United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-86/039
September 1986
SEPA
Superfund
Record of Decision:
Spiegelberg, Ml
-------
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TECHNICAL REPORT DATA
(P/~tU~ 'tad IIf"fUctlOlfS Olf Ih~ 'tv~n~ IHf~~ co",,,/~tilfIJ
1. .-E'O.-T NO. 12. 3. RECI'IE",T'S ACCESSION NO.
EPA/ROD/R05-86/039
.. TITL.E AND SUITITL.E 5. "E'ORT DATE
SUPERFUND RECORD OF DECISION ~""nrember 30 1986
Spiegelberg Landfill, MI 6. 'E.-FORMING ORGANIZATION CODE
7. AUTMO'-CSI 8. 'E..FO..MING ORGANIZATION REPORT NO
t. 'ERFO'-MINQ O'-GANIZATION NAME AND ADDRESS 10. '''OGRAM EL.EMENT NO.
11. CONTRACT/~fIIANT NO.
12. S'ONSORING AGENCY NAME AND ADDRESS 13. TYPE OF RE'ORT AND PERIOD COVEFlEO
U.S. Environmental Protection Agency Final ROD Renort
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SU"L.EMENTARY NOTES
US. A8STRACT
The Spiegelberg site is a waste disposa~ pit located in Green Oak Township,
Livingston County, MI. Currently, the Spiegelberg property is being mined for sand,
gravel, and peat deposits. From 1966 to 1977 the site was used for the disposal of
domestic waste, with the main disposal area located in an abandoned sand and gravel pit
in the northern third of the site. From 1967 to 1978 paint sludge was dumped near the
surface water portion of the gravel pit. The paint sludge area is approximately
one-half acre in size and is reportedly thirty feet deep in several places. There are
two layers of hardened paint sludge: at a depth of three to six feet: and at a depth 0
thirteen feet. Five-gallon paint buckets were also buried at a depth of approximately
ten feet and paint mixed with sand is present at various depths. Only private, domesti
wastes have been disposed of at the site sInce the end of 1978. Organic contaminants
have been detected in onsite and downgradient monitoring wells indicating the migration
of these contaminants from the site into the ground water. The primary contaminants of
concern include: VOCS, organics, inorganics, base/neutral compounds, TCE, toluene,
xylene, metals.
The selected remedial action for the site includes: excavation of 15,000 cubic yard
of waste material which will be separated into liquid and solid sludges and paint
residue with garbage intermixed: offsit.e incineration of approximately 5,000 cubic yard
(See Attached Sheet)
17. I(E Y WORDS AND DOCUMENT ANAL. YSIS
a. DISC'-I'TO"S b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Fleld.Group
.,\::\";UL u U1.
Spiegelberg Landfill, MI
Contaminated Media: gw, soils
Key contaminants: VOCs, organics, base-
neutral compounds, 'inorganics, metals
'8. DISTRIBUTION STATEMENT 19. SECURITY CL.ASS I Tills Rrpo", 21. NO. OF PAGES
None 38
20. SECURITY CL.ASS ,Tllilpal.' 22. PRICE
None
~.
e'A '.'111 2220-1 (R... 4-77)
""I:Y'OUI IIDITION II O.IOL.I:TII
-------
EP~/ROb/R05-86/039
Speigelberg Landfill. MI
16.
ABSTRACT (continued)
.
of the excavated waste material; and disposal of the remaining 10.000 cubic
yards of waste into a RCRA landfill. The capital cost of this alternative
is estimated at $15,771,000 to $18.395,000 depending on the offsite disposal
location. No O&M will be required.
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Summary of Remedial Alternative Selection
Spiegel berg
Green Oak Township, Michigan
Site Location and Description
The Spiegelberg site is a waste disposal pit located in a rural area in
southeastern Michigan. The site is about 40 miles west of Detroit and 1.5
miles from Hamburg, in Green Oak Township, Livingston County, Michigan (see
Figure 1). The site can be accessed from Spicer Road which forms the
northernmost boundary.
The Spiegelberg property is located on approximately 114 acres. There is a
paint sludge disposal area in the northern third of the property at the base
of a sand and gravel quarry which covers 'an area of about one hal f acre (see
Figure 2). Currently the Spiegelberg property is being mined for sand,
gravel, and peat deposits. A family living in a rental home and also a barn
are located on the northwest corner of the property. Domestic refuse is
disposed east of two large metal buildings which are near the center of the
site. The site is surrounded by woods, open fields, and rural residences.
A population of several hundred live within one mile of the site. Immediately
south and adjacent to the property is the Maxey Boys Training School which
contains several hundred long-term residents and employees. North of the
site are the Hamburg VFW Post 1224 and the Holy Spirit Catholic Church.
Several re~ort and State recreational areas are also located near the site.
Borings from the site indicate that the site, typical of a glaciated area, is
covered with discontinuous layers of clay, silt, gravel, and a heterogeneous
mixture of these materials. The glacial deposits contain interbedded aquifers
and aqu;cludes. The site overlies at least two sand and gravel aquifers; an
upper unconfined aquifer, and at least one deeper aquifer that lies below a
sandy, silty clay zone. The thickness of the saturated zone of upper aquifer
beneath the site ranges from less than 20 feet at the paint sludge area to 45
feet at the VFW post near Spicer Road. The total thickness of the upper
aquifer ranges from approximately 30 to 70 feet. The aquifer thickness
increases because the clay layer which forms the lower boundary of the aquifer
is not horizontal. These aquifers may be hydraulically connected at various
places. Groundwater flow in the upper aquifer is generally to the north.
Site History
The Spiegel berg site was used for the di sposal of domesti c waste from 1966 to
1977. The main waste disposal area was located in the northern ~hird of the
site in an abandoned sand and gravel pit. Domestic wastes were still being
disposed of in 1973 despite numerous requests by the Livingston County Health
Department that the owner obtain a refuse dumping permit. Except for private,
domestic waste, no other wastes were disposed at the site since the end of
1978.
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BAS! MAP 15 A PORTION OF THE U.S.G.S. HAMBURG, MI QUADRANGLE (7.5 MINUTE SERIES, PHOTORE'VISED 1975).
CONTOUR INTERVAl. 10', FIGURE I
LOCATION MAP
SPIEGELBERG a RASMUSSEN SITES G~J;iON
LIVINGSTON COUNTY. MI LD ~II
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GENERAL ARRANGEMENT
SPIEGELBERG WASTE DISPOSAL AREA
LIVINGSTON CO., MI
SCALE: 1": 100'
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From 1967 to 1978, paint sludge was dumped in an area near the southwest part
of the gravel pit. The paint sludge area is approximately one-half acre
in size and is reportedly 30 feet deep in several places. Two layers of
hardened paint sludge occur; one at a depth of 3 to 6 feet and another at a
depth of 13 feet. Five-gallon buckets of paint are also buried at a depth of
approximately 10 feet. Paint mixed with sand and soil is present at various
depths. Currently, the paint sludge area is covered with soil so that only
small patches of the sludge are visible. Organic contaminants have been detect-
ed in onsite monitoring wells and in downgradient monitoring wells indicating
the migration of these contaminants from the site into the groundwater.
Current Status
'-'
The Spiegelberg site was placed on the National Priorities List (NPL) in
December 1982, in group 5 making it eligible for federal funding under CERCLA.
The Remedial Investigation (RI) was initiated in May 1984. Sampling and
analysis of subsurface soils in the paint sludge area indicate the presence
of high concentrations of organic and inorganic compounds from the Hazardous
Substances List (HSL). The detection of organic constituents in downgradient
monitoring wells and the mObility characteristics of the compounds found in
the paint sludge area, indicate that transport via groundwater is a major
potential pathway at the site. These results indicate the need for remedial
action which addresses source control of the wastes and contaminated soils
contained in the paint sludge disposal area on the site, in order to reduce
or eliminate exposure of potential receptors to site contaminants. Additional
field work will be conducted to address the groundwater portion of this
investigation. The source control operable unit alternatives were evaluated
through a Phased Feasibility Study (PFS). The operable unit will be a portion
of the overall remedial action and will be consistent with the final remedy
for the Spiegelberg site in accordance with the NCP.
The study i ncl udes sampl i ng of surface soi 1, subsurface soi 1, gravel, and
air. The sampling program was conducted from January to July 1985.
All samples were analyzed for HSL organic constituents. The ambient air
sample was analyzed for volatile organics and particulate semi-volatile
organics, pesticides, polychlorinated biphenyls (PCBs), and metals.
Sample locations are shown in Figure 3.
The surface and subsurface soil samples analyz~ for HSL constituents were
selected on the basis of field Gas Chromatograph (GC) screening results. The
field screening samples were analyzed for 1,2-dichloroethane, trans-1,2-
dichloroethene, tetrachloroethene, and/or benzene, chlorobenzene, chloroform,
1,1-di~hloroethane, 1,1-dichloroethene, ethylbenzene, methylene chloride,
toluene, 1,l,l-trichloroethane, and trichloroethene.
The largest number of contaminants were detected in subsurface soil samples
and samples of paint sludge and soil from the test pits. Most of the
contaminants detected are volatile organics and base/neutral extractable
organics, although low levels of pesticides were detected in surface and
subsurface soil samples collected from the paint sludge area. It is estimated
that there were 15,000 cubic yards of material with 5,000 cubic yards being
hazardous liquid consisting of a mixture of deteriorating 5-gallon containers
of liquid paint, paint residues, and garbage. Ten thousand cubic yards are
solidified sludge. Tables 1 and 2 show the organic and inorganic contami-
nants detected at the Spiegelberg site.
