United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EP AIRODIROS-91 /174
September 1991
Cry (
rt312- '1 ~~ /3 5
)
J
&EPA
Superfund
Record of Decision:
Thermo Chern, MI
U. So Environmental Protection Agenc~
Region III Hazardous Waste
Technical Information Center
841 Chestnut Street. 9th Floor
. PhiJadelphia, PA 19107 .
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
PhRodeiphla. PA 19107.
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50272.101
REPORT DOCUMENTATION \1. REPORTNO.
PAGE EPA/ROD/ROS-91/174
\ ~
3. Recipient's Ac:ceaaIon No.
4. l1t1e and Subtitle
SUPERFUND RECORD OF DECISION
Thermo Chern, MI
First Remedial Action
7. Author(s)
s. Report Date
09/30/91
6.
8. Perfonnlng Organization Rept. No.
9. Ferformlng Orgalnizatlon Name and Addreaa
10. ProjectfTuklWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
1 ~ Sponaoring Organization Name and Addre88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(G)
13. Type of Report & Period Covered
Agency
800/000
14.
1 S. Supplementary Notes
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16. Aba1rsct (Umit: 200 worels)
The 9.S-acre Thermo Chern site is comprised of an inactive solvent and chemical waste
reprocessing, refining, and incineration facility, and an inactive waste hauling
facility in Egelston Township, Muskegon County, Michigan. The area surrounding the
site consists of residential areas, light manufacturing and commercial buildings, and
undeveloped woodlands. The site is adjacent to two other Superfund sites: the SCA
Independent Landfill site, and the Bofors Nobel site, which are located approximately
1,800 feet south and 1.25 miles east of the site, respectively. Site features
include a warehouse, an incinerator, above-ground storage tanks, a laboratory, and
process buildings and associated lagoons. A trout stream, Black Creek, is located
approximately 1,500 feet south of the site and forms a broad and flat wetland. From
1969 to 1980, Thermo Chern received, distilled, and regenerated solvents, paint
wastes, and antifreeze into usable solvents. Unrecoverable materials and by-products
including sludge and residues were incinerated on site. The Thomas Solvent Company,
which lies adjacent to, and is owned by Thermo Chern, has been included as part of the
site because it is suspected to be a source of ground water contamination. The
Thomas Solvent Company was operated as a hazardous waste hauling facility for Thermo
(See Attached Page)
17. Document Analysis L Deacriplo/8
Record of Decision - Thermo Chern, MI
First Remedial Action
Contaminated Media: soil, sludge, gw
Key Contaminants: VOCs (benzene, toluene, xylenes), other
pesticides), metals (arsenic, chromium,
b. Identifier8JOpen-Ended Terms
inorganics
organics (PARs, PCBS,
lead) ,
Co COSAl1 AeId1Group
18. AvailabiHty Statement
19. Security Claaa (This Report)
None
20. SeclB'lty Claaa (This Page)
Nnn~
21. No. of Pages
93
I
~ Price
(See ANSI-Z39.18)
See IMITIIC/ions on Reverse
272 (4-77)
(Formerly N11S-35)
Department of Commerce
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EPA/ROD/R05-91/174
Thermo Chern, MI
First Remedial Action
Abstract (Continued)
v
Chern and collected waste for recycling and returned the material to customers.
Wastewater generated from the distillation and equipment-cleaning process at Thermo-Chern
was discharged onsite into a series of three interconnected lagoons. In addition,
approximately 3,500 drums containing raw and recycled materials were stored in an onsite
underground storage tank farm area during the years of operation. Former onsite
personnel indicated that sludge was occasionally buried onsite, and that onsite chemical
spills frequently occurred. In response to investigation activities during 1988 and
1991, EPA conducted an emergency removal of drums and materials containing hazardous
waste. Federal investigations in 1990 indicated that contaminant releases were one
source of ground water contamination. This Record of Decision (ROD) addresses the source
of contamination by remediation of soil, sludge, debris, and ground water up to the point
where ground water discharges into Black Creek as Operable Unit 1 (OU1). A future ROD
will address OU2, the contamination problems within Black Creek and ground water
contamination south of Black Creek. The primary contaminants of concern affecting the
soil, sludge, and ground water are VOCs including benzene, tolu~pe, and xylenes; other
organics including PARs, PCBs, and pesticides; metals including arsenic, chromium, and
lead; and other inorganics.
The selected remedial action for this site includes excavating, removing, and
incinerating offsite approximately 2,000 cubic yards of soil and sludge; treating and
disposing offsite any ash or residuals produced from offsite incineration; installing an
in-situ vapor extraction (ISVE) system and treating onsite approximately 9.5 acres of
remaining contaminated soil; conducting a treatability study to determine the feasibility
of enhancing the natural biodegradation of organic compounds in the soil undergoing ISVE
treatment; treating gases emitted from the extraction wells using a fume-rich
incinerator; treating liquid from the vapor extraction process onsite; covering the site
with clean soil and vegetation, if necessary; decontaminating, demolishing, and disposing
offsite all onsite buildings and structures; onsite pumping and treatment of ground water
using filtration, air stripping, metal precipitation, and pH adjustment, followed by
treating off-gases using carbon adsorption and onsite discharge of the treated ground
water to Black Creek; treating and disposing all residue, sludge, spent carbon, or spent
coagulants and flocculent at an offsite landfill; conducting additional treatability and
leachability tests to determine the need for further excavation and/or treatment; and
implementing institutional controls including land use restrictions. The estimated
present worth cost for this remedial action is $24,300,000, which includes an annual O&M
cost of $1,091,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Soil cleanup standards are based on State standards and
a carcinogenic risk level of 10-6. Ground water cleanup standards are based on State
standards. Chemical-specific goals for soil include benzene 10 mg/kg, toluene 2 mg/kg,
xylenes 1 mg/kg, PARs 0.2 mg/kg to 0.6 mg/kg, PCBs 1 mg/kg, pesticides 0.0000006 to
0.00005 mg/kg, arsenic 0.0004 mg/kg, chromium 0.04 mg/kg, lead 9 mg/kg, and inorganics
other than metals 0.08 mg/kg. Chemical-specific goals for ground water include
benzene 1 ug/l, toluene 100 ug/l, xylenes 59 ug/l, PAHs 10 ug/1 to 29 ug/l,
arsenic 0.02 ug/l, and inorganics other than metals 4 ug/l.
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TBEUO CHO SITE, XI
OPERABLE UNIT I
DECLARATION FOR THE RECORD OF DECISION
site Name and Location
Thermo Chem site, Operable unit I
Muskegon County, Michigan
Statement of Basis and Purpose
This decision document represents the selected remedial action for
the Thermo Chem site, in Muskegon County, Michigan, Operable Unit
I, which was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA) , as amended .by the Superfund.- Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent practicable,
the National Oil and Hazardous Substance Pollution Contingency Plan
(NCP). This decision document explains the factual and legal basis
for selecting the remedy for this site. .
The State of Michigan concurs with the selected remedy. The
information supporting this remedial action decision is contained
in the administrative record for this site. . . .
Assessment of the site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of Remedv
This operable unit is the first of two operable units for the site.
The selected remedial action for Operable Unit I addresses the
source of. contamination by remediation of soil, sludge and
groundwater up to the Black Creek. .
The major components of the selected remedy include:
*
Decontamination, demolition, and off-site disposal of all
on-site structures;
Excavation and off-site incineration of Group 1 and 2
soils;
.
*
*
In-situ Vapor Extraction for all site soils;
*
off-gas treatment through a fume-rich incinerator;
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* Extraction and treatment of the groundwater with subsequent
discharge to Black Creek; .
2
*
Installation and maintenance of a fence around the site
during remedial actiVities; and
....
*
ImPlementation of zoning and land USe restrictions during
the implementation of the remedy.
The fOllOWing component of the selected remedy will be evaluated
during the imPlementation of in-Situ Vapor Ektraction.
'It
Determination of the optimum amougt of eSSential
nutrients (e.g., mOisture, nitrogen, oxygen, and
PhosPhate) to be added to the unsaturated site soils
in order to promote natural microbial actiVities, without
decreasing the mass removal of the organic compOunds
through in-Situ Vapor Extraction. If determined to be
feasible, this treatment will he implemented as part of the
remedy.
~TA~ORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State environmental
requirements that are legally applicable or relevant and
appropriate to the remedial action, and is Cost-effective. This
remedy. utilizes permanent sOlutions and alternative treatment
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces tOXicity, mObility, or volume as a principal element.
Because this remedy will not result in hazardous sUbstances on-site
above health-based levels, the five-year review will not apPly to
this action.
,
.. A amkus
Administrator
-/f?J
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RECORD OF DECISION
DECISION SUMMARY
'!'BERKO CHD SITE
OPERABLE UNIT I
MUSKEGON COUNTY, MICHIGAN
Prepared By:
U.S. Environmental Protection Agency
Region V
chicago, Illinois
september, 1991
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Section
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.
TABLE OP CONTENTS
~c
SITE NAME, LOCATION, AND DESCRIPTION
.................... .1
SITE HISTORY AND ENFORCEMENT ACTIVITIES ..................4
COMMUNITY RELATIONS HISTORY ..............................7
SCOPE AND ROLE OF OPERABLE UNIT...........~...............8.
SITE CHARACTERISTICS..................................... 8
.-
S~Y OF SITE RISKS.................................... .11
DOCUMENTATION OF SIGNIFICANT CHANGES
. . . . . . . . ". . . . . . . ": . . . . . 18
DESCRIPTION OF REMEDIAL ALTERNATIVES
. . . . . . . . . . . . . . . . . . . . . 18
S~Y OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES ......24
. .
THE SELECTED REMEDY...................................... - oJ
STATUTORY DETERMINATIONS
SUJ.n.!A.Ry. . . . . . . . . . . . . . . . . . . . . . . . . . 33
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ROD SUMKARY
THERMO CHEK SUPERFUND SITE, OPERABLE UNIT I
MUSKEGON COUNTY, MICHIGAN
I. SITE NAME. LOCATION. AND DESCRIPTION
The Thermo Chem Superfund site (the "Site") is located in Egelston
Township, Muskegon county, Michigan, approximately five miles east of
the City of Muskegon. The site consists of approximately 9.5 acres of
land on the south side of the road at 4331 and 4321 Evanston Road (see
Figure 1). The area surrounding the Site is semi-rural and is
comprised of residential areas, iight manufacturing and commercial
buildings, and undeveloped woodland. Black Creek is located
approximately 1,500 feet south of the Site. Black Creek flows to Mona
Lake, which eventually flows into Lake Michigan~-
The nearest population centers to the Site are ~wo mobile home parks
located about 1/2 mile west on Evanston Road that have a total of 594
lots. The nearest single-family residence is located immediately
adjacent to the west of the site. This residence is believed to be
upgradient from the Site based on local hydrogeology information
obtained during investigations at the site (See section V below).
Two other Superfund sites are located near the Site. The SCA
Independent Landfill Superfund site is located approximately 1,800
feet south of the Site (approximately 300 feet south of Black Creek),
and the Bofors Nobel Superfund site is located approximately 1.25
miles east of the Site.
The site consists of two properties which are owned by the Thomas
Solvent Co.: the Thomas Solvent Co. property and the Thermo Chem,
Inc. property. The Thomas Solvent Co. portion covers approximately
1.5 acres, and is situated in the northwest corner of the site. The
Thermo Chem, Inc. portion of the site covers approximately 8 acres
(see Figure 2).
The site is located in the Glacial Lake Plain physiographic unit. The
site is nearly level from north to south with an average elevation of
approximately 655 feet above sea level. The changes in physical
features across the Site are the result of clearing and construction
activities. There is no natural surface drainage on the site because
of the nearly level land surface and the ability of the sandy soils to
allow water to seep through them. Surface soil consists primarily of
medium- to fine-grained sand. The only substantial surface water body
in the area is Black Creek. The Black Creek forms a broad and flat
wetland with standing timber. There is no designated Michigan State
Significant Habitat, or historic landmark site directly or potentially
affected. There are no endangered species in close proximity to the
site~ Some of the areas around Black Creek lie within the lOO-year
. floodplain area. There is a wetland located south of the Site around
the Black Creek area. Black Creek is designated as a trout stream by
the State of Michigan.
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Thermo Chem, Inc. operated as a solvent and chemical waste
reproces$ing, refining, and incineration facility from 1969 until
August 1980. Solvents, paint wastes, and antifreeze received at the
Site were distilled,to regenerate usable solvents. Unrecoverable
materials reportedly were incinerated on site, as were by-products
such as sludge and residues. Wastewater generated from the
distillation and equipment-cleaning process was discharged into a
series of three interconnected lagoons (see Figure 2). The northern-
most lagoon is lined with clay while the other two lagoons are
unlined.
The Thomas Solvent Co. operated from 1961 to October 1986 as a
licensed industrial waste hauler, and hauled hazardous waste to its
subsidiary, Thermo Chem, Inc., for regeneration: The Thomas Solvent
Co. also acquired the recycled material from Thermo Chem, Inc. to
return to the customers. Sixteen underground storage tanks with a
capacity totalling 104,000 gallons were located on the Thomas Solvent.
Co. property and were used to store raw materials and these recycled
materials. The Thomas Solvent Co.. hauled over 200 different chemicals
to the Thermo Chem, Inc. property, which is also owned by Thomas
Solvent Co. Some of these chemicals are designated as hazardous waste
according to the Resource Conservation and Recovery Act (RCRA) (40~-
261 Subpart C and D). At least 3,500 drums were stored on the The~
Chem, Inc. and' Thomas Solvent Co. properties during the time the two
companies were in operation.
There were no physical barriers separating these two adjacent
properties whose ownership and operations were intertwined, and
materials processed at the Thermo Chem, Inc. property were sometimes
deposited at the Thomas Solvent Co. property.
A soil investigation conducted by Michigan Department of Natural
Resources (MDNR) on December 10, 1984 at the Thermo Chem, Inc.
property indicated the pres~nce of: l,l,l-trichloroethane,
. trichloroethene, tetrachloroethene, 4,4' DDT, l,2-dichloroethene, 1,2-
dichloroethane, toluene, ethylbenzene, and xylenes. An investigation
at the Thomas Solvent Co. portion conducted by MDNR on April 30, 1985
indicated that the soil was contaminated with most of these
contaminants as well. Similar compounds also were detected in the
groundwater during the 1985 investigation. Former Thomas Solvent. Co.
and Thermo Chem, Inc. employees indicated that sludge occasionally was
buried on the properties and chemical spills frequently occurred at
the Site. Based on the historical documents and statements from
former employees, it was determined that F001-F005 solvent wastes were Q
disposed of at the Site, which are identified as hazardous wastes
under U.S. EPA's federal regulations promulgated pursuant to the RCRA,
.42 U.S.C. 6901, et seq. .
The Thermo Chem, Inc. property was proposed for inclusion on the
National Priorities List (NPL) in October of 1984. The site was
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placed on the NPL in June 1986. A Consent Order was signed by u.s.
EPA and parties identified by u.s. EPA as being potentially
responsible for the contamination problems at the Site, called
Potentially Responsible Parties, (PRPs). In the Consent Order (U.S.
EPA Docket No. VW 87-C-022, dated september 21, 1987), the PRPs agreed
to conduct a Remedial Investigation and Feasibility Study (RIfFS) at
the ThermoChem, Inc. property to determine the nature and extent of
contamination problems at the property, and identify methods to
correct these problems. The PRPs began investigative activities at
the site in April 1989. .
The Consent Order provided that the Respondents would not be required
to conduct a RIfFS at the adjacent Thomas Solvent Co. property.
However, during the RIfFS at the Thermo Chem, Inc. portion of the
Site, it was discovered that contamination was coming from the Thomas
Solvent Co. property. Therefore, u.S. EPA conducted a study, called a
Technical Assistance Study, to determine the nature and extent of
contamination on the Thomas Solvent Co. property. u.S. EPA'S
investigation of contamination at the Thomas Solvent Co. property was
completed in August 1990, and the final report of u.S. EPA's
conclusions was completed in March 1991. The results of the
investigation at the Thomas Solvent Co. property and the Thermo Chem,
Inc. property indicated that the contamination releases at Thomas
Solvent Co. appear to be one source of the groundwater contamination
identified in the Thermo Chem site NPL listing. Accordingly, the
Thermo Chem site includes both the Thomas Solvent Co. property and the
Thermo Chem, Inc. property.
The Remedial Investigation indicates that groundwater flows south-
southwest toward Black Creek. During the RI at the Thermo Chem, Inc.
property, high levels of contaminants were found in a well near the
Thomas Solvent Co. property upgradient of the Thermo Chem, Inc.
. . . r
property process areas. Th1S well conta1ned contam1nants found at the
Thomas Solvent Co. property. These contaminants were not found in
wells upgradient of Thomas Solvent Co. The soil and groundwater data
collected from both Thomas Solvent Co. and the Thermo Chem, Inc.
properties show that most of the constituents found at the Thermo
Chem, Inc. property were also found at the Thomas Solvent Co.
property. For example, bis(2-ethylhexyl)phthalate was found in the
clay-lined lagoon of the Thermo Chem, Inc. property at a level of 140
parts per million (ppm) and in the soil of the Thomas Solvent Co.
property at a level of 160 ppm. Based on the groundwater flow system
and groundwater data collected, u.S. EPA believes the contaminants
from the Thomas Solvent Co. property are moving toward the Thermo
Chem, Inc. property, contaminating the shallow and deep aquifer of the
northern portion of the Thermo Chem, Inc. property. This
contamination plume then mingles with the contamination plume from the
central processing area at the Thermo Chem, Inc. property.
Contaminated soil at the Thomas Solvent Co. property also contributes
to the groundwater contamination. The Thomas Solvent property, then,
is an additional source of the releases which were identified as part
of the original NPL listing. The scope of the cont~mination listed as
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the Thermo Chem, Inc. site on the NPL includes both the Thomas Solvent
Co. property and the Thermo Chem, Inc. property.
Concurrent with investigation activities at the Thermo Chem, Inc. and
Thomas Solvent Co. properties, an emergency removal of drums and
materials containing hazardous waste was conducted by U.S. EPA at the
Thermo Chem, Inc. property from September 1988 until December 1988.
The removal action was taken to reduce the threats posed to public
health by the presence of the uncontained chemicals and drums at the
Site. The chemicals were stored in the laboratory building, and the
drums.were found in buildings throughout the site. Buildings at the
site were unsecured. U.S. EPA transported the chemicals off site for
incineration. Four drums containing hazardous waste solids and one
drum containing hazardous waste liquid were transported off site for
treatment and disposal. U.S. EPA also sampled the insulation
materials from buildings ~nd tanks for the presence of asbestos
material~ Results indicated that the insulation material did not
contain asbestos.
J
U.S. EPA has separated the study of contamination at the Thermo Chem .
Superfund site into two separate areas, called operable units.
Operable Unit I, which is the subject of this Record of Decision,
focuses on contaminated soil, sludge and groundwater at the site, up
to the point where groundwater discharges into Black Creek. Operabl,
Unit II will address contamination problems in Black Creek, i.e.,
surface water, sediment, plants and living organisms, and groundwater
south of Black Creek. The Operable Unit approach was agreed upon
after discussions between u.S. EPA and MDNR during the RI. This ROD
is being developed for Operable Unit I.
The final RI Report for Operable Unit I was completed in May 1991, and
U.S. EPA anticipates finalizing the report on Operable Unit II in
April 1992. Simultaneously, U.S. EPA began developing and screening
alternatives for addressing contamination problems found in Operable
Unit I. A document called the Alternatives Array was prepared in '
January 1991, which provided a preliminary description of the
technical methods under consideration for cleaning up Operable Unit I.
Based on the evaluation and screeninq of technical methods in the
Alternatives Array, a draft Feasibility Study Report was prepared in
May and finalized in July 1991. The Feasibility Study Report for
Operable Unit I outlines the final alternatives under consideration
for correcting contamination problems found at Operable Unit I, and
provides a thorough evaluation of each.
U.S. EPA asked the PRPs to conduct additional field work to define
groundwater contamination problems around Black Creek and the impact
of the contamination on the Creek. The field work includes installing
approximately 10 monitoring wells north of Black Creek, 6 monitoring
wells south of Black Creek, and collecting seven sediment and surface
water samples from Black Creek. The field work for these additional
activities was initiated in July 1991.
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u.s. EPA also conducted emergency removal activities in April 1991.
During the investigation at the Thomas Solvent property, pure solvent
was discovered in monitoring well #3 which is located approximately'
100 feet downgradient of the underground storage tank farm area at the
Thomas Solvent Property (See Figure 4). U.S. EPA inspected these
underground storage tanks and found that some contained residual
solvents and had venting pipes which could not be secured. u.s. EPA
determined that these tanks could pose an imminent and substantial
endangerment to pUblic health or welfare or environment because of the
potential for explosion and threat of release from the tanks. The 16
underground storage tanks on the Thomas Solvent Co. property and their
contents were removed and taken off site for disposal by u.s. EPA.
III. COMMUNITY RELATIONS ACTIVITIES
Upon the signing of the Consent Order in September 1987, U.S. EPA held
a 30-daypublic comment period. A press release was sent to all media
and advertisements were placed.
A fact sheet was developed in June 1988 to announce and eXplain the RI
process.
