United States
Environmental Protec:tion
Agency
Office of
Emergency and. .
Remedial Response
EPAlRODJR05-931233
September 1993
PB94-963916 -----
Superfund
Record of Decision:
&EPA
Duell & Gardner Landfill, MI
u . S. Environmental Protection Agency
Region III Hazardous Waste
Technical Information Center
841 Chestnut Street. 9th Floor
Philadelphia, PA 19107
...
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
IEI?A AaJpori to!llPirciioU]
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-------
DE~IOH FOR ~ RECORD OF DECISIOH
S~te Name and Location
Duell-Gardner Landfill Site
1285 Bard Road.
Dalton Township, Muskegon county,
Michigan
Statement of Basis and PUrDose
This decision document presents the selected remedial action for the Duell-
Gardner Landfill Site in Muskegon county, Michigan. This response action was
chosen in accordance with the requirements of the comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the
extent practicable, the National Oil and Hazardous substances. pollution
Contingency Plan (NCP).
This decision document explains the factual and legal basis for selecting the
remedial action for this site and is based upon the contents of the
administrative record for the Duell-Gardner site.
The u.S. Environmental Protection Agency and the Michigan Department of
Natural Resources agree with the selected remedy.
Assessment of the s~te
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 Remedv
This final remedy addresses contaminated groundwater and contam~nated soil
associated with the Duell-Gardner site.
The major components of the selected remedy include the following:
*
Extraction of groundwater to capture and halt the flow of the
contaminated groundwater plume.
*
Removal of contaminants from the groundwater by carbon adsorption
treatment.
*
Excavation of contaminated soil and subsequent treatment by low
temperature thermal treatment.
*
Construction of a clay cap to properly cover the old landfill area.
*
Groundwater monitoring to assess the state of remediation.
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-j
S~a~u~orv De~ermiDa~ioDS
The selectea remeay is protective of human health ana the environment,
complies with Feaeral ana Sta~e requirements that are legally applicable or
relevant ana appropriate for this remeaial action, ana is cost-effective.
This remeay utilizes permanent solutions ana alternative treatment
technologies to the max~um extent practicable ana satisfies the statutory
preference for remeaies that employ treatment that reauces toxicity, mobility
or volume as the principal element.
folk I.
9/o7/9b.
I Datoe
Agency
~6<'/fO ~
Russell ~Haraing
Deputy Director
Michigan Department of Natural Resources
g::> 6/'# ::?
Date
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.'
DUELt.-GUJJRBa LAJlDnLL
RECORD OF DBCISIOH
TABLE OF CONTENTS
Decision Summary.
...............
...............!.................4O.......... .1
Site Lcca~ion and Description..............................................1
Si~e His~=ry and Enforcemen~ Activities....................................S
~ommun~~: ~ela~~ons History.
.4O.4O ........................ ..-
................6
~cope :~j ~ole 0: Response Ac~~=n..
....................... .
.........
.......5
~ummar,!
_.: Si,=e
Charac':.erl.S~~::s.
................
...................
........9
Summary:::: Site Risks................................""""""'.""" .12
Description of Alternatives....
........ .... ......... ........
. . . . . . . . . . . . . . 18
Comparative Analysis of AlternatiVes......................................22
Selected Remedy.
4O. .....4O....404O4O4O .......... ..............
. . . . . . . . . . . . . . . . . .26
statutory Determinations...
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28
Appendix I:
Responsiveness summary
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DECISION SUMMARY FOR THE RECORD OF DECISION
SITE NAME. LOCATION. AND DESCRIPTION
7~e Duell-G :jner Landfill si~e is loca~ed i~ ~he sou~heas~ 1/4 of the
~or~hwes~ :.~ of Sec~ion 27, ~llN, R16W, Dalton Township, Muskegon ccun~y,
Michigan (see Figure 1). ~he si~e is loca~ed approxima~ely five miles north
of the ci~y of Muskegon. ~he site is comprised of an 80 acre parcel looated
a~ 1265 Bard Road (see Figure 2). The landfill itself covers an area of about
:our acres; however, was~e was placed in areas ou~side the landfill on the
ground surface. 7he landfill has never been properly covered. The si~e is
no~ fenced; however, ~he landfill area is secluded and pos~ed.
Land use i~ ~he area is primarily residen~ial and agricultural. Approximately
:40 people 1ive wi~hin a one mile radius and 1,:00 people live within a twO
~~le :adius of ~he si~e. 7he landfill is loca~ed on ~he sou~hern half of the
=~~e. 7hO res~dences and an agricultural field are loca~ed on ~he ncr~hern
~ali == ~he ?roper~!. 7he ~o?ograpny a~ ~he s~~e ~~ :~a~ ~= gen~iy ==lling
N~~h a ~opographic relief of approxima~ely 21 fee~.
3usinesses or indus~ry in the vicinity of the si~e include an auto salvage
yard jus~ northeas~ of the site, a campground 1.5 miles west of the site, a
golf course 1.5 miles sou~h of the site, and several small businesses and
several chemical companies located two miles or more from the site in Dalton
Township.
Regional sur:ace water drainage is to the south and east of the site toward
Bear Creek approxima~ely 1.5 miles from ~he site. Much of the precipitation
at the site percolates down through the highly permeable soils at the site.
Local surface water drainage is toward a tributary to Bear Creek located 500
to 1,000 fee~ east of the site. Some drainage may flow to an east-west
~rending agricultural drainage ditch located four hundred feet south of the
site.
The site geology is characterized by glacial deposits approximately 300 feet
thick consisting predominantly of very fine to medium grained sand. The
underlying bedrock is the Marshall formation sandstone. One unconfined
aquifer has been identified at the site. The water table was encountered
between three to s~teen feet below ground level. Groundwater flow beneath
the site is generally to the south-southeast toward Bear creek.
Water supplies in the area are derived from wells in the glacial deposits or
from Lake Michigan. The bedrock aquifer is apparently not utilized as a
drinking water source in Dalton Township. Two residential drinking water
wells are located on the northern half of the site uP9radi=~t of the
contaminant plumes. Approximately twenty-one private well- are located within
three quarters of a mile to the south and southeast of the site (see Figure
3). The depths of the residential wells in the area are.primarily between 2S
and 40 feet below ground level.
1
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LEGEND
.2 PRNATE '."ELL LOCATION & NUMBER
4000
o 2000
1. BASE MAP DEVELOPED FROM THE TWIN LAKE. . . LlL..-! i
MICHIGAN, u.s.e.s. 7.5 MINUTE TOPOGRAPHIC
QUADRANGLE MAP. PROVISIONAL EDITION 1985. ~ l0CA11OH SCALE IN FEET" AGURE
NOTES
I '-VA R7.YN
~ed BJH App'd.../~ I,
POOR QUAt\\'(
OR\G\NAL
PRIVATE WELL LOCATION MAP
ar- SJL
FIGURE - 3
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SI~ HISTORY AND ENFORCEMENT ACTIVITIES
The landfill was used for the disposal of was~es from the mid 1940's to
From the 1940's to 1969 the landfill was owned and operated by Hosea
DeGraffenre~d. Juring this time period indus~rial and municipal was~es
depos~ted in trenches, depressions and on the surface of the site.
1973.
were
!n 1969 the site was purchased by Eugene and Carol Gardner and Paul and Mary
Duell. ~he Gardners and the Duells operated the landfill as a solid was~e
disposal facility licensed by the Michigan Depar~en~ of Public Health (MOPS)
under Act 87, P.A. 1965, from 1969 through 1973. During this time period
wastes were placed in unlined trenches excava~ed at the site. Carol Gardner
reported tha~ s~ained soils were observed when the trenches were excavated.
~he site was periodically inspected by the Muskegon coun~y Health Depar~ment
:rom 1969 through 1973. In 1971, the HDPH s~ipulated that no liquid was~e8
were to be disposed in the landfill. In 1973, the Muskegon County Health
:epartment ~oted that liquid wastes were being disposed in the landfill. The
:'andf:.~l ",as ordered closed by the MDPH effec~i.:e January 1., 1974, aiter which
~~e landf:.l: ceased accep~ing wastes.
:~it.ai concern acout possible groundwater contam~nation at the Dueil-Gardner
Landfill arose when the MOPH was considering approval for the construc~ion of
a community water supply in the area in December 1977. The Michigan
Departmen~ of Natural Resources (HDNR) visited the site and collec~ed soil and
drum samples in 1979 which indicated that PCBs were present in the soil. In
1981 a u.s. Environmental Protec~ion Agency (EPA) contractor visited the site
and collec~ed surface wa~er samples. Another EPA contractor installed four
monitoring wells a~ the site in 1982 and groundwa~er was determined to be
flowing in a sou~heasterly direction. No significant concen~rations of
organics or inorganics were detec~ed in these wells. In 1984 the MONR and
another EPA con~rac~or visited the site and loca~ed and sampled drums loca~ed
in a wooded area adjacen~ to the landfill. The analysis of these samples
showed evidence of organic and inorganic con~amination.
