United States         Office of
Environmental Protection    Emergency and
Agency            Remedial Response
EPA/ROD/R05-91/173
September 1991
Superfund
Record of Decision:
Organic Chemicals, Ml

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50272-101
 REPORT DOCUMENTATION
        PAGE
1. REPORT MO.
    EPA/ROD/R05-91/173
                                                                    3. Recipient1 • Accession No.
   Titto and Subtitle
   SUPERFUND RECORD OF  DECISION
   Organic Chemicals, MI
   First Remedial Action
                                                                     5. Report Date
                                                    09/30/91
 7. Ai*hor(e)
                                                                    8. Performing Organization Rept No.
 B. Performing Organization Name and Address
                                           10. Proiect/Taak/Work Unit No.
                                                                     11. ContracXC) or Grant(G) No.

                                                                     (C)

                                                                     (G)
 12. Sponaorlng Organization Name and Addreaa
   U.S.  Environmental Protection  Agency
   401 M Street, S.W.
   Washington, D.C.   20460
                                           13. Type of Report ft Period Covered

                                                     800/000
                                                                     14.
 IS. Supplementary Notes
 16. Abelract (UmH: 200 worda)
  The 5-acre Organic Chemicals site  is an inactive solvent reclamation and chemicals
  manufacturing facility in Grandville,  Kent County,  Michigan.   The site  includes several
  onsite buildings, structures, above-ground storage  tanks and drum storage areas, a
  boiler facility, a wastewater treatment facility,  and a seepage lagoon.   Wetlands
  potentially  are located 1,900 feet northwest  of the site,  and the Grand River is located
  0.95 miles to the north of the site.  A succession  of petroleum-related industries
  leased the land for petroleum refining from 1941 to 1945,  followed by transport and
  storage  operations from 1945 to  1966.   Organic  Chemicals Inc.,  (OCI) began site
  operations in 1968.   Company records show that  between 1968  and 1980, process waste and
  cooling  water including RCRA hazardous wastes were  discharged to the onsite seepage
  lagoon.   In  1979, 2,200 gallons  of lacquer thinner  were spilled onto the ground onsite
  and subsequently, some of the spilled thinner was recovered  and disposed of onsite  in
  the seepage  lagoon.   In 1980, discharges to the lagoon ceased,  and the  company installed
  a wastewater pretreatment system,  which discharged wastes  to the sanitary sewer system.
  Subsequently, in 1981,  the seepage lagoon sludge was excavated and disposed of offsite.

  (See Attached Page)
 17. Document Analyala a. Descriptor*
    Record of Decision - Organic  Chemicals, MI
    First Remedial  Action
    Contaminated Medium: gw
    Key  Contaminants:  VOCs  (benzene, toluene,  xylenes),  other organics (PAHs,
                        Pesticides)
   c. COSATI Held/Group
 '8. AvallabMty Statement
                             It. Security Claaa flhla Report)
                                      None
                                                      20. Security Ctaaa (This Page)
                                                      	None
21. No. of Pages
        64
                                                                                22. Price
(See ANSt-Z3».1B)
                                      See Iratruction* on ftewnw
                                                      OPTIONAL FORM 272 (4-77)
                                                      (Formerly NTIS-35)
                                                      Department of Commerce

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EPA/ROD/R05-91/173
Organic Chemicals, MI
First Remedial Action

Abstract (Continued)

In 1983, EPA documented onsite soil and potential ground water contamination resulting
from the solvent-contaminated seepage lagoon.  Additionally,  in 1986,  the State
determined that OCI was illegally disposing of sludge and other hazardous residuals from
the onsite solvent recovery operations by placing these into drums or rolloff containers
along with routine non-hazardous waste materials.  Analysis of the drum and container
contents and soil samples from the vicinity of these storage units revealed the presence
of VOCs and other organics.  During 1987, OCI, as part of a voluntary investigation,
discovered and removed 150 buried drums containing sludge and liquid residues offsite,
and identified further onsite soil contamination.  Federal and State investigations have
determined that site contamination has resulted from past operation of the seepage
lagoon by OCI, chemical spills at the site and past oil-related activities.  EPA has
divided the remediation into two response actions.  This Record of Decision (ROD)
addresses contamination in the upper ground water system, as an interim remedy.  A
future ROD will constitute the final response at the site by addressing the remaining
onsite ground water and soil contamination.  The primary contaminants of concern
affecting the ground water are VOCs including benzene, toluene, and xylenes; and other
organics including PAHs and pesticides.

The selected remedial action for this site includes onsite pumping and treatment of
ground water using a treatment system consisting of an equalization/sedimentation basin,
two granular activated carbon vessels, and an air stripper polishing unit; discharging
the treated water onsite to the Grand River; disposing of treatment carbon residuals in
an offsite landfill; conducting a treatability study and pump test to determine the
proper treatment train and pumping rates; and ground water monitoring.  The estimated
present worth cost for this interim remedial action is $5,931,000, which includes an
annual O&M cost of $317,000.

PERFORMANCE STANDARDS OR GOALS:  This remedial action is only part of a total remedial
action and will attain ground water cleanup ARARs during future response actions.

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                               RECORD OF DECISION

                       SELECTED REMEDIAL ALTERNATIVE
                                      FOR THE

                         ORGANIC  CHEMICALS, INC. SITE
                             GRANDVILLE, MICHIGAN
Statement of Basis and Purpose

This decision document presents the selected remedial action for the Organic Chemicals Inc.,
site  in  Grandville,  Michigan, which  was chosen  in accordance with  the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This
decision is based on the administrative record for this site.

The  State of Michigan concurs with 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 in this Record of Decision (ROD), may present an imminent
and substantial endangerment to public  health, welfare, or to the environment.
Description of the Selected Remedy

This ROD addresses a discrete action at the Site.  The selected remedy  is an interim action
remedy and addresses the ground water contaminant plume in the upper ground-water system
at the  site. The second operable unit  will constitute the final response action  at the site
addressing the remaining ground water and soil contamination, which are principal threats at the
site. The selected remedy consists of the following components:

       Install, operate and maintain an  interim ground-water extraction system in the upper
       ground-water system consisting of, at a minimum, three extraction wells. Install, operate
       and maintain a physical-chemical ground-water treatment system for the interim ground-
       water action.

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Statutory Determinations

This interim action is protective of human health and the environment, complies with or waives
Federal and State applicable or relevant and appropriate requirements  for this limited-scope
action, and is cost-effective.  Although this interim action is not intended to fully address the
statutory mandate for permanence and treatment to the maximum extent practicable, this interim
action utilizes treatment and is in furtherance of that statutory mandate. Because this action does
not constitute the final remedy for the site, the statutory preference for remedies that employ
treatment that reduces  toxicity, mobility, or volume as a principal element, although partially
addressed in this  remedy, will be addressed by  the  final response action.  To the extent
practicable, treatment is used as part of the interim action.  Subsequent actions are planned to
address fully the threats posed by the conditions at this site. Because this remedy will result in
hazardous substances remaining  on site above health-based levels, a review will be conducted
to ensure that the remedy  continues to provide adequate protection  of human health  and the
environment within five years after commencement of the remedial action.  Because this is an
interim action ROD, review of this site and of this remedy will be continuing as EPA continues
to develop final remedial alternatives for the site.
   .(las
 egionsfl Administrator

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                           Decision Summary for the Record
                                      of Decision
                              Organic Chemicals, Inc. Site
                                 Grandville, Michigan

I. Site Name. Location, and Description

The Organic Chemicals Inc. (OCI) property is located at 3291 Chicago Drive, S.W., in the city
of Grandville, Kent County, Michigan.  The OCI property, approximately 5 acres, is fenced,
with several buildings, structures, and storage tanks occupying the site (Figures 1 and 2) which
extends over several properties.  The Chesapeake and  Ohio Railroad, which runs southeast of
the facility and along the north side of Chicago Drive, has an elevated railbed acting as a barrier
to surface drainage.   A drainage ditch exists on the west side of the  OCI site.  There is  no
visible surface drainage Unking the site and the Grand River, which is located approximately
0.95 miles north.  Two gravel quarries have been identified near the OCI site.  One quarry is
located 0.3 miles northwest, and the other quarry  is 0.2 miles northeast of the site.   Both
quarries are inactive and filled with water.  An oil well,  1700 feet northwest of the site, was
operational until this year.  Potential wetland areas are 1900 feet northwest of the site on the
opposite side of 1-196.

The OCI property has several buildings and structures occupying the property. The chemical
manufacturing operation, which is housed in two buildings along the western boundary of the
property, produces small quantities of specialized industrial  chemicals and  pharmaceutical
intermediates.  The  solvent recovery operation is housed in  several buildings along the
southeastern portion of the property.  Other structures include a warehouse, several drum and
storage tank areas, an office building, a boiler facility and a waste water pretreatment facility.

Two railroad  sidings  parallel the southern and eastern OCI property  boundaries  (Figure 2).
Along the sidings are the remnants of a series of aboveground storage tank facilities. Although
the tanks no longer exist, the concrete footings and underground piping connections remain.

The OCI property is bordered by Packaging Corporation of America on the east, by the former
Haven-Busch  Co. on  the west, and  by  Grand  Rapids  Gravel  Co. on the north and these
properties are also part of the OCI site. The property directly north and northwest of OCI has
a lower ground surface elevation due to earlier sand and gravel mining activities.  Residential
areas are approximately 200 feet southeast of the site and 1700 feet to  the southwest.

II. Site History and Enforcement Activities

A. Site History

The OCI site is situated approximately 0.95 miles southeast of the Grand River.  The site has
been previously used for petroleum refining from  1941  to 1945, and transport and storage
operations from 1945 to 1966.  A succession of petroleum-related industries leased the land prior
to its  purchase by  Spartan  Chemicals.    Anne R.  Herald,  owner  of the property  from
approximately 1900 to 1942, issued  an oil and gas lease for the entire property to Gerald J.

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 Wagner on December 7, 1937.  Mr. Wagner then leased the premises for oil and gas exploration
 to various third parties. During tenure of these leaseholds, two oil production wells were drilled
 onsite.  One was a dry hole and the other was never completed or maintained. Attempts made
 to identify the exact locations of these wells by reviewing existing data were unsuccessful.

 All oil and gas exploration leases were summarily voided by Ms. Herald on February 7, 1941.
 Other petroleum industry operations commenced onsite in the early  1940's.  Total Pipeline
 Corporation,  a petroleum transporter, leased an oil and gasoline warehouse and tank facility
 onsite during  this period.   Its facilities were then taken over by  its parent company, Total
 Petroleum, Inc., which operated onsite through 1964. Leonard Fuels purchased the site in 1964
 and sold the property to Total Realty in 1966.  In  1968, Spartan Chemical Company acquired
 the site property  for the solvent reclamation and chemical manufacturing  operations of its
 subsidiary, Organic Chemicals  Company (now Organic Chemicals,  Inc.).  Organic Chemicals,
 Inc. (OCI) has operated on the site since 1968. In 1979, OCI became the owner of the premises
 by conveyance of deed from Spartan Chemical Company.

 Historical aerial photographs,  taken from  1960 through 1978, show changes to the physical
! facilities of the OCI site. In a  1960 photograph, three large vertical tanks with two sumps for
' containing spills were present along the northwestern portion of the former refinery". By 1967,
 these tanks were no longer present.  In  1973, the terrain on the western portion of the former
 refinery, was being regraded and leveled.  The ground was visibly  scarred from earth moving
 activity.  In this same year there was a seepage lagoon on the OCI property which appeared to
 contain liquid waste.  Two new buildings and six additional vertical storage tanks had been
 added to the facility in 1973. A 1978 aerial photograph indicates that the west portion of the
 former refinery was abandoned. This area is now owned by Haven-Busch, Co. and was being
 used as an open storage yard for this steel fabrication company. Haven-Busch Co., has since
 closed both their corporate office and their steel fabrication plant.

 In March  1976, a water well was drilled on the OCI property.  The well was  165 feet deep and
 was used to provide plant production and cooling water.  Because of various problems with the
 performance of the well, it was abandoned and the plant returned to the use  of water supplied
 by the city of Grandville.

 A chemical fire occurred onsite on October 11,1976, damaging part of the OCI facilities. The
 cause of the blaze was reported as being started by a spark from a metal drum dragged across
 a floor.  The spark ignited barrels of solvents stored nearby.  According to retired Grandville
 Fire Chief Osterink, the fire was contained in the building and prevented from spreading to other
 storage tanks outside.

 A chemical spill at the site in November, 1979, was reported  to the Michigan Department of
 Natural Resources (MDNR) by OCI. On November 3, 1979, 2,200 gallons of lacquer thinner
 were spilled  by an operator onto the ground onsite.  Some of the  spilled lacquer thinner was
 recovered  and disposed of in the onsite seepage lagoon.

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The OCI site was classified, on April 14, 1980, as a potential hazardous waste site by the EPA.
The EPA summarized the problem in  its  Potential  Hazardous Waste  Site log as "known
groundwater contamination by organic solvents."  Between 1968 and 1980, company records
indicate that OCI discharged its process  waste and cooling water, which included F001-F005
hazardous wastes into  the onsite  seepage lagoon.  In June 1980, OCI ceased discharge of
wastewater to  the seepage lagoon. In 1980, the company installed a wastewater pretreatment
facility with discharge to the City of Grandville Sanitary  Sewer system.   The pretreatment
facility included two 9,000 gallon  sedimentation tanks and a 30,000 gallon aeration basin with
pH adjustment.

In September 1981, seepage lagoon sludges were excavated and transferred to railroad cars.  The
total removed  soil filled approximately seven railroad cars.  These sludges were disposed of at
Chem-Met Services Inc., in Wyandotte, Michigan.

