PB98-964110
EPA 541-R98-098
November 1998
EPA Superfund
Record of Decision:
Allied Paper/Portage Creek/
Kalamazoo River OU 3
Kalamazoo, MI
2/10/1998
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UNITED STATES ENVIRONMENTAL PHUIkCIION AGENCY
I REGION 5
§ \^i7Z ? 77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
FEB 1 0 1998
REPLY TO THE ATTENTION OF:
R-19J
Russell J. Harding, Director
Michigan Department of Environmental Quality
P.O. Box 30473
Lansing, Michigan 48909-7973
Dear Mr. Harding
I am pleased to send you the executed signature page for the King Highway Landfill Record of
Decision (ROD). I would like to thank you and your staff for the tremendous effort involved in
developing this document, which represents a significant step in addressing contamination at the
Allied Paper/Portage Creek/Kalamazoo River Superfund Site.
As you are aware, in order to concur with the remedy decision of this ROD, U.S. EPA was
required to grant a waiver under the Toxic Substances Control Act (TSCA). Because U.S. EPA
believes strongly that all of TSCA's requirements for chemical waste landfills are usually
required to ensure adequate protection of human health and the environment, such waivers are
rare. In order to verify that, as designed and constructed, the remedy selected for the KHL
operable unit "will not present an unreasonable risk of injury to health or the environment from
PCBs"~a determination required by TSCA—I am requesting that the following documents be
submitted for review and approval by the Region V Toxics Program Section before
implementation by the responsible parties:
sampling and monitoring plan or plans;
design plans for flood protection and erosion control;
design plans for excavation, consolidation and de water ing; and
operation and maintenance plans.
U.S. EPA staff will ensure thorough and timely review of these documents.
We look forward to working with your Agency in the future to further address the problems at
the Allied Paper/Portage Creek/Kalamazoo River Superfund Site. /
Sincerely yours,
L. Ullrich
ij Acting Regional Administrator
R«cycl*d/Recyclable • Printed with Vegetable Ol Based Inks on 1OO% Recycled Paper (4O% Postconsumer)
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DECLARATION
SELECTED REMEDIAL ALTERNATIVE
FOR THE KING HIGHWAY LANDFILL - OPERABLE UNIT 3 OF THE ALLIED PAPER,
INC./PORTAGE CREEK/KALAMAZOO RIVER SUPERFUND SITE
CITY OF KALAMAZOO, MICHIGAN
Statement of Basis and Purpose
This decision document presents the selected remedial action (RA) for the King Highway Landfill-
Operable Unit 3 (KHL-OU 3) and the Georgia-Pacific former lagoons 1, 2, 3, 4, and 5, (five
former lagoons) of the Allied Paper, Inc./Portage Creek/Kalamazoo River Superfund site (site).
The KHL-OU 3 includes the King Highway Landfill (KHL), the King Street Storm Sewer (KSSS)
floodplain, and the stretch of the. Kalamazoo River adjacent to the KHL. The KHLr-OU 3 and the
five former lagoons are located in the city of Kalamazoo, Michigan. The remedy was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), 1980 PL 96-510, as amended by the Superfund Amendments and Reauthorization
Act of 1986 and, to the extent practicable, the National Oil and Hazardous Substances
Contingency Plan. This Record of Decision (ROD) addresses the five former lagoons and the
KHL-OU 3 which is one of four Operable Units at the site. This decision is based on the
administrative record for the KHL-OU 3 and the five former lagoons.
Assessment of.the Site
Actual or threatened release of hazardous substances from the KHL-OU 3 and the five former
lagoons, if not addressed by implementing the response action in this ROD, may present an
imminent and substantial endangerment to public health, welfare, or the environment.
Description of the Selected Remedy
This remedy is intended to be the final action for the five former lagoons and the KHL-OU 3 of
the site. The purpose of this remedy is to eliminate or reduce the potential migration of
polychlorinated biphenyls (PCBs) to the Kalamazoo River and to reduce the risk associated with
exposure to the PCB-contaminated materials. This RA includes excavation and on-site
containment of PCB-contaminated soils, sediments and paper residuals (residuals) from the
landfill berms (berms), the five former lagoons, as well as from the river and floodplains adjacent
to the KHL. This RA will address the principal threat posed by the five former lagoons and the
KHL-OU 3 by controlling the current and potential release of PCB contaminatic- to the
Kalamazoo River. The RA addresses the following migration pathways from the KHL-OU 3 and
the five former lagoons: release of leachate to groundwater, surface water, and surface
sediments; and the release of PCB-contaminated residuals/soils to surface water by erosion,
surface run-off, and berm failure.
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The major components of the selected remedy include:
Excavation of PCB-contaminated soils, sediments, and residuals from the berms, the KSSS
floodplain, the five former lagoons, and the Kalamazoo River directly adjacent to the KHL.
Excavated soils, sediments, and residuals containing PCBs will be consolidated in Cell 4 of the
KHL prior to construction of the cover.
The construction of a cover (cap) over the landfill will minimize infiltration of precipitation
through the landfill and prevent potential migration of PCB from the landfill into the Kalamazoo
River. The cap will also prevent exposure to the PCBs. The cap is designed to meet the
Michigan Solid Waste Landfill closure regulations pursuant to Part 115, Solid Waste
Management, of the Michigan Natural Resources and Environmental Protection Act, 1994
PA 451, as amended (NREPA). The cap consists of the following components from bottom to
top:
i
• At least a six-inch thick, select granular fill, gas venting layer will be placed on top of the
residuals. This gas venting layer is designed to collect landfill gas and route it to the passive
venting system. Select granular fill from an off-site source, having a minimum hydraulic
conductivity of 1 x 10"3 centimeters per second, will be used to construct the layer. The gas /
venting system will consist of 19 passive gas vents placed in the select granular fill. Excessive
gas generation is not anticipated due to the type and age of the residuals.
• At least a 30-mil thick polyvinyl chloride (PVC) geomembrane liner (barrier layer) will be
placed over the select granular fill. The PVC geomembrane liner will act as a barrier to
minimize infiltration of precipitation into the residuals.
• At least a 24-inch thick general fill layer (protective layer) will be placed above the 30-mil
PVC geomembrane liner. The protective layer will be capable of sustaining the growth of
non-woody plants, will have adequate water holding capacity, and will be sufficiently thick to
allow for erosion losses. The water that accumulates within this layer will drain to a ditch or a
sedimentation outlet structure and subsequently discharge into the Kalamazoo River.
• At least a six-inch thick vegetative layer (erosion layer) will be placed over the protective
layer. The erosion layer has been designed to promote vegetative growth, provide surface
water runoff, and minimize erosion.
• Erosion protection will be placed on the berms of the landfill. This protection will be
sufficient to protect the berms from a 100-year flood event. Part of this erosion protection
will be provided by a steel sheet piling stabilization wall present between the Kalamazoo River
and the berms of Cells 1 and 2. This wall extends 1020 feet and is located on the north side of
the landfill. It extends from the most northern point of Cell 1, southeast along the perimeter
of Cells 1 and 2, to the junction where the corners of Cells 2, 3, and 4 meet.
• Groundwater monitoring wells will be installed and wells that are no longer needed will be
abandoned.
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• Groundwater and surface water monitoring shall be performed for at least 30 years following
landfill capping. Monitoring of the groundwater aquifer under the landfill will be conducted in
accordance with Parts 1 15, Solid Waste Management, and 201, Environmental Remediation,
of the NREPA, and TSCA (761 .75(b)(6)) at a minimum. Monitoring of the surface water and
sediments will be conducted in accordance with TSCA (761.75(b)(6)) at a minimum to assess
the effectiveness of the remedy.
• Deed restrictions limiting future land use will be imposed at the KHL-OU 3.
• Access restrictions, including enclosing the entire KHL-OU 3 and the five former lagoons
with a fence, will be implemented.
• A permanent marker will be placed at the KHL-OU 3 and warning signs will be posted on the
fence every 500 feet and on all entry gates.
Statutory Determination
The Michigan Department of Environmental Quality (MDEQ) has concluded that the selected RA
is protective of human health and the environment. The United States Environmental Protection
Agency (EPA), through its concurrence with this ROD, agrees with the MDEQ's conclusion. The
selected RA complies with federal and state requirements that are legally applicable or relevant and
appropriate to the RA. Through this concurrence with this ROD, the Regional Administrator of
the EPA has determined that a waiver of certain chemical waste landfill requirements under the
Toxic Substances Control Act is appropriate for the RA selected in this ROD. This remedy utilizes
permanent solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable for the KHL-OU 3 and five former lagoons. This remedy does not
satisfy the statutory preference for remedies that reduce the toxicity, mobility, or volume as a
principal element because treatment of the principal threats of the KHL-OU 3 was not found to be
practicable.
A review will be conducted within five years after commencement of the RA to ensure that the
remedy continues to provide adequate protection of human health and the environment because
this remedy will result in hazardous substances remaining on-site above health-based levels.
David jtflfrich^Acting Regional Administrator Date
UniteoStates Environmental Protection Agency
Russell J. Harding^ Director ] Date
Michigan Department of EnvironmentaljQaality
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TABLE OF CONTENTS
PAGE
I. DECISION SUMMARY 1
A. Site Location and Description 1
B. Site History and Enforcement Activities 3
C. Community Participation 6
D. Scope and Role of the Operable Unit Within Site Strategy 6
E. Summary of Site Characteristics 7
F. Summary of Site Risks 8
1. Human Health Risks 9
2. Environmental Risks . 11
G. Description of Alternatives 14
H. Summary of Comparative Analysis of Alternatives 16
1. Threshold Criteria 16
a. Overall Protection of Human Health and the Environment... 16
b. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) 17
2. Primary Balancing Criteria 19
c. Long-term Effectiveness and Permanence 19
d. Reduction of Toxicity, Mobility, or Volume
Through Treatment 20
e. Short-term Effectiveness 20
f. Implementability 21
g. Cost 22
3. Modifying Criteria 22
h. Support Agency Acceptance 22
i. Community Acceptance 22
I. The Selected Remedy 22
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TABLE OF CONTENTS (continued)
PAGE
1. Cap 22
2. Erosion Protection 23
3. Installation of Groundwater Monitoring System 24
4. Long-term Monitoring 24
5. Consolidation 24
6. Institutional Controls-Fencing 24
7. Posting and Permanent Marker 24
8. Deed Restrictions..... *. 25
9. Long-Term Maintenance 25
10. Financial Assurance Mechanisms 25
11. Other Provisions ! 25
12. Five Year Review 25
13. Significant Modifications to the 1994 Proposed Plan 25
a. Changing Gabions to Steel Sheet Pilings 25
b. Remediation of Cell 4 r. 26
c. Consolidation of PCB-contaminated Residuals, Soils,
and Sediments 26
J. Statutory Determinations 26
1. Protection of Human Health and the Environment 27
2. Compliance with ARARs 28
a. Chemical-Specific ARARs 28
b. Location-Specific ARARs 30
c. Action-Specific ARARs.... 30
3. Cost-Effectiveness 33
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable 33
5. Preference for Treatment as a Principal Element 33
K. Summary 34
L. Responsiveness Summary 34
Attachment 1 48
Figure 1
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I. DECISION SUMMARY
A. SITE LOCATION AND DESCRIPTION
The King Highway Landfill-Operable Unit 3 (KHL-OU 3) and the Georgia-Pacific
former lagoons 1, 2, 3,4, and 5 (five former lagoons) of the Allied Paper, Inc./Portage
Creek/Kalamazoo River Superfund site (site) are the subject of this Record of Decision
(ROD). The King Highway Landfill (KHL), the King Street Storm Sewer (KSSS)
floodplain, and the adjacent Kalamazoo River are included in the KHL-OU 3. The site is
located in Kalamazoo and Allegan Counties, Michigan. The site includes three miles of
Portage Creek, from Cork Street to its confluence with*the Kalamazoo River, and 80
miles of the Kalamazoo River, from Morrow Lake Dam downstream to Lake Michigan.
Also included in the site are five paper residual disposal areas and five paper mill
properties. Paper residuals (residuals) are the waste material produced by the paper mill
during the paper making process. The five disposal areas have been organized into the
following four Operable Units (OUs) of this site:
OU 1: Allied Paper Property/Bryant Mill Pond
OU 2: Willow Boulevard/A-Site
OU 3: King Highway Landfill
OU4: 12th Street Landfill
The KHL-OU 3 is located in the city of Kalamazoo, Kalamazoo Township, Kalamazoo
County, Michigan. More specifically, it is located in the north half of the northeast
quarter of Section 23, Township 2S, Range 12W. The KHL-OU 3 is bordered
immediately on the south by King Highway (M-96), on the west by the Grand Trunk
Railroad right-of-way, and the KSSS floodplain, and by the Kalamazoo River on the
north and east sides. The five former lagoons are located on the Georgia-Pacific mill
property, directly north of the KHL-OU 3, across the Kalamazoo River (see Figure 1).
The Kalamazoo River flows in a westerly direction and is a major tributary to southern
Lake Michigan.
The soils, sediments, water column, and biota at the site are contaminated with
Polychlorinated Biphenyls (PCBs), a hazardous substance and probable human
carcinogen. Based on studies conducted between 1972 and 1989 it has been estimated
that there are well over 300,000 pounds of PCBs in the sediments and soils of, or adjacent
to, Portage Creek and the Kalamazoo River portions of this site. The KHL-CU 3 and the
five former lagoons are both locations which contain PCBs and are considered to be a
current ongoing source of PCBs to the Kalamazoo River. The PCBs continue to migrate
from the KHL-OU 3 and the five former lagoons into the environment and off-site due to
the erosion caused by river flow and surface water run-off. This contributes to the
ongoing contamination of the soils, sediments, water column, and biota of the site (i.e. the
Kalamazoo River) and Lake Michigan. The Michigan Department of Community Health
has issued a species specific no consumption fish advisory annually since 1977 for the
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Kalamazoo River portion of this site due to the PCB contamination. The Kalamazoo
River and Portage Creek have been designated a site of environmental contamination
under Part 201, Environmental Remediation, of the Natural Resources and Environmental
Protection Act, 1994 PA 451, as amended (NREPA), due to PCB contamination. The
Kalamazoo River and Portage Creek have been identified as an Area of Concern by the
International Joint Commission on the Great Lakes due to the detrimental impact the
release of PCBs have on Lake Michigan. Due to the PCB contamination, in August 1990
the site was placed on the National Priorities List (NPL) in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA),
1980 PL 96-510 as amended by the Superfund Amendments and Reauthorization Act
(SARA) of 1986 also known as Superfund.
t
The floodplains, wetlands, and river corridor of the Kalamazoo River and Portage Creek
provide habitat for numerous important fish and aquatic species, semi-aquatic species,
and terrestrial species. Species of special concern at the site are mink and bald eagles due
to their sensitivity to PCB contamination. The Kalamazoo River, downstream of the
KHL-OU 3 and the five former lagoons, flows through the Kalamazoo River Nature
Center and the Allegan State Game area. The river is a critical natural resource for
southwest Michigan providing recreational opportunities such as fishing, hunting,
trapping, bird watching, boating, and swimming.
The river also provides recreational opportunities for hiking and biking along the
extensive trail systems on the banks of the river. Plans have been made to extend the
river trail system along the area where the KHL-OU 3 is located. Residents and visitors
to the area enjoy wetland and woodland habitats which support numerous species of
plants, birds, reptiles, amphibians, and mammals.
