United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EP AlRODIR05-931228
March 1993
PB94-964104
&EPA
Superfund
Record of Decision:
Wash King Laundry, MI
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u . S. Environmental Protection Agenc.y
Region 1/1 Hazardous Waste .'
Technicai Information Center
84'1 Chestnut Street ,9th Floor
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Hazardous Waste Collection
Information Resource Center
US EP A Region 3
Philadelphia, PA 19107
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50272-101
REPORT DOCUMENTAT10N
PAGE
11. REPORT NO.
EPA/ROD/R05-93/228
z
3. Recipient'. Accealon No.
4.
TItle and Subtitle
SUPERFUND RECORD OF DECISION
Wash King Laundry, MI
First Remedial Action - Final
Author(.)
5.
Report Oate
03/31/93
6.
7.
a.
Performing Organization Rept. No.
9.
Performing Organization Name and Addl'8SS
10
Projec:l TaskJWortI Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Raport & PerIod Cov81'811
Agency
800/800
14.
15. Supplementary Not-
PB94-964104
16.. Ab8tract (Umll: 200 words)
The Wash King Laundry site is a former coin-operated laundry and dry cleaning facility
located in Baldwin, Lane County, Michigan. Land use in the area is predominantly
residential and commercial, with woodlands surrounding the residential and commercial
areas. The Middle Branch Pere Marquette River is the only major surface water body in
the area and forms the northern boundary of the site. The Wash King facility is
located in a subdivision which includes 123 residential lots, with the closest
residence located 100 feet north of the site. Ground water in the vicinity of the site
is used as a residential water supply by some residents. The facility operated from
1962 until 1991, when the present owner filed for bankruptcy. In addition to the
coin-operated laundry facility which was used by local residents, a dry cleaning
facility which used PCE also was operated at the facility until 1978. Laundry
wastewater and dry cleaning wastes generated by these two activities w~re disposed of
in four onsite seepage lagoons, which are located in a wooded area 500 feet west of the
laundry building. The total surface area of these seepage lagoons is approximately
10,000 ft2. This improper disposal 'activity has resulted in contamination of the soil,
sediment, and ground water in the area. In 1973, laundry detergent wastes and PCE
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Wash King Laundry, MI
First Remedial Action - Final
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (PCE, TCE, toluene),
(arsenic, chromium, lead)
other organics (PAHs, pesticides), metals
b.
lcIentlflel"8lOpen
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EPA/ROD/R05-93/228
Wash King Laundry, MI
First Remedial Action - Final
Abstract (Continued)
first were detected by State personnel in nearby water supply wells. In 1976, the State
identified additional ground water contamination and ordered Wash King to discontinue all
laundry operations and to develop a new disposal site; however, the owner obtained a local
court order to continue operations. In 1977, following additional State investigations
and a State suit against the site's owner, a court agreement was reached in which the
owner agreed to discontinue all dry cleaning operations and to eliminate all sources of
PCE at the facility. In 1982, additional State investigations detected elevated levels of
PCE in monitoring wells and existing residential wells downgradient of the facility. In
1983, the State required the site owner to construct a public water supply to serve
affected residences and businesses, and in 1984, these residences were connected to the
new water system. Beginning in 1988, the State conducted detailed investigations which
confirmed the onsite ground water contamination and indicated the presence of similar
contaminants in soil, sediment, and surface water in the former disposal lagoons. This
ROD addresses a first and final remedy for the soil and sediment contamination in the
lagoons and ground water. The primary contaminants of concern affecting the soil,
'sediment, and 'ground water are VOCs, including PCE, TCE, and toluene; other organics,
including PAHs and pesticides; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating approximately 1,500 yd3 of
contaminated soil and sediment from the former disposal lagoons; disposing of the soil and
sediment in a permitted hazardous waste landfill offsite; extracting and treating ground
water onsite using ion exchange to remove the metals and either air stripping, carbon
adsorption or oxidation/photOlysis to remove the VOCs and other organic contaminants;
discharging the treated water onsite to Middle Branch Pere Marquette River; monitoring
ground water; and implementing institutional controls, including deed, land, and ground
water use rest~ictions. The estimated present worth cost for this remedial action ranges
from $8,100,715-$18,084,812, which includes an estimated annual O&M cost ranging from
$358,Off2-$1,044,415 for 4 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil and sediment cleanup goals are based on the State risk-based
cleanup criteria, and include aluminum 1 mg/kg; arsenic 0.0004 mg/kg; barium 40 mg/kg;
bis(2-ethylhexyl)phthalate 40 ug/kg; cadmium 0.08 mg/kg; chromium 2 mg/kg; 4,4-DDE 2
ug/kg; 4,4-DDD 2 ug/kg; dieldrin 0.04 ug/kg; di-n-octylphthalate 2,000 ug/kg; lead 0.08
mg/kg; mercury 0.04 mg/kg; nickel 2 mg/kg; and PCE 14 ug/kg. Chemical-specific ground
water cleanup goals also are based on the State risk-based cleanup criteria, and includer
alpha-chlordane 0.03 ug/l; arsenic 0.02 ug/l; beta-BHC 0.02 ug/l; boron 600 ug/l; chrysene
0.003 ug/l; dieldrin 0.002 ug/l; gamma-chlordane 0.03 ug/l; lead 4 ug/l; PCE 0.7 ug/l;
sodium 150,000 ug/l; 1,1,2,2-TCA 0.2 ug/l; and TCE 3 ug/l.
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DECLARATION FOR THE RECORD OF DECISION
WASH KING LAUNDRY
BALDWIN, MICHIGAN
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Wash King
Laundry Superfund site in Baldwin, Pleasant Plains Township, Michigan, which
was chosen in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act, 1980 PA 96-510 as amended by the Superfund
Amendments and Reauthorization Act of 1986, and to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan. This
decision is based on the administrative record for this site.
The U.S. Environmental Protection Agency (EPA) concurs with the selected
remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The site remedy for the Wash King Laundry site addresses both the contaminated
groundwater and the lagoons.
The groundwater remedial action consists of the following:
* groundwater monitoring
* deed restrictions
* groundwater extraction with physical/chemical treatment
The lagoon remedial action consists of the following:
* excavation of contaminated sediments and soils
* off-site disposal
Additional investigation will be part of the pre-design phase to better
characterize the site and to determine if the remedial actions described above
will completely address the site contamination. Additional remedial action
may be required.
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DECLARATION
The selected remedy for groundwater is protective of human health and the
environment. complies with federal and state requirements that are legally
applicable or relevant and appropriate to the remedial action. and is cost-
effective. This remedy utilizes permanent solutions and alternative (or
resource recovery) technology to the maximum extent practicable. and satisfies
the statutory preference for remedies that employ treatment that reduces
toxicity,"mobility, or volume as a principle element.
The selected remedy for the lagoon sediments/soils is protective of human
health and the environment. complies with federal and state requirements that
are legally applicable or relevant and appropriate to the remedial action and
is cost-effective. This remedy utilizes permanent solutions and alternative
treatment (or resource recovery) technologies. to the maximum extent
practicable for this site. However, because treatment of the sediments was
not found to be practicable. this portion af the site remedy does not satisfy
the statutory preference for treatment as a principle element.
Because the site remedy may result in hazardous substances remaining in the
groundwater above health-based levels for a period of time. a review will be
conducted within five years after commencement of the groundwater remedial
action to ensure that the remedy continues to provide adequate protection of
human health and the environment.
~-
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Oat
/~~3
Russell J. arding
Deputy Director
Michigan Department of Natural Resources
/'~
Date
3/, 1'173
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TABLE OF CONTENTS
Declaration
for the Record of Decision....................................l
Dec;sion Summary[[[3
I I I.
IV.
VI I.
I.
II.
Site Location and Description.......................................3
Site History and Enforcement Activities.............................5
A. Previous Site Activities........................................5
B. Current Site Status.............................................6
C. Site Characterization...........................................6
1. Lagoons
2. Groundwater
3. Middle Branch Pere Marquette River Water and Sediments
4. Subsurface Soils
5. Source Areas
.
Scope and Role of the Remedy Selected.....:........................18
Sununary of Site Risks............................................. .18
V.
Highlights of Conununity Participation..............................22
Description of Alternatives........................................22
A . Lagoons. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23
B. Groundwater. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25
VI.
Sununary of Comparative Analysis of Alternatives....................26
A. Evaluation Criteria............................................26
B. Comparative Analysis...........................................27
V I I I. Selected Remedy[[[ 31
IX.
X.
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WASH KING LAUNDRY SUPERFUND SITE
BALDWIN, MICHIGAN
RESPONSIVENESS SUMMARY
A.
OVERVIEW
At the time of the public comment period, the Michigan Department of Natural
Resources (MDNR) had selected a preferred alternative for the Wash King
Laundry site located in Baldwin, Michigan. The cleanup plan would address the
lagoon sediment and groundwater contamination at the site. The chosen remedy
specified in the Record of Decision (ROD) involves excavation and off-site
disposal of the sediments and contaminated soil along with pump and treat of
the contaminated groundwater. Treatment of the groundwater will involve ion
exchange and carbon adsorption, air stripping, or oXidation/photolysis. The
actual treatment scheme will be decided during the design phase after further
evaluation of these alternatives. The treated groundwater would then be
discharged to the Middle Branch Pere Marquette River located north of the
site.
.
.
This Responsiveness Summary addresses the concerns expressed by the public,
both historically and during the 30 day public comment period on the Proposed
Plan, which was held from August 17, through September 15, 1992.
No written comments were received from the public during the public comment
period. However, some concerns were voiced during the public meeting held on
August 24, 1992. The concerns focused primarily on issues that can be
resolved during design and implementation of the remedy. In general, the
community seemed to support the preferred alternative, now the chosen remedy,
as described above. Based on a review of public comments, no modifications to
the preferred remedy were necessary. The potentially responsible party is not
active in this process due to recent bankruptcy of the Wash King Laundry and
did not comment.
These sections follow:
* Background on Community Involvement
* Summary of Comments Received During the Public Comment Period and
MDNR.Responses
- Part I: Summary and Response to local Community Concerns
- Part II: Response to Specific Legal and Technical Questions
* Remaining Concern
* Attachment: Community Relations Activities at Wash King laundry
B.
BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Wash King Laundry site dates back to approximately
1973 when contamination relating to laundry waste was detected in private
water wells in the vicinity of the site. The community involvement increased
around 1977, due to detection of additional contamination in the groundwater
and intensification of negotiations between the owner of Wash King and the
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state. The major concerns expressed during the remedial planning activities
at this site focused on the possible health effects from contamination at the
site, delays in responding to community concerns, and lack of information
flow. These concerns and how they were addressed are described below:
1. Many affected residents were concerned with the potential health
affects relating to consumption and domestic use of the water from their
wells.
MDHR Response: Since 1984, the affected residents have been connected
to a public water supply installed by the owner of Wash King as a result
of negotiations between the owner and the state. Some residents in the
vicinity of the site, that are not hooked up to the water supply, have
had their water tested by either the district health department, the
Michigan Department of Public Health (MDPH), or the MDNR, to assure that
they have a safe water supply.
2. Before initiation of the RI, people were confused or did not believe
some of the technical information that they were given. They also did
not believe that the public water supply was safe, since it is located
on Wash King Laundry property.
MDHR Response: Since the completion of the RI, information has been
shared with the public by sending out progress reports and having public
meetings, allowing residents and other interested individuals an
opportunity to ask questions. On several occasions, the MDNR has
explained to the public that the water supply is drawing water from a
deeper, uncontaminated aquifer or water-bearing unit, which is monitored
by the MDPH, Water Supply Division, on a regular basis to assure that it
does not become contaminated.
3. Many people were opposed to the water system because they would be*
charged operation and maintenance fees.
MDHR Response: This system has not been under the direct control of the
MDNR at any time. The fee schedule is now under the control of the
local Clean Water Association.
4. There was a concern that the Middle Branch Pere Marquette River is
being polluted by Wash King Laundry contamination.
MOHR Response: Sampling has been done of both the surface water and
sediments from the river and no contamination relating to the site has.
been detected. This has been communicated to the residents.
5. Several of the residents complained about delays and inaction
associated with the installation of a clean water source.
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MONR Response: It did take an extended time period to install the
system and hook-up the affected residences. This was primarily due to
negotiations between the owner of Wash King and the state.
6. Laundry wastes are still permitted to be dumped into the sandy,
unlined lagoons. (Concern noted in the Community Relations Plan.)
MONR Response: Before the 1991 bankruptcy, the owner of Wash King was
working with the Waste Management Division of the MDNR to design
acceptable wastewater lagoons, meeting permit requirements, which would
have addressed this concern. However, this is no longer an issue since
these lagoons are no longer in use.
C.
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND AGENCY,
RESPONSES
The public comment period on the feasibility Study and the Proposed Plan for
the Wash King laundry site was held from August 17 to September 15" 1992.
Comments received during this time are summarized below. Part I of this
section addressed those concerns and comments tlat are non-technical in
nature. Responses to any legal and technical questions are provided in Part
II.
Part I - Summary and Response to Local Community Concerns
1. A local resident expressed a concern with use of an air stripper
that would transfer contaminants from groundwater to the air. If you
can't drink it, how can it be safe to breathe?
MONR Response: The contaminated groundwater would be treated, as
necessary, to assure that stringent air quality standards are met.