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68.1/105 11124
2.3/& . 7 4/24
4.7.5/2.388.5 1124 \.0
68 .Ii/l25. 2 6124
14/41
48.1/238.8 In4
0.28/'" 1124
UOIU 1124
3.0/14.6 1124
023/1.1 1124
-------
I Alii I
W,I IIIIW\NICS UY MlflIA h'''ol
:;"111 a IIIIIICi Sif [
l'At;1 IWU
~~I~m!!!!!!!
~!~!~!'!! ~
IIlotOIlO
2 - '111101\000
2 IIoKolluoe
4 - "',,"hvl 2 -1'011101\000
belUtlllO
loiliolle
IIIIIVI bOllleoe
1010' Kvl,,"e
Sly,olle
l.f.J.2 101'8l:1,loroelllooa
f. f.1 "kh'lIIoolhol\a
f.1 '1I,,:II'lIIoolhollo
lolllll:hloroo.llooo
I,'chloroulhuoe
..1110.010....
molhvlooo chforlde
Lo,holl d'su"".a
'IA$I./Nlll1ltA' EX1RACTABlES
bi~li~'Olhyii,eKY'lphlll.I.IO-
dl-lI-bulV' pt,Ih.'.'O
bo,uvl . bUIVI phlhol.l.
dlulhV' phlhololO
1I1"IIIh.looa
2-lIIelllvl n8ph'"olone
0- uil,osodil.hunvl.mlne
4 -1:1110.0....111110
bOl\lolI: ilcld
1'1' ~!f!!!!.~
onmmo-OIIC
dullo IUIC
.:hl...oIol\o
hopl..ch.o.
"ono
I'osi;'
~r.
Toll PII,
Avor.uo
Concentrallonl
~!!!.!.!!...!!!!!atlon I
No. 0'
Posltlv. Ootactlonsl
Tol.. No. 01 S.mp'os
Suhsurloce 5011
"ano. 01 Averaoo No 01
Posilive Concentratlonl Posltlvo Oelecllonsl
Delectlons Slandard Oovl_tlon Tot.. No. 01 Saml.los
74 - 1.000 1411271 6115
1800 - 60.000 5.160115.427 4115
18 - 210 33.8fl2 8/15
08 - 2.500 ;88/645 3115
U - 2.000 48/515 4115
2.8 - 210 14/54 2115
2.300 tli31504 '"5
800 53/207 11.5
2.300 153/504 1115
34.1 - 3.200 305/813 8115
78.. - 210 11.8/83.7 6116
308 - 850 288/205 8115
610 3411n Ilt5 r-
81.8 - 20,000 1.331115.183 2116
2186 80.2/442 1/24
878
11.1145/4
Ilt5
..3
~ !!!.-
411 - I. .-: 275/413 3/8
655 821232 118
200 - ( ~oo 52.800/148.000 3/8
53.2 - ~ .-0",9 47711.140 3/8
1.6 - 4l. ,.100 56.7001152.000 3/8
24.000 - . :.920.000 387.000/1.025.000 3/8
1.7 - In .::0,000 1.300.000/3.810.000 8/8
41 05/1.4 118
31 - OC:. 28/35 4/8
351 - C. - 168/354 218
1.4 - 30;. 461107 5/8
72 8 - ;'~:r. 18/34 218
383 - 7. .:' 14/28 2/8
46 - 10: 223/281 8/.
362 - ~ : 54/07 818
346 - 2( ;,10 8.840/10.800 4/8
180 - E.: ~ 1.34012.020 4/8
1]8 17148 118
1.572 -: .000 12.8001 4/8
Nol05:
111011. spoco Indlceles consllluoni not 'ou...~ above d.tactlon IImlll.
1 Av.".uu conco"I,.lIon for 1851 umpio. may nol raprasant a tru. .t.llsllc81 av.r.g.. Sempl.. 'rom Tasl PII I w.,a ,.'eclad 10 provlda an Ind'Clllon 0' Ih. d.plh 0'
Illu 1'111111 ~h..luu 01..0 SOIOI'IOI trolO Jc;c :'11 2 wer. ,olocled 10 ulva an Indlc.llon 0' .""orll c.so. conc.ntrallonl_.
-
.'
-------
TABlE 2
USI INOIIGANICS BY "'UnA Imo"ot
SPIEGUO[r;J SUE
-- Or.v81 Sur!actt Soli
IIln! o. Avorao. No. o' n.nO' o. Av...O' No. 01
Puc :' JO Concenlnlllonl POllllv. O.I.ellonl/ POllllv8 Cone.nlr.tlon/ POllllvo OOl,etlnnl1
~:,::ill!- Siand.rd Oo"lllIon Tolll No. o. S.mplol Doloellonl Slond.rd OI"I.lIon Tolll No. o. Simples
~!l!!~!!!!!~
el.unhlu'R 2.110 - ~. ' <0 2.745/813 2/2 1.400 - 7.860 4.32812.101 24124
Intlmony
11.50111;; 2.1 - 13 2813.8 U124
be.lum U 6/U 1/2 7.3 - 32!i 42169 80124
beryllium 0.22 - 0.55 008/0.17 2124
(;OdlOllI... 4 0.17/08 1/2~
.:uh.hllu 17.870 - :.500 04.185/8.031 21Z 773 - 122.780 40.055/38.101 24124
«.1\10'"""" 1) 115/92 112 4.1 - 38 102n.7 21124
(ohull 4 - U 34/4.1 10/24
(;uI'IIO. 1 - 114 13.112U 15/24
'run 6.000 .. : ..'70 8.68511.252 2/2 5.690 - 10.300 11.593/8.033 24/24
loud 3 - 47 3 011 2 212 2.7 - 88 1581228 16124
mo!)noslum 11.600 - : ;;.000 13.300/2.404 ZI2 158 - 38.100 11.49718.565 24124
lIIenuonoso 221 - 2. . 244/23 212 112 - 1.510 4501362 24124
morC:llry 0072 - 0.64 006/0.14 8/24
nlc:"ol 8.5 - 27 8.4/8.8 14124
1'018s5111m 3:11 - 1.884 145/815.8 16124 ;,.
5"hllllum 30 - 42 4.4/119 3/24
511\/8' 6.3 02211.1 1124
sodium 560 - 1.810 328152U 8/24
IholliulO 2 - 8 033/1.1 2/24
lin 23 095/47 1124
vanadium 7.1 - 28 1 U/8.1 19/24
llnC 26 - 32 20/42 2/2 28 - 358 50nl 24/24
-------
'Alii I 2
IISI INOIIGANICS BY MrOIA Cmu"ut
Sl'lUjU III IIIj SIU
l'A(jl IWO
TUI rlls Subsurfllci Soli
Rllnge l AverlOI No. 0' nanOI 0' AvarlOI No. 0'
~ "o~IIi'.', Concunultlon! Poslllvi OlllcUonl1 POlltivl ConcenUltloni PositivI Oellcllonsl
r' -1!!!!!f!!f. Slendild Olvlllion 'DIal No. 0' Simpl.. Pelectlons Slandild Deviation TollIl No. 0' SlImples
~ ~!!!!!!!!!!!-
P
J ol"I1IllIum 522 - 3.34( 2.396/918 8/8 1.330 - 6.450 3.741/1.720 15/15
J
~ 1I"I"nony 45 5 61158 1/8
,~
.! 1IIS01lic 28-89 2.1/3.4 3/8 2.7 - 11 5.213.5 14/15
., "II,lulII 76 - 733 2321310 8/8 80 - 1.640 133/417 15115
~ he. ylllulII 019-02(j 0 054/0.10 2/8 0.27 - 0.17 0.16/0.23 7115
\ CIIIIR.II.", 54 - 16 3.51157 3/8 28 -:u 0.3811.0 2/15
.;; caknu.. 26.100 - 8!: '..:;J 60.050/20.427 8/8 827 - 134.000 55.866/44,198 15/15
~
r: dllomlum 52 - 1,110 2911!192 8/8 56 - 272 28/68 15/15
:1 1:1111011 U - 90 14.71306 7/8 4.1 - 8.6 4.313.0 12116
~ CIII'I'O' 11 - 301 056/1312 8/8 7 8 - 20 11.2/40 15/16
~ butt 5.260 - 91.( ',;, 25.585/31.082 8/8 &.800 - 15.300 10.10612.802 15/15
" luo.1 46 - 18.60;; 2.512/8.600 8/8 U - I.ODO 85/217 15/15
~
) IIIIIUlloslllm 3.720 - UI.hJ 1].780/4.648 8/8 026 - 20.700 11. 106/8.638.2 15115
~ n.llnllollOSO 164 - 362 270/65 0/8 135 - 407 312100 15/15
.lIou:ury 0085 - 0088 0.013/003 3116
J. "Idol 84 - 1.650 290/587 8/8 50-81 18 3/18.5 15/15 CJ".
U 11010ssl,,", 665 - 951 601/380.4 8/8 358 - 1.800 6801310 111/15
, ~ol8nlulII
.
< sill'tI. 26 - 6.3 lfi/2.3 3/8 2.3 0.15/0.8 1/15
:~ ~ollillm 2.140 - 3.3; 7 2,8621E81 8/8 555 - 2.880 988/888 10/15
i. 1"011111111
.,
1111 18 - 48 4.3/13 2/16
Vllllodillm 5.1 - 12 8.1/1.2 8/8 8.1 - 2Z 12.6/5.7 15116
lllu: 45 - 30.70:': 8.226/10.782.5 8/0 21 - 1.760 187/444 15115
I~
~
,
4
NOlos'
UIBllk spoce IndlclIl85 cORsllluenl Rol 'e; ..'J IIbovII dlllllcllon IImll..
1 Avo'ouo ';IOIICOlllllllloli '01 losl ump:.. mllV nol replllolni I Irul .lllIlIlcal IvolIlI'. Slmpll. Irom TI.I PII 1 Will .lllclld 10 provldl In Indlcallon 0' Ihl dllplh o.
