United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-93/227
June 1993
PB94-964111
v°/EPA Superfund
Record of Decision:
Spartan Chemical, Ml
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50272.101
REPORTDOCUMENTA~ON 11. REPORT NO. 2. 3. Reclplenra Acce8.lon No.
PAGE EPA/ROD/R05-93/227
4. Title and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 06/30/93
Spartan Chemical, MI 6.
First Remedial Action
7. Author(s) 8. Performing Organization Rept. No.
9. Performing Organization Name and Addr- 10 Project TaskIWort Unit No.
11. Contrect(C) or Grent(G) No.
(C)
(G)
12. Sponsoring Organization Name and Add,... 13. Type of Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, S .W. 800/800
Washington, D.C. 20460 14.
15. Supplementary Notes
PB94-964111
16. Abstract (Limit: 200 words)
The 2-acre Spartan Chemical site is an inactive chemical transfer, blending, and
repackaging plant located in Wyoming, Kent County, Michigan. Land use in the area is
predominantly industrial, with some residences, a park, and a school located adjacent
to the site. Prior to 1963, Spartan Chemical discharged process water containing.. a
variety of chemicals, including aromatic and chlorinated solvents, napthas, alcohols,
ketones, ethers, and lacquer thinners, directly to the ground water as part of its
onsite operations. In 1975, ground water contamination was detected during dewatering
operations at an adjacent facility. Discharge from the dewatering wells was found to
contain various solvents and oils. This contamination was attributed to Spartan
Chemical since it was the only known handler of solvents in the area at the time. In
1980, the State initiated a hydrogeological study that documented concentrations of
organic chemicals in the ground water, which warranted a subsequent study to focus on
the extent of off site, downgradient migration of contamination. Between 1980 and 1985,
a total of 38 monitoring wells were installed .to evaluate the extent of onsite and
offsite contamin(!.tion. After a 1981 State investigation identified contamination in
several private residential wells that were affected, these residents were connected t.o
the public water supply. In 1984, the State required Spartan Chemical to investigate
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Spartan Chemical, MI
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (ethylbenzene, l,l,1-TCA, toluene, vinyl chloride, xylenes)
b. IdentifierslOpen-Ended Terms
c. COSATI Field/Group
18. Availability Statement 19. Security Clasa (ThIs Report) 21. No. of Pages
None 22
20. Security Class (This Page) 22. Price
None
(See ANSI-Z39.18)
See/nstructJons on RavfHS6
OPTIONAL FORM 272 (4.77)
(Formerly NTlSo35)
Department of Commerce
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EPA/ROD/ROS-93/227
Spartan Chemical, MI
First Remedial Action
Abstract (Continued)
and clean up the ground water contamination at the site and, in 1986, to remove five
chemical underground storage tanks. In 1988, the State required Spartan to establish a
ground water collection and treatment system for which the company installed a steam
stripper with an incinerator for off-gases. However, due to equipment problems, it was
modified to an air stripper. In 1988, a purge well was installed onsite and began
operation to control the migration of ground water contamination. In 1990, a second purge
well was installed in an attempt to capture contaminated ground water. In 1992, Spartan
Chemical declared bankruptcy, requiring the State to take the lead, under a cooperative
agreement with EPA, and complete the investigation and cleanup. In 1992, EPA and the
State proposed two remedial alternatives to the public: no action and continuation of the
ground water collection and treatment system, which was shut down due to problems with the
permit and temporary service agreement with the local POTW. Currently, the State is
conducting semi-annual ground water sampling of select monitoring wells to evaluate trends
in contaminant concentrations during system shutdown. This ROD addresses an interim
remedy for continuation of the ground water collection and treatment system to contain the
contaminant migration, but does not address ground water cleanup levels. Future RODs will
address the ground ~ater cleanup levels and any remaining source and ground water
contamination, if necessary. The primary contaminants of concern affecting the ground
water are VOCs, including ethylbenzene, 1, 1, 1-TCA, toluene, vinyl chloride, and xylenes.
The selected remedial action for this site includes evaluating and restarting the existing
ground water collection and treatment system, including filtration, air stripping, and
incineration of VOCs to reduce contamination levels and limit the migration of
contaminants; evaluating several discharge options for treated ground water, including
reinjecting back into the ground water, discharging to the city of Wyoming wastewater
treatment plant, and directly discharging to the nearest surface water body; and
monitoring ground water. The estimated present worth cost for this remedial action was
not provided; however, the estimated annual O&M cost is $72,000.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific ground water cleanup goals were not provided, but will be established at
a later date.
