United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-91/157
March 1991
Superfund
Record of Decision:
Rasmussen's Dump, Ml
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R05-91/157
3. Recipient's Accession No.
4. IMS «nd SubtMe
SUPERFUND RECORD OF DECISION
.Osmussen's Dump, MI
First Remedial Action - Final
5. Report Date
03/28/91
7. Author).)
8. Performing Organization Rept No.
». Performing Orgalnlzation Nairn and Addreaa
10. ProjecVTaak/Work Unit No.
11. Contnct(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nama and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notra
16. Abstract (Limit: 200 word*)
The 33-acre Rasmussen's Dump site is a former industrial and domestic waste disposal
area in Green Oak Township, Livingston County, Michigan. Surrounding land is
predominantly wooded with some residential and agricultural development. Area
residents rely solely on the aquifer underlying the site for their drinking water
supply. The site is adjacent to the Spiegelberg Landfill, another Superfund site.
During the 1960s and early 1970s, domestic, industrial, and drummed hazardous wastes
;ere disposed of on approximately one-third of the site. Many incidences of onsite
burning of wastes were reported during operational years of the facility. Landfill
operations ended in 1977 without complying with State laws on proper capping or
closure. Sand and gravel mining, which began following site closure, caused unearthed
waste fill and drummed wastes to be redistributed around the site. In 1981, the State
detected low levels of ground water contamination onsite. This contamination includes:
two onsite contaminated ground water plumes and four areas of soil contamination
referred to as the Top of the Municipal Landfill (TML), the Northeast Buried Drum Area
(NEBD), the Industrial Waste Area (IW), and the Probable Drum Storage, Leakage,
Disposal Area (PDSLD). In 1984, EPA removed approximately 3,000 drums and 250 cubic
(See Attached Page)
MI
17. Document Analysis a. Dmcrlptors
Record of Decision - Rasmussen's Dump,
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics
(chlorinated hydrocarbons, ketones, phenols), metals (cadmium,
lead)
b. Mentiflers/Open-Endod Terms
c. COSATI Held/Group
18. Availabilty Statement
19. Security CUM (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
174
22. Price
(See ANSI-Z39.18)
See Instruction* on Revene
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R05-91/157
Rasmussen's Dump, MI
First Remedial Action - Final
/stract (Continued)
yards of contaminated onsite soil. In 1990, the PRPs removed an additional 650 onsite
drums, waste, and associated visibly contaminated soil from the TML, NEED, and IW areas,
thereby reducing the risk posed by the areas. Testing in the PDSLD area indicated that
soil contamination resulting from drum leakage continues to migrate into the soil
directly above the ground water table or into the ground water itself, and poses a
continuing ground water threat. This Record of Decision (ROD) provides a final remedy
for onsite contaminated soil and ground water. The primary contaminants of concern
affecting the soil and ground water are VOCs including benzene, TCE, toluene, and
xylenes; other organics including ketones, chlorinated hydrocarbons, and phenols; and
metals including cadmium, and lead.
The selected remedial action for this site includes capping the waste in the TML and NEED
areas, and removing and disposing of waste drums unearthed during cap construction
offsite at a RCRA facility; ground water pumping and treatment using chemical
precipitation followed by pH adjustment to remove metal contaminants, a biological
treatment system to remove organic ground water contaminants, and air stripping and
granular activated carbon to remove residual organic contaminants as necessary;
discharging the treated ground water onsite through a seepage basin in the IW and PDSLD
areas to flush area soil monitoring ground water; continuing residential well sampling in
conjunction with sampling for the adjacent Spiegelberg Superfund site; and implementing
institutional controls including deed restrictions, and site access restrictions such as
fencing. The estimated capital cost for this remedial action is $7,320,000, with an
annual O&M cost of $4,580,000.
RFORMANCE STANDARDS OR GOALS: Soil contaminant levels in the PDSLD/IW areas will be
reduced to less than 20 times the ground water clean-up level for each chemical; or leach
tests performed on the PDSLD/IW soil must produce leachate with concentrations below the
ground water clean-up levels. Ground water clean-up goals are based on a 10~6 cancer
risk level, Human Life Cycle Safe Concentrations (HLSC) detection limits, Taste and Odor
(T&O) Threshold, State standards, and risk- and health-based criteria. Chemical-specific
goals for ground water include benzene 1.2 ug/1 (risk-based), TCE 3 ug7§. (10 risk
level), toluene 800 ug/1 (T&O), xylenes 300 ug/1 (T&O), cadmium 4 ug/1, and lead 5 ug/1
(HLSC). Cleanup for cadmium and lead will not be required if filtered lead and cadmium
samples are 5 ug/1 and 4 ug/1, respectively, or if onsite filtered lead and cadmium
levels are greater than 5 ug/1 and 4 ug/1 respectively and these onsite filtered lead and
cadmium levels are equal to or less than their corresponding filtered background levels.
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Rasmussen Dump site
Green Oak Township, Livingston County, Michigan
Statement of Basis and Purpose
This decision document presents the selected final remedial
action for the Rasmussen Dump Site, in Livingston County,
Michigan. The final remedial action 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.
This decision is based upon the contents of the administrative
record for the Rasmussen Site. The Administrative Record Index
is included as Appendix 1.
The United States Environmental Protection Agency (U.S. EPA) and
the Michigan Department of Natural Resources (MDNR) agree upon
the selected remedy.
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 endangerment to public health, welfare,
or the environment.
Description of the Selected Remedy
This final response action addresses the Rasmussen groundwater
plume area of concern (the remaining principal threat), the four
Rasmussen soils areas of concern, and any drums or concentrations
of industrial waste encountered during the implementation of
response activities on the groundwater and soils.
The Remedial Investigation (RI) and associated Risk Assessment
P.eporc for the Rasmussen Dump site identified areas of concern
including areas of disposed hazardous waste, contaminated soils,
and groundwater. Two interim source control measures were
completed at this site.
1. In the fall of 1984, the U.S. EPA Emergency Response
Team removed nearly 3,000 drums and 250 cubic yards of
contaminated soils from the top and south face of the
dump. „.
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2. In early 1990, the Potentially Responsible Parties
(PRPs) concluded the voluntary removal of roughly 650
drums, waste and associated visibly contaminated soils
from the Northeast Buried Drum (NEBD) area,
Top of Landfill (TML) area, and the Industrial Waste
(IW) area. This was carried out under the directive of
the U.S. EPA Administrative Consent Order of August 24,
1989.
These removal actions significantly reduced the quantity of
containerized waste, reducing a portion of the principal threat
posed to public health, soil and groundwater resources.
The final remedial action chosen for the Rasmussen Dump Site, and
described in the attached Record of Decision will:
* reduce the potential for human exposure to hazardous
substances in the contaminated groundwater resource;
* reduce the potential for human exposure to hazardous
substances from contact with contaminated soil areas;
* reduce the potential for remaining hazardous substances
to contaminate other resources.
The principal threats will be mitigated by the groundwater
extraction and treatment system. Reintroduction of treated
groundwater through the Probable Drum Storage, Leakage, Disposal
(PDSLD) area and the IW area will flush the contamination into
the closed-loop groundwater extraction and treatment system,
where they will be removed. This will eliminate current and
potential threats to the groundwater resource from these two
areas. The lew-level threats posed by contact with, or further
migration of contaminants toward the groundwater resource in the
remaining soils areas (NEBD and TML), are mitigated by
construction of a Michigan Act 64 clay cap over these areas, with
the additional protection afforded by fencing and deed
restrictions. The remedy will be closely monitored throughout
implementation and corrective action will be taken, should
monitoring indicate the ineffectiveness of any component of the
remedy.
The remedy chosen to address the two areas of groundwater
contamination and the IW and PDSLD soils areas includes:
* extraction of groundwater to capture and halt the flow of
the plumes.
* removal of heavy metal contaminants by chemical
precipitation followed by pH adjustment (if necessary).
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* removal of several organic contaminants, including ketones,
by a biological treatment system.
* removal of residual organic contaminants via air stripping.
* further removal of residual organic contaminants via
granular activated carbon (GAC) (or other carbon adsorption
methodology, if necessary).
* discharge of treated water to the groundwater via a seepage
basin situated over the IW and PDSLD soils areas of concern.
* groundwater monitoring through a system of wells to assess
the effectiveness of the system at:
* halting the migration of contamination.
* reducing the levels of contamination in the soils
and groundwater, over time.
* a process effluent sampling program to aid in determining
the treatment system's effectiveness.
* fencing and deed restrictions, as necessary, to ensure the
integrity of the remedy.
Residential well sampling will be continued, in conjunction with
that called for in the final remedial actions at the neighboring
Spiegelberg Superfund Site.
The final processes to be installed for groundwater cleanup will
be determined by treatability studies during design.
In the location of groundwater monitoring well RA-MW-27,
groundwater will need to be purged from this location and will
need to be manifolded into the treatment system feed supply line
for treatment prior to discharge.
The final remedial actions to address the threat posed by the TML
and NEBD soils areas of concern include:
* A Michigan Act 64 clay cap constructed over all wastes in
the TML and NEBD areas of concern as they now exist
spatially on-site. This includes:
* a one-foot thick vegetated soil layer on top,
* a drainage layer at least 1 foot thick, and
* a layer of compacted clay 3 feet thick with a
permeability of 1E-07 cm/sec or less.
* A groundwater monitoring program established at appropriate
locations, depths, and frequency, to detect any changes in
groundwater quality, which would indicate any failure of the
unit.
* Access restrictions, such as fencing, will be placed around
the capped soil areas.
* Institutional controls, such as deed restrictions, will be
put in place to prevent future intrusive land uses.
* Drums of waste which are currently visible, or which are
unearthed during cap implementation, will be disposed of at
a licensed RCRA facility.
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This portion of the final remedial action will require long-term
management to ensure that the integrity of the capping system is
not compromised. The access restrictions and fencing will aid in
this effort. Long-term management efforts will include periodic
well sampling, cap inspection and repair (if necessary), and
maintenance of vegetative cover.
Details of the capping construction such as the potential
employment of terracing, rip-rapped drainage channels, and
perimeter runoff collection will be detailed during the design
phase of remedial action.
Declaration of Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the final
remedial action, and is cost-effective.
This remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable,
although it does not entirely satisfy the statutory preference
for treatment as a principal element. Portions of the
groundwater/soils remedy reduces contaminant toxicity, mobility,
or volume through treatment of the principal threat. However,
treatment of the low-level threats posed by the soils areas to be
capped, was not found to be practicable or cost effective.
Drummed industrial wastes, a former principal threat at the
site, has been largely eliminated through previous removal
actions.
A review will be conducted within five years after commencement
of the final remedial action to ensure that the remedy continues
to provide adequate protection of human health and the
environment, because this remedy will result in hazardous
substances remaining on-site above health-based levels.
tifaitf,
Valdas V. AdaijOcus /} Date
Regional AdmJ
U.S. EPA -
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DECISION SUMMARY FOR THE RECORD OF DECISION
Site Name. Location, and Description
The Rasmussen property, located in Green Oak Township, Livingston
County, Michigan, consists of approximately 33 acres. The
contaminated areas take up approximately one third of the
Rasmussen property. Figure 1 is a map of the site location
within the State of Michigan. It is bounded on the west and
south by the Spiegelberg property, another Superfund site. A
Rasmussen relative owns the property to the east, and Spicer Road
follows the northern property line. The homestead located on the
northern portion of the property is a Centennial Farm. Located
next to the homestead is a small automobile body shop operated by
the property owners. Although still largely wooded, the
surrounding properties support some residential and agricultural
development. All residences and small businesses have on-site
drinking water wells, as there are no municipal water
distribution systems in the vicinity. The residential well at
the Rasmussen residence is approximately 250 feet from the
leading edge of the contaminated groundwater contamination plume,
and is in the direction of groundwater flow.
The legal description of the Rasmussen property is:
Rasmussen property. Spicer Road. Livingston County.
Michigan.
Section 30, TIN, R6E, A NE 1/4 Of NE 1/4, EXC E 262
feet thereof.
The site is located in an area of rolling hills that were
deposited by glacial processes. Surface features include ponds
and swampy areas to the south and east of the Rasmussen site.
Soils consist of sands, gravel and clays underlain by Bayport
Limestone of the Mississippian system. The sand and gravel
deposits had been commercially mined, largely changing the
original topographic contours. Investigations have shown that
two glacial drift aquifers are present beneath the Rasmussen Dump
site separated by a silt and clay confining layer .
The aquifer underlying the site is a Class I aquifer, as it is
"(1) highly vulnerable to contamination because of the
hydrological characteristics" and (2) characterized by
groundwater that is irreplaceable (no reasonable alternative
source of drinking water is available).
Site History and Enforcement Activities
The Rasmussen Dump, which accepted domestic and industrial wastes
during the 1960's and early 1970's, forms a ridge-like crest
across the southern portion of the site and property. Drummed
and other industrial wastes were also disposed of at other
locations on-site. Numerous incidents of burning were reported
during the dump's operation. Several attempts were made by the
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•
•
•
MICHIGANt J
Figure 1 - Rasmussen Site
POOR QUALITY
ORIGINAL
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county and state to bring the Rasmussen dump into compliance with
State laws, but the dump was never properly capped and "closed"
prior to termination of landfill operations in 1977. Sand and
gravel mining, which began after closure in 1977, undermined the
landfill and resulted in the redistribution of fill and drummed
wastes.
Low levels of groundwater contamination were detected in a 1981
study conducted by the MDNR. U.S. EPA's Field Investigation Team
conducted a site inspection in 1982, and the site was scored and
placed on the Federal National Priorities List (NPL) of hazardous
waste sites in 1983.
In October and November of 1984, the U.S. EPA Emergency Response
Team removed roughly 3,000 drums and 250 cubic yards of
contaminated soils from the top and south face of the dump. By
December of 1984, a State-lead Remedial Investigation was
initiated (U.S. EPA was the Support Agency). Late in 1985, MDNR
constructed an eight-foot high chain-link fence around an area
which had been determined to contain various organic chemicals,
low level dioxins and PCBs.
The report of findings for the Remedial Investigation was issued
in September of 1988. Based on the findings of the Remedial
Investigation, the Agencies were able to delineate discrete areas
of buried drums and contaminated soils. U.S. EPA issued an
Administrative Consent Order, under Section 106(a) of CERCLA, for
the removal of the drums, wastes, and associated visibly
contaminated soils from three of the soils areas—the Northeast
Buried Drum (NEBD) Area, Top of Landfill (TML) Area (although
labeled a "landfill" in the RI, this dumping area was never a
licensed fill), and Industrial Waste (IW) Area. Eleven PRPs
signed the Order which became effective on August 24, 1989. This
second removal action began in December of 1989.
Roughly 650 drums were unearthed and staged on-site pending
disposal authority. Waste screening prior to disposal indicated
that the contents of three drums contained waste with a pH of 12
or greater. Preliminary flammability screening indicated that
approximately half of the containers may have contained flammable
contents. PCB composites (5 drums per composite) showed levels
as high as 270,000 ppm, while 80 percent of the composites showed
detectable levels of PCBs. Eight containers were found to
contain liquids. All excavated wastes were manifested as
hazardous and transported to approved RCRA facilities. Figure 2
outlines the locations of each remaining area of concern on the
Rasmussen site.
In June of 1987, the landowner sold approximately 7,000 cubic
yards of contaminated soil (identified as "Ramsey Soil
Excavation" on Figure 2) from the fourth area of concern—the
Probable Drum Storage, Leakage, Disposal (PDSLD) Area. The State
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NORTHEAST BURIED
DRUM AREA
luuCOAtt RESPONSE
Action AREAS
INDUSTRIAL
WASTE AREA
WUNICIPA
LXNDFILL
STORAGE/LEAKAGE/
DISPOSAL AREA
OROUNOWATCR
RA.UV/-37
RAMSEY SOIL
EXCAVATION
RASMUSSEN DUMP SITE
REMAINING AREAS OF
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obtained a temporary restraining order 1) against further
movement of the soils, 2) for return of the soils by the
landowner and the purchaser of the contaminated soils, and 3) for
unrestricted access for the State and U.S. EPA to further their
investigative activities (Civil Action No. 87-8917, Circuit
Court, Livingston County). The soils were returned to the
Rasmussen property, and the landowner and purchaser are required
to repay portions of the State's costs incurred in pursuing this
action.
The Feasibility Study Report, prepared by MDNR, reviewed by U.S.
EPA, and released for public comment on January 16, 1990, is also
based on the findings of Remedial Investigation and Risk
Assessment Reports. Subsequent to the completion of the
Feasibility Study, further soil boring investigations and
analyses were conducted from December of 1989 through January of
1990, on the PDSLD Area. The results of these investigations are
detailed in a Technical Memorandum, attached hereto as Appendix
3, and have been added to the Administrative Record.
Potentially Responsible Parties (PRPs) have been identified by
U.S. EPA for the Rasmussen site. A General Notice Letter was
issued to the identified PRPs in September 1988. Special Notice
Letters will be issued to the PRPs after this Record of Decision
has been signed.
Highlights of Community Participation
A complete chronology of community relation activities for the
Rasmussen site is provided as part of the attached Responsiveness
Summary. This past year's activities include the issuance of the
Feasibility Study (FS) Report for the Rasmussen site on January
16, 1990. Site information including the FS have been and
continue to be available to the public as part of the
administrative record, which is housed at three information
repositories: the EPA Docket Room for Region V, in Chicago,
Illinois, and at both the Brighton City and the Hamburg City
Libraries, near the site. The notices of availability of the
Feasibility Study and Proposed Plan were published in the
Brighton Argus, the Ann Arbor News, and the Detroit News/Free
Press. A Proposed Plan detailing the Agency's preferred
alternative was issued on August 31, 1990, initiating the public
comment period. A public meeting was held on September 13, 1990
at the Green Oak Township Hall. The meeting included a drop-in
availability session, a formal hearing, and an informal question
and answer period. The availability session was held in the
early afternoon. At that session MDNR and US EPA staff were
available for informal discussion on the RI/FS, the Proposed
Plan, or any other subject related to this site or the adjacent
Spiegelberg Superfund site. The public hearing was held in the
evening, and addressed comments on the Rasmussen site. An
informal question and answer session for both sites followed the
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hearing. Responses to the comments received during the public
comment period are included in the Responsiveness Summary, which
is part of this Record of Decision.
Scope and Role of Response Action Within Site Strategy
Removal actions, as previously mentioned, have significantly
reduced the quantity of containerized waste and contaminated
soils at this site, permitting the final remedy, as described in
this ROD, to address the remaining risks posed by the soil and
groundwater contamination.
summary of Site Characteristics
In September of 1988, the MDNR and U.S. EPA issued a Remedial
Investigation Report for the Spiegelberg and Rasmussen sites.
During the investigation, the areas of concern were identified
as: 1) the Rasmussen groundwater plume, and 2) the four soils
areas (PDSLD, IW, NEBD, TML). A Risk Assessment was also
completed and issued as a separate document simultaneously with
the Remedial Investigation Report. Specific contaminants
detected in each area of concern are found in the Tabulations
provided in Appendix 2. Appendix 3 presents the results of the
supplemental soil investigation of 1989/1990. The Tables reflect
pre-removal contaminant levels. Generally, both carcinogenic and
non-carcinogenic compounds were found to be present in the
Rasmussen soils and groundwater plume. To summarize:
* Drummed wastes were disposed of in an area referred to as
the Top of the Municipal Landfill (TML). Periodic fires in
this area may have been the source of the low levels of
dioxins and dibenzofurans identified in this area. Soils
not removed contained PCBs as high as 61 ppm. This is an
area of concern due to the potential dermal threat posed by
the PCBs and benzo(a)pyrene remaining in the surface soil,
and the potential threat to groundwater from leaching of
contaminants through the soils. Refer to Tables 2-5, 2-8
and 2-9 of Appendix 2 for contaminant levels found in
this area. As mentioned, the majority of drummed wastes
have been removed from this area. Surface soils in this
area contain dioxins from the burning of wastes, averaging
less than 1 ppb.
* The dump (TML) also consist? of decomposed and non-
degradable domestic trash, and some scrap metal. These
wastes cover approximately 6 acres, and range from roughly 5
feet thick on the north edge, to greater than 50 feet thick
on the south side. Post-removal observations have shown
that scattered drums are partially buried in the dump and
adjacent soils areas. Weathering and soil slumping continue
to expose new drums.
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A buried drum area was intermingled with the municipal
wastes in the northeast portion of the municipal landfill.
This area is referred to as the Northeast Buried Drum (NEBD)
area of concern. Drums, associated wastes, and contaminated
soils located in the NEBD were found to contain high levels
of volatile organic compounds, semi-volatile organic
compounds and PCBs, and posed both a threat to groundwater
and a dermal threat to humans. All drummed wastes have been
removed from this area. Refer to the "Site History and
Enforcement Activities" section for details of this
removal. Refer to Table 2-14 of Appendix 2 for contaminant
levels found in this area prior to the removal. This area
currently poses a potential risk to groundwater from
residual soil contamination.
The Industrial Waste (IW) area is an area where mixed paint
wastes and drums were found within the gravel pit at the
center of the northern toe of the municipal landfill.
Volatile organic constituents and PCBs characterized this
area, presenting dermal and groundwater threats. Risks
have been reduced by removal of drummed waste and some
contaminated soils from this area, as previously discussed.
Refer to Table 2-15 of Appendix 2 for contaminant levels
found in this area prior to removal activities. This area
continues to pose a potential threat to the groundwater
resource from residual soil contamination.
Testing of subsurface soils and recent gravel mining have
revealed an area where leakage of drums and/or bulk disposal
of liquid may have occurred. This area of concern is
referred to as the Probable Drum Storage, Leakage, Disposal
(PDSLD) area. Refer to Table 2-16 of Appendix 2 and
Appendix 3 for contaminant levels found in this area.
Limited investigations were conducted in this area during
the RI. At the completion of the RI, data indicated that
contamination existed in isolated lenses in the PDSLD
unsaturated zone. The supplemental soils investigation of
1989/1990 gave a clear indication that the majority of
contaminants are not being retained in the upper unsaturated
soils, but have migrated through the upper soils in this
area, and are now found either in the soils above the
groundwater table, or in the groundwater itself. The
contamination in the soils in this area is considered a
current continuing threat to groundwater.
The PDSLD/IW areas combined comprise roughly 9,400 cubic
yards of varying degrees of contaminated soil above the
groundwater table.
The northern (and largest) groundwater contamination plume
appears to have originated from the PDSLD/IW areas of
concern. It is estimated to have traveled roughly 500 feet
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in a north-northwesterly direction (Figure 2) and contains a
large number of organic compounds. It is estimated that 3.3
million cubic feet of contaminated groundwater exists
beneath the site. Groundwater flow rate is 173 feet per
year in the upper aquifer and 204 feet per year in the lower
aquifer. However, contaminants within the plume do not
appear to be moving at the same rate as the groundwater.
The groundwater in the vicinity of RA-MW-27 (southwestern
toe of the dump) was confirmed to be contaminated with
trichloroethene above groundwater cleanup levels. This
confirmation was a result of re-evaluation of existing
Remedial Investigation results and on subsequent PRP
sampling events. Although limited in extent, this area
requires remediation. Both areas of groundwater
contamination are delineated on Figure 2.
As noted above, the glacial aquifer used for water supply is
presently contaminated by the Rasmussen plumes. Continued
migration of the plumes poses a potential threat to water
supply wells north and northwest of the site, although no
wells beyond the site are presently contaminated by the
plumes. Also considered is the fact that the groundwater at
the site is potentially usable, and no reasonable
alternative source of water exists.
The actual or threatened release of hazardous substances
from this site, if not remedied by the selected alternative,
may present an imminent and substantial endangerment to
public health, welfare, or the environment.
Of Site Risks
The 1988 Remedial Investigation and Risk Assessment Reports
detailed the site characteristics and risks prior to the
1989/1990 removal action, and without the benefit of information
gained during the 1989/1990 supplemental soils investigation.
Some of the site-specific details and assumptions used in the
calculation of risk at that time differ from that which is
characteristic of the Rasmussen site in its current state. The
following discussion of the Rasmussen site risks describes the
general concepts used in the RI and Risk Assessment to determine
risk posed and chemicals of concern, and identifies those aspects
of risk calculation that are still applicable after the removal
and additional findings. Integrated with the discussions of
current risks are discussions of groundwater chemicals of current
concern and their corresponding cleanup levels, and the rationale
for the soil remediation compliance points, in order to protect
public health and the environment.
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Human Health Risks
The following discussion of the Rasmussen site risk describes the
general concepts used in the RI and Risk Assessment to determine
chemicals of concern, risks posed by these chemicals, and impact
on risks by the removal actions.
Contaminant Identification
As noted previously, Appendix 2 contains contaminant
concentration summaries for the Rasmussen areas of concern, which
were taken from the Risk Assessment. Appendix 3 contains
additional information on the PDSLD, excerpted from the
1989/1990 Soils Investigation Technical Memorandum. Section 3-2
of the Risk Assessment describes the indicator chemical selection
process and Table 3-1 in Appendix 4 here, lists the selected
indicator chemicals for that assessment. The Risk Assessment
tabulations represent the concentrations found during the
Remedial Investigation samplings prior to the 1989/1990 removal
of 650 drums and some associated soils. Contaminant
concentrations reported in the Risk Assessment tabulations were a
combination of surface soil and subsurface soil/waste samples.
Many of the higher concentrations reported were from wastes
found in close association with the drums in the NEBD, TML and IW
areas, which have now been removed.
Exposure Assessment
The exposure assessment portion of the Risk Assessment identified
the potential exposure pathways and receptors. Identified
pathways and receptors were used in conjunction with assumptions
of exposure frequency and duration, to model exposure point
concentrations.
A. Pathways
Three factors were used to identify exposure pathways:
* Chemical source and release mechanisms to the
environment.
* The environmental transport medium for the released
chemical.
* The point of potential receptor contact with
contaminated media.
1. Groundwater
During the performance of the Risk Assessment, risk calculations
included factors for transport of chemicals from surface or
subsurface waste deposits to the groundwater. These groundwater
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8
scenarios included direct percolation of liquid wastes and/or
solubilization of solid or semi-solid wastes, and lateral
transport of these wastes toward a receptpr at Spicer Road. The
average and maximum source concentrations of contaminants used to
initiate these transport model calculations were often those
taken from drummed waste, now removed from the IW, NEBD and TML
areas.
The contaminants currently found in all four soils areas and
groundwater now represent the source to the environment and human
receptors, with the groundwater resource underneath each area of
concern being the point of potential receptor contact—and not
Spicer Road. The groundwater underneath the Rasmussen site is
potentially usable, and thus requires protection and
restoration. Likewise, based on existing hydrogeologic and
chemical analytical data, contaminants currently in the
groundwater, if not remedied, will migrate northward, eventually
reaching the property boundary and may potentially impact
existing or new wells.
The scenario for point of potential receptor contact with
contaminated groundwater does not change based on prior removal
actions. Potential receptors are likely to be exposed to
contaminants in groundwater via normal domestic uses. With
reference to risk, ingestion is the primary point of potential
receptor contact. Inhalation of volatilized contaminants during
showering or bathing is a secondary exposure route. Dermal
absorption of organic compounds through water usage could also
occur, but studies have shown this to be an insignificant
exposure route in contrast to ingestion or inhalation.
2. Soils
As explained above, the soils areas were considered as potential
sources of groundwater contamination in the Risk Assessment.
Dermal contact with, accidental ingestion of, and inhalation of
volatile organic contaminants and fugitive dust from surface soil
contamination were also considered as pathways in the Risk
Assessment. The Risk Assessment analyses found that due to very
low concentrations of contaminants in RI air samples, routine
release of contaminants through volatilization or fugitive dust
is not significant. Particulate air monitoring conducted as part
of the 1989/1990 drum excavation activities, during which a fair
amount of soil and waste disturbance occurred, did not show
elevated airborne contaminant levels. Contaminants remaining in
these soils areas after removal, currently pose a reduced dermal
contact risk from that which was assessed in the Risk Assessment.
Appendix 4 attached provides the list of indicator chemicals from
the Risk Assessment. The 1989/1990 supplemental soils
investigation has shown that surface soils remaining in the PDSLD
area do not pose a significant dermal or inhalation risk These
results are included as Appendix 3.
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The likelihood of persons coming in contact with the contaminated
soils (direct contact or accidental ingestion) has been
essentially eliminated by the eight-foot high chain link fence,
topped with three strand barbed wire, constructed around all
soils areas of concern during 1985.
The remaining risk posed by the soil areas of concern, listed in
Table 3-6 of Appendix 5, is primarily via their current potential
contribution to the site's groundwater contamination through
percolation or by interaction with the fluctuating groundwater
interface. Specifically, the PDSLD/IW area poses a current risk
to groundwater due to the presence of soil contaminants in close
association with the groundwater, as indicated by the
supplemental soils investigation results in Appendix 3. The TML
and NEBD contaminated soils that remain also present a potential
risk to groundwater.
B. Potentially Exposed Populations
For the purposes of the ingestion scenario exposure assessment,
people who now, or will at sometime in the future, reside in the
downgradient direction of groundwater flow (north-northwest) were
considered potential receptors. Analysis of groundwater samples
collected during the RI and in May/June 1990 indicate that the
groundwater contamination plumes have not migrated beyond the
site boundary, and that residential wells belonging to potential
receptors are currently unaffected by the Rasmussen groundwater
contamination plumes. As noted previously, the Rasmussen
residential well, located approximately 250 feet distant from the
leading edge of the plume, is the closest currently existing
potential receptor. Other currently existing potential receptors
within one mile of the site in the downgradient direction are
limited to roughly 5 households and one VFW Hall.
For purposes of assessing the risk posed by the direct contact
with or inhalation of contaminants from soils and wastes, persons
who would be trespassing within the confines of the fenced area,
or who would potentially be exposed through the occupational
scenario, were considered potential receptors.
The property immediately to the north of the Rasmussen site is
zoned residential, and a developer is currently pursuing options
for building. Assessment of potentially exposed populations for
the future scenario includes the potential use of the groundwater
resource at the Rasmussen site. As will be explored in detail
further on, this is the basis for the chosen groundwater and
soil remediation.
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10
C. Exposure Estimates and Assumptions
As previously noted, portions of the models and assumptions used
in the Risk Assessment to calculate exposure point considerations
are not•characteristic of current site conditions. They reflect
conditions prior to the removal and investigation done in 1989
and 1990. Other assumptions used are standard to all risk
assessments and are still applicable to current site conditions.
This section describes models and assumptions used, and indicates
which are applicable to pre- and post- removal action scenarios.
For complete details of exposure assessment and risk
characterization results see Sections 3.4 and 3.5 of the Risk
Assessment document.
1. Modeling Concepts
The Linkage Model, in conjunction with the Organic Leachate Model
(OLM) and the Vertical and Horizontal Spreading (VHS) Model were
used in the Risk Assessment to predict groundwater contaminant
concentrations at a hypothetical receptor on Spicer Road, which
forms the downgradient boundary of the site. Worst-case and
realistic-case dose estimates were generated using measured waste
concentrations, modeled leachate concentrations, an unsaturated
and saturated zone linkage model, and an EPA-approved groundwater
transport model. In addition to the modeled leachate
concentrations, existing groundwater contaminant concentrations
in the identified plume were also used to estimate risks at the
same receptors.
Modeling for exposure to soils contamination was assessed using
both worst-case and plausible-case scenarios for the hypothetical
cases of contact through trespass and inhalation of contaminated
air or fugitive dust.
2. Contaminant Concentrations
The OLM in conjunction with the VHS Model was used to estimate
the contaminant concentration in the groundwater due to leaching
through the soil. From there, the leachate concentration of a
particular contaminant was derived using a linkage model. This
model is a one-dimensional screening tool that does not account
for contaminant density, co-solvent transport, or colloidal
transport. The model assumes that the source of contamination is
steady (i.e., not a pulse input such as a single spill) and that
contaminant movement occurs only in the vertical direction in the
unsaturated zone and only in the horizontal direction in the
saturated zone. Upon calculating a contaminant concentration in
the saturated zone, a concentration at a selected receptor (in
this case, a hypothetical, shallow domestic well installed near
Spicer Road, the downgradient boundary of the site, can be
estimated. The model mathematically simulates the migration of
contaminated groundwater to a point of exposure. The contaminant
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11 .
concentrations calculated for the site, based on the leaching of
contaminants through the soil to the groundwater (as described
above), and used to derive risk, are not necessarily
characteristic of the current Rasmussen s'ite conditions since the
concentrated wastes in the NEED, IW and TML areas have been
removed.
In order to protect human health and the environment, under
CERCLA and the NCP, cleanup levels have been established for the
site. Given the close proximity of residential wells and the
potential future use of the groundwater, risk-based cleanup
levels have been established for groundwater. These cleanup
levels were used to determine the need for remediation of the
existing groundwater contamination. These cleanup levels are
consistent with "Type B" cleanup criteria in Michigan Act 307.
Michigan Act 307 cleanup criteria are discussed further below.
Cleanup levels have also been established, under CERCLA and the
NCP, for the contaminated soil areas at the site. The objective
for the soil remediation is to reduce the contaminant levels in
the soils to that level which will not leach contaminants above
the groundwater cleanup levels. As such, the cleanup levels set
for groundwater also provide the basis for the soil remediation.
These cleanup levels are also consistent with the cleanup
criteria in Michigan Act 307 (R299.5711(2)) which is discussed
further below.
For soils, the direct contact scenario used maximum and average
source concentrations for the worst-case and plausible-case
scenarios. These concentrations were moderated by factors for
adsorption and soil adherence.
Worst-case scenarios for air use maximum contaminant
concentrations, with a soil disturbance frequency of 30 days per
month and zero vegetative cover, while the plausible-case
scenario uses the arithmetic average of soil concentrations, with
a disturbance frequency of 10 days per month and a 50 percent
vegetative cover.
3. Dose and Exposure Scenarios
Dose is used in the modeling of risk and is defined as the amount
of a compound, in milligrams (mg), absorbed daily, by a receptor,
per kilogram (kg) of body weight Doses can be calculated for a
lifetime (for carcinogenic effects; or for one-time acute
exposures (for noncarcinogenic effects).
The factors which influenced groundwater ingestion dose are
contaminant concentration (maximum or average), ingestion rate,
the fraction of contaminant absorbed, and body weight. The
groundwater ingestion rate used for this site was based on the
standards of 2 liters/day for a 70-kg adult receptor and the
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12
absorption fraction was 100 percent (1.0) for all groundwater
contaminants.
