United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-93/240
March 1993
f/EPA Superfund
Record of Decision:
Muskegon Chemical, Ml
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. 2. 3. Rec:ipient'. Acce8.lon No.
PAGE EPA/ROD/R05-93/240
4. Thl. and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 03/10/93
Muskegon Chemical, MI 6.
First Remedial Action
7. Author(a) 8. Parformlng Organization Rept. No.
9. Performing Organization Name and Addr- 10 ProJact Ta8k/Work Unit No.
11. Contrect(C) or Grent(G) No.
(C)
(G)
12. Sponsoring Organization Name and Add,... 13. Type of Report & Period Cov.red
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplomentary Note.
PB94-964110
16. Abstrect (Limit: 200 words)
The Muskegon Chemical site is located in Whitehall and Fruitland Township, Muskegon
County, Michigan. The site consists of a 19.6-acre chemical manufacturing plant; the
downgradient area between the plant and Mill Pond Creek; and a surface water body
located approximately one-half mile southwest of the plant. Land use in the area is.
predominantly ~ight industrial and residential, with wooded areas to the east of. the
plant and a narrow marshy area adjacent to Mill pond Creek. Underlying the site are
two glacial drift aquifers, which are used by area residents as a drinking water
source. A municipal water supply well is located 900 feet north of the fa cHi ty;
however, ground water flow in the area is to the south-southwest towards Mill Pond
Creek. The nearest residential well downgradient of the plant is one-half mile to the
south-southwest. In 1975, the Muskegon Chemical Company began production of specialty
chemicals at the plant. In 1977, ground water contamination was first detected during
testing for installation of an industriai water supply well at the facility. In 1980,
an investigation indicated the presence of several VOCs in ground water and documented
that the plume was 1,150 feet in length and flowed in a southwesterly direction. In
1981, the State discovered that the ground water contaminant plume was discharging to
(See Attached page)
17. Document Analysis .. Descriptors
Record of Decision - Muskegon Chemical, MI
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (PCE)
b. IdantlfilnslOpen-EncI8d Ttnn8
c. COSATI Fielci'Group
18. Availability Stat_nt 19. Security Class (thIs Report) 21. No.ofPag..
None 34
20. Security Class (this Page) 22. Price
None
(See ANSI.Z39.18)
s..lnstructions on Reverss
OPTIONAL FORM 272 (4-77)
(Formerly NTlSo35)
Department of Commerce
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EPA/ROD/R05-93/240
Muskegon Chemical, MI
First Remedial Action
Abstract (Continued)
Mill Pond Creek. The State determined that this discharge is a threat to human health and
the environment. In 1981 and 1983, the State required additional ground water
investigations and installation of ground water purge wells and a ground water treatment
system. In 1985, Koch Chemical Company purchased the facility from Muskegon Chemical. In
1986, the State ordered Muskegon Chemical and Koch to continue operation of the existing
purge well system for seven years. In 1989, after a State report indicated that
contaminants still were impacting Mill Pond Creek, additional investigations were
conducted to document the level of contamination at the Muskegon facility. In 1991, the
State required Koch to conduct an interim response action and additional site
investigations. This ROD documents the details of the interim response action which
addresses the contaminated offsite ground water discharging into Mill Pond Creek. A
future ROD will address onsite soil and ground water contamination. The primary
contaminants of concern affecting the ground water are VOCs, including PCE.
The selected remedial action for this site includes installing as many 4-inch diameter
purge wells as are needed to capture the contaminated ground water plume and prevent
further discharge to Mill Pond Creek; extracting and treating contaminated ground water
onsite using Koch's granular activated carbon treatment system to remove organics;
discharging the treated water offsite to the Whitehall area POTW; sampling soil and ground
water in the Mill Pond Creek's floodplain during or prior to well installation; and
monitoring soil, ground water, surface water, and air to determine effectiveness of the
treatment system. The estimated present worth cost for this remedial action is $540,000,
which includes an estimated annual O&M cost of $330,000 for one year.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil and sediment cleanup goals are ba~edon the State risk-based
cleanup criteria,-and include aluminum 1 mg/kg; arsenic 0.0004 mg/kg; barium 40 mg/kg;
bis(2-ethylhexyl)phthalate 40mg/kg; cadmium 0.08 mg/kg; chromium 2 mg/kg; 4,4-DDE 2
ug/kg; 4,4-DDD 2 ug/kg; dieldrin 0.04 ug/kg; di-n-octylphthalate 2,000 ug/kg; lead 0.08
mg/kg; mercury 0.04 mg/kg; nickel 2 mg/kg; and PCE 14 ug/kg. Chemical-specific ground
water cleanup goals also are based on the State risk-based cleanup criteria, and include
alpha-chlordane 0.03 ug/l; arsenic 0.02 ug/l;' beta-SHC 0.02 ug/l; boron 600 ug/l; chrysene
0.003 ug/l; dieldrin 0.002 ug/l; gamma-chlordane 0.03 ug/l; lead 4 ug/l; PCE 0.7 ug/l;
sodium 150,000 ug/l; 1,1,2,2-TCA 0.2 ug/l; and TCE 3 ug/l. However, if site background
concentrations exceed these values, then the site background level shall replace a risk-
based cleanup criterion.
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.,'
DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Muskegon Chemical Company
1725 Warner Street
Whitehall, Muskegon County, Michigan
Statement of Basis and Purpose
This decision document presents the selected interim response action for the
Muskegon Chemical Company Site in the city of Whitehall and Fruitland Township,
Muskegon County, Michigan (see figure 1). This interim response action was
chosen in accordance with the requirements of the Michigan Environmental Response
Act, 1982 PA 307, as amended; the Comprehensive Environmental Response,
Compensat i on and L i abil ity Act of 1980 (CERCLA) as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA); and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). The decisions contained
herein are based on the information contained in the administrative record for
this site.
The U. S. Envi ronmenta 1 Protection Agency (EPA) has chosen not to revi ew the
. selection of this interim action at this time.
"
Assessment of the Site
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this Record of Decision
(ROD), may present an imminent and substantial endangerment to public hea1th,
welfare or the environment.
Description of the Selected Remedy
This interim response action addresses the contaminated groundwater plume in the
vicinity of Mill Pond Creek. The Engineering Evaluation and Cost Analysis Report
for the Muskegon Chemical Company site identified the area where contaminated
groundwater discharges to the surface waters of Mill Pond Creek as an area of
concern.
The i nteri m response action chosen for the Muskegon Chemi ca 1 Company site,
described in the attached Decision Summary, will reduce the potential for human
exposure to hazardous substances from contact with contaminated surface water.
The principal threats will be mitigated by a groundwater extraction and treatment
system. The interim response action will be closely monitored throughout
implementation and should monitoring indicate the ineffectiveness of any
component of the remedy, corrective action will be taken.
The major components of the interim response action selected to address this area
of concern include the following:
*
extraction of groundwater to capture and halt the flow of the contaminated
groundwater plume before it reaches Mill Pond Creek,
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*
removal of organic contaminants by carbon adsorption,
*
discharge of treated water to the Whitehall Area Publicly Owned Treatment
Works (POTW), and
*
surface water, groundwater, soil and air monitori ng to' be conducted to
assess the effectiveness of the system at halting the migration of
contamination and reducing the levels of contamination in the groundwater,
surface water and air. .
Statutory Determinations
The selected i nteri m response act ion is protect i ve of human health and the
environment, complies with federal and state requirements that are legally
applicable or relevant and appropriate for this interim response action, and is
. cost-effective. Although this interim response action is not intended to fully
address the statutory mandate for permanence and treatment to the maximum extent
practicable, this interim response action utilizes treatment that reduces
toxicity, mobility or volume as the principal element and thus is in furtherance
of the statutory mandate. Subsequent actions are planned to fully address the
threats posed by the conditions at this site.
Russell arding
Deputy irector
Michigan Department
7ao)r ~
Date
-2-
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DECISION SUMMARY FOR THE RECORD OF DECISION
Site Name. Location. and Description
The Muskegon Chemi ca 1 Company site is located in the city of Wh i teha 11 and
Fruitland Township, Muskegon County, Michigan (see figure 1). The site consists
of the former 19.6 acre Koch Chemical Company's Whitehall Specialty Chemical
Plant located at 1725 Warner Street, and extends approximately! mile southwest
to Mi~l Pond Creek. The area of concern for the interim response action is the
area bounded by Mill Pond Creek to the south and west Simonelli Road to the east,
and White Lake Drive to the north (see figure 2).
