United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA.>ROD.R05-35 021
September 1985
&EPA
Superfund
Record of Decision:
Cemetery Dump, Ml
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/ROD/R05-85/021
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Cemetery Dump, MI
5. REPORT DATE
September 11, 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
1 1. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Cemetery Dump Site is located in Oakland County, Michigan, approximately 35
miles northwest of Detroit. The 4 acre site was once used as a sand and gravel pit
which has been backfilled and cleared. Citizen reports allege that approximately 300
to 600 barrels were dumped and buried onsite in the late 1960s or early 1970s. In
September 1981, the Michigan Department of Natural Resources excavated and transported
offsite approximately 20 to 30 barrel fragments. Analysis of the barrel contents indi-
cated the presence of paint sludges, solvents, PCBs and oils.
This ROD is a source control remedial action that includes excavation and disposal
of approximately 250 drums at an offsite RCRA facility. Total capital cost for the
selected remedial action is estimated to be $1,883,261. Any additional remedial
actions will be addressed in a separate Record of Decision upon completion of the
RI/FS.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI FicM Gr.'u
Record of Decision
Cemetery Dump, MI
Contaminated Media:
Key contaminants:
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Record of Decision
Operable Unit Remedial Alternative Selection
Site: Cemetery Dump, Oakland County, Michigan
Documents Reviewed
I have reviewed the following documents describing the analysis of cost-
effectiveness of remedial alternatives for the cemetery site.
- Remedial Actions Master Plan - Cemetery Site
- Phased Feasibility Study/Cemetery Industrial Waste Dump -
July 1985
- Responsiveness Summary
- MDNR Geophysical Report - Cemetery Site
Description of Selected Remedy
- Excavation of approximately 250 drums containing paint sludges,
solvents, polychlorinated biphenyls (PCBs), and oils, which
will be disposed at a RCRA (Resource Conservation and Recovery
Act), Subtitle C, approved off-site landfill facility.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, and the National Contingency Plan (40 CFR Part 300),
I have determined that removing the buried drums at the Cemetery Dump is a
cost-effective remedial action and provides protection of public health,
welfare and the environment. The State of Michigan has been consulted and
agrees with the approved remedial action.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust fund monies for use at other
sites. In addition, the off-site transport and secure disposition is
more cost-effective than other remedial action, is necessary to protect
public health, welfare, and the environment and is consistent with anti-
cipated final remedy.
The Michigan Department of Natural Resources (MDNR) under a Cooperative
Agreement with the U.S. Environmental Protection Agency (USEPA) has initi-
ated a Remedial Investigation/Feasibility Study (RI/FS) at Cemetery Dump to
evaluate potential contamination pathways and will determine the potential
contaminants remaining on-site after the buried drum removal. Any addi-
tional remedial actions will be addressed in a separate Record of Decision.
Date I ' Valdas V.' Ada*us /_ /
Regional Administrator
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Summary of Operable Unit Remedial Alternative Selection
Cemetery Dump Site
Oakland County, Michigan
Site Location and Description
The Cemetery Site is located in the NE 1/4 of Section 27, Rose Township
(T4N.R7E), Oakland County on Rose Center Road approximately 35 miles north-
west of Detroit (Figure 1). The 4 acre site is a former sand and gravel
pit which has been backfilled and is generally clear with low brushy vege-
tation and grass cover. An estimated 250 drums are buried in scattered
groups within an approximate 2 acre area.
j
Five domestic wells are located within 100 feet of the site perimeter which
all derive drinking water from the same unconfined aquifer. The same
aquifer is continuous in the Cemetery Site area and is used as an area wide
water supply. The residents adjacent to the dump have reported the dis-
covery of drum fragments and waste deposits encountered during gardening.