A community Relations Plan was prepared for the site in July 1989.
This plan lists contacts and interested parties throughout the local
and government community. It also establishes communication pathways
to ensure timely dissemination of pertinent information.
A public meeting was held on April 18, 1991 to explain the results of
the Remedial Investigation and the plan to remove the underground
storage tanks at Thomas Solvent Co. property. A fact sheet was
developed in conjunction with this meeting. Advertisement were placed
to announce the meeting and a press release was sent to all local
media.
The RIfFS'Reports and Proposed Plan for Operable unit I at the site
were releas,ed to the public in July 1991. All of these documents were
made available in the information repository maintained at the
Egelston Township Branch of Muskegon County Library. An
administrative record file containing these documents and other site-
related documents was placed at the same repository. The notice of
availability of these documents was published in the Muskegon
Chronicle on July 8, 1991. Press releases were also sent to all local
,media. A 'public comment period was held from July 11, 1991 to August
9, 1991. At the request of the Thermo Chem PRP group, the public
comment period was extended until September 9, 1991. In addition, a
public meeting was held on July 16, 1991 to present the results of the
RIfFS and the preferred alternative as presented in the Proposed Plan
for the site. All comments which were expressed verbally at the
public meeting are addressed in the Responsiveness Summary of this
ROD.
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8
IV. SCOPE AND ROLE OF OPERABLE UNIT
As discussed in Section III above, U.S. EPA has divided the Site into
two operable units. Operable Unit I, which is the subject of this
Record of Decision, will address soil, sludge and groundwater
contamination up to the Black Creek; Operable Unit II will address
contamination within Black Creek and groundwater contamination South
of Black Creek. This operable unit approach will address
contamination flowing towards Black Creek while allowing further study
of the impact on Black Creek and downgradient groundwater.
U.S. EPA identified contaminated groundwater, soil, and sludge as
potential risks to human health and the environment. Contaminated
soil at the Site is considered to be the principal threat. To address
these risks, U.S. EPA developed the following remedial objectives for
Operable Unit I based on the data obtained during the Remedial
Investigation: .
1)
Reduce or minimize direct human and environmental contact
w~th contaminated soil through inhalation and ingestion;
2)
Reduce or minimize the release of contaminants in soil ant
sludge to the groundwater; and .
3)
Restore groundwater so that contamination levels meet
appropriate health standards, and stop the flow of
contaminated groundwater to Black Creek.
This ROD was developed to meet these objectives and it addresses the
contamination problems identified in Operable Unit I, namely the soil,
sludge, and groundwater contamination at the Thermo Chem, Inc. and
Thomas Solvent Co. properties, up to the discharge point ~t Black
Creek. This response action is being implemented to protect human'
health and the environment from risks posed by the contamination
problems.
This present response action, by addressing contaminated groundwater,
soil, and sludge, is fully compatible with all future Superfund.
investigation and cleanup work at the Site, including the on-going
investigation at Black Creek and in groundwater south of Black Creek.
The contamination problems in the Black Creek, including sediment,
. surface water, biota, and groundwater south of Black Creek, and the
risks posed thereby will be evaluated and addressed during Operable
Unit II.
V. SITE CHARACTERISTICS
Two principal aquifers were identified during the Remedial
Investigation and Technical Assistance study at the Site. The upper
unconsolidated, unconfined aquifer varies in thickness from 20 feet in
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....- ._. --- .
9
the northeast area of the site to 55 feet in the southwest portion of
the site. The groundwater table lies from 17 feet below the ground
surface in the northeast to 32 feet below the surface in the
southwest. The upper unconsolidated deposits are predominantly medium
to fine grained san~. The upper and lower aquifers are separated by a
discontinuous layer of clay. The deeper confined/semi-confined
aquifer is located beneath the silty-clay layer'. It varies in
thickness from 61 feet to 116 feet. The deepest penetrated sediments
are glacial tills.
Although fluctuations in groundwater levels do occur, groundwater in
both the upper and lower aquifers flows in a south-southwest direction
throughout the year. The rate of the groundwater flow is between
1.7 - 2.38 feet per day. Based on the hydrogeo~ogic information
collected during RI, it is believed that the groundwater from the site
is, discharging to Black Creek.
The ground surface of the Site is relatively level, and ,the surface
material consists of sandy soil. Because rainwater flows quickly
through sandy soil, the rate of 'seepage through the soil, called the
permeability rate, exceeds 10 inches per hour. Because of this high
rate, there is no surface runoff or surface drainage of rainwater at
the Site, and rainwater flows directly through.the ground surface to
the upper aquifer. '
The results of a geophysical and soil-gas survey prompted further
investigation to determine. if any drums containing hazardous materials
were buried on the site. Eight pits were dug in search of drums, and
sludge was found in t~e vicinity of test pit #8. Some, of the sludge
was excavated and stored in drums at the site for later disposal. No
drums were found during test pit activities.
Soil contamination at the Site is concentrated primarily in two "hot
spots", located in the central processing area of the Thermo Chem,
Inc. property: the clay liner in the base of the northern most
disposal lagoon on the property; and sludge in the vicinity of test
pit #8. However, soil contamination above levels acceptable to u.S.
EPA and MDNR health standards also has been found in other locations
at the Site. The contaminants causing the most concern are volatile
organic compounds. Of the volatile organic compounds detected in
'these areas, tetrachloroethene, trichloroethene, ethylbenzene, arid
total xylenes were detected frequently in soil samples (See Table 2).
Phthalate compounds were the semi-volatile organic compounds most
- frequently detected.' Inorganic compounds were found in soil samples,
including arsenic, chromium, lead, and cyanide. PCB and Pesticides,
including heptachlor, dieldrin and 4,4'-DDT, were also found in the
soil.
On the Thomas Solvent Co. property, the highest leveis of
contamination were detected in the area just south of the loading dock
and tank farm. Volatile organic compounds detected at this location
were similar to those detected at the Thermo Chem, Inc. property.
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10
During the study of the Thomas Solvent Co. property, the U.S. EPA
excavated 16 underground storage tanks which were believed to be
leaking. However, soil samples collected during the tank removal
indicated that the tanks were not presently leaking.
,
During monitoring well installation, a vertical aquifer sampling
technique was performed in order to determine the presence of a
contamination plume. The groundwater in the shallow and deep aquifers
was sampled at ten foot intervals to the depth of the regional clay
till and analyzed for compounds of concern at the Site. The results
of this vertical sampling technique were utilized to determine the
appropriate depth of screening for each monitoring well. .
Groundwater samples collected from shallow and ~edium-depth monitoring
wells on the Site contained elevated levels of volatile organic
compounds. The most frequently detected compounds include 1,1,1-
trichloroethane, toluene, xylenes, benzene, and ethylbenzene. Of the
semi-volatile organic compounds detected, phthalate compounds were the
most frequently detected. Inorganic compounds such as arsenic and
cyanide were also found in the groundwater. Those contaminants
detected the most frequently at the site also were the contaminants
detected at the highest levels (see Table 3). ' The deep aquifer also
is contaminated with low-to-medium levels of contamination.
Table 2 identifies the maximum concentrations of contaminants in soil,
sludges and the lagoon clay-liner. Table 3 identifies the average and
maximum concentrations of contaminants in groundwater. Many
contaminants including benzene, trichloroethene, and arsenic are known
or suspected human carcinogens. .'
Contaminants were detected in monitoring wells downgradient of the,
Site, 200 feet north of Black Creek. Based on this information, U.S.
EPA believes that contaminated groundwater has reached the discharge
point of Black Creek. U.S. EPA currently is conducting further
studies to determine whether the contamination has, in fact, reached
Black Creek.
U.S. EPA determined that groundwater contamination detected both
beneath and downgradient from the Site is a result of contamination
sources at the Thermo Chem, Inc. and Thomas Solvent Co. properties.
-Operations at the two properties have contaminated the groundwater in
the shallow and deep aquifers. Suspected sources of contamination
include the three inter-connected lagoons located in the central
-processing area and sludges disposed at the Thermo Chern, Inc.
property, the underground storage tanks at the Thomas Solvent Co.
property, and spills throughout the site.
A.single-family residence located immediately adjacent to the west of
the Site has been sampled annually since 1986 by MDNR. No
contamination has been detected at this well.
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11
Based on the levels and type of contaminants found durinq the Remedial
Investigation and the Technical Assistance study, and site operations,
u.s. EPA divided the contaminated soils into four areas. During the
Feasibility study, methods for addressing soil contamination problems
focused on these four areas:
Group 2 Soils:
soils and sludqe in the: a) Clay-lined disposal
lagoon; b) Areas around test pit #1 and #8; and c)
Areas around soil borinqs #3, 4, 5, 9,10, 13, and
Monitoring well #7 (see Fiqure 2 and 3). It is
estimated that the total volume of Group 1 soils is
approximately 1,800 cubic yards.
Soils in the area around soil boring #3 of the Thomas
Solvent Co. property, extending from the qround surface
to the water table (see Figure 2 "and 4). The estimated
volume of Group 2 soils is ~pproximately 200 cubic
yards.
Group 1 Soils:
Group 3 Soils: Soils in the area of the Thermo Chem, Inc. central
processing operations. The estimated area of Group 3
soils is 60,000 square feet.
Group 4 Soils: Soils near the operations area of the Thomas Solvent
Co. property. The surface area covered by Group 4
Soils is approximately 60,000 square feet.
Group 1 soils a);:'e "hot spots" located and included within the area
referred to as Group 3 soils; and Group 2 soils is a "hot spot"
located and included within the area referred to as qroup 4 soils.
More detailed information regarding the results of the Remedial
Investigation are contained in a Remedial Investigation Report.
VI. SUMMARY OF SITE RISKS
After u.s. EPA analyzed the data from the RI, a risk assessment was
performed to evaluate potential effects of the contamination at .
Operable Unit I of the site on human health and the environment. The
existence of and risks posed by Black Creek contamination will be
assessed in Operable Unit II.
The risk assessment focused on ways in which nearby residents and
animals could be exposed to contaminated materials both currently and
in the future. A risk assessment consists of four primary parts:
identifying chemicals of concern; assessing pathways through which
humans, plants, and animals could be exposed to contamination;
assessing the toxicity of the contaminants; and characterizinq
cancerous and non-cancerous health effects on humans.
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.
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Figure 3
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14
a.
.Human Health Risks
1.
Contaminant Identification
In order to evaluate potential risks posed to human health and
the environment, u.s. EPA determines which chemicals were
detected the most frequently; which are the most toxic;, which
are the most likely to migrate off the Site; and which are the
most likely to remain in the environment without breaking down
into less harmful compounds. .Based on these criteria, u.s. EPA
identified a list of chemicals of concern f~r the Site (see list
below and Table 2 and 3). This risk assessment focuses on health
and environmental effects resulting from exposure to these.
chemicals.
1,1-Dichloroethene
Total 1,2-Dichloroethene
Chloroform .
1,2 Dichloroethane
1,1,1-Trichloroethane
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Total xylenes
bis(2-Ethylhexyl)phthalate
Napthalene
Arsenic
Chromium
These contaminants were detected in both groundwater and soils at
the site. The maximum concentrations of contaminants in soil,
sludges and the lagoon clay-liner at the site are listed in Table
2. Table 3 identifies the average and maximum concentrations of
contaminants in groundwater.
2.
Exposure Assessment
The exposure assessment. identifies the pathways through which
people or wildlife could come into contact with site-related
contamination -- both currently and in the future. At the Site,
u.s. EPA determined that currently, trespassers who walk on the
Site to hunt or hike might come into contact with contaminants by
accidentally swallowing soil, inhaling dust blowing around the
Site, or inhaling chemical vapors evaporating from the soil.
u.S. EPA based its evaluation on the assumption that a hiker or
hunter would trespass on the Site 90 days per year and would
remain on the Site for 10 hours per visit over a period of 30
years.
Currently, there are no residential wells downgradient of the
site. Therefore, U.S. EPA has concluded that local residents are
not presently at risk from exposure to contaminated groundwater.
u.S. EPA evaluated potential future risks to people if a
residential neighborhood were developed on the Site. u.S. EPA
assumed that the site would be vegetated and paved in a future
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15
residential development scenario. In addition, u.s. EPA based
its evaluation on the assumption that future residents would
install groundwater wells to be used for drinking water, cooking,
and bathing. Under this scenario, u.s. EPA determined that these
future residents might come into contact with site-related
contaminants by accidentally swallowing contaminated soil;
inhaling chemical vapors evaporating from the soil; drinking
groundwater; or coming into direct contact with groundwater while
bathing or inhaling vapors while showering. To evaluate
potential risks to these future residents, u.s. EPA assumed that
groundwater would be used for drinking and bathing 365 days per
year and contact with soil would occur 240_days per year (during
frost-free days) over a period of 30 years.
.-
The risk assessment utilized a ninety-five percent upper
confidence limit of the arithmetic average concentration to
calculate the risk posed by each contaminant of concern. in the
soil. For groundwater, the risk assessment used the maximum
concentrations of contaminants of concern.
3.
Toxicity Assessment
u.s. EPA evaluates the harmful effects, or toxicity, of a
chemical in terms of its potential cancerous and non-cancerous
health effects. Research is conducted to determine the toxicity
of chemicals, and u.s. EPA uses the results and conclusions of
this research in its evaluation of the toxicity of site-related
contamination. In the research of a chemical's toxicity, the
effects of low levels of chemical exposure on people in the
workplace are studied over long periods of time, and test animals
are studied in laboratories, where animals are exposed to varying
levels of chemicals over different lengths of time.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogen Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg /kg / day) -I ,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg/day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake.
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of ~he actual cancer risk highly unlikely..
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
anima1-to-human extrapolation and uncertainty factors have been
applied.
The cancer potency factors for carcinogenic contaminants of
concern at the site are as follows:
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. .
.'
1,1-Dichloroethene
Chloroform
bis(2-Ethylhexyl)phthalate
1,2-Dichloroethane
Arsenic
Trichloroethene
Benzene
Tetrachloroethene
16
Slope Factor
(mg/kg/day) -1
aroundwater
1.2
.081
.014
.091
2
.017 .
.029 .
.051
~
1.2
.081
.014
.091
50
.017
.029
.051
.-
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg/day, are estimates of lifetime daily.
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental ~edia (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors help ensure that the RfDs will not underestimate the
potential for adverse noncarcinogenic effects to occur.
The reference doses for contaminants of concern at the site that
have noncarcinogenic effects are as follows:
Toluene
Total 1,2-Dichloroethene
Total xylenes
Napthalene.
1, 1, 1-Trichloroethane
Chromium III
1,1-Dichloroethene
Chloroform
bis(2-Ethylhexyl)phthalate
Arsenic
Tetrachloroethene
Reference Dose
(mg/kg/day)
qroundwater ~
.2 .2
.02 .02
.2 .2
.004 .004
.09 .09
1 6X10-7
.009 .009
.01 .01
.02 .02
.001 .001
.01 .01
,
4.
Risk Characterization
A risk assessment evaluates both cancerous and non-cancerous
health effects. Cancer risks are evaluated in terms of the
increase in the expected number of cancer cases in a community.
u.s. E~A considers a cancer risk unacceptable if it might lead ~v
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17
more than one additional case of cancer for every 10,000 to one
million people exposed to the contamination.
Non-cancerous health effects are evaluated in terms of a Hazard
Index. The Hazard Index is a formula that reflects the
likelihood that exposure to a chemical will promote harmful
health effects. A Hazard Index of greater than 1.0 indicates
that exposure to contamination is likely to cause harmful non-
cancerous effects.
Table 1 identifies 'carcinogenic and non-carcinogenic risk for
total contaminants of concern tor each media in each exposure
pathways. Risks posed by each contaminant of concern are
identified in the Remedial Investigation R~port.
(A)
Risk to Trespassers
.-
At the Site, u.S. EPA determined that hikers and hunters who
accidentally might swallow site soil, inhale blowing dust, or
inhale evaporating vapors from the soil might experience an
excess cancer risk of two additional cases for every. 1,000 people
exposed to the contamination. u.S. EPA considers this an
unaccep~able cancer risk. The Hazard Index associated with such
exposure is 500, indicating a strong likelihood that exposure
would cause harmful non-cancerous health effects as well. These
effects might include nerve damage resulting from exposure to
arsenic and central nervous system depression from exposure to
tetrachloroethene.
(B)
Risk to possible Future Residents
Using the maximum levels of each contaminant detected in site
soils for its calculations, u.S. EPA calculated the excess cancer
risk for residents living on the Site if a residential area were
developed there in the future. The cancer risk is nine
additional cases for every.1,000 people exposed to the
contamination in site soils. u.S. EPA considers this an
unacceptable cancer risk. U.S. EPA also calculated the Hazard
Index for possible future residents as 8.0, indicating that.
exposure to contaminants would likely produce harmful non-
cancerous effects. The risk to possible future residents is
lower than the risk to current trespassers because dust emissions
would be reduced by the vegetative cover and pavement assumed for
the future residential scenario.
u.S. EPA also determined that future residents living on the site
might be exposed to contaminants in groundwater by drinking it,
coming into direct contact with it, or inhaling volatile 'organic
compounds evaporating from the water during showering. u.S. EPA
determined that this exposure could produce an unacceptable
cancer risk of two additional cases for every 10 people exposed.
U.S. EPA calculated a Hazard Index of 3,000 for exposure to
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18
groundwater, indicating a strong likelihood that these residents
might experience harmful non-cancerous health effects. These.
health effects would be similar to those produced by exposure to
contaminated soil.
b.
Risk to the Environment
Because the area south of the Thermo Chem site is heavily wooded,
U.S. EPA believes animals may wander onto the property to graze
and come into contact with contaminated soil at the site. In
addition, contaminated groundwater from the site might discharge
into Black Creek. Because some chemicals get stored in the fatty
tissues of animals, animals living near the creek may experience
harmful effects from .the contamination. Moreover, animals or
people who eat the affected animals may experience health
effects, as well. Therefore, u.S. EPA will conduct an ecological
study in the Black Creek area to determine the effect of .
contamination on living organisms during the Remedial
Investigation of Operable unit II. .
The goal of .this response action is to reduce risk from groundwater
and soil contamination at the locations included 'in Operable Unit I to
acceptable human health standards of 10~ for cancer-causing
contaminants and a hazard index of 1.0 for non-cancer causing
contaminants, and applicable or relevant and appropriate standards.
Actual or threatened release of hazardous substances from this site,
if not addressed by implementing the selected response action, may
present an imminent and substantial endangerment to public health,
welfare or the environment.
VII. DOCUMENTATION OF SIGNIFICANT CHANGES
After a careful review of the areas and volumes of soil to be
addressed at the Site, u.S. EPA now estimates that only 3 acres would
be addressed by Alternative 5, and has accordingly recalculated its
cost estimate for Alternative 5 to $21,000,000 present net worth. As
discussed below, this modification does not alter U.S. EPA's selection
of Alternative 3.
VIII. DESCRIPTION OF REMEDIAL ALTERNATIVES
Based on the results of the RI and risk assessment, the PRPs conducted
a Feasibility Study to identify and evaluate a variety of alternatives
for protecting human health and the environment from the contamination.
associated with Operable unit I at the site. After identifying and
screening of potential remedial technologies for the site, five
Alternatives were selected for further evaluation. The selection oi
these five Alternatives from various remedial technologies were based
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19
on the screening process including the remediation goal, volume of
.media remediated, and the merit of the technology. Each of the
alternatives is evaluated using a set of nine criteria that reflect
the goals of the Superfund program and are used by u.S. EPA to compare
the merits of each alternative. These criteria are explained in
Section IX.
Descriptions of the five alternatives considered by u.S. EPA are
provided below, including costs, estimated in terms of capital cost
and annual operation and maintenance cost. Together these two dollar
amounts are converted to net present worth. U.S. EPA's evaluation of
each remedial alternative using the evaluation criteria is summarized
in Section IX. .
The alternatives considered for Operable Unit I are:
Alternative 1: No Action.
Alternative 2: In-situ vitrification of Group 2 and 3 soils; and
Groundwater collection and treatment with discharge to
Black Creek.
Alternative 3:
Off-site incineration of Group 1 and
In-situ vapor extraction of all site
Groundwater collection and treatment
Black Creek.
2 soils;
soils; and
with discharge to
Alternative 4:
Off-site incineration of Group 1 and 2 soils;
In-situ soil flushing and bioremediation of all site
soils; and
Groundwater collection and treatment with discharge to
shallow aquifer.
Alternative 5:
Slurry wall around Group 3 and 4 soil areas;
Capping Group 3 and 4 soils; and .
Groundwater collection and treatment with discharge to
Black Creek. .
All of the alternatives above except Alternative 1 (No Action) contain
the following components:
.
Decontamination, demolition, and off-site disposal of on-
site structures, including the laboratory, process
buildings, a warehouse, an incinerator, and all above-ground
storage tanks, all underground pipelines, and other
structures located at the site.
.
Installation and maintenance of a fence around the site
during the implementation of the remedy.
Restrictions on use of property at the site during
implementation of the remedy, including groundwater
.
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_...... ......- .. .
... ".. - --- .-..--.-
20
remediation, to the extent necessary to implement and
protect the remedy, and to safeguard human health and the
environment during implementation of the remedy.