The KHL was originally a series of lagoons used by the Kalamazoo Paper Company to
dewater the underflow of the paper mill's primary clarifier located on the north side of the
river. Prior to the construction of the King Highway lagoon system, this area consisted of
floodplains, wetlands, and a former oxbow of the Kalamazoo River. According to an
evaluation of the National Wetlands Inventory Maps during the Remedial Investigation
(RI), all the former wetlands within the landfill area have been eliminated by past
landfilling activities. The entire KHL-OU 3 is located in the 100-year floodplain of the
Kalamazoo River. However, the height of the KHL berms extend above the 100-year
flood elevation.
The land immediately adjacent to the south and southwest sides of the KHL-OU 3 is
classified for industrial or secondary commercial use. The Kalamazoo River and an
associated mix of non-forested shrub or central hardwood deciduous forested lands are
located directly east, north, and northwest of the KHL-OU 3. Across the Kalamazoo
River to the north lies the Georgia-Pacific Corporation, Kalamazoo Paper Mill and the
five former lagoons. The KHL-OU 3 is located east of Riverview Park, formerly
Sutherland Park, and Red Arrow Golf Course. South of the landfill, on the other side of
M-96, is a city of Kalamazoo salt storage facility and parking lot area for road work and
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snow removal equipment. Superior Metal Shredder, Inc./Superior Salvage Co./Superior
Industrial Waste Disposal Service lies to the southwest. In close proximity are two
residential neighborhoods located approximately 1,100 feet to the west in the city of
Kalamazoo and 1,200 feet to the southeast in Kalamazoo Township.
The KHL covers 23.2 acres and consists of four Cells. The total volume of residuals in
the KHL is estimated at 282,000 cubic yards. Cells 1, 2, and 3 were permitted under
Michigan Solid Waste regulations as a landfill and are nearly filled to capacity. These
Cells have a total area of 12.3 acres. Cell 4 covers 3.1 acres and contains 12,700 cubic
yards of residuals and is not filled to capacity. Cell 4 was never permitted as part of the
landfill. The majority of the residuals in Cell 4 are submerged in a pond formed by the
transport of water from the other three cells to Cell 4 through culverts in the dikes. The
four cells are separated by dikes approximately 10 to 20 feet high. These dikes were
constructed of sand and gravel in the 1950s. They have been "topped" with gravel and
are used as access roads. Access roads and non-fill area's compose 7.9 acres in the KHL.
In addition to the four Cells of the KHL, PCB-contaminated sediments, soils, and
residuals located on the berms, in the KSSS floodplain, in the Kalamazoo River directly
adjacent to the KHL, and in the five former lagoons at Georgia-Pacific Corporation are
addressed by this ROD (see Figure 1). The Kalamazoo River is located immediately
north and east, while the KSSS floodplain is located immediately to the west of the KHL.
The five former lagoons owned by Georgia-Pacific Corporation are located on the north
side of the Kalamazoo River next to the paper mill clarifier. These former lagoons were
used historically to dewater the underflow from the paper mill clarifier. The estimated
volumes of PCB-contaminated materials located in the KSSS floodplain and the five
former lagoons are 1,000 and 3,000 cubic yards, respectively. These areas contain PCB-
contaminated floodplain soils, sediments, and residuals that will be excavated and
consolidated into Cell 4 prior to the placement of the cap.
The geology immediately underlying the KHL is composed mostly of glacial sand and
gravel deposits with traces of clay and silt. These glacial deposits have been extensively
reworked by the Kalamazoo River. Bedrock, consisting of Coldwater Shale deposited in
the Mississippian period of the Paleozoic Era, lies approximately 50 to 70 feet below the
land surface. The RI indicates that there is a layer of clay, or sand and clay,
approximately 15 feet below ground surface.
Beneath the landfill, the direction of groundwater flow is normally north-to-northwest
toward the Kalamazoo River. The groundwatci horizontal gradient ranges f. jm 0.0014 to
0.0006 feet/feet. The gradient and flow direction are influenced by the Kalamazoo River.
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Carbonless copy paper manufactured between 1957 and 1971 contained Aroclor 1242
(A1242) as an ink carrier or solvent. The A1242 was used as a solvent for certain dyes
that were encapsulated in small spheres and applied to one side of the paper during the
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coating process. The walls of the spheres consisted of a gelatin-gum arabic formulation
which ruptured and released the dye when subject to pressure. The average A1242
content in a sheet of carbonless copy paper was 3.4 percent.
From 1957 to 1971 about 44,162,000 pounds of A1242 were used in the production of
carbonless copy paper across the country. This amount accounted for an estimated 28
percent of all the PCBs that the Monsanto Chemical Company (the sole domestic
producer of PCBs) sold for plasticizer applications during this period, and 6.3 percent
of Monsanto's total domestic PCB sales for those 15 years.
Approximately 19 percent of carbonless copy paper was recycled across the country in
1976 and a greater proportion may have been recycled in previous years. Assuming an
average recycling effort of 20 percent for this paper over the 15-year period when
PCBs were in carbonless copy paper, then recycled paper streams across the country
contained 20 percent of the 44 million pounds of PCBs* used in carbonless copy paper, a
total of some 8.8 million pounds of PCBs in recycled paper pulp and effluents over 15
years.
The PCBs in the carbonless copy paper that the Georgia-Pacific Corporation,
Kalamazoo Paper Mill deinked and repulped either became integrated into new paper
products or became part of the paper mill's waste stream. The process of deinking and
subsequent pulping of the recycled stock broke the spheres containing the PCB-laden
dyes in the paper. These PCBs were then distributed throughout the paper recycling
process, including the waste stream. However, some of the PCBs in the carbonless
copy paper remained in the recycled pulp and subsequently were incorporated into new
paper products. For example, PCB concentrations as high as 433 milligrams/kilogram
(mg/kg) were measured in paperboard used for cereal packaging in 1971. Although
PCB use in the manufacturing of carbonless copy paper was discontinued in 1971, the
paper recycled by the Georgia-Pacific Corporation, Kalamazoo Paper Mill likely
continued to contain PCBs for several years after 1971.
The Georgia-Pacific Corporation, Kalamazoo Paper Mill deinked office waste paper
which contained carbonless copy paper at two mills during the 15-year period when
PCBs were in the paper. Originally, the facility consisted of five mills, three for
making paper products, and two for finishing and converting. Mills 1 and 3 both
performed deinking operations starting in the early 1950s. Mill 3 discontinued
deinking in the late 1960s, was refurbished, and resumed operations in 1975. Mill 1
deinked continuously until the late 1970s. Raw paper waste from all the i.iills was
routed to a clarifier. The clarifier effluent was pumped directly into the Kalamazoo
River (i.e., the site) until 1964 when it was rerouted to the city of Kalamazoo
Wastewater Treatment Plant.
The underflow from the clarifier was dewatered and disposed of at various locations
over the years. From the mid-1950s until the late 1950s the residuals were placed in
the original five former lagoons next to the primary clarifier on the mill property. In
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the late 1950s residuals were sent to the King Highway lagoons, which later became the
KHL, on the south side of the Kalamazoo River for dewatering. The original five
dewatering lagoons were then used as an emergency backup system.
Georgia-Pacific Corporation dewatered residuals in the King Highway lagoons until
1977. Some of the dried residuals from the King Highway lagoons were excavated and
disposed of at the Willow Boulevard disposal area, another OU of the site, until 1975.
By 1975 the Willow Boulevard disposal area was filled to capacity, and Georgia-Pacific
Corporation purchased the A-Site disposal area, another OU of the site, from Allied
Paper, Inc. Some of the residuals from the King Highway lagoons were excavated and
disposed of at the A-Site disposal area. Georgia-Pacific Corporation used the A-Site
disposal area for disposal of residuals from 1975 untH 1987.
The King Highway lagoons were granted a landfill construction permit by the Michigan
Department of Environmental Quality (MDEQ) in Junfe 1982. The King Highway
lagoons became the KHL and Cells 1, 2 and 3 were first granted an operating permit by
the MDEQ in 1983 under what is now Part 115, Solid Waste Management, of the
NREPA as a solid waste landfill. It is still a licensed solid waste landfill. It should be
noted that although Cell 4 contains residuals, it was never licensed as a solid waste
landfill. Most of the residuals present in Cell 4 were disposed of by Georgia-Pacific
prior to Cells 1, 2, and 3 being licensed. However, some of the residuals were
transported to Cell 4 in storm water runoff from Cells 1,2, and 3. Starting again in
1987 Georgia-Pacific Corporation used the KHL for the disposal of dewatered
residuals. When active, the cells were being filled from west to east at a rate of about
150 cubic yards per day.
The MDEQ conducted a routine surface water and biota sampling of the Kalamazoo
River mouth during 1970. The results of this investigation indicated that the river was
discharging PCBs into Lake Michigan. During a biological survey conducted by the
MDEQ in 1971, pursuant to a Federal Water Pollution Control Agency program to
monitor tributaries of Lake Michigan, it was determined that PCBs in the Kalamazoo
River were continuing to discharge to Lake Michigan and were bioavailable.
Using the existing data for the site, the MDEQ scored the site following the CERCLA
Hazard Ranking System. The scoring package was proposed to the United States
Environmental Protection Agency (EPA) on May 5, 1989, and the site was nominated to
the NPL. On August 3, 1990 the site was officially placed on the NPL and was
designated a Superfund site.
The Potentially Responsible Party (PRP) search conducted in 1990 identified three PRPs
for the PCB contamination of this site. These three PRPs, HM Holdings, Inc./'Allied
Paper, Inc., Georgia-Pacific Corporation, and Simpson Plainwell Paper Company, were
notified of their status on June 23, 1990. More recent efforts on the part of the three
initial PRPs to determine other PRPs, have identified the James River Paper Corporation.
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Since 1994 the James River Corporation has participated as a PRP on this site. These
four parties have been identified as PRPs due to past paper mill operations involving the
recycling and deinking of office waste paper that included carbonless copy paper during
the period from 1957 to at least 1971. In accordance with Pan 31, Water Resources
Protection, of the NREPA and CERCLA, on December 28, 1990, the liable panics signed
an Administrative Order by Consent (AOC) with the state of Michigan and agreed to fund
and conduct the Remedial Investigation/Feasibility Study (RI/FS) for the site. The RJ/FS
for the KHL-OU 3 was initiated in July 1993, completed by December 1996, and has
been placed in the Administrative Record.
C. COMMUNITY PARTICIPATION
4
The Responsiveness Summary in Section L discusses the involvement of the community
during the RJ/FS and remedy selection process and demonstrates that the public
participation requirements of Sections 113 (k) (2) (i-v), and 117 of CERCLA have been
met at the KHL-OU 3 and the five former lagoons. The decision is based on the
Administrative Record.
D. SCOPE AND ROLE OF KHL-QU3 WITHIN THE SITE STRATEGY
The MDEQ and the EPA have identified the human health and ecological threat at the
KHL-OU 3 and the five former lagoons to be the PCB-contaminated paper residuals,
soils, and sediments in and adjacent to the KHL-OU 3 and the five former lagoons. The
purpose of this ROD is to select the final remedial action (RA) for the KHL-OU 3 and the
five former lagoons of the Allied Paper, Inc./Portage Creek/ Kalamazoo River site. This
ROD addresses only the KHL-OU 3, and the five former lagoons within the site.
Remedy selection for the other three OUs, Portage Creek, and the Kalamazoo River will
be addressed by other RODs. This final remedy is a source control remedy, which
contains or controls PCB contamination from the landfill, five former lagoons,
contaminated soils, sediments or paper residuals, and the potential release of leachate.
The remedy addresses all media including contaminated paper residuals, soils, sediments,
and migration pathways considered to represent an unacceptable risk of release to both
surface water and river sediments. The ROD for the KHL-OU 3 and the five former
lagoons will be consistent with the final remedy for the site.
This remedy does not include treatment that would reduce toxicity, mobility, or volume
as a principal element. Although incineration was evaluated as a treatment option, the
volume of the waste, implementation time, ana the technical and administraVive
difficulties associated with implementation and cost made it prohibitive. Available
information on the landfill operations indicate that it would not be feasible to attempt to
locate concentrated areas of PCBs (hot spots) because PCBs are spread evenly throughout
the landfill. Therefore, alternatives were not evaluated for location and treatment or
removal of hot spots in the KHL-OU 3 or the five former lagoons. As required by the
National Contingency Plan (NCP), a periodic (five year) review of the remedy
effectiveness will be performed.
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Under the existing AOC, interim measures have been required to mitigate threats of
potential berm failures due to wind and water erosion damage. A 1,020 feet long steel
retaining wall has been constructed to stabilize a portion of the berm and control erosion
on the north side of the KHL.
E. SUMMARY OF SITE CHARACTERISTICS
Based upon the information available to the MDEQ, the KHL is a mono-fill of paper
residuals with an estimated total volume of 282,000 cubic yards. PCBs are the primary
constituent of concern at the KHL-OU 3 and the five former lagoons. PCBs are oily
liquids, clear to light yellow in color, and have no smell or taste. PCBs are hazardous
substances and are carcinogenic. Characteristics of PCBs that cause them to be especially
persistent in the environment are that they bind strongly to soils, do not dissolve well in
water, are not easily broken down, and are lipophilic and therefore have an affinity for the
fatty tissue of biota which causes them to bioaccumulate.
The PCBs at the KHL-OU 3, the five former lagoons, and the site are closely associated
with the fine gray, kaolinite clays and wood fibers that compose the paper residuals.
These residuals containing PCBs were disposed of in the KHL-OU 3 starting in 1957 and
were part of a waste stream produced by the recycling of office waste paper. This office
waste paper contained several types of paper, including the carbonless copy paper which
contained PCBs. The recycling of paper, including deinking at the paper mill, resulted in
the discharge of PCBs to the river either by the discharge of effluents or by sludge
disposal in disposal areas adjacent to the river. The KHL is one of these disposal areas.
The presence of these residual disposal areas on Georgia-Pacific Corporation's property,
adjacent to the Kalamazoo River, is a direct result of waste treatment systems operated at
their paper mill.
The RI at the KHL-OU 3 was conducted in 1993. Based upon public comment on the
Proposed Plan some additional data was collected on the groundwater and the residuals in
Cell 4. As a result of the RI, it was concluded that KHL-OU 3 and the five former
lagoons on the north side of the Kalamazoo are sources and potential sources of PCB
contamination to the Kalamazoo River and its floodplain in the vicinity of the KHL-OU 3
and the five former lagoons.
PCB contamination exists in the residuals in and around the landfill and the five former
lagoons. In Cells 1, 2, and 3 the PCB concentidtions generally increase with deplh. The
maximum PCB concentration found in the top 16 feet of residuals in Cells 1, 2 and 3 was
8.8 mg/kg. Concentrations over 50 mg/kg were detected at depths of 16 to 30 feet. The
maximum concentration in the residuals is 310 mg/kg. However, PCB concentrations in
the top eight feet of residuals in Cell 4 are as high as 69 mg/kg. The reason for the dif-
ference between Cells 1,2, and 3 and Cell 4 is that Georgia-Pacific Corporation
continued to dispose of residuals at the KHL after the use of PCBs in the manufacture of
carbonless copy paper was halted. Tests of residuals that were recently added to the
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landfill did not detect PCBs with the exception of one sample in 1987 that contained 6.5
mg/kg PCBs. The soils below the KHL have a maximum PCB concentration of 9.9
mg/kg. Soil borings taken from the KSSS area immediately west of the KHL showed
PCB levels in the range of 0.37 to 99 mg/kg. The maximum PCB concentration found in
the berms was 77 mg/kg.
