PB94-964102
EP AIRODIR05-94/248
July 1994
EPA Superfund
Record of Decision: .
J and L Landfill Site,
Rochester Hills, MI
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U . ~. Environmental Protection Agency
Region 1/1 Hazardous Waste .
Technical Information Center .
841 Chestnut Street 9th Floor ..,:{
Philadelphia I PA 19107 '. <~:~~k~
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HazardouS Waste CoUeGtion
Information Resource Cehter
US EPA Region 3
Philadelphia, P A 19107
E~A Aatill@~ft CiUtSciml1l
\ ~fi1Iff@rrm~f!D@UD [?Ji~@llIIrrlC~ C~~i~8' '
! US IEf~ ~@WJA@gj) 3
J Phni«Qr&8~~;~, fA 191@7

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DECL\R.-\TlO:\ FOR THE RECORD OF DECISIO:\
~ITE :\:\.\IE .-\",\1} LOCATIO:\
L\:L LlI1dfill. Rl1ch~st~r Hills. Michigan
~T.-\TE:\IE:\T OF BASIS 1\..,\1) PCRPOSE
This decision document presents the selected remedial action for the J&L Landfill. in Rochester
Hills. Michigan. which was chosen in accordance with the Comprehensive Environmental Response,
Cumpensation. and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments
and R~author;zation Act of 1986 (SARA), and. to the extent practicable. the National Oil and
H~z~rdous Substances Pollution Con~;ngency Plan (NCP). This ROD is for the landfill operable
unit (OU I) r~medial action. Groundwater will be addressed as OU2 in a separate document. This
dc:cision is based on the administrative record for the site.
The State of Michigan concurs with the selected remedy because it is expected to attain a standard
of performance that is equivalent to that required under Michigan Act 64. However, the State of
Michigan disagrees with the U.S. EPA's determination that Michigan Act 64 is not an Applicable or
Relevant and Appropriate Requirement (ARAR). The State of Michigan believes that Act 64 is an
ARAR.
ASSESSME:\'T OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action 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 purpose of this remedy is to reduce the risks associated with exposure to the contaminated
materials and to reduce the potential for migration of contaminants to the groundwater. The selected
rc:medy for OU 1 consists of a I-foot compacted clay layer overlain with a Geosynthetic Clay Liner
(GCL)/60 mil Flexible Membrane Liner (FML) barrier layer, a drainage layer consisting of geonet
with geotextile filter fabric, a 36-inch clean fill layer,' and a 6-inch topsoil layer; consolidation of
the contaminated soil and sediments from the east ditch; and monitoring of the contaminated
groundwawr beneath the site. In addition, a proper slope will be constructed and maintained so that
all surface water runoff properly drains off the cap into a collection system, or drainage ditches
around the perimeter of the site.
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( )(11-.:1' dl(l1pllll~I1tS ",It [h~ ,~kl:t~d r~m~dy indude:
.-\banuoning (plugging) the sediment pond culverts. consolidating any contaminated
'>l)ilsi\jediments beneath the existing landfill cap and backtl11ing the sedimentation pond to grade
\\ ilh l.:kan till.
ClHlsulidating any (ontaminated surface soils and sediments. including landfill waste. from the
~ast Jitch to beneath the existing landfill cap.
Regrading the south ditch to retain existing stormwater capacity.
Preparing the existing landfill surface in order to provide a foundation for the new cap, as well
as removing existing vegetation from the landfill surface. '
;~
Regrading the site to promote runoff.
Retrotitting existing monitoring wells.
Installing a passive gas management system.
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Implementation of long-term groundwater monitoring program to ensure the effectiveness of
the remedial action.
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Vegetative cover placement.
..
Fence installation.
'"
Use of institutional controls, including deed restrictions, to limit land and groundwater use.
Monitoring plan for cap integrity and fence inspection, and landf1l1 gas migration.
STATUTORY DETER'\1INATIONS
The selected remedy is protective of human health and the environment, complies with Federal and
State requirements that are legally applicable or relevant and appropriate to the remedial action, and
is cost effective. This remedy utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable for this site. However, because treatment
of the large volume of waste was not found to be practicable, this remedy does not satisfy the
statutory preference for remedies that redt.. -' the toxicity, mobility, or volume as a principal
dement.
Because this remedy will result in hazardous substances remaining on site above health-based levels,
a review will be conducted within five years after commencement of the remedial action to ensure
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111:1! lile rl:llh:d: \.l'lltil1l1cS !\I pfl'\ id~ adequatt prot~ction of human h~alth and the e[1\'ironm~n!.
STATE C()'CllffiE~CE
Till: Slatc lIt' \li.:higan .:oncurs \\'ith the sekcted remedy because it is expected to attain a standard
,II j1L'11'1If11U1k'C that is cqui\'aknt to that required under Act 64. However. the State of Michigan
dill:" litH ;l~rCC \\ith thc C.S. EPA's detennination that Michi!!an Hazardous Waste Mana!!ement Act
- ~-
()~ lit' 1 Y74. as amended. and administrative rules is not ARAR. The State's position regarding their
bclicf that ~Iichigan Act 6~ is an ARAR with respect to the J&L Landfill is attached to this ROD as
pan l,f the Responsiveness Summary.
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V"/' Ar /ttL
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if J /{.C 1.(' ,L /. /'.
Valdas V. Adamkus
Regional Administrator
,/i;/fy
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Date
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TABLE OF CONTENTS
A. Sit~ Location and Description
B. Sit~ History and Enforcement Activities
C. Highlights of Community Panicipation
D. Sl.:ope of the Selected Remedy
E. Summary of Current Site Conditions
F. Summary of Remedial Investigation Results
G. Summary of Site Health Risks and Environmental Impacts
H. Rationale for Funher Action
I. Description of Alternatives
J. Summary of Comparative Analysis of Alternatives
K. The Selected Remedy
L. Statutory Detenninations
Attachments
Figure I
Figure 2
Table I
Table 3
Responsiveness Summary
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DECISION Sl~[~[ARY
J&L wl1<.Ifill
..\. SITE L()CATI()~ A..'\l> DESCRIPTIO~
The J&L wndfill Supafund site is located on Hamlin Road in Rochester Hills. rvIichigan (Figure
I). Th~ ar~a surrounding and including J&L Landtill is generally level. with the exception of a
drainag~ ditch along the eastern boundary, Ladd Drain near the non hem boundary. the south ditch
alung Hamlin Road. and a sediment pond in the nonhwestern comer of the site (Figure 2). The
sediment pond contains continuously flowing water fed by groundwater and an inlet culven
uriginating off-site. There is also a concrete outlet culven which is believed to be oriented to the
northeast. passing under the landfill. the east ditch, and the adjacent propeny and terminating in
wdd Drain. Vegetation covers most of the site except in scattered patches and roadways. Access
tu the site is unrestricted.
Land us~ in the vicinity of the J&L site includes residential. industrial. recreational, other landfills,
and mining (Figure 2). The J&L site is bordered on the east and nonh by Sandfill Landfill No.2,
and on the west by Sandfill Landfill No.1. There are at least six other landfills within one-half
mile of the site. Residential areas exist within 500 feet of the southern propeny boundary,
approximately 1.000 feet nonhwest of the site, and approximately 600 feet east of the site along
Hamlin Road. The J&L site and adjacent properties are zoned light industrial.
The J&L site is located less than I mile west of the Clinton River which flows from nonhwest to
southeast through the Rochester-Utica State Recreation Area. Ladd Drain, which is located on the
northern boundary of the site. drains into the Clinton River. Surface water drainage from the area
also tlows primarily to the nonh and east toward the Clinton River. Groundwater flow direction
similarly. is towards the nonh and east.
B. SITE HISTORY AND E.~ORCL'1ENT ACTMTIES
I. Site His~
Sted slag and steel manufacturing wastes were the primary wastes disposed at the site, which was a
former sand and gravel borrow area. During 1967 or 1968, baghouse dust f1lters were installed on
the de(;tric arc furnaces at the J&L Steel Warren, Michigan facility. The dust collected by these
filters. referred to as electric arc furnace (EAF) dust, was thereafter codisposed of with slag at the
J&L site. This EAF dust. if classified today, would be considered a listed hazardous waste under
the Resource Conservation and Recovery Act (RCRA). Disposal operations at J&L may have
staned as early as 1951 and were terminated in 1980 when the site was closed and the current cap
was installed.
By November of 1980. J&L landfill had been brought up to grade. as specified by Avon
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T\I\\ Il,hip Rlldl~~t~r Hills. and I:o\'~r~d with a landtill cap. Th~ \.:urr~m (ap app~ars to have bc~n
III I \;,;d \\ itl! ~Iag l11aterials. .-\dditionally. th~re an~ ar~as void of \'~getatioll and sl:attered areas of
deb. i~ a~f'lI~S th~ surfac~. This indicates that the current cap is not adequate and requires
i I11prl'\ el11ent.
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Past Studies
III 1 Y76. the Michigan Department of Natural Resources (MDNR) conducted an area-wide
groundwater study and identitied an area of groundwater contamination primarily attributed to a
landtill west of the J&L Landtill. As a result. local residents were provided with an alternative
drinking water supply. This study also determined that although the area-wide groundwater
...:untamination problem was attributable to many possible sources. the J&L site was probably
(ontributing as well.
U.S. EPA Region V files indicate that the J&L Steel Company submitted a Comprehensive
Env i ronmental Response, Compensation. and Liability Act of 1980 (CERCLA) notification in June
1981. claiming ownership of the subject property for which it reported disposal of 55,555 cubic
yards of steel slag from 1966 to 1980. Ecology and Environment, Inc. (E&E), completed a
Preliminary Site Assessment in July, 1983, foUowed by a Site Inspection in June, 1984 to verify the
site location and ownership. The Hazard Ranking System (HRS) scoring was completed by an E&E
Field Investigation Team (AT) in July 1985, with an HRS score of 31. 65 based on the site's
potential for groundwater contamination. The site was proposed for addition to the NPL in the June
10. 1986 Federal Reeister (VoL 51, No. Ill, pp. 21099-21108).
A comprehensive field investigation was conducted during the Remedial Investigation (RI) in order
to determine the nature and extent of contamination at J&L. This investigation included geophysical
study. waste characterization borings foUowed by waste sampling and analysis, surface soil
sampling, surface water sampling, sediment sampling, groundwater monitoring weU installation and
sampling. and residential well sampling. Results of the RI are detailed in the RI report (December
1991 ). Based on the results of the RI and previous investigations, the U. S. EP A divided the site into
two sections called Operable Units (QU). Operable Unit I (QUI) consists of the landfill and its
(:ontents. Operable Unit 2 (OU2) consists of the groundwater and will be addressed in a separate
document in the future. The Site Focused Feasibility Study (FFS) for QUI was completed in
January of 1994. The FFS documents in detail the development and evaluation of several remedial
action alternatives for the landfill operable unit at J&L.
C. HIGHLIGHTS OF COMMUNITY PARTICIPATION
A RI fact sheet was released by the U.S. EPA in July of 1990, foUowed by a public meeting on
August 6. 1990, for the RI to inform the local residents of the Superfund process and the work to be
conducted during the RI. In February, 1992, the U.S. EPA issued a second letter to the public to
inform them of the upcoming RI public meeting on March 12, 1992, where the results of the RI
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.'. ;:1\: di,,\.'u~~~d.
11111)n\1aIil)n r~positorit:s hav~ b~~n ~stablish~d at the Rochest~r Hills Public Library. 500 aide
Tl)\\ n~ Rl)aLl. Rochester. Michigan and Rochester Hills City Hall. 1000 Rochester Hills Drive,
R, I\.'h~stcr Hill~. ~lichigan. In accordance with Section (l13)(k)(l) of CERCLA. the Administrative
ReclIrLl is available to th~ public at these locations. as well as the U.S. EPA Region 5 office in
Chil.'agl\. Illinois.
Th~ Propos~d Plan was available for public comment from January 25. 199.. to March 26, 1994
through the rekase of a fact sheet. A public meeting was held on February 9. 1994 to present the
proposed plan and U.S. EPA's recommended alternative for OUI at J&L Landfill. At the public
l11e~t i ng. U. S. EP A and the MDNR answered questions about the site and the remedial alternatives
under consideration. Fonnal oral comments on the Proposed Plan were documented by a coun
repol1er. A v~rbatim transcript of this public meeting has been placed in the infonnation
repositorit:s and Administrative Record. Written comments were also accepted at this meeting.
Ad\el1isements announcing the availability of the Proposed Plan and the stan of the comment period
wen: published in the Oakland Press on January 17, 1994. At the close of the public comment
pt:riod. February 29, 1994, a second release to the Oakland Press was issued to announce the
~xtension of the comment period until March 26, 1994. Post cards were also sent out to parties on
U. S. EP A's mailing list to announce the extension. Oral and wrinen comments received during the
above mentioned Public Comment period and the U.S. EPA's responses are included in the
Responsiveness Summary of this ROD for OUI.
The public participation requirements of CERCLA sections 113 (k) (2) (i-v) and 117 of CERCLA
have been met in the remedy selection process for the operable unit at J&L. This decision
docu ment presents the select::d remedial action for the J &L site chosen in accordance with
CERCLA. as amended by SARA and, to the extent practicable, the National Contingency Plan
(NCP). The decision for this Site is based on the Administrative Record.
D. SCOPE OF THE SELECTED REMEDY
The J&L Landfill is divided into two areas of concern or "operable units" (OUs): OUI consists of
the landfill contents, and OU2 comprises the groundwater. U.S. EPA anticipates that groundwater
will be addressed in a future proposed plan, upon completion of a focused feasibility study repon
for groundwater.
This ROD addresses the remedy for OUI at the J&L Landfill Site. The threats posed by this Site to
human health and the environment result from source material in the landfill and from contaminated
surface and subsurface soil in the landfill. This response action will contain the source material and
diminate risks associated with direct contact with contaminated soil/sediments. This response action
will be conducted in accordance with applicable or relevant and appropriate requirements of Federal
and State law. U.S. EPA considers containment of the landfill material, which is also a potential
source of groundwater contamination. to be the most practicable remedy. Containment of the
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1,1IIdrill ;d'\I t"1,lIlm..; LS. EP:\'s Pr~slll1lpti\~ R~m~dy approa~h for landtills. which slippons
-;II)pil1~ ;litcmau\eS t"11r sites \\her~ th~r~ is a large \'olum~ of low [~\'d \\'ast~ materials.
Tl1i~ remeJ~ lItiliz~s p~nnan~nt solutions and alternative treatment technologies to the maximum
1.'\lent pra~tkJble for the site. However. because treatment of the large volume of low level waste
malerials at th~ site was not fOllnd to be practicable. this remedy does not satisfy the statutory
prefer~l1l.:e for treatment as a principal element of the remedy.
B~l:alls~ this rem~dy will result in hazardous substances remaining on site above health based levels,
a five year re\'i~w will be conducted to ensure that the remedy continues to provide adequate
prutection of human h~alth and the environment.
E. Sl",[\IARY OF CURRENT SITE CONDITIONS
Th~ RI perfonned at the J&L Landfill Site was designed to characterize the nature and extent of
contamination posed by the landfilled materials at the site. and to conduct a human health risk
ass~ssm~nt and environmental assessment. The RI included sampling and an analysis of
groundwater. surface water. sediments of the surrounding ditches and pond. surface soil, subsurface
soil (waste borings). and residential wells. In addition to chemical analysis, waste boring samples
were collected and tested for their leaching potential (also known as EP toxicity).
Based on the results of the RI, U.S. EPA has detennined that current risks posed at J&L include
direct contact with sediments contaminated with PAH's and inhalation of surface soils containing.
~hromium and other heavy metals. Surface samples along the side slopes of the east ditch, sediment
pond, and Ladd Drain also contain low levels of Volatile Organic Compounds (VOCs) and
Semivolatile Organic Compounds (SVOCs), in addition to the heavy metals previously mentioned.
In addition. waste boring samples analyzed for leaching characteristics showed that selenium in one
sample and lead in another, had the potential to leach into the groundwater. Other heavy metals,
including nickel and zinc, were found to have leaching potentials, but do not have established EP
toxicity maximum allowable concentrations. U.S. EPA also detennined through the RI results, that
a threat to human health and the environment is posed through future residential exposure upon
ingestion of groundwater contaminated with arsenic, and through direct contact with sediments
~ontaminat~d with heavy metals and polyaromatic hydrocarbons (PAH's).
In addition. arsenic was also found in a saturated area of general refuse currently below the water
table. however. data indicates that the arsenic is not currently mobile and has not migrated off-site.
