PB95-964103
EPA/ROD/R05-95/275
February 1996
EPA Superfund
Record of Decision:
Albion-Sheridan Township
Landfill Site, Albion, MI
3/28/1995
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DECLARATION
SELECTED REMEDIAL ALTERNATIVE
FOR THE
ALBION-SHERIDAN TOWNSHIP LANDFILL SITE
Albion, Michigan
Statement of Basis and Purpose
This decision document presents the selected remedial action and
contingent remedial action for the Albion-Sheridan Township
Landfill Site, Albion, Michigan, which were chosen in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1.980, as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986, and, to the
extent practicable, the National.Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the
administrative record for this. Site. The State of Michigan
concurs with this decision.
Assessment of the Site . .
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action in
this Record of Decision (ROD), may present an imminent and
'substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
The purpose of this remedy is to reduce the risks associated with
exposure to the contaminated materials on-site and to eliminate
or reduce migration of contaminants to the groundwater, and to
reduce the risks associated with arsenic contamination in the
groundwater. The remedy includes treatment of principal threat
waste, but other contaminants will remain on-site above health-
based levels; Human health and the environment: will be protected
from these remaining contaminants by capping the wastes.
The major components of the selected remedy -include:
Removal and off-site treatment and disposal of drums
which contain hazardous and liquid wastes from Test Pit
Area #9 and other drums encountered during grading of
the landfill surface;
Construction of a solid waste landfill cover (cap)
which makes use of a Flexible Membrane Liner (FML) over
tthe entire landfill mass,-
Use of institutional controls on landfill property to
limit both land and groundwater use and on adjacent
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property co limit only groundwater use until the clean-
up standard is attained (estimated at 14 years) ,-
Installation of an acti"- landfill gas collection
system including flaring to treat the off -gas frrrr, zhe
landfill, unless U.S. EPA approves passive ventir.g
following design studies;
Monitoring of groundwater to ensure effectiveness of
the remedial action in lowering' the arsenic .
concentration in groundwater through natural oxidation.
The following contingent remedy for groundwater treatment is also
selected for the site:
Treatment of groundwater by in-situ oxidation if, five
•years after landfill cap installation, the arsenic
contamination in the groundwater is not declining at
the specified rate or if contamination threatens
residential wells. . .
Statutory Determinations
The selected remedy and the contingent remedy for groundwater are
both protective of human health and the environment, comply with
Federal and State requirements that "are legally applicable or
relevant and appropriate to the remedial action, and are cost
effective. The selected • remedy and the contingent remedy both
utilize permanent solutions and alternative treatment or resource
recovery technologies to the maximum extent practicable. Both
remedies also satisfy the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a.
. principal element. . . ^
A review will be conducted within five years after commencement of
;the remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment because
this remedy will result in hazardous substances remaining on site
above health-based levels.
State Concurrence
The State of Michigan is in agreement with the selected remedy and
the contingent remedy for this site and has provided U.S. EPA with
a letter of concurrence.
Valdas . V . Adamkus . Data
Regional Administrator
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STATE OF MICHIGAN
NATURAL RSSOURC2S
DEPARTMENT OP NATURAL RESOURCES
STBVBM* T MASON VUIIOINO. fC acx 33031. UNflMO Ml
ROLAMO HMMU. OlMacer
March 24, 1395
Mr. Valdas V. Adamkus, R-19J
Administrator, Region 5
U.S. Environmental Protection Agency.
77 West Jackson Boulevard •
Chicago, Illinois 60604-3590
Dear Mr. Adarakus:
The Michigan Department of Natural Resources (MDNR), on behalf of the State of
Michigan, ius reviewed the draft Record of Decision (ROD) for the Albion-
Shandan Township Landfill Super fund site in Albion* Calhoun County, Michigan.
which we received on February S, 199S. !
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Mr. Valdas V. Adankus
-2-
Marcn 24, 1995
At a minimum, this remedy *i 11. achieve the suostantive reuuinsmtmu uf 4
Type C cleanup under the Michican Environmental Response Act (MERA), 1982
PA 307, as amended".
the cleanup standards
time to ensure that the stanaards continue to oe .net. Addlt:onal monitoring.
or remedial actions may be necessary in accordance: with R 299.5719(1) of the
MERA* in order to assure the effectiveness and integrity of the remedial action
beyond tnat time. ;
,
However, :ne ROD only requires long-tern monitoring until
are attained, alas five years of monitoring beyond that
We look forward to the implementation of this remedy for tht Albion-Sheridan.
Township Landfill Superfuno site. If you have any questions, please reel free
to contact Mr. William Bracford. Chief, Superfund. Section, Environmental
Response Division, at 517-373-8815, or you nay coatact me.
Sincerely,.,
Russell J. Hardino
Deputy Director
517-373-7917
cc: *r. James Maylca, EPA
Ms. Leah Evison, EPA
Mr. Alan J. Howard, HOHR
Mr. HiTHaai Bradford, MONR
Ms. L'.sa Sumnerfleld, MOHR
Mr. Janes Myers, MONR/Albi on-Sheridan
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TABLE OF CONTENTS
A. Site Location • 1
3 . Site History .1
C. Highlights of Community Participation. 2
D. Summary of Current Site Condition • 2
S. Summary of Site Risks 3
?. Scope of the Remedy 12
G. Description of Alternatives : 12
H. Summary of Comparative Analysis of Alternatives 17
I. The Selected Remedy 23
J. Documentation of Significant Changes 28
X. Statutory Determinations ; 29
L. Summary 36
M. Responsiveness Summary 36
N. Glossary. .48
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
A. SITE LOCATION AMD DESCRIPTION
The Albion-Sheridan Township Landfill site (the "site") is an
inactive landfill located at 29975 East Erie Road approximately
one mile east -of Albion, Michigan on the eastern edge of Calhoun
County. The landfill is approximately 18 acres in area and its
boundaries are shown in Figure 1.
B. SITB HISTORY
From 1966 to 1981, the landfill was privately owned and operated
by Mr. Gordon Stevick. The landfill accepted municipal refuse
and industrial wastes from households and industries in the City
of. Albion and nearby townships. In the early 1970s, the Michigan'
Department of Natural Resources (MDNR) approved the landfill to -
accept metal plating sludges. Other materials, such as paint
wastes and thinners, oil and grease, and dust, sand, and dirt
containing fly ash and casting sand were also disposed of at the
site. In 1980, the MDNR collected and analyzed samples of non-
containerized sludges that were being disposed at the site. The
sludges contained heavy metals, including chromium (250,000 •
mg/kg), zinc (150,000 mg/kg), nickel (1,000 mg/kg) and lead (280
trig/kg) . The sludges remain buried at the site. The landfill
ceased operation in.1981.
In 1986, a U.S. EPA Field Investigation Team .(FIT) contractor,
performed a Site Screening Inspection for purposes of scoring the
gite per the Hazard Ranking System (HRS). In 1988, U.S. EPA
proposed the Albion-Sheridan Township Landfill Site for inclusion
on the National Priorities List (NPL), and in 1989, the Albion-
Sheridan Township Landfill Site was officially placed'on the NPL
and designated a Superfund site.
During 1988 and 1989, a U.S. EPA Technical Assistance Team
conducted site inspections and observed surface debris on the
landfill, including drums which appeared to contain grease and
paint waste. Sampling showed that some drums contained wastes
classified as hazardous under RCRA because they were toxic and
ignitable. Some samples contained VOCs, including ethylbenzene,
toluene, tetrachloroethylene, 1,1,1-trichloroethane, and xylene.
As a result of its findings up to 1989, U.S. EPA determined that
a removal action was appropriate. On March 19, 1990, U.S. EPA
.issued a Unilateral Administrative Order to five potentially
responsible parties (PRPs). On May 3, 1990, the UAO was amended
to delete one of the parties.
Later in 1990, two PRPs performed the removal. They removed
approximately 46 drums.from the surface of the landfill. Twenty-
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two of these were overpacked and sent to an off-site facility for
incineration. The remaining 24 drums were crushed and sent to a
Type 2 landfill.
.In 1991, the Albion-Sheridan Township Landfill Site was selected
as a demonstration site for the presumptive remedy for CERCLA
municipal landfill sites, one of the tools, of acceleration within
the Superfund Accelerated Clean-up Model (SACM). OSWER
Directives No. 9355.3-11 "Conducting Remedial
Investigations/Feasibility Studies for CERCLA Municipal Landfill
Sites" and No. 9355.0-49FS "Presumptive Remedy for CERCLA
Municipal Landfill Sites" establish containment as the
presumptive remedy for CERCLA municipal landfills and provide
guidance for streamlining the RI/FS process at these sites.
On June 3, 1991, U.S. EPA mailed special notice letters to six
PRPs to begin negotiations for conducting a remedial
investigation/feasibility study (RI/FS). No good faith offer was
submitted by the deadline, and as a result, U.;S. EPA performed .
the RI/FS using Superfund money.
U.S. EPA initiated the Remedial Investigation/ Feasibility Study
(RI/FS) in January 1992. The work was performed by a contractor
under the Alternative Remedial Contract Strategy (ARCS). U.S.
EPA placed the completed reports in the Administrative Record in
September 1994.
C. COMMUNITY PARTICIPATION
The Responsiveness Summary in Section L discusses the involvement
of the community during the RI/FS and remedy selection process
and shows that the public participation requirements of CERCLA
Sections 113(k) (2) (i-v) and 117 have been met at this site.. The
decision is based on the Administrative Record.
O. SUMMARY OF CURRENT SZTB CONDITIONS
The RI Report in the Administrative Record documents'the methods
and results of the remedial investigation at the Site and
additional details concerning'site conditions may be found in
that document. A summary of U.S. EPA's findings is given below.
1. Adjacent Land U««
A combination of residential, agricultural, commercial, and
industrial properties surrounds the Albion-Sheridan Township
Landfill. One residence .is located immediately adjacent to the
landfill to the south and five additional residences are located
approximately 1000. to 1500 feet southwest of the landfill along
East Erie Road. An active railroad track borders East Erie Road
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Co che south of the landfill, and beyond Che railroad Cracks lies
che Norch Branch of che Kalamazoo River. South of che river is
agriculcural land.
The sice does not fall wichin Che flood plain of Che river.
There are wetlands south of the site adjacent to the river, which
are not expected to be impacted by site activities.
Amberton Village housing development is Located adjacent to the
site on the east side, with the closest residences approximately
500 feet from the landfill. Several residences and commercial
businesses are located along Michigan Avenue approximately 500
feet north of the site. Immediately west of the site is
undeveloped land formerly used for agriculture. Orchard Knoll
subdivision is located approximately 1,500 feet northwest of the
landfill. Approximately 2,000 feet northwest of. the site is a
landfill associated with Brooks Foundry. Approximately one mile
west is the city of Albion, with a population of 10,066 according
to the 1990 census. This figure does not include approximately
1,700 students enrolled at Albion College in the City of Albion.
2. Landfill
The landfill is currently covered with 1 to 4 feet of silty sand
and some gravel. Cover thickness averages approximately 2 feec.
Refuse is present within the cover material at some locations,
including sludge, glass fragments and insulation. The landfill
surface.is currently subsiding at rates of 0.04 feet to 0.13 feet
per year. Refuse material is scattered at the ground surface
throughout, the landfill, particularly on slopes. This material
includes metal, plastic, concrete, asphalt, 55-gallon drums,
wood, tires,.a storage tank, and a junk crane.
Surface geophysical data indicate that the landfill contains
considerable metallic debris, consistent with what one would
expect of disposal practices associated with a municipal landfill
which accepted a variety of industrial wastes. Test pitting
conducted by the MDNR uncovered one area of concentrated drum
disposal, designated Test Pit Area 9 (TP-9), where an estimated
200 to 400; drums are present. MDNR test results show that some
of the drums contain liquid and solid wastes and suspected paint
sludges, including up to 2.7 ppm arsenic, 730,000 ppm 1,2,4-
trimethyl benzene, 40,000 ppm m/p-xylene, 6,500 ppm acetone and
2,400 ppm aluminum. Test pitting results are summarized in a
report entitled Technical Memorandum No. 1. prepared by ABB
Environmental Services, Inc., dated September 14, 1994, which is
included in the Administrative Record.
The landfill ranges from 16 to 35 feet in thickness. During
drilling of wells, U.S. EPA encountered refuse which was
interlayered with medium to fine sand. The refuse included
paper, cardboard, plastic, various metals, cloth, newsprint,
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rubber, leather, wood, glass, suspected foundry sand, styrofoam,
and purple and white crystalline material.
U.S. EPA encountered landfill gases during installation of wells
and subsidence monuments on the landfill, including some VOCs at
concentrations greater than 10,000 ppm. Subsurface samples
contained up to 1,500 ppm VOCs. Additional information regarding
landfill gases may be found in Section 3 of the RI.
Samples of landfill waste from borings contained numerous
contaminants, including 10 VOCs, 19 semi-volatile organic
compounds (SVOCs), and 11 pesticides/PCBs. The most concentrated
contaminant was 4-Methyl phenol at 15 mg/kg. Several -inorganic
substances were present above background levels in subsurface
soils, including antimony, arsenic, chromium, copper, lead,'
mercury, and zinc. The highest concentrations include lead at
208 mg/kg, arsenic at 13.1 mg/kg and chromium at 13.5 mg/kg. One
sample was suitable for the TCLP metals analysis. Results.
indicate the presence of barium and lead in the TCLP leachate, *.
both below hazardous waste levels.
3. Groxindwmter
Groundwater flows beneath the site in the unconsolidated glacial
sediments and the Marshall Formation sandstone. The top of the
water table appears to have only minimal contact with .the waste
in the landfill. The landfill is dug into a series of
unconsolidated sediments (sand, gravel, silt and clay) which
ranges in thickness at the site between 20 and 50 feet.
Groundwater in these unconsolidated sediments is in communication
with the Marshall Formation bedrock. The upper 5 to 25 feet of
the Marshall Formation is highly weathered and fractured.
Groundwater flows fastest through a fractured, but less highly
weathered zone just below that depth.
Groundwater flows generally to the west-southwest beneath the
landfill and curves to the south.near the North Branch of the
Kalamazoo River (Figure 2) . A leachate plume in the groundwater
emanates from the southwest side of the landfill. Data from a
geophysical traverse located south of the river (500 feet south
of the landfill) did not indicate any groundwater contamination
south of the river. Flow rates in the unconsolidated sediments
average 106 feet/year and in the most conductive shallow bedrock
average 45 feet/year. Vertical migration of shallow groundwater
is generally downward beneath the landfill and upward south of
the landfill near the river.
Approximately 10 residential and business wells are located
within 2000 feet of the site, including two wells which serve the
Amberton Village subdivision. Where well depth is known,
'residents near the site obtain groundwater from the Marshall
Formation at depths between 70 and 350 feet. Three City of
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Albion municipal wells are located approximately one mile west of
the site and also obtain water from the Marshall Formation, as do
other residences, businesses and industries in the region.
In October 1992, U.S. EPA sampled groundwater from 4 upgradient
and 6'downgradient residential wells near the site. No site-
related constituents were detected. Bis(2-ethyl hexyl)phthalate,
a component of PVC piping, was detected at an estimated
concentration of 1 ug/1 in one upgradient residential well.
There is no Federal Maximum Contaminant Level (MCL) for this
compound, but the health-based clean-up standard used by the
State of Michigan for this compound is 2.5 ug/1. The
termiticide,i heptachlor, was detected in 2 downgradient and 1
upgradient residential wells, at .concentrations of 0.01 to 0.02
ug/1, well below the MCL of 0.4 ug/1. Numerous inorganic
substances were detected at comparable levels in upgradient and
downgradient residential wells, including naturally-occurring
arsenic at"1-2 ug/1. None exceed MCLs arid none are attributed to
the landfill. A summary of constituents detected in residential-
well sampling may be found in Table 39 of the RI.
U.S. EPA installed a total of 31 monitoring wells at the site.
