United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPAIRODIROS-91/160
June 1991
oEPA
{CSfy (
'P8'fz..-1C,4110
"
i
Superfund
Record of Decision:
Verona Well Field, MI
u. S. Environment I ~ '''.' .'
Region Itl Haza d a rotection AQency
J:~hc~a' :nfor~a~l~ ~::.
Ph;'ade,~~;:.~~tr~~ j O~h Floor. .
"'.~
Hazardous Waste CoIectIon ';
. tnformotfonResowce Center.
US~A Region 3
iPhlOde.fphJo,. PA 19107
-------
S0272-101
REPORT DOCUMENTAT10N 11. AEPORTNO.
PAGE EPA/ROD/ROS-91/160
4. nt. 8IId SIMIle
SUPERFUND RECORD OF DECISION
Verona Well 'Field, MI
Jecond Remedial Action - Final
I-
7. AuIhor(8)
t. fIWfonnklo 0rpInIa1I0n ...... 8IId AddN88
,
12. 8pcM~ Org8/Uallon ...... 8IId AdIhu
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
15. au..--.ry No..
12.
3. A8c:IpIenr. "-aIon No.
5. Report D8te
06/28/91
I.
8. P8rtOnnlng Org8nlzatlon Rept. No.
10. Proj8ctlTuklWOItI UnI1 No.
11. Contract(C) 01' Gr8nI(G) No.
(C)
(G)
13. Type of R~ & Pwtod CoV8l8d
800/000
14.
16. Abatract (UmIt: 200 -.)
The Verona Well Field site consists of a well field, three contaminant sources, and the
ground water between the Source areas and the well field in Battle Creek, Calhoun
County, Michigan. Surrounding land use is mixed residential and industrial. Part of
the site lies within the 100-year floodplain of the Battle Creek River, which runs
southwesterly through the site. The site overlies a surficial glacial aquifer and a
deeper bedrock aquifer, both of which are local Sources of drinking water. The
estimated 53,000 people who reside within the city of Battle Creek and several
-'lrrounding communities and industries use the Verona Well Field, screened within the
drock aquifer, as their primary drinking water source. From 1964 until 1984, the
xnomas Solvent Company stored, blended, repackaged, distributed, and disposed of
industrial solvents at both their Thomas Solvent Raymond Road (TSRR) facility and their
Thomas Solvent Annex facility. Three source areas of contamination have been
identified onsite, including the TSRR and Annex facilities, and a paint shop in the
Grand Trunk Western Railroad (GTWRR) marshalling switching yard. Contamination of the
onsite soil has resulted from surface spills, leaking drums, and leaking underground
storage tanks. During the 1960's and 1970's, the paint shop in a car department at the
(See Attached Page),
17. IIoc:&8Mnt AnaJpIa L oMcrtpto..
Record of Decision - Verona Well Field, MI
Second Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes),
(phenols), metals (arsenic, chromium)
b, IcIentlfl8ralOpan-End8d Tenne
e. COO" TI FlalcltGroup
18, Avllil8bllty ~
-
(s...
".18)
SHm.Irut:fI- on~-
18. SecurIty CIaaa (Thi. Report)
None
20. SecurIty CIaaa (ThIa "'118)
"'''''';.0
other organics
21. No. of P8gea
152
22. Price
(Fonnerty NTlS-35)
Depertment of Co-at
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EPA/ROD/R05-91/160
Verona Well Field, MI
Second Remedial Action - Final
~stract Continued)
GTWRR used solvents for degreasing and cleaning purposes. Spent solvents were either
disposed of directly on the ground or in a drum pit outside the car department building.
In 1981, ground water contamination was discovered at the site, which resulted in a
number of investigations conducted by the State and EPA. In 1984, an Initial Remedial
Measure (IRM) provided for t~e conversion of 12 production wells into purge wells, and
the installation of 3 new production wells and an air stripper. A 1985 Record of
Decision (ROD) addressed remediation of soil and ground water at the TSRR facility, and
provided for treatment of contaminated soil using vapor extraction with off-gas
treatment, and pumping and treatment of contaminated ground water. This ROD addresses
the second and final operable unit for soil and ground water contamination at the site.
The primary contaminants of concern affecting the soil and ground water are VOCs
including benzene, PCE, TCE, toluene, and xylenes; other organics including phenols; and
metals including arsenic and chromium.
The selected remedial action for this site includes treating soil at the Thomas Solvent
Annex and the GTWRR paint shop area using in-situ soil vapor extraction; continuing the
operation of the existing purge wells and air stripper; installing additional purge
wells, and treating extracted ground water from the well field and source areas onsite
using air stripping and vapor phase carbon adsorption, with onsite discharge to surface
water; and monitoring ground water, soil, surface water discharge, and air. The
estimated present worth cost for this remedial action is $15,300,000, which includes an
annual O&M cost of $840,000 for a maximum of 30 years.
PERFORMANCE STANDARDS OR GOALS: Clean-up goals for soil and ground water are based on
State standards. Chemical-specific goals for soil include benzene 20 ug/kg,
~ 10 ug/kg, TCE 60 ug/kg, toluene 16,000 ug/kg, xylenes 6,000 ug/kg, arsenic 0.4 ug/kg,
_old chromium 2,000 ug/kg. Chemical-specific goals for ground water include
benzene 1 ug/l, PCE 0.7 ug/l, TCE 3 ug/l, toluene 800 ug/l, xylenes 300 ug/l,
arsenic 0.02 ug/l, and chromium 100 ug/l.
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RECORD OF DECISION
SELECTED REMEDIAL ALTERNATIVE
Sit. Mam. and Location
Verona Well Field Site
Battle Creek, Michigan
8tatement of Basis and Purpose
This decision document presents the selected final remedial action
for the Verona Well Field Site in Battle Creek, Michigan developed
in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 (CERCLA),
and, to the extent practicable, the National Contingency Plan.
This decision is based on the administrative record for this site.
The attached index identifies the items that comprise the
administrative record upon which the selection of the remedial
action is bas~d.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in tl1is Record Of Decision, may present a current or potential
threat to human health, welfare, or the environment.
Description of the Selected Remedy
The selected, al ternati ve for the final remedy will address the
principal threats posed by the site. The remaining concerns
include two source areas and the three contaminant plumes affecting
the Verona Well Field. The specific components of the selected
remedy include:
- Continued operation of the existing blocking wells and air
stripper in the Verona Well Field;
- Installation and operation of additional purge wells
downgradient of the source areas, and groundwater treatment
(utilizing air stripping with vapor phase carbon) for
. extracted groundwater;
- Collection and treatment (utilizing air stripping with vapor
phase carbon) of contaminated groundwater at the Thomas
Solvent Annex and Grand Trunk Marshalling Yard Paint Shop
source areas;
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- Installation and operation of soil vapor extraction (SVE)
systems to re~ediate contaminated soils at the Annex and Paint
Shop source areas;
- Continued operation and maintenance of the groundwater
extraction system including the installation of additional
groundwater extraction wells;
CJ
- Installation of a treatment system for extracted groundwater
(utilizing air stripping with vapor phase carbon); ~nd
- Implementation of groundwater, soil, surface water discharge,
and air monitoring programs to monitor the treatment systems.
Declaration
As required by Section 121(a) of CERCLA, the selected remedy.is
protective of human health and the environment, attains Federal and
State requirements that are applicable or relevant and appropriate
for the remedial action, and is cost effective. This remedy
satisfies the statutory preference for ,remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal
element and utilizes permanent solutions and alternative treatment
technologies to the ~naximum extent practicable for this site.
Because this remedy will not result in hazardous substances
remaining on-site above health-based levels, the five-year review
will not apply to this action.
state Concurrence
The State of Michigan concurs with the selected remedy for the
Verona Well Field site. The letter of concurrence is forthcoming.
I
6P5!r1.
I
Valdas v. Adamkus
Reqiona Administrator
Date
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~
o
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
VERONA WELL FIELD SITE
BATTLE CREEK, MICHIGAN
Prepared by
u.S. Environmental Protection Agency
Region V, Chicago, Illinois
June 1991
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III.
IV.
v.
n.
nI.
VIII.
Table of Contents
I.
Site Name and
Location. . . . . . . . . . . . . . . . . . . . . . . . . . . .1
II.
Site History and Enforcement ......................2
A. Site Hi&itory.................................... 2
B. History of Source Areas.........................3
. C. Response Actions................................ 4
D. Remedial Investigation/Feasibility Study........?
E. Enforcement Activities..........................?
D
Highlights of Community Participation.............~9
Scope and Role of Operable Unit...................10
Site Characteristics..............................10
A. Geology and HydrogeologY.......................10
B. Nature and Extent of Contamination.............11
1. Site Wide Groundwater Investigation.........11
2. Thomas Solvent Raymond Road.................12
3. Thomas Solvent Annex........................13
4. Grand Trunk Western Railroad................14
Summary of Site Risks.............................1S
A. Identification of Contaminants of Concern......16
B. Exposure Assessment............................16
C. Toxicity Assessment............................17
D. Risk Characterization.~........................18
\
Description of Alternatives.......................18
A. Response Objectives............................18
B. Development of Alternatives....................19
C. Alternatives.................................. .21
Alt. 1 No Action..~............................21
Alt. 2 Additional Purge Wells..................21
Alt. 3 Groundwater Collection and Treatment....22
Alt. 4 In-Situ Soil Treatment..................23
Alt. 5 Soil Excavation and Thermal Treatment...24
Alt. 6 Groundwater Treatment and In-Situ
Soil Treatment..........................25
I Alt. 7 Groundwater Treatment and Soil
Incineration............................26
Alt. 8 In-Situ Groundwater and Soil Treatment..26
Summary of Comparative Analysis of Alternatives...2?
A. Threshold Criteria.............................28
1. Overall Protection of Human Health and
the Environment.............................29
2. Compliance with ARARs.......................29
B. Primary Balancing Criteria.....................29
1. Long-term Effectiveness and Permanence......29
2. Reduction of Toxicity, Mobility and Volume..30
3. Short-term Effectiveness....................30
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IX.
x.
XI.
XII.
4. Implementability........................... .31
s. Costs....................................... 31
C. Modifying Criteria.............................31
1. state Acceptance............................32
2. Community Acceptance........................32
. D. Summary............... ~ . . . . . . . . . . . . . . . . . . . . . . . . 32
Remediation at Thomas 'Solvent Raymond Road........33
°A. Conclusions of Performance Evaluation..........33
B. Alternatives....~..............................34
TSRR Alt. 1 Intermittent Operation of SVE and
Groundwater Extraction Systems.....34
TSRR Alt. 2 Modify the Existing SVE and
Groundwater Extraction Systems.....34
3 Radio Frequency Heating of Soil....35
4 Steam/Hot Air Injection............35
5 steam/Hot Air Injection with
In-Situ Soil Mixing................35
TSRR Alt. 6 Groundwater Aeration...............35
C. Summary of Evaluation of Alternatives..........36
1. Effectiveness...............................36
2. Implementabili ty. . . . . . . . . . . . . . . . . . . . .'. . . . . . .36
TSRR Alt.
TSRR Alt.
TSRR Alt.
3. Costs....................................... 37
D. Summary........................................ 37
Selected Remedy.................... ~ . . . . . . . . . . . . . .38
Statutory Dete~minations..........................40
A. Protection of Human Health and Environment.....40
B. compliance with ARARs......................... .41
1. Chemical Specific ARARs.....................41
2. Location Specific ARARs.............~.......42
3. Action Specific ARARs.......................43
C. Cost Effectiveness.............................43
D. Utilization of Permanent Solutions and
Alternate Treatment Technologies to the
Maximum 'Extent Practicable.....................44
E. Preference for Treatment as a Principal
Element. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44
Documentation of Significant Differences..........45
Responsiveness Summary
Attach1:lent I
State Letter of Concurence
Attachment II
I
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SUMMARy OF REMEDIAL ALTERNATIVE SELECTION
VERONA WELL FIELD SITE
BATTLE CREEK, MICHIGAN
.>
I. SITE NAME AND LOCATION
"
The Verona Well Field Superfund site is located in the northeast
section of the City of Battle Creek, Calhoun County, Michigan.
The site includes the well field, three contaminant sources, and
the groundwater between the sources and the well field (see Figure
1).
,
The Verona Well Field is the primary source of drinking water for
the City of Battle Creek, a city of approximately 36,000 residents
in south central Michigan. The well field also provides drinking
water for several surrounding communities, for a total of
approximately 53,000 residents, three major food processing
industries, and numerous other commercial and industrial
establishments.
The Verona Well Field is located on both sides of the Battle Creek
River, within the gently rolling alluvial valley of .the River. The
valley floor is relatively flat and approximately one mile wide at
the well field. The Battle Creek River flows southwesterly through
the site towards its junction with the Kalamazoo River
approximately 3 miles downstream. Its average flow rate at the
well field is 200 cubic yards per second. The aquifer beneath the
Ve:ona Well Field consists of unconsolidated glaciofluvial sands
from the Pleistocene period overlying Mississippian Age sandstone
bedrock.
prior.to becoming contaminated, the Verona Well Field contained 30
production wells. Currently, thirteen of the original wells are
used, however eight of those wells are under restricted use by the
City due to the periodic presence of low levels ot contamination.
Three new wells were added in the northern part of the well field
in 1984 by V.ST EPA as part of an initial remedial measure. Four
additional production wells were added in 1990 by the City. Twelve
of the original production wells have been converted into
extraction wells to block contamination from moving northward in
the w£ll field (see discussion in section II. C.). In 1989, the
average daily pumping rate from the well field was 12.7 million
gallons per day.
The area surrounding the well field includes three residential
areas containing single family dwellings, and pockets of light and
heavy industry. The largest of the residential areas borders the
well field to the south. The Grand Trunk Western Railroad (GTWRR)
marshalling yard borders the well field to the east. A large
undeveloped wetlands area is located north of the well field.
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RAYMOND ROAD
@
(Geologic c:ro.. ncllon .hown
on Flgur. 9.
o
I
1/-1
SCAlE IN MIlES
1/2
'AYMOND lOAD
lANDfill
Figure 1
VICINITY MAP
VERONA WEll FiElD
BATTlE CREEl<. MICHIGAN
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2
Further south beyond the residential area are the Thomas Solvent
Company facilities, the Raymond Road facility and the Annex (see
Figure 1). These two facilities and the GTWRR paint shop (located
at the marshalling yard) are the identified source areas for the
contamination at the Verona Well Field.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
Contamination in the Verona Well Field was first discovered in
August 1981 when a number of the City's supply wells were found to
be contaminated with volatile organic compounds (VOCs).
Sub$equent sampling by the Calhoun County Health Department showed
contamination in nearly half of the 30 supply wells as well as
several private wells within the residential area to the south of
the well field. .
The Michigan Department of Public Health began s~mpling private
welle in September 1981 and determined that 80 residential wells
were contaminated. Several of the wells contained concentrations
of total VOCs greater than 1000 micrograms per liter (ug/l), with
one well containing greater than 3,900 ug/l' of VOCs.
Following the discovery of contamination in the private wells, the
affected residents were provided with bottled water and pUblic
showers. At that time, efforts began to connect affected
r.esidences to the City water supply. By early 1984, all affected
homes and businesses had been connected or offered. connection.
At the same time, the City of Battle Creek undertook actions to
maintain its water .supply. The most highly contaminated wells were
removed from service, and water from less contaminated wells was
blended with clean water. The City also attempted to remove
contaminants.from the groundwater by pumping water from two of the
most contaminated wells directly to the Battle Creek River.
The site was added to the National Priorities List in July 1982.
Initial studies conducted in arid around the well field by U.S.
EPA's Technical Assistance Team (TAT) contractor, and by Michigan
Department of Natural Resources (MDNR), identified three sources of
contamination: the Thomas Solvent Raymond Road facility, the Thomas
Solvent Annex facility, and the GTWRR paint shop located in the
marshalling yard (see Figure 1).
Contaminant plumes comprised of VOCs were also discovered to be
migrating from the source areas toward and into the well field
(Figure 2). VOC concentrations in the well field ranged from 1 to
356 ug/l. The major contaminants found at the source areas and in
groundwater include Tetrachloroethene (PCE), Trichloroethene (TCE),
1,2-Dichloroethene (DCE), 1,1,1-trichloroethane (TCA), Benzene,
-------
3
~luene, and Xylene.
~e City of Battle Creek retained the u.s. Geologic Service (USGS)
'to conduct a hydrogeological study of the well field and to produce
e groundwater model of the area. The model was used to simulate
various pumping scenarios to characterize groundwater flow in the
-affected area.
B. Historv of Source Areas
~s Solvent Raymond Road
~e Thoroas Solvent Raymond Road (TSRR) and the Annex facilities
were operated as solvent distribution and collection facilities by
the Thomas Solvent Company from 1964 until early 1984. During the
years of operation, industrial solvents were purchased, stored,
blended, repackaged, and transported. The company also stored,
transported and arranged for disposal of spent solvents from its
customers.
Operations at the TSRR site, the company's primary facility,
en'tailed the handling of virgin solvents, both chlorinated and
nonchlorinated. TSRR contained the company's office, garage and
warehouse. It also contained 21 underground storage tanks ranging
in size from 4,000 to 15,000 gallons, used to store solvents
(Figure 3). The tanks were emptied in 1984, and removed in early
~99L
Early investigations at the TSRR area revealed gross contamination
of 'the soils and groundwater resulting from leaks in the
underground storage tanks, leaking drums, and surface spills that
occurred during operation. Contaminants found included PCE, TCE,
TCA, DCE, Benzene, Toluene, Xylene, Acetone, Carbon Tetrachloride,
Chloroform, and Methylene Chloride. In addition to contamination
in soils anci groundwater, a floating layer of nonaqueous phase
liquid (NAPL) was identified at the soil/groundwater interface.
This layer was comprised of pure solvents and mineral spirits
released from the facili~y. The NAPL layer was reported to be
greater than 4 feet at its thickest point. As a result of the
initial - investigations, TSRR was identified as the most
significantly contaminated of the three sources.
~haaas Solvent Annex
The Annex was located on property leased from GTWRR to Thomas
Solvent Company from 1963 until 1984. The Annex facility operation
consisted primarily of the unloading of solvents from railroad tank
cars, but also served as a storage area for 'barrels of spent
solvents. In addition, the Annex contained two underground storage
tanks, a 20,000-gallon above ground tank, a loading dock for barrel
storage, a truck turnaround area, a solvent transfer area adjacent
-------
THOMAS
SOLVENT
ANNEX
Tt lOMAS
SOlVENT
RAYMOND
ROAO
FACILITY
LEGEND
100 fig/! TOTAL VOCs
o
EXISTING BLOCKING WelL
m
~
~ ---- zT
~
en 0 1/4 1/2
-I
:D ~ t :.l
m
!!I SCALE IN MILES
BAILEY
PARK
FIGURE 2
VERONA WEll FIELD
BATTLE CREEK, MICHIGAN
:;;
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N
GROUNDWATER
MONITORING BUILDING
MCC BUILDING
Note:
o . Tank number: corresponds with tank numbers
~
I I
I ,
I I
-~ $DI~
~~IIII
I II ~ ,'.'1 II I' ,
r I I-I
.1 II ~ ,.I}IS
I_I~ ., ~
.0
, ,
, ,
, ,
, ,
..,
BUILDING
(DEMOLISHED)
LOADING DOCK
(DEMOLISHED)
OFFICE
BUILDING
Figure 3
Thomas Solvent Raymond Road
-------
4
to the railroad spur, and a
underqround tanks (Fiqure 4).
were removed by GTWRR in 1990.
Contamination of the soils and qroundwater at the Annex reportedly
resulted from 1eakinq drums and surface spills that occurred durinq
'operations. The major contaminants detected at the site included
PCE, TCE, DCE, TCA, Acetone, Ethylbenzene, Toluene, and Vinyl
Chloride.
small frame structure over the
All three tanks and the bui1dinq
',)
Grand Trunk Western Railroad Marshallinq Yard
The Grand Trunk Western Railroad (GTWRR) marshal1inq yard is an
extensive railroad switching yard containing approximately 30 sets
of tracks and numerous other structures involved in the operation
of the marshalling yard. Among the various bui1dinqs, there is a
car repair shop, and a car department bui1dinq, which includes the
paint shop (see Figure 5). Solvents were used primarily for
degreasing and cleaning as part of operations conducted in these
bui1cinqs.
Contamination of soils and groundwater at the marshalling yard
resulted from solvent disposal practices conducted in the 1960's
and 1970's. According to employees of Grand Trunk, spent solvents
were either dumped on the ground outside the car department
building or disposed of in a drum pit. The drum pit, located just
east of the paint shop, was a 55-ga110n drum half buried in the
'soil with holes for drainage cut in the sides and bottom.
The major contaminants found at GTWRR were PCE and TCA. The
solvent most commonly used by Grand Trunk was Dowc1ene, a
commercially blended product containing PCE and TCA.
C. ResDonse ~ctions
..11 Field Blocking Wells
As discussed above, due .to the, contaminatioll found in several
production wells in the Verona Well Field in 1981, the City of
Battle Creek shifted pumping to the northern most wells in the well
field to avoid contamination. However, contami~ants continued to
miqrate further northward, and by early 1984, 27 of the 30 supply
wells were contaminated.
In an effort to mitigate the continued spread of contaminants and
to provide the City with an adequate supply of drinkinq water, U.S.
EPA and MDNR undertook an Initial Remedial Meas~re (IRM) in May
1984. The IRM consisted of the conversion of 12 of the southern
most pr.oduction wells into blocking (purge) wells, the installation
of three new production wells in the well field, and the
installation of an air stripper to treat contaminated water
-------
@
0 50 100
SCALE IN FEET
(1
LEGEND
£MME'n
S't~EEt
\ "
\ I d:) TANK
\' I CONTROL
\ I ' I BUILDING
\ \ \ " " /
ABOVE \ \'- ~..... ,,/
GROUND \ \ "'SOLVENT
STORAGE \ I,,; TRANSFER
TANK ~ \ /:' STATIO
\ ' I \
EJI I X
, I JI
I 'U'
I \
1\'
I \ \
I \ "
I \ \
/ \ '.
/ \, \
/ \ \
I \ \
I , \
\ T
\ I
, /
'- /
.... ,,;
---
---
PERIMETER OF GRAVEL DRIVE
I
i
\
I
\
\
\
\
Figure 4
THOMAS SOLVENT ANNEX
VEI
a:I
LOADING
DOCK
-------
MARSHALLING
YARD
z-----
o 1 OOF T
~ ~
SCALE IN FEET
DRUM ------- . -.----
DISPOSAL 0
PIT
m
c
::u
-t
o
z
::u
o
~
o
FICUE 5
GRAtD TRUNK WES1EAN RALAOAD CAR DEPAR1UEN1.
PANT SHOP MEA
VE:RONA WEU fiELD
BA TTlE CREEK. MICHIGAN
-------
5
extracted by the blocking wells.
The blocking wells are designed to intercept contaminants as they
enter .the well field from the south thereby preventing the
contamination from reaching wells north of the blocking wells. Of
the 12 production wells converted to blocking wells (V18 through
V29), six wells presently serve as the blocking line (V22, and V24
through V28). Total flow from the blocking system is approximately
1500 - 1700 gallons per minute (gpm). See Figure 2 for location of
blocking wells in the well field.
,.
'Water from the blocking wells is treated in an on site air stripper
and discharged to the Battle Creek River. Extracted water from the
blocking wells is piped to a wet well and then pumped to an 'air
stripper for treatment. Off gas from the stripper is treated on
two vapor-phase carbon adsorption vessels. The activated carbon in
the vessels is periodically regenerated to destroy contaminants.
The installation of the blocking wells was completed in May 1984
and construction of the air stripper was completed in September
1984. During the interim period, a temporary activated carbon
system was used to treat the water extracted from the blocking
wells.
The IRM also included installation of three new production wells to
ensure an adequate supply of drinking water and to help replace
water supply capacity lost in creating the blocking line. The
wells, V51, V52, and V53, were installed north of the existing
production wells in the well field. The capacity of the wells is
~pproximately 6 million gallons per day. These wells were in
production by July 1984.
As early as October 1984, MDPH reported that 14 of the City's wells
were uncontaminated. Since that time, the City's "tap" has been at
or below detection limits for VOCe;. The blocking wells have
remained in operation to date, and the City of Battle Creek
presently uses 18 of its. wells for water supply 'production. Of
these, 10 are identified as uncontaminated aad 8 are under
restricted use by the City due to periodic or potential
contamination.. . Contamination in these wells is due in part to
other sources including spills and leaks from gasoline stations in
the area. In addition, since 1984, there have been a number of low
level .VOC detections north of the blocking line in the well field.
Altho~gh the actual cause of these incidents of contamination has
not been determined, migration of contaminants through or around
the blocking wells is suspected. Alternately, it may be a result
of residual contamination from before the blocking line was
installed.
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6
80urce Remediation at Thomas Solvent Raymond Road
In August 1985, U.S. EPA finalized a Record of Decision (ROD) for.
the remediation bf soils and groundwater at the TSRR facili ty.
. This w~s an operable unit ROD to deal immediately with the most
severely contaminated of the three source areas. The ROD called
for soil vapor extraction (SVE) with off gas treatment for soils
and groundwater extraction (GWE) and treatment for contaminated
groundwater.
The GWE system originally consisted of nine extraction wells
installed at the TSRR facility and immediately downgradient.
CUrrently, eight extraction wells are operational (see Figure 6).
The wells, finished in the unconsolidated sands, remove
approximately 350 gpm of contaminated groundwater from the site.
The water from individual wells is pumped to a common header before
being pumped to the wet well and the existing air stripper at the
well field for treatment. During the first six months of
operation, water from TSRR required pretreatment with aqueous
carbon prior to air stripping due to the high level of
contamination in the extracted groundwater.
The GWE system has been operational since March 1987. Through
December 1990, approximately 14,000 pounds of priority pollutants
have been removed through the GWE system. Total VOC concentrations
have decreased from greater than 19,000 ug/l to less than 1000
ug/l.
.The SVE system removes contaminants from the unsaturated soil zone
by vacuuming soil vapor from the soil through extraction wells that
extend from the ground surface into the top three to five feet of
the water table. The system includes the extraction wells, an
air/water separa~or, off-gas treatment equipment, and two Vacuum
pumps. Figure 7 sho~s a simplified schematic of the SVE syst~m.
The SVE system at the TSRR facility originally consisted of 23
wells. Following removal of the underground storage tanks in
January 1991, the SVE system was rebuilt and now includes 20 wells,
two of wpich are dual extraction wells (see Figure 8).
Off gas treatment of soil vapors was originally accomplished using
Carbon adsorption. . In January of 1990, carbon was replaced with
catalytic oxidation (CATOX), a form of vapor incineration. The
CATOX unit provide~ more cost effective treatment of vapors and
provided for contaminant destruction on si te. Following tank
removal in January of 1991, the CATOX unit was replaced by carbon.
Due to 'greatly reduced levels of VOCs in the off gas, it is now
more cost effective to use carbon adsorption.
The. SVE system was pilot tested in November 1987, and full-scale
operation began in March 1988. Through December 1990, the SVE
system has removed approximately. 45,000 pounds of priority
pollutants. VOC concentrations have been steadily decreasing from
J
-------
N
I)
~EW,
MONITORING BUILDING
MOTOR
CONTROL
CENTER
EXTRACT10N FORCE MAIN PIPE
TO TREATMENT SYSTEM
~
EW2
~
EW~
~
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L~"'d :
~ GROUNDWATER EXTRACTION WELL
~TYPICAL GROUNDWATER
i---' EXTRACT10N WELL
.
i EWI",
I ..,
. ..
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i~ EW7 '..,
.EW,
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.
~,
OFFICE
BUILDING
Figure 6
Groundwater Extraction
System Layout
Thomas Solvent Site
-------
TYPICAL SOil VAPOR
EXTRACTION WEll
AIR-WATER
SEPARATOR
AIR
flOW
AIR flOW
OFFGAS
TREATMENT
SYSTEM
PIPING
CONTAMINATED ZONE
Figure 7 . .
Schematic of Soli Vapor
Extraction System
Thomas Solve"1 Site
-------
A
, EW2
<)
x-x-x-x-x
I ,
x A x
I EWS \c
x ,
J x,
I VE.31 ~~
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x EW6 x
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Scale in Feet
60
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MON !TORING
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A VE.24
EW9
VE.25
VE.17
OECONTAMINATION
PAO
VE.18
VE-20
LEGEND
~ SOIL VAPOR EXTRACTION (SVE) WELL
A GROUNOWATER EXTRACTION WELL
Figure 8
Soil Extraction System
Thomas Solvent Site
-------
7
over 1,000 pounds per day initially, to less than 10 pounds per day
currently. Total VOC concentrations in the off gas have decreased
from 23,000 ug/l in April 1988 to 38 ug/l in September 1990. As a
result of this remedial action, the contaminant levels at the TSRR
facili~y have been dramatica~ly reduced.
D. Remedial Investiaation/Feasibilitv Study
Tbe U.S. EPA began its initial remedial investigation CRI) work in
November 1983. The purpose of the initial RI work was to identify
sources of contamination to the well field and to characterize the
contamination at the site. This RI work was separated into two
phases, the results of which were published in technical memoranda
dated November 1984 and May 1985 respectively.
In February 1984, in response to the worsening conditions in the
well field u.s. EPA initiated a focused feasibility study (FFS) to
address the water supply problem, while the RI for the overall.
cleanup proceeded. In May 1984, U.S. EPA finalized the ROD to
implement the IRM at the well field (see discussion in Section
IIC). ,
In February 1985, U.S. EPA determined that source control at the
TSRR facility should be implemented because of the severity of
contamination identified at that facility. A phased feasibility
study (PFS) was completed in May 1985, and a ROD finalized in
August 1985 (see discussion in Section IIC).
The results of the initial RI work were memorialized in a draft RI
report dated March 1986. This RI report was never finalized
because U.S. EPA determined that additional RI work was needed to
completely characterize the site.
In 1987, U.S. EPA approved the work plan for the final phase of RI
work. Field work was conducted between December 1988 and August
1989. The RI report and baseline risk assessment for the site were
published in August 1990. The feasibility study CFS) and the
proposed plan (PP) for the final remedy were released for pUblic
comment in February 1991. The results of the final RI/FS are
discuEsed in the following sections.
E. Enforcement Activities
Initial. enforcement efforts focused on two identified potentially
responsible parties (PRPs), Thomas Solvent Company (TSC) and Grand
Trunk Western Railroad (GTWRR). Both PRPs declined to conduct the
nI/FS in April 1983, and both declined, in April 1984, to undertake
the. immediate removal/IRM in the well field.
In January 1984, the State of Michigan filed suit against TSC in
State court. That lawsuit sought, among (')ther things, court
-------
8
v
ordered abatement of groundwater contamination. In March 1984, the
Calhoun County Circuit court ordered TSC to install and operate
groundwater extraction wells at the TSRR facility.
In February 1984, U.S. EPA issued a unilateral Section 106
Administrative Order to TSC to remove a floating product layer from
.beneath its Raymond Road facility. TSC complied with the order
initially, and 500 gallons of contaminated water were removed from
the site.
However, in April 1984 TSC filed a Chapter 11 petition under the
Bankruptcy Code. U.S. EPA and the U.S. Department of Justice (U.S.
DOJ) filed a proof of claim based on money owed to the federal
government by TSCfor costs spent at the site. As a result, a
settlement was embodied in a stipulation that was entered by the
bankruptcy court in November 1986, and the government recovered a
portion of the bankruptcy court estate.
In May 1986, the United States and the State of Michigan each filed
civil actions in the United States District Court for the Western
District of Michigan against TSC, GTWRR, and several corporations
associated with TSC for recovery of response costs incurred to
investigate and remediate the Verona Well Field site.
In June 1989, 'a partial consent decree in the case was entered by
the District Court in which GTWRR settled with the United States
and the State of Michigan for 75 percent of past costs up to a
specified date. As of December 1990, a second partial consent
d~cree has been lodged with the Court which embodies an agreement
between the United States, the State of Michigan and TSC et ale for
p~yment of past response costs.
Based on the history of operations at the TSC Annex facility, U.s.
EPA sent out information requests pursuant to Section 104(e) of
CERCLA in April 1989. The 104(e) requests, which were sent to 65
companies a~d individuals, sought information regarding the
recipient's knowledge of, and/or involvement at, the TSC's Annex
facility.
In May 1990, the United States filed a second cost recovery suit in
the United States District Court against 7 additional defendants to
recover response costs related to the TSC Annex.
As is the practice of the U.S. EPA, Special Notice letters will be
issued to initiate negotiations with PRPs following finalization of
the ROD. The goal of these negotiations will be to reach agreement
with the PRPs to implement the remedy called for in the ROD and to
p~rform related operation and maintenance of the t~eatment systems.
-------
9
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Community interest in the problems' at the Verona Well Field site
has been very intense at certain periods during the progression of
. activities at the site. Beginning prior to the start up of the
RI/FS,.community activists staged protests against the handling of
site by u.S. EPA and MDNR and expressed concerns over exposures of
residents from private wells and the need for a clean water supply.
U.S. EPA and MDNR held several meetings and maintained frequent
communication with the community, local officials, and members of
the State legislature and U.S. Congress to resolve issues and
discuss concerns. In addition, fact sheets were prepared by MDNR
periodically to keep the community updated on site progress. A
total of 20 progress reports were issued during the period between
J.983 and 1987.
In November 1983, U.S. EPA held a kick off meeting to discuss the
RI work to be performed. A public comment period was held on the
FFS for remedial measures at the well field between March 29, 1984
and April 12, 1984. Copies of the FFS were made available to the
public at the start of the comment period. A pUblic meeting was
conducted on April 5, 1984, and public comments received throughout
the comment period were evaluated prior to finaliza~ion of the ROD
in May 1984.
Following completion of the PFS for remediation at the TSRR
facili ty, U. S. EPA published the document and began a public
comment period that ran from June 17, 1985 through July 20, 1985.
A public meeting was held to present results of the PFS and to
solicit public comments. After consideration of public comments,
the ROD was finalized in August 1985. .