Groundwater inhalation dose considers the following factors:
volatile generation rate, inhalation rate, body weight, air
exchange rate, shower duration, and total duration in bathroom.
The inhalation rate used was 20 liters/min, for a 70-kg receptor,
and the air exchange rate was 8.3E-03 min~* . The shower duration
and total exposure duration were set at 15 minutes and 20
minutes, respectively.
The assumptions used in the groundwater dose calculations are
standard and applicable to current site conditions.
Doses for the dermal adsorption route of exposure are calculated
using contaminant concentration, area of skin exposed, fraction
of contaminant adsorbed, soil adherence per unit area, exposure
duration, and body weight. Receptor body weights used were
either 50 kg for youths or 70kg for adults. Worst-case estimates
employed a 30-day exposure period for 40 years and the
plausible-case scenario was calculated using 10 days for 40
years. Exposure duration over a lifetime is a factor in
calculating doses and risks from carcinogenic exposure.
Noncarcinogenic exposure uses a comparison between maximum daily
dose and the applicable health standard.
Conservative assumptions used in modeling dose from the
inhalation of emissions from source areas included use of on-site
contaminant concentrations to represent downwind concentrations.
Calculations of these doses also factored in inhalation rates,
fraction of contaminant adsorbed, exposure duration, and the
receptor's body weight. Inhalation rate was set at 20 cubic
meters per day, and it is assumed that 100 percent of the
volatile compounds and only 20 percent of the inorganic compounds
is adsorbed. Both maximum and arithmetic average soil
concentrations were used to generate worst-case and plausible
case exposure scenarios, respectively.
The estimates made for the exposure scenarios are the best
representation of the site conditions at the time of the Remedial
Investigation.
Toxicity Assessment
The toxicological evaluation characterizes the inherent toxicity
of the chemicals. It consists of a review of scientific data to
determine the nature and extent of the human health and
environmental hazards associated with exposure to the various
chemicals. Subsections A. and B. immediately below discuss the
concepts of cancer potency factors (CPFs) and reference doses
(RfDs) as they are typically employed in the risk assessment
process. A site-specific discussion of contaminant toxicity and
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13
the applicable Appendices is included in the "Risk.
Characterization" section below (subsections B. and C.).
A. Cancer Potency Factors
t
Cancer potency factors have been developed by EPA's Carcinogenic
Assessment Group, for estimating the lifetime probability of
human receptors contracting cancer as a result of exposure to
known or suspected carcinogens present in site media. Cancer
potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays, to which
animal-to-human extrapolation and uncertainty factors-have been
applied. CPFs are expressed in units of (mg/kg-day) . CPFs 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. The use of CPFs is in
accordance with U.S. EPA's guidance for establishing carcinogenic
risk.
B. Reference Doses
Reference doses have been developed by EPA (and MDNR in the case
of 0.0004 mg/kg-day for lead) for indicating the potential for
adverse health effects from chronic and or sub-chronic human
exposure to chemicals exhibiting noncarcinogenic effects. RfDs,
expressed in units of mg/kg-day, are estimates of lifetime daily
chemical exposure levels for humans, including sensitive
individuals, that are likely to be without an appreciable risk of
adverse noncarcinogenic health effects. RfDs are derived from
human epidemiological studies or animal studies, to which
uncertainty factors have been applied, 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.
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.
Risk Characterization
The following section describes the process used in the Risk
Assessment to estimate the potential incidence of adverse health
or environmental effects under the exposure scenarios defined in
the above section.
A. Uncertainty in Risk Assessment
Carcinogenic and noncarcinogenic health risks are estimated using
a number of different assumptions. The extent to which health
risks can be characterized is primarily dependent upon the
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14
accuracy with which a chemical's toxicity can be estimated and
the accuracy of the exposure estimates. The toxicological data
that form the basis for all risk assessments contain uncertainty
in the following areas:
»
* The extrapolation of non-threshold (carcinogenic)
effects from the high doses administered to laboratory
animals to the low doses received under more common
exposure scenarios.
* The extrapolation of the results of laboratory animal
studies to human or environmental receptors.
* The inter-species variation in toxicological endpoints
used in characterizing potential health effects
resulting from exposure to a chemical.
* The variations in sensitivity among individuals of any
species.
Exposure estimates presented for groundwater are based on a
number of simplifying assumptions, including the following:
* A contaminant is leached from soil and waste materials
according to the relationship between its environmental
concentration and its solubility, as defined by the
Organic Leaching Model.
* Solubilized contaminants are transported along with the
normal groundwater flow. They reach a receptor at any
defined distance from the source at a concentration
proportional to the source concentration, as defined by
the VHS Model.
* Physical and chemical characteristics of site soils and
groundwater such as retardation, solubilities,
partitioning coefficients, and colloidal effects, are
not necessarily considered.
* Receptor characteristics, such as age, body weight and
exposure duration, are based on published values, with
some attempt at making them more site-specific (eg.
known duration of site use by ORVers).
For soils the main simplifying assumption for assessment of risk
is that contaminants are transported along with air currents or
as particulates, with wind direction and velocity, and are not
dispersed en route to the receptor.
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- . 15 .--•..'
For all exposure scenarios and all media, the chemical analytical
data base is limited by sample locations and sample frequency.
Every effort is made to collect samples that reflect actual site
conditions, but not every portion of the site can be sampled.
»
The following sections on carcinogenic and noncarcinogenic risk
are provided as a description of how risk is characterized, and
the Rasmussen Risk Assessment numbers generated prior to the
removal and sampling of 1989 and 1990 are used as examples. It
should be noted that the receptor concentrations used in the
assessment are based on the leaching of chemicals from wastes
prior to them being removed from the site in 1989/1990. The
chemicals of concern noted in the Risk Assessment and Feasibility
Study were based on conditions prior to the 1989/1990 removal.
The groundwater chemicals of concern listed in Table 1 are for
contaminants found in the groundwater at concentrations above
health-based levels or taste and odor considerations (discussed
further on), that currently exist at the site.
B. Carcinogenic Risks
Carcinogenic risks can be estimated by combining information in
the dose-response assessment (carcinogenic potency factors) with
an estimate of the individual intakes (doses) of a contaminant by
a receptor. The resulting number (risk) is an expression of an
individual's likelihood of developing cancer as a result of
exposure to the carcinogenic indicator chemicals. This
likelihood is in addition to the risks incurred by everyday
activities. For example, a risk of 1E-06 is applied to a given
population, to determine the number of excess cases of cancer
that could be expected to result from exposure. The figure of
1E-06 is one additional case of cancer in 1,000,000 exposed
persons.
For purposes of the groundwater risk evaluation, the Agencies
considered a hypothetical shallow aquifer residential well,
installed at the Spicer Road property boundary. The movement of
contamination with the groundwater was modeled under several
scenarios. The four scenarios presented in the Risk Assessment
included using both the maximum and arithmetic average subsurface
soil source concentrations, each with 1 meter and 10 meter values
of transverse dispersivity (lateral movement) in order to present
a range of potential risk. The total predicted carcinogenic
rrsks (includes both an ingestion and inhalation component) from
potential routine use of contaminated groundwater generated on-
site for the four scenarios are listed in Table 3-6 of the Risk
Assessment attached as Appendix 5 to this ROD. The Rasmussen
groundwater plume as well as the four soils areas are included.
Tables 3-7 and 3-9 of Appendix 5 show the carcinogenic risk from
the soils areas as they pertain to the exposure scenarios of
dermal contact and inhalation of fugitive dust.
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TABLE 1 - CARCINOGENIC RISK AND GROCNDWATER CLEANUP LEVELS FCR THE RASMOSSEN SHE
CHEMICAL
MAX. CONG. POUND
(PI*)
CARC. RISK
W/ MAX CONC.
CLEANUP LEVEL
BASIS
CARC. RISK W/
CLEANUP LEVEL
acetone
benzene
bis (2-ethylhexy 1) phthalate
2-butanone
cadmium
chlorobenzene
2-chlorophenol
1,1-dichloroethene
1,2-dichloroethene
ethylbenzene
isophorone
lead
2-methyphenol
4-methyl-2-pentanone
methylene chloride
toluene
1,1,1-trichloroethane
trichloroethene
vinyl chloride
xylenes
26,()bO.O
700.0
12.0
74,000.0
29.0
3,700.0
17.0
2.0
590.0
2,400.0
440.0
779.0
1,600.0
30,000.0
1,100.0
71,000.0
500.0
774.0
96.0
11,000.0
5.8E-04
4.8E-06
.0
.0
3.4E-05
4.1E-05
2.2E-04
2.3E-04
6.2E-03
700.0
1.2
2.0
350.
4.
50.0
5.0
1.0
100.0
30.0
8.0
5.0
300.0
350.0
5.0
40.0
200.
3.
.0
.0
1.0
20.0
HLSC
1E-06
1E-06
HLSC
HLSC*
T&O
T&O
MDL
HLSC
T&O
1E-06
HLSC*
T&O
HLSC
1E-06
T&O
MCL
1E-06
MDL
T&O
l.OE-06
l.OE-06
1.7E-05
l.OE-06
l.OE-06
l.OE-06
7.0E-05
TOTAL CARCINOGENIC RISK FRCM CONTAMINANTS
CURRENTLY IN GROUNDWATER = 7.3E-03
TOTAL CARCINOGENIC RISK FROM CONTAMINANTS
AT CLEANUP LEVELS
Key to Basis of Cleanup Levels
MDL = Method Detection Limit
MCL = Maximum Contaminant Level
1E-06 = One in One Million Carcinogenic Risk Level
T & 0 = Taste and Odor Threshold
HLSC = Human Lifecycle»Safe Concentration
HLSC* = HLSC or Filtereii Background (whichever is higher)
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16
The carcinogenic risks associated with the maximum.groundwater
concentrations are listed in Table 1 of this ROD.
Major contributing chemicals to the carcinogenic risks from
dermal contact with site soils are as follows: PCBs and
benzo(a)pyrene for the TML; PCBs for the IW; PCBs for the PDSLD;
and dioxins for the NEBD. As noted previously, the drummed
wastes and associated contaminated soils have now been removed
from the IW, NEBD and TML areas of concern. Remediation of these
soils areas is, however, necessary for mitigation of the
potential risk posed by the contaminated soils areas to
groundwater, as noted in Table 3-6 of Appendix 5.
The 1989/1990 supplemental soils investigation, included as
Appendix 3, showed the presence of contaminated soils in the
PDSLD which are a current source of groundwater contamination.
These findings provided more detail with regard to the threat
posed by the PDSLD soils.
Even under the worst-case scenario, the risks from potential
fugitive dust emissions do not exceed 1.56E-07. This is shown in
Table 3-9 of Appendix 5. Potential inhalation of ambient air
from the combination of the Spiegelberg and Rasmussen sites prior
to the 1989/1990 source control removal activities, in the
worst-case scenario, produces a total carcinogenic risk of 4.1E-
06. An explanation of inhalation risk calculation can be found
above in the section entitled "Dose and Exposure Scenarios".
C. Noncarcinogenic Risk
Potential health risks resulting from exposure to noncarcinogenic
compounds are estimated by dividing the maximum daily dose
exposure by the Reference Dose (RfD), to obtain the Hazard Index.
If the Hazard Index exceeds one, there is a potential health risk
associated with exposure to that particular chemical. The
Hazard Index is not a prediction of the severity of toxic
effects, but simply a numerical indicator of the transition from
an acceptable to unacceptable levels. The total Hazard Index for
an exposure route is the sum of all Hazard Indices for each
individual chemical. Hazard Indices were determined for the
existing Rasmussen groundwater plume as noted in the Risk
Assessment Table 3-11 and included in Appendix 6 here. Hazard
Indices were greater than one for the groundwater plume itself,
and for worst-case scenario for the NEBD in the pre-removal
hazard assessment. The Hazard Index Tables for the direct dermal
contact and the fugitive dust emissions scenarios are included in
Risk Assessment Tables 3-12 and 3-14, and attached as Appendix 6
here. None of the direct dermal contact or fugitive dust
emission Indices exceeded one.
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17
Environmental Risk
Over and above its utilitarian value to humans as a usable
aquifer, the groundwater is a resource to be evaluated as are all
other environmental compartments and life forms. Based on the
findings of the Remedial Investigation, a portion of the on-site
groundwater at the Rasmussen site has been degraded and poses the
potential for degrading more of the downgradient resource, if not
remediated. The prevention of further degradation of the
presently contaminated groundwater resource is an environmental
remedial objective that needs to be addressed by any remedy
chosen for the Rasmussen site.
Also evaluated for environmental risk from groundwater
contamination were air, soil, surface waters, and terrestrial and
aquatic biota. None of these potential environmental receptors
were determined to be at risk from the Rasmussen site.
Based on reports of citizen's complaints early in the Rasmussen
site's history, burning wastes and reports of odors may have been
indicative of air releases at that time. Through recent sampling
efforts, air releases have not been found to pose a risk at the
Rasmussen site.
No hydrologic connection was found to exist between the site's
source areas and the area's surface waters. The Huron River is
about a mile and one half north of the contaminated portion of
the site. The Spiegelberg peat pond to the south and several low
areas to the north and east are the only surface water features
located near the site. Assessment of these features showed them
to be uncontaminated, and not hydrologically connected to the
waste areas on the site.
One threatened species, the Eastern Sand Darter (Aromocrvpta
pellucida) (a member of the perch family), and one special
concern species, the Dwarf Hackberry (Celtis tennifolial. were
identified as inhabiting environs near the site. Although
terrestrial flora and fauna which live within or traverse the
site may come in contact with contaminated surface soils,
environmental toxicologists have noted that if contamination is
addressed to protect for human health, potential risks to
wildlife would be addressed as well.
No critical habitats have been threatened by the contamination at
the Rusraussen Site.
Chemicals of Concern and Cleanup Levels
Chemicals of concern were determined for the Rasmussen
groundwater plume. The basis for the selection of the 20
chemicals of concern (noted in Table 1), are those detected at
levels in Remedial Investigation sample data, and which pose a
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18
potential risk to human health and the environment. The
Chemicals of Concern pose a potential risk by either exceeding
the level for the 1E-06 carcinogenic risk-, by exceeding the level
for Human Lifecycle Safe Concentrations (HLSCs), or by exceeding
an aesthetics level. The basis for the selection of these
cleanup levels is provided in CERCLA Section 121 and the NCP. In
order to protect human health and the environment, under CERCLA
and the NCP, risk-based cleanup levels have been established for
groundwater. A risk-based cleanup is necessary due to the close
proximity of residential wells and the potential future use of
groundwater at and near the site. These cleanup levels are
consistent with "Type B" cleanup criteria in Michigan Act 307 and
the Michigan Act 307 Rules (R299.5705, 707, 709, 717).
The chemicals which have cleanup levels based on the 1E-06
carcinogenic risk for the existing groundwater plume are:
benzene, bis(2-ethylhexyl)phthalate, isophorone, methylene
chloride, and trichloroethene. These chemicals are known to
cause cancer in laboratory animals, and thus are classified as
carcinogens.
Two carcinogens, 1,1-dichloroethene and vinyl chloride have
carcinogenic risk levels which are lower than what can be
detected by current laboratory methodologies. These chemicals
have cleanup levels set by their respective method detection
limits (MDLs).
A second group of chemicals of concern at this site are
classified as noncarcinogens and are believed to exert their
toxicity by a threshold mechanism of action. The HLSCs, which
were developed for the noncarcinogens, are based on this concept.
The HLSCs represent the highest groundwater concentration to
which a human can be exposed continuously, for a lifetime,
without exhibiting any observable adverse health effects.
Cleanup levels for six chemicals were set in this manner:
acetone, 2-butanone, cadmium, lead, trans-l,2-dichloroethene, and
4-methy1-2-pentanone.
Unfiltered samples analyzed during the RI were found to exceed
the HLSC calculated for lead and cadmium. There may be reason to
believe that dissolved levels of lead and cadmium will not exceed
background dissolved concentrations. Therefore, the HLSC
groundwater cleanup level noted in Table 1 is starred (*). This
indicates that a determination will be made as a result of
design studies. If 1) filtered lead and cadmium samples are less
than 5.0 ppb and 4.0 ppb, respectively; or if 2) on-site filtered
lead and cadmium samples are greater than 5.0 and 4.0 ppb,
respectively, and on-site filtered lead and cadmium levels are
equal to or than their corresponding filtered background
samples, then cleanup for these chemicals of concern will not be
required.
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19
Where insufficient data exist to calculate HLSCs for
noncarcinogens, or where aesthetic data indicate that the
chemical can still be detected either by.taste or smell at the
HLSC level, the literature-derived Taste and Odor (T&O)
threshold is used as the cleanup level. The cleanup levels for
chlorobenzene, ethylbenzene, 2-methylphenol, toluene, and xylenes
are based on taste and odor thresholds.
One noncarcinogen, 2-chlbrophenol, has a taste and odor threshold
below what can be reliably detected. Therefore, the cleanup
level for 2-chlorophenol is set at the MDL.
Summary of Risks
Although no individuals are directly ingesting contaminated
groundwater from the Rasmussen site, the contamination could pose
a health risk to potential receptors in the future. A
significant amount of contaminated groundwater currently remains
on site and is expected to continue to migrate towards
downgradient wells, thereby creating potential exposure routes
for human receptors. The future possibility exists, as well, for
groundwater use at the site. In order to protect public health
and the environment, remediation of the groundwater resource is
necessary. The NEED, TML, and IW soils areas of concern pose
potential risks to the groundwater resource, while the PDSLD area
poses a current risk to the groundwater. Remediation of these
four soils areas is necessitated by the risks posed to
groundwater.
Potential risks from direct dermal contact or from inhalation of
airborne contaminants, when modeled, do not pose significant risk
to human health.
Actual or threatened releases of hazardous substances from the
Rasmussen site, if not addressed by implementing the response
action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of Alternatives
Alternatives Screening Process
Initially, the Feasibility Study considered all potential
alternatives for remediation of the Rasmussen site. Subsequent
preliminary and detailed screening left only a limited number of
alternatives, in part due to ARARs which restricted remedial
options because of waste types and concentrations present.
The reader is directed to Tables 6-6, 6-7, 6-8 and 6-9 in Volume
III (and associated text in Chapter 6) of the Feasibility Study
Report, for the detailed screening of the PDSLD, IW, NEBD, and
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20
TML soils areas, respectively. The alternatives remaining after
detailed screening of the TML soils area of concern were clay and
multi-media capping, and on-site incineration. The detailed
screening of alternatives for the Rasmussen groundwater plume
area of>concern is described in Chapter 7 of the Feasibility
Study Report and is supported by Tables 7-1, 7-3, and 7-4 in that
report.
In the subsequent evaluation of incineration versus capping, cost
and dioxin disposal were the two major considerations. The large
volume and the variability of the waste contained in the dump
make incineration an extremely costly (over $100 million) option.
Dioxins were found in the TML, but on average were below 1.0 ppb,
the level which may trigger further action (Kimbrough et.al.,
1984). However, the presence of dioxins increases the short-
term inhalation risk to workers and community for alternatives
which involve excavation (due to fugitive dust emissions). The
implementability of the off-site disposal option is limited at
best, as no landfills in the United States accept dioxin-
containing wastes and no vendors were found to treat this waste
type.
Since liquids and other concentrated industrial wastes have been
removed from the NEED, IW and TML by EPA and the PRPs, the
capping alternative is enhanced.
U.S. EPA guidance provides for the combination of medium-specific
alternatives during the detailed analysis phase of remedy
selection. If comprehensive options are found to address all
potential site threats, then the Agency may propose site-wide
remedial alternatives. Remedy selection in the Feasibility
Study anticipated completion of the removal actions, and the
site-wide alternative was proposed as a remedy. Chapters 8 and 9
of the Feasibility Study describe the transition from the
comprehensive list of alternatives to the site-wide alternatives.
As part of the combination of alternatives, the process options
evaluated in the detailed screening of alternatives for the
Rasmussen groundwater were combined to develop a site-wide action
alternative for the contaminant plume. Page 8-5 of Volume I of
the Feasibility Study describes the combination of groundwater
remedial alternatives.
Subsequent to the completion of th2 Feasibility Study, a
supplemental soils investigation in the PDSLD, completed in early
1990, provided additional information as to the nature and extent
of the contamination in this area and led to differing
conclusions with regard to the preferred alternative. The
Remedial Investigation led the Agencies to conclude that soils,
particularly in silty lenses throughout the unsaturated zone in
the PDSLD, were contaminated with PCBs and other organic
contaminants. Based on these facts, remedy selection efforts
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21 . .
were focused on actions which would prevent the contaminants,
shown to be in the intervening PDSLD layers, from migrating to
the groundwater, while providing a level of protectiveness for
the other three soils areas of concern. Excavation and capping
options* were explored along with the non-excavation and capping
options. The accompanying groundwater remedy included re-
injection of treated groundwater via recharge wells rather than
seepage basin reintroduction, due to the lack of space remaining
if the soils capping remedies were implemented. Recharge wells
were found to be less costly than seepage basins, when used
purely for the reintroduction of treated water.
The 1989/1990 supplemental soils investigation of the PDSLD
showed that the following conditions exist in this area:
* The unauthorized sand and gravel mining from this area
in 1987 had taken with it some contaminants from the
unsaturated soils.
* No PCBs were determined to exist at depth in the PDSLD.
* PCBs were not found in the PDSLD soils at
concentrations significantly exceeding 1 ppm.
* Contaminants such as chlorobenzene, ethylbenzene,
toluene, xylenes, 1,2-dichlorobenzene, and 1,3-
dichlorobenzene were found to be within the 25-foot
zone above the water table in the PDSLD. Contaminant
levels were highest at or near the water table.
* Contaminants such as 1,1,1-trichloroethane and
tetrachloroethene were distributed throughout the soil
in the PDSLD, but in concentrations below health-based
risk levels.
Although capping options were retained for the soils areas of
concern as the best overall option and groundwater purge and
treat was retained for treatment of the groundwater plume,
modifications were made to tailor the options based on the new
information. Modifications include:
* The cap would not be effective in containing the
remaining contamination in the IW and PDSLD areas since
it is concentrated in the soil profile just above the
water table, and would continue to be a source of
contamination to the groundwater as the water table
fluctuated. Direct contact with the surface soils of
the PDSLD and IW areas is no longer a concern, so the
cap would not be necessary for those areas. The cap
should cover the TML including the NEED, to prevent
further infiltration, and direct contact with
contaminants.
-------
' - . 22 .
* Reintroduction of treated groundwater could now be
achieved more cost effectively through seepage basins,
since this system, when located above the IW and PDSLO
areas, will serve the dual purposes of 1)
reintroduction of treated groundwater and 2) flushing
of contaminants through the unsaturated zone to the
groundwater, and toward the extraction wells. This
will create a closed-loop groundwater treatment system.
These considerations resulted in different cost estimates and
remedy descriptions in the Proposed Plan than were presented in
the Feasibility Study. Capping cost estimates (below) have been
modified some since the issuance of the Feasibility Study to more
accurately reflect the amount of material required for each cover
type and areal extent. The groundwater cost estimate has also
changed to include seepage basins instead of injection wells.
Cost estimates do not reflect any future drum disposal which may
be required. Drum removal will add roughly $1,000 per container
to the overall cost of each of these options. However, costs are
comparable for all of the capping alternatives.
Design studies show that for all of the capping options
considered, the Rasmussen cap will extend onto the Spiegelberg
property. This is necessitated by cap design criteria involving
slope for drainage and erosion control. Terracing may be designed
into the selected alternative to control the overflow onto
neighboring properties.
Description of Site-wide Alternatives
The site-wide remedial alternatives described below, were
evaluated in the Feasibility Study as Alternatives 1 through 7—
with Alternative 1 being the No Action Alternative for the soils
areas; Alternatives 2 through 5, variations on the in-place
capping alternative; Alternative 6, the No Action Alternative for
groundwater; and, Alternative 7, a Treatment Alternative for
groundwater. Alternatives 8 and 9 in the Feasibility Study are
pertinent to the neighboring Spiegelberg site, and are therefore
not addressed in this ROD.
Soils
Site Wide Alternative 1 - NO ACTION.
Under this scenario, no further remedial measures would be taken
for the four soils areas of concern to prevent potential exposure
to, or migration of the contaminants in the unsaturated zone
soils to the groundwater. Risks currently posed by the
contaminated groundwater are expected to increase under this No
Action scenario. Although the site is currently fenced, the
potential for direct contact with contaminated surface soils is
not completely eliminated, and the No Action Alternative does
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- . 23 •. '.
nothing to reduce the potential for direct contact.with these
soils.
Implementation Time: None.
Capital Cost: $ 0
Annual Operation and Maintenance (O&M): $ o
Total Costs w/ l Year O&M: $ 0
Site Wide Alternative 2 - Clay cap with no further excavation and
restricted access.
Under this alternative, a Michigan Act 64 cap with a 3-foot thick
clay layer, a minimum of one-foot thick drainage layer and a one-
foot thick vegetated soil layer would be constructed over the
combined TML and NEBD areas of concern. The IW and PDSLD areas
need not be covered, but may be partially covered in order to
provide adequate north-face slopes for the two capped areas.
Access restrictions, such as fencing, would be placed around the
capped soil areas. Deed restrictions would be instituted to
prevent future land use. Drums which are currently visible, or
which are unearthed during cap implementation, will be disposed
of in accordance with applicable Federal and State regulations.
Implementation Time: 1 to 2 years.
Capital Cost: $ 2,940,247
Annual Operation and Maintenance (O&M): $ 53,043
Total Costs w/ 1 Year O&M: $ 2,993,290
Site Wide Alternative 3 - Clay cap with further excavation and
restricted access.
Under this alternative, the PDSLD area would be excavated and
consolidated alongside the north face of the dump. A clay cap
(as described in Alternative 2) would then be constructed over
the consolidated areas. Access restrictions, such as fencing
would be placed around the capped soil areas. Deed restrictions
would be instituted to prevent future land uses. Drums which are
currently visible, or which are unearthed during cap
implementation, will be disposed of in accordance with applicable
Federal and State regulations.
Implementation Time: 1 to 2 years.
Capital Cost: $ 4,486,019
Annual Operation and Maintenance (O&M): $ 53,043
Total Costs w/ 1 Year O&K: $ 4,539,062
Site Wide Alternative 4 - Multi-media cap with no further
excavation and restricted access.
Under this alternative, a multi-media RCRA-type cap with 1) a 12-
inch thick vegetated soil layer on top, 2) a 12-inch thick
drainage layer, 3) a synthetic liner at least 20 milliliters
-------
, 24 ..-.-.
thick/ and 4) a 2-foot thick layer of compacted clay with a
permeability of 1E-07 cm/sec or less would be constructed over
the TML and NEBO areas of concern as they now exist spatially on-
site. Access restrictions, such as fending, would be placed
around the capped soil areas. Institutional controls, such as
deed restrictions, would be instituted to prevent future land
uses. Drums which are currently visible, or which are unearthed
during cap implementation, will be disposed of in accordance with
applicable Federal and State regulations.
Implementation Time: 1 to 2 years.
Capital Cost: $ 4,946,285
Annual Operation and Maintenance (O&M): $ 200,000
Total Costs w/ 1 Year O&M: $ 5,146,285
Site Wide Alternative 5 - Multi-media cap with further excavation
and restricted access.
Under this alternative, the PDSLD area would be excavated and
consolidated alongside the north face of the landfill. A multi-
media RCRA-type cap with 1) a 12-inch thick vegetated soil layer
on top, 2) a 12-inch thick drainage layer, 3) a synthetic liner
at least 20 milliliters thick, and 4) a 2-foot thick layer of
compacted clay with a permeability of 1E-07 cm/sec or less would
be constructed over the consolidated areas of concern as they now
exist spatially on-site. Access restrictions, such as fencing,
would be placed around the capped soil areas. Institutional
controls, such as deed restrictions, would be instituted to
prevent future intrusive land uses. Drums which are currently
visible, or which are unearthed during cap implementation, will
be disposed of in accordance with applicable Federal and state
regulations.
Implementation Time: 1 to 2 years.
Capital Cost: $ 6,491,669
Annual Operation and Maintenance (O&M): $ 200,000
Total Costs w/ 1 Year O&M: $ 6,691,669
Additional Notes on Capping Options
Alternatives 4 and 5 (multi-media caps) reduce surface water
infiltration by 99 percent, while Alternatives 2 and 3 (clay
caps) reduce infiltration by 95 percent.
The cost estimates for alternatives 2, 3, 4, and 5 do not include
rmuoval of drummed wastes which may be encountered during
excavation. Drum removal will add on roughly $1,000 per
container to the overall cost of each of these options.
-------
, . .25
Groundwater
Site Wide Alternative 6 - NO ACTION.
Under this alternative, no further remedial measures would be
taken to remediate the groundwater. Current groundwater
contamination would not be addressed, the contaminants would
potentially migrate off-site, and pose an endangerment to public
health and the environment.
Implementation Time: None.
Capital Cost: $ 0
Annual Operation and Maintenance (O&H): $ 0
Total Costs w/ l Year O&M: $ 0
Site Wide Alternative 7 - Treatment
This groundwater treatment alternative includes:
* extraction of groundwater to capture and halt the flow of
the plumes.
* removal of heavy metal contaminants by chemical
precipitation followed by pH adjustment (if necessary).
* removal of several organic contaminants, including ketones,
by a biological treatment system.
* removal of residual organic contaminants via air stripping.
* further removal of residual organic contaminants via
granular activated carbon (GAC) (or other carbon adsorption
methodology, if necessary).
* discharge of treated water to the groundwater via a seepage
basin situated over the IW and PDSLD soils areas of concern.
* groundwater monitoring through a system of wells to assess
the effectiveness of the system at:
* halting the migration of contamination.
* reducing the levels of contamination in the soils
and groundwater, over time.
* a process effluent sampling program to aid in determining
the effectiveness of the remedy.
* fencing.and deed restrictions, as necessary, to ensure the
integrity of the remedy.
* Residential well sampling will be continued, in conjunction
with that called for in the final remedial actions at the
neighboring Spiegelberg Superfund Site.
The final processes to be installed for groundwater cleanup will
be determined by treatability studies during design.
Since contamination has been confirmed in the location of
groundwater monitoring well RA-MW-27, groundwater will need to be
purged from this location and will need to be manifolded into the
treatment system feed supply line for treatment prior to
discharge.
-------
, 26
Implementation Time: Minimum of 5 years.
Capital Cost: $ 2,740,000
Annual Operation and Maintenance (O&M): "$ 4,580,000
Total Costs w/ 1 Year O&M: $ 7,320,000
i
This groundwater treatment alternative would initially cost
roughly $150,000 less if injection wells were used rather than a
seepage basin for re-introduction of treated groundwater.
The reinjected water from the treatment system will not contain
contaminant levels in excess of the levels specified in Table 1,
and the system will be designed as a "closed loop" so that
contaminated groundwater will not migrate off-site. The ultimate
goal of this treatment option is to reduce groundwater
contaminant levels to that which are protective of public health
and the environment, based on the potential for groundwater use
at the site. The goal of flushing for the PDSLD/IW soils is to
reduce contaminant levels to that which will not continue to
adversely impact the groundwater resource. This is discussed
further on in the sections entitled "Attainment of Goals" and
"Compliance Points".
Treatment system sludges generated on site will be tested to
verify their characteristic nature and properties in order to
determine if they are subject to the RCRA Subtitle C
requirements, including the Land Disposal Restrictions (LDRs), or
other pertinent regulations. Those sludges which are not subject
to the RCRA requirements will be disposed of on-site, or at a
landfill meeting applicable Federal and State regulations. Those
sludges identified as RCRA hazardous wastes, will be processed to
ensure compliance with LDR treatment standards, prior to disposal
at a RCRA licensed landfill. The activated carbon will be
regenerated off site at a permitted facility. A monitoring
system designed to verify capture of the contaminant plume will
be implemented, and will include monitoring of residential wells
in the area.
Sirtnrnairy of Comparative Analysis of the Remedial Alternatives
The following nine criteria, outlined in the NCP at Section
300.430(e)(9)(iii), were used to compare the alternatives and to
determine the most appropriate alternative for remediation of the
soils and groundwater that is protective of human health and the
environment, attains applicable or relevant and appropriate
requirements (ARARs), is cost-effective and represents the best
balance among the evaluating criteria. The paragraph(s)
following each criterion detail how the alternatives meet or fail
to meet, that criterion. This comparison of alternatives
considers the "action" options for soils and for groundwater as
complete site-wide alternatives, particularly as they pertain to
Alternatives 2 and 4. For these two alternatives, the soils
action is interdependent with the groundwater seepage basin
-------
27 ...
alternative. For Alternatives 3 and 5, which include excavation
and consolidation of waste areas, the groundwater Alternative 7
would include the less-costly reinjection well process option.
1. Overall Protection of Human Health and the Environment
addresses whether or not a remedy provides adequate
protection and describes how risks are eliminated, reduced
or controlled through treatment, engineering controls or
institutional controls.
All of the site-wide alternatives considered for the soils areas,
with the exception of the No Action Alternative, provide adequate
protection by reducing risk to human health and the environment
by capping soils available for dermal contact, and by limiting
the potential for further contaminant migration, via
infiltration, to the groundwater. Alternatives 4 and 5, multi-
media caps, offer greater reduction of surface water infiltration
than do Alternatives 2 and 3, the clay caps. Short term risks
associated with Alternatives 2, 3, 4 and 5 are primarily due to
dust from construction activities. A health and safety program
which includes worker protection and dust suppression will reduce
these risks.
Alternatives 3 and 5 include further excavation of the PDSLD
soils and consolidate these soils within the site unit. The
combination of the non-excavation soils alternatives (2 and 4)
and a groundwater remedy with seepage basins remove contaminants
with minimal disturbance, as compared to the excavation options.
Although Alternative 4 with Alternative 7 achieves the greatest
overall level of protection of the alternatives being considered,
Alternative 2 with Alternative 7 is also adequately protective.
Implementation of either of these remedies would greatly reduce
the present and potential future exposure risks by: removing
contaminated source material through the groundwater purge
system; decreasing surface water infiltration in the capped areas
(inhibiting contaminant mobility); and limiting potential dermal
and inhalation exposures to contaminated surface soils.
The soils No Action Alternative 1 does nothing to prevent further
contamination of groundwater, or prevent dermal contact exposure
from residual contamination. The No Action Alternative 6 would
not provide protection from existing and potential future risks
to the groundwater.
2. Compliance with ARARs addresses how the proposed alternative
complies with all applicable or relevant and appropriate
requirements of Federal and more stringent State
environmental laws (ARARs) and also considers how
alternatives comply with advisories or other guidance that
do not have the status of laws, but that the U.S. EPA and
•f the State have agreed should be considered for
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28
protectiveness, or to carry out certain actions or
requirements.
