United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Responae
EPA/flOO/ROS-87/052
September 1987
Superfund
Record of Decision:
Rose Township, Ml
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TECHNICAL REPORT DATA
(rum ftta liuovetion on iht rtvtrtt btfon committing)
1. REPORT NO.
BPA/ROD/R05-87/052
SUPERFUND RECORD OF DECISION
2.
Rose Township, MI
First Remedial Action - Final
7. AUTHORISE ~~~
9. PE RPORMING ORGANIZATION NAMI AND ADDRESS
U.S. Environmental Protectior
401 M Street, S.W.
Washington, D.C. 20460
IS. SUPPLEMENTARY NOTIS
> Agency
3. RECIPIENT'S ACCESSION NO. '
September 30, 1987
6. PERFORMING ORGANIZATION CODE
S. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM BL*MBNfNO. ~
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
The Rose Township Dump site is located in rural Rose Township, Oakland County,
Michigan. The 110-acre site comprises an upland area almost completely surrounded by
wetlands, with an abundance of wildlife onsite. From 1966 to 1968 an unknown number of
drums containing solvents, paint sludges and PCBs were buried in a 12-acre portion of
the site. Bulk wastes were also discharged to the surface or into shallow lagoons or
pits in. the area. In June 1979, the Michigan Department of Natural Resources (MDNR)
:ested domestic wells in the area and found low level TCE and PCE contamination. This
contamination made it necessary to supply bottled water to residents. Based on 1979
drum sampling results, funds were appropriated for an immediate removal action, which
disposed of over 5,000 drums offsite. Further testing between 1980 and 1982 indicated
the presence of organic chemical contamination in the ground water. Currently, the
primary contaminants of concern affecting the soil and ground water include: VOCs,
?AHs, PCBs, organics and inorganics.
The selected remedial action includes: excavation of as much as 50,000 yd3 of
contaminated soil; onsite thermal destruction of contaminants in the excavated soil with
disposal of resultant ash (either onsite or offsite depending on the results of EP
toxicity testing); ground water pump and treatment using chemical coagulation, air
(See Attached Sheet)
17.
t. DESCRIPTORS
KEY WORDS AND DOCUMENT ANALYSIS
((.IDENTIFIERS/OPEN ENDED TERMS
Record of Decision
Rose Township, MI
First Remedial Action - Final
Contaminated Media: soil, gw
Key contaminants: organics, PAHs, PCBs,
inorganics, VOCs
IS. DISTRIBUTION STATEMENT
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131
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?:SSi»«S^gt&3*J^^i5^ ^Vtf^»VV'^.t-vVv
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EPA/ROD/R05-87/052
Rose Township, MI
First Remedial Action - Final
16. ABSTRACT (continued)
stripping and activated carbon adsorption with discharge to an appropriate
place. The estimated capital cost for this remedial action is $32,547,000
with annual O&M of $200,000 for years 0-10 and $70,000 for years 11-30.
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Record of Decision
Remedial Alternative Selection
for:
Rose Township - Demode Road Site
Oakland County, Michigan
PURPOSE
This decision document represents the selected remedial action for the Rose
Township site. It was developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and to the extent
practicable, The National Contingency Plan (40 CFR Part 300) of 1985.
The State of Michigan has concurred on the selected remedy, as stated in the
attached Letter of Concurrence.
BASIS
The selection of remedy is based upon the Rose Township Site Administrative
Record. The attached index identifies the items which comprise this record.
DESCRIPTION OF SELECTED REMEDY
The remedy selected is a final remedial action. It consists of the excavation
of as much as 50,000 cubic yards of contaminated soil, onsite thermal destruction
of the organic contaminants in this soil, and the disposal of the resultant ash
as appropriate. Depending on the results of EP toxicity testing, the ash may
either be backfilled onsite (if passing), treated to remove Teachable lead and
backfilled onsite (if not-passing), or placed in an off-site Resource Conservation
and Recovery Act (RCRA) permitted, double-lined landfill facility (if not-passing).
The remedy also consists of the extraction of contaminated ground water, treatment
by chemical coagulation, air stripping, and activated carbon adsorption, and
discharge of the treated water in an appropriate manner. If the treated water
does not exceed Ambient Water Quality Criteria (AWQC) for organic and inorganic
chemicals, it will be discharged into the adjacent marsh.
DECLARATIONS
The selected remedy is protective of human health and the environment, attains
Federal and State requirements that are applicable or relevant and appropriate,
and is cost-effective. As mandated by CERCLA as amended by SARA, The remedy
satisfies the preference for treatment that reduces toxicity, mobility, or volume
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-2-
of waste as a principal element. Finally, I have determined that this remedy
utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable.
In the event that, during the remedial design investigations on the Rose site
waste, it is discovered that the cost of thermal destruction exceeds the cost
estimate in the Feasibility Study by 50% or that thermal destruction will not
be necessary to permanently treat the entire estimated volume of wastes, I will
reconsider the Record of Decision to determine if the selected alternative
still represents the cost-effective remedy and take appropriate action at that
time. The State of Michigan will be consulted in the event that I reconsider
my decision.
Date . r Valdas V. Adamkus
Regional Administrator
U.S. EPA, Region V
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ADMINISTRATIVE RECORD INDEX: ROSE TOWNSHIP DUMP
Title/Subject
A. .1979 Removal Records
B. MDNR Investigation Report
C. Phase I Hydrogeologic
Investigation Data
D. Site Visit Report and
File Chronology
E. Groundwater Contamination
Study (Phase II Hydrogeo-
logic Study)
F. Preliminary Assessment
Report
G. Site Inspection Report
H. Hazardous Ranking
Scoring Package
I. U.S. EPA Notice Letters
J. 1983 Removal Documents
K. Remedial Action Master
Plan
L. Response to Information
Request
M. Rose Township Safety
Plan
M. Work Plan foe Remedial
Investigation/Feasibility
Study
0. Work Plan Addendum
p. Work Plan Addendum
Q. Sampling Study Plan
R. Task 13 Work Plan
Site Investigation
No. of
Author Date Pages
MDNR 1979/1980 approx 2 feet
Wm Murphy 1979 21
MDNR 10/81 35
CH2M Hill 12/21/82 7
MDNR
MDNR
1/28/83 82
U.S. EPA 1/20/83 4
CH2M Hill 9/3/82 14
U.S.. EPA 7/19/82 79
*
II. 3. EPA 10/26/82 14
MDNR 1/83 approx 6 inches
Ch2M Hill 4/4/83 140
Chrysler 7/21/83 28
Corp.
3/22/84 105
E.G. Jordan 4/84 85
E.G. Jordan 4/27/84 2
MDNR 5/4/84 1
MDNR 7/3/84 6
E.G. Jordan 3/85 27
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-2-
MDNR
MDNR
E.G. Jordan 8/86
Title/Subject Author
S. Work Plan Amendment
T. Safety Plan Amendment
U. Supplemental Work Plan
for Remedial Investi-
gation/Feasibility Study
V. Supplemental Work plan
for Revised Risk
Assessment
W. Trip Report
AA. Quality Assurance
project Plan
BB. Community Relations Plan
CC. RI/FS progress Report
DO. preinvestigative Evalu-
ation
EE. QA/QC'd raw data and
Chain of Custody Forms
FF. Action Memorandum U.S. EPA
GG. Information Request U.S. EPA
to Herman Anchill
HH. Response to Information
Request
II. OSC Report Outline for Roy F.
November, 1985 Removal Weston
Action
JJ. 1985 Removal Documents U.S. EPA
KK. Letters Concerning Ralph
November, 1985 Removal Dollhopf
Action
LL. Manufacturers Information Shirco
on Thermal Destruction infrared
Systems
No.
Date
4/29/86
6/19/86
10
2
77
E.G. Jordan 1/15/87 5
U.S. EPA 3/9/84 1
E.G. Jordan 5/84 124
E.G. Jordan 7/18/84 43
E.G. Jordan 9/84 ' 122
E.G. Jordan 9/84 7
E.G. Jordan 1984/1987 approx. 10
file drawers
11/13/85 4
5/8/86 3
H. Anchill 5/21/86 2
11/86
11/85-
8/86
45
approx
2 feet
11/20/85 14
Undated 23
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-3-
Title/Subject
MM Site Program Description
of Technology
NN. U.S. EPA
Meeting Notes
00. Letter to Steve Luzkow
Author
Shirco
Infrared
Kevin
Adler
Shirco
Infrared
Systems, Inc
Date
No. of
Pages
7/15/86 4
3/19/87 2
4/7/87 14
pp.
QQ.
RR.
SS.
TT.
uu.
w.
ww.
AAA.
BBB.
CCC.
DDD.
Final Remedial Investi-
gation/Feasibility Study
Public Notice of Comple-
tion of the Remedial
Investigation/Feasibility
Study Report
Progress Report
Feasibility Study Fact
Sheet
Site Program Fact Sheet
U.S. EPA Correspondence
Concerning Completion
of RI/FS
Transcript of Public
Meeting
Demonstration Plan for
Rose Township Site
Guidance on Remedial
Investigations Under
CERCLA
Guidance on Feasibility
Studies Under CERCLA
Superfund Public Health
Evaluation Manual
Interim Guidance on
MDNR
MDNR
MDNR
MDNR
MDNR
U.S. EPA
MDNR
Shirco
Infrared
Systems
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
6/87
6/87
6/22/87
6/22/87
6/22/87
6/25/87
7/1/87
7/87
6/85
6/85
10/86
12/24/86
234
1
2
5
4
11
14
91
170
178
228
11
Superfund Selection of
Remedy
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-4-
Title/Subject Author
EEE. Letter to James Florio
FFF. Additional Interim
.Guidance for FY '87
Records of Decision
GGG. Meeting Notes for
July 17, 1987 PRP
Meeting
HHH. Meeting Notes from
August 3^ 1987 PRP
Meeting
III. Public Comments on
RI/FS
JJJ. Meeting Notes for
September 3, 1987
PRP Meeting
KKK. Meeting Notes for
September 3, 1987
PRP Meeting
LLL. MDNR Interoffice
Memorandum
MMM. Meeting Notes for
September 15, 1987
PRP Meeting
NNN. Meeting- Notes for
September 15, 1987
PRP Meeting
Date
Lee Thomas 5/21/87
U.S. EPA 7/24/87
Brad
Vanman
000. MDNR Interoffice Robert
Memorandum Hayes
» *
PPP. MDNR Interoffice Robert
Memorandum Hayes
QQQ. Record of Decision U.S. EPA
and Responsiveness
Summary
No. of
Pages
5
6
U.S. EPA 7/17/87 17
U.S. EPA 8/3/87
PRP Group 8/11/87 327
U.S. EPA 9/3/87
PRP Group 9/3/87
9/10/87 4
U.S. EPA 9/15/87 7
PRP Group 9/15/87 5
9/16/87 5
9/16/87 10
9/30/87 175
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
ROSE TOWNSHIP DUMP
I. Site Location and Description
--The Rose Township Dump site is located on Demode Road in rural Rose
Township, Oakland County, Michigan (Figure 1). Located approximately
one mile west of the town of Rose Center, the 110 acre site comprises
an upland area which is almost completely surrounded by wetlands.
The southern periphery of the site is heavily wooded with hardwoods.
The middle portion, a rolling meadowland, is bordered by a marsh to
the west and the northeast and Demode Road to the north. There is an
abundance of wildlife onsite, as evidenced by an actual siting of deer
during a site' inspection in September 1986.
The population of Rose Township was estimated to be 4,560 in July of 1984.
Adjacent to the site, a sparse population is located next to several small
lakes. Although entrance to the Rose site is restricted, onsite activities
which increase risk of exposure to contamination presently include hunting,
snowmobiling, and riding all-terrain vehicles (ATVS). In addition, inspection
walks occur along the natural gas pipeline easement which is present in the
most heavily contaminated area. The two most heavily contaminated areas onsite
were fenced as part of an emergency removal action in 1985. However, a large
hole in one of the fences offers mute testimony to continued site access.
An examination of aerial photographs reveal that a portion of the Rose
site land was farmed through the late 1950's. In the 1960's, farming
was-abandoned and illegal waste disposal began. The operators placed an
estimated 5,000 drums of waste consisting of solvents, paints, and PCBs
upon and into 12 acres in the southwest part of the site. Another portion
of the site was contaminated by lead battery sludges. There are two ground
water contaminant plumes onsite. In the north is a plume consisting mainly
of vinyl chloride, and in the southwest part of the site is a plume consisting
of vinyl chloride, xylene, toluene, benzene, and several other chemicals of
concern. The northern plume threatens to contaminate nearby domestic
wells. One well is located only 1,600 feet away from the site.
II. Site History
A. Previous Investigations
The following is a chronology of events related to the Rose site:
0 From 1966 to 1968 an unknown number of drums of wastes
which included solvents, paint sludges, and PCBs were
burled in a 12 acre portion of the site. Bulk wastes
(including the above) were also discharged to the surface
or into shallow lagoons or pits in the area.
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'. , " .-Regulator sp."
\ j . / ' 'v Station^---
I 4000 FEET
LEGEND
, APPROXIMATE WETLAND BOUNDARY (FROM NATIONAL
WETLANDS INVENTORY MAP)
CiS,? WFEHHED WETLAND BOUNDARY
*" WATEB
STREAM CHANNEL ' _ _
FIGURE 1
NOTE: SITE LOCATION
UPLAND AREAS ARE UNSHADED ROSE TOWNSHIP-DEMODE ROAD SITE
ECJORDANCQ
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The Oakland County Health Department (OCHD) was notified of
illegal dumping at the site in 1968. A subsequent court
action ordered a site cleanup by the waste hauler. In 1969,
an adjacent landowner sued the waste hauler and the Rose
site landowner, demanding that the site be cleaned up. No
apparent cleanup occurred at either time.
Rose Township also brought suit against the waste hauler and
property owner in 1971 to force the dumping to-cease and to
initiate a cleanup. Dumping finally ceased and some unspecified
cleanup action was reportedly undertaken.
The Michigan Department of Natural Resources (MDNR) was notified
of the existence of the site by the OCHD in April 1979. The MDNR
surveyed the area and identified approximately 1,500 drums.
Although some drums were partially'buried, most had been left on
the siirface. A majority of the drums were either leaking or were
bulging due to expansion of contents.
A search warrant, obtained in June of 1979, allowed the drums to
be sampled to identify their contents. PCBs, phthalates, organic
solvents, oil and grease, phenols, and heavy metals (especially
lead and chromium) were found to be present.
Coincident with the drum sampling in June of 1979, the MDNR tested
domestic wells in the area. Apparent low level contamination
consisting of trichloroethylene (TCE) and perchloroethylene (PCE)
in the wells made it necessary to supply bottled water to residents.
However, in mid-1980, a second round of sampling indicated no
contamination existed and the bottled water program was discontinued.
Based on the 1979 drum sampling results, a Toxic Substance Emergency
was declared by the Michigan Toxic Substance Control Commission.
Funds were appropriated for an immediate removal action and for
a study to determine the nature and extent of contamination onsite.
By July of 1980, when the removal action was completed, over 5,000
drums had been removed from the site.
Spring, 1980 saw the beginning of a hydrogeologic study onsite.
The MDNR installed nine monitoring wells and sampled soils. Completed
in 1981, this initial investigation indicated that organic chemical
contamination extended below the shallowest aquifer and that additional
soil samples and monitoring wells would be needed to further define the
horizontal and vertical distribution of chemicals.
MDNR directed the next phase of investigation in 1982. Intending
to define geology, to determine the vertical extent of contamination,
and to determine and profile the existence of deeper aquifers,
the State's contractor installed an additional 13 monitoring wells
and performed numerous soil-test borings. The additional data
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still failed to provide conclusive information regarding ground
water flow direction and distribution of contamination.
0 The Rose site was placed on the National Priorities List in 1982.
0 Federal funds were available in June of 1983 to perform a Remedial
Investigation (RI) and Feasibility Study (FS). E.G. Jordan Co.
(Jordan) was contracted to assess (1) physiographic site con-
ditions, (2) chemical contaminant distribution, and (3) resultant
health and/or environmental risks associated with the contami-
nation. The data from previous investigations and from this phase
provided the information necessary to perform the FS.
B. Current Site Status
The Remedial Investigation/Feasibility Study (RI/FS) of the Rose Site
was begun in February 1984. In late 1984, the following activities
occurred onsite:
0 installation of 19 monitoring wells at 11 locations;
0 ground water sampling of the 19 new monitoring wells,.
the 22 existing monitoring wells, and 11 domestic wells;
0 composite surface soil sampling on a grid in the southwestern
portion of the site, and collection of 50 soil grab samples from
locations throughout the site;
0 soil borings and associated sampling of subsurface soils;
0 magnetometer and resistivity surveys; and
0 air quality analysis.
In 1985 a test-pitting program was undertaken to determine the nature
and quantity of buried metallic objects associated with eight magnetic
anomalies found beneath the drum storage area onsite. Additionally,
three soil borings were collected and one monitoring well was installed
to investigate the newly discovered northern vinyl chloride ground
water plume. A second sampling grid was constructed in this area and
composite surface soil samples were taken. Soil samples were taken
from the test pits and the 10 northern area wells were sampled as well.
In the Summer of 1986, seven additional monitoring wells ("DNR" series-see
Figure 4) were installed to further define the ground water plume boundaries
onsite. Sampling of all 49 wells occurred in the Fall.
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Site Characterization
The result of the previously mentioned investigations indicates that the
Rose site ground water, surface soils, subsurface soils, and the adjacent
wetlands are contaminated with toxic chemicals. The following sections
will address each area of concern:
1. - Ground water
a. Introduction: Hydrogeology, Hydrology
The Oakland County area is underlain by bedrock at depths of
200-300 feet. Composed mostly of shales and sandstone, the
bedrock is overlain by complex stratified glacial deposits
(Figure 2). The site itself is located-on a morainal ridge,
which-is surrounded by glacial outwash deposits. As seen in
Figure 2, a 40-120 foot thick sand unit exists beneath the site.
This is the most permeable of the site soils. The hydraulic
conductivity is on the order of 10-3 cm/sec. The underlying till
has an estimated hydraulic conductivity of 10~7 cm/sec and is
expected to serve as the lower hydraulic boundary. In the lower .
wetlands areas and upon the adjacent slopes, the sand aquifer is
overlain by lacustrine clay (Figure 2), which results in localized
confined conditions in the sand aquifer.
The residents in the site vicinity utilize glacial drift aquifers
for domestic water supplies. Numerous domestic wells are located
in these aquifers, as shown in Figure 3. Sampled domestic wells
are labeled "DW". Providing moderate to high yields of water,
the local wells range from 24 to 330 feet deep and average 100
feet in depth. Approximately six miles north of the Rose site
is the community of Holly, the closest municipal water supply.
Holly also utilizes a glacial drift aquifer source.
The regional ground water flow gradient in the vicinity of the
site is to the north and northwest. Superimposed upon the regional
flow is the local recharge system and shallow ground water flow.
Following the contour of the land surface, a mounding effect
occurs on the ground water levels during recharge conditions^
(Figure 4). This mounding effect flattens out during limited
recharge conditions^ (Figure 5). Overall, flow locally is to
the north. During recharge conditions, however, flow occurs in a
radial manner, from the top of the mound, outward. Estimated flow
rates range from five feet/year in the southwest plume area to 8-21
feet/year in the northern plume area. However, the rate may be ten
times higher in the confined aquifer area and where local permeability
is much greater.
generally late fall and early spring
2generally late spring through early fall, and mid winter
&5&*X^*c-?:^
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SOUTH
LEGEND
111
PROFILE A-A
NOTES
IfrMUOW KMM iOCATDM
onoM or matmA
««'<*"**»"'*»»
^MM 1 "to*«H» wnH OKOIOQC moru c-c
I^LJ«^^I «« « t
- voncMor CICMMIIM
WW1OM). AWI, m»tO
w?'
JM.KWM
tnwios
MU MilMO
MlO
Ml
M>
to net M
tO (IltM
IM U1CA
*o m HI
t« nine
MfUllAS
10 tf 1 M*
M Ull*
IOO FEE 1 IAS
MffCI MC
MlUf (*«
t
MO IMtOG
iu. oofil MMaoMins MO MMsmtTro «*oan« or cor«ci
OAT! MO MTt WITH OQMKl* ***» MO ORAWB
FIGURE 2
INTERPRETIVE GEOLOGIC PROFILE
ROSE TOWNSHP-OEMOO6 ROAD SITE
ECJORDANCQ-
-------
ROSE TOWNSHIP DEMODE ROAD SITE
2000 FEET
UMNO
DW-1 DOMESTIC WELL 3AMPUMQ LOCATION
NOTES
CHEMICAL ANALYSIS OF DOMESTIC Wtl 13
THAT WERE SAMHEO M OCTOBER t»»4
AfK USTEO M APPENDIX O-»
FIGURE 3
DOMESTIC WELL LOCATIONS
ROSE TOWNSHIP-DEMODE ROAD SITE
EC JORDANCQ
-------
J.-.-..-..-. . , '/
:-*;'» ----- -./
;.
. -.. ; V, \JL
UOENO
O MMJITOHMC «CIL CtUSICN
twuMMM Of wtltl IM»C*TfOI
Q WU*ITOHIW6 will lN*t«ll*»KJW
;::.: 1'U KCfH HOAD
on ricnwcTinc mmc( COKTOU*
KlIMTmt n rm. KS1.I
(OASMtO IMrttftt [«lH«r-01.»lrM
I *«r »t-.IS «0*MTOIM*« wttiS *f Hf COMi'iCMO IH IH2
LtVtL CLtVktlOMS UfMUftCD ON II/N/M
MOUMhMTCn *UW»CK «t'f "5
H MTMC CHKMUL*fl SCNLS HMlAt
1*4 till AHOMMSN
rur-i
"ILL KHICMO M CM'IMV 4
-------
V *
I ' ' : ' \ °
Vl ' , : \- » /
l*JM*-- '^ '
- /
: ,-, } f-\ >/ ,1 .
Owx'^"-. . '/ '.- -
" -
. ,v,
«m» mwi inn KIP. mcnxmnt « «uue«i «u>
LCVCL ClIvtTioNS HtMuttCD M l/t/«T.
ntn«fme miMHintii tunnct "t't«5 To Ktr
FIGURE 5
INTERPRETIVE PIEZOMETRIC
SURFACE CONTOUR MAP
LIMITED RECHARGE CONDITIONS
ROSE TOWNSHIP-DEMODE ROAD SITE
ECXiRDANCQ-
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-5-
b. Contamination
A total of 49 monitoring wells has been installed onsite (Figure 4).
Data from 126 ground water samples (including blanks) taken during
two sampling episodes are shown in Tables 1 through 4. .Manganese,
lead, iron, and zinc were consistently detected in the samples (Tables
1 and 2). Barium was found in later samples (Table 2). Aluminum
was also detected, but generally did not exceed the blank values.
Copper, mercury, and arsenic were occasionally found in the samples.
Lead exceeded its Maximum Contaminant Level3 (MCL) at three well
locations in the first round of sampling (RW-7, MW-102I, and MW-
108D) and at one well (RW-7) during the second round (Tables 1 and
2). Arsenic exceeded its MCL in one well in the second round of
sampling (MW-106D).
The levels of zinc, iron, and manganese exceed only the secondary
(aesthetic) standards for drinking water. The zinc and iron may
be derived from the galvanized well casing while the manganese
may be naturally occuring. Barium and copper levels do not exceed
their MCLs. Mercury levels approximate those of blank values,
and thus pose no threat.
No metal exceeded its MCL in domestic well samples.
Two ground water plumes containing organic chemicals exist at the
Rose site. The northern plume consists mainly of vinyl chloride.
The southwestern plume contains toluene, xylene, vinyl chloride,
chlorobenzene, benzene, naphthalene, 1,1,1-trichloroethylene, and
1,1-dichloroethane, as well as other hydrocarbons. The relative
distribution of volatile organic chemicals in the ground water
is shown in Figure 6.
Two northern plume wells, MW-102I and DNR-7, are contaminated with
vinyl chloride, as shown in Tables 3 and 4. Southwest plume well
data are also shown in Tables 3 and 4. Figures 7 and 8 show the
plumes in cross-section. No organic chemicals were detected in
domestic well samples.
2. Soils
Soil sampling at the site consisted of five separate activities
(Figure 9):
3A Maximum Contaminant Level is a promulgated drinking water standard under the
Safe Drinking Water Act. MCLs are based upon consideration of the adverse health
effects of contaminants and are set as close to Maximum Contaminant Level Goals
(MCLGs) as technically feasible. MCLGs are levels at which the contaminants pose
absolutely no risk.
-------
"->---"
X* / *
^^
-:- '' ?i "'/< *"-"'<&
* SIMM iMt iKCc*/m*! ~*~ I V_- _ * r '*
IM iintt IM« iJVioiii/BtrMi V. . > -Or-t
MM ff*lf itM IINM/MNMI X ' M
atOMdCMticTie
J/I
U *o'»t vot'ini
C\ vmn CNIDMM Ktcctip
NO HlftfNM
LI MmfnriOC*mtMfn*fmiCH.»4i*«ufWM«
. J VOlA'Vl MUWCCXMC*lS
*"""* HO lAM^Lt
FIGURE 6
'AREAL DISTRIBUTION OF VOLATILE
ORGANIC CHEMICALS IN GROUNDVWTER ,
ROSE TOWNSHIP-OEMOOE ROAD SITE
ECJORDANOQ
-------
LEGEND
WEST
B
I -
6
I MftU LOCUKM
OtkEHVtD «KIE« Lf VCL (H£ 1 UM.) ON MOvtkUt* ! I
MtU UMfM AMI SAM) B.C.Fll
NOTES
1 3CC »GOC (. IOR L
*MD OWHTATION Of MOf US
it CEOLOCC MKtfU C-C-
Up.. WOMVINt Q*T*WK)M W IO1M. MUtlU OMUMC
* if IWM -
1Q1M. «X»1U OMWMGB M1CCUO
VMTL CM.OMW MUCTCD
. KI-HESCKU nc VCHTCAL oainuuiow or VOLATU
S M ClttUCVMIUI M.ONQ lit AUUM.M1 OF 1 1 £ MOFU
101M VOUklU OMMl«:S DCICCTEO « WL *1 WOIMJQ LOC*HC».S
4. IOUL VOLAlU OROANC CCMCCHltUllONt M
COhKCTLO f 0(4 MClHVLtM. CHOflOt . ACC1ONC, t
rNlHALAlES THAI WCM DElCCtED H IMC S*M^tE
Ttt CHlMlUIKM P*tt SI 4UU Oh T.«i f UUtf b ilCWlt m OM
Tl( BASIS OF A COMPOalL OF IMtOfUlOHV Af**t*JC»u. l-Llall
CUIMCD I I«OM «A»MIt UkltCltO f HOU / i4,«j. io/»t>(CM<
AMD FMM (]» -IOt»M I&ICOMO «V|MT)
KM orrtfi or CM>IO*AIION» MKIM MWM.I Mf MUM* i M
T. IICOHO BAUPLM4 KHMO COMOUCIID ?/)«'» tO'KM
EOLOOiC DC»CIU»f*OHt
101AL VOLAllt OMUNC« MUC'tCO
vmi CM.OMM MIfCICO
f e) MOf MTECIf 0
wm OCCA&ONM MI on GHAVU UMKS
Nut(Soniu> AMI NONbiHAli u> utfosni or
V& AMI St IS Pfttii couou. i. w«i «o Gfwvu.
- --«-
1M.L
PROFILE B
-B'
FIGURE 7
VERTICAL DISTRIBUTION OF
TOTAL VOLATILE ORGANIC CHEMICALS IN SOILS
AND GROUNDWATER AT PROFILES A-A' AND B-B'
ROSE TOWNSHIP-DEMODE ROAD SITE
_ - E.C JORDANCQ -
-------
OUt.W«.)CMMWlM»ra. IMF
jo ins
Bit »VXf9 *- KWlOCAtl
W*MO>
UW 10««. VIM
RW1O
Wtl.lWMOW
0JOO
B7O1
WEST
D
PROFILE D-D- l
EAST
D1
WU1 KAECN MO t
tonx
r*»«rT
JOrETT
CAST
EAST
WEST
, «'0*K
o»«s 'o» ret
OMnr «* f«
a n«9 nxi« <«y«esBni nc VCRTCAL oanvuroN cr VOLATU
~xiw«a w onoiMWATtn ALONO t> ALOACMT or THE ~
>t*l VOLAtU OKUMCS DCnCTfD H «OL AT
AFC
1M. VOLATU
.
T WEKt MtlCTU M IK
AND FROM '?»'» 1Of2/B* (9ECOHD f *EMT>
ff IECOMO *AUn.MO ftOUHD COMOUCTED TM4/M - 1OI I'M.
eV«01M« 9 OAT 1M> »W OJI*
CL*»» « Mit mm ooami*. »AM> AMI OTMA.
RGURE 8
VERTICAL DISTRIBUTION OF
TOTAL VOLATILE ORGANIC CHEMICALS IN SOILS
AND GROUNDWATER AT PROFILES D-D' AND E-E'
ROSE TOWNSHP-OEMODE ROAD STTE
ECJORDANCO-
-------
V : r^$ (*M?^M^ ftl '^lfe,Kfe^fe
. v . r^£\tft^^
S^JL r* ^1^
^m ... ^^ ^i^^ h sMBtf!;-
,r^^
\i-\ ., >-
1;" '. / » '0\' Vxi-'-i: ,\:»)|ui-.'V
// ./. >>L!"*f*s -->(%--A
x_^--
5 r^
^^j .c/
UQENO
MAX | *!C HVEA
A SUHTACC ION. SfpiuCMT S*un.C LOCHiOM
UIP SAMPLE
SUMfACC WA1CN SAMPtC LOCATION
tHALLOV UONlMC. LOCATtON
OftUW flCAVAIMMl tOCAItOM
f" "] COMTOSlIC iOtL SAWLIN6 CRlO
lCAflOM »M*
< coorasiit KM. sutftwc OHIO
SU»F«CC MIL CUM «
-------
-6-
0 A system of 100 ft by 100 ft grids was located in the southwestern
site area and a total of 39 composite samples were collected. (These
grids were located in areas of former waste handling activities.)
0 A total of eight composite and 42 grab samples of surface soils
and sediments was collected in selected site areas and in the
east and west marshes nearby.
0 A total of 77 subsurface soil samples was analyzed from 10
shallow borings (hollow-stem auger) in the southwestern area of the
site. Borings were placed on the basis of the location of former
waste handling activities and ongoing RI activities.
0 Forty-one samples from seven test pits were analyzed for organic and
metals contamination. Locations were selected on the basis of
geophysical investigations performed in 1984.
0 A total of 20 composite surface samples was collected from a
100 ft by 100 ft grid located in the area of MW-102I (northern
plume).
Results of national, site specific background, and site specific contami-
nated soil samples are summarized in Table 5. Metal parameters found to
exceed background levels on a consistent basis are lead and zinc. Metals
found to occasionally exceed background levels are arsenic, antimony,
barium, cobalt, chromium, selenium, silver, and tin. The distribution of
lead correlates with that of other metals, therefore, lead alone has been
used in the discussion of metals contamination. Figure 10 depicts the
distribution of lead in surface soils as determined by the sampling efforts.
High metal values were detected primarily in the southwestern portion of
the site in the area where waste dumping or staging operations are known
to have occurred. .Two widely separated grid sections have lead concentrations
greater than 1000 mg/kg. Two grab samples and ten grid sections have
lead concentrations greater than 100 mg/kg (Figure 10).
Subsurface soil analyses for metals have indicated that (metal) contamination
derived from surface dumping of wastes has not undergone significant transport
to the subsurface. Within the upper one to four feet of soil, lead concentra-
tions dropped below 50 mg/kg. Very few anomalous-levels of metals were detected
in the surface grid sampling area in the vicinity of MW-102.
\
The surface soil distribution of PCBs, shown in Figure 11, is similar to
that of metals (compare to Figure 10). PCB concentrations greater than
10 mg/kg were found in nine southwestern sampling grids. Three of the nine
grids have PCBs in excess of 50 mg/kg. Three test pits (#1,3,5) showed PCBs
in excess of 50 mg/kg, while levels of PCBs in shallow borings were-low.
With the exception of one sample-, no PCBs were detected from the surface
soil grid around MW-102. Test pit data are shown in Table 6.
-------
TABLE 5
ELEMENTAL COMPOSITION OF SOILS
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
ROSE TOWNSHIP-DEMODE ROAD SITE, MICHIGAN
BACKGROUND CONCENTRATIONS OF METALS
IN U.S. SOILS', («g/kg)
BACKGROUND LEVELS IN SOILS AT THE
ROSE TOWNSHIP SITE (ng/fcg)«
MAXIMUM CONCENTRATION OF METALS
IN SURFACE AND SUBSURFACE
SAMPLES AT ROSE TOWNSHIP SITE (nig/kg)
ELEMENT
Aluainua
Antimony
Arsenic
Barium
Berylliiua
Cadaiua
ChroBiun
Cobalt
Copper *
Iron
Lead
Manganese
Mercury
Nickel
Seleoiuai
Silver
Thallium
Tin
Vanadium
Zinc
Al
Sb
As
Ba
Be
Cd
Cr
Co
Cu
Fe
Pb
Ma
Ha
Hi
Se
*
Tl
So
V
Zn
RANGE
70-100.000
0.2-10*
1-50*
15-5.000*
0.01-40
0.01-7
1-15,000*
0-70
< 1-300
100-100,000
2-200*
<1-7,000
0.01-4.6
<5-70
0.1-2*
0.01-5*
0.1-0.8*
2-200*
<7-SOO
<25-2,000
MEDIAN
66.000
1
5
554
6
0.06
53
10
25
25,000
10
560
0.112
20
0.3
0.05
0.2
10
76
54
».
RANGE
0-7455
1.0-13.5
18-87
0-1.0
0-0. 1
4-11.5
0-6.5
. 4-27.5
2854-13,265
4-15
21.5-1179
0-0.1
2.8-13
0-0.1
0-0.7
...
0-6.0
0-16. S
12.5-35
MEAN
4246.2
0
1
!
3.5
42
0.44
0.13
7.7
3.5
12.3
6603
9.5'
313.6
0.02
6.8
0.1
0.1
0
1.0
7-2
23.8
SURFACE*
9765
6.5
148
3010
1.0
8.3
510
148
22,045
31,900
3200
1532
0.19
31
1.9
22
0.9
62
32
2323
SUBSURFACE6
18,000
62
8.6,
82
ND
8.2
107
7.8
109
56,300
1300
656
.45
106
6.5
8.2
HD
35
41
7630
Hotea
'Source for all data except tho§« Barked: Ure, A.M. and H.L. Berrow. 1982. The Element Constituents of Soils In Environmental Cheaistry.
H.J.H. Bowen, ed. 2:94-204.
'Lindsay, Willard L. 1979. Chemical Equilibria in Soils. Wiley Interscleoce. New York. pp. 7-8.
'Bowen, H.J.M. 1982. Environmental Cheaistry. The Royal Soc. of Chemistry. London, pp. 203-204.
-------
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NOTES
i icw cfWUimnieM M MM. MI tirrnnn
W m«/k| OHV wtlCHT
I SOU \»«Kf i wtMC COUtCTCV KtvtCN
niHt «M> xovtust « i»4 r-if^t IT»C n
> ll«O CO*K(N1li*1HM9 SNOW« row FIGURE '0
ton. »»nt> »[! COlltClU « TO iNtKJ
*»«-«. .ro'rz^i ««««««. LEAD CONCENTRATIONS
r.Ttarr.TKi.s1 , r « «:,'^' " IN SURFACE SOIL
Ot* AMA !*' i.i * ^* *** tW'Wm
V, tU .».£., c«mn. .. ROSE TOWNSHIP-OEMODE ROAD SITE
,«t«, MSTW»,5J, Vtl'UV. :.,,... ^r,r^AKI^>^v
E.CJORDANCQ
-------
^v>y mm^lUs^
^fU
^oji^L M^^^^^ML
Lm'n' ~^±'^:'-°*f:'"l" e ' '/' ' ' '' 1^ . i ».M i " =4 I » x I
r ^V
*&^&^~~1 T--V '*.S^NS
^yffi^ ^ f !* /f
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TT«
l-~~~M*f~ A" V -^-»* '. I
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. 43**.,^ si L .^-*'"*' ""'" 4°r
V-%t<^-^ -*-- !-->-«--.--.. i
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n
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tar & ^"^ 7 .*.-*>- ' x
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V 1 / / _T~-~ '
Oi . ^ . . V_J ' ^*~~1 "w>
LEOENO
.. .. .^ . »., MI. A *""" "» » «"""' "*"
t t> flc 10-0. "CO ^ 1UNM« W4TCH S4M*IC LOCATION
^ SH4LLO4I 04HN* IOC4TION
CD 0<*u«l CICAVMION LOCftTION
_ __^ NO MLO» MTICTtON ll»lt
] -\* ~;«NcoiM>onTC iwi »«« IN
!"! yr.7.",it'V!!5t£>4'. .^1^"?' nose TOWNSHIP-
I W.^ffiBSRW.WbSfW^^fc^^0** «-> .
FIGURE //
NTRATIONS
IN SURFACE SOIL
OEMOOE ROAD SITE
E.CJORDANCO. -
-------
-7-
Many surface soil samples showed no detectable levels of volatile organic
compounds (VOCs). Methylene chloride was present in most samples, but
it is suspected that it may be a laboratory contaminant. Phthalates were
present at levels less than 10 mg/kg, with the exception of three samples.
Isolated low levels (<10 mg/kg) of pentachlorophenol, benzoic acid, and
4-methyl phenol were also found.
VOCs and semivolatile organic compounds (SVOCs) were detected in shallow
soil borings and in test pit samples, especially in areas of PCB and
lead contamination. The most common contaminants (and maximum levels
obtained) in soils are toluene (4700 mg/kg), ethylbenzene (430 mg/kg)
chlorobenzene (570 mg/kg), xylene (1400 mg/kg), naphthalene (31 mg/kg),
pentachlorophenol (32 mg/kg), acetone (76 mg/kg), and phthalates (total)
(91 mg/kg). In general, concentrations decreased with depth. However,
high levels (>1000 ug/kg) of total organics were found as deep as 26 feet.
