United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-90/135
September 1990
SEPA
Superfund
Record of Decision:
Ott/Story/Cordova, Ml
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50272-101
REPORT DOCUMENTATION i. REPORT NO. z.
PAGE EPA/ROD/R05-90/135
4. TMeandSubtMe
SUPERFUND RECORD OF DECISION
Ott /Story/Cordova/Chemical, MI
Second Remedial Action - Final
7. Authorfa)
». Performing Organization Name and Addm*
12. Sponsoring Organization Nun* and Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession Mo.
5. Report Date
09/29/90
6.
8. Performing Organization Rapt No.
10. Pro|»ct/Ta*k/Work UnH No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Typ> of Raport ft Period Covered
800/000
14.'
15. Supplementary Not**
16. Abstract (Limit: 200 worda)
The Ott/Story/Cordova Chemical site is a former specialty chemical manufacturing
facility in Dalton Township, Muskegon County, Michigan. The site is at the headwaters
of a small, unnamed tributary of Little Bear Creek, which flows southeast of the site
approximately one-half mile away to Muskegon River, three miles to the south. The site
operated from 1957 to 1985 under a series of owners. Chemical products manufactured
onsite included intermediate items used in manufacturing Pharmaceuticals, dyestuffs,
agricultural chemicals, diisocyanates, and herbicides. For at least ten years,
production vessel clean-out wastes and wastewaters were discharged to onsite unlined
lagoons and allowed to dissipate into soil. In subsequent years, wastes were also
drummed and stored onsite. In the early 1960s, the State noted signs of water and soil
contamination. Site owners attempted to manage the ground water contaminant plumes
emanating from the site, but the effectiveness of these measures was uncertain. In
1977, the State negotiated with a new site owner to remove several thousand drums,
thousands of cubic yards of lagoon sludge, and to destroy or to neutralize phosgene gas
left onsite. In 1982, an alternate water supply was undertaken and financed in part by
(See Attached Page)
wi
17. Document Analysis a. Descriptor*
Record of Decision - Ott/Story/Cordova/Chemical,
Second Remedial Action - Final
Contaminated Media: gw
Key Contaminants: VOCs (-benzene, PCE, TCE, toluene, xylenes), other organics
(pesticides), metals (arsenic)
b. Menflflers/Open-Ended Term*
c. COSAT1 FMd/Group
18. AvdlaMlty Statement
19. Security Claaa (This Report)
None
20. Security Class (This Page)
None
21. No. of Page*
94
22. Price
(See ANSI-Z39.18)
SM Instruction* on Rtnnt
OPTIONAL rORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R05-90/145
Ott/Story/Cordova/Chemical, WI
Second Remedial Action - Final
Abstract (Continued)
the State and a former owner. A Record of Decision (ROD), signed in 1989 and reaffirmed
in 1990 after additional public comment, addressed Operable Unit 1 (OU1) , the
contamination of the nearby Little Bear Creek system. This ROD addresses aquifer
restoration. A subsequent ROD will address remaining threats posed by the contaminated
soil areas at the site. The primary contaminants of concern affecting the ground water
are VOCs including benzene, 1,2 dichloroethane, PCE, TCE, toluene, vinyl chloride, and
xylenes; other organics including pesticides; and metals including arsenic.
The selected remedial action for this site includes installing and operating extraction
wells in a phased approach to restore the aquifer and prevent degradation of useable
ground water downgradient of the plume; pumping and treatment of ground water in the
shallow and deeper zones of the aquifer system using physical-chemical treatment
including UV-oxidation, air stripping, biological treatment such as activated sludge,
and/or filtration/adsorption such as granular activated carbon as determined in the
design phase; discharging the treated effluent in the nearby stream; installing a ground
water monitoring system to demonstrate the effectiveness of restoration; and implementing
institutional controls, such as deed restrictions to limit ground water use. The
estimated present worth cost for this remedial action is $26,000,000, which includes an
annual O&M cost of $1,400,000.
PERFORMANCE STANDARDS OR GOALS : Ground water cleanup goals include benzene 1 ug/1
cancer risk level), toluene 40 ug/1 (State standard), TCE 3 ug/1 (10~6 cancer risk
level) , and xylenes 20 ug/1 (State standard) . Effluents must meet limitations for stream
discharge as administered by the State.
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Declaration for the Record of Decision
Site Name and Location
Ott/Story/Cordova Site
North Muskegon, Michigan
Statement of Basis and Purpose
This decision document presents the selected remedial action for
Operable Unit 2 the Ott/Story/Cordova site, in North Muskegon,
Michigan, which was chosen in accordance with the requirements of
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA) and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision document
explains the factual and legal basis for selecting the remedy for
this site.
The State of Michigan concurs with the selected remedy. The
information supporting this remedial action decision is contained
in the administrative record for this site.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial threat to public health, welfare, or the
environment.
Description of the Selected Remedy
This operable unit is the second of three planned operable units
for the site.
Operable Unit 1 addressed the contamination of the nearby Little
Bear Creek system caused by the influx of contaminated
groundwater whose original source of pollutants was the
Ott/Story/Cordova site. Operable Unit 2 considers aquifer
restoration measures. Operable Unit 3 will consider principal
threats as may be posed by contaminated soil areas associated
with the site.
While Operable Unit 1 addressed one of the key threats posed by
the site, the issue of aquifer restoration was beyond the scop^
of the Operable Unit 1. Operable Unit 2 will consider that go.!.
to the degree possible. The aquifer below and downgradient of
the Ott/Story/Cordova site is contaminated to a significant
degree. Full restoration, if possible, is likely to take many
years. If full restoration is not possible then containment
measures must be implemented for what is now an unknown perio.:
time.
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The United States Environmental Protection Agency (U.S. EPA) in
consultation with the Michigan Department of Natural Resources
(MDNR), will re-evaluate groundwater restoration components of
this Record of Decision at least every five years to review
whether or not satisfactory progress is being made toward aquifer
restoration goals.
The major components of the selected remedy for Operable Unit 2
include the following:
Installation and operation of extraction wells designed to
restore the aquifer and prevent degradation of useable
groundwater resources at the southern boundary (downgradient
edge) of the plume of contamination.
Install and operate a purge and treatment system at points
in the unconfined and semiconfined aquifer system
specifically designed: (1) to halt movement of the
contaminated groundwater plume (2) to reduce pollutant mass
(3) restore the aquifer to useable conditions (4) to be
sufficiently flexible to allow modifications of the design
of the purge system based upon operating experience.
A phased approach will be used for the installation of
extraction and monitoring wells to efficiently define the
extent of groundwater contamination, and to apply the
knowledge gained to effectively demonstrate the capture and
treatment of the entire contaminated groundwater plume.
Installation of a groundwater monitoring system that: (1)
demonstrates the effectiveness of restoration (2)
demonstrates complete capture of the groundwater plume, (3)
identifies the most efficient locations for extraction
wells, (4) is capable of determining when the aquifer is
sufficiently restored to allow wells to be taken out of
service.
Provide for adequate treatment of groundwater collected such
that the resultant discharge will meet substantive effluent
limitations as determined by the authorized State of
Michigan program.
Declaration of Statutory Determinations
The selected remedy for Operable Unit 2 is protective of human
health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. This
remedy utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent
practicable, and it satisfies the statutory preference for
remedies that employ treatment that reduce toxicity, nobility, o:
volume as their principal element.
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The United States Environmental Protection Agency (U.S. EPA) will
re-evaluate this remedy to determine whether health-based levels
can be attained throughout the aquifer. If a determination is
made that any portion of the aquifer cannot be restored, then
containment measures must be employed to avoid contamination of
downgradient areas.
Because this remedy will result in hazardous substances remaining
on site above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
Valdas V. AdamJcus
Regional Admjmistrator
U.S. EPA - Region V
Date
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STATE OF MICHIGAN
NATUfUl »e&OU«<;tS
THOMAS j ANOIIRSON
J fLUnAMr
e
JAMES J BLANCHARD. Governor
DEPARTMENT OF NATURAL RESOURCES
N^ T MASON
ro eo* 3oo?e
O'VIP r HALFS. CWUU'
September 27, 1990
Mr. Valdas Adamkus, Regional Administrator
U.S. Environmental Protection Agency
Region V, 5RA-14
230 South Dearborn Street
Chicago, Illinois 60604
Deai- Mr. Adamkus:
The Michigan Department of Resources (MDNR), on behalf of the State of
Michigan, has reviewed the proposed Record of Decision (ROD) for the
Ott/Story/Cordova Operable Unit 2, Muskegon County, which we received on
August 27, 1990. Operable Unit 2 consists of pumping and treating the
contaminated aquifer. The goal of this action is full restoration of the
aquifer. We concur with the selected remedy, which Includes the following:
Installation of extraction wells designed to restore the aquifer and
prevent degradation of useable groundwater resources at the southern
boundary (downgradient edge) of the plume of contamination.
Installation of a purge and treatment system at points in the unconflned
and semiconflned aquifer system which is specifically designed to:
(1)" halt movement of the contaminated groundwater plume,
(2) reduce contaminant mass,
(3) restore the aquifer to useable conditions, and
(4) be sufficiently flexible to allow modifications of the design of the
purge and treatment systems based on operating experience, including
evaluation of the effectiveness of the treatment system at removing
unidentified compounds.
A phased approach will be used for the Installation of extraction and
monitoring wells to efficiently define the extent of groundwater
contamination, and apply the knowledge gained to effectively
demonstrate the capture and treatment of the entire contaminated
groundwater plume.
J Si
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Mr. Valdas Adamkus -2- September 27, 1990
Installation of a groundwater monitoring system that:
(1) demonstrates the effectiveness of restoration,
(2) demonstrates complete capture of the groundwater plume,
(3J identifies the most efficient locations for extraction wells, and
(4) is capable of determining when the aquifer is sufficiently restored
to allow wells to be taken out of service.
We understand that the specific types of "treatment will be determined in the
Remedial Design phase and will probably consist of granular activated carbon,
UV-ox1dation, air stripping, and biological treatment. The treatment system
will be compatible with the treatment system that 1s being designed for
Operable Unit 1. The cleanup of the contaminated groundwater will meet Type 8
criteria consistent with the Act 307 Rules. The cleanup will also be In
compliance with the Michigan Water Resources Act, Public Act 245 of 1929 and
associated rules.
We urge your continued efforts to implement this remedy as soon as possible
and will continue our efforts to this end as well. If you or your staff have
any questions, please contact Mr. Paul Gauthier at 517-373-8427, or you may
contact me directly.
Sincerely,
Oelbert Rector
Deputy Director
517-373-7917
cc: Mr. Jonas Dlkinis, tPA
Mr. Russ Hart, EPA
Ms. "Kathy Cavanaugh, DAG
Dr. James Truchan, MDNR
Mr. William Bradford, MDNR
Mr. Peter Ollila, MDNR
Mr. Paul Gauthier, Ott/Story/Cordova File
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DECISION SUMMARY FOR THE RECORD OF DECISION
1. SITE NAME, LOCATION, AND DESCRIPTION
The Ott/Story/Cordova site is located in Dalton Township,
Muskegon County, Michigan, approximately five miles north of the
City of Muskegon (see Figure 1). The site is in what may be
termed the northernmost vicinity of the Greater Muskegon area.
A point of concern with regard to the site is the proximity of
residential areas. Such areas exist in the form of a trailer
park slightly northwest of the site, and some 100 homes located
in vicinities shown to be downgradient of the site along Central,
River, and Russell Roads. These homes are within a mile of the
site.
The Ott/Story/Cordova site is at the headwaters of a small
unnamed tributary of Little Bear Creek, which flows southeast of
the site approximately one-half mile away. It is unlikely that
Little Bear Creek serves as the regional groundwater discharge
point. That point is more likely the Muskegon River, some three
miles to the touth.
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Site operations began approximately in 1957. The site has been
owned by various specialty organic chemical manufacturers.
Products made over the span of active operations included
intermediate items used in the making of Pharmaceuticals,
dyestuffs, agricultural chemicals, diisocyanates, herbicides,
etc.
For at least ten years, production vessel clean-out wastes and
wastewaters were all initially discharged to on-site unlined
lagoons and allowed to dissipate into soils by seepage. Later,
accumulation of large numbers of drums of waste occured.
By the early 1960s, signs of water and soil contamination were
beginning to be noted. Later, in response to Michigan concern-,
efforts were made by the site owners to slow the spread of the
groundwater contaminant plume emanating from the site.
Correspondence by some members of the Michigan Water Resourcer,
Commission and later the Michigan Department of Natural Resou:
(MDNR) expressed concern as to the effectiveness of such effc:*
By 1977, with the then present site owner (Story Chemical) in
bankruptcy, a removal action was undertaken by the State of
Michigan and financed in part by a new site owner. Several
thousand drums and thousands of cubic yards of lagoon sludge:
were removed and disposed of from the site. During the site'
history, various information and documents were filed with
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Ott/Story/Cordova Sile
River Road
City .f
Muskc ion
Lake
Michigan
Figure 1
Site Location Map
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federal and state governments. Briefly, and in approximate
chronological order, these are:
- Information generated by Ott Chemical regarding Michigan
Orders of Determination concerning groundwater and lagoon
usage (approximately 1965-1966).
- Information generated by Ott and Story Chemical concerning
effluent content to waters of the State of Michigan
(approximately 1967-1973).
- Information generated by Ott Chemical and submitted to the
Corps of Engineers regarding the River and Harbors Act, (a
forerunner of the National Pollutant Discharge Elimination
System) (approximately 1971).
- Filing for generator status and treatment/storage permits
by Cordova Chemical of Michigan under the Resource
Conservation and Recovery Act (approximately 1980).
- Filing by Cordova for various Michigan air permits (early
1980s).
In 1982, the site was placed on the National Priorities List
(NPL). Also in 1982, an alternate water supply was undertaken in
the vicinity of the site in settlement of a citizens' suit
against of former site owner, and financed in part by a former
site owner, and in part by the State of Michigan.
Three distinct sets of site owner/operators have been involved in
the site over its history. The Ott Chemical Company began
operations at the site in the 1950s as an independent company.
In 1965, Corn Products Company, now CPC International, purchased
all stock of Ott Chemical. In 1972, CPC sold assets that •
comprised the Ott Chemical operations to Story Chemical. In late
1976-early 1977, Story Chemical initiated bankruptcy proceedings..
In late 1977-early 1978, Cordova Chemical Company of Michigan
purchased the site after entering into an agreement with the
State of Michigan. The agreement called for Cordova to destroy
or neutralize phosgene gas left at the site, and to finance in
part the State's action to remove drums of waste and lagoon
sludges. In return, the State of Michigan agreed to limit
Cordova's liability for future site releases caused by past
activities. U.S. EPA was not a party to the agreement.
In 1985, a notice letter was sent to Cordova and CPC, potential 1..
responsible parties (PRPs), advising them of their potential
liability for the site. The letter offered them an opportunity
to conduct a site Remedial Investigation/Feasibility Study
(RI/FS). Both CPC and Cordova declined to accept this offer, ;
U.S. EPA conducted an RI/FS. In March 1989, U.S. EPA also sent
demand letters for cost recovery to CPC and Cordova. In May
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1989, U.S. EPA also informed Cordova Chemical Co. of California
(parent company of Cordova-Mi), Aerojet-General (parent company
of Cordova of California) and Swanton-Story Corporation
(successor of Story Chemical) of their potential liability as
regards this site and sent demand letters to these firms. Both
Aerojet-General and Swanton-Story Corp. are considered PRPs due
to Aerojet's ownership of Cordova Chemical and Swanton-Story
being what remains of Story Chemical after the bankruptcy
proceedings.
In August 1989, PRPs were given notice pursuant to a Section
122(a) letter that U.S. EPA had determined that a period of
negotiations would not facilitate an agreement for remedial
design and action for Operable Unit 1. The availability of the
Proposed Plan/Focused Feasibility Study, and notice of the start
of a public comment period were also stated in the letter.
Presently, litigation among the PRPs, the state and federal
government is underway. CPC International has filed a suit for
its costs against Aerojet, Cordova and the State of Michigan in
the U.S. District Court, Western District of Michigan. In
October 1989, U.S. EPA filed a cost recovery action in the same
federal court.
A ROD for Operable Unit 1 was signed by U.S. EPA in September
1989. However, in November 1989, U.S. EPA reopened public
comment on its selected remedy for Operable Unit 1, and declared
that it would reconsider the selected remedy. This comment
period extended to December 1989. In December 1989, CPC filed a
counter claim against U.S. EPA, alleging improper procedure
regarding compilation of the Administrative Record supporting
Operable Unit 1. Response to this claim was made by U.S. EPA
through the U.S. Department of Justice in February 1990.
In March 1990, U.S. EPA affirmed its Record of Decision for
Operable Unit 1, and later that same month issued a Unilateral
Order pursuant to Section 106 of CERCLA to undertake actions as
determined in the Record of Decision. The PRPs chose not to
comply with the Order. In June 1990, an Inter-Agency agreement
was finalized between the U.S. EPA and the U.S. Army Corps of
Engineers, such that remedial design work for Operable Unit 1
could begin.
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
A RI/FS "Kickoff" availability session was held near the site in
November 1987. Upon the completion of the RI in April 1989, a
copy of the RI report was made available to the public at the
information repositories maintained at the Dalton Township Publi,
Hall and the Walker Memorial Library in North Muskegon. The RI
was also made a part of the administrative record file maintairu
in Region 5 and at the local repository at the Walker Memorial
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Library. A Proposed Plan and Focused Feasibility Study for
Operable Unit 2 were released to the public on August 1, 1989 to
initiate a public comment period for the proposed action. A
public meeting was held in August 1989.
The Feasibility Study (FS) and Proposed Plan for Operable Unit 2
were made available to the public in July 1990. A notice of
availability was published in the Muskegon Chronicle on
July 24, 1990 to initiate a public comment period on the
alternatives from July 25, 1990 to August 23, 1990. In
addition, a public meeting was held on August 16, 1990 in
Muskegon County. At this meeting, representatives from EPA and
the Michigan Department of Natural Resources (MDNR) answered
questions concerning site conditions, problems, and remedial
alternatives under consideration. In response to a request for
extension, U.S. EPA subsequently extended the public comment
period to September 24, 1990. A response to the comments
received during this period is included in the Responsiveness
Summary, which is part of this Record of Decision. This decision
document presents the selected remedial action for Operable Unit
2 for the Ott/Story/Cordova Site in North Muskegon, Michigan,
chosen in accordance with CERCLA, as amended by SARA, and to the
extent practicable, the National Contingency Plan. The decision
for this site is based on the administrative record.
4. SCOPE AND ROLE OF OPERABLE UNIT
As with many Superfund sites, the problems at the
Ott/Story/Cordova site are complex. Consequently, EPA has
organized the remedial work into three planned operable units at
the site. This Record of Decision addresses the second operable
unit planned for the site.
Operable Unit 1 focused on the interception of contaminated
groundwater entering and degrading the Little Bear Creek
system. This action is now in the Remedial Design stage,
with construction start-up anticipated for the spring of
1991.
Operable Unit 2, which is the subject of this Record of
Decision, has as its primary goal the restoration of the
aquifer system below and downgradient of the
Ott/Story/Cordova site.
The goal of the Operable Unit 1 was to address an immediate
threat to human health and the environment, namely the
introduction of a portion of the contaminated aquifer system
in a surface water body that flows through and near a
residential area. The broader question of groundwater
remediation will be addressed by this Operable Unit 2.
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The National Contingency Plan (NCP) provides guidance on this
issue. As stated on page 8732 of the March 8, 1990 "Federal
Register," the NCP notes that: the goal of U.S. EPA's
Superfund approach is to return usable groundwaters to their
beneficial uses within a timeframe that is reasonable given
the particular circumstances of the site.
The NCP also provides guidance on the important consideration
of reasonable timeframe. The NCP calls for very rapid
restoration time periods of groundwater currently used for
drinking water supply. More extended timeframes may be
appropriate for groundwater with the potential to serve as
such a supply.
