nature, rDII at 6:00 a.m. we hear the
beep-beep of en:! loaders backi.n;J up.
We do awreciate the tireless efforts an:! professionalism of the MI:NR and
urde.rstar1d that they are performirq an extremely iJlp:>rtant seIVioe in cleani.n;
up the lanjfill. However, we wculd like to ask abo.It the rights of residents
livin; next to this lanjfill in terms of lost property values and quality of
life due to the ille;a]. actiCl'\S of U:.~ lSible parties. We feel that a
cr:iJre has been cx:mnitted an:! we are the unfortunate victims.
'nle EPA an:! MtNR have spent milliCl'\S of dollars in cleani.n; this site and
adjacent residents have suffere1 financial losses as well as the loss of the
canfort of our property. What actions can be or are beirg done criminally
arrl/or civilly against the responsible parties? Who are the respOIlSible
parties and shouldn't they, rather than taxpayers, pay for cleanup?
Response '2:
It is the goal of u.s. EPA to recxNer all past CX)St,s t.hrcu3h cx::.nsent degree or
civil suits filed against respoIlSible parties. It is also a goal of u.s. EPA
to enforce the iJrplenentatiCl'1 of rerie:tial actiCl'\S by ~ible Parties.
u.s. EPA is CUITently involved in an extensive Potentially ~ible Party
(PRP) search. PRPs are the generators and transporters of hazardous
waste/substances and the owner/qerators of the site. AR:>roxilnate1y 550
infonration requests have been sent to gather mre informatioo a'\ the type of
wastes disposed of and by W'han. As a resu1 t, 94 PRPs have been noticed of
their potential liability. PRP lists will be made available to the public
t.hrcu3h the administrative record.
O::mrent '3:
We have hearo fran scuroes, that we consider fairly reliable, that low level
ru::lear \WaSte has been deposited in the lardfill fran the local hospital, and
this is one resident, arryway, that will never be haWf until that particular
site is addresse:i.
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Respeuse '3:
'!he MrNR's investigatioos at the site have never in:ticated ru:::lear waste 'AS
present in the lanifill. If yo.J have reliable eviderx:e to the CXI"1traXY, }'O.l
shcWd disclose this Wonnatioo to the MrNR or the U.S. EPA. Excavatioo of
wastes was eliminated early in the FS because the estimated cost of the
leaedy was $200 millioo. Excavatioo is the least preferred l~ because it
au.y relocates the prc:blem. To excavate the lardfill WOJ.ld rot be cost
effective arx:l ~ larx:l di~l restrictioos wccld make di~l of such
excavatioos highly ~IOctical. 'lbere WOJ.ld also be a greater risk of
exposure in rem:1Vin;J the material fran the lardfill. '!he HI Act 64 cap will
contain lardfill wastes that are contri.b.ttin; to the gron:iwater problem at
Me!taJrI:)ra .
O::mnent '4:
What is goin:; to happen to the pr'q)erties borderirq the site durin:; an::! after
the iJli:>lementatioo of the Remedial Actioo?
Response '4:
A mre acx:urate extent of the use of neighborirq property will be cutlined in
the Remedial Design. Essentially, extractia\ or injectioo wells will be
installed in strategic locatioos SIJI"I"OUJ'di the site. Pipin;J will be laid to
ard fran these wells ~ below the frost line. Punpirq units near
these wells will be installed am will be fairly ~ive. a:nstructia'\
contractors hire:! by U. S. EPA ani MI:NR to perform \!IOrk are required to restore
any property damaged durin:;J iJrplementatioo of the reDl3dial actia\. '!he U.S.
EPA ard MI:NR will have a p..1blic ueetin;J to ni Ql"m:.Q the outcx.me of the prcp:sed
design an::l make awrq>riate ~.