During the period from 1987 through 1990, U.S. EPA and MDNR held
three separate "availability sessions" to discuss progress
regarding the on-going remedial actions at the site.
In November 1990, the community applied for a Technical Assistance
Grant (TAG) to hire a technical assistant to help them review site
documents prepared for the final remedial action. The TAG was
awarded to the community in December 1990.
The final RI report was released to the public in August 1990. The
public comment draft of the FS for the final remedy and the
proposed plan (PP) for site clean up were released February 15,
199J.. This signaled the start of a 60 day public comment period.
A public meeting was held on March 12, 1991 to present the findings
of the FS and to accept comments on the FS and PP. The public
comment period was scheduled to close April 15, 1991. However,
U.S. EPA extended the public comment period to May 24, 1991 as a
result of an extension request by one of the PRPs.
-------
10
A response to comments received during the public comment period is
included in the Responsiveness Summary, which is part of the ROD.
"
IV. SCOPE AND ROL~ OF OPERABLE UNIT
The Verona Well Field site consists of three source areas cf
contamination and the contaminated well field. Previous actions
have addressed protection of the well field through the
implementation of a blocking well system (IRM) , and remediation of
soils and groundwater at one of the source areas, the Thomas
Solvent Raymond Road facility (operable unit #1). The purpose of
this final operable unit (#2) is to address the remaining concerns
at all of the areas making up the site, and to set final cleanup
goals for the Thomas Solvent Raymond Road source area and evaluate
the effectiveness of the ongoing remediation there.
The Alternatives considered in the FS are intended to clean up the
contaminated soils and groundwater at the Thomas Solvent Annex and
the GTWRR marshalling yard, and to provide additional protection to
the well field. They also address the clean up of groundwater
between the source areas and the well field.
By addressing contaminated soils at the source areas, the selected
remedy will address the principa.l threats at the site, and by
cleaning up groundwater, will eliminate the primary health risks
associated with the site. The project clean up goal is to reduce
health risks to an excess lifetime cancer risk of 1 x lO~ and a
hazardous index of less than one for noncarcinogens in both soils
and groundwater.
V. SITE CHARACTERISTICS
A. Geoloov and Hvdrooeoloov
The uncons~lidated deposits beneath the Verona Well Field consist
of glaciofluvial sands of the Wisconsinan age. The sands are fine
to medium, poorly sorted, with less than ten percent silts and
clays. The bedrock consists of the Marshall Sandstone, underlain
by the C~ldwater Shale. The Marshall Formation is a light- to
medium-gray, fine- to medium-grained, sandstone characterized by
numerous joints, fractures, and bedding plane separations. The
Coldwater Formation is a dark-blue-gray, sandy, silty shale. The
thickness of the unconsolidated sediments ranges from 10 to 65 feet
in the study area. The Marshall Sandstone varies in thickness
between 100 and 120 feet in the area. Figure 9 presents a geologic
cross-section of the study area.
The water table in the study area occurs in the glacial deposits
between depths of 13 to 28 feet. There is no conf ining layer
-------
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LEGEND
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Pl£ISJOCOI[ AND II[COIT Q.AQAI. Of:POSITS
18SS1SSIPPIAN-AC( YARSHAU. SANDSTONE:
18SS1SS1PP1AN-AC( COlOWAItR SHAlE
,.01E:
-'u f1Q/R[ 1 rOlt lOCAlICIN or nl[ CROSS $(C1lON.
FIGURE 9
GEOLOGIC CROSS SEC110N
VERONA WEll FIElD
SA TTlE CREEK, MICHIGAN
-------
11
o
I
between the glacial sediments and the sandstone bedrock. Both
units are used for water supply in the area around the well field.
The glacial unit is used for private wells and the sandstone unit
is used for municipal and industrial supplies. Production wells 'in
the well field are cased through the glacial sediments into the
sandstone. Below,the casing, the wells are open bore holes. The
majority of water from the sandstone is thought to come from
fractures and bedding planes, since the rock itself is relatively
fine-grained.
I
Hydraulic conductivities average 2. 5X10-2 centimeters per second
(em/s) in the unconsolidated sediments and lx10-2 err./s in the
sandstone unit. In the well field, conductivities in the sandstone
have been recorded as high as .21 cm/s.
Natural groundwater flow is toward the Battle Creek River, however,
pumping in the well field has greatly altered the direction of
flow. Well field pumping has created a cone of depression which is
up to 10 feet deep and extends the zone of the well field I s
influence horizontally to the south of the Thomas Solvent
facilities, to the west of the marshalling yard, and east to the
River. Groundwater flow paths are shown in Figure 10.
B. Nature and Extent of contamination
sampling during the remedial investigation included source area
soil sampling and site wide groundwater sampling. The majority of
the samples were analyzed for VOCs, however a limited number of
samples were also analyzed for semivolatiles, pesticides, PCBs, and
metals.
1. site-wi~e Groun~water Investiqation
,
The groundwater i~vestigation focused on the source areas as well
as groundwater downgradient of the sources and in the well field.
The results of the groundwater sampling confirm that there are
three separate plumes of VOCs migrating from the source areas that
merge to 'the south of the well field prior to being captured by the
blocking wells,. The VOC plumes are shown in Figure 2.
The contaminant plumes migrating from the source areas appear to
migrate vertically downward in the aquifer between the source areas
and the well field.' This phenomena is likely due to pumping in the
well field. Vertical cross sections of the VOC plumes for each
source area are shown in Figures 11 through 13.
The primary contaminants in all three plumes are chlorinated
hydrocarbons although other VOCs have also been detected. Each of
the plumes has a different composition related to the individual
source area. These are discussed, later in this section. In
-------
BAli fy
PARK
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SCALf IN MIl£S
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THOMAS
SOlVENT
ANNEX --
THOMAS
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RA YUONO ......-
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LEGEND
.
GROUNDWA fER now
[XISTING BLOCKING WELL
FIGURE 10
PfnECTED GAQtH)WATER FLOW
-
VERONA WfLl nELD
BA fTL[ CRHK. MICHIGAN
-------
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1. CROSS S(CIIONS AR[ aNtRAL IN NAIUIlE AND
DO NOI PURPORt 10 DE AN (lAC I AtPRI:5INIAIiON
Of SUDSURf ACE CONDlIIONS II( III[[N UONItOllING WUlS
2. QU(SIION UAUKS ON ISOC(INCENIAAIION CONIOURS
INUlCAI£ I....(RR[O YAlUES QUESIION WARKS O[ ,.[N
GI OlOQC UNIIS INU.CA 1£ CONtACt IS INI EAAfO.
J. wrll O£PIHS AND SCRUN£D INURYAlS AA£ SHOWN fOR
IlI.US IAA IlYE PURPOSES.
to.2
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- - - - - ... - - - .- - - - - - - - - - - - - - - - - - - - ? - - ... - - - - - - - - - -y- - - - - - - --
-720
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I I I I'
1400 1800 .800 2000
L£GU/U
CONCI N IRA liON ""S ACI ION! . WI..ell WAS ALSO
A I All [(IN I AWIN"N I. D" IA PONIIS 10 Ul
ClJN';IllI RIU!'IIL ',"INARY
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GllOUHIIWA II A II VII or III'''INI D 'ROW WA I[A II YEI
W'ASUNI... HIS OIiIAINIU UN APAIL 2 ANO J. .989
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YlAIiCAI I XAGGlRAIiON ~ lOX
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RGURE 11
CROSS SECTION TOTAL VOCs
THOMAS SOLVENT RAYMOND ROAD
APRIL 1989
VlIWNA wn ,. 1111 J)
"AI Ill. em LK. MIClIlGAN
H')
HUIUII(CIIU "'1011£ WIIlIlIOIIlI£CIION "WII
NOI 5A"I'I£0 !lURING AI'RII 19H9 SA..I'UHG ll/l NI
NS
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800- 18
780 -
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I. CROSS srCTIONS ARt: CEN£RAI IN NA IIlIff AND
00 NOI PURPORT 108£ AN (lACI RlI'H[5I.NIATION
or SU8SUR1"ACf CONOITIOHSII£I.([N IIONIIORINC wrus
2. OU£STION IIARKS ON ISOCONcrrfTRAIION CON lOURS
IIOICIII( INI"(RR(O VAlU£$ QU(SIION IIARKS BI. Iwr£N
C£OlOClC UNTS INIJICAI£ CONIACI ISINf£RREO.
J. .u. II£PIHS AND $CR[[H(D INf£RVAlS All[ SHOWN fOR
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CONCI NIRAIION WAS ACt ION(. IIItIlO/ WAS AlSO
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CUNSlUt III 0 ,.RIIIII/NARY
- .10- -ISOCUNdNIRAIION CON fOUR. CONO NIRAnON
IS r9/1.
OIOUNlIWAIlR II \III DlIfHMlNlO fROM WAIIR II VU
III AS.m.III NIS OO/AINlO ON APRIL 2 AND J. 1981.
.AJNI OAIA WAS USIO fOR CON/OUR
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RGUfE12.
CROSS SECTION TOTAL VOCe
THOMAS SOLVENT ANNEX
APRIL 1989
VlIWNA WI:! I 'II"I 0
UA lllI. CIUI.K. M'CtflGAN
"
-------
860 -
PAINI
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I. CROSS S[CIIONS ARt: G£NrRAlIN NATURE ANO
00 NOI PURPORI 10 III NI [lAC 1 R1PR[S[NIA"ON
C1f 5U8SURf ACE CONOIIION5 11£ IIIIl[N MONIIORINC IIIlllS
2. QU(SIION MARKS ON ISOCONC£NIRAIIOH CONIOURS
INOICAI[ INf[RREO VALUES. QU(SIION MARKS IIlIIillEN
C£OlOClC UNHSINOICAI[ CONIACT IS INfERR10.
] MU IXPIHS AHO SCRE[NED ...[RVAlS ARE SHOIIN fOR
UUSIRAP\/[ PURPDS£5.
CAH
UlPAll
VA"" I
'C1I1'I61
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..MH~>lIAIIING YAHIJ
Wlll nno
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VI ilONA S muc IUH[
(APPHOXIMA In "..,
CII! o~
WI!
"
" ,
( . , " ,
45.160 " . \.: \ ------- SAND AND
'. ., - GRAVEL '
22.501\ \\,64,510 ',,\ 70.5 -- -------10 "
10,000 ,,\~--_..~-~.:) i --""'--' -.. - - -.... ,/
1000~::-r60'~' 18.7 .-...---?- - - -------- ,1'
. " '....... --- --- -- "
SANDSTONE'" ""0 - - -.- - -..,'
" ~-- -- -- - 0' .
'... -- ""':0<....
, --"- ?~~-.. ,/....,
'... . -.._- . 10J.5 '-. "
....-- '----- '? 1.4
--1 ----.. '\
---"0-- \
--------- IJ . /
SANDSTONE ---------?---"
--------
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V£IHICAL [XAGG£RA liON = 10.
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C!»Ir.fNIHAliON WAS Act. IONL 111101 WAS AlSO
A 1100 CONTAMINANI. DATA POINIIS 10 Bf
CUNSIOERED PRn IMINAR.,.
- -10- -ISOCON(;[NIRA"ON CONlOUII. CONct.NIRAIiON
IS r,,/l
CllOUNDWA II H Il VII DI 1I1~"IN1 D I HO" WI. II " " Vll
M[ASURlUlNIS 001 "'NlII UN AI'HO 2 ANU J. 19BY
-860
mOCKING
W£lL
v- 28- 840
-820
-800
-780
. -760
o.
o.
.
...
-7401
8
..
...
-720
RGUAE 13
CROSS SEC1l0N TOTAL VOCe
GRAND TRUNK PAINT SHOP
APRIL 1989
vrlWNA WLI. 11111)
IIA' III. CHI' K, MICltlGAN
a
y
-------
12
addition to VOCs, 20 different semivo1ati1es were also detected b~t
only two (bis (2-ethy1hexy1) phthalate and benzoic acid) were
detected at multiple locations. Detections of semivo1ati1e
compounds were sporadic and did not indicate any pattern or plume
of contamination. No pesticides or PCBs were detected in the study
area and metals concentrations were within the background range
expected for the area.
2. ~hom.s Solvent Raymond Road
The TSRR facility remediation was initiated in 1986 based on
results of previous investigations. The site is approximately 1
acre in size, is fenced, and contains an office building, a process
building for the vapor extraction treatment system, and ~he
controls building for the groundwater extraction system. The soil
vapor and groundwater extraction systems and their associated
piping cover much of the site's surface.
The natural groundwater surface at the site is located between 14
and ~6 feet, however pumping of the extraction wells lowers the
water table to between 16 and 25 feet. The extraction system
creates a 500-foot cone of influence in the glacial aquifer.
Groundwater outside the radius of influence and in the sandstone
unit flows towards the well field. Bedrock beneath the site occurs
on the average of 35 feet below the water ~able.
Remedial investigation field work at TSRR was limited to sampling
groundwater onsite, upgradient, and downgradient from the site.
suil borings have also been collected periodically as part of the
ongoing SVE remediation. Seven onsite, 3 upgradient~ and 14
downgradient wells were sampled. Results from the three rounds of
groundwater samples collected from onsite monitoring wells are
listed in Table 1.
Shallow onsite well B-18 contained the highest concentration of
VOCs at 85,960 ug/l. This well is thought to be within the NAPL
layer beneath the site. Other shallow wells onsit~ also contained
high levels of VOCs, but intermediate well B-l'I had very low
levels. The primary contaminants are PCE, TCE, TCA, xylene, and
toluene. Shallow and intermediate wells CH139S and CH139I are the
most contaminated downgradient wells. They are located
approximately 200 yards directly downgradient from the site, but
are outside the zone of influence of the extraction wells. CH139S
contained 22,300 ug/l vocs, with the primary contaminants detected
being ~inyl chloride, 1,2-DCE, and 1,1-DCA.
The contaminant plume flows to the northwest toward the well field
where it merges with the plume from the Annex facility. High
con!:entrations of VOCs are found in the shallow wells at the
source, and in intermediate and deep wells as it moves downgradient
toward the well field. This vertical migration most likely results
from pumping at the well field.
-------
fable I
GROIINUWATER ANAI.YTICAI. RESUI.TS I;ROM
TIIUMAS SOI.VI:NT RAYMONU ROAU ONSIH; WHI.S (PfIb)
GW819-{)I (iWn20 01 (iWR21 01 GWCII127S 01 nWnl7 02 COWnl8 02 c;WRI9.02 GW020 02
I: A weJO I;AWUI I:AWRI I;AW'i1 ';AI')4 I:AI:~S F.AI.96 F.AI.97
0'1118/89 02118/89 O'ltlR/89 OJIIIIIKOJ 11411»/98 04104/89 04/0)189 04IOJI89
Compound GRAB mt A8 QRA8 (iR An (iRAO (iR An (iRAO (iRAO
Chl,',,'metllilllc
OIlI'II,"n"IIIiIIIC
Villyl Chlll,i"c
l"hl",ot.1h811C
Mclhylcllc Chln,idc 1 " J
Acet,,"c 4'i IJOO
Ca,IMII. OislIlJi,lc
. .1- Oichl",ncl'":nc
'.I-Oidtl"rnctllllll4:
1.2 -I>ichl"rncthcllc
Chl",..'",111
1.2-D..:hlllrnclhnllc
1 IIIIIIIII""C
1.1.I-T,idtl..,IIctIIlIllC ) 2) 6900 4
Cu,IMII. T etmchluri,'c
Villyl "cd....:
B" -III' ,,' ichl. ,,,.n..,1 h..llc
I.! . "ichl"rul""I~IIIC
ch- '.1-l>ichl",,,I.rn,lCllc
T ,ichl",,,clhcllc '1 6 'i'i 17000 ) 6
I) i""'III' Ie hi. ." 'lIIetllllllC
1.1.2 T,ichl..ructh..nc
8C.IICIIC S J 360
"..IIs- ,. J. Oid.I"'''I.rullCllc
0,..111..",,'"
4 Mc.h)'1'2 -Pcllhlll"IIC
2 IIC.'IIIIIIIC
T ctrnchl"ructhcllc 8 IOJ )f>I) 17000 10 26
1.1 :1.1 T ctrnchl.....cthlillC
T,,'"C"C J4000 0.6
Ch'",II"CII'CIIC
!'.thyl"CII!.CIIC lOCIO
Sly,cnc
TIIIIII Xylcllcs 7400
Aer..lcill
Aeryl"lIi..ilc
TOT AI. vors 11 18 4')4 () 0 RSCjhO '4.6 )6
CII...:Clllruli.II" ..'c I'J!/I
.....e I
-------
Ta.,lc I
OROI/NOWAnR ANAI.YTlCAI. RUl/tTS I'ROM
TIIOMAS SOI.VliN'r RAYMUNn RUAn ONSITF. wm.l.s (pph)
OWR21-02 (iWf'l1I21S- (iWH1101 GWRI9 OJ OWR:m OJ (iWH12 OJ ()WCIII21S OJ uWCII127$OJ
'iAI.98 lilKi_14 1+1:11] U:HJ6 I;H:01 1+1:'1" - lilili26 1:1:1:10
~/OJ/89 !!4~~/1I9 O6flttl89 OtIfM!/89 ~I'lttl~~ ~1("~ 06126/89 O6I2W89
Compound GRAB GRAR (iR AD GRAH «iRAh uRAR GRAD (iRAB,
('hl..,.,melllOllc I J I J
h,.tllI..melh.IlC
V illyl Chluridc
('''''''''elhallc
Melhylcllc ChI..ridc
Acel"...: 470
CII,I"," OJ.mll'idc 2
1.1- nichl..,.,clhcllc
1.1- nichl..rc..:tlulllc os 1 J 1 J
1.2-I>idal..,.,clhcllc
«:hl..,.,II'''1I
1,2 nichl..rc...1hIlIlC 0,4
2 - 8""III""C
1,1,1 -'f,ichl",.,clh.llc 18 " f) 2
«'11'''''" 'f clmc:hl..ridc
Villyl Acelllic
8,. 'III' ..Iichlc". 'mclllOllc
1.2 - nichl..ruIN"I,,1I1C
cj, 1.2- Okhl"rul'rullCllC
T ,id,l, ,',ldhc",: J7 Ob ,1 11 n S I J I J
I)."" '""Ie; I,I. ,r. 'RlelhllllC
1.1.2- 'f ,ic:hl",.,elhllllc
bC:II/CIIC 02
111111\ - 1.1 l)idalur"rrullCllc
U,. 'III' ,1'", III
4 Mclhyl'2-PclI'nl"Nlc
2 IIC.IIIIIIIIC
l' cI, "C hi".. tel hCllc 280 .. 16 ifill I) 11 I) J 2
1.1.1.2 'T eI,nd,I""'elh,lIIc
T ..hie"c
«. 'hi.." .hCII/CIIC
flhylhcll/clIC
SIY'CIIC
1,,'"1 Xylcllcs
AUlllcin
Auylnllilrjlc
TOT AI. V()('s 80S 8101 77 l!. 148 21J 91 "
. 'n..u:nt,uljn.., lorC II!!'I
-------
13
Soil sampling at TSRR in 1987 indicated that soils in the area
around the former warehouse and dock areas were contaminated from
the surface to the water table at levels greater than 100 mg/kg of
prior~ty pollutant VOCs. The primary contaminants were PCE, TCE,
TCA# acetone and. toluene. The highest concentration of any
compound detected in onsite soils was of PCE at 1,800 mg/kg. Soil
. and groundwater samples collected at the water table in 1987
indicated that the NAPL layer was still present. However, the
most recent groundwater samples (during the RI) did not show the
presence of this layer.
3. ~homas Solvent Annex
The Annex is approximately 1.25 acres in size, and currently
contains only the loading dock structure. Groundwater is at 12 to
14 feet below the surface and flows northwesterly towards the well
field. Bedrock occurs just below the water table at depths of 13
to 15 feet. Remedial investigation work conducted at the Annex
inclnded hand-auger (near surface) soil sampling, soil borings, and
groundwater sampling.
The near surface soil sampling, which focused on three locations at
the site, was, conducted to determine the extent of contamination
just below the surface. Results indicate contamination by
chlorinated compounds below the loading dock, and in the vicinity
of the old tank control building at three to four feet below the
ground surface. Of the compounds analyzed, PCE, TCE, and TCA were
the Eost prevalent. Concentrations of PCE ranged from 120 ug/l to
.680 ug/l beneath the loading dock, and from 150 ug/l to 14,000 ug/l
in the area of the tank control building. TCE ranged from 56 ug/l
to 440 ug/l at the loading dock, and 400 ug/l to 880 ug/l at the
tank control building. Concentrations of TCA were generally lower
than the others w~th concentrations ranging from 7 ug/l to 93 ug/l
at the l~ading dock, and 34 ug/l to 73 ug/l in the area of the tank
control building. .
Following the hand-auger sampling, 16 soil borings were drilled and
s~mpled at the Annex. Location$ of the. borir.gs were determined
based en previous soil borings and on the results of the near
surface sampling. The locations of the borings are shown in Figure
14.
Twelve different VOCs were detected in the soil borings above the
detectio~ limits. The most frequent contaminants found were PCE
and TCE. Table 2 lists results of the soil boring samples along
with boring numbers, locations, and sample interval. Borings 5B-6
and SB-11 were the most contaminated of the borings with the
greatest number of compounds present and the highest concentrations
of most of the compounds. Bor ing 5B-6 is in the area of the
solvent transfer area and 5B-11 is in the vicinity of the truck
turnaround area.
-------
EMMETt
. ,
LE~END
. NEW SOIL 'ORIN~ LOCATIONS
o EXISTIN~ SOtL 'ORIN~S
. (FROM PREVIOUS STUDIES)
- - - PERIMETER OF ~RAVEL DRIVE
~
o
I
50
SCALE IN FEET
STi£~
14
.
tRUCK
TURNAROUND AREA
Figure 14
SOIL BORING LOCATIONS
VERONA WEll FIELD
BATTLE CREEK. MICHIGAN
100
16
.
~
z
S
....
5
m
LOADI~G
DOCK
-------
TABLE 2
ANNEX SOIL BORING ANALYTICAL RESULTS (~g/kg)
VERONA WEll FIElD
BAnLE CREEK. MICHIGAN
~ INf(AYAlIFlI l0CA11ON OCA m;
'1." ... ,..-
'.11
".1'
'1.01 ... ,..-. ,..
..11
II."
'1.81 ... Old . ..0
,...
..... ...
'I." ,., Old
....
II."
'1.11 ,., Old
..11
II."
'1." ,., "....., ....
.... I"
11.1' '100
'.".""."'"
c-_...
DCA . '.IOCKIRJET"'"
lICE. "CIICH.()fOnvE
1CA . 1fICK.(RJETIWE
1CE.~
111 . '.'.2.1. 1E1MCIt.DAO(1"'"
PCE.'~
101. . 101.DE
.n. tnlOE
EI) E1IMJI(HIIHE
WCl. WTIftlUEIH.OADE
1.IUT.I.IItIIANIH
ACE. IlCETtM
.... 1WM0DN'IAM:1 ~DE1EC1IONIM1'
'1
l..."...
DCDI .lOADNJ DOCII
1AIM AnEA .UNIJUIGR)IJNO 1ANU1AIM CONTAI1 AREA
'IWtSIEA .SOl VIHt 'I¥NSJEA S'A'ION
'~NDNI . TRUCII 'lANAROIH) AREA
1CA 1tE
....
.00 7100
,..
".
PCA
I'U
,....
....
...
"0
no..
I'"
n.
"..
u.
,..
n,
ISOO
noo
,..
IS"
1100
..00
I""
..00
re,
....
5100
noo
.11
..10000
1100
..000
sre
11..10.
,...
110"
111.
JIYl
.
WCl
..IUT
. ....
'. ...
...
.71
.11
U. S" .71 '" .11
1.00 ". .,.
IQ '=I
.u..
....
...
..".
....
U.
I""
U.
...
SUI
.".
n..
IIn.
IISOO
....
UIS'..
....
nooo
-------
TABLE 2 (CQNTINUEDj
ANNEX SOIL BORING ANALYTICAL RESULTS (Jlg/kg)
V~fK)NA WEll fiElD
Al\mE CI?HK. MICIIIGAN
SOl...-...o. ""IAYAI IOCA'1OIf DCA en 'CA Q PCA FU '0. In\ ID M:o. '.80' jQ '~
,.. ft.
roo. in .,. ,.. I..,.
fO' .."
1.00. It,..
UO. ... , "..
.... ....
Itoo. ,....
JlO. ,It.
'00' "31
..0. ,It.
Itoo. ".0.
1100. ".. lit. U... JefO.
s.o. "It
11.000. ,.. IH.I"
4100..0. '.00.., ,"'.... IS..... 14. .UOIS..
.
,,, Jr.
110. uo,
ts. It..
,... 110.
"" uo.
." USt
." .,.
Ito. IS' ,U.
Sf.. IH. ItIO'
ICO. U.. ,.. ....
It.. If.. ....
110. .It U. ,U.
,.. ... Je.
... It. '0'
SI." '.1 ".:..,..
I."
II."
SI.. 1.1 'u...A.....,
I."
11.'4
SI.H 1.1 '._.A.....,
1.11
11.'4
SI.It ..1 '._.A......
1.11
II."
SI." '.1 ,,,...A......
.."
II."
SI." ..1 ,.... Ar-
,..,
II."
lI.u ..1 '...A.....,
I."
11.'4
'1.'4 '.1 ,.... A.....,
'.11
II."
II. IS '.1 ".....,
I."
11.'4
II. It ... DodI
I."
II."
Jr,
sr.
u.
"..
,It
...
...000.
....................
c__...
DCA. '.'1JICM0R0n1tUl:
IICI. I.I~
'CA. ,~
'11. 1JtDlD«nVE
Pel. I.I.U tITAACt8.0AOnHANI
'01. 10101;
.\'l.~
10- InI\Ul9l(N;
M:Ct. "I~ CJt.OIU
'.Iut. 'IIInA....,
ACI. IIC£JONE
.n I(IOWCOlJIW:J AU1IR1DOOIC'lOIflMfJ
l........
DOC. IMDNJDOCII
tAMI AAIA. UNlJ(Ar'JnN) tNWrANI corrAo. NI(A
'RANSFER SOl. v(Nt tRANSflA S'A'1OIf
,.... Nn.IC) '''JCII t.... NIOIHI MIA
110.
St.
It.
fJ.
,..
41..
'It.
110.
.80000.
It.
,..
It..
....
It.
,..
-------
14
Results of the soil boring analyses indicate that contamination is
present vertically throughout the unsaturated zone. Contamination
was found in all three sample intervals at similar concentration
levels. This even distribution of contaminants is indicative of
multiple leaks, spills or discharges over time in various areas on
the annex property.
Groundwater sampling at the Annex included 3 upgradient wells, 7
onsite, and 24 downgradient wells. The results of the' samples
collected from onsi te monitoring wells are listed in Table 3;
locations of the monitoring wells are shown in Figure 17. The
groundwater contamination found at the Annex is similar to the soil
sampling results discussed above. The contaminants are primarily
chlorinated hydrocarbons and aromatics. Vinyl chloride, 1,2-DCE,
TCE, PCE, toluene, ethylbenzene, and xylene were detected above 100
ug/l in at least one onsite well.
The most contaminated wells were shallow wells B-8, B-9, and B-25.
Almost no contamination was found in intermediate wells onsite, and
no contaminants were found with any regularity in the upgradient
wells. In downgradient wells, concentrations were highest
immediately downgradient of the site and decreased with distance
away from the source toward the well field. Contaminants were
found at higher levels in intermediate and deep wells downgradient
of the Annex. This is likely a result of contaminants being pulled
down vertically in the aquifer due to pumping in the well field
(see cross section in Figure 12).
Monitoring wells between the Annex and the Battle Creek River were
sampled to investigate the impact of groundwater contaminants from
the Annex on the River. Low level contaminants were found in some
of these wells «5 ug/l VOCs), however, no definite plume was
identified and contamjnants are suspected of being residual leve~s
from earlier plume, migration toward the River. There does not
appear to be a current impact on the River.
4. Grand Trunk Western Railroad
The car department. shop. is loc-:!ted on the eastern edge of the
marshalling yard amongst several buildings. The marshalling yard
is situated on the eastern edge of a glacial river valley. The
thickness of the unconsolidated alluvium ranges from 15 to 20 feet
below the paint shop, thinning to the east. Groundwater is at a
depth of 18 to 20 feet, just below the bedrock surface which slopes
to the west towards a bedrock valley on the western edge of the
marshalling yard. Groundwater flow is to the north/northwest
towards the eastern portion of the well field.
Remedial investigation work at GTtVRR included hand-auger soil
sampling, soil borings, and groundwater sampling from monitoring
wells. . The hand augering, or near surface soil sampling, was
-------
Table 3
GROUNDWATER ANALYTICAL RESULTS I-kOM TIIOMAS SOLVENT ANNEX ONSrrl! WELLS (pfb)
GWB08~1 GW1I081~1 GWB()I)~I GWD2).01 OWB2).OI GWB2S~1 OWC1I1071-G1 GWCIII07DOI
EAW49 EAWSO EAW67 EAWS6 EA W57 EAWSS EAW1"l EAW70
0)/01189 0)101189 0)102/89 0)101189 0)101189 ,))/0 1189 0]102/89 0)/02189
Compound GRAB GRAB GRA£ GRAB DUPI.ICATE HRAB GRAB HRAB
ChlorOmdhanc
Brnmomelbanc
Vinyl ClaloricJ.: 0.7 J 160 D 9 D
CblorOdballc
Methylenc Chloride ] 46 D ] JD
Acch...c 6
Carbon Disull'idc
I. 1- Oicldorocthcne 17 12 D I
I, 1- OichiorOdhallC 62 0 7 0 6 I J ]10 4 0
1.2-0ichJorUCIhcnc ]200 0 180 0 ISO 31 ISOO D 160 0
Chloroli.rm I 0.5 J
1.2-DicblorocthaIlC U .. J 1 J
2 - BUI.nollc
1.1.1- , richloroethillc 62 0 3 OJ ) J 5 34 D 0.8 J
C' arhon T ctracldoriclc
Villyl Ac..1alc
BII.n..ttlicbl...r.'Alt:lhanc
, ,2 - O..:laloropurpallc
cis-I.2-0ichluropropcnc ISO D
T riddonlt:lbcllc 170 0 110 0 95 12 6 0
Oibromochloromclh.nc
" 1.2 - T ric:hI...rocthanc 0.6 J
Bc.ucnc 4) 4 01 ] 1 22 JD 2
IrulIs-I,)-Oic:l1Ioropropcllc
Brnmuform
4 - MCII.yl- 2-Pclllanonc
2 - HC"III"k:
T dr.chlor."'1hcllc 2 340 0 190 0 170 55 310 0 6 0
I. I ,2.2- TI.1rachiorocthallc
Tolucllc 2 9 II 56 D ] ID
('bloruhclllcnc 1 , 0.4 J
Elllylhc.IlCIIC IJ 140 0 2 0.9 J 840 0.8 J
SIyrcllc 20 160 0 190
T."..I Xylcnc. 34. 36
Acrnlcill
Acrylunitrilc
TOT AL VOCs 51 0 4094 411b.7 4L7 U8.9 2575 2n.1
COllcclllr.lillns IIIC pgll
,.... t
-------
Tablo 3 (Cnn'lJIUed)
GROUNDWATER ANALYTICAL RESULTS FROM TIIOMAS SOLVENT ANNEX ONSrrE WELLS....,)
GWB08-qz GWB08I-qz GWB09-02 GWD2J-02 GWB1S-02 GWCIII01I-02 GWCIII01D-02
EAG62 EAGJS EAUJ6 EAUJ1 EAmS E"I.7J EALn
04106189 04106189 04/06189 04/06189 04/06/89 04/06189 04106189
Compound GRAD GRAD GRAD GRAB GRAD (jRAD ORAB
Chloromcthanc
Dromomethane
Vinyl Chloride 2
Chloroc:lhane
Methylene Chloride 9 2 0.7
Acctonc 100
Carhnll Disullidc
I,I-Dichillrocthcne 9
1,1- Dichloroc:thane 4 16 0.9
1.2-Dic:ldllroc:thcnc 12000 4100 71 2100 38 4
Chlorornrm
1,2-Diehlllroethanc
2-Butanonc
1.1,1- T richloroethanc 1100 SO 2 820 0.9
Carbon Tetrachloridc
Vinyl Aeelatc
Bromodichloromcthanc
1,2 - Dichlorllporpanc
cis-I.2-Dichloropropcnc
T ridalnfllcthenc 110 S'l 970 1
Dihnmtochlnr"mcthanc
1.1.2- Tridalorodhallc
Benzenc 40 2
Iran~-I,3-Diclaloroprupcne
Brumn'orm
4-Mclhyl-2-Pelllanonc
2-lIell8l1l11lo:
T ctraehloroclhenc 2100 0.1 260 100 S:.!O 10 0.1
1,1,2,2- TelrllChioroelhanc
Tlllncnc 3100 B 600 01 J
ChlurobcllLcnc 3
ElhylbcllLenc 1S00 SI 0.6
Styrene
T "'al X ylelles 24000 3() 3JOO 1.1
Acrulein
Acrylonilrile
TOT Al VOCI 49800 0.1 SJ6I 2.)] B:\9S 60.6 S.4
~.