The descriptions of Alternatives 3 and 4 also include cost comparisons
of off- and on-site incineration of Group 1 and 2 soils.
A description of each of these alternatives follows:
Alternative 1:
No Action
Under this alternative, the Site would be left in its present
condition and no action would be taken to reduce the risk of exposure
to contamination. U.S. EPA requires considerati~n of a no-action
alternative to serve as a basis against which other remedial
alternatives can be compared.
Alternative 2: In-situ vitrification of Group 2 and 3 soils; and
Groundwater collection and treatment with discharge to
Black Creek.
Under this alternative, Group 2 and 3 soils will be treated using in-
situ vitrification. This process involves inserting four electrodes
into the ground to form a square around the area of contaminated soit.
An electrical current is produced which heats the contaminated soil to
a temperature of 3,500 F. . At this temperature, the soil melts into a
liquid and the contaminants evaporate into gases. The gases are
captured in a hood placed over the melting area and then treated with
a process called carbon adsorption. This process involves passing the
gases over a bed of treated carbon. The carbon then is regenerated or
disposed of off site. The soil cools and becomes a solid that.
resembles glass and is left in place. Clean soil will be placed over
it and vegetation will be planted. This treatment will prevent the
leaching of soil contaminants into the groundwater. .
Groundwater from the shallow and deep aquifers will be extracted and
treated to meet Michigan Act 307 Type A or B standards throughout the
plume(s) at Operable Unit I. Treatment consists of passing the water
through a filter to remove grit and other coarse particles, followed
by air strippinq. Air stripping involves releasing contaminated
groundwater from the top of a tower while air is blown up through the
falling water. The blowing air forces the organic chemicals in the
water to evaporate. . These gases will be treated using carbon
adsorption, similar to the process used for the gases produced from
the in-situ vitrification of soil. Then the groundwater will pass
through the metal precipitation tank to precipitate metals. The
treated groundwater will be tested to ensure that its acid (pH) level
is acceptable for discharge into Black Creek. If it is not, the
groundwater will be treated first to correct the acid content before
it is discharged. . .
, .
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21
For the discharge of off-gas emitted from the vitrification procedure
and air striping, the Michigan Air Pollution Act (1965 Public Act 348)
is an ARAR. All residue, sludge, spent carbon, or spent
coagulant/flocculent shall be treated to meet the Land Disposal
Restriction standards for F001-F005 wastes and shall be placed in a
RCRA landfill in accordance with the requirement of 40 CFR 268.41.
Discharges of treated groundwater to Black Creek will comply with
applicable or relevant and appropriate requirements, including Clean
Water Act (CWA), National Pollutant Discharge Elimination System
(NPDES) requirements.
Soil and Groundwater will attain Michigan Act 307 Type A or B cleanup
standards. (See Tables 2 and 3)
More soil sampling and leachate tests will be required in the Group 4
soil area in order to attain Michigan Act 307 Type A or B cleanup
standards. If some of these soils are exceeding the cleanup
standards, then these soils will be excavated and consolidated with
Group 2 soils for in-situ vitrification.
The volume of soils to be vitrified is approximately 25,000 cubic
yards. The capital costs of this alternative is approximately
$73,600,000, and annual Operation and Maintenance (O&M) cost is
$959,000. The 30-year Present Worth (PW) cost is $82,700,000. The
amount of time necessary to implement this alternative would be 17
months for soil and 30 years for groundwater .
Alternative 3:
Off-site incineration of Group 1 and
In-situ vapor extraction of all site
Groundwater collection and treatment
Black Creek.
2 soils;
soils; and
with discharge to
Groundwater will be collected and treated by filtration, air
stripping, metal precipitation, and pH adjustment as described in '
Alternativ~ 2.
The Group 1 and 2 soils will be excavated and transported off site to
a RCRA licensed incinerator which can accept such waste under the Off-
Site Policy. This excavation will remove all soils and sludges in
excess of Michigan Act 307 Type A or B Cleanup Standards.
Transportation of the excavated soils will be conducted to meet all
"federal, state and local hazardous waste shipping requirements.
U.S. EPA estimates that 2,000 cubic yards of soil will be excavated in
- Groups 1 and 2. However, this estimate is based on the ceiling for
attainment of direct contact standards for inorganic compounds and
PCB/Pesticides. More soil may have to be excavated in order to attain
Michigan Act 307 standards if a leaching test is not conducted or
fails for remaining soils in groups 1 and 2 contaminated with arsenic,
chromium, lead, zinc or cyanide. If all soils contaminated with
arsenic, lead, zinc or cyanide fail a leachate test, approximately 370
additional cubic yards would have to be removed. If a leachate test
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. .
..-- --..-.. -.------ -- .
--. -~ -._-
... ----
22
is not conducted or if the leachate test fails for soils contaminated
with chromium, approximately 140 additional cubic yards of soil would
have to be removed. Because of the low levels of total chromium, zinc
and cyanide at the Site, u.S. EPA is confident that soils at the Site
contaminated with c~romium, zinc and cyanide will pass a leachate
test. If U.S. EPA determines that based on information obtained
during the RD/RA, the increase in soil volume constitutes a
significant change and requires that the remedy be fundamentally
altered with respect to scope, performance or cost, a ROD amendment
will be issued. U.S. EPA does not anticipate, however, that this will
occur.
After the Group 1 and 2 soils have been removed._from the Site, an in-
situ vapor extraction system will be installed to treat the remaining
site soils to remove the volatile organic compounds to meet Michigan
Act 307 Type A or B Cleanup Standards. The ISVE will include
extraction wells, and may also utilize injection wells. Alternating
rows of injection wells and vacuum withdrawal wells could be installed
to ensure that air is distributed evenly through the soil while
contaminated vapors are extracted at a rapid rate throughout the
system. The gases produced during the in-situ vapor extraction will
be burned in an fume-rich incinerator in order to comply with Michig
Air Pollution Act (1965 P.A. 348). .
During full-scale ISVE implementation, a Treatability Study will be
performed to determine the feasibility of enhancing the natural
biodegradation of organic compounds. The treatability study would be
designed to determine the optimum amounts of nutrients (e.g.,
moisture, oxygen, nitrogen, and phosphate) to be added to the
unsaturated soils to promote biological activity without interfering
with ISVE treatment. If the results of the Treatability Study indicate
that injecting nutrients is a feasible technology which will enhance
the biodegradation of organic compounds, then this technology will ~e
implemented as a component of the ISVE.
The same federal and state regulations (e.g., discharge of gases and
treated groundwater) that apply to Alternative 2 also will apply to
this alternative. In addition, RCRA requirements are relevant and
appropriate at the Site, and applicable to certain remedial activities
as discussed in Section XI. .
The volume of soils to be excavated is approximately 2,000 cubic
yards, and the area to be treated with in-situ vapor extraction is
.. approximately 9.5 acres. The capital costs of this al ternati ve is
approximately $15,200,000, and annual O&M cost is $1,091,000. The 30-
yearpw cost is $24,300,000. The amount of time necessary to
implement this alternative would be 43 months for soil and 30 years
for groundwater.
If this alternative included on~site incineration (instead of off-
site), the costs would be:
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23
Capital Cost: $14 million.
Annual Operation and Maintenance:
Present Net Worth: $23 million.
$1,091,000
Alternative 4:
Off-site incineration of Group 1 and 2 soils;
In-situ soil flushing and bioremediation of all site
soils; and
Groundwater collection and treatment with discharge to
shallow aquifer.
Groundwater will be collected and treated by filtration, air
stripping, metal precipitation, and pH adjustmen~ as described in
Alternative 2. However, under this alternative 'the treated
groundwater would be injected into the shallow aquifer.
This alternative includes off-site incineration of Group 1 and 2 soils
as in Alternative 3. . After the soils have been removed, the remaining
soil will be doused with the treated groundwater in a process called
soil flushing. Prior to the soil flushing, the site will be lined
with a gravel layer to provide support for the flushing network and
enhance the distribution of the flushing water. The water will be
applied to the soil with a pipe distribution system. Recovery wells
will be placed along the'border of the flushing area to recover the
flushing water. Soils will attain Michigan Act 307 Type A or B
standards.
In-situ bioremediation will be evaluated as part of this alternative.
A Treatability study will be conducted to determine whether
bioremediation will be effective.
The federal and state air emission, soil and groundwater requiremen~s
described in Alternative 2 will have to be met. In addition, this
. alternative must comply with. applicable or relevant and appropriate
requirements for underground injection. Requirements include. Solid
Waste Disposal Act requirements and RCRA Land Disposal Restrictions.
The volume of soils to be excavated is approximately 2,000 cubic'
yards, and the area to be treated with in-situ soil flushing is
approximately 9.5 acres. The capital costs of this alternative is
approximately $14,800,000, and annual O&M cost is $1,042,000. The 30-
year PW cost is $24,000,000. The amount of time necessary to
implement this alternative would be 12 years for soil and 30 years for
groundwater .
If this alternative included on-site incineration, the costs would be:
Capital Cost: $13.2 million.
Annual Operation and Maintenance:
Present Net Worth: $24 million.
$1,091,000
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Alternative 5:
Slurry wall around Group 3 and 4 soils;
Capping Group 3 and 4 soils; and
Groundwater collection and treatment with
Blac~ Creek.
The groundwater collection and treatment activities in this
alternative are identical to those included in Alternative 2.
discharge to
Under this alternative, a slurry wall will be installed around the
Group 3 and 4 soils area, which include the Thomas Solvent Co.
operating area and the Thermo Chem, Inc. central process area. The
trench will be dug to the bottom of the contain~d area to a depth of
approximately 30 feet. The trench will be 3 fe~t wide. The excavated
soil will be used in the backfill for the trench.
Following the installation of the slurry wall, a RCRA multi-layered
cap will be installed over the Group 3 and 4 soil areas. The RCRA cap
will prevent rainwater from seeping into the soil below. A drainage'
layer will be installed to direct water away from the capped area, and
a vegetative cover will be placed on top of the cap to limit erosion
by wind and rain.
This alternative reduces the risk of
attains Michigan Act 307 groundwater
Unit I. However, it does not attain
standards for soils.
direct contact with soil and
cleanup standards in Operable
Michigan Act 307 Type A or B
In addition to the property restrictions described on pages 19-20
above, this Alternative would require a perpetual restriction on
residential development, excavation or groundwater use. Michigan Act
307 Rule 299.5719 authorizes such restrictions.
Closure of the Site with a RCRA Subtitle C cap is an ARAR, because'
RCRA wastes (i.e., F001-FOOS) were disposed of at the site.
The area to be trenched and capped is approximately 3 acres. The
capital costs of this alternative is approximately $11,200,000, and
annual O&M cost is $983,000. The 30-year PW cost is $21,000,000.. The
amount of time necessary to implement this alternative would be 22
months for soil and 30 years for groundwater
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed. analysis was performed
nine evaluating criteria in order
is a summary of the comparison of
weakness with respect to the nine
criteria are as follows:
on the five alternatives using the
to select a remedy. The following
each alternative's strength and
evaluation criteria. These nine
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25
1) Overall Protection of Human Health and the Environment
An assessment of whether the alternatives can adequately protect human
health and the environment, in both the short and long-term, from
unacceptable risks posed by hazardous substances, pollutants or
contaminants present at the site by eliminating, reducing, or
controlling exposure to levels established during development of
remediation goals.
2) Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
An assessment of whether the alternatives' attain applicable or
relevant and appropriate requirements under federal environmental laws
and state environmental or facility siting law~or provides grounds
for invoking a waiver. .
3) Long-Term Effectiveness and Permanence
An assessment of the long-term effectiveness and permanence .the
alternatives afford, and the degree of certainty they will prove
successful. Factors to consider include the magnitude of residual
remaining from untreated waste or from treatment residuals at the
conclusion of the remedial activities, and the adequacy and
reliability of controls that are necessary to manage treatment
residuals and untreated waste.
risk
4) Reduction of Toxicity, Mo~ility, or Volume through Treatment
An assessment of the degree to which the alternatives employ treatment
that reduces toxicity, mobility or volume, including how treatment is
used to address the principal threats posed by the site. Factors
considered include the treatment processes employed and materials
treated; the amount of hazardous substances, pollutants or
contaminants destroyed or treated; the degree of expected reduction in
toxicity, mobility, or volume of waste due to treatment and the
specifications of which reductions are occurring; the degree to which
the treatment is irreversible; the type and quantity of residuals
remaining after treatment; and .thedegree to which treatment reduces
the inherent hazards posed by principal threats at the Site.
5) Short-Term Effectiveness
An assessment of the short-term impact of the alternatives considering
the following factors: short-term risks posed to the community during
implementation; potential impacts on workers during remedial action
and the effectiveness and reliability of protective measures;
potential environmental impacts and the. effectiveness and reliability
of mitigative measures during implementation; and time until
protection is achieved.
6) Implementa~ility
An assessment of the ease or difficulty of implementing the
alternatives by considering the following types of factors: technical
feasibility, administrative feasibility, and availability of services
and materials.
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2'
7) Cost
An assessment of the types of costs involved, including capital
annual operation and maintenance cost, and net present value of
capital and operation and maintenance costs.
costs, 0
8) state Acceptance
An assessment of state concerns, including the state's position and
key concerns and state comments on ARARs an~ proposed use of waivers.
') Community Acceptance
An assessment of components of alternatives interested persons in the
community support, have reservations about or oppose.
1.
Overall Protection of Human Health and th~-Environment
Alternative 1, No Action, will not provide protection from risks
associated with site contaminants. People will be directly exposed to
the contaminated soils, and groundwater will continue to degrade due
to release from the soil. Therefore, it will not be discussed any
further, since it is not protective and thus, not an acceptable
alternative.
Alternative 2 through 5 will reduce the migration of contamination
from the contaminated soil and minimize the risks associated with
direct contact with the soil. Alternatives 2 through 4 provide soil
treatment, thus reducing the amount of contaminants available to move
into the groundwater. .
Alternatives 2 through 5 will provide protection from risks which may
be associated with contaminants currently existing in groundwater by
collecting and treating the contaminated groundwater.
Alternatives 2 through 4 will bring exposure levels within an
acceptable risk range for carcinogens.
2.
ComDliance with ARARs
Alternatives 2 through 4 will comply with all applicable or relevant
and appropriate federal and state environmental standards for Operable
Unit I. No waiver would be necessary to implement these alternatives.
For alternative 5, a RCRA subtitle C multi-layer cap would be
installed in order to cQmply with RCRA cap design standards.
Clean Water Act (CWA) and NPDES requirements are ARARs for
alternatives 2,3 and 5. .
The Safe Drinking Water Act, Michigan Act 307, the Michigan Air
Pollution Act (1965 Public Act (PA) 348) and RCRA are ARARs for
Alternatives 2 through 5.
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. -
27
As discussed in Section XI below, Michigan Act 307 Rules provide that
remedial actions shall be protective of human health, safety, the
environment and natural resources and specify three cleanup criteria:
Type A, B, or C. .
Human life cycle safe concentrations, secondary maximum contaminant
level, 10~ cancer risk numbers and background were used to determine
the cleanup levels for the Act 307 Type A/B cleanup. MCLs and non-
zero MCLGs are considered relevant and appropriate to the remedial
action at the site because the aquifers may be used for drinking water
purposes.
u.s. EPA selected a Type A/B cleanup given the potential residential
use of the Site; its amenability to a clean closure; the potential
for groundwater discharge to Black Creek; the isolated nature of the
areas of high contamination in soils; the expectation of restoring
groundwater to beneficial uses; the increased permanence, reliability
and long-term certainty of protection of human health and the
environment; the increased reduction of the volume of hazardous
substances remaining on site; the presence of multiple contaminants
and multiple pathways of exposure; and the State's strong-preference
for a Type A/B cleanup. Given the presence of multiple contaminants
and multiple pathways of exposure, u.s. EPA has chosen a 10~ risk
level for carcinogens as the point of departure for determining
remediation goals consistent with the NCP.
The Land Disposal Restriction of RCRA contained at 40 CFR Part 268 are
ARARs for alternatives 2 through 5. The sludges, ashes, residues,
spent carbon, or spent coagulant/flocculent shall be treated in order
to meet LDRstandards for F001-FOOS wastes and disposed of at RCRA
landfill.
RCRA is relevant and appropriate at the Site and is applicable to
remedial activities undertaken in alternatives 2-5.
Toxic Substances Control Act ("TSCAn) is not an ARAR for this site
because the maximum level of PCB detected at the Site was 1.3 ppm,
which is less than 50 ppm.
The full listing of ARARs for the site is contained in the FS.
Section XI for a more detailed discussion of ARARs.
See
3.
Lona-Term Effectiveness and Permanence
Alternatives 2 through S all provide a high degree of long-term
effectiveness and permanence with regard to groundwater at the site by
collecting and treating contaminated groundwater and assuring that
contaminated groundwater does not impact the Black Creek. .
Alternatives 2 through 4 also provide a high degree of long-~erm
effectiveness and permanence with regard to soils ,at the site by
excavating and treating contaminated soils.
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28 .
Alternatives 2 through 5 include institutional controls which would
restrict use of property on the Site during implementation of the
remedy to the extent necessary to implement and protect the remedy,
and to safeguard human health and the environment during
implementation of the remedy. In addition, Alternative 5 require
perpetual prohibitions on residential use, groundwater use and
excavation.
Alternatives 2 through 4 will all result in a low magnitude residual
risk once treatment is completed. Each may leave some treated
residual soil contamination but at. levels which would still be
protective of human health and the environment.
Alternative 5 will reduce the chance of direct contact and migration
of contaminants into grou~dwater as long as th~-cap and slurry wall
are maintained. Because contaminants are left in place, it leaves a
moderate long-term impact on human health and the environment. The
soil will not be treated. A five-year review will be required for
Alternative 5. Reliance on maintenace and monitoring ,creates
uncertainties as to the long-term effectiveness of the remedy. If
this cap and slurry wall deteriorate, the soils will become a source
of groundwater contamination.
4.
Reduction of Toxicitv. Mobilitv. or Volume throuah Treatment
Alternatives 2 through 4 involve treatment of the principal threat,
the contaminated soil, to Michigan Act 307 Type A or B health-based
standards. Alternative 2 treats soil groups 3 and 4. Alternatives 3
and 4 excavate soil groups 1 and 2 for off-site incineration; and
treat the rest of soil groups 3 and 4. Alternative 2 (in-situ
vitrification) thermally destroys the organic compounds and
encapsulates the inorganic compounds resulting in reduction of
mobility, toxicity or volume. The incineration component of
Alternatives 3 and 4 destroys organic and PCB/Pesticide compounds and
isolates inorganic compounds for off-site disposal. Soil. flushing and
in-situ vapor extraction are utilized in Alternatives 4 and 3,
respectively, to transfer organic contamination from soil to water or
air, where the contaminants are removed using carbon or burned in a
fume-rich incinerator. Assuming the carbon is thermally treated prior
to land disposal or regenerated, these technologies also reduce'
toxicity, mobility or volume through treatment. Biological treatment
breaks down the contaminants into less toxic compounds. The soil'
component of Alternative 5 does not invalve treatment and therefore
does not reduce the contaminant's mobility, toxicity, or volume.
Alternatives 2 through 5 pump and treat the groundwater at Operable
Unit I to Michigan Act 307 standards throughout the plume(s} at this
Operable Unit.
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-
.;
-. .__.._-~ -, - ._- --_. - -.- ._-- ------------- --- .
2'
5.
Short-Term Effectiveness
Alternatives 2 through 5 include access and zoning restrictions and
would utilize equipment to control the amount of dust produced during
remedial activities.
Alternative 2 also would provide protection from exposure to the waste
during implementation because treatment would be in-situ and
excavation is minimizedj however, air emissions produced during
implementation of this Alternative would pose short-term risks to on-
site workers and nearby residents. Direct contact and exposure to
contaminated soils may occur in Alternatives 3 and 4 during excavation
of Group 1 and 2 soils.. -
.-
Alternative 4 would take the longest to implement and Alternatives 2
and 5 would take the least amount of time.
6.
Imp1ementabi1itv
The technical and administrative difficulty of Alternative 2 is
uncertain because in-situ vitrification has not been applied fully at
any Superfund site.
Alternatives 3 through 5 would be relatively easy to implement from a
technical standpoint because the components of each of these
alternatives have been used at other Superfund sites. Without
modification, the soil flushing and bioremediation activities included
in Alternative 4 make this alternative slightly more difficult to
implement because these activities can be performed during non-winter
months only. Alternative 4 would take twelve years to address the
risks posed by soils at Operable Unit Ij Alternatives 2, 3 and 5 .will
take less than 4 years. In addition, because bioremediation is a ,
relatively new technology, U.S. EPA would need to perform treatability
studies before implementing this technique at the Thermo Chem site to
ensure its effectiveness. From an administrative standpoint,
Alternatives 3 and 4 would be more difficult to implement than the
other alternatives if on-site incineration were chosen over off-site
incineration. On-site incineration would require compliance with
substantive Incinerator construction and operation requirements
contained at 40 'CFR Part 264 Subpart 0 which could delay the cleanup.
7.
Cost
Alternative 2 ($82.7 million) has the highest present net worth cost.
Alternatives 3 and 4 have comparable cost. Alternative 5 is the least
expensive of the Alternatives which address the contamination at
operable unit I. There is no major cost difference for on-site and
off-site incineration.
