"-
'- ,
~
United States
Environmental Protection
. Agency
Office of
Emergency and
Remedial Response
EPAIRODIR05-921223
September 1992
PB93-964129
&EPA
Superfund
Record of Decision:
H. Brown Company, MI
u . ~. Environmental Protection Agency
Reglo~ 11/ Hazardous Waste
Techmcallnformation Center
84.1 Chestnut Street, 9th Floor
Phtladelphia. PA 19107
. :
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadetphia. PA 19107
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o
NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain materiaJ which suJ)pIement. but adds no fufther ~ information to
the content of Ute document. All supptemental material is, however. oantain8d in the administrdYe record
for this site.
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50272.101
I REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. Recipient'a Acceaaion No.
PAGE EPA/ROD/R05-92/223
4. TItle and SubtlUe S. Report Date
SUPERFUND RECORD OF DECISION 09/30/92
H. Brown Company, MI 6.
First Remedial Action - Final
7. AUlhor(a) 8. Performing Organization RepL No.
t. Filrfonnlng OrgalnlzatJon Name and Adell... 10. ProjectlT..k/Work Unit No.
11. Contl8ct(C) or Grant(G) No.
(C)
(G)
1~ Sponaorfng Organization Name and Adell... 13. Type 01 Report & Filriod Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
1 S. Supplementary NoIe8
PB93-964129
16. Abatl8d (Umlt: 200 worde)
The H. Brown Company, Inc., site is a former landfill and battery reclamation facility
in Walker, Kent County, Michigan. Land use in the area is predominantly recreational
and industrial, with a wetland area located approximately at the northern half of a
marshy area within the current eastern boundary of the site. In addition, part of the
site lies within the 500- year flood plain of the Grand River. Before 1961, the site
was an uncontrolled dump that received unknown types and quantities of waste. From
1961 to 1982, the owner reclaimed lead from wet-cell batteries. From 1961 and 1978,
the owner reclaimed lead from wet-cell batteries and poured battery acid directly on
the ground surface. The total volume of battery acid disposed of is estimated to be
between 170,000 and 460,000 gallons. From 1978 until the owner ceased active
reclamation activities in 1981 or 1982, battery acid was not drained to the ground:
instead, it was routed to a stainless-steel catch pan and tank. In 1970, the state
inspected the site and noticed acidic waters draining into a culvert that discharged
into the Grand River. In 1978, the state sampled wastewater at the facility and found
elevated levels of lead, copper, and nickel. EPA became involved with the site in the
early 1980's and sampling of surface water from the culvert leading to the Grand River
(See Attached Page)
17. Document Analyal8 L Deacrlptora
Record of Decision - H. Brown Company, MI
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw, sw, air
Key Contamipants: VOCs (benzene, toluene, xylenes), other organics (PAHs, PCBs,
pesticides, phenols), metals (arsenic, chromium, lead)
b. IdentlfiaralOpen-Ended Terma
Co COSATI FiaIdiGroup
18. Avall8bility Sl8tement 19. Security CI..e (This Report) 21. No. 01 Pagea
I None 82
20. Security Cia.. (Thia Page) 22. Price
None
A .1 272 (4-77)
(See NSI-Z38 8)
See Instructions on RevetSe
(Formerty N11s.35)
Department 01 Commerce
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~
EPA/ROD/ROS-92/223
H. Brown Company, MI
First Remedial Action - Final
Abstract (Continued)
indicated elevated levels of chromium and lead. In 1989, the Agency for Toxic Substances
and Disease Registry and the state investigated the site and determined that the site
posed a risk to onsite workers and the community. In response to an EPA-issued
unilateral administrative order to 10 PRPs in April 1991, the owner's widow and the H.
Brown Company erected a fence and performed limited air monitoring around the site. This
ROD addresses the final remedy for the site. The primary contaminants of concern
affecting the soil, sediment, debris (battery casings), ground water, surface water, and
air are VOCs, including benzene, toluene, and xylenes; other organics, including PAHs,
PCBs, pesticides, and phenols; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes demolishing onsite buildings to allow
cleanup of contaminated soil beneath structures, and disposing of the debris in an onsite
or offsite landfill; onsite decontamination of buildings not requiring demolition;
consolidating contaminated surface soilonsite; treating an estimated 180,000 cubic yards
of soil, sediments, and battery chips onsite using in-situ solidification/stabilization;
constructing a containment wall around the treated soil, sediment, and debris, and
covering the solidified material using a multi-layer cap; extracting contaminated ground
water from the shallow aquifer beneath the site; treating collected ground water and
surface water onsite using aeration, filtration, carbon adsorption, and ion exchange,
prior to onsite discharge to the Grand River; conducting additional studies to further
define the extent of contamination in the intermediate and bedrock aquifers; monitoring
ground water and surface water; and implementing institutional controls including deed
and ground water use restrictions, and site access restrictions such as fencing. The
estimated present worth cost for this remedial action is $15,000,000, which includes an
annual O&M cost of $220,000 for 2-3 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil clean-up goals are based on site risks, state ARARs, or background
levels and include PCBs 1 mg/kg (state); arsenic 6.6 mg/kg (background); lead 5 mg/kg
(state). Chemical-specific ground water clean-up goals include benzene 1 ug/l (state);
arsenic 17.9 ug/l (state); and lead 1,423 ug/l (background).
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United States Environmental Protection Agency
Record of Decision
H. Brown Co., Inc. Site
Walker, Michigan
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Table of Contents
S ecti on
Declaration
................. ........... ....
State of Michigan:
Letter of COncurrence. . . . . . . . . . . . . . .
Dec~5ion Summary
.. .. .. ..
.. .. .. ..
.. .. .. .. .. .. ..
.. .. .. .. .. .. ..
Site Name, Location, ana
Description.
.. .. .. .. .. .. .. ..
.. .. .. .. .. ..
Site History ana Enforcement Activities. .
.. .. .. ..
.. .. .. ..
.. .. .. ..
Highlights of community Participation. .
.. .. .. ..
.. .. .. ..
.. .. .. .. ..
Scope ana Role of operaele Unit or Response Action Within Site
Strategy
...........
.. .. .. .. ..
.. .. .. ..
Swmmary of Site Characteristics.
.. .. .. .. .. ..
.. .. .. .. .. .. .. ..
Vi8ual Appearance
Surface Drainage
.. .. .. .. ..
.. .. .. .. .. ..
.. .. .. .. ..
............-
.. .. .. ..
Site Geology ana Hydrogeology .
.. .. .. .. .. .. ..
.. .. .. .. ..
COntamination. .
.. .. . .. ..
.. .. .. .. ..
.. .. .. .. .. ..
Air .
.......
.. .. .. .. .. ..
.. .. .. .. .. ..
Soil
......
.. .. .. ..
.. .. .. .. ..
.. .. .. ..
E8ttmatea Soil Volume.
.. .. .. .. .. ..
.. .. .. ..
Surface Soil
.. .. .. .. .. .. ..
.. .. .. .. ..
Subsurface Soil.
.. .. .. ..
.. .. .. .. ..
.. .. .. .. ..
.. .. .. .. ..
Grounawater . . .
.. .. .. .. ..
.. .. .. .. .. .. ..
.. .. .. ..
Surfacs Water ana Seaiments .
.. .. .. .. ..
.. .. .. .. ..
SWlllll&1"Y of Site Ri8k8 . . .
......
........
Human Health Risks
.. .. .. .. .. .. ..
.. .. .. .. ..
Evaluation of potential Health Risks from Leaa
.. .. .. ..
Environmental Risks. .
.. .. .. ..
.. .. .. .. .. ..
Rationale for Further Action.
.. .. .. ..
.. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
Description of Alternatives
. . . . . . . .
. . . . .
. . . .
common Elements
. . . .
. . . . .
. . . . .
Alternative 1:
No Action
. . . . .
. . . . . . . . . .
Page
i
iii
1
1
5
7
7
8
8
a
13
13
14
14
19
19
21
21.
2S
26
26
34
3S
36
36
36
37
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Alternative 7~.
Soil Containment, Groundwater Treatment, and
Drainage Remediation
. . . . . . .
. . . . . . .
Alternative
8:
Pilot
and
Containment,
Scale
:'reatment
Groundwater Treatment and Drainage Remediation
. . . .
Alternative 9:
Soil Disposal,
and
Groundwater
Treatment,
Drainage Remediation
. . . . . . . .
. . . . . .
Alternative 10:
Pilot and Full-Scale Soil and Groundwater
Treatment and Drainage Remediation
. . . . . . .
Alternative
11:
Soil Smelting and Disposal,
Groundwater
Treatment, and Drainage Remediation. . .
. . . . . . .
Alternative 12:
Soil Smelting and Treatment,
Groundwater
Treatment, and Drainage Remediation. . .
. . . . . . .
Alternative 13:
Soil Smelting and Containment, Groundwater
Treatment, and Drainage Remediation. . . . . . .
Alternative
14:
Soil
smelting,
Solidification
and
Containment,
Groundwater
and
Drainage
Treatment
Remediation.
. . . .
.........
. . . . .
Alternative
15:
Solidification
and Containment of
Soil,
Groundwater Treatment, and Drainage Remediation. . . .
Comparative Analysis of Alternatives:
The Nine Criteria
. . . . .
The Nine Criteria
. . . . .
. . . .
. . . . . .
. . . . . . .
Overall
of
Health
the
and
Protection
Human
Environment. .
. . . . .
compliance with ARARs .
. . . . .
. . . . .
Long-Term Effectiveness and Permanence
. . . .
. . . .
Reduction
of
Toxicity,
Mobility,
Volume
of
or
COntaminants Through Treatment
. . . . .
. . . .
Short-Term Effectiveness
. . . .
.......
. . . .
Implementability
. . . . . . .
. . . .
. . . .
. . . .
Cost
. . . . . .
. . . . .
. . . . . .
. . . . .
State Acceptance
. . . .
. . . . .
. . . .
community Acceptance
. . . . . . . .
. . . .
. . . . .
Selected Remedy. . .
. . . .
. . . .
. . . .
. . . . .
Statutory Determinations
......
. . . . . .
. . . . . .
37
,-
~ I
38
38
39
39
40
40
41
41
41
41
42
43
43
44
44
45
45
45
46
50
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Protection of Human Health and the Environment
. . .. . . . .
Compliance with ARARs .
. . . .. . ..
. . .. .. . . . .. . . . . .
Chemical-specific ARARs .
. . . ..
. . .. . .
Location-specific ARARS .
. . . . .
. . . ..
Action specific ARARs . .
.. . .. .
. . . .
.. . . .
To-Se-Considered ARARs
. . . . ..
. .. . . .
Cost Effectiveness
. . . . .
. . . . . . . . . .
. . . . . .
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
. . . . . . . ..
Preference for Treatment as a Principal Element.
Summary. . . . . . . . . . . . . .
. . . . ..
. . . .. .
. . .. .. .. ..
Responsiveness Summary
(following 62)
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
Administrative Record Index. . . . . . . . (following Responsiveness Summary)
50
51
51
59
60
61
61
62
62
62
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Declaration
Selected Remedial Alternative
for the
H. Brown Co., Inc. Site
Walker, Michigan
site Name and Location
H. Brown co., Inc. Site
2200 Turner Ave., N.W.
Walker, Michigan 49504
Statement of Basis and PurDose
This decision document presents the selected remedial action for the
H. Brown Co., Inc. site, in Walker, Michigan, which was chosen in
accordance with the requirements of 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 document explains the factual and legal basis for selecting
the remedy for this site. The information supporting this remedial
action decision is contained in the administrative record for this
site.
Assessment of the site
Actual or threatened releases of hazardoUs substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DescriDtion of the Selected RemedY
The selected remedy is the final remedy for the site. The remedy
addresses the threats posed by principal threat wastes and
contaminated groundwater at the site. Principal threat wastes are
defined as those soUrce materials considered to be highly toxic or
highly mobile that generally cannot be reliably contained or would
present significant risk to human health or the environment should
exposure occur.
The major components of the selected remedy include the following:
.
Demolishing buildings to allow cleanup of contaminated soil
beneath the structures, and disposal of the debris on-site or
in an appropriate off-site landfill.
i .
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.
consolidating contaminated surface soil
subsurface soil cleanup will be required.
area where
in the
.
SOlidifying/stabilizing, in place, contaminated surface and
subsurface soil and sediments in a cement-like form.
.
Placing a multilayer cap over the solidified/stabilized soil.
sufficient to meet the requirements of Michigan1s Act 64.
.
Surrounding the solidified/stabilized soil with a containment
wall.
.
Collecting, treating and discharging to the surface water all
groundwater and surface water associated with construction.
.
Installing additional wells to further define the condition of
the intermediate and deep aquifers. This information will be
used to determine what, if any, remediation of those aquifers
needs to take place. These wells, along with other wells at
the site, will be used to monitor the effectiveness of the
remedy.
.
Restricting the use of the land and the groundwater.
.
Maintaining a fence around the site to prevent access.
Declaration of Statutorv 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. The 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 every
five years after commencement of remedial action to ensure that the
Valdas V. AdamkUS Date
Regional Adminis
ii
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State of Michigan:
Letter of Concurrence
iii
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tV\ I"UKAI. t'u:.::iOuHCU
COMMI88IOH
I.N\"" oeVUY~T
'ALIL I!ISfLf
Q.O"OCIN f CUYfR
":"'C:; P WILL.
0.&\/10 ItOLLi
o STewART \.IVERS
.JOE. Y ... S~ AHO
R \028
ZlIa
@J
~OHN ENGLER. Governor
DEPARTMENT OF NATURAL RESOURCES
Se.ve,.. T. MUOo 8.'14;1\0. P.O. 800300'1.1.0""0. loll '8!10e
!lOLAIfO ""Alllia. O;'I:CIO'
September 30. 1992
Mr. Valdas V. Adamkus. R-19J
Administrator. Region 5
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago, Ill1no;s 60604-3590
Dear Mr. Adamkus:
The Michigan Department of Natural Resources (MOHR). on behalf of the State of
Michigan, has reviewed the draft Record of Decision (ROD) for the H. Brown
Co.. Inc.. Superfund site in Walker, Kent County, Michigan. which we received
on September 10. 1992. We are pleased to inform you that we concur with the
remedy outlined in the draft ROD for this site.
The major components of this remedy include:
*
Demolishing buildings to allow cleanup of contaminated soil beneath the
structures and disposal of the debris on site or ;n an appropriate
off-site landfill.
*
Consolidating contaminated surface 5011 to the area where subsurface
sot' cleanup will be required.
Solidifying, in place, contaminated surface and subsurface soil and
sediments in a cement-like form.
*
*
Placing a multilayer cap over the solidified soil to inhibit
infiltration of precipitation through the solidified mass and to protect
it from freeze thaw conditions. At a minimum, the cap would meet the
Hazardous Waste Management Act, 1979 PA 64, as amended. requirements,
including: .
three feet of compacted clay,
a layer of compacted soil to protect the cap from frost,
a drainage layer, and
a vegetated top soil layer.
*
Surrounding the solidified soil with a containment wall.
-------
Mr. Valdas V. Adamkus
-2-
September 30, 1992
.
Collecting, treating and discharging groundwater and surface water to
the Grand River.
Installing additional wells to further define the condition of the
intermediate and deep aquifers. This information will be used to
determine what, if any, remediation of those aquifers needs to take
place. These wells. along with other wells at the site, will be used to
monitor the effectiveness of the remedy.
*
*
Restricting the use of the land and the groundwater.
Maintaining a fence around the site to prevent access.
*
The State of Michigan also generally concurs with the analysis of legally
applicable or relevant and appropriate requirements contained in the Statutory
Determinations section of the ROD. Due to the pervasive organic and inorganic
soil and groundwater contamination in the vicinity of the s1te which will
remain unaddressed. the State considers this to be an interim action under the
Michigan Environmental Response Act, 1982 PA 307, as amended. This pervasive
contamination appears to be due to historical landfilling practices in this
vicinity and not the result of activities at the H. Brown site.
We look forward to implementation of the remedy for this site.
SlnCerelY~
~ /.;
Russe J! Ha 1
517-373.7917
cc: Hr. James Mayka, EPA
Mr. Timothy Prend1ville, EPA
Mr. Alan J. Howard, MOHR
Mr. William Bradford, MOHR
Ms. Claudia Kerbawy, HDNR
Mr. Jim Myers/H. Brown File (J2)
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Decision Summary for the Record of Decision
1.
site Name, Location, and
Description
The H. Brown Co., Inc. site is located generally near 2200 Turner
Avenue, N.W. in the city of Walker, Kent County, Michigan. Figure
1 is a site location plan and Figure 3 is a diagram of the site.