Conccnlralions arc ,,~/I
-------
Table 3
GROUNDWATER ANALYTICAL RESULTS't'ROM THOMAS SOLVENT ANNEX ONSrTE WELLS (pftJ)
OWBOIHJ3 0WB08~1 GWIIOtII~3. OWB09~3 OWDlJ-oJ OWD2S-03 OWCH lan~3 OWcHI01D-OJ
EEEJ9 EEE9J EEli08 UEA4 liF.FA7 EEF.62 EEF74 EEF7J
06129/89 06129/89 06129/89 06128/89 06n8/89 06128/89 06128/89 06128/89
Compound ORAB DUPLICATE ORAB GRAD ORAD ORAD ORAD ORAB
Chillromethane
Bromllmethanc
Vinyl Chloride 220 J J
r.lllllroethanc
Mdhylenc Chloride
Acdllne 2600 J
Carbon Disulfide
I. 1- Dichlorocthcne
I. 1- Dicillornethanc 8
1.2-Dichlorocthene I JOOO 11000 D 980 8 D 7J0 J 1600 18
Chlorororm
1.2-Dichlorodhanc
2 - BUlanc"1C
I. 1.1- T richlllrocthanc 1200 J 12000 )
Carhotl Tetrachloride
Vinyl Acdale
Bromcldichlc'romethane
1.2-DicllloroporptlRe
cis-I.2-Dichloropropenc S D 580 J 110 J
T richlortlClhenc 170
DihromclChloromelllanc
1.1.2- Trichloroethanc
Bcnzene
trans-I.J-Dichloropropenc
Bromllrorm
4-Mdhyl-2-PenlaROfIC
2 - Hell8n~1C
T drachlortlClhene 900 JOO J 9 D )JOO 240 2
1.1.2.2- Tetrachloroethane
Tulucnc JJOO 4200 D
(:hluwhclIJ!cIIC
F.lhylhcnLcnc 7100 7900 D
Slyrcnc 1700 J
Tnlal Xylcm:, 24000 11000 D
Acrolcin
Acryillnitrilc
TOT At VOCI 48600 47170 0 1280 JJ 8910 2170 2)
-
Cuncclltralions arc ,.~/I
,.1
-------
15
conducted at nine locations. Samples were collected at depths
between 3 and 4.25 feet and analyzed for a short list of VOCs
utilizing onsite laboratory equipment. Sample locations included
the area of the drum pit and the area just east of the car
department building. Results indicate shallow soil contamination
by PCE and TCA in'the area of the paint shop and drum pit.
Following the hand-auger sampling, soil borings were installed and
sampled from the ground surface to the top of bedrock. Six borings
were installed on the east side of the paint shop and four
installed on the west side. Boring locations are shown in Fiqure
15. Analytical results for compounds detected in the borings are
presented in Table 4. PCE, TCA, and toluene are the only
compounds detected with any regularity. PCE was found in 28 of the
34 Gamples collected. Results indicate a decrease in concentration
of contaminants both laterally and downgradient of the drum pit.
The highest concentrations were found in the deepest soil borings
which seems to indicate stratification of contaminants within the'
soil column.
,
The groundwater investigation at the paint shop involved sampling
and analyzing groundwater from 7 onsi te wells and a number of
upgradient and downgradient wells. The three compounds most
prevalent in the groundwater were PCE, TCA,' and benzene. PCE and
TCA were also found in the near surface soil samples and deep soil
borings, and are known to be the components of Dowclene, the
solvent used by GTWRR.' Results from groundwater samples collected
from onsite monitoring wells are presented in Table 5. Locations
of monitoring wells are shown in Figure 18.
contaminant levels in groundwater at the marshalling yard are
highest closest to the drum pit and decrease downgradient. On the
western edge of the facility, concentrations of contaminants in
monitoring wells are two orders of magnitude lower than adjacent to
the source. Results also indicate a downward vertical flow of the
plume as it moves towards the well field. As with the other
groundwater plumes, it appears this is a result of pumping in the
well field.
~. SUMMARY OF SITE RISKS
CERCLA requires that u.S. EPA protect human health and the
environment from current and potential exposure to hazardous
substarl:es found at or emanating from the site. A base line risk
assessment was conducted as part of the RI in order to assess the
current and potential risks from the site. This section summarizes
the Agency's findings concerning the risks from exposure to soils
at 'the source areas, and groundwater at the source areas and
downgradient in the vicinity of the Verona Well Field.
Assessment of site related risks involved the identification of
-------
298
308
278
288
CAR
REPAIR
SHOP
CAR DEPARTMENT BUILDING
218
238
X
DRUM PIT
(Approximate location)
Paved
FIGURE 15
SOIL BORING LOCAnONS
GRAND TRUNK WESTERN RAILROAD PAINT SHOP
VERONA WEll FIELD
DAnLE CREEII' MICHIGAN
@
Not to Scale
IIGEND
. SOIL.ORING LOCATIONS
-------
TABLE 4
PAINT SHOP SOIL BORING ANALYTICAL RESULTS
Detected Concentrations (~Ig/kg)
VERONA WEll flHD
DAmE CREEK. MICI~IGAN
TOTAL "
.
SOIL 80RlNO INTERVAL F lOCATION 80CII TeA PCE TOl IIECl V
58.21 0.1 E88I SIdI 260 26D
I.U 710 77 151
U... '10 '800 2.060
58-22 0.1 Eal SIdI 2100 2.100
I. U 3800 3.800
U.tl 120 1200 280 280 1.400
58.23 0.1 E88I SIdI 760 76D
I.U 2100 2.100
U-" 150 3200 150 '.500
58-24 0-1 E88I SidI 1400 t.4oo
I-U teD 2400 2,580
U-" 240 3200 3.440
58-25 0-1 E... SIdI 100 100
I- U 1200 1.200
U-II 440 8400 1,140
58-2' 0-1 E.I SidI 440 440
I- U "00 t.loo
U-" ISO 12000 t2,130
58-21 0.1 W.. SIde 8800 '.100
.- U 35000 35.000
U-" "00 t.too
"-22 ..00 240 2.040
58.21 0.1 WK' SIde 280 2.
I-U 0
U... 150 t50
"-20 SlOO 340 '.440
58.21 0-1 WK' SIde 0
I- U 0
U... "00 t.7oo
...20 4000 430 4,430
58-30 0-' W.' SIde 0
6. t2 0
12... 0
11-20 480 490
NOYES:
oor.u Oromodichloro.lhlllI8 .-a. U.","". Chloride
~ T rlchloro.lh.n. Oalow contl.cl r.qulred delecdon Imlle
ro: 1 .tr.chloroelh....
Ta. 10"'-
-------
T.ble 5
OROUNDWATER ANAL VTIeAI. RESULTS FROM TilE ORAND TRUNK PAINT SIIOP ONSITE WELLS (prill)
owcnl06I-G1 owcn 14OI-G1 OWClll451-oi owcnl461-01 owcn 1061.qz owcn 1401-0'2 OWCnI4SI-0'2 0WCII1461-0'2
EAm. EArm EAGl2 EAO I) ED082 E0085 ED088 F.DOII
03105/89 03105/89 03105/89 031OS189 04/05/89 04/06189 04I06Il9 04105/89
C08Ipoand aRAB aRAB aRAB GRAB aRAB GRAB aRAB aRAB
Chlnrnmethllne
Brnmnmethllne
Vinyl Chlnride
Chlorncth.nc
Methylene Chloride 16
Aedo.1C
Celbon Disulfidc 0.4
I. 1- Dichlo,nctbene S 560 E 4 99 0.3
I. I -Dkhlorncthllnc 59 210 I JJ 20.9
I.2-Dichlornetbene 19 17000 23
Chlorororm I
1.2 - Dichlorncthllne 2
2-Bul.,"",e
I. I . I - T richlnrncth.ne 0.6 , ISO D 4400 D 1500 87 6300 4.6
C.rbnn TctrllChioride 180
Vinyl Aeetllfe
Brnmndichlc.romc:th.ne
1.2 . Dichlo'npor....ne
cis- I.2-Dichlornrrure:ne 280 JO O.S
T richlorncthcne 36
DibrnmnchiornlllClhllne
I. I .2- T richlorndh.nc: 22
Renzenc: 3 J 2 160 10.9
tr.ns- I . J-Diclllurnrrorc:nc:
Rrnmnrnrm
4 - Methyl - 2 - Pcnlllnonc:
2 -lIe"IIIJIIC 23.1
T ctr.clllorocihe:ne 6 3JO D 12000 D IJOO 190 16000
I. I .2.2- Tc.1rllchlorneth.ne 5.S
Tolncllc 4900
CI"ornbe:n1cne 16Q
ElhylbclllellC 11000 0.7
Slyrcne O.J
T....I Xylencs 28000 3.J
Acrolein
Acrylonitrile:
TOT AI. VOCs 66 488 17281 ° 64SIO 283 22S01 70.5
Cnnccnlrlllions "'C ,..~"
1'10..1
-------
Table 5 (cont ir.ued)
GROUNDWATER ANALYTICAL RESUI.TS FROM TilE GRAND TRUNK PAINT SHOP ONSITE WELLS (pph)
GWWI4S-02 GWCIII06I-o] GWclll40l-o] GWC1I1451-{)J OWCII1461-oJ GWWI 4S-{)J
EOO89 EEE24 EF.E2J EEE29 EEE27 EI£JO
04106189 06128189 06128/89 06128/89 06128/89 06128189
Compound GRAB GRAB GRAB GRAB G~AB GRAB --
Chlnrolll\.'Ih.ne
Brumnmclh.ne
Vinyl Chloride
Chlnruc:lh.nc
Mc.'Ihyh:ne Cbloride
Acc.'lonc
e.rbon Oisulfidc
1,1- Dichloroclhcnc 160 S 2
I.I-Dichlnrnctbnnc 4 9
1,2-Dichloroclhcnc
Chlorol"nrm
1,2-Dichloruclh8nc
2 -Onh""...c
1,1.1" T richlorueth8nc IJOOO 78 DJ 98 D 5700 10000
Carbon Tdr8rhloridc
Vinyl Acclalc
Brull1lKlil:hl,,,omcth8nc
1,2 - Dichlnropurl"'nc
cis-I,2-Dichlorol'ropcnc
T ricblorocthcnc J
Oibf(lImlChl"romclhllnc
1,1.2 -- T richlurodhllnc
Bcnl.cnc I ()()()() OJ J
Irans-I.J-Dichlorol'ropcnc
Brumolorm
4 -Mcthyl-2-Pcnl.nonc
2-lIcsllnonc
Tctr.cblorocthcnc J2000 460 D IQ() D 2000 DJ 7 JIOOO DJ
1.1.2,2- Tctrllchlometbnnc
TnlllCIIC 2
Chlorol'CIII.CIIC
ElhylbcllI.cnc
Slyrcllc 2
Tolnl Xylcncs
Acrolcin
Acrylnnitrilc
TOTAL VOCs 45160 550 290 2:1700 2J 41000
Conccnlrations 8rc I'j:/1
"acJ
-------
NOTES - TABLES 1-5
NII'es:
J :0 Resull heluw CllolJllcl-requircd dcloc.illo limil; rel"'r;ed ns 011 e"illlule
It = Resull .1"" 'i'ulld in cllrresplllldillJ! hl.II" ""ml'le
I) ..: "illllinll ...m"le
J: ..: t:"imuleel. valuc wu.. nhuI/e c.lihrll.iull r.lI!!e
IIhl/lh = Cuml'"uml wa.. "'" deled,:d
Eaam,.le ellillmll hend:
Uenel
fiWOl9 01
F. A WOflO
02118/89
URAB
Odill il intI
Sum,"e I/IlIlIher
1:1'" 10 "'''lIher
/);,Ie ~1II11,le IlI/o.ell
Sum,.le 'YIIC
Key In sllmpl.: I/lIO.her:
UW = Uru'''Klwuler
11/9 ,. Well IIIIQlher
NlIl/lhers "'ier ")I."ell C
01) = Suml'l inJ! ,..lIm'
-------
16
contaminants of most concern, routes of contaminant migration and
populations potentially exposed to the contaminants. This
information was then used to estimate exposure from contaminants
for the population, which was then compared to chemical toxicity to
arrive'at an estimate of health risks for the well field and each
of the source areas of the site. The r:i,sk assessment was conducted
in a manner consistent with u.s. EPA risk assessment guidelines and
guidance.
An ecological risk assessment was not performed because ~he major
exposure pathways affected the well field and surrounding
industrial areas.
A. Identification of contaminants of Concern
Seventy three chemicals on the U. S. EPA I S Target Compound List
(TCL) and Target Analyte List (TAL) were detected during the RI at
the Verona Well Field site. Of these 73 chemicals, 48 chemicals
were determined to be chemicals of potential concern for the site
based on the frequency of detection, and the availability of
toxicity data established by u.s. EPA for the chemical. Table 6
lists the 48 chemicals of potential concern for the site. These
compounds were used to evaluate toxicity, exposure pathways, and
potential health risks for the well field and each of the source
areas of the site.
B. Exposure Assessment
contaminants have been detected in on-site near and subsurface
soils at all three source areas. Receptors corning into contact
with contaminated subsurface soils may become exposed via three
primary pathways: incidental ingestion; dermal contact; and/or
inhalation of vapors. Because the major land use for the three
source areas at the site are commercial, the exposure scenario was
considered to be that of short-term exposure during site
excavations and trenching. Therefore, potential receptors due to
on-site subsurface soils are on-site short-term workers.
contaminants have also been detected in groundwater at the source
areas and do\\'ngradient from the source areas. Human' exposure to
groundwater contaminants may occur through ingestion of drinking
water, by dermal contact with contaminated water, or by inhaling
conta~inants volatilized from water during showering, cooking, or
other household water usage. Currently, all known downgradient
receptors are connected to the Battle Creek city water supply.
However, exposure may occur through use of private wells for
consumption in place of the city-supply water, or through
nonconsumptive uses such as gardening or car washing. Figure 16
illustrates exposure pathways for the Verona Well Field site.
To estimate contaminant intake by exposed populations, the risk
assessment made certain assumptions about exposure. These
-------
T.hle 6-
CIII':MICAI.S 0... rOn:N"I'IAI. (;ONCI':RN. I)I.:....:{:"I'I-:O IN Vfo:RONA WIo:U. FIF.I.D ARFA
ANN~X PAINT SIIOP RA YMOND ROAD
Sub5urracc Oruundwalcr SUh511fr.U:C Grnundwtler Sub5urrace - Groundwaler
SnUs Onsilc Dnwngradienl SnUs Ur~radicnl Onsile Snils Ur~radienl On511e Down~radlenl
C~rdnngenic
Den7.ene X X X X X"'" ".X. .X
1.2-Dichlnroclhanc X X X X X X
n-NIU'mo-dl-n-propytamlne X ...
Trichlurnclhcnc X X X X X X X 'x
Vin,1 Chloride X X X X .. ,. X
Nc'ncafdnngcnic
Acelone X X X X X X X .X X
Anlimnny X X
Barium X X X X X
IJcnmic Acid X X
Benrylbulylphthalate X
nmmnmelhaRc X
2-Dulanone X X d.
Cadmium X X
('~rbnn IJI5ulOde X X X X
(~hlnrnhcn;~cnc X X X X X
Chromium X X X X X
Currer X X X X
Dlbulylphlhalale X
Diclhyll,hlh:tlalc - X
Elhylbenlcne X X X X X X X X
Manganc.\c X X X X X
Mercury (Inorganic) X
2-Mclhylrhcnul X X
4 - Mel hylphennl I X
..'
4- Mclhyl-2-I>cnlannnc X X X X
Naphlhalene X X
-------
Tuhle 6 (ctln'inll~dt
ANNEX PAINT slIor RA YMOND ROAD
Subsurfare - (Jwumlwa.er Subsurface (Jwundwaler Subsurfare (Jwundwaler
Suils Onsile Dnwngradienl Snils "pgradien. Onsile Suils Upgradienl Onsile Dnwngradlenl
Nuncarcinuger.1c (continued)
Nickel X X X X X
Nilwbcnl.cnC X
Phennl X X
Tuluene X X X X X X X X X X
Tmns-I,2-Dlchlnmelhene X X X X X X X X X
1,1,1- Trichluroethane X X X X X X X X X
Te.mhytlmfuran X
Vanadium X X X X X
X ylenes X X X X X X X
Zinc X X X X X
Dnlh Carcinngenic & Nnnc:m:inugenic
Arsenic X X X
Berylliuln X X X X
Dis( 2-elhylhcxyl)ph. ha laic X X X X X X X X X
DfllmcMlichlc Ifllmelhane X.
C.arbnn Tetrachlnride X X
Chlnrnfnrm X X X X X X
1,I.Dic:hlnwethane X X X X X X
I.I-I>ic:hlurnel hene X X X X X
tlcxachlnrne.hane X
Melhylene Chillfide X X X X X X X X X X
Tctmchlclrnclhene X X X X X X X X X X
I.I,Z-Trichlnruelhanc X X X X
-
-------
CONTAMINANT
SOURCE
CONTAMINANT
RELEASE
MECHANISM
CONTAMINANT
TRANSPORT
MEDIA
EXPOSURE
POINT
EXPOSURE
ROUTE.
EXPOSED
POPUlA TlON
--- >. -.- -----
-.----.-.
-_.. -----------"-
- -.-----..-.... --...- ---
----.----.
Inge.llon -
Olhlte Re.ldence... .. 011.11. Wal., U"'8....-
... Inhalallon ..
l.achlng - G'oundwale, - - ~ - \
.. .. .. .
On,II. ~
.. "'O..maf - I u'ur. On..i'. ..
.. Resid...,./Work...
SOLVENT
SPILLS. LEAI
-------
17
assumptions address
rate, and frequency
lists the exposure
assessment.
the receptor, exposure route, medium, intake
of exposure via identified pathways. Table 7
assumptions for the Verona Well Field risk
contaminant intake estimates were derived using exposure point
concentrations, or direct measurements of concentrations at the
point .of contact. Reasonable maximum exposure estimates were
assumed to be the 95 percent upper confidence limit (UCL) of the
arithmetic mean concentrations in a given medium at a given source
area. For carcinogens, a given total dose is assumed to have
similar potency whether exposure occurs over a shorter (40 year) or
longer (70 year) period. Exposure to workers is not continuous
over a lifetime, so exposures over 40 years were averaged over a
lifetime to estimate the average daily intake. For noncarcinogins,
daily contaminant intakes are estimated. The estimated intakes for
the Verona Well Field site chemicals are compared to lifetime
intakes considered by u.s. EPA to be without adverse effect.
Data used in the risk assessment were grouped by source area,
medium of concern, and exposure situations. These groupings allow
for estimation of potential risk under current and future land use
settings.
C. Toxicitv Assessment
Carcinogens are characterized by a dose-response relationship that
assumes no threshold for exposure without risk. The dose-response
relationship for carcinogens is expressed as a carcinogenic slope
factor, which converts estimated daily intakes cirec~ly to
incremental lifetime risk of cancer occurrence. Cancer slope
factors (CSFs) have been developed by U.S. EPA' s Carcinogenic
Assessment Group for estimating cancer risks associated with
exposure to potentially carcinogenic chemicals. CSF's, which are
expressed in units of (mgjkg-day)ol, are multiplied by the estimated
intake of a potential carcinogen .in mg/kg-day, to provide an
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The CSFs for the carcinogens found
at the Verona Well Field and their respective carcinogen
classifications are listed in Table 8.
Noncarcinogens are assumed' to display a threshold value that
exposure must exceed before toxic effects are manifested. The
threshold value is used by U.S. EPA to derive the toxicity value
which is called the reference dose (RfD). An RfD, expressed in
mg/kg/day, is an estimate of an exposure level that would not be
expected to cause adverse health effects when exposure occurs over
a lifetime. RfDs are designed to protect sensitive individuals and
are specific to exposure route. The RfDs for noncarcinogens found
at the Verona Well Field are listed in Table 9.
-------
Table 7
EXPOSURE ASSl'MPTIosS FOR THE VERONA WELL FIELD SITE I
Exposure Intake Exposure
Receptor Route' Medium Rate Frequencvb
Curreat resideat ingestion water O.lt/day 12lyrnO yr
(nonconsumptive dermal water c 12lyrnO yr
use)
Curreat resideat ingestion water 2t/day daiJynO yr
(consumptive use) dermal water c daiJynO yr
Future resident ingestion water 2t/day daiIynO yr
dermal water c daiJynO yr
Fl.lture worker ingestion water It/day 250 dayslyr/40 yr
dermal water c 250 days/yr/40 yr .
ingestion soil O.Iglday once/yr/40 yr
inhalation vapors 2.1m3/hr B hr/day,
once/yr/40 yr
'An inhalation route due to water use was not quantified.
b Although the assumed exposures to noncarcinogens are intermittent, the available
toxicity values for sy,stemic effects (RFDs) are most properly applied to chronic
lifetime exposures (daiIynO yr). Therefore, since lifetime RIDs are used to caIc""iJate
noncarcinogenic risks, resulting risks may be overestimated.
'Dermal intake is estimated assuming 100% and 25% body surface area exposed for
future residential and worker exposures, respeCtiveJy. Current residential exposures
assume 100% and 25% body surface area exposed for consumptive and nonconsump-
tive use, respectiveIy~ A permeability constant equal to water (Bx10-4 cm/hr) is
assumed.
-------
Tahle 8 (p8~ I of 2)
CARCINOC..:NIC SI,OP": .'ACTORS .'OR Tn..: VERONA WF.U. nEI.D
CONTAMINANTS n.' I>O'fF-NTIAI. CON(:..:RN
Onl Roote I Inhalation R~tes
"el~ht of Slope .'adnrh Wel~ht or Slope 'lid"'"
t..'hemlnl .:.lden~8 (m~-d8yrl SfmKe~ Uste E.ldeMe8 (mrfta-dayrl Souruc Date
Af1'Cnlc A 2 BEAST' --- A 50 IRIS 10-1-89
8en7.ene A 0.029 IRIS 12-1-88 A 0.029 IRIS 12-1-88
"
Beryllium ' 82 4.:\ IRIS 1-1-90 82 8.4 IRIS I-I-~
hl!i(2- Ethylhexyl)rhthalale 82 0.014 IRIS 8.1-89 82 -- IRIS 8-1-89
8rnmodichlommelhane 82 II,IJ HEAST 7-1-89 82 .. "EAST 7.1-89
Carbon letrachlorlde 82 0.13 IRIS 12-1-89 82 0.13 IRIS 12-1-89
Chlom~orm 82 OJJJ6I IRIS 6-3O-M 82 O.ORI IRIS 6-JO-KR
I,I-Dlchlnrnethane 82 OJt9l "EAST 7-1-89 - -- - -
1,2.Dlchloroelhane 82, 11.(191 IRIS 8-1-89 82 0.091 IRIS 8-1-8'1
I,I-Dlchlornclhene C 11.6 IRIS 4-1-89 C 1.2 IRIS 4-1-89
Hexachloroelhane C 0.014 IRIS J-I-M C 0.014 IRIS J-I-M
Melhylene chloride 82 fUJJ75 IRIS 10-1-8'1 82 0.014 IRIS 10-1-89
N - Nilrf15n-dlrmpylamlne 82 7 IRIS J-I-88 .. .. -- ..
Telrachlornelhene . 82 0.051 HEAST 1-1-89 82 o.OOJJ HEAST 7-1-89
1,1,2- Trichlnroelhane C 0.051 IRIS 9- 26-M C 0.051 IRIS 9-26-M
«(.'on'l.)
, -
-------
. - T.hle 8 (paRe 2 far 2) -
CARCINOf:.:NIC sun'.: .'AcrONS .UN 1'1": V.:NONA W.:U. ""':1.1)
- CON'I'AMINANTS 0.' l'on:NnAI. CONC.:NN
Onl NOllIe Inh.I.,1nn Roules
Wel~hl of Slope "'.d....' Wel~hl of Slope Fador'
('1IeIIIkal .:Yldente8 (~-da,rl Sourcec nale .:.ldente8 (mwq-da,rl Sourrec n.'e
Trichloroelhene 82 O.ftl. HEAST 7+89 02 0.017 HEAST 7-'-89
Vinyl chk.ride A 2.3 HEAST 7-1-89 A O.29S HBAST 7-1-89
-
'U.S. EPA Carcinolen Assessmenl Group (CAG) Oas.4iificalion.
Group A: Human carclnogen--Surricicnl evidence rrom cpidemiololical sludles.
Group 8.: Probable human arclnugen--AI leasl limlled evidence ur carcinugcnicily '0 humans.
Group 82: Probable human cardnugcn--Cumbinaliun or sunieicnl cvidcnce in animals and inadequale da.a In humans: .
Group C: Possible human carclnugen--Umlled evidence ur carcinngenici.y in animals In .hc absence or human da.a.
Group D: Nu. clas.4iiried-.lnadequale animal evidence ur carcinugcnicily.
Group E: Nn evidence ur carcinogenidly ror humans.-al Icasl .wo adcqua.e animallcsls shuw no evidcnce or carclnolenlcily.
t'Sources or lox Icily values:
IRIS--Integra'ed Risk Inrormalion Syslem. U.S, EPA 1988 (acces.4ied January 29, '990).
HEASTuHeallh Errecls Assessmenl Summary Tablcs-.Quarlerly Summary. U.S. EPA 19H9
tSlupe rac.or based on slupe or dose response curve rur carcinogcns. Siupe raclur is cxprc.'iscd In risk per averale daily mnlamlnanl
inlake, extrapolaled 10 low duse levels rrom Inrormaliun at high duse Icvels. E.'i.imale is al upper bound and nOI likcly 10 be cxceeded.
Truc risk may be much Inwer, or 7.cro. .
dOased un Risk A'iSCSSmcnl Forum unil risk ur ~JlIIt.5 (pgll).1.
-------
Table 9 ~pa~e I of 4)
TOXICITY VALUES FOR NONCARCINOGENS AT VERONA WELL FIELD
Rere~n~
IJo!;e (Rnt) . Confldenre
Chemlt'81 mrJkrJd8' Snul"t'e8 n8'e CrUIt'81 F.lred tJ~ MfC In Hm' .
URAl. ROUn:
Ace.one 0.1 IRIS 7-1-89 Increased liver and kidney weight 1,000 1 Low
- and nCl'hroloJdcl.y
Anlimony (UXIIJ4 IRIS R-I-89 Longcvily, blood glucose, and 1,000 I, low
cholcslerol
,menlc 0.001 I! HEAST 7-1-R9 Keral05ls and h)'l'erplgmcnl811on .. .. ..
lIarium 0.05 IRIS R-I-89 Increased bloud I'rcs.~ure 1m I Medium
Bcn1.olc acid 4.0 IRIS 8-1-R9 Human dally per capita . I 1 Medium
Dcryllium OJX)S IRIS 1-1-9ft No adverse erreds 1m I low
bis{2-E.hylhexyl)l'hlhala.e 0.02 IRIS 8-1-89' Increased relallve liver weight 1,000 t Mccllum
Bromodichloromelhanc n.02 IRIS 1-1-89 Renal cytomcgaly 1,000 I Medium
Dromomethanc 0.0014 IRIS 8-1-89 Epithelial hypcrl"asia of i,ooo . 1 Medium
forestomach
2-Bulanone 0.05 IRIS 12-1-89 Fetolodelly In rals 1,000 I Medium
BUlyl benzyl phlhalate 0.2 IRIS 9-1-89 Effects on IIver:body and IIver:bra'n 1,000 . low
weighl ral105
Cadmium O.OOOS IRIS 10-1-89 Significanl I'rolclnuria 10 I High
Carbon disulRdc 0.1 IRIS 2-1-89 Felal loxlcily/maUormalions too 1 Medium
Carhun IcirathlnricJc n.B1I17 IRIS 12-I-H9 Liver Icsiuns 1,(JlX) I Mcdium
Chlornhenzenc 0.02 BEAST 7-1-89 Uver and kidney crfecls 1,000 .. -.
Chlllrnrnrm n.m IRIS t}- .111-HH (7.."y l')'Si (I)rmation in livcr - I,IJIIII I Mcdium
'-
-------
Table. 9 (page 2 or 4)
TOXICI1Y VALUES FOR NONCARCINOGENS AT VERONA WELL FIELD
Rererenre
lIMe (Mnt) ~
Confldenre
t.1Innlral rnrftrJd., Sotlrre8 I).'e Criliral "'Bed u~ Mr In Mnt'
ORAL ROUTE (continued)
Chromium 811 1.0 IRIS 8.1.89 No errCCls obscned .00 10 low
,
Chromium VI 0.f10S IRIS J.I-M No effecis repor'ed SOO I low
Copper 0.037' HEAST 7-1-89 Local 01 '"'Ial'on - ~. ....
Di- n-IJUlylphl halale 0.1 IRIS 8-1.119 Increascd moria lily 1,000 I low
1,I.Dlchloroe'hanc 0.1 HEAST 7.1.89 None 1,000 - ..
I,I-Oichloroelhene lum IRIS 4.1-119 Hepallc lesions 1,000 I Medium
.rans-I,2-Dichloroclhcnc 0.02 IRIS 1.1-89 Increased serum alkallno ',000 . Low
phosphalase In male mice -
Dielhyl phlhalalc 0.8 IRIS 8-1.119 Decreased growlh rale, rood 1,000 I low
t:nnsumplion and allered organ
weighls
Elhylhen7.ene 0.1 IRIS H.I.R9 Uver and kidney loucily . I,IX" 1 low
Hexachloroelhane IUI" IRIS .1.I.M Alrophy and degeneralion of Ihe l,f1OO I Medium
renallubulc.~
Manganese 0.2 HeAST 7-1.89 CNS. 100 _ .~
Mercury O.fJlIflJ If EAST 7-1-K9 CNS 10 .. _-
Melhylene chloride 0.06 IRIS 10-1-89 Liver toxicity 100 1 Medium
4- MClhyl-2-pcnlanone(M IOK) fUJ5 IRIS 1-1-K9 Increascd liver and kidncy weighl I ,Of 10 I low
and ncphrulnxicily
-------
Table 9 (page J or 4)
TOXICI1Y VALUES FOR ",ON(;ARCINOGENS AT VERONA WELL FIELD
- Rereftn~ -
l)Me (Mm) Conlldenre
l"!1em!!081 mrJ'rJd., Snune8 1).le Crlllni FJred ut6 MJ« In Rm.
ORAL ROUTE (ronllnlltd)
2-Melhylphenol 0.05 IRIS 11-1-89 Decreased body wel!hts and 1,000 I Medium
neuroloxielly
4-Mclhylphenol o.ns IRIS 11-1-89 Decrea~ed hody weighl5 and 1,000 I, Medium
neuroloxielly
Naphlhalene 0.4e HEAST 1-1-89 Ocular and Inlerl1allCllon5 100 -- --
Nickel 0.021 IRIS J-I-RR Dccrea~ed hody and organ welghl5 100 J Medium
Nllrobenlenc 0"_105 IRIS 8-1-89 Hemalologlc, adrenal, renal and to,ooo 1 low
hepallc lesions
Phennl 0.6 IRIS 10-1-89 Reduced relal hody welghl In ral~ 100 1 Low
Tel rachioroci hene 0.01 IRIS 1.1-89 Hcpatolodelly In mice, weight Kaln t,ooo 1 Medium
'n ral5
Tnluene o.J IRIS 1-I-IW Clinical chcmi~Iry and hemalological 1110 1 Medium
parameler~
I, I, I. Trichloroelhane 0.09 IRIS 6-1-89 Slighl BrOW1h relardallon Kulnea .1,000 I Medium
plg~
1,1,2- Trlchloroelhane 0.104 IRIS 9-26-88 Clinical ~erum-cheml!'ilry 1,000 1 Medium
Vanadium 0.007 UEAST 1-1-89 None ohserved 100 -- --
Xylene!i 2.0 IRIS 7-1-89 ttypcraclivily, dccrea!'ied hudy welghl 1110 1 Medium
and increased mnrlalily (m:llc!'i)
Zinc 0.2 HEAST 1-1-89 Anemia. 10 .. --
-------
Tablr 9 (page 4 or 4)
TOXICITY VALUES FOR NONCARCINOGENS AT VERONA WELL FIELD
Referenre
nose (Rnt) Confldenre
1.1Ienllni mrJkrJd8' S..UI'ft8 nllte Crttlt81 ..:Ired v." MtC In Rnt.
INIIAIATION ROU1''': -
Bromomcthane 0.008 HEAST 7-'-89 Paralysis and lun, damage .,000 ... -
.
2.Butanone 'UJI) UEAST 7-1-89 CNS I,ID) -- --
('.arbon disulndc 0.0' mllm' EPA 9.20-89 Developmental elrcas .,000 ' - Medium
Chloruhen7.cne O.II'S HEAST 7-1-89 Uver and kidney effects lit.".' -- -.
',1- Dichloroelhane 0.1 HEAST 7-'.89 Kidney damage . ,000 - -
Melhylene chloride 0.86 EPA 9-21'-89 Kidney damage I,'x) -- Medium
Telrahydrofuran 0.07 mllm' EPA 9-20-89 Mucociliary depression, histological 3,000 - Low
changes
Toluene 2.ft mllmJ EPA 9.20.89 CNS crfects, eye and nose Ination lI.t -- Medium
1,1,1- Trichloroelhane 0.3 HEAST 7-1-89 Hepalntoxlclly 1,'0' -- ..
Xylenes O.l mllmJ EPA 9.20-89 CNS effects, nnse and thruat lilt 00 Medium
Inltalinn
. Suurccs of Tnxicily Values:
IRIS 0 Integraled Risk Information System. U.S. EPA i988 (aCCCSSt.'d January 29, I 99It).
HEAST - .'caUh EnL'Cls A~'SSmenl Summary Tables - Quarterly Summary. U.S. EPA ICJKCJ.
EPA - Verified Inhalatlnn Reference Dos~:s, Memorandum from Daniel J. GUlh, Ph.D Pollutant AS!icssment Branch, USEPA,
Scptemher 20, 1989.
It UF.Unccrlainly Faclnr.
C MF.Mndifying Faclnr.
d Cnnfidcnce raling frum IRIS, eilher high. medium, nr Inw.
~ The oral RID is heing recnnsidcred by thc RID wnrkgruup.
I Based nn prupnsed drinking water siandard nf D mg/!.
B Nil'kel value hased un nkkcl.snluhle salls.
-------
18
D. Risk Characterization
In order to determine risk, toxicity information for each chemical
is compared to the contaminant exposure levels measured at the
site. Following the determination of risks for individual
chemicals, cumulative risks are estimated by adding the individual
risks for the particular chemicals effecting a given pathway. The
result is a total risk estimate for that pathway of exposure to a
particular medium. For carcinogens, the result is the excess
lifetime cancer risk for the pathway. For noncarcinogens, this
results in a hazardous index (HI) for the pathway.
The current and/or future areas of potential risk are listed below.
These areas were calculated to have chemicals present with hazard
index values greater than one for noncarcinogens and/or excess
lifetime cancer risks of greater than 1 x 10~ for carcinogens. The
U.S. EPA considers excess lifetime cancer risks in a range of 10~
to 10~ as protective; however, the 10~ risk level is used as a
point of departure for setting clean-up levels at S~perfund sites.