Residents in the area would not be exposed to unacceptable levels of
contaminants in the air. Monitoring would be conducted to verify that
air qual ity standards are maintained. '
2. A local resident questioned noise level associated with the
groundwater treatment system.
MDHR Response: The actual design of the treatment system will be worked
out in the remedial design phase. The noise level is uncertain at this
time due to site-specific considerations that may affect the noise
level. The treatment system would be located in such a manner as ,to
minimize disruptions to the area residents and business owners.
3. A question was asked as to start-up of the remedial action.
MOHR Response: For the remedial design of the groundwater treatment it
could take approximately 12 to 18 months before actual implementation of
the cleanup plan. The timeframe for implementation of lagoon sediment
excavation would be much shorter due to minimal design requirements.
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Hopefully, if funding is available, the lagoons can be excavated,
backfilled, regraded and vegetated by mid-1994.
4. A long-time area resident stated that he was pleased to see that
something was finally getting done at the site.
MOHR Response: The Superfund process is a long process requiring
extensive investigation of the site, evaluation and assessment of risks
associated with the site and of several cleanup alternatives, before a
cleanup plan can even be presented to the public. However, under
Superfund, there is the ability to take emergency action, if necessary,
to address sites that may pose an imminent danger to human health and
the environment.
5. A resident asked that if the groundwater was cleaned up as proposed,
would the area residents be able to utilize their own private wells
again.
MOHR Response: The goal of the groundwater treatment would be to reduce
the levels of contaminants in the groundwater to concentrations below
the levels established pursuant to the Safe Drinking Water Act and the
Michigan Environmental Response Act, 1982 PA 307, as amended, so that
the water would be safe for all domestic purposes, including drinking.
6. A resident asked how long it would be before a decision is made
regarding the proposed cleanup.
MOHR Response: A decision will hopefully be reached by March 1993 and
will be available for public review in the ROD.
7. A concern was raised as to what impact the implementation of the
remedy would have on the private road leading back to the lagoons (i.e.,
from heavy truck traffic).
MDNR Response: If damage was done to the road as a result of
implementing the remedial action, the MDNR and the u.s. Environmental
Protection Agency (EPA) would be responsible for any necessary road
repair.
Part II: Response to Specific Legal and Technical Questions
Several comments were received from various MDNR divisions regarding the
Proposed Plan for cleanup at Wash King laundry. These comments primarily
focused on design considerations and will be addressed as necessary when
designing the treatment system and when working out the details for off-site
disposal of the contaminated sediments and .associated soils. Comments were
received from the MDNR Air Quality Division, the land and Water Management
Division, and the Environmental Response Division.
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One comment of significance was received from the MDNR Cadillac district
office that stressed the importance of investigating the site for additional
source areas around the Wash King Laundry building.
Comments that were received from the EPA were in support of the preferred
alternative and addressed design issues only. These comments will be
considered during the design phase of the remedial action.
D.
REMAINING CONCERN
* Some concerns were expressed at the public meeting relating to the
intrusive nature of the treatment system and where the system will be
located.
.
.
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ATTACHMENT
COMMUNITY RELATION ACTIVITIES AT WASH KING
Community relation activities conducted at Wash King have included:
* A public meeting was called by the Attorney General's office, which
focused on the proposed community water system. The MDNR
participated in this public meeting. It was held on May 31, 1983.
* Initial on-site interviews were conducted in July 1983 with follow-up
telephone calls in June 1984.
* Community Relations Plan was prepared in May 1988.
* Fact Sheet for RI/FS Meeting - September 8, 1988.
* Kick-off Meeting for the RI/FS - September 14, 1988.
* Progress Report 11 - AprH 10, 1991.
* Public Meeting - May 1, 1991.
.
.
* Progress Report #2 - July 17, 1991.
* Progress Report #3 - October 15, 1991.
* Public Information Session - October 23, 1991. -
* Progress Report #4 - August 10, 1992.
* Public Meeting on the Proposed Plan - August 24, 1992.
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DECISION SUMMARY
WASH KING LAUNDRY
BALDWIN, MICHIGAN
I.
SITE LOCATION AND DESCRIPTION
The Wash King Laundry site (see Figure I) is located south of the city of
Baldwin in Pleasant Plains Township, lake County, Michigan. It is bordered on
the east by a line approximately 300 feet east of M-37, Star lake Road (76th
Street) to the south, the C & 0 Railroad to the west, and the Middle Branch
Pere Marquette River to the north. The Pere Marquette Subdivision Plat which
comprises the site, includes 123 residential lots, most of which are not used
on a year-round basis. Housing in the area consists primarily of mobile
homes, trailers, and cottages. Numerous commercially developed lots exist
along Highway M-37.
The Wash King Laundry is no longer in operation. Four seepage lagoons,
previously utilized for disposal of laundry wast~water, are situated about 500
feet west of the laundry building in a wooded area. The total surface area of
the lagoons is less than 10,000 square feet. Two of four lagoons were piped
in such a manner that discharge could be alternated between the lagoons. The
lagoons are approximately four feet deep and are not intersected by
groundwater. The closest residence to the lagoons is approximately 100 feet
to the north. The liquid wastewater in the lagoon areas has since evaporated
and seeped into the ground. Access to this area is unrestricted. Warning
signs were posted around the lagoons in August 1992, to discourage access to
the lagoon areas.
The site is generally flat except for a steep embankment leading down to the
Middle Branch Pere Marquette River. The area consists primarily of a
residential area among woodlands and small businesses along M-37.
Some residences in the vicinity of the site utilize their own residential
wells; however, many of the residences have been hooked up to a public water
supply installed by the owner of Wash King.
The site is in the Pere Marquette River basin providing drainage for a 681.6
square mile area. The river flows generally westward, discharging into Lake
Michigan. The Pere Marquette River and its tributaries are class'ified by the
State of Mic~igan as "top quality main streams" and "trout streams".
The site soils are generally composed of medium to fine grained sands to a
depth of approximately 75 feet, with a few shallow clay and/or silt lenses. A
thicker clay layer begins at about 85 feet below ground surface.
Aquifers in the region are predominantly outwash sands an~ gravels.
Groundwater recharge occurs on uplands with sandy soils. Groundwater in the
upper aquifer generally flows to the north-northeast, discharging into the
middle Branch Pere Marquette River, which is at the northern edge of the site.
It is uncertain if deeper groundwater in the upper aquifer also discharges to
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NOTES
,. BASE MAP DEVELOPED FROM THE BALDWIN,
MIOiICAN. 15 MINUTE U.S.C.s. TOPOGRAPHIC
OUADRANGlE MAP, DATED 1959.
MICHIGAN
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FIGURE 1
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2000 .
400
OUADRANCLE LOCATION
SCALE IN FEET
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SITE LOCAT1OH MAP
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FEASIBIUTY STUDY
WASH KING LAUNDRY
BALDWIN. WISCONSIN
4
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the river. Additional investigation will be included in the Remedial
Design/Remedial Action (RD/RA) pre-design phase to address this question.
Groundwater is estimated to be flowing horizontally at an average rate of 185
feet/year.
II.
A.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Previous Site Activities
The Wash King Laundry was in operation between 1962 and 1991, when the present
owner filed for bankruptcy. It was a small, coin-operated laundry which
served local residents. The facility also did dry cleaning until 1978, which
involved the use of tetrachloroethylene (PCE), a solvent.
Laundry detergent wastes and PCE were first detected in the groundwater by
state personnel in August 1973, when the contamination was detected in nearby
water wells.
In 1976, further contamination of groundwater wa$ discovered, and a Notice of
Noncompliance and Order to Comply was issued by the Michigan Department of
Natural Resources (MDNR) to the owner of Wash King Laundry. The Order
mandated that laundry waste discharge to the existing lagoon site cease, and
that plans and specifications for a new disposal site be developed. The site
owner obtained a Stay of this Order from the local circuit court, which
encouraged the parties to work together to solve this problem. A new location
for the lagoons was not agreed upon due to a concern that relocation of the
seepage lagoons would further contaminate the aquifer.
Additional investigations were conducted by the MDNR in 1977, which led the
state to file suit against Wash King Laundry in 1978. A court agreement was
subsequently reached in which the site owner agreed to discontinue all dry
cleaning operations and to eliminate all past and present sources of PCE at
the facility. The MDNR was also instructed by the court to perform an
investigation to clearly show that the laundry facility was the source of the
PCE contamination. This investigation is documented in a report by the MDNR
issued in 1980, titled Groundwater Quality InvestiQation. Wash KinQ Laundry.
Baldwin. MichiQan. Elevated levels of PCE were detected in monitoring wells
installed by the MDNR and existing residential wells sampled downgradient of
Wash King Laundry.
Investigative activities continued in 1982, further documenting the extent of
groundwater contamination. Although discharge of dry cleaning wastes (PCE)
had been discontinued in 1978, laundry waste discharges continued, as allowed
under a 1962 Order of Determination.
In 1983, the state negotiated a settlement with the site owner, specifying
that he construct a public water supply system to serve residences and
businesses in the area of contamination. Two wells were' subsequently
developed into a deeper uncontaminated aquifer to supply water for the public
water system. The main well is located on Wash King Laundry property and is
259 feet deep. The standby well is located on the Windjammer Restaurant
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property adjacent to Wash King laundry, and is 240 feet deep. Affected area
residences were connected to this new water system by the summer of 1984.
The Wash King laundry site was placed on the National Priorities list of
Superfund sites in 1983. In 1984, a Remedial Action Master Plan was
developed.
On December 31, 1986, the u.s. Environmental Protection Agency (EPA) sent a
Special Notice letter to the site owner pursuant to Section 122 of the
Comprehensive Environmental Response, Compensation and liability Act (CERCLA),
.1980 PA 96-510, notifying him as a responsible party for the site
contamination, and offered him the opportunity to conduct the Remedial
Investigation/Feasibility Study (RI/FS). The site owner declined the offer.
As a result, the EPA and the MDNR entered into a cooperative agreement whereby
the MDNR assumed the lead role in conducting the RI/FS, including generation
of the resultant decision documents, including this Record of Decision (ROD).
The RI/FS process began in 1988.
Bankruptcy was filed by the site owner in 1991. . The MDNR has entered into an
agreement with the bankruptcy trustee which grants property access to the
MDNR, EPA, and their designated representatives for the purpose of performing
activities associated with cleanup of the site. The local Clean Water
Association assumed operation and maintenance responsibilities of the public
water supply.
B. Current Site Status
In September 1988, an RI was initiated to define the nature and extent of
contamination at the site and characterize the potential threats to public
health and the environment from the site. Figure 2 shows the sampling
locations for all media investigated in the RI. The RI Report documenting the
field activities was approved by the MDNR in May 1991.
The site FS and Baseline Risk Assessment were approved by the MDNR in May
1992. The FS document details the development and evaluation of an array of
remedial action alternatives for the Wash King laundry lagoons and
contaminated groundwater. The Baseline Risk Assessment evaluated the data
obtained during the RI to determine if site contamination could affect human
health and the environment.
C.
Site Characterization
The following discussion briefly summarizes the nature and the extent of
contamination according to the respective media sampled during the RI. See
Table 1 for a list of contaminants of concern or potential concern. Table 2
is a complete list of organic and inorganic analytes detected at Wash King,
including minimum and maximum concentrations of each analyte detected.
6
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Wash King Laundry
.. 'I . 'j~~:'.,I,'; :'~~..(.L.. . /;, I~~ I t.,' ~ ~ 0 r L~= IIONRORIHO Wtu lOCAllON
IIU 0 . /) '\"\ I I "'\ '\ . . / \/ & \ AIIO NU1I8£JI
111 J :;'.! -' 1,\ ,. ' '. : ));r'::1:1 //[:. '7 .. ~" . "1~ ~ J) ~ := :.::':',:::~
~. ~. , ~\\ \SWI"O""""l/5'P\ i!y ",' ~ ~ -~ ! 0 ,: ',. f"" NO. JS-8I~. 00\'10 1/88.
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. : -, '! 9,R-.....J I 1.... .. pueuc WATP SUPPlY.
IE] ::, \,'~ £?:tJ ?~iiro~~;~.p~ ~l~~~-Lhl V3: ,0,
liD I. ~ ~~~( \.::~:!/ / !~' cf ~ . Existing d~~M JW1)~ 0
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'I ' " \'~.-=r=-~ ,.-) !~ ,~. 01 ,~~ ' !
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~"'--.., :'-I~ r. I~
~ 'c.~ \'. ' I n"02 . "
.,J ,'.. '\~; \\ ( "1;1 T'! " '. . ,.~
., ~,~1~~<~J"i ~ ('~~~~ ", . . /''''?~C? C:nC) I ~IGURE 2
'-'- --~- "-.. - . . I I - (IJ
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-------
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GROUNDWATER
VOLATILES
Carbon disulradc
1.I-Dichiorocdu:Dc
1.2-0ichJoroc:thcuc
T ctrachloroc:thcne
1.1.2.2- T ctrachJorocdw1e
T richlorocdlcne
SEMIVOLATILES
Benzoic: acid
Chryscne
PESTICIDES .
