1
I
1
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPAIRODIR05-91/179
September 1991
err (
~.E <1 2..- 'rb'{ , 3J
&EPA
Superfund
Record of Decision:
Chern-Central, MI
. . .
\U . S. EmfVrornment~i Protection A~V
RegkmJ W~ Hazardous Wast~
khff1)ica~ ~nformation Center
841 Chestnut Street t 9th Aaor
PhUadelphia I PA 19107
'"
,~~
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
philadelphia. PA 19107
-. .....
-------
50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R05-91/179
1 ~
3. RecIpient. ACC888Ion No.
4. 11tIe 8nd Sub1ItIe
SUPERFUND RECORD OF DECISION
Chern-Central, MI
First Remedial Action - Final
7. Author(.)
50 Report Date
09/30/91
6.
8. Perfonnlng Organization Rept. No.
8. P8rf0nnlng Orgalnlzatlon Name 8nd AcId-
10. ProjectlTuklWoril Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
1 ~ Spon8orIng Organization Name and Addreaa
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
13. Type o' Report & Period Covered
Agency
800/000
14.
15. Supplement8ly No...
16. Ab81ract (Un8t: 200 _rda)
The 2-acre Chern-Central site is a bulk chemical storage facility in Wyoming, Kent
County, Michigan. Land use in the area is a mixture of residential and commercial.
An estimated 10,000 people live within 1 mile of the site and receive their water
supply via the municipal distribution system. Two creeks, Cole Drain and Plaster
Creek, lie in proximity to the site. Cole Drain, which has been included as part of
the site, empties into Plaster Creek 2,500 feet north of the site. In addition, two
hotels are located 800 feet from the site. Since 1957, Chern-Central has used the
site to receive and hold bulk chemicals by truck and railroad tanker before
redistribution to various industries. Facilities at the site include a building
with two loading docks and a rail spur on the west side of the plant. Approximately
10 above-ground storage tanks are located along the plant's north side and are
surrounded by a concrete containment wall and paved ground surface. Between 1957
and 1962, hazardous substances entered the ground as a result of faulty construction
of a T-arrn pipe used to transfer liquid products from bulk storage tanks to small
delivery trucks. Additional hazardous substances may have entered the ground
through accidental spills. In 1977, a routine State biological survey of Plaster
(See Attached Page)
17. Document Analyaia L Deacripto18
Record of Decision - Chern-Central, MI
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE, toluene), other organics (PARs, PCBs)
--
b. IdentifieralOpen-Ended Torma
c. COSA" RekIIGroup
18. Avlil.blity St8tement
19. Security Clua (Thi. Report)
None
20. Security Clua (Thia Page)
Non4=>
--"..
'h.
21. No. o' Pages
69
I
~ Price
(See ANSl-Z39.18)
See Instructions on Reverse
272 (4-77)
(Formecty NTlS-35)
Department o' Commerce
-------
EPA/ROD/R05-91/179
Chem-Central, MI
First Remedial Action - Final
Abstract (Continued)
Creek identified a contaminated ditch containing oils with organic compounds including
PCBs and metals that was discharging into Cole Drain. In 1977, the State attempted to
stop the oil flow by damming the ditch. In 1978, EPA excavated sludge from the ditch and
removed the sludge using twelve 55-gallon drums for offsite disposal. Oils, ground
water, and various contaminants continued to enter the ditch, and the State
unsuccessfully attempted to filter oil out of the water. Between 1978 and 1986, the
State and EPA focused their efforts on finding and eliminating the source of the ditch
contamination through extensive investigations of area soil, ground water, and surface
water. Results indicated that ground water and soil surrounding and north of the
Chem-Central plant were contaminated with volatile and semi-volatile organic compounds.
In 1980, the State required Chem-Central to clean up the contamination and to institute a
ground water monitoring program. Consequently, between 1984 and 1985, three ground water
extraction wells, an interceptor trench, and a treatment system using an air stripper
were installed. Contaminated water, soil, and sludge were removed from the ditch and
placed in hazardous waste landfills, and the ditch was backfilled with clean soil. This
Record of Decision (ROD) addresses a remedy for contaminated onsite soil, contaminated
offsite soil surrounding and north of the plant, and the addresses a remedy for
contaminated onsite soil, contaminated offsite soil surrounding and north of the plant,
and the ground water contamination plume emanating from the plant and spreading 1,800
feet northward. The primary contaminants of concern affecting the soil and ground water
are VOCs including PCE, TCE, and toluene; and other organics including PAHs and PCBs.
The selected remedial action for this site includes installing an in-situ vapor
:xtraction system for onsite soil and two offsite soil areas north of the property, using
a network of horizontal piping, collecting contaminated vapors in the soil source area at
the vacuum pump, and treating these vapors using a vapor phase carbon adsorption system
before discharge to the atmosphere; continuing the operation and maintenance of the
current ground water collection and treatment system; installing, operating, and
maintaining an expansion of the current offsite ground water collection system either by
extending the current interceptor trench further east or north, or by constructing two
additional purge wells east of the current interceptor trench; installing and operating a
purge well in the deep lens of contaminated ground water beneath the main aquifer, and
connecting this well to the pump and treat system; treating contaminated ground water
using an air stripper with offsite discharge to a publicly owned treatment works (POTW);
collecting oil in the purge wells, and disposing of the oil at an offsite facility;
monitoring ground water; and implementing institutional controls including deed
restrictions. The estimated present worth cost for this remedial action is $2,099,000,
which includes an annual O&M cost of $170,000; or $2,131,000, which includes an annual
O&M cost of $172,900, depending on which offsite ground water collection option is used.
PERFORMANCE STANDARDS OR GOALS: Contaminant goals for soil are based on 10-6 cancer
level or the Human Life Cycle Safe Concentration (HLSC). Clean-up levels in soil must be
reduced to less than 20 times the ground water standard for each chemical, or soil leach
tests (TCLP) must produce leachate with contaminant levels below the ground water
clean-up levels. Chemical-specific ground water clean-up goals are based on health-based
criteria including 10-6 risk level or Human Life-Cycle Safe (concentration) and State
levels including TCE 3 ug/l (health-based), PCE 0.7 ug/1 (health-based), and
toluene 100 ug/l.
-------
RB.CORD OP DBCISION
SBLBC'1'BD RBKBDIAL AL'1'BRD'1'IVB
POR '1'BB
CBBK CBlf'l'RAL SIH
WYOKING, KICKIGAIf
SD~HT OP BUIS AND PURPOSB
This decision document presents the selected remedial action for
the Chem Central Site, in Wyoming, Michigan, which was chosen in
accordance with the Comprehensive Environmental Response,
compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and to
the extent practicable, the National oil and Hazardous Substances
Pollution contingency Plan (NCP). This decision is based on the
Administrative Record for this site.
The state of MiChigan concurs with the selected remedy.
ASSESSMENT OP '1'BB SIT!
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 OP 'I'D SBLECTED REMEDY
The selected remedy is for ground water and on-property and off-
property soils, with the exceptions noted below. The selected
remedy uses treatment to address the principal threats at the site.
Soils beneath the Chem Central building and paved areas on the Chem
Central property are not part of this remedy.
The major components of the selected remedy include:
o
continue operation of the current existing ground-water
collection and treatment system.
Install and operate an expansion of the current off-property
ground-water collection system, by either, extending the
interceptor trench or installing additional purge wells.
o
o
Install and operate a purge well at the deep lens of
contaminated ground water location and hook this-well into the
current ground-water collection and treatment system.
-------
\,
"
o
Collect oil accumulating in the purge wells and dispose of the
oil at an off-site facility in accordance with applicable
federal and state regulations.
Install and operate a soil vapor extraction system for soils
on-property as well as two off-property locations just north
of the property. .
o
o
zmpose institutional controls, such as deed restrictions to
prohibit the installation of water wells in the site area and
any future development that might disturb contaminated soils.
Implement a ground-water monitoring program capable of
demonstrating the effectiveness of the. ground-water capture
system and that ground-water treatment technology is achieving
clean-up standards.
o
STATUmRY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that are
legally. applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment or resource recovery
technologies, to the maximum extent practicable, and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mObility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years after commencement of the remedial action to
ensure that the remedy continues to provide adequate protection of
human health and the environment.
~/
Date
2
-------
-
nECISION SUMMARY POR TEE RECORD OP nECISION
CJmK CENTRAL SITB
nOKIMG, KICEIGAIt
'Ie 018.
....... ,
J .. Ita
'W.uDR
I
t. 1C8I_-
f","" A
KoIft
~
8o\P:II
.
,.". It. .
CHEa..CDmW. - i
lITE LOCATION I
SITB LOCATION AND DESCRIPTION
The Chem Central property is a 2-acre parcel of land located at
2940 Stafford Avenue in wyoming, Michigan (Figur.. 1 '2). The
Ci ty of wyoming is a southern suburb of Grand Rapids which is
located in west-central Michigan, approximately 25 miles east of
Lake Michigan in Kent County. There are approximately 10,000
people living within one mile of the site.
The site is situated in a mixed residential and commercial section
of the City of wyoming that includes small industrial facilities.
The nearest residences to the site are located approximately 500
feet west of the property boundary. The residential areas
primarily consist of single family residential homes. There are
two hotels located within approximately 800 feet of the site. The
"site" encompasses both a square shaped piece of property owned by
the Chem Central corporation which is the location of the--currently
operating plant and a rectangular piece of land owned by Consumers
-------
BuchAna.n Ave.
I I
-4l-c I
"'"
RESIDENTIAL
AREA
\ oa.
.,0
'(0 ..
Co .:I .
.. "
GD 0
o
Dd~
o
""
fI)
ti
~
...a
fI)
"" r-.-.-.-.,
fI) ~ --.,
~ -.-.-..J Consumers .,
q) . Power
~ L._."\. SubstatIon . ;
.
'--.-., .-.-.
.J
""
fI)
}
~
HillcroJt Ave.
~
!
ocru
D SIQAWO
I ~o\ ","'
Ce-O:
ye~ ; LEGEND
. . Air Stripper
6. Purge Wells
u.s. 'S,
---
400"
J
PIOURS Z
CHEMCENTRAL SITE MAP
n
<:
,0-
-------
Power extending north from the Chem Central property wi th the
approximate dimensions of 1,800 feet in length and 300 feet wide.
In addition, the site includes Cole Drain, and any place where
hazardous substances on 'the property have come to be located. The
Chem Central property is relatively flat however, the rectangular
piece of property consists of a more undulating terrain. Cole
Drain, a small urban creek flowing in a northerly direction, is
located along the site's western boundary. This creek receives
most of the surface runoff from the site. Cole Drain enters
Plaster Creek at a confluence approximately 2,500 feet north of the
site. Plaster Creek enters the Grand River approximately 2.5 miles
northwest of the si te. The Grand River flows to the west for
approximately 30 miles and enters Lake Michigan at Grand Haven.
The Cbem Central plant, constructed in 1957, receives bulk
chemicals by truck or railroad tanker and stores these chemicals in
on-site tanks before redistribution to various industries. The
plant consists of one structure with two loading docks and a rail
spur on the west side of the plant. Approximately 10 above ground
storage tanks are located along the plant's north side and are
surrounded by a concrete containment wall and paved ground surface.
The Chem Central property is fenced along the western and northern
property lines and the actual walls of the building serve as
barriers to entrance to the property on the south and east sides of
the property. The rectangular portion of the property extending
north from the Chem Central property is currently unused and
unfenced. The undulating terrain and sandy soils have however made
this area (south of 28th street) an attractive area to dirt bike
riders, as evidenced by the numerous trails criss-crossing the
terrain. The property to the east of this unused portion of the
property, is currently used as a transformer yard by the Consumers
Power company. Consumers Power owns the unused portion of the
site. The land adjacent to the site on the west is the right of
way for the Conrail Railroad Company's single line track. Adjacent
to the rail line is u.s. Route 131, a four-lane limited-access
highway. The adj acent property north and south of the site is
privately owned, and is occupied by commercial and light industrial
facilities. .
The subsurface geology of the site area consists of a glacial sand
deposit averaging approximately 30 feet in depth (see Piqur8 3).
Underlying this sand unit is a low permeable clay layer which acts
as an aquiclude to the migration of ground water from the upper
sand unit down into the underlying bedrock which is comprised of
gypsum and shales. The clay layer does contain small lenses of
sand and gravel but these lenses are not hydraulically connected to
the upper sand aquifer. There are no drinking water wells in the
immediate site area. The City of wyoming has a municipal water
supply which uses Lake Michigan as its source. An intake on the
Grand River (upstream of the site) is also used as a backup supply
during the summer. The nearest public well to the site is located
approximately 1.5 miles south of the property. An industrial well
2
-------
680
SOUTH
NORTH
21th ST.
870
~
~
~
(j
.........:.}~ (.42
1Jmmtmtffi%%1E
APPROXIMATE lOCA 110N
OF CHEMCEN1RAl F ACiUTY
860
2' ........ . . . .
............. ".""".'.....,..,...
. .............. """"""""....".'
... ............. '.'.".........'.".'..'
".'.........' .......................,
............. .........................
.................. ..............- ... ............,. .............. ..........................
. '.'.....'.......' ............... .... <...................... ............. "..'...'..'...'.""'..."
.................. ............... .... ...................... "..'.'.".'" ".'.'.'.".....'..."..'"
. ................. ............... .... ......................- .............--...........................
.................. ............... .... ...................... '.'.".'...'" ............................
. '..'........"... ............... .... '....'....'......'."" ............. -'.'."'.'...".".".......'
..mmMii::illi:¥ ;~#ffl7HBf: eg@ $~~B@~imllilb:
. .....,............ ............... .,.
. .,.....,.......... "."."'.'.'.. ...
- '....."'.'.'."" ..........,..,- ...
. .....,........... ............... ....
- .................. ..,............ ...-
. ................. ............... ....
. '....".'....".' ...,......... ...
. ."............ ........... ...
. ...........,... .......... ...
. ..............
. ..............
. .'.'...'....'
. '.'..'..".'
. ...........
650
840
,.,..".....,.."""...,......,.,
-.."..'....'.'..'...."...'.'.'..< ........................................
.................................. ........................................
.,.,..."........,....".,......" ...,.,.,.....,....,..,...,.,....."."""
'...'.'........"..".'.'.'.'...." ""..'...'..'..'.'...'.."..'...'.....' -
.................................... ".,..""............,...,.,.,......."
830
- ...........
. ."'...." .
. .........
. ........
820
610
LEGEND
Im1 Gravel ~ rwou Shall
EJ Sand a Silty Clay Well Screen Setting
~ Clay m Sand
~ Sandy Clay ~ Clay . Water Tobie
600
Depth (n)
GEOLOGY BENEATH CHEMCENTRAL SITE AREA
FIOURB
c:,
oP
-------
is located at the C.D. Osborn Company
approximately 500 feet south of the site.
Cole Drain is the only surface water body in the immediate site
area.. This creek is narrow and shallow and poorly suited for
swimming. However, there are areas of the creek where pooling
occurs and children could potentially swim. Fish inhabit this
creek, and it is possible that some occasional fishing occurs.
which
is
situated
SITB HISTORY AND BNPORCEMENT ACTrv7TIBS
The Chem Central property was undeveloped prior to construction of
the present plant. In 1957, the chemical distribution plant was
constructed. Between 1957 and 1962 hazardous substances entered the
ground at the plant through a construction error in a T-arm pipe
used to transfer liquid products from bulk storage tanks to small
delivery trucks. The T-arm pipe was located on the west side of
the building near the southwest corner. After losses in chemical
inventories were noted, the construction flaw was discovered and
then repaired. It is also possible that additional hazardous
substances entered the ground through accidental spills.