* Current residential (nonconsumptive) uses
downgradient of Thomas Solvent Raymond Road
o,f
groundwater
* Current residential (consumptive)
downgradient of Thomas Solvent Annex
uses
of
groundwater
I * Future trench
(inhalation)
workers
at
any
of
the three
source
areas
* Future residents downgradient of and trench workers at any of
the three source areas (ingestion and dermal exposure to
gro.undwater)
Tables 10 through 15 summarize the cumulative risks for carcinogens
and noncarcinogens for each of the affected pathways identified at
the Verona Well Field site. A 1 x 10~ excess lifetime cancer risk
is considered appropriate for setting clean up goals at this site
considering the groundwater is currently used for drinking water
and is the sole source of drinking water for the City of Battle
Creek.
VII. DESCRIPTION OF ALTERNATIVES
A. Response Obiectives
Following completion of the baseline risk assessment, site-specific
remedial action goals were developed. These goals, listed below,
-------
Table 10
Summary or Risk Estimates from Groundwater
Downgradient or Source Areas
Exposure NoncarcinOlenic: Excess Ufetime
Area Scenario Hazard Ind~x Cancer Risk
Ingestion Dermal Inlestion Dermal
Annex Current Resident <0.01 <0.01 !xl 0-6 9x1O.9
(noncoDSulDpnve)
Annex Current Resident 0.02 <0.01 4x10" Ix 1 0-6
(CoDSulDpnve)
Raymond Current Resident 0.49 <0.01 5x10-5 SxlO.;
Road
Table 11
Summary or Risk Estimates from Groundwater
Upgradient of Source Areas
Exposure Noncarcinogenic: Excess Lifetime
Area Scenario Hazard Index Cancer Risk
Ingestion Dermal Ingestion Dermal
Paint Shop Current <0.01 <0.01 1x10.9 2x 10.11
'Resident
Raymond Current <0.01 <0.01 4x10.7 3x 1 0.9
Road' Resident
-------
". Table 1 2
Summary of Risk Estimates from Subsurface Soils:
Ingestion and Inhalation by Trench Worker
Exposure Noncarcinogenic Excess Lifetime
Site Scenario Hazard Index Cancer Risk
,
Ingestion Ingestion Inhalation
Annex Trench Worker 0.39 3x10-7 7x10~
Paint Shop Trench Worker <0.01 &lD-10 3xl 0-6
Raymond Road Trench Worker <0.01 3xlO-9 2xlD.s
Table 13
, Summary of Risk Estimates from Onsite Groundwater
in the Raymond Road Area
Exposure Noncarcinogenic Excess Lifetime
Site Scenario Hazard Index Cancer Risk
Ingestion Dermal Ingestion Dermal
Raymond Road Future 13.4 0.02 7xlO-3 Ix 10.5
Onsite Resident
Raymond Road ,Future 6.72 <0.01 1xl0.3 lxl0-o
Onsite I Worker
-------
Table 14
Summary of Risk Estimates from Onsite Groundwater
ID the Paint Shop Area
Exposure Noncarcinogenic Excess Lifetime
Site Scenario Hazard Index Cancer Risk
Ingestion Dermal Ingestion Dennal
Paint Shop Future Resident 18.7 0.03 ~1O.2 ~xlO's
Onsite
Paint Shop FutUre Worker 9.37 <0.01 4xl0.3 3xl0.(i
Onsite
Table 15
SummaI')' of Risk Estimates from Onsite Groundwater
in the Annex Area
Exposure . Noncarcinogenic Excess Lifetime
Site Scenario Hazard Index Cancer Risk
Ingestion Dennal Ingestion Dennal I
II
Annex Onsite Future Resident 20.1 0.04 7x 1 O'~ Ix 1 0-1
Annex Onsite Future Worker 10.1 <0.01 1x10'~ lxl0's
-------
19
are based on the general goals of the Superfund program as defined
in CERCLA and the NCP.
* lA-Limit groundwater contamination at the Verona Well Field
production wells to contaminant levels that meet State and
Federal clean up standards for protecting human health and the
environment;
* lB-Reduce groundwater contamination in the entire aquifer to
contaminant levels that meet State and Federal clean up
standards for protecting human health and the environment;
* 2A-Reduce all soil contamination at the major source areas to
. levels with a hazard index of less than or equal to one for
noncarcinogens and a total excess cancer risk 1 x 10~ or less
for carcinogens.
* 2B-Reduce all soil contamination at the major source areas to
levels that will prevent groundwater at the site from
exceeding the State and Federal clean up standards for
groundwater.
Site-specific clean up goals were also determined for soils and
groundwater based on the results of the risk assessment and Federal
and State Applicable or Relevant and Appropriate Requirements
(ARARs). Groundwater and soil clean up goals are listed in Tables
16 and 17 respectively. The site-specific remedial action goals
and clean up goals were the basis for developing, screening and
'evaluating a1 ternati ves in the feasibility study for the final
operable unit at the site.
It should be noted that the Cleanup goals listed in Tables 16 and
17 have been updated sincp issuance of the FS. This is because
several factors used in determining the cleanup goals have changed
since that time. 'First, based on new guidance for performing risk
assessments (OSWER Directive 9285.6-03), the assumptions used to
evaluate lifetime exposure have changed from 70 years to 40 years
and from 365 to 350 days per year. Second, cleanup numbers under
Michigan's A,ct 307 have been revised based on the change in
lifetime exposure assumptions (discussed above) and on new
toxicologic data developed. Third, cleanup numbers have been
adjusted to be at least equivalent to the lowest acceptable method
detection limits available.
B. Development of Alternatives
Alternatives developed in the feasibility study for the final
operable unit considered the Annex and Marshalling Yarj Paint Shop
source areas and groundwater downgradient of the sources and in the
well field. Additional remedial measures for the Thomas Solvent
Raymond Road source area are evaluated in a separate document
-------
Verona Well Field, Battle Creek, Michigan ..
Revised Groundwater Cleanup Objectives (6/12191)
Cancer Noa.carclnoaen
- IUIk 1UIk.R8Uo MJcblpn Cleanap
eon........... MDL Go8JII Go8rb MCL MCLG Act 307 Objecll\'r
Acetoae 5 - 3.500 - - 700 700
BaIzene 1 3 - 5 0 1 1
ChlOftIbenzene 1 - 700 loot 100c 100 100
Chloroform 1 14 350 100 - 6 6
1,l.Dicbloroethane 1 1 3.500 - - 700 1
1,2.Didlloroethane 1 1 - 5 0 0.4 1
1.I.Dic:bloroethene 1 0.2 315 7 7 7 . 1
1,2.Dic:hloroethene (cis) 1 - - 70 70 1 1
1,2.Dicbloroethene (trans) 1 - 700 100 100 100 100
Etbylbenzene 1 - 3.500 700 700 70 70
Methylene Chloride 1 11 2.100 - - 5 5
Terrac:hloroethene 1 2 .. 5 0 0.7 1
Toluene 1 - 10.500 1.000 1.000 800 800
1.1.1- Trichloroelhane 1 - 3.150 200 200 200 ~
1.1,2- Tric:hloroethane 1 2 140 - - 0.6 1
Tric:bloroethene 1 8 - 5 0 3 3
Vinyl Chloride 1 0.04 - 2 0 0.02 1
Xylene 1 - 70.000 10.000 10.000 300 300
aPraents concentrations lIIOC:iatecl witb a lxl0o(! ac:eu lifetime cancer risk based on in,estion of 2 htm per day of c:onlaminated
P'Ounclwater (70 q adull. 350 ~. 30 )11).
b"praents concenlrations IIIOc:iatecl wil~ reference dose for noncarc:inOJetlic: contaminants. Concenlration divided by reference dose
provides ri:.t ralio.
C:pr'OpOIed MCl. or MCl.O.
Nota:
.
All units in 1£1/1
MDL . Acceptable Method Detection Limit
Met . Maximum COntallUaaril !eYe1
MCl.O . Maximum contaminant level 'Oil
- . Indicates that no value is available
TABLE.6
-------
TABLE 17
Veron. W~II FI~ld, BaUI~ Cm" MI~hl2an
R~.lsN Soli Cleanup Objml.~ (6112191) ,
ObjKUn 2A OIIJecdft 28
TeI.P IoAtI_te
CalKer Risk Rlsk.Ratlo lor Mkhlpn
Soil Goal Goal G ro.ndw8ter Ad ~an..
Cont8mlnant MOL' (Can:l~ns,1 (Nonc.n:I~ns'Z ProtedlonJ .10,4 OhJ~dln
Renl~ne 10 7:\,000 .. 60 20 2Q
Carbon Tetrachloride . 10 16,000 490,000 JJ 6 10
I,I-Dichloroethane 10 23,000 70,000,000 20 10,000 20
I,I-Dichloroethcne 10 4,000 6,JOO,OOO 4 100 10
1,2-Dichloroethane 10 2.1,000 -- 20 8 10
1,2-Dichloroethcne (cis) 10 -. .. 20 20 20
1,2-Dichlorethene (tnns) 10 .. 14,000,000 2,000 2,000 2,000
Ethylhenlcne 10 .. 70,000,000 14,000 1,400 1,400
Met~ne Chloride 10 283,000 42,000,000 220 100 100
Tetnchloroethene 10 4:\,000 7,000,000 40 10 10
Toluene 10 .. 210,000,000 20,000 16,000 16,000
1,1, I-Trichloroethane 10 .. 6:\,000,000 4,000 4,000 4,000
Trichlor~thene 10 19~,OOO .. 160 60 60
Xylenes 10 -- 1,400,IlOO,000 200,IlOO 6,000 6,000
ICarci~enic concentntion refcrs to soil concentration 8ssociated with a II 10-6 excess lifetime c"rcinog~nic risk, basal on residential in&cstion exposure assumplions (0.1 rJd, 350 dtyr,
24 yo, 70 k& adull).
2Noocarci~enic concentration ref~rs to soil conc~ntration associated with an acceptaille daily exposur~ to a s~cific contaminant, 1Ia~ 'JII residential in&CSlion exposure assumplinns.
3Concentrations in soillhat would be eJl('CCted to leach into the &roundwater 8t concentralions «n:"t~r than th~ &roundwater &0815 lla5ed on U.S. EPA TCI.P procedures (4OCI'R261).
4eoncentntions in soillhat would be expecled to I~ach into the &rountlwater 8t cuncentrations «reater than Michigan Act J07 &roundwatcr cleanup1imits.
5Acceptable Method Detection Umits (MDNR, April 1991).
Note: Concentrations are in Prflt&
-' indicates thai nn value is availaille
In lieu of mcetin& suil cleanup numbers, a leachate tesll:"!-~ he performed as speciried in Seclion 6'of Michi&an Acl J07 for 1y~ II soil cleanups. '.
-------
20
titled, Performance Evaluation Report [of) Thomas Solvent Raymond
Road Operable Unit, Verona Well Field Site, Battle Creek, Michigan.
The findings presented in this document are discussed in Section IX
of this ROD. -
Remedial al ternati ves were 'assembled from applicable remedial
technology process options and were initially screened for
effectiveness, implementability, and cost. Alternatives surviving
the initial screening were evaluated and compared with respect to
the nine criteria required by the NCP. In addition to the remedial
action alternatives, the NCP requires that a no-action alternative
a1so be considered for the site. The no-action alternative serves
prim~rily as a point of comparison for other alternatives.
In ~eveloping alternatives, the FS takes into consideration that
previous remedial and removal actions have occurred or are
currently taking place and will continue to operate. The FS also,
makes assumptions regarding groundwater usage by the City of Battle
Creek. For the purpose of evaluating alternatives, 80 percent of
the City's 1989 maximum daily pumping rate was used. This was
considered a reasonable estimate for the average pumping rate in
the well field. No provision was made for increase in capacity
due to future growth in evaluating ~ffectiveness of the
alternatives. It is U.S. EPA's policy not to provide for future
growth in designing remedial actions at Superfund sites.
Due to the complex hydrogeology of the Verona Well Field, a
groundwater flow model cOupled with particle tracking was developed
and used to evaluate groundwater alternatives. The model allowed
for evaluation of hydrogeologic conditions and flow characteristics
for each alternative. Particle tracking was used to define capture
zones and estimate contaminant travel times under different pumping
scenarios.
Groundwater modeling of the no-action alternative indicates that
the current, blocking-well system may not provide complete
protection to the well field in the future. Simulated qroundwater
flow in the aquifer using pumping rates for 1989, indicate a
component of flow toward the Battle Creek River that could cause
contaminants to move around the \o:estern end of the blocking line to
the production wells west of the River, Bailey Park Wells (see
Figure 10).
Based or this finding, U.S. EPA's contractor, CH2M Hill, looked at
modifying the current blocking system and adding purge wells south
of the existing blocking wells in the vicinity of the southern
boundary of the well field. Based on a comparison of the two
options, additional purge wells were determined to be more
protective, easier to implement, and more cost-effective. As a
result of this evaluation, the FS assumed that additional purge
wells downgradient of the sources and south of the eXisting
-------
21
,
blocking wells in the well field will be installed under all
alternatives except the no-action alternative.
All of the alternatives include groundwater monitoring during the
remediation to measure progress and performance, and to verify
compliance with cleanup goals and discharge limits. Actual
monitoring points, duration of the monitoring program, and
analytical parameters will be determined by U.S. EPA, in
consultation with the State, during the remedial design. Table 18
provides a summary of the various components of each of the
alternatives.
c. Alternatives
Alternative 1 - No Action
Under Alternative 1 no additional corrective action would be taken
at the site. The no-action alternative would include continued
operation of the soil and groundwater remediation at the Thomas
Solvent Raymond Road facility and existing blocking wells and air
stripper in the well field as well.' Operation and maintenance
would include periodic replacement of pumps, blowers, and packing
in the air stripper as well as system monitoring and purge well
maintenance (e.g., acid cleaning and pump tests).
As discussed above, the existing blocking-well system may not
protect the western portion of well field in the future. Figure 10
illustrates projected groundwater flow in the aquifer for the no
action alternative. As shown, there is a component of flow that
could travel around the western end of the current blocking wells
and contaminate the Bailey Park Wells.
Since' no action w~uld be taken at the Annex and Marshalling Yard
Paint Shop source areas, contamination of groundwater would
continue. There would be no aquifer restoration at the source
areas and it is therefore assumed that the blocking wells would
have to operate indefinitely. Costs for this alternative would
result from the operation and maintenance of the existing
groundwater extraction system. It is estimated that operation and
maintenance costs per year would be approximately $160,000, with a
30 year present worth of $2,500,000.
Alternative 1 does not meet a number of Federal and State ARARS.
Specifically, it would not meet Federal Maximum Contaminant Levels
(MCLs) and Michigan Act 307 Rules.
Alternative 2 - Additional Purqe-Well System
Alternative 2 co~sists of the present blocking wells plus
additional purge wells to the south of the well field, downgradient
of the source areas. The FS estimated the need for 8 additional
-------
- Table 18
Combinations 01 Medla-Spedn.: Alternatives to Form Sitewide Alternatives
,
Media-Spttinc Alternative
Soil Gmundwater
SVE .t EXaI".tion! Down
Both Incineration Gradient Collection! In Situ
Sitewide No SOUI'ft .t Both No Purge Treatment or Blol8&lcal
Altem.tive ActioB Ami SoUI'ftI Action Wells SoUI'ft Aft811 .t Annex
Alternative 1 X X
Alternative 2 X X
Alternative J X X X
Alternative 4 X X
Alternative S X X
Alternative 6 X X X
Alternative 7 X X X
Alternative 8 X X X X
X = Component of the Sitewide Alternative
CVORI4M19O.SI
-------
22
wells with a total pumping rate of 1000 gallons per minute (gpm).
As discussed above, the addition of extraction wells to the south
of the existing blocking wells would prevent contamination from
bypassing the existing blocki~g wells and reaching the Bailey Park
Wells. Additional extract:i,on wells would also provide added
protection to the entire well field and would result in a greater
portion of the aquifer being cleaned up more quickly between the
sources and the existing blocking wells.
Extracted groundwater would be treated utilizing an air stripper
with vapor phase carbon for treatment of emissions. The design of
the stripper would be required to meet the technical requirements
of Michigan I s surface water and air discharge standards. Operation
and Maintenance of the treatment systems would include routine
maihtenance of the pumps, fans, and electrical systems and
replacement of the packing and parts. Long-term groundwater
monitoring would a1so be required for influent and effluent of the-
air stripper and the individual extraction wells.
Since no action would be taken at the Annex or Marshalling Yard
Paint Shop source areas, contamination of groundwater would
continue. There would be no aquifer restoration at the source
areas and it is therefore assumed that the. new purge wells would
have to operate indefinitely. Costs for this alternative would
result from the operation and maintenance of the existing blocking
wells and the new purg~ wells. It is estimated that Alternative 2
would have a capital cost of $1,400,000. Operation and maintenance
costs per year would be approximately $410,000, with a 30 year
present worth of $6,600,000.
All ARARs relating to the removal and treatment of contaminated
groundwater would be met. All spent carbon generated by the
treatment process would undergo regeneration at a RCRA compliant
facility. Air an~ Water Discharge standards would also be met by
the treatment process and flood plain protection would be
incorporated into siting of equipment. However, contaminants in
soils and groundwater at the source areas would violate Federal
MCLs and Michigan Act 307 Rules.
Alternative 3 ~ Groundwater Collection and Treatment
Alternative 3 consists of groundwater collection and treatment at
the Annex and Marshalling Yard Paint Shop source areas, and
implemeptation of Alternative 2, the additional purge wells. The
FS estimated the need for six extraction wells pumping at a total
of 400 gpm at the Annex, and four extraction wells pumping at a
total of 400 gpm at the Marshalling Yard Paint Shop.
Groundwater modeling was used to predict flow. directions and
capture zones of the proposed extraction well systems for the Annex
and Marshalling Yard Paint Shop (see Figures 17 and 18). The
-------
W8~
r
z..
LEGEND
o 200
I I
SCALE IN FEET
$ 8-23
I
MONITORING WELL
"""'--822.0 ---
GOUNDWA TER ELEVATION
CONTOUR, UNCONSOLIDATED UNIT
~
....
GROUNDWATER FLOW DIRECTION
EXTRACTION WELL
.
FICI.IAE 17
QAOlN)WA1CR SURFACE AND FlOW CfEC'noNs AT
THOt.;AS SOlYelT ANNeX FOR
AL. TEANA Th'E 3
VERON A WELL ~IELD
BATTLE CREEK, MICHIGAN
-------
'\
<9'9
~ \ \0""
CH-1 90 ~
Q) J
(S) '.C\' .
'/ . u
;> FLOW DlAEC110NS
.. PANT SHOP AREA
At. TERNA 11VE 3
VERONA WELL flEI.D
SA TTlE CREEK, MICHIGAN
-------
23
capture zone for the Annex groundwater extraction system is
estimated to extend 1000 feet laterally and 400 feet downgradient.
At the Marshalling Yard Paint Shop, the capture zone would extend
800 feet latera1~y and 400 feet downgradient. Contamination
greater than 400 feet downgradient of the source areas would
migrate to the new purge wells proposed as part of Alternative 2.
Extracted groundwater would be treated utilizing air stripping with
vapor phase carbon for treatment of emissions. The design of the
air stripper(s) would need to meet the technical requirements of
Michigan's surface and air discharge standards. Operation and
maintenance of the treatment systems would include routine
maintenance of the pumps, fans, and electrical systems and
replacement of the air stripper packing and parts. Long-term
groundwater monitoring would also be required for influent and
effluent of the air stripper and the individual extraction wells.
Although contaminants in groundwater at the source areas would be
captured, this a1 ternati ve does not include remediation of th~
source area soils which would result in indefinite loading of
contaminants to groundwater. Therefore, the groundwater systems at
the sources would likely need to operate for more than 50 years.
Downgradient contamination would migrate to the new purge wells and
would result in clean up of the downgradient portion of the
aquifer. The existing blocking wells would also be operational and
would result in removal of contamination between the blocking wells
and new purge wells. It is estimated that the aquifer downgradient
of the sources would achieve clean up goals in approximately 20
years.
Alternative 3 would attain ARARs relating to the removal and
treatment of contaminated groundwater. In addition, Federal and
State chemical-specific ARARs would eventually be met for
groundwater. All spent carbon generated by the treatment process
would be regenerated at a RCRA compliant facility. Air and Water
Discharge standards would also be met by the treatment process and
flood plain protection would be incorporated into siting of
equipment. However, the lack of soil treatment at the source areas
would violate requirements of Michigan Act 307 Rules for Type B
cleanups. .
Costs for this alternative would result from the operation and
mainte~ance of the existing blocking wells, the additional purge
wells and source area groundwater extraction systems. It is
estimated that Alternative 3 would have a capital cost of
$3,900,'000. Operation and maintenance costs per year would be
approximately $590,000, with a 30 year present worth of
$11,700,000.
Alternative 4 - In Situ Soil Treatment
Alternative 4 includes soil vapor extraction (SVE) systems at the
-------
'.
24
Annex and Paint Shop source areas to remove contaminants from the
unsaturated soils. The SVE system would be designed to treat all
contaminated soil at the Annex and the Paint Shop (currently
estimated to be 26,000 and 4,000 cubic yards respectively.
The FS estimated 'the need for 18 SVE wells and 9 air injection
'wells at the Annex with a total flow rate of approximately 2,200
scfm (standard cubic feet per minute), and 4 SVE wells at the Paint
Shop with a total flow of 400 scfm. The conceptual layout of the
systems at the Annex and Paint Shop are presented in Figures 19 and
20 respectively. Treatment of off-gases from the SVE systems will
be r:equired prior to discharge and must meet MDNR air permit
requirements.
No groundwater treatment at the source areas is included with this
alternative, but Alternative 2, the additional purge wells, would
be included. Because groundwater at the source areas would not be
extracted and treated, cleanup times for the aquifer between the
source areas and the downgradient purge wells is expected to be
greater than 50 years. The length of time for operation of the SVE
systems in order to meet soil clean up goals is estimated to be
between 2 and 5 years.
Soil treatmen~ to clean up goals would meet the requirements of
Michigan's Act 307 Rules for soil remediation. Treatment of vapors
would comply with Federal and State requirements for air emissions,
and the system could be designed and managed to meet all action and
location specific ARARs. Since this alternative does not include
groundwater extraction at the source areas, it is unlikely that
Federal MCLs or groundwater requirements of Michigan Act 307 would
'be met for sometime.
Costs for this alternative would result from the operation and
maintenance of the existing blocking wells, the additional purge
wells and source area SVE systems. It is estimated that
Alternative ~ would have a capital cost of $3,500,000. Operation
and maintenance costs per year would be approximately $620,000,
with a prese~t worth of $9,300,000.
Alternative 5 - Soil Excavation and Thermal Treatment
Alternative 5 consists of excavation and on-site incineration of
the contaminated soils at the Annex and Paint Shop source areas.
The volume of contaminated soils is estimated to be 26,000 cubic
yards at the Annex, and 4,000 cubic yards at. the Paint Shop.
Because of the lack of space at the Paint Shop, the FS assumed that
the incinerator would be placed at the Annex. 50.11 from the Paint
Shop would be transported to the Annex for treatment. A conceptual
layout of the incinerator and soil storage area is presented in
Figure 21. Much of the soils to be remediated at the Paint Shop
are presently underneath the existing Car Department building.
-------
SVE CONTROl
BUILDING -
PARKING
8B-I
BUILDING
-z-
o 50
L..r- .
SCAlE IN rEET
o
I.EGEHD
APPROXIUA TE LATERAL EXTENT
Of SOIl CONTAMINATION
SOIL VAPOR
EXTRACTION WELL
AIR INJECTION WELL
MONITORING WELL
AIR n.OW
RGURE 19
LWOUT OF SOl.. VAPOR EXTRAC110N SYSTEM
THOMAS SOLVENT AtN:X
VERONA WHL FiElD
OA TTl[ CRHK, MICHIGAN
x
.
!
b
%
"
-------
D
LEGEND
- -- - APPROXIMATE EXTENT
OF SOIL CONTAMINATION
. EXTRACTION WELL
MARSHALLING
YARD
z--.
o 100
~ I
SCALE IN FEET
m
c
::u
-t
o
z
::u
o
»
(:) AIR EXrRACTION UNI T &.
VAPOR PHASE CARBON
.---.
RCJJRE 20
LAYOUT OF SOL VAPOR EXTRACT10N S'J~I.:M
CAR DEPARTMENT AREA
vrRONA WUl Fln.D
SA TTl[ CRH.K. MICHIGAN
-------
,.
-RA~OND RD
--
J.E.Wm
.~
EXAMPLE HAUL ROUTE
SOURCf. AREA TO BE EVACUATED
:Z~
o 200
I I
SCALE IN FEET
...+-~
FIOURE 21
INCINERATOR LOCA noN AND LAYOUT
TI10MAS SOLVENT ANNEX
AL. TCRNA 11VES 5 AND 7
VERON A WELL FiELi)
SA TILE CREEK, MICHIGAN
-------
25
Prior to excavation, some or all of the building would have to be
demolished. Excavation of soils will likely result in fugitive VOC
releases that exceed State air quality standards and would requ~re
vapor suppressants and soil covers.
Incinerators have demonstrated a high percentage of destruction for
VOCs. Once treated, it is assumed that soils would meet the
cleanup objectives and would be delisted and replaced on the site.
The FS estimated that excavation and incineration of the
contaminated soils at the Annex and Paint Shop would be completed
in approximately 7 months. No groundwater treatment at the source
areas is included with this alternative, but Alternative 2, the
additional purge wells, would be included. Because groundwater at
the source areas would not be extracted and treated, cleanup times
for the aquifer between the source areas and the downgradient purge
wells is expected to be greater than 50 years.
Excavation and incineration of soils would meet the requirements of
Michigan I s Act 307 Rules for soil remediation. Air pollution
control devices may need to be implemented to comply with Federal
and State requirements for air emissions, and the system could be
designed and managed to meet all action and location specific
ARARs. Since this alternative does not include groundwater
extraction at the source areas, it is unlikely that Federal MCLs or
groundwater requirements of Michigan Act 307 would be met for some
time. .
Costs for this alternative would result from the operation and
maintenance of the existing blocking wells, the additional
downgradient purge wells and excavation and incineration of
approximately 30,000 cubic yards of soil. It is estimated that
Alternative 5 would have a capital cost of $20,000,000. Operation
and maintenance costs per year would be approximately $500,000,
with a present worth of $26,000,000. ,
Alternative 6 - Grdundwater Treatment and In Situ Soil Treatment
Alternative 6 combines Alternatives 2, 3, and 4 to include
continueB operation of the existing blocking wells, installation of
additional purge wells downgradient of the source areas,
groundwater collection and treatment at the source areas, and in
situ vapor extraction of source area soils.
Removing vadose ~one cor.tamination would limit contaminant
migration from soils to groundwater, and active groundwater
collection at the sources would greatly reduce contaminant plume
concentrations migrating from the sources. The FS estimated that
soil clean up goals could be achieved in 2 to 5 years.
Downgradient contamlnation would migrate to the new purge wells and
would result in clean up of the downgradient portion of the
aquifer. The existing blocking wells would also be oper.ational and
would result in removal of contamination between the blocking wells
-------
26
and new purge wells. It is estimated that the aquifer downgradient
of the sources would achieve clean up goals in approximately 20
years..
Alternative 6 would meet all. Federal and State chemical-specific
ARARs for soils and groundwater. The treatment systems could be
designed to meet all location- and action-specific ARARs as well.
Costs for this alternative would result from the implementation,
operation and maintenance of the existing blocking wells, the
additional purge wells, source area groundwater collection and
treatment, and source area SVE. It is estimated that Alternative
6 would have a capital cost of $6,200,000. Operation and
maintenance costs per year would be approximately $840,000, with a
present worth of $15,300,000.
e native 7 - Groundwater
reatment and So'
Alternative 7 is a combination of Alternatives 2, 3, and 5. This
includes continued operation of the existing blocking wells,
installation of additional purge wells downgradient of the source
areas, groundwater collection and treatment at the source areas,
and excavation and incineration of source area soils.
As with Alternative 6, removing vadose zone contamination would
limit contaminant mig~ation from soils to groundwater, and active
groundwater collection at the sources would greatly reduce
contaminant plume concentrations at the sources. The FS estimated
that soil clean up goals could be achieved in less than one year.
It is estimated that the aquifer downgradient of the sources would
achieve clean up goals in approximately 20 years.
Alternative 7 wou~d meet all Federal and State chemical-specific
ARARs for soils and groundwater. The treatment systems could be
designed to meet all location- and action-specific ARARs as well.
Because it is a RCRA waste, the incinerator ash would be delisted
prior to being placed back onsite.
Costs for this alternative would result from the implementation,
operation and maintenance of the existing blocking wells, the
additional purge wells, source area groundwater collection and
treatment, and excavation and incineration of source area soils.
It is estimated that Alternative 7 would have a capital cost of
$22,000,000. Operation and maintenance costs per year would be
approxi~ately $720,000, with a present worth of $31,100,000.
Alternative 8 - In Situ Groundwater and Soil Treatment
Alternative 8 includes the downgradient purge wells of Alternative
2, the source area groundwater collection and treatment systems of
Alternative 3, the source area SVE systems of Alternative 4 and in
situ biological treatment (bioremediation) of contaminants in the
-------
27
saturated soils at the Annex.
The addition of bioremediation at the Annex with groundwater
extraction would enhance the removal of contaminants adsorbed to
the soils in the saturated zone. The groundwater collection and
treatment system 'would extract groundwater, remove contaminants
through air stripping, add oxygen and other nutrients to enhance
bioremediation, and then replace the water back into the aquifer.
Figure 22 presents a conceptual layout of the hydraulic control
required for the system. Figure 23 shows the nutrient supply
systems and the system's conceptual mass balance. The FS estimated
the need for ten extraction wells with a total pumping rate of 110
qpm. Excess treated water would be discharged to the Battle Creek
River. .
Xmplementing bioremediation at the Annex would increase the removal
of contaminants in the saturated zone and decrease the time
required to achieve cleanup goals. The FS estimates ten years to
attain cleanup numbers at the Annex. However, as with Al ternati ves
6 and 7, groundwater cleanup goals would not be met at the Paint
Shop for at least 20 years. All other estimated times for
attainment of cleanup goals are the same as Alternatives 6 and 7.
Alternative 8 is expected to comply with all Federal and State
chemical-specific ARARs for soils and groundwater. The treatment
systems could be designed to meet all location- and action-specific
ARARs as well. However, the necessary injection of nutrients into
the aquifer would need to be evaluated before a determination is
made with regard to ARARs.
Costs for this alternative would result from the implementation,
operation and maintenance of the existing blocking wells, the
additional purge wells, source area groundwater collection and
treat~ent, source area soil vapor extraction, and bioremediati~n.
It is estimated that Alternative 6 would have a capital cost of
$7,400,000. Operation and maintenance costs per year would be
approximately $960,000, with a present worth of $16,000,000.
VIII. SUMMARY pF COMPARATIVE ANALYSIS OF ALTERNATIVES
In order to determine the most appropriate alternative that is
protective of human health and the environment, attains ARARs, is
cost-f:ffecti ve, and utilizes permanent solutions and treatment
technologies to the maximum extent practicable, the remedial
alternatives developed in the FS have been evaluated and compared
using the nine criteria set forth in the NCP. The nine criteria
and a brief description of each is listed below.
* Overall Protection of Human Health and the Environment
addresses whether or not a remedy provides adequate protection
and describes how risks are posed through each pathway are
eliminated, reduced or controlled through treatment,
-------
o
-I~.
H-107I
CH-107D
I TANI< I
SHED
.
. e
0 [S~AB I 8-610 .
-23 . 8-80
UNDER~~~~~~-J-q
LINE J
.
SOL VEN T
TRANSF"ER
t STATION e
.
.
N
.~ LOADI 'G
DOCK
,
o ~O . . I
I e
SCALE IN FEET 08-25
L~G~ND
G> EXISTING
MONITORINC WELL
.. GROUNOWATER EXTRACi10N WEI.I.
- - - - AF»F»ROXIMATE EXTENT OF' SOIL.
CONT AMINA TION
e SUF»F»I. Y WEL.L
. NEW F»ROCESS MONITORING WEI.I.
.
AOURE 22
IN SITU BIOREMEDIA 1100
waJ.. NE1WORK
'!ERONA WEL.I. rlEI.D
SA TTI.E CREEK. MICHIGAN
.
-------
T.eated Water to
8atIIe C.eek River
20 gpm
110 gpm
80 gpm
10 gpm
Above Ground
Groundwater
Treatment
(AIr SirIpper)
UquI:I
Oxygen
. f
1! . .
3 ~ ~
~ ~ z
(See Figure H-4 fo.
O2 and CH. Supply
System Deloll)
Gaseous
Methane
Subst.ate and
Nutrient Feed
110 gpm
SolI Vapor Ext.octlon
Withdrawal Pipes
(See fig... 5-11 'Of Detail)
90 gpm
':' ,:' ,,,',,':',", ' , fluid SUrfac.
.>. :. .: ,'., . 0" . " . $atUraledTr8atMeni'zoite- :. .
,..::' ":',':,"",:,",:':""""::'""',",' "",",'",:,:',,,:,,':: ,::,,"~ ,'<,:,"":,':'; ~~n~~~~men~,'~',:,,::.:,::..,..:, ",'
. . : .' ", ,0 .: :. . . . :,' "'."'.'
. .',
. . . . .
. . ..
o. .' . .
F.actu.ed Sandstone Bed.ock
., ,,,,,,,"A'
Note: Nol 10 Scale
Figure 23
ALTERNATIVE 8: CONCEPTUAL CROSS-SECnONAL LAYOUT
VERONA WEll FIELD
BATTLE CREEK. MICHIGAN
-------
28
engineering controls, or institutional controls.
* ComDliance With ARARs addresses whether or not a remedy will
meet all of- the applicable or relevant and appropriate
r:equirements of other Federal and State environmental statutes
and/or provide grounds for invoking a waiver.