Bcta-BHC
Gamma-BHC (Lindan~)
. Diddrin
4,4'-ODE
Mc:thoxydor
Alph,a-<:hlordane
Gamma-<:hlOrdane
METALS
Anc:Die
Barium
BOI'OI1
Lead
Mangmc:sc
Potassium
Sodium
... .--
[1«-301-991
700C27S122C)...ca
TABLE 1
("~._....- of c-. or Pocc.i8l CD
W.. KilaC I.A88dry Silo
LAGOON SEDIMENTS
VOLATILES
Carboa disulfide
Chloroform
T cU8c:hloroc:dlcDc
Toluene
SEMIVOLATILES
2-B~
Bcazoic acid
Bis(2-c:dtylhcxyl)phdudae
Butylbcnz:yiphthalate
Di:,-oc:tyip~~e
'4~Mcthylphcnol
PESTICIDES
Diddnn
4~4''':DDE
4.".-00D
METALS
Aluminum
Arsenic:
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nic:kd
Silver
Sodium
Van8dium
ZiDc
, .
""
LAGOON SURFACE WATER
VOLATILES
c.n- cIisu1f.dc
c.n- k:b'8Chloricic
Chloroform
T ctndaIoroc:dacDc:
SEMIVOLA11LES
Bcamic acid
8c:Ryt 8Ieoba&
Butybc:azytptaawarc
Bis(2-c:thylhcxyl)phtbalatc
. I?icdaylphthlalc
iJi-n-buiylphtJuiJatc .
Di-n-oayiphthaJatc
PESTtCOES
Gamma-BHC (Lin~)
EndosuIf- sulfate
METALS
Aluminum
Arscaic
Bariam
Boroa
CacImiam
Chromium
Copper'
Cyanide
Iron
Lead
Mcn:ury
MaAC8DCSC
Nickd
Sd-;"'"
SocIiam
Ziac
8
SATURATED
SUBSURFACE SOILS
Chloroform
T c:trIdUorocdlcnc
Toluene
"
-------
1-
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Environnental
HediUII
TABLE 2
"'" , of 1
Ol'9anic end I.-.-nic Anelytcs
Detected at the \I8sb I:ing L~ Site(.)
Concentration a8n9C(b)
of O~tected A".lYtes
IIUICer of LOQci_(d)
S..,lect for AnalYSts
CROUND\lATER
Analyte
Hini-
Hn i!IUII
8acIt9l'oo.rd(C)
Concentration
POshi-
Detection
Honi to,.;ng and
Residential \lells
I
'=i
I
Toul
volatile ~ ~ ~ 20
Tetrachloroctnenc 9.0 1.600 0.36U 10
Trichlorocthenc 0.5 20 0.12\1 5
1.2-0ichlorocthenc 0.5 16 : . O.ZSU 5
1.1-0ichlorocthcne 0.1 0.9 o.~ 3
1.~.2~2~T~trachlo~octhanc 0.5 32. O.Oi\) 8
~ethy{cne chloride. 1.S 19' o.nu., 9
Acetone 39.1 39.1 2.OU . 1
Carboa disulfide 0.2 0.2 O.Z3u 1
Semivolatil~ ~.
Benzoic acid 1.0 1.0 SOU 1
Chrysenc 0.6. 6.0' iOU 3
pesticide/PC8 ~.
Beta-SHC 0.006 0.023 O.osu 3
Camma-BHC (Lindane> 0.008 0.017 O.05U 3
oieldr-in 0.039 0.039 0.1U 1
'.'-DOE 0_01' 0.01' Q.1U 1
Methoxychlor 0.013 0.073 O_1U 1
Alpha-Chlordane 0.~9 0.0/.9 O.Su 1
C~-Chlordane 0.050 0.050 O.SU 1
HetalltH 15
Arsenic 3.2 6.8 1.9U S
BariUD 8.0 63_2 16 13
Beryll i UD 1.' 2_7 '.1 6
CalciUD 27.800 96.200 '-6.200 13
Copper 6.4 6.4 ~.8 1
Iron 12-4 156 26.4 7
Lead 1.6 10_5 1.6U 4
.l48gneSi UD 8.690 y., 000 15.600 15
.~e 2_0 81_5 2.0 10
potasSiUD 334 10.500 7'3 15
SOdiUD 1.530 515.000 3.630 15
V8!WdiUD 3.0 6.0 3_8 5
Zinc 17.9 309 160 11
80r0n 99(, 1 . '00 'ou 3
9
-------
,.
I TABLE 2 '''' 2 of ~
I (Continued)
Concentration R8nge(b) NUliber of lOCollti_(d)
of Detected Anal Ytes S_led for AnIIh'Sis
I EnvironKncal B8dtgr"OW¥S(C) Po8tcl-
M~iUII ANlIYte Minf- Mul- Concentration Total Detection
I ~SUltFACE SOIL Volatile ~ !!!Il9 !!1l9 6
Medly\ene dlloride 5.00 5.00 3.0 0
Acetone 83 83 100 1
I Chlorofo,.. 6.0 '7 11 5
Tetrachloraethene 7.0 1.1 5.00 2
Toluene 110 630 79 6
I ~ivolatite
Oi-n.butylphthalate 2UIU 2100 190 0
I pesdcidefPCB
"one detected
I "'~talfCiI mafkq ~ "~ 1
.l.luninuu 829.0 .1.260 i ; I./'O 1 -
.:.. ,: i IIIOI1Y 2.I.U 3.2 Z.7U. 1 .
I ~ariun 5.1. 8.8 1,. 1
£aci1I i un . 0.3U "0.6 0.6 1.
c.alciun. . 17.100 21,800 20,200 1
ChrOllliun. Total 2.' 9~6 3~1 1
I Cobalt 0.7 1.5' 1.1 1
Copper 1.6 3.2 1.7" 1
Iron 1,330 2,530 1,720 1
I Lead 0.9 0.9 0.9 1
Kagnes iUII 6,030 7,7/'0 8,360 1
...anganese 31 50 50 1
I Mickel 1.3 2.7 2.1 1
potassiua 186 283 310 1
Sodi un 81 109 92 1
vanadiUII 0.6 1.0 1.6 1
I Zinc 7.1. 8.5 7.9 1
SURfACE UATER
I lagoons Volatile ~ ~ ~ 2
Tetracbloroethene 15 32 O.36U . 2
I carbon tetnchloride 0.1 0.1 o.nu 1
ebl_fo... 20 67 0.1U 3
carbon disulfide 5.6 5.6 0.2311 1
Acetone 183 190 2.00 2
I Methylene dlloride 2.9 2.9 0.13U ,
Seaivolat i Ie 2
i Benzyl alcohol 7.0 37 ,OU 2
Benzoic acid 10 10 50U ,
Oiethylphthalate 11 58 10U 2
Oi'n.butylphthatate 1..0 36 10U 2
-
I 8utytbenrylphthalate 67 67 10U 1
bis(2'Ethylheayl)phthalate 1.7 620 10U 2
Di.n~octytphthalate 8.0 72 10U 2
-
..
-------
-
..
TABLE 2 "89C 1 of S
(Concinued)
conc~cr.cion .~(b) Mu.bcr of locations(d)
of O~cected An8tyC~~ S-oted for An8t~is
Envirorcnental 88Cttf'G&8"d(C) posiciw
Hediun Anatyt~ Hi"i- 114.. i..... conc~crat iOft Tout O~tecciOft
p~t;c:idefPC1l !!9lh !!9lh !!9lh
C~.8HC (lindane) 0.3' 0.310 O.OSU
Endosulfan sutfate 0.21 0.21 0.1U
H~ta 1 fCN 3
A1Ullinua 1.00 7,070 17.W 3
Arsenic 2.2 2.1. 1.9U 2
BariUII 20.2 102 16 3
Cac:niUli 1..6 1..6 3.1U 1
CalciUII 35,600 '7.'00 1.6 ,200 3
Chromiun, Total 23.9 23.9 , lUlU 1
.
copper 31.8 31.8 1..8 1
Iron 313' 1,220 26.' 3
Lead' 8.8 62.2 1.6U' .3
":Ignes i un 13,900 .15,800 15.600 :3
"anganese 15.5 1.0..3 . 2.0 2
Hercury" 0.2 0.3 0.2U 2
Nick.el 13.' 13.1.' . 1S.7U' 1
potassiun 5,190 6,800 7l.3 '3
Seleniun 2.9 2.9 2.1U 1
SodiUli 17',000 . 188,000 3,630, 3'
vanadiUli 2.9 2.9 3.8 1
Zinc 156 296 160 3
cyanide, Total 13 13 100 1
Boron . 718 1,670 . '00 2
P~re Harquette ..
,.,
River
Volatile 3
Carbon disulfide 0.23 0.23 0.23U
Semivolatile
None detected
I p~tic:idefPC8
None detected
' Metal/Of 3
AlU8i.... _.~ ".9 ".9 3I..2U 1
Arsenic 2..3 2.3 1.W 1
I a.riUII 26 27.7 23.' 3
Catch... 1.0.600 1.1.300 38.000 3
Iron "7 201 1~ 3
lead 1.' 1.1. 2.5 1
. Magne$ i UII ",300 15,'00 11.,000 1
M~e 11.5 11.5 8.5 2
I potassiua 58l. 8l.1. 6l.5 3
Sodiua 5,760 6,01.0 5.670 :3
Vanadiua 1..2 '.2 2.8U
11
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,
TABLE 2 '''' .. .. ~
I (Continued)
concentration aange(b) NUIOer of locatl..(d)
of Detected Anelytes S-.pled fo,. An8tnis
I e""i ronnenut BactVr'OU"d(C) poshlw
"ediUli An8lyte Mini- M..i- Concentration Tot.t Detection
I SEDIHENT
lagoons
Vol.tite ~ ~ ~ 3
I Acetone 93 98 10U 2
Carbon disulfide 3.0 3.0 5.OU 1
CMorofonD 60 60 11 1
2. Butanone 10 13 10U 2
Tetrachloroethene . 27 190 5.OU 3
Totuene 3.0 1,900 190 :3
( semivolatile 2
"-Hethylphenol 680 680 . 380U 1
Benzoic acid 300 300 1 ,9OO.J 1
Butylbenzylphthalate 1,100 3,600 380U 2
b i s (2 - E thylhe.xyt .)pn.thal a te. 10.,000 73,000 38OU: 2 .
. .
Oi-n.octylphthalate 1,600 ',800. .3800 2
PesticidelPC8 . 2 '.
Dieldrin . 62 62 19U 1
I, ",(.' 'OOE 60 60' 19U 1
",'-' .,DDO '''6 120 19U 2
"eta llOl ~ .~ ~ 2
I A lUlli nun 2,810 '-7,500 1."0 2
Arsenic: 1.7 7_1 1.6U 2
BariUII 28.1 457 11 2
I Caa.iua 1.5 5.0 " 0.6 2
CatciUII 1 ,8l.O 29 . 500 20,200 2
ChrOllliUII, Total 9_8 2(,.6 3.1 2
I Copper 21 181 1.7 2
Iron 1,700 3.a30 1.720 2
Lead (,3.7 1110 0.9 2
HagnesiUII 3.190 3.190 8,360 1
I "anganese 21.9' 78.7 50 2
Mercury 0.14 0.56 . 0.1U 2
Nicket 3.7 11.2 2.1 2
I Pot8ssiua 176 766 310 2
Sit Yer 2.0 2.0 0.3U 1
Sodiua 33' 6,530 92 2
vanedi UII 1.8 - 4.8 1.6 2
I Zinc 136 522 . 7.9 2
Pere Marquette
I Riwr
Vot.tite ~ !!9& !!9l!!1 2
Acetone 76 76 35U 1
I 2'But- 11 16 10U 2
Tot~ '.0 '.0 Su 1
I 12
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TABLE 2
.... S of S.
O'2.8t.'dt
08"91
13
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1.
LaQoons
The sediments and surface water were sampled as part of the RI. The
MDNR conducted supplemental sampling in March 1991 to determine if the
soils underlying the sediments were also contaminated. The results
indicated that only the sediments are contaminated to such a degree that
remediation is necessary. Elevated levels of contaminants including
arsenic, lead, tetrachloroethylene (PCE), bis(2-ethylhexyl) phthalate
and pesticides were detected in the sediments. See Figure 3 for the
sediment area of concern. Similar contaminants were detected in the
lagoon surface water; however, the lagoons are now dry.
2.
Groundwater
Contaminants detected in the groundwater include PCE, trichloroethylene
(TCE), 1,1-dichloroethylene (l,l-DCE), boron, lead, arsenic, and
pesticides. Two rounds of groundwater samples were collected utilizing
both residential wells and monitoring wells. The contaminated
groundwater extends from the Wash King laundry facility and the lagoons
downgradient and north to the Middle Branc" Pere Marquette River.
Contamination may extend north of the river. See Figures 3, 4, and 5
for information on the nature and extent of site contamination.
3.
Middle Branch Pere Marquette River Water and Sediments
Sampling of both the surface water and the -sediments from three sampling
locations shown on Figure 2 did not indicate any levels of site-related
contamination that would pose a risk to human health or the environment.
4.
Subsurface Soils
Sampling of subsurface soils at monitoring well locations indicated low
levels of contaminants, including PCE, apparently from the contaminated
groundwater. This contamination will be addressed as part of the
groundwater remedy.
5.
Source Areas
Additional characterization of potential source areas, other than the
seepage lagoons, is needed. This activity will require an investigation
of the Wash King facility and surrounding soils during the RD/RA pre-
design phase to assure that any ongoing sources are addressed, as
necessary, along with the groundwater treatment. This investigation
would include, but not be limited to, dry cleaning solvent storage areas
and drains. Soil and groundwater sampling should also be conducted in
the vicinity of the historic proposed lagoon site near the C & 0
Railroad tracks (Figure 2). These lagoons reportedly received laundry
wastewater for a short period of time when PCE was ~n use. There is
evidence of wastewater discharge to these lagoons.