O::mnent . 5:
I really don't feel that the plan YQ1 have presented is of sufficient detail
ani cc:rtprehensioo to be able to really maJrd. we siJrplified these isssJeS in order to c;ive the p..1blic
a better ~ of what we are prc::posirg to do. '!he U.S. EPA ani MrNR
will continue to r:::ome'j informatioo to the p..1blic as it is developed durirg
the Rem:!dial Design. MI:.'NR an:1 U.S. EPA feel this site has been stutied
sufficiently to prqose a remedial alternative for the site am sign a Rilac:Drd
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of Decisicrt. '!be cx:rrplete Remedial Investigaticrt Report, Feasibility Stu::tj
ard Administrative IEcord are available for review in the repository.
'}1)e follc:wirq are written cxmnent.s received fran the Potentially F2spcusible
Parties (mPs) an:! their oonsultirq fim, ani are Slm1'narized as follC'M5.
O:mnent '6:
'!be risk assessment is flawe:1. 'n1ere is 00 present risk or prOOably future
risk. '!be risk assessment e.L l a .eaJSly assurre::l ~ WOJld involve
i.rgestirq water within the 1JLD'1icipal waste lard! ill. M::>I"E!IOIIer, the
cont.ami11ants in the shallow water table will not migrate bec:ause the area of
CXJntaminatian has not been defined ard there is a 150 foot thick canfini.ng
clay layer betW1een the shallow water table ani the drinkirq water aquifer.
Vi.I1yl d'lloride shaJld not be considered in the Risk Assesslrent bec:ause it was
cnly detected in 10% of the total scmples, it was never detected in the
lard!ill, ard MrnR used an ilrproper high detecticrt limit for vinyl d'lloride
which resulted in the calOllatiat of an artificially high risk level despite
the fact vinyl chloride was not detected thra.J3ho.rt: the lardfill or JII:ISt of
the site.
Arsenic should not be considered in the risk as,:;,~~TTt bec:ause it is net
present down;radient at levels ex~ ; rg backgro.In1 levels.
Response '6:
'!be risk assessment is a basel ine risk, takirq into ac:xxAJnt o::I'1tami.naticrt
presently at the site ard evaluatirq actual or future exposure scenarioS based
at this data. As a future scenario, a residential exposure is as&JmBd ard a'1e
my place a dri.nJdrq water ~l a'1 or near the site. 0rItami.nants found in
the shallow aquifer below the lardfill present a potential risk to rot mly
nearby residents that utilize the shallow aquifer for their dr~ water
SUWly, but the epard vertically ard,Ior
horizontally. o:rn:.aminant migratiCl'\, particularly vertical migraticrt, is a
distinct p:ssibility. Althcu;Jh the Ren8iial Investigaticrt (RI) identified the
preseraa of a thick CXI'1fi.nirg clay layer between the shallow water ta}:)le and
the deeper drinJdn; water aquifer, it cxW.d not be deteImined that this clay
layer was continJous, am therefore a p:ssible raJte far ocrrt:aminants to reach
the deeper aquifer 1I'L1St be considered.
Arsenic has been detected well abcNe backgro.In1levels dowTgradient of ~
areas .
'n1e data ex>llected in the RI was analyzed by the CD1tract laboratory P.l~~am
(ClP). An lltpI'q)erly high detecticrt limit was not used since the ClP, ~ire
Analytical SeIvioes (PAS) detecticrt limit for vinyl chloride is 10 ~ for
gro..trdwa.ter. Even if vinyl chloride was ~letely eliminated fran the risk
a.sses.snent, the order of magnit::lde fran other cont.ami11ants wa.1ld drive the
o.mulative risk oot of the rarge acx:eptable in the NCP.
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0:Itment '7:
'!he Grcordwater Target Clean-up Levels ('Ias) are in:orrect because the NCP
explicitly requires the K::I.s be used unless the additive risk of the clean up
levels exceed a 10-4 risk level am that practical t.ed1nical conside.ratia1S
need to be considered, sud1 as the practical quantificatioo limit (Rn.). Ncne
of these factors requires lowerirg the 'Ias beleN the K:I.s here.