A Preliminary Assessment (PA)  for  the site  was completed  by EPA in  1983.   The PA
documented potential groundwater contamination from the solvent-contaminated seepage lagoon.
Soils beneath  this pond were also found to  be  contaminated.  A potential for drinking water
contamination  and endangerment of flora and fauna in nearby potential wetlands was indicated
in the PA.

In September  1986, MDNR Law Enforcement Division personnel responded to a complaint of
alleged illegal  disposal of hazardous wastes at  the facility. Reportedly, OCI personnel were
disposing of sludges and  other residues generated from the  solvent recovery  operations by
placing these materials  into drums and rolloff containers along with their normal nonhazardous
solid waste  materials.   Analyses taken from solid waste storage units (rolloffs and 55 gallon
drums) located at the site revealed the presence of various contaminants including methylene
chloride, toluene, ethylbenzene, xylenes and arochlor 1242 (PCB).  Analyses of soil samples
taken from  the vicinity of the solid waste  storage units revealed the presence of methylene
chloride, toluene, xylenes, 1,1,1-trichloroethane, trichloroethene,  tetrachloroethene, chloroform,
1,1-dicnloroethene,  1,2-dichloroethene, and  Aroclor 1242 (PCB).

As a result of this investigation, OCI  was cited by the EPA  on December 3,  1986, to be in
violation of Resource  Conservation and  Recovery Act (RCRA).  Among the violations cited
were: (1) the unreported generation of hazardous waste from a drum cutting operation;  (2) the
routine transport of hazardous waste from the site by unauthorized agents; (3) failure to prepare
hazardous waste manifests, and (4) shipment of hazardous waste to unauthorized  facilities.
Based on these findings, the EPA levied fines of $22,500 on OCI.

During August/September 1987, OCI conducted a voluntary investigation in cooperation with
MDNR.  Approximately  150 buried drums  were discovered and removed from the southwest
corner of the  OCI  warehouse building.  Some of these  drums contained  sludge and liquid
residues. Groundwater samples taken at that time from Prein & Newhof s monitoring  well,
B-ll, indicated the presence of 1,1-dichlproethene, 1,1-dichloroethane, cis- 1,2-dichloroethene,
dibromochloromethane, toluene, ethylbenzene, and xylenes. Monitoring well B-ll was  located

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south and slightly west of the warehouse building. The drum burial area was excavated down
to approximately 17 feet below grade. Soil samples from the bottom of the excavation indicated
methylene chloride (13 ug/kg) and tetrachloroethene (2.7 ug/kg) contamination.

B. Previous Investigations

In November 1979, the MDNR requested that OCI perform a hydrogeological study to
investigate suspected groundwater contamination.  This study, conducted in  four phases,  was
completed in October 1981.  It concluded that the groundwater flow in the upper groundwater
system at the site was northwesterly towards the Grand River. Soil borings identified a sand and
gravel aquifer existed over a clay layer.  The elevation of the top of the clay layer was found
to vary  throughout the area. It was deepest below the area of the former seepage pond.  The
elevation of the top of the clay layer was  found  to be shallowest 1,000 feet west of the OCI
property.   It was concluded  mat this caused a plateau in the  water table by restricting the
westward movement of the groundwater.

Twenty^four monitoring wells were installed during this study.  Analysis of monitoring wells
north and west of the former  seepage pond revealed  the following contaminants:  methylene
chloride,   toluene,   1,1-dichloroethene,   trans  1,2-dichloroethene,    1,2-dichloroethane,
trichloroethene, benzene, chlorobenzene, ethylbenzene, pentachlorophenol, xylene, acetone,
2-propanol, 4-methyl-2 pentanone, trifluoromethylbenzene,  naphthalenes, and various aliphatic
hydrocarbons.

Analyses of surface soil samples taken from the OCI facility revealed the presence of methylene
chloride, toluene, xylenes, 1,1,2-trichloroethane, trichloroethene, tetrachloroethene, chloroform,
1,1-dichoroethene, 1,2-dichloroethene and  Aroclor 1242 (PCB).

The investigation also attempted to determine the rate of groundwater flow. Using soil samples
obtained during the different phases of the investigation and the hydraulic gradient determined
from groundwater elevations, the rate of groundwater flow was estimated by the Kozeny-Carmen
Equation. Due to the various  soil strata encountered, which have various amounts of fines in
with the gravel; it was extremely difficult to accurately determine the rate of groundwater flow.
The calculations indicated that the groundwater flow rate may vary from approximately 0.3 feet
per day to as high as  1.5 feet per day or possibly higher in localized areas of extremely high
permeability.

In the fall of 1988, EPA and the ARCS V project team conducted preliminary field investigation
(PFI) activities with the objective of further characterizing the OCI site.  A description of PFI
activities can be found in the PFI Quality  Assurance Project Plan (QAPP).  The information
gathered during the PFI was incorporated in the planning and implementation of the Phase I RI
activities. Analytical results obtained during the PFI study  are presented in Appendix C of the
Focused Feasibility Study (FFS).

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 C. CERCLA Enforcement

 On March 30, 1988, a letter was sent to both OCI and Spartan Chemical pursuant to Section
 122(a) of CERCLA informing them  that work pursuant to 104(a)  of  CERCLA would be
 undertaken by EPA because OCI and Spartan lacked the financial capability to perform an
 RI/FS.  On April 9, 1991, a General Notice letter was sent to OCI and Spartan; also  on April
 9,1991, a General Notice Letter and  Information Request was sent  to 182 PRPs who were
 customers  of OCI and are  considered generators of hazardous waste at OCI,  pursuant to
 107(a)(3) of CERCLA.

 III. Highlights of Community Participation

 A Community Relations Plan was finalized for the OCI site in February 1989.  This document
 lists contacts  and interested parties throughout the government and the  local community. It  also
 established communication pathways to ensure timely dissemination of  pertinent information. A
 fact  sheet outlining the RI sampling program was distributed in May  of  1989.  An RI public
 availability session was held  on May 10, 1989. A second fact sheet was distributed in January
 of 1991 outlining this interim action for the upper ground-water system. The FFS was  finalized
 on July 17, 1991. The Proposed Plan for the interim action at the OCI site was released to the
 public on July 18, 1991. All  of these documents, including the analytical data upon which this
 decision was based, were made available in both the Administrative Record and the information
 repository maintained at the  Grandville Public Library at  3141 Wilson Avenue in Grandville.
 The  notice of availability of these documents was published in the Grand  Valley Advance  on
 July 16, 1991, and the  Grand Rapids Press on July 18, 1991.

 A public comment period was  held from July  22 through August 20,  1991. A public meeting
 was  held on August 6,  1991, to present the results of the  FFS and the preferred alternative as
 presented in the Proposed Plan for this interim action.  All significant comments which were
 received by EPA prior to the  end of the public comment period, including those expressed
 verbally at the public meeting, are addressed in the Responsiveness Summary, which is attached
 to this Record of Decision.

 IV. Scope of Response  Action

EPA has organized this project into at least two response  actions. The first response  action is
an interim action to address contamination in the upper ground-water system (UGS) by stopping
 the contaminant plume migration. The second response action will constitute the final  response
at the site addressing the remaining groundwater and soil contamination. Sufficient information
exists to begin remediation of the upper groundwater system, although further investigation is
required of the soil, upper and lower groundwater system (LGS>, oil and the OCI facility, if
RCRA closure can not be attained prior to selecting a final remedy.

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This interim action is intended to provide for protection of human health and the environment
by halting migration of the contaminants in the UGS.  This interim action will be consistent to
the extent possible with the final site remedy.

V. Site Characteristics

The primary contaminants at the site are associated with the past operation of the seepage pit by
OCI, chemical spills at the site and past oil related activities.  (Figure 3)  These contaminants
include high  levels of chlorinated solvents and benzene, ethylbenzene, toluene, and xylene
(BETX) compounds.  Lower  concentrations of other  volatile  and semi-volatile organic
compounds were also detected. The nature and extent of contamination is presented in the FFS
report and summarized in the following sections.

A. Hydrogeologic Characteristics and Ground water Contamination

Shallow groundwater at the OCI site occurs in the saturated unconsolidated deposits of sand and
gravel, which range in thickness from 30 to 4 feet.  There are no known residential wells that
draw water from these deposits.  The sand and gravel deposits are underlain by clay throughout
the site except at SB-10 (Figures 4 through 8), which encountered shale directly below the sand
and gravel deposits. The thickness of the clay varies from 0 feet at  SB-10 to 35.5 feet at MW-
20.   The Michigan formation underlies the clay unit and  consists of interbedded gypsum,
limestone and shale  with occasional sandstone  lenses. The Marshall Sandstone formation
underlies the Michigan formation and is the source of groundwater for private and  industrial
wells and is a Class I aquifer. Residential areas are located to the southeast and southwest of
the site. Potential wetland areas and the Grand River are located  on the other side of 1-196.
OCI related contamination has not reached this area, although contamination is moving in this
direction and may eventually reach there unless halted.

Ground water flow in the unconsolidated deposits is to the northwest towards the Grand River.
Ground water flow in the LGS also appears to move in a  northwesterly direction, although
additional wells are necessary to accurately determine flow direction.

The LGS is a confined and locally unconfined (where the clay unit is not present). The hydraulic
conductivity in the UGS at MW-15 was 3.9 X 104 cm/sec, typical of a well-graded silty sand,
and 2.32 X 10"2 cm/sec at MW-3,  typical of a silty sand with some gravel.  The  hydraulic
conductivity values for the UGS ranged from 6^91 X 1(T5 cm/sec at MW-8 to 1.53 X lO"1 cm/sec
at MW-22.

A. Monitoring Wells

Two rounds of groundwater samples were collected from 25 of the 26 monitoring wells installed
during the field investigation (Figure 9).  Monitoring well MW-12 was not sampled due to
insufficient water  in  the  well.   Groundwater  samples were analyzed  for volatile  organic
compounds, semi-volatile organic compounds, pesticides, PCBs, metals and cyanide.  Analyses

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were also conducted for TOX, TOC, COD, BOD, TSS, IDS, alkalinity and chloride.
Appendix E in the FFS presents analytical results of both rounds of ground water sampling.
These analytical results are summarized on Figures 10 and 11 and in Tables 1 and 2.

The groundwater samples with the greatest number and highest concentration of contaminants
were from MW-1 and MW-2 (> 10,000 ug/L total organic contaminants).  These wells are
located in the area of the former seepage lagoon.  Contaminants detected in the samples from
these wells included high levels (> 100 ug/L organic contaminants) of chlorinated solvents and
BETX compounds (i.e., Benzene, Ethylbenzene, Toluene and Xylene).  Lower concentrations
of other volatile and semi-volatile organic compounds were also detected (Figure  10).

Groundwater  samples  from MW-4,  MW-5, and  MW-22  also  contained  relatively high
concentrations of organic compounds (> 100 ug/L total organic contaminants).  Groundwater
samples from  MW-3, MW-6, MW-11, MW-16,  MW-18, and SB-10 contained  much lower
organic contaminant concentrations (ranging  from  10 to 100 ug/L total organic contaminants).
Groundwater  samples from MW-16 and SB-10 contained total  organic   contaminant
concentrations of 3 and 0 ug/L during Round 1 sampling and 57 and 31 ug/L during Round 2
sampling, respectively.   The widespread occurrence of bis (2-ethyl hexyl) phthalate and
methylene chloride at very  low  levels (<40 ug/L) in the groundwater and rinsate samples,
during groundwater sampling rounds 1  and 2, is suspected to be due to sampling or laboratory
contamination.

The majority of the organic contamination detected in the groundwater was from samples taken
from wells  located  near  or on the OCI  property.  Isopleth contours of the  total organic
contamination,  (Figure 10) indicate that contaminant migration is predominantly from source
areas on the property in the north  and west.  Most of this contamination is  in the upper
groundwater system.   However, contamination  (>10 ug/L and  <100 ug/L  total organic
contamination)  was also detected in groundwater  samples from SB-10, MW-18  and MW-19
which  were  screened  in  the  lower  groundwater  system.   Table  3 compares estimated
concentrations used in  the risk analysis  with maximum contaminant levels (MCLs) for drinking
water.

Organic contaminants detected in the samples  from MW-16 are more typical of petroleum wastes
(BETX and polynuclear aromatic hydrocarbon compounds).  This well is  located near old
petroleum waste ponds which were in use in  the 1950s. Some of these ponds still contain black
tar-like  wastes.   It was suspected  that  these ponds  may  represent  a separate source of
contamination and that releases from these ponds may be responsible for the contamination noted
in the samples from MW-16.

Inorganic analytes were detected in all  groundwater samples at varying concentrations (Figure
11). Inorganic concentrations in the samples from MW-17  (UGS) and MW-20 (LGS) were
assumed  to  represent  naturally  occurring background  levels,  in both groundwater systems
because  these  wells were located approximately  500 feet upgradient of the OCI site in a
residential setting.  All samples were filtered and had high turbidity.

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Eleven inorganic contaminants were detected in concentrations significantly above background
(i.e., > 5  times):   aluminum,  arsenic,  barium, chromium, iron, lead,  mercury, nickel,
potassium, sodium, and vanadium. The MCLs for these contaminants are as follows
aluminum -, arsenic -, barium (5000 ug/L), chromium (lOOug/L), iron -, lead (5ug/L),
mercury (2ug/L), nickel (lOOug/L), potassium -, sodium -, and vanadium -.

Aluminum was detected at levels significantly above background in groundwater samples: MW-
21 (Round 2:  17,200 ug/L), and MW-23 (Round 2:  9,220 ug/L).