14
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I
}
}
I
-
LEGEND
? . -MW38 UOHIIOIllHO WELL lOCATION
~ NIO 1fIII/8Eft
TW01 !tIT \WO.L lOCATION AIIO
III NUU8t11
Am IIUIO~ WElL LOCATION
Woo ~~i;;) .~::::"';?O'E~( ,
;,;::-~-:~ --~,,~,....-_._. !...J.. 'f',,:. ''\, (};'!dl
'r"'l ~"!..~=J- ~#-~'''J:'II i~';;~::'~::';':';i"fi;%:1~~~r~':::'~~~-". ~~-':...,,~ j C.:...... }o ~ 'v\\ I
"'~ i it ~ ~----"'-'..............:..... "l.J . ---,.._.~~...:...;--....:...;.;:..;:;:..~.......,.... .. ~o '
~ 7\ r'~"......., "'~'''''''..~~......,.:~ -"""""""" "",~I,
. '( .'-'.._, ,.0---... .. -,-.........~
'. : .J'II ~~, ". \'~" --'-""""'"'''::-f:':~'o''' U
I \ /, ., 11), . . '. I. 0 300
.... ~
SCALE IH FEET
FIGURE 3
I
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v -
. ~ I
. J
I I J I
10
....
I
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s;;::.:; ;...;-
.
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.
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... -....
v
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-------
III.
SCOPE AND ROLE OF THE REMEDY SELECTED
This ROD addresses the final remedy for the lagoon sediment and associated
soils, and groundwater contamination at the Wash King Laundry site. The
remedy presumes that extraction of groundwater in deeper aquifers (below 90
feet) is not necessary. Future monitoring results may indicate that
extraction in deeper zones is warranted to prevent downward migration of
contamination that may endanger either the public water supplies (including
the alternate well) and/or water quality degradation of the Middle Branch Pere
Marquette River. To date, sampling data from the primary public water supply
well has not indicated that contamination has migrated to this deeper aquifer.
Additional soil sampling may indicate that there are sources to the
groundwater contamination other than the lagoons that must be addressed as
part of the site remedy. The estimated soil volume may require adjustment,
should other source areas be detected, or if the estimated volume of
contaminated lagoon sediments/soils is determined to be inaccurate based on
sampling conducted during excavation.
IV.
SUMMARY OF SITE RISKS
.
.
As part of the RI/FS, a risk assessment was conducted to determine if site
contamination could affect human health and the environment. The evaluation
compared contaminant levels at the site with state and federal standards,
considered the manner in which people could be exposed to site-related
contaminants, and estimated whether the contaminants could pose a threat to
human health and the environment.
A given chemical's degree of toxicity may be described in part by its
acceptable intake or its reference dose and, in the case of carcinogens, by
its carcinogenic potency factor. Cancer (or carcinogenic) potency factors
(CPFs) have been developed for estimating excess lifetime cancer risks
associated with exposure to carcinogenic or potentially carcinogenic
chemicals. A CPF is expressed as lifetime cancer risk per mg/kg body
weight/day, and is estimated at the upper 95 percent confidence limit of the
carcinogenic potency of a given chemical. CPFs are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-
bound estimate of the excess lifetime cancer risk associated with exposure at
that intake level. The term "upper-bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. CPFs are derived
from the results of human epidemiological studies or chronic animal bioassays
to which animal-to-human extrapolation and uncertainty factors have been
applied.
Carcinogenic risk is estimated by multiplying the estimated dose of the
chemical by its published or calculated slope factor. Carcinogenic risks are
assumed to be additive for all chemicals within an exposure pathway. The
National Contingency Plan (NCP) has established a carcinogenic risk of greater
than 1 x 10. as being unacceptable for human health. (This represents the
contracting of cancer due to environmental exposure as one in ten thousand.)
18
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The reduction of such risk to within the risk range of 1 x 10~ to 1 X 10.6 is
viewed by the NCP as acceptable. The EPA often uses the 1 x 10~ figure as a
desirable goal for adequate protection of human health and the environment.
Reference dose (RfD) values are normally reported in mg/kg body weight/day,
and generally represent the highest calculated exposure level below which a
given adverse effect will not occur. Reference doses have been developed for
indicating the potential for adverse health effects from exposure to
chemicals. The RfD is based on the assumption that thresholds exist for
certain toxic effects, such as cellular necrosis, but may not exist for other
toxic effects, such as carcinogenicity. RfDs can be derived for
noncarcinogenic compounds, as well as noncarcinogenic health effects of
compounds which are carcinogens. Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from contaminated
drinking water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty factors have
been applied (e.g., to account for the use of animal data to predict effects
on humans). These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcipogenic effects to occur.
.
Estimating the risk of a noncarcinogenic health effect is accomplished by
calculating the hazard quotient (HQ). This is done by dividing the dose
estimated to be received by someone exposed to a substance by the established
safe dosage estimate for that chemical. If the resulting answer is greater
than 1, then the exposure has exceeded a safe level. Adding all the HQs for
the chemicals of concern in a given route of exposure gives a Hazard Index
(HI) for that pathway. If the HI exceeds 1, there is a potential health risk.
For Wash King laundry, the potential exposure pathways were evaluated based on
current land use conditions, and on assumptions of plausible land use changes
which may allow additional types of exposures (i.e., future land use
conditions). Table 3 presents a summary of human health risk estimates
associated with the site. Pathways considered to be most significant at Wash
King are summarized as follows:.
Current land Use Conditions
* Exposure of children to contaminated lagoon sediment through
incidental ingestion and dermal absorption while playing in the
lagoons.
Potential Future land Use Conditions
* Exposure of future residents to contaminated groundwater
resulting from installation of a well within the contaminated
groundwater plume or by migration of groundwater contaminants
to existing wells. Exposure may occur through ingestion or
dermal contact. It would also be possible" for exposure to
occur through inhalation during household water usage.
19
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..
TABLE 3
[
Summary of Site Humaa Health Risk Estimates
Wash King I..3undry Site
r
et.'RRENT U.~D CSECO='iDmoNS
P-ialJv EXDOICd Popd,uion: Arca dUldftll
!.
INnaian ol ~ Alwrncd: 1nI--- apo8I'C (I 4ay1wed1..6
~ tr--) for IO~(a.c..daiJdfaa aces 510 15 yocan).
"..
f
L
NatUft: 0( Ex:Josurc: Incidcn&JIi inCcsaioo and clcrmal_ua with ~ aDd sadaco: "'1" while playin~ in the dry or wet sccpaCC lac-.
r
Medium H2Z~rd Indices
Dermal IncidcnW T c&aI
A~ion ~ P_way
Lacoon-Scdimc:nl 4.6c~1 3.le+OO ~
ua-.s.u:.-.: - 6.4c.()l 7.7e42. 7c41
Water
TOIJIi Sil.C Ri:W. ~+OO
Gna:r Risk
DemW IncidcnLal Tat.
A bsOf1'Cion ~ ~
I.Oc-06 7. I e.()6 1k.()6
7.OC~S 2.4c~ 9c-41
Se.()6
~
;
'L
FUrURE U:'\D USEco;i;DmO~S
. .
POIenti~\' E:::>oscd Popublion: On.Sile Residents
-
Duration Q{ ::oosurc:' Continuous cxposu~ 10 ccvundwater(l~mond\slynr) and iatcnniuant exposure 10 lubsurf:lee.sail and sediment (6
mont4s1yc:uj for a ~ident"s entin:: lifetime (70'yean). Intenniacnc ~ to River suriaee W~ler (I d~y/weelt. 6 monulSly~~r) for 10 yean
(i.t:., childr=: aea S to 15 yan). '.
7
t
. Nature of E.::.:>osun::: InceStion and dcnnal coaua (~- while ~ with -~ dnwn (rom a canuminatcd well.' Incidental inl~Gft 8Dd :
dermal COftUC with lacoon sediment and subsudaCe soil which -y be ~:ht io the C.-nd surface while COftStNCtinc an on..ite residcacL
IncidcnLal ic;=ion and denn81 contaCt with surface wUcr while swinaaia: in Ihc River.
Medium Hu:ud Indices Gna:r Risk
Dama1 lncicIcaW Tc&aI Dcnna1 Incidental Tatal
A~ioo InttCAa. ~ .~ion ~ ~
;, Grounciwucr 9.Jc42. 7 -Sc+OO Ic.oo 2.l eoOS 4.9c~3 Sc~3
.
-
Lac_...sc.:ment 2.21:+00 1.le+01 le+Ol 3.3c~S I. 7e..o.a 21:.04
f Subludace s..Ml I~.os l~oOS Je.OS 3.Oc~ 3.Oc~ 6c~
#
,
River Suda.: Water 1.2c~S 4.6c.os &.4S 1.2c~ 6.Oc~ 7e.(9
Taut Sill: RiK ~t Sc~3
~
'f' I.
i.
2-
.,..
Haz:ud iDdic:ics (HI) and aDCZI'Nb an: -ac.I for Wiwu = - ol aposarc(c.c- inca&ion). Values forc:ach 1QUt&an:---
to ~ . a tOtal risk CAiasatc.
A Cl:rrislc CAi-.c (HI) of &fC8tCI'thM t iDdiaia dac ....... far - I::" r ~ c{{ccu (c.c-livcr disease) to oc:aar in ....... capa8III
at - --1cft18ad duaaioo 10 a --=--~ mediI8a. A _risk Icwi ol cn:aacr thaa I.Oc.06 (Lc- - in a miUioo) is abowtbe
U.s. EP A -s poiaI ol dcpuUIn: for Supat'und &iIcs.
( scb-302p-1J1I:)
700C17SfZ!D.dt
20
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* Exposure of individuals to contaminated soils at a future
residence developed at the site (e.g., on top of the lagoons).
Exposure may occur through incidental ingestion of soil and
dermal contact. It is assumed that contaminants in either
lagoon sediments or subsurface soils at current concentrations
are made available for exposure as a result of site
development.
* Exposure of recreational users of the Pere Marquette River to
contaminated surface water. Exposures may occur through
incidental ingestion and dermal contact with surface water
while swimming. (Even though this exposure route is more
unlikely than the ones noted above, it was still considered in
the risk analysis.)
Under the current land use scenario (Table 3), the site appears to present a
public health concern for children exposed to lagoon sediment while at play in
the lagoons. The noncarcinogenic health risk (HIK4) is primarily due to
exposure to lead in the lagoon sediments and the carcinogenic health risk
(8xIO.6) is primarily due to exposure to arsenic.;n the lagoon sediments.
Exposure of children to lagoon surface water would not produce unacceptable
noncarcinogenic health effects, nor would it pose an unacceptable cancer risk,
based on the risk calculations that were completed. Unacceptable chemical
exposure from surface water, groundwater, or subsurface soil should not occur.
Site contaminants have not been above detection limits in river surface water,
and exposure to groundwater and subsurface soil under current land use
conditions is unlikely.
Under future land use scenarios (Table 3), the site appears to be a public
health concern due to potential exposure to contaminated groundwater and
lagoon sediment. Groundwater would pose a noncarcinogenic health risk (HI=8)
primarily due to the potential ingestion of PCE and lead. The groundwater
cancer risk (5xl0'3) would be due primarily to the ingestion of PCE, 1,1,2,2-
tetrachloroethane, chrysene, and arsenic. As with the current site
conditions, lagoon sediment would pose a noncarcinogenic health risk (HI-IO)
because of the potential ingestion of lead. The sediment cancer risk (2xlO~)
would be due primarily to arsenic concentrations in the sediments. Based on
the assumptions applied, exposure of on-site residents to subsurface soils and
exposure of recreational users to river surface water would produce no
unacceptable noncarcinogenic health effects, nor would it pose an unacceptable
cancer risk.
The Middle Branch Pere Marquette River sediments and surface water will not be
addressed in the remedy since detected contamination has not resulted in any
identified risks in excess of lxlO~.
Potential impacts to the environment were also assessed qualitatively, as part
of the risk assessment. Exposure to dilute solutions of ~aundry wastewater
may have had subtle effects on area wildlife. For example, detergents have
been found to remove protective oil from the feathers of waterfowl, which may
cause hypothermia. Relatively low contaminant concentrations in the lagoon
21
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sediments (and the current lack of wastewater) make it unlikely that wildlife
would be affected by lagoon exposure. If the lagoons are backfilled, there
may be potential for burrowing animals to come in contact with contaminated
sediment, but any effects would be expected to be minimal.
Actual or threatened releases of hazardous substances from this site, if not
addressed by the selected remedy, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
v.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The major public participation activities are discussed in Section B of the
Responsiveness Summary attached to this document. As required under CERCLA
Sections 113(k)(2)(B)(i-v) and 117, a public meeting and public comment period
were held on the preferred remedies as documented in the Proposed Plan for the
site. The public comment period was held between August 17 and September 15,
1992. Comments received during this time period are discussed and addressed
in the Responsiveness Summary (attached to this ROD).
There is an active mailing list of local citizens and other interested
individuals, including the media and public officials, who receive progress
reports about site activities. A total of four progress reports and one fact
sheet were sent out to individuals on the mailing list.
