I
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United States
Environmental Protedion
Agency
Office of
Emergency and
Remedial Response
EP A/RODIR05-911158
June 1991
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Pf3 q 2. ~ Cf 6'-1 log
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oEPA
Superfund
Record of Decision:
Folkertsma Refuse, MI
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PhIladelphia; fA 19107
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REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. A8dpIenI'8 ACC888Ion No.
PAGE EPA/ROD/R05-91/158
. 1ItI8 IIId SubIIII8 5. A8part Date
3UPERFUND RECORD OF DECISION 06/28/91
Folkertsma Refuse, MI
8.
First Remedial Action - Final
7. AdIor(8) 8. Performing Organization A8pt. No.
8. Perfarming Orllalnlzatlon ...... and AdIh88 10. Proj8ctlT88klWoril Unit No.
11. ~C)orGI'8ftt(G)No.
(C)
(01
1~ 8pon8orlnll Orpnlz8t1on ...... and Add- 13. Type of A8part . PerIod Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/000
Washington, D.C. 20460 14.
15. ~tary",*-
18. Ab81r8ct (Umlt: 200 w"")
The 8-acre Folkertsma Refuse site is an inactive industrial landfill in Walker, Kent
County, Michigan. Surrounding land use is primarily industrial with a few private
residences in the vicinity. The site is partially bordered by woodlands, and
migration of contaminants has impacted a 100-year floodplain and scattered wetland
areas of Indian Mill Creek located to the south. The site overlies surficial glacial
and bedrock aquifers, both of which are used for local drinking water supplies.
Onsite features include an uncapped landfill, a man-made creek and a drainage ditch
that join and discharge to Indian Mill Creek, an office building, and three
warehouses. Prior to 1965, the site was used as a muck farm. From 1965 until 1972,
industrial wastes including foundry sand, chemical products, construction debris, and
other industrial wastes were disposed of in the onsite landfill. The primary fill
material in the landfill is foundry sand. Since 1972, the site has been operated as a
pallet repair and manufacturing facility. In 1984, EPA identified elevated
contaminant levels in the cnsite drainage ditch sediment, but not in onsite ground
water. Further investigations in 1985 and 1988 characterized onsite and offsite
(Indian Mill Creek) contamination, and determined the potential for future ground
(See Attached Page)
17. DocuiMnt An81y818 L D88cr1ptcn
Record of Decision - Folkertsma Refuse, MI
First Remedial Action - Final
Contamina~ed Media: sediment, gw
Key Contaminants: VOCs, other organics (PCBs, SVOCs), metals (arsenic,
chromium, nickel)
b. 1dentlti8r8l0p8n-EndIId T8tm8
Co COSA T1 FiIIIdIGroup
18. Availability 8111--t 18. Sea8ity CI- (Th18 Report) 21. No. of Pall"
None 74
20. Sacurity CI- (Th18 P8ge) n Prlca
I Non"'
)
110272.101
(888 ANSI-Z38.18)
See IMlnM:liona on Re-
(Formerly N11S-35)
Department of Commerce
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EPA/ROD/R05-91/158
Folkertsma Refuse, MI
first Remedial Action
- Final
_~stract (Continued)
water contamination. This Record of Decision (ROD) addresses engineering controls for
source material and management of migration of contaminated ground water as a final
remedy. The primary contaminants of concern affecting the landfilled material, sediment,
and ground water are VOCs; other organics including SVOCs and PCBs; and metals including
arsenic, chromium, and nickel.
The selected remedial action for this site includes excavating and dewatering
approximately 1,300 cubic yards of contaminated sediment from the man-made creek, the
drainage ditch, and Indian Mill Creek, and consolidating these within the landfill area;
capping the landfill area with a clay cap and revegetated soil cover installing passive
landfill gas vents, if necessary; converting the man-made creek and the drainage ditch to
permeable subsurface drains to provide for landfill surface drainage; monitoring ground
water and surface water; and implementing institutional controls such as deed and ground
water use restrictions, as well as site access restrictions such as fencing. The
estimated present worth cost for this remedial action is $1,500,000, which includes an
annual O&M cost of $58,000 for the first year. O&M costs for subsequent years were not
provided.
PERFORMANCE STANDARDS OR GOALS:
lifetime cancer risk to the 10-4
Chemical-specific clean-up goals
The remedial action is designed to reduce the
to 10-6 level and the noncarcinogenic HI < 1.
were not provided.
excess
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Folkertsma Refuse site
Walker, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for'
the Folk~rtsma Refuse Site in Walker, 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). The decision is '
based on the Administrative Record for this 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 REMEDY
This, final remedy provides for the containment of the large
volume of low leve~ organic and inorganic waste material
contained in the landfill and the contaminated muck deposit
beneath the landfill; consolidation of the contaminated sediments
of the unnamed creek, drainage ditch, and Indian Mill Creek on
the landfillf and monitoring of the contaminated groundwater
beneath the site. The risks posed by the site will be eliminated
or reduced through engineering and institutional controls.
I . .-
The major components of the selected remedy include:
o
Excavate, dewater;and consolidate on top
materials approximately 1,300 cubic yards
sediment from the unnamed creek, drainage
Mill Creek;
of the landfilled
of contaminated
ditch, and Indian
o
Convert the unnamed creek and drainage ditch into permeable
underground drains to provide for continued site drainage;
o
Install and maintain a cap over the contaminated.sedimer.ts
and landfilled a~eas in accordance with the requirements of '
the Resource Conservation and Recovery Act Subtitle D and
'Michigan Act 641; .
,
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o
Install and maintain passive gas vents on each side of the
-landfill to prevent the buildup of volatile organic
compounds and methane if necessary;
o
Install and maintain a layer of topsoil and a vegetative
covering over the landfilled areas;
o
Install and maintain a fence around the site;
o
Impos~ institutional controls such as deed re~trictions to
prevent the installation of drinking water wells within the
landfilled portion of the site and future disturbance of the
cap and landfilled materials;
o
Implement long-term groundwater and drainage water
monitoring programs to ensure the effectiveness of the
remedial action.
STATUTORY DETERMINATIONS
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 (or resource
recovery) technologies to the maximum extent practicable for this
site. However, because treatment of the large volume of low-
level organic and inorganic waste materials at the site was not
found to be practicable, this remedy does not satisfy the
statutory preference for treatment as a principal element of the
remedy.
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 hu~afi
health and the environment.
:;;;e
,.
2f : Iff!
Valdas V. Adam us
Regional Admi istra'tor
Date
2
,
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DECISION SUMMARY FOR THE RECORD OF DECISION
FOLKERTSMA. REFUSE SITE
WALKER, MICHIGAN
SITE NAME. LOCATION AND DESCRIPTION
The Folkertsma Refuse site is a former industrial landfill
located at 1426 Pannell Road, N.W. in Walker, Michigan (Figures 1
and 2). The City of Walker, which borders the northwest side of
Grand Rapids, is located in southwestern Michigan, approximately
45 miles east of Lake Michigan in Kent County.
The site is a rectangular parcel of land measuring 1,000 by 400
feet and covering approximately 8 acres. The site is generally
flat with 10 feet of vertical relief sloping from the northerrt
boundary to the southern boundary. The surface of the landfilled
portion of the site rises approximately 4 to 6 feet above the
surrounding area. The landfill is not capped and foundry sand,
the primary fill material, is exposed at the surface. However,
the northeast portion of the site has been covered with a 3 inch
layer of gravel. An unnamed creek (manmade) running along the
western property line and a drainage ditch running through the
center of the landfill join at the southern end of the site and
empty into a drain pipe. The drain pipe discharges to Indian
Mill Creek just south of the site. Fishing and swimming have
been reported to occur in Indian Mill Creek. However, Indian
Mill Creek is not a major recreational area. Indian Mill Creek,
which flows in an easterly direction, empties into the Grand
Rjver approximately 2 miles d~wnstream of the site.
The property is currently leased by a pallet repair and
manufacturing company. An office building and three warehouses
are located on the site, and stacks of pallets are organized
along ,the gravelea area. The remainder of the site is overgrown
with weeds, grass and trees and contains several pieces of junk
machinery.
The site and the properties surrounding the site are zoned for
and occupied by industry. There are, however, about ten to
twelve residenaes along the south side of Pannell Road in close
proximity to the' north end of the site. These homes obtain water
from private wells, which are upgradient from the site. There is
also a.residential subdivision approximately a quarter of a mile
north of the site. The subdivision, also upgradient of the site,
is serviced by the Grand Rapids Water Department, which obtains
its water from Lake Michigan and the Grand River. Residences
also exist south of the site, on the other side of Indian Mill
Creek. These homes are downgradient of the site. Michigan
Department of Natural Resources well records indicate that there
is only one domestic well in this area; the other residences are
serviced by the Grand Rapids Water Department. A door to door
survey conducted in 1986 did not identify any additional water
,
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~
Folkertsma
Refuse Site
Alpi
Ave .
Grand
RNer
Michigan
FIGURE 1
.! SITE AREA ~1AP
~ .
. .
. .. . ~
,
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Central
Mk:.higan
Railroad
~
Not to Scale
annell. Street
~ OtftC8
. Warehouses
e Suspected Landfill Area
. UndergrOUnd Drainage
Pipe
II Houses
Bristol
A.eut
o
Green""'-o c=J 0
c::::J
Drainage
Ditch
Rendering Transfer ..
Stabon ~.
,.
Indian Mill Creek
FIGURE 2
SITE DETAIL ~jAP
,
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wells in this area.
East of the site is a tract of undeveloped woodland which was
formerly operated as a muck farm, and the western boundary is
bordered by nursery land and greenhouses. South of the site' is a.
transfer station for a rendering company. Wetlands exist along a
second drainage ditch approximately 85 feet east of the site, and
in scattered areas along the north bank of Indian Mill Creek
downstream from the site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Prior to 1965, the Folkertsma Refuse site was operated as a muck
farm. In 1965, the owners/operators began to accept industrial
wast~ for disposal in a landfill operated on the southern two-
thirds Qf the property. Disposal activities ceased in 1972 and
the property was occupied by a pallet repair and manufacturin~
company soon after.
The landfill averages 5.8 feet in depth, with a reported maximum
thickness of 10 feet at its northern end. It is estimated that
the landfill covers 6 acres and contains approximately 57,000
cubic yards of low-level organic and inorganic waste material.
Most.of this waste material is foundry sand.
As required by CERCLA, the United States Environmental Protection
Agency (EPA) was notified of past waste disposal activities at
the Folkertsma Refuse site in 1981. A preliminary assessment was
completed in 1983. It was determined that an on-site
investigation should be conducted. In 1984, an EPA field
investigation team sampled groundwater and the sediment of the
drainage ditch. Although the groundwater was not found to be
contaminated, elevated levels of semi-volatile and inorganic
chemicals were detected in the sediment samples. In 1985, the
Michigan Department of Natural Resources (MDNR) conducted an
assessment of the. site, and reported that there was approximately
40,000 cubic yards of waste at the site, consist.ing of foundry
sand, chemical products, construction debri~ and other industrial
wastes from heavy manufacturing operations. The site was
proposed for the National Priorities List in 1986. The listing
was finalized in 1989.
Special Notice letters for the Remedial Investigation/Feasibility
Study (RIfFS) were sent to approximately 12 Potr-ntially
Responsible Parties (PRPs) in August, 1987. The PRPs did not
submit a "good faith" proposal to EPA to conduct the RI/FS.
Negotiations were formally concluded in October, 1987, and the
RI/FS was conducted by EPA.
COMMUNITY RELATIONS HISTORY
Community relations activities for the Folkertsma Refuse site
2
,
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began in October, 1988, shortly before the RI was scheduled to
b~gin. EPA conducted interviews~ith state and local officials,
a local environmental organization, and Walker residents to
determine the interest and concern over the site. A Community
Relations Plan was finalized in February, 1989. .
Fact Sheets describing RI activities were released in February
1989 and May 1989. In addition, an ava~lability session was held.
in May 1989 to meet with local residents and answer any questions
about the RIfFS. Notice of the availability session was released'.
on May 1~, 1989. ..
The RIfFS for the Folkertsma Refuse site was released to the
public in mid 1990 and was made available at two local
information repositories. The information repositories are
maintained at the Kent County Public Library and at the Walker.
Cit~ Hall. The Administrative Record is also maintained at both
of these locations.
The Propqsed Plan was released to the public in March 1991. The
public comment period opened April 1, 1991, and closed April 30,
1991. No extensions were requested. In addition, a public
meeting was held April 3, 1991. At the meeting, EPA and State
representatives discussed the results of the RIfFS and the
preferred alternative as presented in the Proposed Plan for the
.site, answered questions, and accepted public comments. Notice
of the Proposed Plan, the public comment period, the public
meeting, and the availability of the RIfFS and other site-related
documents. was published in the Advance on March 26, 1991, and in
the Grand Rapids Press on March 28, 1991. A news release
regarding this information was also made on March 27, 1991.
~ ..,
All comments which were received by EPA during the public comment
period, including those expressed verbally at the public meeting,
are addressed in the Responsiveness Summary, which is part of
this Record of De~ision.
SCOPE AND ROLE OF THE RESPONSE ACTION
This final remedy addresses the large volume of low level organic
and inorganic waste materials contained within the landfill; the
contaminated muck depos.it beneath the landfill; the contaminated
sediments of the unnamed creek, drainage ditch, and Indian Mill
Creek; and the contaminated groundwater beneath the landfill.
Unacceptable risks to human health have been calculated for the
ingestion of, direct contact with, and the inhalation of,
landfilled materials; and for the ingestion of unfiltered
groundwater beneath the landfilled portion of the site.
Unacceptable risks to the environment are posed through the
ingestion of, and direct contact with, landfilled materials and
contaminated sediments. There is also the potential for further'
groundwater contamination, and for the contaminated groundwater
3
,
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to move out from beneath the landfilled materials.
The role of this response action is to prevent current or future
exposure to the landfilled materials, the contamin'ated muck
deposit, the contaminated sediments of the unnamed creek,
drainage ditch and Indian Mill Creek, and the contaminated
groundwater beneath the landfill; to reduce contaminant migration
into the groundwater; and to prevent contaminated groundwater
from moving out from beneath the landfill.
These objectives will be achieved by containing the contaminated
landfill materials and muck deposit; consolidating the
contaminated sediments of the unnamed creek, drainage ditch and
Indian Mill Creek on the landfill; and monitoring the
contaminated groundwater beneath the landfill~ Access
restrictions (i.e. fencing) and institutional controls will also
be implemented.
SUMMARY OF SITE CHARACTERISTICS
As part of the RI, EPA collected samples of the landfilled
material, subsurface soil, groundwater, surface water, and
sediments from the site and adjacent areas. Both ,filtered and
unfiltered groundwater and surface water samples were taken.
Samples from all media were analyzed for organic and inorganic
compounds. '
GEOLOGY AND HYDROLOGY
The geology underlying the site consists of four key subsurface
units: the foundry sand fill unit, a glacial fluvial unit, a
glacial lacustrine unit, and a bedrock unit. The foundry sand
fill unit covers the southern two-thirds of the site and has an
average thickness of 5.8 feet. Beneath the fill unit is a
glacial fluvial unit consisting of a discontinuous silty
clay/muck subunit and a sand and gravel subunit. The silty clqy,
/muck subunit is ~resent only under the landfilled portion of the
site and has an average thickness of 1.5 feet. At some locations
this unit was removed prior to landfilling operations. ,The sand
subunit underlies the silty'clay/muck at the southern two-thirds
of 'the s~te and is exposed at the surface at the northern third
of the site. This sand and g~avel subunit is the major geologic
formation in the Folkertsma Refuse site area. This subunit
consists of fine to. medium sand with an average thickness of 50
feet. The glacial lacustrine unit consists of sil~ and clay, and
the bedrock unit i&'of the Bayport Limestone.
The groundwater table in the site area is encountered
approximately 4 feet below the land surface (BLS), saturating the
landfilled materials at discrete locations. Generally,
groundwater mOVement is to the south-southeast across the site,
with an average hydraulic conductivity of 1.68 ft/day.
4
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Groupdwater in the upper zones of the aquifer (less than 15 feet
BLS) discharge to the unnamed creek, drainage ditch, and India,n
Mill Creek. The deeper portions of the aquifer (greater than ~5 .
feet BLS) flow southward beneath Indian Mill Creek towards the
Grand River..
CONTAMINANT ANALYSES
The analytical results of the sampling are presented in Table 1.
Analysis of the samples indicates that the landfilled materials
contain several contaminants at concentrations above background
soil levels. The contaminants detected at the site include
volatile organic compounds (VOCs), semi-volatile organic
compounds (SVOCs), polychlorinated biphenyls (PCBs), pesticides,
and metals.
Some contaminants have migrated into the muck deposit beneath 'the
landfill, or, in areas where there is little or no muck, to a
limited extent into the sand and gravel unit. Contaminants have
also migrated into the sediments of the unnamed creek, excavated
ditch, and Indian Mill Creek. It is estimated that there are
approximately 57,000 cubic yards of landfilled waste, 12,300
cubic yards of contaminated muck, and 1,300 cubic yards of
contaminated sediment.