Site History
Citizen reports allege that approximately 300 to 600 barrels were dumped
and buried in an old sand and gravel pit (Cemetery Site) in the late 1960's
or early 1970's. The original site owner, Howard Wilson of Holly, Michigan,
was approached by Tucker Ford (a waste hauler) during this time period to
bury some 500 drums at the Cemetery Site. The disposal of the hazardous
wastes at the Cemetery Site was an illegal dumping incident. Consequently,
no records are available describing the disposed materials.
The parcel of land was subsequently subdivided and sold, and 4 residences
were built on site (Figure 2). Portions of drums have been observed on the
surface of the site and area residents have reported the discovery and
removal of drum fragments and waste deposits encountered during gardening
and other activities.
In September 1981, the MDNR excavated and transported off-site approximately
20 to 30 barrel fragments. Analysis of the barrel contents indicated the
presence of paint sludges, solvents, polychlorinated biphenyls (PCBs) and
oils. (Table 1)
The site was placed on the National Priorities List in 1982. The MDNR
entered into a Cooperative Agreement in May 1984, with the U.S. EPA to
conduct the Remedial Investigation/Feasibility Study (RI/FS) and Phased
Feasibility Study (PFS), formerly known as the Focused Feasibility Study.
The RI/FS is scheduled to be completed in the fourth quarter fiscal year
1986.
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-^ r> :">:L • ' <• '•' • '" ~
FIGURE 1
I \
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U
LEGEND
— — *ROPERTV LINE
GREATEST NUMBER OP BURIED DRUMS
SIGNIFICANT NUMBER OF BURIED DRUMS
SEFT ic SYSTEM
• WELL.MONITORING WELLS LABELED B-1
THROUGH B 3
T>>it tkrictt it »" titimatc o' tN« location of tht diioetal »rtt in rdtt'On
IO p'Opvny lint*, wtlli. HoulM. tcl. It il t eempllittien Of thr«« difftftnt m«oi:
1) An M'i*l photo of tn« «it* Uktn in 1980 (Sc*if 1" • 300')
2) A ikttcft of tn« •Mil loeviioni by Ecology *nd Environn«nt. Inc.
on ScottrnM' t. 1B83.
3) A rr»o of tnt bwfi«d d'umi from tn« irwgnttonwttr nudy
by Ecology •id En«>'onm««t on April 19. 1987.
SCALE IN FEET
FIGURE 2
SKETCH OF CEMETER Wl IE
2-3
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TABLE
1
Inorganics
.ANALYSES OF DRUM CONTENTS AT CEMETERY SITE
AS PRESENTED IN RAMP
(September 1981)
E.P. Toxicity Test EP Toxicity
Concentration Range Concentration Maximum Concentration
Chemical
Organics
Xylene
Toluene
Benzene
Chlorobenzene
Cumene
Total Halogens
PCBs
Aroclor 1242
Aroclor 1254
Aroclor 1260
(rag/kg) (mg/2)
10 - 1000' s
10 - 1000' s
10 - 1000' s
10 - 1000' s
10 - 1000' s
<300 - 1130
ND - 280
ND - 60
ND - 2.0
(mg/2)
..
—
—
«•
--
• m
--
--
--
Arsenic
(Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Hexavalent Chromium
Copper
Zinc
Nickel
1.5 - 7.0
<8.0 - 920
1.6 - 11
16 - 380
90 - 370
0.034 - 0.48
<0.3 - 0.5
<2
<0.1 - 0.63
9.6 - 45
99 - 9,290
18 - 110
<0.002 -
0.46 -
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-2-
Current Site Status
Subsurface conditions at the Cemetery site can be described as glaciofuvial
sediments comprised of interbedded watarland deposits of sand and gravel,
silt and sand, and local deposits of glacial till. The subsurface soils
encountered during the drilling of boreholes at the site consisted primarily
of fine to coarse silty sand and gravel. The overall formation appears to
be a coarse textured glacial till, with a matrix that has variable amounts
of cobbles and boulders. Except for sporadic occurrences of non-sorted
clayey or silty lenses and a lack of stratification, it resembles an outwash
deposit. There is no evidence of a continuous shallow confining layer
underlying the entire site. The absence of a continuous naturally occurring
barrier is critical to assessing the hazardous potential of wastes remaining
at the site because there is no subsurface -layer to prevent migration of
buried wastes to the water table.