A three-dimensional block diagram depicting VOC concentrations in the
southwestern gridded area of the' site is presented in Figure 12. Concen-
trations of SVOCs, although similar in distribution to the VOCs, are
generally one order of magnitude less (no figure shown, see Table 7
for soils analyses).
3. Wetlands
Two contiguous wetland areas that have been affected by contamination
from site dumping are present at the Rose site (Figure 1). The west
marsh, lying about 150 feet from the main dumping area, is approxi-
mately 140 acres in area. The east marsh, about 600 feet from the
main dumping area, is about 100 acres in area. The marshes are part
of extensive wetlands which drain to Buckhorn Lake.
to evaluate the impact and migration of site-derived chemicals on
the adjacent marshes, a total of nine surface water samples were
collected from both the east and west marsh in addition to a small
stagnant pond about 1/2 mile west of the site. Sediment and seep
samples were collected from drainage pathways and discharge zones
located along the flanks of the site. Results of chemical analyses
are plotted in Figures 10 and 11 (which show lead and PCB values).
The surface water analyses indicate that lead is found uniformly
throughout the wetlands in concentrations of five to six ug/1.
Although these samples slightly exceed the chronic Ambient Water
Quality Criteria4 (AWQC) of 3.2 ug/1, there is no apparent correlation
between site drainages and elevated lead levels. One sample from the
west marsh had a value of 28.6 ug/1 while one sample from the east marsh
showed 17 ug/1. These sample points were not located in primary site
surface water drainages and therefore cannot be directly attributed
to site sources.
The five seep samples were collected from discharges along the northern
and western slopes of the site. Two samples, both of which were from
. seeps discharging into the west marsh, contained trace amounts of organic
chemicals. PCBs were detected in SE-5 (Figure 11) at a concentration
of 2.6 ug/1. SE-3 contained bis(2-ethylhexyl) phthalate at 100
^Ambient Water Quality Criteria, established under the Clean Water Act, are
developed for protection of aquatic life.
-------
QRIOOEO PORTION
OF SITE
10
I.
APPROXIMATE CROUNOVHAIER
SURFACE ELEVATION
LEOENO
t
SHALLOW BOftUia NUHKN
SAMPLE INTtHVAt AND CONCCHTftATION(««A«l
TOTAL CtPTH OF aORINO I FT)
TEST fit NUUOEII
BOTTOM Or TEST f IT
MQTf riOuftE DEPICTS CONCENTRATION IN SOILS AND
' ASSUMES DISTRMUTION IS UNIFORM TMMUOHOUT
OHIO COMPONENT. ACTUAL COMDITIONS MAY VAftV
FROM THOSE SHOWN.
r9] (CONCENTRATION OF VOLATK ORGAMC!
1 1 [CHEMICALS IN SURFACE SOlLSl«qA«) |
lONCENTRATIONSIN EXCESS OF IOOOmj/1,
CONCENTRATIONS IN EICESS OF lOOmjAj
SCALE IN FEET
1100
'200
Uoo
FIGURE I?.
VOLATILE ORQANICS IN SOILS
ECJORDANCQ -
-------
-8-
ug/1. No elevated levels of inorganic chemicals were detected in
the seep samples. The AWQCs for PCBs and bis(2-ethylehexyl) phthalate
are 0.014 ug/1 and 3 ug/1, respectively.
Eight sediment samples were collected from the West and east marsh
areas and an additional ten samples were collected from drainage
pathways related to site source areas. Sediments in the upper portions
of the western drainage pathways contained low level concentrations
of phthalates (<2.5 mg/1) and trace amounts of PCBs (<0.35 mg/kg).
One marsh sediment sample (SE-40, Figure 11) contained PCBs at 0.2
mg/kg. No other organic chemicals were detected in the sediment samples.
III(a). Risks to Receptors
The Endangerment Assessment performed on the Rose site divided the
affected media into separate categories to address the risk to human
health and the environment in an orderly fashion. The following site -
areas were'addressed:
A. Northern Ground Water Plume
B. Southwestern Ground Water Plume
C. Northern Soil Sampling Area
0. Southwest Soil Sampling Area
E. Offsite Marshes
Since the number of chemicals (especially organics) onsite was so large
as to make a risk assessment unwieldly, a screening process was performed
to narrow the list to the most important chemicals of concern. The
Superfund Public Health Evaluation Manual (1986) was used in this process.
Chemicals selected were evaluated on the relative importance of inherent
toxicity, measured concentrations onsite, physical and chemical parameters
related to environmental mobility, and the persistence of each chemical.
Table 8 lists the pared down list of chemicals of concern for the
Rose site.
Potential risks from contaminated sediments and ground waters from the
Rose site are based upon the assumption that the site would be used in
the future for residential development. Two scenarios for risk assessment
were used. These are the "worst-case" and "most-probable" situations.
Worst-case assumes contact with the highest concentration of a given
chemical found onsite. Most-probable assumes contact with an average
concentration of a given chemical onsite. An average concentration
level is calculated for a given chemical by totaling up the reported
concentrations in the samples taken from a given area and dividing by
the total number of samples taken in that area.
Incremental cancer risks for carcinogens and summary hazard risks for
non-carcinogens were calculated for the chemicals of concern. Excess
lifetime cancer risk is defined as the incremental increase in the
probability of getting cancer compared to the probability if no exposure
occurred. For example, a 10"6 excess lifetime cancer risk represents the
exposure that could increase the incidence of cancer by one case per
million people exposed. The practicable target level for cleanup of
carcinogens is an excess lifetime cancer incremental increase of 10~4
to 10'7. Region V policy is to attempt to clean up to a 10~6 incremental
cancer risk level where technically feasible.
-------
TABLE 8
CHEMICALS OF CONCERN
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
ROSE TOWNSHIP - DEMODE ROAD SITE, MICHIGAN
VOLATILE ORGANIC COMPOUNDS (VOCs)
Aromatics
Benzene
Chlorobenzene
Toluene . .
Ketones
2-Butanone
Isophorone
Chlorinated Aliphatics
Methylene chloride
1,1,1-Trichloroetbane
Trichloroethylene
Vinyl Chloride
SEMIVOLATILE ORGANIC COMPOUNDS (SVOCs)
Phthalate Esters
Bis(2-etJiylhexyl)phthalate
Phenols and Acid Extractables
Pentachlo ropheno1
PAHs
Fluoranthene
Naphthalene
PCBs AND PESTICIDES
PCBs
INORGANICS
Arsenic
Lead
1.87.107T
0007.0.0
-------
-9-
Non-carcinogenic risk values are determined by dividing estimated body dose
levels for a given chemical by the relevant Acceptable Chronic Daily Intake
criterion for the chemical. The resulting ratios are summed to determine the
hazard index, or, the total health hazard expected from exposure to more than
a single chemical of concern. Generally, if the risk ratio is less than one,
an insignificant risk is presented by the chemical in question. However,
more specific data need to be considered before dismissing any given hazard
indices as insignificant.
In general, the routes of exposure identified for the various site media are
as follows:
Ground Hater. Exposure to chemical contaminants in ground water may occur
through dermal absorption, through ingestion as drinking water, and through
inhalation of .VOCs while showering or bathing. Dermal absorption and
inhalation of chemicals have not been assessed in the scientific literature
adequately enough to estimate body dose levels for these methods of exposure.
However, when compared to the total body dose of potential ingestion of
ground water, the contribution is estimated to be small for dermal absorption
and inhalation. Accordingly, only "worst-case" and "most-probable" scenarios
for ingestion of contaminated ground water were developed to assess exposure
risks.
Soils. Exposure to contaminated soils onsite may lead to body dose levels
derived from dermal absorption through skin contact with the soils, and
by ingestion of the contaminated soils. However, ingestion was discounted
in relation to soil contact hazards, since ingestion of soil usually occurs.
during early childhood. It was assumed that very young children (less than
three years old) would not have access to contaminated soil areas due to adult
supervision. Data are lacking regarding soil ingestion among adults (although
cobalt has been suggested as another chemical of concern due to ingestion hazards
at the low concentrations which are found onsite).
Marsh soils and surface waters. Similar exposure hazards exist in the
marshes, since access is unrestricted and low levels of contaminants were
found in marsh soils. Only exposure due to dermal absorption of soil
contaminants was estimated, since insufficient information was available
to quantitatively assess the surface water exposure risks. No biological
samples were examined for contaminant concentrations. Thus, risks from the
consumption of wildlife could not be calculated.
Air. There are two routes of possible exposure through the air: (1)
inhalation of fugitive dust, and (2) inhalation of volatile contaminants.
Presently, due to the presence of existing vegetation and lack of excavation
activity onsite, fugitive dust is predicted to be nearly absent and thus
exposure is minimal. The nearest homes downgradient of the prevailing
winds are one mile away and surface volatization of chemicals is expected
to be low. Thus, inhalation exposure is expected to be minimal also.
Future site response activities may enhance both of these exposure routes
and monitoring will need to be implemented accordingly. These potential
effects are evaluated in the developed remedial alternatives discussion
later in this document.
-------
-10-
A. Northern Ground Water Plume. Six chemicals of concern were detected
in the ground water plume located in the northern area of the site.
Although.there is no exposure to the water at this time, these chemicals
presently pose potential risks. Thus, hypothetical exposure5 was assumec
and a risk assessment was performed using the parameters shown in Table 9.
Under realistic lifetime worst-case conditions, lead would pose a signifi-
cant non-carcinogenic risk. Incremental cancer risks exceed 10~4 for
both most-probable and realistic worstcase conditions. At this time,
virtually all the summary incremental cancer risks for ingestion of this
ground water is due to vinyl chloride. Table 10 summarizes the calculated
risk values for the northern plume chemicals of concern.
Future potential risk was estimated for the northern plume by modelling
underground conditions and predicting what chemical concentrations would
be present at the time when the plume reached Demode Road (i.e., offsite,
in an estimated 2 to 250 years). Table 11 presents the parameters used
to estimate the future potential risks. Although most chemicals have
been diluted to negligible levels, vinyl chloride would still be present
in significant quantity to exceed the 10-4 to 10-7 r-js|< range for both the
most-probable and realistic worst-case conditions, at a level about one
order of magnitude lower than under present conditions. Thus, ingestion
of this ground water could continue to pose a health hazard in the
future. For additional discussion of the ground water in the northern
plume, see the MDNR comments in the attached Responsiveness Summary.
B. Southwestern Ground Water Plume.
Fourteen chemicals of concern have been detected in the southwestern
ground water plume. As with the northern plume there is no. current
exposure to this water. Thus, hypothetical exposure5 was assumed to
estimate the risk in ingesting this water. Again, Table 9 presents
the parameters used in performing the risk assessment. Under present
conditions, total non-carcinogenic summary hazard risk ranges from 2.58
to 103 which indicates that further analyses of the effects of each non-
carcinogenic compound is warranted. Chlorobenzene poses the greatest
single noncarcinogenic risk under both most-probable and worst-case
conditions. The summary incremental cancer risks for all carcinogens
is extremely high, ranging from 1 x 10~2 to 7 x 10"1. The highest
risks are posed by PCBs, vinyl chloride, and arsenic under the conditions
used.
Under modelled future conditions (when this plume reaches Demode Road,
I.e., offsite, 1n an estimated 80 to 270 years), the noncarcinogenic
risk levels are less than 1.0. Incremental cancer risks still exceed
the target range (10~4 to 10"7) for vinyl chloride under most probable
conditions, and for vinyl chloride and arsenic under worst-case conditions
(Table 12).
5Hypothetical exposure assumes that a drinking water well would be
installed in the present day center of either plume.
£):i;^
-------
Table 9
Lifetime Ground Water Ingest ion Exposure
(Present Conditions)
Rose Township Site
Chemical
Benzene
Ch 1 oro ben z ene
Isophorone
Methylene Chloride
T'ol uene
1,1,1 trichloro-
ethane
Tr i ch 1 oroet hy 1 ene
Vinyl Chloride
Bis (£-ethylhexyl )
phthal ate
Naphthalene
Pent ach 1 oropheno 1
PCBs
firsenic
Lead
Other Parameters
Years of Exposure:
Most Probabl e Case
Concentration
Southwest North
P 1 urne P 1 urne
4J
94J 0. 8J
c! "~
9J 0. £
667- 1 . 4 J
5£7J
5£J
££ 83J
11 8J
5
0. 04 -
62 -
c! *~
7 7
L i f et i rne
Worst-Case Exposure
Concentration (ug/1)
Southwest North
Plume Plume
170
35OO 10 J
44
500 3
5£000 1 0 J
£OOO
1200
1400 380
47O 65
£10
3 -
4800
1£4
1 50 44
Li fet irne
Rverage Weight over-
Exposure Period:
A m o u r 1 1 of W a t e r
Consumed :
7O kg
£ I/day
7O kq
£ I/day
J = fl D prox i mat e
- = Not detected
-------
Table 10
Summary of Risk Characterization
(Present Conditions)
Rose Township Site
Noncarcinooenic Effects
Medium Exposure Exposed
Route Population
Southwestern Direct Child
Soils Contact
Mult
Northern Direct Child
Soils Contact
Adult
Southwestern Innestion Child
Ground
Uater and
Plume
fldult
Northern Ingest ion Child
Ground
Uater Adult
PI use
Risk Ratio
Significant Most Worst
Chemicals Probable Case
Lead (95*)
Lead <95<) . -
Lead (100»
Lead (95*) :-
Chlorobenzene 1.58
Toluene
1, 1. 1-trichloroethane
Naphthalene
Lead ' -
Lead <8S<) -
Lead (68tt -
21.2
14.1
39.7
21.2
58.8
26
10
1.1
7.1
2.1
2.1
Suiraary Hazard Index
Host worst
Probable Case
0.25 22.2
0.04 . 14.8
0.1 39.8
0.03 26.5
2.58 103.4
0.39 2.39
0.39 12.39
s Less than 0.1
Other Chemicals, Exposure Routes show no significant risk.
*.
Numbers in parentheses represent cereentage of total noncarcinogenic risk contributed by soecific chemicals.
-------
Taoie 10
ry of Sis* Characterization
(Present Cord it ions)
Rose Townsaio Site
Carcinonenic Effects
Exoosure
3oute
Exoosec
Poouiation
Significant
Chemicals
Hazard Index
lost worst
Probaoie Case
Southwestern
Soils
Direct
Contact
Child
Adult
PCBs (77*)
Arsenic (23X)
PCBs (77*)
firsenic (22*)
-7 -V
3 x 10 4 x 10
-» -₯
2 x 10 3 x 10
Soils
Direct
Contact
Child
Adult
-7 -V
firsenic (100*) 2 x 10 2 x 10
Arsenic (100*) 1 x 10 2 x 10
Northern
Srourd
Uater
Pi true
Incest ion
Child
Adult
-3 . -2
Vinyl Chloride 3 x 10 5 x 10
(100*) .3 _^
Vinyl Chloride 5 x 10 5 x 10
(100*)
Southwestern
Ground
Mater
Plume
Incestion
Child
Vinyl Chloride I x 10 7 x 10
(14*)
ftrsenic (10*)
PCBs (75*)
Adult
-2 -i
Vinyl Cnlorice 1 x 10 7 x 1C
Arsenic (10*)
PCBs (75*)
East Marsh
Sed intents
tniia
Adult
-7 'S
Arsenic (100*) 4 x 10 3 x 10
Arsenic (100*) 5 x 10 3 x 10
-S-
west Marsh
Sediments
Child
Adult
-7 -5
Arsenic (100*) 1 x 10 1 x 10
-8 -5
Arsenic (100*) 1 x 10 1 x 10
-------
Table i i
Lifetime Ground water Ingest ion Exposure
(Fut ure Condi t i ons)
Rose Townshio Site
Chemical Most -Probable Case Worst -Case Exoosure
Concentration (ug/'l) Concentration (ug/l>
So
-
Benaene
Ch 1 orobensene
Isophorone
Methylene Chloride
Toluene
1,1,1 trichloro
ethane
Tr i ch 1 or oet hy 1 ene
Vinyl Chloride
Bis (£-ethylhexyl )
oh t halat f?
Naphthalene
Arsenic
Lead
uthwest
Plume
0. £
5. 8
1. 9
*#
81
19
i'O
6
1. 1
O. 38
0. 07
C.
North Southwest
Plume Plume
_ C1
58
19
- **
810
i 9O
90
15 60
11
*"" ii
0. 7
£0
Nort h
PI ume
_
-
-
-
-
-
60
-
~"
r
-
Other Parameters
Years of Exposure:
flverane Weight over
Exposure Period:
firnount of Water
Consumed:
Elaosed time:
Li ret irne
70 kg
£ I/day
£70 years
L i ret i rne
7O kg
£ 1/dav
£70 vears
J = fipproxirnate
- = Not detected
** = Inconsistent plume; could not be accurately calculated
-------
Table 12
Summary of Risk Characterization
(Future Conditions)
Rose Township Site
Noncarcinogenic Effects
Medium Exposure Exposed Significant
Route Population Chenicals
Southwestern Direct Child Chlorobenzene
Soils Contact Toluene
Lead
Adult Chlcrobenzene
Toluene
Lead
Risk Ratio
Most worst
Probable Case
- 14.4
- 3.53
- 5.47
- 9.58
- 2.35
- 3.65
Suanary Hazard Index
Most Uorst
Probable Case
0.1
0.02
£4.0
16.0
= tess than 0.i
Other Cheuicals, Exoosure Routes sho* no significant risk
-------
Table 12
Sunrsary of Risk Characterization
(Future Conditions)
Rose Township Site
Carcifiooemc Effects
Medium
Exposure
Route
Exposed
Peculation
Significant
Chemicals
Sunmary Hazaro Index
Most worst
Probaole . Case
Southwestern Direct
Soils Contact
Child
Adult
PCBs (54*)
Arsenic (46*)
PCBs (54*)
Arsenic
1 x 10 5 x 10
-1 ~S
8 x 10 3 x 10
Northern
Soils
Direct
Contact
Child
Adult
-« -5
Arsenic (100*) 4 x 10 1 x 10
Arsenic (100*) 4 x 10 7 x 10
Northern
Sround
Water
Piune
Ingest ion
Child
floult
Vinyl Chloride 1 x 10 4 x 10
(100*) - ,
Vinyl Chloride 1 x 10 4 x 10
(100*)
Southwestern
Ground
Water
Pluae
Ingest ion
Child
Adult
-1 -3
Vinyl Chloride 4 x 10' 4 x 10
(91*)
Arsenic <7»)
Benzene (1*)
TCE (IX)
Vinyl Chloride 4 x
(91*)
Arsenic (7*)
Benzene (1*1
TCE (1*)
4 x 10
-------
-11-
Thus, If the waters in either plume were to be used as a source of
drinking .water and consumed for a lifetime, unacceptable (>10~4) cancer
risk to the exposed populace would be posed under present conditions.
Under modelled future conditions, with no remedial action undertaken,
both plumes would continue to pose an unacceptable cancer risk. Although
risks would be at a lower level than the present, they would be spread
over a larger area.
C. Northern Soil Grid.
Of the seven chemicals of concern detected in the northern soils,
only lead and arsenic pose unacceptable risks, and then only under
worst-case conditions. Table 13 shows the parameters evaluated
for the northern and southwestern soils. Table 10 presents the risks
calculated for the indicator chemicals. Risk from direct contact
with surface and sub-surface soils is low in the northern area due
to the scattered nature of metallic contamination in this area.
D. Southwestern Soil Grid.
Twelve chemicals of concern are present in these soils. Under
present realistic worst-case conditions, an unacceptable risk would be
posed by dermal contact with lead. Incremental cancer risks would
be within or exceed the target (10~4 to 10~7) range for PCBs and
arsenic under both most-probable and realistic worst-case conditions.
Subsurface risks were calculated under the assumption that the
soils would be exposed (by future erosion or excavation) with the
absence of any site remediation. Under realistic worst-case conditions,
significant risks would be posed by dermal contact with lead, chlorobenzene-,
and toluene. Incremental cancer risks would be within the target
range for PCBs and arsenic. Thus, present risk is much higher than
future risks, since contamination by lead, PCBs, and arsenic is much
greater in surface soils.
The risk estimates presented above only consider dermal contact with
the soils. Again, ingestion of soils was considered as an additional
exposure route. However, the risk levels were estimated to be one
to two orders of magnitude lower than dermal contact risks and were
deemed insignificant.
The southwestern soils also present a continual threat to ground water
contamination from the organic compounds above the water table. The
presence of the organic chemicals would increase the duration of remediation
of the ground water, for they would be a continual source of chemicals
to the ground water plume during infiltration into the water table. If
the present situation is allowed to persist, it is estimated that the
VOCs would continue to significantly degrade the aquifer up to 600 years
hence. The design phase of this project will better determine the
duration and elimination of the organic contamination threat.
E. Marsh Sediments/Surface Water.
Risks calculated for ingestion of surface waters were very low.
Sediments in the west marsh contained methylene chloride, PCBs,
arsenic, lead, and pentachlorophenol as chemicals of concern. The
-------
ia bIe 15
Direct Contact Exoosure - Soils
(0-2 feet. Present Conditions)
Rose Township Site
Parameter
Most Probable Case
Child Adult
Worst Case Exoosure
Child Adult
Frequency of Contact: 12
(days/year)
Years of Exposure: 5
Absorption Fraction:
VOCs 1O-/.
SVOCs, PCBs, and
Inorganics 1%
Average Weight over
Exposure Period: 35 kg
Amount of soil
contacted (g/day) 2
1C
70 kq
£4
s
3O
SO 7-
10*
35 ka 70 kn
10
50*
Chemical contacted
Ch !crobenzen«3
I sophorone
Methylene Chloride
Toluene
1,1, 1-trichloroethane
Tr i ch 1 oroet hy 1 ene
Bis(£-ethylhexyl )
- phthalate
Naphthalene
Fl uoranthene
Pentach loroohenol
PCBs
Arsenic
Lead (porn)
fiverage
Northern
Site Are
-
15
5
0. 1
-
260J
-
-
-
47
8, 400
1O1. 1
Concent rat i on
(ug/kg)
Sout h west er n
A Site Area
3O9
4J
6£
0. 6J
-
1.0
10, 077
2, 126J
30
124
£8,418
5, 700
150. £
Max irnum
<
Northern
Site Area
-
1 1 0
9O
3
-
2, OOO
-
-
-
1 , 360
196,000
£, 778
Concentrat ion
u g / k D )
Southwestern
Site Area
1 1 . OOO
33OJ
S40
36
-
71
618. 7 GO
Si . OOO
£. 'MOO
8, 200
980. OOO
S3, OOO
1 . 485
J = Approximate
- = Not Detected
-------
Table 13 (continued)
Direct Contact Exposure - Soils
(£-£O feet, F'.it ure Cond it ions)
Rose Township Site
Parameter
Most Probable Case
Child Adult
Worst Case Exposure
Child Adult
Frequency of Contact: 12
(days/year)
Years of Exposure: 5
Absorption Fraction:
VOCs 105«
SVOCs, PCBs, and
Inorganics i*
Average Weight over
Exposure Period: 35 kg
Amount of soi1
contacted (g/day) £
10
70 kg
£4
10
50*
lO-/-
6
30
50*
1O%
35 kg 70 kg
Chemical contacted Average
(
Northern
Site Area
£~-but
-------
-12-
east marsh sediments showed methylene chloride, arsenic, lead, and
bis (2-ethylhexyl) phthalate to be present. Risks associated with
lead and.pentachlorophenol were found to be insignificant under all
of the hypothetical exposure routes in either marsh. Arsenic has an
incremental cancer risk within the target level for both most-probable
and realistic worst-case conditions in each marsh. The risk for PCBs
is within the target range only for realistic worst-case exposure by a
child in the west marsh. No calculated incremental cancer risks
exceed the target range.
III(b). Risk to the Environment
Aquatic and terrestrial, organisms onsite are potentially at risk of
exposure to the hazardous chemicals present. In the wetlands, chronic
AWQCs are exceeded for lead, chromium, and zinc. One sample exceeded
the AWQC for PCBs:
: AWQC Maximum Level in
Surface Water
Chemical Acute Chronic East West
Marsh Marsh
Lead* 82 ug/1 3.2 ug/1 11.9 ug/1 28.6 ug/1
Chromium 16 ug/1 11 ug/1 15.4 ug/1 ND
Zinc 320 ug/1 47 ug/1 64.2 ug/1 ND
PCBs 2.0 ug/1 0.014 ug/1 ND 2.6 ug/1
ND = not detected
* = AWQC values assuming a hardness of 100 mg/1 as CaCOs
This information suggests that chronic (long-term) toxicity to fresh
water organisms could be occurring in some sections of the marshes.
(Some species are much more sensitive and some are much less sensitive
to metals at the AWQC levels. Thus some chronic effects may or may
not occur. No apparent toxicity effects were observed during the site
visit by the biologist.)
Methylene chloride, a common laboratory contaminant, was the only
VOC detected in wetland surface waters. Thus, either the processes
of dilution, dispersion, and volatilization are presently reducing
concentrations of VOCs in surface waters below levels which cause
adverse effects to biota, or no VOCs are being discharged into the
wetlands as yet. However, the southwestern ground water plume is
advancing towards the west marsh and threatens to discharge VOCs
into it at high concentrations. It is estimated that these effects
will be negligible due to dilution, dispersion, biodegradation,
sorption, and volatilization in the west marsh and no VOC toxicity
should result.
Bioaccumulation effects on organisms are unknown. Although organisms
may be exposed to low levels of PCBs, lead, arsenic, and barium in
the marshes, the accompanying Bioconcentration Factors for each
chemical are difficult to quantify. No apparent toxicity has been
noted as yet, although no organisms were collected and tested for
contamination. If contaminated soils are removed or treated during
-------
-13-
any site remediation, additional chemical loading to the wetland would be
eliminated and any current effects would thus be alleviated over time.
The presence of high surficial soil contamination in the site uplands
(especially PCBs and lead) is a concern, as burrowing organisms will be
exposed to contact hazards and, to a greater extent, invertebrates will be
exposed to ingestion hazards. Further bioaccumumlation up the food chain
would thus result. Site soil remediation should eliminate additional
exposure by onsite organisms, reducing environmental risks considerably.
IV. ENFORCEMENT
In October of 1982, seven potentially responsible parties (PRPs) were
notified by U.S. EPA of their potential liability with respect to the Rose
Site and of U.S. EPA's intent to undertake a RI/FS at the site. At that
time, the PRPs were offered the opportunity to voluntarily undertake the
RI/FS themselves. The offer was declined and U.S. EPA proceeded to undertake
a Fund-financed RI/FS at Rose.
Following completion of the RI/FS, U.S. EPA issued special notice letters in
June of 1987, to 29 PRPs identified at the Rose site. The letter notified the
PRPs of their potential liability at the site and identified the preferred
remedial alternative that had been proposed to remedy the site contamination.
It also offered the PRPs the opportunity to voluntarily undertake the implemen-
tation of the remedy selected for the site. Pursuant to Section 122 of SARA,
in an effort to facilitate an agreement with the PRPs, U.S. EPA agreed to
delay any Fund-financed remedial action at the site for 60 days. If,
during this 60 day period, U.S. EPA received from the PRPs a good faith
offer to implement and conduct the remedial action selected for the site, it
was further agreed that an additional 60 day.delay in any Fund^-financed
remedial action would occur.
U.S. EPA held an informational meeting with the PRPs on July 17, 1987. At
this meeting, attended by representatives of 11 PRPs and by State representatives,
U.S. EPA explained the conditions and contaminants which exist at the site
and also further explained the proposed remedial action selected for the site.
U.S. EPA is currently engaged in negotiations with the PRPs, and a good faith
offer is due from the PRPs by October 6, 1987.
V. COMMUNITY RELATIONS
The public comment period for the RI/FS commenced on June 29, 1987, and
was due to end on July 29, 1987. However, the public comment period was
extended to August 12, 1987, in response to public request (by the PRP
committee) for additional time to submit comments.
A public meeting was held on July 1, 1987, to discuss the RI/FS and present
the MDNR and EPA-proposed plan. During the public meeting, no opposition
was raised against the proposed plan. With the exception of the PRPs, the
public is supportive of the remedy. The attached Responsiveness Summary
will detail any concerns raised during the public comment period.
-------
-14-
VI. ALTERNATIVES EVALUATION
The Feasibility Study was initiated to evaluate appropriate remedial
responses to the contamination at the Rose Site. The following areas have
been identified as posing risks to human and environmental receptors on or
near the site:
0 Ground water plumes in the north and southwest areas of the site,
0 Soil contamination in the southwest area and, to a limited
extent, the north area^ and
0 drainage pathways to the wetlands.
a. Technologies Considered
A variety of technologies was identified to address each area of
concern. The following (Table 14) is a listing of the considered
remedial actions for the Rose site, and the initial evaluation
which caused each alternative to be rejected or accepted for further
consideration. Performance criteria, reliability factors, ease of
constructability, and site applicability considerations were used
to perform the initial screening.
Table 14
Identification of Potential Remedial Technologies
SOILS Technology
Fencing
Impermeable
Cap
Land Treatment
Land Disposal
Description
Chain!ink to
site access.
restrict
Liner to reduce
infiltration,
volatilization.
Excavate soil and
spread on surface to
enhance volatilization
and degradation.
Excavate waste and
place in onsite or
offsite approved
landfill.
Evaluation
Applicable. Easy to
implement. Reduces
contact hazards.
Applicable. Controls
contact hazards. Source
still remains.
Not applicable.
Performance data not
documented, PCBs not
volatile. Increases
inhalation hazards due
to VOC exposure.
Applicable, though
not a permanent remedy.
Land Ban requirements
must be considered.
£^:/#^S3^Xi^^
-------
-ib-
Table 14, (Cont'd)
Identification of Potential Remedial Technologies
SOILS Technology
Description
Acceptability
Soil Cover
Solidification/
Fixation
Soil Aeration
Thermal Destruction
ln_ Situ Bio-
degradation
Vacuum Extraction
In Situ Vi-
trification
Soil plus vegetation
over current soil
layers.
Incorporates waste
into solid form to
reduce rate of leach-
ing or volatilization.
Excavate soils and
vigorously mix to
enhance volatilization.
Thermally oxidizes and
destroys organic
contamination.
Microbes mixed into
soils consume and de-
stroy wastes.
Pumping of soil gas
from unsaturated zone.
Electrodes in ground
melt soils, form
glassy block. Volatili-
zed chemicals captured
by hood.
Applicable. Controls direct
contact hazards. Source
still remains.
Not applicable for VOCs.
May be applicable for
metals in incinerator
ash.
Applicable - in conjunction
with PCB and metal treat-
ment technologies.
Applicable - onsite only
due to large volume of wastes,
Ash may need further treat-
ment.
Not applicable - technology
not well demonstrated for
PCBs and metals.
Applicable - must be used
in conjunction with other
treatments to address
entire source. PCBs not
affected.
Not applicable. Large
scale technology not
demonstrated. Gas pipe-
line onsite creates un-
acceptable hazard.
GROUND Technology
WATER
Air Stripping
Carbon Absorption
Description
Promotes exchange
of volatile chemicals
from water to air.
Water is passed through
bed of granular activated
carbon to remove organics.
Acceptability
Applicable - well
demonstrated. SVOCs
not well removed.
Applicable - on a
small scale. Also used
as polishing step with
air strippers.
-------
-16-
Identification
Table 14, (Cont'd)
of Potential Remedial
Technologies
Slurry Wall
Alternate Water
Low permeable material
keyed into bedrock to
control ground water
movement
Variety of choices .(below)
Not applicable. Depth
of bedrock or contin-
uous layer of Imper-
meable soils not
reasonable.
Not Acceptable/Applicable
Source remains onsite:
a. Municipal
Water
b. Surface Water
c. Point of Use
Treatment
d. Deep aquifer
wells
Soils and. Flushing
Ground Water
Village of Holly water
supply hookup.
Local lakes
(In Home)
Available aquifer nearby.
Circulate water through
contaminated soils, col-
lect and treat leachate,
reci rail ate.
Nearest supply is six
miles away.
Surface water not potable
Michigan Department of
Public Health considers
them inadequate on a long
term basis.
May be applicable, but
source still present onsite.
Not applicable. PCBs a.
unaffected. Cold weather
sensitive. Soils perme-
ability varies too great-
ly to perform properly.
b. Response Objectives
Where applicable, Target Cleanup Levels (TCLs) for these technologies were calculated
for each chemical of concern using either ARARs or risk calculations. Where no
MCL exists for a given chemical, especially in the case of soils, risk calculations
were used to target a 10~6 cumulative risk of exposure^ to a particular medium.
For example, in ground water, the MCL for vinyl chloride is 2.0 ug/1. However,
since vinyl chloride is a carcinogen, the risk calculation showed an incremental
cancer risk of 1.3 x 10~4. Setting the incremental cancer risk at 10~6 yielded a
TCL of 0.015 ug/1 for vinyl chloride.
The TCLs for the two plumes were found to be different, since vinyl chloride is the
only carcinogen present in the northern plume and it is one of five in the south-
western plume. Since incremental cancer risk levels are additive, each corresponding
^Region V policy is to obtain a 10*6 incremental cancer risk objective if it is
feasible.
-------
-17-
chemical of concern will have a lower TCL than if it was the only chemical present.
However, the vinyl chloride TCL is far below the detection limit for Special Analytical
Services (SAS) through the Contract Lab Program (CLP). Thus, cleanup of vinyl chloride
will essentially be to non-detection or background.
The target level for arsenic in soils for the 10~6 incremental cancer risk level is
calculated to be 0.41 mg/kg. However, the naturally occurring (background) range
for arsenic in these soils is 1 mg/kg to 14 mg/kg (Table 5), thus it was decided
by EPA and MDNR to set the TCL at 14 mg/kg. Essentially, arsenic cleanup will be
to background. The calculated risk level for this chemical at this TCL is 1.69 x
10-5 which is within the target range. Similarly, the TCL for soil PCBs was set at
10 ppm. a more technically practical level, yet still achieving the target risk range
of 10-4 to 10-7. The calculated risk level in southwest surface soils for PCBs is
3.49 x 10-6 at this TCL. Table 15 lists the TCLs determined for the Rose Site. The
source of each TCL is listed also.
C. Applicable Alternatives
On the basis of identified applicable technologies for each site area of concern,
five remedial alternatives were compiled. Each alternative meets the response
objectives for the site areas (to remove or reduce to acceptable levels the risk of
exposure to site chemicals) but all may not meet the calculated TCLs. Each of the
remedial technologies that address the soil may be coupled with the ground water
extraction and treatment module which is addressed separately. The following are
the alternatives to be considered:
0 no action, except for monitoring
0 excavation (of contaminated soils), with
offsite land disposal
0 excavation, with onsite thermal destruction
of organics and onsite disposal of ash
0 excavation, with soil aeration to remove VOCs
and offsite land disposal for metals and PCBs
0 impermeable capping of site with in situ vacuum
extraction of VOCs.
and for ground water:
0 extraction and treatment by air stripping and carbon
absorption, plus chemical coagulation to remove metals.
D. Description of Alternatives
Alternative 1: No-Action
The No-Action alternative would actually be a limited-action alternative. It would
consist of a site monitoring program, erection of a security fence and provision
for an alternative water supply. Site inspection would also occur.
-------
table 15
Final Target CleanuD Levels (TCLs)
Rose Townshio Site
Northern Ground Water Plume
Chemical
TCL
Source
Lead
Vinyl Chloride
Southwestern Ground Water
Chemical
ftrsenic
Lead
Ch lorobenzene
Benzene
TCE
Vinyl Chloride
PQBs
Methylene Chloride
Northern Surface Soils
Chemical
ftrsenic
Southwestern Surface Soils
Chemical
flrsenic
PCBs'
Lead
Southwestern Subsurface So
Chemical
50 "
0. 015
P 1 ume
TCL
tug/1)
50
50
60
O. 133
0. 627
0. 003
O. OOS
0. 919
TCL
< rng/kg )
14
TCL
(rng/kg )
14
1O
70
ils
TCL
(rna/ka )
MCL
Carcinogenic Risk Calculation
Source
MCL
Prooosed MCLG
Carcinogenic Risk Calculation
Carc.inogenic Risk Calculation
Carcinogenic Risk Calculation
Carcinogenic Risk Calculation
Carcinogenic Risk Calculation
Source
Background Level
Source
Background Level
MDNR/EPfi Decision
Noncarcinogenic Risk Calculation
Source
Chlorobenzene
Isoohorone
Methylene Chloride
1, 1, 1 -1 r i ch1 oroet h a ne
Tr i ch1oroeth y1ene
Sum of
the VOCs
not t o
exceed
0.OS mg/kn
Derivation using TCLs for VOCs
in the ground water and Koc for
chemicals in the soils.
-------
-18-
The proposed monitoring program would involve sampling of selected existing
monitoring wells and the installation and subsequent sampling of eight additional
monitoring wells as shown in Figure 13. Performed on a yearly basis due to slow
movement of the ground water, the laboratory analyses would include lead, arsenic
and the organic chemicals of concern in the ground water plume. The northern plume
moves much faster, thus semi-annual sampling may have to be implemented.
The fence would be installed around the perimeter of the site. Consisting of six
foot high chain link section with three-strand barbed wire, the total length of
fencing would be about 8800 feet. Every 200 foot interval would have a sign that
warns of hazardous chemicals.
The alternative water supply would only be implemented if monitoring indicates the
movement of site-derived chemicals offsite. Since no suitable surface water
exists nearby, the only practical alternative is to supply affected households
with individual deep bedrock wells. The installation of shallow, up-gradient
wells is not recommended since the hydrogeology is so complex that it would be
impossible to predict how the high-yield wells would affect the contaminant plume.
Lastly, site inspection would occur yearly during the site monitoring sampling
program, or more frequently, as needed. Monitoring wells or fencing will be
repaired as required.
This alternative would be easily implemented since all technology is readily
available. Construction of the fence is a relatively simple task, as would.be
the installation of any monitoring wells. Short term effectiveness in protection
would be realized. However, long-term effectiveness is limited since compliance
with site access restriction is voluntary. The presence of a fence has currently
not been successful in preventing site access. The alternative does not remove
or reduce the concentration or threat of site chemicals and their presence
would still pose a substantial threat of release to the environment.
The capital cost of this alternative is approximately $241,600. Annual costs
of $52,000 include ground water monitoring, site inspection and fence maintenance.
Present worth over 30 years is $732,000. The alternative water supply cost is
uncertain, since implementation may occur far into the future. Current capital
cost for the water supply for the six area homes is estimated at $62,700, with
an annual monitoring and maintenance cost of $14,300. Construction would take
one year or less to perform, while sampling and maintenance would occur for 30
years.