A summary of identified ARARs for the soils and groundwater
alternatives are presented in Tables 2 and 3, respectively. All
potential ARARs are included in the Tables, which indicates which
ARARs are now Applicable or Relevant and Appropriate. The key
following the tables indicates whether the ARAR is chemical-
specific (C), location-specific (L), and/or action-specific (A).
As discussed in detail further on in this ROD, the selected
combination of remedies will attain all pertinent ARARs. These
tables list only those identified ARARs necessary for onsite
remedial activities. In some instances, the rules cited contain
both substantive and procedural or administrative requirements.
Only the substantive requirements are ARARs for the purpose of
on-site activities. Examples of administrative or procedural
requirements which are not considered ARARs include, but are not
limited to, reporting requirements and permit application
requirements.
The No Action alternative does not comply with all requirements
of the identified ARARs for the contaminated groundwater plume.
The majority of the remaining potential ARARs identified are not
applicable, relevant or appropriate to the groundwater No Action
Alternative. Adoption of this alternative would not prevent
further migration of contaminated groundwater.
Both the Federal and State Safe Drinking Water Acts are not
applicable (the aquifer under the site is not used for a
community or non-community public water supply) to the Rasmussen
groundwater considerations, but are relevant and appropriate
since they regulate Maximum Contaminant Levels in drinking water
for protection of human health. The aquifer of concern here is
the source of drinking water for the area. Table 11-2 and
Chapters 11.1.3 and 11.2.3 in Volume II of the Feasibility Study
address ARARs for the Rasmussen groundwater Alternatives.
Alternative 7 will attain ARARs specific to individual component
actions (i.e., chemical precipitation, biological treatment, air
stripping, and carbon adsorption).
Alternatives 2, 3, 4, and 5 for soils will meet Federal and State
ARARs, while the No Action Alternative does not comply with any
of the identified ARARs for the soils areas. Both the multi-
media and Michigan Act 64 clay caps comply with the requirements
found in the Resource Conservation Recovery Act at 40 CFR Part
264 et.seq. Please refer to Sections 9.1.3, 9.2.3, 9.3.3, 9.4.3,
9.5.3 of Volume II of the Feasibility Study, and Table 9-2 in
Volume III of the Feasibility Study, for discussions of the soils
Alternatives and ARARs.
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Table 2 - ARARs Sumary Site-Wide Alternatives Rasaussen Soils Areas for Alternatives 1,2, and 3
ALTERNATIVE 1
NO ACXTCM ALTERNATIVE
ALTERNATIVE 2
CLAY CAP
ALTERNATIVE 3
EXCAVATICW/CIAY CAP
FEDERAL ARARs
RCRA 40 CFR 264
Standards for owners and
operators of hazardous
waste TSD facilities.
RESOURCE GUN
Not an ARAR
xERVATICN AND KWXJ/EKY ACT (A and C)
40CFR 264.310;40CFR 264.116-117
Requirements are not applicable
because RCRA hazardous waste was
placed at the site prior to the
effective dates. Requirements
are relevant and appropriate since
they regulate circumstances
sufficiently similar to the site.
40CFR 264.310;40CFR 264.116-117
Requirements are not applicable
because RCRA hazardous waste was
placed at the site prior to the
effective dates. Requirements
are relevant and appropriate
since they regulate circumstances
sufficiently similar to the site.
CLEAN AIR ACT (A)
CAA 40 CFR 50
These regulations
establish the National
Primary and Secondary
Ambient Air Quality
Standards for sulfur
dioxide, particulate
matter, carbon monoxide,
ozone, nitrogen dioxide,
and lead.
40 CFR 50.1-50.12
This requirement is
applicable since
air contaminants may
be emitted.
40 CFR 50.6
Requirement is applicable since
construction operations would be
subject to the TSP standard
(150 ug/m - 24 hour average).
40 CFR 50.6
Requirement is applicable since
excavation and construction
operations would be subject to
the TSP standard (150 ug/m - 24
hour average).
OOCDPATICMAL SAFETY AND HEALTH ACT (A)
OSHA 29 CFR 1910
Occupational safety and
health standards adopted
to provide safe or
healthful employment.
Not an ARAR
29 CFR 1910.120
Requirement is applicable since cap
construction operations would take
place at a hazardous waste site
designated (for cleanup.
29 CFR 1910.120 ;
Requirement is applicable since
excavation and'construction
operations would take place at a
hazardous waste site designated
for cleanup.
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Table .. - ftige 2
ALTERNATIVE 1
NO ACTION ALTERNATIVE
ALTERNATIVE 2
CLAY CAP
%
ALTERNATIVE 3
EXCAVATION/CLAY CAP
OOCDPATKNAL SAFETY AID HEALTH ACT (A)
OSHA 29 CFR 1926
Regulations set forth
the safety and health
standards for
construction and related
activities.
Not an ARAR
29 CFR 1926
Requirement is applicable for all
on-site construction related
activities .
29 CFR 1926
Requirement is applicable for all
on-site construction related
activities.
STATE ARARs
HAZARDOUS WASTE MANAGEMENT ACT (A)
HVMA - ACT 64
Regulations containing
standards for generators
and transporters of
hazardous waste and
owners and operators of
TSDFs.
Not an ARAR
MAC R299. 9619(5) ;R299. 9620(2) ;
R299. 9611-9612
Requirements are not applicable
because HWMA hazardous waste was
placed at the site prior to the
effective dates. Requirements are
relevant and appropriate since they
regulate circumstances sufficiently
similar to the site.
MAC R299.9619( 5) ;R299. 9620(2);
R299. 9611-9612
Requirements are not applicable
because HWMA hazardous waste was
placed at the site prior to the
effective dates.
Requirements are relevant and
appropriate since they regulate
circumstances sufficiently
similar to the site.
AIR PcxinrxcN ACT (A)
APA - ACT 348
Rules containing
emissions limitations
and prohibitions for
particulate matter,
fugitive dust, and VOCs.
MAC R336.1901
Requirement is
applicable since air
contaminants nay be
emitted.
MAC R336.1371-R336.1373
Requirements are applicable since
construction operation at the site
are potential sources of fugitive
dust.
i
*
i :
MAC R336.1371-R336. 1373 ,R336. 1901
R336. 1301 ;R336. 1331 ;R336. 1702
These requirements are applicable
since excavation and construction
operations at. the site are
potential sources of fugitive
dust. Excavation operation would
be subject to State standards for
emissions of VOCs and particulate
matter.
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table 2 - Page 3
ALTERNATIVE 1
NO ACTION ALTERNATIVE
ALTERNATIVE 2
CLAY CAP
ALTERNATIVE 3
EXCAVKIXCN/CLAY CAP
SOIL EROSIGN SEDIMENTATION CCNTRCL ACT (A)
SESCA - ACT 347
Regulations prescribing
the requirements for
soil erosion and
sedimentation control
measures and procedures.
Not an ARAR
)
MAC R323.1701-R323.1714
Requirements are applicable since
construction operations would
involve earth changes and the
potential for soil erosion.
MAC R323.1701-R323.1714
Requirements are applicable since
excavation and construction
operations would involve earth
changes and the potential for
soil erosion.
FROST LAWS (A AND L)
MCLA - 257.722
Rules governing the
reduction of maximum
axle loads during the
period of March - May.
Not an ARAR
Section 257.722
Requirement is applicable since
materials could be transported to
the site from March to May.
Section 257.722
Requirement is applicable since
materials could be transported to
the site from March to May.
MINERAL WELL ACT (A)
MINERAL WELL ACT 315
Rules describing the
permitting requirements
for drilling brine,
storage, disposal, and
test wells.
Not an ARAR
H
ENDANGERED SPECIES ACT
Rules contain a listing
of the fish, wildlife,
and plant species that
have been determined to
to be endangered or
threatened.
Not an ARAR
MAC R299.2211-R299.2229
Requirements are applicable since
monitoring wells will be installed
up and downgradient of the capped
area, as part of the groundwater
monitoring requirements
(R299.9612).
«WC£KU) SHdClKS ACT (L)
MAC R299.1021-R299.1028
These requirements are applicable
since one. threatened species, the
Eastern Spnd Darter (Ammocrypta
pellucida), and one special ;>
concern species, the Dwarf
Hackberry (Celt is tennifolia) ,
have been reported to occur on or
near the site.
MAC R299.2211-R299.2229
Requirements are applicable since
monitoring wells will be installed
up and downgradient of the capped
area, as part of the groundwater
monitoring requirements
(R299.9612).
MAC R299.1021-R299. 1028
These requirements are applicable
since one threatened species, the
Eastern Sand Darter (Aitmocrypta
pellucida), and one special
concern species, the Dwarf
Hackbsrry (Celtis tennifolia) ,
have been reported to occur on or
near the site.
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Table 2 - Page 4
ALTERNATIVE 1
NO ACTION AUEHWKE1VE
ALTERNATIVE 2
CLAY CAP
ALTERNATIVE 3
EXCAVATION/CLAY CAP
MICHIGAN WATER RESOURCES COfOSSION ACT (A AND C)
MWRCA - ACT 245
Statute and rules
protect groundwater
resources from
injurious substances
provide for the
non-degradation of
groundwater.
and
Section 323.6(1)
Requirement is
applicable since
injurious substances
fran hazardous waste
leachate would
continue to migrate
toward groundwater.
Section 323.6(1) MAC R323.2201 et.
>6(j •
Requirement is applicable because
hazardous substances exist in the
soils which may discharge to the
groundwater. Remedy prevents such
discharge.
Section 323.6(1) MAC R323.2201 et.
seq.
Requirement is applicable because
hazardous substances exist in the
soils which may discharge to the
groundwater. Remedy prevents such
discharge.
ENVIRONIElflAL RESPCHSB ACT RULES (A AN) C)
ENVIRONMENTAL RESPONSE
ACT RULES
Rules describe cleanup
criteria for response
activities.
MAC R299.5601-
R299.5727
Parts 6 and 7 of the
Act 307 Rules provide
that remedial actions
be protective of
public health, safety,
and welfare and the
the environment and
natural resources, and
the attainment of
cleanup standards
under Type A, B, or C
cleanup. Parts 6 and
7 are ARARs for the
remedial action.
MAC R299.5601 Parts 6 and 7 of the
Act 307 Rules provide that
remedial actions be protective of
public health, safety, and welfare
and the environment and natural
resources, and the attainment of
cleanup standards under Type A, B,
or C cleanup. Parts 6 and 7 are
ARARs for the remedial action.
MAC R299.5601 R299.5727 Part 6 and
7 of the Act 307 Rules provide
that remedial actions be
protective of public health,
safety, and welfare and the
environment and natural resources,
and the attainment of cleanup
standards under Type A, B, or C
cleanup. Parts 6 and 7 are ARARs
for the remedial action..
-**
The State has identified Michigan Act 245, Part 22 Rules as an applicable ARARy The United
States disagrees that Act 245, as interpreted .and applied by the State in this matter, i.s an
ARAR. This issue is the subject of litigatiot) in U.S. v. Akzo Coatings of America, appellate
case numbers 89-2902 and 89-2137. ; :
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Table 2 - R*ge 5
ALTERNATIVE 4
HJLTI-MEDIA CAP
ALTERNATIVE 5
EXCAVATION/MOLTI-MEDIA CAP
'' FHXRAL ARARs
RESOURCE OUNSERVKTIGN AM) KHLXJNKttt ALT
RCRA 40 CFR 264
Standards for owners and
operators of hazardous waste
TSD facilities
40 CFR 264. 310; 40 CFR 264.116-117
Requirements are no applicable
because RCRA. hazardous waste was
placed at the site prior to the
effective dates. Requirements are
relevant and appropriate since they
regulate situations and
circumstances .
(A and C)
40 CFR 264. 310; 40 CFR 264.116-117
Requirements are not applicable because RCRA
hazardous waste was placed at the site prior to
the effective dates. Requirements are relevant
and appropriate since they regulate
circumstances sufficiently similar to the site.
CLEAN AIR ACT (A)
CM 40 CFR 50
These regulations establish the
National Primary and Secondary
Ambient Air Quality Standards
for sulfur dioxide, particulate
matter, carbon monoxide,
ozone, nitrogen dioxide, and
lead.
40 CFR 50.6
Requirement is applicable since
construction operations would be
subject to the TSP standard (150
ug/tn - 24 hour average).
40 CFR 50.6
Requirement is applicable since excavation and
construction operations would be subject to the
TSP standard (150 ug/m - 24 hour average).
*.
OCCUPATIONAL SAFETY AND HEALTH ACT (A)
OSHA 29 CFR 1910
Occupational safety and health
standards adopted to provide
safe or healthful employment
OSHA 29 CFR 1926
These regulations set forth the
safety and health standards for
const ruction and related
activities.
29 CFR 1910.120
Requirement is applicable since cap
construction operation would take
place at a hazardous waste site
designated for cleanup.
29 CFR 1926 ;
Requirement is applicable for all
on-site construction related
activities .
29 CFR 1910.120
Requirement is applicable since excavation and
construction operations would take place at a
hazardous waste site designated for cleanup.
29 CFR 1926
Requirement is applicable for all on-site
construction related activities.
-------
Table 2 - Page 6 •
AUHENATTVE 4
MJOT-MEDIA CAP
ALUHNATIVE 5
EXCAVATICN/MEin-MEDIA CAP
• STATE ARARs
»
HAZARDOUS HASIE MANAGEMENT ACT ACT (A)
HVMA - ACT 64
Regulations containing
standards for generators and
transporters of hazardous waste,
and owners and operators of
hazardous waste TSDFs.
MAC R299.9619(5);R299.9620(2);
Requirements are not applicable
because HHMA. hazardous waste was
placed at the site prior to the
effective dates. Requirements are
relevant and appropriate since they
regulate circumstances sufficiently
similar to the site.
MAC R299. 9619(5) ;R299.9620(2);R299. 9611-9612
Requirements are not applicable because HVMA
hazardous waste was placed at the site prior to
the effective dates. Requirements are relevant
and appropriate since they regulate
circumstances sufficiently similar to the site.
AIR ran/new ACT (A)
APA - ACT 348
Rules containing emissions
limitations and prohibitions for
parti culate matter, fugitive
dust, and VOCs.
SfiSCA - ACT 347
Regulations prescribing the
requirements for soil erosion
and sedimentation control
measures and procedures.
MAC R336.1371-R336.1373
Requirements are applicable since
construction operations at the site
are potential sources of fugitive
dust.
SOIL, autumn siouniiJMlKi'icM uxrjjfljl
MAC R323.1701-R323.1714
Requirements are applicable since
construction operations would
involve earth changes and the
potential for soil erosion.
MAC R336. 1371-R336. 1373 ;R336. 1901;
R336 . 1301 ;R336 . 1331 ;R336 . 1702
Requirements are applicable since excavation
and construction operations at the site are
potential sources of fugitive dust. Excavation
operations would be subject to State standards
for emissions of VOCs and particulate matter.
L ACT (A)
MAC R323.1701-R323.1714
Requirements are applicable since excavation
and construction operations would involve earth
changes and the potential for soil erosion.
FROST LAMB (A AM) L)
MCLA - 257.722
Rules governing the reduction of
maximum axle loads during the
period of March - May.
Section 257.722 '
Requirement is applicable since
materials could be transported to
the site from March to May.
Section 257.722
Requirement is applicable since materials could
be transported to the site from March to May.
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•Table 2 - Page 7
ALTERNATIVE 4
MULTI-MEDIA CAP
ALTERNATIVE 5
EXCAVATICN/MILTI-KBDIA CAP
' MINERAL NEIL ACT (A)
MINERAL WELL ACT 315
Rules describing the permitting
requirements for drilling brine,
storage, disposal, and test
wells.
ENDANGERED SPECIES ACT
Rules contain a listing of the
fish, wildlife, and plant
species that have been
determined to be endangered or
threatened.
MWRCA - ACT 245
Statute and rules protect
groundwater resources from
injurious substances and
provide for the non-degradation
of groundwater.
MAC R299.2211-R299.2229
Requirements are applicable since
monitoring wells will be installed
up and downgradient of the capped
area, as part of groundwater
monitoring requirements (R299.9612).
fiNUANmOtU) SHUKS ACT (L)
Mac R299.1021-R299.1028
Requirements are applicable
since one threatened species, the
Dwarf Hackbarry (Anrnocrypta
pellucida) ,and one special concern
species, the Dwarf Hackberry (Celt is
tennifolia), have been reported to
occur on or near the site.
MICHIGAN WATER RESOURCES CCMOSSICN
Sections 23.6(1) MAC R323.2201et.seq.
Requirement is applicable because
hazardous substances exist in the
soils which nay discharge to the
groundwater. Remedy prevents such
discharge.
MAC R299.2211-R299.2229
These requirements are applicable since
monitoring wells will be installed up and
downgradient of the capped area, as part of the
groundwater monitoring requirements (R299.9612)
MAC R299.1021-R299.1028
Requirement are applicable since one
threatened species, the Eastern Sand Darter
(Ammocrypta pellucida), and one special concern
species, the Dwarf Hackberry (Celtis
tennifolia) , have been reported to occur on or
near the site.
j_t_t.
ACT (A AM) C)
Section 323.6(1) MAC R323.2201 et.seq.
Requirement is applicable because hazardous
substances exist in the soils which may
discharge to the groundwater. Remedy prevents
such discharge.
'The State has identified Michigan Act 245, Part 22 Rules as an applicable ARAR. Ihe United States disagrees that
Act 245, as interpreted and applied by the State in this matter, is an ARAR. This issue is the-subject of
litigation in U.S. v. Akzo Coatings of America, appellate case numbers 89-2902 and 89-2137.
-------
* 2 - F&ge 8
ALTERNATIVE 4
MOLTI-MEDIA CAP
ALTERNATIVE 5
EXCAVATIOT/MJOT-ffiDIA CAP
ENVIRCtMENXAL RESPONSE ACT BOLES (A AND C)
E3WIKONMENTAL RESPONSE ACT RULES
Rules describe cleanup criteria
for response activities.
MAC R299.5601-R299.5727 Parts 6 and
7 of the Act 307 Rules provide that
remedial actions be protective of
public health, safety, and welfare
and the environment and natural
resources, and the attainment of
of cleanup standards under Type A,
B, or C cleanup. Parts 6 and 7 are
ARARs for the remedial action.
MAC R299.5601-R299.5727 Parts 6 and 7 of the
Act 307 Rules provide that remedial actions be
protective of public health, safety, and
welfare and the environment and natural
resources, and the attainment of cleanup
standards under Type A, B, or C cleanup. Parts
6 and 7 are ARARs for the remedial action.
-------
Table 3 - ARARs Sunoary for No Action and Treatment
Alternative for the Rasnussen Qrounduater Plume
NO ACTTGN
TREKBfBfT ALTERNATIVE
FEDHtAL ARARS
RB9CURCE CONSERVATION AND RBCCWERY ACT (A and C)
RCRA 40 CFR 268
Land disposal
restrictions.
Not An ARAR
40 CFR 268 Subtitle C '.. -
Requirement is applicable since
chemical sludges will need to be
TCLP tested for proper disposal.
RCRA 40 CFR 264
Standards for
owners and
operators of
hazardous waste
treatment storage
and disposal
facilities.
Not an ARAR
40 CFR 264.94; 264.100
These requirements are not
applicable since groundwater is
not contaminated with RCRA
hazardous waste. Requirements are
relevant and appropriate since
they regulate circumstances
sufficiently similar to those at
the site.
40 CFR 264.301; 264.303-304;
264.310;
40 CFR 264.91-100; 264.111;
264.116-117
RCRA hazardous waste (chemical
precipitation sludge) would be
placed in a landfill, and covered
with a cap. Therefore, these
requirements are applicable.
40 CFR 264.271; 264.273; 264.278
These requirements are not
applicable since non-RCRA
hazardous wastes (bio treatment
sludge) would be land treated.
Requirements are relevant and
appropriate since they regulate
circumstances sufficiently similar
to those at the site.
RCRA 40 CFR 263
Standards
applicable to
transporters of
hazardous waste.
Not an ARAR
40 CFR 263
Transfer requirements are
applicable for all off-site
shipments of hazardous waste
(chemical precipitation sludge).
RCRA 40 CFR 262
Standard
applicable to
generators of
hazardous waste.
Not an ARAR
40 CFR 262
Hazardous waste generator
requirements would be applicable
for all hazardous wastes
transported off-site (chemical
Precipitation (sludge).
-------
Table 3 - Page Two
MO ACTION AUTBRNATXVE
TREATMENT ATJTERNAnVE
SAFE [KINKING WATER ACT (C)
SDWA 40 CFR 141
Regulations to
protect, human
health from '
drinking water
contaminants.
Establishes MZLs
and MCDSs.
40 CFR Part 141
Requirement is not
applicable since the
aquifer under the
site is not used to
supply a community or
non-community water
system. Requirement
is relevant and
appropriate since
it regulates
circumstances
sufficiently similar
to those at the site.
40 CFR Part 141
Requirement is not applicable
since the aquifer under the site
is not used to supply a community
or non-community water system.
Requirement is relevant and
appropriate since it regulates
circumstances sufficiently
similar to those at the site.
CLEAN AIR ACT (A)
CAA 40 CFR 50
Requirements
establish the
National Primary
and Secondary
Ambient Air
Quality Standards
for among other
things,
particulate matter
Not an ARAR
40 CFR 50.1-50.12
Requirements are applicable since
emissions from the treatment system
would be subject to Primary and
Secondary Ambient Air Quality
Standards. Construction activities
would be subject to the TSP
standard.
COCOPATICNAL SAFETY AND HEALTH (A)
OSHA 29 CFR- 1910
Occupational
safety and health
standards adopted
to provide safe or
healthful
employment.
Not an ARAR
29 CFR 1910.120
Requirement is applicable since
construction operations would take
place at a hazardous waste site
designated for cleanup.
OCCUPATIONAL SAFETY AN) HEALTH (A)
OSHA 29 CFR 1926
Regulations set
forth the safety
and health
standards for
construction
activities .
Not an ARAR
29 CFR 1926
Requirement is applicable for all
on-site construction related
activities .
-------
•Cable 3 - Page Ibtee
NO ACTION ALIIEHAnVE
•JKEflXMBfT AIHSaOSTIVE
DBARIMBiT OF TBXHSBCRJXnON (A)
DOT 49 CFR 107
Prescribes the
procedures ,
utilized by the
Materials
Transportation
Bureau, OHMP
and OOE for
transport of
hazardous
materials.
DOT 49 CFR 171
Contains general
information,
regulations, and
definitions
governing the
transportation of
hazardous
materials.
Not an ARAR
Not an ARAR
49 GER 107 .
Requirement is applicable since
hazardous wastes (chemical
precipitation sludge) would 4pe ..
transported to an off-site
disposal facility.. .
49 CFR 171
Requirement is applicable since
hazardous wastes (chemical
precipitation sludge) would be
transported to an of f -site
disposal facility.
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Table 3 - Page Four
HO ACXXCN AUDBNKTIVE
HAZARDOUS WASTE MANAGEMENT ACT (A)
HWMA - Act 64-
Regulations
containing
standards for
generators and
transporters of
haz. waste, and
owners of TSDFs.
Not an ARAR
MAC R299.9612
Requirements are not applicable
since groundwater is not
contaminated with HWMA waste.
Requirements .are relevant and
appropriate since they regulate
circumstances sufficiently
similar to those at the site.
MAC R299.9602-9604;
R299.9611-9613;R299.9619-9622
Requirements are applicable
because HWMA waste (chemical
precipitation sludge) would be
placed in a capped landfill.
MAC R299.9301-R299.9311
Hazardous waste generator
requirements would be applicable
for all wastes transported
off-site (chemical precip.
sludge).
MftC R299.9404-R299.9412
Transporter requirements are
applicable for all wastes
transported off-site (chemical
precip. sludge).
MAC R299.9618
Requirements are not applicable
since non-HWMA wastes (bio
treatment sludge) would be land
treated. Requirements are
relevant and appropriate since
they regulate circumstances
sufficiently similar to those at
the site.
AIR PdUJTICH ACT (A)
APA - ACT 348
Rules containing
emissions
limitations and
prohibitions
for particulate
matter, fugitive
dust, and VOCs.
Not an ARAR
MAC R336.1702;R336.1901;
R336.1371-1373
Requirements are applicable since
emissions from the treatment
system would be subject to State
standards for VOCs. Construction
activities are potential sources
of fugitive dust.
-------
•Table 3 - Page Five
NO ACTICN
TREKCHERT ALTERNATIVE
SOIL HUSXGN STOIMBflMnCN C1MIMUL ACT (A)
SESCA - ACT 347
Regulations
prescribing the
requirements for
soil erosion
and sedimentation
control measures
and procedures.
Not an ARAR
MAC R323.1701-R323.1714
Requirements are applicable since
traction would involve earth
changes and the potential for.
soil erosion.
FROST LAWS (A and L)
MCLA - 257.722
Rules governing
the reduction of
maximum axle loads
during the period
March - May.
Not an ARAR
Section 257.722
Requirement is applicable since
wastes (chemical precipitation
and bio treatment sludges) could
be transported from the site
during the period March - May.
SAFE DRINKING WOSR ACT (C)
SDWA. - Act 399
Regulations
establishing
MCLs for certain
contaminants in
addition to the
Federal MCLs.
MAC R325.10601-
R325.10607
Requirements are not
applicable since the
aquifer underlying
the site is not used
to supply a cuaumnity
or non—community
water system.
Requirement is
relevant and
appropriate since it
regulates
circumstances
sufficiently similar
to those at the site.
MAC R325.10601-R325.10607
Requirements are not applicable
since the aquifer underlying the
site is not used to supply a
community or non-conmunity water
system. Requirement is relevant
and appropriate since it
regulates circumstances
sufficiently similar to those at
at the site.
-------
Table 3 - Page Six
MICUL
MWRCA - ACT 245
This statute and
rules protect
groundwater
resources from
injurious
substances. Rules
contain State
water quality
standards,
Lrtjdonent p-Lant
operator
requirements, and
wastewater
reporting
requirements. The
rules also
implement a waste
effluent discharge
system compatible
with NPDES and
provide for the
groundwater.
HI
WSSA - ACT 98
Rules for
classification of
sewage or waste
treatment plant
operators. Rules
also contain
procedures for
construction and
operation and
maintenance of
treatment plants.
MINERAL WELL ACT
ACT 315
Rules describing
the permitting
requirements for
drilling brine,
storage, disposal,
and test wells.
ML) ACTICM AUUOMAHlVli
5W HA'IWt RKIXXJK.3&Y
-------
•Bible 3 - Page 7
HO Acnxn
TKKA3MENT ALTCKNXITVE
NATURAL RIVERS ACT (L)
NATURAL RIVERS ACT
Promotes public
health and
prevents
ecological damage
due to the unwise
development within
the natural river
district.
Not an ARAR
Not an ARAR
INLAND LAKES AND
STREAMS ACT 346
Regulates all
activities below
the high water
mark on inland
lakes and streams.
Not an ARAR
Not an ARAR
WETLANDS
PROTECTION ACT 203
Provides for the
preservation,
management,
protection and use
of wetlands by
prohibiting
certain
activities
requiring permits
and imposing
penalties for
violations of the
Act.
Not an ARAR
Not an ARAR
ENDMJGTOED «HK;IHK ACT (L)
ENDANGERED SPECIES
ACT 203
•tales contain a
listing of the
fish, wildlife
and plant species
that have been
determined to be
endangered or
threatened.
Not an ARAR
MAC R299.1021-R299.1028
Requirements are applicable since
one threatened species, the Eastern
Sand Darter (Aimuucrypta pellucidal.
and one special concern species,
the Dwarf Hackberry (Celtis
rennifclia), have been reported to
occur on or near the site.
-------
Table 3 - Page 8
ID ACTION AUDESNXEIVE
TSEKOtOTf
BIVIRCNMEN1RL
ACT BULBS (C)
ENVIRONMENTAL
RESPONSE ACT RULES
Rules describe
cleanup criteria
for response
activities.
MAC R299.5601
R299.5727 Parts 6
and 7 of the Act 307
Rules provide that
remedial actions be
protective of public
health, safety, and
welfare and the
environment and
natural resources,
and the attainment
of cleanup standards
under Type A, B, or
C cleanup. Parts 6
and 7 are ARARs for
the remedial action.
MAC R299.5601 R299.5727 Parts 6 and
Parts 6 and 7 of the Act 307 Rules
provide that remedial actions be
protective of public health;, ..
safety, arid welfare and the
environment and natural resources,
and the attainment of cleanup
standards under Type A, B, or C
cleanup. Parts 6 and 7 are ARARs
for the remedial action.
KEY TO
SBCDLS
A = Denotes an Action Specific ARAR
C = Denotes a Chemical Specific ARAR
L = Denotes a Location Specific ARAR
-------
, . 29
The groundwater cleanup standards and soil cleanup.compliance
points chosen for this site (for all Action Alternatives) are
based on Section 121 of CERCLA and the NCP. The substantive
provisions of Michigan Act 307 Rules, Parts 6 and 7, are ARARs
consistent with the provisions under CERCLA Section
121(d)(2)(A)(ii), for the remedial action to be undertaken at the
Rasmussen site. The Act 307 Rules provide that remedial actions
shall be protective of public health, safety, welfare, the
environment and natural resources (R299.5601(1)). Criteria for
Types A, B, and C cleanups within the Act 307 Rules provide for
the derivation of cleanup standards and compliance points which
meet the protectiveness goals stated above. The U.S. EPA and the
State agree on the remedy and cleanup standards, since the
groundwater is currently used as a drinking water source, and is
contaminated, and the soils areas pose a continued current and
potential threat to the groundwater resource, if left
unremediated.
More detail with regard to compliance with ARARs is provided in
this ROD under "Statutory Determinations".
3. Long-term Effectiveness and Permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time, once cleanup goals have been
met.
Neither of the No Action Alternatives for the soils or the
groundwater would be effective long-term solutions to the
problems at the site, as they do not address existing or future
site risks. The groundwater treatment alternative would provide
the greatest reduction in the potential for exposure to
groundwater contaminants. This alternative is expected to reduce
contaminant concentrations to the cleanup levels. Estimates
indicate that long-term protection would be achieved in 5 to 15
years, as the treatment system would reduce the concentration of
contaminants over time.
Reintroduction of treated groundwater through the PDSLD/IW areas
of concern, by use of seepage basins, will flush the contaminants
in the PDSLD/IW soils into the groundwater plume, with subsequent
removal by ground water extraction and treatment system. This
closed-loop treatment system will provide the best long-term
protection of the alternatives considered.
Long term effectiveness would be slightly greater with the multi-
media cap than with the clay cap. Long-term management
requirements and the consequences of cap failure would be similar
for each of the four soils action alternatives. A multi-media
cap may require a more-involved maintenance program than the clay
cap and, therefore, presents greater uncertainty with regard to
cap failure.
-------
30
4. Reduction of Toxicitv. Mobility or Volume Through
refers to the ability of a remedy to meet the preference
stated in Section 121(b) of CERCLA, for remedies that
involve treatment to reduce permanently the toxicity,
mobility, or volume of hazardous substances and
contaminants.
The groundwater treatment alternative would nearly eliminate the
toxicity, mobility, and volume of contaminants in the site's
groundwater because of contaminant removal and destruction.
Heavy metal contaminants are precipitated from the process
stream, dewatered, stabilized, and disposed of off-site at a
permitted facility. The biological treatment process will remove
most of the volatile and semivolatile organic contaminants,
including ketones, which are less readily removed by air
stripping and carbon adsorption. The remaining organic
contaminants removed by carbon adsorption, and are destroyed
during the off-site reactivation of the carbon.
Contaminants washed through the soil by the seepage basins in
Alternative 7 would ultimately be reduced in toxicity, mobility,
and volume through treatment by removal in the extraction and
treatment system.
The No Action groundwater Alternative does not reduce toxicity,
mobility, or volume except for the removal of contamination by
natural biological processes over time.
None of the site-wide soils alternatives contributes to the
reduction in toxicity, mobility, or volume of contaminants as no
treatment is utilized in these alternatives.
5. Short-term Effectiveness addresses the ability of
alternatives to manage risks during the construction and
implementation phases, and reduce immediate risks posed by
the hazardous materials present.
During the design and construction of the selected alternative,
the short-term risks potentially posed to the community and
workers can be effectively eliminated through proper engineering
measures and protective equipment for workers. Alternatives 2
through 5 present similar short-term risks to workers and
community. The alternatives including further excavation pose
slightly higher risks from dust exposure during the excavation
activities. Remedial action objectives would be met after
construction of the Act 64 cap. Alternative 7 should effectively
address the short-term risks posed to the community and workers
by contaminated groundwater. Remedial action objectives would
begin to be met after start-up of the treatment system. Ongoing
monitoring of private wells in the community will be continued as
needed until groundwater cleanup is complete. This criteria does
not apply to the No Action Alternative.
-------
31
6. Implementabilitv is the technical 'and administrative
feasibility of a remedy, including the availability of goods
and services needed to implement the chosen solution.
t
Technical feasibility: The individual .technologies used in each
of the action alternatives are conventional and well documented.
Unusual features are not anticipated to be required for any of
the alternatives but will be resolved during the design phase, if
encountered. Potential future actions such as removal of
contaminated source materials or on-site treatment would be
possible under any of the alternatives. There are no differences
in the alternatives' ability to be monitored for effectiveness.
Administrative feasibility: Alternatives 2 through 5 and
Alternative 7 are more administratively feasible than the No
Action Alternatives 1 and 6, since they address the final
remedial action objectives of the site (to varying degrees).
Alternatives 2 through 5 require similar coordination between
Agencies and other potentially affected interests. The No Action
Alternative would require substantial ongoing review effort by
State and Federal Agencies.
Availability of services and materials: The technologies used
under each of the soils action alternatives are conventional and
similar. Alternative 7 does not require any obscure services.
7. Cost includes capital and operation and maintenance costs.
The costs of individual alternatives are detailed above. The No
Action Alternatives have no direct costs associated with them.
The alternatives with excavation are more costly than those*
without. Likewise, multi-media caps are more expensive thansthe.
single-media clay caps.
