EPA Superfund
Record of Decision:
PB97-964102
EPA/541/R-97/029
November 1997
Organic Chemicals, Inc.,
Operable Unit 2,
Grandville, MI
2/5/1997
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RECORD OF DECISION
SELECTED REMEDIAL ALTERNATIVE
FOR THE
ORGANIC CHEMICALS, INC. SITE
GRANDVILLE, MICHIGAN
Statement of Basis and Purpose
This decision document presents the selected remedial action for the Organic Chemicals Inc.,
site in Grandville, Michigan, which was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as "amended
by the Superfund Amendments and Reauthorization Act of 1986 (SARA), 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 the selected remedy.
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 to the environment.
Description of the Selected Remedy
This ROD addresses the second Operable Unit (OU), or discrete action at the Site. The first
OU was an interim action to contain the contaminated groundwater plume. The second OU
is the final action at the site and will address the low level (groundwater) and principal
threats at the site (contaminated soil). The selected remedy consists of the following
components:
Continued operation and maintenance of the existing ground-water extraction system .
in the upper ground-water system to the USEPA Maximum Contaminant Limits at an
Alternate Point of Compliance determined through institutional controls. Maintain the
groundwater extraction and treatment system until the MCLs are attained throughout
the contaminated plume.
Excavation of approximately 6,000 cubic yards of contaminated soil and on-site
remediation by solidification/stabilization.
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Statutory Determinations
The two operable units, which deal with the contaminated soil, and contaminated ground
water, are 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. However, because treatment of the principal threat of the site was not
found to be practicable, this remedy does not satisfy the statutory preference for treatment as
a principle element.
Because these remedies will result in hazardous substances on-site above health based levels,
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 anfl the
environment.
State Concurrence
The State of Michigan concurs with the selected remedy. The Letter of Concurrence is
attached to this Record of Decision.
_
William E. Muno / Dare
Division Director
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STATE OF MICHIGAN
JOHN ENGLER. Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOLLISTER BUILDING. PO BOX 30473. LANSING Ml 46909-7973
INTERNET. http:«v»ww.deq tlate.mi.us
RUSSELL J. HARDING, Director
January 17, 1997
E i f i
JAN 2 3 1997
SUPERFUND DIVISION
OFFICE OF THE DIRECT
Mr. William E. Muno, S-6J
Director, Superfund Division
U.S. Environmental Protection Agency, Region 5
77 West Jackson Boulevard
Chicago, Illinois 60604-3590
Dear Mr. Muno:
SUBJECT: Record of Decision (ROD) for the Organic Chemicals, Inc. (OCI) Superfund Site,
Grandville, Michigan
The Michigan Department of Environmental Quality (MDEQ) is pleased to concur with the ROD
for the OCI Superfund site.
Please provide a copy to the MDEQ once it has been signed. If you have any questions, please
feel free to contact Mr. Ardon Toland, Chief, Superfund Section, Environmental Response
Division, at 517-373-8815, or you may contact me.
Sincerely,
Russell J. Harding
Director
517-373-7917
cc: Mr. Valdas V. Adamkus, EPA
Mr. Alan J. Howard, MDEQ
Mr. Ardon Toland, MDEQ
Dr. George Carpenter, MDEQ
Mr. William Harmon, MDEQ
EQPOIOte
(Roy 10/96)
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Decision Summary for the Record
of Decision
Organic Chemicals, Inc. Site
Grandville, Michigan
I. Site Name. Location, and Description
The Organic Chemicals Inc. (OCI) property is located at 3291 Chicago Drive, S.W., in the
city of Grandville, Kent County, Michigan (the "Site"). The OCI property, approximately 5
acres, is fenced, with several buildings, structures, and storage tanks occupying the Site
(Figures 1 and 2) which extends over several properties. The Chesapeake and Ohio
Railroad, which runs southeast of the facility and along the north side of Chicago Drive, has
an elevated railbed acting as a barrier to surface drainage. A drainage ditch exists on the
west side of the OCI Site. There is no visible surface drainage linking the Site and the
Grand River, which is located approximately 0.95 miles north. Two gravel quarries.nave
been identified near the OCI Site. One quarry is located 0.3 miles northwest, and the other
quarry is 0.2 miles northeast of the Site. Both quarries are inactive and filled with water.
The OCI property has several buildings and structures occupying the property. The chemical
manufacturing operation, which is housed in two buildings along the western boundary of the
property, produced small quantities of specialized industrial chemicals and pharmaceutical
intermediates. The solvent recovery operation is housed in several buildings along the
southeastern portion of the property. Other structures include a warehouse, several drum and
storage tank areas, an office building, a boiler facility and a waste water pretreatment
facility. OCI stopped operations in May 1991, because of financial problems and the
inability to obtain a Resource Conservation and Recovery Act (RCRA) Part B permit. OCI
completed RCRA closure of the equipment and tanks in 1992.
Two railroad sidings parallel the southern and eastern OCI property boundaries (Figure 2).
Along the sidings are the remnants of a series of aboveground storage tank facilities.
Although the tanks no longer exist, the concrete footings and underground piping connections
remain.
The OCI property is bordered by Packaging Corporation of America on the east, by the
former Haven-Busch Co. on the west, and by Grand Rapids Gravel Co. on the north and
these properties are also part of the OCI Site. The property directly north and northwest of
OCI has a lower ground surface elevation due to earlier sand and gravel mining activities.
Residential areas are approximately 200 feet southeast of the Site and 1700 feet to the
southwest.
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II. Site History and Enforcement Activities
A. Site History
The OCI Site is situated approximately 0.95 miles southeast of the Grand River. The Site
was previously used for petroleum refining from 1941 to 1945, and transport and storage
operations from 1945 to 1966. A succession of petroleum-related industries leased the land
prior to its purchase by Spartan Chemicals. Anne R. Herald, owner of the property from
approximately 1900 to 1942, issued an oil and gas lease for the entire property to Gerald J.
Wagner on December 7, 1937. Mr. Wagner then leased the premises for oil and gas
exploration to various third parties. During tenure of these leaseholds, two oil production
wells were drilled onsite. One was a dry hole and the other was never completed or
maintained. Attempts made to identify the exact locations of these wells by reviewing
existing data were unsuccessful.
All oil and gas exploration leases were summarily voided by Ms. Herald on February 7,
1941. Other petroleum industry operations including a refinery commenced onsite in the
early 1940's. Total Pipeline Corporation, a petroleum transporter, leased an oil and gasoline
warehouse and tank facility onsite during this period. Its facilities were then taken over by
its parent company, Total Petroleum, Inc., which operated onsite through 1964. Leonard
Fuels purchased the Site in 1964 and sold the property to Total Realty in 1966. In 1968,
Spartan Chemical Company acquired the Site property for the solvent reclamation and
chemical manufacturing operations of its subsidiary, Organic Chemicals Company (now
Organic Chemicals, Inc.). Organic Chemicals, Inc. (OCI) has operated on the Site since
1968. In 1979, OCI became the owner of the premises by conveyance of deed from Spartan
Chemical Company.
Historical aerial photographs, taken from 1960 through 1978, show changes to the physical
facilities of the OCI Site. In a 1960 photograph, three large vertical tanks with two sumps
for containing spills were present along the northwestern portion of the former refinery. By
1967, these tanks were no longer present. In 1973, the terrain on the western portion of the
former refinery was being regraded and leveled. The ground was visibly scarred from earth
moving activity. In this same year there was a seepage lagoon on the OCI property which
appeared to contain liquid waste. Two new buildings and six additional vertical storage tanks
had been added to the facility in 1973. A 1978 aerial photograph indicates that the west
portion of the former refinery was abandoned. This area was owned by Haven-Busch, Co.
and was being used as an open storage yard for this steel fabrication company. Haven-
Busch, Co. has since closed both their corporate office and their steel fabrication plant and
has been sold to Padnos Iron and Metal.
In March 1976, a water well was drilled on the OCI property. The well was 165 feet deep
and was used to provide plant production and cooling water. Because of various problems
with the performance of the well, it was abandoned and the plant returned to the use of water
supplied by the city of Grandville.
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A chemical fire occurred onsite on October 11, 1976, damaging part of the OCI facilities.
The cause of the blaze was reported as being started by a spark from a metal drum dragged
across a floor. The spark ignited barrels of solvents stored nearby. According to retired
Grandville Fire Chief Osterink, the fire was contained in the building and prevented from
spreading to other storage tanks outside.
A chemical spill at the Site in November, 1979, was reported to the Michigan Department of
Environmental Quality (MDEQ) by OCI. On November 3, 1979, 2,200 gallons of lacquer
thinner were spilled by an operator onto the ground onsite. Some of the spilled lacquer
thinner was recovered and disposed of in the onsite seepage lagoon.
The OCI Site was classified, on April 14, 1980, as a potential hazardous waste site by the
United States Environmental Protection Agency (EPA). The Site was listed on the Rational
Priority List on September 8, 1983. The EPA summarized the problem in its Potential
Hazardous Waste Site log as "known groundwater contamination by organic solvents."
Between 1968 and 1980, company records indicate that OCI discharged its process waste and
cooling water, which included F001-F005 hazardous wastes into the onsite seepage lagoon.
In June 1980, OCI ceased discharge of wastewater to the seepage lagoon. In 1980, the
company installed a wastewater pretreatment facility with discharge to the City of Grandville
Sanitary Sewer system. The pretreatment facility included two 9,000 gallon sedimentation
tanks and a 30,000 gallon aeration basin with pH adjustment.
In September 1981, seepage lagoon sludges were excavated and transferred to railroad cars.
The total removed soil filled approximately seven railroad cars. These sludges were
disposed of at Chem-Met Services, Inc. in Wyandotte, Michigan.
A Preliminary Assessment (PA) for the Site was completed by EPA in 1983. The PA
documented potential groundwater contamination from the solvent-contaminated seepage
lagoon. Soils beneath this pond were also found to be contaminated. A potential for
drinking water contamination and endangerment of flora and fauna in nearby potential
wetlands was indicated in the PA.
In September 1986, MDEQ Law Enforcement Division personnel responded to a complaint
of alleged illegal disposal of hazardous wastes at the facility. Reportedly, OCI personnel
were disposing of sludges and other residues generated from the solvent recovery operations
by placing these materials into drums and rolloff containers along with their normal
nonhazardous solid waste materials. Analyses taken from solid waste storage units (rolloffs
and 55 gallon drums) located anhe Site revealed the presence of various contaminants
including methylene chloride, toluene, ethylbenzene, xylenes and arochlor 1242
polychlorinated bi-phenyls(PCBs). Analyses of soil samples taken from the vicinity of the
solid waste storage units revealed the presence of methylene chloride, toluene, xylenes,
1,1,1-trichloroethane, trichloroethene, tetrachloroethene, chloroform, 1,1-dichloroethene,
1,2-dichloroethene, and Aroclor 1242 (PCBs).
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As a result of this investigation, OCI was cited by the EPA on December 3, 1986, to be in
violation of RCRA. Among the violations cited were: (1) the unreported generation of
hazardous waste from a drum cutting operation; (2) the routine transport of hazardous waste
from the Site by unauthorized agents; (3) failure to prepare hazardous waste manifests, and
(4) shipment of hazardous waste to unauthorized facilities. Based on these findings, the EPA
levied fines of $22,500 on OCI.
During August/September 1987, OCI conducted a voluntary investigation in cooperation with
MDEQ. Approximately 150 buried drums were discovered and removed from the southwest
corner of the OCI warehouse building. Some of these drums contained sludge and liquid
residues. Groundwater samples taken at that time from Prein & Newhof s monitoring well,
B-ll, indicated the presence of 1,1-dichloroethene, 1,1-dichloroethane, cis-1,2-
dichloroethene, dibromochloromethane, toluene, ethylbenzene, and xylenes. Monitoring well
B-ll was located south and slightly west of the warehouse building. The drum burial area
was excavated down to approximately 17 feet below grade. Soil samples from the bottom of
the excavation indicated methylene chloride (13 ug/kg) and tetrachloroethene (2.7 ug/kg)
contamination.
