United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPAIRODIR05-921221
September 1992
PB93-964122
\)
&EPA
Superfund
Record of Decision:
Butterworth #2 Landfill, MI
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EP A Report Collection
Information Resource Center
US EPA Region 3
Philadelphia. PA 19107
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~fOrdoU$ Waste Collecffon
tJs~o:::n~ource Center
PhilQdelphfa, PA 19107
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Region 11\ Hazardo~s Waste
Tecllnicallnformatton Center
841 Chestnut Street. 9th Floor
Philadelphia. PA 19107
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NOTICE.
The appendices listed In the index that ant not found In this document have been f8mCMId at the request of
the issuing agency. They contain mat8riaI which supplement. but adds no further appQc:abIe Information to
, the content of the document. All supplemental material Is, however, contained In the administrative record
for this site.
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50272.101
REPORT DOCUMENTATION 1" REPORT NO. I ~ a. AIcIpI8nt. ~on No.
PAGE EPA/ROD/R05-92/221
... 1118........ I. AIpart D8I8
SUPERFUND RECORD OF DECISION 09/29/92
Butterworth 12 Landfill I.
First Remedial Action - Final
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401 M Street, S.W. - ..
Washington, D.C. 20460 14.
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PB93-964122
18. Ab8tr8ct (limit: 2Il1O --I
The 180-acre Butterworth 12 Landfill is a municipal landfill in Grand Rapids, Kent
County, Michigan. Land use in the area is predominantly residential and industrial.
The site, which lies within the 100-year floodplain of the Grand River, contains
wetland drainage areas with emergent aquatic communities. Prior to 1967, the area to
the east of the stormwater out-fall was used as a municipal landfill (Butterworth 11).
This portion of the site was operated as an open landfill where daily cover of refuse
was not provided. After the enactment of Michigan Act 87 in 1965, Butterworth 11 was
closed, and Butterworth 12 and 13 were opened. Several high-voltage power
transmission lines pass through the landfill, and landfilling was not allowed in the
areas below the power lines; however, it was discovered that the area was allegedly
used to dispose of liquid wastes, such as solvents and paint sludge. Records indicate
that from 1967 to 1971, approximately 3,000 to 4,000 cubic yards of waste per day were
received at the landfill. In 1988, a surface soil/test pit assay identified PCBs at
levels of 800 mg/kg and chromium at levels of 43,000 mg/kg. In 1990, a removal action
was initiated to address this contamination, which resulted in 1,100 tons of material
being removed from the site. This ROD addresses a final remedy for the landfill via
(See Attached Page)
17. DcJa8Mnt An8Jye18 .. D88crtpt0..
Record of Decision - Butterworth #2 Landfill, MI
First Remedial Action - Final
Contaminated Media: Soil, debris
Key Contaminants: VOCs (benzene, TCE, xylenes), other organics (PCBs, pesticides),
and metals (arsenic, chromium, lead)
b. IcIentifier8lOpen-EncIed Tem18
c. COSA 11 FIeIcIIGroup
18. AvoilabiHty Slatement 18. SeCt8'lty Cia.. (Thia Report) 21. No. 01 Page.
None 62
20. SeCt8'Ity CI... (Thia I'8ge) n Price
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(See ANSl-Z39.18)
rruclion. on Revef8e
(Formerfy NTlSo35)
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EPA/ROD/R05-92/221
Butterworth '2 Landfill, MI
First Remedial Action - Final
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Abstract (Continued)
and copper. In 1985, the state and C&D Recycling arranged for the excavation and offsite
capping and establishing ACLs for site-specific contaminants of concern in ground water.
The primary contaminants of concern affecting the soil are VOCs, including benzene, TCE,
and xylenes; organics, including PCBs, and pesticides; and metals, including arsenic,
chromium, and lead.
The selected remedial action for this site includes removing and disposing of exposed
drums containing hazardous materials at an offsite RCRA facility; upgrading the landfill
cover to include a clay cap, and gas venting and treatment systems to meet state
standards; revegetating the area; installing additional monitoring wells in the upper and
lower.aquifers, and implementing a long-term monitoring program for ground water, surface
water, sediment, and biota; establishing ACLs for site ground water based on the current
level of contamination; mitigating affected wetlands; implementing institutional controls
including deed and ground water use restrictions. The est~ted present worth cost for
this remedial action is $15,230,000, which includes an annual O&M cost of $110,000 for
30 years. .
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up goals were not
established in this ROD because current contamination levels will be determined through
sampling of compliance monitoring wells for eight consecutive quarters over a 2-year
period. The indicator parameters to be analyzed quarterly will include all chemicals
established as chemicals of .concern. After the initial 2-year period of quarterly
sampling, ground water shall be monitored for the next 3 years on a quarterly basis;
then, analysis will be made for the primary contaminants of concern.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Butterworth Landfill site
Grand Rapids, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Butterworth Landfill site, in Grand Rapids, Michigan, chosen
in accordance with CERCLA, as amended by SARA and, to the extent
practicable, the National oil and Hazardous Substances Pollution
contingency Plan. This decision is based on the administrative
~ecord file for this site.
The state of Michigan does not concur on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
The remedy will involve capping the landfill and establishing
Alternate Concentration Limits for site specific contaminants of
concern in ground water. The response action for this remedy will
eliminate the primary route of exposure at the site by containing
the soils under a cap that will meet the intent of Michigan Act
641 requirements.
.The major components of the selected remedy include:
Institutional controls
Grading and leveling of the site.
Removal of exposed drums containing hazardous material,
substance or waste, and disposal off-site at a RCRA Subtitle
C disposal facility.
Improvement of the site capping to meet the requirements of
a Michigan solid waste cap (MI Act 641) with inclusion of a
frost protection layer.
Establishment of alternate concentration limits (ACLs) for
ground water.
Ground-water, river-water and river-sediments monitoring.
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STATUTORY DETERMINATIONS
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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. However, because
treatment of the principal threats of the site was not found to
be practicable, this remedy does not satisfy the statutory
preference for 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 remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
Valdas V. Ad us
Regional Adm'nistrator
JJ~k- 2£ Iflf2
Date
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DECISION SUMMARY FOR THE RECORD OF DECISION
SITE RAKB. LOCATION. AND DESCRIPTION
The Butterworth Landfill (Butterworth) site is located in Grand
Rapids, Kent County, Michigan, about one mile southwest of the
Grand Rapids downtown area. The site is approximately 180 acres
and its approximate boundaries are the Grand River on the south,
Interstate 196 on the west, Butterworth street on the north and a
Consumers Power substation on the east (see Figure 1). A
combined storm-water outfall crosses the site (see Figure 2).
The site is within the hundred year floodplain of the Grand
River. .
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The area immediately surrounding the Butterworth site is
, predominantly industrial (see Figure 1). To the west of
Interstate 196 are gypsum mining and processing facili~ies. The
Consumers Power substation and metal recycling facilities are
located to the east. Across the Grand River is the Grand Rapids
sewage treatment plant which is permitted by the State of
Michigan to discharge to the river just south of the site.
Between Butterworth Street and the Butterworth Landfill are
several light industrial facilities. To the north of Butterworth
Street is a residential area, ball park, and zoo.
Butterworth Landfill is generally isolated from the public, and
located away from most housing development. The site is easily
accessible, however, by foot or boat. The John Ball Park and Zoo
are approximately one-quarter mile north of the landfill.
Development along Butterworth Street is generally limited to
small industries. The primary route of exposure from the site
for the surrounding population is through inhalation of
contaminated air and dust. Contaminated ground water does not
migrate into this area because it is upgradient from the site.
The Grand River is a popular recreation area,
utilized by the local community as well as by
for boat entry into the river was constructed
site; however, it is not currently in use.
and is heavily
tourists. A ramp
on the landfill
The ground water table at the site is located in the glacial lake
plain deposits at a depth of approximately twenty-five feet.
This aquifer is contaminated by leachate from the site. Because
of the close proximity of the Grand River to the site, river
stage can be expected to affect ground water levels beneath the
landfill. The .Michigan Formation separates this aquifer from the
underlying Marshall Sandstone, which is the main source of water
for many industrial wells in the Grand Rapids area.