Since the groundwater purge and treat system is being considered
as an integral part of the treatment for a portion of the
contaminated soils areas, and for the treatment of existing
contaminated groundwater, savings are incurred by use of this
procedure. As stated previously, Alternative 7 costs roughly
$150,000 more with the use of a seepage basin rather than
reinjection wells. Alternative 4, without excavation, costs
roughly $144,500 less than Alternative 5, with excavation. The
multi-media cap costs $2 million more than the clay cap, and
cannot be economically justified based on the marginal
improvement in reducing water infiltration. The remedy afforded
by the combination of Alternatives 7 and 2 can be implemented at
little additional cost, while achieving removal and partial
destruction of soil contamination in the POSLD/IW area.
-------
32
8. Support Aaencv Acceptance indicates whether, based on its
review of the Feasibility Study and Proposed Plan, the
support agency concurs, opposes, or has no comment on the
preferred alternative.
i
The United States Environmental Protection Agency and the State
of Michigan agree upon the selected remedy.
•r •>
9. CPTIPninltY Acceptance is detailed in the attached
Responsiveness summary.
Specific comments received from area residents indicate that the
community supports the groundwater remediation program, but would
prefer to have the dump contents either incinerated or removed
from the site. The residents expressed a desire that a financial
vehicle be established to guarantee cap maintenance in
perpetuity. The Responsiveness Summary gives a detailed list of
concerns expressed in writing and verbally at the public meeting.
The PRPs generally support the site wide remedy but take issue
with the cap design details and criteria used to establish the
chemicals of concern and cleanup levels indicated in Table 1.
The PRPs also felt that the capital costs would be much greater
than the plus 50 percent upper bound called for in the National
Contingency Plan.
The Selected Remedy
The preferred alternative for the Rasmussen groundwater plume,
Alternative 7, includes the following process options:
* extraction of groundwater to capture and halt the flow- of
the-plumes.
* removal cf heavy metal contaminants by chemical
precipitation followed by pH adjustment (if necessary).
* removal of several organic contaminants, including fcetones,
by a biological treatment system.
* removal of residual organic contaminants via air stripping.
* further removal of residual organic contaminants via
granular activated carbon (GAC) (or other carbon adsorption
methodology, if necessary).
* discharge of treated water to the groundwater via a seepage
basin situated over the IW and PDSLD soils areas of concern.
* groundwater monitoring through a system of wells to assess
the effectiveness of the system at:
* halting the migration of contamination.
* reducing the levels of contamination in the soils
and groundwater, over time.
* a process effluent sampling program; to aid in determining
the treatment system's effectiveness.
* fencing and deed restrictions, as necessary, to ensure the
integrity of the remedy.
-------
33 . . .
Residential well sampling will be continued, in conjugation with
that called for in the final remedial actions at the ; -ighboring
Spiegelberg Superfund Site.
*
The final processes to be installed for groundwater .eanup will
be determined by treatability studies during the de gn.
Since contamination has been confirmed in the location of
groundwater monitoring well RA-MW-27, groundwater will need*to be.
purged from this location and will need to be manifolded into the
treatment system feed supply line for treatment prior to
discharge.
The preferred site-wide alternative for the Rasmussen soils areas
of concern is Alternative 2, which includes:
* A Michigan Act 64 clay cap constructed over all wastes in
the TML and NEED areas of concern as they now exist
spatially on-site. This includes:
* a one-foot thick vegetated soil layer on top,
* a drainage layer at least 1 foot thick, and
* a layer of compacted clay 3 feet thick with a
permeability of 1E-07 cm/sec or less.
* A groundwater monitoring program established at appropriate
locations, depths, and frequency, to detect any changes in
groundwater quality, which would indicate any failure of the
unit.
* Access restrictions, such as fencing, will be placed around
the capped soil areas.
* Institutional controls, such as deed restrictions, will be
put in place to prevent future intrusive land uses.
* Drums of waste which are currently visible, or which are
unearthed during cap implementation, will be disposed- of at
a licensed RCRA facility.
This portion of the final remedial action will require long-term
management to ensure that the integrity of the capping system is
not compromised. The access restrictions and fencing will aid in
this effort. Long-term management efforts will include periodic
well sampling, cap inspection and repair (if necessary), and
maintenance of vegetative cover.
Details of the capping construction such as the potei. ial
employment of terracing, rip-rapped drainage channels and
perimeter runoff collection will be detailed during the design
phase of remedial action.
Actual or threatened releases of hazardous substances from this
site, if not addressed by the preferred alternative or one-of
other active measures considered, may present a current or
potential threat to public health, welfare, or the environment.
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1. Attainment of Goals
Both MDNR and EPA have determined that the remedy selected
provides the best balance among the nine criteria and meets the
requirements of CERCLA.
Attainment of the groundwater goals of this remedy is dependant
on the meeting of the cleanup levels for groundwater specified in
Table 1. When realized, the groundwater remediation will reduce
risk to levels consistent with applicable, or relevant andi
appropriate Federal and State requirements, and thus will be
protective of human health and the environment.
Completion of the soil flushing portion of this remedy is
measured against the reduction of contaminants in the PDSLD/IW
soils areas of concern to levels which will not produce leaching
of contaminants to groundwater at levels above groundwater
cleanup standards (Table 1). Once this cleanup objective has
been met, a Type B cleanup level for the PDSLD/IW soils will have
been achieved (R299.5711(2)). The compliance point for measuring
PDSLD/IW cleanup is described in the next section.
Completion of the capping/monitoring system for the NEBD/TML dump
area is the point where the remediation goals for these areas
begin to be met. Continued operation and maintenance of the
capped areas will ensure the continued attainment of these goals.
2. Compliance Points
Compliance points to be measured during the course of the
groundwater remediation, to determine the progress towards and
attainment of protective groundwater levels, are: analysis of
the treatment system effluent to directly determine the
effectiveness of the treatment and to prevent the re-release-of
inadequately treated chemicals to the environment; and,
monitoring well analysis to determine the effectiveness of the
treatment system at halting the flow of contaminated groundwater,
and to monitor changes in the contaminant concentrations within
the plume itself. Residential well monitoring in the direction
of groundwater flow will be continued to ensure that these
resources remain unaffected. Specifically, the area of
attainment to be monitored for the completion of the Rasmussen
groundwater contamination remediation extends throughout the
plune in the upper aquifer in the area underlying the Rasmussen
site. Groundwater cleanup will be measured against those levels
listed in Table 1.
The risk posed by the PDSLD/IW areas of concern, as previously
noted, is the risk posed by the migration of contamination into
the groundwater resource. The objective of the soil flushing
portion of the remedy is to eliminate the leaching of
contaminants to the groundwater. In order to determine
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compliance with this objective, the contaminant level in the
PDSLD/IW soils roust be reduced to less 'than twenty times the
groundwater cleanup level for each chemical, or leach tests
performed on the PDSLO/IW soils must produce leachate with
contaminant levels below the groundwater cleanup levels
(R299.5711(2)), or the results of other test methods (other than
TCLP) that accurately simulate conditions at the site must be
employed to demonstrate that contaminants are not leaching into
the groundwater above the groundwater cleanup levels.
Measurements of cap effectiveness will be conducted through the
use of a monitoring well system installed in conjunction with cap
construction.
3. Contingencies
Some changes may be made to the remedy as a result of the design
studies. However, the cleanup goals must be met by the remedy
that is implemented. The following are some of the outstanding
issues which will be resolved during negotiations, remedial
design, and final remedial action: general system design; site
access; maintenance and monitoring; residential well sampling
plan; monitoring well placement and sampling frequency;
oversight; future Potentially Responsible Party involvement; am
determination of background lead and cadmium concentrations.
Statutory Determinations
The selected remedy will control and reduce risks associated with
the Chemicals of Concern in the Rasmussen groundwater plume and
PDSLD/IW areas of concern. Engineering controls (cap) in
conjunction with long-term maintenance and institutional controls
will provide adequate protection of human health and the
environment from the dump and inclusive areas of concern. The
statutory requirements of CERCLA Section 121 will be satisfied to
the extent practicable with the implementation of the chosen
remedy. The following is an enumeration of how the selected
remedy addresses each requirement.
1. Protection of Human Health and the Environment
The selected remedy will provide adequate protection of human
health and the environment through the combined use of treatment,
engineering and institutional control technologies. Risks
associated with contact or consumption of site groundwater will
decrease over time because the extraction and treatment system
will reduce the concentration of all contaminants to the cleanup
levels specified in Table 1. Risk reduction will also be
realized upon completion of the flushing and capping portions o"
the remedy. At completion of this remedy, the carcinogenic ris.
will be reduced to levels considered protective by the Michigan
Act 307 Rules criteria, and well within the EPA's 1E-04 to 1E-06
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range. Carcinogenic risk associated with the Rasmussen site's
groundwater is currently 7.3E-03. The implementation of the
treatment system and the attainment of the required cleanup
levels would reduce the carcinogenic risk to 9.2E-05. Non-
carcinogenic risk will be reduced to levels acceptable to MDNR
and U.S. EPA and consistent with CERCLA. Flushing and extraction
will ultimately reduce the PDSLD/IW soil contamination levels to
that which will not leach into groundwater at levels above
groundwater cleanup standards (R299.5711(2)). The site-specific
capping remedy for the remaining soils areas will afford aquifer
protection from the effects of residual soil contamination. With
proper engineering controls, unacceptable short-term risks will
be not be caused by the implementation of this remedy.
2. Compliance with Applicable or Relevant and Appropriate
Requirements
The remedy selected will meet or attain the applicable or
relevant and appropriate Federal and State requirements, and will
be implemented in a manner consistent with these laws. Tables 2
and 3 list all of the Applicable or Relevant and Appropriate
Requirements (ARARs), and indicate why each is an ARAR for the
selection or implementation of the chosen Rasmussen site final
remedial action.
In particular, the final remedial action selected for
implementation at the Rasmussen site is consistent with the
National Contingency Plan and the State's Act 307 Rules. The
State has identified Michigan Act 245 Part 22 Rules as an ARAR
for the Rasmussen site. The United States disagrees that
Michigan Act 245 Part 22 Rules, as interpreted and applied by the
State, is an ARAR. This issue is the subject of litigation in
U.S. v. Akzo Coatings of America, appellate case numbers 89—2902
and 89-2137. The State agrees with the remedy selected and has
indicated that achieving the Act 307 groundwater cleanup
requirements in treated groundwater prior to reintroducing it
into the aquifer will satisfy the requirements of Act 245.
The groundwater cleanup standards and soil cleanup compliance
points chosen for this site are based on U.S. EPA's agreement
with the State's recommendation of a combination of all three
Types of cleanup for this site. Criteria for complying with the
Type A, B, or C cleanups are contained in Michigan's Act 307
Rules. The substantive provisions, Parts 6 and 7 of the Act 307
Rules, are considered ARARs for the remedial action to be
undertaken at the Rasmussen site. These Rules provide, inter
alia, that remedial actions shall be protective of public
health, safety, and welfare and the environment and natural
resources (R299.5601(1)). The Act 307 Rules specify that this
standard be achieved by a degree of cleanup which conforms to one
or more of the Type A, B, or C cleanup criteria. A Type A
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cleanup generally achieves cleanup to background or non-
detectable levels (R299.5707); a Type B meets risk-based cleanup
levels in all media (R299.5709, 5711, 5723, and 5725); and Type C
cleanup is based on a site-specific risk assessment which
considers specified criteria (R299.5717 and 5719). The selected
remedy meets this ARAR.
U.S. EPA agrees with the State's recommendation given the- fact
that the groundwater is currently used as a drinking water source
and is contaminated, and that the soils-areas, pose a confetaoing*
current and potential threat to the groundwater resource, if left
unremediated.
The emission control requirements of the Clean Air Act (CAA) and
the Michigan Air Pollution Control Act are potential ARARs for
all alternatives except the No Action Alternative. Construction
and treatment system activities are potential sources of fugitive
dust, participates and volatile organic compounds.
The selected remedy may involve the disposal of treatment
residuals which are subject to RCRA Land Disposal Restrictions
(LDRs). Although RCRA listed wastes have not been found at the
site, some RCRA characteristic wastes were removed from the site
during the 1989/1990 removal action. Consequently, treatment
residuals will be tested to determine if they are RCRA
characteristic wastes and subject to the LDRs. If treatment
residuals are determined to be hazardous wastes under RCRA, and
are transported off-site, the Department of Transportation Rules
for the transportation of hazardous materials and RCRA will be
applicable to any off-site movement or handling of the hazardous
wastes.
Post Section 106 removal observations by EPA's oversight
contractor and State staff have indicated that visible drums
remain within the areas to be capped. These drums have become
visible due to the freeze/thaw weathering cycle which causes
slumping of dump and soil materials. The drums removed during
the 1989/1990 action were found to contain RCRA characteristic
wastes. Due to the fact that wastes removed were RCRA
characteristic, and the fact that some drummed materials still
remain, the probability exists for RCRA characteristic wastes and
residuals to still remain within the TML/NEBD portion of the
site. Based on these findings, both RCRA and Michigan Act 64
capping requirements were determined to be relevant and
appropriate for closure of these areas.
3. Cost Effectiveness
The comparison of cost effectiveness versus protectiveness.
achieved is the primary factor for the selection of the
combination of preferred alternatives for the Rasmussen site.
Public comment for this site centered around the public's
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expressed preference for complete removal and destruction of all
contaminated soils areas including the 'dump rather than the
proposed in-place site-specific remedy. It is also the Agencies
statutorily mandated preference for technologies which employ
permanent solutions and treatment technologies. The mandate is
qualified by the phrase "to the Maximum Extent Practicable."
Included in this qualifier is a requirement to balance cost with
the effectiveness of a remedy at protecting public health and the
environment. Removal and destruction of the dump contents would
cost over $100 million. The proposed soils alternatives
(including flushing) will cost approximately $10 million. The
selected remedy outlined above affords overall effectiveness when
measured against the 5 CERCLA Section 121 criteria and the 9
criteria from the National Contingency Plan, and costs are
proportionate to the protectiveness which will be achieved.
4 . Utilization of Permanent Solutions and Alternative Treatment
(or resource recovery) Technologies to the Mqyimmi Extent
Practicable
The remedy employs the preferred permanent solutions and
treatment technologies to the maximum extent practicable. The
chosen alternative permanently removes the contaminants from the
groundwater resource and flushed soils in the following manner:
organic contaminants are extracted via air stripping and carbon
adsorption, and are destroyed during the off -site reactivation of
the carbon units; the activated sludge process removes and
destroys most of the volatile and semi-volatile organic
contaminants; and inorganic contaminants are precipitated from
the process stream, dewatered, stabilized, and disposed of off-
site at a permitted facility. The capping option does not employ
permanent solutions or alternative treatment technologies.
5. Preference for Treatment as a Principal Element
The principal elements of the selected remedy are the treatment
of the contaminated groundwater and flushed soil contaminants,
and capping. These elements address the unacceptable risks at
the site— the further degradation of groundwater resources,
through the combined use of treatment and engineering
technologies. Addressing all of the risks through treatment was
not found to be cost effective. The chosen remedy, although not
wholly a treatment process, is protective of public health and
the environment.
Significant Changes
The following is a documentation and rationale for significant
changes made to the selected remedy since the issuance of the
Proposed Plan in August of 1990. None of these changes require
the issuance of a revised Proposed Plan or the announcement of a
new Public Comment Period, as the remedy does not differ
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substantively from that which was contemplated in the final
stages of the Feasibility Study or the 'Proposed Plan.
There are two changes in the cleanup levels on Table 1 due to
typographical errors in the Proposed Plan. For 1,1-
dichloroethene the maximum concentration is 2.0 ppb instead^of
590.0 ppb as indicated in the Proposed: Plan. This reduces the
carcinogenic risk number for 1,1-dichloroethene from l.OE-02 to
3.4E-05.
'•• •«•-••• - • • £ 3-S '
Careful re-examination of RI results in response to PRP and*
public comment has shown levels of trichloroethene on three
separate sampling occasions during the RI (240 ppb, 774 ppb, and
120 ppb) in Rasmussen Monitoring Well number 27 (RA-MW-27)
(Figure 2). These results were inadvertently overlooked during
the risk evaluation since they were recorded as "background"
sample locations. Sampling conducted by the PRPs on two*
subsequent sampling occasions confirmed trichloroethene in RA-MW-
27. The PRPs propose to remediate this area by the installation
of a separate purge well in this location. The Agencies concur
with this proposal, and add that the purged water from the
southerly RA-MW-27 extraction well location will be manifolded
into the treatment system feed header for treatment prior to
discharge. Cleanup levels for groundwater contamination in this
area are the same as found in Table 1.
Benzyl alcohol was noted in Table 1 of the Proposed Plan as
requiring cleanup. The cleanup level for this chemical, based on
Type B criterion was incorrectly calculated and reported as 9.0
ppb. The correct cleanup number based on these criterion is 10.0
ppm (10,000 ppb) based on data from the National Toxicology
Program bioassay (1989). The site-derived concentrations*of 12.0
ppb do.not exceed the corrected cleanup*level. Benzyl alcohol
has been removed from the list of chemicals of concern fOr^the-
Rasmussen groundwater plume.
The chemical 2-chlorophenol, has a cleanup level 0.1 ppb" based on
aesthetics data. However, consideration was not given for
detectability. An acceptable method detection limit (MDL) for
this chemical is 5.0 ppb. This MDL of 5.0 ppb is the cleanup
goal. However, since the aesthetics criterion is significantly
less than the MDL, the design should attempt to cc ole ly remove
2-chlorophenol from the groundwater.
Since the issuance of the Proposed Plan for the Rasj ss site,
new RfD data became available in the IRIS database f.r 1.4—
dimethylphenol. Based on this data, the new groundv ter cleanup
criterion for. 2,4-dimethylphenol is 100 ppb. The maximum
concentration detected in Rasmussen groundwater was 27.0 ppb.
Therefore 2,4-dimethylphenol is deleted as a chemical of concer
for the Rasmussen groundwater remediation.
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Reevaluation of the aesthetics data for 2-methylphenol and 4-
methylphenol have produced the following respective cleanup
levels: 300 ppb and 400 ppb. Since 2-methylphenol was detected
at 1,600 ppb, it remains as a chemical of concern with a revised
cleanup level of 300 ppb. Since 4-methylphenol was detected on-
site at 280 ppb and the cleanup level is set at 400 ppb, this
chemical is deleted from the list of groundwater contaminants.
In the Proposed Plan the cleanup level for vinyl chloride was set
at 0.18 ppb based on a MDL. The MDNR has recently issued a
memorandum which lists MDLs for use with the Act 307 criteria.
The memorandum lists the MDL for vinyl chloride at 1.0 ppb,
therefore the cleanup number reported in Table 1 has changed to
1.0 ppb. Since the carcinogenic risk level for vinyl chloride is
below what can be reliably detected, efforts should be made to
detect the substance at levels below 1.0 ppb, and to remediate to
those levels, if possible.
Tetrachloroethene was incorrectly reported as a detection of 2.0
ppb on-site. This detection was determined to be unreliable as
both on-site and background samples were estimated values of 2.0
ppb. Tetrachloroethene was not reported in any other samplings
and is deleted from consideration as a chemical of concern.
Cadmium, as with lead, requires resampling during pre-design
studies to confirm its presence as a dissolved contaminant. RI
samples were analyzed for total cadmium. The cleanup level in
Table 1 has been starred to indicate that the HLSC-based cleanup
level of 4.0 ppb may be modified by further analyses.
If studies (and split samplings) show that either 1) on-site
filtered cadmium samples are less than 4 ppb, or 2) if on-site
filtered cadmium samples are greater than 4 ppb, and on site
filtered cadmium samples are less than background filtered
cadmium samples, then cadmium may be deleted from the list of
chemicals of concern.
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RESPONSIVENESS SUMMARY
RASMUSSEN SUPERFUND SITE
GREEN OAK TOWNSHIP, LIVINGSTON COUNTY, MICHIGAN
CONTEXT
This Responsiveness Summary has been prepared to meet the
requirements of Sections 113(k)(2)(B)(iv) and 117(b) of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), which require the United
States Environmental Protection Agency (U.S.EPA) to respond
11. . .to each of the significant comments, criticisms, and new
data submitted in written or oral presentations. . ." on a
Proposed Plan for Remedial Action.
As noted, public participation in Superfund projects is required
by SARA. Comments received from the public are considered in the
selection of the remedial action for the site. The
Responsiveness Summary serves two purposes: to provide the U.S.
EPA with information about the community preferences and
concerns regarding the remedial alternatives, and to show members
of the community how their comments were incorporated into the
decision-making process.
SITE OVERVIEW
The Rasmussen site is located on Spicer Road in Green Oak
Township, Livingston County Michigan. The adjacent property to
the west is another Superfund site known as the Spiegelberg Site.
Due to the close proximity, the two sites were investigated as
part of one Remedial Investigation, and cleanup alternatives
were evaluated through one Feasibility Study Report. However,
the sites differ in method of disposal of waste materials. Some
waste types overlap between the two sites, as do some of the
Potentially Responsible Parties (PRPs). Community relations
activities for the two Superfund sites have, for the most part,
been combined. Activities for the two sites have become more
divergent since approximately 1988, when separate removal and
investigative activities were started, and work began to progress
at differing rates.
The preferred alternative for the contaminated groundwater and
soils at the Rasmussen Site is: the combined use of an
extraction/treatment/seepage basin reintroduction system for the
treatment of groundwater and flushed soil contaminants, with a
capping alternative for the remaining soils areas.
The written and oral comments received from the citizenry and the
Livingston County Health Department were in favor of the
groundwater remedy chosen. The local citizens expressed a strong
desire for the removal of all waste materials, rather than the
proposed capping alternative.
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In general, comments received from the PRPs supported the
proposal for groundwater remediation and capping of the dump
wastes. The PRPs' criticisms of the proposed alternatives
centered around the application of State ARARs, the selection
criteria for chemicals of concern and the calculations of
corresponding cleanup levels, the contents of the Administrative
Record and the proposed capping design.
BACKGROUND ON COMMUNITY INVOLVEMENT
History
A detailed chronology of community relations activities for the
Rasmussen site is attached to this Responsiveness Summary.
Concerns
The Community Relations Plan for the Rasmussen (and Spiegelberg)
Superfund Site(s) was completed on October 25, 1984. At that
time, key concerns identified were:
* Potential for residential well contamination.
* Lowered property values.
* Potential health hazards.
* Lack of response to citizen concerns.
Other concerns are:
* Off-site airborne releases of contaminants.
* Long-term accountability and maintenance for any
in-place remedy chosen.
Effects and Outcomes of Concerns
As a result of the work done on this site over the past five
years, some of the key concerns highlighted above were addressed.
* Past sampling rounds have consistently revealed that
residential wells are uncontaminated.
* Prices for properties which have recently sold in the area
are comparable to prices for similar properties at other
locations in the township, according to township officials.
The township official did note that since lending companies
are aware of the presence of the site, mortgages are
difficult to obtain, and the area is not being built up as
quickly as it might have in the absence of the site.
* Air monitoring throughout the work zone, and at the site
perimeter during the removal actions (peak disturbance),
showed that no air releases were measured off-site.
* Adverse health risks have been identified at the site.
However, this has not resulted in any reported adverse
health effects being experienced by local residents. This
will be an ongoing evaluation. During and after the
implementation of the remedial action, no adverse health
effects from the site are expected.
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* The Attachment to this document shows a rich history of
community involvement throughout the duration of this
project, largely through the efforts of the citizens and the
Livingston County Health Department, in organizing citizen's
groups and staying involved. The concern expressed most
frequently now is that cleanup should proceed more quickly.
SUMMARY OF PUBLIC COMMENTS AND RESPONSES
Comments and questions were received and recorded during a Public
Meeting held at the Green Oak Township Hall on September 13 ,
1990, from 7:40 p.m. to 9:15 p.m. Written comments were also
received throughout the Public Comment Period from August 31,
1990 through October 31, 1990. The transcript of the oral
comments received at the public meeting and the written comments
received during the public comment period are in the
Administrative Record for this site. Following is the response
to these public comments regarding the Site's Proposed Plan
released in August of 1990.
Received at the Public Meeting
The following comments were received and recorded in the
transcript of the public meeting. MDNR and U.S. EPA
representatives addressed the following questions during the
proceedings (see transcript in the Administrative Record) . The
following answers are presented for further clarification.
Comments have been arranged into 7 categories.
1. General Questions and Comments
Is the Rasmussen site a worse problem than the Spieqelberg site?
The Rasmussen site had a wider variety of wastes (mostly drummed)
disposed of on site, and these wastes were spread around over a
larger area. Based on these factors, the Rasmussen site could be
thought of as "worse". The Spiegelberg site, on the other hand,
had a large volume of uncontainerized liquid paint waste poured
into a soil excavation. From a mobility standpoint, the
Spiegelberg paint waste posed a greater problem.
In any event, most of the Rasmussen drummed wastes and all of the
Spiegelberg concentrated wastes have been removed. However, the
hazardous substances remaining at both sites pose a potential
threat to public healtn and the environment, if left
unremediated .
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2. Past Investigations
Which areas of concern were found to be contributing to
aroundwater contamination at the Rasmussen site?
The groundwater plume at the Rasmussen site originates from the
Probable Drum Storage, Leakage, Disposal Area (PDSLD) and
Industrial Waste (IW) areas of concern. To date, no groundwater
contamination has been detected as coming from the Northeast
Buried Drum Area (NEED) or Top of Municipal Landfill (TML) dump
areas, although the contamination in these areas presents a
potential threat to groundwater. Another plume area has been
identified as requiring remediation. It is localized in the area
of RA-MW-27 where drummed wastes collected after being poured out
over the southwest side of the landfill. Please refer to the
second question below for a more detailed description of this
groundwater contamination.
Are there wells and past samplings in close enough proximity, and
screened at the proper depths to detect potential groundwater
contamination from the NEED or TML dump areas?
There are several wells placed closely around these areas of
concern which are screened at varying depths, and which would
detect groundwater contamination, if present.
The neighboring property owner stated that he observed the
dumping of waste over the back side of the hill at the Rasmussen
site. He found it hard to believe that there was no groundwater
contamination associated with the dump. Other commentors asked
follow-up questions as to the testing done around this area.
The Agencies are aware that this dumping occurred, and focused a
large amount of effort toward investigating the results of the
dumping. Some effects of the dumping were more obvious—over
3,000 drums and a pool of black liquid were removed from the top
and south side of the dump in 1984. Careful re-examination of RI
results in response to this comment (and based on further PRP
sampling), have shown levels of trichloroethene on three separate
sampling occasions during the RI (240 ppb, 774 ppb, and 120 ppb)
in Rasmussen Monitoring Well number 27 (RA-MW-27) in this exact
location (Figure 5-6B in the RI). These results were
inadvertently never carried through to the later stages of risk
evaluation.
Sampling conducted by the PRPs on two subsequent sampling
occasions showed trichloroethene in RA-MW-27. The PRPs propose
to clean this area by the installation of a separate purge well
in this location. The Agencies concur with this proposal, and
add that the purged water from the southerly RA-MW-27 location
will need to be manifolded into the influent end of the treatment
system for the northerly plume, for combined treatment prior to
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discharge. Note that more detail is given in the attached ROD
under "Documentation of Significant Changes". This topic is also
addressed further on with respect to the corresponding PRP
comment.
How deep is the deepest well at the Rasmussen site?
Rasmussen Well Number 42 (RA-MW-42) was advanced to a depth of
between 190 and 200 feet below grade. It is terminated in a clay
layer and monitors the groundwater in the 163 foot to 167 foot
interval above the clay. This well was surveyed at approximately
933 feet above mean sea level.
How far south did your testing go?
Surface water sampling went as far south as the peat pond. Soils
sampling went to the southern limits of the neighboring
Spiegelberg property. Shallow groundwater monitoring also went
to the limits of the neighboring property, and business wells to
the south were tested as well.
Are there PCBs and dioxins in the PDSLD Area? Are there dioxins
in the IW area?
In the most recent continuous core sampling of this area, the
maximum level of PCBs detected in surface soils in the PDSLD area
was just over 1.0 ppm (A State representative incorrectly stated
"one part per billion" at the 9/13/90 public meeting), the
current State required cleanup level for PCBs. Past samplings
have shown no dioxins in the PDSLD or the IW areas.
One commentor asked to be shown the extent of the Agencies7
investigations.
An MDNR representative pointed out several sampling locations
based on the Remedial Investigation maps, and provided the
commentor with copies of the Remedial Investigation Report.
What were the levels (actual and not average) of dioxins found
across the site, and what risks are posed by these levels?
The maximum level found (2.996 ppb TCDD equivalencies) at the
site was in a southwesterly soils area on the top of the
landfill. Other maximum levels were as follows: Area of
Reported Burning (western-central TML) = 0.349 ppb
equivalencies; central TML = 0.024 ppb equivalencies; and NEED =
0.061 ppb equivalencies. TCDD is short for 2,3,7,8-
tetrachlorodibenzodioxin, and is considered one of the most toxic
forms of dioxin. If different forms of dioxin are found, certain
conversion factors are used to express all in terms of TCDD
equivalencies.
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Toxicological studies (Kimbrough, 1984) state that residential
soils at levels above l ppb TCDD pose a level of concern. The
soils at the Rasmussen TML do not constitute a residential
setting, nor do they contain purely the TCDD form of dioxin. The
Rasmussen soils containing low-level dioxins do not pose an
unacceptable risk to residents living in the vicinity of the
Rasmussen site. The presence of dioxin lends support to the
decision to cap the TML and NEED soil areas, but would not have
in itself forced this decision.
3. Monitoring of Remedial Actions
Will outside labs be used for testing, to obtain independent
verification of monitoring data and to obtain better turn-around
times than in the past?
Independent labs will most likely be used when State laboratories
are backlogged. If PRPs perform the remedial actions, either the
State or Federal oversight personnel will obtain split samples
for independent verification.
Citizens requested that the residential wells surrounding the
entire site be tested quarterly in perpetuity, for all of the
contaminants present at the site. They recfuested that
residential well testing be continued for as long as there is
material present at the site. Additionally, citizens requested
that all of the sampling data be provided to the households and
businesses around the site.
As stated previously, and acknowledged by the commentor, the
Agencies' preference is to rely on monitoring of wells in between
the contaminated area and residential wells, to detect
contaminant migration prior to any impact on drinking water
supplies. Plans include monitoring of these intermediate wells
on a quarterly basis, once remediation begins, and for as long as
waste remains on-site as per CERCLA Section 121(c), 42 U.S.C.
Section 9621(c). Some residential well monitoring will be
continued as well, with prime focus in the direction of
groundwater flow. All monitoring results will be made available
to the owners of homes tested, and in general, summaries of all
site related monitoring will be provided as part of the periodic
updates to the local information repository.
A representative from the Livingston County Health Department
asked what plans we had for residential well monitoring in the
near future. He requested that LCHD be provided with all data.
as the LCHD is a focal point for residential well concerns, and
offered assistance if requested.
A State contract is being prepared for residential well
monitoring services so that these activities will commence
shortly and be continued for as long as is necessary. We will
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provide all data to the LCHD and gratefully acknowledge their
offer of assistance.
Will the soils to be flushed be monitored for effective clean-up?
Monitoring throughout the unsaturated soil zone will be conducted
as part of the compliance testing for the PDSLD/IW areas flushing
system.
4. Completion of Remedial Actions
When is the groundwater cleanup expected to be complete? When
can the public expect to receive a letter saying that the
aroundwater remediation is complete and safe?
Groundwater cleanup can be expected to take between 5 to 15
years. When remediation goals have been attained, The Agencies
will inform the public of this. Residential water supplies
currently in existence are safe to drink now. When initiated,
the groundwater remediation system will halt the flow of
contaminants and remove them from the environment. This will
insure continued safety of the groundwater resource.
Can the PDSLD/IW soils be removed, or do dioxin disposal
restrictions prohibit this option?
Dioxin disposal restrictions would not prohibit the removal of
these two soil areas of concern, as neither contain this
chemical. Soil flushing is the preferred alternative for the
PDSLD/IW because the soils contamination in this area has been
shown to lie just above the groundwater table. Removal would
require the excavation of a large amount of relatively
uncontaminated soil to get at the soils of concern. These soils
might then have to be treated for risk reduction prior to
disposal (a costly option, with or without soils treatment).
Flushing avoids this unnecessary disturbance (and subsequent
backfilling), utilizes the treated water to enhance contaminant
uptake, achieves the objective of risk reduction through ultimate
treatment, and provides a secondary benefit for water which would
otherwise have to be reintroduced to the ground, all for a
comparatively small added cost. The third question and answer
after this one offers more detail as to this comparison of
alternatives.
Citizens expressed their discomfort and displeasure with the
Agencies7 preference for on-site containment of soil
contamination. Reasons expressed were;
- money was being spent to make these materials more
permanent in their current location rather than taking
them away and doing something with them.
off-site incineration could be an option for dealing
with the dioxin-containinq wastes.
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- uncertainties exist with regard to the durability of
the proposed cap.
the desire to eventually have a completely clean site.
without the need for perpetual- maintenance.
uncertainties with regard to the continuance of PRP
Operation and Maintenance (O & M) funding to insure cap
integrity.
uncertainties with regard to the continuance of Agency
0 & M funding due to changing political climate, and
- cost comparisons should not be the overriding factor
for choosing an in-place remedy where potentially.
public health is a concern.
In-place remedies (capping) for wastes, are not categorically
preferred by the Agencies for site remediation. In selecting the
remedy for the Rasmussen dump wastes, the Agencies considered a
number of factors including cost, implementability, overall
protectiveness, compliance with State and Federal applicable or
relevant and appropriate requirements (ARARs), and short- and
long-term effectiveness. The two primary considerations in
remedy selection are overall protectiveness and compliance with
ARARs. Only after these two criteria have been evaluated, are
costs (and the other criteria) brought into consideration between
remedies which offer equal protectiveness and compliance with
ARARs. Such is the case with remedy selection for this site.
Evaluation showed that both removal and on-site remedies fared
equally with regard to ARARs, and both were found to be
protective of public health and the environment. The Agencies
feel that when implemented and maintained, an in-place capping
remedy will reduce the potential risk to public health and the
environment from contaminant migration to groundwater (the
potential risk here). Human health, therefore is a concern, and
costs only becomes a major distinguishing factor, as it did here,
after the determination regarding protectiveness and risk
reduction had been made.
Statutory considerations aside, the Agencies can fully appreciate
the argument against capping—it seems illogical to make these
materials more permanent in this location rather than elsewhere.
It is also impractical to take all of the wastes from sites such
as this one (primarily municipal garbage), and cap it elsewhere.
These remove/not-to-remove considerations are made on a site-by-
site basis.
Off site incineration of dioxin-containing soils is not
prohibited by statute, but there are problems with locating a
facility currently accepting these materials. (The Times Beach,
Missouri dioxin site cleanup plan calls for construction of an
on-site incinerator to take care of its contaminated soils).