B. Previous Investigations
In November 1979, the MDEQ requested that OCI perform a hydrogeological study to
investigate suspected ground water contamination. This study, conducted in four phases, was
completed in October 1981. It concluded that the groundwater flow in the upper
groundwater system at the Site was northwesterly towards the Grand River. Soil borings
identified a sand and gravel aquifer existed over a clay layer. The elevation of the top of the
clay layer was found to vary throughout the area. It was deepest below the area of the former
seepage pond. The elevation of the top of the clay layer was found to be shallowest 1,000
feet west of the OCI property. This clay mound west of the Site re-directs the westward
movement of groundwater to flow around the mound.
Twenty-four monitoring wells were installed during this study. Analysis of monitoring wells
north and west of the former seepage pond revealed the following contaminants: methylene
chloride, toluene, 1,1-dichloroethene, trans 1,2-dichloroethene, 1,2-dichloroethane,
trichloroethene, benzene, chlorobenzene, ethylbenzene, pentachlorophenol, xylene, acetone,
1-propanol, 4-methyl-2 pentanone, trifluoromethylbenzene, naphthalenes, and various
aliphatic hydrocarbons.
Analyses of surface soil samples taken from the OCI facility revealed the presence of
methylene chloride, toluene, xylenes, 1,1,2-trichloroethane, trichloroethene,
tetrachloroethene, chloroform, 1,1-dichoroethene, 1,2-dichloroethene and Aroclor 1242
(PCB).
The investigation also attempted to determine the rate of groundwater flow. Using soil
samples obtained during the different phases of the investigation and the hydraulic gradient
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determined from groundwater elevations, the rate of groundwater flow was estimated by the
Kozeny-Carmen Equation. Due to the various soil strata encountered, which have various
amounts of fines in the gravel, it was extremely difficult to accurately determine the rate of
groundwater flow. The calculations indicated that the groundwater flow rate may vary from
approximately 0.3 feet per day to as high as 1.5 feet per day or possibly higher in localized
areas of extremely high permeability.
In the fall of 1988, EPA and the ARCS V project team conducted preliminary field
investigation (PFI) activities with the objective of further characterizing the OCI Site. A
description of PFI activities can be found in the PFI Quality Assurance Project Plan (QAPP).
The information gathered during the PFI was incorporated in the planning and
implementation of the Phase I Remedial Investigation (RI) activities. Analytical results
obtained during the PFI study are presented in Appendix C of the Focused Feasibility* Study
(FFS).
C. CERCLA Enforcement
On March 30, 1988, a letter was sent to both OCI and Spartan Chemical pursuant to Section
122(a) of CERCLA informing them that work pursuant to 104(a) of CERCLA would be
undertaken by EPA because OCI and Spartan lacked the financial capability to perform an
RI/FS. On April 9, 1991, a General Notice letter was sent to OCI and Spartan; also on
April 9, 1991, a General Notice Letter and Information Request was sent to 182 Potentially
Responsible Parties (PRPs) who were customers of OCI and are considered generators of
hazardous waste at OCI, pursuant to Section 107(a)(3) of CERCLA. On January 6, 1992, a
Unilateral Administrative Order was sent to the 182 PRPs pursuant to Section 106 of
CERCLA. On September 21, 1992, a De Minimis Administrative Order on Consent was
executed with 100 PRPs providing for payment of past costs in the amount of $1,384,714.
The settlement was pursuant to Section 122(g)(4) of CERCLA. On June 5, 1995, a General
Notice Letter and Information Request was sent to 5 PRPs, pursuant to Section 107(a)(3) of
CERCLA, who had contracted with OCI for the manufacture of chemicals.
III. Highlights of Community Participation
A Community Relations Plan was finalized for the OCI Site in February 1989. This
document lists contacts and interested parties throughout the government and the local
community. It also established communication pathways to ensure timely dissemination of
pertinent information. A fact sheet outlining the RI sampling program was distributed in May
of 1989. An RI public availability session was held on May 10, 1989. A second fact sheet
was distributed in January of 1991, outlining this interim action for the upper ground-water
system. The FFS was finalized on July 17, 1991. The Proposed Plan for the interim action
at the OCI Site was released to the public on July 18, 1991. The Proposed Plan for the final
action at the OCI Site was released on July 12, 1996. All of these documents, including the
analytical data upon which this decision was based, were made available in both the
Administrative Record and the information repository maintained at the Grandville Public
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Library at 3141 Wilson Avenue in Grandville. The notice of availability of these documents
was published in the Grand Rapids Press (Grandville Edition) on July 11, 1996, and the
Grand Valley Advance on July 16, 1996.
A public comment period was held from July 22 through August 20, 1991, for the interim
action and the comment period for the final action was held from July 15 through August 28,
1996. A public meeting was held on August 6, 1991, to present the result of the FFS and the
preferred alternative as presented in the Proposed Plan for the interim action. The ROD was
signed on September 30, 1991. A public meeting was held on July 16, 1996, to present the
results of the Phase II Remedial Investigation, Final Feasibility Study (FS) and the preferred
alternative as presented in the Proposed Plan for the final action. All significant comments
which were received by EPA prior to the end of the second public comment period,
including those expressed verbally at the second public meeting, are addressed in the
Responsiveness Summary, which is attached to this Record of Decision.
IV. Scope of Response Action
EPA had organized this project into two response actions. The first response action was an
interim action to address contamination in the upper ground-water system (UGS) by stopping
the contaminant plume migration. The final action will remediate the ground water to
comply with Maximum Contaminant Limits (MCLs), and the soil contamination to be
protective in an industrial setting.
The soil which is the principle threat at the Site will be addressed by excavation of
approximately 6,000 cubic yards of the contaminated soil and on-site treatment by
solidification/stabilization. Contamination associated with past oil related activities at the Site
are being addressed by MDEQ under the State voluntary cleanup program.
V. Site Characteristics
The primary contaminants at the Site are associated with the past operation of the seepage pit
by OCI, chemical spills at the Site and past oil related activities. These areas are: the former
seepage lagoon, the former lacquer thinner spill Site and petroleum sludge lagoons. The
total organic compounds in soil exceeds 2,747,000, 85,600 and 149,000 ug/kg, respectively,
at these areas. (Figure 3) These contaminants include elevated levels of chlorinated solvents
and benzene, ethylbenzene, toluene, and xylene (BETX) compounds. Lower concentrations
of other volatile and semi-volatile organic compounds were also detected. The nature and
extent of contamination is presented in the FFS and Phase II RI report and summarized in the
following sections.
A. Hydrogeologic Characteristics and Groundwater Contamination
Shallow groundwater at the OCI Site occurs in the saturated unconfined deposits of sand and
gravel, which range in thickness from 4 to 30 feet. There are no known residential wells
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that draw water from these deposits. The sand and gravel deposits are underlain by clay
throughout the Site except at SB-10 (Figures 4 through 8) and SB-16, which encountered
shale directly below the sand and gravel deposits. See Figure 9 for the location of soil
borings. The thickness of the clay varies from 0 feet at SB-10 to 35.5 feet at MW-20. The
sand and gravel aquifer will be referred to as the upper groundwater system (UGS). The
Michigan formation underlies the clay unit and consists of interbedded gypsum, limestone
and shale with occasional sandstone lenses. The Marshall Sandstone formation underlies the
Michigan formation and is the source of groundwater for private and industrial wells and is a
Class I aquifer. Residential areas are located to the southeast and southwest of the Site. The
groundwater systems which lie beneath the clay will be referred to as the lower groundwater
system (LGS).
Ground water flow in the unconsolidated deposits is to the northwest towards the Grand
River. Ground water flow in the LGS also appears to move in a westerly, northwesterly
direction across the Site.
The LGS is a confined and locally unconfmed (where the clay unit is not present). The
hydraulic conductivity for the LGS range from 1.86 X 10 * cm/sec to 2.09 X 10 '3 cm/sec.
The hydraulic conductivity in UGS monitoring wells screened in coarse grained sediments
(predominantly sand and/or gravel) range from 2.86 X IQ* centimeters per second (cm/sec)
to 5.14 X 10'2 cm/sec. Monitoring well MW-9 is an exception to this range with a hydraulic
conductivity of 6.97 X 10'5 cm/sec; however, MW-9 is screened across the sand and gravel
unit to clay unit interface.
B. Phase I Groundwater Monitoring
Two rounds of groundwater samples were collected from 25 of the 26 monitoring wells
installed during the Phase I field investigation (Figure 10). The results of this sampling are
documented in the previous ROD for the Site and presented in Figures 11 and 12.
C. Phase II RI Groundwater Monitoring
Two rounds of groundwater samples were collected from the Phase I and II,monitoring wells
during June 9 through 16, 1993, and September 20 through 25, 1993 (Figure 10). These
samples were analyzed for volatile organic compounds (VOCs), semi-volatile organic
compounds (SVOCs), pesticides, PCBs, metals, and cyanide. Figures 13 and 14 summarize
this information.
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C. 1 Volatile Organic Compounds
The highest VOC concentrations detected during groundwater sampling rounds 1 and 2
occurred at the following monitoring wells: MW-1 (round 2: 2,523 /xg/L) and MW-27 (round
2: 2,623 /ig/L). The principal contaminants detected at MW-1 were 1,2-dichloroethene (565
/ig/L), trichloroethene (195 fig/L), benzene (155 /xg/L), toluene (660 /xg/L), chlorobenzene
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(205 /ig/L), ethylbenzene (310 /xg/L), and xylene (345 /xg/L). The principal contaminants
detected at MW-27 were 1,1,2-trichloroethane (18 ^g/L), benzene (36 /xg/L), toluene (170
/xg/L), chlorobenzene (99 /xg/L), ethylbenzene (400 /xg/L), and xylene (1,900 fig/L). These
wells are associated with the former seepage lagoon and former oil refinery.
VOC tentatively identified compounds (TICs) ranged from 0 to 2,124 fig/kg. Four locations
had TICs greater than 1,000 /xg/kg: MW-27 (1,354 /xg/L; round 1), MW-28 (1,092 /xg/L;
round 1), MW-29 (2,124 /xg/L; round 1), and MW-31 (1,148 /*g/L; round 1).
C.2 Semivolatile Organic Compounds
The highest concentrations of total SVOCs were detected at the following monitoring wells:
MW-1 (413 /xg/L; round 2), MW-20 160 jxg/L; round 1), MW-28 (100 /xg/L; round 1), and
MW-31 (78 /tg/L; round 1). Monitoring wells MW-1 and MW-28 are associated with the
former seepage lagoon and former oil refinery. Compounds detected in samples collected
from monitoring wells MW-20 and MW-31 contained a common laboratory contaminant
(i.e., bis-2-ethylhexylphthalate) or were qualified "B" because they also were found in
corresponding rinsate blanks.
Principal contaminants detected at MW-1 were naphthalene, 2-methylnaphthalene, N-
nitrosodiphenylamine, and carbazole. The principal contaminants detected at MW-28 were
naphthalene and 2-methylnaphthalene.
C.3 Pesticides/PCBs
The following pesticides and PCBs were detected in groundwater samples collected from
MW-1 and MW-8: MW-1 (round 2: aldrin, 0.033 jtg/1; endrin ketone, 0.11 /xg/L; Arochlor
1248, 2.0 /xg/L) and MW-8 (round 1: Arochlor 1242 at 1.6 /xg/L). These compounds were
not detected in other rounds of sampling or in these wells before the Phase II RI.
C.4 Metals and Cyanide
Inorganic elements were detected at varying degrees at all monitoring wells (Figures 13 and
14). To evaluate the data, inorganic concentrations detected in rounds 1 and 2 of MW-17
groundwater samples were assumed to represent naturally occurring background levels in the
UGS. Similarly, inorganic concentrations detected in the round 1 and 2 MW-20 groundwater
samples were assumed to represent naturally occurring background levels in the LGS. These
wells are located approximately-500 feet upgradient of the Site in a residential setting. Table
1 lists the background concentrations for UGS and LGS wells encountered during the Phase
II investigation. The analytical data was used to determine those locations that exceeded five
times background concentrations. Table 2 presents the results of this determination.
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Eleven inorganic contaminants were detected in concentrations significantly above
background (i.e., greater than five times): arsenic, barium, calcium, chromium, copper, iron,
magnesium, manganese, potassium, sodium, and zinc (Table 2).
D. Comparison Between 1989 and 1993 Groundwater Analytical Results
Comparison between the Phase I (1989) and the Phase II (1993) groundwater analytical
results show some important trends in the data: decreased contaminant concentrations at
MW-1 and MW-2, increased contaminant concentrations at MW-4 and MW-27, and a
general decrease in VOCs and SVOCs in outlying monitoring wells (i.e., MW-3, MW-5,
MW-6, MW-8, MW-9, and MW-11).