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SITE HISTORY AND EHPORCBMENT ACTIVITIES
The Butterworth Landfill site was operated by the City of Grand
Rapids, Michigan, and was used for both residential and
industrial waste. Landfilling was performed in three general
areas at the Butterworth Site (see Figure 2). . The limited
information available indicates that, prior to 1967, the area to
the east of the storm water out-fall was used as a municipal
landfill. This area is referred to as the Old Butterworth Dump,
or Butterworth #1. This portion of the site was operated as an
open landfill where daily cover of refuse was not provided. The
refuse was often burned to reduce its volume. . .
After the enactment of Michigan Act 87 in 1965, and consistent
with the federal goal of eliminating open dumping, the Old
Butterworth Dump was closed sometime around 1967 and a new site,
Butterworth Landfill #2, was opened. This new site occupied an
area in.the southwest corner of the site. .
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Later, an additional area, Butterworth Landfill #3, was opened.
The combined size of Landfills #2 and #3 was about 80 acres.
These areas were used by local residents and industries to
dispose of wastes. Several high voltage power transmission lines
pass through the middle of Landfill #2 and #3. For safety
reasons, landfilling was not allowed in the area below these
power lines. However, during the course of the field
investigation, some fill material was identified in the area
below the power lines. In addition, this area was allegedly used
to dispose of liquid wastes such as solvents and paint sludges.
The landfill reportedly received municipal solid waste and
industrial wastes. There is no record as to the exact nature of
these materials, nor the quantities involved. It is also not
clear who all of the potential generators or transporters may
have been. Due to the large industrial sector in the Grand
Rapids area, industrial waste input to the landfill may have
accounted for a significant portion of total waste. There is
some indication (based on file records) that industrial wastes
disposed of at the landfill were either .in drums, which were
buried, or simply dumped in liquid form on a working surface.
other disposal methods, if any, are presently unknown. Records
indicate that from 1967 - 1971 about 3000 - 4000 cubic yards of
waste per day were received at the landfill.
The' landfill was constructed on existing native soils at the
site. .The available data does not show whether a liner or seal
material (such as clay) was used prior to initial fill
operations. It is reported that a clay dike was constructed
around portions of the landfill at some point during its
operation. However, the landfill materials are presumed to have
been primarily materials that existed on-site.
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Butterworth was nominated
and was placed on the NPL
Investigation/Feasibility
1986.
for the National Priorities List (NPL)
in December 1982. The Remedial
study (RI/FS) was initiated in June
In 1988 the surface soil/test pit assay conducted during the RI
located a hot spot of polychlorinated biphenyls (PCBs) at levels
of 800 mg/Kg and chromium (total) at levels of 43,000 mg/Kg. A
removal action was initiated to address this contamination and
was completed in June 1990. Approximately 1100 tons. of material
were removed from the site. The PCB contaminated soil was sent
to Alabama for disposal in a RCRA subtitle C landfill.
HZGHLZGHTS OP COMMUHZTY PARTZCZPATZON
.
An extensive community relations program was undertaken at the
site. Public meetings and availability sessions, usually held
every two to three months, were held to keep the public informed
of progress at the site and address their concerns. A Technical
Assistance Grant was made available to one local community
organization to provide assistance in interpretation of site
related information and documents.
The RI Report, FS Report and the Proposed Plan for the
Butterworth Landfill site were released to the pUblic for comment
on May 26, 1992. These documents were made available to the
public in both the administrative record and information.
repositories located at the Main Branch of the Grand Rapids
Public Library, the West Side Branch of the Grand'Rapids Public
Library and the u.s. EPA Region 5 office in Chicago, Illinois.
The notice of availability for these documents was published in
the Grand RaDid's Press newspaper on May 21, 1992, and The West
side Advance newspapers on May 26, 1992. A public comment period
on the documents was held from May 26, 1992, to July 24, 1992.
In addition, a pUblic meeting was held on June 11, 1992. At this
meeting, representatives from u.s. EPA and Michigan Department of
Natural Resources (MONR) answered questions about problems at the
site and the remedial alternatives under consideration. A
response to the comments received during this period is included
in the Responsiveness Summary, which is part of this ROD. The
public participation requirements of CERCLA Sections 117 and
113(k) (2) (B) (i-v) have been satisfied.
SCOPE AND ROLE OF THE RESPONSE ACTION
This ROD will eliminate .the primary route of exposure at the site
by containing the soils under a cap that will meet the intent of
Michigan Act 641 requirements. Exposure to site soils poses the
primary danger to human health and the environment because of the
risks from possible inhalation, ingestion or dermal contact.
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There is also the threat of contaminant migration from the soils
into the underlying ground water that discharges into the Grand
River. The purpose of this response is to reduce contaminant
migration into the ground water, surface water, and air, and
prevent direct contact with the contaminants.
These goals will be met through the proposed action, which will
involve improving the landfill cover, the establishment of
Alternate Concentration Limits (ACLs) for ground water and ground
water monitoring to ensure the continued absence of impact from
the site on the Grand River. ACLs are site-specific ground water
contaminant concentration levels that will be established through
a process which meets the criteria set forth in section
121(d) (2) (B) (if) of CERCLA. Frequent monitoring of ground water,
river water and river sediments will be undertaken to ensure that
the ACLs will not be exceeded. The establishment of ACLs
provides an enforceable limit for contamination levels in ground
water. If either the new levels are exceeded or if a change in
the river quality indicates that the site is now having an impact
on the river, then further response action for ground water will.
be considered in accordance with CERCLA.
Information gathered during the Remedial Investigation indicates
that due to the location of the site, the direction of ground
water flow and the remedy proposed in this ROD, ACLs are
appropriate for addressing the contamination of ground water at
the Butterworth site. The Superfund Amendments and
Reauthorization Act (SARA) provides for a process for the
establishment of ACLs in Section S121(d) (2) (B)(ii). This section
states that "...a process for establishing alternate
concentration limits to those otherwise applicable for hazardous
constituents in ground water may not be used to establish
applicable standards...except where- (1) there are known and
projected points of entry of such ground water into surface
water; and (II)...there is or will be no statistically.
significant increase of such constituents from such ground water
in such surface water...and (III) the remedial action includes
enforceable measures that will preclude human exposure to the
contaminated ground water at any point between the facility
boundary and all known and projected points of entry of such
ground water into the surface water." The Preamble to the.
National Contingency Plan (NCP) (55 FR 8754) elaborates that
"EPA's policy is that MCLs or MCLGs above zero should generally
be relevant and appropriate requirements for ground water...and
that a waiver is generally needed in situations
where... (they)...cannot be attained. If, however, a situation
fulfills the CERCLA statutory criteria for ACLs...documentation
of these conditions for the ACL is sufficient and additional
documentation of a waiver of the MCL or MCLG is not necessary."
The decision to establish ACLs must be based on whether the site
fulfills the three requirements specified in CERCLA and whether
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remediation of the aquifer to MCLs or non-zero MCLGs is
impracticable. This site meets those requirements. The ground
water discharges into the Grand River (requirement I), there is
no statistically significant impact on river quality that can be
attributed to the site (requirement II), and the fill material
(i.e., the site) extends to the edge of the Grand River allowing
for enforceable measures to preclude human exposure (requirement
III). Additionally, the risk associated with ground water is not
considered significant, calculated to be 9X10-5, and it does not
exceed the upper bound acceptable risk established in the NCP of
1x10-4. Fill material from the landfilling operations extends
into the aquifer throughout the site and it is impracticable to
remove this material from the site ground water. For this
reason, implementation of an active ground-water remediation
would not significantly impact the quality of the ground water in
the shallow aquifer beneath the site. Furthermore, because the
fill actually extends into the river, any active ground water
remediation would likely bring a significant amount of river
water into the landfill. Consequently, the depth of fill
material in combination with the proximity of the fill to the
river makes remediation of the aquifer to MCLs or non-zero MCLGs
impracticable. For these reasons, the Agency believes that it is
appropriate to establish ACLs for site ground water.
SUMMARY OP SITE CHARACTERISTICS
GEOLOGY
The bedrock formations underlying the Grand Rapids area are of
sedimentary origin, formed from sand, clay, or limey mud. The
bedrock strata in the area is covere~ almost everywhere by
glacial drift.. In the Grand Rapids area the rocks that form the
bedrock surface beneath the drift are, from oldest to youngest:
Coldwater Shale, the Marshall Formation, the Michigan Formation
and the Bayport limestone, all of the Mississippian age; t~e
Parma sandstone and a very small area of outcrop of Saginaw
Formation, both of Pennsylvanian age. The bedrock formations are
exposed along the Grand River in the southern part of Grand
Rapids and at points in Wyoming, Paris, Gaines, and Walker
Townships. .