The depth of the water table at the site is estimated to range from 35 to
40 feet. The contour of the water table is flat directly beneath the site'
which may'be due to the very high permeability of the soils. The water
table gradient apparently increases quickly to the east of the site and
tends to parallel the ground surface topography which would mean that ground
water flows generally east-northeasterly. Because of the flatness of the
water table in the site area, it is possible the direction of ground water *
flow may be modified in response to slight seasonal variations in water
table elevations. The ongoing RI/FS will concentrate on the specifics of
ground water conditions. However, based on the geophysics, test pits and
soil borings, there is an obvious threat to the private water supplies
adjacent to the site and in the surrounding area since there are no confining
clay layers to protect the water supplies. Assuming the ground water flow
varies with seasonal fluctuations and the cone of influence from the private
water supplies may extend below the buried drums, the closest water supply
(Figure 3) threatened is within 200-300 feet of the main disposal area.
The PFS relied upon geophysical techniques and test diggings to character-
ize the Cemetery Site. An initial site reconnaissance used an electro-
magnetometer to field screen the site for the location of buried metal
objects. Equipment tests indicate that the electromagnetometer would
detect a single 45 gallon drum to a depth of 12 feet of the Cemetery Site.
Twenty-nine suspect areas gave indications of buried metal objects. Most
of the outlined areas showed responses indicative of metal objects scattered,
rather than in clusters.
Based on the electromagnetic data, areas were selected to be scanned using
ground penetrating radar (GPR). A total of 9 areas were defined for GPR
surveying.
The results of the GPR survey were used to select a 20 foot by 20 foot area
for test digging. Sixteen cylindrical or point metal targets defined as
drums or partial drums are shown within the area along with one metal target
not considered a drum. Additionally, a large portion of the southeast
quadrant does not exhibit any target characteristics representative of dr-jms
or drum fragments.
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'OUim W MONiTOMiNG MU MSMLLCO B'
10 KM
t,., IOC*HONO> HONITOKINO WtLL MSTUI CO •>
ALT «MO WII2IC (NCMIlKlHb.MC IJW.T.I9IJI
.... IOC«T 4"PVC OMNCUSCOrtn DO*NMOl(
• UIOUND txcTiMiNc iuo«iiurii>uM'.iw:i
imi.*uv« » •••".•.'(
FIGURE 3
DRUM DISPOSAL AREA
CfMCTFRv SIT:
MO5I TOWNSHIP. MlCllK'.AN
• i (" v w •••\\>:r •
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-3-
Results of the test digging are shown on Figure 4. Subsoils in the dig
area are extremely cobbly. Fourteen metal objects were uncovered which
correlate with defined radar targets. When radar indicated no metal tar-
gets (i.e., the major portion of the southeast quadrant), none were
encountered. The accuracy of metal objects directly relatable to radar
targets is 88%. Of the 15 radar targets considered to be drums (partial,
whole, or fragments), 8 were confirmed as whole or partial crushed drums.
Five drum fragments along with a 10 foot length of wire stranded cable
and drum ring make up the remainder of the excavated objects. The cable
and drum ring were clustered relatively close together resulting in their
appearance as one radar target. Physical conditions of the drums and
drum fragments are very poor (heavily corroded, perforated, deformed).
Vertical (depth) error is greater than horizontal location error. The
largest error for estimated target depth compared to actual depth was
object 5 which was estimated at 7 feet and was actually encountered at
2 feet. Estimated depth errors ranged from 0 feet to 5 feet for all 14
objects (Figure 4). However, only 3 of the 14 objects ( #5, #6, & #9)
were found more than 2.5 feet from their forecast locations.