Contaminants were also detected above Maximum Cohtaminant Level.s
(MCLs) in unfiltered groundwater samples from beneath the
landfill. A comparison of the filtered and unfiltered
groundwater data indicates that these contaminants (arsenic and
polynuclear aromatic hydrocarbons (PARs)) are not dissolved in
the groundwater7 but rather ~orbed onto particulate matter in the
groundwater. PARs were not detected in any of the filter~~
groundwater samples, and arsenic was removed or reduced to below
acceptable intake levels when the sample was filtered. In
addition, the well in which the PARs were detected was
redev~loped and ~dditional unfiltered samples were collected.
PARs were not detected in any of the unfiltered groundwater
samples collected during this round.'
Two contaminants, beryllium and cadmium, were det~cted above
water quality criteria for freshwater in unfiltered surface water
samples collected from the drainage ditch. Beryllium was
detected above the chronic standard at one location, while
cadmium was detected above both the chronic and acute standards
at two. locations. These chemicals were not detected in any of
the filtered surface water samples, which indicates that these
chemicals are suspended in the surface water, rather than
dissolved. A third contaminant, mercury, was detected in all
filtered and unfiltered surface water samples collected from the
unnamed creek and drainage ditch. Although the levels at which
mercury was detected exceed the chronic freshwater standard
established for that chemical, the field blanks were also
5
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ANALYTICAL DATA
TABLE 1
CONCENTRATION (pPb).
MEAN1a) MAXIMUM
MEDIA
LANDFILLED MATERIALS
Methylene Chloride
Acetone
Carbon disulfide
2-Butanone
Trichloroethene
Benzene
Tetrachloroethene
Toluene I
Ethylbenzene
Xylenes
Phenol
Benzoic acid
Naphthalene
Methylnaphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Di-n-butylphthalate
Fluoranthene
pyrene
Butylbenzylphthalate
Benzo(a) anthracene
Chrysene
bis(2-Ethylhexyl)phthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
gamma-BHC
gamma-Chlordane
Aroclor-1254
Antimony I .
Calcium
Chromium
Cob a 1 'i:..
Copper
Iron
Lead
0.685
15.0
1.86
9.78
2.75
2.64
2.80
99.3
2.72
2.61
92.3
170.
332
263
170
186.
73.3
147
, 1135.
303
24.8
2,166
2,300
49.5
1,865
2,852
163
2303
211.
2032
2607
1485
1340
2.69
8.41
233.
16.8 .
8336
46.6
4.39
95.2
13,589.
60.9
9.75
560.
10.0
180.
8.00
5.00
10.0
1,800.
7.00
110.
1080.
460.
2,900.
880.
320.
2,400' 1
3,300
4,800
34,000
6,300.
46.7
27,000.
30,000.
93.0
20,000.
23,000
820
45,000
22,000.
27,000
31,000
'12,000
11,000.
48.0
15.0
2,500
16.8
59,750
2400
31.0
544
36,600
4,140
DETECTION
RATIO(b)
3/10
8/12
2/12
6/12
1/12
1/12
1/12
12/12
1/12
3/12
4/13
3/11
19/11
8/11
1/11
7/11
7/11
6/11
11/11
7/11
1/11
.11/11
11/11
1/11
10/11
11/11
7/11
10/11
5/11
10/11
6/11
6/11
6/11
2/12
2/12
3/12
1/11
10/10
11/11
416
11/11
I 11/11
11/11
,
'. .
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TABLE 1 (cont'd)
CONCENTRATION DETECTION
MEDIA MEAN MAXIMUM RATIO
LANDFILLED MATERIALS (cont'd)
Magnesium 3675 81,585 8/8
Nickel 35.2 277 8/8
Selenium 0.213 4.40 1/5
Silver 0.535 16.5 1/11
Sodium 239 980 1/3
Vanadium 15.5 28.2 3/3
SEDIMENTS
Methylene Chloride 1.85 11. 0 2/5
Acetone 39.8 120. 5/5
2-Butanone 10.6 34.0 3/5
Toluene 47.6 120. 5/5
Naphthalene 55.4 175. 2/5
2-Methylnaphthalene 101. 175. -1/5
Acenaphthylene 19.0 26.2 1/5
Acenaphthene 45.9 95.0 3/5
Fluorene 35.3 61. 5 1/5
Pentachlorophenol 336. 585 1/5
Phenanthrene 596 1250 5/5
Anthracene 71.8 235. 4/5
Di-n-butylphthalate 47.0 82.0 1/5
Fluoranthene 1722 3050 5/5
pyrene I 2244. 3600 5/5
Benzo(a) anthracene 1525 2450 5/5
Chrysene 2083 3050 5/5
bis(2-Ethylhexyl)phthalate 450 930 3/5
Benzo(b)fluoranthene 2832. 4400 5/5
Benzo(k)fluoranthene 2064. 3150 5/5
Benzo(a)pyrene 2319. 3650 5/5
Indeno(1,2,3-cd)pyrene 2242 3850 5/5 \
Dibenzo(a,h) anthracene 382 940 3/5
Benzo(g,h,i)perylene 2903 5100 5/5
gamma-BHC(Lindane) 4.53 29.0 2/5
4,41-DDE 12.6 22.0 1/5
Endosulfan II 10.6 18.5 1/5
gamma-Chlordane 9.27 26.5 2/5
Aroclor-1254 141. 245. 1/5
Arsenic 9.62 13.5 4/4
Barium 165. 235 3/3
Calcium 29,038. 51,400. 5/5
Copper 337 1,425 3/3
Iron 11,345 24,700 5/5
Lead 80.9 449 4/4
Magnesium 5,959 8,280 3/3
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TABLE 1 (cont'4)
MEDIA
SEDIMENTS (cont'4)
CONCENTRATION
~ MAXIMUM
Nickel
Zinc'
12.3
184
SHALLOW GROUNDWATER
Toluene
Naphthalen.=
Acenaphthen
Dibenzofuran 0
Fluorene
Phenanthrene
Anthracene
Fluoranthene
pyrene
Be~zo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Arsenic
Manganese
Mercury
Silver
2.57
4.96
4.84
5.00
5.64
6.00
5.22
5.86
5.68
5.25
5.29
5.19
5.07
5.11
13.7
347
0.150
8.55
DEEP GROUNDWATER
Beta-BHC
Aluminu,m
Barium
Cadmium
Copper
Iron
Lead
Manganese
Potassium
Arsenic
Mercury
0.0266
731
45.1
1. 83
14.1
1,065
2.96
9.9.9
2,454
1.12
0.136
SURFACE WATER
Beryllium
Cadmium
Chromium
Iron
Lead
Magnesium
Manganese
1.1
3.0
6.8
244
10.6
27,623
49.9
35.5
1085
21.0
5.50
3.00
5.00
8.00
45.0
10.0
36.0
26.0
14.0
14.0
13.0
9.0
12.0
287
1,740
0.430
350
0.0470
8,080
204
4.25
34.0
22,800
20.0
660 ,
3,500
12.7
0.270
6.30
8.30
38.10
440
10.6
29,800
66.a.
DETECTION
RATIO
2/3
5/5
7/15
2/16
1/16
1/16
1/16
2/16
1/16
2/16
2/16
2/16
2/16
2/16
2/16
2/16
6/8
14/14
6/14
2/11
1/10
6/7
1/2
1/12
2/3
12/12
4/8
12/12
2/2
. 4/4
4/12
1/6
2/7
. 4'/7
7/7
1/1
7/7
7/7
,
-------
"
TABLE 1 (cont'd)
MEDIA
CONCENTRATION
MEAN MAXIMUM
DETECTION
RATIO
SURFACE WATER (cont'd)
Mercury
Silver
Zinc
Trichloroethene
0.38
4.89
34.7
0~862
0.60
'13.3
45.5
2.00
7/7
1/4
7/7
1/5
Inorganic concentrations for landfilled materials and sediments are
repc:r-.ted in ppm.
OOMean concentration is the geometric mean of the data results. If the
chemical w~s not detected, the concentration was assumed to be one-half
the detection limit. If a chemical result was due to blank
contamination, the result was omitted from the mean calculation.
~)The detection ratio is the number of samples in which the chemical was
detected to the number of samples in which the chemical was analyzed.
,
-------
contaminated with equal levels of mercury. This indicates that
the levels of mercury detected in the surface water samples are
the result of contamination from the field equipment.
P01'EBTIAL XIGRATION PATHWAYS
The potential migration pathways that have been identified for
the Folkertsma Refuse site include infiltration, surface runoff,
wind erosion and dust emissions, and groundwater, surface water,
and sediment transport. However, except for the small area of
contamination in the sediments of Indian Mill Creek (immediately
surrounding the outfall pipe), contamination has not spr~ad
beyond the site boundaries. The migration of contaminants is
somewhat limited by the low water solubilities and high sorption
potentials of many of the chemicals detected at the site. These
chemicals tend to sorb onto soils and sediment, and their
mobility is decreased. Migration is also retarded by the high
total organic carbon content of the muck deposit, which averages
32% and provides a strong sorption site for most of the
contaminants. In addition, the majority of the contaminants at
the site have minimal or no volatilization potential.
SUMMARY OF SITE RISKS
A baseline risk assessment was conducted for the Folkertsma
Refuse site as part of the Remedial Investigation (Chapter 6 -
Remedial Investigation Report, PRC, June 1989). The baseline
risk assessment was conducted in accordance with the Superfund
Public Health Evaluation Manual (U.S. EPA, 1986), and the Risk
Assessment Guidance for Superfund (U.S. EPA, 1989) when
appropriate. Unacceptable risks to human health have been
identified for the ingestion of, direct contact with, and
inhalation of landfilled materials; and for the ingestion of
unfiltered groundwater from beneath the landfilled portion of the
site. Unacceptable risks to the environment are posed through
the ingestion of and direct contact with the landfilled materi~ls
and the contaminated sediments of the unnamed creek, drainage
ditch, and Indian Mill Creek. The risk assessment, which
includes the identification of site-specific contaminan~s of
concern, an exposure assessment, a toxicity assessment, and a
risk cha~acterization, is described in greater detail in the
following sections.
CONT~NANTS OF CON€ERN
Contaminants of con~ern (COCs) are those chemicals which
potentially pose the greatest risk to human health and the
environment at the site. The selection of COCs is based on the
concentration, the frequency of detection, and the toxicity and
persistence of the contaminants. The COCs at the Folkertsma
Refuse Site includeVOCs, SVOCs, PCBs, and heavy metals such as
arsenic, chromium, and nickel. Table 2 lists the specific COCs
6
,
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TABLE 2
CONTAMINANTS OF CONCERN
LANDFILLED MATERIALS
Toluene
Trichloroethene
Benzo(a) anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Crysene
Dibenzo(a,h) anthracene
Fluoranthene
pyrene
Aroclor-1254
SEDIMENTS
Toluene
Arsenic
Benzo(a) anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene
Dibenzo(a,h) anthracene
Fluoranthene
pyrene .
Aroclor-1254
SHALLOW GROUNDWATER
Toluene
Benzo(a) anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene
DEEP GROUNDWATER
t.
Arsenic
Cadmium
Manganese
Mercury
SURFACE WATER
Trichloroethene
Cadmium
Chromium
Manganese
Mercury
Chromium
Lead
Nickel
Cadmium
Lead
Manganese
Mercury
Nickel
Arsenic
Manganese
Mercury
,
-------
iden~ified for each medium (reference Table 1 for tne range of
detected concentrations).
EXPOSURE ASSESSMENT
The potential risks to human health and the environment were
calculated based on the assumption that no future remedial
actions would be taken at the site. The human populations
potentially exposed to the contamination at the site include
persons working at the site, children and young adults
trespassing on the site, and persons living and wor~ing downwind
of the site. Persons downgradient of the site who use private
wells as a drinking water supply are also potentially at risk
(only one has been identified). If a drinking water supply well
was installed at the site, or additional wells were installed
downgradient of the site, users of these wells may also become
exposed.
Animals potentially at risk include those living at or near the
site or traveling through the site. Animal populations include,
fish, amphibians and reptiles, mammals and birds. Common species
are listed in Table 3. Threatened or endangered species that may
be found in the Grand Rapids area include the per~grine falcon,
Cooper's hawk, red shouldered hawk, marsh hawk, osprey, black rat
snake, Eastern box turtle (locally common in the Grand Rapids
area), and least shrew.
The following potential routes of exposure were identified for
the human and animal ~~pulations at or near the Folkertsma Refuse
site. The pathways include exposure through ingestion, direct
contact, and inhalation and reflect both current and future
conditions.
Human Populations
o
Ingestion of , and direct contact with landfilled materials;
o
Inhalation of fugitive dusts/volatiles;
o
Ingestion of groundwater (shallow and deep zones);
o
Incidental ingestion of and direct contact with surface
water (unnamed creek, drainage ditch, and Indian Mill
Creek) ;
Direct contact' w1th sediments (unnamed
dit-ch, and Indian Mill Cr~ek).
Animal Populations
o
creek, drainage
o
I Direct contact with and ingestion of landfilled materi~ls;
7
,
- '
-------
TABLE 3
SUMMARY OF COMMON ANIMAL SPECIES
FISH
Brook trout
Brown trout
Minnows
Salmon (occasional)
Sculpin
Steelhead (occasional)
Suckers
AMPHIBIANS AND REPTILES
Spotted salamander
American toad
Mud puppy
Bullfrog
Eastern garter snake
Northern snapping turtle
Five lined skink
MAMMALS
white tail deer
Racoon
Muskrat
Eastern cottontail rabbit
BIRDS
Ring-necked pheasant
Mallard
Red-bellied woodpecker
Robin
Red-winged blackbird
I.
,
-------
o
~ngestion of and direct contact with surface water (unnamed
'creek, drainage ditch, and Indian Mill Creek);
Ingestion of and direct contact with sediments (unnamed
creek, drainage ditch, and Indian Mill Cre€k).
Intake of the contaminants of concern was evaluated for the human
populations in these scenarios under probable and worst case
conditions. Chronic intake represents the average daily dose of
"a chemical received over a lifetime and is used in conjunction
with cancer potency factors to assess carcinogenic risk. This
type of intake was calculated using parameters such as chemical
concentration, relative percent of absorption, frequency of
exposure, and body weight, as illustrated in Equations 1.1 and
1. 2 in Table 4.
o
Acute intake represents the estimated dose of a chemical received
from a 1-day exposure and is used in conjunction with allowable
daily intakes to assess risks that are noncarcinogenic. The
parameters used to calculate acute exposures are similar to those
used in deriving chronic exposure, as illustrated in Equations
2.1 and 2.2 in Table 4.
The major assumptions (e.g., body weight, frequency, and
duration) used to evaluate the chronic and acute intakes for the
identified scenarios under probable and worst case conditions are
presented in ~able 5.
TOXICITY ASSESSMENT
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)-1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The '4erm "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of hum~n
ep5.demiological studies or chronic animal' bioassays to whic~
animal-to-human extrapolation and uncertainty factors have been
applied. .
Reference doses (RfDs) have 'been developed byEPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive in~ividuals.
Estimated intakes of chemicals from environmenta~ media (e.g.,
8
,
-------
TABLE 4
EQUATION t.l - CHRONIC INTAKE
CALCULATIONS FOR CHRONIC AND-ACUTE INTAKES
Average
Lifetirn~
. bose (ug or
rng/kg/day)
=
ConcentratiE>n
in Media (rng/kg
or ug/m1)
x
Amount of
Exposure
(kg/day or
rn1/day) .
x
Relative
Percent
Absorption
x
1
Body Weight
(kg)
EQUATION 1.2 - CHRONIC INTAKE (For Direct Contact with Surface Water)
Exposure Concentration Skin Surface
Dose (ug or = in Media (ug/L) x Available for x
mg/kg/day) Contact (crn2)
Frequency of
Exposure
(days/365 days)
x
Years of Exposure
70 Year Lifetime
EQUATION 2.1 - ACUTE INTAKE
Exposure
Dose (ug or
... mg/kg/day)
Concentration
in Media (rng/kg
or ug/ml)
x
Amount of
Exposure
(kg/day or
ml/day)
Permeability
Constant x
. (cm/hr)
x
Relative
Percent x
Absorption
x
Frequency of
Contact (davs)
365 days
Duration of 1 L
Exposure (hr) x 1000 crn]
1
Body Weight
(kg)
EQUATION 2.2 - ACUTE INTAKE (For Direct Contact with Surface Water}
Exposure
Dose (ug 0"': =
mg/kg/day)
Concentration Skin Surface
in Media (ug/L) x Available for x
Contact (cm2)
Permeabil i ty
Constant
(cm/hr)
x
Duration of
Exposure (ht)
Years of
x Exposure
70 Year
Lifetime
1
x Body Weight
(kg)
x
x
1 L
1000 cm] . x
.'
1
Body Weight
(kg) "
-------
TAIIUI 5
PAMNBmIts USID .. BII'OSUIt8 D05II CAU1JIA11ONS
Fr., I8q 01 o...e Tan 01
A-, f1I P-.e ....hoc I'clftll' Bochr We"', Ib} Idln/Ia{} ""'"
AbIorn4i08 You. Y-,
6M TOIIM MtdI £1dIf M!II AM DIM AM 6fJIII DIM
(I) ...... 01 o.a...d Wa- . 11./., NA II./dIJ 100 11 NA 10 ., NA 36S 11
(1) ....... 01 SoiII .