I. Topo~raphy
The J&L Site is on the surface of a glacio-lacustrine delta which slopes to the southeast at a
relatively shallow gradient. The delta is comprised of approximately 35 to 40 feet of sand and
gravel deposits which have been extensively mined throughout the area. Underlying the sand and
gravel deposits are thick lacustrine and morainal silty clay deposits, followed by bedrock composed
primarily of shales.
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Thr~e ~tratigraphic units ~t)nsisting of landfill materials. deltaic sand dnd gravel. and clay materials
\\ ~rc en\.'lllll1lc'red during drilling at the site. Landtill materials are further divided into clay
Illat~riah anLl '.\ aste till material. Clay and other materials comprise the landtill cap and solid fill in
areas 1hat arc de\oid of waste. presumably to bring the landtill up to surrounding surface grade.
Th~ thid'i.nes~ llf day in the current landtill cap ranges from zero to 2.75 feet: the thickness of the
,plitt cla~ fill ranges from ~. 75 to 19.5 feet. Waste material encountered consists of slag from 2 to
1 ~.5 feet thick and general refuse from 3.25 to 22.5 feet thick. In some areas. the two waste
materials are mixed. EAF dust was not directly observed in discrete quantities. but may have been
encountered a.s very fine-grained material mixed within general slag material. Sand and gravel
Jeposits ranging from 7.5 to 25 feet thick and silty clay directly underlie the landfill materials.
J, Hvdrolog\
An unconfined water table aquifer extends into the J&L Site waste materials. MonitOring wells
installed at on- and off-site locations indicate that groundwater flow in the upper and lower ponions
of the aquifer is eastward. and that the water table elevations fluctuate seasonally. Slug tests
perfonned on all on-site monitoring wells indicate that the mean hydraulic conductivities for the
upper and lower portions of the aquifer are 8.14 x 10-3 cm/sec, and 1.43 x 10-3 cm/sec, respectively.
These data indicate that the upper portion of the aquifer is more permeable and more conducive to
contaminant transport than the lower porion of the aquifer. This is also reflected in the fmer
material grain size and the decrease in moisture content observed with depth. The mean
groundwater flow velocity for the upper portion of the aquifer is approximately 175 ftlyear, and is
approximately 15 ft/year for the lower portion. Laboratory permeability test performed 00 silty clay
and clayey silt materials at the base of the shallow aquifer ranged from 5.5 x 10.7 to 6.6 x 10.7
em/sec. indicating that the materials are capable of retarding, but not preventing, venical migration
of groundwater.
Surface water tlow rates were measured during both dry and wet weather conditions at various
locations upstream, adjacent. and downstream of the J&L Site in Ladd Drain and the east ditch, and
in the on-site sediment pond. Based on the depth of the pond, surface water elevation, and
groundwater elevations in nearby wells, it is probable that the sediment pond acts as a localized
groundwater discharge zone. The sediment pond contains water that flows actively through the pond
in a west-to-east direction via inlet and outlet culvens.
~. Contamination Source
The source of contamination at J&L site is the landfilled waste, which is comprised of steel slag,
steel manufacturing wastes intermixed with EAF dust. and general refuse. The estimated volume of
waste contained within the landfill is approximately 455,000 cubic yards, of which approximately
65 % (295.750 cubic yards) consists of steel manufacturing waste (slag intermixed with EAF dust),
and approximately 35 % (159.250 cubic yards) consists of general refuse. Although J&L was
properly closed and capped in accordance with existing requirements in 1980, current site conditions
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illdi,-atl:: tllat till:: ~\isting (ap IH) Il)ng~r m~~ts \2urr~nt F~d~r.ll and Stat~ r~quir~m~nts. For ~xampl~.
,dtlll'lIgll ;1 ":L1luinuous grass ..:u\~r is pr~s~nt o\~r most of th~ sit~. th~r~ Jr~ also s~\'~ral areas \'oid
lIt \ ....g~tatil)(1 \\'h~re th~ soil is darkl:r in color or where roadways are pres~nt. Slag material is also
tllund at th~ surface of the landtill and debris is scattered over the surface of the landfill and along
tll~ -:ast dit\2h. Additionally. access to the property is also unrestricted.
F. Sl~l\IARY OF RE."IEDIAL I:\VESTIGATION RESULTS
Th~ R~medial Investigation was conducted during the summer of 1990, with additional sampling
(unduct~d in January 1991. The scope of work for the investigation included: sampling and
analysis of waste material. natural soil and surface soil, surface water and sediment, residential
wat~r wdls. and groundwater. A geophysical survey was also perfonned.
Results of the sampling indicate that the landfill contents are composed of clay materials consisting
of silty clay. clayey silt. sand, and waste fill material. Clay materials comprise the existing landfill
(ap and solid till in areas that are devoid of waste. presumably to bring the landfill up to
surrounding surface grade. Waste material encountered consists of slag from 2 to 18.5 feet thick,
and general refuse from 3.25 to 22.5 feet thick. In some areas the two waste materials are mixed.
There is also the possibility that EAF dust is mixed with some of the waste, although the data
collected to date does not confinn this.
The hydrogeological investigation indicates that the groundwater flow is from west to east. The
water table surface was found at approximately 13 to 16 feet below ground surface in the central
portions of the landfill. These elevations correspond to levels within the landfill waste.
Results of the waste boring samples indicates that VOCs and SVOCs are predominantly associated
with general refuse, while inorganics (metals) are the principal component of the slag material.
However. in an analysis perfonned by J&L Steel in 1980 of EAF dust collected from the J&L Plant
in Warrenville. Michigan, 2.1 weight percent of the EAF dust sample was found to be composed of
volatile solids/soils. Also, two waste boring samples collected from the area of general refuse
showed that Extraction Procedure (EP) toxicity values for selenium in one sample, and lead in the
other sample. exceeded the maximum concentrations of contaminants characteristic of EP toxicity,
as cited in U.S. Code of Regulations (40 CFR 261.24). For this reason, the general refuse material,
at least at the two locations, can be considered hazardous based on the leachability of lead and
selenium. Eight waste boring samples were also collected and analyzed from the slag and steel
waste materials. Although these results indicate that EP toxicity metal concentrations were very low
and not above standards, the.re is the potential for low levels of selenium, lead, chromium, nickel
and zinc to leach into the groundwater from the slag and steel wastes under the right conditions.
In other analyses. the slag material exhibited elevated concentrations of antimony, arsenic, calcium,
chromium, cobalt. iron, magnesium, manganese, nickel, silver, thallium, and zinc. Of these 12
inorganics. calcium, chromium, magnesium, manganese, nickel, and zinc were also reported as
components in the EAF dust analysis conducted by J&L in 1980. This indicates the probable
10

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l'I\.'".:n(t' lIt" E.-\F dust in the samples. although discrete quantities of the material were not
,p~"ilil.';dl~ pb~~f\.:J during Rl sampling.
Surt;II.'~ soil sampling results also indicate that low levels of organic compounds including toluene.
.I(dl'ne. bt'nwltntluoranthene. benzo\alpyrene and tluoranthene are present on the sides lopes of the
,,';I~1 di\l.'h. lln-"ite sediment pond. and Ladd Drain: and high levels of inorganic chemicals were
ddel.'leJ in the southwest and northeast areas of the site devoid of vegetation. Inorganics were also
detected in the existing landtill cap. but this may be due to mixing of materials when the cap was
installed. and/or the occurrence of weathering and erosion. The presence of these contaminants, in
addition to groundwater sampling results. indicate that the landfill may be a source of groundwater
(ontamination.
Groundwater sampling results indicate that VOCs, SVOCs, pesticides, and inorganic chemicals are
present in the groundwater. The VOC contaminants found included acetone, 2-butanone, benzene,
toluene. ehtylbenzene. and tOtal xylenes. The Maximum Contaminant Levels (MCLs) for total
'\ylenes. ethylbenzene and benzene were exceeded. The MCL for arsenic was also exceeded in
groundwater underlying an area of saturated general refuse. Although the detected VOCs assisted in
driving the future risk to human health and the environment up to the calculated levels, groundwater
in both the upper and lower ponions of the aquifer was also found to contain some VOCs as it .
entered the J&L site. Thus. the J&L site appears to be contributing to the area groundwater
contamination. most likely through the areas of general refuse where the majority of VOCs and the
highest concentrations were detected. The residential wells that were sampled downgradient of the
site were found to be free of contamination originating from the site.
G. SUMMARY OF SITE HEALTII RISKS AND ENVIRONMENTAL IMPACTS
As part of the J&L Landfill site investigation, U.S. EPA conducted a Human Health Risk
Assessment to determine if contamination from the landfill could pose a present or future risk to
human health. The assessment compared contaminant levels detected at the landfill with Michigan
and federal standards. considered the manners in which people could be exposed to these
contaminants. and estimated whether these contaminants could pose a threat to human health. The
potential risks to human health were calculated based on the assumption that no future remedial
actions would be taken at the site. The human populations potentially exposed to the contamination
at the site include persons living on the site and dinbike riders trespassing on the site.
When considering potential health risks, U.S. EPA examines two factors: the risk of contaminants
causing cancer. and the risk of contaminants causing other ailments, such as respiratory, hean, or
nervous system disorders. According to the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), U.S. EPA's general cleanup policy under Superfund indicates that when
the calculated cancer risk from lifetime exposure to site-related contaminants is more than one
additional cancer case in 10.000 people. some type of remedial action is generally required. When
the cancer risk falls between one additional cancer case in every 10,000 people and one additional
cancer case in I miHion people. action may be necessary depending on site-specific factors such as
11

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-;
-, .
I\\~'alil!n and ~11\ irol1m~mal impact. If the: risk is kss than one: additional cancc:r case: in I million.
,h:lilll1 i:-. gcn~rally not r~quire:d llnle:ss the:rc: is an unacce:ptJblc: "non-carcinoge:nic" or c:nvironmentJI
rt'lk.
\\'h~n calculating non-cancer risk. U.S. EPA uses a "hazard index" for both short-tenn (subchronic)
c'\pl1S11re:s and long-tenn (chronic) exposures. A hazard index of greater than l.O indicates a
Plltc:ntial for adverse health effects due to exposure to toxic compounds and is also considered an
unacce:ptable risk level which requires action.
The sdected exposure pathways considered to be most relevant at the J&L Landfill site are those
~Issociate:d with current dirt-bike riding and potential future residential uses of the site. Cancer risks
associated with the dirt-bike rider scenario exceed the I in one million "point of departure" with
re::spe:ct to dennal absorption of sediments and soil. inhalation of dust, and ingestion of sediments
and soil. In this case. for current on-site dirt bike riders the risk is 8 out of one million;1 EPA
seeks to manage sites such that the carcinogenic risk from any medium generally falls within a range
of 1O~ to Wob. EPA's preference is to be at the more protective end of the risk range (lo-b). The
noncancer risks associated with the dirt-bike rider scenario were found to be insignificant for the
c:valuated pathways (hazard index less than 1).
Cancer risks associated with the future potential residential scenario also exceed the I in one m~on
"point of depanure" for ingestion. inhalation, and dennal absorption of groundwater, and for
ingestion and dennal absorption of soil. Noncancer risks associated with the future residential use
of groundwater as a potable water supply also exceed acceptable levels (hazard index is more than
I), and are primarily due to arsenic.
The selected remedy for OUI will not directly address the groundwater contamination, which may
be attributed to several potential sources in the area, including the J&L Landfill site. As several
potential source areas may be involved, an area-wide groundwater study may be necessary to define
the plume of contamination and identify each potential source.
In addition to the Human Health Risk Assessment, an environmental assessment was also conducted
to c:valuate the potential impacts on the flora and fauna from the contaminants at the J&L Landfill
site. The site is primarily a flat, open field, with scattered areas of scrub brush. There are no
wetlands on the property. Surface water features are a man-made sediment pond, eastern boundary
ditch. a south ditch and Ladd Drain on the northern border. The flows in the drainage ditches are
ephemeral. The ecological receptors at the J&L Landfill site include both on-site vegetation and
local animal populations that may come into contact with site contaminants. It was detennined that
some risks may be associated with exposure for terrestrial. avian, and aquatic wildlife species;
however. these risks are e~ted to be low because no species is expected to receive large
exposures to the on-site contaminants.
. See RI for method of risk calculation.
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II. H..\TIO'.\LE FOR Fl"RTIIER ACTIO'
l".s. EP.~ has 1\\0 goals rdated to OUI. One is to protect peopk from breathing and ingesting
~1'lllaminalt:d dUSI particles and from coming into contact with contaminated soils and sediments on
tll~ "lIrfa(~ 11f tile landfill. The second is to minimiz~ the potential for contaminants (primarily
111~lah I ill [Il~ ;;enaal rduse waste. and in the slag internlixed with EAF dust. from affecting the
,-'11\ irl1nm~1H Ihrough runoff into ditches and drains. and from leaching into the groundwater. This
\\ ill reduc~ tilt: potential for further groundwater contamination from infiltration of water through
lilt: unsatUrated materials into the aquifer beneath the land till materials. Additionally, these two
goals would also prevent contaminants from impacting terrestrial. avian. and aquatic receptors.
Cancer risks to sensitive populations are withinthe U.S. EPA's point of depanure risk range. In
order to protect human health and the environment from these risks. U.S. EPA has evaluated
solutions for OUI that involve minimizing the potential for human and environmental exposure to
,-'untaminalion through containment. Containment is more practicable than treatment in this case,
hc:(ausc: of the large volume of low level waste materials. The FFS report for OUI documents the
c:\aluation of the magnitude of site risks. site-specific applicable or relevant and appropriate
rt:4uirements (ARARs), and the requirements of CERCLA and the NCP in the derivation of
remedial alternatives for OUI at the J&L Landfill Site.
I. DESCRIP'fION OF AL TERNA TIVES
Although the NCP reaffirms U.S. EPA's preference for permanent solutions to Superfund site
problems through the implementation of treatment technologies, the preamble to the NCP
contemplates that many remedial alternatives may be impractical for certain sites due to severe
implementability problems or prohibitive costs (e.g., treatment of the entire contents of a large
landfill).
For the landfill contents. U.S. EPA considered the following alternatives. The costs presented for
cach alternative include capital costs (equipment, labor, and other construction expenses to
implement the remedy), and maintenance costs (irrigating, fertilizing, and mulching soil cover or
making knc~ repairs). These costs are then combined and presented as a "present net worth," a
method of economic calculation that estimates the amount of money that would need to be invested
today at 6 percent interest in order to cover initial construction costs, as well as future maintenance
costs.
Of the four alternatives considered, the first is the No Action alternative, which is required by
Superfund regulations to be considered at every Superfund site. The No Action alternative is used as
a baseline against which all the other alternatives are measured. The remaining three alternatives
are capping alternatives which would prevent people from coming in contact with contaminants and
would minimize the potential for erosion as well as percolation of water through the waste.
Capping the landfill will eliminate the risks associated with exposure to surface contaminants as well
as reduce the potential for leaching. In addition, these alternatives, alternatives two through four,
would also require institutional controls, including deed restrictions to prevent the installation of
13

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...., ~
drinking \\;I!~r \\~lIs \\ itl1in the lamlfilkd pllnil)n'of the site and future disturbance of the cap and
[111: !;lIIdfilkd materials. knee installation: a landtill gas management system. backfilling the
,-.-dimenl pomL Jnd abandonment of the drainage culvert system that currently underlies the landfill.
Alternative 1 - \'0 Action. lTnder this alternative. the potential human health and environmental
ri'iks associated with exposure to landfill contaminants would not be mitigated and would most likely
increase as site conditions deteriorate in the future.
Capital Costs:
Maintenance:
Present Net Worth:
Timeframe:
so
SO
SO
Not Applicable
.-\Iternatives 2a and 2b:
2a: 2-Foot Clay Barrier Layer/6-Inch Topsoil/Vegetative Layer
Under this alternative, the landfill and the east ditch would be capped with a 2-foot clay barrier.
layer overlain by a 6-inch topsoil layer. The impermeable clay layer beneath the topsoil would be
designed to minimize percolation of water through the waste material, and the vegetative layer
would ser:ve to control infiltration of precipitation by evapotranspiration and the removal of water by
runoff.