At the Ott/Story/Cordova site, an alternate water supply was
provided in nearby areas downgradient of the site. However,
groundwater users do exist approximately 1 and 1/2 miles to
the east and south (downgradient) of the site. Therefore,
restoration in a reasonable timeframe will be an important
consideration of this Record of Decision. The NCP also
provides guidance on two other important questions; the role
of institutional controls, and whether natural attenuation
should be expected to play an important part. On page 8706
of the March 8, 1990 "Federal Register," the NCP notes that
institutional controls will usually be used as supplementary
protective measures during implementation of groundwater
remedies. On page 8734 of this document, the NCP also notes
that natural attenuation may be recommended when it is
expected to reduce concentration of contaminants in
groundwater to remediation levels in a reasonable timeframe.
U.S. EPA believes that neither the sole use of institutional
controls or dependence on natural attenuation for aquifer
restoration are prudent or effective means in remedying the
highly contaminated groundwater at the site. Groundwater
contamination remains very high presently, even twelve
years after the site ceased operation, and available
information indicates that concentrations of contaminants
will not be reduced without active remediation.
A third operable unit for the Ott/Story/Cordova site will L-
developed to consider areas of soil contamination found on
site. The FS for Operable Unit 2 explored soil alternative
to the site. However, shortly after the completion of the
FS, the State of Michigan promulgated new regulations
concerning environmental response, the Act 307 rules. U.S.
EPA believes it is appropriate to examine assumptions made
in the latest FS concerning projected soil volumes and
cleanup levels in light of those new regulations. In
addition, U.S EPA plans to conduct further soil/sediment
sampling along the banks of Little Bear Creek.
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5.
SUMMARY OF SITE CHARACTERISTICS
An important site characteristic at Ott/Story/Cordova is the
sandy nature of site soils which result in a high permeability.
Past usage of unlined waste lagoons and subsequent plant
spills/releases have resulted in masssive introduction of
pollutants into the soil and groundwater. The RI revealed over
90 different organic compounds in the groundwater, of which 32
are classified as priority pollutants.
The table on the following page presents selected testing results
of groundwater monitoring wells at the site. Highly elevated
levels of compounds such as 1,2 dichloroethane, 1,1-
dichloroethene, vinyl chloride, tetrachloroethene, and benzene
exhibit varying degrees of carcinogenic activity. As was
dicussed in the RI Report, a contaminant's characteristics such
as structure, solubility, and vapor pressure influence its
potential to and rate of migration in soils vapor and
groundwater.
Compounds such as vinyl chloride and 1,2-dichloroethane may be
described as extremely mobile, l,l-dichloroethene, 1,1,1-
trichloroethane, toluene, and xylene as very mobile; and 1,2-
dichloro-benzene as slightly mobile.
RESULTS FOR SELECTED TESTING WELLS
(Results given in micrograms per liter or approximately parts per
billion)
HIGHEST
LOCATION CONTAMINANTS CONCENTRATION MCL
W3
W101S
(none detected-background well northwest of site)
wioil
W101D
OW9
1,2 Dichloroethane
1,1 Dichloroethene
Benzene-3800
Tetrachloroethene
Toluene
1,2 Dichloroethane
1,1 Dichloroethene
Benzene
1,2 Dichloroethane
Tetrachloroethene
Vinyl Chloride
1,2 Dichloroethane
1,1 Dichloroethene
Vinyl Chloride
2200
350
3800
24,000
38,000
110,000
970
510
8
55
9
21,000
7, 900
50,000
5 .
7
5
5
2000
5
7
5
5
5
2
5
/
2
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OW12 1,2 Dichloroethane 110,000 5
1,1 Dichloroethene 1,100 7
Vinyl Chloride 50,000 2
Bl Vinyl Chloride 550 2
OW8 Benzene 15 5
Vinyl Chloride 7,200 2
At the Ott/Story/Cordova site, soils are predominantly sand to a
depth of approximately 65 feet. Then, layers of silts and clays
tend to form a barrier separating the upper unconfined aquifer
from a lower semiconfined zone which begins at about 85 feet
below the ground's surface. All of the samples noted above were
taken from the upper sandy aquifer zone, except for well W101D,
which is in the lower semi-confined aquifer.
The considerable array of groundwater pollutants shown in the
above table yields insight as to the degree of contamination
found at the site. The RI shows the presence of intermingled
silt and clay layers occurring at a depth of approximately 65-85
feet below the ground surface. Contaminants may be more strongly
retained within this interval, and the ability of these layers to
slowly release contaminants throughout the groundwater system
causes concern over the ability to attain ultimate health-based
restoration goals.
The MCL, or maximum contaminant level, helps provide a useful
comparison of the sampled groundwater's relative cleanliness or
contamination. MCLs are enforceable standards for contaminants
in drinking water supply as established by the Safe Drinking
Water Act.
Certain monitoring points are worthy of note as regards to
Operable Unit 2. Well Bl is considerably west of the Little Bear
Creek area, along River Road. Well 101D is just north of Agard
Road, and is screened in sandy soil some 120 feet below the
ground's surface (see Figure 2). In these cases, interception by
wells designed in operable unit 1 to prevent contaminant
discharge into Little Bear Creek from the shallow aquifer is open
to doubt.
The volume of contaminated groundwater at Ott/Story/Cordova has
been estimated at over 1.2 billion gallons. Figures 1 and 2
provide the reader with an approximate idea of site setting, and
the location of wells referred to in these discussions.
6. SUMMARY OF SITE RISKS
Numerous chemical compounds were detected during the course of
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Total Organic Contaminants in micrograms per liter
Unconf ined Aquifer Portion .. •-•
"I
s : /
wjjs
,* J«3
(HOI
MW I6S
(19001,, '
__._) rv. \J 09001_,
W60y
(J«OI
4 '.w:
- wiOil
•—? .__ I «:LL'iVSON ^C-i
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Ott/Story/ Cordova field investigations. As is explained in
further detail in the RI report, some 90 organic compounds were
detected in groundwater, and over 200 organic compounds were
detected in site soil samples. Inorganic compounds were also
detected in both soils and groundwater. Data sets were evaluated
to consider those chemicals above background levels, toxicity
constants for noncarginogens and carcinogens were reviewed, and
the degree of occurrence of a given substance at the site was
considered.
As discused in the NCP, a baseline risk assessment is initiated
as a part of remedial investigation. The purpose is to determine
whether the contaminants found pose a current or potential risk
to human health and the environment in the absence of remedial
action. Such assessment helps provide a basis to determine if
remedial action is necessary. The assessment consists of
exposure and toxicity components combined so as to characterize
overall risk.
Based on this evaluation, twenty-two indicator chemicals were
selected at the Ott/Story/Cordova site which appeared to not only
be present in significant concentrations, but also exhibit the
potential for relatively high toxicity. These substances are:
1,1,2-trichloroethane
1,2-dichloroethane
1,1-dichloroethene
trichloroethene
carbon tetrachloride
vinyl chloride
chloroform
tetrachloroethene
benzene silver
heptachlor epoxide barium
xylene zinc
toluene copper
4,4'-DDT nickel
PCB cyanide
dichloromethane arsenic
EXPOSURE ASSESSMENT
During early production periods at the site, releases of
contaminants occurred either to the air or soil. Since
production activities have now been curtailed, it is assumed t.1-.
all present releases from the site resulted from previous
releases to soil.
Once in soil, further releases can occur by movement of
contaminants into groundwater and the subsequent discharge to
surface water, volatilization into the air or suspension of
contaminated dusts into the air, or runoff of surface water t:
may carry contaminated soils.
The movement of contaminated groundwater results in several
exposure pathways. Users of groundwater are considered a
potentially exposed population. Formerly, several residents
the site were supplied by individual groundwater wells. In .
as a result of a settlement of a citizens' suit against one
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the PRPs, an extension of an alternate water supply to the area
was provided. Beyond this supply extension, groundwater is used
as a water supply. In recent years, the Muskegon County Health
Department has found it necessary to warn residents near the site
not to use groundwater for watering lawns or gardens; such usage
can present a direct ingestion or inhalation pathway. The
groundwater at Ott/Story/Cordova may be classified as a Class II
supply, as discussed in the NCP on page 8732 of the March 8, 1990
"Federal Register." Prior to the present contamination, the
aquifer below and downgradient of the site served as a source of
drinking water.
Operable Unit 2 will address the primary exposure scenario posed
by contaminated groundwater. This scenario concerns ingestion by
potential groundwater users.
TOXICITY ASSESSMENT
The degree of toxicity which may be posed by a given chemical may
be described in part by its acceptable intake for subchronic
exposure (AIS), its reference dose or acceptable intake for
chronic exposure (AIC), and in the case of carcinogens by its
carcinogenic potency factor. Values for AIS and AIC are derived
from information available from studies on animals or human
epidemiologic studies. These values are normally reported in
mg/kg body weight/day, and generally represent the highest
calculated exposure level below which the given adverse effect
will not occur. A carcinogenic potency factor is expressed as
lifetime cancer risk per mg/kg body weight/day, and is estimated
at the upper 95 percent confidence limit of the carcinogenic
potency of a given chemical.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)-1,
are multiplied by the estimated intake of a potential carcinogen;
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies of chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied. .
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
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expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
The following two tables describe AIC, AIS, and carcinogenic
potency factors for indicator chemicals at the Ott/Story/Cordova
site. The third table lists the weight of evidence for the
various categories of potential carcinogens.
RISK CHARACTERIZATION
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 1x10-6 or 1E-6). An excess lifetime cancer risk of 1x10-6
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
The Agency considers excess cancer risk in the range of 10-4 to
10-6 as protective of human health. The risk level of 10-6,
which represents a probability of one in one million that an
individual could contract cancer under the conditions of
exposure, is often used as a "benchmark" of protection. Given
the large number of carcinogenic contaminants found in site
groundwater, the Agency has determined that for groundwater
cleanup a risk level of 10-6 is appropriate for this site for a
given contaminant, such that cumulative excess cancer risk does
not exceed the 10-4 level.
Risks to future potential ground water users were calculated.
Because contaminants in the aquifer are not uniformly
distributed, risks were estimated assuming that a given
10
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AIC AND AIS VALUES FOR INDICATOR
CHEMICALS AT THE OTT/STORY/CORDOVA SITE
Acceptable Intake
Indicator Chemical
1 , 2-Dichloroethane
1, 1-Dichloroethene
Arsenic
Carbon Tetrachloride
Vinyl Chloride
Chloroform
Tetrachloroethene
Benzene
1,1, 2-Trichloroethane
Heptachlor Epoxide
Silver
Barium
Zinc
Copper
Nickel
Tr ichl oroethene
toluene
Cyanide
Methylene chloride
Xylene
PCS
Inqestion Route Inhalation Route
Subchronic Chronic Sxibchronic Chronic
(AIS) (AIC) (AIS) (AIC)
mq/kq/day irqAq/day mqAg/day nq/kq/day
0.009
0.0007a
0.01
O.Ola
0.004a
0.000013a
0.003
O.OSa 0.0014 0.00014
0.21 0.21 0.1 0.01
0.037 0.037
0.02 0.02a
0.43 0.30 1.5 1.5
0.02
0.06
0.1 2a 0.69 n.d
Primary Source: USEPA, 1986a
a - Source: RfD; EPA IRIS database (12/1/88)
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CARCINOGEN POTENCY FACTORS FOR INDICATOR
CHEMICALS AT THE OTT/STORY/CORDOVA SITE
Indicator Chemical
1,2-Dichloroethane
1,1-Dichloroethene
Arsenic
Carbon tetrachloride
Vinyl Chloride
Chloroform
Tetrachloroethene
Benzene
1,1,2-TrichIoroethane
Heptachlor Epoxide
Silver
Barium
Zinc
Copper
Nickel
Trichloroethene
Toluene
Cyanide
Methylene chloride
Xylene
PCB
Inqestion
Potency
Factor
(ing/kg/dl"1
0.091
0.58
1.65b
0.13
2.3
0.006 la
0.051
0.029a
0.0573
9.1
0.011
0.0075
7.7
Route
EPA Weight
of _Evidence
B2
C
A
B2
A
B2
B2
A
C
B2
A
B2
B2
B2
Inhalation Route
Potency
Factor
(mg/kg/d)"1
0.09 la
1.16
15a
0.13a
0.295a
0.08 la
0.0033a
0.029a
0.057a
9.1
1.19
0.013a
0.0143
EPA Weight
of Evidence
B2
C
A
B2
A
B2
B2
A
C
B2
A
B2
B2
B2
B2
Primary Source: EPA, 1986
a - Source: RfD; EPA IRIS database (revised 12/1/88)
b - USEPA, 1987
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EPA WEIGHT OF EVIDENCE
CATEGORIES FDR POTENTIAL CARCINOGENS
EPA Description
Category of Group Description of Evidence
Group A Human Carcinogen Sufficient evidence from
epidemiologic studies to support
a causal association between
exposure and cancer
Group Bl Probable Human Limited evidence of
Carcinogen carcinogenicity in humans from
epidemiologic studies
Group B2 Probable Human Sufficient evidence of
Carcinogen carcinogenicity in animals,
inadequate evidence of carcino-
genicity in humans
Group C Possible Human Limited evidence of carcino-
Carcinogen genicity in animals
Group D Not Classified Inadequate evidence of
carcinogenicity in animals
Group E No Evidence of No evidence of carcinogenicity
Carcinogenicity in at least two adequate animal
in Humans tests or in both epidemiologic
and animal studies
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monitoring well served as a water supply source. Chronic hazard
index values and base case cancer risks were estimated for
indicator chemicals found in each well.
The chronic hazard index value exceeded unity in 19 monitoring
wells. Consequently, were groundwater used in its present state,
there is a health risk with regard to noncarcinogenic chemicals.
With regard to carcinogenic indicator chemicals, cancer risks for
at least one compound exceeded 1 x 10-6 in 22 wells.
Particularly striking were results obtained in monitoring wells
OW12 and OW9. Vinyl chloride concentrations in these wells were
found to be at such levels that the excess cancer risk from this
compound alone was found to approach 1. • Eight other wells
exhibited instances of either vinyl chloride or 1,2-
dlchloroethane exceeding cancer risks of 1 x 10-1. It i-;
important to consider risk associated with groundwater ingestion
at points in the aquifer system unlikely to be influenced by
remedial action of the Operable Unit 1.
Deep well W101D is located north of Agard Road, on the grounds of
the former plant. Additive excess cancer risk at this point is
approximately 9x10-4, primarily from 1,2-dichloroethane, vinyl
chloride, and tetrachloroethene. Well W101D is screened within
the deeper semiconfined aquifer portion. Well W101I, noted
earlier, is located nearby and is screened in the unconfined
aquifer.
Monitoring wells Bl and OW8 are both screened in the unconfined
aquifer zone, and are located along River Road near the
intersections with the C & 0 railroad tracks and Central Road,
respectively. Primarily due to the known human carcinogen vinyl
chloride, excess cancer risk associated with groundwater
ingestion at well Bl is 4X10-2; at well OW8 such risk is in
excess of 1X10-1. These points are sufficiently west of Little
Bear Creek that interception by extraction wells serving the
Operable Unit 1 is open to question.
These results indicate that any potential ingestion of
groundwater from certain areas at the Ott/Story/Cordova site
poses enormous health risks. The above discussions indicate that
the risks from current and potential exposure to contaminated
groundwater are unacceptable. Actual or threatened releases of
hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of
Decision, may present an imminent and substantial endangerment to
public health, welfare, or the environment.
Uncertainly associated with site risk concerns to what degree
contaminated groundwater is used for washing and watering
purposes, despite County warning to avoid such usage.
11
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7. DESCRIPTION OF ALTERNATIVES
The alternatives analyzed for Operable Unit 2 are presented
below. As was indicated above, these alternative only pertain to
the final groundwater remedy.
Alternative 1: No Action
Alternative 2: Institutional Control
Alternative 3a: Supplementary Extraction in only the
Shallower Aquifer Portion, Monitoring, Deed
Restriction, Physical-Chemical Treatment,
Biological Treatment, Stream Discharge
Alternative 3b: Supplementary Extraction in both Shallow and
Deep Aquifer Portions, Monitoring, Deed
Restriction, Physical-Chemical Treatment,
Biological Treatment, Stream Discharge
Alternative 3c: Phased Supplementary Extraction in both
Shallow and Deep Aquifer Portions,
Monitoring, Deed Restriction, Physical-
Chemical Treatment, Biological Treatment,
Stream Discharge
Common Elements. Except for the "No Action" alternative, other
alternatives noted have certain elements in common. All envision
that usage of this portion of the aquifer in its current degraded
state will be restricted, either indefinitely (Alternative 2) or
for the duration of the treatment period (Alternative 3a, 3b,
3c) . U.S. EPA presumes development of a deed restriction with
the current site owner, and cooperation with other private
citizens. The Michigan Department of Public Health advises U.S.
EPA that restrictions for residential wells in Muskegon County
may not be enforceable. All envision that monitoring of
groundwater contaminant levels and movement will be conducted.
Alternatives 3a, 3b, and 3c envision employment of identical
treatment schemes, which in concept are identical to that
employed for the Operable Unit 1. (U.S. EPA notes that remedial
design activity for the Operable Unit 1 is underway, and that
U.S. EPA has recently approved a work plan for the treatability
study of expected removal efficiencies from certain treatment
components to be performed concurrently with remedial design.)
It is not anticipated that the RCRA Land Disposal Restrictions
are ARARs for any of the alternatives discussed above, since the
waste are not listed wastes. Any residuals created through
Alternatives 3a, 3b, or 3c must be managed properly.
12
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Alternative 1 - No Action
U.S. EPA is required to consider a no-action alternative pursuant
to the NCP. This alternative serves as a baseline for comparison
purposes. Under this alternative, U.S. EPA would take no
additional remedial action at the site to monitor, control,
collect, treat, or otherwise cleanup contaminated groundwater.
The cost of this alternative is therefore zero.
Alternative 2-Institutional Controls and Monitoring.
Institutional controls, such as deed restrictions, would be
implemented under this alternative, restricting current and
future uses of ground water at and downgradient of the facility.
Additional ground water monitoring wells would be placed in both
the unconfined and semi-confined ground water systems to evaluate
the southern extent of contamination and provide a basis for
placement of deed restrictions. Alternative 2 relies solely on
institutional control and a monitoring well network as a means of
precluding public usage of contaminated groundwater. U.S. EPA
believes that institutional control has a role to play, but
should not be relied on solely where engineering controls and
treatment are practicable as is the case for the
Ott/Story/Cordova site.
Capital Cost: $0.3 million
Present Worth: $1.3 million
Annual O & M: $0.06 million
Time to Implement: 4-5 months
Alternative 3a - Supplmentary Extraction, Monitoring, Usage
Restriction, Physical-Chemical Treatment, Biological Treatment,
Stream Discharge.
Supplementary extraction wells would be installed only in the
shallow aquifer systems, primarily along the southern edge of
contaminated groundwater areas. Primary ARARs that will be met
by this alternative include the Safe Drinking Water Act for this
portion of the aquifer, effluent limitations as administered by
Michigan for stream discharge, air emission and waste management
regulations. Design life of this, and other restoration
groundwater alternatives, is estimated at 30 years.
Physical-chemical treatment will provide initial removal of
organic contaminants. Biological treatment will yield enhanced
removal of organics prior to stream discharge. Coupled with
filtration and adsorption techniques, further contaminant and
suspended solids removal will occur.
The specific types of physical-chemical treatment (e.g. UV-
13
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oxidation, air stripping), biological treatment (e.g. activated
sludge), and filtration\adsorption (e.g. granular activated
carbon), will be determined in the Remedial Design phase through
engineering design and analysis.
Capital Cost: $6.4 million
Present Worth: $26 million
Annual 0 & M: $1.2 million
Time to Implement: 22-24 months
Alternative 3b - Supplementary Extraction, Monitoring, Usage
Restriction, Physical-Chemical Treatment, Biological Treatment,
Stream Discharge
Supplementary extraction wells would be installed as noted in
alternative 3a, and additional extraction wells would be
installed near points of higher contamination levels in both the
shallow and deeper zones of the aquifer. Requirements to be met
for this alternative are as noted for Alternative 3a. This
alternative contemplates the installation of an extensive
groundwater extraction system that assumes worst case in terms of
magnitude and extent of groundwater contamination. Treatment of
extracted groundwater would proceed as described in 3a, above.