The Chem Central site first came to the attention of federal and
state officials in July 1977, when a routine biological survey of
Plaster Creek conducted by Michigan Department of Natural Resources
(MDNR), identified a contaminated ditch draining into Cole Drain
(tributary to Plaster Creek). The ditch was located north of 28th
street and east of Cole Drain. Sample analysis of the ditch
indicated oils contaminated with organic compounds, including
Polychlorinated Biphenyls (PCBs), as well as heavy metals to be
present. In 1977 the MDNR attempted to control the movement of oil
and other contaminants from the ditch into Cole Drain by damming
the ditch. In 1978, the United states Environmental Protection
Agency (U.S.EPA) excavated sludges from the ditch, resulting in the
removal of twelve 55-gallon drums for off-site disposal. Consumers
Power Company, which owned the ditch at that time, placed warning
signs and a fence around the ditch. Despite these efforts, ground
water, oils, and various contaminants continued to enter the ditch.
MDNR then attempted to filter water from the ditch and subsequently
pump it into Cole Drain. This attempt at preventing the oils and
contaminants from entering the drain was unsuccessful. Oil
absorbent booms were then used to collect oil from the surface of
the water of the ditch. In October 1978, MDNR and U.S.EPA then
focused all efforts on finding and eliminating the source of the
contamination. Between 1978 and 1986, an extensive investigation
was made of soils, ground water, and surface water around the Chem
Central plant and the area between Chem Central and the ditch north
of 28th street. The investigation was conducted by MDNR, U.S.EPA
and an environmental contractor to the Chem Central Corporation.
Results of the investigation indicated that ground water and soils
surrounding and downgradient of the Chem Central plant were
contaminated with volatile and semi- volatile organic compounds.
3
-------
\)
\J
In an effort to get the Chem Central corporation to clean up the
contamination and institute a ground-water monitoring program, the
MDNR filed a suit in the Kent county circuit Court in 1980. In
1984 the court ordered Chem Central to undertake clean-up
activities which included (1) defining the extent of contamination,
(2) designing, constructing" and operating a ground-water
collection and treatment system until court-ordered clean-up
standards were met, and (3) cleaning up contaminated soils in the
ditch. In the fall of 1984, as a result of the court order, three
ground-water extraction wells, an interceptor trench, and a water
treatment system (air stripper) were installed (see Pigur8 2 for
locations) . In 1985, also as a result of the court order,
contaminated water, sludges and soils from the contaminated ditch
were excavated and transported to hazardous waste landfills in
Michigan and New York. The ditch was backfilled with clean soil.
In December '1982, the Chem Central site was proposed for inclusion
on the NPL. In 1986, U.S.EPA issued a special Notice Letter to the
Chem Central corporation. In June of 1987, U.S.EPA and Chem
Central signed an Administrative Order By Consent (AOC) to conduct
a Remedial Investigation (RI) and Feasibility study (FS) for the
Chem Central site. In July of 1987 the site was finalized on the
NPL. Chem Central conducted the RI from 1988 through 1989. The FS
was conducted from 1989 through 1991.
COMMUNITY RELATIONS HISTORY
Community relations activities for the Chem Central site began ~n
July 1987 when a press rel.ase was issued seeking comments from the
public on the AOC. In July 1988, the community Relations Plan was
issued by MDNR. A progress report was first issued for the site in
July 1988 and another in March 1989. A public meeting was held at
the Wyoming City Hall on July 26, 1988 to discuss the upcoming
RI/FS for the site. A fact sheet for the RI/FS Meeting was written
and distributed to the public.
U.S.EPA took the lead for community relations for the Chem Central
site in ,1990. A fact sheet and press release were issued prior to
a March 1991 public meeting to discuss the results of the RI at
Chem Central. The U.S.EPA's Community Relations Coordinator for
the Chem Central site met with local city officials to discuss
issues related to the site prior to the public meeting. In
accordance with CERCLA section 117(a), the Proposed Plan for the
Chem Central site was released for public comment on July 10, 1991.
The public comment period began on July 10, 1991 and closed
September 9, 1991. A public meeting to discuss the Chem Central
Proposed Plan was held July 18, 1991. At the Proposed Plan public
meeting, U. S. EPA and MDNR discussed the remedial al ternati ves
considered, as well as the preferred alternatives.' Notice of the
Proposed Plan, the public comment period, the public meeting, and
the availability of the RI/FSand other site-related documents were
4
-------
published in the Advance (the local wyoming, Michigan newspaper)
and the Grand RaDids Press.
~e RI for the Chem Central site was released to the public in
March 1991, and the FS was released in July 1991. Both documents
were made available at the information repository maintained at the
wyoming Public Library. The Administrative Record was also made
available at this location.
All comments which were received by U.S.EPA during the public
comment period are addressed in the Responsiveness Summary, which
is part of this Record of Decision.
SCOPE um ROLE OP 'l'D DSPONSE ~C'1':rON
The selected remedy addresses several principal threats at the site
which include the contaminated soils surrounding the Chem Central
plant as well as areas of soil contamination north of the plant.
The remedy also addresses the ground-water contamination plume
which emanates from the plant and spreads northward for
approximately 1,800 feet.
Unacceptable risks to human health and the environment have been
identified for soils on and off the Chem Central property. Surface
soils on the Chem Central property present a risk to human health
through direct contact and incidental ingestion. contaminated
soils on and off the Chem Central property present a risk to the
environment due to potential for further migration of contaminants
into the ground water. The potential use of ground water as a
drinking water source also presents an unacceptable risk.
The role of this response action is to protect public health and
the environment from the unacceptable risks associated with the
Chem Central site. These risks included the potential ingestion of
and direct contact with contaminated soils: the possible ingestion
of contaminated ground water: the movement of contaminants from the
soils into ground water: and the discharge of contaminated ground
water into Cole Drain. '
These objectives will be achieved by expanding the current
collection/treatment system for ground water by adding additional
purge wells or extending the interceptor trench to capture that
portion of the ground-water contamination plume not currently
addressed by the system. An' additional purge well will be
installed on-site to collect and treat contaminated ground water
from a deep sand/gravel lens beneath the main sand aquifer. oils
contaminated with organic compounds, including PCBs, which are
accumulating in the active purge wells will be collected and
disposed of off-site in accordance with applicable federal and
state regulations. Soil vapor extraction will be-implemented to
address contamination in the on-property and off-property soils.
5
-------
Institutional controls and a ground-water monitoring program will
also be implemented.
Soils beneath the Chem Central building and paved areas on the Chem
Central property are not included in this response action. These
soils have not been ruled out as potential source areas for further
ground-water contamination for the following reasons:
1. Soils beneath the building and paved areas have
never been investigated subsequent to the discovery of
the flawed T-arm pipe.
2. The source of some contaminants (i.e., PCBs) in the
oil accumulating in the active purge wells has not yet
been identified. Because the levels of PCBs found in the
oil are several times greater than that found in the
surrounding soils which have been investigated, it is
possible that soils beneath the building and paved areas
are contaminated with PCBs and other organic compounds.
3. CUrrent soil analysis around the edges of the Chem
Central building indicates that some of the highest
levels of various compounds are located in these areas
(i.e., volatile and semi-volatile organic compounds),
possibly indicating that levels in adjoining soils
beneath the building may also be contaminated.
4. As evidenced by 35 years of aerial photos, the
present Chem Central building is the result of several
additions to the original structure. The possibility
exists that soil impacted by releases in the past is now
covered by buildings.
Based on the above facts, the soils beneath the building and paved
areas will need to be investigated further at a later date.
S~Y OP SITE CHARACTERISTICS
As Part of the RI, samples of soil, ground-water, sediment, and
surface water from the site and adjacent areas were collected.
Samples fram all media were analyzed for organic and inorganic
compounds.
HYDROGEOLOGY
A sand unit comprises the shallow aquifer in the site area. This
shallow aquifer is unconfined. The depth to the water table in
this aquifer varies from less than 5 feet near Cole Drain to 30
feet in the south eastern portion of the site area. The shallow
aquifer is fairly thin, with a saturated thickness of less than 10
feet to 25 feet. This sand unit thickens toward an area to the
,
-------
east of the Consumers Power Substation. The base of the aquifer
(top of clay) dips to the east in the site area.
The soils identified in cluster wells and borings have shown the
aquifer materials to consist of fine to medium grained sands with
variable concentrations of stones or gravel in apparently
interrupted layers. The shallow aquifer is underlain by a clay
layer. The underlying. clay, which has been penetrated to a
thickness of 38 feet, has a fairly uniform topography. It is a
clean to sandy gray clay. Sand and gravel lenses are also located
in this unit. The top of the clay dips to the east in the area.
The Chem Central plant overlies an apparent clay elevation closed
topographic high. The northeast area of the si te exhibi ts the
greatest degree of dip at the top of the clay.
Gypsum and shales of the Michigan Formation are encountered beneath
the sand and clay units in the northeastern portion of the site
area. A 5 foot thick sand layer is encountered. between the base of
the clay and bedrock in the northern portion of the site area.
Ground water flow in the shallow sand unit is to the north. The
ground water in the area appears to flow roughly parallel to the
north trending seqment of Cole Drain before beginning to enter the
underdrain approximately 700 feet north of 28th street. The
hydraulic gradient in the area changes from approximately 0.4
percent south of 28th Street to 2.4 percent north of 28th street.
This trend may be consistent with a generally northwest thinning of
the aquifer.
In-situ permeability testing and analysis reveals that the
permeability varies from values of a little less than 100 gallons
per day per square foot to 600 gallons per day per square foot. An
average permeability of 260 gallons per ,day per square foot appears
to be the typical permeability value.
contaminant ADalv...
The analytical results of the sampling are presented in Tabl. 1.
Analysis of the samples indicates that soils contain approximately
twenty-two different organic compounds (volatile and semi-
volatile), at concentrations above background soil levels,
including low levels of PCBs. An estimate of the volume of
contaminated soil on the Chem central property is approximately
6,200 cubic yards.
Analysis of ground-water samples indicates that it contains
approximately thirty-five different organic compounds (volatile and
semi-volatile) at concentrations above background (upgradient)
ground-water levels. The majority of these contaminants are above
the Maximum Contaminant Levels (MCLs) in the Federal Safe Drinking
Water Act and the Michigan Act 307 Type B criteria.
7
-------
TAbLE I
SUMMARY OFTHE OCCURRENCE OF CHEMICALS
CENTRATION
DOWNSTREAM
COMPOUND.
well . c~cent\TOTAI.SUM.XU
(continued)
OIemCcntrlll20986
-------
TABLE t
SUMMARY OF THE OCCURRENCE 0' CHEM'tCALS
~OMPOUND.
~jA'W,,*)t;j~~;,t;~,~~{l~~~~W;*~
a.S~(i~ETnYLnE"V~)pnl. .. '"LXfi'lni'if~'14~'J i;ij.f~ "J,tv. ',fl,' ".Nlf'~" . "~~ .., ""0"1'"15 .'. ""ND".(..?>".....,......,.~i!",.........,.,...%I""""6"1""1'" .Wiidj....t:...,w"""",,,,,,,x,,x,,,,,,,,,,,,,,,,w""'6Il" ...
iiaialat:~e:11::
Ii55IBla~aal:
..mNAN11IREHB ISO'I O.J. 0.11 0.5. J, '9 ND 0' " 1.2 1.2 1.2 , '2 .. 0:91"'" 0.97" "'0:"'''''''''2''-1 ... ..
:~~~f~I'!1¥~1~i~;P~
"PROPYLPIffiNOL . .. NA . .~A. .. . NA. . NA'''' ...........,.. ........ .....................,.
~jffij~~kgq\~~IIt~.ii[ :iH~"'_.I'i: :i[;N~_liir :~::U~~- I.H~\:.m~fj;\I~:riff~ttlfr{~~@i~: i\1
iiii'YDRo."NDBNB-ONB NA NA NA NA' . ...... .,..... ...... . ..,.... .......,.... ..
~~!t=;ZC=:~.:
. Swf_SoII"".""''' ...,e...... """"'010 2 foaellll,,, ellherClllllplele" or"""
. Qemlal, Ia BOLD pdnt... WIa8ar"""
.. c-..1ncIucIeI1II ,.1c8Ie ... ~WIIJ h. ......
NA. Not AnI,,'" rOf laIN, uu/8.a.
ND.Not~
-------
TABLE I
SUMMARY OFTnE OCCURRENCE OF CHEMICALS
~OMPOUND.
CAS No.
(conlinucd)
wdl. c~hemccn"TOI'ALSUM.XLS
p.
-------
TARLE I
SUMMARY 0... TilE OCCURRENCE 0... CIIEMICALS
GROUNOW A TER CONCENTRATIONS m
UPGRAOIENT OOWNGRADIENT
..
DEEP WELLS
COMPOUND-
CAS No.
Ave
Ave
Count..
Ave
ount
BEN7.0 (It) nUORAN111ENB NO 0' 15 NO 0 , 40 NO 0 , 8
..'
ISOPIiORONB 18591 ND 0' 15 ND 0' 40 NO 0' 8
i~!.~"..)~-g??U~~~1~~ffl~~
~al}Jf-~rpU ~lh~~Pf1t;~ 1,m:~Hi\.~
PIiENAN11IRENB 15011 ND 0'" ND 0' 40 ND 0' 8
:JJ~~SY~iA1Ii~*j@UM1&MiWWM*iJfJJj}J.H1MH ):~.f'NMM%lMmM1MMm@tm;i1} ...~... .t,:.~:...,..:.jfff:;::.rn:Wl.:;:lt:::... \:."::mt:{t:~tm:::lt\ttilIJ:@@ltt:~tt:H
'iPRoP\iiHENOL" .... .' NA 0.008 0.002 0.015 2/2 NA .. . ......... ..
!~"~i!~~~:n:~~:
D~f~~~;~U;~if~~~£~
. 0Ian1cal. in BOlD print ...lndlc:alor ..leal.
.. Coun8 Include. .11 ",icaIe ... -.....- .......
NAm Nat AnilrDd for in thi. .~-
ND = Nat Ddeded
.. The ..ndielll ... dD-1fIIIIaII an-dwlltr""" ... f- . ehlllo- equlfa. No 8pI.llllenldeep wen..... """11.
-------
TABLE I
SUMMARY OFTHE OCCURRENCE OF CIIEMICALS
SURFACE WATER CONCENTRATIONS m
UPSTREAM DOWNSTREAM
COMPOUND.
CAS No.
Ave
Count..
Ave
Count"
well, c:'chemca1t\1UTALSUM.XLS
(contlnueel)
-------
TABLE I
c.
SUMMARY OF TilE OCCURRENCE OF CIIEMICALS
COMPOUND.
CAS No.
!~~~.~)'!M~~~.~~i!5]~'m...~mt:m-»"wm<'..'">'.'~'f.t'~%'.'.
ii~
OIRYSENB 15611
»i~~~@~fmD'I.-~t~1~!Ifm~1\i:il;!\:.
DIE11IYLJ>HALA1B 14662
!;~~'~II:filffm~.'1~1!lii;;1~~:;\@ltf,i1[liili;t\::
DI.N.OCfYLPlI11IALA1B 111840
~Y.9~9Mm!B;j\tiiifiltj\r&tBtVili::!~!afj[r!f\li.fiit[::
ISOPIIORONB 11S91
~;~~:~::,,:':':.':::.::::~. " Jm\::f':11,=\:~mt[l1l;rtl
%-ME11IYlPIlENOI. 95481
:~~~'.1_11fl~m1::~WJJ'[~iI&~~~t.~[i.;i\\.
:~~~.~m~tji{t:ff@.I.Jlli1\;;::.?~!::~[WI\!1.t~m*::l::
e~~=-
:~~.~,~~~;;;@ilm@;gw'Hi~MM%W@ft{ti:I@f\I'lnnlI
ii~M~~i[Wt:l~jli~i.8IiB.fti.E;~~~\*\~It1tii\ii1;jl
D,IIIYDRO-INDENB-o.N.B ". " "." " " . . "". ..
iM>*OCARti6tini6.,mm;%fMH!\'
-------
Analysis of sediment samples from Cole Drain indicates that Cole
Drain contains low levels of a few organic compounds. However,
most of these compounds were also detected in upstream samples
indicating that these compounds probably originated from a source
other than the contaminated soils on the Chem Central property.