. ..~(a)
PIUb8bIe c.. 1.S8eI1I/.., 15B.GS 11/-, I.IIE04 qJdaf 100 10 11 15 . . ..
Wone c.. 1"'11/'" 1..oBet qJdaf 2.0D.04 qJdIJ .OO 10 11 15 .. .. , 411(4
(1) DIrect 0.... .... SoIII
...... c.. ~ 1I/daf U6BeJ qJdIJ 117BeJ illdaf o.elllb' (b) 10 11 15 . . t "4)
WOII8 CaIe - 4.8Sh! 11/-, 4.8SB4J qJdaf 117BeJ qJdaf SpcdIIc 10 10 15 18 I» 14 411(4)
(4) DIrect 0.... ..., 511.,.. W.,
Prub8bie ~ J,IJO aa' NA I.- N' '.CJ08.Ot N", 10 NA 15 J (t.,~ NA J (I ."..,) .
WOII8 CaIe UJD aa' NA J,11O aaZ '.CJ06.Ot me!,' 10 NA 15 .. (I ."..,) NA.. (I ",-,) 40
(S) 18ddc.... '''''- 01 511.,.. Wiler
P...... c.. 1.11./.., NA O.OSL 100 10 NA 15 I NA I I
WOII8 c.e 1.11./.., NA O.OSL 100 10 NA 15 J NA 2 1
(') .-"~"Ioa 01 ......... o.../V........
Pmb8bIe c.. U .;,., u -~/IIr 1.4 .;/11, 100 10 11 15 n - , "4)
¥fone c.e U..,.. U-/IIr 2.1 . !', 100 11 10 15 fJ I» 14 411(4)
... (7) DiftCt 0Iat.Id wit, SedIIa.818
Prob8bIe c.. 1.278G] 11/-, NA 6.J3PAN qJdaf Ole"'" 11 NA 15 J NA J ..
WOll8 c.. 1.11NJ qJdaf NA I.IJR«J qJdIJ Spccif'1t 10 NA 15 f NA 4 40
. (iI¥:xpOf;un" dose's Wt're cCllcllJ
-------
TARLE Sa
RELATIVE PERCENT A13S0RPTJON VIA DIRECT CONTACT
. . Percent Pef'('(:nt Relative
. Absorption Via Absorption Via Percent
Contaminant Direct Contact In~stion Absorption
pen 5 30 5/30 I: 17%
Lead 1 so 1/50 l1li 2%
Arsenic 1 95 1/95 I: 1.1%
Mercury. 1 7.5 1/7.5 . 13.3%
Nickel 1 10 1/10 II: 10%
Toluene: 3 31 3/31 . 8.1%
PAIls 5 SO S/SO II: 10%
"Ollomium 0.5 26 0.5/26 - 1.92%
, 1/60 :I 1.61%
Copper I 60
Cadmiu(II 1 6 1/6 :I 11%
Manganese 1 5 1/5 = 20%
.
-------
the amount of a chemical ingested from contaminated-drinking
water) can be compared to the RfD (hazard index). RfDs are
derived from human epidemiological studies or animal studies to
Which uncertainty factors have been applied (e.g., to account for
the use of animal data to predict effects on humans). These
uncertainty" factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects
to occur.
The cancer potency factors and the reference doses used to
~uate the potential risks at the.Folkertsma Refuse site are
presented in Table 6. Arsenic, chromium, cadmium, and nickel
have been identified as human carcinogens, and PCBs,
trichloroethene, and PAHs are probable human carcinogens. These
chemicals, and the other contaminants of concern (tOluene, lead,
~, and manganese), also have the potential for causing
acute and chronic noncarcinogenic health effects in humans.
t
JUSK CHARACTERIZATION
Excess lifetime cancer risks are probabilities that are generally
expressed in scientific notation (e.g., 10-6or 1E-6). An excess
li~etime cancer risk of 10-6indicates that, as a p~ausible upper
bound, an individual has a one in a million chance of developing
cancer as a result of site-related exposure to a carcinogen .over
a 70-year lifetime under the specific exposure conditions
identified for the site. EPA seeks to manage sites such that the
carcinogenic risk from any medium generally falls within a range
o£ ~0-4to 10-6. EPA's ;reference is to be at the more protective
end of the risk range (10-6).
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quDtient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the hazard index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
Noncarcinogenic risks are considered to be unacceptable if the
hazard index is greater than 1.0, that is, if the intake of a
chemical exceeds the established reference dose for that
chem.cal.
At the Folkertsma Refuse site, unacceptable health risks have
bean calculated for exposure to the 1andfi11ed materials and the
groundwater (Table 7). The landfilled materials pose an
TInacceptable carcinogenic risk under worst case conditions for
ing~stion (10-4), direct contact (10-3), and inhalation (10-4).
9
. .
,
-------
TABLE 6
CANCER POTENCY FACTORS (CPFs) AND REFERENCE DOSES (RfDs) (a)
CPF
(mg/kg/day)
RfD
(IRq/kq/day)
INGESTION OF AND DIRECT
CONTACT WITH LANDFILLED
MATERIALS
Toluene
Benzo(a) anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene
Dibenz(a,h)anthracene
Aroclor-1254
Chromium
Nickel
_(b)
11.5(c)
11.5
11. 5
11. 5
11. 5
7.7
0.4
1.0
0.02
INHALATION OF FUGITIVE DUST
Benzo(a) anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene
Dibenz(a,h)anthracene
Aroclor-i254 '
Chromium
Nickel
6.1
6.1
6.1
6.1
6.1
7.7
41.0
0.84
1.0
INGESTION OF UNFILTERED
GROUNDWATER (shallow and deep)
Toluene
Benzo(a) anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene
Arsenic
Cadmium
Manganese
Mercury
0.3
11. 5
11. 5
11. 5
11. 5
1. 75
-"
0.001
0.0005
0.02
0.0003
INGESTION OF AND DIRECT
CONTACT WITH SURFACE WATER
Trichloroethene
Cadmium
Chromium
Manganese
Mercury'
0.011
0.09
0.0005
0.005
0.2
0.00C3
,
-------
."
TABLE 6 (cont'd)
DIRECT CONTACT WITH
SEDIMENTS
CPF
(mq/kq/day)
RfD
(mq/Jtq/day)
Toluene
Benzo (a) anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene .
Dibenz(a,h)anthracene
Aroclor-1254 .
Arsenic
Cadmium
Manganese
Mercury
Nickel
0.4
11. 5
11. 5
11.5
11. 5
11. 5
7.7
1.8
0.001
0.0005
0.2
0.0003
0.02
(a) Sources include'SPHEM, HEAST, and IRIS.
(b) Denotes not applicable.
Chemical not carcinogenic/noncar~inogenic.
(c)The .carcinogenic potency factor for all the Polynuclear Aromatic
Hydrocarbons (PAHs) is 11.5 mg/kg/day, the carcinogenic potency factor
for benzo(a)pyrene. .
,
-------
'1'ABLE 7
SUMKARY OF SITE RISKS
CARCINOGENIC RISK NONCARCINOGENIC RISK'
PROBABLE WORST PROBABLE WORST
. CASE CASE CASE C~SE
INGESTION OF 10-4
LANDFILLED MA'1'ERIALS NS* NS N$
DIREC'1' CONTACT WITH 10-3
LANDFILLED MATERIALS NS NS NS
INHALATION OF 10-4
!'OGITIVE DOST NS NS NS
\
INGESTION OF UNFILTERED 10-3 10-2
SHALLOW GROUNDWATER 1. 62 29.7
INGESTION OF UNFILTERED
DEEP.GROUNDWATE~ NS 10-4 NS 2.54
INGESTION OF SURFACE
WATER NS NS NS NS
DIRECT CONTACT WITH
SORFACE WATER NS NS NS NS
DIRECT CONTACT WITH
SEDIMENTS NS NS NS NS
-
TOTAL SITE RISK 10-3 10-2 1. 62 32.24
*NS- Not Significant. EPA defines unacceptable risks are those which exceed
a 10-4cancer risk or have a hazard index greater than 1.0.
I
-------
The ~in contaminants posing these risks are PAHs (ingestion and
direct contact) and chromium (inhalation). No unacceptable
health risks were identified for exposure to the landfilled
materials under probable case conditions. '
The ingestion of unfiltered shallow groundwater poses
unacceptable carcinogenic and noncarcinogenic risks under
probable and worst case conditions. The ingestion of unfiltered
shallow groundwater presents for probable and worst case
conditions a 10-3 and 10-2risk, respectively. The ,Hazard Indices
calculated for the ingestion of unfiltered shallow groundwater
for probable and worst case conditions are 1.62 and 29.7~
respectively. The ingestion of unfiltered deep groundwater poses
unacceptable carcinogenic and noncarcinogenic, risks under worst
case conditions. The carcinogenic and noncarcinogenic risks
calculated for the ingestion of unfiltered deep groundwater under
worst case conditions are 10-4and 2.54, respectively. These
risks are based on the high levels of arsenic detected in the
unfiltered samples from beneath the landfill, ,and on the
concentrations of PARs detected in unfiltered samples from
beneath the landfill. As these chemicals were found to have low
mobility potentials and were not detected in downgradient
samples, the risks are limited to the ingestion of, unfiltered
groundwater from beneath the site.
The landfilled materials and th~ contaminated sediments of the
unnamed creek, drainage ditch, and Indian Mill Creek pose an
unacceptable risk to the environment through ingestion and direct
contact. These risks are posed to the animal populations living
at or near the site (refer to "Exposure Assessment," p. 5 for
specific species) who may wade or swim in the streams, or walk,
lay, or burrow in. the landfilled materials. These risks will not
be significant if exposure i~ infrequent. Frequent exposure,
however,. may result in the bioaccumulation of trichloroethene,
PCBs, and metals (arsenic, cadmium, chromium, lead, mercury,
manganese, and ni~kel).
f .
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
se~ected in this Record of Decision (ROD), may present an
imminent'and substantial endangerment to human health, welfare,
or the environment.
DESCRIPTION OF ALTERNATIVES
Based on the resul~s of the Remedial Investigation and Baseline
Risk Assessment, a Feasibility study was conducted to identify
and evaluate different alternatives for protecting human hea:th
and the environment from the unacceptable risks posed at the
Folkertsma Refuse site. The remedial action objectives for the
site is to prevent current or future exposure to the landfilled
10
,
-------
materials, the contaminated muck depos~t, the contaminated
sediments of the unnamed creek, drainage ditch and Indian Mill'
Creek, and the contaminated groundwater beneath the landfill; to
reduce contaminant migration into the groundwater; and to prevint
contaminated groundwater from moving out from beneath the
landfi~l and beyond the waste boundary. .
The Feasibility study identified nine remedial alternatives,
including the no action alternative, for protecting human health
and the environment from the unacceptable risks posed at the
site. The alternatives that were considered involved a variety
of containment, removal, and treatment technologies, and are
described in greater detail in the following sections.
ALTERNATIVE 1:
NO ACTION
The NCP requires that the no action alternative be considered ,at
every Superfund site. Under this alternative, EPA would take no
further action to control the source of contamination. Long-term
monitoring of the site, however, would be necessary to monitor
contaminant migration. Monitoring would be implemented by using
the previously installed groundwater monitoring wells.
Capital Cost: $ 99,000
1st Year O&M: 49,000
Present Worth: $ 561,000
Time to Implement: 0 months
ALTERNATIVE 2:
CLAY CAP
with this alterhative, the contaminated sediments of the unnamed
creek, drainage ditch, and Indian Mill Creek (approximate:~' 1,300
cubic yards) would be excavated, dewatered, and consolidated on
top of the landfilled materials. The filtrate from dewatering
will be collected, sampled, and discharged to Indian Mill Creek.
If the contaminant concentration in the filtrate exceeds federal
or state standards, the filtrate will be treated prior to
discharge. The contaminated sediments, the landfilled materials,
and the contaminated muck deposit beneath the lanQfill
(approximately 70,600 cubic yards) would be contained with a
compacted laye~ of clay. The low-permeability cap would be
constructed over. the landfilled areas in accordance with the
Resource Conservation and Recovery Act (RCRA) Subtitle D and the
Michigan Solid Waste Management Act (MSWMA 641). The capped
areas ~ould be covered with a layer of topsoil and revegetated.
The unnamed creek and drainage ditch would be converted to
permeable underground drains to provide for continued site
drainage, and the capped areas would be graded to direct surface
runoff into the drains. Gas vents would be installed on each
side of the landfill if necessary to prevent the buildup of
volatile organic compounds and methane. The site would be fenced
11
,
-------
to r~strict access, and institutional controls such 'as deed
restricti9ns would be imposed to prohibit the installation of
water wells within the landfilled portion of the " site and any
activities that might disturb the cap or the landfilled
materials. -In addition, long-term monitoring of the groundwater
and the drainage water from the underground drains would be
conducted. "
Capital Cost: $ 990,000
1st Year O&M: 58,000
Present Worth: $ 1,500,000
Time to Zmp1ement:
3 to 5 months
ALTERRATZVE 3:
CONCRETE CAP
This alternative is the same as Alternative 2, except a layer of
con6rete would be substituted for the layer of clay. As with
Alternative 2, the contaminated sediments of the unnamed creek,
drainage ditch and Indian Mill Creek (approximately 1,300 cubic
yards) would be excavated, dewatered, and consolidated on top of
the landfilled materials. The filtrate from dewatering will be
collected, sampled; and discharged to Indian Mill Creek. If the
contaminant concentration in the filtrate exceeds federal o~
state standards, the filtrate will be treated prior to discharge.
An impermeable concrete cap would be const~ucted over the
landfilled areas to contain the contaminated sediments,
landfilled materials, and the contaminated muck deposit beneath
the landfill (approxi~~tely 70,600 cubic yards). The unnamed
creek and drainage ditch would be converted to permeable
underground drains to provide for continued drainage of the site,
and the capped areas would allow for surface runotf to drain into
the drains. Gas vents would be installed on each side of the
landfill if necessary to prevent the buildup of volatile organic
compounds and methane. The site would be fenced to restrict
access, and institutional controls such as Qeed restrictions
would be imposed to prohibit the installation of water wells
within the landfilled portion of the site and any activities that
might disturb the cap or landfilled materials. In addition,
long-term monitoring of the groundwater and the drainage water
from the underground drains woulQ be conducted.
Capital Cost: $ 2,700,000
1st Year O&M: 58,000
Present Worth: $ 3,30P,000
Time tO~Imp1ement:
3 to 5 months
ALTERNATIVE 4:
EXCAVATE/OFF-SITE DISPOSAL AT RCRA SUBTITLE D
SOLID WASTE LANDFILL
With this alternative, the landfilled materials (approximately
12
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57,000 cubic yards), the contaminated muck deposit beneath the
landfill (approximately 12,300 cubic yards), and the contaminated
sediments~of the unnamed creek, drainag~ ditch, and Indian Mill
Creek (approximately 1,300 cubic yards) would be excavated and
transported to an off-site RCRA su~title D solid waste landfill
for containment. The contaminated sediments would be dewatered
prior to transport. The filtrate from dewatering will be
collected, sampled, and discharged to Indian Mill Creek. If the
contaminant concentration in the filtrate exceeds federal or
state standards,-the filtrate will be treated prior to discharge.
The excavated areas would be backfilled and restored. The
western portion of the site would be covered with topsoil and
revegetated; the eastern portion of the site would be covered
with a layer of gravel similar to original conditions. The
unnamed creek and the drainage ditch would be converted to
permeable underground drains to provide for continued site
drainage. The surface of the backfilled areas wou~d be graded to
direct surface runoff into the drains. A temporary fence would
be installed to restrict access during implementation.
Capital Cost: $ 9,500,000
1st Year O&M: 0
Present Worth: $ 9,500,000
Time to Implement:
6 to 12 months
ALTERNATIVE 5:
EXCAVATE/OFF-SITE DISPOSAL AT RCRA SUBTITLE C
HAZARDOUS WASTE LANDFILL
This alternative is the same as Alternative 4, except that the
landfilled materials (approximately 57,000 cubic yards), the
contaminated muck deposit beneath the landfill (approximately
12,300 cubic yards), and the contaminated sediments of the
unnamed creek, drainage ditch, and Indian Mill Creek
(approximately 1,300 cubic yards) would be transported to an off-
sitelRCRA Subtitle C hazardous waste landfill for containment.
The contaminated 'sediments would be dewatered prior to transport.
The filtrate from dewatering will be collected, sampled, and
discharged to Indi~n Mill Creek. If the contaminant . ~
concentration in the filtrate exceeds federal or state standards,
the filtrate will be treated prior to discharge. As with
Alternative 4, the excavated areas would be backfilled, and the
site restored. .The western portion of the site would be covered
with topsoil and revegetated; the eastern portion of the site
would be covered with a layer of gravel similar to original
conditions. The unnamed creek and the drainage ditch would be
converted to permeable underground drains to provide for
continued site drainage. The surface of the backfilled areas
would be graded to direct surface runoff into the drains. A
temporary fence would be installed to restrict access during
implementation.