Sampling results indicate that contaminants from the landfill
have impacted ground water due to percolation of landfill
leachate. Many monitoring wells had groundwater with contaminant
exceedances of Michigan Admin. Code R. 299.5709 (Act 307 Type B)
levels- and four monitoring wells showed groundwater impact above
MCLs.
A leachate plume extends southwest of the landfill for at least
900 feet (Pigur* 3} and extends vertically to a depth of
approximately 45 feet below the water table. The major portion
of the plume appears to be discharging to the North Branch of the
Kalamazoo River, but does not result in loading concentrations
above Michigan Admin. Code R. 57 criteria. A summary of
constituents detected in monitoring well samples may be found in
Table 28 of the RI.
In the unconsolidated aquifer, U.S. EPA detected several organic
and inorganic constituents; two constituents, 1,2-dibromo-3-
chloropropane and antimony, were detected at levels above the
MCL, in one well each. In the bedrock aquifer, U.S. EPA detected
a number of organic and inorganic constituents above background
levels. Vinyl chloride was detected at the MCL in one well and
detected at one additional well.
The only constituent which exceeded MCLs in the bedrock aquifer
was arsenic. Arsenic exceeded the MCL at one shallow bedrock
well, with a high of 126 ug/1 and was detected at lower levels in
27 additional wells installed in the unconsolidated sediments and
the shallow bedrock. This pattern of contamination indicates
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chat the elevated arsenic levels are caused by'the landfill
;Figure 4).
As described in the RI report for the site, U.S. EPA attributes
the occurrence of arsenic in groundwater at the site both to
release of arsenic from landfill wastes and to release from the
Marshall Formation bedrock beneath the site. U.S. EPA found
arsenic in samples of landfill wastes, but- the concentrations
were not significantly higher than that found in background
subsurface soils near the site. However, during test pitting,
the MDNR found wastes containing up to 2.7 mg/kg arsenic in
deteriorated drums at Test Pit Area No. 9. These wastes and
other unknown buried wastes could be a source of arsenic
contamination in groundwater dowhgradient,of the site.
U.S. EPA attributes arsenic in groundwater at the site mainly to
release of arsenic naturally present in the Marshall Sandstone
beneath the site and possibly from the glacial sediments (Saginaw
lobe sands) overlying the bedrock. Borings into the Marshall
Sandstone beneath the site show that in addition to sandstone, it
contains coal, shale, and pyrite (commonly associated with
arsenopyrite), all of which can contain arsenic. These natural
sources of arsenic are present in the Marshall Sandstone in other
areas as well, and release small amounts of arsenic to
groundwater under natural conditions. The median arsenic
concentration in groundwater from the Marshall Sandstone
regionally is 2 ug/1. Wells immediately upgradient of this site
contain up to 1.4 ug/1 arsenic. Regionally, the sandy soil of
the Saginaw glacial lobe which overlies the bedrock at this site
contains an average of 2.6 mg/kg arsenic and may be an additional
source of arsenic in groundwater at this site.
Assuming relatively uniform physical properties of the soil and
bedrock,-the primary factors affecting release of arsenic from
bedrock or uncons.olidated sediments are the geochemical
conditions measured by pH (acidity) and Eh (oxidation-reduction
potential, discussed below). These factors have been studied
extensively in relation to. arsenic release to groundwater. As
cited in Section 4 of the RI Report, studies show that arsenic is
released.to groundwater-when pH is high (greater than 8.0) or
when Eh is low (under reducing conditions). ("Eh" is a measure
of oxidation-reduction potential. Reduction is a chemical
reaction in which an atom or molecule gains electrons, a process
which is enhanced by the absence of oxidants like oxygen.)
U.S. EPA's investigation showed that only one groundwater sample
at the site had a pH greater than 8, so pH is not the major
factor controlling arsenic release at this site. In contrast,
the monitoring wells in the arsenic plume showed low Eh .or
reducing conditions (as indicated by the presence of ammonia),
while those upgradient of the landfill and outside of the arsenic
plume showed higher Eh or oxidizing conditions.
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As is common at uncapped landfills, water percolating through
landfill wastes at this site becomes reduced by -he chemical and
biological degradation on-going in the landfill. As this
.reducing groundwater moves through the rock beneath the landfill,.
it causes the rock to release arsenic into solution. As the
groundwater flows farther away from the landfill, the effect of
the landfill is lessened and the water becomes more oxidized.
The monitoring wells farthest from the landfill showed mor
oxidized conditions and very low arsenic.concentrations. . .-
result is consistent with the hypothesis that groundwater has
reached its natural level of oxidation and arsenic concentrations
have dropped to naturally occurring background levels by the time
it reaches the residential wells farther down-gradient.
4. Surface Soils
A table summarizing constituents detected in surface soils may be
found in Table 26 of the RI. Although background concentrations.
are typically established for naturally-occurring compounds only"
historical industrial and agricultural activities near this site
resulted in background occurrences of organic compounds as well.
Compounds detected above background on the surface of the
landfill include two volatile organic compounds (acetone and
xylene) and numerous inorganics, including lead at 160 mg/kg,
chromium at 63 mg/kg and arsenic at 52 mg/kg.
In surface soils adjacent to the landfill, several semi-volatile
organic compounds and inorganic constituents were detected at
levels slightly above background. These include lead at
78 mg/kg, chromium at 21 mg/kg and arsenic at 11 mg/kg.
5. Surface Water and Sediments
A summary of surface water detections from the North Branch of
the Kalamazoo River is presented in Table 41 of the RI. No
organic compounds were present at levels exceeding their
respective background levels and federal water quality standards.
The chromium concentration in one filtered river water sample
exceeded both the background concentration and the federal water
quality standard; however the detection is questionable since the
corresponding unf iltered sample did not contain any detectable
quantity of chromium.
Results of a groundwater loading model show that contaminants
detected in groundwater near the river will not result in surface
water concentrations above State of Michigan or Federal surface
water criteria.
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E. SUMMARY OP SITE RISKS (See Glossary for definitions of
terms used in this section)
When it established a presumptive remedy for containment of
municipal landfills, U.S. EPA was reacting -to past experience
that the heterogeneity and volume of these landfill wastes
generally make treatment impracticable and capping essential.
(See Presumptive Remedy for CERCLA Municipal Landfill Sites,
OSWER Directive 9355.0-49FS, September 1993.) The; Albion-
Sheridan Township Landfill contains municipal waste and a wide
variety of industrial wastes, for which protection against direct
contact is essential for human health. Local government records
and other documents indicate that the landfill accepted metal
plating sludges, paint wastes and thinners, oil and grease, and
dust, sand, and dirt containing fly ash and casting sand, in
addition to other industrial wastes. Because of the known danger
of direct contact, ingestion, and inhalation of these wastes, the
presumptive remedy risk assessment assumes that the landfill will
be properly capped and restricted from public access. Therefore,.
pursuant to this guidance, no risk assessment was performed for "
the landfill source itself, since any risk will.be reduced to
acceptable levels through proper capping (see OSWER Directive
9355.0-49FS, cited above).
Following the presumptive remedy guidance for municipal
landfills, a numerical risk assessment was performed only for
off-site media at the Albion-Sheridan Township Landfill Site,
i.e., groundwater, off-site soils, surface water and.sediments.
The risk assessment is documented in the Presumptive Remedy
Baseline Risk Assessment Report ("Risk Assessment Report"), which
is found in the Administrative Record. The risk assessment
determines actual or potential carcinogenic risks and/or toxic
effects the chemical contaminants at the site pose,using a four
step process. The four step process includes: contaminant
identification, exposure assessment, risk characterization, and
health effects assessment. As explained below, many contaminants
were identified as potential contaminants of concern at.this.site
and subjected to a numerical risk analysis, but only a few,
principally arsenic, were found to cause unacceptable risks to
human health or the environment.
1. Contaminant Identification
The.levels of contamination found in different media at the Site
can be found in Section 4 of the RI Report. Chemicals of
potential concern are generally selected for numerical risk
analysis based on their toxicities, level of concentration and
wide spread occurrence. At the Albion-Sheridan Township Landfill
Site, risk calculations were also done for contaminants found at
elevated levels at isolated locations and not widespread. The
chemicals of potential concern are listed below.in Tabl« 1 and
discussed in Section 3 of the Risk Assessment Report.
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For groundwater, 18 chemicals of potential concern (including
arsenic) were, identified for detailed risk analysis, including
all of those which exceeded MCLs or Michigan Admin. Code R.
299.5709 (Act 307 Type B) health based levels and background
levels. For off-site soils, 19 chemicals of potential concern
(including arsenic), were identified which exceeded background
soil levels. For' residential wells, 2 chemicals of potential
concern were identified (heptachlor and selenium) . Three .
chemicals of potential concern were identified for surface water
(carbon disulfide and two phthalate compounds). The Risk
Assessment identified 22 chemicals of potential concern in river
or wetland sediments (including arsenic).
2. Exposure Assessment
The risk assessment examined potential off-site pathways of
concern to human health for the area surrounding the immediate
site property. Because the area land use is expected to remain •__
mixed, current and future land-use scenarios were considered to
be the same.
The following major pathways were selected for detailed
.evaluation:
Ingestion and dermal contact with chemicals in
groundwater;
Incidental ingestion and dermal contact with chemicals
in off-site surface soils;
Incidental ingestion of and dermal contact with
chemicals in surface water;
Incidental ingestion and dermal contact with sediments.
3. Risk Characterization (see glossary for a discussion of
risk .'terms used in'this section)
For each potential human receptor, site-specific contaminants
from all relevant routes of exposure were evaluated. Both non-
carcinogenic health effects and carcinogenic risks were
estimated. As discussed below, non-carcinogenic health effects
exceed a hazard index of 1.0 for arsenic, and to a lesser degree,
thallium and antimony. Carcinogenic risk exceeds U.S. EPA's risk
range for arsenic and to a lesser degree, 1,2-dibromo-3-
chloropropane.
a. Non-Carcinogenic Health Ricks
The hazard index for humans interacting with the Site exceed the
acceptable hazard, index of 1.0, as shown in Table 2. For
ingestion and dermal contact with the groundwater from the
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10
shallow bedrock near the landfill, the hazard index values are
approximately 12 for adults and 54 for children, principally
because of the .concentration of arsenic, and to a lesser amount,
thallium and antimony. The hazard index for shallow bedrock for
arsenic alone also significantly exceeds 1. Thallium was
detected, in only two groundwater samples, both at a concentration
below the MCL. Antimony was detected twice at one location, both
times at levels slightly above the detection limit and above the
MCL. Analysis of a duplicate of one sample did not confirm .the
occurrence of antimony. Because their occurrence is extremely
limited and, in the case of thallium, is below the MCL, U.S. EPA
does not think the site poses unacceptable health risks from
thallium and antimony. .
All other off-site pathways resulted in hazard indices less than
1, as summarized in Table 2.
*
As discussed above, the risk of contact with the current landfill
surface was not quantified because of the use of the presumptive".
remedy pursuant to OSWER Directive .9355.0-49FS, cited above.
However, U.S. EPA expects that the hazard index for human contact
with wastes present in the landfill could exceed 1, especially if
wastes such as those sampled by the MDNR in 1980 (see Section B
of this ROD) were.exposed.
b. Carcinogenic Health Risks
The potential excess lifetime cancer risk posed by the Site
exceeds the acceptable ris"k range of 1 X 10"* to 1 X 10"s for
carcinogens from the future use of contaminated groundwater near
the landfill. Ingestion and dermal contact with groundwater from
the unconsolidated sediments and shallow bedrock aquifer in this
area present, total carcinogenic risks in the range of 2,4 X 10"*
to 2.1 X 10"3. The concentration of arsenic inj the shallow
bedrock aquifer and 1,2-dibromo-3-chloropropane in one sample of
the unconsolidated sediment aquifer result in an exceedance of
the one-in-ten thousand risk level. It should be noted that 1,2-
dibromo-3-chloropropane was only detected in one sample. Natural
oxidation of the contaminated groundwater in the shallow.portion
of the aquifer is expected to reduce the excess cancer risk from
exposure to arsenic in the groundwater to a level below the MCL
(see discussion in Section G of this ROD).
All other off-site pathways resulted in carcinogenic risks within
or below U.S. EPA's acceptable risk range (Table 2).
The carcinogenic risk of contact with the current landfill
surface was not quantified pursuant to the presumptive remedy
guidance on municipal landfills. However, as with non-
carcinogenic risk from the landfill, U.S. EPA expects that
carcinogenic risks from contact with landfill wastes could also
exceed the acceptable risk range of 10'4 to 10's.
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c. Environmental Risks
U.S. EPA conducted a preliminary ecological risk assessment to
characterize the biological resources at the Site and adjacent
habitats, and identify actual and potential impacts to these
resources associated with releases of hazardous substances from
the Site. While several contaminants were detected sporadically
at low concentrations in the wetland and river surface water and
sediment, the data suggest that the Albion-Sheridan Township
Landfill is not currently a source of any significant effect on
ecological receptors. The ecological risk assessment is found in
Appendix C of the. Risk Assessment.
4. Human Health. Effect* of Arsenic Ingest ion
The information presented here is from the Agency for Toxic
Substances and Disease Regis.try (ATSDR) Document No. TP-92/02
"Toxicological Profile for Arsenic", April 1993, which is part o£
the Administrative Record for this site. Only ingestion effects
of arsenic are summarized below, as this is the pathway most
applicable to this site.- This discussion also emphasizes doses
of arsenic at concentrations similar to those present at this
site.
a. Non-carcinogenic effects
Long-term ingestion of low levels of arsenic may cause
cardiovascular, gastrointestinal, hematological, hepatic (liver) ,
dermal/ and neurological effects. These may include irritation
of stomach and intestines, decreased production of red and white
blood cells, abnormal hearth rhythm, blood-vessel damage, and
impaired nerve function.
The single most characteristic effect of long-term exposure to
arsenic is a pattern of skin changes, including a darkening of
the skin and the appearance of small corns or warts on the palms,
soles and torso. While these skin changes are not considered to
be a health concern in their own right, a small number of the
corns ultimately may develop into skin cancer.
For non-carcinogenic effects, the ATSDR estimates the lowest
observed adverse effect level (LOAEL) for chronic ingestion of
arsenic as about 0.014 mg/kg/day, which roughly corresponds to. a
groundwater concentration of 0.11 to 0.51 mg/1 arsenic, depending
on body weight. The highest concentration of arsenic at this
site is 0.126 mg/1, which is within this range.
b. Carcinogenic effects
The ATSDR reports a large number of studies showing that
ingestion of arsenic increases the risk of developing skin
cancer, most commonly squamous cell carcinomas which.appear to
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develop from the wares or corns described above. Ingestion of
arsenic has also been reported to increase the risk of cancer in
the liver, bladder, kidneys and lungs. U.S. EPA classifies
arsenic as a human carcinogen.
The ATSDR reports that the lowest long-term dose of arsenic known
to cause human cancer is about 0.009 mg/kg/day, which roughly
corresponds to a groundwater concentration of 0.10 to 0.82 mg/1
arsenic-, depending on body weight. The highest concentration of
arsenic seen at'this site is 0.126 mg/1, which is within this
range.
F. RATIONALE FOR ACTION AMD SCOPE OF THE SELECTED REMEDY
For purposes of selecting alternatives to remedy site
contamination, U.S. EPA divided the site into a number of "areas
of concern." While these areas of concern are not separate
operable units, the components of the selected alternatives
correspond to addressing each threat posed by an area of concern.
These areas of concern include drums, landfill cover, landfill
gas and groundwater. An alternative remedial component was
selected for each area of concern, as discussed below.
This ROD establishes the final remedy for the Site. The
principal threat at the site is an area of drummed hazardous and
liquid wastes and other potentially hazardous wastes in the
landfill. The selected remedial alternatives will address this
principal threat.at the site.