Cap durability is a direct function of correct design and long-
term 0 & M.
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Portions of this question pertaining to financial assurances,
design, O & M, and cap durability have been addressed under
sections 5, 6 and 7 below.
Mr. Tom Haua. the chairperson of the Citizen/s Information
Committee (CIO expressed the following; The citizens7
preference would be for the complete removal and incineration of
all of the Rasmussen soil contamination and the dump. However.
he did not express much hope for that to happen, and did want to
emphasize that the chosen capping remedy should be monitored.
since the proposed plan failed to detail this requirement. Will
the monitoring system completely ring the capped area?
The complete removal option was explored in the Feasibility Study
and was found not to be cost effective when balanced with the
factor of risk reduction. Risks are significantly reduced with
the capping alternative and can be monitored to insure the
perpetuation of this risk reduction.
The attached Record of Decision itemizes monitoring as a key
ingredient to the capping remedy chosen. There are specific
requirements in Michigan Act 64 which address the monitoring
requirements for capped landfills. The requirements include a
system which will monitor the entire capped area. These
monitoring requirements will be addressed in the scope of work
for the implementation of the chosen remedy.
On Page 13 of the Proposed Plan it states that "excavation and
relocation of the remaining PDSLD soils is not a process option.
in light of the fact that the majority of the contaminants are
located just above the qroundwater table." Why is this not an
option? It seems odd to introduce more contamination to the
qroundwater. only to extract it later.
The sentence would have more appropriately read: "Based on
investigations as well as technical and cost factors, the
remedies which included excavation of soils were eliminated from
further consideration." The 1989/1990 soils investigations in
the PDSLD area determined that the contamination was largely
located near the groundwater table. This soil contamination is
located there due to a combination of the leaching of
contaminants down through the soil column, volatilization from
the groundwater, and wetting of the soils through seasonal water
table fluctuations. These mechanisms (particularly the last two)
would continue to occur even if soils are excavated and
backfilled, causing reintroduction to the soils of any
contaminants still in the groundwater. Technically, it will be
more effective to leave the PDSLD/IW soils in place and enhance
the natural flushing mechanisms. Mechanically, a purge and re-
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10
introduction system is already required to address the
groundwater contamination, and cost-effectiveness is gained
through the secondary benefit of soil flushing.
Admittedly, the concept of moving contaminants toward the
groundwater seems counter productive, however, soil flushing has
been demonstrated to be an effective remedial technology where
relatively homogenous soils are involved over small areas in a
closed-loop setting.
The Proposed Plan stated that deed restrictions would be placed
on the property to prevent "incompatible" future land uses. What
would be considered compatible?
The wording of this statement was perhaps misleading. With
wastes capped in place, and in light of the fact that cap
integrity must be maintained, there is no use of this property
that would be considered compatible.
5. Design and Engineering Concerns
In light of the fact that capping as a remedial alternative has
not been field-proven for more than 8 to 10 years, can we
estimate how long caps will last with proper 0 & M?
Caps are expected to last for at least 30 years with the
minimally required O & M. With advanced 0 & M, this estimate can
increase proportionally to the amount of re-working done. If
areas of the capping and monitoring system are found to be
deficient, these can be re-built or reinforced. Once the
commitment to implement the remedy is made by either the PRPs or
the Agencies and is formalized in the ROD and Consent Decree, the
commitment is made to maintain the system, regardless of the
magnitude of the potential repairs.
How long will the remediation of the PDSLD/IW areas take, if
flushed?
Design studies will have to be conducted to set up the optimum
balance between flushing rate (water input rate), soil residence
time, and characteristics of the particular contaminants. These
studies will take place during the design phase of the remedy.
After the studies are completed, the Agencies should have a
better idea with regard to the length of time needed for the
remediation of the PDSLD/IW areas.
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6. Financial Considerations
Why is it not economically feasible to remove the soils to
groundwater in the PDSLD and IW? Will it take longer to treat
contaminants from both soils and aroundwater? The citizens would
prefer that these soils be excavated and removed to a secure
facility.
The seepage lagoon concept for re-infiltration of treated
groundwater is estimated to cost $150,000 more than would a re-
infiltration system using injection wells. However, soil
disposal costs roughly $200 to $300 per cubic yard for off-site
landfilling and approximately $1,400 per cubic yard for
incineration. The combined IW and PDSLD areas comprise
approximately 9,400 cubic yards of soil. Disposal costs for this
volume would range from at least $1,880,000 for off-site
landfilling, to $13,160,000 for incineration. These cost
estimates do not include on-site equipment costs and personnel.
Through the closed-loop flushing, extraction and treatment,
complete removal of contaminants can be obtained over time. For
a relatively small added cost, the re-infiltration system can be
made to serve "double duty". It is true that the operation of
the system will have to be designed to accommodate the additional
input from soils and groundwater, but this is not expected to
extend the duration of treatment appreciably.
If soils were excavated to groundwater, and the excavation filled
with clean soil, these soils would also become contaminated
through the seasonal fluctuation of the contaminated groundwater.
It is prudent to remediate the soils and groundwater in this area
as a unit.
What would it cost to totally remove all of the soil and
aroundwater contamination, including the landfill?
v
Estimates generated during the early stages of Feasibility Study
preparation show the price for complete removal of all soil areas
and landfilled materials between $150,000,000 and $200,000,000.
Groundwater contamination removal adds on at least an additional
$26,000,000 (capital costs plus 5 times (years) the annual 0 & M
costs as noted in the ROD).
What should a potential developer do now to obtain financing?
Will development potential change in the future based on the
remedial actions proposed? What liability does a developer have
relative to informing home buyers of the sites in the area? Once
completed, will the Agencies be issuing a letter stating thatthe
cleanup has been completed and assuring the public that there is
no need to worry about contamination from the site?
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Obviously, lenders and developers have to review and consider
their obligation with regard to disclosure to potential clients
of the presence of the Rasmussen or other Superfund sites. The
Agencies may not advise developers regarding their obligations in
this area. Throughout the course of the remediation, the
Agencies will be issuing statements of progress. At the
completion of the groundwater purging and treatment operation,
and likewise, once the cap is in place, the Agencies will notify
all persons on the mailing list of the completion of such
activities.
The decision to fund any project depends upon the policies of the
lending institution. The Agencies cannot offer any short-term
solutions or predict the availability of funding for projects in
this area. What the Agencies will do is work to implement risk
reducing remedial actions using the Superfund process. The
status of the cleanup will be reported periodically, to keep all
interested parties informed of the progress of the cleanup
activities. (Note, there is currently no existing risk from
groundwater usage in the vicinity of the Rasmussen site).
Is there going to be a provision for either replacement of the
cap at the end of 30 years of maintenance in perpetuity for this
cap, and where will the money come from?
If a settlement is reached with the responsible parties to
undertake the remedial action, the Agencies7 expectation would be
that the PRPs would also sign on to undertake the operation and
maintenance of the cap for perpetuity. The mechanism for PRP
funded O & M varies depending on what is negotiated. Sometimes
PRPs sign an agreement to make yearly payments, and sometimes
they use the trust fund mechanism.
In the absence of having a settlement with the PRPs, the Federal
Superfund would fund the O & M for one year, and the State would
pay for O & M from then on.
Maintenance in perpetuity means forever, not just 30 years. See
the answer above under Section 5.
What guarantees do we have that if the political climate changes.
the cap O & M will continue to be provided by the Agencies? If
economic feasibility is the rationale for choosing the cap, then
the citizens want to be sure that same reason is not used for
taking away the 0 & M funding.
Although there are no absolute guarantees, the Agencies are under
an obligation to continue to protect public health and the
environment. The likelihood for discontinued funding for any
program exists, but there is a greater likelihood that funding
will continue to be provided through one of the various
mechanisms.
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Economic feasibility was not the only rationale for choosing the
cap for this site, rather it was only one of balancing criteria.
Please refer to the ROD "Summary of Comparative Analysis of
Alternatives" section.
Can EPA comment on the likelihood of actually getting a trust
fund set up? Citizens expressed a preference for seeing "the
money in the bank" rather than promises to pay.
If 0 & M is implemented by the Agencies, no trust fund will be
set up. It is difficult to speculate on the likelihood of the
PRPs setting up a trust fund, however, one of the focuses of the
negotiations toward a consent decree will be to obtain financial
assurances from the PRPs. EPA's concern is not so much which one
of the acceptable mechanisms is proposed, but that adequate
assurances are provided. It is up to the PRPs to propose an
acceptable mechanism for financial assurances. The State prefers
the trust fund mechanism for funding of long-term O & M.
7. Other Verbal Comments
Is October 31. 1990 our last opportunity to have input into what
happens at the site? Will we know what comments other persons
sent the Agencies in writing? Will we have other information
meetings prior to ROD issuance?
Comments and the transcript of the public meeting have been put
in the Administrative Record and repositories for review. The
public comment period closed on October 31, 1990, after being
open for 60 days—thirty more than is required by the National
Contingency Plan (NCP). It would not serve the public interest
in the expeditious remediation of this site to reopen the public
comment period at this time. We will mail out the Responsiveness
Summary, which consolidates all comments received during the
Public Comment Period, and the Agencies' responses thereto, and
ROD, to all persons on the mailing list. The documents will also
be in the Administrative Record and repositories for review.
After these are issued, we will reconvene for an informal
availability session to discuss the ROD.
Comments Received in Writing
Written comments were received from 3 separate parties. As
stated before, the majority of these comments were in support of
the preferred alternative, and urged swift implementation. The
following are responses to the written comments.
The Michigan Department of Public Health. Interaaency Center on
Health and Environmental Quality provided the following comments:
"We have reviewed the proposed plan and selected alternatives as
laid out in the document. The alternative provides for
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14
sufficient protection of public health." They recommend the use
of infection wells versus seepage basins to avoid the attractive
nuisance problem and contaminant diffusion. Another
recommendation offered is that it would 'be economical to combine
the treatment systems for the Rasmussen and Spiegelberg sites.
The groundwater treatment alternative using injection wells
versus seepage basins was the preferred option for the Rasmussen
site. Further investigations into the nature of contamination in
the PDSLD and IW soils areas of concern indicated that the re-
infiltration system could serve two purposes—that of re-
infiltration and flushing. The soil contaminants in this area
are largely located just above the water table, and flushing is
therefore expected to be protective, effective, and economical.
Protective fencing coupled with periodic checking by on-site
personnel should protect against trespass.
With regard to combining the systems, among other things, the PRP
groups for the two sites are comprised of different entities.
The Agencies therefore have to proceed with the remediation of
the sites separately, and negotiate the remedial actions for the
two sites separately. The PRPs may suggest sharing of equipment
between sites if feasible, but this will need to be approved by
the Agencies before implementation.
The Livingston County Health Department (LCHD) feels that the
chosen alternative for the Rasmussen site ". . .will provide an
acceptable solution to the environmental contamination problem at
the site." They suggest that residential well monitoring begin
immediately, and continue throughout the cleanup project. They
ask that monitoring results be provided to residents. Township
officials, and the LCHD. They hope work will ". . .commence
without delay."
Residential well monitoring is expected to/has re-commence(d) the
week of October 22, 1990, and (will) continue at least through
remedy implementation. We would prefer to detect groundwater
contamination prior to its entering residential drinking water
supplies. Monitoring wells placed at varying depths between the
known extent of the plume and the residential wells will afford
this "early warning" system. Some wells are already present, but
a complete monitoring system will be specified with remedy
construction. Results of all monitoring will be made available
to all of the interests indicated by the LCHD.
PRP Comments
The following were comments submitted on behalf of the Rasmussen
Site PRP Group referred to as the Rasmussen Site Steering
Committee (RSSC). Submittals during the Public Comment Period
were made via two documents: 1) "Misapplication of the Act 307
Rules as ARARs to the Decision Process at the Rasmussen Site",
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and "Evaluation of Proposed Plan and Recommended Modifications,
Rasmussen Site". These documents refer to August 1989 submittals
by the RSSC including: 1) "Proposed Remedial Plan, Rasmussen
Site", 2) "Assessment of Zinc and Nickel'Analyses of Groundwater
Samples from the Spiegelberg and Rasmussen Sites, Michigan", 3)
"Post Section 106 Removal Public Health Risk Assessment,
Spiegelberg and Rasmussen Sites", and an August 1990 document 4)
"Proposed Groundwater Cleanup Levels-Rasmussen Site".
The Proposed Plan reflects an improper application of the
Michigan Act 307 Rules as ARARs for the following reasons;
1. U.S. EPA has a duty under SARA and the NCP to evaluate
whether a state regulation constitutes an ARAR. and if so.
U.S. EPA must decide whether and/or how to apply that ARAR.
2. The cleanup criteria in the Proposed Plan constitutes a
misapplication of the 307 Rules as ARARs. and as such are
inconsistent with Section 121(d)(2)(A) of SARA, the NCP and
well-established Superfund guidance and policy.
3. Proper application of the Act 307 Rules would consider Types
A. B and C. and an adoption of a combination of cleanup
types for this site.
4. Recent proposals including this one, demonstrate that MDNR
is recommending an application of the Rules to groundwater
cleanups which is inconsistent with specific provisions of
the Rules and contrary to senior management policy
statements.
5. The Administrative Record's failure to provide -justification
of the basis for the application of the 307 Rules as ARARs
is a violation of due process.
It is true that EPA has a duty to consider whether and how to
apply an ARAR to Superfund site cleanups. The State has the
responsibility of identifying ARARs, defined as any promulgated
standard, requirement, criteria, or limitation, under a state
environmental or facility siting law, more stringent than Federal
requirements (CERCLA Section 121(d)(2)(A)). In this instance,
Michigan Act 307 Rules contain criteria for complying with Type
A, B, and C cleanups. The substantive provisions of the Rules,
Parts 6 and 7, are considered ARARs for the remedial action to be
undertaken for this site. These Rules provide, inter aliaf that
remedial actions shall be protective of human health, safety, and
welfare and the environment and natural resources (Rules
299.5601(1) and 299.5705(1)). The Act 307 Rules specify that
this standard is achieved by a degree of cleanup which conforms
to one or more of the Types A, B or C cleanup criteria. In this
instance, the soil and groundwater cleanup standards and
compliance points are based on U.S. EPA's agreement with the
State's recommendation of a combination of all three Types of
cleanup for this site. With regard to groundwater in- particular,
U.S. EPA found that, given the present and potential future uses
of the groundwater plume, and light of the expectation in the NCP
that groundwater be returned to its beneficial uses, 40 CFR
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Section 300.430(a)(iii)(F), risk-based cleanup levels consistent
with a Type A and B cleanup are appropriate for this site.
Please refer to detailed technical questions and responses below
relative to the intricacies of cap design and application of
cleanup criteria.
Capping Comments
The acreage of the proposed cap extends significantly beyond the
limits of the TML area.
The assertion that the Agencies' proposed cap extends
"significantly beyond the limits of the TML area" is correct.
However, for an acceptable cap under "closure conditions",
several criteria must be met. One of these is to cover
adequately the material inside the waste boundary. In addition,
proper design (including cap thicVr»ess/configuration and slope
requirements) must be met for the site. This will require the
cap design to extend beyond the TML area. The Agencies would be
amenable to review, and if acceptable, approve a cap design
which incorporates terracing. This would reduce the lateral
extent of the cap. In order to meet relevant and appropriate
closure requirements under Michigan Act 64, the cap design for
the Rasmussen Site must extend over and beyond the waste in all
directions.
The PRPs contend that Act 64 is neither applicable nor relevant
and appropriate based on current site conditions.
As stated in the FS, Act 64 is not legally applicable, but as
stated, it is relevant and appropriate, as it addresses problems
and situations sufficiently similar to those encountered at the
site as it currently exists. It is true that the remaining dump
materials are primarily municipal garbage, however, post-Section
106 order removal observations by EPA's oversight contractor
indicate that visible drums remain. Although the Proposed Plan
calls for the removal of drums encountered during capping, a
strong likelihood exists that other containerized and potentially
hazardous wastes will remain within the capped area. Based on
past waste disposal practices, and the dump waste samples taken
during the RI, a small portion of the primarily municipal garbage
contains hazardous substances of higher toxicity. It is the
Agencies' assessment that remaining site conditions are
sufficiently similar to, and require the protectiveness of the
Act 64 capping requirements.
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The RSSC proposes an alternate cap design based on their
determination that Act 641 is relevant and appropriate, and that
Act 64 is not relevant and appropriate. On pages 8 and 9 of
their "Evaluation" document, the RSSC outlines specific remedial
components associated with their proposed alternate capping.
As discussed previously, the determination has been made that
although dump materials are primarily municipal garbage, some
residual hazardous wastes are likely to be present, and therefore
Act 64 is relevant and appropriate.
With regard to the bulleted items on pages 8 and 9, the Agencies
offer the following comments. The backfilling, terracing and
refilling of the Ramsey excavation, and regrading described in
bullets one through three are necessary for both the RSSC's and
the Agencies' cap designs, and are acceptable proposals. The
clay cap proposed in bullet four and depicted in Figure 2.3 is
not sufficient to cover all dump wastes as described in the next
answer. A perimeter collection drain around the cap to collect
surface drainage, as outlined in bullet five, is an acceptable
proposal for any capping regime. Bullet six is confusing as it
states that ". . .areas outside the limits of the landfill cap
would be revegetated for surface water control and to promote
stable surfaces." The use of the word "outside" appears to limit
revegetation to areas other than the capped area. Revegetation
of the entire area is an acceptable proposal, and revegetation of
the cap with grasses is required by statute. The final design of
the cap will be determined during remedial design and may not
include any or may include all of the PRP's "acceptable"
proposals.
The RSSC determined that the cap need not extend over the south
slopes area because dermal contact risks associated with this
area were found to be acceptable, and these areas are heavily
vegetated and presently stable.
The proposal for leaving the south slope as is, with existing
vegetation growing into the wastes, is unacceptable. The area's
wastes are not currently covered with the impermeable layers
required for the most lenient of capping specifications under
State or Federal requirements, for the protection of the
groundwater resource. "Cover" currently consists of sand and
gravely soil intermixed with garbage and scrap metal (including
pieces of drums, car parts, hot water heaters, etc.). Vegetation
growing in these materials over the years has allowed for the
build-up of organic materials, promoting further vegetation.
These growths consist of 4 to 6 inch diameter trees, sumac,
poison ivy, grasses and sedges. Neither groundwater protection
nor long-term maintenance considerations are served by leaving
the south slope in its current condition.
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The RSSC compares their proposed cap design to the cap design
outlined in the Agencies/ Proposed Plan, with regard to the NCP/s
9 evaluation criteria.
i. Overall protection of human health and the environment - The
RSSC states that the Agencies' proposed cap design would provide
overall protection of human health and the environment in the
long-term but not in the short-term. With regard to the short-
term allegations, RSSC suggests that grading of wastes onto
unaffected soils areas and disturbance of landfill wastes would
pose an unacceptable short-term risk. First, the Agencies'
preferred capping alternative as outlined in the Proposed Plan
does not specifically include the regrading of wastes, although
some of this activity may have to be conducted. As outlined, the
Agencies' cap is described as constructed over the TML and NEED
areas of concern as they now exist spatially on-site. Secondly,
any large scale movement of wastes, if necessary, will be
conducted to minimize any potential short-term problems. The
problems envisioned by RSSC are the same ones which would have
been realized during the CERCLA Section 106 ordered removal
activities, where sections of the landfill were excavated and
moved to temporary storage areas. No short term risks were
encountered.
Furthermore, the RSSC design, lacking cover over all wastes and
leaving woody vegetation rooted in wastes, does not conform to
this requirement.
ii. Compliance with ARARs - The RSSC states that the Agencies'
cap design does not take appropriate measures against erosion to
comply with the Michigan Soil Erosion and Sedimentation Control
Act (SESCA), but SESCA is an ARAR for this site, as noted in the
attached ROD. These measures are not specifically outlined in
the Proposed Plan. The Agencies feel that the correct venue for
this level of detail is in the Scope of Work leading into design,
and the remedial design work plan. Capping must "promote
drainage and minimize erosion or abrasion of the cover" (40 CFR
264.310(a)(3)). Measures will be taken within the Agencies'
capping proposal to comply with SESCA. Within the realm of
design consideration are drainage layers, terracing, and other
stormwater management measures.
iii. Long-term effectiveness and permanence - Again, the
majority of the issues brought up by RSSC are tied to future
design considerations and are not necessarily deficiencies with
the Agencies' Proposed Plan. Part of these considerations are
terracing and rip-rapped drainage ditches. A properly designed
and constructed cap should not suffer from internal erosion
(piping). The size of the dump cap area does not necessarily
directly relate to its ability to handle stormwater. Larger
dumps are routinely capped, with design considerations upscaled
for increased water management.
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The Agencies' cap was designed with climactic conditions in mind.
EPA estimates 30 inches of frost penetration in these areas. It
is true that if cracking did occur, the '24 inches of topsoil and
6 inches of the clay would be impacted. This still leaves 30
inches of unaffected clay.
RSSC also argues that the 1E-07 cm/sec permeability proposed by
the Agencies for clay is susceptible to desiccation cracking due
to moisture changes. The clay layer can be kept moist through
the Agencies' 24-inch topsoil drainage layer versus RSSC's 30-
inch layer.
The 1-foot thick vegetative layer (plus 1-foot thick drainage
layer) proposed by the Agencies is intended to provide a zone
capable of establishing shallow rooted grasses and maintaining
the vegetation so as to stabilize the cap and prevent erosion.
The shallow root zone is intended to aid in water uptake and be
persistent enough to withstand drought conditions, at design
slopes. These grasses would also make O & M of the cap easier.
The deep-rooted plants specified by RSSC may adversely affect the
integrity of the clay cap in the long term.
iv. Reduction of toxicity, mobility or volume through treatment
- This factor is not applicable to capping since no treatment is
contemplated.
v. Short-term effectiveness - RSSC's comments on this item are
effectively addressed by previous guestions, and are largely a
function of future design considerations.
vi. Implementability - Implementability of the Agencies'
proposed capping regime is questioned due to size and associated
time constraints, and easements. Although these are factors to
consider, none are prohibitive. Again, size will vary depending
on the use of regrading and terracing. Deed restrictions are not
a factor of implementability germane to the Agencies' proposal
alone, as suggested by RSSC, because any in-place remedy
necessitates the use of deed restrictions to insure the integrity
of that remedy.
vii. Costs - As outlined in previous questions, assumptions made
by RSSC with regard to the Agencies' proposed capping remedy are
erroneous. RSSC then uses these assumptions to re-calculate the
costs of the Agencies' remedy as they envision it being
implemented, and subsequently compare these estimates to that of
their proposal. Many of those assumptions lead to overestimates
in costs. Assumptions include the use of regrading and that the
Agencies' option includes inappropriate erosion control design
measures. This portrayal of the Agencies' remedy is not
accurate.
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The use of costs in remedy selection is for the differentiation
of remedies of equal protectiveness and ARARs compliance, which
has been considered.
viii. Support agency acceptance - Not applicable to this
discussion.
ix. Community acceptance - The RSSC states that "The community
has already expressed significant concern regarding the long-term
integrity of the Agencies' proposed cap remedy." Contrary to
this portrayal, the community clearly expressed concern regarding
the long-term integrity of capping remedies in general. It is
the concept of in-place disposal which was unpalatable to the
surrounding residents, and not the Agencies' proposal in
particular.
The RSSC uses the HELP model to compare their proposed cap design
to the cap design outlined in the Agencies' Proposed Plan, with
regard to hydraulic performance. They also assert that, based on
the modelf "the RSSC proposed alternate cap design will prove to
be superior to the Agencies' Act 64 cap."
As noted by RSSC, the model only illustrates cap effectiveness
with regard to infiltration reduction, and does not account for
frost or desiccation damage. The results of RSSC's modeling
showed the cap designs to be equally effective in reducing
infiltration. RSSC's incorrectly concludes that their cap
proposal is "superior", since (as they note), the test they
employed can not be extrapolated to conclude anything about frost
or desiccation damage.
RSSC contrasts the Agencies' proposed cap cost estimates with
that of their alternate design.
There may be inaccuracies in the cost estimates for the Agencies'
capping remedy, particularly since these estimates were compiled
over two years ago and the costs for supply and placement of clay
are based on 2 rather than 3 feet of clay as presented in the
Proposed Plan. This, and many of the other discrepancies noted
by RSSC, will increase the total price proportionally for all
remedies considered in the alternatives analysis, but may
decrease the unit cost based on quantity. Placement costs for
clay associated with "multimedia covers" (Alternatives 4 and 5),
are generally higher due to the car« needed to be taken
protecting the synthetic liner, hence the unit cost difference in
the FS.
However, costs may be used to differentiate only between remedies
which are protective and meet all ARARs, as noted above. Also
faulty assumptions underlie the RSSC's cost comparison, as noted
above.
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21
Groundwater Indicator Chemical Comments
"The selection process for indicator chemicals indicated in the
Proposed Plan fails to acknowledge the findings from the
Agencies' own risk assessment." (Page 26 of the RSSC "Evaluation"
document) "Potential carcinogenic risk estimates shown for each
chemical in Table 1 of the Proposed Plan effectively assume that
a domestic or community supply well would be installed directly
in the affected groundwater at the locations of maximum chemical
concentrations beneath the Rasmussen site." (Page 29 of RSSC
"Evaluation" document) The RSSC recommends eliminating the
following four chemicals of concern on the basis of Risk
Assessment calculations: bis(2-ethylhexyl)phthalate. 1.1-
dichloroethene. tetrachloroethene. and isophorone.
The Agencies' risk assessment was used as the starting point for
determining risk posed to potential receptors from the areas of
concern. The current selection of chemicals of concern and
cleanup levels must also comply with Federal and State ARARs. In
this instance, EPA chose the risk-based cleanup levels to meet
the expectation in the NCP that groundwater be returned to its
beneficial use, 40 CFR Section 300.430(a)(iii)(F), and based on
the current and future use scenarios for the affected aquifer.
These cleanup levels are consistent with the provisions of Act
307 regarding the removal of hazardous substances from the
aquifer (Rule 299.5705(6)).
Of the four chemicals listed above, all except tetrachloroethene
remain as chemicals of concern based on their concentrations
confirmed during the Agencies' RI, and the comparison of these
concentrations with cleanup levels. Tetrachloroethene was
estimated at 2.0 ppb in two background sample locations (RA-MW-16
and RA-MW-35), and estimated also at 2.0 ppb in one downgradient
location during the same sampling episode (March of 1987).
Although this was reported as a positive detection in Table 2-5
of the Risk Assessment, quality control protocols do not hold
this one detection as validated data. Tetrachloroethene has been
deleted from the list of indicator chemicals.
The RSSC suggests screening out data from the RI based on
frequency of detection. They recommend eliminating 1.1-
dichloroethene. tetrachloroethene. benzyl alcohol. 2-
chlorophenol. and isophorone based on this, criteria.
Low frequency of detection is not a valid reason to eliminate
chemicals since these data points withstood Quality
Assurance/Quality Control. As discussed previously,
tetrachloroethene has been eliminated from the list of chemicals
of concern for other reasons. Benzyl alcohol has been deleted
for the reasons stated later in this document.
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22
The RSSC recommends that the Agencies present the risk results
from the Agencies/ risk assessment and clarify the "unrealistic"
nature of the risk numbers presented in the Proposed Plan.
The risk results from the Risk Assessment are provided in the
ROD, along with the sets of assumptions used to calculate these
numbers. The Agencies do not feel that the groundwater risk
numbers are unrealistic as presented in the Proposed Plan for the
potential consumer of the groundwater resource as it exists
beneath the Rasmussen site.
By failing to consider a Type C cleanup classification, the
Agencies7 Proposed Plan makes no allowances for Site-specific
conditions and disregards issues of technical feasibility.
limitations of analytical chemistry, reasonable and foreseeable
uses of the Site, and cost-effectiveness.
As noted in the response to the first RSSC question, the Agencies
did not fail to consider a. Type C groundwater cleanup. Technical
feasibility and limitations of analytical chemistry were
considered. Although consistent with a Type A cleanup, chemicals
which have a "Basis" for the cleanup criteria noted as "MDL" or
method detection limit have taken into consideration, what is
achievable by a analytical laboratories. In assessing reasonable
and foreseeable uses of the site, the Agencies considered the
potential consumer of the groundwater resource at the site in all
portions of the aquifer.
As stated earlier, the NCP contemplates that cost will be a
differentiating factor only between alternatives which are
protective and which comply with ARARs. Similarly, Act 307 Rule
299.5601(3) states that "The cost of a remedial action shall be a
factor only in choosing among alternatives which adequately
protect the public health, safety, welfare and the environment
and natural resources, consistent with the requirements of part 7
of these rules."
RSSC states that the proposed Type B cleanup levels for acetone.
2-butanone. 1.2-dichloroethene. ethylbenzene. 4-methvl-2-
pentanone. toluene. 1.1.1-trichloroethane. and xylenes are
calculated correctly. However, they did not find that acetone.
2-butanone. 1.2-dichloroethene. 4-methyl-2-pentanone. and 1.1.1-
trichloroethane were present above Type B cleanup levels in RSSC
sampling rounds.
These chemicals have been detected during previous sampling trips
at concentrations exceeding Type B criteria. Chemicals will be
included in the indicator chemical list if they have exceeded
Type B criteria anywhere on the site at any time. They will not
be deleted for the stated reason.
RSSC contends that acetone, bisf2-ethvlhexvl)phthalate, 2-
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23
butanone, and methylene chloride are present in site samples due
to laboratory contamination.
RSSC's discussion of laboratory contamination can be found
throughout the section on groundwater cleanup numbers. Their
Table 3.5 compares selected sample data with the corresponding
laboratory blank. EPA and MDNR recommend eliminating common
laboratory contaminants only if the concentrations in the sample
do not exceed ten times the maximum amount detected in any blank.
All of the methylene chloride, acetone, bis(2-
ethylhexyl)phthalate and 2-butanone data was reviewed for
compliance with this criterion. The results are presented in
Appendix A to this Responsiveness Summary. In addition, review
included complete analysis of the data validation packages for
other indications of poor data quality. Results of the review
show that three of the methylene chloride (GW0023, GW0027 and
GW0028) data points (previously reported as valid) could not be
validated based on the ten times exceedance criteria. All of
these data points were from background wells and did not
represent the maximum data value reported in Table 1 of the
Proposed Plan. One acetone data point (GW006) failed the
validation criteria. This sample was not the maximum reported
value from Table l. Two of the bis(2-ethylhexyl)phthalate sample
analyses (GW006 and GW011) were qualified as having the compound
in the blank (B), but review of the validation package showed
non-detect in the blank. These two concentrations were valid.
One 2-butanone sample (GW016) exceeded the CLP required holding
time, and was found invalid. Two were noted as having low
recovery factors in the spike, one (GW004A) was subsequently
validated, the other (GW0079) was not. Based on these results,
the presence of the four chemicals in question could not be
attributed to laboratory contamination, and will remain as
chemicals of concern for the Rasmussen groundwater plume.
Investigations into the sample points reported in Table 3.5 of
the RSSC comments could not substantiate any of the data listed
therein.
RSSC contends that benzyl alcohol should be deleted from the
chemical of concern list because they could not confirm the
chemical in their sampling rounds.
The risk-based cleanup for benzyl alcohol was incorrectly
reported as 9 ppb. The correct risk-based level, which is
consistent with the Type B cleanup level, is 10 ppm (10,000 ppb)
based on data from the National Toxicology Program bioassay
(1989). The reported concentrations of benzyl alcohol (12 ppb)
do not exceed the cleanup level; therefore, benzyl alcohol should
be removed from the list of chemicals of concern.
RSSC contends that the HLSC for chlorobenzene should be 100 ppb
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24
which is consistent with U.S.EPA's Final Lifetime Health Advisory
and based on an alternate literature citation for the taste and
odor threshold.
The data from Amoore and Hautala (1983) was chosen to establish
aesthetics criteria because it is a well-recognized, quality
study. The threshold odor concentration (TOC) of 100 ppb
reported in Verschueren (1983) is based on two German articles
that are not available for review. EPA has relied on Amoore and
Hautala (1983) for establishing Secondary Maximum Contaminant
Levels. The cleanup level for chlorobenzene will remain at 50
ppb based on the Amoore and Hautala (1983) citation.
The RSSC states that the Agencies arbitrarily cited the lowest
literature taste and odor threshold for 2-chlorophenol. and
should have chosen the HLSC of 40 ppb as the cleanup level.
The selection of the 0.1 ppb as tl.a aesthetics criterion is based
on the data in Verschueren. These data are reported as an odor
threshold of 0.18 ppb and a taste threshold ranging from 0.1 to
6.0 ppb. Since the odor threshold is reported at 0.18 ppb, a
concentration of 0.1 ppb should protect against both adverse
taste and odor effects. An acceptable method detection limit
(MDL) for 2-chlorophenol is 5 ppb. Since the aesthetics
criterion is less than the MDL, the MDL becomes the cleanup goal.
The cleanup level for 2-chlorophenol is 5 ppb. However, since
the aesthetics criterion is significantly less than the MDL, an
attempt to evaluate the aesthetics of the remediated groundwater
should be made.
RSSC contends that the cleanup level for 1.1—dichloroethene
should be set at the MCL/MCLG level of 7 ppb rather than based on
its suspected carcinogenicitv.
The Agencies are currently reviewing the carcinogenicity data for
1,1-DCE to determine if it should continue to be regulated as a
carcinogen. Since the State has historically regulated 1,1-DCE
as a carcinogen, they will continue to do so until the
toxicological review is completed. The cleanup level for 1,1-DCE
remains at 1.0 ppb.
The RSSC contends that the Agencies/ selection of a cleanup level
for 2.4-dimethvlphenol based on a detection limit fl ppb) should
have bfcen based on the draft HLSC of 140 ppb.
Further information has recently become available with respect to
2,4-dimethylphenol. An oral RfD became available in IRIS as of
November 1, 1990. The new risk-based cleanup level, consistent
with a Type B cleanup, is 100 ppb. since the health-based value
is lower than the aesthetics criteria of 400 to 500 ppb, 100 ppb
is the final cleanup level. The Agencies have deleted 2,4-
dime£hylphenol from the list of indicator chemicals for the
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25
Rasmussen site as the maximum concentration detected at the site
is 27 ppb, which is below the cleanup level.
The RSSC contends that the Agencies should have based cleanup
levels for 2-methylphenol and 4-methylphenol on HLSC values
rather than on taste and odor thresholds.