Capital Costs:
Maintenance:
Present Net Worth:
Timeframe:
$2,366,500
$249,400
$2,615,900
9 months
2b: 2-Foot Clay Barrier Layer/42-Inch Protective Layer
This alternative is similar to Alternative 2a, but with a 42-inch protective layer instead of a 6-inch
topsoil layer. The 42-inch protective layer would consist of a 12-inch sand drainage layer, a 24-
inch fill layer and a 6-inch topsoil layer placed over the clay barrier layer. Additionally, this
alternative would involve modifying the cap for the east ditch in order to retain its invert elevation
and existing stonnwater capacity. The primary purpose of the 42-inch layer is to protect the clay
barrier layer from frost damage. The 12-inch drainage layer would also promote lateral movement
of water to minimize infIltration into the clay barrier layer, and would also increase the water-
stOrage capacity of the protective layer. The cover system for the east ditch would consist of 3.5
foot protective layer underlain by a 60 mil Flexible Membrane Liner (FML). The purpose of the
FML in the east ditch is to replace the 2 feet of clay as the impermeable component of the barrier
layer.
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Capital Costs: 53.u37.600
Maintenance: 5187.500
Present Net Wonh: 5~.125 .100
Timeframe: 12 months
Alternatives :3a and 3b:
3a: 3-Foot Clay Barrier Layer with Flexible Membrane Liner (FML)/42-Inch Protective
La~t.'r.
This alt~rnative includes the same components as the previous alternatives. but differs in the cover
.:onstntction. This cover system would consist of a 3-foot compacted clay layer with FML, a 12-
in.:h sand drainage layer. a 24-inch clean fill layer, and a 6-topsoillayer. Similar to alternative 2b.
the east ditch would also require a modified cap construction. and would consist of a FML instead
of a 3 foOt clay layer as the impermeable layer overlain with 42 inches of frost protection.
Capital Costs: S5,350,300
Maintenance: $247,000
Present Net Worth: $5,597,300
Timeframe: 13 months
3b: 3-Foot Clay Barrier Layer with FML/12-Inch Drainage Layer/42-Inch Protective Layer.
This alternative contains the same components as the other alternatives, except that its cover system
consists of a 3-foot compacted clay/FML barrier layer, a 12-inch sand drainage layer, a 36-inch
.:kan fill layer. and a 6-inch topsoil layer. Under this alternative, the 12-inch clean fill layer in
alternative 3a would be increased by 12 inches for a total of 36 inches of clean fill. The additional
six inches of fill protects the drainage layer from frost and would prevent clogging of the drainage
lay~r. The east ditch would receive the modified cap construction described under Alternative 3a.
Capital Costs:
Maintenance:
Present Net Worth:
Timeframe:
$5,830,000
. 5265,600
56,095,600
13-15 months
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.. ,
.\Itl'rnatiH'" ~a and ~h:
~a: I-fuut clay barrier layer under a geosynthetic clay liner (GCL>. overlain with a nn.. and
tupp~d by a ~2-inch protective layer.
.-\Itcrnativc -ki ~onsists of a I-foot compacted clay layer overlain with a geosynthetic clay liner
(GCl). a bO mil tlexible membrane liner (FML) barrier layer. a L2-inch sand drainage layer with
gt:utcxtile filter fabric. a 2~-inch clean fiLL layer. and a 6-inch topsoil layer. The GCL cover system
rt:plal.:es replaces 2 of the 3 feet of compacted clay layer considered for Alternatives 3a and 3b. The
cxcavation of the east ditch would receive the modified cap construction described under
.-\lternatives 3a and 3b.
Capital Costs: $4.480.400
Maintenance: $211 ,000
Present Net Worth: $4.691.400
Timeframe: 12 months
~b: i-foot clay barrier layer under a GCL/geonet with geotextile fabric, FML/42-inch
protective layer.
Alternative 4b consists of a l-foot compacted clay overlain by a GCL/60 mil FML barrier layer, a
drainage layer consisting of geonet with geotextile filter fabric (replacing the 12-inch sand drainage
layer). a 36-inch clean fill layer, and a 6-inch topsoil layer. The GCL cover system replaces 2 of
the 3 feet of compacted clay considered for Alternatives 3a and 3b. The construction of cover
would be the same as Alternative 4a. Alternative 4b was developed to evaluate the effectiveness of
a geonet drainage layer and the pLacement of the drainage Layer below the frost Line. The goo net
drainage layer wouLd have a higher penneability than a sand drainage layer. Protection from frost
would prevent clogging of the drainage layer. The design and construction for the east ditch would
be the same as for alternative 3a, 3b and 4a.
Capital Costs: $4,653,150
Maintenance: $220,800
Present Net Worth: $4,873,950
Timeframe: 12 months
J. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
the relative perfonnance of each alternative is evaluated using the nine criteria, as specified in Title
-W of the Code of Federal ReguLations (40 CFR) Section 3oo.430(e) (9) (iii), as a basis for
comparison. An aLternative providing the best balance of considerations with respect to the nine
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,nl,'n;1 j, d-:!I.'nl1l1le:d (rl1l11 this e:\ aillation, The: following discussion e\'Jluat~s the r~l11~dial
,dk'nuli,.., ''''i);lr;lI~I~ lI~ing ~.'a(h \11' these nine \,:rit~ria.
TI1I'I:,h\1ld Criteria
Th\.' It 11111\1 i 11~ t '.1 \1 I: riteria. l)\erall protection of human health and the environment. and compliance
II It 11 .-\pplh:abk ur Rde:\Jm and Appropriate Requirements (ARARs) are criteria that must be met in
llnkr for ;In alt~rnati\e 10 be sdected.
1) O\'erall Protection of Human Health and Environment addresses whether a remedy would
pro\ ide ad~qllate protection 10 human health and the environment from exposure to contaminated
soils and sediments, and describes how risks posed through each pathway would be eliminated,
r~duced. or controlled under each alternative. At the J&L landfill, the major exposure pathways of
(om;~rn ar~ from ingestion. inhalation. and direct contact with the groundwater and contaminated
,edill1ents and soils,
The :--Jo A.:tion alternative does not satisfy the requirement for overall protection to human health or
the environment. Alternative 2a would only provide an intermediate level of protection because of
the effects of freezing and thawing on the clay barrier layer in the absence of a protective layer. .
This would result in a higher than predicted value for percolation through the clay barrier layer
using the Hydrologic Evaluation of Landfill Performance (HELP) model, Version 2, 1989 (See
Table I of this ROD). Alternatives 2b, 3a, 3b, 4a and 4b provide a much greater and more
complete degree of overall protection because these alternatives reduce cross-media contamination.
Since the quantity of percolation through the barrier layer is minimal for Alternatives 3a, 3b, 4a,
and 4b. the groundwater would be most protected against contaminant migration as compared to
other alternatives.
2) Compliance with ARARs (laws and regulations) addresses whether a remedy would meet all of
the applicable or relevant and appropriate requirements of other Federal and State environmental
statutes and/or provide grounds for invoking a waiver.
As alternative I. the No Action alternative, does not involve conducting any remedial action at the
site. no ARA,Rs analysis is necessary for Alternative 1. Alternatives 2a, 2b, 3a, 3b, 4a, and 4b are
expected to be in compliance with ARARs.
Primary Balancing Criteria
3) Long-telm Effectiveness and Permanence refers to magnitude of 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.
Alternati\e I provides no long-term effectiveness and would result in continuation of the elevated
risk levels that currently exist at the J&L site.
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TARLE 1
Summary 01 HELP Model Resultl
JLL' Site
Rochester HIIII, MlchlC.a
-        
  I!aiItinl Condition Alternative 11 Aheruliwe Zb Alternative ]a Ahel1l8live ]b Aile maiM 4a Allemative 4b
  inch/yur (%) inch/yur (%) Indt/JUr (~) Inch/year (%) hIdI/yelr (~) Inch/year (%) inch/year (%)
rrcciritatinn  29.76 (100) 29.76 (100) 19.76 (100) 29.76 (100) 29.76 (100) 19.76 (100) 29.76 (100)
Itunn"  1.08 (J.6J) 4.73 (15.90) 0.49 (1.65) 1.S2 (5.09) 1.36 (4.58) 1 j() (5.04) 0.10 (0.3S)
1'\.a,..,lran'I,ir atilln 1].6J (19.]8) 1400 (BO.6S) 26.07 (11.61) 21.29 (9168) 21.16 (91.U) 21.28 (91.66) 1S.04 (114.14)
1_lerallhain'le NA NA 0..55 (1.86) 0.7J (0.14) 0.90 (J.OI) 0.7J (1.45) 4.59 (15.0)
ren-nlalion IhmulJl barrier layer NA 0.9S2 (J.M). 2.434 (1.11) O.OU (0.08) 0.026 (0.09) 0.046 (0.15) 0.000 (0.00)
Volume 01 ~n-ofalion thmup barrier NA 511,000' 141,800 1.500 1,600 2,800 0
laye, (cu. 1t./~a')       
        I
rercolation thmuch uillinl day layer 4.986 (16.15) 0.941 (J.lW 2.428 (8.16) 0.017 (0.06) 0.G20 (0.01) 0.015 (0.05) 0.001 (0.002)
Volume of J'Cn-of.tinn IhroulJl ]02,800 57,000' 141,soo 1,100 1,200 900 50
niltin, cta, laye, ({11. h-lyear)       
_.. -       
.Ibc 111'1 r modcl docs notlah into accounllhe Increue In the day barricr', pennubillty'. 101188 elfcdl 01 freCllnland thawinlln thc ablcnee oil ,""cctift layer. Thill, Altcmati~ 2a could tlilert
a murh hiKhcr ~rrnlalion throulh thc blrrier Ind existlnl day laye, as compared to lhe model prcdlded .....
N' . Nllt arr1ir.hlc.

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All ,'I [11~ ~'(lIII;!il\l11~11! altem~Hi\e., redlh:e risks to exposure from ()ntaminated soils anu seuimcnts
I'> r~"ln~III\.~ :1':':\;',>'> ;1'1 \\\;'11 ;1'> b~ r\;'Ju(lng infiltration nf precipitation intO the \\aste. Good
II\aillt~nal\~:e. howevCf. wnulu he re4uired for long-tenn reliability. especially in the east ditch area.
A \\ :lI~r halanc~ study was conducted for the J&L site to evaluate the degree to which the potential
t'l1r ~'pl1!:.1Ininant migration would be reduced under each of the alternatives. The water balance
'll1d~ ....,timateu the J\erage surface water mnoff. evapotranspiration. lateral drainage. and
p\;'r~'(lI;!lilHl through the cover systems of each alternative. and compared these alternatives with
~"islil\g site conditions. The results of this study are shown in Table I.
The l110del that was used for the \\:ater balance study was the HELP model. Version 2. 1989. This
l1ludd. however. does nOt accurately model the percolation over time in cover systems having little
llr 110 protel:tive layer over the barrier layer, and instead assumes that the clay barrier layer's
penneabilit)' \,,'ould remain constant through the post-closure period. In actuality, however, the
effects of freezing and thawing could increase the penneability of the clay barrier layer, resulting in
a IIlIH:h larger volume of percolation through the cap than the model would predict. As a result.
Alternative ~a could expect a much higher volume of percolation through the clay barrier layer
,.:ompared to what the model predicted. The other alternatives evaluated all include a frost protection
layer: therefore. the model's predictions for those alternatives is more reliable.
As illustrated in Table I. Alternative 4b would result in the least amount of percolation through the
barrier layer as compared to Other alternatives.
.4) Reduction of Toxicity. Mobility. or Volume through Treatment evaluates treatment technology
perfonnance in the reduction of chemical tOxicity, mobility, or volume. This criterion addresses the
statUtory preference for selecting remedial actions which include, as a principal element, treatment
that pennanently and significantly reduces the volume, toxicity, or mobility of the hazardous
substances. pollutants. and contaminants.
U.S. EPA recognizes that for large landfills such as the J&L site, source control alternatives that
emphasize treatment to reduce the principal threat posed by the landfill contents may not be
applicable or appropriate. As only containment alternatives were evaluated for the landfill operable
unit at J&L. this remedy does not meet the criterion for reduction of toxicity, mobility, or volume
through treatment. and therefore this criterion is not evaluated as part of the detailed analysis of
altemati\ es.
:;) Short- Tenn Effectiveness refers to the speed with which the remedy would achieve protection,
as well as the remedy's potential to create adverse impacts on human health and the environment
during the construction and implementation period. This includes protection of the community from
any risk that would result from implementation of the proposed remedial action, protection of
workers from any threats that may be posed during remedial action and the effectiveness and
reliability of prOtective measures that would be taken, environmental impacts that could result from
the impkmentation of an alternative and a corresponding evaluation of available mitigation
llleJSUres. and the time requ:red to achieve remedial action objectives.
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. ,
..\11 \.lIntainll1cnt altcmati\'cs may r>os~ some shon-t~nn risks du~ to sit~-r~lat~d activities that (ould
- 1'-:;111.: n\li"e:: .1110 dust. in(rt:as~ local tranic. or disturb \\'ast~s. In g~neral. the conrainment
.dle::rnati\e::~ il1\ oh e minimal dis[Urbance of contaminants: however. the east ditch would require
\.'\\.';1\ atiun and grading activities involving porentially conraminated soils/sediments. The sediment
I)\lud and. if appropriate. the south ditch. will also require some excavation and grading activities,
In addition. (he:: on-sit~ drums containing RI waste will be consolidated on-site and therefore. will
.d~lI I..'rcatc:: a t~mporary disturbance while being consolidated beneath the existing clay cap.
ClIl1sl..'ic:ntious (onstruction and operating practices. and appropriate health and safety measures
would signiticantly reduce any potential risks to human health, as well as the off-site migration of
\.'ontaminants via the air or surface water pathways during remedial action. For all of the
altematives except Alternative I. measures would be taken to monitor and minimize any fugitive
dust emissions. and minimize erosion and potential impact to Ladd Drain. The time required to
I..'omplete cap installation was detennined by assuming an average placement rate of 2,000 cubic
yards/day for capping material and I acre/day for placement of GCL and FML. For all of the
altc:matives except Alternative I. maintenance of the operable unit would cease only at the discretion
of the Regional Administrator. However, a 3D-year time frame was used for cost estimation
purposes.
6) Implementability is the technical and administrative feasibility of a remedy, including the
availability of materials and services required to implement the remedy. There are no serious
barriers to the implementation of any of the containment alternatives, however, the following off-site
components of each containment alternative may require permission for access from adjacent'
landowners: I) The excavation material from the East Ditch which is on Sandfill No.2 property,
and 2) the installation of landfill gas monitoring probes south of the J&L site property and across
Hamlin Road.
7) Cost addresses the estimated capital and operation and maintenance costs, as well as present net
worth. See Cost Summary Table (Table 2, page 27 of this ROD).
8) State Acceptance indicates whether, based on its review of the RI/FS and Proposed Plan, the
state of Michigan concurs with, opposes, or has no comment on the preferred alternative.
The state of Michigan concurs with the selected remedy because it is expected to attain a standard of
perfonnance that is technically equivalent to that required under Michigan Act 64. However, the
State of Michigan disagrees with the U.S. EPA's determination that Michigan Act 64 is not an
ARAR. The State of Michigan believes that Michigan Act 64 is an ARAR (see the attached
Responsiveness Summary and letter of concurrence for further comments issued by MDNR).
9) Community Acceptance
Comments have been submitted by the Community, local officials, and PRPs. Comments and
responses to those comments are described in the attached Responsiveness Summary.
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I~. \"In: ~LI.LCTEI> RL\lEDY
1~.I."d lll1l1\1 ~\'ihiJeratir1Ih \,1 the relluiremelHs of CERCL\.. tile :--iCP ~IIHI halancing ()f the nine
,i'II-:ri:l. tl1-: L.S, EPA has Jetennined that Alternati\e -I-b is the most appropriate remedy for the
I,\:L ,ilL. The (omponents of the selected remedy ~lre described below.
AIILnl:lli\ e -I-h ((lnsisls of a I-foot compacted clay \J.yer o\erlain by a GCLbO mil FML barrier
I:l~Lr. ~l draina~e layer consisting of geonet with gcOtextile tilter fabric. a 36-inch clean till layer to
I'ru, ide lro" protection. and a b-inch topsoil layer. The GCL cover system replaces 2 01 the 3 feet
\11 l\\Illpactcd (lay considered for 'Alternative 3b. The clay must be compacted to a maximum
I'cnueability "I I x 10" emls with a minimum 01 c5 % clay sized (O.OO5mml particles. Alternative
..\.\1 was lle\ eloped to evaluate the effectiveness of a geonet drainage layer and the placement of the
drainage layer below the frost line. The geonet drainage layer would have a higher penneability
lhan a sand Jrainage layer. and protection from frost would prevent clogging of the drainage layer.
The east dit(h would also require a modified cap construction. including a FML impenneable layer.