G. DESCRIPTION OF ALTERNATIVES
The Albion-Sheridan Township Landfill was divided into four areas
gf concern: hazardous and liquid waste drums within the
landfill, current landfill cover, landfill gasses,- and
groundwater contamination. Alternatives were developed
independently, for each of these areas of concern, as summarized
below. A detailed description of the alternatives can be found
in Section* 4 and 5 of the Feasibility Study report,'which is in
the Administrative Record.
NO ACTION OPTION
Alternative 1 - No Action
The No Action alternative serves as a basis to which all other
alternatives are compared. Under this remedial alternative, no
active remedial action or institutional action would be taken
regarding the site. .
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Capital Cost: $ o
Operation and Maintenance (O&M) Cost: SO
Present Value: $ 0
Timeframe: -0-
DRUM REMOVAL OPTION
Alternative 2 - Removal-and off-site disposal of hazardous and
liquid waste drums
This option includes excavation of intact drums found to contain
waste at the location designated TP-9 by the MDNR and excavation
of other intact drums encountered during construction of the cap.
MDNR estimates that 200 to 400 drums are present at TP-9, but
some are empty. After characterization, those solid wastes found
to contain organic and/or inorganic constituents in
concentrations exceeding land disposal restrictions, or
constituents, for which incineration or stabilization as a
treatment method is prescribed, will be transported to off-site
facilities for treatment. All liquid wastes will be transported
to off-site facilities for treatment and/or disposal. The off-
site facilities will be in compliance with U.S. EPA's Off-Site
Rule. Those drums containing solid wastes which do not trigger
land disposal restrictions will be incorporated under the
landfill cap, as the anticipated volume and concentration are not
expected to significantly affect groundwater quality. The option
would be implemented concurrently with cap construction.
Capital'Cost: $ 614,581
O&M Cost: $ 0 . • .
Present Value: $ 614,581
Timeframe: 6 months
LANDFILL CAP OPTIONS
Alternative 3A - Containment by clay Solid Waste cap; deed
restrictions
This clay cap alternative provides the minimum capping
requirements in the State of Michigan for existing or pre-
existing Type II landfills that do not contain a flexible
membrane liner (Michigan Admin. Code R. 299.4425(3) (Adt 641)).
The.existing landfill surface would be regraded. A 24-inch
compacted clay infiltration barrier (hydraulic conductivity less
than or equal to 1 x 10'7 cm/sec) would be installed over a
granular gas collection layer. A 6-inch topsoil layer would be
.placed over the clay to support vegetation,, stabilize the cap,
and -minimize erosion. This alternative also includes deed
restrictions for landfill property and fencing of the landfill.
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Capital Cost: $ 1,542,S09
O&M Cost (30 yr): S 109,373
Present Value:. $ 1,651,982
Timeframe: 6 months
Alternative 3B - Containment by enhanced clay Solid Waste cap;
deed restrictions
This clay cap enhances the minimum Act 641 requirements by
providing additional frost protection for the clay infiltration
layer. .This would be accomplished by installing a 6-inch sand
drainage layer between the 24-inch clay layer and the topsoil and
by specifying a clay soil with a hydraulic conductivity of less
than or equ^l to 5 x 10'8 cm/sec. This alternative also includes
regrading, deed restrictions, and fencing, identical to
Alternative 3A.
Capital Cost: $ 1,779,137 .
O&M Cost (30 yr): $ 109,373
Present Value: $ 1,888,510
Timeframe: 6 months
Alternative 3C - Containment by flexible membrane liner Solid
Waste cap,- deed restrictions
This alternative is an equivalent cover system in accordance with
Michigan Admin. Code R. 299.4425(5) (Act 641). This alternative
uses a flexible membrane liner (FML) instead of clay soil as the
infiltration barrier material. An FML of 40 mil low density
polyethylene or 30 mil polyvinyl chloride would be placed over a
12-inch granular gas collection layer. Eighteen inches of cover
soil would be placed over the FML to protect against puncture and
ultraviolet rays. A 6-inch drainage layer would be placed over
the cover soil, with 6 inches of topsoil placed over the drainage
layer to support vegetation and to stabilize the cap by
minimizing erosion. This alternative also includes regrading,
deed restrictions, and fencing, identical.to Alternative 3A.
Capital Cost: $ 1,728,431
O&M Cost (30 yr): $ 109,373
Present Value: $ 1,837,804
Timeframe: 6 months
LANDFILL GAS OPTIONS
Alternative 4A - Passive collection and venting of landfill gas
Under this alternative, a passive gas collection system would be
constructed to control off-site migration of landfill gas.
Venting wells would;be constructed across the landfill to vent
landfill gas to the atmosphere. Approximately 16 vent wells
would be drilled the entire depth of the solid waste fill, ' •
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estimated at an average of 20 feet, and spaced approximately
every 200 feet. This alternative would be constructed
concurrently Wiith the landfill ca- .
Capital Cost: $ 49,600
O&M Cost (30 yr): $ 207,777
Present Value: $ 257,377
Timeframe: 6 months
Alternative 4B - Active collection and flaring of landfill gas
This alternative includes -construction of an active gas
collection system to control emission of landfill gas from -he
site. The collected landfill gas would be treated on-site by
flaring prior to discharge to the atmosphere. The alternative
includes construction of approximately IS gas wells similar to
the wells in the passive venting system, piping, and a
blower/flare facility. This, alternative would be constructed
concurrently with the landfill cap.
Capital Cost: $ 182,900
O&M Cost (30 yr): $ 446,093
Present Value: $ 628,993
Timeframe :• 6 months
GROUNDWATER OPTIONS
Alternative 5A - Groundwater monitoring; institutional controls
This alternative includes the installation of four new monitoring
wells and the monitoring of existing monitoring wells and
residential wells near the landfill on a quarterly to annual
•basis for arsenic and other contaminants. Groundwater monitoring
would allow U.S. EPA to evaluate the contaminant plume's
migration rate and direction, and to monitor the fate of
contaminants, primarily arsenic. This alternative will allow
evaluation of the effectiveness of the landfill cap for reducing
arsenic in the groundwater. U.S. EPA expects this alternative to
take 1 to 2 months to construct. U.S. EPA expects arsenic to
decrease to 0.05 mg/1 throughout the contaminant plume within 15
years: This "alternative includes 5 years of monitoring beyond
that time to ensure that the M'CLs continue to be met. This
alternative also includes institutional controls in the form of
deed restrictions or local ordinances to prohibit the
construction of drinking water wells which draw water from the
contaminant plume, until the plume meets MCLs.
Capital Cost: $ 128,822
O&M Cost: $ 642,335
Present Value: $ 771,157
Timeframe: 20 years
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Alternative SB - In-situ-treatment of arsenic in groundwater co
0.05 mg/1 (the MCL); groundwater monitoring; institutional
controls
"Jnder this alternative, groundwater would be treated by in-situ
oxidation to remove arsenic from solution. There would be only
one clean-up standard, which would be 0.05 mg/1 (the MCL)- for
arsenic. The-in-situ groundwater treatment system would consist
o.f a network of wells designed to inject air or another oxidant
so as to treat the entire contaminant plume that exceeds 0.05
mg/1 arsenic. The treatment system would be operated until
groundwater meets the clean-up standard for arsenic at the
landfill boundary and throughout the contaminant plume.
Groundwater monitoring under this alternative would be used to
evaluate the progress of groundwater remediation and to verify
that impacted groundwater does not migrate beyond the range of
influence of the treatment system. U.S. EPA expects this
alternative to take 3 months to construct and 5 years to reach
the clean-up standard. This alternative includes 5 years of
monitoring after the clean-up standard is reached to ensure that
the standard continues to be met and institutional controls
identical to Alternative 5A. .
Capital Cost: $ 560,284
O&M Cost: $ 790,457
Present Value: $ 1,350,741
Timeframe: 10 years
Alternative 5C - In-situ treatment of arsenic in groundwater to
0.002 mg/1 (regional background); groundwater monitoring;
institutional controls •
This alternative is identical to Alternative SB except that the
clean-up standard would be 0.002 mg/1 arsenic and the treatment
system would be designed to encompass that portion of the
contaminant plume that exceeds 0.002 mg/1 arsenic. The treatment
system would be operated until groundwater meets the clean-up
standard for arsenic at the landfill boundary and throughout the
contaminant plume. U.S. EPA expects this alternative to take 3
months to construct and 12 years to reach the clean-up standard.
This alternative includes 5 years of monitoring after the clean-
up standard is reached to ensure that the standard continues to
be met and institutional controls identical to Alternative 5A.
Capital Cost: $862,656.
O&M Cost: $ 1,539,827
Present Value: $ 2,402,483
Timeframe: 17 years
Alternative 5D - Groundwater extraction and above-ground
treatment of arsenic to 0.002 mg/1 arsenic (regional background);
groundwater monitoring; institutional controls
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This alternative includes installation of a groundwater
extraction system of approximately 3 wells to intercept the
contaminant plume where it exceeds 0.002 mg/1 arsenic and
construction of an above-ground treatment system to treat
arsenic.. The alternative would involve pilot testing a treatment
system using a chemical oxidation, coagulation, and filtration or
sedimentation treatment train. Treated groundwater would be
disposed on-site into the North Branch of the Kalamazoo River or
off-site to the City of Albion sewage treatment plant. U.S EPA
expects this alternative to take 6 months to construct and .
years to reach the clean-up standard. This alternative includes
5 years of monitoring after the clean-up standard is reached to
ensure that the standard continues to be met and institutional
controls identical to Alternative 5A.
Capital Cost: $ 931,703
O&M Cost:.$ 1,280,281
Present Value: $ 2,211,984
Timeframe: 14 years
H. SUMMARY OF COMPARATIVE ANALYSIS OP ALTERNATIVES
The relative performance of each remedial alternative was
evaluated in the FS and is summarized below using the nine
criteria set forth in the NCP at 40 C.F.R. §300.430. As
described in this section of the NCP, the nine criteria are
divided into threshold criteria, primary balancing criteria and
modifying criteria. Table 4 summarizes the comparative analysis.
An alternative and a contingent alternative providing the "best
balance" of trade-offs with respect'to the nine criteria are
determined from this evaluation.
'THRESHOLD CRITERIA
The following two threshold criteria, overall protection of human
health and the environment, and compliance with Applicable or
Relevant and Appropriate Requirements (ARARs) are criteria that
must be met in order for an alternative to be selected.
1. Overall Protection of Hunan Health and tha Environment
Overall protection of human health and the environment addresses
whether a remedy eliminates, reduces, or controls threats to
human health and to the environment.
No-action Option: Alternative 1 does not satisfy the requirement
for overall protection of human health and the environment.
Drum Disposal Option; Alternative.2 provides protection to human
health and the environment by reducing the risk of hazardous and
liquid wastes leaching into the groundwater. This will not
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eliminate Che -risk because additional wastes will remain at tine
site.
Landfill Cap'Options: With each of the landfill cap
alternatives, the human health risk associated with exposure to
the wastes in the landfill is eliminated. Additionally, each
capping alternative reduces the risk associated with release of
the leachate into the groundwater or outside.the landfill
boundaries. However, Alternative 3A may not satisfy the
requirement for overall protection of human health and the
environment because it is susceptible to damage from freeze-thaw
cycles and may allow continued infiltration of water through the
landfill wastes. Alternative 3B is more effective than
Alternative 3A because it would likely continue to have a lower
permeability even after freeze-thaw cycles. Alternative 3C
provides protection because it is not susceptible to frost
cracking and it is more effective in reducing infiltration of
water through the landfill, thus reducing the amount of
contaminants that can potentially enter the groundwater.
Landfill Gas Options: Both landfill gas options would protect
the landfill containment system from adverse pressure buildup
beneath the cap and will prevent migration of landfill gas
laterally off-site. However, Alternative 4A does not provide for
treatment of the landfill gas and so may not be protective of
human.health if the gas generation rate or concentrations are
high or if certain types of gases are produced. Alternative 4B
provides protection by treating the landfill gas by flaring.
However, if design studies show that the gas generation rate is
low or 'if the generation rate is found to be low following
capping, Alternative 4A may also be protective.
Groundwater Options; All of the groundwater options provide for
overall protection of human health and the environment, by natural
removal or treatment of arsenic and by limiting human consumption
of contaminated groundwater through institutional controls.
Alternative 5A provides protection by monitoring groundwater, to
confirm that arsenic is being removed from the groundwater
through natural oxidation as expected and that the arsenic will
not migrate to locations where it may impact residential wells.
However, if arsenic is not removed from the groundwater
naturally. Alternative 5A may not be protective if used alone.
Alternative SB provides additional protection .for human health by
treating groundwater to the MCL, which is inherently protective
of human health. Alternative 5C and 5D each provide protection
by treating arsenic to the regional background level, which is
below a 1 x 10-6 risk level.
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2. Compliance with ARARs
This criterion evaluates whether an alternative meets ARARs set
forth in federal, or more stringent state, environmental
standards pertaining to the Site or to proposed actions.
Because the No Action alternative does not involve conducting any
remedial action at the Site, no ARARs analysis is necessary for
Alternative 1. With the exception of landfill gas alternative
4A, all of the remaining alternatives (2, 3A, 3B, 3C, 4B, 5A, SB,
5C, and 5D) are expected to be in compliance with action,
chemical,.and location specific ARARs as shown in Tables 2.la
through 2.6b of the FS Report and discussed in Section:J(2)
below. .
Alternative 4A may. not be in compliance with Michigan Admin. Code
R. 433 (Act 641) regarding landfill construction or Michigan
Comp. Laws Section 348 regarding air emissions if (1) the methane
gas generated by the landfill exceeds 25% of the lower explosive'
limit for methane in the landfill, exclusive of gas control
components or (2) the methane gas generated by the landfill
exceeds the lower explosive limit at or beyond the facility
property boundary or (3) if any gasses generated by the landfill
create a nuisance or are otherwise in violation of Michigan Comp.
Laws Section 348 at the property boundary.
PRIMARY BALANCING CRITERIA
3 . Long-Term Effectiveness and Permanence
This criterion refers to expected residual risk and the ability
of an alternative to maintain reliable protection of human health.
and the environment over time once clean up levels have been met.
No-Action Option; Alternative 1 provides no long-term
effectiveness and would result in continuation of the elevated
risk levels that currently exist at the Site.
Drum Disposal Option; Alternative 2 meets the criteria of long-
term effectiveness and permanence. There is some residual, risk
from this alternative due to residues' from off-site incineration
and stabilization processes used to treat the drummed waste.
These residues would be disposed in licensed land disposal
facilities which will have engineering .controls in place to
ensure adequate long-term containment of the wastes. There is
also residual risk from additional wastes remaining in the
landfill.
Landfill Cap Options: Alternatives 3A, 3B and 3C all provide
some degree of long-term effectiveness and permanence through
containment of the waste and reduction of infiltration and by
implementing institutional controls to maintain the cap's'
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integrity. Each of the three caps will .reduce ingestion,
inhalation, and direct contact with contaminated materials and
will reduce infiltration of precipitation into the waste mass
which reduces leachate generation. Alternative 3B is expected to
be more effective and permanent than Alternative 3A because it
includes a clay layer with lower permeability to provide some
frost protection and a sand layer to provide drainage.
Alternative 3C is expected-to be the most effective and permanent
because it includes both a sand layer for drainage and a flexible
membrane liner which is not susceptible to frost-cracking.
Landfill Gas Options: Alternatives 4A and 4B both provide some
degree of long-term effectiveness and permanence by preventing
long-term migration of landfill gases laterally off-site and
protecting the landfill cap from'adverse pressure buildup.
Alternative 4B presents less residual risk in that -it includes
treatment of gases by flaring, rather than releasing gases to
disburse, untreated.
Groundwater Options; All of the groundwater alternatives are . "
expected to provide long-term effectiveness and permanence. At
completion, groundwater throughout the contaminant plume is
expected to have arsenic concentrations below the MCL (0.05 mg/1)
for Alternative'5A and SB. Residual risk immediately following
Alternative 5C or 5D would be lower than Alternative 5A or 5B
because 5C and 5D involve treatment to a lower level. However,
if Alternative 5A or 5B is implemented, U.S. EPA expects the
arsenic to continue, to decrease below the MCL with time.