The aesthetics data for 2-methylphenol and 4-methylphenol have
been re-evaluated. Verschueren (1983) reports the following
aesthetics data for 2-methylphenol in water:
Parameter Concentration Reference
number
odor threshold (tentative): average: 0.65 mg/1 (ppm)
range: 0.016 - 4.1 mg/1
(294)(97)
TOC in water: 0.09 ppm
0.65 ppm
(326)
TOC in water: 0.26 ppm
(325)
odor threshold:detection: 1.4 mg/1
(998)
Taste threshold concentration: 0.003 mg/1
(998)
Reference 998 is a German article unavailable for review,
therefore, the Agencies' original decision to use this article
for development of the aesthetics criterion was inappropriate.
The Agencies are currently using reference 325 entitled "Odor
thresholds of mixed organic chemicals" by A. A. Rosen, et.al.
(1962) to develop the criterion. The threshold developed by
Baker (Reference 294) is a tentative value and the data reported
by Stahl (Reference 326) is a compilation of data and includes
the data of Baker. The study by Rosen (1962) is a well-conducted
study. Threshold odor concentrations (TOC) for several compounds
were generated using a panel of 11 to 16 judges taken from a
pool of 20 people. The geometric mean is reported as the TOC.
The risk-based Type B criterion for 2-methylphenol is 300 ppb
(260 rounded to 1 significant figure).
The only data reported for 4-methylphenol is a taste threshold
concentration of 0.002 mg/1 and an odor threshold (detection) of
0.2 mg/1 from the previously mentioned reference 998. Since
inadequate aesthetics data exists for this chemical, the Agencies
relied on the HLSC as the risk-based cleanup level, which also
meets the Type B criterion. However, since adverse aesthetics
are associated with the phenolic compounds, an attempt to
evaluate the aesthetics for 400 ppb of 4-methylphenol is
recommended. Since the maximum reported concentration of 4-
methylphenol is 280 ppb, it is deleted from the list of
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26
indicator chemicals.
The RSSC reiterates their contention tha-t the Agencies/ proposed
cleanup levels for both benzene and vinvl chloride do not
consider Type C criteria including technical limitations of
analytical chemistry, technical limitations of remedial
technologies,, and cost-effectiveness. RSSC recommends the
following cleanup levels; 5 ppb for benzene and 2 ppb for vinyl
chloride.
The Agencies continue to stand behind the risk-based, Type B
criteria used for these two cleanup levels. Previous responses
deal with the issues of Type C criteria consideration. Final
MDLs issued by the Department include 1.0 ppb for vinyl chloride
(previously reported as 0.5 ppb).
Most commercial laboratories using GC methodology can detect the
required cleanup levels of 1.2 ppb and 1.0 ppb benzene and vinyl
chloride, respectively. A few laboratories using GC/MS will also
achieve these levels. Either technique is appropriate provided
the MDL is adequate.
RSSC feels that the cleanup level set for tetrachloroethene
should be set at the proposed MCL of 5 ppb rather than at the 2
ppb level for potential carcinogenic risk.
The maximum concentration of tetrachloroethene was incorrectly
reported as 2.0 ppb as described in the first response in this
section. Tetrachloroethene will be deleted as a chemical of
concern for the Rasmussen groundwater plume.
According to RSSC. trichloroethene should have a cleanup level of
5 ppb based on the Federal MCL. rather than the l.OE-06
carcinogenic risk number of 3 ppb. Review of the RI and RSSC
subsequent sampling data has confirmed the presence of
trichloroethene in the vicinity of RA-MW-27. The RSSC proposes
installing a supplemental groundwater extraction well near this
location for the purpose of groundwater cleanup.
The Agencies believe it is necessary to establish risk-based
cleanup levels for the site. The basis for the selection of
these cleanup levels is provided in CERCLA Section 121 and the
NCP. In order to protect human health and the environment, under
CERCLA and the NCP, a risk-based cleanup has been established for
groundwater. A risk-based cleanup is necessary due to the close
proximity of residential wells and the potential future use of
groundwater at and near the site.
The NCP requires a site be remediated to within a 10~4 to 10~6
risk range. In order to achieve a level of acceptable risk at
the site, due to the number of carcinogenic contaminants detected
at the site, cleanup levels were established at a 10~6 risk
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27
level rather than at the MCLs or the non-zero MCLGs.
The risk-based, Type B cleanup level of .3.0 ppb for
trichloroethene is associated with an increased cancer risk of
l.OE-06 which the Agencies consider an acceptable level of risk,
and which serves as the basis for regulating carcinogens. The
cleanup level for trichloroethene, which is consistent with the
Type B criterion, will remain at 3.0 ppb.
RSSC contends that lead is not an indicator chemical for the
Rasmussen site because their sampling rounds have shown on-site
concentrations to be less than background levels, and dissolved
lead in these samplings was detected below the HLSC of 10 ppb.
They contend that the MDNR interim RfD calculation which
produces a cleanup level of 5 ppb is inappropriate.
Appendix B attached hereto is further rationale for developing a
risk-based Type B criterion of 5 ppb for lead. The basis for
this criterion is not specifically inhalation exposure, but
rather a blood lead level produced by a variety of exposures.
The Acceptable Daily Intake (ADI) developed several years ago by
EPA is out of date and inappropriate to use. EPA states in IRIS:
"By comparison to most other environmental toxicants, the degree
of uncertainty about the health effects of lead is quite low. It
appears that some of these effects, particularly changes in
levels of certain blood enzymes and in aspects of children's
neurobehavioral development, may occur at blood levels so low as
to be essentially without a threshold." Since development of the
ADI, lead has also been classified as a probable human
carcinogen. As a result, it is appropriate to use an approach
that takes these factors into account and yields a more
conservative estimate than the ADI developed several years ago.
If design studies (and split samplings) show that either 1) on-
site filtered lead samples are less than 5 ppb, or 2) on-site
filtered lead samples are greater than 5 ppb but less than
background filtered lead levels, then lead may be deleted from
the list of chemicals of concern.
The RSSC suggests the deletion of cadmium as a chemical of
concern based on comparisons with background levels and that
dissolved levels meet the Agencies' cleanup levels.
The cleanup level for cadmium will remain at 4.0 ppb. Like lead,
if design studies (and split samplings) show that either 1) on-
site filtered cadmium samples are less than 4 ppb, or 2) if on-
site filtered cadmium samples are greater than 4 ppb but less
than filtered cadmium levels, then cadmium may be deleted from
the list of chemicals of concern.
RSSC. contends that method detection limits ffiDLs) should be
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28
changed to practical ouantitation limits (PQLsl for 1.1-
dichloroethene. 2.4-dimethylphenol. and vinyl chloride, benzene.
2-chlorophenol. 2-methylphenol. 4-methylphenol. and
tetrachloroethene.
The primary difference between the MDL and the PQL is that the
MDL is a detection limit, and the PQL is a quantitation limit.
The detection limit is a measure of when an analytical system
indicates that a substance is present above a certain limit,
there is a 99 percent probability that the substance is present,
but not necessarily at the reported level. The PQL is
established at a level above the MDL where quantitative certainty
is higher. PQL is the lowest level that can be reliably achieved
within specified limits of precision and accuracy during routine
laboratory operating conditions. U.S. EPA developed the PQL
concept to define a measurement concentration that is time and
laboratory independent for regulatory purposes. The U.S. EPA
estimates that the PQLs are 5 to 10 times higher than the MDLs.
MDLs are more appropriate than PQLs as a lower detection limit on
target cleanup levels because:
1) MDLs extend the analytical range to lower levels based on
presence/absence of a contaminant. If a target cleanup
level is below the MDL and lab analysis confirms the
presence of a contaminant above the MDL, then the cleanup
level has not been achieved.
2) Although it is true that more quantitative uncertainty
exists with MDLs than PQLs, this uncertainty is reduced
through reliance on multiple samples.
3) In the absence of a large interlaboratory study to
identify the PQL, the PQL defies precise definition. The
PQL can only be estimated from the MDL using the 5 to 10
factor. MDLs can be determined for a single laboratory
using a specific instrument and a specific analyst.
Cleanup levels for these eight chemicals will not change based on
the PQL vs. MDL consideration. However, noted above are the
changes/deletions for some of these chemicals based on other
considerations.
Groundwater treatment Technology and Cost Comments
"The removal of heavy metals as a process option has already been
eliminated based on the determination. . .that lead and cadmium
are not appropriate indicator chemicals."
Recommendations by the PRPs that chemical precipitation for lead
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29
and cadmium removal are not necessary, will be accepted, provided
that the claim that these metals are not present in the
groundwater above filtered background levels is substantiated.
If necessary for the functioning of the balance of the treatment
system, a filter system for particulate removal may need to be
considered, even if the cleanup standards for lead and cadmium
are not triggered.
RSSC contends that biological treatment is not technically
feasible at the Rasmussen Site. Secondly, biological treatment
is not warranted based on RSSC sample data.
Discussions with manufacturers of treatment technologies and an
operator knowledgeable in the field of groundwater treatment
indicate that the selected technologies are capable of achieving
the required cleanup levels of the compounds at the influent
concentrations. Review of treatability data indicates that with
the exception of xylene and 2-methylphenol, all compounds could
be remediated to the stated target cleanup level by biological
(activated sludge) and aqueous phase carbon adsorption. With the
addition of air stripping, mean cell residence time would be
significantly reduced and would allow for down-sizing of the
biological treatment equipment. Biological treatment systems
are designed on the basis of the total amount of organics present
in the groundwater. This would be determined by the ratio of
BOD:COD:TOX, which would be quantified during the treatability
study (design).
It is a common procedure to add supplemental nutrients and/or
oxygen to maintain an optimum environment for the microbes.
Additionally, if a contaminant concentration is sufficiently low
that the microbes do not recognize it as food, an innocuous co-
metabolite can be introduced to enhance the microbes metabolism
of the contaminant.
It should be noted that biological treatment systems have many
advantages over conventional physical/chemical treatment
processes. Advantages include: multiple organics contaminants
can be treated simultaneously; unlike conventional treatment
methods, biological units are completely destructive, thereby
eliminating the requirements of disposing of the concentrated
contaminant waste streams; and, biological units are inexpensive
relative to conventional treatment methods (eg. 1/20 of the cost
of carbon adsorption and air stripping with vapor emission
controls).
A 360-degree qroundwater monitoring program around the dump for
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30
all parameters at both on- and off-site locations is unwarranted
due to cost and consideration of site hydroaeoloav. according to
the RSSC.
Groundwater monitoring of site closure under Act 64 requires
compliance with 40 CFR Part 264 subpart F. This subpart requires
a groundwater system that consists of a sufficient number of
wells representing background water quality and allows for
detection of contamination when hazardous wastes or constituents
have migrated from the waste management area. It is implied,
therefore, that the detection system be constructed so that
potential migration in any direction be intercepted.
Monitoring of off-site residential wells would be duplicative and
is unnecessary, according to RSSC.
The Livingston County Health Department has the responsibility
for ensuring that residential water supplies are safe to consume.
A major concern of the LCHD was that a safe water supply be
provided to the area. They suggested that alternate public water
be provided to the area around the two Superfund sites, as
municipal supplies are generally monitored more closely
(frequently) than residential supplies. The feasibility of this
was evaluated along with other alternatives. It was determined
that regular monitoring of the existing residential supplies,
until remediation could be assured, was the preferred
alternative. Toward that end, MDNR is currently arranging for
the sampling of residential wells to be conducted contractually.
Any agreement for remediation will also include the perpetuation
of this monitoring until groundwater cleanup at the site has been
achieved.
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ATTACHMENT
The community relations activities conducted at the Rasmussen
site to date are listed below. A key to abbreviations follows.
DATE OF ACTIVITY
1967 and 1968
March 5, 1981
February 1983
February 14, 1983
February 25, 1983
March 1983
April 1983
May 1983
July 29, 1983
TYPE OF ACTIVITY
PARTICIPANTS
Citizen Reports Complaints Citizen, MDPH,
Dumping and Burning
Citizen Complaint
Triggers Action
PIRGIM Meeting
PIRGIM Letter to MDNR
Meeting
Citizen's Letter to TSCC
Public Meeting
Citizens ACTION Formed
Task Force Meeting
September 12, 1983 Task Force Meeting
October 17, 1983
December 19, 1983
Newsletter #1
Task Force Meeting
January 6, 1984
U.S.EPA,
January 23, 1984
Task Force Meeting
Monthly Info. Bulit. #1
LCHD
Citizens, LCHD
Citizens, PIRGIM
PIRGIM, MDNR
PIRGIM,
Citizens,
MDNR, LCHD
Citizens, TSCC
SCARE, MDPH
All Interested
LCHD, MDA, MDNR,
Citizens, Twp.,
MDPH, TSCC,
Senator, Reps.,
Reps., Senator,
LCHD, Citizens,
Commission.,
MDPH, MDNR
U.S.EPA, MDNR
Reps., Senator,
Commission.,
Twp., LCHD,
Citizens, TSCC,
MDPH, U.S.EPA
LCHD, Citizens,
Commission.,
Senator,
MDNR
MDNR
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32
March 12, 1984
CIC Meeting
April 23, 1984
April 24, 1984
May 24, 1984
June 1984
June 7, 1984
June 29, 1984
July 17, 1984
July 19, 1984
Info Sent to Task Force
Monthly Info. Bull. #2
Newsletter #2
Information Repositories
Opened
CIC Meetine
Newsletter #3
CIC Meeting
Public Info Meeting
August 31, 1984 Monthly Info Bull. #3
September 27, 1984 CIC Meeting
October 11, 1984
October 25, 1984
October 30, 1984
November 3, 1984
November 9, 1984
Special Notice
Issuance of Community
Relations Plan
Community Toxicology
Presentation
Newsletter #4
CIC Meeting
Citizens, LCHD,
U of M, MDNR,
Commission.,
U.S.EPA, MDPH,
Twp., TSCC,
Reps.
MDNR
MDNR
U.S.EPA, MDNR
U.S.EPA, MDNR
Citizens, MDNR,
TSCC, Twp.,
MDPH,
LCHD, Senator,
U.S.EPA
U.S.EPA, MDNR
LCHD, Citizens
MDNR, WQB, Twp.,
Commission.,
Hamburg Twp.
U.S.EPA, MDNR,
LCHD, Citizens,
NUS, Fire Dept.
MDNR
MDNR, LCHD,
Citizens, TSCC
U.S.EPA, MDNR
U.S.EPA, MDNR
MDNR, U.S.EPA,
MSU
U.S. EPA, MDNR
LCHD, SEMCOG,
MDNR, Citizens,
Twp.
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33
November 27, 1984 Newsletter #5
December 3, 1984 CIC Meeting
January 7, 1985
January 24, 1985
January 30, 1985
February 4, 1985
March 29, 1985
April 1, 1985
May 31, 1985
July 1, 1985
CIC Meeting
CIC Effectiveness Survey
Newsletter #6
CIC Meeting
Newsletter #7
CIC Meeting
Newsletter #8
CIC Meeting
September 13, 1985 Newsletter #9
December 5, 1985 Newsletter #10
December 10, 1985 CIC Meeting
July 24, 1986
September 8, 1986
August 7, 1987
November 3, 1987
November 9, 1988
Newsletter #11
Progress Report
Newsletter #12
Newsletter #13
Newsletter #14
U.S.EPA, MDNR
LCHD, Citizens,
Twp., MDNR, NUS,
Media, U.S.EPA,
TSCC
Citizens, LCHD,
MDNR, U.S.EPA,
Twp.
U Of M, MDNR
U.S.EPA, MDNR
MDNR, Citizens,
TSCC, MDPH,
Twp. ,
LCHD, NUS
U.S.EPA, MDNR
Citizens, MDNR,
TSCC, LCHD,
MDPH, Twp.,
Commission.
U.S.EPA, MDNR
Citizens, MDNR,
Twp., LCHD, MDPH
U.S.EPA, MDNR
U.S.EPA, MDNR
LCHD, MDNR,
Twp. ,
Citizens, MDPH,
NUS, Fire Dept,
U.S.EPA
U.S.EPA, MDNR
U.S.EPA, MDNR
U.S.EPA, MDNR
U.S.EPA, MDNR
U.S.EPA, MDNR
-------
34
November 14, 1988
June 16, 1989
June 27, 1989
August 1989
August 21, 1989
October 30, 1989
February 8, 1990
May 18, 1990
July 18, 1990
July 24, 1990
July 31, 1990
August 31, 1990
August 31, 1990
September 13, 1990
October 31, 1990
December 5, 1990
CIC Meeting
Newsletter #15
(Mostly Spiegelberg Info)
Public Meeting on
Spiegelberg Removal,
Some Rasmussen Discussion
Establish Local Call-in
Newsletter #16
(Mostly Spiegelberg Info)
Newsletter #17
(Mostly Spiegelberg Info)
Informal Public Meeting
Newsletter #18
Newsletter #19
Newsletter #20
Informal Public Meeting
Proposed Plan Sent Out
PCP Open
Newsletter #21
U.S.EPA, MDNR
U.S.EPA, MDNR
U.S.EPA, MDNR
Citizens, LCHD,
Twp., PRP Rep.
MDNR
U.S.EPA, MDNR
U.S.EPA, MDNR
MDNR, U.S.EPA,
Citizens, LCHD,
Twp., PRP Rep.
U.S.EPA, MDNR
U.S. EPA, MDNR
U.S.EPA, MDNR
MDNR, U.S.EPA,
Citizens, LCHD,
Twp., PRP Rep.
U.S. EPA, MDNR
U.S.EPA, MDNR
Public Meeting on Proposed Citizens, LCHD,
Plan and FS MDNR, U.S.EPA,
PRP Rep.
PCP Closed
Newsletter #22
U.S.EPA, MDNR
U.S.EPA, MDNR
The items listed above, where appropriate, are in the
Administrative Record. All other items can be found as part of
the Michigan Department of Natural Resources, Environmental
Response Division, Superfund Section's Files. In addition,
correspondences with individual citizens and PRPs are contained
in the records. As part of the community relations efforts,
numerous Freedom of Information Act requests^.were filled, and the
-------
35
Information Repository received updated information when
available.
Key to Abbreviations for Attachment
Citizens
Commission
CIC
Fire Dept.
Hamburg Twp.
LCHD
MDA
MDNR
MDPH
Media
MSU
NUS
PCP
PIRGIM
PRP Rep.
Reps.
SCARE
SEMCOG
Senator
TSCC
Twp.
U Of M
U.S.EPA
WQB
- Local Citizenry
- Commissioner's Office
- Citizen's Information Committee
- Township Fire Department
- Hamburg Township Representative
- Livingston County Health Department
- Michigan Department of Agriculture
- Michigan Department of Natural Resources
- Michigan Department of Public Health
- Media Representatives
- Michigan State University
- State Contractor NUS Corporation
- Public Comment Period
- Public Interest Research Group of Michigan
- Representative of Potentially Responsible Parties
- State Representative's Office
- Safe, Clean and Revitalized Environment (Group)
- South(E)ast Michigan Council of Governments
- Representative of Senator's Office
- Toxic Substance Control Commission
- Green Oak Township Representative
- University of Michigan
- United States Environmental Protection Agency
- Water Quality Board
-------
APPENDIX A
COMPARISON OF FIELD AND LABORATORY BLANK SAMPLES WITH GRDUNDWATER
SAMPLE CONCENTRATIONS (IN PFB) FOR THE RASMUSSEN SITE
(TAKEN FROM RI REPORT RESULTS AND DATA VALIDATION PACKAGES)
MEXHYLENE CHLORIDE
RI GROONDWATER
SAMPLE ID
GW 001
GW 002
GW 003
GW 004
GW 004A
GW 0023
GW 0027
GW 0028
GW 0029
GW 0029A
GW 0040
TRAFFIC
KtHJKT
E9348
E9349
E9350
E9379
E9398
EF485
EF490
EF491
EF044
EF045
EF496
CASE GROUNDWATER SAMPLE
#
3675
3675
3675
4050
4050
4758
4758
4758
4964
4964
5155
CCNCENIWmCN
5 J
130
5 J
100 JB
150 B
3000 B
6500 B
10000 B
249 B
161 B
1100 JB
FIELD BLANK
CONCENTRATION
5 RJ
5 RJ
5 RJ
5 RJB
5 RJB
110 UJB
110 tUB
110 UJB
5 UJB
5 UJB
2 UJB
LABORATORY BLANK NOTES DATA VALID
CONCENTRATION
ND
ND
ND
ND
ND
12000
12000
12000
7
7
3
DUPLICATE
< 10X IB
< 10X IB
< 10X IB
> 10X IB
> 10X IB
> 10X IB
(Y OR N)
Y
Y
Y
Y
Y
N
N
N
Y
Y
Y
ACETONE
RI GROUNDWATER
SAMPLE ID
GW 004
GW 004A
GW 006
GW 008
GW 017
GW 040
TRAFFIC
REPORT
E9397
E9398
EA819
EC041
EC078
EF496
CASE
#
4050
4050
4174
4174
4361
5155
GROUNDWATER SAMPLE FIELD BLANK
CONCENTRATION
200 JB
200 B
110 B
26000 B
790
9500 B
CONCENTRATION
10 RJB
10 RJB
ND
ND
ND
11 UJB
LABORATORY BLANK
CC*CENTRATION
ND
ND
14
14
8.1
11
NOTES
DUPLICATE
< 10X IB
> 10X IB
> 10X IB
> 10X Ifi
DATA VALID
(Y OR N)
Y
Y
N
Y "
Y
Y
KEY TO NOTATIONS ON 3 RD PAGE.
-------
APPENDIX A vONTINUED
COMPARISON OF FIELD AND LABORATORY BLANK SAMPLES WITH GRCUNDWATER
SAMPLE CONCENTRATIONS (IN PPB) FOR THE RASMUBSEN SITE
(TAKEN FROM RI REPCRT RESULTS AND DATA VALIDATION PACKAGES)
BIS( 2HE1HXLHEXYL)FHDALKTE
RI GROUNDWATER
SAMPLE ID
TRAFFIC
REPORT
CASE GROUNDWATER SAMPLE
# CONCENTRATION
FIEID BLANK
CONCENTRATION
LABORATORY BLANK
CONCENTRATION
NOTES
DATA VALID
(Y OR N)
GW 005
GW 006
GW Oil
GW 029
GW 029A
GW 052
EC034
EA819
EC045
EF044
EF045
ED930
4126
4174
4174
4964
4964
5959
4
16 B
12 B
24
18
2 J
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ANOMALY
ANOMALY
DUPLICATE
Y
Y
Y
Y
Y
Y
2-BDTANONE
RI GROUNDWATER
SAMPLE ID
GW 001
GW 003
GW 004A
GW£08
GW 016
GW 017
GW 040
GW 079
TRAFFIC
REPORT
E9348
E9350
E9398
EC041
RASMU
EC078
EF496
EK850
CASE
#
3675
3675
4050
4174
RASM
4361
5155
7016
GROUNDWATER SAMPLE FIELD BLANK
CCNCENTRATTCN
60
46
600 J
74000 B
22 J
180
18000 B
11 RJB
OONCENTRATION
ND
ND
ND
ND
ND
12 UJB
11 UJB
ND
LABORATORY BLANK
OCJNCTNTRATTON
ND
ND
ND
8.2
ND
8.9
11
ND
NOTES
LOW RF
> UDX IB
HDID TIME
> 10X IB
> 10X IB
LOW RF
DATA VALID
(Y OR N)
. Y
Y
Y
Y
N
Y
Y
N
KEY TO NOTATIONS ON 3 RD PAGE.
-------
APPENDIX A CONTINUED
CCMPARESON OF FIELD AND LABORATORY BLANK SAMPLES WITH GROUNDWATER
SAMPLE CONCENTRATIONS (IN PPB) FOR THE RASMUSSEN SITE
(TAKEN FROM RE -REPORT RESULTS AND DATA VALIDATION PACKAGES)
KEY TO NOTATIONS
GW = GROUNDWATER
PPB = PARTS PER BILLION
RI = REMEDIAL INVESTIGATION
ND = NOT
LB = LAB BLANK
LOW RF - LOW RECOVERY FACTOR FOR LABORATORY SPIKE
DUPLICATE = DUPLICATE SAMPLE (eg. GW 004 AND GW 004A, GW004A IS THE DUPLICATE)
< 10X LB - RI DATA IS LESS THAN 10 TIMES LAB BLANK DATA, NOT VALID
> 10X LB = RI DATA IS GREATER THAN 10 TIMES LAB BLANK DATA, VALID
HOLD TIME = SAMPLE WAS NOT ANALYZED WITHIN REQUIRED TIME LIMIT AFTER COLLECTION
ANOMALY = DATA QUALIFIED BUT NO EVIDENCE OF WHY UPON REVIEW
DATA QUALIFIERS:
R = DATA IS UNUSABLE, COMPOUND MAY OR MAY NOT BE PRESENT
J = ASSOCIATED NUMERICAL VALUE IS AN ESTIMATED QUANTITY
U = ANALYZED FCR BUT NOT DETECTED
B » FOUND IN BLANK
UJ = ANALYZED, NOT LUlUL'mj, NUMERIC VALUE IS ESTIMATED AS QUALITY CONTROL NOT MET
-------
^APPENDIX B
DRAFT
LEAD
TYPE B CRITERIA
JUSTIFICATION AND RATIONALE
V
The recommendation for lead cleanup goals in residential areas is local
background for soil and 5 ppb for groundwater. Following is a discussion
of the health issues surrounding lead and justification for this
recommendat ion.
Lead has been classified by EPA as a probable human carcinogen based on
sufficient animal data. However, a quantitative estimate of carcinogenic
risk from oral exposure is not available. The following statement is
provided in EPA's Integrated Risk Information System (IRIS):
"Quantifying lead's cancer risk involves many uncertainties, some of
which may be unique to lead. Age, health, nutritional state, body
burden and exposure duration influence the absorption, release, and
excretion of lead. It is also felt that current knowledge of lead
pharmacokinetics indicates that an estimate derived by standard
procedures would not truly describe the potential risk. Thus, the
Carcinogen Assessment Group recommends that a numerical estimate not
be used."
Without a quantitative estimate of carcinogenic risk for lead, it is
impossible to calculate cleanup criteria according to routine procedures.
Lead is also a significant concern in terms of its noncarcinogenic
effects. Effects associated with lead toxicity include: 1) inhibition
of pyrimidine-5-nucleotidase (Py-5-N) and delta-aminolevulinic acid
.dehydrase (ALA-D) activity. Inhibition of ALA-D in the brain is
associated with the gamma-aminobutyric acid (GABA) neurotransmitter
system in various ways. 2) interference in heme synthesis throughout
the body. 3) interference with vitamin D metabolism. 4) changes in
electrophysiological functioning of the nervous system. 5) delays in
early cognitive and physical development of fetuses and young children.
6) deficits in IQs of children. The last two effects have been receiving
considerable attention latetly since these effects occur at very low
blood dose levels and since some of the neurobehavioral effects may not
be reversible. The following language appears in IRIS:
"By comparison to most other environmental toxicants, the degree of
uncertainty about the health effects of lead is quite low. It
appears that some of these effects, particularly changes in the
levels of certain blood enzymes and in aspects of children's
neurobehavioral development, may occur at blood lead levels so low
as to be essentially without a threshold. The Agency's Reference
Dose (RfD) Work Group discussed inorganic lead (and lead compounds)
at two meetings (7/8/85 and 7/22/85) and considered it inappropriate
to develop an RfD for inorganic lead."
-------
ArPENDIX B
DRAFT
EPA is considering an alternative to the RfD approach for lead. (The RfD
is a dose in units of mg/kg of body weight per day which is not expected
to cause any adverse noncarcinogenic health effects.) The alternative is
an Exposure Uptake Biokinetic Model which estimates a blood lead level
associated with specific exposure assumptions. EPA is also expected to
announce an acceptable blood lead level. With this information, the
hazards associated with a particular site can be determined. This model
will also allow us to estimate environmental concentrations which are
acceptable (based on an acceptable blood lead level).
In September of 1989, the Office of Solid Waste and Emergency Response
(OSWER) of EPA provided Interim Guidance on Establishing Soil Lead
Cleanup Levels at Superfund Sites. Their directive states that a soil
lead concentration of 500 to 1,000 ppm is considered protective for
direct contact at residential settings. This guidance is based on a 1985
recommendation by the Center for Disease Control (CDC). At the time of
the CDC publication, the blood lead level of concern was 25 ug/dl.
Recently CDC's Childhood Lead Poisoning Prevention Ad Hoc Advisory
Committee recommended that the toxicity threshold be lowered to 10 ug/dl
or more.
Until EPA provides updated guidance, an interim approach was developed to
estimate safe/acceptable soil concentrations for lead. Acceptable soil
concentrations were generated for three different residential
populations; children without pica, children with pica and the adult.- An
acceptable soil concentration was also developed for the industrial
scenario. The soil concentrations were calculated by plugging the
different exposure assumptions into the direct contact equation presented
in the 307 Rules. As a result, these concentrations are expected to be
protective for the ingestion and dermal absorption of contaminants in
soil. They do not address the issue of impact to the groundwater.
The toxicological endpoint for my calculations is an acceptable blood
lead level of 5 to 10 ug/dl based on the recommendation of the CDC
Committee. This was converted to an acceptable daily dose (mg/kg/day) by
using the following assumptions:
-average adult body weight is 70 kg
-average body weight of a 1-6 year old child is 16 kg
-blood volume for an adult is 56 dl
-blood volume for a child (1-6 years old) is 12.6 dl
-variation in sensitivity of the human population justifies the use
of a 10-fold uncertainty fac'-or rhich reduces the acceptable dose
by one-tenth
The above assumptions produce an acceptable daily intake (ADI) for lead
of 0.4 to 0.8 ug/kg/day for both adults and children. This ADI does not
take into account the carcinogenicity of lead. A discussion of the
exposure assumptions used for the soils calculations follows.
EPA has recommended using a soil ingestion rate of 200 mg/day for
children without pica and 100 rag/day for adults. For children with pica,
a rate of 1,000 mg/day is used which represents an upper range estimate
of children with a higher tendency to ingest soil materials. Assuming
-------
APPENDIX B
DRAFT
that children are exposed to soils only six months out of the year, the
average daily soil ingestion rate for children without pica is 100 mg/d
and 500 mg/d for children with pica. Assuming the same 6/12 month
exposure for adults, their daily soil ingestion rate becomes 50 mg/d.
The same soil ingestion rate was used for industrial workers to protect
those individuals that may be working outdoors on exposed soils. •
Assuming their exposure is for 5 out of 7 days and 6 out of 12 months
over 45 years, the average soil ingestion rate is 20 mg/d.
A "dermal dose of 0.5 g/d was used for children assuming the following:
-in the outdoor scenario, young children have 0.178 m2 of skin
exposed
(this includes hands, forearms and legs below the knees)
-5,120 mg soil comes into contact with each m2 of skin
-when indoors, 0.04 u>2 of skin (just hands) comes into contact..with
dust
-560 mg house dust contacts every square meter of skin
-SOX of house dust is composed of outdoor soils
Multiplying skin surface area by amount of soil on skin results in a
total of 911 mg outdoor soils and 22 mg indoor dust contacting the skin.
Assuming six months of exposure per year to outdoor soils and SOX of
indoor dust is composed of outdoor soils, the total amount of soil on
skin for the younger child is 691 mg. Divide this by 1,460 days (365
days X 4 years) and the final dermal dose for young children is 0.~5" '
grams/d.
A dermal dose of 1 gram/d for adults was derived using the following
assumptions:
-when gardening, adults have 0.197 square meters of skin exposed to
•-.,. - the
soil (hands and forearms)
-35,000 mg/m2 soil gets on the skin during gardening
-in the indoor situation, 0.082 m2 of skin (hands) comes into
contact with house dust
-560 mg/m2 house dust comes into contact with the hands
-SOX of house dust is comprised of outdoor soils
-adults garden 6 months out of the year, 2 days out of the week
These assumptions determine that over a 60 year period (excluding the
first 10 years of life) adults are exposed to 21,572 grams of outdoor
dirt and 806 grams of indoor dust. The total divided by 21,900 days
equates to an adult dermal dose of 1 gram/d.
For the industrial scenario, a dermal dose of 0.4 g/d was calculated
assuming that workers have 0.197 m2 skin surface area exposed (hands and
forearms) and 5,120 mg/m2 soil comes into contact with the skin.
Assuming exposure 5 out of 7 days and 6 out of 12 months over 45 years,
the final worker dermal dose can be calculated.
-------
APPENDIX B
DRAF
The resulting calculations and soil concentrations are presented below:
Children without pica: 0.4-0.8 ug/kg/d X 16 kg X 0.2 X 1000
[(0.1 g X 0.5) + (0.5 g X 0.01)] =-23-46 ppm
Children with pica: 0.4-0.8 ug/kg/d X 16 kg X 0.2 X 1000 V -
[(0.5 g X 0.5) + (0.5 g X 0.01)] = 5-10 ppm
Adults: 0.4-0.8 ug/kg/d X 70 kg X 0.2 X 1000
[(0.05 g X 0.5) + (1.0 g X 0.01)] =160-320 ppm
Industrial: 0.4-0.8 ug/kg/d X 70 kg X 0.2 X 1000
[(0.02 g X 0.5) + 0.4 g X 0.01)] =400-800 ppm
As discussed in the 307 Rules, the 0.2 value represents the assumption
that a person only receives 20X of their exposure to lead from soil.....The
value of 1000 is a conversion factor.
In order to protect children, the most sensitive subgroup of our
population, a soil cleanup criterion of background is recommended for
residential areas. In industrial situations, it may be appropriate to
accept a cleanup criterion of 400-800 ppm, if we can be assured that the
property will remain industrial.
As stated earlier, the above soil cleanup criteria do not consider^
potential impacts to groundwater. According to the 307 Rules, a soil
concentration no greater than 20 times the health-based groundwater
concentration is protective of the groundwater. However, a responsible
party can utilize the direct contact soil equation or some value between
the 20 times groundwater value and the direct contact value as a final
cleanup goal if a leachate test demonstrates that the resulting leachate
does not exceed the acceptable groundwater concentration. The
grouhdw£.ter concentration associated with an acceptable blood lead level
of 5-10 ug/dl in children is 1-3 ppb. For adults, an acceptable
groundwater concentration is 3-6 ppb. EPA has proposed an MCL of 5 ppb;
a final MCL has not yet been established. An acceptable range of
groundwater concentrations for lead is 1-6 ppb according to the method
discussed above. A final Type B groundwater criterion of 5 ppb is
recommended. This health-based value should be used unless it can be
demonstrated that local background is higher, in which case, background
will serve as the cleanup number.