Analysis of surface water samples from Cole Drain did not detect
any contaminants. oils accumulating in two of the active purge
wells at the site were analyzed. The oil contains approximately
fourteen different organic compounds, including PCBs, at high
levels.
Po~8D~ial Kiara~ioD Pathwavs
The potential migration pathways identified for the Chem Central
site include the following:
AIR: The public may be exposed to contaminants in air emitted from
the air stripping tower or that volatilize from contaminated soils.
The potential exposure points are the property itself, nearby
homes, nearby businesses, a nearby hotel, and nearby schools.
SURFACE WATER: A portion of the ground-water contamination plume
(as much as 10% of the total plume) is bypassing the current
ground-water collection/treatment system. This ground water is
most likely discharging into Cole Drain and therefore may be
impacting the surface water and sediments quality. If the ground-
water collection/treatment system were to fail, or be shut down,
there would be a potential increase in the contaminant load to Cole
Drain.
SOIL: Persons working on the Chem Central property may be exposed
to contaminants in the soil by direct contact with the soil or by
incidental ingestion of the soil. The majority of the contaminated
soil is currently covered with pavement' or loose gravel. If the
pavement or gravel areas were disturbed, the potential for exposure
would increase. Under a future residential scenario, pers.ons in
the vac~nt area extending north of the Chem Central property (and
south of 28th street) may be exposed to contaminants found in these
soils. This area is a1so subject to wind erosion and fugitive dust
may be generated. Persons could be. exposed to contaminants in
these soils by inhalation of fugi ti ve dust or direct contact.
Volatilization of chemicals from the soil could also occur.
contaminated soils on and off the Chem Central property act as a
major source for ground-water contamination. As precipitation
moves through these contaminated soils it carries contaminants into
the aquifer.
GROUND WATER: Ground water beneath the site area is contaminated
with organic compounds. The ground-water contamination plume
originating from the Chem Central site presently does not affect
any drinking water wells. If the current collection/treatment
---... .~...
8
-------
:. .
. system were to fail, or be shut down, the ground water would
discharge into Cole Drain and not affect any existing wells. The
exposure pathway is based on the potential that a drinking water
supply well could be placed in the affected area of ground water in
the future.
SUKMARY OP SITE RISKS
A baseline ~isk assessment was conducted for the Chem Central site
as part of the RI. The baseline risk assessment was conducted in
accordance with the Superfund Public Health Evaluation Manual
(U.S.EPA, 1986) and, to the extent practicable, the Risk Assessment
Guidance for superfund (U.S.EPA, 1989).
Unacceptable risks to human health have been identified for direct
contact with or ingestion of the surface soils on the Chem Central
property: and for the ingestion of ground water from the plume area
beneath the site. .
Unacceptable risks to the environment have also been identified for
the soils on and off the Chem Central property and for the surface
water in Cole Drain. The risks from soils are primarily due to the
potential migration of contaminants from the soils into ground
water. The potential risk to surface water in Cole Drain is due to
that portion of the contaminated ground-water plume bypassing the
current collection system. Some of the contaminants present in
ground water could potentially pose a risk through bioaccumulation.
The risk assessment, which includes the identification of site-
specific indicator chemicals, an exposure assessment, a toxicity
assessment, and a risk characterization, is described in greater
detail in the following sections.
Indicator Chemical.
Indicator chemicals were selected from the fifty-one organic
chemicals that were detected at the Chem Central site. The
indicator chemicals for the Chem Central site where selected to
represent the most toxic, mobile, and persistent chemicals at the
site, those chemicals present at the highest concentrations and the
chemicals most prevalent at the site. The indicator chemicals at
the Chem Central site include VOCs, SVOCs, PCBs, and heavy metals.
Table 2 lists the specific indicator chemicals for the Chem Central
site.
Exoosure Assessment
The potential risks to human health and the environment were
calculated based on the assumption that no future remedial actions
would be taken at the si te. The media for which risks were
calculated included air, surface water (Cole Drain), soil on the
Chem Cent~al property, soil on the vacant property _~~~h of the
,
-------
TABLE 2
Indicator Chemicals
1. 1, 1-Dichloroethylene
2. Vinyl Chloride
3. Trichloroethylene
4. Tetrachloroethylene
5. 1,2-Dichloroethane
6. Bis(2-ethylhexyl) phthalate
7. PCB
8. Naphthalene
9. pyrene
10. trans-1,2-Dichloroethylene
11. Toluene
12. Arsenic
13. Zinc
-------
Chem Central property, and ground water. The risk assessment
scenarios for each media included: (1) existing site conditions
with the collection/treatment system on: (2) existing site
conditions with the system off: (3) future site conditions with the
system on: (4) future site conditions with the system off: and (5)
future residential development with the system off.
The human populations potentially exposed to the contamination at
the site include persons working at the Chem Central plant,
children who may play in Cole Drain or in areas where contaminants
have been detected in soils, employees of nearby businesses, hotel
residents, and residents of nearby areas. In addition, it was
assumed that drinking water supply wells would be installed in the
area of ground-water contamination. The users of these wells may
also be exposed.
Several ecosystems and animal populations, in addition to natural
resources, may be potentially exposed to contamination at the Chem
Central site. The potentially exposed ecosystems and animal
populations include small to medium sized trees (siberian elm, box
elder, and cottonwood), shrubs and other weedy species. Cole Drain
also supports some filamentous algae and watercress. Animal
populations include fish, amphibians and reptiles, mammals and
birds. Common species are listed in Ta!»18 3. Threatened or
endangered species that may be found in the Grand Rapids area
include the peregrine falcon, cooper's hawk, red shouldered hawk,
marsh hawk, osprey, black rat snake, eastern box turtle, and least
shrew. The primary natural resources at the Chem Central site are
the ground-water aquifer and Cole Drain.
The following potential routes of exposure were quantitatively
evaluated for the human and animal populations at or near the Chem
central site. All exposure routes were evaluated for short-term
and long-term exposure to adul ts and short-term exposure to
children.
Human population
o Inhalation of air emissions from the stripping tower:
o Dermal contact (swimming) with water in Cole Drain:
o consumption of fish from Cole Drain:
0 Dermal contact with soil and sediments:
0 Ingestion of soils, sediments, and ground water.
Animal population
o
Drink, swim, or feed from Cole Drain.
10
-------
TABLB 3
COMMON SPECIES FOUND IN URBAN AREAS OF SOUTHERN MICHIGAN
Bird.:
English sparrows
Rock doves
Starlings
Grackles
Red-winged black birds
Pheasants .
Mourning doves
Song sparrows
White-throated sparrows
Chickadees
Downy woodpeckers
Nuthatches
Mallards
Yellow warblers
~-.l.:
Norway rats
Muskrats
Raccoons
Opossum
Skunks
Fox squirrels
Flying squirrels
White-footed field mice
Bats
Moles
Shrews
Woodchucks
Cottontail rabbits
..ptil.. , Ampbibian.:
Garter snakes
Ribbon snakes
Eastern box turtle
Green frogs
Leopard frogs
American toads
Pialn
sticklebacks
Minnows
Bluegills
Carp
Steelhead (in Plaster Creek near Cole Drain confluence)
-------
Q'
Intake of the indicator chemicals was evaluated for the human
populations in these scenarios under worst case conditions. The
exposure points were assumed to be in the area with the highest
concentrations of indicator chemicals. The major assumptions
(e.g., body weight, frequency, and duration) used to evaluate both
carcinogenic and non-carcinogenic risks for the identified exposure
routes are presented in ~&bl. 4.
In addition, a qualitative evaluation of relationship between the
on and off property soils at the Chem Central site and the ground
water beneath them was performed.
Toxicitv Assessment
Cancer potency factors (CPFs) have been developed by U. S. EPA' s
carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcino~enic
chemicals. CPFs, which are expressed in units of (mg/kg-day) - ,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 the actual cancer risk highly unlikely. Cancer
potency factors are derived from the resul ts of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by U.S.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 media (e.g., the
amount of a chemical ingested from contaminated drinking water) can
be compared to the RfD (hazard index). RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors help
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur.
The cancer potency factors (slope factors) and the reference doses
used to evaluate the potential risks at the Chem Central site are
presented in ~a1)1. 5. 1,1-Dichloroethylene, vinyl chloride,
trichloroethylene, tetrachloroethylene, 1,2-Dichloroethane, bis (2-
ethylhexyl) phthalate, PCB, and arsenic are pptential human
carcinogens. These chemicals, and other indicator chemicals
(Trans-1,2-Dichloroethylene, naphthalene, pyrene,' toluene, and
11
-------
TABLE ..
SUMMARY OF CONSTANTS USED TO ESTIMATE CHEMICAL INTAKES
lo-YearOld
OJild Adult Reference
AIR
Body weight (kg) 36 70 U.S. EPA. 1988
Inh21ation rate (m3Jbr) 1.3(1) 1.1 (1) U.S. EPA. 1988
. Exposure period (days) 3650 25600 U.s. EPA. 1988
Frequency of exposure (evems) 3650 25600 U.s. EPA. 1988
On-site duration of exposure (bo1m) 0 8
Off-site duration of exposure (homs) 24 16
SURFACEWATER .
DuraDon (hours/event) 2.6 NA U.S. EPA. 1988
Skin surface area (em2) 11800 NA U.s. EPA. 1985
Body weight (kg) 36 NA u.s. EPA. 1988
Frequency (evems) 70 NA U.S. EPA. 1988
Petmeability (cmIbour) (see Table 1-2) U.S. EPA. 1988
Exposure period (days) 3650 25600 U.S. EPA. 1988
Fish consumption (kg/day) 0.0016 0.0016 U.S. EPA. 1988
Water ingestion (1Jbr) 0.050 NA U.S. EPA. 1988
SOIL
Soil ingestion 1m (g/day) 0.2 0.1 U.S. EPA. 1989
Skin surface area (em2) 7.764 4,515 U.S. EPA. 1985
Dust adherence (kg/cm2) 2.77xl~ 2.77xl0~ U.s. EPA. 1988
Body weight (kg) 36 70 U.S. EPA. 1985
Exposure period (days. off-site) 3650 25600 U.S. EPA. 1988
Exposure period (days. em-site) 2740 19180
Frequency (days) 640 13650
GROUND WATER
Ingestion Rate (liters/day) 2 2 U.S. EPA. 1988
Exposure Frequency (daysl)'ear) 365 365
Exposure Duration (years) 10 70 U.s. EPA. 1988
Body Weight (kg) 36 70
Averaging Tune (days) 3650 25600
-----
NA: Not Applicable
(1) Weighted average. See text for explanation
-------
TABLB 5
<>
REFERENCE OOSF..s (CHRONIC AND StJBCHRONIC) AND
CARCINOGENIC SLOPE 'AcrORS 'OR INDICATOR CIIEMICALS.
Oral
Indirator Cbemiral
1,I-DICm.OROB11lYU!NB
VINYL Cm.ORIDB
TRICm.OROETIIYU!NB
TETRACtn.OROB11lYLI!NB
1,,2-DICtn.OROB11lANB
BIS-(2-B11fYL HBXYL) PH11IALA11!
PCB-1248
NAPtrrHALENB
PYRBNB
TRANS-I,,2-DICJD.OROB11IY1J!NB
TOLUENB
ARSBNlC
ZINC
0.009(1)
HI A
HlA
0.01(1)
HI A
0.02(1)
N/A
0.004(2)
0.03(5)
0.02(1)
0.3(1)
0.001(2)
0.2(2
(I) IRIS ~umen~ . .
(2) Health Effects Assessments Summary Table. 3I'JO
(3) Derived in telt
(4) Standard based on Amclor 1260
(5) Flaga, 1990
N/A = Not Available
C = Carcinogen
HC = Non-Carcinogen
0.009(2)
H/A
H/A
0.1(2)
H/A
0.02(2)
H/A
0.004(2)
H/A
0:2(3)
0.4(2)
.0.001(1)
0.2(2)
0.6(1)
2.3(2)
0.011(2)
0.0"(2)
0.091(1)
0.014(1)
7.7(1)
N/A
N/A
N/A
MIA
1.75(1)
MIA
ClNC
C
C
C
C
. C
C
C
HC
NC
NC
NC
C
NC
Inhalation
Slope
factor ClNC
(m (ta ~-I
H/A 1.2(1) C
H/A 0.295(2) C
H/A 0.017(2) C
H/A 0.00033(2) C
HlA 0.091(1) C
HlA 0.015(3) C
H/A 3.5(3)(4) C
H/A H/A HC
H/A H/A HC
H/A N/A HC
2.0(2) N/A HC
H/A 50(1) C
N/A N/A NC
N/A
N/A
N/A
HI A
N/"
N/A
N/A
N/A
N/"
N/"
2.0(2)
N/A
N/"
-------
zinc), also have the potential for causing acute and chronic
noncarcinogenic health effects in humans.
Jisk Cbarac~eriza~ioD
Human Health Risks
EXcess lifetime cancer risks are determined by mUltiplying the
intake level with the cancer potency factor. These risks are
probabilities ~at are generally expressed in scientific notation
(e.9., 1 X lo-"br lE-6). An excess lifetime cancer risk of 1 X 10-6
indicates that, as a plausible upper bound, an individual has a one
in one million chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions identified.
potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminants's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The
HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single
medium or across media. Noncarcinogenic risks are considered to be
unacceptable if the hazard index is greater than 1.0, tha~ is, if
the intake of a chemical exceeds the established reference dose for
that chemical.
At the Chem Central site, unacceptable human health risks have been
calculated for exposure to the on-property soils and ground water
(Table 6). An unacceptable carcinogenic and noncarcinogenic risk
for children and adults under worst case conditions exists for
. ingestion and dermal contact with soils on the Chem Central
property. The estimated carcinogenic risks due to long-term derma~
exposure and ingestion of on-property soils by adults is 1.0 X 10- .
The estimated risk due to 10n1-term exposure of adul ts to on-
property soils is 2.5 X 10- , when arsenic is removed from
consideration. The noncarcinogenic Hazard Index calculated for
dermal contact and ingestion of on-property soils by children
(short term) under worst case conditions is 1.2, while the Hazard
Index for adul ts (short term) is 1.1. It was assumed that the
exposure to soils was the same whether the ground-water collection
system was in operation or not. Therefore the risks posed by the
80il would not change over time. The 80il exposure route is
currently not complete as the on-property 80ils are covered with
pavement or loose gravel. This exposure route would be completed
however, if the pavement or gravel is disturbed. .
.