If no site ground water remediation occurs, Michigan Act 245 and the Safe
Drinking Water Act would not be complied with, since the aquifer would otherwise
yield potable water. The State would not concur with this remedy selection.
Community acceptance would be nil, also. The overall level of protection of
human health and the environment is low.
Ground Water Extraction and Treatment
The ground water extraction and treatment system is an integral part of Alternatives
2 through 5. The extraction system consists of a network of interconnected wells
designed to intercept the north and southwest plumes. The contaminated water would
be pumped to a treatment system designed for removal of chemicals to their TCLs
prior to discharge.
-------
,
- NORTH SITE AREA ( "'.
f .-.-.---.-.-.--?£&
i ' «N
- \f W
W ;"--.
-SSSTTSSSSSS
WUIOMIIIIMII
t.LOMO T^K. MOM.TOR.IM UKATMNt MAY
ravotto MOwnuM* WELL LOUTIOH
ELLS MLECttD rOH LO« IIM1 HO.ITO«MI«
FIGURE
REMEDIAL ALTERNATIVE r
NO ACTION
ROSE TOWNSHIP - DEMODE ROAD SITE
ECJORDANCQ
-------
-19-
An estimated total of 17 extraction wells (15 southwest, two north) would
be used to withdraw 90 gpm from the contaminated aquifer. The water would be
treated to remove. VOCs as well as PCBs, lead and arsenic. Cleanup would be
accomplished through the use of chemical coagulation and filtration prior to
air stripping, followed by an activated carbon absorption polishing step to
remove residual organics. The treated water should be clean enough to discharge
to. the west marsh if the lead levels do not exceed AWQC (3.2 ug/1). If not able
to meet AWQC, discharge will not occur to the marsh. Instead, a POTW may be con-
tacted to determine if it would accept the treated water, or, the water could
be allowed to re-infiltrate into the ground water system onsite. However, these
alternatives for discharge have not been addressed in the FS nor during the
public comment period. Before implementation, the ROD would be re-opened for
public comment to allow for public review of the needed discharge method. Treata-
bility studies during the remedial design phase will address this concern. The
resulting metal sludge would be tested to determine appropriate disposal practices.
Figure 14 shows suggested extraction well locations.
Ground water extraction and the treatment system outlined above are all well demons-
trated and proven technologies. Construction should occur with little difficulty.
Prior to implementation, however, an aquifer pump test will be performed as well
as pilot testing of the treatment system to determine optimum operating parameters.
The mobility, toxicity, and volume of hazardous chemicals in the ground water
will be adequately reduced to lower public health risks associated with ground
water ingestion. As mentioned previously, a potentially adverse effect on the
wetlands may occur if the discharge exceeds AWQC or Michigan Rule 57 criteria for
the protection of freshwater aquatic life.
The State and community would both concur with this phase of the remedial action.
Both short-term and long-term environmental benefits will be realized, as the
pumping will prevent.the plumes from advancing offsite and treatment will eventually
render the aquifer fit to drink from.
Ground water extraction and treatment is to be performed in conformance with the
SDWA, CWA, Michigan Act 245, and the Michigan Air Act (treatment emissions).
Capital costs for this system are $706,000. Annual costs are $129,100 accounting
for an estimated six to ten years of extraction and treatment, or longer as
determined by monitoring data. (These costs have been built into Alternatives 2
through 5 already.)
Alternative 2: Excavation of Contaminated Soils, Offsite Landfill
.Alternative 2 would consist of: excavation and offsite disposal of scattered
waste piles and soils above their TCLs, ground water extraction and treatment,
site monitoring, and site fencing. All site objectives would be met, as the
hazards associated with surface and subsurface soils would be removed and the
ground water plumes eliminated. However, since wastes are only transported offsite
and landfilled in their present state, Alternative 2 cannot be considered a
permanent remedy.
Excavation would consist of removing approximately 50,000 cubic yards of waste
material. The majority (48,000 cy) of the excavation would be located within
-------
c T I I ; /
----__ v »S'_ S t
"S . e J-jf-
SOUTH-SITE AR
f
HUIWH
HKOU1IOWAIIK CXTKACTIOI C»« ! WTLIID TO M.TCHMTIVII 1,1.4, ANO9
KI TUTHSCHTIOk Of TM.MMHT SflTCM
T.CITUCTUM MLL UkCAIKXU MD nnnHM UTt« MI IMto Ml MIT CU
or MrointauMiG nmun«« *w» IHTI MI mciMMTron WTUM. «T»TEM OMMH
t nmWTliM «ILL LOCAIOM MB WUK LIH«IM WILL M MTDMINIO < '»«
»si>« niLO c
MoroiCD n»MTION WILL LOUTUW ,,,,« nilf.l TO M LOCirCD ftIT IIL.OW ««AM
NATi IN 0PM
FIGURE 14
-ADD ON* TECHNOLOGY -
GROUNDWATER EXTRACTION
ROSE TOWNSHIP - DEMODE ROAD SITE
ECJORDANCO
-------
-20-
the southwestern area grid (Figure 15). The remainder would consist of removing
soils above the arsenic TCL (1700 cy) in the north grid area and removing waste
piles (500 cy) scattered throughout the.site. Excavation volumes were derived by
applying the previously discussed TCLs for PCBs, arsenic, and lead, and the total
residual VOCs allowable to eliminate the continual source to the ground water
plumes. Additional soils sampling will need to be performed during the design
phase? to more precisely establish the volumes to be excavated. Materials excavated
would be disposed of at a RCRA Subtitle C facility permitted to accept VOCs, SVOCs,
and PCBs la.the concentrations observed onsite. A facility located in Model
City, New York, about 360 miles away, has been used in the cost estimate derivation
for this site.
Site fencing has been described in the No-Action Section. Site monitoring has been
described along with ground water excavation and treatment in the previous section.
The construction activities would require extensive mobilization and decontami-
nation facilities'onsite, using conventional earth-moving equipment. Implementation
of this alternative is not expected to be complex. Excavation of wastes with
similar characteristics has been sucessfully performed at other hazardous waste
sites. Assuming all TCLs are met, the level of protection at the site utilizing
this remedy is high, since all soil contact hazards would be removed. The ground
water contamination would also eventually be reduced in concentration thus decreasing
risk to receptors. Onsite toxicity, mobility, and volume of contaminants would
be greatly decreased. However, transfer of the waste offsite does not permanently
address the problem as the contaminants will not have been destroyed, immobilized,
detoxified, or reduced in volume.
Onsite environmental impacts will be small and temporary. Erosion may increase
chemical loading in the wetlands until the remedy is complete (in one year or
less) and revegetation has occurred. Standard erosion control practices such as
silt fences and mulch should reduce sedimentation in the wetlands. Once the
contaminated soils are removed, exposure risks of terrestrial organisms shall be
greatly reduced.
The present worth of Alternative 2 is $29,167,000 based on capital costs of
$27,762,300 for fencing, monitoring, construction, and dumping fees. Also included
is the ground water extraction/treatment system. Annual operation and maintenance
costs are associated with the ground water system and monitoring costs for a 30-
year evaluation period. These costs average $108,000/year.
The community does not favorably view the transfer of wastes from one site to
another, even though their "back yard" would be clean. The State does not wish
to deal with future liability of landfilled wastes, instead preferring a more
permanent remedy.
All relevant statutes would be complied with, including RCRA, SDWA, CWA, and
Michigan Act 245. Onsite, overall protection of human health and the environment
would be high, but the associated risks would only be transferred offsite with
the landfilled soils.
^Including marsh soils
-------
-* - i CM*
KiJ_j^r«i
- ; NORTr/SITE AREA \j "Yvi,,
~\. ' / ,-.-.---.-t--=?SCt'^**^~
NOTES
I THE MW StHICS HOMtOHDM wtLLS IvtHC COW0LCTCD
KOHimmc wtu ciusnn
INtMKI or »tu.S nmuTCDI
O WMnMim wcu.
;-=»rtt KCtn HOW
X ftw KMfCS HONtTOMHC WCLL* *t»t COHWLtTtD IN »B2
D. I MD S fVM) TO* DKP. INTtWMttXtTt AND SHADOW WCUS
CTWf USIWBUTnw O' TOT*I.
VOUTLI CMWMC OCWUU M
MCMCMMTCM IM/M
S ACTUAL EXCAVATION lOIIMMNItS WILL BE OCTCHMUCO
ON9ITE U9INQ C FIEI 0 SCHIENIH4 METHODS.
« A SON. COVCt WILL K P1ACID OVt"» tCAD-CONTAMtNt ASH
If ONStTC DISPOSAL H NMMITTED
MOPOMO HOWTOmNt WfLt H«T»LL*TIOII
MOMKD MCIM)IAT(» Loc*rioi/sott STOCK rtn AKIJI
M»TH OF CXCfVATtOM CONTOUH (r«T)
"ILLS KLCCTtD FOB LWB-TtHM WONITONIIft
FIGURE 15
REMEDIAL ALTERNATIVE 3'
EXCAVATE SOILS /THERMAL DISTRUCTION
ROSE TOWNSHIP - DEMODE ROAD SITE
ECJORDANCO
-------
-21-
Alternative 3. Excavation of Contaminated Soils, Onsite Thermal Destruction
Alternative 3 consists of the following components: excavation and onsite thermal
destruction of the chemicals in the scattered waste piles and soils above their
TCLs, ground water extraction and treatment, and site fencing and monitoring.
Except for soils remediation, the other components have been discussed previously.
As described in Alternative 2, excavation of about 50,000 cy of soils to their
TCLs .would remove the dermal contact hazards of the PCBs and the continual
organic chemical source of the ground water plumes. Two types of technology are
RCRA-permitted to incinerate PCBs: rotary kiln and infrared. Both technologies
are available as mobile, onsite-?use units.
Ideally, an infrared unit will be used onsite, since it is estimated that it will
have lower costs than a rotary kiln device. Destruction and removal efficiencies
(DRE's) of 99.9999+% have been demonstrated for wastes with elevated PCB concen-
trations. Infrared units have been reported to "fix" heavy metals in the resulting
ash, such that the ash passes EP toxicity tests for the metals. Lead is an example
of a metal that has been reportedly "fixed" in the ash. Whether or not this
is true, it will be an important factor in the disposal of the Rose site ash, due
to the association of high levels of lead with the PCBs.
Along with the construction described in Alternative 2, additional siting and
operating requirements are needed. The thermal destruction unit will be placed in
proximity to the major excavation area, which calls for clearing and leveling of
about 2 acres. Security fencing and outdoor illumination for a multiple shift
operation would be needed. For a 24 hr/day shift, a limited stockpile of waste
feed would be needed. RCRA temporary waste pile and temporary storage requirements
would have to be met.
Prior to implementation, questions concerning treatment and disposal of ash and
scrubber effluent, performance testing, and emission limits would need to be
addressed. Thermal destruction does not destroy heavy metals, for metals are
still found in the resulting ash and scrubber water. These process wastes are
considered to be hazardous under RCRA, unless they are delisted. EP toxicity tests
will be run on the ash to determine the method of onsite disposal. If the ash
passes the test, it may be backfilled with a soil cover placed over it. If it
does not pass, further treatment will be necessary before burial. Scrubber effluent
would consist of salt brine and low concentrations of heavy metals. A Publically
Operated Treatment Works is being contacted to inquire about the possibility of
them handling the effluent. A test burn will be conducted to determine operating
parameters and expected emissions. Emissions are expected to meet criteria set
forth by the Michigan Air Pollution Control Commission.
Long-term environmental and public health effects will be very beneficial, as the
hazards associated with the contaminants will be permanently removed. Initially,
chemical loading in the wetlands may increase during excavation and incineration,
but erosion controls should minimize the impact.
The capital cost for Alternative 3 is $32,547,000, assuming no further treatment
of the ash will be needed (as being shown by a test of this technology at a Region
IV site). Annual costs consist of both operating and long-term monitoring costs
until year 10, after which annual costs are limited to long-term monitoring costs.
The present worth is estimated to be $34,084,000, based upon annual costs of
$200,000/yr for year 0 to year 10 and $70,000/yr for year 11 to year 30.
-------
-22-
The State concurs with the scope of this remedy. The community also has no object ''"'
to this remedy.
Alternative 4: Excavation of Soils, Aeration of VOC Contaminated Soils, Landfilling
of PCB/Metals Contaminated Soils.
Alternative 4 would consist of the following components: excavation of soils
contaminated with PCBs, lead, and arsenic in excess of their TCLs and subsequent
offsite disposal; excavation and soil aeration of VOC contaminated soils in the
southwest grid area; ground water extraction and treatment; and site monitoring
and fencing. Soil aeration is considered to be a permanent remedy for VOCs,
only, since the hazards associated with PCB and metals containing soils would be
transported to another site, rather than permanently addressed. The VOCs are not
destroyed. The exposure risk is only reduced as the VOCs are transferred to the
atmosphere from the soils.
Site fencing and monitoring and ground water treatment have been described previously
Approximately 25,000 cy of soils would be excavated and landfilled in the manner
of Alternative 2. The remaining 25,000 cy of VOC containing soils would be
treated by placing the wastes into an enclosed rotating drum. Heated air would be
passed over the soil, causing volatilization of the organics. Exhaust gases
would be passed through a treatment process before being emitted into the atmosphere.
Soil aeration has been proven effective in removing VOCs and SVOCs at the McKin
site in Region I. Prior to implementation at the Rose site, pilot studies would
be necessary to estimate process efficiency and expected duration of operation.
Coordination of each construction phase would be a concern. The non-treatable
waste would be excavated and removed prior to excavation for the aeration process.
Stockpiling of VOC-containing soils would have to meet RCRA storage requirements.
Any soils that do not respond to aeration would need to be drummed and landfilled
as well. After aeration is completed, ground water treatment will commence.
This alternative will reduce the public health risks associated with direct
contact and chemical leaching from the soils. Atmospheric exposure could possibly
increase if emissions are too high, but this would be a short term risk as the
estimated time for the aeration process to be completed is 10 to 12 months.
Environmental effects may include chemical loading to the wetlands as discussed
in earlier sections. This, too, should be of a short term nature. However,
environmental exposure to hazardous chemicals will be greatly reduced when the
remedy is completed.
Capital costs would total $26,233,600 for this alternative. Average annual costs
'are estimated to be $95,000/yr. The present worth of Alternative 4 is $27,638,000.
The ground water remediation would comply with Michigan Act 245 and the Safe
Drinking Water Act. For reasons discussed in Alternative 2, neither the State or
the community would support a landfilling alternative.
-------
-23-
Alternative 5: Soil Cap and In Situ Vacuum Extraction
Alternative 5 would consist of the following components: soil capping and vacuum
extraction of VOCs in the southwest grid area, soil cover in the north grid area,
ground water extraction and treatment, and site monitoring and fencing. This is the
only alternative that relies completely on in situ technologies to meet the site
response objectives. Site fencing, monitoring, and ground water treatment have been
described previously.
Application of the in situ process is straightforward. Soil gas extraction
wells are installed to the water table and screened for their entire length. A
blower attached to the well creates a negative pressure, extracting gases out of
soil pore spaces to the surface for treatment. The cap consists of clay, sand, and
soil layers to: (1) seal the surface to help create a greater negative pressure;
(2) decrease the contact hazard potential of PCBs, arsenic, and lead; and, (3)
reduce moisture infiltration which in turn minimizes leachate from organics not
extracted by the wells. The soil cover on the north site allows for revegetation.
Figure 16 shows the planned location of extraction wells and soil covers.
Included in the site monitoring plan for this alternative would be inspection
and repair of the caps as needed.
Short-term effectiveness of soil capping has been well documented. Effectiveness
of the vacuum extraction method depends on the volatility and concentrations of
chemicals present. However, the technologies are easily installed and capping
would provide good short-term protection against soil contact hazards. Unfortunately,
it would be difficult to determine if TCLs have been met in subsurface soils
after application of vacuum extraction. Ground water contamination would still
occur if infiltration continues into southwest area soils, as long-term cap
integrity is suspect.
Short-term environmental risks from onsite construction would be lower for this
remedy than for any of the alternatives requiring excavation. However, vacuum
extraction would only transfer VOCs from the soils to activated carbon air filters,
which in turn would need to be treated or disposed of safely.
Environmental exposure by terrestrial organisms would be reduced due to the clay
and soil covers. Transport of PCBs and the heavy metals to the wetlands would be
curtailed, as would the possibility of ground water contaminating the wetlands
after the remedy is implemented. Long-term reliability is suspect, as the cap may
fail and exposure would result.
The State would not concur if this remedy was selected by EPA. There are doubts
as to the reliability of vacuum extraction methods on VOC removal, and SVOCs
probably would not be removed at all. The community would also probably not concur,
either, as they trust the State to perform the most protective remedy possible.
Alternative 5 cannot be considered a permanent remedy since PCBs and metals are
left untreated. Treatment of VOCs in the soils attempts to address risk level
reduction for these chemicals. Semi-volatile organic chemicals would not be
removed and would remain a long-term ground water degradation source.
-------
-24-
Capital costs of this alternative would be about $3,735,700. The annual cost
would vary over the life of the project, being greatest in the first five years
when all processes are operational ($547,900/yr). For years 6 to 10, annual
costs would drop to $212,100/yr, considering only ground water monitoring and
cap, cover, and fencing maintenance. Total present worth over 30 years is
estimated at $6,789,000.
Section 121(b)(1)(A-G) Review
The following Table (16) lists the evaluated alternatives and their relative
effectiveness versus the CERCLA Section 121(b)(l)(A-6) factors and the nine
points listed in the OSWER directive dated July 24, 1987. (TITLE: Additional
Interim Guidance for Records of Decision: #9355.0-21)
VIII. Selection of Remedy
The No-Action Alternative (#1) was considered as directed by CERCLA. Site
exposure risks are too high to go unaddressed. This alternative proposed
no responses that would address the release and threat of release of hazardous
wastes in a long-term protective manner. Thus, it cannot be selected.
Of the four remaining alternatives, only one (#3) addresses the risks in terms
of permanent destruction of contaminants. This alternative, Soil Excavation
and Onsite Thermal Destruction along with Ground Water Extraction and Treatment,
is the preferred remedy for the Rose Site contamination. Performance of this
remedy, as compared to the others, will:
(i) alleviate the long-term uncertainties of land disposal or capping
in place (CERCLA - Section 121(b)(l)(A)), since there will be
destruction of most of the organics and immobilization of the metals,
(ii) eliminate the volume, toxicity and mobility to the greatest extent
(Section 121(b)(l)), as explained in (i) above,
(iii) attain or exceed all cleanup ARARs promulgated,
(iv) greatly reduce the propensity to bioaccumulate hazardous substances
to the greatest extent (Section 121(b)(l)(C)), since the PCBs will
destroyed and not capped or landfilled,
(v) relieve the short-term and remove permanently the long-term potential
for adverse health effects from human exposure (Section 121(b)(l)(D)),
since the ground water plumes will stop advancing with the onset of
pumping and treating,
(vi) substantially reduce long-term maintenance costs (in comparison
to Alternative 5) (Section 121 (b)(l)(E)), since there will be no
cap to maintain if Alternative 3 is implemented,
(vii) remove the potential for future remedial costs since the wastes would
be destroyed, not left in place or landfilled elsewhere (Section 121
(b)(l)(F)); if the wastes are not destroyed, future leakage and cont-
amination may result,
(viii) not pose threats to human health due to transportation and redisposal
offsite (Section 121 (b)(l)(G)), as posed in Alternative 2 and 4,
-------
OWOOftttC WELL CLUfTEft
IHUMCft Or WILLS NHHCATCD)
O Monrroinmi WELL M$TAU.ATK>K
rrr:s*"t ACCESS «O*D
o sBrtsafi
Z ftw tCHlCS WOMITONM wtUJ WtHt COM*LTTtD
a. tuttcm D. i MO t
»Mmmtrr
vourrt.c CNMMC OCMCALS
omufOMrot t«t/t)
s LIMITS v SWHCC K«uurr «*wt»c«*o ID sown voe CONTOUH
«. TOTAL SVfWACC AREA MWfQ KC,OOO SO FT
7 IXTflftCTION WELL LOCATWH *WO 3C«EK LtNOTMS WILL BE OCTE
fM tHE Milt OP PttL» C SCMCNtftQ
O itnun Dtr»yiNnn UTIBT or tor** ivoc coHTOumit)
. VACUUM r«T»CtlOH TOUT 110 I
IM.L*OMta AM MTfHCONNCCTCD Wltn nriM)
Q nwoMD MOWTMIM .nt IOOIIOH
«m Jtiecrto roil i.o»-Ttm MOHITOHIIM
FIGURE 16
v REMEDIAL ALTERNATIVE 6
VACUUM EXTRACTION
ROSE TOWKSWP - DEMODE ROAD SITE
ECJORDANCQ
-------
TaDle 15
Suffiraary of Seir.BSial Alternatives Evaluation
Rose Township - Deraode Roao Site, Michigan
Criteria
Reduction
of volume,
toxicity, or
rcobility
Ijiplement-
ability
Short tern
Effectiveness
Long term
Effectiveness
State
Concurrence
Coramnity
Corcurrer.ce
ARARs
Corral iance
Overall
Protect iveness
of Hunan
Health,
Environment
Cost:Caoital
Annual
Present Worth
Tirce to
noieisent
or
complete
action
No fiction
None
Easily
Some
Very uncertain
to none
None
None
LOU: SARA
SDWfl, -SCA
CWft, «i Act 245
Slioht
$309.300
64.800
921,000
Less than
one year
+
yearly
monitoring
Offsite
Landfill
+
Air Stripper
Onsite:
Coraoiete
Offsite:
LOH
S.W. : Easily
Ldfl : Moderate
Moderate
Gnsite: High
Offsite: Low
Ground water
Treatment only
DC not like
iandfiiiino
Low: SARfi
Hicn: SDWA, CM,
TSCA, MI Act 245
Onsite:
Fully
Offsite:
Risks are
Transferred
27,760.000
110,000
29,179,000
Less than
two years
ground water treai
yearly monitoring
Onsite
Thermal
Destruction,
flir Stripper
Hioh to
Moderate
(ash.)
6.U. : Easily
Therm: Moderate
Moderate
High
Full
Full
High: SflRA,
RCRfl, SDWA, TSCfl,
CWA, MI Act 245
Fully to
Moderate
(ash)
32.550.000
122,000
34,100.000
Less than
tnree years
:.rf.ent will last up
yearly nonitoring
Offsite
Landfill
Soil Aeration
flir Stripper
Onsite:
Complete
Offsite:
LOH
6.U. : Easily
Soil : LOM
Moderate
Onsite: High
Offsite: Lot*
Ground water
Treatment only
Do not like
landfill ing
Moderate: SARA
SDHfl, TSCA,
QUA, MI Ret 245
Onsite:
Fully
Offsite:
Risks are
Transferred
26,234,000
110,000
27,640,000
Less than
three!?) years
to ten years
yearly nonitoring
Capping,
Vacuum
Extraction,
flir Stripper
Low to
Moderate
G.U. : Longer
Vac- : LOM
Moderate
LOH to
Moderate .
None for
Vacuun Extr.
Lukewarn
to low
Low-Moderate:
SARA, SDWA, CUA
Some: Act 245
Low
to
Moderate
3,936,000
133,000
6,790,000
Uncertain for
Vac. Extr. and
ground water
yearly monitoring
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(ix) have State concurrence and subsequent 10% cost-sharing,
(x) present a cost-effective alternative since the cost is nearly the same
as that of remedies offering similar levels of protection onsite (#2
and #4), ($29.1 million for #2, $27.6 million for #4 and $34.1 million
for #3),
(xi) eliminate public (community) concern with toxics being left in place,
(xii) present the only current method to destroy PCBs, providing for
elimination of their potential to damage the environment,
(xiii) remove contaminants from soils and from the ground water so that
the aquifer will once again be of potential use as a potable water
supply within a practical period of time (compared to Alternative
#5), and
(xiv) follow the Land Disposal Restriction rule, where applicable, to incinerate
halogenated organic compounds when their concentrations reach or
exceed 1000 mg/kg. (The highest PCB sample analyzed showed 980 mg/kg,
which is essentially 1000 ppm.)
The scope of this remedy is as follows:
0 As much as 50,000 cy of PCB, VOC, lead, and SVOC-contaminated soils will
be excavated and thermally treated onsite to destroy the organic wastes.
0 ORE will be. 99.9999% (minimum) for PCBs, VOCs, and SVOCs. Estimated
maximum time frame for completion of thermal destruction is 33 months.
0 Half of the resulting ash (20,000 cy) is expected to contain lead and
arsenic, and it will be tested for EP toxicity. If it passes, the ash will
be classified as non-hazardous and backfilled onsite. If the ash is EP
toxic, treatment will be necessary to reduce the ash to below EP toxicity
levels before reburial onsite. The other 20,000 cy is estimated to already
be non-hazardous (no metals of concern), but it will still be necessary to
meet the substive requirements for RCRA delisting due to the listed solvents
it formerly contained.
0 All emissions and effluent streams will be treated onsite to meet
established ARARs.
0 A ground water extraction system will remove 10-14 pore volumes (1 pore
volume = 22 million gallons) of the southwestern plume and 6 pore volumes
(1 pore volume = 8 million gallons) of the northern plume over a time
period of six to ten years. These volumes are estimated to be necessary
to bring the chemicals in the ground waters to their TCLs.
0 the ground water extracted will be treated by chemical coagulation and
filtration, air stripping, and activated carbon adsorption systems to
remove chemicals to their TCLs. Discharge of treated waters will be to
the west marsh if AWQC (especially for lead) are not exceeded. If found
to exceed AWQC, a local POTW will be contacted to determine if they will
accept the treated waters, or, the water may be placed in a pit onsite
to allow it to infiltrate back into the ground water table. However,
-------
-ke-
enly discharge into the marsh was considered in the FS and placed for public
comment. If an alternate discharge method is needed, the ROD will be reopened
for public comment before implementation of the ground water treatment remedy.
0 Sludge produced by the ground water treatment process will be characterized
and disposed of as appropriate.
0 A site fence will be erected to provide a secure work environment and to
prevent accidental exposure by unauthorized personnel.
0 Site ground water monitoring will occur yearly until TCLs have been met.
To meet the scope of this remedy, the following design tasks, at a minimum,
shall need to be performed:
(i) Treatability study(s) concerning the ground water plumes - to determine
expected metal residual levels before determining the method of discharge,
and to determine flow rates in the air stripper and the carbon apparatus;
(ii) Testing to determine the level of pre-incineration treatment needed,
e.g., sifting, whether fuel oil addition will .help with the burn, etc;
(iii) Pilot testing to determine incineration parameters;
(iv) Soils sampling in the wetlands to delineate PCB cleanup, if any, needed
in the marshes;
(v) EP toxicity testing of the ash to determine how the ash may properly be
disposed of onsite pursuant to RCRA and also chemical analysis to show
effectiveness of incineration;
(vi) Ash treatability testing will be needed if it does not pass EP toxicity
testing. Examples of treatability testing may include solidification/
fixation, or the application of a metals leach liquor to the ash to remove
mobile metals before retesting for EP toxicity;
(vii) Aquifer pump testing to determine efficient flow rates for ground water
extraction;
(viii) Soils sampling in the northern grid area to determine extent of arsenic
contamination and total need for remediation in this area;
(ix) Testing of VOCs and SVOCs leach rate from soils; and,
(x) Any other studies determined to be necessary to fully design, for
bidding purposes, the remediation of the site.
VIII. Compliance with Environmental Statutes
Section 121 (d)(l) of CERCLA provides that selected remedial actions at a site
must attain a degree of cleanup of hazardous substances which ensures protection
of human health and the environment. In determining the level of cleanup to be
- achieved at a site, Section 121 of CERCLA states that applicable, or relevant and
appropriate requirements found in other Federal or State environmental laws or
^«>^it^V£-iVtf^;K&*S^.T.V<;/^
-------
regulations must be met.
Applicable requirements are cleanup standards, standards of control, and other
substantive environmental protection requirements, criteria or limitations
promulgated under Federal or State law that specifically address a hazardous
substance, pollutant, contaminant, remedial action, location or other circumstance
at a site. A requirement is "applicable" if the remedial action or circumstances
at the site satisfy all of the jurisdictional prerequisites of the requirement.
Relevant and appropriate requirements are cleanup standards, standards
of control, and other environmental protection requirements, criteria, or
limitations promulgated under Federal or State law that, while not "applicable"
to a hazardous substance, pollutant, contaminant, remedial action, location
or other circumstance at a site, address problems or situations sufficiently
similar to those encountered at a site that their use is well situated to
that site.
While non-promulgated advisories or guidance documents issued by Federal or
State governments' do not have the status of potential ARARs, they may be
considered in determining the necessary level of cleanup for protection of
human health and the environment.
Table 17 lists the operational ARARs for the Rose Township site. MCLs
established under the Safe Drinking Water Act (SDWA) were used to set target
cleanup levels (TCLs) at the Rose site. A proposed MCLG (Maximum Contaminant
Level Goal) for chlorobezene was used as a TCL because no MCL for chlorobenzene
has been established. Chemicals without any type of MCL use health based,
.calculated target cleanup levels.
MCLs are "relevant" to the remedial action at the Rose site because the aquifers
are or may be used for drinking water. MCLs are "appropriate" because
they set enforceable drinking water standards for public water supplies. As
MCLs apply to water at its point of distribution ("at the tap"), these levels
are appropriate for ground water at this site because residential wells that
would use this aquifer would have minimal or no treatment**.
Several other environmental statutes are ARARs due to the remedial action
proposed at the Rose site. Since hazardous wastes will be treated and stored
on-site, the substantive requirements of the Resource Conservation and Recovery
Act (RCRA) and Michigan Act 64 are applicable requirements which must be met.
RCRA regulations concerning the design, construction, operation and maintenance
of incinerators are also applicable regulations which must be complied with.
In addition, storage of PCB contaminated soil for incineration must comply
with the requirements found in the Toxic Substance Control Act (TSCA). These
are specifically identified in Table 17 hereto.
8Since the aquifer at the Rose site may be used for drinking water, MCLG's
may therefore be relevant. However, under Agency Guidance (7/9/87 from Winston
Porter), MCLs are fully protective as they are the standard for public water
supplies. Therefore, except for chlorobenzene discussed above, MCLs rather
than MCLGs are considered both relevant and appropriate where they exist.
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TABLE 1,
POTENTIAL ARARS
ALTERNATIVE 3 - EXCAVATE/THERMAL DESTRUCTION
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
ROSE TOWNSHIP - DEMODE ROAD SITE, MICHIGAN
Phase III ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
RCRA - Standards for Owners and
Operators of Permitted Hazardous
Waste Facilities (40 CFR 264.10 -
264.8)
RCRA - Manifesting, Recordkeeping,
and Reporting (40 CFR 264.70 -
264.77)
RCRA - Groundwater Protection
(40 CFR 264.90 - 264.109)
RCRA - Closure and Postclosure
(40 CFR 264.110 - 264.120(e);
- 264.310)
General Facility requirements
outline general waste analysis,
security measures, inspections
and training requirements.
This regulation specifies the
reoordkeeping and reporting re-
quirements for RCRA facilities.
This regulation details require-
ments for a groundwater monitor-
ing program to be installed at
the site.
This regulation details specific
requirements for closure and
postclosure of hazardous waste
facilities.
Any facilities will be constructed, fenced,
posted, and operated in accordance with this
requirement. Process wastes will be evaluated
for the characteristics of hazardous wastes
to assess further landing requirements.
Any off-site disposal of hazardous waste will
be properly manifested.
While not "applicable" since there was no
treatment, storage,, or disposal of hazardous
waste after November 19, 1980, these standards
are relevant and appropriate to determining the
level of groundwater cleanup. TCLs will meet
maximum concentration limits set forth at
40 CFR §264.94(a)(2) where such levels exist.
Where they do not exist, the health-based
cleanup levels that have been selected will
constitute alternative concentration limits
pursuant to 40 CFR §264.94(b). Since these
levels do not assume a point of exposure beyond
the site boundary, the restrictions in Section
121 (d) (B) (ii) of SARA do not apply.
Under the proposed remedy, it is expected that
all hazardous substances will be removed from
the site with the possible exception of ash
from incineration. RCRA closure regulations
are generally relevant and appropriate to
this site since known hazardous substances in
significant quantities were disposed of at the
site. (Since this disposal occurred prior to
November 19, 1980, these regulations are not
"applicable" under SARA.) The proposed remedy
will have the effect of removing all hazardous
waste pursuant to 40 CFR §264.113(a). Because
-------
TABLE 17 (continued)
Michigan Hazardous Waste Manage-
ment Act (Act NO. 64, P.A. 1979)
Michigan Water Resources Commis-
sion Act (Act No. 245, R323,
Part 22) Groundwater Quality
Michigan Wetlands Protection Act
(Act No. 203, P.A. 1979)
CWA 40 CFR parts 401 and 403,
or any applicable stricter local
limit contained in the ordinance
adopted by the POTW.
This regulation outlines general
requirements for management
of hazardous waste facilities
in Michigan.
Ttiis regulation outlines the rules
to protect the public: health and
welfare and to maintain the quality
of groundwater in all usable
aquifers for individual, public,
industrial and agricultural water
supplies.
Outlines requirements for conserva-
tion of wetlands whose capacity
for erosion control serves as a
sedimentation area and filtering
basin absorbing silt and organic
matter.
Set standards for discharges to a
publicly owned treatment works
facility.
all hazardous waste will be removed, the land-
fill closure regulations at 40 CFR §264.310 are
neither relevant nor appropriate. As discussed
in the text, the ash from the incinerator will
be disposed of in accordance with RCRA regula-
tions in the event it is determined to be a
hazardous waste.
During the implementation of any site ac-
tivities, .these requirements will be considered
and followed when appropriate.
Actions required to maintain ambient quality
of the groundwater onsite.
Actions required to maintain the soil erosion
control capabilities of the wetlands onsite.
Any discharge to a POTW must meet these
standards.
-------
TABLE 17 (continued)
Phase III ARARs
Requirement Synopsis
RCRA - Incinerators (40 CFR
264.300 - 264.339)
CWA - 40 CFR Parts 122,125
SDWA - 40 CFR Part 144
TSCA - Marking of PCBs and
PCB items (40 CFR 761.60 -
761.79)
TSCA - Storage and disposal
(40 CFR 761.60 - 761.79)
These regulations detail the
design, construction, operation,
maintenance performance standards,
operating requirements, monitoring
and inspection of a RCRA hazardous
waste incinerator.
Any point source discharges must
meet NPDES permitting requirements
which include: compliance with
applicable water quality standards;
establishment of a discharge moni-
toring system; and routine com-
pletion of discharge monitoring
records.
These regulations restrict injec-
tion into the groundwater by means
of certain categories of wells.
PCB storage areas, storage items,
and transport equipment must be
marked with the ML mark.
This regulation specifies the
requirements for storage of PCB
articles in excess of 50 ppm.
Action to be Taken to Attain ARARs
The onsite incinerator must achieve a destruc-
tion and removal efficiency of 99.9999% of the
Principal Organic Hazardous Constituent (PCB)
and 99.99% for other organics. HCl stack
emissions will be controlled to no greater
than the larger of 1.8 kg/hr or 1% of the HCl
in the stack gas prior to pollution control
equipment.
Groundwater which has been treated by onsite
treatment processes will be discharged to
surface waters onsite. Treated groundwater
will be in compliance with applicable water
quality standards. ' In addition, a discharge
monitoring program will be implemented.
Routine discharge monitoring records will be
completed.
In the event that extracted groundwater is
injected into the groundwater, the under-
ground injection Control regulations set forth
in 40 CFR Part 144 must be complied with. It
is expected that any such discharge will com-
ply with applicable regulations that ensure
there will be no adverse impact on health as
a result of such discharge. Compliance will
be reviewed depending upon analysis of the
extracted water.
All storage areas, drums and equipment used
for PCB contaminated soils will be labelled
appropriately.
Storage areas containing PCB contaminated
soils in excess of 50 ppm will be constructed
to comply with this requirement.
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TABLE 17 (continued)
TSCA - Records and Reports
(40 CFR 761.18 - 761.185;
129.105,750)
CM - NAAQS for Total
Suspended Particulates
(40 CFR 129.105,750)
Protection of Archaeological
Resources (32 CFR Part 229,4;
43 CFR Parts 107, 171.1 -
171.5)
D.O.T. Rules for the Trans-
portation of Hazardous
Materials (49 CFR Parts 107,
171.1 - 171.5)
Michigan Surface Water Dis-
charge Permits (MWA PDES)
RCRA - Identification and List-
ing of Hazardous Waste (40 CFR
261)
Michigan Air Pollution Control
Commission Act (Act No. 348,
R336, Part 9) General Rules
This regulation outlines the
requirements for recordkeeping
for storage and disposal of
>50 ppm PCB-contaminated items.
This regulation specifies maximum
primary and secondary 24-hour con-
centrations for particulate matter
These regulations develop pro-
cedures for the protection of
archaeological resources.
This regulation outlines pro-
cedures for the packaging,
labeling, manifesting, and
transportation of hazardous
materials.
Outlines measurements for getting
a surface water discharge permit
in the State of Michigan.
This regulation specifies the
characteristics of Hazardous Wastes
(CHW).
Outlines requirements for prohibit-
ing emission of air contaminants or
water vapors in quantities that
cause, alone or in reaction with
other air contaminants, either of
the following: (a) Injurious effects
to human health or safety, animal
life, plant life of significant
economic value or prope , (b) Un-
reasonable interference ..^ch com-
fortable enjoyment of life and
Records will be maintained during remedial
action in compliance with this regulation for
all materials containing PCB concentrations
in excess of 50 ppm.
Fugitive dust emissions from site excavation
activities will be maintained below 260 ug/m3
(primary standard) by dust suppressants, if
necessary.1
If archeological resources are encountered
during soil excavation, work will stop until
the area has been reviewed by Federal and
state archaeologists.
Contaminated materials will be packaged,
manifested, and transported to a permitted
offsite disposal facility in compliance
with these regulations.
Actions required to meet Michigan NPDES re-
quirements will be similar to those dis-
cussed as part of CWA-40 CFR Parts 122 and
125. These actions will include compliance
with water quality standards, implementation
of a discharge monitoring system and com-
pletion of discharge monitoring records.