'Ihe use of methcx1 or instrozrent detectioo limits is not consistent with EPA
policy. Rather, iQIs instead of instrozrent detectioo limits, shculd be
cx:nsidered in settirg actioo levels where no teL is available.
The Mic:higan Act 307 'tYPe c risk~ cleanup should be selected for this
site.
ResponSe .7:
O:ITpreher1sive Environmental RespaISe ~tioo, an:! Liability Act (CEaA)
requires that reredial acticns carply with all requirements that are
awlicable or relevant an:! awrq>riate. 'D1erefore, a remedial actioo has to
carply with the m:::st strirqent requi.rBnent that is ~lic::able Relevant am
Apprq>riate Requ.i.reJtents (ARM) to ensure that all ARARs are attained. DJe to
the type of contaIninants found at the site, u.s. EPA and MtNR have selected
clean-up levels which OCIIply with type B clean-up starrlards. ros are below
K:I.s because Mic:higan Act 307 'tYPe B clean-up starrlards, the o::ntam.i.nant
specific AFAA for this site, are mre str~ than !CIs. F\1rther
explanations of the clean-up goals are found in sectioo 9.0 and 10.0 of the
R:>D. Provisic:ns in Act 307 type B clean:up state that the best available
detection limits will be used when a 10-6 OOI"Oantratioo is not technically
ac:hievable. Please note that the clean-up levels presented in the FS are not
Mic:higan Act 307 type B clean-up starrlards. Please refer to table 7 of this
R:>D for the 0lrrel'1t clean-up levels.
O:mnent .8
'n1e Gro.Jrdw'ater extractiCl\ and treatItent system as pI"q)OSE!d is contraIy to the
National COntin;Jency Plan (NCP), not required. by law, and is arbitrazy and
capricious.
'n1e pI"q)OSE!d grcunjwater extractiCl\ and treatment system requires treatment of
grcurdwater beneath the lan1fill, treatItent for contaIninants (ars.?1\ic and
barium) which pose no risk above local baclcgrcund based ~ Site data, and
treatment of '!as which are net justified by site oondi tia1S.
'the risk at the site is below the level accepted by EPA at many other
SUperfun::i sites. 'the extent of the grcunjwater CCI'1taminatiCl\ was net properly
measured, 1:ut was estimated usirl; a DJX1el that the NatiaW. ~ of Scierce
has specifically rejected for sud'l awlicaticns.
'Icrs were erroneo..1Sly selected. 'the grcunjwater below the landfill is net
required to be cleaned up as a matter of EPA p:>licy. 'Ihe RIfFS and Plq>osed
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Plan violate this PJlic:j by requi.r~ even the grcurdwater wi thin the
m..m:icipal lardfill to be cleaned up below drirUlementaticn of the p~ system will not reduce the risk fraD ~
grcurrlwater fraa the area because the risk asscx::iate with the bacXgro.lrd level
of naturally 0CX11ITin;J arsenic (6.9 x 10-5) in the dri.nki.rg water aquifer,
which is unaffected by the site, is greater than the reasonable worst~
risk fran tne Site.
Resp::nse '8:
Based en the risk assessment that in:licated an .in::remental carcin:genic risk
of 2.0 x 10-3, which is outside the risk range of the NCP, 'It:Is were developEd
us~ State ani Federal ARARs, whid'1ever is mre strin;Jent. SUpe.rfun:1 sites
in other states may not require as extensive clean-up standards as requirecl in
the State of Michigan, if other ARARs are not mre strin;Jent than the federal
requ.irerrents. For this site, Michigan Act 307 Type B clean-up was chce'!J'\ as
explained in the R>D. Arsenic was fCAJrd in the shallow aquifer a1 site ab:7ve
MC!s which W10lld warrant clean-up. 'n1e ~ for arsenic will be set at
backgm.JI"ld, as explained in the R>D, due to the unusually high naturally
cx:x:urrin;J levels.