12
-------
'1'ABLE ,
SUMMARY OF HAZARD INDICES
EJtisiting Conditions Future Conditions Residential
System On System Off System On System Off System Off
r Child Shon- Tenn
Air 3.6 E4 0 3.6 E4 0 0
W~ (Cole Drain) 0 2.3 E-6 0 1.2 E4 1.2 E4
orr-sile Soil 4.2 E4 4.2 E4 4.2 E4 4.2 E4 4.2 E4
On.Sile Soil 0 0 0 0 1.2 E+O
Ground WIJD 4.0E+l 4.0 E+ 1 4.0 E+ 1 4.0 E+ 1 4.0 E+ 1
Total with Ground Water: 4.0 £+1 4.0 £+ 1 4.0 £+1 4.0 £+1 4.1 £+1
Total without Ground Water: 7.8 £-4 4.2 £-4 7.8 £-4 5.4 E-4 1.2 £+0
Adult Shon- Tenn
Air 1.6 E4 0 1.6 E-4 0 0
W.. (Cole Drain) 0 1.2 E-6 0 6.4 E.S 6.4 "E.S
Off-site Soil 3.7 E4 3.7 E4 3.7 E4 3.7 E4 3.7 E-4
On.Site Soil 0 0 0 0 1.1 E+O
Ground Water 2.0 E+ 1 2.0 E+ 1 2.0 E+ 1 2.0 E+l 2.0 E+ 1
Total witb Ground Water: Z.O £+ 1 Z.O £+ 1 Z.O £+ 1 1.0 £+1 1.2 £+ 1
rrotal without Ground Water: 5.2 £-4 3.7 £-4 5.2 £-4 4.3 £-4 1.1 £+0
Aduh LOlli'. Tenn
Ail 1.9 E-6 0" 1.9 E-6 0 0
WIJI/l (Cole Drain) 0 1.2 E-6 0 6.5 E.S 6.5 E.S
Off.site Soil 2.0 E-3 2.0 E.3 2.0 E.3 1.0 E.3 2.0 E-3
Qa-Sile Soil 0 0 0 0 6.4 E.l
Ground Water 1.8 E+ 1 1.8 E+l 1.8 E+ t 1.8 E+ 1 1.8 E+t
Total with Ground Water: 1.8 £+1 1.8 £+1 1.8 £+1 1.8 £+1 1.8 £+1
Total without Ground Water: Z.O £-3 2.0 £-3 2.0 £03 2.0 £-3 6.4 £01
NOte: The IOIa1s shown are the sums of the hazard indices for various exposure routes
SUMMARY OF TOTAL RISKS
EJtisiting Conditions Future Conditions Residential
System On System Off System On System Off System Off
Adult LonJ. Tenn
Ail 2.5 E- 7 0 2.5 E- 7 0 0
WIJI:I (Cole Drain) 0 2.4 E-I0 0 1.7 E-8 0
Off.site Soil 7.1 E.7 7.1 Eo7 7.1 Eo7 7.1 E.7 7.1 Eo7
On.Site Soil 0 0 0 0 1.0 E-3
Ground Wiler 9.1 E.2 9.1 E-2 .9.1 E.2 9.1 E-2 9.1 E-2
Total with Ground Water: 9.1 £02 9.1 £.2 9.1 £.2 9.1 £.2. 9.2 £.2
Total without Ground Water: 9.7 £.7 7.1 £.7 9.7 £.7 7.3 £.7 1.0 £.3
-------
The ingestion of ground water from the site area poses unacceptable
carcinogenic and noncarcinogenic risks to children and adults under
worst case conditions. The estimated carc~nogenic risks to adults
from exposure to ground water is 9.1 X 10- . vinyl chloride is the
major chemical contributing to the carcinogenic risks. The
noncarcinogenic risk for children (short term) ingesting ground
water is calculated at 40. The noncarcinogenic risks for adults
ingesting ground water is 20 for short-term and 18 for long-term.
These risks do not take into account the currently operating
ground-water collection/treatment system. This exposure route is
presentlY not complete, as no drinking water wells currently exist
in the area of ground-water contamination. The exposure route is
based on the potential that a drinking water well would be
installed in the area of ground-water contamination.
Environmental Risks
A survey of wildlife in the site area has not been conducted.
However, it is probable that species commonly found in urban areas
in southern Michigan occur at the property (... '1&))1. 3).
. Threatened or endangered species that may be found in the Grand
Rapids area include the peregrine falcon, cooper's hawk, red
shouldered hawk, marsh hawk, osprey, black rat snake, eastern box
turtle, and least shrew. wildlife in the area could potentially be
impacted by chemicals at the si te if the currently operating
ground-water COllection/treatment system were to fail or be shut
off. This is based on predicted contaminant load of indicator
chemicals entering the drain under low flow conditions. potential
risks to animal populations from chemicals entering the drain
include bioaccumu1ation.
Ground water is a natural resource that has been impacted by
contaminants at the si te. Soils on and off the Chem Central
property present a risk to the environment due to the potential for
migration of contaminants into the ground water. contaminated
soils act as a continuing source to ground-water contamination as
precipitation moving through the soils carries the chemica~s into
the aquifer.
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 human health, welfare, or the
environment. "
DESCRIP'rIOIf 01' AL'IERNA'IIVBS
Based on the results of the RI and Baseline Risk Assessment, a FS
was conducted to identify and evaluate different alternatives for
protecting human health and the environment from una«=ceptable risks
posed by the Chem Central site. The remedial action objectives for
13
-------
the site are to prevent current or future exposure to both
contaminated soil on and off the Chem Central property: prevent
exposure to contaminated ground water in the site area: prevent
further migration of contaminants in soil down into ground water:
and prevent discharge of contaminated ground water into Cole Drain.
The FS identified seven remedial alternatives for soil and seven
remedial alternatives for ground water. A No Action alternative
was included as part of the array of ground water alternatives. The
No Action alternative addresses both ground water and soil. The
alternatives considered involve a variety of containment, removal,
and treatment technologies, and are described in greater detail in
the following sections and within the FS. .
GROmm D'l'ER
ALTZRnTIVB OW-A - NO ACTION: DISCOHTIHUB Ctr1UU!:HT UKZDIAL ACTIONS
The National contingency Plan (NCP) requires that. the no action
alternative be considered at every Superfund site. Under this
alternative, with the exception of institutional controls, such as
deed restrictions, and ground water monitoring, no remedial
activities would be implemented. The current ground-water
extraction and treatment system would be discontinued.
Capital coat
o , II (aDDual)
preaent worth
$ 5,000
$ 25,000
$ 410,000
COHTIHUB Ctr1UlBHT UKBDIAL ACTIONS
AL'1'ZRnTIVB OW-B:
This alternative would continue the current remedial activities
required under the existing state court order. These remedial
activities would consist of: (1) collecting ground water via purge
wells and an interceptor trench, (2) transporting the collected,
untreated water through a force main to a treatment system, (3)
skimming off the floating oil layer in an oil-water separator, (4)
treating the collected ground water on-property via an air
stripping mechanism, (5) transporting the treated ground water
through a force main to the discharge point, (6) discharging the
treated ground water to the City of Wyoming' s Waste Water Treatment
Plant, and (7) treating air emissions from the air stripping device
using a vapor phase carbon adsorption system. Treatment residuals
generated from the air stripper would have to be treated as a
hazardous waste if they fail the Toxicity Characteristic Leaching
Procedure (TCLP). This alternative also includes quarterly
monitoring of ground water.
capital coat $ °
o , II (aDDual) $ 108,000
Present Worth $ 1,400,000
Estimated Time until Clean-Up Objective
%8 Xet:
10 years
14
-------
&I,yR1t1ftTIVB C;W-C:
EXPAND CtJRREN'1' GROmm-WATER COLLECTION SYSTEX
OFF-PROPERTY
This alt.ernat.ive involves t.he expansion of the current. ground-wat.er
collect.ion syst.em (as described in Alt.ernat.ive GW-B) north of 28t.h
street. to capture ground water currently not being captured east. of
the trench. There are two opt.ions for expanding the current
system:
Opt.ion 1: The current. intercept.or trench would be extended
further east. or north t.o capture ground water current.ly bypassing
the syst.em. The int.ercept.or t.rench would consist. of a 4-inch
polyethylene corrugat.ed perforat.ed pipe imbedded in pea st.one
gravel. This passive system would be placed approximat.ely 10 feet
below the wat.er table. The pipe would slope so that. infiltrat.ing
ground wat.er would flow by gravit.y t.o the lift. station which then
pU8pS the collected ground water back to the air stripper.
Opt.ion 2: Two purge wells would be const.ruct.ed east. of the
current. interceptor trench to a depth of approximately 10 feet..
The ground water would be pumped from the wells t.o the lift station
and then to the air stripper for treatment.
For either option the ground water collect.ion rate is est.imat.ed at.
5 gallons per minut.e (gpm). This estimate is based on the current
interceptor trench's collection rate and the geologic
characteristics of the aquifer north of 28th street. Ground water
collected by eit.her of t.hese options would be treated as outlined
in a1t~rnative GW-B, the current ground-water treatment system.
Treatment. residuals generated from the air stripper would have to
be treat.ed as a hazardous waste if they fail the Toxicity
Characteristic Leaching Procedure (TCLP).
Option 1:
capit.al coat.
o , II (aDDual)
pre.ent. Wort.h
$ 34,000
$ 0
$ 34,000
option" 2:
capit.al coat.
o , II (aDDU&!)
Pre.ent. Worth
$ 28,000
$ 2,900
$ 66,000
..ti.ate4 Ti.e until Clean-Up Objective Ia Ket.:
10 years
ALUJlDTIVB GW-I)I BXPA1m COUBN'1' GROmm-WATER COLLECTION SYSTEX
ON-PROPERTY
As described in the RI Report, a sand and gravel lens is locat.ed in
the clay layer beneath the sit.e. Ground-water samples from t.his
lens showed organic chemicals to be present. This indicates that.
cont.amination is present at greater depths in this area than in
15
-------
-
c .
other areas at the site. This sand and gravel lens is located near
the northwest corner of the Chem Central property. This
alternative includes adding a purge well to the current ground-
water collection system to address this deep area of contamination.
A 4-inch well would be placed to a depth of approximately 45 feet
to collect ground water in the sand and gravel lens. Ground water
would then be pumped directly to the air stripper for treatment.
The collection rate of ground water is estimated at 1 qpm. The
collected qround water would be treated as outlined in Alternative
GW-B. Treatment residuals generated from the air stripper would
have to be treated as a hazardous waste if they fail the Toxicity
Characteristic Leaching Procedure (TCLP).
capi~al C08~
o , II (aDDual)
Pr.aen~ Wor~h
$ 18,000
$ 1,500
$ 38,000
.atiaate4 Tiae Until Clean-Up o~jective 18 .et:
10 years
ALTBlUm~IVB QW-s:
COLLBC'l'IOH UD
I'LOATABLE OILS
OI'I'-PROPBRTY
DISPOSAL
01'
As described in the RI Report, there is a thiri film of floating oil
accumulating in two of the active purge wells at the site. This
alternative includes the removal of this oil by manual bailing.
The collected oil would be disposed off-site in accordance with
applicable requlations. If PCBs are present in the oil,
incineration of the oils may be necessary. It is believed 90' of
the floatable oils can be recovered from the aquifer and will be
destroyed. This alternative assumes that the purge wells will be
operating (Alternative GW-B), since the ground-water flow created
by the purge wells causes the oils to accumulate. A conservative
estimate of the amount of oil to be collected is two gallons
annually.
capital C08~
o , II (aDDual)
pre.ent Worth
$ 0
$ 3,200
$ 42,000
Batimate4 Time until Clean-Up O~jective Ia Xet:
10 years
ALTBlUmTIVB QW-!,:
TaBAT COLLBCTBD GROmm-WATBR BY ULTRA-VIOLBT-
O%IDA'rIOII
This alternative includes treating collected ground water by ultra-
violet oxidation instead of the currently used air stripping
method. UV-oxidation is a chemical oxidation process which uses
oxidizing agents such as ozone and/or hydroqen peroxide enhanced by
ultraviolet light (UV) to oxidize organic compounds. In this
process, many organic contaminants absorb UV light. and undergo a
change in their chemical structure or become more reactive with the
oxidation agents. Commercial treatment systems have been developed
l'
-------
in which the oxidation agent is injected into the ground water. The
ground water would then pass through a UV light cell. Both
hydrogen peroxide and ozone were also considered as oxidants. This
system could be constructed and operated on the site to treat the
ground water collected by the current ground-water collection
system.
capital co.t
o , X (aDDual)
pr...nt wortb
$ 670,000
$ 232,000
$ 3,700,000
..tiaat.4 Ti.. until Cl.an-Up Obj.ctiv. %. X.tl
10 years
aLHRDT%VB G1f-G:
TREAT COLLBCHD GROmm WATER BY B%OLOG%CAL
DBGUDATXOB
This alternative includes treating collected ground water by
biological degradation instead of the currently used air stripping
method. Biological degradation is a treatment method used to
remove a variety of biodegradable organic compounds from water.
One version of biological treatment used for ground water
containing relatively low concentrations of degradable organic
chemicals utilizes a submerged fixed film reactor consisting of a
tank containing plastic media on which the microorganisms attach
and grow. The contaminated ground water is passed through the
reactor, and the acclimated microorganisms transform the
contaminants to carbon dioxide and water. Oxygen and nutrients are
supplied to the reactor to promote the growth of microorganisms.
commercial fertilizers could be used to supply nitrogen and
phosphorous to meet biological nutrient requirements. This system
could be constructed and operated on-site to treat the ground water
collected by the current ground...water collection system. Treatment
residuals generated from this system would have to be treated as a
hazardous waste if they fail the Toxicity Characteristic LeaChing
Procedure (TCLP).
capital co.t
o , II (aDDual)
pr...nt Worth
$ 700,000
$ 123,000
$ 2,200,000
..tiaat.4 Ti.. Until Clean-Up Objective x. .etl
10 years
GUt
ALTERDT%VB 8-A:
XH-SXTU TREATMENT OF SOXLS VXA SOXL VAPOR
EXTOCTXOB
In this alternative, a grid of vapor extraction wells would be
placed in the contaminated soil areas. Each well-is screened in
the unsaturated soil. The wells are interconnected by a shallow
network of horizontal piping that enables connection to a vacuum
pump. contaminated vapors in the soil source areas are collected
- -... ,.-...
17
-------
at the vacuum pump, treated in a vapor phase carbon adsorption
system and then discharged to the atmosphere. An asphalt cover
encompassing approximately 2,000 square yards would be placed over
the areas of vapor extraction to prevent short-circuiting of the
extraction system.
capital Cost
. 0 , X (aDDual)
Present worth
$ 73,000
$ 38,100
$ 182,400
8sttaate4 Time until Clean-Up O~jective Is Xet:
3 years
ALTBRDTIVB S-B:
1M-SITU TRBATHENT OP SOILS VXA SOIL vapoR
BXTRACTIOH AND SOIL FLUSBIHG
In this alternative volatile organic compounds in the soil would
first be removed by soil vapor extraction. After completion of the
soil vapor extraction any organic compounds. and semi-volatile
compounds remaining in the soil would be remediated by soil
flushing. The system would be similar to Alternative S.-A with two
exceptions: two of the venting wells would be constructed so they
could also be used as purge wells, and an infiltration bed would be
constructed over the soil areas of concern. The infiltration bed
would consist of corrugated perforated polyethylene (PE) pipe
imbedded in approximately 10 inches of sand. The sand is then
topped with a synthetic cover and approximately 10 inches of
compacted fill. An asphalt covering would cover the compacted
fill. A flushing fluid would be injected into the piping and
allowed to infiltrate into the contaminated soil. The fluid would
consist of 4% biodegradable surfactant solution with the rest of
the solution being City water. The fluid would be recovered by the
purge wells pumping at approximately 10 gallons per minute to
ensure that all the flushing fluid is recovered. The recovered
flushing fluid would be pretreated on-site prior to discharge to
Wyoming's Waste Water Treatment Plant.
pre.ent Worth
$ 240,000
$ 33,900
$ 40,500
$450,000
(years 1-3)
(years 4-7)
capital Cost
o , X (aDDual)
8.timate4 Time until Clean-Up o~jective Is .et:
7 years
ALTERNATIVE S-C:
IN-SITU TREATMENT OP SOILS VIA SOIL V1POR
EXTRACTIOH AND BIORECLAMATIOM
This alternative is similar to S-B with respect to the well systems
and the infiltration bed. In addition, a nutrient tank would be
required for preparation and storage of nutrient ',solution. The
system described in Alternative S-A would be operated until the
levels of. volatile organic compounds in the soils diminish to
concentrations which are no longer feasible to warrant. continued
18
-------
vapor extraction. The soil vapor extraction system would then be
restructured to inject and capture a nutrient solution which
stimulates the qrowth of native microorqanisms. The microorqanisms
would quickly acclimate to the constituents present, and with the
addition of the essential nutrients, will deqrade many orqanic
compounds. Commercial qrade fertilizer would be used to supply the
ni trCKJen and phosphorous required. Hydroqen peroxide could be used
as an oxyqen source.
