United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-90/126
June 1990
Superfund
Record of Decision:
Spiegelberg Landfill, Ml
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REPORT DOCUMENTATION 11. REPORT NO. I 2. 3. Hecipien1'8 Acce..ion No.
PAGE EPA/ROD/ROS-90/l26
4. TItle end SWIlIIe 5. Report Date
SUPERFUND RECORD OF DECISION 6/29/90
Spiegelberg Landfill, MI
6.
First Remedial Action - Final
7. Author(a) 8. Performing Organlzallon Hepl. No.
'0 ~rmlng Orgalnlzallon Nama and Add.... 10. Projec1lTaakJWork Un/t No.
11. Contr8c:1(C) or Grant(G) No.
(C)
(G)
12. ~ Organization Nama and Addre.. 13. Type 01 Rapor1 .. Period Co_ad
U.S. Environmental Protection Agency
401 M Street, S.W. 800/000
Washington, D.C. 20460 14.
15. Supplem8nl8ry No..a
16. Aba1rad (Umlt: 200 worda)
The 11S-acre Spiegelberg Landfill site is an active sand, peat, and gravel mining site
in Green Oak Township, Livingston County, Michigan. Surrounding the site are several
residences and small businesses which rely on onsite non-municipal water sources for
their drinking water supply. In addition, the Rasmussen Superfund site neighbors the
site to the east. From 1966 to 1977, a 2.5-acre portion of the site was used to dispose
)f septic, domestic, and industrial wastes, including paint sludge. Site investigations
revealed two areas of concern, a paint sludge disposal area, Operable Unit I (OU I) and
a ground water plume (OU II), contaminated as a result of the paint sludge disposal
area. The paint sludge disposal area was addressed in a 1986 Record of Decision (ROD),
and all wastes associated with the paint sludge disposal area were removed, including
the paint sludge and debris, the contaminated soil underlying the paint waste, liqu id
paint, laboratory liquid waste, and gas cylinders. This second ROD focuses on the
resulting ground water plume, which is estimated to contain 3,770,000 cubic feet of
contaminated ground water. Although the contaminated ground water plume has not yet
migrated beyond the site boundary, continued migration of the plume poses a threat to
water supply wells north and northwest of the site. The primary contaminants of concern
(See Attached Page)
17. Docurnant Analyala L Deacrlptora
Record of Decision - Spiegelberg Landfill, MI
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw, sw,
Key Contaminants: VOCs (benzene, toluene, xylenes); metals (lead)
b. Idantlfler8/Op8n-Endad Terms
-
c. COSA T1 FI8IdIGroup
18. Av8llabllty Statement III. Sec\8'I1y Cia.. (Thia Report) 21. No. 01 Pagea
None 68
I 20. Secl8'ity Cia.. (Thia Page) 22. Price
None
272 (4-77)
50272-101
(See ANSl-Z3I1.18)
See /MlrlJCliona on lie"",.
(Formetly NTlS-35)
Department 01 Commerce
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EPA/ROD/R05-90/126
Spiegelberg Landfill, MI
~irst Remedial Action - Final
Abstract (Continued)
affecting the ground water are VOCs including benzene, toluene, and xylenes; and metals
including lead.
The selected remedial action for this site includes ground water pumping and treatment
using chemical precipitation and pH adjustment to remove inorganics, biological treatment
to remove organics, and air stripping and granular activated carbon to remove residual
organic contamination, followed by onsite discharge of treated water to the ground water;
implementing institutional controls including deed restrictions; and ground and well
water monitoring. The estimated present worth cost for the remedial action is $4,420,000
which includes a present worth O&M cost of $2,000,000 over at least 5 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water cleanup goals include
benzene 1.2 ug/l (based on a 10-6 cancer risk level), toluene 40 ug/l (based on taste and
odor thresholds), and lead 5.0 ug/l (based on human lifecycle safe concentrations).
-------
.a..a.._~.
-.--=.._..'_a_':::":':"::"--- ..
.. -- .-.....-- -
.-. .....---."--- -..- _..- .-. -' -....--- --"",,,.., ...,.._--~_.-
IB:1ARATICIi PCm. '.IDE llementin:J the response action selected in this Record of
Decisioo (R:>D), presents a potential threat to p.1blic health, welfare, or the
environment .
Descriptioo of the Selected Remedv
'!his final response action ad:}resses the groorrlwater cx:ntamination plume-the
secx:n:1 of two Operable units at the Spiegelberg site. A so.JrOe control.
remedial action was ocn:iucted by a Potentially Respcns.ible Party durin:J 1989,
00 ~le unit 1-the Paint Slmge Area. Waste materials rerroved fran the
Spiegelberg site at that time were: 13,980 cubic yards of paint slmge arrl
debris, 26,800 albic yards of cx:ntaminated soils fran below the paint waste,
64 galla1S of liquid paint, 623 bottles of liquid laboratory wastes, and 4
ampressed qas cylimers. '!his action eliminated all wastes arXl cx:ntaminated
soils.
'!he remedial actioo chosen in the attached ReoJrd of Decisioo oc:nsti tutes the
final and overall l~ for the site. '!he primary goals of the remedial
acticns at the Spiegelberg site are to:
.
eliminate the potential for human eJCpOSUre to reua~ hazardaJs
substances, W1ch may occ::ur due to ~a1 of cx:ntaminated site
groorrlwater ;
edh e:ss all potential risks to human health and/or iJrpacts to the
environment.
.
-------
'!he ~i~l Investiqatia1 (RI) for the Spi~lb€arq site identified areas of
ocnoern includ.in;J areas of di qpceed hazardous waste, oontaminated soils, am
grcurxtwater. '!he 1986 Ja) addressed all areas of cx:noem exoept the
grcurxtwater. Potential risks associated with the site are posed by the
pat:.ential for oansunptiat of that grcurxtwater. '!he selected !:e:ai8:2ly addresses
the principal threat by grcurxtwater extract.iat ani treatment, with site use
~lcictia1S to insure the integrity of the !:~y. O:>rrect.ive act.ia1
WIA:III~ will be taken shcW.d JDa'1itoriIg in:iiC2te the ineffectiveness of any
<> .'1 >CI~ of the reL6Jy.
'!he !:~ c:hcsen to address the grcurxtwater oontaminatia1 inclu:ies extraction
of the grcurxtwater, and treatment of that water with chemical precipitation of
Detals and ~ adjustment, biological treatment, air strippiIg, ard cartxm
adsoIptia1, with re-injection of treated grcurxtwater via injectia1 wells. '!he
major ocrrpanent.s of the treatment inchxJe the followin;:
*
rem:JVal of inorganic contaminants by chemical precipitation followed by
~ adjustment,
rem::wal of the bilk of the organic oontaminants, inclulin] keta1es, by a
biological treatment system,
*
*
rem::rval of residual organic oontaminants via air strippi.r'q,
further rem:JVal of residual organic oontaminants via granular activated
cartxm,
*
*
disd1arge of treated water to the grcurxtwater via injection wells, ard
deed restrictions an:Vor other institutia1al controls, as necessary, to
insure the integrity of the l.e:a~y.
'lhe actual need for the use of all of the treatment ~~es or alternate
treatment prooess(es) will be determined thra.gh treatability evaluation
duri.r'q the p~ign P1ase. .
*
In acktitia1 to grcurxtwater treatment, a 'JIII:1'litoriIg program to verify that the
o:nt:am.inant plume is in fact beiIg captured by the PJrge ard treat system,
will be institute:i. '!his will i1d.u:le DD'litorin; of a series of JllJrritor
wells, al~ with a residential well m::nitorirg P:t:~LCWl.
1W'!1 ~-ratia1 of Statutmv DetP1"lft; rmticns
'!he selected le:u.:dy is protective of tnmJan health am the envirament,
CCIIp1ies with Federal and State requi.reIrents that are legally awliC2ble or
relevant and IJk,ILvpriate to the remedial actia1, and is cost-effective. '!his
b:ucdy utilizes permanent solutia1S am alternative trea~ technologies to
the max.i:JIum extent practicable, and it satisfies the statutory pref~ for
remedies that eDp10y treatment to reduce toxicity, 1IICi,)ility, ar volume as
their principal e1euent.
2
.. . . .' .. .. ~
-------
.--. ~.._.~...._..---'- -.----_.~...-'--------_.-----....._--~..- - --- _. .. - ..-.-.-..
. ;..--.... -. . .-.. .... ... . ..
A review will be cx:n:hJcted five years after oarpletioo of the ~il'll action
to engure that the 1:~ oa'1tinues to provide adequate protectioo of human
health am the envi.ranent.
~
Valdas V.
~cnU
U.S. Fa. -
~.
tar
V
t-
~ 2q~ If9o.
Dite
3
-------
~....-_...:.. .....- -~_.._--
....~ -~-_..-.
-~._~_.~._-.- --.... -....
" .
. '.
.
p;r!T~C6 ~ Jim 'JHE RIin.a
-------
. .' - ..---
--'--- .
-"~..:.:L.:~C":- . .
__~__M-""~---' -~.~ -
- . - - .. - .. - . - - .
... . .-.. - .
Figure 1
-
Spiegelberg Site Location
-------
:. ::::'::::':"::':~:':::::--:.:::r-~-=-~-..- -
. - .._~~~~-
-_._~ - h_- ._-. .
---..-.--. '0_"__"
.. -.-: ~_'r"'.":"'-,."";";;:''';'..~....~........,..._. ...-...
.no ..a' - ...~ "'.,
. .
lIicI11iQhts of O-lI1itv ~ri:"t'!ipwt-i,..,
A CCIIplete d'1ra1ology of ~vUty relatim activities for the SpiAf)P'~.rg
.ite is pravidecI as part of the at:t:.ached Respcnsiveness ~UMn;ltry. :ReaeI1t
activities iJx:ltr:ie the iRSUanOe of the Feasibility Study (liS) Report and the
Ptey:'6ed Plan for the Spiagp'~rg site m Jara.w:y 16, 1990. Site informatim
1n:ludinq the liS have been am 0CI"Itirue to be available to the pmlic as part
of the administrative record, 1IIlicb is mused at three infm:matia1
I'epo&itaries: the EPA Doc::Ket Roan for Regim V, in Chicago, nlinois, and at
both the Brighta1 City am the Hanturq City Libraries, near the site. 'Ihe
mtioe of availability of these finn~nts was p..1blished in the Brighta1 Argus,
the Ann AJ:bor News, and the Detroit NewsjFree Press. A p..1blic t'YTIWTIP1'1t pericx:1
a1 these doa.Dnents was held fraD Jara.JaZy 16, 1990 to Februaxy 16, 1990, an:l
was extel1ded thra.¥;;Ih March 19, 1990. A p..1blic meetin;J was held on
February 8, 1990 at the Green oak 'IOwnship Hall. 'Ihe meetin;J inc1u:Sed a drcp-
in availability session, a formal heari1q, and an infomal quest!m and answer
period. 'Jhe availability sessim was held in the early af't:errxx:I1. At that .
sessim MI:NR and tE EPA staff were available for informal di~1c:sim m the
RI/FS, the P1.~ Plan, or any other subject related to this site or the
adjacent p;.~'n~c::pn SUperfurr:i site. 'Jhe p..1blic hearin;J was held in the
evenin;, and acXlressed cx:mnents m the Spiegelberg site. An infomal session
followed the heari1g and cxnsisted of questioos and answers on this and the
adjacent p;.c:m1C!sen site. Response to the cx:mnents received c:lurin:;J the p..1blic
oc:mnent period is inclu:Sed in the Respa6iveness .SlmInaJ:y, 1Iiobicb is part of
this Record of Decision.
~ am R:>le of ~se kt!m WitNn Site strategy
Since the soorce-ocrJtrol ~i;llll actioo in (p:!rable Unit 1 removed the wastes
and CXI'1tami.nated soils, the remedial actim for (p:!rable Unit 2 will aaD:ess
the rema.in:iTg graJrrlwater area of CXI1Oem. '!he actioo will prevent further
migratia1 of the cart:.aminant plume into the aquifer that is the sooroe of
drink:irxJ water for the local residents. .
9-ty of Site Characteristics
ram Uses
'Jhe nort.hem portia1 of the Spi~~rg prcperty \t}ere the Paint Slui]e had
been ~ited, is alne-Jd:ly cxmnercially mined for san:! am gravel. '!he
rema.in:iTg prcperty is used for a small peat D1i.nin3 cperatioo and agria1l t:ural
activities. 'Jhe resideooe a1 the northern end of the prcperty is rented to
its aJlu:i1t ntY'!I1't'nts. Adjacent prc:perties are primarily used for 1IIi~.
residential anj agriail t:ural pzrposes. All residera:s and small bJs~~es
have cn-site water SlJI:Plies, as there are no m.micipal water distrihItia1
~ in the vicinity. '!he p;.cc::m1"'~ property to the east is another
SUperfund site 1Iwhicb CD1tains varicus dcmestic and industrial di ~ areas,
as well as an auto body slx:Ip. AlthcuJh it is difficult to project future land
UJeS, the area will prtbably sustain an increase in resi.dentia1 develc:pDent,
pu1:.!ailarlyas the potential threats fran the sites are Idtigatad.
CD1taminants famd in the CJl"CIUR1water are detailed in the .~""'''Y of Site
Risks" partia1 of this Reoo1::d of Decisia'1 (Ia). Generally, bath carci.rogenic
am ncn-carci.rogenic 0. ..,.an:!s were famd to be present in the Spi~] ~rg
CJl"CIUR1water plume.
-------
~. --.--- -- .
-- - - ..-.'-""'-->-.--".'--.---,,,,,.-,-
.-.J"--':':""':'-'::- --....~.._- ------.--- -----.. - -.-
- ....-....... -. -
~--- .,--,_..._.-~'.'-' '.---" _....':..
. ". .....- - . ._~.
Geologic Settim
'1he Spi~'Mrg SUperfun:I site is located 1n an area of rolling hills that
were deposited by glacial pt~t'es. 'these glacial ~f?es have ~~
features such as kames, terminal am grwrd m:>raines, am an:1 water filled
depressia'lS. ¥ames deposits are hilly rennants of prmrh,,,,' river delta
~its that typically have high an;le cross-b::rldi~, whictl can be famd 1n
~ sectias of the Spier:JP''-rg gravel pit. 'these deposits ocndst of
sands, gravel and clays. '!he teIms terminal and grc:urD m:>raines deDJte the
reqia1aJ. classificatioo of the tc:pography an:i deposits of the site. NeartJy,
penis and swcmps are noted SOJth am east of the Spiegelberg site.
'!be glacial deposits 1n the vicinity of the Spi~''-l:'9 site are \.D"derlain by
the Bayport Limestcrae of the Mississi~ian system. '!be Bayport Limestcrae is
stratigrcq:tUcally the ywrqest Mississi~ian fonnatioo EnXIUl1tered in the
Michigan Basin. '!he Bayport Limestcrae is classified as a light to dark gray
fossilifercus l.iJIesta1e an:i dolanite i.nt.erbedjed with quartz silt.st.a1e am
san:ista1e .
Maior Fin:lirgs of the Remedial Investiqation an:i R;~1c ~
In Septarber of 1988, the MmR am U; EPA i!Ctc::l~ a ~hll Investigatioo
Report for the Spiegelberg an:i Rasr!ussen sites. DJrln; the investigatioo, the
areas of CXI'X:)eJ:T1 identified for the Spiegelberg site were 1) ~le unit I -
'!he Paint Sl\D1e Dispcsal Area ard associated CXI1taminated soils, am 2)
Operable unit II - '!he GroJrrlwater cmtaminatioo Plume resul t.in:3 £ran the
Paint Sl\Xlge Disposal Area. A Risk Assessment was also OCIIpleted and 156111>(1
as a separate OooJrN:aTJt with the ~j~l Investigatioo Report.
.
'!be grc:urlwater OCI1taminatioo plume originates !ran the OCI1taminated
soils and waste materials :11'1 the Paint Sl\Xlge Area. All wastes and
OCI1taminated soils were rem:wed by Ford ~ ~ pm;uant to the
Dec-n1"er, 1988 O:nsent ~-=:.
*
'!be plume was defined as an area of OCI1taminatiCl'\ ~tely 500 feet
by 200 feet (at the time of the CXIIpletioo of the RI), flowin;J in a .
north, northwesterly directioo (Figure 2). It is estimated that 3.77
aillioo cubic feet of OCI1taminated grc:urlwater exists beneath the site.
GroJrrlwater flow rate is 266 feet per year in the upper ~fer and 131
feet per year in the lower aquifer. 1fc:1wever, ccntaminants within the
plume do mt ~.,. to be DDVln; at the same rate as the gran:lwater. An
uwer am a lower aquifer are present am are separated by a
discx:rIt.i.rJ. clay layer (Figure 3). cmtaminants have migrated !ran the
uwer aquifer to the lower aquifer.
'1be pot:.ential tbreat to hLman health fran OCI1taminated gran:lwater was
~s;ed m the scenarios of irgestioo of ccntaminants fraD drinkilJ;, am
inhalatioo of cx:rttaminant vapors that may EJDanate traD the water 1Il1en it
is used.
.
7
-------
.~..:~~-----...
r .
LEGEND
880.0
GROUNDWA TER CONTOUR. U,..ER AQUIFER
Figure 2 -
B'J.O- -
GROUNDWATER CONTOUR, LOWtR AQUIFER
Spiegelberg Site Estimated
Groundwater Plumes
~
ESTIMATED EXTENT OF ORGANIC.cONTAMINATION IN
U~ER AQUIFER
'-~ :\;:-~ ~.:,~..-,. . ~
ES TlMA TED EXTENT OF O"GANIC CONTAMINA TlON IN
LOWER AOUIFER
. tI.
r""""- --
SCALI. .In
110
I
.
+ LOOTION OF IoIVOROGEOLOGICAL CROSS SECTION
THROUGH CONTAMINANT "LUME ON FIGURE 3
-------
PSCW
IOI~ST
~ t~
~ 51"-...-52
,---U '
~ISO I I
I I
I I / / /
~ /.
. 100
I /
c
>
"
ISO
''''''10
I
51"-"'- 'IA
I
Isr-".-~:
II
51"---21
I
51'-...- SO
II
"
<
100
NOTES:
t. lOCATION ..JW..a ~ FQJIII 1-78.
2. All DlSTAHCU NfO OLVA-,oNI "'"C)_Alt:.
3. SU8SUIIf" AC( (;(0l0Q( PII()nl( IN 1(-': It: 0
."'OM 1(Sf "'fS AND IIOIIIHCS DlSCUSs(O.
.. 5(CTION S.O. 1f1(lIPtI(tAIION:S -O...A1(.
.. (11(11' NfO 0(''" rJ1 wA$1(S -O"..AI(.
KEY
o SO
~
,,()RIIONTAl SC4li ;" ;t.!.'
I . ~ A~ WAI(II !A8L[
m. .._~ NfO OMII INOU$IIIIAl "A$I(:;
D. $AHO AND CRAil(\. TO SIl TY SAND
(110.)(11 A I( TO HOt P[II..E A8!U TY)
~. $AHOy SIlT TO SIlTY ClAY
. (lOW TO II(IIY lOW P(IIw(A!llUTY)
(7J'J - SHALE (I[OAOCK)
c:z:J. (S 1IMA 1(0 (11(11' rJ1 0IICN8C
COIIT_"IIOII PlUM[
~. CROUIIOwA 1(11 n.OW Dlll[C1IOII
. . OO""wAIIO lEACHlNC rJ1 CGIIT_ANTS
" l1Iau w"5 T£5.
J '0
-~--~
..'{qnCAl SCALE IN ;([1
Figure
3
-
GENERALIZED HYDROGEOlOGIC CROSS-SEC11ON
PAINT SlUDGE WASTE SITE
SPIEGELBERG SITE. UViNGSTON COUNTY. MI
~
I
I
I
I
I
I
I
PSCW'
SOUM"5T
1000
'SO
i .
tOO
:'
. i
I
I
!~
800
!...oo
.00
-------
. --... _4.. .... -"'-'."" .~."'._----"""--""~-"--'---...._-_..".._- ---.---.". ~- -. -- . -.. .',. _. _.