The H. Brown site is located in a light industrial area in Walker,
in south central Michigan. A Grand Rapids city park is located east
of US-131. Further to the east of the park, approximately 1,000
feet from the site, lies the Grand River. The site is roughly
bounded by US-131 on the east and Turner Avenue on the west, but
includes one area to the west of Turner Avenue. The site also
includes Zenith Auto Parts to the north and Abbott Auto Parts
(formerly Turner Auto Parts) to the south. The site is roughly
bounded by Zenith Auto Parts on the north, southbound US-131 on the
east, Abbott Auto Parts on the south, and Turner Avenue on the west.
The site includes the following components (see Figure 3):
.
Areas with surface soil contaminated with 500 parts
per million (ppm) or more of lead;
.
An unnamed drainage ditch east of Zenith Auto Parts;
.
A drainage ditch named Cogswell Drain located near
the southern boundary of Keizer Equipment Company;
.
The storm sewer on Turner Avenue,
Auto Parts and Cogswell Drain;
between Zeni th
.
Approximately the northern half of a marshy area
within ( 1) the current, eastern boundary 0 f H.
Brown, (2) southbound US-131, (3) Cogswell Drain,
and (4) the unnamed drain east of Zenith Auto Parts.
This area is referred to as the "wetland" throughout
this document.
The general area qf the site was once used as a landfill that
received unknown types and quantities of waste. The boundaries of
the landfill are not well defined, but they may extend beyond. the
boundaries of industries surrounding H. Brown.
1
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,
.
I
l£GEND
.-.. .....
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,
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.
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- - ......... ~
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WAI.I
-------
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- - -....... ~ -
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"----'. :--.
Fi u re 2
'-
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LEGEND
~ AREA OF IOOu'\'£AH
ZONE A FLOOD
AREA BETWEEN LlMIl S
OF mE tOO-YEAR
AND 500- YEAR FLOOD
I I AREA OF MINIMAL
ZONE C FLOODING
H.
BROWN
SITE
5110' J.. 500' 1,000'
~ -----,----1
SCALE: I- = 1,000'
H. BROWN SITE
WALKER. MICHIGAN
-------.-..---..
FIGURE 3-2
FLOOD PLAIN MAP
- .---... . .---.---- - -- - . <-..
#¥II: ENVIRONMENTAL MANAGEMEtIT, IIIC
-------
Figure J
.1
--- -- ---
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-------.-
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} II IIRowt-l ::ill 1
-.N-
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. ~ I .
, ~
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'.
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2.
Site Historv and Enforcement Activities
Before 1961, a large area, including the site, was an uncontrolled
dump. Herman Brown (now deceased) owned mos~ of the area now called
the H. Brown site. From 1960 to 1962 Mr. Brown leased portions of
his property to the City of Grand Rapids on a con~ingent basis for
landfilling purposes. This contingency never developed, and during
the time of Mr. Brown's operations, no landfilling occurred. No
documentation is available regarding the amounts and types of
hazardous substances, if any, or the parties who may have disposed
of waste in this landfill area.
Between 1961 and approximately 1982, H. Brown reclaimed lead from
wet-cell batteries. Battery reclamation operations were not limited
to the fenced portion of the site. Such operations probably
extended north, south, and east of the fenced portion of H. Brown.
From 1961 to 1978, battery acid was poured directly on the ground
surface of an area measuring approxima~ely 25 by 50 feet. This area
housed a battery shredder. The battery acid was drained directly to
the ground before shredding the batteries. EPA believes that the
acid was contaminated with heavy metals. The total volume of
battery acid disposed of in this area is estimated to be between
170,000 and 460,000 gallons. During the early years of operation,
battery reclaiming activities may not have been limited to the 25-
by 50-foot area. Some battery casings may have been broken during
storage elsewhere on the site and then hauled to the battery
shredder for further processing. After 1978, battery acid was not
drained to the ground; instead, it was ro~ted to a stainless-steel
catch pan and tank. H. Brown ceased active reclamation, including
battery shredding, in 1981 or 1982. From that date to the present
the operation accepted scrap nonferrous metals that are sold to off-
site purchasers.
Before 1985, MDNR considered H. Brown to be a small-quantity
. generator of hazardous waste. The facility no longer reclaims
batteries or generates hazardous waste.
MDNR inspected H. Brown several times during the 19705. In 1970,
MDNR noted acidic waters draining into a culvert that discharged to
the Grand River. In 1978, MDNR sampled wastewater ponded at the
facility and found elevated levels of lead (3.9 parts per billion
(ppb), copper (22 ppm), and nickel (2.6 ppm).
In the early 1980s, u.s. EPA became involved with the site. The
site was inspected in 1984 as a potential hazardous waste site.
sampling of surface water from the culvert leading to the Grand
River indicated elevated levels of chromium (198 ppm) and lead (1.4
ppm) and an acidic pH that may have been attributable to the site
operations. Subsequently, the site received a Hazard Ranking System
score of 39.88 and was proposed for listing on the National
5
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Priorities List (NPL) on March 29, 1985. The site was designated a
Superfund site and placed on the NPL on June 10, 1986.
On september 28, 1987, U.S. EPA began negotiations with a group of
potentially responsible parties (PRPs) for performance of the RIfFS.
On March 4, 1988, negotiations were c~ncluded without resolution
because the Agency did not receive a geod faith offer.
In November 1988, U.S. EPA began the RIfFS at the site. After
preliminary investigations at the site detected high levels of lead
in surface soil, U.S. EPA informed the Agency for Toxic Substance
and Disease Registry (ATSDR) of the po~ential for threat to publi=
health. ATSDR and MDNR's Division of Public Health investigated the
site in August 1989. On the basis of MDNR's findings, ATSDR
determined that the site may pose a risk to on-site workers and the
community.
On April 12, 1991, U.S. EPA issued a Unilateral Administrative Order
(UAO) to ten PRPs. The UAO required that those parties erect a
fence around the en~ire site and implement a dust control program.
To date, only Tessie Brown (Herman Brown's widow) and the H. Brown
company have complied with the UAO, erecting a fence with a
windskirt around the site and performing limited air monitoring.
The RI was conducted from November 1988 to March 1991. During the
RI, the nature and extent of contamination at the site was
determined, contaminant fate and transport was examined, and a
baseline risk assessment was conducted. This information is
summarized below. The June, 1992, RI' report provides further
details.
On June 23, 1992, U.S. EPA made an offer of a de minimis settlement
to approximately 1400 PRPs. Using site documents obtained from
Herman Brown, the Agency calculated that each of these PRPs
contributed less than 0.1% of the volume of waste to the site. In
the proposed settlement a paymen~ schedule is presented which
consists of three tiers. The tiers are based upon volume of
hazardous substances contributed by the PRPs. The payments
specified for each respective tier are $1,000, $5,000, and $10,000.
The settlement was structured such that the Agency would recover
approximately 10% of past and future response costs. On July 30,
1992, the Agency held a meeting with the de minimis parties in Grand
Rapids, Michigan with approximately 700 of the de minimis parties
attending. At that meeting the Agency explained the settlement and
answered questions. copies of the documents linking each of the
parties to the site were also distributed. The deadline for the
parties to commit to the settlement by providing signature pages to
. the Agency, was september 22, 1992.
6
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"I
-' .
Hiahliahts of Community Participation
Community interest with the site had been minimal throughout the
RIfFS process. In May 1989, a fact sheet was sent out informing the
public about the Superfund process and describing the activities
planned for the RIfFS. EPA held an availability session at the
Walker Community Building, on May 23, 1989 to discuss the planned
RIfFS process. On June 5, 1990, another availabilty session was
held at the Walker community Building, to discuss the results of the
first phase of the RIo Approximately 30 people attended this
session.
u.S. EPA released the Final RIfFS reports for the H. Brown site to
the public on July 8, 1992, for public comment. These two documents
were made available to the pUblic in both the administrative record
maintained at the United States Environmental Protection Agency
(U.S. EPA) Docket Room in Region V and at the Walker City Hall. The
documents were also made available at the public information
repositories maintained at Walker City Hall and Kent County PUblic
Library - Walker Branch. The notice of availability for these two
documents was published in the Grand Rapids Press on July 2, 1992.
The advertisement also announced that a public comment period on the
proposed plan and its underlying documents was to be held from July
8, 1992 to August 6, 1992. On July 24, 1992, U.S. EPA ran another
advertisement in the Grand Rapids Press announcing a 30-day
extension to the public comment period, extending it until September
8, 1992. In addition, a public meeting was held on July 30, 1992,
at the Amway-Grand Plaza Hotel in Grand Rapids, Michigan. At this
meeting, representatives from U.S. EPA and the MDNR answered
questions about problems at the site and the remedial alternatives
under consideration. Approximately 100 people attended that
meeting. A response to the comments received during this period is
included in the Responsiveness Summary, which is part of this ROD.
The provisions of Sections 113 (k) (2) (B) (i) - (v) and 117 of the
Comprehensive Environmental Response compensation and Liability Act
of 1980 (CERCLA), as amended have been satisfied.
4.
Scope and Role of Operable Unit or Response Action Within Site
Strateav
This Record of Decision (ROD) addresses the final remedy for the
site. The threats. posed by this site to human health and the
environment are primarily lead contaminated soil, battery casings,
sediments, surface water, and groundwater. .
The contaminated soil and battery casings are the source materials
for contamination at the site and are classified as principal threat
waste. Principal threat wastes are considered to be those source
materials that are highly toxic or highly mobile that generally
cannot be reliably contained or would present significant risk to
7
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human health or the environment should eXDosure occur.
ground and surface water will also be treated.
Contaminated
5.
Summarv of Site Characteristics
Pursuant to the authorities under the CERCLA, as amended, and the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), an RI and FS were conducted at the site.
Figure 4 thru 7 show the sampling locations for soil, suface water
sediments and groundwater. During the RI/FS the following
conditions were observed at the H. Brown site:
1. Visual Appearance
Batteries and scrap metal are stored on the ground or on pallets
throughout the currently active area of H. Brown. Within this area,
the ground is covered by a mixture of materials, collectively
referred to as "fill material." The fill material includes sand,
silt, and debris, such as battery chips, lead mesh from battery
cores, and other by-products of battery reclamation operations. In
general, the concentration of battery chips in the fill material
increases to the northeast. A large pile of battery chips,
approximately 100 feet by 100 feet by 15 feet high, lies in the
fenced portion of the central area of the H. Brown Co. property.
Battery chips and debris extend beyond the current, northern
boundary of H. Brown. An underground storage tank formerly used for
fuel oil was located in the southwestern area of H. Brown. This
area has been backfilled with sand after the tank was removed; a
polyvinyl chloride (PVC) standpipe has been installed as a vent.
2. Surface Drainage
The site is essentially flat, with no drainage controls. Much of
the surface runoff from within the current boundaries of H. Brown
collects in a small depression located in the southeastern part of
the fenced portion. The surface runoff from the rest of the site
flows either to the east, towards an ephemeral wetland area, or to
the west, towards Turner Avenue, where it enters the storm sewer
system.
Southbound US-13 1 is elevated above the level of the site,
restricting surface drainage further east and resulting in an
ephemeral wetland. The surface water ponded in the wetland flows
east under southbound US-131 through two culverts, one behind the
northeast corner of H. Brown and another behind the eastern boundary
of Zenith Auto Parts. These culverts discharge to the floodplain of
the Grand River.
Surface water may also enter the City of Walker storm sewer, which
runs from north to south along Turner Avenue. To the north, the
storm sewer discharges into an unnamed drain that runs east to the
8
-------
Grand River. To the south, the storm sewer discharges
Cogswell Drain, which receives runoff from areas to the
south of Keizer Equipment as well, and then flows east
Grand River. See Figure 7.
into the
west and
into the
3. Site Geology and Hydrogeology
The H. Brown site lies within the southern portion of the Michigan
Basin structure, which consists of sedimentary rocks dipping gently
to the north. In the site area, the sedimentary bedrock is covered
by a veneer of glacial alluvial drift, consisting of glacial
outwash, lake beds, sand, or spillways.
From a hydrogeologic point of view, the subsurface at the site
consists of the following four, distinct formations:
.
Topmost layer of fill material, approximately 15
feet thick; this layer is referred to as the
"shallow aquifer";
.
A layer of clay, approximately 4 feet thick on
average, just underneath the shallow aquifer; this
clay layer is referred to as the "aquitard";
.
A layer of glacial outwash material that lies
underneath the aquitard, except in the western
portion of the site where it is in direct contact
with the shallow aquifer; this layer is referred to
as the "intermediate aquifer"; and,
.
sedimentary
aquifer."
bedrocks,
referred
to
as
the
"deep
The shallow aquifer is recharged by infiltration of surface water
resulting primarily from precipitation on the site area. Therefore,
the flow of groundwater in the shallow aquifer varies throughout the
year. The groundwater in the intermediate and deep aquifers flows
. uniformly to the southeast.
The RI activities revealed that the intermediate aquifer receives
groundwater from the deep aquifer; it also has some potential ta
receive water from the shallow aquifer.
4. contamination
The analyses of the air, soil gas, surface soil, subsurface soil,
surface water, sediment, and the groundwater at the site revealed
that lead is the primary contaminant in all media at the site.
other metals, including arsenic, barium, chromium, and copper, were
also detected, but at much lower concentrations. Among organic
contaminants, volatile organic compounds (VOC), semivolatile organic
13
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compounds (SVOC), and polychlorinated biphenyls (PCB) were detected
in surface soil, subsurface soil, sediments, and groundwater.
Soil gas sample analysis indicated that the soil gas at the site
consists primarily of methane and hydrogen sulphide. Both gases may
be by-products of natural, biological decomposition of organic;
waste. Therefore, the investigation of contamination in soil gas
was not pursued after preliminary RI activities.
The nature and extent of contamination in air, soil, groundwater,
and surface water and sediments at the site are summarized below.
Air
Air at the site is contaminated by dust from the site; it has
particulate matter containing lead and other contaminants present in
surface soil at the site. In August 1989, eight air samples from
various upwind and downwind locations at the site were collected.
Using these samples, the highest concentration of lead in air at the
site was found to ~e 23.7 micrograms per cubic meter (~g/mJ), in an
area affected by facility operations, such as loading and unloading
trucks and operating a forklift. The lowest measured concentration
of lead in air was 0.82 ~g/mJ, at a location upwind of the site.
Soil
Samples from surface and subsurface soil at the site were collected
and analyzed for to~l analyte list (TAL) metals and target compound
list (TCL) organics in May and June 1989, and again in August 1990.
Figures 4 and 5 show the sampling locations for surface and
subsurface soil,' respectively. Tables 1 through 4 present
analytical results of soil sampling conducted at the site. These
tables also present the statistical information related to the
detection of TAL metals and TCL organics in soil samples.
Data indicate that surface soils are contaminated with a variety of
SVOCs and PCBs. In addition, VOCs and pesticide. compounds were
detected at low levels and low frequencies. When the on-site
concentrations of VOCs, SVOCs, and pesticide compounds are compared
to background concentrations, it is evident that many contaminants
with elevated concentrations in site soils are also present in
background soils. Also, individual SVOC, VOC, and pesticide
compounds may be comparatively elevated in either background or site
soil samples.
Some metals, such as aluminum, copper, iron, and zinc, naturally
occur at high concentrations in soil; detection of such metals in
soil does not necessarily indicate soil contamination at the site.
other metals, such as antimony, arsenic, and lead, do not naturally
occur at high concentrations in the soil. Therefore, detection of
14
-------
such metals in high concentrations in soil at the site indicates
soil contamination.
As indicated in Tables 1 and 3, lead and antimony were detected in
soil at much higher levels t~an other inorganic contaminants. In
addition, concentrations of antimony detected in soil at the site
were in proportion to those of lead in soil. Both observations
indicated that (1) the soil at the site is conta~inated pri~arily by
lead and antimony and (2) the contamination of soil at the site is
related to past battery reclamation activities at the site.
The contamination of soil by lead is selected to represent the
extent of surface and subsurface soil contamination at the site.
The RI report should be referred to for more details of the extent
of soil contamination by substances other than lead.
Estimated soil Volumes
The total volume of battery chips was estimated to be 33,000 cubic
yards (cy), out of which approximately 15,000 cy is stockpiled on
the surface and the remaining 18,000 cy is mixed with the fill. The
volume of soil to be remediated, including battery chips, is
estimated at 180,000 cy. Approximately 50,000 cy of soil is
estimated to have lead concentrations more than 20,000 mg/kg; the
remaining 130,000 cy of 50il is estimated to have lead
concentrations between 20,000 and 500 mg/kg.
All settled sediments above cleanup levels,
drainage ditches, should also be remediated.
surface soil
in storm sewers and
Highest and lowest concentrations of lead in surface soil within the
currently active area of H. Brown were found to be 265,000 and 800
mg/kg, respectively. corresponding concentrations outside the
currently active area of H. Brown were found to be 380,000 and 58
mg/kg, respectively.
Figure 8 shows isoconcentration contours for lead in surface soil
wi thin the currently active area of H. Brown. The highest
concentrations of lead in surface soil were detected in the
following areas:
.
An area surrounding the location of former battery
shredder in the center of the fenced portion;
.
An area west of the former shredding operation and
within the fenced area, where battery chips are
accumulated; and,
.