Groundwater monitoring is planned to continue for 5 years beyond
attainment of the treatment standard in each alternative.
If Alternative 5A is effective in the short term, it is likely tc
be the most.effective alternative in the long-term because it
involves monitoring a natural clean-up process (natural
oxidation) to remove arsenic'from groundwater. U.S. EPA expects
arsenic to precipitate and otherwise be removed from groundwater
as conditions in the contaminant plume become more oxidizing
(e.g., contain more oxygen) after the landfill is capped. The
landfill cap in Alternative 3C would be the most effective in
changing groundwater conditions because it is the most effective
in the long-term at reducing infiltration through the landfill.
The Agency also expects an oxidizing environment to reduce the
release of arsenic from the bedrock formation into the
groundwater. .
4. Reduction of Toxicity, Mobility, or Volume through
Treatment
This criterion evaluates treatment technology performance in the
reduction of chemical toxicity, mobility, or volume. This
criterion addresses the statutory preference for selecting
remedial.actions, which include, as a principal element, treatment'
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-hat permanently and significantly reduces the volume, toxicity,
or mobility of the hazardous substances, pollutants, and
contaminants. •
No-Act ion Potion: Alternative 1 for "r.o-action",. provides no
reduction in toxicity, mobility, or volume.
Drums and Landfill Options; Alternative 2 for drum extraction
and treatment provides a reduction in toxicity, mobility and
volume through off-site incineration or stabilization of
hazardous and liquid wastes found in drums. Although there will
be no additional treatment of landfill contents, landfill cap
alternatives 3A, 3B and 3C all provide.a reduction in mobility of
hazardous substances by reducing leachate generation in the
landfill, although 3C would be the most effective in "this.
Alternative 4A reduces the mobility of landfill gas by
controlling lateral migration and 4B reduces volume, toxicity and^
mobility of the gases by gas collection and treatment.
Groundwater Options; Alternative 5A for groundwater monitoring
does not include treatment as a direct action. However, under
this alternative, U.S. EPA expects reduction of toxicity and
mobility to be achieved through natural oxidative processes in
the aquifer. Alternatives 5B, SC, and 5D meet this requirement
more fully by achieving faster reduction of toxicity and mobility
by in-situ groundwater treatment or by collection and above-
ground treatment.
5. Short-Term Effectiveness
Short-term effectiveness considers the time to reach cleanup
objectives and the risks an alternative may pose to site workers,
the community, and the environment during remedy implementation
until cleanup standards are achieved.
Drums and Landfill Options: Potential risks-to the community
from excavating drums, capping the landfill and constructing a
landfill gas control system (Alternatives 2, 3A, 3B, 3C, 4A and
4B) are from exposure to airborne dust and organic vapors from
the waste mass and leachate. The risk to the community from
exposure to organic vapor is approximately equal for the three
cap options. The FML cap (Alternative 3C) may pose less total
risk to the community during construction than the clay caps .
(Alternatives 3A and 3B) due to less truck traffic and less
exposure to airborne dust.' The risk to workers employed in the
construction of.any of the cap options and either of the gas
collection systems from exposure to the waste mass and leachate
material is approximately equal. All the alternatives, except
Alternative 1 for "no-action", include measures to .minimize the
short-term impacts during construction, such as dust control and
the use of safe work practices.
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Groundwater Options; U.S. EPA expects the natural oxidation'
processes-monitored by Alternative 5A for groundwater monitoring
to reduce arsenic in groundwater to 0.05 mg/1 (the MCD- within 15
'years. Alternative 5B reduces the time to reach the MCL to 4
.years by treating the water ir.-situ. The more stringent clean-up
standard of 0.002 mg/1 set in Alternative 5C and 5D would take 12
years and 9 years to reach, respectively.
There is some uncertainly about how fast the natural oxidation
process will reduce arsenic in groundwater. Alternative SB and
5C reduce this uncertainty by treating the groundwater in-situ to
enhance oxidation. Alternative 5D reduces this uncertainty by
groundwater extraction and above-ground treatment. However,
because most of the impacted groundwater is located in the
fractured bedrock aquifer, there remains some uncertainty
regarding the effectiveness of the in-situ treatment of
Alternatives 5B and 5C and of the groundwater extraction system .
in. Alternative 5D. • •
6. laplementability
This criterion addresses the technical and administrative
feasibility of implementing an alternative, and the availability
of various services and materials required for its
implementation.
All the alternatives are implementable and can be readily
constructed with technology and materials presently available.
Construction of the FML cap, Alternative 3C, is slightly more
difficult to implement than Alternative 3A or 3B because its
effective installation involves more specialized testing to
ensure an effective seal.
All of the groundwater monitoring and treatment alternatives
depend on proven and readily available equipment and expertise.
Alternative 5A for groundwater monitoring is the most easily
implementable, compared to the other groundwater alternatives,
since it relies in large part on existing wells.
7. Coat
This criterion compares the capital, O&M,.and present value costs
of implementing the alternatives at the Site. Table 3, shows the
Cost Summary. The "no-action" option is the least costly, but
does not protect human health or the environment. The clay
landfill cap considered under Alternative 3A is slightly less
costly than the caps considered under Alternatives 3B and 3C.
The enhanced clay cap in Alternative 3B is slightly more
expensive than the FML cap in Alternative 3C. Passive venting
under Alternative 4B is substantially less costly than active gas
collection and treatment in Alternative 4A. Of the groundwater
alternatives, Alternative 5A, groundwater monitoring, is the
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lease costly. Alternatives 5C and 5D, which involve treatment to
more stringent levels, are more costly than Alternative SB, which
involves treatment to the MCL.
MODIFYING CRITERIA
8. State Acceptance
The State of Michigan is in agreement with the selection of -
Alternative 2 for drum removal, Alternative 3C for the landfill
cap, Alternative 4B for landfill gas (unless pre-design studies
show that 4A meets ARARs) , and Alternative 5A for groundwater,
•for remediation of the Albion-Sheridan Township Landfill Site.
The State is also in agreement with the selection of Alternative
5B as a contingent remedy for groundwater cleari-up. The State
has provided U.S. EPA with a letter of concurrence.
9. Community Acceptance
Comments have been submitted by.the community, local government
officials, and potentially responsible parties (PRPs). Comments
and responses to those comments are described in the
Responsiveness Summary.
I. THE SELECTED REMEDY
Based upon considerations of the requirements of CERCLA, the NCP
and balancing of the nine criteria, the. U.S. EPA has determined
that Alternatives 2 for drum removal, 3C for a flexible membrane
cap, 4B for active gas collection, and 5A for groundwater
monitoring, with a contingency for Alternative SB, in-situ
treatment to' the MCL, together constitute the most appropriate
remedy for the Site. The components of the selected remedy are
described below. Mitigative measures will be taken during all
remedy construction activities to minimize adverse impacts to
surrounding residents and the environment.
A review will be conducted within five years after commencement
of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment
because this remedy will result in hazardous substances remaining
on site above health-based levels.
1. Drum Removal .
All drums found to contain solid or liquid wastes at the location
designated TP-9 on Figure 5 and which are structurally sound
enough to remove with wastes intact will be excavated. The
location and extent of area TP-9 are described further in the
report "Technical Memorandum No. 1" prepared'for the MDNR by ABB
Environmental Services, Inc. This'report is part of the
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Administrative Record for this site. MDNR estimates'that 200 to
400 drums are present in this area, some of which are empty.
All other structurally sound drums containing solid or liquid-
wastes encountered during consolidation or site preparation for
landfill cap construction will, also be excavated. All excavated
drums showing signs of degradation will be overpacked as
necessary, and moved to a staging area for waste
characterization.- Approximately nine overpacked drums excavated
by the MDNR during test pitting which are temporarily secured on'
the surface of the landfill will be included with other excavated
drums;for proper characterization and removal. After
.characterization, those solid wastes found to contain organic
and/or inorganic constituents in concentrations exceeding land
disposal restrictions, or constituents for which incineration or
stabilization as a treatment method is prescribed, will be
transported to off-site facilities for/treatment. All liquid
wastes will be transported to off-site facilities for treatment
and/or disposal. The off-site facilities will be in compliance
with U.S. EPA's Off-Site Rule. Those drums containing solid
wastes which do not trigger land disposal restrictions will be
incorporated under the landfill cap, as the anticipated volume
and concentration are not .expected to significantly affect
groundwater quality.
•Empty storage tanks and abandoned machinery located on the
surface of the landfill will either be incorporated into the
landfill or transported to off-site facilities for recycling or
disposal. Any items removed off-site will be wipe sampled as
appropriate to determine the proper type of disposal facility or
its acceptability to a recycling facility.
2. Landfill Cap
The entire landfill waste mass shown, on Figure 1 will be capped.
Site preparation and layout will be completed.to re-route surface
water drainage away from the capped area.
Waste on the east.edge of the landfill will be consolidated
towards the west so that the east boundary of the landfill cap
and any perimeter road needed for maintenance is contained on Lot
28 (Figure 1). Waste on the south edge of the landfill will be
consolidated so that the south boundary of the landfill cap and
any perimeter road needed for maintenance is contained on Lot 28,
parcel 3 and that portion of Lot 28, parcel 2 north of a line
extending, due east from the north boundary of parcel 1. If Lot
28, parcels 1 and 2 are instead acquired, consolidation of the
south edge of the landfill will not be .necessary. Any property
acquisition will be done in compliance-with the Uniform
Relocation Assistance and Real Property Acquisition Policies Act
of 1970.
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The landfill will be graded to attain grades and slopes required
co facilitate drainage. Regrading may be used to achieve sub-cap
contours. Any materials other than clean fill employed to
achieve proper contours will be used only if specifically
approved by U.S. EPA, in consultation with MDNR. To the extent
practicable, existing trees in areas not affected by the landfill
cap will be left in place. -
At a minimum, the cap will consist of a 12-inch sand gas
collection layer on top of the existing waste mass, a flexible
membrane liner (FML), a 6 inch sand drainage layer or technical
equivalent, 18 inches of cover soil, and 6 inches of topsoil. A
filter fabric may be placed between the cover soil and the
drainage layer to minimize fill material from clogging the
drainage layer. The FML will .be equivalent to or less permeable
than a 40 mil low density polyethylene or 30 mil polyvinyl
chloride. .The drainage layer will be composed of either 6 inches
of sand no coarser than 3/8 'inch, with a minimum hydraulic
conductivity of 1 x l-'2 cm/sec, or a synthetic material with a "
transmissivity of at least 3 x 10"s m2/sec.
The Presidential Memorandum on Environmentally and Economically
Beneficial Practices, signed on April 26, 1994 and published in
the Federal Register on August 22, 1994 (59 FR 43122), encourages
Federal agencies to incorporate the use of native plants wherever
practicable into landscape projects, in order to reduce the use
of chemical fertilizers and pesticides, reduce water usage,
reduce.maintenance costs and preserve natural habitats.
Therefore, pre-design studies will be performed to determine
whether seeding the vegetative soil layer on the surface of this
landfill with native species is practical and cost-effective,
considering both short-term and long-term costs. If U.S. EPA
'determines that the use of native species is practical and
results in the same or less cost in the long-term than the use of
traditional species, native species will be used.
3. Landfill Q*«
Unless landfill gas characterization studies during the pre-
desigri stage show that gas emissions will meet ARARs (e.g.,
Michigan Comp. Laws Section 641 and 348) without treatment, an
active landfill gas collection system will be located in a grid
network throughout the landfill and the off-gas from the landfill
will be collected by piping and treated in a blower/flare
facility. However, if U.S. EPA, in consultation with MDNR,
determines that a passive venting system will meet. ARARs, a
system of -venting wells may be constructed across the landfill to
vent landfill gas to the atmosphere. The gas collection or
venting wells will be constructed to collect gas from the entire
area and depth of the landfill.
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4. Groundwater Monitoring
A groundwater monitoring program will be designed and implemented
at the site. The monitoring program will include:
(1) Quarterly sampling of the contaminant plume to detect
•changes in concentration of arsenic in the groundwater and
to determine whether the levels of arsenic trigger the
contingent remedy as specified below,
(2) Quarterly sampling of drinking water wells downgradient of
the Site and of the Amberton Village water wells, to detect
the presence and concentration of any site-related
contamination,
(3) Annual sampling of the contaminant plume to detect
additional hazardous constituents which may be present,
(.4) Annual sampling of the arsenic concentration for five years.
following attainment of the clean-up standard, to ensure
that the standard continues to be met, and
(5) Collection of a water level measurement whenever a well is
sampled, to confirm groundwater flow directions at the site.
During the pre-design phase, four new monitoring wells will be
installed to define further the contaminant plume to the west and
south of the site and to define further the vertical extent of
contamination; in order to design an effective groundwater
monitoring program. The new wells will be installed at the
approximate locations indicated in Figure.6: MW09DB in the deep
bedrock, MW15SB in the shallow bedrock, MW16SB in the shallow
bedrock, and MW16DB in the deep bedrock. The MW15SB well will be
vertically sampled prior to 'installation to ensure that the most
contaminated interval is screened. Also prior to the initiation
of the groundwater monitoring program, the water levels of all
existing and new monitoring wells will be recorded and all wells
will be sampled and analyzed for target compound list (TCL)
organics, target analyte list (TAL) inorganics, and 1,2-dibromo- .
3-chloropropane. These analyses will be done using methods which
achieve method detection limits equal to or less than the MCL for
each compound or analyte, for those which have an MCL.
5. Contingent Remedy for In-Situ Groundwater Treatment
Five years from the date on which construction of the landfill
cap is complete, a statistical test will be performed on wells in
which the arsenic concentration exceeds. 0.05 mg/1 (currently only
MW06SB). ' This statistical test, described below, is designed to
determine whether arsenic in this well or wells is declining
sufficiently fast to fall below 0.05 mg/1 within 15 years of
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completion of landfill cap construction. If any well fails this
test, the contingent remedy will be implemented.
Implementation of the contingent remedy includes pilot testing,
design, .installation and operation of a system for in-situ
oxidation of groundwater which will restore arsenic in
groundwater to 0.05 mg/1 (the MCL). This system for in-situ
groundwater treatment will also be implemented if at any time
U.S. EPA, in consultation with MDNR, determines that the
groundwater plume affected by the landfill threatens to raise a
residential well, in existence at the time this ROD is signed,
above 0.05 mg/1, the MCL for arsenic.
a. Description of the Contingent Remedy
If the contingent remedy is implemented, the in-situ groundwater
treatment system will first be pilot-tested to determine whether
air or another, oxidant -is most suitable for the site and to
assist with design of the system. The system will consist of a
network of wells designed to treat all contaminated groundwater
that exceeds the MCL for arsenic, for example as shown in
Figure 7. The in-situ groundwater treatment system will be
operated until groundwater meets the MCL for.arsenic at the
landfill boundary and throughout the contaminant plume.
U.S. EPA expects the precipitated arsenic from the in-situ
treatment to be in the form of a suspended solid, which will be
removed from groundwater as it flows through fractured bedrock
and granular soils. Groundwater monitoring will be used to
evaluate the progress of groundwater remediation and to verify
that impacted groundwater does not migrate beyond the range of
influence of' the treatment system. Groundwater monitoring will
continue for five years after-the clean-up standard is reached to
ensure that the standard continues to be met.
b. Contingent Remedy Trigger
If, five years after completion of the landfill cap, .any well
fails the statistical test described below, the contingent remedy
will be implemented. For each well that exceeds 0.05 mg/1
arsenic (currently only MW06SB), data collected over the five •
year period will be used to estimate the date at which arsenic
concentrations will meet 0.05 mg/1. Initially, sample
concentrations of arsenic will be plotted against time to enable
U.S. EPA to determine if a downward trend is present. If, five
years after completion of the landfill cap, U.S. EPA determines
that a downward trend is present over a sufficient number of
quarters,'a regression, time series, or other model approved by
U.S. EPA will be used to estimate arsenic concentrations based oh
time. If the data do not exhibit a serial correlation, a
regression model will be used to estimate a linear or nonlinear
trend for the subset of data which .represent a downward trend.