In Sep~ember 1985., the MDNR identified 21 distinc~ drum and waste areas at the
s~te. Approximately 550 drums in various s~ages of deteriora~ion were found
randomly scattered in the woods adjacen~ to the landfill in groups of 9 to 140
drums. Hundreds of small laboratory bottles, areas of refuse and debris, anA
piles ~f unidentified sludge-like material were scattered around the base of
the l_~dfill. Under a CERCLA removal action, the EPA removed the drums, some
of the laboratory bottles, the sludge-like material. and some soil from the
site in March 1986.
In Novemcer 1986 a Remedial Investigation/Feasibility Study (RI/FS) was
initiated for the Duell-Garner Landfill site. The RI/FS was intended to
quan~ify, through sampling and analysis. the residual contamination at the
site and to identify appropriate remedial alternatives. The RI/FS was a
s~ate-lead activity funded with federal superfund money and state funds used
as advanced match for the pending remedial action.
Remedial Investiqation (RI) field work beqan in December 1986 and continued
intermitten~ly through August 1990. The RI report was completed in March of
1992. A Treatability Study was conducted to identify and evaluate
5
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~echnolog~es which may ei~ina~e or reduce ~he ~oxic~~y, ~obility, and/or
volume of :=n~am~nan~s presen~ in site soils and groundwa~er. The
:rea~abil~=: Study was conduc~ed from Novemcer 1990 through March 1991 and the
:rea~abil~~7 Study repor~ ~as completed in March 1992. :he Feasibility Study
(FS) repor: ~as c=mple~ed in Auqus~ 1992.
COMMUNITY RELATIONS HISTORY
~ comple~e chronology of community rela~ions ac~ivi~ies for the Duell-Gardner
Landfill s~~e is prov~ded as par~ of the a~tached Responsiveness Summary.
~ Proposed Plan for ~his remedial alterna~ive was released April 16, 1993.
:his documen~ and all suppor~ing documen~s are available ~o ~he public in the
adminis~ra~~ve record main~ained a~ ~he HDNR in Lansing, Michigan and a~ the
informa~ion repos.~ory a~ ~he Dalton Township Hall. The no~ice of
ava~labili~: for :he Proposed Plan was published in ~he Muskegon Chronicle on
~pr~l :5. :=93. ~ ~hir=y ciay puclic comment pericd ~as held from Apr~l :6
~~rouQn ~ay :5. :=93. :n addition. a puclic mee~~~~ ~as held on Apr~l :8,
- - - -' .;:..~ ~::is ::-.ee~~~g. =epresent:at::,':es 0: -.:~e MC::R anci E?A answered
~~es~:.cns acout: -.:~e s~t:e and the remedial alternat:~7es under cons~dera~~on and
accep~ed ::rmal commen~s from ~he public regarding ~he proposed alterna~ive
and ~he o-.:ner alterna~ives analyzed in the FS. Responses to the commen~s
-.:aken dur~ng ~he public mee~ing and written comments received during the
public comment period are included in the Responsiveness summary, which is
par~ of this Record of Decision (ROD).
This decis~on document presen~s ~he selected remedial ac~ion for ~he Duell-
Gardner Landfill site in Muskegon Coun~y, Michigan, chosen in accordance with
CERCLA, as amended by SARA and, to the extent practicable, the National
Contingency Plan. The.decision for the selected remedial action is based on
the administrative record.
SCOPE AND ROLE OF RESPONSE ACTION
This ROD addresses ~he final remedy for ~reacmen~ of soil and groundwater
contamina~ion a~ the Duell-Gardner Landfill site. The contamina~ed soil is
considered the principal threat a~ the site. The contamina~ed soil represents
a pr~ary threa~ as a source of contamination of groundwater as well as a
threa~ to human health due to direct conta~ and incidental ingestion of the
soil. The grounawa~er represen~s a primary threat to human health and the
environmen~ due to ing..tion of and contact with water from the contaminated
portions of the aquifer that contain contaminants at concentrations above the
Maximum Contaminant Levels (MCLs) established by the Safe Drinking water Act
and/or Michigan Environmental Re.ponse Act, 1982 PA 307, as amended, (Michigan
Act 307) Type A or B criteria.
The selec~ea remedial alternative will address all threats at the site,
including several areas of 50il contamination (se. Figure 4) and the two
plume8 of groundwater contamination (saa Figure 5).
The final remedy for the site is intended to address the entire site with
respect to ~he threats to human health and the environment indicated in the
6
-------
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DUELL AND GARDNER LANDFilL SITE
REMEDIAL INVESTIGATION
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si~e risk (endangermen~) assessmen~. :he findings or the risk assessmen~ are
included in the RI Repor~ and are summarized in a la~er sec~ion of this ROD.
SUMMARY OF SITE CHARACTERISTICS
Soils encoun~ered below ~he surface of the si~e consist predominan~ly of
:ine ~o medium sands. ~~ited amoun~s of silt and clay were encoun~ered
:ew loca~~ons~ however, no con~inuous confining layer was found.
very
a~ a
One unconfined aquifer has been iden~ified a~ ~he si~e. ~he groundwa~er flow.
in a sou~h-sou~heas~erly direc~ion benea~h ~he site. The average flow
~eloci~y of the groundwa~er was calcula~edto be .17 fee~ per day (62 feet per
year). :t is believed ~ha~ groundwa~er flowing benea~h ~he si~e discharges to
3ear Creek approx~a~ely 1.5 miles ~o ~he south-southeas~ of ~he site.
~er~ical migra~ion of the groundwa~er is considered to be negligible a~ ~he
si~e.
Surrace wa~er
=: ~~e so~ls.
:: Sear Creek
=ounaary.
=~nof: appears to be minimal due ~o the highly permeable na~ure
:ocal surface water drainage is ~o ~~e sou~heas~ ~o a ~=ibu~ary
l=ca~ed approx~mateiy 500 ~~ lCCO :=e~ east of ~he site
RI field ac~ivi~ies conduc~ed include surveying and mapping, geophysical
surveys, tes~ pi~ excava~ions, soil sampling, moni~oring well ins~allation,
and groundwater moni~oring. These field ac~ivities began in December 1986 and
continued intermitten~ly through January 1992.
Twen~y-one loca~ions with a~ leas~ one organic compound have been iden~ified
in on-site soils. The primary organic con~aminan~s found in the soils include
bis(2-ethylhexyl)ph~halate, crystal violet, aniline, and N,N-dime~hylaniline.
Polychlorinated biphenyls (PCBs) and pes~icides (DDT, DDD, and DDE) were found
in ~he soils a~ twc ~oca~ions. crys~al viole~ was detec~ed in t~e soil at up
to 188 par~s per million (ppm). The pes~icide DDD has been detec~ed at up to
180 ppm in the soil. See Table 2 for a list of soil contaminan~s.
:he areas of soil con~amina~ion are generally very small, isolated zones
corresponding to areas where contamination may have leaked or spilled from
drums loca~ed on the surface. It was aS8umed that a 100 square foot area
around each of the shallow soil sampling locations and somewhat larger are..
around the test pit locations would require remediation. It is estimated that
a total of 1,800 cubic yards of soil would require remediation. The ~wenty-
one locations with organic con~amination correspond well with the twenty-one
drum and wa.~e loca~ion. identified by ~he MDNR in 1985.
Groundwa~er flow. under ~he si~e in a south-~_~thea.~erly direc~ion. TwO
plumes of groundwa~er contamination appear to be emanating from areas which
are located outside of the landfill area at the site. Groundwater
contaminan~s include chloroform, carbon tetr£:hloride, aniline, and
N,N-dimethylaniline. The chloroform and carbon ~etrachloride have baen found
only in the shallow portion of the aquifer (ten to twenty feet below the
ground surface) while the aniline and N,N-dimethylaniline have also been found
in deeper portions of the aquifer (uP to 100 feet). Groundwater contamination
does not appear to have spread very far from the site1 however, the
downgradient extent of the contaminant plumes has not yet been fully -
characterized and will be addressed prior to the design. ..