An area just north of the eastern portion of the
fenced area, where battery chips were disposed.
19
-------
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Subsurface soil
Subsurface soil samples were first obtained from waste
characterization and well borings within the currently active area
of H. Brown. Samples were later collected from other locations for
an improved assessment of the nature and extent of contamination in
areas of known or suspected lead-contaminated surface soil. Figure
9 shows the concentrations of lead in subsurface soil at various
depths at sampling locations within the currently active area of H.
Brown.
Concentrations of lead decrease dramatically with depth. For
example, concentrations of lead decrease by two orders of magnitude
within the first 5 feet from the ground surface. At 12 feet below
the ground surface, high concentrations of lead are limited to
isolated spots. Below the aquitard, lead concentrations are
comparable to the background levels of lead in subsurface soil.
Groundwater
The groundwater in all three aquifers (shallow, intermediate, and
deep) is contaminated; contaminants detected in these aquifers are
presented in Tables 5 and 6. Contaminants and the statistical
information related to their detection in shallow, intermediate, and
deep aquifers are presented in these tables as normal, shaded, and
bold text, respectively.
Many inorganic elements, such as calcium, iron, and manganese,
naturally occur- at high concentrations in the groundwater.
Detection of these inorganics at high conc~ntrations in groundwater
at the H. Brown site does not mean that the groundwater at the site
is contaminated by them. However, the occurrence of inorganic
metals such as antimony, arsenic, and lead at high concentrations
and of all organic compounds is not natural. Therefore, their
detection in groundwater at the H. Brown site is an indication of
ground-water contamination.
considering above mentioned differences in concentrations that
generally define the contamination by an inorganic element or an
organic compound, Tables 5 and- 6 indicate that the shallow aquifer
at the site is contaminated primarily by inorganic contaminants.
The intermediate and deep aquifers are contaminated primarily by
organic contaminants. Some organic contaminants detected in the
intermediate and deep aquifers, such as vinyl chloride, were -not
detected in the soil or the shallow aquifer at the H. Brown site.
Therefore, the contamination of intermediate and deep aquifer may
not be solely associated with the battery reclamation activities at
the site, which primarily involves inorganic chemicals.
contamination of groundwater in the shallow aquifer is directly
related to Herman Brown I s acti vi ties. Ubiqui tous, high
concentrations of lead in groundwater can be associated with
21
-------
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-------
TABLE)
Range of Range of
Contaminant' Detection Detected Mean 95% Contaminant Delection Detected Mean 95%
Frequencyb Concentrations UCL< Frequency Concentrations uel
(mglkg) (mglkg)
Aluminum 38 of 38 2,310 to 19,300 7,669 9,083 Magnesium 38 of 38 2,050 to 33,900 8,034 9,808
18 of '8 i9510'18,300 S,9i4 8,2$2 18 of i 8 i9.110 ri,800 4,844 6,80j
Antimony 19 of 38 3.8 to 1,030 57.6 117 38 of 38 98.6 10 2,350 420 542
i4 of i8 2.8 io 6,560 631 1.407 Manganese 18 o~ 18 U to 512, 218 291
Arsenic 38 of 38 2.1 10 104 16.5 23.8 Mercury 27 of 38 0.12 to 1.5 0.4 0.5
18 of i8 2.4 to 254 43 73.7 IJ of 18 O. i 10 0.6 0.2 0.3
Barium 38 of 38 41.810 1,000 254 322 Nickel 38 of 38 10.6 to 1,300 106 178
180t i8 i1.3 10532 140 200 i 8 of 18 1.6 to 123 24.8 39.4
Beryllium 34 of 38 0.2 to 2.0 0.5 0.7 Potassium 38 of 38 211 to 2,080 649 774
12 of 1 $ 0.3 10 1.5 0.5 0.1 17 of 18 135 io 1,720 621 841
Cadmium 13 of 38 0.6 to 32.8 1.9 3.6 Selenium 8 of 38 0.72 10 2.6 0.5 0.7
5 of I ~ 0.5 to 4.7 0.7 1,3 4 of t 8 0.4 to 1.6 0.4 0.5
38 of 38 3,970 10 110,000 30,276 37,637 Silver 6 of 38 1.1 to 13.8 1.0 1.7
Calcium 18 of 18 528 10 $0,800 22,114 30,246 6 of 18 0.6 io 6.0 i.2 2.0
Chromium 38 of 38 8.6 to 165 42.3 53.4 Sodium 38 of 38 47.3102,270 269 387
18 of t 8 2.8 to 254 39 68.7 18 ot IB 54.1 io 283 135 162
38 of 38 3.0 1082.3 9.1 13.2 Thallium 3 of 38 0.5 to 2.1 0.3 0.5
Colla!! 18 of 18 1.11026.1 2 of 18 1.0102.3 0.6
6.2 ~U 0.8
31 of 38 3.7101,390 118 255 Vanadium 36 of 38 5.0 10 55.5 17.4 20.9
Correr " 13 of 18
18 of 18 19.4 to 1,000 199 339 2.9 io 23.2 8.8 12.3
38 of 38 5,500 10 162,000 38,847 49,425 Zinc 38 of 38 27.9 to 6,280 793 1,159
lrem 18 of 1 ~ 902 10 97,100 25,141 38,541 18 of 18 30.8 io 1,180 345 595
Lead 38 of 38 7.2 to 622,000 26,236 58,670
18 of i Ii 118 10 6~9,OOO 64, 125 142,400
INORGANIC CONTAMINANTS DETECTED IN SUnSURFACE SOIL
Notes: . Information relaled 10 contaminants delt:cted wilhin currently active area arrear as normal text; those detected oUlside cnrrenlly aClive area
arpear as shaded text .
b A deleclion frequency of -36 of 38- imrlies Ihal the contaminanl was delected in 36 of 38 samples
< The 95 % upper confidence limit (UCL) on the arithmetic mean concentration of detected contaminant in soil
1-17
-------
TABLE 4
Detection Range of Detected 95% Detection Range of Detected 95%
Contaminant Frequency" Concentrations Mean UCLb Contaminant Frequency Concentrations Mean UCL
(ftglkg) (ftglkg)
VOC. 4-Chlorophenyl-phenylelher I of 14 4,000
Vinyl Chloride I of 18 14 Fluorene 9 of 16 230 to 6,700 1,565 2,593
Methylene Chloride 12 of 18 2.3 to 18 4.4 6.5 N -Nitrosodiphcny Ilimine 3 of 16 860 to 4,600
Acetone 160f 18 6.0 to 1,100 202 384 Phenanthrene 15 of 11 530 to 30,500 7,042 11,411
_....~
Carbon Disulphite II ul 18 1.5 to 970 79.9 194 Anthncene 10 of 16 330 to 6,700 1,753 2,902
2-butanone 5 of 18 16to 170 35.8 63.3 Di-n-Butylphth818te 3 of 15 380 to 8,600
I,I,I-trichloroethane 2 of 18 5.0 to 8.0 Fluonnthene 17 of 17 410 to 33,500 6,803 11,322
Trichloroethene I of 18 7.0 Pyrcne 11 of 18 460 to 36,000 1,055 11,410
Benzene I of 18 8.0 Butylbenzylphthalate I of 14 98,000
Toluene 13 of 18 4.0 to 18 18.1 21-6 Benzo(a)anthracene 10 of 15 430 to 15,950 3,166 5,601
Chlorobenzene I of 18 27 Chry.cne 14 of 18 680 to 15,400 4,165 6,332
Ethylbcnzenie 60fl8 7.0 to 2,000 125 358 Bis(2-cthylhex yl)phthalalc 10 of 16 540 to 110,000 15,948 31,516
Total Xylenes 6 of 18 9.0 to 9,300 533 1,621 Di-n-octylphthalate I of 14 1,600
SVOC. Benzo(b )nuoranthenc II ofl6 980 to 15,100 3,058 :. i .516
2-Methylphenol I of 15 5,800 Benzo(k)nuoranthenc 1 of 14 660 to 10,900 2,239 4,108
4-Methylphenol I of 15 4,100 Indeno( 1,2,3-cdlPyrenc 5 of 14 380 to 4,300 171 1,435
2,4-Dimethylphenol I of 15 3,500 Dibenz(a,h)anthracene I of 14 3,900
Napthalenc 12 of 11 230 to 5,300 1,581 2,343 Benzo(g,h,i)pcrylene 5 of 14 380 to 2,875 687 1,190
2-Methylnapthalene 13 of 18 150 to 3,800 1,095 1,684 Pesticides and PCBs
Acenapthylene 2 of 14 293 to 460 4,4' -DDD 4 of 18 110 to 150 131 - 232
Acenapthene 7 of 15 160 10 3,700 931 1,608 4,4'-DDT I of 18 325
Dibenzofuran 8 of 15 160 to 5,500 1,104 1,928 Aroclor-1221 3 of 18 2,025 to 56,000
2 ,4-Dinitrotoluene I of 14 4,000 Aroclor-1242 2 of 18 6,600 to 11,000
- Arocior-12S4 --
Dimethylphthalate I of 14 4,000 4 of 18 2,900 to 9,600 2,511 3,198
'ORGANIC CONTAMINANTS DETECTED IN SUBSURFACE SOIL
Nntes:
. A detection frequency of "I of 18" indicates th.t contaminant was detected in one of 18 samplcs
. 95 percent upper confidence limil of arithmetic mean of detected concentntions.
A blank cell in the table implies that corresponding statistical parameter could not be calculated because ..r the infrcquent detection of the contaminalll
-------
TABLE :
Range of
Contaminant Detection Detected Mean
Frequencr Concentrations 95% UCLb
(mg/kg)
Aluminum 60 of 60 213 to 23.200 4,501 5,317
Antimony 60 of 60 4.3 to 4,980 896 1,191
Arsenic 60 of 60 5.2 to 463 91.5 115
Barium 60 of 60 24 to 1.090 200 245
Beryllium 33 of 60 0.3 to 13.6 0.7 1.1
Cadmium 46 of 60 0.6 to 32.4 2.9 4.1
Calcium 60 of 60 2.400 to 97.100 15.944 19.402
Chromium. 57 of 60 7.5 to 214 39.6 49.9
Cobalt 56 of 60 1.2 to 14.2 4.1 4.8
Copper 60 of 60 27.4 to 4.400 557 767
Cyanide 10 of 43 1.0 to 3.9 0.8 1.0
Iron 60 of 60 1,280 to 153.000 24,293 30,088
Lead 60 of 60 806 to 265.000 110,123 130.150
Magnesium 59 of 60 2S2 to 18.500 5,129 6,010
Manganese 59 of 60 28.2 to 647 223 252
Mercury 52 of 60 0.1 to 1.8 0.4 0.5
Nickel S6 of 60 6.9 to 197 37.9 46.9
Potassium 57 of 60 208 to 1,100 464 523
Selenium 9 af 24 0.2 to 4.0 0.4 0.8
Silver 15 of 60 1.0 to 9.2 1.4 1.9
Sodium 54 of 60 63.6 to 345 115 129
Vanadium 56 of 60 5.0 to 49.4 12.2 13.9
Zinc 60 of 60 41.9 to 2,040 361 438
INORGANIC CONTAMINANTS DETECTED IN SURFACE SOIL
Notes: . A ddectiou !requeDCY of .33 of 60. indicates that COD,..miftaJIl was detected in 33 of 60 samples
b 9S perceDl upper confidence limit of arilhmetic meaD of detected CODcenuabons
1-15
-------
TABLE 2
ORGANIC CONTAMINANTS DETECTED IN SURFACE SOIL
Contaminant Detection Range or Detected Mean 9570 UCL" Contaminant Detection Range of Detected Mean 95% UCL
F~uency" Concentnlion! ("glkg) Frequency Concentrations (1IIIkg)
voc. Pyrenc U or 11 210 to 120,000 10,264 24,94t
Methylene Chloride I of 11 46 Bulylbenzylphlhalate 6 of 17 120 to 670 175 278
... -.
Acetone 1 of 17 83 Benzo(a)anthncene 12 of 11 100 10 8,000 1,365 2,458
Carbon Disulfide S or 11 2.0 to 6.0 1.9 2.8 Chrylene 15 of 11 200 to 120,000 9,273 23,992
1,2-dichloroe:the:nc 4 of 11 2.0 to 5.0 1.6 2.2 Bis(2-dhylhex yl)phthu laIc 13 of 17 510 to 120,000 17,116 33,190
I ,I ,I-Irichloroelhane 3 of 17 6.81063 9.3 16.8 Di-n-oclylphthalale 2 of 11 :13010 4,700
Trichloroethenc S or 17 3.010 8.0 2.8 3.9 Benzo(b)nuoranthene 14 or 11 18010 8,700 1,914 3,049
Telmchloroclhane 5 of 17 7.0 to 26 8.0 12.2 Benzo(k)nuoranthene II of 11 83 to 4,000 \,041 1,116
Styrene 2 of 11 0.8 to 1.0 Bcnzo(a)pyrcnc 12 of 11 360 10 6,000 1,495 2,336
Toluene: 17 of 11 2.0 10 32 8.4 15.4 Indeno(I,2,3-cd)pyrcnc 5 or 17 690104,200 952 1,579
Xytenes I of 17 2.0 Dibenz(a,h)anthracene 2 or 11 190 10 1,600
I SVOC. I Benzo(g,h,i)pyrene 6 of 17 1,100 108,300 1,594 2.640
Phenol 5 of 11 100 10 400 109 168
2-Mcthylphenol 3 of 17 160101,160 184 335 I Pesticides and PCBs I
Isopropene 2 of 17 205 to 240 Della BHC 4 of 11 8.2 to 35 1.9 12.3
Benzoic Acid 2 of 17 280 to 180 Dieldrin 5 of 17 1810290 41.9 79.7
Naphthalene B of 17 19010 9,700 909 2,092 4,4-DDE 8 of 17 20 to 110 30.1 47
2-Mcthylnaphthalene 10 of 17 110101,300 752 1,634 Endrin 2 of 17 33 to 110
Acenapthylene I of 17 95 4,4-DDD 7 of 17 23 10 84 24 34.2
Aeenapthene 7 of 17 99 10 S ,800 524 1,238 4,4-DDT 9 of 17 38 to 180 11.9 104
Dihenzofuran 7 of 11 130 to 4,500 445 995 Endrin ketone 10 of 17 1110 18 28.2 40.4
Fluorcnc 9 of 11 19 to 4,200 442 964 Alpha-chlordane 2 or 17 250 10 295
N -nit roslIlJiphcnylamine 6 of 17 82.5 to 2,500 . 251 55S Gamma-chlordane 3 of 11 92 to 250 64.4 90.8
Phenanthrene 15 of 17 230 to 120,000 9,761 24,502 Aroclor-1221 2 of 17 4,300 10 12,000
Anthracene 10 of 17 11010 3,600 562 1,077 Aroclor-123 I I of 17 2,000
Di-n-Butylphlhulalc 4 of 17 120 to 710 113 194 Aroclor-1242 3 of 11 670 10 1.100 422 531
Fluoranlhene 13 of 17 21010 120,000 9,092 23,858 Aroclor-1254 II ofl7 81010 8,200 1,573 2,595
NlllcS:
. A detection frequency of "I of 17" indicates that conlaminant was detected in one of 17 samples
. 95 percenl upper confidence limil of arithmetic mean of detecled concentrations
A blank cell in the table implies Ihat corresponding statislical parameter could not be calculated because of infrequent delection of contaminant
1-16
-------
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-------
TABLE 5
Del.ClCtioa RUI8C of Detected 95% Detec&1on Range or DeleCleG I 95'1 I
ConWDinanl"
F~ Conc:cnua&iOlll i"glL) Mean I VCL" Conl8lDitwl& Frequency CODCel1lra&ioDl Mean
(/lgiL) VCL
I
26 of 26 43.3 ID 111.900 19.282 30.772 26 of 26 12.150. to 352.000 :
91.712 125.707 I
Aluminum 13 of 14 183..&0..0.400 5.245 11.214 Magncuum 14 of 14 44.500&0.307.000.. 124;m:. 168M}..