Capital Cost: $8.9 million
Present Worth: $40.3 million
Annual 0 & M: $1.9 million
Time to Implement 25 months
Alternative 3c - (Phased) Supplementary Extraction, Monitoring,
Usage Restriction, Physical-Chemical Treatment, Biological
Treatment, Stream Discharge
Supplementary extraction wells would be installed in both shallow
and deeper zones of the aquifer such that, in conjunction with
the Operable Unit 1 all known areas of contaminated groundwater
would be addressed. Alternative 3c differs from alternative 3b
in that it adopts a phased approach to aquifer restoration. This
alternative would have the extraction system installed in
.incremental steps based on the actual extent and magnitude of
groundwater contamination. Treatment of extracted groundwater
would proceed as described in 3a, above.
Capital Cost: $6 million
Present Worth: $26 million
Annual 0 & M: $1.4 million
Time to Implement: 22-24 months
8. Summary of Comparative Analysis of Alternatives
14
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A detailed analysis was performed on the alternatives developed
in the FS.
The nine evaluation criteria utilized in accordance with the NCP
are: overall protection of human health and the environment;
compliance with ARARs; long-term effectiveness and permanence;
reduction of toxicity, mobility, or volume through treatment;
short-term effectiveness; implementability; cost; state
acceptance; and community acceptance.
These criteria are defined below:
- Overall protection of human health and the environment:
addresses whether a remedy provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering
controls, or institutional controls;
- Compliance with ARARs; addresses whether a remedy will meet
all of the applicable or relevant and appropriate Federal and
State environmental laws and/or justifies use of a waiver.
- Long-term effectiveness and permanence: addressess the
expected residual risk and the ability to maintain reliable
protection of human health and the environment over time, once
clean-up goals have been met;
- Reduction of toxicity. mobility, or volume through treatment:
addresses the anticipated performance of the treatment
technologies the remedy may employ;
- Short-term effectiveness: addresses the period of time needed
to achieve protection and any adverse impacts on human healt..
and the environment that may be posed during the construction
and implementation period (i.e., until clean-up goals are
achieved);
- Implementability; addresses the technical and administrative
feasibilty of a remedy, including the availability of
materials and services needed to implement a particular
option; and
- Cost; addresses the estimated capital and O & M costs, as
well as a present-worth.
- State agency acceptance; addresses the support agency's
comments and concerns.
- Community acceptance; addresses the public's comments on
concerns about the Proposed Plan and RI/FS report. (The
15
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specific response to public comments are addressed in the
Responsiveness Summary section of the ROD).
The following is a summary of the comparison of each
alternative's strength and weakness with respect to the nine
evaluation criteria:
Overall Protection of Human Health and the Environment
Unlike certain other criteria, a remedy is either deemed
protective or it is not. There are not "degrees" of protection.
Only those alternatives determined to be protective will be
considered for the selected remedial alternative.
Alternatives 3b and 3c which call for supplementary extraction
and treatment of contaminated groundwater in both shallow and
deep aquifer zones to health-based standards offer protection of
human health and the environment. Alternative 3a envisions
supplementary extraction and treatment only in the shallower zone
of groundwater, and allows the deeper aquifer to remain
contaminated. Alternatives 1 and 2 do nothing to abate the
movement of contaminated groundwater areas which as discussed
previously in this document cannot logically be expected to be
contained by extraction wells serving Operable Unit 1.
Alternatives 1 and 2 are not protective of human health and the
environment because they may permit spread of contamination into
areas where future well users may be adversely affected.
Compliance with ARARs
This criterion, as with the protectiveness criteron, must be met
for an altnerative to be a selected remedy (unless one of the six
waivers allowed under the statute is appropriate).
A table of all known site-specific federal and state ARARs and
to-be-considered information is provided below. Key ARARs for
each alternative have been noted in Section 7 of this document.
Each alternative carries its own set of criteria that must be met
before implementation of that alternative can be termed to be
compliant.
Alternative 3a, 3b, and 3c would meet their respective applicable
or relevant and appropriate requirements of federal/state
environmental laws and regulations. The preferred (3c)
alternative would comply with the Clean Air Act and pertinent
Michigan regulations on dust and volatile eraissons control, RCRA
regulations on proper residuals management, the Michigan-
administered Pollutant Discharge Elimination System, the Safe
Drinking Water Act, and Michigan Act No. 307
TABLE OF FEDERAL ARARs
16
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Safe Drinking Water Act (SDWA), 42 U.S.C. 300f: Establishes
criteria for drinking water quality. Chemical specific,
regarding alternatives 3a, 3b, 3c.
Clean Water Act (CWA), 33 U.S.C. 1251: Establishes effluent
guidelines and water quality criteria. Chemical specific,
regarding alternatives 3a, 3b, 3c.
National Pollutant Discharge Elimination System (NPDES)
Program; 40 CFR Parts 122,125 and Subchapter N: Regulates
the discharge of water into surface water. (CWA Section
402). Chemical specific, regarding alternatives 3a, 3b, 3c.
Federal Standards for Toxic Pollutant Effluent; 40 CFR Part
129: Regulates the discharge of certain pllutants. Chemical
specific, regarding alternatives 3a» 3b, 3c.
Fresh Water Quality Criteria (FWQC): Regulates surface water
discharge from site. Chemical specific, regarding
alternatives 3a, 3b, 3c.
Clean Air Act and National Ambient Air Quality Standards
(CAA and NAAQS), 40 CFR Part 50: Regulates site emissions
including particulates during on-site excavation. Action-
specific, regarding alternatives 3a, 3b, 3c.
40 C.F.R. Part 50; EPA Regulations on National Primary and
Secondary Ambient Air Quality Standards (NAAQS). Action-
specific, regarding design of treatment for alternatives 3a,
3b, 3c.
Note: An ARAR for an on-site incinerator, air stripper for
groundwater treatment or soils treatment units. Used to
establish units for air emission based upon modeling. The
NAAQS specify the maximum concentration of a federally
regulated air pollutant (i.e., SO , particulate matter
(PM ), NO , CO, ozone, and lead) in an area resulting from
all sources of that pollutant.
40 C.F.R. 125, Subpart A; EPA regulations on Criteria on
Standards for the NPDES, Criteria and Standards for
Technology-Based Treatment Requirements in Permits.
Note: An ARAR because it sets out applicability of technology
based treatment requirements for discharges of certain
pollutants. Section 125.3(c) establishes methods for
determining technology based limits.
Action-specific, regarding alternatives 3a, 3b, 3c.
40 C.F.R. 125, Subpart K; Criteria and Standards for Best
Management Practices.
17
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Note: An ARAR because it requires implementation of best
management practices requirements in substantive permits to
prevent release of toxic constituents. Chemical-specific,
regarding alternatives 3a,•3b, 3c.
Safe Drinking Water Act; 42 U.S.C. 300
40 C.F.R. Part 141; EPA National Primary Drinking Water
Standards; Maximum Contaminant Levels (MCLs).
This standard is an ARAR since the aquifer is potentially
usable as a drinking water source. Chemical-specific;
alternatives l,2,3a,3b,3c. (Alternatives 1 and 2 make no
attempt at compliance.)
Resource Conservation and Recovery Act (RCRA) of 1976, as
amended by the Hazardous Solid Waste Amendments (HSWA) of
1984, 42 U.S.C. 6901. Regulates disposal of solid waste and
the generation, transport, storage, treatment and disposal
of hazardous wastes.
Action-specific, regarding alternatives 3a, 3b, 3c since via
treatment processes sludges/residuals will be created which
will require proper management.
Executive Order (EO) for Wetlands (11990) and Floodplains
(11988) as implemented by EPA's August 6, 1985, Policy on
Floodplains and Wetlands assessments for CERCLA Actions:
Regulates remedial action implementation in wetlands or
floodplains. Location-specific regarding alternatives 2,
3a, 3b, 3c.
40 C.F.R. 122, R122.41; EPA NPDES Permit Regulations,
Conditions Applicable to all Permits.
Note: Administrative procedural requirements are not ARARs if
reme'dial action is undertaken on-site under CERCLA. A
substantive technical requirement to ensure compliance with
technical discharge standards including monitoring, record
keeping and notification of noncompliance with discharge
standards would be an ARAR. U.S. EPA believes actions
envisioned by alternatives 3a, 3b, 3c constitute on-site
response.
18
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TABLE OF STATE ARARs
Michigan Water Resources Act, Public Act 245 of 1929, as
Amended (Water Resources Commission General Rules, Part 4,
21): establishes surface water and groundwter quality
discharge standards and monitoring requirements. Provides
ground water criteria for CERCLA sites, landfills and
discharges to surface water. Implements NPDES regulations.
Michigan Air Pollution Act, Public Act 348 of 1965, as
Amended: Regulates air quality in the presence of new or
modified air sources. Action-specific, pending design of
volatile organics in 3a, 3b, 3c.
Mineral Well Act, Public Act 315 of 1969: Dictates that the
proper procedures for installing and abandoning monitoring
wells are adhered to. Action-specific for alternatives 1, 2,
3a, 3b, 3c. (Note: Alternative 1 would fail to comply.)
40 C.F.R. 262; Regulations for Hazardous Waste Generators
Michigan Hazardous Waste Management Rules, Part 3, R299.9301
to 9309; "Generators of Hazardous Wastes."
f
Note: This is an ARAR if CERCLA site materials are shipped
off-site to RCRA treatment, storage or disposal (TSD)
facility. Chemical-specific, pending analysis of
sludges/residuals from alternatives 3a, 3b, 3c. Michigan has
an authorized hazardous waste program with substantively
identical requirements to 40 C.F.R. 262-265.
40 C.F.R. 264, Subpart C; Preparedness and Prevention.
This regulation requires written records of waste management
operations. This is an ARAR if CERCLA site materials are
shipped to a RCRA TSD facility. Chemical-specific, pending
analysis of treatment residuals for alternatives 3a, 3b, 3c.
40 C.F.R. 264, Subpart F; Ground Water Protection.
Michigan Hazardous Waste Management Rules.
Note: Provides requirements to detect and respond to releases
in an aquifer. An ARAR for post-closure detection monitoring
after remediation where constituents remain on-site. Chemical-
specific, pending selection of treatment reagents for
alternatives 3a, 3b, 3c.
39
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Part 4, Rule 57; Acute Toxicity, Chronic Toxicity, Etc.
Note: An ARAR because it provides requirement that surface
water must not be toxic to.aquatic life (except in
small zones to initial dilution at discharge points.) Not an
ARAR if wastewater is discharged to a POTW.
Chemical-specific, POTW discharge not contemplated for
alternatives 3a, 3b, 3c.
Michigan Safe Drinking Water Act; Michigan Public Act 399
Note: Act 399 is an ARAR because although a "public drinking
water supply system" as defined under the Act does not or may
not currently exist at or near the site, ground water could
potentially be used as a drinking water source in the future.
Action-specific for alternatives 1, 2,: 3a, 3b, 3c.
Part 7, R336.1702; New Sources of VOC Emissions.
Note: This is an ARAR for new sources of VOC emissions for
new remedial action. Any person responsible for any new
source of VOC emisssions shall not cause or allow the emission
of VOC emissions from the new source to exceed the lowest ,
maximum allowable emission rates. A design consideration for
alternatives 3a, 3b, 3c since volatile organics make up a
substantial portion of groundwater pollutants, and transfer
from groundwater to air without proper treatment not
appropriate.
Michigan Environmental Response Act; Act No. 307
The substantive provisions of Parts 6 and 7 of the rules
promulgated under the Michigan Environmental Response Act (Act
307) are considered to be an ARAR for the remedial action to be
undertaken at this site. These rules provide, inter alia that
remedial action be protective of human health, safety, and the
environment, (Rule 299.5705(1)). The rules specify that this
standard is achieved by a degree of cleanup which conforms to or.
or more of three cleanup types; a type A cleanup generally
achieves cleanup to background (Rule 299.5707); a type B cleanu:
meets specified risk-based levels in a given media (Rule
299.5709); and a type C cleanup is based on a site-specific ri: •
assessment which considers specified criteria. U.S. EPA has
determined that the selected remedy meets the criteria for a t...
B cleanup of the groundwater. The State has identified Act 24
as an ARAR. U.S. EPA disagrees that Act 245 as interpreted ar. :
applied by the State, is an ARAR. Nonetheless, it is the Stat-
judgement that the selected remedial action for this site will
provide for attainment of all ARARs including the Michigan Wat-
Resources Act and Part 22 rules. The remedial action will ha:•
the migration of contaminated groundwater and restore the aqu.
20
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to a usable condition. The purged water will be treated prior to
discharge.
Long-Term Effectiveness and Permanence
This criterion focuses on any residual risk remaining at the
site after the completion of the remedial action. The criterion
assesses the adequacy and reliability of any controls used to
manage hazardous substances remaining at the site. Unlike the
criterion of protectiveness, it is possible to consider
effectiveness in terms of degree of permanence.
Alternatives 3a, 3b, and 3c provide a superior degree of
permanence compared to alternatives 1 and 2, in that the
contaminants within the aquifer system will be extracted and
given treatment. Further, both 3b and 3c are superior to 3a
because they allow for the treatment of aquifer portions which
cannot be addressed satisfactorily by 3a or Operable Unit 1.
While the ability to fully restore all portions of the aquifer
now contaminated is not certain, alternatives 3a, 3b, and 3c
clearly offer an enhanced opportunity to meet cleanup goals than
with alternatives 1 or 2.
/
Alternatives 3b and 3c meet this criterion through pumping and
treating contaminated groundwater in an effort to mitigate off-
site migration of contaminated groundwater and return the aquifer
to its beneficial use. Alternative 3a may not be as effective in
in the long term in that the uncertainty in its ability to
capture all the contaminated groundwater is much greater than
Alternatives 3b and 3c.
Reduction of Toxicity, Mobility, or Volume through Treatment
This evaluation addresses the statutory preference for selecting
remedial actions that employ treatment technologies which
permanently and significantly reduce toxicity, mobility, or
volume of the hazardous substances. This preference is satisfied
when treatment is used to reduce the principal threats at 'the
site through destruction of toxic contaminant mobility, toxicity
or reduction of total volume of contaminated media.
By providing for extraction of portions of the contaminated
aquifer which may not be satisfactorily addressed by the
implementation of the Operable Unit 1, contaminant mobility can
be substantially curtailed by alternative 3b and 3c. While
extraction rates and well locations are best left to design
phases of this project coupled with operating experience yielding
enhanced aquifer response information, up to 400 gallons per
minute of contaminated groundwater may be extracted if
alternative 3c is undertaken. Alternatives 3a, 3b and 3c also
allow for reduction of toxicity of groundwater contaminants via
physical-chemical and aerobic biological treatments. In summar.
21
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alternatives 3a, 3b,and 3c would provide reduction in contaminant
toxicity and mobility and are clearly superior to alternative 1
or 2 which do not offer such capability; no alternative would
have a pronounced effect on contaminant volume.
Short-term Effectiveness
Short-term effectiveness considers the time needed to achieve
protection against any adverse impacts on human health and the
environment that may be posed during the alternative's
construction and implementation period until remedial clean-up
goals are achieved. Important factors to consider to evaluate
the short-term effectiveness of each alternative are protection
of the community during remedial action, protection of site
workers during remedial action, and time until remedial
objectives are met.
Alternatives 2, 3a, 3b, and 3c may require the installation of
groundwater monitoring wells to complement existing wells at the
site. Such installation can be accomplished within a relatively
short time frame of 4-5 months. Some minimal disturbance to the
surrounding community may occur. Various protection measures
will require implementation during the construction phase, such
as air monitoring for the community and protection gear for site
workers.
The activity noted above should cause no more than temporary
inconvenience to the local community. Supplements to treatment
systems envisioned for Operable Unit 1 may be necessary for
alternatives 3a, 3b, and 3c. This may require excavation
activity which could result in increased dust generation.
However, both workers and the local community should be protected
through proper application of dust suppression techniques.
Alternatives 3a, 3b, and 3c should take (respectively) 24, 28,and
24 months for implementation of construction activity.
•
Implementability
This criterion addresses the technical and administrative
feasibility of implementing an alternative, and the availability
of various services and materials required during the remedy
implementation.
All the alternatives can be implemented without significant
difficulty concerning availability of extraction and treatment
component hardware. Treatability study efforts regarding
Operable Unit l will provide important design information for the
treatment system. U.S. EPA cannot judge precisely the degree of
cooperation that may be given by various property owners over th-
area of contamination. Consequently, there may be some
difficulty in gaining access from property owners to install th-
22
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extraction system.
In considering the three active restoration approaches,
alternative 3a is likely the easiest to implement. This is
because it addresses only restoration of the shallow portion of
the aquifer. Alternative 3c poses a moderate challenge. It
attempts to address both shallow and deeper zones of the aquifer,
which is a more complex design consideration. However, because
3c envisions a phased approach to well installation, any
refinement to the system should be taken in an informed manner.
Alternative 3b, which does not envision a phased approach, would
likely prove the most difficult to implement.
This criterion assesses the cost effectiveness of the
alternatives. The projected present-worth cost of Alternative 3a
is approximately $26,000,000. Alternative 3b has a present worth
cost of approximately $40,300,000, which is the highest cost
alternative. Alterntive (3c) has a present-worth cost of
$26,000,000.
Alternatives 3a and 3c are estimated to cost $26,000,000 in terms
of present net worth for installation of new monitoring wells,
data gathering efforts regarding future pollutant migration
trends, installation of extraction wells, associated conveyance
and treatment, and operation-maintenance of such devices.
Alternative 3b has a present net worth of $40,000,000 for these
same tasks. Costs are predicated to a large degree on design
and future operating experience. While a precise number and
location of extraction wells cannot be projected at this time,
design should consider those segments of the aquifer that cannot
be satisfactorily addressed by Operable Unit 1.
In terms of initial capital cost, alternative 3c is most
advantageous. For approximately the same cost, it addresses both
shallow and deep zones of the aquifer; whereas alternative 3a
addresses only the shallower area. In terms of capital,
operation/maintenance, and present net worth, alternative 3c is
superior to alternative 3b which also envisions addressing
shallow and deep aquifer zones.
Alternative 1 and 2 have far lower costs than 3a, 3b, or 3c.
However, alternatives 1 and 2 are not protective of human health
and the environment, and therefore cost comparisons are not
meaningful between such subsets of alternatives.
State Acceptance
This criterion has been explored more fully in comments the Sta"-
23
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of Michigan made regarding the Proposed Plan. As noted in the
transcript of the public meeting, the State of Michigan indicated
concurrence on the approach recommended in the Proposed Plan.
Community Acceptance
The issues of community acceptance will be addressed more fully
in the Responsiveness Summary developed for this operable unit.
If comment from Operable Unit 1 can be used as a guide, the
citizens who live in the vicinity of the site will favor
aggressive groundwater restoration efforts. PRP comments on the
Operable Unit 1 were highly negative; such comments can be
expected again for any measures beyond institutional control or
no-action.
9. Selected Remedy
Before noting the major components and costs of the selected
remedy, it is appropriate to discuss remediation goals for
groundwater at the site. The goal of this remedial action is to
restore all portions of the aquifer so that it may serve as a
drinking water resource. Some studies suggest, however, that not
all groundwater extraction and treatment programs are completely
successful in reducing contaminant concentrations to health-based
levels throughout an aquifer. U.S. EPA therefore recognizes that
review of future operating data may indicate the technical
impracticability of attaining health-based groundwater quality
standards throughout the aquifer. If, at any of the subsequent
five-year reviews, it becomes apparent that unsatisfactory
progress is being made in attaining groundwater goals, the remedy.
may be reevaluated. If the remedy is reevaluated, any change in
remedy shall be accomplished through reopening and amendment of
the ROD, to include an explanation and documentation of all
findings, in accordance with 42 U.S.C. 9261(d)(4), and 9617. The
following list notes higher levels of certain hazardous
substances detected in the aquifer below and downgradient of the
Ott/Story/Cordova site, maximum contaminant levels (MCLs)
associated with certain hazardous substances, Integrated Risk
Information Systems (IRIS) concentrations that represent a 1X10-6
cancer risk for certain carcinogenic substances, to be considered
levels, and proposed Michigan Act 307 cleanup standards which
represent a "Type B" cleanup response. ( See table on following
page.)