Also, three public meetings and one information session were held, dur.ing the
RIfFS, in an attempt to inform individuals of site activities and provide an
opportunity to ask questions and raise concerns.
A technical assistance grant (TAG) was not issued by the EPA. The purpose of
the TAG is to facilitate local involvement in site activities. The only known
local organization related to the site is the Clean Water Association, which
is now responsible for the operation and maintenance of the public water
supply, installed as a result of the contaminated groundwater from Wash King.
VI.
DESCRIPTION OF ALTERNATIVES
The Superfund goal of the remedy selection process is to select remedies that
are protective of human health and the environment, that maintain protection
over time, and that minimize untreated waste to the extent practicable.
Specific remedial action goals for Wash King Laundry include:
* For lagoon sediment, the goal is to prevent ingestion and dermal
contact with the sediments.
* For groundwater, the goal is to prevent ingestion and dermal contact
of contaminated groundwater by a hypothetical future resident.
Following is a discussion of the remedial alternatives that were developed for
both the lagoons and the contaminated groundwater.
22
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A.
lagoons
Laqoon Sediment Alternative #1:
No Action
The Superfund program requires that a "no action" alternative be considered at
every site. It is used as a basis of comparison during the evaluation of
other alternatives. This no-action alternative assumes that nothing would be
done to address the lagoon contamination. This alternative involves no direct
cost and no time requirement for implementation.
Laqoon Sediment Alternative #2:
Groundwater Monitorinq
CaDDinq (Act 64)/Deeq Restrict~encinq/
This alternative consists of construction of a Hazardous Waste Management Act,
1979 PA 64, as amended, cap over the lagoon sediments, implementation of deed
restrictions to restrict land use at the site, and fencing around the capped
lagoon area. Although both the Act 64 and the Solid Waste Management Act,
1975 PA 641, as amended, caps passed the effectiveness, implementability, and
cost evaluation, the implementation of an Act 64 cap would potentially provide
a greater reduction in water infiltration and i~ the leaching potential of
contaminants from the lagoon sediment than an Act 641 cap. In the FS, only an
Act 64 cap was considered in the evaluation process, not an Act 641 cap. The
EPA Resource Conservation and Recovery Act (RCRA) staff conducted a
preliminary review of the proposed site cleanup. The conclusion was that the
spent PCE discharged to the lagoons was RCRA listed waste F002. Therefore, an
Act 641 cap would be unacceptable.
The Act 64.cap would consist of placing a minimum of 3 feet of compacted clay
over the contaminated soils, placing clean fill over the clay to establish
final grade, covering the fill with a very low density geomembrane, placing an
IS-inch thick drainage layer over the membrane, placing an additional 6 inches
of topsoil over the drainage layer, and vegetating.
Land use restrictions are included to limit development of the Wash King
Laundry site in and around the capped area. Also, groundwater monitoring is
included in this alternative to assess and evaluate the migration of
contaminants from the lagoon area.
The estimated capital cost associated with this alternative is $236,384, with
an estimated annual Operation and Maintenance (0 & M) cost of $52,095, and a
total present worth cost (assuming 30 years of 0 & M) of approximately
SI,037,240. The implementation time required for this alternative is
estimated at one construction season.
Laqoon Alternative #3:
Monitorinq
This alternative consists of in-situ (in-place) solidification of the lagoon
sediment, backfilling with clean soil to the surrounding ground surface,
establishing vegetative cover, implementation of deed restrictions to restrict
land use at the site, and fencing around the lagoon area.
Solidification/Deed Restrict~encinq/Groundwater
23
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Lagoon sediment would be mixed with solidification/stabilization reagents
using traditional earth-moving equipment. An estimated 1,500 cubic yards of
lagoon sediment would be solidified in-situ. A treatability study would be
necessary to determine the type and amount of reagent to be used, necessary
curing times, and effectiveness for reducing the leaching potential of
contaminants from the lagoon sediment. The area would then be graded with
clean soil to a sloping or uniform grade, and vegetative cover established.
The land use restrictions, fencing, and groundwater monitoring would be the
same as those described in Alternative #2.
The capital cost for implementation of this alternative is estimated at
$439,015 with an annual 0 & M cost of $51,855, and a total present worth cost
(assuming 30 years of 0 & M) of $1,236,182. The time required to implement
this remedy would be approximately one construction season. Before
implementation, a treatability study would be required.
LaQoon Alternative #4:
Excavation/Off-Site Incineration
This alternative consists of excavation of the l~goon sediment and
transportation of the lagoon sediment off-site to a licensed facility for
incineration. The lagoon sediment would be excavated to a depth of 2 1/2 feet
below the present lagoon bottom. It is estimated that approximately 1,500
cubic yards of material would be excavated for incineration.
Since all contaminated material would be excavated, there would be no
permanent land use restrictions, fencing, or groundwater monitoring instituted
as part of this alternative.
The estimated capital cost for this alternative is $3,259,100 with no
associated 0 & M costs. The time required for implementation of this remedy
is approximately one construction season.
LaQoon Alternative #5:
Excavation/Off-Site Disposal
This alternative consists of excavation of the lagoon sediment and
transportation of the sediment off-site to a licensed hazardous waste landfill
for disposal. The lagoon sediment would be excavated to a depth of 2 1/2 feet
below the present lagoon bottom. It is estimated that approximately 1,500
cubic yards of material would need to be excavated.
Because all contaminated material would be excavated, there would be no
permanent land use restrictions, fencing, or groundwater monitoring instituted
as part of this alternative. .
The estimated capital cost for this alternative is $760,650 with no associated
o & M costs. The time required for implementation of this alternative is one
construction season.
24
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B.
Groundwater
Groundwater Alternative #1:
No Action
The Superfund program requires that a "no-action" alternative be considered at
every site. It is used as a basis of comparison during the evaluation of
other alternatives. This no-action alternative assumes that nothing would be
done to address the groundwater contamination at this site. This alternative
involves no direct cost or implementation period.
Groundwater Alternative #2: Monitorinq/Deed Restrictions
This alternative consists of the implementation of land use restrictions at
the site to prevent construction of drinking water wells in the areas of
groundwater contamination. Monitoring is included as part of this alternative
to assess and evaluate the migration of the contaminant plumes.
The estimated capital cost associated with this alternative is $13,125, with
an annual 0 & M cost of $169,670 and a total present worth cost of $2,621,462.
Since there is no associated construction with t~is alternative, there is
relatively no implementation time required.
Groundwater Alternative #3:
Chemical Treatment
Monitorinq/~Restrictions/Extraction/Phvsical-
This alternative consists of extraction and treatment of contaminated
groundwater using physical-chemical treatment methods. Monitoring is included
as part of this alternative to assess the effectiveness -of the extraction and
treatment system, and to evaluate the migration of the contaminant plumes.
Deed restrictions will be implemented to prevent construction of drinking
water wells in the areas of groundwater contamination. .
The groundwater would undergo treatment for removal of sodium, boron, lead,
and arsenic using ion exchange. The ion exchange process will also reduce
elevated levels of various inorganic laundry waste constituents and total
dissolved solids at the site. Following ion exchange treatment, the
groundwater would undergo treatment for organic contaminant removal using air
stripping, carbon adsorption, or oxidation/photolysis. The exact treatment
scheme will be determined during the remedy design phase. After treatment,
the groundwater would be discharged to the Middle Branch Pere Marquette River.
Land use restrictions would be implemented at the site to prevent construction
of drinking water wells in the areas of groundwater contamination.
The estimated capital cost associated with this alternative ranges from
$1,263,870 to $1,835,270 depending on the treatment scheme, with a range of
o & M costs of $358,082 to $1,044,415 and a range of total present worth costs
of $7,340,065 to $17,324,162, again, depending on the specific treatment'
scheme chosen~ Treatability studies would be required before this alternative
could be implemented. It is estimated that this alternative would require one
construction season for implementation upon completion of the necessary
treatability studies. Based on the information available to date, it is
25
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estimated that operation of a treatment system would be necessary for
approximately four years. This estimate may need to be adjusted as more data
becomes available.
VII.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
Evaluation Criteria
Each of the alternatives were evaluated using a number of evaluation criteria.
The regulatory basis for these factors comes from Section 121 of Superfund
Amendments and Reauthorization Act of 1986 (SARA) (Cleanup Standards) and the
NCP. Section 121(b)(I) states that, "Remedial actions in which treatment
which permanently and significantly reduces the volume, toxicity, or mobility
of the hazardous substances, pollutants, and contaminants as a principle
element, are to be preferred over remedial actions not involving such
treatment. The off-site transport and disposal of hazardous substances or
contaminated materials without such treatment should be the least favored
alternative remedial action where practicable treatment technologies are
available." Section 121(b) also states that the following factors shall be
addressed during the remedy selection process: :
The long-term uncertainties associated with land disposal.
The goals, objectives and requirements of the Solid Waste Disposal Act.
The persistence, toxicity, mobility, and propensity to bioaccumulate of
such hazardous substances and their constituents.
Short- and long-term potential for adverse health effects from human
exposure.
Long-term maintenance costs
The potential for future remedial action costs if the alternative
remedial action in question were to fail.
The potential threat to human health and the environment associated with
the excavation, transportation, and redisposal, or containment.
Section 121 of SARA requires that the selected remedy is to be protective of
human health and the environment, cost-effective, and use permanent solutions
and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable.
(A)
(8)
(C)
(D)
(E)
(F)
(G)
Alternatives were also evaluated using the nine criteria specified in the NCP.
These criteria are as follows:
Overall protection of human health and the environment addresses whether a
remedy provides adequate protection of human health and the environment and
describes how risks posed through each exposure pathway are eliminated,
reduced, or controlled through treatment, engineering controls, or
institutional controls.
Compliance with applicable or relevant and appropriate requirements (ARARs)
addresses whether a remedy will meet all of the ARARs of other federal and
state environmental laws and/or justifies a waiver of the regulation to
implement the remedy.
26
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Long-term effectiveness and permanence refers to expected residual risk and
the ability of a remedy to maintain reliable protection of human health and
the environment over time, once cleanup goals have been met.
Reduction of toxicity, mobility, or volume through treatment evaluates the
anticipated performance of each treatment technology with respect to reduction
or elimination of contamination toxicity, mobility, and volume.
Short-term effectiveness addresses the period of time needed to achieve
protection, and any adverse impacts on human health and the environment that
may be posed during the construction and implementation period of each
alternative.
Implementability is the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a
particular option.
Cost includes estimated initial capital and operation and maintenance (0 & M)
costs. Cost is also expressed as net present worth costs, which is the total
cost of an alternative in terms of today's dollars.
State/support agency acceptance reflects aspects of the recommended
alternative and other alternatives that the support agency favors or objects
to, and any specific comments regarding ARARs or the proposed use of waivers.
The Proposed Plan should address views known at the time the plan is issued.
Community acceptance summarizes the public's general response to the
alternatives described in the Proposed Plan and in the RI/FS, based.on public
comments received. Evaluations under this criterion usually will not be
completed until after the public comment period on this Proposed Plan.
B.
Comparative Analysis
The analysis that follows was performed using the above nine criteria as they
apply to each of the developed alternatives.
1.
Overall Protection of Human Health and the Environment
For lagoon alternatives, Alternatives #2 through #5 will reduce risks to human
health and the environment. Alternatives #2 and #3 may not be as protective
as Alternatives #4 and #5, since they require that contaminated material be
left on-site, whereas Alternatives #4 and #5 require off-site transport of the
contaminated material for either treatment or disposal. Alternative #1 will
not provide protection to human health or the environment, and will not be
retained for further consideration. .
For groundwater alternatives, Alternative #3 will provide the greatest
protection to human health and the environment. Alternat~ve #2 will provide
protection to human health from ingestion, inhalation, and direct contact with
groundwater by use of institutional controls and monitoring. Alternative #1
will provide no protection and will not be retained for further consideration.
27
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2.
Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs)
The State of Michigan has promulgated rules pursuant to the Michigan
Environmental Response Act, 1982 P A 307, as amended. The substantive
provisions of Parts 6 and 7 of the rules establish general standards for
cleanup of contaminated sites. These substantive provisions are considered to
be an ARAR for this response action. In general, the EPA maintains that
substantive provisions of state regulations, which are more stringent than
CERClA requirements constitute ARARs. These rules provide, among other
things, that remedial actions be protective of human health, safety and
welfare, and the environment. The MDNR's rules establish criteria for three
acceptable cleanup types which could be applied to satisfy the substantive
requirements of Part 7. Under the rules, a Type A cleanup generally achieves
cleanup to background levels (or method detection limit), a Type B cleanup
generally achieves specific state-wide (or standard) risk-based cleanup
levels, and a Type C cleanup is based on a site-specific risk assessment that
considers specific criteria outlined in the rules. Rule 705(2) and (3)
require that all remedial actions attain the degree of cleanup specified for a
Type A, B or C, or a combination of types. :
Since the owner of Wash King discharged laundry waste with PCE to the lagoons,
and the PCE is a RCRA listed waste F002, RCRA ARARs are applicable for
contaminated soils and groundwater containing PCE. Sediments containing PCE,
which are excavated from the lagoons, must meet either a treatability variance
set forth in land Disposal Requirements guide 6A, or the treatment standards
for F002 listed waste in 40 C.F.R., 268.41. After treatment, the sediments
may be land disposed off-site only in a RCRA permitted landfill.
More details on ARARs identified for this site are in the Feasibility Report
dated March 31, 1992.