9
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o
Several =es~den~ial wells are loca~ed approxima~ely one half mile ~o ~he sou~h
and eas~ == the s~~e along McMillan and pillen roads. ~he ~wen~y-one private
Hells l=ca~ed wi~hin ~his area were sampled during ~he investiga~ion and have
~o~ been ~~pac~ed by ~he si~e. surface wa~er and sedimen~ samples were
=~llec~ed fr~m the tr~bu~ary ~o Bear Creek l~ca~ed eas~ of the si~e and
sedimen~ samples were collec~ed from ~he drainage ditch sou~h of the site.
:Ieither == ':~ese dra~nage sys~ems have been i::lpac~ed by the site.
A Trea~acil~ty Study was performed ~o assess the effec~iveness of differen~
':rea~men~ ':echnolog~es in trea~ing certain cen~aminan~s found at the site.
:he Trea~ability Study evalua~ed s~abilization and fixation, low ~emperature
thermal ':rea~men~, and soil washing as methOds of trea~ing the soil f~r
=rys~al ~iolet, aniline, and N,N-dime~hylan~line. Carbon adsorption and
ultraviolet oxidation were evalua~ed for ~rea~ing crys~al violet, aniline, and
~.N-dime~hylan~line in groundwa~er.
The T=ea~acility Study c~ncluded tha~ low tempera~ure thermal trea~ment would
=e eifec~~7e in remov~ng the ~arge~ ==mpounds =r=m s~~e 50ils. Stabilization
~na f~xa~~=n, and so~l washing were de~erm~ned no~ -:= be effec~ive. ~arbon
~asor~-:~=~ and u~tr~v~clet =x~da~~=n were snown t~ be eifec~~ve in t=ea~~ng
~h~ targe~ ::mpounds i~ 5~te g=~undwater.
GROUNDWATER CONTAMINANTS OF CONCERN
MAXIMUM ACT 307 MAXIMUM
.:OMPOUND CONCENTRATION :'YPE 3 STANDARD CONTAMINANT LEVEL
Carbon Tetrachloride 110 1 5
Chloroform 270 6 100*
Tetrachloroethylene 10 1 5
N,N-Dime~hylaniline 186 10 NA
Aniline 6.3 6 NA
Gentian Violet 3.0 0.3 NA
all units are micrograms per liter (ug/l)
* - This MCL is for all trihalcmethanes combined
NA - not available
DBLE - 1
10
-------
v
SOIL CONTAMINANTS OF CONCERN
ACT 307
MAXIMUM ACT 307 DIRECT
CONCENTRATION TYPE B CONTACT
COMPOUND IN SOIL STANDARD STANDARD
3is(2-e~hylhexyl)phtha1ate 9100 40* 90,000
crys~al ':iole~ 188,405 6* 10,000
Aniline 4,293 120* 70,000
~l,N-Dime~hylan~line 1,587 200* 500,000
Arocior ::42 (?CB) 2400 :,000 :,000
Pen~achlorophenol 1100 6* 10,000
4' ,4' DDD 150,000 2* 5,000
4' ,4' DDE 85 2* 4,000
..' ,4' DDT 7,300 2* 4,000
Chrysene 970 330(t 330(t
Benzo(k)fluoranthene 490 330(t 330(t
Indeno(1,2,3-cd)pyrene 350 330(t 330(t
BenZo(a)anthracene 910 330(t 330(t
~il units are micr?grams per kilogram (ug/kg)
o Indicates that this criteria is based on the acceptable method detection
limit
,.
Indica~es tha~ this cri~eria is ba8ed on a level equal to twenty tim88 the
Type S groundwater standard pursuant to the Mi.chi.gan Administrative code
(MAC) R299.5711(2). The Type 8 numbers for soil may also be set at a
concentra~ion in soil below which produces a concentration in leachate that
is equal to the Type 8 groundwater cr~~eria. Leachate concentration shall
be determined by a method which best represents in situ conditions. Such
leachate testing may be performed as part of the P~e-design Investigation.
This may result in a change i the Type B numbers for certain contaminants
and a cha~;e in the amount of soil requiring remediation.
DBLE - 2
11
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c
SUMMARY OF SITE RISKS
~s par~ == ~~e RI/FS, an Endangermen~ ~ssessmen~. also known as a risk
assessmen~. has c=~duc~ed t~ de~ermine wha~ effec~~ con~am~na~ion associated
h~t~ ~~e s~~a wouid have on human health and the env~ronment ~= thes~~e were
:eft ~ntreated. 7~e Endangermen~ Assessmen~ ~as ~repared according ~o u.s.
E?A's Risk ';ssessment Guidance for Supertu~d: ':olu.::le 1 - Human ::ealth
Evaluatic~ ~anuai (?ar~ A) and Volume 2 - Environmental Evaluation Manual.
:he r~sk assessment ~akes into account curren~ risks as well as potential
f~ture r~sks. :he future risk scenario takes into account the possibility of
future res~dential use of the contam~nated areas. ~~cluding the possibility of
~he ~nstal:at~on cf drinking water wells in the c=~~aminated zone. :he
evalua~~o~ considered the manner i~ which people could be exposed to site-
related cc~taminants and estimated the carcinogenic and non-carcinogenic
~ealth ttreats these con~aminants may have upon human health or the
enVl.r=nmen~.
~ g~~en c~e~~cal's degree of tox~city ~ay ce descr~=ed i~ par~ :7 i~s
a=ceptaDle ~~~aKe er ~~s reference dese and. ~~ ~~e case cf carc~~ogens. by
~~~ =~==~~=;en~c ;=~ency :ac~=~. :~ncer ~== =a~c~~:gen~c~ ;o~ency :ac~crs
C?:51 ~a.e ~een ceveiopea for e5t~=.at~ng excess :~=et~e cancer r~sks
associatec ~~th exposure to carc~~ogenl.c or potentially carcinogenl.c
=heml.cals. ~ CPFois expressed as lifetime cancer r~sk per mg/kg body
~eight/day, and is estimated at ~he upper 95 percen~ confidence limit of the
carcinogen~c potency of a given chemical. CPFs are multiplied by the
estimated i~take of a po~ential carcinogen. in mg/kg-day, xo provide an upper-
bound est~=ate of the excess l~fetime cancer risk associated with exposure at
that ~ntake level. ~he term "upper-bound" retlects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestir..ation of the actual cancer risk highly unlikely. CPFs are derived
from the results of human epidemiological studies or chronic animalbioassays
to which animal-to-human extrapolation and uncertainty factors have been
applied.
Carc~~ogen~c risk is estimated by multiplying t~e estimated dose of the
:~em~cal =y ~~s puclished or calc~lated slope factcr. carc~nogenic risks are
assumed te be additive fer all chemicals within an exposure pathway. The NCP
has established a carcinogenic risk of greater than 1 x 10"4 as being
unacceptable for human health. (This represents the contracting of cancer due
to enviror.~ental exposure as one in ten thousand.) The reduction of such risk
to within the risk range of 1 x 10.4 to 1 x 10'0 is viewed by the NCP as
acceptable. The E?A often uses the 1 x 10"6 figure as a desirable goal for
adequate protection of human health and the environment.
Reference dese (RfD) values are normally reported in mg/kg body weight/day,
and generally represent the highest calculated exposure level below which a
given adverse eff'ect will not occur. Reference doses have been developed for
indicating the potential for adverse health effects from exposure to
chemicals. ~he 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 non-
carcinogenic compounds. as well as non-carcinogenic health effects of
compounds ~hich are carcinogens. Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from contaminated
12
-------
drinking wa~erl can be compared ~o ~he RfD. ~fDs are der~ved from human
epidemiological s~udies or animal studies to which uncertainty factors have
been applied (e.g., ~o account for the use of an~l data ~o predic~ effects
on humans). ~hese uncer~ainty :ac~ors help ensure that the RfDs will not
~nderes~~ate ~~e potential for adverse non-carcinogenic effects to occur.
:::stimating the risk of a non-carci~ogenic' health effect is accomplished by
:alculating the hazard quotient (HQ). This is done by dividing the dose
estimated to be received by someone exposed to a substance by the es~ablished
safe dosage estima~e for that chemical. ~f the resulting answer is greater
than 1, then ~he exposure has exceeded a safe level. Adding all the HQs for
~he chemicals of concern in a given route of exposure gives a Hazard Index
(HI) for ~ha~ pathway. !f the HI exceeds 1, there is a potential health risk.
~he Endangerment Assessment addressed potential pa~hways by which human
populations couid be exposed to contaminants originating from the Duell-
Gardner si~e. :~ identifying potential pathways of exposure, both current and
?oss~ble f~ture si~e and surrounding land use conditions are considered.