Groundwater VOC and SVOC concentrations at MW-1 and MW-2 apparently decreased
between 1989 and 1993. Average VOC concentrations at MW-1 and MW-2 during-1989
sampling were 29,684 and 53,523 /zg/L, respectively. Whereas, average VOC
concentrations at MW-1 and MW-2 during 1993 sampling were 1,398 and 135 /xg/L,
respectively; a decrease in concentration of approximately 95 and 99 percent, respectively
occurred. Similarly, average SVOC concentrations at MW-1 and MW-2 during 1989
sampling were 1,569 and 805 p.g/L, respectively. Whereas, average SVOC concentrations at
MW-1 and MW-2 during 1993 sampling were 287 and 6 /xg/L, respectively, a decrease in
concentration of approximately 82 and 99 percent, respectively occurred.
Groundwater VOC and SVOC concentrations at MW-4 and MW-27 (a Phase II well nest)
apparently increased between 1989 and 1993. Average VOC and SVOC concentrations at
MW-4 during 1989 sampling were 142 and 12 ng/L, respectively. Whereas, average VOC
and SVOC concentrations at MW-4 and MW-27 during 1993 sampling were 1,371 and 27
txg/L, respectively.
Contaminant isopleths were drawn to visualize changes between 1989 and 1993 groundwater
conditions (Figure 12 and 14). The following conclusions can be drawn from evaluation of
these contours: 1) apparently, the aerial extent of the 100 /ig/L plume has increased between
1989 and 1993; 2) apparently, the aerial extent of the 1,000 /xg/L plume has decreased
between 1989 and 1993; and 3) the center of the plume seems to have shifted to the west of
the OCI Site.
E. Phase II Residential Well Analytical Results
Three residential well samples were collected for analysis of VOCs during the Phase II RI:
PW-2, PW-3, and PW-5. No VOCs were detected in PW-3. The following VOCs were
detected in PW-2: acetone (14 itg/L), carbon disulfide (1 /xg/L), chloroethane (0.3 jxg/L),
chloromethane (13 ng/L), 1,2-dichloroethane (17 /ig/L), and 1,2-dichloropropane (0.4 /xg/L).
In PW-5, toluene was detected at a concentration of 0.1 ttg/L.
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10
PW-2 analytical results are anomalous because no other bedrock wells screened in the
Marshall Sandstone (i.e., MW-41, MW-42, PW-2, and PW-5) contained such high
concentrations of chlorinated organics. Furthermore, no VOCs were detected in PW-2
during Phase I RI sampling. In addition, although PW-3 is located just 300 feet away from
PW-2, the sample and duplicate sample collected from PW-3 contained no detectable VOC
concentrations.
F. Surface Soil Analytical Results
A total of 142 surface soil samples were collected at OCI during the Phase II investigation.
See Figure V. Eight samples were collected at monitoring well locations; 33 samples were
collected at soil boring locations; and 101 samples were collected at surface soil locations.
The samples were analyzed for VOCs, SVOCs, pesticides, PCBs, metals, and cyanide. Table
4-13 in the Phase II RI presents the organic and inorganic compounds detected in surface soil
samples.
F.I VOCs
Three surface soil samples (SS-96, SS-104, and SS-107) had the highest concentrations of
total VOCs (greater than 10,000 /tg/kg). Soil at these locations contained elevated levels of
xylene (25,000, 73,000, and 360 /tig/kg, respectively), toluene (6500, 74,000, 170 Mg/kg,
respectively) and tetrachloroethene (1,400, 4,700, and 3,000 kg, respectively). In addition,
SS-96 and SS-104 had high concentrations of ethylbenzene.(1300 and 25,000 kg,
respectively), and SS-107 had a high concentration of 1,2-dichloroethene (13,000 /xg/kg).
Both SS-104 and SS-107 are located in former tanker loading areas and are on or adjacent to
the main driveway of the Site. SS-96 is situated in the northeastern corner of the former
lacquer thinner spill area, immediately south of the northern tank farm. SS-96 and SS-107
were the only two surface soil samples that had VOC TICs greater than 10,000 (12,250 and
12,640 pig/kg, respectively); all other surface soil VOC TICs ranged from 0-6000 Mg/kg.
F.2 SVOCs
SS-51, SS-95, and SS-105 contained the highest levels of total SVOCs (greater than 100,000
/zg/kg). The compound containing the highest concentration at all three locations was bis(2-
Ethylhexyl) phthalate (66,000, 220,000, and 150,000 /*g/kg, respectively). SS-95 and SS-
105 are located within the former lacquer thinner spill area, and SS-51 is located on the Site,
just outside of the staging area. SS-51 is situated on level ground at the bottom of a hill
from the OCI buildings. Because of the elevated concentrations at SS-58, SS-59, and SS-60,
which are near SS-51, it is believed this level ground is affected by surface runoff.
In addition to the three locations mentioned above, 23 out of the 52 sample locations within
the Site fenced area contained high levels of total SVOCs (greater than 10,000 /ig/kg).
These high concentration surface soil locations are in areas associated with considerable Site
activity or with surface runoff from high Site activity locations (e.g. the depression that runs
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along the western edge of OCI and the low ground north of the boiler house and aeration
basin).
Nine surface soil samples contained SVOC TIC concentrations greater than 1,000,000
seven of these are located within the Site fenced area (SS-51, SS-58, SS-68, SS-69, SS-93,
SS-95, and SS-97). Their concentrations range from 1,303,800 to 3,269,100 jig/kg. SS-110
is located east of the Site along the railroad siding and has an SVOC TIC concentration of
1,656,400 fig/kg. SS-30 was located on the hill adjacent to PCA rail siding and has an
SVOC TIC concentration of 2,430,300 /xg/kg. Twelve surface soil samples contained greater
than 100,000 fig/kg SVOC TICs; 11 of these samples were taken in the areas of high activity
in the Site fenced area. The twelfth surface soil sample (SS-98) was located along the
railroad siding east of the Site.
-\
F.3 Pesticides/PCBs
Surface soil pesticide levels outside of the Site were less than 140 /xg/kg. Within the fenced
area, pesticide levels ranged from 0-6616 ^g/kg. The five highest pesticide concentrations
were detected at SS-68 (1,163.4 /xg/kg), SS-84 (1,113.1 /xg/kg). ss'93 (2,232.5 /xg/kg), SS-
97 (6,616.1 /xg/kg), and SS-103 (4,275 /xg/kg).
PCBs in the surface soil samples were found predominantly within the Site. Concentrations
in this area ranged from 43 to 74,000 /xg/kg, with the seven highest concentrations located at
SS-60 (17,000 /xg/kg), SS-61 (30,490 /xg/kg), SS-81 (74,000 /xg/kg), SS-86 (14,000 /xg/kg),
SS-93 (32,000 /xg/kg), SS-103 (45, 000 '/xg/kg), and SS-104 (13,000 /xg/kg). In general,
samples outside of the OCI Site contained low PCB concentrations (< 100 /xg/kg). The one
exception is SB-22 (345 /xg/kg), which is located approximately 1,500 feet northwest of the
Site.
F.4 Metals and Cyanide.
Inorganic elements were detected at varying degrees at all locations. The highest surface soil
inorganic contamination encountered occurred at the Site during the Phase II investigation,
and in particular, at the former lacquer thinner spill area.
The highest concentrations of inorganic analytes were found at the former lacquer spill area.
In this area, four analytes were found to be significantly higher than background
concentrations: cadmium, chromium, cyanide, and lead. Cadmium was found in excess of
50 times the background level of 0.21 /xg/kg at SS-31 (33.6 mg/kg), SS-32 (41.4 mg/kg),
SS-33 (35.7 mg/kg), SS-40 (44.8 mg/kg), and SS-96 (11.9 mg/kg), and greater than five
times background at SS-45 (2.2 mg/kg). Chromium was found in excess of 50 times the
background level of 19.84 mg/kg at SS-31 (1490 mg/kg), SS-32 (1590 mg/kg), SS-33 (1540
mg/kg), and SS- 105 (1180 mg/kg), and greater than five times background at SS-40 (629
mg/kg) and SS-95 (835 mg/kg). Cyanide was found in excess of 50 times the background
level of 0.33 mg/kg at locations SS-31 (113 mg/kg), SS-32 (136 mg/kg), SS-33 (120 mg/kg),
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and SS-105 (95.8 mg/kg). Lead was found in excess of 500 times the background level of
13.99 mg/kg at SS-31 (13,100 mg/kg), SS-32 (10,600 mg/kg), and SS-105 (8460 mg/kg).
G. Additional Studies
The following additional studies were performed to supplement the data obtained during the
Phase II RI:
•Cone Penetrometer Study
• Dense Non-Aqueous Phase Liquid (DNAPL) Investigation
•Phase II RI Non-Aqueous Phase Liquid (NAPL) and Headspace Results
G.I Cone Penetrometer Study
The EPA tasked the U.S. Army Corps of Engineers (USAGE), Earthquake Engineering and
Geosciences Division, Waterways Experiment Station, to perform an investigation at OCI "to
evaluate and demonstrate the ability of the Site Characterization and Analysis Penetrometer
System at the Site." Appendix M presents the USAGE investigation report; the following
paragraphs summarize the report.
The investigation was conducted in July 1992. 49 cone penetrometer penetrations were
completed along a 300 x 300 foot grid. The USACE estimated that petroleum contamination
greater than 100 ppm total recoverable petroleum-hydrocarbons was present in two distinct
plumes, as presented in Figure 16. The first plume extended from the Site property, west
approximately 800 feet, and north approximately 2,000 feet. The second plume extended
approximately 400 feet radially from the sludge waste pit. The sludge waste pit is
approximately 2,500 feet north of the Site. The report indicates the easterly extent of the
first plume was not defined conclusively during the cone penetrometer investigation; the first
plume likely extends further east than is shown in Figure 16.
G.2 DNAPL Investigation
Six DNAPL wells were located and constructed at OCI. See Figure 17. No DNAPL has
been detected in these wells to date. Although not conclusive, it appears that DNAPL is not
present at OCI.
G.3 Phase II RI NAPL and Headspace Study
During the drilling of Phase II RI soil borings, headspace analyses and non-aqueous phase
liquid (NAPL) shake tests were performed at two-foot intervals for each boring. The
headspace test was performed by placing approximately 100 ml of soil into a 250 ml glass
jar. The glass jar was covered with aluminum foil, sealed, and set aside for 5 to 10 minutes.
After the prescribed period of time, the lid of the jar was opened, the aluminum foil was
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punctured simultaneously with the tips of a photoionization detector and a flame-ionization
detector, and the instrument readings were recorded.
The NAPL shake test was performed in a manner similar to that described in Cohen, et al.
(1992). Approximately 100 ml of soil was placed in a 250-ml glass jar, containing
approximately 50 ml of distilled water and 1 gram of SUDAN IV (a hydrophobic dye).
After sealing the jar, the mixture was shaken vigorously and inspected for changes. If
NAPL was present in the soil sample, then the dye would dissolve within the NAPL and
appear bright red. If no NAPL was present in the sample, then the dye would not dissolve
into the solution, and no color change would occur. Appendix F of the Phase II RI presents
the head space and NAPL test results.
Headspace readings, using an FID, were observed to be greater than 1,000 ppm at thp
following locations: SB-12, SB-25, SB-26, SB-29, SB-30, SB-32, SB-35, SB-41, SB-43,
MW-35, MW-38, D-4, and D-6. Eleven soil and liquid sample locations indicated the
presence of NAPL: SB-12, SB-14, SB-25, SB-26, SB-30, SB-42, SB-44, D-2, D-3, MW-33,
and MW-38. These locations correspond to those associated with OCI operations, former oil
refinery operations, or waste disposal sites from the former oil refinery.
H. Contaminant Fate and Transport
This section describes the fate and transport of the constituents detected at Organic
Chemicals, Inc. (OCI), based on Site history, knowledge of surface and subsurface media
gained during the Phase I and II remedial investigation (RI) field investigations, and
analytical results. The purpose of this section is to evaluate qualitatively potential pathways
of contaminant migration, as well as to describe the environmental behavior of Site
contaminants.