capital co.t
o i . (lUmual)
Pre.ent Worth
$ 250,000
$ 33,900
$ 75,500
$ 620,000
(years 1-3)
(years 4-S)
..tiaated Time until Clean-Up O~jective I. .et:
ALTEJtDTIVB 8-D:
S years
80IL CAPPING
A soil cap would be placed over the off-property areas where soils
are actinq as sources for qround-water contamination. The cap
would consist of 1S inches of low-permeability compacted soil alonq
with 6 inches of top soil capable of supporting plant life. A cap
would be desiqned to minimize the amount of precipitation that
miqht further wash contaminants from the soil into the qround
water. The cap would cover approximately SOO square feet of off-
property soil. Periodic moni torinq and maintenance would be
required for the soil cap.
capital co.t
o i K (aDDua1)
pre.ent worth
$ 3,SOO
$ 3,100
$ 54,000
..tiaated Tiae To Construct A Cap: 3 months
ALTERDTIVB 8-B:
FENCING
A fence would be placed around the off-property areas where soils
act as a source for qround-water contamination. This fence would
consist of a 6-foot-high, galvanized steel, chain-link fence topped
with barbed wire and an S-foot-wide qate to facilitate access of
service vehicles.
capital co.t
o i . (aDDual)
pre.ent worth
$ 5,500
$ 1,600
$ 31,000
..tiaated Tiae To Construct A Pence:
3 months
11
-------
ALTBRDTIVB S-I':
SOIL CAPPING AND I'BNCING
This alternative combines both Alternative S-D and S-E. Fencinq
around the capped area would help maintain the inteqrity of the
cap.
capital co.t
o , K (azmual)
pra.ant wortb
$ 9,300
$ 4,700
$ 85,000
..timatad Ttaa To Con.truct a Cap and I'anca: 3 months
AL'lBRDTIVB S-Q I
BXCAVATION OF OR-PROPBRTY SOILS AND DISPOSAL
OFF-SID
Two areas on-property would be excavated and soils disposed of at
a licensed off-site disposal facility. The area on the west side
of the Chem Central buildinq would be excavated. This area
encompasses a 60-foot by 275-foot area. The area north of the Chem
Central buildinq would also be excavated. This area encompasses a
60 foot by 75 foot area. The excavation would extend vertically to
the water table (approximately 8 feet). The total volume of soil
to ~ removed is estimated at 6,200 cubic yards. 'The railroad spur
on the west side of the Chem Central building would have to be
removed and replaced, as would the fence alonq the western property
boundary. Metal sheetinq would be required alonq the main line of
the railroad tracks and the buildinq to protect them from damaqe
durinq the excavation activities. The costs listed below are
presented for the two types of disposal facilities which could be
used for the excavated soils. If analysis of the soil indicates it
is a hazardous waste (fails TCLP), then the soil must be treated
and disposed of in accordance with applicable Federal and state
requlations at an U.S.EPA approved facility. ' If the soil is not a
hazardous waste (passes TCLP), then it may be disposed of in a
Michiqan Type II landfill.
capital Co.t
o , .
pra.ant Wortb
$ 560,000
$ 13,000,000
$ 0
$ 0
$ 560,000
$ l3,000,0~0
(Type II Landfill)
(Hazardous Waste Facility)
(Type II Landfill)
(HaZardous Waste Facility)
(Type II Landfill)
(Hazardous Waste Landfill)
1 year
Bstimatad Tima until Claan-Up objectiva I. Katl
SmomRY OF COMPARATIVE ANALYSIS OF ALTBRNATIVES
The remedial alternatives developed in the FS were evaluated usinq
the followinq nine criteria. The advantaqes and d1sadvantaqes of
each alternative were then compared to identify the alternative
providinq the best balance amonq these nine criteria.
20
-------
o
o
o
o
o
o
o
o
o
ov8rall Pro~8c~ion of Human H8alth an4 th8 Bnvirona8nt --
Addresses whether a remedy provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering
controls, or institutional controls.
co.plianc8 vi~h ARAR8 -- Addresses whether a remedy will meet
all of the applicable, relevant, or appropriate
requirements (ARARs) of other Federal and state
environmental laws and/or justifies use of a waiver.
Long-'1'8rm Bff8ctiv8n8.. u4 P8rman8nce -- Addresses the
expected residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment over
time, once clean-up goals have been met.
.84uction of contaminant '1'ozici ~y, Kobili ty, or Volume '1'hrough
'1'r8a~8nt -- Addresses the anticipated performance
of the treatment technologies the remedy may employ.
Short-'1'era Bffectivene.. -- Addresses the period of time
needed to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period.
Impl..en~abili ty -- Addresses the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
co.~ -- Addresses the estimated capital and O&M costs, as
well as present-worth.
state Acceptance -- Addresses the
comments and concerns.
support
agency's
community Acceptance -- Addresses the public's comments
on and concerns about the proposed Plan and RI/FS Report.
The first two criteria, OVerall Protection of Human Health and the
Environment, and Compliance with ARARs, are threshold requirements
that must be met for an alternative to be selected. The next five
criteria are balancing criteria used to evaluate the advantages and
disadvantages of each alternative. The final two criteria, state
and community acceptance, are mOdifying criteria which are used in
a final evaluation of each alternative. The comparative analysis
of the alternatives for both ground water and soil is presented
below. .
21
-------
GROtJ'ND WATER
overall Pro~ec~ion of Human Heal~b an4 tbe Bnvironaent
In analyzing the various possible ground-water remedial
alternatives discussed above, U.S.EPA looked at two components in
order to determine whether a particular remedial alternative is
fully protective of human health and the environment: (1) whether
the al ternati ve would capture the proportion of the plume of
contamination deemed necessary to fully protect human health and
the environment, and (2) whether the particular treatment
technology employed by the remedy would clean up the ground water
to levels deemed fully protective by EPA. Some of the remedial
alternatives, such as GW-C and GW-D, would use the current
treatment technology, but would be expansions of the current
ground-water collection system. Others, such as GW-F and GW-G,
rely on alternate ground-water treatment technologies, but would
utilize the current collection system. In order to be considered
fully protective of human health and the environment, a remedial
alternative both had to ensure the capture of all ground water
contaminated above clean-up levels, and be capable of remediating
the ground water to U.S.EPA'S clean-up standards.
In the superfund process, clean-up remedies are selected that
reduce the threat from carcinogenic contaminants at sites such that
the excess risk from any medium (i.e., soil or ground water) to an
individual exposed oV6er a lifetime generally falls within a risk
range from 10-4to 10- . U.S.EPA's preference is to select remedies
that are at the more protective end of the risk range. Therefore,
when developing its remediati~n goals (clean-up levels), U.S.EPA
determined that a risk of 10- is necessary to fully protect human
health and the environment. .
The "No-Action" alternative does not provide overall protection of
human heal th and the environment because it allows continued
migration of the ground-water contaminant plume of contamination in
the ground water and would allow contaminated ground water to
discharge to Cole Drain. Alternative GW-G will most likely not
provide overall protection of human health and the environment
because biological degradation does not work effectively on
chlorinated organics, which are the principal ground-water
contaminants at Chem Central. Thus, Alternative GW-G would not be
able to meet remediation goals. Alternative GW-G is also not fully
protective because it relies on the current ground-water collection
system, whose deficiencies are elaborated in this section's
discussion of Alternative GW-B. GW-B will only partially protect
human heal th and the environment because some ground water
currently bypasses the current ground-water collection system. As
such, the potential for contaminated ground water to discharge to
Cole Drain exists. A discharge to Cole Drain may create a threat
to humans and several animal populations that come into direct
22
-------
contact with the contaminate~ water. Alternatives GW-C and GW-D
require that Alternative GW-B be implemented. Individually,
Alternatives GW-C, GW-D and GW-E are not fully protective because
they are not comprehensive remedies. It is necessary to combine
Alternatives GW-D and GW-E with Alternative GW-C because
Alternative GW-C alone will not remedy the contamination found in
the deeper sand lens. Al ternati ve GW-C alone, also, will not treat
the floating oils found in the purge wells, which are highly
contaminated with PCBs and organic compounds, which is addressed by
Alternative GW-E. The collection of approximately 90% of the
floatable oils in the purge wells using alternative GW-E is
sufficient to address this aspect of ground-water contamination.
However, implemented together, Alternatives GW-C, GW-D and GW-E
would be protective because together they address all sources of
qround-water contamination. Alternative GW-F intercepts, collects,
and treats a portion of the contaminated qround water before it can
discharge to Cole Drain. Alternative GW-F would be able to meet
the clean-up standards that U.S.EPA has identified: however, since
it relies on the current qround-water collection system, it is only
partially protective, based upon the same reasoninq as that
contained in the above discussion for Alternative GW-B.
Since the No-Action Alternative and GW-G (Bioloqical Deqradation)
do not provide adequate protection of human heal th and the
environment, they are not available for selection and will not be
discussed throuqh the remainder of this analysis.
Compliance with ARAR8
The major potential qround-water ARARs include the requirements of
the Federal Safe Drinkinq Water Act: Federal Clean Water Act:
Michiqan 1929 Public Act 245 Parts 4 and 9, as amended: 1976 Public
Act 399, as amended; and 1982 Public Act 307, as amended. The
MDNR has issued rules to implement Act 307. These rules establish
criteria for three acceptable clean-up types. Under the rules, a
Type A cleanup generally achieves cleanup to backqround or non-
detectable ievels, a Type B qenerally achieves risk-based clean-up
levels (10- ),and a Type C cleanup is based on a site-specific risk
assessment that considers specific criteria.
U.S.EPA has used the framework outlined in the NCP that will reduce
the concentration of hazardous sqbstances to levels presenting a
site risk of not greater than 10-bfor carcinogens and hazard index
of 1 for noncarcinogens. Therefore, a risk level of 10-~as been
used as a point of departure by U.S.EPA in selectinq the
appropriate ARAR, or clean-up standard, for the site. In examining
potential state ARARs, U.S.EPA has determined that the clean-up
standards defined by a Michigan Act 307 Type B cleanup are those
which are most compatible with U.S.EPA's preferred risk level, and
which also allow for overall protection of human health and the
environment.
23
-------
The major ARAR for Alternatives GW-B, GW-C, GW-D and GW-F is
Michigan Act 307 Type B. Alternatives GW-C and GW-D will comply
with this ARAR. As Alternative GW-B and GW-F do not capture
approximately 10% of the ground-water contamination plume, they
will not meet the Michigan Act 307 Type B.
Alternative GW-E must comply with the Toxic Substances Control Act
(TSCA). Compliance with these requirements would be required if
the oil contains ~ 50 ppm of PCBs. Alternative GW-E is capable of
complying with this ARAR.
The major air ARARs include the requirements of Michigan's 1965
Public Act 348, as amended, and the Federal Clean Air Act. All
Alternatives will comply with both of these ARARs.
Long-T.ra Bff.ctivene.. an4 perman.nc.
Alternatives GW-C, GW-D and GW-E provide a high degree of long-term
effectiveness and permanence at the site by cOllecting and treating
the contaminated ground-water and assuring that the contaminated
ground-water does not impact Cole Drain. Alternatives GW-B and.
GW-F would only be capable of capturing approximately 90% of the
plume as opposed to the vast majority of the plume. Alternative
GW-B leaves the risk of contaminated ground-water discharging to
Cole Drain. These risks could result from a potential direct
contact threat to humans and several animal populations. All
alternatives include institutional controls such as deed
restrictions, to prevent the use of ground water in the site area.
Ground-water monitoring would also be implemented in each
alternative.
Short-Term Bff.ctiv.ne.8
There is an increased risk of exposure to workers during
construction of alternatives GW-C, GW-D, and GW-F but these risks
can be minimized by following proper safety guidelines.
Alternative GW-E presents a risk of dermal contact with the
recovered oil and inhalation of volatile organics from the oil by
workers collecting the oil. This risk can also be minimized by
following proper safety guidelines and wearing protective clothing.
Risks from increased air. emissions of organic compounds from
alternative GW-C are similar to those of alternative GW-B .but are
not expected to exceed federal or state air emission guidelines.
Thus these increased air emissions would not present unacceptable
risk levels.
..4uction of contaminant Tozicity, lIobility, or Volume through
Treatment
Alternative GW-C, GW-D, GW-E, and GW-F are all able to sufficiently
reduce ground-water contamination through treatment. The floatable
oils are removed and destroyed in Alternative GW-E. --Alternatives
2C
-------
GW-B and GW-F do not capture the entire plume. As such, these
alternatives are not fully successful in reducing the toxicity,
mobility and volume of contaminants in the ground water.
Technical aDd A4mini8trative Difficulty
Alternatives GW-B, GW-C, GW-D, and GW-E are all relatively simple
to construct and operate. These alternatives are reliant on the
currently operating collection/treatment system. This system is
operating to design specifications, and all air and water discharge
permits have already been obtained. The treatment system currently
meets or exceeds the performance specifications required by the
City of Wyoming's Waste Water Treatment Plant for discharge of the
treated ground water from the air stripper. Alternative GW-F would
be the most difficult to implement. A pilot study of the UV-
oxidation system using the contaminated ground water present on the
site would be required. This study would determine whether this
type of system could be used on a large-scale and long-term basis.
Alternative GW-F also requires a four month delivery time for the
necessary equipment.. In addition, before Alternative GW-F could be
implemented, the current ground-water treatment system would have
to be decommissioned. Alternative GW-F may be inconsistent with
the obligations of the state court judgement. For all these
reasons, Alternative GW-F is considered to be technically and
administratively difficult.
coat
A comp~rison of capital, operation and maintenance (0 & M), and
present worth costs for implementing the various ground-water
alternatives at the site are presented below.
ALTERNATIVE
CAPITAL
No-Action: $ 5,000
(Institutional Controls and Monitoring)
GW-B
$ 0
$ 34,000
$ 28,000
GW-C
Option 1
Option 2
GW-D
$ 18,000
$ 0
$ 670,00
$700,000
GW-E
GW-F
GW-G
o & M
$ 25,000
$ 108,000
$ 0
$ 2,900
$ 1,500
$ 3,200
$ 232,000
$ 123,000 .
PRESENT
WORTH
$ 410,000
$ 1,400,000
$ 34,000
$ 66,000
$ 38,000
$ 42,000
$ 3,700,000
$ 2,200,000
NOTES: Present Worth Costs assume a 5\ interest rate.
Listed 0 & M Costs are annual costs.
25
-------
The costs presented are compiled for each individual alternative
only and do not include costs for any other alternative which must
also be used in conjunction. For instance Alternative GW-E
requires that the purge well system be operating, such as GW-B:
however, the costs shown are only for implementing GW-E, they do
not include purge well operation.
state Acceptance
The response of MDNR has been discussed in the section describing
the selected remedy.
community Acceptance
community acceptance is assessed in the attached Responsiveness
Summary. The Responsiveness Summary provides: 1) a thorough review
of the public comments received on the RI/FS and Proposed Plan: and
2) U.S.EPA's responses to the comments received.
Gn
OVerall protectioD of Human Health an4 the BDvironaeDt
In analyzing the various alternatives for their ability to meet the
overall protectiveness criterion, U.S.EPA looked to two areas of
concern: 1) the degree to which they would minimize or eliminate a
direct contact threat to contaminated soils, and 2) the degree to
which they would protect ground water from the leaching of soil
contaminants.
The No-Action Alternative for soil remediation would not control
exposure to the contaminated soil and would allow for continued
migration of contaminants from the soil into ground water. The No
.. Action Al ternati ve would therefore not be protective of human
health and the environment. Alternative S-E reduces the chances of
direct human contact but does not affect migration of contaminants
to the ground water. Therefore, it is not protective of human
'health and the environment by itself. Since the No Action
Alternative and Alternative S-E do not provide adequate protection
to human health and the environment, they are not available for
selection and will not be discussed throughout the remainder of
this analysis.
Alternatives S-A, S-B, and s-c are protective of human health and
the environment because they reduce the migration of contaminants
from the soil to ground water. These alternatives also include a
soil cap in the areas where soil vapor extraction takes place. The
soil cap will reduce the risk of direct human contadt. Alternative
S-D is also potentially protective of human health and the
environment. Alternative S-D would reduce direct human contact
risks and would reduce, but not prevent, the pote~tj~~ for the
2'
-------
migration of contaminants from soils into ground water.