Groundwater flows across the KHL to the Kalamazoo River with a horizontal gradient
that averages 0.0004 feet/feet. PCBs were not detected in groundwater. However, PCBs
were detected in a leachate sample collected from Monitoring Well 1 OR at a
concentration of 1.4 ug/L (micrograms per liter).
One surface water sample was collected from the pond1 in Cell 4 and analyzed for PCB.
The analytical results show a PCB concentration of 0.026 ug/L.
Five surficial residual samples collected in Georgia-Pacific Corporation's five former
lagoons detected PCB concentrations in the range of 0.2 to 110 mg/kg. PCBs were
detected in three subsurface residual samples in the former lagoons at concentrations
from 3.4 to 70 mg/kg. Five soil samples from below the lagoons contained PCB levels in
the range of 0.043 to 2.9 mg/kg.
F. SUMMARY OF SITE RISKS
Estimated Human and Ecological Risks if Current Conditions at the KHL-OU 3
and Five Former Lagoons Continue in the Future:
A Baseline Risk Assessment (BRA) to evaluate risks to human health and the
environment under current, unremediated conditions was conducted. A number of
pathways were screened from the quantitative evaluation based on qualitative screening
and the assumption that exposure scenarios could not be assigned a probability of
occurrence in the foreseeable future due to restrictions presented in Part 115, Solid Waste
Management, of the NREPA and the assurances by the Georgia-Pacific Corporation that
the landfill would be closed in accordance with Part 115, Solid Waste Management, of
the NREPA. The land use restrictions will be permanent under Part 115, Solid Waste
Management, and Part 201, Environmental Remediation, of the NREPA. Because the
waste is identical (i.e., waste was generated from the same source at similar
concentrations), the routes of exposure are the same, and the receptors are the same at the
KHL-OU 3 and the five former lagoons, the MDEQ has determined that the BRA for the
KHL-OU 3 is applicable to the five former lagoons.
The pathways which were not evaluated quantitatively in the BRA include the use of
groundwater, ingestion of and dermal contact with Kalamazoo River water and
sediments, ingestion of biota, and inhalation of constituents released to air from
surface/soil residuals by nearby residents, trespassers, and anglers.
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The land use restrictions required by Part 115. Solid Waste Management, and Pan 201.
Environmental Remediation, of the NREPA will prohibit residential use of the KHL in
the future. Based upon this information it was not necessary to quantitatively evaluate
the future residential scenario for the KHL-OU 3 or the five former lagoons. This
includes the possibility of using the groundwater under the KHL and the five former
lagoons as a potable water source.
Groundwater, which is discharged to the river, is not used as a potable water source either
on-site or downgradient of the KHL-OU 3. Since residential use will be restricted on the
KHL-OU 3 as a condition of the Part 115, Solid Waste Management, of the NREPA
permit, and as a condition of closure under Parts 115, future installation of potable wells
is effectively precluded. Although PCBs were detected in leachate from one well, they
were not detected during the RJ groundwater sampling or in the previous landfill permit
groundwater monitoring! .
Ingestion of, and dermal contact with Kalamazoo River water, sediments, and ingestion
of biota were not evaluated quantitatively. The sampling results for the KHL indicate
that as long as the berms remain intact, the potential impact from the PCBs inside the
KHL on surface water quality can be prevented. In particular, the low concentrations of
PCBs in the leachate, the lack of detection of PCBs in groundwater, the low hydraulic
gradient (0.0004), and low permeability of the residuals all lead to the conclusion that
impacts on surface water should be limited if the primary migration pathways continue to
be controlled. The present primary migration pathways for the release of PCBs into the
river are erosion of residuals from the berms and floodplains and the five former lagoons.
The largest potential risk and migration pathway is the release of PCB-contaminated
residuals due to failure of the landfill berms. The risks from PCS contamination already
existing in Kalamazoo River water, soils, residuals, sediments and biota will be assessed
in other OU's.
Inhalation by nearby residents of constituents released to the air from surface soil and
residuals was not evaluated quantitatively due to studies which demonstrated it to be
insignificant. During the RJ, an air monitoring program was conducted at two other OUs
of the site (Willow Boulevard/A-Site and Allied Paper, Inc.). Emissions were found to be
in compliance with Part 55, Air Pollution Control, of the NREPA. Given that the KHL-
OU 3 has lower concentrations of PCBs in surface soils than the two test OUs, and that
the distance to the nearest receptor is greater, risks associated with hypothetical, off-site
exposure via inhalation was considered negligible.
1. Human Health Risks
Based on the environmental setting of the KHL-OU 3, issues regarding the movement of
constituents on-site (i.e., on the KHL-OU 3), and potential for transport off-site (i.e., off
the KHL-OU 3), the exposure pathways that are currently possible in association with the
OU include:
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Incidental ingestion and dermal contact with surface soil/residuals by on-site
workers, especially bulldozer operators.
Inhalation of airborne particulates by on-site workers.
Dermal contact with surface water in Cell 4 by on-site workers.
Incidental ingestion and dermal contact with surface soil/residuals, and sediments
in Cell 4 by trespassers.
Incidental ingestion and dermal contact with residuals along the berms by anglers.
A Hazard Index (HI) approach was used to characterize the overall potential for non-
carcinogenic risk associated with exposure to multiple constituents that cause non-
carcinogenic health effects. The calculation of an HI in excess of one indicates the
potential for adverse health effects. Both pathway-specific and total His less than one are
estimated for workers, trespassers, and anglers.
Carcinogenic risk is expressed as a probability of developing cancer as a result of lifetime
exposure. The EPA's acceptable target range for carcinogenic risk associated with
Superfiind sites in general is one in ten thousand (1.0 x 10"4) to one in one million
(1.0 x 10"6) and the MDEQ's target is one in one hundred thousand (1.0 x 10"5). For all
Superfiind sites the acceptable risk level is established by the EPA Regional
Administrator on a site-by site basis.
Risks associated with constituents detected in soils, residuals, and sediments were
evaluated. Based on the environmental setting of the KHL-OU 3, and the likely
foreseeable use of the KHL-OU 3, surface soil/residuals, sediments, and water in Cell 4
were determined to be the media of interest at Cell 4 in the BRA. The constituents of
concern in these media were PCBs and polychlorinated dibenzodioxin/polychlorinated
dibenzofuran (PCDD/PCDF). Therefore, hypothetical risks based on potential exposures
to PCB and PCDD/PCDF in surface soil, surface residuals, surficial sediments, and water
in Cell 4 were estimated in the assessment. Additional RI work conducted in Cell 4
indicated that the residual PCB concentrations are greater, (an average of 4.9 mg/kg and a
maximum of 69 mg/kg) than those used in the risk assessment. Consequently, the risk
assessment may underestimate the potential risks at the KHL-OU 3.
On-site workers, trespassers, and anglers are considered the primary receptors of interest.
Total cancer risks are 4 x 10"6 for workers, 1 x 10"5 for on-site trespassers, and 1 x 10"4 for
anglers. Although exposures associated with failure of the berms have not been
quantitatively estimated, it is reasonable to assume that this event would cause additional
unacceptable human health and ecological risk. Consequently, the risk assessment
recognized that long-term berm stability will be needed to prevent unacceptable human
and wildlife exposure to PCBs from the KHL-OU 3.
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2. Environmental Risks
The primary habitat in the vicinity of the KHL-OU 3 and the five former lagoons is the
Kalamazoo River and associated floodplain, which are immediately adjacent and border
the northern, western, and eastern perimeter of the KHL-OU 3. The Kalamazoo River
and associated floodplains are immediately adjacent to the south and north of the five
former lagoons. The one surface water body within the KHL-OU 3, other than the river,
is the pond in Cell 4. The five former lagoons are also surface water bodies. The water
cover in the KHL-OU 3 and the five former lagoons is derived from direct precipitation
and surface runoff from surrounding areas.
The perimeter berm upslope from the Kalamazoo River is part of the ecosystem
encompassed by the Kalamazoo River and floodplain. There are no barriers to prevent
fauna movement from the floodplain or river to the KHL-OU 3. This is also true for the
five former lagoons on the north side of the Kalamazoo River. The wooded areas of the
berms also provide habitat for terrestrial or river wildlife species. According to the
National Wetland Inventory map for the Kalamazoo Quadrangle, two wetlands are
located within the KHL-OU 3. Results of field reconnaissance for wetland assessment
indicate these wetland areas were eliminated by past physical alterations related to
licensed landfill activities at the KHL. The Cell 4 area supports emergent wetland
vegetation at its southernmost extent and provides habitat for waterfowl species, aquatic
organisms, and mammals.
The aquatic and semi-aquatic flora and fauna in the vicinity of the KHL-OU 3 and the
five former lagoons are typical of the area. Most aquatic and semi-aquatic wildlife
species are generally associated with the adjacent Kalamazoo River and floodplain. The
aquatic habitat of the river and floodplain adjacent to the KHL-OU 3 and five former
lagoons provide support for development of various life stages offish, turtles, and
amphibians which are associated with the Cell 4 pond and the five former lagoons.
Terrestrial wildlife species which inhabit the KHL-OU 3 are likely limited to small
mammals (e.g., mice, squirrels, woodchucks, mink, raccoons, and muskrats ) and birds,
especially passerines and waterfowl. Because the Kalamazoo area is part of a major
migratory flyway route for waterfowl species, Cell 4 may be used as a migratory
stopover. The water cover in Cell 4 and the five former lagoons attracts and supports
waterfowl throughout the nesting season because water is present year-rouna and the
vegetation surrounding these areas provides adequate cover and materials for nesting.
Larger mammals, such as white-tailed deer, also use the KHL-OU 3 as indicated by the
deer tracks observed in the residuals. Muskrat dens have been observed in the Cell 4
pond and there is evidence of woodchucks burrowing into the berms of the landfill.
There are no federally-listed endangered or threatened species known to reside within the
KHL-OU 3 or the five former lagoons. Because the KHL-OU 3 and the five former
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lagoons are sources of PCBs to the rest of the site, it is important to consider all the
federally-listed endangered or threatened species that inhabit the entire site. The
federally-listed endangered or threatened species known to reside within the site are two
turtle species that are considered scarce, one snake that is considered endangered, and
bald eagles, which are considered a threatened species that live and nest on the site.
There are also four threatened and one scarce plant species.
The potential effects of exposure to PCBs in the Cell 4 pond were evaluated for acute
toxicity to crustaceans and insects. The risk assessment assumed that Cell 4 does not
support a fish population. However, during the RI fish were observed in Cell 4.
Consequently, the risk assessment probably underestimates the potential ecological risk at
theKHL-OU3.
Although the risk assessment does not quantitatively assess the chronic exposure to PCBs
offish, aquatic invertebrates, amphibians (e.g., frogs), and reptiles (e.g., snakes and
turtles), it does recognize that these organisms in Cell 4 would bioaccumulate PCBs and
pass them up the food chain to other organisms which would feed upon them. These
bioaccumulation food chain effects present the greatest potential for ecological and
human health exposure and significant risks. This would occur when organisms forage
on the organisms from Cell 4 and when the PCBs from the KHL-OU 3 or the five former
lagoons are released into the river.
The presence of PCB-contaminated residuals, soils, and sediments in areas outside Cells
1,2, 3, and 4 of the KHL and the five former lagoons is evidence of past or ongoing
releases to the Kalamazoo River. The landfill berms are being eroded by surface water
runoff and the continuous flow of the Kalamazoo River. These berms contain residuals
that are being exposed and eroded into the Kalamazoo River. The possibility of failure of
the berms located between the Kalamazoo River and Cells 1, 2, and 4 of the KHL is a
potential threatened release. Some of the potential threatened release from berm failure
has been addressed by the construction of a steel retaining wall along the berms of Cells 1
and 2.
Environmental risks identified in the draft Environmental Risk Assessment on the
Kalamazoo River associated with PCB exposure at the site, of which the KHL-OU 3 and
the five former lagoons are a part, are as follows:
Sensitive aquatic biota such as invertebrates and fish, are likely to be adversely
affected both directly (direct contact) and indirectly (food chain) by PCuS in surface
water and streambed sediment.
These effects include mortality, reproductive effects (i.e. failure), decreased
populations and growth effects for sensitive species.
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• PCB contamination of surface water and streambed sediment indirectly affect
sensitive piscivorous predators, such as mink, through consumption of PCB-
contaminated prey.
Impaired reproduction of mink and, ultimately, decreases in mink populations are the
observed effects of PCB contamination in aquatic prey.
Other less sensitive piscivorous predators, such as bald eagles, are at risk if fish are
the predominant prey item consumed and if foraging takes place mostly within
contaminated aquatic areas. Bald eagles on this site have failed to reproduce for at
least the last seven year.
t
• Terrestrial and semi-aquatic biota are at risk from PCB-contaminated floodplain
sediment and surface soil, depending on life history (e.g., foraging behavior, diet,
mobility) and sensitivity to PCBs. '
Carnivorous terrestrial species, represented by the red fox, are likely to be at
significant risk if foraging is concentrated in riparian areas with PCB-contaminated
floodplain sediment and diet consists of prey that reside in PCB-contaminated areas.
Omnivorous terrestrial species, represented by mice, appear to have moderate
potential for risk from PCB-contaminated surface soil/floodplain sediment. These
risks would be location-dependent, and would be influenced by diet, season, and
mobility of consumers and by the level of contamination of food items.
Omnivorous birds that consume a substantial amount of vegetation, represented by
the robin, may be at risk if consumed terrestrial plants are taken from highly
contaminated areas. Consumption of terrestrial invertebrates such as earthworms is
expected to contribute substantially less to total PCB intake than ingestion of plants,
based on estimated PCB levels in plants and measured PCB concentrations in
earthworms.
Semi-aquatic herbivorous mammals, represented by muskrat, are at risk from PCB
contamination because estimated dietary doses exceed recommended threshold values
for rats. Muskrats contaminated with PCBs also cause adverse effects to muskrat
predators because some muskrats contain PCBs in excess of recommended dietary
limits for PCB-sensitive predators such as mink.
Based on the results of the risk assessment for the KHL-OU 3 and the draft Ecological
Risk Assessment for the site, the objectives of the RAs must address the following risks:
Human health risks for persons who trespass or work on the KHL-OU 3.
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Human health and ecological risks due to past migration of PCBs to the
Kalamazoo River and surrounding floodplain areas, and berms from the KHL-
OU3.
Human health and ecological risks due to the continued release of PCBs to the
Kalamazoo River, surrounding floodplain areas, and berms from the KHL-OU 3.
Human health and ecological risks due to the potential additional release of PCBs
to the Kalamazoo River and surrounding floodplain areas caused by failure of the
berms of the KHL-OU 3.
G. DESCRIPTION OF ALTERNATIVES
A total of seven potentially applicable technology types which incorporated 60 different
process options were screened with respect to technical'implementability at the KHL-OU
3. Based upon this screening, three potentially applicable technology types were chosen
as alternatives. The 'No Action' option was evaluated as required by the NCP to provide
a baseline for comparison of the effectiveness of the remedial alternatives. Under the No-
Action alternative, no active response measures would occur. No reduction of toxicity,
mobility, or volume through treatment of the PCBs would be provided by this alternative.
Therefore, no risk reduction would result from this action. The No-Action alternative
would not meet the applicable or relevant and appropriate requirements (ARARs) and
would not be protective. One of these ARARs, Part 115, Solid Waste Management, of
the NREPA requires that the closure of KHL-OU 3 meet or exceed the closure
requirements for a landfill pursuant to the Michigan Solid Waste regulations (Part 115,
Solid Waste Management, of the NREPA). Due to the above factors the No-Action
alternative was eliminated by screening in favor of the three potential alternatives listed
below.
