PB97-964115
EPA/541/R-97/117
January 1998
EPA Superfund
Record of Decision:
Bendix Corp/Allied Automotive
St. Joseph, MI
9/30/1997
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RECORD OF DECISION
REMEDIAL ACTION
BENDIX SUPERFUND SITE
ST. JOSEPH, MICHIGAN
September, 1997
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TABLE OF CONTENTS
CONTENT PAGE NO.
DECLARATION
DECISION SUMMARY 3
I SITE NAME, LOCATION, AND DESCRIPTION 3
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
IV SCOPE AND ROLE OF THE RESPONSE ACTION 4
V SUMMARY OF SITE CHARACTERISTICS 5
A. Land Use 5
B. Surface Water 5
C. Geology 5
D. Hydrogeology 6
VI MAJOR FINDINGS OF THE REMEDIAL INVESTIGATION
AND RISK ASSESSMENT 6
A. Source Areas 6
B. Fate and Transport of Site-Related Contaminants 8
VII SUMMARY OF SITE RISK 8
A. Objectives 8
B. Human Health 9
C. Ecological Risk Assessment 13
VIII DESCRIPTION OF ALTERNATIVES 15
A. Alternative 1 16
B. Alternative 2 16
C. Alternative 3 19
D. Alternative 4 20
IX SUMMARY OF THE COMPARATIVE ANALYSIS OF
ALTERNATIVES 20
A. Threshold Criteria 20
B. Primary Balancing Criteria 21
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C. Modifying Criteria 21
X THE SELECTED REMEDY 23
A. Cleanup Levels 24
B. Description of Remedial Components 24
C. Long-Term Monitoring Plan 27
XI STATUTORY DETERMINATIONS 27
A. The Selected Remedy is Protective of Human
Health and the Environment 27
B. The Selected Remedy Attains ARARs 27
C. The Selected Remedy is Cost-Effective 29
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies
to the Maximum Extent Practicable 29
E. The Selected Remedy Satisfies the Preference for
Treatment that Permanently and Significantly Reduces
the Toxicity, Mobility, or Volume of the Hazardous
Substances as a Principal Element 30
XII DOCUMENTATION OF SIGNIFICANT CHANGES 30
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TABLE OF CONTENTS
(continued)
TABLES
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Eastern & Western Ground Water Plumes - Compounds of
Potential Concern
Summary of Exposure Scenarios
Summary of Site Risk
Hickory Creek Surface Water and Sediment Exposure
Lake Michigan Surface Water Exposure Point Concentrations
Components of the Remedial Alternatives
Cleanup Levels for Ground Water-Western Plume
Cleanup Levels for Ground Water - Eastern Plume
ARARs Criteria and Guidance for the Selected Remedy
FIGURES
Figure 1 Site Location Map
Figure 2 Conceptual Model Eastern & Western Plumes
Figure 3 Conceptual Model-Interpretive Geologic Profile B-B' Western Plume
Figure 4 Conceptual Model-Interpretive Geologic Profile C-C' Eastern Plume
Figure 5 Example of Natural Attenuation
APPENDICES
Appendix A MDEQ Letter of Concurrence
Appendix B Administrative Record Index and Locations
Appendix C Responsiveness Summary
LIST OF ACRONYMS
REFERENCES
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DECLARATION
SELECTED REMEDIAL ACTION
FOR THE
BENDIX SUPERFUND SITE
ST. JOSEPH, MICHIGAN
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Bendix Super-fund Site (Bendix
Site) in St. Joseph, Michigan and describes the legal and technical basis for the selection. The remedial
action was chosen in accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980, as amended by the Superfiind Amendments and Reauthorization Act
(SARA) of 1986, and is in compliance with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) to the extent practicable. This decision is supported by documentation
contained in the Administrative Record for the Bendix Site.
The State of Michigan Department of Environmental Quality (MDEQ) concurs with the selected
remedy.
ASSESSMENT OF THE BENDIX SITE
Actual or threatened releases of hazardous substances from this Bendix Site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), present a potential future
threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This final remedial action addresses contamination associated with two ground water plumes at the
Bendix Site (Western Plume and Eastern Plume). The statutory and regulatory requirements for the
remedial action at the Bendix Site are to: •
• Reduce/eliminate the potential risks to human health associated with exposure to
chlorinated volatile organic compounds (VOCs) in the Western and Eastern
Plumes;
• Reduce the concentrations of VOCs in the Western and Eastern Plumes to drinking
water standards;
• Reduce/control the VOC source of contaminants; and
• Satisfy Applicable or Relevant and Appropriate Requirements (ARARs).
The selected remedial alternative for the Bendix Site is Alternative 3: Ground Water Institutional
Controls and Deed Restrictions, Soil Vapor Extraction (Eastern Plume Inferred Source Removal), and
Monitored Natural Attenuation (Eastern and Western Plumes). The selected remedy focuses on
confirming and monitoring the natural degradation of contaminants that is occurring in the Western and
Eastern Plumes. If GSI criteria exceedences are predicted or detected through monitoring, contingency
plans will be implemented to insure compliance with the GSI criteria. In addition, a soil vapor extraction
(SVE) system in the vicinity of the Eastern Plume source area would be used to control/reduce VOCs
in the vadose zone soils. The major components of this remedy include:
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• Environmental monitoring to evaluate the effectiveness of natural attenuation
processes in the Plumes
• Deed restrictions to prohibit future ground water use
• Land use restrictions to restrict access to Bendix Site-related VOCs in vadose zone
soils
• Natural attenuation of ground water Plumes to continue destruction of ground
water contaminants
• Five-year site reviews
In addition the following three components will be implemented to address the Eastern Plume source
area:
• Maintenance of existing cover system to minimize infiltration of precipitation to VOCs
in vadose zone soils and restrict access to/direct contact with those soils
• Operation of SVE system to control/reduce contaminants in the vadose zone
• Installation of SVE vapor phase treatment system to remove VOCs from the treatment
off-gases
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal and state
requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost
effective. This remedy utilizes permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable and satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining on site, a review will be conducted within
five years after start-up of the remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment. This review will be conducted at least every five years as
long as hazardous substances are present above health-based clean-up levels.
STATE CONCURRENCE
Upon receipt, the State of Michigan concurrance letter will be included in the Administrative Record and
Appendix A of this ROD.
William E. Muno / Date
Superfund Division Director
U. S. EPA Region V
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DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION
The Bendix Superfund Site is a National Priorities List (NPL) site located in Lincoln Township, Berrien
County, Michigan, approximately four miles south of the City of St. Joseph (Figure 1). The Bendix Site is
located at 3737 Red Arrow Highway, approximately one-half mile from the eastern shore of Lake Michigan,
and approximately one-third mile west of Hickory Creek, and bordered to the west by Red Arrow Highway.
The Bendix Site's topography is generally flat and the land surface is mostly covered by manufacturing
buildings and pavement. The land surface rises slightly to the west of the Bendix Plant to the lake bluff. The
land surface to the east gently slopes toward Hickory Creek falling steeply away at the creek. Land surface
between Hickory Creek and Lake Michigan is generally open and covered with grass, allowing rainwater to
recharge ground water. Ground water flows beneath the Bendix Site from the south. A natural divide causes
ground water to flow from the Bendix Site toward Hickory Creek (to the east) and toward Lake Michigan
(to the west). Hickory Creek and Lake Michigan are used for recreational purposes. Ground water
associated with the Bendix Site is not used. The entire area adjacent to the Bendix Site is supplied with
drinking water from the City of St Joseph municipal water supply. The source of the drinking water is Lake
Michigan.
Currently, land use in the vicinity of the Bendix Site is a mixture of commercial, residential, and industrial.
The area between Red Arrow Highway and Lake Michigan is mostly residential. Commercial and industrial
facilities are located between the Bendix Site and Hickory Creek. Areas north and south of the Bendix Site
are a mixture of commercial and residential properties.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Bendix Site was originally farmland but was developed in 1939 by the Nylen Products Corporation. The
36-acre facility consisted of an iron casting foundry and a machine shop. The Bendix Corporation (Bendix)
purchased the property in 1952 that was later acquired by Allied Chemical in 1983. It's successor,
AlliedSignal Inc. sold the facility to Bosch Braking Systems Corporation (Bosch, current owner) in 1996.
The facility currently contains a foundry and a manufacturing plant (Figure 2).
Oil-based cutting fluids were used at the facility during the 1950s and 1960s. Water-soluble cutting fluids
were used beginning in 1967. Chlorinated solvents were reportedly used in the 1960s and 1970s. From 1965
to 1975, foundry dust collector and machine shop oily waste waters were disposed into three former unlined
lagoons: (1) foundry "A" lagoon, (2) south lagoon, and (3) the loading dock lagoon. The foundry "A" lagoon
and the loading dock lagoon were closed and their contents disposed into the south lagoon. The south lagoon
was closed in 1978 with the installation of a Michigan Department of Natural Resources (MDNR)-approved
clay cap. Bendix used an on-site liquid incinerator, lagoons, and off-site commercial disposal facilities until
the mid 1970s. A landfill (Maiden Lane Landfill) was also used from 1966 to 1979 for the disposal of
foundry residues, asbestos in brake shoes, and encapsulated asbestos pellets. Environmental investigations
began at the Bendix Site in 1975 when three ground water wells were installed around the south lagoon.
Since that time numerous investigations have been conducted to evaluate the nature and distribution of
industrial chemicals in soil, ground water, surface water, and sediments associated with the Bendix Site and
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neighboring properties. Industrial chemicals identified in the environment include both organic and inorganic
compounds associated with the manufacture of braking systems.
In June 1988, the Bendix Site was proposed for inclusion on the NPL. AlliedSignal, Inc., owners of the
Bendix Site at that time, were informed that it was potentially responsible for contamination at the Bendix
Site. On February 13, 1989, AlliedSignal entered into a Consent Agreement with U.S. EPA to conduct a
Remedial Investigation and Feasibility Study (RI/FS). The Bendix Site was officially listed on the NPL on
February 15, 1990.
As a result of industrial activities at the Bendix Site and the natural ground water divide, two VOC Plumes
have been identified (Eastern and Western Plumes). The major site-related contaminants are
trichloroethylene (TCE) and its degradation products. The Eastern Plume source is in the vicinity of the
loading dock, creating a Plume that extends northeast to its primary discharge point along Hickory Creek.
The Western Plume originates in the area of the north parking lot and extends to the northwest where it
discharges to Lake Michigan (see Figure 2). The closed south lagoon is located over the ground water divide
and continues to release low levels of industrial cutting oil residuals to the ground water.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
A complete chronology of community relations activities for the Bendix Superfund Site is provided in the
Responsiveness Summary (Appendix C). Recent activities include issuance of the RI/FS report and the
Proposed Plan for the Bendix Site. These documents were introduced into the Administrative Record on
August 12, 1997. Bendix Site documents are available to the public as part of the Administrative Record
which is housed at three information repository locations: (1) U.S. EPA Docket Room for Region V in
Chicago, Dlinois; (2) Maud Preston Palenske Memorial Library in St. Joseph, Michigan; and (3) Lincoln
Township Public Library in Stevensville, Michigan. The Administrative Record index and addresses of the
Information Repositories are presented in Appendix B.
A Public Comment period was held from August 14,1997 to September 12, 1997. US. EPA and Bosch ran
a concurrent news release on August 13, 1997, in the St. Joseph Herald Palladium to announce the comment
period and the Public Meeting. A Public Meeting was held August 20, 1997 at the Lincoln Township Hall
in Stevensville, Michigan. The meeting included a summary of site history and a presentation of the
proposed remedy. The response to the comments received during the public comment period is included in
the Responsiveness Summary (Appendix C).
IV. SCOPE AND ROLE OF THE RESPONSE ACTION
The selected remedy for the Bendix Site provides a comprehensive approach for site remediation. The
remedy includes natural attenuation of the Eastern and Western Plumes by natural degradation of VOCs in
Bendix Site ground water. If GSI criteria exceedences are predicted or detected through monitoring,
contingency plans will be implemented to insure compliance with the GSI criteria. Additionally, an SVE
treatment system in the vicinity of the Eastern Plume source area will be utilized to remove VOCs from
vadose zone soils. These VOCs are a source of ground water contamination in the Eastern Plume.
Contaminants will be captured through vapor extraction wells. Emissions from the SVE capture system will
be treated using photocatalytic oxidation to destroy VOCs in the off-gases prior to discharge.
These remedial actions will prevent the potential for future human health risks associated with exposure to
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VOCs in the ground water Plumes and the air through volatile emissions by (1) reducing VOC concentrations
in the Eastern Plume source area (2) reducing volatile emissions in the vadose zone over the Eastern Plume,
and (3) reducing concentrations of VOCs in ground water associated with the Eastern and Western Plumes.
In the event that monitoring shows confirmed, statistically significantly exceedences of ground water
contamination above the established values at the point of compliance (POC), a contingency plan will be
implemented to prevent further release of contaminants into surface water bodies.
V. SUMMARY OF SITE CHARACTERISTICS
A. LAND USE
Land use in the area of the Bendix Site is a mixture of agricultural, industrial, residential, and recreational.
The source of drinking water in the area is primarily Lake Michigan surface water via the St. Joseph
municipal water supply system. The entire area in the vicinity of the Bendix Site has access to this public
water supply. Water supply surveys have been conducted by MDEQ and Bendix/Bosch over the past several
years. The results indicate that contaminated ground water is not being used as a primary drinking water
source. Select residential drinking water wells located primarily to the east of Hickory Creek will continue
to be monitored periodically for site contaminants.
B. SURFACE WATER
Two surface water bodies dominate the surface water drainage in the vicinity of the Bendix Site; Lake
Michigan to the west and Hickory Creek to the east (see Figure 2). The Bendix Site is situated on a
topographic divide approximately one-half mile east of Lake Michigan and one-third of a mile west of
Hickory Creek. Bosch is currently discharging non-contact cooling water and storm water runoff to Hickory
Creek. This is a permitted discharge in compliance with the provisions of the Federal Water Pollution
Control Act. The storm water collection system for the plant is fully described in the Bosch MDNR National
Pollutant Discharge Elimination System permit No. MI003174.
C GEOLOGY
The current land surface features are dominated by the deposition and subsequent erosion of Wisconsin
continental ice sheets. These deposits are genencally referred to as glacial drift, which was deposited as the
ice sheet advanced (tills and moraine deposits), or as the ice melted and reworked unconsolidated deposits.
The majority of the area around the Bendix Site was submerged below glacial Lake Chicago and consists of
lacustrine deposits, which are characterized as deep water deposits made up of fine sand, silts and clay. The
final stages of deglaciation resulted in unvegetated planes of exposed sand. This sand was reworked by
surface drainages, creating the incised drainage currently occupied by Hickory Creek. Dune sand deposits
along the present-day shoreline of Lake Michigan are windblown sand forming the lake shore bluff.
The uppermost soil unit at the Bendix Site is a fine to medium sand. This sand extends from the surface to
approximately 40 to 50 feet below ground surface. This medium to fine sand unit allows rain water to
infiltrate the subsurface and recharge the ground water. This unit also has the greatest hydraulic conductivity
(K), which has been measured in the lQ-3to 10" cm/sec range (Keck, 1986 and W&C, 1995). Therefore, this
unit is of particular interest with regard to contaminant transport. These fine to medium sands grade to fine
silty sands with depth.