For the lagoon alternatives, Alternatives #2 and #3 will not comply with
Michigan Act 307 Type A or Type B cleanup criteria, but would comply with this
regulation if Type C criteria are met. These alternatives may not meet the
1ocation standards, isolation distances, or the bottom liner permeability
requirements as specified in Act 64, which means a waiver could be required.
Alternative #3 may attain ARARs, but it can not be clearly determined without
treatability tests to confirm if desirable leach/release rates could be
obtained.
lagoon alternatives #4 and #5 would comply with all identified ARARs.
For groundwater alternatives, Alternative #2 will not comply with several of
the identified ARARs, including Act 307 and the maximum contaminant levels
(MCls) established by the Safe Drinking Water Act (SDWA). Alternative #3 will
comply with all identified ARARs.
28
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3.
Long-Term Effectiveness and Permanence
Lagoon Alternative #2, capping and land use restrictions, presents a reliable
means to control direct exposure to contaminated soils. The cap must be
adequately maintained to reliably protect against direct exposures. over time.
Groundwater impacts due to potential leaching of contaminants from the lagoon
sediment would also be reduced by placement of the cap. For Lagoon
Alternative #3, the purpose of solidification is to immobilize the
contaminants in the lagoon sediment and render it resistant to leaching as
well as control direct exposure by the use of land use controls and deed
restrictions. The long-term reliability of solidification is not known at
this time. Over a period of time, weathering of the solidified material could
result in leaching .of contaminants. For Alternatives #4 and #5, the
contaminated lagoon sediment will be excavated and transported off-site for
either disposal or treatment. There would be no residual risks remaining at
the site, however, there may be a transfer of risk from the Wash King Laundry
site to another location.
For Groundwater, Alternative #2 would not provi~ adequate long-term
effectiveness and permanence due to use of institutional controls only.
Alternative #3 would reduce the risks to human health and the environment by
treatment of the contaminated groundwater. The effectiveness would depend
upon the ability of the treatment system to efficiently collect and treat the
groundwater to achieve the cleanup goals.
4.
Reduction of Toxicity, Mobility, or Volume Through Treatment
For lagoon alternatives, Alternatives #2, #3, and #5 would not employ any
treatment technologies. Alternative #4 (off-site incineration) will
permanently reduce the toxicity and mobility of the contaminants by treatment.
The volume of the residual ash may be increased due to the treatment employed
by the off-site facility.
For groundwater Alternative #2, this criterion would not be met. Alternative
#3 would reduce the toxicity, mobility, and volume of the contaminated
material by treatment.
5.
Short-term Effectiveness
All the lagoon alternatives could present an impact to the residences closest
to the lagoons due to their proximity to the lagoons. Controls could be
implemented in all cases to try and reduce or eliminate these impacts, such as
erosion control and other actions taken to minimize dust generation. Also, as
a precautionary measure, air monitoring would be conducted.
Groundwater Alternative #2 does not involve any construction activities,
therefore, there would be no additional environmental impacts occurring as a
result of implementing this alternative. Groundwater Alternative #3 could
29
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present an impact to residences near the lagoon areas, due to dust generation,
however, appropriate controls could be implemented to reduce or eliminate
these impacts.
For all alternatives involving construction activities, which include all the
alternatives mentioned here, with the exception of groundwater Alternative #2,
it is estimated that it would take one construction season for implementation.
For Groundwater Alternative #3, it is estimated that it will take
approximately 4 years after construction completion to treat the contaminated
groundwater to acceptable levels.
6.
Implementability
All the alternatives for both the lagoons and the groundwater are relatively
easy to implement. Most of the technologies being considered for this site
have been proven reliable at other sites. For the treatment alternatives such
as solidification for lagoon sediment (Lagoon Alternative #3) and Groundwater
Alternative #3, a treatability study would be required during design of a
treatment system.
.
.
More time would be required in a design phase for both Lagoon Alternatives #2
and #3 compared to Lagoon Alternatives #4 and #5, meaning that remedial action
for the latter two alternatives could be implemented sooner than that for
either Lagoon Alternative #2 or #3.
7.
Cost
Lagoons:
8
Alt. Capital Cost O&M Cost Total Present Worth
2 $ 236,384 $ 52,095 $ 1,037,240
3 $ 439,015 $ 51,855 $ 1,236,182
4 $3,259,100 None $ 3,259,100
5 $ 760,650 None $ 760,650
2 $ 13,125 $ 169,670 $ 2,621,462
3b $1,263,870 $ 547,145 $ 9,675,130
3c $1,268,370 $1,044,415 $17,324,192
3d $1,835,270 $ 358,082 $ 7,340,065
Groundwater:
8.
.
O&M costs refer to annual operation and maintenance costs
This alternative includes ion exchange and air stripping.
This alternative includes ion exchange and carbon adsorption
This alternative includes ion exchange and oxidation-photolysis
b.
.
c.
d.
8.
Support Agency (EPA) Acceptance
The EPA, as the support agency for this site, supports th~ remedy chosen for
Wash King laundry.
30
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9.
Community Acceptance
The community accepts the cleanup plan chosen for the site. Concerns raised
during the August 24, 1992 public meeting are discussed in the Responsiveness
Summary (attached to this document) and will be addressed in the design and
implementation of the site remedy.
VIII.
SELECTED REMEDY
The selected remedy for the lagoon sediments is Alternative #5, excavation and
off-site disposal. It provides the best solution to the contamination as
revealed by comparison of the alternatives to the evaluation criteria. The
volume of contaminated sediments is relatively low. Therefore, an extensive
on-site containment system would not be cost-effective. Also, on-site
containment may not comply with all the identified ARARs, specifically, Act
64, the Hazardous Waste Act. Due to the geology at the site (i.e., the
extensiveness of sand below the lagoon), containment at this site may prove
unreliable, eventually requiring removal of the sediments at a later date.
This would result in additional expense for addressing a relatively small
volume of contaminated material. Due to the vapiety of contaminant types
detected in the lagoon sediments, as well as the site geology, the reliability
and effectiveness of on-site treatment or containment is questionable. Off-
site incineration would effectively treat the organics, but not the inorganics
(metals) resulting in only partial treatment. Solidification of the lagoon
sediments may not be an effective long-term solution to the contamination. It
is not a proven technology for all the types of contaminants found at Wash
King, especially the organic compounds.
During removal of the lagoon sediments, a thorough dust control program will
be necessary and ambient air monitoring will be required to ensure that
unacceptable levels of contaminants do not become airborne. This is
especially important due to the proximity of the nearest residential home to
the lagoon area. Also, multiple handling of the contaminated sediments will
be avoided, if at all possible. This could be achieved by loading the
contaminated soils directly into rolloff boxes or other appropriate containers
for direct transport off-site.
After lagoon sediment excavation, the underlying soils will be sampled and
analyzed using procedures specified in the MDNR Verification of Soil
Remediation Guidance (or the most current MDNR guidance) to verify that all
contaminated soils above state cleanup standards (Type B criteria) are removed
from the site for proper disposal.
The selected remedy for groundwater is Alternative #3, involving treatment of
the contaminated groundwater. This alternative would most effectively satisfy
the requirements of all the evaluation criteria as described above. The
inorganics would be treated by use of ion exchange, whereas the volatiles and
other contaminants would be treated by use of air stripping, carbon
adsorption, or oXidation/photolysis. The actual treatment design would be
determined after further testing at the site and an in-depth evaluation of the
specific treatment schemes.
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TABLE 4
RisK-Based Cleanup Criteria (307 Type B Cleanup Criteria) for
Contaminants of Concern
Wash King Laundry Site
Contaminant
Tetrachloroethene
bis(2-ethylhexyl)phthalate
Di-n-octylphthalate
Dieldrin
4,4-DDE
4,4-000
Aluminum
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Nickel
Contaminant
1,I-Dichloroethene
Tetrachloroethene
1,1,2,2-Tetrachloroethane
Trichloroethene
Chrysene
Beta-BHC
Dieldrin
Alpha-Chlordane
Gamma-Chlordane
Arsenic
Boron
Lead
Sodium
LAGOON SEDIMENT
Maximum
Concentration
Type B
Criteri a (1)
190 ug/kg
73,000 ug/kg
4,800 ug/kg
62 ug/kg
60 ug/kg
120 ug/kg
47,500 mg/kg
7.1 mg/kg
457 mg/kg
5.0 mg/kg
24.6 mg/kg
114 mg/kg
0.56 mg/kg
11. 2 mg/kg
GROUNDWATER
14 ug/kg
40 ug/kg
2,000 ug/kg
0.04 ug/kg
2 ug/ kg
2 ug/ kg
1. 0 B mg/kg
.0004 B mg/kg
40 B mg/kg
0.08 mg/kg
2 . 0 B mg/ kg
0.08 mg/kg
0.04 mg/kg
2 . 0 B mg/ kg
Maximum
Concentration (uQ/l)
Type B
Criteria (uQ/l)
0.9
1600
32
20
6.0
0.023
0.039
0.049
0.050
6.8
1,400
10.5
515,000
7.0
0.7
0.2
3
0.003
0.02
0.002
0.03
0.03
0.02 B
600
4.0
150,000
(1) Act 307, Type B criteria updated through March 16, 1992, MONR interoffice
memo.
B qualifier: If the local site background concentration is higher, it is used
in place of this numerical Type B value.
32
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The cleanup goals that will be used are based on the MCLs and non-zero Maximum
Contaminant Level Goals where relevant and appropriate, as promulgated under
the SDWA or more stringent state standards. Pursuant to the SDWA,
contaminant-specific levels or MCLs have been promulgated and are periodically
revised, which represent the maximum permissible level of a contaminant in
drinking water. The State of Michigan has also set cleanup levels for
groundwater and soils under Act 307, which is an ARAR for this site. (See
Table 4.)
Since there is groundwater discharge to a surface water body, the cleanup
goals will also take into consideration discharge limitations for protection
of the surface water as calculated in accordance with Rule 323.1057 (Rule 57)
of the Michigan Water Resources Commission Act, 1929 PA 245, as amended, which
is also an ARAR. The National Toxics Rule (NTR), which promulgates numeric
criteria for several states, including Michigan, will also be considered when
determining acceptable cleanup levels for the discharge of treated groundwater
to the Middle Branch Pere Marquette River. This Rule became effective on
February 5, 1993.
The CERCLA requires the use of promulgated state cleanup standards, if those
standards are ARARs that are more stringent than equivalent federal standards.
Therefore, cleanup standards will be based primarily on Act 307 cleanup
criteria and Rule 57 values or NTR criteria, where appropriate. Groundwater
will be treated on-site until the cleanup levels are achieved satisfying
either a Type A (background or method detection limit for each contaminant) or
a Type B cleanup. Since the groundwater is utilized as a source of drinking
water for area residents outside the zone of contamination, a Type C cleanup
for the groundwater is not appropriate.
The treated groundwater will be discharged to the Middle Branch Pere Marquette
River meeting the National Pollutant Discharge Elimination System discharge
limits to be obtained early in the RD/RA phase of remedy implementation. In
addition, any discharge to the atmosphere will be in compliance with the Air
Pollution Act, PA 348.
The selected site remedy will provide the best balance of trade-offs among
alternatives with respect to the nine criteria used to evaluate clean-up
alternatives. Based on the information available at this time, the MOHR and
the EPA believe that the chosen remedy would protect human health and the
environment; would comply with ARARs; would be cost-effective; and would
utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. The groundwater
remedial action would satisfy the preference for treatment as a principle
element.
Additional site characterization is necessary to verify that contamination
above the acceptable state and federal cleanup standards are addressed. This
work will include additional groundwater and source investigations as part of
the RO/RA pre-design phase as previously discussed in this document.
33
-------
. .
~ . ,". .
. .
'.
. .
-',. '.
TABlB D-'
DBTAPJD) ARARa ANALYSIS
. WASH ICINO U.UNDRY SITS
SOILS ALTBRNATIV!!S
TABLE. 5
.0 ...
. .
'. .
. .
'.
.'
. . ", .
, .
ALTE~A'IWeSS
eXChVATIOHl.OPP-SITU DISPOSAl,
STATS Of MICHIOAN - CHEMICAL-speCifiC ARARI
. . '. 1~ .~.,. '.,
..; .'
MeRA - Aol 301. P.A. IPiZ
RulOi plOwldl", iho procedurel ror
cScle""lAIn; cl~ crflertl ror .
'onlalfllftlnll IIII~nd,;"er. IUIClce
...ler, lOll!. Ind air:
MAC R199.5701 - R299.n27. .;
The 1011 clCln-up Illndard. cORlalned In Ih~ rulu
.re Ipplle.ble beC'UIC a loll rc",:cdl~llCllon
cleftn-up II "'Inl pel!onlle~ ..~, '!I~ ~lIe, '
11111 Illem~llve will mecllh~ cl~.n-lip 11~",bldl,
S1:ATB OP M,lCHioAN - lOCATION SPECIfiC ARARI
. .
, ..
. '.
.. .
.".
I:.JJ '..
: 0°
,'.
No locilion-Ipee!"c A~A~I Idc~t!n~d '
. '.: .
~~
ST A 1B Of MICHIOAN - ACTION-SPECIFIC A RARI
. .
. .