Arsenic was detected at levels significantly above background in groundwater samples: MW-1
(Round 1: 12.1 ug/L),  MW-2 (Round 2: 22.5 ug/L), MW-4 (Round 1:  10.4 ug/L, Round 2:
13.8 ug/L), MW-5 (Round 1: 26.8 ug/L, Round 2: 35.7 ug/L), MW-6 (Round 1:  5.3 ug/L,
Round 2:  11.6 ug/L), MW-10 (Round 1:  6.6 ug/L, Round 2: 13.2 ug/L), MW-11 (Round 1;
8.2 ug/L, Round 2:  20.5 ug/L), MW-15 (Round 1:  6.4 ug/L, Round 2: 13.3 ug/L), MW-16
(Round 2: 19.3 ug/L), MW-22 (Round 1:  6.6 ug/L, Round 2:  7.9 ug/L) and MW-23 (Round
2: 9.3 ug/L).

Barium was detected at levels significantly above background in groundwater  samples: MW-11
(Round 1: 268 ug/L, Round 2: 593 ug/L), and MW-14 (Round 1: 239 ug/L, Round 2:  210
ug/L).  Chromium  was detected  at levels significantly above background in groundwater
samples: MW-7 (Round 2:  57.3 ug/L) and MW-14 (Round 2: 94.1 ug/L).

Iron was detected at  levels significantly above background in groundwater samples:  MW-11
(Round 2: 24,800 ug/L), and MW-21  (Round 2:  20,200 ug/L). Lead was detected at levels
significantly above background in groundwater sample MW-11 (Round 2: 47.1 ug/L).  Mercury
was detected at levels significantly above background in groundwater samples: MW-22 (Round
2: 5 ug/L) and SB-8 (Round 2:  5 ug/L). Nickel was detected  at levels significantly above
background in groundwater samples:  SB-7 (Round 2:  75.9 ug/L) and SB-10 (Round 2:  94.4
ug/L).

Potassium was detected at levels significantly above background in groundwater sample SB-10
(Round 2:  77,100 ug/L).  Sodium was detected at levels significantly above background in
groundwater samples: MW-3 (Round  1:  484,000 ug/L, Round 2:  1,000,000 ug/L), MW-14
(Round 2: 468,000 ug/L), MW-18 (Round 2: 384,000 ug/L), MW-19 (Round 1:  509,000
ug/L, Round 2: 849,000 ug/L), SB-7 (Round 1: 3,000,000 ug/L, Round 2:  4,000,000 ug/L),
SB-8 (Round 2:  1,000,000 ug/L) and  SB-10 (Round 2:  4,000,000 ug/L).

Vanadium was detected at levels significantly above background in the groundwater sample from
MW-21 (Round 2:  30 ug/L).

Analytical results from groundwater sampling rounds 1 and 2 forTOX, TOC,  COD, BOD, TSS,
TDS, alkalinity, pH, specific conductivity and temperature are presented on Tables 1 and 2,
respectively.  The results of the TOX and TOC analyses received a data qualifier, "J," because
the required sample holding times were exceeded by the laboratory. Since the sampling holding

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times were exceeded, this data was considered unreliable.  In order to obtain reliable data,
groundwater  was  resampled September  4-12,  1990.  The parameters that  the  resampled
ground water were analyzed for are denoted on Tables 1 and 2.

B.  Residential Well Analytical Results

Four residential well samples were collected during Round 1 groundwater sampling:  September
9-26, 1989 all are screened in the LGS. Three residential well samples (PW-1, PW-2 and PW-
3) were analyzed for volatile organic compounds, semi-volatile organic compounds,  pesticides,
PCBs, metals, cyanide, alkalinity, BODS, TOC, COD, TDS, and TOX. Residential well sample
PW-7 was analyzed only for volatile organic compounds. These analytical results are presented
on Pages E-4, E-8, E-16 and E-20 (Appendix E).  The residential well sampling locations are
presented in Figure 9.

Two types of volatile organic compounds were detected:   methylene chloride and  toluene.
Methylene chloride was detected in PW-1 and PW-2 at a concentration of 8 ug/L. Toluene was
detected in PW-3 at a concentration of 0.5 ug/L.

Two types  of semi-volatile organic compounds were detected:  bis(2-ethylhexyl)phthalate and
benzoic acid.  Bis(2-ethylhexyl)phthalate was detected in PW-1  and PW-3 at concentrations of
2 and 3 ug/L, respectively.  Benzoic acid was detected in PW-1 at a  concentration of 2 ug/L.

Two inorganic contaminants were detected at levels significantly above background  (i.e., >  5
times): lead and zinc. Lead was detected at levels significantly above  background in residential
well PW-1 at a concentration of  173  ug/L. Zinc was detected at levels  significantly above
background in residential wells PW-1 (294 ug/L), PW-2 (1,180 ug/L) and PW-3 (337 ug/L).

C. Contaminant Migration Routes

Two major mechanisms provide the  potential  for  migration  of contaminants from soil  to
groundwater at the site.   First, percolation of rainwater through the soil results  in vertical
leaching of contaminants to the underlying groundwater systems. Second, seasonal fluctuations
in the shallow unconfined groundwater system allows groundwater to come into contact with
typically unsaturated contaminated  soils.   Once  the groundwater contacts  these soils,
contaminants may solubilize in the groundwater.  Even  though there has been a continual
flushing and dissolution of compounds by these natural processes, residual contamination remains
in the  surface and  subsurface soils.   These contaminants  have low solubilities and strongly
adsorb to  soils.   Thus, there  may essentially be a continuous  source of groundwater
contamination due to contaminated soils at the facility.

Analytical results from the  field investigation indicated that the unsaturated soils  serve as a
continual source of contamination to the groundwater.  Three major source areas at the  site were
identified based on the RI analytical  results.   These areas are (Figure 3):  former seepage
lagoon, former lacquer thinner spill site and petroleum sludge lagoons.   The total organic

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                                          10

compounds in soil exceeds 2,747,000, 85,600 and 149,000 ug/kg, respectively, at these areas.

Other areas at the facility which may be ongoing sources of groundwater contamination are:  the
area near soil boring (SB-10) where a subsurface soil sample at a depth of 3 to 5 feet contained
20,200 ug/kg total organic contaminants; the area at MW-16 where a subsurface soil sample at
a depth of  11 to 12.5 feet contained 7,050 ug/kg total organic contaminants as shown in Figure
12; stained soil in a trench due west of the OCI chemical building (Figure 13), as represented
by surface soil samples SS-19, SS-20 and SS-21 which contained 76,500 ug/kg total organic
contaminants; and stained soil  approximately 300 feet north of the former seepage lagoon, as
represented by  surface  soil  sample  SS-6  which contained 370,000  ug/kg total  organic
contaminants.

The subsurface soil samples collected  from MW-1 and MW-2 during the RI indicate that the
saturated soil aquifer matrix directly beneath the former seepage lagoon is contaminated.  The
contaminants detected in the soil at a depth of 11  to  12 feet (MW-1) are identical to those
detected at a depth of 21 to 22 feet (MW-2), indicating that the contaminants from the lagoon
have migrated downward to the clay unit.  Several compounds disposed  of at OCI are knownv
as nonaqueous phase liquids (NAPLs), because of their low solubility and hydrophobicity (i.e./
low octanol/water coefficient).  Many compounds, such as trichloroethene and tetrachloroethene,.
are denser than water and are known as dense nonaqueous phase liquids (DNAPLs).  When
initially disposed of in the former seepage lagoon, these DNAPLs may have migrated vertically
downward  as undissolved free  product within the upper groundwater system and formed pools
of free product at the upper boundaries of the Clay unit directly below the former seepage
lagoon. The former seepage lagoon subsurface soil analytical results  are presented below:


Compound                Seepage Lagoon Subsurface Soil Results (ug/kg)

                                 (SAMPLE DEPTH)

                                 (11-12 ft)           (21-22 ft)

Trichloroethene (D)               100,000            30,000
2-methylnapthalene (D)              170
Toluene (L)                    1,800,000            490,000
Chlorobenzene (D)                94,000             38,000
Ethylbenzene (L)                   93,000             41,000
Styrene(L)                         -                16,000
Xylene (L)                       360,000           120,000
N-nitrosodiphenylamine (L)         18,000            240,000
Bis(2-etnylhexyl)phthalate (L)       4,800             47,000
Naphthalene (L)                     400             12,000
Arochlor 1248                       1400

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                                          11

   where:      (D) = density greater than water
              (L) = density less than water

Organic compounds that are less dense than water, such as ethyl benzene, toluene and xylene,
were also found in the deep (21-22 ft) subsurface soil sample. These compounds may have been
dissolved in organic matrices along with DNAPLs, creating a mixture having a density greater
than water which would have a tendency to migrate vertically downward.  Sampling was not
performed  that would confirm that free product was on top of the clay.

C.I  Ground water Migration

The hydraulic gradient in  the upper groundwater system is to the northwest from the facility
toward  the Grand River.  The analytical  results  of groundwater  samples confirms  that
contaminants from the facility have migrated approximately 1,000 feet north and northwest as
shown on Figure 10.  The highest contamination in the upper groundwater system is located
directly below the former seepage lagoon.   Contaminant concentrations within this system
decrease as the groundwater flows northwest to below 100 ug/L approximately 500 feet from
the former seepage lagoon. Contamination has also been found in the LGS in MW-18 and 19
as stated above, approximately 250 west of the former seepage lagoon.  Contamination will be
further investigated as part of the final response action.

D. Contaminant Characteristics and Behavior

The  hazardous substances  identified from analysis of environmental media samples during the
RI are discussed in terms of their chemical/physical characteristics and environmental behavior.

D.I  Suspected Contaminants

A list of the organic compounds detected  in all sample media analyzed during the RI is presented
in Table 4.  The environmental  media sampled at  the site contained aromatics, chlorinated
aliphatics and chlorinated alkanes. Phthalate esters were also detected. Analyses for each media
also  detected unknown compounds.  The analytical results of tentatively identified compounds
is presented in Appendix E of the FFS.

D. 1. a  Environmental Behavior

The following section assesses the environmental behavior of the compounds detected during the
RI.  This information is used to evaluate the potential for future contaminant migration.

The  migration potential of an  organic contaminant was assessed using a calculated  mobility
index.  The mobility index (MI) is a  measure  of the contaminants relative tendency to migrate
in the environment and reflects a contaminant's migration potential in water, air, and soil.  It
can be represented as:

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                                          12
              MI  = log [(water solubility x vapor pressure)/K,J

The following table is a general guide to the Water Mobility Index and the relatives mobility of
compounds.
              Relative Mobility Index           Mobility Descriptions

                     >5.00                    Extremely Mobile
               0.0 to 5.00                     Very Mobile
              -5.0 to 0.00                     Slightly Mobile
              -10.0 to -5.00                    Very Immobile

    • Chlorinated Ethenes. Chlorinated ethenes including tetrachloroethene, trichloroethene, 1,1-
dichloroethene, and 1,2-dichloroethene (total) were detected in groundwater, surface soil, and
subsurface soil  samples collected during the  RI.   Tetrachloroethene,  trichloroethene, and
dichloroethenes are common  degreasing and extraction solvents.   It is  also known that the
dichloroethenes  are  potential  anaerobic degradation products  of  tetrachloroethene and
trichloroethene.

             MOBILITY INDICES FOR CHLORINATED ETHENES

       Compound         Mobility Index             Mobility

   Tetrachloroethene             0.87                 Very Mobile
   Trichloroethene               2.70                 Very Mobile
   1,1 -Dichloroethene           4.32                 Extremely Mobile
   Trans-l,2-Dichloroethene      4.54                 Extremely Mobile
Groundwater  samples from  monitoring wells near  or  at  the OCI facility contain high
concentrations of tetrachloroethene and trichloroethene.   Groundwater  samples  taken from
monitoring wells downgradient from the facility had concentrations of tetrachloroethene and
trichloroethene which were much lower than those found in samples taken from wells nearer to
the facility.  For example, samples collected on the OCI facility, from MW1, contained
160 mg/L (J) of tetrachloroethene and  21,000 ug/L of trichloroethene.  Samples that were
collected 250 feet west of the seepage lagoon, MW4, did not contain either of these compounds
(Figure 9).

   • Chlorinated Ethanes.  Groundwater, surface soil, and subsurface soil samples taken during
the RI contained 1,1,1-trichloromethane,  1,1,2,2-tetrachloroethane, 1,1-dichloroethane, and 1,2-
dichloroethane.  Chlorinated ethanes are widely used as degreasing and extraction solvents and
intermediates in chemical synthesis.  Like the chlorinated ethenes, chlorinated ethanes can also

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                                         13

undergo  anaerobic reductive  dehalogenation.   Therefore,  the dichloroethanes are potential
anaerobic degradation products of tetrachloroethane and trichloromethane.

In general, as the number of chlorine atoms per molecule decrease, the water solubilities and
vapor pressures increase  and  the organic carbon partition coefficients decrease.   This would
indicate that the relative mobilities as represented by the mobility index, would increase with a
decrease in chlorine contents,  as show below:
                MOBILITY INDICES FOR CHLORINATED ETHANES

   Compound             Mobility Index             Mobility

   1,1,1 -trichloroethane       3.08                    Very Mobile
   1,1-dichloroethane          4.59                    Very Mobile
   1,2-dichloroethane          5.19                    Extremely Mobile

As with chlorinated ethenes, the mobility index or migration potential of chlorinated ethanes
increases with a decrease in chlorine content.  In MW1, samples  collected on the OCI facility
contained 6 ug/L (J) of 1,1-dichloroethane and 51 ug/L (J) of 1,2-dichloroethane.  Samples that
were  collected 250  feet west of the seepage lagoon, MW4,  contained  6 ug/L of  1,1-
dichloroethane and no 1,2 dichloroethane (Figure 10).