The on-site Jrums containing Rl waste will be consolidated on-site. In addition. a proper slope will
he (onstructed and maintained so that all surface water runoff properly drains off the cap into a
(olk-.:tion system. or drainage ditches around the perimeter of the site.
Other components of lhe selected remedy include:
Removing existing vegetation from the landfill surface.
'"
Abandoning (plugging) the culverts, consolidating any contaminated soils/sediments beneath the
existing landfill cap and backfilling the sedimentation pond to grade with clean fill.
Consolidating any contaminated surface soils and sediments, including landfill waste, from the
east ditch to beneath the existing landfill cap.
'"
Cleaning and regrading the south ditch to retain existing stOnnwater capacity.
Regrading the surface of the site to promote runoff.
Preparing the existing surface in order to provide a foundation for the new cap.
Retrofitting existing monitOring wells.
Installing a passive gas management system.
Vegetative cover placement.
Fence installation.
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Il11pkm~nlalil1n (If inSlilutillnall.'ontrols tn limit land and gruund\\'at~r l1S~,
~h)nitnring plan for cap intt:grity and f~nct: inspc:=clion, and landtill gas migration,
Impkmt:nt long-tenn groundwater program to ensure dfectiveness of the remedial action,
L. STATt:TORY DETER\IINATIO:SS
Th~ sdc:=cted remedy is protective of human health and the environment. complies with Federal and
State requirements that are legally applicable or relevant and appropriate to the remedial action, and
is (:ost c:=ffective. This remedy utilizes permanent technologies to the maximum extent practicable.
Howc:=vc:=r. because treatment of the principal threats of the site was not found to be practicable, this
rt:medy doc:=s not satisfy the litatutory preference for remedies that reduce the toxicity, mobility, or
\ olumc:= through treatment as a principal element. The size of the landfill. as well as the nature and
lucation of wastes. precludes a remedy in which contaminants could be excavated and treated cost-
effectively.
Bc:=causc:= this remedy will result in hazardous substances remaining on site above health-based levels,
a review will be conducted within five years after commencement of the remedial action to ensure
that the remedy continues to provide adequate protection of human health and the environment.
1. Protection of Human Health and the Environment
Implemc:=ntation of the selected remedy will protect human health and the environment by reducing
thc:= risk of exposure to hazardous substances present in surface soils and reduce the potential for
contamination to migrate to groundwater at the site. Groundwater monitoring will be required to
provide early warning against the risk that the hazardous substances present in the leachate may
migrate and further contaminate the aquifer. Institutional controls will be imposed to restrict uses of
the site to prevent exposure to hazardous substances and contaminants in the soil and the leachate at
the site. No unacceptable shon-term risks will be caused by implementation of the remedy. The
-:ommunity and site workers may be exposed to dust and noise nuisances during construction of the
final cover. however mitigative measures will be taken during remedy construction activities to
minimize the impacts of construction upon the surrounding community and environments. Ambient
air monitoring will be conducted and appropriate safety measures will be taken if contaminants are
emiued.
2. Compliance with ARARs
The selected remedy for the J&L Landfill Superfund Site will comply with all identified, applicable,
or relevant and appropriate, Federal and more stringent State requirements (ARARs) unless waived
pursuant to Section 121 (d)(4)(B). The ARARs for the selected remedy are listed below:
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,'hl'l11il'al-Spl'l'ifk Rl'ljuirt'mt'nts
CI1':lnic;d--;pcL'ific ARARs regulate the release to the environment of .,pecdi..:: substances having
,-.:11:1111 c:11.:mical ,:haracteristics. Chemical-specific ARARs typically determine clean-up levels at a
,ilc \\ Ilen tile remedy requires treatment or removal of contaminated media. or involves a discharge
,1\ \.'l11~'~lInina[c:d l1r treated media. The selected remedy does not require contaminant treatment.
1'-:111\1\ al ur destnICtion. but rather relies on containment of wastes left in place. No chemical-
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R...""III\:-: Clll1'.:r.;!rjpl1 Jl1d R~(P\-:r\" _-\(r IRCRAI
Suhrirk D Part 2.+1
Suhrirk D (If RCRA go\~rns th~ disposal of solid waste. The Subtitle D regulations. promulgated
ill Ul't(lh~r. 1~~3. ar~ not appli(able to the site: but the U.S. EPA has determined that these
r-:gulations lI1a~ be rde\ant and appropriate. These include the following regulations:
.+U CFR Part 257: Requirements for classification of solid waste disposal facilities and practices
.+() CFR Part 258: Criteria for municipal solid waste landtills
Although this site is not a municipal solid waste landfill it does appear that some portion of the
Ial1dfilled waste at the J&L Landfill Site was similar to municipal solid waste; therefore, the criteria
~stablished by this requirement may be relevant and appropriate.
Th~ requirements of .+0 CFR Part 258 and associated guidance (guidance documents are not ARAR
but do constitute a factor to be considered) recommend the use of a barrier layer to prevent
infiltration consisting of two feet of clay or a technical equivalent which will provide equal or
greater protection against infiltration of the cover by precipitation.
Subtitle C
Subtitle C of RCRA is not applicable at the J&L Landfill Superfund Site. The effective date of the
regulations regarding the disposal of listed hazardous waste was November 19, 1980. Waste
disposed prior to that date is not considered as RCRA listed hazardous waste even if the waste in
question is similar to RCRA listed hazardous waste. Since the final disposal of waste at the J&L
Landtill Site took place before the effective date of the regulations, these requirements are not
applicable: however. a number of the requirements set forth in Part 264 regarding landfill closure
are relevant because they deal with landfill closure and are also appropriate to the specific conditions
at this particular site. These requirements include the regulations set out below:
~o CFR Part 261 Identification of hazardous waste
.+0 CFR 264.117 These requirements regulate post-closure care, including groundwater monitoring,
and future use of the property.
-\.0 CFR 264.228 These requirements regulate closure and post-closure care. These requirements
are relevant for closure and post-closure care of the landfill and the sediment pond.
.+0 CFR 264.310 These regulations set forth requirements for closure and post-closure care at
landfills. The landfill closure requirements set forth in this regulation include requirements that the
final cover must be designed and constructed to minimize the migration of liquids through the
landtill. In order to satisfy this requirement, the Office of RCRA has established a policy of
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. .
~l'\L\L\R Y ()F (lCESTIO:\S Y\D CO\l\IE:\TS RECEIYED DCR~(~ THE PCBLIC
\IEE1T\(~ ..\.'\D LS. EPA RESPO:\SES TO THESE CO'~IE~TS.
\\'rillcn ,:Ul11l11cJ1(S receiveu Juring the public comment period for the J&L landtill site have
\1-:en ~ull1l11arizcu helow tt)gether with U,S. EPA's response to these comments. Copies of
the tll'iginal kllef'> ;lre a\ailabk for re\ie\v in the information repositories and Administrative
ReCtH'd.
Comm~nts by the \lichigan Department of ~atural Resources (~ID:\"R)
COt-.lMENT: The first comment is a reiteration of MDNR's view that ~lichigan Act 64 is
an Applicable or Relevant and Appropriate Requirement (ARAR) ,
RESPONSE: The respective positions of MDNR and U.S. EPA on this question have
~dready been established in correspondence between the Agencies. panicularly in letters to
JI1(.I from Mr. William Bradford (MDNR) and Mr. James Mayka (U.S. EPA). U.S. EPA
has deteml ined that Act 64 is not an ARAR for this site. U. S. EP A has determined that Act
b-\. is not applicable as the wastes at the site were disposed prior to the effective date of the
Act's implementing regulations. The Act may be relevant as the remedial action will require
closure of a landfill at which wastes similar to listed RCRA wastes were disposed; however, .
U.S. EPA has determined that the specific requirement that three feet of clay be used for the
cover is not appropriate as the selected remedy will achieve equal or better performance in
preventing infiltration of precipitation by using a one foot layer of Geosynthetic Clay Liner
(GCL), The resulting decrease in overall thickness of the cover is a significant advantage as
the topography of the area presents engineering problems related to the height of the cover
system relative to the surrounding area. While U.S. EPA has determined that Act 64 is not
ARAR. the Agency does believe that the Act's requirements and, in panicular, the standard
of perfonllance it sets forth for reduction of infiltration of precipitation through the waste
l11ass are to be considered (TBC).
COMMENT: Michigan believes that only Alternative 3b meets the technical requirements of
Act 6-\.: however. MDNR will not object to the selection of Alternative 4b, provided that it
attains the performance standard for reduction of infiltration required by Act 64.
RESPONSE: The selected alternative 4b does attain a standard of performance equivalent to
that required under Act 64, Therefore, the MDNR has concurred with the selected remedy.
COMMENT: MDNR states that the proposed alternative must also address issues related to
the sediment pond, the east ditch, the current drums on-site, and surface water runoff.
RESPONSE: In order to address these concerns, the following activities will be included as
part of the remedy;
- Contaminated sediments from the sediment pond in the northwest comer of the site will be
removed before the sediment pond is filled to grade with clean fill. These sediments will
then be consolidated underneath the current landflll cap.
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- CUl1Iall1inateLi slIl1'ace soils in rht: t:ast ditch will bt: r~mo\'t:d bdor~ (,Jpping and
- \llhtti idat~o unoemeath tht: (u rrt:nt landtill cap.
- The drums curr~ntly on sit~ that are tilled with personal protective equipment (PPE) and
drilling (linings from on-site activities will be shredded and consolidated in a contiguous pan
\)f rhe landfill.
- Any drums on site filled with site-related liquid waste (i.e., decontamination water. etc.)
will be tested for analytical parameters and removed for proper off-site disposal unless the
~lIbstantive components of applicable groundwater discharge pennit exemptions are met.
- The proposed landfill cap will be designed such that surface runoff, as well as the water
that filters through the cap to the drainage layer above the GCL, is directed to one of the on-
~ite drainage ditches or other appropriate outlet.
COMMENT: The proposed plan description of U.S. EPA's preferred alternative did not
cl~arly state the order of placement of the GCL and flexible membrane Liner (FML).
RESPONSE: The order is clarified in the Record of Decision (ROD), which states that the
clay will be overlaid by the GCL followed by the FML.
COMMENT: Page 5 of the proposed plan did not include the one foot of clay over the
waste before the GCL and FML are laid down.
RESPONSE: This item is appropriately addressed in the ROD where the one foot of clay is
clearly included as pan of the remedy.
COMMENT: MDNR believes that the ARARs listed in the Focussed Feasibility Study
(FFS) are actual, not potential state ARARs for OUI.
RESPONSE: Until a Record of Decision is issued in which U.S. EPA selects a remedy, it is
appropriate to qualify all references to ARARs as "potential". This is because an ARAR is
triggered by on-site remedial action. As long as remedial actions are only considered as
possible alternatives or proposed alternatives, it is appropriate to refer to "potential" ARARs
which might be triggered if a particular remedial action alternative is selected. When the
Record of Decision is issued, U.S. EPA makes a fmal detennination regarding all ARARs
for the remedial action selected.
COMMENT: MDNR states that the fmal cover design needs to address waste dewatering
and groundwater remediation options because such future actions would cause substantial
settlement of the landfill cap. In addition, they recommend the use of a very low density
polyethylene as the material for the FML.
RESPONSE: These comments assume that a future operable unit (OU2) will dewater the
waste mass as pan of the remedy. This cannot be detennined at this time; however,
potential future actions will be considered during the remedial design phase. At that time,
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\)\I!\..'I1ti;t! flltllr~ ;!(til)nS tt) r~m~dy grollnlhvate:r \lill b~ cL1nsidcr~d as pan of the: d~sign
I'n ',-',-'"'' fur ,",ck,-.ting appropriate materials for the F\IL.
c< J\I\IE:'\T: \ID;-":R states that Act 6~ requires a groumhvate:r monitoring program.
RESP< ):\SE: AltlwlIgh Ad b~ is not an ARAR for this site:. a groundwater monitoring
j1wgrall1 is incllllkJ as pan of the sdected remedy.
Comments from Officials of the City of Rochester Hills.
I, Letter from the Mayor, Billie Ireland (with enclosure prepared by the City Engineer)
COMMENT: The Mayor would like to see the State and U.S. EPA work cooperatively and
address the area-\vide contamination problem. nor just J&L Landfill as an isolated issue. The
\Iayor"s kner also e:xpressed the City's desire to work in close cooperation with U.S. EPA
1m site remedy issues. The City expressed concerns regarding drainage and run-off from the
landfill and the potential for adverse impacts on the surrounding area. The future use of the
area. along with both physical and aesthetic impacts of remediation at J&L Landfill to the
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L~l!a t'WI11 [11~ Direl:tor l'f the Planning Depal1l11ent
CUM:\IENT: The Planning Commission shares the MDNR's sUPPOI1 of Alternative Jb.
The (;IP in 3b includes a thicker clay barrier and a l2-inch drainage layer.
RESPONSE: Th~ U.S. EPA believes that the selected remedy offers equal or greater
protel.:tion against intiitration as compared to Alternative 3b. and agrees with other comments
\\hi<.:h suppOI1 a reduction in the amount of clay required as a barrier layer.
COMMENT: The Planning Commission feels that sealing the landfill before the evaluation
and remediation of the groundwater contamination is premature and that the OU2 process
may show that groundwater contamination is running off into the Ladd Drain and the Clinton
River.
RESPONSE: As part of the selected remedy, U.S. EPA has included a groundwater
monitoring program which will serve as an indicator of the effectiveness of the cap and the
potential for any contaminants detected in groundwater to migrate off-site. Consistent with
Agency policy, U.S. EPA is trying to address the most immediate and greatest potential risks
tirst at the J&L site. The Remedial Investigation (RI) shows that present risks could result
from direct contact with contaminated material, while potential risk from groundwater is a
future risk based on a future residential scenario, where residents would be living on the
landfill and drinking well water from the contaminated shallow aquifer. Capping the landfill
will reduce present risks by reducing the potential for direct contact with contaminants, as
well as reduce the potential for infiltration and groundwater contamination and off-site
migration of contaminants while OU2 is being addressed. The selected remedy includes the
imposition of deed restrictions to prevent futUre use of the property that might adversely
affect the remedy. These restrictions will also act to prevent futUre risk by banning futUre
residential development or groundwater consumption at the site.
3.
Comments from Manager of Inspection Services
COMMENT: Jerome Eby, the Building Department's Manager of Inspection Services,
~xpresses concern about the impact of the proposed remedy on drainage patterns in the area.
, RESPONSE: As mentioned earlier, such concerns will be addressed during the Remedial
Design in accordance with ARARs and are expected to maintain current drainage patterns.
As far as the aquifer is concerned, OU2 will specifically address these concerns. U.S. EPA
has consistently expressed support for the idea of an area-wide groundwater stUdy.
4.
Comments from the City Engineer
COl'vIMENT: Jim Dietrick, City Engineer, was primarily concerned with run-off and
drainage issues. specifically regarding the surface run-off that sheet-flows west to east across
the landfill and the building west of the site.
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kESP( >:\SE: The: r~lIle:d! \\ ill he: Jesigned (0 e:nsure that. to the maximum extent
I)r~l(!ll'ahle. the surbce rUIl-off is Ilot significantly altered by the remedial action and that
~ldia(cllt property is Ilot adversely affected.
C():-'ll\lE~-':T: ~lr. Dietrick also 4uestioned the number of tnlcks that \\ill be hauling
Il1alc:riah ~ll1d \\hat thc:ir mute will be.
RESPONSE: This issue will be detennined during the remedial design phase. once the exact
\ ulume uf materials required for remediation can be more accurately estimated. At that
time. the public will be notitied of such actions.
As far as the legal concerns raised regarding compliance with local ordinances, CERCLA
and the NCP do not require U.S. EPA to obtain penn its for any actions conducted entirely
ull-site: however. the remedial action will comply with the substantive portions of any
applicable or relevant and appropriate requirements.
Comments by Private Citizens
COMMENT: Mr. Robert Green of Waterford, Michigan recommends that additional
measures for implementation be considered;
First of all. he recommends a plan that does not depend entirely upon containment as the
only means of addressing the contamination at the site, but may also include some non-
containment activities in conjunction with capping.
RESPONSE: In response. U.S. EPA is in the process of addressing OU2. which will
consider alternatives for groundwater. Also, alternatives considered for this site follow U.S.
EPA's presumptive remedy approach for landfills, which supports capping alternatives for
sites where there is a large volume of waste materials. contaminated at low levels. The
selected remedy is protective of human health and the environment. Anempting to excavate
and remove even portions of the J&L landfill would not be practicable or cost effective, and
no more dfective in reducing the risk.
COMMENT: Mr. Green expresses the concern for wildlife and the protection of dwindling
habitat.