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DECLARATION FOR THE RECORD OF DECISION
SPARTAN CHEMICAL SUPERFUND SITE
WYOMINGr KENT COUNTYr MICHIGAN
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action for the
contaminated groundwater for the Spartan Chemical site in Wyoming, Kent
County, 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 u.S. Environmental Protection Agency (EPA) and the Michigan Department of
Natural Resources (MDNR) agree on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the interim response action selected in this Record
of Decision (ROD), may present an imminent and substantial endangerment to
public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Spartan Chemical site as specified in this interim
action ROD addresses only the contaminated groundwater. .
The interim remedial action for the groundwater consists of the following:
* . Evaluation of the existing groundwater collection and treatment
. system and of discharge options available for the treated
groundwater. The evaluation process may result in modifications to
the existing treatment system and/or relocation of the discharge
point;
* Restart of the existing groundwater collection and treatment system;
and
* Groundwater monitoring to evaluate the effectiveness of the
groundwater collection and treatment system.
Additional investigations will be required to. better characterize the site,
focusing on potential source areas, such as possible lagoons, chemical spill
areas, and chemical storage tank areas. Further remedial actions may be
required to address any remaining site concerns.
1
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DECLARATION
This interim action is protective of human hearth' and the environment,
complies with or waives federal and state applicable or relevant and
appropriate requirements (ARARs) 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 does utilize treatment and thus is consistent
with 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 further addressed by the
final response action. Subsequent actions are planned to fully address 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
protec(ion 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 ongoing as the MDNR, with
assistance from the EPA, continues to characterize the site and to develop
final remedial alternatives for the site cleanup.
~ ~9 /93
I (
£;~/u I~~-
.In- Valdas v. Adamkus
o Regional Administrator
U.S. EPA, Region 5
Date
~6<7~J
Date {
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Declaration for the Record of Decision.......................................l
TABLE OF CONTENTS
Decision Summary[[[3
III.
IV.
VI I.
VIII.
I.
II.
Site Location and Description.........................................3
Site History and Enforcement Activities...............................3
A.
B.
Si te Hi story. . ... ......... . . .. . . . . . . . .. . .. . ..... . . . . . ..... . ........3
Previous Investigations............................;...............6
Highlights of Community Participation.................................9
~cope and Role of Response Action.....................................9
V.
VI.
Si te Characteri st i cs. . . . . . . . . . . . . . . . . . . . . . . . . . . . .... . . . . . ..... . . . . .. .10
Summary of Site Ri sks. .. . .. .. .. .. .. .. .. .. .. .. . . . . .. . .. .. .. . .. . ..... ..10
Description of Alternatives..........................................13
Summary of Comparative Analysis of Alternatives......................14
A.
B.
Evaluation Criteria..............................:................14
Comparative Analysis............................................. .16
IX. Selected Remedy[[[18
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- -
DECISION SUMMARY
SPARTAN CHEMICAL SUPERFUND SITE
WYOMING, KENT COUNTY, MICHIGAN
I.
SITE LOCATION AND DESCRIPTION
The Spartan Chemical site (see Figure 1) is a 2-acre parcel located at 2539-
28th Street in Wyoming, Michigan. It is situated among other small industries
with a residential area and a city park located to the north of the site, and
a school adjacent to it on the east side. The terrain in the vicinity of the
site is relatively flat.
The company was a bulk chemical transfer, blending, and repackaging plant.
During lts operation, Spartan Chemical handled a variety of chemicals,
including aromatic solvents, napthas, alcohols, ketones, ethers, chlorinated
solvents, and lacquer thinners. A list of chemicals handled at Spartan
Chemical and their relative volumes are shown in Table 1.
Approximately 30 storage tanks, five of which were underground, were utilized
by Spartan Chemical for storage of chemicals. The above-ground tanks rest on
concrete pads which are surrounded by containment walls. The underground
storage tanks (USTs) were removed by the owner of Spartan Chemical under
guidance of the MDNR, Environmental Response Division, Grand Rapids district
office. Two USTs (6,000-gallon sections of a baffled 12,000-gallon tank)
contained acetone and methyl ethyl ketone. Two other USTs, that were also
sections of a baffled 12,000 gallon tank, contained isopropyl alcohol and
acetone. The fifth UST was a 12,000 gallon tank that contained toluene.
Contaminated soils associated with the USTs were not excavated as part of the
removal. In addition to the USTs, other potential source areas exist at this
site. Chemical spills and seepage from wastewater lagoons may also have
contributed to the groundwater contamination. There is conflicting
informatjon available with regard to whether or not wastewater lagoons existed
at this .site. Further investigations of potential source areas will be
required as part of future activities at the site.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
Prior to 1963, the company discharged its process water to the groundwater.
The groundwater contamination was detected in December 1975 during dewatering
operations at an adjacent facility. The dewatering was being done to lower
the water table allowing for construction of'a press pit. The discharge from
these dewatering wells contained various solvents and oils. Spartan Chemical
was the only known handler of solvents in the area at that time.
