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           .. •-•

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                                                              s  :  /
                                                                      wjjs
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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

                                10

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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

                                12

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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..."
                                13

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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

                                15

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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

-------
 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

-------
 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

-------
 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

-------
 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

-------
 f    VO.     1
     30
'tCHS/FIUHS PAGES DATE
                                                         mimsmms RECORD
                                                   oir/STORY/cQRDon, Hi: ommx mr n
                                                (Tbt KK tad indices for OperaoJe Unit II art
                                        btrebj Jacorporated bf  reference into the 2nd OperabJe Uait)
             Tins
                                      AUTHOR
                                                                RtCIPlUT
                                                                                                    DOCIIHHT
           3     90/02/20
             Litter rccotlimtita
             of 2/22/90  itetioq
             to discuss  settltttat
                                      6.foist,CtC
                                      International
                                                   OS DOJ/SPH/KI
                                                   Attf.Ctn.
Correspoodeoce
           2      90/02/02
             letter re.-Ott/Storf/
             Cordora Sitt State
                                      R.Hm,BSm
                                                                        Ccrrespoodeoce
90/03/00     Fact  Sneet:
             Toiiritr  Cflarac-
             teristic Stile finaJired'
                                                                                                     fact 5oeet
                89/09/29
             Htto  ttilotttit
             Cuidaoce  oo Suptrtuod
             Jelection  of Reiedf
             (Jir.J3SS.8-JJj  "

             Keio  rtiJ-Qoilitiei
             CLP Data  and Recoi-
             ieotfatioo5 for its Qst
                                                                Porter,VStPA
                                                                S.Vtllt.QStPk
                                                                        Keioraodui
89/10/18     Keio  reconsiderations
             JD Ground  fater fieie-
             diation  at Superfund
             Sittt
                                                                                asm
                                                                                    Xeioraodui
                90/02/U
          I     90/03/08
Keio re.-Draft KorJt PJan
Ott/Storj/Cordora  Pilot
Testinj - Deceioer 1J8J

Keio rt-.OSVER Cirectire
JJ55.D-28,  Control of
Air fiissions froi
Superfund Air Strippers
at Superfund Groundvater
Sites (Attacnient)

Ktit re.-Jejuest  for
faclt?round  Soils Tata
at DueJJ-Gardner Site
("3 u'Jej frsi Ott/StcrjJ
                                                      J.Btiotiaa.HDlR
                                                               S.faszreaJt, «/)*/!      Keioraodui
                                                               (JSIFA
                                                                                    Xeioraodui
                                                                                    ffeioraodui
          1     M/03/IS
                                         c::«  t:
                             fiie.  re.-  ,:/.;;,fi  it:i
                             jo  toe  Adiic.  Se::rd
                             'Acalrsis  ?.'  x'.?.1.
                                                  c   Fer:

-------
 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
Superfund Site and
Jorites fablic
Ccttent
                                                     muismrns  MCORD
                                                         . HI,  opgmis mr 12  - UPDATE n
                                                     HSftGO* COMTI. HICBIGAX
                                                   AUTHOR
                                                  CB2K
                                                                           MC1HUT
                                                                           OSSPA
                                                                             THE
                                                                                              Reports/Studies     17
                                                  S.S.SPA
                                                                                              Reports/Studies     is

-------
'CBS/rum PACES am
                   TITLS
                                                                      MCORD MUSI
                                            OTT/STOHY/CORDOVA, Kit  OPtRASlt  MIT t2 - UPBATS 12
                                                                 comr,  KICBIGA*
                         AUTHOR
                                                                               TYPS       DOCHOHBSR
          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
Ketorandut
                                                                       Kttorandui
          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
                                            R.Bart-USm  4
                                            K.Kvlligan-VSACS
                                                                                          Reports/Studies      15
                                                                      • Reports/Stuiit!     if
                                                                               QS/iCI

-------
                                           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

-------
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

-------
-3  a '
    PAGES
 rms
                                                            m HCOKD  lA'
                                                          (  opmsi«  o«ir
                                                           coi/m,
                                               AUTHOR
                                             DOdJKEHT
          «ff/«7/JJ
         H'OS/01
           '07/00
ifttfr res Rsijufst r'or
paoe.« frei ti< /S for
                      to !)• arfdfd to  tbt
                      initrtiticn rtpositoiy
                      vitb pige:  attached
tetter re:  f/
jiieiiatfJj',  Kr.  Paul
Gautftjer is assigned as
frc/ect /fanaaer /or tfc«
Ctt/5tor)-/Cordjra sit*

tetter re.-  P.tquest fcr
JP daf eitensicn  of tbt
cement period on the
P. S.'C Crcondvittr
CJeanup PJaa  and  fS

JPA Pr:p?5«j  Ground'
tfmr CJeaoup fJao
for Ott/Storf/Coricn
LHart-USSeti
*.SittJe-DaJton
fovosiip
                                               K.Hatt-Kott.militn
                                               tee.P.C.
Correspondence
                                                   tfeiorial
                                                   library
                         DJaJJotti-1/SJPA      Correspondence
                         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
                                               I/SSPA
                                                                                             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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