Ille 1111111 slll
-------
:, .::'- , 'r: ':: ~ :-;::,~".' ,';~~.~ ::", \<'~', .'~''''''.~ :,'. ':: 'd", ... .;.':.',~:.-::~~.,',~..Wt;;" :~~';~..~' -t,,}...;.J~:..:'~ ~:/--: ,:;!:~:~~:,~:i..',./,~:.,~, ~ . '-~":,", '.~:,;~.:'".j'., -~ ~:..:-. :-: ~::;,:'; _.~.;~:. .':'.~~:.::'.:::.;;;y :..,.:,:.I;l..'; '~..:"t.:.f::..i:. ~t:'~.~l-~.~~:ii;.~ j':;:;;:':ii~t..:.;;:;.,;;, ,,~~!).:;~_:~.-~t "'':''-....~ :''''.: ",.;.~:,.;...:....
10
Test Pits
Materials from test pits excavated in the paint sludge area appear to be the
most heavily contaminated media in terms of contaminant concentrations and
the number of organic chemicals detected. The locations of the test pits are
shown in Figure 3.
Materials sampled from the test pits include paint sludge, soil, and soil
mixed with paint. Test pit 2, located at the northern edge of the paint
sludge area, contained the highest concentrations of organic contaminants.
Toluene, ethyl benzene, and xylene, common constituents of paint, were detected
at significantly elevated levels.
Table 3 compares the concentrations of inorganic constituents detected in the
samples to literature background concentrations. Constituents that significantly
exceed background levels from the literature include barium, cadmium, chromium,
cobalt, copper, iron, lead, magnesium, nickel, and zinc.
Subsurface Soil
Concentration ranges for organics and inorganics detected in samples from the
paint sludge area and from outside the paint sludge area are presented in
Tables 4 and 5. Table 5 also compares inorganic concentrations with literature
background soil concentrations. Metal concentrations in the paint sludge
area significantly exceed literature levels. They include barium, cadmium,
chromium, lead, nickel, silver, tin and zinc. The compound 1,1,1-trichloroe-
thane was detected in all subsurface soil sampling locations except sample
location Nos. 43, 44, and 47. Sample location Nos. 200 and 136 also contained
chlorobenzene and/or chloroform and 1,2-dichloroethane. Sample location are
shown on Figure 3. .
Surface Soil
The surface soil contained fewer organic compounds at lower concentrations
than subsurface soils. Chloroform, methyle11e chloride, toluene, 1,1,1-tri-
chloroethane, and 1,1-dichloroethane were detected in samples from the paint
sludge area. Several samples from outside the paint sludge area contained
chlorobenzene, chloroform, 1,1-dichloroethane, 1,1-dichloroethene, methylene
chloride, and 1,1,1-trichloroethane. Pesticides were detected at two locations
in the paint sludge area. No metals were detected at concentrations signifi-
cantly higher than literature background soil concentrations.
Gravel and Ai r
Nothing significant was found in air and gravel samples.
Health Risk
The major potential health risk at the site is associated with exposure to.
known or detected carcinogenic compounds. Known or suspected carcinogenic
compounds detected in environmental media include benzene, chloroform,
methylene chloride, 1,1,2,2-tetrachloroethane, tetrachloroethene, trichlorethene,
bis(2-ethylhexyl) phthalate, n-nitrosodiphenylamine, delta-BHC, gamma-BHC,
chlordane, heptachlor, and several inorganic constituents. These and other
compounds detected at the site are also associated with acute, chronic, mutagenic
reproductive and/or teratogenic effects.
-------
TABLE
1
oJ
SPIEGELBERG TEST PIT :NORCAN/CS (mg/kg)
CONCENTRATION RANGES
u
Test Pit Materials (mQ/kQ) Average U.S.
Range of Average Literature Soil
Positive Detections Concentration Concentration( 1) Imq/lcq)
aluminum 522 - 3.340 2.396 47.000
antimony 45 5.6 NA
.. - .
barium 7.3 - 733 232 440
beryllium 0.19 - 0.24 0.054 0.G3
cadmium 5.4 - 16 3.5 NA
calcium 26.700 - 89.000 68.050 9.200
chromium 5.2 - 1,710 297 37
cobalt 2.2 - 90 14.7 6.7
copper 1 1 - 397 85.6 17
iron 5,260 - 97,800 25,585 18,000
lead 4.6 - 18.600 2,572.1 16
magnesium 3.720 - 16,900 13,790 4,400
manganese 164 - 362 276 330
nickel 6.4 - 1,650 289.7 13
potassium 665 - 951 591 15,000
silver 2.6 - 6.3 1.5. 0.05 - 0.1(2)
sodium 2,140 - 3,730 2,862 5.900
vanadium 5.7 - 12 9.1 58
zinc 45 - 30,700 6,224.6 48
(;
Note: NA - Not Available
Sources:
"
(1)
(2)
Shacklette and Boerngen. 1984
Barrett. 1982
" .
11
-_.._--'~ -. ..... - ,-...- - _0".-".'.. -..~. -.. ~ --.--.. -~-~ --- ..-...-......_-.-~--------~-,.-.---.._---~. --."'------"--------_I'>-..--_.",-,_--------~-"-,,..,--,-
-------
TABLE
~
"1
SUBSURFA.CE SOil - ORGANICS (J,lg/kg)
CONCENTRATION RANGES
SPIEGELBERG SITE
Paint SludCle Area(1)
Samples Outside of
Paint SludQe Area(2)
Volatiles
. ~.... . -''''.-'
. .~ r. ,.. '",,-.,,,,,, ..
.' ". . .~,. . .
6,000 . :;,lJOO l,ut];" " UQ,OOu
90 - 210 76.4
800 ND
18 - 2,500 0.8
57 - 460 34.1 - 3,200
210 2.9
2,300 ND
7.6 - 210 8.3 .- 26
2,300 ND
210 - 2,000 2.6 - 4.3
~~~utgiiOi.e
carbon disulfide
1,1-dichloroethane
ethyl benzene
methylene chloride
styrene
tetrachloroethane
toluene
1,1,1-trichloroethane
xylenes (total)
Base/Neutrals
di-n-butyl phthalate
diethyl phthalate
naphthalene
308 -
510
81.6 -
475
20,000
340
ND
ND
- 850
Pesticides
delta-SHC
176
ND
NOTES:
(1) Sample Location Numbers 42, 43, 47, 49, 118
(2) Sample Location Numbers 92, 114, 125, 140
ND - Not Detected
12
.. - ----. ~ .---.__.- -~ ---- -'~w""''''''''-'''''',..._,-.. .,.,.."" .,.'.....,.....- -. -.. "'-"'r..,-r-'..." -".' '.::-"'-"-".~.-..~'-r:::-'r- '''~;;'''='''''''"'F-rU'.'.~';.--''..."".....,,''...,''!'J'''!7J,....r:-.::~.'''';:.-:''..~.::;':,'-':"'.!.~'''';'-~~~'''~~~~'''~:~~~''~Y:0:::t'~'.;:;:;';~~~~~,'-;....'~f~
-------
... ...,.-- ..- .- - ".."~'.. .."" '. ............-1'~". -.. .... ...- _.-.."~ . ...
TABLE 5
SUBSURFACE SOil INORGANICS (mg/lcg)
CONCENTRA TJON RANGES
SPIEGELBERG SITE
Average U.S.
Samples Outside 01 literature
Paint Sludge Area( 1) Paint Sludge Area(2) Soil
Range 01 Positive Range 01 Positive Concentration
Element Detections (maIko) Detections (maIko) (mo/ka)(3)
"'.""""~r"p,~ 1 "':.-t" .. ~ ~.,'" .., I'" 1~. .,.. eo"":" ,it-;" ",..~
arsenic 2.6 - 1 1 3.1 - 1 CJ 5.2
barium 9 - 1.640 9.8 - 37 440
beryllium 0.44 0.28 - 0.77 0.63
cadmium 2.8 2.9 0.28(4)
/
calcium 17,500 - 134,000 827 - 84,300 9,200
chromium 5.6 - 272 7 - 16 37
cobalt 4.1 - 6.4 5.2 '- 9.6 6.1
copper 8 - 20' 1.8 - 19 17
iron 5,890 - 13,700 6,350 - 15,300 18,000
lead 3.8 - 1,080 3.2 - 8 16
magnesium 4,720 - 29,700 926 - 17,800 4,400
manganese 135 - 316 228 - 491 330
mercury .06.5 .067 - .068 0.058
nickel 7.6 - 81 5.9 - 20 13
potassium 358 - 641 502 - 1,900 15,000
silver 2.3 NO 0 .05(4)
sodium 954 - 1,980 555 - 2,880 5,900
tin 16 48 0.89
vanadium 8.1 - 13 9.2 - 22 58
zinc 21 - 1,750 23 - 45 48
Notes:
(1) Sample location Numbers 42, 43. 47. 49. 118
(2) Sample location Numbers 92, 114, 125, 140
(3) Shacklene and Boerngen, 1984
(4) Barret. 1982
13
-------
: 0.... ::;'::,:;.': ..~...... "~'.~~~~ ',.:~-::'\~ ~I"-""~,~:'~.,i~' 'i.""c ~~....:-....:; .{\:~\). ':"'..:. .:}~' ~~~.~::.": ,I; ,/\A')";':" ~'::~' ~ '.'=,~-:-".~'.::;::/::"'.t..~:: ~->"'-:",:""-,;: ::.:::;:.:;.,.":"'",'~" ,.:, ',:,.:. '.~ '
. ", '. L:. ." ..: ...'..~. .:.il,'''-::: .". .~, ':, ; "'..,,, """
-14-
Threat to Public Health
Hazardous substances found in the paint sludge area at the Spiegelberg site
pose a potential threat to public health and the environment. The major
potential pathway of exposure is ingestion of contaminated drinking water.