   • Aromatics. Benzene, toluene, chlorobenzene, ethyl benzene and xylene were detected in
the ground  water, surface soil,  and subsurface soil,  during the RI.   These compounds,
characterized as containing an aromatic or benzene ring, are common chemicals used in a variety
of industrial processes.

   The calculated mobility indices for the aromatic compounds are shown below.  The mobility
indices suggest that aromatic compounds are generally less mobile than chlorinated ethenes and
ethanes.  This is substantiated by  the data, for example, the concentration of toluene dropped
from  42,000 ug/L (J) in MW1  to  1 ug/L (J) in  MW4,  while the  concentration of  1,1-
dichloroethane remained the same from MW1 to MW4 (Figure 10).
           MOBILITY INDICES FOR AROMATIC COMPOUNDS

       Compound          Mobility Index             Mobility

   Benzene                      3.3                  Extremely Mobile
   Ethylbenzene                -0.01                 Slightly Mobile
   Chlorobenzene                1.2                  Very Mobile
   Toluene                      1.7 ^                Very Mobile
   Xylene                       0.9                  Very Mobile

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                                          14

   1,2-dichlorobenzene           -0.23                 Slightly Mobile
   1,3-dichlorobenzene           -0.78                 Slightly Mobile
   1,4-dichlorobenzene           0.05                 Very Mobile
   1,2,4-trichlorobenzene         -1.24                 Slightly Mobile

Tentatively Identified And Unknown Compounds.

   • Tentatively identified and "unknown" compounds were detected in the groundwater, surface
soils, subsurface soils and test pit soils at the OCI site.  These analytical results are presented
in Appendix E of the FFS.

Based on  the above information, it is  necessary  to implement this interim  action to stop
migration of the contaminant plume.

VI. Summary of Site Risks

The following groundwater exposure scenario was evaluated quantitatively:  a future ingestion
of drinking water for adults only and potential for current ingestion of drinking  water from the
private wells.  Due to the limited scope of the FFS and the unlikelihood of future  residential land
use, only one exposure pathway was chosen to evaluate potential  future adverse health risks
associated with exposure to contaminated  groundwater. This scenario assumes that contaminated
ground water will migrate to the LGS  where it would be a potable water source.

A. Toxicity Assessment Summary

Cancer potency factors (CPFs) have been developed by U.S. EPA's Carcinogenic Assessment
Group for estimating excess lifetime cancer  risks associated with exposure to potentially
carcinogenic chemicals.  CPFs, which are expressed in units of (mg/kg-day)"1, are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate
of the excess lifetime cancer risk associated with exposure at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated from the CPF. Use of this
approach makes underestimation  of the  actual cancer risk highly unlikely. Cancer potency
factors are derived  from the results  of human epidemiological  studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty factors have been applied.
See Table 5.

Reference doses (RfDs) have been developed by U.S. EPA for indicating the potential for
adverse health effects from exposure to  chemicals exhibiting noncarcinogenic  effects.  RfDs,
which are expressed  in units of mg/kg-day, are estimates of lifetime daily exposure  levels for
humans,  including sensitive individuals.   Estimated intakes of chemicals from environmental
media(e.g., the  amount of a chemical  ingested from  contaminated drinking  water) can  be
compared to the RfD. RfDs are derived  from human epidemiological studies or animal studies
to which uncertainty factors have been applied (e.g., to account for the use of animal data to
predict effects on humans). These uncertainty factors assure that the RfDs will not underestimate

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                                          15

the potential for adverse non carcinogenic effects to occur.

Excess  lifetime cancer risks are determined by multiplying the intake level with the cancer
potency factor.  These risks are probabilities that are  generally expressed in scientific notation
(e.g., IxlO"6 or 1E-6).  An excess lifetime cancer risk of 1x10"* indicates that, as a plausible
upper bound, an individual has a one in a million chance of developing cancer as a result of site-
related  exposure to a carcinogen  over a 70-year lifetime under the specific conditions at a site.

Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HQ) (or the ratio of the  estimated intake derived from the
contaminant concentration in a given medium to the contaminants reference dose). By adding
the HQs for all contaminants within a medium or across all media to which a given population
may reasonably be exposed, the Hazard Index (HI) can be generated. The HI provides a useful
reference point for gauging the potential significance of multiple contaminant exposures within
a single or across media.

Excess  cancer risk estimates were calculated for exposures to carcinogenic indicator chemicals
by  summing the product of the chronic daily intakes (GDI) and cancer potency factor for all
carcinogenic indicator chemicals  and  intake routes for a given human receptor.  Hazard indices
were calculated for exposures to non-carcinogenic indicator chemicals by summing the ratios of
GDIs to acceptable daily intakes (reference doses) for all chemicals and intake routes for a given
human receptor.

B. Risk Summary

A current potential groundwater use for each private well was evaluated for ingestion of drinking
water.   A chronic hazard index of 1.91  was estimated for PW01.  Lead (1.88), copper (.01),
and zinc (.02) were associated with this risk. These  contaminants may be associated with the
type of plumbing used, rather than site related contaminants.  PW02 and PW03 both had chronic
hazard indices less than one.

Excess  cancer risk for current potential groundwater use from PW02 was zero because no
carcinogens were detected.  The estimated excess lifetime cancer risks for PW01 (7.84x 10"s) and
PW03 (2x10^) were within the EPA  range of concern of 10* and 104.

The future exposure  scenario  included residential groundwater use. Only  exposure to
groundwater was assessed under the future residential  scenario.  A chronic hazard index of 17.6
was estimated for potential future residential use of  groundwater.   This indicated a potential
noncarcinogenic health risk for  this hypothetical scenario.  Trichloroethene in  groundwater
accounted for approximately  79 percent of this noncarcinogenic risk.   Both toluene and N-
nitrosodiphenylamine accounted for approximately 11 percent.

Excess  cancer risk for potential future  residential  groundwater use was estimated at 3xlO*3.
Vinyl chloride (SxlO4), trichloroethene (8x40^), 1,1-dichloroethene (3x10"*), and Arsenic(3xlO"J)

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                                          16

 accounted for the majority of this excess cancer risk.

 The OCI site poses an imminent and substantial endangerment to public health, welfare or the
 environment.  Implementation of the selected remedy should stop further migration  of the
 contaminant plume, achieving significant risk reduction while a final solution is being developed.

 VII. Description of Alternatives

 By combining selected technologies, four alternatives were developed for this interim action to
 address the contaminated ground water in the UGS.  The four alternatives  developed for this
 interim action are:

   •   Alternative 1 — no action;

   •   Alternative 2 — source containment, groundwater monitoring, and  land use and deed
       restrictions;

   •   Alternative 3 — groundwater collection, groundwater monitoring, UV/oxidation, activated
       sludge and discharge;

   •   Alternative 4 — groundwater collection, groundwater monitoring,  granular activated
       carbon (GAC), air stripping and discharge.

A. Alternative 1 — No Action

The no action alternative is required by the National Contingency  Plan (NCP).  Under the no
action alternative, the site is left "as is" and no funds are expended for monitoring, control or
cleanup of contamination associated with the OCI site. This alternative serves as a baseline for
comparison with the other alternatives.

The capital and present worth cost for this alternative is $0.

B. Alternative 2 - Source Containment, Groundwater Monitoring, and Institutional Controls

Alternative 2 includes the construction of a multi-media RCRA Subtitle C cap above the former
seepage lagoon, groundwater monitoring and land use and deed restrictions.

The multi-media RCRA Subtitle C cap from bottom to top would consist of compacted clay, a
synthetic membrane, a drainage layer, compacted native soil, top  soil and  a vegetative layer.
A cross-section of the cap is shown  on Figure 14. The cap would be 120 feet long and 120 feet
wide.

A monitoring well sampling program would be initiated to determine the effectiveness of the
multi-media RCRA cap in reducing contaminated leachate from entering groundwater.  This

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                                          17

alternative should be designed and constructed within a year to eighteen months.

Institutional controls, such as land use and deed restrictions would also be applied to the site.
The objectives of these restrictions are to prevent exposure to harmful contaminants in the
groundwater and the former seepage lagoon and to control future development or excavation at
the site.

The capital cost of this alternative is $95,000 with O&M of $27,000.  The present worth cost
is $510,000.

C. Alternative 3 ~ Groundwater Monitoring,  Groundwater Collection, UV/Oxidation Activated
Sludge and Discharge

Alternative 3 includes groundwater monitoring, groundwater collection, UV/Oxidation, activated
sludge treatment and discharge of treated water to the Grand River.

A monitoring well sampling program would  be initiated to determine the effectiveness of the
groundwater extraction system in reducing contaminated groundwater  from entering the LGS.
This alternative could be designed and constructed within a year to eighteen months.

Based on the groundwater extraction schemes developed, approximately 40 gpm of water would
be extracted from  three extraction wells  on site.  Following extraction, the contaminated
groundwater would be pumped  through a pipe network to an onsite groundwater treatment
facility. The treatment system would consist  of an equalization basin, a UV/Oxidation reactor,
an activated sludge unit, and a multi-media filter.  After the first five years of remedial action,
the activated sludge unit and  multi-media filter will be replaced by a GAC unit.  This change
is necessary because of an expected decrease in influent BOD after five years of pumping.

The treatment  facility will be located on the OCI property approximately 150 feet north of the
OCI office building. Following treatment, water  would travel  by gravity flow approximately
5,000 feet north of the treatment  facility  to the Grand River.   Figure 15 illustrates the
preliminary locations of the  extraction  wells,  the piping routes,  the groundwater treatment
facility and the Grand River discharge point.

It should  be  noted that  the activated sludge process  was chosen as an applicable  and
representative biological treatment process so that the cost to implement Alternative 3  might be
estimated.  The final biological treatment process would be selected during remedial design as
part of a treatability study during the design of this system.

Action-specific Applicable or Relavant and  Appropriate Requirements  (ARAR)s which are
applicable for the site pertain to the construction of the groundwater collection system and
treatment process, the treatment and subsequent discharge of the treated groundwater, and the
management of treatment  residuals in accordance with the Land Disposal Restriction (LDR)
requirements of RCRA,  as  these residuals would contain listed hazardous  wastes.   The

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                                          18

groundwater would be treated to surface water quality standards for organic  and inorganic
contaminants before being discharged to the Grand River.

The capital cost is $1,323,000 with O&M of $291,000. The present worth cost is $5,787,000.

Alternative 4 -Groundwater Monitoring, Groundwater Collection, Granular Activated Carbon
(GAC) Air Stripping and Discharge

Alternative 4 includes groundwater monitoring, groundwater collection, GAC treatment followed
by Air Stripping and discharge of treated water to the Grand River.

A monitoring well sampling program would be initiated to determine the effectiveness of the
groundwater extraction system in reducing contaminated groundwater from entering the LGS.
This alternative could be designed and constructed within a year to eighteen months.

The groundwater extraction schemes for this alternative are the same as alternative 3. Following
extraction, the contaminated groundwater would be pumped through a pipe network to an onsite
groundwater  treatment   facility.     The  treatment   system   would  consist   of  an
equalization/sedimentation basin, two GAC vessels and an air stripper. The majority of volatile
organic compounds would be removed in the GAC vessels.  The air stripper would be used only
as a polishing unit.   Therefore, off-gas vapor control is not expected to be  needed.  The
discharges from the air stripper will meet the requirements of state code MAC R336.1701-. 1702.
The residua] GAC from this treatment process would be properly treated in accordance with
LDR requirements and disposed of off-site at a RCRA permitted landfill because it will contain
listed hazardous wastes.   If the residual GAC is regenerated it must be done  in a RCRA
permitted treatment unit which is in compliance with 40 CFR Part 264 Subpart  X. Following
treatment, water will be pumped to the Grand River located approximately 5,000 feet north of
the facility.  Actual discharge limits would be established in accordance with the requirements
of the  Clean Water Act  (CWA) NPDES program.  A treatability study during predesign is
necessary for the proper design of this system.

The capital cost  is  $1,065,000  and the O&M cost  is $317,000.   Present  worth cost is
$5,931,000.

VII. Comparative Analysis of Alternatives

In order  to determine the most appropriate  alternative for the OCI site,  the alternatives were
evaluated against each other.  Comparisons were based on the nine evaluation criteria.
The nine criteria are: 1) overall protection of human health and the environment, 2) compliance
with applicable or  relevant and  appropriate requirements, 3) long-term effectiveness and
permanence, 4) reduction of toxicity, mobility, and volume, through treatment, 5) short-term
effectiveness, 6) implementability, 7) cost, 8) state acceptance, and 9) community acceptance.
However, due to the limited scope of this interim action, as discussed below, certain of these
criteria are not relavent in selecting the appropriate alternative.

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                                          19

A. Overall Protection of Human Health and the Environment

All of the remedial alternatives considered for the OCI site are protective of human health and
the environment by eliminating, reducing, or controlling risks at the OCI site with the exception
of the no action alternative.  As the no action alternative does not provide protection of human
health and the environment, it is  not eligible for selection and shall not be discussed further.
Alternative 2 would reduce infiltration through the highly contaminated  material at the site
although it would provide  minimal  control of contaminant migration in the  groundwater.
Alternatives 3 and 4 would gradually remove contaminants, thereby reducing the risks from
ingestion and further off-site migration.

B. Compliance With ARARs                                             :

Each alternative is evaluated for compliance with ARARS, including chemical specific, action
specific, and location specific ARARS. The alternatives presented for the interim action will
comply with those standards that  are associated within the limited scope of this interim action.
In accordance with Section 121(d)(4) of CERCLA,  this remedial action is  only part of a total
remedial action and will attain the ARAR with regard to ground-water cleanup upon completion.
The final response action will attain all ARARs unless a waiver is invoked.

