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
-------
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
-------
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.
-------
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.
-------
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
-------
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.
-------
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.
-------
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
-------
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).
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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:
-------
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
-------
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
-------
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
-------
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)
-------
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
-------
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
-------
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.
-------
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.
-------
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
-------
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.
-------
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.
-------
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
-------
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).
-------
25
E. Preference for Treatment as a Principal Element
This preference will be addressed in the final decision document for this site.
-------
City of
Grandville
HIVEHTOWN PARKWAY
NO SCALE
FIGURE I'
OCI SITE LOCATION MAP
ORGANIC CHEMICALS, INC. SITE
-------
HAVEN-BUSCH CO
"*>. *^^-^
oo
1 -r m
°«
n- * ro
PACKAGING CORPORATION OF AMERICA
/3
^
-------
u
il
hi
ll
H
I
I
450' O'
450' 900'
FIGURE 3
SOURCE AREAS
ORGANIC CHEMICALS. INC. SITE
-------
J
a
w
K
.
FIGURE 4
PLAN LOCATION OF GEOLOGIC CROSS SECTION
ORGANIC CHEMICALS. INC SITE
-------
sl£
M
i
A
NORTH
620
600
'SBO
« 560
540
520
500
i BORING MH-lS
1
1 MON 1 TORIHG
PCLL MH"15
SILTY SAND ,
3!-*-
?
(574.31
SANDSTONE -
B
;a
1 *
1
1-
|
£
OR ING SB-B
BORING MH-21
MONITORING
HELL SB-B MONITORING
HELL MH-18
| BORIIIC SB-S
BORING MH-lb
SILTY '.-AND ^
^ ^ COATED H/HYOROCARBON
?b< SUBSTANCE
_ ' o' SAND ANO GRAVEL UNIT
1589 ?3T~- --____
_ ' CLAY UNIT
~~ ^
L 1 MES1 ONF-^^^s^
x R SHALE ~^--^
£ m jz
ISM*" LIMESTONE--
SHALE ~^%
LIMESTONE ' /
1
I
''/.
-%
^
«-^£:
^
r?
lu£
BEDROCK / 1514.
T/
SHALE '
/-FILTER
, -- / LENGTH
I f SCREEN
I \ LENGTH
; 1 SAND AND GRAVEL UNIT
.-MONITOR INC
HELL MH-21
T
/-
/
/
*x
L
vifloucr ST-
^^^/ if CLftVEY SILTJ
13
0
o
0 1
OIL y
STAINED pj
.---"Mf--.
(563.81
^^.^
"*---^^
1 """~~--
1
51
b
<** i-
i
~T
i
i
I
1
1
1
%
^
,
1
£
s
>7
s4a
A
JK1NU MH-^O «
SOUTH
i MONITORING
HELL MH-20
:
^
(523.31
SAND. Silly SAND. Gravelly SKNU. b'KHVtL. b.ny
GRAVEL. Clayey SAND. Clayey SILTi brown, gray.
620
600
SQO
5KO
510
SJO
yellowish-brown' poorly lo well graded' 1 ^QQ
LEGEND nediun lo very dense' subroundedi
fine lo coarse gra«ned'
' , ^__ lopeoi 1 in upper fool
I 1 SANO ^ CLAY IH SHALE CLAY UNIT
°"0 GRAVEL V/y SILTY CLAY
o3 GRAVELLY SAND \//^ CLAYEY SILT
^3 riAvr» CAMI 1' ' ' SILTr SWNO
W4A CLAYEY SANO 1 . , SRM)r S|LI
^ CLAYEY GRAVEL lljjjj CRAVEL
{TTI CLHYI S.lly ULHYJ gr
i?? LIMESTONE yellowish-brown' har
i^J plasticity Boisti w
dry lo wet >
ISO' 75' 0 150;
5'non^Vaslic to low HOKIZONTflL SCflLE
'trace lo some sand and gravel
KT7- BEDROCK
<>. GYPSUM
j^o LIMESTONE' grayish-whi le' cryslalline' slighliy
wealhered lo fresh
.;;: SANDSTONE SHRLEj 8ray| ,,ealhered_
.-_ HATER LEVEL IN MONITORING ^UM, whi te and gray, .1 iflhl ly weathered lo fresh,
HELL MEASURED ON 11/7/89 w/shale f , 1 led fractures
1571.31 ELEVATION OF BOTTOM OF BORING
CI/MIDLT S1
300'
(FEET ABOVE MSL)
NORTH-SOUTH GEOLOGIC CROSS SECTION A-A'
ORGANIC CHEMICALS. INC. SITE
-------
OKlANIt: UHtMIL/tL. IHl .