At an elevation of between 580 and 560 feet above Mean Sea Level (MSL), the soil type changes to
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interlayered clayey silts and silty sands with occasional gravel. This unit is discontinuous and is most
prevalent below the eastern side of the Bendix Site. When present, this fine-grained unit ranges in thickness
from a few feet to approximately 20 feet. The K values of the silt/clay layers are generally 1O'5 cm/sec with
occasional 10"6 cm/sec values in the clay units (W&C, 1995). The interlayered silty sands have K values
ranging from 10"4 to 10s cm/sec. Ground water movement through this interlayered unit will occur
principally within the more conductive thin silty sand layers.
Below the interlayered clayey silt sand is a stiff clay to silty clay. This clay unit is most prevalent at the
center of the Bendix Site near the plant. The K value of this unit was measured at 10* cm/sec (W&C, 1995).
This unit has a significantly lower permeability than the sands located stratigraphically above, and will act
as a hydraulic barrier to the vertical migration of ground water and/or contaminants.
D. HYDROGEOLOGY
Regional ground water flow is toward Lake Michigan with a current lake elevation of 580 feet above MSL.
The maximum ground water elevation in the vicinity of the plant is approximately 600 feet above MSL.
Superimposed on this regional flow are the localized effects of Hickory Creek. Hickory Creek has incised
the sandy surface soils to a current creek elevation of 586 feet above MSL. This elevation difference between
the ground water and the creek causes the localized ground water to flow toward Hickory Creek. This has
created a ground water divide in the vicinity of the Bendix/Bosch plant (see Figure 2). Ground water on the
east side of this divide flows toward and discharges to Hickory Creek, while ground water on the west side
of this divide flows toward and discharges to Lake Michigan.
Directly beneath the Bendix Site, there are three distinct hydrogeologic units, the unconfined water table
aquifer; a series of aquicludes (semi-confining layers) consisting of interbedded silts and sands; and the lower
clay unit acting as an aquatard (confining layer).
VI. MAJOR FINDINGS - REMEDIAL INVESTIGATION AND RISK ASSESSMENT
In July of 1997, the Rl report for the Bendix Site was issued. The nature and distribution of contaminants
at the Bendix Site have been investigated since the early 1980s. Industrial chemicals identified in the
environment include both organic compounds and inorganic elements associated with the manufacture of
braking systems. The most frequently detected contaminants at the Bendix Site are TCE and 1,1,1-
trichloroethane (1,1,1-TCA), along with their degradation products, vinyl chloride, cis-l,2-dichloroethene
(cis-1,2-DCE) and trans-1,2-dichloroethene (trans-1,2-DCE), and 1,1 -dichloroethane (1,1 -DCA).
The Bendix Site is located on a ground water divide approximately halfway between Lake Michigan to the
west and Hickory Creek to the east. As a result of industrial activities occurring at the Bendix Site and the
natural ground water divide, two VOC ground water Plumes have been identified as the Western and Eastern
Plumes (see Figure 2).
A. SOURCE AREAS
The Western Plume originates in the area of the north parking lot and extends to the northwest where it
discharges to Lake Michigan. The Eastern Plume originates in the area of the current loading dock creating
a Plume that extends northeast to its discharge point along Hickory Creek. During the RI several potential
source areas were evaluated, and the following three were identified as significant continuing sources of
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contaminants to ground water:
• the former south lagoon;
• the inferred deep VOC source below the north parking lot; and
• the inferred shallow VOC source in the vicinity of the loading dock.
1. Former South Lagoon
The former south lagoon is located at the south end of the Bendix Site upgradient of the plant. This location
is situated across the ground water divide (see Figure 2). As a result, ground water flowing below the former
south lagoon diverges, moving both east toward Hickory Creek and west toward Lake Michigan. The lagoon
was operated as an evaporation/infiltration lagoon from 1965 to 1975. The lagoon received waste water from
the foundry and manufacturing plant. This material contained both petroleum- and vegetable-based cutting
oils, and possibly some chlorinated hydrocarbons. The non-chlorinated compounds appear to be the primary
food source (substrate) for microbial activity occurring in the ground water below and down gradient of the
closed south lagoon. As a result of this microbial activity, the ground water below and down gradient of the
lagoon has become anoxic (depleted of oxygen). This is a critical step in the anaerobic dechlorination of
chlorinated VOCs that is occurring within both the Western and Eastern Plumes.
2. Western Plume
The inferred source of the Western Plume is a deep TCE dense non-aqueous phase liquid (DNAPL) that is
located beneath the north parking lot approximately 70 to 80 feet below ground surface. VOCs detected
above the federal Maximum Contaminant Levels (MCLs) in the Western Plume include vinyl chloride, 1-1-
dichloroethene (1,1-DCE), 1,2-dichloroethene (1,2-DCE) (total of cis- and trans-), and TCE. Once the
source material has dissolved into the ground water, it travels predominantly by advection. The ground water
in this area is flowing toward and discharging to Lake Michigan (see Figure 2). VOCs were not detected
in the surface water of Lake Michigan, however they do exceed estimated mixing zone based criteria.
3. Eastern Plume
The Eastern Plume is primarily a chlorinated solvent Plume that emanates from the area of the loading dock
and to a lesser extent the former south lagoon. VOCs detected above the MCLs in the Eastern Plume include
vinyl chloride, 1,1-DCE, cis-1,2-DCE, trans-1,2-DCE, and TCE. The Plume extends from the loading dock
area to the northeast; in the vicinity of Maiden Lane, the Plume is drawn to the east by the low head
conditions created along Hickory Creek (see Figure 2). Based on the results of the RI, the source of the
Eastern Plume is located at approximately 30 feet below ground surface in the vicinity of the water table
(Figure 4). This source material is inferred and has not been directly observed or sampled. The nature of
the source material and its location has been inferred based on ground water samples collected directly below
the loading dock. High concentrations of VOCs (cis- 1,2-DCE at 440,000 ^g/L) in the shallow ground water
with correspondingly low concentrations of VOCs from deeper ground water samples indicate the presence
of a non aqueous phase liquid (NAPL) at or near the capillary fringe directly below the loading dock, but not
deeper within the aquifer.
The Eastern Plume consists primarily of TCE and its degradation products (e.g., cis-1,2-DCE and vinyl
chloride). The Plume extends from the source areas (former south lagoon and loading dock area) to Hickory
Creek. Eastern Plume ground water appears to be discharging to Hickory Creek. Concentrations of Plume-
related contaminants detected in the shallow ground water monitoring wells closest to Hickory Creek exceed
the MDEQ estimated Ground Water/Surface Water (GSI) mixing zone based criteria. Predictive mixing-
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zone based modeling for Hickory Creek indicates the Plume complies with the mixing-zone based GSI
criteria at the Ground Water/Surface Water discharge point, and will be verified during remedial action
activities. Long-term monitoring of the ground water is required to confirm the model and the assumptions
used in the predictive model. Contingency plans will be developed and if necessary implemented to bring
potential discharges back into compliance with the GSI criteria.
B. FATE AND TRANSPORT OF SITE-RELATED CONTAMINANTS
The ground water contamination in both the Western and Eastern Plumes consists primarily of VOCs (i.e.,
TCE, DCE, and vinyl chloride). U.S. EPA's Kerr Laboratory has attributed the occurrence of DCE and vinyl
chloride to the natural anaerobic degradation of TCE.
U.S. EPA's Kerr Laboratory has conducted extensive evaluations of the conditions at the Bendix Site, and
has indicated that the most important natural degradation mechanism is reductive dechlorination. This
mechanism involves microbially catalyzed reactions caused by the replacement of chlorine atoms on the
organic solvent molecules with hydrogen atoms. Reductive dechlorination of TCE results in the formation
of daughter products, most significantly cis-l,2-DCE and vinyl chloride (Figure 5). Vinyl chloride, in turn,
is degraded either aerobically or anaerobically to carbon dioxide or ethene, respectively.
All biodegradation reactions require an electron donor and an electron acceptor. In reductive dechlorination
reactions, the contaminants (i.e., TCE, DCE) serve as electron acceptors rather than the primary food source
(election donor) for microbes. Thus, a primary organic substrate (food source) is necessary to serve as the
electron donor for microbial energy and reproduction. A number of low molecular weight organic compounds
can serve as electron donors. Data from the Bendix Site suggests that one source of the primary substrate
(electron donors) used by anaerobic microorganisms to drive the dechlorination reactions originates from the
former south lagoon. The low levels of soluble cutting oil residuals and other non-chlorinated organic
compounds are being released into the ground water from the former south lagoon.
Reductive dechlorination of TCE and DCE leads to the production of vinyl chloride. Vinyl chloride is more
readily treated in aerobic and iron-reducing conditions than in anaerobic conditions. The model for the
destruction of TCE in both the Western and Eastern Plumes (see Figure 5) occurs in two steps:
Anaerobic reduction of TCE to cis-l,2-DCE, vinyl chloride, and finally to ethene.
Aerobic oxidation of any remaining vinyl chloride to carbon dioxide.
VII. SUMMARY OF SITE RISK
A Baseline Risk Assessment was conducted to evaluate potential risks from contaminant exposure at this
facility, and determine the need for and extent of remediation. The complete Human Health Risk Assessment
and the Ecological Risk Assessment is presented in Section 6.0 of the RI Report (W&C, 1997a). Risk
assessment was conducted in accordance with U.S. EPA's guidance, including: "Risk Assessment Guidance
for Superfund: Volume I Human Health Evaluation" (U.S. EPA, 1989a) and "Risk Assessment Guidance
for Superfund: Volume II Environmental Evaluation Manual" (U.S. EPA, 1989b). These documents provide
the methodology and standard assumptions used for evaluating risk and developing appropriate cleanup
standards.
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A. OBJECTIVES
The specific objectives of the baseline risk assessment for the Bendix Site facility are to provide:
• an evaluation of potential human health and ecological risks and a basis for determining the
need, as required, for remedial action at this facility;
• a basis for determining the appropriate remedial target cleanup levels for contaminants in soils,
ground water, sediments, and/or surface water, as necessary; and
• a basis for comparing the health impacts of various proposed remedial alternatives.
B. HUMAN HEALTH
The Human Health Risk Assessment for the Bendix Site is a quantitative evaluation, conducted in accordance
with U.S. EPA and state guidance, and consists of the following components:
• Hazard Assessment;
• Exposure Assessment;
• Toxicity Assessment; and
• Risk Characterization.
The Human Health Risk Assessment for the Bendix Site indicates that the ground water contaminant
concentrations present in the Eastern and Western Plumes result in carcinogenic and non-carcinogenic risk
estimates greater than the U.S. EPA target risk range. Other media evaluated (i.e., site soils, surface water,
and sediments) were below target risk ranges and are therefore not considered a potential risk.
1. Hazard Assessment
The objective of the Hazard Assessment is to identify the compounds of potential concern (CPCs) for each
medium. Identification of CPCs are selected based on historical use at the Bendix Site, the frequency, spatial
distribution, and magnitude of detection in each medium of concern, and comparison of detected
concentrations to appropriate health/risk-based federal and state criteria. Table 1 presents identified CPCs
for Bendix Site ground water including: frequency of detection; minimum, maximum, and average
concentrations; and federal and state drinking water standards, as appropriate.
2. Exposure Assessment
The purpose of the Exposure Assessment is to estimate the type and magnitude of potential exposure to
CPCs at or migrating from the Bendix Site based on site-specific conditions. Exposure is quantified by
calculating exposure doses for each exposure scenario. Exposure doses are calculated based on the exposed
populations, exposure point concentrations, and exposure pathways using the equations and default values
presented in U.S. EPA and state guidance (U.S. EPA 1988, 1989a, 1991, and MDEQ 1996). Standard
equations and exposure parameters used for estimating exposure doses, organized by exposure medium,
exposure route, and population are presented as Table 6-6 of the RI (W&C, 1997a). The exposure
assessment considers both current and future potential land uses to identify potentially exposed populations.
The Bendix Site is currently used for industrial purposes, and it is expected that future uses will remain
industrial. A significant portion of the Bendix Site consists of buildings and paved areas, and the property
boundary is fenced The Bendix Site slopes to the east towards Hickory Creek and rises slightly to the west
towards Lake Michigan. Land use between the Bendix Site and Hickory Creek is industrial. Residences are
present on the east (far) side of Hickory Creek. Land use between the Bendix Site and Lake Michigan is a
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mixture of residential and commercial. City of St. Joseph municipal water is available in this area. Hickory
Creek and Lake Michigan are used for recreational purposes. Table 2 presents a summary of the media
evaluated, exposed population and complete exposure pathways.
3. Toxicitv Assessment
The toxicity assessment provides information regarding the potential for a specific CPC to cause adverse
effects in humans, and characterizes the relationship between the dose of a chemical and the incidence of
adverse health effects in the exposed population This assessment, therefore, identifies a dose-response value
that can be used to quantitatively evaluate potential health risks as a function of chemical exposure.
Carcinogens
Carcinogenicity is quantified by the cancer slope factor (CSF). The CSF is U.S. EPA's upper-bound lifetime
probability of an individual developing cancer as a result of a lifetime exposure to a carcinogen. CSFs are
determined by U.S. EPA and published in an integrated risk information system (IRIS, 1995d), an on-line
database for toxicity data, and health effects assessment summary tables (HEAST, 1994a). A summary of
the oral dose-response information for carcinogenic effects, including the CSFs, for each CPC is provided
in Table 6-13 of the RI report (W&C, 1997a).
Non-Carcinogens
Non-carcinogens are those compounds that cause an effect (e.g., liver damage) other than carcinogenicity.
Carcinogens may also have non-carcinogenic effects; these effects are considered and included with the
effects of non-carcinogenic compounds. In addition, non-carcinogenic compounds differ from carcinogens
in that they are believed to have threshold dosage levels below which adverse effects are not expected. U.S.
EPA's preferred criterion for quantifying non-carcinogenic risk is the reference dose (RfD), which
corresponds to U.S. EPA's identification of the threshold effects level with an added margin of safety. The
IRIS database maintains a current listing of all the verified RfDs, which are reported in units of mg/kg-day.
By definition, the RfD is an estimate of an average daily exposure level below which significant, adverse non-
carcinogenic health effects are not expected. Table 6-14 presented in the RI report presents the chronic RfDs
and oral dose-response information for non-carcinogenic effects for each CPC. Toxicity profiles for the
CPCs are available from the IRIS database.
4. Risk Characterization
The Risk Characterization integrates the quantitative exposure and toxicity values for each exposure
scenario. Table 3 presents a summary of the quantitative summary of site risk.
Carcinogenic Effects
Carcinogenic risks are evaluated by multiplying the estimated exposure dose by the CSF to obtain an estimate
of incremental risk, as follows:
Carcinogenic Risk = Exposure Dose (mg/kg-day) x CSF (mg/kg-day)"1
The cancer risks of each compound are summed within each exposure scenario. U.S. EPA's guidelines state
that the total incremental carcinogenic risk for an individual resulting from exposure at a hazardous waste
site should not exceed a target risk range of IxlO"6 to 1x10" (U.S. EPA 1990). In this risk assessment, the
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estimated carcinogenic risk for each exposure scenario was compared to these values. If the estimated risk
is below the acceptable range, no further action is recommended. If the estimated risk is within the
acceptable range, the exposure scenario is reviewed to determine whether further actions are warranted,
depending on where the estimated risks fall within that range. Further actions are recommended for estimated
risks exceeding the upper end of the target risk range (1x10^).
