United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-90/137
September 1990
Superfund
Record of Decision:
Anderson Development, Ml
-------
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R05-90/137
3. Recipient's Acceuion No.
4. TOe and Subtitle
SUPERFUND RECORD OF DECISION
Anderson Development, MI
First Remedial Action - Final
5. Report Date
09/28/90
7. Aulhor(«)
8. Performing Organization Rept No.
9. Porfoimlno Orealnlation Name and Addreea
10. Proiacl/Taak/Work Unit No.
11. Contraet(C) or Grant(G) No.
(C)
(C)
12. Sponeoring Organization Name and Addree*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report* Period Covered
800/000
14.
IS. Supplemenury Nolea
16. Abstract (Umlt: 200 worda)
The 12.5-acre Anderson Development site is an active chemical manufacturing facility in
Adrian, Madison Township, Lenawee County, Michigan. The site is in a 40-acre industrial
park, and is comprised of several areas of contamination that exceed health-based
levels, including a 0.5-acre former process wastewater pretreatment lagoon containing
lagoon sludge, clay underlying the lagoon, and a small quantity of soil near the lagoon.
From 1970 to 1979, the plant produced 4,4-methylene bis(2-chloroaniline) (MBOCA), a
hardening agent for the production of polyurethane plastics. Process wastewater was
discharged directly to surface water until 1973, when it was discharged to a publicly
owned treatment works (POTW). In 1979, the State ordered the POTW not to accept the
waste stream because of the decreased efficiency of the POTW resulting from MBOCA. In
1980 and 1981, the site owner and the State performed a cleanup action of all
contaminated site areas with levels of MBOCA above 1 ppm. This included decontaminating
the plant, sweeping streets, shampooing/vacuuming residential carpet, and removing some
surface soil. This Record of Decision (ROD) addresses the remediation of the
pretreatment lagoon area. The primary contaminants of concern affecting soil and lagoon
sludge are organics, namely MBOCA and its degradation products.
(See Attached Page)
MI
17. Document Analyaia a. Descriptors
Record of Decision - Anderson Development,
First Remedial Action - Final
Contaminated Media: soil, lagoon sludge
Key Contaminants: organics (MBOCA and its degradation products)
b. Mentffiera/Open-Ended Terms
c. COSATI Reid/Group
18. Availabifity Statement
19. Security Class (This Report)
None
20. Security Class (This Psge)
None
21. No. olPagea
148
22. Price
(See ANSI-Z39.18)
See Instruction* on Ravene
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department ol Commerce
-------
EPA/ROD/R05-90/137
Anderson Development, MI
First Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site includes removing and treating standing water
in the lagoon; excavating contaminated soil, clay, and lagoon sludge from a 100-foot by
75-foot area and placing the material in an unexcavated portion of the lagoon; treating
the contaminated material by in-situ vitrification; collecting pyrolized gases, and
treating the gases using a scrubber system, air filters, and carbon adsorption beds;
filling the lagoon containing the vitrified material with clean fill; and conducting
ground water monitoring and soil sampling. The estimated present worth cost for this
remedial action is $2,364,050, which includes a total O&M cost of $38,530 over 30 years.
PERFORMANCE STANDARDS OR GOALS: A cleanup action level of MBOCA 1,684 ug/kg was
calculated based upon EPA guidance documentation. The cleanup level corresponds with
the excess lifetime cancer risk level of 10"^.
-------
OF EEi:i>iifM
ROD SOMABY.
ANCGRSCN EEVEIDEMENT GCHEANY STIE
ACKON, MICHIGAN
-------
KBULKIJ OF EECZLSXCH
ACTION
FOR THE
ANDERSON DEVELOPMENT (XMPANY SHE
AHOMf, MICHIGAN
SITE NAME AND IPCATION
Anderson Development Company Site
Adrian, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the
Anderson Development Company Site in Adrian, Michigan, chosen in accordance
with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERdA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent practicable, the
National Contingency Plan (NCP). The decision is based on the
Administrative Record for the Anderson Development Company Site. The
attached index identifies the items which comprise the Administrative Record
upon which the selection of the remedial action is based.
The State of Michigan has been consulted and concurs with the selected
remedial action.
op THE SITE
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the remedial action selected in this Record of
Decision, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
OF
The selected remedial action for the Anderson Development Company Site
addresses the principal threat through remediation of contaminated
pretreatment lagoon sludge, surface soils around the lagoon found to have
levels of contamination above health based levels, and some of the naturally
occurring clay which underlies the lagoon found to have concentrations of
contaminants above the clean-up action level. The major components of the
selected remedial action include:
* Removal and proper treatment of the standing water remaining
in the lagoon;
-------
* Excavation of contaminated soils with contaminant concentrations
above the clean-up action level, and consolidation of these soils
into the lagoon;
* Excavation, from a 100 ft by 75 ft area, of lagoon sludge and
underlying clay, to a depth sufficient to meet the clean-up action
level, and staging onto the remaining portion of the lagoon;
* In situ vitrification (ISV) of the resultant staged wa«ag of soil,
sludge and clay to a depth sufficient to meet the clean-up action
level;
* Air monitoring and conf innational soils sampling during the remedial
action; and
* Groundwater monitoring, additional confirmational soils
sampling and verification borings following the remedial action for
a period of 5 years to assess and confirm the efficacy of ISV.
STAH/TORY DEIERMTTJATTOM5
The selected remedy is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost-effective.
Ihe remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the statutory
preference for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element. Because the contaminants will
either be destroyed in the process and removed in the of f -gas treatment
system or molecularly broken down and chemically bound within the resultant
glass-like product, a five year review is not necessary.
Valdas V. Adamkus/ /T Date
Regional
-------
SUMMARY OF REMEDIAL AI2ERNATTVE SELECTION
ANEEKSON EEVELORfENT OCMEANY SHE
AEKLAN, MICHIGAN
TABLE OF OCNQNLS
I. SHE NAME, IDCKLTON AND DESCRIPTION 2
U- £>rii£ HISIUUY AND ENFORCEMENT AunvrrxES 5
UI. OOHDNnY PftRndFKnON 7
IV. SGOFE AND RDIE OF REMEDIAL ACTIVITIES 7
V. SDMAEY OF SHE CHARAdERISTICS 9
VI. SUMAK? OF SITE RISKS 12
VH. DOGLHENTATICN OF SIOOFICANr CHANGES 16
VTTT. LfeSdUiTIONS OF AISEBNAl'IVKS 16
IX. SOMAFY OF THE OCHPARATTVE ANALYSIS OF KLSS3XKTTVES.. 22
X. THE «Ki.Hr«iM> REMEDY 35
XI. STATUTORY EEIERMINATIONS SUMMARY 36
XU. RESPONSIVENESS SUMMARY (Attached)
-------
I. SITE NftME. LOCATICN AND DESCRIPTIOK
The Andersen Development Company (ADC) Site is located in an industrialized
area in the southeast side of the city of Adrian, in Madison Township,
Lenawee County, Michigan. (See Figure 1). The ADC facility is located at
1415 E. Michigan Street. The ADC facility occupies roughly 12.5 acres of a
40 acre industrial park, and includes several buildings which are used for
manufacturing and storage, offices and laboratory space. Within this 12.5
acre area is a farmer process wastewater pretreatanent lagoon which contains
anywhere from two feet to five feet of standing water, depending on the tims
of year and amounts of precipitation. The approximate area of this lagoon
is one-half acre.
I . *L . -
Andenon Developnent Coop any
Approziaite Scile:
1- • 2000'
(FROM USCS T.S MINUTE
ADRIAN QUADRANGLE)
POOR QUAll i
ORIGINAL
Figure 1
-------
The "area of contamination" for which a response action is necessary is
limited to the former pretreatment lagoon area, and the remedial action
selected in this Record of Decision represents a complete Site clean-up.
During negotiations for conduct of the Rennpriial Investigation and
Feasibility Study, the "Site" was limited to the extent of the ADC property,
and was not intended to include areas of contamination away from the
facility (e.g., the Adrian Wastewater Treatment Plant). Contaminated ****•«»
(above the health-based clean-up action level) include lagoon sludge, some
of the naturally occurring clay which underlies the lagoon, and a
volume of surface soils located adjacent and to the north of the lagoon.
For a map of the area and map of the lagoon area, refer to Figures 2 and 3,
respectively.
Figure 2
-------
/
WOVE GROUND STEEL
WASTEWATER STORAGE TANK
SURFACE SOL / SEDIMENT SAMPLMC LOCATION
SURFACE SOL / SEDIMENT AREA REQUIRING REMEDIAL ACTION
LAGOON SLUDGE / CLAY AREA REQUIRING REMEDIAL ACTION
"ARE* Of CONCERN" TO BE REMEDIATED
Figure 3
Situated in an industrialized setting, the ADC facility is within 1000 feet
of Aldrich Oil, AGET Manufacturing, Marco Plastics, Adrian Packaging, Inter-
American Zinc and Hydro-Tech Chemicals. The former pretreatment lagoon is
located approximately 400 feet south of the ADC main office building and is
within 200 feet of the property boundary of Hydro-Tech Chemicals.
Approximately'330 hones are located within a one kilometer (5/8 mile) radius
of the ADC plant, including two residential subdivisions: Drexel Park and
Sunnyside. Boundaries for the Site include Church Street to the north, Gulf
-------
Street to the west, Wabash Street to the east, and railroad tracks to the
south and east. The closest residences to the Site are approximately 1/4
mile away.
Adrian is loeated-in glacially-derived- topography, a moraine comprised of
unconsolidated and heterogeneous clay, silt, sand and gravel. The
underlying bedrock formation is the Coldwater Shale, located approximately
100 to 250 feet below the land surface. Most surface soil around the ADC
Site is hard clay till, brown to grey in color, with variable amounts of
sand and gravel. Surface runoff from the Site is conveyed by City storm
sewers to the East Side Drain, which is an ephemeral tributary to the South
Branch of the River Raisin. Adrian (population 21,276) water supplies are
drawn from Lake Adrian, a reservoir located on Wolf Creek which merges with
the River Raisin at approximately two miles upstream of the mouth of the
East Side Drain. No wetlands or floodplains have been identified near the
Site. The ADC facility is within 6000 feet of the River Raisin at its
closest point. Ihe lagoon is fenced, and access is provided via a gate and
unpaved road to the west of the lagoon.
TT. Sl'i*? HitfUMy AND EMRJK Mflran* ACl'lVl'lY
Anderson Development Company (ADC) is a corporation principally involved in
the manufacture and sale of specialty organic chemicals. It is located on
the southeast side of the City of Adrian in Lenawee County, Michigan. Ihe
Site covers approximately 12.5 acres, including a pretreatment lagoon,
within a 40 acre industrial park. ADC is surrounded by light industrial and
residential areas.
ADC is a specialty organic chemical manufacturing facility. ADC began
production of MBOCA, i.e., 4,4'-Methylene bis(2-chloroaniline), in 1970
under the trade name Curene 442. MBOCA is used as a hardening agent in the
manufacture of polyurethane plastics. Throughout the 1970's, ADC produced
as much as 1.3 million pounds of MBOCA annually. During this period, ADC
accounted for 25% to 40% of the MBOCA production in the United States.
MBOCA has a number of synonyms, depending on its producer: Curalon M
(Uniroyal) ; Cyanaset (American Cyanamid) ; MOCA (DuPont) , etc. MBOCA is
biodegradable and belongs to a class of compounds known as aromatic
Its molecular formula is CfCHClN* MBOCA is a known animal
carcinogen and the National Institute for Occupational Safety and Health
(NIOSH) recommends that it be regulated as a human carcinogen. Two known
biological degradation products (metabolites) are N-acetyl -MBOCA, (AC) and
N,N'-diacetyl -MBOCA, (DAC) . Based on studies of similar degradation
products of benzidine and other aromatic amines, these degradation products
are considered even more toxic than MBOCA. MBOCA is generally considered to
be a crystalline solid which does not readily dissolve in water. It has a
high affinity for organic and inorganic particulate matter. MBOCA has a
very low vapor pressure of 10~5 mm Hg § 24 degrees Celcius. Pure MBOCA has
a melting point of approximately 110 degrees Celcius (about 230 degrees
Fahrenheit).
-------
The process waste discharges of the MBOCA production process caused MBOCA
contamination of the nearby East Side Drain, the Adrian Wastewater Treatment
Plant (WWTP) and River Raison . Originally, ADC discharged its process
wastewater and cooling water, untreated, into the East Side Drain. Ihis
occurred through 1973 when the MCNR discovered the discharge of aniline into
the East Side Drain. In late 1973, ADC separated the process wastewater
from its cooling water, thus allowing for pretreatment of the wastewater to
the satisfaction of the MCNR prior to discharge to the municipal water
treatment system. MBOCA discharges to the WWTP continued, resulting in
rlPCTPasPd efficiency of the WWTP. At the WWTP, MBOCA settled out with other
solids and formed a sludge material which was applied to the land leading to
MBOCA contamination at the WWTP drying beds. Eventually, MCNR advised the
City of Adrian not to accept ADC discharges contaminated with MBOCA. MBOCA
was found in surface sediments on and around the ADC plant in 1979, and
MBOCA production was stopped. MBOCA discharges to the environment occurred
via surface water and airborne routes. The airborne mechanism of
contamination may have resulted from sublimation of MBOCA during the
manufacturing process or generation of MBOCA particles as fugitive emissions
which were subsequently discharged to the environment through the plant's
ventilation system. No MBOCA was detected in the subsurface soil at a depth
of greater than 1.5 feet and no groundwater contamination was detected.
Treated process wastewater and storm water run-off discharges from the ADC
plant resulted in the contamination of the East Side Drain bottom sediments.
The Michigan Department of Natural Resources (MCNR), Michigan State Toxic
Substance Control Commission (TSCC), ADC and local governmental agencies,
through comprehensive cleaning and monitoring efforts, cleaned the
contaminated areas (those above an MBOCA level of 1 ppm) in 1980 and 1981.
Clean-up actions included in-plant decontamination, residential carpet
shampooing/vacuuming, street sweeping, removal of some surface soils from
roads and parking lots, and paving/tilling/covering of unpaved areas near
the plant. Contaminated soils were placed in the Wayne County Municipal
landfill. This response action was funded by the State, who later recovered
their costs from ADC.
The Site was placed on the National Priorities List (NFL) in 1983. In June
1984, a Remedial Action Master Plan (RAMP) was developed by U.S. EPA using
available data. It was recommended in the RAMP that further investigations
were necessary and some kind of remedial action needed to be implemented.
On April 30, 1986, Anderson Development Company entered into an
Administrative Order by Consent ("ADC" or "the Order") with U.S. EPA for
the conduct of a Remedial Investigation and Feasibility Study (RI/FS). C.C.
Johnson and Malnotra, P.C. has been contracted by ADC to conduct all work
related to the RI/FS.
On May 23, 1986, the U.S. EPA Region V Regional Administrator signed a
CERCLA 106 Administrative Order by Consent stipulating the undertaking of a
Remedial Investigation and Feasibility Study (RI/FS) for the purposes of
determining the nature and extent of the threat to the public health or
welfare or the environment due to the release or threatened release of
hazardous substances or contaminants from the Site and to evaluate
-------
appropriate remedial action alternatives to prevent or mitigate the
migration or release of hazardous substances or contaminants from the Site.
The signed Order underwent a 30 day public comment period shortly
thereafter. No comments were received during public comment and the Order
became effective on-July 2 / 1986 r
On July 2, 1990, the U.S. EPA published, and placed in the repository for
public viewing, a Proposed Plan for remedial action. A formal public
hearing was held on July 12, 1990 to answer questions in regard to the
Proposed Plan and to accept verbal public comment on the Proposed Plan.
U.S. EPA accepted written comment on the Proposed Plan through August 8,
1990.
TTT. QCMCNUY PARTICIPATION
Since the Anderson Development Company Site is actually part of an operating
chemical plant (although physically separated from the ADC facility by some
400 feet to the south), and the lagoon itself is rather small (approximately
one-half acre), and situated within an industrialized area, it is generally
not perceived as a health threat by the public. Consequently, Superfund
activities at the Site, prior to the publication of the Proposed Plan, have
received minimal attention from the community and limited interest by local
organizations and the media.
Community relation activities began with a public meeting held in Adrian on
June 24, 1987 to A\sn\ss. the work to be conducted under the RI/FS.
Following completion of the RI/FS, the U.S. EPA published a Proposed Plan
for remedial action on July 2, 1990. The RI and FS Reports, Proposed Plan
for remedial action and the Administrative Record, have been placed in
Information Repositories located at the Adrian City Library and Adrian City
Hall building.
To encourage public participation in the remedy selection process consistent
with Section 117 of CERCLA, the U.S. EPA set a 30 day public comment period
from July 2, 1990 through August 1, 1990 for the Proposed Plan. The public
comment period was extended 7 days to August 8, 1990 because some documents
were delayed in being sent to the information respositories. A Proposed
Plan public meeting was held at Adrian Community College on July 12, 1990.
The remedy for the Anderson Development Company Site described herein was
selected after a detailed review of the public comments received. The
attached Responsiveness Summary addresses those public comments received.
IV. SCOPE AND RDIE OF OPERATOR rfffTT QR RESPONSE ACTION
Ihe FS identified five remedial objectives for the ADC Site based on the
data obtained by the Remedial Investigation and the possible exposure
routes identified in the Endangerment Assessment. The objectives of the FS
are:
-------
8
1) To prevent dermal contact and ingestion/inhalation of MBOCA
contaminated soils and fugitive dusts;
2) To reduce excess lifetime cancer risk levels to 1 X 10E-04 to
1 X 10E-06, with a "point of departure" of 1 X 10E-06;
3) To prevent potential MBOCA contaminated soil erosion and runoff
to surface waters;
4) To prevent possible migration of MBOCA from contaminated surface
soils through fugitve dust, erosion or runoff to surface water,
and;
5) To prevent possible migration of MBOCA and other organic
contaminants from contaminated media into the groundwater by way
of leaching.
Seven actions were identified in the FS to satisfy these objectives. Also
included in the FS were the No Action Alternative and an alternative
involving implementation of institutional controls only. Two additional
alternatives were costed out for purposes of comparing 10~4 clean-up costs
to 10""^ clean-up costs, although these two alternatives were not evaluated
in detail. These potential actions were combined to formulate an array of
remedial alternatives. These alternatives were screened and compared to
each other and the remedial objectives to determine their ability to achieve
the objectives.
The U.S. EPA further evaluated the FS array of remedial alternatives and
selected five remedial alternatives that would satisfy the objectives of the
ES, meet health based clean-up levels and meet the statutory requirements of
CERdA. The U.S. EPA also evaluated the "On-Site Landfill" alternative
which was presented by the PRP as its preferred alternative in the FS.
Tables 1-1 through 1-6 attached hereto lists the remedial alternatives that
were evaluated in this decision document, their component parts and costs.
The remedial action selected for the ADC Site will use treatment to
eliminate principal threats associated with direct contact of contaminated
media. The role of the remedial action selected is a complete Site remedy,
as groundwater is not contaminated with either MBOCA, degradation products
of MBOCA, or other contaminants above levels of concern. When the remedial
action is completed, no further remedial action at the Site is envisioned.
The monitoring of groundwater will be conducted to ensure that the inorganic
and remaining organic contaminants in the vitrified mass are not migrating
and remain encapsulated. Hazardous substances above health-based levels and
outside of the area of vitrification will not remain at the Site after
completion of the remedial action, but to further assess the effectiveness
of ISV, and to ensure that lateral migration of contaminants has not
occurred, confirroational soils sampling and groundwater monitoring will be
conducted. There will not be a need for a five year review due to the
complete destruction of MBOCA via extremely high temperatures encountered
during the remedial action.
-------
V. SCMCVRY OF
A. Site Qiaracteristics
The Anderson Development Company is an actively operating, specialty
organic chemical manufacturing facility located in an industrial setting.
The area of concern, however, is limited to the former pretreatment lagoon
and its surrounding soils, as determined by extensive sampling during a
phased field study. Within this lagoon, process wastewaters which were
pumped from the manufacturing facility were aerated and treated with
potassium permanganate in order to oxidize the MBOCA in the wastewaters and
to eliminate gore of the obnoxious odors emanating from the standing water
in the lagoon.
The Remedial Investigation was completed in four phases. The first three
phases only aiV^pegaH environmental contamination of MBOCA, AC and DAC.
Phase I field sampling began in October 1987 and was completed in November
1987. The results of this sampling phase were presented in two technical
memoranda submitted in April 1988. Additional sampling for Phase II of the
RI was conducted in September 1988, with results presented in a November
1988 technical memorandum. Further waste characterization of the
pretreatment lagoon was conducted in November 1988. Phase IH results were
presented in the Revised RI Report submitted by ADC in January 1989. The
final phase (Phase IV) was conducted in April 1989 for the purpose of
characterizing lagoon sludge, lagoon clay and lagoon area groundwater for
most U.S EPA Target Compound List (TCL) compounds, as well as assessing the
vertical extent of MBOCA, AC and DAC contamination in the clay beneath the
lagoon. Phase IV sampling results were presented in the Revised RI Report
submitted in July 1989 and resubmitted with further revisions in September
1989 (Final RI Report) .
Samples of soil, sediment, surface water and groundwater were collected as
part of the RI. Surface soil, near-surface soil and sediment are the
primary environmental media which have indicated detectable MBOCA, AC or DAC
contamination. RI data indicate current on-site MBOCA levels up to
2,800,000 ug/kg (pretreatment lagoon sludge) and off -site MBOCA levels up to
350 ug/kg (surface soils within 2000 feet of ADC Site) . Various volatile
and semi-volatile organic compounds including toluene and 4-methylphenol
were found in the lagoon sludge. Both the number and concentrations of
detectable organics were lower in the lagoon clay.
Results of the RI indicated that groundwater and surface water on-site as
well as off-site are not contaminated with MBOCA, AC, or DAC. Low levels of
several volatile and semi -volatile organic compounds were detected in the
confining layer. The RI concluded that the groundwater and surface water
are not contaminated at levels of concern and do not need remediation.
While various organic compounds were detected in this limited water bearing
layer of clay, some of these, such as acetone and methylene chloride, have
been attributable, at least in part, to laboratory contamination.
-------
10
Furthermore, levels of both detectable volatile and semi-volatile organics
were found to be much lower in the confined aquifer than in the confining
layer groundwater. In the confined aquifer, one semi-volatile compound,
caprolactum, was found in elevated concentrations. This chemical is non-
carcinogenic and relatively innoccuous. Furthermore, while caprolactum was
detected in the confining layer and confined aquifer, it was not detected in
either the lagoon sludge or underlying clay layer, thus indicating an off-
site source. When the sandy aquifer was reached during drilling, artesian
conditions were found as water levels rose to the piezometric surface of the
aquifer.. These conditions would tend to mitigate downward contaminant
migration into the underlying aquifer.
An assessment of the health risks associated with MBOCA contamination on-
site and off-site was carried out and presented in the Endangerment
Assessment (EA). Various exposure scenarios, through which different
populations could potentially be exposed to MBOCA, were evaluated. Risks
ggsociat^d with oral ingestion and dermal exposure to MBOCA contaminated
soil/sediment were considered for each of the scenarios.
MBOCA action/clean-up levels for 1 X 10E-04 to 1 X 10E-07 risk levels were
dpfprmined for different exposure scenarios and compared with the maximum
observed MBOCA levels. Consistent with the NCP, a 1 X 10E-06 "point of
departure" was considered for clean-up purposes. This comparison indicated
that except for the ADC lagoon area, no surface or subsurfaces soil/sediment
remediation is warranted.
An "action level" or clean-up level of 1684 ug/kg (rounded down to 1.6 ppm)
of MBOCA for soils (10E-06 risk level) was calculated based on the
residential exposure scenario considered in the Endangerment Assessment.
The exposure routes and calculated target levels were determined in
accordance with U.S. EPA guidance documents, Superfund Public Health
Evaluation Manual (SPHEM) and Superfund Exposure Assessment Manual (SEAM).
A 10E-06 carcinogenic risk level of approximately 1.3 ppm was calculated
based on the standardized exposure assumptions as defined in Rule 299.5711
of Act 307. Within this rule is an algorithm which establishes an
acceptable risk for exposure via direct contact with contaminated soils.
Although the Act 307 clean-up goal is slightly more stringent than that
which was fM>t-ormi"orf according to U.S. EPA guidance, because the State does
not see any practical or significant difference between these two values,
the higher value was acceptable to MDNR. This action level of 1.6 ppm
necessitates remedial action for some surface soils, lagoon sludge and clay
beneath the sludge in the ADC pretreatment lagoon area. The total volume of
clay to be treated can only be approximated at this time because of the fact
that during Phase IV, samples of the clay could only be taken from as deep
as five (5) feet. Further sampling and analyses will be conducted during
design for the purposes of delineating the extent of vertical contamination,
thus allowing for more accurate costs analyses.
Feasibility Study (FS) activities began in December 1988. A draft FS was
submitted by ADC on October 3, 1989. The draft FS included remedial action
objectives to arMrpfis contamination of the lagoon sludge, clay beneath the
lagoon and some surface soils around the lagoon. The Final FS was
-------
11
submitted to U.S. EPA and MDNR on March 2, 1990. The FS and Proposed Plan
were ™aA» available for public comment on July 2, 1990.
From the data gathered during the RI, the following conclusions were drawn
in the FS:
* MBOCA concentrations in the environment surrounding the ADC plant
have decreased significantly since 1980. This reduction is
attributable to the cessation of MBOCA production, the initial
remedial action undertaken at the plant and surrounding area, and to
a lesser extent, to the biodegradation of MBOCA in the environment.
* No MBOCA, AC or DAC was detected . in off-site groundwater, and only
one surface water sample contained MBOCA at a detectable
entration (1 ug/1) .
* Concentrations of MBOCA, AC and DAC in the surface and subsurface
soils and sediment around the ADC plant area varied from non-
detectable levels to a maximum of 350 ug/kg. MBOCA concentrations in
soils around the former lagoon area were found to be as high as
98,000 ug/kg.
* Sludge in the former pretreatment lagoon contained MBOCA levels as
high as 2,800,000 ug/kg, manganese levels as high as 101,000,000
ug/kg (10% by weight), toluene as high as 140,000 ug/kg and numerous
other organic constituents in concentrations as high as 200,000
ug/kg. See Attachment A.
* Subsurface clay beneath the lagoon contained MBOCA at concentrations
up to 660,000 ug/kg, AC concentrations up to 3900 ug/kg, and DAC
concentrations up to 35,000 ug/kg. Various inorganics and volatile
and semi-volatile organics were also detected in the clay layer, but
at levels lower than those found in the lagoon sludge. See
Attachment A.
* The confining layer does not contain detectable levels of MBOCA, but
AC was found once at 21 ug/1. One Target Compound List (TCL) organic
(M-Chloroaniline) was detected at 1000 ug/1, as well as several
tentatively identified compounds (TIC's). See Attachment A.
However, this confining layer does not represent an adequate,
continuous aquifer and is considered unusable by both U.S. EPA and
MDNR.
When comparing current MBOCA levels within the pretreatment lagoon area, at
the Adrian WWTP, around the ADC facility, in the East Side Drain, and in
locations within the City of Adrian to those levels found during 1980 and
presented in the RAMP, it is obvious that degradation through biological or
photochemical means has occurred over the past 10 years. (N.B.- While this
evidence may support Anderson's claims that MBOCA does degrade in the
environment, and that current levels will continue to degrade, questions
remain with respect to the ultimate by-products of MBOCA in situ and the
fate and transport of these by-products.) Tables 2-1 and 2-2 compare
-------
12
current MBOCA levels to MBOCA levels found 10 years ago. For off-site
locations, attempts were maH«a to duplicate earlier sampling locations.
Tfeble 2-3 presents a summary of MBOCA, AC and DAC concentrations during the
RI.
B. Area Hvdroqeology
Based on the information gathered from borings and wells completed during
the Ttemftdial Investigation (RI) field activities, the hydrogeology
immediately surrounding the ADC plant was described in the RI. In the
pretreatment lagoon area, there is an upper brown till unit, 30 to 40 feet
thick, with snail but variable amounts of silt, sand and gravel. This unit
does not contain perched aquifers, but contains small "pockets" of
groundwater where the permeability is believed to be greater than that of
the remainder of this "confining layer." Below this confining layer is a
saturated and confined aquifer composed primarily of poorly sorted grey and
black sand, silt and gravel. The thickness of this unit was not
Based on water level measurements, well logs, construction details and
survey data collected during the RI, it is estimated that in the sandy,
confined aquifer, groundwater flows approximately to the northwest.
However, in the clay-rich confining layer, the flow pattern could not be
predicted because of the heterogeneity of the unit. Die clay-rich confining
layer is not used for any water supply purposes. The residential wells
closest to the ADC Site are those located in the Sunnyside Subdivision, and
are believed to be upgradient with respect to the Site. These wells tap
into the confined and deeper aquifer. Also, the residences in the Sunnyside
Subdivision are provided with a central water supply. The only known
operating domestic water supply well in the Sunnyside Subdivision is at the
Sunnyside Cafe, located on East Maumee Street, and hydraulically upgradient
to the Site.
YE. SCMMRRY OF SHE RISIS
The RI data indicate that the groundwater and surface water are not
contaminated. Air, indoors of industrial and commercial establishments,
and the ADC Plant were not found contaminated after the initial response
activities at the ADC Plant and its vicinity. Wipe samples taken at
numerous locations within the plant following the 1980-81 response action
were found to be well within QSHA standards for MBOCA. The indoors of these
facilities are considered relatively free of MBOCA contamination and were,
therefore, not sampled during the RI. Surface and subsurface soil on-site
and off-site, and surficial drainage sediments in the ADC Pretreatment
lagoon area contain MBOCA to which human and environmental populations can
be exposed. Based on the 10E-06 risk level for MBOCA, off-site soils and
sediments and groundwater are not contaminated above levels of concern.
While ambient air monitoring was not conducted as part of the RI, because of
the fact that MBOCA production ceased 11 years ago, and because surface
soils are not contaminated at greater than health-based levels, except for a
small area adjacent to the lagoon, airborne exposure is not considered a
concern.
-------
TABLE 2-1
Adrian Surface Soil «2000 ft from sitel
Location
#5 215 McVicar St.
#6 1123 E. Frank St.
#7 218 S. Gulf St.
#8 Wabash Park
419 Bohn Aluminum Co.
#10 1545 Dorothy St.
#11 Westend Ruby St.
112 Ball Diamond
#16 1027 Love St.
High MBOCA level
in ua/kg fdatel
320
629
6500
20,300
5300
4300
6500
201
180
(9/80)
(10/79)
(5/80
(6/81)
(9/80)
(6/81)
(5/80)
(10/79)
(10/79)
RI MBOCA level
in uo/ko
<60
<60
290
300
<60
<60
100
<80
350
Adrian Surface Soil f>2000 ft from site)
Location
#1 Island Park
#2 1667 Howe11 Road
#3 County Fairgrounds
#4 McKinley School
#13 2737 Cloverdale
#14 2347 Parr Road
#15 Treat & Lansing Rds.
#17 St. Mary's Cemetary
#18 Monument Park
High MBOCA level
in ua/kq (date)
5 (5/80)
310 (5/80)
386 (10/79)
20 (50/80)
156 (10/79)
386 (10/79)
32 (10/79)
3 (10/79)
10 (5/80)
RI MBOCA level
in uq/kq fl987)
140
<60
220
<70
90
<60
<60
<80
<60
-------
TABLE 2-2
East Side Drain Surface Water
1980 MBOCA Range
fuq/L)
1.0 to 6.8
1987 MBOCA Range
rua/Ll
<1 to 1
East Side Drain Sediment
Location
1980 MBOCA
level in uq/kq
Phase I RI MBOCA
level in ua/kcr (10/87)*
Phase II RI MBOCA
level in uq/ko9/88*
nc =
**
1
2
3
4
5
6
7
8**
9
10
11
5900
1600
14,000
88,000
120,000
3300
83,000
11,000; 1800, 2700
1300
5200
34,000
170;
<60;
<60;
130;
70;
90;
<60;
<60;
<60;
<60;
<60;
200; 90
<80;<60
<80;<60
130;<60
<60; 90
70;<60
130; 300
<60;240
<60;<70
<70; <80
<60;<70
<90; <100
nc
nc
110; <60
nc
nc
80; 60;
<60;<60;
nc
nc
nc
<60
<60
not collected
6" depth intervals (0-6"; 6-12", 12-18")
surface, 0-5", & 6-10" depth intervals
Location
o near WWTP, upstream
of East Side Drain
confluence
o downstream from
East Side Drain
confluence
o downstream from
Beaver Creek
confluence
River Raisin Sediment
1980 MBOCA
level in uq/kq
110
160,000
8900
Phase II RI MBOCA
level in uq/ka (9/88)*
<60, <60
<60, <60
<60, <60
* 6" depth intervals (0-6", 6-12")
-------
TAILE 2-3 (continued)
OF DETECTED MSOCA. OAC AND AC
CONCENTRATIONS
I MEDIA | SAMPLING AREAS | CONCENTRATION RANGES
| | | Phase til, in ug/L
1 ....|... .......... ............. ........ .
I WATER | M80CA
1 1
| Croundwater
1 OrourtOwater
1
1
i
| Croundwater
1
1
i
I Croundwater
1
1
(Surface yater
!