.:..~--~ .-.-...----- ---......._--_.;_..--~.__....~.". '''--.''''-''.--.''-, _.~-.-_._.-
.~.. . .
. ~ -... - - -' .'.
"
.
'!be glacial ~fer used for water SUWly is presently ocntaminated by
the Spi~n,prg plume. CUJt.inJed migratioo of the plume poses a threat
to water eq:.ply wells north ard northwest of the site, althc:u#1 no wells
beyood the Spiagp1hE'rg prqerty are presently ocntaminatecl by the plume.
'!be actual or threatened release of hazardcus substances traD this site,
if rtt remedied by the selected alt.eJ:native,. may present an iDminent ani
su1:stantia1 el"dargennent to p..1blic health, welfare, or the envira1ment.
.
site Rl~
As ooted above, the ~i"l Investigatioo am Risk As.~c::mP11t Reports
detailed the site cnaracteristics and r:i.sks prior to the ~le unit I
so.lrOe ~i III] actioo CXI'ducted by Ford MJtor ~. SeIDe of the site-
specific details am ~g..c:l1Tr{1tioos used in the calcu1atioo of risk at that time
are rm cbaracteristic of the SpiegeTherg site in its current state. 'Ihe
foll~ diRl"!1SSioo of Spiegelberg site r:i.sks describes the qeneral oaA)qJLs
used in the pre-so..trOe control ~le \mit as..~, to det.eImine risk
posed and O1emicals of Q:n:)em, those aspects of risk calcu1atioo that are
still cq:plicable in the post.-sa..troe control ~le \mit scenario, am
details hew O1emicals of Q:n)ern were derived for the post.-scuroe oantrol
~le \mit grc:A.niwater oarxtitioos in order to protect p..1blic health am the
envira1ment.
Human Health Ri !::1(s
O::nta:rninant Identification
Table 1 is a SUDItIal'Y of cartaminants famd in grc:A.niwater beleN the
Spiegelberg site. 'Ihe table lists the maY)lTI1m ~tioos of each chemical
famd, and whether the CXI'1taminant was detenni.ned to be a 01em1.ca1 of ~
prior to the rE!IDCVa1. actioo, am after the rE!IDCVa1. for c1earup PJZpOSeS.
~ As.~c;rnent
'Ihe exposure as.~c::mI:OT'Jt portioo of the Risk As~~ identified the
potential exposure pathways am r&.qJLors. Identified pathways ani ~Lors
were used in OCI'1jurd:ioo with assI.DIpt:ioos of exposure frequency ani duration,
to m:rlel exposure point ~tioos.
A.
Pathwavs
'Ihree factors were used to identify exposure pathways:
.
OvD!ca1 sa.IJ:'Oe and release JDed1ani.sms to the envi.rcnDent.
'Ihe env~ 0. 8la::rrt:al transport medium for the reJ.~~ cbemi.ca1.
.
.
'the point of potential ~tor cart:act (exposure rart:e) with
cx::ntaminated --' i 1'1 .
DJrinq the prcductia1 of the Risk AsS'oo~, risk calcu1atiaw in:1\Dd
factors for transport of cbemicals fraD surt'aoe or 8ut6Urface waste ~its
to the CJl."CUndwater. Release JDed1ani.sms urder the pre-souroe Cu,l.ul q')er8ble
10
-------
.:.. ~-' --:.... ....~ :"':'-:~-'~--~'--_.'- - - ";-=.::::::"':::':~~.:.::..-._':":":..;; .:.--:._::. - ..... __r:... .. ~:__.:- "-=. .':_.':~.;- ':- '4:"':':"''::: _4.:". ,...' -"'-. .
'Dsble 1 - SpiegP1heTq Grwrdwater Pl\De O:ntaminants,
o...~lU.dlia1 Ran:;Jes and Q1AIIi~1R of a..."~~1
Maxim.Jm O'snical Q1AIIi t!al
Ct:I'amtratim of O:::noem of~
Gra.1rdwater 0:I1tami.nant u;./l Pre-rem::Mll Pcst~
aoet.a1e 690 *
2-hrt:anc:1'1e 550 * *
benzene 8 * *
toluene 120 * *
xylenes 56 * *
1, 1, l-trichloroethane 6 *
1, l-dichloroethane 170 *
4-methyl-2-pentarx:ne 140 *
ethylbenzene 16 *
vinyl chloride 120 * *
chlorcbenzene 26
. bis(2-ethylhexyl)Ii1thalate 120
di~-octyl Ii1thalate 10
di~-bltyl Ii1thalate 4
benzoic acid 140
dlloroethane 93
2-hexara1e Sl * *
~l 9
~;um 79
nickel 734
lead 1,870 * *
unit scenario incluied direct pertX)latim of liquid wastes an:3,Ior
solubilizatim of solid or semi~lidpaint wastes. '!he ocrJtaminants currently
fani in the grD..1l"dwater row represent the scuroe to the enviraDent and human
receptors, with the grD..1l"dwater be~ the transport medium for the released
cbemicals. ~c::ed m existirg hydrogeologic and cbemical analytical data, it is
liJcely that cx:ntaminated grD..1l"dwater cxW.d 0CI'11:irAJe to m::JIJe ~ with
the identified grourxlwater flCM di.rectim. In aMitim, the disc:x:nt.iru::
oa1finiIg layer ctserved at the Spiegelberg Site woold also allCM existirg
grD..1l"dwater a:rrtaminants to reach, and be transported thrcaJgh, the lower
aquifer .
'J11e scenario for point of potential re,oeptor CXI1tact with CCI'1taminated
grD..1l"dwater does not charge ~sed a1 rem:wal cxnsideratia1s. ~
receptors are likely to be expcsed to a:rrtaminants in grourxlwater via oormal
~c uses. With reference to risk, irgestim is the primary point of
potentiall-.qJlor CD1tact. Inhalatim of volatilized oc:ntaminants dur~
&hcweri.n; or bathin:J is a secx:n1ary exposure route. Dermal ~~a1 of
organic C" .'1 o.IJ'ds cxW.d also ooa1r, bIt studies have shewn this to be an
insignificant exposure route in oa1trast to irgestim or imalatim.
....
-------
~.:~~=..:..: ~oA'.".:~.:::---=r:---------:-~k'-":"~--':~--:,,-.:::=::.:.:: :-=-:..-~.. ._~.~ .
- . . ~"- ... -.--... '."--.. _. -'-.- --.',...--
._-~_.-.. _.......;.;.. ..- -'--- -.....-. '. '. -..' ~.. ..
,"
~
8.
Potentia11,y ~ la:W.atia1S
Far the puIpOSeS of the mcposure A~~~F:mI?1It, pecp1e \Iih) rt:N, "or at SCIDetime in
the future, reside em Spicer Read em the dcwn:;Jradient prq:ert:y boordiuy
(north) are ocnsidered patential receptors. Analysis of groun:!water 8aq)les
collected durirq the RI and in Jar'L1arY of 1990, irrlicate that the grourdwater
ocntaminatiem plume has not migrated beya1d the site boordiuy, an::! that
residential wells belc:n;in;J to potential receptors are unaffected by the
Spi~lberq graJrdwater ocntaminatiem plume.
c.
ExDosure Estimates am Asslmptia1S
As mted previously, p:>rticms of the ~, fi: am assunpticms used to calallate
~ point ~ticms for the pre-souroe caltro1 cp!l"ab1e unit
scenario at the Spi~J~J:g site are not characteristic of 0JrI'eJ1t site
cx:n:titicms. Other ~CU::IVTticms used are stardard to all risk analyses, or are
still characteristic of current site cx:n:titicms. 'lhi.s sectiem describes . .
~ls and ~~mpticms used, am inticates which are aw1icab1e to the pre-
am or post-souroe CXX1tro1 cp!l"ab1e unit scenario. For
-------
- ~--,-- .. " .-.
d" --:~.. .:.:.~---._-_.~...;...-.::.-=:"'.-::' -:.~ -_. - ..-:.-......_:''1. ..,. ~ "'- '..'...'":: .:':-.~-.:-:'..':. ..-"':. :.: '..
b.
D;B
[b;e is used in the mdelin3 of risk and is defined as the amamt of a
Oo.'I>OUrd, in milligrams (JIg), absomed daily, by a reoeptor, per kilogram ()cg)
of body weight. Doses can be calculated for a lifetime (for carcirlogenic
effects) or for ooe-t:.ime aoJte exposures (for ncn::arcirlogenic effects) .
'Ihe factors '-Ihich influenced in;Jestioo dose are 0CIltaminant 00I1CEa aLLatia1,
c:xrJtact rate, the fractioo of 0CIltaminant absoIDed, am body weight. 'Ihe
in;Jestiat rate used for this site was based 00 the starrlards of 2 liters/day
far a 7o-)cg adult reoeptor am the absorptioo fractioo was 100 percent (1.0)
far all gro.D'dwater CXI'1taminants.
IMalatioo dose ocnsiders the follCMin;J factors: volatile generatioo rate,
inhalatioo rate, body weight, air exd1arge rate, shower duratioo, am total
duratioo in bathroan. '1he inhalatioo rate used was iO Ii te.rs,lmin, for a 7o-)cg
k~, am the air exd1arge rate was 8.3E~3 min-. '!he shower duratioo
am total exposure duratia1 were set at 15 minutes and 20 mi.rutes,
respectively. .
With the exceptioo of 0CIltaminant ~tian, the assurrpticns used in the
dose ca.lculatims are starrlard am awlicable to post-swrce ca1trol ~le
unit site cxn:li tims.
c.
~ Scenarios
Both ma.xim.Im an:i arithmetic average su1:surfaoe soil CXRJentratia1S were used
to generate worst~ and plausible case exposure scenarios, respectively.
In additioo, the actual maxim.Jm and actual average gro.D'dwater ~tiCl1S
within the plume were also used in the same exposure scenarios. '1he estimates
made in this sectioo are the best representatioo of the site oc:n:titia1S at the
time of the ~;~1 Investigatioo.
Toxicity Assessment
A.
Cancer Pctency Factors
Cancer potency factors (CPFs) have been developed by EPA' S carcln::qenic .
Ass~~ Group, for estimatin;J exoess lifetime cancer risks associated with
exposure to pat.entially carcinc:genic ctsni.cals. Cancer potency factors are
derived fran the results of human epidemi.olO;Jica1 stJ.xlies or c:brcnic animal
bioassays, to Wich animal-to-human extrapolatioo am ~ factors have
been awlied. a'Fs are expressed in units of (ug,lkg-day) . '!be CPFs for the
two carcinc:genic O1em.icals of Ccnoem in the SpifI9Pl'-rg grcurdwater plume are
listed belo.' in Table 2, am are taken fran Table 3-3 (~ 3-U to 3-15) of
the Risk Asses~~.
13
-------
-
-,
.. . . ,C' .~.L - ....
..;;...:-~---
- . ...-..
":-.-: ':':--_- - .;. :;::.-:::--:r-;:...-..~;~ . :;".-. ,.o.t".'"' -~, ....~) - .
Table 2 - Cancer ~ Factars far Spi~'berg
GraJrdwater Carc.i.tDgenic n-ni t'A 1 R of
a... ~~I
Carcinogenic ~ Factors
(Dg,I)cg,Iday)
Chemical Oral Inhalatia'1
benzene 2.9xl0-2 2.9xl0-2
vinyl d110ride 2.30 2.95XlO-l
Q"Fs are DL1l tiplied by the estimated i.nta.ke of a potential carciJ'Xlge:n, in
Dg/kg-day, to provide an upper-I::o.m:i estimate of the excess lifetime canoe.r
risk ~c:.c:oc-iated with ~ at that i.nta.ke level. 'Ihe tenn ~ bamd"
reflects the
-------
._#--'-:::--:=' '~-'''-~'::;';-'':-.~'':::'-~-'''-''------8'M.~---:-----'-- -
._..-._. --.----.-.....-- ':..f"-.,
Table 3 - Refw.t:iI LJt: Doses far Spi agp' het9
GraJrd.Jater ~
n-it"!A1R of o...~HI
Reference Doses
(Dg/Jcg-day)
O1emical oral Inhalatia1
aoeta1e 0.1
24:ut.anc11e 0.05
ethylbenzene 0.1
toluene 0.3 1.5
r:jlenes 2.0 0.44
1,1,1-trid1l0r0ethane 0.09 3.1
1,1-did1l0r0ethane 0.12 0.138
2-hexana1e N/A N/A
4-methy1-2-pentancne 0.05 * N/A
lead 0.0004 N/A
N/A .. RfD not 8R'licable for this d1emical
* .. MI:NR qenerated RfD
R; ~1c Q}aracterizatioo
'Ihe followin;J sectia1 describes the process used in the site(s) RiSk
Assessment to est..iJDate the potential in::idenoe of adverse health ar
envi.ra1menta1 effects urr3er the exposure scenarios defined in the abaYe
sectia1.
A.
Urw=ertaintv in Risk Ass~sment
Carcinogenic arrl nc:n:::arcinogenic health risks are estimated usin; a ra~'" of
different Ac:c:I1''t-wtias. 'Ihe extent to Widl health risks can be characterized
is primarily deperrlent upcI'1 the acx:unt.cy with 1IIhidl a chemical's taxicity can
be estimated arrl the acx:uracy of the exposure estimates. '1he taxioological
data that farm the basis far all risk assessments CXI1tain uooerta:inty in the
followin;J areas:
*
'Ihe extrapolatioo of ncn-threshold (carcinogenic) effects fraD the
high doses administered to laboratory aJ"I;~ 1 R to the low n-es
received \.1l'der 1Ime O.,.,o.W1 exposure scenarios.
*
'1he extrapolatia1 of the results of laboratory animal sb.I:lies to
human ar envi.ra1menta1 receptors. .
'1he inter-species variatia1 in taxioological . dpoints used in
ct1aracteri.z~ potential health effects resultinJ traD exposure to a
cbemical.
*
..~
-------
-_~_.i
- .- ,-
.- _.. --_. --~~~-""":".
. '.'~.;.-u:.-====---:=-"':"-'':''-_:'::':''.-:-'''-.'--:':::':':-.:::'''_..;.._-;.:~.._- - _&-'1.'''''''..-::~ ;::.-:"-.-':.._-~"; ~.'.' ~_._- ~-
4
.
'Jhe variaticna in sensitivity uaq individn"1A of any ~ies.
Exposure estimates presented are also based a1 a r-,JI'I'Ih:.,r of siDplityin;
~1rI{1tia1S, including the followin;1:
.
A cx.ntaminant is lead1ed fran soil and waste materials aooordin;J to
the relatia1Ship between its envi.rc:nIenta1 ca'::':'lu~Cltia1 and its
solubility, as defined l7:i the Organic I..eachin:;J Model.
SOlubilized 0CI'1taminants are transported alag with the normal
gro.miwater flew. '!bey read1 a reoeptor at any defined c:li.stanoe
fran the sa.trOe at a canoentratia1 prcp:ntimal to the source
canoentratia1, as defined l7:i the VMS Model.
*
*
Rlysical and chemical characteristics of site soils and gro.miwater
such as: nrtardatia1, solubilities, partiticnirg coefficients, and
oolloidal effects are not cxnd,den!d.
~r characteristics, such as age, body weight, and eJq>OSUre
duratioo are based 00 p.1blished values, with sane atteupt at mak.in:J
them more site specific.
'!he chemical analytical data base is limited l7:i semple locatioos and semple
frequeJ'x::y. Every effort is made to oollect sanples that reflect actual site
cx:n:litioos, hIt not every portioo of the site can be scmpled.
*
'!he follawin;J brief sectioos a1 carcin:qenic and ncn:arcin:qenic risk are
prcwided as a descriptia1 of haw risk is characterized, and the Spi~'h8:0rg
pre-souroe cx:ntrol ~le \mit Risk Assessment raJl'l'lh:..xs are used as exmrples.
It should be mted that the receptor canoentratioos used in these .c.~oc~TJts
are based a1 the leac::.hin3 of chemicals fran the waste no l~ p1:: lSent
oosite. 'D1i.s pre-souroe cx:ntrol operable unit characterizatioo of risk was
the basis for theselect.ioo of the 12 Pre-rerDaYal Chemicals of 0::nce1:n listed
in Table 1.
B. Carcin:qenic Risks far Potential Hoosehold Use of ~b~r
Carcin:qenic risks can be estimated by caIi:>i.nirg infcmnatioo in the dose-
respa~ ~~g"""~'1t (carcin:qenic pJtency factors) with an estimate of the
irxtividual intakes (dooes) of a cx.ntaminant by a ~t.ar. '1he resultin;
J"I~.r (risk) is an I!Xpre6Sioo of an intividual'8 likelihood of develc:pinJ
am;:,er as a result of E'>CpOSUI'e to the carcin:qenic indicator chemicals. '!his
likelihood is in additioo to the risks inaJrred by 8Yel)'dayactivities. For
~le, a risk of 1E-06 or a 1 in 1,000,000 c:hanoe, is 8R>lied to a given
pq:ulaticm, to detemine the nmber of ~C! cases of can::2r that CX11ld be
expected to result fran exposure. '!he figure of 1E-06 is "me acktitimal case
of ~ in 1,000,000 exposed per&a'1S.
"JI'ar pnposes of this Risk As~~, the Agencies cxnsidered a bypathetical
IIhallew ~fer residential well, installed at the spicer ibid prcprty
boundary. '!he JIICM!!IDent of c:x:ntaminaticm with the graJl'dwater ... ww.' ed
under several scenarios. '!he fa.1r scenarios P&- s~rt:.ed in the Risk 1tsB ~
inc:l\ded usin;J bath the 1IPIY';'Ium and arithmetic average an~ace 80il BO.JrOe
cx:n:JerJtraticn;, eacb with 1 meter and 10 meter values of t:rarwYerse
16
-------
':-:";";:";""""':"I:ftIG>~..,~:~ .-'-..,....~ .-..... ..-..
~~-_.._~. "" ~~..
. ~ --.' ". . ..'. -_. ". . --
.. -..J'. ~- n.. - -. - .. ..
dic:;pPT'Sivity (latera1l1KJVement) in order to present a rarqe of potential risk.
'!he total predicted carcirogeni.c risks (in=ludes both an ~oo am
imalatia1 (;0 "'I ncentrations (in Table 1) fo.md in the Spiegelberg grourdwater are:
benzene, maximJm oorcentration = 8.0 Ri>, risk = 6.7E-Q6i W, vinyl d1loride,
maxim.Im cx.n::entration = 120 Ri=>, risk = 6.0E-03.
c.
Noncarcinogenic Risks for Potential Hoosehold Use of GrcJun:)water
iUtential health risks resultin; fran e>cpoSUre to nooc.arcincgenic ~
are estimated by cx::rtpari.n:J a rraxilm.Irn daily dose to the Ref~ n::se. (RfD) .
'!he RiD is the level of a daily e>cpoSUre to the human IXPliation that is likely
to be wi thoot appreciable risk or deletoric:us effects. If the ratio of the
maxim.nn daily dose to the RID, ~ as the Hazard Wex, exoee(!c; a1e, there is
a potential health risk associated with e>cpoSUre to that particular d1emical.
'!he Hazard Irrlex is not a mathematical predictioo of the severity of toxic
effects, b.It siIrply a l'1UII'erical indicator of the transition fran aCXEptable to
unaCXEptable levels. A total Hazard Ir'rlex for arrj exposure route is calculated
by S:lJmn1n; the Hazard Irrli.ces for the individual chemicals of oonoem. Hazard
Irdices were determined for the exist.in; Spiegeli::)erg grourdwater plume as ooted
in Table 5. Table 5 was derived fran Table 3-11 (page 3-52) of the Risk
~c:mPJ'1t.