This section is divided into two parts: potential migration routes and contaminant persistence
and migration. Potential migration routes will be evaluated to determine routes that could
transmit contaminants to receptors. Contaminants associated with pertinent migration routes
will be evaluated based on their persistence in the environment and factors affecting
contaminant migration.
H.I Potential Routes of Migration
This section discusses the following potential routes or pathways of contaminant migration:
air, surface water, soil exposure; and groundwater.
H.I.a Air Pathway
The release of hazardous substances to the air appears to be a minor potential contaminant
migration route because no work activities are performed onsite and the onsite water
treatment facility is no longer in operation. There are neither open pits nor industrial
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operations which emit fugitive dust at OCI. No other sources of contaminant transport to the
air pathway exist on the Site; therefore, the air pathway for contaminant transport is
considered insignificant.
H. 1. b Surface Water Pathway
The release of hazardous substances to surface water appears to be a minor potential
contaminant migration route. A small intermittent ditch, Roy's Creek, runs from the quarry,
southeast of the Site, 1,250 feet northwest to a point west of the Wyoming publicly-owned
treatment works (POTW), and north of Packaging Corporation of America. Roy's Creek
then runs west for approximately 1,000 feet before turning north for 2,500 feet, where it
discharges into the Grand River.
•*.
Based on the contaminant plumes presented in Figures 12 and 14, Roy's Creek does not
appear to be a discharge point of groundwater contaminated above 100 /ig/L. The nearest
monitoring wells upgradient from the intermittent creek, MW-11 and MW-29, had the
following groundwater total VOC analytical results: Round 1: 400 and 8 /ag/L, and Round 2:
0 and 0 /zg/L, respectively. The 400 /ig/L result for MW-11 during round 1 sampling was
attributed primarily to chloromethane (i.e., 390 /ig/L). This contaminant was not detected at
MW-11 during the second round of Phase II sampling or the first or second rounds of Phase
I sampling. Therefore, contaminant transport by the surface water pathway was considered
insignificant. However, without the collection of surface water or sediment analytical data,.
and a subsequent risk analysis on that data, this pathway cannot be completely ruled out.
H.l.c Soil Exposure Pathway
The release of hazardous substances through exposure to Site soils appears to be a potential
contaminant migration route. Evaluation of the surface soil data determined that high levels
of carcinogenic polynuclear aromatic hydrocarbons (PAHs), lead, polychlorinated biphenyls
(PCBs), and dioxin/furans were present at the OCI Site. These contaminants may cause
undue risk to trespassers and future onsite workers.
H. 1. d Groundwater Pathway
The release of hazardous substances through exposure to lower groundwater system (LGS)
groundwater may be a potential contaminant migration route. Levels of chlorinated
hydrocarbons and petroleum products are present in the upper groundwater system (UGS),
and to a much lesser extent, in the LGS. The UGS groundwater pathway is currently being
addressed by the existing groundwater treatment system. Private wells located near the Site
are screened in the LGS, specifically the Marshall Formation (i.e., sandstone).
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H.2 Contaminant Persistence and Migration
The contaminants associated with the soil exposure and groundwater migration pathways
were evaluated based on their persistence in the environment and factors affecting
contaminant migration. Table 3 presents physical and chemical constants associated with
these contaminants [e.g., aqueous solubility, vapor pressure, Henry's law constant, organic
carbon partition coefficient (Koc), octanol-water partition coefficient (Kow) and density].
The aqueous solubility represents the maximum concentration of a compound that will
dissolve in water at ambient temperature and pressure. Vapor pressure is the pressure
exerted by a chemical vapor in equilibrium with its solid or liquid form at a given
temperature. Henry's law constant provides a measure of the'extent of chemical partitioning
between air and water at equilibrium. The organic carbon partition coefficient, Koc* is a
measure of the tendency for organic compounds to adsorb to soil or sediment. The octanol-
water partition coefficient, Kow, is an indicator of hydrophobicity or the tendency of a
compound to avoid the aqueous phase. Density is the mass of a compound divided by its
volume.
H.2.a Soil Exposure Pathway
The contaminants associated with the soil exposure pathway are carcinogenic PAHs, lead,
PCBs, and dioxin/furans. Based on the data presented in Table , these compounds would
tend to adsorb to soil particles because of their high Koc and tend not to transfer to water- or
air-phases because of their low water solubilities and vapor pressures. Because lead can be
found in numerous forms, each having its own unique physical characteristics, data for lead
was not presented in Table 3. A determination of the species of lead was not performed as a
part of either the Phase I or Phase II RIs; therefore, this subsection does not discuss lead
migration.
H.2.b Groundwater Exposure Pathway
Contaminants associated with the groundwater exposure pathway are chlorinated
hydrocarbons, aromatics, and PAHs. Because of the differences in physical characteristics of
these contaminants, this subsection discusses chlorinated hydrocarbons and aromatics
separately from PAHs.
Water solubility and K^,, are important physical characteristics that affect.contaminant
transport in groundwater. Based on the data presented in Table 3, chlorinated hydrocarbons
and aromatics generally have moderate water solubilities (greater than 10,000 mg/L) and low
K^ values (less than 100); therefore, chlorinated hydrocarbons and aromatics would tend to
be susceptible to the groundwater transport pathway.
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Based on the data presented in Table 3, PAHs generally have low water solubilities (less
than 1 mg/L) and moderate to high K,,w values; therefore, PAHs would tend not to be
susceptible to the groundwater transport pathway.
VI. Summary of Site Risks
The following groundwater exposure scenario was evaluated quantitatively in the FFS: a
future ingestion of drinking water for adults only and potential for current ingestion of
drinking water from the private wells. Due to the limited scope of the FFS and the
unlikelihood of future residential land use, only one exposure pathway was chosen to
evaluate potential future adverse health risks associated with exposure to contaminated
groundwater. This scenario assumes that contaminated ground water will migrate to the LGS
where it would be a potable water source. -*.
A quantitative assessment of baseline risk for human health at OCI, evaluates potential
exposures and subsequent risks for current trespassers and future occupants of OCI. This
assessment addressed risks associated with exposure to chemicals present in soils at the Site,
as well as the area of investigation (AOI). For the risk assessment, the AOI was defined as
that area at OCI excluding both the Site and the area near the petroleum sludge lagoon (i.e.,
the area represented by soil samples collected from the following locations: SB-12, SB-14,
MW-16, MW-32, and MW-33).
A. Toxicity Assessment Summary
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)'1, 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 the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors
have been applied.
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which
are expressed in units of mg/kg-day, are estimates of lifetime 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 assure that the RfDs will not
underestimate the potential for adverse non carcinogenic effects to occur. Table 6-7 gives
RfDs and slope factors.
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Excess lifetime cancer risks are determined by multiplying the intake level with the cancer
potency factor. These risks are probabilities that are generally expressed in scientific
notation (e.g., IxlO"6 or 1E-6). An excess lifetime cancer risk of IxlO'6 indicates that, as a
plausible upper bound, an individual has a one in a million chance of developing cancer as a
result of Site-related exposure to a carcinogen over a 70-year lifetime under the specific
conditions at a site.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminants reference dose). By
adding the HQs for all contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can be generated. The HI
provides a useful reference point for gauging the potential significance of multiple -*•
contaminant exposures within a single media or across media.
Excess cancer risk estimates were calculated for exposures to carcinogenic indicator
chemicals by adding together the product of the chronic daily intakes (GDI) and cancer
potency factor for all carcinogenic indicator chemicals and intake routes for a given human
receptor. Hazard indices were calculated for exposures to non-carcinogenic indicator
chemicals by summing the ratios of GDIs to acceptable daily intakes (reference doses) for all
chemicals and intake routes for a given human receptor.
B. Risk Summary
B.I Carcinogenic Risk
The future exposure scenario included residential groundwater use. Only exposure to
groundwater was assessed under the future residential scenario. A chronic hazard index of
17.6 was estimated for potential future residential use of groundwater. This indicated a
potential noncarcinogenic health risk for this hypothetical scenario. Trichloroethene in
groundwater accounted for approximately 79 percent of this noncarcinogenic risk. Both
toluene and N-nitrosodiphenylamine accounted for approximately 11 percent of the risk.
Excess cancer risk for potential future residential groundwater use was estimated at 3xlO~3.
Vinyl chloride (SxlCT1), trichloroethene (8x10^), 1,1-dichloroethene (3x10^), and
arsenic(3xlO"*) accounted for the majority of this excess cancer risk.
x.
The above risk assessment was performed in the FFS. No risk assessment was performed in
the Phase II RI for the shallow aquifer because the interim ROD concluded that the
groundwater may pose an imminent and substantial endangerment to public health, welfare or
the environment. Implementation of the interim ROD selected remedy has begun to stop
further migration of the contaminant plume, achieving significant risk reduction while a final
solution was developed.
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The Site current trespasser scenario yielded an excess lifetime cancer risk of 2 x 10"4. Risk
is due to exposure to the following compounds: benzo(a)pyrene, dibenzo(a,h)anthracene,
2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD) (on a total equivalent basis), and PCB
(Aroclor 1248). The Site future worker scenario yielded an excess lifetime cancer risk of 3 x
10"4. Risk is due largely to exposure to the following compounds: benzo(a)pyrene,
beryllium, bis(2-ethylhexyl)phthalate, chromium(VI), dieldrin, 2,3,7,8-TCDD (on a total
equivalent basis), and PCB (Aroclor 1248). In both the Site current and future scenarios,
risk was found to exceed the acceptable range of 10"6 to 10"*.
The excess lifetime cancer risk for the Area of Investigation (AOI), MW-41, and MW-42
future residential exposure scenarios was evaluated. The excess lifetime cancer risk for these
scenarios was, 5 x 10'5, 1 x 10"*, and 2 x 10~5, respectively. Only the MW-41 scenario was
outside of the acceptable range of carcinogenic risk. Arsenic was responsible for trie excess
risk in this scenario equal to 1 x 10^.
B.2 Non-carcinogenic Risk
The Site current trespasser HI and the Site future worker were 0.2, and 0.8 respectively,
these risk numbers are below the level for increased concern of non-carcinogenic effects.
The HI for the AOI future resident was 0.7, this risk is below the level for increased concern
of non-carcinogenic effects. The His for the MW-41 and MW-42 scenarios (the two
Marshall sandstone well scenarios) were 2 and 0.4, respectively. The HI in MW-41 is due
largely to the manganese and arsenic water concentrations.
B.3 Qualitative Ecological Risk Assessment Results (QERA)
A HI less than 1.0 indicates the ecological chemicals of potential concern are below levels of
ecological concern. The hazard indices for the open water wetland, the forested wetland, the
scrub-shrub wetland, and the old field terrestrial habitats were 0.07, 0.14, 0.17, and 0.17,
respectively. Therefore, habitats and species at OCI do not appear to be subjected to
significant ecological risk from OCI contamination. Figure 18 shows the sample locations
used to determine the HI. Tables 5 and 6 show the intake values used to calculate the His.
B.4 Assessment of Human Health and Environmental Risks Presented by the Site
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response actions selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or, the environment.
VII. Description of Alternatives
Two alternatives were developed for the final groundwater action and nine were developed for
the final source action. The alternatives developed for these actions are:
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• Alternative 1: No Action
• Alternative 2: Institutional Controls
All of the following alternatives include the groundwater final alternative which consists of
continued operation of the existing groundwater system and will ;be referred to as Alternative
10.
• Alternative 3: Contaminated Soil Containment by Concrete Capping and Surface
Controls
• Alternative 4: Offsite Disposal of Contaminated Soil
-v.
• Alternatives: Onsite Ex Situ Treatment of Contaminated Soil by Soil Washing
• Alternative 6: Onsite Ex Situ Treatment of Contaminated Soil by
Solidification/Stabilization
• Alternative 7: Treatment of Organic-Contaminated Soil by Onsite Thermal
Treatment and Containment of Residual and Inorganic-Contaminated Soil by Capping
• Alternative 8: Treatment of Organic-Contaminated Soil by Onsite Thermal
Treatment and Landfill Disposal of Residual and Inorganic-Contaminated Soil
• Alternative 9: Treatment of Organic-Contaminated Soil by Onsite Thermal
Treatment and Treatment of Residual and Inorganic-Contaminated Soil by
Solidification/Stabilization
• Alternative 10: Continued Operation and Maintenance of the Existing Granular
Activated Carbon Groundwater Treatment System
A. Alternative 1: No Action
Alternative 1 is the no action alternative, required by the National Contingency Plan and
Superfund Amendments and Reauthorization Act regulations. This alternative serves as a
baseline for comparison with other alternatives for the soil and groundwater alternatives.