RESPONSE: The concern for wildlife is very important, and was considered during the
remedy selection process. The selected remedy is designed to prevent the migration of site
contaminants by eliminating the potential for direct contact with contaminated materials and
substantially reducing the potential for infiltration, and the potential for contaminants to
migrate to the aquifer. and potentially to the river. In addition, it should also be pointed out
that while the selected remedy will have positive impacts for wildlife, the RI has not
indicated any adverse effects on wildlife or the Clinton River, and none are to be expected as
a result of the remedial action.
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l'( J\I\IE~T: \lr. Gr~~n r~(t)II1I11~nJs the installation and monitoring of p~nnanent
d\l\\ ngradicnt w~lIs.
RESPONSE: Installation of additional permanent down gradient monitoring wells is not
I1c(~ssary at this time: huwever. the groundwater monitoring program listed in the selected
r-=lI1~dy will address such concerns.
COl\1l\IENT: ~lr. Green recommended that a subsurface drainage collection system be
installed using both vertical and horizontal drilling techniques.
RESPONSE: A drainage collection system, as such, is not determined to be appropriate at
this site because the remedy includes a drainage layer to deal with water which infiltrates
through the cap layer. This water would be uncontaminated water which had infIltrated
through the clean materials of the upper layers of the landfill cover. As already indicated
above. drainage and runoff will be directed to the existing drainage system.
COMMENT: Mr. Green would like to see both groundwater and gas monitoring programs
as part of the remedy.
RESPONSE: Groundwater monitoring, as well as gas venting and appropriate air monitorin~
are included as part of the selected remedy.
COMMENT: A continuing effort for future reimbursement of any clean-up costs from any
and all PRPs associated with the site is recommended in light of recent U.S. Court of
Appeals decisions which allow for institutional liability of contaminated sites.
RESPONSE: U.S. EPA has a policy of "Enforcement First" and will pursue reimbursement
of all response costs from potentially responsible parties (PRPs), in addition to seeking
performance of both the remedial design and remedial actions by the PRPs.
COMMENT: Specific Deed Restrictions for the site have not been detailed and fully
disclosed for this remedy.
RESPONSE: In regard to deed restrictions, U.S. EPA will seek the imposition of
institutional controls which will be defined and specified in the Consent Decree (CD) or
Order for implementation of the selected remedy. The CD will be a public document, and
will be available for public comment prior to being entered by the COUnt The deed
restrictions will be recorded in the official chain of title and will be public documents. U.S.
EPA will seek deed restrictions that will protect the integrity of the remedial action and
prevent future land use that would endanger human health through ingestion or direct contact
with hazardous substances.
COMMENT: Ms. Ruth Haselhuhn. a local resident, has described unpleasant odors from
the area, as well as the groundwater being a possible drinking water source.
RESPONSE: The intention of addressing J&L landfill with the selected remedy for OUI,
and then OU2, is to alleviate some of these concerns. Gas venting and groundwater
6
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111l)l1il\1ril1~; pr\1grams ilh':l1rporat~d into the selected remedy will address these "pecific issues
1\:I~ltcd 1\1 J&L L1I1dfili. It is also important to note that arsenic found in the ground\l.'ater
hl'lh.:ath ].\:L Lmdfill was not found to have migrated oft'-site or downgradient of the site.
« )f\lMENT: ~lr. David Van Made suggests planting trees on the site and making it a
puhlic park. nr at least taking into accollnt other measures to beautify the site.
RESPONSE: Neither the vegetative cover nor the future uses pennitted at the site can be
allowed to interfere with the effectiveness of the cover as a barrier to prevent contaminant
l11igration, For example, tree roots could interfere with the integrity of the remedy by
damaging the cover. However. the aesthetic concern expressed about the appearance of the
site will be discussed with the PRP during negotiations. If U.S. EPA perfonns the remedy,
aesthetic concerns will be addressed by the Agency.
Comments by the Clinton River Watershed Council
COMMENT: The Council is concerned, as others mentioned above are. with diverting the
water around the landfill, as well as addressing OU2 as soon as possible,
RESPONSE: These concerns about the area-wide problem and groundwater, are being
considered partially in the selected remedy and as pan of OU2. As mentioned in the
Council's letter, "no one is using groundwater wells in this vicinity for drinking water supply
purposes and there are nOt detectable impacts on Clinton River water quality from
groundwater inflow or surface water conveyed via the Ladd Drain".
Comments by L TV Steel, the Potentially Responsible Party (PRP)
General Comments
COMMENT: L TV Steel asserts that the remedial action objectives (RAOs) were improperly
developed because risk from groundwater ingestion was considered in developing RAOs for
Ihis operable unit. L TV asserts that this operable unit is specific to the soil medium;
therefore. that U.S. EPA acted erroneously in considering any risks other than direct contact
with soils in developing RAOs for this operable unit.
RESPONSE: The U.S. EPA does not consider operable units for individual media apart from
the context of the site as a whole. The U.S. EPA looks at how the action selected for one
unit will affect other media at the same site, with the objective of achieving a consistent,
coordinated series of remedial actions. Developing RAOs for individual operable units
without considering the effect on other media could result in a significant increase in cost,
without sufficient gains in protectiveness to justify the additional cost. U.S. EPA's Risk
Assessment Guidance calls for preparation of a baseline risk assessment which considers all
risks presented at a site.
COMMENT: L TV states that the landfill does nOt have a bottom liner and that some waste
i~ below the groundwater table, therefore they do not believe it necessary to eliminate surface
water infiltration as part of the remedy. L TV Steel also believes that groundwater
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,-PI1(:llI1inatitH1 (L1ntriburion thwugh intiltration is not as signiticant as groundwater tlow. and
tllllS wnuld lik~ (0 addr~ss groundwat~r tkw,: and contribution to groundwater contamination
,c:paratd y.
RESPONSE: Groundwater contamination contribution through groundwater flow will be
;IJdr~ss~J s~parately during development of the proposed plan for OU2: however. there is
.,(ill (onrriburion and porential for further contribution of groundwater contamination through
intiltration. Thus. intiltration is a consideration of the selected remedy. Also, EP toxicity
(~sts perfonned as pan of the RI indicate that selenium, lead, and possibly some other heavy
metals have the potential to leach from unsaturated materials into the groundwater.
U.S. EPA will consider groundwater flow through the waste as part of the focused feasibility
study which will develop alternatives for the second operable unit.
COMMENT: L TV Steel believes that the risk assessment developed for the site
overestimates the total cancer risk and inappropriately uses groundwater as a media of
(oncern. and therefore does not agree with the RAOs established.
RESPONSE: U.S. EPA's risk assessment process is based on specific guidance developed
for this purpose, and it is a conservative process. J&L LandfLll's Risk Assessment complies
with approved U.S. EPA Risk Assessment guidance. -
COMMENT: LTV Steel describes what they believe to be inaccuracies in the RI
characterization of site contaminants.
RESPONSE: Some of these inaccuracies described are not pertinent to OUl, and are more
specific towards groundwater issues, which will be addressed in OUZo One specific
comment which. if accurate, would possibly affect the risk assessment in regard to PAHs is
the current slope factor for Benzo(a)pyrene (BaP). In July 1992 the slope factor of 5.8
(mg/kg-day)" as .described by LTV, was revised to 7.3+0 (mg/kg-day}l. The original slope
factor of 1.15 + 1 (mg/kg-day)'l applied in the RI is no longer valid; however, use of the
revised lower slope factor for BaP would not lower the calculated risks to a point at which
the conclusions of the risk assessment would be changed. The change would only decrease
the cancer risks estimated to result from exposure to carcinogenic PAHs by approximately
one third (37%). Therefore, the total reasonable maximum exposure (RME) cancer risk for
the on-site dirt bike rider decreased from 1.4 x 10.5 to 1.2 x 10.5 and the total RME cancer
risk for the off-site dirt bike rider decreased from 2.4 x 10.5 to 1. 7 x 10,5. Also, the total
RME cancer risk for the future resident was unchanged. Thus, the risk levels still fall within
U.S. EPA's point of departure of 1 x lQ-6.
COMMENT: L TV Steel disagrees with the type of cap recommended by the Agency
because they believe it represents a misapplication of ARARs. The recommended
alternative, 4b (4a in the FFS) is based 00 a technical equivalent of RCRA Subtitle C
(hazardous waste) cover system. As RCRA Subtitle C is not an ARAR for the J&L Landfill,
an FML is not required to meet RAOs and ARARs.
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kESP( ):\S E: The Agelh:Y sdected alternati\e ..J.D. based un the e\'aluation of the nine
..'\ ;liua!iull Io'l"iteria and the technical merit of -+b as opposed to a "misapplication of an
,':"RAR." :\Ithuligh the selected remedy meets a higher perfonnance k\cl than is legally
r-:411ired. alternative 4b was also found to be more cost effective proportionate to the degree
lIt' protectiveness it affords. compared to all the other alternatives evaluated. For instance,
.1\.\:l\rding to the HELP model. -+b allows 0.001 inch/year. or 453 gallons/year of percolation
tllfl\Ugh the barrier layer for the cost of an additional capital cost of S 535.500. LTV's
recommended cap allows I. 7 inches/year. or 770.908 gallons/year of percolation through the
barrier layer.
COMMENT: Related to the above comment. LTV Steel does not agree with the inclusion of
a Fi\lL as part of the selected remedy.
RESPONSE: The U.S. EPA has detennined that the FML provides a very cost effective
engineering component which greatly improves the design and protectiveness of the cover
system as a whole for this site.
COMMENT: L TV Steel disagrees with the thickness of frost protection for this cover
system. based on their knowledge of frost protection applications at Other landfills in the
area. L TV specifically compares 30 inch frost protection layers allegedly approved for G&H
Landfill and Rasmussen Landfill.
RESPONSE: The Record of Decision for G&H Landfill specifies 42 inches of frost
protection. Although the PRPs contested this during negotiations, the Agency required that
42 inches of frost protection be used at the G&H Landfill. At Rasmussen Landfill, 30 inches
of frost protection is sufficient because the site is in Livingston County where local frost
prOtection codes are at 30 inches. In Livingston County there are lower average frost depths
than for Oakland County, where the J&L site is located; therefore, any frost protection layer
less than 42-inches would not meet local codes and requirements for frost protection required
in Oakland County.
Proposed Plan and FFS Comments
COMMENT: LTV recognizes that the rules for Michigan Act 307 include a cleanup
criterion for soils that considers leaching of chemicals from soils into groundwater
(R299.5711)(2). However they do not believe that there is a comparison presented in the RI
or FFS of concentrations in groundwater. expected from leaching of soil contamination to
assess whether the estimated inf1.ltration of the proposed remedy will exceed a Type B
groundwater cleanup level. Regardless. LTV does not believe that the recommended remedy
includes groundwater remedial action objectives (RAOs), and that it is not appropriate nor
necessary to propose a remedy that addresses any groundwater exposure.
RESPONSE: Since Act 307 is an ARAR, the requirements of Act 307 should be met;
however. R299.5711(2) is Type B criteria, and J&L Landfill site is a Type C cleanup. The
aforementioned rule states that "to ensure that soils do not pose a threat of aquifer
contamination, the concentration of the hazardous substance in soil shall be below that which
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l)flIJl1I':~S a I..'l)nc~ntration in kachate that is ~qual" to Type B Cleanup Criteria for ingestion
llt groundwater. As indicated by L TV. no comparison between leachable concentrations in
,;round\,,,oater and Type B Cleanup Criteria was made: this is due to the fact that this site is a
T~ pe C deanup under the Act 307 rules. Therefore. this comment is not applicable to the
~t:kcted remedy ° Also. the cover design that prevents water infiltration to the greatest extent
\\ Lluld tle th~ preferred remedy.
COMMENT: L TV states that the results of the HELP model evaluation indicates that the
highest contribution of chemical migration to the groundwater is from the saturated waste
(below the watenable) and not the unsaturated waste. L TV also states that the remedial
measures which reduce contaminant migration from the unsaturated waste to the groundwater
will have only a small effect in reducing the overall contaminant migration to the
groundwater. Implementing LTV's alternative cover (see Table 3 of this document) would
reduce the unsaturated waste contribution to only 5 percent.
RESPONSE: The contaminant Migration Model presented as an Attachment to LTV's
I..'omments provides an acceptable equation and methodology for detennining the ratio of the
I..'ontaminant migration from the unsaturated waste to the total contaminant migration from the
unsaturated and saturated waste. However, LTV makes an unvalidated assumption that
chemical concentrations within the infiltrating water from the unsaturated zone and the
saturated zone would be the same. This assumption would only be true after the system
(landfill) has reached an "equilibrium" with respect to contribution of contaminants from
unsaturated and saturated waste. Typically as time progresses, the concentrations of
chemical constituents within the groundwater would decrease during a shoner time period
than the concentrations of constituents within the pore water of the unsaturated zone. This is
primarily due to the higher water volume flowing through the saturated waste material.
Therefore, field measurements (i.e., lysimeter) should be taken to validate the above
assumption before simplifying the equation to ratio of flows. Additionally, U. S. EP A's
selected remedy will reduce the unsaturated waste contribution to 0.042 percent, compared to
the 5 percent offered by LTV's alternative cap.
COMMENT: LTV describes a comparison against the evaluation criteria, and in general of
the U.S. EPA Proposed Plan Cap and Alternative Cap. LTV states that both the proposed
plan recommended cap and the LTV alternative cap would be protective in the long term for
human health and the environment.
RESPONSE: The proposed plan recommended cap would provide a greater degree of
environmental protection than the LTV alternative cap due to the reduction in inf1ltration
through the landfill.
The statement under the bullet for Reduction of Toxicity I Mobility or Volume through
Treatment that it (the proposed plan cap) would only have a small effect in reducing the
overall migration of contaminants is not substantiated as discussed in the previous response.
10
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Rt'I11t'dial In\t'.;ti2atiun Cnmmt'nts
Cl )~l~lE:\T: L TV .:ommc=nts that thc= sitc= was improperly charactc=rized during the RI and
Ii,\', llm:~ ~pel:itic .:ommc=ms summarizc=d as follows:
c.
The RI did not define site-specific contaminant fate and transport mechanisms
and the extent of contamination.
The RI did not differentiate between chemicals that can be solely attributed to
the site. as opposed to potential off-site sources.
Background sampling criteria were not met.
II
..
RESPONSE: The above specific comments were apparently summarized from a comment
kttc=r datc=d 9 April 1992 where specific issues are brought up. As such, specific responses
are contained in the following sections. However, no details regarding the first comment
(site-specific contaminant fate and transport) are given in either lener. There is reference to
a L TV comment letter dated 23 March 1994. but it is unknown whether this is the letter
contained in Attachment A with a different date.
9 April 1992 Letter
General RI Comments
COMMENT: L TV states that the overall approach followed in conducting the RI is the state
of the practice and generally confonns to the current regulations and guidance documents.
RESPONSE: U.S. EPA agrees with this comment.
COMMENT: L TV states that laboratory data sheets were not provided for samples from the
waste material. groundwater, surface water, surface soil and sediment. Also, that detection
limits for all the chemicals reported were not present in the summary tables.
RESPONSE: Due to the volume of data sheets generated during the RI, copies were not
incorporated into the RI Report. Copies were sent to U.S. EPA as they were received from
the Contract Laboratory Program (CLP) laboratory or the U.S. EPA Central Regional
Laboratory (CRL). All analytical raw data was validated by WESTON (U.S. EPA's
consultant) personnel in accordance with U.S. EPA validation guidelines. Generally, the
detection limits for all analytes were achieved as specified in the QAPP (January 1990). In
some cases. laboratory QA objectives were not met due to matrix interference or non-linear
instrument response. In these cases, the detection limit is reported on the data summary
tables and qualified with "UJ." For the purposes of the RI, these were considered non-
detections.
CO~IMENT: L TV believes that several background samples were selected for this
investigation that do not meet background sample criteria. It is stated that background media
sampling should meet one or more of the following summarized criteria:
11
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Table ~
Comparison of Various Lap ComponentS for the .J&L Landfill Cap
i  'I US EP A Recommenced C;l;J ;    I 
I Component I  :.-::v Altemauve L:lp i 
 I I FFS Altemau\'e 4b) I    i 
         I
! Toosoli II 6 in. I  6 in. I 
 Fill Thickness I  36 in. I  12 in.  
 Filter Fabric   (Composed with the Geonet) I Non-woven Geotextile  
 D1'a1nage Layer   Geonet    12 in. sand  
 Flex:bie Membrane Liner I  60 mli I  none  
 I (FMLl  I   '    
          I
 G~syntneuc Clay Lmer  ; 3entomat or eq:,nvaient   Bentomat or equivalent ! 