Process ash must be evaluated for CHW prior
to disposal (onsite or offsite) or treat-
ment.
Actions required to limit emissions from
onsite units that will adversely affect
ambient air quality.
-------
TABIE 17 (continued)
Michigan Air Pollution Control Outlines permitting requirements to Actions required to obtain necessary permits
Commission Act (Act No. 348, R336, install, construct, reconstruct, re- for onsite units producing emissions.
Part 2) Air Use Approval locate, or alter any process, fuel-
burning equipment, or control equip-
ment which may be a source of an
air contaminant.
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-2a-
Discharge of any treated ground water to the west marsh will have to meet or
exceed the water .quality criteria or other specified levels found in the
Clean Water Act, the Michigan Wetlands Protection Act, and Michigan Act 245.
The emission control requirements of the Clean Air Act (CAA) and the Michigan
Air Pollution Control Act are applicable to any incinerator emissions. Parameters
of concern are sulphur oxides (SOx), nitric oxides (NOx), VOCs, other gases
and particulates. Air pollution control is a part of the ground water and soils
remedial action.
RCRA regulations for the identification of hazardous waste will be used to determine
whether or not the incinerator ash can be disposed of onsite. If the incinerator
ash is determined to be a-hazardous waste under RCRA, or if any other hazardous
wastes are transported off-site, Department of Transportation Rules for the Trans-
portation of Hazardous Materials will be applicable to any off-site transportation
of the hazardous wastes. Any hazardous waste must be also be disposed of pursuant
to RCRA.
The proposed remedy involves placement and treatment of soils and debris
wastes. Placement of wastes or treated residuals is prohibited under RCRA
Land Disposal Restrictions (LOR) unless certain treatment standards are met.
LOR standards have not been promulgated for soil and debris wastes, but when
published, the standards may be applicable or relevant and appropriate.
Despite the absence of specific treatment standards, the treatment method-
employed as part of this remedial action satisfies the statutory requirement
to, ...'substantially diminish the toxicity of the waste or substantially reduce
the likelihood of migration of hazardous constituents from the waste so that
short-term and long-term threats to human health and the environment are
minimized.1 [Section 3004 (m) H.S.W.A.]
«.
IX. Further Considerations
A Superfund Innovative Technology Evaluation (SITE) program test of an
alternative technology will occur onsite in October 1987. An infrared thermal
destruction unit will be tested to determine its effectiveness in destroying
PCBs associated with a lead-contaminated soil. The ash will be tested for EP
toxicity, and if passing, will enable it to be disposed of onsite. The amount
of lead presently contaminating the soils is insufficient to warrant reclamation
efforts.
Another alternative for ash disposal would be offsite landfilling of the
20,000 cy not passing EP toxicity testing, although this is a remote possibility.
Landfilling would add another $7,000,000 to the present worth of Alternative 3
.($41,000,000). Further onsite treatment would cost less, but further testing
' is needed before cost estimation can be made.
If the treated ground water is not dischargeable into the marshes, it may
have to either be sent to a local POTW or reintroduced into the ground water
system. Reintroduction into the ground water onsite may lead to a variation
of the thermal destruction remedy, if the treated waters are allowed to
percolate back into the water table through the excavation pit. In this
scenario, the PCB-contaminated soils are excavated and incinerated as planned.
' The treated waters, meanwhile, are drained into the excavated pit where, in
theory, the VOCs and SVOCs in the soils are flushed out into the ground
water. After the PCBs have been incinerated, the flushing mechanism will be
evaluated to see if it has reduced the volume of VOC-contaminated soils to be
-------
-29-
incinerated, which may result in a less expensive remedy. The chemicals which
may have been flushed into the ground water in this manner will be removed by
the ground water treatment technology already in place. After soils Teachability
tests during design, if this alternate method of VOCs cleanup is found to be
practical, the ROD will be reopened for public comment before implementation
of the flushing variation.
In considering reopening the ROD to provide for a flushing variation, the following
criteria will be evaluated:
(i) economy of scale - depending on the amount of PCBs that needs to be
incinerated, it may be more efficient to run the VOCs-containing
soils through as well;
(ii) community acceptance;
(iii) cleanupttime - total site remediation time is estimated to be
less than 10 years. Leaving VOCs in place may extend this time far
into the future if it causes longer ground water remediation time.
(Note: experience during design and remediation will provide a more
accurate basis for determining cleanup time with respect to a flushing
variation);
(iv) land ban regulations state that incineration is the remedy for
halogenated organic compounds in excess of 1000 mg/kg. The PCBs
appear to meet this criteria in some spots. Chlorobenzene is present
at a maximum of 570 ppm, which could be a low analysis. If so,
incineration of the soils containing this level of chlorobenzene
would tend to be favored, leading back to the economy of scale point
earlier made.
(v) reliability of the flushing variation;
(vi) implementability - the water going into the excavation pit will result
in sloppy working conditions and higher incineration costs due to wet
soils; and,
(vii) clean closure - would be most reliably accomplished by complete site
remediation through thermal destruction of PCBs, VOCs, and SVOCs in
. the Rose soils; and,
(viii) cost effectiveness.
X. Schedule:
The estimated schedule of future events is outlined below:
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-30-
Action : Date
ROD Signature 9/30/87
Design Award FY 1988 Ql
Design Completed - - FY 1989 Ql
Start Construction FY 1989 Q2
Complete Thermal Destruction FY 1992 Q2
Complete Ground Water Treatment FY 1995 - 1999
After ground water extraction and treatment operations cease, a risk assessment
will be performed to reflect the completed remedial actions, and site delisting
procedures will be initiated.
-------
Rose Township - Demode Road
Responsiveness Summary
INTRODUCTION
A public comment period was in effect from June 22, 1987 until August 12,
1987 to provide for public review of the Remedial Investigation/Feasibility
Study (RI/FS) for the Rose Township - Demode Road Superfund site. The RI/FS
had been prepared to evaluate information on the contaminants on the Site
property and to evaluate whether cleanup operations were needed to protect
human health and the environment. Copies of the RI/FS were available at the
Rose Township Hall and the Holly Library for review. A public meeting was
held oh July 1 1987. Staff from the Michigan Department of Natural Resources
(MDNR) and the U.S. Environmental Protection Agency (U.S. EPA) explained the
RI/FS to local residents and other interested parties, answered questions,
and received comments.
This responsiveness summary outlines comments and questions posed at the
public meeting, comments received in writing, and Agency responses.
BACKGROUND
The Rose Township Superfund Site is located oh Demode Road in Rose Township,
Oakland County, Michigan. Currently it is ranked #161 on the National Priorities
List. ' '
It has been documented that from 1966 to 1968, and possibly until 1971,
a portion of the property was being used for disposal of waste materials.
Both liquid and solid industrial wastes were dumped at the site.
Site investigation work has revealed ground water contamination under the
site. Soil boring and test pitting operations showed that extensive soil
contamination exists as well. The contamination provides risks to receptors
in the form of potential ingestion of contaminated ground waters and potential
contact with contaminated soils.
The RI/FS evaluated a number of alternatives and recommended the use of a
cost effective, fully protective, permanent remedy to reduce the risks to
receptors to acceptable levels.
COMMENTS AND RESPONSES
A. Public Comments.
The only written public comments addressing the RI/FS and the proposed remedial
action plan were received from the Potentially Responsible Party (PRP) Committee.
These are addressed in Part B. Because the public meeting also concerned the
Superfund Innovative Technology Evaluation (SITE) test of an infrared thermal
destruction unit at the Rose Site, comments dealt with both the proposed plan
in general (incineration) and the technology in detail. The following verbal
comments, expressed at the July 1, 1987 public meeting, were addressed by
either the MDNR or U.S. EPA and are documented below:
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-2-
(Note: The comments are taken from a transcript of the public meeting. Directly
quoted comments are marked by quotation marks (" "); lengthy quotations are
paraphrased and are marked by apostrophe (''). The original phrasing is left int.
however. Responses shown are also taken from the transcript.)
1. "You said there are moderate lead levels. Ten thousand parts per kilogram
i s moderate?"
Actually, the greatest amount of lead measured (in the Rose site soils)
is 1400 ppm. In comparison to another site test (to which this comment
refers) with the infrared device, this is a moderate level. At the Peak
Oil Site in Florida, lead levels are greater than 10,000 ppm.
2. "You talk about the lead would become immobile and if I understand it
correctly, if the demonstration is successful then the soil would be
actually left right at the site. Is that correct?"
If the lead is immobilized such that the ash passes the EP toxicity test,
the ash will be backfilled on site. If the ash does not pass EP toxicity,
further treatment (not incineration) or land disposal will be necessary.
3. "What's going to be contained in the steam plume [of the infrared unit]?"
Oxygen, carbon monoxide, carbon dioxide, water, and possibly oxides of sulfur
and nitrogen.
4. "Is that going to be monitored?"
Yes, continuously.
5. "...with an alarm?"
Yes. The presence of only those gases (in comment 3, above) is evidence
of complete combustion. If, for example, a low 02 sensor would be tripped,
the soil would stop feeding into the unit until 02 rises to acceptable
levels.
6. "If you condense the entire amount of product [lead] in the soil, how big
of a brick would that make?"
(An estimate of the amount of lead present was sent to the questioner.)
7. "Once the thermal destruction unit is in steady state operation what is the
emitted noise level?"
No ear protection is required. It's very quiet. What you'll hear are
motors and blowers for the most part (according to the Shirco manufacturer's
representative).
8. 'How long to thermally treat the entire 50,000 cu. yards?'
Between two and three years, at most.
t
9. 'What are the capital cost considerations for this technology?1
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-3-
Capital costs are based on contractor installation, labor and machine
purchase costs, electrical costs, and other services and chemical costs.
For a breakdown, see Appendix K of the RI/FS.
10. 'According to your literature, you'll end up with ash and scrubber water
wastes. Either one could still be contaminated and have to be hauled
from the site or stored onsite. Why bother burning it up? Why go through
the $34 million if you're going to have the same stuff there?'
The purpose of thermal destruction (or any remedy) is to reduce the
hazards on site. Incineration will destroy PCBs and VOCs, both major
hazards. True, the metals won't be destroyed, but what may happen is
they will be rendered immobile and thus less hazardous. Further treatment
may be necessary for the waste water and/or ash. This will be determined
during the SITE test.
11. 'The typical excavation doesn't go more than 14 feet deep either, right?' _..
For this site, maximum excavation depth is 14 feet in a limited area.
12. "Now your test well showed contamination down to 90 feet."
Yes, in the ground water.
13. 'Heavy metals will still be present in the soils after the plume is
extracted to re-contaminate the ground water.1
. Metals tend to leach very slowly. Once the surface contamination is treated
to pass EP toxicity, risks from heavy metals will be minimized.
14. 'Why can't the site be fenced immediately, rather than waiting, no matter
what the chosen alternative is? The cost is lower now than what they
will be a year from now.'
True, costs will be lower now, but a design phase must be conducted first.
The most hazardous spots have been fenced already, however. The proposed
fence is mainly for safety's sake during construction and operation and
maintenance.
15. 'Why can't the additional monitoring wells be sunk now [to provide more
data to evaluate during design]?'
U.S. EPA can't fund this until the design phase. MDNR doesn't have the
manpower to do it by themselves.
16. "What's the chance in getting it [design] started and the Superfund drying
up again?"
Very low. There are 4 1/2 years left and $8.5 billion allocated for this
appropriation. Money has been planned for and set aside for the design.
17. "Is that money allocated where it can't be sponged off for another project?"
Although there have been problems in previous years due to Superfund
drying up, the present authorization should be adequate to fund all sites
that are ready to start during the next 4 years.
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18. 'What is the schedule for the next steps in the cleanup process?1
After signing of the Record of Decision in September, the State will apply
for a Cooperative Agreement for design funding in October. Design should
take 1 year or less. Remedial Action is planned to start in late 1988.
19. "Would it be safe to double those times based on past performances?"
These scheduled times should remain fairly firm.
20. "How often are you testing the monitoring wells?"
Testing will occur yearly. Domestic wells are due to be tested by the
Health Department in July (1987).
21. "What kind of flap do you anticipate ... from surrounding communities ...
like Springfi&ld Township who will be downwind of that, White Lake and
all others?"
The remedy has been widely advertised in local papers and the Detroit
News in an attempt to gauge public sentiment. Only twenty to thirty
citizens showed up at the open house (held June 30, 1987) and none
seemed dead set against the SITE test or chosen remedy.
22. 'Which soils do you plan to test, the most highly contaminated or the
more moderately contaminated?'
The soils that are most highly contaminated with PCBs and lead will be
tested in the infrared unit.
23. 'What other incinerator units have been looked at to satisfy the chosen
remedy?'
Rotary kiln incinerators are also permitted to destroy PCBs.
24. "Are we going to have any kind of liaison between the township or the
officials and the residents and yourself if this site goes in operation
so we know more what's going on?"
There's going to be several MDNR personnel to contact. Thor Strong is
the public involvement specialist for this site.
25. 'What are the plans as far as emergency action if there is a problem with
the unit?1
A site safety plan will be drawn up before operation, and it will include
fire department coordination.
26. 'Will we have another public meeting prior to any action?1
When the full scale unit goes onsite, another public meeting will be held.
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27. 'Why not remove the PCBs and metals and sell them to someone else?'
The concentrations of site chemicals are not high enough to warrant
recycling. PCBs are not sold any longer. Lead is present in a low enough
concentration that is it less bothersome to treat the soil and leave the
metals in place.
28. 'With the pre-burner in the unit at 1850°F - isn't that hot enough to release
that lead right out of there?'
Since the furnace will be operating at 1600° F the lead should stay right
in the soil. The SITE test should show that.
29. "Higher temperatures could be more efficient for removing the compounds
wouldn't it?"
No. Higher temperatures require higher energy input levels. Thus, lower
temperatures would cost less.
30. 'Why doesn't the DNR buy their own infrared unit to take from site to site
for cleanup?'
Competition with private industry is not favored by State law. Also, the
MDNR is unwilling to assume any liability due to their cleanup performance.
31. "Earlier you talked about cost recovery efforts. Are you thinking about
litigation?"
Yes. Both the State Attorney General's Office and U.S. EPA. Regional
Counsel are involved.
32. 'How does the site compare to others-is this one of the first to be
cleaned up under your program?'
This site is one of three to come this far through public comment on a
final RI/FS. (Others are Novaco and Burrows)
33. "Are there large viable companies involved with this site?"
Yes.
34. Two local residents were interviewed by Channel 7 (of Detroit) as to
their views concerning the site remedy. One remarked that the cleanup
levels 'exceeded all her expectations for action at the site.1 The other
remarked that he thought 'it was the best thing to happen to the site in
a long time.' The interviews aired July 1, 1987 on the local news program.
The U.S. EPA acknowledges the public support for the chosen remedy.
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B. PRP Public Comments.
The joint PRP Committee has provided three volumes of comments on the RI/FS and
the recommended alternative. One set of comments specifically addressed the
RI/FS and provided the PRP's own risk assessment and feasibility study.
Another set rails against the proposed plan as being (1) inconsistent with
the law, and (2) arbitrary and capricious. Since the Rose project is a State
lead, the MDNR will address the technical issues (part 2). Part 1 deals with
the selection of alternative comments.
1. Selection of Alternative
The comments contained herein are from the document entitled: "Comments
Submitted to EPA Region V On Behalf of the PRP Group at the Rose Township -
Demode Road Site" .("the document").
a. Page 1 of the document determines 'that the selection of thermal destruction
as a remedy for the Rose Site is inconsistent with the law (CERCLA as
amended by SARA) and is arbitrary and capricious. The costs of implementing
this remedy cannot be recovered by the EPA as a result.1
The decision to remedy the site using thermal destruction will be defended
in the following section as comments are responded to point by point.
Thermal destruction was not arbitrarily arrived at as a remedy. EPA believes
that cost recovery will not be denied as a consequence.
b. 'The major flaws in the Record include EPA's:
(i) Failure to obtain sufficient data before selection of remedy
(ii) Failure to identify PRPs adequately
(iii) Failure to provide for meaningful PRP participation in the formation
of the administrative record
(iv) Failure to place all decision-making data into the administrative
record for the PRPs.'
(Responses)
(i) Based upon EPA, MDNR and E.C. Jordan's (RI/FS contractor) best professional
judgement, sufficient information is available concerning the Rose site to
show that (1) potential substantial risks to receptors exist on site, (2)
chemicals causing these potential risks need to be rendered risk-free
(within established limits) to receptors, and (3) appropriate methods to
deal with the chemicals may be identified and one or more selected to be
implemented. The NCP does not list the exact number of water samples (for
example) needed for a complete RI/FS. Instead, §300.68 (e) (2) deems that
the factors (i through xvii) listed shall, as appropriate, be assessed in
determining whether and what type of remedilT (and/or removal) actions
will be considered. Selection of a remedy [§300.68(i)] is based upon
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determining a cost-effective remedial alternative that effectively mitigates
and minimizes threats to and provides adequate protection of public health
and welfare and the environment.
The Superfund Amendments and Reauthorization Act (SARA), which super-cedes
the NCP, iterates the need for treatment of contamination in a .permanent
manner (Section 121).
(ii) Section 113(k)(2)(D) provides that the President "shall make reasonable
efforts to identify and notify PRPs as early as possible before selection
of a response action. Nothing in this paragraph shall be construed to
be a defense to liability." .
U.S. EPA notified seven of the PRPs of their potential liability at the
Rose Township site in October of 1982. U.S. EPA has reviewed MONR files
and the court files from private lawsuits in an attempt to notify all PRPs.
U.S. EPA has 'also told the identified PRPs that if they have any information
linking more parties to the site, it would be reviewed and appropriate action
would be taken. If the PRP committee knows of additional evidence linking
other parties to the Rose Site, U.S. EPA welcomes its receipt.
(iii) U.S. EPA has told the PRP committee that its comments on the proposed plan
made to U.S. EPA prior to the closure of the Administrative Record will be
incorporated into the Record.
(iv) The Administrative Record for the Rose site will include all of. the data upon
which U.S. EPA based its decision.
c. 'The remedy selection decision is arbitrary and capricious because it:
(i) fails to consider cost as required by CERCLA, the NCP, and EPA
guidance, especially an unproven technology as selected
(ii) fails to properly assess present and future risk
(iii) fails to compare risks of the selected alternative's performance
versus performance of other alternatives
(iv) fails to consider all risks associated with construction and
transportation activities of each alternative
(v) fails to consider further in situ containment remedies
(vi) improperly rejected in situ containment remedies during the selection
process
(vii) fails to recognize the diminished benefit of thermal destruction
technologies at this site
(viii) uses an inappropriate ground water contaminant model to predict
future concentrations of chemicals which may be migrating from
the site.1
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(Responses)
(i-viii) All.relevant statutes and guidances were followed in evaluating riskr
costs, and health benefits during screening of alternatives and the
subsequent identification of onsite thermal destruction as a preferred
remedy. Since these comments are vague as presented here and are expanded
upon later in the document, the individual points will be responded to
at that time.
d. 'The administrative record and the RI/FS do not follow general principles
of administrative law, in that they:
(i) contain an inadequate level of detail;
(ii) do not describe the technical rationale for each conclusion reached;
(iir) do not provide an explanation of the weight that EPA placed on each
factor in the NCR and CERCLA, as amended by SARA; and,
(iv) do not indicate when professional judgement was relied upon nor do
they identify whose professional judgement was relied upon.1
Section 113(k)(l) of CERCLA requires that an administrative record be established
upon which the selection of a response action will be based. Pursuant to this
section, an administrative record has been prepared for the Rose site. U.S. EPA
feels that this administrative record contains sufficient information to support
U.S. EPA's proposed plan for this site. .
The following section addresses more specific comments.
e. The PRP group suggests that 'two months of official public comment time is
within the reasonable time frame to comment as required by Congress.
Without inclusion of requested documents in the Record, EPA's decision
will be based on a defective Record and will be arbitrary and capricious.1
According to the NCP (§300.67 (d)), public comment periods are to last not
less than 21 days. Public meeting(s) shall be held during this time
period. The RI/FS was available to the public on June 22, 1987.
Officially, public comment started June 29, 1987 as advertised in a local
newspaper (Holly Times). As noted by the PRPs themselves, the comment
period was extended to August 12, 1987 from July 29, 1987. Thus, an
official comment period of 44 days was available to interested parties,
more than twice the mandatory time period. SARA does not set a time period
for public comment, only allowing a "reasonable" time period to comment
(Section 113 (k)(2)(B)).
The PRP Committe must also be reminded that some of the PRPs were notified
of their potential liability in 1982. Depositions taken in private lawsuits
in 1981 and 1982 also made the PRPs aware of their potential liability at the
Rose site. The RI/FS start was a matter of public record. If technical data were
needed for review, all the Committee had to do was request them. It is unfair
for the PRPs to wait over 40 months to request the data and then claim that U.S.
EPA is at fault for their (PRP's) inability to review all of the technical data.
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, 'Failure of the EPA to take all comments into account "at all stages of
remedial action" is a violation of due process. Surely it would be a
deprivation of due process to require PRPs to pay $42 million without any
hearing and with little opportunity to evaluate EPA's technical position,
no less confront EPA's experts.1
Sections 113(k) and 117 of CERCLA outline the procedures that U.S. EPA
must follow concerning public participation in the RI/FS process. Section
113(k) requires that U.S. EPA prepare an administrative record upon which
the selection of a response action will be based. Section 113(e)(2)(B)
provides that interested persons be allowed to participate in the development
of the administrative record. "Section 117 states that before the adoption
of any remedial action, U.S. EPA must publish notice of the planned remedial
action, provide for a reasonable opportunity for submission of written
and oral comments, and provide an opportunity for a public meeting at or
near the facility regarding the proposed remedial action.
As stated earlier, U.S. EPA has prepared an administrative record for the
Rose Township site. U.S. EPA has also notified and provided the public
with an opportunity to comment on the RI/FS. U.S. EPA held a public meeting
on July 1, 1987 to discuss the proposed remedial action for the site. In
addition, U.S. EPA has told the PRP group that prior to closure of the
administrative record, all of the comments made by the PRP group during
negotiation sessions with U.S. EPA concerning the selection of remedial
action at the site will be part of the administrative record.
The PRP group seems to suggest in their comment that their due process rights
would be violated if they are not afforded a hearing and an opportunity to
confront EPA's experts. However, Section 113 (j) of CERCLA specifically
states that "In any judicial action under the act, judicial review of any
issues concerning the adequacy of any response action taken or ordered by
the President shall be limited to the administrative record".
Recently, in United States v. Seymour Recycling Corp., et al., IP 80-457-C,
the United States District Court for the Southern District of Indiana,
Southern Division, specifically held that "judicial review of EPA's remedy
selection on the basis of the administrative record will be in accord with
the requirement of due process". (See court order of July 14, 1987).
, 'EPA did not comply with CERCLA, SARA, and the NCP in selecting the remedial
alternative at the site. In selecting a remedy, EPA must consider:
(i) alternatives which do not attain, meet, and exceed Federal and State ARARs;
(ii) alternatives which give a preference to remedial actions in which treatment
which permanently and significantly reduces the volume, toxicity, and
mobility of the hazardous substances, pollutants,, and contaminants is
a principal element;
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(iii) the short and long-term potential average health effects;
(iv) the feasibility of alternatives;
(v) the significant adverse effects and environmental benefits of each
alternative. CERCLA, as amended by SARA, specifically requires the
consideration of the potential risks associated with excavation and
transportation of wastes and contaminated soil.
(vi). the long-term uncertainties associated with land disposal and the goals,
objectives, and requirements of the Solid Waste Disposal Act;
(vii) the persistance, toxicity, .mobility and propensity to bioaccumulate of
the chemicals involved;
(viii) the costs; and
(ix) the degree of support for the alternative by parties interested in the
site.'
(Responses)
(i) See the No-action alternative as described in the RI/FS.
(ii) Alternative 3, which addresses this issue, is described 1n the RI/FS.
(Hi) All alternatives discuss this in the RI/FS.
(1v) See the FS.
(v) See the discussion for each alternative. Section 121(b)(1)(G), as
partially quoted in the comment above deals with the consideration of
risks involved with excavation and transportation (of contaminants)
for redisposal or containment, which was done in the FS for Alternatives
2 and 4.
(vi) See the Alternatives Analysis in the FS.
(vii) See Section 7.5.2 of the RI/FS for discussion of bioccumulation.
viii) -See the Detailed Analysis of Alternatives in the FS.
(ix) As a proposed, not chosen, remedy was presented to the public at the
July 1, 1987 public meeting, the degree of support by parties interested
in the site is being gauged. Recall in part A, comment 34, that two
local residents were interviewed concerning the proposed plan and
they expressed their support for the proposed project.
h. 'EPA may also select an alternative that does not meet ARARs when:
(1) The alternative is not the final remedy but will become part of a more
comprehensive remedy;
(ii) The remedial action will attain a standard of performance equivalent to
the ARARs;
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(iii) The State has not consistently applied (or demonstrated the intention
to consistently apply) a State ARAR in similar circumstances at other
sites within the State; and,
(iv) The need for protection of public health and welfare and the environment
at the site is out-weighed by the need for action at other sites which
may present a threat to public health or welfare or the environment,
. considering the total amount of money in the Fund.
EPA must consider and weigh these various factors and select a remedy that
protects public health and the environment and is cost-effective.'
(Responses)
U.S. EPA has weighed all pertinent factors before recommending the proposed
plan. See the RI/FS and the Record of Decision for a thorough review. Recall
that:
(i) The proposed plan is intended to be a final remedy. While EPA may
consider such an alternative (that does not meet ARARs), the proposed
plan is more protective-of long-term public health and the environment.
(11),(111) U.S. EPA may consider, but is not bound to select such an alternative
(Section 121(d)(4).)
(iv) This site presents a potential risk to human health and to the environment.
The proposed plan provides a cost-effective remedy for these risks.
i. 'Containment is a legally permissible remedy. The pre-SARA CERCLA did not
prohibit containment as means of remedy dealing with inactive landfills.1
Post-SARA CERCLA does not prohibit the containment option, either. However,
Section 121 (b) relates that treatment options are to be preferred over non-
treatment options. Please note that the Rose site involves a "midnight
dumping" site, not an inactive landfill.
j. 'SARA does not require a permanent remedy in every case. SARA expresses a
preference for such a remedy, but only when it is cost-effective.1
True, SARA does not require a permanent remedy (see response to i). It
does require us to consider the long-term uncertainties associated with land
disposal, and the potential for future remedial action costs if the alternative
remedial action in question were to fail. Containment remedies fit these
categories, thermal destruction does not. (Section 121(b)(l)(A) and (F)).
For a discussion of remedy selection and cost-effectiveness, see Section VIII
of the ROD.
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k. 'In the "real world" decision making required by SARA, one must balance the
facts: (a) there is limited incineration capacity; (b) the infrared thermal
destruction units are of an innovative nature and unknown reliability; (c)
the cost of thermal destruction is substantial, and (d) the benefit of
thermal destruction of some wastes, particularly soils containing non-
homogenous wastes, which include VOCs and metals, is questionable.'
The ROD does not specifically choose an infrared thermal destruction unit
as the remedy. The ROD chooses onsite thermal destruction as the remedy.
If an infrared device will not perform adequately, a rotary kiln device is
an alternative. The infrared device is preferred, because it affords the
same degree of VOC and PCB destruction as the latter device, although at
an apparently lower cost. The estimated cost of thermal destruction
in somewhat higher than the non-proposed remedies. However, the remedy is
cost-effective due to its capability to permanently destroy major contaminants
onsite. SARA does not preclude the use of an innovative and unknown technology,
but rather encourages its use depending on the degree of "interested party"
support (Section 121 (b)(2)). The question as to whether an infrared unit will
perform adequately has been answered by previous testing. After the SITE program
to be held onsite in October 1987, the time EPA and MDNR will assess whether
the technology will effectively handle the Rose site waste.
1. 'An in situ containment remedy is consistent with a "permanent" remedy
since it would significantly reduce the mobility of any contaminants present
at the site.'
EPA acknowledges the possibility of an in situ containment remedy being
applicable if a permanent technology were not implementable at the site.
However, the recommended remedy does a better job (and thus is "preferred"
by Section 121 (b)) in reducing the volume and toxicity (and even the
mobility of the indestructable metals) than any in situ containment remedy
that is currently technically feasible. Please recall that the possibility
of future remedial action (and costs) would exist if the waste would still
exist in its present form (Section 121(b)(l)(F). Also, containment would not
prevent the migration of contaminated ground water offsite.
m. 'EPA must "indicate the extent to which the release or threat of release
may pose a threat to public health or welfare or to the environment." It
must also consider the "extent to which Federal environmental and public
health requirements are applicable or relevant and appropriate to the
specific site, and the extent to which other Federal criteria, advisories,
guidance and State standards are to be used in developing the remedy" (40
. CFR §300.68 (e)(l)).'
U.S. EPA has considered these points, as found in the RI/FS and the Record
of Decision.
n. 'EPA must assess "the extent to which the alternative is expected to
effectively present, mitigate, or minimize threats to, and provide adequate
protection of public health and welfare and the environment." (40 CFR
§300.68 (h)(2)(1v)).'
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See response to comment m, above.
o. 'EPA is also required by CERCLA to compare risks of the alternatives to
ensure that the risks of implementing a remedy do not outweigh its benefits.
The NCR provides that an alternative which does not meet ARARs or standards
may be chosen if a remedy which satisfies all ARARs or standards would pose
greater risks.'
40 CFR 300.68(g)(3), cited in the document, states that "if an alternative
has significant adverse effects, and very limited environmental benefits,
it shall also be excluded from.further consideration." The recommended
alternative has great environmental benefit in that the organic contaminants
will be permanently destroyed and the heavy metals will possibly be
immobilized.
p. 'Consideration- of costs is a central factor in selecting CERCLA remedies.1
Consideration of cost is one of several central factors in selecting site
remedies. See especially Section 121(a) and (b) of SARA.
q. 'The NCP specifically requires the "selection of a cost-effective remedial
alternative that effectively mitigates and minimizes threats to and provides
adequate protection of public health and welfare and the environment."1
EPA agrees with the above comment, and adds that SARA (Section 121) mandates
preference for selection of such alternatives.
r. 'The NCP specifically lists costs first among the factors to be considered
in selecting among remedies which adequately protect public health and the
environment.'
Comment noted. See response to p., above.
s. 'Cost is also considered when determining whether the alternative is technically
practical to implement at the specific site. This is particularly true where
the purported benefits of an innovative technology may not be realized (i.e)
having to landfill soils subjected to thermal destruction due to their content
of heavy metals.'
Once again, Section 121(b)(2) of SARA allows EPA to select a remedial action yet
unproven at another site. Section 121(b)(l) encourages the use of permanent
solutions and alternative treatment technologies. Based on available data, the
infrared unit has been proven to perform well on Rose-type wastes. Therefore,
it is likely that infrared thermal destruction will effectively and cost-
effectively clean up the site. If the pilot test proves otherwise, a rotary
kiln device will be tested. If thermal destruction proves to be impractical,
EPA will have to consider implementing another remedial alternative.
t. 'Cost also is important in deciding whether CERCLA's Fund balancing test applies.'
EPA agrees with the comment.
u. 'EPA draft guidance also states that:
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"Where the leachate migration potential from contaminated soils or mixed
waste is small, and/or the toxicity of the leachate is low, land disposal
will be the cost-effective, highly reliable management alternative.[From
interim criteria for Selecting Alternative Technologies, February 6, 1986,
Henry Longest II, Director's Office of Emergency and Remedial Response, to
Waste Management Directors and Regional Counsels.]'
The above quoted memorandum has been superceded by an Office of Solid Waste
and Emergency Response (OSWER) Final Directive entitled: Interim Guidance
on Superfund Selection of Remedy, dated December 24, 1986. (Directive
Number 9355.0-19) The directive is from 0. Winston Porter, Assistant
Administrator, to Regional Administrators, Directors of Waste Management
Divisions, and Regional Counsels. It states that "cost is an important
factor when comparing alternatives which provide similar results." And,
"cost may be used to discriminate among treatment alternatives, but not
-between treatment and non-treatment alternatives" (p5). In other words,
in situ non-treatment of soils, favored by the PRPs, is not the better
alternative solely because it is less costly than the EPA recommended
alternative.
v. 'In consideration of the Public preference for a remedy, nothing in CERCLA
or its legislative history indicates that Congress intended that EPA
abdicate its reponsibility to make informed remedial decisions and simply
allow the public or a state agency to thrust a remedy upon it. Congress
did not intend by including Section 121 (b)(2) in SARA that EPA ignore or
give less weight to the other factors in SARA, particulary costs. EPA
cannot select a non-cost-effective remedy simply because the State of
Michigan or some member of the public demands it.1
EPA realizes that public preference (Section 121 (b)(2)) is not the only de-
ciding factor in selecting a remedy for a site. Recall that EPA and the State
present the alternatives to the public and show which remedy is recommended.
The public's role is to provide comments with respect to the proposed plan
(Section 117). No member of the public nor of the State Agency "demanded"
that thermal destruction be used onsite. Rather, it is an alternative
that they generally agree on as being the appropriate cleanup remedy for
this site that satisfies the requirements of the NCP and of SARA.
w. 'EPA also should not ignore the concerns of the community members who live
near the site. It is likely that the enthusiasm for excavation and thermal
destruction of the wastes would be considerably less among those citizens.'
From the response at the July 1, 1987 public meeting held in Rose Center,
Michigan, it appears that the citizens who live closest to the site are very
enthused about onsite thermal destruction in contrast to the responsible
parties who live far removed from any dangerous wastes.
x. 'In sum, EPA must balance the needs of all the public, not just those of
the state officials or citizens who live in the immediate vicinity of the
site. Herein, the PRP groups raise substantial concerns about the
soundness of EPA's preferred remedy. Each individual error is enough to
make EPA's decision arbitrary and capricious. The sum total of these errors
renders EPA's decision fatally flawed.'
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The preferred remedy has been chosen according to statutes and EPA guidelines.
Public opinion has been weighed carefully. Our proposed plan has not
been arbitrarily chosen and the decision is based upon Congressional intent
to cleanup and destroy (where possible) wastes rather than leave them in
the ground where found.
y. 'The lack of data to connect the chemical-bearing aquifer to the aquifer in
which the closest domestic drinking water wells lie (is the reason that)
EPA's premise that protection of a drinking water supply is the basis for
selection of an excavation and thermal destruction remedy is unsound.1
The connection of the aquifers, is logically inferred at this point. It
should be noted that ground water contamination was not the primary reason
for recommending the thermal destruction alternative. The hazards posed
by the PCBs onsite, as well as the SVOCs threatening the water table
both contributed to its selection. The ground water, to be treated by
extraction and air stripping, is protected by Michigan Act 245, enacted to
preserve all potable aquifers, currently in use or not.
z. 'Many of the backup documents for the calculations in the RI/FS are not
present on the face of the document.'
As stated in the comment document, the PRPs have submitted a FOIA to remedy
the situation.
aa. 'The decision to select the alternative was not made in accordance with the
law and is arbitrary and capricious.'
Response to this general comment has already been made in previous sections.
bb. 'E. C. Jordan's RI/FS fails to follow EPA guidance, and is so conclusory
and vague that it provides no basis for EPA's decision or for subsequent
judicial review.1
The RI/FS adequately follows the guidance and allows for a decision
that hazardous chemicals have degraded the environment and they
are also a risk to potential receptors. The ROD provides the reasoning
behind the remedy selection process.
cc. 'Specifically, .the RI/FS is arbitrary a*id capricious because it:
(1) falls to make findings required by CERCLA;
(i1) provides Inadequate information upon which to base any remedial
decisions;
(111) ignores the Congressional mandate for selectton-of cost-effective
remedies;
(1v) fails to evaluate, in a meaningful manner, the other remedial alternatives
particularly in situ containment alternatives;
(v) contains an inadequate and flawed Risk Assessment which fails to
consider the present threat to public health from the site; and
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(vi) considers local, state and federal permits (and) institutional
requirements for onsite remedial alternatives despite the fact
that the NCR clearly requires no permits.
The cost of implementing the chosen alternative thus cannot be recovered by
EPA. EPA must initiate a new remedy selection process which cures these
defects in conformance with the NCP.'
(Responses)
(i) EPA feels otherwise. The findings are in the ROD and the Administrative
Record.
(ii) See response to previous comment (bb).
(iii) Cost-effectiveness-does not mean the least-cost remedy. The "Interim
Guidance on Superfund Selection of Remedy", dated December 24, 1986,
indicates that cost is to be considered when comparing alternatives
providing the same level of protection. That is, the findings of
cost effectiveness requires ensuring that the results of a particular
alternative cannot be achieved by less costly methods.
(iv) Most in situ alternatives were screened out in the FS as being
impractical and/or not protective enough of the public health and
the environment. Note that Alternative 5 is a containment remedy.
(v) Rose Township is a remedial site* As such, a present and future Risk
Assessment is conducted for the site conditions.
(vi) Section 121(e) of SARA requires no permits for onsite remedies. EPA
agrees that none are needed.
Overall, the RI/FS, the ROD, and the Administrative Record demonstrate the procedures
used by EPA, MDNR, and other Agencies to evaluate alternatives and select a final
remedial plan. This process is intended to avoid an arbitrary and/or capricious
selection.
dd. ' A review of the RI/FS demonstrates that EPA failed to assess risks adequately
and correctly as required by law. The risk assessment inadequacies are:
(i) an incorrect assessment of exposure from a hypothetical well located
in the center of each plume rather than from the nearest downgradient
drinking water well as required by EPA guidance;
(ii) failure to follow the indicator chemical selection procedures;
(iii) utilization of a chemical transport model which assumes an
instantaneous input of contaminants into the aquifer rather than the
more realistic assumption of continuous input over time;
(iv) the ignoring of the data which indicates (sic) that no contaminants are
presently migrating from the site;
(v) utilization of MCLGs rather than MCLs as required by EPA guidance;
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(vi) failure to compare the risks of incineration to those of containment.1
(Responses)
(i) Risks are assessed as both present and potential exposure to receptors.
The placement of a well in the center of the plume is a worst-case
scenario and is supported by enforcement of Michigan Act '245. Act 245
serves to protect the present or future use of a potable aquifer (as
the Rose site aquifer would be if not contaminated by PRP wastes).