1
(Surface water
Resident ill yells |
1
Lagoon Area-- |
Confined Aquifer
Monitoring yells
Lagoon Area--
Confining Layer
Monitoring yells
Adrian WVTP--
Monitoring yells
Lagoon Area Drainages
East Side Drain
I SOIL/SEDIMENT
| Surface Soi I | Aarian
! 1
{Surface Soi 1
I
(Surface and
ISwDsurface Soi I
I
ISur'ace ana
ISwDsurface Soi I
|
1 Suosurface Soi I
1
j
(Seoiment
1
4
(Seoiment ana
(Surface Sei I
1
|Seai mcnt
1
(Sediment
(Sediment
1
Plant Area
Broken Pavements
Plant Area
Borings
Adrian yWTP
Borings
Clay Beneath
Lagoon sludge
Lagoon Sludge
Lagoon Area
East Side Drain
River Raisin
Plant Area
Catch Basins
•
-
DAC
•
-
-
•
-
AC
•
•
•
'
-
•
Phase lit. in ug/kg
3300 to
660.000
5300 to
2.800,000
*
-
-
tf
<70 to
410
na
"
-
-
•
"
'
-------
TAaXE 2-S
ftMMIT C» KTCCTO NMCA. DAC Aat AC
COMCCITtATlOJB
•ZD1A | SAW. JUG AJtEAS caHCEDTtATIOH UNGES
1 Maae 1. In t«/L
MATE! «OCA
firainduatar
Crnrrtimr
CreutJxittr
CroMuater
Surface Voter
Surfact Wattr
iMidanttal <1
Wtlls
Lagoon Ar«a» <1
Confirwd Aqjif«r|
Monitoring W«IU|
Lagoon Art»--
Confining Layer
Monitoring WtUt
Adrian MAP--
Monitoring UaLU
Lagoon Art*
Drainage*
East Sidt Drain
SOIL/SC01MENT
Surface Soil
Surface Soil
| turf act and
ISuteurfacc Soil
1
| Surf ace and
|S
«60 to 100
COMCEMTRATIOI IADGES
•h«*a 11. In ug/L
MOCA
<1
<1
«1
"
'
•
•tias* 11
•
«60 to 160
<100 to
96,000
<100 to 110
<60 to 60
AC
na
na
<1 to 17
'
•
in ug/kg
-
na
na
na
na
•
-------
13
Direct inhalation of MBOCA in the environment is unlikely, primarily
of the chemical's low volatility. It could be possible to inhale dust or
silt to which MBOCA was bound, especially under dry and windy conditions and
in those areas where surficial soils contain MBOCA, although most of the
areas where MBOCA was detected in the surface soils are either paved or
well vegetated, ard thef natural, hard clay soils lure hot easily disturbed.
Current MBOCA levels in the air were not determined because previous on-site
and off-site air data indicated MBOCA levels below the current standard or
levels of concern. Because of MBOCA's low vapor pressure, it is not
considered a volatile compound, and therefore, the potential for MBOCA
releases to the environment via volatilization front surface soils is
negligible. Furthermore, the highest concentrations of MBOCA are in the
sludge and underlying clay, both of which are covered by the standing water
in the lagoon, thereby providing a "barrier11 to any potential
volatilization. MBOCA's Henry law constant of 1.8 X 10"8 atm-nP/mole
indicates volatization from aqueous solutions to be negligible, as well.
The inhalation route for MBOCA, therefore, was not considered.
The ingestion route of exposure is possible for some populations. Because
all groundwater and surface water sampled during the RI were free of
detectable MBOCA (except one surface water sample in the East Side Drain at
the detection limit), exposure through drinking water is negligible or non-
existent. MBOCA-containing surface soils encountered on-site and off-site
could possibly be ingested by humans and environmental populations from
normal activities. Ingestion of MBOCA through consumption of plants grown
in contaminated soil is also possible, especially if plant roots (e.g. -
carrots) grown in contaminated soils are eaten. Due to the lack of data
indicating if MBOCA contaminated soils are being used for growing vegetable
with roots for personal consumption and MBOCA levels in the produce, the
ingestion of MBOCA through produce consumption was not considered.
Ingestion of MBOCA through contaminated fish consumption also was not
considered, because of non-detected MBOCA levels in fish tissues during
previous (1979-1980) MNER studies. Exposure to MBOCA via ingestion of soil
or sediment would be more likely in wildlife, especially for earthworms and
other burrowing organisms and animals. However, because of the lack of
MBOCA data on wildlife and burrowing organisms and animals, and the absence
of hunting in the areas adjacent to the ADC Site, this route of exposure to
human population was not considered.
Dermal absorption of environmental MBOCA is a possible route of exposure for
populations coming in contact with MBOCA contaminated soil on-site and
off-site. If bare skin is exposed to MBOCA-containing soil, the chemical
could be absorbed through the skin, especially in unfenced, accessible areas
where MBOCA is present in surficial soils/sediment. Bare feet, legs, hands
and forearms would provide routes for entry in human populations; paws,
tails, feet and underbellies would be the exposed areas in most animal
populations. Animal population exposure to MBOCA through dermal absorption
will not be considered because of the lack of site-specific RI data. Again,
binding of MBOCA by soil may make it less releasable to the skin and thus
reduce the level of exposure.
-------
14
In the EA, the children population was not considered, as the health
assessment was concerned with carcinogenic risk only, and cancer-related
data for children is lacking.
Sixteen adults are employed at the Adrian WWTP where some of the surface
soils are contaminated. At least one person is present during each 8-hour
shift. The total number of industrial and commercial adult employees in the
vicinity of the ADC Site are 2,250 (Adrian Chamber of Commerce). Anderson
Development Company currently employs 130 persons, of which 70 work in the
day shift, and 30 in each of the other two 8-hour shifts. There are ADC
workers who work around the lagoon. Three to four other ADC employees and
up to 10 railroad workers may also visit the areas adjoining the ADC lagoon
for short periods.
Wanderers/explorers could come in contact with MBOCA contaminated
soil/sediment at the Adrian WWTP, ADC lagoon area and the East Side Drain.
The estimated population of such wanderers/explorers at the ADC lagoon and
WWTP is relatively small because of the existing fencing and 24-hour per day
presence of employees for surveillance. The East Side Drain, because of its
steep and thickly wooded side slopes, is also not very welcoming of
wanderers/explorers. Any wanderer/explorer activities would also be
seasonal. The estimated populations of wanderers/explorers (i.e.,
trespassers) and frequency of their visits for the three areas are as
follows:
Adrian WWTP MBOCA Contaminated Area 20/year
ADC lagoon MBOCA Contaminated Area 16/year
East Side Drain MBOCA Contaminated Area 25/year
After reviewing the PI data and the available background data and
information, the following scenarios were identified through which adult
human population could potentially become exposed to MBOCA:
1. Residential Adult (oral ingestion and dermal) exposure to MBOCA
contaminated soils in off-site yard and public properties (parks,
County Fairgrounds);
2. Adi lit Trespasser (oral ingestion and dermal) exposure to MBOCA
contaminated sediment/surface soil at East Side Drain, Adrian WWTP and
ADC lagoon, and;
3. Occupational Adult (oral ingestion and dermal) exposure to MBOCA
contaminated soil/sediment/sludge at the Adrian WWTP and ADC lagoon.
Exposure scenarios which were initially evaluated but eliminated include
inhalation of MBOCA from the ADC Site, ingestion through consumption of
contaminated produce, fish and wildlife, oral ingestion and HC.TTMI contact
with contaminated groundwater and incidental or other oral ingestion and
dgrmql contact with contaminated surface water. Groundwater and surface
water are considered essentially incomplete pathways because;
-------
15
1. MBOCA has a lew solubility, and;
2. Only one surface water detection of MBOCA (1 ug/1 at
detection limit) was found during the RI.
Inhalation of MBOCA vapor or particulate is eliminated because:
1. MBOCA has a low vapor pressure, and;
2. Airborne particulate MBOCA data (1979-1980) did
not indicate high levels.
No other MBOCA contaminated soil/sediment from the ADC facility were used
for exposure scenario evaluation because the lagoon area soil MBOCA
concentrations are expected to be highest and are expected to represent
worst case exposure scenarios.
While the Statement of Work attached to the Administrative Order by Consent
entered into by Anderson Development Company and U.S. EPA states that the EA
will "determine the overall magnitude and probability of actual or potential
harm to public health and the environment as a result of the MBOCA
contamination11, the presence of other chemicals in the lagoon sludge may
raise the question of whether unacceptable risks may exist from those
chemicals. A preliminary toxicity screening was performed to answer this
question and indicated that the other chemicals are not present in levels
which pose elevated health risks. The purpose of this was to ensure that
those chemicals most likely to pose potential human health risks were
addressed in the risk assessment.
For each chemical positively identified in the lagoon sludge during Riase IV
sampling, a toxicity value (either a reference dose or a slope factor) was
obtained from the IRIS (Integrated Risk Information System) database. Using
the human intake factor (HIT) for the residential scenario, and an
acceptable excess lifetime cancer risk of 1 X 10E-06 (for a carcinogen) or a
hazard index (HI) of 1.0 (for a noncarcinogen) , clean-up levels were
calculated using the following formulae:
For Carcinogens: For Noncarcinogens:
C = Target Risk T^el C = RfD
(HIF) (SF) HIF
where;
C = Clean-up Level, mg/kg
HIF = 3.9 x E-07 kg/kg-day
RfD = Reference dose for a particular noncarcinogen, mg/kg-day
SF = Slope factor for a carcinogen, (mg/kg-day) -1
-------
16
on this screening, the Endangerment Assessment ruled cut the potential
for adverse health effects from these chemicals.
VH. DOCCMPI1!AT1OT OF SIGNIFICANT CHANGES
The Responsiveness Summary attached hereto addresses the comments received
during the 38 day public comment period on the Proposed Plan. The Proposed
Plan identified ISV as the preferred alternative for this Site; this Record
of Decision reflects the Agency's selection of that alternative.
VTTT- EE5CRIPTICN OF AUERNAT1VES
The major objective of the FS and the Proposed Plan was to evaluate remedial
alternatives consistent with the goals and objectives of CERCEA, as
by SARA. The cost work-ups, as presented in the FS, for Alternatives 2
through 7 below are based on the excavation of clay beneath the lagoon to a
depth of five (5) feet. During RI field activities, vertical sampling could
not be accomplished at depths greater than five feet into the clay. Three
locations were selected for Phase IV sampling. At two of these locations,
MBOCA was not found above the clean-up level at five feet. However, MBOCA
levels of 6.0 mg/kg and 3.2 rog/kg were detected at a depth of 4.5 feet at
these locations. At the third location, MBOCA was detected at the 4.5 and
five foot depths an concentrations of 51 mg/kg and 37 mg/kg, respectively.
No true pattern of MBOCA degradation with depth could be ascertained from
this sampling, because of the non-linearity of data. To better delineate
the vertical extent of MBOCA contamination, more sampling is required.
However, for the purposes of FS cost estimates, it was assumed that the five
foot depth represented that depth at which MBOCA concentrations would be
below the clean-up action level, and would therefore be the depth necessary
to achieve a Type B clean-up under Michigan Act 307. Therefore, the capital
cost of the alternative selected in this Record of Decision may increase if
further sampling results indicate that treatment to clay depths below five
feet are needed.
Alternative 1 - (Alternative A-l in the FS) - No Action Alternative. No
remedial action will be undertaken at the Site. No costs are associated
with this alternative.
Alternative 2 - (Alternative B in the FS) - Excavation, On-site RCRA type
landfill. This alternative involves the excavation of contaminated
materials (i.e., surface soils, sludge, and clay to a depth of about five
feet) and consolidation into an on-site RCRA type landfill.
The implementation of this alternative begins with Site mobilization which
includes the establishing of truck loading areas, minor clearing and
grubbing, establishment of work areas for contractor offices, establishment
of a decontamination area, and delineation of contaminated surface soil and
material staging areas.
-------
17
This alternative begins with the pumping out of the entire volume of
standing water in the lagoon. This water would be tested for solvent
concentrations and disposed of in an appropriate manner by a licensed waste
hauler.
Following removalr of -the standing water,—lime and- fly ash would be added to
the lagoon sludge to provide cementing properties to the sludge and achieve
reduction in shrink/swell behavior. Furthermore, metals in the sludge would
be somewhat immobilized. Based on RI sampling, it is estimated that MBOGA
trations above the health-based clean-up level are present at clay
depths of up to five feet. Therefore, the stabilized sludge and clay
beneath the lagoon up to a depth of five feet would be excavated and staged
in a predetermined staging area. Additionally, at least three inches of °
dried sludge/clay from the lagoon side slopes would be removed and staged.
The total volumes of excavated materials amount to approximately 450 cubic
yards of sludge, 2350 cubic yards of underlying natural clay and 200 cubic
yards of sidewall sludge and clay.
The cleaned lagoon would be backfilled with two feet of compacted clay. A
100 ft by 75 ft area in the southwest section of the lagoon would be filled
with local soils. The remaining 200 ft by 100 ft section of the lagoon
would be utilized to construct a RCRA type landfill. The staged material
would be placed above the liner and leachate collection system. A RCRA
multi-media cap would then be placed above the contaminated materials.
Because of the fact that inorganics in the sludge would be stabilized and
because of MBOCA's high affinity for organic matter and low solubility in
water, any leachate that is generated is expected to be relatively free from
high concentrations of contaminants. The leachate would be pumped to the
ADC process wastewater treatment plant prior to discharge to the Adrian
WWTP, or prior to being disposed of via a licensed waste hauler.
Two clusters of grourdwater monitoring wells (each with one shallow and one
deep well) would be constructed north of the lagoon.
Estimated Construction Costs $ 495,420
Estimated Annual O&M Costs $ 15,300
Estimated Total O&M (FW) $ 109,150
Estimated 30 Year Present Worth $ 604,570
This alternative is expected to take four (4) months to complete.
Alternative 3 - (Alternative C in the ES) - Excavation and Off-Site
landfill ing. This alternative involves excavation of contaminated surface
soils around the lagoon, solidification and excavation of the lagoon sludge
lagoon sidewall excavation, excavation of clay to a depth of five feet and
off-site disposal of all contaminated materials in a RCRA permitted
landfill.
Mobilization and work area delineation activities are similar to that
described above for Alternative 2. Standing water in the lagoon would be
removed and disposed of in an appropriate manner. The volumes of excavated
-------
18
materials would be the sane as those identified in Alternative 2. The
excavated, clean lagoon would be backfilled up to the ground surface with
clean fill. The excavated surface soil area would be backfilled with 18
inches of clean fill and six inches of top soil. Two groundwater monitoring
well clusters would be constructed north of the lagoon.
Estimated instruction Costs $1,172,250
Estimated Annual O&M Costs $ 6,500
Estimated Total O&M (FW) $ 14,500
Estimated 2 Year Present Worth $1,186,750
This alternative is expected to take two (2) months to complete.
Alternative 4 - (Alternative I>-1 in the FS) - Excavation and On-Site
Incineration. This alternative consists of on-site incineration of
contaminated soils, sludge and clay followed by disposal of the ash back
into the lagoon. (It is anticipated that the ash would pass the TdP Test
and disposal at an off-site RCRA landfill would not be necessary.) The
alternative proposed in the FS utilizes rotary kiln incineration although
other technologies such as infrared incineration and circulating bed
combustion are available and have been employed at other sites. This
alternative would destroy MBOCA and any other organic constituents, and
would provide for reduction of MBOCA to levels below the action level for
the Site.
A trial burn would be conducted to ensure that performance criteria are
being met and to ensure that the design of the air pollution control train
if satisfactory to meet Federal and State air emissions requirements.
Standing water in the lagoon will be managed as described above.
The volume of materials to be incinerated would be the same as that
identified for Alternatives 2 and 3 above. Gaseous emissions from the
incinerator would pass through a quench tower, followed by a Venturi
scrubber and packed (absorption) tower prior to discharge to atmosphere via
a stack. Emissions would be monitored for criteria pollutants under the
Clean Air Act, and to ensure that a 99.99% destruction and removal
efficiency (ERE) is attained for MBOCA. Incinerator ash and scrubber
blowdown (dependent on TdP) would be placed back into the lagoon.
The groundwater monitoring program would be extend for 30 years and consist
of laboratory analysis for MBOCA only.
Estimated Construction Costs $3,699,340
Annual O&M Costs $ 6,500
Estimated Total O&M (IV) $ 38,530
Estimated 30 Year Present Worth $3,737,870
This alternative is expected to take six (6) months to complete.
Alternative 5 - (Alternative D-2 in the FS) - Excavation and In Situ
Vitrification (ISV) . This alternative involves in sitai (or in-place)
heating and melting of contaminated soils, sludge and clay resulting in the
-------
19
destruction and removal of MBOCA and other organic contaminants and
ianobilization of inorganics and any organics which nay be present as
residuals in the vitrified mass.
The ^eaacfc-design-parameters-will-be-detprmined-follcwing-an-engineering^
scale treatability study, in which a predetermined mass (about 60 pounds) of
contaminated soils, sludge and clay and a predetermined mass of "clean"
surrounding soils (about 300 pounds of uncontaminated, natural clay) are
sent off-site, and a small-scale test is conducted to determine the
technical feasibility of ISV. Results of the treatability study would be
available within approximately 10 to 12 weeks.
Following the treatability study, the contractor would mobilize to the Site.
Site preparation work would begin, including clearing and grubbing,
construction of decontamination facilities and set-up of the ISV
contractor's trailers.
Following removal of the standing water in the lagoon, excavation of
contaminated soils, sludge and clay to a depth of approximately five feet
would take place. The sludge and clay would be excavated from an area of
about 100 feet by 75 feet and placed in the unexcavated portion (about 200
feet by 100 feet) of the lagoon.
Electrodes would then be placed into the ground. Because of the low
electrical conductivity of soil, a conductive mixture of graphite and glass
frit would be placed over the excavated soils between the electrodes, thus
serving as an initial conductive (i.e., starter) path. An electric current
would melt the soil, raising it to temperatures of about 1600 to 2000
degrees Oelcius. A very steep thermal gradient (i.e., about 150 to 250
degrees C per inch) precedes the advancing melt surfaces. Large-scale
ISV systems can melt soils at a rate of about 4 to 6 tons per hour.
As the thermal gradient advances, organic contaminants first vaporize then
pyrolyze (i.e., decompose in the absence of oxygen) into elemental
components. Organic pyrolysis products are typically gaseous. These gases
move slowly through the melt (because of the high viscosity of the molten
materials) toward the upper melt surface. Some of these gases may dissolve
in the molten mass; however, the majority move to the surface. The gases
that are evolved during the melt are collected by an off-gas collection hood
which is placed over the melt area. If combustible gases pass through the
"dry zone" and are present, they will combust upon contact with air beneath
the collection hood. The hood is made of a special fiberglass construction
able to consistently withstand temperatures of 400 degrees C. These gases
are then treated in a scrubber system, high-efficiency particulate air
(HEPA) filters and dual-staged (i.e., in series) carbon adsorption beds
prior to discharge to atmosphere.
When the electric current ceases, the molten mass cools and solidifies into
a glass-like material that will permanently retain its physical and chemical
integrity. After vitrification is completed for a given area, electrodes
are placed in an adjacent area, and the process is repeated until the entire
-------
20
20,000 square foot area is vitrified. When vitrification is oonpleted, the
lagoon would be backfilled with clean fill.
Two clusters of groundwater monitoring wells would be constructed north of
the lagoon. Groundwater monitoring for MBOCA would take place for 30 years.
Estimated Construction Costs $2,325,520
Estimated Annual O&M Costs $ 6,500
Estimated Total O&M (PW) $ 38,530
Estimated 30 Year Present Worth $2,364,050
This alternative is expected to take four (4) months to complete.
The FS cost estimate for ISV is based on an ISV processing cost of $350 per
ton. This correlates to the cost estimates for two other Superfund Sites in
Michigan: the Ionia Municipal Landfill in Ionia and the Parsons Chemical
Site in Grand Ledge. The Ionia Site FS indicates an ISV processing rate of
$300 per ton. The Parsons Site final contract shows that the first 1000
cubic yards of contaminated materials will be processed at a rate of $800
per cubic yard (roughly $615 per ton) and the remaining volume (2800 cubic
yards) of contaminated materials will be processed at a rate of $400 per
cubic yard (roughly $310 pert ton). The Parsons' costs agreement includes
all mobilization costs, site preparation costs, utilities, administrative
costs and other related cost items.
Alternative 6 - (Alternative D-3 in the FS) - Excavation, On-Site
Chemical/Biological Oxidation and On-Site Disposal. This alternative
involves the chemical and biological oxidation of contaminated soils, sludge .
and clay. Prior to implementation of this alternative, a bench or pilot-
scale treatability study would be conducted to obtain necessary process and
design information.
Following site mobilization and lagoon water removal, all soils, sludges and
clay above the action level would be excavated and staged on-site. A slurry
of these contaminated materials would be mixed with an oxidant (e.g.,
potassium permanganate) and an adsorptive/bulking material (e.g., granular
carbon). Natural soil microorganisms and their nutrients (nitrogen,
phosphorous and potassium) would be added in this mixing unit or in a
separate mixing unit.
Off-gases from the mixing units would be collected and treated by vapor
phase carbon adsorption prior to discharge to atmosphere. The treated
slurry containing microorganisms would be retained in a combination
dewatering/biotreatment unit. To provide for accelerated biodegradation,
the supernatent would be recirculated back to the lagoon to prepare a slurry
of contaminated soil, sludge and clay.
After dewatering, the sludge/residue would be tested for compliance with
TCLP, and proper disposal, either on-site or off-site would follow.
Two monitoring well clusters will be constructed north of the lagoon, with
MBOCA monitoring to follow for 30 years.
-------
21
Estimated Construction Costs $1,245,170
Estimated Annual O&M Costs $ 15,300
Estimated Total O&M (PW) $ 90,710
Estimated 30 Year Present Worth $1,335,880
This alternative is expected to take nine (9) months to complete.
It should be noted that following bench-scale experiments using hydrogen
peroxide (t^C^) as the oxidizing agent, ADC changed the process depicted in
the FS. Because of the failure of H2O2, and the technical drawbacks of
attempting to use ultra-violet light on an opaque slurry, the PGP began to
perform bench-scale oxidation experiments with potassium permanganate
(WlnO4). Although these subsequent test results were encouraging, several
major concerns remained. In effect, ADC virtually revised the entire
chemical oxidation/biological degradation alternative. At the time this
Record of Decision was signed, ADC was pursuing pilot-scale tests on
chemical oxidation, and dropped biological degradation from further
consideration. Costs estimates on this revised treatment scheme by the PRP
and U.S. EPA differ significantly. Anderson costed the "new" chemical
oxidation alternative at approximately $1.1 million; U.S. EPA costed this
alterantive at approximately $3.1 million. Further treatability testing and
optimization testing should result in an accurate estimate of capital and
operating costs.
Alternative 7 - (Alternative E in the FS) - Excavation, Off-Site
Incineration and Off-Site Disposal. This alternative involves the
excavation of approximately 3000 cubic yards of contaminated soils, sludge
and clay, followed by the transport and off-site incineration of these
contaminated materials.
Following site mobilization and lagoon dewatering, contaminated soils,
sludges and clay to a depth sufficient to attain the clean-up action level
will be excavated and trucked off-site to a RCRA permitted incinerator.
After incineration, the residues will be placed in a RCRA landfill.
The excavated areas will be backfilled with clean fill materials. In
addition, two clusters of groundwater monitoring wells north of the lagoon
would be installed and MBOCA sampling will be conducted for a period of two
years.
Estimated Construction Costs $6,508,780
Estimated Annual O&M Costs $ 6,500
Estimated Total O&M (PW) $ 14,500
Estimated 2 Year Present Worth $6,523,280
This alternative is expected to take two (2) months to complete.
-------
22
IX. SaHARY OF THE OGMPARACTVE ANAT.YSTS OF
A. The Nine Ev?*i'*»t'icn Griter'*
Hie FS examined nine alternatives, including the No Action alternative, and
evaluated them according to technical feasibility, environmental protection,
public health protection and institutional issues. In addition to these
nine, the FS also presented two variations which were based on excavation to
a two foot depth into the clay. However, these variations were presented
for costs comparisons only and were not evaluated against the nine criteria
set forth in the NCP. The U.S. EPA carried forth each of these alternatives
for evaluation in its Proposed Plan, but will evaluate only six alternatives
along with the No Action alternative in this Record of Decision.
Alternatives not considered in this ROD were Institutional Controls, Partial
Incineration and Cap, and lagoon Cap. The alternatives evaluated in this
document provide a sufficient array of potential Site remedies, and those
not carried forward would not have complied with the statutory requirements
of the Michigan Environmental Response Act (MERA or Act 307) .
Ihe alternatives were evaluated according to the following nine criteria
which are used by the U.S. EPA to provide the rationale for the selection of
the final remedial action at a site:
UCLTEKLA
1) Overall Protection of Human Health and the Environment addresses
whether or not a remedy provides adequate protection and describes how risks
posed through each pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
2) Compliance with State and Federal Regulations (ARAR's) addrpssps
whether or not a remedy will meet all the applicable or relevant and
appropriate requirements of other Federal and State environmental statutes
and/or provides grounds for invoking a waiver.
PRIMARY BAIANCTNG CKTIEKIA
3) Reduction of TtocLcity, Mobility, or Volume is the anticipated
performance of the treatment technologies a remedy may employ.
4) Short-Term Effectiveness aA^ppgcpg the period of time needed to achieve
protection, and any adverse impacts on human health and the environment that
may be posed during the construction and implementation period until cleanup
goals are achieved.
5) Ljang-Tterm Effectiveness and Permanence refers to the ability of a
remedy to maintain reliable protection of human health and the environment
over tiire once cleanup goals have been met.
-------
23
6) Tr1 gMPJTt-afrri li ty is the technical and administrative feasibility of a
remedy, including the availability of materials and services ncsar^ to
implement a part"'f^li^r option.
7) Oast includes estimated capital and operation and maintenance costs,
and net present worth-costs. - — —
MJLXLFYIN3 CKTmoA
8) State Acceptance indicates whether, based on its review of the RI/FS
and the Proposed Plan, the State concurs in, opposes, or has no comment on
the preferred alternative at the present time.
9) Community Acceptance will be assessed in the Record of Decision
following a review of the public comments received on the RI/FS report and
the Proposed Plan.
B. OmiJnrat"ive Analyses of Alternatives
Each alternative was evaluated using the nine criteria. Ihe regulatory
basis for these criteria comes from the National Contingency Plan and
Section 121 of CERCLA (Cleanup Standards) . Section 121 (b) (1) states that,
"Remedial actions in which treatment which permanently and significantly
reduces the volume, toxicity or mobility of the hazardous substances,
pollutants, and contaminants is a principal element, are to be preferred
over remedial actions not involving such treatment. The off-site transport
and disposal of hazardous substances or contaminant materials without such
treatment should be the least favored alternative remedial action where
practicable treatment technologies are available." Section 121 of CERCLA
also requires that the selected remedy be protective of human health and the
environment, cost effective, and use permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum
extent practicable.
Each alternative is compared to the nine criteria in the following section:
1) Overall Protection of Human Health and the Environment.
All of the alternatives presented in this Record of Decision, with the
exception of Alternative 1 (No Action) , would provide protection to human
health and the environment. This protection would be obtained by preventing
direct contact with contaminated sludge, soil and clay, or by treating
contaminated materials such that MBOCA concentrations are reduced to health
based levels. Protection can also be obtained by preventing percolation of
surface water and/or groundwater flow through the contaminated media.
Excavation of all contaminated materials to a depth which would ensure that
the clean-up level is attained, followed by either in situ treatment
(Alternative 5) or off-site treatment and off-site disposal (Alternative 7)
would offer adequate protection. Excavation of all contaminated materials
to the action level followed by either on-site treatment and on-site
-------
24
disposal (Alternative 4) or off-site disposal (Alternative 3) would also
achieve a 10E-06 risk level at the Site.
However, Alternative 3 would be considered the least favored of these based
on Section 121 of SARA, the NCP and Michigan Act 307. As stated in Section
121(b) of SARA, "The offsite transport and disposal of hazardous substances
or contaminated materials without such treatment should be the least favored
alternative remedial action where practicable treatment technologies are
available." Alternative 6 underwent a pre-Treatability Study bench-scale
screening to determine the effectiveness of hydrogen peroxide in reducing
MBOCA levels in a soil/clay/water slurry. Results of this pre-scxeening
were found to be less than favorable. Furthermore, the PRP-produced
Treatability Study Work Plan which was reviewed by U.S. EPA technical
experts at the Robert S. Kerr Environmental Research Laboratory (RSKERL) in
Ada, Oklahoma and the Risk Reduction and Engineering Laboratory (REEL) in
Cincinnati, Ohio was found to be deficient in numerous areas. U.S. EPA, in
consultation with MENR, determined that the Chemical Oxidation and
Bioremediation scenario, as presented in the FS, would not offer adequate
MBOCA degradation to warrant replacement of ISV as the preferred alternative
for this Site. As stated in the Responsiveness Summary attached to this
document, the PRP is exploring additional pilot-scale tests and
optimization treatability studies. The results of these should be available
in December 1990. ADC has changed its technical approach to chemical
oxidation and has revised the treatment process, method of clay excavation
and oxidizing agent (to KMnO4). ADC has been conducting bench-scale
experiments since April 1990. To date, ADC still has not generated a
conclusive body of evidence which would support their claims that chemical
oxidation is a viable alternative.
Tables 3 and 4 illustrate the probable end products of Alternatives 5 and 6,
lively. It is important to note that for Alternative 6, there exists
the likelihood that any and all of the contaminants found at the Site could
form reaction products other than those listed. Therefore, the potential
for production of possible toxic chemicals needs to be fully investigated
before much merit is given to the adequacy of Alternative 6 in terms of
overall protection.
2) Qmpi TaryTp witii Applicable or Relevant and ^ \ *i *
-------
Table 3
Probable Producti and By-product* of ISV Treatment
CONTAMINANT
METALS:
Antimony (Sb)
Areenlc (At)
Barium (Ba)
Beryllium (Be)
Cadmium (Cd)
Chromium (Cr)
Lead (Pb)
ManganeM (Mn)
Magnetlum (Mg)
Silver (Ag)
Sulfur, molecular (S)
Titanium (Tl)
ORQANICS:
Acetone
Tetrachloroethane
Toluene
Acetaldehyde
Cyclobulane. ethyl
Hexane
1-pentene, 2.4.4-trlmelhyl
Polychlorlnated blphenyla (PCBa)
Propanelhiolc acid/eater » 1.2-dtehlorobenzene
Cyclohexane. 1,1 -dimethyl
1 ,2-dlchlorobenzene
4_M»A>i«*-dimethyl-
3(4H)-dlbenH>turanone
CO
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
CO2
A
A
H2O
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
N2
A
A
Proba
NO
C
C
MePrc
NO2
C
C
•duct*
CI2
B
B
B
B
B
and By
HCI
B
B
B
B
B
-prodi
SO2
B
Ida
SO3
H2S
OTHERS
A: Elemental Sb. wlfldea ft oxMee In glc.ee
A: Elemental Aa. aulRdea & oxtdea In glaae
A: Ba oxldea In glaee
A: Be oxldea In glaaa
A: Cd oxldea In glaaa
A: Cr oxldea In glaaa
A: Elemental Pb 4 oxldea In glaae
A: Mn oxldea In glaaa
A: Elemental Mg A oxldea m glaaa
A: Ag oxldee In glaae
A:Sulfidealnglaaa
A: Elemental Tl & oxldea In glaaa
A:Ch(orldeamglaaa
A:Chlorldeelnglaee
A:ChlorkJ«»lngla«a
A: Chlorldee hi glaae
AiChlortdealnglaaa
-------
Table 3
Probable Product* and By-producl* of ISV Treatment
CONTAMINANT
enzoic acid
2-<2H-benzotriazol-2-yl)-4-methyl-phenol
2 -methyl- 1-ptopene tetramer
6.5-dim«thyl-2-h9x«ne
4-chloro-e-methoxy-2pyrlmidinamlne
2-(2.4-dinlrophenyl)-S,e.7.a-tetrahydro-
2H-1 ,2.3-benzothladla2fn*
4a.9-4ihydro^.gb^imethyl-3(4H)dlbenzofuranone
N-^-melhylcyclohexyl^N'-phenyt-urea
4.4-melhylene ble-benzeamlne
1.1-*ullonyl M*|4-chloroH>«nzen«
t ,4-dimethyoxy-anthracene
4.4'-melhylene bl»]2-chloroH>«f*«mln*
2-<2H-benzotrla*ol-2-yl)-4-n"thrl-ph«nol
2.3.3a.4.7.7a-hexahydro-
2.2.4.4.7 ,7-nexamelhyl-IH-lndene
10-fnethyl-elco*ane
4-dlmethyoxy-«nthracene
Slyiena
Methylen* chloride
Tetrahydrofuran
2-fnelhyl-2-propanol
1 . 1 ,2-trlchlof o-l ,2.2-Ulfluofoettune
1-pfopanol
4-hydtoxy-3-mettiy1-pentanone
4.4'-
-------
Table 4
Probable Products and By-products of Chemical Oxidation by KMnO4
CONTAMINANT
METALS:
Antimony (Sb)
Arsenic (As)
Barium (Ba)
Beryllium (Be)
Cadmium (Cd)
Chromium (Cr)
Lead (Pb)
Manganese (Mn)
Magnesium (Mg)
Silver (Ag)
Sulfur, molecular (S)
Titanium (Ti)
ORGANICS:
Acetone
Tetrachloroethane
Toluene
Acetaldehyde
Cyclobulane. ethyl
Hexane
1-penlene. 2,4,4-trlmethyl
Polychlorlnated blphenyls (PCBs)
Propanethlolc acid/ester » 1,2-dichlorobenzene
Cyclohexane. 1,1 -dimethyl
1,2-dichlorobenzene
4-methylphenol
Phenol
Bis (2-ethylhexyl) phthalate
Morphollne
4-hydroxy-4-methyl-2-pentanone
1 -methyl-2-pyrrolidinone
m-chloroanillne
4a.9b-dihydro-8.9b-dlmelhyl-
3(4H)-dlbenzoluranone
Probable Products and By-products i
CO
A
A
A
A
A
A
A
A
A
A
A
A
CO2
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
H2O
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
N2
B
A
NO
A
B
N02
A
B
CI2
B
B
B
B
B
HCI
A
A
A
A
A
SO2
B
S03
H2S
A
MnO2
[
A;
A|
A
Ai
A
A
A!