 (GCLJ i    I    
 Comoacted Clay   12 in.  I  12 in.  
 Cap ConstrUction Cost   SI.893,700    SI,104,800  
 Total Cost   $4,730.400    53,233,700  
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.
Ll)L'atipl1s "lll)uld be .;clected 'iuch that there is 110 potential impact from site
\,:lJntam II1~lIltS.
A minimum of three background samples should be colkcted.
Background samples should be of the same material type and depth range as
Ihe in\'esligative S~.lIllpieS \.'ollected from each media.
.
.
RESP< )!\SE: A 'ipccifiL' reference to these guidelines is not provided. The above
-,ulI1lnarized ,:riteria are not found or referenced in OSWER Directive 9355.3-01 "Guidance
fur Conducting Remedial Investigations and Feasibility Studies Under CERCLA." which was
Ihe ducument primarily used to develop the RI planning documents at the time. Investigative
'iample results were compared to available site-specitic background samples which were
limited due to the presence of other landfill sites surrounding the J&L Landfill site: as well
as Iypical concentrations in soils as published by the U.S. EPA and MDNR. The
..:umbination of these three sources yields an adequate database for comparison purposes.
Also. draft f\IDNR guidance such as "Verification of Soil Remediation" was not available at
Ihe time of the RI for J&L Landfill. Therefore. this guidance would nOt have been used at
the time of the RI and is not applicable.
However. considering the above mentioned criteria. the fact that monitoring wells GW -02S
and GW -02D are located on the J&L Landfill property in the southwest comer does not,
constitute deletion as suitable background evaluation points. Historical aerial photographs do
not indicate that filling activities occurred in this area and the boring logs for these wells do
not indicate that any waste materials were encountered. These facts, combined with the
eastward groundwater tlow direction, indicate they are suitable background evaluation points.
COMMENT: L TV also indicates that only two upgradient surface water samples were
collected (SW-05 and SW-09).
RESPONSE: Additional upgradient surface water sample locations were identified in the
immediate vicinity of the study area: however. the locations were dry even after significant
precipitation and could not be sampled.
Also. surface soil sample results were compared to soil samples collected from a background
soil boring located southwest of the site. It is acknowledged that the depth intervals and
geologic mawrials (sandy) of the background soil boring are different than the landfill cap
materials (predominantly clayey). However, it should be noted that the clayey landfill cap
materials are anomalous to the area. The natural surficial soils of the area are sandy loam
(see Subsection 3.5.2 of the RI report). The only other clayey surface soils within the study
area are cap materials for surrounding landfills which would not represent natural
background surticial soil conditions either. This being the case, a comparison of the
chemical composition of cap materials to natural background sandy soils is valid. It should
also be noted that a surface soil sample was also collected on the property south of J&L
across Hamlin Road as a background sample during the additional off-site characterization
work described in Appendix H. Comparing the analytical results from this sample indicates
the chemical composition is very similar to that of the background soil boring soil sample
results and that the on-site surface soils results are still high (especially inorganics) in
companson.
12
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("< )~I:\(E:-;T: L TV hdie:\e:s that the: RI repon does not e:valuate the data to identify \..hich
,:Ih.:micab are: 'iite rdate:d and that the waste characteristics of the surrounding landtills are
"imi lar t~) those at J&L Landtill. Additionally. the RI does not discuss potential contributions
,It' (hem iL'ab from other 'mrrounding landfills.
RESPONSE: (n n:sponse to the comment that the waste characteristics of the surrounding
landfills is similar to that of the J&L Landfill. the U.S. EPA does not believe this to be the
,:ase. The J&L Landfill is composed of 65 % slag materials. as stated in the RI Repon. The
'iurrOlmding landtills are tilled with general refuse with the exception of a small area within
Sandfill Landtill No.2 and some slag spread over the surface as described in Appendix H.
The chemical characteristics of the general refuse and slag materials are quite different. In
general volatiles and semivolatiles were found associated with general refuse and inorganics
were found associated with slag materials.
Spel:itic RI Comments
COMMENT: Pg 3. Groundwater. Eight chemicals were evaluated by LTV: Benzene,
trichloroethane. phenol. bis(2-ethylhexyl)phthalate. arsenic, cyanide. lead and iron. LTV's
evaluation indicates only arsenic to be directlv attributable to J&L Landfill. The other
chemicals were found at higher concentratIons in upgradient wells. Also, although .
monitoring well GW-05S is screened in the waste material and showed higher concentrations
of phenol and iron than in upgradient wells, LTV considers this monitoring well to be a
leachate well. L TV also believes that phenol and iron most likely have migrated to the site
from upgradient sources and are not site related.
RESPONSE: L TV has selected eight chemicals (benzene. trichloroethane. phenol, bis(2-
e:thylhexyl)phthalate. arsenic, cyanide. lead, and iron) for an evaluation of whether they are
site.related or not in groundwater. The selection criteria for these eight compounds in
rdation to the point that LTV is trying to make is unclear. It is stated in the RI report that
benzene and lead .were detected in both upgradient and downgradient wells and the placement
of the wells indicates that the potential sources of these contaminants may be an upgradient
source and/or general refuse within J&L. It is also acknowledged that lead was detected in
quality comrol flush water samples at concentrations up to 7 ""g/L. Because of this, there is
uncenainty as to whether low concentrations of lead detected in groundwater can be
attributed to the site. However, it must also be realized that lead is present within the
landfill waste materials and may have migrated to the water table. This conclusion is based
on the results of EP toxicity data for which lead was found to exceed maximum allowable
concentrations indicating the refuse materials in the landfill contain lead and can be
considered hazardous due to leachability.
There is apparently some confusion regarding trichloroethane. U.S. EPA takes this to mean
I, I, I-trichloroethane; however, this compound was not detected in either Round 1 or Round
2 groundwater sampling. If it is a typographical error and LTV meant trichloroethene, this
compound was only detected once in an upgradient well at a low concentration.
Phenol was detected in two downgradient well locations at concentrations ranging from 30 to
.HO ~giL compared to a single upgradient detection (during second round sampling) at 150
13
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,I:! L. T11\..' pr-:ll1i,-: It'r d-:kting ph-:npl ~IS ,I sitt: L'pntJminant s~~ms tt) h~ its lkt~ctit1n in
\\ \\' -II~S .I, L TV \..'t1l1sitkrs ~lW -U5S It1 h~ a kachat~ wcll rathc:r than a groundwater well.
Cii\\..'11 Ih-: (;IL't that landfill waste is present below t:1~ ilatural water 'table in direct contact
\\ itl1 ul1d~rlying aquifer materials (sand) without henefit of a low-penneability liner, a case
1.;ln llc made to L'onsider this a water table \vell. Howe\'er. if we delete the phenol results of
\\\\'-I))S \\c arc ..,till left with the fact that phenol was dc:tected in downgradient deep well
\\W-(l)O during bt1th f\lllnds at comparable concentrations. \\'hereas phenol was detected in
;111 lIpgradi~nt well only during the second round of sampling.
The L'umpound bis( 2-ethylhexyl)phthalate was detected in upgradient monitOring wells at
,imilar nr greater concentrations than downgradient wells. This compound is also a common
laboratory contaminant. However. this compound can be considered site-related and is a
L'hemical contaminant of potential concern (Risk Assessment) due to its presence at high
\..'(HKentrations in waste materials and the potential for it to migrate to groundwater.
Similarly. L'yanide was only detected in upgradient wells but can still be considered a site
\..'ontaminant due to its presence in other media.
Although iron is not a chemical of potential concern. the groundwater analytical results
dearly indicate that iron concentrations in groundwater are greater in downgradient wells
compared to upgradient wells. This is not surprising given slag materials and EAF dust (not,
found in upgradient landfills) are composed of iron oxide at greater than 27% by weight
(Table 2-1 of the RI).
The upcoming additional groundwater monitoring at the site may help to resolve some of the
groundwater issues highlighted in this section. It should also be noted that L TV split
groundwater samples in the field with U.S. EPA during the RI. The results of these samples
have not been made available to U.S. EPA by the PRPs for review and comparison.
COMMENT: It is stated in the RI Report (Subsection 6.2.2) that the results of surface water
sampling indicate, that. in general. volatiles. semivolatiles. and pesticides were only detected
at very low levels in investigative samples. It is also stated that while inorganics were
detected at high levels. the highest levels were detected in upgradient sample SW-09.
RESPONSE: As discussed in response to groundwater issues above. a detennination as to
whether a specific chemical is site related or not, cannot be made solely on the basis of its
detection in a specific media; but rather. the detennination should take into account all media
in which the chemical was detected on-site.
COMMENT: It is stated that the concentrations of semivolatiles detected in background
samples were higher than in site sediment samples; therefore, contributions from off-site
sources are likely.
RESPONSE: The RI Report states that volatiles. semivolatiles. pesticides, and inorganics
were only detected at low levels in investigative sediment samples or at comparable levels to
that of upgradient samples.
14
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I{i~k ,\~w~..mt'nt Cummt'nts
1 :\Dril 199~ Letter
\'aliditv lit' Risk Ass~ssl11~nt
COMt\.lENT: L TV bdi~v~s that the data indicates there is a strong likelihood that many
-:h~l11icals found at the site are from other sources or are a background condition.
Furth~ntlore. the risk assessment must include a discussion of the contribution of
"additional" risk from the site above the background conditions, which include the artificial
hackground levels contributed by non-site related sources.
RESPONSE: The data presented in the RI and site history indicate that the inorganics
associated with the slag materials pose potential environmental problems and health risks that
are nOt equivalent to those posed by surrounding landfills. Therefore, evaluation of
"additional" risk from the site above surrounding conditions is not necessary.
COMMENT: L TV states that there is a 2 to 20 fold overestimation of the total cancer risk
due to the uncertainty associated with the use of inappropriate slope factors or incorrect
quantification of the dentlal absorption of a few of the chemicals considered in the
calculation. In addition, calculation mistakes for averaging time, exposure duration, and
average exposure frequency were also identified by LTV.
RESPONSE: There were no inappropriate cancer slope factors used or incorrect
quantification of dermal absorption. Typographical errors in tables of Section 7 regarding
averaging time, exposure durations, and average exposure frequency did not affect the
calculation of risks.
COMMENTS: LTV states that the groundwater pathway is a hypothetical pathway, and it is
not likely that greundwater would be used directly as a source of residential drinking water.
In addition. the use of the concentrations of contaminants in the on-site monitoring wells
leads to an unrealistic over-estimation of the levels of contaminants in downgradient
residential wells.
RESPONSE: U.S. EPA agrees that the groundwater exposure pathway is a hypothetical
scenario. However, it was conservatively evaluated in accordance with regional U.S. EPA
guidance.
COMMENT: The risk was calculated by summing the risks across all pathways. To assume
that one person will be exposed to maximum concentrations through all pathways is
inappropriate and not consistent with agency guidance.
RESPONSE: It is not unreasonable, and is consistent with U.S. EPA guidance, to assume
that one receptor may be exposed to the reasonable maximum concentration of chemicals in
each environmental mediUm. It is important to recognize that the reasonable maximum
concentration represents the high end of what is expected to be the average concentration for
the site. General practice for risk assessments examined cumulative risk, and therefore the
15
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11'1-. \\ ;1' ~:d,-llIat~d 11\ "lImmillg Ihe risks ,1(rl1SS all palhways ill accl1rd:lIlcc wilh Agcncy
:':lIid;IIk'~ ,It Ihal lil11~.
l} :\PRIL IlJ91 LETTER
('omments un Section 7 (Risk Assessment)
The"~ \..'l1I11IIl\~nts wac addresscd in the responses to comments containcd in the 1 April 1992
k!t~r r~garding the validity of the risk assessment.
C()~l;.,lE;-J'T L TV believes that data presentation was poor. that tables were unclear and
difficull !O interpret. Specifically. the tables did not indicate which slope factor was used for
l1iL'kd. ur which forms of chromium was analyzed.
RESPONSE: As stated on pg 7-109. paragraph 2. though total chromium was detennined at
the site. 10 percent was assumed to be Cr"'o and 90 percent assumed to be CrT3.
Also. Table 7-2~ indicates that the cancer slope factor for nickel refinery dust was used.
The assumed distribution of Cr",3 and Cr"'o is stated on pg 7-109. paragraph 2.
COMMENT: L TV would like to see an explanation for the statistical methodology applied
to daive the exposure concentrations for average and the reasonable maximum scenario
cases. Also. they would like described how the "non-detect" results were treated in the
process of calculation to estimate the exposure concentrations. Additionally, L TV requests a
copy of Sample Quantitation Limits (SQLs) in order to complete their review.
RESPONSE: As described on pg 7-49, Subsection 7.1.3, and in accordance with U.S. EPA
guidance. nondetects were included in the calculations at one-half of the sample quantitation
limil (SQL) except for cases of unusually high SQL which resulted in elimination of the
value from the analysis. SQLs can be obtained from the laboratory data packages.
Specific Risk Assessment Comments
COt-.lMENT: In section 7-1: paragraph 3: sentence 3 of the RL the furure contaminant
concentrations were based on current contaminant levels assuming that present concentrations
will persist in the future. The assumption ignores the rates of chemical and physiological
degradations and this may result in an over-estimation of exposure point concentrations for
all media exposures. The risk estimations obtained in the risk assessment are not appropriate
to be presented as future risks.
RESPONSE: An assumption was made in the risk assessment that current contaminant
concentrations will persist in the future. This is a conservative simplifying assumption that
may arguably lead to overestimation of future contaminant concentrations for those
contaminants that are subject to degradation (i.e., organic contaminants). This assumption
does not lead to any significant overestimation of the future concentration of inorganic
contaminants. Since inorganic contaminants in soils and sediments appear to be driving the
remedy selection. modeling of future organic contaminant concentrations appear to be
unnecessary.
16
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C()~l~lE~T: pg -:. -:--l~: Tabk 7-:-. th~ rang~s ofd~t~ct~d conc~mra[ions for
l1~nwtllll\ralHh~n~ \\~r~ shown as bl)-69. Is it coincid~mal that both samples had th~
;I.kmil.'al ..:c,n\.'~ntra[ions.)
RESPUNSE: Surfac~ soil sampl~s 5510 and 55 l~ both had detections of
h~nzo( 1\ )t1uoramh~n~ of 69 ,ug/kg.
COMMENT: pg 7.7-18: Table 7-3. LTV requests an explanation of how the calculation
m~thod was not consistent in each table.
RESPONSE: The average exposure concentration was the geometric mean of the data. The
maximum exposure concentration was the minimum of the following two quantities: the
maximum detected concentration and the upper 95 percent confidence limit on the arithmetic
mean of the data. Nondetects were included at one-half of the sample quantitation limit.
The calculation method was consistent in all tables.
COMMENT: pg 7.7-18: Table 7-3, LTV asks how the average and maximum exposure
-:oncemrations for beryllium was calculated.
RESPONSE: The average and maximum exposure concentrations for beryllium are
incorrectly listed as 0.58 and 0.57, respectively. The correct values should be 0.49 and
0.57. respectively. The corrected value for the average exposure concentrations will not
affect the conclusions of the risk assessment.
COMMENT: pg 8, 7-18: Table 7-3, chromium was not defined in this table or others, as
trivalent. hexavalent or as total chromium.
RESPONSE: Total chrumium levels were determined during RI investigations.
COMMENT: pg. 8, 7-19: Table 7-3, for mercury the frequency of detection was reported
as 1/12 in the table and average and maximum exposure concentrations of 0.1 and 0.09 were
listed. therefore L TV requests an explanation of this.
RESPONSE: The average and maximum exposure concentrations for mercury are listed as
0.1 and 0.09, respectively. The correct values should be 0.07 and 0.09, respectively. The
corrected value for the average exposure concentration will not affect the conclusions of the
risk assessment.
COMMENT: pg 8, 7-31: I: 2, L TV states that the elimination criteria used to exclude some
chemicals are not appropriate, as it should be based on the concentration-toxicity screening
applied to specific media at the site.
RESPONSE: Screening of chemicals in the risk assessment was performed in accordance
with U.S. EPA's Risk Assessment Guidance for Superfund (1989).
COMMENT: pg 8. 7-57:3: I. LTV believes that the evaluation of lead is outdated.