Well records within a five mile radius of Butterworth Landfill
indicate that the Michigan Formation exists below the surface
sand deposits. This formation consists of about seventy-five
feet of alternating layers of gypsum and hard shale. The
Michigan Formation at the site was found to range in thickness
from 75 feet to 116 feet. Most of the Michigan formation
appeared dry and free of water.
Below this is the Marshall Formation consisting of some 300 feet
of poorly cemented sandstone and hard shale. The Marshall
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formation extends to 370 feet below the surface and is the upper
unit of the Mississippian Aquifer System. Both of these
formations dip in a northerly direction. '
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The fill materials deposited at the Butterworth site are directly
on top of Pleistocene near shore lake plain deposits that extend
for about twenty-five feet. Beneath this is approximately
fifteen feet of gypsum, which appears to be present in several
continuous layers. Below the gypsum is twenty-five feet of
shale, which is underlain by about ten more feet of gypsum.
In the northern part of the landfill, the fill material was found
to extend from the surface to an estimated forty feet below the
surface. The glacial and alluvial deposits lying below the fill
material and unconformably above the Michigan Formation are found
at or near the surface in the north of the site and at depth of
twenty feet below the surface near the river. The glacial
materials are composed of gray, medium to coarse sands
interbedded with fine gravels. The glacial and alluvial deposits
were found to range from coarse gravels to silts. Fine sands
were shown to be most abundant. A few small clay lenses are also
present at the site.
HYDROLOGY
The Grand River has the second largest drainage basin of any
stream in Michigan. It drains an area of about 5,570 square
miles, of which 4,900 square miles lie upstream from Grand
Rapids. The river is about 300 miles long and has a total fall
of more than 500 feet. It rises in the northeastern part of
Hillsdale County, flows northwestward, and empties into Lake
Michigan. at Grand Haven. Principal tributaries are the Roque,
Thornapple, Flat, Maple, Lookinglass, and Red Cedar Rivers.
The annual average flow of the Grand River at Grand Rapids from
1983 to 1988 was estimated to be 4,710 cubic feet per second
(cfs), with the greatest daily flows occurring during February,
and to a lesser extent in March. Ten year, seven day low f~ow
has been reported as 696 cfs. The maximum discharge in this area
(recorded period 1901-1978) occurred during the flood of 1904,
when a flow of 54,000 cfs was recorded. This flood resulted in
the complete inundation of the area now occupied by Butterworth
Landfill.
Mean annual precipitation in Kent County is about 33.5 inches per
year, with a mean annual evapotranspiration rate of 30 inches per
year. Thus, net percolation to the water table is 3.5 inches per
year. Infiltration rates are generally high in the area. High
stream flow occurs during spring because of snow melt.
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Drainage at the landfill site is accomplished by two drainage
swales, one to the north and one to the west. These areas join
and drain into the Grand River.
HYDROGEOLOGY
Ground water in the Grand Rapids area occurs in both bedrock and
unconsolidated glacial drift deposits. It is used by practically
all the population and industries outside the area served by the
cities of Grand Rapids, East Grand Rapids, Walker, and wyoming.
The quantity and quality of the ground water available are
dependent on the geology. In general, the aquifers in the Grand
Rapids are recharged by precipitation that falls within the area.
Declines in ground water level occur because of evaporation,
drainage to adjacent streams. and discharge from wells.
The Marshall formation lies immediately above the Coldwater Shale
and is the only bedrock formation in the area that yields large
quantities of water. The formation is composed almost entirely
of sandstone that is relatively permeable. The formation
contains a shaly area that separates the formation into an upper
and lower part.
The ground-water table at the site is located in the twenty-five
feet of qlacial lake plain deposits that lie just below the fill.
Because of the close correlation between snowmelt, rainfall, and
ground-water level, particularly in areas with sand soils, the
elevation of the ground water at the site fluctuates with
precipitation.
Because of the close proximity of the Grand River to the
Butterworth Landfill, river stage can be expected to affect
ground-water levels beneath the landfill. In general, it can be
expected that ground water will flow from the water table beneath
the landfill to the Grand River. The total discharge from the
site, based on ground-water flow and infiltration, is calculated
to be 0.138 cfs as compared to the 4,710 cfs average annual flow
of the Grand River.
ECOLOGY
The entire landfill site is overgrown with tall grass, brush and
scattered small trees. Larger trees, generally willow and
cottonwood, are located along the Grand River. The wetland
drainage areas to the north and east of the landfill contain
emergent aquatic communities such as grasses, sedges, and
cattails.
Animal burrows are present throughout the site. Representative
rodents that are likely to be present on the site are muskrats,
gophers, opossum, shrews, mice, and rats.
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The freshwater fish predominantly found in this area of the Grand
River include bass, yellow perch, sunfish, crappie, rock bass,
and suckers. A survey was conducted by the State of Michigan
Water Resources Commission on the Grand River to determine heavy
metal concentrations in fish. Concentrations were not found to
exceed FDA or Canadian tolerance limits.
SUMMARY OP SZTE RZSKS
During the RI/FS, an evaluation was conducted to estimate the
health or environmental problems that could result if the
contamination at the site was not addressed. This evaluation is
commonly referred to as a baseline risk assessment. In
conducting this assessment, the focus was on the health effects
that could result from exposure to contaminated soil,
contaminated ground water and water from the Grand River that
could have been impacted by contaminated ground water.
The potential routes of exposure evaluated were ingestion,
inhalation and dermal contact with soil, ingestion and dermal
contact with Grand River water, and ingestion of ground water.
As in most landfills, there is a large number of contaminants at
the Butterworth Landfill contributing to the risks associated
with the site. However, the number of contaminants that
constitute over 95% of the risk in each medium is relatively
small. In ground water, the compounds that cause 95% of the
elevated risk levels are the metals antimony and arsenic, the
volatile organic compounds l,l-dichloroethane and vinyl chloride,
and the semivolatile organic compounds bis(2-ethylhexyl)
phthalate, and polychlorinated biphenyls (PCBs). The
contaminants in soils that cause 95% of the elevated risk levels
are the metals arsenic, beryllium, and chromium; and the
semivolatile organic compounds polynuclear aromatic hydrocarbons
(PAHs), PCBs, and the pesticide dieldrin.
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 carcinogenic
. 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. CPFs
are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation
and uncertainty factors have been applied.
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Excess lifetime cancer risks are determined by multiplying the
intake level with the CPF. These risks are probabilities that
are generally expressed in scientific notation (e.g., 1X10-6).
an excess lifetime cancer risk of 1X10-6 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 at a site.
Reference doses (RfDs) have been developed by u.s. EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting non-carcinogenic 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 can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied. These uncertainty factors help ensure
that the RfDs will not underestimate the potential for adverse
non-carcinogenic effects to occur.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ). 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.
The baseline risk assessment evaluated several different
categories of people who could potentially be affected by the
contamination at the site. These included adults working on the
site, children playing on the site, and those using the Grand
River for recreational purposes.
The category of children playing on the site had the highest
estimated health risk from non-carcinogenic (not cancer
producing) substances. This health risk was from contact,
ingestion and inhalation of site soils. The non-carcinogenic
hazard index for this category is estimated at 13. The u.s. EPA
considers a hazardous index of 1 as a level of acceptable risk.
A hazard index above 1 could possibly result in an unacceptable
risk to human health. Therefore, a hazard index of 13 indicates
that there is an increased chance of adverse health effects posed
by the site to children who play on the site.
For risks of cancer, the baseline risk assessment estimated the
excess lifetime cancer risk posed to an adult, working on the
site and drinking contaminated ground water to be 3.0X10.'. Put
another way, if the site was not cleaned up and 10,000 adults
were exposed to contaminants from the site over their lifetimes,
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3 individuals might develop cancer under the conditions of the
exposure assessment. .
It is important to note that this health risk estimate was based
on the assumption that individuals would be working full time on
the site. Under this scenario, workers would be exposed to site
cont~minants via dermal contact, soil ingestion, particle
inhalation, and by drinking water from a well placed ~nto the
contaminated aquifer. . Presently, residences near the site use
the city's water supply, which comes from Lake Michigan, and not
from the ground water contaminated by this site.