(ii) The selection process-for indicator chemicals as outlined in the Public
Health Evaluation Manual (PHEM) is a general guideline and not a mandated
approach. This comment is addressed further in the Technical Section
(Part 2) of the Responsiveness Summary.
(iii) The rationale for use of the chemical transport model is discussed
in the RI/FS.
(iv) Data which indicate that ^10 contaminants are presently migrating
from the site are non-existent. Some PCBs are found in the marsh
sediments, lead exceeds its AWQC in the surface waters, and the
northern vinyl chloride plume threatens to reach Demode Road in
the very near future. Seepage to the marshes is contaminated as
we! 1.
(v) Where MCLs exist, they were used. The only chemical of concern which
used its MCLG was chlorobenzene* It has no MCL, thus, the target cleanup
level (TCL) for chlorobenzene was to be calculated based on risk indices.
Since a MCLG is a health-based criterion, it is appropriate to use it
as a target cleanup level in this case.
(vi) The risks of containment were not compared further since this alternative
was screened out in the Initial Screening of Alternatives Section in
the FS.
ee. ' The risk assessment in the RI/FS at this site fails to comply with EPA policy,
methodology and guidance. It should provide a qualitative sense of the magnitude
of the existing risks presented by the site and the risk that might be presented
if a reasonable containment alternative is implemented, along with an understand-
ing of which factors control the risk.1
The risk assessment does provide a sense of the magnitude of the exisiting and
potential risks posed by the Rose site. In the detailed analysis of Alternative
5, a containment remedy, discussion of the risks of implementability is presented.
ff. 'The methodology of the ground water risk assessment is incorrect - it should
evaluate the risk of ingestion of water from the nearest downgradient drinking
water well, not from such a well in the center of each plume.'
As the PRPs noted in their comment (p28) document, EPA guidance requires
that the exposure point will be the geographic point of highest individual
exposure for a given release source/transport medium combination. This
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was done for the PCB/metals exposure routes for soils. Since ground water
is not the only significant risk onsite, a conservative approach was used
to estimate the risk to receptors. The risk to receptors at downgradient
domestic welIs is a potential risk, not a present risk.
gg. 'An objective review of the site data indicates that there is no present
significant risk.'
The comment document provides no supporting risk calculations to back this state-
ment. Seemingly, it ignores the contact hazards of the PCBs and lead, plus
environmental damage due to those chemicals. Our proposed plan is based
on potential and probable risks to receptors.
hh. 'The future risk according to EPA calculations, even if no remedy is implemented,
would be virtually zero for over 250 years. After 250 years, the risk, at worst,
would be low in an absolute sense; lower than the risk levels typically considered
by EPA as. unworthy of regulatory action; and lower than the levels permitted in
EPA's guidance for determining cleanup levels. Even this de minimis and remote
risk, however, would be virtually eliminated through the implementation of cost-
effective in situ containment measures.'
The future risks to potential receptors have been shown (in the Risk Assessment)
to exceed the target risk range (10~4 to 10"7) far into the future. The ground
water plumes are spreading and migration offsite will occur. The U.S. EPA
would be remiss in its duties to protect the environment if it were to allow
a known treatable source to further degrade a large expanse of a potable aquifer.
Soil contact risks are ignored in this comment. - These.also are not zero at
present or in the future. EPA questions whether an in situ containment remedy
will prevent ground water plumes from migrating downgradient in the future.
ii. 'The most significant errors in EPA's assessment of risk include the improper
use of EPA maximum contaminant levels (MCLs) and maximum contaminant level
goals (MCLGs) as ARARs.1
Where found, noncarcinogen MCLs were used as target cleanup levels (TCLs)
for the Rose site. Where multiple contaminants exist, the MCLs were
reduced accordingly to allow for these multiple risks. For carcinogens,
MCLGs are all zero, which of course, are technically impractical. MCLs
yielded unsatisfactory risk levels for the target chemicals in the plumes.
Thus, risk-based target cleanup levels were calculated. Vinyl chloride,
for example, has a 10~6 health risk-based TCL of 15 ppt (northern plume),
but the detection limit is higher than this value. Thus, the TCL is essen-
tially at non-detectable values for this chemical.
jj. 'EPA failed to use the 100 ppm arsenic soil advisory level determined by
ATSOR as "safe". Even though 10 ppm is within the range of the background
level of arsenic (1 to 14 ppm), actual measurements of uncontaminated
soil may indicate a higher background. EPA failed to adequately characterize
the background levels of arsenic, which may result in EPA excavating and
incinerating larger quantities of soil containing no chemicals attributable
to the site (i.e. arsenic).'
Currently, EPA is re-evaluating the arsenic soil TCL in light of this
comment. The matter will be resolved before a ROD is signed. Arsenic in \
the ground water does have a MCL of 50 ppb, however.
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kk. 'Additionally, EPA failed to consider its own 25 ppm soil cleanup advisory
level for PCBs. Although recently characterized by EPA as not presenting an
unreasonable risk, the RI/FS arbitrarily uses 10 ppm (as a TCL).'
Again, the PCB TCL is a health-based cleanup level. EPA has also received
comment from the U.S. Department of the Interior Fish and Wildlife Service
concerning the PCBs on the Rose site. Before it will release natural
resources liability, the Fish and Wildlife Service would like to see a PCB
TCL of 0.1 mg/kg for soils on site. (This value is based on protection of
wildlife).
11. 'The following criteria cause a failure to properly assess present and
future risk due to site contamination and subsequently exaggerated the
the risk from the site. This causes EPA to propose a non-cost-effective
remedy to protect against this exaggerated risk:
(i) The-use of chemical contamination levels in the center
of the ground water plume to estimate the present and
future risk, rather from the nearest drinking water well;
(ii) Faulty selection of indicator chemicals in performing the
risk assessment; and
(iii) The use of questionable chemical transport model and faulty
input parameters to establish future risks;1
(Response)
Each of these parameters have previously been discussed and need not be
treated further.
mm. 'The PRPs question the value of the risk assessment since the linear
extrapolation model for estimating carcinogenic risk from exposures at low
chemical concentration levels is uncertain.'
The MDNR and EPA choose to handle risk assessments with methods that are
scientifically documented and currently used in the Toxicity field. The linear
multi-staged extrapolation model is one of the few well-established models
currently in use. As the PRPs noted in their comment document (p37), the results
of a risk assessment are not a measurement of the "real" concern risk but a
"plausible upper limit to the risk [calculated for regulatory purposes] that
is consistent with some proposed mechanisms of carcinogenesis..."
nn. 'Virtually all EPA and other federal regulations require action to reduce
risks only when the lifetime upper-bound cancer risk is in the range of 10~4
to 10"7 level. EPA often uses the 10~5 cancer risk level as an acceptable
risk management level.'
Region V policy is to attain the 10~6 risk level for complex contaminant
mixtures where technically feasible and cost effective.
.00. 'EPA's suggestion that the public health is threatened by the Rose Township
site is not supported by the Record, in that:
(i) the present risk is virtually zero,
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(ii) future risk would be zero for over 250 years,
(iii) after 250 years, the risk would be lower than that which requires
regulatory action.'
(Response)
These comments have been addressed previously.
pp. 'Even assuming that the public health was threatened, the proposed remedy
of thermal destruction would simply expend limited financial resources only
to concentrate the chemicals of primary concern, heavy metals, in the ash,
which would then need to be reburied [presumably means landfilled] elsewhere.
Reburial of the concentrated metals would present the same risks as in situ
containment of the original soils. Thus, nothing in the record supports
the inordinately expensive remedial measures being contemplated for this
site. Its selection is arbitrary and capricious.'
The public health is threatened, as are the environmental surroundings.
Thermal destruction is the primary treatment to deal effectively with PCBs.
Reburial of lead-containing ash that passes EP toxicity test does not
present the same risks as in situ containment remedies, as explained in the
FS. The remedy is expensive, yet cost-effective when considering alternatives
affording the same level of protection. Note that the proposed plan will
remove the continual source of ground water degradation as well.
qq. 'The risks of performing the various alternatives have not been adequately
compared as required by CERCLA and the NCR (Section 121(b)(l)(G)). The
record does not contain:
(i) Adequate discussion of risks associated with excavation and onsite
thermal destruction.
(ii) A discussion of the residual risks which could remain after the
implementation of a reasonable containment remedy,
(iii) A review of the risks of transportation offsite.'
(Responses)
(i) See the discussion of Alternative 2 and 3 in the FS for evaluation of
excavation risks and thermal destruction risks.
(ii) A discussion of containment risks was presented in the detailed
discussion of Alternative 5. The risks include future continual
ground water degradation, remedy failure, and bioaccumulation and
subsequent human exposure due to ingestion of contaminated biota.
(iii) See Alternative 2 in the FS.
rr. 'EPA has admitted the potential of significant risks from excavation and
incineration (in the RI/FS).'
Yes, there are potential risks with incineration. All OSHA regulations
will be followed to protect personnel and the environment from harm.
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If risks are shown to be too great, another alternative may need to be chosen.
However, these are mainly short-term risks associated with thermal destruction
versus long-term threats and risks associated with containment remedies. Section
121(b)(l)(A-G) of SARA tends to favor low, short-term technological risks
versus long-term health risks on site.
ss. 'Excavation and thermal destruction are:
(i) inherently risky,
(ii) extremely costly,
(iii) time consuming, and
(iv) unproven (thermal destruction) on non-homogeneous waste soils.1
(Responses)
(i)»(ii) These have been previously addressed.
(iii) Only 3 years should be needed to complete this part of the remedy.
(iv) This will be addressed by the SITE program test and during remedial
design.
tt. 'Excavation may also present significant risks resulting from:
(i) The disturbance of soil and release of chemicals into the air,
(ii) The exposure of wastes to greater moisture infiltration which would
increase chemical migration into the ground water,
(iii) Greater risks from volatilization of chemicals from the large volumes
of water which would need to be collected and treated,
(iv) The exposure of workers to chemicals,
(v) Accidents during operation of the heavy equipment.1
(Responses)
(i) This is addressed in the FS and in response to comment rr.
(ii) Ground water treatment will be occurring anyway.
(iii) The additional risk from air stripper emissions has been calculated
by the EPA to be on the order of 10~8 to 10~9. (See Appendix L).
(iv, v) Safety procedures must and will address these possibilities.
uu. 'Additional risks from disposal of ash offsite will occur. These are:
(i) Accidents and subsequent spillage during transportation,
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(ii) Chemicals tracked offsite by tires of trucks leaving the site,
(iii) Inhalation of vapors and dusts at the incinerator and at the ash
reburial site, and
(iv) Disposal risks.
Failure to account for these risks is arbitrary and capricious. The
selection of EPA's preferred remedy is inherently flawed.'
(Responses)
These concerns have been addressed herein. Also, see the discussion of
Alternative 2 in the FS. The same principles apply for possible ash
disposal in Alternative 3.
vv. 'At Rose, the costs of the alternative chosen far exceed the costs of
containment and fails to provide any greater public health or environmental
protection.'
The costs are higher for the recommended alternative, yet it is cost-
effective because it protects the public health and the environment over
the long-term versus short-term for containment. See Section 121(b)(l)(F)
of SARA.
ww. 'The technical reliability of infrared thermal destruction is uncertain.
Its unreliability is underscored by the fact that EPA is utilizing its
Superfund Innovative Technology Evaluation Program (SITE) to test this
technology. It is one thing for EPA to perform research in furtherance
of its overall mandate, but it is quite another to require PRPs to pay for
research rather than remediation.'
Data from use of infrared technology on other Superfund sites and laboratory
tests have proven the unit's effectiveness on PCBs and (possibly) in the
fixation of lead. Contrary to what the PRPs believe, they are not being
charged for the SITE program test to be run at the Rose site.
xx. 'The preference for thermal destruction at this site is arbitrary and
capricious. Thus, the only choice supported by the Record is some type of
containment.'
EPA's preference for thermal destruction has been previously justified.
The PRPs allegation that "the only choice... is some type of containment"
is arbitrary itself, since no supporting data were presented with this
statement.
yy. 'A containment remedy at this site could eliminate any potential for public
exposure to contaminated soils and minimize migration of chemicals into
the ground water.'
The uncertainty of public protection by containment remedies caused them
to generally be screened out during the initial screening of alternatives.
Section 121(b)(l)(F) of SARA, as discussed earlier, is relevant here,
also. SARA calls for the EPA.to prefer remedies that use treatment to
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-23-
permanently and significantly reduce toxicity, mobility, or volume of waste
over remedies that provide protection through prevention of exposure.
zz. 'Congress did not mandate excavation and thermal destruction in SARA. Rather,
SARA requires a reasoned and public decision-making process which encompasses
consideration of all reasonable alternatives, including containment.1
Congress did not mandate any specific remedial alternatives for site cleanup.
However, they did mandate that EPA prefer treatment remedies and permanent
solutions over those which do not reduce the toxicity, volume, or mobility
of the waste. Thermal destruction was recommended as a remedial action
after carefully considering alT types of alternatives in accordance to
statutes and EPA guidance.
aaa. 'EPA's consideration of the need to comply with state permits is contrary
to the NCP, EPA policy, and SARA. (Table 10-5 of the RI/FS suggests that
state permits may be required for implementation of on-site remedies.)1
If the remedial process is delayed because of permit applications, then
they will probably not be sought. However, EPA wishes to foster good
relations with the states and is willing to go through permitting processes
when it is able. In any event, EPA will meet the technical requirements
of the permits.
bbb. 'EPA must consider reasonable alternatives during the process of selecting a
remedy at a CERCLA site, therefore rejecting reasonable onsite containment
as a remedial alternative is improper.'
This comment has been discussed previously. See the FS for alternative
consideration and screening.
ccc. 'Both CERCLA and RCRA contemplate the need to take action short of excavation,
including a containment scheme which is designed to protect public health.
Action other than slavishily meeting the technical landfill design agreements
of RCRA will accomplish the common goal of CERCLA and RCRA - the protection
of public health. Such actions are permitted by EPA regulations.'
EPA feels that its proposed plan is more protective of human health and the
environment for reasons already discussed.
ddd. 'The PRP Group requests that EPA:
(i) revise the RI/FS so that it evaluates all appropriate factors
[particularly comparing onsite thermal destruction with contain-
ment] before selecting a remedy;
(ii) revise the RI/FS to adequately and properly consider all reaso-
able alternatives, including in situ containment, according to
the factors set forth by SARA aricTTn"e NCP;
(i1i) Comply with CERCLA, as amended by SARA, the NCP, and general
principles of administrative laws; and
(iv) recommend a cost-effective remedy which will adequately protect the
public health.
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If EPA fails to address the flaws in the RI/FS, its costs of implementing
the selected remedy cannot be recovered.'
(Response)
EPA has performed its statutory requirements to the fullest extent practicable.
A cost-effective remedy which is fully protective of long-term public health
has been recommended for implementation.
2. Technical Comments
The following comments are taken from a document submitted by the PRP
Committee entitled: "Fred C. Hart Associates, Inc. Review of the E. C.
Jordan Final Report." The document evaluates th work performed by E. C.
Jordan which was used to develop the RI/FS and it presents a summary of
conclusions based upon the evaluation. The MDNR addressed the majority of
the technical comments.
a. "Jordan's assessment of the Site shows that there is no present exposure
risk from the groundwater and that chemistry data confirms (sic) that no
chemicals of concern are presently leaving the site."
As addressed earlier, the major risks from ground water exposure are
present and future potential risks. Chemistry data do confirm that
chemicals of concern are leaving the site. There are PCBs in marsh
sediments, lead exceeds AWQC in the marsh surface waters, and a seepage
sample also showed PCB contamination.
b. "Jordan has failed to follow the procedures outlined in the Superfund Public
Health Evaluation Manual (PHEM) and has improperly assessed present and
future risk in accordance with EPA policy and guidance."
U.S. EPA and MDNR believe that the risk assessment is valid and properly
shows the potential risks to receptors of chemicals from the Rose Site.
Specific comments follow:
c. "No evidence is provided that establishes a direct connection between the
aquifer beneath the Site and the aquifer from which local residents obtain
their drinking water."
The PRP emphasis on a lack of direct evidence on the connection between
domestic wells (nearest receptors) and the contaminated site aquifer(s) is
misplaced. Anyone would be "hard pressed" to state there is no connection,
simply based on the geologic nature and complexity of this site. Circumstantial
evidence alone suggests a connection: over the entire site there is a hydraulic
connection between the shallowest and deepest aquifers. The vast majority of
domestic wells in the area are finished above the deep clay till (if it is
present beyond the site).
d. "Even if one accepts the unsubstantiated assumption that there is a
connection between the aquifers, there still is virtually no risk because
a conservative (e.g. over-estimation) prediction of groundwater movement
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indicates that at a minimum, it would take over 250 years for any chemical
of concern to reach the nearest drinking water well."
The ground water flow velocity in the report was understated: in the
northern portion of the site, vinyl chloride is present in significant
concentrations and the groundwater in this contaminated area is moving at
a rate between 200 and 500 ft/yr. In only a few years, this contamination
is .likely to move to many receptors. And, according to Michigan law, the
ground water is contaminated and it must be remediated, regardless of the
proximity of present receptors.
e. "Jordan did not compare the risk of implementing the selected remedy with
the present risk of the Site."
The present risk of the Site has been shown to be very great for a long
period of time; The risk of implementing the proposed plan should be
minimized by standard engineering and safety practices. Possible extra
short-term risks posed by implementation of the remedy are balanced by
permanent remediation of the site.
f. "Jordan's selected remedy did not address the potential risks related to
the release of volatiles during soil excavation-or adequately assess air
emissions during incineration and the reliability/implementability of
thermal destruction."
EPA recognizes that some volatiles will be lost when soil is excavated,
which may pose an inhalation risk to the Workers and the surrounding
community. However, these risks are expected to be minimized through the
use of safety procedures during remedial action. Note that the ground
water degradation source will be removed, thereby reducing considerably
the long-term risks due to ingestion of contaminated water.
g. "Jordan's exposure scenario utilizes assumptions that are not reasonable.
For instance, contrary to guidance in the PHEM, Jordan has chosen a drinking
water exposure point that is within the center of the on-Site groundwater
plume. Jordan's soil exposure scenario assumes that local hikers will
choose an abandoned industrial waste Site as a picturesque locale for a
hike and while on Site eat enough soil to incur a significant health risk."
Selection of a well in the center of a plume as a reasonable worst-case
scenerio is, in U.S. EPA's and MDNR's opinion, not inappropriate for this
site. As discussed in a recent RD/RA negotiation meeting with the PRPs
(September 3, 1987), Jordan's soil exposure scenario used a hunter as the
most likely adult exposure, and soil ingestion was not used as a likely
exposure scenario.
h. "Some of Jordan's scenario's are not only unreasonable but impractical.
Jordan assumes as a potential soil receptor the hypothetical snowmobiler,
even though it would be expected that this person would be riding during
the winter months while snow covers the frozen ground, when Jordan had
stated that no soil contact is expected. Additionally, it is hard to
understand how someone wearing winter clothes, including gloves, would be
susceptible to dermal contact from frozen soil."
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Snowmobiling was not used as an exposure scenario. It is only an example
of present site use. This, too, was discussed with the PRPs on
September 3, 1987.
i. "Jordan has selected cleanup standards that are contrary to EPA Policy.
See J. Winston Porter Memorandum (July 9, 1987) concerning guidance on
selection of ARARs, and Lee M. Thomas, letter to the Honorable James J.
Florio (May 21, 1987). [Specifically, the document feels MCLs, rather
than MCLG's, are ARARs.]
The RI/FS utilized health-based risk calculations to formulate cleanup
levels where no MCLs exist. The only exception is .vinyl chloride, since
the MCL shows an unacceptable risk to potential receptors. However, the
TCL calculated (15 ppt) for vinyl chloride is way below detection limits
for the chemical, such that the final TCL will approximate the MCL (2.0
ppb) as a result. MCLGs for carcinogens are zero, which is impractical
to clean up to'.
j. "Jordan failed to adequately compare the risks, benefits and costs of the
Remedial Alternatives."
See the RI/FS for the discussion of comparison of risks, benefits, and
costs of the remedial alternatives. U.S. EPA and MDNR feel that it is
adequate in its scope.
k. "Target Cleanup Levels (TCL) are incorrect or overly conservative for some
chemicals based upon particulate/water partition coefficient (Koc) values
and/or a risk level of 10~6, and not an appropriate cleanup standard. In
the case of vinyl chloride, a TCL was calculated starting with an
unnecessarily conservative groundwater cleanup standard (TCL of 0.015
ug/1, vs. EPA MCL of 2 ug/1). Jordan initially chose a soil TCL goal for
arsenic of 0.828 ppm when the Agency for Toxic Substances and Disease
Registry (ATSDR) of the Center for Disease Control has determined that a
level of 100 ppm is a safe level based on the risk from the direct inges-
tion of contaminated soil by a child (Fed. Reg. Nov. 20, 1985, p. 47923)."
Vinyl chloride was discussed above. As discussed in the ROD, a cleanup
level of 14 ppm for arsenic has been set based on background levels in the
soils and health-based risk calculations using current available data.
1. "Jordan's TCL for arsenic in soil (10 ppm) is below the top range of
background levels of arsenic found on Site (Table 8-2). It is clearly
unreasonable to present a cleanup level that would remove soil that would
in some cases be below background levels.
U.S. EPA agrees that it would be unreasonable to cleanup below background
levels in the case of arsenic. As stated above, the TCL for arsenic in
soils has been set at 14 ppm, which is the highest recorded background
level at the site.
m. "Jordan has used an inappropriate groundwater contaminant model to predict
future concentrations of chemicals. The model assumes a single input of
chemicals into the environment; this is incorrect based upon known disposal
facts and Jordan's own assessment of Site conditions (pg 3 - Final Report
RI/FS June 1987).
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Hart's criticisms of the chemical transport are basically acknowledged by
Jordan in the text of the RI/FS. The Agencies believe that this is a
reasonable simplified modelling effort. As more data become available for
the complex geology at the site and for the chemicals of concern, more
extensive modelling can be performed. Nothing in the FS provided by Hart
suggests anything else which could resolve their own criticisms.
"Jordan's choice of monitoring well RW-7 for the groundwater receptor point
required that the initial input concentrations of groundwater into the
model be obtained from RW-7. RW-7 was not properly constructed nor was it
sampled according to EPA protocol. These factors result in inaccurate
(excessive) input concentratio.ns, and may have led to an over-estimation
of receptor concentrations at the nearest domestic well as predicted by
their model."
Use of monitor well RW-7 is appropriate for this site. Hart's concern
about the construction of RW-7 is insignificant. The well log indicates
the presence of odors and a greenish color in the aquifer (also there
were red coloring of clays above, which strongly suggests contamination).
Typical well construction for this phase of the study included letting the
formation collapse around the well screen. If any drill cuttings were
used as backfill material, it would have been from the sediments in or
above the aquifer. Also, it is likely that it would have been the low
permeable overlying clays. Further, these cuttings would have been placed
above the bentonite seal. Thus, this location suggests that concentrated
contaminants existed before the well was placed here, and the chemical
results show contamination is still present in high levels. If it is accurate
(which is doubtful) that this well was not properly evacuated before sampling,
then the volatile chemical levels present "would likely be lower than those
actually in the aquifer.
"The model assumes no attenuation of chemicals due to dilution, adsorption,
volatilization or biodegradation, in direct contrast to the methods of an
'expert in the field that Jordan has often retained, Dr. James Dragun.
Dr. Dragun has noted that these processes are important to quantify in
order to properly assess the health hazards associated with chemical con-
centrations in groundwater."
As stated earlier, Jordan has acknowledged the limitations of their ground
water transport model. See response to comment m, above.
"Jordan has also used estimated concentrations in calculating exposure to
indicator chemicals. This is not authorized by the PHEM and is contrary
to accepted scientific methodology."
According to our interpretation of the RI tables in Chapter 7, it is true
that some estimated values were used for evaluating chemicals as the average
concentrations in the respective plumes. The worst-case concentrations,
i.e., the highest concentrations found, were not estimated values. A
likely reason that some of these average concentrations are denoted with a
"J" qualifer is that the average values determined may have been noted as
approximate values. Also, they may be below the CLP detection limit, but
above the analytical detection limits of the procedure used. According to
our interpretation, nowhere in the PHEM is this practice forbidden, nor
do we believe it is contrary to accepted methodology. It is a mechanism
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which allows some quantitative analysis of potential risk, particularly
when taking average values, since these would automatically be an
extrapolation of some hypothetical mean value.
q. "Contrary to EPA guidance, Jordan has not used a quantitative method of
selecting the chemical of "highest concern". Because of this, and the
fact that a confusing selection rationale was used, reviewers cannot
properly evaluate the conclusions drawn by Jordan's Baseline Risk
Assessment presented in the RI/FS."
and,
"Some of the indicator chemicals Jordan has chosen were detected with such
low frequencies and magnitudes that the resultant analysis is of virtually
no significance. Additionally, some laboratory detections are estimated
concentrations which are not accurate."
While it is true that Jordan did not utilize the worksheets provided in
the Superfund Public Health Evaluation Manual (PHEM) to quantitatively
"score" the indicator chemicals, professional judgement, based on knowledge
of the chemicals' physical/chemical characteristics, relative toxicities,
concentrations detected in various media, and representatation of various
approximate mobility categorizations were used to identify the indicator
chemicals. The selection process for indicator chemicals as outlined in
the PHEM is a general guideline which considers these same general charac-
teristics and allows one to take a "cookbook" approach to assign a quanti-
tative score to the chemicals found at a particular site. The process
used by Jordan may have selected several chemicals as chemicals of concern
that may not have been necessary,'(e.g., 2-butanone and isophorone), but
when the quantitative risk assessment was conducted these chemicals dropped
out of the process and no target concentration levels were developed to
drive the cleanup. Having unnecessary indicator chemicals is not critical,
it only provides additional work for the risk assessor when establishing
the quantitative risk assessment. A problem could arise if, in the indicator
chemical selection process, a chemical of concern were missed, and because
of some unusual physical/chemical properties or extreme toxicity, would
not be adequately addressed by the selected remedial action for the site.
However, this was not the case for this site.
r. "Many typographical errors exist. Numerous inconsistencies in criteria
values are presented for Tables 6-3 (pg. 69) and Table 7-2 (pg. 81) (e.g.
Chlorobenzene - 250 ug/1 vs. 19,500 ug/1 (AWOC); Methylene Chloride -
1500 ug/1 vs. N/A (Health Advisory); Methylene Chloride - 193,000 ug/1 vs.
0 (Freshwater Acute))."
The errors have been corrected in the tables noted above.
s. "Soil incineration proposed by Jordan may in fact increase the levels of
inorganics in the soil/ash and may result in a soil/ash waste product that
must still be disposed of as a hazardous waste. Jordan has not adequately
addressed the potential disposal problem."
This will be addressed during the design treatability testing. If found
to be significant, U.S. EPA will reconsider the proposed plan.
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t. "In identifying and screening remedial alternatives, Jordan has failed
to adequately consider how the combinations and distributions of the
various chemicals on-site will complicate the selection of appropriate
technologies. Technology used to remediate a chemical specific group
may cause the release and distribution of pollutants."
This, too, will be addressed during the design-phase. The proposed plan
is intended to permanently address all aspects of chemical pollution
through destruction (or immobilization in the case of metals).
u. "The remedial alternatives recommended could lead to an increase in exposure
of workers, the public and the.environment to the chemicals of concern on
site."
Standard safety engineering practices should minimize this short-term
risk. However, the greater benefits of long-term risk reduction more than
compensate.
v. "The remedy recommended in the FS cannot ensure that the chemicals of
concern in groundwater and soil will be destroyed or rendered harmless.
Even Jordan has stated this in their evaluation of the remedies."
The design phase testing will shed more light on the reliability of the
proposed plan.
w. "The inconsistencies found within the report along with the generally poor
presentation of data makes it difficult to evaluate the findings. The
report does not describe the technical rationale for all conclusions and
does not indicate when professional judgment was relied upon or identify
whose judgment was used."
The report indicates that remedial action needs to be taken at this site.
The Administrative Record contains all of the information relied upon in
the selection of the remedy.
x. "Jordan has failed to consider the inherent risks to workers and the
general public inherent in the excavation, incineration and possible
movement of soils off-site. In view of the very Tow risks from the
site, the inherent risks of this type of remediation may substantially
exceed the risks at the site."
The present and potential risks at the site are not "very low," but are
rather substantial. Risks of implementing the remedy are considered in
the description of the alternative in the FS.
y. "Only the lack of time prevents this review from criticizing other specific
problems, errors and inconsistencies in the Jordan RI/FS."
Comment noted, but it is irrelevant. .
-------
-30-
z. [The PRPs Risk Assessment and Feasibility Study provided with the previous
documents (addressed in Parts 1 and 2) is the basis for the PRP comments
already discussed. The PRP Risk Assessment claims there is little or no
present or future risk on-site, and bases their preference for in situ
containment remedies or No-Action remedies on this assumption.]
The reasoning is flawed. There j_s_ a present risk, a present-potential risk,
and a future potential risk due to the chemicals of concern onsite. SARA
mandates a preference for permanent treatment remedies to address hazardous
waste site remediation.
C. Other Agency Comments
1. U.S. Department of the Interior
a. "There is a potential for direct and indirect injury to migratory birds
in the immediate vicinity of the site, until the contamination is
removed or contained. Accordingly, we are not prepared to grant a
release from claims for damages to resources under our trusteeship at
this time. We would be willing to reconsider this position if the
containment and/or cleanup at the site is implemented in a manner that
renders these release innocuous to our resources." [See attached letter.]
As suggested in the Dol letter, U.S. EPA has consulted with the U.S.
Fish and Wildlife Service in East Lansing, Michigan during public
review of the RI/FS. Their comments are below:
b. While the TCL for PCBs is a legitimate consideration of human health
risk and of economics, "it is the opinion of the U.S. Fish and Wildlife
Service that the TCL for PCBs is too high and if implemented will lead
to direct and adverse impacts to resident and migratory wildlife at
the Site." In consideration of bioaccumulation by invertebrates
(earthworms) and other organisms on up the food chain, the TCL should
be set at 0.1 ppm PCBs in soils. "To provide for a margin of safety
we recommend that this value be halved to 0.05 mg PCB/kg soil dry
weight." [See also attached letter.]
While U.S. EPA appreciates the spirit in which this recommendation is
given, we must unfortunately keep the TCL as is. The extra volume of
soils that would need to be excavated would render the remedy imprac-
tical to implement.
2. Michigan Department of Natural Resources.
a. From Robert Hayes, Project Geologist, MDNR:
"The ground water flow velocity in the report was understated: in the
northern portion of the site... ground water is moving at a rate
between 200 and 500 ft/yr. (See attached flow velocity data.) In
only a few years, ... contamination is likely to move to many receptors."
U.S. EPA is placing the ground water velocity calculations into the
Administrative Record. (See attached memorandum.)
-------
-31-
Llst of Attachments
1. Department of the Interior - letter to U.S. EPA
2. Fish and Wildlife Service - letter to MDNR
3. MDNR - interoffice memorandum
-------
United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
175 WEST JACKSON BOULEVARD
CHICAGO. ILLINOIS 60604
TAXE
PWKW
AMERICA
MEMORANDUM
TO:
FROM:
Subject:
May 15, 1987
Basil G. Constantelos, Director
Waste Management Division, U.S. EPA
u.s. C~A. R:
WASTC r-.'A.sAG^:E
OFFICE OH IKE
:O.\' v
UT DIVISION
t
Sheila M. Huff, Regional Environmental Officer, DOI
Preliminary Natural Resource Surveys, Region V
For your information, I have enclosed copies of Interior's comments on
Preliminary Natural Resource Surveys. These represent sites where
Department has expressed concern about impacts to Trustee Resources.
These are being provided to your office so that proper consultation with
U. S. Fish & Uildife Service can take place, as expressed in the letters.
further information, I may be contacted at 353-6612.
Thank you for your assistance.
the
the
For
Enclosures
(1
U
\7 G
\i b.
JUL07 1987
SITE MANAGEMENT
SECTION.
*v
-------
United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
WASHINGTON, D.C. 20240 ** "
e
ER86/956 MA?- 2 4 1S87
Memorandum
Mr. Gene Lucero, Director - ^
Office of Waste Programs Enforcement 7" h^/i
U.S. Environmental Protection Agency xl / k r*
401 M Street, SW (Room S364N) WH 527 » J ^\>
Washington, D.C 20460 ^'
Dear Mr. Lucero:
Pursuant to our Memorandum of Understanding, the Department of the Interior has
completed a Preliminary Natural Resources Survey of the Rose Township Dump Site,
Oakland County, Michigan. Our survey indicates that no lands, minerals, anadromous
fish, Indian resources, or endangered species under the trusteeship of the Department are
being or have been affected by the site.
However, there is a potential for direct and indirect injury to migratory birds in the
immediate vicinity of the site, until the contamination is removed or contained.
Resources under our trust in the site vicinity include wood ducks, mallards, and redwing
blackbirds.
Heavy metals and PCBs have been found to be the principle contaminants of the surface
and sub-surface soils. Volatile and semi-volatile organic compounds are located in sub-
surface soils, and in the groundwater as well. PCBs have also been detected in the
groundwater plume. Although undocumented, these contaminants do pose a threat to
migratory birds, their habitat, end food chain.
Accordingly, we are not prepared to grant a release from claims for damages to
resources under our trusteeship at this time. We would be willing to reconsider this
position if the containment and/or cleanup at the site is implemented in a manner that
renders these releases innocuous to our resources. We suggest that the U.S. Fish &
Wildlife Service be consulted during the development of the Remedial
Investigation/Feasibility Study. Our Departmental contact for this site is Sheila Huff,
Regional Environmental Officer, Chicago, IL (FTS 353-6612).
Sincerely,
Bruce Blanchard
Director
bcc: Director, Waste Mgrot Div, USEPA Vv'
T. J. Miller, FWS, Twin Cities
CC: Field Supv, FWS, E. Lansing
Steve KJ<»;
-------
»«» - »«M~» * -» _' W .. *> 4 | A WA* W W i
East Lansing, Michigan 4S323
August 12, 1937
Mr. Steve Luzkow
Remedial Action Section
Groundwater Quality Division
Michigan Department of Natural Resources
P.O. Box 30028 is
Lansing, MI 4G9C9
Dear Mr. Luzkcw:
This letter is a follow-up to your August 5, 1987 telephone conversation with
Dave Best of my staff concerning the Rose Township-Oemode Road Dump site
(CERCLA) in Oakland County, Michigan. This letter provides our written
comments on the Remedial Investigation/Feasibility Study of June 1937,
prepared by private consultants for the Michigan Department of natural
Resources. Additional information was obtained from Ms. Bonnie Elsdcr, U.S.
Environmental Protection Agency on August 3, 1987. ye appreciate the dead!inn
extension for cormtents to August 12, 1387.
»The document adequately describes the high quality terrestrial and wetland
habitats surrounding the dump site, and lists numerous wildlife species known
or expected to inhabit this area. The U.S. Fish and Wildlife Service concurs
with this wildlife evaluation for the site. In November 1986, this office
performed a Preliminary Natural Resources Survey of this site at the request
of the U.S. Environmental Protection Agency and concluded that trustee
resources, including migratory birds and waterfowl, are attracted to the site
and adjacent areas, and may be impacted.
Our principle concern with the document is with the discussion regarding the
degree of impact of PCB-contaminated soils onsite and offsite, as well as the
selected final PC8 target cleanup level (TCL). We have learned that the final
TCI for PCBs of 10 mg PC3/kg soil dry weight involved two considerations.
First, this TCL was based on a human cancer risk assessment (10 risk) for
physical exposure/contact and ingestion of soils at the site.
In addition, there appears to be an economically driven cleanup consideration
for this TCL, since the TCL will determine the amount (area! as well as depth)
and hence cost, of contaminated soil/sediment that will require excavation for
thermal treatment and backfilling, or disposal at a licensed landfill. Both
are legitimate considerations and we have no reason to doubt the findings of
the PCS human health risk assessment. However, a quantitative wildlife health
risk assessment was not performed as part of thti setting of the TCL.
-------
It is the opinion of the U.S. Fish and Wildlife Service that the TCL for PCSs
is too high and 1f implemented will lead to direct and adverse impacts to
resident and migratory wildlife at the site. We offer a metnod and
suggestions for establishing a final TCL for PCBs in soils which will
adequately protect wildlife resources. We feel that our recommended TCL can
be further modified to reflect the depth at which the sediment/soil samples
are to be taken in preparation for removal, or are to bo disposed as part of
backfilling at the site aftsr thermal treatment.
Our cause for concern about tha designated TCL for PC3s is the known
bioaccumulation of PCSs by organisms within a food chain. In general, there
is a 10-fold increase in whole organism PCS body burdens between each step up
the food chain. The initial step in the food chain at this site is, and will
be after site cleanup, the processing of soil materials and accumulation of
contaminants by soil invertebrates. The bulk of the soil invertebrates in
terrestrial and vegetated wetland situations ara earthworms (Oligochaeta). We
have attached to this letter a table we developed for another project which
surveys the expected bioaccumulation potentials (expressed as a storage ratio)
for earthworms in various PCS and heavy metal soil situations. Tha storage
ratios for PCBs by earthworms from the surveyed literature conforms quite well
with tha 10-fold increase between trophic levels.
There is little doubt about tha ability of soil invertebrates, earthworms in
particular, to accumulate PCSs to levels well in excess of soil
concentrations. This known accumulation is the avenue by which impacts to the
more visible and economically important wildlife species will occur at the
site. There are numerous wildlife species (avian, mainrnalian, reptilian and
amphibian) which prey wholely, or in part, on earthworms and other soil
.invertebrates (reference attached). The impacts of feeding on earthworms
having various PCS burdens have not been directly studied. However, the U.S.
Fish and Wildlife Service has recently published a synoptic review of hazards
to fish, wildlife and invertebrates by way of PCB exposure in their diets and
media, or in selected tissues and organs (reference attached). For birds, it
is reported that concentrations of PCSs in excess of 3 rag PCB/kg fresh weight
in a diet are associated with an increased likelihood of death from PCB
poisoning. For the mink, one of the most susceptible small mammals, a diet as
low as 0.1 mg PC3/kg fresh weight is reported to cause death and reproductive
toxicity.
Based on our visit to the Rose Township dump site in October 1986, this office
believes that mink are permanent residents at and adjacent to the dump site.