* Lona-Term Effectiveness and Permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time once cleanup goals are achieved.
*.Reduction of Toxicitv. Mobilitv. or Volume refers to the
preference for a remedy that uses treatment to reduce health
hazards, contaminant migration, or the quantity of
contaminants at the site.
* 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 construction and
implementation period until cleanup goals are achieved.
* ImDlementabilitv is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option. .
* Cost includes estimated capital and operation and maintenance
costs and net present worth costs.
* State AcceDtance indicates whether, based on its review of the
RIfFS and proposed plan, the State concurs, opposes, or has no
comment on the preferred alternative.
* Communitv AcceDtance is based on comments received from the
public during the public comment period. These comments are
assessed in the responsiveness summary attached to the ROD
following review of the public comments received on the RIfFS
and the proposed plan.
A summary of t~e evaluation for each alternative is summarized in
Table 19.. Following the individual evaluations, alternatives were
compared in order to identify the alternative providing the best
balance among the nine criter.ia. The results of the comparison are
discussed below.
A. Threshold Criteria
The two most important criteria are statutory r,equirements that
must be satisfied by any alternative in order for it to be eligible
for selection. These two criteria are discussed below.
-------
o.m..
PrOlecll"n 01
"'- He-
and
Envtr.......e
-.--....--"- -...-
CompIi8nce wllh
ARAR.
... -----.
long-Term
EIlecIIV8MSS
. ...........
........ ....
. AdotJJac,'"
-- ..........
Reducllon of
TOllcity,
1IobI1iI" .nd
V"'"-
.,,~
"CIC8S~' used
.............
..-
Aft_'Iv. t
....-
II'''''''''''' ~
'~"''''''dI.lDdIr_1c..&«:I
... cunLMw'*" ~" "'0'.
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to ""lJla18 ..ough 01 ..ound
-....-.-...--
-
-----
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----
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DOwhg,adlP.n/
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groun:tr..- ...u.on '08 ...
-..--..-....
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------ .
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..., I.OIM""..ID ew.,:---
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not ..Idr." I0Il cClft8allWWlnl
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/vi sa....., aid .~ "1d'0t! 1:'-
bnu.......1UO 10 lie.. 0'01."".'"
conl.mU'4nl. Conlolm.nanil
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........
.---... --.-.
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........... 8OUId.. ..........,
.. SIll....
A"""""8 3
c._-C_"
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"~I..",,"..,",,~:~.,..,""AII I
Rr"o... ...". .. !8N. uI I.., ...,,-
Irtrn~b8.I.IO'~:J:J,....,
~ fISt, In grau..I1'" ...
so..r:. ....." .. "air eal.t....NJ
'.'D'''ftIQI8'''~''',ln, Was
WI pruIIJdiI)n ..... 8' A8 2
U"'''' aI AftAl1t ......" 10
.ountt...... and 8'ourwtw.....
'U8n8f8~b8... '.....
...... of ""f8QM Ad )1)1 .u18s
-..Id........,. tOWC8.."
'--______h_.
SOlI ,ISA. SMIle as AI , Grour.t
... mia, .---10 ...10- 8ft
-.. ......
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AlII """.'" ..11' ,.."., u""'1U
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'te,..Iu...r"'.......'" ..,.... 11..1 kJ
bu. laID'."" !..,....... co."",..
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SVI wouU br! ~I Iu n.~ 11101 h
nu.~ bnfJd ...fIIl!. 'or ".1fI"M
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...." l.aIt... m.-.y bn '~I.od lei
"18UI wid ~~.. 'It~"-=""S
ClOfbt an s.ohreIlI .:'!.k'S ,...
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.esdu.ll\ would.. .1.10' b dI
'I!'CI ~... e.poSUIu ';'0,,"11
...... ..sA:. SMnIt .., A. 2 SolI
(:0111..,..80III1I\ .. .......-..1 ,c.W18
..... ,......
Noll "",,"'h' .. t.o"lIe. r,d.'
&led .UUI"',"!f UJI'."'.",,,,,,,
'''.,IIJrwoNJr..S ...., be .rtIud
an II. ,....... ~.............., t:.,..
1ot...! Nu c.onIIuI~. ~ cdflLrcl
"""",'''
~- ....... ,...... III", to. Vt.ll >. .,
",8IIu'.. ,...... ,...e-. A. "...,....,
... qr.JU!."."''' ....tf..'.L''''..,.!
lllOY...1 I" ,.. ".~I ..... c....,
'..n"lt.tnh 1I~"",,,,'d ..1" ',vI
au'" boo 1""1"'..., ..~ .....,..d
Alle'N'1ve 5
(u:a.,.atlOfl end
lnc......allOlt" Sourcn
,,,........ II'''"., M"".p'..-8nlll,
I., . ,,'u' ..n... 8,.... ,.".....
.."'.. II.""'" ...., ."",,""'....'~.. ~
",. ........, ..... ~,~.om .. ..
".,.....sAI ~
1"-,,,,.""Md...........,wuuId
COI',., ...ft .. .au.... \pUI.1hc
AIiAIh. 11.01...... to I..~ Itll.b
nub,." All...'....' ~ fugJInr8
"""\IOII,""...n'l\ ..... .11:.
".1Ion ftOUId ..qur. ..equc...
1I0lllou"0 and t.ontl~ IIJII~
8UuId .lAir 10 ~.......... SUItS.
bll lI~etncnl~ --*1 be met
d..e....,.. 11......".1""'1 A' nC""
UII'WJOI'OIIls wmt' ..s .. AI 2
s...m.,b'-"
5.Itt"'.lS A. ,
'''..'I.'''..,....I:,VI .............
,.un..11'''''.''''-. H' w.".u..,. '''41'
'."'. AlII .....,.... ".II fII'..."'''
"'1 ..,11..111111'''''1'. "!,,,,''',,,, bl
tju,"""J -.:..
A""'MII"ell
c.-ac... c_-
- ".............. AIr
SbIA>ef;
In SlId SVE
h'.~adu... ,ad .."., I.uuld ba
, hIO'''''~re''''',''''''"~.A''''
au""""""""s palNUr""'"
bu .1110'..7010 )0 ,a..,
huugllUUl ......... .......
AlleonaU.... 7
c._--c-
8nd I.ealaWnll;
18Caw...ion ....
end.."...... .. Soule.
"'...
s...., on AI 6 ucnopt ~ tr,A"
t:ouIIJ... ,1810."" I,..
,. AlWts.. .....:Idd 10 be.....
b CuN..,....." ~.Ir.""".
--"""*-"
.-. .-. -_.~ -_. ---- -.----.
.s.m.. At .
.---.--.----------
SuII.nA, .'.IO'~~'NI..'"
.our.......... "'''10'.....20
DJU,.....
Sf" .... 0'''''''..'' Iru."""".
sl_.1 ""(miI" ....'!) lu.nl ....
qu.iIID ~01 01 Conl.ll'fWUllI'
:...u.. .1:'0 A... J ,...1"
-....- ..-.--.
s... as AI ,
s.m. ..s A8 ,
s...,,,,,,~A's ,;."It'~
AIIemaIw. .
~c-....
-h_;
.. SlId SVE .. _I -
PIInI ~.. s...
IIIoIaQIc8I T-
:......., .b AI 6 b JDtI ,..... II
".If ~.... ........
'M'.I.UIMIat.uG.a.td.. ..1.10'
OIl" .... . aatId t. ... . .
...... """.111 - --
A8> .... ,
---- - . - .-. - .-
,,~bot........, Itapaw.
............- ~
W. teA ...,....., "~""'88 ..
........' .., . ..... ..... ..
...,..... po 10 .. ........
kill III 1ft ......... M,..,
~......bAt .
----- .-.-...
Pol.nI.:.' toe ....,.8 complul8
lumu6........ .~ 8ft II.
.............. AI otIta1lwas.....
..... AnI.. .... 10,.,., ne
...d.aIIun at "OUt"''''' .. ..
,...... sf.. Itlill' ....,. 2G D JD
'UM'
,. ~ '''''yr... 'a:""""". ...
,,"'011\..' b do.""" VOL,
''''.''.....1'''.' .... 9h....""""'''
...1 ","'If"""'~, ~VI ......
"",.! ,..nc t.u.II,lItiMI.,nb "'If
"'''.''''''' III V,X; gtour"""""
l.ulIl"",.........
'able 19
DErAILED EVALUAflON Of AUERNAflVES
VII/ONII Will I n 811
11A11I1 ClnlK MIIIIk;/IN
-------
AIIem8IIw8 1
....-
IE"'" -"-1
Allem81hre 2
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AIr SIr......
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. raf!8Cl8dl'8duc.
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. ..-.-...
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DEJA/LED EVALUAJlON OF AlfERNAJlVES
VII/UNA Will 11.,1
IIAIIII UIlIK MIUnc.;1\N
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29
~. OVerall Protection of Human Health and the Environment
Alternatives 1 does not address current and potential future ris~s
from soil and qroundwater contamination at the sources and
groundwater downqradient of the sources. Al ternati ve 2 does
address risks posed by qroundwater downqradient of the sources, but
does not provide protection from qroundwater at the source areas.
Alternative 3 addresses risks from qroundwater contamination at
both the sources and downqradient. Risks posed from source area
soils would not be addressed by Alternatives 1, 2,' or 3.
Alternatives 4 and 5 would eliminate risks from contaminated soils
and would address risks from downgradient contaminant plumes,
however future potential risks from groundwater at the source areas
would not be mitigated for several decades.
Alternatives 6, 7, and 8 address all current and potential future
risks posed from soils and groundwater at the site.
2. Compliance With ARARs
Of the eight alternatives only those that contai~ both soil and
groundwater remediation would meet ARARs. Alternative 8 may
require a wavier of Michigan's Water Resources Commission Act to
allow injection of nutrients into the groundwater. Alternatives 1
and 2 would not meet Federal and State ARARs for qroundwater
including Federal MCLs and Michigan Act 307 Rules, nor would they
meet Act 307 for soil remediation. Alternative 3 would comply with
groundwater ARARs, but would not meet Act 307 requirements for
soils. Alternatives 4 and 5 would comply with Act 307 soil
remediation requirements, but would not actively address
groundwater contamination at the source areas and would, therefore,
take several decades to meet MCLs and groundwater requirements of
Michiqan Act 307.
B. Primarv Balancina Criteria
Five primary balancing criteria are used to identify major trade-
offs between the remedial al ternati ves which satisfy the two
threshold criteria. These trade-offs are ultimately balanced to
identify the preferred alterna.tive and to select the final remedy.
Alternatives that do not satisfy the threshold criteria include
Alternatives 1, 2 (by itself), and 3. These alternatives are not
discussed further (except the combination of Alternative 2 with
other alternatives):
1.' Long-Term Effectiveness and Permanence
Alternatives 4 through 8, once completed, could reduce residual
exc~ss lifetime carcinogenic risKs of contaminants associated with
the soil and groundwater to below 1 x 10~. In the case of
Alternatives 4 and 5, however, this would require an extended time
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30
period.
Alternatives 4 and 5 provide adequate and reliable controls for
preventing exposure from contaminated soils but not from source
area groundwater contaJtl.ination. Al ternati ves 6, 7 and 8 would
eliminate the need for control of contaminated soil or groundwater
once the remedial action is completed. For soils this would be 1
to 5 years, and for groundwater approximately 20 years.
2. Reduction of Toxicity, Mobility, and Volume
Alternatives 4 through 8 treat contaminants in soils and
groundwater and permanently destroy the contaminants thereby
reducing toxicity. Groundwater treatment requires destruction of
contaminants through regeneration of vapor/aqueous phase carbon.
Contaminants in soils would be incinerated, or destroyed through
regeneration of vapor phase carbon and/or catalytic oxidation.
Alternatives 6, 7, and 8 provide for reduction of the greatest
volume of contaminants because they treat the greatest volume of
contaminated groundwater.
3. Short-Term Effectiveness
All of the a1 ternati ves are expected to be protective of the
community and site workers during. implementation and operation of
the remedial action. The greatest potential risk to the community
and site workers is with Alternatives 5 and 7, due to release of
fugitive VOC emissions during excavation. Because groundwater
remediation will take several years, there is also a potential for
private well use during that time. Health advisories and/or
.temporary institutional controls may need to be implemented to
prevent this.
Alternatives 4 through 8 could achieve the remedial objectives for
the sitE (see Section VII). Alternatives 4 and 5 could both meet
soil remediation objectives in one year for Alternative 4 and 2 to
5 years for Alternative 5. The groundwater objective for
protection of the aquifer (Objective lB) would eventually be met at
the source areas but this would take several decades..
Implementing soil and groundwater remediation concurrently as with
Alternatives 6, 7, and 8, would meet groundwater and soil
objectives. However, Alternatives 6 and 7 require more than 20
years to achieve groundwater objective lB. This is due to the
continued desorption of contaminants from soil in the saturated
zone. Alternative 8 includes bioremediation of the contaminated
saturated zone soils. This would provide a reduction in time
required to achieve cleanup goals in the groundwater at the Annex.
None of the alternatives are expected to have adverse environmental
impacts. There is a potential impact associated with discharging
water to the Battle Creek River. This impact is mitigated with
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31
treatment of the water prior to discharge, provided the treatment
system(s) are maintained in proper working condition and in
compliance with discharge limits. Effluent limits required by the
MDNR are designed to protect aquatic life in the river. Because of
the proposed location of the incinerator at the Annex, no impact to
the environment would be expected from its operation.
4. Implementability
50il vapor extraction, which is proposed for Alternatives 4, 6, and
8, has been successfully implemented at the Raymond Road source'
area. Implementation of SVE is not expected to pose any problems,
but the length of operation is difficult to predict. Incineration,
proposed for Alternatives 5 and 7, is a proven technology and is
not expected to have implementation problems, however, there ~re
significant technical and administrative requirements for setup and
operation. Services and materials required to implement SVE,
onsite incineration and groundwater extraction are widely
available.
In situ biological treatment presents the most uncertainty with
respect to its technical feasibility. This technology is
considered innovative and its effectiveness has not been
demonstrated for many of the contaminants present at the site.
Implementation would require extensive bench- and pilot-scale
testing to determine its feasibility, the residual concentrations
it could achieve, and the time needed to achieve them. Services
for bioremediation of chlorinated compounds may be limited due to
the required expertise, which is offered by few companies.
Administratively, none of the alternatives, except Alternative 8,
would have difficulties. Substantive requirements of discharge
permits would have to be met for air and water discharges, and the
incinerator would. have to complete a test burn to demonstrate
compliance with emission standards. Bioremediation would require
permission from the State to inject t~e nutrients into the aquifer.
5. Costs
Costs for ope~ation of the existing blocking wells and cost for
Alternative 2 are included in the costs for Alternatives 4 through
8. Alternatives 5 and 7, which include incineration of
contaminated soils, are significantly more expensive than
Alterr.atives 4 and 6, which use soil vapor extraction. Alternative
8 is similar to Alternative 6, but is slightly more expensive
because it includes in situ bioremediation.
C. Modifvina Criteria
These two criteria reflect the comments and concerns of the State
and the local commu~ities on the alternatives presented to address
the Verona Well Field site contamination.
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32
1. state Acceptance
Tbe.MDNR has been the support agency for the RIfFS and has reviewed
this record of decision. The. MDNR concurs with the selected
remedial action. However, the MDNR feels that modifications to the
proposed SVE systems should be looked into prior to initiation of
soil remediation at these source areas. In addition, MDNR does not
feel that Alternatives 1 through 5 are protective or attain ARARs
and therefore these alternatives would not be acceptable to it.
I
2. Community Acceptance
Several comments have been submitted by the community, local
governments, and potentially responsible parties. In general,
issues presented in the comments were directed toward the locations
of the additional purge wells of Alternative 2, the results of the
risk assessment, the process for determining clean up goals for the
site, and the modeling used in the FS. In addition, there were
several comments that proposed additional alternatives. Overall,
most comments support the concept of SVE for soil remediation and
continued operation of the existing blocking wells. However, the
need for source area groundwater collection was questioned, as was
the need for the additional purge wells.
D. Summary
Based on a comparison of the nine criteria, Alternatives 1, 2 and
3 do not provide protection from all of the potential risks at the
site and do not comply with ARARs. Because these alternatives did
not satisfy the threshold criteria, they were not evaluated against
the remaining criteria. Alternatives 4 through 8 are protective
and would attain ARARs.
Alternatives 6, 7, and 8 provide the greatest degree of long-te~m
effecti veness and. permanence because they provide the greatest
degree of remediation of contaminants. All of the alternatives
provide reduction of toxicity through destruction of contaminants,
although, Alternatives 6, 7, and 8 destroy a greater volume of
contaminants.
Although all of the .alternatives would be considered protective of
the community during implementation and operation, Alternatives 5
and 7 have the gre~test potential for community exposure to VOCs
during excavation of contaminated soils. Alternatives 4 and 5
would attain soil cleanup goals in 5 years and one year
respectively. However, under these alternatives, groundwater clean
up would require more than 50 years. Alternatives 6 and 7 have
similar time frames for clean up of soils, but because groundwater
at the sources would be actively remediated, these alternatives
would clean up groundwater in 20 to 30 years.
Implementation of SVE for Alternatives 4, 6, and 8 is not expected
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33
to pose any implementation problems. Incineration, proposed for
Alternatives Sand 7, would have significant technical and
administrati ve requirements for implementation. Bioremediation has
not been shown -to be effective in the remediation of many of the
compounds present at the Annex. Extensive testing would be
required prior to start ~p and there would be numerous
administrative requirements associated with injection of nutrients
into the aquifer. In addition, there is a limited number of
experts available who could perform the work.
Alternatives Sand 7 are the most costly due to the incineration of
contaminated soils. Costs for 6 and 8 are similar, and are
somewhat greater than Alternative 4 which does not include
groundwater remediation at the source areas.
The'MDNR concurs with the selected remedy for the site, but does
not consider Alternatives 1 through 5 to be protective or comply
with ARARs and therefore would not accept any of these.
alternatives. The community, local governments and PRPs that
submitted public comments concur with soil remediation at the
sources and the continued operation of the existing'blocking wells
but differ on other aspects of the selected remedial action.
Public comments received during the public comment period are
addressed in the responsiveness summary of this ROD.
IX. REMEDIATION AT THOMAS SOLVENT RAYMOND ROAD
The Raymond Road remedial action was initiated as a result of a ROD
in August 1985 that called for installation and operation of SVE
and groundwater extraction systems to address soil ~nd groundwater
contamination at the Raymond Road source area. The previous ROD
set interim clean up standards for soils, and postponed
establishing clean up standards for groundwater. Final soil and
groundwater clean-up standards for the Raymond Road facility ~re
the same as for other source areas and the groundwater plumes
listed in section VII of this ROD (see Tables 16 and 17).
A. Conclusions of Performance Evaluation
As part of the ongoing remediation at the Raymond Road facility, a
performance evaluation report was developed to report progress and
evaluate potential enhancements to the ongoing remediation. Based
on the report's conclusions, several alternatives were proposed for
enhancement of both SVE and groundwater extraction systems.
I
The conclusions presented in the report are summarized below.
* The zone of influence of the groundwater extraction system
, does not extend downgradient to the livestock yard. High
levels of contamination have been detected in ~onitoring wells
in this area.
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34
* Loading rates of the off-gases from the SVE system hC!tve
decreased from greater than 1,000 pounds per day initial~y to
least than 10 pounds per day currently.
* Soil samples collected in 1989 and 1991 indicate that soils
contamination is now limited primarily to the smear zone
(unsaturated zone/saturated zone interface) in the locations
where floating product was detected previously. Results
indicate that the majority of the VOC mass has been removed.
* The presence of NAPL (nonaqueous phase liquid) has created
pockets of contamination in the pore spaces of the soils
located in the smear zone that slowly release VOCs to the
groundwater.. These pockets of NAPL are difficult, if not
impossible, to completely remove using conventional SVE 'and
groundwater extraction methods and result in the plateauing of
contaminant concentrations in groundwater which leads to
prolonged operation of groundwater extraction systems without
achieving cleanup goals.
* Transfer of VOCs from these pockets of NAPL in the soil pores
occurs more readily to soil vapor than to groundwater.
* Results of the bench-scale study suggest that SVE should be
able to remove the contaminants in soils, even with the NAPL
pockets, if sufficient air/NAPL interface is created.
B. Alternatives
Based on these conclusions, six alternatives were developed and
,evaluated to determine if enhancements to the systems c~uld be
implemented that would expedite remediation of soils and
groundwater. Thomas Sol vent Raymond Road (hereinafter TSRR)
Al ternati ves 1, 2, and 6 propose alterations to the existing
systems and Alte~natives 3, 4, and 5 propose the employment of new
treatment technologies.
TSRR Alternative 1 Intermittent
Groundwater Extraction Svstems
ODeration
t')f
the
SVE
and
I
This entails 'operation of the SVE wells and the groundwater
extraction wells on an intermittent basis. The system would be
turned off for several days or weeks and then operated for a given
period of time. The objective would be to allow contaminants more
time to diffuse into the soil vapor from the soil pore spaces.
This would result in a lower volume of groundwater and soil vapor
being extracted with greater concentrations of VOCs removed.
TSRR Al ternati ve 2 - Modifv the Existina SVE and Groundwater
Extraction Systems
This a1 ternati ve includes modification of the existing SVE and
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35
groundwater extraction systems. Modifications to the groundwater
extraction system would include additional extraction wells in the
area of the livestock yard to extend the zone of influence of the
groundwater extraction system to include capture of the high
concentrations of contaminants in this area. Modifications to the
SVE system would include: 1) .screening additional SVE wells in the
lower few feet of the vadose zone to force air into this area; 2)
installation of air injection wells screened in the lower portion
of the vadose zone to introduce horizontal flow to this area; and
3) install dual extraction wells (extraction of groundwater and
soil vapor from the same well). This technique provides for
enhanced removal of contaminants from the saturated soils. Dual
extraction wells lower the groundwater surface to expose more
contaminated soils that can then be subjected to SVE.
TSRR Alternative 3 - Radio Freauencv Heatina of the Soil
This alternative employs thermal energy to increase the rate of VOC
removal from the soil by raising the temperature of the soil. This
allows for increased volatilization of contaminants, and provides
the energy required to overcome the forces holding the NAPL in the
soil pore spaces.
TSRR Alternative 4 - Steam/Hot Air In;ection
Steam injection is similar to SVE with the exception that
pressurized steam is injected into the soil. Once injected, steam
condenses and mobilizes lower boiling point contaminants and aids
in the volatilization of higher boiling point contaminants.
Contaminants are recovered in the extraction wells in both liquid
and vapor phases and are treated using condensation, distillation,
and vapor phase carbon.
TSRR Alternative 5 - Steam/Hot Air In;ection With In Situ Soil
Mixina
This alternative combines steam injection with physical mixing of
the soil. Physical mixing is accomplished using a large drilli~g
tower with two augers that mix the soil. As soil is mixed, hot air
and steam are injected in to the soil. The steam and hot air
volatilizes VOCs and they are then carried to the surface where
they are treated as described in TSRR Alternative 4.
TSRR Alternative 6 - Groundwater Aeration
With groundwater aeration, compressed air or nitrogen is sparged
into the saturated zone to remove VOCs in the saturated zone. As
air moves through the pore spaces, it displaces the groundwater
which causes contaminants to volatilize into the air or soil vapor
and is extracted by the SVE system.
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36
c. SummarY of Evaluation of Alternatives
The alternatives were evaluated based on effectiveness,
implementability, and cost. Table 20 presents a summary of the
evaluation.
~. Effectiveness
Intermittent operation of the extraction systems under TSRR
Alternative 1 would increase Voc concentrations in the soil vapor
but would probably not hasten removal. In fact, it could slow the
rate of removal due to a decrease in the concentration gradient
between soil vapor and adsorbed VOCs which would decrease the rate
of diffusion to soil vapor. Intermi ttent operation of the
groundwater extraction system is not expected to have any effect on
rate of contaminant removal from the saturated zone, nor has
experience shown any increase in removal rates by the SVEsystem
following shut down of the groundwater extraction system.
TSRR Alternative 2 has the potential to significantlY increase the
effectiveness of the SVE and groundwater extraction systems by
providing quicker release of contaminants from soils through air
injection and dual extraction. Additional groundwater extraction
wells would significantly reduce the time required to reach
groundwater cleanup goals in the aquifer.
TSRR Alternative 3 would likely be very effective at removing
contaminants from the vadose zone. Field data suggests a greater
than 90 percent removal efficiency. However, this technology would
not remove contaminants in the saturated soils, and thus would not
decrease cleanup times for the groundwater.
Like TSRR Alternative 3, TSRR Alternative 4 would be effective in
removing contaminants from the vadose zone, .but would not address
contamination in' the saturated soils. Some SVE vendors have
experienced difficulty in operation of stearn injection due to
condensing stearn clogging pore spaces.
TSRR Alternative 5 would likely provide the quickest and most
effective means of completing remediation of the vadose zone. Based
on current field data, site remediation could be completed within
a year after implementation.
TSRR Al ternati ve 6 provides for removal of contaminants in the
saturat~d soils and may also be effective in removing VOCs from the
capillary fringe.
2. Implementability
I
No technical or regulatory involvement is required for TSRR
Alternative 1. TSRR Alt~rnative 2 would require additional well
installations for both soil and groundwater extraction systems and
-------
T.h~ 20
S.mm81'J .. t:..I..11on of R.mHllal Opt""
AIIor..-11ft IlirKrt,I'" t:IfHllw- Im,._....'!"1 C~..
AlItm8I~ 1 . Inlnmillenl oprralion . l.imiled . I~ 10 imrkmenl . None
AIItm8I~ 2 . SVI! lpIem lIIOdificalion . MOIl mnlamin.nls rellJ(Md In . l:.y 10 ImJ*men1 . SIO 10 IJ per yard
2 10 J ran
AllmuIM] . Radio rreque!XJ heallnl . 90 ~nl mnla~in.nl relllCMlI . Technically way mmpla . S1J per yard
aller 1 year
. Would require "ailed review
from Siale ululalnn
,
AllmulM 4 . Slell~ 8ir lajmion . , InpltWftl hul 1IIC8I . MocIcralely mmpla . SSO per yard
mnlaminanls probably removed
In I rar . RqulalOl'J ronc:an abold
milralion «If lleam and orpaie
, liquids
Allmu'~ J . In ail. 8011 millinl . 90 penal mnlamlnan' UIIMMII . Technically mmpla . Sioo '0 SJOO per yard
afler I rar
. Would require "ailed review
- from rqula'OI'I
AllmulM 6 . O.-.dw8ler Ift1IlioIt . Shown '0 be err«.~ on a few . 1!8y '0 ImJ*men' ?
ai'a
. Rqula'ory mnttI1I abo8t air
injec.ion inlo aquifer
aNo addi.1onaI CI1I'; abold 10 pen:al deaaae In Ctlrrm' oprnllnl CI1It.
Noce: OJalllis.ed abowe ate hi addi.ion '0 .he 001" already Incumd a' the aile. "f'he aJItJ do IIOC include apenaa aaoda.ed wI.h cuw'rudlon oweni,h..
pennllllna, or ftrificalion ,,","in,.
\.
-------
37
additional piping. Installing additional extraction
dual extraction wells would requir~ modifications to
pumping system for groundwater. No new regulatory
would be required.
Technical and regulatory implementation issues of TSRR Alternative
3 are expected to be complex. Application of this technology would
be the' first full-scale demonstration of this technology. In
addition, it is not clear if the technology is commercially
available. TSRR Alternative 4 would require less complex technical
and requlatory requirements than TSRR Al ternati ve 3, but would
require a demonstration that the injected steam could be
controlled. Implementation of TSRR Alternative 5 would have
similar requirements as TSRR Al ternati ve 3. There are several
issues that would need to be resolved and could result in a 2 to 3
year delay in implementation. TSRR Al ternati ve 6 would be
relatively easy to implement although it would probably require
pilot testing to determine radius of influence of injected air.
wells and/or
the existing
requirements
3. Costs
Cost savings for TSRR Alternative 1 may not be significant beca~se
the system maintenance and analytical costs would remain unchanged.
SVE operating cost savings would be offset by the ihcreased costs
associated with turning the system on and off. Additional cost of
implementation and operation of TSRR Alternative 2 for 2 years of
operation is estimated to be about $400,000.
TSRR Alternative 3 is estimated to cost approximately $2,800,000.
This cost is based on pilot-scale operation and could increase
substantially for permitting and engineering oversight. The
preliminary cost estimate for TSRR Alternative 4 is approximately
$2,200,000. TSRR Alternative 5 has an estimated cost of
$7,400,000, and could be much more based on permitting requirements
and engineering Qversight. There is limited cost information
available for TSRR Al ternati ve 6. However costs are expected to be
approximately $40,000 for well installation and it is assumed thbt
operation costs would be similar to the air injection portion of
TSRR Alternative 2.
D. Sumrnarv
TSRR Alternative 1 may not be acceptable due to the requirement to
turn off the groundwater extraction system. There are no cost
savings and no decrease in operating time. Since the report
concluded that SVE should be able to remove contaminants from the
vadose zone with enhancements, TSRR Alternatives 3, 4, and 5 are
not justified because they do not address the saturated soils and
are very expensive to operate for a reduction in operation time of
1 to 2 years over conventional SVE. TSRR Alternative 2 provides
enhancements to the effectiveness of the SVE system at a lower
cost, ,is implementable, and would provide some enhancement to
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38
remediation of the groundwater. TSRR Alternative 6 looks to be the
most effective technology for the saturated soils, and it would
provide some enhancement to remediation of the vadose zone.
x. SELECTED REMEDY
This section presents the selected remedy for the final operable
unit at the Verona Well Field Superfund site. Section 121 of
CERCLArequires that all remedies for Superfund sites be protective
of human health and the environment, comply with ARARs, be cost-
effective, and utilize permanent solutions and alternate treatment
technologies to the maximum extent practicable. Alternative 6 is
believed to provide the best balance of trade-offs among
alternatives with respect to the nine criteria set forth in the NCP
for evaluation of alternatives. Based on the evaluation of the
a1 ternati ves, u. S. EPA and the State of Michigan believe that
Alternative 6 will be protective, attain ARARs, be cost-effective,
and will utilize permanent solutions and alternate treatment
technologies to the maximum extent practicable.
The selected remedy for the final operable unit entails:
Continued operation of the existing blocking wells and air
stripper in the Verona Well Field;
- Installation and operation of additional purge wells
downgradient of the source areas, and groundwater treatment
(utilizing air stripping with vapor phase carbon) for
extracted groundwater;
- Collection and
phase carbon)
501 vent Annex
source areas;
treatment (utilizing air stripping with vapor
of contaminated groundwater at the Thomas
and Grand Trunk Marshalling Yard Paint Shop
- Installation and operation of soil vapor extraction systems to
remediate contaminated soils at the Annex and Paint Shop
sources areas; and
- Implementation of groundwater, soil, surface water discharge,
and air monitoring programs to monitor the treatment systems.
The respDnse objectives and cleanup goals for the final remedy are
presented in Section VII of the ROD. Response objectives include
continuing to limit groundwater contamination at the Verona Well
Field prDduction wells to levels that do not pose a health hazard,
reducing contamination in the affected aquifer and in all source
area soils to levels that meet cleanup goals, and preventing
additional contamination of groundwater above cleanup goals through
leaching of contaminants from soils. Cleanup goals developed for
the final remedy are listed in Tables 16 and 17. The selected
remedy will achieve the response objectives and cleanup goals for
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39
the site.
The risk assessment identified 48 chemicals of potential concern.
for the site. Of those, 18 chemicals were identified as indicator
chemicals for groundwater and 14 chemicals were identified as
indicator chemicals for soils. These indicator chemicals (listed
.in Tables 16 and 17) are the primary compounds, with the exception
of arsenic, found during the risk assessment to present individual
risks greater than 1 x 10E-6 increased carcinogenic risk or a risk
ratio of greater than one. Since other compounds were identified
(the remaining chemicals from the list of 48 not identified as
indicators) at the site, periodic sampling will be required to
ensure that none of the remaining chemicals are exceeding ARARs.
Sampling for these chemicals will be required at a minimum of once
every two years. Table 21 lists the Act 307 Type B cleanup numbers
for all 48 chemicals of potential concern. These numbers would be
utilized as action levels for compliance with Act 307, an ARAR for
the site.
One of the goals of this remedial action is to restore groundwater
to its beneficial use, which is, at this site, a drinking water
source. Based on information obtained during the RI/FS, U.S. EPA
believes that the selected remedy will achieve this goal. It may
become appar~nt, during implementation or operation of the
groundwater extraction system that contaminant levels have ceased
to decline and are remaining constant at levels above the cleanup
goals for the site in some portion of the plumes. In such a case,
the system performance standards and/or the remedy may be
reevaluated.
The selected remedy calls for groundwater extraction for a period
of 20 to 30 years, during which the system's performance will be
carefully monitored on a regular basis and adjusted as warranted by
performance data collected during operation. The remedial design
will specify the s~mple locations, sample frequency, analytical
parameters, aild reporting requirements for the monitoring program.
The final remedy incorporates the ongoing interim actions at the
sjte as part of the site remediat~on. Based on conclusions of the
Performance Evaluation Report (for] Thomas Solvent Raymond Road
Operable .Unit, April 1991, the final remedy also includes the
following additional and/or continued remedia). actions at the
Thomas Solvent Raymond Road source area: .
- Continued operation and maintenance of the
extraction system including installation of
groundwater extraction wells;
groundwater
additional
- Installation of a treatment system for extracted groundwater;
and
- Implementation of a groundwater monitoring program.
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Table 21
Michigan Act 307, P.A. 1982, as Amended
Type B Cleanup Numbers: 6/20/91
COMPOUND
Carcinogenic:
Benzene
1,2-Dichloroethane
n-Nitroso-di-n-propylamine
Trichloroethene
Vinyl Chloride
Noncarcinogenic:
Acetone
Antimony
Barium
Benzoic Acid
Benzylbutylphthalate
Bromomethane
2-Butanone
Cadmium
Carbon Disulfide
Chlorobenzene
Chromium (total)
Copper
Dibutylphthalate
biethylphthalate
Ethylbenzene
Manganese
Mercury (inorganic)
2-Methylphenol .