Although contamination has not been detected in residential wells, hazardous
substances, whose origin can be attributable to the paint sludge area, have
been detected in downgradient monitoring wells. Among the contaminants found
in the paint sludge area, the high concentrations of water-soluble compounds
such as ketones, monocyc1ic aromatics and chlorinated aliphatics detected in
subsurface soils and wastes have a strong potential to migrate into the
groundwater. The mobility characteristics of these contaminants indicate
that exposure via ingestion of contaminated groundwater is possible.
Domestic uses of the groundwater (showers, cooking, etc.) may also constitute
a significant route of exposure.
Direct contact with soils is considered a minor potential threat under existing
conditions as surface soils are not appreciably contaminated. Disturbance of
the surface soil will increase concentrations to a significant degree and
increase the potential for direct human contact. Mining activities
or other means of soil disturbance would increase the probability of direct
exposure to hazardous constituents.
In order to determi ne action 1 eve1 s .or target ri sk concentrations for residual
contaminants remaining in soils and groundwater after remediation, a Vertical
Horizontal Spread (VHS) model and a Diffusion model were used. Spicer Road,
the northernmost boundary of the site, was used as a receptor location.
To determine subsurface soil concentrations associated with a particular risk
level at a groundwater receptor location, target risk levels associated with
exposure to acceptable concentrations at the receptor location must be determined.
Ranges of total carcinogenic risk of 1 x 10-4, 1 x 10-6, and 1 x 10-7 were
considered for the groundwater (see Table 6). For noncarcinogenic compounds,
relevant standards~ criteria, or guidelines were selected as target exposure
concentrations. Health Advisories, ADls, RMCLs, or AWQC were selected as
target exposure concentrations (whichever value is lower). Target concentra-
tions that are below relevant standards or criteria were also considered (lCF,
1985). These results are shown in Table 7.
The Diffusion Model was used to determine the action levels of soil con tam i- .
nants that will achieve the target groundwater concentrations discussed above
and presented in Table 6 and 7 because it is more conservative than the VHS
model. Tables 8 and 9 present these action levels. Excavation of contaminated
soils to these concentrations will result in residual risks that correspond
to the selected target risk levels. A carcinogenic risk of 1 x 10-6 was
selected as the goal for the level of clean-up at the Spiegelberg site. 50i1
concentration targets are below guidelines as these are calculated to
consider additive effects associated with exposure to mUltiple compounds.
-------
Comoound
chloroform
methylene chloride
1,1,2,2-tetrachloroethene
tetrachloroethene
trichloroethene
n-n itroso di ph enyl ami ne
gamma-SHC
chlordane
'. ,,:'. '::', '~":.: ,-~ .. ~. . ..'
heptachlor
Notes: (1)
(2)
(3)
(4)
(5)
. . ..'. ~ ~{:-.'.': :~:~. . :;'~'.~.:~..":; r:~}~~';':: -~.~: ~;:"'~'.-:::1:,,'~.?~:'~-:.-1.~~;./i': S;:'~:':-h;"~';:?-:>;~:L:~~-}\,/.-~;::';....:.~i.zL~~-~1:.r:.o'.~~.3 ~:~~:~J:.:1A'~ .~" .:."::~ ~'~':;~.: .~: .....~:::.,.-'.'::/:.:;.::~.:-~..;;.::.'. ::-. :.:'-.. .
TABLE
o
TARGET GROUNDWATER CONCENTRATIONS ASSOCIATED
WITH TOTAL CARCINOGENIC RISK ESTIMATES
SPIEGELBERG SITE
Total
Carcinogenic
Risk of
1x10-4
( llc/l}(1)
Total
Carcinogenic
Risk 01
1x10-6
( '.jQ/I}(2)
Total
Carcinogenic
Risk 01
1x10-7
( II Q/I}(3)
4.4
46.6
1.75
5.8
29
71
0.26
0.21
0.10
0.044
0.466
0.0175
0,058
0.29
0.71
2.63x10-3
2.17x10-3
1.0x10-3
0.0044
0.0466
0.00175
0.0058
0.029
0.071
2.63x 10-4
2.17x10-4
1.0x10-4
Corresponds to a target risk level of 1x10-5 for each individual
compound.
Corresponds to a target risk level of 1x10-7 for each individual
compound.
Corresponds to a target risk level of 1x10-8 for each individual
compound.
Calculations are limited to those compounds for which an evaluation
has been conducted by the EPA Carcinogenic Assessment Group.
Calculations assume a 70 kg man ingests 2 liters of water a day over
a lifetime,
15
-------
TABLE 7
TARGET GROUNDWATER CONCEN-."RATIONS FOR NONCARCINOGENS
SPIEGELBERG SITE
Target Target
Concentrations that Concentrations Balow
Correspond to Guidelines or
Guidelines or Criteria Criteria(4)
Compound ( u a/I) ( u a/I)
acetone 100,000(1) 7,692
- '.J~.;.,niJij", :.GC~"', U...
1,1-dichloroethane 4,050(1) 312
ethyl benzene 680(6) 52.3
4-methyl-2-pentanon9 3,550( 1) 273
toluene 2.000(6) 154
1,1,1 -trichloroethane 200(6) 15.4
xylenes 440(6) 33.8
di-n-butyl phthalato 44,000( 1 ) 3,385
di-ethyl phthalate 440,000(1) 33,846
naphthalene 9,000(1) 692
styrene 140(6) 10.3
Notes:
(1)
(2)
(3)
(4)
(6)
Acceptable Daily Intake (AD I)
Lifetime Health Advisory
Ambient Water Quality Criteria (AWQC)
Calculated bV dividing the guideline or criteria by 13
(13 . n + 1; where n . the number of compounds in the mixture)
Proposed Recommended Maximum Concentration Levels (RMCLs)
16
-------
, '-i'.... Ao..;. ~.--~ ~.
-- ...... -..-. .
:'''''~''' . ~
..._......_~..;....
~''''''''' ." ,-
~ ..'~~---
-... -
T ADLE 9
SOIL ACTION LEVELS Fon PAINT SLUDGE AREA hlo/kO)
OIFFUSION MOOEl
KNOWN OR SUSPECTED CARCINOGENS
SPIEGELDERG SITE
1 JC 10-4 Risk level 1 K 10-6 Risk Level 1 K 10-7 Risk level Paint Sludge Area
Contaminant Average Mm
-------
-19-
Alternative Evaluation
A Phased Feasibility Study (PFS) of proposed remedial actions for the Spiegel-
berg site was completed by NUS Corporation and submitted for public review
and comment on September 8. 1986. This is a State-lead operable unit project.
being conducted through a cooperative agreement with the State of Michigan
Department of Natural Resources. The following site-specific goal was developed
as a result of the study.
10.
1 Oa.
o
Reduce or eliminate the source of contaminates leaching into the
groundwater. Ten remedial action alternatives were developed based
on this goal and in accordance with the NCP. The alternatives are:
1.
2.
No Action
Soil Cap
3.
Soil Cap with Bentonite
Multimedia (RCRA) Cap
4.
5.
Excavation/Onsite Landfill Disposal
6.
Excavation/Offsite RCRA Landfill Disposal
7 .
8.
Excavation/Separation of Wastes/Offsite Landfill Disposal
Excavation/Mobile Onsite Incineration/Offsite Landfill Disposal
9.
Excavation/Offsite Incineration at Baton Rouge. Louisiana
Excavation/Offsite Incineration at Sauget, 1llinois
9a.
Excavation/Offsite Incineration at Baton
Rouge. Louisiana/Offsite Landfill
Excavation/Offsite Incineration of Hazardous Wastes at Sauget.
Illinois/Landfill of Non-Hazardous Materials
The alternatives were screened for technical feasibility. environmental and
public health concerns. institutional considerations and costs. The technical
evaluation includes performance. reliability. implementability. and safety.
-------
-20-
A lternat i ve 1:
No Action
The no action alternative is required by the NCP to evaluate the impact of
not performing remedial action at the site. The no action alternative would
not require any work to be done. This alternative would not protect public
health and the environment because it would not address the existing environ-
mental degradation or potential groundwater contamination which may result
from continued releases of contaminants. The alternative would not meet any
applicable federal, state, or local requirements.
Cost for Alternative 1- No Action
Capi tal
Annua 1 O&M
Present Worth
N/A
N/A
N/A
Alternative "2:
Soil Cap
A soil cap covering about one-half acre, would consist of approximately 12
inches of a compacted natural soil and 6 inches of a topsoil capable of support-
ing vegetation. A soil cover would be permeable and although vertical infiltra-
tion through the sludge may be reduced, it would not be eliminated, therefore
the cap would not provide adequate protection to public health and the environ-
ment. Since waste materials are left on the site, a surface cap would retard,
but not prevent further pollution migration to the adjacent subsurface soils.
The underlying aquifer would still be at risk since contaminant migration
from the paint $ludge to the groundwater would not be completely remediated.
In addition, if the soil cover is disturbed and the wastes are excavated
at some future time, adverse health conditions could occur through direct
contact. Institutional controls may be required to prevent exposure.
A soil cover is easily implemented and would take about
tion. Annual inspection is recommended, and occasional
may be required. The soil cap would have a finite life
require perpetual maintenance4
3 months for construc-
repair and revegetation
span, and would
The soil cap alternative would not meet federal RCRA requirements, but could
be in compliance with CERCLA. This alternative may not be in compliance with
Michigan Acts 245 and 127, since it does not prevent further degradation of
the envi ronment.