:~ere are ~hree general routes ~hrough which i~dividuais may be exposed to the
:~em~cais or ==~cern a~ the s~~e: ~~halaticn, ~~gest~on, and dermal
adsorpt~on. 7he exposure pa~hways evaiua~ed i~clude:
:) current and po~ential f~ture use of the groundwater (ingestion and
inhalation)
2) incidental ingestion of s~rface soil, sediment and/or surface water
3) dermal contact with surface soil
~he exposure assessment for ~he site identified six receptor groups as human
populations with a potential for exposure to site contaminants. ~he six
receptor groups and relevant exposure routes for which public health risks
were evaluated include:
1) Adult Workers
potential ingestion of groundwater, incidental
ingestion or dermal contact with surface soil.
subsurface soil, sediment and surface water.
2) Adult ResidentS
potential
ingestion
sediment,
use of groundwater, incidental
or dermal contact with surface
and surface water.
soil.
3) Adult Trespassers
Incidental ingestion or dermal contact with
surface soil, sediment and surface water.
4) Adolescent Residents
potential use ~f groundwater, incidental
ing.stion or ~armal contact with surface
sediment and surface water.
soil,
5) Adolescent Trespassers
Incidental ingestion or dermal contact with
surface soil, sediment and surface water.
6) Child Residents
Potential use of groundwater, incidental
ingestion or dermal contact with surface soil.
The toxicity assessment identified the available and appropriate toxi~ity
values for each chemical of potential concern. The Integrated Risk -
13
-------
q
:nforma~~e~ Sys~em (!RIS) da~aaase and the Health Effec~s Assessmen~ Summary
Tables were consul~ed fer toxicity informa~ion. !nadequa~e carcinogenic
and/or ~on-carc~~ogenic toxicity informa~ion was available for several
chemicals c: potential =encern. T~e possible health effects of these
chem~cals and consequences of thei~ exclusion from the endangerment asseSSm8n~
are unknown.
The chemicals of concern selected for risk characterization in the groundwater
were alum~num, nickel, silver, vanadium, cyanide, chloroform, carbon
tetrachloride, aniline, 4l,N-dimethylaniline, and crystal violet. The
chem~cals of concern for surface soil included aluminum, barium, chromium,
~ead, manganese, z~nc, aniline, crystal violet, and N,N-dimethylaniline. For
subsurface soils aluminum, barium, cadmium, chromium, cobalt, lead, manganese,
~ickel, .anadium, =yan~de, aniline, butylbenzylphthalate crystal violet, di-n-
~ctylphthaltate and N,N-dimethylaniline were selec~ed as chemicals of concern.
The Endangerment Assessment concluded that t~e drinking of contaminated
groundwater ;osed t~e greatest potential r~sk at t~e site. The Hazard Index
~alue (?alues above 1.: can produce adverse health effects) tor potent~al
:~ture ~se c: t~e groundwa~er was 2.; ~or an on-si~e child residen~ and 1.2
:cr an on-5~~e adolescent resident. This ~s pr~arily attr~butaale to the
presence of carbon tetrachloride and N,N-dimethylaniline in the groundwater.
Potential ~~~ure residential use also results in an increased cancer risk of
one in 10,000 for adult residents, due to the presence of carbon
tetrachloride, chloroform, and crystal violet in the groundwater (see tables
three and four).
Future res~dents or others who have direc~ contact with contaminated soil at
the site are also poten~ially at risk. To facilitate risk characterization,
the endangerment assessment divided the site into three areas (see Figure 6).
The maximum est~ted additional cancer cases that could result from exposure
to surface soil is 1.6 cases per 10,000 persons exposed for an on-site adult
resident i~ risk area A. The majority of the cancer risk from area A is
attribu~able to crystal violet, 4'4'-DDD and 4,4'-DDT. The maximum cancer
r~sk for exposure to area B soil is 5 cases per 100,000 persons exposed. The
maJority c: the cancer r~sk from Area B so~l ~s due to PCBs (Aroclor 1242).
See tables five and six for more detail on risks attributable to soil
exposure.
In addition to posing unacceptable health risks as described above, the Duell-
Gardner Landfill site does not meet certain environmental standards that would
be considered to be applicable or relevant and appropriate requirements
(ARARs) for any remedial action. The levels of certain contaminants in the
groundwater exceed their respective MCLs and/or Michigan Act 307 Type A or B
standards in groundwater. The soil cont~ation exceeds the Michigan Act 307
90il Type B standards for several contamin.~ts at 21 separate locations. Of
these 21 locations, five locations have exhibited contaminants in soil in
excess of the direct contact hazard levels established by the MOHR pursuant to
Michigan Act 307. The contaminated soils a180 pose a threat to the
groundwater at the site. Contaminants may leach from the soil and become a
continual source of groundwater contamination.
Potential impacts on nonhuman receptors and the environment were also
evaluated. ~he Endangerment Assessment concluded that the threats to
environmental receptors posed by the Duell-Gardner ~~te appear to_be minimal
14
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and adverse impac~s on plan~s and wildlife are unlikely or es~ima~ed to be
limi~ed.
Actual cr ~~rea~ened releases or hazardous subs~ances from ~his si~e, if not
addressed by ~he selec~ed remedy, ~ay presen~ an i~inen~ and subs~antial
endanqermen~ ~o public health, ~alfare, or the environmen~.
HAZARD INDICES
I I I SUBSURFACE I TOTAL HAZARD
REC~P'!'OR GROUNDWATER SURFACE SOIL SOIL INDEX
I I I I I
i C:-:ild ?esl-dent 2.7£+00 2.2E-02 ~lE 2.7E+00
i
, I
.:"dolescent I :.2E+00 ! 5.7E:-03 HE 1.. 2E+00
Resl-dent
Adult ?esl.den~ 7.8E-01 2.0E-03 NE 7.8E-01
Adolescen~ 1. 2E-0 1 1. OE-04 NE 1.2E-01
Trespassers -
Adult 8.0E-02 2.0E-05 NE 8.1E-02
Trespasser
Adult Worker 8.0E-02 8.2E-05 2.4£-.01 2.4£-01
TABI.E - 3
CAHCEK RISJtS
TOTAL
SURFACE INCREMENTAL
RECEP'TOR GROUNDWATER WATER SEDIMENT CANCER RISK
Adult Resident 8.7 X 10'5 8.8 X 10'6 NE 9. 6"'XI0.?::i,i:;.
Adult 1.3 10.7 3.4 X -10 1.3 X 10-1
NE X
Trespasser
Adult Worker 2.9 10'6 1.3 10.7 3.4 X .10 2.9 X 10.6
X X
'rABt.E - 4
NE - Not evaluated (non-applicable exposure route)
15
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HAZARD INnICES
SOIL RISE AREAS
RECEPTOR I SOIL AREA A I SOIL AREA B I SOIL AREA C
Child Resident; I 1.4E+00 2.7E-02 I 1.2£-02
i'.dolescen~ Resi.cien~ I 5.2E-01 8.4E-03 I 3.6£-03
: Adult Re91.cent; I 2.5£-01 2.8£-03 I 1.0£-03
,
I I
.::'.dolesce!1': Trespassers ~.7£-02 1.6£-04 I S.lE-05
: ' I 'I
.::'.dul~ ':':9StlaSSer ! ::.lE-03 ~.4£-05 3.5£-06
,I Adult ',./orker I :.2E-02 I 1.3£-04 I 4.1E-05 I
~ABLE - 5
c:ARCER RISJtS
SOIL RISE AREAS
RECEPTOR SOIL AREA A SOIL AREA B I SOIL AREA C
Adult Resident 1.6 X 10.4 5.0 X 10'5 5.8 X -8
Adult Trestl&sser 4.1 X 10'6 1.3 X 10'6 1. 6 X -9
Adult Worker 4.9 X 10'6 1.8 X 10'6 3.3 X ,8
~-6
16
-------
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Lrtll..--J
-------
DESCRIPTION OF ALTERNATIVES
The alterna~ives analyzed at ~he Duell-Gardner site are presen~ed below.
These alterna~ives are numbered to correspond with the numDers in the
:eas~bili~y Study repor~. To facilitate ~he evaluation process, the cleanup
~as been separa~ed by media to include alterna~ives to remediate the
groundwater and alterna~ives to remediate ~he soil. All listed costS are
es~imates. Annual operation and maintenance (O&K) costS are ~he yearly costs
assoc~ated with the running of the treatment system, maintenance of landfill
:aps, and/or continued monitoring of groundwater quality. .
SOILS ALT~RNATIVES
Alteruative 51:
No Action
Construc~~cn Cos~:
~nnual O?era~~on & Maintenance:
:=tal ?resen~ Worth C:sts:
50
50
50
:One Superf'.:nd program requires that the ..~to Action" alternative be evaluated
at every s~te to establish a baseline for cQmparison. Under this alternative,
no action will be taken to prevent exposure to the soil or ~o prevent
contaminants from leaching from the soil at the site.