Actual or threatened releases of hazardous substances from this
site, if not addressed by the preferred alternative or one of the
other active measures considered, may present an imminent and
substantial endangerment to public health, welfare, or the
environment. .
DESCRIPTION OP ALTERNATIVES
The alternatives analyzed for the site are presented below.
Detailed information on each of the alternatives is available in
the Feasibility study (FS) Report. After consideration of all
alternatives presented in the FS, the U.s. EPA has shortened the
list of alternatives to four alternatives. This short list was
chosen because it represents the full spectrum of alternatives
presented in the FS without the redundancy of the matrix
established in that document.
The four alternatives evaluated for this site are as follows:
- Alternative 1: No action. Under this alternative, no remedial
action would be taken; the site would remain in its present
condition. .
- Alternative 2: Access restrictions, site monitoring, cap
improvements, installation of additional on-site and off-site
monitoring wells, establishment of Alternate Concentration
Limits. . .
- Alternative 3: Access restrictions, site monitoring, cap
improvements, up-gradient slurry wall.
- Alternative 4: Access restrictions, site monitoring, cap
improvements, down-gradient slurry wall, on-site ground-water
extraction wells, discharge of contaminated ground water to
either a publicly owned treatment works or on-site treatment and
discharge to the Grand River.
COMMON ELEMENTS. Except for the "no action" alternative, all of
the alternatives now being considered for the site include a
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11
number of common elements. These elements are access
restrictions, measures to mitigate the impact of flooding of the
Grand River, mitigation of any impacted wetlands, surface
controls, drum disposal contingency plan and long-term
monitoring. The access restrictions include maintaining the
current site fence, establishing'deed restrictions to restrict
excavation and construction at the site and to restrict the use
of ground water. The drum disposal contingency plan will address
removal of any drums containing hazardous waste identified during
the remedial action.
ALTElUIATXVB 1:
NO ACTION.
ESTIMATED CAPITAL COST: $0
ESTIMATED ANNUAL OPERATION AND MAINTENANCE
ESTIMATED PRESENT'NET WORTH: $0
YEARS TO IMPLEMENT ACTION: 0
(O&M) COST:
$0
The NCP (the Superfund implementation rule) require the u.S. EPA
to consider a "no action" alternative for every Superfund site.
Under this alternative, u.S. EPA ,would take no further action at
the site to protect human health and the environment.
ALTElUfATXVB 2:
SOIL CAP UIICBIGD ACT 641 CAP) WITH ESTABLISJIIID'r OP ALTBRDTB
CORCJD1TRATIOR LIXITS IACLs) FOR GROmm WATER.
ESTIMATED CAPITAL COST: $13,530,000
ESTIMATED ANNUAL OPERATION AND MAINTENANCE (O&M) COST: $110,000
ESTIMATED PRESENT NET WORTH: $15,230,000
YEARS TO IMPLEMENT ACTION: 3-7
This alternative calls for improving the landfill cover to meet
Michigan Act 641 ~equirements for solid waste landfill covers.
The requirements for Michigan Act 641 landfill covers consist of
a minimum of 2 feet of compacted clay with a cap slope not to
exceed 1 foot vertical to 4 feet horizontal nor less that 2'. To
establish a more permanent cap as well as reduce long-term
operation and maintenance cost, a frost-protection or freeze-thaw
layer will be incorporated into the Michigan Act 641 cap
requirements.
currently, all information indicates that ground water in the
shallow aquifer under the site is discharging into the Grand
River, which is the physical and hydrogeologic boundary for the
site. The discharging ground water has no detectable impact on
the river. Since fill material extends into the shallow aquifer
under the landfill, it is not practicable to remove all fill
material in order to restore the shallow aquifer to beneficial
use. Further, it is not practicable to install active ground
water remediation because the result would be to effectively draw
water from the river into the site. For these reasons, ACLs,
which are site specific chemical concentrations for ground water
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at a site, would be established. ACLs are established by
developing baseline ground-water quality levels for the shallow
aquifer at the site and then employing a statistical analytical
method to determine what level of contamination would cause a
statistically significant impact to the Grand River. If future
sampling confirms a statistically significant increase in the
concentrations of the compounds of interest, U.S. EPA would then
make a decision regarding the need to implement a subsequent
remedial action.
Additional monitoring wells would be installed on both sides of
the Grand River to insure that all ground water continues to
discharge to the river and that concentrations of contaminants in
the ground water do not increase and exceed ACLs. A monitoring
program of Grand River water and sediments will be instituted to
ensure that there is no future impact from the site on the Grand
River. If a significant impact from site contaminants is
detected in either river water or sediments, then an additional
action will be undertaken to mitigate any impact.
ALTERNATIVE 3:
LOW PBRHBABILITY CAP (MICHIGAN ACT 64 CAP) WITH CONSTRUCTION 01' AN
UPGRADIBNT VERTICAL BARRIER FOR GROUND WATER.
ESTIMATED CAPITAL COST: $24,880,000
ESTIMATED ANNUAL OPERATION AND MAINTENANCE (O&M) COST: $110,000
ESTIMATED PRESENT NET WORTH: $26,540,000
YEARS TO IMPLEMENT ACTION: 3-7
The provisions of this alternative include improving the landfill
cover to meet Michigan Act 64 requirements for hazardous waste
landfill covers and installing an upgradient ground-water barrier.
In contrast to the Michigan Act 641 cap, the requirements for a
Michigan Act 64 landfill cover consist of a vegetated soil layer at
least 1 foot thick, a drainage layer at least 1 foot thick, and 3
feet of compacted clay with permeability of less than or equal to
1X10-7 em/sec. An in-ground barrier, such as a slurry wall, would
be constructed on the northern, western and eastern boundaries of
the site to minimize the migration on-site of ground water in the
shallow aquifer and thereby into the Grand River. The barrier
would be constructed so that it would extend down the entire depth
of the aquifer to ensure that ground water could not bypass the
barrier. .
ALTERNATIVE 4: .
LOW PERMEABILITY CAP (MICHIGAN ACT 64 CAP) WITH CONSTRUCTION OF A
DOWNGRADIENT VERTICAL BARRIER AND GROUND-WATER EXTRACTION.
ESTIMATED CAPITAL COST: $27,970,000
ESTIMATED ANNUAL OPERATION AND MAINTENANCE (O&M) COST: $140,000
ESTIMATED PRESENT NET WORTH: $30,150,000
YEARS TO IMPLEMENT ACTION: 3-7
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This alternative provides for improving the landfill cover to
meet Michigan Act 64 requirements for landfill covers, install a
downgradient ground-water barrier, and extract ground water for
treatment. An in-ground barrier would be constructed on the
southern side of the landfill to isolate the site ground water
from the Grand River. Extraction wells would be installed in the
fill material near the in-ground barrier to maintain a balance
between the hydraulic pressure from the ground water and that
exerted by the river.. Contaminated ground water collected by
this system would either be discharged to the City of Grand
Rapids publicly owned treatment works (POTW) for treatment off-
site or extensively treated on-site prior to discharge to the
Grand River. The ground-water extraction system would be
required to operate in perpetuity.
COMPARATXVE ANALYSXS OP ALTERHATXVES:
THE NXNE CRXTERXA
In accordance with the NCP, the relative performance of each.
alternative is evaluated using the nine criteria, 40 CFR section
300.430 (e) (9) (iii), as a basis for comparison. An alternative
providing the "best balance" of trade-offs with respect to the
nine criteria is determined from this evaluation.
The following two threshold criteria; overall protection of human
health and the environment, and compliance with applicable or
relevant and appropriate requirements, are criteria that must be
met in order for an alternative to be selected.
1.
OVerall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses
whether a remedy eliminates, reduces, or controls threats to
human health and to the environment.
The major exposure pathways of concern at the Butterworth
Landfill site are the potential for inhalation, ingestion and.
dermal contact with contaminated site soils. Based upon these
pathways of concern, the alternatives were evaluated on their
ability to reduce exposure to those soils.
Alternative 1 does not provide any reduction in the risk to human
heal th and the environment. For this reason, Al ternati ve. 1 is
eliminated from further evaluation as an acceptable alternative
to remediate this site.