A|
A
A
B
A
A
A
A
A
A
A
A
A
A
A
A
A
A
OTHERS
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
-------
Table 4
Probable Products and By-products of Chemical Oxidation by KMnO4
Anderson Development Company, Adrian. Michigan
CONTAMINANT
O-(O-tolyloxy)-benzolc acid
2-(2H-beruotriazo)-2-yl)-4-methyl-phenol
2-methyl- 1 -propene tetramer
5,5-dlmelhyl-2-hexene
4-chloro-6-methoxy-2pyrlmldlnamlne
2-(2.4-dintrophenyl)-5.6.7.8-tetrahydro-
2H-1 .2,3-benzothladlazlne
4a.9-dihydro-8.9b-dlmethyl-3(4H)dibenzofuranone
N-(2-methy1cyclohexyl)-N'-phenyl-urea
4.4-methylene bls-benzeamlne
1 .1 -sulfonyt bls|4-chloro|-benzene
1 ,4-dlmethyoxy-anlhracene
4.4'-methylenebls(2-chloro]-benzeamlne
2-(2H-benzotrlazol-2-yl)-4-methyl-phenol
2.3.3a.4.7.7a-hexahydro-
2.2.4.4.7.7-hexamethyl- 1 H-lndene
1 0-methyl-elcosane
4-dlmethyoxy-anthracene
Slyrene
Melhylene chloride
Tetrahydroluran
2-methyl-2-propanol
1 . 1 ,2-trlchloro- 1 ,2.2-lrlf luoroethane
1-propanol
4-hydroxy-3-methyl-penlanone
4,4'-methylene bis(2-chlofO)anlline (MBOCA)
N-acetyl-4.4'-methylene bls(2-chloro)anillne |AC|
N.N'-dlacetyl-4.4'-methylene bls(2-chlofo)anlline |DAC|
Probable Products and By-products
CO
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
C02
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
H2O
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
N2
A
B
B
B
B
B
B
B
B
NO
B
A
A
A
A
A
A
A
A
N02
B
A
A
A
A
A
A
A
A
CI2
B
B
B
B
B
B
B
HCI
A
A
A
A
A
A
A
S02
B
SO3
C
H2S
A
Mn02
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
OTHERS
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
Probable
LEGEND:
A - Most probable reaction to occur
B - Second most probable reaction to occur
C - Least most probable reaction to occur
-------
25
General groundwater monitoring and corrective action requirements for waste
management units are included in 40 CFR Part 264 Subpart F, promulgated
vmder the Resource Conservation and Recovery Act of 1976 (RCRA). Although
RCRA is not applicable to this Site because no disposal of hazardous waste
took place due to the fact that the MECCA is not considered a RCRA listed
waste (see below), these requirements are relevant and appropriate for the
Site. This subpart requires a system of wells to detect hazardous
constituents in groundwater downgradient of the waste unit. The detection
of waste unit constituents downgradient could trigger the need for
:tive action. Corrective action is required for all releases of
hazardous constituents from any solid waste management unit pursuant to 40
CFR Part 264 Subpart F. There have, however, been no detected releases of
contaminants in the groundwater. All alternatives, except the No Action
Alternative, include a groundwater monitoring program which would meet the
subsequent criteria of 40 CFR Part 264 Subpart F monitoring requirements.
Alternatives 3 and 7 involve the excavation and off-site transport of
contaminated materials. 40 CFR Part 262, is relevant and appropriate for
these alternatives classifying the Site as a generator of hazardous waste.
40 CFR Part 263 lists transporter regulations which are relevant and
appropriate to these alternatives. Alternatives 3 and 7 would comply with
40 CFR Part 262 and 263 ARAR's.
Ihe Clean Air Act sets maximum contaminant concentrations for airborne
releases. Alternatives 2 through 7 provide air monitoring to evaluate air
releases and assure compliance with this ARAR.
The Hazardous and Solid Waste Amendments (HSWA) to RCRA include provisions
restricting land disposal of RCRA hazardous wastes. The purpose of the HSWA
is to minimize the potential of future risk to human health and the
environment by requiring treatment of hazardous wastes prior to land
disposal. The land disposal restrictions (LCR's) under HSWA are not
applicable for those alternatives involving land disposal of contaminated
soil, sludge and clay or residual incineration ash because the wastes are
not RCRA listed wastes or RCRA characteristic wastes.
It was determined that the MBOCA found at the Site is not a RCRA listed U
waste because it does not meet the requirements of 40 CFR Part 261.33 (i.e.,
it is not a fHcrcrrrUaH commercial product, off-specification specie,
container residue or spill residue). LCR provisions are not considered
relevant and appropriate. The Agency is undertaking a rulemaking that will
specifically apply to soil and debris. Since that rulemaking is not yet
complete, U.S. EPA does not consider LCR's to be relevant and appropriate
at this Site to soil and debris that does not contain RCRA restricted
wastes. It may be noted, however, that the selected remedy meets MECCA
treatment standards under the LCR's. A treatment standard for MECCA is
included in the Third Thirds treatment standards, at Federal Register Vol.
55, No. 106. The revised concentration-based standard is 35 rag/kg. If
LCR's were relevant and appropriate, Alternatives 2 and 3 would not meet LCR
requirements because no treatment would take place. Alternatives 4, 5 and
7 would achieve clean-up goals more than one order of magnitude more
-------
26
stringent than the RCRA treatment standard for MBOCA. If Alternative 6 is
effective and if it were implemented, to meet Act 307 Type B clean-up
criteria, the treated soils, sludge and clay would meet the RCRA treatment
standard because the health-based action level established for the Site is
significantly lower than the RCRA treatment standard.
40 CER Part 400, Subchapter N regulates the quality of water discharged to
publicly owned treatment works (POTW's) , and may be an ARAR for Alternatives
2 through 7 which involve the removal of standing water in the lagoon.
The dean Air Act establishes National Ambient Air Quality Standards (NAAQS)
for primary air pollutants and is an ARAR for air emissions from the Site
during excavation, incineration and ISV.
The Department of Transportation (DOT) Hazardous Materials Transportation
Act, 40 U.S.C. 1801 regulates off-site transportation of hazardous waste and
is an ARAR for those alternatives involving off-site transport of MBOCA-
laden
The Occupational Safety and Health Administration (OSHA) establishes rules
and regulations at 29 CFR 1926 for remedial workers during construction
activities.
Alternative 1 does not meet identified TBC's.
Alternative 7 involves sending materials excavated from the site to an off-
site incinerator. The U.S. EPA off-site policy (OSWER Directive No.
9834.11) is a TBC for site remediation and will be followed to ensure that
wastes are sent to a RCRA permitted incinerator.
Alternative 3 involves sending materials excavated from the site to an off-
site landfill. The U.S. EPA off-site policy is a TBC and will be followed
to ensure that wastes are sent to a CERdA off-site compliant RCRA permitted
landfill.
The U.S. EPA Office of Groundwater has published Groundwater Classification
Guidelines (GWCG's) which enable classification of all groundwater as Class
I, H, or III, based on its use, value, and vulnerability- The confined
sand and gravel aquifer beneath the Site would be classified as a Class II
aquifer (current or potential source of drinking water). A Class II aquifer
should be protected from contamination which might render the aquifer
unusable or unacceptable as a source of drinking water. Therefore, contam-
ination or degradation of the groundwater is unacceptable and should not be
allowed to occur. The GWCG's are TBC for this Site. Alternatives 2 through
7, have various components which would or could comply with this TBC.
The U.S. EPA Environmental Criteria and Assessment Office has prepared the
Integrated Risk Information System (IRIS) to provide health based and
regulatory information on specific chemicals. IRIS provides chemical
specific information which is utilized by U.S. EPA in risk calculations and
-------
27
development of health based clean-up goals and is TBC. The Tables presented
in the FS and in this Record of Decision utilize ISIS values where
appropriate. As presented in Alternatives 2, 3, 4 and 7, the elimination of
the direct contact threat by complete excavation of the contaminated area
would comply with the health based clean-up goals developed utilizing the
IRIS database^ Mternatives-3-and-7y-theeliiniration-of-the-direct- contact
threat by treatment of MBOCA-laden materials via incineration would comply
with the health based clean-up goals developed utilizing the IRIS database.
The groundwater monitoring component of Alternatives 2 through 7 comply with
the TBC health based cleanup goals developed utilizing the IRIS database.
The U.S. EPA Office of Emergency and Remedial Response, Office of Solid
Waste and Emergency Response has prepared the Superfund Public Health
Evai nation Manual to provide methods and guidance in preparing health-based
risk assessments. The Tables presented in the FS and in this Record of
Decision utilize the SPHEM where appropriate. As presented in Alternatives
2, 3, 4 and 7, the elimination of the direct contact threat by complete
excavation of the contaminated soils, sludge and clay would comply with the
TBC health based clean-up goals developed utilizing the SPHEM. The
groundwater monitoring component of Alternatives 2 through 7 comply with
the health based clean-up goals developed utilizing the SPHEM.
State of Michigan ARAR's
The substantive provisions of Parts 6 and 7 of the rules promulgated under
Act 307 of the State of Michigan are considered an ARAR for the remedial
action to be undertaken at the Site. These rules provide, inter alia, that
remedial actions be protective of human health, safety and welfare, and the
environment and natural resources [Rule 299.5705 (1)]. The rules specify
that this standard is achieved by a degree of clean-up which conforms to one
or more of three clean-up types (Rule 299.5705 (2) et sea;.). Type A
criteria are based on reduction of hazardous substance levels to background
or below detectable levels (Rule 299.5707). Type B criteria are based on
reduction of hazardous substance levels to an acceptable risk level (e.g.,
an excess lifetime cancer risk of 1 X 10~6 for carcinogens) using
standardized exposure assumptions (Rule 299.5709). Type C criteria involve
a site-specific assessment of risk and remedy evaluation to select remedies
which do not pose an unacceptable risk (e.g., an excess lifetime cancer risk
of 1 X IQT6 for carcinogens). Remedy evaluation under Type C criteria must
include evaluation of alternatives which meet Type B criteria. This
evaluation must be made against a variety of factors listed in Rule
299.5717.
Alternatives 3, 4, 5 and 7 would meet the requirements of a Type A or B
clean-up under the Act 307 Rules. Alternative 3, however, involves off-site
landfilling of contaminated materials, without treatment, which is the least
preferred alternative under both SARA and Act 307. Alternative 6 has the
potential to achieve MBOCA reductions sufficient to meet Type A or B
requirements, but this has not been adequately demonstrated. Alternative 2
does not meet the Type A or B clean-up criteria, according to the State of
Michigan, as set forth in Rules 299.5707 and 299.5709.
-------
28
Act 348 of 1965 and Administrative Rules defines requirements for air
emissions during remedial actions and is an ARAR. All alternatives,
except the No Action Alternative, comply with this ARAR ty providing an air
monitoring program. Alternatives 4 through 7 would need to provide a stack
emissions monitoring program, as well.
Michigan Hazardous Waste Management Act, Public Act 64 of 1979, as amended,
sets regulations for generators and transporters of hazardous waste and
owners and operators of hazardous waste treatment, storage and disposal
facilities. This would be an ARAR for all alternatives except the No Action
Alternative.
Rule 613 is the RCRA equivalent to 40 CFR Part 264 as previously
described under Federal ARAR's.
Michigan Soil Erosion and Sediment Control Act, Public Act 347 of 1972 sets
regulations prescribing the requirements for soil erosion and sedimentation
control measures and procedures, and is an ARAR for Alternatives 2 through
7.
Michigan Occupational Health and Safety Laws, Michigan Act 154 of 1974
regulates working conditions for the health and safety of workers and is an
ARAR for Alternatives 2 through 7.
State of Michigan TBC's
SARA Section 121 (e) states that no permit shall be required for the portion
of any remedial action conducted entirely on-site. It is the intent of the
U.S. EPA to meet the substantive requirements of any permit related ARAR's
or TBC's.
Based upon the above analysis, Alternatives 4, 5 and 7 would meet Federal
and State ARAR's and TBC's.
3) Reduction of ToocLcity, Mobility, or Volume (TMV).
Alternative 1, No Action, would not result in the reduction of the toxicity
or mobility of MBOCA, nor in the volume of contaminated materials.
Alternatives 2 and 3 provide for containment of the contaminated soils,
sludge and clay, but offer no reduction in TMV via treatment.
Alternatives 4 and 7 would offer significant reductions in MBOCA toxicity
and mobility, and low to moderate volume reductions via thermal incineration
of MBOCA contaminated soils, sludge and clay. Destruction and removal of
MBOCA and other organics would be on the order of 99.99% by weight or
greater. Because these organics would oxidize, under ideal operating
conditions, to carbon dioxide, water vapor and hydrogen chloride, there
would occur some reduction in total volume of contaminated materi als as the
organics undergo a phase change. Additional volume reduction would occur as
the water present in the sludge and clay would vaporize and be discharged to
the atmosphere; because of the high moisture content of the sludge, the
-------
29
overall volume reduction could be as high as 10%. The inorganics present,
such as manganese, would be unaffected (i.e., would not sublimate) by the
operating temperatures of the rotary kiln (1800 to 2400 degrees F) and would
remain in the resultant ash.
TOP tests woulontefprmdne the proper procedure for handling the ash, yet it
is anticipated that the ash will pass the TCXP.
Alternative 5 would offer the greatest reduction in MBOCA TMV of the
alternatives considered in this Record of Decision. Organic contaminants
would undergo pyrolosis and breakdown of molecular bonds under extremely
high temperatures (2800 to 3600 degrees F) resulting in destruction
efficiencies of typically 99.9% to 99.995% by weight. The remaining
volatile and semi-volatile fraction is volatilized and captured by the off-
gas treatment system. These off-gases are routed through an air pollution
control train which includes dual-staged activated carbon adsorption beds.
In these carbon adsorbers, organics can be removed from the off-gas stream
with efficiencies as high as 99.9%. Therefore, total destruction and
removal efficiencies (ERE's) of organics through ISV can be as high as
99.9999% by weight.
Any particulate matter entrained in the rising gas plume would be treated in
fabric filters before the off-gases are discharged to atmosphere. Acid
gases which might result after elemental components such as hydrogen and
chlorine gas come in contact with ambient air, and cool, beneath the hood
are treated in a scrubber system prior to the removal of small particles
(> 0.3 urn dia.). As in Alternative 4, inorganic elements would not be
destroyed. However, inorganics would be chemically incorporated into the
residual obsidian-like ISV product, resulting in high reductions in the
mobility of inorganics. No other solidification or stabilization
technology can offer the reductions in inorganic mobility that ISV can.
Those inorganics which may sublimate (i.e., go from a solid to a gaseous
state) would be collected in the scrubber after the gases are cooled,
allowing for the metals and metal oxides to recondense. Volume reductions
as high as 40% can be achieved for sludges (depending on the moisture
content), and as high as 25% to 35% for most soils. Because of the
compacted nature of the clay beneath the Site, volume reductions in the clay
are expected to be lower than for most soils.
Alternative 6 would, in theory, offer reduction of MBOCA toxicity by
chemically oxidizing MBOCA to primarily carbon dioxide and water. The two
chlorine atoms in each molecule of MBOCA would probably react with hydrogen
to form hydrochloric acid, which can be readily removed in packed absorption
towers. Since extensive treatability studies have not been conducted on the
MBOCA-laden materials at the Site, an accurate prediction of the ultimate
reaction products from the addition of hydrogen peroxide and/or potassium
permanganate cannot be made. It is conceivable that many of the other
organic compounds with higher activation energies than MBOCA could cause
the oxidizing agent to react with them preferentially. If this were to
occur, the MBOCA removal efficiency could be markedly reduced. Pre-
screening bench studies did not show high levels of MBOCA destruction, even
at a 2:1 molar ratio of H2O2 to MBOCA. Furthermore, to determine the
-------
30
efficacy of H2C>2 as an oxidant, precise mass balances needed to be
performed, and were not done so by Anderson's contracted laboratory. Such
mass balances and analyses of all end products would indicate if any
chemicals are being generated which might be more toxic than MBOCA itself.
Follow-up bench-scale experiments with KMnO4 exhibited greater reductions in
MBOCA concentration, but as with the earlier H202 experiments, there were
concerns over the degree of quality assurance and quality control associated
with these tests. In addition, toxicity data on possible oxidation end
products were not provided by ADC, in spite of the fact that prior
experiments (Zabi3c, 1982) suggested the formation of certain, possibly
carcinogenic, azo compounds from the chemical oxidation of MBOCA via KMnCfy.
Some reduction of MBOCA mobility would, obviously, be expected if MBOCA
degradation occurs, yet it is improbable that such reduction would approach
that of Alternatives 4 and 5. Because chemical agents would be added to the
contaminated materials, volume increases would occur.
4) Short-Term Effectiveness.
Alternative 1 presents no potential short-term risks to workers, nearby
populations or the environment because no Site remediation will take place.
Alternatives 2, 3, 4, 6 and 7 include excavation activities which could pose
some risk to remedial workers. Some volatilization of organics and
generation of airborne MBOCA-laden particulate matter may occur during
sludge intrusive activities and excavation of soils and clay, thus
presenting the potential for contaminant inhalation by remedial workers.
Alternative 2, which includes the solidification and stabilization of the
contaminated lagoon sludge, would present the remedial workers with a higher
risk for inhalation due to the increased volatilization of organic
compounds. The potential for contaminant inhalation by remedial workers
under Alternative 5 is less than that for the above alternatives because an
off-gas capture hood will be placed above the treatment area. Additionally,
because of the fact that treatment occures in situ, the potential for dermal
contact and inhalation is lower for remedial workers than for the other
alternatives evaluated.
Additionally, a low risk of dermal exposure exists for the remedial workers
in each of the alternatives, with the exception of the Mo Action
Alternative. Risks to workers could be minimized by the utilization of
environmental monitoring equipment and personal protective equipment.
Proper dust suppression techniques could be used to minimize the amount of
fugitve emissions generated. During the execution of the clean-up tasks
associated with any of Alternatives 2 through 7, the risks to non-worker
populations (i.e., ADC plant employees and nearby residents) and the
environment would be relatively low or non-existent. Proper design and
maintenance of air pollution control equipment for Alternatives 4 and 5
would mitigate any potential risks to nearby populations. Similarly, off-
site incineration in a RCRA-compliant incinerator, as identified in
Alternative 7', would minimize the potential risks to populations near the
incinerator. For Alternatives 2 and 3, proper erosion control measures
would need to be taken to minimize any harm to the environment. Also, for
Alternatives 3 and 7, there exists the potential for the release of
hazardous materials during off-site transport due to spillage from trucks or
-------
31
traffic accidents. Soil spillage can be minimized or prevented by proper
covering of trucks prior to leaving the work zone. Alternative 6 would need
to undergo extensive toxicity screening in order to determine if toxic by-
products are generated during remediation activities.
The amounts of time necessary to cc^lete eacii alternative are presented
above-in SecticrrvTH;
5) Ifng-Verm Effectiveness and Bermanence.
Alternative 1, No Action, offers no long-term effectiveness or permanence.
Alternative 2 involves the construction of an on-site RCRA landfill which
would offer long-term protectiveness by eliminating the direct contact
pathway. Solidification and stabilization techniques would serve to reduce
the mobility of MBOCA in the sludge, thereby offering increased protection
to the confined aquifer beneath the lagoon. However, no landfill is leak
proof, and the potential for environmental releases would continue to exist
for the life of the landfill. Alternative 3 would involve removing all
contaminated materials with MBOCA concentrations above the health based
action level and placing them in an off-site RORA-permitted landfill. This
alternative, by virtue of the fact that MBOCA-laden soils, sludge and clay
would be removed from the contaminated area would offer a greater degree of
effectiveness than Alternative 2. As with Alternative 2, the potential for
contamination of the nearby environment would exist throughout the life of
the landfill. It should be further noted that SARA considers this
alternative to be the least favored alternative remedial action where
practicable treatment technologies are available.
The implementation of Alternative 2 will result in the reduction of the
mobility of MBOCA and the other contaminants in the sludge and clay by
providing a low permeability barrier to infiltration and groundwater.
However, because of MBOCA's low solubility in water, its high affinity for
organic matter, its high retardation factor, and the low hydraulic gradient
in the clay till beneath the Site, the benefits to be derived from reduction
of MBOCA mobility would be marginal, at best. Alternative 3, like
Alternative 2, would offer no reduction in TMV via treatment, but would
offer some reduction in contaminant mobility. The long-term protection of
Alternative 2 is directly related to the design of the leachate collection
system and liners.
Alternative 4 would offer a very high degree of long-term effectiveness as
organic contaminants such as MBOCA would be destroyed in the rotary kiln
which can attain a ERE of 99.99% by weight. Ihis alternative would
eliminate the potential for direct contact with contaminated soils, sludge
and clay. With proper maintenance of the rotary kiln and air pollution
controls, nearby populations and the environment can be assured of high
degrees of protection during the extent of the remedial action. Long-term
groundwater monitoring after completion of the Site remediation would
assure the effectiveness of this alternative. Alternative 7 would also
offer a very high degree of long-term effectiveness as the contaminated
materials would be sent off-site to a PCRA-permitted incinerator. Because
most contaminated materials with MBOCA above the health-based action level
-------
32
are to be removed front the Site, and incinerator ash would be disposed of
off -site, the groundwater monitoring program would not last as long as for
Alternative 4.
Alternative 5 would also offer a degree of long-term effectiveness to the
environment and nearby populations. Through a pyrolytic process (and, to a
much lesser extent, through combustion of partially ignited organics upon
contact with ambient air beneath the capture hood, and adsorption onto the
carbon beds) and process of encapsulation, ISV would offer a high level of
destruction for organics and a higher degree of inorganic mobilization than
Alternative 2. The remaining vitrified mass would be covered over with
clean native soil, thereby eliminating the potential for dermal contact. By
encapsulating any residual organics (presence of organics should be
negligible due to the extremely high temperatures and long residence times
they will be subjected to) and the bulk of inorganics in the glass-like
product, the confined aquifer beneath the lagoon would be protected for
"geologic timeframes." Groundwater monitoring and confirmational soils
sampling after completion of this remedial action would ensure protection of
the aquifer.
In theory, Alternative 6 would offer a high degree of long-term
effectiveness to the environment via chemical and/or biological oxidation
of MBOCA. The effectiveness of this alternative is dependent on the ability
of the oxidant (either ^2^2 or KMn°4) to preferentially break down MBOCA to
002 and H2O. Because of the myriad of organics and inorganics present in
the sludge and underlying clay, a simple stoichiometric relationship cannot
be predicted. Any of a number of chemical reactions could occur
simultaneously, and to ensure the necessary oxidation of MBOCA, levels of
H2C>2 or KMn04 much greater than that needed to react soley with MBOCA would
be needed. Furthermore, it is unknown whether more toxic reaction products
may be formed. Also, not enough information exists on all the potential
degradation products of MBOCA to make accurate assessments about the
ultimate fate and transport of these chemicals. If a treatability study,
including extensive quantitative and qualitative assessments of all
reaction products, shows that the ultimate end products would be 002, H20
and innocuous compounds, then a determination can be made that this
alternative would offer a degree of long-term effectiveness equal to that
of Alternatives 4, 5 and 7.
6) Tnpl
There are no implementability issues with the No Action because no
activities will be undertaken at the Site. The methods of excavation and
solidification/stabilization for Alternative 2 require the application of
available construction equipment and proven technologies. The total time.
for implementation of this alternative is four months from the contractor's
notice to proceed.
As in Alternative 2, the excavation and solidification/stabilization methods
for Alternative 3 utilize readily available construction equipment and
technologies. Since waste disposal would take place at an off -site
facility, this alternative would not require new construction activities.
-------
33
No permits would be required for activities done at the Site, but permits
would be required for the trucks which will haul materials off-site.
Because of the relatively small volume of waste involved, finding available
capacity at a RCRA Subtitle C landfill may not be a problem.
On-site incineration (Alternative 4) wouldbermoderately easy to implement
at the Site. There may be some difficulties in moving all the necessary
trailers into the area immediately adjacent to the lagoon. These spatial
traints would probably preclude ADC from using the infrared (IR)
incinerator, which would require a number of full-length tractor-trailors to
mobilize simultaneously at the Site. Because a portable rotary kiln would
require less space than an IR unit, ADC is limited to this type of
incinerator or a circulating fluidized bed incinerator (N.B.- a circulating
bed combustor was not presented by ADC for evaluation in the FS). A trial
burn would be necessary to ensure that all applicable emission standards are
met. By varying loading rates and incinerator parameters such as residence
time and amount of combustion air, the proper operating conditions can be
predicted to ensure air pollution standards are met during full-scale
operations. Because of the small volume of materials to be handled, the
unit cost of incineration would excalate considerably and there may be sane
difficulty in finding a contractor to treat such small volumes. The total
til*** to implement this alternative would be approximately six months from
contractor's notice to proceed.
Alternative 5 involves an innovative technology, ISV. Only one contractor
provides the technology described above. Currently, the contractor has only
one piece of equipment but is building a second which should be ready for
use in late 1990. Although this technology has not yet been applied on a
commercial scale at a Superfund Site, a number of bench-scale, engineering-
scale and full-scale tests have been performed to date. Additionally,
several pilot-scale and large-scale tests are planned for the summer and
fall of 1990. The Parsons Chemical Site remediation is scheduled to begin
in January 1991. In all, over 85 ISV tests have been conducted at various
scales. These tests have been conducted on over 30 soil types, with
successful results occurring on all but two. These two exceptions were
found to be deficient in monovalent cations, and were subsequently made
processible by the addition of soda ash.
Some difficulties may exist in obtaining an adequate connection to a power
source and ADC may incur additional one-time costs to provide for this hook-
up. Alternatively, a portable, diesel-powered source of electricity can be
brought to the Site, although this may be more costly than arranging for a
proper hook-up.
As with Alternative 4, emissions testing would be required to determine
compliance with applicable Federal and State air pollution control
requirements. Through pilot-scale testing and accurate data on the chemical
composition of the contaminated sludge and clay, proper design of the
scrubber, carbon beds and fabric filters can be achieved. The time needed
to implement this remedy is about four months from the contractor's notice
to proceed.
-------
34
Alternative 6 involves the chemical oxidation and biological oxidation/
degradation technologies which have been successful in specific applications
of soils contaminated with petroleum hydrocarbons or groundwater
contaminated with various organics. However, the concern with
implementability of this alternative stems from the fact that adequate
bench-scale or pilot-scale studies have not been performed, and too many
uncertainties remain. There are serious concerns about the ability to use
this technology on the stiff clay which is contaminated with MBOCA. It is
anticipated that difficulties would arise in attempting to make a
sludge/clay/water slurry, and that a considerable amount of "down time" may
be experienced due to machinery failure during materials handling operations
(e.g., broken impeller blades or augers).
The types of equipment needed for this alternative are commercially
available and a number of contractors offer services in these areas. As
with Alternatives 4 and 5, the off-gas treatment system would be required to
meet applicable Federal and State air regulations. The total time for
implementation of this alternative is nine months from contractor's notice
to proceed.
Alternative 7 offers very little difficulty in ability to implement.
Excavation and hauling of contaminated materials would be achieved using
cxiiuuun construction equipment, and incineration would take place in an
operating, licensed RCRA incinerator. Although no permits would be needed
or on-site activities, manifests would be needed for off-site hauling of
contaminated materials. The total time for implementation of this
alternative is about two months from contractor's notice to proceed.
7) Oost.
The cost estimates presented for each alternative were developed from the
1989 Mean Cost Data guides and unit prices from similar remediation
projects. Operation and maintenance costs were estimated for a thirty year
period, unless otherwise noted. A discount rate of 10% percent over a
thirty year period was used for present worth calculations of capital and
operating costs. The estimates provide a cost range of -30 to +50 percent
of overall implementation costs.
Of the three alternatives (i.e., 4, 5 and 7) which provide the best balance
of the six criteria above, Alternative 5 is the least expensive.
8) State Acceptance.
The State of Michigan has indicated that it concurs with the chosen remedial
alternative. The State of Michigan supports the selection of ISV, as the
selected remedy achieves Type B clean-up requirements under Act 307, offers
long-term effectiveness and protection to human health and welfare and the
environment, and is cost-effective when compared with alternate Type B
clean-up options considered for this Site. The State of Michigan also
concurs with U.S. EPA's decision to delay issuance of Special Notice Letters
pursuant to Section 122 of SARA in order to allow ADC sufficient time to
-------
35
complete their final stages of treatability tests to determine the
effectiveness and safety of chemical oxidation. Should these tests
demonstrate that chemical oxidation can achieve the clean-up goal
established for this Site, without the formation of toxic oxidation by-
products, the State would accept chemical oxidation for remediation of the
ADC Site. A letter from the Michigan Department of Natural Resources
indicates this support. Attachment B.
9) Cdmunity Acceptance.
The specific comments received and U.S. EPA's responses are outlined in the
Attached Responsiveness Summary. Almost universally, the community response
to the Proposed Plan was negative. Contained within the written comments
received and oral comments recorded at the Public Meeting were several
often-repeated issues. The general perception of ISV is that of an
unproven technology which may present potential hazards to the nearby
community.
In response to concerns from the community, U.S. EPA will not implement
full-scale ISV at the Anderson Site until such time as full-scale ISV data
is available and evaluated. This would allow the citizens of Adrian the
opportunity to witness the utilization of this technology prior to
implementation in their community. The State of Michigan concurs with U.S.
EPA's rationale and course of action in this case.
Since March 1990, Anderson has advocated the use of chemical oxidation for
implementation at the Site. In order to allow Anderson additional time to
fully evaluate chemical oxidation, U.S. EPA will delay issuance of Special
Notice letters under Section 122 of SARA for a period of time sufficient to
allow Anderson the opportunity to present the Agency with a "good faith
offer" within 60 days of the initiation of RD/RA negotiations. U.S. EPA
will delay ig-«aianr» of Special Notice Letters until on or about November 30,
1990. U.S. EPA will evaluate the results of the chemical oxidation pilot-
scale test and treatability study. If Anderson can demonstrate to the
satisfaction of U.S. EPA that MBOCA concentrations can be reduced below
health-based levels in all contaminated media, without the formation of
toxic oxidation by-products, U.S. EPA will consider amending this Record of
Decision if chemical oxidation provides the best balance of the Nine
Evaluation Criteria.
X. TOE SELfgJUU REMEDY
U.S. EPA believes that the proposed remedy, ISV, is the most appropriate
solution for the ADC Site because of its performance against the nine
evaluation criteria previously disraisspd. The major components of
Alternative 5 include the following:
* Removal and proper treatment of all standing water which remain in
the lagoon;
* Excavation of a small volume of surface soils in the vicinity of
the lagoon;
-------
36
Excavation and staging of the lagoon sludge and underlying clay,
to a depth sufficient to meet the clean-up level from a selected
portion of the lagoon, onto a predetermined, larger portion of the
lagoon;
In situ vitrification (ISV) of the resultant staged mass of soil,
sludge and clay to a depth sufficient to meet the clean-up action
level;
Ambient air monitoring and of f -gas control equipment monitoring
during the remedial action; and
Groundwater monitoring and conf irrational soils sampling
following the remedial action for a period of 5 years to assess
and confirm the efficacy of ISV.
XI. jTUAtHJ KSS
1. Protection of Human Health and the Environment
The selected remedy provides adequate protection of human health and
the environment by treating all contaminated lagoon area materials found
to be above the clean-up level via in situ vitrification.
Any short term risks associated with excavation of contaminated
materials (e.g. , dust generation) will be minimized by the use of good
construction practices. Because the remedial action will be performed
in situ, potential to remedial workers and nearby populations would be
minimized. Ambient air monitoring, as well as off -gas treatment system
emissions monitoring, will be conducted to assess possible exposure
during remedial action.
2. Attainment of ARAR's
The selected remedy will attain all Federal and State applicable or
relevant and appropriate requirements as described in Section IX of
this Record of Decision. In addition, the selected remedy will
attain all Federal and State "To Be Considered" requirements as
described in Section IX of this Record of Decision.