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30
8.
state AcceDtance
The state of Michigan concurs with the selected remedy. The state
also concurs with the analysis of ARARs with the exception of the
omission of WRC Act, MCL 323.6(a) (Act 245) and associated Part 22
Administrative Rules. u.s. EPA disagrees with-the state's position
that MCL 323.6(a) is an ARAR at this site. This issue is the subject
of litigation in u.s. v Akzo coatings of America, appellate case
numbe~s 89-2902 and 80-2137, and may be reassessed after a decision
has been rendered. The state has indicated in its concurrence letter
that the selected remedial action will provide for attainment of all
ARARs and will comply with Part 22. .
9.
Community AcceDtance
.-
The specific comments received and u.s. EPA's responses are outlined
in the attached Responsiveness Summary.
x. THE SELECTED REMEDY
As provided in CERCLA and the NCP, and based upon the evaluation of
the RIfFS and the nine criteria, the u.s. EPA, in. consultation with
the MDNR, has selected Alternative 3 as the Operable Unit I remedial
action at the Thermo Chem Site.
The major components of Alternative 3 include the following:
*
Decontamination, demolition, and off-site disposal of all
on-site buildings, including the laboratory, process
buildings, a warehouse, an incinerator, and all above-ground
.storage tanks. When this is accomplished, soil samples from
these areas will be collected and analyzed.
Excavation and off-site incineration of Group 1 and 2 soils -above
Michigan Act 307 Type A or B standards. Group 1 soils include
soil and sludge in the clay-lined disposal lagoon, test pit #1
and #8, and soil borings #3, 4, 5, 9, 10, 13, and monitoring well
#7. Group. 2 soils include soils in the area around soil boring
#3 at the Thomas Solvent Co. property. The estimated volume of
soils of Group 1 and 2 soils is approximately 2,000 cubic yards.
Transportation of the excavated soils will be conducted to meet
all federal, state and local hazardous waste shipping
requirements. The ash or residue produced from off-site
incineration will be treated to meet Land Disposal Restrictions
and placed in a RCRA landfill.
*
*
In-situ vapor extraction for all site soils to meet Michigan Ac~
307 Type A or B standards. Prior to the full-scale
implementation of in-situ vapor extraction, a pilot-scale test
may be conducted at the site to determine the number of
extraction and injection wells necessary, the spacing between
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31
AJr InJ-=ton Tow«
,.
a.t ,.
~
Vapor
Tr.ctment
Sylt.m
. ~~tcrT--
0WT*::8I Vczn
t t
If If If 11 If If If
Z '1'--........"8m .
If ~ If
00 . .
?ooo 0 .. l1'Ooo'8 I"IQ.IgI'I . .
c-,;o.T...ad8CII .
WIW T..
Gtound-wcer Ex1radIon Well
Figure 5
Selected Remedy
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32
wells, and pumping rate necessary to achieve maximum removal of
the volatile organic compounds. (See figure 5)
While the vapor extraction system is operating, a Treatability
Study will be performed to determine the appropriate amount of
nutrients (e.g., moisture, oxygen, nitrogen, and phosphate) that
would need to be added to the site soil in order to enhance the
natural breakdown of organic compounds. If u.S. EPA determines
the treatment could be implemented easily and effectively, it
will be included as part of the remedy. " "
Gases emitted from the extraction wells will be treated using
a fume-rich incinerator in order to meet the air quality
standards of the state. The liquid from the vapor extraction
process will be treated at the Site. .-
*
After completing the treatment of the soils, the site will be
covered with clean soil and vegetation, if necessary.
Groundwater from the shallow and deep aquifers will be
extracted and treated to Michigan Act 307 "Type A or B standards
using filtration, air stripping, metal precipitation, and pH
adjustment. The emitted gases will be treated to meet State air
quality standards using carbon. The carbon will be regenerated
or disposed of off-site in accordance with LDRs. The treated"
groundwater will be tested to meet the substantive requirements
under NPDES before being discharged to Black Creek. (See figure
5) All residue, sludge, spent carbons, or spent
coagulants/flocculent shall be treated to meet the Land Disposal
Restriction standards for F001-FOOS wastes and shall be placed in
a RCRA landfill in accordance with the requirement of 40 CFR
268.41.
*
Additional studies will be conducted at the site to determine
backqround soil concentration, the ability of some
contaminants to leach to the groundwater, and the existence of
other. contaminated soil. Based on the results of these
additional studies, more excavation and/or treatment may be
necessary to meet Michigan Act 307 Type A or B standards.
Institutional controls will be implemented to restrict future
development of the site to the extent necessary to implement and
protect the remedy, and to safeguard human health and the
environment during implementation of the remedy. These include
Land Use restrictions and construction of a fence around the
boundary of the site.
*
At the completion of this remedial action, Michigan Act 307 Type A or
B Standards will be attained for groundwater throughout the
groundwater plume at Operable unit I, and for soils at Operable Unit
I.
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Estimated Costs for Implementing the Selected Remedy are as follows:
Capital Costs:
Treatment Component
Estimated Cost
1} Excavation and
Off-site Incineration
of Group 1 & 2 soils
2,000 cubic yards
$ 7,200,000
2} ISVE
9.5 acres
$
820,000
3) Groundwater Collection, Treatment
and Discharge to Black Creek
$ 6,500,000
.-
Annual Operation and Maintenance Cost
$ 1,091,000
Total Costs (Present Net Worth)
$24,000,000
XI. STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of Section 121 (a)-
(e) of CERCLA, as amended by SARA, to:
c.
Protect human health and the environment;
Comply with ARARs (or justify a waiver);'
Be cost effective;
utilize permanent solutions and alternative treatment or
resource recovery technologies to the maximum extent
practicable; and, .
. Satisfy the preference for treatment as a principal. element
or'provide an explanation as to why this preference is not
satisfied.
a.
b.
d.
e.
The implementation of Alternative 3 at the Site satisfies the
requirements of CERCLA, as amended by SARA, as detailed below:
a.
Protection of Human Health and the Environment
This selected remedy will provide adequate protection of human health
and the environment through treatment.
Risk posed by soil and groundwater contamination at Operable unit
I will be reduced and controlled by the groundwater extraction
and treatment system and the ISVE system of the selected remedy.
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In addition, hot spots at Operable Unit I containing Inorganic
and PCB/Pesticide contamination will be excavated and treated at
an off-site incinerator. The selected remedy will attain
Michigan Act 307 Type A or B Standards for contaminants in the
soil and groundwate~.
No unacceptable short-term risks will be caused by implementation
of the remedy. Standard safety programs, such as fencing, use of
protective equipment, monitoring, off-gas treatment, and dust
control measures, should mitigate any short-term risks. Short
term risks include exposure of site workers and the community to
volatile organic compounds in the soils and air, and to dust and
noise nuisance during implementation of the groundwater and soil
remedies. ISVE should not present short-term ri~ks due to VOC
emission if properly designed and monitored.
b.
Compliance with ARARs
The selected Remedial Action for Operable Unit I at the Thermo
Chem Site will comply with all Federal and more stringent State
Applicable or Relevant and Appropriate Requirements for Operable
Unit I. The major ARARs are presented below.
i)
Chemical Specific ARARs.
The selected remedy will achieve compliance with Chemical
specific ARARs related to groundwater, soil and ambient air
quality at the site.
A)
Groundwater
Relevant and Appropriate requirements for groundwater include
primary drinking water standards established by the Safe Drinking
Water Act. Several contaminants of concern identified at the '
. Site have Maximum Contaminant Levels (MCLs), proposed MCLs and/or
Maximum contaminant Level Goals (MCLGs). MCLs are relevant and
appropriate to circumstances at the Site, since the aquifers are
potential sources of drinking water. MCLGs are relevant and
appropriate when the standard is set at a level greater than zero
(for non-carcinogens). The point of compliance for MCLs and
,MCLGs is throughout the plume at Operable Unit I.
As discussed in section IX, the substantive provisions of Parts 6
. and 7 of the rules promulgated under Act 307 of the State of
Michigan are considered an ARAR for the remedial action. These
rules provide, inter alia, that remedial actions be protective of
human health, safety and welfare, and the environment and natural
resources [Rule 299.5705(1)]. The rules specify that this
standard is achieved by a degree of clean-up which conforms to
one or more of three clean-up types (Rule 299.5705(2) et sea.).
Type A criteria are based on reduction of hazardous substance
levels to background or below detectable levels (Rule 299.5707).
~
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35
Type B criteria are based on reduction of hazardous substance
levels to an acceptable risk level (e.g., an excess lifetime
cancer risk of 1 x 10~ for carcinogens) using standardized
exposure assumptions (Rule 299.5709). Type C criteria involve a
site-specific assessment of risk and remedy evaluation to select
remedies which do not pose an unacceptable risk (e.g., an excess
lifetime cancer risk of 1 x 10~ of carcinogens). Remedy
evaluation under Type C criteria must include evaluation of
alternatives which meet Type B criteria. This evaluation must be
made against a variety of factors listed in Rule 299.5717.
u.s. EPA has chosen a Type A or B cleanup under Michigan Act 307.
The Type B groundwater cleanup standards for such compounds are
more stringent than the MCLs. The selected remedy will attain
Michigan Act 307 Type B cleanup standards set forth in Table 3
throughout the plumes at Operable Unit I of the Site.
B)
Soil
Relevant and Appropriate requirements for soils at the site
include Michigan Act 307 standards. As discussed in Section IX,
U.S. EPA has chosen a Type A or B cleanup pursuant to Act 307.
Type A cleanup standards are background or detection levels; Type
B cleanup standards correspond to a risk level of 10~ for
carcinogens and a human life cycle safe concentration for
noncarcinogens.
Group 1 and 2 Soils exceeding Type A or B cleanup standards set
forth in Table 2 will be excavated and incinerated and disposed
of off-site consistent with Resource Conservation and Recovery
Act (RCRA) Land Disposal Restrictions (LDR) treatment standards
contained at 40 CFR Part 268, which are applicable. Group 3 and
4 soils will be treated by ISVE to meet the cleanup standards set
forth in Table 2.
C)
Residues
All sludges, ashes, residues, spent carbons, and spent
coagulant/flocculent produced from soil, groundwater and
treatment will be treated to LDR standards for F001-F005
prior to disposal at a RCRA landfill.
air
waste
D)
Buildings
Investigations conducted at buildings at the Site revealed no
evidence of the presence of asbestos. Prior to demolition
further sampling will be conducted to detect the presence of
asbestos. If asbestos is present, relevant and appropriate
standards set forth at 40 CFR Part 61 will be followed.
-------
36
lii)
Action Snecific ARARs
The selected remedy will achieve compliance with ARARs governing
the performance of activities at the site.
A)
Manaaina RCRA Wastes
Resource Conservation and Recovery Act (RCRA) listed wastes,
including F001-FOOS spent solvents were found at the Site. RCRA
requirements are applicable to all remedial activities involving
treatment, storage or disposal of media contaminated with these
wastes, including the following components of the selected
remedy:
.
Soils containing F001-FOOS constituents can be incinerated
off site only in a RCRA permitted incinerator.
The ash from the soil and sludges containing the F001-FOOS
waste must meet LDR treatment standards. . Incinerated sludge
must meet the treatment standards in 40 CFR Part 268 Subpart
D, although incinerated soil would be eligible for a
treatability variance. After meeting the treatment
standards, the ash may be land disposed only in a RCRA
Subtitle C unit.
.
.
The fume-rich incinerator in the ISVE must comply with the
substantive requirements of 40 CFR Part 264 Subpart o.
.
Tanks used in the treatment of the groundwater must comply
with 40 CFR Part 264 Subpart J.
.
Residues such as spent carbon from the treatment of
groundwater which are regenerated must be treated in a unit
in compliance with 40 CFR Part 264 Subpart x.
Residues which contain F001-FOOS constituents such as metal
precipitates from groundwater treatment must meet the LDR
treatment standards if land disposed.
,
.
.
Corrective action must be undertaken consistent with 40 CFR
264.101.
The selected remedy complies with all of the above requirements
as well as the equivalent requirements in Michigan Rule 613 and
Public Act 64.
B)
Closure
RCRA closure requirements are relevant and appropriate because of
the presence of RCRA wastes at the site. Compliance with Act 307
Type B standards will assure the attainment of health based
standards, the prevention of leachate contamination of
-------
..
37
groundwater and the absence of a direct contact threat.
Compliance with Type B standards will achieve the requirements of
40 CFR 264.111 closure at the Site assures the attainment of
health based standards. Because groundwater at the site is
contaminated with RCRA waste, post closure monitoring is
required.
C)
UST
Underground storage tanks were removed from the Thomas Solvent
property by u.S. EPA in july 1991. The requirements of 40 CFR
Part 280 Subparts F and G are relevant and appropriate. .
D)
Air Emissions
Air Stripping, ISVE, groundwater treatment and excavation
activities will comply with Michigan's Air Pollution Act (1965
Public Act (PA) 348) and Clean Air Act requirements. Best
Available Control Technology (BACT) requires treatment of. the air
emissions from the air stripper system and ISVE. These
requirements will be satisfied through use of a vapor phase
activated carbon system to remove VOCs from the stripper air and
the use of fume-rich incinerator to burn VOCs from the ISVE. The
off-gases should be treated in order to meet PA 348 emission
limit requ~rements.
E)
Discharaes
Discharges to Black Creek from the Groundwater Extraction and
Treatment System and site run-off will comply with applicable
NPDES requirements, and the Federal Water Pollution control Act
Amendments of 1972 as amended by the Clean Water Act of 1977
(CWA), including Water Quality criteria under CWA S 304 and state
water quality standards promulgated pursuant to CWA S 303 .
F)
Workers
Michigan Occupational Health and Safety Laws, Michigan Act 154, .
and the Occupational Safety and Health Administration regulations
at 29 CFR 1926 govern working conditions.
( i i i ),
Location Specific ARARs.
The selected remedy complies with location specific ARARs. The
only activities conducted on wetlands or the floodplain at the
Site during operable unit I will be the installation and use of
wells for monitoring and groundwater extraction. The
requirements of 40 CFR 264.18(b), CWA S 404, 40 CFR Parts 6, 230
and 320 through 330, Executive Orders 11988 and 11990, and the
-------
. .
~
38
wild and Scenic Rivers Act if they become applicable or relevant
and appropriate.
c.
Cost-effectiveness
The Selected Remedy, Alternative 3 is a cost-effective
alternative providing for protection of human health and the
environment and long-term effectiveness. Alternatives 3 and 4
are slightly more expensive than Alternative 5 but provide a
significantly greater degree of long-term effectiveness.and
permanence. Because there is no treatment of soils, there is a
greater risk of contaminants entering the groungwater with
Alternative 5 over the long term. Alternative 2 is three-times
more expensive than Alternative 3 without provid~ng proportional
effectiveness. Although Alternative 2 provides complete
destruction of the contaminants in the soil, Alternative 3
provides similar effectiveness through a combination of
excavation for off-site incineration and treatment at one-third
less cost. There is no major cost difference between'
Alternatives 3 and 4, but Alternative 3 can clean up the soilS
times faster than Alternative 4.
d.
utilization of Permanent Solution and Alternative Treatment
Technoloqies or Resource Recovery Technoloqies to the Maximum
Extent Practicable
u.S. EPA, with the State of Michigan's concurrence, has
determined that the selected remedy represents the maximum extent
to which permanent solutions and alternative treatment
technologies can be util~zed in a cost-effective manner for the
Thermo Chem 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 remedies for addressing soil and,
groundwa~er contamination provide the best balance of tradeoffs
in terms of long-term effectiveness and permanence, reduction in
toxicity, mobility or volume achieved through treatment, short-
term effectiveness, implementabi1ity, cost, also considering the
statutory preference for treatment as a principal element and
considering state and community acceptance.
Alternative 3 reduces the toxicity, mobility, and volume of the
contaminants in the soil and groundwater; complies with ARARs;
provides long-term effectiveness; and protects human health and
the environment equally as well as Alternative 2 and 4. In the
long-term, Alternatives 2-4 are more effective than Alternative
5, which requires post-remedial maintenance and protection of' the
cap. Alternatives 2 through 4 each reduce the toxicity, mobility
and volume of contaminants in the soil and groundwater;
Alternative 5 contains them. In terms of short-term
effectiveness, Alternative 3 would produce less short-term risks
to the community and on-site workers during implementation than
Alternative 2 because there are far less VOCs emitted.
-------
39
Alternative 3 also can achieve protection five times faster than
Alternative 4. Alternative 3 will be easier to implement
technically because it requires less construction, and
administratively because it will require less coordination with
relevant aqencies. Finally, Alternative 3 costs five times less
than Alternative 2 while providinq the same effectiveness. The
major tradeoff that provide the basis for this .selection decision
are short-term effectiveness, implementability, and cost. The
selected remedy is more reliable and can be implemented more
quickly, with less difficulty and at less cost than the other
treatment alternatives and is therefore determined to be most
appropriate solution for the contaminated soil and qroundwater at
the Thermo Chem site. . .
The selected remedy satisfies the statutory pr~ference for
treatm~nt as a Principal Element by utilizinq the qroundwater
extraction and treatment system, the ISVE and Off-site
incineration to address the risks posed at Operable Unit I.
e.
Preference for Treatment as. a Principal Element
The principal threat at the Thermo Chem site is the contaminated
soil, due to the current and potential use of ~he contaminated
soil under recreational and residential land use. . If left
untreated, the contaminated soil would continue to leach
contaminants into the qroundwater.
The selected remedy directly addresses this threat by excavatinq
hot spots in the soil which have highly concentrated contaminants
for off-site incineration, and by treatinq the remaininq orqanic
compounds in the soil throuqh in-situ vapor extraction and
bioremediation, if necessary. In addition, the contaminated
groundwater will be treated.
-------
.' ,.
Table I
SU88ary of Risk by Expo8ure Pathways
Boil
"
Hot Soot' Soil2 Hot Spot Soil Hot Spot Soil Hot Soot Soil
Ingestion 7XIO.' 5XIO"' 2XIO" 9XI0.' 2 5 1
Dermal Contact NA 1x10" 9x10" NA 60 7
Inhalation/Vapor 6Xl0.1 1X10.1 3X10"' 3X10" NA 20
-~':!~~}_~~!2!1J..I!~!I!:._------ NA' 2X10" NA 500 I
------------- ---------- ------------- ---------- ------------- ------- ~----------- --------
Total 7 Xl 0.' 2X10.] 1X10'] 9XI0'] 2 500 90 8
Carcinogenic
Current
Future
Razard Index
Current
Future
Groundwater
Ingestion 1X10.' 1000
Dermal Contact 6X10'] 2000
-~~!.t!l_~~~_i_~~t!~J!2!_____-- 1X10.' 100
---------------------------- ----------------------------
2XI0"
Total 3000
Carcinogenic
Ra8ard Index
--
IThe term hot spot refers to the northernmost disposal lagoon.
2soil in this'table refers to all the soils except the hot spots.
..
~ means "Not Applicable."
-------
...{:::. ..
:..::.:.. .
..
. COMPOUNDS .....
.:: ... ...... :.. .:...
.. .
VOCS
Acetone
Benzene
1,2-Dichloroethene
1,2-Dichloroethane
2-Butanone
I, 1, I-Trichloroethane
I, 1,2, 2-Tetrachloroethane
Trichloroethene
4-Methyl-2-Pentanone
Tetrachloroethene
Toluene
Chlorobenzene
Ethylbenzene
styrene
Total Xy1enes
Semi-VOCB
~
1,4-Dichlorobenzene
1,2-Dichlorobenzene
2-Methylphenol
4-Methylphenol
Isophorone
2,4-Dimethylphenol
Naphthalene
2-Methylnaphthalene
Dimethylphthalate
Hexachlorobenzene
Pentachlorophenol
. .<
MAXIMUM LEVELS
TABLE - 2
SOIL CONTAMINATION
D~TECTED/SOIL CLEANUP
THERHO-CHEH SITE
SITB.CONCENTRATIONS (mg/kg)
CLAY LINER
.... .......S~IL,i} ...... TEST .,. PI~.....
1.2
ND
ND
ND
ND
2.8
0.005
37
ND
1,500
180
0.53
80
1.6
500
0.063
0.15
0.11
3
ND
0.8
2.8
2.5
0.18
0.064
3.7
1,300
19
NO
4.7
4,400
ND
ND
23
660
16
270
ND
19
ND
62
0.55
2.8
17
190
3.7
76
36
7
0.64
ND
ND
ND
NO
1.4
NO
ND
140
ND
400
ND
2,900
270
6.6
220
33
770
0.42
2.5
ND
NO
ND
ND
40
18
ND
ND
57
FREQUENCY
5/69
1/69
1/69
1/69
4/69
7/69
2/69
18/69
1/69
3/69
22/69
4/69
18/69
3/69
19/69
3/120
4/120
3/135
6/135
1/120
7/135
17/135
17/135
31120
1/120
4/120
STANDARDS
STANDARDS' .... (mg/kg):
GROUND WATER ...DIRECT}':
PROTECTION...." .... .CONTAC't:
STANDARD2 ... .....STANDARD~
10
0.020
1.0
0.008
8
2
0.004
0.060
8
0.01
2
1
0.6
0.020
1
0.020
0.1
0.8\
8
0.2
0.6
0.6.00
0.200
ND
0.00004
0.006
8,000
10
800
4
4,000
2,000
2
40
4,000
8
16,000
2,000
8,000
10
200,000
20
7,000
10,000
10,000
90
10,000
1,000
400
NO
0.8
10
;'1.