Non-carcinogenic Effects
Non-carcinogenic effects are quantified in terms of a Hazard Index (HI), which is calculated by dividing the
exposure dose by the RfD:
Hazard Index (HI) = Exposure Dose (mg/kg-day) / RfD (mg/kg-day)
Non-carcinogenic risks are evaluated by dividing the exposure dose of each compound by its respective RfD,
and summing the resulting hazard index for each compound within each exposure scenario. The resulting
cumulative non-carcinogenic risk for each exposure scenario was compared to the U.S. EPA target HI of 1.
If the HI is less than or equal to 1, no adverse health effects are anticipated from the predicted exposure dose
level. If the HI is greater than 1, the predicted exposure dose level could potentially cause adverse effects
(U.S. EPA 1989a). Table 3 presents a summary of the carcinogenic and non-carcinogenic risk estimates for
each exposure scenario.
5. Summary of Human Health Risk Assessment
Based on the Bendix Site conceptual model developed in the RI, five media at and surrounding the Bendix
Site were identified as the focus of this assessment:
• Site soils;
• Eastern Ground Water Plume;
• Western Ground Water Plume;
• Hickory Creek surface water and sediments; and
• Lake Michigan surface water.
Site Soils
Based on the results of this risk assessment, no remedial action is necessary to protect human health due to
contaminants present in subsurface site soils, given the current and foreseeable industrial land use.
Contamination in site soils is limited to the Bosch property. A site-specific quantification of potential risks
was calculated using a utility worker scenario. The estimated carcinogenic and non-carcinogenic risks were
well below U.S. EPA target risk ranges. At each exposure point where a receptor may come into contact with
known or potentially contaminated media, exposure point concentrations (EPCs) are determined for each
CPC. To provide a range of risk estimates, the maximum and/or average (arithmetic mean) concentrations
of the CPCs were used as the EPCs for each medium. The qualitative evaluation indicated that none of the
EPCs exceeded the Draft MDEQ soil direct contact values or U.S. EPA residential soil screening level for
lead. Furthermore, the EPCs did not exceed the MDEQ Volatile Soil Inhalation Criteria (MDEQ, April
1997) for potential commercial/industrial exposures due to the volatilization of VOCs from soil to air.
Eastern and Western Ground Water Plumes
The risk assessment indicates that the ground water contaminant concentrations present in the Eastern and
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Western Plumes result in carcinogenic and non-carcinogenic risk estimates greater than the U.S. EPA target
risk range, based on residential drinking water scenarios. Contamination in ground water is migrating off-site
in the Eastern Plume (discharging to Hickory Creek) and Western Plume (discharging to Lake Michigan).
Ground water in the area of the plant is identified as a potential future drinking water resource by the MDEQ.
However this area is provided with municipal water. Future potential receptors were assumed to be residents
using the ground water for drinking water. Potential drinking water exposure could be via ingestion, dermal
contact, or inhalation of VOCs from ground water.
A site-specific quantification of potential risks was calculated for ground water from within both the Eastern
and Western Plume areas using the residential drinking water scenario. The estimated carcinogenic and non-
carcinogenic risks (using both maximum and average EPCs) exceeded the U.S. EPA target risk ranges for
the Eastern Plume and the Western Plume. The results of the qualitative human health risk assessment
indicate that the majority of the CPCs are at or above federal or state drinking water standards and/or other
state screening criteria. These contaminants include vinyl chloride, 1,1-DCE, 1,2-DCE (total), TCE, cis-1,2-
DCE, trans-1,2-DCE, 1,1,2-TCA, aluminum, arsenic, iron, manganese, and zinc in the Eastern Plume.
In the Western Plume, the contaminants exceeding these criteria are vinyl chloride, 1,1-DCE, 1,2-DCE
(total), TCE, 1,1,2-TCA, cis-1,2-DCE benzene, iron, manganese, zinc.
Hickory Creek
The results of this risk assessment indicate that no remedial action is necessary to protect human health due
to contaminants present in Hickory Creek surface water and sediments.
Contaminated ground water from the Eastern Plume appears to discharge into Hickory Creek. Potential
exposure points are surface water and sediments in the creek. Potential receptors were identified as children
using the creek for recreational purposes. Potential exposure was evaluated as surface water ingestion/dermal
contact, or sediment ingestion/dermal contact. A site-specific quantification of potential risks was calculated
using a child recreational scenario. The estimated carcinogenic and non-carcinogenic risks were below the
U.S. EPA target risk ranges.
The compounds in surface water were also qualitatively compared to drinking water criteria. No surface
water CPCs exceeded drinking water standards, with the exception of high iron and manganese values, which
are due to the high background values for these metals. No applicable standards or criteria are available to
qualitatively evaluate exposure to sediments.
Lake Michigan
The results of this risk assessment indicate that no remedial action is necessary to protect human health due
to the Western Plume discharging to Lake Michigan surface water.
Ground water from the Western Plume is discharging to Lake Michigan. Potential exposure points in the
lake are surface water. No Plume-related chemicals were detected in the surface waters of Lake Michigan.
However, to provide a conservative risk evaluation, concentrations of Plume-related chemicals measured in
the Western Plume ground water were also compared to federal and state criteria. A dilution factor of 10 was
applied to projected ground water concentrations based on the common dilution factor used by MDEQ for
developing mixing zone based criteria for discharges to Lake Michigan. Potential receptors were identified
as adults and children using the lake for recreational purposes (e.g. swimming). Potential exposure could
be via surface water ingestion/dermal contact.
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A site-specific quantification of potential risks was calculated using child and adult recreational scenarios.
The estimated carcinogenic and non-carcinogenic risks were below the U.S. EPA target risk ranges. The
results of the qualitative risk assessment indicate that none of the EPCs exceed federal/state health based
drinking water standards.
C. ECOLOGICAL RISK ASSESSMENT
The objective of the Baseline Ecological Risk Assessment is to characterize the current and future potential
ecological risks that may exist at the Bendix Site. This Ecological Assessment is based on a qualitative
evaluation, by comparing reported concentrations with appropriate standards. An exposure assessment was
conducted to determine ecologically sensitive areas that may be potentially impacted by the site contaminants.
CPCs were selected for contaminated media in these areas. The EPCs were then compared to environmental
screening criteria.
1. Exposure Assessment
The Bendix Site is industrial, consisting of pavement and buildings, and does not contain significant
ecological habitats. Contaminated soils are located under pavement, buildings, or are capped, and are not
directly accessible to ecological receptors. Ground water is located 25 to 30 feet below ground surface and
is not accessible to ecological receptors. However, ground water discharges to two surface water bodies that
are the subject of this ecological risk assessment.
The exposure assessment identifies ecologically sensitive areas as a result of the contamination at the Bendix
Site. These include the areas where the Eastern Plume discharges to Hickory Creek and where the Western
Plume discharges to Lake Michigan. Potential ecological receptors include the flora and fauna associated
with Hickory Creek and Lake Michigan ecosystems.
Hickory Creek is located approximately one-third of a mile to the east of the plant, and is a perennial stream
approximately 30 feet across and generally one to two feet deep. Hickory Creek water use is classified by
MDEQ as suitable for agriculture, navigational, industrial water supply, public water supply at the point of
intake, cold water fish, other indigenous aquatic life and wildlife, partial body contact recreation, and total
body contact recreation from May through October (MDEQ Fact Sheet Permit No. MI0003174). Hickory
Creek receives non-contact cooling water from the Bosch facility, as well as storm water runoff from the
Bosch facility and the municipal storm water system. The confluence of Hickory Creek and St. Joseph River
is approximately three miles to the north, with the St. Joseph River entering Lake Michigan approximately
six miles downstream of the plant.
Lake Michigan is located approximately one-half mile to the west of the plant. The lake is used for
recreational purposes, including swimming, fishing, and navigation, and is suitable for cold water fish and
other indigenous aquatic life and wildlife.
2. Evaluation of Protected Species in the St. Joseph Area
Currently there is no available documentation that suggests that protected or endangered species are present
within the area of the Bendix Site. The following is a summary of the Michigan Natural Features Inventory
review of the Bendix Site conducted by the MDEQ: "there are no known occurrences of federal- or State-
listed endangered, threatened or otherwise significant species, natural plant communities, or natural features
at the location specified: Berrien County, T5S R19W, Sections 3,4,9,10."
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3. Selection of Compounds of Potential Concern
CPCs and EPCs were selected for the surface water and sediments in Hickory Creek and surface water of
Lake Michigan based on a review of the existing data base. The same CPCs identified in the human health
risk assessment were retained as CPCs in the ecological risk assessment. The only compounds detected and
eliminated from this evaluation were sodium, magnesium, and calcium (see Table 1).. To provide a
conservative estimate of risk, the EPC for each CPC was the maximum detected concentration.
4. Qualitative Ecological Risk Characterization
The qualitative assessment of potential risk to the environment consists of comparing the EPCs of each CPC
for each media to applicable environmental screening criteria. Concentrations of Plume-related chemicals
measured in Hickory Creek surface water were compared to the federal and state standards, as presented in
Table 4. No Plume-related chemicals were reported from the surface water of Lake Michigan (Table 5).
However, to provide a conservative risk evaluation, concentrations of Plume-related chemicals measured in
the Western Plume ground water were also compared to federal and state criteria. A dilution factor of 10 was
applied to projected ground water concentrations based on the common dilution factor used by MDEQ for
developing mixing zone based criteria for discharges to Lake Michigan. The Criteria are:
• Federal Ambient Water Quality Criteria (AWQCs). These criteria are established by the U.S.
EPA to be protective of aquatic organisms in surface water (U.S. EPA, 1986). Fresh water
chronic and acute criteria are available for many of the CPCs.
• Michigan Ground Water/Surface Water Interface (GSI) values are criteria used to evaluate the
potential impact of contaminated ground water venting to a surface water body. These criteria
are developed by the state in accordance with Rule 323.1057 of Part 4 of Part 31 of the Natural
Resources and Environmental Protection Act, 1994 PA 451 (Part 31). Under this act mixing
zones may also be allowed. Mixing zone allowances for ground water are applied in the same
manner as for point source discharges, except that no permit is required. However, like point
source discharges, mixing-zone-based discharged criteria are calculated on a case by case basis
in accordance with Part 31.
Contaminant concentrations measured in Hickory Creek sediments were compared to the following
environmental criteria:
• Effects Range-Low (ER-L). The U.S. EPA screening guidelines include the ER-L for
comparison of compounds detected in sediments. The ER-L value is the concentration
equivalent to that calculated at the lower 10th percentile of the available, screened sediment
toxicity data. As such, it represents the low end of the range of concentrations at which effects
were observed.
• Apparent Effects Threshold (AET). The U.S. EPA screening guidelines include the AET
values, which relate the chemical concentrations in sediments to at least one biological indicator
of injury (e.g., sediment bioassays or altered benthic fauna abundance) to determine the
concentration of the contaminant above which biological effects would always be expected.
Hickory Creek
Mixing zone-based GSI criteria were estimated using the MDEQ Interim Environmental Response Division
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Operational Memorandum #17 dated April, 1996. Mixing zone based GSI criteria are exceeded in the
existing ground water monitoring wells nearest Hickory Creek.
However, predictive modeling for the Eastern Plume indicates the Plume will comply with the mixing-zone-
based GSI values as the Plume migrates and discharges to Hickory Creek. Because this is a prediction only,
long-term monitoring of the Plume is required to ensure ground water does not vent to Hickory Creek above
GSI criteria. If GSI criteria exceedances are predicted or detected through monitoring, contingency plans will
be implemented to insure compliance with the GSI criteria.
The surface water quality for Hickory Creek also includes a requirement of 6 mg/1 dissolved oxygen (DO)
for cold water fish (R 323.1065, MDNR 1994). Based on the DO measurement collected during the surface
water and sediment investigation (W&C 1996), the cold water fish requirement is satisfied. Surface water
samples collected from Hickory Creek and Lake Michigan do not contain Plume-related contaminants that
exceed federal Ambient Water Quality Criteria (U.S. EPA, 1986). The contaminant concentrations in
Hickory Creek sediments are below the ER-L and AET criteria, indicating the CPC concentrations are below
levels considered to have an effect on aquatic biota.
Lake Michigan
To evaluate the potential impact of the Western Plume on Lake Michigan, U.S. EPA Kerr Laboratory and
the University of Michigan have completed several surface water and shallow ground water investigations
along the interface of the Western Plume and Lake Michigan. The results of these investigations are
summarized in Section 5.0 of the RI report (W&C, 1997a) and provide the basis for this ecological
assessment.
Western Plume ground water is discharging to Lake Michigan. Concentrations of Plume-related
contaminants detected in existing ground water monitoring wells nearest to Lake Michigan exceed estimated
MDEQ GSI mixing zone-based values. However, predictive modeling for the Western Plume indicates the
Plume will comply with the mixing-zone based GSI values as the Plume migrates and discharges to Lake
Michigan. Long-term monitoring of the ground water is required to ensure ground water does not vent to
Lake Michigan above GSI criteria. If GSI criteria exceedances are predicted or detected through monitoring,
contingency plans will be implemented to insure compliance with the GSI criteria.
5. Summary of Ecological Risk Assessment
Based on this qualitative assessment, the Ecological Risk Assessment concludes that the contaminant
concentrations in Hickory Creek and Lake Michigan surface water and sediments do not pose a significant
threat to the environment. Estimated GSI mixing zone based criteria are exceeded in monitoring wells near
Hickory Creek and Lake Michigan. Predictive modeling for the Plumes venting to Lake Michigan and
Hickory Creek indicates the Plumes will comply with the mixing-zone based GSI criteria at the Ground
Water/Surface Water discharge points. Long term monitoring will be required to evaluate the remedy and
demonstrate compliance with GSI criteria. Contingency plans will be implemented in a timely manner in the
event monitoring indicates GSI exceedences are predicted or have occurred.
VIII. DESCRIPTION OF ALTERNATIVES
Twenty six potential remedial technologies were identified in the FS (Table 3-1 of FS). Six options were
retained for detailed analysis of the Western Plume, and eight options were retained for detailed analysis of
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the Eastern Plume. These alternatives range from No Action (used as a baseline to compare with the other
alternatives) to containment to permanent treatment. Four alternatives were selected for the Proposed Plan
and are discussed below. Detailed descriptions of each alternative can be found in Section 6.0 of the FS
report.
A. ALTERNATIVE 1 - NO ACTION
This alternative was developed and evaluated in the FS to serve as a baseline with which to compare the other
remedial alternatives. For the No Action Alternative, no institutional controls would be implemented and
no remedial actions would be conducted. This alternative would not implement institutional controls to
prevent the potential for future exposure to contaminated ground water and would not include remedial action
statutory and regulatory requirements to reduce ground water VOC concentrations to drinking water
standards.
Ground water flow modeling was conducted to estimate remedial time frames for the Eastern and Western
Plumes. The limiting factor associated with meeting drinking water standards throughout the aquifer is the
dissolution of inferred source material to the dissolved phase in ground water. Based on the current natural
attenuation processes occurring in the Plumes, it is estimated that it will take approximately 150 to 250 years
for chlorinated VOCs to be degraded to drinking water standards throughout the aquifer. This estimate
assumes that active remedial activities would not be conducted for the Eastern and Western Plume inferred
source areas.
A detailed discussion of the ground water flow modeling used to estimate the remedial time line frames is
presented in Appendix A of the FS report.