The n:rle1 was s~ly used as a estimaticn of the plune ani was qualified as
such in the RI. 1d:titioo groun::lwater scmplinq is sc:hedu1ed to fully
d1aracterize the plune.
It is true that groun::lwater below the lardfill will not have to meet 'laB:
ho.ever, the NCP ani the State of Michigan requires 'It:Is to be met at the site
00urrlary an:! all PJints beya'Id. State ani Federal regulaticn; are ~ at
the 00urrlary of the site, therefore, remedial actia1 is required. 'n1e puIII)
an:l treat system will be designed to treat the cart:.aminatioo in the shallCN
aquifer to meet the State of Michigan's ard the NCP's points of oarpliara!.
Alt.ho.Jgh it is ideal for items such as p.mp tests an:! treatability stu:1ies to
be ino:>tp::)rated as part of the RI or FS, they were delayed because of the work
required for the ~irq Remedial Acticn q:erable unit 018.
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O:mnen't '9: -" '
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'Ihe p~.~' ~ '~Cap is ~"t:S the:~D; is -nOt7~ by
law an:! is atbitraxy a1d capriciaJSL.'1"'(~ardfU1, is~tcparly cMracterized
as a hazardous waste ~; ~1 site. Michigan Act "'lStahdards' reb:Wd awly
to this site and failure of the FS to consider the adequacy of Act 641 is a
fatal flaw in the report. 'Ihe ApplicatiCl\ of Act. 64 standards,...{8ther than
Act 641 st.arrlards, results in se.lectiCX'\ of a ~=Iedy whidl is ~ appropriate
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or c:cst~ffective for the site.
Re:spcnse '9:
'!he ~ has ccnsistent1y ~lied MI Act 64 to lardfills that have acDePted
hazardaJs wastes arrl have been a'I the Natiooal Priori ties List (NPL).
HetaIrora did receive haz.ardoJs waste evidenced by the thousands ot buried
dJ:uts a'I the site arrl the mirql in;J of waste fran area 4 an:! the lan:1fill. MI
Act 641 arrl Act 64 are oot cx:nsidered cx:nflictin;J requirements b.rt: aes that
are in ~c:ia'l to each other. For this site, since haz.arclo.JS wastes were
accepted for disposal am gro.,Irdwater is ocntam.inated by the wastes within the
site, Act 64 should an:! does take prece1erre CNer Act 641 if the facility has
accepted hazardous wa.stes. If the site accepted hazardous wastes after 1980,
then the Act 64 is awlicable; if the site accepted hazardcAJs wastes prior to
1980, then Act 64 is relevant an:! ~I'q)riate for the HetalTOra Ianifill, Act
64 is relevant an:! ~I'q)riate. '!his is cxnsi.stent with the requirements of
the NCP. ~~ffecti veness cx::mes into play a1ly when two remedies pe.rfor:m
siJni.larly, then the rore cost~ffective of the two weW.d be selected. In
this case, Act 641, an ~ since it deals with the closure of nmicipal solid
waste lamfills, does not achieve the stardards as set by Act 64, the ARAR
that is relevant an:! ~I'q)riate for this site sinoe the site aooepted
hazaroc.JS wa.stes.
Cr::Imer1t _10:
'!he ~ gro..1p has sroght every ORX>rtunity to ~rate with EPA to reach an
expeditic.JS cost~ffective remediatia'l of the MetaItora site. 'n1e ~ have
been hanpered in this effort because many were notified so late in the
process. We request EPA notify the manufacturers of defective tires rl;~
at the site that they are PRPs in this case. EPA has provided no raticr.a.le
for its failure to do so.
Response _10:
Since IrOSt ~ evidence was un::avere:i late in the first remedial actia'\, it
was iJTtxssible to notify PRPs of their liability arrj earlier. '!he liability
of tire manufact:ure.S is beizq looked into. 'lhis an:! other legal isc:l- will
be addressed in negotiatiaw for this operable unit.