In conclusion, several points warrant discussion and provide
justification for a conservative approach in dealing with the cleanups of
lead-contaminated sites. These points are: 1) lead has been classified
as a probable human carcinogen and there is currently no established
methodology to address this issue; 2) due to past and current exposures,
the population in Michigan already has a certain blood lead level. A
study conducted nationwide from 1976 to 1980 reported that the mean blood
lead level for the entire U.S. population is 13 ug/dl. This suggests
that further exposure to lead should be minimized as much as possible;
3) the threshold for noncarcinogenic effects of lead has not been
identified and may be so low that essentially it may not exist; 4) the
-------
APPENDIX B
DRAFT
neurological effects associated with low blood lead levels may not be
reversible; 5) significant exposure to lead occurs from the atmosphere.
As a summary, a soil cleanup criterion of background is recommended for
residential areas. In industrial situations, where we can be assured
that the property will remain industrial, it may be appropriate" • to'accept
a cleanup criterion of 400-800 ppm. The recommended groundwater cleanup
criterion for dissolyed lead is 5 ppb. If local background is greater,
background will serve as the final cleanup goal.
Pleae contact Christine Flaga, MDNR, Environmental Response Division for
further information. (517) 373-0160.
-------
APPENDIX 1 . .
RASMUSSEN ADMINISTRATIVE RECORD INDEX
-------
I
APPENDIX 2
RISK ASSESSMENT TABLES
RASMUSSEN CHEMICAL CONCENTRATIONS
BY AREA OF CONCERN
-------
TABLE 2-S
CONTAMINANTS DETECTED IN GROUNDWATER
RASMUSSEN DUMP SITE
Contaminant
acetone
2 butanon*
2 he«anone
4-melhyl-
2-pentanone
benzene
elhylben/ene
chlorobenzene
loluene
total nylenes
1.1,1 Kicliloroe lhane
l.l-dichloioeihane
leiidclilocoethcne
Irichlotoeihene
1.2 dichlorotMhtMie
1. l-dltltlulOVlllCne
Range of
Positive
Detections
(MS/I)
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Residential Wells
No of
Positive
Detectiom/
No of
Samples
Average
Concentration
(MB/I)
Wells in Plume -Shallow
Range of
Positive
Detections
110-
26.000
22-74.000
3,000-
3.100
300-
30.000
260-700
500-2.400
1,000-
3.700
18.000-
71.000
3.700-
11.000
99-500
6-550
2
8-500
240 590
2
No of
Positive
Detections/
No. of
Samples
6/14
S/14
2/14
9/14
S/14
S/14
S/14
S/14
S/14
S/14
7/14
1/14
S/14
4/14
1/14
Average
Concentration
(MO/I)
2.630
6.630
435
4.S20
161
S79
914
14,500
2.690
82
116
0.1
54
114
01
Background Wells - Shallow
Range of
Positive
Detections
(M9/I)
ND
46-60
ND
ND
ND
1
S
1-9
2
ND
ND
2
2-774
ND
ND
No. Of
Positive
Detections/
No of
Samples
2/59
1/59
1/59
4/59
1/S9
2/59
9/59
Average
Concentration
(ng/i)
2
002
008
03
0.07
20
Background Wells - Deep
Range of
Positive
Detections
(MO/I)
ND
11
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
No Of
Positive
Detections/
No of
Samples
1/9
Average
Concentration
(MO/|)
1
"
. -
08
oo
-------
TABLE 25
CONTAMINANTS DETECTED IN GROUNDWATEft
RASMUSSEN DUMP SITE
PACE TWO
Contaminant
vinyl chloride
chloroform
melhylene (hloride
liam-1.3 dichloio-
propene
phenol
2-methylphenol
4 methyl phenol
2.4-dimeihylpheiiol
2-chlorophenol
bii(2-elhylhe«yl)
phlhalale
di-n-butyl phlhalate
di n oclyl phlhalale
butyl benzyl
phlhalate
beniu(a)anlluaiene
tluytene
1 mini. in. IHII-
4 11,11.1
Range of
Positive
Detections
(MB*)
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
Ml)
lit)
Residential Wells
No ol
Positive
Detections/
No ol
Samples
Average
Concentration
(M9/I)
Wells in Plume - Shallow
Range ol
Positive
Detections
(M9/I)
96
1-5
100-t.lOO
34
17-62
260-1.600
70-280
14-27
12-17
12
21
NO
ND
NO
ND
ND
ND
No. ol
Positive
Detections/
No of
Samples
I/U
2/14
3/14
1/14
5/14
5/14
4/14
2/14
2/14
1/14
1/14
Average
Concentration
(MO/I)
7
04
96
2
10
277
44
3
2
09
2
Background Wells - Shallow
Range of
Positive
Detections
tug/I)
ND
NO
5- 10.000
NO
3-12
ND
ND
ND
NO
3-24
2-S
IS
3-7
3
3
2
4
No. of
Positive
Detections/
No. of
Samples
8/59
5/59
4/59
6/59
2/59
2/59
2/59
2/59
1/59
1/59
Average
Concentration
(ug/l)
340
06
08
03
0.1
02
01
0 1
003
007
Background Wells - Deep
Range of
Positive
Detections
(noyi)
ND
ND
NO
NO
8
ND
NO
ND
ND
2
ND
NO
ND
NO
NO .
ND
ND
No. of
Positive
Detections/
No. of
Samples
1/9
1/9
Average
Concentration
(MO/1)
0.9
02
•o
08
OQ
-------
TABLE 2-5
CONTAMINANTS DETECTED IN GROUNOWATER
RASMUSSEN DUMP SITE
PACE THREE
Contaminant
benioic acid
beniyl alcohol
isophorone
PCB-1260
dionin
bdfium
cadmium
chromium
copper
lead
nickel
ainc
Residential Wells
Range of
Positive
Detections
(M9/I)
ND
NO
ND
ND
ND
ND
ND
NO
8-9
NO
ND
48-950
No Of
Positive
Detections/
No. of
Samples
2/3
3/3
Average
Concentration
lug/I)
6
353
Wells in Plume -Shallow
Range of
Positive
Detections
-------
TABLE 2-6
CONTAMINANTS DETECTED IN SOIL
TOP OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
Contaminant
acetone
2-butanone
4 methyl -2-pentanone
benzene
ethylbenzene
chlorobenzene
toluene
tola! xylenes
styrene
tetrachloroelhene
irichloroethene
1,2 dichloroelhene
1. 1.2 irichlofoethane
1,1,1-uichloroethane
1,1 dichloroe thane
chloroform
meihylene chloride
Surface Soil*
Range ol Positive
Detections
(pg/kg)
30-300
30
330
6-11
17-1.600
6-980
8-1.700
77-5.300
48-590
10
6-42
6-8
42
9
6
6
96-450
No. of Positive
Detections/
No. of Samples
3/6
1/6
1/6
2/6
5/6
5/6
6/6
5/6
2/6
1/6
4/6
2/6
1/6
1/6
1/6
3/6
5/6
Average
Concentration
(Mg/kg)
57
5
55
3
458
259
363
1.900
106
2
14
2
7
2
1
3
181
Subsurface Soil/Waste**
Range of Positive
Detections
(Mg/kg)
32.000
120-100.000
6-7
6-160.000
100.000
6-300.000
12-2.700.000
5-1.400
6-7
7
18 !
111-10.000
No. of Positive
Detections/
No. of Samples
1/16
2/16
3/16
4/16
1/16
4/16
3/16
4/16
3/16
•
1/16
1/16
4/16
Average
Concentration
(pg/kg)
2.000
6,260
1
10.100
625
18,800
169.000
• 88.
. 1
0~4
;
1
701
-------
TABLE 2-6
CONTAMINANTS DETECTED IN SOIL
TOP OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
PAGE TWO
Contaminant
phenol
4-methylphenol
pentachlorophenol
bis(2 ethylhexyOphthalate
di-n-butyl phthalate
di-n-octyl phthalate
dimethyl phthalate
butyl benzyl phthalate
anthracene
benzo(a)pyrene
lluofanlhene
m(Jeiio( 1 . 2. i i il)|)ynTie
iitiplilhulene
2-methylnaphlhalene
phenanllueiie
(jyfcMi-
Surface Soil*
Range of Positive
Detections
(pg/kg)
500-2,300
500-1.700
2,000
700-14,000
1.600-10,000
119-1.400
218
500
SOO
9,300-13.000
500-4,000
500-1.000
No. of Positive
Detections/
No. of Samples
3/6
3/6
1/6
4/6
4/6
2/6
1/6
1/6
1/6
2/6
5/6
4/6
Average
Concentration
(|ig/kg)
550
633
333
3.430
2.970
253
36
83
83
3,720
1,230
417
Subsurface Soil/Waste**
Range of Positive
Detections
(pg/kg)
620
1,400
32.000
370-18.000.000
330-330.000
6.600
870-1.300
330-7.600.000
580
380-580
330-150,000
580-21.000
580-6.600
370-580
No. of Positive
Detections/
No. of Samples
1/16
1/16
1/16
11/16
5/16
1/16
2/16
7/16
1/16
2/16
4/16
3/16
2/16
3/16
Average
Concentration
(lig/kg)
39
88
2.000
1.350.000
24.800
412
. 136
479.000
36
60
-•9.490
. 1,390
•
449
83
-------
TABLE 2-6
CONTAMINANTS DETECTED IN SOIL
TOP OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
PAGE THREE
Contaminant
N-nitrosodiphenylamine
benzole acid
isophorone
carbon disulfide
aniline
1 ,2-dichlorobenzene
1 ,4-dichlorobenzene
hexachlorobenzene
PCB-1242
PCB-1248
PCB-1254
PCB-1260
4,4'-DDT
endrin
dioxin
Surf ace Soil*
Range of Positive
Detections
(ljg/kg)
500-3.000
2.000
3.000
6-215
160-61.000
330-870
270
0002-0024
No. of Positive
Detections/
No. of Samples
2/6
2/6
1/6
2/6
33/34
2/34
1/34
8/10
Average
Concentration
(Kg/kg)
583
667
500
37
16.500
35
8
0.007
Subsurface Soil/Waste* *
Range of Positive
Detections
tug/kg)
370-18.000
620-47.000
6-7
660
380
370-650
330
3.600-4.800
1.800-34.000
200-62.000
400-1.600
210
i
+
No. of Positive
Detections/
No. of Samples
6/16
2/16
2/16
1/16
1/16
3/16
1/16
4/21
3/21
12/21
2/21
1/16
Average
Concentration
fug/kg)
1.330
2.980
0.8
41
24
102
21
800
2.230
5,980
95
13
-------
TABLE 2-6
CONTAMINANTS DETECTED IN SOIL
TOP OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
PAGE FOUR
Contaminant
barium
cadmium
chromium (total)
chromium (hexavalent)
copper
lead
nickel
zinc
Surface Soil*
Range of Positive
Detections
(mg/kg)
107-508
2-14
15-129
+ +
9-19
66-357
11-30
90-321
No. of Positive
Detections/
No. of Samples
6/6
2/6
6/6
6/6
6/6
3/6
6/6
Average
Concentration
(mg/kg)
225
3
42
14
171
9
153
Subsurface Soil/Waste**
Range of Positive
Detections
(mg/kg)
16-2.120
2-39
8-1.010
+ +
13-554
9-1.440
7-108
31-1.630
No. of Positive
Detections/
No. of Samples
16/16
7/16
16/16
16/16
16/16
16/16
16/16
Average
Concentration
(mg/kg)
289
5
88
97
290
23
535
+ Dioxin was not detected in sample RAD-SS-049.
+ + Cr«* was nol detected in samples RA-SO-801 (waste); RA-SO-802. RA-SO-803.
Includes sumple numbeis: RA-SO 13; RA-SO-14; RA-SO-19; RA-SO-19A; RA-SO-20; RA-SO-33; RA-SO-77; RA-SO-78; RA-SO-79;
RA SO «0. KASO81. RA SO 82. RA-SO 83; RA-SO-84; RA-SO-85; RA-SO-85A; RA-SO-86; RA-SO-87; RA-SO-88; RA-SO-89;
RA SO 90. RA-SO-91. RA SO 92; RA SO 93; RA-SO-94; RA-SO-95. RA-SO-96; RA-SO-108; RA-SO-109; RA-SO-110; RA-SO-111;
RA SO 112. RA-SO-117; RA-SO-117A; RA-SO-802; RA-SO-803. RAD-SO-009; RAD-SO-010; RAD-SO-011; .-RAD-SO-012;
RAD SO 013. RAD SO 047, RAD SO-047D; RAD-SO-048; RAD-SO-049; RAD-SO-050.
Includes sample numbers: RA-TP-020; RA-TP-021; RA-TP-022; RA-TP-023; RA-TP-024; RA-TP-025; RA-TP-026; RA-TP-027;
RA TP 028. RA-TP-029; RA-TP-048; RA-TP-049; RA-TP-050; RA-TP-051; RA-TP-052; RA-TP-052A; RA-SO-097; RA-SO-098;
RA SO 099; HA SO-100. KA SO-101; RA-SO-801; RAD-SS-049.
Soul if NUS Coipuidlion. Seplenibei 1988
-------
TABLE 2-8
CONTAMINANTS DETECTED IN SOIL
SOUTH SLOPE OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
Contaminant
acetone
2-hexanone
benzene
chlorobenzene
ethylbenzene
toluene
total xylenes
tetrachloroethene
trichloroethene
methylene chloride
chloroform
bill 2 elliylliexyl)|)lHhjldle
di n bulyl phth.ilaie
di-n ociyl phihalate
buiyl benzyl pluhaluie
aceiiiiphihene
.iiilliliK.CHv.'
Surface Soil*
Range of
Positive
Detections
(pg/kg)
10
16
2
8
26
5-23
42
9
54-500
2-6
334-3.920
No. of Positive
Detections/
No. of Samples
1/6
1/6
1/6
1/6
1/6
5/6
1/6
1/6
5/6
2/6
5/6
Average
Concentration
-------
TABLE 2-8
CONTAMINANTS DETECTED IN SOIL
SOUTH SLOPE OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
PAGE TWO
Contaminant
.
benzo(a)anthracene
benzo(b)fluoranthene
benzo(k)fluoranthene
benzo(a)pyrene
chrysene
fluoranthene
Iluorene
naphthalene
2-methylnaphthalene
phenanthrene
pyrene
4-melhylphenol
2,4-dimethylphenol
carbon disullide
dibenzofuran
N-nitrosodiphenylamine
PCB I2b4
(lioxm
Surf ace Soil'
Range of
Positive
Detections
(no/kg)
500
500
500
4.500
500
20-59
500
14.000
0001-2 996
No. of Positive
Detections/
No. of Samples
1/6
1/6
1/6
1/6
1/6
2/6
1/6
1/6
9/9
Average
Concentration
(iig/kg)
83
83
83
750
83
13
83
2.330
048
Subsurface Soil**
Range of
Positive
Detections
(Mg/kg)
1.200
452
813
651
1.200
5.150
438
4.090
4.000
17-380
231
625
0.003-0.349
No. of Positive
Detections/
No. of Samples
1/4
1/4
1/4
1/4
1/4
1/4
1/4
1/4
1/4
4/4
1/4
I 1/4
7/7
Average
Concentration
(tig/kg)
300
113
203
163
300
1.290
HO
1.020
1.000 •
122
58
156
Oil
-------
TABLE 2-8
CONTAMINANTS DETECTED IN SOIL
SOUTH SLOPE OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
PAGE THREE
Contaminant
barium
cadmium
chromium (total)
chromium (hexavalent)
copper
lead
nickel
zinc
Surface Soil*
Range of
Positive
Detections
(mg/kg)
48-3,165
5-21
13-199
•••
16-244
51-1,200
12-40
139-1,360
No. of Positive
Detections/
No. of Samples
6/6
4/6
6/6
6/6
6/6
5/6
6/6
Average
Concentration
(mg/kg)
774
6
59
69
461
16
448
Subsurface Soil**
Range of
Positive
Detections
(mg/kg)
11-1,160
15
13-66
6-567
5-2.120
7-84
31-1,420
No. of Positive
Detections/
No. of Samples
4/4
1/4
4/4
4/4
4/4
4/4
4/4 .
Average
Concentration
(mg/kg)
302
4
39
149
542
28
378
+ Cr»6 was not detected in sample RA-SO-805.
• Include iuinple number* RA SO 015; RA-SO 035; RA-SO-036; RA-SO-037; RA-SO-037A; RA-SO-066; RA-SO-805; RAD-SO-008.
RAD SO 023. RAD SO 024. RAD-SO 025; RAD-SO 046; RAD SO-053; RAD-SO-054; RAD-SO-055; RAD-SO-056.
•• include-, ijmple numbers RA-SO 069; RA-SO 070; RA-SO-070A; RA-SO-071; RAD-SS-008; RAD-SS-023; 8AD-SS-023D;
RAD SS 024; KAD-SS 02i>; RAD-SS-046; RAD-SS-054.
Source: NUS Corporation. September 1988
-------
TABLE 2-9
CONTAMINANTS DETECTED IN SOIL
SOUTH BASE OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
Contaminant
acetone
2-butanone
ethylbenzene
chlorobenzene
toluene
total xylenes
trkhloroelhene
chloroform
methylene chloride
pentachlorophenol
bis(2 ethylhexyl)phthalate
naphthalene
2-methylnaphlhalene
pyrene
N-niuosodiphenylamine
benzole acid
PCB-1254
PCB-1260
dioxin
Surface Soil*
Range of
Positive
Detections
(no/kg)
15
10
13
7
5
32
S
5
150
500
500
500
2.000
9,900
0002-0089
No. of Positive
Detections/
No. of Samples
1/2
1/2
1/2
1/2
1/2
1/2
1/2
1/2
1/2
1/2
1/2
1/2
1/2
1/2
3/3
Average
Concentration
(pg/kg)
8
5
6
4
2
16
2
2
75
250
250
250
1.000
4.950
0.032
Subsurface Soil/Waste* *
Range of
Positive
Detections
(tig/kg)
6
3.300
6.900
370
470
180
+ •»•
No. of Positive
Detections/
No. of Samples
1/1
1/1
1/1
1/1
1/1
1/1
Average
Concentration
(ug/kg)
NA
NA
NA
NA
NA
NA
-------
TABLE 2-9
CONTAMINANTS DETECTED IN SOIL
SOUTH BASE OF MUNICIPAL LANDFILL
RASMUSSEN DUMP SITE
PAGE TWO
Contaminant
barium
cadmium
chromium (total)
chromium (hexavalent)
copper
lead
nickel
zinc
Surf ace Soil*
Range of
Positive
Detections
(mg/kg)
140-1.030
4
33-89
•»•
43
188-835
19
94-642
No. of Positive
Detections/
No. of Samples
2/2
1/2
2/2
1/2
2/2
1/2
2/2
Average
Concentration
(mg/kg)
585
2
61
22
512
10
368
Subsurface Soil/Waste**
Range of
Positive
Detections
(mg/kg)
175
25
55
325
13
153
No. of Positive
Detections/
No. of Samples
1/1
1/1
1/1
1/1
1/1
1/1
Average
Concentration
(mg/kg)
NA
NA
NA
NA
NA
NA
NA Not applicable
* Includes sample numbers RA-SO-004; RA-SO-016; RA-SO-804; RAD-SO-026; RAD-SO-027; RAD-SO 052.
• • Includes sample numbers RA-TP-053; RAD-SS-052; RAD-SS-052D.
+ Cr * 6 was not detected when analyzed in sample RA-SO-804.
+ + Dioxin was not detected in samples RAD-SS-052; RAD-SS-052D.
Source: NUS Corporation. September 1988
-------
TABLE 2-14
CONTAMINANTS DETECTED IN SOIL AND WASTE *
NORTHEAST BURIED DRUM AREA
RASMUSSEN DUMP SITE
Contaminant
acetone
2-butanone
4-methyl-2-pentanone
2-hexanone
benzene
ethyl benzene
chlorobenzene
toluene
total xylenes
styrene
tetrachloroethene
trichloroethene
1,1,1 -trichloroethane
1,1-dichloroethane
methylene chloride
phenol
bis(2-ethylhexyl)phthalate
di-n-butyl phthalate
di-n-octyl phthalate
butyl benzyl phthalate
fluorene
naphthalene
2-methylnaphthalene
phenanthrene
isophorone
Range of Positive
Detections
(ug/kg)
28-4,000,000
4,800-66,000,000
12,000-16,000,000
410,000-680,000
54,000
5-21,000,000
15-2,600,000
5-30,000,000
22-17,000,000
5,000-40,000,000
5-54,000
11-340,000
6-850,000
12-100,000
10,000-500,000
45,000
330-210,000
330-190,000
6,600-17,000
330-530,000
710,000
660-1,300,000
6,600-460,000
6,600-2,900,000
20,000-100,000
No. of Positive
Detections/
No. of Samples
18/18
11/18
8/18
2/18
1/18
15/18
15/18
15/18
16/18
3/18
3/18
6/18
5/18
2/18
10/18
1/18
11/18
13/18
2/18
12/18
1/18
14/18
10/18
9/18
3/18
Average
Concentration
(yg/kg)
613,000
2,100,000
1,380,000
60,600 —
3,000
1,850,000
429,000
3,980,000
4,780,000
2,280,000
3,000
30,900
53,900
5,560
76,500
2,500
25,700
23,100
1,310
62,900
39,400
140,000
40,900
181,000
7,830
-------
TABLE 2-14
CONTAMINANTS DETECTED IN SOIL AND WASTE *
NORTHEAST BURIED DRUM AREA
RASMUSSEN DUMP SITE
PAGE TWO
Contaminant
PCB-1254
PCB-1260
4,4'-DDT
dioxin**
barium
cadmium
chromium
copper
lead
nickel
zinc
Range of Positive
Detections
(ug/kg)
160-22,000,000
8,400-32,000
520
0.012-0.061
(mg/kg)
10-10,100
2-9
11-798
5-70
10-5,170
3-39
45-8,210
No. of Positive
Detections/
No. of Samples
18/18
2/18
1/18
4/5
18/18
10/18
17/18
18/18
18/18
18/18
18/18
Avterag'e
Concentration
(yg/kg)
2,570,000
2,240
29
0.027
(mg/kg)
1,660
3
219
33
1,470
17
1,580
* Includes sample numbers RA-TP-030; RA-TP-031; RA-TP-032; RA-TP-033; RA-TP-034;
RA-TP-03S; RA-TP-036; RA-TP-037; RA-TP-038; RA-TP-039; RA-TP-04Q; RA-TP-041;
RA-TP-042; RA-TP-043; RA-TP-044; RA-TP-045; RA-TP-046; RA-TP-047; RAD-SO-014;
RAD-SO-015; RAD-SO-016; RAD-SS-015; RAD-SS-016.
** Dioxin was analyzed in both surface and subsurface soil samples.
Source: NUS Corporation, September 1988
-------
TABLE 2-15
CONTAMINANTS DETECTED IN SOIL
INDUSTRIAL WASTE AREA
RASMUSSEN DUMP SITE
Contaminant
acetone
2-butanone
4-methyl-2-pentanone
benzene
ethylbenzene
chlorobenzene
toluene
total xylenes
styrene
telrachloroelhene
trichloroethene
1, 1,1 trichlofoethane
chloroform
methylene chloride
carbon disulfide
dichlorodilluoroineihane
pt'iU.K hlO(O|)!ieiiol
Surf ace Soil*
Range of
Positive
Detections
(ug/kg)
25
6
2-6
6
6
1
98-130
No. of Positive
Detection/
No. of Samples
1/3
1/3
2/3
1/3
1/3
1/3
2/3
Average
Concentration
(eg/kg)
8
2
3
2
2
03
76
Subsurface Soil/Waste* *
Range of
Positive
Detections
fug/kg)
86.000
240.000
160.000-300.000
9-150.000
4-1.500.000
5-1.700.000
50.000
7-12
9
10
29-99
44
10-110 '
3.978
No. of Positive
Detection/
No. of Samples
1/11
1/11
2/11 .
3/11
6/11
3/11
1/11
2/11
1/11
1/11
7/11
1/11
8/11
1/11
Average
Concentration
(tig/kg)
7.820
21.800
41.800
23,600
163.000
224.000
4.540
.2
0.8
09
~59
•4
34
361
-------
TABLE 2-15
CONTAMINANTS DETECTED IN SOIL
INDUSTRIAL WASTE AREA
RASMUSSEN DUMP SI l£
PAGE TWO
Contaminant
/
bis(2-ethylhexyl)phthalale
di-n-butyl phthalate
di-n-octyl phlhalate
bulyl benzyl phthalale
acenaphthylene
benzo(a)anthracene
benzo(b)lluoranthene
benzo(k)fluoranthene
benzo(a)pyrene
fluoranihene
naphthalene
2 melhylnaphlhalene
phenanthiene
lyrene
N-nilrusudiplienylannne
.•mime
l>f.U I2V1
dio«m
Surface Soil*
' Range of
Positive
Detections
(M9/kg)
1,400
500
260-2.300
1
No. of Positive
. Detection/
No. of Samples
1/3
1/3
2/3
Average
Concentration
(ng/kg)
467
167
853
Subsurface Soil/Waste* *
Range of
Positive
Detections
(MQ/kg)
137-24.000
330-6.600
8.900-110,000
3.499
1.043
1,159
1.159
759
1.043
32,000-35,000
3,100-7.000
148-6.600
1,033
13,000
566
5,200-4.800.000
No. of Positive
Detection/
No. of Samples
4/11
3/11
2/11
1/11
1/11
1/11
1/11
1/11
1/11
2/11
2/11
2/11
1/11
1/11
1/11
i 2/11
Average
Concentration
(tig/kg)
2.470
667
10.800
318
95
105
105
69
95
6,090
918
613
94
1.180 .-
51
437.000
-------
TABLE 2-15
CONTAMINANTS DETECTED IN SOIL
INDUSTRIAL WASTE PIT
RASMUSSEN DUMP SITE
PAGE THREE
Contaminant
barium
cadmium
chromium (total)
copper
lead
nickel
zinc
Surface Soil*
Range of
Positive
Detections
(mg/kg)
22
5
7
33
4-10
10-20
25-421
No. of Positive
Detection/
No. of Samples
1/3
1/3
1/3
1/3
3/3
2/3
3/3
Average
Concentration
(mg/kg)
7
2
2
11
7
10
157
Subsurface Soil/Waste**
Range of
Positive
Detections
(mg/kg)
8-35,000
2-546
4-11.300
6-7,340
3-132,000
6-3,800
15-280,000
No. of Positive
Detection/
No. of Samples
9/11
3/11
11/11
11/11
11/11 .
11/11
10/11
Average
Concentration
(mg/kg)
3.720
50 '
1.040
679
12,000
356
25,800
* Includes sample numbers RA-SO-17; RA-SO-21; RA-SO-65; RAD-SO-018.
"Includes sample numbers RA-SO-49; RA-SO-50; RA-TP-011; RA-TP-012; RA-TP-013; RA-TP-014; RA-TP-015; RA-TP-016; RA-TP-017;
RA TP 018; RA-TP-019.
1 Dioxin was not detected in sample RAD-SO-018.
Source: NUS Corporation. September 1988 . "
-------
TABLE 2-16
CONTAMINANTS DETECTED IN SOIL
PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREA (AFTER EXCAVATION)
RASMUSSEN DUMP SITE
Contaminant
acetone
2-buianone
4-methyl-2-pentanene
ethylbenzene
chlorobenzene
toluene
total xylenes
slyrene
telrachloroethene
I.I.I Irichloroellune
MK-lhylcllC lllloilde
c.irbon tJmilfitie
Surf ace Soil*
Range of
Positive
Detections
(pg/kg)
12
7.900-53,000
6.000-38.000
2-190.000
6-360.000
5-10
11
Jt>-I05
No. of Positive
Detections/
No. of Samples
1/16
3/16
2/16
12/16
4/16
2/16
1/16
3/16
Average
Concentration
(M9/kg)
0.8
15.100
2.750
12.700
27,900
0.9
0.7
12
Subsurface Soil/Waste**
Range of
Positive
Detections
(lig/kg)
45-6,950
49.063
2,822
25-261
65-344
43-248
59-2.655
6
5-7
16-864
18-36
65-124
No. of Positive
Detections/
No. of Samples
2/10
1/10
1/10
4/10
4/10
4/10
4/10
1/10
2/10
3/10
4/10
2/10 ~"
Average
Concentration
(ug/kg)
700
4.910
282
36
61
57
238
0.6
1
91
10
19
-------
TABLE 2-16
CONTAMINANTS DETECTED IN SOIL
PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREA (AFTER EXCAVATION)
RASMUSSEN DUMP SITE
PAGE TWO
Contaminant
bis(2-ethylhexyl)phthalate
di-n-butyl phthalate
di-n-octyl phthalate
diethyl phthalate
butyl benzyl phthalate
naphthalene
2-methyl naphthalene
phenanthrene
N-nitrosodiphenylamine
benzoic acid
PCB-1254
dioxin
Surf ace Soil*
Range of
Positive
Detections
(tig/kg)
368-1,552
42-22,000
82
58-130
72-30.000
52-100.000
70-31.000
65-7,500
40-24,000
36.000
310-16.000
0008-0.019
No. of Positive
Detections/
No. of Samples
5/16
6/16
1/16
2/16
5/16
4/16
4/16
4/16
6/16
1/16
6/16
2/4
Average
Concentration
(pg/kg)
280
1.900
5
12
2.886
7,650
2.570
616
1.910
2,250
1,740 .
0.007
Subsurface Soil/Waste* *
Range of
Positive
Detections
(pg/kg)
370-800
48-330
56-180
176
117
607
No. of Positive
Detections/
No. of Samples
2/10
2/10
4/10
1/10
1/10
1/10
r
Average
Concentration
(pg/kg)
117
38
46
18
«.
12
61
-------
TABLE 2-16
CONTAMINANTS DETECTED IN SOIL
PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREA (AFTER EXCAVATION)
RASMUSSEN DUMP SITE
PAGE THREE
Contaminant
barium
chromium
copper
lead
nickel
zinc
Surf ace Soil*
Range of
Positive
Detections
(ng/kg)
(mg/kg)
11-37
7-13
10-12
4-14
8-12
27-43
No. of Positive
Detections/
No. of Samples
3/7
3/3
3/3
3/3
3/3
3/3
Average
Concentration
(pg/kg)
(mg/kg)
20
10
11
8
10
33
Subsurface Soil/Waste* *
Range of
Positive
Detections
(ng/kg)
(mg/kg)
7-21
3-10
6-17
3-7
6-12
18-38
No. of Positive
Detections/
No. of Samples
10/10
10/10
10/10
8/10
8/10
10/10
Average
Concentration
(M9/kg)
(mg/kg)
11
6
9
3
6
27
Includes sample numbers RA-SO-40; RA-SO-118; RA-SO-119; RA-SO-120; RA-SO-121; RA-SO-122; RA-SO-123; RA-SO-124;.
RA-SO-125; RA-SO-125A; RA-SO-126; RA-SO-128; RA-SO-130; RA-SO-132; RA-SO-134; RA-SO-135; RAD-SO-019; RAD-SO-020;
RADSO-021; RAD-SO-022. • .
Includes sample numbers RA-SO-43; RA-SO-44; RA-SO-45; RA-SO-51; RA-SO-72; RA-SO-073; RA-SO-127; RA-SO-127A; RA-SO-129;
RA-SO-131;RA-SO-133;.
Table 2-16 does not include 2 sample locations (RA-SO-38 and RA-SO-39) that were destroyed by excavation activities in June 1987.
Source: NUS Corporation, September 1988
-------
Y
APPENDIX 3 -
1989/1990 TECHNICAL MEMORANDUM
SUPPLEMENTAL SOILS INVESTIGATION - PDSLD
-------
MICHIGAN DEPARTMENT OF NATURAL RESOURCES
INTEROFFICE COMMUNICATION
March 26. 1990
TO: Rasmussen Site File
. • - *
FROM: Jim Myers, SMU 2, Superfund Section
SUBJECT: Technical Memo Rasmussen Dump Site Excavation Area Soil
Investigation
Attached is the summary of the field activities at the Rasmussen site from
December 14, 1989 to January 9, 1990. Included in this report are results
and conclusions from the above activities.
cc: Ms. Denise Gruben
Ms. Claudia Kerbavy
Mr. Ray Milejczak
'/
1 '030
-------
Y
TECHNICAL MEMORANDUM
RASMUSSEN DUMP SITE EXCAVATION AREA
SOIL INVESTIGATION
DECEMBER 14, 1989 - JANUARY 9, 1990
ENVIRONMENTAL RESPONSE DIVISION
MICHIGAN DEPARTMENT OF NATURAL RESOURCES
STATE OF MICHIGAN
MARCH 1990
-------
TABLE OF CONTENTS
SECTION
I.
II.
III.
IV.
V.
APPENDIX 1.
APPENDIX 2.
APPENDIX 3.
APPENDIX 4.
APPENDIX 5.
APPENDIX 6.
Introduction. l
Sanpling Protocol and Procedures 4
Field Activities 7
Results 10
Conclusions 18
Field Notes
Field Screening Methods
Soil Boring Logs
PCB Analyses Results
PCB CLP Analyses Results
Field Screening Results
LIST OF FIGURES
FIGURE
1. Site Hap. 5
2. Variations in Concentration with Depth in soil for:
a)Substituted Benzenes; b) Volatile Organics. Location:
RAB-A 19
3. Variations in Concentration with Depth in soil for:
a)5uLstituted Benzenes; b) Volatile Organics. Location:
RAB-C 20
4. Variations in Concentration with Depth in soil for:
a)Substituted Benzenes; b) Volatile Organics. Location:
RAB-D 21
5. Variations in Concentration with Depth in soil for:
a)Substituted Benzenes; b) Volatile Organics. Location:
RAB-F 22
6. Variations in Concentration with Depth in soil for:
a)Substituted Benzenes; b) Volatile Organics. Location:
RAB-1 23
7. Cross-section Rasraussen Site, PCE in Soils 24
8. Cross-section Rasnussen Site, Chlorobenzene in Soils......25
9. Cross-section Rasmussen Site, Total Xylenes in Soils 26
ii
-------
LIST OF TABLES
Y
TABLE
1. Target Organic Oonpcxmds 2
2. Target PCBs 3
3. PCS Results 10
4. Field Screening Results 11
111
-------
SECTION I
The Rasmussen site is located in Green Oak Township, Livingston County,
Michigan. Between 1984 and 1989 the Michigan Department of Natural'' '
Resources (MDNR) and the U.S. Environmental Protection Agency (EPA)
conducted a Remedial Investigation and Feasibility Study (RI/FS) in
accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA). In June, 1987, approximately 7,000 cubic yards of
soil were excavated for use as residental and commercial construction
materials off -site. This soil was returned to the Rasnussen site
(November, 1987 thru July, 1988) under court order.