The capital and present worth cost for this alternative is $0.
B. Alternative 2: Institutional Controls
Alternative 2 is a limited action alternative that includes implementation of institutional
controls to prevent direct contact with or ingestion of contaminated soil. A 6-foot security
fence with three strands of barbed wire would be installed in contaminated areas of the Site
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not currently fenced to reduce the opportunity for exposure. This alternative would include
addressing areas south of the staging area and along the abandoned railroad siding. Warning
signs would be displayed on fences to alert the public of potential hazards. Future uses would
also be limited by deed restrictions.
The capital cost and O&M cost for this alternative are $47,569 and $7,000 respectively. The
present worth cost for this alternative is $155,176.
C. Alternative 3: Contaminated Soil Containment by Concrete Capping and Surface Controls
Alternative 3 involves capping contaminated soil areas with concrete. The concrete cap was
selected as representative of forms of containment that reduce potential contact with
contaminated soils and surface water infiltration into groundwater of de minimis volatile
organic soil contaminants that are major groundwater contaminants. The major soil
contaminants of concern at the Site are not expected to leach to groundwater. Drainage
controls would be provided to control surface water runoff. A 6-foot security fence with
three strands of barbed wire would be installed in contaminated Site areas not currently
fenced, as described in Alternative 2. Deed restrictions would be placed on the Site to limit
future land use (i.e., subsurface excavations below the concrete cap). For cost estimating
purposes, it is assumed a pre-design investigation will be performed to confirm the extent of
soil contamination.
The capital cost and O&M cost for this alternative are $2,137,691, and $12,000 respectively.
The present worth cost for this alternative is $2,322,161
D. Alternative 4: Offsite Disposal of Contaminated Soil
Alternative 4 includes excavation, removal and transportation of contaminated soil from the
OCI Site to an approved landfill. Appendix B in the Phase II RI shows 5,561 cubic yards of
soil must be disposed of at a Resource Conservation and Recovery Act (RCRA) Part B-
permitted landfill and 22 cubic yards at a Toxic Substances Control Act (TSCA) permitted
landfill. An additional 457 cubic yards of soil may be disposed of at a local solid waste
landfill. The total estimated soil to be remediated is 6040 cubic yards. See Figure 19.
Following excavation and disposal of contaminated soil, the OCI Site will be backfilled with
clean soil and revegetated. Following disposal of contaminated soil, the Site would be
considered safe for industrial use. Fence restrictions will be required because groundwater
remediation will be operating long after the soil cleanup is complete. For cost estimating
purposes, it is assumed that a pre-design investigation will be performed to confirm the
extent of soil contamination. In addition, it is assumed the offsite disposal facility will
require analytical testing to be performed at a consistent rate (i.e., one test per 100 cubic
yards) during the offsite transfer of contaminated soil.
The capital cost and O&M cost for this alternative are $2,363,032, and $7,000 respectively.
The present worth cost for this alternative is $2,470,640.
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E. Alternative 5: Onsite Ex Situ Treatment of Contaminated Soil by Soil Washing
Alternative 5 includes excavation and onsite treatment by soil washing. Excavated
contaminated soil will be placed in waste piles with an impermeable base and cover.
Contaminated soil is screened to remove coarse rock and debris. For cost estimating
purposes, it is assumed 1 percent of the total volume of soil to be treated will consist of
cobbles and other large debris, too large to be accepted into the treatment unit. These
materials will be disposed of offsite as solid waste.
Chemical additives, such as surfactants, acids, bases, and chelants, are added to the soil to
produce a slurry feed, which flows to an attrition scrubbing machine. Mechanical and fluid
shear stresses are applied to the slurry feed through the use of screens, separators, and
cyclones. After these steps, the following output streams are created: coarse clean fraction,
contaminated fine fraction, and contaminated process water. ^v-
Soil monitoring will be implemented to confirm the treatment process reduced contaminant
levels below cleanup goals. The coarse clean fraction is expected to be used as backfill. All
excavated areas will have a vegetative cover. The contaminated fine fraction, assumed to be
10 percent of treated volume, will require disposal in a RCRA-permitted landfill. For cost
estimating purposes, it is assumed 10 percent of the treated soil volume will fail to meet
cleanup goals and be disposed of offsite as solid waste. Contaminated process water would
be treated and returned to the plant for re-use.
Following disposal of contaminated soil, the Site would be considered safe for industrial use.
Fence restrictions will be required because groundwater remediation will be operating long
after the soil cleanup is complete. Before implementation of this alternative, it is assumed a
treatability study would be required to determine the necessary chemical additives to treat the
soil to below cleanup goals. For cost estimating purposes, it is assumed a pre-design
investigation will be performed to confirm the extent of soil contamination. In addition, it is
assumed the offsite disposal facility will require analytical testing to be performed at- a
consistent rate (i.e., one test per 100 cubic yards) during the offsite transfer of contaminated
soil.
The capital cost and O&M cost for this alternative are $2,270,401, and $7,000 respectively.
The present worth cost for this alternative is $2,378,009.
F. Alternative 6: Onsite Ex Situ Treatment of Contaminated Soil by
Solidification/Stabilization
Alternative 6 includes excavation and onsite treatment of contaminated soil by
solidification/stabilization and subsequent onsite disposal of stabilized soil. Excavated
contaminated soil would be placed in waste piles with an impermeable base and cover.
Contaminated soil is screened to remove coarse rock and debris and combined with pozzalanic
ingredients (including fly ash and cement binding reagents) and water in a pug mill. For cost
estimating purposes, it is assumed 1 percent of the total volume of soil to be treated will
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consist of cobbles and other large debris, too large to be accepted into the treatment unit.
These materials will be disposed of offsite as solid waste.
Wet slurry is returned to excavated areas to cure. Stabilized material would exhibit
engineering characteristics similar to those of a low load bearing concrete mixture (i.e., 25-50
psi). It is estimated the net volumetric expansion of stabilized soil would be 25 percent. For
cost estimating purposes, it is assumed 10 percent of treated soil will fail the Toxicity
Characteristic Leaching Procedure (TCLP) and be disposed of offsite as RCRA hazardous
waste.
Following treatment and curing of stabilized soil, a vegetative cover would be applied to the
stabilized mass to protect future workers from dermal contact with treated soil. The Site
would be considered safe for industrial use. Deed restrictions to limit future excavation of
stabilized soils would be required. Fence restrictions will be required because grouridwater
remediation will be operating long after the soil cleanup is complete. Before treatment, a mix
evaluation would be performed to determine the most effective mix ratio of soil, pozzalanic
ingredients, and water.
For cost estimating purposes, it is assumed that a pre-design investigation will be performed
to confirm the extent of soil contamination. In addition, it is assumed the offsite disposal
facility will require analytical testing to be performed at a consistent rate (i.e., one test per
100 cubic yards) during the offsite transfer of contaminated soil.
The capital cost and O&M cost for this alternative are $1,596,399, and $7,000 respectively. .
The present worth cost for this alternative is $1,704,007.
G. Alternative 7: Treatment of Organic-Contaminated Soil by Onsite Thermal Treatment and
Containment of Residual and Inorganic-Contaminated Soil by Capping
Alternative 7 includes excavation and thermal treatment of contaminated soil followed by
onsite containment of residual by capping. Before implementation of this alternative, soil
would be segregated into three groups. Group 1 (Figure 20) soils contain organic
contaminants above their respective cleanup goals. Group 2 (Figure 21) soils contain
inorganic contaminants above their respective cleanup goals. Group 3 (Figure 22) soils
contain both organic and inorganic contaminants above their respective cleanup goals. Group
1 and 3 soils would be thermally treated and contained. Group 2 soils would not be thermally
treated, but would be contained. Estimated volumes of Group 1, 2, and 3 soils are 126;
1,306; and 4,609 cubic yards, respectively.
Excavated contaminated soil would be placed in waste piles with an impermeable base and
cover. Contaminated soils to be thermally treated would be screened to remove coarse rock
and debris. For cost estimating purposes, it is assumed 1 percent of the total volume of soil
to be treated will consist of cobbles and other large debris, too large to be accepted into the
treatment unit. These materials will be disposed of offsite as solid waste. Screened soil
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would be fed into a mobile thermal treatment unit (including either fluidized bed, thermal
desorption, or circulating bed technologies) to treat Group 1 and 3 soils. After thermal
treatment, the residual (ash and soil) would be tested for contaminants to verify inorganic
contamination and that residuals were below organic contaminant cleanup goals. Residuals
above organic contaminant cleanup goals would be retreated.
For cost estimating purposes, it is assumed 10 percent of the treated soil would be disposed
of offsite as RCRA hazardous waste. The remaining Group 1 and 3 soils would be placed in
areas inside a security fence and contained along with Group 2 soils with a concrete cap.
Drainage controls would be provided to control surface water runoff. Deed restrictions would
be placed on the Site to limit future land use (i.e., subsurface excavations below the concrete
cap). Before treatment, a trial burn would be performed to determine thermal treatment
effectiveness. ->-•
For cost estimating purposes, it is assumed a pre-design investigation will be performed to
confirm the extent of soil contamination. In addition, it is assumed the offsite disposal
facility will require analytical testing to be performed at a consistent rate (i.e., one test per
100 cubic yards) during the offsite transfer of contaminated soil.
The capital cost and O&M cost for this alternative are $8,786,474, and $12,000 respectively.
The present worth cost for this alternative is $8,970,944.
H. Alternative 8: Treatment of Organic-Contaminated Soil by Onsite Thermal Treatment and
Landfill Disposal of Residual and Inorganic-Contaminated Soil
Alternative 8 includes onsite thermal treatment of organic-contaminated soil and landfill
disposal of the thermal treatment residual and inorganic-contaminated soil. Before
implementation of this alternative, soil would be segregated into three groups, as discussed in
Alternative 7. Excavated contaminated soil would be placed in waste piles with an
impermeable base and cover. Contaminated soils to be thermally treated would be handled as
described in Alternative 7. After thermal treatment, the inorganic contaminated residual (ash
and soil) would be tested to verify inorganic contamination and that residuals were below
organic contaminant cleanup goals. Residuals above organic contaminant cleanup goals would
be retreated.
Residuals below organic and inorganic contaminant cleanup goals would be backfilled onsite.
Residuals having inorganic concentrations above contaminant cleanup goals and Group 2 soils
would be tested to determine whether they are RCRA hazardous. RCRA hazardous soils
would be transported offsite to a RCRA Part B-permitted landfill. Non-RCRA hazardous
soils would be transported offsite to a local solid waste landfill. Clean soil would be
backfilled into excavated areas and revegetated to tiring areas back to grade. Following
treatment of contaminated soil, the Site would be considered safe for industrial use. Fence
restrictions will .be required because groundwater remediation will be operating long after the
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soil cleanup is complete. Before treatment, a trial burn would be performed to determine
thermal treatment effectiveness.
For cost estimating purposes, it is assumed a pre-design investigation will be performed to
confirm the extent of soil contamination. In addition, it is assumed the offsite disposal
facility will require analytical testing to be performed at a consistent rate (i.e., one test per
100 cubic yards) during the offsite transfer of contaminated soil.
The capital cost and O&M cost for this alternative are $8,583,301, and $7,000 respectively.
The present worth cost for this alternative is $8,690,907.
I. Alternative 9: Treatment of Organic-Contaminated Soil by Onsite Thermal Treatment and
Treatment of Residual and Inorganic-Contaminated Soil by Solidification/Stabilization
Alternative 9 includes onsite thermal treatment of organic-contaminated soil and
solidification/stabilization of the thermal treatment residual and inorganic-contaminated soil.
Before implementation of this alternative, soil would be segregated into three groups, as
discussed in Alternative 7. Excavated contaminated soil would be placed in waste piles with
an impermeable base and cover. Contaminated soils to be thermally treated would be handled
as described in Alternative 7. After thermal treatment, the inorganic contaminated residual
(ash and soil) would be tested to verify inorganic contamination and that residuals were below
organic contaminant cleanup goals. Residuals above organic contaminant cleanup goals would
be retreated. Residuals below organic and inorganic contaminant cleanup goals would be
backfilled onsite. Residuals having inorganic concentrations above contaminant cleanup goals
and Group 2 soils would undergo a solidification/stabilization process as described in
Alternative 6. Stabilized material would exhibit engineering characteristics similar to those of
a low load bearing concrete mixture (i.e., 25-50 psi). It is estimated the net volumetric
expansion of the stabilized soil would be 25 percent.