CCmient '11:
Based upon site specific cx:n:litions am the applicatia'l of these aooeptab1e
risk levels at ather SUpe;'funi sites, it is inawrcpriate for residual risk
levels to be set at a 10-6 level for the Metarrcra Site. '!he NCP states
expl ici tly that the 10-6 level shall be used as the point of departure for
det.er1r\inin3 remediatia'\ goals for al t.ernati ves when ~ are rot available
or are not sufficiently protective because of the presence of 1IL1ltiple
contamiraants at a site or DUltiple pathways of e>q')OSUre.
Response '11:
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~ are available for this site arC have been determined to be the rules of
Midligan Act 307 type B clean-up.
0::mrerTt t 12 :
'!he exposure scenario is flawed since shallC'N aquifer wells will net be
deve1cp:d within the p~ tnm:1a.ries. 'Ihis will net ocx:ur because access
to the site will be restricted arC be cxrn:i.nually managed for years to cx:me.
Respa ISe t 12 :
A risk as-sessment considers the risk pa;ed by no actioo being taken at the
site. In order to restrict well placement, irstitutiooal ccntrols 1I11St be
ilrpleJrented. '!he NCP states that institutional ccntrols cannot replace
treatment ted1nologies as a L~:::alledy to address contaminatioo. 'Ihe
oontamination does not stq:) at the laOOfill boun:!aries. 'Ihe gro.D"rlwater needs
treatment to protect hl..DT'lan health and the environment in aa:ordanoe with the
NCP.
O:mrent #13:
It is ilTprc:par to assuIre d1emical exposure will c:xx:ur at levels which are
measured urder the site. 'Ia.s shcW.d be ~l iEd to gro.D"rlwaters at the site
bo..1rdary .
Response # 13 :
As stated before, the State of Mid1igan point of oarplianoe is defined as the
site 00Jrrlary and all points beyord. It is here, and net urder the landfill,
that 'Ia.s will be met.
Cam'ent #14:
!he NCP does not ~itate a 10-6 residual risk level for Superfun:1
cleanups. '!he 'Icrs should be consistent with u.s. EPA directives.
Response # 14 :
Clean-up sta.rrlards are consistent with u.s. EPA requirements, as stated in the
NCP, by m:etirq the rore strin;ent of state am federal ARMs.
Cam-er1t # 15 :
!he option to disd1arge extracted ~ter to a surface water body was
el ilniraated fran further consideration solely because three of the closest
surface water bodies are located at Boy Socut pI'q)8I'ty. Other surface water
bodies suitable for discharqe exist in proximity to the site. ~c:M at the
stated objectives of the this sectiat, surface water d.ischaJ:ge is net "clearly
precl\.ded" and, therefore, was eliminated prematurely. surface water
discharge should be cx::rrpared with the ~ter rec:harqe technolo;y. 'the
cx:rtparison needs to in:l\.r:ie an evaluation of whether the in=reased CX8t
associated with ~ter rec:harqe is justified by the presumed reductiat in
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aquifer cleanup tUe.
Re:spa loSe '15:
Aquifer reinjectioo is the favored d.i.scharge meth::d, but the use of a surface
water bcdy as an qJtian for rei.nj ectioo will be evaluated in the design ~.
'Ibe rore ccst~ffective c:ptioo which neets AFAPs will be ~len:e.nted.
Ccmnent 116:
The FS is inc:x:.ITi'lete in its a.sse:ssnEnt of the <:aR>irq requi.rarent for this
site. '!he lack of infonnatioo with respect to the availability of cawinq
materials needs to be acX1ressed.
Response '16:
'!he CXJ6t of clay was based 00 oonstructioo oost iIDex, am industry average.
'Ihese are estimates and can vary fran -30% to +50%. 'Ibe locatioo of a local
clay source is probable because of the area's geology. '1his walld likely
reduce costs.