It should be noted that monitoring well W3 located upgradient of
the site showed no detectable volatile organic contaminants or
pesticide fractions, and for semivolatiles revealed only two
phthalate compounds at low part per billion levels.
As the table indicates, there are several hazardous substances
within the aquifer system at the site that demonstrate
carcinogenic behavior. Consequently, achieving MCLs may not be
24
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Ott/Story/Cordova
Groundwater Cleanup Goals
(micrograms per liter)
SUBSTANCE
RI FINDING
CONC. AT
MCL 1 X 10-6
TBC NATL MICH. 307
PRIMARY TYPE B
Benzene
Chlorobenzene
Chloroform
1 , 2-Dichlorobenzene
1 , 4-Dichlorobenzene
1 , 2-Dichloroethane
1, 1-Dichloroethene
1 , 2-Dichloroethene
(total cis/trans)
Ethylbenzene
Heptachlor
Heptachlor
3800
110
1900
2700
74
110000
7900
810
2100
0.15
0.49
5 1
60
0.19
600
5 0.4
7 0.06
70(cis)
100 (trans)
700
0.008 0.0004
0.004 0.0002
1
100
10
1.5
0.4
0.06
100
30
0.004
0.004
Epoxide
n-Nitroso-
diphenylamine
Tetrachloro-
ethene
46
24000
0.
Toluene
1,1,1-Tri-
chloroethane
Trichloroethene
Vinyl Chloride
Xylene(s)
93000 2000
. 3100
110 5 3
130000 2 0.015
12000
40
200
:
0. i
where MCL= Maximum Contaminant Level as per Safe Drinking Water A
TBC= To-Be-Considered as a National Primary Drinking Wat--
Regulation
1 x 10-6= level noted Jn Tntegr-Ttv.i ;\isk Information. Sysf'
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MICHIGAN LIMITS ON STREAM DISCHARGE (Act 245, Part 21; Rule 57)
for paramaters to be treated.and discharged from the Ott/Story/
Cordova site. Alternative discharge sites are located on Little
Bear Creek or the N. Branch Muskegon River at a discharge rate of
0.57 MGD.
Parameters
BAT Limits
vinyl chloride
1,1-DCE
benzene
toluene
chloroform
meth. chloride
1,2-DCA
chlorobenzene
MIBK
acetone
benzyl alcohol
4-meth. phenol
2-chlorophenol
2-ethylaniline
4-chloroaniline
tetraethyl urea
camphor
benzole acid
THF
bis (2-ethylhexyl)
phthalate
arsenic
cadmium
chromium
copper
cyanide A
lead
nickel
selenium
zinc
3
2
5
5
10
Rule 57(2)
3.1
2.6
60
100
43
59
560
71
1155
500
44
3
10
27
5
533
60
208
11
100
184
0.7
93
40
4
10
148
22
177
LBCrk. NBrMR
BAT
BAT
BAT
225
BAT
BAT
1260
160
2599
1125
99
7
22
61
11
1199
135
468
25
BAT
BAT
BAT
BAT
10327
BAT
BAT
BAT
7332
119280
51636
4544
310
1033
2789
516
27788
6196
21481
1136
BAT
241
0.9
121
51
5
11
191
29
229
4863
18
2435
977
106
130
3666
585
4435
Note :
- all units above are expressed in terms of micrograms per liter
- "BAT" refers to best available treatment
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sufficiently protective. Achieving a concentration of
contaminant that would yield no more than a 1X10-6 cancer risk
for any individual carcinogen is therefore a desirable cleanup
level for any substance which exhibits carcinogenic behavior.
Since there are several carcinogenic substances in the
groundwater, total cumulative carcinogenic risk due to ingestion
would be approximately 2X10-5. The cleanup goal is the more
stringent value listed for a given contaminant in the following
table.
Based on the remediation goals, the selected remedy for Operable
Unit 2 at the OTT/STORY/CORDOVA site is alternative 3c for
groundwater restoration. In keeping with recent guidance, U.S.
EPA believes it may be advisable to consider the phased
installation of extraction wells based on knowledge gained of
aquifer response. It is not known at this time whether such
additonal installation will be necessary, nor how many years into
the future such a step may be taken. Some changes may be made to
the remedy as a result of remedial design and construction
processes.
10. Statutory Determinations
Protection of Human Health and the Environment
The aquifer system below and down gradient of the
OTT/STORY/CORDOVA site has been severely degraded through the
introduction of contaminants associated with former material or.
product usage activity at the site. At least a portion of the
aquifer in question can no longer serve as a source of
residential and industrial water supply, which it once did. At
several locations within the aquifer, cancer risks in excess of
1X10-1 would be encountered by a potential groundwater user.
The selected remedy protects human health and the environment
with regard to contaminated groundwater. For groundwater,
extraction of contaminated groundwater, treatment utilizing
physical-oxidation, adsorption, and filtration will assist in
reducing contaminant levels. Monitoring and institutional
controls will assist in evaluating effectiveness of restoration
measures.
Implementation of the groundwater remedy will not pose
unacceptable short-term risks or cross-media impacts. With
regard to groundwater, the goal of the selected remedy is to
restore levels of risk to potential users of the aquifer to 10-6
for a given carcinogen, such that cumulative risk is below 10-4.
If this goal proves unattainable, then a possible future goal ir.
containment of groundwater contamination, and the avoidance of
pollution of downgradient aquifer portions not now known to be
affected.
25
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Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
The groundwater selected remedy is required to fully comply with
all federal and more stringent state ARARs unless a waiver is
invoked. The selected remedy complies with all ARARs. With
regard to groundwater, the selected remedy has as its goal the
attainment of all ARARs concerning degree of restoration in
conformance with CERCLA Section 121.
Cost Effectiveness
The selected remedy for groundwater affords overall effectiveness
proportionate to its cost. The groundwater remedy does promote
aquifer restoration. Alternative 3c affords a high degree of
effectiveness by promoting restoration in both shallow and deep
zones of the aquifer, monitoring restoration progress, and
providing information on how the system can/should be refined in
the future to meet remediation goals. Alternative 3c is the
least costly alternative that addresses both zones of the
aquifer.
Utilization of Permanent Solutions to the Maximum Extent
Practicable
The groundwater remedy selected provides the best balance of
tradeoffs among the alternatives considered with respect to the
nine evaluation criteria. The remedies selected also utilize
permanent solutions and treatment technologies to the maximum
.extent practicable for the OTT/STORY/CORDOVA site in conformance
with CERCLA Section 121. Beyond the criteria of protection and
ARARs compliance, the selected remedy had the best overall
balance of long term effectiveness and permanence, reduction of
hazardous substance toxicity, mobility, or volume through
treatment, short-term effectiveness, implementability, and cost.
For groundwater, a remedy invoking active restoration attempt
through extraction and treatment is clearly superior with regard
to reduction of substance toxicity, mobility, or volume and long-
term effectiveness.
The State of Michigan has been consulted during development of
the site feasibility study, proposed plan, and participated in
the public comment period.
Community views were solicited during the public comment period.
The U.S. EPA attempted to keep the community informed of site
developments via the local information repositories and by the
local establishment of certain documents in the administrative
record for this site prior to the commencement of the public
comment period.
26
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Preference for Treatment as a Principal Element
By providing treatment for contaminated groundwater collected by
extraction wells the selected remedy fulfills the statutory
preference for treatment as a principal element. Utilization of
such treatment will assist in the destruction of various site
pollutants.
11. Documentation of Significant Changes
The U.S. EPA has reviewed and responded to all significant
comments received from interested parties during the public
comment period. Comments were made on the alternative indicated
as preferred in the Proposed Plan as well as other alternatives.
Based on review of these comments, the U.S. EPA has determined
that there is no need for any significant change to the selected
alternative, 3c. In the event that additional data or
information during the design of the remedy reveals the need for
modification, U.S. EPA will notify the public of any changes to
the remedy presented here in this Record of Decision in
accordance with applicable law and Agency guidance.
27
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Ott/Story/Cordova (OSC)
North Muskegon, Michigan
Operable Unit 2
RESPONSIVENESS SUMMARY
Introduction
The purpose of this responsiveness summary is to document the
comments received during the public comment period, and to provide
the response of the United States Environmental Protection Agency
(U.S. EPA) to such comments. All of the comments summarized in
this document were considered prior to U.S. EPA's decision
concerning appropriate remedial action regarding Operable Unit 2
for the OSC site.
The responsiveness summary is divided into two parts. The first
portion provides the reader with a brief site history, and provides
an account of community involvement and citizen concern. The
second portion summarizes public comment, both written and oral,
concerning the Proposed Plan and contains U.S. EPA's response to
such comments. Lengthier comments are provided in their entirety
in the administrative record developed for the OSC site. In some
instances, comments which address a common concern or subject
matter may be grouped according to that common issue, and responded
to together.
Site Overview and Community Concern
The OSC site is located in Dalton Township, Muskegon County,
Michigan. The site is near the headwaters of a small unnamed
tributary of Little Bear Creek. Within a mile of the site there
are residential areas along Central, River, and Russell Roads.
The site has been owned by various specialty organic chemical
manufacturers. Production operations began approximately in 1957
and continued until 1985. Products made included pharmaceutical
intermediates, dyestuffs, agricultural chemicals, herbicides,
and diisocyanates.
A prominent feature of the site is the highly sandy nature of its
soils. For at least ten years, production vessel clean-out wastes
and wastewaters were discharged to on-site unlined lagoons and
allowed to dissipate into soils by seepage. By the early 1960s,
signs of groundwater and soils contamination were beginning to be
noted.
The first instances of community concern began to surface in the
1960s. For a time, contaminated groundwater was collected and sent
untreated to Little Bear Creek, beginning about 1967. Complaints
about odor followed. In the 1970s, con-unity concern again arose
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when complaints about degraded private well water supplies linked
to movement of contaminated groundwater from the OSC site were
raised. In 1982, an out of court settlement was reached between
area residents and a former site owner concerning extension of an
alternate water supply into the.vicinity of the site.
In 1982, U.S. EPA also placed the site on the National Priorities
List (NPL). In 1987, after having concluded negotiations with
potentially responsible parties (PRPs) that did not result in
private performance of a Remedial Investigation/Feasibility Study
(RI/FS), U.S. EPA conducted a "kickoff" availability session at the
Dalton Township Hall. U.S. EPA also established two local site
information repositories to inform the local residents of site
progress.
In August 1989, U.S. EPA released a Proposed Plan and FS for a
first operable unit for the site. This dealt with the matter of
intercepting that portion of the contaminated groundwater which
would otherwise enter and degrade Little Bear Creek. A public
meeting was held in August 1989. A Record of Decision for OU 1 was
signed in September 1989 and affirmed in March 1990. A further
Proposed Plan and FS were developed and released to the public in
July 1990 to address overall restoration of the groundwater as a
second operable unit.
A notice was placed in the "Muskegon Chronicle" advising of the
initiation of a public comment period for the second operable unit
on July 25, 1990. A public meeting was held at the Dalton
Township Hall on August 16, 1990 at which representatives from
U.S. EPA, the Michigan Department of Natural Resources (MDNR), and
the Michigan Department of Public Health (MDPH) explained site
history, key study findings, alternatives developed, and the
preferred alternative at the outset of the comment period. A
question and answer session followed. Oral comments on the
Proposed Plan were then taken. U.S. EPA also noted at the public
meeting its receipt of a request to extend the public comment
period. U.S. EPA announced to those in attendance at the meeting
of its intention to extend the close of the comment period from
August 23, 1990 to September 24, 1990. Subsequently, U.S. EPA
advised the general public of this extension by placing an
advertisement in the "Muskegon Chronicle".
It is U.S. EPA's belief that the following topics are of concern to
citizens who reside in the vicinity of the OSC site:
1) health concerns with regard to past and present inhalation of
air which may be contaminated due to site releases and ingestion of
water which may be contaminated by the site;
2) deterioration of warning signs in the vicinity of Little Bear
Creek and the need for replacement of those signs;
3) concern that if the U.S. EPA needs to fund a possible long term
remedy that a shortage of funds for cleanup may develop in the
future;
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recover such funds spent in accordance with its authority.
Hopefully, the taxpayer will not bear the ultimate cost of
necessary action.
Comment 2b- "...this type of desolation of our water and other
resources will never stop until the state and national Governments,
the DNR and the EPA included padlock the doors of all proven and
suspected polluters and seize all assets until each case is
resolved..."
Response 2b: U.S. EPA believes that if such environmental statutes
as the Clean Water Act, Resource Conservation and Recovery Act,
Clean Air Act, etc. and their state counterparts are vigorously
enforced, then in large measure conditions that lead to the
designation of Superfund sites will be avoided in the future.
Comment 3- "...There are a lot of things happening not just here
but everywhere and I tell you sometimes I go home and cry..."
Response 3: U.S. EPA notes that the challenge of promoting a clean
environment is indeed an ongoing and seemingly never ending task.
Comment 4- "...I'm really concerned about the fact that
incineration is even...an option..."
Response 4: While the FS developed for the site explored certain
treatment possibilities concerning site soils, incineration is not
an option with regard to the Proposed Plan for operable unit 2,
which deals solely with the question of whether further groundwater
restoration steps should be taken.
Comment 5- "...we have created our government, our EPA and our DNR
to help us and we've got to do more ourselves to support them and
to let them know that it is more important to us to have safe
standards.. .we have to create jobs that are not devastating the
environment so that the children won't grow up to have a job
anyway..."
Response 5: U.S. EPA recognizes that a sound economy is a vital
part of any community. U.S. EPA sincerely hopes that it is ably
representing the environmental interests of citizens, and looks
forward to working with the community in this regard.
Comment 6- "...It's a real crime that a site can be allowed to get
this bad...we have to have laws that will shut these places down
until everything is resolved so we don't build pollution on top of
pollution. . .we want this site cleaned up but we can see beyond this
site to this same company that polluted this area...
we're great at hindsight. They come back and say don't eat the
fish, don't sprinkle your lawns with this water, don't let your
children play in this water...The people have real concerns around
here. We don't just want to treat one situation we want to help
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4) concern that operable units will not compliment each other;
5) concern over the chemical industry in general, contaminants that
may be generated from such industry, and how to prevent similar
situations such as OSC from occurring in the future;
6) concern expressed over other.bodies of water to which the Little
Bear Creek system is tributary, and the effect the OSC site may
have on them;
7) concern over the possible interaction of contaminants already in
the environment from the site, and the new contaminants which may
be formed as a result of their interaction.
Oral Commentary Received at the Public Meeting
Comment la- "...I would hope that there were a lot more money
available to get going on this site since it's been really thirty
yeaxs since there was documented contamination and really nothing
has effectively been done to clean up the site except for removal
of some of the most hazardous substances..."
Response la: U.S. EPA notes that upon completion of design
activities for the first operable unit for this site, remedial
action funds should be available if no means of private performance
of that action are available. U.S. EPA does not rule out the
possibilty of settlement with PRPs for the second operable unit.
However, if this is not possible, U.S. EPA believes funds will
stand behind the remedial actions identified embodied in the Record
of Decision for this site. U.S. EPA notes without further comment
the speaker's view that past site contaminant control efforts were
ineffectual.
Comment Ib- "...I would like to say that I'm absolutely appalled by
the stance that the Companies are taking... these [EPA] staff
members are answering questions instead of doing what really needs
to be done. I think it's absolutely disgraceful and I think
people in this community ought to be outraged..."
Response Ib: U.S. EPA notes that it has not in the past agreed
with many of the comments submitted on behalf of the PRPs with
regard to this site. While U.S. EPA supports the right of the
public, including PRPs, to comment, U.S. EPA is appreciative of
this citizen's views.
Comment 2a- "...Unfortunately it [the Proposed Plan] is much too
late and at horrendous expense to all taxpayers..."
Response 2a: If U.S. EPA is unable to reach a settlement with the
private parties over conduct of whatever action may be selected as
a result of this Plan, then Superfund monies will be used to
finance needed remedial action. However, U.S. EPA will attempt to
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been done..."
Response 9: As in Response 8, U.S. EPA consulted with ATSDR in
preparing this response. ATSDR informs U.S. EPA that a preliminary
health assessment for the OSC site has been developed by MDPH, and
that a version proposed to be the final health assessment is
expected to be available for public comment in a couple of months.
ATSDR suggests that the speaker contact the MDPH Lansing office for
information on other area health assessments.
Comment 10- "...you'd like to get someone to take care of our
pollution problem? When you go to vote in November if it says
incumbent I would suggest that gentleman is not doing his job..."
Response 10: U.S. EPA believes no response is necessary to the
comment other than to include it in the administrative record.
:
Comment lla- "...I would like to see the site secured somehow and
controls so that they could not do that [pollute the site] because
I don't trust them..."
Response lla: If U.S. EPA believed that immediate action was
necessary to limit access as a means providing security with regard
to releases of hazardous substances such action could be taken.
Comment lib- "...I would want to be informed about any health
survey...going on in my area..."
Response lib: As with certain previous comments, U.S. EPA consulted
with ATSDR in preparing a response. U.S. EPA understands that MDPH
staff have been out to the speaker's residence and that they will
continue efforts to keep the commenter informed of survey progress
and results.
Comment lie- "...I live very close to the creek... and I have
breathing problems when I'm exposed to a fog coming off that
creek..."
Response lie: From the address given by the speaker, the creek in
question may not be Little Bear Creek but rather Green Creek. U.S.
EPA's action for the first operable unit would involve the
interception of contaminated groundwater prior to stream entry and
would offer relief from the type of problem the speaker describes,
but only with regard to Little Bear Creek.
Comment lid- "...I would like to see some sort of survey done c:
the pollutants in the bottom downstream in the lakes and in Bed:
Creek, because there is more people living over there..."
Response lid: U.S. EPA agrees that monitoring efforts are :
important part of remedial efforts, and will take this comment
under advisement.
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rewrite laws so that this doesn't continue to escalate..."
Response 6: As noted earlier (see Response 2b), U.S. EPA believes
that vigorous enforcement of environmental statutes and regulations
will help prevent instances like this from recurring.
U.S. EPA observes that under Superfund a new owner or operator may
incur liability for site conditions pending release or threatened
release of hazardous substances.
Comment 7- "...the biggest concern I have is the cop out that
Companies appear to be, one cop out they appear to be using is that
Bear Creek and perhaps some of the other smaller tributaries in the
area are not used that much for the public or perhaps their uses
are limited. But obviously these are part of a larger water shed
including Lake Michigan and Muskegon Lake...Ultimately everything
that gets put in upstream is going to come downstream ...you can't
simply say that this stream isn't used fbr much. That is not a
valid analysis..."
Response 7: U.S. EPA agrees with the speaker's points about the
interrelationship of bodies of water. U.S. EPA also notes that
according to MDNR stream classification, Little Bear Creek is
considered a high quality body of water, specifically a cold water
fishery, if left in its natural state. U.S. EPA does not
necessarily agree that what goes into one stream will be received
by the next body of water in sequence. Physical and biological
forces may change the composition of contaminants received
upstream; their concentrations may indeed be reduced at a
downstream location. However, the manner in which the reduction
took place could also have an effect upon the community. An example
might be the volatilization of certain materials into the air from
the stream, or the buildup of sludges along a stream's banks.
Comment 8- "...my concern [is] for the people that live at...the
trailer park...[the] area is not in the clean up...we lived there
from 1979 to 1981 and we did not drink the water. The smell was so
bad...I had many skin conditions when I lived there...and my nine
year old daughter has bone cancer...I would like to have the health
study included to that area..."
Response 8: In preparing this response, U.S. EPA consulted with the
Federal Agency for Toxic Substances and Disease Registry, (ATSDR).
ATSDR informed U.S. EPA that MDPH staff have been in contact with
the speaker, and that MDPH study efforts will attempt to include
that area. U.S. EPA notes that a monitoring well located in the
vicinity of the trailer park and used in conjunction with the OSC
RI effort in April 1988 did not reveal the presence of volatile
organic contaminants.
Comment 9r "...I would like to be involved in, invited to, be part
of any further health assessments that are done in this County...!
would also like input into the health assessment that has already
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are high at this site. U.S. EPA will determine if those who may be
potentially liable for site conditions are willing to undertake
cleanup measures. If there is no such willingness, U.S. EPA will
undertake necessary action itself and ultimately seek cost
reimbursement through the courts.