The following are ARARs that the alternatives would comply with: for alternative 2, RCRA
Subtitle C for the construction of the cap; for alternatives 3 and 4,  RCRA 40 CFR Part 264
Subpart J  for the construction and operation of the sedimentation and equalization basin;  for
alternatives 3 and 4 the Clean Water Act for discharge to the Grand River and state code MAC
R336.1701-.1702 for discharges  to the air; spent carbon if land disposed will comply with
treatment standards of 40 CFR 268.41 and, if regenerated, 40 CFR Part 264 Subpart X.

C. Long-Term Effectiveness and  Permanence

This criterion is not applicable because this interim  action is designed to protect human  health
and the environment while longer term measures are being determined.
D. Reduction of Toxicity, Mobility, or Volume (TMV) Through Treatment

This evaluation addresses the statutory preference for selecting remedial actions that employ
treatment technologies which permanently and significantly reduce toxicity, mobility, or volume
of the hazardous substances. This preference is satisfied when treatment is used to reduce the
principal threats at a site through destruction of toxic contaminants, irreversible reduction of
contaminant mobility, or reduction of total volume of contaminated media.

Alternative 2 will not reduce the toxicity, mobility, or volume through treatment. Alternative
3, by removing and treating the groundwater with physical and biological treatment, will reduce
the toxicity and the mobility of the groundwater plume as well as the volume of the plume.

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                                          20

The toxicity,  mobility, and  volume  of the contaminated  material will not be reduced by
Alternative 4 by treatment if the residual carbon is land disposed because the contaminants will
only be transferred to the residual carbon and the air by the air stripper.  If the residual carbon
is regenerated, which will likely be more cost-effective then the toxicity, mobility, and volume
of the contaminated material will be reduced by treatment.

E. Short-Term Effectiveness

This evaluation focuses on the effects to human health and the environment which may occur
while the alternative is being implemented and until the remedial objectives are met.  The
following factors  were used to evaluate the short term effectiveness of each alternative:
protection of the community during remedial actions, protection of workers during remedial
actions, environmental impacts from implementation of alternatives, and time until remedial
objectives are met.

Construction operations associated with Alternatives 2, 3,  and 4  will  produce minimal
disturbance to the surrounding community.

With regard to the time until remedial objectives are met, Alternative 2 should take a few weeks
to a few months to implement.  Alternatives 3 and 4 will be operated until the final remedial
alternative is selected for the site, which is not expected to exceed 5 years.  With regard to
environmental impacts, alternatives 3 and 4 may result in a change in groundwater flow and will
have to be monitored so that no adverse impacts result in the potential wetland areas on the
opposite side of 1-196.  Also, alternative 3 relies on a biological system to treat contaminants
that is subject to upsets  resulting in occasional  exceedances of discharge requirements.
Alternative 4 is a physical-chemical system that will not be subject to these upsets.

None of these alternatives will result in unacceptable short-term risks to workers, residents, or
the environment.

F. Implementablity

This evaluation addresses the  technical and  administrative feasibility of  implementing the
alternatives  and the availability of the  various  services and materials required  during  its
implementation.

Alternative 2,  capping, is well demonstrated and commercially available. Alternatives 3 and 4
are proven technologies and are commercially available.

Administratively,  none  of  the  alternatives  should  have  any  problem  with  regard  to,
implementation, although sludge from the alternative 3 treatment process will be considered a
hazardous waste because the groundwater was contaminated as a result of improper discharges
of F001 through F005 wastes from the OCI facility. The sludge will have to be .delisted before

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                                          21
it could be considered a non-hazardous waste or treated in accordance with LDRs prior to
disposal.
G.  Cost

This evaluation examines the estimated costs for implementing the remedial alternatives. Capital
and O&M cost are used to calculate estimated present worth costs for each alternative.
Alternative 2 has a capital cost of $95,000 and an O&M cost of $27,000.  Total present worth
is $510,000.  Alternatives 3 and 4  are  very  similar with regard to meeting  the  remedial
objectives, alternative 3 has  slightly less present worth cost of $5,787,000 while alternative 4
has a present worth cost of $5,931,000. The capital and O&M for alternative 3 were $1,323,000
and $291,000  respectively. The capital and O&M costs for alternative 4 were $1,065,000 and
$317,000 respectively. The present worth cost of alternative 2 is significantly less  than 3 and
4  but it fails to meet  the remedial objective  of halting  contaminant plume  migration.
Alternatives 3 and 4 present worth cost are very close to each other.

H.  State Acceptance

The State of Michigan concurs with EPA's selection of alternative 4 for the interim action at the
OCI site.

I. Community Acceptance

Community response to  the alternatives  is presented in the responsiveness summary, which
addresses comments  received during the public comment period.

IX. The Selected Remedy

After considering the requirements of CERCLA, the detailed analysis of alternatives, and public
comments, EPA has selected Alternative 4 for  the interim action at OCI:

Alternative 4 - Install, operate and maintain an interim ground water extraction system in the
upper ground-water system consisting of, at a minimum, three extraction wells.  Install, operate
and maintain a ground-water physical-chemical treatment system for the interim ground-water
action.

A treatability study along with a pump test will be performed as part of design to determine the
proper treatment train and pumping rates.  Ground water will be properly treated to comply with
NPDES  discharge limitations.  The  residuals  from this treatment  process will  be treated in
accordance  with  LDRs  and properly disposed off-site at a  RCRA permitted  landfill  or
regenerated in a RCRA permitted treatment unit which is in compliance with 40 CFR Part 264
Subpart X because the residuals will contain listed hazardous wastes.

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                                         22
 The primary goal of this interim action is to stop contaminant plume migration thereby reducing
 threats to public health and the environment.
The capital cost  is $1,065,000 and  the  O&M cost  is $317,000.   Present worth cost is
$5,931,000.

X.  Statutory Determinations

The selected remedy must satisfy the requirements of Section 121(a-e) of CERCLA to:

  A.  Protect human health and the environment;
  B.  Comply with ARARs;
  C.  Be cost-effective;
  D.  Utilize permanent solutions and alternate treatment technologies to the maximum extent
       practicable; and,
  E.  Satisfy a preference for treatment as a principle element of the remedy.

The implementation of Alternative 4 at the OCI site satisfies the requirements of CERCLA as
detailed below:

A. Protection of Human Health and the Environment

Implementation of the selected alternative will reduce and control potential risks to human health
and the environment by halting the flow of the contaminant plume off the site. With regard to
the community and onsite workers, the selected alternative will provide minimal disturbance and
therefore minimal risk to the community and onsite workers.

Protection of human health and the environment will be achieved by future response actions that
further address contaminated groundwater and soil.

B. Compliance With ARARS

The selected interim action will comply with those ARARs that are pertinent, given the limited
scope of this action. The ARARs for  the interim action are listed below.

B. 1 Chemical-specific ARARS

Chemical-specific ARARs regulate the release to the environment of specific substances having
certain chemical characteristics.  Chemical-specific ARARs typically determine the extent of
cleanup at a site.

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                                         23

B.I.a Groundwater

In accordance with Section 121(d)(4) of CERCLA, this remedial action is only part of a total
remedial action and will attain the ARAR with regard to ground-water cleanup upon completion
of future response actions.

B.l.b Surface Water

i. State ARARs

Section 303 of the  CWA requires the State to promulgate state water quality standards for
surface water bodies, based on the designated uses of the surface water bodies.  CERCLA
remedial actions involving  surface water bodies must ensure that applicable or relevant and
appropriate  state water quality standards are met.   The standards established pursuant to
R323.2102-.2189 of the Michigan Water Resources Commission Act, Public Act 245 of 1929,
as amended, would be applicable to this site. The Grand River near the OCI site is designated
a cold  water fishery.

B.2 Location-specific ARARs

Location-specific ARARs are those requirements that relate to the geographical position of a site.

i. Federal ARARs

Executive Order 11990 - Protection of Wetlands is an applicable requirement to protect against
the loss or degradation of wetlands.  As discussed above, Alternative 4  should be designed not
to have an adverse effect on wetland areas on the opposite side of 1-196.

ii. State ARARs

The Goemaere-Anderson Wetland Protection Act of 1979 (Act 203) regulates any activity which
may take place in wetlands in the State of Michigan. As discussed above the selected alternative
should be designed to not adversely effect wetland areas.

B.3 Action-specific ARARs

Action-specific ARARs are requirements that define acceptable treatment and disposal procedures
for hazardous substances.

i. Federal and State  RCRA ARARs

The substantive requirements of RCRA  waste generation and temporary storage  regulations
under  40 CFR Part 262 and MAC R299.9601-.ll 107 are  applicable  when  managing the
treatment residuals from the ground water system (e.g., residual carbon).  Also, Federal and

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                                          24

State RCRA LDRs governing off site disposal are applicable to the disposal of treatment
residuals.

ii.  State ARARS

The State is authorized to implement the National Pollutant Discharge Elimination System
(NPDES) program. The requirements of a Michigan Pollutant Discharge Elimination System
(MPDES) permit, under MAC R323.2102-.2189 would be applied to the discharge of the treated
water into the Grand River. Subject to the approval of the U.S. EPA, effluent limits for surface
water discharge will be established by the MDNR.

MAC R336.1701-. 1702 regulates air emissions from treatment technologies and is applicable to
point source emissions from industrial  facilities.  Because air strippers may emit hazardous
substances in the form of VOCs, this section is applicable to the remedy. The need for emission
control  technology shall be evaluated based  on requirements  of this section.  If air stripper
emissions are projected  to exceed standards  at the OCI property boundary, the point of
compliance, then vapor control technology such as vapor phase activated carbon will be included
in the treatment system to bring air emissions into compliance.

Additional action-specific ARARSs are found in the FS.

C. Cost-effectiveness

EPA believes the selected remedy is cost-effective in preventing the migration of contaminated
ground  water at the site.  Cost-effectiveness compares the effectiveness of an alternative in
proportion to its cost of providing its environmental benefits. Alternative 2 was the least costly
of the three alternatives but failed to meet the objective of the remedial action of stopping further
migration of the contaminant plume. Alternatives 3 and 4 both met the remedial action objectives
and cost relatively the same. Alternative 3 is more effective with regard to the reduction of TMV
only if the residuals from alternative 4 are land disposed.  If the residuals from alternative 4 are
regenerated, alternative 4 has the same reduction of TMV through treatment.  Alternative 4 has
significantly greater performance with regard to short-term effectiveness. Alternative 4 provides
overall effectiveness proportional to its cost and represents a reasonable value.

D. Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent Practicable

EPA and the State of Michigan believe the selected remedy for the OCI Site represent the
maximum extent to which permanent solutions  and treatment technologies can be utilized  in a
cost-effective manner  for the interim action.  The Alternative represents the best balance of
tradeoffs among the alternatives with respect  to the pertinent criteria given the limited scope of
the action, (see above).

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                                           25



E. Preference for Treatment as a Principal Element




This preference will be addressed  in the final decision document for this site.

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                             City of
                            Grandville
                      HIVEHTOWN PARKWAY
NO SCALE
                                FIGURE   I'
                                OCI SITE LOCATION MAP
                                ORGANIC CHEMICALS, INC. SITE

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                                                   ORGANIC CHEMICALS. INC. SITE

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PLAN LOCATION OF GEOLOGIC CROSS SECTION
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                                                                                                                                               NORTH-SOUTH GEOLOGIC CROSS SECTION A-A'
                                                                                                                                               ORGANIC CHEMICALS. INC. SITE

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                                                                                                                                                          ORGANIC CHEMICALS. INC SITE

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ORGANIC CHEMICALS. INC. SITE

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                                                                                                                                                                  FIGURE 8
                                                                                                                                                                  EAST-WEST GEOLOGIC CROSS SECTION D-D1

                                                                                                                                                                  ORGANIC CHEMICALS. INC. SITE

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V

*
• - PRIVATE WELL
•  - SOILBORINO
•  - MONITORING WELL
      450'      O1       450^	900'
FIGURE «»
MONITORING WELL LOCATIONS
ORGANIC CHEMICALS, INC. SITE

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«.