Estimated Time to Design and Construct = No remedial activities required
Estimated Remedial Time Frame = 150 to 250 years
Estimated Capital Cost = $0
Estimated Operation and Maintenance Costs (net present worth) = $0
Estimated Total Cost (net present worth) = $0
B. ALTERNATIVE 2 - GROUND WATER INSTITUTIONAL CONTROLS AND DEED
RESTRICTIONS. SOIL VAPOR EXTRACTION (SVE) TREATMENT OF THE EASTERN
Plume SOURCE AREA. SOURCE CONTAINMENT OF WESTERN Plume. TREATMENT
WITHIN THE CONTAINMENT SYSTEM. AND MONITORED NATURAL
ATTENUATION (EASTERN AND WESTERN PlumeS). WITH PROTECTIVE
CONTINGENCIES
This alternative would consist of the following components:
• Environmental Monitoring
• Institutional Controls
• Natural Attenuation of Dissolved Plumes
• Five-year Site Reviews
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Eastern Plume Source Area
Maintenance of Existing Cover System
Operation of SVE System to remove volatile contaminants from the vadose zone
Installation of SVE Vapor Phase Treatment System
Western Plume Source Containment
• Installation of Low Permeability Barrier System
• Installation of Ground Water Extraction System
• Installation and Operation of Ground Water Treatment System within Low
Permeability Barrier System
• Discharge of Treated Ground Water
1. Environmental Monitoring
Environmental monitoring will be used to evaluate (1) the effectiveness of natural attenuation processes in
the Plume, (2) the subsurface microbial environment, (3) compliance with appropriate MDEQ GSI criteria,
and (4) evaluating the change in risks to human health and the environment over time. Environmental
monitoring will consist of routine periodic sampling and analysis of ground water and Lake Michigan and
Hickory Creek surface water.
Contaminated ground water discharging to Hickory Creek and Lake Michigan will be monitored at the POC
and at sentinel wells within the ground water Plumes. The protection criteria for the POC will be the more
restrictive of either the contaminant concentrations found during the monitoring well installation, as a
baseline value, or the calculated GSI mixing zone-based value. POC wells will be installed in the ground
water Plumes as close to Hickory Creek and Lake Michigan as possible where ground water gradients
demonstrate movement toward the creek and the lake.
Sentinel wells are to be located in the Plumes between the inferred source areas and the POC. Sentinel wells
are used to predict or provide early warning of potential exceedances of POC criteria and to monitor the
effectiveness of the remedy to reduce the level of contaminants within the Plume.
The details of establishing progress toward aquifer restoration will be developed in the Long Range
Monitoring Plan in the Statement of Work and will be based on mathematical projections showing the
projected/actual change in the ground water concentrations over time. The individual contaminants, and the
cumulative risk posed by these contaminants, will be evaluated at each monitoring event to establish the
trend (improving or deteriorating) of the ground water restoration. Least square fit and linear regression
analysis are two mathematical approaches that can be used to show these trends. A contingency plan will
be provided in the Long-Term Monitoring Plan and will be implemented to protect human health and the
environment if environmental monitoring predicts or detects exceedences of POC criteria. For mathematical
trends that predict POC exceedences this plan will require an evaluation of the impacts of the exceedence,
potentially leading to increased monitoring, or the implementation of one of the ground water control
measures identified in the FS, or other suitable methods, to prevent further release of contaminants to the
surface water body. These measures may include: ground water pump-and-treat (either on site or off-site);
ground water biovenung and/or biosparging, enhanced biodegradabon of contaminants in the Plume; in-well
stripping; a combination of these procedures; or other technology advanced by the PRPs and approved by
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the U.S. EPA, in consultation with MDEQ, felt suitable for remediation. For confirmed, statistically
significant exceedances of contaminants above the established values at the POC, the contingency plan will
require the implementation of additional ground water control measures, as indicated above, to prevent
further release of contaminants to the surface water body.
The remedial action will be continued until the Eastern and Western Plumes have been restored to drinking
water standards throughout the Plumes.
2. Institutional Controls
Institutional controls in the form of deed and land use restrictions will be implemented to (1) restrict/control
utility and maintenance work in the vicinity of the loading dock (Eastern Plume source area) and former south
lagoon to minimize potential future human health risks associated with site-related contaminants in vadose
zone soils and (2) prohibit the potential future use of Eastern and Western Plume ground water on- and off-
site.
3. Natural Attenuation
This alternative includes Natural Attenuation for control and remediation of VOCs in the Eastern and
Western Plumes. Studies have indicated that biodegradation is occurring within the Western Plume at a rate
of approximately 600 pounds per year. Natural Attenuation is providing active treatment of VOCs in the
Plumes. The containment barrier would effectively isolate the Western Plume inferred source area. The
slurry wall would restrict dissolution and natural attenuation of the inferred source, resulting in a 400 year
estimated remedial time. Estimated remediation time for the Eastern Plume would be the same as the No
Action Alternative (150 to 250 years).
4. Five-Year Site Reviews
Five-year site reviews consisting of ground water and surface water sampling at least once every five years
will be conducted to assess the impacts of contaminants to ground water, Lake Michigan and Hickory Creek
surface water, and to evaluate potential risks to human health and the environment, until the ground water
had been restored to drinking water standards.
5. Eastern Plume Source Area
A SVE system will be designed, installed and operated to control/reduce VOCs in vadose zone soils above
the ground water (Eastern Plume and source area). This will reduce the mass of source material that is
contaminating the ground water, reduce the concentration of volatile contaminants in the vadose zone, and
reduce the time to achieve drinking water standards in the Eastern Plume. The extracted VOCs will be
oxidized and vented to the atmosphere. The VOC treatment system will be monitored to ensure compliance
with state and federal emission requirements.
6. Western Plume Source Containment
Under this alternative, a containment wall (i.e., slurry wall) approximately 1,260 feet long and 100 feet deep,
would be installed around the deep inferred source of the Western Plume to reduce the mobility of
contaminants and the volume of upgradient ground water contacting this inferred source. A Ground water
Extraction System would be installed to achieve hydraulic containment within the low permeability barrier
system and to collect contaminated ground water from within the barrier for treatment. The ground water
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treatment system would be designed to reduce the influent concentrations to drinking water standards. The
FS evaluated the following ground water treatment system: pretreatment to remove inorganics, iron and
manganese oxidation, UV-oxidation, residual peroxide reduction, treated water disposal, sludge thickening,
and sludge dewatering.
The FS evaluated ground water reinjecticn/reinfiltration (e.g., reinfiltration pond, tile field, wells) and surface
water discharge options. The surface water discharge option assumed Hickory Creek to be the receiving
stream because the local publicly-owned treatment works will only accept treated ground water on a
temporary basis. The Bendix Site currently has a permit to discharge non-contact cooling water and storm
water to Hickory Creek.
Residual risks would remain at the Bendix Site from contaminants in ground water in the remainder of the
Western Plume. Institutional Controls would restrict the potential future access to and use of ground water,
thereby eliminating this exposure pathway as a source of residual risk.
Estimated Time to Design and Construct = 2 years
Estimated Remedial Time Frame: Eastern Plume = 150 to 250 years
Estimated Remedial Time Frame: Western Plume = 150 to 400 years
Total Capital Costs = $10,553,000
Total Operation and Maintenance Costs (net present worth)= $4,963,000
Total Costs (net present worth) = $15,516,000
C. ALTERNATIVE 3 - GROUND WATER INSTITUTIONAL CONTROLS AMP DEED
RESTRICTIONS. SOIL VAPOR EXTRACTION TREATMENT (EASTERN Plume
INFERRED SOURCE REMOVAL). MONITORED NATURAL ATTENUATION
(EASTERN AND WESTERN PlumeS). WITH PROTECTIVE CONTINGENCIES
This alternative will consist of the following components:
• Environmental Monitoring
• Institutional Controls
• Natural Attenuation of Dissolved Plumes
• Five-year Site Reviews
Eastern Plume Source Area
• Maintenance of Existing Cover System
• Operation of SVE System to remove volatile contaminants from the vadose zone
• Installation of SVE Vapor Phase Treatment System
The components of Alternative 3 are the same as described for Alternative 2 except that Alternative 3 does
not include the Western Plume Source Containment components. For Alternative 3, the estimated
remediation time for the Eastern Plume is 150 to 200 years. This is slightly lower than Alternatives 1 and
2 (150 to 250 years) because the SVE treatment system will reduce the mass of inferred source contaminants,
thereby reducing the time required to restore the aquifer to drinking water standards.
Estimated remediation time for the Western Plume is the same as Alternative 1 (estimated remediation time
is 150 to 250 years). This is significantly lower than Alternative 2 (remediation time up to 400 years)
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because the Western Plume containment barrier would not be installed.
Estimated Time to Design and Construct = 2 months
Estimated Remedial Time Frame: Eastern Plume = 150 to 200 years
Estimated Remedial Time Frame: Western Plume = 150 to 250 years
Total Capital Costs = $756,000
Total Operation and Maintenance Costs (net present worth)= $3,412,000
Total Costs (net present worth) = $4,168,000
D. ALTERNATIVE 4 - GROUND WATER INSTITUTIONAL CONTROLS AND DEED
RESTRICTIONS. MONITORED NATURAL ATTENUATION (EASTERN AND
WESTERN PlumeS). WITH PROTECTIVE CONTINGENCIES
This alternative would consist of the following components:
• Environmental Monitoring
• Institutional Controls
• Natural Attenuation of Dissolved Plumes
• Five-year Site Reviews
• Eastern Plume Source Area -Maintenance of Existing Cover System
The components of Alternative 4 are the same as the components for Alternative 2 except that Alternative
4 does not include the Eastern Plume source area SVE system or the Western Plume containment system.
Each of the Alternative 4 components are described in Part B of this Section (see Alternative 2).
Alternative 4 includes maintenance and/or repair of the asphalt and concrete cover system that currently
exists over the inferred Eastern Plume source area. This will reduce the potential flushing of source material
into the ground water beneath the Bendix Site, and reduce potential access/direct contact to these soils by on-
site workers.
Because Alternative 4 includes natural attenuation of the Eastern and Western Plumes, the estimated
remediation time is the same as Alternative 1 (150 to 250 years).
Estimated Time to Design and Construct = Readily implementable
Estimated Remedial Time Frame = 150 to 250 years
Total Capital Costs = $624,000
Total Operation and Maintenance Costs (net present worth) = $2,270,000
Total Costs (net present worth) = $2,894,000
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The relative performance of each remedial alternative was evaluated in the FS using the nine criteria set forth
in the NCP at 40 CFR Section 300.430. A remedial action providing the "best balance" of trade-offs with
respect to the nine criteria is determined from this evaluation.
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A. THRESHOLD CRITERIA
1. Overall protection of human health and the environment addresses whether or not a
remedy provides adequate protection and describes how risks posed through each pathway
are eliminated, reduced, or controlled through treatment, engineering controls, or
institutional controls.
2. Compliance with ARARs describes how the alternative complies with chemical-, location-,
and action-specific ARARs, or other criteria, advisories, and guidance.
B. PRIMARY BALANCING CRITERIA
The following five criteria are used to compare and evaluate the elements of one alternative to another that
meet the threshold criteria.
1. Long-term effectiveness and permanence evaluates the effectiveness of alternatives in
protecting human health and the environment after response objectives have been met, in
terms of the magnitude of residual risk and the adequacy and reliability of controls.
2. Reduction in toxicity, mobility, or volume through treatment evaluates the treatment
technologies by the degree of expected reduction in toxicity, mobility, or volume of
hazardous material. This criterion also evaluates the irreversibility of the treatment process
and the type and quantity of residuals remaining after treatment.
3. 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, until the remedial action objectives are achieved.
4. Implementability assesses the ability to construct and operate the technology; the
reliability of the technology; the ease of undertaking additional remedial actions; and the
ability to monitor the effectiveness of the remedy. Administrative feasibility is addressed
in terms of the ability to obtain approvals from other agencies. This criterion also evaluates
the availability of required resources, such as equipment, facilities, specialists, and capacity.
5. Cost evaluates the capital and operation and maintenance costs of each alternative, and
provides an estimate of the total present worth cost of each alternative.
C. MODIFYING CRITERIA
The modifying criteria are used in the final evaluation of remedial alternatives after public comment on the
Rl/FS and Proposed Plan has been received.
1. State acceptance addresses whether, based on its review of the RI/FS and Proposed Plan,
the state concurs with, opposes, or has no comment on the proposed remedial alternative.
The State of Michigan has provided comments on the RI/FS and the Proposed Plan and has
documented its concurrence with the remedial action in its letter of concurrence, and upon
receipt, will be presented in Appendix A.
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2. Community acceptance addresses whether the public concurs with the Proposed Plan.
Community acceptance of the Proposed Plan was evaluated based on comments received
at the Public Meeting and during the public comment period. This is documented in the
Responsiveness Summary presented in Appendix C.
The section below presents the nine criteria and a brief summary of each alternative and its strengths and
weaknesses according to the detailed and comparative analyses.
Overall Protection of Human Health and the Environment
Site conditions currently pose no risks to human health and the environment. However, the potential
exists for future human health risks associated with exposure to ground water. Alternative 3 will
reduce contaminant concentrations in ground water to levels protective of human health risk.
Alternative 3 also includes source control of the Eastern Plume which will reduce the time required
to achieve drinking water standards. Alternatives 1 and 4 will reduce contaminant concentrations
in ground water over time to levels that would reduce human health risk. Containment associated
with Alternative 2 would isolate the Western Plume source which could significantly increase the
time required to meet drinking water standards.
Compliance with Applicable or Relevant and Appropriate Requirements
The alternatives will comply with chemical-specific ARARs over time (i.e., when drinking water
standards are achieved). Location- and action-specific ARARs will not apply to Alternatives 1 and
4 because remedial activities will not be conducted. The other alternatives will be designed to meet
location- and action-specific ARARs.
Long-term Effectiveness and Permanence
Alternative 3 and Alternative 4 will provide effective and permanent treatment over time by allowing
the natural degradation processes occurring in the Eastern and Western Plumes to continue until
drinking water standards are achieved. If the Western Plume inferred source area can be located,
Alternative 2 would minimize the migration of ground water contaminants via containment.
However, Alternative 2 would only be effective if the barrier is installed around the actual Western
Plume source area (which has not been directly observed or sampled to date). Additional studies
would be required to locate this source. Alternatives 2 and 3 would also minimize potential
exposure to on-site workers associated with Eastern Plume vadose zone soils via SVE treatment.
The No Action alternative would not include institutional controls to prevent the potential future
human health risks associated with exposure to ground water.
Reduction in Toxicitv. Mobility, or Volume through Treatment
Natural Attenuation appears to be effectively controlling the spread of the Eastern and Western
Plumes. Alternative 3 will decrease the volume of contaminants within the Eastern Plume source
area via SVE treatment and natural attenuation processes will reduce the toxicity of chemicals in
both Plumes. Natural biodegradation processes associated with the No Action and Natural
Attenuation alternatives (Alternatives 1 and 4) will reduce the toxicity of ground water contaminants
via natural biodegradation processes occurring within the Plume. However, these alternatives would
not provide containment/control of contaminants in Eastern Plume source area vadose zone soils.
However, this would also restrict dissolution and biodegradation of the source material, resulting
22
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in a significant increase in time to achieve drinking water standards.
Short-term Effectiveness
Alternatives 1,3, and 4 will have no adverse effects to the community or the environment.