As noted in Table 5, three of the Hazard Irrli.ces exceed a1e. '!his is an
Wicatia1 that the potential for human cxnsunption of ca1taminated
grcurdwater which poses a health risk exists, if the plume read1es the site
ba.1rmIy. A SL1I11rIaI'Y table is in::l\.Ded in the Risk Ass€'s-~.TJt Report, which
shows OCI1tami.nant-specific Hazard Indices for each exposure scenario.
17
-------
- ~...~:::..:.:..:....: .:-=:::.::-::-:.~"~--==,,:'-":'==:"::::::::::=:';":,:,::,:~ ~._- '---"~_.. ...- -. .
- ~_.- . -...-
~" . -
- - .. .'.
, .,'._.,-.
. ..~, - ... .
. "n. ..
Table 5 - Nc::.rrarcirx:q Risk far Spi~'h(:-rg
GraJrdwater 0:I1taminati.a1RJt.enti.al tJEJe
MaxiJIum Average
Scuroe ~tia'1 Scuroe ~tia'1
a.rc1m a.r-1Om a.r-1m iSrr=lOm
10.4 1.98 3.56 0.68
a.r-transverse di ~rsivity
Envira1rnent-.A 1 pi sk
'Jbe grourdwater is a resource to be evaluated as are all ather envirc:nDenta1
cxmpart:ments arr::l life forms. Based a'1 the firx:iin3s of the pPnw:rlbl
Investigatia'1S, a portia'1 of the oo-site grourdwater at the SpiEWJP~rg site
has been degraded, arr::l poses the potential for degrad.inJ DDre of the
~ent resource, if not remediated. 'Jbe pteventia'1 of further
degradatia'1 of the presently CXI"ltaminated grourdwater resouroe is a ~ i ~]
oojective that has been acxxmplished at the SpiEWJP 1 hPrg site. 'Jbe source of
CXXltaminatia'1 above the grourdwater is no lm:;Jer present, arD the level of
grourdwater CXXltaminatioo currently present, will not in=rease as a result of
past waste di ~ practices. '!be existirq grourdwat.er oa1taminatia'1 will
-------
-~..:.:.::.:'.:...._..t.:.."":'\.':"~':".'.. .,.'-~-'.-:-~~
.. _.. --- .-. .- .- .-.-...-.... ..----
Q1e threatened species, the Eastern Sand Du1:.er CAn1nocrvPta pellucida) (a
1I'~,~er of the perch family), and a1e special ~ species, the ~
Had
-------
.-::--.;;.. ::..-....- "
.. .
~-=':;;;'N~.....o...-...-'.-
. '-,,;.,'~'.,""""-:".... ,,"":111::""~'-"".
......_-*-- . ..' p. .
wu.euUy remains m site am is EDCpE!Cted to CXX'ItinJe to migrate towards
downgradient wells, there17:i creat.in; potential exposure routes for human
receptors.
Actual or threatened releases of hazarcbJs subst:.arr:es fraD the Spi~' ne.rg
aite, if not aQ1ressed by iDpl~ the respcnse actioo selected in this
RX>, -y present an imninent am substantial ~ to p.1blic health,
welfare, or the envircraDent.
Deec:ript:im of Altemat.i.ves
'Ihe two site-wide ~iA} alt.en1atives described below, were evaluated in
detail in the Feasibility Stu:iy as Alt.en1atives 8, '!he No Actim Alt.en1ative,
ard 9, A Treatment Alternative. Alternatives 1 t.hrcu;h 7 in the Feasibility
Study are pertinent to the ~~)~c;en site's soil and graD'dwater areas of
c:x::ncern, ard are therefore not aQ1ressed in this Ja).
'!he site-wide alternatives oonsidered for addressin:;J the risks posed by the
Spiagp'hPrg graD'dwater OCI1taminatioo plume iIX::lude the No Act.ia'1 Alternative,
as required by the NCP, ard a treatment al teJ:native cxnsi..st.ing of: extraction
ard a inatim of treatment processes with d.i.sd1arqe back to the
gramdwater via injectia'1 wells.
'!he No k:tion Alternative
Under this scenario, no further remedial ~""C::::lJres would be i.Dplemented at the
site. 0Jrrent graD'dwater CXI'1tamina.tion would not be aQ1ressed, the
cxrrtaminants would potenti.ally migrate off-site, and p:se an ~ to
plblic health am the envira1ment.
GraJrrlwater Extraction. Treatment am Discharoe
1.
:I1rI:>lerentation
I:q>lementatia'1 of this alteJ:native involves the follc::win:J:
*
extractia'1 of CXI'1tami.nated gramdwater usin:;J rect::Nerj wells;
rem:wal of inorganic cxrrtaminants by chemical precipitatia'1 followed
by pi adj\.m;~rt:; .
*
*
reIII:MU of the b1lk of the organic cxrrtaminants, inc1ud:in:J Jcet.cnes,
by a bioloqical treatment system;
further rem:wal of residual organic CXI1taminants via air str!R>1n;;
d.i.sd1arqe of effluent, treated to meet the clean;:> levels specified
in Table 6, via injectia'1 wells, am
*
*
*
deed restrictia'1S an:3;or ather institutiaal '-It.u1s, as neoe5-x\ry,
to insure the integrity of the l~.
20
-------
.-- ...--- ,--~_...... .
-'. --.':.."':'-~7~;""~..::.;r1iiio7- --- ~~::;;":,:.~.:-:.... "-.-
----..- --.--.- -...... ~..~...
In order to meet state gI"CU"1dwater disc.harge requ.irements, the reinjected water
fraD the treatment system will rot 0CI1tain oont.aminant levels in ~9 of the
levels specified in Table 6, and the system will be designed as a "closed lcq>"
80 that reinjected or CCI'1taminated gI"CU"1dwater will rm. migrate off-site.
Treatment system slu:ges generated 00 site will be tested to verity their
characteristic nature and prcprl.ies in order to ascertain ~ or rot they
are subject to the RCW\ SUbtitle C requirements, in::ludirq the Lard D~l
Restrictioos (ILRs). 'Ihose which are rot subject to the R::AA recpi.rements,
will be d;~ of m-site. 'Ihose which are iIrpacted, will be treated to
insure cx:mpliaooe with 1m treatment starrlards, prior to d;~. '!he
activated caJ:ban,lcharcoal will be treated off site in a permitted facility. A
m:nitorirg system designed to verify capture of the oont.aminant plume will be
bplemented, ard will include uaritorirg of residential wells in the area.
2.
~
'!he estiJrated oost of bplementation of the U!(edy determined durin:J the
Feasibility sm:!y (1987-1988) was $4.42 million, CCIIprised of a capital oost
of $2.42 millioo an::! a present worth ~tion arrl mai.rrt:.enaro! oost of $2.0
millioo. '!he oostin;J for this Alternative in the Feasibility sm:!y incl\Ded
the same process cptioos listed above with the exoeptioo of the re-injectioo
wells. '!be Alternative was oost.ed with a seepage basin system for the re-
:intrc:ductioo of treated waters to the gI"CAII'rl. '!he seepage basins were
originally inclu::led prior to the raraval acticns, as a neoE?5-'*'IY ~oo for
the eJ1harx::ement of CXI1tam:inant DOVernent through the unsaturated zooe. Sin:Je
contaminants in the msaturate::l zone were renoved, seepage basins are not
required to enhance cxrrt:aminant movement. Cost savin3s will be :inc11rred with
the use of re-injectioo wells CNer seepage basins. Based 00 calculaticns
presented by Ford )otJtor 0:IIpany, seepage basins wa.1ld oost $224,455, to
cxnstroct, while reinjection \/ells wa.1ld oost $55,675 to caJ::ttLuct. .
3.
TiJre to InPlerent
For the puposes of oost evaluation, the remedial actioo was estimated to take
5 years to iJrplement, alt:hcn:t1 the actual duratiCl'1 of cleanup will depen:i 00
the rate of extractiCl'1 am the acb.1al time it takes to readl the cleanup
levels specified in Table 6.
4.
Spec! fied Cleanuc Levels
'!he SpiEqe1berg grourdwater cleanup levels to be adlieved by the
iJIplementatioo of the treatment al ternati ve are listed in Table 6.
'Ihe lE-06 carcimgeni.c level for vinyl chloride is 0.015 RiJ. HcM!Yer, the
clearLJP level for this \> .'\ ani is 0.5 RiJ, the Methcd Detectioo Lbni t (MDL)
for Methcd 524.2 GCMS (as required by 40 em Sectioo l41.24 (g)(l1)(i)(C» ,
..iro! this is \/hat can be reliably measured. 'Ihe risk 8Sc;;oci.ated with the 0.5
RD clearLJP level far vinyl chloride is 2. 5E-05. -
21
-------
.,-::w-::~:W_.- .-:-=~-:::::"".~ - '._-::":'-~"~"=--~=--::+.:'"~~:.':-'_------~-_:. :--...
.-.---..--.- ..-.
~-- .0- - ... ...... - ... ..
.........-....: - _. .0
.00'- .. .
. .
'!be 1E-06 carcinogenic risk leve1t.for benzene is 1.2 Ai:>, and is euplayed here
as the clearJJP level for this oarpound. 'Ihe total carcinogenic risk
"!I:.~iated with the clean.Jp levels for the two carcinogenic cbemicals of
CXI1OelT1 is 2. 6E~5, as ~red to the carciIo:Jenic risk of exi.stin; levels of
oc:ntaminatia1 of 6. 0E~3.
'!be HLSC CXI~ was explained earlier in this Ja). Toluene and xylenes
clearJJP levels have been set at the taste and odor thresholds in order to
protect the usefulness of the gI'CIl1rdwater for water SURUY pnposes, s,in:,e
these levels are l~ than the calculated HI.SCs for these 0.'1 amds.
'!be }qercies require that lead be cleaned up to the 5.0 Ai:> awrcod.mate HLSC.
Alternately, design sttrlies may be cxn.:b::t:ed to determine the "bacJcgra.n:l"
levels in filtered gI'CIl1rdwater sanples, and an average bacJcgra.n:l
~tia1 will be used as a lead clea.nJP level for Spi"JPlberg
gI'CIl1rdwater. BacJcgra.n:l will be detezmined fraD the followin;J fOJr exi.sti.rq
wells: S~14, SP-+Itl-24, SP-MW-30, and ~ 40.
'!be total risk associated with five ncn-carcinogenic 0I:Itpa.1Tr::ls is not
sarething that can be cx:arpared to that for the two carcinogenic ~.'iamds.
'1berefore, an overall total .risk fran all of the cbemicals of ~ is
incalculable. However, the five ncn-carcinogenic cbemicals of CXI1OelT1 each
irdividually exoeed their oon-espondin;J clearup level-a level detezmined to
be protective of twman health a:rrl the envi1.\08~It.. .
'!his actia1 is e>:rg Grourdwater
~.. i;!l' Act.i.cn
Cleanup level
Q}emical (Ri:» Basis
benzene 1.2 1xl0 -06 Carcinogenic Risk
vinyl ctUoride 0.5 Analytical Detectia1 Limit
2-b1tarr.ne 350.0 HLSC
2-hexarrne 50.0 HLSC
toluene 40.0 Taste and Odor 'lhreshold
xylenes 20.0 Taste an:! QX)r '1hreshold
lead 5.0 Apprax. HI.SC (Backgrcun:i)
911mRty of thrpmItiw Analysis of the Selected Al~
'!be follc:::JWirg nine criteria were used to ~re the alternatives and to
select the la.&.edy for the site. '!he paragrcq::h(s) followi.n:.:J each criteria
detail haw the two alternatives meet (ar fail to meet), each criteria1.
1.
Overall ~-+itWl of B.1IIan Health IUd the Erwira'aent 8&h es- 1It~tl.:L
or JX:Jt 8 k--=dy provides ~ prctecti.a1 IUd desc:ribs tDi risJcs are
e1.brl.nated, r-JII~ or c.-I~ulled tbra.91 t:reat:Di!nt, ~ '-AAaL.u1s
or iJ&t:.it:ut:ia1a1 ~iL.uUS.
~7
-------
. -"1 -
--,-,:-----'---- ..
. .
. . ;- ~.-"~"~..-..._--_:~ '-:'':'''''':'':''-~~._-~':::'' ..:'3 ~\"wJo._t~''''-'''-',,,,,,,-,,,,,,__._.I' . . ~
. .
1JIp1ementatioo of the selected treabDent alternative, will adequately reduce
the present and potential future exp:sure risks at the site, by I"E!IDCWin:3'
CX81taminants to the clean-up levels identified in this ~VI'Pnt. Carcinogenic
risk ~~iated with the SpietJP'~rg site's grcurdwater is a.n.L_tlly
6.OE-03. '!he inplementatioo of the grcurdwater treat:Irent system and the
at:tainDent of the recpired clearJ.JP levels would reduce the carcincgenic risk
to 2.6E-05. At:tainDent of the clearop levels assures pratect.ia1 of tuman
health and the erwilament. '!he grourdwater resc:uroe will be restored to a
usable cxntitia1, and the envi..rarmmt will be protected fran further
~ca1atia1. .
'!he No Actioo Alternative, does rot meet the protectiveness criterioo as it
does rot provide pratectioo fran the exi.st.in;J risks posed by the site, and
cxuld 1n::rease the potential for f'ut:ure risJcs.
2.
Q:IIpli.aJ'a! with ARARs cd.h-e:sses hew the PL' pJSed alternative 1T'8'1{11 i ~
with the pertinent Federal and State regulaticns. 'Ibis critericn a1so
cx:n;iders hew an alteI:native a:m:p1i.es with advisories or \Al~ guidance
that do mt have the status of laws, bIt that the m EPA am the State
have ~d!d to fo1.law.
'!he selected alternative will attain AR1\Rs specific to.:in:lividual 00 JI'I a~ it
actias (i. e., d1emical precipi tatioo, biological treat:Irent, grcurdwater
di.sc:harge, etc.). A surrmary of identified AR1\Rs is presented in Table 7. All
potential AR1\Rs are inchrled in the Table, vuc:b :in:licates vuc:b AR1\Rs are rDII
Afplicable or Relevant am Afprq>riate. Note the key followin:J the tables an:}
the (l!ic:c:tY"iat.ed irrlicatioo of whether the ARAR is c:hem.ica1-specific (C),
locatiar-specific (L), and/or actiar-specific (A). As di~~~ in detail
further a1 in this RD, the selected U:lledy will attain all identified ARARs.
'!he Kic:bigan Department of Natural Rescuroes has recently prcm..1l.gated
administrative IUles cpverniIg "Enviralnental Respa ~ Activity" pm;uant to
the Kic:bigan Enviralnental Respa~ Act, 1982 PA 307, M.C.I.. 299.605 ("Act 307
Rules") . 'Ihese Act 307 Rules, to be oodified at M.A.C. Rule 299.5101 n Bg,
have been formally adcpted by the Kic:bigan Natural Rescuroes ()-'mni ~c:ioo am
awroved by the Joint o::mnitt.ee 00 Administrative ~es of the Kic:bigan
Legislature. '!hey will be in full le;al effect a1 or about JUly 10, 1990,
fifteen days after they are filed with the Kic:bigan Secret.ary of State, in
accordance with the Mic:bigan Administrative Procedures Act.
'!he Act 307 Rules cx:.ntain provisias establ~ procedures for respcnse
activities (M.A.C Rules 299.5501-5519), selectioo of remedial act:.ioo (M.A.C.
Rlles 299.5601-56(7), am clearaJp criteria (M.A.C. ~es 299.5701-5727) at
sites of enviraDental cxm.aminatioo ..mere respcnse activities are taken
pn-suant to Act 307 an:1 are AR1\Rs fer this ~i'" actia1. 'Ihese Rlles
ca'1tain recpirements that are awlicable to ~i,,' act:.ia1 at the SpietJP'~T'9
site since this Ja) is deYelcpd anticipatin1 the possible. expe.rdit:ure of both
State am Federal turds, am State matd1 wa.1ld be provided pm;uant to Act
307. If not legallyawlicable, then recpirements of the ~ 307 J:Ules are
relevant am aw.[\~iate silo! c:xrttaminant levels o.JITently faJn:1 in site
~ter ~ levels set by awlicatia1 of the clearup criteria.
23
-------
-;~"":"'"~.........:"" -~- - ..---'- 1
.u --- -.-.- .._, . - .
~
. . .
T~ 7 . 1IWU SImncn for No Action CIId Selected RIIT*IaI Alternative for $pieoelbtrg GrcundwGt. P!Ime
I NO ACT10N ALTERNATM SELECTm ALTERNATM
FIDERAI. MAAt
RESOURC£ CONSt:JNA'IION NlD REaMRY N:T (A CIId C)
laM «I CJJI 218 Not iii NW. 4OCf'R 288 SubtitJe C
t8Id ... rwtI;a;..18 ~ iI applicable lira
. . dIImicaI IIudga will II8Id to be
TaP tilted for proper cf'Ispoa.
RCRA 40 CJJI 2&.4 Not iii NW. 40 en 2&.4.94; 2&.4.100
SttNardI for 0WIW1 CIIC! The8e r8ePr1lTlllrtl en not app/ic:obII Iince
opntor1 of hazCI'dou8 waste 9"OIhi\:~ i8 ~..; r.~natlcl with RCRA halcrdcIUI waste.
~ ... CIIC! ~:"'f' :1. ~:..."'\ CIId appropriate lira they
-- foclties I'89UIotI .:ri'iJ/ 'I~~' 'I"~~ 1imiI« to thole at the lite
4OCf'R 2&.4.301; 264.303-304; 2&4.310;
40 CJJI 2&.4.81-100; 2&.4."1;264.,,.,17
RCRA halcrdaul walla (c:hemic:aI precipftation 1WJe)
wcUd be pIOC8d ~ 0 landfill. CIIC! CCI'Ind with 0 cop.
Thftforl. ttIIIe ~rement.e en oppIicobIe
40 CJJI 264.271; 2&.4.273; 264.278
These ~ en not applicable Iince ~
hazard0u8 wCllta (bio treatment 8Iudge) woUd be IchI
treated. R~ en rlltvt61t CIIC! appropriate Ilia they
~ot. cira.nwtancet tUff'1CientJy acr to thole at h lite.
RCRA 40 CfR 263 Not on NW. 40 CfR 263
StoncIard8 opp&catIIe to TrrrwporW I'8qUirImenta en app&cabIt for 01
trV1IpOItn of halcrdcIUI WCIIte off-. Ihipmtnta of hal«doul ...
(dlemicol JlrICipita!ion 1Iudge)
RCRA 40 CfR 262 Not on NW. 40 CfR 262
StoncIard8 ~ to Ho:z«doul .aIIa venerator ~ 8CdcI be
veneraton of hczZ'ardcIUI WGIte ~ for 01 hal«doul 80ItII
InNpoW off-titt (dlemicol 1WJe).
aIAH WATER N:T (A)
CIA 40 CfR 122 Not on IifM 40 CFR Part 122 (1ICIpt 122.21; 122.44(1); 122. 48)
Rtp6n cnmg prvriIiDnI ~ 18 not CIIIPficabIe IiIC8 Ift'w1t
for h tfIDES provarn. fnwn h hatmInt I)'It8m would be ~ to pn!
. fnwn 0 - IIU'CL
- . '
CIA 40 CJJI 125 Not on MM 40 CFR flirt 125 . w.pc.t A
n.. ~ I8ttIbI8h h ~ i8 not ~ Iince tftWIt
crtn .., .... fnwn the trIatm8rt IyIt.n .edIt II! ~
.. I!I 81m provarn. ~ fWId fnwn . poi'It IOII'CL
ToIIIt 7 c:anIIrud on !lilt IIOOt
-------
- . - ~ ...--.' ..---_..