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If the data do exhibit a serial correlation, a time series model
will be developed in lieu of a regression model on the same
subset of data. Another method may be used if approved by U.S.
EPA. For each well which exceeds 0.05 mg/1 arsenic and has a
downward trend for arsenic, the model approved for those data
will be used to predict the date at which arsenic concentrations
will meet 0.05 mg/1 arsenic, assuming that the observed, trend
continues. A-well fails the statistical test if the date at
which the arsenic concentration is predicted to meet 0.05 mg/1 is
more than 15 years from the date of landfill cap completion.
6. Institutional Controls
Institutional controls will be implemented, which include access
and deed restrictions and may include .local ordinances. A fence
around the entire landfill will control, access to the site and
protect the cap. A maintenance program will be-.implemented to
maintain the landfill cap. This program will include maintaining
a full, competent vegetative layer and periodic inspection of the
cover to ensure that excessive erosion or leachate seeps are not'
occurring. Deed restriction to prevent future development of the
landfill property will be implemented pursuant to Michigan Admin.
Code R. 299,. 610 (e). Deed restrictions or local ordinances may be
implemented to restrict construction of water wells which will
draw water from the arsenic plume as shown on Figure 4. At a
minimum, advisories will be issued to all property owners
impacted by the arsenic plume.
J. DOCUMENTATION OP SIGNIFICANT CHANGES
U.S. EPA released a Proposed Plan for public comment on
October 3, 1994. The Proposed Plan identified the following
remedy components for this Site: Alternative 2 for drum
disposal, Alternative 3C for a landfill cap, Alternative 4B for
gas collection, Alternative 5A for groundwater monitoring, and a
contingent remedy for Alternative SB for in-situ treatment o-f
groundwater. This ROD makes no change in the Alternatives
selected. However, based on comments received during the public
comment period, this ROD allows a change in the order of the
material layers of the selected landfill cap from that presented
in the proposed plan. Also, this ROD specifies that as part of
cap construction, waste must be consolidated away from'a private
residence adjacent to the landfill. This was not addressed in
the Proposed Plan. Both of these issues are discussed more fully
in the Responsiveness -Summary.
K. STATUTORY DETERMINATIONS
U.S. EPA's primary'responsibility at Superfund Sites is to
undertake remedial actions that protect human health and the
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environment. Section 121-of CERCLA has established several
statutory requirements and preferences. These include the
requirement that the selected remedy, when completed, must comply
with all ARARs imposed by Federal and State environmental laws,
unless the invocation of a waiver is justified. The selected
remedy must also provide overall effectiveness appropriate to its
costs, and use permanent solutions and alternative treatment
technologies, or resource recovery technologies, to the maximum
extent practicable. Finally, the.statute establishes a
preference for remedies which employ treatment that significantly
reduces the toxicity, mobility or volume of contaminants. The
following sections discuss how the selected remedy and contingent
remedy meet these statutory requirements.
1. Protection of Human Health and the Environment
Implementation of the selected remedy and the contingent remedy
will protect human health and the environment by reducing the
risk of exposure to hazardous substances present in the landfill
and groundwater at the Site. The excavation and off-site
treatment of drummed hazardous and liquid wastes provides
protection by reducing the risk of these wastes leaching into the
groundwater and contaminating drinking water or mixing with
surface water. The selected FML landfill cap will reduce the
direct contact risk of exposure to hazardous substances present
in soil-at the Site. Additionally, the FML cap will reduce the
rate of infiltration by which precipitation passes through the
contaminated soil and will maintain th'at reduction over time. By
reducing the rate of infiltration, the FML cap will also reduce
the rate of leachate generation in the landfill; and therefore,
it will also reduce the risk that hazardous substances,
pollutants, and contaminants present in the leachate will migrate
and contaminate the aquifer. .
Groundwater monitoring will be required to provide early warning
against the risk that arsenic present in the groundwater adjacent
to the landfill may migrate and contaminate residential wells.
If the contingent remedy for groundwater treatment is triggered,
an in-situ groundwater treatment system will clean up groundwater
at a faster pace to further protect drinking water/supplies.
Institutional controls will be imposed to restrict uses of the
Site to prevent exposure to hazardous substances and contaminants
in the soil and the groundwater at the Site. No unacceptable
short-term risks will be caused by implementation of the remedy.
The community and site 'workers may be exposed to dust and noise
nuisances during construction of the landfill cap. Mitigative
measures will be .taken during remedy construction activities to
minimize such impacts of construction upon the surrounding
community and environs. Ambient air monitoring will be conducted
and appropriate safety measures will be taken if contaminants are
emitted.
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2. Compliance with ARARs
The selected remedy and the contingent remedy will comply with
all chemical, action, and location specific ARARs. For a
complete list of ARARs and other criteria, advisories and
guidance to be considered for the alternatives at this site, see
Tables 2.la through 2.7 of .the Feasibility Study Report. Below
is a discussion of the key ARARs for the selected remedy.
KEY FEDERAL ARARS (See Feasibility Study Report for complete
listing of action, chemical and location specific ARARs.)
1. Action Specific
Resource Conservation and Recovery Act (RCRA)
RCRA requirements for facilities treating, storing or disposing
of hazardous wastes (Subtitle C) are not. applicable because the .
landfill was closed in 1981 and no available records indicate
that wastes were disposed of after November 19, 1980, the
effective date of RCRA. However, RCRA Subtitle C requirements
are relevant and appropriate .to the portion of the remedy
involving off-site treatment of drummed waste because some of the
drummed wastes are likely to have hazardous characteristics or
contain constituents which-are regulated as a "listed" hazardous
waste under RCRA. These requirements are appropriate because
they address the protection of the environment at the Site and at
the off-site disposal location, which could be contaminated by
these RCRA-like wastes. The drum disposal portion of the
selected remedy and contingent remedy will meet these
requirements.
RCRA Subtitle C requirements are also relevant to the landfill
wastes which will be left at .the site, but they are not
appropriate. They are relevant because the landfill accepted
hazardous industrial wastes, including metal plating sludges, and
these wastes, which are similar to. listed wastes, will remain
buried at the site. RCRA Subtitle C requirements are not
appropriate for the site, however, because of the low levels of
contamination found during investigation of the landfill and off-
site media.
As previously discussed, samples of landfill waste from borings
contained numerous contaminants, the most concentrated of which
was 4-Methyl phenol at 15 mg/kg. Several inorganic substances
were present above background levels in subsurface soils,
including.antimony, arsenic, chromium, copper, lead, mercury, and
zinc. The highest concentrations included lead at 208 mg/kg,
arsenic at 13.1 mg/kg and chromium at 13.5 mg/kg. Additionally,
sampling for characteristic wastes showed no such wastes present
in the landfill. One sample was suitable for the TCLP metals
analysis,' the results of which indicated the presence of barium
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and lead in the TCLP leachate, both below hazardous waste levels.
Therefore, Subtitle C requirements do not correspond to the
relatively low risks posed by the site. Subtitle D retirements
are more appropriate to the site conditions.
RCRA Subtitle D regulates the disposal of solid waste. Subtitle
D requirements are not applicable to the site, but are relevant
and appropriate. 40 CFR Part 258 regulates municipal solid
waste, which is a large part of the waste disposed at this site.
This Part requires the use of a barrier layer consisting of two
feet of clay, or a technical equivalent which will provide equal
or greater protection against infiltration. The flexible
membrane 1 inner and other components of the cap required by this
ROD are equivalent to or more protective than required by RCRA
Subtitle D.
Clean Air Act (CAA)
The CAA establishes National .Ambient Air Quality standards
(NAAQS) for several "criteria pollutants" expressed as primary
and secondary allowable .short- and long-term concentrations in
the air. Under the CAA, each state must adopt a state
implementation plan to demonstrate how it will meet its statutory
obligation to attain and maintain NAAQS. Standards called New
Source Performance Standards (NSPS) are promulgated under the
regulatory authority of the CAA. Title III applies to new
sources which emit more than 10 tons per year of any hazardous •
air pollutant or 25 tons per year of any combination of hazardous
air pollutant listed. Emissions at this Site are not expected to
exceed these limits, but if they do, best available control
technology requirements may be applicable. If this is the case,
the selected remedy and contingent remedy will meet this
requirement.
Occupational Safety and Health Act (OSHA)
Regulations promulgated under the Occupational Safety and Health
Act, codified at 29 CFR 1910, regulate the safety and health of
workers. These requirements are applicable to work at the site
and will protect the health and safety of workers implementing
the selected response action. .
2. Chemical Specific
Safe Drinking Water- Act (SDWA)
40 CFR 141 - Federal Drinking Water Standards promulgated under
the SDWA include both MCLs and Maximum Contaminant Level Goals
("MCLGs"). The NCP at 40 CFR 300.430(e)(2)(i)(B) provides that
MCLGs established under.the SDWA that are set at levels above
zero, shall be attained by remedial actions for ground or surface
waters that are current or potential sources of drinking water.
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MCLs and non-zero MCLGs usually are applicable only at the
drinking water tap from a public water supply, however, they are
relevant and--appropriate at this site because .near the landfill,
the same aquifers which exist below the Site are presently being
used by residences in the area for drinking water" and are
expected to continue to be used in the future. The selected
remedy and the contingent remedy both meet the MCL for arsenic
(the only contaminant being considered for treatment at the
Site).. There is no MCLG for arsenic. • •
The Preamble to the NCP (55 FR 8753), provides that groundwater
cleanup standards should generally be attained throughout the
contaminant, plume or at and beyond the edge of the waste
management area when waste is left in place. This remedy and
contingent remedy will meet the MCL for arsenic at the boundary
of the final landfill cover and throughout the contaminant plume
beyond the landfill boundary, because this is the area where
humans could potentially be exposed to contaminated groundwater.^
3. Location Specific
Executive Order on Floodolain Management
Exec. Order No. '11.988; 40 CFR 6.302(b)
The requirements of Executive Order No. 11.988 are applicable
because the selected remedy and contingent remedy have the
potential to impact the flood plain. Although no part of the
landfill itself is on the flood plain, several monitoring wells
are on the flood plain' of the North Branch of the Kalamazoo
River. Executive Order No. 11.988 requires that actions at the
Site be conducted in a manner minimizing the impact on the flood
plain. The selected remedy and the contingent remedy will be
implemented'in a manner that will minimize any adverse impact on
the flood plain. . . • •
Executive Order on Protection of Wetlands
Exec. Order No. 11.900; 40 CFR 6.302(a) and Appendix A
The requirements of Executive Order No. 11.900 are applicable
because the selected remedy and contingent remedy may have the
potential to impact wetlands. Although no part of the landfill
itself is covered by wetlands, there are wetlands 400 feet south
of the landfill, adjacent to the North Branch of the Kalamazoo
River. The selected remedy and the contingent remedy will be
implemented in a manner that will minimize any adverse impact on
wetlands.
Endangered Species Act
16 USC. 1531 et sea.: 50 CFR Part 2QQ. 50 CFR Part 402 '
The Endangered Species Act requires actions .to conserve
endangered or threatened species. -The U.S. EPA consulted the
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Department of the Interior and has determined that there are no
endangered or threatened species in* or around the Albion-Sheridan
Township Landfill site and therefore, no endangered or threatened
species will be impacted by site contamination or by site
remediation.
KEY STATE ARARS .(See Feasibility Study Report for complete
listing of action, chemical and location specific ARARs.)
1. Action Specific
Michigan Environmental Response Act (Act 307) -- Michigan Admin.-
Code R. 299.601 et sea.
Among other provisions, Act 307 authorizes the MDNR to issue
regulations related to remediation of contaminated sites in the
State of Michigan.. Part 7 of the Act 307 Rules is an ARAR for
this Site. This Part requires that a remedial action achieve a
degree of cleanup identified by the Act as either Type A (cleanup
to background levels or to a method detection limit), Type .B
(cleanup to risk-based levels) or Type C (cleanup under site-
specific conditions).
•At this site, the-landfill itself could not be cleaned up to*
background or method detection levels (a Type A cleanup) nor to
risk-based levels (a Type B cleanup) without excavating and
removing the landfilled waste at a great cost which would yield
little additional protection or environmental benefit.
For groundwater at this Site, background levels of arsenic may be
achieved in time by natural oxidation, which is to be monitored
by the selected remedy. The groundwater treatment required under
the contingent remedy will not meet background levels during
active treatment because U.S. EPA has determined that "the
additional treatment is not appropriate to the small amount of
contamination present at the site and its partly naturally
occurring origin. Type B criteria for arsenic are below the'
method detection limit and may never be met for groundwater at
this Site because of the naturally occurring background levels of
arsenic in groundwater.
U.S. EPA has determined that the substantive requirements of a
.Type C cleanup are relevant and appropriate at this Site. The
substantive requirements of a Type C cleanup include a
requirement that any remedial action which involves on-site
containment of a hazardous substance shall include provisions for
the long-term monitoring of the site to assure the effectiveness
and integrity of the remedial action. The selected remedy and
the'contingent remedy will meet this requirement and all other
substantive relevant and appropriate requirements of Act 307 with
respect to a Type C cleanup.
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Solid Waste Manaaemenc Act 'Act 541) -- Michigan Admin. Cede
R. 299.401 et sag.
Pares 3 and 4 of che Act 641 Rules establish closure and post-
closure rules for industrial solid waste and municipal solid '
waste landfills. These rules'are not applicable to the Site
because it did not receive waste after October 9, 1991; however,
the rules are relevant and appropriate. The FML cap selected for
this landfill meets both the requirements of Rule 425(5) for a
municipal solid waste cap and of Rule 304(6) for an industrial
solid waste cap. The gas control and groundwater monitoring
measures of the selected remedy and contingent remedy will also
meet Act- 641 requirements.
Michigan Air Pollution Act (Act 348) -- Michigan Admin. Code R.
336.1901 et sea.
This Act provides for fugitive dust control and emission control
for air contaminants in quantities, that will cause injurious
effects and is an ARAR for this Site. The excavation of drums, "
cap construction, and other portions of the selected remedy and
the contingent remedy will meet these requirements.
Michigan Soil Erosion and Sedimentation Control Act (Act 347)
This Act requires soil erosion control and sedimentation plans
for any earth changes of one or more acres if within 500 feet of
a lake or stream. The North Branch of the Kalamazoo River is
within 500 feet of this landfill, therefore this Act is an ARAR
for the Site. The earthmoving portions of the selected remedy
and the contingent remedy will meet these requirements.
Michigan Como. Laws Ann. Section 257.722 ("Frost Laws")
These requirements pertain to maximum axle loads permitted over
certain Michigan highways during certain months of the year, to
prevent damage caused by excessive loads during the period when
the weather alternates between freezing and thawing. These
requirements are riot ARARs because they do not pertain to on-site
activities; however, the do constitute applicable off-site
requirements. • •
3. Cost Effectiveness
Cost effectiveness compares the.effectiveness of an alternative
in proportion to its cost of providing environmental benefits.
The costs associated with the implementation of the entire
selected remedy and the contingent remedy are listed below. The
present value cost's below are lower than those, issued in the
Proposed Plan because the discount rate was updated to 7 percent.