Alteruative 52:
Excavation of Contaminated Soil and Containment by cappi.D!)
Construction Cost:
Annual O&M:
Total Costs:
$1,597,000
$73,000
$2,718,000
This alternative consists of excavation of contamina~ed soils, consolidation
of these so~ls in the landfill area, and construction of a clay cap which
=omplies w~th the Michigan Hazardous Waste Management Act, :979 FA 64, as
amended (Michigan Act 64). Other elements of this alternative include
~plementation of land use res~rictions at the site and fencing of the
landfill area.
Approximately 1,800 cubic yards of soil will require excavation. Soils to be
excavated include all areas contaminated with organic compounds above the Type
B criteria established pursuant to Michigan Act 307 (see F1qure 4).
The landfill cap would consist of placing a min~um of three feet of compacted
clay over the contaminated soil, and placing at least another three feet of
soil on top of the clay to provide for drainage and frost protection. A fence
would be erected around the capped area. Land use restrictions and fencing
would be placed on the area i=maQiately around the cap to limit development,
as required by Michigan Act 64.
18
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Alternat1ve 53:.
Excavation, vitrification and capping the Old Landfill Are.
Construction Cost:
Annual O&H:
Total CoSts:
54,249,000
539,000
54,843,000
7his alternative consists of excavation of the same soils as in Alternative
S2. :'hese soils would then be placed in the land:..:l area and. treated by a
?rocess called vitrification. In the vitrification process a~ electrical
current is passed through electrodes pl~ced in the ground, heating the soil to
its melting point and, upon cooling, forming a glass-like mass. This
solidified mass is resistent to leaching and more durable than granite. The
'litrified mass would then be covered with a clay cap meeting the closure
requirements of the Michigan Solid Waste Management Act, 1978 PA 641, as
amended. (Michigan Act 641).
7he 1andfi:: cap would consist 0: at least ~wo feet of compacted clay cover~g
~he ~reated so~l. and an additional ~hree feet 0: 50~1 ~o provide for drainage
:nd =rost ~=otection. :enc~~g and land use re5tric~ions would ce put in place
:5 requ~=ed by ~ich~gan Ac~ :41. 7he a5socia~ed monitcri~g required by an
:1~chigan nCt 041 landfill closure w~ll also oe periormed.
Alternative 54:
LaDdfill Area
Excavation, On-Site Thermal Treatment and Capping of the 014
Construction Cost:
Annual O&M:
Total COSts:
52,230,00<
S39,00C
$2,824,000
This alternative consists of excavation of the sam. contaminated soils as in
Alternative 52. These soils would be treated on-site using low temperature
thermal treatment (LTTT). The LTTT process uses heat to strip or volatilize
contaminants from the soil into an air stream. volatilized contaminants and
water vapor are co~lected in an off-gas handling system for subsequent
~reatment and/or disposal. LTTT differs from incineration in that the
contaminated soil is only heated to the range of the boiling points of the
contaminants to be removed, thus avoiding higher temperatures that would burn
the contaminants or the soil.
The LTTr proces. was shown to be effective in removing certain contaminant. in
bench scale tests performed as part of the Treatability study. Pilot scale
testing may be needed during the design of this remedy to ensure the
effectiveness of LTTT on soils from the site.
Th. LTTr proce.. will only remove organic contamination from the soil.
Inorganic compounds may remain in the soil. T~e treated soil will be placed
on the lar.=:ill area and the landfill will be capped as in Alternative 53.
Fencing, land use restrict1ons, and monitoring will be put in place as in
Alternat1ve 53.
19
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).lternative 55:
LaJ1dfill Area
~xcavation, Off-s1te InciAeration ana cappinq of the Old
~~nstruc~~=n C=S~:
;"nnua1 O&M:
:'~tal C~Sts:
$8,103.000
$39,000
$8,697.000
:'his a1ter~ative ~~.olves the excavaticn of ccntaminated soil as in
Alternative 52. :~e soils would then be transported to an off-site facility
~~ be incinerated. Jue to the fact that the landfill has never been properly
closed, the landf~:l will be capped as in Alternative 53. Fencing, land use
=estric~icns, and ~onitoring will be put in place as in Alternative 53.
GROUNDWATER AL~~~NATIVES
Alternative GW1:'
~lo Action
C=ns~r~c~~=n c=s~:
~nnua1 C~erat~=~ ~ Maintenance:
::tal ?resent h=r~n CoSts:
$0
;:;)
SO
The Superfund prc:;ram requires that ':he "~lo Action" alternative be evaluated
at every site to establish a baseline for comparison. Under this alternative,
no action would be taken to prevent exposure to on-site groundwater or to
prevent migration ::f the contaminated groundwater off-site..
Alternative GW2:
So Remedial Action with Land Use Restrictions and Monitor~q
Construction COSt:
Annual O&M:
Total COStS:
$16,000
$ 59,000
$917,000
:'his alternative c::nsists of the implementation of land use restrictions at
~~e 51te t= prevent construct.on or drinking water wells in the areas of
groundwater contam~ation. Monitoring of the groundwater is included to
assess and evaluate the migration of the contaminated groundwater. This
monitoring will be performed over the next thirty years.
Alternative GW3:
Groundwater
Extraction and Ultraviolet Oxidation Treatment of
Total Costs:
$1,076,000
$173,000
$59,000
$2,857,000
(yrs 1-10)
(yrs 10-20)
Construction CoSt:
Annual O&M:
This alternative involves removal of contaminated groundwater, treatment by
ultraviolet oxidation, and discharge. Contaminated qroundwater will be
removed from the aquifer by a system of extraction wells and pumped to an on-
site ultrav101et cxidation treatment system. The extraction system will be
designed to remove all contaminated groundwater and prevent the further
migration of the contaminant plumas. The goal of ~his alternative-will be to
20
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mee~ t~e Michigan Act 307 Type B s~andards and MCLs for the con~aminants of
concern at all points in the aquifer. excep~ benea~h the landfill. This would
restore the groundwa~er resource to its beneficial (ie. residen~ial) use.
In the uitraviole~ cxidation process. ozone and hydrogen peroxide are put into
a reactor ~~th the con~amir.~ted groundwa~er. 7~e ozone and hydrogen peroxide
react ~ith the organics in ~~e wa~er. breaking down t~e contaminan~s in~o non-
~oxic compounds. ~lso. ultraviolet light is used to fur~her remove organics
by pho~odegrada~ion. If complete oxidation occurs the products from the
process are carbon dioxide and wa~er. :ollowing ~rea~men~. the trea~ed water
Nill be discharged on-site into the ground via a seepage sys~em.
Alterna~ively. the treated wa~er may be discharged to the agricultural
drainage ditch south of the site.
Jltraviolet oxidation was shown to be effective in treating certain site
:on~am~nants in the groundwater during bench scale tests conducted during the
7reatab~li~y Study. Jltraviolet oxidation is not expected to be as effective
~~ treat~~g carbon tetrachloride and chlorororm as i~ ~ill ~ith the o~her
;r=und~ater :=ntam~nan~s. 7he cost est~~ate may oe sign~=icantly
~~cerest~=ated depena~ng C~ the acili~y to remove c~rcon ~=trachlor~de and
=~lorotorm. Additional ~reatacili~y studies w~ll be needed during t~e design
of this sys~em to determine its effectiveness in treating all contaminants
found in site groundwater. :t is anticipated that it will take approxima~ely
ten years to complete the groundwater cleanup.
This alternative also involves the groundwater monitoring as i~_Alternative
GW2.
Alternative GW4:
Carbon Adsorption
Extraction of the ContallU.z1ated Groundwater and Treatment by
70tal C=s~s:
5485,000
$278,000
$59,000
53,076,000
(yrs 1-10)
(yrs 10-20)
cons~ruction COSt:
Annual O&M:
This alternative consists of extraction of the groundwater as in Alternative
GW3. treatment of this water by carbon adsorption, and discharge of the
treated water. The goal of this alternative will be to meet the Michigan Act
307 Type B s~andards and MCLs for the contaminants of concern at all points in
the aquifer, except beneath the landfill. Tbis would restore the groundwater
resource to its beneficial (ie. residential) use.