Alternative S-F is a combination of Alternatives S-D and S-E.
Alternative S-F will provide adequate protection of human health
and the environment by reducing direct contact threats and by
reducing, but not preventing, the migration of contaminants into
the ground water. Alternative S-G is protective of human health
and the environment because it requires the removal of contaminated
s011 which would eliminate the risk of contaminant migration to
ground water. The risk of human exposure would also be eliminated.
complianC8 witb aDR8
The maj or soil ARAR for the Chem Central site is MiChigan Act 307.
MDNR has issued rules to implement Act 307. These rules establish
criteria for three acceptable cleanup types. Under the rules, a
Type .A cleanup generally achieves background or nondetectable
levels. The Type B cleanup achieves levels required: to protect
ground water from the migration of contaminants from the soil into
the ground water: to protect against unacceptable human health
risks due to direct contact: and, to protect surface water quality.
.A Type C soil cleanup is based upon a site-specific risk
assessment, that considers specific criteria. The clean-up
standards for soils at the Chem Central site are consistent with
Michigan Act 307 requirements.
Alternatives S-A, S-B, S-C and S-G are capable of complying with a
Type B MiChigan Act 307 cleanup. Alternatives S-D and S-F may not
comply with a Type C Michigan Act 307 cleanup, which is the least
stringent type .of cleanup contemplated under this statute. The
State of Michigan has indicated that Alternatives S-D and S-F as
presented in the FS would not comply with Act 307, based upon the
specific criteria used for evaluating a Type C cleanup.
The major air ARARs include MiChigan's 1965. Public Act 348, as
amended, and the Federal Clean Air Act. All soil alternatives will
comply with these ARARs.
LOng-T8r.a Bff8ctiv8n8.8 and Perman8nC8
Alternatives S-A, S-B, S-C and S-G will all result in a low long-
term risk once the treatment or soil removal is completed. Each
may leave 801le residual soil contamination but at levels which
would still be protective of human health and the environment.
Alternative S-D will reduce the chance of direct human contact as
long as the cap is maintained. since the cap only covers, and not
removes, the contamination, it leaves a moderate long-term risk to
human health and the environment. Alternative S-F poses a moderate
long-term risk since fencing the capped soil areas will reduce
access and therefore requires less maintenance of' the cap. The
effectiveness of Alternatives S-D and S-F over the long-term can be
diminished from frost heave and desiccation. .
27
-------
Short-~er.a Bffectivene.8
Alternatives S-A and S-C may result in increased short-term risks
to the community from air emissions. However, a car~on adsorption
system can be used to minimize these emissions. Exposure through
dermal contact and inhalation by workers in and around the
construction area may occur during the installation of the vapor
extraction system. Proper protective clothing will minimize the
risk to workers in these areas involved with these. hazards.
Alternative S-B may result in the same short term risks as
Alternative S-A. In addition, flushing fluid could be discharged
to qround water if pump failure occurs, or if an inadequate
gradient is produced in the purge wells. Alternatives S-D and S-F
may pose a risk to residents and workers because during the
construction of a cap volatiles or particulates can be released
from the soil. Alternative S-G could result in a risk to workers
in the area of soil removal as well as the community from vapors
released from the soils during excavation, loading, transportation,
and disposal.
Reduction of Tozicity, Mobility, or Volume Through Treatment
Alternatives S-A, S-B and S-C treat the contaminated soils thereby
resulting in a reduction of the toxicity, mobility and volume of
contaminants. Any residual contamination would be below acceptable
risk-based levels for these alternatives. Alternatives S-D and S-F
do not involve a treatment component and therefore do not reduce
the toxicity, mobility, or volume of the contaminated soil through
treatment. Alternative S-G removes the contaminated soil from the
site but does not reduce toxicity, mobility, or volume of the
contaminants if treatment is not required prior to disposal at the
off-site facility.
Technical and Administrative Difficulty
Alternatives S-A, S-B, and S-C would all require pilot studies to
maximize the efficiency of each system. Alternatives S-B and S-C
would also require the removal of a railroad line running onto Chem
Central's property. Removal of this railroad line would interrupt
the company's business for a short period of time. Alternatives
S-D and S-F are straightforward and require little technical
expertise. However, implementation of these alternatives may
require zoning variances. Alternative S-G would require the
removal of the railroad line on Chem Central's property and would
also require sheet piling along the building and the main rail
line. Administrative difficulties may be. encountered in
identifying a landfill willing to accept the contaminated soil for
disposal under Alternative S-G.
28
-------
coat
A comparison of the capital, operation and maintenance (0 & M), and
present worth costs for implementing the various soil alternatives
at the site is presented below. .
ALTERNATIVE CAPITAL 0 & M
S-A $ 73,000 $ 38,100
S-B $ 240,000 (yr.1-3) $33,900
(yr.4-7) $40,500
S-C $ 250,000 (yr.1-3) $33,900
(yr.4-7) $75,500
S-D $ 3,800 $ 3,100
S-E $ 5,500 $ 1,600
S-F $ 9,300 $ 4,700
S-G (Type II Ldfl) $ 560,000 $ 0
(Haz Waste) $ 13,000,000 $ 0
PRESENT
WORTH
$ 182,000
$ 450,000
$ 620,000
$ 54,000
$ 31,000
$ 85,000
$ 560,000
$ 13,000,000
Notes: Present Worth Costs assume a 5' interest rate.
Listed 0 & M Costs are annual amounts.
stat. Acceptance
The response of MOHR has been discussed in the section describing
.,.
the selected remedy.
community Acceptance
community acceptance is assessed in the attached Responsiveness
summary. The Responsiveness Summary provides: 1) a thorough review
of the public comments received on the RI/FS and Proposed Plan: and
2) U.S.EPA's and MOHR's responses to the comments received.
'1'HB SELECTED REDDY
The selected remedy for ground water is a combination of
alternatives evaluated for the Chem Central site.. These include:
Alternatives GW-B, continue CUrrent Remedial Actions: GW-C,
expansion of the current ground-water collection system off-
property: GW-D, expansion of the current system on-property: and
GW-E, collection of floatable oils from the purqe wells. The
selected remedy for soil on and off the Chem Central property is
Alternative S-A, soil vapor extraction.
2'
-------
The major components of the selected remedy are illustrated in
piaur. 4 and include:
o
continue operation and maintenance of the current ground-
water collection and treatment system.
Install, operate and maintain an expansion of the current
off-property ground-water collection system, either by
extending the interceptor trench or installing additional
purge wells.
o
o
Install, operate and maintain a purge well at the deep
location of contaminated ground water identified in the
RI.
o
Collect oil in the purge wells and dispose of the oil at an
off-si~e facility in accordance with applicable federal and
state regulations
Install, operate and maintain a soil vapor extrac~ion
sys~em for soils on-property as well as two off-property
locations just north of the Chem Central property.
o
o
Institutional controls such as deed restrictions to
prohibit the installa~ion ofwa~er wells in the si~e area
and any future development that might disturb
contaminated soils, will be sought.
Implement a ground-water monitoring program capable of
demonstrating the effectiveness of the ground-water
capture system.
o
BXPANSION OP CURREHT GROUND-WATER COLLECTION SYSTEK OPP-PROPERTY
This remedy involves the expansion of the current ground water
collection system north of 28th Street to capture ground water
currently bypassing the collection system. The current ground-
water collection system includes the following:
water
via
wells
and
an
collecting ground
interceptor trench,
transporting the collected, untreated ground
through a force main to a treatment system,
purge
water
any
floating
in
oil-water
layer
an
skimming off
separator,
trea~ing the collected ground water on-site via air
stripping,
30
-------
Buoll4ft4ft Ave.
Chem-
Cen frol
PIPP
AREA
AIR
CON1ROlS
-,
I
'-""'----6.-----,6
seM2 "0..,- Aqulf.
~
~
...,
ft1
"'~
RESIDENllAL
AREA
\ ~o 0 '
'(" ..
(» ~
... "
--
III
Hillarofl Ave.
cru
Du
Slat. ord AV8.
...,
fI)
~
..
. ~"'~-----", .
'-.-- -:11
-I:: :::===-III~..._..._...
"Cole '0-;;;;;''''
I e\ it-
C'ef).\t
~~; ~
. . Air Stripper
/. Purge Wells
A New Purge Wells
. Soil Vapor Extraction Wetls
/ FlOURS 4
Extension to Interceptor. Trench
EPAts Preferred Alternative
--
----
u.s. '81
n
2f'
40ft
I
-------
transporting the treated ground water through a force
main to the discharge point,
discharging the treated ground water to the City of
wyoming PQTW, and
treating air emissions from the air stripper using a.
vapor phase carbon adsorption system.
To collect the . portion of the ground-water plume currently
bypassing the interceptor trench north of 28th street, one of the
following options will need to be implemented.
OP'1'%ON 1
An interceptor trench would be constructed east or north of the
lift station as shown in Piqur. 4. The interceptor trench would
consist of a perforated pipe imbedded in gravel. This passive
system would be placed below the water table (approximately 10
feet) so that ground water will infiltrate into it. The pipe would
slope so that the infiltrating ground water would flow by gravity
to the lift station. Any dewatering. required during construction
would be discharged to the lift station.
OP'1'%ON 2
Two purge wells would be constructed to an approximate depth of ten
feet. Approximate locations are shown in Piqur. 4. The ground
water would be pumped from the wells and transmission piping would
convey the water to the lift station.
For either option the ground-water collection rate is estimated at
5 qpm. This estimate is based on the current underdrain system's
collection rate and aquifer characteristics. The collected ground
water will be transferred from the lift station to a treatment
system through the transmission piping. The ground water will be
treated as outlined above in the description of the current
collection/treatment system. .
A final decision on the option to be implemented will be made
during the remedial desiqn phase based on a comparison of the
effectiveness of the two options.
BXPANSION OP GROUND-WATBR COLLECTION SYSTBK ON-PROPERTY
The ground-water collection system will be expanded on the Chem
Central property by adding a purge well to capture on-property
ground water in the sand/gravel lens at SCH-2 near the northwest
corner of the property (see Piqur. 4). A well will be placed to an
approximate depth of 4S feet. Transmission pIping will be
installed to convey the ground water to a treatment system.
31
-------
The collection rate of ground water is estimated at 1 qpm. This
estimate is based on the hydrogeological characteristics of the
aquifer. The ground water will be treated as outlined in the
description of the current collection/treatment system under
"Expansion of CUrrent Ground-Water Collection Off-Property".
COLLBC'1'IOB A!U) OF'-SI'1'1 DISPOSAL OP FLOA'1'ABLI OILS
The thin film of floatable oils present in the purge wells will be
removed by manual bailing. The collected oil will be disposed of
off-site in accordance with applicable federal and state
regulations. A conservative estimate of the amount of oil
collected is 1 gallon per recovery event, with two events per year.
Along with the oil, approximately 9 gallons of water will also be
collected.
IN-SIft '1'RBA'1'KB1f'1' OP SOILS VIA SOIL VAPOR BrrRAC'1'IOB
A s011 vapor extraction system will be installed, operated and
maintained for on-property and off-property soils impacted by
organic chemicals. Venting wells will be spaced approximately 75
feet apart. The actual number of wells and the exact spacing
needed to effectively cover the area of concern will be determined
during the remedial design. Based on soil characteristics, a
conservative estimate for the yield at each well is approximately
20 cubic feet of air per minute (CFK). This flow rate will
determine -the size of the blower required to create a vacuum of
approximately 5 psi. The estimated emission of VOCs in the air
stream generated during this operation is 0.4 Ib/hr. Air controls
consisting of a vapor phase carbon adsorption system will be
required for treatment of air emissions. The extracted soil vapor
will be conveyed to the air treatment system through buried
ducting. A cover of sui table material will be placed over the
currently exposed areas to be vapor extracted.
The soil vapor extraction system. is expected to reduce the
contaminant levels in soil to below the soil cleanup standards for
the site. However, some semi-volatile compounds may be more
difficult to vapor extract. It is estimated that 80' of semi-
volatile compounds will be removed using soil vapor extraction.
If, following a treatability study or through additional soil
testing during the operation of the soil vapor extraction system,
it is determined that the system is unable to reduce the 'semi-
volatile compounds to below the soil cleanup standards, additional
treatment methods in order to reduce the compounds to below the
soi1 cleanup standards will be evaluated and implemented to
supplement the vapor extraction system. This may include soil
flushing or bioreclamation as described under Alternatives S-B and
S-C. .
32
-------
TABLE 7A
MICHIGAN ACT 307 TYPE B CLEAN-UP STANDARDS
FOR GROUND WATER AT THB CHEMCBNTRAL SITE
y~:}..:. BAsIS FOR LEVEL . .. ..
CHEMicAL ..:...: CLEAN-UP LEVEL (ppb) METHOD DETECTION LIMIT (ppb) .
Benzene 1 HB 1
Bis(2-Ethylhexyl)phthalate 2 HB 5
Chloroethane 9 HB 1
1,1-Dichloroethane 700 HB 1
1,2-Dichloroethane 0.4 HB 1
1,2~Dichloroethene 70 HB 1
1,1-Dichloroethylene 7 HB 1
Trans-l,2-Dichloroethylene 100 HB 1
Ethylbenzene 30 SW/R.57 1
Methylene Chloride 5 HB 1
2-Methylnaphthalene 10 UB 10
2-Hethylphenol 40 SW/R.57 10
Naphthalene 29 SW/R.57 5
Pentachlorophenol 0.3 UB 20
Tetrachloroethylene 0.7 UB 5
Toluene 100 SW/R.57 1
1, 1, I-Trichloroethane 117 SW/R.57 1
1,1,2,2-Tetrachloroethane 0.2 UB 1
Trichloroethylene 3 UB 1
Vinyl Chloride 0.02 UB 1
Xylene 59 SW/R.57 1
NOTESs
-ppbs "parts per billion" or ug/L
-HBs Health Based
-SW/Rule 57: Surface water protection
Public Act 245, Rule 57.
based on Michigan Water Resources Commission Act,
When the ground water or soil clean-up level is lower than the method detection limit,
the method detection limit is then used as the clean-up standard.
-------
CleanuD standards
In the Superfund process, clean-up remedies are selected that
reduce the threat from carcinogenic contaminants at sites such that
the excess risk from any medium (i.e., soil or ground water) to an
individual exposed over a lifetime generally falls within a risk
range from 10-4to 10-6. U.S.EPA's preference is to select remedies
that are at the more protective end of the risk range. Therefore,
when developing its remediatio~ goals (clean-up standards), U. s. EPA
determined that a risk of 10-OWas necessary in order to be fully
protective of human health and the environment.
The Clean-up Standards for the Chem Central site are listed in
Table 7A '78. The cl~an-up standards for ground water have been
established at the 10-~evel for each carcinogenic contaminant and
at the Human Life Cycle safe Concentration (HISC) for each
noncarcinogenic contaminant. The clean-up standard, for soil have
been established based on direct contact at the 10-~evel for each
carcinogenic contaminant and at the HISC for each noncarcinogenic
contaminant. In addi tion, a soil clean-up obj ecti ve has been
established to protect ground water from the leaching of soil
contaminants into the ground water. In order to demonstrate
compliance with this objective, the contaminant levels in the on
and off-property soils must be reduced to less than twenty (20)
times the ground-water clean-up standard for each chemical (see
Table 7A , 78), or leach tests (TCLP) performed on the soils must
produce leachate with contaminant levels below the ground-water
clean-up levels, or the results of other test methods (other than
TCLP) that accurately simulate condi tions at the si te must be
employed to demonstrate that contaminants are not leaching into the
ground water above the ground-water clean-up standards.
Points of ComDliance
Compliance points to be measured during the course of ground-water
remediation, to determine the progress towards the attainment of
ground-water clean-up standards, include the treatment system
effluent and monitoring well analyses. The area of attainment for
ground-water contamination extends throughout the plume in the
aquifer underlying the Chem Central site.