The preferred habitat would be the vegetated wetlands and fringing upland
areas which surround the site. However, mink are quite mobile and could
easily use the dump site presently and upon completion of cleanup. Obviously,
numerous avian species use the dump site and surrounding areas for feeding,
migratory and breeding areas.
Although mink have not been documented from gut content studies to be direct
predators of earthworms, they are opportunistic predators which are known to
feed on a variety of vertebrate and invertebrate species. Many of these
vertebrate species are known predators of earthworms. The existence of these
intermediate worm predators only exacerbates the potanti-il PCS thraat to mink
through the food chain.
-------
Utilizing the medn storage ratios and PC3 soil concentrations from our
attached table, we have attempted to calculate the approximate PCB body
burdens in earthworms which one would expect from various soil PCC
concentrations. These calculated body burdens can then be compared to PCS
hazards in wildlife diets, as reported above. The results are as follows:
PCBs in soil PCB in worms
(mg/kg, dry weight) (:nq/kq, fresh weight)
110.3 608.9
9.7 13.0
0.7.1 ' 0.92
0.13 " 0.08
These values are approximations only, as mean values were used in the
calculations and the original tests were run with different soil types,
experimental designs and exposure periods. However, plsasa note that the
fresh wet PCS concentration in earthworms does not approach the health hazard
level for mink diets until the PCS concentration in the soils approach the
lave! of G.I mg PCB/kg soil dry weight. T'nerafore, we believe that the final
TCL for PC3s in soils/sediment should be set at a maximum of 0.1 mg. PCB/ky
soil dry weight. TJ provide for 4 margin of safety we recommend that this
value be halved to Q.05 mg PCs/kg soil dry weight.
This value appears to be well within the potential cleanup range for the
thermal treatment process proposed for preliminary testing on contaminated
soils at this sits, under the Environmental Protection Agency Superfund
Inovative Technology Evaluation Program. This process has been reported to be
99.9999* efficient for PCB destruction at the design temperatures of 1350-
2300 F. Using this efficiency and the maximum PCB soil concentration reported
for the entire site (250 mg PC3/kg soil dry weight), the maximum expected PCB
concentration in the resultant ash will be 0.025 mg PCB/kg soil dry weight,
which is below our recommended final TCL. Therefore our recommended final TCL
is a reasonable value in terms of cleanup technology potential.
Our recommended final TCL does have important implications for degree of
excavation and cleanup of soils at the site. Tnis will likely increase the
areal extent of the cleanup area, but may not drdtnatically change the extent
of excavation and cleanup in a vertical direction. He believe that our'
recommended final TCL for PCBs in soils need not apply necessarily to the
entire soil depth profile. Since earthworms generally confine their feeding,
burrowing and overwintering activities to the top 4-5 feet of a normal soil
profile, our recommended final TCL would only need to apply for this upper
soil stratum. This upper soil stratum would not only be present at the
southwest dump site, but would also be applicable to the west facing drainage
slops below the southwest site and the single wetland sediment site where PGQs
above our recommended final TCL were detected. A higher final TCL value may
be appropriate for excavation or backfilling criteria for PCB contaminated
soil and ash below the five-foot depth contour. Groundwater extraction and
treatment will h«lp protect/control the environmental impact of t;i*se higher
PC3 concentrations in the lower soil strata.
-------
Cur final TCL for soil PCBs may also be modified if sufficient capping of the
backfilled thermal treatment ash occurs. At this time, there is no
information as to whether capping will occur. It is only known that the ash
resulting from thermally treated soils excavated from the site will have to
pass EP toxidty tests, as being a non-hazardous waste, in order to be
backfilled onto the site. If backfilling and capping of the site does occur,
a 4 to 5 foot topsoil layur should be coniidereo for installation above the
protective cap. This topsoil- layer will permit soil invertebrate activity to
occur.without jeopardizing the integrity and function of the cap.
Special consideration should be given to better documentation of sediment/soil
concentrations of PCBs offsita. . PCB concantrations on the drainage slope
below the dump site and tho one wetland site with detectable PCBs, were all
above our recommended final TCL at which we consider impacts to. wildlife will
occur. We suggest that additional soil/sediment samples be taken in these two
areas, particularly in the wetland area, to better determine the presence and
levels of PCBs. "Additional soil/sediment sampling in other areas of the
wetland west of the dump site is also suggested. Should PC2s indeed be
present at these sites above cur recommended final TCL, then our next
recommended step woula be to collect soil invertebrates at these sites for PCS
residue analyses. If significant oioaccurnulation of PC3s is indicated, then
additional collection and testing of predator organisms, such as mink and
waterfowl may be warranted. All of these bioassays may be preliminary to
actual soil/sediment removal and cleanup at thase sites. Thr.se bicassays fray
also be useful after cleanup of the soutnwest dump site to determine the
appropriatenass of the final selected TCL and the success of the cleanup in
preventing impacts to the environment. This office would be willing to assist
in the design of these bioassay techniques.
%
It was not clear in the Document if actual cleanup is proposed for areas with
PCa-contaminated soil outside and adjacent to the southwest dumpsite. This
previously mentioned site is located on the upper drainage slope to the
wetland and does contain good forested habitat. However, the appearance of
good habitat at any site should not factor into the decision for possible
cleanup. If PC3s in the soils are indeed above cur recommended final TCL,
then bioassays and/or cleanup of the soil should occur.
Information is also apparently not available as to the probable uses or
processes with which the PCOs were employed, prior to disposal at the site.
Thermally employed uses of PCBs can. lead to the pyrolitic formation of
dloxins/furans. Although the Michigan Department of Natural Resources does
not expect dioxins and furans at this site due to the absence of these
compounds at a nearby CERCLA site which received similar wastes, we suggest
that a selected few soil samples from the southwest dump site undergo
dioxin/furan analyses or an extract assay for dioxin equivalence. Since
capping of a site is the only available clean-up methodology that we are aware
of for dioxins/furans, it may well be worth the expense to document their
absence or presence early on in this study. Sines the thermal treatment
method is proposed to be tested on a small scale at this site, we suggest that
the dioxin/furan analyses, or an extract assay for dioxin equivalence, be
conducted on a few of the resultant ash samples.
-------
This office is willing to further discuss the above topics and aid, where
possible, in the design and documentation of any wildlife health bioassays
necessary for this site. Please direct your questions to either Dave Best or
Tim Kubiak at (517) 337-6650. Thank you for this opportunity to co.iment on
the Remedial Investigation/Feasibility Study document for the Rose Township
dump site.
Sincerely yours,
Robert D. Pacific
- - Robert D. Pacific
Field Supervisor
cc: Bonnie Eleder, U.S. EPA, Chicago. IL (5HE-12)
-------
September 16, 1987
TO: Steve Luzkow, Project Mgr., Demode Rd., SMU
FROM: Robert Hayes, Project Geologist, Demode Rd., SMU
SUBJECT: Demode Road - Supplemental Evaluation
Some information and evaluations that I presented to E. C. Jordan for the
Final RI/FS were not included in that report. The purpose of this memo
is to bring several important points to light regarding contamination
flow rates, nature of vinyl chloride plume, connection of north and south
plumes, and remedy selection that -must be considered in evaluating this
site for remediation.
Using the information contained in the RI/FS, I calculate groundwater
flow rates that are significantly different than those presented in
Jordan's report (see attached calculations). Groundwater velocity in the
'northern groundwater contamination (i.e. vinyl chloride) plume ranges
from approximately 200 - 500 feet/year. Jordan's suggested flow ranged
from approximately. 21 feet/year up to a possible 200 feet/year. This was
based on overall site averages, rather than location specific (i.e. north
plume area) data that I used. This is a significant difference, and one
that suggests vinyl chloride (a carcinogen) will spread on and off site
at a much faster rate than previously indicated. I believe this adds a
new sense of urgency to the remediation of this site.
When considering the hydrogeology of the entire site, it is apparant
that there is a groundwater recharge area in the same location as the
known contaminant source area (i.e., the southwest portion of the site's
upland area). Contaminants apparently are either retarded from moving
vertically by the surficial clay deposits or they may be directed hori-
zontally to more granular recharge areas. Once they move downward they
encounter an unconfined shallow aquifer. In this mounded (most of the
year) recharge zone contaminants initially move vertically and radiate to
southwest, west* northwest and north directions away from the source
area. As contaminants reach the lower portions of the aquifer, the
regional groundwater flow system directs them generally northward toward
Demode Road.
Groundwater in the southern portion of the site moves much slower than
groundwater in the northern portion (previously .discussed). (Attached
are calculated groundwater velocities and additional groundwater flow
contour maps.) When the entire site is considered, groundwater in the
south moves on the order of 20-30 feet/year, toward the central portion
of the site it gradually increases to approximately 50-75 feet/year, and
continues to increase as it moves northward. When it reaches the north
portion (e.g. vicinity of DNR-7) it begins to move considerably faster -
-------
-2-
greater than 200 feet/year. For some of these flow rates I used assumed
values for hydraulic conductivity and porositygenerally resulting in
lower flow rates than I would expect for this type of aquifer. Addition-
al slug tests/pump tests would be necessary to get more accurate data.
(These flow rates could easily be much greater than presented hereby
assuming greater values.)
Although the exact location of the vinyl chloride is unknown-several
physical and chemical conditions make its presence In the north part of
the site a serious concern. Considering the different groundwater
velocities, the location of known source areas, and the fact that vinyl
chloride occurs as a result of chemical degradation and moves quite
rapidly in the groundwater, chemicals apparently have moved a significant
distance from the south or at least south central portion of the site. A
major concern should be preventing contaminants from reaching the high
groundwater velocity area in the north part of the site. Indeed, we
should emphasize that the chemicals in the groundwater in the south
portion of the site should be removed before they continue to transform
into chemicals of even greater health concern (e.g., vinyl chloride) and
move northward and rapidly away from the site.
The Jordan report treats the north and south plumes as separate concerns.
I do not believe this is the case. Indeed, I believe there is ample
evidence (flow directions, flow rates, stratigraphy, etc.) in the report
that indicates the "north" and the "south" plumes are related and in fact
connected. Additional intermediate depth wells in the vicinity of RW14
and MW103 (both shallow wells) should confirm this interpretation.
I conclude that at present there is enough data to select a remedy that
would remediate this site appropriately. Further, I suggest that there
should be some sense of urgency associated with remediation (for reasons
described above) of this site. Finally, I recommend that at least the
number of additional monitor wells suggested in Jordan's report be
installed and pump tests completed prior to (or at least during) the
Remedial Design phase of this project. The information gained from these
additional monitor wells will be indispensable to a realistic remedial
design and may even suggest the need for more and/or better located
monitor wells for the final remedial action.
cc:^Mr. Kevin Adler, EPA
Mr. R. Willson/Mr. J. Linton
-------
GROUNDWATER VELOCITY SUMMARY
DIRECTION/LOCATION AVERAGE VELOCITY
North Plume Area;
PNR-6 to DNR-4 400 ft/yr
DNR-5 downgradient 220 ft/yr
(toward Demode Rd.)
Central Site Area:
DNR-3 to MW102D 50 ft/yr
South Plume Area;
Shallow Aquifer
RW7 to RW9 35 ft/yr
RW6 to Wetland 19 ft/yr
Deep Aquifer
DNR-1 to MW106D 15 ft/yr
-------
DEMODE ROAD SITE
Groundwater Flow Velocity
Formula: Velocity (v) = K, , x . I gradient
con
porosity
NORTH PLUME; Flow from DNR6 to DNR 4 on 4/8/87
IT = V - T
DNR
6 4
n (assumed)
vnKTO , = 47.89-ft/d (.007) = 1.34 ft/d
DNR-6 - -
1.34 fc/d - 489 ft/yr
VDNR5
= KDNR-5 ' I - 27.09 ft/d (.0067) - 0.7 ft/d
n 0.25
- 0.7 ft/d = 265 ft/yr
If assume n = 0.3 then
VDNR6 = 40? ft/yr and VDNR5 = 2*°
SOUTH PLUME; Average Groundvater velocity
Shallow Aquifer; Data: 4/8/87 k (estimated)
RW-7 to RW-9 Water elev. 1007.54' (RW7)
Distance appox. 450' - 996.56' (RW9)
10.98'
I - 10.98 - 0.024
450
v - KI - 1.0 ft/day (assumed) x 0.024 approx. .1 ft/day
n 0.25
approx. 35.0 ft/year
RW-6 to wetland (approx. elev. 999')
v » KI - 1.0 ft/day x 0.013 approx. 0.05 ft/day
n 0.25
0.05 ft/day approx. 19.0 ft/yr
DNR1 to MW106D Data 4/8/87
8.27 I = .89 = 0.00066 approx. .0007
-7.38 1350
0.89
-------
v = KI = 15 ft/day x 0.0007 = 0.043 ft/day
n .25
15.3 ft/year
CENTRAL SITE AREA
Groundwater Velocity
DNR-3 to MW-102D elev. 1007.42 DNR-3
-1005.97 MW-102D
1.45
I = 1.45 = .001
1300
v = KI « 30 ft/day x .001 approx. 0.14 ft/day
n . ' .25
approx. 50 ft/year
-------
TABU I
ROUND 1
ANALYSES OF MONITORING WELL WATER SAMPLES
ROSE TOWNSHIP SITE - MICHIGAN
SAMPLE LOCATION
SAMPLE DATE
Parameters
Metals, Total (pg/t)
Aluaiuua
Antinooy
Arsenic |
Bariiun
Berylliua ,
Cadniua
Chroniua
Cobalt
Copper .
Iron '
Lead
Cyanide
Manganese
Mercury
Nickel
Seleniua
Silver
Thai Hum
Tin
Vanadiua
Zinc
RW-I
8-16-84
.
--
--
--.
--
--
--
--
--
--
--
--
22
--
--
--
--
28
140
RU-1D
8-16-84
._
--
--
--
--
'
6.3
145
--
--
152'
RW-2
8-16-84
._
--
--
--
--
--
--
--
15
--
94
0.24
--
--
--
--
--
3930
RW-2D
8-16-84
._
--
--
--
55
11
104
0.38
--
--
--
4410
BW-3
8-15-84
_ ..
.
--
116
,
--
76
7.6
60
--
--
106
--
2810
RW-4
6-17-84
__
--
--
6.9
124
--
--
--
--
2840
RW-5
8-16-84
_.
--
273
574
6.5
612
--
--
209
RW-SD
9-25-84
_
--
--
--
--
--
--
--
--
138
--
605
--
--
--
--
--
--
--
86
RW-6
8-14-84
--
--
--
--
7320
1320
0.45
--
--
1280
RW-6D
8-14-84
__
,
--
--
--
--
--
312
--
...
27
--
--
--
--
1330
RW-7
8-15-84
461
--
II
--
--
--
--
10000
94
47
0.40
..
..
-.
--
23800
KW-B
8-15-84
_ _
--
--
--
--
--
--
--
--
60
--
--
14
0.46
--
..
--
--
23
..
272
KW-8U
8-15-84
..
--
--
-.
--
.-
--
--
--
453
13
--
3b
--
..
.-
-.
--
--
._
312
2.85.170
0001.0.0
-------
TAUIJ-: | (emu.)
ANALYSE III MiNriUKINi; VKI.I. WATKit SAWUS
ICIISIC TIIWNSIIII' .SITE - HIUIIUAN
: UWATIIM
DATE
KW-9
I'd I JIM- 1 1-!':.
A I lux ilium
An I ikuiiy
Arkruir
llnyll iiM
C.iJmiiMi
l.'lu.MHIIIUI
Iron
Utfil
Cyaiiiilv
He i fury
Niikel
Srlclllliw
Silver
Tin
'Hi I
0.40
14
26
65
KW-IO
V-lb-84
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NH
NS
NS
NS
NS
NS
NS
NS
KW-10
-B4
HW-II UW-12 hW-ll
U-2S-84 8-15-84 tt-l'j-84
NS
NS
' NS
NS
NS
I.S NS
NS
uu-ri
16
91
14
134
4-fiO
4020
NS
NS
NS
NS
NS
NS
NS
N.'i
NS
NS
NU
NS
KW-14 KW-lb KU-16 hW-l/ ItV-l/U
J-24-84 8-16-84 8-14-84 B-U-84 8-17-84
NS
KU-18
tt.6
Il6uo
--
--
--
b.2
--
14-J
--
--
--
:ioo
__
..
--
9.9
--
II
--
--
--
--
-.
142
106
. --
' -- 486
1'J 5.0
--
67 4:>
o.:ji
.-
..
..
-.
766 S8/
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
IH/
IMWll
2 .8-i. I HI
IMIOI.0.0
-------
TAUIJi | (i:..nl . )
ANAI.Y&KS w MtiHrriiuiNi; wti.i. UATKU :;Anri.t.s
KOSK TUUN^IIII- iJITK - HlllllliAH
SAHI'lt UiCATKMI
IMIt
HW-IUII IIW-IOII) IIW-IO.'I HW-IO2I NU-IIIJ HW-IOI HU-IOtS HW-I04I HW-IOSS BW-I04S MW-|Oi HU-IUSI MU- IOMI UU-im.ll
|)ii|i(HU-IUIA) UnpfUl* 10) ' l)ii|> lhiti
lU-JO-Ht *»-^6-H4 J-2S-8« 'J-21-a« l-'J-U-> l-U-ltt. <)-2«-tt4 'J-24-H4 B-ltt-H^ «-ltt-l>4 B-IH-B4 8-U-B/. U-^^-H'. B-I/-KA
Aliwuim
An 1 iiMitiy
Ili-iyl liiui
L'llllMIIIIM
I run
I.C4.I
Cyan i ilc
Hcnury
Nitfci-l
SelcniiM
Silvri
TlMllilMI
Tin
VdlldJ i turn
ZI III
Total Uissolvvil Suliils
240
au
20'j
2?. 2
24
21
20
1/2
62
Jltt
3H2U
HA
17/0
NA
1260
NA
MA
NA
Wl
NA
111
III
21
148
NA
16
iH
HA
NA
1 1 10
NA
1010
NA
NA
. i/o
.0.0
-------
TAIIIJC | (i:.,ni.
.v.'ifc:; of
; ui-:i.i. WATKK SAWI.KS
snt - n i can; AN
SANI-U: LOCATION
.SANH.K IIATK
I'.il aui-lirl ^
M.-ljIs, iul.il (|lg/t)
Aliiiuiiiiiiit
Anl im4iiiy
A i srnit'
11.11 IIIUI
Ili-iyl I liiul
I jilmt\m
I IIIUM i uui
1 1 mi
I., .i.l
I y.iiiiitr
M:illg.inr:»i:
H..-II my
Nukcl
tit* I en i nui
Si Ivcr
Ilia Ilium
Tin
riu-iw.il HW-iiH.1) tiw-ion iiu-io/it MW-IOHI nw-iomi HV-WJII HW-IIOS MU-IIUS HU-IIOI
l)ii|i lhi|> lhi|i(HW-30>
B-I/-B4 8-17-BA I0-|0-h/. IO-IO-B4 IO-IO-B4 <»-2!>-U4 IU-2V-H4 IU-2'J-B4 IO-2'J-B4 IU-29-14 1-8-85
4
I
HU-IIOU 111'- 20
l-'J-Hb
nu-1111
2 1 in.
Tol.il
226
. / 127 lU'i
VJ.2 .
Sulttls
NA
NA
:n.u
you
2 BO
Jb.b
114
:iB.6
I'JU
34,1 86.S
10 J
S'l.l
NA
J20
B'J2
NA
BBS
2UO
8)0
300
NA
2B.2
NA I BO
2.KV I/O
(Hill/ 00
-------
I:AUI£ I (t:..m.)
.VS^ IIF KlNITllltlNC Utl.l. MATCH SAHPU3
KOSt K1WN.SIIII' SITE - HI Clll UAH
SAHM.K UHIATKiH
.K HATE
THII*
BLANK II-
IJ-I4-B4
HW-28
iut;rii.i.to
WAItK
HUNK
IU-JU-U4
IIW-32
1)1 STII 1^11)
WATCH
UI.AKK
II -01 -84
rule
BIANK 12
a-20-84
m/rtH
BIJUIK |l
U-I6-B4
Hl.TtH
ItUNK 12
8- 16-84
Aliuuilliw
An I inuny
Aiuuuir
II. 1 1 1 iw
202
iiliuiiu*
I lll»OIIIIU
ilt
u|i|irr
I ull
ir>l. I /(I
llllll'l.O.li
-------
TAHUi I
ANALYSIS of HUN minim; WKI.I. SAHI'I>:S
(HV-102 STUIlV AKKA)
KilSt TIIWNSIIIP - lltHHIt KllAI) Slit
SMI|)|C Lor.il iuii
Sjia|ile llali;
I'jUiuclfi s
Hi'l J Is - Tiil.il
Aluminum
Anl lOHiiiy
ll.il inn
liny II MM*
I'jilwiiuu
Call inn
CIlKHHIIUI
Colull
Cuiiiicr
(run
lead
N.I cues ina
(IJUgJIII'UC
Urn in y
Nirkel
I'uljSSillM
Scl ell JIM
III Ivrr
Smliiw
Tli.illiuui
Tin
V.iiMiliuu
/I IU
ryjin.tr
KW-I
4-25:85
(MB/O
-.
--
__
--
--
572/0
II
--
..
.100
7.0
22480
148
--
--
--
--
-.
--
--
.
751
NA
KU-14
4-25-85
--
--
._
--
--
tti'iiU
10
-.
.-
--
l)
IBJIO
72
--
--
--
--
15
--
--
--
--
B'i'J
NA
KW-I 8
4-2S-85
--
.-
--
--
5IBIO
--
--
--
151
1 7690
17
--
--
--
--
--
--
--
--
--
9b2
NA
HU-IOII
4-24-85
'
--
--
..
--
--
7:i84o
--
--
lit
--
5.4
211/0
29 -
--
--
--
--
--
--
--
--
--
2/6
NA
NW-IOII)
4-24-85
--
--
..
--
--
78010
--
--
166
--
25800
22
--
--
--
--
5507
--
--
--
--
NA
tlW- 1021
4-25-85
--
--
.-
--
--
54470
15
--
IJ2
326
20
21580
32
--
--
--
--'
--
6!l54
--
--
--
2/1
NA
HU-51
(Mil* NU-I02I)
4-25-85
--
--
--
--
57320
--
'
..
--
--
21790
19
--
--
--
»-
5464
--
--
--
90
NA
HW- I02U
4-25-85
-.
--
--
60810
13
--
48
169
23
20800
41
--
--
--
--
81'89
--
--
--
2bli9
NA
HW- 10 i
4-25-85
--
--
--
--
45780
--
--
--
5.2
1/900
17
--
--
--
--
--
5432
--
--
--
I26/
NA
MU-!
(UUi
4-24
--
--
--
--
--
--
--
--
--
--
--
--
--
--
NA
Nul.-s:
-- - No I ilitt fit ctl 01 liulow runli.iil ilrlitrl iuii
NA - Hul jn.ily/ril.
Dill1 - Uii|i|italc ujiu|.li'.
our
-------
TAIU.K 2.
ANAI.YStS OK MONITORING WELL WATtll SAMPLES
KOIIN1) II
KOSt TOWNSHIP SITt - MICH I UAH
SAMPLE LOCATION
SAHri.F. DATE
I'ji Jiiu icrs
Metals.. Total (|ig/«)
Aluminum
Ant moiiy
Arsenic
Bjrium
Bcrylliun
Cadmium
Cliiooiiuin
Cobalt
Copper
Iron
Li-jJ
Cyamdt
rl.ingoiirr.e
MI-K in y
Nil k«-l
belruium
Silver
1 lu 1 1 i uiu
Tin
Vanidium
Z inc-
Htf- 1
9-30-86
A8
--
--
103
--
--
A
--
S.A
93S
--
--
2A
--
--
--
--
--
--
--
99
HW-1I)
9 -30-86
if
«
--
31
--
--
A.I
--
--
238
--
--
181
--
--
--
--
--
--
--
98
KW-2
9-2'J-Bl>
SS i
--
--
78
--
--
--
A. 8
A82
--
--
121*
--
--
--
--
--
' --
--
ISI
KW-3
9-311-86
6S
--
--
139
--
--
--
--
A. 6
I2SO
--
--
SA
--
--
--
-.
--
--
--
AS
KW-A
9-30-Bb
86
--
--
IIA
--
--
--
--
--
967
--
--
2S7
--
--
--
--
--
--
--
1100
KW-5
10-1-86
A6
.--
-. .
106
--
--
--
7.6
1310
--
37
--
--
--
--
--
..
--
ISO
KW-51)
10-1-86
AS
--
--
196
--
--
--
8.6
96S
--
...
A8I
--
16
--
-- .
--
._
--
IIS
KU-6
10-1-86
66
--
--
30
--
--
--
6. A
7020
--
--
1300
0.2
--
..
--
..
..
--
178
KW-61)
10-1-80
61
--
. ..
91
--
--
--
--
A. 8
S88
--
--
19
--
--
..
..
..
..
1SS
RV-7
10-2-86
2S60
--
IA
320
7.3
113
12
138
3AAOQ
ISO
209
--
A7
-.
'
22
73000
KV-8
9-30-86
60
--
100
--
-- .
3.3
1080
--
--
26
..
-.
_-
_.
..
IOA
UW-81)
10-1-86
96
--
--
103
--
--
--
--
A. 8
1080
--
--
IB
--
--
-_
--
..
_.
--
187
KW-iill Hi
IU-I-KI.
73
--
--
IOA
--
--
--
--
S.9
ItiuO
--
--
IS
--
--
.
.-
..
..
.,
U.B
I .-.HI.. ISA
-------
TAUU: 2. lt:""'
ANAI.YMCS OF HUN II OK I NO WM.I. HAIKU SANH.ti,
HOUND II
USt: VUWNSIIII' SITE - HICIIICAN
SAMHI.L' LOCATION
SAHI'l.t IJAIt
I'jraim-ters
finals, Total ((!£/£)
Aluminum
Antimony
Arsenic
8 j r i UB
bcryll iun
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Cyanide
Manganese
Ntrrtury
Nickel
Selenium
Si Ivrr
Iliallium
lin
Vanadium
2 UK
KW-'J
10-2-Bb
54
--
--
68
--
--
--
3.9
80
--
--
173
--
II
. -.
--
--
--
--
235
KW-10
9-29-86
76
--
10
--
73
360
--
--
--
--
--
--
4760
KW-ll
9-29-86
59
--
24
-
--
--
3.3
74
6.9
--
30
--
--
--
--
--
--
--
2800
KW-12 KW-14
9-30-8b 9-24-86
56
--
23 .25
"
--
--
_.
7.5
40
._
--
35 10
--
--
-
--
--
--
j-
1240 1740
KW-15
9-29-Bb
66
~-
34
--
--
6.5
--
--
289
6.2
--
41
--
10
--
--
--
--
--
3510
RW-16
10-2-86
61
--
96
--
--
--
--
6.2
79
-- -
--
33
--
--
131
KW-17
10-2-86
61
--
--
31
--
-
4.1
276
'
--
54
--
--
--
--
--
287
KW-16
9-25-B6
._
--
--
85
--
--
--
--
--
36
--
--
17
40
--
--
--
--
--
286
I.'.««.. IS4
-------
TAIil-t 2.
SAMI-LI LOCATION
SAWUJIAJK
I'.iramc-lers
n.-tals (|ig/t)
aluminum
antinuny
arsenic
ha ri urn
l>ery) 1 ium
cadmium
> lirouiuni
Cobalt
C0|iuer
iron
lead
cyanide
manganese
mercury
nickel
selenium
silver
thallium
tin
vanadium
zinc
ANAI.Y.St.S OK HuNITOKING WELL WATtK SAMH.KS
KOUNI) II
ROSE TOWNSHIP SITE - HI CHI CAN
HW-10211 riW-IOblt
MW-10II rlW-IOII) MU-1021 HW-102U l)u|> MU-103S HW-I04S MU-1041 HW-10SS HW-1051 HW-I05D HW-I06U llu(.
9-25-Bt. 9-25-86 9-23-86 9-24-86 9-24-86 9-24-86 9-24-86 9-24-86 9-29-86 9-29-86 -9-29-86 9-30-86 9-30-Hi.
34
118
447
25
41
27
151
67
3.S
237
14
Kb
408
25
14S
708
24
100
10
..
16
::
4.5
-
-
13
5
44
11
38 87
"*" **
-i **
87
17
38
60
_
36
"*
4.5
96
20
53
..
158
4.4
._
164
--
14
__
110
124
«
"
__
1320
26
20
__
70
124
4
1UBO
21
378
32
609
1420
13
-------
TAHU: 2 (tuni- >
ANALYSES OF HUNITnKINU WtLL WATCH SAHI'l.tS
kOUNI) II
KOSK TOWNSHIP SITE - MICHIGAN
SAMPLE LOCATION
5 V!!M PATE ___
I'jranieters
HW-IO/I
t-22-Hb
MW-IU7I)
9-22-86
jIllllillllllU
am irouny
dfitllH
liariuin
l>erylltum
< admium
t hromium
colull
copjier
I ron
lea,]
cyanide
manganese
mercury
UK ke)
MW-IOUI
9-29-86
66
120
7.2
IJ20
20
132
6.
1060
22
MW-IOliD
9-29-86
57
1A2
HW-1081)
Ouji
9-29-86
tlW-1091)
9-30-84
MW-IIOS
10-1-86
60.
143
4.2
HW-I10I
10-1-86
HW-IIOI)
10-2-66
75
122
.168
72
48
88
58
33
HW-IIOU
Hup HW-|i
10-2-8i> 10- .
93
8.1
160
59
1510
28
1560
30
27
4.4
884
38
5.4
177
27
5.9
1510
9
-------
i AIIII: 2. ":"»' )
ANAI.VSKS (if ritlNITOKlNC Wtl.l. WATEK SAMI'I.KS
I(UIINI) II
HUSK TuwNsinr snt: - MICHIGAN
SAMPLE LOCATION
SAMI'tE HATE
DNH I ONK 2 DNK 3 DMK U DNH 5 DHK 6 ONR 7
4-22-86 9-24-86 6-25-86 9-21-86 9-21-86 9-23-86 9-23-86
Hclals (ug/f)
aluminum
aul imuny
arsenic
bjriua
l-rryll ium
i hroaiium
i..tiaU
iron
lead
cyanide
manganese
ait- rcury
nickel
selenium
ii Ivcr
thai I mm
tin
vjiiadiiuu
ziur
567
8.6
1330
22
507
1520
21
5.8
843
35
164
8
1050
20
179
A40
22
86
31
811
22
91
29
12
251
152
210
380
109
48
153
12.HI.. r>4
-------
Tviti.t 2,. (Omt.j
HOUND II
ANALYSES OK MdNITOIIINU WEM. WATKK SAMPLES
WISE TOWNSHIP SITE - HICIIKJAN
SAMPLE
UOi
Ul.iuk
V-22-B6
HW-202
UUnfc
9-25-86
HU-205
Blank
9-30-B6
NW-207
Blank
10-1-86
HU-209
BUnk
IO-2-K6
Blank
10-2-86
P j runic te is
A I lira i HUM
Ant imuiiy
Arsenic
Bjrinm
Beryl I linn
Cjilmiiun
Chrunniiin
Cuba It
Lopjier
Iron
Le.i.l
Cyanide
76
79
27
103
A8
57
64
57
Mercury
N'icket
Selenium
Silver
flu Ilium
Tin
Viiijitium
Zinc
Tutdl Uisiolve.l Solids
20
NA
44
K20
21
NA
20
NA
41
4.2
82
57
7.8
31
12. BO. !")<,
Ill) 17.0.0
-------
SAHI-I.K Ul
SAMI'I.K DATi.
KU-I
-K.-B'.
IIU- III
H-16-Hd
UM-2
TAIIU: 3
AN.VI.VStU UK IMNI lOKIMti WKI.I. WATKII K
ISK KIWNSIIII' SITE - MICHIGAN
KU-.I KW-4 KW-!> KU-MI
-IS-H4 B-I/-84 8-16-84 'J-2i-B
KW-b
B-lA-84
KU-60
B-K.-BA
KW-B KW-BII
8-IVB4 B-IS-84
Mi* I liy I |i|iiriu» I
ctliylbiriizriir
Id l.It|llulO^lllyll.llc
lulllt:lle
1 1 ii li I ii i in' I hy lent:
I'CIl:.
1 , 1-fIiililiiiticlli.im:
1,1 . l-l r lililoiiurlli.mc
I , I ,J-t l Ii til in IK Iti. UK-
|jfn/i»i t ai ill
H jus I , ^-iliililitiin Iliylcne
In ii/i-tir
»<! liy lirni* «|I|IIIM|I*
ln-|>l Jilili.l
I I III) I tit I II llluKIMI I llJIIU
|ii*ni a( lilui U|I|IL*MU|
iKu(iliui t»iii:
Jtcluuc
J 1 1 Ii 1 1> i ml 1 1 1 mi i unu: I liiine
2-liulilll ..... :
il i - ii- lull y I |i|i( li.i I jl i-
tliiu.-lliy|ilillialali:
i*yt lulitrxainMit.*
2-i liliiiu{>4ifiiiil
Ii l u I .' -c I liy I In xa I )|iht li.i I al c-
vinyl tliluinli:
t lilui'ni'l li.mr
It I idliyilii.liiuii
ltl ill t lilnliifl.liy li:nt:
ill ii-iulyl |i|il h.i l.il <
<4.'<) llliT
O.J5-* --
AK
.Stll
I. IKII
II
KI'J
--
iti
no
--.
--
--
12
S60
. -.
<>'JO
Illl
2B
--
--
--
2V
--
--
--
--
--
--
--
7
""*
--
«
iJll
--
--
--
20.1
--
--
--
--
ii
--
jbj
--
51
18
14
S
202
22,
6,
0.
IB
J.
43.
--
--
--
--
>
'1
.3
.4
.2
.2
.40
24*»
2
,1
8
46
J700
4600
^2000
-- , HOD
4BOO
210
7800
-~ --
~~
--
--
J.IKII --
-,
.-
..
-.
--
..
..
-.
--
--
III. «'-
--
--
-.
--
--
--
1.01:
--
--
..
--
11. OC
b 4
--
--
--
--
0. I'l-'
--
--
--
.UK
1.4K
--
--
-.
--
--
._
J. JK
--
--
4.8KII
J.BK
I :»K
ii- n 1 1 ritMiil i plirny I .iiu i nc
-------
TABU ^ < C-'oul >
ANALYSIS W MIHITIiKINi: WK1.I. WATKH S
KOSK TuWNSUir SITt - HIUIKiAN
SAMI-U:
SAMI'I.K DATE
HW-U
B- 14-B'i
KW-IU
B-I6-H4
KW- II)
KW-II
KW-12 HH-U HW-|:»
B-IS-B4 B-IS-HA 9-2U-B4
KW-14 KW-lb
J-24-B4 B-I6-B4
KU-16 KW-I? KW-I/II KU-IB
B-14-84 H-I7-B4 B-!/-«< B-22-B4
> li 1 11 1'l
I el 1 41 It I uruct liy I rue
tulunif
1 1 icliluniclliylciiu
xy It: mts
1.2-Jiibluioclhdiii:
I , I -ill I llluia.rlll.ini:
I , I , 1-1 I It Illill ui llldlic
I , 1 ,2-1 lit him ui.-llidiiu
Ili'll^Uli Jl lit
nil' l liy I cue i It I u i i :iiii|||i|iriiyl.iniiiii:
NS
US
MS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Mill
J.IKH
2't
NS
NS
NS
NS
NS
NS
NS
NS
NS
HS
HS
NS
NS
HS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
--
--
--
--
«
--,
140
7UO
--
--
--
--
iUU
--
--
--
--
--
--
--
201
--
--
--
7y
NS
0.2CI-- 0.2i"
I.BC II.OC -J.IC
7.2
10
20J
DIIDd.O.U
-------
TAUI.K 3 (*'"!» >
ANALYSES UK IMiNI TllUINli UKI.I. WATCH SAIII'llS
St: TllUNSUII* SITK - NIUIICAN
j; UN:ATIHN
SAtll'Lt IIATK
MW-IOII MW-IUIII HU-IIUI nw-io^i NW-IOI HW-IUI HV-IO/.S »iu-io4i HW-KIS.S nv-iobs HV-IOS nu-ioii nw-iu-ji) tiv-iot.ii
ln.|.(HW IOIA) lluji(|il' IU) I)U|> Ibip
IO-:iO-84 -J-.II.-B4 «J-2:»-B4 'J-2'j-H« l-'J-Bi l-9-Bi 'J-24-B4 «»-2«-B4 B-IB-B4 fl-18-8* B-IB-B4 8-IB-B4 B-Z2-B4 B-l/-8«
» ll.nlllo.orll.yU-l.c
lulufnc
I I iilllulbirlliyllrm:
xylcurs
I , J-tli t'littiiiii:llililufurlliiim-
I . I .I'll LllloKlL-llLllll-
1 , 1 , 2 - 1 r i t li I i>i »<:! luiir
tfii/uii jiii)
tijiii 1 ,2-ilii lilnn>i:lliyltdili|ur
f llllll'Ol I'll tllui IIHMrl lldlM!
IM-HI.II |I|IIIII|I|M ll»l
4A
Mil
2K "
1.0 il
IU
I.S
795
2.t- 6.4B iJU SHU II 20 II
W
diililuiuill I luiiiiiuii'l lune
i'yi loliojliii
2-ililuiu|>lii-
l.i^(i!-. lliylhi
vinyl Uili'iidt:
rlilurui-lliitiif
14-1 1 uliy.h uliu uii
1,1 iln liloriii.-lliylciu'
tli-ii-ni lyl |i|illi.il.it r
(4.4J WIT
Jllll'll"!