Reevaluation of geophysical data, particularly radar signal confidence
after ground truthing, indicates the estimate of 237 whole or partial
drums is reasonable. If the test dig area is representative of the
entire survey area, the error of estimate for drum count is less than 20X.
Based on the electromagnetic survey, ground penetrating radar survey, and
test digging the MDNR concluded:
0 The maximum depth of the old gravel operation was 24 feet from
the present ground surface
0 A 50 foot x 70 foot area may contain subsoils contaminated by
spilled liquids
0 Four areas contain 99% of the drums
0 No drums are buried at a depth greater than 16 feet from the
present land surface
Drum sample results from the May 1985 test digging are shown in Table 2.
The data set was not available during the drafting of the PFS, but has
recently been received and validated.
Acetone, toluene, chlorobenzene, naphthalene, bis (2-ethylhexyl)phthalate, and
di-n-pctyl phthalate are regulated hazardous wastes under RCRA. Methylene
chloride is a known human carcinogen. Chlorobenzene is a suspected human
carcinogen. Aroclor 1254 and 1248 are regulated by the Toxic Substance
Control Act (TSCA) as a toxic substance.
Enforcement
CERCLA related enforcement activity began in June 1985. A total of 14
potential responsible parties had been identified for the Cemetery Site.
Notice letters were sent to each party and a meeting was held to discuss
the PFS. The potential responsible parties declined the opportunity to
design and implement the operable unit on July 30, 1985.
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«f
•
.---•>
Ill
el
0*
eSv
la*
- r
-a
>
O>x
zD
iD
'
OHE IMCH EQUALS FIVE FEET
REFERENCE TABLE
OBJECT
NUMBER
ASSOCIATED
RADAR TARGET
DEPTH
DEPTH BELOW
SURFACE IN
FEET
DESCRIPTION
1
t
5
4
9
0
7
a
0
to
II
It
IS
14
t'
8.8'
4S'
l.f
7'
4§
t'
4'
4*
6'
§'
e'
r
4'
4'
4'
44
r
t*
r
IB-
S'
•'
_•
4' J
s*
8*
2*
1§
10" «Y 8" DRUM FRAGMENT
CRUSHED METAL DRUM
CRUSHED METAL DRUM
CnuSMSD METAL DRUM
CfiUCHED METAL DRUM
CRUSHED MiTAL DRUM
DflUM FRAGMENT
I'iYl', ANCl'SY6" DRUM
FRA4MENTS
CRUSHED METAL DRUM
/•METAL CABLE
IDRUM RIN«
CRUSHED DRUM FRAG»£«T
CRUSHED METAL 0«Un
DRUM FRAGMENT
CRUSHED METAL DRUM
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Table 2
May 1985 Drum Sample Analysis
Methylene Chloride
Acetone
2-Butanone
Toluene
Ethyl benzene
4-Methy1-2 Pentanone
Chlorobenzene
Naphthalene
Bis (2-Ethylhexyl) Phthalate
2-Methyl naphtha!ene
Di-n-octyl Phthalate
Aroclor 1254 and 1248
Alternatives Evaluation
'•' i»^-^™~ j
The PFS was initiated to evaluate the appropriate source control remedial
action alternatives at the Cemetery Site. Preventing the release of the
contaminants would eliminate the threat to the unconfined aquifer which
is used by the area residents for water supply. According to the U.S. EPA
Ground Water Protection Strategy published in August 1984, the threatened
aquifer at the Cemetery Site appears to be a Class I-Special Ground Waters.
This class of ground water is "highly vulnerable to contamination because
of the hydrological characteristics of the areas under which they occur..."
Based upon available data from the soil borings, geophysics, and test pits
this unconfined aquifer is "irreplaceable, in that no reasonable alternative
source of drinking water is available to substantial populations." The
specific criteria to define each class have not been published for public
review and the classification for this aquifer may change.