Implementability
The No Action and Natural Attenuation alternatives (Alternatives .1 and 4) would be readily
implementable because no remedial activities would be required. Alternative 3 could be
implemented in approximately two (2) months. Pilot-scale testing will be required to evaluate and
optimize the SVE system associated with the selected alternative. The containment barrier
associated with Alternative 2 would be difficult to install because (1) the specific location of the
source is uncertain and (2) it would have to be set 90 to 100 feet below ground surface adjacent to
existing structures and utilities. Alternative 2 would require approximately two (2) years to
implement.
Cost
The capital, operation and maintenance costs, and net present worth costs are presented for each
alternative in the Description of Alternatives (Section VIII). The No Action alternative is the least
costly of the alternatives. Alternative 3 is less costly than Alternative 2 because it utilizes the
natural attenuation processes within the Plume and does not require the installation of a deep
containment barrier. The selected remedy is more costly than Alternative 4 (Natural Attenuation)
because it includes using the SVE system to promote source control of the Eastern Plume to reduce
the volume of contaminants contributing to ground water contamination.
State Acceptance
The State of Michigan has provided comments on the FS and the Proposed Plan and has documented its
concurrence with the remedial action as stated in Section XIII. Upon receipt, a copy of the State's letter of
concurrence will be included as Appendix A.
Community Acceptance
Community acceptance of the Proposed Plan was evaluated based on comments received at the Public
Meeting and during the public comment period. There were only a few comments concerning the Proposed
Plan. There was no opposition raised to the Selected Remedy. This is documented in the Responsiveness
Summary presented in Appendix C.
X. THE SELECTED REMEDY
U.S. EPA has selected Alternative 3 as the remedy for the Bendix Superfund Site. Alternative 3 addresses
ground water and source areas associated with the Western and Eastern Plumes. Alternative 3 includes:
Alternative 3 - Ground Water Institutional Controls and Deed Restrictions, Soil Vapor
Extraction Treatment (Eastern Plume inferred source and vadose contamination removal),
and Monitored Natural Attenuation (Eastern and Western Plume), with protective
contingencies.
23
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U.S. EPA and MDEQ have determined that the selected remedy provides the best compliance with the nine
criteria. The selected remedy meets the requirements of CERCLA and has received favorable public
comment.
A. CLEANUP LEVELS
Drinking water standards were selected as cleanup levels for the Bendix Site based on the results of the
baseline risk assessment and set at the more stringent federal or state promulgated drinking water standards,
or derived as a health-based standard where no MCL is available. This approach is consistent with the NCP
that defines acceptable exposure for noncarcinogens as a Hazard Index (HI) equal to 1 and carcinogenic risk
between 10* to 10"6. Therefore, a noncarcinogenic HI less than 1 (e.g., 0.8) or a carcinogenic risk less than
10"6 (e.g., 10') is considered to be protective of human health.
The results of the baseline risk assessment indicate that potential future exposure to ground water results in
an unacceptable "exposure level" to human health. Compounds are present at concentrations associated with
a noncarcinogenic risk greater than an HI equal to 1 and/or carcinogenic risk greater than 10~". The data used
to evaluate potential future risks from ground water exposure are discussed in Section 6.0 of the RI. The
selection of compound-specific drinking water standards is discussed separately for the Western and Eastern
Plumes.
1. Western Plume
Six organic compounds (vinyl chloride, 1,1-DCE, TCE, 1,1,2-TCA, benzene, and 1,2-DCE) are present at
concentrations associated with elevated risk estimates. Exposure to these compounds accounts for 100
percent of the baseline carcinogenic risk and 99.9 percent of the baseline noncarcinogenic risks. These
compounds are listed in Table 7 with the frequency and range of detection, federal MCL and state drinking
water standard (DWS) concentrations, and frequency at which each compound was detected at concentrations
in excess of the federal MCL/state DWS.
Three of the six compounds listed in Table 7 (vinyl chloride, 1,2-DCE [total], and TCE) are present at
elevated concentrations in multiple locations within the Western Plume ground water and are identified as
the CPCs. Drinking water standards are proposed as cleanup levels for each of these compounds (see Table
7). The cleanup levels for these compounds were set at federal MCLs, which are the same concentrations
as the state DWSs. Remedial actions taken to reduce exposure to or concentration of these compounds will
result in a concurrent reduction of exposure to other compounds present in the ground water.
2. Eastern Plume
Six compounds (vinyl chloride, 1,1-DCE, TCE, 1,2-DCE, arsenic, and manganese) are present at
concentrations associated with elevated risk estimates. Exposure to these compounds accounts for 100
percent of the carcinogenic risk and 99.9 percent of the noncarcinogenic risks. These compounds are listed
in Table 8 with the frequency and range of detection, federal and state drinking water standard
concentrations, and frequency at which each compound was detected at concentrations in excess of the federal
MCL/state DWS.
Four of the six compounds listed in Table 8 (vinyl chloride, 1,1 -DCE, 1,2-DCE [total], and TCE) are present
at elevated concentrations in multiple locations within the Eastern Plume ground water and are identified as
the CPCs. Cleanup levels are proposed for each of these compounds and were set at federal MCLs (see
24
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Table 8). State drinking water standards for these compounds are the same concentrations as the MCL.
B. DESCRIPTION OF REMEDIAL COMPONENTS
The selected remedial alternative for the Eastern and Western Plumes and their source areas acknowledges
the natural biodegradation processes occurring within the Plumes. Environmental monitoring will be
conducted to evaluate the continued effectiveness of natural attenuation processes and institutional controls
will be implemented to protect public health by restricting future use of ground water. This alternative
includes the following components:
• Environmental Monitoring with protective contingency plans;
• Institutional Controls;
• Natural Attenuation of Dissolved Plumes;
• Five-year Site Reviews;
• Eastern Plume Source Area-Maintenance of Existing Cover System;
• Eastern Plume Source Area-Operation of SVE System; and
• Eastern Plume Source Area-Installation of SVE Vapor Phase Treatment System.
1. Environmental Monitoring
Environmental monitoring will be used to evaluate (1) the effectiveness of natural attenuation processes in
the Plume, (2) the subsurface microbial environment, (3) compliance with appropriate MDEQ GSI criteria,
and (4) the change in risks to human health and the environment over time. Environmental monitoring will
consist of routine periodic sampling and analysis of ground water and Lake Michigan and Hickory Creek
surface water.
Contaminated ground water discharging to Hickory Creek and Lake Michigan will be monitored at the POC
and at sentinel wells within the ground water Plumes. The protection criteria for the POC will be the more
restrictive of either the contaminant concentrations found during the monitoring well installation (baseline
value), or the calculated GSI mixing zone-based value. POC wells will be installed in the ground water
Plumes as close to Hickory Creek and Lake Michigan as possible where ground water gradients demonstrate
movement toward the creek and the lake.
Sentinel wells are to be located in the Plumes between the inferred source areas and the POC. Sentinel wells
are used to predict or provide early warning of potential exceedances of POC criteria and to monitor the
effectiveness of the remedy in reducing the level of contaminants within the Plume.
The details of establishing progress toward aquifer restoration will be developed in the Long Range
Monitoring Plan in the Statement of Work and will be based on mathematical projections showing the
projected/actual change in the ground water concentrations over time. The individual contaminants, and the
cumulative risk posed by these contaminants, will be evaluated at each monitoring event to establish the
trend (improving or deteriorating) of the ground water restoration. Least square fit and linear regression
analysis are two mathematical approaches that can be used to show these trends. A contingency plan will
be provided in the Long-Term Monitoring Plan and will be implemented to protect human health and the
environment if environmental monitoring predicts or detects exceedences of POC criteria. For mathematical
trends that predict POC exceedences this plan will require an evaluation of the impacts of the exceedence,
potentially leading to increased monitoring, or the implementation of one of the ground water control
measures identified in the FS, or other suitable methods, to prevent further release of contaminants to the
25
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surface water body. These measures may include: ground water pump-and-treat (either on site or off-site);
ground water bioventing and/or biosparging; enhanced biodegradanon of contaminants in the Plume, in-well
stripping; a combination of these procedures; or other technology and approved by the U.S. EPA, in
consultation with MDEQ, felt suitable for remediation. For confirmed, statistically significant exceedances
of contaminants above the established values at the POC, the contingency plan will require the
implementation of additional ground water control measures, as indicated above, to prevent further release
of contaminants to the surface water body.
The remedial action will be .continued until the Eastern and Western Plumes have been restored to drinking
water standards.
2. Institutional Controls
Institutional controls in the form of deed and land use restrictions will be implemented to prohibit ground
water use associated with the Eastern and Western Plumes both on- and off-site. Institutional controls will
be drafted, implemented, and enforced in cooperation with adjacent property owners and the federal, state,
and local governments.
3. Natural Attenuation
The selected remedial alternative includes natural attenuation for treatment of site-related VOCs (i.e., TCE,
1,2-DCE, and vinyl chloride) in Eastern and Western Plume ground water. U.S. EPA Kerr Laboratory has
concluded that the most important natural attenuation mechanism at the Bendix Site is biological reductive
dechlorination (Wilson et al., 1996, Weaver et al., 1996a, and Weaver et al., 1996b). Based on
environmental data collected to date, natural attenuation is providing active treatment of chlorinated orgamcs
in the Western Plume. TCE is degraded to DCE, which is then degraded to vinyl chloride in the strongly
reducing, anaerobic conditions within the Plume Vinyl chloride is degraded to either ethene or carbon
dioxide, depending on the subsurface conditions (either anaerobic or aerobic, respectively). By the time the
Plume reaches the Lake Michigan beach front, much of the chlorinated mass has been degraded to ethene.
Extensive site characterization data indicate that natural attenuation is effectively containing the spread of
contamination by reducing contaminant concentrations. Natural attenuation is an appropriate remediation
method only where it is fully protective of human health and the environment, and where it can be
demonstrated capable of achieving site-specific remediation objectives (e.g., drinking water standards) within
a reasonable time frame. The NCP states that remediation time frame for restoring ground water to its
beneficial use should be developed based on specific site conditions. Under these natural attenuation
processes, the time to achieve drinking water standards is estimated to be between approximately 150 to 250
years. County well permit regulations preclude the use of this aquifer for residential use, and the time frame
projections shown are reasonable given this site specific circumstance.
4. Five-year Site Reviews
Under CERCLA Section 121(c), a remedial action that results in hazardous wastes, pollutants, or
contaminants remaining on site should be reviewed every five years. Data collected during the monitoring
program will be used to assess potential impacts of contaminants, and evaluate whether human health and
the environment continue to be protected by the alternative.
26
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5. Eastern Plume Source Area - Existing Cover System
The cover system above the Eastern Plume source area consists of asphalt, concrete slab, and existing
buildings. The cover system will be visually inspected annually and repaired as necessary (e.g., resurfaced,
patched). This cover system will continue to minimize infiltration to vadose zone soils, thereby reducing the
amount of contaminants released to ground water, and will also reduce potential access/direct contact to these
soils by on-sitc workers.
6. Eastern Plume Source Area - Operation of SVE System
The SVE treatment system is an in situ vadose zone treatment technology that operates via application of
a vacuum to promote vapor flow through the vadose zone. Contaminants will volatilize from soil and be
swept by air flow to air extraction wells located throughout the contaminated area. Extracted air will be
treated using photocatalytic oxidation to achieve air emission requirements.
C. LONG TERM MONITORING PLAN
The Long-Term Monitoring Plan will present specific details of the long-term sampling and analysis
requirements for compliance monitoring of air emissions, surface water, and ground water as required by the
selected remedy for the Bendix Site. This plan will present the location of each sampling point, sampling
protocol, analytical method, analytical level, data evaluation level employed for each sampling location
during the long-term monitoring phase of the remedial action. The Long-Term Monitoring Plan will also
present the method used to determine what constitutes an exceedence or projected exceedence, when and what
action(s) (contingencies) will be taken to protect human health and the environment if exceedences are
reported above determined action levels.
XL STATUTORY DETERMINATIONS
The selected remedy for the Bendix Site is consistent with CERCLA and in compliance with the NCPto the
extent practicable. The selected remedy is protective of human health and the environment, attains ARARs,
and is cost-effective. The selected remedy also satisfies the statutory preference for treatment that
permanently and significantly reduces the toxicity, mobility, or volume of hazardous substances as a principal
element. The following describes how the selected remedy meets these requirements.
A. THE SELECTED REMEDY IS PROTECTIVE OF HUMAN HEALTH AND THE
ENVIRONMENT
The selected remedy will provide adequate protection of human health and the environment through
institutional controls to prevent exposures to ground water and through the treatment technologies to be
employed. The potential future risks associated with access to/use of site ground water will decrease over
time because Natural Attenuation will reduce the concentration of contaminants to the drinking water
standards listed in Table 1.
B. THE SELECTED REMEDY ATTAINS ARARs
The selected remedy will comply with identified federal and state ARARs. Potential chemical-and location-
specific ARARs were identified, defined, and summarized in Section 7.0 of the RJ report. Potential action-
specific ARARs were identified in Section 2.0 of the FS report.
27
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Table 9 presents the chemical-specific ARARs for the selected remedy. Because remedial actions will not
impact natural resources (e.g., wetland areas), location-specific ARARs do not apply to the selected remedy.
Action-specific ARARs for the Eastern Plume remedial activities are listed in Table 9. Activities associated
with the selected remedy will be conducted according to regulations outlined by OSHA.
A brief narrative of significant chemical- and action-specific ARARs, and other criteria, follows.
1. Water Regulations
Chemical-specific ARARs for site ground water include regulations and criteria promulgated under the Safe
Drinking Water Act (SOWA), Clean Water Act, and State of Michigan statutes. In addition, certain other
numerical goals will be attained. The federal National Drinking Water Regulations consist of contaminant-
specific standards known as MCLs and Maximum Contaminant Level Goals (MCLGs). MCLs are
enforceable standards that are the maximum permissible level for specific contaminants in public water
supplies. MCLGs are non-enforceable health-based goals that establish levels at which no known or
anticipated adverse health effects occur. The NCP, 300.430(e)(2XI)(B) and (C), requires that MCLGs above
zero, and MCLs, be attained for ground water sources that are current or potential sources of drinking water.
Under the Michigan Drinking Water Rules, the state adopted federal MCLs. Because ground water
associated with the Bendix Site is potentially a drinking water source, MCLs are not applicable at the site,
but they are relevant and appropriate. In developing the cleanup levels, the Risk Assessment compared
ground water contaminant concentrations with federal MCLs, Michigan drinking water standards, and
Michigan aesthetic drinking water values. Cleanup levels were set at MCLs. Michigan drinking water
standards adopted federal MCLs. The selected remedy will be complete when drinking water standards have
been achieved in the ground water Plumes.
Part 201 (Environmental Remediation) of the Michigan Natural Resources and Environmental Protection Act
of 1994 (Public Act 451) is applicable to the selected remedy and specifies rules for establishing risk-based
cleanup criteria for a site. If risk-based cleanup criteria established for ground water under this rule differ
from (a) the state drinking water standard, or (b) criteria for adverse aesthetic characteristics, the cleanup
criteria for the site will be the more stringent of (a) or (b) unless use of the aquifer is restricted. The Bendix
Site aquifer will also be restricted by implementing institutional controls and deed restrictions.
Under Rule 323.1057 of Part 4 of Part 31 of the Natrual Resources and Environmental Protection Act, 1994,
as amended; PA 451 of the National Toxics Rule (NTR; Federal Register, December 22, 1992, VOL.