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M
                                                                                                                                          FIGURE I!
                                                                                                                                          INORGANIC OROUNDWATER RESULTS (ug/L)
                                                                                                                                          ORGANIC CHEMICALS, INC. SITE

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FIGURE f-t
ORGANIC OROUNDWATER RESULTS (ug/L)
ORGANIC CHEMICALS. INC. SITE

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u
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 i
                                                                                                                                                                                  LEGEND:


                                                                                                                                                                                     SOU BORING

                                                                                                                                                                                     MONIIOHING  Will

                                                                                                                                                                                     II.SI Pll
FIGURE IZ

ORGANIC SOIL DORING AND TEST PIT RESULTS

ORGANIC CHEMICALS, INC. SITE

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ANALYTICAL DATA PRESENTED H I«fllE S3
                     LEGEND:
                     A SS - SURFACE SOIL LOCATIONS
                         FIGURE 13
                         ORGANIC SURFACE SOIL RESULT:-: (ug/kg)
                         ORGANIC CHEMICALS, INC. SITE

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RCRA Multi-media Cap
                                              i   i    i    i   i    i   i    i
                                              i   i    i    i   i    i       i
                                              i   i    i    i   i    i   i
0.5* Topsoil

1.5'Native Soil

1* Drainage Layer
30 Mil Synthetic Membrane1

2' Clay (Hydraulic Conductivity^ OE-7 cm/sec):
                                                                           FIGURE  IM
                                                                           CROSS-SECTION OF MULTI MEDIA RCRA CAP
                                                                           ORGANIC CHEMICALS, INC. SITE

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                     DISCHARGE TO GRAND RIVER (2300 FT)
LEGEND:

  •      EXTRACTION WELL
 	      PIPING
         GROUNDWATER TREATMENT FACILITY
  pURE 15
  LTERNATIVE 3 & 4:  EXTRACTION WELLS, PIPING
ROUTES AND TREATMENT FACILITY LOCATIONS
ORGANIC CHEMICALS. INC. SITE

-------
                                 TABLE  1
              PHYSICAL/CHEMICAL PARAMETERS FOR GROUNDWATER
                                  ROUND 1
                                  ANALYTE
SAMPLE
LOCATION
MW1
MW2
MW3
MW4
MW4D
MW5
MW6
MW7
MW8
MW9
MW10
MW11
MW 11D
MW 13
MW 14
MW15
MW 15D
MW 16
MW17
MW 18 **
MW19 *•
MW 20 ' '
MW21
MW22
MW23
SB7"
SB 8"
PW01
PW02
PW03
TDS
(mg/l)
636
719
2760
580
720
628
600J
616
487
2530
596
633J'
640J'
. 716
1650
1200
1140
750
379
1130
4190
261 OJ
845
560J'
470
12300J'
5630J*
1130
1560
787
TSS
(mg/l)
1380J'
852J'
6130J
1590J
1190J
1860J
1470J
64.5J
3500J*
2050J'
8960J'
12700J'
9970J •
2000J'
31. OJ-
965J
792J
16500J'
224J
1280J'
258J
45.5J
10100J
2500J'
1410J
299 J-
74.5J'
8.5J
12.5J
2U
COD
(mg/l)
464J
432J
272J
35. 3J'
80.0J'
66.9J'
113J'
26.4J
76.0J
144J
276J
2840J
2640J
184J
63.4J'
268J
59.8
184J
31. 2J
336J
268J
66. 9J'
328J
280J
190J'
928J-
313J'
5U
5.4J
5U
TOC
(mg/l)
10.0-
18.6'
3.0J1
3.5J'
3.5J'
4.1J'
2.7'
2UJ'
2.1J'
4.6'
3.6J'
8.9'
8.3'
7.3J-
5.5J'
2UJ'
2UJ'
32.1J'
2UJ'
25.8J'
4.5J'
2U'
2.2UJ'
5.3V
2UJ'
2U-
2U-
2U
2U
2U
TOX
(ug/L)
826J'
14000J'
26. OJ'
80J*
116J'
58.0J1
20.85J'
16.0J'
13.8J*
25.4J'
25.6'
33.6'
38.4J-
75.0"
27.4J-
11J'
SU'
37.2'
15.2J'
26.9'
20.7J'
118'
15.8J'
182J'
22.6J'
27.8J'
28.8J1
24.7J
17.2J
7.9J
BOD
(mg/l)
90 J'
15.7J'
22.5J'
7.9J*
4.1J'
4.7J*
6.4J-
2.1J1
2UJ'
2UJ'
4.1J'
79.2J'
35.2J-
2UJ-
4.0J'
2UJ-
4.0J'
45.4J'
4.0J'
91. OJ'
57.0J-
4.8J1
2.5J-
10J'
9.8J'
2UJ*
3.4J'
2UJ
2UJ
2UJ
ALKALINITY
(mg/l)
349J
369J
190J
322J
287J
284J
300J
237J
886J
363J
601 J
534J
606J
3.7J
346J
275J
288J
496J
245J
272J.
16U
164J
202J
226J
240J
132J
105J
190J
138J
192J
PH
6.88
6.91
—
—
—
—
6.95
—
6.5
6.97
6.74
6.9
—
6.73
--
6.78
--
--
7.6
6.81
--
6.9
--
6.9
7.7
6.91
6.26
--
--
--
Specific
Conductivity
(umhos)
930
604
—
--
—
--
640
--
668
2000
755
700
--
843
--
1564
--
--
599
580
--
Temp
(C)
17.1
14.3
--

—
—
13.7
--
16
13.4
18.5
15.4
--
14.2
--
16.1
--
--
16.8
17.8
--
1040 | 13.8
--
865
669
6180
5270
--
--
--
--
14.7
16.8
11.1
11.8
--
--
--
NOTE:
J - ESTIMATED
U - UNDETECTED
• - RESAMPLING DATA TO FOLLOW
D - DUPLICATE
-- - NOT TESTED OR ANALYZED
•' = LGS MONITORING WELLS
SB-10 '' WAS NOT SAMPLED DURING ROUND 1
GROUNDWATER SAMPLING
TDS - TOTAL DISSOLVED SOLIDS
TSS - TOTAL SUSPENDED SOLIDS
COD « CHEMICAL OXYGEN DEMAND
TOC - TOTAL ORGANIC CARBON
TOX = TOTAL ORGANIC HALIDE
BOD = BIOCHEMICAL OXYGEN DEMAND

-------
                                 TABLE  2
              PHYSICAL/CHEMICAL PARAMETERS FOR GROUNDWATER
                                  ROUND 2
                                  ANALYTE
SAMPLE
LOCATION
MW1
MW2
MW3
MW4
MW5
MW6
MW6D
MW7
MW8
MW8D
MW9
MW10
MW11
MW13
MW14
MW15
MW16
MW17
MW18"
MW19"
MW 20 • •
MW2T
MW21D
MW22
MW23
SB 7"
SB 8"
SB 10"
TDS
(mg/I)
61 7J
587J
2960J
640J
468J
470J
460J
628J
445J
397J
2450J
504J
400J*
693J
1670J
1050J
540J
380J
2840J
4350J
2390J
81 7J
693J
457J*
41 7J
11500J*
5400J'
11200J*
TSS
(mg/l)
1070J*
1660J'
18500
502J
720
1140
2450
1170
2340J'
2080J'
2730J'
904J*
251 OOJ'
5290J'
458J'
764
945J'
165
292J'
1270
407
4190
5290
660J'
2040
179J'
151J*
2470J'
COD
(mo/I)
321J
159J
242J
27J*
37J'
44J*
79J'
44J
56J
52J
91J
25J
474J
75J
33J'
32J
179J
20J
222J
91J
37J'
75J
83J
125J
135J'
95 J'
139J*
198J'
TOC
(mo/l)
16J'
6.1J*
1.7J*
3J*
3.7J*
3.1J'
3.2J*
3J'
1.1J*
58J*
2.8J'
2.8J'
76J'
3J'
6.1J'
1.5J'
24J'
3.9J*
57J'
2.5J*
2.7J'
19J'
29 J*
5.7J'
43J*
4.3J'
11J-
5.7J'
TOX
(uo^-)
~
—
6.7*
—
45*
5U*
SU'
12*
6.7*
—
20*
—
—
25'
—
«
~
5U'
—
SU*
5.2*
5U1
5U'
..
9.7*
—
—
—
BOD
(mo/I)
63J-
19J'
21J*
6J'
5J*
5J*
5J*
5J*
2UJ*
2UJ'
4J*
4J'
18J'
2UJ*
3J*
2UJ*
9J'
3J*
117J*
6J*
13J*
4J'
4J-
14J'
12J'
8J-
SJ*
21J1
ALKALINITY
(mfl/l)
430J
31 3J
1890J
287J
285J
299J
331J
271J
432J
436J
285J
380J
590J
343J
352J
271J
374J
168J
127J
249J
170J
287J
333J
31 5 J
333J
131J
115J
72J
pH
7.3
7.87
7.04
7.03
7.58
7.52
—
6.93
7.3
—
7.32
9.2
7.38
7.11
7.15
7.35
7.47
7
7.6
7.44
9.14
6.76
«
7.33
9.39
7.6
8.53
--
Specific
Conductivity
(umhos)
820
770
1350
900
610
648
—
888
486
—
1910
700
623
610
2200
1230
670
593
2420
4320
2100
651
—
607
615
12730
5090
10300
Temp
(C)
14
13
11
12
11
11
~
12
12
—
10
11
13
10
12
11
11
12
11
11
12
12
--
13
12
9
11
--
NOTE:
J • ESTIMATED
U - UNDETECTED
• - RESAMPLING DATA TO FOLLOW
D - DUPLICATE
— « NOT TESTED OR ANALYZED
• * - LGS MONITORING WELLS
TOS - TOTAL DISSOLVED SOLIDS '
TSS - TOTAL SUSPENDED SOLIDS
COD - CHEMICAL OXYGEN DEMAND
TOC - TOTAL ORGANIC CARBON
TOX - TOTAL ORGANIC HALIDE
BOD - BIOCHEMICAL OXYGEN DEMAND

-------
Table 3
Area of Contamination
Upper Ground-Water
System








Contaminants Found
Trichloroethene

Toluene
Xylene
Monochlorobenzene
Vinyl chloride
1-ldichloroethene
Arsenic
Benzene
Bis ( 2-ethylhexyl )
*\K4-K A 1 a+- A
Estimated Concentrations
Found (ua/L)
6,700

12,700
1,700
300
31
42
15
105
T Mjm4
MCL
Level (ua/L) !
5 .

1,000
10,000
100
2
7
50
5
k &**<»{ 1 AW1««.

-------
                            TABLE 4
               SUMMARY OF COMPOUNDS DETECTED
VOLATILE ORGANIC
COMPOUND
1 ,1 ,2.2-Tetrachloroethane
Tetrachloroethene
1,2-Trichloroethene
1,1,1-Trichloroethane
Trichloroethene
1,2-Dichloroethane
1,2-Dichloroethene
1.1-Dichloroethane
1,1-Dichloroethene
Vinyl Chloride
Chloroform
Benzene
Toluene
Ethyl Benzene
Chlorobenzene
Styrene
Xylene (total)
Phenol
1.2-Dichloropropane
2-Hexanone
4-Methyi-2-Pentanone
2-Butanone
Carbon Disulfide
Acetone
Methylene Chloride
SURFACE
SOIL

X
X

X
X





X
X
X


X






X
X
SUBSURFACE
SOIL'
X
X
X

X
X
X




X
X
X
X
X
X
X



X
X
X
X
GROUND
WATER

X

X
X
X
X
X
X
X
X
X
X
X
X
x-
X
X
X
X
X


X
X
 • Includes compounds detected in test pit soils.
Page 1 of 4

-------
                         •    TABLE H
                SUMMARY OF COMPOUNDS DETECTED
SEMIVOLATILE
ORGANIC COMPOUND
Acenaphthene
Fluorene
Phenanthrene
Bis(2-ethyl hexyl) phthalate
8is(2-chloroethyl) ether
Naphthalene
2-Methyl Naphthalene
N-nitroso diphenylamine
Benzyl alcohol
2-Methyl phenol
4-Methyl phenol
Benzoic Acid
Di-n-butyl phthalate
Dibenzofuran
Pentachlorophenol
Butyl benzyl phthalate
2.4-Dimethyl phenol
2-Chlorophenol
Di-n-octyl phthalate
Pyrene
Fluoranthene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
lndeno(i ,2,3-cd)pyrene
Diethyl phthalate
Anthracene
Chrysene
Benzo(g.h,i)perylene
SURFACE
SOIL
X

X
X

X
X
X




X
X

X


X
X
X
X

X
X
X
X
X
X
X
SUBSURFACE
SOIL '
X
X
X
X

X
X
X

X
X

X
X

X


X
X
X
X
X







GROUND
WATER
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X










 ' Includes compounds detected in test pit soils.
Page 2 oU

-------
                             TABLE  *j
                SUMMARY OF COMPOUNDS DETECTED
PESTICIDES/PCBS
Endosulfan sulfate
Aroclor 1242(PCB)
Aroclor 1248 (PCS)
Aroclor 1254 (PCB)
Aldrin
4,4- ODD
4.4-DDE
4,4-DDT
Gamma Chlordane
Lindane
Beta - BHC
Delta - BHC
Alpha Chlordane
Dieldrin
Heptachlor Epoxide
Dioxins
SURFACE
SOIL


X
X
X
X
X
X
X
X


X
X
X
X
SUBSURFACE
SOIL'

X
X

X
X
X
X
X
X
X
X




GROUND
WATER
X















 • Includes compounds detected in test pit soils.
Page 3 ol 4

-------
                             TABLE  H
                SUMMARY OF COMPOUNDS DETECTED
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
SURFACE
SOIL
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X


X

X
X
X
SUBSURFACE
SOIL'
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X

X
X
X
GROUND
WATER
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
  Includes compounds detected in test pit soils.
Page 4 of 4

-------
               TABLE 5-
TOMCITY VALUES FOR CHEMICALS OF CONCERN
CHEMICALS
Vinyl Chloride
Methylene Chloride
Acetone
1 ,1-Dichloroethene
1,1-Dichloroethane
1.2-Dlchloroethene (total)
1 ,2-Oichloroethane
1 .1 ,1-Trichloroethane
Trichloroethene
1,1.2-Trichlorotthane
Benzene
Tetrachloroethene
Toluene
Chlorobenzene
Ethyl benzene
Xylene (total)
Phenol
bit(2-Chloroethyl)Ether
Benzyl Alcohol
2-M8thylphenol
4-Methylprienol
2.4-Dimethylphenol
Benzole Acid
Naphthalene
2-Methylnaphthalene
Aeenaphthene
Oibenzofuran
Diethylphthalate
Fluorene
N-Nitroiodiphenylamine(l)
Phenanthrene
Anthracene
Di-n-Butylphthalate
Fluoranthene
Pyrene
Butyl Benzyl Phthalate
Benzo(a)Anthracene
bi»(2-Elhylhexyt)Phthalate
Chrytene
Oi-n-Octyt Phthalate
Benzo(b)Fluoranthene
Benzo(k)Ruoranthene
Benzo(a)Pyrene
lndeno(l ,2,3-cd)Pyrene
Benzo(o,h,l)Perylene
INHALATION
RID