Contact with the drums must also be considered in the remedial action alter-
native. Although the drums are buried, the neighbors to the site have
reported the uncovering of drums and wastes during gardening and other
activities within their backyards. This material has been subsequently
removed when encountered by the residents.
Based on the identification of the waste sources and potential receptors,
the PFS screened several alternatives which would be appropriate for the
Cemetery site. The screened alternatives are presented in Table 3.
Subsequently the four alternatives listed in Table 4 were proposed for detailed
evaluation based on the following parameters:
1) Constructability
2) Reliability
3) Implementation
4) Cost
5) Level of Protection
6) Volume reduction
7) Adverse environmental impacts
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TABLE 3
SUMMARY OF INITIAL SCREENING OF TECHNOLOGIES
Initial Screening
Category
of Action
Response
Action
Remedial
Technology
Considered
Acceptable
Engineering
Practice
Effectiveness
Overall
Status
Removal
excavation
on-site
landfill
flushing
off-site
land
disposal
on-site removal and drain- feasible
ing of drums, removal of
soils
excavation, disposal on-
site in an approved hazar-
dous waste facility
water extraction (and sub-
sequent treatment of sub-
surface wastes)
disposal off-site disposal
in an approved hazardous
waste storage facility
Treatment in situ favored use of soil bac-
biodegradation teria to promote chemicals
b i odeg rada t i on
land surface/subsurface bio-
treatment degradation
incineration on-site high temperature
destruction in mobile
incinerator
feasible
possibly
feasible
feasible
uncertain
effective
effective
unknown
feasible
uncertain
feasible uncertain
not feasible effective
in this case
thermal destruction in a feasible
permanent off-site facility
effective
acceptable
acceptable
unacceptable
acceptable
unacceptable
unacceptable
unacceptable
acceptable
Page retyped for NTIS - October 1, 1985
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TABLE 3
SUMMARY OF INITIAL SCREENING OF TECHNOLOGIES
Initial Screening
Category
of Action
Receptor
Avoidance
Response
Action
no action
alternate
water suppl
Remedial
Technology
Considered
posting of area
development of new public
y water supply for area
Acceptable
Engineering
Practice
feasible
feasible
Effectiveness
possibly adequate
short-term-future
status uncertain
not warranted at
this time
Overall
Status
acceptable
unacceptable
fencing
institutional
constraints
On-site capping
Containment
permanent site restrictions feasible
legal restriction on site marginal
use and access
partially effec-
tive at preventing
access
not effective
acceptable
with other
technologies
unacceptable
multi-barrier capping
system
feasible
questionable for
stopping subsur-
face migration
acceptable
with other
technologies
vitrifica-
tion
solidifi-
cation/fix-
ation
subsurface
barrier
walls
in-place high temperature
solidification
waste excavation followed
by chemicals mixing
installation of a perimeter
subsurface and impermeable
material
not
established
feasible
feasible
unknown
unknown
ineffective to
retard migration
unacceptable
unacceptable
unacceptable
retyped for NTIS - October 1, 1985
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-5-
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Table 4
KEMEDIAL ACTION ALTERNATIVES
No Action
Waste Excavation and Off-Site Land Disposal
Waste Excavation and On-Site Land Disposal
Waste Excavation and Off-Site Incineration
The PFS had proposed to remove the buried drums and the contaminated soils
from the Cemetery site, however, the extent to which contaminants may have
migrated in the soils has not been defined. Therefore, this operable unit
will only address the buried drums. After the removal of the buried drums,
additional soil samples will be collected to determine the remaining levels
of contaminants. This additional soil data, along with the completed ground
water study, will permit the MDNR and U.S. EPA to determine the appropriate
target levels for compounds that could be left on site. The objectives of
the PFS, source control and elimination of direct contact with drums, will •
still be 'achieved in this operable unit; however, the extent of total
clean-up will be deferred until the conclusion of the RI/FS when more data
will be available.