3
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Area opography (U.S,G.S. Quadrang1e nap)
Spar~an Chemical COQpar.:
\-Jyc::nng. f\ichigan Se= 9. T .I2\-!. R.6N
Contour Interval = 10'
i:ID' .:."'~ \
'" t'-... I !
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SOIL TESTING SERVICES
OF MICHIGAN, INC.
U1. II. Ga".O .,VER. """SING.. MICHIGAN .....
9-3-21 704;)8
POOR QUAU.i
ORIGiNAL
4
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-' .
CHEHICAL
TABLE 1
CHEMICAL VOLUr.,ES AT SPARTAN CHEMICAL COMPANY PLANT
KEY:
Aromatic Solvents
VOLUl4E
Toluol
Xy 101
ilOO Solvent
:150 Solvent
~3 Solvent
1
1
2
2
2
Aliphatic Naphthas
Shell :140
V.f>1.&P. Naphtha
EC
Mineral Spirits
#135
Shell #340
Spartan Sol."B"
Tolusol US
Shell 501. 71
Alcohol
3
2
"2
3
3
2
None
3
Methanol
Isopropyl
Alcohol 99~ 2
Tecsol Anhydrous 2
N. Butyl Alcohol 3
N. Propyl
Alcohol
Isobutyl
Alcohol 3
Diacetone A.f. 3
2
Wyoming, Michigan
1- High Volume.
2- Medium Volume
3- Low Volume
CHe-tICAl
VOLUME
CHEMICAL
Glycol Ethers
Ketones
Acetone 1
M.E.K. 2
M.I.B.K. 2
M.A. K. 3
M.P.K. 3
D.I.B.K. 3
LA. K. 3
Tetrahydrofuran 3
D.M.F. 3
Methyl Oxitol (EH)
Oxitol (EE)
Butyl Oxitol (EB)"
Dioxitol (DE)
Butyl Dioxitol
3
3
3
3
(DB) 3
Chlorinated Solvents
Esters
Trichloroethylene
Perchloroethylene
Methylene Chloride
Tri -Ethane
3
3
2
2
Ethyl Acetate
99~
Ethyl Acetate
85-88~
Isopropyl
Acetate
N. Propyl
Acetate
Isobutyl
Acetate
N. Butyl
Acetate
1.8.1.8.
3
2
. Lacquer Thinners
3
116 Lac. Thinner
11660 Lac. Thinner
11060" lac..Thinner
1
3
3
2
3
Wash Up Thinners
'125 Wash Thinner 1
:10 Wash up Thinner 2
AMK Thinner 3
3
3
Ether Acetate
Ek EE
Acetate
EK EB
Acetate
3
3
5
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,
In 1981, the Kent County Health Department conducted a street survey to
determiqe usage of residential wells north and downgradient of groundwater
contamination detected at the site. Six homes showed no record of municipal
water service. The private wells associated with these homes were
subsequently tested by the health department and contamination was detected.
According to th~ health department and information available to the MDNR,
these homes have since been connected to the public water supply.
On September 8, 1983, Spartan Chemical 'was added to the National Priorities
List (NPL) of environmentally contaminated sites, making it eligible to
receive federal cleanup funds. In 1984, Spartan Chemical signed a consent
order with the MDNR agreeing to conduct an investigation and cleanup of the
contaminated groundwater at the site. However, due to bankruptcy of the
company in February 1992, the MDNR has taken the lead to complete
investigation and cleanup of the site under Superfund.
B. Previous Investigations
Site investigation activities were conducted by Spartan Chemical, under the
direction of the MDNR, Environmental Response Division, Grand Rapids district
office as discussed in the following paragraphs. This information was
sufficient to support construction of an air stripper, which started operation
in 1988.
A phase I hydrogeological study was initiated in 1980. The first reported
groundwater data from three monitoring wells (Wells W, E, and N) showed that
there were concentrations of organic chemicals in the groundwater that
warranted a complete hydrogeological investigation to determine the extent of
chemical migration beneath the site. In December 1980 and February 1981,
additional groundwater samples were obtained from monitoring wells constructed
previously.and from new wells. The data from these monitoring wells are in
Tables 2 and 3.
A phase II hydrogeological study conducted in 1981 focused on the extent of
off-site, downgradient migration of contamination. Six (6) additional
monitoring wells were installed further documenting the extent of groundwater
contamination.
Additional wells were constructed in 1985 to expand the existing monitoring
well network. Over the course of the groundwater investigations, a total of
38 monitoring wells (including two temporary wells) were installed to evaluate
the extent of contamination.