Alternative 1: Landfill Closure (consolidation, containment and capping in
accordance with Part 115, Solid Waste Management and Part 201 , Environmental
Remediation, of the NREPA).
Alternative 2: Removal and disposal of residuals.
Alternative 3: Removal, treatment, and disposal of residuals.
All cost estimates presented with the following descriptions of the three alternatives are
expressed in 1994 dollars and are based on conceptual engineering and design. Capital
costs consist of direct costs (e.g., construction, equipment, transportation, disposal,
analytical, treatment, and contingency) and indirect costs (e.g., engineering, legal, and
permitting fees) incurred by implementing a specific alternative. Operation and
Maintenance (O&M) costs refer to long-term, post-construction measures necessary to
ensure continued effectiveness of an RA. The O&M costs were developed for the first
year of system operation and a 30-year present worth (PW) cost analysis. Total net PW
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cost represents the sum of money, if invested in the base year and disbursed as needed.
that would be sufficient to cover costs of a remedy over its planned life (assumed to be 30
years for comparison purposes).
Alternative 1: Landfill Closure (consolidation, containment and capping in
accordance with Part 115, Solid Waste Management and Part 201 Environmental
Remediation, of the NREPA)
Capital Cost: $ 1.6 - $2.7 million
O&M Cost: $125,00(rayear
Net PW Cost: $3.2 - $4.3 million (capital and O&M)
Implementation Time frame: 1.0 years
i
Alternative 1 involves the consolidation and containment of the PCB-contaminated
residuals via landfill closure, reinforcement of the existing berms, and long-term
monitoring. Closure of the landfill would be in accordance with Part 115, Solid Waste
Management, of the NREPA regulations and the landfill's current permit. Reinforcement
of the existing berms would increase stability and minimize the potential for berm failure
under flood conditions. Long-term monitoring involves the collection and analysis of
groundwater and surface water samples to track the effectiveness of the cap. Alternative
1 also includes institutional controls such as fencing, deed restrictions and sign posting to
reduce potential human exposure to soil, residuals, and other media.
Alternative 2: Removal and Disposal of Residuals
Capital Cost: $55.5 - $66.5 million
O&M Cost: None
Net PW Cost: $55.5 - $66.5 million (capital and O&M)
Implementation Time frame: 2.9 years
Alternative 2 includes the excavation, dewatering, and off-site disposal of all residuals
from the KHL-OU 3. Dewatering the residuals would yield a material acceptable for
disposal and transport to an off-site commercial landfill. Water obtained from residuals
dewatering would be treated on-site to remove any PCBs prior to discharge.
Based on the results of the RI, at least 76,000 cubic yards of residuals contain PCB
concentrations greater than 50 parts per million (ppm) and would be regulauJ for off-site
disposal by the federal Toxic Substances Control Act (TSCA), Subpart D of the Code of
Federal Regulations (CFR) 40 CFR 761. Such residuals would be disposed at an existing
commercial TSCA disposal facility. The 206,000 cubic yards of residuals with PCB
concentrations less than 50 ppm would not be regulated by TSCA and could be disposed
of at a commercial sanitary landfill.
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Following the excavation and disposal of the residuals, the landfill would be graded to
match the surrounding area. A minimum 6-inch layer of topsoil with vegetative cover
would be installed to minimize erosion to comply with Soil Erosion and Sedimentation
Control requirements.of Part 91, Soil Erosion and Sedimentation Control, of the NREPA.
The capital costs associated with this alternative are higher than Alternative 1 due to the
high cost of off-site disposal of residuals at a TSCA facility (off-site TSCA disposal
represents approximately 50 to 70 percent of the total capital cost for Alternative 2).
Alternative 3: Removal, Treatment, and Disposal df Residuals
Capital Cost: $55.0 - $426.8 million
O&MCost: None
Net PW Cost: $55.0 - $426.8 million (capital and O&M)
Implementation Time frame: 4.4 years
Alternative 3 is the same as Alternative 2 with the addition of a treatment step. Residuals
with a PCB concentration 50 ppm or greater (76,000 cubic yards) would be treated either
on-site or off-site via incineration prior to disposal in a commercial sanitary landfill. The
206,000 cubic yards of residuals containing less than 50 ppm of PCBs would be disposed
at a commercial sanitary landfill.
The capital costs associated with this alternative are higher than Alternatives 1 and 2 due
to the high cost of incineration (on-site or off-site) of the residuals (incineration
represents approximately 50 to 90 percent of the total capital cost for Alternative 3).
H. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, the relative performance of each alternative is evaluated
using nine criteria (section 300.430(e)(9)(iii) of the NCP) as a basis for comparison. The
alternative which provides the "best balance" with respect to the nine criteria is
determined from this evaluation.
1. Threshold Criteria
a. Overall Protection of Human Health and the Environment addresses whether a
remedy provides adequate protection of humau health and the environment -nd describes
how risks posed through each exposure pathway are eliminated, reduced, or controlled
through treatment, engineering, or institutional controls. The selected remedy must meet
these criteria.
The major exposure pathways of concern at the KHL-OU 3 and the five former lagoons
are ingestion of, inhalation of, and dermal contact with PCB-contaminated soils or
residuals in the landfill; ingestion of and dermal contact with PCB-contaminated
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soils/residuals and sediments in Cell 4; dermal contact with PCB-contaminated surface
water in Cell 4; and ingestion of and dermal contact with PCB-contaminated river
sediments and soils along the berms. The release of PCB-contaminated residuals from
berm, the landfill cells, floodplain, river sediments, or berm failure would result in the
bioaccumulation of PCBs and food chain effects which will also be considered in the
evaluation of exposure pathways.
Alternative 1 would provide adequate protection of human health and the environment by
controlling the mobility of contaminants through engineering and institutional controls.
The cap, constructed in accordance with Part 115, Solid Waste Management, of the
NREPA along with institutional controls, would serve as a barrier to human and wildlife
contact with the residuals. An adequate cap would alsb decrease the rate of precipitation
infiltration, thereby further reducing the potential for PCBs to migrate into groundwater.
Stabilization of the berms would prevent release of residuals due to berm failure.
Consolidation of residuals from the berms, the KSSS flbodplain, the five former lagoons,
and the Kalamazoo River into Cell 4 prior to the construction of the cap will reduce the
potential for exposure and migration of PCBs into the environment.
Alternative 2 would provide adequate protection of human health and the environment by
eliminating the presence of contaminants at the KHL-OU 3 through removal and off-site
disposal of PCB-contaminated waste.
Alternative 3 also provides adequate protection of human health and the environment by
eliminating the presence of contaminants on-site. The removal and off-site
disposal/incineration of PCB-contaminated waste eliminates risks associated with PCBs
at the KHL-OU 3.
b. Compliance with ARARs addresses whether a remedy will meet ARARs set forth in
federal and state environmental laws and/or justifies a waiver from such requirements.
ARARs of most concern to this remedial action include the following:
• Surface water quality standards in Part 31, Water Resources Protection, of the
NREPA.
• Rules established under Part 31, Water Resources Protection, of the NREPA
regarding permit requirements.
• Site-specific pollutant limitations and performance standards which are
designed to protect surface water quality in the Federal Clean Water Act.
• Regulations prohibiting unauthorized obstruction or alteration of any
navigable water in the United States (dredging, fill, cofferdams, piers, etc.) in
the Federal River and Harbor Act;
• Regulations on dredging or filling of lakes or stream bottoms found in Part
301, Inland Lakes and Streams, of the NREPA.
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• Rules prescribing soil erosion and sedimentation control plans, procedures.
and measures found in Pan 91, Soil Erosion and Sedimentation Control, of the
NREPA.
• Rules regarding construction, operation, and maintenance of sewage systems
in Part 41, Sewerage Systems, of the NREPA.
• Rules prohibiting the emissions of air contaminants in quantities which cause
injurious effects to human health, animal life, plant life of significant
economic value, and/or property found in Part 55, Air Pollution Control, of
the NREPA.
• National ambient air quality standards in the Federal Clean Air Act.
• Transportation and handling requirements in the USDOT Placarding and
Handling regulations for materials containing PCBs at concentrations of 20
ppm or greater.
• Rules specifying environmental response, ri^k assessment, RAs and site
cleanup criteria in Part 201, Environmental Remediation, of the NREPA.
• Regulations regarding the construction, operation, and closure of sanitary
landfills, solid waste transfer facilities, and solid waste processing plants in
Part 115, Solid Waste Management, of the NREPA.
• Effluent standards for toxic compounds including PCBs in the Federal Water
Pollution Control Act Toxic Pollutant Effluent Standards.
• TSCA disposal regulations at 40 CFR Section 761.60 et seq. are applicable to
PCBs at concentrations of 50 ppm or greater when such PCBs are "taken out
of service". Under the RAs being considered, TSCA disposal regulations
could be triggered by the excavation of PCB-contaminated residuals,
sediments and soils from the five former lagoons. These residuals, sediments
and soils would be consolidated into Cell 4. Pursuant to 40 CFR Section
761.60 (a) (4), PCBs must be disposed of: "(i) in an incinerator which
complies with 761.70; or (ii) in a chemical waste landfill which complies with
761.75." The TSCA compliant chemical waste landfill disposal method is
generally much less expensive than incineration.
The on-site consolidation and containment of PCBs, whether from sediments, soils, or
residuals excavated from the five former lagoons will be placed in Cell 4. Cell 4, being
an existing landfill cell does not possess the following chemical waste landfill
requirements found in Section 761.75 (b):
• Bottom liner requirements (the landfill does not have a bottom li .2r) (761.75
(b)(l)and(2)).
• Hydraulic conditions - fifty foot distance between bottom liner and historical
high water table or leachate collection system (761.75 (b)(3)).
• Leachate collection requirements (761.75 (b)(7)).
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Pursuant to 761.75 (c) (4), the EPA Regional Administrator may determine that one or
more of the requirements in 761.75 (b) is not necessary to protect against unreasonable
risk of injury to health or the environment from PCBs and may waive such requirements.
In this ROD, the EPA Regional Administrator waives the requirements in 761.75 (b) (1),
(2), (3) and (7) because the final RA will provide protection to human health and the
environment against unreasonable risks of injury. Also taken into consideration are the
following facts: 1.) no significant reduction in long-term risks would be gained from off-
site disposal of the relatively small quantity of PCBs in excavated residuals, sediments,
and soils as compared to the amount of PCBs being contained in place under the final
cover; 2.) PCBs are the only chemical of concern; 3.) the PCB concentrations in the five
former lagoons are lower than those already present in the KHL; 4.) the PCB-
contaminated residuals were disposed of prior to February 17, 1978; 5.) the residuals
originated from the same industrial process waste stream; and, 6.) the leachability of
PCBs from the KHL-OU 3 is not likely because of the high PCB affinity for the residuals
and the low hydraulic conductivity of the residuals (~ I1 x 10'7 cm/sec.).
Alternatives 2 or 3 would be in compliance with state and federal ARARs. These two
alternatives would comply with the TSCA disposal requirements of 761.60. Alternative 1
includes the on-site consolidation, containment and capping as described in this ROD and
would be in compliance with all state and federal ARARs except TSCA regulations of 40
CFR Section 761.75 (b). With a waiver for the chemical landfill requirements of 761.75
(b), Alternative 1 meets the disposal requirements of 761.60. Alternative 1 would also
comply with the existing permit closure requirements of the NREPA because a part of the
KHL of the KHL-OU 3 is a permitted solid waste landfill.
2. Primary Balancing Criteria
c. Long-term Effectiveness and Permanence refers to expected residual risk and the
ability of a remedy to maintain reliable protection of human health and the environment
over time once cleanup goals have been met.
Alternative 1 would provide long-term effectiveness via consolidation of residuals from
outside the berms and five former lagoons into Cell 4, stabilization of the berms, and
isolation of the residuals by capping. Permanence of the remedy would require that long-
term operation and maintenance and monitoring will be provided to insure that the
remedy maintains its reliability to protect human health and the environment over time.
Alternative 2 would provide long-term effect:vcness via removal of residuaL and off-site
disposal. This alternative provides permanence without any additional actions at the site.
Alternative 3 would provide long-term effectiveness via removal and treatment of
residuals. This alternative also provides permanence without any additional actions at the
site.
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d. Reduction of Toxicity, Mobility, or Volume Through Treatment addresses the
statutory preference for selection of RAs that employ treatment technologies that
permanently and significantly reduce toxicity, mobility, or volume of the hazardous
substance as a principal element.
As detailed above, the stated programmatic goal of the EPA, as expressed in the NCP, is
to select remedies that are protective over time and "minimize untreated waste" (section
300.430 (a) (1) (i)). The NCP states that the EPA will use "treatment to address the
principal threats at a site, wherever practicable" (section 300.430 (a) (1) (iii) (A)). This
preference is satisfied when treatment is used to reduce the principal threats at a site
through destruction of toxic contaminants, reduction of total mass of toxic contaminants,
irreversible reduction in contaminant mobility, or reduction of total volume of
contaminated media.
Alternative 3 is the only alternative that would result in' the reduction in the toxicity,
mobility, or volume of contaminants through treatment. Incineration would destroy the
PCBs in the soils, sediments and residuals. Approximately 76,000 cubic yards of
residuals with PCB concentrations equal to or greater than 50 ppm would be treated on-
site or off-site via incineration prior to disposal in a commercial sanitary landfill. The
remaining 206,000 cubic yards of residuals containing PCB concentrations less than 50
ppm would also be disposed of in a commercial sanitary landfill.
e. Short-term Effectiveness considers the time to reach cleanup objectives and the risks
an alternative may pose to site workers, the community, and the environment during
remedy implementation. This criterion also considers the reliability and effectiveness of
any mitigative measures taken during remedy implementation to control those short-term
risks. ,
Alternative 1 has some potential short-term negative impacts. Capping is a standard
engineering process and standard safety precautions would be undertaken to reduce the
likelihood of accidents during construction. Truck traffic during cap construction may
increase noise and dust. Protective controls would need to be in place to suppress dust
that contains PCB concentrations so that federal and state air-quality standards are
complied with. The use of erosion controls would mitigate short-term effects posed by
potential siltation and contaminant release to the Kalamazoo River. Standard health and
safety requirements would protect site workers and the community from unacceptable
exposures to hazardous substances. The discharge of treated water to the Kalamazoo
River or to the Kalamazoo Wastewater Treatment Plant will be in accordant with the
substantive requirements of National Pollutant Discharge Elimination System (NPDES)
discharge criteria (as administered by the state under Part 31, Water Resources
Protection, of the NREPA), which are set at protective levels.
Alternative 1 has the greatest short-term effectiveness since the project could be
completed within one year, which is a shorter time period than that for the completion of
Alternatives 2 and 3. In comparison, implementation of Alternative 2, which includes the
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excavation and off-site disposal of all residuals and the restoration of the former cell
areas, would take approximately 2.9 years to complete. Alternative 3, which involves
excavation and incineration as a treatment process, has the longest implementation time.
This is due to project schedule uncertainties associated with the permitting process,
incinerator acquisition, construction and modification, test bum requirements, and trial
runs required prior to approval of the treatment technology for the residuals. Excavation,
incineration, and off-site disposal of the residuals to be treated and restoration of the
former cell areas would take approximately 1.9 years to complete. When considering the
uncertainties mentioned above, the time frame of Alternative 3 could increase by 2.5
years to 4.4 years.