7 of 7 28.6 to 639 192 400 70f1 31'%00 to 146.000 101,%14 195.!08
6 of 26 26.3 to 281 37.2 62.7 26 of 26 247 to 9.080 1,710 2.415 I
Antimony Mang- 14 of 14 337. to 3.060. 880:,:::::.' 1;257 H
70(1 21.0 to 466 161 320 I
26 of 26 1.8 ID 370 34.5 64.1 12 of 26 0.25 ID 4.7 0.5 0.9 I
Aracnic 11 of14 1.%..&0 224 18~6 52..1 Mercury 1 of 14 0.15
3 on 2.9 to 3.7 2.21 3.24 lor7 0.81
26 of 26 US ID 1450 588 734 23 of 26 10.7 to 3.190 198 447 I
Barium 14 of 14 54.3 10 663 296'. 423 Nicbl 8ofJ4 1.810 157 23;6. 49.12H
7011 20.2 to 8IU 44.. 61.8
6 of 26 0.83 &0 4.95 1.0 1.47 26 of 26 I.22D to 68.300 17.597 23,467
BcryUium 1 of 14 1.9 Potauium 14 of 14 2..840.10 18.000 7,159 10,701 i
7011 7.3 to 10.800 4,693 8,484
10 of 26 1.4 to 21.7 4.33 6.66 I of 23 1.2
Cadmium 1 of 14 8.0 Selenium '
i
26 of 26 112.500 10 1.060,000 345.885 435.455 4 of 26 1.0105.2 1.0 1.5 I
Calcium 14 of 14 161.000 10 58Z.ooo 323.286. 393;707 Silver I
1011 113.000 10 449,000 216,On 379,498
22 of 26 6.32 10 219 61.4 86.5 26 of 26 7,63010989.000 74,5167 ::~~..,
Chromium 8 of 14 H 6,6.&0 88.6 14.& 215;9. Sodium 14.of14 13;050.&0 S06;OOO!I. IllSl.'.::.
7017 20.050 to 141.000 91,10 190,Q15
22 of 26 6.4 10 65.9 18.0 24.8 1 of 18 6.2 I
Cobalt 9~f-I4 4At.a.70.a 16.1 21;3: 'IbalJium ..
.H . ...
24 of 26 5.0 10 1.660 254 416 23 of 26 5.2 &0 297 47.3 79.7 I
Copper 9 of 14 1A7:.co .130 20.1 4&.6. V 8DIIiium l1.oU4 3.4 to .108 16.0.:. 31.~7
3 of7 4.8 to U 4.02 6.U Ion 7.3 I
26 of 26 692 &0 373.000 63.491 94.894 26 of 26 8.6 10 ..0.500 4,474 7,824
I
Iron 14 of 14 2.230.&0 132..000 26.431 45,449 ZUK: 13 of 14 21.110 463 . 91:1. 161.0
7of7 859 to 16.800 1,993 16.866 7or7 16.9 to 4.260 920 2.314
26 of 26 3.8 &0 18.800 1,876 3.475 I
LcaG 13b(14.... :t.5:to ,223H 4%3. 77:4
6016 I.G to 9.7 4.&5 8.6
INORGANIC CONTAMINANTS DETECTED IN GROUND WATER
Notes:
a CODt!lmin!ln~ detected in the shallow aquifer and information related to them appear as normal text in the table.
CODtamin!ln~ detected in intermediate and deep aquifers and information related to them appear as sbaded and bole
tex~ respectively
b A detection frequency of "1 of 26" implies that the cont!lmin!lnt was deteeted in 1 of the 26 samples collected;
a detection frequency of "3 of 26" implies that the cont!lmin~nt was detected in 3 of 26 samples collected;
and 50 on
c 95 percent upper confidence limit of the arithmetic mean concentration of a contaminant
A blank in the table indicates that the conf:lminant was either not detected or the deteCtion frequency was insufficiem
for calculation of the parameter represented by the blank
1-24
-------
TABLE 6
Detecllon Range of Detected 9'" Ddcc:tion Ringe of Dctectro 9S~
Conlaminanl' Frcquencyb Concenlralions Mean UCL" Contaminanl frequency Concentrations Mean UCL
(pgll) (PelL)
VOC. Naphthalene Ion 5
2 of 9 4.010 9.0 N-Nilrosodiphenylamine 1,0(9 6
Vinyl Chlnritlc 8 of 14 7.010 S9 12.0 20.S Phenanthrene 10(9 7
~
J of 7 6.0109.0 5.0 7.4 Anlhracene Ion 2
..
~ 'Ihylene Chloride 2 of 7 1.0 10 3.0 10(9 I
l illl...n Disulfide 20f9 71016 Di-n-Butylphlhalale i ot 14 1
2 of9 41045 Fluolanlhene I of 9 14
I} I>ichlllrllclhmc (I..'" II 2 of 14 5102$ Pyrene lof9 15
20(7 25 10 38 Bulylbenzylphlhalale 1 of 7 6
Carllon Tcirachillridc I of 14 2 Benzo(a)anlhracene 10f9 IS
2 of 9 4 III 23 Chryscne 1 of 9 14
IIl'Il/I:nc
I of 14 3 I of 9 31
.. Bis(2,clhylhellyl)phlha lale 1 of 1 61
'I'cirachhlll,clllcnc I of 14 1
Tolucne 30f9 42510 93 13 36 Benzo(b )nuoranlhene I of 9 24
Chlurobenlcne J of 9 3 to 9 J.J 5.8 Benzo(k)nuoranlhene I of 9 16
Elhylhcnzcnc 2 of 9 1810 140 Benzo(a)pyrcne I of 9 19
Tolal Xylcne! 2 IIf 9 29 to 340 Indeno( 1,2,3-cd)pyrenc 1 of 9 19
I SVOCs I. Dibenz(a,h)anlhracenc lof9 6
. Benzo(g,h,i)perylene lof9 21
I of 9 15
1'111'11111 I of 14 8
Pesticide.
4 MdhylJlhcnol I of 9 32 Heptachlor lof9 0.08
Ikn7.0ic Acid lof9 15 Dieldrin lof9 0.7
ORGANIC CONTAMINANTS DETECTED IN GROUND WATER
Notes:
;0 Conlaminanlsdelected in the shallow aquifer and information related tn them appear as normal text in the table. Contaminants detected in
intermediate ami deep aquifers ami infnrmatio" related to them appear as shaded and hold text, respectively.
I. A deteclion frequency of "2 of 9" implie:; Ihat the contaminant was detected in 2 of 9 samples collected; a detection frequency of "I of 14" implies
that the contaminant was detected in 1 of 14 samples collected, and so on.
,. q~ percenl upper confidence limit of arithmetic mean of detected concentralions
1-25
-------
battery reclama~ion activities of Mr. Brown. Sporadic detec~ion of
low concentra~ions of organic con~aminants may be associated with
former landfilling, an underground storage tank, or site operations.
The sources of organic contamination in the intermediate and deep
aquifers are not known. The contamina~ion may be associated with
former landfilling in the general area of the site, with other
industries adjoining the site, or some other unknown activity.
Lead is the primary contaminant in the groundwater in the shallow
aquifer (see Table 1-5). The detected concentrations of lead there
ranged from 3.8 micrograms per liter (~g/L) to 18,800 ~g/L, with 95
or more percent of concentrations [95 percent upper confidence level
on. arithmetic mean of concentrations (95% UCL) ] estimated to be less
than or equal to 3,4 75 ~g/L. Vinyl chloride is the primary
contaminant in the intermediate and deep aquifers (see Table 6) with
detected concentrations ranging from 7 to 59 ~g/L in the
intermediate aquifer and from 6 to 9 ~g/L in the deep aquifer.
Corresponding 95% UCLs are 12 and 5 ~g/L for the intermediate and
deep aquifers, respectively.
The extent of contamination in all three aquifers at the H. Brown
site is difficult to determine. High background concentrations of
lead and some other inorganic contaminants in groundwater in the
shallow aquifer make it difficult to determine the extent of
contamination in it. The lack of sufficient information about
background concentrations of organic contaminants prohibits the
determination of the extent of contamination in the intermediate and
deep aquifers. Therefore, it was assumed that the contaminated
groundwater lies only within portions of the aquifers that lie
underneath the contaminated' surface soil at the H. Brown Co.
property.
Surface Water and Sed~ents
The surface water and sediments in storm sewers in front of the H.
Brown property (on Turner Avenue and south of Keizer Equipment), the
drainage ditches, and the wetland area east of the H. Brown property
are also contaminated, primarily by lead. The impact of H. Brown on
the contamination of surface water and sediments in the storm sewer
on Turner Avenue is clearly demonstrated by the increased 95% UCLs
for lead concentrations there. The 95% UCLs for lead in water and
sediments in this sewer increased from 49. 8 ~gi Land 111 ~g /kg ,
respectively, at background locations to 391 ~g/L and 1520 ~g/kg,
respectively, at a location immediately downgradient of the H. Brown
site. However, the contamination of surface water and sediments in
the storm sewer south of the Keizer .Equipment is not solely
associated with H. Brown, because this sewer receives lead-
contaminated surface water and sediments from areas in addition to
H. Brown. The 95% UCL for' lead in surface water and sediments
contributed to thi~ sewer from the H. Brown property were 391 ~g/L
and 1520 ~g/kg, respectively, as compared to 2,700 ~g/L and 181
~g/kg, respectively, from areas west of the H. Brown property and
25
-------
10.4 ~g/L and 462 ~g/kg, respec~ively, from areas south of the H.
Brown property.
concentrations of lead in surface water and sediments in the wetland
area and the drainage ditches running through it" were much lower
than those detected in surface wa~er and sediments in storm sewers,
soil, and groundwater at t~e H. Brown site. H. Brown-related
contaminants other than lead were eit~~r detected at very low
concentrations or not detected. The RI r~port (PRC, 1991) should be
referred to for further details.
6.Summarv of site Risks
-Human Health Risks
Pursuant to the NCP a baseline risk assessment was performed using
analytical data generated during the RI. The baseline RA assumes no
corrective action will take place and that no site-use restrictions
or institutional controls such as fencing, groundwater use
restrictions or construction restrictions will be imposed. However,
for the future site scenarios, present ac~ion a't: the site and
current plans for development are considered. Potential exposure
pathways considered for this site under current and unrestricted
future site development scenarios were: .
1) Inhalation of soil as dust;
2) Direct contact with soil;
3) Ingestion of soil;
4) Direct contact with surface water;
5) Direct contact with sediments;
6) Incidental ingestion of sur~ace water; and,
7) Inqestion of qroundwater.
A smaller group of contaminants than all those actually detected at
the site was selected to focus the baseline risk assessment.
Approximately 50 contaminants were detected in air, soil,
groundwater, surface water, and sediments at the H. Brown site. As
part of the RA, these contaminants of concern (COCs) were selected
to focus the RA on contaminants associated with greatest potential
risk. The COCs were selected based on (1) potential human
exposure, (2) data evaluation and validation, (3) comparison of
naturally-occurring compounds to background concentrations, (4)
evaluation of quantification limits, and (5) availability of
toxicity data. The COCs selected for various media at the H. Brown
site are presented in Table 7.
26.
-------
I norgalU'
Volatile Orpnac::a
Pol~'yc::li, Aromauc:
HydnxamoftlcPA}b)
CbJorinated Peaicidca '"
Herbieiclca
M*.O~
... .:"']Ir.~"'",
CONT AMINANTS OF CONCERN IN SOn.. AIR. GROUND WATER.
SURFACE WATER. A!W SEDIMENTS
Surface Waler
~ &!:: Ground Water and SedimenlS
AlWlliDum Alumimlm Alumimlm AlIIIIIiaum
~y ....~y AnWDOny AI'IcIIK:
"'- AnaIic:: !\I'8mC Barium
Barium Barium Barium Cadmium
Beryllium Bcryllillm Beryllium Chromium
C..d,...Uft Cadmium Cadmium Coball
au-m ChraIIIium ChroIDIwD C~
C~ Copper Coball lraa
1-"" Lead Copper 1-""
M.....- M....-. 1.caA Mans-
Mcm:ury Mtm:ury Maap.- NieD!
NicIW NicUl Mm:ury Silwr
Sil.,. Silver Ni,Ul V 8II8Iiium
V8II88ium V.1I8Iiium SilY8l' Zinc
ZiIIG ZlDc V all80ium
Cyani1i8 Zinc
Cartxm di1u16dc Mcdlyleae dUoride Bc-
Elhylbcazalc Tol- Caru- ciisui6dc
Tol- Total zylCIICI ElhylbcazcDc
Tow zytellCl Tol-
ToW zylCIICI
ViDyI cAtaricie
Ac=..-b.'"'''' AC.al rrLtia- ~11111~
."l1l8I- Atn r~'''y6cDI BelaiD(a)aD&bnc8M
8emDCa)a111i1nc88 ,.- BealD(b)fIuoruIID8aD
8emDCb)~ Bc:aIDC...."'''- IDC BcmD(1t)fl~
8emDC1t)fll101UlllcDD 8caaI(b)thiocuIDcI8 Bcar.o(J,A.i)pcryleDc
8carD(J,A.i)pcry1c8 1IcaaI(k)~ Bc:aIDCa"ymID
8emDCa)pymID Bcar.o(J,b.a)payal ChryIaIe
Bil(2.a&bylbuyl) pblballla Bc:aIDCa~ Da-zta.b)lDlAraccac
aary.. CIIry.- Di:.HlulylpbdlUa&c
ca.-.au)alldlr8ccDc Dib8z(u)alllluaCCIIC FJ--.-
Dib8r.D1iaru Fluar8IID8DI lDd8I8M l.2.J-cd)pymIC
Di~lpbllWala ~ 2-MldayipbcDOl
Di..-&yll'lldl8ial& IDdI8I( 1.2.3-cd11lYftDC N,,*,".u.-
AllOr' -- 2.M..,..-.I- PbCII8IIIIUaIC
~ N~.- PymI8
~l.l.3-cci)pyn8 ~
2---~.'- Pyn8
2-Mad1y1ph8DDt
N~-
JIb .......
~
DUD Di8IdriD
Din' HepI8CIUar
N-N'~ DibIaIDiI- Bil(2,.clbylhnyt) pbtbalale
PII8ID ~ N-Na-o~'-y1amiDD
PCB DHHctyt PIIIIIaIaI8 PIIeDDI
2-M1daJipll8DDi
N-N'di '*' ~'ph "l'ylamiDD
Ph...
PCB
. Air iI COI'..""-18II5 by dua from 1110 aile
1-32
-------
Lead is the single mos~ i~por~an~ cae in
because of its ubiquitous presence in high
adverse health effects associated with
concen~ra~ions of lead.
all media a~ the site
concen~ra~ions and the
exposure to even low
For each exposure pathway evaluated, carcinogenic and
noncarcinogenic health risks were characterized for the reasonable
maximum exposure risk scenario, for current site conditions, and
for future site development. EPA assumed poten~ial future
residential use of site property based on Agency guidance and the
proximity of nearby residences. Table 8 lists the exposure
assump~ions used for each of the pathways evalua~ed.
Reference doses (RfDs) have been developed by U.S. EPA for
indica~ing 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 (e.g., the
amoun~ of a chemical ingested from contaminated drinking water) can
be comDared ~o the RfD. Rfds are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to accoun~ 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 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) (the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminan~s 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. Any Hazard Index value greater
than 1.0 suggests that a non-carcinogen potentially presents an
unacceptable health risk.
Table 9 lists the total Hazard Indices for the pathways
considered. As the table indicates the following scenarios'
Hazard Indexes exceed 1.0:
.
Direct cont~ct with soil by current and future on-site
workers (HI=24.9), future residential adults (29.2) and
children (63.9), and workers on an adjacent property
(13.9);
.
Ingestion of soil by current and future on-site. workers
(1.89), future residential adults (4.46) and ch~ldren
28
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PARAHIERS USED IN RISK EQUAI.OMS
_.- - n-
p"""'y Parameter On-site Off.slte Residential Adults Reslden"e' AdJecent Chltdren
\lorker Children chltdren "orker (Riverside
School)
I"halatlon of IR = Inhalation Rate (m'/hr) ].0 1.25 1.25 1.25 3.0 1.25
rllrJitive Du!;t
C = Chemical Concentration (mg/m') Chemical Speelf ie
- El = EXDosure lime (hours/dav) 8 ] 21, 21, 8 6
ED = EXDosure Duration (days) 6 975 121, 10 950 3.285 6.975 121,
BU = Body Ueight (kg) 70 25 10 25 70 25
1I = Lifetime (vears) 70 10 70 70 70 70
AI = Averaging Time (davs) 45 vears 4 vears ]0 vears 9 vears 45 vears 6 vears
Oi, 1" I COlltncl wi th C = Contaminant Concentrat ion Chemical Specific
Sui 1 (mg/kg)
cr = Conversion Factor (10. kg/mg) .
SA = Surface Area Avaitable for ],120 - 4,050 3,160 3.120 -
I Contact (cm')
AF = Soil to skin Adherence Factor 2.11 - 2.11 2.11 2.11 .
(fig/em')
ADS z Absorbtlon Factor 0.25. 0.10, 0.25, 0,10. 0.01 0.25, 0.10. 0.25,
(uni tlessHVOCs. SVOCs. 0,01 0.01 0.10.
.!norganics) . 0.01
EF = E xposlire r ,'equency 1~~ 11.0 140 155
(event/year)
ED = Exposure Duration (years) 45 . 30 9 45 .
BU = Body Ueight (kg) 70 - 10 25 70 -
1I = Lifetime (years) 70 - 70 10 70 .
---
""1"':1 inn of (lII,si 1(' CR = So i I Consumption Rate (g/day) 0.1 - 0.1 0.2 0.1
Sill I af e 50 i I!; ----
C = Concentretlon of Contominant Chemical Specific
in Soil (mg/kg) .