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Total estimated costs for the selected remedy at the Albion-
Sheridan Township Landfill Site are:
Capital Cost O&M. Present Value
$ 2,654,734 $ 1,197,801 $ 3,852,535
If the contingent remedy for groundwater treatment is implemented
at. the site, the total estimated costs for. the selected remedy
are:
Capital Cost O&M. 30 Yr. Present Value
$ 3,086,196 $ 1,345,923. $> 4,432,119
Both the selected remedy and the contingent remedy for this site
are cost effective because they provide the greatest overall
effectiveness proportionate to costs when compared to the other
alternatives evaluated. The estimated cost of drum removal and -
disposal is proportionate to the risk reduced by removing known
hazardous wastes and liquid wastes which could easily contaminate
groundwater. The estimated cost of the selected landfill cap is
intermediate between the other two cap alternatives and assures a
high degree of certainty that the remedy will be effective in the
long-term due to the significant reduction of the mobility of the
contaminants achieved through containment of the source material
and the decrease in leachate generation. The estimated cost of
groundwater monitoring, and the additional cost of in-situ
treatment of arsenic to the MCL if necessary, are proportionate
to the risk present- from the groundwater. The addition of
arsenic treatment to below the MCL by either in-situ or ex-situ
methods would provide only a limited additional reduction of risk
•to public health and the environment, which is not justified by '
the additional cost for these alternatives, since it is believed
that additional lowering of contaminant levels will occur by
natural oxidation.
4. Utilization of Permanent Solution* and Alternative
Treatment Technologies or Resource Recovery
Technologies to the »»•*•»"»«" Extent Practicable
The selected remedy and contingent remedy represent the maximum
extent to which permanent solutions and alternative treatment
technologies can be used in a cost-effective manner at this site.
Of those alternatives that are protective of human health, and the
environment and that comply with ARARs, U.S. EPA has determined
that the selected remedy and the contingent remedy provide the
best balance in terms of long-term effectiveness and permanence,
reduction of toxicity, mobility, or volume of contaminants, short
term effectiveness, implementability, and cost,., taking into
consideration State and .community acceptance-.
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The removal cf hazardous and liquid waste drums, installation and'
maintenance cf a final cover for the landfill, groundwater
monitoring, and restriction of site access through installation
of a fence and institutional controls, will provide the most
permanent solution that is practical and proportionate to the
cost.
5. Preference for Treatment as a Principal Element
Based on current information, U.S. EPA and the State of Michigan
believe that the selected remedy and the contingent remedy are
protective of human health and the environment and utilize
permanent solutions and alternative treatment technologies to the
maximum extent possible. The selected remedy satisfies the
statutory preference for treatment of the hazardous substances
present at the site as a principal element by requiring treatment
of drummed hazardous wastes present on sice. The selected remedy
also includes treatment of gasses generated by the landfill,
unless ARARs are met without treatment. If the contingent remedy
is implemented, groundwater also will be actively treated in-situ
to remove arsenic.
L. SUMMARY
The selected remedy and the contingent remedy will satisfy the
statutory requirements established in Section 121 of CERCLA, as
amended by SARA, to protect human health and the environment,
will comply with ARARs, will provide overall effectiveness
proportionate to its costs, and will use permanent solutions and
alternate treatment technologies to the maximum.extent
practicable. Treatment of hazardous wastes found on site is a
component of the selected remedy. Treatment is also a component
of the contingent remedy for groundwater clean-up, if natural
oxidation does not occur as fast as predicted.
M. RESPONSIVENESS SUMMARY
The public participation requirements of CERCLA sections 113 (k)
(2) (i-v) and 117 of CERCLA have been met during .the remedy
selection process. Section 113 OO (2) (B) (iv) and 117(b) of CERCLA
requires the EPA to respond "... to each of the significant
comments, criticisms, and new data submitted in written or oral
presentations" on a proposed plan for a remedial action. The
Responsiveness Summary addresses concerns expressed by the
public, potentially responsible parties (PRPs), and governmental
bodies in written and oral comments received by EPA and the State
regarding'the proposed remedy for the Albion-Sheridan Township
Landfill Site.
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Background
U.S. EPA issued a fact sheet to the public in Albion, Michigan,
at the beginning of the Remedial Investigation. The Agency also
hosted a. public meeting on August 25, 1992, to provide background
information on the Albion-Sheridan Township Landfill site,
explain the Superfund process, and provide details, of the
upcoming investigation. The remedial investigation was completed
in July, 1994, and in August, 1994, U.S. EPA issued a second fact
sheet to summarize the results of the investigation.
The RI/FS reports and the Proposed Plan for the Albion-Sheridan
Township Landfill site were released to the public for review in
September, 1994.. An information repository has been established
at the following location: Albion Public Library, 501 S.
Superior Street, Albion, Michigan. The Administrative Record has
been made available to the public at the U.S. EPA Docket Room in
Region V and at the information repository. •
A public meeting was held on October 5, 1994 to discuss the FS
and the Proposed Plan. At this meeting, representatives from the
U.S. EPA and MDNR answered questions about the Site and the
remedial alternatives under consideration. Formal oral comments
on the Proposed Plan were documented by a court reporter. A
verbatim transcript of this public meeting has been placed in the
information repositories and Administrative Record. Written
comments were also accepted at this meeting. The meeting was
attended by approximately 35 persons.
The FS and Proposed Plan were available for public comment from
October 3, 1994, through December 4, 1994. Comments received
during the public comment period and U.S. EPA's responses to
those comments are discussed below and are a part of this ROD.
Advertisements announcing the availability of the Proposed Plan,
start of the comment period and extension of the comment period
were published in the' Albion Reporter.
During the comment period, EPA received approximately 11 written
submittala containing comments on the proposed plan.
Summary of Significant Comments
Comments by thm Calhoun County Health Department
COMMENT: The Calhoun County Health Department supports the
recommended alternatives.
COMMENT: 'They would like to leave the option open for •.
Alternative SB if monitoring showed an increase in any hazardous
levels of contamination or if the groundwater plume changes
direction.
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RESPONSE: U.S. EPA has chosen Alternative 53 (in-situ treatment
of groundwater) as a contingent remedy, which will be implemented
if arsenic contamination in grcundwater is not decreasing fast
enough or if residential wells are threatened..Other contaminants
are not present in the groundwater at hazardous levels. The
groundwater monitoring which is part of both the selected and
contingent remedy includes monitoring of flow directions.
Comments by the Officers of the Church of the Nazarene
COMMENT: The officers of the Church of the Nazarene are
concerned because they live close to the area and are concerned
about their members and children at their church and in the
neighborhood. They recommend the following:
Remove drums •
Cap landfill • '
Treat gas ' • •
Monitor groundwater
RESPONSE: In general, U.S. EPA agrees with these
recommendations. However, the Agency may allow landfill gasses
to be vented without treatment if it is demonstrated that is safe
and will meet all applicable or relevant and appropriate
"requirements.
Comments by Private Citizens
COMMENT: Mr,. Kenneth Lampart agrees with the recommended
alternatives: 2, 3C, 4B, 5A, and any or all other actions needed
to protect the public of Albion-Sheridan Township and Jackson
County, Parma Township, and Amberton Village.
COMMENT: Mr. Lampart asks why this process is taking so long.
RESPONSE: U.S. EPA's initial action at this site was the removal
of drummed waste from the surface of the landfill, where .passers-
by might come into contact with hazardous wastes. This action
was accomplished relatively quickly following notification. The
other possible threats at the site -- the large mass of buried
wastes, possible contamination of soils, surface and groundwater
surrounding the site -- did not appear to present as much of an
immediate threat and so were dealt with under. the Remedial
Program at U.S. EPA. The Remedial Program takes more care to
thoroughly understand the extent of contamination at the site, so
that the cleanup actions which are taken can be the'final actions
needed at the site. The Remedial Investigation/Feasibility Study
at this site took three years to complete, which is slightly
faster than the average time of four years. This time was spent
investigating and negotiating with potentially responsible
parties, investigating the site, studying possible clean-up
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options, conferring with the State of Michigan and the public,
and choosing an option.
COMMENT: Mr. Lampart asks what kind of water and other
contaminants he is unknowingly subjected to from elsewhere.
RESPONSE: The purpose of U.S. EPA's investigation was to
determine the 'nature and extent of contamination from the Albion-
Sheridan Township Landfill site. No significant contamination
was discovered from other sources during our investigation.
COMMENT: Mr. Lampart asks when the "22 full drums and 24 empty
drums" were removed from the landfill, how many contained
hazardous wastes, solids, and liquids? He also asks how deep the
samples were taken from. '.
RESPONSE: The 1990 removal report documents that the drums
appeared to contain grease and paint wastes, but does not
indicate how many were solids and. liquids. Four drums were
analyzed and found to contain hazardous wastes. All of the drums
.removed in 1990 were found on the surface of the landfill.
During its later investigation, U.S. EPA sampled landfill wastes
up to 36 feet deep at three locations and found no hazardous
wastes. However, hazardous wastes were found by the MDNR in
drums buried at one location in the landfill. This ROD requires
removal of those drums which contain hazardous or liquid wastes,
which could contaminate groundwater.
COMMENT: Mr. Lampart asks, if he entered the .fenced in area and
walked around, would his health be at risk from exposure?
RESPONSE: The fence was put up for that very purpose, to
eliminate any health risk from exposure .to waste which is inside
the fence. Although much of the waste inside the fence is
presently covered by sandy soil, there are areas where it is
exposed on the surface.
COMMENT: Mr. Lampart asks, since the Kalaraazoo River is not of
any significant health risk, should he get his drinking water
from there?
RESPONSE: Although there are no significant health risks to
recreational use of the North Branch of the Kalamazoo River
caused by the landfill, U.S. EPA does'not recommend using it as a
drinking water source without appropriate treatment.
COMMENT: Mr. Lampart asks, what is the one location where
• arsenic presently exceeds the federal drinking water standards
and is anybody using water from this location now?
R'ESPONSE: The concentration of arsenic exceeds drinking water
standards in one monitoring well (MW06SB), drilled by U.S. EPA
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immediately adjacent to the landfill. No one is using this well
as a drinking water source and there are no residential wells
adjacent to t.his monitoring well. The residential well closest
to'the landfill is•located immediately south of the landfill and
is deep enough not to be contaminated by the landfill plume.
COMMENT: Mr. Lampart asks whether Harrington School might have
received exposure from-the landfill, for example by truck
traffic, dust, or wind, and whether in general the air is safe
when the wind blows off the dump site.
RESPONSE: Although there is no way of knowing historical
exposure patterns, U.S. EPA's investigation showed no exposure to
the Harringtpn School from the Albion-Sheridan Township Landfill
site at this time. With the current vegetative cover, there is
minimal dust generated from the site and gas generated by'the
landfill is released over a wide area at low concentrations.
However, U-.S. EPA believes expeditious construction of the
landfill cap and implementation of landfill gas controls will
further insure the safety of .surrounding residents and
businesses. The type of cap chosen by U.S. EPA 'for this landfill
uses a flexible membrane liner instead of clay to stop
infiltration and therefore will involve a lower level of truck
traffic during construction than a clay cap.
^COMMENT: Mr. Lampart asks whether the water for Amberton Village
should be filtered or treated before-it is supplied to homes and
whether it is -safe to drink the water from residences near the
landfill.
RESPONSE:. The Amberton Village well and all residential wells
near the landfill were sampled during the remedial investigation
and will continue to be monitored in the future. Water in all of
the residential wells and the Amberton Village well met federal
drinking water standards and is safe to drink.
COMMENT: Mr. Alan R. Moore states that during the public
hearing, contaminants were listed as "low" and asks that they be
listed as actual values compared to average background.
RESPONSE: There are too many'actual values involved to list
here. .However, the Remedial investigation Report lists all
actual values and background values for surface and subsurface
soils, groundwater and surface water sampled at the site. This
Report is part of the Administrative Record for the site and is
available at the Site Repository at the Albion Public Library and
at U.S. EPA Region 5 headquarters in Chicago.
COMMENT.-. Mr. Moore asks whether there could be a cost/benefit
analysis for the remedy.
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RESPONSE: As is discussed in Section H of this ROD, U.S. EPA
bases its remedy selection on nine criteria. To be considered
for final selection, a remedy must provide overall protection of
human health and the environment and must comply with all
applicable or relevant and appropriate requirements (or provide
grounds for a waiver). The proposed re-re • is then selected by
determining which provides the best combii.l..ion of attributes
with respect to long-term effectiveness; short-term
effectiveness; reduction in toxicity, mobility, or volume;
implementability; and cost. The final remedy is selected based
on all these criteria and State and community acceptance, based
on comments received during the public comment period. The
Superfund process as provided in the National Contingency Plan at
this time does not include assigning dollar values to
improvements in human health risks and the environment, as would
be required in a cost/benefit analysis.
COMMENT: Mr. Moore asks why the landfill contents couldn't be ;
excavated and placed in an approved sanitary landfill.
RESPONSE: The costs associated with this would be prohibitive.
In addition, the amount of time required to excavate and
transport all of the waste would place nearby residences and
businesses at risk from much greater exposure than capping the
landfill in place.
COMMENT: Ms. Sally Ammerman asks how close to the landfill new
drinking waters wells would have to be, to be at risk.
RESPONSE: This ROD requires the imposition of deed restrictions
or local ordinances prohibiting domestic use water wells which
draw water from the arsenic contaminant plume shown on Figure 4.
This area extends approximately 600 feet to the southwest of the
landfill. Outside of this area, arsenic is at or below the
natural background level in the region. Water wells close to the
plume boundary (defined as 2 ug/1 arsenic) shown on Figure 4 may
draw water from the plume if they are very shallow; deeper, wells,
such as the existing private well immediately south of the
landfill, may not be affected because they are deeper than the
plume.
COMMENT: Ms. Ammerman, Mr. Robert Lopez, and Mr. Mike. LaNoue are
concerned that drilling of large volume water wells by the
proposed Albion Renewable Energy Power Plant may cause migration
of contaminants from the landfill to the City of Albion's Clark
Pumping Station or to private water wells. Mr. Lopez also
requests that the hydrogeological study include the area of the
proposed plant. • •
RESPONSE: If the proposed plant is built, it is very unlikely
that wells at that location would have any affect on the
contaminant plume at the landfill. However, if wells were
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proposed at thac or any other location which were likely co
spread the contaminant plume or change its flow direction, U.S.
EPA and MDNR" have the authority to take action to protect human
.health and the environment, under CERCLA Section 104 and 106 and
Michigan Act 307, including seeking legal•injunctions.
The hydrogeolpgical study of the Albion-Sheridan Township
Landfill did not include the area of the proposed plant because
it is approximately 3/4 mile upgradient of the landfill. Except
for wells installed to determine background conditions, the
majority of U.S. EPA's hydrogeologlcal investigation was
concentrated on areas down-gradient of the landfill, the
direction in which contaminants'would flow.
COMMENT: Ms. Doreene Derr,' Mr. Robert Lopez, and Mr. Mike LaNoue
each stated that there are six Superfund Sites in the Albion area
and it is essential for Project Managers to coordinate with each.
other. Others at the public meeting held to discuss U.S. EPA's.
Proposed Plan were confused about the various governmental lists*
of cleanup sites. •
RESPONSE: U.S. EPA agrees that it is important for-Project
Managers of Superfund sites to coordinate and to consider the
wider community in all Superfund site decisions. In some cases,
such as at the Albion-Sheridan Township Landfill, contamination
is fairly localized and does not interact with any other
contamination in the area.
Although there are multiple contamination sites in Albion, U.S.
EPA considers only two to be Superfund sites.• Historically, the
term "Superfund Sites" has meant those on the National Priorities
List, a list of high-priority cleanup sites which are eligible
for funding using Superfund money. The two sites in this
category in Albion are the McGraw-Edison Corporation Site and the
Albion-Sheridan Township Landfill Site. A soil and groundwater
cleanup is in progress at the McGraw-Edison site.'
As the cotranentors have pointed out, there are a number of
additional sites in the Albion area designated as sites of
environmental contamination on a list, compiled by the Michigan
Department of Natural Resources, of sites.addressed or needing to
. be addressed under the Michigan Environmental Response Act (MERA
or Act 307}. These sites and others may also appear On a master
list of sites addressed or needing to be addressed under the
Federal Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA). this federal list is called the CERCLA
Information System, or "CERCLIS". Following investigation, State
or Federal action may or may not be taken at these additional
sites. . . •
COMMENT: Mr. LaNoue requests that U.S. EPA form a geographic
initiative area in Albion to address the multiple waste sites and
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other environmental concerns in che Albion area. He also made
.additional comments concerning the proposed Albion Renewable
Energy Power Plant.