3. Oast-Effectiveness
The selected remedy provides cost-effectiveness because a high
degree of permanence is achieved by treatment via in situ vitrification
of all contaminated materials which exceed the health based clean-up
goal. The selected remedy can be implemented at a cost far less than
the complete incineration of all contaminated clay with MBOCA
concentrations above the targeted action level. The cost of ISV has
been shown to be less than or equal to the costs associated with partial
excavation of the lagoon followed by of f -site incineration of the
-------
37
principle threat and placement of the remaining contaminated
into an on-site PCRA landfill. The selected remedy is also less
expensive than the on-site incineration of all contaminated
above the clean-up level. While the ultimate cost of chemical oxidation
will not be known until completion of pending treatability study
cptimization-testST- the-cost-of- this-alternative-nay-exceed-the cost of
the selected remedy, as well. Therefore, of the alternatives presented
in the FS which meet Type B clean-up requirements, the selected remedy
is the most cost-effective.
»
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum Extent
The selected remedy provides the best balance with respect to the nine
evaluation criteria as described in Section IX of this Record of
Decision. Treatment technologies are utilized to the maximum extent
practicable by vitrifying the entire mass of contaminated materials,
thereby leaving a glass-like, impermeable monolithic structure which
serves to encapsulate all inorganic contaminants and any organic
contaminants which may not have been destroyed and removed during the
vitrification process. This alternative will achieve the health based
clean-up standard of 1.6 ppm of MBOCA. This alternative is further
balanced with respect to the nine criteria because a permanent solution
which utilizes an innovative treatment technology is being selected.
The groundwater monitoring component of the selected remedial action
will assure that concentrations of contaminants do not increase after
implementation of the source control remedial action.
5. Preference for Treatment as a Principal Element
The selected remedy eliminates the principal threats at the Site, direct
contact with and/or ingestion of contaminated sludge, soil and clay by
the use of treatment, via in situ vitrification, of the contaminated
media, and is accord with the SARA preference for remedies using
treatment as a principal element.
-------
YTT. pHmJUc-LVEy^^ SUMMARY
This Responsiveness Summary has been prepared to meet the requirements of
Sections 113 (k) (2) (B) (iv) and 117 (b) of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 (CERCXA) , which
requires the United States Environmental Protection Agency (U.S. EPA) to
respond "... to each of the significant comments, criticisms, and new data
submitted in written or oral presentations" on a Proposed Plan for remedial
action. This Responsiveness Summary addresses concerns expressed by the
public, potentially responsible parties (PRP's) and governmental bodies in
the written and oral comments received by U.S. EPA regarding the proposed
remedy for the Anderson Development Company ("ADC" or "Anderson") Site.
A. OVEKVliSW
1. Backnround/Proposed Plan
The Anderson Development Company Site is located in the town of
Adrian, Michigan. The Anderson facility is situated within a 40 acre
industrial park. Anderson Development Company owns approximately
12.5 acres of property within this industrial area, including an
unlined former process wastewater pretreatment lagoon.
The Remedial Investigation concluded that sludge within the lagoon,
clay beneath the lagoon and surface soils adjacent to the lagoon are
contaminated with MBOCA, a chlorinated, semi-volatile, Class B2
carcinogen. MBOCA, along with two of its most prevalent
biodegradation products and a host of organic and inorganic compounds
were detected in the lagoon sludge and underlying clay. MBOCA was
detected at levels nearly 1700 tiroes the clean-up action level
determined in the Endangerment Assessment.
The Feasibility Study evaluated a number of source control options
for site remediation. Among the options considered were
incineration, in situ vitrification (ISV) and chemical/biological
oxidation. The Proposed Plan identified ISV as the U.S. EPA's
preferred alternative.
2. Public Comment Period
The U.S. EPA held a public comment period from July 2, 1990, through
August 8, 1990, for the interested parties to comment on the Proposed
Plan for remediating contaminated surface soils, lagoon sludges and
underlying clay at the Anderson Development Company Superfund Site.
Comments were also taken on any documents in the administrative
record, including the Remedial Investigation/Feasibility Study
(RI/FS) . The Proposed Plan public meeting on July 12, 1990, focused
on the results of the FS and U.S. EPA's preferred remedial
alternative. Oral comments were taken at the public meeting of
July 12, 1990. 18 oral comments were transcribed by a court reporter
at the public meeting. During the public comment period, over 60
written comments were received by U.S. EPA.
-------
Anderson Development Company petitioned U.S. EPA to delay the
signing of the Record of Decision or, in the alternative, to proceed
forth with a "contingency" ROD which would identify chemical
oxidation as the selected remedy, with incineration as the "back-up"
remedy. This request was presented to U.S. EPA in a letter from Mr.
Arvid-Sather of -Michaely-fiest- & -FriedrichT- -legal-counsel-for
Anderson, to Ms. Sandra Otaka, Assistant Regional Counsel, U.S. EPA
Region V. U.S. EPA has decided to go forth with ISV as its selected
remedy. MDNR concurs on this selected alternative. Pilot-scale
studies and treatability tests continue for chemical oxidation, but
at the time of the signing of this ROD, there was no conclusive data
to support the selection of chemical oxidation. Although ADC has
stated in writing and has made verbal assurances to U.S. EPA and MCNR
that it would consent to implementing incineration if chemical
oxidation should fail, recent indications are that ADC would not
agree to one of the incineration options evaluated in the FS, but is
pursuing a low temperature thermal aeration (ETTA) process instead.
The effectiveness and applicability of IUTA to Site contaminants is
being explored by ADC concurrently with chemical oxidation pilot-
scale and treatability testing. Because of the legitimate con
over the technical feasibility of both of these processes, U.S. EPA
determined that it would be in the best interest of the public if ISV
remained the preferred alternative of both Agencies.
The purpose of this Responsiveness Summary is to document the U.S.
EPA's responses to comments received during the public comment
period. These comments were considered prior to selection of the
final remedy for the Anderson Development Company Superfund Site,
which is detailed in the Record of Decision (ROD).
3. Community Involvement
U.S. EPA is responsible for conducting the community relations
program for this Site. A community relations program was established
for the site in 1986. It established a process for a two-way flow of
project information between local officials, concerned citizens, the
media, and U.S. EPA. Two information repositories were established
in the Adrian , Michigan local area: at the Adrian City Hall, and at
the Adrian Public Library. Several different press releases and fact
sheets were issued to inform the community of field activities and
the findings of the RI and FS. Community relations activities are
summarized in the ROD and the Community Relations Plan. All press
releases, fact sheets, and other documents prepared for this Site are
available for review in the site administrative record, if additional
information is desired.
From the comments received during the public comment period and at
the public meeting, there is a very strong community resistance to
U.S. EPA's preferred alternative, ISV. The community perception,
real or otherwise, is that ISV is an unproven technology which may
present potential dangers to the nearby community.
-------
4. Public Meeting
Ihe required public meeting on the Proposed Plan for the Anderson
Development Company Site was held on July 12, 1990, from about 7:00
p.m. to 10:30 p.m., at Adrian College in Adrian, Michigan.
Approximately fifty (50) persons attended, including several local
and state officials or their representatives, representatives of some
companies located in the area surrounding the site, local residents
and concerned citizens, and members of the media.
Representatives of U.S. EPA and the Michigan Department of Natural
Resources (MDNR) presented information concerning the RI, FS and
Proposed Plan, and responded to questions from individuals attending
the meeting. An oral public comment period was held and a transcript
of this portion of the meeting was prepared by a court reporter.
Copies of the transcript are available at Site information
repositories.
B. SUMMARY OF OOMMFVIS RE? "Eiy^'l * AND
Questions and comments received during the public comment period are
paraphrased and organized into 10 discrete subsections within this
summary. These subsections reflect the questions and comments
concerning the Superfund process, and the nine criteria which U.S.
EPA must use when evaluating remedial alternatives at Superfund
sites. Many of the issues raised by the PRP were echoed by members
of the community. Therefore, some of the PRP's comments are grouped
with the community comments. In Section C, separate PRP issues are
addressed. Questions or comments which are of a similar nature have
been grouped into a single comment within one of the sections. The
Agency's responses are given after each comment.
The comments are presented organized as follows:
1. Superfund process;
2. Overall protection of human health and the environment;
3. Compliance with applicable or relevant and appropriate
requirements (ARAR's) of other Federal and State environmental
statutes;
4. Long-term effectiveness and permanence;
5. Reduction of toxicity, mobility, or volume through
treatment;
6. Short-term effectiveness ;
7 . Implementability ;
8. Cost;
9. State acceptance; and
10. Community acceptance.
1. The Superfund I
Comment 1A; Several commentors questioned why U.S. EPA, having at one
"approved" excavation and landfill, now proposes to use ISV to
-------
treat the lagoon area.
foagponse; Anderson Development Company produced the Rl and FS Reports
for the Site as part of the work to be performed under an
Administrative Order by Consent (ADC) between Anderson and the U.S.
EP&y and made effective on July 25, 1986. The-work performed under
Section VII of the ADC is detailed in an attachment to the ADC
entitled the Statement of Work (SOW). Under Task 12-4 of the SOW,
Anderson was required to "recommend the alternative determined to be
the most cost-effective. The recommendation shall be justified by
stating the relative advantages over the other alternatives
considered."
Without direction from the U.S. EPA or MCNR, ADC identified
Alternative B (Excavation and On-site landfill) as its recommended
alternative in the Draft FS Report. At no time did either U.S. EPA
or MENR give approval to ADC's recommended alternative. During a
February 14, 1990 meeting in Chicago between all parties, ADC was
informed again that an on-site landfill would not be acceptable to
either Agency. ADC was informed that an on-site landfill would not
conform with Section 121 of CERCLA and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). Specifically, treatment
to the maximum extent practicable is to be pursued when practicable
treatment technologies are available. As stated in the preamble to
the NCP, "U.S. EPA expects that treatment will be the preferred means
by which to address the principal threats posed by a site, wherever
practicable."
Additionally, ADC was informed that the on-site landfill would not
meet the requirements for either a "Type A" (clean closure to
background or non-detect levels of contamination) or a "Type B"
(clean-up to a 10"6 risk level) clean-up under the then-proposed
Michigan Environmental Response Act (MERA or Act 307). ADC was told
that, upon approval of Act 307 by the Joint Committe on
Administrative Rules (JCAR), this would be considered an applicable
requirement to meet at the Site. In its review of the Final FS and
in U.S. EPA's April 5, 1990 letter which approved the FS, U.S. EPA
again informed Anderson that the on-site landfill alternative was
unacceptable.
Anderson, and the consultants retained by Anderson to conduct the
RI/FS, are entitled to express their comments regarding U.S. EPA's
preferred remedy as members of the public. They are not entitled to
select the remedy for the Site. Anderson and its consultants
supported the landfill alternative in the FS rather than ISV based on
a different interpretation than U.S. EPA of the NCP's evaluation
criteria and cost-effectiveness considerations.
Comment IB; One commentor expressed the concern that U.S. EPA may not
have selected a particular alternative because it only met minimum
requirements and not the Agency's preferred, most desirable, or
state-of-the-art standards. Anderson and one other commentor
-------
expressed the view that the selection of ISV was an arbitrary
decision by U.S. EPA driven by a desire by the Agency to conduct an
ISV experiment at Anderson.
Response; The Decision Summary of the ROD and the accompanying
Administrative Record document in great detail how U.S. EPA equitably
applied the risk assessment and remedy selection process to choose
the Selected Remedy. U.S. EPA believes that the CZRCLA criteria and
goals were applied consistent with the NCP, as required, and
disagrees that the requirements or risks do not support the choice of
ISV. This technology was chosen not out of a "desire," but in
response to a clear statutory mandate from Congress and to ensure
compliance with applicable State of Michigan and Federal regulations.
Other FS alternatives, including on-site landfill and
chemical/biological treatment (unless pilot-scale tests demonstrate
otherwise), do not offer the permanence or effectiveness of treatment
that ISV does. In addition, the State of Michigan has stated that
the On-Site Landfill alternative would not comply with rules
promulgated under Act 307. MDNR has stated, "It is the determination
of the MDNR that the on-site containment alternatives considered for
the ADC site would not be appropriate. Rules 299.5603(1) (b)&(g)
require the MDNR to consider 'the long term uncertainties associated
with the proposed remedial action7 and the 'reliability of the
alternatives."1 Because of the Act 307 Rules, which were made
effective on July 11, 1990, a Type A or B level of clean-up has been
determined to be appropriate. The on-site landfill, by virtue of the
fact that significant concentrations of MBOCA would be left in place,
with the potential to eventually migrate, does not meet the
appropriate clean-up criteria for this Site, and has been determined
to be unacceptable to the MDNR. In addition, the on-site landfill
does not meet the CERCIA mandate for remedies which provide treatment
of contaminants where practicable.
The selected remedy meets ARAR's and satisfies CERCLA' s preference
for the utilization of treatment technologies which offer permanent
solutions in the selection of ISV. The claims that U.S. EPA wants to
"experiment" at the ADC Site are unfounded and untrue. As discussed
below, ISV is a technology which is beyond the experimental stage.
However, in order to address the public's concern regarding the
"experimental" nature of ISV, U.S. EPA has agreed that until such
time that ISV successfully completes rigorous treatability testing,
it will not be utilized at the Site.
Furthermore, U.S EPA has honored ADC's request of March 1990 to delay
the publication of the Proposed Plan for a period of eight weeks to
allow ADC to perform bench-scale chemical oxidation screening
experiments. U.S. EPA has also worked closely with ADC to provide
comments and direction on its chemical oxidation test results and
proposals. U.S. EPA will delay the start of negotiations for
remedial design and remedial action in order to allow ADC time to
complete additional treatability and pilot-scale tests. The amount
of patience exhibited by the Agency, especially in light of the fact
-------
that ADC has had considerable tine to produce quality data, should
indicate that the U.S. EPA has not arbitrarily sought to implement
ISV at this Site, without giving a great deal of consideration to
other alternatives.
One~comrnentor expressed- the-belief - that -UvSv EPA had
already dy-i^^ to ma* ISV
Response: The NCP establishes a regulatory framework for
implementation of CERCXA. The NCP requires that the FS be available
for public comment for not less than thirty days (40 CFR 300. 679 (d)).
The total comment period was thirty-eight (38) days. The required
public meeting on the Proposed Plan was held on July 12, 1990.
All public comments which were received during the comment period
were seriously considered prior to the final decision on the remedial
action. Comments received expressed a diversity of opinion about
what action is needed to clean up the Site, and not all opinions
could be satisfied by any one decision. Although community
annpptanoe is one of nine criteria used to evaluate remedial
alternatives, it must be weighed against the other criteria.
Based on the comments received, the community has expressed
opposition to the ISV component of the Selected Remedy, is concerned
that the implementation of the process must ensure the safety of the
local community, or is concerned with the potential adverse financial
impact of the Selected Remedy on Anderson Development Company.
However, at this time, the Selected Remedy represents the best
balance among the alternatives of the evaluation criteria used to
evaluate remedies. The Selected Remedy emphasizes long-term
effectiveness and permanence, protection of human health and the
environment, and reduction of toxicity, mobility, and volume through
treatment. The Selected Remedy is safe and provides short-term
effectiveness, and is implementable. Also, the Selected Remedy has
the support of the State of Michigan.
Furthermore, U.S. EPA has allowed for Anderson to pursue bench-scale
and pilot-scale experiments with chemical oxidation to determine its
effectiveness and potential applicability to Site conditions. U.S.
EPA, at the request of Anderson Development Company on March 20,
1990, delayed publication of the Proposed Plan for a period of eight
(8) weeks (i.e., from May 2, 1990 to July 2, 1990) to allow ADC to
complete preliminary bench-scale chemical oxidation experiments.
U.S. EPA has been cooperative in Anderson's efforts. Treatability
Study guidance and Quality Assurance Project Plan guidance documents
have been sent to Anderson and its contractor. Additionally, the
U.S. EPA Region V has sought the expert assistance of the technical
staffs at the Robert S. Kerr Environmental Research laboratory
(RSKERL) in Ada, Oklahoma and the Risk Reduction Engineering
Laboratory (RREL) in Cincinnati, Ohio to review ADC chemical
oxidation tests results and proposals. At Anderson's own admission,
-------
this technical assistance has been very helpful in their attempts to
design a viable treatment scheme.
Despite poor initial results, U.S. EPA has continued to work with ADC
as they proceed with modifications to the treatment process
originally presented in the FS. Such cooperation should clearly
indicate that the U.S. EPA has made every effort to evaluate
chemical oxidation fairly, and to allow ADC to present an effective
solution to contamination problems at the lagoon. To date, ADC has
not shown that chemical oxidation will be able to achieve health-
based action levels for MBOCA, without the formation of toxic by-
products from the process itself. Therefore, U.S. EPA cannot
seriously consider implementing this alternative with the information
presently available. Based on the information available, the only
other alternatives which would be acceptable to U.S. EPA would
involve either on-site or off-site incineration of contaminated
surface soil, sludge and clay.
To further show its good faith and reasonableness, U.S. EPA will
delay ispaianne of Special Notice Letters pursuant to Section 122 of
SARA for a limited period of time. This would allow Anderson the
ssary time to further explore the potential efficacy of its
revised chemical oxidation alternative. The intent of delaying the
negotiations moratorium is to allow Anderson time to complete pilot-
scale and treatability tests in such a timeframe that the Company can
present U.S. EPA with a good faith proposal within the first 60 days
of the negotiations period.
Additionally, U.S. EPA will not implement ISV at the ADC Site until
such time as full-scale implementation at the Parsons Chemical Site
in Grand Ledge, Michigan is completed. The Parsons Site is
contaminated with pesticides, mercury, volatile and semi-volatile
organics and dioxins. Remediation efforts are scheduled to begin
shortly, with full-scale ISV targeted to begin in January 1991. The
results of the Parsons full-scale ISV application will be available
to U.S. EPA during the design phase at Anderson. Also, as stated
above, prior to implementing ISV at the Anderson Site, the process
will have to undergo detailed engineering-scale testing and whole
rock analyses of the soils, sludge and clay in the area of
contamination. This testing will be characterized by rigorous
quality assurance/quality control (QA/QQ protocols and
confirmational sampling and analyses. In effect, ISV will undergo
the same level of technical scrutiny which any other alternative
would need to undergo.
2. Overall protection of human health and the environnent
Comment 2A; Several commentors question whether the human health and
environmental risks posed by MBOCA in the lagoon area were high
enough to justify the Proposed Plan. Many commentors noted that
MBOCA migration is minimal and that direct human contact is limited.
-------
8
Response; The primary goals of the Superfund program are to protect
public health and the environment. In the Superfund program, a
reasonable exposure scenario is developed to describe the current and
potential risks posed by the site. This is used to determine whether
a cleanup action must be taken, and to help determine what actions
are needed to~protect~againstsuch~risksv
U.S. EPA determined that exposure to surface soils in the lagoon
area, lagoon sludges, and clay beneath the lagoon sludges present
unacceptable risks to human health and the environment. These are
the media that require clean-up action.
Various exposure scenarios were evaluated in the Endangerment
Assessment. Among these was the "Residential Adult Off-Site Yards"
exposure scenario, in which human exposure to MBOCA may occur via
oral ingestion and/or dermal contact. The calculated MBOCA
concentration in contaminated media which would present an excess
lifetime cancer risk of 1 in 1,000,000 (i.e., 10~6 risk level) based
on the routes of exposure evaluated is 1,684 parts per billion (or
micrograms per kilogram).
The NCP details that the Superfund program shall achieve an adequate
level of protection at Superfund Sites. The NCP defines this
adequate (or "acceptable") lifetime carcinogenic risk range as 1 in
10,000 to 1 in 1,000,000 (i.e., 10~4 to 10~°) excess cancer deaths
due to exposure to contaminants at a Superfund Site. A 10""6 "point
of departure" is generally considered protective in remedy selection.
MBOCA concentrations in the lagoon sludge were found to be as high as
2,800,000 parts per billion (ppb), or approximately 1700 times the
10"6 residential risk level. With this in mind, it becomes obvious
that the risks present at the Site are significant and warrant
remediation of the lagoon.
Once clean-up action is determined to be needed, nine criteria are
used to evaluate and select a remedy. These criteria are listed
above and are desribed in the ROD. The Selected Remedy provides the
best balance among the evaluation criteria for the alternatives
evaluated.
Comment 2B; Several commentors stated that they felt that the
chemical/biological alternative provided at least as much protection
of human health and the environment as would ISV.
Response; The technical feasibility of chemical/biological treatment,
identified as Alternative 11 in the Proposed Plan and as Alternative
D-3 in the FS, is not proven for the media at the Site which present
risks to the public health and the environment (i.e., surface soils,
lagoon sediments and clay). Chemical treatment, using potassium
permanganate (KMnO4), however, has been used at Anderson to treat
process wastewater contaminated with MBOCA. For such a treatment to
work, adequate contact between the reagents (KMnO4) and contaminants
-------
(MBOCA and the other chemicals present) must be achieved and
maintained, and the process must be maintained within a narrow pH
range. In order to treat soils, clays, and lagoon sludge, these
media would need to be mechanically agitated into small particles
which could then be made into a continuously stirred water slurry.
Chemical treatment methods in slurries typically rely strongly on
settling cut suspended particles prior to addition of the chemical
reagents. MBOCA binds strongly to the clay and soil particles
themselves, which rules cut settling prior to KMn04 oxidation.
Therefore, KMnQ4 will need to be added directly to the slurry.
Because the slurry contains materials other than MBOCA that will also
react with KMnO4, large quantities of KMnO4 may be needed. The
oxidation process itself produces a Mn02 precipitate which leads to
the decomposition of the KMnO4 in solution, and may control the
oxidation of certain organic compounds. Because of these concerns
regarding the chemistry of the reactions, chemical oxidation by KMnO4
is not considered by U.S. EPA, at this time, to be protective of
human health and the environment. However, the U.S. EPA is confident
that ISV will offer adequate protection in order to meet the clean-up
goal. Because of the high temperatures attained, in the absence of
oxygen, the MBOCA molecule should readily break down into elemental
components of carbon, nitrogen, chlorine and hydrogen, along with the
formation of hydrogen chloride (which can be removed in the off-gas
treatment system).
The U.S. EPA's concerns regarding chemical/biological oxidation as a
method of remediating the ADC Site have been made known to ADC for
sane time now. On August 15, 1989, ADC was notified by U.S. EPA,
regarding chemical oxidation, that "Extensive treatability studies
would be necessary to determine the reaction (s) taking place, the
extent of completion of the reactions, the products of these
reactions, and the possible toxicity of the reaction products."
This concern was also brought up by ADC, in fact, when the chemical
oxidation and biodegradation alternative was screened out in the
initial FS submittal (October 1989 Draft FS Report). As stated on
page 3-16 of that report, "Oxidation of MBOCA by chemical oxidation
may be a viable and effective solution, but the contaminated sludge
also contains unknown chlorinated compounds (up to 200 rog/kg) and 4-
chloro-6-Methoxy-2-Pyrimi d ine (up to 80 mg/kg) which would not be
readily oxidized. Hazardous chlorinated products would be formed by
oxidation of 4-chloro-6-Methoxy-2-Pyrimidine." The report continued,
"This alternative therefore, is not implementable at the ADC Site."
RSKERL expressed similar concerns in its review of the chemical
oxidatian/bicdegradation alternative. RSKERL questioned the ability
of chemical oxidation to selectively oxidize MBOCA while "bypassing
the myriad of inorganic and organic coirpounds (with lower
oxidation/reduction potential) present in the slurry." RSKERL also
went on to state that the oxidation of MBOCA will not only result in
-------
10
the formation of carbon dioxide and water, but in the formation of
hydrogen chloride as well.
RREL also pointed out that "chemical oxidation will not be selective
in regards to MBOCA." PREL recommended that a bench test involving
IWnO4~^appTicatibnrto^ MEOOi7witnaJit~the ihter^era^Jes of other
contaminants, be an integral part of the pre-screening study. Ihis
would give opt, imam oxidation efficiency of KMn04, and thus would
indicate the Trayimm potential level of MBOCA reduction that can be
anticipated.
These experiments should then be followed by further tests of
contaminated soils, sludge and clay as separate media, to
determine if the effectiveness of chemical oxidation varies with
mpdia of concern. Extensive quantitative and quantitative
analyses would be needed to identify the reaction products given off.
Such tests would indicate if MBOCA is being chemically broken down,
and not just molecularly altered, and what, if any, toxic compounds
are formed. Also, toxicity tests would need to be conducted to
determine if the process generates chemicals which would pose greater
risks to human health and the environment than MBOCA itself.
The U.S. EPA's Environmental Criteria and Assessment Office (ECAO) in
Cincinnati has also provided Pegion V with a technical review
regarding historical data on MBOCA degradation by KMn04. ECAO's
findings are included in the Admininstrative Record for this Site.
ECAO reviewed three publications (i.e., Barek et al.f 1986;
Castegnaro et al., 1985; International Agency for Research on Cancer
(IARC), 1985) which described MBOCA destruction via KMnO4 in sulfuric
acid solutions. ECAO concluded that, "... none of the three
publications... provides conclusive evidence for complete destruction
(over 99%) of MBOCA by permanganate/sulfuric acid treatment. The
claimed non-mutagenicity of the treatment products has not been
unequivocally proven. Finally, the oxidation products of the
treatment process have not been identified and some of these products
may have other toxic end points."
Until such time as Anderson answers all of these questions, the
effectiveness and safety of chemical oxidation will be in doubt.
U.S. EPA, however, will offer Anderson the opportunity to perform
additional studies to demonstrate that chemical oxidation is capable
of reducing the present concentrations to the target cleanup level of
1684 ug/kg (roughly 1.6 parts per million, or ppn) MBOCA. These
studies will also evaluate what operating conditions must be
maintained for the treatment to work, and to evaluate whether those
conditions are achievable.
3. Compliance with applicable or relevant and appropriate
requirements (ARAR's) of other Federal and State environmental
statutes
-------
11
Comment 3A; One commentor suggested that since RCRA does not specify
a treatment technology for MBOCA, any method may be used including
excavation and landfill or chemical/biological treatment.
Response; Under the Superfund program, U.S. EPA is charged by
Congress with selecting the remedy for clean-up of Superfund sites.
The selection of a clean-up remedy includes the selection of a
treatment method. Remedy selection for Superfund sites does not need
to be driven by RCRA requirements. The remedy selected for the ADC
Site was based upon consideration of health-based clean-up goals
determined by CERCLA guidance and Act 307 clean-up assumptions and
calculations. Numerous alternatives were evaluated for the Anderson
Site, including excavation and landfill, as well as
chemical/biological treatment. The Selected Remedy complies with
ARAR's and provides the best overall balance among the evaluation
criteria. While it is true that there is not a RCRA treatment method
for MBOCA, within the Third Thirds Treatment Standards, a
concentration-based standard of 35 mg/kg exists for MBOCA. The
Selected Remedy will meet this standard by more than one order of
magnitude in terms of degree of clean-up. Because of the nature of
the wastes present at the ADC Site and the method by which the MBOCA
was placed into the lagoon, the determination was made that RCRA
would not be applicable to the remedial action selected for the Site.
The clean-up action level instead was based upon exposure scenarios
and land use scenarios considered in the Erdangerment Assessment
(EA), which is part of the Administrative Record for the Site, and
the Rules for the Michigan Environmental Response Act. The
excavation/on-site landfill option described in the FS would not meet
clean-up criteria in the Act 307 Rules, would not offer reduction in
contaminant toxicity, mobility or volume and would not utilize
permanent solutions to address Site contamination.
Comment 3B; One commentor questioned whether a MDNR air permit could
be granted for ISV since no tests have been performed on the Anderson
lagoon which would identify by-products or off-gases resulting from
the process.
pggpnnggi in implementing the remedial action, U.S. EPA is required
to meet the substantive standards of State ARAR's, but is not
required to obtain a permit for activities conducted on-site. Prior
to the initiation of full-scale operation of ISV treatment at
Anderson, a treatability study will be conducted to generate data
concerning the specific by-products or off-gases which may result
from ISV treatment of the lagoon area. This data will be submitted
to MDNR as part of the review process during the design phase of the
clean-up. Based on treatability study data from other ISV
demonstrations and a review of the contaminants present in the
lagoon area, U.S. EPA at this time does not anticipate difficulty in
meeting the State of Michigan air permitting standards. In
addition, the ISV system is well equipped with air pollution
controls, which will be designed to meet all applicable Federal and
State requirements. It should be noted that the issue of air
-------
12
releases and necessary permits must be considered for all
alternatives, and treatability tests must be conducted to generate
necessary information.
Comment 3C: One commentor stated that, in the FS Report, the on-site
landfill was-fourd-to-have-Go^l-ied-wi1^-State-cmd-Federal ---------- ------
regulations, yet, in the Proposed Plan, the U.S. EPA asserted that
this alternative did not comply with all State and Federal
regulations. The coiuuentor felt that the landfill alternative does
ccnply with such regulations but may not meet U.S. EPA's preferences.
Response; U.S. EPA's letter which approved the Feasibility Study
(FS) , dated April 5, 1990, clearly indicated that several concerns
still remained, but that those concerns did not warrant the submittal
of another revision of the F5 report. The letter then clearly
indicates the specific concerns, among which is "the On-Site landfill
alternative is clearly unacceptable. This alternative does not
conform with the goals and intent of Section 121 of SARA nor the
National Contingency Plan. The U.S. EPA will select its preferred
alternative in a document entitled the Proposed Plan. U.S. EPA will
then present the Proposed Plan along with the FS for public viewing
and comment." That letter is part of the Administrative Record for
the Site, which was available for public review during the public
comment period. Again, it should be noted that the FS Report was
written by Anderson's consultant. The U.S. EPA was not involved in
writing the document, but did comment as appropriate. Further, the
on-site landfill, does not meet the more stringent requirements of a
Type B clean-up, which the State believes to be appropriate for this
Site.
Comment 4A; Several people questioned why U.S. EPA selected a
Proposed Plan which was unproven and experimental. Several
commentors were concerned that U.S. EPA could not guarantee that ISV
could successfully treat the lagoon area.
Response; The Selected Remedy represents the best balance among the
alternatives of the evaluation criteria used to evaluate remedies.
The Selected Remedy is protective of human health and the
environment, attains Federal and State requirements that are legally
applicable or relevant and appropriate for this remedial action, is
cost-effective and consistent with achieving a permanent remedy.
The Selected Remedy satisfies Oongressionally mandated preferer
for remedies that employ treatment that reduce toxicity, mobility or
volume as a principal element, and that utilize permanent solutions
and alternative treatment (or resource recovery) technologies to the
maximum extent practicable for this site.
ISV has been tested approximately ninety (90) times on a wide variety
of waste types at various scales. At least seven large scale tests
-------
13
have been performed. Also, it is anticipated that the process will
have been performed commercially at three or more Superfund sites
before remedial operations at the Anderson Site are initiated.
According to the criteria used by U.S. EPA to identify remedial
technologies for Superfund sites, ISV is not an "experimental"
technology. The experimental stage of the process has been completed
and ISV is now considered an "innovative" technology available for
use at Superfund sites. Further, while the vendor may continue
experimentation in an effort to improve the technology and its
economics, these experiments will not be performed during remedial
operations at Anderson. Only tested and approved procedures will be
authorized by U.S. EPA for use at Anderson.
Congress has directed U.S. EPA to meet certain statutory mandates for
remedy selection at Superfund sites. These mandates include the
preferences for treatment as a principal element of the remedy, and
the utilization of permanent solutions and alternative treatment
technologies to the maximum extent practicable. ISV is an
alternative treatment technology which provides for a permanent
solution. While ISV is an emerging technology, it has undergone
extensive review by U.S. EPA, and data has been submitted which
demonstrates its potential to successfully treat contaminants present
at Anderson. However, prior to full-scale implementation of ISV, a
treatability study and demonstration test will be completed on actual
contaminated media from the Anderson Site. This test will determine
the effectiveness of ISV in treating MBOCA and other Site
contaminants, as well as determining the parameters that provide for
day-to-day operation which meets the stringent performance and safety
standards of U.S. EPA and the State of Michigan.
Regarding the use of innovative technologies, the preamble to the NCP
states, "... U.S. EPA supports such diversification and expects that
it will generally be appropriate to investigate remedial alternatives
that use innovative technologies when such technology offers the
potential for comparable or superior treatment performance or
implementability, fewer or lesser adverse impacts than other
available approaches, or lower costs for similar levels of
performance than demonstrated technologies."
In addition, U.S. EPA Administrator William Reilly's "Management
Review of the Superfund Process" identified the development and use
of innovative technologies as one of eight major elements in the new
strategy for the Superfund Program. Among Administrator Reilly's
objectives are to remove the regulatory and policy barriers to using
new technologies and to provide technical support and assistance to
the Regions during remedy selection. The impetus for developing new
technologies is to broaden the array of safe and effective treatment
technologies for implementation at Superfund sites.
While U.S. EPA will not guarantee the performance of ISV, the PRP's
in developing performance and operations standards to be met by the
-------
14
vendor, may, through contract negotiations with the vendor,
incorporate guarantees of treatment into their remediation contract
documents. Geosafe (ISV vendor) has developed treatability study
protocols which allow for a high probability of success for scale-up
if initial tests were favorable. Therefore, if an engineering-scale
test were"run with success, it~is expected"that a large-scale test
would be at least as successful, and subsequently, full-scale
implementation should also be net with increased performance.