VOE-01







2.0E+00
5.0E-03

3.0E-01





























INQESTION
RID

6.0E-02
1.0E-01
9.0E-03
1.0E-01
1.0E-02

9.0E-02
7.3E-03
4.0E-03

1.0E-02
2.0E-01
2.0E-02
1.0E-01
2.0E+00
O.OE-01

3.0E-01
6.0E-02
6.0E-02
2.0E-02
4.0E+00
4.0E-03
4.0E-03
4.0E-03

8.0E-01
4.0E-03

4.0E-03
3.0E-01
1.0E-01
4.0E-02
3.0E-02
2.0E-01
4.0E-03
2.0E-02
4.0E-03
2.0E-02
4.0E-03
4.0E-03
4.0E-03
4.0E-03
4.0E-03
REFERENCE

IRIS
IRIS
IRIS
HEAST
HEAST

IRIS
HEALTH ADV.
IRIS

IRIS
H EAST/IRIS
IRIS
IRIS
H EAST/IRIS
IRIS

HEAST
IRIS
IRIS
HEAST
IRIS
HEAST
NAPH
NAPH

IRIS
NAPH

NAPH
IRIS
IRIS
IRIS
IRIS
IRIS
NAPH
IRIS
NAPH
HEAST
NAPH
NAPH
NAPH
NAPH
NAPH
INHALATION
SLOPE
FACTOR
2.9E-01
1.4E-02

1.2E+00


8.1E-02

1.7E-02
6.7E-02
2.9E-02
3.3E-03





1.1E+00



























INQESTION
SLOPE
FACTOR
2.3E+CO
7.6E-03

e.OE-01


9.1E-02

1.1E-02
6.7E-02
2.9E-02
5.1E-02





1.1E+00











4.9E-03






1.2E+01
1.4E-02
1.2E+01

1.2E+01
1.2E+01
1.2E+01
1^E401
1.2E+01
WEIGHT
OF
EVIDENCE
A
B2

C
B2

B2

B2
C
A
B2
D

D
D
D
B2






B2










C
B2
82
B2

B2
62
B2
B2

REFERENCE
HEAST
IRIS

IRIS


IRIS
•-.
HEAST
IRIS
IRIS
HEAST





IRIS











IRIS






B(a)P
HEAST
B(a)P

B(a)P
B(a)P
HEAST
B(a)P
B(a)P

-------
                           TABLE  S
       TOXICITY VALUES FOR CHEMICALS OF CONCERN
CHEMICALS
Heptachlor
Dleldrtn
4.4-DDD
4,4'-DDT
Gamma-Chlordane
Arochlor-1248
Arochlor-1254
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Cobalt
Lead
Manganaee
Mercury
Silver
Zinc
Cyanide
Dioxins/Furans (HxCOO)
2.3,7.8 - TCOD
INHALATION
RID









1.0E-04





4.3E-04
3.0E-04






INGESTION
RfD
6.0E-04
5.0E-05

6.0E-04
6.0E-05



1.0E-03
7.0E-02
6.0E-03
5.0E-04
5.0E-03
1.0E-01

1.4E-03
1.0E-01
3.0E-04
3.0E-03
2.0E-01
2.0E-02


REFERENCE
IRIS
IRIS

IRIS
IRIS



HEAST
IRIS
HEAST
HEAST
IRIS
(•)

(b)
IRIS
HEAST
HEAST
HEAST
HEAST


INHALATION
SLOPE
FACTOR
4.5E+00
1.BE+01

3.4E-01
1.3E«00



8.0E+01

8.4E+00
8.1E+00
4.1E+01


4.0E-02





6.2E+03
1.5E+5
INQESTION
SLOPE
FACTOR
4.5E+00
1.8E+01
2.4E-01
3.4E-01
1.3E+00
7.7E+00
7.7E*00

1.7E+00

4.3E+00




4.0E-02





6.2E+03
1.5E+5
WEIGHT
OF
EVIDENCE
62
B2

B2
B2
B2
B2

A

82
B1



B2
0
0


0
B2
B2
REFERENCE
IRIS
IRIS
IRIS
IRIS .
IRIS
IRIS
IRIS

H EAST/IRIS

HEAST
HEAST
IRIS


EPA RES. 3





IRIS
HEAST
 NOTES:

  IRIS-
HEAST-
 NAPH-
    (a)-
   (b)-

   RfD-
 B(A)P-
INTEQRATED RESEARCH INFORMATION SYSTEM. (10/90)
HEALTH EFFECTS ASSESSMENT SUMMARY TABLES (3RD QUARTER. FY 1090)  '
NAPHTHALENE RfD VALUE. THIS IS NOT AN EPA VERIFIED RfD.
EST. RfD CALC. FROM THE PROPOSED DRINKING WATER STAND. OF 1.3 MG/L BY B&V.
RfD CLAC. BY B&V FOR THIS ASSESSMENT BASED ON PREVIOUS PROPOSED MCLG OF 0,02 MG7L
THIS IS NOT AN EPA VERIFIED RfD.
REFERENCE DOSE
BENZO(A)PYRENE DERIVED SLOPE FACTOR

-------
                                APPENDIX
                       RESPONSIVENESS SUMMARY
                     ORGANIC CHEMICALS INC. SITE
                        GRANDVILLE, MICHIGAN
I. Responsiveness Summary Overview

In accordance with CERCLA 117, the U.S. Environmental Protection Agency (U.S. EPA)
held a public comment period from July 22, 1990 through August 20, 1991 for interested
parties to comment on the  Proposed Plan (PP) for the interim remedial action at the
Organic Chemicals Inc. (OCI) Site in Grandville, Michigan.

The PP provides a summary of the background information leading up to the public
comment period.  Specifically, the PP includes information pertaining to the history of the
OCI Site, the scope of the proposed cleanup action and its role in the overall Site cleanup,
the risks presented by the Site, the descriptions of the remedial alternatives evaluated by
EPA, the identification of EPA's preferred alternative, the rationale for EPA's preferred
alternative, and the community's role in the remedy selection process.

EPA held a public meeting at 7:00 p.m. on August 6, 1991 at the Grandville City Council
Chambers in Grandville, Michigan  to outline the remedial alternatives for the interim
action described  in the PP and to present EPA's proposed remedial  alternative for
controlling contamination at the OCI Site.

The responsiveness  summary, required by  the Superfund Law, provides a summary of
citizens' comments  and concerns identified and received during  the public comment
period, and  EPA's responses to those comments and concerns. All comments received
by EPA during the public comment period will be considered in EPA's final decision for
selecting the remedial alternative for addressing contamination at the OCI Site.

This responsiveness summary is organized into sections and appendices as described
below:

      I.    RESPONSIVENESS SUMMARY OVERVIEW.  This section outlines the
            purposes of the Public Comment period and the Responsiveness Summary.
            It  also references the appended background information leading up to the
            Public Comment period.

      II.    BACKGROUND   ON   COMMUNITY   INVOLVEMENT   AND
            CONCERNS. This section provides a brief history of community concerns
            and interests regarding the OCI Site.

      III.    SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
            DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES
            TO THESE COMMENTS.  This section summarizes the oral  comments

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             received by U.S. EPA at the July 25, 1990 public meeting, and provides
             U. S. EPA's responses to these comments.

       IV.    WRITTEN   COMMENTS  RECEIVED  DURING   THE  PUBLIC
             COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS.
             This section contains the written comments received by EPA containing
             written comments,  as well as EPA's response to those written comments.
II.     BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

Local awareness of the OCI site has been minimal from the onset because the area has
been industrial since 1939 and has not impacted the general public. More interest has
been shown by adjacent industries and the numerous generators that have been named
potentially responsible parties that shipped spent solvents to OCI for recycling.

A public availability session  was held on May 10, 1989 to inform the public of the
remedial investigation and sampling and to answer questions concerning  the site. Most of
the individuals that attended the session included interested land owners adjacent to OCI
and were interested in the time frame to perform the investigation and begin remediation.

As part  of EPA's responsibility and  commitment to  the  Superfund  Program,  the
community has been kept informed of ongoing activities conducted at the OCI site. U.S.
EPA has established a  repository at  the Grandville Public Library, where relevant site
documents may be viewed.  Documents stored at the repository include:

0      The final Phase I Focused Feasibility Study for the site;

0      The PP for the site;

0      Fact sheets summarizing the.technical studies conducted at the site;

0      Public Meeting Transcript.

U.S. EPA's selection of a remedy to cleanup the contamination at the  OCI site will be
presented in a document known as a Record of Decision (ROD).  The ROD and the
documents containing information that U.S. EPA used in making its decision (except for
documents  that are  published  and  generally available)  will also be  placed in the
information repository, as will this responsiveness  summary.

III. Summary of Major Questions and Comments Received During  the  Public Comment
Period and U.S. EPA Responses to These Comments

Oral comments raised during the public  comment period for  the OCI Site interim

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remediation have been summarized below together with U.S. EPA's response to these
comments.

COMMENT: A resident asked if the contaminated area on Figure 4, page 4 of the
proposed plan would be fenced and whether warning signs would be posted on the fence.

RESPONSE: A fence will be erected to maintain security for this response action, which
will include any extraction wells, distribution lines and treatment facilities. The fence will
likely not encompass the area referred to by the resident but will approximate it. Warning
signs will be posted on the fence.

IV.    Written Comments Received During the Public Comment Period.

The written comments regarding the OCI site have been summarized below, together with
U.S. EPA's responses to these comments.

COMMENT: One commenter expressed a general concern that removal of the soil in the
immediate area of the  seepage  lagoon  would  remove the highest concentration  of
contamination at the site and reduce leaching to the ground water.

RESPONSE:  .The  objective of this  interim  action  is  to  stop  the migration of the
contaminant plume. Soils will be addressed as pan of the Phase n investigation, which
should provide the necessary information to cost-effectively remediate the soils.

COMMENT: One commenter expressed a general concern that the PRP Group has had
an inadequate amount of time to respond to the proposed remedy and other aspects of the
site.

RESPONSE:  By letter dated March 30, 1988, U.S. EPA informed Organic Chemicals,
Inc. and Spartan  Chemical  Company that U.S.  EPA,  pursuant to Section  122(a) of
CERCLA, intended to undertake the RI/FS at the Organic Chemicals site, because neither
Organic  Chemicals nor Spartan  possessed the financial capability  to conduct RI/FS
activities. This letter also stated that U.S. EPA would not notify the customers/generators
at the site of their potential liability because U.S.  EPA could not then determine whether
these customers/generators were responsible for the site contamination. When, during the
course of the remedial  investigation, it became apparent that the customers/generators
should be notified of their potential CERCLA liability,  a PRP address list and General
Notice Letters were generated and mailed to the approximately 175 customers/generators
on April 9, 1991.  These notice letters were put together as expeditiously as possible to
facilitate PRP organization.  U.S. EPA traveled to Grand Rapids on June 4, 1991, to meet
with PRPs and  provide information regarding the site and to answer questions that the
PRPs  had in connection with the site.  When the Phase I Remedial Investigation and
Focused Feasibility Study was finalized on July 17,1991, U.S. EPA immediately provided
the PRP Steering  Committee  a  copy of  the study.   In accordance  with the public

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participation  requirements of Section 117 of CERCLA, U.S. EPA released its Proposed
Plan for remedial action on July 18, 1991, and was available to answer questions from
members of the public at a meeting in Grandville, Michigan on August 6, 1991. In short,
U.S. EPA has acted to provide PRPs with notice and to share information concerning the
site in its possession as quickly as possible so as to promote an effective PRP response to
the selected interim action groundwater remedy.

Reference was also made by the commenter to the exclusion of the State's comments on
the FFS from the administrative record. The State's comments were omitted because they
did not form a basis for the selection of this response action.

COMMENT:  One commenter stated that U.S. EPA's identification of PRPs for the site
is incomplete and that U.S. EPA has  not considered OCI's chemical manufacturing
operations in terms of identifying additional PRPs.

RESPONSE:  U.S. EPA, through its PRP search activities, identified over 180 PRPs for
the site,  most of whom sent various solvents to OCI's  solvent recovery  operation for
recycling.  U.S. EPA  located over 150 of these PRPs, and 144 PRPs currently comprise
the PRP List.   Because the site contamination is not divisible between OCI's solvent
recycling operation and its chemical manufacturing operation, the PRPs are jointly and
severally liable for the entire costs of site remediation.  U.S. EPA, in its enforcement
discretion,  may limit  the number of named PRPs at a site to a manageable  figure;
however, U.S. EPA is willing to evaluate information provided by PRPs that other parties
not identified by U.S.  EPA are liable parties pursuant to Section 107 of CERCLA.

COMMENT: One commenter has stated that the definition of the "site," as that term has
been used in the RI/FFS and in conversation, is unclear.

RESPONSE:  The site name, as designated in the National Priorities List at 40 C.F.R.
Part 300, Appendix B, is the Organic Chemicals, Inc. site.  The site extends over several
properties and is defined as the areal extent of contamination and all suitable areas in very
close proximity to the contamination necessary for implementation of the response action.
"Areal extent of contamination" refers to both surface area, groundwater beneath the site,
and air above the site.  The Organic Chemicals, Inc. site should be distinguished from the
Organic  Chemicals, Inc. property, which  refers to  the real  property located at  3921
Chicago  Drive, S.W.  in Grandville to which Organic Chemicals, Inc. holds  legal title.
The OCI property has at times  been referred  to in an abbreviated manner as the site,
when, in fact, the OCI property is a portion of the site.

COMMENT:  One commenter has stated that there is  no "imminent and  substantial
endangerment" presented by the site.