Comment 14- A letter received September 24, 1990 from an area
resident; the letter states in part:
"...The Ott/Story/Cordova site is one of the priorities. It looks
really bad on these people that they have been responsible for
contamination for so many years and want to drag their feet about
cleaning up their poisons...Everyone knows that the contamination
does not go away on its own. . .It would seem that they would want to
take this as a challenge and clean it up as soon as possible..."
Response 14: Issues of responsibility and liability with regard to
certain persons are now before the Court." U.S. EPA concurs with
other portions of this comment.
Comment 15- A letter received September 24, 1990 from an area
resident; the letter states in part:
"...According to the Michigan DNR, this site is the worst hazardous
waste site in the entire state...The proposed "phased"
removal and treatment of groundwater contaminants will not protect
the public and restore the environment in an effective and timely
manner. The site requires a massive effort at cleanup, regardless
of the cost...Most importantly, the lawsuit launched against the
EPA and DNR by CPC, International.. .must be dropped.. .A lawsuit
aimed at environmental agencies and officials who are attempting to
clean up this site very effectively slows the entire process...It
is an insult to the public that is unnecessarily exposed to the
many dangers of the...site...1 am particularly concerned about the
high incidence of childhood cancer and other illnesses..."
Response 15: U.S. EPA concurs that the site is of high priority
to the State of Michigan. U.S. EPA disagrees that the remedy is not
protective of the public since the goal of the preferred
alternative is to collect and treat all known contaminated
groundwater, working in conjunction with the first operable unit.
Given that cost is one of the nine criteria by which U.S. EPA is to
evaluate alternatives, U.S. EPA also disagrees with the
statement that the remedy should proceed "regardless of the
cost...". U.S. EPA recognizes the commenter's concerns over cleanup
progress and the possible effect of lawsuits on that progress.
However, the choice of dropping a lawsuit rests with the party
initiating that action.
Comment 16- A letter received September 24, 1990 from an area
resident; the letter states in part: "...I am concerned that the
cleanup at the Ott/Story/Cordova...site.. .will take much too long
under the proposed "phased" plan...No one knows how the groundwater
will flow- which way or how far...Many people...are at risk...[Arc
8
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Written Commentary Received During the Public Comment Period
Comment 12- A letter received August 20, 1990 from an area
resident. The letter states in part:
Comment 12a- "...my comments simply put are as follows: to first
research the effects of all the airborne chemicals in the impact
area on both plant and animal life..."
Response 12a: As with certain oral comments listed earlier in this
document, U.S. EPA consulted with ATSDR in preparing this response.
ATSDR has available to it various reports on toxicological profiles
of certain chemicals, and ATSDR will explore this literature as a
means of research into effects of chemicals on animal and plant
life. U.S. EPA will reference the following'toxicological profiles
as a part of the administrative record for the OSC site: 1,1-
dichloroethene; 1,2-dichloroethane; vinyl chloride; and benzene.
The first two reports were prepared for the ATSDR and U.S. Public
Health Service by Clement Associates in December 1989; the third by
Syracuse Research Corp. in August 1989, and the report on benzene
was prepared in May 1989 by the Oak Ridge National Laboratory.
Comment 12b- "...to keep the...population ...informed...as to the
health dangers...associated with the creek..."
Response 12b: It is U.S. EPA's understanding from ATSDR that MDPH
staff visited and spoke with the writer. Also, U.S. EPA notes that
the administrative record for the OSC site, notably with regard to
the first operable unit, speaks to this point and is available
locally at the Walker Memorial Library in North Muskegon. U.S. EPA
will continue efforts to keep the public informed as new
information becomes available.
Comment 12c- "...to eliminate any phase of treatment that would
risk more exposure to animals, namely surface water location..."
Response 12c: Should U.S. EPA select a remedy involving groundwater
collection, treatment, and discharge to surface water, U.S. EPA
anticipates the need to have the resultant effluent meet
appropriate limitations as established by MDNR. It is likely that
monitoring of such effluent will include both chemical and toxicity
monitoring as a means of safeguarding the surface water.
Comment 13- A letter received September 24, 1990 from an are.'.
resident; the letter states in part:
"...the pollution at this place is very bad for you, and I think
the people that are making that pollution should clean it up righ*
now. Why don't they just start today..."
Response 13: U.S. EPA agrees that groundwater contamination level
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pond usage continued to 1978.
Response 17d: U.S. EPA notes that lagoon sludges were an apparent
target of the 1977-1978 removal action. In that sense, the ponds
remained a continuing source of contamination at the site.
Comment 17e- The commenter provides discussion to refute the FS
statement that "...various configurations of purge wells were
operated between 1965 and 1972..." and notes that there was very
little operation of purge wells during those years. The commenter
notes that some production wells operated as purge wells, and the
" so-called interceptor wells...installed in the mid-1960s, were
rarely operated at any time..." Further, the commenter notes that
"...all the purge wells had severe operational problems...". Again
the commenter notes that "...contamination continued to migrate
because of the poor operating conditions of the purge wells...there
is no evidence that the entire plume was within the capture zone of
the purge wells..."
Response 17e: U.S. EPA notes with interest the above discussion.
U.S. EPA notes that the FS was prepared prior to some of the
considerable discovery effort made as a result of the on-going
litigation involving this site. Should it be necessary to do so,
U.S. EPA would be willing to add documentation to the
administrative record to accomodate an expanded base of facts. The
degree to which these wells were operated and their success,
however, does not alter the present situation in regards to remedy
selection.
Comment 17f- The commenter notes that CPC Inc. was not the sole
contributor of funds for a new water supply.
Response 17f: U.S. EPA notes the above comment, and believes no
further response is necessary.
Comment 17g- The commenter disputes the FS1 assertion that there
are incinerators in the vicinity of the site which could handle
sludges generated from remedial action outlined for OU 2.
Response 17g: The FS meant that there would be no need for a cross
country shipment. U.S. EPA notes that incinerator capability is
present in the Chicago area approximately 160 miles away where
there are RCRA/TSCA licensed incinerators.
Comment 17h- "...Neither the analyses nor the conclusions reference
in any way the human health risk evaluation for a current land use
scenario."
Response 17h: U.S. EPA disagrees. Please note page 7-87 of the RI
report for the site which discusses this matter.
Comment 17i- "...The FS inexplicably fails to include an evaluation
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we] worse off having the Superfund than if the responsible parties
were made to pay for immediate and total clean up?..."
Response 16: It is true that U.S. EPA projects many years to
accomplish clean up goals under any of the active restoration
alternatives. This is due in part to the large amount of
groundwater involved, the relatively high levels of contamination,
and the need to evaluate total extent of contamination. U.S. EPA
notes that it is possible to make certain predictions as to where
groundwater will flow, although all conceivable knowledge of the
groundwater system at the site is not known. In general, U.S. EPA
believes that area residents are better off having the Superfund
program available for at least two basic reasons: Superfund
establishes certain liability criteria within the law so that it
may be determined who potentially responsible parties may be.
Without such criteria, it might be much more difficult to determine
responsibility. Furthermore, Superfund provides a fall back so that
some action may be taken if private parties are not willing to do
so.
Comment I7a- "...Cordova/Michigan, Cordova/California, and Aerojet
request that U.S. EPA place these comments on the Administrative
Record..."
Response 17a: U.S. EPA will do so.
Comment 17b- [the persons noted above]"...hereby incorporate by
reference...comments submitted...on the Focused Feasibility
Study...those comments should be considered repeated here..."
Response 17b: U.S. EPA placed all such comments and responses
thereto into the Administrative record for OU 1. U.S. EPA's index
for the record for OU 2 notes the incorporation of the record for
OU1 into OU2, as well as particular documents added for OU2.
Comment 17c The commenter notes at length that its operations and
products are distinct from Ott and Story, and that organic
compounds detected in the soil and groundwater are the result of
operations of Ott and Story, and not the operations of
Cordova/Michigan.
Response 17c: U.S. EPA notes that the commenter may misinterpret
the FS phrase which says "...throughout much of its history...".
Given that site operations began about 1957, the phrase is
literally true as to the chemical operations noted. However, U.S.
EPA does not mean to imply that that phrase applies to Cordova
operations. U.S. EPA has no response at this time to the statement
that organics detected in the soil and groundwater are the result
of Ott/Story operations. It is not the intent of either the FS or
the Proposed Plan to make findings as to possible liability.
Comment 17d- The commenter notes as inaccurate an FS statement that
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groundwater was not evaluated ...[it] would provide the benefit of
flushing to reduce the time necessary for completing the
remediation..."
Response 17m: U.S. EPA observes that the site is near the
headwaters of two relatively small surface water bodies- the
unnamed tributary of Little Bear Creek to the east and Green Creek
to the west. A possible concern with regard to groundwater
injection is that of inadvertently creating a groundwater mounding
effect that might cause a shift in movement patterns, and impact a
water body not previously thought to be affected by the site.
Please see page A-22 of the FS for further discussion of this
issue.
Comment 17n- "...The FS fails to adequately evaluate the possible
use of certain Cordova/Michigan facilities, including the force
main line, equalization basin...
"Response 17n: U.S. EPA has no reason to believe that such devices
would be not reserved for private usage. The discharge point from
the equalization basin (the force main) goes to the POTW. As noted
in Response 17i, U.S. EPA thinks such discharge is not appropriate.
Comment 17o- "...Several options for soil remediation were either
eliminated without justification or were not considered at
all..."[for example]...biological treatment of soils..."
Response 17o: U.S. EPA notes several papers placed in the record on
the subject of biological treatment of materials. Topics include
biodegradation studies using white-rot fungus and bioremediation of
hazardous wastes. In addition, the management of soils will be a
component of OU 3 for the site. As the commenter noted, they will
have further opportunity at a later time to comment on alternatives
for OU 3.
Comment 17p- "...Another option for soil remediation that
apparently was not considered is removal of highly contaminated
soils, or "hot spots" combined with capping and containment..*"
Response 17p: U.S. EPA notes this as a prudent comment and will
give this consideration as information necessary for operable unit
3 is developed.
Comment 17q- "...While the FS makes that statement [that the
alternative selected should be consistent and compatible with the
first operable unit]...there appears to have been no attempt to
design a cost-effective treatment system that would encompass both
the operable unit and the remedy selected in the FS..."
Response 17q: It is not the function of an FS to actually perform
design. U.S. EPA does note correspondence between it and its
designer for the first operable unit in which U.S. EPA stated
"...should it be necessary to adopt other measures to deal with the
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of discharge of groundwater to the POTW...the failure to adequately
consider a discharge to the POTW is particularly inexplicable in
view of the ongoing litigation in the case of Muskegon Charter
Township v. County of Muskegon (Muskegon County Circuit Court,
Case No. 90-26094-CE..."
Response 17i: U.S. EPA notes a document dated 8/31/90 denying a
request from U.S. EPA's treatability study contractor for
permission to discharge treated groundwater to the POTW even on a
limited basis as would be the case with treatability study
discharge volume. The ability to implement a POTW discharge would
appear to be in serious doubt considering the on-going litigation.
Given this position, and recalling the comments received on this
subject in December 1989 from Muskegon POTW, discharge to the POTW
is not a matter which should have been seriously considered in the
FS.
Comment 17j- The commenter notes that a lack of pilot testing
prevents a proper evaluation of remedial alternatives.
Response 17j: U.S. EPA notes that in late 1989 results of limited
pilot testing were received and subsequently placed in the record
for this site. The FS refers to this on page 4-14.
Comment 17k- "...The FS blatantly fails to consider less-costly
remedial measures, such as supplementing the operable unit with a
more modest purge operation..."
Response 17k: Please note page 4-14 of the FS wherein it is stated
"...placement of wells for this alternative would be such as to
avoid unnecessary duplication of efforts associated with the first
operable unit...". The placement and operation of wells selected
under OU 2 are to be done in a manner that will capture the entire
Groundwater plume, ensuring prevention of further migration and
treatment to remediate the groundwater. A purge operation that is
not designed to do this is not acceptable.
Comment 171: "...The FS eliminates deep-well injection as a
disposal alternative because there would be no access to [a]
permitted facility. This basis makes no sense..."
Response 171: U.S. EPA notes that the record for the site indicates
that in the mid- to- late 1960s the concept of deep well injection
was given consideration. However, the developers of those concepts
abandoned deep well injection in favor of stream and POTW
discharge. Employment of an on-site deep-well injection facility
would not appear to be consistent with OU 1. Injection without
prior treatment would not appear to meet CERCLA's preference for
treatment. U.S. EPA questions whether deep -well injection would be
an appropriate technique given the expected significant volumes.
Comment 17m- "...The discharge of treated groundwater to the
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Response 17t: 40 CFR 300.430 notes NCP direction on conducting an
RI/FS and the selection of a remedy. This direction states in part:
"...The purpose of the remedial investigation/feasibility study is
to assess site conditions and evaluate alternatives to the extent
necessary to select a remedy...". The phased approach noted with
regard to location of extraction wells seems particularly advisable
when one considers OSWER Directive No. 9355.4-03 which says in
part:
...it will be beneficial at most sites to implement the
groundwater remedy in stages. This might consist of
operating an extraction system on a small scale that can
be supplemented incrementally as information on aquifer
response is obtained....
Comment 17u- "...The data to date suggests that there are other
upgradient sources, which have not been properly identified...".
The commenter discusses monitoring well OW-3, and states that the
source of groundwater contamination at this point (south of former
-production areas) is unknown. The commenter further states that
this point is 2400 feet south of the Site and is not hydraulically
downgradient from any site source area.
Response 17u: U.S. EPA notes the presence of N,N-dimethyl
benzeneamine in the groundwater at OW-3 during RI sampling. U.S.
EPA notes that this compound appears associated with raw materials
and products utilized during the Ott and Story periods. Figure 4-3
of the RI indicates that well OW-3 is downgradient of the Site and
well 103. U.S. EPA also notes figures 2-2 and 2-4 in the FS, which
indicate that OW-3 is south of plant areas designated as where
three feet of heavily contaminated soil were removed in 1978. U.S.
EPA further notes that well cluster W103 is located about half way
between the former production areas and OW-3. At W103 vinyl
chloride, 1,2-DCA, and benzene are all revealed at concentrations
greater than 1000 ppb.
Comment 17v- The commenter disputes an estimate in the FS that
groundwater would be cleaned up in 30 years. The commenter also
suggests that the FS does not consider remediation of soils as a
source of contamination.
Response 17v: The FS uses 30 years as an estimate, in part because
cost projections beyond 30 years begin to lose significance. On
page A-24, the cautionary statement is made that the 30-year design
life may not be adequate to achieve the remedial objective. Because
of the high concentrations of contaminants, the large volume of
water involved, and the possibility of "bleed-off" of contaminants
from silt-clay layers at depth, it is sufficient to note that
groundwater cleanup at the site will require long-term commitment.
U.S. EPA disagrees with another statement made by the commenter at
this point, namely that the FS did not consider elimination of
source materials, i.e., contaminated soils at the site. The FS did
indeed consider such materials, and these materials will be
14
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concept of aquifer restoration, we urge that such measures proceed
in the most cost-effective manner possible so as to supplement- but
not unnecessarily duplicate- extraction and treatment efforts made
with regard to the Little Bear Creek problem..."
Comment 17r- "...The FS indicates that biological sludges will be
initially disposed of as hazardous waste. The FS further provides
for delisting of sludges if appropriate....none of the soils or
solid wastes at the Site, including the residuals from the
biological treatment operations, will be listed hazardous
wastes...."
Response 17r: Residuals created must be managed in accordance with
appropriate regulations. Residuals involved may not be listed
hazardous wastes, but 25 organic compounds were added to the list
of what may make a waste hazardous through the characteristic of
toxicity. It would appear prudent to monitor residuals created
through water treatment for such characteristics. The sludge will
be tested prior to disposal. If the sludge tests positive under
the TCLP analysis it will be considered as hazardous waste and
treated as appropriate before disposal in a RCRA landfill.
Comment 17s- "...The extent of groundwater contamination has not
been defined, and hence the design and selection of a particular
remediation alternative is inappropriate...This [area near
monitoring wells W25 and W26] is a sizable area which has not been
investigated in terms of groundwater contamination and
hydrogeological characteristics, making the selection of a remedy
inappropriate..."
Response 17s: The extent of groundwater contamination is not fully
known; however, U.S. EPA believes what is known justifies selection
of a groundwater treatment remedial alternative. The NCP, at 40
CFR 300.430(a), provides that remedial actions are to be
implemented as soon as site data and information make it possible
to do so. U.S. EPA believes an important remedy component is the
development of a sound groundwater monitoring program to evaluate
effectiveness and to determine if there are other areas of
groundwater contamination which are not being adequately
controlled. One program management principle established under
that Section of the NCP is that operable units should be used when
early activities are necessary or appropriate to achieve
significant risk reduction quickly.
Comment 17t- "...Both the NCP and the U.S. EPA RI/FS guidance
documents clearly state that one of the primary goals of the RI/
FS is to define the nature and extent of groundwater contamination.
Neither the nature or extent of contamination at the Site has been
defined...the evaluation of the various purge well scenarios
presented in the FS are highly speculative and were completed
premature to defining the true extent of contamination..."
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"conservative" used in connection with purge rates, and notes
that there is a disparity between estimated capture boundaries
north and south of purge well points.
Response 17aa: By "conservative" it is meant usage of the higher
range of permeability values found in RI well slug tests, so that
the model would account for faster water travel rates. U.S. EPA is
not aware of pump tests done at the site that have stressed the
aquifer over a prolonged period. One obvious reason for this is
the problem of what to do with the large volumes of contaminated
groundwater that would result from such a test. U.S. EPA notes
that south of the wells is in a downgradient direction and it is
normal to expect a larger capture zone to the upgradient side of a
well.
Comment 17bb- "...Influent calculations were not carried through
for the preferred option...concentrations' would be significantly
different [less than] indicated in Appendix B..."
Response 17bb: U.S. EPA disagrees. The preferred alternative is
expected to have at least one well location in a relatively high
level contaminant area. Thus, not all wells in this alternative
are anticipated to be at "fringe" locations.
Comment 17cc- "...The RI did not incorporate much of the data from
the many previous investigations..."
Response 17cc: Unfortunately, U.S. EPA cannot determine what data
the commenter is referring to, and therefore cannot respond to this
comment. However, U.S. EPA did generate a large volume of quality
assured data sufficient to characterize the extent and magnitude of
the contamination and to select a remedy for OU 2.
Comment 17dd- Considerable analyses yield results falling into the
broad classification of tentatively identified compounds.
Response 17dd: U.S. EPA believes this point was raised and
discussed adequately in FFS commentary; see pages 19 and 20 of the
Responsiveness Summary for OU 1.
Comment 17ee- "...A waste is not hazardous under RCRA merely
because it contains.a hazardous constituent..."
Response 17ee: U.S. EPA concurs, but the FS statement was that soi :
contaminants may be "possibly indicative of RCRA listed waste", an:
not that it actually was RCRA listed waste. A substance may not t •
a hazardous waste but may trigger requirements that are releva; •
and appropriate.
Comment 17ff- "...There is no basis to conclude that soils would :
characteristically hazardous under existing regulations..."
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addressed for remedy in OU 3. However, the possibility of future
soil remediation does not effect the need for groundwater
remediation.
Comment 17w- "...it will be necessary to locate purge wells in the
most highly contaminated areas to minimize actual cleanup time..."
Response 17w: U.S. EPA notes this comment, and believes that a
phased approach offers sufficient flexibility to adopt such a
strategy if warranted.
Comment 17x- "...A separate and complete report should be prepared
to document the models. The report should include input/output
parameters,...the calibration process, and details of the
sensitivity analysis..."
Response 17x: Appendix A of the FS contains discussion of aquifer
layer assumptions on page A-2, hydraulic conductivity assumptions
on page A-3, defines boundary assumptions on pages A-4 and 5, and
discusses calibration on page A-7. U.S. EPA believes such
discussion is sufficient, but will add further information on
input/output data to the administrative record.
Comment 17y- "...it would seem much more appropriate to first
evaluate a line of purge wells along the central axis of the most
contaminated portion of the plume prior to installing wells near
the lateral edges of a plume... It may be that [such a line of
wells]...in conjunction with the FFS purge wells...may provide an
adequate capture zone to contain the entire plume..."