Furthermore, it is Geosafe's policy to guarantee process performance
for full-scale operations in the remediation contract. Geosafe will
guarantee that the required destruction and removal efficiencies
(CRE's) and leach characteristics will be met and that the specified
volume of waste will be vitrified.
Comma iL 4B; Anderson commented that because of the damage ISV would
cause to the lagoon area, verification of its effectiveness would be
difficult.
Response; The ISV treatment process will leave a massive glass-like
block in place at the treatment zone in the lagoon area. While this
block is more durable than granite or marble, readily available
technology exists to collect samples from it. Like these rock
formations, the ISV glass-like block can be sampled by standard
drilling equipment to collect a core sample. The sample can then be
analyzed for chemical content. By comparing analytical results from
after ISV treatment to those prior to treatment, the effectiveness of
ISV treatment can be readily verified.
Additionally, during the treatment process, the vitrified mass is
continuously monitored using several techniques to ensure pre-set
performance standards are attained. Off-gases are continuously
monitored using U.S. EPA sampling procedures. Groundwater sampling
and confirmational soil sampling adjacent to the melt are also
indicators of ISV performance. These performance standards and
required monitoring will be set during the design phase.
5. Reduction of toxicity, mobility, or volume through •treatment
Comment 5A; Many comrnentors supported the chemical/biological
treatment alternative because they felt that this procedure is well
established, proven and less expensive than the U.S. EPA Proposed
Plan. Anderson commented that this alternative had been successfully
used in the past at Anderson, that it is a method capable of having
its effectiveness verified, and that recent studies have shown it to
be effective in eliminating more than 99 percent of the
contamination.
Response; Oxidation/reduction reactions between oxidizing agents and
organic materials are commonplace. However, treatment of
contaminated soils with oxidizing agents for the purpose of oxidizing
a unique chemical contaminant has not been demonstrated.
Furthermore, U.S. EPA is not aware of any previous application of
-------
15
such technology. Resistance to the use of oxidants applied directly
to contaminated soils or sludges is due to the potential for creating
reaction by-products which could be toxic, thereby producing a
situation which could be just as hazardous or more hazardous than the
existing situation. Also, because the chemical make-up of soils and
sludges vary considerably, the application of oxidants to these
matrices must be thoroughly evaluated on a case-by-case basis.
The chemical/biological treatment alternative has not been
ssfully demonstrated for the media of concern at the Anderson
Site. Chemical oxidation by KMnO4, as proposed by Anderson, has only
been used at the Anderson Site for the treatment of wastewaters, but
not for soils and lagoon sludges. In order to successfully address
Site risks, the remedy must achieve the desired concentrations and
reductions for the media of concern. The highest MBOCA
concentrations and the required reduction to achieve the target level
of 1.6 ppm for the lagoon sludge, clay and surface soils near the
lagoon are: 2800 ppm and 99.94% reduction; 660 ppm and 99.74%
reduction; and 98 ppm and 98.28% reduction, respectively. Although
Anderson reports to have effected MBOCA reductions in bench-scale
experiments from roughly 1200 ppm to 10 ppm (i.e., 99.16% reduction),
it remains to be seen if this can be accomplished at scale-up. It
should further be noted that bench-scale experiments were performed
on water slurries, with an initial concentration significantly less
than the 2800 ppm maximum concentration detected at the Site, and
that the end concentration was significantly greater than the target
clean-up concentration of 1.6 ppm. As stated above, the fact that
the MBOCA molecule adheres so readily to organic materials such as
clay particles, raises very serious material handling concerns and
the ability to promote adequate contact between oxidant and
contaminant. For these reasons, statements that chemical oxidation
is a proven technology are premature, at a minimum.
It should be further noted that ADC first attempted to utilize a
chemical oxidation process which incorporates H202 as the preferred
oxidant, along with ultra-violet (UV) light. Due to the poor
performance of H2C>2 (the highest level of MBOCA reduction seen was
34% by weight, despite the fact that molar ratios of H2O2 to MBOCA of
2:1 were used) and the fact that the resultant slurries were
extremely opaque and not amenable to UV photcdegradation, ADC had to
reconsider its approach. Further experiments were run using a rretal
catalyst to hasten the chemical reaction between MBOCA and H2®2> tut
these results were also unfavorable. Subsequent bench-scale
experiments were run using KMn04 as the oxidizing agent. While the
results were more favorable than the previous H2O2 experiments, a
number of questions remained. Anderson eventually revised its entire
treatment scheme such that the proposed chemical oxidation process
presented to U.S. EPA on July 31, 1990 at a meeting in Cincinnati,
Ohio was considerably different in scope than the chemical
oxidation/biodegradation alternative presented in the Final FS
Report. The scattered, unregimented approach by ADC and its
consultant should be viewed as an indicator that the chemical
-------
16
oxidation alternative is not as easy to design and implement as ADC
would have one believe. If chemical oxidation were a proven
technology for the matrices and types of contaminants at the Anderson
Site, many of the concerns raised by the U.S. EPA would have been
readily answered at this tine.
Yet, U.S. EPA concurs that this method is capable of having its
effectiveness verified. However, this method has not yet been shown
to be capable of achieving the needed reductions for each of the
above media. Therefore, U.S. EPA does not believe that this
treatment method has yet demonstrated itself to be well proven and
established for the contaminants and media at the Anderson Site.
Comment SB; Several commentors state that since MBOCA is
biodegradable, it therefore would break down to safe levels if placed
in a landfill or if left undisturbed.
Response; U.S. EPA concurs that MBOCA is biodegradable, since its
biodegradability is well documented in scientific literature.
Scientific literature regarding MBOCA's biodegradability is included
in the Administrative Record for the Site. However, that literature
also indicates that four biodegradation products, two of which are
monoacetyl MBOCA and diacetyl MBOCA (referred to in the RI,
Endangerment Assessment, and FS Reports as AC and DAC, respectively),
are considered more toxic than MBOCA itself. Thus, biodegradation
may not result in a reduction of toxicity of contaminants, but
rather an increase in toxicity. With biodegradation, toxicity may be
increased, and protection of human health and the environment could
be decreased. For these reasons, U.S. EPA does not consider
biodegradation to be an acceptable alternative.
6. Short-term effectiveness
Comment 6A; Several commentors expressed concern with the safe
operation of the ISV treatment process during remediation, especially
the use of ISV in an urban setting. Among the safety issues
identified were potential emissions of hazardous gases, "stray"
electric currents, damage to underground utilities (e.g. gas
pipelines, sewers and water lines) and surrounding homes and
businesses, fires and explosions, and risks to site remediation
workers. One commentor expressed concerns with how closely the
clean-up would be monitored to ensure public safety and
effectiveness. Another commentor expressed concern that during
remediation, rain could wash contaminants off-site.
Response; Temperatures of 100 degrees C (212 degrees F) have been
measured as far as five to seven feet from the full-scale ISV
treatment zone. The ISV melt, as a rule of thumb, should thus not be
located closer than 15 feet to underground utility lines and
structures which could be damaged by temperatures above 100 degrees
C. Examination of Site diagrams provided in the RI Report does not
indicate any above ground structures within 15 feet of the ISV
-------
17
treatment zone. Location of underground utilities are not noted,
but there are not indications of structures which would likely have
underground utilities running to them within 15 feet of the ISV
treatment zone. The closest pipeline on the Site is on the north
side of the pre-treatment lagoon, more than 150 feet away from the
proposed processing area. Exact locations of underground utilities
(e.g. , gas pipelines, sewers and water lines) will need to be
during the design phase.
No surrounding homes or businesses are located within the likely
digt-anoo which might be affected by soil settling that will result
from ISV treatment. This matter will need to be further examined
during the design phase.
Induced voltages of 10 volts have been measured 10 feet from active
ISV process zones. No voltages have ever been detected further than
this distance. Since soil has extremely low conductivity as compared
to molten soils within the ISV process zone, "stray currents" are not
created. In fact, conductive materials such as graphite and glass
frit are placed on the ground surface between the electrodes to serve
as a "starter path" for the electric current during the vitrification
process.
ISV treatment uses a hood to collect gases released by the treatment
process. The hood extends well beyond the ISV melt area, and is
operated under negative pressure to assure capture of gases generated
during ISV treatment. Gases will undergo treatment, such as acid gas
scrubbing, particulate removal in high efficiency filters and
adsorption onto activated carbon, to assure that health and safety of
nearby populations are protected, and that State air emission
requirements are met. A treatability study on actual wastes from
Anderson during the design phase of the clean-up will determine what
gases will be generated during treatment, which will allow for design
of the off-gas treatment system. The off-gas treatment system will
have a self-powered backup treatment system, so that proper treatment
is assured even during power failure.
Computer models will determine the thermodynamics of the ISV process.
Data such as the types and concentrations of contaminants, and their
;tive enthalpies of combustion will be input in order to
determine maximum heat loads that can be expected during the melt
process. This allows for any necessary safeguards to be implemented
should high instantaneous heat releases be likely.
The potential for explosions at the ADC Site is non-existant. If
ISV were attainted in an area where full, intact drums containing
high-BIU liquid (e.g., solvents such as toluene and MEK) were present
within two (2) feet of the surface, high volume releases of organic
vapors could occur. For an explosion to occur, oxygen must be
present in quantities to allow for an explosive mixture to be present
within the range of flammability for a particular combustible
material. The amount of oxygen in the vadose zone (i.e., unsaturated
-------
18
zone) is negligible. Because of the absence of oxygen, the ISV
process is inherently different than incineration, which requires
oxygen, in greater than stoichiometric amounts, to allow for proper
combustion. Upon reaching the ground surface, combustible gases such
as solvent vapors would combust immediately upon coming in contact
with~ambient~air;Tb~prevent~the~possibility~of "explosion^ in
instances where intact drums close to the surface exist, clean soil
can be placed over the contaminated area. This would allow for a
slower release of organic vapors, thereby providing for greater
destruction, via pyrolysis, of the organics as they rise in the melt.
Because there are not high BTU pockets at the ADC Site, this is a
moot point. Any combustible gases which rise through the melt zone
or adjacent "dry zone" would ignite near the ground surface, and
would not have the opportunity to accumulate to the point where
combustibles and oxygen are present in the explosive range.
The potential for fire due to the ISV process is also non-existent.
An incident did occur during a 1989 experiment conducted by the
Department of Energy (DOE) at the Idaho National Engineering
laboratory (INEL). At the time, DOE was experimenting with a number
of low weight hood designs to allow for easier movement during ISV
processing. The hood tested during this particular trial run was of
a fabric material coated with an organic-based substance. A spark
beneath the hood resulted in auto-ignition of this coating. The
sytem was immediately shut down, with no further complications or
releases to atmosphere. Geosafe has developed a glass hood capable
of withstanding temperatures of 400 degrees C (about 750 degrees F).
To ensure that the skin temperature of the hood does not encounter
temperatures in excess of 400 degrees C, Geosafe performs
computerized thermodynamic analyses of the heat generated during the
ISV process.
Risks to site remediation workers due to ISV treatment are lesser
than under all other alternatives considered, other than the No
Action alternative, due to the in-place nature of the alternative.
Other clean-up alternatives involve excavation of all the wastes,
thereby presenting potentials for exposure to remediation workers,
the public and the environment. Under the Selected Remedy, only a
portion of the contaminated soils, sludges, and clays will be
excavated. These will be consolidated into the lagoon area. During
this action, controls such as berms will be used to prevent the
potential runoff of contaminants from the Site during rain. Other
controls, such as a tarp, can be placed over the excavated material
to limit its exposure to rain. This matter will need to be further
examined during the design phase.
The ISV process is constantly monitored and controlled by a
distributed microprocessing system. This system monitors hood
temperature and pressure, plenum temperature and pressure, pressure
drops in the off-gas treatment system, OD^, GO, 0^, pH of scrub
solution, off-gas flow rate and differential pressures across the
various filters, among other process parameters. If the process
-------
19
control system fails, the system is equipped with proper
instrumentation and gauges to ensure appropriate processing is
taking place.
U.S. EPA will oversee the clean-up to ensure the protection of public
safety and the environment, and the effectiveness of the remedy.
U.S. EPA will oversee treatability studies needed to implement the
Selected Remedy, and will review the treatability study and design
documents. U.S. EPA will also provide on-site monitoring of the
Selected Remedy during its implementation, including testing to
demonstrate effectiveness of the Selected Remedy as implemented.
7. Tnpl CTTCT-rf-aH-i 1 i i-y
No comments were received during the public comment period on any of
the alternatives regarding this evaluation criteria.'
8. Cost
Comment 8A; Many commentors supported alternatives such as on-site
excavation and landfill or chemical/biological treatment as more cost
effective than the U.S. EPA Proposed Plan. At one extreme, one
commenter felt that the clean-up plan should be accomplished at the
least possible cost pursuant to a plan agreed upon by the business or
entities responsible for the clean-up.
Response; Cost is only one of the nine criteria used to evaluate
remedial alternatives, and must be weighed against the other
criteria. While the on-site landfill alternative and the
chemical/biological treatment alternative are less expensive than the
ISV alternative, neither provides a comparable level of 1) protection
of public health and the environment, 2) reduction in the toxicity,
mobility or volume through treatment, or 3) long-term effectiveness
and permanence, as would be attained through ISV treatment. The
Selected Remedy provides the best balance among the evaluation
criteria of the alternatives evaluated.
In addition, when comparing alternatives, cost-effectiveness is only
to be considered among those alternatives which offer protection to
human health and the environment and which comply with Federal and
State ARAR's. Currently, the effectiveness and protection of the
chemical oxidation alternative is unknown. In view of this, a
determination of cost-effectiveness when compared to technologies
which are protective cannot be made.
Furthermore, assuming that chemical oxidation was determined to be
protective and compliant with all ARAR's, there remains a question on
whether it will, in fact, be cost-effective when coirpared to ISV.
Preliminary cost analyses of the chemical oxidation alternative were
performed by RREL. These results indicated that the capital cost of
this remedial action would exceed three (3) million dollars, with a
large portion of the costs going toward the purchase of very large
-------
20
amounts of TQfoD^. This would place chemical oxidation in the
general cost range as ISV (which was posted out in the FS at
approximately $2.4 million). Granted, additional pilot testing and
performance test, ing of chemical oxidation would be needed before cost
estimates can be made with a high degree of accuracy, but the RREL
calculationsdo~point~cut that^tiie a3st~of ~chemic^^
in all likelihood, far exceed that costs determined by ADC (i.e.,
$1.1 million to $1.3 million).
The on-site landfill alternative represents the least expensive
alternative (other than the No Action alternative), not the most
cost-effective.
U.S. EPA and MDNR evaluated those alternatives which offered
protection and compliance with ARAR's. The alternatives which met
these criteria were on-site incineration, off-site incineration and
ISV. Of these, ISV was the least expensive alternative. Because
these alternatives offered protection and achieved ARAR's, the
Agencies could evaluate them against one another. It was determined
that ISV was clearly the cost-effective alternative. ISV even
offered greater reductions in contaminant toxicity, mobility and
volume than did Alternative 9 in the Proposed Plan (excavation and
off-site incineration of lagoon sludge and contaminated clay to a
depth of only two (2) feet, followed by the placement of a multi-
media cap over the remaining contaminated clay) at lower costs (i.e.,
$2.4 million vs. $3.8 million).
Comment 8B; Several commentors questioned whether U.S. EPA took into
consideration the potential adverse economic impact that the Proposed
Plan could have on Anderson Development Company and the community.
One commenter urged U.S. EPA to adopt a clean-up plan that results in
a healthy environment and a financially healthy company.
Response; Congress has directed U.S. EPA to work with private parties
that may have been responsible for contamination at Superfund sites.
Congress has established provisions in CERdA and SARA that allow
private parties to do work at Superfund sites (Section 106 and 122 of
CERdA) while U.S. EPA retains the oversight responsibility to ensure
that the work is done correctly (including any and all work U.S. EPA
determines to be necessary). Under CERdA Sections 120 (e) (6), 106
and 122, U.S. EPA has the authority to allow or require Anderson
Development Company or other potentially responsible parties to
perform or pay for remedial action activities at the Anderson
Superfund Site.
Further, Congress has mandated that the cost of a remedial action be
one of the nine criteria used by U.S. EPA to evaluate remedial
alternatives. The costs of each remedial alternative considered were
carefully evaluated. However, Congress also mandates that protection
of public health and the environment and selection of permanent
solutions be attained. While U.S. EPA appreciates the concerns
regarding the potential economic impact of the selected remedy on
-------
21
Andersen, it is not permitted by law to select a less costly remedy
which does not comply with Congressional mandates. At this time, the
Selected Remedy provides the best balance among the evaluation
criteria.
Conment 8C; Several ccranentors questioned why Anderson would be
required to bear the expense of an alternative clean-up method if ISV
does not successfully clean-up the lagoon area. One commentor
suggested that U.S. EPA pay for the ISV treatment since it is an
experimental remedial technology. Others supported U.S. EPA paying
for an alternative clean-up method that may be required if ISV is
CERdA and SARA provide a means for U.S. EPA to clean-up
hazardous waste sites where one or more potentially responsible
parties have not been identified or where potentially responsible
parties (PRP's) have been identified but refuse to pay for
remediation of a site. The trust fund established by Congress allows
U.S. EPA to fund site clean-up in the absence of funding by
potentially responsible parties. However, to conserve trust fund
monies, Congress mandates that U.S. EPA allow or require potentially
responsible parties to perform or pay for remedial action activities
at Superfund sites. At this site, Anderson has been identified as a
potentially responsible party. Anderson must pay for the remedial
action voluntarily, or U.S. EPA may undertake the remedial action
and seek to recover the costs from Anderson through legal means. If
cost recovery is required, Congress has authorized U.S. EPA to
recover the cost of all remedial activities not inconsistent with the
NCP. If U.S. EPA issues a CERCIA Section 106 Order to ADC, and ADC
fails to comply with this Order, ADC will be liable for punitive
damages which together can equal three times the cost of the remedial
action. Anderson bears the responsibility of addressing the
contamination problems at the Anderson Site, including the
implementation of the Selected Remedy, and the implementation of any
additional remedy required for the Site.
Comment 8D; Several commentors, including Anderson, expressed
concern that since only one vendor existed for ISV, the cost estimate
presented by U.S. EPA may be too low and that if selected it will be
difficult to control the cost of implementing ISV.
Response: The reliability of cost estimates applies to all
alternatives evaluated in the FS, and presented by U.S. EPA in the
Proposed Plan. All costs estimates were prepared by Anderson and its
consultant. As treatability studies are completed, many of the
present uncertainties will be resolved, allowing more accurate
estimates of cost. With appropriate contract documents and contract
management by the PRPs, such as those implemented in typical
construction contracts and familiar to Anderson, the PRPs will be
able to adequately control the cost of implementing the remedy. For
example, the contract may specify a mixture of firm fixed price for
certain elements, such as costs to mobilize the equipment to the
-------
22
site, and unit prices for other elements, which would provide a fixed
cost per unit used. The unit pricing approach would likely be used
for electrical energy, for example. While only one vendor does
exist, it should be noted that this vendor is marketing a new
technology^ for application in the Superfund arena. For the
technology to establish itself in the marketplace, the vendor must
ensure that ISV is cost-effective when compared to established
technologies such as on-site incineration.
9.
No comments were received during the public comment period on any of
the alternatives regarding this evaluation criteria. However, it
should be noted that the State of Michigan, through the Department of
Natural Resources, was directly involved in oversight of RI/FS
activities and concurred on the Proposed Plan and Selected Remedy.
10. Community acceptance
CuimmuL 10; Several commentors stated that the entire community was
opposed to ISV and supported either the excavation and landfill
alternative, or the chemical/biological treatment alternative.
Response; Community acceptance is one of nine criteria used to
evaluate remedial alternatives, and must be weighed against all other
criteria. At this time, the Selected Remedy represents the best
balance among the alternatives of the evaluation criteria used to
evaluate remedies.
Community acceptance of the chemical oxidation alternative may be
influenced by the apparent belief that this alternative is a proven
technology. While chemical treatment of wastewaters is proven, the
application of chemical reagents to isolate a specific chemical and
oxidize it safely to carbon dioxide and water in various media, such
as the case at Anderson, needs to be demonstrated. For reasons
stated in this Responsiveness Summary and also contained in the
Administrative Record, there are very legitimate concerns as to the
safety and effectiveness of chemical oxidation. Ihe community has
also raised concerns over the ultimate cost of ISV, while accepting
ADC's FS cost estimate for chemical oxidation, when the ultimate cost
of chemical oxidation could conceivably increase markedly over the
ADC cost estimate.
Based on the comments received, the community has expressed
opposition to the Selected Remedy, is concerned that the
implementation of the process must ensure the safety of the local
community, or is concerned with the potential adverse financial
impact of the Selected Remedy on Anderson Development Company.
However, the comments expressed a diversity of opinion about what
action is needed to clean-up the Site, and not all opinions could be
satisfied by any one decision. Additionally, it is anticipated that
this Responsiveness Summary will serve to allay public concerns about
-------
23
ISV and addrftss misconceptions regarding the Agency's renedy
selection process.
U.S. EPA will encourage ADC representatives and members of the
conmunity to witness full-scale ISV processing at the Parsons
Chemical Site which is expected in early 1991. In addition, U.S.
EPA will encourage the community to seek a Technical Assistance Grant
(TAG) and will provide additional information to the community on how
to apply for such a grant. Information regarding the U.S. EPA's TAG
Program is presently available in the Site information repositories.
C. SUMMARY OF COMMENTS RECEIVED FROM PRP's AND RESPONSES
The following is a summary of comments received from the attorneys
representing Anderson Development Company (ADC), in a letter dated
July 18, 1990 addrpssprt to Michael A. Valentino, U.S. EPA Remedial
Project Manager, and signed by Charles V. Sweeney, of Michael, Best &
Friedrich. That letter is part of the Administrative Record for the
Site. The comments are presented as organized in the letter. U.S.
EPA has subdivided the comments based upon separate issues.
Responses directly follow the individual comments.
1. ADC's position regarding allowing natural bicdegrada'ticT* and
capping of the lagoons
Comment 1A; "Since ADC, EPA and MDNR all desire to remediate the
surface lagoons using proven technologies due to the residential
areas near this site, Alternative B: Excavation, On-Site RCRA-Type
Landfilling is the most cost effective alternative. MBOCA is
biodegrading through natural bacterial degradation at the site. The
National Contingency Plan (NCP) does recognize containment will be
used in certain situations. Where the chemical MBOCA is naturally
degrading, containment is really a treatment alternative. We
disagree with EPA's understanding regarding Michigan ARAR's requiring
active treatment."
Response; As stated above in the responses to public comments in
Section B, on-site landfilling is an inappropriate option for this
Site according to the criteria of the administrative rules for
Michigan Act 307. Furthermore, this option does not provide for the
best balance of the Nine Criteria set forth in the NCP.
Specifically, because of the inherent unreliability of landfills,
this alternative does not offer adequate long-term effectiveness and
protection. Neither does this alternative offer reduction of the
toxicity, mobility or volume of the waste, nor does it meet SARA'S
and Act 307's preference for selecting remedies which use treatment
technologies to the maximum extent practicable. Furthermore, also as
stated above in the responses to Comment 5B contained in Section B,
biodegradation of MBOCA results in chemicals which in fact pose
greater risks to human health and the environment than does MBOCA.
The discussion of the on-site landfilling alternative in the FS does
not aHrfrnaag biodegradation as part of the alternative, nor does it
-------
24
address the more serious concern of biodegradation products being
more toxic than MBOCA. Containment would represent a Type C clean-
up, as previously noted. In evaluating the various alternatives for
the Site, MENR has determined that a Type B clean-up is an
appropriate remedy as it offers a more permanent_andcost-?effective-
solution than containment. lastly, it is unknown how long it would
take for MBOCA and its biodegradation products to break down into
innocuous chemicals. Considering the fact that MBOCA levels in the
lagoon sludge have been detected as high as 2,800,000 ppb more than
10 years after MBOCA production ceased, quick extrapolations would
indicate that it may take a number of decades before health-based
MBOCA levels are achieved.
Comment IB; "...experiments with remediation technologies...have
cost ADC a considerable amount of money.. .ADC desires to start
remediating the site through containment and monitoring or chemical
treatment rather than spend money on continued testing."
Response; Since neither the FS nor the Proposed Plan present a
"containment and monitoring" alternative, and the PRP's letter does
not further elaborate on the matter, U.S. EPA assumes that this
comment refers to the On-Site Landfilling alternative. As stated
above in the responses to public comments contained in Section B, and
as above in the response to PRP Comment 1A, On-Site landfilling does
not provide adequate long-term protection of human health and the
environment, nor does it comply with statutory preference under SARA
for treatment of the principal threat to the TMXJTM" extent
practicable. This alternative does not meet the expectations of the
Act 307 nor the Superfund program as stated in the preamble to the
NCP which include the utilization of permanent treatment
methodologies which maintain long-term protection to human health and
the environment over time, and which minimize the amount of untreated
waste.
U.S. EPA also assumes that the "chemical treatment" referenced in
this comment refers to the Chemical/Biological Treatment alternative,
presented as Alternative D-3 in the FS and as Alternative 11 in the
Proposed Plan. As stated above in the responses to public comments
contained in Section B, U.S. EPA has offered ADC and its consultants
ample time and oppurtunity to demonstrate the effectiveness of
chemical treatment technologies it has proposed in reducing the
contaminant concentrations at the Site to target clean-up levels for
the site media. Despite these opportunities, ADC and its consultants
have yet to satisfactorily propose a treatability study which
addresses all concerns raised by U.S. EPA to ADC. In attempts to be
fully receptive to ADC, U.S. EPA has undertaken considerable efforts
to provide thorough technical review of ADC's proposals for chemical
oxidation, first for hydrogen peroxide (H202) as the oxidant and then
for potassium permanganate (KMn04) as the oxidant, each time
providing timely comment on proposals.
-------
25
In responding to these comments, ADC and its consultants have changed
technical direction, but have yet to fully address U.S. EPA's
comments, specifically the underlying concerns that the treatability
study methodology proposed by ADC provide methodology to
toxicity of end products and by-products of the reactions for the
contaminants present at the Site. Adequate treatability testing is
needed to address unknowns before implementation of a remedy for the
Site.
2. Comments regarding ISV and concerns similar to those raised by
HtP's at the Pristine, Inc. Superfund site
Comment 2A; "ADC does not agree with your [U.S. EPA's] responses to
environmental and safety concerns about ISV. ..A chief issue is
whether or not ISV is an alternative treatment and an innovative
technology ... its use for chemical contamination raises new
questions."
Response; According to the criteria used by U.S. EPA to identify
remedial technologies for Superfund sites, ISV is not an
"experimental" technology. The experimental stage of the process has
been completed and ISV is now considered an "innovative" technology
available for use at Superfund sites. Further, while the vendor may
continue experimentation in an effort to improve the technology and
its economics, these experiments will not be performed during
remedial operations at Anderson. Only tested and approved procedures
will be authorized by U.S. EPA for use at Anderson.
Congress has directed U.S. EPA to meet certain statutory mandates for
remedy selection at Superfund sites. These mandates include the
preferences for treatment as a principal element of the remedy, and
the utilization of permanent solutions and alternative treatment
technologies to the maximum extent practicable. ISV is an
alternative treatment technology which provides for a permanent
solution. While ISV is an emerging technology, it has undergone
extensive review by U.S. EPA, and data has been submitted which
demonstrates its potential to successfully treat contaminants present
at Anderson. ISV has been tested for soils contaminated with mixed
organic and inorganic wastes, including molecularly complex chemicals
such as poly-chlorinated biphenols (PCB's) , pentachlorophenol (PCP) ,
dioxins, organo-chlorine pesticides (dieldrin and aldrin) and
creosotes. Ihe ISV process has been succesfully tested in over 30
different soil types. Section 121 (b) (2) of SARA states in part, "Ihe
President may select an alternative remedial action meeting the
objectives of this subsection whether or not such action has been
achieved in practice at any other facility or site that has similar
characteristics . "
However, prior to full-scale implementation of ISV, a treatability
study and demonstration test will be completed on actual
contaminated media from the Anderson Site. This test will determine
-------
26
the effectiveness of ISV in treating MBOCA and other Site
contaminants, as well as determining the parameters that provide for
day-to-day operation which meets the stringent performance and safety
standards of U.S. EPA and the State of Michigan.
Regarding the use of innovative technologies/ the preamble to the NCP
states, "... EPA supports such diversification and expects that it
will generally be appropriate to investigate remedial alternatives
that use innovative technologies when such technology offers the
potential for comparable or superior treatment performance or
inplementability, fewer or lesser adverse iitpacts than other
available approaches, or lower costs for similar levels of
performance than demonstrated technologies."
Comment 2B; "...the public comments from the public hearing in
Adrian, Michigan were in opposition to ISV. The Editorial [in The
Daily Telegram, date not specified on the copy submitted with this
comment] agrees with ADC that chemical/biological treatment along
with natural biodegradation should be the selected alternative. . .the
cost impact of the clean up (sic) decision [on Anderson Development
Company] must be considered."
Response; The portion of this comment relating to public comments
echoes Comment 1QA in Section B on community acceptance. See that
comment, and the response to that comment, contained in the responses
to public comments in Section B above. The portion of this comment
relating to cost echoes Comment 8B in Section B on cost. See that
comment, and the response to that comment, contained in the responses
to public comments in Section B above.
Comment 2C; "According to ISV's developer, Battelle Pacific
Northwest Laboratories, experience with low boiling point organics
that are uncontained in the soil column is very limited, and
feasibility testing with actual site samples prior to application is
strongly recommended. . .At ADC, like Pristine, the contaminant [MBOCA]
is highly volatile at relatively low temperatures. By the time the
soil is melted, the MBOCA is either destroyed or moved out of the
treatment area.
"ADC is very concerned about lateral migration of contaminants into
adjacent soil or perhaps downward into groundwater. Larry
Penberthy, a competitor of ISV, believes and provides a good
technical argument that: 'Instead of being destroyed, the
vaporizable chemical contaminants simply move away from the hot core
melt by Vapor Retreat, unaltered. They move downwardly below the
melt core as well as horizontally away from the melt core. This
vaporizing/condensing action is progressive, building up
ntration in the isotherm layers corresponding to each
chemical's boiling point. Shis vapor retreat phenomenon could lead
to increased contamination of groundwater. Moreover, in order to
test for this effect it would be necessary to test a rather large
volume of soil so that temperatures away from the molten zone are low
-------
27
enough to have condensation of vaporized contaminants. However, most
testing is done on too snail a volume of contained material to see
this effect.' "
Response; Former misconceptions such as organic vapor retreat have
been shown not to exist, and enough empirical data exists to support
the selection of this technology for a wide range of contamination.
Organic vapors, generated as each organic compound undergoes
volatilization at its respective boiling point, would tend to either
migrate vertically through the dry zone (i.e., zone in which water
has undergone a phase change to the vapor state, resulting in greater
organic vapor permeability) toward the ground surface, or via
chemical diffusion according to Pick's law along a concentration
gradient in the direction of decreasing contaminant concentration
(i.e., toward the melt). Pick's law states that the mass of
diffusing substannps passing through a given cross-section per unit
time is proportional to the concentration gradient. The mechanism of
diffusion ceases at the point at which concentration gradients become
non-existent. Additionally, it is known that vapors will distribute,
via diffusion, within the available void volume which exists at a
temperature between the vapor point isotherm (this isotherm is
located between the 100 degrees C isotherm and melt boundary for most
organic compounds) and the melt temperature. Since vaporization
occurs at the coolest boundary of this volume, and the concentration
of vapors is initially highest at that point, the concentration-based
diffusion moves toward the melt, along the concentration gradient,
as expected under Pick's Law.
Some fraction of organic molecules will migrate away from the melt
via thermal diffusion in an attempt to establish chemical equilibrium
to offset the effects of Fickian diffusion. However, vapors cannot
move to cooler areas beyond their respective vapor point isotherms
without recondensing. In effect, the ambient (or "cool") soil zone
acts as a hindrance to vapor retreat due to thermal diffusion. Upon
recondensation, concentration gradients exist in which chemical
diffusion again becomes the predominant mechanism. As a result,
chemical migration towards the melt resumes and pyrolysis continues
to break down molecular bonds with concomitant reductions in
contaminant concentrations. Therefore, vapor retreat and contaminant
enrichment does not occur at locations cooler than the vapor point
isotherm.
For gases to move laterally away from the melt and beyond the dry
zone, they would have to behave in a manner inconsistent with known
diffusion mechanisms. Further, it is known that gases migrate along
the path of least resistance to their flow. Observations of ISV
melts have shown that vapors have not migrated into adjacent soils.
For vapors to do this, they would have to overcome higher flow
resistance encountered outside of the dry zone where the interstitial
volume of the soil is partially or fully filled with water. Movement
of vapors within the dry zone is constrained by the limited void
volume present within soil. This volume, however, is maximized in
-------
28
the dry zone, where, in addition to the absence of liquid water,
channeling and some fluidization between soil particles may
contribute to this effect.
Studies by Dragun (1988) have^hown that liquids present in soil will
move from locations "of thicker to thinner films, toward regions of
lower film tension. This mechanism, known as capillary action, is
enhanced during the ISV process by the resultant thermal effects on
soil porosity, and viscosity effects on the liquid undergoing
capillary action. Capillary water and chemicals present in capillary
water move toward the melt as they are drawn into the dry zone.
Contaminants present continue to move toward the melt until they
reach their respective vapor point isotherms, at which time
volatilization occurs and they become part of the vapor phase.