O:mnent '17:
Precipi tation/floo::ulatioo wculd require disposal of sl\Dje at an off-site
Resource CorI.sezvation and Rsocvezy Act (~) facility ~ch does not ~,..
to be i.nclooed in the Appen:tix 8 cost estimates. '!he ~ has not oc:rduct..ed
an evaluatioo of di~ ~cns for the generatej sl\.dge, hew the sl\D;le
generated c:x:uld be c:lisposed, the availability of disposal capacity for the
slujge, or the cost of slujqe di~. '!his inxItplete evaluatioo may result
in inawrq:>riate Lt:.me.ly selectioo, ard ~tioo am management problems
t:l1r'ooghout the life of the L~'
Response '17:
All treatJrent systems, with the exceptiat of W/Oxidatiat, have a secxrdaly
waste stream that will have to be tested, ard perhaps treatej or disposed of
at a ~ CXlTpliant facility as required by ~ lard di~l restricticns.
'!his is repeatedly menticned in the R)[) ard the Pi.~ Plan. ']he UDJnt of
sl\X3ge generatiat requiri.n;J ~ di~l cannot be determined at this time
and, therefore, cxst estimates cannot be given.
O:mnent t 18 :
While the two conoeptual plans which are presented (system A ard system B) are
describe:! in the FS, a detailed evaluation ard cxmparisa1 between the two
alternatives is not presented. System B (the 20 year system) is eventually
selected in the PL~ Plan withc:ut adequate evaluatia'\.
RespoIISe t 18 :
'!he FS evaluated two conoeptual plans to determine the cost diffe.ren:1!S
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bet\.1een cleanirq up the aquifer 1n a shorter time frame, an:! eliminatin;
q:eration ard maintenance cxst associated with the larger tllreframe. '111e
PL~.J6ed Plan an:1 the RX) selected the shorter timeframe because the ccst
ctiffe.re1'lCe is minimal. 'l11e NCP also states that an aquifer shaUd be returned
to its natural state in the shortest timeframe practicable.
lhmPJ'1t f 19 :
'l11e FS iJrprc:perly ooncl\Des that "plume" stabil izatioo \WCW.d 1 ik.ely CICX'-Jr well
into the future au.y after site-related ocnstituents have spread CNer a
significantly larger area than is au-rently involved. '!he RI data base,
however, does oot contain arrj infonnation regard.in; the area currently
involved. '!here is 00 basis for di c:n1c:.c:.irq stabilizatioo of a "plume" until
there is good demonstration that a "plume" exists. SiJlple mathematical
m:x:1els are 00 substitute for acx::urate field data in det.e.rminin;J the prese1"O!
an:! extent of a plume.
'!he FS states that five pore volumes JIIJSt be removed to reach '!as.' It is
very unlikely that the very lOtI 'Icrs will be met at all, let alcn! after five
pore volumes. '!he 2o-year clearDJP scenario has not been substantiatBi. 'I1'1e
cost inplicatia1S for not achievin; the '!as in a 2o-year timeframe shculd be
evaluatBi .
Page 8-24 states: '''!he capital an:! annual expen:litures, as well as the time
required to achieve '!as, DUSt be evaluatBi to evaluate ~ch system can
better serve the MetaItDra Site". 'lbere is no evaluatioo presented of hew a
210 gpn system was selected. 'Ihis selectia'l is not presented in the FS. '!he
Proposed' Plan states that the shorter time period is preferred, tut there is
00 evaluation of the two.
'n1e SUIm'aI'Y states that recharge will minimize ext.ractia'l time an:! thereby
speed up remediation of the Site. 'Ihe cost of the surface water di.sd\arge
alten\ative, which was prematurely eliminated in Table 4.2, is not presented.