-.-.-.- .._.-----_.--'::'~':."'''''''~-''-'-';'--------.'''---- '- ...
.. .-.-'':.-.. .-" .~....... - .. .. .... ..'-
. .
Table 7 . Pave Two
NO ACTION Al~TM SIlECTED Al~lM
f1mW. WAa . CWH lATER N:T CCHTNJED (A)
CIA 40 en! 403 Hat 11\ NWI. 40 en! ~ 40J
~ 403 conlaN 9I"R R.ernent . not appficabIe"
~I,.=- for .mu.rt tram the tr8GIImInt
11ft IOIrC8I !1f pollution. .,.tIm !lOUd not be ~
m.o a PaTI. ~ ill
reImrIt ftj appropriat8 ..
. f8CJJ1C1t88 ~
8Iff"1Ci8ntJy Iini« to
,... at 1tIe 1iIa.
Q£AN III. N:T (A) -..
CM40en!5O Hot 11\ NWI. 40 en! 50.1-50.12 I
RecJiationl 8IId>IiIh tile R.1I!'tII'ItI en ~"''';~. '
Nationci Pr'm~ IIId tmiaiOlll tram the hot:.. :
Seconda'y ~ Nr .,.tIm !lOUd be ujlct to I
~rIy ~ for PmI«y IIId S8concIc.y Irnbi8nt A;
CITIIIII9 CItI-« 1IWI;a. ~ SIaIdnL ConItNctian actMti88
rnatI8r !lOUd be ujlct 10 .. '19' ItcnIcrd.
OCCUPATIONAL. SAmY.M) I£AlTIi (A)
OSHA 2V en! 1910 Not. 11\ NWI. 2V en! 11110.120
~oncilGfltyllld ~.~..
hedttI Mldlrds adcIpt8d ~ opntianIlOUId tab pIooI
to ~de 1IIf. or at a hazcrdau8 willie II. ~
hecithhi empkrJment. for dInID.
OSHA 29 en! 1926 Not 11\ NWI. 29 en! 11126
Al9JIitiona III forth the RtcP"1ITIIIII . ~
1IIf8ly IIId hedth MIc!crda for III CIIHft8 canIIr\Ic:Iion
for c:cntruc:tion actMtiea. FIiat8d actMIia.
DEPNmIOO ~ 1RAHSPOR'TA'OON (A)
DOT 49 en! 107 NIIt 11\ NWI. 48 en! 107
Pre.:rUe 1tIe ~ ~iI~"
utilZtd by .. YattriaI. hazRiul IICIIt8 (dwNcd
TF'CI'IIpQ1GIian IUIcaI. CHI! prqitGIian aIdgI) -*I be
IIId OOE for ~ !1f IrIIIIportId III 11\ oft....
haznu mUicia. -- tacIfty.
DOT 48 en! 171 Not 11\ NW. 48 en! 171
~ venn ~.~1Ira
~ CIId dIWiorII haznaut 8I11III (dwNcd pI~,
~ .. trnportatian aIdgI) -*I be 1nI'~ to
fItf IIcmrdauI matnis. 11\ oft.... ... 1oc:8Iv.
wr DRIICING 1A'ItR N:T (C)
SDIM 40 en! 141 40 en P8t 141 40 en P8t 141
~Io~ ~lIInot~ ~lIInot'"
IunCII hdh tram ~ .. .. .... ... lira .. ..... .. -
..~ .. ... III not I8ICI to h ... III not -.t 10
f:IIabItt8 IKtI .. 0 CIOImUIIy « .. 0 CIOImUIIy «
CIId MCU8L r8\-~I.'.ritt ... "*"" l8\-,*i"~"'" ~
~ ill I'IiII'CIIt ~ ill...
CIId ~ lira CIId 4PI-"t"" lira
I ,.pill cnuwnc. I...~
IIIfIIci8ntIy ... 10 ~... to
'... at .. ... -- at .. ..
T.. 7 canIiUIcI III !lilt ....
-------
. .,,.~ ,. -
... - --... .. - . - .: -.. ..
.. .. -.-' -".
. - -- -. ...., ....,
,. . .
. .
Table 7 - Page Three
NO ACTION ALTERNATIVE SELECTED ALTERNATIVE
STATE ARARs
HAZARDOUS WASTE UANAGEMENT ACT (A)
HWMA - ACT 64 Not on ARM? MAC R299.9612
Regulations Requirements are not applicable
containing since groundwater is not
standards for contaminated with HWA waste.
generators and Requirements are relevant
transporters of and appropriate since
haz. waste, they regulate circumstances i
and owners sufficiently similar to
of TSDF s. those at the site.
UAC R299.9602-9604;
R299.9611-9613;R299.9619-9622
Requirements are applicable because
HWMA waste (chemical precipitation
sludge) would be placed in a
capped landfill.
MAC R299.9301-R299.9311
Hazardous waste generator
requirements would be applicable
for all wastes transported
. off-site (chemical precip. sludge).
MAC R299.9404-R299.9412
Transporter requirements are
appfJcable for all wastes
transported off-site
. (chemical precip. sludge).
MAC R299.961S
Requirements are not applicable
since non-HWMA wastes
(bio treatment sludge) would be
land treated. Requirements
are relevant and appropriate
since they regulate circumstances
sufficiently similar to
those at the site
Table 7 continued on next page
-~.. ...-. . .. - .
-------
---.0.-_- ..-- .' - ..... --'
. - ,. -'.' -. .... - .'-
"
f
Table 7 - Page Four
NO ACTION AlTERNATIVE SELECTED AlTERNATIVE
STATE ARARS CONTINUED
AIR POllUTlON ACT (A)
M'A - ACT 348 Not an ARAR UAC R336.1702;R336.190 1;
R336.1371-1373
Rules containing Requirements are applicable
emissions limitations since emissions from the
and prohibitions treatment system would
for particulate be subject to State standards
matter, fugitive for VOCs. Construction activities or:: ,
dust, and VOCs. potential sources of fugitive dust. ,
SOIL EROSION SEDIMENTATION CONffiOL ACT (A)
SESCA - ACT 347 Not an ARAR UAC R323.1701-R323.1714
I
Regulations prescribing Requirements are appficable
the requirements since construction would involve
for soil erosion earth changes and the
and sedimentation potential for soil erosion.
control measures
and procedures.
FROST LAWS (A and L)
UCLA - 257.722 Not on ARAR Section 257.722
Rules governing the Requirement is applicable
reduction 01 maximum since wastes (chemical
axle loads during precipitation and bio
the period treatment sludges) could be
'larch - 'lay transported from the site
during the period "arch - 'lay
SAFE DRINKING WATER ACT (C)
SDWA - Act 399 UAC R325.1 060 1-R325.1 0607 MAC R325.1 060 1-R325.1 0607
Regulations estabfishing Requirements are not Requirements are not
WCLs for certain applicable since the aquifer appficabJe since the aquifer
contaminants in addition underlying the site is not underlying the site is not
to the Federal UCLs used to supply a community used to supply a community
or non-community water system. or non-community .ater system.
Requirement is relevant and appropriate Requirement is relevant and appropriate
since it regulates circumstances since it regulates circumstances
sufficiently similar to those at the site. sufficiently similar to those at the site.
Table 7 continued on next page
-------
'. '-".. -'..--_._--~..~...~ -_...'
-....-. .- .
~, ---.~" ...
-.. . .... ... -...-
***
Tab!e 7 . Page 5
T NO ACTION ALTERNATNE SELECTED ALTERNATh'E
STATE ARARs CONTINUED
. -... .......
WATERWORKS AND SEWERAGE SYSTEU ACT (A)
WSSA - ACT 98 Not on ARAR R299.2901.R299.2927
Rules for classification Requirements are applicable
of sewage or waste since a waste treatment
treatment plant operators. facility would be constructed
Rules also contain and operated on-site.
procedures for construction
and operation and
maintenance of
treatment plants.
UfNERAL WELL ACT (A)
UINERAL WELL ACT - ACT 315 Not an ARAR ~AC R299.2211-R299.2229
Rules describing the Requirements are appficable
permitting requirements since extraction, injection
for drilling brine, and monitoring wells would
storage, disposal, and be installed on site.
and test wells.
Table 7 continued on next page
*** As the lemedy ~ reinjecticm of the grwrdwater into the aquifer
after cleaning, the State has also identified Act 245, which requires
meet.in; specified levels prior to discharge, as an applicable ARm. 'Jhe
united States disagrees that Act 245, as inteIpreted and applied by the
State in this latter, is an ARAR. 'Ibis issue is the subject of
litigaticm in u.s. v. Akzo Q)at~ of A1!erica, awellate case J"II~
89-2902 and 89-2137, and 'lIi!J.y be r-"'~ ~ after a decisicm has been
ren:iered. 'Jhe State cx:n::urs with the remedy selected, and has state::i
that in awlyin;J Act 307'6 nq.rlreIDents to the treated groundwater for
reinjecticm to the aqUfer, the ~~y selected will _tisfy the
rIq.1irements of Act 245.
-------
.1. .~ . - -.\.'" -. . - .~
. -.....--- -~_..... - ...- -. .
.-..._~':'_-_.'. -
Table 7 . Page 6
NO ACTION ALTERNATIVE SELECTED ALTERNATh'E
STATE ARARs CONTINUED
NATURAL RIVERS ACT (L)
NATURAL RIVERS ACT 321 Not an ARAR Not and ARAR
Promotes public health
and prevents ecological
damage due to the unwise
development within the
natural river district.
INLAND L4KES AND STREAMS ACT (L)
INLAND LAKES AND Not an ARAR Not an ARAR
STREAMS ACT 346
Regulates all activities
below the high water mark
on inland lakes and streams
WETlANDS PROTECTION ACT (L)
WETLANDS PROTECTION ACT 203 Not em ARAR Not an ARAR
Provides for the preservation,
management. protection and
use of wetlands by
prohibiting certain activities,
requiring permits, and
imposing penalties for
violations of the Act.
ENDANGERED SPECIES ACT (L)
ENDANGERED SPECIES ACT 203 Not an ARAR MAC R299.1 021-R299. 1028
Rules contain a 6sting Requirements are appflcable
of the fish, .ndfrfe since one threatened
and plant species that species, the Eastern Sand
have been determined Darter (Ammocrypta peIIucida),
ta be endangered ar and one special concern lp8Cies,
threatened. the Dwarf HackberTy (Cettis tennifafia),
have been reported to
occur on or near the site.
Table 7 continued on next page
-------
. .
. . '.. _. .'- -. ... ~._- ~-_.... --_._.,. - ,-.-...... ...-- ..-..-.-....... .- -. -.. -
. .. .
..'. .,\
Table 7 - Page 7
NO ACTION ALTERNATIVE SELECTED ALTERNATIVE
STATE ARARs CONTINUED
ENVIRONMENTAL RESPONSE ACT RULES (C)
~RONMENTAL RESPONSE ~AC R299.5705-R299.5725 UAC R299.5705-R299.5725
ACT RULES Requirements are applicable Requirements are applicable
Rules describe cleanup to remedial action at to remedial action at
criteria for response this site to the extent this site to the extent
activities. that the remedial action that the remedial action
is undertaken using State is undertaken using State
funds pursuant to funds pursuant to
Act 307. Requirements are relevant Act 307. Requirements are relevant
and appropriate. otherwise, since and appropriate, otherwise, since
contaminant levels currently contaminant levels currently
found in site groundwater' found in site groundwater
exceed levels set by exceed levels set by
application of application of
cleanup criteria. cleanup criteria.
... .".:'"-
KEY TO TABLE 7 SYMBOLS
A = Denotes on Action Specific ~~AR
C = Denotes 0 Chemicol Specific ARAR
L = Denotes 0 Location Specific ARAR
-------
_...:..~. ...:_-_..::~---~~-::-_.'-""""""'~ 4
....... ----.--.--------.-....
. ....... -......-- . -- .-
. .. ..
..
.
'Jhe No Actim alternative does net ocmply with the requirements of the Act 307
Rules, Michigan Water Resooroes O:mnissioo Act, or the Federal am State Safe
Dri.nkin; Water Acts as ooted in Table 7. 'Jhe majority of the pat:.ent.ial ARARs
identified are net awlicable, relevant or awIq)riate to the No Act.i.a1
Alternative. 'Jhe adcpt.im of this alternative would net prevent further
aigratim of cx:rataminated g:rcundwater. Both the Federal and State safe
Dri.nJdn; Water Acts are net applicable (the aquifer uroer the .ita is net used
for a (XMI'ftmity or ra1-O .,..imity lImter sq:.ply), but are relevant and
~iate sirx:e they regulate )la}.'inum Contaminant Levels in drlnki.n:J lImter
far protectioo of human health.
I.crq-tenD Effectivaes5 and PeJ::Danenoe refers to the ability of a ~~
to JIBintain reliable prot.ecti.a1 of b.man health and the envircn1e1t ewer
time, a1CB clean..1p gca1s have been 8!t.
'Jhe treatment alternative would prcwide the greatest reductioo in the
potential for exposure to g:rcundwater 0CIltaminants. 'Ihis alternative is
e>cpected to reduce cx:ntaminant ~tioos to the clean up levels. Iag-
teJ:m protectioo would be adrieved in apprcod.mately 5 years, as the treatment
system WtUld reduce the volume of 0CIltaminants rNer time. Na1e of these
cpUi ties are offere::l by the No Actioo Alternative.
3.
4.
RedL.1ctia1 of Tarlcity, Jl:j)illty, or Vo1\De refers to the ability of a
~~ to JEet the prefererDe stated in Secti.a1121(b) of ~ far
raxsties that involve treat:ment to pezmnently redD! the tOOcity,
Ebility or vcl\De of bazarcb.Js sub;taroes am 0CIltaminants.
'Ihis al ternati ve would nearly eliminate the toxicity, m:t>ility, ar volume of
cx:rttaminants in the site's g:rcundwater because of cx:ntaminant destructi.oo, am
WtUld reduce the m:i:>ility of irorganic cx:rttaminants. 'Jhe activated sl\d;Je
process is aimed at I"E!Jl¥:7Virg most of the volatile am semivolatile organic
cx:rttaminants, in::ludin3 ketmes, Wid1 are less readily remaved by carlxI'1
ldsorptioo an:! air striwin3. 'Ihe remainirg organic cx:rttaminants are
extracted via air striwin3 and carbon ldsorptioo, am are destroyed durirg
the off-site reactivatioo of the carba1 units. Irx>rqani.c cx:rttaminants are
precipitated fran the prooe:ss stream, dewatered, st8bilized, an::l. n i ~ of
off-site at a permittEd facility.
'1be preference for reductioo of toxicity, mct>ility, am volume is met by the
activated sltd;Je, am by carlx:I'\ ldsorptia1 steps of the treatment train for
the organic cx:rttaminants. Other prooes,;es eliminate cx:rataminatia1 fran the
site's g:rcundwater, b.Jt nqrlre n;~l of that cx:rataminatioo elsewhere.
'1be No Act.ia1 alternative does rot redooe toxicity, mct>ility, or volume ~
thrc:u:1h the slow natural ~"es of n;~rsia1 am bi~caJaticm.
SKrt-'t:.em effect.ivs leSS ad:h. e 5' the ability of the al t.emative to
~~ ris1cs 4Irin;J the oCn:»t...Lucticn ani bpl.::aucall.d~ fhases, am
rEd~ i~iate risks pceed by the bazarcb.Js 8irteria1s toIL r L.
DIrin;J the design am ocnstructia1 of the selected altematiWt, the sDxt-tem
risKs potentially posed to the (nmI.1r1ity am worXers can be effectively
eliminated t.hr'cu3h 14~ ~ ~!::IJreS am protective 8Cl1i~ for
wcrlcers. ~b' actia1 cmjectives would begin to be D!t after 8tart-up of
5.
31
-------
.~-..:..:.:.. "":~.:"...;'"-=.:..,;,.''':''::::'::-:--''. -:-:-.;:...-=;::;..~-=-. --
~- .. -- ..... ".
. . ,
'..
.
the treabDent system. CD1OiJ'g Da1itorirg of private 1IIells in the rrmrrtvdty
will be oa"Jtin.Jed as ~ until gro,Irdwater cleanJP is cxzplete. 'Ihis
criteria does not ewly to '!be No Actia1 Alternative.
6.
r:aplement:ability .is the t.ectJni.ca1 and administrative fEAtdhi 1 ity of a
~, .bx:1u:lin;J the availability of goods and &en'ices r T -"'ad to
bp1sDent the cb: Ii an solutian.
fJbe individual technoloqies used in the treabDent alternative are OCI"IVentia1a1.
am well dem:nstrated. No \.II'Uc:I~l features are anticipated to be required for
this alternative. '!his alternative is admi.ni..stratively feasible as it
ad:h'esses the remedi.a1 actia1 objectives for the site and pezmitt.in;;J
requirements are adUevable. '!be No Actioo Alternative meets J'a1e of the
feasibility criteria.
7.
CD;t .bx:1\des capital and q:eratia1 arrlllBint:enarxJe ccsts.
Q:)st estimates (detailed in the Descriptioo of Alternatives sectia1 of this
RX», hold the 1988 net worth for Alternative 9 to be $4.42 millia1 as
originally designed. '!his in::ludes $2.42 millia1 for capital costs and the
balaooe for ~tia1 and mai.ntenanoe.
8.
~ Iqea::y ~ inticates Y1et:her, }wt!l¥W'1 em its review of the
FS arrl 1»-' ,.oeed plan, the 51 JRXXrt Iqea::y 0CI'laIrS, . IU() S F$, or bas no
&:11 ...1w-o!!1 tl em the selected .L~.
'!be State of Michigan is the lead agercy and has prepared this RX> and the tE
EPA cx:n::urs with the selected .r.~.
9.
O--1I1ity ~ is detailed in the attached ~,-
SI1ImRyY .
Specific ocmrents received fran area residents inticated tmiform and strcn;J
SlJR'Ort of the selected l.~. 'n1e Responsiveness SUnInaIy gives a detailed
list of ~ expressed in writirg and verbally at the pJblic hearin;J.
Selected Remedv
1.
Attairanent of Goals
Beth MLNR am EPA have deteImi.ned that the le:weQy 1ItUd'l inclu:Ses extractioo
with biological treatment, chemical precipitaticm, air striwirg, and carbc:I1
adsarptia1 with gramdwater c:lischarge of treated water via injectia1 wells,
provides the best CXlIpliaroe with the nine criteria. '1be selected alternative
meets the requirements of CEaA, and has received favorable pJblic l'Y'Wm'P1"Jt. ,
tJpa1 CXlIpletia1 of this l~ to the clearop levels specified in Table 6, the
risk to pJblic health and the env.ira'1nl?nt fraD the SpiEWJP'~t"9 gramdwater
plume will be reduced to levels CXI'1Sistent with ewlicable- Federal am State
recpireIDents, and thus be protective of human health and the 81ViraDent.
32
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. '.' .--.....':"':"-.---. - .
----.----..<1.
........---.- .
- .- .--'- -- -- -.
. ...'
"0
o
2.
Ckm:>liame Points
O:mpl~ p:>ints to be 1ftA:'!::1Jred durin;J the ocurse of the ~b' actic:n, to
deteJ:mine the pt~cSS of, ard the attainment of protective grwrrlwater levels
are: effluent c:becJdn:J to directly deteJ:mine the effectiveness of the
treatment ard to prevent the re-release of untreated cbemi.cals to the
EI'IV.ircnDent: ard, mcnitorin;J well checks to deteJ:mine the effectiveness of the
treatment system at hal tin:} the fiOili of cxrJtaminated grwrrlwater, ard to
-=ni tor the charqeS in the ocmaminant' s cx::.mentratims within the plume
itself. Residential well mcnitorin;J in the clirectic:n of grwrrlwater flOili will
be 0CI1tirued to insure that these resooroes remain unaffected.