57(246): 60848-60923) Ground Water Surface Water (GSI) criteria have been identified as goals for the
selected remedy. These GSI criteria identify the maximum ground water contaminant discharge to surface
water. The final GSI value is the more restrictive of the Rule 57 value and the NTR value, where both are
available (excluding arsenic whose GSI value is the Rule 57 value). Under the 1995 amendments to Part 31,
mixing zones for ground water venting to a surface water body are allowed. Mixing zone determinations and
discharge criteria are developed on a case by case basis in accordance with Part 31.
2. Air Regulations
The Clean Air Act provides primary and secondary air quality standards to protect human health from known
or anticipated adverse effects of pollutants. The Michigan Air Pollution Control Act (Act No. 348) and Part
55 of Michigan Public Act 451 (Air Pollution Control) contain contaminant-specific regulations that pertain
to allowable emissions of pollutants from various air containment source categories and processes. These
requirements are applicable to the selected remedy because the SVE treatment system associated with the
28
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Eastern Plume will produce VOC emissions. The SVE off-gas treatment system will be monitored on a
monthly basis to ensure compliance with state and federal permitting and emission requirements.
C. THE SELECTED REMEDY IS COST-EFFECTIVE
The remedy provides overall effectiveness proportionate to its cost. The estimated costs associated with this
remedy are:
• Capital Cost:; , $ 756,000
• Operation and Maintenance Costs (net present worth): $3,412,000
• Total Cost (net present worth): $4,168,000
Alternative 3 is considered cost-effective because it takes advantage of the natural attenuation processes
occurring in the Plumes. The remedy provides protection against the potential for future human health risks
associated with exposure to site ground water. Major capital costs associated with the selected remedy
include well installation for long-term monitoring, and legal and engineering support associated with
implementing institutional controls. Major operation and maintenance costs include the five year site reviews
and operation and maintenance of the SVE systenj.
The No Action alternative is less costly, but it would not provide protection from the potential future risks
associated with ground water exposure. Alternative 4 (Natural Attenuation) is less costly than the selected
remedy. However, the selected remedy utilizes the SVE treatment system to reduce the concentration of
VOCs in vadose zone soils, thereby minimizing potential exposure to on-site workers.
The selected remedy affords overall effectiveness when measured against CERCLA Section 121 criteria and
the NCP's nine evaluation criteria, and costs are proportionate to the protection that will be achieved.
D. THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM
EXTENT PRACTICABLE
The selected remedy represents the maximum extent to which permanent solutions and treatment
technologies can be used in a cost-effective manner at the Bendix Site. The remedy permanently removes
the contaminants from the natural environment in the following manner:
VOCs are extracted from vadose soils (at the source of the Eastern Plume) by a SVE system with
photo-oxidation destruction of the off-gassed vapors.
U.S.EPA Kerr Laboratory has determined that through the natural attenuation (microbial anaerobic
and aerobic dechlorination) process approximately 600 Ibs. of TCE are destroyed annually in the
Western Plume.
Natural attenuation is also occurring along the Eastern Plume, destroying TCE.
The selection remedy is protective of human health and the environment, complies with federal and
state requirements that are legally applicable or relevant and appropriate, and is cost effective.
Natural Attenuation of the Eastern and Western Plumes combined with Eastern Plume source control
SVE to control/reduce VOCs in vadose zone soils; maintenance of the existing vadose zone soil
29
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cover system; environmental monitoring; and restrictions to prohibit access to vadose zone soils and
ground water through institutional controls will provide the most permanent solution practicable,
proportionate to cost.
E. THE SELECTED REMEDY SATISFIES THE PREFERENCE FOR TREATMENT THAT
PERMANENTLY AND SIGNIFICANTLY REDUCES THE TOXICITY. MOBILITY. OR
VOLUME OF THE HAZARDOUS SUBSTANCES AS A PRINCIPAL ELEMENT
The principal .element of the selected remedy is treatment of the contaminated ground water by natural
attenuation of contaminants in the Western and Eastern Plumes. This remedy permanently reduces the
toxicity, mobility, and volume of contaminants in ground water by the microbial degradation of TCE.
Vadose soils that continue to be a source of contaminants to ground water will be removed by an SVE
system, off-gases will be destroyed by a photo-oxidation vapor treatment. This remedy addresses the
potential threat to human health and the environment by the restoration of the ground water resource by the
permanent destruction of hazardous substances. This will significantly reduce the toxicity, mobility, and
volume of the hazardous substances.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the recommended alternative described in the proposed plan.
30
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TABLE I
EASTERN AND WESTERN GROUNDWATER PLUMES - COMPOUNDS OF POTENTIAL CONCERN (CPCs)
RECORD OF DECISION
BENDIXSITE
ST. JOSEPH, MICHIGAN
COMPOUND
FREQUENCY
OF
DETECTION
E4STERN GROltNDWATER PLt'ME
VOCs, ug/l
vinyl chloride
ij-DCE "
j.l-pCA
1.2-bCE (total)
ICE
1.1.2-TCA
toluene
m,p-xylene
c-xylene
trans- U-DCE
ci$-l.2-DCE
Inorganics, ug/l
aluminum
arsenic
iron
manganese
zinc
18/47
6/23 .,
27/47 '" ''__
8/17
9/47
. -• — ••--
23/47
6/24
7/24
1/30
16/30
8/23
15/23
" 23/23
' 22/23
9/23
WESTERN GROUND\V\TER PLl:ME
VOCs, ug/l
vinyl chloride
chloroethane
I.I-DCE" '_
U-DCA
1.2-UCE (total)
fCE
i.i.i-TCA
benzene
toluene
cis-r2-DCE
trans- 1.2-DCE
Inorganics, ug/l
iron
manganese
zinc
54/96
1/7
8'44
4/14
4/7
25/96
1/7
4/44
5/44
31/96
:o/89
6/7
6/7
3/7
MINIMUM
CONC.
95J
4)
1 8J
6J
55
4J
11
" 2.7
1.2
290
1.3
I98B
I.2B
" 1958
46B
IOB
01
6J
1
2J
44
I.V
7J
1.5"
I.2J
06
04
152B
34.9
123
MAXIMUM
CONC.
4.200
12
240
7.600
530
5J
28
9.7
9
290
170.000
963
' 62 9
22.100
7.710
4.410
960
23
28
93
680
85.000
V
7.1
17
160.000
26.3
3.840
168
4.030
AVERAGE
323
5.2
"79
1,159
47
4
35'
59»
58*
54
20.611
72.8
17.5
3.881
668
297
74
6.4
2.4
"372*
248
900
5.3
" 115*
"us-
1.847
58'
860
79
647
FEDERAL
MCLs/
STATE DWSi
2/2
7/7
NS/880***
70/70"
5/5"
"5/5
I.OOO/ 1.000
10.000/10.000
10.000/10,000
100/100
70/70
NS/NS
50/50
NS/NS
NS/180"'
*~ NS/2.46b'**
2/2
NS/220'*
7/7
NS/880"
70/70
"" 5>5
5 '5
'5/5
I.OOO/ KOOO
70/70
100/100
NS.'NS
NS/180**
NS/2.400"
STATE ADWVj
NS
' NS
NS
NS
"" NS '
_.. ^
790
280
280
NS
NS
50
NS
300
50
5000
NS
NS
NS
"NS"
NS '
NS
NS
NS"
790
NS
NS
300
50
5000
NOTES.
B = for inorganics, value detected berxseen instrument detection limit and practical quantitation limit.
J = estimated value.
blank = compound delected in the method blank
NS = No standard
• When calculating ihe average. 1 - the detection limn was used lor non-deiccls In some cases, the average is higher
than (he maximum detected, due to c\traordmanl> high detection limits for some samples For those compounds selected as
C'PC's. the maximum concentration "ill be used instead of Ihc average 10 calculate quantitative risk estimates
MC'I.s - Federal Maximum C'onlaminam l.ocls. I:PA. 19% " indicates federal action lex el (MDNR. W5a & l^hl
DWSs - Michigan Drinking Water Standards ••• indicates health-based drinking water value (MDNR. IWa & I9<*5hi
AO\\ \'s = Mu-hipan aesthetic drinking water values
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TABLE 2
SUMMARY OF EXPOSURE SCENARIOS
RECORD OF DECISION
BENDIX SITE
ST. JOSEPH, MICHIGAN
Media
Site Soils
Eastern Groundwater Plume
Western Groundwater Plume
Hickory Creek
Lake Michigan
Exposed Population
Utility Worker
Residents
Residents
Children Recreation
Children Recreation
Adult Recreation
Complete Exposure Pathways
Soil Contact/Ingestion/Inhalation
Potential Future Drinking Water Scenario Via
Groundwater Contact/ Ingestion/ Inhalation
Potential Future Drinking Water Scenario Via
Groundwater Contact/ Ingestion/ Inhalation
Surface Water Contact/Ingest ion
Sediment Ingestion
Surface Water Contact/lngestion
Surface Water Contact/lngestion
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TABLE 3
SUMMARY OF SITE RISK
RECORD OF DECISION
BENDIXSITE
ST. JOSEPH, MICHIGAN
SCENARIO
Soils
Ingestion
Dermal
Total
Eastern Groundwater Plume
Ingestion
Inhalation (Showering)
Dermal
Total
Western Groundwater Plume
Ingestion
Inhalation (Showering)
Dermal
Total
Hickory Creek
Ingestion Sediments
Dermal Sediments
Ingestion Surface Water
Dermal Surface Water
Total
Lake Michigan
Children
Ingestion to Surface Water
Dermal Surface Water
Total Children
Adults
Ingestion Surface Water
Dermal Surface Water
Total Adults
Carcinogenic
Max.
6.6E-07
O.OE+OO
6.6E-07
9.5E-02
5.6E-02
1.3E-03
1.5E-01
3.3E-02
3.5E-02
6.5E-04
6.9E-02
I.OE-07
NA
3.3E-10
4.9E-10
I.OE-07
Risk
Avg.
8.1E-08
O.OE+OO
8.1E-08
7.6E-03
4.3E-03
l.OE-04
1.2E-02
1.8E-03
1.3E-03
2.8E-05
3.1E-03
4.8E-08
NA
1.6E-10
2.3E-10
4.8E-08
2.4E-08
3.4E-08
5.8E-08
2.0E-08
5.6E-08
7.6E-08
Hazard
Max.
0.085
0.0062
0.092
540
55000
0.52
56000
830
1200
12
2000
0.023
NA
0.0018
0.000032
0.025
Index (HI)
Avg.
0.01 1 '
0.00037
0.012
66
4800
0.076
4900
11
570
0.14
580
0.011
NA
0.0014
0.000011
0.012
0.00013
0.00013
0.00026
0.000028
0.000053
0.000081
Bold indicates calculated risk exceeds 1E-6 or HI exceeds 1.
-------
TABLE 4
HICKORY CREEK SURFACE WATER AND SEDIMENT
EXPOSURE POINT CONCENTRATIONS (EPCs) COMPARED TO ENVIRONMENTAL SCREENING
CRITERIA
SURFACE WATER
RECORD OF DECISION
BENDIXSITE
ST. JOSEPH, MICHIGAN
COMPOUND
VOCs, ug/l
Chloroform
Bromodichloromethane
cis-1.2-DCE
Metals, ug/l
Iron
Maneanese
EPC
(MAXIMUM CONC.)
1.7
0.57
1.6
504
101
AWQCs
Chronic/Acute
28,9007 1,240
NC/NC
11.600/NC
NC/ 1,000
NC/NC
SEDIMENTS
COMPOUND
VOCs, ug/kg
Vinyl Chloride
1,1 -DC A
cis-l,2-DCE
Xylene
Metals, mg/kg
Aluminum
Arsenic
Barium
Chromium
Copper
Iron
Lead
Manganese
Nickel
Vanadium
Zinc
EPC
(MAXIMUM CONC.)
43
2J
IOJ
U
2,200
6.3
42.6
19.5
19.7
17,200
8.3
466
13.4
8
63.5
FEDERAL/STATE SCREENING CRITERIA
ER-L
NC
NC
NC
NC
NC
8.2
NC
81
34
NC
46.7
NC
^0.9
NC
150
AET
NC
NC
NC
40
NC
57
NC
260
390
NC
450
NC
140
NC
410
AWQCs - Ambient Water Quality Criteria
ER-L = Effects Range - Low
AET = Apparant Effects Threshold
Source: EPA. 1986
NC = No criteria.
J = estimated value.
-------
TABLE 5
LAKE MICHIGAN SURFACE WATER EXPOSURE POINT CONCENTRATIONS
COMPARED TO ENVIRONMENTAL SCREENING CRITERIA
RECORD OF DECISION
BENDIX SITE
ST. JOSEPH. MICHIGAN
COMPOUND
VOCs, UE/I
vinyl chloride
1,1 -DCE
1,2- DC A
TCE
benzene
cis-l,2-DCE
trans- 1 .2-DCE
EPC
(AVERAGE CONC.)
8.3
0.9
0.6
14.5
0.9.
52.7
2
AVVQC's
Acute/Chronic
11,600/NC
NC
NC
5,280/840
5,300/NC
11,600/NC
11.600/NC
AWQCs = ambient water quality criteria,
National Oceanic and Atmospheric Administration.
NC = no criteria.
Note: The EPCs were calculated by using the average concentrations of the Lake Michigan groundwater
CPCs identified in the Human Health Risk Assessment and applying a 10 times dilution factor.
Example: Vinyl Chloride EPC concentration in surface water is the average concentration
(83 ug/l)/dilution factor (10) = 8.3 ug/1.
-------
TABLE 6
COMPONENTS OF THE REMEDIAL ALTERNATIVES
RECORD OF DECISION
BENDIX SITE
ST. JOSEPH, MICHIGAN
ALTERNATIVE
KEY COMPONENTS
ALTERNATIVE I: NO
ACTION
• Five-year site reviews
ALTERNATIVE 2:
GROUNDWATER
INSTITUTIONAL
CONTROLS AND DEED
RESTRICTIONS. SOIL
VAPOR EXTRACTION (SVE)
TREATMENT OF THE
EASTERN PLUME SOURCE
AREA. SOURCE
CONTAINMENT OF THE
WESTERN PLUME.
TREATMENT WITHIN THE
CONTAINMENT SYSTEM.
AND MONITORED
NATURAL ATTENUATION
(EASTERN AND WESTERN
PLUMES)
Environmental monitoring
Institutional controls (deed restrictions, zoning)
Maintenance of existing cover system (i.e.. pavement over Eastern Plume source
area)
Use of existing SVE system in the Eastern Plume source area to collect
chlorinated organics in the vadose zone
Treatment of SVE off-gases
Installation of a circumferential, impermeable barrier (e.g.. slurry wall) in Eastern
Plume source area
Installation of groundwater extraction system within the barrier
Treatment of groundwater (e.g., UV/oxidation)
Groundwater discharge (e.g., groundwaler reinfection, surface water discharge)
Natural attenuation of dissolved organics in Eastern and Western Plumes
Five-vear site rc\ ic\\ s
ALTERNATIVE 3:
GROUNDVVATER
INSTITUTIONAL
CONTROLS AND DEED
RESTRICTIONS, SOIL
VAPOR EXTRACTION
TREATMENT (EASTERN
PLUME INFERRED SOURCE
REMOVAL). AND
MONITORING NATURAL
ATTENUATION (EASTERN
AND WESTERN PLUMES)
Environmental monitoring
Institutional controls (deed restrictions, zoning)
Maintenance of existing cover system (i.e., pavement over Eastern Plume source
area)
Use of existing SVE system in the Eastern Plume source area to collect
chlorinated organics in the vadose zone
Treatment of SVE off-gases
Natural Attenuation of dissolved organics in Eastern and Western Plumes
Five-vcarsitc rcvicus
ALTERNATIVE 4:
OROUNDWATER
INSTITUTIONAL
CONTROLS AND DEED
RESTRICTIONS.