The former Koch Chemical Company facility is bordered on the north by a light
industrial area, an open wooded area to the east, the C&O Railroad to the south,
and Warner Street to the West. Another light/medium industrial area
(Howmet/MISCO Corporation) is located on the west side of Warner Street, across
from the facility. South of the railroad tracks is a wooded area drained by
Mill Pond Creek. A narrow marshy area is located adjacent to Mill Pond Creek
throughout the interim response action area of concern.
Investigations have shown that two glacial drift aquifers are present beneath the
Muskegon Chemical Company site which are separated by a silt and clay confining
layer. These are in turn underlain by a thick layer of clay that forms the base
of the aquifer in this area.
The direction of groundwater flow in the area of concern is to the south -
southwest towards Mill Pond Creek. Information obtained from the interim
response action and remedial investigation studies indicate that groundwater in
the upper sand aquifer discharges to Mill Pond Creek.
Many residences in this area use both the upper and lower aquifers as a SQurce
of drinking water. Sampling of residential wells in the vicinity of the site in
June 1991, did not show any impact from the contaminated groundwater plume. The
nearest residential groundwater wells are located t mile north and ~ mile south
southwest of the site. A Whitehall municipal well is located 900 feet north of
the facility. .
Site History and Enforcement Activities
The Muskegon Chemical Company began production of specialty chemicals at the
Whitehall facility in.1975.
Groundwater contamination was initially discovered in 1977, during testing for
the installation of an industrial water supply well at the facility.
A hydrogeologic investigation conducted in 1980, identified three primary organic
contaminants of concern in the groundwater: 1,2 dichloroethane (DCA), bis
(2-chloroethyl) ether (Chlorex), and triglycol dichloride (TGDC). The
contaminant plume was estimated to be 1,150 feet in length, flowing in a
southwesterly direction from the facility. The Muskegon Chemical Company
installed one purge well, centrally, in the path of the plume. The probable
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source of contamination was identified as a leak in the drainage system inside
the Muskegon Chemical Company manufacturing facility, which was subsequently
repaired.
In 1981, it was discovered that the groundwater contamination plume from the
Whitehall facility was discharging to Mill Pond Creek. As a result of this
discharge, the Michigan Department of Natural Resources (MDNR) and the Muskegon
Chemical Company entered into a consent agreement and a plea agreement in 1981
and 1983 respectively. These agreements required the Muskegon Chemical Company
to conduct two hydrogeologic investigations, and to install several groundwater
purge wells and a groundwater treatment system.
On December 31, 1985, Koch .Chemica1 Company (Koch) purchased the Whitehall
facility from Muskegon Chemical Company. On January 7, 1986, Muskegon Chemical
Company, Koch, and the MDNR entered a consent agreement wh i ch approved the
existing purge well system and established a seven year period of operation.
A March 1989, report by the Surface Water Quality division of the MDNR documented
continued impact by the Whitehall facility groundwater contamination plume on
Mill Pond Creek. On February 21, 1990, the Muskegon Chemical Company Superfund
Site was placed on the National Priorities List (NPL), requiring that
contamination at the site be investigated and cleaned up according to the
provisions of the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA).
On February 25, 1991, Koch and the MDNR signed an Administrative Order by
Consent, that requires Koch to conduct an interim response action and a Remedial
Investigation and Feasibility Study (RIfFS) under direction of the MDNR. As a
result of this order, Koch has retained the firm of CH2M Hill to perform the
interim response action and RIfFS.
During the summer of 1991, Koch conducted field activities, which included ground
water, surface water, soil and sediment sampling, as part of the interim response
action and remedial investigation at the site.
Hiqh1iqhts of Community Participation
A chronology of community relation activities for the Muskegon Chemical Company
site is provi ded as part of the attached Responsi veness Sumary. The Engi neeri ng
Evaluation and Cost Analysis (EEjCA) report and interim response action Proposed
Plan for the Muskegon Chemical Company site were released for comment on April
14, 1992. These two ~ocuments were made available to the public in both the
administrative record and the information repository maintained at the Whitehall
City Library and the MDNR, Environmental Response Division, Superfund Section
office in Lansing, Michigan. The notices of availability for the EE/CA report
and Proposed Plan were published in the White lake Beacon and the Muskegon
Chronicle. Issuance of the Proposed Plan detailing the MDNR's preferred
alternative, on April 14, 1992, initiated a 30 day public comment period for both
the Proposed P1 an and the EE/CA report. A pub 1 i c meeting' and avail abil i ty
session was held on April 30, 1992, at the Whitehall City Hall. Themeeting
consisted of a short presentation outlining the results of the field
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investigation and the alternatives considered for the interim response action,
followed by a formal question and answer session. Following the public meeting,
the MDNR project manager and representatives from the Koch Chemical Company were
available for informal discussion on the EE/CA report, the proposed plan, and any
other subject related to the Muskegon Chemical Company site. Responses to the
comments received during the public comment period are included in the
Responsiveness Summary, which is part of this ROD.
Scope and Role of Response Action Within Site Strategy
The MDNR considers the discharge of contaminated groundwater to Hill Pond Creek
to be a threat or potential threat to human health and the envi ronment.
Reduction of.this threat or potential threat is best achieved by halting the flow
of contaminated groundwater into Mill Pond Creek. The primary human exposure
pathway is via direct contact with or incidental ingestion of contaminated
surface water. This interim action is necessary to halt the migration of the
contaminated groundwater plume and protect human health and the environment from
the above mentioned exposure pathway. It is the intent of this interim response
action to quickly stop all groundwater contaminated above Michigan Environmental
Response Act, PA 307, as amended, Type B levels from discharging into Mill Pond
Creek. To the greatest extent practicable, this interim response action will be
consistent with the overall remedial action at the site. The Remedial
Investigation and Risk Assessment reports are expected to be released in the late
Spring or early Summer of 1993. These reports will address ihe remaining areas
of concern at the Muskegon Chemical Company site.
Summary of Site Characteristics
In March of 1992, the MDNR released the EE/CA report for the interim response
action at the Muskegon Chemical Company site. During the investigation, the. area
of concern associated with the discharge of contaminants to ~ill Pond Creek was
characterized, this included the following.
Geoloqy and Hydroqeoloqy
The geology in the interim response action study area consists of inter-layered
sands, silts and clays. The sandy materials are mostly fine to medium sand, with
occasional coarse sand with gravel. Where saturated, the sand forms the
uppermost aquifer at the site, which is under water table conditions. The upper
sand unit is approximately 60 feet thick and is underlain by a thick layer of
clay that forms the base of the aquifer in this area.
The upper sand is divided roughly in half by a laterally continuous fine grained
unit composed predominately of silt with varying quantities of clay. The unit
averages about 5 feet in thickness and forms the base of the uppermost aquifer
at the site. Observations during field activities suggest that this thin fine
grained unit may be laterally continuous beneath Mill Pond Creek and throughout.
the interim response action study area.
Underlying this silt/clay unit is another fine to medium grained sand layer about
30 feet thick, which is in turn underlain by a substantial thickness of gray clay
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having interbedded sand units. The 30-foot thick sand unit was observed to be
saturated and constitutes a confined aquifer in the vicinity of Mill Pond Creek.
Th~ direction of groundwater flow in the interim response action study area i~
to the south-southwest towards Mill Pond Creek. Information obtained from the
field investigations indicate that groundwater in the upper sand aquifer
discharges to Mill Pond Creek.
Many residences in this area use both the upper and lower aquifers as a source
of drinking water. Sampling of residential wells in the vicinity of the site in
June 1991, did not show impact from the contaminated groundwater plume. The
nearest residential groundwater wells are located t mile north and 4 mile
south-southwest of the site. A Whitehall municipal well is located 900 feet
north of the facility. .
Nature and Extent of Contamination
The interim response action investigation included studies for potentially
contaminated medi.a in the vicinity of Mill Pond Creek, including soils,
groundwater, and surface water and sediments in Mill Pond Creek and the unnamed
tri butary that runs southeast of the production facil i ty. Results of the
investigation show that the groundwater contamination plume is approximately
1,100 feet wide (see figure 2). The groundwater contaminants of concern are
tetrach 1 oroethene (PCE), 1,2 d i ch 1 oroethane (DCA), bi s (2 -ch 1 oroethyl) ether
(Chlorex), and triglycol dichloride (TGDC). The range of. contaminant
concentrations is listed in Table 1. The extent of soil contamination in the
floodplain adjacent to Mill Pond Creek will be fully delineated as part of the
design of the interim response action.