In 1985, a Remedial Action Master Plan was completed by the engineering firm
of Prein & Newhof for Spartan Chemical, which included a recommendation for a
purge and treat system. A Remedial Action Plan was completed by EDI
Engineering & Science, Inc. in 1987, which expanded on the 1985 report.
In 1988, an Aqua Detox steam stripper with an incinerator for off-gases was
installed by Spartan Chemical. Due to equipment problems with the system in
the steam mode of operation, it was modified to an air stripper. Two purge
wells (PW-I and PW-2) were installed, one on-site and one downgradient, to
6
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(
TABLE 2
GROUNDWATER QUALITY ANALYSES DATA
Phase I
Sampling Dates: December 30 and 31, 1980
Spartan Chemi~a1 Company
Wyoming, Michigan
Sampled by STS Consultants, ltd.
CHEMICAL Well: N W E OW-2 OW-3 OW-4 OW-6
PARflJ.!ETER
C.O.O: mgj1 2,200 1,370 5,940 8 24 1,690 16
1.O.C. mg/l 370 139 1 ,600 11 5 450 15
°erchloroethylene ug/1 -- 21 -- 2,200
rich1oroethy1ene ug/1 16 2,500
Methyl Chloroform ug/1 46 12,000
Methylene Chloride ug/l ,1 18,000
1,2 Oichloroethane ug/l <1 *
= 100
Toluene ug!l <1 100,000
*
Interferences present preclude quantification below this concentration.
The reported value is an upper limit of detectabi1ity established by the
degree of interference.
7
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TABLE 3
GROUNDWATER QUAlITY ANAlYSES DATA
Phase I
Samp 1 i ng Date: February 20. 1981
Samples taken and analyzed by MOHR
Spartan Ch~ical Company
Wyoming. Michigan
CHEHICAL Well: OW-l' OW-5 OW-7 OW-8
PARAMETER
Trichloroethylene. ug/l J:l -'1 1,700 2,300
Hethy1ch1oroform. ug/1 ,1 ~1 4.800 2.800
Toluene. ug/l ~10 ..::'10 >100.000 57.000
Benzene. u;/l ,10 ~lC 5.700 < 1 .000
Xylene. ug/1 <::10 '10 19,000 15,000
1.2 Oichloroethane. ug/1 ~ 1 L1 5,400 <. 100
.Acetone, ug/1 NO NO NO NO
Isopropanol. ug/1 NO NO NO NO
Ethyl benzene, ug/l £.10 .::: 10 7,400 5.000
Methylene Chloride. ug/l NO NO TR TR
Perch1oroethylene. ug/1 Ll 2 490 1,800
Trichloromethane, ug/l Ll L.l 660 < 100
Chemical Oxygen Demand mg/1 £4 ~4 1,030 115
Total Organic Carbon mg/l 11 5 300 56
ND- ~one detected to laboratory detection limits
TR- Trace. not quantifiable
8
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control the migration of groundwater contamination. PW-2 (downgradient) was
insta1l~d in June 1990 in an attempt to capture contaminated groundwater off-
site.
Q .
A site assessment by the EPA Technical Assistance Team was conducted at
Spartan Chemical on May 14, 1992. Five soil samples and one groundwater
sample were collected for analysis. The samples were analyzed for volatile
organic compounds (VaCs), semi-volatile organic compounds, and eleven priority
pollutant metals (total). vacs were detected in all of the samples, however,
they were detected at levels below the EPA/s removal action limits. Also,
other contaminants detected in the samples did not justify an emergency
removal action. The EPA also conducted a site reconnaissance, including an
inspection of the above-ground tanks. The inspection of the above-ground
tanks indicated that the tanks are almost empty with only residual solids and
liquids remaining on the bottom of the tanks.
In November 1992, the EPA and the MDNR proposed two remedial alternatives
(Alternative 1: No Action and Alternative 2: Continuation of Groundwater
Collection and Treatment System) to the public for comment. Subsequent to the
public comment period for these two alternatives, it was necessary to shut off
the groundwater collection and treatment system. Please see Section XI.
Documentation of SiQnificant ChanQes for a discussion of this issue.
Currently, semi-annual groundwater sampling of select monitoring wells is
being conducted by WW Engineering & Science, Inc., under direction of the
MDNR. The purpose of this monitoring program is to evaluate the effectiveness
of the treatment system and to provide information on the trends of
contaminant concentrations.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The major public participation activities are discussed in Section B of the
Responsiveness Summary (attached to this document). As required under CERCLA
Sections 113 (k)(2)(B)(i-v) and 117, a public meeting and public comment
period were held on the preferred remedy as documented in the Proposed Plan
for the .site. The public comment period was held between November 18, 1992
and December 21, 1992. Comments received during this time period are
discussed in the Responsiveness Summary.