- HWMA - Iocr 64. P.A. 1\119
ROl'llillonl, conl.lnlnl Il8n4ardl
ror ICDeril~n .heS '''nlpol1o"
or /lUarcSoui wlilo, .nd ownon
IneS oPC"'Of' or hUlfdoUI Will.
Irealm,iII 110"1° .nd dllpolll
C"IIIIIOI: .
MAC R299. 960I-R299.9613:. ~2,99.9619.R299.CJ/"12
Thele requlremenll .re .pplleibio bc'e~l1Ie eo'nt3mlll~led
10111 will be dllpoled al an oCC-',itt I~ndnll.'
11111 IlIem~llve wi!} comply ,wflh Ihoac rcq"lremellll,
The oCC-IUe I~ndlill C.cllll)' Inl)':bll ICtI,ilrcd I~ Ilul
Ihe con..mlnucd loll In oldcilo"onllll)' \VIIi. Ihe 1~lId
dhpolll rcqlllren,.nli ej,!,ul~'ed ~ti },el 6-1 3dll,IIIhiullvc
nile 627 (R299.96271. . . " .
, .
. " .
. I, :
.. .t"
'. .
I . .';
..:,r:' . ,
.' ",
,> .
-I"' .
'.
.. ..- -'-'-
. ,
. .--..---..-
Page 1 of 5
'.
. . .
.,
.'
, '
. .
, .
.~
. .
-------
, '
"
TABLB D-'
DBTAI1.ED A~A~. AHA LYSIS
WASH KINO LAUNDRY SITI\ '
SOILS A1.TeRHATIVI!S
, ,
Page'2 of 5
TABLE 5
"
'. """',
ALTeRN/. TLVI! SS
EXCA V A TIONi or~-sfrE DlsrOSA I.
," . "
MAC R299,9301-R299.9m
, ,
. ~"
. .;. " " .
Oenellior requlreme~" would, be 'rplluble
lor tll hau.dout W"lc,l"n'pOrt~,a olr-.lre
(1.0, excavated haoon iedlmen"~" ~ '
. . . ,t.' . "
Thl. allematlye will comrly wllh th'nc' requlremenlt,
. .' .,0;,;
"
,".. .
"
. .,
MAC R299,9-IOI-R299,9412' , , '
. '", .' ~. ",
... ...' .'
. . T"ntporter requlr~mcnll are'.ppll~I~!c 10. all '
orr-.II. thlp01enli orlura.dout wa't~" ,
(1.0, excavated haoon tedlnlents~, ",,; ,',',.
. .:f': .
This tllemallye will c001(11y WIIj,'I~ele rc qllire III e'nll ,
, "
, "
, ,
SWMA" Ar::T 6041, p,"', 1911
Ruin preacriblna tho rCCjulrcmcnll lor
n~w 1M .xliII", U"ltlry IlndOn
'lcIllU... ,1'111 nil.. lOver oonllN~lIon
~nnl\II". pl1lOldunl, IIRdOn dOllln,
,roundwltcr qUl11l1, ponnubllll, 'nUnc.
~lo8ll11na ploc~duitl; .nd operltln, '
requi remonll. "
Not tn ARAR
, "
. '
'. ..
,:': 0'- .
'.' ,,: .
. .;.. : ,0,:'
" "
. ..'
. . . . '0" ...',.
',' "
. ,0 .' '.
. ,'. "
','
", '..
,"':', .
"
',', "
. '
":'.' .'
"..",' . .
. '. .
..' ,.
, '
. .:.
. .. "',
. .. : '.::'.: ~ "
, .' .
, "
, "
..
,-
",
. ':.,
, ,
tn
f')
. ","
" ,
..
"
-------
,.
'.
-
:-
_.
-
-
-
-
"...--'-
'. .
.,. .
.. ".' '." ....'
.:" "':
TABLE 5 '
..' "
Page'3 of 5
TAILS D.' '
DBTAIUID AaARt ANAl-VIIS
WAlH ICINO LAUNDRY SrTI
SOILS ALTI!RNATI...es
, ,
AI.rr:RNl,.tIV~ !:~
I!Xc;", V A 1"ION"0I'11~:;nl!'III~I'II~;1\1
. ~-_.........
APA - ACT JoC...r,A, 1965
Rul.. ConIJIDI~. cmlllloni
IImlullonl 1l1li prohlbltlonl rDr
pl"iculate rnaUtr. tu<ivi elUI'-
,nd vohllli o,.lnlo compound I.
MAC R336,1311-R336:1373; R336.1901
Thele requlremenU ire Ippliu\JI~ bc~aule uClvntlulI
ICllvillel mlY bo a potenllal, I.o~,r~o.~~.~ugillve dUll,
. / ." .
Thh allemallve "illl comply ~Ii~ Jh~I,e ,eq\ll.elllel1l1.
, '
,
'"
. :.
.". ,
"
. .::~ ":; :.' ..
" .
. .
.' '.
MAC R323.1101-R123.I7I~ ;,,:":' :'
, .
111CIO requlromehll arp .apl'lIc,ablo'bf,ClUIO uuvall..n
aellviliu would In"'olve elith c"'.~8ij'llId Ihe pOlenlil1
ror loll erollon. ' ,,', ;~.
I
Thll allemallve will compIYI!(I;hihCl~ ,cljukemenll.
\0
I"')
SI!3CA. - ACT JoC7. '.A. 1911
Reluliliona pllKrlblna tho
reqUlrtllllnil ro, loll erotlon Inll
. aocIlnltf\IItlon control mCllurel ,nil
procccluru,
" ,"
'. ::;".
0"', '0
. .
~RCA. - Ael24S. P.A. 1919
TheM rulu centaln $1110 walU
11111111, IlIn48rlll. trealmenl planl
openlor Rqulremenll, Inll
..lIlcwate, repo"'"' rellulremenll.
Tho rulca altO Implement I wille
Imuc'nt ellacha,.1 Ifllem
compallble wllh NPDES. and rrovlde
ror iht noa-deludilion of
iroundwlllr.' . .
SeelloR 23U(I): " '.
MAC R323.'2201-R313.2111,", ..
. ..:.',' . .
11.010 requlremenll ire al'~Uc"bJ~:be~llIse a diacharge
10 Iho groundwllU h occurring,;' ',:' '. '
.' ~:.~. :
11,1s IliemlUve will eomp'iy. wi,~,'he~t requlre;"eIlU.
", .
" :,Y; ~ '" '.
.,
: "
. .:.
. '
Setllon '251,712
. .
, MCLA - 1S1.n1
Ruin l~e"!IGI Iho rcduellon ~r
rnilimum i"l loada durlnllho
pcrl~ or MarCh, Apr\1. Inll MI~
(1... hOll laWI).
"0'
This req"lr(m~nl h .ppllcI\Jle,bccIIlS~ ~'cavll(d wulcs
'could be unnsp;r1ed rromlhe .Sli~, d;,,1111: Ih'o'l\,olllhs III
MftlCh. April. or ..toy. .
. ...;
This nlle""lIve will cn,"ply \\'lIh 11,11 1~'I"ilC",<"I.
.' ,.
, . .
.. .:' .
-------
.'
. 't.
TABLE 5'
, ,
, "
TA8LBD-" ,', .
DBT~IU!D ARAR. ANALYSIS
WASH ICJHO U.UH~8Y SITS
SOIU AL TeRNA TtVES '
, '
"
" .
.. 0"::'.'
ALT!!RtiATI~~SS' ,
I!XCA V A TIONI OPP-SIT!! DI$POS'A L
. ,', .
0.' .
" ,
I.; .
, ,
MINBRAL WELL ACT - Act 'IS, P,A, 1969
Ruin doecrlblna ~ polJ11ll1lna
nqulrcmlnU ror, driliJaa brine,
Itonlo, dl.pOul, and tnt'",elll,
Not In ARAR
',' .,' .
.,,'. "','
. ..' :
"
..
. .,'.-','
. "0
. "
, '
. '
, :,"
"
,'::: .
"
.,:0" ;,.'
MIOS~A - Ae' I~. P,A, 195. ,
Rule. conialilllll OCC,upallonal health
Ind ..rcty lUodard.. Tncludlni '
conllnICil~ .nd conll,nlCllon relaied , '
aetlvillu: ,,'
Con.tructlon Sarely Slan:hrdl (p~rt,i:-~:~)
. '
ThclO requlremen" .,0 appllCiblC becailiC eonllNellon
Iyro aetlvltlu will lake. phee al tlw.llo:if,o, car1h
",ovlnl aei\vlllel, heavy ~qUlpm'e~\?~e!'.IIOn), '
~. ~ ." .
Thll alternative will comply with ~~~~~~eqUlrenlen",
. . '0
PIIDBAAL - AcrIOH.~PECIPIC ARAKI
..",
~. .:": .
, ,
" ,
I\.f.SOURCB COHS!RV A TIOH AHD RI!COVERY ACT.
40 CPR P.st 2~2U
RelUhllOGJ conlalolnj ~tandarda
ror leocrilon .nd Inoipostell or
haunSoui ",..II, ,rid owneR and
opent,,, or haurdoU. ",..II trealment,
atollio, and dltrolll racilitlu, '
HOl an ARAR
i. .
:..
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. .'"
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, , ,
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"
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"
Page 4 of 5
, ,0
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,
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"
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, -
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-------
T A8LH D-;
DErAILeD ARAR. ANALYSIS
WASH ItIHO LAUNDRY SITS
SOILS ~LT!RNATt,~!S
TABLE 5.
.' .
Page 5 of 5
.'f .
. .
. " ..
.0. .
ALT2RNAnv.,255
2XCA v A TIOHI opp-sire: DISPOSAL
CLEAN AIR ACT -Ao CPR ParU SO. 60, .nd 61
RCIUllllool cI",blhhlna nilional prlm.ry .nd
Kconclary .1I1~~lcnt .I~ qullIl, .lInclalll.. atandud.
ror InclDonton. and cailnlon. It.aoclardl ror
h.II,rdoul' .ir ~lIullnll.
HOI .n ARAR
,,',
, '
,",
"
, ,
i:' .
. ," .
. '
.' .'
. .
'"
... .
. ',:.""".
"
, '
, '
, ,
. .
"
D,O, T. Rul.. ror Ibl Tnniportilion or
Hl1lfdoUi M.lerl8l. -~, CPR Pari I 107 Ind 171
P.rt ioi prtloiibti the timrdoul flfOIram proccduICI
uIJllu4 bY.virtoul "eOclll pcrulDln,lo Ihe
tllDlport1llon or h8!,rdoIil m'lcrhla. ,
P.rt 171 COnIlIRl "M,?I Inrorm.llon. ",ul.llonl,
.nd dennldon"Oycroln, the I"nlporullon or
h.llrcloul ",.Iutlla. . .
.., CPR PlluI07 Ind .71
. ,
.:..
. ':. .
co
C"1
, '
Th"e requlrementl w~uld bo .pplle.bio !o, .11 wul.1
',,",porttd orr-litt (I,e, ~xclY'l.d Iag0c9h'"dlmtntJ),
. .. . .
Thll .lItmotlyt will tom ply with 'h~~~:',,~ul~clllcntJ,. ,
. . ,0'
0: I';
, .
, '
, .
"
, "
. ,
. ,
.' ,
. ,
to. :". '"0',,:: .'
"
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.
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.;.00
..' "
.' ',','
, ,
.. ;': .~. : ::.
---... 0---_--' - .-.
-------
..
-
-
'.~
.'
. .
. .
.'. .
TABLS D-4
DBTAILBD.ARAR. ANALYSIS
WASH KINO LAUNDRY slTa
OROUHDWATER ALTBRNATIVI!.S
TABLE: e'5 ;
" ,
.',. .
AlTERHATIVe03!', ' .
MOHITORINO/DeED RESTRICTIoNs/exTRACTION
PIIY5ICAl-ClleMICALTRi':TMENT,
.. .
5TATQ Of MICIIIOAH,CIIJ!MICAl-SP1!CIPIC ARARI
SDWA - AaT '99, P.A; JV76
IIccul'IIOIII .llablllhl"l MCL', ror
cclUln coal.mllllnl, In Iddilion 10
\he PeeSenl MCl'l.
MAC R31S.101S01- R325.10607
Thea. requlremcntl lie' nol 'l'plieDble ~c(.ault Ih'
Iqulrer underlying \he Ille II 1101 ulcd i'
-------
-.
---p
>:---
-
. ..
... .
. .
TAILB D..c .
DBTAILED "RARe ANALYSIS
WAiH .clHa LAUHDR'( arrB
OROUHDWATER ALTERNATIVES
~~BLE 6 .
. .
..',.
, .
. '
, '
'.
. . :.
ALTJ!~j\TI'-:I!O~. .
MONITORIHOIDEED RES'rR~CTIONS/EXTRACTION
PIlYSICAL-CHEMICAt:.TREA TMEHT
PEDERAL - CHeMICAL-SPECifiC ARARI
pedora' Wiler Pollullon Control Ael (Clecn Wile, Ael) -
SJ V.S.C. I1JI
~lloo )OC provide. ro, Iho doveloprnenllnd
publication or wa.or quallt)' crUottl ro,
bwnln hullh Ind .qualle lIro,
Wlte' qUlIiI)' crllerla lie nolle;llI)' e~rorcelble.
.llndlldl .nd 110 tllereroro nol 'ppilatble. HowevCl,
Ihe)' uo IClevlnl .nd .pprop,I.IO IICh"l~ Ihe)' .