The cost estimates presented in the PFS included excavation of contami-
nated soils. These costs have not been deleted from the capital costs
presented in this document. The remedial action estimate will decrease
equally for Alternatives 2, 3, and 4 since only the buried drums would be
removed.
Estimation of total volume removed during excavation is based on the following
assumptions:
1. Drums are separate from each other and are placed at an
average depth of 8.5 feet.
2. Each drum and associated contaminated soil covers an
area 4 feet on a side.
3. Released materials migrate directly down with no horizontal
migration since drums are located in the unsaturated zone.
4. Excavation will occur over entire suspected drum disposal
area (approximately 250 feet x 25U feet).
5. A total of 250 drums are present.
6. Total excavation depth is 20 feet.
The above assumptions regarding the total waste and soil volume to be
removed will have to be modified djring the Remedial Design to obtain a
more accurate cost. For example, Item 2 would not include associated
contaminated soils but rather only the soil removed with the drums. Item 3
would not be appropriate in this operable unit. Item 4, excavation of main
disposal area, may have to be modified to reduce the amount of soil removed.
Finally, Item 6 will reflect the appropriate depth to remove the drums.
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-6-
Alternative 1 - No Action
Alternative 1 evaluated "No Action" as required under Section 300.53(g)
of the National Contingency Plan (NCP). This alternative would involve no
remediation of the buried drums and contaminated soils at this phase of the
project. The RI/FS would be completed before a final remedy for the site
is evaluated. The PFS had proposed some minimal field activity to warn and
protect people from the hazards present. This activity included a surface
clean-up program, warning signs, and installation of temporary fencing.
Since site access would be restricted by the fencing, the surface clean-up
activity was deleted from the cost estimate. Table 5 summarizes the cost
for this alternative.
Table 5
Cost for Alternative 1 - No Action Alternative
Capital Costs $ 6,000
30 yr. Operation and Maintenance (O&M) $26,000
Present Worth $32,000
Alternative 2 - Waste Excavation and Off-Site Land Disposal
Alternative 2 involves the excavation and removal of approximately 1,700
cubic yards of drums and associated contaminated material. An estimated
61,778 cubic yards of uncontaminated soil (Table 6) would have to be moved
to reach the buried drums.
Table 6
Total Excavation Calculations
a. Excavation depth 20 feet - sidewall stabilization required
1. Sidewall slope - 2 horizontal to 1 vertical
b. Total surface area of excavation
250 x [20 x 2] x 2 = 330' on a side
Total Amount of Material Excavated
(330' x 330') + (250' x 250') x 20 x 1/27 = 63,481 cy
<—£-*
Amount of Contaminated Material Excavated and Disposed
4' x 41 x 11.5 x 250 Drums x 1/27 = 1,703 cy
Estimated Amount of Overburden to be Moved to Reach Drums
63,481 cy - 1,703 cy = 61,778 cy
The site would be fenced before excavation is initiated to prevent direct
contact by potential receptors with excavated wastes. Shallow depressions
with a synthetic liner will be prepared for the temporary storage of drums,
and associated solid wastes and soil. Any liquid wastes from the drums and
pits will be temporarily stored in leak proof hoppers and tested prior to
off-site disposal.
There are only two landfill facilities in the general area of the Cemetery
Site which are RCRA (Resource Conservation and Recovery Act) approved for
accepting the expected waste materials. Both facilities are approximately
100 miles from the site and were used in determining the transportation
costs. Table 7 summarizes the costs for this alternative.