Njffiib I BOR INC MH-16
620 ~
-
: EDO
580
560
540
OILY SLUDGE .:
COATING ^ ft
\£
~T" ~
2-4
I MON1IDR1MG
HELL MH-16
SILTY
SAND--^
Sir-:
1
9. i
BORING MH-II
i MON 1 TOR 1 NC
MONl TOR INK
BORING HH-6-
BLACK CARBON
GRANULES -~
2 ;;
^-a._C.LAY LENS~^~
*y P ~~~~~-X
» M HYDROCARBON/
MONITORING ~
HELL MH-22 1
BORING MH-22 i /
1
I
₯
,5t?3, 15^l,UC°'
very stiff to hard) lo« plast.c.lyi mo.si)
traces of sill, sand and gravel
DEDROCK
SHALE) grey) IraclureUi mealherad lo fresh
LIMESTONE) gray
GYPSUM) uhitoi cryslallinei sliQhlly nealhored
and fractured
200' 100' 0
&KBMB
200 -
400'
HORIZONTAL SCALE
FIGURE i.
NORTH-SOUTH GEOLOGIC CROSS SECTION B-b
ORGANIC CHEMICALS. INC SITE
-------
c
HESJ. r-
620
* .
600
5 ' s*° ~
560
510
520
" 500
CLAYEY SILT-y
,°
3
E
(579
BORING MH-M i BORING MM-12
i MONITORING i MONITORING
HELL MM-11 HELL MH-I2
BORlriG SB-9 1 SAND -\
TOPSOIL-A \
^^ [jjnf^""^ ^ A
SAND . ^^^ , SflND AND ]
.U 0° -- 1592. 1 1 "^
BORING MH-B ORCflNIC I MONITORING r^i
1
\ AL
a^i
*§ ' 0° ^-^ (S90.1)
p^ O , -* PIA/IIMIT
fcj ^__ __ "77 LLni Urll 1.
7l (577.81 ~~~~-~-__
BEDROCK UNIT
T'
^FILTER
. ,( LENGTH ....... - - . ...
1 I SCREEN
1 r^ LENGTH
SAND AND
1- MONITORING CHEMICALS HELL KH-2 ^2^-
HELL MH-U INC^
\ | UORING MH-20
BORING MW-2 1 \ 1 ^ CLAYEY SILT
MONITORIIIC
HELL HH-18
BORING MH-18 1
S ' L T Y /
\ SAND '
i
*^ ^ ic
OIL ^^^^j'0°
STAINED s^rr
~~ ^ '/
~~"~~~- iA
LIMESTONE ^ =
SHALt ^ "&
LIMESTONE -^
SHALE x^ 5>
LIMESTONE 5^
SHALE 'V£
~l J-J -i
/| f/rsOLVENT
^' >' COATING
\ ^-OIl.Y
i _ -^w COATING
-^ (583.81
7
"X
'^v
V.
' **' ^
FJ ^ v
J 1
(544.51
SHALE v
J<
J_l
1 1
J L
V*
^
^
ss
V
//
^yt
//;
E3
^
j^j;
^y
a
/
MONIIORINC
MtLL MH-20
1523.3)
JSfiflVEL UN11
SAND, Silly SAND. Sandy SILT. Clayay SILT.
GRAVEL. Silly GRAVEL, brown, yel 1 owTsh-browo.
' bla
cKi Ic
i bZO
6,00
i 580 -
S60 i
b<0 ^
1 520
500
>ose to very dense, poorly to well
1 EGEND graded, f ine to coarse grained, subrounded,
^i ~~ ~~ dry lo wet, w/lrdces of cobbles and clay,
lopsoil in upper fool al sone local ions
F-lc,Mn t%r,.v Bcu.,c 200-100-0 POO- ,00
muj
i ,
o^.f GRAVEL
PT^TI <:IITY n B» rr-^ CLAY, Silly CLAY, bro.jn. gray, bluish-gray. HORlZONlflL SCALE
\'/'\ CLAVE* SIIT S^ LIMESTONE Oreenish-grBy, very stiff to hard, lo«
X/.'A CLhYt* SILT PXn ulaslicitu, Hoist, «j/ traces of sill, gravel
n i ' ' ' **nd
sand
0 IT KJjUl SILTY GRAVEL JV^ SRN£)r S,LI l£&] CYPSUM BEORDCK
o * ui . SHALE, bluish-gray, gray. blacK. green, slighlly
" i« "leathered to fresh
S°" X. H.1TER LEVEL IN MONITOR INS . ,.:.. . . ,, . .