Alternatives 2,3 and 4 are protective of human health and the
environment because these alternatives eliminated the major
exposure pathway by preventing contact with site soils through
construction of a landfill cover.
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2.
compliance with Ap~licable or aelevant and Appropriate
Requirements .
This criterion evaluates whether a remedy meets
relevant and appropriate requirements set forth
state environmental laws pertaining to the site
actions or if a waiver is justified. ARARs are
detail in statutorv Determinations.
applicable or
in Federal and
or proposed
discussed in more
All of the alternatives, except for the no action alternative,
will comply with Federal and state ARARs. The major ARARs that
will be complied with include: RCRA and Michigan Hazardous Waste
Management Act (Act 64), which address the handling of hazardous
materials (including requirements for incineration,
transportation, land disposal restrictions, and minimum
technology requirements for landfills, and hazardous waste
landfill covers); the Clean Air Act and Michigan's Air Pollution
Control Act (Act 348), which address air emissions from the.
excavation; Michigan Water Resources Commission Act (Act 245),
which addresses ground water quality; and Michigan Environmental
Response Act (Act 307), which addresses cleanup type; Federal
Safe Drinking Water and state Safe Drinking Water Act (Act 399);
and landfill closure ARAR Michigan Act 641.
Alternative 2 requires that ACLs be established for contaminated
ground-water pursuant to CERCLA section 121(d) (2) (B) (ii). . This
replaces the water quality standards set forth in Act 307 and Act
245.
3.
Long-Term Bffectiveness and Permanence
This criteria refers to the ability Qf an alternative to maintain
reliable protection of human health and the environment over time
(lower residual risk) once the clean-up goals have been met.
Alternatives 2, 3 and 4 provide long-term effectiveness by
containing the landfilled waste on-site through engineering
controls. Long-term maintenance of the landfill cover will be
required to insure the continued future performance of the cover.
Alternative 2, 3 and 4 reduce infiltration of precipitation into
the landfill mass through construction of the landfill cover and
thereby reduce the production of leachate. In addition,
Alternative 3 further minimizes, but does not eliminate, the
production of leachate by reducing the amount of ground water
entering the site through construction of an upgradient vertical
barrier. Alternative 4 significantly reduces the production of
leachate by decreasing the amount of ground water entering the
site through construction of both upgradient and downgradient
vertical barriers and through collection of any leachate formed.
This alternative involves continual extraction of leachate and
ground water to prohibit the production of leachate.
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4.
Reduction of Toxicity, Mobility, or Volume Through Treatment
This criterion evaluates treatment technology performance in the
reduction of chemical toxicity, mobility, or volume. This
criteria addresses the statutory preference for selecting
remedial actions which include, as a principal element, treatment
that permanently and significantly reduce the volume, toxicity,
or mobility of the hazardous substances, pollutants, and
contaminants.
This criteria and the statutory preference are not met for any of
the alternatives since none of the alternatives involve treatment
as a principal element.
5.
Short-Term Effectiveness
Short-term effectiveness considers the time to reach clean-up
objectives and the risks an alternative may pose to site workers,
the community, and the environment during remedy implementation
untii clean-up goals are achieved.
Alternatives 2, 3, and 4 involve containment of the landfilled
waste on-site and are expected to require approximately the same
length of time to implement. Community and worker health can be
protected during improvement of the landfill cap through safety
control measures including dust suppression.
Alternatives 3 and 4 would require trenching to install the
vertical barriers. Community and worker health would be more
difficult to protect due to the activity of excavating the
landfilled waste from the trenches. uncovering waste would
increase the potential for exposure to hazardous constituents by
direct contact and inhalation.
6.
Implementability
This criterion considers the technical and administrative
feasibility of implementing an alternative.
Alternatives 2, 3 and 4 will involve an increase in traffic
through the local communities. Measures will be evaluated during
design to insure that the increase in traffic due to construction
activities will have minimal impact on residents and the local
community. .
No significant implementation problems are projected for the
capping components of Alternatives 2, 3 and 4. Cap materials are
expected to be obtainable from nearby sources. The engineering
expertise and construction practices and equipment for
installation, operation and maintenance of this component of
these alternatives' are available and proven. Some special
consideration for both the radio towers and high-tension towers
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16
located on the site will be ~equired during design and.
construction. Access to areas outside of the Butterworth
Landfill property is necessary for Alternative 2 for installation
of the ground-water monitoring system including the construction
of the additional monitoring wells. Although, .statutory
authority provides u.s. EPA the legal. right access those areas,
the potential exists that acquiring access might cause a delay.
Installation of the downgradient vertical barrier in Alternative
4 will be difficult due to the proximity of the fill material to
.the river as well as the fact that the river. will place
substantial hydraulic pressure on the barrier. Alternative 4'
also requires treatment of the extracted ground water through use
of the local POTW. Potential problems exist in'Alternative 4 due
to the questionable ability. of the Grand Rapids POTW to treat the
contaminated ground water, development of an appropriate
pretreatment system to allow discharge to the POTW, or in design
and construction of an on-site ground-water. treatment facility.
'n
7.
Cost
This criterion compares the capital, operation and maintenance,
and present worth costs of implementing the alternatives at the
site. .'
The costs for each alternative are as follows:
ALTERNATIVE CAPITAL COST ANNUAL O&M COST' PRESENT NET
WORTH
1 $0 $0 $0
2 $13,530,000 $110,000 $15,230,000
3 $24,880,000 $110,000 $26,540,000
4 $27,970,000 $140,000 $30,150,000
Present Net Worth calculated for 30 years at 5%. Calculation of
Present Net Worth is an estimate of the value of money used to
pay future costs in "today's" dollars. The calculation is. based
on the assumption that an existing dollar will earn interest and
therefore has a greater value than a future dollar.
8.
state Acceptance
The State of Michigan has assisted in the development and review
of the Administrative Record. However, the State of Michigan has
indicated that it does not agree with the use of ACLs at this
site and, therefore, does not concur with the selected
alternative.
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9.
community Acceptance
Based on the comments received by the u.s. EPA, the selected
alternative appears to be acceptable to the community. community
concerns are addressed in the attached Responsiveness Summary.
SELECTED REMEDY
Based upon considerations of the requirements of CERCLA and the
NCP, balancing of the nine criteria, and public comment, the u.S.
EPA has determined that Alternative 2 is the most appropriate
remedy for the Butterworth Landfill site.
The components of the selected remedy are as follows:
1.
Institutional Controls:
Institutional controls may include, as necessary,
restrictions to control future development of the
landfill area and to prohibit the installation of .
ground-water drinking water supplies at the Butterworth
Landfill property and an isolation zone consisting of
land within the area between the Butterworth Landfill
property and 1000 feet to the north, east, south and
west of the lateral extent of the landfilled waste as
defined in the Remedial Investigation Report.
Restrictions regarding the installation of ground-water
drinking water wells outside of the point of compliance
(the landfill boundary), within the isolation zone
noted above, may be lifted as to individual locations
if u.s. EPA determines that: contaminant levels within
ground water have fallen and. will remain below MCLs or
MCLGs for contaminants detected at the site.
2.
Additional Monitoring Well Installation:
Additional monitoring wells in the upper and lower
aquifers shall be installed to provide data on these
aquifers. The number of wells installed shall be, at a
minimum, 17 wells in the upper aquifer generally
located between the fill material and the Grand River.
The location of the wells shall be determined by use of
a statistically stratified plan. The plan shall
consist of dividing the approximately 4250 foot
landfill/river front boundary into 17 equal partitions
approximately 50 feet by 250 feet in size. One well
shall be located within each partition. To induce a
statistical randomness into the design location for
each well, each partition shall be subdivided and
numbered. A random number table shall be employed to
select the numbered subdivision in which the well shall
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be placed. The random numbe~ chosen for each partition
shall be recalculated using the random number table.
The data from sampling of these wells shall be used to
help institute the statistical data needed to establish
the Alternate Concentration Limits. The number and
location of these wells shall be specified in the
Remedial Design.
Additional monitoring wells shall be installed in the
upper and lower aquifers on the opposite side of the
Grand River from the landfill. These wells shall be
used to verify that the Grand River continues to
function as a hydrogeologic boundary. The number and
location of these wells shall be specified in the
Remedial Design.
3.