Act 245 states that the groundwater quality will be maintained and provides
for the IInondegradation" of the groundwaters. Degradation is defined as a
change in groundwater quality from local background conditions. Any onsite
alternative which does not totally stop infiltration and leaching would not
meet the intent of this law. Action levels would have to be such that the
concentrations remaining would be consistent with the Michigan Water Resource
Commission's IInondegradation policy."
-------
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Act 127 states that no one can pollute, impair, or cause harm to the environment.
MDNR will determine whether action levels selected are consistent with the Act.
Since this land is privately owned, this action may also require purchasing
and/or condemning the site in an effort to assure that the landowner will not
damage or disrupt the soil-covered area.
Cost for Alternative 2:
Soil Cap
Capital
Annual O&M
Present Worth
$33,000
1,400 (yrs 1-30)
46,000
Alternative 3:
Soil Cap with Bentonite
This surface cap consists of 18 inches of locally available sand with an
additive of dry bentonite tilled or harrowed into the top 12 to 14 inches to
try to achieve a permeability of less than 10-7 centimeters/second (em/sec).
A 6-inch layer of topsoil would be placed on top of the 18-inch base, and
proper vegetation would be established. This is a proven technology for
reducing infiltration; however, the structural integrity of the cap cannot
be guaranteed. Construction would take about 6 months. Although this cap
would be more effective in reducing infiltration than the natural soils. cap,
all the concerns associated with alternative 2 are applicable to this
alternative. This cap is not as effective as the RCRA designed cap, which
offers greater assurance of structural integrity.
Cost of Alternative 3: Soil Cap with Bentonite
Capi tal
Annual O&M
Present Worth
$99,000
1,400 (yrs 1-30)
112,000
Alternative 4: Multimedia (RCRA) Cap
The purpose of a multimedia cap is to minimize vertical infiltration through
the waste which results in generation of contamination in the underlying
groundwaters. A multimedia (RCRA) type cap would include a 2-foot compacted
clay layer (permeability < 10-7 em/sec) and a 30 mil synthetic liner, which
provides a cap of low permeability. Additionally, the RCRA cap would minimize
the risk of dermal contact and migration of contaminated materials.
It is expected that capping the site with a low permeability cap would signifi-
cantly reduce but not prevent vertical infiltration and subsequent groundwater
contamination. The amount of infiltration protection provided by a multimedia
cap is much greater than that provided by a soil cap; however, materials remai~ing
in the paint sludge area will continue to degrade and have adverse effects on
the surrounding environment.
A RCRA cap is a proven technology. Contruction is expected to take about 9 months.
Periodic inspection and maintenance of the cap will be required. A multimedia
cap has a finite life span, and would require perpetual maintenance. Eventually,
replacement of the cap may be required.
-------
-Lt-
This alternative could comply with CERCLA but will not comply with RCRA if
the wastes lie less than 5 feet above the groundwater. Pilot testing will be
done to confirm the location of the wastes.
Cost for Alternative 4: Multimedia (RCRA) Cap
Capital
Annual O&M
Present Worth
$154,000
1,400 (yrs 1-30)
167,000
Alternative 5: Excavation/Onsite Landfill Disposal
This alternative would require the excavation of approximately 15,000 cubic yards
of paint sludge and contaminated soil and final disposal of this material in
a newly constructed, onsite RCRA type landfill. The liquid paints would require
solidification prior to placement in the landfill which could include mixing
with lime or f1yash type materials. All material contaminated in excess of
the proposed action levels of 1x10-6 risk level will be excavated. Field
screening will be required to determine when target levels have been achieved.
Excavation is a standard technology which can be implemented using common
construction equipment and procedures. The construction and closure should
be completed within 1 year providing technical criteria for permits can be
met.
The high concentrations of volatile organic contaminants in the paint sludge
area suggest a potential for significant releases of these volatiles to
ambient air during excavation, creating an adverse impact to the public health.
Temporary noise could also have an adverse impact.
The landfill will require regular inspection, maintenance, and groundwater
monitoring through its projected life to insure its integrity. Groundwater
monitoring is required in accordance with RCRA regulations.
This alternative is expected to meet all applicable federal requirements in
regard to soil remediation and source control; however, the Michigan Solid
Waste Management Act 641 regulations are more stringent than federal RCRA
standards. Under Section R229.6415 of the Michigan Hazardous Waste Management
Act, Requirement (3) states that a landfill shall not be located in an area
where there are less than 6 meters of soil with a permeability of 1x10-6 em/see
or less, immediately below. and lateral to the liner. In addition, Michigan
regulations require 5 feet of compacted clay in the landfill liner and cap.
It is not certain what the depth of the base of comtamination is but it is known
to be uneven. The PFS estimates that the base of the paint sludge waste lies
5 to 7 feet above the water table.
Due to the sandy nature of the soil at the site and the lack of a
substantial thickness of natural clay or equivalent beneath the disposed
wastes, it is unlikely the Spiegelberg site can meet the above technical
requirements of Act 64.
-------
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-23-
Although the U.S. Environmental Protection Agency does not require permitting
on Superfund sites, remedies are expected to meet the intent of permit require-
ments. The Michigan Department of Natural Resources will require an Act 641
permit, which the State of Michigan will issue, before this alternative can
be impl emented.
Cost for Alternative 5: Excavation/Onsite Landfill Disposal
Present Worth
$1 ,893,000
32,300 (yr - 1)
18,800 (yrs 2 - 5)
10,900 (yrs 6-30)
2,039,000
Capital
Annua 1 O&M
Alternative 6: Excavation/Offsite Landfill Disposal
This alternative would require the excavation of approximately 15,000 cubic
yards of paint sludge and contaminated soil, and final disposal of this material
in an offsite RCRA landfill. Materials would be removed to the soil action
levels, which would eliminate the possibility of future environmental degra-
dation from this source at the site, making it a reliable option. The remediated
area would be backfilled with locally available soil and revegetated~ The
CECOS International hazardous waste landfill in Cincinnati, Ohio was identified
as being a possible disposal site. It is in compliance with RCRA and is
currently in compliance with the U.S. EPA offsite policy. CECOS is approximately
400 miles from the Spiegelberg site.
The adverse impacts are the same as those for alternative S. In addition, a
possible hazard would exist in the event of an accident during transporta-
tion. Federal Department of Transportation (DOT) Hazardous Materials Trans-
portation Rules must be observed.
The alternative would fulfill applicable federal and state standards and
regulations with regard to source control and soil remediation under the
current CERCLA law.
Cost for Alternative 6: Excavation/Offsite Disposal
Capital
Annua 1 O&M
Present Worth
$10,925,000
NA
10,925,000
Alternative 7: Excavation/Separation of Wastes/Offsite Landfill Disposal
This alternative differs from alternative 6 in that the wastes are separated
according to hazardous or nonhazardous materials based on RCRA characteris-
tics. RCRA characteristics are EP toxicity, corrosivity, ignitability, and
reactivity. However, CERCLA wastes are not determined solely based on
RCRA characteristics, but also on whether they have hazardous constitutents.
-------
-24-
The solid wastes at the site have not been proven to be free of hazardous
constitutents, therefore this alternative will not be considered further.
The costs are presented for the purpose of comparison.
Cost of Alternative 7: Excavation/Separation
of Wastes/Offsite Landfill Disposal
Capital
Annua 1 O&M
Present Worth
$7,530,000
NA
7,530,000
Alternative 8: Evaluation of Excavation/Onsite Mobile Incineration/Offsite
Flnal Dlsposal
This incineration alternative provides for the excavation and onsite destruction
of the volatile organic compounds present in the paint sludge area. Since
incineration does not destroy metals, the ash residue from the incinerator
will probably contain heavy metal compounds at concentrations that would
require disposal in a landfill that is in canpliance with RCRA and the offsite
policy. For costing purposes, it was assumed that the ash residue would be
transported and disposed of at CECOS Landfill in Cincinnati, Ohio.
Since a relatively large, flat area is required to setup and operate a
mobile incineration system, extensive grading and site preparation would
be necessary. In addition to the space required for the portable trailers,
haul roads, and access roads would be constructed, as well as areas for
stockpiling of the waste and the ash residue. A supply of fuel, industrial
electric power, and boiler grade water supply would also be required.
In conjunction with the incineration technology, the site remediation rate
would be limited by the capacity of the i~cinerator. The initiation of site
clean-up will be dependent on the availability of a mobile incinerator, as
there are only a limited number of approved units available. Due to the high
costs associated with mobilization, site preparation, and permitting, this
alternative with a capital cost of $43,091,000 is not cost effective for the
amount of material to be incinerated. Only 15,000 cubic yards of wastes are
estimated for this site.
Incineration of paint waste materials is an acceptable and proven technology.
Mobile incinerators have been proven as effective methods for destroying
hazardous, combustible materials. The rate at which the wastes are incin-
erated can be determined only after more tests on the materials and/or the
performance of a test burn.
It is estimated the alternative will take 2 years to canplete including site
restoration. Materials will be excavated that exceed the action level criteria.
This alternative would reduce continued degradation of the underlying ground-
waters by removing the source of contamination, thereby protecting public health
and the envi ronment; however i-t is ant; ci pated that the technical requi rements
of the regulations will cause implementation of this alternative to be very
difficult and time consuming.
-------
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The technical requirements of the Federal Clean Air Act, the Michigan Air
Pollution Act, and the Michigan Hazardous Waste Act (Act 64) must be met
in order to implement the onsite incineration. Act 64 involves extensive
state permitting. The scrubbers should provide flue gases which meet applicable
air quality standards. The alternative is expected to meet all applicable
federal and state requi renents in regard to source control. If the ash
residue is transported to an offsite facility, hazardous materials transport
regulations must be met.