RESPONSE: U.S. EPA declines to designate Albion as a geographic
initiative area at this time. U.S. EPA and the States undertake
geographic initiatives to accelerate environmental protection in
areas which, because of their size and/or complexity, outstrip
the resources and authorities .of a single agency. Historically,
these areas have been chosen through comparative risk
assessments. The geographic initiatives undertaken in Region 5
to date are in major urban areas (e.g. Detroit/southeast
Michigan) or areas of high industrial concentration (e.g.,
Gary/northwest Indiana). Albion is small enough that U.S. EPA
and the Michigan Department of Natural.Resources believe they can
coordinate together without an official designation as a
geographic initiative area.
U.S. EPA notes Mr. LaNoue's comments concerning the proposed
power plant, but does not respond to them here, since this.
responsiveness summary focuses on the Albion Sheridan Township
Landfill Site. We recommend Mr. LaNoue and other concerned
citizens contact- the Michigan Department of Natural Resources
concerning the current status of the project as it is our
understanding that it may be temporarily or permanently on hold.
Comments by Potentially Responsible Parties:
COMMENT: Bull & Associates, Inc. ("HAI"), commenting on behalf
of the City of Albion, states that they generally concur with the
approach presented in the Proposed Plan for the Site.
COMMENT: K&Z, Corning, Inc. ("Corning") and Cooper Industries
("Cooper") agree with Alternative 2A for removal arid disposal of
drummed waste. HAI recommends the ROD incorporate language which
could provide the flexibility to limit removal to only drums that
are structurally sound and determined to contain hazardous waste
in order to minimize transport/disposal costs and reduce exposure
risks during closure. They recommend that criteria for
determining which drums stay and which are to be removed be.
incorporated into the ROD. Corning wishes to confirm their
understanding that any drums found that contain non-hazardous
solid waste would be left in the landfill as they pose no threat
to groundwater. Cooper Industries agrees with the Agency that
drums containing unidentified liquids and solid hazardous waste
which are discovered during the remedial action will be properly
disposed.
RESPONSE: U.S. EPA agrees that only drums which are structurally
sound enough to be removed with wastes essentially intact should
be removed from the landfill. The. ROD provides specific language
concerning the selection of drums for off-site disposal.
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Coming's underscanding is correct that -drums containing non-
hazardous solid wastes would be left in the landfill. Details of
drum removal .and disposal can be found in Section I of the ROD.
COMMENT: HAI and Corning concur with the recommendation for a-
flexible membrane liner (FML) to cap the landfill rather than a
:lay cap, because it will be a more effective barrier for
reducing surface water infiltration and is probably the most cost
affective. . ' -
COMMENT: HAI, Corning, and Cooper state that the FML cap
configuration as shown on Figure 3.3 of the FS should be changed
so that the permeable drainage layer is immediately above the
FML, to provide more protection against punctures in the liner
and a better drainage pathway. They also recommend that the ROD
allow for performance demonstrations that alternate material
(i.e., geoco'mposite) can be considered for a drainage layer.
RESPONSE: U.S. EPA has considered-the technical merits of.this ^
request and determined that the requested change should be made."
Section I of the ROD specifies the drainage layer to be directly
on top of the FML and also incorporates the requested flexible in
material. ' •
COMMENT: HAI, Corning, and Cooper all support the installation
of a passive gas venting system, at least initially. HAI states
that ah active extraction system is known to exacerbate landfill
settlement, which ultimately may resu.lt in increased cap
maintenance costs. In addition, HAI .states that since a gas
monitoring plan will have to be developed for the site, it will
be possible to monitor the effectiveness of -a passive venting
system. Corning states that the generation rate and composition
of landfill gas should be evaluated during Remedial Design and
the interconnected piping and blower/flare facility of an active
system should be added only if the gas concentrations exceed
ARARs. Cooper states that it is U.S. EPA's proposal that the
passive venting points be installed first, with active gas
collection to be ajdded only if vented concentrations exceed U.S.
EPA or MDNR criteria.
RESPONSE: In Section I of this ROD,"U.S. EPA is requiring
installation of an active gas collection and treatment system
unless, during, the design phase, it is demonstrated that a
passive gas venting system will meet all applicable or relevant
and appropriate requirements. If. U.S. EPA's evaluation, in
cooperation with that ;pf the MDNR, indicates that passive venting
will meet all requirements, it will be1 approved.
COMMENT: HAI and'Corning agree with the selected groundwater
alternative for groundwater monitoring. HAI states that the
concentration and extent of the groundwater contamination does
not appear to warrant the implementation of an active groundwater
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remedy, nor present a significant risk to human health and the
environment. Corning states that the reduced infiltration
through the waste material and the natural attenuation of arsenic
should mitigate the impacts to groundwater at the site'.
COMMENT: HAI requests that the U.S. EPA provide the rationale
for such an extensive groundwater monitoring program (especially
the quarterly monitoring of residential wells) in light of the
objective defined in the FS. The groundwater flow conditions of
the bedrock aquifer documented in the RI indicate that nearby
residential wells apparently receive water from the northwest
(presumable the wells are set into the bedrock) and, thereby, to
a large degree, are hydraulically isolated from the landfill.
The monitoring of these residential wells should only occur as a
contingency based on groundwater quality results of wells
affected by the landfill, rather than a pre-determined, arbitrary
quarterly schedule.
RESPONSE: The groundwater monitoring system under the selected *
alternative has several purposes: to monitor the effectiveness
of natural oxidation in reducing arsenic concentration, to
monitor other contaminants which are emanating from the site at
less hazardous levels, and to ensure that there is no impact to
•any residential wells from contamination emanating from the site.
As explained in Section I of the ROD, the ROD retains flexibility
regarding which specific wells will be monitored in the long term
and regarding many details of the sampling schedule.
The RI groundwater flow maps do not indicate that the groundwater
source for these wells is from the northwest. Rather, the flow
maps, along with the groundwater plume contour maps show
groundwater from the landfill heading southwest towards the
residential wells on East Erie Road. The U.S. EPA believes that
quarterly sampling for residential wells is appropriate given the
close proximity of the wells to the landfill.
COMMENT: HAI states that the ROD should include language which
allows the proposed groundwater monitoring network to be amended
by data collected from the installation of the two proposed
monitoring well nests.
RESPONSE: The ROD requires the installation of four additional
monitoring wells during the design phase, including one well nest
of two wells and two isolated wells. As explained in. Section I
of the ROD, the ROD retains flexibility regarding which specific
wells will be monitored in the long term and regarding many
details of. the sampling schedule.
COMMENTj Several parties commented on parameters to be analyzed
in the groundwater monitoring program. HAI assumes that
groundwater samples will be analyzed for only inorganic
parameters because they state that no volatile organic compounds
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which could be directly accribuced to the landfill were detected.
HAI also states that a semi-annual VOC sampling frequency is more
appropriate .given the results of the risk assessment.and the
requirements of Act 641. Corning/ Inc. comments that the
groundwater analytical program has not been specified and that
they recommend that the analytical program include only the
analytes of concern' identified during the- Remedial Investigation.
Cooper Industrie* suggests that TAL/TCL analytes be used for the
initial sampling of any newly installed well, with subsequent
quarterly and annual testing to be for only those analytes of
concern to Cooper and the Agency.
RESPONSE: Section I of the ROD includes some flexibility for
developing a target list for groundwater monitoring once a
sufficient data-set has been established. The ROD requires one
complete round of groundwater samples to be analyzed for Target
Compound List and Target Analyte List parameters, ammonia and
field parameters, to provide a wider basis for design of the
groundwater monitoring program.. For subsequent long-term
monitoring, the ROD retains some flexibility regarding the target
parameter list.
COMMENT: Corning and Cooper state that the Feasibility Study
recommends 30 mil PVC or -40 mil VLDPE for' the liner material.
Corning and Cooper recommend a stronger and thicker material such
as 40 to 60 mil HOPE for the liner. Corning states that the
sturdier liner material will be easier to install, is less likely
to tear during installation, and will have better seam integrity.
RESPONSE: The ROD requries a flexible membrane liner which is
equivalent to or less permeable than a 40 mil low density
polyethylene or 30 mil polyvinyl chloride. If U4S. EPA determines
during -the remedial design that a stronger or thicker material
should be used for the liner, the ROD allows "that flexibility.
COMMENT: Corning states that the composite liner system provides .
only 30 inches of cover for the FML and that an additional six
inches of cover soil should be added to ensure that the FML xs
below the frost line. Cooper states that they are evaluating
whether the 30" depth to the flexible membrane liner is sufficient
to prevent rupture during Michigan freeze/thaw cycles, and requests
the Agency consider allowing parties the option to increase the
depth of the FML by providing a thicker cover, if warranted.
.RESPONSE: The landfill cover required in the ROD is a minimum
thickness. U.S. EPA does not believe it is essential for an FML to
be below the frost line. However, if U.S. EPA determines during
Remedial.Design that thicker layers should be used, the ROD allows
thaf flexibility.
COMMENT: Corning and-Cooper state that the general landfill cap
contours in the Feasibility Study show steep slopes where "cut ar.d
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fill" regrading of the existing topography could reduce slope
angles, provide better stability, and reduce cap material volumes.
They request flexibility in the contour design to accommodate these
potential benefits.
RESPONSE: There is flexibility included _n the ..3D concerning the
final slopes and how they are attair.aa, -Ithouc.i the requirements
of Michigan Act 641 must be'met. Private property boundaries may
restrict cut and fill regrading in some areas. These are described
in Section I of the ROD.
COMMENT: Corning states that the groundwater monitoring program
'for the site, as specified in the Feasibility Study, includes 27
wells. It is Corning's understanding that four new wells .will be
installed during the Remedial Design phase and added to the long-
term monitoring program to be sampled during quarterly and/or
annual events.
RESPONSE: The ROD requires the installation of four additional
monitoring wells during the design phase. Aa explained in Section
I of the ROD, the ROD retains flexibility regarding which specific
wells will be monitored in the long term and regarding many details
of the sampling schedule. The monitoring scheme presented in the
Feasibility Study is an example of a monitoring program which would
be' acceptable by U.S. EPA.
COMMENT: Cooper states that the RI/FS Report is silent regarding
supplemental investigation activities; however, during a meeting
U.S. EPA mentioned the need for additional monitoring wells to be
installed during the remedial design phase of the project. Cooper
believes that the current monitoring well network and associated
compliance monitoring at the site is sufficient to determine the
effectiveness of the cap to prevent' leaching to groundwater and to
ensure that is no-potential impact to domestic water supplies.
RESPONSE: U.S. EPA has determined, in consultation with the MDNR,
that the new wells are necessary and they are required by this ROD.
The four additional monitoring wells are shown on Figure 3.4 of the
Feasibility Study as proposed new wells and were also included in
the Proposed Plan which was available for public comment from
October 3 to December 4, 1994. The wells at MW15 and MW16 are
needed to further define the contaminant plume to the west and
south of the site, respectively, in areas where -the groundwater
gradients are low and flow directions somewhat variable. The MW15
well is intended to- ensure that no contamination is flowing toward
the Orchard Knoll Subdivision, where groundwater contaminants of
unknown origin were detected in the past. The two deep bedrock
wells, (at 'MW16 and MW09) are needed to further define the-, vertical
extent of contamination, since at present there is only one deep
bedrock well at the site.
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COMMENT: Cooper states that the Risk Assessment Report does not
identify which analytical methods are to be utilized for the
quarterly and annual groundwater monitoring well compliance
sampling detailed in Figure 3.4.
RESPONSE: The ROD retains some flexibility regarding analytical
methods for groundwater monitoring, although it does require that
methods have detection limits at or below the federal maximum
contaminant level (MCL) , for those analytes which have an MCL.
Specific methods will be approved as part of a Quality Assurance
Project Plan during Remedial Design.
COMMENT: Cooper states that the RI Report describes that
residential wells, surface water 'samples, and selected groundwater
monitoring well samples. were analyzed using . the "Region 5
Residential Well REQUIRES." No laboratory contacted by Cooper was
familiar with the "Region 5 Residential Well REQUIRES." Cooper
requested and has been supplied with,the analytes of concern and
associated detection levels, but that information is still not
specific enough regarding the "Region 5' Residential Well REQUIRES""
protocols to allow comment by Cooper. For residential wells,
Cooper suggests that a gas chromatograph method, which has lower
detection levels than a typical GC/MS method and is a more standard
methodology, be used rather than the Region 5 Residential .Well
REQUIRES.
RESPONSE: During the Remedial Investigation, residential wells
samples and selected other samples were analyzed under U.S. EPA's,
Contract Laboratory Program as a Special Analytical Service
(REQUIRES) because lower detection limits were needed. As
discussed in Section I of the ROD, the specific analysis methods
for groundwater samples during Remedial Design and Remedial Action
will be proposed by the party conducting the design and subject to
approved by U.S. EPA as part of the Quality Assurance Project Plan.
N. GLOSSARY
Applicable, or Relevant and Appropriate Requirements (ARARs)
Section 121 (d) of CERCLA requires that remedial actions meet
legally applicable or relevant and appropriate requirements (ARARs)
of other environmental laws. Legally "applicable" requirements are
those cleanup, standards, standards of control, 'and other
substantive environmental protection requirements, criteria or
limitations promulgated .under Federal or State law that
specifically address a hazardous substance, pollutant, contaminant,
remedial action, location, or other circumstances at a CERCLA site.
"Relevant and appropriate" requirements are 'those requirements
that, while not legally applicable to the remedial action, address
problems or situations sufficiently similar to those encountered at
the site that their use is well suited to the remedial action.
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Non- promulgated advisories or guidance documents issued by federal
or state governments ("to-be-considered or TBCs") do not have the
status of ARARs; however, where no applicable or relevant and
appropriate requirements exist, or for some reason may not 'be
sufficiently protective, non-promulgated advisories or guidance
documents may be considered in determining the necessary level of
clean up for protection of human health and the environment.
Aquifer
A body of rock that is sufficiently permeable to conduct
groundwater and to yield economically significant quantities of
water -to wells and springs.
Baseline Risk Assessment .
The baseline risk assessment' is an analysis of the potential
adverse health effects caused by hazardous substance releases from
a site in the absence of any actions to control or mitigate these
releases. The baseline risk assessment assumes no corrective
action will take place and no site-use restrictions or"
institutional controls such as fencing, groundwater use
restrictions or construction restrictions will.be imposed. There
are four steps in the baseline risk assessment process: data
collection and analysis; exposure assessment; toxicity assessment;
and risk characterization.
Cancer Potency Factors (CPFs)
Cancer potency factors (CPFs) have", been developed by EPA' s
Carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day) 'l,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the. excess
lifetime cancer risk associated with exposure at that intake level.
The term "upper bound" reflects the conservative estimate of the
risks calculated from the CPF. Use of this approach makes
underestimation of 't:he actual cancer risk highly unlikely. Cancer
potency factors are derived from the results of human
epidemiolocpLcal studies or chronic animal bioassays.
Comprehensive Environment Response. Compensation, and Lability Act
(CERCIA1
A federal law passed in 1980 and revised in 1986 by the Superfund
Amendments and Reauthorization Act. CERCLA created a special tax
that goes into a trust fund, commonly, known as "Superfund", to
investigate and clean up abandoned or uncontrolled hazardous waste
sites.
Excess Lifetime Cancer Risks
Excess lifetime cancer risks are the sum of all excess cancer
lifetime risks for all contaminants for a given scenario. Excess
Lifetime Cancer Risks are determined by multiplying the intake
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level by the cancer potency factor for each contaminant of concern
and summing across all relevant chemicals and pathways. These
risks are' probabilities that are generally expressed in scientific
notation (e.g. l X 10"6) . An excess lifetime cancer risk of l x 10"' '
indicates that a person's chance of contracting cancer as a result
of site.related exposure averaged over a 70-year lifetime may be
increased by as much as 1 in one million.