MONITORED NATURAL
ATTENUATION (EASTERN
AND WESTERN PLUMES)
Environmental monitoring
Institutional controls (deed restrictions, zoning)
Maintenance of existing cover system (i.e.. pavement over Eastern Plume Source
Area)
Natural attenuation of dissolved organics in Eastern and Western Plumes
Five-vcar site rcvicu s
NOTE:
SVE = soil vapor extraction
-------
TABLE 7
CLEANUP LEVELS FOR GROUNDWATER - WESTERN PLUME
RECORD OF DECISION
BENDIX SITE
ST. JOSEPH, MICHIGAN
COMPOUND
VOCs, ng/L
vinyl chloride
1.2-DCE (total)
TCE
1.1-DCE
1.1.2-TCA
benzene
FREQUENCY
OF
DETECTION
54/96
38/96
25/96
8/44
1/7
4/44
MINIMUM
CONC.
0.1
0.4
1.3
1
7J'
1.5
MAXIMUM
CONC.
960'
160000-
85000*
28*
7J*
7.T
'AVERAGE
74'
960*
900'
24
53'
7.1-
FEDERAL
MCU
STATE DWS
2
70
5
7
5
5
NO. OF
DETECTIONS
GREATER
THAN
MCL/STATE
DWS
18/96
15/96
20/96
2/44
1/7
1/44
CLEANUP
LEVEL
2
70
5
"V.""
'..
'•-
NOTES:
' When calculating the average, 1/2 the detection limit was used (or non-detects:
In some cases, the average is higher than the maximum detected, due to high detection limits for some samples
In these cases, the maximum cone, is used instead of the average
' No cleanup level proposed because this compound was not retained as a CPC.
MCL = Federal Maximum Contaminant Level
DWS = Michigan Drinking Water Standard
'Site concentrations that exceed cleanup levels.
-------
TABLE 8
CLEANUP LEVELS FOR GROUNDWATER •
EASTERN PLUME
RECORD OF DECISION
BENDIX SITE
ST. JOSEPH. MICHIGAN
COMPOUND
VOCs, iigfl
vinyl chloiide
1.1-OCE
1.2-DCE (lolal)
TCE
Inorganic s.fig/l
arsenic
manganese
FREQUENCY
OF
DETECTION
19/47
6/23
24/47
9/47
15/23
22/23
MINIMUM
CONC.
95J-
4J
13
55'
1 28
46B
MAXIMUM
CONC.
4200'
12'
170000'
530'
629'
7710'
'AVERAGE
320'
52
7000'
47*
18
670
FEDERAL MCU
STATE DWS
2
7
70
5
50
NA
USEPA
GUIDANCE/
CRITERIA
..
-
--
.-
.
-
840 e
NO. OF
DETECTIONS
GREATER
THAN
MCL/STATE
DWS
19/47
4723
15/47
9/47
3/23
3/23
CLEANUP
LEVELS
2
7
70
5
i
j ..
NOTES:
' When calculating me average. 1/2 the detection limit was used lor non-delecls
In some cases, the average is higher than the maximum delected, due to high delectior. limits lor some samples
In these cases, the maximum cone, is used instead ol the average.
' No cleanup level proposed because (his compound was not retained as a CPC.
MCL = Federal Maximum Contaminant Level
DWS = Michigan Drinking Water SlaMard
e = USEPA derived risk-based concentration for residential drinking water (IRIS, November 1995).
'Site concentrations that exceed the cleanup levels.
-------
TABLE 9
ARARs CRITERIA AND GUIDANCE FOR THE SELECTED REMEDY
RECORD OF DECISION
BENDKSITE
ST. JOSEPH, MICHIGAN
Chemical-Specific ARARs
Safe Drinking Water Act (SDWA) - MCLs
SDWA-MCLGs
Clean Water Act (CWA) - Ambient Water Quality Criteria
Clean Air Act - National Primary and Secondary Ambient Air Quality
Standards
Michigan Natural Resources and Environmental Protection Act 451 (Part 201)
Part 31 of Public Act 451
Michigan Safe Drinking Water Act
Michigan Air Pollution Control Act (Act No. 348) of the Public Acts of 1965
The following chemical-specific criteria were also considered:
USEPA Risk Reference Doses
USEPA Carcinogen Assessment Group Cancer Slope Factors
USEPA Health Advisories
MDNR Operational Memoranda #8 and #14
MDEQ Operational Memoranda #17
MDNR Interim Generic Utility Worker Groundwater Contact Criteria:
Addendum to Operational Memos #8 and #14
Action-Specific ARARs
State of Michigan Part 55 of Public Act 451, Air Pollution Control (formerly
Act. No. 348) Part 2 and Part 7
-------
'< >
LAKE
MICHIGAN
BASE MAP COMPILED FROM U.S.G.S.
TOPOGRAPHIC QUADRANGLES TOR
STEVENSVILLE. MICHIGAN 1970. AND
BEN TON HARBOR. MICHIGAN PHOTO-
REVISED 1980.
, .
\ ;,.. .1 .:.• .-• . -• •
•
DR.BY: KAP |
FIGURE 1
SITE LOCATION MAP
RECORD OF DECISION
BENDIX SITE
ST. JOSEPH. MICHIGAN
SCALE: NOTED
JOB NO.: 9319*07
DATE: SEPTEMBER 199
WOOO\RD & OJRRAN
Engineering • Science - OpcroNon*
-------
FIGURE 2
BENDIX SUPERFUND SITE
ST JOSEPH, MI
Lake
Michigan
Inferred Source of
Western Plume
Bosch
Manufacturing I I
Plant ^ '
Inferred Groundwaler Flow Direction
Interpretive Total VOC (ng/L)
Contamlnationn
Former Loading Dock Lagoon
(Inferred Source of
Eastern Plume)
Approximate Location of
Croundwater.Divide
Former South Lagoon
(Primary Source of
Substrate)
Not to Scale
-------
A
Northwest
FIGURE 3
BENDIX SUPERFUND SITE
ST JOSEPH, MI
A'
Southeast
-~2800 ft-
POTENTIAL
EXPOSURE
POINT
LEGEND
MIGRATION PATHWAY
INFERRED
SOURCE
AREA
North Parking Lot
Inferred Source of
Western Plume
Groundwater
Flow Direction
Clay
Silry Sand
- Groundwater Level
Groundwater Flow Direction
Projected Concentrations of Total
VOCs in Groundwater((ig/L)
Not to Scale
i'Doscn/a-a'
-------
B
South
FIGURE 4
BENDIX SUPERFUND SITE B'
ST JOSEPH, MI North
-~1000ft-
Loading Dock Area
Former South Lagoon
Source Material
INFERRED
SOURCE
AREA
-~2000f1-
MIGRATION PATHWAY
LEGEND
•100-
- Groundwater Level
Groundwater Flow Direction
Projected Concentrations of Total
VOCs in Groundwater (pg/L)
Not to Scale
POTENTIAL
EXPOSURE
POINT
\/ Inferred Source
Material
m/DOScrvo-b'
-------
Aerobic
VC + O2
VC + Ethene
COo ^> HoO
Figure 5
Example of Natural Attenuation
Record of Decision
Bendix/St. Joseph Site
St. Joseph, Michigan
WOODARD&O^BIN I
-------
APPENDIX A
MDEQ LETTER OF CONCURRENCE
-------
STATE OF MICHIGAN
JOHN ENGLER, Govwnor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOLLISTER BUN.OINO, PO BOX 30473. LANSING Ml 4*800-7873
IMTERNET: Mtp^/www.dcq.mu.mi.u*
RUSWBJ. J. HAMOMO, doctor
October 20, 1997
Mr. William E. Muno, Director, Superfund Division
U.S. Environmental Protection Agency
Region 5
77 West Jackson Boulevard, S-6J
Chicago, Illinois 60604-3590
Dear Mr. Muno:
SUBJECT: Concurrence with the Record of Decision (ROD) for the Bendix Superfund Site
We are in receipt of the September 30, 1997 Record of Decision for the Bendix Superfund Site in
St. Joseph, Michigan. The Michigan Department of Environmental Quality (MDEQ) concurs
with the ROD. We expect that when the remedy is implemented, the groundwater monitoring
system and all necessary groundwater use controls will comply with all applicable state
requirements.
If you have any questions, please feel free to contact Ms. Claudia Kerbawy, Chief of the
Superfund Section, Environmental Response Division, at 5 17-335-3397, or you may contact me.
Sincerely,
Russell J. Harding
Director
517-373-7917
cc: Mr. David Ullrich, EPA
Mr. Alan J. Howard, MDEQ
Mr. Claudia Kerbawy, MDEQ
Dr. George Carpenter, MDEQ
Mr. William Harmon, MDEQ
EOP0100*
(R«v. 1UW)
-------
APPENDIX B
ADMINISTRATIVE RECORD INDEX
AND
LOCATIONS
REPOSITORIES:
LINCOLN TOWNSHIP PUBLIC LIBRARY
2099 WEST JOHN BEERS ROAD
STEVENS VILLE, MICHIGAN 49127
MAUD PRESTON PALENSKE MEMORIAL LIBRARY
(ST. JOSEPH PUBLIC LIBRARY)
500 MARKET STREET
ST. JOSEPH, MICHIGAN 49085
-------
riff ID.
II/IJ/M
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uuiifnirifi iieeu inu
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focuur mi Mcinm
it
5tit«Nit tt
Itt Ciiltetiif i
II/M it tftt
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11 !>/«!/«
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tli lutflf Citftntln
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litmtlrc ft. Itttfk,
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tttjttt flu ttt
urn it uiiff-
fifiij, lie,, Ititlt
litiMtlri Iriti ffitiu
ft.
litliurlif-feJitei,
lie. (If;
Itftrti/ttt4ln 14
«J IJ/17/ll
rirt flu /or
IJ/fJ • ft. ;»ffl, II
fifiiwlif-felMc*
M
-------
tilt 10.
99/93/99
MCWI inn
miii cMMimci siri
ir. mm, uciicii
imucrs0m
rmi
mm
iicirinr
wcimr rrw
Irite
4ierlei, St.
lartl
, HI
Raw Data and Saapling Data have not been copied, but are
available for review at the U.S.EPA Region V, Chicago, IL.
-------
tift JO. 1
CI1MICI Ifllf
mil; cfliMiirjoi sin
tiiduce locueitf ttt trtlltblt ttt reriei it
HIM lefloi f-Cllcifo li
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luirdoit lute Sitei ui
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li*/liil«ff/CcrriJJliI«
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Sroiai-titer
Iirc(10u,etil./Jt It. liter IS/0f/ll
Strrer '
) CIICW
Otter lariroaieotil
Stitatei
Protocol for Croud-
liter Irilutjooi
i|t< (ulitf Objtctint
V ttitiiil leipoite
uetlritleti Pcrelopieit
ttocett
ttiinet for Coadictiif
leietfiil
iod Penibilitr
ooder CIICU
toner. J./OSm
IS/ll/l?
lie. lute Croutfliter fn* K/I9/I1
force
CM federal frofriu
17/IJ/fl
osm/em
a
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
BBHDIX CORPORATION SITE
ST. JOSEPH, BBRRIBN COUNTY, MICHIGAN
UPDATE 41
AUGUST 12, 1997
NO.
1
2
DATE
00/00/00
00/00/00
AUTHOR
Weaver, J. ,
et al; U.S.
EPA/NRMRL
Weaver, J. ,
et al; U.S.
EPA/NRMRL
RECIPIENT
U.S. EPA
U.S. EPA
06/13/86
01/00/90
01/00/90
03/19/90
10/00/90
10/00/90
Keck Consulting 'U.S. EPA
Services, Inc.
12/13/91
Engineering-
Science, Inc.
Engineering-
Science, Inc.
Beebe, S. ,
MDNR
Engineering-
Science, Inc.
Engineering-
Science, Inc.
Dykstra, M.,
All-ied-Signal,
Inc.
U.S. EPA
U.S. EPA
Whittaker, K.,
Engineering-
Science, Inc.
U.S. EPA
U.S. EPA
Kuhns, J.
U.S. EPA
TITLE/DESCRIPTION PAGES
Paper: "Case Study of 4
Natural Attenuation of
Trichloroethene at St.
Joseph, Michigan"
Paper: "Extraction of 5
Degradation Rate Constants
from the St.. Joseph,
Michigan, Trichloroethene
Site"
Hydrogeologic Study 310
Final Investigation for
the Bendix Site
Technical Memorandum: 51
Clay Surface Mapping and
Screened Auger Results
for the Bendix RI/FS
Technical Memorandum in 53
Support of the RI/FS for
the Bendix Site
Letter Forwarding 75
Attached Information
Concerning Michigan ARARs
for the Bendix Site
Phase I Technical 168
Memorandum for the RI/FS
at the Bendix Site
Work Plan Addendum for 111
Phase II Remedial Inves-
tigation Activities at
the Bendix Brake Systems
Site
Letter re: Groundwater 10
Investigation Historical
Summary at the Bendix
Site
-------
Bendix AR
Update #lj
Page 2*
HO. PATH
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
10
05/06/92
Semprini, L.,
et al.
U.S. EPA
11
05/26/92
Willard, C., Wilson, D.,
and K. Whitaker; Allied Signal-
Engineering- Bendix
Science, Inc.
12
08/00/92
McCarty, P.,
Stanford
University and
J. Wilson,
U.S. EPA
13 12/00/92 Engineering-
Science, Inc.
14 04/00/93 Engineering-
Science, Inc.
15 05/00/93 U.S. EPA/
ORD
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
16
10/00/93
Engineering-
Science, Inc.
U.S. EPA
Paper: "Design and 12
Treatability of In Situ
Bioremediation of
Chlorinated Aliphatics
by Methanotrophs at
St. Joseph, Michigan"
(U.S. EPA: Symposium on
Bioremediation of
Hazardous Wastes, May
5-6, 1992)
Letter re: Results of 23
Investigation Aquifer
Characterization Study
Phase II In-Situ Bio-
remediation Testing at
the St. Joseph Plant
Paper: "Natural 5
Anaerobic Treatment of a
TCE Plume at the St.
Joseph, Michigan, NPL
Site" (U.S. EPA: Bio-
remediation of Hazardous
Wastes [EPA/600/R-92/
126])
An Evaluation of the 164
Closed Maiden Lane
Landfill Site
Final Phase II Work 335
Plan for the RI/FS at
the Bendix Site
Abstract: "Natural 5
Anaerobic Bioremediation
of TCE at the St. Joseph,
Michigan, Superfund Site"
(Kitanidis, P., et al;
Symposium on Bioremedia-
tion of Hazardous Wastes:
Research, Development,
and Field Evaluations,
May 4-6, 1993)
Phase IIA Technical 79
Memorandum for the RI/FS
at the Bendix Site
-------
Bendix AR
Update #1
Page 3
NO. DATB
AUTHOR
RECIPIENT
TITLB/DBSCRIPTION
PAGRS
17 04/18/94
18 03/27/95
19 04/00/95
20
08/00/95
Wilson, J.,
U.S. EPA/
RSKERL
Wilson, J.,
U.S. EPA/
RSKERL
Semprini, L.,
et al.