**frilti|ilil Ill-Hi-
ll-llll ln^o
-------
TAIII.K T) (Cu'il I
ANAI.Y.SKS UK fHiNITUKIMli WK.I.I. WAIK.K SAMI'I.KS
KU.M-: TUWNMIU* SITE - n 11:111 CAN
SAMI'l.t llD'ATION
SA.'11'I.K IMTK
nu-iiu>i> MW-i6i.u NW-III/I HU-IO/II HW-IOHI IIU-IUBU nw-ni'Jii tiw-iios HW-IIIIS riw-noi HW-iion iir-^o riw-iiu
Dmi Hup Uii|i(IIW-!IU) BlJiik
l-'J-H'j 111-29-84
«-!/-«« H-I7-H4 10- Ifl-H'i 1(1- 10-11', IO-JO-H4
\U-2li t ha I u I e
vinyl fliloiiili:
t liloiuctlidiii:
I c( i dliyili ului'iiii
1,1 Jitliluioelliylciic
ili-n-oilyl |ilitliiilalc
Ci.«) IIIIT
pin in. I
jt rli.i|i|it lii:iir
li -u 1 1 1 nil.. 1 1 |ilu ny I .mil iir
6A
JA
3A
6A
12. /Il
/.A
I IA
:i'JA
:IDJ
JIA
i . H'J . I /II
mum. o.o
-------
TAIIO: 3 "1 )
lit HiiNITliUINi; Wtl.l. WATKU
UIKiK TilUNSIIH' !illt - IIICIIIIiAN
SAMI'lt LOCATIIUi
SAMI'1.1: MATE
I'-JIUUU Id S
thlui
lill.l.rlll-
11 icliluiurlliylciic
xylcucs
,2-ilitliloruelliaiie
, l-tliililoruelliiiiii:
,1.1-11 i«Ii I or in-1 bane
,1,i-ll it lilur<>i:ll>.illi:
11 jus 1,2-Jn'liluioclliylciit-
Mi-lliylriic ihliiilili;
li<:|it at him
I liiiiiulri
dfCllillL-
ilii lilorotli I Inuiouelliaiiu
2-bnlttiiunu
ill me I liy Iplilha I at c
tyi lulirxanmie
vinyl fliluridn
«lili*ru«l tune
li-u-uilyl (ilillulale
(4,4) Hill
|ilu nut
ai rn.i|ihl lu'iie
n - n 111 IIMII! i |iln:iiy I am i in-
ncir
BUNK S\-
a- u-84
»iw-2B
DISIH.I1.U
WATEk
UUNK
10-111-84
HW-!I1£
IHSTU.t.tl>
UAIKIi
BUNK
II-OI-U4
run*
HUNK 12
B- 20-84
HI.TKH
III.AHK II
B-IO-B4
UtTEM
BLANK 12
»- 16-84
O.'J
I BK
^ . B->. I /U
(mill (i.(i
-------
TAIII.K 3 («"iit.)
ANALYSIS OK HuNITUKINU WKI.I. SAMI'IKS
(NV-102 STUDY AKtA)
KIKE TOWNS!!!!' - DKHUIIK KOAI) SITU
S j«|i 1 c Lot a 1 1 un KW- 1
Sji.pl.' II li- 4-25-85
1'jl.llllL-lflb
Org.uiirs |ig/lt
wlliyK-nc id lor idc
' airluiic
lutllLMIf
l IlloiuirlllUllc
1, l-«li« liloroclliyU'iie
1 , l-iliihloioL'lhaiitr
iruiis-l^-ilirliloroclliylem:
1,1, l-li itliluroi-lliani:
2-l>lll Illullf
fliluruliciizriie
vinyl thlui'iilf
2-licxammi'
tli-ii-lintyl|.|illulaie
di s(:'-L-lliyllu-xyl)|>htli
--
IOJ
--
1.0
--
- _
liW-14
4-2S-8'i
2blll
50.111
2S.IU
50.1
3)
I'll)
2S.I
IIOl)
50 IU
--
--
--
101
--
--'
--
101
KW-18
«-25-H'>
'.III
Illlll
--
--
--
--
--
--
KU
--
--
--
10.1
--
--
--
~ "
HW-IOII
4-21-HS
5111
--
5.1
--
--
--
--
10.111
5J
--
--
101
--
--
--
"* **
riW'ioio
«-2«-85
5111
IO.IH
--
--
--
--
-- '
IOJU
--
--
101
--
--
. .
* ~
NW-I02I HW-51
(UUC HWT.I02I)
4-25-85 4-25-85
10 III
25 111
IOJ
--
--
--
--
--
2011
101
390
20.1
10.1
10.1
--
50.1
10.1
IOJU
20.10
IOJ
--
--
--
20JU
3)0
--
IOJ
--
--
50J
IOJ
NW-1020
4-25-B5
5JU
10.10
--
--
--
IOJB
IOJ
--
IOJ
IOJ .
-
IOJ
m-103
4-25-85
5JU
IOJU
5J
--
--
--
--
--
IOJU
--
--
IOJ
IOJ
--
IOJ
HU-50
(Ulduk)
4-24-85
Sill
10.111
VI
--
--
--
--
--
III*
--
--
IOJ
--
--
IOJ
NllTKS:
.1 - csliuuliMl value
U - also (iiniiil in blunk
-- - mulct c< I cil
'..4'.
-------
ANAI.YSKS Ut HUNHOKING WEI.l. WATEK SAMPLES
KOUNU 11
HllSE TMNSIIU1 SITE - HI CHI CAN
SAtll'I.E LOCATION KW-I
SAMI'U DATE 9-30-86
I'ji jnirl ers
L'fB'.'llL'J* (MB/*)
( lilorolienzcne
eltiylbenzene
l«- 1 rarliloruethy leuc
to Incur
t ricliloi oethylene
I'CBs
naphtha I ene
xyleues
1 , J-dichlurorlliane
1 , l-diclilofoelhane
1 , 1 ,1-lrii liloroclhaue
1 , 1 ,2-lriihloroetliaiie
lieuzuic acid
irans 1 ,2-dichloroethylene
lienzenr
oietliyleiie chloride
heulachlur
1 1 norol riclilorouiet hane
neiil aililoio|i|icnul
i&o|>hoiune
acetone SJB
dichlorodi 1 luoroumlhane
L'-lmlaiione. 18B
KW-II)
9-30-86
--
__
--
--
--
--
--
--
6
--
--
--
2J
9
--
--
--
--
--
4JB
--
1811
KW-2
9-29-86
"t
--
--
--
--
--
--
--
--
--
2J
--
--
--
--
IOB
--
2IB
KW-3 RW-4
9-30-8o 9-30-86
--
__
--
IJ IJ
35
..
_-
,.
..
8
IS
.-
..
19
--
_.
__
--
__
SJB 4JB
.-
ISB ISB
HW-5
10-1-86
--
..
IJ
--.
--
--
--
7
--
2J
2J
IJ
.
--
3J
4JB
--
19U
RW-SU
10-1-86
190
_.
--
62B
71
--
.-
72
--
490
48
--
--
710
170
6J
--
--
--
13
6IB
--
83B
KW-6
10-1-86
170
31
--
2JB
350
--
--
--
10
19
7J
. 31
--
450
26
3J
--
--
28
19JB
--
3UH
KU-61)
10-1-86
--
..
--
--
--
--
--
--
--
--
--
6JB
--
2IB
*
HW-7
10-2-86
3300
3100
4400
SSOOOB
I200J
--
200
2SOOOB
--
--
--
, --
--
--
--
--
--
--
8300B
--
I3000B
kW-8 KW-81) KW-81) l)<
9-30-86 10-1-86 10-1-86
..
-.
--
2J -- UB
--
--
..
_.
._
-.
..
__
__
..
--
.-
--
_.
SJB 3.IB 5.IH
..
ISB 18B lob
di-n-|iutyl|ititlialalt
d i me i liypli t ha I a l c
> yi lolit-xanunr
sU-elhylhexiyll )olilhalalc 3BI
vinyl chloride
thlui ortliaiie
1,1 dithluroelhylene
ili-n-ticlyl phlhdlale
(4.4) DDT
jteiia|iht hi-iie
n-n 11 ru:.odi|>hi-iiylainiiic
1,4-iliinelhy luheiiol
I;II|MHI lei rai hloridi*
f>IIJ
65
9J
Sill
3UJ
4JB
86
3J
3JB
1400
SJ
6J
8.1
6.JB
BJB
15JB
3JII
SJB
SJIi
2J
I III
\i Hi. l'.4
I ml I.' .11.11
-------
SAMI'U. UiL'AlluN
S.VII'U: IMTJ.
KW-'J
lO-L'-Bt,
HW-IO
9-29-Bo
TAIII1. V I'«« I
ANAI.VSCS (tf MONIIUKINC; WKLI. WATKK SAMI'I.Kb
kdl'NI) II
kdSK TUWNSIIII* blTt - HICIIUiAN
KW-ll
'J-2-J-86
KW-12
9-30-86
KW-l«
9-24-86
RW-15
8-29-86
KM-16
10-2-86
RU-17
10-2-86
KW-IB
9-25-86
i dim o
id raililort>i-lliy lene
t u J ueiif
1 1 ulilurut
i , J- Juliloi (iifl
I , l-dictiloi ot
1,1, 1-1 riililoructhaue
1 ,1 ,2-u i
acid
iidiii 1 ,2-dicliloroelliyleiic
l-fll/L'llt*
mi thy I rue chloride
In |it a( hlor
I luurulric li
.'-lilllullOIIC
di -ii-liulyl|ililliu
.limi-tliyl
eye lulitr.xaiioiic
J-chli.
vinyl rliloride
i lilo roc t (unt-
il I i aliyilrolDran
I , l-iliililuruclliyifiic
ill -n-i.i lyl |ihlhalalt;
(H.'ll DUI
|>llcli»l
41 C|I.1|>||| Ill-Hi-
ll- III I I u&i«li|i|ii:iiy luuillif
81
2000
1SJ
60B
I2U
9JU
31B
16B
2GB
bJB
1JU
218
188
I6b
6JB
77
I6U
III!
18B
6JB
21B
I7b
3JB
5JB
25B
3JB
111)
4JU
3JH
-------
TABLE f/ (Ci.nl. )
ANALYSES (IK HONITliUINti WELL WATER SAMPLES
. kUIIND II
HOSE TOWNSHIP SITE - MICHIGAN
SAMPLE U iC AT I ON
SAMPLE DATE _
t'.iramel cri>
HW-IOII
HW-I01I)
HV-I02I
!»-23;«!
HW-IU2I)
MW-102I> l)u|> HW-103S HW-IU4S
-24-86 9-24-B6 9-2-J-86 ___ 9-2A-86
HW-10AI
"9-24-86
HW-10SS
9-29-86
HW-IOSI
9-29-66
HV-IOSD
9-29-B6
HW-IOill
9.-JJO-J6
HV-IOc.ll
Duf
bruniuilirlilorumelluiie
i-lilorolorui
''
9.1
trl rachluruethy lenc
lolueur
l r uliloroelhylene
2J
U
2.1
2.1
1 ,2-dirhloroelhdiie
I , l-dicliloroelluiie
1 ,1 , 1-t ruliloroellunc
1 , 1 ,2-lricliloroelhaiie
liciizoic acid
trans 1 ,2-itichIoroelliylcnc
leiu- chloride-
In |"t ji lilur
( luuioi in lilorouielluiu-
pent .ichlu. optienul
1 blrpllolUllL-
jtrtt.nr
li i lilorodi I luuroioftliaiif
J-hul-none
I i - n - tin t y I |>h l ha I a l e
Uiinrtliyl uhlhalal t
< yi loliexjiione
17U
iJM
'JU
7.IB
2JU
2JU
7B - JJU
2JB
l.i&(2-tlliyriu:xyl)|ilitli
-------
TABI.K V (Com .)
ANAI.VSKS OF HI >N JTOK ING WKU WATiK SAHI'MSi
HOUND II
KOSt ?OUNSIIII> S1TK - MICHIGAN
HW-10BD NW-IIOU
SANI'U LOCATION HW-I07I MW-J07U MW-I08I HW-1081) Uu|i MW-1091) HW-110S NV-II01 HW-1IOU l)u|. Hu'
SAHi'U "«" 9-22-86^ 9-22-86 9-29-86 Jtl-'J!6. 9-29-86 9^30^84 l°-JL^_ I'J
- llCXdIIOIIC .
rlilorolit-nzfiic _" "" ' --
«"*-Hiyl|i|u-iK,| ~~ ~~ -- .. ~J ~~ -- SJB
elliylliciizcni! "_ ~~ -- -- ~~_
lfliaililoiUel|iy|e,lc _~ "" -- -- ""
toliiciir
Iritliloropthyltne
I'CBs "" .. *~ 2J ..
Haplilhalriie II " " -- "" " -- .. 1J
xyl.tncs I" -- .. "~ ~- -- (
I i-'-dichloroellune .. "" " -- .1
I, l-dirliloruetlune
l.l.l-lrirhloroeihane
1.1,2-trichloroethane
I'enzoic acid
trans l,2-dichloroetl,yle,,e II
tenzene
"ctliylene chloride 4ju ""
lif|>tJtl,|or __ 7U 2J . U
lluoroiricliloioiucllidne '.'.
l'iJiilrtclil* 171. 27|, ^
.... Ibis 2'Jti 1211 l(l>
cycl olit-xanoni- -- -- -- . --
2-cliloro|>lieiiol
--f ,f. /1'ii^iidjaif; tj
vnyl chloride ... " 5JB 7JB
«JB 7JU
"U 7JB
lelrdhydroluran II "" -- -- "" " -- .. 3JU 3JB
l.l-'Jicliloroetliyleue
?i:ra' l"ll'""-te I6JB »« :: ii :: :: :: - :: ::
1-l.flK.I ^
»> riij|.Iil I,,.,,, "~
"-''l>u!.'"ln'l>ri>yl**iIH. II " -- -- II " . -- II
-------
lAIU.K *-j (Cont.)
ANALYSES OK MilNITuHING WKLI. WATtK SAMI'I.KS
HOIINl] II
ItoSt TUWNSII1I' SITE - HI CHI CAN
SAHI'I.K LOCATION ' UNK 1 DNK 2 DNK 3 UNK 4 DNR 5 DNK 6 DNK 7
SAHI'LK J)ATK ^Zl'i-^t _______ 9-24-86 9-23-86 9-23-86 _ 9-23-86 9-23-86 9-23-B6
It'll jt lilui ueltiylene
tolllCIIL-
iriclilorocthylene
n<>|ilithateiie
xyleats -- -- -- -- -- --
1 ,2-dicliloroetliane
1 ,1-ditliloruetlidiie -- -- -- --
1, 1 , l-trichloroelhane
1 . 1 ,2-lrichloroetliaue
benzoic acid * -- -- -- -- -- -- 7-
Iriiiis 1 ,2-dichloroethylene -- -- -- . -- --
benzune --
aclhyUnc chloride 611 UU 3JB 2.IB 2JB AJb 2JB
lit-plat lilur
I luorui i icIilorouictluiiL' -- -- -- <--
|ienlai liloroplu-iiol
tsopltui-uiic
ate tone
dirlilorudi (luoronelliane
2-|iut annul-
di-ii-lui(yl|i|itlialale -- 3JB
dimrlliy plillialate
rye loliexaiiiiiii.-
2-tliloio|ilienul
liis(2-ftliylliL-xyl)|ihllia)ale --
vinyl diloriJc -- -- -- -- -- -- 1110
rhlorucllianr -- -- -- -- --
li-i rjhyilitiliirjii
I , l-ili ihl«i oclhylciie -- -- -- -- -- -- --
ili-ii-odyl jilillialaU- -- I7JU
(A.AJ I)|)T
I.IK-IH.I
^11 Cll.l|l|ll III III
n-nil t n:.i>ili|i|irny|iiuiiiup AJ
U'.Ko I
-------
IAIU.E (i:,mt. j
ItUIINO II
ANAI.VSI-S UK fluN iron (Hi; Wl-l.l. WATKN H.UII'I.K.S
KOSK TOWNSHIP .Si IK - MICIIICAN
SAMPLE LniMTIIIN
SAMPLE UATK
Pjrauieters
BUS
Blank
9-22-86
MV-202
UUnk
9-25-86
Ul4llk
9-JO-86
llljnk
10-1-86
NW-/U-J
HI.ink
IO-2-B6
IIW-^IO
II I.ink
I (1-2-Ho
melliylphenul
ethyl benzene
let r.iclilo
tulucne
tricliloroelhylene
PCBi
1 ,2-ilicliluroetlidne
I , I -Jicliloi'oethJiie
1,1. l-lrichluroelli.ine
I, I ,^-iriililuroetliJiie
beuzutc 41. ill
Irjiis 1 ,2-tlUhloroelhyleiie
benzene
melhylcne cliloridc
hcpldchlor
Muorotrtcliloroaellune
pent jclilurophenol
isophorune
acetone
diclilorodil luoroaethane
2-butanune
-------
Sample Location
Sample Number
Sample Depth
Sample Date
Parameters
Metals - Total pg/kg
TABU: fo
ANALYSIS OF TEST PIT SOIL SAMPLKS1
HOSE TOWNSHIP - DEMODE ROAD SITE
Tl'-l
37
3'
3/21/85
Tl'-l
38
]'
3/21/85
Tl'-l
39
It'
3/21/85
Tl'-l
31
r
3/21/85
TP-1
32
2'
3/21/85
TP-1
33
r
3/21/85
TP-1
34
4'
3/21/85
TP-1
35
V
3/21/85
TP-1
3f.
8"
3/21/85
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Tlia 1 1 i urn
Tin
Vanadium
Zinc
Cyanide
10800
15
--
--
--
21400
23
'--
23
20800
8
13800
505
--
24
--
--
--
--
29
45
NA
12100
18
--
36
--
22
21800
92
3840
263
25
53
NA
1760
--
11
--
-.
15)00
5.9
--
--
56300
7.2
4490
75
--
--
--
--
--
--
--
14
NA
4200
6.2
779
--
--
89
--
14
1410
314
--
305
--
--
--
--
--
._
214
NA
10500
--
13
--
--
8560
32
22
21300
39
5930
384
--
24
'
.
--
--
--
--
30
48
NA
18000
28
--
--
34
--
31
32400
14
5370
463
106
--
--
41
60
NA
5250
11
--
'
83000
12
i
14
12700
6.6
32700
289
--
--
--
32
NA
6410
--
8.8
r
-
80100
14
13500
5.5
21800
252
--
--
--
30
NA
9350
--
15
1050
--
3.8
--
85
--
17000
530
--
238
0.19
--
--
--
--
--
--
--
--
261
NA
TP = test pit
NA = not analyzed
1 Each sample listed represents the results ol a sample collected from a distinct area of the lest pit at a distinct depth interval. If more llian one
sample at a specific depth is listed for a given pit, then more than one area of the pit was sampled at that depth. See Appendix E-6B for soil
descriptions and sample locations.
6.85.45
0004.0.0
-------
TAIII.K ID
ANALYSIS OK TKST IMT SOU. SAMPLES
ItllSE TilUNSIIll' - DKHOIlK KdAI) SITE
Sample Loral inn
Sample Nninlirr
Sample Depth
Sample Dale
I'ai .inn-lei s
Organ! t-s jig/kg
Jl Cl Illll'
lolllirlllt
i-tliyllieii/i-iic
(liliiinlifiixi-iie
xyl enes
1,1,2 1 rii liloroL-lliane
li i( liluroclliylcue
li.-lrat liluioelliylene
naphlhalene
2 -im: t hy 1 u.iulil ha 1 ene
plieiiaiillil'elie
at c-iLijilil In in-
'1 1 linn-lie
1 liiiiranl hrne
pyreue
i i i i
penlarliluinphiMiol
4 melhyl-2 pi-ulanune
tli-ii-linlylplilhalale
lint yllirnzyl phi lulale
liii>(2-elhy Iliexyl )i>lillial
ili-u-ut:tylplilhali)le
PCU's
/. A'-IIIIT
Tl'-l Tl'-l
'1 ~t "t 11
.1 / .)n
i1 r
3/2I/8S :l/2l/B1)
330011
. 17000
2riOO.J
800000 51
- -
37000
3700
1 ~JAA 1
1 700 J
-.
.-
3:iOJB
330.111
ate 1/OO.IB 'J60I1
680 720C
Tl'- 1
3!)
4'
1/21/8^
2/OOU
i)IOO
rjl)000
37000
S200
' ^ -
--
i/oo in
--
20
Tl'- 1
31
3/2I/8S
IJOOOU
33000
4400
300000
8 1000
16000
2800
1700.1
_ ^
24oir
1700
-- '
420011
1700.111
1700011
--
I4000C
Tl'- 1
32
V21/8S
6S00011
230000
4'JOO
1 100000
14000
1700.1
1 700.1
--
--
--
--
--
1 700 IB
I700JU
3300B
1000
Tl1- 1
33
1'
3/2I/8S
8IB
b.l
--
--
--
--
--
330.1 It
330 JB
330.IB
IS
Tl'-l
34
4'
3/2I/8S
3300U
6700
38000
--
4200
460
330J
~ "
""
--
""
. fc'JOU
3800B
--
Tl'-l
3b
I I
'»/2!/«. . ....
I300JU
11000
7600(1
,
3200
340
330J
""
_.
310JD
330JB
4000B
__
--
Tl'- 1
3d
8"
3/21/H'j
6 /(III
2KUOII
801)0
_ _
6700
6600.1
20000
74000
sly rone
antlir;ii'i:
i!iu|iliurune
jn.i I i lit:
ililii-u/iila
I raus 1 ,2-itirliluriiL-lliylcnc
480
Tl' - tubl pit
.1 = rsl iui.ilt'il v.ilue
U = iilsit luiunl in liliink
C - ionliiiui:
-------
TABLE
-------
TAIll.K
(runt.)
ANALYSIS UK TKST I' IT SOU. SAHI'UCS
HUSK TOWNSHIP - IlKMODK KdAI) Slit
Sample l.iu.iliou
Sample Niimlier
Sample Ilirplli
Sample D..II-
I'ai'auiet IM'S
.uetoin:
(lllllCIIU
rlliylluMlzeiie
rhlGioliriizriu:
xylniL-s
1,1,2 li itliloruellidiit;
irifliluroelliylciiL*
tctraililuroelliylem:
naphthalene
2 -mel hy 1 iidptil ha 1 eue
plicuaiilliieiie
afeiiaplillifiu:
1 1 no i rue
i liluianllieiie
pyrenr
pen 1 a rlil in optical) I
4 iuiflliyl-2 pcntaiiuiu:
ili-ii-liiilylplillialalf
lull y 1 benzyl plil ha 1 ale
lii^(2-('lliyllit.-xyl ) pill ha laic
ill-ll-ia lylplllhalali-
I'Clls
TP-2
ID
2.5'
3/19/85
5811
--
--
--
--
--
24
330J
330.)
330J
--
--
--
--
330J
960B
1000011
--
1IOOOC
TI'-2
II
3/19/Uli
..
37011
--
--
78UOO
--
--
16110
16000
7600
6600J
--
--
--
--
--
8200
6600J
76000
--
26000C
TP-2
12
3/19/8')
..
--
--
--
6.4
--
--
5.1
3)0.1
330.1
330J
330J
--
--
--
--
--
--
160011
580011
--
2600IIC
TI'-2
11
2.5'
__
--
--
--
9200
--
--
6600J
--
--
--
--
--
--
--
6600.1
--
29000
--
20000
IT- 2
14
2.5'
:\l 19/85
J.
--
500J
--
9900
--
--
.
330J
330.)
330.)
--
--
--
--
--
3 30 J 11
360JB
380011
--
I4000C
'IT- 2
15
4.5'
__
--
'
--
5J
--
--
--
«
--
330J
--
--
--
330.IU
960 JU
--
-
TI'-3
21
3.5'
3/20/85
._
8300011
280000
11000
980000
--
--
4100
16000
6600
--
--
--
--
--
32000.1
--
6600.)
11000
19000
--
5100
Tf-:i
20
8"
3/20/85
-
._
8600011
300000
11000
1 000000
--
4500
22000
9100
6600.1
--
--
--
'
6600J
13000
30000
--
27000C
TI'-3 ,
22
2.5-3' |
__
4700000
430000
54000
1400000
--
5000
7000
, 1900
I700J
-
--
--
--
--
loouoj
1700.IU
I700B
3700B
..
1900
ityri-nc
jiilln.ii riur
I ,^-ilit lilui .ili
plirnol
.ma I Hie
tliliiMi^o(4,li)d
t r.ius 1 ,2-iliililiiroclliyli:iic
310.1
330.1
3IOJ
Tl' - Irul |.il
J - i-sl i m.11 rd v .lim-
it ; al^u liiiiinl in M.ink
C - .onI i,,,,r,I |,y (iC US
-- ; n..1 ilt-lfi Ir.l
-------
TABLED (coot.)
ANALYSIS OF TEST PIT SOIL SAMPLES
ROSE TOWNSHIP - DEHODE ROAD SITE
Sample Location
Sample Number
Sample Depth
Sample Date
Parameters
Metals - Total mg/kg
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
Cyanide
TP-3
25
2'
3/20/85
1560
--
.
--
--
5.3
5070
91
--
--
--
39
NA
TP-3
26
2'
3/20/85
1910
--
13
5810
135
--
49
NA
TP-3
24
6'
3/20/85
2260
6.7
82000
16
8280
18
15700
227
--
--
--
44
NA
TP-3
23
2'
3/20/85
6480
39
9.2
396
--
8610
64
35
13500
1300
3810
230
--
--
--
--
--
32
--
851
NA
TP-4
5
2'
3/19/85
3000
--
--
177
--
12
8420
34
186
--
-
55
NA
TP-4
6
6*
3/19/85
3730
--
7.6
--
7780
2.6
335
--
--
--
.
--
21
NA
TP-4
7
2'
3/19/85
6460
--
9
165
--
10300
15
15800
17
468
--
--
--
--
56
NA
TP-4
a
5'
3/19/85
2960
--
--
--
6540
--
375
--
--
--
-.
18
NA
TP-4
9
5'
3/19/85
,
4010
--
--
7.6
.
,
8110
3.0
481
--
'
23
NA
TP = test pit
NA = not analyzed
6.85.45
-------
TABLE
dual.)
ANALYSIS OK TEST PIT SOU. SAMl'I.KS
UIISK TOWNSHIP - liKHftliK U(lAI) Slit
Sample l.ouliim
Saui|ile Number
Sample l)c|illi
Sjwiilij Dale
art-lorn-
1 ol in-lit-
el liy 1 benzene
i liloiolien/ene
xyleues
1,1,2 I 1 itliluriiclliani-
IridilmiielliyltMic
tcl i n oelliy leiiir
ilaplillialemr
2-BU.-1 liy 1 uaplil ha 1 rm:
pIlC'll Jill 111 t-IIC
1 llltllL-IIC
1 luoraiilheiiL-
|>yreiiL-
pcnl arli 1 o ruptu-no 1
4 uic-lliyl-2 |ii!iildiiniit:
il i - n - liul y 1 |ilil It j 1 a I c
lull yl benzyl (ilillial ale
li i s 1 2 -it 1 liy 1 lir.xy 1 ) phi lia 1 al c
ili-n-oc lyl|ilill,alale
I'Clls
'IT- 3
2S
21
3/20/85
5.1
--
9.6
no
--
--
--
1400
1500
5100
mm
--
--
--
10.1
--
660.III
'J60U
--
IOOOOOC
Tl'-l
20
r
3/20/85
51
5.J
'J.'J
52
--
--
--
910
1100
3300
liJU
--
--
10.1
310.1
310.1
8KOB
310.1
6500()i:
Tl'-l
24
6'
1/2II/K5
1 10000B
2201100
3' 2' 51
3/l'J/85 l/l'i/B-t 1/19/85
74B
15
8.3
6.0
31
-.
..
-.
-.
-.
--
--
i
-.
330.1 B 330JU
..
-_
170
Tl'-A
9
5'
JJ/!l/«!»
-.
-.
--
--
--
--
1
--
--
._
--
--
. ..
--
--
..
..
--
slyrenr
ml III atTIU:
I SU|)I|UI(I|IL-
1,2-iliililuiuliiMi/i.-nc
|ilicnul
Jiul ine
d i LCII/II (a, It Jdiil hut viie
I raus 1,2-il i t h I urue I liy If ne
780
110.1
410
'IT =
.1 - i-sl I out i-il va I lu-
ll - also luiiinl in III.mk
('. - run) i ruiril liy ClXIS
-- - mil ilfli-i led
6
Ih
-------
TAllLE 6 (c-onl.)
ANALYSIS OK TLST PIT SOIL SAMPLES
RUSE TOWNSHIP - UEMODE KOAD SITE
Sample Location
Sample Number
Sample Depth
Sample Diite
Parameters
Metals - Total pg/kg
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Hjynesiuin
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
Cyanide
TP-5
27
IV
3/20/H5
8970
46
14
435
--
4.5
14400
73
--
10!)
29400
1050
7010
344
0.45
33
6.5
--
--
--
35
--
438
NA
TI'-S
28
5'
. 3/20/B5_
7920
--
9.3
439
--
--
51600
32
--
311
16900
2K8
15100
378
0.15
26
--
--
--
--
--
--
--
354
NA
TP-5
29
2V
3/20/B5
B820
--
9.4
1010
8.2
30700
81
:j8
17100
346
11800
261
0.29
--
--
--
--
--
--
--
530
NA
TP-5
30
5V
3/20/85
5230
6.6
--
69500
12
--
1«J
11800
41
26200
260
--
--
. -- '
.
--
--
--
53
"A
TP-6
42
5'
3/21/B5
7960
--
8.3
--
--
--
16
15
15500
5.1
--
195
--
--
.-
--
..
--
'--
36
NA
TP-6
4]
3'
3/21/85 .
4880
9.2
--
--
27700
15
15
12100
8.7
6820
273
25
--
--
--
.
45
NA
TP-6
40
6-8"
3/21/85
4400
6.7
--
--
21100
9.5
--
--
8590
15
4360
254
--
--
--
--
53
NA
Uackhoc1
43
3/21/85
5880
11
--
. 136000
16
--
39
14600
16
74100
493
--
--
5000
--
63
NA
TP = test pit
NA = not analyzed
1 A sample ol fibrous, splintery material, perhaps fiberglass, that was collected from the backhoe bucket from
Test Pit 6 at a depth o( 3-4 feel.
-------
TAIII.K (p (unit.)
ANALYSIS lit TK.M I'll Silll. .SANI'I.KS
HUSK iiiWNSIIII' - IIKNOUK KOAt) SITE
Sjiupli- Location
Sample Niiuit>i:i
Sample Orplli
Sample Dull.'
I'.HJUIl'll'l b
Oryaiiitb (IB/kg
at I't Unt-
il) 1 lll-IIC
fl liy Ihritzriif
iTllllllllieilZellr
xyltm-s
!,!,_ Iritliluiiiellunu
irl i.n liloiiii'lliy lent;
najila liali'iir
2 -uii-l liy 1 iMplil lid 1 em:
plirii.inllirriir
ai'iriiaplillicne
1 1 11(11 CIIC
1 liiur.iiil liriu-
pyn-iie
prill dt III orupllt'llol
4 mrlliyl-2 priitdiioiiu
ili-ii-liuly Iplillialalt:
lull yltii'ii^ylphllidldl r
li i s ( 2-tl liy 1 tiexy 1 )plil lia 1 air
ili-n-urlylplillialale
I'CU's
4, 4 '-DDT
slyrcne
isoplioroiu-
1 ,2-ilit liloroliL-ii/ciie
(lllflUll
anal int:
ililien/u(alli)aiitliriii*fiii.>
trans 1 ,2-iliililurnrlliyleue
'IT1 - lesl pi I
1 - i-st iudti'il value
II - .ilsn liuiiiil in lilank
C - mill iiiw.-il liy i;(.'-H.S
-- - not ilirlci (fil
6.85.45
,,.., 2.0
ri'-fi
21 .
IV
I/20/B5 _
--
--
--
--
6.9
--
5.1
1IO.J
--
--
--
--
:noi
..
--
--
'I'jim
1200011
1200
7000C
--
--
-.
--
--
-_
--
TT'-5
28
5'
J/20/H5
--
2(iOIII)ll
2'JOOU
UDOO
1 1011(10
--
--
15000
2200
1700.1
_-
--
--
--
--
1 11)00
--
--
:"jimi)n
1 700.1
/4ooiic
--
--
-.
--
--
--
--
IT--5
2'J
2'i'
y 20/85
--
II OIK)
28000
--
IJOUIIO
--
--
2500
550
J'JO.I
--
--
--
--
--
2500J
--
TUMI)
/mum
--
j5iiot:
--
--
.-
--
--
--
--
TT'-5 TT'-O Tl'-t
TO 42 41
5V 5' V
T/20/85 .1/21/85 :}/?l/8'J
-.
JHOli 5.1
MOO 5.1
-.
26000 15 5.J
--
--
1400
540
__
.-
--
._
--
-.
800
JIO.IU -- . 3JO.IB
TTOIU noil) JTiun
I4ooou 3TO.ni :i:io.iu
--
280 480C
..
--
--
._
..
..
TI'-6
40
6-8"
W\IK
-------
TABLE lo (coat.)
ANALYSIS OF TEST FIT SOIL SAMPLES
ROSE TOWNSHIP - DEMODE ROAD SITE
Sample Location
Sample Number
Sample Depth
Sample Date
Parameters
Mctala - Total rag/kg
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
Cyanide
TP-7
17
2V
3/20/85
4660
«
--
864
--
62
9130
226
262
--
--
--
75
NA
TP-7
16
r
3/20/85
6530
8.1
1240
12200
105
22
13700
185
6130
227
--
--
--
--
--
--
936
NA
TP-7
18
2V
3/20/85
5010
--
667
--
3200
52
--
15
8330
70
264
--
'
--
385
NA
TP-7
19 Dup 18
2V
3/20/85
5390
--
--
--
14
--
24
7340
36
--
265
--
--
--
--
99
NA
TP-8
1
3'
3/19/85
8100
.--
16
--
9820
16
--
16
18100
7.0
7130
353
--
.
"
..
.-
--
37
NA
TP-8
2
6'
3/19/85
8620
8.1
--
--
--
79
22
19300
127
333
--
--
--
--
43
NA
TP-8
3
3'
3/19/85
12400
15
4.1
21 ,
,
25
27000
11
332
.
--
-.
50
NA
TP-8
4
3'
3/19/8S
.
9180
11
--
--
26
--
24
23900
7
274
--
48
NA
TP = test pit
NA = not analyzed
6.85.45
0006.2.0
-------
TAIII.K fe
ANALYSIS OK TEST I'lT .SON. SAHI
I.KS
HO.'iK TOWNSHIP - IIKMUIIE KOAI) SITK
:ijni|ilf Lot at ion
Sample Number
S.im|ilc l)o|)lli
Sample l).i I c
I'.iidiuc-U-i :;
Ul eillllO
lnlllfllU
olliy 1 lirn ill-lie
I'lllnrullCIIZelie
xylcne*
1,1,2 1 1 ii Mui uelliune
li iililoiuelliylcne
tcli ai liluruflliylciie
naphthalene
2-i«i:l hy 1 lijplil li.i 1 cue
lllll'lUllllll I'lIU
ai <:|i.i|>hl In-ill'
1 IlllllCllf
1 linn JiilliL-no
|iyieiit
4 iui-lliyl-2 (iciil iiiione
il t -n- lnil yl i3
36
8/4
--
--
--
460
1101
--
--
--
--
--
--
» 10 111
330.IU
1601)11
16000
--
Tl1-/ TI'-8
19 Dii|. 18 1
2V 3'
:j/20/85 VIV/«S
5111
-.
W .
28
l|
--
.-
330.1
310.1
__
..
._
--
--
-.
J30.II1
330JO
330.111
660C 640C
--
TI'-8 Tl'-8 Tl'-8
234
61 3' 3'
3/19/85 3/19/85 3/19/85
1001) V>ll
.-
..
...
.-
.-
..
i
--
--
-.
.-
--
.-
._
-.
-.
--
260C
1 ,2-iliililuiulien^ene
phenul
J'iO.1
1,2-ituliloruclliyleiic
5.6
Tl' - Ust |iii
.1 - f.'jl i in j I i-i|
II -
-------
TAIII.K 7
ANAI.Y.'iKS (IK MIKKACK SUM. (iKAU SAHl'I.KS
KllSfc TuWNSIIir SITK - MICHIGAN
Location
Sanplc lljli-
SKI1A-1
8-23-84
SKUA-2
8-23-84
SKUA-3
8-24-85
SKUII- I
8-24-84
SKUA-A
SKIIA-5
SMM-6
SKUA-7
SKIIH-7
8-24-84
SKUA-8
8-24-84
SEDII-8
8-^4-84
SKIJA-«»
8-27-84
trials, Tula)
A liiia ilium
Ant iiwiiiy
AlbrnlL
Iliiriiiin
Beryl I nun
Cdiluiiui
Cli ionium
Culi.i 1 1
Cii|i|ier
I rou
l.ea.1
Cymiiile
Mi'iiiuy
Niikfl
Si; I i-ii i urn
b i I ve i
Tliu 1 1 i urn
Tin
V.iiuiliiiia
Zinr
blOO
--
2.5
34.5
O.S
0.13
10
3.5
II. 0
7700
II). 5
0.3
184
10
0. (
--
--
14
23
42Ub
--
2
28
--
0.15
6.5
4.5
7.0
5080
14
175
--
5.0
0.25
--
--
--
--
22
5J45
--
3.5
30
I.I
11.5
5.5
124
8080
%
--
150
--
10
O.I
0.6
--
--
11
37
5H60
--
4.0
45
0.45
0.2
17
5
16.5
8'J'JO
68
--
I'Jl
--
12
--
--
--
--
14
:i4
78(.5
--
4.5
559
0.7
7.5
109
10
32.5
13810
425
3.275
250
0.17
11
1.2
--
--
6.0
20
328
74'J'j
-.
5.5
102
--
0.6
21
8.5
15.5
12565
47
1.6
1:12
0. 13
14
O.I
--
.-
17. S
54
5885
--
2.5
52
0.4
0.16
9
4
42
7175
14
-.
887
--
7
O.I
--
.-
12.5
30
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
'JOIO
--
4.5
110
0.7
0.12
14
8
174
11455
33
1532
0.11
12.5
0.2
--
--
2.5
18.5
59
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
HA
NA
NA
NA
NA
NA
NA
NA
5.0
99
0.8
0.2
16
£
II.5
137 IS
23.S
1211
13
0.2
23. i
43
HA
NA
NA
NA
NA
NA
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
151 I
8.0
OH
4
5VJO
6.U
2
O.I
2 . B'». I '10
001 I. I). 0
-------
IA1IIK 7 (lU-nl. )
ANAI.Y.SKS (IK SIIIOACt .Sill I. UKAII SAHI'LKS
KOSK TdWN.MIII' SITU - HI Oil I CAN
Sample Lot .it I on SKUA- 1 SKDA-2 SKUA- 1 SKDU- 1 SKIIA-4 SHIIA-S SKUA-6 SKIHl-6 StlIA-7 SKIIIi-7 StDA-B SJKMI-8 litllA-'J
l)al<- 8-2.J-84 8-23-H4 U-24-8S U-24-B4 a-2A-tt« 8-2/.-8A tt-24-84 8-24-84 8-24-84 8-24-84 8-24-64 8-24-84 8-27-84
I'jl .iilicli-l :.