17
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RESP( J:\SE: 111 [!1~ ~Ih)ell(~ III' l".S. EPA health ,:ritcria fl)r kad. a ljualitatiw risk
," ;!IlI;1l il 111 \\ ;IS prc:-,c:nte:d. :\0 I.:urrent nr future: l1n-site residential expo)ure scenarios wae
....' \ ~d lIa[~d ill the ri sl\. ass~ssl1lent. and thcrefl)re. use nf U. S. EP A' s kad uptake biokinetic
II \lll.k I (L LBK) \\ as inappropriate. The L u 13K lIlodei might have been appropriate for the
i"lIture hYIK)thetical off-site residential exposure scenario. However. the concentrations of
11..';ld ill s~dil11ents that may move off site and be deposited in a background were low and not
\ It l.'l\l1Ccr1l.
COMMENT: pg 8. 7-58:~: I. LTV believes that bioconcentration factor (RCF) or log BCF
il1fonnation would be useful to characterize chemicals in the environment. Also. there is no
rate: and t ranspon i nfonnation included in section 7.2. 1.2 in relation to the rate of
hil1degrauation. \ arious half lives in air. water and soil for each chemical of concern. This
IHissing infonnation. L TV states. contributes significantly to assess the fate of chemicals in
the environment.
RESPONSE: Since environmental modeling was not within the scope of the RI. future risks
presented in the risk assessment were based on measured contaminant levels. Estimated rates
\)1' biodegradation and chemical degradation for the organic contaminants are not needed since
inorganic contaminants appear to be driving the remedy selection.
COMMENT: pg 8. 7-60: Table 7-11, LTV notes some minor corrections of molecular
weights for benzene at 78.11. methylene chloride at 84.93, and trichloroethene at 131.40.
Also. when octanol/water partition coefficient and vapor pressure are provided. temperatures
measured must be specified.
RESPONSE: The minor corrections of molecular weights are noted. Temperature-
dependent physical properties. such as vapor pressure and octanol/water partition coefficient,
were obtained from the literature for a temperature of 200C, or as close to 20°C as possible.
COMMENT: pg 9. 7-70: I: 1. LTV does not believe that the conceptual model contains a
description of the rationale for assessing exposure pathways for J&L and partitioning the site-
related risks. especially considering it is located adjacent to other landfills.
RESPONSE: An evaluation of the conceptual exposure model and the rationale used in
selecting exposure pathways for further analysis is presented on pg 7-70 to 7-77.
COMMENT: pg 9, 7-72:4 (Subsection 7.2.2.2), LTV does not believe that the scenario for
exposure to drinking water from the upper 25 ft is appropriate for the site, because it is
unlikely that the groundv.'ater at the site would be used directly as a source of residential
drinking water.
RESPONSE: While the State of Michigan may impose restrictions on the use of aquifers
\\' ithin 25 feet of ground surface. assumptions regarding the use of this aquifer are justified
since the well survey conducted in the vicinity of the site identified several wells 25 feet or
less in depth.
18
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l'()~I~IE~T: pg 4. 7-73:2: I. LTV \\LHIId lik~ an explanation for the rationak for !h~
11l11is~iLIII Llf grl1unJwatc:r modding.
RESPONSE: Th~ risk ass~ssm~nt states that the groundwater ~xposure pathway is a
lIypL1theti~al future exposure sc~nario and that groundwater modeling of contaminant
Illigra!ioll might pro\id~ more realistic ~stimates of future groundwater concentrations.
HOWe\ cr. groundwater madding was not a pan of the scope of the RI. In addition.
gll idance from C. S. EP A Region V indicates that the"... the contaminant concentration used
(0 calculate the ground water reasonable maximum exposure should be the concentration of
(lie ~ontaminant at the center of the contaminant plume" (Memorandum from: 10hn Kelly,
To: Remedial and Enforcement Response Branch RPMs and Supervisors, Subject: Future
Residential Land Use Ground Water Exposure Point Concentrations for the Baseline Risk
Assessment. 10 May 1991).
COMMENT: pg 9.7-78:2:1. Define the "off-site" locations in the text.
RESPONSE: The off-site locations refer to soils from adjacent landfills that were sampled,
analyzed. and presented in Table 7-3.
COMMENT: pg 9, 7-79; Table 7-16, LTV makes several comments on the calculations
used for soil ingestion, dermal contact and dust inhalation.
RESPONSE: The fraction ingested for the average scenario, in the absence of U.S. EPA
guidance. is based upon professional judgment. The averaging times listed in Table 7-16 are
incorrect. The averaging times should be 3,650 days (365 days/year x 10 years) for
noncarcinogenic risk calculations. The correct averaging times were used for the risk
calculations (Appendix G) so the typographical errors in this table had no effect on risks
calculated for the site. The average exposure frequency, in the absence of U.S. EPA
guidance. is based on professional judgment.
Adjustment of chemical intake for the soil matrix effect is not specified in U.S. EPA's Risk
Assessment Guidance for Superfund (1989), (RAGS).
Adjustment of chemical intake via inhalation of particulates for a deposition factor is not
specified in RAGS.
COMMENT: pg 10, 7-80; Table 7-17, LTV does not believe that the sediment dermal
contact adherence factor for average and maximum scenario are realistic. .
RESPONSE: The adherence factors used are based on conservative values recommended in
RAGS. The fraction of dermal exposure to contaminated soils was conservatively assumed
to be 1.0 as recommended in RAGS.
COMMENT: pg 11, 7-82:4: 1, LTV states that the estimation of fugitive dust release is not
accurate.
19
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RESP( J:\SE: II i\ I\.'Cl1gniLl..'d Ihat the: "qlwiol1 used to I..'slill1ate Ih~ air ,-'l1l1c~mratil)n of
IlI~ili\1..' dll\1 rl..'ka~l..'s ;l~s(),-'ialcd with \e:hiclllar traffic may ,-'l)ntain a significant d~gree of
1IIh:I..'I1;lil1i:.. .IS describ~d in Slloscction "7.~..+ (Unc~r1ainty .-\nalysis). .-\n equation developed
11\ L.S. EP.-\ fl)r \c:hicks \Iiith at least four wheels was used in the absence of a similar
,:qll;llilll1 I,)r 1\\ ()-\vhceled \chicles.
C()~lt\lE~~T: pg 11. l-x7: Table 7-IS. LTV comments on several of the exposure
Irc.'qul..'l1cic:s used for ingestion of drinking water. denTIal contact by bathing. and inhalation
11: sho\\-ering,
RESPONSE: U.S. EPA guidance does not indicate that the average exposure frequency for
a residential scenario is 275 days/year. Guidance from U.S. EPA. Region VI indicates 350
days/yc:ar for the average residential c:xposure frequency (Memorandum From: John
Rauscher. Ph.D.. Toxicologist. To: Donald Williams. Section Chief. Subject: Central
T c.'lIdenc: and RME Exposure Parameters. 18 August 1992). This value was used in the risk
assessment.
Evaluating residential exposure to groundwater via bathing and showering is a. conservative
approach that is not unrealistic. Bathing evaluated only the dermal contact exposure route,
and was chosen to be representative of all dermal contact with groundwater (resulting from
activities such as hand washing, household chores, car washing, gardening, and showering).
Showering evaluated on:'J the inhalation exposure route, and was chosen to be representative
of all inhalation exposure to groundwater (resulting from activities such as cooking,
Jishwashing, laundering, and bathing).
COMMENT: pg II. 7-90: Table 7-19. LTV believes that the parameters used for the
surface water pathway require clarification and that the exposure frequency of 365
(days/year) is not valid for surface water/sediment exposure pathway for adults.
RESPONSE: The exposure frequencies listed in Table 7-19 are incorrect. The correct
values are 2.+5 days/year for the average and maximum exposure scenarios. The correct
c:xposure frequencies were used for the risk calculations (Appendix G) so the typographical
arors ill this table had no effect on the risks calculated for the site.
The exposure duration of 10 years is correct. The averaging time should be 3,650 days.
The correct averaging times were used in the risk calculations (Appendix G) so the
typographic errors in this table had no effect on the risks calculated for the site.
Based on site surveillance. the din-bike rider was assumed to be a pre-teen to young adult
with hands. arms. and legs exposed to surface water. The adult resident was assumed to
have hands and forearms exposed to surface water.
COM1vlENT: pg 12. 7: 102: Table 7-2'+. LTV states that the slope factors used for BaP by
inhalation and ingestion routes are not correct.
RESPONSE: The current oral cancer slope factor for benzo(a)pyrene is 7.3E+0 (mg/kg-
day)'l. as opposed to the value of 1.15E+ 1 (mg/kg-dayyl used in the risk assessment. This
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..11;lI1gt: \\ ould dt:l..:r~ast: th~ (;lIK~r risks t:'itimjt~d to r~sult from ~xposur~ to c.lfcinog~nic
p\lIYl..:y(lil: aromatic hydrocarbons (PARs) by approximatdy ont~-third 137 percent). The
,k(rt:ase w0uld be most nOtable in the estimated risks resulting from dermal exposure to soil
,1Ild st:diment. \,,'here carcinogenic PARs contributed vinually all of the risk. However. use
\\1" th~ new lower slope factor for benzola)pyrene would not lower the calculated risks from
\ .ther lI\~dia and would not d1ange the conclusions of the risk assessment.
COl\lMENT: pg 12.7-105: Table 7-15. The RiD for thallium (in soluble salts) of 2E-2
Img.' kg/d) is available on the Integrated Risk Information System (IRIS) and should be used
il1st~ad of 7E-5 from Health Effects Assessment Tables (HEAST).
RESPONSE: The current oral RID for thallium (sulfate) is 8E-05 mg/kg-day, as opposed to
the value of 7E-05 mg/kg-day used in the risk assessment. This change would lower the
l10ncancer Health Quotient (HQ) for thallium. However. since this metal did not contribute
~igniticantly to site risks in the risk assessment. a decrease in this HQ would also be
insigniticant with respect to overall site risks.
COMMENT: pg 12. 7-118: 1 :2. LTV believes that the use of the slope factor derived from
the dennal absorption of drinking water leads to an overestimation of risk as stated in the
text. Without the lifetime cancer risk of arsenic in drinking water, the total futUre cancer
risk by all other organics is 4.3E-6.
RESPONSE: The oral cancer slope factor for arsenic is based on the stUdy of Tseng et al.
(1977) which reponed an increased incidence of skin cancers in humans that were exposed to
arsenic in drinking water via ingestion.
COMMENT: pg 12,7-118:3:1, LTV states that the risk associated with dermal contact and
ingestion of soil will be reduced when the slope factor for BaP is corrected to 5.8
Img/kg/dr'. and the ingestion of arsenic through groundwater is adjusted or eliminated.
RESPONSE: The revised risk estimates associated with the revised cancer slope factor for
benzo(a)pyrene were discussed above for comment 7: 102:Table 7-24. No adjustment in the
risk posed by arsenic in groundwater is appropriate.
COMMENT: pg 13, 7-118:6:2, LTV asks U.S. EPA to describe why the total adult hazard
indices for all pathways combined were 6.7E-l for the RME and 1.6E+0 for RAE.
RESPONSE: This comment identifies a typographical error. The corrected sentence is:
"The total adult hazard indices for all pathways combined range from 6.7E-l to 1.6E+0 for
the RAE and RME, respectively, and the total child hazard indices range from 1. 7E+0 to
~.2E+O for the RAE and RME. respectively."
COMMENT: pg 13,7-119:1:1, LTV states that the Hazard Index values for RME exceeded
I .0 for both the adult and child because drinking water ingestion included manganese and
barium. which should have been excluded from the chemicals of concern list. These two
metals are insoluble in water and have low intrinsic toxicities.
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\'il.I---:1: The: C.S. EPA has not c:\aluate:d soluble: salts of nkkd as a class of compounds for
pl11e:l1!ial human (arcinogenicity. Which fonn of nick~1 compound was use:d for the SF \'alue
lisle:d in the Table G-2:
Thallium: Describe: the fonn of thallium for the listed RtD.
The: labks G-2 and G-3 list the RtDs without identifying the exposure routes. Not all the
RtDs are identical for both oral and inhalation exposures.
RESPONSE: No RtDs or cancer slope factors are presented for cobalt as none has been
c:stablished by U.S. EPA.
Lead: the concentration-toxicity screening included a semiquantitative evaluation of lead by
using U.S. EPA's previously withdrawn RID for lead. This resulted in lead being included
as a chemical of potential concern for the site. However, the withdrawn RID was not used
in the calculation of site risks: exposure to lead was evaluated in a qualitative fashion.
Nickel: For the purpose of a conservative initial concentration-toxicity screening, it was
assumed that nickel was present in a carcinogenic fonn. The cancer slope factor for nickel
rdinery dust was used.
Thallium: The RID for thallium sulfate was used.
For the purposes of a conservative concentration-toxicity screening, health criteria for the
oral exposure route were used as a default. However, for chemicals that are known to be of
particular concern via inhalation exposure (e.g., Cr+6), inhalation health criteria were
included in the concentration-toxicity screening.
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I' >II, ," I"~, \\ I,,: 11\.' \ I.'r 1'\ 1~~ihk, the dl.''ii~n 'itandards in Final CI)\erS 1)(1 Hazardous \Vaste: Landfills
,tilt! :-'lIrLl..1.' 11111'IIlIndlll':lIh. EP.-\ 5j()-S\\'SLJ-()..I.7. July. !LJXY. a RCRA technical guidance document
1\11' till.' dl.'~i~n lIt' landfill Cl1vcrs. This ~uidance te4llirts the use: of a tlexible membrane liner
IF\IL\: 11\1\\ \.'\ \.'r. guidance dl1cuments are not promulgated standards: therefore. such guidance is
111 'I ,-\R.-\R ullder the standards l)f Section 121 of CERCLA. Such guidance is. however. a factor
,\ l1i..'h i~ "\1\ he' -':1.)(lsilkred" in the sekction of a remedy. The selected remedy will not follow the
rl.'qllircl11e'nts fL)r a RCRA Subtitle C cover given in the guidance document cited: however. the
~I.'b:tcd remedy "..ill employ a Fi\lL. as well as geosynthetic and natural day layers. and a drainage
I~l\er ut' t!cond and !!eotextik fabric. The reason for this is explained below.
. ~ ~
()c..'lIpational Satetv and Health Act
Regulations promulgated under the Occupational Safety and Health Act. codified at 29 CFR 1910,
regulate the safety and health of workers. These requirements are applicable and will protect the
health and safety of workers at the site implementing the selected response action.
STATE ARARs
i\lichigan Environmental Protection Act 127 of 1970
This Act prohibits any action at the site which pollutes, impairs, or destroys the State's natural
resources. This Act is applicable or relevant and appropriate to the remedial action at this site. The
remedial action must be carried out in such a fashion as to avoid any pollution, impainnent or
destruction of the State's natural resources.
Michi£!an Occupational Safety and Health Act 154 of 1974
This al.:t provides for regulation to protect the safety and health of workers. This requirement is
applicable or relevant and appropriate for the response action at this site.
:--lichi!!an Environmental Response Act 307 of 1982. as amended and Parts 6 and 7 of the associated
rules
The Michigan Environmental Response Act 307 (Act 307) provides for the identification, risk
assessment, and evaluation of contaminated sites within the State; therefore, Act 307 is applicable,
or relevant and appropriate, to the J&L Landfill Superfund Site. The U.S. EPA considers the
substantive portions of Parts 6 and 7 of the Act 307 rules to be ARARs for the remedial action at
this site. The requirements of the act provide that remedial actions shall be protective of human
health. safety, the environment, and the natural resources of the State. To achieve the standard of
protectiveness. Act 307 requires that a remedial action shall achieve a degree of cleanup identified
by the Act as either Type A (cleanup to background levels), Type B (cleanup to risk-based levels),
l)r Type C (cleanup to risk-based levels under site-specific conditions). At the J&L Landfill Site,
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l"S. EP.-\ has dd~nnint:J that Typ~ C ..:ritt:ria art: appropriat~. Th~ sdt:ct~J rt:lI1t:dy r~4uir~s
,\ q)(;lil1l11~11! lIt' th~ lanJfilkJ wast~. T> p~ A nr Typ~ B crit~ria ..:oulJ not b~ l11~t without ~:'<.cavatil1g
;tl1d r~l1h)\il1g th~ landti!kd \vast~ at a great cost which would yidd link or no additional protection
\ 'I" ~'n\ irul1l11t:l1!al benctit. The use of Type C critc:ria will ensure a suitably protective, appropriate,
,lIld ~ll'\t-df~cti\~ rt:mt:dy.