Alternatives 2 and 3 would need proper controls so th£re would be no significant short-
term effects on the community or exceedances of standards during implementation due to
the projected level of excavation and on-site incineration activity. During the 2.9 years to
implement Alternative 2 and the 4.4 years to implement Alternative 3, the air emission,
from excavation and on-site incineration of Alternative 3 or the excavation and removal
of the residuals of Alternative 2, could cause dust levels in the ambient air to exceed
protective standards. For these Alternatives, truck traffic during the removal operations
may increase noise and dust. Protective controls would need to be in place to suppress
the dust and associated PCB emissions that could be above the federal and state air
quality standards to reduce short-term impacts to site workers and local residents. The
use of erosion controls would mitigate the short-term effects posed by potential siltation
and contaminant release to the Kalamazoo River. Standard health and safety
requirements would protect site workers and the community from short-term exposures to
hazardous substances. The discharge of treated water to the Kalamazoo River or to the
Kalamazoo Wastewater Treatment Plant will be in accordance with the substantive
requirements of NPDES discharge criteria (as administered by the state under Part 31,
Water Resources Protection, of the NREPA), which are set at protective levels.
f. Implementability is the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement a particular option.
No significant implementation problems are projected for Alternative 1. Cap materials
are expected to be obtainable from nearby sources and standard construction methods will
be used. Hauling cap materials to the KHL-OU 3 may increase the wear and tear on the
local roads. Environmental controls will be needed to prevent air emissions to the
atmosphere or migration of PCBs to the river during consolidation and cap construction.
Alternatives 2 and 3 meet the implementation criteria stated above. The excavation
techniques used for both these Alternatives are generally well proven. However,
environmental controls will be needed to prevent the emissions or migration of PCBs to
the river and the atmosphere during excavation and on-site incineration. Material
handling problems and mechanical breakdowns could slow the treatment progress. Also,
based on the restricted availability of mobile incineration units (six to twelve month lead
time may be required for scheduling purposes) and the testing required for agency
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approval, the implementability of Alternative 3 may be more difficult. Public acceptance
of on-site incineration may also be a hindrance to the implementation of Alternative 3.
g. Cost includes estimated capital and O&M cossts, also expressed as net present worth.
Table 2
Estimated cost of Remedial Alternatives for KHL-OU 3
Alternative
I (Cap & Contain)
2 (Removal & Disposal)
3 (Removal, Treatment & Disposal
Capital
(million)
$ 1.6 - 2.7 4
$55.5 - 66.5
$55.0 -426.8
O&M
(per year)
$125,000
None
None
Present Worth
(million)
$3.2 - 4.3
$55.5 - 66.5
$55.0 - 426.8
3. Modifying Criteria
h. Support Agency Acceptance addresses whether or not the Support Agency agrees
with, or objects to, any of the remedial alternatives.
The EPA, as the support agency for the site, is in agreement with the analyses and
recommendations presented in the RI/FS, Proposed Plan and this ROD. The EPA
concurs with the selected alternative as presented below.
i. Community Acceptance addresses the public's general response to the remedial
alternatives and to the Proposed Plan. Specific responses to public comments are
addressed in jhe attached Responsiveness Summary.
I. THE SELECTED REMEDY
In accordance with CERCLA and the NCP, and based upon the evaluation of the RJ/FS
and the nine criteria, Alternative 1 has been selected as the method providing overall
effectiveness proportional to its cost to adequately protect human health and the
environment against exposures to hazardous substances at the KHL-OU 3 and the five
former lagoons. The RA for the KHL and the five former lagoons shall meet the limited
industrial cleanup criteria set forth in sections 20120(a) and 20120(b) of the NREPA.
The RA for the KSSS floodplain which is adjacent to the KHL shall meet the residential
cleanup criteria set forth in sections 20120(a) and 20120(b) of the NREPA and the TSCA.
1. Cap
Under Alternative 1, a cap shall be placed on Cells 1, 2, 3, and 4 of the KHL-OU 3 in
compliance with the current requirements of Part 115, Solid Waste Management, of the
NREPA concerning cap specifications for closure of a solid waste disposal facility. The
construction of the cap over the landfill will minimize infiltration of precipitation through
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the landfill and prevent continued migration of residuals from the landfill into the
Kalamazoo River. The cap consists of the following components from bottom to top.
At least a 6-inch thick select granular fill gas venting layer will be placed on top of the
residuals. This gas venting layer is designed to collect landfill gas (methane) and route it
to the passive venting system. Select granular fill from an off-site source, having a
minimum hydraulic conductivity of 1 x 10" cm/s, will be used to construct the layer. The
gas venting system will consist of 19 passive gas vents placed in the select granular fill.
The venting system shall be monitored to determine whether emissions may cause
potential health effects. If potential health effects are indicated, an emission treatment
system shall be placed in the venting system to reduce the emissions to acceptable levels.
However, excessive'gas generation is not anticipated dxie to the type and age of the
residuals.
At least a 30-mil thick polyvinyl chloride (PVC) geomembrane liner (barrier layer) will
be placed over the select granular fill. The barrier layer will act as a barrier to minimize
infiltration of precipitation into the residuals.
At least a 24-inch thick general fill layer (protective layer) will be placed above the 30
mil PVC geomembrane liner. The protective layer will be capable of sustaining the
growth of non-woody plants, will have adequate water holding capacity, and will be
sufficiently thick to allow for erosion losses. The water that accumulates within this layer
will drain to a ditch or a sedimentation outlet structure and discharge to the Kalamazoo
River.
At least a 6-inch thick vegetative layer (erosion layer) will be placed over the protective
layer. The vegetative layer has been designed to promote vegetative growth, provide
surface water runoff, and minimize erosion. The feasibility of using vegetation that
would provide habitat, such as native grasses, will be addressed in the Remedial Design.
2. Erosion Protection
Placement of erosion protection on the berms of the landfill will be in compliance with
TSCA section 761.75 (b) (4), and Part 115, Solid Waste Management, of the NREPA.
This protection will be sufficient to protect the berms up to two feet above the 100-year
flood event. Part of this erosion protection will be provided by a steel sheet piling
stabilization wall which was constructed during 1994 and 1996 as an interim action. The
1,020 foot wall was constructed between the Kalamazoo River and the perimeter of Cells
1 and 2 on the north side of the landfill. It extends from the most northern point of Cell
1, southeast along the perimeter of Cells 1 and 2, to the junction where the corners of
Cells 2, 3, and 4 meet. Selection of erosion protection for the remaining sides of Cells 1
and 4 will be determined as part of the Remedial Design (RD).
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3. Installation of Groundwater Monitoring System
Groundwater monitoring wells will be installed and wells that are no longer needed will
be properly abandoned. This groundwater monitoring system will developed in RD.
4. Long-Term Monitoring
Groundwater and surface water monitoring shall be performed for at least 30 years
following landfill capping. Monitoring of the groundwater aquifer under the landfill will
be conducted in accordance with Parts 115, Solid Waste Management, and 201,
Environmental Remediation, of the NREPA, and TSCA (761.75(b)(6)) at a minimum.
Monitoring of the surface water and sediments will be conducted in accordance with
TSCA (761.75(b)(6)) at a minimum to assess the effectiveness of the remedy.
*
5. Consolidation
The PCB-contaminated residuals, soil, and sediments from the berms and the adjacent
floodplains of the KSSS will be consolidated into Cell'4 of the KHL. Verification
sampling will be conducted, and if the MDEQ's unrestricted residential cleanup criteria
of 1.0 parts per million is achieved, the action will be accepted as a final remedy. If this
criteria is not achieved, the PRPs will propose, within 45 days, specific additional actions,
including an implementation schedule, that will be taken to achieve any of the appropriate
state cleanup criteria.
PCB-contaminated residuals and sediments from the adjacent Kalamazoo River will be
consolidated into Cell 4 of the KHL as an interim response action using visual criteria.
The focus of this action will be to consolidate residuals at the toe of the berms back into
Cell 4.
PCB-contaminated residuals and soils from the Georgia-Pacific five former lagoons will
also be consolidated into Cell 4 as a final remedial action with a cleanup criteria for PCBs
of 21 ppm. Land use restrictions will be imposed, and recorded with the register of deeds.
Verification sampling will be conducted to determine if the limited industrial cleanup
criteria of 21 ppm has been achieved. Upon completion of the excavation the five former
lagoons will be backfilled with clean soil. Soil erosion control measures will also be
implemented.
6. Institutional Controls - Fencing
Institutional controls will be relied upon to provide additional effectiveness to the
remedy. A fence shall be installed around the entire KHL and the five forrr^r lagoons to
restrict access. This shall be installed as part of the RA.
7. Posting and Permanent Marker
As required by Part 201, Environmental Remediation, of the NREPA, a permanent
marker will be placed at the KHL describing the restricted area of the KHL-OU 3 and the
nature of any restrictions. Warning signs will also be posted on the fence every 500 feet
and on all entry gates. Construction details shall be part of the RD.
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8. Deed Restrictions
Deed restrictions shall be placed on the landfill area property to regulate the future use of
the KHL-OU 3.
9. Long-Term Maintenance
Long-term maintenance and post-closure care will be provided. Detailed plans shall be
part of the Remedial Design.
10. Financial Assurance Mechanisms (FAM)
Financial Assurance will be established by the PRPs in accordance with Part 201,
Environmental Remediation and Part 115, Solid Waste Management, of the NREPA.
The Financial Assurance mechanism will insure that there are funds available to pay for
monitoring, operations and maintenance, oversight, and other costs determined by the
state to be necessary to assure the effectiveness and integrity of the remedial action.
If the U.S. EPA conducts the action this FAM will not be necessary.
11. Other Provisions
Mitigative measures will be taken during remedy construction activities to minimize the
noise and dust impacts of construction upon the surrounding community. Fugitive dust
emissions shall not violate the National Ambient Air Quality Standards for emissions of
paniculate matter smaller than 10 microns or the standards contained in Part 55, Air
Pollution Control, of the NREPA.
12. Five Year Review
A review will be conducted within five years after commencement of the RA to ensure
that the remedy continues to provide adequate protection of human health and the
environment Because this remedy will result in hazardous substances remaining on-site
above health-based levels.
13. Significant Modifications to the 1994 Proposed Plan and the 1997 Revised Proposed
Plan
The revised Proposed Plan released in July 1997 presented the all following
modifications to the preferred alternative with the exception of the change in the
unlimited residential criteria.
a. Changing gabions to steel sheet pilings
The erosion control and berm stabilization system has been changed to steel sheet piling
from the rock filled wire baskets called gabions that were originally proposcu. Boih of
these options were reviewed in the FS. The steel sheet piling was selected because of
site-specific advantages it has over gabions discussed below.
During a storm in 1994 the berm was damaged when several trees were uprooted. This
left a 120 foot section of the berm vulnerable to erosion and failure. For this small
section of berm an interim response action was necessary to prevent berm failure. The
sheet piling could be quickly and cost-effectively implemented to stabilize this section of
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berm. Also, there was a greater degree of confidence that the installation of the sheet
piling could be properly constructed and would result in fewer construction impacts on
the river than gabions. Review of the berm conditions to either side of the sheet piling
indicated that installation of another 900 feet of sheet piling as an interim action would
further stabilize the berm and be consistent with the final remedy.
The sheet piling was driven 20 feet into the ground to stabilize the base of the berm. The
retaining wall was extended two feet above the 100-year flood elevation, 765.5 feet above
sea level, to prevent surface water runoff from eroding residuals and soils into the
Kalamazoo River and protect the berrn and the KHL-OU 3 from severe flood events.
During construction, precautions were taken to minimize impacts of the work on the
Kalamazoo River. Residuals found on the surface or m the berms were removed and
placed in a storage area in Cell 4. Clean material was then placed in this void between
the sheet pile retaining wall and the remaining berm. The entire area has been seeded to
promote growth of vegetation across the surface.
b. Remediation of Cell 4
Additional investigation of Cell 4 indicated that it contains a greater volume of PCB-
contaminated residuals (12,700 cubic yards) than originally estimated, that the PCB
concentration was greater than originally estimated (maximum of 69 mg/kg), and that the
pond supported numerous species of aquatic life including fish. Based upon the new
information the remedial decision was made to cap and contain the residuals in-place.
The pond in Cell 4 will be dewatered prior to the construction of the cap.
c. Consolidation of PCB-contaminated residuals, soils and sediments
PCB-contammated residuals have migrated from the landfill and have contaminated the
soils and sediments of the berms, KSSS area, floodplain, and the Kalamazoo River
directly adjacent to the KHL-OU 3. The PCB-contaminated residuals, soils, and
sediments from these areas will be excavated and consolidated in Cell 4 prior to
construction of the cap. There are also five former lagoons on the north side of the river
next to the paper mill's clarifier that will be excavated and placed in Cell 4 at the same
time. This action will take advantage of the most cost-effective disposal alternative
available.
The unlimited residential cleanup criteria was specified in the Revised Proposed Plan was
2.3 ppm. However, this cleanup criteria has been changed to 1.0 ppm due to a change in
the absorption factor use to calculate this criteria. This will affect the consolidation of
contaminated materials from the KSSS floodplain.
J. STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of Section 121 of CERCLA to:
1. Protect human health and the environment
2. Comply with ARARs
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3. Be cost-effective
4. Utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable
5. Satisfy the preference for treatment as a principal element of the remedy.
The implementation of Alternative 1 at the KHL-OU 3 of the site satisfies the
requirements of CERCLA as detailed below:
1. Protection of Human Health and the Environment
The presence of PCBs in areas outside the KHL berms is evidence of a past or ongoing
release of PCBs from the KHL-OU 3. The possibility of berm failure between Cells of
the KHL-OU 3 and the Kalamazoo River is recognized as a threatened release of PCBs,
a hazardous substance and carcinogen, into the environment. The implementation of
the selected alternative will reduce and control potential risks to human health and the
environment posed by exposure to PCB-contaminated residuals.
The potential risk caused by exposure to PCBs by workers (4 xlO"6), on-site trespassers
(1 x 10"5), and anglers (1 x 10^) will be reduced by the cap which will provide a barrier
that will eliminate the PCB exposure pathways of inhalation, ingestion, and dermal
contact. All PCB-contaminated materials with a; concentration greater than or equal to 1
mg/kg from the berms and KSSS, concentration greater than or equal to 21 mg/kg from
the former five former lagoons, and all residuals from the Kalamazoo River immediately
adjacent to the KHL-OU 3 will be excavated further reducing any exposure pathway for
workers, on-site trespassers, or anglers. The dewatering of the pond in Cell 4 prior to
capping will again eliminate all exposure pathways associated with the PCB-
contaminated surface water at the KHL-OU 3. By eliminating the exposure pathways the
alternative effectively reduces the risk to less than 1 x 10"6. Institutional controls in the
form of fencing and posting along with deed restrictions will further reduce the likelihood
of any exposure to humans.
To a large extent, the reduction of risk to wildlife from exposure to PCBs at the KHL-OU
3 will be accomplished in the same way. The consolidation of PCB-contaminated
residuals, soils, and sediments into Cell 4 and construction of the cap will reduce the
exposure pathways. Also, the dewatering of the Cell 4 pond will further reduce the
exposure pathways.
The largest potential risk to human health ana the environment is from the iailure of the
berms. This alternative will provide stabilization and erosion protection for the berms to
prevent failure. The selected remedy also protects the environment by reducing the
potential risk posed by PCBs migrating to the surface water (the Kalamazoo River).
Capping the landfill, in addition to reducing any potential further risk posed by exposure
to landfill contaminants, will reduce precipitation infiltration through the residuals over
time.