13
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Capital Cost: $ 22,700,000
1st Year O&M: 0
Present Worth: $ 23,000,000
Time to Implement:
6 to 12 months
ALTERNATIVE 6:
EXCAVATE/THERMALT~ATMENT/ON-SITE DISPOSAL
Under this alternative the landfilled materials (approximately
'57,000 cubic yards), the contaminated muck deposit beneath the
landfill (approximately 12,300 cubic yards), and the contaminated
sediments of the unnamed creek, drainage ditch, and Indian Mill
Creek (approximately 1,300 cubic yards) would be excavated and
thermally treated. The contaminated sediments would be dewatered
prior to treatment. The filtrate from dewatering will be
collect~d, sampled, and discharged to Indian Mill Creek. If the
contaminant concentration in the filtrate exceeds federal or
state standards, the filtrate will be treated prior to discharge.
It is expected that most of the organic contaminants would be
destroyed in the process, as a permitted incinerator is required
to achieve a destruction and removal efficiency of 99.99 percent.
The heating value of the waste materials has not yet been tested,
but it is estimated to be low (approximately 1,000 to 2,QOO
Btu/lb). Results from the trial burn and EP toxicity analyses
during site remediation would determine if the treatment
residuals require additional treatment (e.g., sOlidification)
prior to disposal.
The treatment residuals (approximately 56,000 to 64,000 cubic
yards) would be used as backfill material for the excavated
areas. Prior to being placed in the excavated areas, the treated
material would be analyzed to determine if it exhibits any
characteristics of a hazardous waste under RCRA. Although it is
not anticipated, further remedial actions (e.g., sOlidification)
may be needed if the residual material is found to be a
characteristic wa~te. The excavated area would be backfil~ed,
covered with topsoil and seeded. As with the otper alternatives,
the unnamed qreek and the drainage ditch would be converted into
underground drains to provide continued site drainage. The
surface of the backfilled areas would be graded to direct surface
runoff ,into the drains.
f .
As the treatment residuals would be disposed of on-site, fencing
would be Installed to restrict access, and institutional controls
such as deed restrictions wquld be imposed to prohibit the
installation of water wells within the backfilled portion of the
site and any activities that might disturb the treatment
residuals. In addition, long-term monitoring of the groundwater
and the drainage water from the underground drains would be
conducted.
Capital Cost:
$ 38,900,000 .
14
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"1st Year O&K: 49,000
Present Worth: $ 39,000,000
~ime to ~plement:
30 to 36 months
AL1fED1A'1'~ 7:
EXCAVATE/SOLIDIFY/ON-SITE DISPOSAL
This alternative involves excavating the contaminated landfilled.
materials (approximately 57,000 cubic yards), the contaminated
muck deposit beneath the landfilled materials (approximately
12,300 cubic yards) and the contaminated sediment of the unnamed'
creek, drainage ditch, and Indian Mill Creek (approximately 1,300
cubic yards), and solidifying the materials. The contaminated
sediments would be dewatered prior to solidification. The
filtrate from dewatering will be collected, sampled, and
discharged to Indian Mill Creek. If the contaminant
concentration in the filtrate exceeds federal or state standards,
the filtrate will be treated prior to discharge. The
solidification process would be conducted on site.
Several solidification processes have been demonstrated and
evaluated at other Superfund sites as part of EPA's Superfund
Innovative Technology Evaluation (SITE) program. The HAZCON and
the Soliditech processes are two examples of solidification
processes that might be used for this alternative. The HAZCON
.process is .a cement-based process in which the contaminated
material is' mixed with cement. The Soliditech process mixes the
contaminated materials with cement, fly ash, or kiln dust, and
incorporates a reagent into this mixture. The mixture may then'
be pumped or poured back into.the excavated area for curing, or
placed into forms for curing. There are less handling
requirements if the mixture is disposed of directly into the
excavated area rather than placed into forms for curing. The
strength of the solidified mass may be less.
The additives in the HAZCON and Soliditech processes will
increase the volume of materials. The HAZCON process, using
equal ratios by weight of.waste and cement, has been found to
result in an average volume increase of 120 percent. .The
Soliditech process, which uses a 2:1 ration by weight of waste to
cement, was .found to result in an average volume increase of 22
percent. .' .
As with the other alternatives, the unnamed creek and drainage
ditch would be converted into permeable underground drains to
provid~ continued site drainage, and the surface of the
solidified areas would be sloped to direct runoff into the
undergrQund drains.
site access would be controlled by fencing, and institutional
controls such as deed restrictions would be imposed 'td prohibit
the installation of water wells'within the solidified portion of
15
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the site and any activities that might disturb the solidified
materials. In addition, long-term monitoring of the groundwater
and the drainage water from the underground drains would be "
conducted. . ,
~. .
Capital Cost: $ 22,900,000
1st Year O&M: . 49,000
Present Worth: $ 23,000,000
Time to Implement:
3 to 6 months
ALTERNATIVE 8:
IN-SITU STABILIZATION/SOLIDIFICATION
With this alternative, the contaminated sediments of the unnamed
creek, drainage ditch, and Indian Mill Creek (approximately 1,300
cubic yards) would be excavated, dewatered, and consolidated on
top of the landfilled materials. The filtrate from dewatering
w1ll be collected, sampled, and discharged to Indian Mill Creek.
If the contaminant concentration in the filtrate exceeds federal
or state standards, the filtrate will be treated prior to .
discharge. The contaminated sediment, the landfilled materials
(approximately 57,000 cubic yards), and the contaminated muck
deposit beneath the landfilled materials (approximately 12,300
cubic yards) would then be solidified by an in-situ
stabilization/solidification process which involves injecting and
mixing a grout-like agent into the materials. .
The Geo-Con Deep Soil Mixing (DSM) system is one example of an
in-situ stabilization/solidification process that might be used. '
The grouting agent produces a complex crystalline network of
inorganic polymers. The polymers reportedly have a high
resistance to acids and other naturally existing deteriorating
factors. Structural bonding, in the polymers is mostly covalent.
There is'a two-phased reaction, in which the toxic elements and
compounds are complexed: first in a fast-acting reaction, and
then permanently by t~e building of macromolecules, which f .
generate over a long period of time. The mixing and injection
system consists of one set of cutting blades and two sets of
mixing blades attached to a vertical drive auger, which -rotates
at ,approximately 15 revolutions per minute. Two conduits in the
drive rod are used to inject the grouting agent at the bottom of
the shaft. The agent is injected as. the auger is advanced into
the contaminated material. Further mixing occurs as the auger is
withdrawn. The grouted soil columns are 36 inches in diameter
and are positioned in an overlapping pattern.
,.
As with the other alternatives, the unnamed creek and drainage
ditch would be converted into underground drains to provide
continued site drainage, and the surface of the
stabilized/solidified areas would be graded to direct surface
runoff into the drains. Access would be controlled by site
fericing, and institutional controls such as deed restrictions
16
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would be imposed to prohibit the insta£lation of water wells
within the stabilized/solidified portion of the site and any
activities that might disturb the stabilized/solidified ; .
materials. In addition, long-term monitoring of the gro~ndwater
and th~'drainage water from the und~rground drains would be
conducted. "
capital Cost: $ 16,300,000
1st Year O&M: 49,000
Present Worth: $ 17,000,000
Time to Implement:
10 to 16 months
ALTERNATIVE 9:
IN-SITU VITRIFICATION
with this alternative the contaminated sediment of the unnamed
creek, drainage ditch, and Indian Mill Creek (approximately 1,300
cubic yards) would be excavated, dewatered, and consolidated on
top of the eastern portion of the landfill. The filtrate from
dewatering will be collected, sampled, and discharged to Indian
Mill Creek. If the contaminant concentration in the filtrate
exceeds federal or state standards, the filtrate will be treated
prior to discharge. As a thickness of 9 to 10 feet is needed to
optimize the efficiency of vitrification, the fill material and
the underlying muck deposit in the western portion of the
landfill (approximately 17,500 cubic yards) would be excavated
and consolidated on the eastern portion of the landfill. This
would bring the thickness of the contaminated materials to 10
feet. The landfilled materials, the contaminated muck deposit
beneath the landfill, and the contaminated sediments of the
unnamed creek, drainage ditch, and Indian Mill Creek would be
vitrified in-situ with an innovative technology that destloys
organic contaminants and immobilizes inorganic contaminants in a
vitrified mass. Due to the high permeability of the foundry sand
fill material, in-situ vitrification is not effective for
treating contaminated material below the water table. A trench
drain would be installed upgradient of the site to divert and
lower the elevation of ground water during vitrif~cation.
The Geo-Safe process is one example of a process that might be
used. with this process, four electrodes are i~serted into the
soil down to the' bottom of the contaminated material. A
conductive mixture of flaked graphite and glass frit is usually
placed, among the electrodes to act as the starter path for the
electrical circuit. Heat from the high current of electricity
passing through the electrodes and graphite creates a melt. The
graphite starter path is eventually consumed by oxidation, and
the current is transferred to the molten soil, which is not
electrically conductive. As the melt grows downward and outward,
it incorporates nonvolatile elements and destroys organic
components by pyrolysis. The pyrolyzed byproducts migrate to the
17
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surface of the vitrified zone, where they combust in the presence
of oxygen. Inorganic materials are dissolved into or are
encapsulated in the vitrified mass. Convection currents within
the melt uniformly mix materials that are present in the soil.
When the electric current ceases, the molten volume cools and
solidifies. The off-gasses and combustion products are drawn
from the hood into a treatment system and treated.
The unnamed creek and drainage ditch would be converted into
underground drains to provide continued site drainage, and the'
surface of the vitrified area would be graded to direct surface
runoff into the drains. Access would be controlled by site
fencing, and institutional controls such as deed restrictions
would be imposed to prohibit the installation of water wells
within the vitrified portion of the site and any activities that
might disturb the vitrified materials. In addition, long-term
monitoring of the groundwater and the drainage water from the
underground drains would be conducted.
Capital Cost: $ 42,200,000
1st Year O&M: 0
Present Worth: $ 42,200,000
Time to Implement:
27 to 30 months
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives developed in the FS were evaluated,
using the following 9 '~riteria. The advantages and disadvantages
of each alternative were then compared to identify the
alternative providing the best balance among these 9 criteria.
o
,
Overall protection of human health and the environment --
Addresses whether 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 -- Addresses whether a remedy will
meet all of the applicable or relevant and appropriate
requirements (ARARs) of other Federal a~d state
environmental statutes and/or provide grounds for invoking a
waiver.
o
o
Long-Term Effe~t~veness and Permanence -- Addresses the
magnitude of residual risk and the ability of a remedy to
ma~ntain reliable protection of human health and the
environment over time, once cleanup goals have bee~ met.
0,
Reduction of Toxicity, MObility, or Volume Through Tre~tment
\ -- Addresses the anticipated performance of the treatment
technologies that may be employed in a remedy.
18
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o
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.
o
Implementability -- Addresses
administrative feasibility of
availability of materials and
particular option.
the technical and
a remedy, including the
services needed to implement a .
o
Cost -- Addresses the estimated capital and operation and
maintenance costs, as well as present worth.
o
state Acceptance -- Addresses whether, based on its review
of the RI/FS and Proposed Plan, the state concurs with,
opposes, or has no comment on the preferred alternative.
o
community Acceptance -- Addresses the pUblic's comments on
and concerns about the Proposed Plan and RI/FS Report.
The first two criteria, overall protection of human health and
the environment and compliance with ARARs are threshold
requirements that must be met. The next five criteria are
balancing criteria used to evaluate the advantages and
disadvantages of each alternative. The final two criteria, state
and community acceptance, are modifying criteria which are used'
in a final evaluation of each alternative. The comparative
analysis of the alternatives is summarized below and proceeds
from the alternative that best satisfies the criterion to the one
that least satisfies the criterion.
I
OVERALL PROTECTION OF HUMAN HEALTH AND ENVIRONMENT
All of the remedial alternatives considered for the Folkertsma
Refuse site, except the no action alternative, are protective of
human health and the environment. These alternatives eliminate,
reduce, or control the risks through various combinations of
treatment, engineering and/or institutional controls. As the nS
action alternative does not provide protection of human health
and the environment, it is not eligible for selection and shall
not be discussed further in this document.
Alternatives 2, 3, 4, 5, 7 and 8 protect human health and the
environment by containing the contaminated materials and
isolating the public and animals from the contaminants.
Alternatives 2, 3, 7 and 8 contain the materials on-site, while
Alternatives 4 and 5 transport the contaminated materials to an
off-site facility for containment. Alternatives 6 and 9 reduce
the risk to human health and the environment by destroying the
organic contaminants at the site and containing the inorganic
contaminants. In addition, the institutional controls employed
19
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in Alternatives 2, 3 and 6 through 9 restrict site access and the
use of groundwater. These controls also reduce exposure to
contaminants. All of the alternatives reduce the potential for
contaminants to migrate to the groundwater, and for the
contaminated groundwater to move out from beneath the landfill
and beyond the waste boundary. All of the alternatives also
reduce the potential for contaminants to migrate to Indian Mill
Creek.
'COKPL~ANCB .~TB ARARs
This section discusses how each alternative complies with major
ARARs. Alternatives 2 through 9 are in compliance with all
identified ARARs (Table 8). Alternative 2, which involves
capping the waste materials, would be required to comply with the
requirements of the Resource Conservation and Recovery Act (RCRA)
Subtitle D and the Michigan Solid Waste Management Act 641
(MSWMA). Alternatives 4, 5, 6 and 7, which involve the
excavation and disposal of contaminated materials, or the
excavation, treatment, and disposal of treatment residuals, must
comply with the requirements of RCRA and the Michigan Hazardous
Waste Management Act 64 (MHWMA). Alternatives 4, 5, 6, 7, and 9
require excavation below the water table, which may affect the
wetlands near the site. These alternatives would be required to
meet the requirements of the Goemaere Anderson Wetlands
Protection Act of Michigan. All alternatives involve the
excavation of 'sediment. As excavation would occur below the 100
year flood elevation, these alternatives must comply with the
conditions of federal and state floodplain regulations. All
alternatives involve excavation, construction, or treatnlent
ac~ivities which may release contaminants into Indian Mill Creek.
As such, the standards set forth in the Clean Water Act and the
Michigan Water Resources Commission Act 245 (MWRCA) must be met.
Alterpatives 2 and 3 involve the installation of gas vents, if
necessary, to prevent the buildup of VOCs and methane. If
installed, these alternatives would be required to comply 'with
the Michigan Air Pollution Act 348 (MAPA). In addition,
Alternatives .2 through 7 and 9 involve excavation, construction,
or treatment activities which may result in the release of
contaminants into the air. These alternatives must comply with
the air quality standards ,in the, Clean Air Act, and MAPA.
LONG-TERN. EFFECTIVENESS AND PERMANENCE
,
Alternative 9 provides the greatest degree of long-term
effectiveness and permanence by destroying organic contaminants
and immobilizing inorganic contaminants. Any organics that may
volatilize during the process are captured in a hood over the
melting zone and treated. Metals are encapsulated in a glass
mass that is very resistent to leaching.
Alternative 6 provides a ver.y high degree of long-term
20
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o
o
'0
TABLE 8
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARs)
Federa.l ARARs
o
o
o
o
o
o
National Ambient Air Quality standards (40 CFR 50)
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CWA)
Occupational Safety and Health Act (OSHA)
Endangered Species Conservation Act
Federal floodplain regulations
State ARARs
o
o
o
o
\
o
o
o
o
o
o
Michigan Air Pollution Act 348 (MAPA)
Michigan Hazardous Waste Management Act 64 (HWMA)
Thomas J. Anderson, Gordon Rockwell Environmental Protection
Act 127 .
Michigan Occupational Safety and Health Act 154 (MIOSHA)
Michigan Natural River Act 231
Michigan Water Resources Commission Act 245 (MWRCA)
'. Michigan Environmental Response Act 307 (MERA)
Michigan Inland Lakes and Streams Act 346
Michigan Soil Erosion and Sedimentation Control Act 347
Michigan Solid Waste Management Act 641 (MSWMA)
Gomaere Anderson Wetlands Protection Act
Michigan EnQangered Species Act 203
State floodplain regulations
,
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effectiveness and permanence by destroying the organic
contqminants with a thermal treatment technology. The
a],ternative is considered very reliable; however, the residual-
ash may contain metals at levels that pose a risk ,and thus'
require additional treatment.
Alternatives 7 and 8 provide a high degree of long-term
effectiveness and permanence by containing the contaminated
materials with stabilization/solidification processes. These
processes reduce the potential for contaminants to leach into the
underlying soils and groundwater. However, Alternatives 7 and 8
may not be very effective on the materials containing organic
contaminants at the site.
Alternatives 4 and 5 provide a high degree of'long-term
effectiveness and permanence at the site by removing all the
contaminated materials from the site. Although these
alternatives are extremely reliable in removing the residual
at the Folkertsma site, they move the materials to another
location without providing treatment.
risk
Both Alternatives 2 and 3 reduce the risk at the site to the same
degree as any of the above alternatives in the short term. As
the contaminated materials are left in place, however, these
alternatives rely on institutional controls and operation and
maintenance for long-term effectiveness.
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT
Alternatives 6 and 9 reduce the toxicity and the volume of the
contaminated materials at the site. Alternative 6 uses thermal
destruction; Alternative 9 employs in-situ vitrification.
Alternative 9 also reduces the mobility of the treatment
residuals.