In this alternative, the extracted water is fed through a bed of activated
carbon to remove contaminants. carbon adsorption treatment is a physical
separation process. in which contaminants are removed from the water stream as
they adsorb to the carbon. The spent carbon is then taken off-site for
treatment and/or disposal. Carbon adsorption was shown to be effective in
treating certain site contaminants in the groundwater during bench scale tests
conducted during the Treatability Study. Carbon adsorption is a180 expected
to be effective in treating carbon tetrachloride and chloroform. FollowiDq
treatment, the treated water will be discharqed on-site into the ground via a
seepage system. Alternatively, the treated water may be discharged to the
agricultural dra~age ditch south of the site. It is anticipated that it will
take approximately ten years to remediate the groundwater.
21
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:his al~erna~~ve also ~nvolves ~~e groundwa~er moni~or~r.g as in Alterna~ive
GW2.
COMPARATIVE ANALYSIS OF ALTERNATIVES
:he follo~~ng ~ine cri~er~a. ou~lined in the NCP a~ Sec~~~n
;OO.430(e)(;)(iii}, were used to compare the alterna~ives and to determine
~he mos~ appropria~e alterna~ive for remedia~ion of the soils and groundwater
~ha~ is pro~ec~ive of human health and the environment. a~tains applicable or
=elevan~ and appropriate requirements (ARARs), is cost-effec~ive and
=epresen~s ~he bes~ balance among the evaluating criter~a.
-. Overall ?=o~ec~ion of Human Health and t~e Environment addresses whether or
no~ a remedy provides adequate protection and describes how risks are
elimina~ed. =educed or =ontrolled through treatment. =ng~neer~ng con~rols
or inst~~~~~cnal controls.
-' Co~oi~~~=e ~~~~ ~?~Rs a~dresses r.cw t~e ~roposed a~ternat~ve complies w~~h
~ll app~~=acle or relevant and appropr~a~e requ~rements of Federal and more
stringen~ S~ate env~ronmen~al laws (ARARs) and also considers how
al~erna~~ves comply with advisories or other guidance that do no~ have the
s~atus of laws, but that the EPA and the State have agreed should be
considered for protectiveness, or to carry out certain actions or
requiremen~s.
- .
Lona-te=m Effectiveness and Permanence refers ~o
maintain reliable protection of human health and
once cleanup goa1s have been met.
~he acility of a remedy to
the environment over time,
4. rteduct~on of Toxicitv. ~obilitv or Volume Throuah Trea~ment refers to the
ability of a remedy to meet the preference stated in Section 121(b) of
CERCLA, :or remedies that involve trea~ent to reduce permanently the
~oxici~y, mobility, or volume of hazardous substances and con~aminan~s.
:5 .
Short-~erm Effectiveness addresses the ability of alterna~ives to manage
risks during the construction and implementation phases. and reduce
~ediate risks posed by the hazardous materials present.
6. ImDlementabilitv is the technical and
remedy, including the availability of
implement the chosen solution.
administrative feasibility of a
goods and services needed to
7. ~ includes capital and operation and maintenance costs.
8. SUODort Aaencv AcceDtance indicates whether, ba.ed on its review
Feasibility Study and proposed Plan, the support agency concurs,
or has no comment on the preferred alternative.
of the
oppose.,
9. communitv AcceDtance summarizes the public's general response to the
alternative described in the Proposed Plan. Community Acceptance is
detailed in the attached Responsiveness summary.
22
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7~e fcllcw~ng comparison of alcerna~ives c~ns~ders ehe op~ions t~r soils and
groundwa~er~
-. Overa~l Protect~on of Human Health and the £nv~rODmeDt
5~ils Alterna~i~es
Alterna~~ve S5 elimina~es on-site human health risks associa~ed wich
inhala~ion, inges~ion, and direc~ c~n~ac~ wi~h c~n~aminaced so~ls.
Alterna~ives 53 and 54 will elimina~e or su~s~an~ially reduce and con~rol
human heal~h risks associaced wi~h inhala~ion, inges~ion, and direcc contact.
Groundwacer impac~s due co leaching of con~am~nan~s from soils will be
elim~na~ed under Alcernative 55, and elimina~ed or substantially reduced under
Alterna~ives 53 and 54. Alterna~ive 52 will reduce direc~ con~ac~ risk and
ehe risk of con~aminants leaching from ~he soil and impac~ing ~he groundwa~er
by containing soils under a cap.
Groundwaeer Alternacives
~lcernac~ves GW3 and GW4 w~ll be prccec~ive 0: ~uman healch and environmen~ as
~=ea~men~ ft~ll reduce ehe c~ncen~ra~~on c: ==nc~~~nancs co ~eiow heaich based
scandards. Alternacive GW3 may have difficulcies ~n ae~a~n~ng ehe cleanup
s~andards for carbon eecrachloride and chloroform. Alternacive GW2 will
provide proeec~ion ~o human healeh by implemeneing land use res~ric~ions to
preven~ cons~ruc~ion of drinking wacer wells -~ site: however, land use
restrictions will no~ preven~ exposures to con~aminated groundwa~er ~hat may
migra~e from ~he si~e or reduce risks ~o environmen~al recepeors.
2. Comp~iance with Applicable E i Relevant and Appropriate Requirements
(ARARs)
50ils Alterna~ives
Alterna~ives 53, 54, and 55 will comply with the ARARs ident~fied for these.
alterna~ives. The.. alterna~ives will meec ehe Michigan Act 307 Type 8
=leanup requiremencs for organics a~ all areas ou~side the landfill area. Due
~o ehe capp~ng of ~he landfill area, chese alterna~ives will meee ehe Michigan
Act 307 Type C cleanup requiremen~s for ~he overall cleanup.
Alterna~ive 52 will not
soil cleanup standards,
action.
comply with the Michigan Act 307 Type A or Type 8
but may meet the requirements for a Type C remedial
Ground~~ter Alternatives
Alternae~ves GW3 and GW4 will comply with the ARARs identified for these
alternatives. Th... alternatives will comply with the requirements for a
8 cleanup for qroundwa~er. Alternative GW3 may have difficulty complying
the cleanup levels for carbon te~rachloride and chloroform.
~
w~h
Alterna~ive GW2 will no~ comply with the maximum contaminant levels (MCLS)
iden~ified in Act 399 and will not meet the wa~er quality criteria for human
health. This alternative will no~ comply with the requirements for a ~ A
or Type 8 cleanup under Michigan Act 307.
23
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- .
Long-term Effectiveness ana Permanence
Soils Alterna~ive9
~~terna~ive S5 prov~de9 for long-~erm effec~ivene9s and permanence by removing
so~l con~am~na~ed wi~h organ~c compounds. ::0 unaccep~able risk from organic
=ompounds w~ll remain at the si~e under Alterna~ive S5. unacceptable risks
==om organ~c and i~organic compounds under Alternative S3 will be effec~ively
=limina~ed by v~~=i:ying ~he soils in~o a solid impermeable mass and placing
~he vi~ri:ied so~ls under an Michigan Act 641 cap.
Alterna~ive S4 w~ll provide for long-term effectiveness and permanence ~hrough
~=eatmen~ of the soils by LTTT. 7~is trea~ment will permanently reduce
~rganic con~am~na~ion in the ~rea~ed soils. Risks from any remaining
~norganic c=n~am~na~ion will be controlled by placing ~he soils under a clay
=ap.
~lternative S2 w~ll reduce di=ec~ con~ac~ =isk by placing th~ soils under an
:-:ic:l:..gan ;'ct 54 cap, ;:ut ..,ill :lot provide as much permanence as the treatment
=emeQ~es. :~is alternative may r.ot :e etfec~:..ve ~:l elimina~:..~g ~~e leacning
;f contam~nantS from so~l into ~he groundwa~er due to the high water table and
~he highly permeacle nature of the soils at the site.
Groundwater Alternatives
Alterna~ives' GW3 and GW4 will reduce risks to acceptable levels by providing
for the permanen~ removal of contaminants from the ground~ater via treatment.
Alternative GW3 may have difficulty attaining the cleanup standards for carbon
tetrachlor~de and chloroform. :f this alternative cannot attain cleanup
levels, unacceptable risks may remain. Alternative GW2 will not provide
adequate long-term effectiveness and permanence because contaminants will
remain in the groundwater and may migrate from the site.
4. Reduction of Toxicity, Mobility, or Volume Through Treatment
Soils Alternatives
Alternatives S4 and 55 will reduce the toxicity and volume of organic
compounds, pe8ticides, and PCBs. The.e alternatives will not reduce the
toxicity of any metals that may be contained in the thermal treatment
residuals. Alternative 54 will limit the ability of any remaining metals in
the treated soil to impact groundwater by containing the soils under a clay
cap.
The toxicity of the volatile organic compounds will be reduced under
Alternative 53. Th. toxicity of non-volatile organic and inorganic ccmp0und8
will not be reduced: however, Alternative 53 will effectively ~bili:e the
non-volatile organic and inorganic compounds. The volume of contaminated
soil will be somewhat reduced due to water evaporation and el~tion of soil
pore space.