.,
ululale IlluIUonl Ind cllCumlllnC1:lllIrnelenlly
Ilmlllr 10 thole Illho 511e. .
Coneenlnllonl or lI,enlc. Ill'hl-chl~nI~ne. Clmml-chll.,.!.ne,
dieldrin. 1.1.2,2-letrlehloroclhln'o, l!tr..~i,lo'nelh~ne, Ind
III~hlo'o!hene exceed Ihelr rCI~e!I~Ctw.~!C' qllllll)' erilerll
ror p,olecllon or hU!1l1n heehh, '; WII~r lju!lIty, erlle,l. IIC
nol IVlllablo lor bcll-imc. ch~~n'e.. .oilium, Ind boron,
',' " .
Thll al'emilivo will mecllhe w,"er ,qu.llly erllerla
ror tho eompoundllhied Ibove., .~. . '
.'
..
'j
ST A TB Of MICHIOAH LOCA nOH-SPECifiC ARARI
. -
.
thlural River Aea - ACI23I, P."- 1970
ltulei ao prtvena "olOClcal damalo duo
10 I8\WIM cIov.lopmenl within Iho .
IIIlural river dhlriel,
MAC R28J.ISI-R281.160\ '
. '
. -,
" :. .:
Thele ,equlremenll irt appllcalile bCCluic conslruCllon
or Iho croundwller t,c.tmenl ,Yllc.m: !I'IIY I.ke phce
wllhln I dCIICnl1ed nll~rll,lver ~1.!!,lcl.
.
11111 IlIem.llve will comply wl!h,lhc,e .req~lhClnenll.
. ..'"
.. . .
, .
:::-".\,"',' .
0: . ", ~
'.0.
..
, ..,
, 1
.'. .. "
'. ,.'
. .
. .
..
Page 2 of 5
, .
'~
'.
-------
, ,
".0' . ,"
. :
I"",,: '.','
TABLS D-.4
DIrl'AILBO AMRa ANALYSIS
WASH KINO LAUNDRY 8ITS
OJ(OUHDWATBR ALTeRNATIves
.: ~ '.
"", " . .
. TABLE '6. "..""
, .
'1 .: ~.
~LTB~A T;VE 03
MOHiTORINO/DEliI) RESTRlclJo~SIEXTRACTIOH
PHYSICA L-CHEMrCA t:",U!A TM EHT
,,' .
STATB Of MICHIOAH ACTIOH-SPEClfIC ARAR.
. .
HWMA - ACT 64. P.A, 1979
Relulll'lonl eonlllnln, Illndudl
ror lenellioll Ind IlIn'rortell
or hlurdo\ll "1"0, Ind ov.'nera
Ind ClpClIlOri or hlurdOliI ....10
'Rllmenl .Ioralo ~nd dllpolll
heliltlu.
MAC RZ99.9S01 - R'299,9523; R199:9601 . RZI/9.96'l'l;
MAC RZ99,9611
The.e 'equlreOlenll Ire. Ip"lIelble' be.alule Ihe iio\lllllw.le,
10 be I,elled Ind Ihe liCilmenl'e.hl,"I~ (I,e, ."enl.
e'lbon, Ion ueh.ngi l\I~dh) ni.t bo ,~'U.U~OUI' .
. '
11.1s IlIem,liye will ~onlply wllhl!'F.e rcqulr~;nelll',
, '.
. MAC RZ99.9301 - R199,9311
, '.
Oener.lo, requlremenll would be Ipplleitrle ror .11
hlllldoul wnle IlInlpor1ed orr-i!le (i,( .pcnl ei,hnll,
Ion ueh.nge nlcdll), : .', '. ", '
. . ."~ i',.
Thll IlIem'llvc wllll:(Jm~ly wlih ih~le,reqUlrcmcn~.,
" '
, "
MAC R199.9~OI - R299,9411 ' ,
. : ," to,
TllnlportCl'cqulrenlenll lie i"pllclblc ro, III
orr-Ille .hlpOlcnllllr hlu,dou~ w..,e' (1:1, .pcnl'
cubon, Ion uehlngo Rledll). ' '. " ' '
11.i. Dllcmftllve will CO."'I,ly wilh Ihcle'rcquirc,'lIell",
. .
APA - ACT 3-41. P.A. 1965
Rulel conlllnlnl cmlnlonl
IImlllllonl ond prohlbltlonl ro,
"artlcul"1 miller, rUlllln dllil.
.nd YOlllilo o'llnle eompoulld~.
R336,I90I; R336',1371-IJ13; Rn6;1101-R336,170'l
, ,
. ......',
11.ue 'equlrem~nl1 'i,c ~l'pll~D~I~ ~c:ule cnn"nI~llnn
lellyille. (I,e, lruhnenl.Ylle",. pIping) lie pol~nllal
.ou,cu oC rlll:\llve dU'I: In Iddi!iD.!.,i.I' ~lIIlulnul
Cron' Ihe Ilr .lrlppllll untl !II/y'bc~; Ibu;ce nr yul.liI~
01£,"10 eon,po!lI1dJ, " . :. :. '. .
This Dllen'ftllye' will cOlIIl'ly ..'ill, Ihc,lf ,eqllir~IIICIII!,
.. .". .
. J'
."
Page 3 of 5
.....
~
"
'". ..
. ,
, '
-------
~ ",: . .
TULS D-4
DBTAILBD AItARI ANALYSIS
WASH ICIHO LAUNDRY SITS
OROUNDWA'rER ALTERNATIVES
TABL'E 6:. '., :"
Page 4 of 5
, .
~LTBRNAra\tE!03 .
MONITORIHO/DEBD RESTRICTIONS/BXTRACTION
.. ..
PHYSIC"'L-CH~IC"'L '{I(I!A TMENT
'. .
SESC... ..ACT "'7, P.A. 1912
Re,ullUolIIl'nlCrtbl", lho
rcqulRmenll lor 1011 ero.lon 1.4
IC4lmenlll!oa eonlrol mellurn Ind
proccduru. .
. . .
MAC RJ23.nOI-R32U714 :..:' ~ "::.
ThCle rcqulrcmcnlllle .ppllcabl~ ~~a(lIc con~lruclion
Inllallallon 01 !he trealmenl 'ay,,,~m iilld" plpln, may
Involvo cu1h ch.ncCl ind !he '~I~~II~I lOT loil crollon.
.' .
, .
. .. .
Thll .llcmallve will con~ply,vlih'lh~"C !i!1I)jICl~ICnla.
.' .
.' .
MIHEAAL WELL ACT. Act 315, P.A. 1969
Rulu clelCnblll& rh. permllll",
requiremenlilor drUUn, bnn.,
Iioneo, dlepOul, and left well..
MAC R299.22SI .'R299.2268'
". :
, ..
..'
"ThclO requlrcnlCnl.llc .ppIiCiblo' bcc.ui~ ~louridw~lcr
monllollnc weill may be.lnllaUed:or replked..
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Thll .lIemltlvc will comply wllh'lheae 'I~qulrclllenh.
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MCI.A~ 2-'7.722
Rule. eovernlne lb. reduction 01
mutmurii ulo loadl durlne tho
period ol""rell. April, and M'y
(1.0. lroft II.'VI).
Section 251.722
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Thll ,cqulremenl II ippllc..b!c b~c;I\lIe wuiCi .
(I.c. .penl cllbon, Ion uehlnee me.dll) could be
l"nlpol1ed I,om I';. .Iio durl.ne thq:~i~tllI ur .
Much. "1',11, .nd May. .' "
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Thll .llem.tlve will comply wl~h.~II.!'. requirelllcni.
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MWRCA - ACT 2oCS. P.A. 1929
, 1;1>c1O rulu eonl.lo SUlo w.ler
qwlllJ 8I.ndlrd.. 1/'CIlmenl pl.nl
openlo, rcqulremcnl'. Ind
","I0....I.r nl'Ol1ln, requlremenl..
Th. !VIII 1110 Implem.nl I 111111.
,ml\Ull dJlCha... iy.lem
,emp,lIbl. wil" H'De.t, Ind provide
tor \hi non-dcartdallon 01
aroundw'lcr.
Secllon 323.6(I)..323.6(b), 323:1 . '. ::.
MAC Im3.1~I-R3n.1116: RU3;l2il:R313.i236
MAC R323.2101-R323.216O; R323.2201-R)13.22J1
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Tholo rcqulrem~n\llr' '''rpJlC'~I~.~Ullle i dl.ch~lr:e
10 Ihe eroun~w.tcr .n~ 10 .urr.C:c')oi:.le, Ii octutiuG.
11118 IllOmallyo will co"'rly wl!1iiilei~ :,CiJUlrem~nl',
Includlne only Ihe .ub'.t.nllvo"elJulrei~~~ In nllCi
R 313.2101. R )23.2160 rc~~'~lh~HI'DES ,?,"lIillinC.
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TAILB IH ,
DBTAILBD ARARI ANALYSIS
WASH JaHO LAUNDRY SrTa
OROUNDW A T1!R ALTERNATIVES
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TABLE 6
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ALTERNA'tIVEQJ' '
MONITORINO/DeeD RESTRICTIO~S;EXTRACTION
PIIYSICA L-cil EMICA C.TRJ!A TMENT
MIOSHA - Actl~. f,A, 19~
Ruin contJlnlna occupatlonll hCllth
Ind urcty ,iindud.. Inclucll~1
con.INCtlon Ind conllNCtion ,chled
ICllvllle!.
Con.lnlellon S.rely Sund,"1a (Pari .:301 '
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ll1eae ,equlremenl' 110 ,prilclble bee,,!.e Cdn.tOlCllnll
Ictlvltl.. wllll.ke pl.ce Itlhe .ile, . .
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Thl. .ltern'llve will conlply wllh Iht.l~:,'c~\llremenll,
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fEDERAL - ACTION-SPECifiC ARAR.
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CLBAH AIR ACT. .0 CPR '"tI 50 .ad 61
RClul.llon. tllAblhhll1l 11.11011.1 prlm.ry and
lUoodary .mbltll,.I, qlllllty .lAndarl!., .nd cm'"lon.
.Iaadard. ror haurdou. .Ir pollul.nll,
~o CPR PII18 50 Ind 61.
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The.e ,equlrement. IIC ippllClb1e b~uulO Ilr eOllllloli1
will bo lenellled r,om U'o.alr IIJp~I~G:UIIII,
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Thll Ilte(1l.llve will comply wll~ Ihelt rcq,;lrelllenU,
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,Page 5 of 5
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IX.
1.
STATUTORY DETERMINATIONS SUMMARY
Protection of Human Health and the Environment
The selected remedy provides adequate overall protection of human health and
the environment, by removal and off-site disposal of contaminated lagoon
sediments and soils and by treating the contaminated groundwater.
Institutional controls will be implemented during remediation to assure
protection until confirmation sampling and analyses indicate that health-based
cleanup has been achieved.
Any short-term risks associated with excavation and transportation of
contaminated sediments and soils (dust generation) will be minimized by the
use of standard construction practices. Air monitoring will be conducted to
assess possible exposure during remedial action.
2.
Attainment of ARARs
The selected remedy will be designed to meet all ARARs of federal and state
environmental laws. Tables 5 and 6 provide a summary of the ARARs considered
for the soil/sediment and the groundwater preferred cleanup alternatives,
respectively, and states whether or not the alternative will attain the
specified ARARs.
Under Act 307, the goal of the groundwater cleanup will be to obtain Type B
criteria (Type A - method detection limit or background levels, will be used,
where appropriate). The goal of the lagoon remediation will involve
excavation of contaminated sediment and soils to Type B criteria (Type A -
method detection limit or background levels, where appropriate) using the
Michigan Verification of Soil Remediation Guidance. The MDNR has consulted
with the EPA concerning this cleanup criteria.
3.
Cost Effectiveness
The chosen lagoon remedy is cost-effective, since long-term 0 & M is not
required. The chosen groundwater remedy is the only one that passed the
effectiveness, implementability, and cost evaluation. Details of the
treatment will be worked out in the design phase. Cost-effectiveness will be
considered further at that time.
4. Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent Practicable
For contaminated groundwater, this remedy utilizes permanent solutions and
alternative treatment technologies, to the maximum extent practicable, and
satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principle element.
Treatment of the sediments and soils was not feasible due to the site geology
and the wide range of contaminant types.
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5.
Preference for Treatment
Treatment is a principle element of the groundwater remedy chosen for this
site. The MDNR determined that treatment of the lagoon sediments and soils at
the site was inappropriate based on the evaluation conducted during the FS and
the site-specific factors discussed earlier in this ROD. By treating the
contamination in the groundwater, the selected remedy for the groundwater
only, satisfies the statutory preference for remedies that employ treatment
as a principle element. This will permanently and significantly reduce
toxicity, mobility, or volume of hazardous substances in the groundwater.
x.
DOCUMENTATION OF SIGNIFICANT CHANGES
The MDNR released the Proposed Plan for pUblic comment in August 1992. The
Proposed Plan identified excavation and off-site disposal of contaminated
lagoon sediments/soils and treatment of the contaminated groundwater as the
preferred alternative. No written comments were received during the public
comment period on the Proposed Plan and only a few comments were made at the
August 24, 1992, public meeting. The comments received and MDNR responses are
presented in the attached Responsiveness Summary.
Based on review of comments received, the remedy as presented in the Proposed
Plan is the selected remedy, and no significant changes to the remedy are
necessary.
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