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Table 7
Cost for Alternative 2 - Waste Excavation and Off-Site Land Disposal
Capital Costs $ 1,883,261
30 yr. O&M N/A*
Present Worth N/A**
Alternative 2 would achieve the two objectives of the PFS by removing the
threat of release from the wastes into the Class I aquifer. This alter-
native would also remove the most concentrated contaminant levels, there-
fore lowering the threat of contact that may exist to residents digging
in the area for gardening and other activities. The RI/FS will develop
acceptable target levels for any remaining contaminated soils. The
reliability and level of protection for Alternative 2 would be acceptable
since the drum source would be removed permanently from the site.
Constructability and implementation are feasible for a depth of excavation
no greater than 20 feet. The threat of any additional adverse environmental
impact would no longer exist once drums are removed. Costs for this alter-
native are less than Alternative 3 and 4.
Alternative 3 - Waste Excavation and On-Site Land Disposal
Alternative 3 involves construction of an on-site disposal facility for the-
excavated contaminated material. The facility would meet all RCRA regula-
tions as well as all State laws for constructing a disposal facility.
In addition, the alternative must comply with site management and control
techniques, installation of contaminant monitoring facilities, and contami-
nant migration protection strategies. The facility would require a double
liner and double leachate collection system. A berm would be built around
the facility and ground water monitoring program would be instituted in
compliance with regulations. Table 8 summarizes the cost for this alternative,
Table 8
Cost for Alternative 3 - Waste Excavation and On-Site Land Disposal
Capital Costs $ 1,961,966
30 yr. O&M 415,000
Present Worth 2,376,966
Alternative 3 would be feasible in terms of the constructability and imple-
mentation since construction of RCRA landfills is a proven technology.
However, the source would be kept on site which offers only a medium level
of protection to the unconfined aquifer should the on-site landfill integrity
fail. Costs for Alternative 3 would exceed the capital costs in Alternative
2 due to construction and 04M costs for 30 years.
Alternative 4 - Waste Excavation and Off-Site Incineration
Under Alternative 4 the excavation and handling of waste before disposal
would be the same as described in Alternative 2. The major difference
between this Alternative and Alternative 2 would begin at the packaging
requirements for waste materials. Non-pumpable solid materials are accepted
at the incineration facility only in burnable plastic or fiber drums not
exceeding 30 gallons or 300 pounds. Liquid materials are only accepted in
bulk. Special hoppers and drum loading facilities will have to be provided
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at the Cemetery site to assure proper waste preparation. Furthermore, the
excavated drums and drum fragments will have to be handled independently
either by disposing in a landfill facility or by incineration separately
from the soils. Table 9 summarizes the cost for this alternative.
Table 9
Cost for Alternative 4 - Waste Excavation and Off-Site Incineration
Capital Costs $ 3,142,866
30 yr. O&M N/A*
Present Worth N/A**
Alternative 4 would meet all the criteria relating to the concerns at the
Cemetery Site. The Off-site Incineration would also guarantee the total
destruction of the waste.
* Because all of the alternatives involve remedial actions as part of an
operable unit and not the final remedy, no operation and maintenance
costs are involved. Operation and Maintenance requirements will be
included in the final remedy for the site.
** Present worth values are not applicable for these off-site disposal
alternatives because remedial activities are limited to a one time,
short-term action.
Summary:
Alternative 1 does not meet the source control objective uf the operable
unit remedial action. The modified "no action" proposed would restrict
site access and therefore minimize the threat of contact with contaminants
through digging below the surface. This alternative would not prevent the
release of contaminants into the unsaturated zone or potential migration into
the unconfined Class I aquifer and private water supplies.
Alternative 3 would meet the objectives of the operable unit by isolating
the contaminants from the environment and placing the wastes in an on-site
RCRA approved disposal facility. However, the geology of the site and the
lack of any guaranteed protection to the unconfined aquifer used by adjacent
residents make on-site landfill construction inappropriate.
Alternatives 2 and 4 are technically feasible, do not require complex plan-
ning to design, protect the public health, are consistent with the final
remedy, exceed environmental standards, and have low community impact.