Alter~atives 2, 3, 4, 5, 7 and 8 are containment remedies and do
not treat the contaminated materials. None of these alternatiJes
reduces the mobility, toxicity, or volume of contaminants through
treatment. In addition, the additives used in the
sOlidification/stabilization processes in Alternatives 1 and 8
wi~l inc~ease the volume of materials.
SHORT TERM EFFECTIVENESS
Alternatives 2, 3, 4, and 5 provide the lowest short-term risk to
site workers and th.e community. Each of these alt'ernatives has a
potential for contaminated dust emissions; however, standard dust
control measures and strict air monitoring should minimize any
dust emissions. Alternatives 2 and 3 will take only 3 to 5
months to complete as compared. to Alternatives 4 and 5 which will
take 6 to 12 mGnthsto complete. '
Alternatives 7 and 8 provide greater short-term risks than
21
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Alternatives 2 through 5. The stabili~ation/solidification
processes may release volatile organics into the atmosphere,
increasing the risk to site workers and the community. The time
to complete Alternative 7 is the same as Alternatives 2 and 3 ..
(approximately 3 to 6 months), and Alternative 8 is expected to
take la to 16 months to complete. . "
Thermal destruction (Alternative 6) and in-situ vitrification'
(Alternative 9) present the greatest risk to site workers and the
community. The generation of contaminated dust and air emissions
could potentially pose a risk to the community over an extended
period of time. The time to compl~te these alternatives is the
longest: 30 to 36 months for Alternative 6, and 27 to 30 months
for Alternative 9.
IKPLEMENTABILITY
Alternatives 2 and 3 are the easiest to construct and operate.
Periodic maintenance of the caps and the groundwater and drainage
water monitoring systems will provide for continued reliability
of these alternatives. Additional remedial actions would also be
easy to implement if the 5-year review or the groundwater or
drainage water monitoring programs indicate additional actions
are necessary. These alternatives use standard engineering
practices and should not present any administrative difficulties.
Alternatives 4 and 5 are also easy to construct. As the
contaminated material would be removed from the site, the
potential need for additional remedial actions at the site would"
be eliminated. Administrative difficulties may be encountered in
identifying a landfill willing to accept the contaminated
m~terials for disposal.
Alternatives 7 and S are slightly more difficult to construct
than Alternatives 2, 3, 4, and 5 due to additional materials
handling requirements for the sOlidification/stabilization
process. Of the ~wo alternatives, Alternative 7 is slightly
easier to construct because large pieces of buried steel can
interfere with the in-situ process required in Alternative 8. If
the 5-year review or the groundwater or drainage water monitoring
programs indicate that additional remedial action is necessary,
both of these qlternatives present a greater difficulty for
implementing further actions. Vendors for solidification are
readily available, but in-situ solidification vendors are
slightly less available. Finally, Alternative 7 may be more
diffic~lt to complete administratively because the increased
volume of materials may necessitate that land adjacent to the
site be purchased. "
Alternative 9 is more difficult to implement than Alternatives 7
and"S because fewer vendors are available and the in-situ
vitrification process requires specialized equipment. The
22
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process is not effective for treating highly permeable soils in
contact with ground water; therefore, groundwater would need to
be diverted at the site. In addition, buried me~al objects in
the foundry sand may decrease the implementability of the process
if the objects must be removed.
Alternative 6 is considered the most difficult to implement
because thermal treatment requires the same amount of materials
handling as Alternatives 7 and 8, as well as complex operation
procedures for the safe destruction of contaminants. Prior to,
operation, a trial burn would need to be conducted and the ash
tested to determine appropriate disposal options. During
operation, thi$ alternative would require the most monitoring and
testing. This alternative 'also requires a large amount of space
for the incinerator and materials staging areas, and may require
that land adjacent to the site be leased. As many federal,
state, and local air standards need to be met, this alternative
presents the most administrative difficulties.
I
COST
The FS evaluated several alternatives
The estimated capital costs, 1st year
costs, and the present worth costs of
summarized below.
with a wide range of costs.
operation a~d maintenance
the alternatives are
ALTERNATIVE CAPITAL COST 1ST YEAR 0 'M PRESENT WORTH
Alternative 1 $ 99,000 $ 49,000 $ 561,000
Alternative 2 $ 990,000 $ 58,000 $ 1,500,000
Alternative 3 $ 2,700,000 $ 58,000 $ 3,300,000
Alternative 4 $ 9,500,000 $ 0 $ 9,500,000
Alternative 5 $ 22,700,000 $ 0 $ 23,000,000
Alternative 6 $ 38,900,000 $ 49,900 $ 39,000,000
Alternative 7 $ 22,900,000 $ 49,000 $ 23,000,000
Alternative 8 .$ 16,300,000 $ 49,000 $ 17,000,000
Alternative 9 $ 42,200,000 $ 0 $ 42,200,000
Alternative 2 (clay cap) is the least costly~ and Alternative 9
(in-situ vitrification) is the most costly. within this cost
range,' the remaining alternatives have a wide range of present
worth costs. Alternatives 4, 5, and 9 do not have O&M costs,
while the remaining six alternatives have O&M costs comparable to
each other.
f ,
STATE ACCEPTANCE
Michigan Department of Natural Resources has concurred with the
selected remedy.
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COMMUNITY ACCEPTANCE
Community' acceptance is assessed in the ,attached Responsiveness
Summary. The Responsiveness Summary provides: 1) a thorough
review of the public comments received on the RI/FS and Proposed
Plan; and 2) EPA's and MDNR's responses to the comments received.
THE SELECTED REMEDY
The selected remedy is Alternative 2, the clay cap alternative.
This alternative will provide for a cost-effective and
appropriate remedial action for the landfilled areas. The type
of cap utilized in Alternative 2 is appropriate since the
majority of landfilled material is foundry sands. Foundry sands
are not a listed waste under RCRA and the Agency does not have
any information indicating that the foundry sands disposed of in
the landfill are characteristic wastes under RCRA., In addition,
samples collected from the landfill during the RI were not
determined to be EP Toxic (a RCRA characteristic test).
The major components of the selected remedy are illustrated in
Figure 3 and include:
o
Excavate, dewater, and consolidate approximately 1,300
yards of contaminated sediment from the unnamed creek,
drainage ditch, and Indian Mill creek on top ~ the
landfilled materials;
cubic
o
Convert-the unnamed creek and drainage ditch into permeable
underground drains to provide for continued site drainage;
o j
Install and maintain a cap over the contaminated sediments
and landfilled areas in accordance with the requirements of
the Resource Conservation and Recovery Act Subtitle D and
Michigan Act 641;
o
Ins~all and maintain passive gas vents on each side of the
landfill, to prevent the buildup of volatile organic
compounds and'methane if necessary:
, t
o
Install and maintain a layer of topsoil and a vegetative
covering over the landfilled areas;
o
Install and maintain a fence around the site;
o
Impose institutional controls such as deed restrictions -
to prevent the installation of drinking water wells
within the landfilled portion of the site and fut~re
disturbance of the cap and landfilled materials;
o
Implement long-term groundwater and drainage water
monitoring programs to ensure the effectiveness of the
24
,
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Q PanneU Street
~ ~ m
N
N«m~ 0
J
I
S Area to be CoYered
With Clay Cap
. Area at Ditch and Un-
named Creek to Haw
Sediment RemoYed and
to be ConYett8d into
UndergrOUnd [)raj".
Area at Indian Mill Creek
to be Excavated
. Warehouses
~ Houses
~
~
£8 Office
-
reenhouses
~
I
D
Unnamed .
Creek
---f'
~
Und~IOped
Property
Excavated
Ditch
Road To Be Used For
Constrvctjon ActMties
Indiat1 Mill Creek
.~ Underground
Pipe
-- ..,
FIGURE 3
ALTER~ATI\'E 2 - CLAY CAP
. '
,
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remedial action.
SITE PREPARATION
Portions of the site to be capped, that are not under permqnent
structures (buildings and loading docks), will be cleared.
Clearing the site would involve removing all scrap metal, unused.
Eachinery, and pallets.. In addition, trees and shrubs in the:
1andfilled area will be removed and disposed of at an appropriate
off-site facility. Approximately 6 acres will have to be cleared
of scrap metal, unused machinery, and pallets. Approximately 3 '
acres will have to be cleared of trees and shrubs.
General site preparation includes activities and costs associ~ted
with on-site mobilization. This includes setting up
administration and decontamination trailers, improving access
roads, and constructing a vehicle decontamination area. Heavy
truck traffic to and from the site will take place on the access
road south of the site owned by the Darling Rendering Company.
This road will need to be widened and improved to withstand the
additional traffic flow. In addition, 300 feet of additional
access road will be constructed on the site. A vehicle
decontamination area will be constructed to restrict contaminated
naterials to the site. The decontamination area will include a
sump to collect decontamination fluids and a storage area for
drummed decontamination fluids and contaminated materials.
'Decontamination fluids will be analyzed and properly disposed of.
Contaminated materials will also be properly disposed of.
The utilities that now service the site will need to be improved.
Additional water and gas hookups will involve minor site
preparation costs.
SEDIMENT EXCAVATION AND CONVERSION TO UNDERGROUND DRAINS
The unnamed creek and drainage ditch will be converted into
underground drainageways before placing the low-permeability clay
cap over the landfilled a~ea. Although groundwater discharges to
the creek and ditch, the conversion to drains is not expected to
significan~ly affect the current groundwater flow pattern at the
site. As part of the conversion, the contaminated ~ediment and
muck in the unnamed' creek and drainage ditch will be excavated to
the underlying sand unit (approximately 1,300 cubic yards). The
excavated material will be dewatered by a filter press. The
solids will subsequently be capped as part of the landfill, along
with tbe contaminated sediments excavated from Indian Mill Creek.
The filtrate from the dewatered sediments will be collected,
sampled, and discharged to Indian Mill Creek. If the contaminant
concentration in the filtrate exceeds federal or state National
Pollutant Elimination Discharge System standards, the filtrate
will be treated prior to discharge. During the excavation of
sediment and muck, the surface water will be collected upstream
25
,
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of the site and pumped directly to Indian Mill Creek.
Engineering controls will also be implemented to prevent
contaminated materials from migrating to Indian Mill Creek during
construction. Clean material (approximately 1,100' cubic yards) ,
will be placed in the excavations to provide a suitable bedding.
Perforated drain tile (approximately 1,500 feet of 48-inch '
diameter tile) and filter material (approximately 1,700 cubic
yards) will be placed in the excavations and covered with coarse
aggregate to the land surface. Both underground drains will have
permeable covers to capture surface water runoff from the clay
cap.
DiS~ALLATION OF CLAY CAP
A clay cap will be placed over the landfilled area to isolate
human and animal receptors from contaminated materials. The cap
will be installed and 'maintained in accordance with RCRA Subtitle
D'and MSWMA 641. The area to be capped, including the
contaminated sediments from the unnamed creek, drainage ditch,
and Indian Mill Creek, will be graded and compacted. The cap'
material will consist of two layers, a compacted clay layer and a
surficial layer of topsoil. The compacted clay layer will have a
compacted thickness of 2 feet and a hydraulic permeability less
than or equal to ~0-7centimeters per second. The compacted clay
layer will be covered with 6 inches of topsoil and seeded with'
natural grass seed. The capped, areas will be graded so that
surface runoff enters the underground drains described above.
The western portion of the landfilled area to be capped covers
approximately 9,000 square yards and will require approximately
6,000 cubic yards of compacted clay and 1,500 cubic yards of
topsoil. The eastern portion of the landfilled area to be capped
covers approximately 17,300 square yards and will require 11,500
cubic yards of compacted clay and approximately 2,900 cubic yards
of topsoil.
The construction of a, low permeability cap over the landfilledf
materials may result in the buildup of VOCs or methane;
therefore, a passive gas control system will be installed if
necessary. As the landfill~d material is already of high
pe~eability (10-3centimeters per second), the gas control system
will con~ist of five vents on each side of the landfill.
GROUNDWATER AND DRAINAGE WATER MONITORING
The groundwater and the drainage water in the underground drains
will be monitored (or hazardous substances that may leach out of
the contaminated materials. Groundwater samples will be
collected from th~ existing monitoring wells. The drainage water'
will be monitored in each of the drains at a location
downgradient 0; thelandfilled'area, yet prior to the conve~gence
of the two drains. The specific details of the groundwater and
26
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drainage water monitoring programs will be developed in the
Remedial Design.
SITE JaUBTEliAIlCE
Annual 'operation and maintenance activities will include
maintaining the cap and drains, and quarterly monitoring of the
groundwater and the drainage water from the underground drains.
In addition, the gas vents will need to be monitored for flow and
chemical speciation of emissions. As the contaminated materials
will be left on-site, the remedial action would be reviewed every
five years.
IMPLEMENTATION TIME AND COSTS
The selected remedy will take approximately 3 to 5 months to
implement. A detailed cost summary is provided in Table 9. ~he
capital cost is approximately $990,000, and 0 & M is estimated to
be $58,000 for the first year. The present worth cost of the
remedy over a 30-year period is $1.5 million.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to. undertake remedial actions that achieve.
adequate protection of human health and the environment. In
addition, section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that when
complete, the selected remedial action for this site must comply
with applicable or relevant and appropriate environmental
standards established under Federal and State environmental laws
unless a statutory waiver is .justified. The selected remedy must
also be cost-effective and utilize permanent solutions an~t
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment
that permanently and significantly reduce the volume, toxicity,
or mobility of hazardous wastes as their principal element. The
following sections discuss how the selected remedy meets these
statutory requirements. .
PROTECTION OF ~UMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment
through containment of the landfilled materials and contaminated
sediments of the unnamed creek, drainage ditch, and Indian Mill
Creek.' The cap will be constructed in accordance with RCRA
subtitle D and MSWMA 641.
capping the landfilled materials and contaminated sediments will
eliminate or reduce human and animal exposure through ingestion,
direct contact, and inhalation. The cap will also reduce the
27
,
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TABLE 9
ESTIMATED COST OF ALTERNATIVE 2 - CLAY CAP
Site Preparation
Drainage System
Clay Cap
Heal~h and Safety Equipment
Groundwater Monitoring
Site Maintenance
Gas Control System Monitoring
MObilization/Demobilization (4%)
Bid Contingency (15%)
Scope Contingency (20%)
Construction Subtotal
,
Permitting and Legal Activities (5%)
Engineering Design (7%)
Services During Construction
Total Capital Cost
Present Worth at 30 years
@ 10 Percent Discount Rate
CaDital
$
73,300
190,000
264,000
4,500
61,400
$
593,200
23,700
88,900
119.000
.
$ 824,800
41,200
57,700
65.900
,"
$
990,000
$1,500,000
,
o & M
$ 49,000
6,600
2.400
$ 58,00Q
. , .
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potential for contaminants to migrate to the groundwater, and for
the contaminated groundwater to move out from beneath the
landfill and beyond the waste boundary. . A groundwater and
drainage water monitoring program will also be implemented.
Fencing and institutional controls' such as deed restrictions will
further restrict exposure to the landfilled materials and
contaminated sediments, as well as reduce the potential for the
ingestion of contaminated groundwater beneath the landfill.
The selected remedy does not pose any short-term threats that
cannot be readily controlled, and no adverse cross-media impacts
are expected from its implementation.
By implementing the selected remedy, the risks at the Folkertsma
Refuse site will be reduced to within EPA's acceptable risk range
for carcinogens (10-4to 10-6) and to an acceptable level for
noncarcinogens (Hazard Index ~ 1).
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
The selected remedy of excavation, consolidation, and containment
will comply with all applicable or relevant and appropriate
chemical, action, and location-specific requirements (ARARs).
The ARARs considered for the selected remedy at the Folkertsma
Refuse site are presented below.
Action-Specific ARARs:
Action-specific ARARs are requirements that define
acceptable treatment and disposal procedures for hazardous
substances.
Federal ARARs
\RCR~ Subtitle D 40 CFR Part 241 establishes
requirements' for the disposal of solid waste in
landfills. As the selected remedy involves placing a
cap over the iandfilled area of the site, this
regulation would be applicable or relevant and
appropriate to the action.
,.
state ARARs
Michigan Solid Waste Management Act 641 provides
regulations for the construction, operation, and
closure of solid waste landfills. This act is
applicable or relevant and appropriate to the action as
the selected remedy involves placing a cap over the
landfilled area of the site. Requirements for soljd
waste' closure include a minimum 2 feet of compacted
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,clay !~th a hydraulic permeability less ~han or equal
,to 10 ,and a slope not to exceed 1 vert1cal to 4
horizontal nor less than 2%.
Michigan Environmental Response Act 307, as amended,
provides for the identification, risk assessment, and
evaluation of contaminated sites within the state;
therefore, Act 307 is applicable or relevant and
appropriate to the Folkertsma Refuse site. These rules
provide that remedial actions shall be protective of
human health, safety, the environment, and the natural
resources of the State. To achieve the standard of
protectiveness, Act 307 rules specify that a remedial
action shall achieve a degree of cleanup under either
.Type A (cleanup to background levels), Type B (cleanup
to risk-based levels), or Type C (cleanup to risk-based
levels under site-specific considerations). At the
Folkertsma Refuse site, EPA has determined that Type C
criteria would be appropriate. The selected remedy
utilizes a containment technology, and cleanup
standards developed under Type A and Type B criteria
could not be met unless the source materials were
.removed. Type C criteria would provide for a cost-
effective and appropriate remedial action for the
'landfilled areas.