Cost for Alternative 8:
Di sposal
Capi tal
Annual O&M
Present Worth
Alternatives 9, 9a:
Excavation/Onsite Mobile Incineration/Offsite Final
$43,091,000
NA
43,091,000
Excavation/Offsite Incineration
This alternative addresses the excavation of 15,000 cubic yards of waste
material and incineration of that material at an offsite canmercial incineration
facility. The difference between 9 and 9a is the offsite location of the
incinerator. The waste materials would be excavated, packaged in 30-gallon
fiber or plastic drums, and transported by truck to a licensed. canmercial
incinerator. The selection of an incineration facility would be governed by
the capacity and backlog of the available incinerator and by compliance with
the U.S. EPA offsite policy.
Two incineration services were evaluated: Rollins Environmental Services,
Inc.. a large incineration service in Baton Rouge, Louisiana and Trade Waste
Incineration, a small incinerator in Sauget, Illinois. It is necessary to
eval-ute both options because the small incinerator will have less capacity
and may not be able to handle the large volume of material to be incinerated.
Although the larger incinerator will have greater transportation costs, it
has a large available capacity and would be able to accept the waste in one
batch.
This alternative is expected to meet all applicable federal and state require-
ments. By taking the material to a permitted, offsite facility the cost as
well as the time frame for implementation would be greatly decreased from
onsite tncineration. Hazardous materials transport regulations must be met
for the transport of the material to the incineration site. The alternative
is considered a permanent source control measure. providing the most effective
protection for public health and the environment.
Cost for Alternative 9. 9a:
Excavation/Offsite Incineration
Baton Rouge. Louisiana
Capi tal
Annual ° & M
Present Worth
Sauget, Illinois
Capi tal
Annual ° & M
Present Worth
$32,016,000
NA
$32 ;616 ,000
$28,817.000
NA
$28.817.000
-------
-26-
Alternative 10, lOa:
Excavation/Offsite Incineration/Offsite Landfill
This alternative will excavate the 15,000 cubic yards of contaminated material
and separate it into the liquid waste mixture and the solidified paint sludges.
The liquid material will be incinerated and the solidified paint sludges will
be di sposed of in a RCRA landfill. The difference between alternative 10
and lOa is the disposal location.
The incineration sites are the same as alternative 9, and the RCRA facility
is the same as alternative 6. It is estimated that one-third of the wastes
or 5,000 cubic yards will be incinerated, and 10,000 cubic yards will be
1andfi11ed in a RCRA landfill. The excavated area will be backfilled and
revegetated. Maintenance would be minimal.
This alternative would meet all applicable federal and state requirements.
As in alternative 9, hazardous materials transport regulations must be met
for the transport of the material to the disposal site.
The alternative is a permanent source control measure providing adequate
protection to public health and the environment.
Cost for Alternative 10, lOa:
Excavation/Offsite Incineration/Offsite Landfill
Baton Rouge, Louisiana
Cincinnati, Ohio
Capi tal
Annual O&M
Present Wprth
$18,395,000
NA
18,395,000
Sauget, Illinois
Cincinnati, Ohio
Capi tal
Annual O&M
Present Worth
$15,771 ,000
NA
15,771,000
Consistency with Other Environmental Laws
There are several laws and policies that address proposed actions at the
Spiegelberg site. The no action alternative would not be in compliance with
any federal or state regul ations. The soil cap alternatives would not meet
federal RCRA requirements. The RCRA cap would comply with RCRA if the base
of the wastes lies 5 feet or more above the groundwater. Alternatives 2, 3 and
4 may not be in compliance with Michigan Acts 245 and 127 since they do not
prevent further degradation of the environment. Act 245 establishes ground-
water quality and Act 127 states no one shall pollute, impair or cause harm
to the environment. Since the liquid wastes would remain in the ground with
the potenti a1 to further contami nate the"groundwater, the MDNR could determi ne
the above alternatives do not meet the standards of these acts.
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-27-
Alternatives 6, 8, 9 and 10 will fulfill all federal regulations. Alter-
native 5, Onsite Landfill, should meet federal and state Regulations regarding
protection of public health and the environment even though a permit may not
be required. Meeting the Michigan technical requirements may be difficult
and time consuming. Alternative 7, Separation of Wastes/Offsite Landfill
Disposal, has been el iminated since it does not meet the requirements for the
handling of CERCLA wastes.
Selection Process
The primary threat from the paint sludge area to public health is by ingestion
of contaminated groundwater. There is a potential for continued migration
from the source of contamination downward into the drinking water source.
The no action alternative would do nothing to reduce or eliminate the source
of leaching into the groundwater. In addition, it would not meet any federal
and state regul at ions. For these reasons ,alternati ve 1 was el iminated.
Surface capping is a technology used to reduce infiltration from precipitation,
thus reducing leaking of contaminants from the wastes and into the underlying
aquifer. The cap alternatives 2, 3, and 4 provide different levels of protect-
ion, the RCRA cap being the most protective. Although capping retards infilt-
ration, it does not remove the source of contamination. Hazardous wastes
will continue to degrade and have adverse effects on the surrounding environ-
ment. Caps have a finite life span and require perpetual maintenance and
eventual repl acement. If the cap is di sturbed and wastes are excavated at
some time in the future, there is a potential for adverse health impacts.
This is of special concern at Spiegelberg as quarrying operations are current-
ly being conducted on the property. In addition, the capping alternatives
would not meet federal and state regulations. The cost of the caps range
from $33,000 to $154,000. See Table 10 for a summary of cost for all the
alternatives considered. Construction time for capping is from 3 to 9 months
depending on the type of cap.
Alternatives 5 and 6 evaluate onsite and offsite RCRA landfill disposal.
Landfills designed in accordance with appropriate RCRA requirements are
standard disposal alternatives and are considered effective in containing the
waste. The onsite landfill would meet federal requirements and construction
normally would take about 1 year; however, meeting the technical requirements
of Michigan regulations would greatly increase the time required for implemen-
tation. It is unlikely that this site can meet the technical requirements of
Act 64 for the location of an onsite landfill due to the absence of under-
lying layers of natural clays of the appropriate depth and thickness. The
cost of this alternative is $1,893,000. The offsite RCRA landfill would meet
federal and state requirements. Although a RCRA landfill is a proven and
acceptable technology, it does not provide destruction of contaminated waste
and does not provide protection to the general public health and the environment
that incineration provides. In addition to destructive technology, incineration
does not rely on limited RCRA landfill capacity. Also the Land Disposal Ban
demonstrates agency trend toward permanent remedies. Congress has made it
clear to the cleanup programs that in the future, alternative technologies
will be strongly encouraged, to remediate hazardous wastes. The cost for
offsite RCRA landfill disposal is $10,925,000. .
-------
TADLE 10
COST SUMMARY FOR ALTERNATIVES
CAPITAL. O&M. AND PHESENT WOnTI-I COSTS
SPIEGELDERG SITE
Remedial ..ctlon Altornatlve
Capital
1.
No action
2.
Soil cap
33,000
3.
Soil cap with ae :llives (bentonite)
99,000
4.
Multimedia (RCr~) c~p
154,000
5.
Excavation/OnsH,~ landfill Disposal
1,893,000
6.
Excavation/OffsH.. landfill Disposal
,10,925,000
7.
Excavation/Sepe::ltlon of Wastos/Offslte
landlill Disposa~
7,530,000
8.
Excavation/OnsE) Mobile Incineration/Off site
Final Disposul c.:: l\sh Residue
43,091,000
9.
Excavation/OffsL:, Incineration at
Oalon Rouge, lc' .;siana
32,016,000
!la.
Excavation/Offsit ; Incineration at
Sau{)el, Illinois
28,817,000
10.
\::):cLlviJtion/O(f; ;itc Incinerution at
1~ILon I~Oll'::I(~, Ir.nisiuniJ/Offsite Landfill
l)iSIX)~;(11 at Ci';cinnati, Ohio
18,395,000
Wa. l::Xc~v~tion/Of:[:.:;itc Incineration at
S,"llQrt-, 111 i n()~ ~/(\ffsi ''(~ f.Hnofi 1]
15677],000
Annual O&M
1,400 (Vrs 1-30)
1,400 (Vrs 1-30)
1,400 (Vrs 1-30)
32,300 (Vr 1)
18,800 (Yrs 2-5)
10,900 (Yrs 6-30)
Present Worth
,
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46,000
112,000
167,000
2,039,000
v
,
10,925,000
c'
~:
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7,530,000
"
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43,091,000
32,016,000
28,817 ,000
f-
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18,395,000
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15,771,000
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-------
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The remaining alternatives include incineration or a combination of incineration
and land filling. Incineration provides for the destruction of volatile
organic compounds. The ash residue may require landfilling in a RCRA licensed
landfill. Incineration is expected to meet all federal and state regulations.
Meeting the technical requirements of the necessary regulations will cause
implementation of onsite incineration to be very difficult and time consuming.
Onsite incineration would cost $43,091,000. Offsite incineration would greatly
reduce the cost and the time frame for implementation by reducing the technical
requirements. The cost of offsite incineration is $28,817,000 - $32,016,000,
depending on location of the incineration site.
The offsite incineration and land filling alternative separates the waste into
liquid wastes and solidified paint sludges. The solidified paint sludges
would be land filled in a RCRA landfill. This would greatly reduce the cost
of total incineration and still provide protection to the public health and
the environment. Depending on the location of the disposal sites this alter-
native will cost from $15,771,000 - $18,395,000.
Recommended Alternative
The National Oil and Hazardous Substances Contingency Plan (NCP) [40 CFR Part
300.68(i)] states that the appropriate extent of remedy shall be determined
by the lead agency.s selection of the remedial measure which the agency
determines is cost-effective and protects public health. Based on the
evaluation of the cost and effectiveness of each proposed alternative, the
comments received from the public and "the MDNR, the following alternative has
been determined to be cost-effective as
defined by the NCP.