Soil and groundwater contamination in the vicinity of the former production
facility will be addressed as part of the final remedial action for the site.
Summary of Site Risks
Due to the fact that this is an interim response action being performed early in
the cleanup process, the quantitative risk assessment for the site has not been
completed. However, the Michigan Department of Public Health in conjunction with
the Agency for Toxic Substances and Disease Registry have prepared an Interim
Preliminary Public Health Assessment for the site. In thjs document several
potential exposure routes have been identified.
Human Health Risks
The following discussion of the Muskegon Chemical Company site risk describes the
general concepts used by the MDNR to determine chemicals of concern, risks posed
by these chemicals, and impact on risks by the interim response action.
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TABLE 1
MUSKEGON CHEMICAL SITE
INTERIM RESPONSE ACTION
CHEMICALS OF CONCERN
COMPOUND MAXIMUM CONCENTRATION (ppb) CLEANUP STANDARDS GROUND-
. (ppb) WATER
CLEANUP
surface water/ TYPE TYPE RULE CRITERIA
(ppb)
groundwater sediment A B 57
1,2-Dichloroethane 200 5 N/A 1 1 1
Tetrachloroethene 16 2 1 1 1 1
bis(2- 7 5 5 5 5 5
Chloroethyl)ether
bis(2- 250 N/D 5 N/A N/A 5
Chloroethoxy)ethane
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Contaminant Identification
As discussed previously, Table 1 contains contaminant concentration summaries for
the interim response action area of concern, which were taken from the EEICA
report. Contaminant concentrations reported in the EE/CA report include
groundwater, surface water, and sediment samples.
Exposure Assessment
The exposure assessment is part of the Ri sk Assessment. Its purpose is to
identify the potential exposure pathways and receptors. Identified pathways and
receptors are used in conjunction with assumptions of exposure frequency and
duration, to model exposure point concentrations. This assessment has not been
completed at this time; however, several potential exposure pathways and
receptors were identified as part of the Interim Preliminary Public Health
Assessment.
A.
Pathways
The following three media have been identified as primary potential
exposure pathways:
1.
Groundwater
Based on existing hydrogeologic and analytical chemical data, a
contaminated groundwater plume exists at the site. The plume starts
in the vicinity of the former Koch Chemical Company plant and has
mi grated south - southwest to Mi 11 Pond Creek and may potent i ally
impact surface water.
Potential exposure pathways may include. inhalation of volatilized
contaminants during showering or bathing, ingestion of; and dermal
absorption of organic compounds through water usage.
The nearest residential groundwater wells are located k mile north
and t mile south southwest of the site. A Whitehall municipal well
is located 900 feet north of the facility.
2.
Soils
Two soil areas of concern have been tentatively identified at the
site, these are: 1) The soil on the former Muskegon Chemi ca 1
facility property which is considered to be a potential source of
groundwater contamination; and 2) The soil in the marshy area
adjacent to Mill Pond Creek that is potentially affected by the
discharge. of contami nated groundwater through spri ngs. Derma 1
contact with, accidental ingestion of, and inhalation of volatile
organic contaminants and fugitive dust from surface soil
contamination are considered to be potential pathways.
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The soils in the marshy area adjacent to Mill Pond Creek will be
addressed by this interim response action. The soils on the former
Muskegon Chemical facility property will be addressed as part of the
final remedial action at the site.
r
3.
Surface Water
The surface water and sediments adjacent to the area where
contami nated groundwater discharges to Mill Pond Creek have been
tentatively identified as an area of concern at the site. Dermal
contact with, accidental ingestion of, and inhalation of volatile
organic contaminants from surface water and sediments are considered
as potential pathways.
The risk assessment will establish the relative importance of each
of the above mentioned exposure routes.
B.
Potentially Exposed Populations
The major potential exposure route is through exposure to contaminated
soils in the vicinity of Mill Pond Creek and contaminated surface water
and sediments in the Creek. Analysis of groundwater samples collected
during the RI indicate that the groundwater contamination plume has not
migrated beyond Mill Pond Creek, and that residential wells belonging to
potent i a 1 receptors are currently unaffected by the Muskegon Chemi ca 1
Company groundwater contamination plume. A re~idence located at the
intersection of Simonell i road and White Lake Drive is the closest
existing potential receptor.
C.
Exposure Estimates and Assumptions
Existing groundwater, soils, surface water, and sediment contamination is
currently assessed in relation to Type A, B, and C cleanup criteria
specified in Act 307 Rules, which provide for Type A, B, and C cleanup
criteria. CERCLA Section 121(d)(2)(A)(ii}, and the NCP provide for the
consideration of Act 307 Rules in the establishment of cleanup levels.
Type A, B, or C criteria are detailed further on in this ROD.
Potential groundwater and surface water contamination from the soils
adjacent to Mill Pond Creek area is also currently assessed in relation to
cleanup levels derived from Act 307 criteria. For soils, cleanup
standards are based on the objective of contaminant reduction in the soil
matrix to that level which will not leach contaminants above groundwater
cleanup levels (R299.5711(2}). Cleanup of the area soil is based on the
same objectives as cleanup of the groundwater.
The groundwater and soil cleanup standards chosen for this site are based
on Act 307 Rules. Criteria for cOJllplying with the Type A, B, or C
cleanups are contained in Act 307 Rules. The substantive provisions,
Parts 6 and 7 of the Act 307 Rules, are considered applicable or relevant
and appropri ate requi rements (ARARs) for the remedi a 1 action to be
9
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undertaken at the Muskegon Chemical Company site. These Rules require
that remedial actions shall be protective of public health, safety, and
welfare and the environment and natural resources (R299.5601(1». The Act
307 Rules specify that this standard be achieved by a degree of cleanup
which conforms to one or more of the Type A, B, or C cleanup criteria. A
Type A cleanup generally achieves cleanup to background or non-detectable
levels (R299.5707); a Type B meets risk-based cleanup levels in all media
(R299.5709, 5711, 5723, and 5725); and Type C cleanup is based on a site-
specific risk assessment which considers specified criteria (R299.5717 and
5719).
Contaminant levels found in the groundwater exceed the groundwater cleanup
criteria, as shown in Table 1.
Toxicity Assessment
A toxicity assessment, including a discussion of cancer potency factors and
reference doses for all contaminants of concern, will be included in the risk
assessment report.
Risk Characterization
Risk characterization including carcinogenic and noncarcinogenic risks and
uncerta i nty in the ri sk assessment will be addressed as part of the ri sk
assessment report. '
Environmental Risk
Over and above its utilitarian value to humans as a usable aquifer as defined by
the Water Quality Commission Act Part 22 Rules (R3223.2203(i», the groundwater
is a resource to be evaluated as are all other environmental compartments and
1 ife forms. Based on the findings of the Interim Response and Remedial
Investigations, a portion of the groundwater and surface water at the Muskegon
~hemical Company site has been degraded and poses the potential for further
degrading groundwater, surface water and sediments downgradient, if not
remediated. The prevention of further degradation of the presently contaminated
groundwater, surface water and sediments is an environmental remedial objective
that needs to be addressed by any final remedy chosen for the Muskegon Chemical
Company site.
Chemicals of Concern and Cleanup levels
Chemicals of concern were determined for the interim response action. The basis
for the selection of the four chemicals of concern (noted in Table 1) are those
detected at levels, in Interim Response and Remedial Investigation sample
analysis, which pose a potential risk to human health and the environment. The
Chemicals of Concern pose a potential risk by either exceeding the level for the
one in a million (lx10-6) carcinogenic risk, or by exceeding a detection limit,
where the detection 1 imit is above the concentration which present a 1xlO-6
carcinogenic risk. The basis for the selection of these cleanup levels are
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provided in the Act 307 Rules (R299.5705, 707, 709, 717), CERCLA Section
121(d}(2}(A}(ii}, and the NCP.
<>
Three chemi ca 1 s of concern, bi s (2-Chl oroethyl )ether, 1,2 -di chl oroethane and
tetrachloroethene, are known to cause cancer in laboratory animals, and are
therefore classified as carcinogens. These compounds have 1x10.6 carcinogenic
risk levels which are lower than what can be detected by current laboratory
methodologies. The cleanup levels for these chemicals of concern are set by
their respective method detection limits.