There is a mailing list of local citizens and other interested individuals,
including the media and public officials, who receive newsletters relating to
site activities. The Proposed Plan and one information bulletin have been
sent out.
IV. SCOPE AND ROLE OF RESPONSE ACTION
This interim action addresses only the groundwater contamination. Sufficient
information exists to allow for selection of a groundwater collection and
treatment system at this site. This interim action is intended to provide for
9
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protection of human health and the environment by reducing additional
migratio~ of the groundwater contaminants.
This action will be consistent with future actions, to the extent practicable.
Additional investigation of potential source areas is still necessary.
V. SITE CHARACTERISTICS
The geologic formations beneath the site are predominantly silty and gravelly
sands. The direction of shallow groundwater flow is north-northwest and the
rate of groundwater flow is estimated to be 1.4 feet per day.
Contaminants detected in the groundwater include various organics, such as
toluene, ethyl benzene, xylenes, and 1,1,1-trichloroethane (1,1,1-TCA). Refer
to Figure 2 for monitoring well locations and Table 4 for the groundwater
sampling results obtained since 1986. The highest levels of contaminants have
been detected in monitoring well 37, just south of the air stripper near PW-1.
In April 1992, 110,000 parts per billion (ppb) of toluene, 33,000 ppb of
xylene, 10,000 ppb of ethyl benzene, and 4,500 ppb of 1,1,1-TCA were detected
in the groundwater at MW-37. Lower concentrations were detected during the
September 1992 sampling round.
VI. SUMMARY OF SITE RISKS
Typically as part of the RI, a risk assessment is conducted to determine if
on-site contamination could ~ffect human health and the environment. - A
quantitative risk assessment was not completed for the groundwater
contamination at this site. However, a qualitative risk assessment was
performed by comparing groundwater contaminant concentrations to the Maximum
Contaminant Levels (MCls) in the Safe Drinking Water Act and the type B
criteria in Michigan Act 307. Based on these comparisons, an assessment of
the potential risks associated with groundwater was made.
Both the" historic and the current groundwater data for the site clearly shows
that there is a risk associated with the contaminant types and levels detected
at this site. The contaminated aquifer is a potentially usable drinking water
aquifer. The concentrations of several contaminants detected in the
groundwater exceed the Maximum Contaminant Level identified for that
particular compound, including toluene, xylene, 1,1,1-trichloroethane, and
vinyl chloride. Several of the contaminant concentrations also exceed
Michigan type B cleanup criteria as calculated pursuant to the Michigan
Environmental Response Act (1982, P.A. 307, as amended) Administrative Rules.
The comparison of site contaminants to type B criteria, which compares to a
10~ risk. level, was made only to evaluate the potential risk posed by the
groundwater contamination. Because this is an interim action, no cleanup
c~iteria have been selected for this site at this time.
Currently, the groundwater is not used as a source for drinking water, as
residents within the zone of contamination, identified by ongoing groundwater
10
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I .
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20'"
CJ
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, ,f.B 6
oG 27""1.
f. ~ ,,~.
.r::--;~ c., ~ ~ ~.--Ml1
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LEGEND
. . Purge wen
. . Monllorln9 wen
::I
-E}r
100 0
Do-
SW1
200
J
FIGURE 2
SITE MAP
with monitoring well location
SPARTAN CHEMICAL COMPANY
WYOMINC. MICHl CAN
"
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Table 4
SPARTAN CHEMICAL
GROUNDWATER MONITORING WELL/ANALYTICAL DATA
Summary Report
Units: ug/L
Compound Name
Minimum
Concentration
Detected
Maximum
Concentratioll
Detected
Maximum
Contaminants Level
(MCLa)
MICHIGAN
TYPE B
Levels
=============..ag===============c=================================c====================ca==============aR=acacaaa==e====
Benzene
Chlorobenzene
Chloroethane
Chloroform
Bthylbenzene
Methylene Chloride
l,l-Dichloroethane
1,2-Dichloroethane
l,l-Dichlorethylene
1,2-Dichloropropane
Trans-1,2-Cichloroethylene
Tetrachloroethylene
Toluene
l,l,I-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Vinyl Chloride
Xyh!llu
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
11.11.
1600.0
780.0
380.0
10000.0
12000.0
170.0
540.0
73.0
330.0
140.0
13000.0
1100.0
260000.0
6300.0
46.0
1900.0
210.0
-I I OliO. II
.****.**...*********
Key - N.D. . Not Detected
- N.A. a Data Not Available
5.0
N.A.
N.A.
100.0
700.0
N.A.
N.A.'