Alternative 10:
Excavation/Offsite Incineration/Landfill
The recommended action is considered a source. control operable unit remedial
measure as defined in section 300.68(e) of the NCP. The objective of the
action is to remove the source of continued contaminant migration from the
site. This alternative includes excavation of 15,000 cubic yards of waste
material and separating it into liquid sludges and paint residue with garbage
intermixed, and solid paint sludges. It is estimated there are about 5,000
cubic yards of the combined material which will be incinerated and 10,000
cubic yards of solid paint sludge which will be landfilled in a RCRA licensed
landfill. The material will be transported to the incineration site and the
landfill site by truck. The length of time to complete this alternative is
governed by the size and location of the disposal sites; however, it is
expected to take less time than onsite incineration. Alternative 10 is the
most cost-effective alternative that will provide adequate protection to
public health and the environment.
The capital cost of this alternative is approximately $15,771,000 to $18,395,000
depending on the disposal location. The State of Michigan agrees to contribute
ten percent of the source control operable unit costs.
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-30-
Operation and Maintenance
There are no operation and maintenance requirements associated with this remedy
for the operable unit. O&M needs for the final remedy will be evaluated at
the conclusion of the RIfFS.
Community Relations
A public comment period was held from September 8 to September 29. Copies of
the PFS were made available to the public for review. The Hamburg Township
Library and the Brighton City Library served as the repositories. The MDNR
issued a press release in the Ann Arbor News and the Brighton Argus announcing
the dates of the public comment period. A progress report was sent to notify
the public of the public meeting and the alternatives under consideration for
t hi s remedy.
The public meeting was held at the Hamburg Township Fire Hall on September
15, 1986. Approximately 40 people were in attendance including rep~esent-
atives from MDNR, U.S.EPA, NUS contractors, and local officials.
The citizens took an active role in the meeting. Their main concern was the
potential for their drinking water to become contaminated and any further
environmental destruction from the hazardous mat~rial. The public is anxious
for the clean-up to begin and is concerned about funding. Another issue
raised was the effect of the site on their property value. An open forum was
held on September 24th to give citizens an opportunity to ask more questions.
Responses to written comments are in the attached Responsiveness Summary.
Enforcement
A responsible party search at the Spiegelberg site was completed in August 1983.
James Spiegelberg, the property owner~ does not have any written records of
the waste disposal practices on his property; however, interviews with him
revealed that municipal wastes were accepted at the site as well as paint
sl udges from Ford Motor Company. Other indi vidual s identi fi ed as possi b 1 e
sources of information at the site were Douglas and Homer Rasmussen, owners
of adjacent property, and Al Pearson, a waste hauler. Accordingly, U.S. EPA
sent notice letters on December 12, 1985 to: Douglas and Homer Rasmussen,
James Spiegelberg, Al Pearson and Ford Motor Company.
Although Ford I s search of its record-s reveal ed no evidence of the di sposal of
paint sludges at the Spiegelberg property, Al Pearson was able to provide the
Agency with documentation of his agreement with Ford to dispose of paint sludges.
In addition, he provided a description of his disposal practices which entailed
the hauling of paint sludges to the Spiegelberg property from the Ford Wayne
Truck assembly plant.
Another potentially responsible party identified early in the search was
Burton Chemical Company, which allegedly dumped liquid wastes at the site in
1973. Effo rts to locate the company in surroundi ng towns have been fruit-
less, and none of the notice letter recipients had any additional information
concerning this company.
"
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-31-
Ford Motor Company has requested meetings with EPA to discuss the remedy
selected at this site. A meeting was held in Chicago on August 27, 1986
wherein Ford challenged findings in the Phased Feasibility Study. Additional
negotiations are anticipated to extend past the date of the actual signing of
the Record of Decision.
Schedule
Approve Remedial Action
9/30/86
11/25/86
Complete Enforcement Negotiations
Award Cooperative Agreement RD/RA
12/02/86
12/02/86
Start Des; gn
Camp 1 ete Des i gn
10/01/87
10/01/87
Start Construction
Complete Construction
6/30/89
The current schedule will be effective if funds are available for this site
pending reauthorization of Superfund. If funds are not available, a new
schedule will be developed.
Futu re Act ion
The RI/FS addressing the final remedy, is currently being prepared. A response
for the remediation of the groundwater will be analyzed. The RI/FS is expected
:t{) b.e canple.ted in March 1987.
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Spiegelberg Phased Feasibility Study
Responsiveness Summary
I nt roduct i on
A public comment period was in effect from September 8. 1986 until
September 29. 1986 to provide for public review of a Phased Feasibility
Study (FS) for the Spiegelberg Landfill Superfund site. The PFS had been
prepared to evaluate information on a paint sludge trench on the Spiegelberg
property and to propose contamination control or clean-up options that could
be performed as an operable unit prior to the competion of the full Remedial
Investigation/Feasibility Study. Copies of the Phased Feasibility Study were
available for public review at the Hamburg Township Library and a public
meeting was on September 15. 1986. The meeting was conducted to give staff
from the Michigan Department of Natural Resources and the U.S. Environmental
Protection Agency the opportunity to explain the PFS to local residents and
other interested parties. and th answer questions and receive comments.
This responsiveness summary outlines comments and questions posed at the
public meeting. comments received in writing. and agency responses.
Background
The Spiegelberg Superfund site and the adjacent Rasussen Landfill site are
located on Spicer Road about 1/2 mile west of U.S. 23 in Green Oak Township
of Livingston County. Both sites are listed on the National Priority List
for the federal Superfund program and on the State 1 i st of sites of env; ron-
mental contamination promulgated under the Michigan Environmental Response
Act.
Gravel mining has been practiced at the Spiegelberg site since before 1940.
As early as 1966 there is documentation that a portion of the property was
being used for disposal of waste materials. Both domestic and industrial
wastes. including liquid wastes. were disposed of at the site at least until
1977.
Site investigation work has revealed groundwater contamination under the
site. Test pitting operations were conducted in areas of the site where
buried wastes were suspected. The test pitting revealed the presence of
paint wastes in solidified and unsolidtfied form.
A Phased Feasibility Study is a method of expediting control of cleanup for a
portion of a contamination site. A PFS may be performed in instances where a
source of contamination has been identified and for whi~h enough information
exists to permit the evaluation and selection of appropriate remedial measures.
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-2-
Following a PFS, remedial measures can be implemented prior to the completion
of the full-scale RI/FS. The PFS was undertaken for the paint sludge area on
the Spiegelberg site in order to determine means to eliminate it as a source
of further groundwater contamination.
'"
The draft PFS evaluated twelve different remedial strategies. While the
report did not identify a recommended or preferred solution, DNR and EPA
staff explained at the meeting that a tentative staff position favors excavation
of wastes with off-site disposal either through incineration or combination
incineration and RCRA landfilling.
Comments and Responses
The comments made on behalf of Ford Motor Company by Steven C. Nadeau have been
reviewed. The major technical concerns articulated therein are: 1) the paint
sludges at the site do not pose a substantial threat to human health and the
environment; 2) the selection of an offsite remedy is not justified; and 3) the
selected remedy for this operable unit is not cost-effective. Generally, Ford
Motor Company feels that the data collected at the site is inadequate to support
the Agency's selected remedy and consequently has asked that the administrative
record be held open until November 1, 1986 for the submission of additional
information that is currently being collected and evaluated. The Agency has
agreed to do so.
Based on information collected during the RIfFS, the Agency has confidence in
its conclusion that the surficial aquifer at the site is contaminated and that
the paint sludge disposal area is a source for that contamination. The decision
to proceed with a source control operable unit was based on the desirability of
reducing additional groundwater contamination by removing a known source. Such
an approach to source control is acknowledged in the NCP at ~300.68(c) and can
be implemented if cost-effective and consistent with a permanent remedy at the
si tee
It is the opinion of USEPA and MDNR after reviewing data relating to waste
characterization and site hydrogeology that an onsite remedy at this particular
site is not feasible for these types of wastes. Therefore, the offsite remedy
selected is considered appropriate and cost-effective.
Finally, in its formal comments on the PFS, Ford repeats its objections to the
public comment period of September 8-29, 1986. Since Ford received a copy of
the PFS on September 8, 1986, and submitted its comments to the Agency on
September 29, 1986, it had a full 21 days in which to formulate its comments.
Insofar as additional information was collected by the State and also collected
through Ford's own field tests during the 21 day public comment period, the
Agency has agreed to review comments and/or the results of Ford's analyses up
until November 1, 1986. The information will be evaluated and a determination
made whether it justifies a reconsideration of the Record of Decision at that
time.
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-3-
Additional comments were submitted on behalf of Ford by O'Brien and Gere
Engineering, Inc.
Major concerns are:
o
Comment: The lack of documentation for numerous statements and conclusions
made within the draft PFS, as they pertain to the geology of the site and the
investigations conducted to date. The failure to provide raw and interpreted
field data with the draft PFS rendered the validity of the statements made
within the document impossible to evaluate adequately.
Response: O'Brien and Gere Engineers, Inc., have received, through their
Freedom of Information Act (FOIA) request all materials MDNR used to arrive
at their conclusions, including the following: Well logs, CLP data, well
locations, draft hydrogeological technical memorandum study, soil gas reports,
onsite daily logs, and correspondence between the contractor and MDNR reviewing
the above information. In addition, the PFS report was not intended to
contain information that generally belongs in the Remedial Investigation
Report.