ED = Exposure Duration (days) 6.975 . 10 950 2 190 6915
DU = Dody Ueight (kg) 70 - 10 16 10 -
1I = Lifetime (yr) 10 - 70 70 70 -
AI = Averaging lime (days) 6 915 10 950 2.190 6915 -
--------- ----
lIi'l'l'l Conlact wilh C = Contaminant Concentration Chemical Spec! f ie
s,,, ';0' e \In''''' L-!mg/l)
I ---_.---
-------
_.__n_. -- - --
pathwy Parameter On. site Off.slt. Residential Adults Residential AdJuent Children
lIorker Children Children Yorker (Riverside
___n__._- School)
SA z Surface Area of Skin 11,600 19,400 11,600 - .
Contacted (cm2)
PC '" Dermal Permeablll ty (8.~ Ie 10 8.4 Ie 10 . 8.4 Ie 10' 8.4 )I 10 . - .
. cm/hr)
-!!. = Exposure Time (hours/day) 2.6 2.6 2.6 - .
EF = EJCposure Frequency 28 1~ 28 . -
(davs/vear)
EO = EIePosure Duration (vears) - 9 30 9 - -
-
CF = Conversion Factor (1 L/1000 -
cm') .
BII = Bodv Ueight (kg) 25 10 25 - .
L1 = Lifetime (years) 10 10 10 . -
AI = Averaging Time (days) - 9 years 30 years 9 vears . .
.._--"
II i I N-t Contact wi th C: Contaminant Concentration Chemcical Spec If Ic
S,.diml'nts (mg/kg)
CF = Converion Factor (108 kg/mg) , - '
SA = Surface Area Available for . 1,080 820 1,080 - -
Contact (em')
AF = Soi I to Skin Adherence ractor 2.11 2.11 2.11 -
(m9/cm')
ABS = Absorbtion factor (unltless) 0.25, 0.25, 0.10,0.01 0.25, -
.1vocr,. svocs. Inorganics) 0.10.0.01 0.10 0.01
H = Eleposure Frequency 28 14 28 .
(days/year)
EO = Exposure Duration (years) 9 30 9 . -
BU = Body Ueight (kg) 25 70 25 . -
LT = Lifetime (vears) - 10 10 70 - -
AI = Averaging Time (days) . 9 years 30 vea~s 9 vears . -
I lid denta I 'ngestion c.: Contaminant Concentration Chl'lllical Specific
"' Surface Uate,. (mg/l)
CR = Contact Rate (l/hr) . 0.05 0.05 0.05 - -
-I!~~osure T ime (hours/d~~. 2.6 2.6 2.6 - .
EF = Exposure Frequency 28 14 28 - -
(days/year)
EO = Exposure Duration (years) . 9 30 9 - -
-------
. """ ... .... v ,........ '" ~...... - - I
-
Pathwy Parameter On-!jite Off .alte Residential Adults Residential Adjacent Children
lIorker Children Children "orker (Riverside
-- School)
BII = Body weight (kg) - 25 70 25 . .
If = lifetime (vears) 70 70 70 . .
AJ = Averaging Jlme (days) . 9 vears 30 years 9 years . .
'/lqr.stion of Ground CR D lIater Consumption Rate 2 . 2 1 . .
\later (L/Day)
C D Contaminant Concentration chemical Spec If Ie
(rng/l)
ED = EKDOsure Duration (days) 11 700 . 10 950 3 2B5 - .
BII = Body lIelght (kg) 70 ' 70 25 . .
lJ = lifetime (vr) 70 , 70 70 . .
AJ = Averaging Time (days) 11,700 . 10,950 3.285 - .
-------
TABLE 9
SUMMARY OF RISKS- TO HUMANS FOR ALL EXPOSURE SCENARIOS
AND LAND USE CONDmONS AT SITE
S~I Sceaano Descripaon I La.na
Exposure I Receptors Use ELCRIt HI"
Number Pathway
la On-sue workers' 2.20 E-51> I 1.44 E-2
lb ChildreD m me pari: CFT' 3.14 E-9 2.31 E-S
Ie Tnh.l.rion of Adjaccn: sue worbrs' 2.37 E~ I 1.55 E-3
ld conbl.........M On-sice adu1&s- 4.31 E-5 4.23 E-2
FR-
Ie dlllt On-sice c:DildreD - 3.62 E-5 1.18 E-l
if CbildIea at school. school hour exposure 4.66 E-9 2.28 E-5 .
crf
Ig Chi1dreD at school. 24 hour exposure 2.72 E-8 3.57 E-3
2a Oa-sice workers'" CFI 1. 74 E-4 2.49 E+ 1
. 2b Direct coDlaCt Oa-sice adults." 1.36 E-4 2.92 E+l
FR
2e widl. mil Oa-sice children-" 8.93 E-S 6.39 E+ 1
2d I Zeaith 8Il1O pans wo~'. I CFI 2.7S E-3 1.39 E+ 1
3a I Oa-tnce workers'" I CFI 1.10 E-S 1.89 E+O
I
3b I Ingescion of Oa-Slce .awcs'., 1. 72 E-S 4.46 £+01
FR
3e soil Oa-sice children'" 3.02 E-S 3.90 £+ 1
3d Zeaith awo pans workers.' I CFI 6.04 £-5 1.05 £ +0
4a Direct COIII8CC Qa-sice adu1ta FR 2.12 E-9 4.35 £-2
4b wilb IUriace Oa-site children 2.13 E-9 1.10 £-1
CFI
4c W8IeI' Off-site childrm (Grmd River) 0.00 E+O 2.22 £-2
Sa Oa-lice adulu FR 2.39 E-7 6.65 £-2
Sb Direct COIII8CC Oa--ce children S.2S E-7 4.91 £-1
wim podi_n CFI
5c Off-site childrm (Grmd River, 0.00 E+O 2.51 E-2
6a !n..;til'ft,.1 Oa.-sice adults FR 2.14 E-9 1.07 E-2
6b iDgaIioa of On-sice childrm 3.59 E-9 5.99 E-2
CFI
6c suri8ce war. Off-sire c:hi1dnD (Grmd River. 0.00 E+O I 5.87 E-3
7d Oa-sire worars'. , FII 1.67 E-4 3.86 £+0
7e ms-u- of OD-site adulSa-" 3.12 E-4 1.08 E+ 1
groaad W8I8' FR
7f OD-sire c:hildrm', , 1.31 E-4 1.52 E+ 1
. Does Dot include risk from expoIUI'e 10 1- IlIA P AHa at the site
b Exceaa lifelime C8IIC8I' risk (ELCR) C Hamd iDdmt (HI)
4 Currem ami fubIn iDciu8tIia1 (CFl) use of the site - FUbIr'e residcDtia1 (FR) use of the site
r Currm& iDduIIrial (Cl) use of the site I: Future industrial (Ft) use of the sice
b 82.20 E.S8 imp1ia 2.20 x 1~; 82.20 E+08 iDlDiiel2_20: 82.20 E-S8 implies 2.20]1: 1O's, aud so OD
. Exposure sc:eII8rio with excess lifetime cmcer nsi: (ELCR) in excess of 1.oo:lt lQ'6
I Exposure 5(""""';0 wilb hazard index (HI) more WID 1.0
1-39
-------
(39.0), and current and future workers on an adjacen~
property (1.05); and,
.
Inges~ion of groundwater by future on-site workers
(3.86) and future residential adults (10.8) and
children (15.2). .
Cancer potency factors (CPFs) have been developed by u.s. EPA's
Carcinogenic Assessment Group for estima~ing excess lifetime
cancer risks associated with exposure to potentially. carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)-I,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors 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 (e.g., to account for the use of animal data to predict
effec~s on humans).
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor for each contaminant
of concern. These risks are probabilities that are generally
expressed in scientific notation (e.g. lxlO~ or lE-6). An excess
lifetime cancer risk of lX10~ 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. The u.s. EPA generally attempts to reduce
the excess lifetime cancer risk posed by a Superfund sites to a
range of 1X10~ to lxlO~ (1 in 10,000 to 1 in 1 million), with an
emphasis on the lower end of the scale (lX10~).
Table 9 indicate the excess lifetime cancer risks for different
scenarios. As the table shows several scenarios exceed the
acceptable Excess Lifetime Cancer Risks as described above. The
following bullets summarize the major carcinogenic risks at the
site:
.
Direct contact with soils by off-site workersl (3X10~),
future residential adults 1xlO~.
IAs defined in the RI and FS, "off-site" means the area
outside of the originally fenced portion of the H. Brown company,
Inc. property. It should not be construed to mean "off-site" as
referred to in the NCP.
33
-------
.
Ingestion of groundwater by
residential adults Jx10~.
Evaluation of Potential Health Risks from Lead
In addition to the above analysis, the U.S. EPA Biokinetic Uptake
Model (Lead Model)was used in the risk asseS3ment to approximate
blood-lead (PbB) levels in children exposed ~~ lead contamination
on or from the H. Brown site. This Lead Model was developed by
U.s. EPA because the noncarcinogenic effects of lead in infants
and young children do not appear to exhibit a threshold, i.e.
there is no evidence of a dose or exposure level of lead below
which no adverse effects are observed. An RfD is generally based
on .no observable effect level (NOEL). Because there may be no
" NOEL for some of the adverse neurobehavioral effects of lead, an
RfD may not be appropriate for evalua~ing effects of lead.
PbB levels calculated using the Lead Model were compared with a
10 microgram-per-decaliter (~g/dl) benchmark or cutoff value.
Levels equal to, or greater than this may produce adverse effects
which may be sufficiently significant to warran~ regulatory
action. This is considered a level of concern and should not to
be confused with a threshold, because adverse effects may be
associated with levels less than 10 ~g/dl.
Two different analyses were performed using the Lead Model. The
first considered the contribution of lead on the H. Brown site to
air concentrations of lead at the Riverside Public School
(located across the Grand River, approximately two blocks away)
and the resulting effect on PbB in a population of children
living near the school. The other analysis considered the effect
of site lead concentrations on a population of children living on
the site, because there is the potential for future residential
use of this property.
When the default parameters are used in the model--that is, when
only typical concentrations of lead are assumed with no
contribution from a significant source such as the H. Brown site
(0.200 ~q lead/m3)-- 6 in 10,000 children would be expected to
exhibit PbB above the 10 ~g/dl cut-off level. .
The air" lead concentrations measured on-site (7.4 ~g lead/m3)
would put nearly 1 in 1,000 children at risk of exhibiting PbB
levels above the cut-off.
If the lead concentrations measured in all on-site media (soil,
air, and groundwater) are used in place of the model default
parameters, 100% of the children living on-site would be expected
to achieve PbB above the 10 ~g/dl cut-off level. It should be
noted in this case that at the high concentrations of lead
measured on-site, it is actually not possible to accurately
34
-------
predict the resulting PbB levels. Because the red blood cells
read a sa~uration concentration at high intake levels, ~he
predicted levels may not be physically possible.
In summary, children living in the vicinity of the Riverside
Public School may not be at significantly greater risk of
aChieving PbB levels above the 10 ~g/dl cut-off as a result of
wind-borne dispersion of lead from the H. Brown site. Children
living on-site would, however, be at significantly greater risk
based on measured air concentrations alone.
-Environmental Risks
A qualitative review of risks posed to wildlife by contaminated
. materials from the site was performed as part of the
investigation. The pathways evaluated included ingestion and
direct contact with surface water; direct contact with sediments;
and direct contact with, and ingestion and inhalation of surface
soil. Due to the high levels and na~ure of the contaminants
found at the H. Brown site, wildlife having repea~ed and
prolonged exposure ~o contaminated materials may be at risk in
each of the pathways examined. Concentrations of lead in the
river are not expected to result in overt toxicity to aquatic or
other species, with the possible exception of potentially
localized effects just downstream of the Cogswell drain outfall.
Elevated concentrations of lead, and the associated toxic metals
antimony and cadmium, could potentially produce toxic effects in
any aquatic species that could inhaDit the wetland. Because the
wetland area is isolated, ephemeral, located' within a larger
industrial area, and is separated from the river by the highway,
the wildlife population density is this area is currently very
low. The wetland area is not expected to be used for
agricultural purposes. These factors will help to limit the
effects of contaminant concentrations on an ecosystem scale. If
wildlife were to come into contact with site surface water or
sediments, concentrations of lead and other site contaminants are
likely to contribute siqnificantly to the heavy metal body
burdens of resident species, with potentially adverse effects.
Based upon the risks summarized above, actual or threatened
releases of hazardous substances from this site, if not addressed
by implementation of the response action selected by this ROD may
present an imminent and substantial endangerment to public
health, welfare, or the environment, primarily through use of
contaminated groundwater. The site may also pose risks to non-
human receptors from contaminants released from the site into
surface waters and the wetlands.
35
-------
7. Rationale for Further Action
Actual or threatened releases of hazardous substances from this
site, if no~ addressed by implemen~ation of the response action
selec~ed by this ROD, may present an ~mminent and substantial
endangerment to public health, welfare, or the environment.
Therefore, based on ~he findings in the RI repcrt and the
discussion above, a Feasibility study (FS) was performed to focus
the development of alternatives to addr~ss the threats at the
site. The FS report d~cuments the evaluation of the magnitude of
site risks, site-speci:~c applicable or relevant and appropriate
requirements, and the requirements of CERCLA and the NCP in the
derivation of remedial alternatives for the H. Brown site.
8 .
Description of Alternatives
The ten cleanup alternatives evaluated for the H. Brown site are
presen~ed below. More detailed information on these cleanup
alterna~ives is available in the Feasibility Study Report.
Ccmmon Elements
With the exception of Alternative 1, the remaining nine
alternatives considered for the H. Brown site include a number of
common elements:
.
Demolishing buildings -- Demolition and removal of two
ccntaminated buildings would be required because the soil
under the buildings is expected to be contaminated. These
materials will either be disposed of on-site, or sent to an
appropriate off-site landfill.
.
consolidating surface soil -- contaminated surface soil
would be moved to the area where subsurface soil cleanup
would be required.
.
COllecting, treating, discharging and monitoring groundwater
-- contaminated groundwater from the shallow aquifer would
be collected through a series of underground drainage
ditches, treated to meet state and federal water quality
standards, and then discharged to the Grand River.
Treatment will include aeration, filtration, carbon
adsorption, and ion exchange. Residue from the treatment
process will be disposed of off-site in an appropriate
facility. It is estimated that treatment of the shallow
groundwater should take one year to complete. Additional
wells would be installed to determine the nature and extent
of contamination of the intermediate and deep aquifers and
to monitor the effectiveness of the remedy.
36
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.
Collec~ing, trea~ing, and disposing of surface wa~er and
5edimen~s from the we~lands, sewer sys~em and drainage
ditches -- Surface wa~er from the sewer system, we~lands,
and drainage ditches would be treated and discharged along
with groundwater. Contaminated sediments would be ~reated
and disposed along with the con~aminated soil.
.
Restricting site use -- Restrictions would be placed on the
use of the site and the groundwa~er during and after cleanup
activities.
.
Restricting site access -- Maintain a fence around the site
to limit access.
Alternative 1:
No Action
The Superfund program requires that a no-action alternative be
considered at every site. It is used for comparison during the
evaluation of the other alternatives. Under this alternative, no
ac~ion would be taken to cleanup the site. This alternative does
include a review every five years to determine the need for
additional action.
Capital Cost: .
Annual Operation and Maintenance
Present Worth (30 Year):
Time to Implement:
(O&M) cost:
NONE
NONE
NONE
NONE
Alternative 7: soil containment, Groundwater Treatment, and
Drainaqe Remediation .
Under this alternative, soil requiring remediation would be
consolidated on-site, surrounded by a containmen~ wall to prevent
migration of groundwater through the waste, and then covered with
a multi-component clay cap which would be designed to comply with
state and federal hazardous waste regulations. The cap would
consist of a three foot thick layer of compacted clay, a layer of
compacted soil to protect the cap from frost damage, a drainaqe
layer, and a one foot thick veqetated layer. A fence would be
constructed around the area to prevent access.
capital Cost:
Annual operation and Maintenance
Present Worth (30 Year):
Time to Implement:
(O&M) Cost:
$4,800,000
$220,000
$6,900,000
9 - 18 Months
Alternative 8: pilot Scale Treatment and containment, Groundwater
Treatment and Drainaqe Remediation
As part of this alternative a soil treatment system, which uses
an acid leaching process to remove lead from the soil, would be
37
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tested in pilot-scale equipment. This process involves washing
the contaminated soil with an acid solution, precipitating out
the dissolved lead and then sending the lead to a smelter for
recovery. If it is effective, full-scale treatment of the soil
under Alternative 10 or 12 would take place. If the treatment
process is ineffective a containment wall would be constructed
surrounding the contaminated subsurface soil. A multi-layer cap
meeting state and federal ARARs for hazardous waste would be
placed on the site to prevent exposure to contaminated soil and
minimize the infiltration of precipitation through waste and into
the groundwater. The cap would consist of a three foot thick
layer of compacted clay, a layer of compacted soil to protect the
cap from frost damage, a drainage layer, and a one foot thick
vegetated layer. A fence would be constructed around the cap to
prevent access to the area.