\li~'hi~al1 Soil Erosion and Sedimt:ntation Control Act 3~7 of 1972
The ~lichigan Soil Erosion and Sedimentation Control Act (Act 347) regulates earth changes.
induding cut and till activities, which may contribute to soil erosion and sedimentation of the
sUI1'ace waters of the State. The Ladd Drain, adjacent to the site, flows into the Clinton River, a
surface water of the State. Act 347 will be applicable or relevant and appropriate to the
~arthmoving activities at the site to the extent that those activities might result in soil erosion and
~t:dimentation of the waters of the State.
\lichi~an Air Pollution Act 34.8 of 1965. as amended and associated rules. To the extent that Act
3~~ may be more stringent than the Federal program. Act 348 is considered ARAR. The remedial
adiol1 will be conducted in a manner that shall comply with all applicable air pollution
requirements. particularly regarding fugitive dust emissions and any venting that may be necessary
as a component of the remedial action.
Michigan Hazardous Waste Manaeement Act 64 of 1979. as amended and administrative rules
Michigan is authorized to administer its own hazardous waste program within the State, in lieu of
the Federal program. This Act regulates the generation, transport, treatment and disposal of
hazardous waste in Michigan. As with RCRA, Act 64 is not applicable to closure of the landfill as
the disposal ceased prior to the effective date of the regulations implementing the Act. The specific
rt:quirements of the Act regarding cover component specifications may be relevant for the same
reasons given, above. regarding the Federal regulations promulgated under Subtitle C of RCRA;
however, U.S. EPA does not consider those requirements appropriate for this site when the
hydrogeological characteristics of this site and the relation of the remedy for this site to the
surrounding landfills and the topography thereof. as well as the special constraints impOsed by
dimate are considered. While U.S. EPA does not believe that Act 64 is ARAR for this remedial
action, U.S. EPA has detennined that Act 64 is "to be considered", and U,S. EPA has considered
the goals of the Act re~arding the closure of landfills containing hazardous waste as this site
contains substances similar to "hazardous waste" as that tenn is defmed by RCRA. Additional
discussion of site-specific factors relevant to the remedy selection is provided below.
The waste at this site is in contact with a shallow aquifer which is already contaminated up-gradient
from the site. The location of the site and its relation to the sUITOunding landfills impose practical
constraints on the thickness of any cap which can be engineered on the site and effectively
maintained as a barrier layer. A clay cap must, if it is to retain any effectiveness as a barrier layer
given the climate of these latitudes. be protected by an additional soil layer (42 inches of frost
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!11\lll.:dilllll. .'1" the ,-'(I\er \\ ill he \uhjC:d tl1 dc:gradati()n through cracking and erosion as a result of
<.l'\IIlal 11"1...t:lln~ :lnd tllawing"
The ,ite 1.."(1\ ef'; lInly 17 acres in areal extent. It is long and narrow. The cover must have a
,uit;lhk -;I(lpe tll permit the drainage of precipitation if it is to function properly in reducing
infiltr;ltion. Th~ engineering problems associated with these factors are exacerbated by each
~ldditi(lnal requirement to thicken the barrier layer. Therefore. U.S. EPA has determined that the
must appropriate:: cover will be one which achieves the maximum reduction in infiltration rate
consistent with a suitable slope to permit drainage. To achieve this, U.S. EPA has selected a
rc:medy which employs a one-foot clay layer followed by a geosynthetic clay layer. a flexible
membrane liner. and a geonet with geotextile filter fabric for drainage, as well as the necessary 42
inches of frost protection. By using geosynthetics rather than clay and sand. it is possible to achieve
the desired minimization of infiltration and the requisite drainage layer while avoiding the erection
(If a barrier laya so tall that it would be difficult to design it to slope properly in relation to the
\urrounding landtills. This barrier should provide the most appropriate level of protection against
infiltration possible at this site.
:-'"1ichigan Solid Waste Management Act 641 of 1978
The State is authorized to administer its own solid waste management program, in lieu of the
Federal program. The Michigan Act was revised in October of 1993, and the implementing
regulations regarding landfill closure were rewritten and promulgated then; therefore, these
regulations are not applicable at this site; however, they may be considered relevant. The
regulations at R299.4425(3) have been identified by Michigan as those that would "apply" (sic) to
this landfill for purposes of closure. R299.4425(3) requires two feet of clay and six inches of top
soi I. U. S. EP A has determined that this requirement would not be appropriate for this site, and
U. S. EP A has selected a cover design which, while it uses only one foot of clay, nevertheless
provides greater protection against infiltration of liquids than what could be achieved using two feet
of clay while being more suitable for this site in regard to the engineering difficulties discussed
above.
\-lichigan Compiled Laws Annotated Section 257.722 ("frost laws").
Michigan has identified these requirements pertaining to maximum axle loads permitted over certain
Michigan highways during certain months of the year. These laws are designed to prevent damage
to Michigan highways that might otherwise be caused by excessively heavy loads during the period
when the weather alternates between freeze and thaw.
A requirement must be triggered by a component of the remedial action which occurs on-site to be
ARAR. Actions which take place off-site must comply with all applicable laws, but only actions
which occur em-site as a component of the remedial action selected in the Record of Decision are
.~RAR. The requiremems of MCLA ~ 257.722 are not ARAR; however, they do constitute
~lpplicabk otl-site requirements.
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3.
C\I\( Effcdi\ cnc..,~
C\I\( dkl:ti\en>=ss (ompares the dfel:tiveness of an alt~rnati\e in propol1ion to its cost of providing
""11\ irl1l1l1lel1tal bendits. Table 2 lists the costs associated with the implementation of the selected
rC:lIh::d\ .
TABLE .2
TUlal estimated costs for the selected remedy at the J&L Landtill Site:
Total
Capital Cost
Total
O&M. 30 vr.
Total
Present W ol1h
Alternative
~b
54.653.200
5220.800
$4.874,000
The sd~cted remedy for this site is cost effective because it provides the greatest overall
effectiveness propol1ionate to its costs when compared to the other alternatives evaluated; the net
present wOl1h being S~.874.000. Although slightly higher than 4a and a bit higher than 2b, the
estimated cost of the selected remedy is fully justified because the level of effectiveness increases
greatly. The effectiveness of 4b is actually greater than 3a and 3b, yet the cost is significantly less
compared to the cost of $5,~i97,300 and $6,095,600 for 3a and 3b, respectively. The effectiveness
of 4b assures a high degree of certainty that the remedy will be effective in the long-tenn due to the
signiticant reduction of the potential mobility of the contaminants achieved through containment of
the source material and the decrease in potential leachate generation. In addition, 4b is also more
d'fective from an engineering perspective. That is, due to the flatness of the surrounding areas,
construction of a cap which meets the technical requirements set forth and which is effective in
reducing infiltration to the greatest extent possible, would be more difficult to implement using the
I:omponents and design in alternatives 3a and 3b.
~. Utilization of Pennanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedy represents the maximum extent to which pennanent solutions and treatment
t~chnologies can be used in a cost-effective manner for OUI at this site. Of those alternatives that
are protective of human health and the environment and that comply with ARARs, U.S. EPA has
d~tennined that the selected remedy provides the best balance in tenns of long-tenn effectiveness
and pennanence, reduction of toxicity, mobility, or volume of contaminants, short tenn
dfectiveness, implementability, and cost, taking into consideration State and community acceptance.
The installation and maintenance of a final cover for the landfill, ground water monitoring, and
restriction of site access through installation of a fence and institutional controls, will provide the
most pennanent solution practicable. proportionate to the cost.
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"
PI".:kr':I1CL' 1\ 'r Tr'::llll1.:l1! :h :1 Pril1cipal Ekmet1!
13,1,.:d 1\11 dlm:1H inh)nnation. L".S. EPA believes that the selected remedy is protective of human
1,,-':lIth :llld the cll\in11lIlh:nt am! utilizes pennanent solutions and alternative treatment technologies to
tll': 111:I\illlUIII L'\tent p~1ssible. The remedy, however. does not satisfy the statutory preference for
Ir'::ltll1L'lIt p1' th\:' hazardpus ,uhstances present at the site as principle element. as such treatment was
11Pl Ipund tp he practiL'ahle or cost effective.
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:,"';T€ := "ql~.~iG":'N
.~7'..J;:AL ~ESOUR:E;
r.:c MMiS3iCN
.E;:;~'f :. ~ART'I/"
..).~I:'" ::JE'."J''';-
"A.~'L 83£'.£
.AMES P "'LL
DAIj'IO ...ou.l
£EY M, ',11."10
JC"OAN iJ. ~,ITiE~
1£
JOHN ENGlER. Governor
DEPARTMENT OF NATURAL RESOURCES
S!e,1!(I,; T. Voiun 61Mdi~. P.O. 601 30028 t.An&lng, W ~909
FOlAND HARMES. Oir.CIa
JIJne 30, 1994
Mr. Valdas V. Adamkus, R-19J
Administrator, Region 5
U.S. Environmental Protection
77 We3t Jackson Doulevard
Chicago, Illinois 60604-3590

Dear Mr. Adamkus:
Agency
The M'ichigan Department of Natural Resources (MDHR), on behalf of the State of
Michigan, has reviewed the Record of Decision (ROD) for the J&L Landfill
Superfu~d site operable unit 1 (OUl) remedial action (landfill cap) and the
~r'opCJ:)ed n~mt:dy ,"ontained in tt1at ROD. Mic.higan c.on(.urs with the OUI remedy
proposed in the ROD consisting of: 1) a Michigan Hazardo~s Waste Management
Al,;t, 1979 PA 64, ii~ Q;aeuded, and Q)~lJciated ,'u1e$ tedmlc.al equivalent
landfill cap (one-foot compacted clay overlain by a geosynthetic clay liner.
(GCl), it 60-mil f1tJJ.iul~ III~mlJnUlt 1 jilt" (FML) utinier li£yer', a
geonet/geotextile filter fabric drainage layer, a 36~inch clean fill layer,
and a 6-1nch lopsoil layer) and 2) lhe remedy cumpunt!nls 1 islt!u UII PclYI: 22 or
the attached ROD. The State concurs with the understanding that the U.S.
Env1ronmental Protec:t1on Agency (EPA) will further enluale and cHJun!SS lh~
contaminated groundwater at the site in a second operable unit for the J&l
Landftll Superfund s1te.

The State does not concur with EPA's omission from the ROD and from other
references of the following State of Michigan regulations which the State
considers as applicable or relevant and appropr1ate requ1rements (ARARs):
1) the Michigan Hazardous Waste Management Act, 1979PA 64, as amended, and
associated rules, 2) the Michigan Water Resources Commission Act, 1929 PA 245,
as amended, MCl 323.6(1), MCL 323.1 et ~, and the associated Part 22
A1ministrative Kules MAC R.3,3.2~Ol et ~, 3) the Mineral Well Act, 1969
PA 315, as amended, 4) the Liquid Industrial Waste Removal Act, 1969 PA 136,
" the substantive portions of Part 5 of the Michigan EnVironmental Response
Act, 1982 PA 307, as amended, cleanup rules, and 6) the Michigan Compiled laws
Annotated--Sect1on 257.72Z (frost laws). Ihe State ~as previously ident1f1ed
these requirements as ARARs for the OUI remedial action being selected for
this site. The State still considers these as AKAHs.
The EPA previously identified 40 CFR parts 262 and 263 regulations for
removal, transport and off-site disposal of hazardous waste as ARARs yet did
not include them in the final ROD. Please include these regulatlons in the
final ROD because the drummed well development and decontamination water may
be classified as hazardous and will likely be taken off site for
treatment/disposal.
'/8]
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Mr. Valdas V. Adamkus
-. 2 .
';i.ln!! 30, i994
The State of Michigan believes that the EPA should determine what action~ will
,e taken to address the contamtnaleu groundwater at the site beforQ the OUl
landfill cap is installed. If this determination i$ not made prior to cap
installatlon, it is poss1ble that yruw~w.ter remediation or w~stc dowatering,
if deemed necessary, will adversely affect the integrity of the cap due to
excess1ve settling. Mov,ng ahead w1lh Lite .:.ap prior to lIaking a fin~l
decision on the need for a 9roundwater remedy could also have the tendency to
bias that evaluation, particularly l' illphmt:I\ting I groundwater remedy would
or could result in high cost damage to the 1andf111 cap. If the cap is
constructed prior to completing the groundwll~r ~va1uation and a grou~dwater
remedy is subsequently implemented which adversely affects the cap, the State
will not guarantee its lOS match (11 OUl 1 S it fund response) for any costs
associated with repairing the cap.

There were a number of components of the OUI remedy which were not clearly
defined in the text of the ROD but were better ut:fined in the respons;vene:i!.
summary. The State of Michigan concurs with the remedy selected with the
following understanding of the points 1n questiun:
- The proposed landfill cap wi'l be des1gnvd ~y,h that the water that
filters through the cap to the drainagl layer a~ove the GCl is directed.
to one of the on-site drainage ditches or other!~~p"oprilte collection
system; !

- Contaminated sediments from the sediment pond in the northwest corner
of the s1t. will be removed betore the sed1ment:pond is filled to grade
with clean f11'. These sediments will then be consolidated underneath
the current 'andfill cap. S1milarly, the contamtnated surfac.e
soils/sediments from the east ditch will be Ixc~vated from the ditch and
consolidated underneath the ex1st1ng 1anO(111 c~p; and
- The cap for the east ditch will consist of an FML (60 mil) overlain
with 42. inches of clean fill/tops01l/vegetation: for frost protection.
I

The State of H;chiqan also recommends that the follow~ng be ircluded as part
of OUI remedy implementation: 1) the water from surface runoff and LhH
drainage layer of the caD be sampled to ensure that the water leaving the site
and entering a surface water body is uncontall1nated, Z) any contam1nated
~oils/sediments from the south ditch be excavated andl placed beneath the
existing clay cap with the rest of the landfill contents, and J) a11 01 Un:
on-~ite drums containing soil cuttings, personal protective equipment, and
well developMnt and purge water be addressed now or,1 at a lIinimum, be
prop~r1y secured; currently, they are "at adequately :secured to prevent human
exposure.
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Mr. Valdas V. Adamkus
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Jt;ne 30 I 1934
The State of Michigan also requests that the June 20, 1994, letter from
Ms. Betn O'Bricn, MDNR, to Ms. Laura Evans, EPA, transmitting comments on th~
second draft of the QUI ROD be included as a part of the administrative record
for this site.
We are pleased to be partners with you in ~elccting this remedy and look
forward to working together to accomplish the final remedy at this site.
Sincerely, ~

,~~V~

Russell J. Harding ---.J
Deputy Director
S17 -373-7917
AL lcH;tllll~lIt.
c<.::
Mr. Jdlne~ Mayka, EPA
Ms. Wendy Carney, EPA
Ms. LiiUT'ca EHn~, EPA
Mr. Paul Novak, MDAG
Mr. Tarik. N4l11uur, MDNR
Mr. William Bradford, MDNR
Dr. Geory~ C4r'p~nter, MDNR
Ms. Beth O'Brien, MONR
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MICHIGAN DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL RESPONSE DIVISION
SUPERFUND SECTION
FAX TRANSMITTAL
~
DNRt
PLEASE DELIVER TO:
NAME: Wendy Carney
COMPANY: U.S. EPA, Region 5
TELEPHONM NUMBER: (312) 353-6SS3
fAX NUMD1!R: (312) 353 5541
SENT BY:
NAME: Beth O'Brien
TITLEJUNIT: Project Manager I SMU 1
PHONE NUMBER: (517) 33S-3«m
t'AX NUMBER: (')7) 335-4887
TODAY'S DATE:
June 30, 1994
NOTE.:
Here is the signed copy of d1e J&L OUi ROD concum=u~ letter. The origiJ\al will be mailed by relular
mAit. (;atl if you have any questions.
5~
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. u
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE:
JUN 3 0 1994
SUBJECT:
~eauest for C~ncurrence on the Record of Decision for
Remedial Act~~n at the J&L Landfill Site,
Rochester Hills, Michigan
FROM:
William E. Muno
Director
Waste Management Division
Gail C. Ginsberg
Regional Counsel
TO:
Valdas V. Adamkus
Regional Administrator
The purpose of this memorandum is to recommend that you sign the
attached Record of Decision (ROD) for the J&L Landfill site located
~n Rochester Hills, Michigan.
The ROD was prepared in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act, 42 U.S.C.
9601 et seg., as amended by the Superfund Amendments and
Reauthorization Act of 1986, Public Law 99-499, and, to the extent
practicable the National Contingency Plan, 40 CFR Part 300, and
Agency policy. We have reviewed the attached documents and have
concluded that the ROD is both legally and technically sufficient.
As such, we believe that implementation of this remedial measure is
a proper exercise of your delegated authority.
Please feel
questions.
free to contact either of us should you have any
Attachment
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