Very little toxicological information is available about bis(2-chloroethoxy)-
ethane. At this time it is not considered to be a carcinogen. Due to the lack
of information the cleanup level has been set equal to the method detection limit
for this compound.
Contami nant 1 eve 1 s found in the groundwater exceed the groundwater cleanup
criteria, as shown in Table 1.
Summary of RisKS
Potent i a 1 ri sks from di rect dermal contact or from i nha 1 at i on of airborne
contaminants in the soils, surface water and sediments in or adjacent to Mill
Pond Creek may pose a risk to human health.
Although no individuals are directly ingesting contaminated groundwater from the
Muskegon Chemical Company site, the contamination discharging to soils, surface
water and sediments in or adjacent to Mill Pond Creek could pose a health risk
to potential receptors. In order to prevent further degradation of soils,
surface water and sediments and to protect public health and the environment,
remediation of the groundwater resource is necessary.
Actual or threatened releases of hazardous substances from the Muskegon Chemical
Company site, if not addressed by implementing the response action selected in
this ROD, may present an imminent and substantial endangerment to public health,
welfare, or the environment.
Alternatives ScreeninQ Process
Preliminary Screening
A preliminary screening of remedial alternatives was conducted as a first step
of the EE/CA report. The preliminary screening first assembled general response
actions which satisfy the remedial objectives of the interim response action.
The fo 11 owi ng general categori es of response actions were i nc 1 uded in th is
preliminary screening process: .
*
*
No Action
Groundwater collection
In situ treatment
Ex situ treatment and discharge
*
*
11
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Four factors were used to screen the preliminary remedial technologies and their
associated process options: technical feasibility; effectiveness; environmental
impacts; and cost. . .
~
As a resul t of the pre 1 imi nary screeni ng process, only one option for the
treatment and discharge of contaminated groundwater met all four of the screening
criteria. This is the Collection System Flow Redistribution, Granular Activated
Carbon (GAC) Pretreatment and Discharge to Whitehall Area Publicly Owned
Treatment Works (POTW).
Koch currently has a permit to discharge 150,000 gallons per day of pretreated
water to the Whitehall Area POTW. Under this treatment and. discharge
alternative, flow from the existing system would be redistributed to allow the
volume from the new system to be incorporated within the limits of the existing
permit. Contaminated groundwater from the interim response action purge system
would be treated in Koch's existing GAC treatment system prior to discharge to
the Whitehall Area POTW. .
All alternatives discussed below will be implemented using an. "observational
approach" . Thi s means that the selected remedy wi 11 be constructed in a
step-wise fashion. For example, one purge well would be installed, developed,
and pumped to determine the cone of influence, and the location of the next well
would be based on the results of the first well. This process would. be repeated
until enough wells were installed to capture the entire plume. The use of this
observational approach will allow for the most efficient and expeditious
installation of the system and will increase the likelihood of implementation
during the 1992-1993 construction season. .
Detailed Evaluation of Alternatives
On 1 y a 1 i mited number of a lternat i ves rema i ned for th is action after the
preliminary screening process. The reader is directed to Tables 4~6 through 4-12
(and associated text in Chapter 4) of the EEICA report.
The resulting viable remedial action alternatives were secondarily screened,
based on the nine criteria outlined below. It was at this stage, prior to the
detailed screening, that options were combined to form a range of treatment and
disposal alternatives for the interim response action.
Description of Alternatives
The interim response action alternatives described below, were evaluated in the
EE/CA report as Alternatives 1 through 4-B--with Alternative 1 being the No
Action Alternative; Alternatives 2 through 48, variations on groundwater
extraction and treatment.
Alternative 1 - No Action
The No Action alternative is included to satisfy the requirements of the National
Contingency Plan (NCP) (40 CFR 300.430(e)(5)). Under this alternative, no
12
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further remedial measures would be taken for the interim response action, other
than those previously implemented at the site. .
Capital Cost: $ 0
Annual Operation and Maintenance (O&M):
Total Costs wi 1 Year O&M: $ 0
$ 0
The Superfund program requires that the No Action alternative be evaluated at
every site to establish a baseline for comparison. Under this alternative, no
further action would be taken at the site to prevent potential exposure to
contaminants migrating from the groundwater to the surface water.
Alternative 2 - Bluff interception wells
Under this alternative, 4-inch diameter groundwater purge wells would be
installed along the bluff. This system would capture the width of the
contaminant plume. Estimated flow of this system is 26 to 52 Gallons Per Minute
(gpm) . . The capture zone of thi s system extends to the toe of the bluff,
potentially leaving residual contamination in the flood plain to flush to the
creek.
Capital Cost: $ 210,000
Annual O&M: $ 330,000
Total Costs wi 1 YearO&M:
. .
$ 540,000
Alternative 2-A - Bluff interception wells, flood plain well points
Under this alternative, 4-inch diameter groundwater purge wells would be
installed along the bluff. This system would capture the width of the
contaminant plume. In addition, ll-inch hand driven well points would be placed
the width of the plume in the flood plain to capture any residual contamination
that may be present. Estimated flow of this system is 46 to 92 gpm.
Capital Cost: $ 230,000
Annual O&M: $ 330,000
Total Costs wi 1 Year O&M:
$ 560,000
Alternative 3 - Flood plain interception wells
Under this alternative, 4-inch diameter groundwater purge wells would be
installed in the flood plain. . This system would capture the width of the
contaminant plume. Estimated flow of this system is 25 to 50 gpm. The capture
zone of this system extends to the creek. Some draining may occur in the flood
plain.
Capital Cost: $ 230,000
Annual O&M: $ 330,000
Total Costs wi 1 Year O&M:
$ 560,000
13
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Alternative 4 - Flood plain interception trench
Under this alternative, a four foot wide by six foot deep trench would be dug
in the flood plain. This system would capture the width of the plume. The
trench would also be lined with a permeable geotextile fabric to prevent erosion.
A six inch diameter slotted drain pipe would be placed in the bottom and sump
pumps woul d be placed along the trench, as necessary, to collect any water
enteri ng the trench. The trench woul d then be backfi 11 ed wi th gravel. The
estimated flow of this system is 43 to 86 gpm. The capture zone of this system
extends to the creek. Some draining may occur in the flood plain.
~
Capital Cost: $ 540,000
Annual O&M: $ 330,000
Total Costs wi 1 Year O&M:
$ 870,000
Alternative 4-A - Flood plain interception trench and barrier
Under this alternative, a four by six foot trench would be dug in the flood
plain. This system would capture the width of the plume and be lined with a
permeable geotextile fabric. The downstream side of the trench would be lined
with an impermeable membrane to block flow. A six inch diameter slotted drain
pipe would be placed in the bottom and sump pumps would be placed along the
trench as necessary to collect any water entering the trench. The trench would
then be backfilled with gravel. The estimated flow of this system is 30 to 60
gpm. The capture zone. of this system would end at the down gradient side of the
trench, potentially leaving residual contamination between the trench and the
creek to flush to the creek.
Capital Cost: $ 560,000
Annual O&M: $ 330,000
Total Costs wi 1 Year O&M:
$ 890,000
Alternative 4-8 - Flood plain interception trench and delayed barrier
Under this alternative, a four foot wide by six foot deep trench would be dug in
the flood plain. This system would capture the width of the plume and be lined
with a permeable geotexti1e fabric. A six inch diameter slotted drain pipe would
be placed in the bottom and sump pumps would be placed along the trench as
necessary to collect any water entering the trench. The trench would then be
backfilled with gravel. After the system is operated long enough to remove all
contaminated groundwater between the trench and the stream, a bentonite slurry
wa 11 wou1 d be i nsta 11 ed down gradi ent of the trench to reduce the flow of
uncontaminated groundwater into the system. The initial estimated flow of this
system is 43 to 86 gpm. The estimated flow after installation of the slurry wall
is 30 to 60 gpm. Prior to installation of the slurry wall the capture zone would
extend to the creek. After installation of the slurry wall the capture zone
would end at the slurry wall.
Capital Cost: $ 620,000
Annual O&M: $ 330,000
Total Costs wi 1 Year O&M:
$ 950,000
14
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The detailed evaluation of alternatives based on the nine criteria is described
as below.