The compliance points for soil remediation include all soils on the
Chem Central property and the soils immediately north of the Chem
Central property. The area of attainment for soil contamination
extends throughout the soil column.
IXPLEKBN'rATIOIt TIXB A1I1) COSTS
The selected ground-water remedy will take approximately 10 years
before clean-up objectives are met. The soil remeBy will take an
estimated 3 years before clean-up objectives are met.
33
-------
The current cost estimate for the selected remedy is approximately
$2,099,000 or $2,131,000 (reflects present worth costs) depending
on whether an extension to the interceptor trench is constructed or
two new purge wells are added to the current collection and
treatment system for ground water. A break down of the costs
associated with the selected remedy is as follows:
CONTINUED OPERATION OF CURRENT GROUND-WATER COLLECTION SYSTEM
capi~al Cos~
o , X (aDDual)
Pr..en~ Wor~b
$0
$108,000
$1,400,000
EXPANSION OF CURRENT GROUND-WATER COLLECTION SYSTEM OFF-PROPERTY
option 1 (interceptor trench)
capital Cost
o , X (aDDual)
Present Wortb
Option 2 (purge wells)
capital Cost
o , X (aDDual)
Present wortb
$34,000
$0
$34,000
$28,000
$2,900
$66,000
EXPANSION OF CURRENT GROUND-WATER COLLECTION SYSTEM ON-PROPERTY
Capital Cos~
o , K (aDDual)
Present Wortb
SOIL VAPOR EXTRACTION
capital Cost
o , X (aDDual)
Present wortb
$18,000
$1,500
$38,000
$72,000
$35,500
$175,000
MONITORING AND INSTITUTIONAL CONTROLS (30 years)
capi~al Cost
o , I( (aDDual)
Presen~ Wor~b
$5,000
$25,000
$410,000
STAT'D'l'ORY DETERMINATIONS
Under its legal authorities, U.S.EPA's primary responsibility at
superfund si tes is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
34
-------
the selected remedial action must comply with applicable or
relevant and appropriate environmental standards established under
Federal and state environmental laws unless a statutory waiver is
justified. The selected remedy must also be cost-effective and
utilize permanent solutions and alternative treatment technologies
to the maximum extent practicable. Finally, the statute includes
a preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mObility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
PBOTBC'1'IOB 01' JIUKAH DALD um '1'BB BBVIBOBKBB'l'
The selected remedy protects human health and the environment
through treatment of ground water and soils impacted by organic
chemicals at the Chem Central plant. Institutional controls will
also be implemented to protect human health and the environment.
OVerall. protection of human heal th and the environment will be
achieved by. continuing operation of the current ground-water
collection and treatment system: expanding the current
collection/treatment system to intercept and recover all of the
ground-water contaminant plume, including the contaminants present
in a deeper sand and gravel lens for treatment: and implementing a
soil vapor extraction system for soils on and off the Chem Central
property.
Implementation of the ground-water component of the selected remedy
will reduce the risks identified for that media. All ground water
contaminated above clean-up levels within the contaminant plume
will be captured, preventing the uncontrolled discharge of
contaminants to Cole Drain. In addition, the contaminants present
in ground water will be treated by an air stripper. Air emissions
off the air stripper will also be controlled. .
soil vapor extraction will treat soil contamination, thereby
significantly reducing the migration potential for contaminants to
move from soil to ground water and by reducing the direct contact
risks at the site. Although contaminants are transferred from soil
to air throuqh soil vapor extraction, air emissions from the soil
vapor will be controlled via carbon adsorption.
Tbe selected remedy does not pose any short-term threats "that
cannot be readily controlled, and no adverse cross-media impacts
are expected from its implementation.
COKPLIAIICB WID APPLICABLE OR RBLBVAN'r AND APPROPRIATB RBQUIRBKEN'rS
The selected remedy will comply with all applicable or relevant and
appropriate chemical, action, and location-specific requirements
35
-------
(ARARs). The ARARs for the selected remedy at the Chem Central
site are presented below.
Action-specific ARARs:
Action-specific ARARs are requirements that define acceptable
treatment and disposal procedures for hazardous substances.
o
Federal ARARs
Resource Conservation and Recovery Act , Subtitle C (RCRA)
addresses the proper handling treatment, storage and
disposal of hazardous wastes. These requirements may be
ARARs for the Chem Central site due to the fact that the
oil removed from the purge wells and the treatment
residuals generated from the air stripper and soil vapor
extraction system may be RCRA characteristic wastes~
Waste Generators.
( i. e., treatment
to for treatment,
40 CFR 262: Regulations for Hazardous
This is an ARAR if site materials
residuals, oils) are shipped off-site
storage or disposal.
40 CFR 263: Department of Transportation (DOT) Hazardous
Materials Transportation Act,42 USC 1801. This is an
ARAR for any shipment of hazardous materials.
40 CFR 264, Subpart D: Contingency Plan and Emergency
Procedures. Technical requirements are ARARs for the on-
site treatment of soils to minimize hazards to human
health and environment
40 CFR 264, Subpart E: Manifest System, Recordkeeping and
Reporting. This regulation requires written records of
waste management operations. This is an ARAR if
hazardous wastes are shipped to a RCRA facility.
40 CFR 268, Land Ban Restrictions. Disposal of treatment
residuals and contaminated oil must be in accordance with
the RCRA Land Disposal Regulations.
o
Occupational Safety and Health Act (OSHA) regulations
under 40 CFR 300 (300.38). This is an applicable
regulation which establishes safety and health standards
for protecting employees from unsafe work conditions.
o
Toxic Substance Control Act (TSCA), 15 USC 2601. This
regulation requires testing and use restrictions for
PCBs.
40 CFR 761 (761.60): PCB Storage and Disposal. Is an
ARAR if PCB concentrations are over 50 ppm in any media.
36
-------
o
u. S. EPA Pretreatment Standards; 40 eFR 403. 5 ; POTW' s
NPDES Permit. This ARAR prohibits discharge to a POTW of
pollutants that ~pass-through" (exit the POTW in
quantities or concentrations that violate the POTW' s
NPDES permit) or cause "interference" (inhibits or
disrupts the POTW, its treatment processes or operations,
or its sludge processes, use or disposal, thereby causing
a violation of the permit). Under these regulations,
certain POTWs, specified in section 403.8, are also
required to develop pretreatment standards for specified
users where pollutants discharged to the public system
could cause interference or pass-through. The
regulations also prohibit introduction into a POTW of:
(1) pollutants which create a fire or explosion hazard,
(2) pollutants which will cause corrosive structural
damage, (3) solid or viscous pollutants that will
obstruct flow, (4) pollutants discharged at a flow rate
and/or concentration that will cause interference, and
(5) heat that will inhibit biological activity.
Federal elean Air Act, 42 use 1857; 40 use 52, R52.21:
u. S. EPA Regulations on Approval and Promulgation of
Implementation Plans (prevention of Significant
Deterioration of Air Quality). These provisions impose
various requirements (e. g., use of best available control
technology) on any new maj or source of a federally
regulated air pollutant in an area which has been
designated attainment or unclassifiable for that
pollutant. A "major stationary source" is a source
listed in 40 CFR 52.21 which emits, or has the potential
to emit, 100 tons per year of a federally regulated air
pollutant or any non-listed source that emits, or has the
potential to emit, 250 tons per year of a federally
regulated air pOllutant. This requirement is relevant
and appropriate if any treatment- system used during
remediation would constitute a maj or stationary source of
any federally regulated air pollutant.
o
o
state ARARs
Michigan Environmental Response Act 307. MOHR has issued
rules to implement Act 307. These rules establish
criteria for three acceptable clean-up types. Under the
rules, a Type A cleanup generally achieves cleanup to
background or non-detectable levels, a ~e B generally
achieves risk-based clean-up levels (10- ),and a Type C
cleanup is based on a site-specific risk assessment that
considers specific criteria. Act 307 may be an
applicable requirement: however, even if it is not,
U.S.EPA has determined that it is a relevant and
appropriate requirement. The clean-up standards selected
37
-------
o
for soil and ground water at the Chem Central site are
consistent with a Type B cleanup.
Michigan Water Resources Commission Act Public Act 245,
Part 4. This is a relevant and appropriate requirement
that provides general prohibition of concentrations in
surface water for substances which impart unpalatable
flavor to food, fish, or otherwise interfere with the
reasonable use of the surface water in the state.
Part 4, Rule 57: Acute Toxicity: provides that
surface water must not be acutely toxic to
aquatic life (except in small zones to initial
dilution at discharge points).
Part 4, Rule 57: Chronic Toxicity: provides
that surface water with designated aquatic
life uses shall not be chronically toxic to
aquatic life (except in mixing zones and below
critical low-flow conditions).
Part 4, Rule 57: General Toxicity: provides
that surface waters must not be toxic or
injurious to man or to terrestrial or aquatic
life.
Part 4, Rule 57: Human Toxicity: provides
that surface water must be maintained to
preclude adverse toxic effects on human health
resulting from contact recreation, consumption
of aquatic organisms, or consumption of
drinking water after reasonable treatment.
Part 4, Rule 57: Toxicity criteria: provides
that concentrations of toxic materials for
which no numerical cri teria have been
specified must not exceed values which are
chronically toxic to representative, sensitive
aquatic organisms, as determined from
appropriate chronic toxicity data or
calculated as 0.1 of the median lethal
concentrations (LC50) for non-persistent
toxics.
Part 4, Rule 57: Numerical criteria for
Toxics: provides for numerical criteria for
certain toxic materials including some site
indicator chemicals.
Part 4, Rule 98: Antideqradation: reqUires
maintenance and protection of existing waters
when water quality is better than water
38
-------
quality standards, especially when discharging
wastewater. In addition, this rule would
address ground water discharges to surface
water bodies.
o
Part 9, Rule 234; Wastewater Reporting. This
is an applicable regulation which provides
reporting requirements for discharges of
wastewater to the waters of the state or for
discharges to a sewer system. An ARAR because
treated ground water is discharged to a POTW.
Michigan Air Pollution Control (MAPC) Act: Michigan
Public Act 348. Part 3, R336.1301 and 336.1331:
Particulates. This is an applicable regulation for the
air stripper and soil treatment unit.
Part 3, R336.1371 to 1373: Fugitive Dust. This
is an ARAR for loading and unloading of bulk
materials that act as a source of fugitive
dust. Trucks with less than a 2-ton capacity
that are used for transporting of bulk
materials are exempt. Trucks larger than 2-
ton capacity must abide by Rule 372 provisions
when transporting. .
Part 7, R336.1702: New Sources of VOC
Emissions. Any person responsible for any new
source of VOC emissions shall not cause or
allow the emission of VOC emissions from the
new source to exceed .the lowest maximum
allowable emission rate of the following: (1)
the maximum allowable emission rate listed by
the commission on its own initiative or based
upon the .application of the best available
control technology. (2) The maximum allowable
emission rate specified by a new source
performance ~tandards promulgated by the
U.S.EPA under authority enacted by Title 1,
Part A, section III of the Clean Air Act, as
amended, 42 USC 7413. (3) The maximum
allowable emission rate specified by a permit
to install or a permit to operate. The
requirements may be an ARAR if remediation
operations cause emissions of VOCs that exceed
50 tons/year, 1000 pound/day and 100 pounds
per hour.
Part 9, R336.1901: Emissions Limitations and
Prohibitions. This ARAR regulates. the
discharge of air contaminants from any source
in such concentration and duration as may be
39
-------
injurious to or adversely affect human health
or welfare, animal life, vegetation, or
property, or as to interfere with the normal
use and enjoYment of animal life, vegetation,
or property.
Part 10, R336.2001: Intermittent Testing and
Sampling. This is an ARAR for sources of
emissions on-site. This regulation may
require the owner or operator of any source of
air contaminant to conduct acceptable
performance tests, in accordance wi th Rule
1003.
o
Michigan Hazardous Waste Management Act, PA 64. This
regulation is substantially similar to U. S. EPA 's RCRA
Subti tIe C requirements, and may apply to the proper
handling, treatment, storage and/or disposal if the oil
removed from the purge wells and any trea~ent residuals
generated at the Chem Central site are characteristic
wastes under the Michigan regulations implementing the
RCRA program in that State. .
Michigan Hazardous Waste Management Rules,
Part 3: Generators of Hazardous Wastes. These
requirements are substantially similar to
Federal ARAR 40 CFR 262.
Michigan Hazardous Waste Rules, Part 4:
Transporters of Hazardous Waste. These
requirements are substantially similar to
Federal ARAR 40 CFR 263 (DOT).
Michigan Hazardous Waste Rules, Part 6:
Contingency Plan and Emergency Procedures.
These requirements are substantially similar
to Federal ARAR 40 CFR 264, Subpart D.
o
Michigan Hazardous Waste Rules,
Recordkeeping and Reporting.
requirements are substantially
Federal ARAR 40 CFR Subpart E.
Michigan Occupational Health and Safety Laws, Michigan
Act 154: Workers Protection. These requirements are
substantially similar to Federal ARAR 40 CFR 300
Part 6 :
. These
similar to
Cbemica1-specific ARAR8
Chemical-specific ARARs regulate the release to the-environment of
specific substances.
40
-------
o
Federal ARARs
Safe Drinking Water Act: 42 USC. 300. Part 141 U.S.EPA
National Primary Drinking Water Standards Maximum
contaminant Levels (MCLs). This is a relevant and
appropriate requirement when an aquifer is potentially
usable as a drinking water source.
o
40 CFR 141.50: U.S.EPA National Primary
Drinking Water Standards: Maximum Contaminant
Level Goals (MCLGs). The National Contingency
Plan states that ground water that is or could
be used for drinking water will be restored to
MCLGs that are above zero. When MCLGs are set
at zero the corresponding MCLs will be used as
the cleanup level. MCLs, where MCLGs are set
at 0, are considered by U.S.EPA to be fully
protective of human health and the environment
as these standards fall within the acceptable
risk range of 10-4to 10-6for carcinogens.
Toxic Substances Control Act (TSCA): 40 CFR 761.60:. PCB
Disposal. This is an applicable requirement when PCBs
are detected in oils removed through the operation of the
groundwater pump and treat system.
o
Federal Clean Air Act, 42 USC 1857, 40 CFR Part 50:
u. S. EPA Regulations on National Primary and Secondary
Ambient Air Quality Standards (NAAQS). This may be an
ARAR for the air stripper and soil treatment units. The
NAAQS specify the maximum concentrations of federally
regulated air pollutants (i.e., sulfur dioxide,
particulate matter, nitrogen dioxide, carbon monoxide,
ozone, and lead) in an area resulting from all sources
of that pollutant. No new construction or modification
of facility, structure.or installation may emit an amount
of any criteria pollutant that will interfere with ~e
attainment or maintenance of a NAAQS.
o
State ARARs
Michigan Environmental Response Act 307.
State ARARs for Action-Specific ARARs.
(see section on
o
Michigan Environmental Protection Act MCL section 691:
Protection of the Air, Water and Other Natural Resources
and the Public. This is a relevant and appropriate
requirement that provides judicial basis and coordinated
management action for protection of the state's air,
water, and other natural resources as well as the health,
41
-------
..
safety and qeneral welfare of the public from hazardous
substances.
o
Michiqan Water Resources Commission Act Public Act 245,
Part 4. This is a relevant and appropriate requirement
that provides qeneral prohibition of concentrations in
surface water for substances which impart unpalatable
flavor to food, fish, or otherwise interfere with the
reasonable use of the surface water in the state.
Part 4, Rule 57: Acute Toxicity: provides that
surface water must not be acutely toxic to
aquatic life (except in small zones of initial
dilution at discharqe points).
Part 4, Rule 57: Chronic Toxicity: provides
that surface water with desiqnated aquatic.
life uses shall not be chronically toxic to
aquatic life (except in mixinq zones and below
critical low-flow conditions).
Part 4, Rule 57: General Toxicity: provides
that surface waters must not be toxic or
injurious to man or to terrestrial or aquatic
life.