'Ihe time saving of rec::harge r:Ner surface water di.sd\arge is insinuatBi, tut
not evaluated. '!he evaluatia'l of the 20 an:! 40 year alternatives requires a
cost benefit analysis. surface water di.sd\arge was prematurely eliminatBi am
thus should be considerEd in the detailed analysis.
It is un:lea.r in the FS Wether W!X)r pw;e treatnent is expected to be neede'1
at this tim!. Page 8-53 says "if deemed neoe9~ry," later on Page 8-56 it
says: ''because air strippin; produces off gass that DUSt be treatBi, a vapor
~ cart:xJn adsorptia'l unit is aaBi to the system." It is not clear at this
time whether there is even a need for Yap:)r ~ treatment, as the
contaminant plume an:1 thus the mass of ccntaminants that will be re:ncved fran
the aquifer, is unknown due to the .ira..-,,,,lete RI data base. Vapor phase
c.art:a1 treatment does not arr"'1'" to be in Table B-6 capital cost estimate:
however, it does ~Ar in the anI"IJal cost. 'the anrual costs do not ~,. to
reflect cperation in a feur ~..c:tY1 climatic area.
'the laboratory stu:lies required to detezmine iCl'1 exc::harqe vs
precipitatiOl'Vflocx:ulation sha.1ld have been cx:n::h1cted as part of the FS.
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'!he report doeS net inticate whether lard disposal of the treatJterrt sl\D;Je
""ill be possible. An evaluatia'\ of alternative disposal optia'lS and the
relata1 costs is required.
Respa~ '19:
'Ihe issue of pll.UT'e def ini tia'\ is d; en \S--n in respa ISe '8.
'the 20 ard 4o-year systerrs adlieve the sarlW! goal, the difference beirg the
lerqth of tiJre required for p.mpirq and treatirq. '!he 20-year system was
d-.osen because it wo..1ld t.ake less time to remediate the aquifer. 'Ihe NCP
states that the goal of SUpe.rfurd's awroadl to ocntarninatEd gI"O.JOOwater is to
return usable gI"O.JOOwaters to their beneficial uses within a tine frame that
is reasonable given the ci.roJmst.an=es of the site. 'n1e 4C>-year system will be
considered if evidence 5Ug3eSts that the 2o-year system is not reasonable far
the site. A CU1tainment system is needed to keep oontaminatia'\ fran
spreadirq. If after a tiJre period agreed upon by the U.S. EPA in cxnsultatim
""ith the MtNR, the 'Icr.s are not met, further remediaticrt may be called far or
alternate cleaJHJp goals may be establi.she::l.
'!he FS ta..1d'\es crt the issue of surface water reinjecticrt and states it ~d
not be cost effective to utilize a surface water reinjecticrt point. As stated
before, the opticrt for surface water injecticrt will be left open for the
design phase if all ARAP.s are met.
State and Federal regulatia'lS limit the emissims fran air strippers:
therefore, a vapor (:i1ase cartx:n adsorpticrt unit would be r--<::;\ry to meet the
MW>.s as identified in the R:)[). Ccst figures for the vapor ~ carlxI1 unit
are estimates an::l may ~ baged a1 !:"""'c:t'Ir\al variatia1. '!his does net have
an inpact on selection of a gI"O.JOOwater treatment optia1, as the alternative
selectaj ..as the m::st cost effective.
'the cx:mrent a1 laboratory studies crt the inorganic treatJTent systerrs has been
addressed in respoI ~ '8.
'!he R)[) rHen~ lard~;~ opticns for treatJnent slur::qe a1 page 10.
cament '20:
'!he FS does net adequately describe the lardfill area to be c:xJVered, am does
not provide arrj details with respect to the areas to be C'A~ an:! the volume
of the fill materials' required to adlieve desired grades. CU1siderirg the
extreme ~LClPUC oon:iitions present at the site, it is ner--=-~ to provide
additional details a1 the geanetry of the OCNer system. In additicrt, there
is no mention of stormwater management of runoff fran the c:x:upletEd cap.