Specifically, the area of attairlDent to be D?a~ for the ampletic:n of the
Spi&JP'hPrg grwrdwater plume remediatic:n exten:!s t.hrc:u;hcut the plume in the
uwer an:i l~ aquifers in the area un3erlyin;J ani surr:aJniin:J the
SpieJP'hPrg site.
3.
CD1timen::ies
SaDe charqeS may be made to the l.~ as a result of the ~;~, design an:}
cx:.nst.roction process, however, the cleanup goals JDJSt still be met by whatever
variation of the l.~ is iJrplemented. 'the follCJiIiin;J are Sate of the
oot.stardin:;J i.5SI~ which will be aO:1ressed durin;J negotiatims, ~; ~,
design, ani ~i~' actic:n, an:i Wich may alter the lemedy as descri1:Jed in
the R)[): treatment duratic:n: site access: general system design: maintenance
am Da'UtoriIg: residential well sa:apliIg plan: Da1itorirg well placement am
sanplin;J frequerx.y: oversight; future Potentially Respcnsible Party
inYol varent: ani, deteDninatic:n of backgro..1r'd lead cx::.mentratims.
statutarv Det~1"'III;natia1
'the selected lemedy will CXI'1trol an:i eliminate risks associated with the
O1emicals of O::mem in the Spiery:a'hPt'g groon:twater plume. 1he statutoIy
requirements of cmcI.A Sectic:n 121 will be satisfied with the bplementatia1
of the c::b::6en le:trJ!!dy. 1he followi.J'q is an erume.rated descriptic:n of how the
selected A1 temative meets each requirement.
1. Prot:.ect:.i.m of IbIBn Health am the Er1viraDent
1M selected :a.o:::tJ.edy will prcM.de adequate protectic:n of human health an:i the
envira'"ment thrc:u:3h the treatment t:ed'1rologies to be euplayed. Risks
as.~iated with CC'I1tact or c:x:n;unptic:n of site grwrrlwater will decrease CNer
time because the extractic:n an:i treatment system will reduce the OCALCUW.atim
of all CXI'1tam:inants to the c1ear1Jp levels specified in Table 6. At ampletim
of this leuedy, the carcimgenic risk will be ~~ to levels CXI1Sidered
acceptable in the MidUgan Act 307 Rules, am well within the EPA's 1E-04 to
1E-06~. earciro;Jenic"risk llSS'Y"iated with the SpiEWJP'hPrg site's
CJl'ClD'1dWater is a£u.~.uy 6.0E~3. '!he iJlplE!!llS1tatic:n of the treatment system
ard the attainDent of the req.dred c1eamp levels 'WCUld z-o'!- the .
carcinogenic risk to 2. 6E~5. Na'H:arCimgenic risk will be rer't~ to levels
to 1ItUch b..Jman; JII1J.y be tDCpOSEd, without adverse effect durin;J . lifetime or
part of a lifetime. unaooeptable shcrt-t.eIm risks will be not be caused by
the iJlplement:atia'1 of this ~~.
33
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_._---~_.,._-------_. -
. - ..~. -. ......- . -. .
. .
. ..
..
2.
n-w.p1f3J1Ce with ~1fnPI~le ar Relevant am ~ PecJ1i.~d..D
'1he 1:~Y selected will meet or attain the awlicable or relevant and
1JWlC\J.date Federal and State requirements, and will be inplemented in a
manner ocnsistent with these laws. Table 7 lists all of the Applicable ar
Relevant am AwrcPriate Requi.rement.s (ARARs), and describes ~ it is an ARM
far the selectim or iuplementation of the chcsen SpiE'7'"~rg gran:lwater
~j"1 actia'1, for the attainment of clearnJP goals.
.In partiOl1.ar, the ~ia.] action selected for iuplerrentatim at the
SpierJPlbE--rg site is cxnsistent with the Natia'lal 0:r1tirgen:y Plan, the State's
Act 307 ~es, and with the State's Act 245, Part 22 ~es. '1he State has
identified Act 245 as an MAR. '!be State ocncurs with the l.~ selected, am
has stated that in awly~ Act 307's requirements to the treated gra.n:iwater
to be reinjected to the aquifer, the leaedy selected will satisfy the
requirements of Act 245. '!be united States disagrees that Act 245, as
inteIpreted and awlied by the State in this matter, is an ARAR. '1his issue is
the subject of litigatim in u.s. v. Akzo Coatims of America, ~llate case
l'I1ITIhPrs 89-2902 and 89-2137, and may be ~~ after a decisim has been
rerDered.
'1he selected 1:eauedy will a~in requirements c:xrttained in the Michigan Act 307
~es. Part 7 of the ~es provides, in general, for three different types of
clean.1p criteria, designated as Types A, B, and C. Type A criteria are based
m reductia'1 of ~ sulstanoes ~tia'1 to bacKgrcurd of detectable
levels. Type B criteria are basOO a'1 reduction of hazardcus substance
~ticns to an ainatia'1 thereof] proposed shall be at the qJtioo of the persa1 iJL~~
the remedial actiQ'l." For p.u:poses of sel~ remedial actim for
gra.n:iwater OCI'1taminatim at this site, ~ plDpOSed a OCIti:>inatia'1 of ~
An and ~ Bn clean.1p. '!hat is, ~ has selected extractioo and treatment
of the ~ substances in the groun:iwater to levels determined thraJ;;Jh
Rule 299.5709, inc:hxti1XJ a lE-06 risk-based level for carcin:qens, or to the
Method Detectim Limit ar bacKgrcurd ~tia\S p..tr'SUS1'1t to Rule 299.5707.
'1he clearop levels stated in Table 6 are cxnsistent with the requirements of
these Mes. '!he clearL1p level for benzene is based at a lE-06 carx::er risk
and is ocnsistent with Rules 299.5709 and 299.5723. '1he cleanJp level for
vinyl ct1l.oride is based at analytical detectim limits and is ccnsistent with
Rule 299.5707 (b) . '1he cleanup levels for 2-brt:ancne and 2-hexancne are ba~
at Human Lifecycle Safe ~ticns and are ocnsistent with Rules
299.5709(b) and 299.5725. '1he clearA.JP levels for toluene and xylenes are
~~ upa1 taste and odor thresholds and are cxnsistent with Rule 299.5709 (d) .
'1he clearJJP level for lead is based 00 an awrcximate Human Lifecycle Safe
o.....-::utratia'1 and is cxnsistent with Rules 299.5709(b) an:! 299.5725.
3.
0:Jst Effecti,w-
Major capital CX&t ite!ll& incluE the extractia'1 and rechaIge wlls, pm:p haJse
and cx:.ntrols, the in1ividual treatJrent systems, activated au:1x:I'1, ard site
utilities. Major q:eratim and maintenance cost items incluE _&'1/ costs,
IIImpliIXJ am JII:I'1itoriIXJ, laboratory analyses, reactivatim of au:1x:I'1, waste
.l~ di ~l, rc:ut1ne systems inspectiCl'1 and maintenance, and report.i1XJ.
'Ibis 1:E!uSdy affords cwerall effectiveness }Jlqx>rtiatate to its CX&t.
34
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-.-. .'
--.--..-' .'-'
. .
.
.
.
'lhe selected ~~ affords overall effectiveness when 1DE*'=.Jred against the 5
c::::Ea::tA Sectia1 121 criteria am the 9 criteria fran the Natia1al ~
Plan, and (X)Sts are prqxn1:iooate to the protectiveness whid1 will be
ecbieved.
4.
Ut..i1izat,i.at of PeI:manent Solutia1s am Alternative Treat.:ae1t (ar reswroe
recxM!XY) 'lbJulOlcgies to the MaYinnm EKtent Practicable
'!he r:emedy EllplajS the preferred permanent solutioos arrl treabDe:nt
tedux>logies to the maximJm extent practicable. '!he t'erlledy permanently
~ the (XI'1tam.inants !ran the ~ter resource in the follcwin:;1
manner: organic CCI'1tami.nants are extracted via air striW~ ani c:.arta1
adsorptioo, arrl are destroyed dur~ the off-site reactivatia1 of the carl:x:In
units: the activated sl1.d:Je prooess removes and destroys JrOSt of the volatile
am semi-"olatile organic CXIl'1tami.nants, includin;J ketones, whid1 are less
readily rem:M3d t7:i cartx:I1 adsoIptioo in the water process and air striwin;J:
am inorganic (XI'1tam.inants are precipitated fran the process stream,
dewatered, stabilized, am disposed of off-site at a pennitted facility. As
stated previaJSly, ally the carbon adsorption process permanently destroys the
wastes collected. '!he other process options in this treatment train require
further Ii; ~] of cxn:entrated wastes.
5.
Prefe.reme far Treatment as a PJ:i1x:ipal ElBDent .
'!he principal element of the selected remedy is the treatment of the
CXIl'1taminated ~ter, as detailed above. 'Ibis elE!ITel1t addresses the
prirx:ipal threat at the site-the further degradation of the ~ter
resource .
~~a1 of sianificant Q}araes
'!he follawi.n;J are dooImentatioo of, am rationale for significant ~ made
to the selected u::llIedy since the issuance of the P.t~ Plan in Jaruary of
1990. Nc:ne of these ~ require the issuance of a revised PI.'~ Plan
or the ~ of a new Public Ccmnent Period, as the L~ does not
differ substantively fran that whid1 was oonteDplated in the final stages of
the Feasibility Stu:iy or the P.tq:a;ed Plan.
'!he PL~ Plan identified ~ter extractioo with biological treatment,
d1emical precipitatia1, air striW~, am carlxr1 adsorptioo with gI"CU'dwater
d.i.scha%qe of treated water via seepage lagoons, as the preferred alternative.
'!he selected alternative no lcn:;Jer irx:lu:les d.i.scha%qe of the treated
gI"CU'dwater via seepage lagoa1s. '!he agencies initially ocnsidered s9CF7
lagoa1s as a cost effective way to achieve the re-i.ntrcrluctia1 of treated
gI"CU'dwater, am, at the same time, provide a means of flushirg resiclua1 soil
cart:aminatia1 fran the unsaturated Za1e. siroe CX3'1taminated soils in the
unsaturated Za1e were rem::wed in the Operable unit 1 so.lrCe CXI'1trol ~;,,1
actia1, the agencies have rOii selected injectia1 ~ls as the cost-effective
IIIet:hcx1 for re-intrcductia1 of the treated gI"CU'dwater. 'Ihese wells will be
located ard &.oL.:e1s1 at the proper depth, to facilitate ~ of
cart:aminants that remain in the saturated soils.
Another factor \lUc:tl favors the use of injectia"l wells Oler S!~ basins is
the reductia1 in areal extent of abc:we-qroUn:3 attractive ~ st%uct:11res,
vud1 ~1nP'C: the security costs (linear feet of ferx::irg) and the liability
involved with cperating cpn lagoa1S.
35
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~_::'~.----..._. -
.. ..'''.'--,.--. _.
. -.-. . ... -...
....
. . " s
:.
. .
-
Methyl.. cblaride ws identified in the ~qA.-"6ed Plan as a ~;~ of
0.. aA:uh Upa1 reviw of the ~bl InYestigatia1 data the Agencies have
detemined that the presence of methylene ctUarlde in the semple analysis of
the Spiagp'~...rg grwndwater, can I'XIt be cx:.nfi.rmed with arrr ~- of
reliability, since the OCI'1Oel1traticns fourd in the laboratory blanks were
~le to those found in the grcun::lwater scmples. Methylene ctUaride will
not be cxn;idered a memical of CD10em unless it is ocnfi!:med by future
saDplinq raJI'ds.
'lbe Pt- ~ Plan imorrectly characterized 1,1-dic:hloroethane as a carcinogen
and, as sud1, listed in:Drrect cleamp levels. 'lhe cleanJp level (HLSC),
~~ a1 the fact that 1,1-dic:hloroethane is a rxn-carcin:::qenic volatile
organic 0. .'1 a.D'X1, is 700 ppb.
Four of the cleaTJJP levels listed in the ~~ Plan (aceta'1e 700 ppb, 4-
methyl-2-pentanc:ne 350 ppb, ethylbenzene 30 ppb, ard 1,1, 1-tric:hlorcethane 200
ppb) ard the ~ corrected level for 1,1-did1lorcethane (700 ppb), were above
levels detected in past grcun::lwater sanpl1nr-;. As such, these 5 d1emicals were
deleted fran the list of Ov:!mi.cals of Q::I'oam for the remedi.atia1 of the' .
Spipt)P' ~rg grcun::lwater. GraJn:iwater flew systems beneath the site are
dynamic, ard fluct::uaticns can be expected in oa1tam.i.nants an:! detected levels
in each well. If subsequent scmplirg rooms cx:.nfirm that ~ or JIIJI'e of these
chemicals are present in Spiegelberg grcun::lwater, above the cleamp levels
noted, the chemicals will be DD'litore:i as Ov:!mi.cals of 0Jncern for the ~Hal
actia1.
~~ a1 a cxmnent received, the Agencies will cxn;ider an alternative
grcun::lwater cleaTJJP level for lead. Past unfiltered backgraJnd grcun::lwater
semple analyses foun.:l an average OCI'1Oel1tratia1 of lead at 159 ppb. Since this
level is frail unfiltered semples, design stu:ties will .in=l\Xle the
determinatioo of actual filtered backgraJnd lead OCI'1Oel1traticns in grcun::lwater
for the Spi('It)P J ~J:9 site. '!be approximate HI.SC of 5.0 PIX> is listed as the
required clearup level unless tiltered backgraJnd lead OCI'1Oel1traticns are
detennined to exceej that durirg ~ial design. In that case, the clearuJp
level for lead will be the average c...-=ntratia1 of the filtered lead scmples.
'lhe PL- ".osed Plan ard previ.cusly if:.c:I~ site dco1mP1'1ts irr::licated that the
grcurdwater flew d.irect:ia1 at the Spiegelberg site is to the northwest.
FUrther evaluatia1 of the data gathered irr::licates that there my be a westerly
(;u'IQS&t to grwndwater flew underneath the former paint slUf:i]e area. '!he
owrall grcurdwater flow for the site is to the northwest.
Public (Z.,..-=-nt ard cx:n:em was expressecl rega:rdin:J the use of 1.0 ppb as the
required cleanJp level for vinyl d110ride versus the calculated 0.015 Ri> (lE-
06 risk p.1II'her). '!he Agencies cannot require a cleamp level1l4U.c:h amnat be
reliably ~!:IJred, bcM!ver, they have detennined that laboratories can, am
are raJtine1y required to, analyze for vinyl ctUoride dawn'to the 0.5 ppb
l8Yel. ~ to 40 em Sectia1 141.24 (9) (U) (i) (C) laborataries DJSt
ena.lyze to 0.5 ppb for drinkin;J water. Method 524.2 will ac:hieYe this level
,of detect.ia1. 'Iherefare, the required cleamp level for vinyl dUaride is
cban;JB1 to 0.5 Ri>.
36
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-.....-.-. ... -...-- "'.'" ..., . .... .-'., .--.....----..----.. -.-..
.
...
GREEN OAJ(
RESPONSIVENESS SUMMARY
SPIEGELBERG SUPERFUND SITE
TOWNSHIP, LIVINGSTON COUNTY,
JUNE 24, 1990
MI CHI GAIl
OVERVZ8f
The preferred alternative for the contaminated groundwater at the
spiegelberg Site is: the combined use of groundwater extraction,
chemical precipitation, biological treatment, air striping, and
carbon adsorption, with discharge of treated groundwater via
re-injection wells.
The written and oral comments received from the citizenry and the
-;.vingston County Health Department, were all in support of the
. :,-:!ncies' preferred alternative, and encouraged the agencies to
~~oceed as swiftly as possible, to implement that alternative.
In general, comments received from the Potentially Responsible
Party (PRP) were critical of past investigative activities and
technical documents including the Remedial Investigation and
Feasibility Study Reports. With regards to the proposed plan for
the remediation of the spiegelberg groundwater plume, the PRP
agreed with the need for remedial action and with many of the
~qencies' proposed cleanup levels, but offered several different
emical-specific cleanup levels, and a .odified methodology for
~ne attainment of the levels.
BACKGROUBD ON COMMUMITY IMVOLVBIIBNT
COncerns
The community Relations Plan for the spiegelberg (and Rasmussen)
Superfund Site(s) was completed on October 25, 1984. At ~at
time, key concerns identified were:
* Potential for residential well contamination.
* Lowered property values.
* Potential health hazards.
* Lack of response to citizen concerns.
From August 1989 to February 1990, the PRP conducted an Operable
Unit Remedial Measure at the spiegelberg site. Citizen's concerns
expressed prior to the initiation of the removal were:
. Potential for air releases.
. Trucking traffic and road conditions.
~fACbl and out.co8ec of Concerns
.
the work done on this site over the past five
the key concerns highlighted above were addressed.
Past sampling rounds have consistently rev.aled
that residential wells are unconta.inat.d.
Individual properties which have recently sold in
the area, according to township officials, are
going for comparative prices to si.ilar dwellings
elsewhere. The township official did note that due
As a result of
years, .ost of
.
1
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--... --- ~ ..- ~.'"
~
. .
"
-..-----......- - "'---'-~ _.~ .
. .-.. '.........."............-.-.... .
*
to the fact that lending companies are aware of the
presence of the site, mortgages are difficult to
obtain, and the area is not being built up as
quickly as it might have in the absence of the
site.
No adverse health effects have been noted from the
site, however, this will obviously be an ongoing
evaluation. When the groundwater remedial action
has been implemented as planned, no adverse health
effects from the site are expected.
The Attachment to this document shows a rich
history of ccmmunity involvement throughout the
duration of this project, largely through the
efforts of the citizens and the Livingston County
Health Department, in organizing citizen'~ c:,lX;UPC
and staying involved. The concern expressed mo~~
frequently now is that cleanup should proce~~ mor~
quickly. .
Air monitoring throughout the work zone, and at the
site perimeter during the removal actions, showed
that no air releases were measured off-site.
Road maintenance was kept up during the removal
actions and no concerns were registered regarding
discourteous trucking.
*
*
*
smoIARY OF PUBLIC COMMENTS AIID LEAD AGENCY RESPONSES
What follows is the response to public comment regarding the
Spiegelberg Superfund Site's Feasibility Study dated OCtober 1988,
and the site's Proposed Plan released in January of 1990.
Comments and questions were received and recorded during a Public
. ~eting held at the Green Oak. Township Hall on February 8, 1990,
om 7:40 p.m. to 9:25 p... Written comment was also received
. .roughout the Public Comment Period from January 16,1990 through
February 16, 1990, and which was extended until March 19, 1990.
rn._nts Received at the Public 1Ieet~
The following comments were received and recorded in the
transcript of the public .eeting. They bave been rearranged into
12 categories (the subheadings) for consolidation purposes.
1.
Lo9istics
Where do we stand on the National Priority List. if the action is
put in place? If this plan is put into action. will its start-uD
be affected by the site's ranking on the list?
once a site is listed,
Priorities List. Once
phases of the remedial
ranking.
its ranking does not change on the National
an investigation has begun, subsequent
process are not governed by the .ite's
2
-------
p. .". ~--'-"'---- ~.
len will the proposed remedial action begin. if approved?
If approved, the agencies anticipate that the action would begin
in approximately a year to a year and a half, barring any
unforeseen circumstances.
~ow Ion; will this oreferred program take if it is put into
action?
For purposes of evaluating costs, the remedy was estimated to take
five years to complete, although the actual duration of cleanup
will depend on the rate of extraction and the actual time it takes
to reach the cleanup levels specified in the ROD. A better
estimate of treatment duration will be available, once the design
phase studies are completed. The Feasibility study erroneously
stated that cleanup would be achieved in two years. During the
preparation of the feasibility study, two years was the amount of
time estimated tor getting the system on line and completely
functional.
Is there a possibility that the agencies will change their minds
and select the No Action Alternative?