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No unacceptable short-term risks or cross-media impacts will be caused by
implementation of the remedy. The community and site workers may be exposed to
noise and dust nuisances during the consolidation and construction of the cap. As
mentioned above, mitigative measures will be taken during excavation and construction
activities to minimize the noise and dust impacts of construction on the surrounding
community.
2. Compliance with ARARs
The selected remedy will comply with the federal and/or state ARARs (categorized as
chemical-specific, location-specific, and action-specific) listed below:
a. Chemical-specific ARARs
1
Chemical-specific ARARs regulate the release of specific substances which have certain
chemical characteristics. Chemical-specific ARARs typically determine the extent of
cleanup at a site.
Federal Chemical-Specific ARARs:
TSCA:
TSCA establishes the requirements for handling, storage, and disposal of PCB. This is an
ARAR for any residuals, sediments, and soils containing PCB concentrations 50 ppm or
greater which are moved. However, as it applies to the KHL-OU 3 and the five former
lagoons, some of the requirements of TSCA are waived as explained below.
Excavation of residuals and soils from the five former lagoons will be required. Some of
these excavated residuals will contain PCBs at concentrations 50 ppm or greater.
Excavation and consolidation of these residuals on-site could be considered disposal of
PCBs pursuant to 40 CFR 761.1 (c). In this case, 40 CFR 761.60 (a) (4) would require
any non-liquid PCBs at concentrations of 50 ppm or greater in the form of contaminated
soils to be disposed of: (i) in an incinerator which complies with 761.70; or (ii) in a
chemical waste landfill which complies with 761.75. The selected remedy provides for
disposal of PCBs in a landfill that does not meet the following chemical waste landfill
requirements of Section 761.75 (b): bottom liner requirements because the hjidfill does
not have a bottom liner (761.75 (b) (1) or (2)); leachate collection requirements and
requirements for a fifty-foot distance between the bottom liner and the historical high
water table (761.75 (b) (3) and (b) (7). However, pursuant to 761.75 (c) (4), the EPA
Regional Administrator has determined that for the KHL-OU 3, the TSCA chemical
landfill requirements in 761.75 (b) (1), (2), (3), and (7), are not necessary to protect
human health and the environment. For the KHL-OU 3, the low permeability site cover,
long-term monitoring, access restrictions, and institutional controls included in the
selected remedy provide protection to public health and the environment. The written
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statement of this finding and waiver by the EPA Regional Administrator, as required in
761.75 (c) (4), is provided by signing this ROD.
The excavated material will be consolidated and stored in Cell 4 which is to be its final
disposal location. The remedy will comply with 40 CFR 761.75 (b) (4) (i) and (ii). which
requires diversion of surface water runoff from a 24-hour, 25-year storm. The remedy
will also comply with 761.75 (b) (5) which requires surface water and groundwater
monitoring, and 761.75 (b) (9) which includes requirements for support facilities. 40
CFR 761.75 (b) (8) is not an ARAR because it applies to the operations of chemical
waste landfills.
Clean Water Act (CWA) - Ambient Water Quality Criteria:
This act and criteria establish monitoring requirements for the discharge of waste
treatment effluents to waters of the United States. They are applicable to the excavation
and dewatering of sediments from the Kalamazoo River and residuals from the five
former lagoons. They would also be applicable for the dewatering of the pond and
residuals in Cell 4.
Federal Water Pollution Control Act (WPCA), Toxic Pollution Standards:
This act would be applicable to the discharge to the Kalamazoo River of water from all
dewatering activities.
State Chemical-Specific ARARs:
Part 201, Environmental Remediation, of the NREPA provides for the identification, risk
assessment, and evaluation of contaminated sites within the state; therefore, Part 201,
Environmental Remediation, of the NREPA is applicable or relevant and appropriate to
soils, sediments and residuals at the KHL-OU 3. The EPA considers the substantive
portions of Part 201, Environmental Remediation, of the NREPA, especially Section
20118, to be ARARs for the RA at this site. The rules provide, inter alia, that RAs shall
be protective of human health, safety, welfare, and the environment of the state. To
achieve the standard of protect!veness, Part 201, Environmental Remediation, of the
NREPA, in particular those in Section 20120(a) and 20120(b), specify that a RA shall
achieve a degree of cleanup under residential, industrial, or commercial criteria.
The MDEQ has determined that the limited ihuustrial criteria pursuant to Sections
20120(a) and 20120(b) of the NREPA would be appropriate for the KHL and the five
former lagoons. The property is zoned for industrial use, therefore, limited industrial
criteria would provide an appropriate RA for the KHL and the five former lagoons. The
limited industrial cleanup criteria of 21 ppm will be met. The unrestricted residential
cleanup criteria of 1.0 ppm will be met on the landfill berms and in the KSSS floodplain.
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Part 31, Water Resources Protection, of the NREPA establishes effluent standards in
accordance with the Federal WPCA and the CWA, and also establishes rules specifying
standards for several water quality parameters including PCBs. This would be applicable
to the discharge to the Kalamazoo River of water from all dewatering activities.
b. Location-Specific ARARs:
Location-specific ARARs are those requirements that relate to the geographical position
of a site. These include:
Federal Location-Specific ARARs:
TSCA:
TSCA establishes the requirements for disposal of sediments, soils, and residuals with
PCB concentrations 50 ppm or greater. This would be an ARAR for containment or
disposal of any residuals, sediments, and soils containing PCB concentrations 50 ppm or
greater disposed of after February 17, 1978. It is believed that the PCB-contaminated
residuals at the KHL-OU 3 and five former lagoons were disposed of prior to this date.
However, TSCA would regulate the disposal of these excavated residuals. For this
remediation some of the requirements of TSCA have been waived as explained above.
State Location-Specific ARARs:
Part 115, Solid Waste Management, of the NREPA:
Part 115, Solid Waste Management, of the NREPA contains regulations regarding the
construction, operation, and closure of sanitary landfills, solid waste transfer facilities,
and solid waste processing plants. These regulations govern the long-term monitoring
and closure of the landfill. Part of the landfill area is licensed under this act.
c. Action-Specific ARARs:
Action-Specific ARARs are requirements that define acceptable treatment and disposal
procedures for hazardous substances.
Federal Action-Specific ARARs:
CWA and Discharge to Waters of the United States:
The CWA and Discharge to Waters of the United States establishes site-specific pollutant
limitations and performance standards which are designed to protect surface water
quality. Types of discharges regulated under the CWA include discharge to surface
water, indirect discharge to a Publicly Owned Treatment Works (POTW), and discharge
of dredge or fill materiaJs to United States waters. This Act is relevant to the treatment
and discharge of water to the Kalamazoo River or POTW from the dewatering operations.
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Rivers & Harbor Act:
The Rivers & Harbor Act prohibits unauthorized obstruction or alteration of any
navigable water in the United States (dredging, fill, cofferdams, etc.). It also requires
federal agencies, where possible, to avoid or minimize adverse impacts of federal actions
upon wetlands and fioodplains. Remedial activities conducted in such a way will avoid
obstruction or alteration of the Kalamazoo River channel.
U.S. Department of Transportation (USDOT) Placarding and Handling:
USDOT Placarding and Handling regulates the transportation and handling of materials
containing PCBs at concentrations of 20 ppm or greater. This ARAR may apply to
transport of residuals from the five former lagoons, the KSSS, and the river adjacent to
the landfill to Cell 4.
Clean Air Act:
The Clean Air Act establishes requirements for constitilent emission rates in accordance
with national ambient air quality standards. Excavation and cap construction activities
will be regulated by the Clean Air Act.
State Action-Specific ARARs:
Part 91, Soil Erosion and Sedimentation Control, of the NREPA:
This Act regulates earth changes, including cut and fill activities which may contribute to
soil erosion and sedimentation of surface water. Part 91, Soil Erosion and Sedimentation
Control, of the NREPA would apply to any such activity where more than one acre of
land is affected or the regulated action occurs within 500 feet of a lake or stream. Part 91,
Soil Erosion and Sedimentation Control, of the NREPA would be applicable to the cap
construction activities since these actions could impact the Kalamazoo River, which is
less than 500 feet from the KHL-OU 3 and the five former lagoons.
Part 301, Inland Lakes and Streams, of the NREPA:
The Michigan Inland Lakes & Streams Act regulates the dredging or filling of lake or
stream bottoms. Activities associated with the selected remedy, sediment removal, and
berm stabilization are regulated under this Act due to the proximity of the KHL-OU 3 and
the five former lagoons to the Kalamazoo River.
Part 115, Solid Waste Management, of the NREPA:
Part 115, Solid Waste Management, of the NREPA contains regulations regarding the
construction, operation, and closure of sanitary landfills, solid waster transfer facilities,
and solid waste processing plants. These regulations govern the long-term monitoring
and closure of the landfill. The landfill area is licensed under this Act.
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Part 41, Sewerage Systems, of the NREPA:
Part 41, Sewerage Systems, of the NREPA establishes rules regarding construction.
operation, and maintenance of sewage systems. This may be applicable since the treated
dewatering water is discharged to the municipal sewer system.
Part 31, Water Resources Protection, of the NREPA:
Part 31, Water Resources Protection, of the NREPA establishes the rules regarding water
and wastewater discharges, provisions for the non-degradation of groundwater quality,
and uses of groundwater. This is applicable for discharge of waters to the Kalamazoo
River. Part 31, Water Resources Protection, of the NREPA also includes the rules
regarding permit requirements for discharges. Although permits are not required for on-
site Superfund actions, the substantive requirements rrfust be met for all dewatering
operations that discharge to the Kalamazoo River.
Part 55, Air Pollution Control, of the NREPA: '
Rules prohibiting the emission of air contaminants in quantities which have injurious
effects on human health, animal life , plant life of significant economic value, and/or
property are established in Part 55, Air Pollution Control, of the NREPA. This would be
applicable to excavation and cap construction activities.
Michigan Occupational Safety and Health (MIOSHA) Act 154:
MIOSHA establishes the rules for safety standards in the work place and is applicable to
the remediation activities.
TSCA, 40 CFR 761, sets specific requirements for the disposal of PCBs and would
therefore be applicable to the site.
Part 201, Environmental Remediation, of the NREPA:
As described earlier, the NREPA provides for the identification, risk assessment, and
evaluation of contaminated sites within the state. The MDEQ has determined that the
substantive provisions of Part 201, Environmental Remediation, of the NREPA are
applicable or relevant and appropriate to the KHL-OU 3 and the five former lagoons.
Part 201, Environmental Remediation, of the NREPA rules require that RAs shall be
protective of human health, safety, welfare, and the environment of the state.
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3. Cost-Effectiveness
Table 1 lists the costs associated with implementation of the selected remedy.
Table 1
Total estimated cost for the selected remedy at the KHL-OU 3:
Alternative Total Capital Cost Total O&M. per Yr. Total Present Worth
1 $1.6-$2.7 million $125,000 $3.2 - $4.3 million
The selected remedy for the KHL-OU 3 And the five fprmer lagoons are cost-effective
because it provides the greatest overall effectiveness proportionate to its cost when
compared to the other alternatives evaluated, the net present worth being $3.2 - $4.3
million. The estimated cost of the selected remedy is much lower than the cost of
Alternatives 2 and 3, and assures a high degree of certainty that the remedy will be
effective in the long-term due to the significant reduction of the mobility of the PCBs
achieved through containment of the source material and the prevention of leachate
generation.
4. Utilization of Permanent Solutions and Alternative Treatment 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 KHL-OU 3. Of
those alternatives that are protective of human health and the environment and that
comply with ARARs, the state of Michigan and the EPA have determined that the
selected remedy provides the best balance in terms of long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume of contaminants, short-term
effectiveness, implementabiliry, and cost, taking into consideration state and community
acceptance.
Consolidation of residuals outside the landfill into Cell 4 in addition to the installation
and maintenance of a final cover for the landfill, groundwater monitoring, and restriction
of access through installation of a fence and institutional controls, will provide the most
permanent solution practicable, proportionate to cost.
5. Preference for Treatment as a Principal Element
Based on current information, the EPA and the State of Michigan believe that the selected
remedy is protective of human health and the environment and utilizes permanent
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solutions and alternative treatment technologies to the maximum extent possible. The
remedy, however, does not satisfy the statutory preference for treatment of the hazardous
substances present at the KHL-OU 3 as a principal element because such treatment was
not found to be practical or cost-effective at the KHL-OU 3.
K. SUMMARY
The selected remedy will satisfy the statutory requirements established in Section 121 of
CERCLA, as amended by SARA, to protect human health and the environment, will
comply with ARARs or provide grounds for invoking a waiver, and will use permanent
solutions and alternate treatment technologies to the maximum extent practicable.
i
Treatment is not a component of the selected remedy because an attempt to treat the
PCBs present at the KHL-OU 3 and the five former lagoons would not provide a
sufficient significant additional decrease in risk presented by the KHL-OU 3 and the five
former lagoons to justify the increased cost of attempting to incinerate the PCBs.
L. RESPONSIVENESS SUMMARY
The public participation requirements of CERCLA sections 113 (k) (2) (i-v) and 117 of
CERCLA have been met during the remedy selection process. Section 113 (k) (2) (i-v)
and 117 of CERCLA require the state as the lead agency to respond "... to each of the
significant comments, criticisms, and new data submitted in written or oral presentations"
on a Proposed Plan for an RA. The Responsiveness Summary addresses the concerns
expressed by the public, PRPs, and governmental bodies in written and oral comments
received by the MDEQ regarding the Preferred alternative for the KHL-OU 3.
OVERVIEW
At the time of the public comment period, the MDEQ as lead agency, in consultation with
the EPA, the support agency, had proposed a preferred alternative for the KHL-OU 3 in
the city of Kalamazoo, Michigan. The preferred alternative addressed the PCB-
contaminated soils, sediments and residuals associated with the KHL. The preferred
alternative specified in the ROD includes capping and containment of the KHL. Prior to
construction of the cap, the excavation and on-site containment of PCB-contaminated
soils, sediments and residuals from the landfill berms, Georgia-Pacific Corporation's five
former lagoons, the adjacent river, and the KSSS floodplain, into Cell 4 of the KHL, will
be conducted.
Judging from the comments received during the public comment period, the selected
alternative was generally supported. The residents would prefer not to have a
nonproductive zone (i.e., the closed landfill) in their community and their comments dealt
with issues of the long-term effectiveness of the selected alternative. The PRPs would
only support the selected alternative.
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These sections follow:
Background on Community Involvement and Concerns
Summary of Comments Received During the Public Comment Period and the MDEQ's
Responses
Attachment: Community Relations Activities at the KHL OU 3
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Prior to the KHL being included in the site as a source area, community involvement was
non-existent. Since the KHL became part of the site, the MDEQ has issued seven
progress reports and hosted eleven public meetings during the scoping of the RI for the
KHL-OU 3, the five former lagoons, and the site. During the public meetings the MDEQ
provided background information on the KHL-OU 3 and the five former lagoons,
explained the Superfund process, and provided details of the upcoming investigation.
During July 1993, the MDEQ issued a fact sheet describing the RI work being conducted
at the KHL-OU 3. All phases of the RI were completed by December 1996. The MDEQ
issued other fact sheets and progress reports summarizing the results of the investigation.
The MDEQ distributed a third fact sheet in June 1996 that described the dike stabilization
project conducted as an interim action.