4-Methylphenol
4-Methyl-2-Pentanone
Naphthalene
Nickel
Nitrobenzene
Phenol
Toluene
Trans-1,2-Dichloroethene
1, 1, 1-Trichloroethane
Tetrahydrofuran
Vanadium
Xylenes
Zinc
GROUNDWATER (ua/l)
1
0.4
0.005
3
0.02
700
3+
2000+
30,000
1000
10
400
4+
700
100
100
1000+
700
6000
70
700
2+
40
400
400.
30
100+
4
4000
800
100
200
200
*
300
1000+
s:>n ~ (\XI Ika)
20
8
0.1
60
0.4
14,000
60+
40,000+
600,000 .
20,000
200
8000
80+
10,000
2000
2000
20,000+
10,000
100,000
1400
10,000
40+
800 i
8000
8000
600
2000+
80
80,000
16,000
2000
4000
4000
*
6000
20,000+
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Table 21
(continued)
Michigan Act 307, P.A. 1982, as Amended
Type B Cleanup Numbers: 6/20/91
COMPOUND
GROUNDWA'I'ER (Uq / l)
~TT.C::(uq/kq)
Both Carcinogenic and Noncarcinogenic:
Arsenic
Beryllium
Bis (2-ethylhexyl) phthalate
Bromodichloromethane
Carbon Tetrachloride
Chloroform
1,1-Dichloroethane
1,1-Dichloroethene
Hexachloroethane
Methylene Chloride
Tetrac~loroethene
1,1,2-Trichloroethane
0.02+
*
2
0.3
0.3
6
700
7
2
5
0.7
0.6
0.4+
*
40
6
6
100
10,000
100
40
100
10
10
+
------------------------------------------------------------------
If local
criteria,
goal.
background is greater than these health-based
local background can be used as a final cleanup
*
No Type B cleanup numbers have
beryllium; therefore, Type A
compounds. This number is
provided when developed.
been developed for vanadium and
numbers will be used for these
being developed and will be
Note: In lieu of meeting soil cleanup numbers, a leachate test may
be performed as specified in Michigan Act 307, for Type B cleanups.
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40
This additional groundwater action is based on TSRR Alternative 2
of the performance report which is discussed in Section IX of the
ROD. TSRR Alternative 2 proposed enhancements to the SVE system as
well as the groundwater extraction system, however, only the
groundwater portion of TSRR Alternative 2 will be incorporated into
the final ROD. SVE enhancements will be addressed by the current
actions on-going at Raymond Road. A pilot test for the SVE
enhancements evaluated in TSRR Alternatives 2 and 6 is currently in
the planning stages.
In accordance with the preference for innovative treatment
technologies and to ensure the most expeditious clean up at the
site, emerging in situ treatment technologies shall be evaluated as
to their effectiveness in addressing VOCs in saturated and
unsaturated soils. The evaluation will focus on whether any such
technologies have the capability of reducing contamination in the
saturated and/or unsaturated soils such that cleanup time is
reduced or the ability to achieve cleanup goals is enhanced.
XI. STATUTORY DETERMINATIONS
The selected alternative for the Verona Well Field, as outlined
above, meets the statutory requirements set forth in Section 121 of
CERCLA, in that it is protective of human health and t~e
environment, attains ARARs, is cost-effective, utilizes permanent
solutions and treatment technologies or resource recovery
technologies to the maximum extent practicable and has a preference
for treatment as a principal element as described below.
A. Protection of Human Health and the Environment
The selected remedy addresses risks posed from all of the pathways
identified in the risk assessment for the site. Remediation of
grounowater at the sources and downgradient in the aquifer will
reduce the potential excess lifetime cancer risk for ingestion of,
inhalation of, and dermal exposure to contaminated groundwater to
1 x 10~ throughout the aquifer. Furthermore, the hazard index for
risks from noncarcinogens in groundwater at thE:' Thomas Solvent
Raymond Road source area will be reduced to less than one.
Remediation of' source area soils will reduce the potential excess
lifetime cancer risk from inhalation of contaminants in soils by
future onsite workers to 1 x lO~.
Implementation of the soil and groundwater remedial actions at the
source areas and in the downgradient aquifer, as called for in the
selected remedy, will not pose any unacceptable short-term risks or
cross-media impacts to the site, the community, or the onsite
workers.
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41
B. Comcliance with ARARs
The selected remedy, which is the final remedy for the entire site
including the modifications to the prior Thmas Solvent Raymond Road
operable unit ,will comply with all Federal, and more stringent
State, applicable or relevant and appropriate requirements (ARARs)
of environmental laws. The following is a discussion of the major
ARARs which the selected remedy will attain. Additional ARARs can
be found in other documents in the administrative record.
I
1. Chemical-Specific ARARs
Chemical-specific ARARs include those laws and requirements that
regulate the release of contaminants to the environment.
Federal
Maximum Contaminant Levels (MCLs) and non-zero Maximum Contaminant
Level Goals (MCLGs) are the Federal drinking-water standards
promulgated under the Safe Drinking Water Act (SDWA), and are
applicable to municipal water supplies serving 25 ~r more persons.
MCLs and non-zero MCLGs are relevant and appropriate for the Verona
Well Field site since the affected groundwater at the site is a
drinking water supply. .
Secondary MCLs established under the SDWA are desiqned to control
contaminants in drinking water that effect the aesthetic qualities
of drinking water, and are nonenforceable under the federal
regulations.
Section 304 of the Clean Water Act (CWA) establishes Ambient Water
Quality Criteria (AWQC) for protection of human health and aquatic
life. The AWQC are considered relevant and appropriate at
Superfund sites where a release or the threat of release is prese~t
or when remedial actions require point source discharges. Since
treated water will be discharged to the Battle Creek River, AWQC
are relevant and appropriate for the discharge.
I
No Federal chemical-specific standards exist for soils.
State
The Michigan Enviro~mental Response Act 307, P.A. 1982, as amended,
and associated rules (Act 307) and administrative rules promulgated
uJ"der the act provide for the identification, evaluation, and
remedia'tion of environmentally contaminated sites within the State.
Therefore, the U.S. EPA considp.rs substantive portions of Parts 6
and 7 of Act ~07 t~ be an ARAR for the remedial action at this
si~~. Under Act 307, all remedial actions must be protective of
public health, safety, welfare, and the environmental and natural
resources of the State. To achieve protectiveness, Act 307
specifies that remedial actions shall achieve a degree of cleanup
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42
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) criteria.
The v.s. EPA has determined that acceptable standards for soil and
groundwater cleanup, that have been derived under type B criteria,
would be protective for groundwater and soils at the site. Cleanup
levels derived under Type B criteria would allow the aquifer to be
restored to its beneficial uses by achieving the risk-based cleanup
standards the U.S. EPA has determined will assure protection of
human health and the environment.
Portions of the Water Resources Commission Act 245, P.A. 1929, as
amended, (Act 245) establish surface water quality criteria
standards to protect human health and the environment. The State
administers the NPDES program under Part 21 of Act 245. Therefore,
Part 21 of Act 245 would be applicable to the direct discharge of
treated water to the Battle Creek River or to the indirect'
discharge through groundwater movement to a surface water body.
The Michigan Air Pollution Control Commission Act 348, P.A. 1965,
as amended, (Act 348) establishes standards for ambient air quality
and emissions. Compliance with Act 348 requires attainment of an
incremental carcinogenic risk concentration of l' x 10~ and one
percent of the threshold limi t value concentration for
noncarcinogens. The, substantive requirements of Act 348 are
considered applicable to air discharges as a result of the selected
remedial actions.
2. Location-specific ARARs
Location-specific ARARs are those requirements that relate to the
geographical location of the site.
Federal
Both RCRA (40 CFR 264.18 (b) - hazardous waste storage - flood
plain) and Executive Order 11988 - Protection of Flood Plains, are
relevant and appropriate for this site, since the well field is
adjacent to the Battle Creek River. These regulations require
placement of groundwater treatment systems in the well field be
above the lOa-year flood plain. The Endangered Species Act of 1973
is also a location-specific ARAR for the site.
State I
The Hazardous Waste Management Act 64, P.A. 1979, as amended, (Act
64), regulates the generation, transport, treatment, storage, and
disposal of hazardous waste. A more specific discussion of the
siting provisions of Act 64 is set forth in the responsiveness
summary. .
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43
3. Action-Specific ARARs
Action-specific ARARs are requirements that define acceptable
treatment and disposal procedures for hazardous substances.
Federal
Since the Thomas Solvent Company operated waste storage facilities
that resulted in release of contaminants to the environment after
1980, RCRA is applicable for the Raymond Road and Annex source
areas, and wastes contained in soils and groundwater from releases
that originated from these facilities are RCRA-listed wastes. The
release of contaminants from the Grand Trunk Paint Shop occurred
prior to 1980, so RCRA is relevant and appropriate for contaminated
soils and groundwater resulting from release of hazardous
substances from that source area. Since the TSC facilities were
RCRA regulated storage facilities, closure regulations under RCRA
Part 264 Subparts I and J (264.178 and 197) are applicable. The
remedy complies with the requirements for closure because treatment
of soils with SVE will be equivalent to "clean closure." Closure
and post closure requirements for storage facilities are regulated
under RCRA Part 264 Subpart G. The remedy complies with
substantive requirements pertaining to closure (264.111, 264.112
and 264.113). In addition, corrective action requirements of Part
264 Subpart F will be met for the entire site to the extent they
are applicable or relevant and appropriate. Since spent carbon
from the treatment systems will be shipped off-site to be
regenerated, Land Disposal Restrictions (Land Ban) apply to the
extent that no~ification must be made to the treatment facility
that the wastes are RCRA-listed. The remedy does not include
"placement" of wastes under Land Ban. '
State
The State of Mich~gan is authorized to administer RCRA within the
State. Under the Hazardous Waste Management Act 64 (Act 64) the
State regula~es the generation, transport, treatment, storage, and
disposal of hazardous waste. Pertinent portions of Act 64 that are
more stringent than RCRA Subtitle C would be applicable for the
Verona Well Field site.
C. Cost-Effectiveness
Cost-effectiveness compares the effectiveness of an alternative in
relation to its cost of protecting human health and the
environment. Alternative 6 is the least costly alternative that
provides protection from all identified current or potential future
pathways of exposure from contaminated soils and groundwater at the
site.
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44
D.
t
U.s. EPA believes 'the selected remedy represents the maximum extent
to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner for the Verona Well Field site.
Of the alternatives that are protective of human health and the
environment and comply with ARARs, U.s. EPA has determined that the
selected remedy provides the best balance of trade-offs in terms of
the five balancing criteria (long-term effectiveness and
permanence, reduction in toxicity, mobility and volume achieved
through treatment, short-term effectiveness, implementability, and
cost), and also considering the statutory preference for treatment
as a principal element and considering State and community
acceptance (modifying criteria).
Once the alternatives satisfied the threshold criteria, the key
criteria used in remedy selection were short-term effectiveness,
implementability, and costs. Alternatives 4 and 5 require the
longest time for groundwater remediation to cleanup goals because
they do not address groundwater contamination at the sources thus
delaying contaminant removal until it has moved downgradient.
Alternatives 5 and 7, which include soil incinera~ion, are much
more costly than the Alternatives 4, 6, and 8, without providing
any additional protection. Alternative 8 proposed a technology
that is untested for treatment of the contaminants found at the
site.
~he State of Michigan concurs with the selected remedy. The
community supports portions of the remedy and has submitted
comments regarding the proposed action which are included in the
responsiveness summary attached to this ROD.
Since A~ternative 6 utilizes permanent treatment technologies for
remediation of both groundwater and soils and will require
destruction of contaminants during treatment, and because it ~s
less costly than incineration and is a proven technology previously
used at this site, it is considered to provide the best balance of
trade-offs with respect to the nine criteria and represents the
maximum extent to which permanent solutions and treatment are
practicable.
E. ~eference for Treatment as a princinal Element
The selected remedy satisfies the statutory preference for
treatment as a principal element. The principal threat to human
health is from the soils at the source areas. The remedy will
treat the soils as well as groundwater, which is a primary pathway
of exposure. Since Al ternati ve 6 utilizes permanent treatment
technologies for remediation of both groundwater and soils and will
require destruction of contaminants during treatment the preference
for treatment is satisfied.
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45
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Verona Well Field site was released for
public comment in, February 1991. In the Proposed Plan, u.S. EPA
identified Alternative 2 as an alternative to implement an
additional line of blocking wells at the southern boundary of the
well field. The objectives of the new blocking wells were to
provide protection from contaminant migration to the production
wells on the west side of the Battle Creek River in Bailey Park,
provide additional protection to the main well field east of the
river, and to restore the portion of the well field between the
existing blocking wells and the new blocking wells.
During the public comment period, several comments expressed
concern about the proposed locations of the new wells. Members of
the community in which three of the wells were to be located,
expressed strong objections to the placement of the wells there.'
In addition, consultants for Grand Trunk and a citizen of the
community expressed concern over the potential for contaminants to
be drawn further into the residential area due to the placement. of
the extraction wells. Consul tants for Grand Trunk were. also
concerned about the overall effectiveness of the extraction wells
based on their placement so far downgradient from the sources and
proposed that wells be placed in the axes of the plumes. This
would allow for removal of contaminants closer to the source where
concentrations are higher. .
Based on these concerns and the alternate proposals received, u.s.
EPA has modified Alternative 2. Alternative. 2 now entails
placement of downgradient purge wells to address protection of
Bailey Park and the main well field, and to restore groundwater in
the well field south of the existing blocking wells. Placement of
the extraction wells will be determined during the design of the
remedial action based on meeting these objectives, but will also be
based on the concerns expressed during the public comment period.
The decision on optimum placement of the wells, to be made by U.S.
EPA in consultation with the State, will be aided by the use of
groundwater modeling during the design. Considerations will
include the relocation of wells originally planned for the
residential area southwest of the well field, and the placement of
one or more purge wells in the area of highest contamination
concentration downgradient of the Annex (the selected remedy also
calls for additional extraction wells downgradient of the Raymond
Road fa~ili ty) .
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ATTACHMENT I
RESPONSIVENESS SUMMARY
VERONA WELL FIELD
BATTLE CREEK, MICHIGAN
Introduction
The United States Environmental Protection Agency (U.S. EPA) and
'the Michigan Department of Natural Resources (MDNR) have completed
the final Remedial Investigation and Feasibility Study (RIfFS) at
the Verona Well Field Superfund site in Battle Creek, Michigan.
During the RIfFS, U.S. EPA and MDNR collected information on the
nature and extent of contamination at the source areas and well
field, evaluated alternatives for appropriate remedial action at
the source areas and well field, and proposed a final remedial
action for the entire site. Throughout the investigation process
at the site, U. S. EPA and MDNR have held several meetings and
availability sessions to discuss site progress and receive comments
and questions from the public. At the conclusion of the FS, U.S.
EPA and MDNR finalized a proposed plan for the final remedy which
identified the recommended alternative for remedial action at the
site. U.S. EPA offered a 99-day public comment period on the FS
and proposed plan from February 15, 1991 to May 24, 1991. At a
public meeting on March 12, 1991, U.S. EPA presented its proposed
plan and accepted public comments on the proposal.
.
The RIfFS has been undertaken under the authority of the
Comprehensi ve Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended, and the National Contingency Plan
(NCP), as amended. Under CERCLA, comments received from the public
are considered in U.S. EPA's selection of the remedial action for
each site. This document summarizes comments received during the
public comment period and indicates how the comments were
considered in the selection of the remedial action for the Verona
Well Field site.
The responsiveness summary has three sections:
I
I. OVerview. This section briefly outlines the U.S. EPA's proposed
plan for remediation at the site.
II. Communitv 'Involvement. This section provides a brief history
of community interest and concerns raised during remedial planning
activities at the site.
III. Summarv of Public Comments Received Durine Public Comment
Period and u.S. EPA Res~onses. Comments received are organized by
persons submitting the comments and grouped by issue, and followed
by U.S. EPA responses to the comments.
The de~ailed transcript of the proposed plan public meeting and the
written comments are not included in the report. They are
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2
available for public inspection in the administrative record
located in the public repository at the Willard Library in Battle
Creek, Michigan.
I. Overview
On February 15, 1991, U.S.EPA made available to the pUblic for
review "and comment the FS report and u.s. EPA's proposed plan for
remedial action at the Verona Well Field site. The proposed plan
presents 8 alternatives evaluated for remediation of the site and
U.S. EPA's preferred alternative which entails:
Continued operation of the existing blocking wells and air
stripper in the Verona Well Field;
- Installation and operation of
downgradient of the source areas,
for the extracted groundwater;
additional purge wells
and groundwater treatment
- Collection and treatment of contaminated groundwater at the
Thomas Solvent Annex and Grand Trunk Marsha~ling Paint Shop
source areas;
- Installation and operation of soil vapor extraction systems
for remediation of contaminated soil~ at the Annex and Paint
Shop sources areas; and
- Continued operation and maintenance of the groundwater
extraction system at Thomas Solvent Raymond Road, including
installation of additional extraction wells;
- Installation of a treatment system for extracted groundwater
at the Thomas Solvent Raymond Road source area; and
- Implementatiop of groundwater, soil, surface water discharge,
and air monitoring programs to monitor the treatment systems.
u.S. EPA received several comments from the public at the public
meeting in Battle Creek, and received several additional written
comments from the public, local governments, State Agencies and the
potentially responsible parties (PRPs).
II.
Communitv Involvement
communi:y interest in the problems at the Verona Well Field site
has been very intense at certain periods during the progression of
activities at the site. The community has expressed concerns over
exposures to residents from private wells and the need for a clean
water supply. U. S. EPA and MDNR have held several meetings and
maintained frequent communication with the community, local
-------
3
officials, and members of the State Legislature and U.S. Congress
to resolve issues and discuss concerns. Fact sheets Were prepared
hy MDNR periodically to keep the community updated on site
progress. A total of 20 progress reports were issued hetween 1983
and 1987.
In November 1983, U.S. EPA held a kickoff meeting to discuss the RI
work to be performed. A pUblic comment period was held on the
focused feasibility study (FFS) for remedial measures at the well
field hetween March 29, 1984 and April 12, 1984. Copies of the FFS
Were made available to the pUblic at the start of the comment
period. A public meeting was conducted on April 5, 1984, and
public comments received throughout the comment period were
evaluated hefore finalization of the ROD in May 1984.
Following completion of the phased feasibility study (PFS) for
remediation at the TSRR facility, U.S. EPA published the document
and began a public comment period that ran from June 17, 1985
through July 20, 1985. A pUblic meeting was held to present
results of the PFS and to solicit pUblic comments. After
consideration of pUblic comments, the ROD was finalized in Auqust
1985.
During the period from 1987 through 1990, U.S. EPA and MDNR held
three separate availability sessions to discuss progress regarding
the ongoing remedial actions at the site.
In November 1990, the community applied for a Technical Assistance
Grant (TAG) to hire a technical assistant to help them review site
documents prepared for the final remedial action. The TAG was
aw~rded to the community in December 1990.
The final RI report was released to the public in August 1990. The
public comment draft of the FS for the final remedy and the
proposed plan (PP), for site cleanup were released February 15,
1991. This signaled the start of a 60-day public comment period.
A pUblic meeting was held on March 12, 1991 to present the findings
of the FS and to accept comments on the FS and PP. The pUblic
comment period was scheduled to close April 15, 1991. However,
U.S. EPA extended the public comment period to May 24, 1991 as a
result of an extension request by one of the PRPs.
III. Summar of Comments Received
U.S. EPA's ResDonses
The public comments regarding the Verona
organized into two categories:
Well
Field
site
are
- Summary of comments from the community, local governments, and
State agencies; and
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4
,
.,
- SUmmary of comments from PRPs plan.
Many of the comments submitted were paraphrased in order to
ef.fectively summarize them in this document. . Also, a number of
comments were submitted during the public comment period that are
not relevant to the selection of the remedy and are not significant
ccmmaents, criticisms, or new data regarding the proposed plan.
.Therefore, in accordance with Section 117(b) of CERCLA, it is not
appropriate to respond to such comments in this responsiveness
summAry. Such comments will be included in the aclministrati ve
record for the site.
Summ~rv of Communi tv. Local Government. and State Aaencies Comments
Comments were received from the community and several local
governments orally during the public meeting and in writing during
the remainder of the public comment period.
.
Several comments expressed concern about the proposed
locations of the new purge wells and asked that the wells
not be placed in the residential area southwest of the
well field. In addition, many citizens asked that plans
for the additional wells and piping take into
consideration the residents and their properties.
,
Based on these concerns and others, U.S. EPA has modified the
proposed plan. The selected r.emedy ensures that no purge
wells will be placed on residential properties. However,
there may be a need to place at least one well on the
per meter of the residential area either in the vicinity of
Emmett and Brigden Roads (along the railroad tracks) or
adjacent to the river. The final locations of the wells will
be determined during the remedial design. U.S. EPA will make
every effort to avoid locating pipes and digging trenches in
the residential neighborhood. Consideration will be given to
the residents when planning and implementing the remedy;
however,. there may be the possibility of acti vi ty along the
perimeter of the residential area depending on where the purge
wells are located.
.
Two comments were made with regard to the location of the
additional air strippers called for in the proposed
remedy. One comment indicated that Michigan Law
prohibi ts the placement of treatment facilities wi thin
2,000 feet of a municipal well.
Michigan's Hazardous Waste Management Act 64 requires that new
waste treatment facilities be located a minimum of 2,000 feet
from a municipal well. For the siting of an air stripper,
this portion of Act 64 would not be relevant and appropriate
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5
for the reason that the purpose of this remedial actioni$ to
remedy an already contaminated water supply. U.S. EPA is
unclear as to why there would be oPposition to placement of
this additional air stripper at the well field. The cited
portion of A~t 64 is meant to restrict contamination of clean
water supplies by preventing the handling of waste in the
proximi ty of municipal wells. However, in this case, the
restrictions on siting new facilities would not be relevant or
appropriate because the treatment system may be placed at the
well field to remedy an already contaminated water supply.
The final locations for the air strippers have not yet been
determined, and it is not certain whether any of the strippers
will be located within 2,000 feet of the municipal wells. The
specific locations of the strippers will be determined during
. the remedial design. .
.
One comment asked where the piping for the downgradient
purge wells will be located.
Because the exact location of the purge wells has not been
determined at this time, the locations of piping for the wells
have also not been determined. This information will be
determined during the design.
.
Several comments were received from the community, local
governments, and the Michigan Department of PUblic Health
(MDPH) regarding U.S. EPA's proposal to use treated water
from the existing blocking wells in the City's water
supply. Three comments were in support of using the
treated water; however, one of the comments suggested
that we include aqueous phase carbon treatment following
air stripping to "polish" the water, and another of the
comments' asked that adequate sampling be conducte~ to
ensure quality. The City of Battle Creek and other local
government bodies expressed opposition to use of the
water in the City's distribution system.
As -discussed at the public meeting, u. s. EPA believes that
groundwater is a very valuable resource and should be
preserved rather than wasted, if there is a means of using it.
The proposal to reuse the treated water is based on this
ideology. However, the City of Battle Creek is not willing to
e.ccept the tr~ated water for its water supply, and thus U.S.
EPA cannot go forward with this plan at this time.
One citizen commented that the proposal to place
extraction wells in the residential area would result in
pulling the contaminant plumes farther into this area.
U.S. EPA acknowledges this concern and, based on this as well
.
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6
as other concerns, has determined that purge wells will not be
located in the residential area downgradient of the Annex
facility (see response to Issue 1B below). .
One comment stated that the neighborhood south of Raymond
Road and the Raymond Road Landfill is not addressed in
the FS even though contamina~ion was found in this area.
U~S. EPA acknowledges that low levels of contaminants have
been found in monitoring wells downgradient of the Raymond
Road landfill. However, it has been determined that the
contaminants migrating from the landfill are not c~ntributing
to the contamination of the Verona Well Field. For f\:rther
discussion see response to Issue 5 below.
.
. .
One comment stated that the risk assessment is faulty due
to its narrow view of what the chemicals of concern are
on the site. The comment also stated that by not
including the landfill and ignoring heavy metals the
risks at the site are understated.
The Risk Assessment conducted for this site initially
considered all 73 compounds detected during RI sampling. This
list was reduced to 48 chemicals of potential concern based on
frequency of detection (compounds detected in less than
5 percent of the samples were eliminated) and availability of
toxicity information (compounds were eliminated if no toxicity
information was available). The 48 chemicals of potential
concern include volatile and semivolatile compounds and
metals. The risk numbers presented in the risk assessment
include the risks from all 48 chemicals of potential concern.
The calculations of risk are presented in Appendix B of the RI
Report.
The Raymond Road la~dfill is not currently affecting the
Verona Well. Field and is being addressed under a sep~rate
State action (see response to Issue 5 below).
One comment asked why the public doesn't have input into
developing alternatives. The comment further questioned
U. S.. EPA' s hiring practices for contractors and stated
that u.s. EPA's contractor seemed to be making the
decisions regarding planning and cleanup for the site.
u. S. EPA hires contractors with expertise in the field of
hazardous waste investigations and remediation. u.s. EPA does
not feel it would be prudent to allow members of the public
without this expertise to perform this type of work. u.s.
EPA's contractor, CH2M Hill, was hired following the Federal
Acquisition Regulation (FAR) which specifies the requirements
for the acquisition of architect-engineer services. u.s. EPA
has been satisfied with the. work that has been performed at
.
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7
this si te by CH2M Hill and has retained CH2M Hill as a
contractor in the Superfund program based largely on. its
overall performance. However, CH2M Hill is not respons~ble
for making decisions concerning investigation and cleanup at
this site or any site and has not made those decisions at this
site. That. is and has been the responsibility of the U.S.
EPA. Furthermore, the FAR requires that periodic audits be
performed by the Office of Inspector General of U.S. EPA and a
final audit at completion of the contract by the General
Accounting Office (GAO).
One comment suggested that bioremediation be considered
due to its potential to expedite cleanup even though it
costs slightly more.
U.S. EPA considered bioremediation for removal of contaminants
at the Annex as a means of expediting cleanup of grounduateri
however, bioremediation has not been shown to be effective in
breaking down many of the contaminants found at this site (see
response to Issue 7 below).
.
One comment asked why it has taken so long to begin
cleanup of the site.
The process for studying and cleaning up a Superfund site is
very lengthy and requires several years to complete. However,
at the Verona Well Field site, U.S. EPA and the State have
taken several actions to protect the well field and the
residents, including implementation of the blocking well
system, hookups to City water for affected homes, temporary
bottled water to affectpd residents, and the start of cleanup
of the most severely contaminated source area.
.
A comment expressed concern regarding the saf ety
practic~s of the contractors working at the Raymond Road
facility and questioned whether such practices are
endangering workers and the community.
U.S. EPA is not aware of any unsafe practices by its
contractors at the Raymond Road facility. Each of the
contractors is required to follow a safety plan that
identifieb risks from site contaminants and other hazards, and
air sampling is conducted to ensure that no offsite releases
occur during onsite activities. A copy of the safety plan and
work plan for the work being conducted presently has been put
in the site repository at the Willard Library in Battle Creek.
.
.
A petition was submi tted with several signatures that
asked for relief from payment of monthly water bills by
the homes that were hooked up to city water due to
private well contamination and suggested that U.S. EPA
apply monies recovered from the responsible parties to
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8
pay for the residents' water bills.
Under the Superfund program, U.S. EPA is charged with cleaning
up hazardous waste sites and protecting people from exposure
to dangerous chemicals released from these sites. Whenever
p~ivate wells are threatened or contaminated, U.S. EPA looks
to State and local governments for assistance in providing
safe drinking water. In the case of the Verona Well Field,
the City of Battle Creek has provided drinking water to
residents under provisions of Michigan's Environmental
Response Act 307. Unfortunately, Act 307 does not p~ovide for
payment of water bills for affected residents.
Money that has been recovered by U.S. EPA is for costs
incurred for. response activities to study the site, protect
the well field, and begin cleanup at the Thomas Solvent
Raymond Road facility. Under the Superfund law, monies
recovered from responsible parties at Superfund sites must be
put back into the general funding for use at other Superfund
sites.
.
One comment stated the U.S. EPA was in violation
CERCLA requirement that ATSDR (Agency for
Substances and Disease Registry) perform a
assessment at the Verona Well Field site.
of the
Toxic
health
It is true that CERCLA requires that all Superfund sites have
a health assessment completed. However, the preliminary
health assessment is used to determine whether there are
health risks caused from site contaminants and to determine if
further followup health activities are indicated. For Verona
Well Field, a health study has already been completed by MDPH
through a cooperative agreement with ATSDR. ATSDR has also
actively reviewed site documents for this site since 1983, and
has tasked MDPH to perform an updated health assessment bFsed
on the most current data reported by U.S. EPA.
One comment expressed concern over lack of detail in the
FS and stated that it made it difficult to comment on the
I FS and proposed plan.
The FS is not intended. to be a design, but an engineering
study to determine the feasibility of implementing various
alternatives to clean up the site. What U.S., EPA is asking is
that the publ.ic submit comments on the concept involved for
the various alternatives.
.
.
A comment was received that said that the risk assessment
is faulty because it states that the plume is not
draining into the river.
Water level measurements collected as part of the remedial
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9
investigation (RI) showed that above (north) the Emmett Street
dam, groundwater levels are generally lower than the level of
the river and the river is recharging the groundwater. Below
the dam (south), the opposite is true, and shallow groundwater
discharges into the river. Monitoring wells located south of
the dam were 'sampled as part of the RI and showed little or no
contamination. There is currently no evidence that shows that
any of the contaminant plumes are discharging into the river.
One comment asked for the reason that data collected
before 1989 were not included in the RI report.
Analytical data from the Verona Well Field site are available
from sampling events conducted in 1982 to the present.
However, analytical methods, detection limits, sample
collection, and custody procedures have changed since 1982,
I and consequently more current data are assumed to have greater
accuracy. In addition, the conditions at the site have
changed considerably over the 9 years it has been studied. In
order to generate more accurate, up-to-date, and defensible
data, it was decided not to use any of the pre-RI (data
collected before 1988) for any quantitative purpose in the RI
or Risk Assessment. Data from before 1988 were used in
qualitative analyses, like the selection of sample locations
and for the tracking of plume movement.
.
Two comments questioned why the FS only addresses 12
chemicals when the RI identified 48 chemicals in need of
cleanup from over 70 found at the site.
The FS presents cleanup objectives for 18 chemicals found in
the groundwater and 12 chemicals detected in the soil at the
site. Although 48 chemicals of potential concern were found,
indicator chemicals are identified based on frequency of
detection and level of detection. These are the primary
compounds, with the exception of arsenic, found during the
Risk Assessment to present individual risks greater than a one
in one million increased carcinogenic risk or a risk ratio of
greater than one. Arsenic occurs naturally in the groundwater
at this site and was not considered for remedial action.
.
.
Two comments asked why there is no allowance made for the
dangers of living over the plume in an area with porous,
sandy soils and high water tables.
Th~ exposure pathways evaluated for current and future
residents at the site included consumptive and nonconsumptive
uses of groundwater. The ingestion of contaminated
groundwater was the only exposure route quantified because it
, is generally more easily quantified and defensible than
inhalation risks. Risk estimates for' the residential
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10
ingestion pathway assume the consumption of 2 liters of
contaminated groundwater each day for 40 years. "1'his
assumption is more conservative and correspondingly more
protective than one for an inhalation pathway would have been.
.
One comment stated that the FS has a total disregard for
human life.
The FS addresses risks to human health identified during the
site Risk Assessment by setting cleanup objectives for soils
and groundwater at the site at levels of 10~ increased
carcinogenic risk and hazard index ratios of less than one.
Soils found at the source areas and all affected groundwater
are addressed through these cleanup objectives. These cleanup
"objectives and the exposure pathways they address were
developed in accordance with the NCP, Section 300.430.
Two comments claimed that the risk assessment is faulty
in that it does not include information from residential
soil sampling.
There is no indication that residential soils are or have been
contaminated due to the contamination identified at the Annex,
Thomas Solvent Raymond Road, or Paint Shop source areas.
Because the residential soils are not part of a plausible
exposure pathway, it did not make sense to evaluate them as
part of the risk assessment.
.
.
One comment noted
included in the FS.
that air monitoring costs were not
Air monitoring costs were only included for Alternatives 5 and
7 which involved excavation of the contaminated soils. If it
is determined that air moni toring is required during
implementation (for trenching, etc.) of other alternatives,
the cost estimates will be revised.
.
On~ community member
proposed alternative.
submitted
modifications
to
the
These mod,ifications have been considered and are addressed
under u.S. EPA's response to Issue 8 below.
Summarv of PRP Comments
The PRPs submitted several volumes of comments prepared by
technical consultants and attorneys retained by the PRPs. Three
different consultant/attorney "groups" representing Thomas Solvent
Company, Grand Trunk Western Railroad, and the seven Annex
defendants submitted comments. Comments are grouped into eight
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11
different. issues, with various concerns identified for each issue.
A summary of specific comments is included with each of the issues.
~he responses to the eight main is~ues include:
Response 1:
Response 2:
Response 3:
Response 4:
Response 5:
Response 6:
Response 7:
Response 8:
RESPONSE lA
The U. S. EPA ' s positions on the current and
future use of the Verona Well Field (Response
lA) and justification for additional blocking
wells (Response 1B)
The U.S. EPA's position on considering the site
for an Act 307 Type B cleanup
The U.S. EPA's approach
objectives at the site
The U.S. EPA's position on the feasibility of
the proposed plan ever meeting the required
cleanup criteria
to
setting
cleanup
The U. S. EPA ' s approach to other sources of
groundwater contamination around the well field
The U. S. EPA 's response to technical comments
regarding the groundwater modeling
The U. S. EPA' s response to specific comments
pertaining the development and analyses of
alternatives in the FS
The U.S. EPA's consideration of other proposed
alternatives.
u. S. EPA 's pos i tion regard ing the current and planned use of the
Verona Well Field.
~ne comment suggested that increased pumping at the
Verona Well Field after contamination was discovered has
exacerbated the extent of the groundwater plume.