Kuhns, J.,
U.S. EPA
Weaver, J.,
et al. ;
U.S. EPA/
NRMRL
21 09/00/95 Woodard &
Curran
22 09/00/95 Woodard &
Curran
23 09/00/95 Woodard &
Curran
24 00/00/96 Weaver, J.,
et al; U.S.
EPA
Kuhns, J.,
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
FAX Transmission 7
Forwarding Attached Paper:
"Intrinsic Bioremediation
of TCE in Ground Water at
an NPL Site in St. Joseph,
Michigan" (Wilson, J., et
al.)
Letter Forwarding 54
Attached Information re:
Intrinsic Bioremediation
Journal Article: 12
"Anaerobic Transformation
of Chlorinated Aliphatic
Hydrocarbons in a Sand
Aquifer Based on Spatial
Chemical Distributions"
(Water Resources Research)
Project Summary: "Natural 4
Bioattenuation of Tri-
chloroethene at the St.
Joseph, Michigan, Superfund
Site" (EPA/600/SV-95/001)
Phase IIB Technical 72
Memorandum for the Bendix
Site (FINAL)
Phase IIC Technical 55
Memorandum for the Bendix
Site
Surface Water and 35
Sediment Sampling Plan
for the Bendix Site
Excerpt: "Field-Derived 12
Transformation Rates for
Modeling Natural Bio-
attenuation of Trichloro-
ethene and its Degradation
Products" (Delic, G. and
M. Wheeler: Next Generation
Environmental Models and
Computational Methods,
Chapter 20)
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Bendix AR
Update #1,
Page 4|
MO. DATS
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
25 04/00/96 U.S. EPA/
OSHER
26
27
32
09/00/96
10/00/96
07/24/97
Woodard &
Curran
U.S. EPA/
OSWER
28 05/01/97 Adriaens, P.,
et al.
29 07/00/97 Woodard &
Curran
30 07/00/97 Woodard &
Curran
31 07/00/97 Woodard &
Curran
Kerr, G.,
Bosch Braking
Systems
Corporation
Public
U.S. EPA
Public
U.S. EPA
U.S. EPA
U.S. EPA
Glatz, K.,
U.S. EPA
Technology Fact Sheet: ' 4
"A Citizen's Guide to
Bioretnediation" (EPA-
542-F-96-007)
Surface Water and 246
Sediment Sampling Report
for the Bendix Site
Technology Fact Sheet: 4
"A Citizen's Guide to
Natural Attenuation"
(EPA-542-F-96-015)
Excerpt: "Biogeochemistry 7
and Dechlorination Potential
at the St. Joseph Aquifer-
Lake Michigan Interface"
(In Situ and On-Site
Bioremediation Symposium.-
April 28 - May 1, 1997)
Feasibility Study 448
Report for Bosch Braking
Systems (FINAL)
Remedial Investigation 253
Report for Bosch Braking
Systems: Volume 1 (Text,
Tables and Figures)
[FINAL]
Remedial Investigation 262
Report for Bosch Braking
Systems: Volume 2
(Appendices A-H) [FINAL]
Letter Forwarding 14
Attached Revised Pages to
the Surface Water and
Sediment Sampling Report
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
BENDIX CORPORATION SITE
ST. JOSEPH, BBRRIEN COUNTY, MICHIGAN
UPDATE #2
SEPTEMBER 25, 1997
NO. DATE
1 08/00/97
2 OB/20/97
3 09/03/97
4 09/08/97
5 09/10/97
AUTHOR
U.S. EPA
O'Brien 6
Bails
Berrien
County, Ohio
Berrien
County, Ohio
Kerr, G.,
Bosch Braking
Systems
Corporation
RECIPIENT
Public
U.S. EPA
U.S. EPA
U.S. EPA
Glatz, K.,
U.S. EPA
TITLE/DESCRIPTION PAGES
Proposed Plan for the 13
Bendix/Bosch Braking
Systems Site
Transcript of August 59
20, 1997 U.S. EPA
Public Meeting re: the
Allied Signal/Bosch
Contamination Site
Berrien County Private 5
and Type III Public
Ground Water Supply
Ordinance (UNSIGNED)
Berrien County Water 6
Ordinance: Water Supply
System No. 2 Operation
Letter re: Bosch's 3
Response to U.S. EPA's
Proposed Plan for the
Bendix Site
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APPENDIX C
RESPONSIVENESS SUMMARY
OVERVIEW
The public participation requirements of CERCLA sections 113 (k) (2) (i-v) and 117 of CERCLA
have been met during the remedy selectiofl process. Section 113 (k) (2) (B) (iv) and 117 (b) of
CERCLA require the U.S. EPA to respond "...to each of the significant comments, criticisms, and
new data submitted in written or oral presentations" on a proposed plan for a remedial action. The
Responsiveness Summary addresses concerns expressed by the public, potentially responsible
parties, and governmental bodies in written and oral comments received by U.S. EPA and MDEQ
regarding the proposed remedy for the Bendix Superfund Site.
BACKGROUND OF COMMUNITY INVOLVEMENT
Community involvement was initiated when the Bendix Site was placed on the NPL in February
1990. The following is a chronology of community relations activities to date:
U.S. EPA met with several local residents, the Berrien County Commissioner, and a representative
from the County Health Department to identify community concerns and interests Regarding the
Bendix Site (January 1990).
Community Relations Plan (CRP) was prepared based on concerns and interests generated from
community interviews (August 1990).
U.S. EPA published two Public Meeting notices in the Herald Palladium to discuss site
investigations and to announce the meeting.
A Fact Sheet was distributed to inform the community about the Public Meeting, provide
background on the Bendix Site, and provide information on proposed Phase I RI activities (February
1990).
A Public Meeting was held on February 8, 1990 at the Lincoln Township Hall in Stevensville to
explain the RI/FS process, discuss proposed Bendix Site investigations, and to receive comments
and questions from the public regarding the Bendix Site. U.S. EPA also announced to the public
the availability of the Administrative Record. Locations of the Information Repositories are listed
below (February 1990).
Announcement was placed in the Herald Palladium that the Bendix facility had been added to the
NPL (February 1990).
MDNR released Progress Report # 1 to keep area residents and other interested persons informed
of progress, findings, and proposed activities for the Bendix Site (March 1990).
MDNR met with residents at the St. Joseph Township Hall to discuss community concerns
associated with the foundry emissions at the facility (not related to the site Superfund process)
(March 1990).
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A Fact Sheet was distributed to inform the community of Phase I RI results and to describe Phase
II activities (August 1991).
The RI, FS, and Proposed Plan for the Bendix Site were released to the public on August 12, 1997.
The public comment period was held from August 13, 1997 to September 12, 1997. Comments
received during this period and U.S. EPA's responses to those comments are included in this
Responsiveness Summary (September 1997).
A Public Meeting was held on August 20, 1997 to discuss the FS and Proposed Plan.
Representatives from U.S. EPA and MDEQ answered questions about the Bendix Site and the
proposed remedial alternative. A transcript of this public meeting has been placed in the
Administrative Record. Written comments were also accepted at the meeting. Approximately 35
people attended, including local residents and Bosch representatives.
RESPONSE TO COMMENTS
Two concerns were advanced during the .Comment Period. Ms. Cathy Knauf, a resident near the
Western Plume, is concerned about the long term safety of her children, should the ground water
plume pattern change over time and vent contaminants at the beach, where her children may be
exposed. It was explained that the Monitoring phase of the remedy will detect changes in ground
water concentrations and flow patterns, and would provide adequate warning of changes in the
plume pattern. The results of these Monitoring events will be placed in both Repositories. Ms.
Knauf felt she may not be aware of the Monitoring events and requested that the results of all
Monitoring events be sent to her. The Statement of Work will include a provision that a copy of
all Monitoring results will be sent to Ms. Cathy Knauf at her present address.
Mr. Jim Scholz, also a resident on the south edge of the western plume, expressed concern that his
water rights would be compromised by the deed restrictions placed on the use of ground water near
the plume, and that he would not be able to place a well in this aquifer until the Remedy had been
complete. In consideration of this concern, current Berrien County regulations require that a permit
be acquired to install a well on the property of any Berrien County resident. The Berrien County
policy is to deny a well permit to any resident currently on the St. Joseph Municipal Water System.
Mr Scholz is on the St. Joseph System. However, should the regulation change, and Mr Scholz
installs a well on his property, Bosch would be required to test this well on an annual basis until the
ground water remedy is complete. This is consistent with the residential well monitoring program
that will be included in the Statement of Work (SOW) for private wells near the plume. A copy of
the pertinent Berrien County regulations have been placed in the Administrative Record and the
repositories.
Response to Bosch Letter of September 10, 1997. U.S. EPA appreciates Bosch's support of the
selected remedy. Bosch takes exception to the phrase "more restrictive" in setting the POC
monitoring value for the plumes. Bosch suggests that the ground water contaminant concentrations
can increase at the POC without necessarily exceeding the GSI values, and therefore should not
trigger contingency considerations specified in the ROD. The following explanation justifies the
"more restrictive" wording used in the ROD to identify the ground water compliance criteria. The
plumes represent unique situations, since they discharge to surface water bodies thus creating the
GSI condition. There are three requirements that must be satisfied to allow and set Alternate
Concentration Limits (ACLs) as calculated using GSI numbers. They are: a) the condition of the
ground water plume cannot further deteriorate: b). deed restrictions must be in place to control the
use of the ground water during the remedy; and c) the ground water plume must be discharging to
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a surface water body. For reason a) above, the phrase "the more restrictive" as used in the ROD to
characterize the baseline conditions to evaluate the progress, or lack of progress, of the restoration
of the contaminated ground water plumes, is justified, and will be retained in the ROD. The details
of establishing progress toward aquifer restoration will be developed in the Long Range Monitoring
Plan in the Statement of Work. In principal it will consist of mathematically evaluating the
monitoring data as it is acquired, and establishing the trend (improving or deteriorating) of the
ground water quality. The individual contaminants, as well as the cumulative risk posed by these
contaminants, will be evaluated. Least square fit and linear regression analysis are two mathematical
approaches that can be used to show trends. The monitoring schedule will set the base period for
establishing trends from the baseline contaminant values, This approach is consistent with GSI ACL
principles and with the NCP policy requiring that a remedy restore an aquifer to its most beneficial
use in a reasonable time frame. The wording used in the ROD is consistent with these policies.
A copy of Bosch's letter has been included in the Administrative Record, and in the repositories.
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LIST OF ACRONYMS
1,1-DC A 1,1-dichloroethane
1,1-DCE 1,1-dichloroethene
1,2-DCE 1,2-dichloroethene
1,1,1-TCA 1,1,1-trichloroethane
1,1,2-TCA 1,1,2-Trichloroethane
ARAR Applicable or Relevant and Appropriate Requirement
AWQC ambient water quality criterion
Bosch Bosch Braking System
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
cis-1,2-DCE cis-l,2-dichloroethylene
CPC Compound of Potential Concern
cm/sec centimeter/second
DNAPL Dense Non Aqueous Phase Liquid
EPC exposure point concentration
ER-L Effective Range-Low
FS Feasibility Study
GSI ground water/surface interface
HA Health Advisory
HEAST Health Effects Assessment Summary Tables
HI Hazard Index
IRIS Integrated Risk Information System
K hydraulic conductivity
Keck Keck Consulting Services Inc.
MCL maximum contaminant level
MCLG Maximum Contaminant Level Goal
MDEQ Michigan Department of Environmental Quality
MDNR Michigan Department of Natural Resources
MGS Michigan Geologic Survey
MSL mean sea level
NAPL non-aqueous phase liquid
NCP National Contingency Plan
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LIST OF ACRONYMS
(continued)
NPL National Priorities List
NOAA National Oceanic and Atmospheric Administration
POC Point of Compliance
POTW Publicly Owned Treatment Works
PRG Preliminary Remediation Goal
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
SVE soil vapor extraction
TCE trichloroethylene
Trans-1,2-
DCE trans-1,2-dichloroethylene
A^g/L micrograms per liter
U.S. EPA United States Environmental Protection Agency
VOCs volatile organic compounds
W&C Woodard & Curran
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LIST OF REFERENCES
Keck Consulting Services, Inc., 1986. "Hydrogeologic Study: Final Investigations"; June 1986.
Michigan Department of Environmental Quality, 1997. "Part 201 Generic Soil Inhalation Criteria for
Ambient Air: Technical Support Document." April 1997.
Michigan Department of Environmental Quality, 19965. "Interim Environmental Response Division
Operational Memorandum #17: Instructions for Obtaining Determinations on Mixing Zone-
Based Ground Water Surface Water Interface Criteria for Inclusion in Remedial Action Plans
and Monitoring Compliance with Criteria for Discharges of Ground Water Contaminants to
Surface Water"; April 12, 1996.
Michigan Department of Natural Resources, 1995a. "Interim Environmental Response Division
Operational Memorandum #8, Revision 4: Generic Residential Cleanup Criteria"; June 8,
1995
Michigan Department of Natural Resources, 1995b. "Interim Environmental Response Division
Operational Memorandum #14 Revision 2: Remedial Action Plans Using Generic Industrial
or Generic Commercial Cleanup Criteria and Other Requirements"; June 1995.
National Oceanic and Atmospheric Administration, 1994. NOAA Screening Guidelines. Hazmat
Report 94-8, U. S. Department of Commerce, NOAA, Coastal Resources Coordination
Branch, Seattle, WA.
State of Michigan Geologic Survey, 1988. "The Glacial Lakes Around Michigan", Bulletin 4, W.R.
Farrand, University of Michigan.
U.S. Department of Commerce, National Oceanic and Atmospheric Administration, 1994. "NOAA
Screening Guidelines for Inorganics."
U.S. EPA, 1986. "Quality Criteria for Water", Office of Water Regulations and Standards;
Washington, D.C.; May 1986.
U.S. EPA, 1988d. "Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA"; Office of Solid Waste and Energy Response; Washington, D.C.; October 1988.
U.S. Environmental Protection Agency, 1989. Office of Emergency and Remedial Response.
Interim Final Guidance on Preparing Superfund Decision Documents (OSWER Directive
9355.3-02). July 1989.
U.S. EPA, 1989a. "Risk Assessment Guidance for Superfund: Volume I Human Health Evaluation".
U.S. EPA, 1989b. "Risk Assessment Guidance for Superfund: Volume II Environmental Evaluation
Manual"; March 1989.
U.S. EPA, 1990. "National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule",
55FR8666; March 8, 1990.
U.S. EPA, 1991a. "Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation
Manual, Supplemental Guidance, Standard Default Exposure Factors"; March 25, 1991.
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U.S. EPA, 1992b. "Framework for Ecological Risk Assessment"; February 1992.
U.S. EPA, 1994a. "Health Effects Assessment Summary Tables (HEAST)"; March 1994.
U.S. EPA, 1995a. "Integrated Risk Information System (IRIS)"; July 1, 1995.
U.S. EPA, 1996. "Drinking Water Regulations and Health Advisories"; February 1996.
Wilson,'Barbara H., John T. Wilson, and Darryl Luce, 1996. "Design and Interpretation of
Microcosm Studies for Chlorinated Compounds"; Conference Proceedings from Symposium
on Natural Attenuation of Chlorinated organics in Ground Water, Dallas, TX, September 11-
13,1996;' EPA/540/R-96/509; September 1996.
Woodard & Curran, 1995. "Final Phase IIB Technical Memorandum"; September 1995.
Woodard & Curran, 1997a Final Remedial Investigation Report"; January 1997
Woodard & Curran, 1997b. Final Feasibility Study Report, July 1997.
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