The EPA awarded a Technical Assistance Grant (TAG) for this site to the Kalamazoo
River Protection Association (KRPA). The KRPA is a member of the Citizens Advisory
Committee (CAC) established by the MDEQ. The MDEQ also established the
Government Advisory Committee (GAC) comprised of all interested elected officials
from local, state and federal governments. A list of meeting dates, attendees, and topics
discussed at each meeting concerning the KHL-OU 3 can be found in Attachment 1 of
this ROD.
f
Results of the RI were presented to the GAC/CAC on March 9, 1994. Results of the Risk
Assessment and Focused Feasibility Study (FFS) were presented to the GAC/CAC on
August 24, 1994. The results of the Cell 4 investigation performed in January 1995 were
presented at GAC/CAC meetings in March 1995. Technical Memorandum 15, Mill
Investigations, contains the results of the RI for the five former lagoons. This document
was placed in the six information repositories listed in Table 2 in August 1996.
Fieldwork for the KHL-OU 3 RI got underway in July 1993. The MDEQ held nine
meetings and issued eight progress reports/fact sheets detailing the RI work and the RI
findings at the KHL-OU 3. The RJ and FS reports were released to the public and placed
in the six information repositories, listed in Table 2 , in July 1994 and in September 1994,
respectively. The Proposed Plan was also released for public review in September 1994.
The Administrative Record has been made available to the public at the Superfund
Section of the MDEQ in Lansing, Michigan, and at the six information repositories
established at the locations shown in Table 2.
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In August 1994 the MDEQ approved the FFS report. The Proposed Plan for the KHL-
OU 3 was released to the public for review in September 1994. These documents were
made available to the public at the office of the Superfund Section. MDEQ. in Lansing.
Michigan, and the information repositories.
TABLE 2
Allegan Public Library
180 South Sherwood
Aliegan, Michigan
(616)673-4625
Charles Ransom Library
331 Hubbard Street
Plainwell, Michigan
(616)685-8024
Comstock Township Library
6130 King Highway
Comstock, Michigan
(616)345-0136
Kalamazoo Public Library
316 South Rose
Kalamazoo, Michigan
(616)342-9837
Otsego District Library
219 South Farmer *
Otsego, Michigan
(616)694-9690
Waldo Library
Western Michigan University
Kalamazoo, Michigan
(616)387-5156
A public meeting was held on September 14, 1994 to discuss the FFS and the Proposed
Plan. The meeting was attended by approximately 25 persons, including local residents
and representatives of the PRPs. At the meeting, representatives from the MDEQ and the
PRPs answered questions about the KHL-OU 3 and the remedial alternatives under
consideration. Formal oral comments on the Proposed Plan were documented by a court
reporter. A verbatim transcript of questions and answers and public comments during the
public meeting has been placed in the information repositories and Administrative
Record. Written comments were accepted at the meeting and by mail and were also
included for placement in the information repositories.
The Proposed Plan was available for public comment from September 14, 1994 through
November 14, 1994. Comments received during this public comment period were
reviewed, and the MDEQ's responses are included in this Responsiveness Summary.
Advertisements announcing the availability of the Proposed Plan and start of the public
comment period were published in the Kalamazoo Gazette, the Union Enterprise, Allegan
County News & Gazette, Holland Sentinel, and the Kalamazoo Gazette-North.
Responding to public comments and a request by the MDEQ for additional groundwater
and Cell 4 data, the PRP's conducted additional limited RI sampling. In the meantime,
the Mill investigation was completed and the five former lagoons were identified as an
area in need of remediation. Because of the modifications made to the original preferred
alternative, the MDEQ issued a Revised Proposed Plan on July 1, 1997. The public
comment period was from July 1, 1997 through July 30, 1997. A Revised deposed Plan
meeting was held on July 16, 1997. Comments received during this public comment
period were reviewed, and the MDEQ's responses are included in this Responsiveness
Summary. Advertisements announcing the availability of the Proposed Plan, the
Proposed Plan meeting, and start of the public comment period were published in the
No longer an information repository for the site. It has been replaced by the Saugatuck-Douglas District
Library, Center Street, Douglas, MI 49406, 616-857-8241.
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Kalamazoo Gazette, the Union Enterprise, Allegan County News & Gazette, Holland
Sentinel, the Kalamazoo Gazette-North, and City Life (published by the Kalamazoo
Gazette).
SUMMARY OF SIGNIFICANT COMMENTS
Many of the comments below have been paraphrased to effectively summarize them in
this document. The reader is referred to the Administrative Record, located at the
Information Repositories, which contains copies of all oral and written comments
submitted to the MDEQ.
Comment 1 J
Several commenters and the KRPA expressed concerns regarding the amount of time for
review of the RI/FFS documents. Specific comments iriclude: there should have been
more time prior to the September 14 public meeting to review the documents; the time for
providing comments on the Proposed Plan should be extended; and there should be
another meeting to answer questions.
Response 1
In response to the expressed concerns regarding the amount of time to review the RI/FFS
documents and develop comments, and a specific request made during the public meeting
on September 14,1994, the public comment period was extended an additional 30 days to
November 14, 1994.
Both the state, and federal regulations require that the public be given opportunities to
review and comment on proposed RAs. As stated in Part 201, Environmental
Remediation, of the NREPA, Section 324.20120d, the public is encouraged to comment
prior to MDEQ approval of a proposed plan for RA. In the CERCLA regulations [40
CFR 300.430(f)(3)(I)(C)J, a minimum of 30 days is provided to review the Proposed Plan
and supporting information.
Based on the MDEQ's experience in landfill remediations under the NREPA , the agency
believes that a 60-day comment period in this case is sufficient to obtain complete public
comments on the Proposed Plan. The MDEQ will continue to meet with the public
regarding the Allied Paper, Inc./Portage Creek/Kalamazoo River Superfund site.
Comment 2
Two commenters provided comments related to the future recreational use of the river in
the area of the KHL. The expressed concerns were that Alternative 1 needs to be
compatible with future recreational use, which may include the proposed river trail
system and boating activities along the river. Specific comments included that
Alternative 1 should not pose a physical danger to boaters and that related liabilities be
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addressed, and that the remediated K.HL-OU 3 should not pose a danger to future users of
a river trail system.
Response 2
The post-closure plan for the KHL-OU 3 will necessarily include institutional controls
such as access restrictions as required by Part 115, Solid Waste Management, and Part
201, Environmental Remediation, of the NREPA. Nevertheless, the implementation of
Alternative 1 is not expected to prohibit the development of a trail in the area.
Alternative 1 is protective of human health and the environment. Protectiveness is
provided by the NREPA cap, dike stabilization, consolidation of residuals, erosion
control, long-term monitoring, and institutional controls. The landfill cap and
institutional controls protect the public from exposure to PCBs contained in the landfill.
The steel sheet-pile wall was installed to stabilize the landfill dike. The design of this
wall does not present a hazard to navigation.
The nature of liabilities for the owner of the landfill and users of the adjacent river is
essentially the same as those that exist today or those that are associated with other
private lands along the river.
Comment 3
Two commenters and the KRPA provided comments regarding the compliance of
Alternative 1 with ARARs, questioning whether Alternative 1 complies with Acts 307 or
641. In addition, the commenter stated that "the interpretation of 40 CFR 761 is not
satisfactory." The commenter claimed that the "standards" of Act 307 would not be met
by Alternative 1 and that the alternative would "not meet the full construction
requirements for full compliance with Act 641."
Response 3
During the FFS evaluation process, all three alternatives were assessed as to their
compliance with federal and state ARARs. As noted in the text of the ROD, Part 115,
Solid Waste Management of the NREPA (formerly Act 641) provides siting,
construction, cap, monitoring and other requirements for certain Michigan landfills.
Because Cells 1 through 3 of the KHL were licensed prior to implementation of Part 115,
the regulation's siting and construction requirements do not apply to these cells.
Furthermore, MDEQ does not believe the siting and construction requirements are
relevant and appropriate to the selected alternative. With regard to Cell 4, MDEQ does
not generally require unlicensed landfills that are in the process of closing to comply with
the siting and construction requirements of Part 115. MDEQ believes that such
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requirements are neither applicable nor relevant and appropriate to the remedy selected
for Cell 4 in this ROD.
It is important to note that the remedy selected in this ROD will comply with all of the
closure requirements in Part 115. In other words, MDEQ determined that the capping
and closure requirements of Part 115 were either applicable or relevant and appropriate to
this selected remedy.
Part 201, Environmental Remediation, of the NREPA (which supersedes Act 307)
requires the cleanup of sites to levels which, based upon considerations of future land use,
do not present a risk to human health or the environment. Limited Industrial criteria
apply because the KHL area is, and will continue to be", restricted to industrial land uses
under local zoning ordinances. Based upon analyses contained in the site-specific RA for
the KHL-OU 3 and the FFS, Alternative 1 will put controls in place so the KHL-OU 3
will not present a risk to human health or the environment. Therefore, Alternative 1
meets Limited Industrial criteria and complies with
Part 201, Environmental Remediation, of the NREPA.
The following provides additional information regarding the interpretation of 40 CFR 761
with respect to Alternative 1 as presented in the FFS. The regulations developed under
the TSCA, which govern the disposal of PCB, are.presented in 40 CFR 761. Subpart D -
Storage and Disposal of 40 CFR 761 begins with this note:
"This subpart does not require removal of PCB and PCB Items from service and
disposal earlier than would normally be the case. However, when PCB and PCB
Items are removed from service and disposed of, disposal must be undertaken in
accordance with these regulations. PCB (including soil and debris) and PCB Items
which have been placed in a disposal site are considered to be 'in service' for
purposes of the applicability of this subpart. This subpart does not require PCB and
PCB Items landfilled prior to February 17, 1978 to be removed for disposal...."
The description of the history of disposal of residuals that contained PCB concentrations
50 ppm or greater as presented in the FFS, together with the wide experience base in
applying this "pre-1978" exemption to landfill sites, support the interpretation that 40
CFR 761 is not an ARAR. This would apply to the PCB-contaminated materials that are
capped and contained in-place.
Although the EPA agreed that TSCA was noc an ARAR for the proposed pi«m, the sub-
sequent decision to consolidate residuals from the five former lagoons near the landfill
into Cell 4 resulted in TSCA becoming an ARAR. The TSCA disposal regulations at 40
CFR Section 761.60 et seq. are applicable to PCBs at concentrations of 50 ppm or greater
when such PCBs are "taken out of service". Under the RAs being considered, TSCA
disposal regulations could be triggered by excavation of PCB-contaminated soils, and
residuals from the five former lagoons. These materials will be consolidated into Cell 4.
Pursuant to 40 CFR Section 761.60 (a) (4), PCBs must be disposed of: "(i) in an
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incinerator which complies with 761.70; or (ii) in a chemical waste landfill which
complies with 761.75." The TSCA compliant chemical waste landfill disposal method is
generally much less expensive than incineration.
The on-site consolidation and containment of PCBs, whether from sediments, soils, or
residuals excavated from the five former lagoons will be placed in Cell 4. Cell 4, being
an existing landfill cell does not possess the following chemical waste landfill
requirements found in Section 761.75 (b):
• Bottom liner requirements (the landfill does not have a bottom liner) (761.75
(b)(l)and(2))
• Fifty foot distance between bottom liner and historical high water table
(761.75(b)(3))
• Leachate collection requirements (761.75 (q)(7))
Pursuant to 761.75 (c) (4), the EPA Regional Administrator has determined that one or
more of the requirements in 761.75 (b) is not necessary to protect against unreasonable
risk of injury to health or the environment from PCBs and may waive such requirements.
In this ROD , the EPA Regional Administrator waives the requirements in 761.75 (b) (1),
(2), (3) and (7) for the following reasons:
1. The final RA will provide protection to human health and the environment against
unreasonable risks of injury.
2. No significant reduction in the long-term risks would be gained from off-site disposal
of the small quantity of PCBs in excavated residuals, sediments, and soils because the
bulk of the PCBs will be contained in place under the final cover.
Comment 4
A number of commenters and the KRPA expressed preferences for treatment of the PCB-
containing residuals. For several commenters, this was at least part of their basis for
stating opposition to Alternative 1 and support for alternatives that include removal. For
other commenters, this preference was communicated as part of their support of
Alternative 1 in a recommendation that provisions be made to allow for future treatment
of the residuals at such time as "technology becomes available to treat the affected
residuals," "in a reasonable and safe manner." One commenter recommended the siting
of an incinerator central to all of the OUs to treat not only KHL-OU 3 residuals, but those
from other OUs as well. A related comment offered by one commenter is that Alternative
1 does not address complete reduction of mobility and toxicity.
Response 4
The essential requirement of remediation is that it be protective of human health and the
environment. Alternative 1 satisfies that requirement and has greater short-term
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effectiveness than Alternative 3, which includes treatment. The greater short-term
effectiveness is due to the shorter schedule for completion of Alternative 1 as compared
to Alternative 3 and the fewer short-term negative human health and environmental risks
associated with excavation, transport, and treatment. In addition. Alternative 1 is more
implementable and less costly than
Alternative 3.
The siting of a central incineration facility might in theory reduce the unit costs of
incinerating KHL-OU residuals. The reduction in costs relative to on-site incineration, if
any, (costs for transportation of residuals both to and from the facility would need to be
evaluated) would not sufficiently compensate for the predictable decrease in
implementability that would accompany configuratiort of such an alternative. It is
doubtful that such an alternative would be preferable to on-site incineration.
The potential for future treatment after implementation1 of Alternative 1 exists in the five-
year review provision of CERCLA Section 121(c). The EPA will conduct a review of
site conditions every five years. If, after reviewing site conditions, a significant risk were
found as a result of failure of the remedy to be protective, the remedy will be
reconsidered. At such time, the availability of cost-effective treatment technology could
be further evaluated. It is important to note that treatment will not need to be considered
if the remedy is working as designed.
The implementation of Alternative 1 will provide a reduction in the potential mobility of
the residuals by cap placement, dike stability, and erosion control. Cap placement will
minimize the potential for PCB migration via dust generation, surface water runoff, and
groundwater flow. Dike stabilization and erosion control measures will minimize the
potential for dike erosion or failure, thereby reducing the potential migration of PCB-
containing residuals to both the site and the Kalamazoo River.
Comment 5
Two commenters and the KRPA stated that Cell 4 should be included in the remediation.
Response 5
Cell 4 will be included in the remediation as described earlier. The FFS stated that
additional information was needed to determine the appropriate action for Cell 4. After a
comprehensive probing and sampling investigation of Cell 4 in January 19$ Z, remedial
alternatives specific to Cell 4 were evaluated. The MDEQ concluded that of the four
alternatives (i.e., no action; containment under a cap similar to that selected for Cells 1, 2,
and 3; on-site disposal in Cells 1, 2, and 3; or off-site treatment and disposal),
containment under Part 115, Solid Waste Management, of the NREPA Type III cap
(which includes an impermeable liner) best achieves all criteria required by state and
federal guidelines. An important consideration in the selection process was additional
data that indicate Cell 4 residuals are similar in many respects to residuals contained in
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Cells 1, 2, and 3. These residuals reside at the same elevation, have similar PCS
concentrations, are composed of the same materials, have the same physical properties
and originated from the same production process.
Comment 6
A number of commenters and the KRPA expressed concerns regarding the long-term
effectiveness of Alternative 1. One commenter stated that there must be responses to any
future release of PCB from the KHL-OU 3 if detected by long-term monitoring. Another
commenter believed the issue of infiltration of groundwater beneath the KHL-OU 3
would not be adequately addressed by Alternative 1. One commenter stated that
construction materials that would last more than 30 years should be selected, while
another commented that the selected materials should last 500 years. One commenter
suggested the construction of a "steel sea wall" to provide long-term protection of the
dike. One commenter questioned if a steel retaining Wall had a long enough life
expectancy. Another questioned why only 30 years was used to address monitoring, and
expressed the need for financial assurances for future work at the KHL-OU.