. ACCEPTABLEi BACK"".........
........ .... ... .... .. ...... . GROUNDL}.
W>L(mgjk9)~..... (m91)t~J....:..
..
..
..."
.. . .
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.010
0.330
0.330
0.330
0.330
O. 330
0.330
O. 330
0.330
0.330
0.330
1.700
.......
"... .
..
0.033
ND
ND
NO
ND
ND
ND
ND
NO
ND
ND
ND
NO
NO
ND
ND
ND
NO
ND
ND
NO
ND
ND
NO
NO
ND
-------
t,: ': ,,'
MAXIMUM
TABLE 2-(Continued)
SOIL CONTAMINATION
LEVELS DETECTED/SOIL CLEANUP
THERMO-CHEM SITE
STANDARDS
... ,.
, ,
.. ....
" ,
SITBCOHCaur.rRATtONS.. (illlg/k9T " "..... "',',' ",...."',' ,
..'. . ",,'..,.'..',.... '.',',',....'" "FREQUE~CY
SOIL1TBST.PIT:.;Ct.Ay: LIH'R ..
:~~::~:~b\76:~;~;:.:'ii:.,rJ~~C:~~:.' ".:.,i.A.:.',:.,'.'":..:.:,,.,C,.,i(rm~£g:;;:n/Tk'~g.p,:)',4'LIt,.'.,'.'.:,..,..,.'.,.,.,:.,'.,...'.,':.:,'.:,.,: .'~k~kdR6ti~D{'
STANhARD2,./,. '.,..;;STANDARD~}'. ."""'(mg/kg)r/
1 '
!
I
I
I
..'
.. . "...... ...
d'. d. ........... ''''.
... . . ... .. . . . . . . ..
. .... n.... ....
}COMPOUNDS':.".
, ,
Pesticides/PCB
Heptachlor
Dieldrin
4,4'-DDT
Aroclor-1254
0.200
0.019
0.031
1.3
ND
ND
ND
ND
ND
ND
ND
ND
4/54
1/54
1/54
6/69
0.00004
0.0000006
0.00005
1.0
.30
.080
4.0
1.0
0.0011
0.0033
0.0033
0.033
ND
ND
0.028
ND
Inorganics
Aluminum
Arsenic
Barium,
Cadmium
Chromium'
Lead
Mercury
Zinc
Cyanide
7,010 2, 720 5,650 1,31/131 1.0 NA NA 2525
5 1.3 10.1 64/131 0.0004 0.8 0.050 1.0
46 49.1 255 116/131 40 90,000 1.0 9.0
1.4 24 22.6 8/131 0.080 100 0.005 ND
33.7 978 242 126/131 0.04 1,000 0.050 4.0
11;>9 49.5 1,050 124/131 9 NA 0.125 2.0
0.29 ND 0.73 7/131 0.04 NA 0.050 ND
125 26.8 753 122/131 20 50,000 0.050 21
18.6 599 58.7 24/131 0.08 2,000 NA 1.0
1: Contaminants Detected in Soil other than Test Pit and Clay-Liner area.
~ 2: 20 Times Act 307 Groundwater Type B Standards
3: 10~ Carcinogenic Risk as Calculated Using Act 307 Type B Standards
4: As Determined by MDNR
5: Total Chromium (Standards are for hexa-chromium)
6: These standards include Surface water Standards, Rule 57(2) of part 4 of Act 245.
,NA: Not Available
'ND: Not Detected
MDL: Method Detection Limit
* If background levels are higher than standards for inorganic8, the background levels will be the standards.
I
,
,
-------
'COMPOUNDS
",
..,
VOCs (ug/l)
Acetone
Benzene
Carbon Tetrachloride
Chloroform
1,1-Dichloroethane
1,2-Dichloroethene
1,1-Dichloroethene
1,2-Dichloroethane
2-Butanone
1, 1, 1-Trichloroethane
1,1,2-Trichloroethane
1,1,2,2-Tetrachloroethene
Trichloroethene
Tetrachloroethene
Toluene
Ethylbenzene
Styrene
Xylenes (total)
Semi-VOCs
(ug/l)
1,2-Dichlorobenzene
2-Methylphenol
Naphthalene
,2~Methylnaphthalene
Bis(2-ethylhexyl)phthalate
Pentachlorophenol
Inorganic co.pounds (ug/l)
Aluminum
Arsenic
cyanide
Iron
Zinc
~ :
TABLE - 3
GROUNDWATER CONTAMINATION THBRNO-CHB8 SITB
, ,
,
..
". ."..." .." ',' -.-. .
...- -, -,.... .....' .. .
. .-, ... .n.. .... . .. ... ..
..... ".-'."...".'.'. ,",'","."..",".'. "... .". .
KCCE;TA~~~:::';;::'::Mb£." :.'::'.'~'~~~(~1~:~:j0~:'
'. . ':":.(U9/1)/:',..' ,.. ".... , ,'..',"
FREQUENCY:,:
.. STANDARDS ",'
, , (ug/ l) ,.",.",
301 (B) ' '.. '.' MCt
..
331 1,600 4/76 500 ND 5 ND
3,209 26,000 20/76 1 5 1 ND
4.0 110 3/76 0.3 5 1 ND
619 2,600 16/76 6 NA 1 ND
1,572 7,900 23/16 700 NA 1 ND
4,061 20,000 36/76 70 NA 1 ND
58 380 15/76 7 7 1 ND
270 3,100 15/76 0.4 5 1 ND
836 2,900 4/76 400 NA 5 ND
3,649 44,000 45/76 117 200 1 ND
63 200 6/76 0.6 5 1 ND
3 5 2/76 0.2 NA 1 ND
9,542 140,000 47/76 3 5 1 ND
5,960 60,000 43/76 0.7 5 1 1.0
14,835 140,000 40/76 100 1,000 1 ND
1,189 7,900 32/76 30 700 1 ND
484 1,000 6/76 1 100 NA ND
2,878 28,000 38/76 59 10,000 1 NO
75
NA
NA
NA
NA
200
5
NA
5
NA
5
2 0
ND
NO
ND
NO
6.0
ND
SITE CONCENTRATION
. . (ug/l):', ":
"AVERAGE ."',MAXIMUM
..
NA
50
200
NA
NA
NA
50
50
NA'
NA
280
ND
NO
170
1,500
5 5 1/76 7
24 58 20/76 40
58 660 26/76 29
16 150 15/76 10
431 4,500 11/76 2
17 27 2/76 0.3
272
12
55
2,941
522
3,210
132
315
21,500
3,720
20/76
37/76
14/76
45/76
55/76
50-200
0.02
4
300
80
307(B): Act 307 Type B standards for the
MCL: Maximum Contaminant levels f6r U.s.
ND: Not detected
MDL: Method Detection Limit
* If background levels are higher th~n standards for inorganics, the background levels will be the standards.
state of Michigan
EPA's drinking water standards
NA: Not Available
-------
~
RESPONSIVENESS StJXHARY
THERMO CHEK SITE
OPERABLE UNIT. I
MUSKEGON COUNTY, XICHIGAN
PURPOSE
This responsi veness summary, required by the Superfund Law,
provides a summary of citizen's comments and concerns identified
and received during the public comment period, and u.S. EPA's
responses to those comments and concerns. All comments received by
u.S. EPA during the pUblic comment period have been considered in
the selection of the remedial alternative for the site. The
responsiveness summary serves two purposes: It provides u.S. EPA
wi th information about community preferences and concerns regarding
the remedial alternatives, and it shows members of the community
how their comments were addressed. .-
This document summarizes written comments received during the
public comment period of July 11 to September 9, 1991. The public
meeting was held at 7:00 p.m. on July 16, 1991 at Egelston Township
Hall, Muskegon, Michigan. Several comments were submitted during
the public meeting.
OVERVIEW
The preferred alternative for the Thermo Chem site was announced to
the public just prior to the beginning of the public comment
period. The selected alternative includes:
*
Demolition and off-site disposal of all on-site structures;
* Excavation and off-site incineration of Group 1 and 2 soils;
*
In-situ Vapor Extraction of all site soils;
off-gas treatment through fume-rich incinerator;
*
* Groundwater collection and treatment with discharge to Black
Creek.
PUBLIC COMMENT AND AGENCY RESPONSE
Comments received during the public comment period on the FS and
Proposed Plan for the preferred remedy along with U. S. EPA' s
responses are summarized below. Comments and responses have been
divided into three sections. The three sections are as follows:
A.
Summary of comments received during the public meeting,
July 16, 1991;
Summary of comments submitted by the public during the
public comment period; and
B.
-------
2
C.
Summary of comments submitted by the PRP Steering
Committee.
The comments below have been paraphrased in order to effectively
summarize them in this document. Copies of the public meeting
transcript and written comments are available for review at the
public information repository.
.A.
SUKKARY OF COHKENTS RECEIVED DURING THE PUBLIC KEETING,
. JULY 1', 1"1
Comment: One resident inquired whether the structures located on-
site could be relocated off-site and reused. .,He also inquired
whether site itself could be reused after completion of the remedy.
Response: The on-site structures, including laboratory buildings,
warehouse, incinerator, storage tanks and underground pipelines
will be decontaminated and demolished for off-site disposal. This
part of the remedy is necessary in order to determine the
contamination problems in the soil beneath the on-site structures
and to implement the selected remedy at the Site. However, some of
these structures such as process buildings, equipment and storage
tanks could be relocated off-site for reuse after such structures
are decontaminated and pass the Wipe Test approved by U.S. EPA.
The incinerator located on-site is outdated and may not comply with
current incinerator standards. After Operable Unit I of the site
is cleaned up to cleanup standards for both soil and groundwater,
it can be reused as an industrial or even a residential area.
Comment: One resident asked if a treatability study for the
selected remedy will be conducted .in order to ensure the remedy
will work. .
Response: During the Remedial Design for the selected remedy, U.S.
EPAmay conduct treatability studies and/or pilot tests for several
components of the ISVE and groundwater extraction system. While the
ISVE is operating, U.S. EPA will perform a treatability study to
determine the appropriate amount of nutrients (e.g., moisture,
oxygen, nitrogen and phosphate) that would need to be added to site
soils in order to enhance the natural breakdown of organic
compounds. If U. S. EPA determines that this treatment is feasible, .
it will be included as part of the remedy. In addition, U.s. EPA
may conduct a pilot-scale. test of the ISVE before conducting fu11-
scale ISVE to determine operation parameters such as the number of
extraction wells and pumping rate required in order to achieve
cleanup standards. With regard to the Groundwater Extraction
System, a treatability test may be performed to determine the
design parameters of the treatment system in order to meet the
discharge limit and to evaluate the optimum pH and
coagulant/flocculent dosage for the metals removal.
-------
3
Comment: One commentor wanted a future assessment of natural
resources damages by this site and any other sites that may be
contributing to contamination at Muskegon Lake and Mona Lake.
Response: Muskegon Lake is not connected to the site. Natural
resource damage assessments are conducted by the state and/ or
Federal Natural Resources Trustees. u. s. EE:'A will determine
whether Black Creek, which is located approximately 1500 feet South
of the site, is impacted by groundwater contamination from the site
in operable unit II. In July 1991, several sediment and surface
water. samples were collected from Black creek to determine the
contamination problem. If the results of these samples indicate
that Black Creek is impacted by the site, then u.S. EPA will
determine the extent of this contamination. It may be that the
contamination from the Site reaches Mona Lake. u.S. EPA will also
determine whether the bio-community such as .fish, plants and
animals'may be affected by contaminants from the Site.
Comment: The same comment or expressed concern with the
utilization of off-site incineration and its effect on the people
hosting the incinerator.
Response: At this time, u.s. EPA does not know the off-site
incinerator to which the soils from the site will be sent.
However, the soils must be sent to a licensed RCRA incinerator
acceptable for receipt of such waste. The facility the waste is
sent to will be subject to RCRA regulations, and must be acceptable
under the Off-site Policy. ' For a facility to be acceptable under
the Off-site Policy it must, among other requirements, be in
compliance with any applicable State or Federal Laws, including
RCRA. The purpose of the off-site policy is to avoid having CERCLA
wastes contribute to present or future environmental problems by
directing these wastes to facilities determined to be
environmentally sound. Ashes and residues generated from the
incineration of site materials will be treated to meet Land
Disposal Requirements at 40 CFR Part 268, prior to land disposal in
a RCRA landfill. ' ,
Comment: An Attorney for the PRPs expressed reservations about
attaining Type-B criteria in a 30-year time period at this or any
site.
Response: U.S. EPA believes that most of the contaminants found in
the groundwater at the site can be cleaned up to Type B standards
within 30 years using a groundwater extraction system which
includes air stripping and metal precipitation. However, in the
case of Arsenic, it is difficult to say at this time whether
Arsenic can be cleaned up to type A or B levels using current
technology. '
.J
-------
4
Comment: One Commentor suggested capping or entombing the
contaminants without expending cleanup funds. His suggestion was
to cap the contaminants over, and keep people off.
Response: Alternative #5 contains a RCRA cap over contaminated
areas, and a slurry wall. U.S. EPA evaluated this alternative
against the other alternatives with regard to the nine criteria.
Although Alternative #5 is slightly less expensive than the
selected remedy, it is not as protecti ve as al ternati ves which
treat the source of contamination. It is also possible that the
cap and slurry wall will deteriorate in, the future and the
contaminated soil will act as a source of groundwater
contamination. The remedies which treat the soil achieve more
long-term permanence and protectiveness.
Comment:
One Commentor felt that the Site sho~ld be fenced off.
Response: The Site will be fenced off with a six-foot high chain
link fence topped with three-strand barbed wire during remediation.
Comment: The same commentor also felt that wildlife should be a
' priority and wanted an investigation of what was happening with the
foodchain and the Creek and its inhabitants.
Response: An investigation into the effects of the Site on Black
Creek is underway. If sediments and surface samples collected from
Black Creek in July 1991 indicate that the Site has contaminated
Black Creek, then u. S. EPA will conduct a biological impact
assessment including impact to fish, animals and plants around
Black Creek. T~ese concerns will be addressed in Operable Unit II.
Comment: One Commentor expressed concern about air emissions in
the Muskegon area, requested monitoring and asked that we consider
the chemical makeup of the air in the county in any kind of cleanup
plan implemented.
Response: The Selected Remedies require that emissions from on-
site treatment components and excavation be treated to Clean Air
Act and Michigan Air Pollution Act '(1965 Public Act 348) Standards.
Gas emissions from ISVE systems will be treated using a fume-rich,
incinerator, and vapor emissions from air stripping will be treated
through a carbon adsorption process. During implementation of the
selected remedy, u. S. EPA will perform air emission monitoring'
throughout the site.
.
B.
SUMMARY OF COMMENTS SUBMITTED BY THE PUBLIC DURING THE
PUBLIC COMMENT PERIOD
Comment: One commentor related the history of a well located 1500
feet South of Black Creek. According to this commentor, the water
.
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5
in this well was good in the 1950's, bad in 1980's and, after a new
well point was installed deeper in 1990, OK again.
Response: This ROD addresses contamination problems in the soil
and groundwater up to the discharge point at Black Creek. The well
located 1500 feet South of Black Creek is not part of this
response. However, during Operable Unit II investigations, U.S.
EPA will investigate whether the contaminants. from the Site reached
this well.
Comment:
exchanges:
. u.s. EPA's statement that an imminent danger at the Site was
the possibility that a child could trespass and eat dirt
contaminated with something; .'
A comment or questioned the following public meeting
. The change in U. S. EPA' s position regarding the need for
removal of soil at the Thomas Solvent Property after the removal of
the underground storage tanks;
.
The ground layouts were out of scale and wrong;
. The ground was said to be contaminated with cyanide, lead,
arsenic and other metals although such materials were allegedly not
handled at the location, and the response was incoherent;
. The incorrect impression given that 200 drums left at the site
were left by Thomas/Thermo Chem, the lack of markings on such
drums, and the waste of time and money involved in incinerating
these drums, which contained contaminated soil and gloves from test
boring instead of treating them with total Site soils;
. Much time was spent on alleged residues found along Black
Creek although there is no easy access to the creek which is at
least 1/4 mile from any activity;
. If a surface or groundwater problem exists, the .landfill
across the lake and Lakeway should also be suspect;
. To spend money cleaning up any possible minor residues here is
a complete waste; EPA should clean up Mona Lake and Muskegon Lake
~hich have higher residues; representatives could not provide a
relative comparison of any potential dangers at this site to other
sites in the area, state, or countiy;
.
.
The criteria used to evaluate this site were flawed;
. .Representati ves were unaware of any new state of the art
techniques for clean up;
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.0
6
. A clean up will never be successful until an agreeable
definition of how good is good and how bad is bad is made;
. None of the proposed alternatives are viable or realistic and
the cost estimates are outrageous.
Response: A review of the Administrative Record contains a more
complete response to the questions raised than can be answered in
brief public meetings.
. .
. The Remedial Investigation (RI) Report, for instance, contains
a detailed discussion of the scenarios u. s. EPA considers in
assessing risk. The potential effects of contaminants on a child
eating dirt from the site is a recognized r.isk in a future
residential scenario.
. The Technical Assistance Report indicated high levels of
groundwater contamination which suggested soil contamination as
well on Thomas Solvent Co. property. In fact, pure solven~ product
was discovered in a well 100 feet downgradient from the tank farm
area during the investigation. This indicated that the tanks had
been or were leaking. Analysis of the tanks upon removal indicated
that they were not currently leaking. This does not mean that they
did not leak in the past. It is also possible that chemicals leaked
during the loading and unloading process in the tank farm area.
The sandy nature of site soils is such that the contaminants could
pass through the soil to the groundwater without leaving a major
trace in the soil.
. The figures included. in the proposed plan were developed in a
not-to-scale format in order to provide the reader a quick glance
at the positions of site structures. More accurately scaled and
detailed figures can be found in the RI and FS reports.
. The RI report and the Technical Assistance Report document the
presence of inorganic compounds, including cyanide, lead, and
arsenic at the site above local background levels. For example,
lead was found in the on-site clay lagoon at a concentration of
1,050 mg/kq.
. The drums located on-site contain mostly cutting soils and.
decontaminated water. These drums were marked, dated and fenced.
.There were also drums containing hazardous materials which were
extracted from the 16 excavated underground storage tanks. These
drums, labelled as hazardous material were stored at the site
during analysis of the contents of the tanks, and disposed of off-
.site once the results of analysis were reviewed. u.S. EPA did not
incinerate drums containing contaminated soils and gloves from test
borings or any other drummed materials. However, the selected
remedy does call for the future excavation and incineration of Hot
spots of soils at the site.
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..
7
. with regard to contamination of Black Creek, the avenue for
contamination of this Creek by the Site is the groundwater. U.S.
EPA is currently investigating whether groundwater contaminated by
the Site has reached and impacted Black Creek.
. This investigation around
potential for other sources.
. U. S. EPA does not consider the contamination at this si te
minor and has determined remedial action is required to protect
human health and the environment.
Black
Creek will
examine
the
. The investigations conducted were aimed at determining the
nature and extent of contamination at this particular site.
Information about other superfund sites in Michigan can be obtained
from the Region V Office of Public Affairs.
. The commentor did not specify his objections to t~e evaluation
of the site, or any particular state of the art technique he felt
should have been considered.
. The Site will be cleaned up to clean-up standards which are
based on health-based standards and ARARs. The Site can be defined
as "clean" if it is cleaned-up to these clean-up standards.
. The Alternatives evaluated have been successfully implemented
at other Superfund sites. The costs of the selected remedy is
comparable to costs for such a cleanup at other Sites. One cost
estimate (Alternative 5) was revised downward based on a
clarification of the assumptions.
Comment: This commentor felt U.S. EPA should consider the
following alternative: remove all "hot spots" a'nd any solvent
floating on the water table, treat highly contaminated water, fence
off contaminated areas, buy neighboring properties if contaminated,
prohibit drinking water wells and residences and identify the site
. as a permanent contaminated site.
Response: The selected remedy includes the removal of hot spo~
soils for off-site incineration. As suggested by this commentor,
clean-up and performance standards are required to establish the,
manner and end-point of a clean-up. They are also required by
Applicable or Relevant and Appropriate Requirements, including
Michigan Act 307, RCRA and Safe Drinking water Act (SDWA) MCLs. It
-is the expectation of the SDWA and the NCP that groundwater will be
returned to beneficial uses. The CERCLA and the NCP also expresses
a preference for treatment. The commentor's remedy would not
comply with ARARs and would be inconsistent with the NCP. This
proposal only addresses highly contaminated groundwater. It also
leaves contaminants in the soil which could further contaminate the
groundwater. U. S. EPA did evaluate a soil containment al ternati ve.
Alternative #5 called for capping of site soils with fencing and
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8
insti tutional controls such as perpetual prohibi tions on
residential use and drinking water wells. U. S. EPA chose the
selected alternative, however, based on an evaluation of the nine
criteria set out in the NCP. It is also more productive to treat
non-hot-spot soils with the ISVE, and render the site amenable to
residential and industrial use and eliminate the. need for long-term
maintenance of a cap.