Because the rate of advancement of the melt is from one to two orders
of magnitude greater than the rate of capillary water movement, the
ISV process itself overtakes the capillary forces present in soils,
and in effect, contaminants are pyrolized even faster than they can
be drawn towards the melt, resulting in greater concentration-based
gradients.
Water vapor is the predominant vapor present within the treatment
zone during vitrification. Water is usually present in soil in the
15% to 30% by weight range, whereas contaminants are usually present
in the part per billion to 1% by weight range. During ISV
processing, water vapor acts as a carrier gas as water miscible
organics are incorporated into the water vapor (steam) and carried
along in the treatment zone. Water balance measurements and findings
from radio frequency in situ soil decontamination studies using
tracers have revealed that water vapor and contaminants rise toward
the ground surface. This process is called "carrier gas transport."
Carrier gas transport is similar to a well known phenomenon in the
field of air pollution control where improper design of counterflow
packed absorption towers has resulted in liquid entrainment and
elevated pollutant levels at the point of clean gas discharge.
Another effect which leads to greater contaminant destruction and
which should contribute to the diffusion of MBOCA toward the melt is
the effect the ISV process has on adsorption of organics onto soil
particles. Experiments conducted in soils at temperatures between
150 degrees C (about 270 degrees F) to 300 degrees C (about 540
degrees F) indicate that the efficiency of organic adsorption
decreases. This phenomenon is also seen in the air and water
pollution control fields wherein gas phase and liquid phase activated
carbon adsorption beds are regenerated via reverse flow of saturated
steam. The thermal effects of the steam overcome the molecular
forces attracting the organics to the carbon. Consequently, in
soils, as the melt advances, temperature increases and contaminant
adsorption decreases, allowing for chemical diffusion and carrier gas
transport to govern chemical movement.
-------
29
Further contributing to the destruction of contaminants in the melt
zone is the fact that the viscosity of the melt is approximately 100
poise (as compared to the viscosity of water which is about 0.01
poise) . The viscosity of water is therefore 10,000 tiroes less than
the viscosity of the melt. This results in a slow tine rate of
travel of organic vapors (i.e. , in the form of gas bubbles) to rise
upward through the melt. These gas bubbles would, in fact, rise and
not descend due to bouyancy effects and density differentials . The
long "residence" times result in greater and greater thermal
destruction of contaminants, much the same as increasing the
residence timeg in incinerators (while at constant temperature and
percent oxygen) will result in greater destruction of organic
contaminants. Experiments involving mass balances on various
volatile and semi-volatile organics have shown destruction
efficiencies in the soil of greater than 99.9% by weight. Add to
this the removal efficiency of dual-staged activated carbon beds, and
the overall destruction and removal efficiency of the ISV process can
appoach 99.9999% by weight (i.e., "six nines") for organics.
Additionally, the depth of processing at the Anderson Site will
probably be five to eight feet (5 to 8 ft) into the clay, depending
on the results of additional soil sampling during the desing phase.
Because the water table is approximately 30 feet below the ground
surface, the bottom of the melt would be at least 10 to 15 feet above
the water table. This "barrier" of clay should offer adequate
protection to the groundwater should trace amounts of MBOCA migrate
downward. However, there is a preponderance of empirical data to
dispel Mr. Penberthy's claim of downward migration.
During remedial design, locations for confirmational soil borings
will be considered. These locations will be selected based on
information regarding the vapor point isotherm for MBOCA. Borings
will be taken from adjacent "clean" soils at that point at which
MBOCA will go f ran the vapor state back to its normal state at
ambient temperatures (i.e., solid).
Furthermore, by providing for a "factor of safety" during design, the
aerial extent of ISV processing can be increased to include sub-
surface soils adjacent to the melt perimeter. This would allay any
ns that lateral migration and vapor condensation outside of the
co
treatment zone did occur by treating those clean soils around the
melt, thereby destroying any organics which, according to Mr.
Penberthy, may migrate. Again, due to the preponderance of empirical
evidence and theoretical support, the U.S. EPA is not concerned with
the potential for lateral migration as Mr. Penberthy insists.
Comment 2D; "Penberthy also raised several important safety
questions [about ISV related to the Pristine site] , such as effects
from soil heating and subsidence, and about using ISV at a heavily
industrialized area. . .Near the ADC site low-income residential homes
exist, as well as industry. ..Furthermore, Geosafe's [a subsidiary of
Battellle] own publications (copy submitted with this comment
-------
30
document) admit that ISV is not economically feasible unless the
depth of contamination is greater than 5 to 7 feet. Additionally,
the soil must be dry for ISV to work properly, according to Geosafe."
Response; The^ 5 to 7 foot depth cited _jji the^bgye ^comment is
considered by Geosafe to be the economic minimum for ISV
implementation fully in place. This depth of overburden melts
first, and the molten material helps contain the vapors emanating
from contaminated soils beneath during the remainder of the melt
process. If a 5 to 7 foot overburden is not present, clean soil
could be placed using conventional earthmoving equipment to
establish the overburden. Since the remedy as conceptualized
already calls for use of conventional earthmoving equipment to
excavate some contaminated soils and consolidate those soils into a
portion of the surface lagoon, no additional equipment mobilization
costs are expected in order to achieve the placement of a clean
overburden prior to initiation of the melt. Furthermore, sufficient
borrow volume of clean soil should exist at the Site in order to
achieve this depth of coverage for the 4500 cubic yards expected to
be processed by ISV.
It should also be noted that eight possible soil/waste arrangements
are presented in the Geosafe document provided with this comment
document, among which are: 1) in-situ; 2) modified in-situ, involving
some rearrangement of materials or filling with materials as
described above; and 3) process-container repetitive settings,
involving performance of repetitive settings within process
containers. The selection of the waste arrangement would be based
upon consideration of: 1) the physical state of the material (e.g.,
solid, liquid, slurry, sludge); 2) the location of the material
(e.g., in soil, in an impoundment or lagoon, under or near
structures, in the water table); 3) expected response of the material
to ISV processing (e.g., volume reduction, angle of repose, expected
susidence depth and area, expected gas/vapor volumes); and 4) the
physical capabilities of the ISV processing equipment (e.g., maximum
width and depth of settings). These matters would be evaluated
during treatability testing for ISV, which, as ADC recognizes, would
need to be performed prior to implementation of ISV.
Contrary to the assertion by the FRP's, the soil need not be dry for
ISV to work properly. The amount of water present in the soil,
determined by the soil volume to be ISV-processed multiplied by the
soil moisture content, has a large impact°&£ the energy costs of
implementing ISV. It takes approximately as much electrical energy
to evaporate one pound of water as it does to melt one pound of soil.
Therefore, the lower the moisture content of the matrix, the lower
the electrical energy costs will be. Electrical energy costs account
for the majority of ISV treatment costs. Again, the soil moisture
content would be one of the parameters which would need to be
-------
31
The ISV process should be performed sufficiently distant from
engineered structures to prevent unintended damage to them by the
processing. The two primary concerns are thermal effects, and
effects due to soils densification and related subsidence. While
during processing a 100 degree C isotherm exists 6 to 12 inches from
the 1600 degree C or higher melt surface, this isotherm will move out
into the soil during cooling after the melt is ceased. The 100
degree C isotherm has not been measured any further than 5 to 7 feet
frm any full-scale ISV process. The cooling of ISV settings at
specific sites will vary. Evaluation of the thermal cooling gradient
would need to be evaluated during the design phase, based upon
information gathered during treatability testing for ISV. A rule of
thumb for estimating purposes is that the ISV melt should not be
located closer than 15 feet to underground utility lines and
structures that could be damaged by temperatures above 100 degrees C.
This matter will need to be examined fuller in the design phase.
Similarly, the design phase will need to consider expected soil
subsidence relative to aboveground structures (e.g., undermining of
soil under a floor slab or foundation).
The balance of this eminent as it relates to neighborhood setting and
safety of ISV in an industrial area is discussed in the response to
Comment 6A in Section B above.
Comment 2E; "By its very nature, ISV leaves treated contaminated
material on-site. Due to ISV's unproven status, monitoring of the
vitrified mass will be required to assure it is a reliable and
permanent remedy."
Response; U.S. EPA concurs that the ISV process will leave a
residue of treated material on-site. The NCP requires that any
remedy which leaves material above health-based levels on-site
undergo a five year evaluation to verify effectiveness of the remedy.
Because MBOCA will not remain above health-based levels, a five year
review is not necessary. It should be noted that the two remedies
which seem to be favored by ADC, On-Site landfilling, and
Chemical/Biological Oxidation, leave material on-site, and thus
would require a five year evaluation of remedy effectiveness. U.S.
EPA requires that the effectiveness of any treatment remedy be
verified by testing. The testing may consist of treatability
testing, or pilot-testing, and will always consist of testing during
implementation to verify effectiveness in achieving both design
criteria as well as target clean-up levels. As discussed in the
response to Comment 6A in Section B above, U.S. EPA will provide on-
site monitoring of the Selected Remedy during its implementation,
including testing to demonstrate effectiveness of the Selected Remedy
as implemented. As discussed in the response to Comment 4B in
Section B above, verification testing of the ISV
process, in relation to the glass-like block-left by the process, can
be achieved using readily available techniques.
-------
32
Comment 2F: "Batelle agrees that application of ISV technology
involves five basic types of risks that must be considered,
including: (1) unplanned releases of hazardous material to the air,
soil or groundwater environments, (2) environmental exposure quality
of the residual monolith7- (3) assurance that-processing has been
completed as planned, (4) generation and disposition of secondary
wastes, and (5) ocurrence of any other unforeseen events or effects.
ADC is NOT willing to accept these risks."
Response: These five basic types of risks identified by Battelle are
contained in a letter from Battelle to members of the PRP group for
the Pristine, Inc. site. That letter was included as an exhibit to
the PRP comment document. Examination of that letter indicates that
Battelle has identified these risks from the perspective of contract
negotiations, and whether to bid on implementation of a remedy. That
letter outlines Battelles risk management policy in evaluating
whether to bid on contracts, and states: "The company's risk
management policy would relate to these risk types by first including
a review of all applications to assess the type and magnitude of
risks and possible consequences. The review would identify how such
risk exposure could occur and possible mechanisms to prevent or
control such exposure. Information from this review would be
considered relative to the company's risk management policies and
standards to determine whether or not to bid a particular
opportunity. If a positive bid decision were to be made, the
analysis would also identify operational, contractual and
administrative protective mechanisms that should be employed as part
of the project." The letter goes on to indicate that possible
protective mechanisms are numerous, and that those would be subject
to a contract between Battelle as the remediation contractor and the
PRP group as the client. Further, the letter enumerates five
contract provisions which Batelle, as remediation contractor, would
require in a contract. They are summarized as follows:
1. "The company (Battelle) would require performance of a
treatabilitv test prior to issuance of a formal quotation."
2. "The company (Battelle) would require client indemnification
regarding injury or loss that may result from processing the
client's waste.. .Such indemnification would not be expected to cover
gross negligence or wilfull misconduct on the part of the company
(Battelle)."
3. "The company (Battelle) would require limitation of warranties
associated with the performance of the residual glass product."
4. "The company (Batelle) could be expected to warrant that it
would process a given volume at the site, and that the processing
would result in the melting of the soil matrix. Such a warranty
would be limited by the discovery of site conditions that could make
the processing unsafe or technically infeasible; such a situation
-------
33
could develop if the client's site characterization efforts were
inadequate."
5. "The company (Battelle) would not take title to or
responsibility for secoryfoTY wast"/->g that may be generated during the
processing.. .secondary wastes left at the end of the project would be
the responsibility of the client."
The letter further states "I'm sure that when you, as the potentially
responsible party (FRP), look at the kinds of conditions stated
above, you recognize that they are designed to protect the
remediation conpany from uncertainties associated with providing a
service to the client. Of course the client also needs as much
certainty as possible relative to the remediation. Therefore, the
company (Battelle) should be willing to employ procedures and
reporting mechanisms that give the client as much security as
possible against unforeseen events. For example, regarding residual
product quality, there is no way that the company (Battelle) can
guarantee the product quality because of unknowns associated with
actual composition of the soil/waste mixture.. .The company (Battelle)
should be willing to employ sampling and testing procedures during
and after the processing so that residual quality can be estimated in
a timely manner. Such testing would not guarantee the residual
quality, but it would provide a means for detecting the a problem in
this area if it were to arise. Then the question for the client
would be what action to take for resolution of the problem. In the
case of the residual product quality, there are operational
alternatives that could be utilized to improve the quality. Such
extra effort could be provided for in the project contract. Please
be assured that the company (Battelle) would be willing to work with
the PRP group.. .to provide as much mutual risk management security as
possible."
Excerpts from this letter are presented at length in this response
in order to indicate several points. First, that these are typical
concerns that will be raised by any remediation contractor,
regardless of the remedial technology that is to be implemented.
Second, that these concerns are legal matters that will be
addressable via contract negotiations between ADC and its selected
remediation contractor. Third, that this letter from Battelle, the
parent company to Geosafe, indicates that Battelle/Geosafe is willing
to negotiate a contract with a potential client that will mutually
address Battelle/Geosafe and client risk management security
regarding these concerns.
nt 2G: "...based upon the environmental conditions (the type of
contamination, the physical condition and location [surface] of the
waste material, high water table and close proximity to residential
and industrial sites) at ADC, Dr. Kim Anderson of The Earth
Technology Corporation would not recommend ISV. As you know, Earth
Technology is presently utilizing ISV at the Ionia Landfill site for
-------
34
treatment of buried drums in a dry, confined trench far from
industrial development. "
Response; U.S. EPA's response to the issue of whether ISV is the
-prqper-remedia] -alternative-^ or- -the-Site ~is-contained~ in the -----------
responses to public comments in Section B.
3. Inform EPA of cur (ADC's) contacts with Dragun Corporation,
Larry Penberthy, Canonie Environmental, The Earth Technology
Corporation, (Hi Corporation and EDI Engineering & Science to assist
Johnson & Malhotra (ADC's present consultant) on developing a
oDax3ation mmmiiai alternative
Comment 3: "... your [July 11, 1990] letter challenged ADC to
implement treatment of the soil utilizing KMnO4. ADC has contacted
other consultants to assist Johnson & Malhotra [ADC's consultant]
with this challenging proposal. Specifically, we (ADC) have narrowed
our selection to Canonie Environmental, EWI Engineering (sic), The
Earth Technology Corporation, OHM Corporation and The Dragun
Corporation as consultants. . .You made numerous contacts regarding the
oxidation issues. Your [July 11, 1990] letter acted as a catalyst
for ADC to contact additional consultants to present an innovative
and safe oxidation process to the negotiation table. Furthermore,
since natural degradation of MBOCA continues, these delays provide
additional reason to utilize capping, thereby allowing continued
natural degradation of MBOCA."
Response: It should be noted that U. S. EPA identified serious
concerns regarding chemical/biological oxidation to ADC as early as
August 15, 1989, as discussed in the response to Comment 2B in
Section B, via a letter which stated "Extensive treatability studies
would be necessary to determine the reaction (s) taking place, the
extent of completion of the reactions, the products of these
reactions, and the possible toxicity of the reaction products."
ADC has had over one year to present its case regarding chemical
oxidation. It is unfortunate that the PRP's consider that the July
11, 1990 letter was the "catalyst" to initiate serious endeavors to
finally attempt to address the concerns first raised by U.S. EPA
eleven months earlier.
Attempts to pursue chemical/biological oxidation bench-scale studies
were not initiated until April 1990, after ADC was informed that the
U.S. EPA was considering ISV as its preferred alternative in the
Proposed Plan. The Administrative Record will also show that ADC did
not include the chemical oxidation alternative in its Revised FS
which was received by U.S. EPA on December 19, 1989.
As indicated in correspondence to ADC contained in the
Administrative Record, U.S. EPA delayed publication of the Proposed
Plan in order to allow ADC to submit pre-screening data. In fact,
U.S. EPA postponed commencement of the public comment period in order
-------
35
to allow ADC to conduct preliminary bench-scale treatability
experiments on chemical oxidation. U.S. EPA acted in good faith in
allowing additional time for ADC to submit data supporting chemical
oxidation. Data provided by ADC was of questionable quality, did not
demonstrate desired contaminant concentrations, and did not address
concerns raised in August 1989. These concerns are Hjgraiggg^ in the
response to Comment 2B in Section B.
Had ADC presented information which would have justified selection of
chemical/biological oxidation, strong consideration would have been
given by U.S. EPA to the Chemical/Biological Oxidation alternative.
U.S. EPA's concerns regarding "natural degradation" are presented in
the responses to Comment 5B in Section B and to Comment 1A in
Section C above.
Since the PPP's comment does not elaborate on "capping," the U.S EPA
assumes this refers to utilization of the Excavation/On-Site
land fill alternative as the PRP's preferred remedial alternative to
be implemented. As stated above in the responses to Comments 1A, 3A,
and 3C in Section B and to Comment 1A in Section C above, the
Excavation/On-Site Landfill alternative does not meet the State's
criteria for a Type B clean-up, nor does it meet the NCP and SARA
preferences for treatment of the principal threat to the maximum
extent practicable.
4. Correct migmrterBhanri'iTi^B and inaccurate or incomplete
information included in your July 11, 1990 letter to ADC
Comment 4A; "...ADC will set the record straight as to
misunderstanding (sic) and/or incomplete and/or inaccurate
information. ADC generally agrees with EPA's position that
probably is not effective. Initially, ADC and EPA agreed to
undertake preliminary treatability studies on H^O^ and other
potential precipitants. EPA was to review preliminary data to allow
ADC to focus additional investigation. EPA, due to its extensive
workload, was not timely in its review.
"These experiments, undertaken by... Clayton Laboratories [on behalf
of ADC] , were submitted to EPA with the understanding that they were
to be preliminary in nature and [to be] used to determine if further
work should be done. It is unfortunate that Clayton Laboratories did
not deliver the quality of product in a timely manner as both EPA and
ADC had thought. ADC acknowledges time was wasted waiting for the
work product from Clayton. Clayton did not deliver the material and
data requested by ADC. Clayton's work product was not acceptable and
apparently not up to the caliber EPA has obtained on other projects.
ADC is working with consultants to salvage the data and provide EPA
the necessary data to substantiate chemical oxidation as the [ADC's]
selected alternative. It is time to go forward rather than look
back. We look forward to our meeting to discuss additional studies
of potassium permanganate to satisfy EPA and MDNR requirements."
-------
36
U.S. EPA's response to this comment is discussed at
length in the response to Conmment 2B in Section B, and to a lesser
degree in the responses to Comment IB and Comment 3 in Section C
above.
Comment 4B; "In your [July 11, 1990] letter, EPA states that
Anderson's Feasibility study (sic) reported that by-products
involved in chemical oxidation should eliminate chemical oxidation
from consideration. This paragraph was jointly drafted by ADC and
EPA with the understanding that containment would be the selected
remediation. EPA told ADC this would be a convenient way to xclose
out' this alternative for the official record. Counsel for ADC was
not present at this meeting since it appeared ADC and EPA had agreed
upon containment as the selected remediation.
"Your [July 11, 1990] letter discussed chemical oxidation of other
substances. It is obvious chemical oxidation is not selective for
MBOCA. ADC and EPA, based upon analysis in the record, do not expect
sufficient other organics in the sludge to cause significant
problems."
Response; Contrary to the PRP's assertion that the decision to
"eliminate chemical oxidation from consideration" was made by both
U.S. EPA and ADC, at no time did U.S. EPA say that the above
language "would be a convenient way to * close out' this alternative
for the official record."
The Draft FS was prepared by consultants to ADC. The decision to
eliminate chemical oxidation from the Feasibility Study instead of
pursuing costly treatability studies to confirm its efficacy and
applicability was made by ADC, not the U.S. EPA.
Additionally, at no point did U.S. EPA agree that containment would
be acceptable at the Site.
With regard to the issue of other organics in the sludge, it is
noted that ADC and its consultant screened out this technology in
the draft version of the Feasibilty Study (Draft FS) received by
U.S. EPA on October 3, 1989, because of "the presence of unknown
chlorinated hydrocarbons... which would not be readily oxidized by
the oxidants considered."
Comment 4C; "ADC and Dr. Malhotra have previously attempted to meet
with you and technical members of EPA and MDNR to discuss a good
working plan for chemical oxidation with KMnO4... We are hopeful our
forthcoming meeting can provide direction towards a working plan for
chemical oxidation."
Response; With reference to the statement that ADC and Dr. Malhotra
had attempted to meet with MDNR, members of U.S. EPA's Risk Reduction
and Engineering laboratory (RREL) and others, it was the U.S. EPA's
-------
37
decision not to meet at that time because of the fact that the
treatability study work plan and preliminary bench-scale experiments
were of such poor quality that U.S. EPA did not expect a productive
meeting. In fact, it was ADC's consultant who suggested that RREL
suggest modifications to the work plan. It did not seem appropriate
for the U.S. EPA to be responsible for designing the treatability
studies of PRP's or their contractors. However, on July 31, 1990,
U.S. EPA (Region V and RREL) and MDNR representatives did meet in
Cincinnati, Ohio with ADC representatives, ADC consultants and legal
counsel for ADC. U.S. EPA exercised considerable resources in
providing ADC with timely and detailed review of its chemical
oxidation/biological degradation and subsequent chemical oxidation
proposals. Only after ADC and its consultants had reviewed U.S. EPA
comments (March 22, 1990 by RSKERL; June 26, 1990 and July 16, 1990
by RREL) and understood the complexity of the concerns regarding
implementation of chemical oxidation did it appear that a fruitful
technical exchange could be undertaken.
Comment 4D: "ADC included ISV as a last minute suggestion upon
^suggestion' by EPA to present a more complete FS. The analysis on
ISV, by necessity, was done hastily and with the understanding that
it was more of an academic exercise than a practical solution. ISV
is not the proper technology for this site.
"You cited several sites where ISV is being considered a selected
alternative. These sites are not located near residential areas.
While your attempt to addresss concerns about Astray voltage' is
noteworthy, it will not address the xfears' of the people of Adrian.
In fact, numerous studies continue at the University of Wisconsin on
the effects of electromagnetic fields from power lines in the air.
This much voltage in the soil could have unknown effects on people
and our environment."
Response; ISV was presented in the Draft FS, and despite efforts by
ADC to screen out this technology, U.S. EPA informed ADC at a
November 1989 meeting and in a November 22, 1989 letter that ISV
should be retained for further analysis because the technology is
amenable to the contaminants found at the Site and to the
hydrogeology at the Site. ADC and its consultant had ample
oppurtunity and time to prepare a professional assessment of ISV.
U.S. EPA's response to safety issues are discussed in the response to
Comment 6 in Section B. U.S. EPA's response to the issue of whether
ISV is the proper technology for the Site is also contained in the
responses to public comments in Section B.
As noted below, the ADC Site is not the only site located near
residences for which full-scale ISV is being considered.
The Rocky Mountain Arsenal (M-l Holding Ponds) Site in Commerce City,
Colorado is located in close proximity to a residential area and the
site is adjacent to the northern boundary of the Denver Stapleton
-------
38
Airport. Among the contaminants present are arsenic, mercury,
cadmium and various pesticides. While not identified as a target
contaminant within the treatment area, the Health and Safety Plan for
this site addresses the possible presence of Army agents (e.g.,
mustard gas). In November 1990, it is anticipated that 90% of the
remedial design will be completed for this site. Full-scale
implementation of ISV should occur in June 1991 or shortly
thereafter.
The Shattuck Chemical Site, which is an operable unit for one of the
Denver Radium Sites, is located in the downtown area of the city of
Denver, Colorado. Ine contaminants of concern are radium-226 (the
parent^ isotope to radon gas), natural uranium, thorium-230, lead-210,
and selenium. An on-site engineering-scale treatability study has
been completed and U.S. EPA is in the process of evaluating the
results of this study.
The Northwest Transformer Superfund Site in Everson, Washington is
contaminated with PCB's. The site is situated within several
hundred feet of residences. Data from a recently completed
treatability study are undergoing a validation and review process.
If these results are favorable, full-scale implementation would begin
in the near future.
The comparison to the health effects of high voltage transmission
lines is inaccurate. Granted, strong electromagnetic fields
associated with high voltage power lines have been measured in the
air within close proximity to such lines and the potential health
impacts are being studied, but the electromagnetic field in the
ground during ISV processing is very weak, and as noted in the
response to Comment 6A in Section B, tests show that the induced
voltage produces only a 10 volt potential at short distances (i.e.,
about 10 feet).
Comment 4E; "Mr. Huerta [of ADC] believes that not only is ISV *not
the most cost effective alternative,' but also ISV is an unproven
technology for consideration at this site. While EPA may utilize its
own position on cost-effectiveness, ADC must remediate this problem
utilizing a safe, cost-effective solution or simply close shop."
Response; U.S. EPA's response to the "cost effective" issue is
contained in the response to Comment 8A in Section B. U.S. EPA's
response regarding cost impacts on ADC and potential economic
impacts on the community are discussed in the response to Comment 8B
in Section B. At the aforementioned July 31, 1990 meeting in
Cincinnati, U.S. EPA asked ADC if they would be willing to perform an
engineering-scale treatability test to determine the feasibility of
ISV. Legal counsel for ADC responded in the negative. It should be
noted that, by ADC's own admission, they are pursuing concurrent
treatability studies for both chemical oxidation and a process which
ADC did not present in the FS, low temperature thermal aeration
(IUTA). Based on information presented by ADC, the total costs of
-------
39
these tests will run approximately $50,000. ADC was informed at the
July 31, 1990 meeting that an engineering-scale ISV treatability test
would cost in the range of $45,000 to $60,000. Geosafe has reviewed
the Phase IV sampling results which identified an array of organic
and inorganic compounds within the lagoon sludge and clay. Geosafe
is confident that ISV would be amenable to the types and
concentrations of contaminants found at the Site. A engineering-
scale treatability study and whole rock analysis of the sludge and
clay would be required prior to implementing this alternative.
-------
TABLE 1-1
-------
ALTEINATIVC •: EXCAVATION. OM-SITE LAMOFlLLINC
(PAiTIAL HODiriCATIOH Of IACCOM)
CAPITAL COST
| OESCIIPTIOM
1
1
|SITE/COM$TIUCriOH WORK
1
(General Mobiliiation
1
(Surface Sell Eicavation
1
(lagoon u«ter Disposal
1
(Sludge Orying/Stabiliiation
1
(lagoon Sidevall Eacevation. Staging
(and Placement
1
(Lagoon Sludge Eacavation. Staging
(and Placement
1
(Lagoon Clay Eacavation (5 fret). Staging
(and Placement
1
(Filling of facets Lagoon Area (Outside the
(Landfill)
1
(Liner Placement in Landfill Area
1
(2* Compacted Native. Clayey Soil
1
|2' Clay Layer Placement
1
(60 mil Liner Placement
1
|1' Leachate Detection (Sand)
I
(Drainage net «ith Geotea
1
(60 eul Liner
1
|1' Leachate Detection i Collection (Sand)
1
(Drainage Net mth Ceotei
1
| Ceotei tile Memorane
1
(Cap Placement
1
(Placement of 3' Clay Layer
1
(Placement of 30 «H Liner
1
(Placement of 1.5' Sand Layer
1
(Placement of 2' vegetative Layer
1
(Mulching/Seeding
1
(Leachate Collection Sump. Piping and
(Pumping Structure
1
(Cap Drainage Collection System
1
UNIT
iun> SUB
cubic yd.
gallons
cubic yd.
cubic yd.
cubic yd.
cubic yd.
cubic yd.
cubic yd.
cubic yd.
square yd.
cubic yd.
square yd.
square yd.
cubic yd.
square yd.
square yd.
cubic yd.
square yd.
cubic yd.
cubic yd.
square yd.
lump SUB
lump SUM
QUAJITm
5
90.000
4SO
200
450
2.350
2.350
600
600
1.850
300
850
1.750
350
800
1.750
1.8SO
2.050
1.100
1.500
2.500
LMIT PI ICE
»
10
0.2
30
10
10
15
10
10
18
9
15
13.5
9
15
13.5
1
18
3
10
12
1
TOTAL COST
*
20.000
50
18.000
13.500
2.000
4.500
35.250
-23.500
6.000
10.800
16.650
4.500
11.500
15.300
5.250
10,800
1.750
33.300
6.150
11.000
18.000
2.500
8.000
6.000
C-7
-------
ALTERNATIVE •: EXCAVATION, OH-tlTE LANO'ILLINC
(PARTIAL MODIFICATION Of LACOCM) (Continued)
CAPITAL COST
| OESCIIPTION
1
(Monitoring well Construction
1
|Le»ch«te Detection Piping «nd Mcnholt
1
1
(SUBTOTAL
1
(MISCELLANEOUS
1
1
(Netlth *nd Safety Monitoring I Supplies
1
(Decantwnintt ion facilities (Concrete Pad
(end Sump)
1
(Air Monitor ing/Sot I Swpling
1
1
(SUBTOTAL - CAPITAL COST
1
(Legal fe«s. License I Permits • it
1
(Engineering t Construction Mwgenent - 201
1
1
(SUBTOTAL
1
(Contingency - IDS
1
(TOTAL CAPITAL COST
1
UNIT
e»ch
lu*p SUB
(iff, SUM
Imp SUB
IU»P SUB
QUANTITY
8
UNIT PtICE
S
1,250
TOTAL COST
»
10.000
6.000
300.300
25.000
5.000
30.000
360,300
1S.020
72.060
450,180
<.5,WO
495 >20
C-8
-------
ALTERNATIVE I • EICAVATIM. OH-SITE LAMDFIILINC (PARTIAL MODIFICATION OF UQOOH)
OPERATION t
DESCRIPTION
VEGETATIVE COVER KAIHTINANCE ..._..
SHORT -TERN MQMtToaiHC
Crovndwatcr Sampling. l*bor»tery
An«lr*i( «nd Report
LONG-TERM MONITORING (oree every 5 yeirt)
Crouidwater S«tcling, Labor itory
Analysis i leport
SUBTOTAL
Contingency - Cost Based on 201 of Subtotal
TOTAL
|
UMITS (QUANTITY
lu»p su»
••eh
each
- -
1
1
UNIT MICE t
15.JOO
15. 500
TOTAL MNUAL
COST. »
,1.000
15,300
15.300
OPERATION
TIH6. YRS
30
2
28
BEGINS IN
TEAR HO.
1
1
3
PIE SCUT WORT*
t
15.J70
28,450
47. UO
*
U
1CS
C-9
POOR QUALfij
ORIGINAL
-------
ALTERNATIVE • • EICAVATION. ON-SITE
LANOFILLINC (PARTIAL MODIFICATION OF LAGOON)
TOTAL PRESENT WOBTN COSTS
1
| DESCRIPTION
1
1
(TOTAL CAPITAL COSTS
1
[TOTAL OiM COSTS
1
1
(TOTAL PRESENT IOBTH COSTS
1
TOTAL PRESENT MOSTN
t
495. 420
109.150
604.570
C-10
-------
TABLE 1-2
-------
ALTERNATIVE C: IXCAVATIO*. OFF-SITE LANDFILLINC
CAPITAL COST
| DESCIIMIOM
1
1
(SITE/CONSTRUCTION M»K
1
1
(General Mobilisation
1
(Surface Soil Eicavation
1
(Lagoon Water Disposal
1
(Sludge Orying/Stabil ixation
1
(Lagoon Sidewall Excavation and Loading
1
(Lagoon Sludge Eicavation and Loading
1
(Lagoon Clay Eicavatien (5 f**t depth)
|t Loading
1
(Transportation of All Soils to Landfill
1
(Disposal at the Landfill
1
(Clean lackf ill
1
(Monitoring Well Construction
1
1
(MISCELLANEOUS
1
(Health t Safety Monitoring and Supplies
1
(Decontamination Facilities (Concrete Pad
|t Sure)
1
(Air Monitoring/Soil Sampling
1
1
(SUBTOTAL - CAPITAL COST
1
(Legal Fees, license t Permits • SX
1
(Engineering t Construction Management • SX
1
(SUBTOTAL
1
(CONTINGENCIES • 10X
1
1
(TOTAL CAPITAL COST
1
WIT
1
|IUMP SUB
cubic yd.
{gallons
1
cubic yd.
cubic yd.
cubic yd.
cubic yd.
cubic yd.
cubic yd.
cubic yd.
each
limp sun
Imp su*
QUANTITY
1
5
90.000
450
200
450
2.3SO
3,000
3,000
11,250
a
UNIT PIICE
•
10
0.2
30
10
10
15
35
200
10
1,250
TOTAL COST
»
20.000
SO
16,000
13,500
2.000
4.500
35,250
105,000
660,000
112.500
10.000
15,000
5.000
26,000
9*6. BOO
4A.440
44.440
1.065.680
106.570
1.172.250
C-15
-------
AIT EM AT IVI C • CXCAVATION. WF-llTE LANDFILliHC
OPEKATIOM t MAINTENANCE
OESCIIPTION
SNOBT-TEIN MONITORING
Crov«*.it«r Sanpling {"BOCA only).
laboratory Analysis I Icport
SUBTOTAL
[Contingency • Cost Based on 20Z of Shfetotal
1
(TOTAL
UNITS
••eh
OUANTITT
1
UNIT MICE S
6.500
TOTAL ANNUAL
COST, ft
».soo
OPEUTIC*
TIMC. TIS
2
BEGINS IN
TEA! NO.