The initial RI soil sampling (1984) in and near the excavation indicate
that high levels of volatile organic hydrocarbons (VOC's) and PCB's exist _
directly adjacent to the excavation. Analysis of groundwater samples
collected from existing monitoring wells on site indicated groundwater
contamination directly beneath the excavated area.
Contaminants found in the soil and groundwater in the vicinity of the
excavation included the following:
Maximum Concentration
Compound Soilfmg/RcQ Groundwater(mg/L)
toluene 71.0 290
xylene 9.1 760
ethylbenzene 2.4 160
chlorcbenzene 3.7 110
2-butanone 74.0
PCB's 5.2
napthalene 35.0
Further sampling of this area, now reffered to as the "Ramsey Excavation",
was conducted by Warzyn Engineering Inc. (Warzyn) in July, 1987. This
included sampling of surface and subsurface soils in and near the excavated
area. Analyses of these samples consisted of VOC's, acid/base neutral
fraction, and pesticide/PCB fraction. The results of this phase of
sampling and analysis identified the excavation as part of an area where
drums were once stored, and possibly leaked contaminants to the soil. The
excavation and vicinity was renamed the Probable Drum
Storage/Leakage/Disposal
(PDSLD) area.
In order to further define the extent of the PDSLD, additional sampling was
conducted by NUS in the excavation area and several areas throughout the
Speigelberg/Rasroussen properties. This included surface and subsurface
soil sampling, with field screening for selected organics (Table 1.), by
NUS, and laboratory analysis for PCB's (Table 2.)» by W.W. Engineering and
Science (W.W.).
-------
Table 1. Target Organic compounds for Field Screening.
Organic Analyses
1,2-Dichlorobenzene
Chloroform
1,1 -Dichloroethane
1.3-Dichlorobenzene
1.1 -Dichloroethene
trans- 1,2-Dichloroethene
Methylene chloride
Tetrachloroelhene
1.1.1 -Trichloroethane
Trichloroethene
Benzene
Chlorobenzene
Elhyl benzene
Toluene
Xylenes*
Theortho, meta. and paraisomersof
xylene will be resolved individually to the
degree allowed by the
instrument.detector, and
chromatographic column used.
-------
Table 2.
Target PCS Compounds
PCS Analyses
1016
1221
1232
1242
1248
1254
1260
This Technical Memorandum summarizes the PDSLO area investigation, which
was conducted from December 14, 1989 to January 9, 1990. The memorandum
documents all site activities conducted by NUS, and reports all analytical
results from this study. All previous sampling efforts and reports have
been considered in the conclusions regarding the nature and extent of the
contaminants in the POSLD.
-------
Figure 1. ? Nap
£&&*<+++
.:--».- ~~
LEGEND
RAMSEY EXCAVATION
PROBABLE DRUM STORAGE,
LEAKAGE. DISPOSAL AREA
RAB-B SAMPLED LOCATION
-------
Prior to sampling for Selected Organic Field Soeening, all sampling
equipment was decontaminated using liquinox in potable water, followed by a
distilled water rinse. Between samples, all sampling spatulas were
decontaminated using procedure documented above, followed by a distilled
water rinse. Excess water was then shaken from the equipment and allowed
to air dry. When necessary, clean paper towelling was used to dry
'* "
Disposable wooden spatulas were used for all PCS sampling. These spatulas
were disposed of after one use.
Selected Oranics S^rrlin and Field
Selected organics field serening samples were collected in a 200 mL, wide
mouth glass jar. Soil was sampled from the length of the split barrel
sampler. Samples were analyzed daily by gas chromatography in a mobile lab
located at the VFW Hall, near the site. The method of analysis and quality
assurance and quality control procedures are documented in the work plan—
(see appendix 2.). Validation of this data was performed by NUS.
Samling and
Samples were collected from the length of the split barrel sampler in a 250
mL glass jar and stored in iced coolers until further processing. Twice
daily, sample jars were sealed with a custody seal, logged in on a Chain of
Custody Record, sealed in a plastic bag, and placed in a cooler on ice,
which was in turn sealed with a custody seal, until delivery to W.W.
Engineering and Science within 7 days. All PCS samples were analyzed
according to EPA method 8080. Validation of this data was performed by
W.W. Engineering and Science.
-------
SHCmCM TTT
FIELD ACTIVITIES
I
Field activities were performed at the site from December 14, 198$t.thru
January 10, 1990. Soil, VOC, and PCB sampling was performed during this
period.
The following personnel were present at the site on the dates given:
MDNR:
Deni.se Gruben
Ray Mile jczak
Jim Myers
NUS:
Dan Hamel
Roy Oonley
Tim Mayotte
Stearns Drilling Co.:
Kelly Ruhlman
Gary Geerligs
Duane Daverman
Darryl Krause
Jim Gryska
12/14/89 - 1/2/90, & 1/10/90
12/14/89 - 12/21/89 & 1/8/90
12/26/89 - 1/9/90
12/14/89 - 1/10/90
12/14/89 - 1/5/90
1/5/90 & 1/8/90
12/14/89 - 12/21/89
12/14/89 - 12/21/89
12/26/89 - 1/10/90
12/26/89 - 12/28/89
1/2/90 - 1/10/90
The following outline documents daily activities on the site.
All sample depths subject to lithologic confirmation.
Underlined samples indicate PCB analysis
* indicates selected organics field screening
12/14/89
12/14/89
12/15/89
location
SPMW-5D
SPB-13
RAB-I
12/18/89
RAB-F
Sample Depth (ft. below grade 1/Paiciii>eLers
4.5-6, 14.5-16, 19.5-21, 24.5-26,
29.5-31, 34.5-36
0-0.7, 2.5-4.0, 5.0-5.6, 8.5-10.0
0-1.0*. 1.5-3, 3-4.5*. 4.5-6. 6-7.5*.
7.5-9, 9-10.5*. 10.5-12, 12-13.5*r 13.5-15,
15-16.5*. 16.5-18, 18-19.5*. 19.5-21*.
25-26.5*. 30-31.5*. 35-36.5*f 40-41.5*.
41.5-43, 43-44.5*. 44.5-46
0-1.5*f 1.5-3, 3-4.5*. 4.5-6, 6-7.5*.
7.5-9, 9-10.5*. 10.5-12, 12-13.5*. 13.5-15,
15-16.5*. 16.5-18, 18-19.5*. 19.5-21*.
25-26.5*. 30-31.5*f 35-36.5*. 40-41.5*.
41.5-43, 43-44.5*. 44.5-46, 46-47.5*.
47.5-49, 49-50.5*. 50.5-52, 52-53.5*.
53.5-55, 55-56.6*r 58-59.5*
-------
12/19/89
RAB-E
12/20/90
RMW28D
12/20-21/89 RMW17
12/26/89
RAB-G
12/27/89
RAB-H
1/2/90
1/3/90
1/3-4/90
RAB-A
RAB-C
RAB-D
1/4-5/90
1/8/90
1/8/90
1/9/90
RAMTC.8D
SFMW20D
SFMW15
SPB15
0-1.5, 1.5-3, 3-4.5, 4.5-6, 6-7.5,
7.5-9, 9-10.5, lp.5-12, 12-13.5, 13.5-15,
15-16.5, 16.5-18, 18-19.5, 19.5-21, 21-22.5,
25.5-27, 27-28.5, 28.5-30, 30-31.5, 31.5-33,
33-33.85
3.5-5, 8.5-10, 13.5-15, 18.5-20, Y •
23.5-25, 28.5-30, 33.5-35, 38..5-40, 43.5-45
3.5-5.0, 8.5-10, 13-15, 18.5-20,
23.5-25, 28.5-30, 33.5-35, 38.5-40
0-0.75, 1.5-3, 3-4.5, 4.5-6, 6-7.5,
7.5-9, 9-10.5, 10.5-12, 12-13.5, 13.5-15,
15-16.5, 16.5-18, 18-19.5, 19.5-21, 24.5-26,
29.5-31, 34.5-36, 39.5-41, 41-42.5, 42.5-44,
44-45.5, 45.5-47, 46-48.5, 49-50.5, 50-51.5,
54.5-56
0-1.5, 1.5-3, 3-4.5, 4.5-6, 6-7.5,
7.5-9, 9-10.5, 10.5-12, 12-13.5, 13.5-15,
15-16.5, 16.5-18, 18-19.5, 19.5-21, 24.5-26,
29.5-31, 34.5-36, 39.5-41, 41-42.5, 42.5-44,
44-45.5, 45.5-47, 47-48.5, 48.5-50, 50-51.5,
51.5-53, 54.5-56
0-1.5*. 2-4, 4-5*. 5-6*. 6-8*r 8-10*.
10-12*. 12-14*. 14-16, 33-35*
0-2*. 2-4, 4-6, 6-8*. 8-10, 10-12,
12-14*. 14-16*. 17-19, 18-20*. 20-22, 22-24,
24-26*. 27-28, 28-30, 30-32*. 32-34, 34-36,
35-37*
0-1.5*. 1.5-3, 3-4.5*. 4.5-6, 6-7.5*.
7.5-9, 9-10.5*. 10.5-12, 12-13.5*. 13.5-15,
15-16.5*. 16.5-18, 18-19.5*. 19.5-21*.
25-26.5*. 30-31.5*. 35-36.5*. 40-41.5*.
41.5-43, 43-44.5*. 44.5-46, 46-47.5*.
47.5-49, 49-50.5*. 50.5-52, 52-53.5*.
53.5-55*
19-21*. 24-26*. 29.5-31, 34-36, 44-45.5,
49-50.5, 54-55.5
4.5-6, 9-11, 14-16, 19-21, 24-26, 29-31,
34-36, 39-41, 44-46, 49-51
4-6, 6-8, 9-11, 14-16, 19-21, 24-26,
29-31
0-1.5, 1.5-3, 3-4.5, 4.5-6, 6-7.5,
7.5-9, 9-10.5, 10.5-12, 12-13.5, 14-15.5,
19-20.5, 24-25.5, 29-31.5":
8
-------
1/9/90 RMW-23D 0-1.5, 1.5-3, 3-4.5, 4.5-6, 6-7.5,
7.5-9, 9-10.5, 10.5-12, 12-13.5, 13.5-15,
15-16.5, 16.5-18, 18-19.5, 19.5-21, 21-22.5,
22.5-24, 24-25.5, 25.5-27, 27-28.5, 28.5-30,
34-36.5, 39-40.5, 44-45.5, 49-50.5, 54-55
Y
-------
SBCTKH IV
Results of the soil sampling and chemical analyses are presented iiiithe-
following tables and appendicies. This includes HNu readings, boring logs,
selected organics field screening, PCB analysis.
HNU readings taken in the field at the the time of sample collection are
listed in Appendix 1.
Due to the fact that seme of this work was done to replace previously
completed work, only boring logs for new borings and and those replacement
borings that differed significantly from the original boring logs were
supplied by NUS. Boring logs for all locations, either original or new,
are attached (Appendix 3).
The analytical results of the PCB analysis were supplied by W.W. PCBs were
detected in five samples. These five samples were aisr> analyzed under the
contract laboratory program (CLP) criteria. Table 3 is a listing of the
results of the initial PCB analysis and the CLP criteria analysis for those
samples where PCB's were detected. The results of all PCB analysis are
included in Appendicies 4 and 5.
Table 3. PCB Measurements in Soils
Sample
location (depth)
RAB-C (0-2)'
RAB-D (0-1.5')
RAB-F (0-1.5')
RAB-F (3.0-4.5')
RAB-I (1.5')
Initial Analysis
Gone, (ppb)
160
1,200
200
200
180
CLP Analysis
Cone, (ppb)
180
1,000
280
170
190
The analytical results of the selected organics field screening were
supplied by NUS. Raw data sheets, GC retention time displays, and quality
control reports are included in Appendix 6. Copies of these documents are
maintained in NUS and MDNR files and have been supplied to the potentially
responsible party's designated representative. Table 4 is a listing of the
analytical results of the selected organics field screening of samples from
the Spiegelberg and Rasnussen sites.
10
-------
Table 4. ANALYTICAL RESULTS (ug/kg)
SPIEGELBERG AND RASMUSSEN DUMP SITES
BORING RAB-A
Depths (ft)
Methylene Chloride
1,1-Dichloroethene
1,1-Oichloroethane
trans- 1 ,2-Dichloroethene
Chloroform
1,1,1 -Trichloroethane
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Chlorobenzene
Ethyl benzene
o-Xylene
m.p-Xylenes
1 ,3-Oichlorobenzene
1 ,2-Dichlorobenzene
0-2
2U
1U
ID
1U
2U
1.7
1U
1U
1U
1.4
1.3
3.4
1.9
1.8
2.0
2U
2-4
2U
)U
1U
1U
2U
2.0
1U
1U
1U
1.4
1.4
1.7
1.7
1.8
2U
2U
4-6
2U
1U
1U
111
2U
6.2
1.8
1U
iu:
2.8
1.3
1.8
1.8
1.7
2U
2U
6-8
2U
IU
1U
IU
2U
2.4
IU
IU
IU
1.6
1.2
IU
1.6
1.4
2U
2U
8-10
2U
IU
IU
IU
2U
IU
IU
IU
IU
1.8
1.3
1.4
1.7
1.4
2U
2U
10-12
2U
IU
1U
IU
2U
2.0
1U
IU
IU
1.6
1U
1U
1.6
1.3
2U
2U
12-14
i .
2U
IU
IU
IU
2U
10P
2.0
IU
IU
1.6
IU
IU
1.4
1.3
2U
2U
33-35
2U
IU
3.3
IU
2U
8.2
3.6
2.0
.IU
2.2
5.6
IU
1.8
1.5
2U
2U
-------
Table 4. ANALYTICAL RESULTS (ug/kg) •
SPIEGELBERG AND RASMUSSEN DUMP SITES '
BORING RAB-C
Depths (ft)
Mcthylene Chloride
1,1-Oichloroethene
1,1-Dichloroethane
trans- 1,2-Oichloroethene
Chloroform
1.1. 1 -Trichloroethane
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Chlorobenzene
Ethylbenzene
o-Xylene
m.p-Xylenes
1 ,3-Oichlorobenzene
1,2-Oichlorobenzene
0-2
2U
1U
1U
1U
2U
2.0
1U
1U
3.7
1.7
1U
1.4
1.8
1.4
2U
2U
6-8
2U
1U
1U
1U
2U
1U
1U
iu
8.5
1.4
1U
IU
1.4
1.2
2U
2U
6-8
(dup)
2U
IU
IU
IU
2U
2.4
tu
IU
6.4
1.5
IU
IU
1.4
1.2
2U
2U
12:14
2U
1U
IU
IU
2U
6.1
IU
IU
IU
5.08
94
37
140
110
2U
2U
14-16
250U
12SU
12SU
125U
250U
110
125U
12SU
250
3608
2200
1300P
4200
3000
250U
250U
18-20
125U
62U
62U
62U-
125U
62U
62U
62U
62U
838
620
500P
1400
1000
125U
125U
24-26
500U
250U
250U
250U
500U
250U
250U
250U
500
29008
4800
3600
9200
6800
500U
500U
30-32
V -
250U
125U
125U
125U
2SOU
125U
12SU
125U
450.
1400
3000
1900
4800
3500
250U
250U
35-37
500U
250U
250U
250U
sobu
250U
2SOU
250U
250U
4208
1400
1800
2800
1900
500U
500U
-------
Table 4. ANALYTICAL RESULTS (ug/kq)
SPIEGELBERG AND RASMUSSEN DUMP SITES
BORING RAB-O
Oeptht(ft)
Melnytene Chloride
i.l-Oi
-------
Table 4. ANALYTICAL RESULTS (u
SPIEGELBERG AND RASMUSSEN DUMP SITES
• BORING RAB-F
0«pttn(ft)
Methyler* Chloride
1.1-Oichlorotthene
t.l-Dichloroethane
tram- 1 ,2-Oichloroethene
Chloroform
t.l.l-Tri
-------
Table 4
ANALYTICAL RESULTS (u
SPIEGELBERG AND RASMUSSEN DUMP SITES
BORING RAB-I
OtptMft)
Mclhytcnt CMorid*
1.l-0«
-------
Table 4. ANALYTICAL RESULTS (ug/kg) '
SPIEGELBERG AND RASMUSSEN DUMP SITES -
BORING RAMW-18D
Depths (ft)
Methylene Chloride
1,1-Oichloroethene
1,1-Oichloroethane
trans- 1 ,2-Oichloroethene
Chloroform
1 . 1 , 1-Trichloroethane
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Chlorobenzene
Ethyl benzene
o-Xylene
m.p-Xylenes
1 ,3-Dichlorobenzene
1.2-Dichlorobenzene
19-21
2U
1U
1U
1U
2U
1U
>U
1U
1U
1.3
1.6
1.2
1.3
1.2
2U
2U
24-26
2U
1U
1U
1U
2U
1U
1U
'U
1U
1.8
1U
1U
1.3
1.4
. 2U
2U
-------
Table 4. ANALYTICAL RESULTS (ug/kg)
SPIEGELBERG AND RASMUSSEN DUMP SITES
RINSATE SAND
Number
Methylene Chloride
t,l-Dichlor6eth«n«
1,1-Di
-------
SBCTEQN V
Graphs of concentration of various species with depth for borings*, ..
RAB-A,C,D,F,I are illustrated in Figures 2 through 6. From the data and
these Figures, the following conclusions were drawn:
1) 1,1,1-Trichloroethane (TCA) is widespread (borings RAB-A,C,D,F,I) and
distributed throughout the soil column. Concentrations range from 110
to 0 ppb.
2) Tetrachloroethene (PERC) is present in borings RAB-C and RAB-D, and
distributed throughout the soil column. Concentrations range from 500
to 0 ppb.
3) Substituted benzenes (chlorobenzene, ethylbenzene, toluene, and
xylene) are present in RAB-C,D,F and concentrated at or directly above
(within 25 feet) the water table. The Concentration ranges and action
levels are:
Compound Range (ppb)
Chlorobenzene 4,800 to 0
Ethylbenzene 3,600 to 0
Toluene 2,900 to 0
Xylene 16,000 to 0
4) Dichlorobenzenes (both 1,2-dichlorobenzene and 1,3-dichlorobenzene)
are present in RAB-D with 15 feet of the water table. Concnetrations
range from 440 to 0 ppb.
5) At locations RAB-A and MCL8D substituted benzenes are present
throughout the soil column at concentrations on the order of 1 ppb.
Due to the limited number of boring locations in the PDSLD, it is difficult
to determine the spatial extent of contaminants in the soil. Figures 7
through 9 are soil cross-sections of Concentration for perchloroethene,
chlorobenzene and toluene, respectively. Additional soil borings are
necessary to accurately determine the spatial extent of the PDSLD.
Polyrhlororated biphenyls (Aroclor-1254) were detected in five samples at
four locations. The greatest depth of occurance is 3.0 to 4.5 feet in
boring RAB-I. Concentrations range from 1.2 to 0.16 ppb. PCBs were not
founds at depth in the soil column in the PDSID.
18
-------
Figure 2. Variations in Concentration with Depth in the Soil for:
a) Substituted Benzenes; b) Volatile Organics.
a)
Location RAB-A
I
o
•a
f
u
j
• O toluan*
Ct—banzano
b)
Location RAB-A
u
Depth from 940*
1.1.1-TCA
TCE
-------
Figure 3. Variations in Concentratio with Depth in the Soil for:
a) Substituted Benzenes; b) Volatile Organics.
a)
Location RAB-C
-3
s,
V 3
£ «
ffi
u
J
10 -
15 -
14 -
13 -
12 -
11 -
10 -
9 -
8 -
7 -
6 -
8 -
4 -
3 -
2 -
1 -
0 -
^
a
•*
a
*-
T
f>
£
O
••.*.'... i , .
i' \
* i
,. . i
' *rtl
ff
D
•,. .•*
-1
.A I
A / / \,
/ M
' ' ' ' t
i X- » •' \
\ • . ''x 1 A
' 1 ' •/ X A ^ X 1
' k' ' /^i^. N+x l""
• *s /' / ^V'YW XJ^
' ' S x / cJ-L 1 s?
-
-
0 20 40 60
Dopth from 940*
Q Toluene + Cl-bonzano * Et-bonzano A Xyt«n«
b)
£
N.
\gf
§
a
£
u
J
Location RAB-C
500 —i
400 -
300-
200 -
100 -
0 -
a
>
a
T
c
6
0
i
V
' 'v 1
' Y
i '
1
.' 1 1 rH
. JQ
' 1 eS
.' »• . u
1 .Id)
Ij
f ' i (Q
1 1 X
A ' '1
? 1
> '
, ' '
« • '.
\ ' I1
' n n 1 n
•y\/ '•
0 20 40 60
Depth from 940'
a 1.1,1-TCA O PERC
-------
Figure 4. Variations in Concentration with Depth in Soil for:
a) Substituted Benzenes; b) Volatile Organics.
a)
u
o
u
4
3 -
2 -
1 -
rti
u
Q Toluene
Location RAB-D
1. .
20
Ccpth from 940*
d-banzan« O Et-bcnzen*
b)
O)
\^
o
a
c
u
200
Location RAB-0
20
Q 1.1.1-TCA
Oapth from 940'
+ TCE
« PERC
-------
Figure 5. Variations in Concentration with Depth in the Soil for:
a) Substituted Benzenes; b) Volatile Organics.
a)
Location RAS-F
i '
i?
^
§i
II
V
u
s
u
a Taluana
b)
^%
•
<
oi
+^
c
o
a
!
u
3
j.o -
3 -
2.5 -
2 -
1.5 -
1 -
0.5 -
- p-Tfr
•' ' . «\-
• ' . | , v
. i »
4 '
3 A
e? '
*
v -a;
<— t rff
2 • *,!
di 'i
5 • ,'
•D '
§ '
S ' „
0 R
• /\
.'' /A
i//V
?]* r
F r
/'• \
f \
- .
-
0 20 40 60
Depth from 94V
+ Cl— banzena O Et— b«nzan« A Xyl«n«
Location RAB-F
ISO-i •
140 -
130 -
120 -
110 -
100 -
90 -
80 -
70 -
60 -
60 -
40 -
30 -
20 -
10 -
i
/ .
/' » i
f \ 1
/ . i
» 1
/
\ i
, . i
9
* 1 * 1
> 1 \ A
Hi . x ^31
w ^i
J / \ to
•D ; 'N ^1
S V ^"
3*O. (1)|
p r \ Jjl
0 / \ 5,
*-* / \ ^1
/ X
'A 1
\ '
> \ I
/* *\ '
\ .
^v-b-o-*^ ^ ° °~^^^ _^-o^o4_ .
0 - u-- •" — -J 1 1 [• ~~ B- -ij - .y . -^ B-
0 20 40 60
Oopth from 94CT
1.1.1-TCA
O PERC
-------
Figure 6. Variations in Concentration with Depth in the Soil
a) Substituted Benzenes; b) Volatile Organics.
for:
a)
Location RAB-I
f**
£
s
g
s
u
s
u
11 -
10 -
9 -
f
8 -
7 -
6 -
5 -
4 -
3 -
2 -
1 -
O —
0
. ; . ; , . _, | . 1 1
'(
\
1
1
1
1
' •,
J
01 . »H
> • gi
•J , H
T3 I "
1 ' ^
U i 3
o 1
' 7 '-
A'xV '
/x /A '
*• • — ^ -^ 1
20 40 &
Toluano
D«pth from 9401
+ O-bwizana
Xyton*
b)
Location RAB-I
o
a
I
u
S
20
D«pth from 940*
1.1.1-TCA o PERC
-------
Figure 7.
West
Relative
E levation
In Feet
Scales:
Vertical
6
feet
Horizontal
5
feet
40
CROSS-SECTION RASMUSSEN SITE
PCE In Soils In ug/Kg
Cl = 100 ug/Kg
East
40
80
Distance Along Profile In Feet
-------
West
Figure 8.
RAB-F
CROSS-SECTION RASMUSSEN SITE
Chlorobenzene In Soils In ug/Kg
Cl = 1000 ug/Kg
w
so
Relative
Elevation 40.
In Feet
Scales:
Vertical 30
0 12
feet
Horizontal
20
6 40
feet
10-
o-
3.1
970
760
RAB - C
East
40
80
120
160
240
Distance Along Profile In Feet
-------
West
Relative
E levation
In Feet
Scales:
Ver t ical
6 12
feet
Horizontal
0 40
feet
60-!
50-
40-
30-
20-
10-
0-
Figure 9.
RAB-F
t.3
1.2
4.5
9.6
3500
2800
CROSS-SECTION RASMUSSEN SITE
Total Xylenes In Soils In ug/Kg
Cl = SOOO ug/ Kg
East
40
80
120
160
260
240
Distance Along Profile In Feet
-------
V
APPENDIX 1.
NOTES
-------
SMVLDC nmoocts AND ERXEDCRBS
i
Soil baring samples were collected from a total of 18 locations, 8 'points
associated with the FPSLD area and 10 points around the
properties, as identified on Figure 1. The sampling
locations were identified prior to the actual sampling, see Figure 1.
Eight boring locations (RAB-A thru RAB-I) are new boring locations, The
remaining 10 locations are replacement borings of previously sampled
locations. Samples were collected for three purposes: lithologic
confirmation, selected organics field screening, and laboratory analysis
for PCB's.
All soil borings were drilled using a 4.25" ID hollow stem auger, gas or
deisel powered drill rig. All samples were collected using a 2" ID split""
barrel samplers. Prior to drilling and between drilling locations, the
drill rig and drilling equipment were decontaminated by steam-cleaning.
Where possible, the split barrel sampling device was steam cleaned between
samples. If steam cleaning was not possible , the split-barrel sampling '
device was washed with Alconox solution and rinsed with clean water. Field
blanks, using Baker purified sand, were taken at each boring location to
test the effectiveness of the decontamination procedures. ,
Ihe specific sampling protocol which was implemented on site is as follows:
1. The identified sampling location was cleared of loose material, snow,
and ice.
2. a) For surface samples, a clean split barrel sampler was driven to the
appropriate depth.
b) For subsurface samples, a hole was drilled to the appropriate
depth, using the hollow stem auger drill rig. Then the same procedure
used for surface sampling was followed.
3. The split barrel sampler was opened and visually inspected.
4. A 250 mL sampling jar was filled with soil from the length of the
sample core for PCS analysis.
5. A 200 mL sampling jar was filled with soil from the length of the
samolti core for selected organic field screening.
6 A 250 ml sampling jar was filled with soil from the length of the
sample core for lithologic confirmation.
7. All jar labels were completed with appropriate information.
8. Sampling data (ie., date, location, blow counts, visual observations,
Hnu readings, etc.) was recorded in field note books, and is presented
in- Appendix 1 . „.
-------
V
APPENDIX 4
RISK ASSESSMENT INDICATOR CHEMICALS
-------
TABLE 3-1
INDICATOR CHEMICALS
SMEGELBERG SITE AND RASMUSSEN DUMP SITE
Contaminants that are
Known or Probable Carcinogens
benzene
1 , 1 ,2.2-tetrachloroethane
1 , 1 ,2-trichloroethane
1,1-dichloroethane
tetrachloroethene
trichloroethene
1,1-dichloroethene
vinyl chloride
chloroform
methylene chloride
bis(2-ethylhexyl)phthafate
benzo(a)pyrene
benzo(a)anthracene
benzo(b)fluoranthene
benzo(k)fluoranthene
chrysene
indeno( 1 ,2,3-cd)pyrene
PCBs
2,3.7.8-TCDD(dioxin)
N-nitrosodiphenylamine
cadmium
nickel
Contaminants with
Noncarcinogenic Effects
acetone
2-butanone
toluene
ethylbenzene
chlorobenzene
total xylenes
styrene
1,1,1 -trichloroethane
1,1-dichloroethane
tetrachloroethene
1 ,2-dichloroethene
1,1-dichloroethene
chloroform
methylene chloride
bis(2-ethyl hexyl)phthal ate
di-n-butyl phthalate
phenol
carbon disulfide
barium
cadmium
chromium (III)
copper
lead
nickel
zinc
-------
APPENDIX 5
RISK ASSESSMENT
CARCINOGENIC RISK
-------
REVISION- 11/10/89
TABLE 3-6
TOTAL CARCINOGENIC RISK
POTENTIAL HOUSEHOLD USE OF GROUNOWATER
SPIEGELBERG SITE AND RASMUSSEN DUMP SITE
t
Source Area
Existing Plume-Spiegel berg
Existing Plume - Rasmussen
Top of Municipal Landfill
Northeast Buried Drum Area
Industrial Waste Area
Probable Drum
Storage/Leakage/
Disposal Area
Berm Area
Maximum Source Cone.
OT = 1m
3.83x 10-3
6.23 x 10-3
2.12x 10-"
1.22x10-3
1.62x 10-4
1.35x 10-6
5.46 x 10-6
QT= 10m
7.29 x 10-4
2.04 x 10-3
283x 10-5
1.53x10-4
I.SSx 10-5
1.09x lO-?
7.12x 10-'
Average Source Cone.
ay= 1m
1.90x 10-3
6.78 x lO-4
3.88x10-5
2.82x10-4
3.20x10-5
3.15x10-7
1.82x 10-6
i.
07= 10m
3.62x 10-4
2.22 x 10-4
5.18x 10-6
3.53x105
3.05x10-6
4.42 x 10-8
2.37 x 10-7
For input parameters and assumptions, see Section 3 4.4.1 and Appendix B.
-------
REVISION-11/10/89
TABLE 3-7
TOTAL CARCINOGENIC RISK
DIRECT DERMAL CONTACT WITH SURFACE SOILS
RASMUSSEN DUMP SITE '
, Source Area
Municipal Landfill Area
Area of Reported Burning
Industrial Waste Area
Probable Drum Storage Area
Berm Area
Northeast Buried Drum Area
Worst-Case Scenario
1.21x10*
896x106
4.42 x 10-6
3.13x10-5
6.34 x 10-6
1.23x106
Plausible-Case Scenario
i
1.08x 105
8.47x10-7
5.47x10-7
1.17x 10-6
5.29 x 107
2.13x10-7
For input parameters and assumptions, see Section 3.4.4.2 and Appendix C.
-------
REVISION-11/10/89
TABLE 3-9
TOTAL CARCINOGENIC RISK
FUGITIVE DUST EMISSIONS
RASMUSSEN DUMP SITE
Area of Concern
t
Municipal Landfill Area
Industrial Waste Area
Probable Drum Storage Area
Berm Area
Northeast Buried Drum Area
Worst-Case Scenario
1.56x1(H
6.07 x 10-9
1.72x 10-9
6.34x 10-9
5.52 x 10-10
Plausible-Case Scenario
6.02x101* '
'4.40xlO-'0
2.39x10-'0
2.79x10-'0
4.79 x 10-"
For input parameters and assumptions, see Section 3.4.4.3 and Appendix D.
-------
Y
APPENDIX 6
HAZARD INDICES
-------
REVISION - 11/10/89
TABLE 3-11
TOTAL HAZARD INDICES. POTENTIAL HOUSEHOLD USE OF GROUNDWATER
SPIEGELBERG SITE AND RASMUSSEN DUMP SITE
1
Source Area
Existing Plume-Spiegelberg
Existing Plume - Rasmussen
Top of Municipal Landfill
Northeast Buried Drum Area
Industrial Waste Area
Probable Drum Storage/
Leakage/Disposal Area
Berm Area
Maximum Source Cone.
OT= 1m
10.4
53.1
0.92
7.56
0.06
0.08
0.10
OT= 10m
1.98
17.4
0.12
0.94
0.006
0.01
0.01
Average Source Cone.
OT = 1m
3.56
8.99
0.13
0.94
0.01
0.02
0.04
i,
QT= 10m
0.68
2.95
0.02
0.12
0.001
0.002
0.005
For input parameters and assumptions, see Section 3.4.4.1 and Appendix B.
-------
REVISION-11/10/89
TABLE 3-12
TOTAL HAZARD INDICES
DIRECT DERMAL CONTACT WITH SURFACE SOILS
RASMUSSEN DUMP SITE •
Source Area
I
Municipal Landfill Area
Industrial Waste Area
Probable Drum Storage Area
Berm Area
Worst-Case Scenario
1.47x 10-2
J.ISx 10-3
2.76* 10-2
4.44 x 10-3
Plausible-Case Scenario
3.71 x 10:*
4.04x10-4
3.98x10-3
2.77x10-4
For input parameters and assumptions, see Section 3.4.4.2 and Appendix C.
-------
RE VISION-11/10/89
TABLE 3-14
TOTAL HAZARD INDICES (FOR CHILDREN)
FUGITIVE DUST EMISSIONS
RASMUSSEN DUMP SITE .
Area of Concern
I
Municipal Landfill Area
Industrial Waste Area
Probable Drum Storage Area
Berm Area
Worst-Case Scenario
4.13x106
3.44 x 10-"
2.11x105
3.61 xlO-"
Plausible-Case Scenario
1.85x10« '
'2.13x10-12
2.56 xlO-7
1.27x10-12
For input parameters and assumptions, see Section 3.4.4.3 and Appendix D.
-------
STATE OF MICHIGAN
•TURAL Aittouncei COMMISSION
J
.MOON e. cuvcn
CLIWOOO A. MAI160N ' . • „ ... _• ._ __ _
0 STCWAUT MVKHS •• JOHN ENGLER. Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON
c.O. 0
-------
Mr. Valdas Adamkus • . -2- . March 28, 1991
resource by preventing water infiltration. In addition, purged water will be
treated prior to reinjection and then hydraul ically contained on-site by the
purge wells in a manner that will also prevent degradation of groundwater
quality, consistent with the Water Resources Commission Act and Part 22 Rules.
We are. pleased to be partners with you in selecting this remedy and look forward
to working together to accomplish the final remedy at this site.
Sincerely,
lbert Rector
Deputy Director
517-373-7917
cc: Ms. Susan Schneider, US DOJ
Mr. Jon D1kin1s, US EPA
Ms. Alison Gavin, US EPA, ORC
Ms. Wendy Carney, US EPA
Mr. Ken Glatz, US EPA
Mr. Robert Reichel, AG
Mr. William Bradford, MDNR
. Ms. Claudia Kerbawy, MDNR
Ms. Oenise Gruben, MDNR
------- |