MichiganiInland Lakes and Streams Act 346, as amended,
regulates inland lakes and streams in the state. Act
346 would be applicable or rele~ant and appropriate to
the excavation of sediments in Indian Mill Creek.
Michigan Soil Erosion and Sedimentation Control Act 347
regulates earth changes, including cut and fill
activities, which may contribute to soil erosion and
sedimentation of the surface waters in the state. Act
347 would be applicable or relevant and appropriate to
the excavation of sediments in the unnamed creek,
drainag~ ditch and Indian Mill Creek, and the
installation of the cap, as these actions could impact
Indian Mill Creek.
Chemical-specific ARARs:
Chem~cal-specific ARARs regulate the release to the
environment of specific substances having certain
chemical characteristics.
Federal ARARs
National Ambient Air Quality Standards 40 C:R,50
provide air emission requirements for actic~s which may
29
,
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release contaminants into the air. As the selected
-remedy involves excavation and construction activities
which may release contaminants or particulates into the
air, this act is relevant and appropriate.
Clean Water Act provides surface water quality criteria
for the protection of human health and aquatic life.
The Federal Ambient Water Quality criteria (AWQC) are
nonenforceable guidelines that set pollutant
concentration limits to protect surface waters and are
applicable to point source discharges. At Superfund
sites, AWQC are relevant and appropriate requirements
for the discharge of treated water. As the filtrate
from the dewatered sediments will be discharged into
Indian Mill Creek, the Clean Water Act is applicable.
. Occupational Safety and Health Act 29 CFR 1910
regulates the health and safety of workers. As the
contamination at the site could potentially pose a
hea~th risk to response workers, this act is
applicable.
S~ate ARARs
Michigan Air Pollution Act 348 provides air emission
requi~ements for actions which may release contaminants
into the air. As the selected remedy involves
excavation and construction activities which may
release contaminants or particulates into the air, this
act is relevant and appropriate. In addition, if it is
determined that it is necessary to install gas vents to
'prevent the buildup of VOCs and methane, Act 348 is
also applicable or relevant and appropriate.
Michigan Water Resources Commission Act 245, as
amended, establishes surface water quality standards to
protect human health and the environment. The National
Pollutant Discharge Elimination System (NPDES) is
administered by the State. As the filtrate from'the
dewatered sediments will be discharged into Indian Mill
Creek, Act 245 is applicable.
.
Michigan Occupational Safety and Health Act 154
provides regulations to ensure safe and healthy working
~nvironments. As the contamination at the site could
potentially pose a health risk to response workers,
this act is applicable.
Location-specific ARARs:
Location-specific ARARs are those requirements 'that
relate to the geographical 'position of a site. These
30
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.include:
Federal ARARs
Endangered Species Conservation Act provides for the
identification and protection of endangered/threatened
species and their habitat. As several threatened or
endangered species have been identified in the Grand
Rapids Area, this act is relevant and appropriate to
those activities necessary to implement the selected
remedy which may impact th~se endangered species.
Executive Order 11988 provides regulations for the
protection of floodplains. This order is applicable to
all actions occurring below the 100-year flood
elevation. As the selected remedy includes activities
which would occur below the 100-year flood elevation
(the excavation of sediment in the unnamed creek,
drainage ditch, and Indian Mill Creek; and the
installation of underground drains in the unnamed creek
and drainage ditch), this order may be applicable.
Executive Order 11990 provides regulations which
protect against the loss or degradation of wetlands.
As wetlands have been identified in the vicinity of the
site, this order is applicable to those actions which
may impact these wetlands.
State ARARs
Thomas J. Anderson, Gordon Rockwell Environmental
Protection Act 127 provides for the protection of
natural resources from ~mpairment and destruction by
pollution. As such, this act is applicable or relevant
and appropriate to the selected remedy.
Michigan Natural/River Act 231 provides for the
protection of natural waterways as well as the
protection of fish and. wildlife resources associated
with these waterways. As the site is 100 to 300 feet
from Indian Mill Creek, and the selected remedy
involves activities which may impact the creek, this
act is applica~le or relevant and appropriate.
Michigan Endangered Species Act 203 provides ~or the
protection and"regulation of activities occurring in
the vicinity of endangered/threatened species or their
habitat. As several threatened or endangered species
have been identified in the Grand Rapids Area, this act
is releva~t and appropriate to those activities in the
selected remedy which may impact these endangared
species. .
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.GoemAere-Anderson Wetland Protection Act regulates any
activity which may take place within wetlands in the
State of Michigan. If the " remedial action occurs in a
wetland area, this act will be applicable or relevant
a~d ap~ropriate. .
Other Criteria, Advisories or Guidance to be Considered
for this Remedial Action:
state Recommended Allowable Air Concentrations have
been established by Michigan Department of Natural
Resources, Air Quality Division. The standards
established for benzo(a)pyrene are relevant to
consider, as this chemical has been detected in the
landfilled materials at the site and may be released
via fugitive dusts.
EPA and the state have agreed to incorporate
institutional controls such as deed restrictions to
prohibit the installation of water wells beneath the
landfilled portion of the site and any activities which
might disturb the cap or landfilled materials.
The RCRA Land Disposal Restrictions (LDRs) are not ARARs for the
Folkertsma Refuse site. The consolidation of the contaminated"
sediments from the unnamed creek, drainage ditch, and Indian Mill
Creek on the landfill is considered the movement of wastes within
a single area of contamination (AOC). The movement of wastes
within an AOC does not constitute land disposal or placement. As
land disposal or placement will not occur at the Folkertsma
Refuse site, th~ RCRA LDRs are not triggered.
COST-EFFECTIVENESS
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs: the net present worth value being $1.5 million. The
selected remedy is the least costly of those alternatives which
protect human health and the environment.
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES
-------
mobility, or volume achieved through treatment, short-term
effective~ess, implementability, cost, also considering the
statutory preference for treatment as a principal element, and
considering state and community acceptance.
In addition to protecting human health and the environment and
complying with ARARs, the selected remedy provides the lowest.
short-term risks to site worKers and the community, and can be
implemented in 3 to 5 months.' The remedy is easy to construct
and operate, presents little or no administrative difficulty, and
is the least costly alternative. Institutional controls and
operation and maintenance will ensure that the remedy is
effective in tne long-term. In addition, the state of Michigan
has concurred with the selected remedy.
The selected remedy is a containment remedy, however, and does
not meet the criterion for reducing toxicity, mobility, or volume
through treatment; nor does it satisfy the preference for
treatment as a principal element. The only alternatives to meet
these criteria are Alternatives 6 and 9, incineration and in-situ
vitrification. These alternatives, however, pose the greatest
short-term risks to site workers and the community and take 2 to
3 years to implement. These alternatives are more difficult to
construct and operate, and present greater administrative
difficulty. In addition, as the risks at the site are posed by a
large volume of low-level organic and inorganic waste material,
the selected remedy is consistent with the expectation within the
NCP that these types of materials will be addressed by
engineering controls. '
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
,
As discussed above, the selected remedy does not satisfy the
preference for treatment as a principal element. The risks at
the Folkertsma Refuse site are posed by a large volume of low-
level organic and inorganic waste material. Containment
satisfies the NCp'expectation that low-Ievei, long-term threats,
like those posed by the materials at the Folkertsma Refuse site,
will be addressed by engineering controls.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Folkertsma Refuse site was released for
public comment in March, 1991. The Proposed Plan identified
Alterna~ive 2, the plpy cap, as the preferred alternative. EPA
reviewed all written and verbal comments submitted during the
public ~omment period. Upon review of these comments, it was
determined that no significant changes to the remedy, as it was
originally identified in the Proposed Plan, were necessary.
~3
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RESPONSIVENESS SUMMARY
FOLKERTSMA REFUSE SITE
WALKER, MICHIGAN
z.
RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public'
comment period from April 1, 1991 through April 30, 1991 for
interested parties to comment on the Remedial
Investigation/Feasibility Study (RI/FS) report and the Proposed
Plan for the Folkertsma Refuse site in Walker, Michigan.
The Proposed Plan provides a summary of the background information.
leading up to the public comment period. Specifically, the
Proposed Plan includes information pertaining to the history of the
site, the scope of the proposed cleanup action and its role in the
overall site cleanup, the risks posed by the site, the descriptions
of the remedial alternatives evaluated by EPA, the identification
of EPA's preferred alternative, the rationale for EPA's preferred
alternative, and the community's role in the remedy selection
process.
EPA held a public meeting at 7:00 p.m. on April 3, 1991, at the
Walker community Building in Walker, Michigan, to discuss the
I .
resul ts of the RI/FS and to present EPA' s proposed remedJ.al
alternative for controlling contamination at the landfill.
The'responsiveness summary, required by the Superfund Law, provides
a summary of citizens' comments and concerns identified and
regeived during the public comment period, and EPA's responses to
those comments and concerns. All comments received by EPA during
the public comment period were considered in EPA's final decision
for selecting the remedial alternative for addressing contamination
at the Folkertsma Refuse site.
\
This responsiveness summary is organized into sections as described
below:
"
I.
RESPONSIVENESS SUMMARY OVERVIEW. This section outlines
the purpose of the Public Comment period' and the
Responsiveness Summary. It also references the appended
background information leading up to the Public Comment
period.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS. This
section provides a brief history of community concerns
and interests regarding the Folkertsma Refuse site.
II.
III.
,SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVEC DURING
THE PUBLIC MEETING AND EPA RESPONSES TO THESE COMMENTS.
This section summarizes the oral comments received by EPA
at the April 3, 1991 public meeting, and provides EPA's
responses to these comments.
,
-------
. IV.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS. This section
summarizes the written comments received by EPA during
the public comment period, as well as EPA's responses to
these comments.
2
,
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. II.
BACKGROUND ON COMHUNITY INVOLVEMENT AND CONCERN
Community interviews were conducted in October 1988, to determine
the interest and concerns of the community over the Folkertsma..
Refuse site. EPA interviewed state and local officials, a local'
environmental organization, and local residents. The respondents'
indicated that there was a strong interest in learning more about
the Superfund program and the activities planned for the site'.
However, no history of , community concern regarding the site had
been identified.
Most of. the residents and local officials interviewed were
surprised that the Folkertsma Refuse site was considered to be
potentially hazardous. Many of them did not consider foundry sand,
the primary material disposed of at the site, to be a potentially
hazardous waste. There is a foundry approximately a half-mile
southwest of the site, employing many Walker residents, and foundry
sa~3 has been a familiar form of landfill material to the residents
in the vicinity of the site. In addition, landfilling operations
at the site ceased in 1972, and a pallet company has been operating
on the site ever since. This passage of time, as well as the fact
that the site does not visibly give the impression as being
potentially hazardous, also seems to have influenced the lack of
concern. .
The concerns expressed by the community during these interviews are
.summarized.below:
o
Local officials and residents were concerned that EPA's
findings regarding foundry sand could have many implications
for the other foundry sand landfills in the community.
'Residents were concerned that their private wells might be
contaminated. .
.
o
o
Local officials were concerned that the contamination at the
site would migrat~ to the Grand River, endangering alternate
drinking water supplies and recreational activities.
Residents, local officials, and the pallet company expr.essed
concern that publicity of the site be kept to a minimum in
order that th~ public not be alarmed.
. .
o
As part of EPA's responsibility and commitment to the Superfund
program, the community has been kept informed of ongoing activities
condu~ted at the Folkertsma Refuse site. EPA has established two
information repositories where relevant site documents may be
reviewed. One repository is located at Walker City Hall; the other
is at the Kent County Public Library. Documents stored at the
repositories include:
o
RI Workplan! Health qnd Safety Plan, Quality Assurance'
3'
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Project Plan, Community Relations Plan:
o
RI/FS ~eports:
o
Proposed Plan:
o
Fact sheets, summarizing the technical studies conducted
at the site;
o
Public Meeting Transcript;
o
comments received
during the
public. comment
written
period.
EPA I S selection of the remedy to control contamination at the
Folkertsma Refuse site is presented in a document known as a Record
of Decision (ROD). The ROD and the documents containing
information which EPA used in making its decision (except for
documents that are published and generally available) will also be
placed in the information repositories, as wili this responsiveness
summary.
III. SUMMARY OF QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
MEETING AND -EPA RESPONSES TO THESE COMMENTS.
Oral comments raised during th~ public meeting for the Folkertsma
Refuse site have been summarized below together with EPA's response
to these comments.
COMMENT: One resident stated that he did not believe the materials
disposed of at the site posed a risk to human health and the
environment. -
RESPONSE-: EPA I S determination of risk at the Folkertsma Refuse
site is based on the findings of the Remedial Investigation (RI)
and Risk Assessment, which were conducted in accordance with ~he
National contingency Plan (NCP). During the RI, EPA collected and
analyzed samples of the landfilled material, soil, groundwater,
surface water, and sediment. The analytical results, of t.hese
samples indicate that the landfilled materials are contamina.ted,
and that\the contamination has spread into the soil, groundwater,
surface water, and sediment. . The da~a collected during the RI was
then used in conjunction with established toxicity information and
standard exposure scenarios to determine if the contamination at
the site poses a risk to human health and the en~ironment. The
risk values genera~ed in the Risk Assessment for the Folkertsma
Refuse site exceed the acceptable risk range established under the
Comprehensive Environmental Response,compensatio~, and Liability
Act (CERCLA) and warrant a remedial action.
.
COMMENT: One resident stated that he did not feel the
contamination detected at the site was great enough to warrant a
4
,
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remedial action.
RESPONSE: CERCLA gives EPA the authority to conduct remedial
actions when there is a release or threatened release of iny
hazardous substance, pollutant, or contaminant into the environment
which may present an imminent and substantial endangerment to human
health and the environment. At the Folkertsma Refuse site,
unacceptable risks to human health have been calculated 'for
exposure to the landfilled material and groundwater. These risks
range from 10-2to 10-3(one additional case of cancer for every 100
to 1.000 people exposed). In addition, the landfilled material and
the sediments of the unnamed creek, drainage ditch, and Indian Mill
Creek pose unacceptable risks to the environment. As these risks
exceed EPA's acceptable risk range of 10-4to 10-6(one additional
case of cancer for every 10,000 to 1,000,000 people exposed), an
action is justified.
.
COMMENT: One resident expressed his preference for the remedial
alternatives which involved excavating the landfilled materials and
contaminated sediment and transporting them to an off-site landfill
for disposal.
RESPONSE: CERCLA provides EPA with a set of nine criteria for
evaluating remedial alternatives. These criteria include overall
protection of human health and the environment; compliance with
applicable or relevant and appropriate requirements (ARARs); long-
ter.m effectiveness and permanence; reduction of toxicity, mobil i ty ,
or volume through treatment; short-term effectiveness;
implementability; cost; and state and community acceptance. After
the alternatives are evaluated, the advantages and disadvantages of
each alternative are compared to identify the alternative which
p=ovides the be~t balance among the nine criteria.
Considering that the risks at the Folkertsma Refuse site were
calculated under worst case conditions, EPA believes that the
alternatives involving excavation and off-site disposal do not
provide the best balance amcng the nine evaluation criteria. While
these alternatives are protective of human health and the
environment, comply with ARARs, are' effective in the short-term,
and remove the risk from the Folkertsma Refuse site, they move the
materials to another location without providing treatment. The
long-term effeqtiveness of these alternatives relies upon effective
disposal at t~e receiving landfill. In addition, these
alternatives do not reduce toxicity, mobility, or volume through
treatment; may present administrative difficulties in identifying
a landfill willing to accept the contaminated materials for
disposal; and are more costly than other alternatives having the
same advantages.
Based on the nine evaluation criteria and the comparative analysis
of 'alternatives, EPA believes that the clay cap alternative
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provides the best balance among the nine criteria. The clay cap is
protective of human health and the environment, complies with
ARARs, is" effective in the long and short term, presents little or
no administrative or technical difficulties, and has the least
cost. Although this alternative does not satisfy the criterion for
reducing toxicity, mobility, or volume through treatment, the risks
at the site are posed by a large volume of low-level waste
material, and it is not 'practical to utilize a treatment
technology.
COMMENT: The owner of the pallet company and two residents
expressed concern that the clay cap alternative be revised to
include a top 'covering which would enable the pallet company to
continue operations on the site.
RESPONSE: CERCLA authorizes EPA to provide for remedial actions
which protect human health and the environment from a release or
threatened release of any hazardous substance, pollutant, or
contaminant into the environment. EPA's authority is limited to
the protection of human health and the environment, and does no~
include human occupancy or economic considerations.
EPA is, however, willing to consider during the remedial design,
the placement of additional cover material, such as asphalt, over
the cap once it is in place. The owners of the pallet company and
the owner of the property may be able aspha~t those portions of the
site they wish to resume operations on, provided that the
construction specifications (including thickness and composition of
the asphalt) meet EP':1' s approval, and that the parties involved
provide EPA with assurance that they will properly install, inspect
and maintain the covering. The owner of the pallet company and the
owner of the property would not be permitted to access or extend
business operations beyond the asphalted area. In addition, the
owners of the pallet company and the owner of the property would be
responsible for installing and maintaining a fence between the
asphalted portions of the site they ~xpect to be operating on and
the remainder of the capped area. .