1
PIESENT UOBTN]
* 1
l
1
12.080 |
1
i
1
i
i
i
i
;
i
i
12.080 :
i
i
2.420 '
016
POOR C
ORIGINAL
-------
ALTEIMATIVE C • EXCAVATION,
OFF-SITE LANDFILL IMC
TOTAL MESENT VORTN COSTS
1
| OESCI1PTION
1
1
(TOTAL CAPITAL COSTS
1
| TOTAL OP" COSTS
1
1
ITOTAL MESEMT UORTN COSTS
1
TOTAL MESEMT UOBTN
*
1.172.250
U.500
1. 1Bd.no
C-17
-------
-------
ALTERATIVE 0-1: EXCAVATIOM. OM-SITE IHCUElATlCm AMD »-$ltt DISPOSAL
CAPITAL COST
| DESCIIPTION
1
1
(SITE/CONSTRUCT ion won
1
(Central Mobilization
1
(Surface Soil Excavation
1
(Lagoon Water Oi*pes«l
1
(Trial turn of Incinerator at Site
1
|lagoon sidevatl Excavation
1
(Lagoon Stubs* Excavation
1
(Lagoon Clay Excavation (5 feet depth)
1
(Incineration of All Soil*
1
(Disposal lack in the Lagoon
1
(Monitoring Well Construction
1
(lackfilling of Lagoon
1
(MISCELLANEOUS
1
(Health I Safety Monitoring and Supplies
1
(Decontaminat ion facility (Concrete Pad
(and Simp)
1
(Air Monitoring/Soil Sampling
1
1
(SUBTOTAL - CAPITAL COST
1
| legal feet. Licence* ft Permit* - SX of
(Capital Cost
1
(Engineering 1 Construction Hanagenent • St
1
1
(SUBTOTAL
1
(Construction Contingencies - 101
1
(TOTAL CAPITAL COST
1
UNIT
lump am
cubic yd.
gallon*
lunp SUB
cubic yd.
cubic yd.
cubic yd.
ton*
cubic yd.
each
cubic yd.
lump sun
lifip su*
Imp su»
QUANTITY
S
90,000
200
450
2,350
3.800
3,000
8
8,250
UNIT PtICE
f
10
0.2
10
10
15
TOO
10
1.250
10
TOTAL COST
»
20.000
SO
18,000
130.000
2,000
4,500
35.250
2.660,000
30,000
10.000
82.500
30.000
5.000
30,000
3.057.300
152. B70
152.870
3.363.IKO
336,300
3.699, 3*0
C-18
-------
ALTCIMATIVE 0-1: EXCAVATION, CM-SITE INCINERATION AND ON-SITE DISPOSAL
OPERATION t MAINTENANCE
DESCIIPTION
SMOtT-TEIH HONITOIINC
Croundwattr Sampling ("BOCA only),
laboratory Analysis »r«3 leport
LONC-TEIN HONITOIINC
Croundwater Sanplino.. Laboratory
Analysis and leport
SUBTOTAL
Contingency • Cost Based on 20Z of Subtotal
TOTAL
UNITS
•ach
••eh
1 1
(QUANTITY (UNIT MICE *
1
1
6.500
6,500
(TOTAL ANNUAL JOPEUTION
COST. > JTIUC. TIS
6.500
6.500
2
2B
IIECIHS IN
TEA* HO.
1
3
IKESENT MOST*)
i
'2.080
20,030
32.110
6.420
U
C-19
POOR
-------
ALTEINAT1VE 0-1: EXCAVATION. ON-SITE
INCINEIATIOM AND OM-SITE DISPOSAL
TOTAL PIESENT yOSTN COSTS
I
| OESCIIPT10M
I
I
| TOTAL CAPITAL COSTS
I
(TOTAL OtM COSTS
I
I
(TOTAL PIESENT VORTM COSTS
I
TOTAL PIESENT UOtTH
»
3.699.3*0
38.530
3. 737.870
C-20
-------
TABLE 1-4
-------
ALTERNATIVE 0-2: EXCAVATION. IN-JITV VITIIMCATIOH
CAPITAL COST
| DESCIIPTIOM
1
1
ISITE/CONSTIUCTIOM uoac
1
(General Mobil ization • ISV Contractor
| - General Contractor
1
| Surface Soil Excavation
1
(Lagoon water Disposal
1
|Trcaiability Study Off-Site
1
(Technical Assistance
1
(Lagoon Sideual I Excavation
1
| Lagoon SluOge Excavation
1
(Lagoon Clay Excavation (5 feet depth) from
(area MOO1 x 75') without ISV
1
(In Situ vitrification
1
(Monitoring Well Construction
1
(Backfilling of Lagoon
1
(MISCELLANEOUS
1
(Health t Safety Monitoring and Supplies
1
(Decontamination facility (Concrete Pad
(and Sunp)
1
(Air Monitoring/Soil Sanpling
1
1
(SUBTOTAL • CAPITAL COST
1
(Legal Fees, Licenses I Permits • 5X of
(Capital Cost
1
(Engineering I Construct ion Management • 101
1
1
(SUBTOTAL
1
(Const ruction Contingencies - 10X
1
(TOTAL CAPITAL COST
1
UNIT
lV*P SUB
•
cubic yd.
gallons
imp *u»
Imp tin
cubic yd.
cubic yd.
cubic yd.
tons
each
cubic yd.
Imp sum
Imp su*
Imp sun
QUANTITY
S
90.000
200
ISO
720
3.770
8
12.150
UNIT MICE
•
10
0.2
10
10
15
350
1.250
10
TOTAL COST
*
ISO. 000
20,000
SO
18.000
45,000
75,000
2,000
1.500
10,800
1.319.500
10.000
121.500
30,000
5,000
30.000
1.838.350
91.920
183. 840
2. 1U. 110
211.410
2,325.520
C-21
-------
ALTERNATIVE 0-2: EXCAVATION. IM-SITU VITRIFICATION
DESCRIPTION
SNORT-TERN MONITORING
CrokTducter Swvling (MBOCA only).
Laboratory Analy»i» *od Report
LONG-TERN MONITORING
Croundwater Sampling, Laboratory
Analysis and Report
SUITOTAL
Contingency - Cost lased on 20X of Subtotal
| TOTAL
IMITS
••eh
•aeh
1
QUANT ITT
1
1
UNIT MICE *
6,500
6.500
TOTAL ANNUAL (OPERATION
COST. » (TIME. TRS
6.500
6.500
2
28
•ECINS IN
TEAR NO.
1
3
PRESENT yD8TK|
12,080
20.030
C-22
\
-------
ALTERNATIVE 0-2: EXCAVATION.
IN-SITU VITRIFICATION
TOTAL PRESENT UDRTN COSTS
j DESCRIPTION
1
1
[TOTAL CAPITAL COSTS
1
(TOTAL OtM COSTS
1
1
(TOTAL PRESENT WQBTN COSTS
1
TOTAL PRESENT UORTN
S
2.325,520
38,530
2.3M.050
C-23
-------
TABLE 1-5
-------
ALTERNATIVE 0-3: EXCAVATION. OH-SITE CHEMICAL/BIOLOGICAL
AMD ON-SITE DISPOSAL
CAPITAL COST
| DESCRIPTION
1
1
|S:TE/COMSTRUCTION UOB.K
1
(General Mobililation
1
(Surface Soil Excavation
1
(Treatabil ny Study Off-Site
1
(Pilot Scale Study
1
(lagoon Side»all Excavation
1
(lagoon Sludge Excavation
1
(lagoon Clay Excavation (5 foot oeptr.)
1
(Criemicat/Biologicai treatment
1
(Disposal Back in the Lagoon
(Bactfilling of Lagoon
1
(MISCELLANEOUS
!
Nealtn i Safety Monitoring and Supplies
1
|0econtan>inat ion facility (Concrete Pad
and Sump)
tir woni tor ing/Soi 1 Sanpting
|SUBTOT»l • CAPITAL COST
I
(legal fees, licenses i Pennts • n of
(Capital Cost
(Engineer ing t Construction Management - 15X
1
(SU8T01AL
1
(Construction Contingencies • 101
(TOTAL CAPITAL COST
1
OMIT
Imp sum
cubic yd.
lump sum
lump Sum
cubic yd.
cubic yd.
cubic yd.
cubic yd.
cubic yd.
cubic yd.
lump sum
lump sum
lump sum
QUANTITY
S
200
450
2.3SO
3.000
3.000
8.250
UNIT PRICE
S
10
10
10
15
190
10
10
tOTAL COST
t
20.000
50
20.000
100.000
2.000
4.500
35.250
570.0CC
30.000
82.500 '
30,000
5.00C
30.000
920.300
65.050
137.620
1.131.970
113.200
1.245.170
C-24
-------
TABLE 1-6
-------
ALTEINATIVE E: EXCAVATION. OFF-SITE INCINEIATION
CAPITAL COST
| DESOUPTION
1
1
ISITE/COMSTIUCTIOM WOBC
1
(General Mobilisation
1
(Surface Soil Eicavation
1
(Lagoon water Disposal
1
(Lagoon Side«all Ekcavation
1
(Lagoon Sludge Eicavation
1
(Lagoon Clay Excavation (5 f«t depth)
1
| Transport of all soils to Incinerator
1
| Incineration
1
(Clean Backfill
1
(Monitoring yell Construction
1
(MISCELLANEOUS
1
(Health t Safety Monitoring and Supplies
1
(Decent ami nation Faci lity(Concrete Pad t Sump)
1
(Air Nonitoring/Soi t Sampling
1
(SUBTOTAL • CAPITAL COST
1
(Legal Fees, Licenses t Permits • IX of
(Capital Cost
1
(Engineering i Construction Management - 1X
(of Capital Cost
I
(SUBTOTAL
I
(Contingencies - 31
1
(TOTAL CAPITAL COST
1
UNIT
lUlp »LH
cubic yd.
gallon*
cubic yd.
cubic yd.
cubic yd.
cubic yd.
tons
cubic yd.
each
lump sun
lump sun
lump sun
QUANT ITT
5
90.000
200
450
2.J50
3.000
3.UO
11.250
8
UNIT PtlC£
*
10
0.2
10
10
15
81
1.500
10
1.250
TOTAL COST
»
20.000
1
50
16.000
2.000
4.500
35.250
243.000
5.700.000
112.500
10.000
15.000
5.000
28.000
6.195.300
61.950
61.950
6.319.200
189.580
6.508,780
C-27
-------
ALTERNATIVE E: EXCAVATION. Off-tilt IHCIIIEUTIOH
OPERATION (
DESCRIPTION
SHOIT-TEtH MONITORING
CrohT«*»*tcr S*n«tinq (MOCA only).
l«eor»tory An>ly*it * Icport
SUtTOTAL
Continqcncy - Cost l«t«d en 201 of St£tottl
|tOI*L
1
1 1
UNITS |OUMT|TT|UMIT MIC£ »
••eh
1
6.500
TOTAL ANNUAL JOPEUIIW
COST. « jtlNC. TIS
4.JOO
2
IECIMS III
TEA* NO.
1
ciESdT yc!^
t
12.SU
12.083
2.120
U.50C
C-28
-------
ALTERNATIVE E: EXCAVATION. OFF-SITE
IHCIMEBATIOM
TOTAL PRESENT IOITN COSTS
1
| DESCRIPTION
1
1
(TOTAL CAPITAL COSTS
1
(TOTAL 0*« COSTS
1
1
(TOTAL PRESENT U08TH COSTS
1
TOTAL PRESENT UORTH
t
6,508,780
14.500
6.523,280
029
-------
ATTACHMENT A
-------
TAILE 1-2
CONCENTRATIONS OF VOLATILE AMD SEMI-VOLATILE ORGAN1CS.
•«•*. AHO METALS IN METREATMENT LAGOON AREA
Parameter
I METALS
Sb
AS
Ba
Be
Cd
Cr
Pb
1
| Hn .
"9
1 *9
|
|
1 Tl
I
i
1
1
|I!.A. VOLATILE ORGAN I CS
(Acetone
•
|Methylene Chloride
i
1
jTetrachloroettiene
i
1
[Toluene
|Styrene
Lagoon Sludge
(vig/kg)
•
6000 to 0900
92.400 to 134.000
2700 to 2BOO
•
36.000 to 68.300
15.600 to 16,700
6 6
30.3 * 10 to 107 * 10
290 to 500
4900 to 15.300
•
5000 to 00,000
<2000 to 7000
< 70, 000 to UO.OOO
-
Concentr
Lagoon Clay
-------
TMIE 1-2
1
1
1
1
1
Parameter
1
1 ' ...
|1I.I TMTATIVELY IDENTIFIED
VOLATILE ORCAN1CS (TlCt)
1
1
|»cetaldehyde
i
1
(Cyclobutane. ethyl
| Unknown hydrocarbon 1
JMextne
|1-Pentene, 2»-tri*ethyl
|Proo»n*thioic acid/ester •
1 1 ,2-Oichtoroberaene
(Unknown hydrocarbon II
jCyclohexane. 1.1 -dimethyl
|1.2 Dichlorobenjen* • Unknown
| Hydrocarbon
|1.2 Dichlorobenjen*
|1-Propanol
|1.1.2-Triehloro-1.2.2-
|Trif luroethane
|2-«ethyl-2-propanot
jTetrahydrofuran
|H-chloroani line
Lagoon Sludge
(ug/kg)
- - -
2000 to 20,000
3000 to 7000
5000 to 6000
10.000 to 40.000
6000 to 20.000
10.000
3000
6000
'
20.000
3000
-
-
-
•
•
Concentr
Lagoon Clay
(ug/kg)
— - - - . ...
•
-
•
•
-
•
10
30
9
40
*
It ions
Confining Layer
Monitoring Welle
(ug/L)
-
-
-
-
-
-
-
-
-
•
10
Confined Aquifer
Monitoring Wells
(ug/L)
... -
-
-
-
-
1
-
-
-
i
-
-
-
-
1-18
-------
TABLE 1-2 (continued)
1
1
f
\
I
1
1
IIH.A SEMI-VOLATILES
|4-Methylpnenol
1
(Phenol
I
1
|4-CMoroani line
i
1
(N-Nitrosodipnenylamine
1
1
|Bis (2-ethylhexyl)-prithalate
i
1
1 1 , 2 -0 i eh I orobeitzene
1
1
(MLB. TENTATIVELY IDENTIFIED
| SEMI-VOLATILES (TICS)
1
i
1
|4-hyQroxy-4-«ethyl pentanone
|4, 4 '-Methyl eoetois£2-chlorol •
Ibenztnine
1
jCaprolactam
1
JMorpholine
i
1
|4-Myaroxy-4-«ethyl-2-Pentanone
1
|1-«ethyl-2-Pyrrolidinone
1
|M-Chioroaniline
I
1
|4-Chioro-6-Metho*y-2-
[Pyrinidinanine
1
|4a, 9b-DihyOro-6, 9b-di«ethyl-
|3(4H)-diberaofuranone
i
1
{Molecular Sulfur
i
1
1
|o-(o-Tolyloiy)benzoic acid *
unknown compound
|N-(2-Mcthylcycloheiyl)-M'-
|phenyi-urea
Lagoon Sludge
(ug/kg)
14.000 to 47,000
4000 to 9000
-
•
4000 to 6000
<2000 to SOOO
.
6000
20,000
7000
20.000 to 30.000
SO. 000 to 100.000
10.000 to 20,000
SOOO
8000 to 20,000
SOOO
20.000 to 40,000
Concent r
Lagoon Clay
(ug/kg)
.
•
-
-
•
.
1000
400
•
-
•
-
-
•
-
*
-
ations
Confining Layer
Monitoring yells
(ug/L)
-
•
40
-
•
-
.
-
20 to 70
-
-
*
-
-
-
-
*
-
Confined Aquifer
Monitoring Wells
(ug/L)
-
*
-
10
-
•
'
•
200
*
-
'
•
*
•
•
*
•
1-19
-------
TUIE 1-2 (continued)
Parameter
111.I SMI-VOLATILE TICi
(continued)
1.1-Sglfonytbit H-chloro) •
benzene
(4.4- Nethylenetois 12-ehI ore] •
(benzenafliine
I
|2-<2H-Beniotriazol-2-yl)-4-
| me thyI-phenol • unknown
(compound
I
|2-Methyl-1-propene tetraner
I
|S.S-Dinethyl-2-he*ane
I
|2-<2.*-Oinitrophenyl) 5.6.7.8
|tetrahydro-2n-1.2.3-
Ibenzothiadiazine
pO-Methyl-ticesane
I
(Possible 1,4-dianethyoxy-
(anthracenc
I
|4-dimethyoxy-anthracene
I
I
I2.3.3a.4.7.7a-he«ahydro-
|2,2.*.*.7.7-hexa»i»thyl-1»(-
I
|M-2-Propenyl-2-p«-open-L-a«ine
I
|2-Methyl-1-3-6*trio>oc«ne
I
(fcniline
I
(x-chleroaniline
I
|2- C(2-hydro«r«thyl )anino) -2-
|
-------
TAKE 1-2 (continued)
Perimeter
lit. I SEMI-VOLATILE TICS
(continued)
3-Chloro-4-«ethyl benzeamine
|1-Hydro*ymethyl)-5,5-di«ethyl-
|1-2.4-iBidazolidinedione
[Unknown Ester
Possible thteno C3,2-b)-
|thiophene
| Unknown nitrogen Containing
| Compound
[Octanoic Acid
13-Octadecene
I
[Possible Octanoic Acid,
methyl ester
(Possible o-chloroaniline »
unknown compound
[Unknown Compounds (including
[hydrocarbon* ( chlorinated
{compounds)
| IV. PCBs
Lagoon Sludge
(wg/kg)
-
-
-
•
1000 to 70,000
•
Concentr
Lagoon Clay
(ug/kg)
-
•
•
•
3000
•
ations
Confining Layer
Monitoring Wells
(ug/D
30
10
400
30
400
-
•
SO to 100
H/A
Confined Aojuifer
Monitoring wells
(ug/L)
•
•
•
-
-
10
10
10
30
9 to 30
«/A
1-21
-------
ATTACHMENT B
-------
STATE Of MICHIGAN
ftCKxmcu comtiwiON .-.-•-
THOMAS J. ANDEASON
MARINE j. FLIIHARTY
OOROON f. ouvcn
JAMES J. BLANCHARD. Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON BUILDING
PO BOX 30021
LANSING. Ml 4890»
DAVIO F, HAIE8.
September 27, 1990
Mr. Valdas Adamkus, Regional Administrator
U.S. Environmental Protection Agency
Region V, 5RA-14
230 South Dearborn
Chicago, Illinois 60604
SUBJECT: Anderson Development Company Superfund Site, Lenawee County
Dear Mr. Adamkus: *
The Michigan Department of Natural Resources (MDNR), on behalf of the State of
Michigan, has reviewed the proposed Record of Decision (ROD) for the Anderson
Development Company (ADC) site which we received on September 7, 1990. The
remedy in the proposed ROD consists of In Situ Vitrification (ISV) to destroy
or immobilize contaminants which exceed health based levels 1n the
pretreatment lagoon sludges, the clay which underlies the pretreatment lagoon,
and the surface soils around the pretreatment lagoon.
At t.he public meeting and In public comments on the proposed plan for the
sit*, there was substantial concern raised regarding the safety, technical
feasibility, and cost-effectiveness of ISV as a potential remedy at this site.
In evaluating the feasibility study and proposed plan for this site, in
addition to public comments received and information available on ISV, we have
determined that ISV Is an appropriate remedy for the site. ISV is now
considered a proven, innovative technology. We expect it to safely and
effectively provide a permanent remedy for the site which is protective of the
public health, safety, welfare, environment and natural resources. The remedy
can meet the criteria for a Type B cleanup under Michigan Act 307 rules, and
of the potential remedies that have been shown to be able to meet those
criteria, ISV 1s the least costly. We concur with selection of ISV as the
final remedy for this site. This concurrence is contingent on its continued
successful evaluation through the treatability study and design process and
its successful full scale Implementation at another site 1n Michigan prior to
implementation at the Anderson Development Company site.
I understand that ADC is currently exploring the potential effectiveness of
other technologies such as chemical oxidation and low temperature thermal
aeration, even though ADC developed the feasibility study for the site which
HI 026
3/i9
-------
Mr. Valdas Adamkus -2- September 27, 1990
had originally ruled out or failed to consider these alternatives. EPA with
.MDNR . agre.ementJva.s _al ready delayed.p.ubl ij.hjn9 the_proppsed_pAan in order t_o._
give ADC time to demonstrate that chemical oxidation would be a viable
alternative. We concur with EPA's proposal to also delay the start of
negotiations for remedial design and remedial action for 60 days to allow
additional time for ADC to explore and attempt to demonstrate the
effectiveness of these technologies. If within that time period they are
successful in demonstrating that another technology would be able to meet the
cleanup criteria 1n a more cost-effective manner, the MDNR would support
reopening the ROD.
I look forward to our continued cooperation in the successful implementation
of the final remedy for this site.
Sincerely,
Delbert Rector
Deputy Director
517-373-7917
cc: Mr. Jonas Dikinis, US EPA
Ms. Mary Tyson, US EPA
Mr. Michael Valentino, US EPA
Dr. James Truchan, MDNR
Mr. William Bradford, MDNR
Ms. Claudia Kerbawy, MDNR
Mr. Brady Boyce, MDNR
Ms. Lynelle Marolf, MDNR
-------
Pagt Ho. 1
07/08/50
nmmm PACUS DAK
rim
jDxrmruriri MCO«D inn - mm n
umsot umnmt nuui svmiw sm
ADRIAI, mcsm*
mimit
Doci/mr tni
1 88/01/13
Letter
Rei Anderson DereJopieot
Coipanf Site • fiene*
Coueots tor Dntt
flndanjeneat Amssienr
aod IS
Hiciaei A.
ITSJPA
Caieotioo
J.Buerta - ADC
Correspondent
88/10/04 Letter
Re; Anderson DereJopieat
Coipanf Site 817/5
Project Progress Report
Ho. IS
mo enclosure
Jaies I. Huerta
Aoderjoo DereJopieat
Coipacf
M.Valentino - USE?A Correspoodeoce
88/10/12 Letter
tit: Aadertoo DereJopieot
Coipaoy-Pretreatieot
La;ooo Soil iaipjjnj
locations
vita attacoieat
VieaaeJ A.
OStPA
Valentino
f.Naiaotra - CCJH Correspondence
2 88/10/28
letter
Ret Aadersoa DereJopieot
Coipaaf - Pretreatieet
layoon Saiplja;
Procedures
KicoaeJ A.
VSSfl
faleotioo
].Huerta • ADC
Correspondence
3 88/11/01
Letter
fie; Coipjetioa
of HI/IS at tae
Aadersoa DereJopieot
Coipaor Site
(TicaaeJ A. PaJeotioo
ITStPA
J.fluerta - ADC
Correspondence
3 88/11/17
Letter
fie: a prerious
Jetter refoestio;
confinatiofl of
81/fS scoeduJe
coipJetioo dates
Jaies 8. luerta
Aodersoo DereJopieit
Coipaor
if. Valentino - ffSfPA Correspondence
2 88/11/2J
Letter
tficeiel A. Valentino
Arrid Satoer - KBf Correspondence
-------
Page Mo.
01/OS/90
om
miusrntm mow inn - mm n
AIDHSOI nnumn comii somim sirs
IDHAI,
run
iUTBOK
Ret Andersoo Derelopieot
Coipanr Site,
Jfienigan
mimir
momr rm
DOCHVKBU
1 88/11/29 Letter Ificnael A. Mention
Rti Aflderjoo DereJopieot VSSPl
Coipaor Site Jeriev of
Draft fil Jeport
JJueAeoe • 15, IDC. Correspondence 8
3 88/12/06 letter Jaie* «. loerta
lei Anderson lerejopieot inderson Oerelopient
Coipanr Site SI/IS Coipaor
Project Projresi Report
Ho. 18
X.Falentioo • OSStH Correspondence S
2 88/12/08 letter Kicnael L raleotino
Kti Anderson CereJopieot USSPl
Coipanf Site
Adrian, Micoi;an
B.Bofce • NDVII Correspondence 10
1 88/12/15
letter
Rei Anderson
Derelopieot Coipaof
Site fierier of Draft
fndan;enent
Assessieat and
/easioiJitf Studf
reconicaj Meiorandoi
KichieJ A. Valentino
SSEPl
J.Ducneoe - IS, Inc. Correspoodeoce 11
( 88/12/22
letter
fie.- Jeriev Collects
on Anderson DereJopieot
Coipanf Draft teiediaj
Inresti;ation Jleport
«icoael A. Valentino
USfPA
J.fiuerta - ADC Correspondence 12
1 89/01/03 letter tficbiel (TaJentioo
Rei Anderson DereJopieot OSfPA
Adriao, Kicnijao
J.Ducoeoe - IS, Correspondence
Inc.
5 89/01/04 letter Jaies I. Juerta
fiei Aodersoo DereJopieot Anderson DereJopieot
Coipaof Site fil/fS Coipaor
Oaleotioo • VSSPA Correspoodeoce 14
-------
Page Jfo. 3
07/08/90
ruts urn
uunstunn mots now - mm n
luiisoi DWLOPwir cowir soptRtm sm
mm,
imt
Amos
mumr
rm
Project Progress Report
Ho. 19
iritn attacnieoti
12 83/01/20
Letter
fie; Addition*]
Vori fiefuireienti
for Anderson DereJopient
Coipanf Site RI/f$
mi attacnient
Bail G.
KIM
Constantelos J.tfuerta - l/SSPA Correspondence
1 89/01/26 Letter Kicoael A. Valentino
fie.- Anderson DereJopient SSIPI
Coipanr, Adrian, Nicni;an
J.Ducnene - IS. Inc. Correspondence
3 85/02/02
Letter
fiei Anderson Dereiopient
Coipanf Site SI//S
Project Progress Report
No. 20
Jaies fi. fluerta
Anderson DereJopient
Coipanf
K. ITaJentino - (TSfPA Correspondence
17
1 89/02/02
Letter
fiei Additional Vorlr
fieguireient for
Anderson DereJopient
Coipanf Site KI/IS
Jaies I. luerta J.Constanteios - Correspondence
Anderson Dereiopient
Coipanf
1 89/02/OS
Letter
fie.- Confination
of Heetioo.
Micnael A. Valentino J.Huerta - VSBPl Correspondence
asm
19
6 89/02/07
Letter
fie: Phase IV RI
at ADC fretreatieot
La;oon Soil and
Sludge Saipling
Jonn B. fveddale
C.C.
Joooion i Jfalnotra, P.C.
Inrironieotal fn;ineers
(T.Faleotioo - tiSiPl Correspondence
20
2 89/02/08
Letter
fiei fierised RI Report
Kicaael A. Calentino
vsm
J.Euerta - ffSfPA Correspondence
21
3 89/02/15
Letter
fie: fierised
fticnael A. Valentino
VSfPA
J.ffuerta - VSSPl Correspondence
22
-------
Page So. t
07/08/90
umismrin most nm - mm n
nmotmr comit sopEstm sirs
HICSICM
ims/mn PAWS nm
rmt
fil/fS ScneduJe for
tne Anderson Derelopient
Coipanf Site
enclosure"
oocomr
DOCXVKBSS
1 89/02/16
Letter
fie.- Rescheduling
of letting
fficnael 1. Valentino
asm
J.fluerta - HOC
Coriespondmct
4 89/02/lS Letter Kicbitl I. Vilentiao
Bet totersoo DereJopieot USSfi
Coipaof Sice
vitb attaclneot
J.Jvetdile - CCJK Correspomfea:e
1 8J/03/K
Letter
fie; iaienoa OereJopient
Coipaof Site -
DijapproraJ
of
JficlaeJ 1. IfaJeatjno
osm
J.Buerti • HOC
Correspoodeace
25
Letter
fiei Aodersoo
Derelopieot Coipaof
Site Rl/IS Project
Progress Report
«o. 21
vito eacJosure
Jaies J. fluerta
iodersoo Derelopieot
Coipaof
ioo - IfHPA Corres'poodeoce
26
2 S9/04/18
Letter
Rei Aodersoa Derelopieot
Coipaor Site - Approrai
of (JPP aod fort Plao
Nicoael I.
asm
Valentino
J.fluerta - ADC Correspondence
27
6 89/05/05
Letter
fiei Anderson DereJopient
Coipanf Site fil/fS
Project Progress fieport
lo. 22
Jaiei I. fluerta
Anderson Derelopient
Coipanf
((.Valentino - ffSIPA Correspondence
5 SJ/Oi/07
Letter
fie.- Anderson DereJopient
Coipanr Site SI/IS
Jaies K. Buerta
Anderson DereJopient
Coipoaf
K.FaJentiao - [ftgPA Correspondence
29
-------
* «
Page Ho. 5
07/08/90
mat/mill PtSSS DATS
JITLS
Project Progress Report
Jo. 23
RECORD nm • mm n
tsmoniur comu smarm sits
mm, ucamt
MCIPIW
nocumr TYPE
89/07/OS letter
Ret later SOD DereJopient
Coipanf • fieriev ot
Revised Reieditl
Investigation Report,
fudaoaerieot kssessieat
and AJtematires Arraf
Docaieot
Hicoael J.
osm
Valestito J.Ouclieoe - 15, lac. Correspondence
30
89/07/07 Letter Jaies R. Buerta
Res Anderson Derejopieot Anderson
Coipanf Site RI/TS Coipanf
Project Progress Report
Jo. 24
H.Valeatioo - VS&PA Correspondence
8J/07/3J Letter
Jte: Aadersoa Derejopieot
Coipany Site RI/IS
Project Progress Report
Ho. 25
Jaies R. Soertt
Aflderson DereJopieot
Coipaof
K. Valentino - 1/SfPA Correspondence
32
89/08/09
Letter
taken dunnj
Phase IV field
activities
S.I. Kalootra
C.C.
Johnson i Halbotra, P.C.
- VSBPl Correspondence
33
89/08/15 Letter
Re: Rtviev Contents
to Revised Sndangertent
Assessient, final
Reiedial Investigation
Report and Alternatives
Array for toe Anderson
DereJopient Coipanf
Site
tfieoaei A. Valentino
tlStPl
J.Baerta - ADC
Correspondence
89/08/29 Letter Kicnael A.
Ret Anderson Derejopieot OSEPt
Coipanf
J.Buerta - ADC
Correspondence
35
-------
Page Ho. 6
07/08/90
moss 11011 - OPDAM n
AIDMSOI nmotmr comii svmiw sm
mm,
nau/nui ness urn
riri!
aocamr im
3 89/08/30 letter Jaies fi. Juerta
fie: Anderson Derelopient Anderson Derelopient
Cotfuj-Site~tI/-lS Coipanr
Project Progress fieport
lo. 26
If. Valentino - OSSPK Correspondence jf
1 89/09/01 letter Patriot J. fbillips C.friredi • CCJH Correspondence
Re/ Adrian, jficnigao Vesta fecinoJoaj, ltd.
Site
37
89/09/15 letter
fiei felepbone
Conrersation of
Septeiber 14, 1989
vitb attacnients
Jaies l. foerti
Jnderson Derelopient
Coipanf
If.raJentino - VSSPA Correspondence 38
letter
Rei Anderson DereJopieot
Coipany Site IIUS
Project Progress Report
#o. 27
Jaies It. Jfuerta
Anderson DereJopient
Coipaof
K.faieotino - (TSfPA Correspondence 39
J 89/10/OS
letter
lei Duration
of Saiple Iitraet
Storage
Joiepn «ari
C.C.
Joboion f KaJnotra, P.C.
(f.raleotino - VSfPA Correspondence
I 89/10/21
letter
fie: Conrersation
of the saie daf
as tne letter
Kicoael A. Valentino J.fluerta • ADC Correspondence
41
I 89/10/30
letter
fie/ laforiatioo on
Jo Situ Nitrification
rechnoJojf
Vieaael A. raJentino
asm
J.Huerta • ADC
Correspondence 42
2 89/10/31
letter
fiei Anderson DereJopieot
Coipanf Site SI/IS
Project
Jaies fi. Buerti
Anderson Derelopieot
Coipanf
N. Valentino - ITSKPA Correspondence 43
-------
Paje'Jo.
07/08/90
•/rms mess
umunum «JCO*D nm . mm u
AIDHSOJI nmotun conmi svpmm sm
mm,
tins
Progress Report So. 28
mmsaf
oocvmr tits
89/11/01 letter
fie.- CifiCIA Anderson
Site lagoon Clean-Up
Jaies Jfuerta
Anderson DereJopient
Coipan?