5.0
7.0
5.0
100.0
5.0
1000.0
200.0
5.0
5.0
2.0
10000.0
1.0
100.0
9.0
6.0
700.0
5.0
700.0
0.4
7.0
0.5
100.0
0.7
1000.0
200.0
0.6
3.0
0.02
10000.0
N
.....
-------
monitoring, are utilizing a public water supply. Area residents may, however,
use the_groundwater for outdoor use (i.e., car washing and lawn sprinkling)
and thereby expose themselves to a potential health risk.
Downgradient of Spartan Chemical is Lamar Park. Lamar Pond, which is used for
various recreational activities, is located within the park. This pond has
previously been sampled, with no indication of contamination.
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementation of the response action selected in this ROD, may
present an imminent and substantial endangerment to public health, welfare, or
the environment.
VII. DESCRIPTION OF ALTERNATIVES
At the time the Proposed Plan was issued, two remedial alternatives were
proposed for the interim action. These alternatives only address the
contaminated groundwater and are:
Alternative 1 - No Action
The Superfund program requires that the "no action" alternative be considered
at every site. Under this alternative, the existing groundwater collection
and treatment system would be shut down, allowing for continued migration of
groundwater contamination. No groundwater monitoring would be conducted.
There is no cost or operation and maintenance (O & M) asso~iated with this
alternative.
Alternative 2 - Continuation of Groundwater Collection and Treatment System
Operation of the groundwater collection and treatment system would continue in
order to reduce concentrations of contaminants in the groundwater that exceed
MCLs and Michigan's type B cleanup criteria and to reduce the migration of the
groundwater contaminants. Groundwater sampling of certain monitoring wells
would continue to allow for evaluation of contaminant concentrations,
contami~ant movement, and effectiveness of the system. Implementation of this
alternative would not be a problem, since the treatment system with an
incinerator for the treatment of off-gases and two purge wells are already in
place.
The treatment system began operation in 1988. When in operation, the treated
water was discharged to the city of Wyoming's sanitary sewer system, with
treatment of volatile organic contaminants by the incinerator. The treatment
system consists of the following major components:
1). In-line bag filter
2) Stripping tower
3) Catalytic incinerator
4) Effluent pump
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The first component, the in-line bag filter, is designed to remove particulate
matter trom the groundwater before it enters the stripping tower. The filter
bags are 150 micron mesh and are made of polyester. The second component,
which is the stripping tower, is 5 feet in diameter and approximately 50 feet
tall. The purged groundwater is pumped to the top of the tower and evenly
spread over the diameter of the tower. As the groundwater cascades down
through the tower, the contaminants are stripped from the groun6water by air
that is passing up through the tower. The third component of the treatment
system is the incinerator. It heats the air stream up to approximately 800°F.
The heated stream then passes through a catalyst bed, where the contaminants
are incinerated. The hot exhaust gases from the catalyst bed are then passed
through a primary heat exchanger and then into the atmosphere through a 4 inch
diameter stacK at a point 24 feet above grade. The purpose of the effluent
pump, the fourth component, is for recirculation, as well as for effluent
discharge, depending on what is necessary. Refer to Figure 3 for a diagram of
the treatment system.
Approximate 0 & M costs associated with the existing system are approximately
$6,000 per month. This cost estimate does not account for potential discharge
or design modifications that may impact the cost.
Subsequent to the public comment for these two alternatives, it was necessary
to shut-off the groundwater collection and treatment system. Please see
Section XI. Documentation of SiQnificant ChanQes for a discussion of this
issue.
VIII.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
Evaluation Criteria
In order to determine the most appropriate alternative for the groundwater at
the Spartan Chemical site, the alternatives were evaluated using the nine.
evaluation criteria, required under Superfund regulations. The nine criteria
are summarized as follows:
1. Overall protection of human health and the environment addresses whether a
remedy provides adequate protection of human health and the environment and
describes how risKs posed through each exposure pathway are eliminated,
reduced, or controlled through treatment, engineering controls, or
institutional controls.
2. Compliance with applicable or relevant and appropriate requirements
(ARARs) addresses whether a remedy will meet all of the ARARs of other federal
and state environmental laws and/or justifies a waiver of the regulation to
implement the remedy.
3. Long-term effectiveness and permanence refers to expected residual riSK
and the ability of a remedy to maintain reliable protection of human health
and the environment over time, once cleanup goals have been met.
o
14
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--
--.....-...
---------....--.
BAG FILTER
STRIPPINC TOWER
EFFLUENT PUMP
f!i':U!
~B8
,. ivl r..~OJ
CATALYTIC INCINERATOR
<
co
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EQUIPMENT BUILDING
C)
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WLI.