Sampling and analysis of these additional monitoring
wells shall be' incorporated into the final ground-water
monitoring program, as appropriate. The installation
of these wells shall be completed during the Remedial
Design. .
Installation and Implementation of Ground-water
Monitoring Program:
A ground-water monitoring program shall be implemented.
This program will be identified in the Remedial Design.
The ground-water monitoring program shall be designed
to detect contaminants, changes in contaminant
characteristics and increases/decreases in the
concentration of hazardous substances, pollutants and
contaminants in the upper and lower aquifers at and
near the site. .
Ground-water monitoring shall include collection and
field and laboratory analysis of samples from selected
monitoring wells. At a minimum, field analysis shall
include ground-water elevation, pH, temperature,
specific conductivity, and redox potential. Laboratory
analysis performed shall include organic. compounds and
inorganic analytes from u.s. EPA's Target Compound List
(see Table 1) on an annual basis for at least the first
2 years (2 annual samplings and analyses). At the end
of the initial 2 year monitoring period, u.S. EPA may
re-evaluate the frequency of monitoring and the number
of analytes and compounds that shall be analyzed for in
ground water.
The ground-water monitoring program shall continue
until at least 30 years after the completion of
construction at the site. At the end of 30 years, U.S.
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19
EPA will determine the need to extend the period of
monitoring.
If, at any time, additional information indicates that
the ground-water monitoring program should be changed,
u.s. EPA may require modifications to the program.
Modifications may include, but are not limited to, a
change in the number and selection of ground-water
monitoring wells to be sampled, installation of
additional ground-water monitoring wells, the selected
laboratory analysis parameters, and/or the compounds
and analytes which shall be monitored for in ground'
water. '
4.
surface-Water/sediment/Biological Monitoring:
A surface-water/sediment/biological monitoring program
shall be implemented and shall be identified in the
Remedial Design. streams, intermittent streams,
combined sewer overflow, and the Grand River waters and
sediment as well as selected fish and benthic lifeforms
shall be sampled and analyzed quarterly for the first
two years and annually thereafter. The surface-
water/sediment/biological sampling points and analytes
shall be specified in the Remedial Design.
The surface-water/sediment/biological monitoring
program shall continue until at least 30 years after
the completion of construction at the site. At the end
of 30 years, U.S. EPA will determine the need to extend
the period of monitoring.
If, at any time, additional information indicates that
the surface-water/sediment/biological monitoring
program should be changed, u.s. EPA may require
modifications to the program. Modifications may
include, but are not limited to, additional surface-
water/sediment/biological monitoring points, a change
in the frequency of monitoring, and/or analysis of
additional parameters.
5.
Establish Alternate Concentration Limits
ACLs shall be established for site ground water and be
based on the current level of contamination. To
quantify the current contamination levels, baseline
ground-water quality levels shall be established.
These levels shall be determined through sampling of
compliance monitoring wells for 8 consecutive quarters
over a 2 year period. The indicator parameters to be
analyzed quarterly shall include, but are not
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necessarily limited to, all ch~micals established as
chemicals of concern in ground water at the site (see
Table 2). The frequency, timing, and protocol shall be
developed in the RemediaL Design with the objective of
gathering representative data of ground-water quality
and its variation over a 2 year period. A statistical
test which accounts for the variation of the data shall
be employed to measure compliance, and shall be
equivalent to or the same as the "Cochran's
Approximation to the Behrens-Fisher Student's t-test"
provided in 40 CFR Part 264 Subpart F,Appendix IV.
The monitoring wells used to determine and subsequently
verify ground-water quality shall be located
downgradient between the landfill mass and the river to
which the plume discharges. The number of monitoring
wells designated for sampling as well as the frequency
of sampling and the parameters sampled shall be
determined in the Remedial Design. Monitoring wells to
be sampled shall include existing ground-water
monitoring wells and additional ground-water monitoring
wells determined and specified by u.S. EPA.
After the initial 2 year period of quarterly samplinq
used to develop the baseline ground-water quality
statistic, ground water shall be monitored for the next
3 years on a quarterly basis. At a minimum, Analysis
shall be made for" the primary contaminants of concern.
At the end of this 3 year period, U.S. EPA may re-
evaluate the frequency of monitorinq and number of
compounds and analytes that shall be analyzed for in
ground water. At a minimum, ground water shall
continue to be monitored on an annual basis.
For subsequent monitoring events, a new statistic shall
be developed and compared to the baseline water quality
statistic derived during the first 8 quarters of
monitoring. If the new statistic exceeds the baseline
statistic at the 95% confidence limit there is high
probability that a statistically significant increase
of a parameter(s) has occurred. ~he statistic may
apply to each compound in Table 2 or to the sum of the
compounds or to both. At the end of the 3 years of
compliance monitoring, u.s. EPA may re-evaluate the
frequency of monitoring and the number of compounds and"
analytes that shall be analyzed for in ground water.
" At a minimum, ground water shall continue to be
monitored on an annual basis.
If U.S. EPA should determine that it is appropriate to
reduce the frequency of ground-water monitoring events
and during a subsequent monitoring event an ACL is
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21
exceeded at the 95% confidence level at anyone of the
compliance points defined in the Remedial Design,
quarterly monitoring shall be reinstated and be
conducted, at a minimum, over a 1 year period to
confirm or reject the initial results. If an ACL is
exceeded at the 95% confidence level for 2 consecutive
quarters, then the Remedial Action Plan (RAP) shall be
implemented to address the ACL exceedance. The RAP
shall be developed as part of the Remedial Design and
shall consist of pre-determined response actions to
address ACL exceedances. The RAP shall be designed, to
mitigate an impact on the Grand River or a threat to
human health and the environment. Examples of
potential engineering response actions Include, but are
not limited to, identification and removal of a source
hot spot, installation of slurry walls to reduce or
eliminated interaction between the ground water and the
river, and/or installation of a ground-water extraction
system. .
6.
Landfill Cover
New landfill covers shall be installed, or the existing
landfill covers shall be repaired/retrofited to meet
the requirements of Solid Waste Management Act 641
(1978), as amended, Michigan Code of Laws (MCL)
Sections 299.401 through 299.436. The landfill caps
shall cover all landfilled waste at the site.
The landfill cap shall include, but not be limited to:
* GAS VENTING AND ~REATMENT SYSTEM: the cap
shall have a final cover system capable of
allowing removal and treatment (if needed) of
generated gas from within the landfill.
* CLAY CAPPING LAYER: a minimum 2 foot thick
clay cap shall be designed to provide a low
hydraulic conductivity barrier to percolation.
The specific specifications of the clay capping
layer are listed within MDNR Act 641.
* FREEZE-THAW LAYER: a cover layer that
provides additional rooting depth for vegetation
and protects the clay capping layer from damage
due to freeze-thaw and desiccation. .
* TOPSOIL: a minimum of 6 inches of topsoil
shall be designed over the cover layer to support
the proposed vegetation.
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* REVEGETATION: Seed and fertilizer shall be
applied to the topsoil layer to establish a
vegetation cover. The seed type and amount of
fertilizer applied shall be proposed in the Desiqn
and Specifications Plan and will depend on the
type and quality of topsoil and compatibility with
both native vegetation and the final site use.
* SLOPE: The slope of the final cover shall
not exceed 1 vertical to 4 horizontal and shall
not be less than 1 vertical to 50 horizontal.
* FLOOD PREVENTION: Appropriate measures as
defined in the Remedial Design shall be undertaken
to mitigate any impact, or potential impact, from
flooding of the Grand River.
Adequate noise and dust suppressant measures shall be .
taken to protect the community from the effects of
construction. Earthen berms and/or plant materials
(i.e., trees or shrubs) shall be placed around the
landfill area perimeters to control dust and noise
impacts. Adequate measures shall be employed to
protect surface waters from siltation during
construction and post-closure.
7.
Mitigation of Wetlands
Any wetlands impacted by activities conducted as a
result of this remedial action 'shall be mitigated as
deemed appropriate by U.S. EPA.
8.
Drum Removal and Disposal
Drums, either currently exposed or uncovered during
activities conducted as part of the Remedial Action,
which are determined to contain hazardous material,
substances, or waste in any amount which would
constitute a release or spill of such hazardous
material, substance, or waste, shall be removed and
disposed of in accordance with all applicable or
relevant and appropriate regulations for the material.