K.Valtatiuo • USE?I Correspondence
89/11/08 letter tficoael I. Faieotioo
Re: iadersoo Oerelopieot IISSH
Coipaof Site • Reiaiaiog
SI/IS Scoedule
J.Huerta - ADC Correspondence
45
14 89/11/22 letter fficfiael A. Valentino
Re.- Anderson Oereiopient VSIPI
Coipaoy
- fierier Conents
to Draft
/easioiJitf Stodf
vitn attacoients
J.Huerta - ADC Correspondence
89/11/27 letter
fie.* Additional
fieriev Couents to
Draft feasibility
Study
Micnael A. Valentino
assn
J.lfuerta - ADC Correspondence
47
89/11/29 Letter Jaies R. Kuerti
Rei Anderson Derelopient Anderson DereJopient
Coipany Site Rl/fS Coipany
Project Progress Deport
Ko. 29
H. Valentino - OSfPA Correspondence
48
89/12/21 letter
Jet Anderson DereJopient
Coipany Site
- Reriev of Rerised
feasibility Study
and fndangenent
Assessient
licnael A. Valentino J.Ducnene - IS, Inc. Correspondence
49
89/12/29 letter Jaies I. Suerta
fie: Anderson Derelopient Anderson Derelopient
Coipanf Site Rl/fS Coipanf
H. Valentino - 0SEPA Correspondence
50
-------
fige 'to. S
07/08/90
nm/nm ness DAK
mmsmrm RKORD JIDII • mm n
juusoi osmoimr comn somim sirs
mm,
rim
Project Projress Report
Ho. 30
AWIOR
mimtt
rm
mum
4 90/01/10
letter
fie; 'lerised feasioilitf
Study Report
for Anderson Derelopient
Coipanf,
SutiJtted Deceioer, 1989*
Coetao friredi
C.C.
Joioson £ XaJootri, ?.C.
logintert
Jf. Valentino • USSfk Correspondence
51
11 90/01/25
Letter
fiei additional coneots
bf toe Kicnijan
Departient of latoral
Resources regarding toe
Draft /easioilitf Studf
vitn attacned coiienti
froi Us. Chris
•- tie dirision's
tozicolojist
Bradf Bofce
VSSPl
K. Kalentino - SSStH Correspondence
52
5 90/02/07
letter
Re; /inal Rerisions
to tne Cndan;erient
Assessient and
feasioilitf
Studf for tne Anderson
Derelopient Coipanf Site,
Adrian, tficnijan
V.ralentioo
J.ffuerta - ADC Correspondence
53
3 90/02/23
Letter
Re> /inal Reriev
Couents to toe
Rerised fndan;erient
Assessieot for tne
Anderson Derelopient
Coipanf Site,
Adrian, Vicnijan
I. Valentino
USSfi
J.Buerta - ADC Correspondence
2 90/03/Of
Letter
Ret Anderson Derelopient
Coipaof Site IIUS
Project Progress Report
fo. 32
Jaies R. Buerta
Anderson Derelopient
Coipanf
a*. Valentino - ffSSPA Correspondence
55
-------
Page'to. 9
07/04/90
PAGJS DAK
mono IIDM • mm n
AIDHSO* nmnun comir samim sirs
ADRIAN
tint
lOWtt
Mcmtut
DOCOHEHT
3 SO/03/20
Letter
Res feasibility Study
of Anderson Derelopieot
Coipaof Site, Adrian,
tficbigao
Jaiet R. ffuerta
iodersoD Cerelopieot
Coipaof
((.raJeotioo - (tffPA Correspoodeoce
3 90/02/20
Letter
Jiei feasibility Stodf
of Aodersoo PereJopieot
Coipaaf Site, Adrian,
Kicbijao
Jaiet R. ffuerta
Anderson Derelopient
Coipanf
((.Valentino • U5SPA Correspondence
57
J 90/04/05
Letter
Re: Approval of
feiedial Investigation
Report, fndangenent
Assessient and
feasibility Stodf
Mienael Valentino
osm
J. fiuerta
Der.
Anderson Correspondence
58
90/04/JJ Letter
Re: RI/IS, Anderson
Derelopient Coipanf,
Adrian, Jficbijan
vitb attacbed copy
of fork Plan for flencb
Scale freatabilitf Study
for Anderson Derelopient
Coipany
S.f.Kalbotra
C.C.
Jobnson t Kalbotra, P.C.
K. Valentino - I/SEPA Correspondence
59
43 90/OJ/07
Letter
Rei Anderson Derelopient
Coipany Site fil/fS
Preliiinary Assessient
Cbeiicai Oxidation
Alternatire
vitb attacbieots
Jaies luerta
Anderson Derelopient
Coipanf
K.Valentino - USEPA Correspondence
2 90/0*719
Letter
Kti Anderson Derelopient
Coipany Draft Proposed
flan
Brady Bofce
HDIR
K. Valentino - tfSfPA Correspondence
-------
fage to. 10
07/08/90
ricu/niu PACK urn
ims
ADWisrmm mots wn • mm n
Dtmomir comii sommo sirs
JUJII, HICBIGlt
mmnr
DOCVKSHT rm
DocxomR
6 89/09/00
fact Sheet)
PoiJution Jnrestigation
iecentJf Coipleted
iodersoD Dertlofieot
Coipaof
USSPK
fact Sheets
2 88/12/07
Htto
He-, Expedited Data
Istesntnt Reviev
for the todtrsos
Derelopieoc Coipaoy
Sue
vitb attaciieots
Ion liedergatg
osm
CJoss - 05m
Httaraadai
89/OV12 Keto
Kti Approval
of fuaJjtp Jssuraoce
Project PJaa IQWP)
tor Phase IV fieiediaJ
lorestiyatioo Studies
at tie Anderson
DereJopieot Coipany
Site, Adrian, Klchigan
Valerie J. Jones
asm
t.liederyaag • USSPk Neioraodui
6i
I 89/08/03
Neio
Jte> Aodersoo DereJopieot
Coipaof, Alternatives
Array
Jodf rieiian
VS2PA
H. Valentino - ffSEPA Neiorandui
89/08/03 letter
Re: Jeriev of the
AJternatires Arraf
flocuient for tne
Anderson Developient
Coif anf Site
luan-Kai frao
1/5JPA
Jf.raientino - ITSfPA Neiorandui
1 89/08/07
Letter
Set fierier ot the
fierised DeiediaJ
lorestijatioo feport
for tne Anderson
DereJopieot Site
Jaies ffriic
DSIPA
K. Valentino - 1/SffPA Neiorandui
67
-------
Page Ho.
07/flS/JO
n
PACK DAK
uunsmtm RSCORD IIDSI • mm n
umsoi Dimotmj comit SBPWI/ID sin
KICSIGUl
rim
iVTBQR
RSCIPIW
TIPS
8S/OB/08 letter
Rti fater Dirision
Seriev ot tie Rtqutst
for MHti for tie
Aodersoo Derelopieot
Coipaof Site
CfiarJes B. Sutfio
OSSPi
B.Coastsutelos
OSSPI
Htionadm
$9/11/03 Neio
Res later Dirision
Aeriev of tie Draft
feasioilitf Study (7S)
for Anderson Derelopient
Adrian,
CoarJei I. Sutfio B.CoostaoteJoi - Neiorandui
osm vsm
Jl 90/03/22
Neio
Jie: ierjev
of 'Additional fieiedial
Technologies at toe
Anderson Derelopient
Site' and Attacnient
vitn attacnient
Join (fattnevs
N.Valentino - I/SSPA Meioraodui
70
SO/Of/lS Ktio
Re: ifater Dirision
Reriev of tie Proposed
Plan for tne Anderson
Oerelopient Coipanf
Site, Adrian, Kicni;ao
Dale S. Jrfsoo
VSfPA
D.ffllricn • I/SEPA Neiorandui
90/M/26 Htto
Ret fierier of
'Anderson Derelopieot
Coipanf Preliiioarf
Oxidation festinj'
and General toil Plan
vitn cover soeet
Hugo Durnai
Clois Sloeui
OSfPA
H.Valentino - t/SKPA Neiorandui
72
90/05/17 Sonar? of Preliiinary
Oxidation fests Osiny
501, 1001 and 2001
0202 Doses
vitn corer sbeet
C.C.
Joooson i JfaJnotra, P.C.
InrirooientaJ lojlneers
K.ralentioo - trsm Otner
-------
Page to. 12
07/08/90
mn/mu PIGSS Dm
mmsmrin moss IIDSI - mm n
iimsoi osmotmr comvt sapssim sirs
mint,
rim
torsos
mitmr
im
DOCHUMBSR
26 88/08/00
fork Plao
tor Additional Saipliog
SeiediaJ Investigation
at Anderson DereJopient
Coipaoy
Adrian, Ificoigao
C.C.
Joonsoo t Halbotra, f.C.
larjrooieotaTfogioeers
«.FaJ«Dtioo - 1/sm Reponi/Studits
JJ 38/09/00
hitoiti tort tlaa
for Additioaal
SaipJioj itittial
iDveitigatioo at
indtrsoo Derelopieot
Coipaof
Idriao, Kicbigao
C.C.
JoiDJOo t Kalhotra, f.C.
taiiroottntal Soqiteers
H.Valtotioo • OSSn Reports/Studies 75
5£ 88/10/00
Suuarf of tbast II
lortstigatiot
Aodtrsoa Bevelopittt
Coipaoy
Adrian, Michigan
field
Ketealf and Sddj
USSH
Reports/Studies 76
57 88/J1/00
Meioraodui
oo Phase II JeiediaJ
lortstigatioa SaipJioj
Coipaflf
Adrian, fficoiaao
C.C.
Joootoo i MaJoocra, f.C.
larirooiencaJ fagioeers
H.Valeotiao - VSSPA Rtports/Studits 77
12 88/J2/00
fecooical fierier
Coiieoti oo toe fjf't
Draft fieiediaJ
lorestigatioo Etport
lodtrton DereJopieot
Coipaoy
4driao, Vicoigao
IC1IJ) life Srsteii
H.Viltotiao • VS&Pti Reports/Studies 78
69 88/12/00
fecooicaJ Veioraodui
oo loicial fasts
of feasibility Stud?
for Aoderioo Derelopieot
Coipaof
idnao, Kicoigao
C.C.
Joooioo I tfaJootra, f.C.
lorirouiental fogioeers
IT.Valentino - QStPl Rtpons/Studits 79
-------
Pige V>.
07/03/90
DAK
tint
RKORD um - mm ti
otmotmt coma somim sirs
mm.
AI/WOR
Documr tm
152 89/01/00
Rerised
Reiedial Investigation
Report - Volute II
Anderson DereJopient
Coipany
Adnao, tfictijao
C.C.
JoAosoo £ Kaliotra, f.C.
foriroaientaJ i&ylaters
• VSSH Reports/Studies
165 89/01/00
Reriseif
JticdiaJ Investigation
Report - ^oJuie I
Anderson DereJopieut
Coipaof
Adrian, Michigan
C.C.
Joiflson & (TaJootrj, ?.C.
foriroouatai Joyineers
V.Faleotioo - ffSJPA Reports/Studies SI
7J flJ/OJ/flfl
r«cboieal Jterieir
of fJPj Draft
Sfldaojerient Assessieot
Report
Aoderson Derelopieot
Coipaof
Adrian, Kicoiaan
iodaagerieat Aisessient
Orersijnt
Lite Syitnt
tf.faJentino - 1/SfPA Reports/Studies 82
SS/01/00 fecnnieal Reriev
of PRPi
reconicai Meiorandui
on Initial Juki
ot tne feasaoilitf Study
Anderson Derelopient
Coipany
Adrian, Vicniyan
ICAIR Life
USItA
Deports/Studies 8J
69 89/03/00
Quality Assurance
Project Plan
for Phase IV
81 Saiplin; at
Anderson DereJopient
Coipanf
Adrian, Kiciigao
C.C.
Jonoson i Malnotra, P.C.
(nrironiental fngineers
Oaleotioo - I/SSPA Reports/Studies 84
89/03/25
Aiended
Vort Plan/field
Saiplin; Plan
C.C.
Jonnson i Malnotra, f.C.
Jnrironiental Jnjineers
K. Valentino - 1/SiPA Reports/Studies 85
-------
fagc Ho. 14
OJ'OS/90
UCHS/IRAHS PACES DATS
minsmrin nun iiosi - mm n
Aiosssoii DsvtLOPHsir comm somim sits
ADRIAH,
tmt
tor Pbase IV
SI Satpling at
Anderson Dereloptent
Cotpanf
Adrian^ Hicbigan
(Second Rerisionl
AOTBOR
RSCIPISMT
Documr tm
DOCHI1HSW
339 as/07/Ofl
Hail
Retediil larestigttioa
Report • Volute II
Aaderioa Serelopiett
Coipaaj
Adraia, Hicbigaa
C.C.
Jobasoo 4 Kilbotra, f.C.
loriromeatal Sagioeers
If. Valentino • VSSPA Reports/Studies Si
5 89/07/00
fecbDical Reriev
Coiieott on the tBfi
linal Reiedial
Investigation Report
Anderson Dereloptent
Coipanj
Adrian, Kichigan
ICAIR Life Systeti
osm
Reports/Studies 87
7 85/07/00 Rtriev Couents on tbe ICAIR Life Systtts
PRPs Rerised Sndaogeneat
Asseisient Report
Anderson Dereloptent
Cotpany
Adrian, Hicbigan
OSSPA
Reports/Studies 88
.'05 8J/OJ/00
Final
Retedial Inrestigation
Report • Volute I
Anderson Derelopteat
Cotpanj
Adrian, Hicbigan
C.C.
Jobnson i Kilbotra, P.C.
Snriroatental Sagiaeers
H.Valentino - VSSPA Reports/Studies
89
91 89/09/00
Tecbnical tetorandut
on Detailed Analysis
of Reiedial Alternatires
Anderson Dereloptent
Cotpany
Adrian, Kicbigaa
C.C.
Jobnton C Halbotra, P.C.
Inrirontental Ingineers
It. Valentino - OSSPA Reports/Studies
90
-------
07/08/90
PMSS Dm
tins
imiismrm MCORD imi • mm n
umsoi Dtmofmr COUP MI samim sxri
RSCIIIHT
rm
90/02/00 final
fndaoyerient liseisttat
Rtpon for
Anderson DereJopient
Coipany 5u<
Adrian, flicniyan
C.C.
JobntoQ & Kalbotn, f.C,
Jonraoieacai lagiottts
H. FaJeotino - USSPk Reports/Studies 91
294 90/02/00
final
feasibility Stoij
for Anderson OereJopieot
Coipaof
Adraio, Xicoi;ao
C.C.
Joboioo & Halhotn, f.C.
{flrironi«ocai Engineers
- USSPti Reports/Stutits 92
-------
to. i
0116: /SO
emmet mounts inn • mm n
JIDHSOI Dimomir comtr SQHMOID sin
Guidance Docoieoti are available tor review at
QSttl fe^on V-Chiago IL
tint
AppJieatiofl aod (raloatioo Ceoiafe Corporation 89/Oi/QQ
CoflsideratioDs for Jo Sico
Vitrification recinoJojfi
4 frcacieoc Process tor
Destruction and/or Periaoeot
Iiiobiiizatioo of flarardoos
NateriaJs
freatieot f.Kaibotra • CCJt 90/03/12
of Salogtaatti BCs, tCts,
fCts. Bioiins, EDS aod
CcJorinated So]rents
vitb cover sneet
Status of In Situ r.fitzPatridt • fieosafe Corp. 10106/OS
Vitrification fecnnoJoyfi
A freatieot Process for
Destruction and/or
feriaoeot IiiobiJizatioo
vitb cover sheet
letter S.Iiitala - Ctostte 90/06/06
Re: ID Situ
Nitrification fipJoree
frainiog Prograi aod
Nacnine fabrication
Plan
vitb enclosure
119
-------
rage to.
sim
TlflS
uuiisnain mono sumne/om iiosi - mm n
jwmoi osmotmt comir smsim sirs
toauns lor emit, m as mime ir rag
asm mioi v otncss, CBICUO, ULIIOIS.
rm
00/00/00 Sunarf of ADC Ltqoon
Sludge, Clay, and
Grouadvacer SaipJiny
Results
Saipliog Data
88/12/15 Ciroiatojrau
and ijuaatitatioD reports
for the standards used
io the aaaifsis of
Aodersoo Derelopieot
Project
D.Straodberji - CfC, Joe.
F.CiuriJJa - ITSfPJI SaipJiug Data
-------
ff la. 1
OI/vi/90
mom
ACMm GUIDt for tbe AdiioiJtratire Record
smiomtr comir sumim sir;
mm,
Dsnmioi
ADC
ARM
CCJH
CSC, Inc.
/S
IS, lac.
KB!
HOUR
m
m/rs
VSSPK
Anderson Dtrtlofttat
Coipaof
Applicable or Jicleraoc
and Appropriate Standards,
nutations, Criteria,
and fieguireieutJ
C.C.
JODDSOD & Kalbotra, f.C.
Claftoa JarirooieotaJ
ConsuJtaots, Inc.
/easiiiJitf
Life Syttti, Inc.
Hicbitl, Beit tni lieiricb
Departieot
of laturaJ Resources
Potentially
Responsible
tettits
Assurance
Project Plan
Seieiiil Inrestigation/
feasibility Study
United States
forirooieotai
frocectioi) Agency
-------
• • "
••ge Nc>. 1
DRAFT ADMINISTRATIVE RECORD INDEX
ANDERSON DEVELOPMENT COMPANY
ADRIAN, MICHIGAN
:ChE/>'iM«E PAGES DATE TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
5 65/10/06 USEPH Notice Letter asking the Basil Cons:anteios-USEPfl
aaressee if they Mill perform
trie actions necessary to aoate
any releases or threatened
releases of nazaroous
suostances.
J.riuerta-Araerson Develop Correspondence
254 66/02/10 Anderson Development
Company's Feoruary 10,
1986 Response to EPA
Proposal.
6 67/Oc/l? Siimary of resconses of
Anderson Dev. to review
cosiriients on QfiPP for R1/F3.
finoerson Development Conpany UStPA
S.K.Malhotra-Johnson 4
Halhotra
Cc>rre=Dcnaence
Doug Bailotti-tJSEPA Corresponaence
i 87/C7/i5 Kesoonses of PRP to
review osinments of 3/6/37.
t 37/06/00 sucerfura Fact Sneet -
Anderson Deveiopwen:
Cocioany Site.
t s7/0i/0o Review of QAPP
2 at/ Ob/06 News Reiease "Anderson
Develooraent Co. To
Investigate bite
tion".
S.K.nainotra-Jonnson
Nalnotra
UStPfl
Janes
USEC'A
1 87/06/18 News Release JEPft To Ariswer
Questions On Anderson
Deveiooraent Suoerfuna Site".
B 66/05/25 floainistrative Order By
Consent Re: Reoeaui
Investigation Ana
Feasaaihty btucy.
7 w/i>i/CO Hazardous fanning System
Scoring Pacxage.
USEPA
Valflas AdankusHJSEPA
Cy i'ocujsentation secoras ror
Hazard Rankir.a ivsteni.
Paul Bitter - UStPA
Ecology 4 Environment
Doug Ballotti-L!£E?M Corresoonoencs
Fact Sheet
Norman Nieoergang-USEPA Werjoranoura
News Release
News Reiease
ftnoerson Develoonent Co. Pleaaings/Qrsers
USEPft
USEPft
Resorts/Studies
ftewrts/Studies
00/00/Oi) Scooe Of Work for a
Resorts/Studies
-------
rage No.
:)&/28/66
PAGES DAfE TITLE
Remedial Investigation/
FeasabilTty Stuoy.
7 82/07/14 Hazardous Ranking Systes
Scoring Package.
14 82/09/06 Site Inspection Resort.
5 63/02/17 Prelininary Assessment.
66 64/06/04 Reueoial Action Raster
Plan (RAMP).
£2 Bt/ll/17 Site Visit Healtn 4 Safety
Plan.
66 87/02/12 Worn Plan: Remedial
Investigation/
Feasaoihty Stacy.
4 37/Ob/i9 Project Progress Sesort
tl.
2% 67/07/22 Quality Assurance Project
Plan (QfiPP)
1 67/06/04 Project Progress Sewrt
1 67/09/22 Project Progress SEpcrt
1 8V/lO/lb Project Project Seport
t <>.
il 87/11/00 Final Community Relations
Plan.
1 87/11/12 Project Progress Sewrt
15.'
87 87/12/17 Enoansernent Assessaent
Oversignt.
1 67/12/24 Project Progress *ecort
I b.
DRAFT ADMINISTRATIVE RECORD INDEX
ANDERSON DEVELOPMENT COMPANY
ADRIAN, MICHIGAN
AUTHOR
RECIPIENT
J. Angelo - Ecology 4
Environment
Jonn Angelo - Ecology t
Environment
Ton Kocn - Ecology 4
Environment
CHcfi Hill
USEPfl
USEPfl
USEPA
USEPfl
James Huerta-Anoerson Dev. Doug Ballotti-UEEPft
Jaaes rtuerta-Anoerson
Deveiocmen:
USEf'A
Jaaies Muerta-wncerson
Develocment
Doug Bailott:-USEPA
Doug Ballotti - USEPA
Dcug 3ailottHj££PA
Doug Ballotti-JSEhfl
Doug fiallotti-uSEPA
Jacoos Engineering S«uo, Inc. USEPA
Jaoes Huerta - Anderson
Deveicoment
James Huerta-Anaerson
Deveioonent
James rtuerta-Anoerson
Oeveiopraent
Jaaies nuerta-Anoerson
Oevelooraent
DCCURENT TYPE
fteocrts/Studies
Reports/Stuoies
Rsports/Stucies
Reports/Studies
Reports/Studies
fteoorts/Stuoies
Re:orts/£tuc:es
Reoorts/Stuoies
Reports/Studies
Reports/5tac:ss
fiepcrts/Stuoies
Reoorts/Studies
James Huerta-Anoerson
Deveioccent
Doug Ballotti-USEPA Reoorts/Stuaies
Dean Gears -Jacoos Engineering Eva riowarc - UiEPA
Grou
James Muerta-Anaerscn
Develooraent
5 88/01/22 Projecct Progress Reoort Jaaes Huerta-Anderson
Doug Beilotti
Doug Balloni-USEPA
ReX'rts/Stuaies
Reports/Stud les1
Rerorts/Stuoies
-------
jge No.
-"iCh£/h'fift€ PAGES DATE TITLE
* 7.
3 88/02/03 Project Progress Report
* 8.
3 88/03/02 Progress Report *9.
£ 68/04/05 Project Progress Report
* 10.
76 86/04/07 Tecnnical nemorarioura On
Surface Water, Soil find
Sediraent Sampling At
Anderson Development
Company.
78 66/04/07 Tecnnical Memoranda™ On
Residential Well Anfi
Brounawater sampling
At Anaerson Development
Company.
5* 66/04/13 Final Reoort for Site
Water and Mil Samoles
suDraittea between 10/21
and 11/4/87.
DRAFT ADMINISTRATIVE RECORD INDEX
ANDERSON DEVELOPMENT COMPANY
ADRIAN, RICHIGAN
AUTHOR
Development
James Huerta-Anderson
Development
James Huerta-flnflerson Dev.
James Huerta-Anaerson
Development
S.K.Ptalhctra-Jonnson J
Halnotra
S.K.Balhotra-Jonnson 4
Bainotra
Roaert LiecKfiela-Claytcn
Environ.
RECIPIENT
Doug BallottiHJSEPfi
Doug Ballotti-USEPA
Doug Ballotti-USEPA
Doua Ballctti-USSEPA
DOCUi'lENT TYPE
Doug Ballotti - USEPA Reoorts/Studies
Reports/Stuoies
Reports/StudIBS
Resorts/Studies
Resorts/Studies
S.K. Salhotra-Jonnson4?iain Resorts/Stuo195
-------
mimsmrm mm mm • mm n
MDMSOI Dimotmi c0«pA*r sirs
MRIM, WEIGH
mxs PACES om
rim
mi
90/00/00
-Public-Coiient—
letter.*
io response to
a Public Beating
held en
Julr 12, 1990
-bf fuierooj-Parties-
Piiiip-Schutte
USfPA
Correspondence-
5 90/03/2t
Letter
Re.- Conents oo tie
proposed bioreiediatieo/
cbeijcl oiidatioo
treatient process fn
cootaiioaced soils,
sludoes and clay
vitb attacked ceio
Hicbitl (Taleotioo
vsm
Huerta/ffalbotra Correspoodeoce
90/03/30 Letter
Rt: .'.cd-rscn
Derelopient Coipanf
Proposed feasibilitf
Studj- (2/?(!l
Pradf Bofce
KM
K.Faleotino - USE?A Correspondence
90/Wit Letter Hicfcael A. Valentino
Re: And«rs?n Derelopient PSJfA
C:spanjr Site - Rene* of
fr'atibilit}1 Studp lf')r)r
Plan
8. fllaoef - P5EPA Correspondence
PO/04/J7 Letter
Re: fransiittal
of Treatioilitf ftudf
Guidacce Docuient
tficnael A. Paientioo
USEfK
C.C. Jonosoo & Correspondence
Kalootra
31 SH/Oi/Of Letter Stephen C. LiiJtala
Re-. Ic-Situ Nitrification Geosafe Corporation
Trainin; froarai
and tfacnioe. fabrication
Plan
K.Talentino • DSfPA Correspondence
2 90/06/U ISV Applicabilitf
Jaies E. flaosen
H.Faleotino - I7SEPA Correspondence
-------
St. 2
I'90
>.'FmS PACK DATE
rms
MJTBOR
HCORD IRDEI - mm 12
DEmofHEtT comjrr SITE
, KICSICAI
HCIFim
DOCUKERT THE
at Anderson Derelopient Geosafe Corporation
Site
9 90/07/11 Letter Kicbael A. FaJentioo
Re: Andersen Derelopient 1/SfPA
Coipanf Superfund Site
- Selection of ReiediaJ
Action AJteroatire
Various tatties Correspondence
50/07/JJ letter
Ae.- Deaoo.'tratien
of FnsotecD's IfobiJe
freatieot Unit
Kbaliqae A. IToao
Jnsotecn Jo;.
N.falefltioo - VSSPA Correspondence
SO/07/14 tetter
fie: Anderson
Dereiopient Cotpanf Site
AdditiocaJ Aeriev
Coaients to CneiieaJ
Oiidntitn Retetial
Action AJternatire
K.ealeotioo
1/5SPA
JJ.ffuerta - ADC Correspondence
?7 90/01/18 Letter Charles V. Steeoej K.Valtotioo - 0SJPA Correspondence
Re.- Anderson DereJopient KicnaeJ, Best, /rjedricn
Coipany Superfund Sit?
vitn various enclosures
90/07/2t Letter
Re: fectnicaJ issues
raised in the fonaJ
"fiesponsireoess
of toe Record of Decision
fficoael A.
USEPk
FaJentino
C.Steeof - KB/
Correspondence
J5 90/07/27
Letter
Re: Anderson
CereJopieot Coipanf
Ki/rs
Cneiieal Oxidation
festjny
vitn attaciients
Jaies Suerta
Anderson DereJopient
Coipanf
K.FaJentino - tfSfPA Correspondence
90/08/03
Letter
Se-. Anderson
CnarJes r. Sittaej H.FaJeotino • OSJPA Correspondence
Kicoael Best i /riedricn
-------
»-.'. 3
I i IK
nm PAGES cm
JITLE
Derelopient Coepany
-Super-food- Si te -
mimmrm moan nwx - mm n
MOERSOt DEVELOPKEIIT COHtMl SITE
ADRIAN HICHICAI
AUTHOR
RECIPIEIT
Docvmr Tm DOCSOHBER
3 90/08/OS
Letter
Re: Request tor an
tittosieo to
Decnber I, 1990
for tht receipt of
coiieots oo toe
flecord of Decision
(ROD)
Arrid A Satber
Hicbitl, lest
& Itittiieb
S.Otaka •
Correspoodeoce
36 90/tS/OS
Letter
fie.-
rerievs en
Jn-Snu Citrification
atta;oient5
0aJe K. fincos
Ceo5afe Corporation
K.FaJentioo -
Correspondence
9C/OS/11 Cover letter
for the proposed
Bench-ScaJe Ltv
Tesperatore Tberial
Aeration TeconoJoof
TreatibiJitr Test
A. Satner
l, Beit
t frieiricb
S.Otaka - QSEPl
Correspoodeoce
90/OS/27
letter
Re-, fieguest for
fitension of
Public Conent
Period
K. Faleotioo
(TSfPA
J.fluerta - ADC
Correspondence
90/08/31
Letter
Re: facsiiile
transiitted on
August 31, 1990
Kichael A. FaJentino
VSSPA
J.luerta - ADC
Correspondence
90/09/00 Letter
Re-. Signioa of POD
Valdai F. Adaihs
1/SfPA
J.DiogelJ -
Cofloressiao
Correspondence
2 90/09/05 Letter Jaies R. floerta K.Faientino - (FSfPA Correspondence
Re.- Aodersoo Derelopient Anderson CereJopieot
Coipaof Site RJ/fS Coipaof
-------
.';,'.
•if
mono imi • mm n
MDERSO* DEVSLOPmr COHPAff SITS
ADRIAJf, KICBISM
PAGES am
•rim
AUTHOR
RSCIPIEM
DOCUKEKT TIPS
Project Progress
Report He. It
2 Jfl/OJ/Jl
Letter
Re: State
Concurrence
on 151'
Jaies fructjn
fl.Jiederyanj • 0SSPA Correspondence
4 ?0/0?/12
Letter
Re.- request to defer
its Record of Decision
Jo/in D. DinaelJ
Conyress of tie
United States
• OSSPA Correspondence
J0/05/J7 Letter
Re.- Anderson
DereJopient Subiittal?'
vitb attacbient
(Verb PJan to Conduct
a Pencb ScaJe
Treatability
Stud}-)
Jaies fluerta
Anderson Dereiopieot
Coipanf
K.FaJeotino • PSKPJ Correspondence
?0/07/j:
franscipts
of CraJ Conents
PniJip Scnutte
vsm
Keetin; Votes
j CO/QOfCQ
Keio
Re: ISV rest
vitb enclosures
Penbertfif
FeDoertnf JlctroieJt
International, Inc.
C.Sveenef - USEPk Jfeiorandui
2 .'0/07/12 Kero DaJe 5.
Re: Ifater Dirision Reriev USEPK
of tne Record of Decision
for tne Anderson
DereJopient
Site
OJlricb - VSEPk (feioraodui
J M/07/16
Keio:
Rerie» of tbe Draft
Record of Decision
fcr tne Anderson
Derelopieut Site
Juan-Mai fran
USEPK
N.raJentino - tTSKPA Neiorandui
-------
.V;.
• an
muismrm RECORD imi - mm n
DMiopmr co«A»r sm
ADSIAJI, fTJCHIGAI
PAWS WK
Docomr
DOCHOKIEP.
5 -worm
Ke«o -
R«: Rerieir
Kart C.Kectse
PSEPJI
of 'Anderson Derelopieot
Coepanf Preliiioarf
Oxidation resting'
and General for* Plan
- USEPH Heioraodui
50/03/05 JTeic
R«: recnnical
Renew of rest Data
and rreataoilj'tf rest
Proposals presented
07 Anderson flerelopient
Co.
Kitk Htckts
K.Valentino - {1SBPA Neioraodai
2 90/OS/U Heio
Re: Reeedf
Delegation Report
Ton t. CJaf
F.Adailtas • 05§PA Neiorandui
1 "0/08/22 Keio Kar* Keetes
Re: Oiidatjon of WBOCA USEtK
K.Falentino - (7SEFA Meioraodui
Neio
Se.- Response
to a request coocernioy
toe Anderson 0erelopient
Coipanf
vitn attacbient
Pei-/ting flurst
IISEM
K.FaJentino - USSPA Neiorandui
It OO/flO/Ofl If or* Plan Doiovo
To Condoct a Pencn Scale
rreatafciJj'tf Study
/or Anderson Derelcpieot
Coipanf Lagoon
Reports/Studies
£5 89/tn/OC
AJternatires Arrap
/or
Anderson DereJepient
Coipanf
Jaiej R. fiaerta
Anderson Oerelopieot
Coipanf
K.ralentino - PSJPA Reports/Studies
AJternatires Array
Jaies R. Suerta
Jf.Falentioo - OS8PA Reports/Stadies
-------
He.
: 'IFMS PACES DATE
Tins
fur
Anderson Derelcpient
Coipany
mow msi • UPDM n
MDERSM DSVtLOPmt CCKPKHJ SITS
mm.
norm
katttsco Dtvtloptiat
Ccipanf
Documr TYPE
DOCHlimF.
?0/0£/05 Anderson Derelopient
Corpanf 5ite
RI/FS
Project Progress
Report »o. J5
vith carer letter
Jaies R. Rutrta
Anderjon Oerejopieot
Coipanf
Jf.Kalentino - VSEPA Reports/Studies
90/03/03 Anderson
Derelopient Coipany
Site RI/FS
Project Progress
Report Ho. J7
corsr letter
Jaies ft. ffuerta
Anderson Derelopient
Coipanf
K.Falentinfl
Reports/Studies
Record of decision
KIM
Reports/Stadies
-------
Paje Ho. l
05/21/90
GUIDS far tbe Jdijoistmm Rtccrd
Dtvtiotmr com.n smsrm sits
mm, WEIGH*
ADC
emu
Anderson ••Derclopito-t -
Coipaoy
Coipretieosirc
Eavirooieotil Sespoase,
Coipeosatioo, and
liability Jlcc
of
JfilS
iBterqrtttt
Risk lofonacioo
ISV
KBI
KDUR
osm
PR?
KI.'IS
ROD
USSPA
Jo-Sicu Vit
Hicbatl, Best and Jittricb
Michigan Dtpartieot
of Hatoral Jtesour:es
Office
of Solid Vasti
and Stergeocf
Response
foteatiallj
Responsible
Perties
Quality Assuranct
Project Plan
Reiednl lartstigatioo/
feasibility Study
Aecord of Decisioo
l/ojced States
Sariroateotal
Protection
------- |