IV.
SUMMARY OF WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS.
written comments received during the public comment period for the
Folkertsma Refuse site have been summarized below together with
EPA's response to these comments. Copies of the original letters
are available for review in the information repositories.
. I
COMMENT: A representative of the Kent County Health Department
e~press~d agreement with EPA's'proposed plan to cap the landfilled
materials. He went on to comment, however, that without disputing
SPA's Risk Assessment, he felt that the public, health risks
relating to the Folkertsma Refuse site were over emphasized in
comparison to the risk of injury, disease, or de~th by living in
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our every day environment.
RESPONSE: Although the risks posed by' the contamination at the
Folkertsma Refuse site may be over~mphasized in comparison to the
risk of. injury, disease, or death by living in our every day'
environment, CERCLA requires EPA to take an action at sites where
the carcinogenic risk has been determined to be greater than 10-4
(more than one additional case of cancer for every 10,000 people'
exposed). At the Folkertsma Refuse site, unacceptable risks to
human health have been calculated for exposure to the landfilled
material and groundwater. These risks range from 10-2to 10-J(one
additional case of cancer for every 100 to 1,000 people exposed).
In addition, the landfilled material and the sediments of the.
unnamed creek, drainage ditch, and Indian Mill Creek pose.
unacceptable risks to the environment. As these risks exceed EPA' s
acceptable risk range of 10-~o 10-6(one additional case of cancer
for every 10,000 to 1,000,000 people exposed)," an action is
justified.
COMMENT: The representative of the Kent County Health Department
also raised the issue as to whether it would be appropriate to
similarly address other known foundry sand disposal areas in Kent
County.
RESPONSE: EPA cannot respond to this comment \fnless further
information on the other foundry sand disposal areas is provided.
The question as to whether it would be appropriate to similarly
address other known foundry sand disposal areas in Kent County is
a site specific issue. The conclusions drawn from the
investigations conducted at the Folkertsma Refuse site are
particular to that facility and cannot be applied to other foundry
sand landfills. In addition, not all sites warrant the expenditure
of Fund money. CERCLA establishes a pre-remedial process for
determining which sites are eligible for investigation and cleanup
under Superfund (the National Priorities List (NPL». Eligibility
for the NPL is de~ermined by the Hazard Ranking Score for the site.
The Hazard Ranking Score is based on the results of a preliminary
assessment and on~site inspection of the facility. Although ma~y
sites have been brought to the attention of EPA and the State, hot
all of them have ranked high enough to warrant expenditures from
the Fund. In addition, these foundry sand disposal areas may be
regulated by current state laws.
The status of specific foundry sand landfills in Kent County can be
determined by contacting the Environmental Response Division of the
Michigan Department of Natural Resources. .
COMMENT: The owners of the pallet company and the owner of the
property have already asphalted some areas of the site and
submitted I a map depicting additional areas they would like to
asphalt. They need the buildings and the eastern portion of the
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site (approximately 5 acres) to operate their two-family owned
business. According to the owners, they cannot afford to move,
purchase another 5 acres, or build new buildings without someone
off-setting the cost; otherwise, they will be forced to go out of
business.
RESPONSE: CERCLA requires that all remedial actions comply with
applicable or relevant and appropriate requirements (ARARs). The
capping remedy selected for the Folkertsma Refuse site is required
.to comply with the Resource Conservation and Recovery Act (RCRA)
Subtitle D and the requirements .of the Michigan Solid Waste
Management Act 641 (MSWMA 641). Specifically, this includes a
minimum of two feet of compa~ted clay cover with a permeability
less than or equal to 1 x 10- centimeters/second, and a slope not
to e~ceed 1 vertical to 4 horizontal nor less than 2%.
EPA is, 'however, willing to consider the placement of additional
cover material, such as asphalt, over the cap once it is in place.
The owners of the pallet company and the owner of the property may
be able to asphalt those portions of the site they wish to resume
operations on, provided that the construction specifications
(including thickness and composition of the asphalt) meet EPA's
apprqval, and that the parties involved provide EPA with assurance
that they will properly install, inspect and maintain the covering.
The owner of the pallet company and the owner of the property would
not be permitted to access or extend business operations beyond the
asphalted are~. In addition, the owners of the pallet company and
the owner of the property would be responsible for installing and
maintaining a fence between the asphalted portions of the site they
expect to be operating on and the remainder of the capp~d area.
Tbe owners of the pallet company and the property owner also
expressed the following comments:
COMMENT: The landfill has been in existence for 20 years and has
n~t contaminated any wells or streams.
RESPONSE: Although contamination has not yet impacted any off-site
water well ~upplies, groundwater sampling indicates that the
groundwater beneath the landfill is contaminated, and that there is
a potential for the contaminated groundwater to move o~t froIt!
beneath the landfill. . Arsen,ic was. detec.ted in unfiltered
groundwater samples collected from 'beneath the landfill at
concentrations as high as 116 and 287 parts per billion (ppb).
Background water samples collected from wells installed upgradient
of the landfill only conta~ned arsenic at concentrations ranging
from 0 to 9 ppb. .
Contamination was also detected above background levels in surface
water samples collected from the unnamed creek a~d drainage ditch.
Cadmium and chromium were detected at concentrc~icns of 8 and 38
I.
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. ppb; - neither of these chemicals were detected in surface water
s~mples collected from upstream locations.
COMMENT: The sediments in the unnamed creek and Indian Mill Creek.
ar~ contaminated before reaching the landfill.
RESPONSE: Analysis of the sediment data indicates that the
landfill is the source. of sediment contamination in Indian Mil~
Creek and the unnamed creek. Contam'inants such as polynuclear
aromatic hydrocarbons, cadmium, chromium, and nickel were detected.
in the sediments of the unnamed creek and Indian Mill Creek at
concentrations two to three times greater than those detected in
background sediment samples. This indicates that the landfill, not
an off-site source, is the cause of the contamination.
COMMENT: The landfill is not the only landfill containing foundry
sand: foundry sand has been landfilled throughout the river valley
area.
RESPONSE: Al though there may be other areas where foundry. sand has
been disposed of, the landfill at the Folkertsma Refuse site was
found to pose an unacceptable risk to human health and the
environment. CERCLA gives EPA the authority to conduct remedial
actions when there is a release or threatened release of any
hazardous substance, pollutant, or contaminant into the environment
. which may present an imminent and substantial endangerment to human
health and. the environment. At the Folkertsma Refuse site,
unacceptable risks to human health and the environment have. been
calculated for exposure to the landfilled material, groundwater,
and contaminated sediment. These risks exceed EPA's acceptable
risk range of IO-4to lo-G(one additional case of cancer for every
'10,0-00 to 1,000,000 people exposed) and therefore justify an
action. .
COMMENT: The western portion of the landfill should be capped with
top soil or. gravel to prevent exposure: the sediments of the
unnamed creek and drainage ditch should be excavated: and the creek
and ditch should be lined. with clay or tile.
RESPONSE: 'CERCLA requires that all remedial actions comply with
applicable or relevant and appropriate requirements (ARARs). The
capping remedy selected for the Folkertsma Refuse site' must comply
with the Resource Conservation and Recovery Act (RCRA) subtitle D
and the Michigan Solid Waste Management Act (MSWMA). These ARARs
require that a solid waste cap consist of a minimum of two feet of
compadted clay. A soil covering or a layer of gravel alone would
not meet the requirements of these regulations.
COMMENT: Legal counsel for the owner of the site expressed their
concurrence with the comments submitted by the Potentially
Responsibility Party (PRP) group (discussed on the following.
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pages), and also expressed their belief that the Proposed Plan for.
the Folkertsma Refuse site was deficient in that it did not address
the impact of th~ proposed remedy upon present us~s of the site.
RESPONSE: The Proposed Plan supports only preliminary decisions
for a site and includes only observations and tentative'
recommendations. It is not the intent of the Proposed Plan to make
definitive findings or declarative statements that cannot be
revised. As such, EPA believes that the Proposed Plan for the
Folkertsma Refuse site is sufficient in addressing the impact of
the proposed remedy upon present use.s of the site. The description
of the preferred remedy discloses that the site would be fenced to
restrict access, and that deed restrictions would be imposed to
prohibit the installation of water wells beneath the landfilled
portion of the site and any future development which might disturb
the 1andfilled materials. Any other statements regarding the
impact of the proposed remedy on present uses of the site at this
time would be premature, as it is not the intent of the agency to
preclude activities that can be compatible with the clay cap, only
to exclude those activities which may damage the cap material.'
COMMENT: Legal counsel for one of the PRPs summarized the comments
submi tted by the PRP group and expressed their support of these
comments. They additionally submit that the use of institutional
and access controls, alone would be adequate to control human
exposure to the surface contaminants and prevent use of groundwater
beneath the site. .
RESPONSE: EPA does 'not believe that the use of institutional and
access controls alone would be adequate to protect human health and
the environment from the contamination at the Folkertsma Refuse
site. Fencing would not prevent erosion and off-site migration of
the contaminated-1andfi11ed materials; nor would it prevent the
contaminated sediments from 'migrating into Indian Mill Creek and
beyond. In addition, EPA's experience has been that a fence is not
sufficient to prevent humans and animals from coming into cont~ct
wi th contaminated materials, as fences may be crawled under,
climbed, or cut.
A group of Potentially Responsible Parties (PRPs) I for the
Folkerts.a Refuse site submitted several comments in response to
the RI/FS and the Proposed ~lan. These comments are summarized
below with EPA's response. '
COMMENT: Portions of the site are underlain by f~om 3 to 10 feet
of fill material c~mprising foundry sand and construction debris.
There appears to be some inconsistency in the Remedial
Investigation report (RI) regarding the extent of fill material
which may affect where application of the. selected remedy is
appropriate. Specifically, the extent of fill depicted in the map
of Figure 3-5 is greater than that depicted in the Geologic Cross
Section A-A' of Figure 3-3. The former was apparently derived from
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verbal reports while the cross section depiction was generated from
boring log data and, as such, presumably is more reflective of
actual conditions." "
RESPONSE: ~he extent of fill mate~ial depicted" in Figure 3-5 was
not derived from verbal reports. As noted on the figure, the
estimated extent of the landfilled area is based on aerial
photographs dated spring 1969, spring 1976, and the results of the
soil sampling conducted in 1989. If there is a slight discrepancy
between Figure 3-5 and Cross Section A-A', it is because of the
limitations encountered in extrapolating soil boring data into a
cross section. Figure 3-3 is not meant to be a strict portrayal of
the geology directly beneath A-A', but rather a general
representation of the area based on soil boring data obtained from
discrete locations.
COMMENT: The Risk Assessment is designed to represent worst case
conditions, and, as such, follows a conservative approach. A more
realistic approach to risk evaluation is to calculate a "maximum
likely" exposure dose based on a 95% confidence level determined
from a statistical analysis of the data.
RESPONSE: The Risk Assessment for the Folkertsma Refuse site was
conducted in accordance with the Superfund Public Health Evaluation
Manual (SPHEM), the appropriate guidance when the Risk Assessment
was conducted. Under SPHEM, risks are assessed in terms of
probable case conditions and worst case conditions. EPA has since
published a new manual, Risk Assessment Guidance for Superfund
(RAGS), in which risk is assessed in terms of reasonable maximum
exposure. Issuance of the new manual does not invalidate risk
assessments co~ducted under previous guidance. The new guidance
was applied to the Risk Assessment for the Folkertsma,Refuse site
where practical. I
COMMENT: In the evaluation of risks associated with drinking
groundwater underlying the site, EPA's conservative approach
appears to have been carried to an unrealistic extreme because the
analytical results from unfiltered groundwater samples were used in
the evaluation. People do not drink unfiltered groundwater. The
suspended sediments responsible for the elevated an~lytical results
will be filtered out of the water as it migrates through the
aquifer sedime~ts on its way to any potential receptor. Further,
an even marginally designed and constructed water supply well will
remove such sediments through an engineered or naturally developed
filte~ pack surrounding the well screen.
The significance of this assumption to the risk assessment process
is that most of the calculations involved are linear, producing
risk values that are directly proportional to the raw data
(groundwater quality results, in this case) used. As a result, the
apparent risk posed by a given contaminant in the groundwater will
be over 100 times higher for some of the parameters than if the
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realistic (filtered) analytical results had been used. The net
result of this unrealistically conservative approach is that
existing. groundwater quality is portrayed "and treated as
significantly worse than it actually is, elevating concerns about
present and. potential future groundwater quality to inappropriate
levels which are reflected in the remedy selection process.
RESPONSE: Although the use Qf unfiltered groundwater data in "the
risk assessment may be a conservative approach, EPA does not
believe it represents an "unrealistic extreme". Although no one. is
currently drinking the contaminated groundwater beneath the
landfilled portion of the site, EPA must consider that there is a
potential for contaminated groundwater to migrate off-site, and for
wells to be installed in areas of groundwater contamination. In
addition, EPA cannot assume that each of the residences using water
from a contaminated well will have a properly installed and working
filter on the tap.
It is also the position of the Agency that unfiltered groundwater
samples are more representative of the chemical concentrations
found in groundwater from an unfiltered tap. Filtering groundwater
samples may actually underestimate the chemical concentrations
found in unfiltered tap water.
EPA recognizes the assumptions that were involved in assessing the
risks at the Folkertsma Refuse site. EPA has indicated several
times (Proposed Plan, public meeting and Record of Decision) that
the use of unfiltered groundwater data in the risk assessment is a
conservative approac\-.,. EPA has also stated that groundwater
contamination is limi~ed to the groundwater beneath the landfill,
and that no one is currently using this groundwater as a water
supply. EPA further explained that filtering the groundwater
samples removed or reduced the contamination to below Maximum
contaminant Lavels (MCLs) established under the Safe Drinking Water
Act.
The assumptions involved in assessing the risks at the Folkertsma
Refuse site are reflected in the selected remedy. EPA believes it
is more appropriate to implement institutional controls such as
deed restrictions and groundwater monitoring at the site rather
than install a system which would pump and treat contaminated
groundwater. The deed restrictions would prevent exposure to
contaminated groundwater by prohibiting the installation of water
supply wells beneath the landf~lled portion of the site, and
groundwater monitoring would ensure that the chemical
c~ncentrations in the groundwater did not increase. In addition,
the low-permeability nature of the cap would also enhance the
effectiVeness of the deed restrictions by reducing infiltration and
the potential for further groundwater contamination.
CO~ENT: One critical assertion regarding the groundwater on page
6-13 of the RI states: "Total metals were analyzed for in both
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unfiltered and filtered samples. The results for the two fractions
were very, similar, indicating that the majority of metals present
were dissol ved in the groundwater samples." This statement
directly contradicts interpretations presented elsewhere and is not
supported by the analytical results for filtered and unfiltered'
samples presented .in Table 4-6 of the RI which shows declines
exceeding two orders of magnitude (lOO-fold) in some cases when
comparing the filtered to the unfiltered results. Additionally,'
the two unfiltered shallow groundwater samples that exceeded the
ARAR of 50 parts per billion (ppb) (the Safe Drinking Water Act
Maximum Contaminant Level (MCL) for arsenic), and contributed to
the unrealistic exposure dose calculation, failed the Contract
Laboratory Program quality assurance protocol. Although not a
catastrophic quality assurance failure, the discrepancy in the,
matrix spike recovery does cast some doubt on the validity of the
analytical results and calls into question the appropriateness of
basing even "worst case" risk assessments on these'numbers.
RESPONSE: The statement on page 6-13 is incorrect. The sentence
should have read: "The results for the two fractions were
dissimilar, indicating that the majority of metals present were
sorbed onto particulate matter in the groundwater samples."
Although the discrepancy in the matrix spike recovery indicates
that the actual concentrations of arsenic detected i~ these samples
may have been overestimated or underestimated (they were reported
as 287 ppb and 116 ppb), the presence of the chemical is verified,
and, risk as,sessment guidance indicates that this data may be
included in the quantitative risk assessment. In addition,
comparison with the risk analysis for the ingestion of unfiltered
de~p groundwater indicates that unacceptable risks to human health
have been calculated for arsenic concentrations as low as 12 ppb.
As such, it appears likely that the arsenic detected in the shallow
groundwater, regardless of the uncertainty associated with
conc~ntration, results in unacceptable risks to human health.
COMMENT:" Individual cancer potency factors (toxicological data) do
not exist for three of the five polynuclear aromatic hydrocarbons
. .. ,
(PARs) of concern. In the absence of J.ndJ.vJ.dual data, the potency
factor for benzo(a)pyrene was used to represent the toxicity of the
other chemicals. Although the qualification is made that'this may
overestimate the risks posed by these compounds, it is still a
conservative assumption on the part of the Agency.
RESPONSE: Although individual cancer potency factors do not exist
for the other PARs (benzo(a) anthracene, benzo(b)fluoranthene,
0dibenzo (a, h) anthracene and chrysene), the most recent studies
conclude that these PARs are probable carcinogens. Benzo(a)pyrene
has been the most widely studied of the PAHs, and research
indicates ,that most of the data pertaining to benzo(a)pyrene is
applicable to all PAHs, especially those that are carcinogenic. As
such, the Agency uses the cancer potency factor for benzo(a)pyrene
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in calculating the risk from all carcinogenic PAHs.