The Agencies are required by the National Contingency Plan, to
evaluate the No Action Alternative as part of the Feasibility
study process. The No Action Alternative does not address the
ctual or threatened releases from this site. The Remedial
investigation and Risk Assessment show that if not remedied, the
groundwater contamination aay present an imminent and subst~ntial
endangerment to public health, welfare, or the environment. The
No Action Alternative does not meet the remedial action objectives
mandated by Federal and state Law.
~r~~~.c~~a~~~t~;~nd~~n~: :~a~.r:~~itt~;r~~P~~~~e~o~~~~c
comment period and public meetinQ?
If the remedy is changed 8ignificantly from that called for in the
proposed plan, the public comment period will be re-opened.
2.
site Access and ownership
Who is the current owner of the areas being remediated?
,
Mr. James spieqelberg is the current owner of the property defined
as the Spieqelberg Site.
~:tv~~y:l~~~~so~oci~~n~~v:n~oa~~~:s~I~~U~~operty-thrOUQhOUt
In the past, access has been gained by written and verbal consent
~i th the owner, for each phase of "ork. Access for the proposed
'emedial actions "ill be secured by the PRPs (if they i.ple.ent
the remedy). If the PRPs do not implement the remedy, or if the
3
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.. .-..-. -..........-...
-. ---.--.. -.---........- .-'''....,.
.- .~-' -~ .. -'.- -', ~ .
..- -..... '.........
..-. . ... ,. ,.
PRPs exhaust their best reasonable effort
agreements, the state and EPA shall their
to obtain access through written consent,
through a court order.
to secure the access
best reasollable efforts
or, if necessary,
Have the current owners of the Spiegelberg property been paid for
900ds and services?
The state and Federal governments have not paid the property
owners for any goods or services. It is our understanding that
the PRP (Ford Motor Company) purchased some materials as part of
the paint sludge removal action.
will the State or Federal agencies be paying the owner for the
property for placement of the treatment system? Is this a
negotiable point?
No. Since the property owner is a PRP as well, the owner aay be
liable for costs incurred by the Federal or State governments.
3.
Site Security
How will the buildings. pumps and treatment system be secured?
Fencing will be erected as necessary to protect treatment system
components. Guards may need to be hired to patrol the area when
no workers are at the facility.
What protective measures
site. the property owner
jeopardize your results?
knowledge that wells had
owner.
do you have that while there is no one on
will not mine in the areas that could
The questions were asked with the
previously been destroyed by the property
U.S. EPA and MDNR will be .eeting with Mr. Spiegelberg to .
negotiate interim access agreements. The PRPs will negotiate an .
RD(RA access agreement with Mr. Spiegelberg if they implement the
remedy. These access agreements are legal documents which would
indicate Mr. Spieqelberq'. intention to comply.
Wouldn't the injunction process. to prohibit t:AWlpering with
equipment. be lengthy?
If a court order 1. necessary, the aqencies will seek an order as
quickly as possible.
The well that was destroyed, how was it destroyed. and was his
bulldozer taken away from him? Can the well still be ...pled?
There were three wells destroyed 1n the past year and a half. one
flush-mount well was topped by a brush tri..er and can .till be
sampled, one was excavated and lain horizontally (this well was
subsequently properly grouted and can not be sampled), and the
outer casinq of one well was undermined and can still be s.-pled.
4
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... ----,--_.::~:r.::" '..I:::::::-::::=::-==_..:.;-:-::=.::.:~:.: ---~._. ".--.... ,,- ---,.-..... '.. ':'::."':''1. ..,. . - --.". "::."~..":.'"'. .,.,~"-.':~,: :"",'"'. ,,-_....
. -
~o equipment was taken away from the property owner. Althou~h two
wells can still be sampled, the integrity of the wells have been
compromised and any data generated from these wells in the future
may be questionable.
Were the destroyed wells considered vital to the continued
monitoring of the site?
Every well that is installed is considered vital to monitoring of
the site, however there are other existing wells that can still be
monitored to continue to accurately assess the situation.
Additional wells can be installed, if necessary.
4.
~e90tiations and PRP Involvement
What is the process for getting the PRPs involved in the cleanup.
and do you sue them if they decline to do the work?
Once ~ remedy is selected, and the Record of Decision (ROD) is
signed, the agencies expect to begin negotiations. with the PRPs on
a Remedial Design/Remedial Action settlement. The Settlement
Agreement would take the form of a Consent Decree which is
negotiated and agreed to by all parties and approved by the court.
Signing of the Consent Decree would legally require the PRPs to
i.mplement the cleanup. If the PRPs decline to voluntarily carry
lt the remediation, the agencies will have the option to ~)
~nitiate the remedial action with public funds and pursue cost
recovery through a lawsuit, 2) issue a unilateral administrative
order requiring the PRPs to do the work, or 3) sue the PRPs for a
court order requiring them to do the cleanup.
Are you able to make any comments on the likelihood that the PRP
will pay for the remedial actions? .
A PRP has done remedial work on the site in the past. However, it
is inappropriate to speculate on whether they will implement the .
groundwater remedy.
One commentor sU9gested that we should i.plement the remedy. and
then ne90tiate later. to speed up the process.
Negotiations vill not be protracted to the detriment of the
progress of the cleanup. However, every effort is .ade to first
obtain the necessary cleanup at PRP expense, to avoid the use of
public funding and to .ini.ize litigation.
If the PRPs si~ the consent decree and a9ree to do the work. are
you relieving them of liabilities in the future? Who determines
Jf the PRPs get a release of liability?
-onsent decrees are worded to suit the specific .ite .ituation.
1Y covenant not to Bue in the future is negotiable for certain
.atters, and for certain matters, is not. The content of the
Consent Decree is determined by the united states Departaent of
5
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.' h 'h 4.- - ~ -,
,--:-:..,-,.:::::.-.,-.:.::::":";.";:"'"~---,.".~~-~ "'-..-.-... ---.. .... .
Justice on behalf of EPA, and by the Michigan Attorney General on
behalf of the State.
Does the public find out the result of the negotiations before
final decisions are made?
Public involvement does not end with this Public Comment Period.
The Public will be notified prior to commencement of Remedial
Action. If a Consent Decree is negotiated on behalf of EPA, the
U.S. Department of Justice will provide public notice and an
opportunity to comment on the Consent Decree before it is entered
by the court.
5.
Public Involvement
pill the area residents. the township. and the county be
periodically updated once the cleanup begins. and with what
frequency?
All interested parties will be kept informed throughout the
process, either by newsletter, public meetings, or postings on the
sign board used for the paint sludge removal. Rather than tie our
. notification process to a specific schedule, we would expect to
provide newsworthy information on an as-it-happens basis. The
Administrative Record, located at the Hamburg and Brighton Public
Libraries, will be continually updated throughout the cleanup.
It was requested that certain responses (the issue of risk-based
cleanup levels vs. detection limit for carcinogenic compounds) be
provided sooner than the issuance of this responsiveness summary.
since that could affect additional public comment and the ROD.
The agencies stated that we would try to provide answers to these
questions sooner, however we do not want this process of comment
and response to go on indefinitely.
6.
Funding and Implementation
Is funding for the remedial actions quaranteed once the proqram
starts?
EPA has set aside funding for conducting the design
remedial action. We viII first try to get the PRPs
the action and then, if necessary seek funding from
EPA's Fiscal Year 1991 and 1992 appropriation.
for this
to implement
the state and
Concern was expressed that the cleanup levels required for this
site were different than non-Superfund site cleanup levels
required elsewhere in the State. Part of that concern vas for the
use of taxpayer dollars to clean the vroundwater for an extra six
to ten years to reach levels that were immeasurable.
The cleanup levels specified for this site are consistent vith
current State and Federal governing law, rules and guidance. All
6
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- ~ - ..~...:._.::-::,~:-~..._.---"-,,
--.*-.. ..' - ._-. ~
.-.... _6 - ..- . ~. ." .-.
groundwater cleanups in this state have, and will have to comply
with these requirements. Every effort is made to avoid the use of
taxpayer's dollars to remediate sites where PRPs can be
identified. Cleanup levels are not compromised in any situation,
and the cleanup levels for this site will not be below what is
measurable.
7.
~ontaminant Levels and Cleanup Criteria
~~er~~ ~~;n~a~~ ~~e:~et~~sf~~u~~::i~~l~~t~~ :~~i~~e~~e cleanup
Yes, remediation will continue until all of the cleanup levels are
ect.iev.d.
Z~.~_l~vels in the groundwater currently above the cleanup
ie~el~ iisted in the proposed plan?
The contaminated plume beneath the site currently contains
chemicals above the cleanup levels.
:i~e~h~u~a;~r~~l~oi~~~t~~~:dl~:t~i~ie:~~~i~e;~~s:r~n~::~:~d
~~~~9h the preferred remedy? will there be effectiveness testing
- 11 chemicals found in the groundwater?
fhe chemicals listed with cleanup levels in the proposed plan are
considered "indicator" chemicals. If these indicator chemicals
are removed to the specified levels, then the other contaminants
are likely to be removed as well. Effectiveness monitoring of
effluent and monitoring wells will be done for a full range of
contaminants, and not restricted to the indicator list.
~~~y~I~~~~~i~:V~~~O~~s~~~.~o~r;.~~;~h~~r~~;h~~: r~': ~f~ii~~d
~:~~~~i~~~~i~~~~'1.~i~=~n~~~lihe~~Ut~~o~::i~~1;~ea~h:po~~ ~~e~.
;~i~~~~.~:~~~r ~;~k is immeasurable for these two. chemicals. but
i- _1 - " __en. Does that mean that there is a 1 in 400.000
~~~~~~ ~f ~~~~i~9 cancer at the 1.0 ppb 1.1-dichloroethane level.
--- - 1 _n ___000 chance at the 1.0 p~b vinyl chloride level?
The groundwater concentration for vinyl chloride associated vith
the 1E-06 cancer risk is 0.015 ppb. This concentration is be10v
the level vhich .ost certified analytical laboratories can .easure
using BPA-approved methodology. For those chemicals having 1E-06
groundwater concentrations less than the analytical detection
li.it, the acceptable detection limit viII then beco.e the cleanup'
requirement. A cleanup level can not be achieved if it can not be
reliable .easured. After the public comment period clo88d, the
Agencies checked into Method Detection Limits (MDL), and found
~at the MDL for vinyl chloride of 1.0 ppb, listed in the Proposed
Plan, vas not the lowest detection that could be reliably achieved
by laboratories. Under 40 CrR 141.24 section (g)(11)(i)(C), BPA
7
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..----._w "oJ' ....-..-.-....---... _.~'-.._-.... ..
......-"---.-. .-.), ..-."'............--.-.....---....
requires that laboratories achieve 0.5 ppb for this compound for
analysis of water supplies.
It is true that the risks posed by the detection limit cleanup
standard of 1.0 ppb or 0.5 ppb are higher than that for the
lE-06 level. There is a lot of conservative ism built into the
risk assessment process. For example, the acceptable groundwater
concentration is not directly associated with a risk of 1
additional case of cancer per one million persons exposed. It is
the concentration associated with the 95th percentile estimate of
risk, or the 95 percent upper bound on risk. This means that the
true risk is expected to be less than lE-06, 95 percent of the
time and may even be near zero. other conservative assumtions
used in ~'il~ ~t" culation of the lE-06 number include human
consWIJ.'": .r.. ~ . :.1 :.iters of contaminated water daily for 70 years,
and a C;:. "I :'.. : "" ;t: i ti vi ty for humans to develop tumors than
experia'6": ~"~ ;"«:...1". ..nls.
l,l-dichloroethane is no longer listed as a Chemical of Concern.
Please refer to the answers to the PRP's written comments or the
ROD for an explanation of this change.
The charts on pages 13 and 14 of the Feasibility study designate
the "one additional case in 100.000 for cancer" in Column 3. This
is contradictory to the cleanup levels which are based on the one
additional cancer case in 1.000.000.
This is a typographical error and an errata page has been
provided. It should read "one additional case in 1,000,000 for
cancer."
What laboratory wastes were found during the paint sludge removal
actions. and how do they fit into the final remedy considerations?
The materials found buried below the paint sludges were:
one empty cylinder that had contained compressed gas,
one empty cylinder that had contained hydrogen bromide,
one cylinder containing carbon 8onoxide gas,
one cylinder containing hydrogen chloride gas,
348 4-ounce glass ampules and one balf pint glass bottle
containing phosphorus trichloride, and
275 glass bottles of various sizes and shapes containing
a variety of chemical laboratory wastes.
Although it did not identify the location of the laboratory
wastes, the analyses conducted as part of the RI/FS would have
detected any contribution of these wastes to the overall
groundwater plume, since complete chemical analyses were
conducted. The 8ajority of the laboratory containers were aealed
and unbroken when excavated.
8
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....-. ~..'
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.- -- ..-"--:""-;;"__4_" ... "'-".'
.. . . .. -~. '-" .
~ there any suggestion that the laboratory wastes were biological
in nature?
We had no reason to believe that the laboratory wastes were
biological wastes.
If in fact. new. more stringent levels of toxicity are determined
during the course of cleanup. will the remediation be adjusted to
account for the more stringent requirements?
Yes, if new information regarding a change in the
is developed, the cleanup levels will be reviewed
needed, to assure the protection of public health
environment.
toxicity levels
and adjusted as
and the
8.
Groundwater r.c. '::"':i&I~;-.,:"
What is a "plume"?
"plume" is the term used to describe that portion of the
groundwater which contains contamination. The term .plume. was
adopted for this use in describing groundwater contamination
because it implies that there is a fixed source with some
mechanism of dispersion acting to .ove portions of that source
from its origin.
J the groundwater flow to the northwest?
The general groundwater flow for the site, in both the upper .and
lower aquifers is to the northwest. There may be a westerly
component to groundwater flow beneath the former paint sludge
disposal area.
How is it possible to contain groundwater that is flowinq?
Although groundwater does flow, it is not like flow of vater on
the ground surface or in a stream. Groundwater flows in between
the soil particles and is slowed down by its contact with the
soil. Groundwater containment, as it applies to the remedy
proposed here, refers to the halting of its natural flow through
the soil and drawing it up through a line of wells, to a treataent
system. The best way to envision this is to think of the
traditional aeans ot .containment---a vall. Instead of putting a
physical vall 1nto the ground, a line of wells 18 placed
perpendicular to the direction of groundwater flow, near the
leading edge of the contaainated' qroundwater. When all of the
wells are pumping, the conta.inated qroundwater is prohibited from
proceeding in its natural direction by drawing the vater 1nto the
wells, and is thus contained.
9
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Wha~ is the groundwater flow rate at the site? If the 'groundwater
is moving and the contamination is moving. how is it possible that
the wells across the street are not cont~minated? '
The qroundwater flow rates determined in the RI are indicative of
localized conditions and not necessarily representative of a
site-wide scale. Additional aquifer testing, preferably a pump
test, will be necessary during a design phase to properly
construct an effective treatment syste.. We have looked at the
qroundwater flow rate in both aquifers in more detail and have
found them to be: 1) Upper Aquifer: 2.57E-04 centimeters/second
(266 feet/year or 0.73 feet/day), and 2) Lower Aquifer:
1.26£-04 centimeters/second (131 feet/year or 0.36 feet/day).
Although we can not say fU1' ceri..i:d.n why neighboring wells are not
contaminated, some or all or ..'h,=,~ following may contribute to this:
hydrodynamic dispersion (analogous to dilution), flow direction,
confining layers may be protecting residential well intakes,
retardation (chemicals flow slower than water), cation exchange,
chemical decay, and biologi~ transformation. At this time, the
determination of a dominant process would be speculative and
possibly erroneous. '
One commentor stated that five years a90. when they purchased
their property. that the DNR "guaranteed me that there was no
water contamination. none." "And now five years later. . . . we
now have honest to God real life water contamination. . .n
Five years ago, the DNR (and the EPA) knew of the groundwater
contamination underneath the Spiegelberg site, and informed the
home purchaser that, it existed. What was stated at that time, was
that the contamination had not migrated off-site. To this day,
the agencies have no evidence that the contamination has migrated
off the Spiegelberg property, and are making every effort ~o get a
system in place, to halt the flow of contaminants. '
A question came up before about what happens if the money doesn't
work out and the problem gets worse. How can it get worse in
light of the fact that that the wastes have been removed?
Since the wastes have been removed, 'the continued contribution of
contaminants to the groundwater has been ended. However, those
contaminants already in the groundwater under the site have the
potential to continue to move. So "worse" here is not the best
tera to use. It would be better to say that if left untreated,
the groundwater problem could .ove toward residential wells.
10
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..:.~.:...- -'.""." -.-- "'''''''-''~~-..-.'.---'-'''' -. ,-
_--~~~T--_-':~--------- _:......:._~............- ~4";' ---.-,. "'--'- -""--""""-----'.. ....
Residen~ial Well Monitorin;
How often will the residential wells be tested. and by whom? We
would like to see the test results in a mere timely fashion than
in the past?
Responsibility for testing of the residential wells will be
resolved during negotiations with the PRPs and be defined further
as part of the design. These decisions will be public noticed
prior to the commencement of Remedial Action. Currently we plan
on testing the off-site wells on a quarterly basis. The
monitoring wells will be tested and the testing paid for, by the
parties implementing the final remedy. OVersight and monitoring
will be provided by the agencies if th~ PRPs implement the remedy.
Every effort will be made to disF;c;,.ine~E:: ~he sample results to
those directly concerned and th(. H~e I UiDgpartments, in a timely
manner.
A residential well monitoring program will be done as part of this
remedy. Which wells will be tested as part of this proqram. only
the ones in the direction of groundwater flow? .
In the past, residential wells have been checked in all directions
around the site, although the prime focus are those wells in the
direction of groundwater flow. The program will continue to
~itor wells in the direction of groundwater flow.
/
10.
oversight and System Monitorin;
Who is 90ing to monitor the effectiveness of the treatment system?
Concern was expressed over the notion that the person that created
this problem is going to police themselves while cleaning it up.
The persons responsible for the implementation of the treatment
system will monitor its effectiveness, in order to keep the
facility running. EPA or the state will oversee the PRP .
implementation of the .ystem, should the PRPs consent to undertake
these actions. The Agencies will also be testing periodically to
insure the effectiveness of the system and to verify the required
reporting.
How often and by what means will the effectiveness of the
treatment system be monitored? The feasibility study proposes
that the monitoring and recovery wells will be checked quarterly.
but the effluent will be checked weekly. why is that? Are the
detection limits for the monitoring 90in9 to be down far enou9h to
detect cleanup to the r~ired levels?
If an agreement is entered into with the PRPs, the Consent Decree
and attached statement of work will outline the rol.. of all
parties, and how the work will proceed. If PRP run, the
fectiveness of the system will be 8onitored by representatives
~- the agencies, by taking duplicate samples for independent
analysis.
11
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..... -_.JO,..~- -.-. - - "._--._---~~.a........'-
..........._--- -
. -" ....-.- .
.. . .. ......".
The Feasibility study was written to compare the alternatives, and
certain assumptions were made for costing purposes. During design
of the remedy, it may be determined that the sampling intervals
need to be either lengthened or shortened, depending on the
aquifer characteristics and pumping rates. Effluent checking is
to directly determine the effectiveness of the treatment and to
prevent the re-release of untreated chemicals to the environment
(whether the system is meeting the permitted discharge levels).
The 80nitoring well checks are to determine the effectiveness of
the treatment system at halting the flow of contaminated
groundwater, and to monitor the changes in the contaminant's
concentrations within the plume itself.
EPA Contract Laboratory P.rogram (CLP) prC'~"~'')ls will be used to
monitor the system. Within the CLP prcx..;':':'. ~. :,:,,..~:\n routinely and
reliably request detection limits which e.~.'~. ~.: ~. -':atection needs.
Are you at this point, able to say whether au ~n9ineer will be
overseeinq the treatment system on a 24-hour basis. an a-hour a
day basis. every day. or once a week?