4-uictlryl|ilitniul
2-4 dioiclliyl|ilit:iiul
let rarliloioctliylfiic
luliiiMie
1 1 li lilm ui-lliylenc
I'llli -- -- 2dUUIIU 4'JUOUO I800UO VJU IUO 92 26 300 110
xyl«:nes -- -- -- -- 1:.?....
1 ,2-JiclilornrllMiiu -- -- -- -- -- -- -- -- -- ,
I , l-lrii hloi ofllune
1 . 1 , 1-lrii lilufoclluiir -- . -- -- -- -- -- -- -r
llCIIZuif dl III
liiius 1 ,2-iliililuroelliy leiie
lutlliylcm: Uiloml.- J80 3.9 J4» )/ 42 18 52 IS 21 6.8 J.9 14 It
I Im.iut IK lilurutMliuiiu -- -- -- S.I -- i.4 -- 12 19 -- -- V!) 6.1
|ll-|ll Ut Illol 0|lllL-|Hll
i^ii|iliuroiu:
di'rlune -- , -- -- -- -- -- -- -- -- -- --
|>litliulaU-s (lol.il) -- VJU llbOO I'JUO 618/1)0 28IU -- 5JU 'JtiO
|ili<-iiul -- -- -- -- 550
pyi-L-ni: -- -- -- -- -- -- -- -- 860
lirn/.yl ulruliol
2.HS.I/U
/inl'» it l\
-------
TAIII.K
7
(Coul.)
ANAI.Y.SKS UK .SIIHKACK Kill). (iKAII SAMI'I>:S
KDSK TUUN.SIIII' SITE - HI cm CAN
S.im|iK- ll.ilc
I1.11 iitticl IM u
H.ldjs, T.'l.i
Alllmilinm
Aul iinuny
A i sru i *
II j r i uiu
Ili-iyl I iiuu
I .illinium
Cliiuiniiiiu
l.'ubj 11
l'l>|l|II'l
I lun
l.i-a.1
Cy.in I ilc
M.iiig«iiii::*c
Mtri t'ui y
Nirkul
liir I I'll i mil
b 11 vi-1
11,all mm
Tin
Vjn uili ma
7. i ur
Stl)A-IO
8-27-84
1916
5.0
0.45
A
261
SKUA-11
8-27-8'.
270J
14
53
0
0
5
j:
197
10275
1010
0.
3
16
5
0
IU
12.
BH
SKUA- 12
2230
--
9.5
17
--
0.07
5
--
43.5
758S
8
--
307
0.19
4. 5
--
--
--
--
29
bKIIA-13
B-27-U4
--
4
II
1.0
0. 12
II
5
27.5
HA 10
I.I
--
220
0. 1
9
0. 15
--
4.5
14
2'J
SKDA-14
B-2/-B4
--
13.5
B3
O.o
0. 11
9.0
5.5
ij
13265
II
--
402
7.5
0. 1
--
3.0
13
IB
SKIM- 15
8-27-B4
3424
_.
3.0
29
O.B
0. Id
6.5
3.0
40
5110
15
--
201
--
5
--
--
__
--
31.. 5
SKIM- Ib
8-27-84
2<>47
--
2.5
21
--
O.I
5.5
--
6.5
4107
10
2110
--
4.5
--
--
6.0
--
IB
SKUA- 1 7
B- 2 7-84
2542
--
4.5
28.5
0. I
0.4
10
2.5
99
19950
24
--
IAA
--
9.0
O.I
--
--
8A
SKUA- 18
8-27-84
50J5
6
3.5
344
0.3
8.3
38
3
19580
6610
2357
0.475
73
0.13
12
O.I
1.4
23
2251
.SKUA- IB
8-27-84
4315
4.2
2.0
36S
--
8.2
33
--
27045
6620,
3200
0.425
63
0.11
17.5
1.4
62
1969
btllll- 19
8-28-84
2678
--
3.5
IB
0.4
--
6
3.5
11
4961
15.5
167
5
O.I
--
--
28
.SKIIA-20
8-28-84
4171
--
1
IB
--
--
7
3.5
10
6440
5.5
--
IHb
--
7.0
--
--
__
10.5
19
utnu
-2U
B-28-B4
3095
--
5
IB
0
II
7
3
9
(250
s
--
214
--
o
--
--
--
i/
.O
.00
. 5
.5
.'.
.'. H5. I 70
Oil I 1.0.0
-------
TAUI.K
(Com )
ANAI.VSKS UK SIIKIAI:K'.SIIII. UKAU
mist Tiiwmmii' SITK - MICHIGAN
Saco|ilc- bullion
Sample IKile
SKUA -It)
B-27-B4
SCIIA-II
8-27-84
fit DA- 1 2
S-2/-BS
SKIIA- IJ
SEDA-l'i
B-27-B4
SKIIA- »
SKKA-16
8-27-B4
SKIIA-1 /
B-2/-84
iitllA-18
H-27-B4
;;toA-ia
B-27-64
SKIIU-I'J
8-28-84
SKDA-20
tt-28-84
8-28-84
lelrjililoioolliylcnc
lollll-IIL-
I r I cli I it roc I liy I cue
I'Cllu
xyluurs
1 ,2-iliililoi oclluiie
I , l-lriclilnruvlliiiiie
1 ,1 , l-lrii Illuroflliani;
bfiizuir j< ill
lidns 1 ,2-JicliluiucMliyli.-iie
WL-lliylfiic thloii.lr
I liiorulfit liloiuflh.ine
100 I4IU 1310
IB
7.1
I (10
Jl
4tt
1.4
11!
J.9
1480 1100 2480
(llll'llul
pyrriut
licn/.yl a I culm I
i O.O
-------
TAUUC
. )
ANAI.YSKS OK SIIKKACE SOU. UKAII bA
HUSK TOUN.SIIII* SITE - HI cm CAN
e l.oral iuii
Satuute IKilu
I'd 1.1 nit-11'rs
Mt-ljls, Tul.il (iug/kK)
Aluminum
Ant i tunny
Ai'sririr ^
It.i r i im
llciyl I inn
Cjilmiuui
Cliriiuiiiu
I'oli.i 11
<:..|i|iei
I run
l.ca.l
Cyan I ilc
Mallgallrsr
Hr11 my
Nuk«l
.Sc I,-11111111
Si Ivc-l
Thai I iuui
Tin
V«iii.iili uiu
2int
SKDA-21 SKDA-22 iiK»A-2:i SKDA-24 .SMIA-25 KKIIA-26 SKUA-2 7 SEUA-28 hKIM-28 SK.IlA-2'J SEDU-30 Stllll-.ll StllA- 12
&-2&-RI. 8-2H-B'. K-28-B/I 8-2B-84 8-28-B'i B-28-A4 8-28-84 8-2B-84 8-2B-84 8-28-84 8-28-84 8-28:tt4 8-2'J-84
110:1
2.
36
0.
0.
4.
I.
6I'J5
8
270
5.
22
45
08
5
5
I "72
1.0
21
0.4
0.0!)
5
4!i>
2854
5.5
151
2.8
O.I
0.7
14
2M60
3.0
27
0.3
O.IB
4.5
8.5
4702
3.5
33.5
0.7
6.5
3
7.5
iyO
8
5a
--
5.5
--
--
2.3
-- '
25 .
4/05
--
2.5
87
0.8
0.25
J
5.5
10
7010
14
1179
O.I
10
0.15
--
--
10.5
35
5255
3.5
46
0.13
9.5
6.0
10
7'J/O
10
505
--
)
O.I
--
--
13
30
5710
3
48
0.13
10.5
6.0
9.5
8320
10
518
ij
0.15
i
13.5
33
4738
--
3.5
43
0.8
«J.5
5.5
8.5
7385
11.5
455
--
7.5
0.7
11.6
32
3075
I.I
2.0
,25
: 0.12
5.5
5.0
7.5
5/05
7.5
313
0.1
5
22.5
IB'J5
--
8
57
--
0.13
4
--
3.5
10020
5-5
1404
--
3.0
--
--
--
--
34
2H'iL
--
2.0
26
0.35
0.12
4.5
--
4.0
41 12
6.3
101
--
2.')
--
.
--
--
IB
2 H',. I /()
01)15.0. (I
-------
TAIII.K
7
(Cunt.)
ANAI.YSKS UK SIIUKACK Mill. CHAII SAtll'|.KS
BOSK TOWNS!!!!' Slit - rilUIICAN
Sample l.ui.iliuii*
S.nu|>lu Ikili-
I'ai dttifl t'i'tt
SMIA-21
A-liu I liy l|i|icn»l
2-4 ilinirlliyl|ilirn»l
t e( i uililuiocl |iy ICIIL-
1 lit lilinot/tliy Icnc
HCIIs.
xylciu's
1 ,2-tli * lilfiruirl IIJIIIT
I , l-l l it lili>i iii-l ll^nc
I , I , 1-1 1 It Illuiiu-Uiaiie
tii-n/iiir ji nl
Iraus 1 ,2-iliili|niiii.-tliyUriir
wrlliyU-iiL- rliluriili-
I Itiuioli li Illul ucl liaiitr
btl)A-22
S-28-U4
SKDA-2'i
8-2B-B4
SKOA-24
SKI)A-2i
B-2B-BS
SKDA-26
SKIIA-27
8-28-BA
KKHA-2B
SEDti-28
8-28-84
SKI1A-29
8-28-84
SKI>B-:iO
B- 28-84
.SKHII-11 iitllA- J-'
8-2B-84 8-2V-B4
92
2'JO
S80
2200
IIUl)
JOO
67
IUU
IB
S.8
8.i
14
II
cs (lolal)
(lllruol
pyriMiu
licn/yl iilcnliul
«JOOO
OIHd.O.U
-------
TAI1I.K
(Conl.)
ANAI.YSKS :
8-29-84
2204
81
318
--
0. 16
6.0
--
4.0
23480
14.5
--
154
6.0
--
33
8-2-J-H4
SKIIA-37
B-2'J-l)',
SKIMI-37 SKUA- 38 . SKDI1-38
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
HA
NA
NA
NA
NA
NA
NA
1856
--
2.0
-------
TAHI.K 7 (Cunl . )
ANAI.YSKS OK SUIIKADK SOII. lil(AU SAHM.tS
KOSI-: TOWN.SIIII* SITK - Hlt.HKiAH
l.ocalioi, SEOII-JJ Stl)A-34 SKIIA-35 SKIlU-35 Si:UA-K- SKI)II-.|6 SKIM-17 .SKIIII-37 StllA-38 btl)B-3B Stl)A-3'J SKDII-40 StDU-'tl
Ujie 8-28-84 8-29-84 8-29-84 8-29-84 8-29-84 B-29-85 8-29-84 8-29-84 8-29-84 8-29-84 8-29-84 8-2'J-84 B-29-U4
l*.n jmrl t* rb
(lijjarilis ((IK/ kg)
2-4 dimethyl phenol
Ictrui liluroetliylene
e 10
I'CBs -- 4IUIO 199 VM 2101) 40UO 74 37 -- -- 200 110
xy I (MIL'S
1 ,2-dii'lilurui-lliuiiK -- 4.7
I , l-li i< hloructlune -- -- -- -- -- -- -- -- -- .
1,1 , l-l riihloroi.-lh.ine 'J.4
1 1. ins 1 ,2-ilicliluruclhylenu
wi-lhylciif .hlo.iiht 110 41 72 J2U I3UO M :t4 14 14 57 7.8 120
I luorut lit lilorotrlliane
|
-------
TAIII.K y (Conl . )
ANAI.YSKS (IK SIIKI-Al.'K SOU. UKAII SAni'l.KS
TUWN.'illir SI IK - MICHIGAN
S.ini|ilc 1.1.1.11 lun
l'j| .iiurl ri s
Nirlal*, T..I.II (lUK/kK)
Aliiuiiiiuin 4056 3840 (. IHII
Antimuay
Ai SI-MI i I.B 1.2 !I.O
lljinira 52 5!) 68
Ili-iyl I mm 0. IS 0.3 0.5
Cu.liniiiui 0.26 0.32 0.42
Cliiuuiiiim 8 6.0 'J.5
folia 11 3 2.7 4.0
C..|.|.i-i 7 5.5 6.0
(run 6305 4823 8100
l.i. nl 21 17 2'J.5
Cy;mi 5')
^KIlA-45
I1-2U-K4
4I45
l.u
50
0.5
0.2
/.O
.» . 5
6.5
6I45
II. 0
540
5.8
J.5
2!l
UKI)A-4(>
. .B-2'J-II4
IHI;
I.O
41
0.1
0,2
6.5
3.5
4.0
5220
12
83<)
5
--
__
2*1
!iKI)A-4/
8-2-J-B4
30-J5
I.J
IB
0.45
0.07
6.5
3.0
5.0
5185
6.3
212
5.0
--
-~
16 .
.SKDA-4B
II-2'J-B5
45 /B
2.3
24
0.45
0.16
-------
TAIII.K
(Cunt.)
ANALYSES (IK SIIKKACK SOIL liKAO SAHI'I.Kb
KM:;K TdWNsmr .si IK - MICHIGAN
S ..... |ilr
.SKI1A-42
8-2U-84
SKI)U-4:i
8-2B-84
SKUA-44 SKIIA-'.S
SMlA-4l>
H-J')-U'.
SEIIA-4/
B-20-B4
SKIIA-AB
B-2'J-BS
SKIiA-VJ
8-2'J-BA
I cl i at Itlui iii-thy lent-
t IllllCllf
1 1 Itliloroi-lliyli nr
1 ,2-iliililuroirlliaiii-
I , l-li it liloiin.-lli.nu:
I , I , l-t l iilllnlui-llMlic
bfiioiir ui ill
I r jus 1 ,2-iliililuiuelliytt:iic:
lui-lliylfiir cliliii iili-
( \ inn ul t i i li I uruu I luiii!
|it* nl ai hlin'iiplicuu I
isu|>lii>ruiu*
aicluiic
lilillulutru (lol.il)
plunol
fiyiriio
|icii/.yl almliol
6/0 IJOU
1200
2700
5200
..I/O
01120.0.0
-------
TABLE
7
ANALYSES OF SURFACE SOIL - GRID SAMPLES
ROSE TOWNSHIP SITE - MICHIGAN
Sample Location
Sample Date
Parameters
Metals. Total (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Cyanide
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Tin
Vanadium
Zinc
7S-OE
8-22-84
2566
--
2.5
16
0.3
0.07
5
5.0
4848
7.5
137
--
3.5
--
__
--
17
7S-OW
8-22-84
5260
4
365
0.7
6.0
30
3.5
8.5
8215
125
240
8.0
1.9
2.5
14
93
7S-IW
8-22-85
3730
--
3
326
0.6
26
3.5
8.0
6570
143
0.5
175
0.18
7.0
0.15
-
10
226
6S-OE
8-22-84
4176
3
236
0.5
0.25
15
4.0
6.5
6465
132
--
192
--
7.5
0.15
11
93
6S-OW
8-22-84
3143
--
2.5
22
0.4
0.08
7.0
4.0
18.5
5870
9
244
6
::
3.5
20
63- IV
8-22-84
7170
4
611
0.35
2.3
70
7
25.5
11095
1480
--
225
0.14
31
0.45
46
19
312
5S-OE
8-22-84
3794
3.0
35
0.11
6
3.5
5
5845
8.5
0.575
389
5.5
__
22
5S-OW
8-22-84
3810
1.2
3.5
420
0.85
SO
3.5
12.5
6055
345
0.85
162
0.13
10
0.15
--
302
5S-IH
8-22-84
5035
3.5
262
0.4
0.6
48
6.0
14.5
8115
216
--
182
0.12
13
0.2
__
13
337
4S-OE
8-22-84
3881
2.5
53
0.3
0.18
9.0
4.2
5.5
6050
87
0.55
282
0.15
6.0
O.I
....
38
4S-OW
8-22-84
4675
1.8
5.5
180
0.6
3.0
32.5
3.7
10
7930
599
0.65
205
9.5
0.5
6.0
12
158
43- IV
8-22-84
5025
3.5
120
0.3
0.5
26
4
16
8820
104
0.625
210
0.11
10.5
0.2
2.5
13
131
3S-OE
8-21-84
3265
2.5
37
--
0. 13
8.0
4.3
5.0
5055
13
--
304
--
5.0
__
-
--
26
3S-OV
8-21-84
4613
4.5
87
--
0. 15
15
4.5
9.5
7185
41
--
209
0.17
8.5
~
_ _
12
100
2.85.170
-------
TABLE If (Cont.)
ANALYSES Of SURFACE SOIL - GRID SAMPLES
HOSE TOWNSHIP SITE - MICHIGAN
Sample Location
Sample Dale
Parameters
Organics (pg/fcg)
4-nethylphenol
2-4 dimethylphenol
tctracbloroethane
tetrachloroethylene
trichloroethylene
PCBs
xylenes
1,2-dichloroethane
1,1,1-trichloroethane
benzoic acid
ethyleoe chloride
fluorotricbloroethane
peatachlorophenol
acetone
phlbalates (Total)
phenol
2-4 dimethyl phenol
pyrene
benzyl alcohol
7S-OE 7S-OW 7S-IW 6S-OE 6S-OW 6S-IW SS-OE 5S-OW 5S-IW 4S-OE 4S-OW 4S-IW 3S-OE 3S-OW
B-22-84 8-22-84 8-22-85 8-22-84 8-22-84 8-22-84 8-22-84 8-22-84 8-22-84 8-22-84 8-22-84 8-22-84 8-21-84 8-21-84
23000 1600
5.2
3200 980000
24000 42000 64000 80900
840
390 8000
17 14 23 86 19 300 29 24 20 18 17
8200
3000 760 1200 21000 1000 1920 -- 4S70 2600
6.1 120 ISO
1600
2.85.170
-------
TABLE 7 (Coot.)
ANALYSES OF SURFACE SOIL - GRID SAMPLES
ROSE TOWNSHIP SITE - MICHIGAN
Sample Location
Sample Date
Parameters
Metals. Total (cog/kg)
Aluoiuum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Cyanide
Manganese.
Mercury
Nickel
Selenium
Silver
Thallium
Tin
Vanadium
Zinc
3S-IW
8-21-84
5535
2S-OE
8-21-84
3235
2S-OU
8-21-84
5080
2S-IW
8-21-84
5845
IS-OE
8-21-84
3497
1S-OW
8-21-84
4967
1S-IW
8-21-84
3763
OS-OE
8-21-84
5865
OS-OW
8-20-84
4975
OS-IU
8-21-84
4840
OH-OE
8-20-84
3443
ON-OW
8-22-84
4073
OH-IU
8-21-84
3385
BASE-GE
8-23-84
2864
4
390
--
0.2
36.5
6.0
13.5
9305
201
0.28
233
14
0.15
::
14
334
2.3
41
0.4
0.1
6.8
4.5
5.0
5130
22
378
4.5
~~*
::
30
5.0
146
0.3
24
6.0
12.5
8800
98
256
12
0.1
::
14
142
4.0
164
0.5
0.38
22
5
13
10530
38.3
293
12
....
"
15
158
2.5
31
--
0.11
7.5
4.25
5.0
5260
13.5
172
--
5.5
_
::
33
4.5
86.5
0.3
23
148
19
8265
80
0.35
173
O.I
12
- _
2.5
12.5
76
4.S
225
0.4
29
6.0
8.5
7240
170
189
8.5
::
135
5.0
40.5
0.74
12
6.0
11.0
9945
23.5
284
11.5
0.35
::
15.5
40
3.
3010
0.
510
4.
11.
8125
34
144
0.
9.
..
::
14
2323
5
26
0
5
11
5
3.2
1Q5
0.09
43
6.2
9.0
8255
67
215
9.0
0.15
2.2
14
145
5
314
3.8
11.0
5.5
8.5
5925
36
0.35
195
0.15
6.5
""
::
52
2.3
95
0.2
13.5
4.0
9.0
6620
54
0.28
205
O.I
7
"~
::
it
62
3
35
--
0
10
5
8
7510
20
0
262
0
5
-
-_
12
34
.8
. 11
.0
.0
.55
.1
.25
2.0
21
--
--
5.5
--
5.0
5335
7.0
--
206
--
4.S
_ _
--
--
20.5
2.85.170
-------
TABLE «7 (Cont.)
ANALYSES Of SURFACE SOIL - GRID SAMPLES
ROSE TOWNSHIP SITE - MICHIGAN
Sample Location 3S-IW 2S-OE 2S-OW 2S-IW 1S-OE 1S-OW 1S-IW OS-OE OS-OW OS-IW OM-OE OH-OW ON-IW BASE-OE
Sample Date 8-21-84 8-21-84 8-21-84 8-21-84 8-21-84 8-21-84 8-21-84 8-21-84 8-20-84 8-21-84 8-20-84 8-22-84 8-21-84 8-23-84
Parameters
Organica (pg/kg)
4-methyl phenol 4700 -- ? 850
2-4 dimethylphenol 710
letracbloroethane
tetracbloroetbylene
tricbloroetbylene
pCBs 17000 460 10900 30000 24600 1300 7200 700 9400 28800 65 16000 2400
xylenes
1,2-dichloroethaoe
1,1.1-tricbloroethane -- -- -- -- " "
beozoic acid -- -- " ' " 5200
melhylene chloride 180 190 34 55 100 180 230 110 300 840 48 8.2
fluorotrichloroethane
pentachlorophenol
acetone -- -- --
phlhalates (total) -- 4700 -- 840 2360 -- 2080 540 750
phenol
2-4 dimethyl phenol
pyrene -- . -- --
benzyl alcohol -- -- -- --
2.85.170
0028.0.0
-------
TABLE 7 (Com.)
ANALYSES OK SURFACE SOIL - HIGH INTENSITY GKID SAMPLES
ROSE TOWNSHIP SITE - MICHIGAN
Sample Location BASE-OW 1N-OE 1N-OEA1 1N-OW 1N-OWU1 2N-OE 2N-OEA1 2N-OW 2N-OWA1 3N-OE 3N-OW 4N-OE 4N-OW 5N-OL 51.-
Sample Dale 8-23-84 8-22-84 8-22-84 8-22-84 8-22-84 8-23-84 8-23-84 8-22-84 8-22-84 8-23-84 8-23-84 8-23-64 8-23-84 8-23-84 8-L'>
Parameters
Metals, Total (mg/kg)
Aluminum 2910 4494 5535 3623 NA 5125 3798 3288 3478 3613 3500 3682 2929 3408 35)0
Antimony -- -- -- NA -- -- -- 6.5
Arsenic 4.5 3 « 2.5 NA 3.5 3.2 3.5 3.0 3.2 3.2 2.5 10 2.5 2.
Barium 447 27 36 28 NA 42 44.5 73 62 31 29 31 201 21 29
Beryllium 0.7 0.25 -- 0.8 NA 0.7 -- 0.35 0.6 0.35 -- 0
Cadmium 0.15 0.12 0.16 0.12 NA 0.14 -- 0.16 0.18 0.2 0.15 0.15 0.32 0.08 0
Chromium 7.0 9.5 10 8.0 NA 9.5 7.5 6.5 7.5 9.0 6.0 8 10 6.5 7
Cobalt 3.0 4.0 5 4.0 NA 3.5 4.0 3.5 3.6 4.0 4.5 4 4.0 4
Copper 7.0 6.5 8 8.5 NA 7.5 65 12 11.0 7.0 7.0 5.5 11 6.5 7
Iron 6030 6750 7830 7030 NA 7830 6065 5735 5905 6050 5385 6425 5410 4905 Sbt.O
Lead 15 12 14 13 NA 13 10.5 29.5 25 10.5 11.5 10 1485 7 Jo
Cyanide -- -- -- NA
Manganese 224 203 252 202 NA 346 273 250 286 301 262 357 182 208 180
Hercury 0.11 -- 0.11 -- NA -- -- -- -- ~ 0.1
Nickel 5 6.5 9.0 5.5 NA 7.0 5.0 5.5 6.0 6.5 5.5 7 6.0 5.5 5.
Selenium 0.1 0.1 -- 0.15 NA -- -- -- -- 0.15 -- 0.1 0.1
Silver -- -- -- -- NA
Thallium -- -- -- NA 0.9 0.8
Tin 3.0 2.5 -- NA 4.0 -- 2.2 2.B 2.4 4.0 1)
Vanadium -- 12 14 11.5 NA 13.5 -- -- 10 -- -- 12
2inc 27.5 26.5 38 26 NA 33 31 33 31 25.5 25 21 166 19 G'J
' A and B suffixes denote duplicate samples.
-------
TABLE H (Coat.)
ANALYSES OF SURFACE SOIL - GRID SAMPLES
ROSE TOWNSHIP SITE - HICHICAN
Sample Location
Sample Date
Parameters
Organics
4-oethylphenol
2-4 dioetbylpbenol
tetracbloroe thane
tetrachloroethylene
trichloroethylene
PCBs N
xylenes
1 ,2-dichloroethane
1 , 1 , 1-trichloroetbane
benzole acid
metbylene chloride
fluorot rich loroe thane
pentachlorophenol
acetone
phthalatea (total)
phenol
2-4 dimethyl phenol
pyrene
benzyl alcohol
BASE-OW 1N-OE 1N-OEA 1N-OW 1N-OWB 2N-OB 2H-OEA 2M-OW 2H-OWA 3N-OE 3H-OW 4H-OE 4N-OW SN-OE SN-OW
8-23-84 8-22-84 8-22-84 8-22-84 8-22-84 8-23-84 8-23-84 8-22-84 8-22-84 8-23-84 8-23-84 8-23-84 8-23-84 8-23-84 8-23-8'
4400
160 27
48 220 520 63
12
520
4.9 11 41 23 43 58 20 30 39 32, 17 43
72 65
8.6 3.9
270
8SO 900
1770
0030.0.0
-------
TAIII.K 7
ANALYSIS UK SllllSllliKACK SOU. SAHI'I.KS
WISH TIIWN.SII It* - Ml CM I CAN
S.iuulc l.uijlion
Sani|i|e IKile
I'ai jiui'ttis
Metals,
ToUl (my/kg)
Aliuuiiium
Aul imiiuy
Arsenic
II j r i un
Bcryi 1 ium
C, iilmium
Cli minium
Cul.all
CUUJILT
1 1 on
l.i-jil
Cyan i ilr
N. iiiK.iue.se
Men in y
Nnkel
Selenium
Silver
'Hi j 1 1 i HID
Tin
V. mail ium
X.iiir
SIU 0-2
I-9-8S
4330
...
--..
11
8830
V.5
13')
18
SUI 2-4
1-9-8!)
3180
.-
moo
31V
...
33
SIU 6-8
l-9-8i
4U/0
13
10200
24
2 VI
32
SIU 8-10
I-9-8S
5080
IS
l/i
12'JOO
5.9
300
...
3d
SIM A 8-10 Sill 10-12
l-'J-8'j 1-9-85
/iBSO 4410
8.6
13 11
11700 13200
V.2 B.I
2'> 1 24 /
..i
33 34
SII2 6-8
1- 13-85
4040
6.6
9400
4.V
ISO
3/i
SB2 12-14
l-K-te
4930
...
12
10500
5.6
33!>
--
2(t
SB2 18-20 SHI 2-
I-I4-8S 1-10-8
3120 dlHli
_._
6.8 14
8940 1 141)0
4.9 5.3
0.27
29S I/.ri
...
'
20 II
2.UJ.IVO
0042.0.0
-------
TAIII.K 7
ANALYSIS OK SIIIISIIKKACK SOU. SAHI'I.KS
KuSK TUUNSIIII' SITU - III CM I CAN
S>iui|>li: I. in J I inn
llati:
Sill U-2 Sill L'-'i
|-«j-B-> I-'J-B!)
SHI 6-11 Silt H-IO SHI A 8-10 Sill 10-12 SII2 6-8 SU2 12-14 SII2 1B-20 SltJ '!-'> SI1J t,-L
l-'J-Kri l-'J-8'j 1-9-H!) l-'J-8r> I-TJ-B1! I-I4-8S 1-14-85 l-lll-«'i I-IO-81)
4-iui-lliyllilifiiul
2-4 ilimi-lliyl|>hi-nul
ti-l rji liloiorlliyli'iic
lu! iii-iif
1 i ii lili'iortliylrm:
I'CBs
xy I rues
1,2-iliililoioi-llune
I , l-ili< liluriii'lli.iiiL'
1 ,1,1-1 1 iililoiiu-llijiiL-
1,1 ,2,2-lL-luclilor
ticiizuic ai ill
1 1. nib 1 ,2-difliluroL-lltylciiir
mrlliylriif rliluiiiti;
Ul'L'tDIIL'
|ilii'iml
2 -Inil. ..... at-
>li-ii-liiilyt|i
lii-n/.o(.i)jiillii.it me'
i lirysrm-
l»-u/.o(li)l liiurdiitliriiir
i soplioi uiir
vtliyllii-n/triif
si yntiu-
ill -n-m lyl|>iilli.ilcilc
ca i lion ill bill tiili:
>yi cue
ii - ii i 1 1 us I il i I'lirny I am I nir
i hi n into ria
10
4SIS
24H
10(11)11
68.IIU
2/i.^U
1120
Ki'.llll
6.1
74U
1711
ll'OOII
6'JU
4)11
20
I
S4U
5SI1
61 OH
SOU
OKOII
"
lyooj
7700
76000
66000
390.10
390JI1
VJO.I
190.)
.
--
26
77
120
370J8
370.111
--
--
2BU
220
45
380.111
9
7
64U
2IU
--
58011
518
J80J
13.12
.1/0
..0.0
-------
S.IIII|I|L- l.oial inn Sin 4-6
S.iui|ik- ll.ilc 1-10-85
I'.irjiuclers
Tula) (nig/kg)
A 1 HID ilium 5880
Aul imciiiy
Ai bruit
HJI ium
Itirtyi lium
C.iituiiiiia
I'll Him illlD 11
C..IMU
Cu|i|irr
linn 13200
I.I.M.I . 8.1
Cy.miilr
H m^tincM' 247
N<-iriiry
Nnlu-l
Si- 1 fit i nra
S 1 1 vt; r
Tli.il 1 inm
Tin
V.i.l.nliiiiu
Xiiu 34
2 . Kri . 1 lit
(Hi'. 1 I) tl
TAIIl.t 7 (cuiitiiiiiL-J)
ANALYSIS OK SIlHSIIKFACK SOU. SAHH.KS
KOSK TOWNSHIP - HI cm CAM
SU3 8-10 SHI 10-12 SHI 12-14 SI13A 12-14 SB) 14-16 SI14 2-4 SU4 6-8 SU4 10-1.2 SU5 2-4
I-IO-8S I-IO-K5 1-10-85 I-IO-B5 I-IO-H5 1-13-85 1-13-85 1-13-85 l-lu-BS
.
3610 1450 2030 1610 S82 3330 3180 1660 5()
...
___ ... -.. -
. ...
:
. _-_ . ( ...
16 16 9.0 6.6 10 6.4 , 20
... ...
15
12800 1430(1 12'JOO ')/«<) 45000 6/60 6640 4000 1820(1
5.8 5.8 - 3.0 --- 6.6 6.0 --- 12
2'J2 4.3 324 356 103 U>8 100 36 421
... ---
.-. ...
. ...
: ...
34 2') 2'J 25 22 23 14
-------
Sample' l.oi jt ion
Samp I L- lljttr
TAHIJ-: 7 (C.,1,1.)
ANALYSIS UK SUItSIIUKACK Sill I. SAMI'I.KS
HUSK TOWNSHIP SITK - HICIIICAH ,
I
Sill K-III .Sill 10-12 SIO 12-14 SIUA 12-14 Sill 14-16 SB4 2-4 SII4 6-8 SII4 10-12 SB5 2-4 SII5 8-10 SHS
1-10-85 I-IO-BS I-KI-B5 1-10-85 1-10-85 1-11-85 1-13-85 1-11-85 1-16-85 1-16-85 1-1
Organic;
2-4
Irt ui lilouu-tliyli-iie
lolllUIll'
1 I iililui i.rlliyli'iir
Mis
xylrm-s
I , L'-iln liloiDftli.ini'
I , 1-ilii liluim-lluiuc
1,1, I-U it liliiinrllianc
1 , 1, 2, 2-1 1- 1 ladiluruclli.iui:
liL-nzoii aciil
I raus 1 ,2-iln liluiuulliylcnc
uii-l hy I flic flilni iilu
neul ai li 1 ii i'u|ilii:iiu I
al ClOUC
(lIlCIIIll
'J-lillluilune
ill -n-linl y I phi ha I al e
lirn,!i>(a).iiillii.M cue
I iii>rlil lulalr
n-n i 1 1 us i il i (iliriiy I ma i nc ( I )
lIlIlM Illlillll
21
A III
l/i8U
2.ri8K
2.I5K
7.'J7
36.1711 53.5311
2<).06II 63.I4B
/86
12,/i'J
17000
740
91000
1001)00
4600
1550
310000
IU00.1
6V)
J60.I
I 100
L'/OO
5011
Mil
--
--
1 00011
--
--
--
--
-.
--
72001)
. 41001)
.1601
I 00000
360.IB
160 IU
--
--
-.
--
--
--
--
3811
48
--
210
360.IB
360.111
--
160.1
--
--
--
-.
--
--
4511
65
--
34
3'JU.IB
3'JO.IB
--
--
--
T-
--
--
--
--
570.1
IIOOJ
--
3500
370JB
2IOOU
3800
--
2000
IfiOQO
4200
I'JOO
2100
370.1
--
.-
--
--
360.1 U
350011
8500
--
2100
. 66000
25000
6'JOU
3.10(1
--
5501
II 111)1
--
I4DUU
160111
loo III
K.lll
--
--
550J
--
U.DI
--
--
'.SOI
> ' -.1/0
0.0
-------
TAUI.K 7 (irunlinucil)
ANALYSIS OK SIIHSllKKACK SOU. SAMI'l.tS
KUSK TOWNSHIP - HI CHI CAN
Sample l.iitallun
S.unjili: llalc
Parameters
Helals,
Tula! (ing/kg)
A 1 null HUM
An 1 imuiiy
Arsunii:
Barium
lleryi 1 iiua
Cailmium
Chromium
Col.all
Cupper
1 lull
U.i.l
Cyan i ile
Manganese
Heirnry
Nickel
Selenium
Si 1 VIM
Ilia 1 1 1 llw
Till
Vadaililim
Xiui:
2.BS.I/U
01144. 0.0
SIlS 8-10 SB5 20-22 SI16 2-4
1-16-85 1-16-85 I-I3-H5
56SO Iu50 4S40
...
4.1 ,
14 6.1
II 100 9S40 'JOI.O
10 5.7
243 20
6.1
...
8.4
.8830
5.4
238
20
SII7 12-14 SB7 22-24 SII8 u-8
1-12-85 1-12-85 1-12-B'j
806 731 Ml
...
...
1.6
. 30'JO 2460 3120
3.7
104 70 103
...
..'.
12 II 13
-------
iAIII.K 7 <«:"»» )
ANALYSIS UK MIH:;III;KAI:I-: sun. SAHI-I.K.S
KliSK IllUUSIIir SI IK - HIUIICAN
S.IUIJilr I.IM ,ll Mill
Sjuijiji- ll.ili;
l'.ir.nui!ti:rs
2-4 l-IJ-8.') l-ll-K'i l-K'-Bi l-IL'-Bb I-I2-BS l-l
SH8 0-8 SII8 14-16 SliBA 14-16
1-12-8* I-I2-8S 1-12-8'.
SI
VI-
'JJ
lii. s(2-L-lliyllu-xyl)iihlli.i late
rluyueiu-
l>rii/i'(l>)l liiiiraiillii nc
3HO.IU
I/O III
S 70.1 II
' 370.18
tlitoiolu'ii/fiiv
<! liyllieiut'iic
.slyifiu:
(nil yllicuzyl|ililli.ilitti
ill -n-iit (yl|i|ill
|llll IIJIll III I'llL'
r.iiliini ill su I liili:
:i60J
IIOOJ
3601
n-nil rositli|
-------
TAItl.K 7 (ronliiim-.l)
ANALYSIS OK .SIIIISllltKACK SOU. SAHI'LHS
KOSK TdWNSIIII' - MIUIICAN
Saui|> 1 e l.ui .1 1 i uii
Sample Date'
Parameters
Htlals,
Tulal (uig/k)*)
Alum ilium
An I iuiuny
Aruenit
ll.uiiio
lie ry ilium
Cailiuiuto
Chromium
Colult
('ii|i|it*i
1 run
l.e.,,1
ry.iniJe
Manganese
Mercury
Nickel
Si.- 1 mi urn
Silver
Tlia 1 1 i inn
Tin
V.ulailiiiiu
Xllir
SUB 14-16
1-12-85
/'JO
...
2800
0.23
87
...
...
...
SIIHA l/i- 16 SUB 20-22
1-12-B-i 1-12-85
1140 1470
14
4580 /OiiO
4.2
124 284
IK 21
SIW 2-4
1-17-85
4:u>u
62
___-
A.'J
17
6'JJO
4. 1
:
267
-__
8,2
_'__
22
SU9 16-18
1-17-85
6350
12
7.8
...
I2BUO
7.3
271
...
...
:io
SI19 24-26
1-17-85
2350
...
7. -8
6.1
...
11 100
6.6
Ul
44
SIIIO 0-2
1-11-85
10'JOO
82
26
17
19700
71
0.99
509
...
...
64
sum 10-12
1-11-85
2B/0
...
9.7
6.0
...
9300
6.3
22B
...
...
.._
2l>
Oll'i ri. 0.0
-------
TAHIi: 7 <<:""' ^
ANALYSIS UK .SilHSIIKI-ACK SOU. SAHI'I.KS
UIISK TIlWNSIIII' SITK - HI CHI CAN
:iaui|>le l.ur.itiuu
iamjiU- l).ili-
I'alMfti-lrrs
111 5.111 Mb (|lg/kg)
4-rai Iliylplienol
2-4 Jimrlliyl|iliunol
1 rl i at h 1 o i url liy 1 line
1 ol ill-lie
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