The suggestion that increased pumping at the Verona Well Field
after contamination was discovered has exacerbated the extent
of the groundwater plume is not realistic in light cf the
situation at the Verona Well Field. U.S. EPA's responsibility
at Superfund sites is to protect human health and the
environment. In the case of the Verona Well Field, actions
were taken to stop contamination from entering the production
wells in the well field. This was accomplished by
implementing the blocking well system currently in operation
at the well field. U.S. EPA took action to protect the well
.
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12
field because it is the source of drinking water for the City
of Battle Creek, with a population of more than 35,000, and
implementing the blocking wells was determined to be the most
cost-effective alternative for providing a long-term source of
clean drinking water for the City. Without the blocking
wells, all of the City's production wells would have
eventually become contam~nated.
One comment stated that the selected remedy should
provide for additional capacity for the City for future
growth, and one comment stated that the selected remedy
should not provide for increased capacity due to recent
water demands from the cereal industry in Battle Creek.
The provision for additional capacity for the City to
accommodate future growth was not a consideration in
I developing and evaluating the alternatives for remedial
action. In fact, it is U.S. EPA's policy not to provide for
any future growth when designing remedial actions for
Superfund sites. It is U.S. EPA's position that any increase
in pumping, or other actions, in the well field by the City
that results in failure of the blocking wells to protect the
well field will be the responsibility of the City. This
includes any increased pumping to respond to increased water
demands from the cereal industry in Ba~tle Creek.
.0
One comment stated that restoring the well field to its
original size is not a stated objective of the FS.
Although restoring the well field to its original capacity was
not a stated objective in the FS, it is an objective of the FS
to restore the entire affected aquifer. Placing purge wells
at the southern boundary of the well field will result in
cleanup of the groundwater within their zone of influence in
an accelerated time period and will provide further protection
to the well field from the contaminant plumes.
.
.
One comment asked that
water from the current
instead of discharging
looked at by U.S. EPA.
the feasibility of using treated
blocking wells for potable uses
it to the Battle Creek River be
The feasibility of using treated water from the current
blocking wells for potable uses instead of discharging it to
the Battle Creek River has been evaluated by U.S. EPA and was
included as part of the proposed cleanup plan for public
I
comment. U.S. EPA feels that the use of the treated water
would be a beneficial use of the water and would preserve a
natural resource. However, the City of Battle Creek has made
, the decision not to accept the treated water for distribution
within its water supply. Without the consent of the City,
U.S. EPA cannot go forward with this plan. .
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13
'.
One comment stated that the City of Battle Creek has
considered the possibility of moving the well field
because of numerous sources of contamination incl'~ding
other sources than those addressed under Superfund.
The possibility of moving the well field because of numerous
sources of contamination including other sources than those
addressed under Superfund was not considered as part of the
FS. U.S. EPA has not been informed of consideration of any
such actions. If the City of Battle Creek were to move its
well field, the goals of the remedial action would need to be
reevaluated to determine whether the selected remedy is
appropriate in light of this change. .
RESPONSE 1-D
There were a number of comments questioning the need for new
blocking (purge) wells, given the U.S. EPA's position on current
and planned uses of the well field. As identified in the FS,
additional purge wells are needed to provide overall protection of
the western portion of the well field and more rapid and effective
restoration of the southern portion of the well field as well as
restoration of the downgradient plumes. The placement of the wells
in the FS report was done primarily for evaluation purposes. The
ROD provides for a degree of flexibility in well placement based on
guidelines for overall well field protection.
Specific comments are as,follows:
A number of comments questioned whether the screening of
remedial alternatives adequately considered either the
existing or a modified blocking well system.
In developing. the FS, three possibili ties were considered:
~etaining the existing blocking well network without
modification, modifying the existing blocking wells, and
construc~ing additional purge wells. The first was retained
as the no-action alternative. The other two alternatives were
then evaluated for implementability, effectiveness, and cost.
.
The implementability and cost of both alternatives were
considered to be about equal. The development of additional
purge wells was selected as Alternative 2, based on the
greater extent of overall protection they could provide the
Verona Well Field, and in particular the production wells in
Bailey Park, and the more rapid and effective restoration of
the aquifer in the area between the source areas and the well
field.
.
Several comments were received that stated there is no
evidence that the limited detection of chemicals in
-------
14
samples from behind the existing blocking wells repre-
sents a failure of the b~ocking system.
While it cannot be stated for certain that the periodic
detection of cis-l,2-DCE in Verona production wells V-1J and
V-J6 represents a failure of the blocking well system, the
locations of these wells and the corresponding concentrations
of cis-l,2-DCE in the nearby blocking wells V-22, V-24, V-25,
and V-26 indicate that the compound may be miqrating beyond
the existing blocking wells.
The detection of cis-l, 2-DCE at 7 ppb in well V-J6 in July
1988 can likely be attributed to the shutdown of the blocking
wells for J weeks due to a valve failure and the subsequent
flooding of the air stripping treatment system dry well.
It is also not plausible that other source areas are the
cause of the periodic contaminant breakthrough, since the
only known contaminant sources within the zone of
influence of the well field that were not addressed by
the FS are petroleum product UST (underground storage
tanks) sites that do not contain 1,2-DCE. However, it
has been speculated that the contaminants found are a
result of residual contamination from the previous
occurrence of the plumes extending farther into the well
field (prior to implementation of the blocking wells).
..
Several comments suggested that enhancing the existing
blocking well system would have resulted in the most
cost-effective remedial alternative.
Enhancements of the existing blocking well network was
considered during the initial development of the alternatives
as an alternative to the construction of additional blocking
wel~s. It ~as not carried further into the alternative
development process because the need to add additional wells
to . protect the Bailey Park production wells resulted' in
present worth cost estimates that were essentially equal for
the two options. In addition, adding any new wells to the
current system would require additional air stripper
capacity. Providing additional purge wells was selected for
inclusion in the FS because it provided greater overall
protection of the entire well field and more rapid and
effective restoration of the affected aquifer.
. '
One comment suggested that the reliance upon the existing
blocking well system as a no-action alternative, without
examining ways to upgrade the system, is inconsistent
with the NCP.
The NCP requires the development and evaluation of a range of
remedial alternatives, so that EPA can select an appropriate
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15
remedy for the site.
Section 300.430(e) (2) of the NCP states:
, "Alternatives shall be developed that protect human
heal th and. the environment by recycling waste or by
eliminating, reducing, and/or controlling risks posed through
each pathway by a site. The number and type of alternatives
to be analyzed shall be determined at each site, taking into
account the scope, characteristics, and complexity of the site
problem that is being addressed."
One of these alternatives is to be the no-action alternative
as described in Section JOO.430(e)(6) of the NCP:
"The no-action alternative, which may be no further
action if some removal or remedial action has
,already occurred at the site, shall be developed."
Upgrading the existing blocking wells was considered in the
initial scoping of alternatives, but was not carried forward
in the development of alternatives because it was judged to be
less effective at providing overall protection and restoration
of the well field. EPA finds no inconsistency with the NCP on
this point.
.
A comment
alternatives
well system.
was
were
received that questioned why the
not evaluated without the new purge
Alternative 2, as presented in the FS, focuses on the overall
protection of the Verona Well Field. Groundwater modeling
carried out as part of the FS showed enhancement of the
present blocking well network to be necessary in providing
overall protection to the well field. As a result of this
evaluation, it was decided that it was necessary to include
Alternative 2 with the remainder of the alternatives in order
to have alternatives that achieve protection.
A comment was received stating that the purported
justification for the new purge well, system is
contradicted by statements located elsewhere in the FS
that the existing blocking wells are already aChieving
cleanup objective 1A.
While the existing blocking well network appears to be
achieving Remedial Objective 1A in the northern portion of the
well field, groundwater modeling carried out in support of the
FS showed that contaminant breakthrough around the western
edge of the blocking well network is possible in the future,
given current pumping conditions. Given the potential for
breakthrough, additional purge wells are needed to provide
long-term effective protection to the northern and western
portions of the well field, and to restore the southern
.
-------
16
portion of the well field.
Two comments questioned the statement on paqe 5-12 of the
FS that with continued pumpinq of the Bailey Park wells,
contaminants from the Annex may miqrate around the
western edqe of the existinq b10ckinq well system.
Computer mode1inq of the well field and surroundinq area
showed that under existinq pumping conditions, the potential
exists for contaminants to migrate around the western edge of
the existinq blockinq well network and contaminate the Bailey
,Park wells, and possibly the main well field. This modelinq
. is presented in Appendix D of the FS.
.
A comment was received that questioned why the FS did not
consider increasinq the pumping rate of the existing
blocking wells.
The existing blocking wells are limited by the treatment
capacity in the present air stripping treatment system (2,000
qpm). While increasing the pumping rates in conjunction with
a new expanded treatment system could have been investiqated,
the existinq blocking well system still would not have been
able to ,protect the western portion of the well field from
possible contamination. Increasinq the extraction well
pumpinq rates also would not restore any more of the affected
aquifer. .
.
.
Two comments questioned how EPA could justify the
installation of a new blocking well system based on the
detection of 1,2-DCE in downgradient wells.
The justification for additional purge wells was not based on
the detection of 1,2-DCE in production wells V-13 and V-36,
but rather on'projections of future contaminant migration, the
results'of computer modeling of the site, and on the desire
for remediation of a greater portion of the affected aquifer
than is currently underqoinq remediation.
Modeling projections based' on current municipal pumping
conditions showed that compounds from the existing
contaminant plumes south of the well field could migrate
around the western edqe of the current blocking system.
Therefore, modifications to the blocking well system were
deemed necessary to adequately protect the city well
field.
In addition, while the existing blocking
protect the northern portion of the well
address the southern portion of the
remainder of the affected aquifer.
we~ls function to
field, they do not
well field or the
-------
17
Two comments were received statinq that the location. of
purqe wells in the Darlene/Kimball neiqhborhood may have
the effect of acceleratinq the movement of. tha
contaminant plume towards and beneath that neiqhborhood.
U~S. EPA has acknowledqed that this may indeed happen and as a
result of this concern (and others) has modified Alternative 2
in the ROD to specify that no new wells will De placed within
the boundaries of the neiqhborhood. Additional wells will
likely be installed to protect the Bailey Park I municipal
wells. Wells will also be installed in the area between the
neiqhborhood and the source areas to provide qreater
containment and treatment of the plumes as they leave the
source areas and more effective restoration of the affected
aquifer.
.
.
One comment suggested that a series of monitorinq wells
and a regular monitoring proqram be implemented to
provide an early warning of the initiation of
breakthrough of the existing blockinq wells.
An effective monitoring program for trackinq the miqration of
the contaminant plume is advantaqeous and necessary in
providing adequate well field protection. However, in the
case of the Bailey Park wells and the western portion of the
main well field, qroundwater monitorinq showed that
contaminants were close to the Battle Creek River in 1989.
Given the rapid movement of qroundwater in this aquifer
system, it would be unwise not to provide purqe wells to
protect Bailey Park now, and to monitor the effectiveness of
those wells.
.
One comment stated that Alternative 2 will face a qrE~ter
risk of breakthrough than the existinq blockinq wells due
to the higher concentrations of contaminants at the
location of the new purqe wells.
I
Despite the fact that they have been used as blocking wells
since 1984, the wells that make up the existinq blocking well
network were oriqinally designed, constructed, and operated as
potable water production wells. As production wells, they
were not spac~d as closely together or drilled as deeply as
blocking wells may have been. Consequently, althouqh the
concentrations of contaminants are likely to be greater at the
locations of the new wells, the new wells are expected to be
more effecti ve throuqh placement and construction than the
existinq wells at capturing the contaminant plumes.
The additional purqe wells as proposed in the ROD will capture
the majority of contaminants in the plumes migratinq from the
source areas, thereby restoring a qreater portion of the
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18
affected aquif~r and providing a qreater reduction in
contaminant volume and mass over a shorter period of time than
would be possible solely with the existing blocking wells.
The existing blocking well network, modified to protect Bailey
Park, will continue to capture contaminants downgradient of
the new purge wells.
USPONSE -2
Comments frequently suggested that the site should
considered for a Type B cleanup and that a Type C cleanup
applicable and realistic given the site conditions.
co~ents are addressed below.
not be
was more
Specific
.
Two comments suggested that the Type B standards are not
an ARAR because they are not promulgated as def ined in
Section 300.400(g) (4) of the NCP.
The Michigan Environmental Response Act 307 of 1982, as
amended (Act 307), is a promulgated State law that provides
for the identification and evaluation of contaminated sites
within the State. Accordingly, Act 307 is either applicable
or relevant and appropriate to the Verona Well Field site, and
the substantive portions of the Act 307 rules that apply to
site remediation (Parts 6 and 7) must be followed, in lieu of
a waiver, during the remedial action at this site.
According to Section 300.400(g) (4) of the NCP which describes
the applicability of state standards, a state standard must be
legally enforceable and of general applicability in order for
it to be considered an ARAR.
In order to be legally enforceable a state law must be i~sued
in accordance with state procedural requirements and contain
specific enforcement provisions or be otherwise enforceable
under state law. Act 307 rules, which are codified to M.A.C.
Rule 299.5101, have been issued in accordance with state
pro~edural requirements. Specific enforcement provisions for
Type B c:riterianave been established by using standardized
exposure assumptions. Type B cleanup criteria are based on
reduction of hazardous substance concentrations to an
~cceptable risk level (1. e., 1 x 10-6 for carcinogens). If
Type B criteria are less than the Method Detection Limits then
the Method Detection Limit is the cleanup goal. These
specific enforcement provisions parallel the U.S. EPA policy
to reach an acceptable risk of 1 x 10-6 individual excess
cancer risk in order to protect human health and the
environment.
General applicability, as referenced by the NCP, requires that
potential state ARARs be applicable to all remedial situations
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19
described in the requirement, not just CERCLA sites. Acti307
Type a cleanups have been applied across the State of Michigan
according to the criteria outlined in the Act 307 Rules.
Cleanup criteria applied to Type a sites are hazardous
substance concentrations that do not pose an unacceptable risk
on the basis of standardized assumptions and acceptable risk
levels. The risk factors follow those presented within the
11. S. EPA Risk Assessment Guidance for SUDer fund , December
1.989.
Three comments stated that other Superfund sites in
Michigan have been classified as Type C and therefore
there has been an inconsistent application of the type
cleanups in Michigan. One of the comments suggest that
this inconsistency is due to the practice of using the
latest toxicological data available at a site as a basis
for Type B cleanups.
As specified in Act 307, the application of Type A, a, or C
cleanup in the State of Michigan is made on a case-by-case
basis, considering the site-specific information. The Type B
cleanup objectives at the site are justified because of the
current and future use of the groundwater downgradient for
public and private water supply, the rate and direction of
groundwater movement, and the overall mobility and toxicit} of
the contaminants. The cleanup goals set under a Type a cleanup
will allow the aquifer to be returned to beneficial use by
achieving the risk-based standards consistent with the U.S.
EPA risk assessment and chemical specific ARARs. The U.S. EPA
finds no inconsistency in the application of cleanup goals by
the State of Michigan or in the application of cleanup goals
identified for this site.
.
.
Three comments stated that the MDNR never gave a Type C
cleanup due consideration at Verona.
The U.S EPA agrees with the State of Michigan that Type C
cleanup objectives are not appropriate for this site given the
current and future use of groundwater migrating from the
source arf3as. The u. s. EPA policy under the Safe Drinking
Water Act. (SDWA) is to restore groundwater resources to
beneficial use where practical. The target residual risk
under the SDWA is consistent with a Type a cleanup.
Type t criteria have been applied to sites where, due to the
nature and extent of contamination, the availability of
technologies for remediation of the contaminants, and the
location of the site and its surroundings, the use of
containment or institutional controls is the most appropriate
way to eliminate all the exposure pathways considering the
factors in Act 307 and the NCP.
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20
RESPONSE 3
A number of comments were received relating to the selection of
chemic.al-specific cleanup objectives. Specific comments are as
follows: .
..
Several comments' suggested that cleanup levels and
alternative performance standards were based on factors
that are not ARARs.
U.S. EPA does not base cleanup levels solely on ARARs. The
cleanup objectives presented in the FS are based on acceptable
human health~based risk levels, MCLs, MCLGs, and Michigan
Act 307 Cleanup Objectives in accordance with the NCP, Section
300.430(e) (2) (i). This approach is compatible with U.S. EPA's
policy. Michigan Act 307 rules are promulgated in the State
of Michigan and are considered ARARs at this site.' Rules
299.5709 and 299.5711 of Act 307 address compliance with
Type B cleanup criteria for groundwater and soils,
respectively.
.
A number of comments questioned the apparent absence of
institutional controls to prevent installation and use of
residential wells in the contaminated aquifer and to
prevent direct contact with contaminated soils. One
comment went on to say that U.S. EPA failed to adaquately
cosider institutional controls, which is contrary to
language in Section 300.430(a) (iii) of the NCP.
For groundwater, there are no laws available within the State
of Michigan to prevent the use of an existing well for
domestic water supply. Health advisories to warn citizens
against the use of an existing well are the strongest mecpure
available. Because there are currently wells in the
contaminated' aquifer, there is no means of controling their
use.
For' source area soils, section 300.430(a) (iii) of the NCP
prohibits the use of institutional controls in lieu of active
response measures:
"The use of institutional controls shall not substitute
for acti~e response measures (e.g., treatment and/or
containment of source material, restoration of ground
waters to their beneficial uses) as the sole remedy
unless such acti ve measures are determined not to be
practicable, based ~n the balancing of trade-offs among
al ternati ves that is conducted during the selection of
remedy."
Because the property on which the sites arc located is currently
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21
in private ownership, and because the contaminants in the soil
would continue to cause groundwater objectives to be exceeded, deed
restrictions were not considered to be effective. .
One comment suggested that a survey be conducted to
determine if there'are private well users. If there are
none, the groundwater pathway should be eliminated.
Risk assessment guidance does not allow for elimination of
specif ic pathways based on current use if the potential for
completion of the pathway in the future can not be guaranteed.
At the Verona Well Field site, there is no available mechanism
for the prevention of groundwater use within the residential
neighborhood, despite the availability of the municipal water
supply, and the insurance of health advisories.
.
.
A number of comments questioned why cleanup levels
corresponding to risks in the 1E-4 and 1E-S range we~e
not considered.
The NCP requires that the 10~ risk level be used for
determining remediation goals at sites with multiple
contaminants and exposure pathways
(NCP 300.430(e) (2) (i) (A) (2». Also, ,Michigan Act 307 rules,
ARARs for this site, require cleanup objectives corresponding
to 10~ risk levels for soils and groundwater at Type B sites
(See discussion vnder response No.2 for applicability of Type
B cleanup). For these reasons, only 10~ risk levels were
considered in setting the cleanup objectives for this site.
Three comments questioned why the groundwater cleanup
objectives for benzene, chloroform, 1,2-dichloroethane,
l,l-dichloroethane, cis-and trans-l,2-dichloroethene,
ethylb~nzene, tetrachloroethene, toluene,
trichloroethene, vinyl chloride,. and xylene are below
MCLs and/or MCLGs.
The NCP requires that cleanup objectives be protective of
human health and the environment by considering federal and
state ARARs and appropriate exposure pathway risk levels.
Cleanup objectives that are more stringent than ARARs may be
set when ARARs are not available, or are determined to be
insufficiently protective due to multiple contaminants and
multiple exposure pathways. Cleanup objectives for this site
cqnsider risk potential and Act 307 objectives as well as the
MCLs and MCLGs.
.
.
A number of comments stated that the cleanup
in the FS appear to be the result of a risk
that considers exposures and calculateQ risks
what is expected and associated with the site.
objectives
assessment
far beyond
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22
The cleanup obj ecti ves presented in the FS consider
contaminant exposure through groundwater and soil ingest'ion.
Given the presence of a contaminated groundwater plume beneath
a residential neighborhood, and the potential for excavations
at or near the sites due to their industrial nature, the
selected pathways are considered to be reasonable and
justifiable.
.
One comment questioned why there is no comparison between
the risk levels calculated by the risk assessment in the
RI and the risk levels associated with chemical-specific
ARARs listed in the FS.
The two documents in question have separate purposes. The
. risk assessment, completed as part of the si te ' s Rem.edial
Investigation, calculated the risk from several exposure
pathways at the site using chemical data obtained from the
si te. This was done to evaluate the need for additional
remedial action. The risk levels presented in the FS used the
same exposure pathways to identify the cleanup objectives for
the site. The risk levels used to calculate the cleanup
objective for the exposure pathways are a one in a million (10'
6) increased cancer risk for carcinogenic compounds and a
hazard index of less than one for noncarcinogenic compounds.
These levels are set by EPA to be protective of public health.
The cleanup goals are also based on chemical-specific ARARs
(i.e., MCLs, MCLGs, and Act 307). Cleanup goals were
determined based on the more restrictive of the two.
Two comments were received stating that the rationale for
the selection of cleanup goals for compounds that have
both carcinogenic and noncarcinogenic cleanup goals is
not apparent. One of these comments also stated that the
process for determining the average concentrations and
their significance is unclear.
For all compounds, the lowest (most. restrictive) of the
chemical-specific ARARs or the carcinogenic/noncarcinogenic
risk is designated as the cleanup objective. This is done to
ensure compliance with the ARARs and so that the alternative
is protective of human health. The chemical-specific ARARs
include carcinogenic and noncarcinogenic risk numbers, MCLs,
MCLGs, and Michigan Act 307 Type B cleanup numbers.
.
The average concentration presented in Chapter 3 of the FS is
provided solely for comparative purposes. The averages were
determined by summing the posi ti ve values for the samples
where the compounds were detected, and adding one half of the
detection limits for each sample where the compounds were not
detected. The total value was then divided by the number of
samples.
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23
Two comments asked why the potential for different risks
at different soil depths. was not evaluated. One of the
comments added that soils deeper than 2 feet below ground
surface,are normally not considered to pose a risk due to
ingestion.
As stated in the Remedial Investigation Report, the surface
soils (0 to 2 feet) at the Annex and Paint Shop sites are not
considered to be a health risk, primarily because of the
volatile nature of the contaminants and length of .time since
the site has been active. Should trenching be used, the
remainder of the vadose (unsaturated) zone would be treated as
one unit because of the relatively small size of the zone (10
to 12 feet). Risks due to ingestion, inhalation, and dermal
contact were evaluated in the Risk Assessment. Only the most
stringent of these, ingestion, was evaluated in the FS.
.
One comment asked why the risks associated with the
groundwater protection concentrations on page 3-7 are not
reported.
The soil cleanup objectives presented in FS Table 3-2,
page 3-7, under the heading of Groundwater Protection
correspond to the chemical concentrations in' a soil matrix
that would be expected to leach into the groundwater at
concentrations exceeding th~ 10~ excess lifetime carcinogenic
risk for groundwater based on ingestion. The actual risk
numbers for soil ingestion at these concentrations have not
been assessed.
.
One comment requested the reference for the document
where u.s. EPA has determined that the entire aquifer is
a compli~nce 'point, as stated in the FS on page B-5.
The' preamble to the NCP (55 FR Page 8753) discussed the
application of Section 300.430 (e)(2)(i)(A) which specifies
the standards for location of point of compliance 'for
groundwater cleanuo standards. For the purpose of the
Feasibility Study, it was assumed that the identified cleanup
objectives must be met in the entire aquifer in accordance
with ARARs relating to the potential use of the aquifer (MCLs,
MCLGs, and Michigan Act 307). The actual compliance
monitoring points for the selected remedy will be determi~ed
during remedial design.
.
.
One comment stated that remedial objectives lA and 1B are
not practical because water to the consumer must be below
the cleanup objectives but not necessarily all water in
the aquifer.
Where groundwater is or may be used directly for drinking
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24
o
water, MCLs and nonzero MCLGs are relevant and approp:,,:iate
remediation goals to be met in the groundwater itself. This
is the case at this site, given the locations of the
contaminant plumes, re~idential neighborhood, and city well
field. In -addition, .both EPA and the State of Michigan
(through Act 307) have identified the entire aquifer as the
compliance zone for groundwater remedial objectives.
.
One comment said that the FS is inconsistent with
Section 300.400(g) of the NCP because it does not
identify the health-based cleanup levels contained in
Proposed Corrective Action Regulations as potential ARARs
for soil remedial objectives at the site.
I
Proposed regulations like the one identified above are not
ARARs because they may change before being promulgated as
final rules. However, proposed rules may be considered as "to
be considered" criteria where they are useful in developing
remedial objectives. At this site, health, risks based on
ingestion exposure pathways, MCLs, MCLGs, and state ARARs
(Michigan Act 307) were used in setting cleanup obje~tives.
There is no inconsistency with Section 300.400(g) of the NCP.
One comment suggested that the remedial objectives in the
FS are quite basic, almost generic, because they do not
take advantage of available site-specific details.
The remedial objectives presented in the FS were developed
based upon site characteristics and site ARARs. Primary
considerations used in the development of the remedial
objectives were the locations and use of residential and
municipal groundwater wells, the lack of available regulations
to prohibit the use of contaminated residential wells, and the
state ARAR, Michigan Act 307, which through a Type B cleanup
objective seeks to return the site to beneficial use.
.
.
One of the comments stated that the FS objectives bar
consideration of soil containment because soil
containment does not reduce contamination.
Soil containment (capping) was considered in the FS
(pages 4-16 and 4-17), but not retained for alternative
development because capping would not prevent the further
mil;Jration of contaminants from the soil, particularly the
smear zone, to the groundwater. Soil containment is also
inconsistent with a Michigan Act 307 Type B remediation plan,
which seeks to return the site to beneficial use. Act 307 is
, a state ARAR for this site. Type B cleanup objectives have
been identified as appropriate for remediation of this site.
.
Two comments stated that the canc\!r risk cleanup goals
should be recalculated to take into consideration the
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25
updated EPA guidance on exposure factors contained in
OSWER Directive 9285.6-03, March 25, 1991.
The cleanup objectives contained in the Record of Decision
(ROD) have been revised to take into account the updated EPA
quidance on exposure factors as contained in OSWER
Directive 9285.6-03, March 25, 1991. Please refer to Tables
16 and 17 of the ROD.
.
One comment questioned the use
procedures to set soil cleanup goals
stated that soil cleanup criteria
actual leachate data.
of TCLP leachate
and a second comment
should be based on.
TCLP procedures were used to estimate soil concentrations for
the prevention of further groundwater contamination at the
si te. Because TCLP was developed by EPA to determine the
mobility of contaminants in liquid, solid, and multiphase
wastes, this is a valid estimating technique. The estimated
concentrations are likely conservative in that it is assumed
that 100 percent of the contaminant will leach into the
groundwater in 20 volumes of water. However, this assumption
may be close to the actual situation, given the sandy,
nonorganic nature of the site soils. TCLP is also used in the
Michigan Act 307 rules, an ARAR at this site, for setting soil
remediation goals. Under. Act 307, site-specific leaching
tests may be considered as the basis for demonstrating
achievement of soil cleanup goals.
One comment asked for the reason that data collected
prior to 1989 were not included in the RI report.
This comment was addressed above under Summary of Community
Comments.
.
One comment questioned the assumption made in the risk
as!iessment that contaminants will persist at the same
concentrations downgradient as at the exposure point,
since this does not take into consideration natural
degradation.
While it is likely that natural degradation will decrease the
concentrations of groundwater contaminants downgradient of the
source areas, there are currently no reliable methods for
determining the extent of degradation over a given time or
distance. Furthermore, some degradation products of chlo-
rinated VOCs are more toxic than the original contaminant.
Consequently, the conservative approach of assuming no
degradation was used in conducting the Ri,sk Assessment. It
. should be pointed out, however, that this assumption had no
bearing on the selecti~n of risk-related cleanup objectives in
the Feasibility Study.
.
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26
RBSPONSE ..
J
Issue 4 pertains to the feasibili ty of meeting. the soil and
groundwater cleanup objectives. The comments noted that in view of
the EPA's experience in remediation at Thomas Solvent Raymond Road,
and in view of other technical literature published by the U. S.
EPA, that the low cleanup objectives at the source areas may never
be achieved. Thus the cleanup objectives should be waived as an
ARAR. Related to this was the concern that cleanup goals were
placed below the U.S. EPA method detection limit for several VOCs.
.
Several comments stated that groundwater and soil cleanup
goals are too low and that current technologies can not
be expected to achieve the cleanup goals. Many comments
suggested that new, more attainable, cleanup goals be
established. One comment went on to say that groundwater
extraction at the source areas should not be required
because cleanup objectives could not be met, and one
comment questioned whether U.S. EPA's approach was
consistent with the NCP.
U.S. EPA acknowledges that research into groundwater pump and
treat remedies have suggested that, in certain instances, low
level cleanup goals cannot be achieved. Uncertainty in
meeting cleanup objectives is an insufficient reason for not
initiating groundwater extraction. At a minimum, implementing
groundwater extraction would remove most of the dissolved
contaminant mass at the source areas in a relatively short
period of time as has been the case at many other sites
documented by the U.S. EPA. Progress toward cleanup will be
evaluated after the groundwater extraction systems are
implemented and, if it is determined that cleanup objectives
cannot be achieved, consideration will be given to
establishing alternative concentration limits (ACLs).
However, until it is shown that the selected technologies' can
not achieve cleanup goals for this site, the remedy must be
designed to be protection of human health and the environment
and comply with ARARs. Since the stated cleanup goals are
based on protection and ARARs, U. S. EPA believes that this
approach to evaluating effectiveness of soil and groundwater
remediation is consistent with Section 300.430(e) of the NCP.
.
Several comments referred to the Thomas Solvent Raymond
Road remediation as an example of the failure of current
technologies to meet low-level cleanups.
The Performance Evaluation Report (U.S. EPAi April, 1991) for
the Thomas Solvent Raymond Road source area reviewed the
progress of the remediation to date. In that report, the U.S.
EPA noted that it could still take many years for the
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27
groundwater extraction system to meet the groundwater cleanup
goals. This observation is consistent with other studies of
groundwater extraction and treatment systems by the U.S. EPA
and others. However, the purpose of the Performance Report
was to find ways to enhance the groundwater collection system.
One of these ways may be through groundwater sparging. The
U. S. EPA is currently planning pilot testing of groundwater
sparging and other enhancements at the Raymond Road facility.
The - U. S. EPA notes that in areas where the saturated zone
soils were not directly contacted by NAPL, groundwater
extraction has been fairly effective in meeting the cleanup
objectives. Since the extent of NAPL observed at the Annex or
'Paint Shop is significantly less than what has been observed
. at the Raymond Road facility, it is possible that the
groundwater remediation will proceed more quickly at the Annex
and Paint Shop; and it is likely that groundwater remediation
will proceed more quickly in the plumes downgradient from the
sources where the contaminant concentrations are relatively
dilute. Furthermore, in the data from the most recent vadose
zone soil sampling effort (January, 1991), VOCs were not
detected at a 100 ppb detection limit. This indicates that
cleanup objectives may be already met for many of the VOCs
(e.g., toluene, xylene, ethy1benzene, 1,1,1-trich10roethane,
trans 1,2-dich10roethene) and that cleanup objectives for the
other VOCs may be met in the-near future. Thus, the U.S. EPA
feels that SVE will effectively achieve remediation of the
vadose zone soil to meet the soil cleanup objectives.
Several comments stated that groundwater and soil cleanup
goals are below the ~nalytical method detection limits.
In the case where a cleanup goal is below the method detection
limit for a 9iven compound, U.S. EPA will generally establish
the cleanup goal at the method detection limit. This method
has also been adapted by the MDNR under Act 307. However,
method -detection limits are based on the lowest acceptable
detection method available for a given chemical, not on
detection limits established by U.S. EPA for routine
analytical services - (RAS). Because method detection limits
vary considerably between laboratories, MDNR has compiled a
list of acceptable - method detection limits for several
compounds regulated under Act 307. In addition, the cleanup
goals in the ROD have been adjusted to reflect acceptable
method detection limits.
.
RESPONSE 5
.
Several comments were made pertaining to other sources of
groundwater containination within the zone of influence of
the Verona Well Field. There was a concern that the
-------
-.
28
other sources of contamination were not considered in the
evaluation of alternatives and alternative selection.
u.s. EPA identified and investigated several other potential
sources of contamination as part of the final phase of RI
work. These'other sources included the Raymond Road Landfill,
the Grand Trunk Roundhouse, and the Consumer Power property.
Soil samples collected at the Roundhouse and Consumer Power
properties did not show any indication that these areas are
contributing to the contamination in the Verona Well Field.
Monitoring wells were installed and groundwater samples were
collected in the vicinity of the Roundhouse and the Raymond
'Road Landfill. Sample results from the Roundhouse did not
indicate any. groundwater contamination downgradient of that
area. Results from the landfill indicated low levels of VOCs
are present downgradient of the landfill. However, there is
no indication that contaminants migrating from the landfill
are contributing to the contamination problem at the well
field. The contaminant plume detected downgradient of the
landfill appears to be within the zone of influence of the
well field but has not migrated more than a few hundred feet
. from the landfill.
Because the contamination has not affected the well field,
U.S. EPA' determined that the landfill was not contributing to
the contamination of the well field. The landfill is
considered to be a separate site and is eligible for ranking
as a potential Superfund site. The State also has a program
for site remediation under Michigan Act 307 that includes a
system for priority ranking of sites based on their actual or
potential impacts to human health and the environment. The
State has determined that the Raymond Road landfill will be
added to the State I s list of sites and undergo ranking to
determine its priority for remediation under Act 307.
u.s. EPA, MDNR, and the City of Battle Creek have identified
addi tional sources of contamination to the aquifer in the
vicinity of the well field that consist of petroleum compounds
r~leased to groundw~ter as a result of gasoline spills and
leaking underground tanks at gas stations in the vicinity of
the well field. Although these various sources may contribute
contamination to the well field in the future, petroleum
products are CERCLA exempt, and therefore cannot be addressed
under the Superfund program. The MDNR has agreed to address
these sites under the State Underground Storage Tank (UST)
program. Cleanup of the contamination at two of these sites
are already underway.
RESPONSE'
Several comments were received regarding the technical validity and
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29
accuracy of the groundwater modeling performed as part of the FS.