Alternative 52 will not reduce the toxicity, mobility or volume of
contaminated soil.
24
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Groundwa~er Alte~na~iveg
rtlterna~ive5 GW3 and GW4 will reduce the toxicity, ~obility and volume of
~on~aminants in t~e groundwa~er, and will sa~isfy the s~a~u~ory preference for
~s~ng trea~en~ as a principal elemen~ of the remedial alterna~ive. 5pen~
=arcon, which would require managemen~, will be generated as par~ of
~lternative GW4. ~lterna~ive GW2 will no~ reduce ~he toxicity, mobility or
-olume of =on~am~~ants in the groundwater, and will no~ use ~reatment as a
pr~ncipal elemen~ of the remedy.
-.
Short-tera Effec~iveD...
So~is Alternati7es .
rtlterna~ives 52. 53. and 54 will not presen~ shor~-term impac~s to on or off-
s~te residences, =ons~ruction workers, or the env~ronmen~. Standard safety
programs, such as fencing, use of protective equipmen~. monitoring. off-gas
~reatmen~ and dust =ontrol measures should mitiga~e any shor~-term risks.
~~der Al~erna~ive 55, ~~ere would be po~en~ial risks to puclic health and the
~nv~~onmen~ =ur~ng transpor~a~~on 0: t~e c9n~am~nated soils to the
~no~nera~~on fac~:~~!, ~nless spec~al safe~y ~easures were taken.
~lterna~~7es 5S and 52 could be ~mplemen~ed in a snor~er time frame than 53
and 54 because pi~Q~ s~udieg would no~ be needed.
Groundwa~er Alterna~ives
rtlterna~ives GW3 and GW4 should no~ presen~ shor~-term impacts to on-site or
off-site residences, workers, or the environmen~. Evalua~ion ~f this
criterion is no~ app~icable for Alterna~ive GW2 because cons~ruc~ion is no~ an
element of this alternative. GW4 could be implemented fas~er tha~ GW3 because
it is a more conven~ional groundwater treatmen~ technology.
6. ImplemeDtability
Soils Alternatives
rtlterna~ive SS should be easy to implemen~ depending upon the available
capaci~y of an off-site treacmen~ fac~lity. rtlterna~ive 52 should be easy to
implemen~. Alterna~ive 54 is easy to implement depending upon the results of
pilot tes~inq and ~he availability of a mobile thermal treatmen~ unit.
Alternative 53 may be more difficult to implement due to the availability of
the vitrification process. Vitrification is currently available from only on.
vendor and this vendor is currently experiencing delays in their projects.
Groundwater Alternatives
Alternatives GW3 and GW4 are relatively easy to implement. Both have been
used at several sites to remediate contaminated groundwater. The equipment,
services, and ma~erials necessary to implement these alternatives are readily
available. Alterna~ive GW2 is technically feasible to impleme~t and the
equipment, services and materials needed are readily available.
2S
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7. Costs
7he cos~s == i~dividual ~~~erna~ives are detailed below.
Capi~al ;"nnual Total Present
~ O&M Cos~ Wo~h Cost
,;;lternatio;e 52 51,5;7,000 573,000 52,718,000
;"lterna~~o.'e 53 54,249,000 539,000 54,843,000
;..lternati';e 54 52,~;;0,000 $39,000 $2,824,000
;..lternati':e 55 $8,103,000 539,000 $8,697,000
~olternat~':e GW2 516,000 559,000 5917,000
;..lternati';e GW3 51,076,000 5173,000 (yrs 1-10) 52,857,000
559,000 (yrs 10-20)
.;lterna~io:e GW4 5485,000 5278,000 (yrs 1-10) 53,076,000
559,000 (yrs 10-20,
7~ese c:s~s are based upon ~he F5 report costS and ~echn~cal ~emos completed
after ~he =eas~bility study.
8. U.s. Environmental Protection Agency Acceptance
The MDNR was the lead agency for conducting the RI/FS and"preparing the ROD.
The EPA agrees with the remedy as selected in the ROD.
9. Community Acceptance
The public has in general been supportive of the preferred alternative as
described in the Proposed Plan. community acceptance is assessed in the
attached Responsiveness summary. The Responsiveness summary provides a
~horough r~view 0: the pu~lic comments received on the Proposed Plan, and the
agencies' responses to those comments.
THE SELECTED REMEDY.
Based upon the requirements of CERCLA, as amended by SARA, the NCP, the
detailed analysis of alternatives and puDlic comments, the MDNR and the EPA
have selected Alternative S4 for addressing soil contamination and Alternative
GW4 for addressing the contaminated groundwater to comprise the remedial
action for the Duell-Gardner site. Given the available information, the KeRR
and the EPA believe the selected remedy is protective of human health and the
environment, complies with ARARs, provides the best balance of trade-offs
under the nine evaluation criteria and is a C08t effective solution.
The main components of the preferred alternative are:
..
Excavation of contaminated soils and treatment of these soils on-site using
a mobile Low Temperature Thermal Treatment sY8tem~
26
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Extrac~~on of con~amina~ed groundwa~er and on-s~~e ~rea~men~ using a Carbon
~dsorp~ion ~rea~men~ sys~em.
:~s~alla~ion of a clay cap c~ ~~e landfill area mee~i~g ~~e requiremen~s of
Michigan Ac~ 641.
~.S. EPA and MDNR will seek ~= i~pose site deed res~ri=~ions t~at preven~
ins~allation of drinking wa~er wells in the affec~ed area 0: t~e si~e
during remedia~ion.
Groundwater monitoring ~o assess the state of the remediation and assure
con~ainmen~ of the con~aminan~ plumes.
Performance of a Pre-design I~ves~iga~ion to further define the limits of
the ccn~amina~~on.
7~e goal of ~~e soil elemen~ cf ~~~s remedial ac~ion is to res~ore all areas
=~ts~de t~e landfil~ area ~o t~e~r oeneficial uses. 7~e 50~ls to be excava~ed
:or ~rea~men~ ~~=lude all so~ls ~~~~ organ~c =on~amina~icn acove ~~e Michigan
~c~ 1:7 ~'lpe B cr~~er~a. :~ is es~~a~ed tha~ a ten foo~ square area around
each soil sampling poin~ will be excava~ed and somewhat larger areas around
~he test pit loca~ions. :t will be necessary to perform verification sampling
around each tes~ pit to ensure that all contaminated soil has been excavated.
It also may be necessary to perform some additional soil sampling during the
Pre-design Investigation to further define the limits of soil contamination.
~lso, soil :eachate testing may be performed to determine the Michigan Act 307
Type B standards for cer~ain soil =on~aminan~s as provided in MAC
R299.S711(2).
The treated s6il will be placed on the old landfill area and the landfill will
be properly closed. A clay cap will be placed on the landfill area that meets
the closure requiremen~s of the Michigan Solid Waste Disposal Act, 1978 PA .
641, as amended. The cap will consist of two feet of compacted clay overlain
~y additional soil. to provide for drainage and frost protec~ion. ~~e landfill
area will be fenced and the U.S. EPA may seek to impose land use res~riction.
on the landfill area.
The goal of the groundwater element of this remedial action is to restore the
groundwater to its beneficial use, which is use for residential purposes.
Based upon information obtained during the RI/FS and upon a careful analy.i.
of all remedial alternatives, the HeRR and the EPA believe that the selected
remedy will achieve this goal. The groundwater will be extracted and treated
until such time as monitoring indicates that the MCLs and the Michigan Act 307
Type A/B standards have been met and maintained. The point of compliance
shall be any point in the aquifer excluding the landfill area. It is
estimated that it will take ten years to complete the groundwater treatment.
It is anticipated that the groundwater at the site will be mon: :red for the
next thirty years.
To properly design the groundwater extraction system, additional information
will need to be gathered to define the full extent of the groundwater plume..
This information will be gathered during the Pre-design Investigation. At a
minimum, additional monitoring wells will be installed downgradient ot the two
contaminant plumes. . .
27
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:~e es~~a~ea C05~S assoc~a~ea wi~h ~~e 5elec~ea remeay,
~lterna~i7es 54 ana GW4, are:
a cOmDina~ion of
capital cos~
AnDual O&M Cos~ (for years
Annual O&M Ccst (for years
Total Present Worth Ccst
cne through ten)
ten through tweD~Y)
S 2,715,000
S 317,000
S 98,000
$ 5,902.000
The annual =pera~~on and main~enance c=s~s for ~he firs~ ten years include
opera~ion 0: ~he groundwa~er ex~rac~ion and ~rea~men~ system as well as
groundwater moni~o~ing and main~enance of the landfill cap and fence. ~he
annual =pera~ion and main~enance cos~s for ~he nex~ ~wen~y years i~clude
grounawa~er ~oni~cr~ng and ma~n~enance or t~e landfill cap and fence.