Response 17y: While these comments are directed at the FS, U.S.
EPA notes that the Proposed Plan on page 8 describes the phased
approach as "...supplementary extraction wells would be installed
in both shallow and deeper zones of the aquifer such that, in
conjunction with the first operable unit all known areas of
contaminated groundwater would be addressed..." The goal expressed
in the comment is very similar to that stated in the Proposed Plan.
Comment 17z- The commenter notes that there is no information on
capture boundaries, and that they cannot evaluate effectiveness of
purge wells.
Response 17z: U.S. EPA notes that boundary information is found on
pages A-4 and 5. Figure A-3 also helps in evaluating
effectiveness. This information was derived by plotting
groundwater contour lines on a map and drawing perpendicular lines
in order to project flow. By then noting whether a given
perpendicular line reaches a projected well location, one can make
a prediction as to capture zone. In the MODFLOW program, a change
in well locations will change projected flow lines.
Comment 17aa- The commenter asks for a definition of the term
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Comment 17jj- The Proposed Plan inaccurately states that if actual
or threatened releases from the site are not addressed by the
preferred alternative or one of the active measures considered
there may be an imminent and substantial endangerment.
Response 17jj: U.S. EPA believes that the statement in the Proposed
Plan is correct. A 5/7/90 MDNR memorandum states in part:
"...Department staff have determined that significant amounts of
contaminated groundwater continue to underflow the unnamed
tributary and Little Bear Creek...". Therefore, groundwater
contamination may threaten downgradient users or other surface
water bodies. U.S. EPA does perceive that there is imminent and
substantial endangerment, coupled with the many points in the
contaminated portion of the aquifer which now
exceed the 1 x 10-4 upper risk range.
Comment 18a- "...Neither...CERCLA nor the NCP empower the Agency to
adopt and force compliance with a vague and incomplete remedy that
lacks credible evidence that it will be effective in remediating
groundwater at the site..."
Response 18a: Part 300.430 of the NCP provides U.S. EPA with
direction on adoption of a remedy, while CERCLA Section 106 enables
U.S. EPA to secure relief upon determination that there may be an
imminent and substantial endangerment because of actual or
threatened release of a hazardous substance from a facility.
U.S. EPA is unsure of the meaning of "vague and incomplete"
remedy, unless the commenter is objecting to the Proposed Plan's
preference for a phased approach to extraction well installation.
OSWER Directive 9355.4-03, dated 10/18/89 says in part: "...it is
usually appropriate to design and implement the groundwater
response action as a phased process. An iterative process of
system operation, evaluation, and modification during the
construction phase can result in the optimum system design...".
An adoption of a remedy which calls for a phased approach is not
therefore automatically "vague and incomplete". U.S. EPA believes
that the Proposed Plan is solidly based upon the Administrative
Record.
Comment 18b- "...the sole basis for EPA's decision to implement a
second operable unit at the site is a belief that the plume of
contamination has [also migrated to] an area located almost
directly south of the plant...[this finding is] based upon a single
set of sampling data taken from one isolated observation well (OW-
3)...[and the substances found therein are not]...the signature
chemicals associated with previous plant operations..."
Response 18b: U.S. EPA hereby incorporates Response 17u into this
response. U.S. EPA disagrees that findings at well OW-3 are a sole
reason for a decision to think in terms of operable units to
address the site. As indicated in Response 17u, the presence of
di-n-octyl phthalate is not the basis for OU 2. U.S. EPA declared
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Response 17ff: There are at least three compounds (methoxyclor,
hexachlorobenzene, and 1,4- dichlorobenzene) in site soils whose
total concentrations exceed RCRA regulatory levels for hazardous
waste by the characteristic of toxicity. 40 CFR 261.11 may require
EPA to perform a leachate procedure test to see if soils need to be
considered "hazardous waste" for OU 3 discussion purposes, and U.S.
EPA intends to perform the TCLP test on those soils.
Comment 17gg- "...U.S. EPA's decision to delay a final evaluation
of soil remediation alternatives is inconsistent with the decision
to proceed with a groundwater remediation alternative... If the
Act 307 rules require reevaluation of the soil remediation
alternatives, then such reevaluation is required with respect to
the groundwater remediation alternatives..."
Response 17gg: On page 8703 of the 3/8/90 "Federal Register" in
which the revised NCP is given, it is stated that "....EPA...
promotes making sites safer and cleaner as soon as possible...and
addressing the worst problems first...." Since certain risks
associated with groundwater ingestion are higher than risks posed
by soils, it is appropriate that U.S. EPA consider groundwater
remedial action first. Further, the technology utilized to meet
groundwater ARARs is not apt to be appreciably different if cleanup
requirements should change. However, a change in soil volumes
estimated to undergo remediation due to different cleanup levels,
would potentially exert a significant influence upon remedial
alternatives.
Comment 17hh- "...It is well-known that city water presently serves
the area served by that section of the aquifer and that simple
institutional controls would preclude any groundwater ingestion
from that portion of the aquifer..."
Response 17hh: Page 8706 of the 3/8/90 "Federal Register" notes
this concept from the NCP: that institutional controls should not
substitute for more active response measures unless such measures
are not practicable. Further, U.S. EPA notes a 3/28/90 memorandum
from the MDPH which questions the viability of enforcement measures
to be taken regarding residential well installation in Muskegon
County. Consequently, it is U.S. EPA's position that institutional
controls alone would not be protective for the site.
Comment 17ii- U.S. EPA gives no basis for a goal of 1 x 10-6 excess
cancer risk for groundwater.
Response 17ii: U.S. EPA refers to the 3/8/90 publication of th«
NCP in the "Federal Register", and notes the discussion on pag«
8716 of risk range. An excess cancer risk range of 1 x 10-4 to '.
x 10-6 is, deemed acceptable, with 1 x 10-6 given as a point o:
departure. Given this NCP language and the numerous carcinogens ;•
the groundwater, it is U.S. EPA's position the 1 x 10-6 is t:.
appropriate cancer risk level for the protection of public healt!
17
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Response 18f: U.S. EPA hereby incorporates Response 17x into this
response. U.S. EPA disagrees that it is in violation of CERCLA
Section 113 (k) (2). U.S. EPA observes in addition that it is
incongruous for the commenter to declare that the Agency is in
violation of this provision in light of the failure of CPC to
provide its model to U.S. EPA. U.S. EPA believes that the proposed
plan is solidly based upon the Administrative record.
Comment 18g- Proper identification of the scope and direction of
the plume is critical to any effective groundwater remediation plan
because EPA has chosen to break this site up into operable units
and targeted the second unit for a specific portion of the plume.
Response 18g: OU 2 is not targeted for a specific portion of the
plume. As the Proposed Plan for OU 2 states on page 8: "...in
conjunction with the first operable unit, all known areas of
contaminated groundwater would be addressed...." This plan will be
implemented in phases. As previously stated, U.S. EPA believes
that it is consistent with the NCP.
Comment 18h- "...Substantial evidence, including 1990 sampling
data, demonstrate that EPA has based the second operable unit upon
an erroneous plume mapping. Proceeding in light of this
evidence would be wholly arbitrary and wasteful of time and
resources that should be used to more accurately address
contamination known to exist at the Site."
Response 18h: U.S. EPA hereby incorporates Responses 18b and 18d
into this response. U.S. EPA contends that point OW-3 appears to
be on the western edge of contaminated areas, and is not a central
point in determining if further remedial action needs to be taken
at the site. U.S. EPA is reluctant to classify one well sample (of
which U.S. EPA has not received laboratory results as yet from
MDNR's split sample) as "substantial evidence". Further, the
commenter's phrase "proceeding...would be...arbitrary..." is too
vague to make further response.
Comment 18i- CPC asserts that insufficient data exists to proceed
to remedial action.
Response 18i- U.S. EPA believes that there is sufficient data to
begin a phased approach to remediate contaminated groundwater at
the Site.
Comment 18j- "...there is only a generalized discussion of the
places where the groundwater extraction wells will be located,
appropriate pumping rates, projected contaminant removal
efficiencies, and the potential impact that second unit wells could
have on wells required in the first unit..."
Response 18 j: That is the function of an FS; more detailed
specifics on well placement, pumping rates, etc., are a function of
20
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in the ROD for OU 1 that a second operable unit would consider
"...possible remediation of the downgradient contaminant plume...."
U.S. EPA also declared in the Proposed Plan for OU 2 that OU 2
would consider "...components of contaminated groundwater flow
which were not addressed by the. first operable unit...and to seek
restoration..." of the overall groundwater situation, in
conjunction with work for OU 1. U.S. EPA notes that there are
other monitoring wells (for example, B-l and OW-8) that indicated
considerable contamination south of the plant and sufficiently west
•of Little Bear Creek such that capture by extraction wells serving
OU 1 is very doubtful.
Comment 18c- Geraghty and Miller, at the request of CPC, has
developed and is refining a groundwater flow model for the site,
which will be submitted for the record. "...When this model was
run using site-specific parameters, it found that groundwater from
the plant could not have migrated to OW-3 from the plant site..."
Response 18c: U.S. EPA is unable to consider a model which has not
been submitted for inclusion into the Administrative record or
otherwise to U.S. EPA for review. U.S. EPA disagrees with CPC's
migration contention, at least until it is known how far to the
west CPC's model's projections may have started. The
administrative record for the site indicates many instances of
releases to the environment at several site locations. It is not
inconceivable that OW-3 may have been downgradient of such a
release, especially when one considers the presence of N, N-
dimethyl benzeneamine in the RI sample for this well.
Comment 18d- "...If OW-3 is properly excluded...then...the plume is
much smaller in total area..."
Response 18d: U.S. EPA disagrees. Please see FS Appendix A,
Figure A-6. Note that in this scenario for the preferred
alternative, that the farthest new extraction well west of Little
Bear Creek was projected to be in the vicinity of well B-l. This
scenario did not envision placement of an extraction well at
OW-3, although in keeping with a phased approach, U.S. EPA expects
operation and monitoring efforts to determine the necessity of
adding other wells.
Comment 18e- "...Both. EPA and MDNR were invited to sample OW-3 with
the ES&S representative. A representative of MDNR participated and
split samples with ES&G..."
Response 18e: U.S. EPA wrote to MDNR and requested that MDNR
participate on U.S. EPA's behalf. This was done. Once again, data
from OW-3 is not part of the basis for OU 2.
Comment 18f- "...The EPA groundwater model has not been placed in
the administrative record. CPC maintains that EPA is in violation
of CERCLA Section 113(k)(2)..."
19
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Comment 18n- U.S. EPA is required under CERCLA to support remedial
decisions with a sound record of factual information. This
information should be developed prior to, not after, the selection
of a preferred remedial alternative. EPA's proposal violates
CERCLA Section 113(j)(2) and 40 CFR 300.430(e) and (f) of the NCP
and is not sufficiently well defined to be capable of
implementation.
Response 18n: CERCLA Section I13(j)(2) has to do with judicial
review, and indicates that a response action shall be upheld unless
the objecting party can show that the decision was arbitrary and
capricious based on the record. U.S. EPA disagrees with CPC's
conclusion that its Proposed Plan violates these Sections. U.S.
EPA believes that sufficient information has been obtained to make
a groundwater remedial selection consistent with 40 CFR 300.43.
See discussion in Response to Comment 17s.'
Comment 18o- "...As currently drafted, the proposed remedy is far
too vague to be turned over to a technical expert for
implementation..."
Response 18o: A selected remedial action decision by U.S. EPA is
not a detailed design document. Technical design of the remedy's
components is left to the remedial design phase under the NCP. 40
CFR 300.430(f)(1) provides that remedies selected shall reflect the
scope and purpose of the actions being undertaken and how the
action relates to long term comprehensive response at the Site.
Section 300.435(a) provides that the "remedial design/remedial
action (RD/RA) stage includes the development of the actual design
of the selected remedy and implementation of the remedy through
construction." The NCP clearly did not expect the Record of
Decision to be a design document. The ROD is meant to select
response actions that will achieve long term cleanup at the site.
It is clear that significant groundwater contamination exists at
the Site and a groundwater pump and treat program must be
implemented to clean it up. Sufficient information exists on the
nature of contamination to select technolgies capable of treating
this groundwater. It is possible that in the field work may
require some alteration or refinement of the pumping or treating
program, but that should not delay getting into the field. The
groundwater extraction wells will be installed in phases building
upon knowledge gained in implementation. Sufficient information
exists on groundwater flow and contamination now to determine where
wells must go to capture the mass of the plume of contamination
efficiently. Information gained in installation and operation of
those wells (operation of which may effect the plume and thus
selection of other extraction well locations) will be used to
select other locations needed to capture the entire plume.
Comment 18p- "...EPA has failed to show that its preferred
alternative will be effective in remediating groundwater..."
22
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the remedial design efforts. Presently, the remedial design for
OU 1 is ongoing.
Comment 18k- "...a recovery well network is proposed for pumping
the semi-confined aquifer at the site, even though the extent of
contamination has not been characterized in the aquifer amd the
effect of pumping on the shallower aquifer has not been
determined...."
Response 18k: U.S. EPA appreciates the suggestion with respect to
the need to acquire more data on the extent of contamination in the
semi-confined aquifer. U.S. EPA will ensure that this zone will be
monitored as part of the Proposed Plaan's groundwater monitoring
program. U.S. EPA refers to a 4/25/90 memorandum from one of the
Agency's Environmental Research laboratories which states in part:
"...the installation of one well in the lower aquifer may not be
adequate to effectively recover the entire plume in the lower
aquifer. . .the well in the lower aquifer should be placed in the
heart of the plume to optimize ...recovery..." U.S. EPA also
observes that excess cancer risk to a well user at one point in
the semi-confined aquifer has been calculated to be 9 x 10-4, which
is outside the acceptable risk range. In addition, the phased
approach in the selected remedy will allow the flexibility to
design ultimately the most efficient configuration for groundwater
extraction.
Comment 181- The commenter states that there is no basis to the
estimate that groundwater cleanup efforts may go on for 30 years or
more.
Response 181: U.S. EPA hereby incorporates Response 17v into this
response. The 30 years estimate was used as a basis for cost
analysis. Frankly, given the severity of the contamination at the
site it will more than likely be longer to cleanup the aquifer.
Comment -18m- "...treatability studies still must be completed
before the Agency has any idea of whether the proposed treatment
train for the groundwater will work..."
Response 18m: U.S. EPA has conducted a treatability study with
respect to the proposed use of Ultraviolet Oxidation as a treatment
technology: Please refer to the January 1990 "SITE Program
Demonstration of the Ultrox International Ultraviolet Radiation/
Oxidation Technology" report. On page 2 the report indicated:
"...the...system achieved removal efficiencies as high as 90% for
the total VOCs present in the groundwater. The removal
efficiencies for TCE were greater than 99%....maximum removal
efficiencies for 1,1-DCA and 1,1,1-TCA under optimal...conditions
were about 65 and 85%, respectively...." In addition, U.S. EPA is
presently conducting a site specific treatability study for the OSC
site, which is a remedial design component for OU 1.
21
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(Further comments with regard to Comment 18 come from a technical
appendix which accompanied the letter from counsel for this PRP.
U.S. EPA will highlight those comments from the appendix which are
not repetitive of comments within the letter.)
Comment 18t- "...the FS did not recognize the practicality of the
potential utilization of the upper aquifer remediation wells to
also remediate the lower semi-confined aquifer..."
(U.S. EPA note: this comment is discussed further in an attachment
section dealing with the semi- confined aquifer.)
Response 18t: U.S. EPA expresses reservation about this approach
primarily due to the silt/clay layer that separates the unconfined
and semi-confined aquifer portions. Extraction wells in the upper
portion may make only very slow progress compared to a well in the
deeper portion.
Comment 18u- "...the contaminant transport model used by the USEPA
appears to be inappropriate for use with the USEPA flow model...it
appears that the contaminants transport model used in the FS cannot
accurately predict the dispersion of contaminants in the
groundwater...
(U.S. EPA note: this comment is discussed further in an attachment
section dealing with solute transport modeling.)
Response 18u: The MOCFLOW "modeling effort had as its goal a worst
case look at where the plume may go. U.S. EPA notes that such a
two-dimensional model is indeed inadequate to precisely predict
cleanup time. However, the key point is that U.S. EPA is not aware
of any model that could accurately predict this. U.S. EPA
believes an investigator could spend thousands of dollars and a
great deal of time in attempting to calibrate a three-dimensional
model, and not have it be particularly accurate until extraction
wells were actually turned on and one began to get feedback on such
important site issues as "how quickly will the silt/clay layers
yield the contaminants now adsorbed to them?"
Comment 18v- "...USEPA's technical rationale for lumping together
different organic compounds into a single measurement for the
purpose of estimating the extent of the plume is not well
conceived...organic compounds with different adsorption
characteristics migrate at different rates...USEPA fails to provide
evidence that all contaminants in the plume have the same
retardation characteristics..."
Response 18v: U.S. EPA hereby incorporates Response 18u into this
response. It is true that different organic species will have
different retardation coefficients. However, there are so many
organic compounds associated with the OSC site that it would be a
herculean effort to have a model account for the movement of
individual species. Further, U.S. EPA is unaware of how such a
model may account for biodegradation effects within the aquifer,
-------
Response 18p: U.S. EPA has stated in the Proposed Plan that all
known areas of contaminated groundwater should be collected by
extraction wells usage. U.S. EPA does not dispute that the task of
cleaning site groundwater will require long term commitment.
Comment 18q- The commenter asserts that EPA's usage of a Section
106 order was "draconian", and that there is no immediate and
substantial hazard.
Response 18q: U.S. EPA's issuance of an order regarding OU 1 to
CPC is not relevant to the selection of this remedial action for
OU 2.
Comment I8r- "...The record before the Agency indicates that there
is no benefit associated with the adoption of piecemeal or stopgap
measures..."
Response 18r: On page 5 of its Proposed Plan, U.S. EPA notes that
OU 2 "...is intended to consider the whole area of contaminated
groundwater...". U.S. EPA disagrees that this is a piecemeal
approach to site management. U.S. EPA believes that the phased
approach is the most effective means in remedying the site
groundwater contamination. It is consistent with the directives of
40 CFR 300.430(a) for taking action as soon as site data and
information make it possible to do so.
Comment 18s- "...CPC stated as early as 1981, and continues to
believe, that no achievable means exists whereby contaminants in
this aquifer can be removed...to the point of restoring groundwater
at this site to the rigorous potability standards required for
public water systems..."
Response 18s: U.S. EPA contends that one of the main reasons for
the belief posited above is the very high levels of contaminants
found in the aquifer below and downgradient of the site. Surely the
high degree of contamination is not sufficient reason to refrain
from considering the undertaking of remedial measures.
The goal of this operable unit is to restore the aquifer to its
beneficial use. U.S. EPA will do everything in its ability to
achieve this goal.
Comment 18t- "...Unless and until EPA can present a plan of
remedial action that is sufficiently definite to evaluate whether
its ends can be achieved and describes the means that must be
designed and implemented to meet these ends, CPC would decline all
participation in EPA's proposal..."
Response 18t: It is impossible for U.S. EPA to compose a Proposed
Plan with, in essence, all remedial design work included therein.
U.S. EPA contends that it has appropriately characterized the OSC
site in regard to the OU 2 and has provided sufficient detail to
select a remedy.
23
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unnamed tributary. Consequently, river cells are an acceptable
choice.
Comment 18aa- "...cells along the southern constant head model
boundary are too close to the NOR-AM extraction wells..."
Response 18aa: There is a distance of some 2000' from the model's
southern boundary to the NOR-AM wells. U.S. EPA believes that it is
important to note that there are indeed area groundwater users.
Comment 18bb- "...USEPA has no clear-cut remediation goal for the
OU 1...extraction wells in terms of a definite zone of capture..."
Response I8bb: The goal of OU 1 is quite explicit. It is
remediation of the Little bear Creek system, not aquifer
remediation. Such wells will be of assistance in an overall aquifer
remediation program. Design flow rates may indeed vary from FS
projections, but it is not the function of an FS to provide all
design details necessary to undertake remedial action, it is to
explore if certain alternatives may be feasible for site remedy.