Following solidification/stabilization of contaminated soil, the stabilized mass would be
analyzed for TCLP. For cost estimating purposes, it assumed 10 percent of the stabilized
material fails TCLP and would be disposed of offsite as RCRA hazardous. A vegetative
cover would be applied to the remaining stabilized material to protect future workers from
dermal contact with treated soil. The Site would be considered safe for industrial use. Deed
restrictions to limit future excavation of stabilized soils would be required. Fence restrictions
will be required because groundwater remediation will be operating long after the soil cleanup
is complete.
Before treatment, a mix evaluation would be performed to determine the most effective mix
ratio of soil, pozzalanic ingredients, and water; a trial burn would be performed to determine
the effectiveness of thermal treatment. For cost estimating purposes, it is assumed a pre-
design investigation will be performed to confirm the extent of soil contamination. In
addition, it is assumed the offsite disposal facility will require analytical testing to be
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performed at a consistent rate (i.e., one test per 100 cubic yards) during the offsite transfer of
contaminated soil.
The capital cost and O&M cost for this alternative are $7,930,993, and $7,000 respectively.
The present worth cost for this alternative is $8,038,601.
J. Alternative 10 - Operate and maintain a ground water extraction and treatment system to
contain the contaminated plume within OCI property boundaries and prevent the migration of
contaminants to sensitive receptors like the LGS. Ground water is currently being extracted
and treated by the granular activated carbon system to comply with NPDES discharge
limitations with discharge to Roy's Creek.
A ground water extraction and treatment system will be operated until MCLs are achieved at
the point of compliance. The point of compliance is throughout the contaminant plume.
Enforceable land use restrictions or other institutional controls will be required for the Site to
prevent unacceptable risk from exposures to hazardous substances in the groundwater.
Exposure controls will remain in effect until MCLs and other pertinent Part 201 criteria are
achieved throughout the contaminated plume. A monitoring plan that meets the substantive
requirements of Part 201 of the Michigan Natural Resources and Environmental Protection
Act, Act 451 of 1994, ("Part 201") will be developed and implemented to ensure the
effectiveness of the remedial action.
An alternate point of compliance (APC) may be established by the EPA in consultation with
the MDEQ if the likelihood of exposure to the aquifer is demonstated to be remote, and
enforceable land use restrictions or other institutional controls are in place to prevent
unacceptable risk from exposures to hazardous substances in the groundwater. The APC must
be protective of human health and the environment, as well as consistent with the NCP and all
applicable or relevant and appropriate state requirements, including Part 201. If the EPA
establishes an APC, continued operation of the groundwater extraction and treatment system is
not required if MCLs are attained at or beyond the APC. However, the groundwater
extraction arid treatment system will remain in place and operational until MCLs are achieved
throughout the contamianted plume. Also, exposure controls and the monitoring plan will
remain in place until MCLs and other pertinent Part 201 criteria are attained throughout the
contaminated plume.
The residual GAC from this treatment process will be properly treated in accordance with
LDR requirements and disposed of off-site at a RCRA permitted landfill because it will
contain listed hazardous wastes.^ If the residual GAC is regenerated it must be done in a
RCRA permitted treatment unit which is in compliance with 40 CFR Part 264 Subpart X.
The present worth, capital, and O&M costs are $6,200,000, $398,000, and $400,000
respectively, assuming the system operates for thirty years. If the time frame is reduced as a
result of compliance with the cleanup goals due to the implementation of institutional
controls, the present worth cost would be reduced to $2,000,000, and O&M cost would be
$120,000.
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VII. Comparative Analysis of Alternatives
In order to determine the most appropriate alternative for the OCI Site, the alternatives were
evaluated against each other. Comparisons were based on the nine evaluation criteria.
The nine criteria are: 1) overall protection of human health and the environment, 2)
compliance with applicable or relevant and appropriate requirements, 3) long-term
effectiveness and permanence, 4) reduction of toxicity, mobility, and volume, through «
treatment, 5) short-term effectiveness, 6) implementability, 7) cost, 8) state acceptance, and 9)
community acceptance.
A. Overall Protection of Human Health and the Environment ,
All of the remedial alternatives considered for the OCI Site are protective of human health
and the environment by eliminating, reducing, or controlling risks at the OCI Site with the
exception of the no action and institutional control alternative. As the no action and
institutional control alternatives do not provide protection of human health and the
environment, they are not eligible for selection and shall not be discussed further.
Alternatives 3 through 10 would be protective of human health and the environment by
eliminating the direct contact exposure pathway (i.e., capping), or by removing contaminated
soils from the Site (i.e., landfill disposal), or by immobilizing hazardous constituents in a
stabilized matrix (i.e., solidification/stabilization), or by removing or destroying hazardous
constituents in the soils (i.e., soil washing and thermal treatment) and by eliminating ingestion
of contaminated groundwater.
B. Compliance With ARARs
Each alternative is evaluated for compliance with ARARS, including chemical specific, action
specific, and location specific ARARS. Alternatives 4, 5, 6, 8, 9, and 10 would comply with
identified federal and state ARARs. Alternatives 3 and 7 may not comply with the EPA land
ban requirements because they do not include treatment of all hazardous constituents.
C. Long-Term Effectiveness and Permanence
This evaluation focuses on the results of a remedial action in terms of the risks remaining at
the Site after response objectives have been met. The following factors are addressed for
each alternative: magnitude of remaining risk, adequacy and reliability of controls.
Alternative 3 would minimize long-term exposure by covering contaminated soil with a
concrete cap and through application of deed restrictions. Alternatives 4 through 9 would
require excavation and soil removal; thereby, eliminating human exposures and migration of
hazardous constituents. Alternative 10 should pose no risk because contaminated water will
either be treated to MCLs or due to institutional controls will not allow exposure to residents.
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Continued monitoring of the aquifer will preclude contamination reaching a drinking water
source. Therefore, the primary remedy and the contingency measures provide overall
protection of human health and the environment, either by reducing contaminants to MCLs, or
through institutional controls.
D. Reduction of Toxicity, Mobility, or Volume (TMV) Through Treatment
This evaluation addresses the statutory preference for selecting remedial actions that employ
treatment technologies which permanently and significantly reduce toxicity, mobility, or
volume of the hazardous substances. This preference is satisfied when treatment is used to
reduce the principal threats at a Site through destruction of toxic contaminants, irreversible
reduction of contaminant mobility, or reduction of total volume of contaminated media.
•»
In Alternatives 3 and 4, no reduction of toxicity, mobility and volume through onsite
treatment would be experienced.
In Alternatives 5 through 9, approximately 6,041 cubic yards of contaminated soil would be
excavated and treated in either a soil washing, solidification/ stabilization or thermal treatment
unit. Alternatives 5 through 9 would provide greater reduction in volume, mobility, and
toxicity through treatment of Site contaminants than Alternatives 1 through 4. Alternatives 5
through 9 achieve the Superfund Amendments and Reauthorization Act preferred treatment to
reduce the toxicity, mobility, and volume for hazardous substances.
The toxicity, mobility, and volume of the contaminated material will not be reduced by
Alternative 10 by treatment if the residual carbon is land disposed because the contaminants
will only be transferred to the residual carbon. If the residual carbon is regenerated, which
will likely be more cost-effective, then the toxicity, mobility, and volume of the contaminated
material will be reduced by treatment.
E. Short-Term Effectiveness
This evaluation focuses on the effects to human health and the environment which may occur
while the alternative is being implemented and until the remedial objectives are met. The
following factors were used to evaluate the short term effectiveness of each alternative:
protection of the community during remedial actions, protection of workers during remedial
actio'ns, environmental impacts from implementation of alternatives, and time until remedial
objectives are met.
•x
Alternatives 3 through 9 would create short-term impacts comparable to one another,
including the release of dust and air pollutants during excavation of contaminated soils,
increased noise levels, and increased traffic around the Site. Use of engineering controls
would limit air emissions. Alternatives 4 through 9 require offsite disposal; however,
Alternatives 4 and 8 create more potential for release of contaminants during transportation
because most soils will be transported to an offsite disposal facility.
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With regard to Alternative 10 there are no construction impacts because construction is
complete. With regard to the time until remedial objectives are met, Alternative 10 will be
operated until the final remedial objective is met, which could take one to eleven years
depending on the point of compliance.
None of these alternatives will result in unacceptable short-term risks to workers, residents, or
the environment.
F. Implementablity
This evaluation addresses the technical and administrative feasibility of implementing the
alternatives and the availability of the various services and materials required during its
implementation.
Technical and administrative requirements for implementing Alternatives 3 and 4 would be
moderate. Technical and administrative requirements for implementing Alternatives 5 and 6
would be moderate to high. Technical and administrative requirements for implementing
Alternatives 7 through 9 would be high.
Alternatives 4 through 9 would each have to comply with administrative requirements
regarding transport of hazardous waste, as set by the U.S. Department of Transportation.
Alternatives 7 through 9 would have to comply with strict substantive air permit requirements
for thermal treatment. Alternative 10 poses no problems because it is already constructed.
G. Cost
This evaluation examines the estimated costs for implementing the remedial alternatives.
Capital and O&M cost are used to calculate estimated present worth costs for each alternative.
Capital costs range from a low of $48,000 for Alternative 2 (institutional controls) to a high
of $9 million for Alternative 7 (thermal treatment and capping). Alternatives 4, 5, 6, 8, and 9
have a vegetative cover; therefore, the present worth O&M costs over a 30 year period are
only approximately $0.1 million. However, for Alternatives 3 and 7, which have a concrete
cap, estimated present O&M costs are $0.2 million, because long-term monitoring and
maintenance would be required. The present worth cost of Alternative 6 is the lowest of the
alternatives that eliminated the principle threat. The present worth for Alternatives 7, 8, and 9
(thermal treatment) are about 3 times the present worth for capping, offsite disposal, soil
washing, and stabilization.
The capital cost for alternative 10 was $398,000 and the total present worth cost could be as
high as $6,200,000 depending on monitoring frequency and length of operation.
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H. State Acceptance
The State of Michigan concurs with EPA's selection of alternatives 6 and 10 for the final
actions at the OCI Site.
I. Community Acceptance -
Community response to the alternatives is presented in the responsiveness summary, which
addresses comments received during the public comment period.
IX. The Selected Remedy
After considering the requirements of CERCLA, the detailed analysis of alternatives, -and
public comments, EPA has selected Alternatives 6 and 10 for the final actions at OCI:
Alternative 6 - Alternative 6 includes excavation and onsite treatment of contaminated soil by
solidification/stabilization and subsequent onsite disposal of stabilized soil. Excavated
contaminated soil would be placed in waste piles with an impermeable base and cover.
Contaminated soil is screened to remove coarse rock and debris and combined with pozzalanic
ingredients (including fly ash and cement binding reagents) and water in a pug mill. For cost
estimating purposes, it is assumed 1 percent of the total volume of soil to be treated will
consist of cobbles and other large debris, too large to be accepted into the treatment unit.
These materials will be disposed of offsite as solid waste.
Wet slurry is returned to excavated areas to cure. Stabilized material would exhibit
engineering characteristics similar to those of a low load bearing concrete mixture (i.e., 25-50
psi). It is estimated the net volumetric expansion of stabilized soil would be 25 percent. For
cost estimating purposes, it is assumed 10 percent of treated soil will fail the Toxicity
Characteristic Leaching Procedure (TCLP) and be disposed of offsite as RCRA hazardous
waste.
The present worth, capital, and O&M costs for the selected remedy are $1,704,007,
$1,596,399, and $7,000 respectively.
The basis for the remediation goals is to protect future Site workers to a IxlO"4 excess cancer
risk. Table 7 provides the cleanup goals for this risk level.
Alternative 10 - Operate and maintain a ground water extraction and treatment system to
contain the contaminated plume within OCI property boundaries and prevent the migration of
contaminants to sensitive receptors like the LGS. Groundwater is currently being extracted
and treated to comply with NPDES discharge limitations.