Alternative 4, off-site incineration, would ensure total destruction of the
contaminants. However, Alternative 4 requires more pre-transportation
preparation before leaving the site. The requirements that solid wastes be
packed into burnable plastic or fiber drums and liquids contained in special
hoppers would increase the health and safety concerns associated with
handling. Additionally, drums and drum fragments would have to be separated
from the contaminants and disposed separately, thereby increasing the time
and costs of material handling. No additional public health or environmental
benefits would be achieved by selection of Alternative^. For these reasons,
this alternative has been eliminated.
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Alternative 2, off-site landfill disposal, is the 'most cost effective remedy
proposed because it protects the public health and the environ.nent, is
consistent with the final remedy, less expensive than off-site incineration,
and will minimize health and safety concerns during waste preparation.
Community Relations
Copies of the PFS were made available to the community on July 22, 1985.
Two locations served as respositories in the area: Rose Township Hall and
the Rose Township Library in Holly. The MDNR issued a press release on
July 26, 1985, which announced the availability of the study, opportunity
to comment until August 12, 1985, and the schedule for the public meeting.
The public meeting was held on August 1, 1985 at the Rose Township Hall.
Approximately 25 residents attended the meeting. Representatives of the
USEPA, MDNR, and local government were present. The MDNR presentation
explained the purpose of the PFS, described the current situation regarding
site contamination, and discussed the recommended alternative. One public
comment was received in writing by the potential responsible parties.
These comments are addressed in the attached Responsiveness Summary.
Consistency with Other Environmental Laws
*
Off-site transportation and disposal of drums and wastes will be in accordance
with the appropriate RCRA and TSCA regulations for the transportation and
disposal of hazardous waste and PCBs. This will include manifesting of
wastes and shipment to a RCRA and, if necessary, TSCA, approved facility.
Ground water contamination will be managed in future remedial actions.
Appropriate RCRA technical regulations will be used when remedial alternatives
are evaluated in the remaining RI/FS work to be conducted by the State of
Michigan and EPA.
Recommended Alternative
The National Oil and Hazardous Substances Contingency Plan (NCP) [40 CFR
Part 300.63(j)] states that the appropriate extent of remedy shall be
determined by the lead agency's selection of the remedial measure which the
agency determines is cost-effective (i.e., the lowest cost alternative that
is technologically feasible and reliable) and which effectively mitigates
and minimizes damage to and provides adequate protection of public health,
welfare or the environment. Based on the evaluation of the cost and
effectiveness of each proposed alternative, the comments received from the
public and the MDNR, and State and Federal environmental requirements,
Alternative 2 has been determined to be most cost-effective.
The recommended alternative is considered a source control, operable unit
remedial action (removal of buried drums), as defined in section 300.63(d)
of the NCP. The objective of the action is to eliminate the threat of
release from the contaminant source to the Class I aquifer and to
remove the threat of contact to the surrounding community and the wildlife
in the area. The RI/FS will examine appropriate final response actions for
the site.
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The capital cost of this alternative is estimated t-o be $1,883,261. Since
this action involves excavation and off-site disposal, and because this is
an operable unit of the final remedy for the site, there are no operation
and maintenance (O&M) costs for this alternative. In addition, present
worth values are not applicable because the recommended alternative involves
a one time, short term action with no 0 & M costs and an estimated construc-
tion time of two months.
Schedule
The MONR will manage the design and construction of the remedial action.
Implementation of the remedial action will not be initiated until the
design is reviewed and approved by EPA.
Approve Remedial Action (Sign ROD) 09/10/85
Award MDNR Cooperative Agreement for
Design/Action 09/10/85
Start Design 09/11/85
Complete Design 12/85
Start Construction 2/86.
Complete Construction 4/86
Future Actions
The State lead RI/FS is scheduled for completion in summer 1986. The study
will assess the ground water conditions and soils related to the Cemetery
Site and propose the appropriate remedial actions.
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