COMMENT: The exposure scenario for the inhalation of fugitive dust
is overly conservative. The only risk in excess of EPA's 1 x 10-4
acceptable threshold appears to be to adults living and working at.
the site boundary. The risk is based on the assumption that
contaminated dust will be generated during the on~site operation of '
all terrain vehicles (ATVs). This assumption is unrealistic, as
the operation of ATVs on the site will be precluded by the
'institutional controls and fencing included in the selected remedy.
In addition!, the only contaminant theoretically posing a risk above
the 1 x 10-~hreshold is chromium. For chromium, the conservative
assumption is made that all of the chromium present is the toxic
species, hexavalent chromium. The statement is made elsewhere in
the report that hexavalent chromium realistically probably
constitutes less than one percent of the total. Experience at
other sites has shown that chromium in the environment is virtually
never of the hexavalent species as reduction through time converts
the hexavalent fraction to trivalent chrome. Even if the actual
percentage of hexavalent chromium approached thirty, the resulting
estimated risk would fall below the 1 x 10-4threshold.
In light of the critical significance of this highly questionable
assumption, a limited program of sampling and laboratory analysis
was undertaken to assess the validity of the assumption. Samples
of shallow fi}l (foundry sand) were taken at or near four locations
indicated by the RI data to contain detectable levels of chromium~
At each location, samples were taken at the surface and at a depth
of one or two feet below grade as permitted by site c~nditions.
The results of these analyses demonstrate conclusively that the
c~rome in the shallow fill at the site is, in fact, the 'trivalent
species, rendering the contrary assumption in the risk assessment
excessively conservative and inaccurate. There are no
toxicological data demonstrating that trivalent chrome is
carcinogenic; in ,the absence of hexavalent chrome, the resulting
theoretical risk falls well below the 1 x 10-4threshold. This
finding indi~ates that the concerns about airborne dust from the
site are unfounded. ' '
RESPONSE: The components of remedial action cannot be considered
when assessing the risks at a sit.e. This'would defeat the purpose
of risk assessment, as well as be inconsistent with the NCP. The
objective of risk assessment is to characterize current and
potential threats to human, health and the environment posed by
contaminants at or released from a site, under baseline (e.g. no
remedial action) conditions. The results of the baseline risk
assessment are used to determine if an action is warranted, and
then to develop the remedial alternatives. consideration of
remedial action in the baseline risk assessment ~~u~d only mask the
potential risks at a site. As such, fencing dnd institutional
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(,
.controls cannot be considered when determining exposure scenarios
for the baseline risk assessment.
The assumption that all chromium present at the site is hexavalent
chromium is conservative. EPA does not believe, however, that the '
results of eight samples from four locations are adequate to'
"demonstrate conclusively" that the chrome in the shallow fill a:t
the site is entirely .of the trivalent species. It is also
debatable as to whether the eight sampies were actually taken "at
or near" the four locations indicated by the RI data to contain.
detectable levels of chromium: two of the samples are shown as'
being approximately fifteen feet from the corresponding RI sampling
locations: the other two are shown as being between forty-five and
fifty feet from the corresponding RI' sampling locations. , In
addition, chromium (total) is a contaminant regulated under the
Safe Drinking Water Act. Even if the inhalation risks are
overestimated, the Agency would still be concerned about the
potential impacts of chromium on groundwater.
As such, EPA believes that the data and assumptions used in the
risk assessment are valid, and thereby believes that exposure to
airborne dust presents a potentially unacceptable risk. Even if
the ri~k for exposure to airborne dust is overestimated, there are
still potentially unacceptable risks for exposure to the landfilled
materials through direct contact and ingestion.
'COMMENT: Other factors contributing to the overly conservative
nature of the risk assessment are apparent discrepancies in values
used to calculate the exposure frequency and those used to
calculate particulate air emissions from the Folkertsma Refuse
site, and the use of concentration values from samples collected
,from, one to eight feet below land surface in the inhalation
exposure endangerment assessment for all indicator parameters with
the exception of PAHs. The RI appropriately uses adjustment
factors for windless days and precipitation when calculating
particulate emissions from the site, however, these corrections are
ignored when estimating both probable and worst case exposure
scenarios for windborne material. When calculating the inhalation
exposure for the endangerment assessment for PAHs, :the RI used
concentration values from that fraction of surface soil samples
that would pass a 200 mesh sieve (diameter < 75 uM). This fraction
represents the portion likely to become ~irborne. For all other
including chrome, concentration values for samples collected at
depth were used.
These Ipractices introduce unrealistic components to the airborne
risk assessment through several avenues, 1) chemical concentrations
from samples collected at depth may not be representative of levels
likely to become airborne, 2) PRC's data indicate, as might be
expected, that the proportion of sample that passes the 200 mesh
sieve - and correspondingly the respirable portion -"increases with.
depth.
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RESPONSE: At the Folkertsma Refuse site, factors for windless days
and precipitation were taken into consideration when determining
the amount of particulate emissions from the site. As these
factors (i.e., windless days and precipitation) were used in the
calculation for particulate emission intake, it would have been
inappropriate to adjust for these factors again when determining'
the exposure frequency. This, would have resul ted in
misrepresenting the exposure dose.
As the airborne concentrations of inorganic compoun~s are based on
unsieved soil samples collected from 1 to 8 feet below the land
surface, EPA cannot definitively assert that these conce~trations
are representative of levels likely to become airborne. Sieved
surface soil data for inorganic compounds is not available.
Considering these factors, EPA does believe that there may be some
uncertainty in the risks calculated for the inhalation exposure
pathway. EPA does not believe, however, that the analytical
results of the four surface soil samples collected by the
commentator adequately defines the chromium concentrations likely
to become airborne from the site. ' ,
In addition, there is no basis for the statement that PRC's data
indicate that the proportion of sample that passes the 200 mesh
sieve - and correspondingly the respirable portion - increases with
depth. As indicated in the RI Report, the only soil samples sieved
were those collected at the surface. None of the soil samples
collected at depth were sieved. In the absence of data, it is
inappropriate to conclude that the respirable portion of the sample
increases with depth. '
Although EPA believes that there may be some uncertainty in the
risks calculated for the inhalation pathway, unacceptable risks
have been calculated for exposure to the landfilled materials
through ,direct contact and 'ingestion. Even if the risks posed
through inhalation were disregarded, the risks posed through direct
contact and ingestion still support the need for remedial action/at
the Folkertsma Refuse' site.
COMMENT: The risks associated with the Folkertsma Refusp. site are
only marginally above the envelope of risks identified as
acceptabie by EPA. Considering the conservative approach that was
taken in assessing the risk~ at the site, this finding appears
reflective of the reality that the' site poses a truly minimal
threat to human health and the environment.
;
RESPONSE: Although-the Risk Assessment for the Folkertsma Refuse
site may have taken a conservative approach, it was conducted in
accordance with guidance (SPHEM, and RAGS where appropriate) and
the NCP. At the site, risks to human health have been identified
for exposure to landfilled materials and groundwater. The risk
calculated for'direct contact with landfilled materials is 2 x 10-3
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(two additional cases of cancer for every 1,000 people exposed).
Risks associated with the ingestion of landfilled materials and
inhalation of fugitive dust range from 2 x 10-4to 3 x 10-4(two to
three additional cases of cancer for every 10,000 people expose~).'
The ris~ calculated for the ingestion of shallow groundwater is 3
x 10-2.(three additional cases of. cancer for every 100 people
exposed); and the. risk associated with the ingestion of deep
groundwater is 6 x 10-4(six additional cases of cancer for every
10,000 people exposed).
The NCP defines unacceptable risks as those exceeding 1 x 10-4(one
additional case of cancer for every 10,000 people exposed). As the
risks calculated for the Folkertsma Refuse site exceed the
acceptable level of 1 x 10-4,they are, by definition of the NCP,
unacceptable and warrant an action.
COMMENT: The RI data indicate clearly that contaminants conta~ned
in the unsaturated fill materials are essentially immobile,
presenting a negligible potential for migration to underlying
groundwater. The refinement of the understanding of the presence
of hexavalent chrome in the shallow fill should largely resolve
concerns about airborne transport of dust from the site. This
leaves direct contact with and ingestion of fill or ditch sediments
as the only exposure routes by which risk might be incurred. A
low-permeability clay cap clearly is not required to address these
potential exposure routes. Virtually any type of cover material
would serve the purpose. Sand would actually meet the object1ve
but may present an excessive erosion potential if a vegetative
cover cannot be maintained. A sand cover with a veneer of topsoil
to support vegetation, however, might be entirely suitable.
The issue of meeting ARARs would also appear arguable in this case.
Many foundry sand disposal sites in Michigan are regu:..:;ted as
containing "inert, site-specific wastes" and are closed with
minimal engineered safeguards. Many other historic foundry sand
disposal sites in Michigan were never regulated much less "closed"
with engineered features a~d now have residential neighborhoods
built over them.
In light of these realities, it is recommended th~t a cover of one
foot of native soil overlain by six inches of topsoil be considered
for installation at the site. .
I;
RESPONSE: The risks identified for the Folkertsma Refuse site are,
by definition of the NCP, unacceptable and warrant an action.
Under ,CERCLA, remedial actions at Superfund sites must comply with
chemical-specific, action-specific, or location-specific applicable
or relevant and appropriate requirements (ARARs), or a waiver must
be invoked.
The. waste ill the landfill at the Fc:kertsma Refuse Superfund site
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is, 'by definition of the Resource Conservation and Recovery Act
(RCRA), a solid waste. Capping and closure. of solid waste
land£ills are actions which are regulated under RCRA Subtitle D and
the Michigan Solid Waste Management Act 641 (MSWMA 641). Any cover
installed over solid waste landfills must meet the minimum
requirements of these acts. Specifically, these include a minimum
of two feet of compacted clay cover and a slope not to exceed 1
vertical to 4 horizontal nor~less than 2%. The recommendation of
a cover of one foot of native soil overlain by six inches of
topsoil would not meet the requirements of RCRA Subtitle D and
MSWMA 641, and therefore, cannot be considered further.
COMMENT: The configuration for the cap presented in the Proposed
Plan includes covering the. ditches. Excavating the sediments
be£orehand to prevent contact is clearly redundant in this
scenario.
RESPONSE: The Proposed Plan does not include covering the ditches;
although they will be modified, their functions will remain the
same. In addition to lowering the local water table level, the
ditches will continue to capture surface water runoff from the cap
for site drainage. After sediment excavation, the ditches will be
lined with drainage tile and then filled to the surface grade level
with coarse aggregate. The tile and coarse aggregate will protect
the cap from erosion, as well as prevent contaminated landfilled
materials from eroding from the sides of the ditches and migrating
downstream.
COMMENT: The estima:l!d costs presented in the Feasibility Study
(FS) for sediment excavation in the ditches include significant
expendi tures for dewatering, presumably after excavation and before
they are placed on the fill. While dewatering might be required
for off-site transport and disposal, the rationale for dewatering
these sediments is unclear. It should be noted that the surface
water quality data indicate that these sediments do not contain
leachable contaminants. .
RESPONSE: EPA believes that dewatering the sediments from the
ditches is a sound engineering practice which will technically
enhance implementation of the selected remedy. It is impractical
to spread water-logged sediments over the landfilled materials (or
portions thereof), transforming the currently compacted surface cf
the landfill into a slurry. Delays would be encountered in
allotting time for the sediments to dry out, otherwise grading
would be difficult" i~ not impossible. In addition, the sediments
would detract from the strength of the foundation provided by the
foundry\. sand, and the cap could be prone to excess settl ing in
various locations.
~he costs associated with dewatering the sedinents constitute 2% of
the' capital costs estimated for the selected remedy. Given the
engineering and technical benefits of this practi~e, EPA does not
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con~ider these costs to present a significant expense.
COMMENT: The recommended alternative,' includes converting the
ditches into underground drains. The reasoning behind this is not
presented in the documentation and. cannot be reasonably inferred.
The excavated ditch, explicitly, and the unnamed creek, probably,
were originally installed to dewater the site slightly to
facilitate removal of the peat and muck originally present. In
light of the highly permeable nature of the fill materials at the'
site (as reflected by the gently horizontal hydraulic gradients in
the fill revealed by the RI) and the reduction of infiltration
which will result from virtually any type of cap installed, the
continued need for these drainage features is non existent. The
potential direct contact and sediment transports will be resolved
by removal of the sediments. The $164,000 estimated for the design
and construction of these features (tiled and covered drains),
therefore, is unjustified.
RESPONSE: As discussed in a previous response, the ditches perform
two functions at the site: they lower the local water table level
and promote surface drainage by capturing runoff. These functions
are significant. A lower water table indicates a reduced potential
for saturation of the fill material, and hence leachate formation
and groundwater contamination. In addition, the ditches capture
surface water that would otherwise infiltrate into the landfill.
This also reduces the potential for leachate ,formation anc
groundwater contamination. As such, it is not the intent of the
proposed alternative to alter the functions of the ditches. The
ditches, however, must be modified with drainage tile and gravel to
protect the cap from erosion and prevent contaminated materials
from eroding from the sides of the ditches and migrating
downstream.
COMMENT: The preferred alternative includes the installation of
venting structures through the cap to prevent the buildup of
methane gas or volatile organic compound (VOC) vapors under the
cap. Tois is a 'standard feature of caps placed over municipal
refuse landfills in which methane is generated as the refuse
decomposes. This element of the al ternati ve, however, would appE2~r
to be completely unnecessary at this site. The RI detected no
confirmed VOCs in any media at the site, much ,less at
concentrations which would cause concern about vapor buildup.
Foundry sand does not yield methane gas as it ages. Even if it
did, the fill has been in place for twenty years or more and almost
certainly has come essentially to equilibrium with its environment.
Finally, the proposed vents present several negative features su~h
as jeopardizing the integrity of the cover, unnecessarily
restricting future site use and increased overhead and maintenance
costs.
RESPONSE: ' Although foundry sand may not yield methane gas 3S it
ages, portions of the Folkertsma Refuse site are underlain by
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deposits of muck and peat. In addition, VOCs were detected at low
concentrations at several locations within the landfilled material.
The VOCs detected in the landfilled material include 2-butanone,
xylene, tetrachloroethane, trichloroethene, benzene, carbon
disulfide, acetone, methylene chloride, and toluene. Whenever a
low-permeability cap is placed over material of greater'
permeability, there is a potential for methane gas and VOCs (if
present) to buildup and migrate to other areas (such as basements) .
.At the Folkertsma Refuse site, however, the potential for the
buildup of methane and VOCs is low. This has been recognized by
the Agency and reflected in the selection of a final remedy. The
description of the selected remedy in the Record of Decision (ROD)
reads "a passive gas control system would be installed if '
nece~sary."
COMMENT:- The data on existing groundwater quality at the site
indicate the absence of significant impacts upon usable groundwater
some two decades after disposal at the site was discontinued. This
data should therefore reflect equilibrium conditions for the
unremediated site. Furthermore, the scope of the monitoring
program outlined in the FS looks like it is designed more for an
uncoDtrolled site in which chlorinated solvents had been placed.
It includes sampling ten wells four times a year and analyzing each
sample for complete scans of organic and inorganic parameters.'
It seems mucp more reasonable to design a monitoring program
tailored to known and reasonable expectable conditions associated
with the site and reflecting the essentially static nature of site
processes. In such an approach, the analytical parameter list
would be pared to one reflective of present knowiedge and
monitoring frequency might decline through time if no unexpected
findings appear.
RESPONSE: The ten existing wells to be sampled in the FS included
three shallow and three deep wells downgradient of the landfilled
area, three shallow wells screened beneath the fill materials, and
one upgradient shallow well. These wells, the'parameters to be
analyzed, a,,'j the sampling frequency cmtlined in the FS were
utilized primarily for costing purposes. The ROD states that the
specific details of the groundwater monitoring program will b~
d~veloped in the Remedial. Desig~. -
COMMENT: . Given that concerns about direct contact with or airborne
migration of contaminants will be resolved by the proposed cap, it
appears that the primary purpose of the proposed fence is to
protect the cap. The primary threat to the cap is inappropriate
vehicular traffic and the fencing program proposed shouJd reflect
a level of protection appropriate to this threat. A six-foot high,
chain-link fence with three strands of barbed wire would be
e~cessive in the prevention of entry by all-ter~ain vehicles.
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RESPONSE: Although EPA is concerned about protecting the integrity
of the clay cap, the main objecti,re of the fence is to restrict
unauthorized access. during construction of the remedy. Many
activities will be going on during this time: on-site.
mobilization, clearing and grubbing, construction of the additional.
access road, decontamination, sediment excavation and conversion to
underground drains, consolidation of contaminated materials.,
grading, and installation of the cap. Trespassers may be exposed
to site contaminants, or hurt themselves by falling over
construction debris and other equipment. In addition, some.
trespass~rs may be inclined to vandalize the trailers or other
property. It has been the experience of EPA that measures such as
barbed wire are necessary to deter unauthorized access to site
premises during construction. In addition, the site currently, has
an operating pallet company on the property. A permanent fence
will not only preclude unauthorized access to the site during
construction, but will also prevent access to the cap over the
long-term.
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