Detailed Evaluation of Alternatives
The following nine criteria, outlined in the NCP at Section 300.430(e}(9}(iii),
were used to compare' the a 1 ternat i ves and to determi ne the most appropri ate
alternative for remediation of the soils and groundwater that is protective of
human health and the environment, attains ARARs, is cost-effective and represents
the best balance among the evaluating criteria. The paragraph(s) following each
criterion detail how the alternatives meet or fail to meet, that criterion. This
comparison of alternatives considers the options for the interim response action.
1.
Overall Protection of Human Health and the Environment addresses whether
or not a remedy provides adequate protection and describes how risks are
eliminated, reduced or controlled through treatment, engineering controls
or institutional controls.
All of the alternatives considered for the interim response action, with the
exception of the No Action alternative, adequately reduce the risk to human
health and the environment by limiting the potential for further contaminant
migration to the surface water. Alternatives 2 and 4-A could potentially' leave
residual contamination in the flood plain to flush to the Mill Pond Creek. All
other alternatives would stop the flow of contaminants to the creek. All
groundwater options 'woul d stop the majority of the flow of contami nants into Mill
Pond Creek, eliminating the direct dermal contact and ingestion of surface water
exposure pathways.
All of the alternatives, with the exception of the No Action alternative, will
remove contaminants to an acceptable level prior to discharge to the Whitehall
Area POTW. The water will be further treated at the Whitehall Area POTW through
biological degradation before discharge to the environment.
Any short term risks associated with the alternatives are primarily due to
construction activities. A health and safety program will reduce these risks to
workers involved with construction, operation, and maintenance of the system.
Alternative I-No Action does nothing to prevent further contaminant migration
to the surface water.
Risks currently posed by the contaminated groundwater would not be expected to
decrease under the No Action scenario. Although the site is currently posted
advising against trespass, the potential for direct contact with contaminated
surface water is not completely mitigated, and the No Action alternative does
nothing to reduce the' potential for direct contact with the surface water.
2.
Compliance with ARARs addresses how the proposed alternative complies with
all ARARs of Federal and more stringent State environmental laws and also
considers how alternatives comply with advisories or other guidance that
do not have the status of laws, but that the U.S. Environmental Protection
Agency (EPA) and the State have agreed should be considered for
protectiveness, or to carry out certain actions or requirements.
15
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All alternatives, except the no action alternative, will generally comply with
ARARs of State and Federal environmental or facility siting laws specific to this
interim action. The following State and Federal ARARs are specific to this.
interim response action:
:
*
*
CERClA
Act 307
Federal Clean Water Act (CWA 40 CFR part 403)
Michigan Soil Erosion Sedimentation Control Act of 1972 (Act 347)
Michigan Water Resources Commission Act, 1929 PA 245, as amended
Michigan Goemaere-Anderson Wetland Protection Act of 1979 (Act 203)
*
*
*
*
3.
long-term Effectiveness and Permanence refers to the ability of a remedy
to maintain reliable protection of human health and the environment over
time, once cleanup goals have been met.
This interim response action is not intended to be permanent, but is intended
to stop the flow of contaminated groundwater into Mill Pond Creek until a
site-wide remedy can be implemented (2 to 3 years). It is possible that the
interim response action system may become incorporated into the final remedial
action for the site.
The No Action alternative would not be an effective long-term solution to the
problem at the site, as it does not address existing or future site risks.
Alternatives 2 through 4-8 provide the greatest reduction in the potential for
exposure to surface water contami nants. These a 1 ternat i ves are expected to
reduce contami nant concentrat ions in Mill Pond Creek by e 1 i mi nat i ng further
discharge of contaminated groundwater.
4.
Reduction of Toxicity, Mobility or Volume Through Treatment refers to the
ability of a remedy to meet the preference stated in Section 121(b) of
CERClA, for remedies that involve treatment to reduce permanently the
toxicity, mobility, or volume of hazardous substances and contaminants.
Alternatives 2 through 4-8 would nearly eliminate the toxicity, mobility, and
volume of organic contaminants in the site's groundwater because of contaminant
destruction. The contaminants are removed via carbon adsorption, and are
destroyed during the off-site reactivation of the carbon.
The No Action groundwater alternative does not reduce toxicity, mobility, or
volume except through volatilization and the slow processes of biodegradation.
Short-term Effectiveness addresses the ability of alternatives to manage
risks during t~e construction and implementation phases, and reduce
immediate risks posed by the hazardous materials present.
During the design and construction of the selected alternative, the short-term
risks potentially posed to the community and workers can be effectively
eliminated through proper engineering measures and protective equipment for
workers. Al ternatives 2 through 4-8 present simil ar short-term ri sks to workers
and community. The alternatives 4, 4-A, and 4-8, which include further
5.
16
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excavation, have slightly higher short term risks from dust exposure during the
excavation activities. .
Impacts to the environment vary between alternatives. Alternatives 3, 4, 4-A,
and 4-8 would have construction effects on the flood plain from drill rigs or
heavy machinery necessary to implement these alternatives. Alternatives 3, 4,
4-A, and 4-8 would potentially cause some draining of the flood plain and Mill
Pond Creek. Drainage of the creek would be for a shorter duration under
alternative 4-8. An additional environmental impact, under alternatives 4, 4-A,
and 4-8, is possible.siltation of the creek from excavated soils. This would
need to be mitigated by use of engineering controls during and after
construction.
Remedial action objectives would begin to be met after start-up of the system.
Sampling of monitoring wells on the site will be continued as needed until
groundwater cleanup is complete. This criteria does not apply to the No Action
Alternative.
6.
Implementability is the technical and administrative feasibility of a
remedy, including the availability of goods and services needed to
implement the chosen solution.
Technical feasibility: The individual technologies used in each of the action
alternatives are conventional and well documented. Unusual features are not
anticipated to be required for any of the alternatives but will be resolved
during the design phase, if encountered. There are no differences in the
alternatives' ability to be monitored for effectiveness.
Administrative feasibility: Alternatives 2 through 4-8 are more administratively
feasible than Alternative 1, due to the fact that they address the interim
response act i on objectives at the site. A lternat i ves 2 through 4-B requi re
similar coordination between Agencies and other potentially affected interests.
The No Action alternative would require substantial ongoing review efforts by the
State. .
Availability of services and materials: The technologies used under each of the
action alternatives are conventional and readily available.
7.
Cost includes capital and operation and maintenance costs.
The costs of individual alternatives are detailed above. The No Action
alternative has no direct costs associated with it. The alternatives with an
interception trench are more costly than those without.
8.
Support Agency Acceptance indicates whether, based on its review of the
Feasibility Study and Proposed Plan, the support agency concurs, opposes,
or has no comment on the preferred alternative.
The EPA has chosen not to review the selection of this interim action at this
time. The MDNR anticipates the EPA would concur with the remedial alternative
chosen for this interim response action, due to the fact that the remedy has been
17
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se 1 ected in comp 1 i ance wi th the NCP, is protect i ve to human health and the
environment, and meets the requirements of Act 307 which are more stringent that
the NCP.
9.
Community Acceptance is detailed in the attached Responsiveness summary.
Sped fic comments received from area residents indicate that the Community
supports the preferred interim response action, but would prefer immediate
implementation of a final remedial action for the entire site.
The Selected Remedy
The preferred alternative for the interim response action is Alternative 2, with
minor modifications. The modifications are due to the lack of information about
contami nant d i stri but i on and concentration in the fl ood p 1 a in area. Th is
alternative incorporates additional groundwater and soil sampling of the flood
plain area. The preferred ~lternative includes:
*
The installation of 4-inch diameter groundwater purge wells on the bluff
to the extent necessary to capture the contaminated groundwater plume and
prevent further discharge of the contaminated groundwater to Mill Pond
Creek.
*
Extraction of the contaminated groundwater and treatment in Koch's GAC
treatment system with subsequent discharge to the Whitehall Area POTW.
Sampling of the soil and groundwater in the flood plain area, during or
prior to the installation of the bluff purge wells, to determine the
extent of contamination in this area. Results of this investigation will
be evaluated to determine whether residual contaminants, if present, will
continue to discharge to Mill Pond Creek and pose a threat or potential
threat to human health and the environment. If it is determined that it
is necessary to mitigate the threat or potential threat posed by any such
contamination, additional response actions will be taken. This will
include the installation of purge well points in the flood plain
(Alternative 2-A). .
*
1.
Attainment of Goals
The MDNR has determined that the interim response action selected provides the
best balance among the nine criteria and meets the requirements of CERCLA and
Act 307. .