For purposes of evaluating this alternative it was assumed that
the soil treatment system was ineffective and the contaminated
soil is to be contained on-site.
capital Cost:
O&M Cost:
Present Worth:
Time to Implement
$5,100,000
$220,000
$7,200,000
9-18 Months
Alternative 9: soil Disposal, Groundwater Treatment, and
Drainage Reaediation
In addition to the common activities discussed above, this
alternative involves transporting soil contaminated above 500 ppm
of lead (approximately 180,000 cy) to an approved off-site
hazardous waste landfill. The excavated areas would be
backfilled with clean soil from off-site sources.
capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$41,000,000
$180,000
$41,000,000
18-24 Months
Alternative 10: pilot and Full-Scale Soil and Groundwater
Treatment and Drainage Remediation
As part of this alternative, some soil from the site would be
treated by the acid-leaching process on a pilot-scale basis, as
discussed in Alternative 8. Assuming the soil treatment system
is effective all soil requiring remediation (above 500 ppm of .
lead, approximately 180,000 cy) would be treated by the acid-
leaching process. The treated soil would be backfilled on-site
and covered with a clay cap designed to comply with state and
federal solid waste regulations. The cap would consist of two
feet of compacted clay, a drainage layer, a layer of compacted
soil to protect the cap from frost damage, and a vegetated layer.
38
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This cap would preven~ exposure to any residual con~amina~ion and
reduce infiltration of precipitation into the soil. A fence
would be cons~ruc~ed around the cap ~o prevent access to the
site.
capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$22,000,000
$220,000
$24,000,000
2-4 Years
Alternative 11: soil Smelting and Disposal, Groundwater
Treatment, and Drainage Remediation
In addition to the common elements discussed above, this
alternative would include excavation of all of the contaminated
soil. soil with lead concentrations of more than 20,000 ppm of
lead and PCB concentrations of less than 1.00 ppm (approximately
50,000 cubic yards) would be sent to a lead smelter to recover
the lead.. The remaining soil would be disposed of, off-site, in
an approved hazardous waste landfill.
Capital Cost:
Annual O&M Cost:
Present Worth:
. Time to Implement:
$36,000,000
$20,000
$36,000,000
18-24 Months
Alternative 12: soil smeltinq and Treatment, Groundwater
Treatment, and Drainaqe Remediation
This alternative is based upon the assumption that the acid-
leaching process discussed in Alternative 8 cannot effectively
treat soil contaminated with lead above a certain concentration.
Initially, some soil will be treated in a pilot-scale test of the
process to determine the range of concentration that could be
cost-effectively treated. If the process is found to be
completely ineffective, one of the other proposed alternatives
would be implemented. Cost estimates were based upon the
assumption that soil above 20,000 ppm lead (approximately 50,000
cy) could not be treated by the acid-leaching process and would
be sent to a smelter for lead recovery. Excavated areas would be
backfilled with clean soil. The site would then be covered with
a clay cap that meets state and federal standards for solid waste
landfill caps. The cap would consist of two feet of compacted.
clay, a drainage layer, a layer of compacted soil to protect the
cap from frost damage, and a vegetated layer. This cap would
prevent exposure to any residual contamination and reduce
infiltration of precipitation into the soil. A fence would be
constructed around the cap to prevent access to the site.'
39
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capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$23,000,000
$220,000
$25,000,000
2-4 Years
Alternative 13: 50i1 smelting ana containment, Grounawater
Treatment, ana Drainage Remediation
Under this alternative, all soil having more than 20,000 ppm of
lead (approximately 50,000 cy) would be excavated and sent toa
smelter to recover the lead. The excavated area would be
backfilled with clean soil from off-site sources. A cap would
be constructed to cover, ana a containment wall constructed to
surround, the remaining soil exceeding clean-up levels. A multi-
layer cap meeting state and federal ARARs for'hazardous waste
would be. placed on the site to prevent exposure to contaminated
soil and minimize the infiltration of precipitation through waste
and into the groundwater. The cap would consist of a three foot
thick layer of compacted clay, a layer of compacted soil to
protec~ the cap from frost damage, a drainage layer, and a one
foot thick vegetated layer. This cap would prevent contact with
the site soil and minimize infiltration of precipitation through
the waste. A fence would be constructed around the cap to
prevent access to the area.
Capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$9,600,000
$220,000
$12,000,000
2-3 Years
Alternative 14: soil smelting, Solidification ana Containment,
Groundwater Treatment ana Drainage Remediation
Under this alternative, all soil having more than 20,000 ppm of
lead (approximately 50,000 cy) would be excavated and sent to a
smelter to recover the lead. soil having less than 20,000 ppm
but more than 500 ppm of lead (approximately 130,000 cy) would be
solidified in place in a cement-like form. The excavated area
would be backfilled with clean soil from an off-site source,
surrounded by a containment wall, apd then covered with a
hazardous waste cap. The cap would consist of a three foot thick
layer of compacted clay, a layer of compacted soil to protect the.
cap from frost damage, a drainage layer, and a one foot thick
vegetated layer. The purpose of the cap is to prevent contact
with, and minimize infiltration of precipitation through the
solidified soil. The cap would also prevent damage to the
solidified soils from frost and wet-dry cycles.
capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$16,000,000
$220,000
$18,000,000
2-3 Years
40
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Alternative 15: solidification and containment of Soil,
Groundwater Treatment,. and Drainage Remediation
Under this alternative, all soil requiring remediation
(approximately 180,000 cy) would be solidified, in place, to
cement-like form. The solidified soil would be surrounded by a
containment wall and covered with a hazardous waste cap. The cap
would consist of a three foot thick layer of compacted clay, a
layer of compacted soil to protect the cap from frost damage, a
drainage layer, and a one foot thick vegetated layer. The
purpose of the cap would be to prevent contact with, and
infiltration of precipitation through, the solidified soil. The
cap would also prevent damage to the solidified soils from frost
and continual wet-dry cycles.
Capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$13,000,000
$220,000
$15,000,000
2-3 Years
9.
Comparative Analvsis of Alternatives:
The Nine Criteria
The followinq nine criteria, outlined in the NCP at 40 CFR
300.430(e)(9) (iii), were used to compare the alternatives and to
determine the most app+opriate alternative for remediation of the
soils and groundwater contamination that is protective of human
health and the environment, attains applicable or relevant and
appropriate requirements (ARARs), is cost-eftective and
represents the best balance among the evaluating criteria. An
alternative providing the "best balance" of trade-offs, with
respect to the nine criteria, is determined from this evaluation.
The Nine criteria
- Threshold criteria:
Overall Protection of Human Health and the Environment addresses
whether a remedy provides adequate protection and describes. how
risks posed by each exposure pathway are eliminated, reduced, or
controlled through treatment, engineering controls, or
institutional controls.
Because the no action alternative does not provide adequate
protection to human health and the environment, the no action
alternative is not available for selection and will not be
discussed through the remainder of this analysis.
All of the remaining alternatives offer protection to human
health from risks related to exposure to contaminated soil or
41
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groundwater at the site. All of the alterna~ives also protect
the environment. Alternatives that would remove all soil
requiring remediation from the site, such as Alternatives 9 and
11, would be protective of the environment for the long-term.
Alternatives 14 and 15, which would solidify/stabilize all, or
some, of the soil requiring remediation, pose so~e risk over the
long-term if the solidified/stabilized matrix lc~as its integrity
and contaminants leach to the groundwater. Alternatives 7, 8 and
13, which leave all or some soil requiring remediation at the
site offer less effectiveness because contaminants left in the
soil at the site may leach over time into the groundwater. Such
leaching would contaminate the groundwater that may seep into the
Grand River and may affect aquatic life.
compliance with ARARs addresses how the proposed alternative
complies with all applicable or relevant and appropriate
requirements of federal and more stringent state environmental
laws (ARARs). It also considers how the alternatives comply with
advisories, criteria, or other guidance to be considered (TBCs)
that do not have the status of laws, but that the U.S. EPA and
the State have agreed are "appropriate" for protectiveness or to
carry out certain actions or requirements, and/or provide grounds
for invoking a waiver.
A summary of identified ARARs for the alternatives is included in
Section 11 below. Only ARARs necessary for on-sit~ remedial
activities have bee~ identified. The selected remedy will be
designed to meet all applicable or relevant and appropriate
requirements of federal and more stringent state environmental
laws. In some instances, rules cited contain both ~ubstantive
and procedural or administrative requirements. Only the
substantive requirements are ARAR for the purpose of on-site
activities. Examples of administrative or procedural
requirements which are not considered ARAR include, but are not
limited to, state approval requirements. reporting requirements,
permit application requirements, and ~=ovisions in rules or
statutes that list factors to be considered in selecting a
remedial action alternative .but do not set forth a "standard or
level of control" for that action to meet.
All alternatives would comply with all ARARs for contaminated
soil, groundwater, and air at the site. The major groundwater
ARARs include the requirements of the federal Safe Drinking Water
and Clean Water Acts and state Acts 245 and 307. Alternatives 7,
8, 13, 14, and 15 wo~ comply with state Act 64 and federal
Resource conservation~~nd Recovery Act (RCRA) requirements for
capping of the waste. Alternatives 10 and 12 would comply with
state Act 641 and RCRA requirements for capping. Those
alternatives requiring off-si~e disposal or treatment of waste,
or treatment by the acid washing method, would comply with RCRA
Land Disposal Restrictions. Each of the alternatives requires
excavation of sediments from the adjacent wetlands; therefore,
42
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each alterna~ive will have to mee~ the reauirements of the
Goemaere-Anderson Wetlands Protec~ion Act.of Michigan, and
Execu~ive Orders 11990 and 11988 (We~lands Pro~ec~ion and
Floodplain Management, respectively). In addition, each of the
alternatives requires excavation, construction, or trea~ment
activities which may result in the release of contaminants into
the air. Each alterna~ive must, therefore, comply with the air
quality standards in the Clean Air Ac~ and the Michigan Air
Pollution Act.
Long-Term Effectiveness and Permanence refers to the'magnitude of
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time, once
cleanup standards have been met.
Alternatives 9, 10, 11, and 12 would either remove or treat, and
Alternative 15 would solidify/stabilize and completely contain,
all soil requiring remediation. Therefore, these alternatives
would be most effective for the long ~erm. The remediation of
soil by Alternatives 9 through 12 would be permanent, whereas the
remediation by Alternatives 14 and 15 would be effective for a
long, but unknown period of time. The uncer~ain permanence of
remediation under these alternatives results from the possible
disintegration of the solidified/stabilized matrix over time.
Assuming the most effective mixture of solidifying/stabilizing
agents and waste is selected through studies, and proper
construction of the containment components of the remedy is
performed, the possibility of Alternatives 14 and 15 losing their
integrity is remote.
Alternatives 7 and 8 would leave all contaminated soil on-site.
Alternative 13 would leave all but the most cdntaminated soil on-
site, sending the most contaminated to a smelter. The soil left
on-site would have the potential to contaminate the groundwater
because of the possible leaching of contaminants from the soil.
Each of these alternatives would remain effective as long as the
integrity of the cap and containment wall is maintained.
Assuming good construction quality of the containment components,
the possibility of them losing their integrity over time is
remote. .
Reduction of Tozicity, Mobility, or volume of Contaminants
Through Treatment is the anticipated performance of the treatment
technologies a remedy may employ.
All alternatives would reduce toxicity, mobility, or volume of
contaminants in the groundwater by removing and treating the
contaminants. The maximum reduction is offered by Alternatives
10, 12,14 and 15, because each would treat or solidify/stabilize
the contaminated soil. Alternatives 11 and 13 would partially
reduce the toxicity, mobility, and volume of contaminants in the
soil, because only a portion of the contaminated soil would be
43
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treated at a smelter. Alternatives 14 and 15 would not reduce
the toxicity, but they would significantly reduce the mobility of
the contaminants. Under alternative 15, the volume would
actually increase because of the solidification/stabilization
process. Neither Alternative 7 or 8 meets this criterion because
neither involves treatment of the soil.
Short-Term Effectiveness refers to the speed with which:he
remedy achieves protection, as well the remedy's potential to
create adverse impacts on human health and the environment that
may result during the construction and implementation period.
All of the alternatives would pose some short-term risks during
. implementation. Alternative 7 is expected to have the most
significant short-term risks because of the difficulty associated
with constructing the containment walls. This construction
involves welding synthetic sheets together inside a trench.
Alternative 8 is expected to have the least significant risk,
because it only involves the excavation of soil to construct
subsurface drains and removal of soil. The other alternatives
would have nearly tha~same level of short-term risks.
Those alternatives that are most quickly implemented and based
upon proven and easily available technologies would provide
greater short-term effectiveness. Alternatives 8, 10, and 12
require pilot-scale testing befere implementing the rest of the
alterna~ive; they would have a relatively low degree of short-
term effectiveness. Alternatives 7, 8, 14, and 15 would have the
greatest short-term effectiveness because t~ey involve proven and
easily available containment or solidification/stabilization
technologies. Alternatives 9 and 11, which require disposal or
treatment in an off-site facility, would deliver only a moderate
degree of short-term effectiveness because of the possibility in
delays due to capacity or regulatory problems.
On-site workers involved with the excavation and/or treatment of
soil, in each of the alternatives, would be exposed to
contaminated soil and dust. Some off-site individuals may also
be exposed to the contaminated dust. Risks from such exposures
would be minimized ;by providing protective equipment to workers
and taking dust control me~sures.
Implementability is the technical and administrative feasibility
of a remedy, including the availabil~~y of materials and services
needed to implement the chosen solution.
Alternatives 7 and 15 would be the easiest to implement because
vendors are readily available and do not require pilot-scale
studies or rely on off-site treatment or disposal. Alternatives
8, 10 and 12 would be more difficult to implement than other
alternatives, primarily because the equipment for treating the
soil would have to be originally.designed and fabricated, or
44
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pilot-scale tes~ing would be required to determine whether full-
scale treatmen~ is possible. Alterna~ives 9, 11, 12, 13, and 14
would be somewhat difficult to implement, because of the need for
regulatory determination of compliance for the receiving facility
and the potential for capacity problems as they involve
constructing a containment wall and a cap.
Cost
Cost includes estimated capital, operation and maintenance, and
present net worth costs. Table 14 lists the cost for each of the
alternatives.
'l'a))le 1 0
Estimated cost
1 NONE NONE NONE
7 4,800,000 220,000 6,900,000
8 5,100,000 .220,000 7,200,000
9 41,000,000 180,000 41,000,000
10 22,000,000 220,000 24,000,000
11 36,000,000 20,000 36,000,000
12 23,000,000 220,000 25,000,000
13 9,600,000 220,000 12,000,000
14 16,000,000 220,000 18,000,000
15 13,000,000 220,000 15,000,000
-Modifying criteria:
state Acceptance indicates whether, based on its review of the
RIfFS and Proposed Plan, the State concurs with, opposes, or has
no comment on the preferred alternative.
The State of Michigan has assisted in the development and review
of the Administrative Record. The state1s position regarding the
selected alternative is discussed in its concurrence letter. The
State is expected to concur on the remedy.
community Acceptance The specific comments received and u.s.
EPAls responses are outlined in the attached Responsiveness
summary.
45
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1Q. Selected Remedv
Based upon considerations of the requirements of CERCLA, the NCP
and balancing of the nine criteria, ~he u.S. EPA has determined
that Alternative 15, Solidification and containment of Soil,
Groundwater Treatment, and Drainage Remediation, is the most
appropriate for the H. Brown site.
The components of the selected remedy are as follows:
1. Access Restrictions
a. Temporary and/or permanent fences and signs will be
erected and maintained around the site and
pretreatment/treatment systems as specified by the u.s. EPA.
b. Pursuant to Michigan Act 307, institutional controls
including, but not limited to, notice to future property
owners of contamination at the site, deed restrictions to
regulate the development of the H. Brown site, and groundwater
use restrictions in the areas that have contaminated
groundwater will be sought. Groundwater use restrictions may
be rescinded after remediation standards are met and proven to
be maintained.
The purpose of these restrictions is to prevent exposure to
site contaminants, prevent erosion of the cap, and provide
security for the remedial action equipment.
2.
site Monitoring
Groundwater and surface water monitorina. Groundwater
aquifers and surface waters and sediments in the site vicinity
will be sampled and analyzed periodically to monitor chemical
contaminant levels during site remediation.
Monitoring shall include shallow, intermediate, and bedrock
aquifers beneath the site. sampling and analysis will
include existing groundwater monitoring wells and additional
groundwater monitoring wells.
3.
Building Demolition/Decontamination
Buildings located on the site above soil requiring remediation
will be demolished and disposed of on-site or in an
appropriate off-site landfill. Buildings not requiring
demolition shall be properly decontaminated to meet state or
federal standards. All buildings will also be tested to
assure that they have been properly decontaminated.