Comment 18cc- "...restoring the aquifer to its highest beneficial
use...provides no measurable benefit...since no biota are affected
by the groundwater plume and the aquifer is not being used for any
purposes..."
Response 18cc: This portion of the aquifer once served as a
drinking water supply. Further, in light of the evidence from MDNR
as to creek underflow by groundwater, U.S. EPA believes there may
be a threat to downgradient users. U.S. EPA believes it is
incorrect to think in terms of the aquifer "ending" at Little
Bear Creek. In addition, the NCP is quite clear in stating
Superfund's goal to return usable groundwaters to their beneficial
uses.
Comment 18dd- "...protection of Little Bear Creek is a valid
remedial objective since at that point migration of the plume was
identified..."
Response 18dd: U.S. EPA concurs. The goal of OU 1 is the protection
of Little Bear Creek.
Comment 18ee- "...It has been shown that no water quality criteri >.
have been exceeded due to the plume's discharge into the surfao
water..."
Response 18ee: U.S. EPA disagrees. Please see corrected and revis-
RI pages 7-26, 7-27; and revised FFS pages 1-5, 2-9, and 3-4.
Comment 18ff- "...The FS proposed groundwater system
inconsistent with more typical arrays of unit treatmcr
processes..."
26
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creation of "daughter" compounds, etc. In plain terms, there comes
a time when it is time to say "Ready. . .Set. . .Go", and do some
cleanup. U.S. EPA is confident that it has accurately enough
characterized the extent and magnitude of contamination at the OSC
site to select a remedy.
Comment 18w- "...During the RI, only one well...was tested using
slug injection and slug extraction methods...numerous slug tests
are necessary to evaluate the spatial variability...of the
hydraulic conductivity field...no pumping stress was applied to a
well..."
Response 18w: A primary reason as to why no pump tests have been
done to date is that to yield meaningful results the aquifer must
be stressed over a substantial period. To stress this productive
aquifer would require the extraction of a large volume of water.
However, it should be noted that U.S. EPA does not believe this
type of information would at all have any effect on the selection
of remedy. In addition, as a part of remedial design for OU 1 a
pump test will be conducted.
Comment 18x "...it is probable that USEPA's flow model for the site
is a three-dimensional application using MODFLOW, a program
developed by the USGS..."
Response 18x: Appendix A of the FS declares that this is indeed the
the case. U.S. EPA notes the comment concerning USGS, and notes
further that this would indicate the model is in the public domain.
Comment 18y- "...All modeling performed by USEPA neglects regional
components of groundwater flow...USEPA's modeling analysis
extrapolates onsite hydraulic gradients to the boundaries of the
model...this technique is subject to large uncertainties..."
Response 18y: Hopefully, a model is to be some representation of
what is actually happening out at a site. The course of the RI
study yielded specific site information on hydraulic conductivity,
groundwater levels, thickness of soil layers, stream flow, etc. It
seemed prudent to utilize such data in helping to calibrate the
model. U.S. EPA questions whether the extra expenditure of
resources would have been justified to calibrate using regional
components of flow. U.S. EPA is confident in the degree of
calibration for the model and notes that with any model, until
actual pumping occurs, model predictions are subject to error.
Comment 18z- "...the river cells used to simulate the unnamed
tributary...are inappropriate for a stream supplied mainly by
groundwater base flow...drain cells offer a more appropriate
boundary condition for the simulations..."
Response 18z: In model efforts for the OSC site, it is more
important to describe effects upon Little Bear Creek, and not the
25
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Response 18jj: U.S. EPA cannot determine what is meant by
"unexpressed factors or policy", and cannot respond further to this
portion of the comment. The contamination problems at the OSC site
are severe, and in that sense remedy is expensive. However, the
preferred alternative U.S. EPA identified in the Proposed Plan for
OU 2 is the most cost effective of the active restoration
alternatives. U.S. EPA disagrees that a phased approach to the site
is a piecemeal approach.
Comment 18kk- Appendix 3
Response 18kk: U.S. EPA observes that Appendix 3 is a technical
literature review assembled by counsel for CPC. The papers cited
therein point to the complexity and difficulty of fully remediating
groundwater through pump and treat remediation. U.S. EPA concurs
that groundwater remediation is a complex task. U.S. EPA does not
agree on certain specific points made by counsel. These include:
"...risks allegedly posed by a contaminated aquifer that has not
been used since the 1960s...". U.S. EPA notes "1960s" is surely in
error, since the record for the site notes residential well
complaints, sampling, and concern throughout the 1970s.
"...actual field evidence shows that the techniques currently
available for pumping and treating groundwater to these low levels
are not implementable...". U.S. EPA notes that the techniques
surely are implementable, but rather their ultimate success in
bringing about complete restoration may be difficult. U.S. EPA
notes that simply because the ultimate success of a given course of
action may be subject to question, that is not sufficient reason to
refrain from seeking relief through the techniques currently
available.
"...In the proposed remedy and FS, EPA does not cite or make any
comment upon the large body of literature casting doubt upon the
effectiveness of attaining the major goal of Operable Unit No. 2,
i.e., groundwater remediation...". U.S. EPA notes however that the
administrative record for OU 2 has several recent papers on
groundwater literature. These works include:
Groundwater research involving Superfund — specifically pp. 20-22
on Superfund Aquifer Remediation Research, "EPA's Approach to
Evaluating and Cleaning Up Groundwater Contamination Problems at
Superfund Sites", "Superfund Groundwater Issue-Facilitated
Transport", "In-Situ Aquifer Restoration of Chlorinated Aliphatics
by Methantrophic Bacteria", "A Guide on Remedial Actions for
Contaminated Groundwater", "Federal Glossary of Selected Terms-
Subsurface Water Flow and Solute Transport",
the SITE UV Oxidation bulletin noted earlier in this Responsiveness
Summary, "A Catalog of Research-New Technology Under Study",
"Remediation through Groundwater Recovery and Treatment",
"Groundwater Cleanup at Several Superfund Sites", "Predicting
the Fate and Transport of Organic Compounds in Groundwater"
Comment 19- A letter received September 24, 1990 from the West
28
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Response 18ff: FS sequencing of treatment units does not mean that
a designer does not have some flexibility to optimize the system.
The remedial design is the appropriate stage to develop plans and
specifications for the implementation of the remedy.
Comment 18gg- "...a filter is usually placed before the carbon unit
and/or backwash and chlorination system is installed in conjunction
with the carbon system in order to remove the inorganic
particulates that would otherwise accumulate onto the carbon..."
Response 18gg: U.S. EPA appreciates these comments on maintenance
aspects, and will place them in the record and route them to its
design and treatability study contractors for their consideration.
In like manner, U.S. EPA will inform its treatability study
contractor of views expressed by G & M on UV oxidation. (In a like
manner, U.S. EPA will transmit comments on soil characterization
and soil remediation technologies to the ARCS contractor who will
be performing tasks necessary for the development of OU 3.) U.S.
JEPAr would like to add that this comment in no way affects the
selection of remedy for OU 2.
Comment 18hh- "...The USEPA...[FS] proposes a complex groundwater
system that includes as many as four unit treatment processes..."
Response 18hh: U.S. EPA notes that the number and high
concentrations of contaminants in the groundwater system present a
complex treatment task, as well. The on-going treatability study in
conjunction with the remedial design will ultimately determine the
appropriate combination of treatment processes necessary to
adequately treat the contaminated groundwater. This is not an issue
for the selection of remedy process.
Comment 18ii- "...No analysis exists that completely and
conclusively relates the source of contamination to the impacts on
the environment and thereby to the degree of cleanup that should be
achieved in each environmental medium..."
Response 18ii: The degree of cleanup that should be achieved in a
given environmental medium is established through compilation of
ARARs and the development of a risk assessment. How the
contaminants may be impacting the environment is one function of
the risk assessment .process. Both the FS and Proposed Plan noted
important ARARs for the site, and the RI contained an assessment of
risk. U.S. EPA notes that the risk assessment demonstrated that the
risks to public health from ingestion of contaminated groundwater
is several orders of magnitude above U.S. EPA's acceptable risk
range. The OSC site is considered one of the most hazardous siter
in Michigan due to the severity of groundwater contamination.
Comment 18jj- "...due to unexpressed factors or policy, the USEF/
may continue to propose an expensive, piecemeal approach t
remediating the Site..."
27
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f VO. 1
30
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Michigan Region Environmental Network in regards to the OSC site.
The letter states in part:
Comment 19a- "...upon reviewing the Administrative Record...it
appears that the site has been adequately and responsibly
studied..."
Response 19a: U.S. EPA concurs that study has now been adequate to
decide upon remedies for the site.
Comment 19b- "...the levels of contaminants reported in the
groundwater are tremendously high...all evidence suggests that a
serious health threat to the public health exists..."
Response 19b: U.S. EPA concurs.
Comment 19c- "...When will the actual cleanup begin?"
Response 19c: It is U.S. EPA's goal that work be under way by mid
1991 to install devices needed to serve the first operable unit.
Comment 19d- "...We understand that the chosen plan for groundwater
cleanup, a phased approach, appears prudent and cost-effective.
Unfortunately, such a plan cannot provide the speed and
thoroughness required at this site..."
Response 19d: U.S. EPA notes that the groundwater contamination
levels at the site are severe enough, and the volume of groundwater
affected large enough, that groundwater remediation must of
necessity require a long- term committment.
Comment 19e- "...we would also like to request a meeting with the
appropriate EPA officials in order to find out what actions that
Muskegon County citizens can take..."
Response 19e: U.S. EPA would be pleased to cooperate.
29
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Ho.
'ICHB/tmi IACtS DATS
1 89/11/00
2 89/12/00
Qir/STORI/CORDOVA, HI, OPfRABLS SUIT 12
If tit AH and indices for Operable Volt II are
berebf incorporated bf reference into the 2nd Operable
TITll
AUTBOR
RtCIPIUT
rut
Variance (or Retedial
Actions
VStfA Directite
9200.S-2S1TS
BSIPA
Viirificitioo (Suidascel
Superfund LDR Guide 17
Detenininq Kbes Land
Disposal
RtstrictloostlDKI
Are Relevant and Appro-
priate to CtRCLA Response
Actions - VStPA OSm
Publication
VSEtA
Otber
20
Otber
5 SO/01/00
22 10/02/00
3 S3/11/10
6 83/11/10
137 86/07/00
'Superfund Records
of Decision Update'
'Questions aod Ansvers
Regarding the 1J90 ICf
'Calculation of an
Acceptable Lerel for
PCEs in Soils and
Surfaces there tbe
Potential for ffuiao
Contact fusts'
'Riskt tret fCBs'
Hob He Treatieat
Technologies for
Saptrtaad tastes
Interii tdition
astPA
VSSPA
H. Clark,tb.D.,VSltA
K.Clark,Ph.D.,VSm
UStPl
Otber
Otber
Reports/Studies 24
Reports/Studies .'5
/Jeports/Studies :i.
19 88/01/12
12 SJ/0J/H
Ott/5torf/Cordora Site
Crouad Penetrating
Radar Surrey
'Ketals in Soils:
A Brief Suiiarf,
vitb transiittal
leto
UStPA
t.Barrett.VSlPA (author
of paperhK.Bttq,
OSlPAlaatbor of teiol
t?A foiics
Coordinators
Reports/Studies
Reports/Studies
-------
(M/06/90
PAGES DATE
5 00/00/00
4 87/01/00
7 83/00/00
5 SS/Of/H
81/07/00
4 8S/07/0J
39/07/00
IKDEI
orr/sTORi/coRDou, w« OPMMM w/r /2
(fie Afl jotf iodkjs for Op«ra6J< Pfl/t /J art
incorporated by rtftrtoce iate tb< 2ai Opettble
TITLE
Cosure Options for
Superfund Sites'
Stsurcb
Description
norson
USSPK
OSSPH
(75m -
MCIfJW
J.Baltj,D.laaq,
L.UtrriatoD
Suptrfuod LDP, Guidt /<
Coipljiog titb tbt
Saner Restrictions
Under Land Disposal
Sestrictioos ILDRs)
Paper: 'Efk's Approach
to frajoatio? and
Cleaning Up Cround
facer Coatauoatiofl
at Superfund Sites'
OStlR Directive
935S.O-28-. Control of
Mr Siissions !roi
Superlued ^ir Strippers
at Suptrfunil CrtuiDdvater
Sites IGuidance)
Supertvnd lt>* Guide 12 VSIH • Dir.JJ47.J-J2fS
Cotpljing titb the
California List
Restrictions Under
Land Disposal Restric-
tions (LDRsI
oocumr
Otfcsr
Otfi«r
DOCHVHHR
12
Otner
asm
Other
15
Otter
5up«rfood Lflfl Gviit n
Treatient Standards and
Kinitut Technology
Rtquireitnts Under Land
Disposal
RestrictioaslLDRsI
Superfuod LDR Guide 15
Detenininq Hben Land
Disposal Restrictions
ILDRs) Are Applicable
to CERCLA Response
Actions
Superfund LH C-uiit tlA
Obtaining a 5:iJ and
Debris Treat^:litj
mn-oit.93ti.nm
Otb.tr
ism - Dir.13V.3-05lS
Other
VSSPA - CJr.?J47.j-05fS
frier
-------
new/mm FACES DATE
mow mm
HI, mums WIT 12
DOCVHHTS LISTED AM tOJ COPIED /OR m
BUT KM BS w;mo AT ostPA.RKion r CHICAGO
rim
oocamr
89/08/00
89/10/00
89/04/00
00/00/00
Superlund Crouodvittr
Issue - Ficilitittil
TtiDSpon. OSWR •
OSSPA
'fidiitattd traosport*
is defioti as aof process
that bas tbt potential to
sped tbe transport of a
pollutant bejeai vbat is
eipectei uotf«r idealized
flov, and is ao issue of
potential coocero to
5uper-
fuod decision taken
KCttH MMs - Focus on UStPK
Closure Requiretents.
VSSPK OSm Directive
92)4.2-04 PS. This
fact saeet addresses
CKRCH cotplitnce vitb
SCSI Subtitle C
Superlund looomire OSSPK
fecbnoloqj Sraluation.
IPH/S40/SS-89/OQT.
Sbirso Pilot Sale Infra-
red Incineration Systet
at tbt Rose Jovosbip
Deiode
Road Superfond Site
Pirtortance Snluaticn l/5m
ot Puip-aod-trett
Reiediations. QSVSR-
EPK/S40/4-89/OOS
Other
Otber
Otbtr
89/08/00 Jo-Sito Aquifer '
Restoration of Chlori-
nated Aliphatic: fcf
KethaDotropbic Bacteria.
- Held eiperitentatiot
joroJno? iocroducio;
ittbiDt and oifqen into
aquifer to encourage
grovtb
ot bacterial ccnunitj to
R.Ketr.SSlPA;
forirooicotaJ Research
Lab, EPA/600/52-89/033
Other
-------
ncHt/rms PAGES DATS
muimnrirt
OTt/STORT/CORDOVA, il, OPSRABLS SUIT H
(The Alt mi indices (or Operable Vait II ire
berebf incorporated if reference into tie 2nd Operable Unit)
TIHS
MTBOR
mmw
DOCUHMT
DOCHUHBSlt
S( 8!
2 S9/11/W
103 89/11/99
S9 89/12/29
Bvaluitica of GrouDdvater VSSPA
fitractioo Ktiediei
Volute I Sunarf Report
OSIPA
Reports/Studies 2?
iraJoatJou
DttoDstratioo Bolletia
tlltrariolet Radiation
and Oiidatioo
KHHK Natural Resources
Coitissioo -
Sariroaieotal
Coataiinaticc Response
Activity
Sraluatict of Advanced
OzjdacJofl Process
Including HJ/Oiidation
and the Ultroi Process
(Transitttal letter
attacked)
Reports/Studies
JO
HOUR
Reports/Studies
JJ
Slack 4 Veatcb
VSSPA/CB2K Bill Reports/Studies
-------
Fa?e Ha.
(M/flf/SO
TITLS
oocmurs uoti
, HI-, ommi axir n
Guidance Docatenti art available tot reviev at
VStPA Region V-Cbicago II
HUMOR
OAK
'Verification of
PCB Spill Cleanup
By SaipJiaj and
Analysis'
'field K'anual for
did Saipling of .
PCB Spill Sites to
Verify Cleanup'
'Developieat of
Adrisory Levels for
Polycblonnated
BipbenyislPCBs)
Cleanup'
Sipbeoyls
Spill Cleanup Policy
Project Suiiary
Derelopieot of Advisory
Levels for Polycblori-
nated BipbenylslPCBs)
Cleanup
'A Cuide to Developing
Superfuni Proposed
Plans'
Kidvest Research Inst. for J5/08/00
BStPA
Kidvest Research Inst. tor Sl/OS/00
IISSP A
UStPA S(/05/00
federal Uegister Fo.SMo.JJ «7/0
-------
•age So.
M/flS/Sfl
mow
ni: otmm mr n
- m Docmurs iisris m nor COPIED rot m
BUT KM BS mism M vsm.Ridoii r CSJCAGO
PAGES Dm TITLE
help degrade chlorinated
aliphatic solvents.
8S/08/OQ Seoreiediatioa of COD-
tatioated Surface Soils
MIBOR
RECIFIEM
oocvmr
K.Kerr.VSEPA;
Research laboratory,
Other
-------
ADMINISTRATIVE RECORD
ACRONYM LIST
OTT/STORY/CORDOVA, MI REMEDIAL SITE
(OPERABLE UNIT #2)
ARARs Applicable or Relevant & Appropriate
Requirements
CERCLA Comprehensive Environmental Response,
Compensation & Liability Act
MDNR Michigan Department of Natural Resources
NCP National Contingency Plan
j
OSWEP Office of Solid Waste & Emergency Response
PCBs Polychlorinated Biphenyls
RCRA Resource Conservation & Recovery Act
RPM Remedial Project Manager
USE PA United States Environmental Protection
Agency
US DOI United States Department of Interior
US DOJ United States Department of Justice
-------
•sgi A'i?.