Lan1fill gaseS can be safely vented to the atJra;phere, as is CUIII.....1 practice
at 1rOSt landfill sites. An evaluaticrt of why flarirg is considered to be
neoE>SSary at the site should be presented.
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~espouse '20:
'Ihe lan:liill cap is sbTply illustrated in the FS arrl sane material-need
estimates are given in af:perdix B. F\Jrther details at the cap will be
addressed in the remedial design.
I&nfill gas end.ssians D1JSt be in CClTplian:=- with the ARARs identified in the
RX>. If treatment of the gas is det.ennined to be needed to c:x:mply with
ARARs, then it will be required to be iIrplenented.
o:mre.nt '21:
COsts in the PL.~ Plan for capital an:l annual oosts are imorrect.
There is an error in ~irq cx:st for the lanifill as presented in the FS.
Response #21:
~ you. for your o::mnent. 'these errors have been addressed in the RX> ard
the Administrative Record.
O::mrent #22:
'!he U.S. EPA is plaJ1J'1i.n; to designate the subsUrface soils beneath the dlum
rem:1Val areas as ~le Unit 'lhree. O:nsiderin:J that Drum Area N\mt)er 4
excavation has been cx::IT'pleted for sane time, it wculd be pnx1ent to initiate
the investigatiat of that area as socn as possible, as cxrrtami.nants ~ch are
located in these soils may be cxrrt:i.nually leached further an:l deepA..r into the
soil.
Response #22:
Drum Area 4 is OJI"I"ently urDer stu:iy and those soils requirin:J rem::wal will be
incinerated as part of ~le Unit one. 'therefore, the soils that are 1ICSt
heavily ntaminated will be removed which will minimize the leac:hin:) of
oontaminates dc:1wnward into the soil. '!he final ~ _Iedy, for the drum areas an:l
the site, can then be aairessed in Operable Unit 'lbree.
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a::M1Dn' j
~A
LISr OF ~ IXJRIH:; 'DiE RJBLIC CXM4E1fl' FERIa>
PCR 'IHE ~ u.NIFnL srm
F'R:Jt JULY 12 .~ ~r 28, 1990
~ FR:Jo1 RESII:Ern;:
mME AND AFFIUATIal
CI:M1ENl' 1:
~2:
a:t1MENI' 3:
cx::t-1MD1I' 4:
a:t1MENI' 5:
NANC'i A. RAY, RESIIENI'
~ A. ~, RESIm-n'
MR. HIGiES, RESItENI'
MR. roI»Wl, RESIIENI'
MR. HtGiES, RESIDDn'
~ FR:Jo1 PRFS:
~ 6-10:
cx:H1EN!S 11-22:
PRP - ~ IANDFIIL a:J1MITI'EE
cn5ISI'ING OF 11 PRFS,
IJ:.Tu.J< SIQIED B'i JACK D. SHUMATE
SFO~, STEERING a:J1MITI'EE.
ATrAOiMEN1'S
~-R:JVERS & AS.SCX:IATES,
GRADIDlI' CDRFOAATIal REFORI'
1Icx:H1EN!S 00 '!HE ffASIBILIT'i S'IUDY
FINM. ~ REFORI' AND PR:)K6EI) PIAN"
~ IANDFIlL SITE
IAPE:ER a::uNIY, MIOfiGAN
13
saJRCE OF ~
IEI'Im
~, DI\!ID
N:GJST 3, 1990
STA'l"fMENI' M1\IE AT 'lHE
AUGUST 1, 1990 PUE[JC
HEARIN:;
STA'l"fMENI' ~ Kr THE
AUGUST 1, 1990 ~C
HEARIN:;
STA'l"fMENI' P9t.IE Kr THE
AUGUST 1, 1990 PUBLIC
HEARJN:i
~, DI\!ID
AUGUST 28, 1990
ATrAOiMENI' 'It) ~
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