g.."1 HELL MEASURED ON 11/7/89 LIMESTONL, orayish-»h. lei f inely cryslal 1 .rw,
iat- fresh, u/ouosum and sandfit ana __
SS"
1579.71 ELEVRIIQN OF BOTTOM OF BORI.NC (FEET ftBOVE MSLI
GYPSUM, white, crystalline, uealhered to fresh
FIGURE 7
EAST-WEST GEOLOGIC CROSS SECTION C-C
ORGANIC CHEMICALS. INC. SITE
-------
D
HEST
>l
620
-. 600
580
560
510
nuJ
nu
ORGANIC
CHEMICAL.
MONITOR INC
( BORING SB-1O
"
O
F
i
5^
*X*
y/,
^
^
I
MONITORING
HELL SB-IO
SIL1 ,
_--
- COATED M/ . SBND AND iSRAVEL UNIT
HYDROCARBON
SUBSTANCE _ -- "
-SANDSTONE ?-' C-LAi UNIT
SHALE
3 BECIRC/O unLL
I
I
i
| BORING SB-7
0°
^
I
%
fl
£2
-
"~
d
HONIIORING
HELL SB-7
j
-. 2
^^ i
GYPSUM C \
-BORING SB-1 HELL MH-5
BORING HH-5
f~ GRAVtL BLACK
r HYDROCARBON
(l CUATING y
^F
' COfllEO H/OILY f
/ SUBSTANCE _}
IT
i " L
X IS8
a. -_?._.?
1 INC.
X.
->J
<.-''?
"1-
^ Q ^
3.61 l«
1 AY LENS^
BORING KH-6
1 Mf in IT OR INC
HLLL MH-6
/ SOMF CARBON
/ CRHNULL'S
fif' GRRHULES
/ «J= HYDROCARBON
/ COATING
I fl
54, > BL1C<-OILY
SLUDCL
COATING
I57B.JI
1
(562.11 IS60.9I
620
£00 3
in
£
UJ
s
Sc
sso y
§
tC
>
560 oi
540
I
I/"
FILTER
LENGTH
100' 50'
100'
200'
SCREEN
LENGTH
HORIZONTftL SCrtLE
LEGEND
a
SAND
3o| GRAVEL
^ CLAYEY SAND
ffl FILL
CLAY
SILTr CLAY
CLAYEY SILT
SILTY SAND
SANDY SILT
SILTY GRAVEL
SHALE
| LIMESTONE
GYPSUM
\','/,\ SAIOSTONE
JL HATER LEVEL IN MONITORING
HELL MEASURED ON 11/7/63
IS62.1I ELEVATION OF BOTTOM OF BORING IFEET ABOVE MSLI
SANll ANO CRflVFI UNIT
SRNO. s;ilu Sand. Cl&yey Sand. GRAVEL. Silly GRAVEL.
SILTj broWi end blacK. Tooso to «ediu. densai poorlu
to !! graded) fine to course grained! subroundedi
dry. «oi8t and *el i i»/lracea of clay. t.ll. cobbles
and filli lopcoil in upper foot.
plBf UNIT
CLAY. Sil'.y CLAY» broiui. gray, bluish-gray! very
stiff to hardi lo» to high plaslicityi moisti
/traces of sand, gravel and gypsum.
QCnttOCK UNIT
SHALE» gray. darK-grayi fractured.
LIHEStONEi shaleyi Qrayi crystalline! / sandstone lens.
CYPSUMi nhite. pinKi crystalline! uealhered.
FIGURE 8
EAST-WEST GEOLOGIC CROSS SECTION D-D1
ORGANIC CHEMICALS. INC. SITE
-------
V
*
- PRIVATE WELL
- SOILBORINO
- MONITORING WELL
450' O1 450^ 900'
FIGURE «»
MONITORING WELL LOCATIONS
ORGANIC CHEMICALS, INC. SITE
-------
«.
»<
M
FIGURE I!
INORGANIC OROUNDWATER RESULTS (ug/L)
ORGANIC CHEMICALS, INC. SITE
-------
FIGURE f-t
ORGANIC OROUNDWATER RESULTS (ug/L)
ORGANIC CHEMICALS. INC. SITE
-------
u
i
i
LEGEND:
SOU BORING
MONIIOHING Will
II.SI Pll
FIGURE IZ
ORGANIC SOIL DORING AND TEST PIT RESULTS
ORGANIC CHEMICALS, INC. SITE
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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
------- |