MO'roR CONTROL CENTER
EQUIPMENT
LA YOUr SCHEMATIC
T-20f
STRIPPING TOW'ER
'-PilIL '~AA
FIGURE,)
10
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4. Reduction of toxicity. mobility. or volume through treatment evaluates the
anticip~ted performance of each treatment technology with respect to reduction
or elimination of contamination toxicity, mobility, and volume.
5. Short-term effectiveness addresses the period of time needed to achieve
protection, and any adverse impacts on human health and the environment that
may be posed during the construction and implementation period of each
alternative.
6. Implementability is the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to
implement a particular option.
7. Cost includes estimated initial capital and 0 & M costs. Cost is also
expressed as net present worth costs, which is the total cost of an
alternative in terms of today's dollars.
8. State/support agency acceptance reflects aspects of the recommended
alternative and other alternatives that the support agency favors or objects
to, and any specific comments regarding ARARs or the proposed use of waivers.
9. Community acceptance summarizes the public's general response to the
alternatives described in the Proposed Plan, based on public comments.
received. Evaluations under this criterion are usually not completed until
after the public comment period on the Proposed Plan.
B.
Comparative Analysis
The "no action" alternative is not protective of human health and would not
meet state and federal ARARs. For these reasons, it is not available for
selection as the groundwater remedy, and will not be carried through the
evaluation process against the nine criteria as described above. The
following comparative analysis discusses Alternative 2 only, assessing its
performance, should the system be restarted and operation continued, against
the nine evaluation criteria.
1. Overall Protection of Human Health and the Environment
Operation of the treatment system would reduce potential threats to human
health and the environment by reducing the spread of groundwater contamination
while not releasing contaminants to the air because of incineration of the
off-gases.
2. Compliance with ARARs
An interim action ARAR waiver is being invoked for this interim response
action for groundwater cleanup criteria. The final groundwater response
action will comply with federal and state ARARs or provide justification for a
waiver. This interim action will comply with ARARs relating to discharge of
the treated groundwater, disposal of any treatment residuals, and any air
emissions from the groundwater treatment system.
16
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3. Long-term Effectiveness and Permanence
This cr~terion is not applicable at this time. A further and more complete
evaluation of the site remedy will be conducted after completion of additional
site investigation activities.
4. Reduction of Toxicity, Mobility, or Volume
Contaminant toxicity, mobility, and volume would be reduced by treatment of
the contaminated groundwater. .
5. Short-term Effectiveness
Prior to the shutdown of the groundwater collection and treatment system
discussed in Section XI. Documentation of SiQnificant ChanQes the air
stripper system was operating to contain the contaminant plume. The shutdown
and future evaluation of the groundwater collection and treatment system may
create some short-term problems. The shutdown may result in the further
migration of the contaminant plume. This condition is presently being
monitored at the site. The evaluation of possible future modifications to the
groundwater collection and treatment system and changes in the treated
groundwater discharge points may result in a short d~lay in achieving
. containment of the contaminant plume.
6. Implementability
Prior to the shutdown of the groundwater collection and treatment system
discussed in Section XI. Documentation of SiQnificant ChanQes, the system was
fully operational and this criterion was not applicable. The shutdown of the
system and the possible modifications and options for discharge being
considered to restart the system may present future impleme~tation problems.
These problems would be primarily associated with obtaining approvals (i.e.,
permitting requirements) from and coordinating with other agencies.
7. Cost
When Alternative 2 was presented in the Proposed Plan to the public, no
construction costs were anticipated for implementation of this alternative.
Now that the system is shut down, an evaluation of system modifications and
various discharge options for treated groundwater is required. This
evaluation process may result in modifications to the treatment system and/or
location of the discharge point. Any modifications would likely result in
construction costs. However, these costs are expected to be minimal since the
primary treatment system is in place.
The approximate cost for 0 & M associated with the existing groundwater
collection and treatment system and groundwater monitoring is $6000 per month.
Changes. resulting from the evaluation of the current system may impact the
cost of 0 & M.
8. State Acceptance
The MDNR was the lead agency for preparing the Proposed Plan and the ROD. The
MDNR recommends the selection of Alternative '2: Continuation of the
Groundwater Collection and Treatment System, with some modifications. The EPA
agrees with MDNR recommendations.
17
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9. Community Acceptance
Overall the community supports continued treatment of the groundwater.
However, there were some concerns expressed with regard to air emissions from
the treatment system. Air emissions are treated by an incinerator before
discharge to the air. See the attached Responsiveness Summary for a full
discussion regarding Community Acceptance.
IX.
SELECTED REMEDY
The selected interim groundwater remedy for this site is Alternative 2 with
some modifications. The major components of the selected interim remedial
action include:
* Evaluation of the existing groundwater collection and treatment
system and of discharge options available for the treated
groundwater. The evaluation process may result in modifications to
the existing treatment system and/or relocation of the discharge
point;
* Restart of the existing groundwater collection and treatment
system; and
* Groundwater monitoring to evaluate the effectiveness of the
groundwater collection and treatment system.