Comment: Another commentor opposed incineration of highly-
conta~inated hot spots in the selected remedy for the following
reasons:
. There is an unknown impact of incineration-on health and the
environment. Emissions contain toxic, persistent, and
bioaccumulative pollutants which pose a serious'health threat to
humans. and animals. These emissions threaten more than the
immediate area, could be dispersed across the hemisphere and may
end up in the waters and sediments of the Great Lakes. .
. The EPA should study the impact of incinerators on public
health if it believes so strongly in this technology.
. There are no methods developed for direct monitoring of an
incinerator. No sampling and analysis techniques exist to identify
and quantify many of the potential compounds emi tted, toxici ty
data is not available for all compounds, and there are no methods
for identifying products of incomplete combustion.
. A destruction and removal efficiency of an incinerator
determined by the trial burn is not a reliable indicator of an
incinerator's impact on health and environment because it does not
include other routes of chemical releases. such as fugitive
emissions, deposition in residues, unburned chemicals, heavy
metals, and newly formed chemicals or PICs. The 4-nines standard
does not mean that 99.99 percent of the chemical was actually
destroyed.
Response: Incineration is recognized as an acceptable treatment
technology in appropriate circumstances. Incinerators ar~
extensively regulated by RCRA. U.S. EPA will send its wastes to an
incinerator which complies with RCRA and other applicable Federal.
and State laws. For contaminated soils from the Site, it is
believed that the. organic compounds and pesticides will be
destroyed in the incinerator. Inorganic compounds such as arsenic
and lead would remain in the ash with minimal air pollution effect.
The ash will be treated to meet Land Disposal Restriction
requirement.
Comment: This Comment or questions u.s. EPA's motives for sending
soils to an off-site incinerator when the State is bringing a
portable kiln to the nearby Bofor's site. .
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..
9
Response: U.S. EPA evaluated Alternatives 3 and 4 with both off-
site and on-site incineration for hot-spot soil. An On-site
incinerator must be constructed in a manner consistent with RCRA
performance standards. U.S. EPA will comply with RCRA incinerator
requirements for th~ fume-rich incinerator utilized in the ISVE.
However, requirements for the incinerator needed to incinerate hot
spot soils are much more extensive and make the remedy more
difficult to implement. Therefore, off-site incineration can be
implemented more easily. with the estimated soil volume of 2,000
cubic yards, there is no cost difference between on-site and off-
site incineration. u.S. EPA will send the excavated soils off-site
to an already estabJ..ished and approved facility which is in
compliance with RCRA.
Comment: This commentor urged U.s. EPA to look at other options
for soil destruction even at more cost.
Response: In Alternative #2, U.S. EPA considered in-situ
vitrification. The costs involved are roughly three times the
costs of Alternatives 3, 4 or 5. In addition, difficulties have
been encountered in the implementation of in-situ vitrification
technology. This is a new technology which raises many
uncertainties in implementation.
C.
SUMMARY OF COMMENTS SUBMITTED BY THE PRPs
u. S. EPA is only responding to comments on the remedy, not
. liability, and makes no representations as to the PRPs rendition of
the facts or law.
Comment: The Thomas Solvent PRPs questioned the need for a
treatability study to determine the amount of nutrients to be added
to soil. to enhance biodegradation.. According to these PRPs, the
chlorinated chemicals at the site are not amenable to aerobic
degradation and the chemicals that are aerobically biodegradable
can be easily volatilized from the soils using the vapor extractio~
system. .
Response: The ISVE will remove volatile organic compounds from
contaminated soil to cleanup standards. However, U.S. EPA is not
fully assured that the ISVE will remove semi-volatile organics to
cleanup standards. The purpose of conducting a treatability study
during the full-scale implementation of the ISVE is to determine
whether injection of nutrients such as oxygen or nitrate will
promote the naturally occurring bioactivity in the soil in order to
break down semi-volatile organic compounds. If the treatability
study indicates that this treatment component is feasible, u.S. EPA
will utilize the enhancement of biodegradation during the ISVE.
,
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...;
1.0
U.s. EPA does not believe this component will increase the cost of
the remedy significantly.
Comment: The Thomas Solvent PRPs found no cleanup goals in the
Feasibility Study or the Proposed Plan. They did not read the
human health standard of 10-6 for carcinogens and a 1.0 hazard
index for noncarcinogens or the Michigan Act 307 Type B standards
in Tables 3 and 4 as clean-up levels.
Response: The Michigan Act 307 Type B standards correspond to a
human health standard of 1.0~ excess cancer risk for carcinogens and
a human life cycle safe concentration for noncarcinogens. Set out
in Tables 3 and 4 of the proposed plan, these Type B standards or
background and detection limits (Type A) are considered by U.S. EPA
and MDNR to be the appropriate clean-up levels for Operable Unit I
at the Site.
Comment: The Thomas PRPs did not feel the Feasibility Study
considered the possibility of a Type C Clean-up under Michigan Act
307, and states that if remedial alternatives had been evaluated
with respect to Type C clean-up levels, a more cost-effective
remedy could have been selected.
Response: Alternative #5 was a containment cleanup. This remedy
would have to comply with Type C in order to comply with Act 307.
However, an evaluation of other criteria such as protectiveness,
long-term effectiveness and reduction of toxicity, mobility and
volume through treatment recommended the selected Alternative.
Type A/B cleanup, not a Type C cleanup, is appropriate for the Site
and is the best at achieving the nine evaluation criteria contained
and the expectations and goals of the NCP, considering:
.
.
.
.
.
.
.
the potential residential use of the Site;
the potential use of the aquifers for drinking water;
.
.
the increased
certainty of
environment;
long-term
and th~
reliability and
of" human health
permanence,
protection
the potential for groundwater discharge to Black Creek;
the increased reduction in the volume of hazardous
substances remaining on site;
the State's strong preference for a Type A or B cleanup;
the CERCLA mandate to use permanent solutions to the
maximum extent possible;
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11
.
the restoration of groundwater to beneficial uses; and
the presence of multiple
pathways of exposure.
u.s. EPA has determined that ISVE, offsite incineration of hot spot
soils and groundwater Extraction and treatment is a cost-effective
alternative which provides the best balance of the nine-criteria.
Containment of the source without treatment does not satisfy the
statutory preference for treatment as a principal element of the
remedy.
.
contaminants
and multiple
Comment: The Thomas PRPs pointed out that oxidation processes for
groundwater treatment was dropped out without any reasons in
Development and Screening of Remedial Action Alternatives of the
Feasibility study. According to the PRPs, the oxidation technique
using ultraviolet rays can present a considerable cost savings over
air stripping/carbon.
Response: The Chemical oxidation technique, which. included
oxidation with ultraviolet rays, was identified as one- of the
viable technologies for treatment of groundwater in the early
phases of the Feasibility study. However, thi~ technique was
dropped in development and screening of remedial action because
organic compounds in groundwater can be treated through air
stripping and inorganic - compounds can be treated through the
precipitation with lime. EPA welcomes any additional treatability
study information the PRPs can provide demonstrating that this
technology provides greater benefits than conventional treatment.
Comment: The Thomas PRPs questioned the capital cost estimate of
$2.6 million for groundwater treatment. .
Response: These costs are needed to clean up the
compounds, including Arsenic in groundwater using
precipitation tank. .
Comment: The. PRPs did not believe the data supported the statement
in the Fact Sheet that EPA was studying ways to correct the
contamination problems the site has caused in Black Creek. The'
PRPs felt it has not been proven that the site had a detectable
~mpact on Black Creek, and stated that there was no acknowledgement'
of alleged impact by other sites on Black Creek. According to the
PRPs, the investigations being conducted this year are to determine
whether site operations have impacted the Creek.
-
inorganic
a. metal
Response: During the investigation at the site, contaminants were
detected in monitoring wells downgradient of the site, located 200
feet North of Black Creek. Based on this information and
hydrogeologic data obtained during the investigation, u. S. EPA
believes that contaminated groundwater from the Site has reached
the discharge point of Black Creek. However, U. S. EPA hereby
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1.2
states that it has not yet concluded that Black Creek has been
impacted by the Site. As the Proposed Plan notes at page 1.1., "U.S.
EPA currently is conducting further studies to determine whether
the. contamination has, in fact, reached Black Creek." These
studies will also examine the possibility of contamination from
other sources. At this time, u.S. EPA does not know whether other
sites have impacted Black Creek.
Comment: The PRPs object to the statements made in the fact sheet
and the proposed plan that drums containing hazardous chemical
wastes were removed from the site in 1.988. According to the PRPs,
the materials removed consisted of laboratory reagents in their
original containers stored in the laboratory building at the Site,
and the jars and bottles were packed by a U.S.EPA contractor into
larger drums for transport and handling. The PRPs feel that the
statement is misleading with respect to the condition which the
materials were stored on the site and with respect to the character
of those materials. .
Response: On Auqust9, 1988, U.S. EPA conducted a site assessment
and recommended that a removal action be implemented. The
investigation observed that the buildings on site were not
restricted and access could be gained through doors and broken
windows. U.S. EPA also observed and inventoried 330 containers of
various chemicals and solvents in the laboratory and drums
containing borax, sulfuric acid, and sodium hydroxide in the
manufacturing buildings on site. U.S. EPA determined the
laboratory chemicals left at the abandoned buildings combined with
the proximity of the buildings to a residential areas presented a
threat of imminent and substantial endangerment to human health and
the environment. Therefore, U.S. EPA removed approximately 43
laboratory packs (acids, bases, flammable, and poisons) off-site
for incineration. Four drums of hazardous waste solids (bases) and
one drum of hazardous waste liquid (corrosive) were transported
off-si te for treatment and disposal. Abandoned and disposed
. hazardous chemicals are considered hazardous chemical wastes.
,
Comment: The PRPs object to the fact sheet statement that the
field work will include studying ecological impacts of the
contamination on wildlife, plants, and organisms. They say that
the work currently planned for the Black Creek area does not
include a study of ecological impacts, and the work to be conducted.
during the summer of 1991. is determine (sic) whether or not any
impact could potentially exist. .
Response: The PRPs are correct in noting that the current field
work does not include a study of ecological impacts. The Proposed
Plan at page 8 does not include such a study. If Black Creek is
contaminated, an ecological impact study will be conducted.
Comment: The PRPs object to the statement made in the proposed
plan that sixteen underground storage tanks were located on the
.J
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13
Thomas Solvent Company property and were used to store these
recycled materials. The PRPs feel this statement is inaccurate and
misleading and cite a 1984 Pollution Incident Prevention Plan
(PIPP) prepared by Thomas Solvent Company as only identifying two
tanks containing recycled material.
Response: The PIPP's only description of the co~tents of the tanks
is a listing of compounds next to tank numbers. Contrary to the
PRP's assertion, there is no reference in the PIPP as to use of the
materials in the Tanks or any characterization as "commercial" or
"product." Because only two of the items listed have "recovered"
preceding the names, the PRPs have concluded that only two tanks
stored recycled materials. The PIPP listing did not correspond to
the sampling results from the tanks. However, u.s. EPA's statement
may be overly broad. While u.S. EPA has evidence that recycled
materials were placed in the tanks, it does not' follow that such
materiais were placed in all of the tanks. Accordingly, u.S. EPA
has corrected this statement in the ROD at page 4.
Comment: The PRPs object to the conclusion "at least 22 of those
chemicals are designated as hazardous waste". This statement is
said to be taken from a 1991 Metcalf and Eddy report which is said
to list commercial products produced and sold ~y Thomas Solvent.
Response: The list referred to above although labelled a "Products
List," includes materials sent to the Site for treatment or
disposal as well materials which came out of the site. u.s. EPA
has reviewed waste transaction documents and found hazardous wastes
a defined by RCRA as well as hazardous constituents. At page 4,
U.S. EPA has deleted the number of hazardous wastes. .
Comment: The PRPs object to the Statement that the scope of the
contamination. listed as the Thermo-Chem, Inc. on the NPL
encompasses the Thomas Solvent Company property. The PRPs state
that data documents that there is a defined plume for Thomas
Solvent which is distinguishable from the Thermo Chem plume, and
argue that it is the contamination discovered on the Thomas Solvent
property encompasses or impacts the Thermo Chem property and not
vice versa. They feel u.S. EPA's statement implies that
contamination of Thomas Solvent is a result of Thermo Chem. .
Response: While it is true that contamination at Thomas Solvent.
may have resulted from Thermo Chem operations, the statement cited
merely refers to the.fact that the contamination noticed on the NPL
listing encompasses both the Thermo Chem, Inc. Property and the
Thomas Solvent Company property. A clarification to this effect
has been made at pages 5 - 6 of the ROD.
Comment: The PRPs request that u.S. EPA clarify that it is the
ground water table which is encountered, not the top of the
aquifer, from 17 feet to 32 feet below ground surface.
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..
14
Response: The PRPs are correct in pointing out that it is the
groundwater table, not the upper aquifer, which lies from 17 feet
to 32 feet below the ground surface. This has been clarified on
page 9 of the ROD.
Comment: The PRPs request that u.s. EPA present the necessary
assumptions and calculations to support u.s. EPA's estimation that
approximately 100 gallons per minute of groundwater discharges to
Black Creek.
Response: Based on the local hydrogeologic data and the thickness
of shallow aquifer, u.s. EPA estimated that groundwater discharges
to Black Creek at a rate of approximately 100 gallons per minute
from the Site. However, U.S. EPA recognizes that such calculation
is premature at this time without conducting further investigation,
i.e. pump test, around Black Creek. Therefore, U.S. EPA deleted
this calculation from the ROD on page 9.
Comment: The PRPs felt that insufficient investigations had been
conducted to limit Group 2 Soils to the area around soil boring 3,
and that Group 4 soils have not been delineated. They note that
U. S. EPA did not detect any contamination beneath the removed
underground storage tanks and that the Technical Assistance Study
documented a significant groundwater contamination plume in the
vicinity of the underground storage tanks.
Response: U.S. EPA conducted a Technical Assistance investigation
at Thomas Solvent to determine the nature and extent of the
contamination problem. 166 soil-gas samples were collected at
Thomas Solvent and analyzed for volatile organic compounds. This
soil-gas survey was conducted to determine possible source areas,
the extent of contamination in the soil and groundwater, and to
assist with locating soil borings at the Thomas Solvent Property.
Based on soil/gas results, five soil borings were drilled and
sampled at this 1.5 acre property. (For the locations of soil
borings, see the Technical Assistance Report.) Each soil boring
was sampled every two feet to a.depth of 16 feet. B~sed on the
results of the soil samples, soil boring #3 was considered a hot
spot. This soil boring contains high levels of organic an~
inorganic compounds and PCBs, including 1,500,000 ug/kg PCE, and
1,300 ug/kg PCB. The absence of soil contamination beneath the,
underground storage tanks at the time of the removal does not mean
that these soils were never contaminated. The sandy nature of the
soil may have allowed contaminants to pass through to the
groundwater without retaining residues. The fact that we
discovered pure solvent product in a downgradient well located 100
feet south of the tank farm area indicates the possibility of
leaking or injecting of contaminants during the loading and
unloading process or releases from the underground storage tanks.
Comment: The PRPs obj ect to U. S. EPA' s expans ion on the PRP
prepared FS to address the Thomas S~lvent Property, and to require
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15
a pilot test. The PRPs also feel that the cost estimates do not.
incorporate u.s. EPA's expansion on the FS.
Response: While u.s. EPA agreed in the Consent Order not to have
the PRPs conduct RIfFS activities at the Thomas Solvent property,
and the PRP generated FS consequently limi ted the Therm Chem
property, u.S. EPA conducted its own investigation to determine the
nature and extent of the contamination at the Thomas Solvent
Property. u. S. EPA utilized the Technical Assistance Report
findings to categorize the soil at the Thomas Solvent Property.
Since" Thomas Solvent contains similar contaminants at similar
levels as the Thermo Chem property, u.S. EPA determined that it is
appropriate to consider the alternatives evaluated in the
feasibility study for Thermo Chem property at the Thomas Solvent
property. .
u.S. EPA is uncertain about the effectiveness of'the ISVE to treat
semi-volatile organic compounds to clean-up standards. The purpose
of the bioremediation pilot test is to establish whether the
injection of nutrients during a full-scale ISVE will promote
naturally occurring bio-activity in order to degrade semi-volatile
organic compounds. If the treatability study indicates that it is
feasible, this injection of nutrients can be incorporated into the
remedy to treat semi -VOCs to clean-up standards without maj or
system modifications or a significant increase in cost.
since the FS prepared by the PRPs for the Thermo Chem .Site has
calculated costs for each alternative for a range of volumes of
soils, and since the addition of Thomas Solvent Property soils to
the soils to be addressed at the Thermo Chem property falls within
the "range upon which the cost estimate was based, the estimate for
applying the alternatives to both properties at the site would be
consistent with the estimates provided in the FS. For example, the
FS estimated costs for alternative #5 for an area of soil ranging
from 0.7 acres to 18 acres. The site, including both the Thomas
Solvent Property and the Thermo Chem property, contains an area of
only 9.5 acres. The estimated costs for off-site incineration of
hot spot soils in Alternatives 3 and 4 were based on a ~ange of
volume from 400 cubic yards to 2,000 cubic yards. The selected
remedy, which addresses both properties, calls for excavation of
approximately 2,000 cubic yards. The cost of groundwater treatment
may increase from the estimates provided for the limited area of'
the Thermo Chem property addressed in the FSi but this increase
will not be significant. The maj~r part of groundwater cleanup
costs, Operation and Maintenance costs, will not be affected.
Comment: The PRPs argue that because of the incorrect technical
and legal conclusions, the most significant of which pertains to
u.S. BPA's decision to require the Thermo Chem PRPs to undertake
remediation of the Thomas Solvent property, u.S. EPA's proposed
remediation of the Thermo Chem site as set forth in the Proposed
Plan must be revised.
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16
The PRPs argue that, u.s. EPA is attempting to combine two separate
facilities into one facility, and that u.s. EPA does not have a
valid basis for combining the two facilities. The PRP position is
that U.S. EPA is expanding the site to cover a wholly different
release originating from a separate parcel of property upgradient
from the originally defined Site. They cite Washinaton state
DeDartment of TransDortation v. u.s. EPA 917 F.2d 1309 (D.C. Cir.
1990) to support an inverse proposition that if a Site is named
after an industrial plant as opposed to a geographical location,
the NPL site does not give notice that any property other than the
namesake property would be included in the NPL site. . The PRPs
contend that the Thomas Solvent Facility is an independent,
upgradient source of contamination for which the Thermo Chem PRPs
have no liability.
.-
Response: Data obtained during the RIfFS at Thermo Chem and the
Technical Assistance study at Thomas Solvent revealed that Thomas
Solvent was a source of contamination identified as the Thermo Chem
Site in the NPL listing. The HRS package for the Thermo Chem site
includes all groundwater contamination at the Thermo Chem property,
including the contamination emanating from the Thomas Solvent
property. A full reading of 56 Federal Register 5600 - 5601
explains the inclusion of the Thomas Solvent Property: .
" Facility [Site] Boundaries. The NPL does not
describe releases in precise geographical terms.... the
purpose of the NPL is merely to identify releases of
hazardous substances that are priorities for further
evaluation. The names of sites are provided for
identification purposes only; the sites are not limited
to (or coextensive with) the boundaries of properties
that may be referred to in the name. Of course, HRS data
upon which listing is based will, to some extent,
describe which release is at issue; that is, the NPL site
would include (but not be limited to) all releases
evaluated as part of that HRS analysis (including
noncontiguous releases evaluated under th~ NPL
aggregation policy, see 48 FR 40663 (September 8,1983.)
.
Identifying a release or facility on the NPL provides
notice that the entire facility will be addressed; the
facility includes the source or sources of contamination
and. any area where a hazardous substance release has
"come to be located" (CERCLA section 101 (9). The listing
process is not intended to define or reflect the
"boundaries" of such facilities or releases. In fact,
CERCLA does not refer to site "boundaries," and that term
has little or no legal significance.
The NCP does provide that the nature and extent of the
threat presented by a release will be determined by an
RIfFS as more information is developed on site
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17
contamination [40 CFR JOO.4JO(d} (2) (55 FR 8847, March 8,
1990)]. During the RIfFS process, the release may be
found to be larger or smaller than was originally known,
as more is learned about the source and the miqration of
,the contamination. However, this inquiry focuses on an
evaluation of the threat posed; the boundaries of the
release need not be defined, and in any event are
independent of listing. Moreover , it generally is
impossible to discover the full extent of where' the
contamination "has come to be located" before all
necessary studies and remedial work are completed at a
site; indeed, the boundaries of the contamination can be
expected to change over time. Thus~ in most cases, it
will be impossible to describe the boundaries of a
release with certainty. At the same time, -however, the
RIfFS or the Record of Decision which defines the remedy
selected may offer a useful indication to tbe public of
the areas of contamination at which the Agency' is
considering taking a response action, based on
information known at that time.