2.
Compliance Points
Compliance points to .be measured during the course of the interim response
action, to determine the progress towards and attainment of protective cleanup
levels, are: analysis of the treatment system effluent to directly determine the
effectiveness of the treatment and to prevent the release of inadequately treated
chemicals to the Whitehall Area POTW; and, monitoring well sampling and analysis
to determine the effectiveness of the extraction treatment system at halting the
18
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flow of contaminated groundwater. Specifically, the area of attainment to be
monitored for the completion of the interim response action includes the
groundwater, surface water, sediments, and soils in and adjacent to Mill Pond
Creek. Cleanup will be measured against those levels listed in Table 1.
3.
ContinQencies
Some minor changes may be made to the remedy as a result of the design studies.
However, the cleanup goals must be met by the remedy that is implemented.
Statutory Determinations
The selected remedy will control and reduce risks associated with the Chemicals
of Concern in the interim response action area of concern. The statutory
requirements of CERClA Section 121 and Act 307 will be satisfied to the extent
practicable with the implementation of the chosen interim response action. The
following is an enumeration of how the selected remedy addresses each
requirement.
1.
Protection of Human Health and the Environment
The selected interim remedy will provide adequate protection of human health and
the environment through the use of treatment technologies. At completion of this
interim response action, the risk from exposure to contaminated surface water,
sediments and soil will be reduced to levels considered protective by the Act 307
Rules criteria and the,NCP. Risks associated with contact or consumption of site
groundwater will decrease over time because the extraction and treatment system
will reduce the concentration of all groundwater and surface water contaminants
toward the cleanup levels specified in Table 1.
2.
Compliance with ARARs
The remedy selected will meet or attain the Federal and State ARARs and will be
implemented in a manner consistent with these laws. In particular, the interim
response action selected for implementation at the Muskegon Chemical Company site
is consistent with the NCP, Act 307, and with Act 245. The groundwater and soil
cleanup standards chosen for this site are based on Act 307 Rules. Criteria for
complying with the Type A, 8, or C cleanups are contained in Michigan's Act 307
Rules. The substantive provisions, Parts 6 and 7 of the Act 307 Rules, are
considered ARARs for the remedial action to be undertaken at the Muskegon
Chemical Company site. These Rules require that remedial actions shall be
protective of public health, safety, and welfare and the environment and natural
resources (R299.5601(1)). The Act 307 Rules specify that this standard be
achieved by a degree of cleanup which conforms to one or more of the Type A, B,
or C cleanup criteria. A Type A cleanup generally achieves cleanup to background
or non-detectable levels (R299.5707); a Type B meets risk-based cleanup levels
in all media (R299.5709, 5711, 5723, and 5725); and Type C cleanup is based on
a site-specific risk assessment which considers specified criteria (R299".5717 and
5719). The selected remedy utilizes a combination of Type A and B criteria and
meets this ARAR.
19
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3.
Cost Effectiveness
The compari son of cost effect i veness versus protect i veness ach i eved is the
primary factor for the selection of the combination of preferred alternatives for
the Muskegon Chemical Company site. The selected remedy outlined above affords
overall effectiveness when measured against the five CERCLA Section 121 criteria
and the nine criteria from the NCP, and costs are proportionate to the
protectiveness which will be achieved.
Utilization of Permanent Solutions and Alternative Treatment (or resource
recovery) Technologies to the Maximum Extent Practicable
The preferred remedy employs .permanent solutions and treatment technologies to
the maximum extent practicable for this interim response action.
4.
5.
Preference for Treatment as a Principal Element
The principal threat at this site, the contaminant source area, will be addressed
in the final remedy "for the site. As a result, the satisfaction of this
preference, for the site as a whole, will be addressed at that time.
The principal element of the selected interim remedy is the treatment of the
contaminated groundwater. This interim remedy is protective of publ ic health and
the environment. .
20
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GLOSSARY
Administrative Order by Consent - An agreement, provided for by CERCLA or MERA,
between the EPA or the MDNR and a potentially responsible party(s) to
perform removal and/or remedial actions at a site.
Administrative Record (AR) - An official record comprised of all documents
. pertinent to the decision making process of selecting remedial action to
be taken at a site.
Aquifer - A geologic formation, group of formations, or part of a formation
capable of yielding a. significant amount of groundwater to wells or
springs.
ARARs - (Applicable or Relevant and Appropriate Requirements) Legal Requirements
promulgated under Federal, State, or local law that establish cleanup
requirements for Superfund sites.
Biological Degradation - A process where microorganisms modify the chemical
nature of contaminant molecules by breaking large molecules into fragments. The
resulting products generally have lower toxicity than the original contaminant.
Carbon Adsorption - A technique used for the removal of dissolved contaminants
from leach~te' and contaminated groundwater by adsorption onto granular
activated carbon.
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
of 1980, also known as Superfund: Amended in 1986 by the Superfund
Amendments and Reauthorization Act (SARA).
Cleanup Level - The contaminant concentration goal of the remedial action,
i . e., the concentration of a groundwater contami nant to be achi eved
through remedial action.
Cone of Influence - The cone shaped depression of groundwater around a purge well
that is affected by pumping water from the well. Any groundwater in this area
or flowing into this area will be captured by the purge well.
Contaminant Plume - An area of contamination with measurable horizontal and
vertical dimensions that is suspended in and often moves with groundwater.
Extraction - A method to withdraw contaminated groundwater through a well or a
series of wells, which can then be treated prior to discharge.
Feasibility Study (FS) - A study which evaluates different methods to
remediate, cleanup, or otherwise resolve the contamination problems
identified in the Remedial Investigation (RI).
GAC - Granular Activated Carbon, a medium upon which organic contaminants are
adsorbed in a treatment system.
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National Contingency Plan (NCP) - Policies and procedures that the Federal
Government follows in implementing responses to hazardous substances.
National Priorities list (NPl) - A federal roster of uncontrolled hazardous
waste sites that actually or potentially threaten human health or the
environment and are eligible for investigation and remediation under the
Superfund program.
Operation and Maintenance (OlM) - Operation and maintenance costs are
post-construction costs necessary to maintain the future effectiveness of
a remedial action. These costs include maintenance materials and labor
costs, operati ng 1 abor costs, energy, di sposal of residues, insurance,
taxes, costs of periodic site reviews, and licensing.
Proposed Plan - A document that describes the site; summarizes key findings of
the Remedial Investigation and Feasibility Studies; provides a brief
.analysis of remedial alternatives under consideration; identifies the
alternative preferred by EPA and the State; and provides the public with
information on how they can participate in the remedy selection process.
Purge Well- The wells through which extraction takes place.
Remedial Action - An action that is implemented to address a direct threat to
human health or the environment.
Remedial Investigation (RI) - A study which examines the nature and extent of
contamination problems at the site.
Responsiveness Summary - The document in which the Agencies' address all
comments received during the public comment period.
22
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;
RESPONSIVENESS SUMMARY
MUSKEGON CHEMICAL SUPERFUND SITE
WHITEHAll, MUSKEGON COUNTY, MICHIGAN
OCTOBER 30, 1992
Context
Th is Respons i venes s Summary has been prepared to meet the requ i rements of
Sections 113 (k) (2) (B) (iv) and 117 (b) of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), which require the
United States Environmental Protection Agency (EPA) to respond
.. .. to each of the significant comments, criticisms, and new data submitted
in written or oral presentations. . ." on a Proposed Plan for Remedial Action.
As noted, public participation in Superfund projects is required by SARA.
Comments received from the public are considered in the selection of the remedial
action for the site. The Responsiveness Summary serves two purposes: to provide
the EPA with concerns regarding the remedial alternatives, and to show members
of the community how their comments were incorporated into the decision-making
process. .
The Mi chi gan Oepartmen.t of Natural Resources (MONR), as 1 ead agency for the
Muskegon Chemical Company (MCC) site, has prepared this responsiveness summary.
Site Overview
The Muskegon Chemi ca 1 site is located southeast of the ci ty of Whi teha 11,
Muskegon County, Michigan. The site consists of 19.6 acres which includes the
Muskegon Chemical site and the vertical extent of contamination originating from
the facility. Contamination from the facility is known to have miqrated 1/2 mile
southwest to Mill Pond Creek.