Oi/OS/90
Tint
Transport'
Record of Decision for
lairchild Seiiccnductor
Site. California
Record of Decision for
tulton Ttninal Site, J?F
GUlDAICt DOCUKtllTS IHDSI
OTT/STORI/CORDOVA, HI, OPERABLE mr n
Guidance Docutmtt are inilstlt for rent* at
VSSPK Region V-Cbicago II
KUTHOR
usse/i
USSPA
69/09/00
69/09/00
'Grotiodfater Research'
(iote esp. pp.20-22
oo 'Superfund Aquifer
Reiedittioo Research')
bf USSPK Office of
Technology Transfer and
Regulatory Support
'Detertiniag Soil
Response Action levels
Based OD Potential
Contaiinant Migration
to Ground Hater: A Coi-
peadiui of Eiaiples'
bj USKPA Office of
Sierqency & Reiedial
Response
Hicbiqao Act to.Ml
(Proposed Version as
of 11/9/691 to-be-
considtred laterial
proiuJjatioo pending-.
consider AM status
Risk Assessient
Guidance for Superlund
Volute I Hoiaa Health
Evaluation Kanual
(Part A) Intent Final
IPA 1600-1/89/086
69/10/00
SPA StO/2-81/051
69/10/00
69/11/09
VSSPA
69/12/00
-------
r.,. Ho. 2
06/02/90
FICHS/FRAKE PAGES DATE
3 89/89/14
ADMimSTRATIVS RECORD IXOEI - UPDATE II
OTT/STORf/CORDOYA, KIi OPERABLE Dili 12
(The AR and Indices for Opmblc Halt II art
hereby incorporated by reference into Operable Doit 12)
TITLE
ADTBOR
for 38 Inorganic and
Organic Drinking
Vater Cootaiinaots
Neio rectification of J. Cannon, USEPA
Out-of-State Shipients
of Superfond Site
Hastes
RECIPIEIT
DOCOKENT UH
USEPA Regions I-I Guidance
DOCHDHEER
12
6 89/10/00 CERCLA Coipliance vith OSEPA
Other Lavs Kanual
RCRA ARARsi focus on
Closure Requireients
5 89/12/00 CERCLA Coipliance-Vith DSEPA
Other Lavj Kaoual
Overviev of ARARsrfocas
on ARAR Vaivers
Guidance
Guidance
13
14
16 89/12/15
90/02/15
2 90/03/27
Keio re: Accelerated D. Clay, OSEPA
Response at KPL Sites
Guidance
(OSVBR Dir. Ho.9200. 2-02)
Keio reifioal P.evisloos B. Longest II, OSEPA
to the national Contin-
gency Plan
Keio reijcreeoing
reviev of treatieot
technologies for soils
and jedlieot! at the
St.Louis River site
P.dePercin.OSEPA
DSEPA Regions I-I Guidance
DSEPA Regions I-I Guidance
D.Siebers,DSEPA
Guidance
15
17
13 90/04/00 Drinking Vater
DSEPA Office of
Regulations and Health Drinking Vater
Advisories
Guidance
2 90/04/06 Keio reiVater Division D.Bryson,DSEPA
Reviev of draft proposed
plan
I 90/04/10 Keio stating that R.Bart,DSEPA
Unilateral Adunistrative
Order for 1st operable
ucit vjs issued; no
resp^se ?M? tee;
received
froi FRFs vitt inteotiCD
D.Ollrich.USEPA
S.Ratbao,DSEPA
Keiorandui
-------
Page So. I
06/fl2/90
PICBE/PRAKE PACKS DATE
TITLE
ADKIHISTRATIYE RICORD IIOE1 - OPDATE II
OTT/STORT/CORDOYA, HI. OPERABLE OUT 12
(The AR and indices for Operable Unit II art
hereby incorporated by reference into Operable Onit 12)
AUTHOR
REC1PIE1T
DOCOHERT TTPB
DOCIOKBBR
1 90/83/38
4 90/03/30
Pon letter in response
to citizens' questions
and concerns, reihealtb
surveys to be conducted
B.Boyle,loteragency
Center for Health and
EnriroQieotal Quality
Letter coueoting on J.Pilpu«,KDPH
reviev of draft proposed
plan, concurring vitb
later Supply Division's
support for the pre-
ferred groundvater
treatieot alternative
Citizens
Correspondence
D.Jordan-Izagoirre,A Correspondence
TSDR
2 98/04/10
90/05/04
90/05/08
Letter rei2/H/90'
correspondence froi
DSEPA to HDHR dis-
cussing draft ROD
language for tbe site
Letter traosiitting
the ROD and PPS for
the 1st operable unit
letter reireviev of
DSEPA's ARARs subiittal
(.Bradford,HDRR
R.Hart,DSEPA
R.TaszreaMDHR
J.DiUoii.OSEPA Correspondence
J.PalensU,OS Any Correspondence
COI
R.Iart.OSEPA
Correspondence
89/12/00 CERCLA Coipllaoce DSEPA
Kith State Requireteotsi
Quick Refercoct fa:t
Sheet
Pact Sheet
Eomoaieotal Pact Sheet: OSEPA
Foiicity Characteristic
Rule Pinalized
Tbe final national
Contingency Fhoi lev
Directions for
Superfuod
USfPA
Pact Sheet
Guidance
88/03/03
12 88/12/05
DRAPT Kater
Criteria Suiiary Chart
USIPA
Heio re.Table cf R.Idano«icz,OSEPA
Drinlting Va**r Sindards
and Health Adnscries
Guidance
GSEPA perioooel Guidance
8 89/00/00 Proposed Re^ireieats
-------
>»,< No. 4
PICKS/FRAME PAGES DATE
T9 00/00/00
19 89/94/14
15 89/10/80
139 90/01/00
90/05/07
ADKimSTRATlYE RECORD 1IDEI - UPDATE II
OTT/STORY/CORDOYA, Kit OPERABLE OIK 12
(The AR and ladled for Operable Dolt II are
hereby incorporated by reference into Operable Doit 12)
HUB
Rot Fungus
Vacum-Assisted Steal
Stripping to Rewe
Pollutants froi
Contaiinated Soili
A Laboratory Study
A Field DeioostmioD
of tbe DV/OiidatioD
Technology to Treat
Ground Kater Contaii-
nated vitb 70Cs
Preliiinary Health
Asstisient
1989 Report oo Great
Lakes Hater Quality
Appeodiz A
Progress in Derelopiog
and Iipleieatiog P.eiedial
Action Plans for Areas
of Concern io Great Lakes
Superfuod Technology
Evaluation Reporti
SITE Prograi Deioo-
stration of the Ultroi
loternatioo Oltraviolet
Radiatioo/OiidatloD
Technology
Work Plan
Treatability Pilot
Study
AUTHOR
Geosyathetic Research
Institute i DSEPA
RECIPIEIT
DOCDKERT TTPE DOCRUKBGR
Reports/Studies
DSEPA aod PRC Eofiroo-
leotal Kanageient, lac.
ATSDR
Great Lakes Kater
Quality Board
Reports/Studies
31
Reports/Studies
Reports/Studies
32
33
osm
Reports/Stadies 14
Vaste Science &
Technology Corp.
DSEPA
Reports/Studies 35
-------
Page Ho. 3
06/02/99
nminm PAGES DATE
i 90/04/16
1 90/95/08
RECORD UDEI - UPDATE II
OTT/STORY/CORDOVA, KIi OPERABLE OUT «2
(The AR and iodkei for Operable Doit II are
hereby incorporated ky reference into Operable Bait 12)
TITLE
to coiply vitb the Order
K«io reireviev of
draft proposed plan
for tbe second of t»o
planned operable uoits
Heio reiCoiients on
Feasibility Study for
tbe site
AUTHOR
luao-Mai Tran.OSEPA
B.Blaney.OSEPA
Office of RiD
RECIPIEIT
R.Hart.BSEPA
D.Yeskis.OSBPA
DOCUKERT TTF8
Keiorandui
Xeioraodui
DOCHUMBBR
21
22
Treatability Assessteot
Planoing Guide for
Solidificatioo/Stabili-
ntioo of Cootaiiaated
Soils
Ceoter Hill Solid
and flazardooi Kaste
Research facility, 0
Other
23
2 89/04/08
1 89/06/21
2 90/02/00
10 00/00/00
RPM's note to reviems
of tbe first draft
proposed plao,
discussing soils
alternatives
Superfund Innovative
Technology Evaluation
Deionstratioo Bulletin
Organic Extraction
Utilizing Solvents
Telephone Conversation
between USEPA and CB2X
Hill
re i Ror-Ai Cbeiical
Production (ells
Superfund Innovative
Technology Evaluation
Deionstration Bulletin
In-Situ Steai/Hot-Air
Soil Stripping
Abstract: Rtioval
of Soluble Toiic
Ketals froi Hater
R.Bart.BSEPA
DSEPA
B.RuodelUlacUVmcD
BSEPA
Various Authors
Other
Otaer
25
Otber
Other
Reports/Studies
13
Bench-Scale
Biode?radatic2
Studies Kith Organic
Pollutants Oiing a Vhite
Various Aotbors
SJSEFA
-------
ADMINISTRATIVE RECORD INDEX (ATTACHMENT)-UPDATE #1
OTT/STORY/CORDOVA OPERABLE UNIT #2
USEPA BELIEVES THAT CERTAIN ARTICLES APPEARING IN VARIOUS
ENVIRONMENTAL JOURNALS MAY BE OF INTEREST IN HELPING TO
UNDERSTAND TECHNOLOGY ISSUES WHICH MAY BE OF RELEVANCE TO
SITE DECISIONS. HOWEVER, USEPA DOES NOT WISH TO WRONGFULLY
COPY SUCH MATERIAL. THEREFORE, USEPA LISTS BELOW ARTICLE
TITLES AND JOURNAL SOURCES AND WILL MAKE INFORMATION
AVAILABLE AT ITS REGION V CHICAGO OFFICE.
1. From Hazardous Materials Journal,Vol.3,Number 2,March-
April 1990.
"A Field Evaluation of the UV/Oxidation Technology to
Treat Contaminated Groundwater" by N.Lewis,
K.Topudurti, and R.Foster - p.42.
"A Catalog of Research-New Technology Under Study"-p.56
"Hazardous Waste Decontamination with Plasma Reactors"
by L.J.Staley - p.67.
2. From Hazardous Materials_Journal,Vol.3,Number 1,January-
February 1990.
"ATSDR Update: Goals for Implementing the Health
Provisions of CERCLA" by B.L.Johnson - p.30.
"Using an Organophilic Clay to Chemically Stabilize
Waste Containing Organic Compounds" by R.Soundararajan,
E.P.Barth,J.J.Gibbons - p.42.
3. From Pollution Engineering,Volume XXI,Number 5,May 1989.
"Biological Treatment of Hazardous Waste" by M.F.Torpy,
H.F.Stroo, and G.Brubater - p.80.
4. From Pollution Engineering,Volume XXI,Number 7,July
1989.
"Remediation through Groundwater Recovery and
Treatment" by G.J.Ziegler - p.75.
"Status of Contaminated Soil/Sediment Cleanup Crit.-M i
Development" by J.Fitchko,PhD - p.90.
-------
Page do. 1
»6/«2/9e
flCHE/rRAKE PAGES DATE
ADKinsmrm RECORD IIDEI - UPDATE n
orr/sroRT/coRDovA, KI. OPERABLE UNIT 12
(the following,docmentt are not copied,
but are available for regies io DSEPA Region V Chicago Offlc
TITLE
ADTBOR
RECIPIENT
DOCUMENT TTPB
DOCSUHESR
199 98/03/08
126 88/12/21
Cordova generator ID, farioos
Part A i Part B,
inspection and dome
related correspondence
in the RCRA filet
(several hundred pages)
federal Register
containing the rerieed
Final National Contin-
gency Plan(pp.666f-88(5)
Federal Register
Containing the proposed
Revised National Contin-
gency
Planfpp.51394-51526)
(Notesthe preaible of the
final KCP refers back to
certain parts of the
proposed NCP)
Various
Other
Other
Other
-------
13. From Chemical and Enginee_r_ing Ne_ws,April 30, 1990,
pp.10-15,Volume 68,Number 18.
"Chemical Management, Communities Tussle with Hazardous
Waste Rules".
14. From Chemical and Engineering News,December 24, 1988,
pp.24-25.
"Low-cost Cleanup of Petrochemicals".
15. From Chemical and Engineering News,September 14, 1987
pp.-17-19.
"Fungus Shows Promise in Hazardous Waste Treatment".
16. From Pollution Engineering,February 1987, pp.66-68.
"Vacuum VOCs from Soil" by M.Bennedsen.
17. From Chemical and Engineering News, December 22, 1986
pp.20-21.
"Plasma Technology to Tackle Toxic Wastes".
18. From Hazardous Materji._als_C!pntrol, March/April 1989,
pp.8-12 and 70-74.
"Part 1: Choosing a Treatment for VHO-Contaminated
Soil" by D.Towers,et al.
|bid - pp.14-19,"Part 2i In Situ Heating to Detoxify
Organic-Contaminated Soils" by K.Ohma and J.Buelt.
19. From Hazardous Materials._Cpntrol_, November/Decembe r
1988, pp.15-18 and 30-31.
"Part 2: Groundwater Cleanup at Several Superfund
Sites" by L.Haiges and R.Knox.
-------
5. From Pollution Engineering,Volume XXI,Number 13,December
1989.
"New Way to Measure Landfill Clay Liner Conductivity"
by J.Uppot and C.L.Rauser - p.52.
6. From Pollution Engineering,Volume XXI,Number 8,August
1989.
"On-Site Incineration as a Remedial Action Alternative"
by R.J.McCormick and M.L.Ouke - p.68.
7. From Hazardous Materials_ C_o_nt£ol, Volume 2, Number 5,
September-October 1989.
"Bioremediation of Hazardous Waste" by A.Q.Bourquin -
p. 16.
8. From Hazardous Materials Control,Volume 1,Number 4,
July-August 1988.
"Industrial Waste Remediation" by C.R.Brunner - p.26
9. From Pollution Engineering,Volume XXI,Number 11,October
1989.
"Thermal Treatment Technologies for Hazardous Waste
Remediation" by N.P.Johnson and M.G.Cosmos.
10. From Chemical and Engineering News,February 19,1990,
pp.5-6.
"Benzene in Perrier found by North Carolina Lab".
11. From Chemical and Engineering News,March 12, 1990, p.4
"Hazardous Wastest EPA Adds 25 Organics to RCRA List"
12. From Chemical and Engineering News,December 5, 1988,
p. 14.
"Contaminated Wells Create Headache for Kodak".
-------
ens/nuts PAGES am
I 90/05/15
1 90/05/17
1 30/06/05
1 90/tS/lS
muismrm RICQRD
QtT/STOm/CORDOn, KI, 0mm* Wf 12
KUSHGOK COfflff,
atom n
Tint
Lttter re: Response
to a request for ill
the inforntion and
studies concerning
the Ott/Story/Cordoia
site; forvarded to the
repository to reriev
the intonation
Letter res Inquiry
concerning bov tany
cubic yards of soil
are to be treated at
Ionia ant vbat tit
the captial cost?
Letter re-. Questions
forvarded to RCRA
concerning itns tn
be included in the
Proposed Plan
Letter fotmrdinq a
copy ol tbe tork plan
developed to guide a
proposed onsite
treatability study
effort
R.Tastreak-HOIIR
minnr
H.Jetinei
rues DOCHUKHR
Correspondence i
K.Sart-HStPK
Correspondence
R.Bart-SStP*
J.lleiun-USlPA
Correspondence 3
t.im-ssm
D.ftita-Ccriora
Cbn. Co.
Correspondence
M/Ot/OO
10
CSRCLK Cotpliance vitb
Otbtr Lavs Kaooil
CSRCU Coipliaoce vita
tbe cn tad
Keeling lotes trot
tbe Cincinnati ORD
Heeling beld April
Heto re-, fecbnical
Renev of tbe Ott/
Story/Cordora
Superfund Site Rl/tS
Letter forvardisq a
tetn vitb inlortitien
i'.: Ccntaiioant flute
/act Sheets
R.Strt-HSSPA
Keeling totes S
Dr.O.Steroitzkt (
S.Buling-VSSP/l
R.ras:rtik-KDM
Hetorandut
R.Hart-UStPK
-------
ACRONYM LIST FOR
OTT/STORY/CORDOVA OPERABLE UNIT f2-UPDATE #1
ADMINISTRATIVE RECORD INDEX
ATSDR Agency for Toxic Substances & Disease
Registry
ARARs Applicale and/or Relevant and
Appropriate Requirements
CERCLA Comprehensive Environmental Response,
Compensation & Liability Act
FFS Focused Feasibility Study
MDNR Michigan Department of Natural Resources
HDPH Michigan Department of Public Health
OSWER Office of Solid Waste and Emergency Response
PRP Potentially Responsible Party
RCRA Resource Conservation and Recovery Act
ROD Record of Decision
USEPA United States Environmental Protection
Agency
VOCs
Volatile Organic Compounds
-------
CHS/mm PAGES DATS
ill !0/06/2!
15 50/07/00
TITLS
Ctt/Storr/Cordora Site
Public Cental
ftasibililf Studf
Report
0tt/Storf/Cordora
site
Proposed Plan if
G.S.SPA for
final Grouadvater
Cleanup at
Oll/Storj/CcrtoTi
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HSftGO* COMTI. HICBIGAX
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TITLS
MCORD MUSI
OTT/STOHY/CORDOVA, Kit OPtRASlt MIT t2 - UPBATS 12
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AUTHOR
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1 SO/06/08
I SO/OS/U
Uaiiertlov of Littlt
lar Cretk and tht
llDDned Tributary,
Ctt/Storj/Cordora
sitt
Keio re-. Ott/Storj/
Cordon Proposed Plan
Keto rt: Hater Division
of the Kerised Proposed
Plan for the Ott/Storj/
Cordora Site, Vinoebago
Illinois
J.Kleinn-UStPA
D.Bryton-HSSPA
R.Hirt-UStPA
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JJ 00/CO/CO
6 88/OS/CO
8? 89/01/22
Table I. Properties
of Contaiinaats
fonooJf found at
Svpertiiad Sites
S.Buling-USttA
K.Htrt-VSEPk
Draft
Guidance titled,
'Kov Clean is it?'
Keio fffrwdiaj a copf
ct the Guidance to-be
considered latenal on
Selecting Retedies for
Sdfertand Sites vith
PCI Ccntaiination
R.B»tt-vsm
Saperfond Branch
Chiefs
Reports/Studies 11
Reports/Studies 12
Reports/Studies
54 50/115/21
JO/Of/OS
15 !9/03/2( Conducting field Tests O.DiGlolioH.Soe Cbo, R.Btrt-USSPA
for Kraluation of Soil Pb.D.-VSSPA
facuui litractico R.Oupont.Pb.S.t
Application torvitttt H.leiblovski.tb.D.-
by Scott Billing of Dept. el Clril t
VSSPA Snrlrooieatal lngr.
Utah State CuJrenitf
Reports/Studies M
D»R of laturaJ ^soorc«s
remission forirooieotal
Cootau'aatioo Response
Activity
Inttragency Agreetent/
Aiendtent Pitt 1 -
General Intonation,
vitb attacbitnt A:
Sccpe of iforJt for tht
F.eudial Design at the
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Reports/Studies 15
• Reports/Stuiit! if
QS/iCI
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CffliMJfCJ DOCWfWS
OTT/StOll/COKDOU, Kit OfmBLS MIT
DocuKOtt are arallabjt /or miev at
ffSIM Rtyion r-Cftjcayo IL
Handbook DO /a-Situ USSPA/P.isk Rtttictioa 90/01/00
Treaties of Hazardous laboratory
Haite-Cootaiioattd
Soils
Michigan Act Ho. J07 J0/05/00
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CHS/FRAHE PAGES DATS
TITl!
RECORD IXOEI
OTT/STORI/CORDOVA, HI, OPERABLE HIT n • mm 12
THE momrs LISTED ARE HOT rot TBS REPOSITORI,
BUT KAY BE REVIEW IT asm, RUM v, CHICAGO. IL
AHTBOR
RSCIfllRT
DOOIl/KBJR
12 W/Qi/16
5 JO/IM/2J
12 w/os/eo
27
Article titled:
'Troubled Haters'
re: The Mississippi
River faces all of
the cation's joriroo-
icntal probltis
Article titled;
'Cbtiical,Detocracj
and a Response to tbt
Earironieat'
FOCUS Xevsletter re:
EPA/Industry Loci; ID
Pest-Closure Penit
Court Battle
Article titled:
'Predicting the fate
asd Transport of
Organic Coipounds in
Groundvater - Part I'
Haf-Jone JJJO
Article titled: 'tPA,
Snrircnientalists
Feud Orer Land Ban
Haste Rule"
Hevsveek
VSIPA
Otner
Cbeiical t Engineering I1SEPA
tt»s, Vol.68, Ho. 17
Otber
Hazardous Kattrials
Control Rtstarcb
Institute
vsm
Otber
R.Olsen S, A.Darii SSIPA
Hazardous Katerials
Control
KoJ.Mo.J
D.Bansoo-Cbeiical 4 VStPA
Engineering Sets
Otber
Otber
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for Ott/Storf/Coricn
LHart-USSeti
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K.Hatt-Kott.militn
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tfeiorial
library
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P.Sc6utte-(/S£PA Correspondence J
fact Soeets
tetter fomrdina. a
cop)' of Director's
Order N?. Of/.101.50,
Tesjccated Trout Strrai?
fcr toe State of HI
Rerisicn Ko. 1
Ptt/Stor^/Cordora
P.I Report
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Reports/Studies 5
Reports/Studies f
JKo. J
Ott/Storf/Cordora
focused fS
BSIM
Pepcrts'5tudie«
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CHIOS for tit ktuoiatruirt Record
Ott/StorjVCordora, HI, Operable Quit 12 • Ofiatt
Kuskeqcn County, Michigan
mount CSFIHITIOX
CERClt Cciprebensire Borircniental
Response. Coipensation, and
Liability Jet of J?80
CM CJeao facer Jet
KDNR Michigan Dtparttent of
natural Resources
HOUR Kicnigan Depl. i(
natural Resources
PCS Pclycblorinated Bipbecyls
RCRA Resource Conservation
and Recovery Jet
Rl/FS Retedial lovestigatict/
Feasibility Study
SOVH Safe Drinking Hater
Jet
US ACS United States Jrif
Corps of
OSSH United States Snrircneental
Protection Agency
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