A ground water extraction and treatment system will be operated until MCLs are achieved at
the point of compliance. The point of compliance is throughout the contaminant plume. A
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monitoring plan that meets the substantive requirements of Part 201 will be developed to
ensure the effectiveness of the remedial action. Enforceable land use restrictions or other
institutional controls will be required for the Site to prevent unacceptable risk from exposures
to hazardous substances in the groundwater. Exposure controls will remain in effect until
MCLs and other pertinent Part 201 criteria are achieved throughout the contaminated plume.
A monitoring plan that meets the substantive requirements of Part 201 will be developed and
implemented to ensure the effectiveness of the remedial action.
An APC may be established by the EPA in consultation with the MDEQ if the likelihood of
exposure to the aquifer is demonstated to be remote, and enforceable land use restrictions or
other institutional controls are in place to prevent unacceptable risk from exposures to
hazardous substances in the groundwater. The APC must be protective of human health and
the environment, as well as consistent with the NCP and all applicable or relevant and
appropriate state requirements, including Part 201. If the EPA establishes an APC, continued
operation of the groundwater extraction and treatment system is not required if MCLs are
attained at or beyond the APC. However, the groundwater extraction and treatment system
will remain in place and operational until MCLs are achieved throughout the contamianted
plume. Also, institutional controls and the monitoring plan will remain in place until MCLs
and other pertinent Part 201 criteria are attained throughout the contaminated plume.
The total costs of the remedy with and without implementation of institutional controls
associated with the APC are: present worth, $3,704,007 and $9,904,007, capital costs,
$398,000, and O&M costs $127,000, and $407,000 respectively. The cleanup goals for this
remedy are MCLs.
The residuals from this treatment process will be treated in accordance with LDRs and
properly disposed off-site at a RCRA permitted landfill or regenerated in a RCRA permitted
treatment unit which is in compliance with 40 CFR Part 264 Subpart X because the residuals
will contain listed hazardous wastes.
X. Statutory Determinations
The selected remedy must satisfy the requirements of Section 121(a-e) of CERCLA to:
A. Protect human health and the environment;
B. Comply with ARARs;
C. Be cost-effective;
D. Utilize permanent solutions and alternate treatment technologies to the maximum
extent practicable; and,
E. Satisfy a preference for treatment as a principle element of the remedy.
The implementation of Alternatives 6 and 10 at the OCI Site satisfies the requirements of
CERCLA as detailed below:
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A. Protection of Human Health and the Environment
Implementation of the selected alternatives will reduce and control potential risks to human
health posed by exposure to contaminated soil, and ground water. Extraction and treatment of
contaminated ground water will be conducted to meet federal and state Ground-Water Cleanup
Standards. Soil and debris at the Site will be excavated and backfilled so that the direct
contact exposure risk will be reduced to 10"4 and migration of contaminants to ground water
will be mitigated.
With regard to the community and onsite workers, all alternatives will pose potential risks
from dust and air emissions generated during excavation activities. Perimeter air monitoring
will be needed during remedial activities to determine if steps are needed to protect the
community from adverse air emissions: Workers will be required to wear the proper_]>rotective
health and safety equipment to protect their safety. None of these short-term risks will result
in unacceptable exposures to human health or the environment.
B. Compliance With ARARS
The remedies selected for final action, Alternatives 6 and 10, will comply with ARARS that
are pertinent to this scope of action. The ARARs for the final response action are listed
below.
B.I Chemical-specific ARARS
Chemical-specific ARARs regulate the release to the environment of specific substances
having certain chemical characteristics. Chemical-specific ARARs typically determine the
extent of cleanup at a site.
B.I.a Soils
The soil clean-up standards for the OCI Site will be based on risk based criteria for an
industrial setting.
B. 1 .b Groundwater
Maximum Contaminant Levels (MCLs), and the non-zero Maximum Contaminant Level
Goals (MCLGs), the Federal drinking water standards promulgated under the Safe Drinking
Water Act (SOWA), are applicable to municipal water supplies servicing 25 or more people.
At the OCI Site, MCLs and MCLGs are not applicable, but are relevant and appropriate, since
the sand and gravel aquifer is a Class IIB source which could potentially be used for drinking
in the area of concern (the contaminant plume). MCLGs are relevant and appropriate when
the standard is set at a level greater than zero (for non-carcinogens), otherwise, MCLs are
relevant and appropriate. The point of compliance for ground water standards may be
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attained at an ARC in accordance with Part 201, which is applicable, rather than throughout
the plume. The timeframe for compliance will depend on the point of compliance.
B.l.b Surface Water
i. State ARARs
Section 303 of the CWA requires the State to promulgate state water quality standards for
surface water bodies, based on the designated uses of the surface water bodies. CERCLA
remedial actions involving surface water bodies must ensure that applicable or relevant and
appropriate state water quality standards are met. The standards established pursuant to
R323.2102-.2189 of the Michigan Water Resources Commission Act, Public Act 245 of 1929,
as amended, would be applicable to this Site. The Grand River near the OCI Site is •»
designated a cold water fishery as is Roy's Creek where the groundwater treatment system
discharges.
B.2 Location-specific ARARs
Location-specific ARARs are those requirements that relate to the geographical position of a
site. There are no location-specific ARARs for this Site.
B.3 Action-specific ARARs
Action-specific ARARs are requirements that define acceptable treatment and disposal
procedures for hazardous substances.
i. Federal and State RCRA ARARs
The substantive requirements of RCRA waste generation and temporary storage regulations
under 40 CFR Part 262 and MAC R299.9601-.11107 are applicable when managing the
treatment residuals'from the ground water system (e.g., residual carbon). Also, Federal and
State RCRA LDRs governing off site disposal are applicable to the disposal of treatment
residuals.
ii. State ARARS
The State is authorized to implement the National Pollutant Discharge Elimination System
(NPDES) program. The requirements of a Michigan Pollutant-Discharge Elimination System
(MPDES) permit, under MAC R323.2102-.2189 has been applied to the discharge of the
treated water into Roy's Creek. Effluent limits for surface water discharge have been
established by the MDEQ, with approval by EPA.
Additional action-specific ARARSs are found in the FS.
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C. Cost-effectiveness
EPA believes the selected remedy is cost-effective in eliminating the principle threats, and
protecting residents and the environment from the contaminated soil at the Site. Cost-
effectiveness compares the effectiveness of an alternative in proportion to its cost of providing
its environmental benefits. Alternative 6 was the least costly of the seven alternatives that met
the objective of the remedial action of eliminating the principle threat at the Site. Alternative
10 was the only alternative for groundwater because it was determined in the FS that the
existing system was capable of achieving compliance with the groundwater cleanup goal.
Alternatives 6 and 10 provide overall effectiveness proportional to its cost and represents a
reasonable value.
D. Utilization of Permanent Solutions and Alternative Treatment Technologies to the,
Maximum Extent Practicable
EPA and the State of Michigan believe the selected remedy for the OCI Site represent the
maximum extent to which permanent solutions and treatment technologies can be utilized in a
cost-effective manner for the final action. The Alternative represents the best balance of
tradeoffs among the alternatives with respect to the pertinent criteria given the limited scope
of the action. (See above).
E. Preference for Treatment as a Principal Element
The principal threat at the OCI Site is the contaminated soil due to direct exposure. The
remedies selected in this ROD satisfy the statutory preference for treatment as a principal
element of the remedy by treating the ground water, but does not satisfy the preference by
excavating and stabilizing the contaminated soils at the OCI Site.
XI. Documentation of Significant Changes
The preferred alternative in the proposed plan (PP) was to continue operation of the existing
groundwater treatment system until the cleanup goals were met. Although not explicitly
stated in the PP, the cleanup goals were to be met throughout the plume. Comments received
from the two PRP groups requested that institutional controls allow for an APC because the
UGS is not used as a drinking water source, is .not expected to be used as a drinking water
source and the Site is remote. As a result of this comment the Selected Alternative was
modified in Section IX to be a remedy allowing for institutional controls to determine an
APC.
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APPENDIX
RESPONSIVENESS SUMMARY
ORGANIC CHEMICALS INC. SITE
GRANDVILLE, MICHIGAN
I. Responsiveness Summary Overview ..
In accordance with CERCLA 117, the U.S. Environmental Protection Agency (EPA)
held a public comment period from July 15, 1996 through August 28, 1996 for
interested parties to comment on the Proposed Plan (PP) for the final remedial action at
the Organic Chemicals Inc. (OCI) Site in Grandville, Michigan (the Site").
The PP provides a summary of the background information leading up to the public
comment period. Specifically, the PP includes information pertaining to the history of
the OCI Site, the scope of the proposed cleanup action and its role in the overall Site
cleanup, the risks presented by the Site, the descriptions of the remedial alternatives
evaluated by EPA, the identification of EPA's preferred alternative, the rationale for
EPA's preferred alternative, and the community's role in the remedy selection process.
EPA held a public meeting at 7:00 p.m. on July 16, 1996, at the Grandville City
Council Chambers in Grandville, Michigan to outline the remedial alternatives for the
final action described in the PP and to present EPA's proposed remedial alternatives
for treating the groundwater and soil contamination at the OCI Site.
The responsiveness summary, required by the Superfund Law, provides a summary of
citizens' comments and concerns identified and received during the public comment
period, and EPA's responses to those comments and concerns. All comments received
by EPA during the public comment period will be considered in EPA's final decision
for selecting the remedial alternative for addressing contamination at the OCI Site.
This responsiveness summary is organized into sections and appendices as described
below:
I. RESPONSIVENESS SUMMARY OVERVIEW. This section outlines
the purposes of the Public Comment period and the Responsiveness
Summary. It also references the appended background information
leading up to the Public Comment period.
*v
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND
CONCERNS. This section provides a brief history of community
concerns and interests regarding the OCI Site.
HI. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES
TO THESE COMMENTS. This section summarizes the oral comments
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received by EPA at the July 16, 1996 public meeting, and provides
EPA's responses to these comments.
IV. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES TO THESE
COMMENTS. This section contains the written comments received by
EPA, as well as EPA's response to those written comments.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Local awareness of the OCI site has been minimal from the onset because the area has
been industrial since 1939 and has not impacted the general public. More interest has
been shown by adjacent industries and the OCI's former customers that have been
named as potentially responsible parties.
A public availability session was held on May 10, 1989, to inform the public of the
remedial investigation and sampling and to answer questions concerning the site. Most
of the individuals that attended the session included interested land owners adjacent to
OCI and were interested in the time frame to perform the investigation and begin
remediation.
As part of EPA's responsibility and commitment to the Superfund Program, the
community has been kept informed of ongoing activities conducted at the OCI site.
EPA has established a repository at the Grandville Public Library, where relevant site
documents may be viewed. Documents stored at the repository include:
° The final Phase I Focused Feasibility Study for the site;
The PP for the interim action at the site;
0 Fact sheets summarizing the technical studies conducted at the site;
The Phase II Remedial Investigation (RI) and Feasibility Study (FS);
0 The PP for the final action at the site;
\
0 Public Meeting Transcript for both Public Meetings.
EPA's selection of a remedy to cleanup the contamination at the OCI site will be
presented in a document known as a Record of Decision (ROD). The ROD and the
documents containing information that EPA used in making its decision (except for
documents that are published and generally available) will also be placed in the
information repository, as will this responsiveness summary.
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III. Summary of Major Questions and Comments Received During the Public Comment
Period and EPA Responses to These Comments
Oral comments raised during the public comment period for the OCI Site final
remediation have been summarized below together with EPA's response to these
comments. -
COMMENT: Mr. Ken Cox stated support for preferred alternative of excavating the
contaminated soil and on-site remediation by solidification/stabilization.
RESPONSE: EPA acknowledges the comment.
IV. Written Comments Received During the Public Comment Period. _•»
The written comments regarding the OCI site have been summarized below, together
with EPA's responses to these comments.
COMMENT: The Toll PRP Group expressed support for the preferred alternative for
soil remediation.
RESPONSE: EPA acknowledges the comment.
COMMENT: One comment expressed by the Reclaim and Toll PRP Group was that
the cleanup goals for the groundwater should not have to be obtained throughout the
contaminated groundwater plume but should be determined by institutional controls
because the aquifer is not used as a drinking water source. The Toll Group also
requested that the cleanup goals be no more stringent than the MDEQ industrial
cleanup goals for the soil and groundwater.
RESPONSE: As a result of this comment the selected remedy was modified to allow
for an alternate pont of compliance to be determined through institutional controls to
attain the cleanup goals. A monitoring plan that meets the substantive requirements of
Part 201 will be developed to ensure the effectiveness of the remedial action.