For these reasons, the NPL need'not be amended if further
research into the extent of contamination expands the
apparent boundaries of the release. As discussed above,
the NPL is only of limited significance, as it does not
assign liability to any party or to the owner of any
specific property.... If a party wishes to contest
liability for releases on discrete parcels of property,
it may do so if and when the Agency brings an action
against that party to recover costs or to compel a
response action at that property.
The PRP make the incorrect assumption that an NPL site may only be
expanded when the same release is found to have contaminated an
area that is larger than the originally detected area. As
indicated above, the facility includes the source or sources of
,contamination and any area where a hazardous substance release has
"come to ,be located" (CERCLA Section 101 (9). The NPL site may be
expanded to include the source of a release. In Washington State
Department of Transportation v. u.S. EPA, the property included was
a "source" of the contamination noticed on the NPL. As indicated
above, a site is not limited to the boundaries of properties that'
may be referred to in the name of that Site, and includes all
releases evaluated as part of the HRS analysis.
. Comment: The PRPs do not believe the Administrative Record
supports the inclusion of the Thomas Solvent Property in the Thermo
Chem Site. They cite a negotiated RIfFS Consent Order which
expressly prevents u.S. EPA from modifying the RIfFS Work Plan to
require them to conduct an RIfFS at the adjacent Thomas Solvent of
Muskegon; and the limited definition of "Site" in this Consent
-------
18
Order. The PRPs claim that U.S. EPA relies on the PRAP alone as
the basis for its decision.
Response: The Proposed Plan at pages 6-7 describes the findings
supporting its conclusion that the release listed on the NPL
included the Thomas Solvent Property. These findings are
documented in the Administrative Record. In particular, the RI
report, the HRS package and the Technical Assistance report contain
the findings which support the inclusion of the Thomas Solvent
Prope~ty.
Comment: The PRPs state that U.S. EPA has statements from
undisclosed persons justifying the decision - to combine both
properties at the Site, and has refused to provide those statements
on request.
Response: Although u.S. EPA does have interviews with undisclosed
persons which contain information which may be relevant to the
issue of liability, such statements were not the basis for
including the Thomas Solvent property at the Thermo Chem Site. The
documents establishing a basis for the inclusion of the Thomas
Solvent Property are described in the response to the previous
comment. u.S. EPA has advised PRPs at meetings, including public
meetings, and in phone conversations that the document described
exists. This document, which is dated July 1990, and which
documents interviews with numerous persons regarding operations at
the Thomas Solvent and Thermo Chem properties is exempt from FOIA
under 40 CFR 2.118(a) (5) and (7) (i) (A) and (D). U.S. EPA has
received and responded to numerous FOIA requests at this Site. If
any requestor feels this document was responsive to their request
and was not identified, they should identify the RIN nUmber so that
U.S. EPA can review the request. .
Comment: The PRPs arque that a cleanup in accordance with the
PRAP would impose liability on the Thermo Chem PRPs for
contamination for which they claim they are not legally.
responsible.
Response: The Site characterization does not assign liability to
any party or to the owner of any specific property. If a party
wishes to contest liability for releases on discrete parcels of
property, it may do so if and when the Agency brings an action"
against that party to recover costs or to compel a response action
at that property. The subject of the Proposed Plan and this ROD is
the site and the remedy; not liability. Comments with regard to
liability will not be addressed in this responsiveness summary.
Comment: The PRPs arque that since U.S. EPA has not undertaken a
feasibili ty study for the Thomas Sol vent property, the proposal for
a remedy for the TS property, which they call a facility, is
premature and violates CERCLA.
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..
19
Response: U.S. EPA arranged for an RIfFS at the Thermo Chem Site.
When it was determined that this site also included the Thomas
Solvent Property, investigations were conducted on this property to
obtain the information that the negotiated RIfFS did not already
provide wi th regard to this portion of the Si te. Much of the
information acquired during the PRP RIfFS was applicable to both
properties at the Site.
Comment: The PRPs claim that the Type B standards are not ARARs
and may not be used for the cleanup. They argue that Type B
standards cannot be used as ARARs, since they are not specifically
part of the promulgated Act 307 Rules but are the result of cleanup
criteria developed by MDNR. They add that standards are constantly
being revised and are not fixed Targets.
Response: The substantive provisions of parts 6 and 7 of the Act
307 Rules have been determined to be ARARs. These rules are
promulgated standards, requirements, criteria or limitations, under
a state environmental or facility siting law, more stringent"than
the Federal requirements and have been found to be relevant and
appropriate at the Site. They are legally enforceable and of
general applicability. U.S. EPA finds no inconsistency in the
application of cleanup qoals by the State of Michiqan or in the
application of cleanup goals identified for this Site. These rules
contain criteria for complying with Type A, B, and C cleanups.
They provide that remedial actions shall be protective of human
health, safety, and welfare and the environment and natural
resources, and specify that this standard is achieved by a degree
of cleanup which conforms to "one or more of the Type A, B orC
cleanup criteria. The substantive requirements of Parts 6 and 7 of
the Act 307 rules must be complied with in order to be consistent
with CERCLA and the NCP. u.S. EPA has selected a remedy which is
protective of human health and the environment as required by
CERCLA and the NCP. This remedy, and the specific site standards
set forth in Tables 2 and 3, have been determined to comply with
the promulgated criteria and methods contained in Rules 299.5703,
299~5709, 299.5723 and 299.5725. .
Comment: PRPs argue that u. S. EPA should have and did not
consider a Type C cleanup, and must reevaluate the possible
,remedial alternatives, including an evaluation of a Type C cleanup. "
Response:
This comment is addressed at page 10.
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..
._--- -
.--. .-..
. -.. --
..
STATE OF MICHIGAN
NA1VRAL RESOURCES COMMISSION
MARLENE J. FLUHARTY
GORDON E. GUYER
O. STEWART MYERS
RAYMOND POUPORE
.
JOHN ENGLER, Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON BUILDING
P.O. BOX 30028
lANSING. MI 48909
8£:lBJ:RT RE:GTSR. 8" - l
ROLAND HARMES, Director
September 19, 1991
Hr. Valdas Adamkus, Regional Administrator
U.S. Environmental Protection Agency
Region 5, 5RA-14
230 South Dearborn Street
Chicago, Illinois 60604
Dear Hr. Adamkus:
"
The Michigan Department of Natural Resources (MONR), on behalf of the State of
Michigan, has reviewed the draft Record of Decision (ROD) which w~ received on
August 14, 1991, for the Thermo-Chern Superfund site in Muskegon County,
Michigan. We are pleased to inform you that we concur with the selected
remedy outl ined. in the draft ROO for operable unit number L
The major components on the selected remedy include:
o decontamination, demolition and off-site disposal of a1l'on-site buildings,
with subsequent sampling of underlying soils;
o institutio~al controls, including zoning, land use restrictions, and
construction of a fence around the perimeter of the site. The institutional
controls will extend until the groundwater remedy has been completed;
o excavation and off-site incineration of soils from selected "hot spots";
o in-situ soil vapor extraction of contaminants in remaining soils and a
treatability study to determine whether enhanced biodegradation should also
be added. The cleanup levels for soils will be dictated by the Rules
promulgated under the Michigan Environmental Response Act (HERA) (1982 P.A..
307, as amended). Since groundwater discharge to Black Creek is occurring,
as required by MERA Rule 713 (2), soil cleanup numbers will be set based on
20 times the allowable level specified pursuant to Rule 57(2) of the Part 4
Rules of the Water Resources Commission Act (1929 P.A. 245, as amended)
(WRC Act), where these are more stringent than'those resulting from MERA
Rules 711{2} or 711{5}. These numbers are listed in Table 2 of the draft
ROD;
'\ ..0;
0'
U':,:,».;
-
-------
Mr. Valdas Adamkus
-2-
September 19, 1991
o groundwater extraction and treatment from both the shallow and deep
aquifers. Groundwater treatment will include filtration, air stripping,
metals precipitation, and pH adjustment. The air stripper shall be equipped
with a vapor phase activated carbon treatment unit. Monitoring of the
treated effluent will be done to assure compliance with the substantive
requirements of a National Pollutant Discharge Elimination System (NPDES)
permit prior to discharging the effluent to Black Creek. It is possible
that aqueous phase carbon will be needed to treat semi-volatile
contaminants. The groundwater cleanup numbers will be dictated by the
Type B numbers generated pursuant to MERA Rule 709 or, as required by MERA
Rule 713(2), the Rule 57(2) numbers, whichever is more stringent. These
cleanup criteria are listed in Table 3 of the draft ROD;
o additional studies will be done to determine background._concentrations of
inorganic soil contaminants, the ability of some contaminants to leach from
site soils to groundwater, and the existence ~f other contaminated soil.
These studies may dictate that additional excavation and/or treatment may be
needed to meet federal or state standards.
The state also concurs with the analysis of legally applicable or relevant and
appropriate requirements (ARARs) contained in Section XI - Statutory
Determination Summary, with the following exception. The state has
previously identified the WRC Act, MCL 323.6(a) and the associated Part 22
Administrative Rules, MAC R.323.2201 g1 ~ as ARARs for this site. It
remains our position that the WRC Act and the associated Part 22 Rules are
ARARs for the remedial action for this site because hazardous substances in
the aquifer beneath the site are migrating to degrade previously
uncontaminated groundwater.
It is the MDNR's judgement that the selected remedial action for this site
will provide for attainment of all ARARs, including the Part"22 Rules of the
WRC Act by preventing further discharges of injurious substances into the
groundwater outside of the containment area and by remedying the existing
groundwater contamination.
The MONR believes that the ROD should include a requirement that a program-to
monitor the effectiveness of the remedial action be designed and' implemented.
This operable unit is the first of two planned for the site. This first
operable unit addresses soils, sludges, and groundwater up to its discharge
point to Black Creek. The function of this operable unit is to eliminate the"
source of contamination and treat contaminated groundwater which has already
migrated from the site. The second operable unit will address surface water
and sediments in Black Creek, and groundwater south of Black Creek, if
-necessary. While the remedy in operable unit 1 addresses some of the
principal threats at the site, the second operable unit will involve all other
aspects of the Thermo-Chem site.
,
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.,
.;
, .
'. ----.-.-- ----.-.. -- ..- .~
Mr. Valdas Adamkus
-3-
September 19, 1991
If you have any quest;ons regard;ng th;s s;te, please contact Mr.
Adelman at 517-373-8436, or you may contact me d;rectly.
~:1fj21}
bC1iUGnelbert Rector
Deputy D;rector
517 -373-7917
cc: Mr.
Ms.
~r.
Mr.
Mr.
Mr.
Mr.
Jonas D;k;n;s, EPA
Mary Tyson, EPA
Jae lee. EPA
Robert Re;chel, Department of Attorney General
Alan Howard, MOHR
W;lliam Bradford, MOHR.
Peter Ollila, MOHR/Thermo-Chern F;le
M;tchell
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Page 110. ~
07/09/91
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEM
MUSKEGON, MICHIGAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
12 85/03/29 Letter re: James Gregg, Roger Przbybsz, MONR Correspondence 1
Thomas Solvent Co. Varnun, Ridderin;,
Chapter" No. Schmidt & Howlett
NK-84-00843, Thermo
Chem, Inc.
4 85/08/29 Letter re: Roger Przybysz, D. Adams, Thomas Correspondence 2
Analytical results MDNR Solv Co.
and location map for
the soil gas survey
conducted on 4130/85, .'
at the Thomas Solvent
Co.
7 86/05/21 Letter re: Basil Constantelos, Various Correspondence 3
USEPA's consideration USEPA
of spending public
funds to investigate
and take corrective
action for the control
of the release of
hazardous substances
at the Thermo Chem
site
9 86/09/08 Letter re: Basil Constaelos, R. Byersmith Correspondence 4
USEPA's consideration USEPA
of spending public
funds to investigate
and take corrective
action for the control
of the release of
- hazardous substances
at the Thermo Chem site
5 86/09/09 Letter re: Basil Constantelos, Various Correspondence 5
USEPA's documentation USEPA
of the release or
threatened release
of hazardous substances,
polluntants and
contaminants at the
Thermo Chem site
11 86/10/22 Letter re: Diane Diks, Various Correspondence 6
5/21/86 letter USEPA
regarding Thermo Chem
from USEPA
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Page No.
07/09/91
2
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEM
MlSICEGON, MICHIGAN
FICHE/FRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCN~E.
1
87/11/12
Letter re:
Abandoned undergrCUld
Storage tanks at
4321 E. EV8nIton Ave.
Larry Hruskach,
Egelston Township
Fire Depart8nt
Thermo Cham Inc.
Correspondence
7
1 87/11130 Letter re: JIIIIIeS Su II i van, Egelston Twsh. Fire Correspondence 8
11112/87 letter Sullivan, Hamilton Dept.
addressed to Thermo & Schulz .-
Chemical Co.
15 88/01/29 Letter re: Diane Diles, Susan Franzetti Correspondence 9
SLlllllllry of all USEPA
response costs incurred
by the USEPA at the
Thenmo Chem sfte
1 88/03/24 Letter re: Mitchell Adelman, Dan Wi llea Correspondence
Receipt of 11/12/87 MDNR
to Thermo Chem/Thomas
Solvent and their
response dated
11/30/87
1 88/06/02 Letter re: Jae Lee, James Sull fvan, Correspondence 11
Revie.. of Chief USEPA S,H&M
Hruskach, Egelston
TONnShip Fire
Department letter
dated 11/12/87
to Thermo Chilli
and the response
dated 11130/81
55 88/07/25 Letter re: Susan Franzetti, Jon Faletto, USEPA Correspondence 12
Thermo Chem, Inc. Gardner, Carton &
NPL Site Douglas
4 88/08/11 Letter re: Jon Faletto, Susan Franzettf Correspondence 13
Emergency removal USEPA
action at Thermo
. Chem, Inc.
10 89/01/09 Letter re: Valdas Adamkus, James Sull ivan Correspondence 14
Thermo Chem NPL site USEPA
Administrative Order
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Page No. 3
07/09/91
ADMINISTRATIVE RECORD INDEX
REMED I AL ACT! OIl
THERMO CHEM
~ MUSKEGON, MICHIGAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
directing compliance
with the USE~'s
request for access
to the Thermo them
NPL site located
at 4331 Evanston Ave.
12 89/02/21 Letter re: Jae Lee, Susan Franzetti Correspondence 15
Cost Reimbursement USEPA
for Thermo them
site
11 89/01112 Letter re: Susan Prout, J8IIIeS Sull ivan Correspondence 16
Administrative Order USEPA
directing compliance
with the USEPA's
request for access
to that portion of the
Thermo Chem, Inc.
NPL site drum storage
area that has been
found to be on
Thomas Solvent Co.
property
4 89/10/23 Letter re: will i am Herceg, Jae Lee, USEPA Correspondence 17
ERM's conduct on MONR
the Thermo Chem
site during the
week of 9/11-15/89
. 30 90/01/11 Letter re: Iv~rs Antens, Susan Franzetti Correspondence 18
Recovery of costs USEPA
incurred by the
USEPA for response
activity, performed
under CERCLA as amended
12/03/88 thru 09/30/89
32 90/01/29 Letter re: IvarsAntens. Susan Franzetti Correspondence 19
Recovery of costs USEPA
incurred by the USEPA
for response activity
performed under the
authority of the
CERCLA
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Page No. 4
07/09/91
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEM
JlJSICEGON, MICHlGAJI
b
FI.CHE/FRAME PAGES DATE TITLE AUTHCR RECIPIENT DOCUMENT TYPE DOCN~ER
4 90/02109 Letter re: Themes Lentzen, .lee Lee, USEPA Correspondence 20
SlIIIIIIIry of the PIP Metcalf & Eddy
llleeting notes for the
Thenao Chea site
Work Assignment COS028
6 90/04/02 Letter re: Maria Gonzalez, Susan Franzetti Correspondence. 21
Cost OVerc1H: InIer USE~A
Thermo Chem, Inc.
Consent Order .-
41 90/04/09 Letter re: .Iae Lee, Ie. Waskiewicz, Ford Correspondence 22
Review Comments on the USEPA Co.
Technical Memorandum
No. 2 for the Remedial
Investigation, Thermo
Chem
8 90/04/27 Thermo Chem, Inc. Mari. Gonzalez, Susan Franzetti Correspondence 2.,.'
Site Consent Order USEPA
2 90/05/04 Letter re: USEPA Steven leoh l, Jae Lee, USEPA Correspondence 24
Sponsored work Landman, Latimer,
at Thomas Solvents Cl ink & Rebb
35 90/05/10 Letter re: Ivars Antens, Susan Franzetti Correspondence 25
Thermo Chem, USEPA
account that has
been outstanding for ,
over 90-days
2 90/06/22 Letter re: John Imse, .Iae Lee, USEPA Correspondence 26
Thermo Chem RI/FS ERM-NC
Schedule
1 90/07106 Letter re: Ii II Herceg, .Iae Lee, USEPA Correspondence 27
MONR's completion MONR
of its review of
the Thermo Chem
Sampling and Analysis
Plan, Part 1 and 2
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Page No. 5
07/09/91
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEM
MUSKEGON, MICHIGAN I
I
I
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
44 90/07110 Letters re: .lames Strayton, .Iae Lee, USEPA Correspondence 28
Tes X Work Assignment Metcalf' Eddy
No. C05D28 Thermo
Chem RI/FS Oversight
Field Activity Reports
16 90/09/18 Letter re: Robert Bowden, . Various Correspondence 29
Request for USEPA
Information Pursuant
to Section 104(e) of
CERCLA and Sect i on
3007 of RCRA, for the
Thomes Solvent site
26 90/09/18 Letter re: Robert Bollden, Steven !Coh l torrespondence 30
Thomas Solvent site USEPA
General Notice of
Potential Liability
2 90/09/25 Thomes Solvent site Richard Thomas, Carol Graszer, USEPA Correspondence 31
General Notice of Thomas Solvent Co.
Potential Liability
5 90/09/25 Letter re: Richard Thomes, Robert Bowden, USEPA Correspondence 32
Thomas Solvent site Land, Latimer,
General Notice of Clink' Robb
Potential Liability
2 90/10/D3 Letter re: James Strayton, .Iae Lee, USEPA Correspondence 33
Additional Field Metcalf & Eddy
Work Requirements at
Thermo them
6 90/10/04 Letter re: Richard Thomas, Carol Greszer, USEPA Correspondence 34
Request for Information Thomas Solvent Co.
Pursuant to Section
104(e) 3007 of RCRA,
for the Thomas Solvent
site
6 90/10/11 Letter re: .Iae Lee, !C. Waskiewicz, Ford Correspondence 35
Request for additional USEPA Co.
field activities for.
the Remedial
Investigation at the
Thermo them site
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Page No. 6
01/09/91
ADMJNJSTRATIVE RECORD INDEX
REMED J AL ACTI ON
THERMO CHEM I
tl./SKEGON, ~ J CH J IiAN I
I
FJCHE/FRAME PAGES DATE TITLE AUTHOR RECJPJENT DOCUMENT TYPE D0CNUM8ER
19 90/10/12 Letter re: Robert Bowden. Various Correspondence 36
Thomes Solvent site USEPA
General Notice of
Potential Liability
2 90/10/25 Letter re: Barry Nelson. "a. L... USEPA Correspondence 37
Tea X Work Aasignnent Metcalf & Eddy
No. COS028
Thermo Chem RJ/FS
Oversight Summery of
RIXI Meeting. 10/18/90
4 90/10/29 Letter re: ..ae Lee. IC. Waskiewicz, Foret Correspondence 38
Position of the USEPA Co.
USEPA fOllowing the
meeting held on
10/18/90. regareting
the RJ/FS at the
Thermo Chem site
4 90/10130 Letter re: Tes X James Strayton. "ae Lee. USEPA Correspondence 39
Assignment No. C05028 Metcalf & Eddy
Thermo Chem RJ/FS
Oversight Slug Test
Qualifications and
Comnents
4 90/11/02 Letter re: Raymond Murphy. Jae Lee. USEPA Correspondence 40
Request for additional Ross & Hardies
Work
13 90/11/16 Letter re: Timothy Vanderver. Valdas Adamkus. Correspondence 41
AciDinistrative Patton, Bogs & Blow USEPA
. Order on Consent
concerning the
Thermo Chem site
written on behalf
of the Respondents
9 90/11/26 Letter re: "ae Lee. T. Vanderver, P,B&B Correspondence 42
Thermo Chem Jnc. USEPA .l
Additional Work
Dispute
2 90/11/29 Letter re: Timothy Vanderver. Valdas Adamkus. Correspondence 43
11/16/90 letter Patton, Boggs & Blow USEPA
requested on behalf
of the Thermo Chem
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P8ge No. 7
07/09/91
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEM
tLlSKEGON, MICHIGAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
participating PRPs
that a withdrawal of
a directive from the
RPM wh i ch purported
to order additional
work for the ThenlO
Chem site
3 90/12/13 Letter re: Timothy Vande rver, Maria Gonzalez, Correspondence 44
Agreements reached Patton, 809gs & 8low USEPA
at llleeting on
12/11/90 and subsequent
telephone conversation .-
concerning EPA's
demand for additional
RI/FS work at the
Thermo Chem site
6 90/12/26 Letter re: 10/11/90, Jae Lee, J. lmes, ERN-NC Correspondence 45
letter from the USEPA USEPA
recommending that the
PRPs for the Thermo
Chem Superfund .ite
submit each chapter
of the baseline risk
assessment report
separately for review
3 91/01/02 Letter re: Maria Gonzalez, R. Leininger, WMNA Correspondence 46
Access to Waste USEPA
Management, Inc.