Additional site investigations will be required to better characterize the
site, focusing Qn potential source areas. Further remedial action~may also
be required to address any remaining site concerns.
Operation-of the groundwater collection and treatment system provides the best
solution to the groundwater contamination, even though the current non-
operational status of the system may present some short-term effectiveness and
implementability concerns before the system is operational again. Cost
associated with any modifications would be minimal since the primary system is
in place. Based on a comparison of the two alternatives to the nine
evaluation criteria and the fact that the system is in place, Alternative 2
with potential system and discharge modifications provides the best solution
to the groundwater contamination problems. Potential discharge options are
discussed in Section XI. Documentation of SiQnificant ChanQes.
X.
STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of Section 121 (a-e) of
CERClA. The requirements specify that a remedy: a) Protect human health and
the environment; b) comply with ARARs; or provide justification for a waiver;
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 principal element of the remedy. The implementation of
q
18
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Alternative 2, with modifications, at Spartan Chemical satisfies these
requirements of CERClA as detailed below:
A.
Protection of Human Health and the Environment
Implementation of the selected remedy will reduce and control potential risks
to human health and the environment by controlling the further migration of
contamination off-site and treating on-site groundwater contamination.
Protection of human health and the environment will be achieved by future
response actions at this site to address contaminated soils that may be an on-
going source to the groundwater contamination.
B.
Compliance with ARARs
An interim action waiver is being invoked for this response action for
groundwater cleanup criteria. The final groundwater response action will
comply with federal and state ARARs or provide justification for a waiver.
This interim action will comply with ARARs relating to the discharge of the
treated groundwater, disposal of any treatment residuals, and any air
emissions from the groundwater treatment system.
ARARs relating to the discharge of treated groundwater to surface water
include the Clean Water Act of 1977, as amended (33 U.S.C. 1251) and the Water
Resources Commission Act, 1929 P.A. 245, as amended, Part 4, Rule 57 - Water
Quality Standards. ARARs relating to the discharge of treated groundwater to
the ground include the Water Resources Commission Act, 1929 P.A. 245, as
amended, Part 21 - Wastewater Discharge Permits. -
ARARs relating to the disposal of any treatment residuals include the Resource
Conservation and Recovery Act of 1976.
ARARs relating to the air emissions from the operation of the incinerator
system include the Clean Air Act of 1963, as amended (42 U.S.C. 7401), 40 CFR
50 - National Primary and Secondary Ambient Air Quality Standards; the Clean
Air Act of 1963, as amended (42 U.S.C. 7401), 40 CFR 61 - National Emission
Standards for Hazardous Air Pollutants; and the Air Pollution Act, 1965 P.A.
348, as amended, Parts 3, 7, and 9.
C.
Cost-effectiveness
The selected remedy is cost-effective, since construction of the primary
treatment system has already been completed by the owner of Spartan Chemical,
prior to bankruptcy of the company.
D.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum Extent
Practicable
The MDNR and the EPA believe that the selected remedy represents the maximum
extent to which permanent solutions and treatment technologies can be utilized
in a cost-effective manner for this interim action.
19
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E.
Preference for Treatment as a Principal Element
This preference is addressed in the interim action since groundwater is being
treated. This preference will be further addressed in the final decision
document for this site.
. .
XI.
DOCUMENTATION OF SIGNIFICANT CHANGES
In January 1993, subsequent to the close of the public comment period, the
treatment system was shut down because of unresolved problems regarding the
renewal of the discharge service agreement with the city of Wyoming. A
service agreement (or permit) was needed to continue discharging treated
groundwater to the city of Wyoming wastewater treatment plant. In brief, the
main unresolved issues are: 1) the state cannot legally sign a new service
agreement or permit because the city is now requiring indemnification
language, and 2) the treatment system was unable to meet the discharge limits
being imposed by the city in the new agreement.
It will be necessary to evaluate options for upgrade of the existing system
and discharge of treated groundwater before the system can be put back in
operation. The discharge options that will likely be included in the
evaluation are; (1) reinjection back into the groundwater, (2) discharge to
the city of Wyoming wastewater treatment plant, and (3) direct discharge to
the nearest surface water body which requires satisfying the state
requirements for a National Pollutant Discharge Elimination System (NPDES)
permit. These options are presented here for information purposes only, and
another option may be evaluated, and possibly chosen, for discharge~f the
treated groundwater. Any option chosen will comply with ARARs or a waiver
will be invoked.
Upon completion of the entire evaluation process, additional design activities
may be necessary to achieve an effective and complete groundwater treatment
system.
q
20
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