Specific comments are as follows:
One group of comments centered on the procurement of' the
model code (MODFLOW), modifications that were made to the
code, and the resulting accuracy of the code.
The U.S. EPA obtained its model code from the USGS with the
multi-aquifer well (MAW) package already incorporated into the
model code. It should be noted that the code qbtained is
public domain software, but had not yet been formally released
for distribution. The addition of the MAW package was
performed by Michael McDonald, one of the original authors of
the MODFLOW code, and has been thoroughly benchmarked by the
USGS. Documentation for the apportioning of flow rates is
available through the U.S. EPA.
..
In order to enable the use of this code on a personal
computer, the U. S. EPA added statements to the code that
enables it to open and close data files. Because of
alternative methods of performing this function on a mainframe
computer (on which the code was developed), these statements
were not included in the code received from the USGS. These
statements in no way affect how the data are read by the code,
or computations performed by the code. Once these statements
were added to the code, the code was compiled and benchmarked
against the MODFLOW code that was already publicly
distributed. Comparison of the output from these simulations
indicated differences in head values of less than 0.001 feet.
.
A comment was presented that relates to the relative
precision of the code executed on a personal computer as
opposed to a mainframe computer.
. i
Using the MOD FLOW code obtained from the USGS and the
constructed Verona Well Field model, the U.S. EPA has
benchmarked the precision of the code between a VAX 8650
mainframe and a personal computer. In these simulations, the
out;>ut head values indicated differences of less than 0.001
feet.
.
A comment was presented that questions the validity of
the wseed value used by the strongly. implicit solver
(SIP) package used as part of MODFLOW to solve the system
of equations, and suggests that the head values
calculated in the model may be in error as much as 2 feet
because of an invalid wseed.
When the U.S. EPA performed the small scale modeling of the
Verona Well Field area, a wseed value of 0.005 was used, with
a convergence criteria of 0..01 foot (i.e., when all head
values showed less than a 0.01 foot change between iterations,
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30
'-'
the simulation ended) for the final calibration and
verification. The U.S. EPA chose this wseed value by
modifying it between successive simulations, until the model
converged the quickest, was most stable, and produced the
smallest volumetric water budget discrepancy. The wseed value
chosen by the U.S. EPA is considered to have a slig~t
overshooting effect, which is normally desired for model
convergence. Using a larger wseed, the model will have an
undershooting effect, and converge at a slower rate. If the
wseed becomes to large, the model may converge to soon and the
head values may be either too high or too low (depending on
the direction of convergence), this effect will cause the
volumetric water budget (the tabulation water inflow and
outflow in the model, ideally zero) discrepancy to increase.
. The U.S. EPA has simulated the calibrated Verona model aver a
wide range of wseed values, including utilizing the capability
of the model to calculate its own wseed value. The results
are as follows, with the residual referring to the difference
between the calculated head using the specified wseed, and the
calibrated head values presented in the FS:
"
WSEED RESIDUAL % DISCREPANCY NO. OF
VALUE (ft) IN WATER BUDGET ITERATIONS.
0.0001 Model uns'table, would not converge
0.0005 < 0.01 0.65 32
0.005 as calibrated 0.88 42
0.01 < 0.1 1.58 62
0.05 < 0.2 1.97 62
0.10 < 0.4 2.59 64
model
calculated < 0.01 0.65 32
The results of this exercise clearly indicate that the use of
~ larger wseed in this instance causes discrepancy to increase
in the volumetric water budget of the model, as well as
increasing the time required for convergence, while decreasing
the accuracy of the model.
In addition to the above simulations, the U. S. EPA ran the
calibration simulation using the preconditioned conjugate
gradient (PCG) solver package for MOD FLOW (this package was
no't available during the Verona modeling, but is currently
publicly distributed). The PCG is a preferred solving tech-
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31
nique because the mathematics behind it are inherently Llore
stable, and it does not require the specification of a wseed
value, only the closure criteria (0.01). Output from this
simulation indicated a residual (as defined above) of less
than 0.1 foot, a volumetric water budget discrepancy of
0.49 percent, and conve~ged in 24 iterations.
Given the information presented above, the U.S. EPA believes
that the modeled potentiometric data presented in the FS are
precise to the ability of the model code and the models
calibration. The U.S. EPA does not believe that the solving
technique used during the simulations caused errors of up to 2
feet in the modeled head values.
',)
.
A comment was presented that questions the validity of
several cells within the small scale models upper layer
going dry during model simulations.
In two areas within the small scale model (the central portion
of the well field and the northeast corner of the study area),
cells in layer 1 tend to dry up during simulQtion. Layer 1 of
the model corresponds to the unconsolidated deposits that
overly the bedrock in this area. In these areas of this layer
the elevation of the bottom of the unconsolidated deposits is
above the measured potentiometric head elevations, and thus
cells pertaining to these areas in the model dry up. The
model simulates this effect accurately, as concluded by
comparing the paleotopographic map of the top of the bedrock
and a potentiometric map of the well field area.
.
A comment was presented that questions the reliability of
the MODPATH particle tracking that was performed in
conjunction with the groundwater flow modeling, and
suggests that some of the wells simulated may be acting
as weak sinks which may produce an optimistic capture
zone analysis.
To perform a particle-tracking analysis, MODPATH uses the
input and output data sets from the MODFLOW model. Input
consists of typical MODFLOW parameters such as the geometries
for the model, as well as horizontal and vertical hydraulic
conductivity values. In addition, MODPATH requires as input,
the output modeled head data for each layer of the model, as
~ell as a complete mass balance for each cell in the model.
The mass balance for each model cell contains a value of
inflow or outflow for each face of the cell, as well as flow
data for any internal sinks or sources within the cell. A weak
sink is defined as a sink that does remove all available water
. entering a cell (1. e., inflow into the cell is greater than
the specified discharge of the sink or, in this case, well).
During a MODPATH simulation,
there are three var iables or
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32
options that can affect the movement of a particle.
as follows:
These are
.>
a)
The specification of a porosity value for the
aquifer material.
The specification of artificial zones within
the model at which particles may be removed.
b)
,-
c)
The specification as to whether or not
particles are to be removed by a weak sink. If
particles are removed by a weak sink, the
simulation would be considered liberal; if they
are not, then the simulation would be
considered conservative.
During the MODPATH simulations performed by the U. S. EPA, a
value of 34 percent was used for the porosity of the aquifer
materials, and should be considered conservative in that when
used to calculate a groundwater velocity, the velocity would
tend to be slightly low. This porosity value is consistent
with the values used throughout the RIfFS.
While the option to use artificial zones to .remove particles
within the model can be invoked, the U.S. EPA used no such
zones during MODPATH simulations.
For all MODPATH simulations, the U.S. EPA opted not to allow
the model to remove particles from the model via the use of a
weak sink. This is irrelevant, however, since by examining
the mass balance data. for cells that include a sink, these
would be considered strong sinks.
When outlining the capture zones for the proposed wells I t.he
U. E. EPA used the particle-tracking output and the ground-
water flow model output, and believes that the capture zones
outlined compare favorably with both output data sets.
The' U.S. EPA would also like to note that they acknowledge the
limi tations to the MODFLOW and MODPATH modeling, that the
proposed area of the new purge wells, hydraulic conductivity
data is very sparse, and that prior to the installation of a
complete system, testing should be performed in this area to
obtain hydraulic conductivity values as well as the radius of
influence of such a well.
.
A comment was presented
the new blocking well
aquifer, and suggests
necessary.
that questions the depth to which
system would penetrate into the
that full penetration would be
The
installation
and
operation of
fully penetrating wells
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33
would have the effect of continually drawing the contamination
deeper into the aquifer. This is due to the higher
conductivity of the lower portion of the aquifer compared to
the upper portion of the aquifer. By operating a well that is
screened through both pQrtions of the aquifer, a much greater
vOlume of water will .be removed from the lower aquifer,
drawing contaminants downward. By installing the new blocking
wells at 50 to 70 percent penetration of the aquifer
(depending on location), it is believed that the wells will
capture the contamination without drawing it deeper into the
aquifer.
"
,.
A comment was presented suggesting that in the U.s. EPA
modeling logs, a verification run was performed on data
obtained in 1984, and there was a 5-foot head
discrepancy. Also, no axial well simulations were
performed.
The U. S. EPA performed no verification run using data from
1984. The verification run used data from 1989, and had an
average discrepancy in the Raymond Road ar'ea of 1.48 feet
(layer 1), 1.21 feet (layer 2) and 2.00 feet (layer 3).
The U.S. EPA never performed, nor suggested that any type of
"axial well" simulations were performed.
.
A comment was presented that suggested that the original
USGS model of the Verona well field could have been
executed on a 80386-based minicomputer.
It would have been possible to execute the USGS model on a
80386-based microcomputer, if the computer was capable of 32-
bit processing and had sufficient extended memory. Since all
parties invoived (i.e., the U.S. EPA ,and the USGS) did not
have these capabilities, it was determined to modify the
model t~ run on any microcomputer.
.
A comment was presented that questioned the justification
of reducing the precision of the USGS model to run on a
microcomputer, and suggested that the grid spacing of the
USGS model was superior to the U.S. EPA local model, and
that no modification was necessary.
The original USGS model was large and cumbersome to work with,
with a slow execution speed. The model grid had relatively
tight descretization in the area of the well field, but
expanded to 100 x 500 foot spacings in the area of Raymond
Road and the Annex. The model was developed to analyze the
I well field, but was insufficient to apply to the remediation
simulations at Raymond Road, the Annex, and the paint shop.
The U. S .
EPA modified the USGS model so that it executed
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34
faster, and would provide only boundary condition information,
to be input onto a small scale model that had a refined grid
(100 x 150 foot) spacing in the source areas.
,-
v
A comment was presented that suggested that the
modifications to the USGS model be verified by comparing
output from the model to that of the original model.
Since the modifications to the original USGS model were so.
extensive, the U.S. EPA believes that calibrating the modified
model to existing data to be more prudent. Results of this
calibration are presented in Appendix D of the FS.
.
"
A comment was received that suggests that the ut,ility
program "modrot" that was used to transform the USGS data
to the new model grid needs documentation and
verification to indicate whether or not it is properly
functioning.
Documentation and verification cannot always justify the
proper functioning of a utility program. The only method that
can insure the proper functioning of such a utility program is
to perform the transformation, then contour plot both sets of
data and check for any discrepancies. This procedure was
performed for all datasets from the USGS that were
transformed, then the corresponding output was reviewed by
both the U.S. EPA and the USGS to detect any discrepancies.
.
.
A cOJtlment presenteri suggests to present the sensitivity
analysis, the use of a separate contour map .for each
model layer, for each sensitivity run.
Including this level of documentation in the FS would
effectively triple the size of Appendix D, without providing
any significant information to the general reader. These
contour plots are part of the -U.S. EPA modeling logs, which
have been made available to interested parti,s.
A comment presented suggests that the magnitude
variation in the sensitivity analysis was too large.
During the sensi ti vi ty analysis, the model appeared to be
somewhat insensi ti ve to many of the input parameters. To
fully appraise the effect these parameters had on the model,
it was necessary to increase the range of variation typically
used during a sensitivity analysis.
.
of
.
A comment was presented indicating a discrepancy in
Appendix D. In one instance, reference is made to a
stream loss of :2 cfs measured by the USGS in the well
field area, while in other instances a value of 2.5 cfs
is used.
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35
A value of 2.5 cfs stream loss was measured by the USGS, and
the calibrated model simulated stream loss at 2.4 cfs.
.
A comment was presented that asks to define the term
"root mean square error."
The "root mean square error" is simply old terminology for the
term "standard deviation."
A comment was received that suggests tables, that list
calibration residuals for the calibration and
verification simulations be present in the FS.
These tables were compiled for model simulations, and were
made part of the u.s. EPA modeling logs. These logs have been
made available to interested parties.
.
.
A comment was presented that indicates a discrepancy
between a model data set and Table D-l (a list of wells
and corresponding pumping rates) of the FS. It appears
that two wells were presented in the data set for Grand
Trunk Western Railroad, where only one is present on
Table D-l. Also that a Bailey Park well listed in Table
D-l was not included in the dataset and that a well named
"Columbia" was in the dataset but not presented in Table
D-l.
Grand Trunk Western Railroad operates two wells in the area of
the Verona Well Field. In the regional model, since both
wells were located within the same cell of the model, their
discharge was combined and simulated as a single well
discharging 100 gpm. In the local scale model, these wells
were located in different cells, so they were each simulated
separately at'50 gpm each.
.
All Bailey Park wells, V-14, V-15,
both the data set and Table D-l.
and V-17 are present, in
The well named "Columbia" refers to the Columbia township
well that is within the boundaries of the regional model, but
outside the boundaries of the local model. It was
inadvertently left off Table D-l.
.
A comment was received that suggests that the particle-
tracking maps should be drawn indicating travel time and
the entry-exit point of each particle for each layer.
The drawing of such a map would become very confusing given
the number of particles used in the simulation. Instead, the
11. S. EPA opted to proj ect the 3 -D location of the particle
track onto a 2-D surface. In addition, an example of the
particle travel time analysis is presented in Figure D-26.
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36
"
A comment was received that suggests that the model was
calibrated poorly, especially in the area of the Annex,
and that there is a significant difference in flow
direction between the model and field data in the area of
the Annex.
Appendix D of the FS'states that the calibration process
(local scale model) achieved a standard deviation between
model output and measured field data of 1.72 feet (layer 1),
2.71 feet (layer 2), and 1.35 feet (layer 3). In addition, in
the area. of the Annex, the calibration process achieved a
standard deviation between model output and measured field
data of 0.39 foot (layer 1), 0.73 foot (layer 2), and 0.27
foot (layer 3). The U. S. EPA believes this calibration is
adequate for the intended use of the model.
.
In general, data interpreted manually or mechanically in the
form of a contoured potentiometric map lack the insight into
the hydrogeology (Le., effects from changes in geology or
hydraulic properties) that a model possesses when it
calculates the potentiometric head values within the model.
It is for this reason that the U.S. EPA refrains from
calibrating a model based on an interpreted flow direction.
The U.S. EPA calibrated the Verona model on collected
potentiometric data, and maintains the general tendencies seen
in this data. I.n the unconsolidated deposits in the area of
the Annex, the field data (for February and October, 1989)
indicate a north-northwest trend in the groundwater flow, the
same general trend is present in the flow directions observed
in the groundwater flow model output. in the sandstone
aquifer, field data indicate a flow direction from the Annex
area northwest, and the same trend is observed in the output
from the groundwater flow model. In addition, the axis of
contaminant plumes in both aquifers appears to have a
northwest to north-northwest trend.
RESPONSE 7
Several comments were also received pertaining to the specific
development and description of alternatives in the Public Comment
Feasibility Study. The comments are as follows:
. I
One comment stated that the FS falsely assumed that
expedited cleanup times is one of the nine criteria
listed in the NCP for consideration in evaluating
proposed remedies.
Section(e) (9) (iii) (E) (4) of the NCP requires that "time until
protection is achieved" be considered as one of the factors to
be assessed under short-term effectiveness; one of the nine
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37
criteria.
..
One co~ent inquired as to why the FS did not provide a
cost evaluation as part of the alternative screening
process. .
No cost evaluation was presented in the alternative screening
process because this FS did not screen the alternatives before
detailed analysis. Following screening of technologies, there
were a limited number of alternatives and U.S. EPA did not
believe additional screening would eliminate any of the
I alternatives. While alternative screening is often done in
fe~sibility studies, it is not required by the NCP or the
"Guidance for Conducting Remedial Investigation/Feasibili ty
Studies Under CERCLA," Interim Final, October, 1988. .
.
Various comments suggested the contaminant mass estimates
were either unrealistically high or too low.
The U.S. EPA acknowledges that contaminant ~ass estimates are
. often inaccurate and variable. It is also recognized that
there is a wide variability in the mass estimates using the
kriging method, particularly at the Annex. This variability
is due to one "hot spot" at SB-11. However, based on the
available data, the U.S. EPA feels that these estimates are a
fair prediction of the contaminant mass. Contrary to one
comment, the U.S~ EPA did not use the maximum contaminant mass
estimate for the Annex and so bias the alternative evaluation.
The maximum mass estimate at the Annex was 62,000 pounds
(Table A-1). The U. S. EPA used a modified average of 37,000
pounds in the development and evaluation of alternatives for
the Annex (Table A-2). The variability of the mass estimates
did not affect the selection of SVE for soil treatment at the
Annex or at the Paint Shop (The mass estimates did affect the
assumed. type of off-gas treatment, but not the need for off-
gas treatment). .
.
One comment suggested that there were other "hot spots"
of soil contamination around the Paint Shop.
Most of the contamination at the Paint Shop centers around the
drum pit. Hot spots of soil contamination may exist around
the paint shop, particularly around SB-27 as discussed in
Technical Memorandum No.4. It is possible that other hot
spots also exist around the paint shop where solvents may have
been spilled or disposed of. While this possibility may
indicate a need for further sampling before SVE design and
implementation, it does not affect the remedy selection or the
need to treat the known contaminated soil.
.
Two comments suggested that in situ bioremediation has
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38
"
potential for the site. One comment questioned if the
basis for estimating th~ duration of bioremediation had
been adequately presented in the FS.
The U. S. EPA agrees that in situ bioremediation may have
potential for the site. The FS included a detailed study of
the current feasibility of using in situ bioremediation for
chlorinated VOCs (Appendix H). The U.S. EPA has concluded
that currently in situ bioremediation for chlorinated VOCs has
not been sUfficiently demonstrated to warrant inclusion in the
proposed plan. It may be considered in the future as more
pilot studies are completed and more field data are presented
on its success in meeting low cleanup levels for chlorinated
VOCs.
c
In Appendix H, it was estimated that in situ bioremediation
could take 7 years to 5 years for the anaerobic phase and 2
years for the aerobic phase. As discussed in Appendix H (page
H-8), the length of anaerobic treatment was based on the half
life chlorinated VOCs observed in an anaerobic environment.
The length of aerobic treatment was based on the time needed
to deliver sufficient oxygen and methane to the microbes to
biodegrade the contaminant mass. Both of these times are only
estimates and would need to be revised after bench scale
testing of the bioremediation system.
.
Several comments were made pertaining to the i) need for
off-gas treatment for the SVE system ii) the
justification for the type of off-gas treatment selected
in the FS and iii) that catalytic oxidation is not a
proven technology for chlorinated VOCs.
The requirements of Michigan's Act 348 are presented in the FS
on page 3-14. Generally, compliance requires attainment of an
ex~ess cancer risk of 1 x lO~ for air emissions. In addition,
all new sources of VOCs must be treated with best available
control technology. Consequently, the FS assumed that off-gas
treatment would be required for the SVE systems and air
strippers. Catalytic oxidation was selected as the best off-
gas treatment for the Annex, and vapor phase carbon was
selected for off-gas treatment at the Paint Shop. As
discussed on page 5-32 and discussed further in Appendix G of
the FS, the basis for these selections was cost effectiveness
based on the estimated contaminant mass at each source area.
Catalytic oxidation was used effectively at Raymond Road
source area for off-gas treatment, and so the U.s. EPA
considers it to be a proven technology. The final treatment
process option will be determined during the remedial design.
.
One comment stated that incineration should not have been
developed into an alternative. Another felt that the
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39
time estimated to complete incineration was too short.
The comment also stated that offsite disposal of the
treated soil should have been discussed since it is not
clear that the treated (incinerated) soil could be
delisted.
Thermal treatment was carried forward as an alternative
because of its ability to meet soil remediation goals more
quickly than SVE. Ultimately, thermal treatment was not
included in the proposed plan because it was not cost-
effective or as implementable as SVE. The actual time needed
to complete incineration would depend on the type of thermal
. treatment process option selected and the size of the unit.
Commercial, mobile incinerators are available that could
. feasibly treat the soils in 7 months. The U.S. EPA feels this
is a reasonable assumption for the FS.
The FS did assume that treated soil could be delisted and
placed back onsi te. For the type of soil and nature of
contaminants, the U.S. EPA feels this is a valid assumption.
Meeting delisting criteria would have had to have been
demonstrated during bench scale and pilot testing had
incineration been selected for the proposed plan.
.
One comment stated tha,t pretreated (e.g., air stripped)
groundwater could be discharged to the POTW and this
option should be retained.
Assuming that air stripping is required for either discharge
to a POTW or to the Battle Creek River, the U.S. EPA did not
see any advantage, cost or otherwise, for discharging to the
POTW. Furthermore, the Battle Creek POTW did not want to
receive the ~roundwater.
.
One comment suggested that "passive flushing" should have
been considered as treatment under the no action
alternative since this has been considered at other
Superfund sites.
The U.S" EPA dces. not consider passive flushing a viable
alternative at this site. Passive flushing would not meet any
of the ARARs or the goals of the remediation in a timely
~anner. Furthermore, it may be less expensive to remove the
contaminants with SVE than to allow leaching into the
groundwater and removal through groundwater extraction, either
at the source areas or the well field. The U. S. EPA has
selected passive flushing at other Superfund sites, but does
not select passive soil flushing at sites where groundwater
ingestion is an exposure pathway.
.
Numerous comments were made
layout, and specification of
pertaining to the size,
the SVE and groundwater
-------
",
40
extraction systems.
Specific comments included that:
c
It is unclear if passive air injection (versus.
active air injection) is to be used for SVE at the
Annex.
- The SVE systems were oversized. Sizing should be
based on a 10-year operational period (instead of
2 to 5 years).
- A pilot test would not be needed.
- Spacing of the groundwater extraction wells was
too conservative.
- The optimum sequence for air stripping and
activated carbon was not correct.
- The effect of iron was not considered in the
groundwater treatment technologies.
In response to all these comments, the U. S. EPA notes that
final layout, sequencing, and sizing of technologies is to be
determined during the remedial design. The purpose of the FS
is to make reasonable estimates, evaluate alternatives on
those estimates, and to select the best al ternati ve.
. Groundwater pump tests, SVE pilot tests, and further' soil
sampling will all affect the final design of remedial
technologies. The following responses are also made to
particular comments.
First, the FS assumed the use of active (forced) air
injection. Passive air injection would be considered, but its
effectiveness would have to be demonstrated in a pilot test.
Second, the u.s. EPA doubts that a scaled down system
operating for a longer period of time is necessarily more cost
effective. Capital costs for SVE systems are relatively
inexpensive compared to the operational cost. Third, even
with the u.S. EPA's experience at Raymond Road, a pilot test
would still y.ield important information such as the initial
extraction rates of VOCs and the effectiveness of
passive/active air injection. Fourth, final spacing of the
groundwater extraction wells will be based on aquifer pump
tests at each of those locations. Fifth, the optimum sequence
of activated carbon and air stripping will be determined in
the" design phase. The sequencing suggested in the FS was
based on the assumption that the liquid phase carbon would
temporarily be placed in front of the air stripper to minimize
loading to the air stripper. This would enable its size to be
minimized. The U.S. EPA notes that the air stripper will need
vapor phase treatment (e.g., vapor phase carbon) and this must
be considered in the sequencing of the two technologies.
Sixth, the problem of iron precipitation on the operation on
an air stripper is acknowledged (page F-S). The high O&M
r.equirements presented by iron precipitation is one reason why
a S-year life of the air strippers was assumed. It has been
the U.S. EPA's experience that iron precipitation will add
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41
significant expense to the O&M of an air stripper. The U.S.
EPA agrees that, if the problem is severe, pretreatment of
iron and other metals may have to occur before air stripping.
Several comments questioned the methodoloqy used to
estimate influent concentrations for the groundwater
treatment systems at the source areas. One comment
inquired why there was a difference between the average
concentrations presented on Table 3-1 and th, influent
concentrations used in Appendix F. Another co~ent asked
why acetone, methylene chloride, chloroform, and
chlorobenzene were not considered in the design of the
air stripper.
The estimates of groundwater concentrations presented in
Appendix F of the FS were derived from the 1989 groundwater
data. These average concentrations allowed reasonable
estimates to be made for the size of the air strippers at the
various source areas. While it is acknowledged that the
actual concentrations observed during remediation at the
source areas may vary from those in the FS, the averages
provided a good basis for estimating design criteria.
.
The concentrations presented in Table 3-1 of the FS were taken
from the risk assessment which included concentrations of one
half the detection limit for samples where a compound was not
detected. Table 3-1 concentrations are presented solely for
comparative purposes. They are generally higher than those
concentrations presented in Appendix F which averaged only
detected compounds.
Acetone, methylene chloride, chloroform, and chlorobenzene
were not considered in the design criteria of the air stri~per
because they' were not detected at concentrations excet/ding
their cleanup objectives with any frequency. They are not
expected to require removal in the final air stripper design.
Because these compounds were detected in so few samples, the
ave~ages presented in Table 3-1 may be artificially hiqh for
the reasons stated above.
.
Some comments were made' on the locations of the air
strippers and one comment pointed out that air stripping
at the p,aint Shop could violate space' requirements for
the required area between a residence and a treatment
system.
The U.S. EPA does not consider the placement of air strippers
as shown in the FS to be final. The placement of air
strippers in theFS considered the economies of scale for
fewer air strippers and ease of operation. However, final
placement will be determined in the remedial design.
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42
.
Numerous comments were also made in regard to the cost
estimate. General comments varied from saying the
estimated costs were exorbitant to suggesting that the
costs were too low. Specific comments included:
~
- The assumed equipment lives were too short.
Why were two activated carbon systems included in the
Alternative 6 cost estimate and why does Alternative 5
include a line item for activated carbon at the source
extraction wells?
- Why were the present worth costs calculated with a 15.1
present worth multiplier?
- What activated carbon loading amounts were used in
estimating carbon usage?
- Why are the per foot costs of SVE well installation
more at the Paint Shop than the Annex?
- The cost estimate did not include air scrubbers for
treatment of HCL in the SVE offgas.
- Air monitoring costs were not consistent between Alts.
5 and 7.
It is difficult for the U.S. EPA to respond to general
comments saying the cost estimate was too high or too low.
The U.S. EPA feels that the estimated costs presented in the
FS are a fair and realistic .stimate, within the accuracy of
FS level cost estimates which have a required accuracy of +30,
~50 percent. Many of the estimated costs reflect actual costs
incurred with SVE and air stripping at the Raymond Road source
area and in the well field. One comment confirmed the basic
accuracy of the air stripping and SVE cost estimates with
independent cost estimates of these items. While the final
costs will certainly vary from these estimates, the estimates
were useful for the purpose of selecting an alternative that
was cost effective as well as protective of human health and
~he environment.
In responding to the specific comments, the U.S. EPA
acknowledges that much of the groundwater pumping and
treatment equipment may last more than 5 years. However, past
experienc~ has shown that iron precipitation will add
considerable expense to maintaining the well screens, pumps,
and air stripper. Thus the actual costs represented by
a.ssuming a 5-year life are realistic.
Second, an allowance for activated carbon should have been
included only once for Alternative 6 and not at all for
Al ternati ve 5. Nei ther of these would have a significant
effect on the cost estimates for the respective alternati~es.
Third, the present worth of the operation and maintenance
costs at a 5 percent interest rate was calculated with a 15.1
present worth factor instead of the 15.37 which is more
-------
43
commonly used. The U.S. EPA notes that the difference bet~een
th~se two present worth factors is less than 2 percent and is
inconsequential given the stated accuracy of a FS level cost
estimate.
Fourth, vapor phase carbon usage was estimated based on a 14
percent loading efficiency, which is the efficiency observed
during the remediation at the Raymond Road source area (see
page G-11). .
Fifth, the estimate per linear foot of well installation at
both source areas should have been 155 dollars per foot (not
540 dollars per foot at the Paint Shop as shown on Table I-6).
.
Sixth, in response to the need for scrubbers to remove HCL
from the off gas, the U.S. EPA notes that this potential was
discussed on page G-11. The U. S. EPA feels that scrubbers
would probably not be needed, so no allowance was included for
them in the cost estimate.
Seventh, air
alternatives.
moni toring costs should be $452,000
f or both
RESPONSE 8
Many comments were received that suggested other alternatives be
considered. These included:
No action (with. some monitoring and continued operation
of the blocking wells)
The U.S. EPA feels that implementing SVE would be more
protective of' human health and more cost effective than
allowing "passive flushing" to slowly leach the contaminants
into the groundwater where they. are more difficult and costly
to remove. SVE will likely meet the soil cleanup goals within
a few years. Most comments agreed on the need for soil
treatment, and the selection of SVE as the most effective soil
treatment technoloqy. Passive flushinq would not meet cleanup
goals, especially those specified under Act 307, for the
foreseeable future. The U.S. EPA did not select a no action
alternative for the soil because it is not protective of human
health, will not meet ARARs, and is not cost effective.
.
.
SVE at the source areas and modified blocking well system
(No groundwater extraction wells at the source areas)
, One comment suggested only SVE at the source areas
optimization of the existing blocking well system.
comment questioned the need for groundwater extraction
at the source areas because groundwater extraction may
and
The
wells
never
-------
44
meet the cleanup objectives and the pace of remediation is not
a sufficient reason to include source area groundwater
extraction. This comment is addressed under Response #lB.
(:
SVE at the source areas, groundwater collection at the
source -areas, modified blocking wells, and possibly
collection wells between the sources and the existing
blocking wells
Numerous alternative arrangements to the new purge wells were
proposed. These included mOdifying the existing blocking well
line, adding more monitoring wells near the Bailey Park wells,
and installing several new extraction wells downgradient from
the sources in an orientation parallel to the direction of the
plumes instead of perpendicular as proposed in the FS. The
U.S. EPA is most concerned with protection of the well field
and restoring the aquifer downgradient from the source areas.
Installation of additional purge wells is one way to achieve
these obj ecti ves. Other configurations of adcU tional
blocking/extraction wells will be considered by the U.S. EPA
during design phase. The U.S. EPA's position on alternative
purge wells is discussed more fully under Response #lB.
e.
-------
ATTACHMENT II
ST~Te OF MICHIGAN
...""''''' ....0UIICa co-.selON
IMIILfNf J _~UIo4A,"",
00110001' 01,1"'-
O. If&WAIIT IllYaIlS
RATYO~ -o..-oAE
{I
JOHN ENGLER. Gov..nor
DEPARTMENT OF NATURAL RESOURCES
mII'N' T. "II.SO'" I!JI..O'NG
. ~o. lOX *21
1oIoNS"'C: -"1 4uoe
DeLlfln' IIIfCTOIII. ~..
June 28, 1991
Mr. Valdas Adamkus, Regiona' Administrator
U.S. Environmental Protection Agency
Region 5. SRA-14
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Adamkus:
The Michigan D!partment of Natural Resources (MDNR), on behalf of the Stilte of
Michigan, has reviewQd t~e Record of Decision (ROD) for the Verona Well Field
Superfund site (Calhoun County) final remedial action, and the proposed remedy
contained in that ROD. The State concurs with the remedy proposed in th!! ROD
consisting of: 1.) groundwater extraction and treatment in conjunction with
soil vapor extraction and treatment at the Thomas Solvent Annp.x and the Grand
Trunk Western Railroad (GTWRR) paint shop, 2.) continued operation and
maintenance of the existing blocking wells and associated groundwater
treatment system, 3.) installation and operation and maintenance of an
additional set of blocking wells and associated groundwater treatment sy:;tem,
4.) continued operation and maintenance of the existing groundwater extraction
and treatment system and soil vapor extract ion ind treatment system at Thomas
Solvlnt Raymond Road, and S.) monitoring of the groundwater in the area. The
u1timate goa1 i$ to remedy all contaminated soil and groundwater such thiit it
meets all Applicabl. or Relevant and Appropriate Requirements (ARARs) and
cleanup objectives.
The State also generally concurs with the analysis of ARARs contained in
Appendix B of the public comment draft feasibility stu~y for this site d;lted
February 1991. However, the substant ive port ions of the Michigan Hazardl)us
Waste tlanagement Act, (1979 P.A. 64, as amended) shou1d be included IS an
ARAR. The State and the U.S. Environmental Protection Agency (EPA) have
agreed that the "portions of Act 64 that are more stringent than RCRA Suhtitle
C would be applicable for the Vlrona We" Field site" (Section XI, B, 3 c)f the
ROD). In addition, the State dOls not concur with the omission of the
Michigan Water Resources Commission Act (1929 P.A. 245, a~ amended), MCL
323.6(1) and the associated Part 22 Administrative Rules MAC R.323.2201
et.seo. from ApPlndix B of the Feasibility Study and from other referenc.!s.
The State has previously identified these requirements as ARARs for the
remedial action being selected for this site. The State still considers these
as ARARs.
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Hr. Valdas Adamkus
-2-
June 26. 199,1
.
It 15 the Department's judgement that the sele'ted remedial actions for t,1s
site wil' provide for attainment of a'1 State ARARs including the Hichiga,
Water Resources Commission Act and Part 22 Rules. The remedial action will
halt th~ migration of contaminated groundwater and eventually restore the
aquifer to a usable condition.
The State is concurring 1n the ROD with the understanding that Tables 16 and
17 in the ROO are being revised to incorporate all indicator compounds that
EPA and MOHR have agreed upon. Specially, we understand that carbon
tetrachloride and benzene wil' be added to the final list of soil indicator
compounds (Table 17 of the ROD). Finally, it is the State's understand in;
that III cleanup numbers for the remedy (both indicator compounds and the'
remaining identified compounds of concern) will be at least as stringent as
the Type B criteria for these compounds established pursuit to the Michigan
Act 307 Rules.
We are pleased to be partners with you in selecting this remedy and look
forw~rd to working togeth~r to accomplish the final remedy at this site.
~intereR I,
F~~ ?SWi~ II
Acting Deputy Director
517-373-7917
,c: Mr. Jonas Oikin1s, U.S. EPA
Ms. Susan Louisnathan, U.S. EPA
Ms. Margaret Guerriero. U.S. EPA
Mr. Robert Reichel, De~t. of Attorney General
Mr. Alan Howard, MDNR
Mr. Andrew Hogarth, MONR
Mr. Robelt Hayes, MOHR
Ms. Nar.ftte Leemon, MOHR
Mr. Wi11iam Bradford, MOHR
Mr. Brady Boyce, MOHR
Ms. Beth O'Brien, MDHR
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