Part 4, Rule 57: Human Toxicity: provides
that surface water must be maintained to
preclude adverse toxic effects on human health
resulting from contact recreation, consumption
of aquatic organisms, or consumption of
drinkinq water after reasonable treatment.
Part 4, Rule 57: Toxicity criteria: provides
that concentrations of toxic materials for
which no numerical criteria have been
specified must not exceed values which are
chronically toxic to representative, sensitive
aquatic orqanisms, as determined from
appropriate chronic toxicity data or
calculated as 0.1 of the median lethal
concentrations (LC50) for non-persistent
toxics. .
Part 4, Rule 57: Numerical criteria for
Toxics: provides for numerical criteria for
certain toxic materials includinq some site
indicator chemicals.
Part 4, Rule 98: Antideqradation: requires
maintenance and protection of existinq waters
when water quality is better than water
42
---... -.-.
-------
~
quality standards, especially when discharging
wastewater. In addition, this rule would
address ground water discharges to surface
water bodies. .
o
Part 9, Rule 234: Wastewater Reporting. This
is an applicable regulation which provides
reporting requirements for discharges of
wastewater to the waters of the state or for
discharges to a sewer system. An ARAR because
treated ground water is discharged to a POTW.
Michigan Safe Drinking Water Act: Michigan Public Act
399. Act 399 is a relevant and appropriate requirement
because although a "public drinking water supply system"
as defined under the Act does not or may not currently
exist at or near the site, ground water could potentially
be used as a drinking water source in the future.
o
Michigan Air Pollution control (MAPC) Act: Michigan
Public Act 348. part 3, R336.1301 and 336.1331:
Particulates. This is an applicable regulation for the
air stripper and soil treatment unit.
Part 3, R336.1371 to 1373: Fugitive Dust. This
is an ARAR for loading and unloading of bulk
materials that act as a source of fugitive
dust. Trucks with less than a 2-ton capacity
that are used for transporting of bulk
materials are exempt. Trucks larger than 2-
ton capacity must abide by Rule 372 provisions
when transporting.
Part 7, R336.1702: New Sources of VOC
Emissions. Any person responsible for any new
source of VOC emissions shall not cause or
allow the emission of VOC emissions from the
new source to exceed the lowest maximum
allowable emission rate of the following: (1)
the maximum allowable emission rate listed by
the commission on its own initiative or based
upon the application of the best available
control technology. (2) The maximum allowable
emission rate specified by a new source
performance standards promulgated by the
U.S.EPA under authority enacted by Title 1,
Part A, Section III of the Clean Air Act, as
amended, 42 use 7413. (3) The maximum
allowable emission rate specified by a permit
to install or a permit to operate. . The
requirements may be an ARAR if remediation
operations cause emissions of vocs.that exceed
43
-------
50 tons/year, 1000 pound/day and 100 pounds
per hour.
Part 9, R336.1901: Emissions Limitations and
Prohibi tions. This ARAR regulates the
discharge of air contaminants from any source
in such concentration and duration as may be
injurious to or adversely affect human health
or welfare, animal life, vegetation, or
property, or as to interfere with the normal
use and enjoYment of animal life, vegetation,
or property.
Part 10, R336.2001: Intermittent Testing and
sampling. This is an ARAR for sources of
emissions on-site. This regulation may
require the owner or operator of any source of
air. contaminant to conduct acceptable
performance tests, in accordance wi th Rule
1003.
Location-specific ARARB
Location-Specific ARARs are requirements placed upon the
concentration of hazardous substances or the conduct of activities
solely because they are in specific locations. .
o
Endangered Species Act: 16 USC. 1531 et seg.: 50 CFR part
200: Game Law of 1929, Public Act 286. Statute requires
that proposed actions minimize effects on endangered
. . species. It is an applicable requirement if plant or
animal endangered species or "critical habitat" is
adversely impacted by the site.
OTHER CRITERIA. ADVISORIES OR GUIDANCB '1'0 BB CONSIDERED (TBCs) POR
THIS REMEDIAL ACTION (This list i8 not all inclusive):
o
RCRA Air Emission Standards - 3 lbs/hour total organic
emissions from all units.
o
Heal'th Effects Assessments (HEAs) and Proposed HEAs,
(Health Effects Assessment for (Specific,Chemicals).
Reference Doses (RFDs), ("Verified Reference Doses of
U.S.EPA, "ECAO-CIM-475, January 1986). See also Drinkinq
Water Equivalent Levels (DWELs), a set of medium-specific
drinking water levels derived from RFDs.
o
o
Carcinogenic Potency Factor (CPFs) (e.g., Ql Stars,
Carcinogen Assessment Document for Tetrachloroethylene
(Perchloroethylene).
44
-------
o
Public health criteria, on which the decision to list
pollutants as hazardous under Section 112 of the Clean
Air Act was based.
o
Guidelines for Ground Water Classification under the
U.S.EPA Ground Water Protection strategy.
U.S.EPA Ground Water Protection strategy (August 1984).
o
o
U.S.EPA Guidelines
(December 1986).
Ground Water
Classification
for
o
Elements of aquifer identification (October 1979).
OSHA heal th and safety standards that may be used to
protect public health (non-workplace).
o
o
Health Advisories, U.S.EPA Office of Water.
U.S.EPA Water Quality Advisories, U.S.EPA Office of
Water, ,criteria and Standards Division.
o
o
U.S.EPA, Superfund Public Health Evaluation Manual
(October 1986), Provide Acceptable Intake Concentration
(AlC) Reference Dose (RFD) and Minimum Effective Dose
(KED).
o
Health Advisories (U.S.EPA Office of Drinking Water).
o
Risk Assessment Guidance for Superfund, Volume I, Human
Health Evaluation Manual (Part A), Interim Final,
December 1989
o
Risk Assessment Guidance for Superfund, Volume II,
Environmental Evaluation Manual, Interim Final, March
1989.
o
U.S.EPA Integrated Risk Information System.
U . S. EPA Proposed Maximum Contaminant Level Goals (MCLGs).
o
o
U.S.EPA
factors.
carcinogen
(CAG)
potency
Assessment
Group
o
Federal Sole Source Aquifer requirements
court-Ordered Ground Water Remediation criteria. The
court decided that Chem Central/Grand Rapids Corporation
may discontinue purging ground water when the following
conditions are met:
o
45
-------
a. The concentration of a comp.ound in ground water is
equal to or less than the 10-5risk level of NOAEL as
appropriate for the particular compound: or
b. When the concentration of the compound has been
reduced to the point of diminishing return as calculated
according to a specified method.
and
Hydraulic
o
soil Properties, Classification,
Conductivity testing.
A Method For Determining the compatibility of Hazardous
Wastes.
o
o
Guidance Manual on Hazardous Waste Compatibility.
Federal Clean Water Act, section 304 (g) Guidance
Document, Revised Pretreatment Guidelines (3 volumes).
o
o
Guidance for POTW Pretreatment Program Manual.
Developing Requirements for Direct and
Discharges of CERCLA Wastewater~ Draft (1987).
Indirect
o
RCRA
Permit
by
Rule
o
Guidance for Implementing
Requirements at POTWs.
Draft Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under the
Pretreatment Program.
o
o
Water Related
Pollutants.
Environmental
Priority
of
129
Fate
o
Water Quality Standards Handbook.
Technical Support Document for Water Quality-based Toxics
Control.
o
o
Lab Protocols Developed Pursuant to the Clean Wate~ Act.
The source of the oil contaminated with PCBs and other organic
compounds collecting in the active purge wells is presently.unknown
and may in fact be a continuing source of ground-water
contamination. Due to this possible source, ground-wate~ ARARs may
not be met utilizing the proposed remedial alternative. Before any
findings are made regarding the techi1ical impracticability of
achieving ground-water ARARs, a full investigation of the nature
and extent of soil and ground-water contamination under the Chem
Central building and paved areas must be conducted.
"6
-------
o
COST-BPPBCTrvBHBSS
The selected remedy is cost-effective since it provides overall
effectiveness proportional to its costs. The net present worth
value is approximately $2,100,000. The selected remedy for ground
water is the least costly alternative which provides full
protection of human health and the environment. soil vapor
extraction is the least costly soil al ternati ve providing both
treatment of the contamination (as opposed to containment) and
overall prot~ction of human health and the environment.
UTILIZATIOII 01' PBRDlIENT SOLUTIONS AND ALTBRHATIVB TRBATKBNT
TBCBHOLOGIBS (OR RESOURCB RECOVERY TBCBHOLOGIBS) TO TBB XU:IKtJK
BD'BII'l' PRACTICABLE
U. S. EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner at the Chem
Central site. Of those al ternati ves which protect human health and
the environment and comply 'with ARARs, U.S.EPA has determined that
the selected remedy provides 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, implementability, cost, the statutory preference for
treatment as a principal element, and state and community
acceptance.
The selected remedy for both ground water and soil does result in
air emissions which may increase short-term risks to the community
and the environment during implementation: however, vapor phase
carbon adsorption will be used to minimize these emissions to
within acceptable risk levels. The remedy for both ground water
and soil is a treatment technology and therefore satisfies
u. S. EPA 's preference for treatment as a principal element. The
remedy is easy to construct and operate and presents little or no
administrative difficulty. The ground water remedy for the most
part is in place and operating to design specifications, air and
water discharge permits have also been obtained. A pilot study
will be required for the soil remedy prior to full-scale
application. The remedy is the least costly of the alt~rnatives or
combination of alternatives which provide full protection of human
heal th and the environment and use treatment to address the
contamination. Institutional controls and operation and
maintenance will ensure that the remedy is effective in the long-
term. In addition, the state of Michigan has concurred with the
selected remedy.
PUPBUIICB :rOR TRBATKBNT AS A PRINCIPAL BLBKBHT
As mentioned above, the remedy for both ground water and soil at
the Chem Central site satisfies U.S.EPA's preference for treatment
as a principal element. Ground water is (and will be) treated
47
-------
using air stripping, and soils will be treated using soil vapor
extraction.
DOCtJHENTA'1'ION OP SIGNIPICANT CHANGBS
The Proposed Plan for the Chem Central site was released for public
comment July 10, 1991. The Proposed Plan identified Alternatives
GW-C, GW-D, GW-E, and S-A as the preferred alternatives. U.S.EPA
reviewed all written comments (no verbal comments were made)
submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the
remedy, as it was originally identified in the Proposed Plan, were
necessary.
_..... '.#h..
48
-------
STATE OF MICHIGAN
NATURAL RESOURCES COMMISSION
MARLENE J. FLUHARTY
GORDON E. GUYER
O. STEWART MYERS
RAYMOND POUPORE
...'"
~
ffii ~~ ~ ~ 1~9~ ~
JOHN ENGLER, Governor
DEPARTMENT OF NATURAL RESOURCES WASTtS: ~,~~ REGiON V
STEVENS T. MASON BUILDING N:Ai\f\\:iEI\':ENT DIVISION
P.O. BOX 30028 OFFICE OF. THE DIRECTOR
LANSING. MI 48909
RECEIVED
~~~~mx~~
Roland Harmes, Director
SEP 2 6 1991
September 24, 1991
o : u.Jmb
~ e~/r2F
IJ)E. s+l~
U. S. EPA REGION 5
OFFICE OF REGlor;;.j" A:MINISTRATOR
Mr. Va1das Adamkus. Regional Administrator
U.S. Environmental Protection Agency
Region 5, 5RA-14
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Adamkus:
ill & (f rf n n- rr
U C;r;i 18:,1$ fJJ]
OFF/"E (jf
ASSOCIATE DJ SUPtRFUND
VISION ()'~-"'Tr.
The Michigan Department of Natural Resources (MDNR), on behalf of the State"of
Michigan, has reviewed the draft Record of Decision (ROD) which we received on
September 9, 1991, for the CHEMCENTRALjGrand Rapids (CCGR) Superfund site in
Kent County, Michigan. We are pleased to inform you that we concur with the
selected remedy outlined in the draft ROD.
The major activities required by the selected remedy include:
o continuing operation of the existing groupdwater collection and treatment
system;
o imposing institutional controls such as deed restrictions to prohibit
installation of water wells in the site area and any future development that,
might disturb contaminated soils. The institutional controls will continue
until the groundwater and soil remedies have been completed;
o installing,and operating an expansion of the current off-property
groundwater' collection system, either by extending the interceptor trench or
installing additional purge wells;
o install ing and operating an in-situ soil vapor extraction (SVE) sy'stem for
soils on-property as well as two off-property locations just north of the
property. If, following a treatability study.or through additional soil
testing during operation of the SVE system, it is determined that the system
is unable to reduce the semi-volatile compounds to below the soil cleanup
standards, additional treatment methods will be evaluated and implemented to
attain the desired cleanup standards. The cleanup levels for soils will be
dictated by the Type B cleanup levels for soils as described in the Michigan
ni
-------
G
Mr. Va1das Adamkus
-2-
September 24, 1991
Environmental Response Act (MERA) (1982 P.A. 307, as amended), MCl 299.601
et ~, and its rules. Since groundwater discharge to Cole Drain is or may
be occurring, consistent with the 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 Michigan Water Resources Commission
Act (WRCA) (1929 P.A. 245, as amended) where these are more stringent than
those resulting from the MERA Rules 711(2) or 711(5). However, if a leach
test is performed consistent with Rule 711(2), the cleanup numbers maybe
revised to reflect the results of the leach test. These numbers are listed
in Table 7 of the draft ROD;
o installing and operating a purge well at the deep lens referred to as SCH-2
to extract contaminated groundwater. This well will be piped into the
existing treatment system;
o collecting oil accumulating in the purge wells and disposing of the oils at
an off-site facility in accordance with applicable state and federal
regulations;
o implementing a groundwater monitoring program capable of demonstrating the
effectiveness of the groundwater capture system.
The groundwater cleanup numbers for all groundwater will be dictated by the
Type B numbers generated pursuant to the MERA Rule 709 or, as required by the
HERA Rule 713(2), the Rule 57(2) numbers, whichever is more stringent. These
cleanup criteria are listed in Table 7 of the draft ROD.
The MONR also concurs with the Statutory Determination Summary with the
following exception. The MOHR has previously identified the WRCA MCl 323.6(a)
and the associated Part 22 Administrative Rules, MAC R.323.2201 et ~ as
ARARs for this site. It remains our position that the WRCA 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.
a
It is the MOHR's judgement, however, that the selected remedial action for
this site will provide for attainment of all ARARs, including the WRCA and the
Part 22 Rules, by preventing further discharges of injurious substances into
the groundwater outside of the containment area, and by remedying the existing
groundwater contamination.
.
-. ...
-------
- -
v .
'J
Mr. Valdas Adamkus
-3-
September 20, 1991
We still have the same concerns outlined in our letter of September 20, 1991,
containing comments on the proposed plan for this site. These concerns are
that the selected remedy may not be able to meet the cleanup objectives in a
timely manner due to the presence of a floating product layer on the
groundwater; soil vapor extraction may not be able to treat semi-volatile
contaminants; and soils in the water table fluctuation zone would be treated
faster by active remediation than by natural flushing with contaminated
groundwater. We reiterate our position that the ROD should explicitly set
a timeline for conducting the additional work activities for the soils under
the buildings and paved areas on the CCGR property.
We are encouraged, however, that the U.S. Environmental Protect.ion Agency
will set the cleanup standards at those specified as Type B rules of our MERA.
We understand that these numbers will become the performance standard that
will have to be achieved, regardless of the technology employed to meet the
standards.
If you have questions regarding this site, please contact Mr. Mitchell Adelman
at 517-373-8436, or you may contact me directly.
Sincerely,
~j?- /)
~~\. Delbert Rect~ ?
Deputy Director
517-373-7917
cc:
Mr. Jonas Dikinis, EPA
Ms. Wendy Carney, EPA
Mr. Michael McAteer, EPA
Mr. Jeremy Firestone, DAG
Mr. Alan Howard, MDHR
Mr. William Bradford, MDHR
Mr. Peter Ollila/CCGR File
Mr. Mitchell Adelman, MDHR
.
------- |