Property
7 91/02/14 Letter re: Steven Kohl, Jee Lee, USEPA Correspondence 47
Conments upon Landman, Latimer,
Proposed Removal Cl ink & Robb
Action at Thomas
Solvent of
Muskegon, Inc.'s Bulk
Storage Facil i ty
28 91/03/15 Alternative Array Jee Lee, John Imes, ERM correspondence 48
Review Conments USEPA
5 91/03/22 Letter re: John Imse, Jae Lee, USEPA Correspondence 49
Thermo Chem RI/FS ERM-NC
Alternative Array
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,.
'age No. 8
07/09/91
ADMINISTRATIVE RECORD INDEX
REMED 1 AL ACTI ON
THERMO CHEM
tlJSKEGON, MICHIGAN
fICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE D0QIUMB5R
Docunent - USEPA
end fmNR COIIIIIfInts
3 91/04/04 Letter re: John IlISe, Jae Lee, USEPA Correspondence 50
ThenDG Chem Site ERM-NC
RI/FS Review
Conments 01'1 ANJ
4 91/04/22 Letter re: Mich.el Adelman, Stavros ~nouil, Correspondence 51
Response to 4/17/91 fmNR USEPA
letter requesting .-
appl icable or
relevant and appropriate
State of Michigan
requirements (ARARs)
for the tank removal
at the Thomes Solvent
faciUty
2 91/07/03 Letter re: Jae Lee, John lilies, ERM North Correspondence 52
Approval of the USEPA Cent
F.asibility Study
Operable Unit I,
Thermo Chem Superfll'ld
Site
12 90/10/18 Thermo Chem Meeting Various Meeting Notes 53
Notes
23 83/03/14 Memorandl.ln re: Claude Mays Ill, USEPA File Memorandl.ln 54
Preliminary Assessment Ecology & Environment
,
2 88/08/09 Memorandl.ln re: Loui s Fabi nsk i , Bob Bowden, USEPA Memorandun 55
Thermo Chem ATSOR
Health Consultation
7 88/11/08 Memorandun re: PC Lall, Various Memoranclun 56
Thermo Chem aite USEPA
Polrep 2
2 89/02/08 Thomes Solvents. David Ullrich, Mary Gade, USEPA Memorandun 57
MID 017 274 093 USEPA
6 89/03/20 Memorandun' re: Partap Lall, Robert Bowden, USEPA Memoranclun 58
. Request for Removal Mary Gade, USEPA
Action at the Thermo
Chem site
10 89/07/10 Memorandun re: John Imse, Jae Lee, USEPA Memorandun 59
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Page 110. 9
07/09/91
ADMIIiISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEM
filJSICEGON, MI CH I GAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMEIIT TYPE DOCNUMBER
Thermo Chem , ERN-NC
Technical Meetinsl
6130/81
4 90/02/10 MemorancUD re: .Iohn IlISe, Various MemorancUD 60
Technical Meetinsl ERN-IIC
held 1/17190
14 90/05/29 MemorancUn re: Maria Gonzalez, Various Memorendun 61
Dispute of 1/'29/90 USEPA
Accounting for Thermo
Chem Inc. site
90/06/26 Memorandun re: Valerie Jones, John Ketley, USEPA Memorandun 62
Approval of the USEPA
First Draft, Fund
Lead QAPP for
additional Soil
S~ling and Analysis
of the Remedial
Investigation/Feasibility
Study Activity at the
Thermo Chem Site
8 90/11/14 Memorandun re: John Imse, ERM-NC Various Memorandun 63
SUllllBry of the
Thermo Chem Meeting
held 10/18/90
91/01/21 Memorandun re: John Imse/ Various Memorandun 64
Thermo Chem Site Elsie Millano,
Baseline Risk ERM-NC
Assessement
2 91/04/19 Memorandl.lft re: Stavros Emmanouil, Various . Memorandl.lft 65
Polrep .1 for USEPA
Thermo Chem RV2
aite
2 91/04/24 Memorandl.lft re: Stavros Emmanouil, Various Memorandun 66
Polyrep #2 for USEPA
Thermo Chem RV2
site
2 91/04/26 Memorandl.lft re: Stavros Emmanouil, Various Memorandl.lft 67
Polrep t3 for USEPA
Thermo Chem RV2
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P.ge No. 10
07/09/91
ADMINISTRATIVE RECORD IWEX
REMEDIAL ACT I 011
THERMO CHEM
tLlSKEGOII, MICHIGAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DoaJtENT TYPE DOCNUMBER
"
site
2 91/04/29 MemoranduD re: St.vros Emmanouil, V.rious MeIIIoranduD 68
Polrep " for USEPA
Therm Chell RV2 site
2 91/05/01 MemoranduD re: St.vros Emmenoutl, V.rious MetIoranduD 69
Polrep 15 for USEPA
Therm Chem RV2 site
10 90/12/11 Therm Chem V.rioua Other 70
Acid i t i ona l Work .-
Dispute Negotiation
114 87/08/00 Therm Chem, Inc. USEPA Pleadtnsl/Orders 71
Actninistrative
Order by Consent
regarding Remedi.l
Investigation and
Feasibility Study
13 90/01/12 Actninistrative Order Maria Gonzalez, J81118S Sull iv.n Pleadinsl/Orders i
Directing Compliance USEPA
with Request for
Access with cover
letter
14 90/01/23 Actninistrative Order Maria Gonzalez, James Sull ivan Pleadinsl/Orders 73
Directing Compliance USEPA
with Request for
Access to Conduct
Remedial Investigation
with cover letter
17 91/02/19 Thomas Solvent of David Ullrich, Various Pleading/Orders 74
Muskegon Property USEPA
Unilateral Actninistr.tive
Order
24 00/00/00 National priorities USEPA Report/Studies 75
List - Thermo Chem
Site
-24 80/09/18 Boring S8q)les from Ohio Liquid Disposal MONR Report/Studies 76
Thomas Solvents by
High-Performance
Liquid Chromatography
with Electrochemical
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07/09/91
11
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEN
MUSKEGON, MICHIGAN
FICHE/FRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCI.J4ENT "PE
DOCNUMBER
Detection (HPLC-EC) -
with cover letter
10 810/02/29 Pollution Incident Donald Adams, Roger Pr:-zybysz, MONR Report/Studies T7
Prevention Plln Thomas Solvent Co. c
Thomas Solvent Co.
71 86/03/07 111. Site Hellth USEPA USEPA Report/Studies 78
and Safety Plln
for Thermo Chem
site - with cover
letter
91 86/04/23 Hydrogeologic Study lCeck Consulting USEPA Report/Studies 79
Thomas Solvent Co. Services, Inc.
91 87/07117 Detailed Statement Thermo-Chem Steering USEPA Report/Studies 80
of Work for Remedial COIIIni ttee
Investigation
Feasibility Study
8 88/07127 Chemical Analysis MOPH Report/Studies 81
of Water
1"3 88/12/22 S~l ing and Analysis Thermo-Chem Steering USEPA Report/Studies 82
Plan for Remedial Comn i tt ee
Investigations and
Feasibility Study
Part 1 - Field
- S~l ing Plen
305 88/12/22 SBq:ll ing and Analysis Thermo-Chem Steering USEPA Report/Studies 83
Plan for Remedial Comni tt ee
Investigation and
Feasibility Study
Part 11 - Quality
Assurance Project
Plan
"1 88/12/22 Data Management Plan Thermo-Chem Steering USEPA Report/Studies 810
For Remedial Comni tt ee
Investigation
52 88/12/22 Health and Safety Thermo-Chem Steering USEPA Report/Studies 85
Plan for Remedial Comnittee
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12
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEM
MUSKEGON, MICHIGAN
FICHE/FRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCN1.MBER
Investigation
90
88/12/22
Work Plan for~
Remedial Investigation
Feasibility Study
Revision 3
Thermo-Chem Steering
CCllllllittee
USEPA
Report/Studies
86
20
89/05/00
On Scene Coordinator's
Report - Thermo Chell
USEPA
Report/Studi..
81
136 89/06/00 Technical Memorandum Thermo-Chem Steering USEPA " Report/Studies 88
No 1. Remedial Ccnmittee
Investigation Task 1
381 89/12/22 Technical Assistance USEPA . R~rt/Studies 89
Work Plan Documents
for the Thermo Chem
site
61 90/02/26 Thermo Chem RI/FS John IlIISe, Jae Lee, USEPA Report/Studi es \
Technical Memorandum ERM-NC
No.2
9 90/03/01 Tes X Work Assignment James Strayton, Jae Lee, USEPA Report/Studies 91
No. C05068 Thomas Metcalf & Eddy
Solvents Technical
Assistance (TA) Field
Activities Report:
3/1/90 and 3/5/90
,
38 90/03/08 Appendun to Appendix James Stray ton, Jae Lee, USEPA Report/Studies 92
G-Soil Gas SOP of the Metcalf & Eddy
fA Work Plan GAPP
Thomas Solvent
26 90/05/11 Removal Action Plan Weston-Major USEPA Report/Studies. 93
for Thomas Solvents - Program Division
with cover letter
12 90/05/25 . S8q)l ins and Analysis Thermo-Chem Steering USEPA Report/Studies 94
Plan Addendun for Ccnmittee
Remedial Investigation
and Feasibility Study
Part II - Quality
Assurance
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Palle 1110. 13
07/09/91
ADMINISTRATIVE RECORD INDEX
RENED I AL ACT! ON
THERMO CHEM
,. MUSKEGON, MICHIGAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
o
.
30 90/05/25 S~l ing and Anelyais Thenao-Chem Steering USEPA Report/Studies 95
Plan Addendun for COIIIIIi ttee
Remedial Irwestillation
and Feasibility Study
Part I - Field Sampling
Plan
15 90/06/11 The Determinetion Pace Inc. USEPA Report/Studies 96
of Volatile Organics
in Water
.'
11 90/11/16 Transmittal of Cathy Pi cltrel, Jae Lee, USEPA Report/Studi es . 97
General Risk Metcal f & Eddy
Assessment Requirements
for the Thermo Chem
RI/FS with cover
letter
153 91/01/00 Alternatives Array Thermo-Chem USEPA Report/Studies 98
DOCUDent Steering COIIIIIittee
10 91/02/25 CDq)Uter Model ing of Carl Stay, Jae Lee, USEPA Report/Studies 99
Thermo Chem site ERM-NC
with cover letter
100 91/03/00 Finel Technical Metcalf & Eddy, Inc. USEPA Report/Studies 100
Assistance Report
For Thomas Solvent
Site
84 91/03/28 Draft Remedial Jae Lee, John IIIIH, ERM-NC Report/Studies 101
Investigation Report USEPA '
Review Comments Thermo
Chem Superfund site
with cover letter
5 91/04/00 EPA Includes USEPA Report/Studies 102
Thomas Solvent in
Thermo Chem Contamination
Study; Plans to remove
Underground Tanks
362 91/05/00 Feasibility Study ERM North Central USEPA Report/Studi es 103
Thermo Chem Site
52 91/05/29 Analysis results for Barry Sperling, Stavros Emmanouil, Report/Studies 104
soi Is from Thomas ITC USEPA
Solvents P.N. 183
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'8ge 110. 14
07/09/91
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
THERMO CHEM
MUSKEGON, MICHIGAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCIJ4ENT TYPE DOCII\I4BE'
"
16 91/05131 Letter ...: Thomas Lentzen, "ae Lee, USEPA Report/Studies 105
Final Saseline Risk Metcal f I Eddy
Assessment Record of
Decision Coqarter Files
25 91/05131 Analysis results for Sarry Sperl ing, Stavros Emmanouil, Report/Studies 106
the tenax air samples IYC USEPA
from Thomas Solvents
P.N. 183
55 91/06/05 Final Analytical Richard Mauch/ USEPA .- Report/Studies 107
Report - Solvent Marvin Stephens,
Reclaiming Site Wadsworth Alert
Laboratories
6 91/06/12 Letter re: David .Iohnston, "ae Lee, UEPA Report/StudieS 108
Thermo Chem Corrections ERN - North Central
to Remedial Investigation
Report
94 91/06/24 Thermo Chem Site Elsie Mi llano, .Iae Lee, USEPA Report/Studies
Corrections to ERN North Central
Section 6.0 of the
. Remedial Investigation
Report
22 91/07/02 Transmittal of Cathy Pickrel, .Iae Lee, USEPA Report/Studies 110
Explanation Baseline Metcalf I Eddy
Risk Assessment
Calculations for the
Thermo-Chem and Thomas
Solvent Sites
.
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P8ge 8/0.
09/24/91
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION - UPDATE NO.1
THERMO CHEM SUPERFUND SITE
MUSKEGON, MICHIGAN
" FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUHBER
'" 2 91/05/02 Letter re: Response D. Johnston-ERM J. Lee'U.S.EPA, RPM Correspondence
to USEPA Comments - North Central, Inc.
Thermo Chem RI/FS
S~l ing end Analysis
P len AddenduI 2
Docunents
11 91/07/02 Letter ra: Thermochem R. C~-Coqu:hem ~.JOhnston,ERM'North Correspondence 2
Bottlewere Issues Laboratories, Inc. Cent
2 91/07/03 Letter re: Approval J. Lee-U.S.EPA, RPM J. lame,ERM-North Correspondence 3
of the Feasibility Central .-
Study, Operable Unit
I - Thermo Chem Site
91/07/22 Letter forwarding 3 D. JOhnston,ERM-North J. Lee-U.S.EPA, RPM Correspondence 4
copies of the final Central, Inc.
revisions of the
RI/FSP and Addendum
2 QAPP for both the
Stream Sampling end
Moni toring Well
activities
91/07/25 Letter re: Request for R. Murphy-Ross & Hardles P. Schutte-U.S.EPA, Correspondence 5
an additional 30 days CPA
to provide comments
to the U.S.EPA's
Proposed Plan
91/08/06 Letter re: The public M. Gonzalez-U.S.EPA, R. Murphy-Ross & Correspondence 6
corrment period for the Atty for ORC Hardies
Thermo Chem Superfund
Site has been extended
W'lt H Sept. 9, 1991
2
91/08/08
Letter re: Requesting
cooperation In assist-
ing ERM with completing.
an environmental
Investigation
R. Boy,ERM'North
Central, Inc.
Rev. W. Burrel
Correspondence
7
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, .
9age No. 2
09/24/91
ADMINISTRATIVE RECORI) INDEX
REMEDIAL ACTION - UPDATE NO.1
THERMO CHEM SUPERFUND SITE
""SKEGON, MICHIGAN "
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
\J
2 91/08/27 Letter re: MONR A. Rownel-MOII .I. Tr8l.b-U.S.EPA Correspondence 8
supports the preferred
remedy outlined in the
Proposed Plen, dateo
July 1991
3 91/09/06 Letter re: Request for D. Johnston, ERM-North BIshop & Mrs. U. Correspondence 9
access to resident's Central, Inc. Burrel
wooded property with
map attached .-
8 91/07100 EPA Proposes Cleanup U.S.EPA-Reglon V Fact Sheet 10
Plan for Thermo Chell
Superfund Site
1 91/08/01 RIIFS Saq:ll ins! Metcalf & Eddy Map 11
Locations
2 91/07/03 Memo re: Contingent V. Jones-U.S.EPA J. Kelley-U.S.EPA Memorandun 12
Approval of QAPjP
Addendun 2 for RI
Activities
2 91/09/03 Memo re: Remedy D. Clay-U.S.EPA V. Adamkus-U.S.EPA Memorandun 13
Delegation Report
1 91/07/08 -The U.S.EPA Announces The Muskegon Chronicle PLtlI ie Publi e Comments 14'
I Public Meeting Ind
Invites Public Coament
on . Proposed Plen for
Addressing ContamiNotion
Problems
2 91/07/09 Public Comments on the M. Bernard-Area Resident P. Schutte-U.S.EPA, PLtllic Comments ,15
proposed plan CPA
2 91/07116 Letter re: Public D. Anderson-Citizens P. Schutte-U.S.EPA, Public Conments 16
Comment on Proposed UnIted for the CPA
Plan Environnent
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ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION - UPDATE NO.1
THERMO CHEM SUPERFUND SITE
MUSKEGON, MICHIGAN
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09/24/91
.
4
FICHE/FRAME PAGES DATE
40
91/07/22
97
91/07/16
. TITLE
and Feasfbflity Study
Part I
Ffeld Sampling Plan
Surface Water and
Stream Sedfment
Sampling and Analysfl
Plen Addendum 2 for
Remediel Investfgation
and Feasfbflfty Study
Part I .
Field Sampling Plan
Public Meeting for
Thermo Chem Superfund
Site
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION - UPDATE NO.1
THERMO CHEM SUPERFUND SITE
MUSKEGON, MICHIGAN
AUTHOR
ERM-North Central, Inc.
K- Schotts, CSR &
Notary Publfc,
Mecosta, actin; for
Muskegon County,
State of Mfchfgan
I'
RECIPIENT
DOCUMENT TYPE
DOCNUMBER "
ThenDO-Chem Steering Reportl/Studles
tam
24
. .-
Transcrfpt
. 25
..
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~
Index of Guidelines
Thermo Chem Superfund site
operable Unit I
Muskegon, Michigan
1979 Water-Related Environmental Fate of 129 Priority
Pollutants, NTIS PB80-204373, U.S. EPA
1985 Rapid Assessment of Exposure to Particulate Emissions from
Surface Contamination Sites, EPA/600/8-85/002, Office of Health
and Environmental Assessment, Washington, D.C.
1986
Superfund Public Health Evaluation Manual, NTIS PB87-183125
9/87 Superfund Exposure Assessment Manual, OSWER Directive
#9285.5-1
1988 Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA, Interim Final, Office of
Emergency and Remedial Response
1/88 Preliminary Assessment Guidance, OSWER 9345 0-01
(OERR/HSCD) Final
1/83 Emergency Response Procedures for Control of Hazardous
Substance Releases, EPA-600/D-84-023 (Rockwell 'International)
Final
2/88 Superfund Removal Procedures, Revision # 3 OSWER #9360.0-
038 (OSWER/OERR) Final
10/88 Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA, OSWER #9355.3-01 (OSWER/OERR)
Final
3/87 Data Quality Objectives for Remedial Response Activities:
Development Process, OSWER #9355.0-7B (CDM Federal Programs
Corp.) Final
6/84 Geophysical Techniques for Sensing Buried Wastes and Waste
Migration, EPA-600/7-84/064 (Technos, Inc.) Final
2/88 Laboratory Data Validation Functional Guidelines for
Evaluating Organic Analyses, (Viar and Co.) Draft
.9/85 Practical Guide for Ground-Water Sampling, EPA/600/2-85/104
(Illinois st. Water Survey) Final
2/84 Slurry Trench Construction for Pollution Migration Control,
EPA/540/2-84-001 (OERR) Final
10/85 CERCLA Compliance with Other Environmental Statutes, OSWER
#9234.0-2, Final
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2
8/88
Draft
CERCLA Compliance with other Laws Manual, OSWER #9234.1-01
~
9/86 Guidelines for Carcinogen Risk Assessment Federal Register,
September 24, 1986. p.33922 (EPA) Final
9/86 Guidelines for Exposure Assessment Federal Register,
September 24, 1986, p.34042. Final
Integrated Risk Information System (IRIS), Final
9/88
Public Health Risk Evaluation Database, F~nal
6/88 Community Relations in Superfund: A Handbook, OSWER
#9230.0-038, Final
11/87 Revised Procedures for Planning and Implementing Off-Site
Response Actions, OSWER # 9834.11 (OWPE), Interim Final.
2/91 National Priorities List for Uncontrolled Hazardous Waste
sites 56 Federal Register 5598 (February 11, 1991), EPA Final
8/90 National Priorities List for Uncontrolled Hazardous Waste
Sites 55 Federal Register 35502 (August 30, 1990), EPA Final
12/90 Superfund Removal Procedures, Action Memorandum Guidance,
EPA/540/P-90/004
1/90 Handbook on In Situ Treatment of hazardous Waste-
contaminated Soils, EPA/540/2-90/002
12/88 Guidance on Remedial Actions for Contaminated Ground Water
at Superfund Sites, EPA/540/G-88/003
12/89 Risk Assessment Guidance for Superfund, Volume 1, Human
Health Evaluation Manual, Part A,. Interim Final,. EPA/S04/1-89/002
7/89 Terra Vac In Situ Vacuum Extraction System, Application
Analysis Report, EPA/540/A5-89/003 .
4/89 Technology Evaluation Report: SITE program Demonstration
~est Tera Vac In situ Vacuum Extraction System, Groveland
Massachusetts, Volume I, EPA/540/5-89/003a
~
.8/90 Literature Review and Scoping Study for the Enhancement of
the Volatilization of Organic contaminants in the Unsaturated
Zone, CH2M Hill Engineering LTD
12/86 Interim Guidance on Superfund Selection of Remedy, OSWER #
9355.0-19
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3
"
5/91 Engineering Bulletin: In Situ Soil Extraction Treatment,
EPA/540/2-91/006
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'.
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