STATUTORY DETERMINATIONS
~~e 5eiec~eo remeay ~~il ==n~r=i ana reduce risks assoc~a~ea.wi~h ~~e
:=n~am~~a~eo so~l ~na c=n~am~na~ea gr=unawa~er a~ ~~e Duell-Gardner ~andfill.
:~e s~a~u~==y req~~=emen~s c: C~RC~A 5ac~~=~ l~: ana Michigan Ac~ ~J7 ~~ll be
sa~~sfied ~= ~he ex~en~ ?rac~~=a~le w~~h ~~e implemen~a~~on or the chosen
remeaial ac~ion. ~he follow~ng is an enumera~ion of how the selec~ed remedy
addresses each requiremen~.
1. Protection of Human Health and the Environment
The selec~ed remedy will proviae adequa~e pro~ec~ion of human health and the
environmen~ ~hrough ~rea~men~.
Risk posed by soil and groundwa~er contamination at the site will be reduced
and con~rolled by ~he groundwa~er ex~raction and treatment system, the soil
excava~ion and treatment and by the capping of the old landfill. The selected
remedy will attain Michigan Act 307 Type A or B standards for contaminants in
the grounawater. ~he selected soil remedy will provide for closure of the
landfill ana will comply with a Michigan Act 307 T:rpe C remedy. ~he soil
remedy ~~l: also provide for ~he removal and treatmen~ of organ~c soil
con~amina~~on above Type A or B limits for areas ou~side the landfill.
No unaccep~able short term risk will be cau.ed by implementation of the
remedy. 5hor~-term risks include exposure of si~e workers and the community
to dus~ and noise nuisance during implementation of the soil and groundwater
remedies. Standard safety programs. such as fencing, use of protective
equipmen~. monitoring, off-gas treatment and dust control measurea should
mitigate any short-~erm risks. Also, the landfill and contaminated soil area.
are loca~ed on the back portion of the site, away from the road and other
residences, and these locations are somewhat secluded in a wooded area.
2. compliance with Applicable or Relevant &Ad Appropr:i.ate Requirements
The selected remedy will be designed to meet all applicable and relevant
requiremen~s (ARARs) of Federal and more stringen~ state environmental law..
The following discussion provides the details of the ARARs that will be met by
the selec~ed remedy.
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CHEMIC~L S?EC::!C ~RARs
Safe Drinking Water Act of 1974, as amended (42 U.S.C. 300f)
~o CFR 141 - ~ax~um Contaminant Levels (MCLsI - ~staDlishes MCLs for
inorganic and organ~c chemicals. coliform bacter~a. radium 226. radium 228,
alpha particles. and photon radioactivity in pucli: water systems. ~CLs for
=~ntaminants in g=oundwater will be met.
Clean Water Act of 1977, as amended (33 U.S.C. 1251)
40 CFR 129 - Toxic pollutant Effluent Standards - ~stablishes effluent
standards prohibi~~ons of specific compounds for specified facilities
discharg~ng to nav~gable waters. ~hese requirements may apply to the
jischarge 0: ~=eated groundwater. should t~e discharge be to a surface
water.
Clean Air Act of 1963. as amended (~2 U.S.C. 7401)
40 CFR 50 - National Primary and Secondary Ambient Air Quality Standards -
~stablishes natic~~l air quality standards. The appendices provide methods
and procedures fo: ~easuring specific air pollutants. These standards may
apply to the operation of the soil treatment system.
40 CFR 61 - National Emission Standards for Hazardous Air pollutants -
:dentifies substances that have been designated hazardous air pollutants, and
specifies prohibited activities, describes procedures for determining whether
construction or modification is involved, prescribes methods of applying for
approval and covers the manner in which start-up notification is to be
provided. The substantive requirements of this part may applY to the
operation of the soil treatment system.
Water R.sour~es Comaission Act, 1929 PA 2~5, as ameDded
Part 4, Rule 57 - Water Quality Standards - Establishes limits for all waters
of the State for the following components: dissolved solids, pH, taste and
odor producing suestances, total phosphorous and other nutrients, and
dissolved oxygen. These requirements will apply to the discharge of treated
water, should it be discharged to a surface water.
Part 21 - '.~~tewater Discharge Permits - Establishes permit requirements for
the discharge of wastewaters to the ground. The suDstantive requirements of
this part will apply to the discharge of treated water, should the discharge
be to the ground.
Part 22 - Groundwater Quality - Establishes non-degradation requirements for
groundwaters of the state.
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MichiqaD EnviroDmeDtal RespoDse Act, 1982 PA 307, as amended
Part 7 - c:eanup Criter~a - Establishes cleanup criteria for three types of
~emediat~=~s: T:'Pe A, Type S, and Type C. ~he T:'Pe A and Type S substantive
~equirements apply to the groundwater remedy and the.. standards will be met.
~s a whole. ~he soil :emedy will meet the requirementS of a Type C remedial
act~on: r.c~ever, ~he so~l ~o be excavated and treated wil: include all soil
~hat ~s i~ excess of ~he Type A or B standards for organics. This will
?rov~de f:= ~he soils outside the landfill area to be returned to their
beneficial \~e. resident~al) uses.
Air PollutioD Act, 1965 PA 348, as ameDded
Parts 3, 7, and 9 - Emissions - specifies emission l~itations for
particulates, fugitive dust, VOCs, and contaminants which may be injurious to
or adversely affect human health or welfare, animal life, 'legetation, or
property, := interfere w~th normal use and enjoyment. The substantive
=equ~remen~s of ~hese par~s w~ll apply to the soil excavation, the operation
:: the 5C~~ ~=eatment system, and constr~=t~on act~'l~ties.
ACTION S?ECIFIC ARARs
R.source cODservatioD aDd Recovery Act of 1976, Subtitle D, as a.aDded (42
U.S.C. 6901)
The substantive requirements under Subtitle D concerning landfill closure will
be met.
Solid Waste ManagemeDt Act, 1978 PA 641, as ..aDdad
7he substant~ve requirements concerning landfill closure are relevant and
appropriate to the construction of the landfill cap. These requirements will
be met.
Air PollutioD Act, 1965 PA 348, as aaeDded
Parts 3, 7, and 9 - Emissions - specifies emission l~tations for
particulates, fugitive dust, vocs, and contaminants which may be injurious to
or adversely affect human health or welfare, animal life, vegetation, or
property, or interfere with normal use and enjoyment. The substantive
requirements of these partS will apply to the sail excavation, the operation
of the sail treatment system, and construction activities.
Part 10 - Intermittent Testing and Sampling, may require performance of
acceptable performance tests. The substantive requirements of this part
apply to the sail treatment system.
will
30
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~
3. Cost Effectiveness
~he selec~ea remedy provides for overall cos~ effec~iveness. ~he on-site
~rea~men~ of the con~amina~ed soils provides for a estima~ed sav~ngs of over
54,Saa,aao over off-si~e incinera~~on. The selec~ed groundwa~er remedy will
cos~ minimally more ~han ~he ultraviolet oxidation alterna~ive bu~ it is
expec~ed ~= be more effec~ive in removing certain cen~aminantS and is
cons~dered ~~ be a more reliable a~terna~ive.
4. Utilization of Permanent Solutions aDd Alternative ~reatment (or resource
recovery) ~echDoloqies to the Maximua Extent practicable
The selec~ed remedy utilizes permanent solutions and alterna~ive ~reatmen~
~ecnnelogies ~o the maximum ex~en~ prac~icable. 80th the trea~men~ of the
so~l by Low Tempera~ure Thermal Trea~ment and ~reatmen~ of groundwater by
Careen ~dsor~~ion will permanently remove con~amir.~n~s from ~hese media.
:=~ Temperature Thermal Trea~ment of so~ls is cons~dered an al~erna~ive
~~~a~men~ ~ecnnology.
The
3y trea~~r.g ~~e con~am~nation ~n t~e groundwa~er and in the so~l ~~e selected
remedy satisfies the s~atutory preference for remedies that employ ~reatment
which permanently and significan~ly reduces ~oxicity, mobility or volume of
hazardous substances.
s. Preference for ~reatment as a Principal Element
The selec~ed remedy satisfies the statutory preference for ~reatment as a
principal elemen~ since it provides for ~rea~men~ of the principal threa~
(con~amina~ed soil) a~ the site through low temperature thermal treatment.
31
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