The frequency of an engineer's presence in overseeing the
o treatment system has not been determined at this time, but will be
determined during the design phase of the project. It is unlikely
that an engineer will be present at all times, however.
Will there be monitoring wells near the seepage basins. and will
they be periodically tested?
It is now unlikely that seepage basins will be employed in this
remedial action (see answers to PRP comments). If seepage basins
were to be employed in this remedy, the installation and periodic
sampling of monitoring wells is a permit requirement. Although
Superfund Cleanups conducted entirely "on-site" are not required
to obtain discharge permits, the substantive limits on discharges
under State and Federal Environmental laws 8USt be met. .
11.
System Design, Operation and Maintenance
Is the water only in effect treated once?
The way the extraction system and re-introduction system is
usually designed, the re-infiltration occurs upgradient from the
extraction, 80 that after a certain residence time, the vater is
re-extracted. The residence time is designed 80 that the
re-introduced water is not immediately diluting the extracted
water, but serves to pull aore contaminants out of the ground.
How that you have a qood sense of the extent of the pluae. is
there any intention to put down any further wells near the
determined edqe as permanent 80nitorinq wells for the pluae?
Yes, aore monitoring wells need to be installed during the design
phase to 80nitor the leading edge of the pluae. By checking the
12
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.-',.. ....- ,.. ..'.
-.--..- . .- -...- '.. -... .'"
~ea between the leading edqe of the plume and the residential
wells, we can determine plume movement prior to it impacting a
potable water supply.
How often are the carbon filters and general maintenance going to
take place?
These factors will be determined during the design phase, and are
based on the flow rate through the system, the contaminant
concentrations in the water drawn through at any particular time,
the "effective life", and capacity of the particular brand of
treatment medium or equipment employed.
What is the waste activated sludge that will be the result of the
biological treatment? Is the sludge harmful?
Waste activated sludge is similar to the residue f\,'om '~'as\:~water
treatment plants. As the groundwater is cleaned, the heavier
contaminants, dead microorganisms, and naturally occurring
substances precipitate out. This heavier residue or sludge will
be tested to ascertain if it is subject to RCRA subtitle C
requirements, including the Land Disposal Restrictions (LDR).
Sludges which are impacted by these restrictions will be treated
to insure compliance with LDR Treatment Standards prior to
disposal; otherwise, it will be disposed of on-site.
~:ti~~~f:~i~a~~~t~:~~~~t~nw~~; =:t~~e~;~;~a~~~ :~~ =~;~:t:r~~.it
be disposed onsite?
The liquid phase, once taken off, will be treated as purged
groundwater, if necessary, and re-introduced to the ground.
;:~ you comment on the likelihood of a spill of effluent due to
hinery malfunction and the spill going unnoticed for an.
extended period of time.
It is standard engineering practice to incorporate manual and
automatic process controls and alaras into the design of any waste
treatment facility. While the type (or ~thod) of controls will
vary depending on the treataent process utilized, all serve the
following functions: provide continuous chemical, physical,
mechanical or biological processes; .ake auto.atic adjustments to
the process in response to feedback: and notify personnel of any
alara conditions. Some examples of these controls are: water
level sensors, low level shutoffs, chemical feed pumps with
aonitors, pump controls, dissolved oxygen .onitors, torque
limiters, flow meters, pressure gauges and autodialers. These
automatic systems, combined with site inspection and aonthly
operating reporting, minimize the likelihood of a spill or other
system .alfunction going unnoticed.
13
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-" .....,- ........ ---- -. .'. -.-. .~-'''--'-_._-
Is the air stripping going into the atmosphere. and what effect
does that have on persons downwind?
During the design of the treatment system, it will be determined
if the air stripper will potentially discharge substances to the
atmosphere which would be harmful to the public. Although carbon
adsorption is listed as part of the water treatment process,
another form of cafbon adsorption can be added on the system to
extract contaminants out of the vapor phase discharge of the air
stripping, and prevent significant air releases. Any remedy
chosen will have to comply with the substantive requirements of
State air pollution laws and regulations which limit the discharge
of contaminants to the air.
12.
Other Comments and Ouestions
Is the primary concern from the sites for humans?
concern for wildlife in the ecosystem?
Is ther6 else a
Site investigations and cleanups are concerned with both public
health, and the environment (which includes wildlife) equally. By
addressing the concerns for public health at the Spiegelberg site,
we ate also addressing the environmental concerns. .
Has any study been done on animal life as to any harm or residual
contaminants may be in the flesh of deer. pheasant or whatever
animals may be in the area. Rabbits and squirrels are legal to
hunt there. but pheasant are not. Is it possible to have these
studies done if they have not been conducted?
No studies on animal life have been done, to date. We contacted a
United States Fish and Wildlife Service Toxicologist, and he
indicated that the likelihood of having contaminants in the area's
wildlife, from the Spiegelberg site is small. He stated that
since the contaminants were sub-surface, and since there was no
real habitat in the immediate vicinity of the former paint sludge.
area, to attract resident wildlife, the squirrels, deer, etc. may
pass through but would not feed or nest in the areas of concern.
Additionally, the Toxicoloqist offered that any cleanup which was
to be completed based on concern for human health effects, would
address any concerns for future use of the area by wildlife.
Do you think that companies within Livingston County and Green Oak
Township are 90in9 to ;et to bid on implementation of this plan.
80 that we have people we know who are monitorin; our wells and
who are desiqninq a system? .
-
If the State or Federal Governments conduct the remedial actions,
they have priaary contractors already under contract who are
pre-qualified. Much of the subcontracting work is bid out. When
this remedy is sent out for bids, regardless of who implements the
remedy, any pre-qua1ified contractor may place a bid for the work.
If there are pre-qualified remedial action or treatment design
engineering firms who submit favorable bids from this iaaediate
area, then they may be selected to do the work.
14
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- . - '.~"":I". ..
)0 you know if there are any significant stYdies that qive
i~f~~ati~n about accumulated effects of toxic waste? Is this
theoretical or are we able to predict the true effects?
Many studies have been conducted to determine the combined effects
of chemicals and the results of their accumulation. A vast body
of literature exists which documents these studies. However, due
to the extensive list of contaminants, the different species of
fauna that may be impacted, differing environmental factors, and
many other -unknowns", the science has only begun to define these
effects. The best that toxicologists can theoretically model at
this point, is to take a conservative approach, and to assume that
the combined effect of the chemicals is additive.
;~:p~::e~~ ~~ec~~rPo~~~c~~~e~~~ ~~~Ct~~ ~i:~~f:~~e~a~~litY
c;ite~ia Document's toxicity level for supporting a healthy
~:~~~ :~:t:~te :~~c~h~o~~~~n~~ue:;:~~~S;o~~~i~~e~~c~~~~i~:ness
a~~t it? Is it feasible that the substances ~ot there from
movement of soil or through the air?
There are certain amounts of metals naturally occurring in the
environment. Although they are present in soils, one reason that
they showed up with such prevalence in the bog 1s due to the
-acidic nature of this .icro-environment. The natural acidity of
the bog water will cause the metals to be released in higher
'quantities from the soil, and become more pronounced in the water
samples. The AWQC Criteria, and the "healthy aquatic system" used
as a measure of toxicity are geared towards larger ponds, lakes
and running waters which normally support fish and bottom dwelling
macroinvertebrates. Bogs do support healthy aquatic life if
undisturbed, but support a set of plants and animals suited to the
aore acidic environments.
Is the rest of the Spiegelberq site still open for further work
and remediation if necessary?
No further work is necessary beyond what has been done to
remediate soils, and what i8 proposed to be done with groundwater
remediation. .
r~1'\ts Received in lfri~ift9
Comments were received in writing from 8 separate parties. As
stated before, the majority of these comments were in support of
the preferred alternative, and urged a swift implem~ntation. The
following were comments which require response.
15
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.,~....,.._-----_. -- ~
-------
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- -
...........-..--- '--- ......-..-.---...------:.-...-- --".- :..:~-..: .:.'- .... - .
. .
~roperty, and the property has been brought back to its
pre-dumping grade. The property is operated as a sand and gravel
mining operation. Restoration of the site to its pre-mining grade
is not within the purview of the program. Groundwater
contamination will be remediated based on the Proposed Plan and
the incorporation of public comment. Carcinogens will be treated
to a level that is compatible with what can be detected, and at
the same time, is protective of public health and the environment.
Off-site well sampling, to insure the integrity of residential
water supplies, will be conducted on a regular basis and, at
least, until the groundwater contamination has been remediated.
It is difficult to speculate at this poi~t as to the future use
and ownership of the property.
PRP Comments
The PRPs have submitted comments through two avenues: 1) letter
from counsel, and 2) through their technical consultants and
included in two volumes entitled "Evaluation and Development of
Groundwater Cleanup Levels" and "Technical Evaluation of RI/FS and
Proposed Plan". .
The proposed plan description of the recommended Remedial Action
Alternative suggests that a number of design specific technolo9ies
may be specified in the Record of Decision {"ROD"}. We do not
alieve it is appropriate to identify any specific treatment
wechnologies or process options in the ROD. These details are not
typically finalized until the design phase.
EPA Headquarters guidance entitled "Preparing standard Superfund
Records of Decision" outlines the format for writing RODs. The
guidance instructs the writer to "Enter the major components of
the selected remedy in bullet format". Such instructions to
include detail can be found on pages 2, 4, and 15. OSWER
Directives 9283.1-2, December 1988 and OSWER Directive 9283.1-2
FS, April 1989 illustrate the level of detail appropriate for the .
ROD.
RI investigations did not proceed outwards from the known source
area to define the lateral extent of the affected 9roundwater.
The PRP comments that the chronologie order of the .onitorin9 well
installations is Rinefficient". that its phasin9 with the test
pittin9 was out of se~ence. and that the chemicals of concern
could have been established at that tiae.
Only a portion of the wells used in the RI were installed in Phase
I before the test pits were excavated. The phase I vella were
intended to generally define the extent of contamination located
downqradient of suspected source areas and to further define the
site hydrogeology. Data from the test pitting aay not bave
influenced the Phase I well locations even if available at the
i.e of their installation. The test pits ..y have provided
~hemical data useful for determining compounds of concern.
However, the U.S.EPA and the MOHR have typically requested
17
-------
.. :6_~-'=:"::':'.-:"'6_~'.__'------".1~ .~.,--= -"'~;";;;'.;...:.;.,.._---;~_":":":'_~_.._-~.-~":'::".:..;.I.....';:"';";"~~..;.,--.....:. _..
Hazardous Substance List scans for initial phases of
investigations to detect all compounds of concern, using available
technoloqy.
It is acknowledged that soil gas testing is a valuable tool for
delineating affected groundwater zones. However, this type of
investigation typically follows the installation of wells and
preli.inary identification of chemicals in groundwater. not
before.
50il gas testing is an investigative geophysical/geochemical tool
used to qualitatively delineate groundwater and soil contamination
This investigative procedure may be used to place monitoring
wells, soil borings, or locate source areas. The State and their
contractor used soil gas surveys for all three purposes, to aid in
. ~he locations of borings and monitoring wells during Phase 4 .
drilling, and to delineate possible source areas such as that
located in the Spiegelberg "Pit Area". The PRP's suggestion of
describing soil gas testing after well installation for
preli.inary identification of chemicals .ay also be suitable for
some site investigations. This preference does not preclude the
Agencies' use of a soil gas survey prior to Phases 2, 3, and 4
. well installation. The soil gas studies conducted at the
Spiegelberg site, and field methodologies used, were prudent and
justified. .
The RI report is generally lacking in detail regarding the
descriptions of the field programs and the procedures which
followed. These details are typically incorporated into
appendices in an RI.
were
Specific detail for site investigations may not be located in the
RI, although some technical memoranda are included in the
Appendices. The Rdetailed information required to conduct a
comprehensive verification of the RI findings" does not appear as
part of the RI but is available as part of the site's overall
record, since it is as the PRP describes--detailed.
The RI interpreted the qroundwater flow patterns in the upper
aquifer as being to the northwest of the paint sludge disposal
area. The detailed review determined that qroundwater flow in the
upper aquifer 1s to the west in this area. Although the error in
the qroundwater flow pattern will not affect the final remedial
action alternative selection process. it will definitely i.pact
the final desiqn and remediation costs.
It i. true that the qroundwater generally flows to the northwest
in the upper aquifer, and it is also true that there .ay be a
westerly component of qroundwater flow in the vicinity of the
former paint sludge area. It is bowever, an overstate.ent to call
the agencies' characterization of the qroundwater an RerrorR.
Final design, with its associated -design studies" are a necessity
in any instance, and added costs are debatable.
18
-------
-..
...... .. '--"'.':':.;"':':', ''''----'':'-----'''- ~;"1~"--;";:--"'-- -. ". ..;-------_._~.::-_::""-.-....-~~...~-_._.--_...~=--'.-_. '''''
. .
~he RI concluded that the upper and lower aquifers merge to the
west of the paint sludge disposal area. The detailed review
determined that the upper and lower aquifers do not merge except
in a limited area immediately west of the former paint sludge
,area. Detailed comment on the geologic interpretation attempts to
1} play down the usefulness of the gamma 109S. 2) discuss
discontinuity/continuity based on color variations in
stratigraphic layers. and 3} use water level measurements to
discredit the RI contention of discontinuity.
Upon further review of the available body of information, the
Agencies feel that the contractor (NUS) was conservative in their
estimation of the extent of the discontinuity of the clay, in the
.f!:.:' -:'~".:"~' of the Remedial Investigation Report which describe the
'. :.::' ~.~ "~ : . ,'. ogeoloqy (Section 5.1.1), the extent of the groundwater
!:',~~' ~. , . .10n (5.2.1), and the "Contour Map of the Top of the
(;,:...r.:. ..ug Layer" (Figure 5-3). Boring logs for OBG-3B, OBG-4B,
and OBG-5B appear to show that the discontinuity may be aore
widespread in comparison to the NUS estimation of the extent of
the confining layer.
Gamma logs are useful for determining lithologies, especially at
sites where heterogeneous glacial deposits are found. They may
detect the presence of clay layers "missed" by drilling
techniques. Large clasts in coarse or fine-grained till deposits
ay prohibit split~spoon sampling; slough or heave into a borehole
~ay provide a non-representative sample of the formation;
cementing of deposits may also limit sampling capabilities.
Borehole geophysics should be used in connection with physical
drilling logs to provide the most accurate description of site
geology.
The color of clay may not be an indication of its (dis)continuity
across a geologic section. A clay layer with different colors
from different boreholes .ay be stratigraphically equivalent. The
color of a clay is a function of its depositional environment and.
current environment. Evidence exists in drilling logs for
SP-MW-13, SP-MW-40, and SP-MW-53 that the color of a continuous
clay layer changes vertically as veIl as horizontally. The
clastic content of the wells designated by the PRP as "westerly
wells" are also a function of depositional environment and aay not
be used as a criteria to discount the stratigraphic equivalency of
clay detected in different boreholes.
It is recognized that head differences exist for the shallow/deep
well pairs at OBG-4A/4B, OBG-5A/SB, and SP-MW-51/51A~ However,
the 9a..a logs, the drilling logs, and chemical data do not
support the contention that a continuous clay/confining layer
exists beneath the former paint sludge area.
19
-------
"'. -..;;:.---~.,;:;--.r------'---""'---- ----. '-.'
The RI concluded that the clay layer between the upper and lower
a~ifers does not exist below the paint sludge disposal area. The
detailed review determined that this finding could not be
substantiated.
Unless a substantial depression exists in the confining layer
beneath the former paint sludge disposal area, the Agencies'
interpretation is correct.
The RI indicated that the groundwater plume has migrated beyond
SP-MW-52. The results of the groundwater sampling conducted in
February/MarCh of 1990 have determined that this interpretation of
the areal extent and location of the affected groundwater zone is
incorrect. L
Altho~~. "'t.. - j"o . dd" maps of the Spiegelberg groundwater plume
indicate t:i1at the plume has extended beyond SP-MW-52 to the west,
RI data does not indicate that this is a fact.
To clearly inform the public that the source remediation has been
completed. an addendum should be prepared to the RI reflectinq
remedial work which has been completed to date by Ford and
MDNR/USEPA.
The Administrative Record contains ample evidence that the source
remediation took place. The source remediation is mentioned
starting with Chapter 8 of the Feasibility Study, and is noted in
the Proposed Plan, the Fact Sheet, several newsletters, and
updates to the progress of the removal were posted on a signboard
on Spicer Road. The final report of these activities, submitted
by the PRPs, will become part of the public record.
The reference to the affected sector of the Spiegelberg propertv
should be changed from northeast to northwest.
The affected sector of the Spiegelberg property should be the
northwest.
~~;~~~i~ ~ntioned. there is n~ discussion of the well
t ~ns nor of the samp~ng proqrams that took-g}ace tn
1981. .
An RI report does not necessarily need to include previous
documents within its own text. References to a document can be
sufficient to direct a reviewer of the RI to the document's
location.
20
-------
. ' . _.' ..--..-..--....--------.--.-- -
ae concentrations of methylene chloride in both laboratory and
field blanks were on many occasions equivalent or 9reater than
those observed in the actual groundwater samples. The RI
indicated the positive detection of several chemicals in the
affected 9roundwater zone which are typical field or laboratory
artifacts. The results of the 9roundwater sampling conducted in
February/March of 1990 do not substantiate the presence of these
compounds in the groundwater.
Upon review of the data, the agencies have determined that the
methylene chloride previously determined to be present in sample
analyses of the spiegelberg groundwater, cannot be confirmed with
any degree of reliability. It is true that the concentrations
found in the laboratory blanks were comparable to those found in
the groundwater s_~~les. Unless confirmed in future sampling
rounds, 'methylc..e ,;:..lo~.j,oe will not be considered a chemical of
concern for the Spiegelberg groundwater plume remediation.
Groundwater flow systems beneath the site are dynamic, and
fluctuations can be expected in contaminants and detected levels
in each well. The fluctuations may be resolved by future sampling
prior to the design phase.
Problems with the FS include 1) a lack of technical support to
justify eltmjnation of specific alternatives which may be very'
viable at the site. and 2) a lack of detailed costs to carry out
n accurate cost evaluation of remedial alternatives.
The agencies feel that the decisions made in the Feasibility study
regarding the screening of remedies and cost evaluations were well
documented, thought out, and justified.
Great detail is provided for the reevaluation of the method for
re-introducing treated water to the 9round. The PRP provides
technical and financial justification for reconsidering injection
wells versus the seepage laqoons proposed ~y the aqency.
The agencies initially included the option of seepage lagoons
versus injection wells because the lagoons offered a better means
of flushing residual 80il contamination out of the soil profile
and into the extraction veIls. Soil contamination was excavated
to the groundwater table during the source remediation. The PRPs
have provided adequate detail to show that injection wells are
.ore cost effective, and will still achieve the overall 90al of
protecting human health and the environaent. In light of these
facts, the agencies will now propose injection wells located
strategically and screened at the proper depth, to facilitate
flushing of contaminants that remain in the soil ben.ath the
groundwater table, as the re-introduction portion of the .elected
alternative.
\nother consideration in favor of the extraction vells is the
ttractive nuisance characteristic of the seepage lagoons.
Injection wells take up less space and require less equip.ent and
21
-------
- 4 _.- ----- --<,<-.--Z'.._i ........ -----..
res~urces devoted to protecting persons from coming in contact
(inadvertently or otherwise) with the equipment.
~: :~~u~~::~~;Sp~~m;h:e;~~:t~~nt~; ~~:n:~;~~~~~o~d;:l~~ ~;hin
plume..
The location of the extraction wells is open for determination
during the design phase of remedy implementation.