Other comments related to the long-term effectiveness of Alternative 1 included
questions and statements regarding the potential future impacts of river meander and rare
flood events.
Response 6
It was concluded in the FFS that Alternative 1 will be effective over the long-term.
According to the requirements of the NCP, the three alternatives were evaluated using
two threshold criteria and five primary criteria. Long-term effectiveness and permanence
was one of the five primary criteria, and it was concluded that Alternative 1 will provide
for long-term effectiveness and permanence. Long-term monitoring and maintenance of
the KHL-OU 3, including the structures used to isolate residuals and PCB from human
contact and the river, are necessary components of Alternative 1 to assure long-term
effectiveness. As part of the post-closure plan for the permitted landfill, a monitoring
program will be established and approved by the MDEQ.
Monitoring and maintenance activities will proceed for an indefinite period of time to
assure long-term effectiveness. The 30-year duration of monitoring and maintenance
activities employed in the FFS for cost-estimating purposes was selected to be consistent
with EPA guidance. EPA guidance for FS states that "In general, the peridu of
performance for costing purposes should not exceed 30 years for the purposes of the
detailed analysis."
With respect to financial assurances, as required under the current Parts 201 and 115 of
the NREPA Landfill operating permit for the KHL, a Perpetual Care Fund will be
established and maintained to be used exclusively for closure, monitoring, and
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maintenance of the landfill and for response activities necessitated by a discharge from
the facility.
Ongoing monitoring in conjunction with the five-year review provision of CERCLA will
provide the necessary technical, legal, and administrative tools necessary to detect and
respond to conditions to assure the long-term protectiveness of human health and the
environment from PCBs at the KHL-OU.
The design of Alternative 1 will consider the future forces of the river and how changes
in upstream conditions could affect the long-term effectiveness of the alternative.
Specifically, the dike stabilization measures will be designed to withstand the erosive
forces of extreme high-flow events. In addition, changes in upstream land use and
structures that could affect the stability of the containment system at the KHL will be
monitored. The incorporation of such monitoring in Alternative 1 was in response to a
similar comment from the public made on August 24, "1994.
In December 1996 the construction of a steel sheet-pile wall along 900 feet of the dike
that separates Cells 1,2, and 3 from the Kalamazoo River was completed. The work
extends the existing 120 feet of retaining wall installed in 1994 after a storm uprooted
trees on the dike. The FFS reviewed two options for stabilizing the dike: placing rock-
filled wire baskets called gabions, or installing steel sheet pilings. Although gabions
were originally proposed, the steel sheet piling has now been selected and installed
because of its site-specific advantages over gabions. For example, based upon the small
repair project in 1994, there is a greater degree of confidence that the sheet piling could
be properly constructed and result in fewer construction impacts on the river than
gabions. By extending the retaining wall two feet above the 100-year flood elevation, the
sheet pile will prevent surface water runoff from eroding soils into the river and will
protect the dike and KHL-OU from severe flood events.
Comment 7
Three commenters stated their support of Alternative 1. One of the commenters provided
unqualified support noting that it: "is the lowest cost while protecting the environment;"
"doesn't increase short term risk of PCB escaping by disturbing the site;" and "can be
completed more quickly than Alternatives 2 and 3." A second commenter, in agreeing
that Alternative 1 "is the most desirable at this time," also expressed a preference to see
the "site cleaned up" but that he "understandfs] the ramifications of disturtvnce and
incineration, and cannot really see just moving the contaminants to another site.:> The
third commenter noted support of "this remedy as an interim solution."
Response 7
The MDEQ acknowledges these comments.
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Comment 8
One commenter asked a question about how the remediation contract would be awarded
and expressed concerns regarding the quality of remediation if the contract simply went
to the lowest bidder.
Response 8
Although it remains to be determined exactly how contracting would proceed,
performance-based contract specifications and a construction quality assurance program
are prominent and necessary features of remedial contracting. Contractor qualifications
and experience, the reliability of the contractor's proposed approach to meet the
performance specifications, and costs are all important considerations in contractor
selection. Note also that the AOC requires the MDEQ s review of contractor
qualifications and the MDEQ's oversight of all aspects of the remediation to ensure the
remedy is constructed as designed.
Comment 9
One commenter and the KRPA requested another round of groundwater sampling
because the quantitation limit for the analyses of the RI samples (1 ug/L) was higher than
the recommended PCB detection limit presented in MDEQ guidance.
/•
Response 9
In response to this comment, an additional round of groundwater sampling was
performed in August 1995. PCBs were not detected in any of the groundwater samples at
a detection limit of 0.2 ng/L. Also, it should be noted that the compliance groundwater
monitoring program required by the landfill's operating permit has collected several years
of data at or below the MDEQ Target Detection Limit of 0.2 ug/L. PCBs were not
detected in any of these samples.
Comment 10
One commenter claimed that the incineration costs presented in Alternative 3 were
substantially overestimated since fuel costs would be lower because of greater British
Thermal Unit (BTU) value of residuals. It was claimed that as a result, incineration costs
should be only half of those presented in the FFS.
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Response 10
As part of the alternatives evaluated in the FFS, Alternative 3 indicated costs associated
with on-site and off-site incineration. Vendors offering on-site incineration and off-site
incineration services that were contacted during the FFS for cost information noted that
costs for incineration would not likely change based upon any further consideration of the
BTU value of the residuals. Based upon the analysis of the costs of hazardous waste
incineration projects, the reason that total costs are insensitive to the BTU value is that
fuel costs are not a relatively large cost component of hazardous waste incineration
projects. 4
Comment 11
t
Two commenters expressed concern regarding the precedent set by Alternative 1 for the
KHL-OU 3 with respect to containment remedies at other portions of the site.
Response 11
The individual OUs and the site will be investigated and evaluated separately, consistent
with the Consent Order between the MDEQ and the PRPs, and consistent with CERCLA
and Part 201, Environmental Remediation, of the NREPA.
Comment 12
A number of commenters and the KRPA expressed concern about the use of the Part 201,
Environmental Remediation unrestricted residential cleanup criteria for PCBs of 2.3 ppm
being used for the KSSS floodplain soils. Their concern was twofold. The first concern
was that the unrestricted residential cleanup criteria for PCBs of 2 3 ppm is based on
human health and not on ecological receptors such as mink. The second was that this
may set precedent for the cleanup of the Kalamazoo River, Portage Creek and their
wetlands/ floodplains. The commenters recommended that the cleanup criteria be set at
0.33 ppm for sediments to protect the environment. The comments pointed out that this
is the cleanup number that the Surface Water Quality Division (SWQD) of the MDEQ
has recommended at other sites for the cleanup of PCBs in sediments.
Commenters also indicated that using visual criteria for consolidating residuals back into
the landfill from the Kalamazoo River was not appropriate because some of the sediments
in the river that are contaminated do not have the gray clay appearance.
Response 12
The Part 201, Environmental Remediation, unrestricted residential cleanup criteria for
PCBs is now 1.0 ppm and not the previously level of 2.3 ppm that was listed in the
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Revised Proposed Plan. The change in this criteria is due to the change in the percent
absorption factor from 1 percent to 14 percent. This factor is used by both the MDEQ
and the EPA. The MDEQ recognizes that the Part 201, Environmental Remediation,
unrestricted residential cleanup criteria for PCBs of 1.0 ppm is based on risk assessment
for the protection of human health. However, the MDEQ believes that this limited action
on soils using the soil criteria is appropriate and will be protective of human health and
the environment. The focus of the remedial action to consolidate the residuals back into
the KHL from the KSSS floodplain and the Kalamazoo River immediately adjacent to the
KHL is very limited and addresses a very small amount of residuals situated next to the
KHL. This action would consolidate these residuals back into the KHL from which they
originated and prevent them from eroding into the Kalamazoo River where it has the
potential to cause a human health and environmental impact.
This cleanup action is focused on the KHL-OU 3 and not on remediating the Kalamazoo
River or it's floodplains. These areas will be addressed by other RODs. Because the
focus of this ROD is the remediation of the KHL-OU 3 and the five former lagoons and
not remediating the river or floodplains, except in this limited area, it will not set
precedent for the cleanup of these areas. If the ROD for the Kalamazoo River sets more
restrictive cleanup numbers, for the river sediments and floodplain soils, the river and
floodplain area will be re-evaluated to determine if additional actions are necessary.
Commenters are correct in stating that sediments can be contaminated with PCBs and
may not show any visual criteria. The MDEQ acknowledges this fact. Once again the
purpose of this ROD is not to conduct a river cleanup but a consolidation of residuals
back into the KHL for the purpose of remediating the KHL-OU 3. This action will
remediate only residuals that are in the river. Once the RI/FS for the river is completed
and a ROD for the river sets the cleanup criteria for river sediments, the sediments along
the KHL-OU 3 will be re-evaluated to determine if additional actions are necessary.
Comment 13
The KRPA expressed concern that the five former lagoons would only be remediated
down to a PCB cleanup level of 21 ppm.
Response 13
The Part 201, Environmental Remediation limited industrial cleanup criteria for PCBs is
21 ppm. The land that contains the five former lagoons is zoned industrial and, therefore,
it is appropriate to apply the limited industrial cleanup criteria.
Comment 14
Two commenters and the KRPA expressed a concern that the remediation of the KHL-
OU 3 would destroy critical habitat for wildlife along the Kalamazoo River. The
shoreline area of the river acts as a important corridor for wildlife. They requested that a
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green zone be provided along the edge of the river to restore some of the habitat lost by
the construction of the remedy. Another suggestion was to move the edge of the landfill
back from the river to provide a important wildlife corridor.
Response 14
The MDEQ and the Michigan Department of Nature Resources are discussing with the
PRPs the use of plants that would provide both habitat and a green zone at the KHL-OU 3
as part of the remedy. This issue will be investigated in the Remedial Design for the
remedy.
Comment 15 *
One commenter and the KRPA asked for a 30-day extension of the public comment
period for the Revised Proposed Plan. '
Response 15
After careful review of the small amount of modification to the preferred alternative
presented in the original Proposed Plan the MDEQ determined that the 30-day time
extension for public comment was not warranted. The request was denied.
Comment 16
The KRPA opposes the TSCA waiver in favor of the total removal of the PCB-
contaminated waste from the KHL-OU 3.
Response 16
The TSCA waiver applies to the removal of 3,000 cubic yards of PCB-contaminated
residuals and soils from the five former lagoons and its disposal into Cell 4 of the KHL-
OU 3. If the five former lagoons were not being remediated by this action the TSCA
waiver would not be necessary. However, the addition of this material into the KHL-OU
3 prior to construction of the cap will not cause any problems. The materials being
removed from the five former lagoons are identical to the materials already in the KHL-
OU 3, with one exception, the concentrations of PCBs are lower. The review of the
preferred alternative indicates that it is not necessary to require a bottom liner, a leachate
collection system or the 50 foot separation distance between the waste and uie top of the
high groundwater table at the KHL-OU 3. These requirements all focus on resolving a
groundwater contamination problem. The KHL-OU 3 does not have a groundwater
contamination problem to resolve. No PCBs have ever been detected in the groundwater
under the KHL-OU 3. By singing this ROD, the EPA Regional Administrator will have
determined that these three requirements are not necessary to protect human health and
the environment against unreasonable risk or injury.
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Attachment 1
Community Relations Activities for the KHL-OU 3 of the Allied Paper, Inc./Portage
Creek/Kalamazoo River Superfund Site
Community relations activities conducted at the KHL-OU 3 have included:
Decembers. 1990 Pre-meeting With Local Officials
A meeting was held with local elected officials prior to the general public meeting on the
scoping ofthe RJ. The site history, Superfund process, RJ, and the TAG were discussed.
December 12. 1990 Public Information Meeting
The start ofthe scoping process for the RI was announced. Held in the city of
Kalamazoo, this meeting provided information about trie site history, the Superfund
process, the RI, and the TAG. It was also the first meeting since the site was placed on
the NPL.
March 19.1991 Public Information Meeting
Attendees included two neighborhood organizations from the city of Kalamazoo. Site
history, RI scoping, the Superfund process, the AOC and risk assessments were
discussed.
January IS. 1992 Public Information Meeting
Progress on the development ofthe RI/FS work plan and site status were presented at the
meeting held in the city of Allegan. The KRPA discussed the TAG.
December 2. 1992 Meeting with the KRPA
TAG responsibilities and the KRPA's role in the Superfund process and the community
were discussed at the meeting. Scoping for the RI was also discussed.
January 13. 1993 First GAC Meeting
Twenty participants from local governments were present at the meeting held in the city
council chambers in the city of Plainwell. The January 1993 Site Problem statement was
distributed and discussed and Progress Report #5 concerning the RI was reviewed.
February 17. 1993 Public Information Meeting
A progress report on the work plan development for the RI was presented. The project
managers explained the Superfund process and discussed the OU work plan. A brief
overview ofthe Portage Creek/Kalamazoo River work plan was also presented.
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February 23. 1993 GAG Meeting #2
The MDEQ and GAC members discussed OU work plans at the meeting held at the
Parchment City Hall.
March 3. 1993 Public Information Meeting
A progress report on the RI was presented at the meeting which was held in the city of
Allegan. Project managers presented an explanation of the Superfund process and
discussed the Portage Creek/Kalamazoo River work plan development. A brief overview
of the OU work plan was also presented.
March 18. 1993 First CAC Meeting '
The project managers presented a description of the Superfund process, an overview of
the work plan development, and other site information. The KRPA was introduced to the
public. There was a presentation on the Area of Concern program, a program
administered by the SWQD that addresses a variety of issues related to the river basin.
The meeting was held at the Plainwell Comfort Inn in the city of Plainwell.
November 3.1993 CAC Meeting #4
The MDEQ discussed the Superfund process and gave a progress report and update on
the KHL-OU 3 and the site RI. The schedule for submittal of draft documents to the
MDEQ was distributed and discussed. The meeting was held at the Plainwell Comfort
Inn in Plainwell.
Novembers. 1993 GAC Meeting #6
The MDEQ discussed the Superfund process and gave a progress report and update on
the KHL-OU 3 and the site RI. The schedule for submittal of draft documents to the
MDEQ was distributed and discussed. The meeting was held at the Plainwell Comfort
Inn in Plainwell.
November 18. 1993 Presentation to the Kalamazoo Environmental Council
The MDEQ presented the Superfund process, updated site progress, and gave an
overview RI/FS. Future expectations related to the RI were also discussed.
December 8. 1993 Public Information Meeting-Progress Update
The MDEQ provided an overview of the Superfund program and an update on the
progress being made in the KHL-OU 3 and site RI. Additional comments were provided
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by the KRPA. Approximately 40 people attended the meeting, which was held at the
Comfort Inn in Plainwell.
March 5. 1994 GAC Meeting #8. CAC Meeting #6
The results from the RI of the KHL contained in Technical Memorandum #6, King
Highway Landfill Operable Unit, were presented and a project update was provided. The
meetings were held at the Comfort Inn in Plainwell.
August 24. 1994 Combined GAC & CAC Meeting
A presentation on the FFS for the KHL was given to the CAC and elected officials.
Meetings were held at the Comfort Inn in Plainwell.
September 14. 1994 Proposed Plan Public Meeting
The King Highway Proposed Plan public meeting was held at the High School in
Comstock.
March 8. 1995 Combined GAC and CAC Meeting
The KHL-OU 3 was discussed, as well as additional RI work and the ongoing PRP
search.
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