The Preferred Alternative for this site consists of placing purge wells along the
bluff adjacent to and up gradient from Mill Pond Creek. Further investigations
and treatment are planned to study the flood plain to determine the nature of the
contamination.
Written and oral comments received from the public were in favor of the Preferred
Alternative, however, .local residents expressed a strong concern for expedient
cleanup of the groundwater.
Backqround On Community Involvement
History
The Koch Chemical facility has been a source of great concern for the residents
of Whitehall since contamination was discovered at the site in the late 1970's.
23
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In June 1979, homeowners in the vicinity of the Muskegon Chemical facility began
a letter writing campaign concerning a plant explosion which occurred in March
of that year. Fearing that the explosion had threatened publ ic health, the
residents contacted the Michigan Department of Natural Resources (MDNR). . The Air
Quality Division of the MDNR received numerous complaints concerning noxious air
emissions allegedly originating from the Muskegon Chemical Company facility. In
the early 1980's, residents initiated a meeting with Muskegon Chemical
representatives in order to discuss the chemicals and processes used at the
facility. In addition to meeting with the company representatives, residents
took their concerns to the Whitehall City Council.
The City of Whitehall became formally involved with the contamination at the site
in February 1980. The City Council passed a resolution requiring the company to
address the groundwater contamination at the site.
The MCC site was added to the National Priorities List on February 21, 1990. As
the lead agency for the site, the MDNR published the Community Relations Plan
(CRP) for the site, which identified concerns expressed by the residents and
local officials of Whitehall.
Concerns
The Community Relations Plan (CRP) for the Muskegon Chemical Superfund Site was
completed in February 1991. At that time, the following concerns were
identified.
*
The potential effects of groundwater contamination on public health.
The effect the contamination would have on property, the local
wildlife and area recreation.
*
*
The inadequacy of the existing purge well system to capture the
groundwater plume.
*
The poor flow of information from the MDNR to the public in the past.
The lack of knowledge about the Superfund program.
*
*
Whom will be responsible for the cost of the site cleanup.
Effects And Outcomes Of Concerns
Some of.. the key concerns ment i oned above were addressed duri ng the site
investigation are described below.
1.
Residential wells and area surface water sediments were sampled during
the Remedial Investigation (RI). The results from these residential
sampling rounds were transmitted to the public through progress
reports, personal correspondence~ and the Engineering Evaluation and
Cost Analysis (EEjCA) report. Surface water and sediment sampl ing
results were reported in the RI.
24
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2.
3.
4.
5.
6.
Effects on wildlife issues will be addressed' in the Risk Assessment
report, however, studies were not conducted concerning property values
or recreation as this was out of the scope of the Superfund program.
Groundwater sampl ing conducted during the RI demonstrated that the
existing purge well system was not properly capturing the contaminant
plume. This problem will be addressed by the interim response action.
To improve the information flow from the MONR to the community,
progress reports are published on a regular basis. A Citizen
Information Committee (CIC) was also formed to help keep the members of
the community informed about activities at the site. Frequent
telephone contacts are made to insure that information is flowing in
all directions. All of these activities are on-going.
In order to inform the public about the Superfund program, fact sheets
are sent out describing the purpose of the program. Also the Superfund
program and its various aspects have been reviewed and discussed with
the public during public meetings and CIC meetings.
The responsibility for conducting and funding the cleanup was
estab 1 i shed in a Consent Order between the MONR and Koch Chemi ca 1 .
Under this Order, Koch Chemical is responsible for the RI and the
Feasibility Study (FS), as well as the interim response action.
Summary Of Public Comments And Responses
Questions and comments were received during a Public Meeting held at Whitehall
City Hall on April 30, 1992, from 7:00 p.m. to 9:00 p.m. Written comments were
also received during the public comment period which ran from April 14, 1992 to
May 14, 1992. Following is the response to public comments regarding the interim
response action Proposed Plan for the Muskegon Chemf~al Site.
Comments Received at the Public Meetinq
The following questions and comments were received at the public meeting. The
MONR, EPA, and Muskegon Chemical representatives addressed the following
questions during the proceedings. The following answers are presented for
further clarification. Comments have been arranged into 3 categories.
1.
General Questions and Comments
Why does it...take so 'ong to perform a cleanup action after a study has been
conducted?
There are many time requirements, such as the 30-day public comment period,
required as part of the Superfund process. In addition, it takes time to design
the cleanup plan, review the plan, and procure contractors to perform the work.
25
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What ti8e constraints exist that prolong the study of the site and its plume?
The RI report is currently under review by the MDNR, and the draft Risk
Assessment is due to the MDNR by the end of February. Following the issuance of
the final RI and risk assessment, is issuance of the FS report and a Record of
Decision (ROD) for the site as a whole. This process generally takes 18 months
to two years.
How long does it take to study the groundwater flow?
At this site the remedial investigation began in July 1991, and the results from
the final round of groundwater sampling were available in March 1992. All of
this information will be used to evaluate and select the final remedy at the
site.
Is there a set number of personnel that will aid in a faster cleanup?
There is not a set number of personnel that will aid in a faster cleanup. The
cleanup is currently progressing at a very fast rate considering the complexities
at the site. Data collection, analysis, and evaluation is a very time consuming
process, that can not be avoided. High quality data is necessary for adequate
remedy selection. Additional personnel are assigned to the project as needed.
How many full time personnel work on this site (cleanup)? .
The number of full time personnel working on this cleanup depends on the stage
of the cleanup process. During the field investigation, the state had 4 to 5
full time people on staff and/or under contract, and Koch/CH2M HILL had 10 to 15
full time people. Currently, there is probably 1-2 one full time people for the
state. and at least 1-2 full time persons for Koch/CH2MHILL working on the
project.
Is a fish consumption advisory in effect on Hill Pond Creek?
The original fish consumption advisory was initiated by the city because the
State did not have adequate information about the contaminants to make a
determination on the need for a fish advisory. At that time a division of the
1 oca 1 government deci ded to post the creek due to the uncerta i nty about the
contami nants. It was 1 ater determi ned that there were not 1 eve 1 s of the
contaminants which would require a fish advisory in Mill Pond Creek.
2. Concerns About The Koch Chemical Facility
When will the Koch Chemical Facility be fully decommissioned?
The production at the processing plant ended in Oecember 1991. All chemicals and
the equipment used in processing were removed from the site, and the plant
decommissioning was completed by the end of 1992. At that time all equipment,
except those needed to treat the purged groundwater, was removed from the site.
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What is being done with the processed chemicals and equipment currently at the
facility? .
The processed chemicals at the plant will be distributed in three ways. First,
the processed chemicals and finished product will be sold to Koch's previous
customers. Second, some of the unused raw materials are being sold back to the
various vendors. Third, all other chemicals will be neutralized and disposed of
according to solid waste or hazardous waste requirements.
Plant equipment will be cleaned, dismantled, and sold. Some of this equipment
will be sent to Koch's sister plant in Kansas for reuse.
Are there plans to remove the buildings (on site) to get at the source of the
contamination?
The MDNR is not aware of any plans to remove the buildings on site at this time.
There are technologies available, such as soil flushing, where it may not be
necessary to remove the buildings to get at the contamination.
The overall remedial action plan for this site requires Koch to look at options
which include removing the buildings in order to get at the. source of the
contamination. .
Why is the company not considering removing the buildings on site?
It is Koch's intention to hold the property until the site is certified clean by
the MDNR and the EPA. When the certification is received from both agencies,
Koch will then offer the property for sale. If the buildings can be left on site,
Koch would b~ adding additional value to their land.
Will the Koch Chemical property be leased or rented for use?
As mentioned above, Koch pla~s to hold on to the property until the property is
certified clean by the MDNR and EPA. Once this certification has been received,
then the property will be ready for sale. .
Does Muskegon Chemical have any liability contracts with the previous owners of
the property? .
It is not known at th is time whether or not Koch Chemi ca 1 has a 1 i abi 1 ity
contract with its previous owners. The company has agreed to conduct the interim
response action. If the company also agrees to conduct the final remedial action
at the site, the option of further action against the previous owners will be up
to the Koch 'Chemical Company.
3. Technical Concerns
What is the rate at which Koch is pumping it's existing purge wells? What will
be the pumping rate~after the new purge wells are in place?