46
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4.
. Soil Consolidation
Contaminated soils exceeding cleanup standards will be
consolidated on-site to the area where soil
solidification/stabilization will be performed. This area
will be located above the clay confining layer. Testing will
be conducted to assure that all soil requiring treatment has
been consolidated to the area referred to above. Excavated
areas will be backfilled with clean soil from off-site
sources.
5.
In Situ Solidification/stabilization of Contaminated
Soils/Sediments
All soils/sediments exceeding cleanup standards will be
solidified/stabilized by an in situ
sOlidification/stabilization process, to reduce the mobility
of contaminants in the soil. EPA expects that the
sOlidified/stabilized mass will meet Toxicity Characteristic
Leaching Procedure (TCLP) standards, as specified in 40 CFR
Part 268, Appendix I and for each extraction of the Multiple
Extraction Procedure (MEP), ("Test Methods for Evaluating
Solid Waste, Physical/Chemical Methods", Method 1320 SW-846).
Testing will be performed to assure that the most protective
solidifying/staDilizing agent is used to achieve maximum lonq-
term structural and chemical integrity of the
solidified/stabilized matrix. Once treatment is complete, EPA
expects that the waste will no longer be RCRA
characteristically hazardous.
6.
Containment Wall
A containment wall will be constructed around the treated
soil/sediment. The wall will extend vertically from the
ground surface down to the clay confining layer beneath the
treated soil so as to prevent groundwater from coming in
contact with the treated mass. The wall will have a
permeability equal to, or less than, the treated mass.
sampling and testing of the containment wall will be performed
to ensure that the wall will maintain adequate impermeability
over time to protect the treated mass from groundwater
infiltration.
7.
cap construction
A cap will be constructed on the site so that it complies with
Michigan Act 64. The cap will consist of a 12 inch vegetative
soil layer, > 12 inch drainage layer, 3 feet of compacted.
clay, and maximum and minimum slope.
47
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A Michigan Act 64 cap is considered protective r:= this site,
because it would provide protection against direc~ contact
with waste at the site, act as a significant barrier to
infiltration of precipitation, and protect the
solidified/stabilized mass from damaged due to freeze-thaw
conditions. The waste is in direct hydraulic connection with
the shallow groundwater.
8.
Groundwater/Surface Water Collection, Treatment and
Discharge
Both contaminated groundwater and surface water will be
collected, treated, and discharged to the on-site surface
waters. It is anticipated that discharge to the Turner Avenue
sewer will be feasible. If it is not feasible, treated
. liquids will be discharged directly to the Grand River. A
groundwater extraction/collection system will be installed to
collect for treatment the contaminated groundwater in the
shallow aquifer beneath the site. Collected groundwater and
surface water will be pumped to an aboveground storage tank
before being treated and then discharged to the Grand River.
Groundwater will be extracted until the remediation standards
of Table 14 are achieved at the point of compliance. The
point of compliance for the groundwater remediation standards
is the boundary of the final landfill cover. Contaminated
groundwater and surface water will be extracted until the
cleanup standards listed in table 14 are met. Extracted
groundwater will be treated on-site through aeration,
filtration, carbon adsorption, and ion exchange to meet NPDES
permit standards prior to discharge to the Grand River. Such
a treatment system will be required to meet the substantive
requirements under, but not limited to the Clean Air Act,
Clean Water Act, RCRA, and any more stringent state standards.
If feasible, The treated liquids would then be discharged to
the Turner Avenue sewer. The discharge would comply with the
substantive requirements of an NPDES permit. If discharge to
the sewer is not feasible, treated liquids will be discharged
directly to the Grand River, and would comply with all NPDES
permitting requirements.
Additional studies on the nature and extent of the groundwater
contamination will be performed during the Remedial Design
phase of the project. The purpose of these studies will be to
further define background levels in the shallow aquifer and to
more fully define the nature and extent of contamination in
the intermediate and bedrock aquifers beneath the site. The
results of these studies will be used along with information
from the Remedial Investigation to determine whether the site
is the source of the contaminants in the intermediate or
bedrock aquifers and if contaminant levels exceed that are
protective of human health and the environment. If those
contaminant levels are determined to be site related and found
48
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no~ to be pro~ec~ive in either or the aquifers, alternatives
for remediation will be analyzed.
The goal of this remedial action is to restore the groundwater
in the upper aquifer to its beneficial use and to protect
agains~ curren~ and future exposures. Specifically, the
groundwater will be collected un~il the cleanup standards are
met a~ the point of compliance.
Based upon information obtained during the RI and FS, the u.s.
EPA believes that the selected remedy will meet these goals.
It may become apparent during implementation or operation of
the groundwater extraction/collection system, that contaminant
levels cease to decline and are remaining constant at levels
higher than the remediation standards in Table 14 over some
portion of the contaminant plume. In such a case, or if other
circumstances necessitate the system performance standards,
the system design, and/or the remedy may be reevaluated.
9.
Surface Water and Sediments
Surface water and sediments from the wetlands adjacent to the
site, the drainage ditches leading to the Grand River, and the
sewer system running along Turner Avenue, that exceed the
cleanup standards in Tables 12 and 14 will be collected and
treated along with the consolidated soils and contaminated
groundwater as discussed above.
10.
other provisions
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 will not violate the National Ambient Air
Quality standard for particulate matter smaller than 10
microns (PM-10). potential runoff, silting, and sedimentation
problems from construction will be mitigated to comply with
Michigan Acts including Public Acts 203 (1979), 346 (1972) and
347 (1972) for wetland protection, inland lakes and streams,
and soil erosion and sedimentation control, respectively.
Because excavation and/or filling in the wetland area adjacent
to the site will take place the selected remedy will comply
with the Wetland Management Executive order 11990, and
MiChigan's Goemnere-Anderson Wetland Protection Act, Act 20~
of 1979.
The solidified/stabilized waste will continue to be contained
on-site. Because this solidified/stabilized waste is the
source of the contaminants, hazardous constituents will
therefore remain at the site. A review of site conditions
will be conducted every five years after the initiation of the
remedial action.
49
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11.
Statutorv Determinations
The selected remedy must satisfy the requirements of Section 121
(a) through (f) of CERCLA to:
Protect human health and the environment;
Comply with ARARs or justify a waiver;
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 principle element of the remedy.
The implementation of the selected alternative at the H. Brown
Co., Inc. site satisfies these requirements of CERCLA Section 121
as follows:
1.
2 .
3 .
4.
a.
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 soil and groundwater.
Solidification/stabilization and containment of all soil
exceeding cleanup standards will permanently reduce and
control existing and potential risks, through treatment and
engineering contols. Extraction and treatment of contaminated
groundwater to meet groundwater remediation standards will
reduce the potential excess lifetime cancer risk and non-
carcinogenic risks due to ingestion of -contaminated
groundwater.
Institutional controls will provide short-term effectiveness
for the prevention of drinking contaminated groundwater until
the groundwater remediation standards are met. The selected
remedy also protects the environment by reducing the potential
risks posed by site chemicals d~scharging to surface water
(Grand River) and the adjoining wetlands.
cappinq the site, in addition to reducinq any potential
further risk posed by exposure to site contaminants, will
reduce precipitation infiltration through the cap and maintain
that reduction over time. The cap wil: reduce g~ound-water .
contaminant loading to the aquifer, al_Jwing the restoration
of the aquifer within a reasonable time frame. No
unacceptable short-term risks will be caused by implementation
of the remedy. The community and site workers may be exposed
to noise and du;:t nuisances during construction ot the cap and
solidification/stabilization of the soils. Mitigative
measures will be taken during remedy construction activities
to minimize impacts of construction upon the surrounding
community and environs.
50
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b.
Compliance with ARARs
The selected remedy will comply with the federal and/or state,
where more stringent, applicable or relevan~ and appropriate
requiremen~s (ARARs) listed below:
1.
Chemical-specific 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
Safe Drinking Water Act MCLs and MCLGs - 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 drinking water supplies servicing 25 or more
people. At the H. Brown site, MCLs and MCLGs are not
applicable, but are relevant and appropriate, because
the aquifer is a Class II aquifer which is presently
beinq used as a drinkinq water source in the area
surrounding the site and could potentially be used in
the area of concern. 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. The point of compliance for
federal drinking water standards is "at the boundary of
the solidified/stabilized waste, because this is the
point where humans could potentially be exposed to
contaminated groundwater. Because this site will have a
final clay cover, the point of compliance will be at
the boundary of the final cover.
clean Water Act Section 304 - Surface water quality
standards for ~he protection of human health and
aquatic life were developed under section 304 of the
Clean Water Act (CWA). The federal Ambient Water
Quality Criteria (AWQC) are nonenforceable guidelines
that set pollutant concentration limits to protect
surface waters that are applicable to point source
discharges, such as from industrial or municipal
wastewater streams. At a Superfund site, the federal
AWQC would not be applicable except for pretreatment
requirements for discharge of treated water to a
Publicly owned Treatment Works (POTW). CERCLA (section
121(d) (1» requires the u.s. EPA to consider whether
AWQC would be relevant and appropriate under the
circumstances of a release or threatened release,
51
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depending on the designated or potential use of
groundwater or surface water, the environmental media
affected by the releases or potential releases, and the
latest information available. Since the contaminated
aquifer is a potential source of drinking water and
since treated water will be discharged ~o the Grand
River, AWQC adopted for drinking water and AWQC for
protection of freshwater aquatic organisms are relevant
and appropriate to the point source discharge of the
treated water into the Grand River. only the
substantive NPDE5 permitting requirements will need to
be met if discharge is allowed into the Turner Avenue
sewer. If discharge is directly to the Grand River all
NPDE5 requirements would be met because such discharge
would be off-site.
Clean Air Act National Ambient Air Quality Standards 40
CFR 50 - These regulations provide air emission
requirements for actions which may release contaminants
into the air. As the selected remedy involves
excavation, construction, and groundwater treatment
activities which may release contaminants or
particulates into the air, emission requirements
promu~qated under this act are relevant and
appropriate.
State ARARs
Michigan Act 307 - The state of Michigan has identified
the Michigan Environmental Response Act (referred to as
"MERLA," "the Act," or "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, 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 generally achieves cleanup to
background or non-detectable levels (R299.5707)i a Type
B level meets specified cleanup levels in all media
(R299.5709-571S and 5723), and a Type C cleanup is
based on a site-specified risk assessment (R299.5717(2)
and 5719(1».
.U.5. EPA's selected soil cleanup standards for this
site are in compliance with Act 307 and it implementing
rules in that they meet the standard for selection of a
.Type C (R 299.5717(2) and 5719(1»). The cleanup levels
for contaminants in soil are determined by comparing
current concentrations of contaminants with the
background concentrations and with allowable
concentrations based on (1) risks and (2) ARARs. Table
52
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11 lists the represen~ative chemicals found in the soil
and the corresponding federal and state clean-up
criteria which the U.S. EPA believes to be adequately
protective of human health and the environment. Table
12 lists the soil remediation standards for the H.
Brown site.
Current concentrations of individual contaminants are
compared first with their background and ARAR-based
allowable concentrations. The cleanup leve~ for a
contaminant is not proposed if its current
concentration is lower than its background or ARAR-
based allowable concentration. However, if the current
concentration of a contaminant is higher than its
background and ARAR-based allowable concentration, the
cleanup level for the contaminant is set at the larger
of the background and ARAR-based allowable
concentrations. If the ARAR-based allowable
concentration is not available for a contaminant, its
current concentration is compared with its background
and risk-based allowable concentrations and the cleanup
level for the contaminant is not proposed if either of
these concentrations are more than the current
concentration of the contaminant. If the current
concentration of a contaminant is more than its
background or risk-based allowable concentrations, the
cleanup level for the contaminant is set at the larger
of the background or the risk-based allowable
concentration for the contaminant;
u.s. EPA's selected groundwater cleanup standards for
this site are in compliance with Act 307 and its
implementing rules in that they meet the standard for
selection of a Type A (R 299.5707)jType B (R 299.5713).
The numeric groundwater cleanup standards were derived
by separately comparing current concentrations of
contaminants in each aquifer with the corresponding
background concentration and with allowable
concentrations based on (1) risks and (2) ARARs.
53
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TABLE II
COMPARISON OF CLEANUP LEVELS FOR SOn.. WITH CURRENT. RISK-BASED.
ARAR.BASED. AND BACKGROUND CONCENTRATIONS OF
TARGET CONTAMINANTS (nuriq)
-.
Target CODt1Ilft1ftUtt CTC) I CODce:DU'WOD" (DIg/kg) I
CunaI1 I Risk I A.RAR BackgroUDC1 Cleaauu I
ADIimoDy I ~..~,~:~~.. 1.00 E+O 5.00 E-l ND8 5.00 E.1 (ARAR) I
Ar88ic 1.15 E+2 1.00 E+O 6.60 E+O I 6.60 E+O I
4'.2S:E+l'" 6.60 E+O (BackgrouIMi)
Beryllium 1.14 E+O 1.00 E-2 Not 6.00 E-1
5.60:E~l' AvaUable 6.00 E.1 (BackgroaDIi)
CbmIIIium 4.99 E+ 1 2.00 E+O 5.40 E+1 5.40 E+ 1
~1t::E+l"
. 1.30 E+5 Below
.
Lead 1.99,,£+5. D~OD 5.00 E+2 4.90 E+2 5.00 E+2 (ARAB.)
Limill
BEEP 1.01 £+ 1 1.00 £+0 3.30 E-1 I ND
3.32:£+1" 3.30 E-1 (ARAR,)
CDD 8.52 £-2 2.00 £.2 3.30 E.l ND
1.46:iE~r
DOT 1.33 E-l 2.00 £.2 3.30 £.1 NO
':3:05$~'F:
NNDPA 5.46 E+O 1.00 £+0 3.30 E.1 NO 3.30 £-1 (ARAR)
t~lCU::~;l':
PCBa 5.48 £+0 1.00 £.2 1.00 £+0 'NO 1.00 E+O (ARAB.)
1~85:,E+'l
isutn....- 2.OS E+2 9.00 E+l NO 9.00 E+l (ARAR)
B=uDCa>-m..--".a 1.00 £+2 3.30 E.l NO 3.30 E.l (ARAR)
Beamca)pynmr 3.60 E+2 3.30 E-l ND 3.30 E.1 (ARAIl)
B=uDCb)ftau. 1I.AAdI 1.80 £+2 3.30 E.l NO 3.30 £-1 (ARAIl)
Beu.ock)fl11o.t ......... rr 8.30 E+ 1 3.30 £.1 I ND 3.30 £-1 (ARAR) I
Cbfy-.rl 2.00 E+2 3.30 £-1 ND 3.30 E-l (ARAR)
Dibeazla.h}.""""..--i 7.90 E+2 3.30 E-l ND 3.30 E-l (AlWl)
JndeaD( 1.2.3-c:dMiaW 6.90 £+2 3.30 E-l ND 3.30 £-1 (ARAll)
Noca:
T'he c:umDI CODI:CIIII8IiaD of TCs in surfIce soil within me cwreDUY acGve area of the lire 8pp8I' IS
nom8l tal: tba8 of TCs in surf8= IOil 0UII:id0 tb8 c:wreauy acUve area appear as sb8ded taL 1b8 ri*-
bI8i ~ UMi &be c:urraat CODCIIIIII'8tic 0UIIide of the CUI1'CDtiy fem:8i area &III DOC ~&-- for
eo_.A..,i.. '.-wiII8O currcat coac:au:rariaDI do DOt pose a sigaificat risk
lAdle ~.......,.. colWZIIIS. "1.19 E+3" g,d;"'- 1.19 x lQ1: 81.14 E+O" indicala 1.14: "1.46 E-1-
i...w..- 1.46 x 10'1. aaA 10 on.
~
Not d~ (ND)
COI!'...m-r does not polO a sigDificat risk. but its current CODceauaUon violaces ARAR
2-16
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TABLE 12
CLEANUP LEVELS FOR SOn. (mg/kg;
Targu CoD'.'""'-' (TC) I CICIIDUp Level I
ADDIDDDy 5.00 E-1 (ARAR)
Atsauc 6.60 E+O (~)
Beryllium 6.00 E-1 (B~)
ChromIum
Lea4 5.00 E+2 (ARAR)
BmP 3.30 E-1 (ARAR)
DDD
DDT
. NNDPA 3.30 E-l (ARAR)
PCBs 1.00 E+O (ARAB.)
I~IOpaur 9.00 E+ 1 (ARAB.)
Beamca }.ft''''''-'''' 3.30 E-1 (ARAB.)
, Beamca)pyl'Cll8" 3.30 E-1 (ARAR,) I
BeIIZDC b)fluanDllllillff 3.30 E-I (ARAR)
Beazock)fluonDlileDe'" 3.30 E-l (ARAR)
~ 3.30 £-1 (ARAR,)
Diheazaa.h~ 3.30 E-I (ARAR,)
IDdIIID( 1.2.3,")".1&...1 3.30 £-1 (ARAB.)