Groundwater
The water beneath the earth's surface that flows through soil pores
and rock openings. Often utilized as a source of drinking water.
Hazard Index (HI)
The Hazard Index (HI), an expression of non-carcinogenic toxic
effects, measures whether a person is being exposed to adverse
levels of non-carcinogens. .The HI provides a useful reference
point for gauging the potential significance of multiple
contaminant exposures within a single medium or across multiple
media. The HI for non-carcinogenic health risks is the sum of all
contaminants for a given scenario. Any Hazard Index value greater
than 1.0 suggests that a non-carcinogen potentially presents an
unacceptable health risk.
Inorganic compounds
Chemical compounds that are composed of mineral materials,
including salts and minerals such as iron, aluminum, mercury, and
zinc.
Leachate
A liquid (usually water from rain or ' snow) that has percolated
through wastes and contains components of those wastes.
MCLS
These are Maximum Contaminant Levels (see primary Drinking Water
Standards). •
National Priority List (NPL)
U.S. EPA's list of top priority hazardous waste sites that .are
eligible for federal money under Superfund.
National Contingency Plan (NCP)
The Federal regulation that sets the framework for the Superfund
program. The NCP identifies the governmental organizations
involved in the remedial response, outlines their roles and
responsibilities, and discusses the interrelationships of these
organizations. In addition, the NCP provides guidelines for
planning and conducting response activities.
Organic Compounds
Chemical compounds composed primarily of carbon, including
materials such as solvents, oils, and pesticides.
-------
51.
Permeability
The ease with which groundwater moves through earth materials.
Movement is controlled by the size and shape of spaces between
zhese materials.
Present Value Cost
An economic term used to described today's cost for a Superfund
cleanup and reflect the discounted value of construction and future
operation and maintenance costs. U.S. I~A uses present value costs
when calculating the cost of alternatives for long-term projects.
Primary Drinking Water Standards (MCLs)
Primary Drinking Water Standards are maximum contaminant levels
(MCLs) set for substances that can pose a~ threat to health when
present in drinking water at certain levels; Because these
substances are of concern for health (not just aesthetic ) reasons,
primary MCLs are enforceable under the Safe Drinking Water Act.
Record of Decision (ROD) . .
A document signed by EPA's Regional Administrator, outlining the
selected remedy for a Superfund site. The ROD includes the
Responsiveness Summary, which addresses concerns presented to EPA
during the public comment period.
Reference Doses (RfDa)
Reference doses (RfDs) have been developed by U.S. EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting non-carcinogenic effects.' RfDs,. which are
expressed in units of mg/kg-day, are estimates of average daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media, (e.g., the
amount of a chemical ingested from contaminated drinking water) can
be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which 'uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors help
ensure that the RfDs will not underestimate the potential for
adverse non-carcinogenic effects to occur.
Resource. Conservation and Recovery Act of 1976 (RCRA)
The federal law that establishes a regulatory system to require the
safe and secure procedures to be used in treating and disposing of
hazardous waste.
Semi-Volatile Organic Compounds (SVOCs)
Organic chemicals that vaporize less readily than VOCs. These
.compounds, include many polynuclear aromatic hydrocarbons and
pesticides. • • '
Superfund Amendments and Reauthorization Act of 1986 (SARA)
Amendments to the Superfund Law, CERCLA.
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52
Volatile Organic Compounds (VOCs)
Organic chemicals, such as methylene chloride and benzene, than
vaporize easily. Some VOCs found -at the sice include carbon
tetrachloride, vinyl chloride, benzene, and chloroform.
Wetlands
Areas chat are inundated by surface or groundwater with sufficient
frequently to support vegetative or aquatic life that depends upon
saturated or seasonally saturated soil conditions for growth and
reproduction. -40 CFR Pt.6, App.A, Section 4 .(j).
-------
LIST OF FIGURES AND TABLES
Figure 1 Property Boundary Map
Figure 2 Shallow Bedrock Ground Water Flow Map
Figure 3 Specific Conductance Isoconcentration Map
Figure 4 Arsenic Isoconcentration Map
Figure 5 Test Pit Locations
Figure 6 Example Long-term Monitoring Well Location Map
Figure 7 Proposed Air Sparging System for MCL Criteria
Table '-' • Chemicals of Potential Concern
Table 2 Maximum Risks from Combined Ingestion and
Dermal Contact Pathways for Various Media
Table 3 Cost Summary for Remedial Alternatives
Table 4 Evaluation Table
-------
1 I
'.300
11
[T.
' LOT 27
PARCEL S
LOT 27
OARCEL
•5«::
6.000
5.JCC '.
.- ri-.p\—<
x— ;:3*giri
') - :n-a
v^ :.? .s»
~ .i-.:r_ so.•;:
-
.FIGURE 1
PROPERTY
30UNDARY MAP
-------
SHALLOW BEDROCK
GROUND WATER FLOW MAP
(JANUARY 18. 19**)
-------
^r -.^--ti
-rf
-;oc
6.000
i.JCO
LEGEND
O - =
?.*V(V 9110
FIGURE 3
;::.rau«
SPSCIHC CONDUCTANCE
ISOCONCENTOATION MAP
SHALLOW BEDROCK
-------
• era*
^>t^
///S^-1
,•1/03
EARTH
ARSENIC
;SOCONCENTRAT10N MAP
SHALLOW BEDROCK
TICK
-------
*: ;:: a- sec *=j
tttoKnt Comaur uao.
FIGURE 5 .
TEST PIT LOCATIONS
ALBlON-SheilDAN LANDFILL
ALBION. MICHIGAN
ABB Environmental Services, inc.
-------
O«3O*Ot1WA1t '.ANOFIU. 9
- -:«Sh£D a<3«TIONS WGICJ
S.^vf CKIO SOUMOAH-r)
.ANOflU. 9OUN01I
WGICAt *-•
FIGURE 6
«0»0
T*ACX
*t~ '.OCAT10M
! LONG TERM MONITORING WELL
-------
PROPOSED AIR SPARING
SYSTEM FOR MCL CRI7ZRIA
-------
TABLE 1
( 'liemiculs of Potential Concern
Albion-Sheridan Township Landfill, Albion, Michigan
Surface Soils
BeiiitHaiaiiliiracene
Bcn/olhMluiiraiilhcnc
brii/o(k)lliMHanlliene
Beiuo(glii)perylene
BenziKalpyrene
Chrysene
Dibenz(a.liKuiUiracene
Di-n hmyl plilhalaie
1 luuiaiillicne
IwdciuK l.2.3-i.'d)|»yicnc
Pliciianlhrcnc
I'yrciie
Arsenic
Barium
Clirtiiiiiimi
Cupjicr
Cyanide
Vanadium
Zinc
Ground Water Monitoring Wells - Unconsolidated Sediment and Bedrock Aquifers
Bcn/cnc
Carbon disullidc
l.2-DihriMUo-3-cliloro|mipaiic
Vinyl chloride
Xylcnc. liiul
Bis(2clhyl hcxyllphihalaic
nndosuHan snllaie
l.iiidanc
Aniiiniiny
Arsenic
Hariuni
Cadininin
C«ihall
lion
Nkii-l
Sclcninin
Iliiillium
Zinc
Residential Wells
Heptaclilor
Selenium
•_'
Surface Water
Carbon disulfide
Butyl benzyl plilhalaie
Dicdiyl phtbaJale
River Sediments
Acetone
Mcihyknc cliloride
Bis(2-clliyl hexyDnliihalalc
riiioranllicnc
I'licnanilircnc
Pyrene
bBIIC
b Eiulosullan
liiuliin
Uiuli in aldehyde
Cadmium
Chromium
Cyanide
Thallium
,«ili.«.m\ni|vXI S
-------
2 "I .'
t 'liciiiiculs of Potential Concern
Albion-Sheridan Township Landfill, Albion, Michigan
Wetland Sedinieiils
AlCltMtC
Mcihylciie cMufiik
Bis(2-eibyl hciyDpliiliabic
2 MnliylnaplillMleuc
I'licuwilhrcnc
4.4'-l>I>T
h F.iiilosiill.ui
Hiulriit
liuilfiii alilcliyilc
liiuliiii kcli«ic
1 Icpiiiclilot
Mciliiuycliliu
Arsenic
Mcnury
Selenium
iiioii(>i|.\f*»\*u>ii>nu'oit:.xi.:>
rum. .1 in •> >i
-------
Table 2. Maximum Risks from Combined Inaestion and
Dermal Contact Pathways.for Various Media
... . Maximum Maximum
Media Hazard Index Carcinogenic Risk
Groundwater • 54 2.1 x 1CT3
Off-site soils • 0.18 2.6 x 10'5
Surface water .0.11 0
Sediments 0.048 ' 1.9 x 10'"
-------
Table 3. Cost Summary for Remedial Alternatives
Alternative
2 -
3A
3B
3C
4 A
4B
5A
SB
5C
5D
Drum Removal
- Clay Cap
- Enhanced Clay
Cap
- FML Cap
- Passive Venting
of Landfill Gas
- Active Collection
of Landfill Gas
- Groundwater
Monitoring (GWM)
- In-situ Treatment
to MCL + GWM
- In-situ Treatment
to Type B + GWM
- Pump & Treat + GWM
Capital Cost
$ 614,581
$ 1,542,609
$ 1,779,137
$ 1,728,431
$ 49,600
$ 182,900
$ 128,822
$ 560,284
$ 862,656
$ 931,703
O&M
-o-
$ 109,373'
$ 109, 3731
$ 109,373*
$ 207,777'
$ 446, 0931
$ 642,335*
$ 790,457J
$ 1,539,827*
$ 1, 280,281s
Present Value
$.614.581
$ 1,651,982
$ 1,888,510
$
$
$
$
$
$
$
1,837,804
257,377
628,993
771,157
1,350,74.1
2,402,483
2,221,984
Includes 30 yrs
2 Includes 20 yrs of GWM (5 yrs beyond expected attainment of MCLs)
3 Includes 5 years of in-situ treatment (during yrs 6 through 10, as called for in the
contingent remedy) and 5 additional yrs of GWM during yrs 11 through 15
1 Includes 12 yrs of in-situ treatment and 5 additional yrs of GWM
s Includes 9 -yrs of pump and treat and 5 additional yrs of GWM
-------
TABLE -
Evaluation Table
No
Onam
Omen*
EVALUATION CRITERION
3A
38
3C
4A
48
SB
5C
SO
1 . OvwU PraMcuon ol Hcttft A
4. RMucMn el Tonety.
or VOUM tHeugji T
S. Shon-Mfm QIMMMWM
7. EatiMWdCo)
so
$0.6
$1.7
$1.9 | $19-
mitbOft
$0.3
$0.7
$1.1
$1.8
$2.7
million
8. Slat* Ag*ncy AeMcuna
leltiwf
t wM M tMMMd HHr tlw |
9. CofiunuMv
»d m« r»cofTvn«no«o an^ffwoM «M 69 «vtiuMO «n*r ir» cubic eommM o»nod
• lui*
-------
Index to the Administrative Record
Albion-Sheridan Township landfill
Albion. Michigan
Title
1. Action
Memo
Author
Jason
El-Zein
Date
1/19/90
2. Site Weston, Inc. 1/4/90
Assessment
Subject
Request for
funda for
surface removal
actions at AST
Landfill
Site inspection,
analytical
results. 4 removal
action plan
* of Pages
7
27
3 . Drum
Sampling
results
(TAT)
4. letter to •
George
Rouman,
Calhoun
County
Health Dept.
Grace
Analytical
Lab, Inc.
11/1/89 Analytical results 7.
G.A. Matthew. 06/28/66
VP Manufacturing
Union Steel
Products, Co.
Disposal at Albion- 2
Sheridan Meeting
5. Application G.D. Stevick
for solid
waste -dis-
posal license
3/3/69
3. Letter to
R. Sieler
C. Harvey, 10/23/7C
Michigan Water
Tank Truck Resources
7.
Service
Phone
Record
Commission
Basin Eng.
Beth A.
Kenning
2/6/90
Waste license for
general refuse.gar
bage, industrial
waste.•liquid
waste, rubbish
Inform Seiler that
Albion Landfill •
cannot be used for
their liquid indus
trial wastes past
1971.
.Types of waste
disposed of at
the Site. .
-------
Update to the
Administrative Record
July 3. 1990
3.
9.
10.
11.
4 A
12.
13.
14.
letter
Phone
Convers
Phone
Convers
Report
\A & ^h
Map
r.eport
Affidav
G . Roun;
A. Wilkinson
ation
B. O'Neal
ation
MDNR
Suburban
Laboratcries
it A. Wilkir.son
3/9/66
5/5/88
3/1/88
9/2/80
8/23/89
4/25/90
Waste operations
Community
Participation
Community
Participation
Evaluation
Map
Sampling
Legal Document
2
1
1
3
-------
-LSILN. -:i:;: ^.-J
IRl-j ;.••—.
... «.•-.•-/ - a
2 :9
-------
U.S. EPA ADMINISTRATIVE RECORD
ALBION-SHERIDAN TOWNSHIP LANDFILL
ALBION. ,11 CHI CAN
UPDATE *»1
• 09/26/94
:-3Ci :ATE
AUTHOR
'ECIFIE.1T
;0/00/00 li-.aeDiriaifl. £.
06/21/88 rhoe«8, I.. J.S. EPA U.S. EPA
sloeeler. J., Pirn Toimshio
Nichiqan Otoartient
sf Public ri
07/01/91
10/10/91 :"«ater A-iisn J.s. ErA
01/00/92
Ihaeoer or ::uerct
.iPlante. :.. «nd
liuie. 7.
a 04/21/92
:.3. EPA Snoford. «.. SSBI
Mil. 3.. »:«iR NW, R.. U.S.
3 05/00/92
JO/W/93
H Enqinttrinq ft
unei
U.S. EPA
.5 06/00/93 Vtriou
04/21/9:
asssssss:*
Journal
Out to Fresc Action tno . iir tfftct on
Enqinttrinq 5 true turn*
ri: rticoittndrt Aqncr Policy on
tht G«rcinoqmicitT Risk Atiociatid nth tht
Inqntion of Inorqanic Antnic
Litttr n: Riwlts of Organic ChMical
of lUttr Supln v/AttacflMits
09/08/93
, «.. ..s. EPA Ssy.lt. 3., .•::?::«
JeotrtMnt of s-.:iic
'•iciith
*Jll, S.. "2HR :haro, R.. ::.s. £"A
n. C.. 9ecioients
s lunicioal iatir: Rioort of tht
• - : :ai riattr Fact Finding CoaaittH*
:-«;:s:u« Paotr: 'Fretit/fhai Efficts on tin
Hr«raunc Canductmty of CoiMCttd Clays*
i Transportation fttstarch Boartl
'.ttttr re: Pilot Pro net Stltction to
Strtaiitnt tht RI/FS
wetttr re: flDM's Contnts on Strtulininq
tftt RI/F5 Prociss
Prajtct Plans for tht RI/FS
Jsurnai Articlt: 'Laboratory Testing to
ivaiuatt Chanqts in nvdrauiic Conductivity of
Cjioacttd Clavs Caustd by Ffttzt/Thavt Statt
:f tht Art* (Aatrican Society for Testing and
**ttmis)
Vtrious Jsurnai Articles: 'Silecttd
Literature and Bibliooraonv for Seochnistry
ind ln-;itu Fixation of Arsenic*
letter -eauestinq HDPH's Casaents on the
Craft PJ'aso i.SmMry Reoort
?ASES
:&
Dtsartsent
:f Public Health
Latter re: flaqnetouter Survey
Letter re: U.S. EPA's Saiolinq of Drinlinq
Vater •/Httacneents
86 .
717
13
124
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