Based on information obtained during the RI and FS, U.S. EPA .
believes that the selected remedy will meet these goals.
Mitigative measures will be taken during remedy construction
activities to minimize the impacts of noise, dust and erosion
run-off to the surrounding community and environs. Fugitive dust
emissions shall not violate the National Ambient Air Quality
Standard for particulate matter smaller that 10 microns (PM-10).
Potential runoff, silting and sedimentation problems from
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23
construction. shall be mitigated to comply with HI Acts including,
but not limited to, public Acts 203 (1979), 346 (1972) and 347
(1972) for wetland protection, inland lakes and streams, and soil
erosion and sedimentation control, respectively.
The landfilled waste will continue to be contained on-site. Since
this landfilled waste is the source of the contaminants,
hazardous constituents will therefore remain at the site. A
review of site conditions, the remedy's progress toward
achievement of remediation standards and the availability of new
emerging technologies which could further reduce the toxicity,
mobility or volume of hazardous constituents remaining at the
landfill shall, at a minimum, be reviewed every 5 years after the
. initiation of the remedial action.
STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of section 121 .
a through f of CERCLA to:
5.
Protect human health and the environment;
comply with ARARs or Justify a Waiver;
Be cost effective;
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable; and
satisfy a preference for treatment that reduces
toxicity, mobility, or volume as a principal element of
the remedy.
1.
2.
3.
4.
The implementation of the selected alternative at the Butterworth
Landfill site satisfies these requirements of CERCLA section 121
as follows:
1.
Protection of Human Health and the Environment.
Implementation of the selected alternative will reduce and
control potential risks to human health posed by exposure to
contaminated site soils. Capping the landfill, in addition to
reducing any potential further risk posed by exposure to landfill
contaminants, will reduce precipitation infiltration through the
cap and maintain that reduction over time. Improvement of the
cap will reduce ground-water contaminant loading to the aquifer.
No unacceptable short-term risks will be caused by implementation
of the remedy. The community and site workers may be .exposed to
noise and dust nuisances during construction of the cap. As
above, mitigative measures will be taken during remedy
construction activities to minimize impacts of construction upon
the surrounding community and environs. '
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24
2. ComDliance with ARARs
The selected remedy.will comply with the Federal and/or state,
where more stringent, applicable or relevant and appropriate
requirements (ARARs) listed below:
a.
Chemical-sDecific ARARs
Chemical-specific ARARs regulate the release to the
environment of specific substances having certain chemical
characteristics. Chemical-specific ARARs typically
determine the extent of clean-up at a site.
Federal ARARs
Maximum contaminant Levels (MCLs) and to a certain
extent non-zero Maximum Contaminant Level Goals
(MCLGs), the Federal drinking-water standards
promulgated under the Safe Drinking Water Act (SDWA), .
are applicable to municipal water supplies servicing 25
or more people. At the Butterworth Landfill Site, MCLs
and MCLGs are not applicable, but are relevant and
appropriate since the aquifer in the area of
contamination is suitable for use as a source of
drinking water in the future. MCLGs are relevant and
appropriate when the standard is set at a level greater
than zero (for non-carcinogens), otherwise, MCLs are
relevant and appropriate. CERCLA section
121(d) (2) (B) (ii) provides for the establishment of ACLs
under limited circumstances. Those circumstances are
present at this site. Pursuant to CERCLA Section
121(d) (2) (B) (ii) ACLs may not be used except where (I)
there are known and projected points of entry of such
ground water into surface water; (II) ... there is or
will be no statistically significant increase of such
constituents from such ground water in such surface
water at the point of entry...; and (III) the remedial
action includes enforceable action which will preclude
human exposure ...
ACLs are also discussed in the Preamble to the NCP (55
FR 8754), which states that "ACLs may be used if the
conditions of CERCLA S 121(d) (2) (B) (ii) are met and
cleanup to MCLs or other Drotective levels is not
Dracticable (emphasis added). If these statutory
criteria for ACLs, including a finding that active
restoration of the ground water to MCLs or non-zero
MCLGs is deemed not to be practicable, documentation of
these conditions for the ACL is sufficient and
additional documentation of a waiver of the MCL or MCLG
is not necessary."
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25
The decision~o implement ACLs must be based on whether
the site fulfills the three requirements specified in
SARA. This meets those requirements. The ground water
discharges into the Grand River (requirement I), there
is no statistically significant impact on river quality
that can be attributed to the site (requirement II),
and the fill material extends to the edge of the Grand
River, therefore precluding human exposure.
(requirement III). The risk associated with ground
water does not exceed the acceptable risk range
established in the NCP and the fill material extends
into the aquifer throughout the site. . Additionally,
the depth of fill material in combination wi-th the
proximity of the fill to the river, makes remediation
of the aquifer to MCLs impracticable.
State ARARs
The substantive provision of Michigan Act 307 and the
Part 22 rules of Act 245 are ARARs at the Butterworth
Landfill Site. However, as explained above, with
respect to ground water, the establishment of ACLs
pursuant t~ CERCLA Section l2l(d) (2) (B) (ii) replaces
the State ground-water quality standards. In any
event, the remedies described in Alternatives 3 and 4
are impracticable due to the presence of fill material
in the shallow aquifer and extending into the Grand
River. These facts make the attainment of MCLs, or
more stringent state ground-water quality standards
impracticable.
b.
Location-specific ARARs
Location-specific ARARs are those requirements. that relate
to the geographical position of a site. These include:
Federal ARARs
Executive Order 11988 - Protection of Flood Plains -
are relevant and appropriate for this site. The
landfill is currently within the 100-year floodplain of
the Grand River. Any portion of the remedy that is
constructed within the 100-year flood plain must be
adequately protected against a 100-year flood event
(e.g., geotextiles should be used to secure topsoil,
etc.)
Section 404 of the Clean Water Act regulates the
discharge of dredged or fill material to waters of the
United States. Activities during the remedy may be
regulated under section 404 of the CWA; therefore, the
substantive requirements of section 404 would be
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26
relevant and appropriate to the remedial action at the
site.
Executive Order 11990 - Protection of Wetlands - is an
applicable requirement to protect against the loss or
degradation of wetlands. The site does contain
wetlands. Remedy activities may pose a threat to these
wetlands. The scope of the impact has not yet been
determined. Mitigative efforts will be applied to the
clean-up based on the impact on the wetlands.
state ARARs
The substantive provision of the Goemaere-Anderson
Wetland Protection Act 203 of 1979 (Act 203) regulates
any activity which may take place within wetlands in
the state of Michigan. Act 203 is relevant and
appropriate to the remedial action at the Butterworth
Landfill site.
The substantive provision of the Inland Lakes and
streams Act 346 of 1972, as amended, regulates inland
lakes and streams in the state. Act 346 would be
applicable to any dredging or filling activity on Grand
River bottomlands.
The substantive provision of the Soil Erosion:and
Sedimentation Control Act 347 of 1972 regulates earth
changes, including cut and fill activities, which may
contribute to soil erosion and sedimentation of surface
waters of the state. Act 347 would apply to any such
activity where more than 1 acre of land is affected or
the regulated action occurs within 500 feet of a lake
or stream. Act 347 would be applicable to the cap and
ground-water monitoring system construction activities
since these actions could impact the Grand River, which
is less than 500 feet from the landfill area.
c.
Action-sDecific ARARs
Action-specific ARARs are requirements that define
acceptable treatment and disposal procedures for hazardous
substances.
Federal ARARs
For landfill closure, RCRA Subtitle C requirements are
not applicable since the hazardous substances of
concern were disposed of prior to November 1980. since
fill material extends in the ground water beneath the
site, the effectiveness of an impermeable hazardous
waste cap would be diminished. Therefore, while
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27
subtitle C is relevant, it is not appropriate for
technical (effectiveness) reasons due to the
circumstances of this site.
RCRA Land Disposal Restrictions (LOR or Land Ban) would
not be applicable since no "placement" of RCRA
hazardous waste would be occurring at this site.
RCRA subtitle C requirements, including LOR, would be
relevant and appropriate if wastes were to be excavated
and managed and these wastes were determined to be
characteristic RCRA subtitle C hazardous wastes.