RESPONSE:  Section  106(a) of CERCLA authorizes the President to take certain  actions
when  the  President  determines  that there may be an  "imminent  and  substantial

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endangerment" to the public health or welfare or the environment because of an actual or
threatened release of a hazardous substance from a facility. The President has delegated
this authority to the Administrator of EPA, who, in turn, has delegated this authority to
the Regional Administrators.   In  this case, an imminent and substantial endangerment
exists because numerous hazardous substances are present at, and migrating from, the OCI
facility, as  documented by the Phase I RI/FFS.   These hazardous  substances have
contaminated the soil and groundwater at the site to unacceptably high levels, and further
migration of the hazardous substances present in the groundwater is threatened.

COMMENT:  One commenter has stated that the interim response activity proposed by
the EPA is not consistent with the National Contingency Plan.   (No specifics were
provided.)

RESPONSE:  The procedures followed by U.S. EPA in selecting  the proposed interim
response remedy are consistent with the procedures delineated in the National Contingency
Plan, found at 40 C.F.R. Part 300.  The selected interim  response action  itself was
selected pursuant to the criteria established by the National Contingency Plan and provides
the most appropriate remedial action for the site problem that is being addressed in this
Record of Decision. Since the commenter failed to provide specifics with, regard to what
components of the NCP the response action is inconsistent with, U.S. EPA  has no basis
to respond further to the commenter.

COMMENT: Other remedial alternatives presented in the FFS are more appropriate with
respect to the conditions at the site than the interim response activity proposed by  EPA.

RESPONSE: The commenter  failed to  specify which alternatives presented in the FFS are
more appropriate.  As such, U.S.  EPA continues to believe that alternatives 1  and  2 will
not meet the objective of the interim action which is stop the migration of the contaminant
plume.  Alternative 3 is a biological treatment system that is subject to upsets resulting in
occasional exceedances of discharge requirements,  and is, therefore,  not as reliable as
alternative 4.

COMMENT: Maps and Plans are  of generally poor  quality.   A proper base map is
necessary to support a clear  and accurate presentation of RI data and the drawing of
proper conclusions from that data.  The variable format of figures used in the RI/FFS
makes the data difficult to understand.

RESPONSE: Original maps should be of readable quality and the data has been presented
adequately in the maps.  The objective of this interim action  is to  stop the  migration of
the contaminant plume and the data and graphics provided in the  RI/FFS supports  this
decision. Base maps will  be provided as part of the Phase II RI.

COMMENT: A second oil refinery operated northwest of the OCI property; sand  and
gravel mining took place on the adjacent property with unidentified fill materials.  None

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                                        6

 of these historic land uses have been adequately documented.

 RESPONSE: There is no evidence from aerial photographs from 1938 when the area was
 farmland to the present that a second refinery was operated northwest of the OCI property.
 The gravel pits that are adjacent to the property are filled with  clean material according
 to the manager of Meekhoff Trucking.

 COMMENT:  There is  a lack of detail on the former oil refinery operation.  Given the
 period of time the refinery operated, more detail on its operation and contribution to soil
 and ground-water quality is appropriate.

 RESPONSE: Oil related contamination was not part of the scope of work for this RI/FFS.
 This contamination will be investigated in the Phase II RI.

 COMMENT: Fill material brought to the site could affect the performance of the ground-
 water extraction system  and may have  contained  contaminated material.  Fill identified in
 Mateco boreholes are not mentioned in Black & Veatch logs.

 RESPONSE: The effect of the soils with regard to ground water extraction system will
 be evaluated as part  of design  of the extraction  system.   No evidence indicates that
 contaminated fill was brought to the  site as discussed  with the manager of Meekhoff
 Trucking. Soil boring logs are to be considered as a description of the soils and geology
 as noted by the geologist in the field  and were not classified whether  fill material was
 present or not.

 COMMENT: Physical evidence of contamination in the borehole logs such as oil coated
 soils and odors is not  supported by ground water quality analysis in various areas of the
 site.

 RESPONSE: The scope of this investigation did not include oil related contamination.
 This will be further investigated  as part of the Phase II RI.

 COMMENT: The ground water flow direction  and gradient in the lower ground water
 system should be defined. The investigation should not be extensive and  should be limited
 to two additional wells in the LGS to define gradient and direction of  the LGS ground-
 water flow.

RESPONSE: Additional wells will be installed in the LGS to adequately determine the
extent of contamination, gradient  and  direction  of flow  as part of the  Phase II
investigation.

COMMENT: Private wells (non potable)  had high metal- concentrations likely related to
well construction.  The risk assessment assumes that drinking water wells will be placed
in the UGS. This is unrealistic because water is supplied by the  City of Grandville and if

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wells were installed it would be in the LGS.

RESPONSE: The  FFS states that high metal concentrations found in residential non
potable wells is likely related to plumbing. The risk assessment assumes that contaminants
from the UGS will migrate to the LGS where the groundwater could be used for potable
purposes.  The remedial action is intended to reduce the chance for further migration of
contaminants from the UGS to the LGS.
COMMENT: Ground water sampling was performed over an unacceptably long period of
time for both Round 1 and Round 2.

RESPONSE: Upon further review of field logs it was noted that the RI/FFS inaccurately
presents the sample collection dates.   The correct dates of groundwater sampling  are
September 19 - 26, 1989 and November 7  -  13,  1989.   As such,  the  ground-water
sampling was performed over an acceptable period of time.

COMMENT: The use of three different bailers (stainless steel, teflon, and PVC) increases
the importance of the analysis of field blanks.  Field blanks should have been coordinated
with bailer type to assess possible patterns in sample collection interference on analytical
results.  It would be useful to summarize decontamination procedures at this point in the
text to permit comparison with the QAPP, to identify the bailer cord material and its
possible impact on analytical results and to evaluate the adequacy of sample collection and
handling procedures.

RESPONSE: Bailer type was not designated in the approved QAPP. Bailer type was not
noted in the field log notes.  Therefore is not possible to coordinate bailer type with blank
samples. The impact of bailer cord on  analytical results is insignificant with and irrelevant
to selection and implementation of this response action.

COMMENT:  Residential well monitoring was conducted on only one occasion and was
inconclusive.

RESPONSE: Additional monitoring of residential wells will be performed as part of the
Phase n RI and will be compared with the initial results.

COMMENT: The FFS did not include consideration of alternative ground water collection
methods.  Such  alternatives could be  more useful and  more cost-effective.  Discharge
options  should be further assessed after determining treatment efficiencies.  Ground water
recharge through an infiltration gallery could be used to flush contaminants back to the
extraction wells and should have been considered.

RESPONSE: Extraction well pumping was chosen through the screening process in the
FFS.  Other methods were considered.in the FFS but were screened out for reasons stated

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                                        8

in the FFS.   The primary criteria  used  for screening in  the FFS were effectiveness,
implementability, and cost-effectiveness.  Other methods can be considered in remedial
design if shown to be more cost-effective. The method specifically mentioned above was
considered in  the FFS but was eliminated because of the concern that aquifer reinjection
may cause unforeseen hydraulic gradients  in the upper ground-water system, causing
accelerated  and   uncontrolled  dispersion  of  contaminated  plumes.  Furthermore,
groundwater recharge standards may be much more difficult to attain than surface water
discharge limits.

COMMENT:  If ground water extraction is selected then a test well should be pumped for
several days to ensure that the zone of interception is fully developed before conducting
treatability tests on extracted water.  The low flow rate anticipated could be pretreated in
the on-site aeration basin for  the duration  of the test.  After establishing the zone of
interception for EW1, EW2 could be installed at an optimized location and simultaneously
tested.  EW-3  would be installed only if necessary based on the optimized location of EW-
2. Monitoring wells around EW-3 suggest that water quality may not merit pumping.  All
test waters could be directed to the on-site treatment works for pretreatment and discharge
to the Grandville  POTW.  The low flow rate should  make both the  vapor release of
contaminants and hydraulic loading  at the POTW tolerable for the few weeks of testing.

RESPONSE: Treatability tests are planned prior to remedial design.  Use of the treatment
works at  OCI with discharge to  the Grandville POTW would have to  be properly
coordinated with OCI and the City of Grandville.

COMMENT:  There is not enough  information available to  make a proper, fact based
objective, selection of treatment at this time. The combined flow from pumped wells is
the only accurate measure of raw water quality that must be treated.  Treatability testing
on the  combined  flow is required  before  treatment can be optimized using effective
treatment efficiency and cost analysis.

RESPONSE:  Other physical, chemical treatment alternatives can be evaluated as part of
treatability tests than those in Alternative 4.

COMMENT: The selection of Alternative 4 is not adequately explained.  UV\H2O2 should
remain  in consideration  due to the relatively low flow  anticipated,  high destructive
efficiency of such treatment and its apparent lower cost. Even  if carbon polishing is
required this treatment may still be more cost-effective than relying on carbon for primary
treatment.

RESPONSE: Alternatives 1 and 2 will not meet the objective of the interim action which
is stop the migration of the contaminant plume.  Alternative 3 is a biological  treatment
system  that is subject  to upsets  resulting  in  occasional • exceedances of  discharge
requirements, and is, therefore, not as reliable as alternative 4. The basis for the selection
of Alternative 4  is presented in more detail in the  ROD. See response to previous

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                                       9

comment for the second portion of the comment.

COMMENT: Treatability tests are necessary for proper design of the treatment system.

RESPONSE: Treatability tests are required prior to design, as discussed in the ROD.

COMMENT: UV  oxidation should  be considered a primary treatment  on its own.
Biological treatment should have been given lower consideration. BOD is already too low
to support biological population  and groundwater  is generally low in  nutrients,  which
would necessitate feeding the bioreactor regularly.

RESPONSE: The biological treatment proposed as part of Alternative 3 is considered
necessary  because of the high COD concentrations in the influent.  In Appendix G of the
FFS the values for BOD and COD entering the groundwater treatment facility are 17 and
468 mg/L, respectively.  It is expected that some of the influent COD will be converted
to BOD during the UV-oxidation process.  To account for this, it was  assumed that the
BOD exiting the UV-oxidation unit will be approximately 30% of the influent COD (i.e.
BOD = 0.3 (468 mg/L) = 140 mg/L).

Also, the  BOD  test is performed with an unacclimated seed.  Due to the  nature of the
toxic chemicals in the groundwater, it is unlikely that a five-day BOD test will accurately
predict the "true" value of BOD  that this waste stream would exert upon surface water,
which has developed an acclimated microbial population.  Therefore, the groundwater is
expected to have sufficient BOD  to sustain an activated sludge process.

COMMENT: Monitoring wells were drilled into the LGS  without double casing, allowing
contaminants to migrate from the UGS to the LGS.

RESPONSE:  All LGS wells installed during the Phase I RI were double cased.

COMMENT: Sample holding times were exceeded on Rounds 1, 2 and 3 and result  in
qualified data and uncertainty in  the interpretation of results.

RESPONSE: This sampling  will  be performed again as part of the Phase II RI or as part
of design.  It is unlikely that  more accurate data will change the conclusions made to date.

COMMENT: There are insufficient background samples to establish the natural inorganic
variation in local soils. MDNR guidance specifies a minimum of four background samples
per soil unit. There was no indication that the sample collected was native to the area and
not imported fill acquired during the development of the area.

RESPONSE: The number of background samples  collected conformed to the approved
sampling plan. Additional background samples are planned to be collected as pan of the
Phase II RI.

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                                         STATE Of MICHIGAN
NATURAL RESOURCES COMMISSION
  MAftlfNfJ PLUMA.1TY
  GORDON C. GUYtH
  0 STEWART MYFR;,
  RAYMOND PCjPoiu     .                       JOHN ENGLER, Governor

                           DEPARTMENT OF NATURAL RESOURCES
                                        STCVTNS T. MASON BUILOlNO
                                            P.O. BOX soo:e
                                           LANSING. Ml 
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Q. r, L>  '."•-' r c. r.. r
      Mr. Valdas Adamkus                      -2-                   September 27,  1991


      It  1$  the State  of Michigan's  understanding  that  further  investigation of the
      upper  and lower  groundwater  systems,  the  soil, the oil and the OCI facility is
      warranted and will be conducted during  the next phase of  the remedial
      Investigation.   We also understand  that the  final remedial action at the site
      will address all  site-related  contamination  in the entire upper and lower
      groundwater systems, and  all site-related contaminated soils because the Interim
      action will not.  The final  remedial  action  will  also meet all applicable or
      relevant and appropriate  requirements (ARARs), most  of which are being waived
      for the  Interim  action.

      We understand that the specific types of  treatment will be determined  1n the
      remedial design  phase and will probably consist of granular-activated carbon,
      air stripping, and/or possibly UV/ox1dat1on  with  some form of biological
      treatment.

      We understand that, because  this  1s a limited  Interim action, the U.S.
      Environmental Protection  Agency 1s  waiving many of the ARARs; therefore ARARs
      need not be as comprehensive as they  would be  for an operable unit.  However,
      the State of Michigan considers all substantive portions  of the following acts
      as AHARs for the interim  action selected:

           the Michigan Water Resources Commission Act  (1929 P.A. 245, as amended) and
           associated  rules;

           the Air Pollution Act (P.A.  348  of 1965,  as  amended), and the Michigan Air
           Pollution Control Commission General Rules

      We urge your continued efforts to implement  this  Interim  action as soon as
      possible and will continue our efforts  to this end as well.  If you or your
      staff  have any questions, please  contact  Ms. Beth O'Brien at 517*335-3098 or me.
                                                 Sincerely,
                                                 Delbert  Rector
                                                 Deputy Director
                                                 517-373-7917
      cc:  Mr. Jonas Diklnis, EPA
           Ms. Wendy Carney, EPA
           Mr. Tom Williams, EPA
           Mr. Alan Howard, MDNR
           Mr. William Bradford, MDNR
           Mr. Scott Cornelius, MDNR
           Ms. Beth O'Brien, MDNR

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