Koch has a permit with the Whitehall Area Publicly Owned Treatment Works (POTW)
to discharge 150,000 gallons per day. Koch is pumping the existing purge system
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at 150,000 gallons a day. The company has no intentions to exceed this permit
limit, and will take the necessary steps to prevent this. Calculations in the
EE/CA estimate that discharge of contaminated groundwater to Mill Pond Creek can
be stopped without exceeding the 150,000 gallon per day discharge limit. This
will however, require re-distribution of the pumping rates of water from the
various purge wel'ls in order to capture the contaminat~d groundwater, prevent
discharge to the creek, and avoid exceeding the 150,000 gallons per day limit.
When the new purge wells are pl~ced on the bluff, will these wells increase the
purge capacity?
When the new purge wells are placed in the bluff region of the plume, these wells
will be pumped at a greater rate than the purge wells already present. The
pumping rate of the older wells will be reduced once the bluff wells are in
operation. The pumping rate of the bluff wells, combined with the pumping rate
of the older purge wells will result in a 150,000 gallon a day total pumping
rate.
Win the interim response action being conducted at the creek be visible from the
White Lake Drive?
Currently it is possible to see the site from White Lake Drive. One road already
exists into the site area. The plan is to have a service road in order to get
to the various well 'points in the bluff area. There are also wells on the north
side of White Lake Drive. These already exist and are visible from the road. The
service road south of White Lake Drive and the monitor wells north of White Lake
Drive are all that will be visible to the casual passer-by.
When will the interim.response action purge wells be put into place? When will
additional purge wells be put into place?
It is anticipated that the interim response action purge wells will be put into
place sometime during the late winter or early spring of 1993. These wells will
stop the discharge of contaminated groundwater to Mill Pond Creek. Additional
purge wells may be necessary as part of the overall remedial action at the site.
These wells would be installed after the completion of the RI/FS.
What will be done if, after the purge wells are put into place, it is detenmined
that contamination is still entering Hill Pond Creek?
If it is determined that after the bluff purge wells are in place that
contaminants are still entering the creek, then the purge flow will have to be
redistributed to capture the contamination. It is estimated that the bluff purge
wells will require a pumping rate of 26 gallons a minute. This option also
allows the company to pump water in the various "hot spots" in the plume area.
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Why can't Koch supply as many carbon filtered wells as necessary to clean up the
contamination so it can go right back into Hill Pond Creek clean, so we don't
have to worry about it effecting the wetlands. Why do we have to think in tenms
of public treatment systems in which the public will have to pay for? Why can't
we expect Koch to clean up the water themselves?
It is the intent of the interim response action to place into operation a system
that will prevent contaminant discharge to Mill Pond Creek in the very near
future rather than a few years down the road. As part of the eva 1 uat i on process,
Koch/CH2M HILL evaluated various treatment options. Due to the fact that this
option can be implemented now with the approved discharge to the POTW, this
option allowed for a faster response than construction of a new treatment system
with discharge to the creek: Final remedial action evaluation will include
consideration of treatment on-site with discharge to Mill Pond Creek. As part
of the agreement with the Whitehall Area POTW, Koch pays for the treatment of
their pretreated waste water. Therefore, the treatment costs will not be paid
for by the public.
Is the discharge mentioned in the interim response action considered a part of
the existing discharge already going to the wastewater treatment system?
The discharge to the wastewater treatment plant is a part of the existing
authorized discharge. . Koch is authorized under its contract with the city and
county to discharge up to 150,000 gallons a day of processed water and treated
groundwater. Since' the plant shut down, the company has been able to discharge
more groundwater as it no longer has processed water to discharge. The discharge
mentioned in the interim response action will not ex.ceee the established
dischar~e limit. - .
What level of contaminant concentration can be released to the wastewater
treatment plant?
The contract agreed upon by the Whitehall Area POTW and the company calls for a
level of half a part per million (0.5 ppm).
How are contaminants treated at the wastewater treatment plant?
The chemicals, at the concentrations that they are found in the groundwater, are
bi odegradabl e and are affected by the treatment processes at the wastewater
treatment plant. The information developed by the county waste treatment system
indicates that the chemicals are treated to a nondetectable level. Although the
wastewater treatment plant can treat down to a nondetectable level, federal and
state law requires that industries pretreat their wastewater prior to delivery
to the wastewater treatment pl ant. As mentioned above, Koch pretreats the purged
groundwater down to 0.5 ppm.
Is there a treatability problem with the chemical Chlorex?
In the past there was a treatability problem when Muskegon Chemical began sending
its processed waters to the treatment plant. This problem was due to high
concentrations of Chlorex in the waste water. In response, the Whitehall Area
POTW requi red that Muskegon Chemi ca 1 treat thei r waste water down to a 1 eve 1 that
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could be handled by the treatment plant. As a result, the company is now
required to treat down to 0.5 ppm before sending its wastewater to the treatment
facility. A supervisor at the treatment facility indicated that since Koch
started treating its wastewater down to 0.5 ppm, there has not been a
treatability problem at the facility.
If the wastewater treatment plant will not accept the water from the purge well
system, what other options are there for disposal of the purge water?
"
If it is determi ned that the wastewater treatment plant cannot accept the
pretreated water from the purge system, then treated wastewater would have to be
discharged to the groundwater or surface water. If this is the case, a
groundwater or surface water. di scharge permit wi 11 be needed and appropri ate
treatment performed.
The chemicals which are in the groundwater, do these bioaccumulate in fish and
wi ldl ife?
The chemicals which have been released to the groundwater do not bioaccumulate
in fish or wildlife species.
How much water enters Hill Pond Creek in the plume area?
It is currently estimated that the groundwater flow from the plume area into Mill
Pond Creek is 150 gallons per minute.
Are there plans to drain the flood plain in onder to purge the contamination?
The plan of action to be taken at the flood plain is dependant on the outcome of
the investigation of the flood plain. If it is determined that the flood plain
is contaminated, then the plan of action with the least impact on the area will
be the use of well points for groundwater extraction. The well points may drain
the f1 ood p 1 ai n. The extent of the dewateri ng, if any, by the we 11 poi nts is not
known at this time, but is expected to be minimal due to the small area of
influence by the well points.
Why are all alternatives considered for cleanup based on Koch's discharge limits
to the local wastewater treatment plant?
Koch determined that they could capture the contamination entering into the creek
within the previously established discharge limit. As a result, Koch could
continue using the exi~ting activated carbon treatment system with discharge to
the wastewater treatment plant. It was determined that this would allow them to
carry out the interim response action in an expeditious fashion.
What impact has the site had on the Whitehall municipal aquifer located to the
northeast of the Koch facility?
During the RI, monitor wells and soil borings were placed northeast and northwest
of the site, to delineate the limits of the plume. Contamination was detected
in only one well on the northern boundary. The Contaminant was
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1,2 Dichloroethane at 1.7 parts per billion. A monitoring well was installed at
the depth that contamination was encountered and no further contamination has
since been detected at that location. No contamination was detected at any of
the other background locations. Based on the information that is available at
this time, the site does not pose a threat to the new Whitehall Municipal well
located approximately 1.5 miles to the northeast.
What intentions are there to check the municipal aquifer for contamination?
The study conducted under the Rl indicates that the groundwater contamination
plume travels southwest towards Mill Pond Creek. There are no indications of any
groundwater movement towards the city of Whitehall municipal well. We do not
anticipate further investigation of the aquifer to the north under this consent
agreement. .
Has there been a formal presentation to the Muskegon County Board of Works
concerning the discharge to the wastewater treatment plant?
Prior to Koch Chemical's acquisition of the site, there was a presentation to the
Board when the contract between the Muskegon Chemical Company and the Whitehall
Area POTW first originated. The changes proposed in the interim response action
will not change the quantity or quality of the water entering the wastewater
treatment plant, which is allowed under terms of the existing contract. The
company is willing to make another presentation to the Board, if needed, in order
to clarify any misunderstandings.
Comments Received In Writing
Only two questions were received in writing from the public during the public
comment period. As mentioned before, the citizens have encouraged the MDNR and
Koch Chemical to move toward a swift implementation of the interim response
action.
What is the efficiency of the purge well system to capture the contaminants as
the plume progresses?
The efficiency of the existing purge well system is unknown. Based on sampling
observations, we are aware that the existing system is not compl,etely capturing
the contaminant plume.
Is the HDNR or Koch Chemical aware of a problem with treating the chemical
Chlorex?
The Whitehall Area Wastewater Treatment Plant operator has indicated that the
plant does not have a problem with Chlorex at the current discharge limit of 0.5
ppm.
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