Notea:
The cumm CO--a.~OD of TCs in aurf8ce soil within c= cum:DI1y acUVD area of the lire 8fIPI8I' U
. nora81 tea: dIo8e of TCs in surface soil 0UIIide &be cunady acUVD area 8ppe8I' as ahadeci ceu. Tb8 risk-
ba8d c:oac:auraioD 8IIIi &be cum:a& CODCCIIIr8IioD oUllido of the cum:DI1y feaceci ... are DOt pc . ri for
C..g'AII.i"'AllfII wbo8e CUI'I'aIt COD:~DCt.aaaa do DOt pose a sigDifiCIDt risk
In die ooar-lI,...qoa colUDllla. 81.19 £+38 iftd....t- 1.19:1t loJ: 81.14 E+08 iDdi""- 1.14: 81.46 £-18
inlh- 1.46 X Hrl. alIA 10 em. .
Not d~ (ND)
4
C.........,i...... does DOt pose . sir..~r risk. but its c:urrcat com:eatnlioa violases ARAR.
2-16
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Table 13 lists the represen~ative chemicals found in
the groundwater and the corresponding federal and state
preliminary clean-up criteria that the U.s. EPA
believes to be adequately protective of human health
and the environment. Table 14 lists the groundwater
remediation standards for the H. Brown site.
Current concentrations of individual contaminants in
each aquifer were compared first with their background
and ARAR-based allowable concentrations. The cleanup
level for a contaminant in an aquifer is not proposed
if its current concentration in the aquifer is lower
than its background concen~ration in the aquifer or its
ARAR-based allowable concentration. However, if the
current concentration of a contaminant in an aquifer is
higher than its background and ARAR-based allowable
concentration, the cleanup level for the contaminant is
set at the larger of the background and ARAR-based
allowable concentrations. If the ARAR-based allowable
concentration was not available for a contaminant, its
current concentration in the aquifer is compared with
its background and risk-based allowable concentrations.
The cleanup level for the contaminant in that aquifer
is not proposed if either of these concentrations are
more than the current concentration of the contaminant
in the aquifer. If the current concentration of a
contaminant in an aquifer is more than its background
or risk-based allowable concentrations, the cleanup.
level for the contaminant in that aquifer is set at the
larger of the background or the risk-based allowable
concentration for the contaminant.
The u.s. EPA has determined that Type B criteria would
yield groundwater clean-up standards that also provide
for the protection of surface water quality, in turn
protecting human health and the environment. Type B
criteria will be as protective as a remedy consistent
with the u.s. EPA risk ~ssessment policy.
u.s. EPA does not consider the other provisions of Act
307 and its implementing rules identified by the State
as ARAR, 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 ARAR, the remedial
actions and cleanup standards selected for this site
are in compliance with these :~ate-identified ARARs
since they have been selected .n accordance with CERCLA
and the NCP.
MiChigan Water Resources commission Act (Act 245) as
amended - portions of the Water Resources Commission
56
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State ~~s
Michigan Hazardous Waste Management Act (Act 64)- Upon
closure of the site, high levels of contaminants will
be left on-site in a solidified/stabilized mass.
Because the solidified/stabilized waste is sUfficiently
similar to waste regulated under the Act and there is a
need to protect the solidfied/stabilized mass from
seasonal conditions, the Act's requiremen~s are
relevant and appropriate for. the waste.
Michigan Public Health Code, Public Act 368 of 1978,
Part 127 - This act regulates the water supply intended
for use or used to supply groundwater. It is
applicable to the selected remedy, because it addresses
the location, construction, and abandonment of private
drinking wells.
Inland Lakes and Streams Act, PUblic Act 346 of 1972,
as amended - The act regulates construction activities
on or over bottomlands of inland lake and streams.
This act will be applicable to the selec~ed remedy,
because it addresses the mitigation of po~ential run-
off, erosion, silting, and sedimentation in the surface
waters during construction.
Mineral Well Act, Public Act 315 of 1969, as amended -
This act regulates location, construction, and
abandonment of monitoring and test wells. This act is
similarly. relevant and appropriate for the selected
remedy.
To-Se-considered ARARs
4.
OSWER Directive #9355.4-02 Interim Guidance on Establishing
Soil Lead Cleanup Levels at Superfund sites - This directive
sets interim soil lead cleanup standards at 500 - 1000 parts
per ~illion.
~.
cost Effectiveness
Cost effectiveness compares the effectiveness of an
alternative in proportion to its cost of providing
environmental benefits. Table 14 lists the costs associated
with the implementation of the remedies.
The selected remedy for management of migration, Alternative
15, has been determined to afford overall effectiveness
proportional to its cost. Alternative 15 carries moderate
costs in comparison to the other nine alternatives considered.
Those alternatives less costly than Alternative 15 do not
offer permanent solutions such as the
61
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solidification/stabilization proposed in Alternative 15. They
instead propose to contain the waste withou~ treatment. The
selected remedy, therefore, affords the greatest effectiveness
proportional to its cost.
d. utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery 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 trade-offs 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.
The selected remedy offers a high degree of long-term
effectiveness and permanence. It will significantly reduce
the inherent hazards posed by the contaminated soil and
groundwater by treating these substances. These benefits are
achieved at a reasonable cost.
e.
Preference for Treatment as a Principal Element
The statutory preference for treatment,as a principal element
of a remedy is satisfied by the selected alternative.
12~
summarv
The presence of soil and groundwater contamination at and
around the H. Brown site requires that remedial actions be
implemented to reduce the risk to public health and the
environment. The U.S. EPA believes, based upon 'the RIfFS and
the Administrative Record, that the selected alternatives
provide the best balance of trade-offs among alternatives with,
respect to the criteria used to 'evaluate the remedies. Based
upon the information available, at this time, the U.S. EPA
believes that the selected remedy will be protective of human
health and the environment, will attain ARARs and will utilize
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent
practicable.
~y
62
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COlilamiuanl CUrielit Ri~k-hased AKAR- Background Cleanup Contaminant Current 1I.1t .baed ARAR. Background Cleanup
buecl baed
Antimony 6.27 8 +I 2.00 8+0 5.00 8+0 5.00 BtO 1.97 B+I 6.1. Bt I 6." 8+1
6.418 tI 1.798+ I 1.79 8 +I Vanadium' ~.~~ '-HI 1.00 8+1 2.00 8+ I 3.81 E+ 1
Arsellic ~.21 ~+ ~ 1.25 E+O 1.79 Et I 2.76 E+ i 7.30 £+0
3.24 E+O 1.82 St] 4.61 E+:I 4.67 B +J
7.34 E..2 1.06 E t3 linc t.~t,t~ 2.50 E +2 4.67 E+J lRtIH
B." iUJII 4.~~H 1.00 E+2 2.00 E+J ~.1~ PH 2.311H3 1.06 £t2
6.18 E+ I 2.76 E+I Ben&eDe~ 1.01 E+I 5.00 B-1 ..00 BtO 1.00 8tO
. Benzo(l)aolbracene'
Bel yllium" 1.47 IH 0 1.00 8+0 1.508+1 5.00 8+0 5.00 8tO
1.90 IHO 1.00 E-) 3.50 E+ I too 8+0 Benzo(l)pyrene' 1.90 S+I 5.00 BtO 5.00 StO
~ ";" :: ~. :"."
- Ii 1 I' . "f
C:ulminJII" 6.66 EI 0 4.00 E+O BelWl(b)Ruoraalbeoo' 1.40 Et I 5.00 BtO 5.00 8+0
1.00 E+O 4.00 E+O
8.00 tHO ' Ben&o(It)nuorlnthene' ..608+1 5.00 8tO 5.00 8+0
--.-. ~ .
8.6S E I I 9.S4 E +t BEnpc.4I 3.10 EH 2.00 E-I 5.00 EtO 5.00 E+O
ClUIIJlliUJII 2.69 Et' 6.25 E+O 5.00 E+I 9.6S i!H 6.10 E+ I
. . I : .::. ...: : .
3.48 8 tJ 1.428U 1.42 8 +J Chr)'IeDo' 1.408+1 5.00 B+O 5.00 8+0
Lt':,,1 1.14 e H Below 5.00 E+O ,.il9 ~+~ Dibenz(a,h)anthracene' 6.00 E+O 5.00 B+O 5.00 8tO
:. .;.:.:. Detection
8.60 E+ 0 1.50 £+0 Dieldrlo' 7.00 E-I 5.00 8-4 1.00 8-2 1.00 8-2
2.49E-I3 2.35 8 tJ Heptachlor" 8.00 E-2 2.00 E-J 1.00 8-2 1.00 E-2
Manj!allt"se p~~H 1.25 E I 2 2.JS E I-J H~ ~+1 Indeoo(l.2.J~d)PJrene' 1.90 Et I 5.00 8tO 5.00 E+O
3.20 E+2 2.16 E+I Phenanthrene'. 7.00 8+0 5.00 B+O 5.00 8tO
-----
4.47 E+2 1.03 E +2 1.03 E+2 Vinyl Cblorido 6.42 E+O 1.00 E-2 1.00 E+O 1.00 E+O
Nickel 4.91 B+ i 2.508+0 1.03 IH 2 6:702+ t
TABLE 13
COMPARISON OF (:LEANUr LEVELS FOR GROUND WATER WlfH CURRENT,
RISK-BASED, ARAR-BASED, AND BACKGROUND CONCIEN11tATJO,.. 0' TCI (,aIL)
NClIt'~: . In conceuiratiull cululllns, "1.05 E + I. indicates 1.05 It 10': -1.80 F. to. indicate. 1.80: ~5.00 E-'" indic.te. S.OO X 10.1. ROd 10 on. Tbe io'hrmalion related to
cunlaminllnts in shallow, intt'rmediRle. and deep (bed rork) Rquifen appear. in tho lable as norml\I,lhsded. and bold tnl. A blank cell in the column for alloWllble
roncentratiofls based un ri..k illdicate8 Ihat the contaminanl dues not pelle !';ipificlDt health dlb: in the culullIn for aUoWRbIe COlICootntioDI bued on AltARs, . blank cell
illdkale~ Ihal 811 ARAR-"8~d allowable t'QlICefllr8tiCln is nllt available fQr tbe contamwaoli 10 tho columu for backpouodcoDCOolnllODl.la iaclicatu thai the contaminant
was nlll detected in the backgruund: an,l, ill the clliumn for the deRllup levels, a blank cell Indicates thRI Ihe deanup for the contaminant 18 not proposed.
b CClnlamillanl was delected only once in Ihe inlermediate aquifer
C Coutaminant was detected only once in the deep aquifer
.1 ("Cllllalllinalli wa~ delecled Clllly IIIlce in Ihe ~hallClw aquifer
2-21
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TABLE
, .
I."
CLEANUP LEVELS FOR GROUND WATER (~iL)
.
CODhI...,......r j CI~ I CODbI""tYt~..,r j Cleu~ I
Amimony 5.00 E+O VauOium 16.81 E+l I
Anemc jl.79E+l 4.67 E+3
ZiDc
Barium
BeaellO 11.00 E+O I
Beryllium BeDZoca~ne 5.00 E+O I
BeazocaJPyrene 5.00 E+O
4.00 £+0 BeDZoc D )fluoraml1ene 5.00 E+O
Cadmium Beazocic)fluoraml1ene 5.00 E+O
Qaromium BEHP 5.00 E+O
1.42 E+3 ChryIeae 5.00 E+O I
LeaA DibellZtu)amDr'acene 5.00 E+O
DieJdriD 1.00 E-2
He,t8cA!or 1.00 E-2 I
MaDgaDae lDdeDoc 1 .203 ~d)pyrene 15.00 E+O I
PheuD(IU'eDe 5.00 E+O
N'1Cke1 1.03 E+2 VID}'I Chloride 1.00 E+O
Nota:
. mconceD1l'8licmcolU111118. 81.05 E+18 indv--- 1.05 It l()l; 81.80 E+O. indicarea 1.80: .5.00 E-l. ind.iea&e8S.oo It 10"1,
aDfi 10 on. The iDfOl'lllllliaD re!aI8O co
CO_...i....... in 1DaIIow. iDrenDeGi8re.8DA deep (beci rocic) aquiien appean in the table U Ilormal. shad8cL 8DA boW feU. A
blak cell in tho coiuam for allOW8ille
coDceD1DI:iau -- OD risk iDdi't"..~,&bat me CO"""''''.,,, doe8 not poI8 ligDificant health risb: ill me colUIIID for allowable
COIII:eDtr'aliOll8 --.all. ARARa. a blullt cell
jnd....ta &bat aD ARAll-ba8eci allOW8ille caaceIIII'8IiaD ilnoc available for me COil""""""'. in the column for background
cODCeDtr'alicma. it i..d....... &bat die coa""""8ftP
wu DOt de~ in me ~ aDd. ill the column for me cleamql levels. a blaDk cell indiC81e81ba& me cle8111q1 for the
CO'''-'''.''' iI DOl ptOp08llG.
b Coa""'-'''' Gell ~1.1i ODIy once in the iDtenaedi81e aquiier
c Co....",;"",...... G.~ oaly once in the deep aquiier
d Co.."'""".,,' WU delee-t DD1y ODC8 in me 8baUow aquifer
2-27
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Act 245 (Michigan Act 245) of 1929, as amended, will be
applicable to the remedy and es~ablish surface wa~er-
quality standards to protec~ human health and the
environment. The State administers the NPDES program
under Part 21 of Michigan Act 245; therefore, Part 21
of Act 245 would be applicable to the direct discharge
of treated water to the Grand River.
Michigan Air Pollution Act 348 provides air emission
requirements for actions which may release con~aminants
into the air. The selected remedy involves excavation,
construction, and groundwater treatment activities
which may release contaminants or particulates into the
air. This act is relevant and appropriate.
2.
Location-specific ARARS
Location-specific ARARs are those requirements that relate
to the geographical position of a site. These include:
Federal ARARs
The Clean Water Act Section 404 - This section of the
Act regulates the discharge of dredge and fill
materials at sites to waters of the United States.
These regulations are applicable to capping of the site
and other activities which may take place in the
wetlands.
Wetlands Management Executive Order 11990 - This order
is applicable to the site. The order requires federal
agencies to avoid, to the extent possible, the long-
and short-term adverse impacts associated with the
destruction or modification of wetlands.
RCRA Location standards 40 CFR Part 264.18 - These
standards are relevant and appropriate for the remedy
at the H. Brown site because a portion of the site is
located in the 500 year flood plain. These standards
specify that a facility located in a flood plain must
be designed, constructed, operated, and maintained to
'prevent washout of hazardous wastes by a flood.
Floodplain Management Executive Order 11988 - This
order is applicable at this site. It requires the
minimization of potential harm to or within flood
plains and the avoidance of long- and short-term
adverse impacts associated with the occupancy and
modification of flood plains.
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stateARARs
Goemnere-Anderson Wetland Protection Act, Act 203 of
1979 - Regulates any activity which may take place
within we~lands in the state of Michigan. . Act 203 is
applicable a~ this site~ it will require the
replacement of adversely impacted wetlands with
comparable resources.
soil Erosion and Sedimentation Control Act, Act 347 of
1972 - This act is applicable to this site due to the
selected remedy's use of cons~ruction activities that
may impact the Grand River. The act regulates earth
changes, including cut and fill activities which may
contribute to soil erosion a~d sedimentation of surface
water of the State. Act 347 would apply to any such
activity where more than one acre of land is affected
or regulated action occurs within 500 feet of a lake or
stream.
Michigan Act 307, Rule 719(3) - This rule requires
institutional controls be placed on the site including,
but not limited to, notice to future property owners of
contamination at the site, deed restrictions to
regulate the development of the H. Brown site, and
groundwater use restrictions in the areas that have
contaminated groundwater. Groundwater use restrictions
may be rescinded after remediation standards are met
and proven to be maintained.
3 .
Action Specific ARARs
Action-specific ARARs are requirements that define
acceptable treatment and disposal procedures for haz~rdous
substances.
Federal ARARS
RCRA subtitle C Land Disposal Restrictions (LDRs) -
Consolidation and solidification/stabilization~will
occur within the area of contamination. Therefbre, the
requirements of this act will not be triggered for
solidification/stabilization. The requirements of this
act will be applicable to any off-site treatment of the
waste products of the selected remedy due to the
groundwater treatment process and required pretreatment
steps, and to any of the waste products of that process
that are RCRA hazardous waste. These regulations
govern the storage and disposal of hazardous waste.
This remedy will comply with LDRs through a
Treatability Variance for wastes that cannot be treated
to meet the standard.
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The ~otal estimated costs for the selected remedy a~ this site
are as follows:
Alternative
Total
Ca'Dital Cost
Total
O&M. 30 yr.
Total
Present Worth
15
13,000,000
220,000
15,000,000
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Responsiveness Summary
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