Comment: Failure to take into account the solidified nature of the paint
sludge when estimating the volume of leachate generated by infiltration
through the waste materials, and failure to take into account the solidified
nature of the paint sludge when estimating the concentration and chemical
composition of leachate generated through contact of aqueous infiltration
with the waste materials.
Resronse: In estimating the volume, concentration and chemical composition
of eachate generated by infiltration through the waste materials, contaminant
characteristics such as solubility and mobility, rather than waste character-
istics, were taken into account because hazardous constituents present
in the waste were detected in the downgradient monitoring wells. The test
pitting effort conducted by MDNR indicated that the solidified paint sludge
is interspersed with semi-solid, sludge-like and liquid waste materials.
This would make it difficult, and probably invalid, to assume that the volume,
concentration and chemical concentration of leachate would be reduced or
altered because of the presence of solidified materials. In addition, only
limited information was available about the solidified materials. Accordingly,
we used "worst-case" assumptions. Extensive sampling and analysis of this
material would need to be undertaken in order for us to establish that the
type and amount of leachate would be appreciably reduced because of the waste
characteristics. Leachability will be addressed during the pre-design
phase.
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-4-
Res~onse: The two generic analytic groundwater models were not meant to
deflne the potential plumes emanating from the site. These two models were
used to generate information necesssary to support and aid in the performance
of the risk assessment. Because of the very nature of risk assessments. the
information generated from the models are based on a worst-case scenario, and
therefore. are conservative.
For these models. the assumptions used were based on
minimum value for a given input variable which would
scenario. or if there were sufficient data to make a
then a realistic value would be used.
either the maximum or
result in a worst case
realistic assumption.
A number of the specific technical comments questioned the validity of our
assumptions. Assumptions are based on the worst case scenario. The Agency
believes that predictions which were identified by the commenter as over-
estimated are realistic when considering the worst-case scenario. Risk
assessment and analysis. by their nature, require conservative information to
produce conservative conclusions necessary to protect human health and the
environment.
With regard to the remedial action, the information gained by the model
supports the need for source control. Under the worst case scenarios, a
potential receptor at Spicer Road would incur a health risk in the future
without a remedial action. A source control remedial action would remove the
source of contamination which should reduce the level of risk in the future
to potential receptors by preventing further release of contaminants and
thereby limiting extent of future groundwater remediations.
The models were not meant to defi"e the groundwater contamination plume at
the site. Plume definition will occur in future phases of the remedial
investigation. At that time, additional information regarding the geological
and hydrogeological conditions of the site can be obtained, analyzed, and
incorporated into a more complex, site specific plume modelling effort.
Comment: The absence of field data in the draft PFS for groundwater conditions
in the shallow aquifer directly downgradient to the waste materials. Data
generated by O'Brien and Gere from wells installed on September 18 and 19
indicate that, with the exception of approximately 10 ug/1 of 1.1 ,1-trich10r-
oethane, groundwater at tne~e locations is free from contamination predicted by
the models.
Response: Although it is recognized that additional data would increase the
certainty of the conclusions drawn, the absence of this information does not
prohibit the determination of a potential release to the environment.
Upon receipt of information provided by O'Brien and Gere Engineers Inc., on
or before November 1.1986. we will review and evaluate this information to
determine whether it justifies a reconsideration of the Record of Decision at
that time.
~
Comment: The absence of a description of the levels of precision associated
with the concentrations of groundwater residues predicted by the models and
the absence of an estimate of the width and areal extent of the plume predicted
to occur at Spicer Road based on the model output.
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-5-
u
Response: It is not the intent of the model to provide minute precision or
boundanes of a plume, nor is it required by the NCP. Rather, it is intended
to present potential future risks to receptors.
Comment: Inappropriate presentati on and use of the" hi gh" and "average"
residue concentrations. Misrepresentations of the paint sludge residues as
soils residuevalues in table C-l. Both considerations result in an overestimate
of leachate and groundwater residue prediction, which ultimately result in an
overstatement of human health risks associated with the paint sludge disposal
a rea.
Response: The Public Health Assessment for Spiegelberg was prepared according
to guidance contained in the Endangerment Assessment Handbook, August 1985.
Groundwater models utilizing "high" and "average" contaminant concentrations
to predict both maximum and average contaminant releases are standard in
Public Health Assessments. By using this approach we are able to develop a
range of actual and potential public health risks. The conservative risk
estimate is necessary to compensate for uncertainties in sampling and analyses,
groundwater models, unknown health effects of complex mixtures of contami-
nants, and sensitive subgroups in the population.
Comment:
Inadequate documentation of the domestic use exposure scenario.
Response: Consistent with U.S. EPA Endangerment Assessment Guidance, the
domestice use exposure scenario was based on standardized assessment procedures,
established in the endangerment handbook USEPA April 1985f. Methods for
Assessing Ex,osures to Chemical Substances, Volume 2. EPA 560/5-85-002, U.S.
Environmenta Protection Agency, Washington, D.C. This reference is sited
in the PFS.
Comment: No presentation of the incremental reduction in risk when comparing
the feasible remedicAl scenarios.
Response: We are not required by the NCP to present incremental reductions
in risk for each alternative evaluated by the PFS. Instead each alternative
is compared to the base-line no action alternative where risks have been
identified in the Public Health Assessment. The selected alternative in
accordance with the NCP is a "cost-effective remedial alternative that
effectively mitigates And minimizes threats to and provides adequate protection
of public health and welfare and the environment [40 CFR 300.68(i)].
Comments received from interested citizens are addressed as follows:
Comment: It is the feel ing of three canmenters that the material at the site
is not hazardous and money should not be spent to remove it.- In addition it.
was suggested if there is any hazardous material present, its removal would
cause more ground and air contamination.
Response: Selection of the No Action alternative will not prevent future
degradation of the groundwater which has been identified as a potential
pathway for human exposure by the risk assessment. The threatened aquifer is
currently being used as a primary drinking water supply.
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-6-
Comment: Several commenters indicated a sense of relief that on-site remedies
were not being recommended. Given that staff positions at the meeting were
only tentative, one person asked whether or not further public comment would
be sought if, through the review process, anyon-site remedy became favored.
Response: EPA and MDNR staff positions favor excavation with off-site disposal.
The U.S. EPA Regional Administrator, who must sign a Record of Decision
authorizing the remedial measures to be employed, has the authority to concur
or not concur with staff level recommendations. If a significant change in
the favored alternative occurs during the review process, public comment will
aga i n be sought.
Comment: While on-site incineration doesn't appear to be cost-effective as a
means of disposing of paint sludge trench wastes alone, this option might
be cost-effective and the most appropriate course of action if all wastes at
both Spiegelberg and Rasmussen sites were considered together.
Response: The Phased Feasibility Study approach does limit the range of
potential alternatives because of the need to focus on only a portion of the
wastes and contaminants present at a site. However, any remedy resulting
from a PFS must be consistent with final remedial actions at the site. This,
of course, requires that professional staff make judgments as to what final
remedies might be. DNR and EPA staff feel that excavation and off-site
disposal will be most consistent with final site remedies at the Spiegelberg
site.
Comment: The PFS should investigate more closely the provision of alternate
water supply to nearby residents. The provision of an alternative water
supply would eliminate the major potential source of exposure documented in
the PFS, so that a lesser degree of cleanup at a lower cost may be acceptable.
Such a course of action would also help to reduce the stigma that the community
feels and help to maintain property values. The provision of an alternate
water supply should be priced out in combination with some at the less costly
clean-up methods.
Res~onse: The PFS addresses one source of groundwater contamination. Both public
hea th and environmental resources need to be addressed by the remedy selected.
The feasibility study for the remainder of the two sites will address the
issue of groundwater contamination, and at that time provision of alternate
water supply will be more .closely examined.
Comment: Concerns were expressed over local groundwater contamination.
Have contaminants traveled as far as Spicer Road? Are the contaminants found
traceable to the paint sludge trench?
Response: Contaminants have been found north of the paint sludge trench as far
as Spicer Road. While the contaminants found in monitor wells north of the
paint sludge trench have been also found in the trench itself, current
information is not sufficient to assume that the trench is the only source.
DNR staff will install several additional monitor wells to fill in remaining
gaps in data.
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-7 -
Comment: What is the policy for testing private wells in the area. Commenter
Hid i cated he has just buil t a house 1 ess than 1/2 mi 1 e from the si te and
would like to have his well tested.
()
Response: The Livingston County Health Department, in conjunction with the Michigan
Department of Public Health, has implemented a regular well testing program for
homes ~thin 1/2 mile of the site. The testing program has involved collecting
samples from a portion of the homes each quarter, so that each home is tested
once a year. This program is considered quite adequate for monitoring the
quality of private drinking water supplies. To date, no contaminants have
been found in any private wells. DNR staff have notified Livingston County Health
Department about the new home within the 1/2 mile testing radius.
Comment: The endangerment assessment discussion points out the fact that we-
do not know what cumulative health effects will result from exposure to a
variety of chemicals present in the groundwater at the site.
Response: This is indeed true. The potential health effects from chronic
exposure to a single chemical is only poorly understood. There have been even
fewer studies and thus even less is understood about the cumulative impact of
exposure to a combination of chemicals.
Comment: Why is gravel mining still underway at the Spiegelberg site? Isn1t
there the potential for spreading contaminants through the mining and sale of
gravel?
Response: Citizens first expressed these concerns in 1984. While Mr. Rasmussen
has voluntarily ceased hauling from his property~ Mr. Spiegelberg has maintained
a gravel mining and hauling business. DNR staff has tested gravel for contaminants
form the mining area, from on-site stockpiles, and from area roadways where
travel had been used. The most recent gravel testing took place in winter of
1986. To date, the test results have shown the gravel to be clean. Gravel is
not being excavated from the paint sludge area or other areas where waste
material is suspected.
J
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