~~~ ~~~ ~O~;h~ ~our methods of treatment. identified has not been
e _e e n the data currently avallable. The only
~le;;iy d;mo~~trated treatment requirement is the air strippin9
unit. The other three pT-~cesses will ultimately impact the
operation of the treatme.!lt f~~r.~.lity. but will not impact the
treatment standards reqr":J ~:~._.~~..be achieved.
'.
Whether the specific processes are necessary depends on which data
sets are viewed. Past MDNR/USEPA data shows that all of the
proposed processes are needed to treat the groundwater
contamination. Recent PRP sampling shows otherwise.' The agencies
feel that all of the processes proposed may be necessary until
treatability studies are concluded. studies may indicate a
difference in the chemicals in question, and thus, the need for
all of the treatment processes. It may be true that one or aore
of the processes are required to facilitate the operation of other
treatment processes, but that does not preclude their mention as
necessary components of the system.
~~~i~~~:~g of the residential wells downaradient of the site is
~~~ ~;~~~~a~ ~s la~; ~; t~~ l~~~-term monitoring program since
~~i :~i~"tW;-~~~d~;t;~ ~ ched these wells. Monitoring the
w~~:g ;~ ;~t ;;th;~-: ~I~~~itY of the treatment system will be
:;iisPp~~;id~ an earlyOWarni~~90~~u~~;~e~~~~;t~~~~s since these
The agencies feel that a combination of early warning and
residential well sampling is necessary to insure that public
health is not compromised.
:;~~~:~~~a~~D1i~~t~:~~rb:=~n~~ i~,::;~~;ia~a~ai:.~~~e~~~s'
~~~~i~hl~;~th:n; ~h~uid be classified as a non-carcino;en. Upon
i~~~ic~~~~~:~~~~~a~~~n~ ~:t~~~~:~t:~i~~e~ ~e~=it;~ra to be
140 ppb.
The agencies acknowledge that their characterization-of
1,1-dichloroethane as a carcinogen was incorrect. Based on our
calculations of the Human Lifecycle Safe concentration for
1,1-dichloroethane, the cleanup level should be 700 ppb. Since
this cleanup level of 700 ppb is above what bad been detected in
the groundwater during the Remedial Investigation (maxi.um of 170
ppb), 1,1-diChloroethane is not listed in the Record of Decision
22
-------
. ..:-:.. . -.--...---. --.. .:":~.:....:.
. ~~..::.~:.:'''_."'. ...-~ -.... ...--. ......-----
. ........ ~.._.. -.---- -- ---- .
~s a chemical of concern. Should subsequent design studies show
that this chemical is of concern, the cleanup level for this non-
carcinogen will be set at 700 ppb.
Wit~ ~espect to ~a~t we believe that this parameter was incorrectly
idedt~~ied as ~e~ ~-;~~ ~ieanup because backaround concentrations of
t:~ t~ }~e S~:~_~_b t; tee However. if lead is included as a
l~~e~ ~.~anu~ yaiame_-~. a ~e A cleanup level of 159 Dcb
__--k_r_und) shou_d be _sed. _lternately the MCL for lead is 50 pcb.
The agencies stand behind their proposed cleanup standard for lead
of 5.0 ppb, the calculated Human Lifecycle Safe Concentration level.
Alternately, the Agencies' will consider a groundwater cleanup level
for lead, which is consistent with Type A of the Act 307 Rules. This
approach would use levels from filtered groundwater samples, to be
taken from background wells during the remedial design phase of the
project. The rationale for the consideration of background levels is
based on WRC R323.2205(1) ** which provides for the nondegradation
from background water quality in usable aquifers.
2)
3)
3)
4)
The Agencies find unacceptable, the use of MCLs in deriving cleanup
levels for carcinogens, as the level of risk associated with these
numbers is 2 to over 4 times greater than what is considered
protective, yet achievable. MCLs were developed for municipal water
8upplies and factor in issues inappropriate for the cleanup of
contaminated groundwater.
The primary difference between the MDL and the PQL i. that the MDL
is a detection limit. and the POL is a auantitation limit. The
.. A. the r...dy requlr.. r.lnj.ctlon of the ,roundwater Into the equlf.r .ft.r cl..nl"" the Itete h.. el.o
~tlfled Act 245, which requlr.. ...tlng .peclfled level. prior to dl.char,e, .. an appllc.ble AlAR. The
.ed State. dlaa,re.a that Act 245, .. Interpreted and applied by the It.te In thl. ..tter, I. .n ARAR. Thi.
I..U' I. the .ubject of lltllatlon In U.S. v. Akzo Coetlnaa of A.erlc., appell.t. ca.e nu8ber. 89-2902 and 89-
2137, and ..y be rea.....ed .fter . decl.lon ha. been rendered. The St.te concur. with the r...dy .elect.d,
and ha. .t.ted that In applying Act 307', requlr...nt. to the tr.ated ,roundw.ter for reinjection to the
.qulfer, the r...dy .elected will ..tl.fy the requlr...nt. of Act 245.
23
-------
. .._~ ."".. -.., '-- .....
-.....---'
..... -c..-,-_.. -'-~.-:. --..-'::
, ----~_.' c-::z.::~...-----,*- ----,'-.....'''~ ~.'~..-.....__.. .. --- .
detection limit is ft measure of when an analytical system
indicates that a substance is present above a certain limit, there
is a 99 percent probability that the substance is present, but not
necessarily at the reported level. The PQL is established at a
level above the MDL where quantitative certainty is higher. PQL
is the lowest level that can be reliably achieved within specified
li.its of precision and accuracy during routine laboratory
operating conditions. u.s. EPA developed the PQL concept to
define a measurement concentration that is time and laboratory
independent for regulatory purposes. The U.S. EPA estimates that
the PQLs are 5 to 10 times higher than the MDLs.
The use of MDLs are more appropriate than POLs as a lower
detection limit on target cleanup levels because:
MDLs are more appropriate becau~~ 0: h.~~ ,(>
-------
-...---.- .
-:- ....:..-:.:;...-..;.. ~.",. . "
.. .."~"-_. --"""~._'_"::~..._----,_.---,----,-,:-.,,,: .. .._:...:""....-...","'-..... -......- -------...
'&J
.
cleanup levels for benzene initially noted in the Proposed Plan,
and formalized in the ROD, and the MDL of 0.5 ppb now required for
vinyl chloride, are required for protection of public health and
the environment. Both u.s. EPA and MDNR feel that the cleanup
levels can be achieved through the use of the chosen alternative.
It is not appropriate to argue that the remedy will incur qreater
costs than a remedy which would not achieve the goal of
protectiveness.
-Although the proposed Michigan Act 307 Rules have not yet become
effective. the Proposed Plan in most cases selects qroundwater
cleanup levels consistent with the TYPe B approach of the proposed
307 Rules. In anticipation of the finalization of these rules. the
comments presented herein include an analvsis of the appropriate
groundwater cleanup levels as contemplated by the proposed 307
Rules."
The cleanup levels listed in the ROD are consistent with the Act
307 Rules. They are also consistent with the National oil and
Hazardous Substances Pollution Contingency Plan (NCP) section
300.430(e), Michigan Act 245 P.A. 1929, as amended, and Water
Resources Commission General Rules, Part 22.** Except for the
changes noted above for methylene chloride, l,l-dichloroethane, and
lead, and the deletion of acetone, 4-methyl-2-pentanone,
ethylbenzene, and l,l,l-trichloroethane as chemicals of concern,
the remaining ten cleanup levels set forth in the attached ROD, are
the same as the levels outlined on page 5 of the Spiegelberg Site
Proposed Plan (issued on January 16, 1990).
The PRP suqqests that their recommended cleanup levels should be
applied and evaluated at the extraction svstem.
Exactly what is meant by this statement is obscure, as there are
many points in a treatment system where levels can be evaluated.
Cleanup compliance must be measured in the effluent to determine
the efficacy of the system at meeting the cleanup levels, and at.
the influent and other monitoring wells in the plume to determine
if the levels of contamination in the aquifer have declined to the
cleanup levels, so that the system may be turned off.
REMAINING CONCERNS
What follows is a summary list of outstanding concerns which will
be addressed during negotiations, remedial design, and/or remedial
action: * Treatment Duration
* Well Destruction
* Site Access
* System Design, Maintenance, and Monitoring
* Residential and Monitoring Well Sampling Plan
* OVersight
* Future PRP Involvement
* Background Lead Determination
A. the r...dy require. reinjection of the .r~ater into the equlfer .fter cleanint, the State ha. al.o
,dentlfied Act 245, which require. ..eting .peclfl.d level. prior to dl.ch.rge, .. an appllc.ble AlAR. The
United St.te. dl.agree. th.t Act 245, .. interpreted .nd .pplled by the St.te In thl. ..tter, i. .n AlAR.
Thi. i..ue i. the .ubject of litigation in U.S. v. Akzo to.tlna. of A.erlc., .ppell.te c..e nu8ber. 89-2902
'nd 89-2137, .nd ..y be re...e..ed .fter . decl.lon h.. been rendered. The St.te concur. Mlth the r...dy
.elected, .nd h.. .t.ted th.t in .pplying Act 307'. requlr...nt. to the tre.ted gr~.ter for reinjection
to the aquifer, the r...dy .elected Mill ..tl.fy the requlr...nt. of Act 245.
25
-------
....~ ... '.......--.--.->.... - -'--...- '.
AT'l'ACHNEIIT
..- .~~--.-.~- .
The community relations activities conducted at the Spiegelberg
site to date are listed below. A key to abbreviations follows.
DATE OF ACTIVITY
1960's
March 5, 1981
February 1983
February 14, 1983
February 25, 1983
March 1983
April 1983
May 1983
July 29, 1983
September 12, 1983
October 17, 1983
December 19, 1983
January 6, 1984
January 23, 1984
March 12, 1984
April 23, 1984
April 24, 1984
May 24, 1984
June 1984
June 7, 1984
June 29, 1984
TYPE OF ACTIVITY
Citizens Report Complaints
Dumping and Burning
Citizen Complaint
Triggers Action
PIRGIM Meeting
PIRGIM Letter to MDNR
Meeting
Citizen's Letter to TSCC
Public Meeting
Citizens ACTION Formed
Task Force Meeting
Task Force Meeting
Newsletter 11
Task Force Meeting
Task Force Meeting
Monthly Info. Bull. 11
CIC Meeting
Info Sent to Task Force
Monthly Info. Bull. 12
Newsletter 12
Information Repositories
Opened
CIC Meeting
Newsletter 13
26
PARTICIPANTS
Citizens, MDPH,
LCHD
Citizens, LCHD
Citizens, PIRGIM
PIRGIM, MDNR
PIRGIM, Citizens,
MDNR , LC:\i:"1
CitizenF-!, TSCt:
SCARE, IIDPH
All Interested
LCHD, MDA, MDNR,
Citizens, Twp.,
MDPH, TSCC,
Senator, Reps.,
Reps., Senator,
LeHD, Citizens,
Commission.,
MDPH, MDNR
U.S.EPA, MDNR
Reps., Senator,
Commission.,
Twp., LCHD,
citizens, TSCC,
MDPH, U.S.EPA
LeHD, Citizens,
commission. ,
senator, U.S.EPA,
MDNR
MDNR
Citizens, LeHD,
U of H, MDNR,
Commission.,
U.S.EPA, MDPH,
Twp., TSCC, Reps.
MDNR
MOHR
U.S. BPI., MOHR
U.S.EPA, MOHR
citizens, IIDNR,
TSCC, '1'Vp., MOPH,
LCHD, Senator,
U.S.BPA
U.S. BPI., MOHR
-------
. -.. -----
.
..
, .
(attachment continued)
DATE OF ACTIVITY
July 17, 1984
TYPE OF ACTIVITY
CIC Meeting
July 19, 1984 Public Info Meeting
Auqust 31, 1984 Monthly Info Bull. 13
September 27, 1984 CIC Meeting
October 11, 1984 Special Notice
october 25, 1984 Issuance of community
Relations Plan
October 30, 1984 Community Toxicology
Presentation
November 3, 1984 Newsletter 14
November 9, 1984 CIC Meeting
November 27, 1984 Newsletter 15
December 3, 1984 CIC Meeting
January 7, 1985
January 24, 1985
January 30, 1985
February 4, 1985
March 29, 1985
April 1, 1985
May 31, 1985
July 1, 1985
September 13, 1985
December 5, 1985
December 10, 1985
July 24, 1986
September 8, 1986
september 15, 1986
Auqust 7, 1987
November 3, 1987
CIC Meeting
CIC Effectiveness Survey
Newsletter 16
CIC Meeting
Newsletter 17
CIC Meeting
Newsletter 18
CIC Meeting
Newsletter 19
Newsletter 110
CIC Meeting
Newsletter 111
Progress Report
Public Meeting on PFS
Newsletter 112
Newsletter 113
27
PARTICIPANTS
LCHD, Citizens
MDHR, WQB, Twp.,
Commission. ,
Hamburg Twp.
U.S.EPA, MONR,
LCHD, Citizens,
NUS, Fire Dept.
MOHR
MOHR, LCHD,
Citizens, TSCC
U.S.EPA, MOHR
U.S.EPA, MOHR
MDHR, U.S.EPA,
MSU
u.s. EPA, MOHR
LCHD, SEMCOG,
MDHR, Citizens,
Twp.
U.S.EPA, KDNR
LCHD, Citizens,
Twp., MDHR, NUS,
Media, U.S.EPA,
TSCC .
Citizens, LCHD,
MDHR, U.S.EPA,
Twp.
U of M, KDHR
U.S.EPA, MDHR
KDHR, Citizens,
TSCC, KDPH, Twp.,
LCHD, NUS
U.S.EPA, MDHR
Citizens, MOHR,
TSCC, LCHD, KDPH,
Twp., Commission.
U.S.EPA, MOHR
Citizens, MOHR,
Twp., LCHD, MOPH
U.S.EPA, MOHR
U.S.EPA, MOHR
LCHD, MOHR, Twp.,
Citizens, MOPH,
NUS, Pire Dept,
U.S.EPA
U.S.EPA,
U.S.EPA,
U.S.EPA,
U.S.EPA,
U.S.EPA,
MOHR
MOHR
MOHR
MOHR
MOHR
-------
'"-_.'-
.
~
t.
-~~'..'.:.:
-"'-...~::'~.:;;':":-"";"--_.<----- -,_:'-''''''''::''"'';'"~~.:A"_-r.~~.....'I.a.-.... .-..,-....................,..... -
(attachment c.ontinued)
DATE OF ACTIVITY
November
November
June 16,
June 27,
Auqust 1989
Auqust 21, 1989
Auqust 22, 1989
9, 1988
14, 1988
1989
1989
october 30, 1989
January 16, 1990
January 16, 1990
February 8, 1990
March 19, 1990
TYPE OF ACTIVITY
Newsletter 114
CIC Meeting
Newsletter 115
Public Meeting
PARTICIPANTS
U.S.EPA, MDHR
U.S.EPA, MDHR
U.S.EPA, MDHR
U.S.EPA, MOHR
Citizens, LeHD,
Twp., PRP Rep.
MDHR
U.S.EPA, MDHR
MDHR
on Removal
Establish Local Call-in
Newsletter 116
Information Board Put Up
Information Posted At Least
Weekly for Active Period
Newsletter 117
Proposed Plan Sent out
PCP Open
Fact Sheet Sent out
Public Meeting on Proposed
Plan and FS
U.S.EPA, MDHR
U.S. EPA, MDHR
U.S.EPA, MDHR
Citizens, LeHD,
MDNR, U.S.EPA,
Twp., PRP Rep.
U.S.EPA, MDHR
PCP Closed
The items listed above, if not in the Administrative Record, can
be found as part of the Michigan Department of Natural Resources,
Environmental Response Division, Superfund Section's Files. In
addition, numerous correspondences with individual citizens and
PRPs are contained. in the records. As part of the community
relations efforts, numerous Freedom of Information Act requests
were filled, and the Information Repository received updated
information when available.
Key to Abbreviations for Attachment
citizens
Commission
Fire Dept.
Hamburg Twp.
LCHD
MDA
MDNR
MDPH
Media
IISU
NUS
PIRGIM
PRP Rep.
Reps.
SCARE
SEMCOG
Senator
TSCC
- Local Citizenry
- Commissioner's Office
- Township Fire Department
- Hamburg Township Representative
- Livingston County Health Department
- Michigan Department of Agriculture
- Michigan Department of Matural Resources
- Michigan Department of Public Health
- Media Representatives
- Michigan State University
- State Contractor NUS Corporation
- Public Interest Research Group of Michigan
- Representative of Potentially Responsible Parties
- State Representative's Office
- Safe, Clean and Revitalized Environment (Group)
- South(B)ast Michigan Council of Governaents
- Representative of Senator'. Office
- Toxic Substance Control Commission
28
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U.S.EPA
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- Green Oak Township Representative
- University of Michigan
- United states Environmental Protection Agency
- Water Quality Board
29
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NAT1MAl RnOUItCeI CO Ul "ION
THOMAS J. ANOERSON
MARLENE J. FLUHARTY
GORDON E. GUYER
KERRY KAMMER
ELLWOOD A. MATTSON
O. STEWART MYERS
RAYMOND POUPORE
STATE OF MICHIGAN
11
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~~ ~~~
..
JAMES J. BLANCHARD. Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON BUILDING
P.O. BOX 30028
LANSING. MI 48909
DAVID F. HALES. Director
O. W.M 0
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W~ $1- /a Ke..
June 29, 1990
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Mr. Valdas Adamkus, Regional Administrator
U.S. Environmental Protection Agency
Region V, SRA-14
230 South Dearborn Street
Chicago, Illinois 60604
J U Ii? '-'c'''1
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OFFICE Cf i.__.-
..........n~JR
Dear Mr. Adamkus:
The Michigan Department of Natural Resources (MDNR) , on behalf of the State of
Michigan has reviewed the Record of Decision (ROD) for the Spiegelberg Dump
groundwater remedial action and the proposed remedy contained in that ROD.
Michigan concurs with the remedy proposed in the ROD consisting of
groundwater extraction and treatment, reinjection of treated groundwater via
injection wells, deed restrictions to provide for the integrity of the remedy,
and monitoring of groundwater and residential wells in the area.
The State also concurs with the analysis of legally applicable or relevant and
appropriate requirements (ARARs) contained in Table 7 of the ROD with respect
to those ARARs identified in that table. The State does not concur with the
omission from that table of the Michigan Water Resources Commission Act 245,
PA 1929, MCL 323.6(a) and the associated Part 22 Administrative Rules, MAC
R.323.2201 et seQ. The State has previously identified these requirements as
ARARS for the remedial action being selected for this site.
The Water Resources Commission Act and The Part 22 Rules are ARARs for this
remedial action for. two reasons. First, hazardous substances in the aquifer
beneath the site are migrating to degrade previously uncontaminated
groundwater. Second, one element of the selected remedial action is discharge
of purged, treated water back into the groundwater through reinjection wells.
It is the Department's judgement that the selected remedial action for this
site will provide for attainment of all ARARs including the Michigan Water
Resources Commission Act and Part 22 Rules. The remedial action will halt the
migration of contaminated groundwater and restore the aquifer to a usable
condition. In addition, the purged water will be treated prior to reinjection
and then hydraulically contained on-site by the purge wells in a manner that
will prevent degradation of groundwater quality, consistent with the Water
Resources Commission Act and Part 22 Rules.
R1026
3/89
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Mr. Valdas Adamkus
-2-
June 29, 1990
We are pleased to be partners with you in selecting this remedy and look
forward to working together to accomplish the final remedy at this site.
Sincerely,
lid- ~~
Delbert Rector
Deputy Director
517-373-7917
cc:
Mr. Jon Dikinis, US EPA
Ms. Peg Andrews, US EPA, ORC
Mr. Jon Peterson, US EPA
Mr. Robert Reichel, AG
Mr. William Bradford, MDNR
Ms. Claudia Kerbawy, MDNR
Ms. Denise Gruben, MDNR
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