The only foreseeable manner in which the selected
remedy may store or dispose of hazardous waste is when
or if drums located during the closure operations
contain RCRA hazardous wastes. The RCRA waste
generation and temporary storage regulations under 40
CFR Part 262 would then be applicable to the storage of
those drums prior to 'off-site disposal.
state ARARs
The state of Michigan administers RCRA within the
state. Under Hazardous Waste Management Act 64 of
1979, as amended, the state regulates. the generation,
transport, treatment, storage, and disposal of
hazardous waste. Act 64 also regulates the closure,
and the postclosure care, of hazardous waste disposal
facilities in the state. As with RCRA subtitle C,
above, Act 64 is not applicable or relevant and
appropriate to closure of the landfill. Act 64 would
be applicable to the treatment or storage of hazardous
landfill contents such as drums.
The substantive provision of the Michigan Solid Waste
Management Act (Act 641) is applicable or relevant and
appropriate for closure of the landfill. The landfill
cover design required by regulation promulgated under
this state statute provides adequate protection from
direct contact with the landfilled waste and minimizes
leachate produced by the site~
The State of Michigan has identified the Michigan
Environmental Response Act (referred to as Act 307) and
its implementing rules as ARARs for this site. u.s.
EPA finds that only Rules 705(2) and (3), 707 - 715,
717(2), 719(1) and 723 qualify as ARARs in compliance
with Section 121(d) (2) of CERCLA. These rules provide
for the selection of a remedy which attains a degree of
cleanup which conforms to one or more of three levels
of cleanup - Type A, B, or C. A Type A cleanup
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28
generally achieves cleanup to background or non~
detectable levels (R299.5707); a Type B cleanup meets
specified cleanup levels in all media (R299.5709 - 5715
and 5723) and a Type C cleanup is based on a site
specific risk assessment [R299.5717(2) and 5719(1)].
U.S. EPA does not consider the other provisions of Act
307 and its implementing rules identified by the State
as ARARS because they are either procedural, not more
stringent or do not establish cleanup standards.
Additionally, U.S. EPA believes that even if certain of
these provisions were considered as ARARs, the remedial
actions and cleanup standards selected for this site
are in compliance with these State identified ARARs
since they have been selected in accordance with CERCLA
and the NCP.
The selection of a cap for containment of contaminated
soils along with establishment of ACLs for site ground
water is in accordance with a site specific risk
assessment conducted for the site which meets the
requirements of CERCLA and the NCP and therefore, a
Type C cleanup, as allowed by R299.5703(2) and (3),
5717(2) and 5719(1).
3.
Cost-effectiveness
Cost-effectiveness compares the effectiveness of an alternative
in proportion to its cost of providing its environmental
benefits. The table under Part 7 of the section entitled
comparative Analysis of Alternatives lists the costs associated
with the implementation of the alternatives.
Alternative 1 is the least expensive alternative; however, it
does not provide adequate protection of human health and the
environment, does not meet ARARS, and does not provide
effectiveness over the long term.
Alternative 2 (the selected alternative) is considered cost-
effective. The greatest threat to human health and the
environment is through contact, inhalation or ingestion of site
soils which will be controlled through installation of a solid
waste landfill cover. The risk associated with site ground water
is within u.S. EPA's accepted risk range and currently does not
pose a threat to the Grand River. Establishment of ACLs with
continued long-term monitoring will insure continued lack of
degradation of the Grand River~
Alternatives 3 and 4 are more expensive than Alternative 2, do
not provide any additional reduction in site risks and are
therefore not considered to be cost-effective for this site.
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29
4.
utilization of Permanent Solutions and Alternative Treatment
Technoloaies or Resource Recoverv Technoloaies to the
Maximum Extent Practicable
The selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in
a cost-effective manner for this site. Of those alternatives
that are protective of human health and the environment and
comply with ARARs, the 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, and considering state and
community acceptance.
5.
Preference for Treatment as a PrinciDal Element
The statutory preference for treatment as a principal element of
a remedy is not satisfied by the selected alternative.
Due to the large volume of landfilled waste that would need to be
treated, treatment of this low level threat waste is considered
impracticable. Instead, the remedy employs engineering controls
which will be protective of human health and the environment to
address the low level threat posed by the landfilled waste.
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TABLE 1
U.S. EPA.TARGET COMPOUND LIST
Chloromethane
vinyl chloride
Methylene chloride
Carbon Disulfide
1,2-Dichloroethane
Chloroform
2-Butanone .
Carbon tetrachloride
Bromodichloromethane .
cis-1,3-Dichloropropene
bis{2-Chloroethyl) ether
1,3-Dichlorobenzene
Benzyl alcohol
2-Methylphenol
bis{2-Chloroisopropyl) ether
Dibromochloromethane
Benzene
trans-1,3-D~chloropropene
2-Hexanone
Toluene
1,1,2,2-Tetrachloroethane
Styrene
N-Nitrosodi-n-propylamine
Ni trobEimzene
2-Nitrophenol
Benzoic acid
bis{2-Chloroethoxy) methane
1, 2, 4-Trichlorobenzene
Hexachlorobutadiene
2-Methylnaphthalene
Hexachlorocyclopentadiene
2,4,6-Trichlorophenol
2,4,5-Trichlorophenol
2,4-Dinitrotoluene
Acenaphthene
Dibenzofuran
Diethylphthalate
4-Chlorophenylphenyl ether
4-6-Dinitro-2-methylphenol
beta-BHC
Heptachlor epoxide
Dieldrin
Endrin
4,4'-DDD .
4,4'-DDT
Endrin ketone
gamma-Chlordane
Arochlor-1016
Arochlor-1232
Arochlor-1248
Arochlor-1260
74873
75014
75092
75150
75343
67663
78933
56235
75274
10061015
111444
541731
100516
95487
108601
124481
71432
10061026
591786
108883
79345
100425
621647
98953
88755
65850
111914
120821
87683
91576
77474
88062
95954
606202
51285
132649
84662
7005723
534521
319857
1024573
60571
72208
72548
50293
53494705
5103742
12674112
11141165
12672296
11096825
Bromomethane
Chloroethane
Acetone
1,1-Dichloroethene
1,2-Dichloroethene
1,2-Dichloroethane
1, 1, 1-Trichloroethane
vinyl acetate
1,2-Dichloropropane
Phenol
2-Chlorophenol
1,4-Dichlorobenzene
1,2-Dichlorobenzene
4-Methylphenol
Trichloroethene
1,1,2-Trichloroethane
Bromoform
4-Methyl-2-pentanone
Tetrachloroethene
Chlorobenzene
Ethyl benzene
Xylene (Total).
Hexachloroethane
Isophorone
2,4-Dimethylphenol
2,4-Dichlorophenol
Naphthalene
4-Chloroaniline
4-Chloro-3-methylphenol
2-Chloronaphthalene
2-Nitroaniline
Dimethylphthalate
Acenaphthylene
3-Nitroaniline
4-Nitrophenol
2,4-Dinitrotoluene
Fluorene
4-Nitroaniline
alpha-BHC
delta-BHC
Endosulfan I
4,4'-DDE
Endosulfan II
Endosulfan sulfate
Methoxychlor
alpha-Chlordane
Toxaphene
Arochlor-1221
Arochlor-1242
Arochlor-1254
74839
75003
67641
75354
540590
107062
71556
108054
78875
108952
95578
106467
95501
106445
79016
79005
75252
108101
127184
108907
100414
1330207
67721
78591
105679
120832
91203
106478
59507
91587
88744
131113
83329
99092
100027
121142
86737
100016
319846
319868
959988
72559
33213659
1031078
72435
5103719
8001352
11104282
53469219
11097691
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c
Aluminum
Arsenic
Beryllium
Calcium
Cobalt
. Iron,
Magnesium
Mercury
Potassium
Silver
Thallium
Zinc
"
TABLE 1
(continued)
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Nickel
Selenium
Sodium
Vanadium
Cyanide
-------
IRORGDIC
Antimony
. Arsenic
Barium
Chromium
Cyanide
Lead
Manganese
Nickel
Silver
Vanadium
Zinc
TABLE 2
CONTAMINANTS OF CONCERN IN GROUND-WATER
ORGDIC
Benzene
Beta-BHC
Bis (2-ethylhexyl) phthalate
Chloroethane
1,1-Dichloroethane
1, 2-Dichloroethene, .(total)
Arochlor 1242 (PCBs)
Trichloroethylene
vinyl Chloride
Xylenes (total)
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