The groundwater cleanup goals were changed from the residential risk based goal to
the Maximum Contaminant Levels (MCLs) determined by the Safe Drinking Water
Act. The change was made^ because MCLs have been used by Region V in the past for
similar aquifer conditions. The soil cleanup goals are for an industrial setting.
COMMENT: The Toll Group has requested that deed restrictions be placed on the
OCI property to keep it industrial.
RESPONSE: Deed restrictions are not necessary because the position of the City of
Grandyille is that the zoning of the property will remain industrial.
-------
COMMENT: The Toll Group requested that the ground water cleanup goals be re-
evaluated as part of the five year review.
RESPONSE: Re-evaluation of the groundwater cleanup goals is not a function of the
five year review.
COMMENT: The calculated risk and hazard associated with ingestion of groundwater
from the upper groundwater system was presented in the Feasibility Study. The UGS
does not present an environmental risk, and as such, the evaluation was inappropriate.
RESPONSE: The MDEQ does consider this aquifer to be a usable aquifer and
therefore, the evaluation is appropriate.
•»
COMMENT: The groundwater remedy selected in the FS for OU2, was selected in
the FS without benefit of the development of other alternatives for comparison of
feasibility, cost, contrary to the requirements of the NCP. Also, the FS is not the
instrument for selection of remedies in the NCP, but rather is meant solely for the
development and comparison of remedial alternatives. The OU1 groundwater remedy
was selected as an interim action until OU2 could be implemented, and was not meant
to be a final remedy (CERCLA 106 Order, Page 7, Item G).
RESPONSE: The Alternatives Array Technical Memorandum (AATM) issued October
12, 1995, presented the groundwater remedial action objectives and the alternative
based on those objectives. The FS did not select the groundwater remedy. It was the
only remedial alternative presented in the FS for the groundwater because it was
properly screened and made available for comment in the AATM in accordance with
the NCP.
The CERCLA 106 Order, Page 7, Item G states:
"USEPA has divided the site into two operable units. The first operable unit is
an interim action that is intended to address the migration of contaminated
groundwater in the UGS. The second operable unit will address soil
contamination and a final groundwater remedy."
The final groundwater remedy selected in OU2 is consistent with the OU1 interim
action groundwater remedy ^pursuant to 40 CFR 300.430 (f)(ii)(C)(l).
COMMENT: The Reclaim PRP Group provided solvents to OCI for recycling. The
Reclaim PRP group should not be considered PRPs for the OU2 soils Remedial Action
because they did not provide the constituents which are identified in the FS as
contributors to degradation of human health or the environment.
-------
RESPONSE: The EPA considers members of the Reclaim PRP Group to be PRPs,
because those PRPs arranged for the disposal or treatment of hazardous substances at
the site, and those PRPs' hazardous substances, or hazardous substances similar to
those of the PRPs, are present at the site. Because the site contamination is not
divisible between OCI's solvent recycling operation and its chemical manufacturing
operation, the reclaim and toll manufacturing PRPs are jointly and severally liable for
the entire costs of site remediation.
COMMENT: The inorganic chromium (VT) was not analyzed in the RI. Only
chromium (III) was analyzed for at the site. Chromium (VI) should not be listed as a
compound of concern.
RESPONSE: It was assumed to be present at the site due to the difficulty associated
with sampling for chromium (VI). If it can be reliably demonstrated to both EPA and
MDEQ that chromium (VI) does not exist at OCI, it can be proposed that it be
eliminated as a contaminant of concern.
COMMENT: The FS states that lead is one of the compounds that poses greater than
1 percent of the carcinogenic risk. Examination of the FS current trespasser and future
worker scenarios reveals that lead does not contribute to the total carcinogenic risk
under either scenario.
RESPONSE: Correct, lead does not contribute to the total carcinogenic risk under
either scenario.
COMMENT: A cleanup depth of 10 feet is used in the future worker scenario.
However, future workers will not be exposed to Site soils to a depth of 10 feet on a
regular basis year after year.
RESPONSE: The cleanup depth scenario is very conservative.
COMMENT: Changes in soil volume and increases in leachate failure could increase
the cost of Alternative 6 between two and three million dollars. As a result the
Reclaim Group advocates the use of the capping alternative as the alternative that best
satisfies the various criteria set out in the NCP for selection of the Remedial Action.
RESPONSE: If as a result,of the predesign investigation, the cost of
solidification/stabilization and disposing of the contaminated soil on-site significantly
increases, the Group can request that the capping alternative be implemented in its
place. Table 4-10 evaluates the cost of increasing the soil volume 100% for
Alternative 6; the resultant change in soil volume would increase the present worth cost
to 2.7 million dollars as compared to 2.3 million for capping, which may not warrant a
change in the Selected Remedy. The Group can request that the OU2 ROD be
amended and that the cap alternative be implemented.
-------
COMMENT: On page 4-16 of the FS the first paragraph states "A 1-foot vegetative
cover would eliminate dermal exposure to the solidified mass" and the second
paragraph indicates that a 2-foot vegetative cover is required. The Reclaim Group
feels that a 1-foot vegetative cover is adequate.
RESPONSE: The amount of vegetative cover should be determined during design.
COMMENT: Asphalt capping is equivalent in achieving ARARs for the soil
contaminants of concern to the stabilization remedy. Concrete capping reduces the
mobility of the contaminants by removing the exposure pathways. An asphalt cap
achieves the overall purpose of preventing exposure to the soil contaminants of
concern.
•»
RESPONSE: Capping does not achieve chemical specific ARARS, the stabilization
remedy does.
COMMENT: In Table 4-11 of the FS, low rankings for Alternatives 1, 2, and 3 were
awarded for short-term effectiveness, and Alternatives 4 through 9 were awarded high
rankings but involve excavation, increased traffic noise and dust.
RESPONSE: Table 4-11 is incorrect with regard to short-term effectiveness as the
commenter states, although Alternatives 3 through 9 have comparable short term
impacts to one another as stated on page 4-41 of the FS.
COMMENT: Alternative 3-Capping is an effective remedial alternative comparable in
long-term effectiveness to Alternative 6-Stabilization. Both alternatives provide long
term controls to prevent exposure and migration of hazardous constituents contained in
soil.
RESPONSE: In Section 4.4.2 of the FS on pages 4-41 and 42 it explains that
Alternative 6 has greater long-term effectiveness than Alternative 3 because it
eliminates human exposures and migration of hazardous constituents as compared to
minimizing exposure and migration.
COMMENT: Alternative 5-Soil Washing is comparable in cost to Alternative 3 and 4
and should be evaluated with a comparable ranking score in the FS.
RESPONSE: Agreed, although Alternative 6 should have a higher score in the FS
because it costs less than Alternatives 3, 4, and 5.
COMMENT: One commeter requested that^he FS be revised to eliminate reference to
n-nitroso-diphenylamine and replace it with diphenylamine.
-------
RESPONSE: The change is unnecessary due to the change in the groundwater cleanup
goals changed from residential risk based to MCLs. There is no MCL for either
compound.
-------
Q NO SCALE
RGURE 1
Od SITE LOCATION MAP
npruwrr rwrrvnri!.R INC. SITE
-------
o -n
ro
PACKAGING CORPORATION OF AMERICA
-------
FORMER
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NOTES: 111
(2)
13)
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spilled 2.200 gallons
of laauer thinner.
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yards of seepage lagoon soils
and sludges were disposed of at
Che«-M«l services. Hyandolte. Michigan.
In September 1987. approximately
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BffWJ
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18
7.8
1.8
2
559000
S
10.4
Z2
1530
10
39600
121
0^
15.3
9420
10
1.6
101000
2
4.7
3.3
10
ROffi£L2
.(ug/L)
28
46
8-<
S-2
1
4
saoooo .
9
-7'
9
1870
3
41100
t23
°'2
1*
2000
2
35.6
105000
2
14
i" 1
-------
TiM*. Z. Companion 6«r«««o Gfoundwmi«r inorganic
Coflotntnuoni (uyl) and Th»ir Aitociil«g Background
Conevntraiions (u^l.).
Phis*U
"qfMty ffuo
^ound I
UGS
ll.T
IT
XI
IIJ
Round 2
UGS
17.1
17.1
P.I
X*
.OS
LOS
u
zu
1VJ
IJ
til
-------
TAHI.li 3
PHYSICAL AND CHEMICAL CONSTANTS OF DETECTED COMPOUNDS
COMPOUND
CASff
M.W.
S.G.
CHLORINATED HYUHOCAHBUNS
Vinyl Chloride
1.1-Otehtaroelhane
1.2-Dfchloroelhana
1,1-DtaNoroethene
cta-1.2-Dlchloroelhene
(rans-1.2-Otchkxoethane
Methytene Chloride
TatracMoroelhene
1.1.1-Trichkxoethaoe
1.1.2-Trfchloroethane
Trichkxoethene
Chloroform
75-01-4
75-34-3
107-06-2
75-35-<
156-58-i
156-W-f
75-09-;
127-1&4
71-5W
79-00-!
79-014
67-66-:
63
00
09
97
07
97
BS
166
133
133
131
110
001
.18
24
,22
.28
26
1.33
162
1.34
-
1.46
1.48
AROMATICS
Benzene
Chtorobenzene
Elhylbenzene
Toluene
Xylene (mixed)
79-01 •€
10B-90-7
100-41-^
108-883
1330-20-7
78
113
106
92
106
088
1.11
087
0.87
084
SolubMly
(man
2.8E«03
51E+03
85E«03
23E»03
35E«03
6 3E«03
20E<04
1.5E«02
15E«03
45E«03
1.1E*03
82E+03
18E«03
47E«02
15E«02
5.4E*02
20E»02
POLYNUCLEAR AROMATIC HYDROCARBONS
Acenaphlhene
Acenaphlhylena
Anthracene
Benzo(a)Anthracene
BenzofbjFluoranlhene
Benzo(g.h.l)Pen/lene
Benzo(a)Pyrene
Chrysene
Floofanlhene
83-32-8
20e-9W
120-12-7
56-55-2
205-00-2
191-24-2
50-32-8
21841G
206-44-C
154
152
178
228
252
276
252
228
202
1.02
0.90
128
1.11
-
•
1.11
1,27
1.25
3.4E«00
39E«00
4.5E-02
5.7E-03
14E-02
7.0E-04
1.2EX)3
1.8E-03
21E-01
LogKow
1.38
179
1.48
1.84
0.70
046
1.25
260
249
247
242
1.97
Koc
Vapor
Pressure
(mmHg)^
Henry's
Constant
(atm-m3/mol)
57E«01
30E«01
14E«01
65E«01
49E«01
59E<01
B.BE«00
36E»02
15E«02
56E«01
13E«02
31E»01
2.7E»03
23E»02
64E*01
S.8E«02
20E*02
3.4E«02
36E«02
18E*01
1.2E«02
30E«01
58E«01
15E»02
82E4)2
5.9EX)3
" 0.8E-04
3.0E-02
7.6E-03
6.7E-03
2.7E-03
2.5E-02
1.4E-02
1.2E-03
91E-03
29E-03
213
2.84
315
273
326
9.7E«01 9.5E'01
3.3E«02
1 1E»03
30E«02
24E«02
12E«01
70E«00
28E«01
10E«01
5.5E-03
3.5E-03
6.4E-03
5.9E-03
7.0E-03
4.00
3.70
445
5.60
606
651
606
5.61
490
4.6E*03
25E+03
14E»04
14E'06
55E+05
16E«06
5-56*06
20E«05
38E«04
1.6E-03
29E-02
2.0E-04
22EXW
50E-07
1.0E-10
S6E-09
63E-09
50E-06
0.2E-05
1.5E-03
10E-03
1.2E-06
1.2E-05
5.3E-OB
16E-06
1.1E-06
6.5E-06
(Page t of 2)
-------
Table M
Chemical-Specific Toxicity Values
Ingestion Exposures
-------
Table 4 (Continued)
Chemical-Specific Toxicity Values
Inhalation Exposures
1II4J
10149
us.*)
4.0143
I.SWS
BVOJ
ir*«o
3E-<0
IE«0»
«4I
JE-01
t
*.«Z4I| H
1M4I| H
I H
1.it-Oil 1
: H
K
I H
14MI
l.TI-KI
1JE«00
>.]§*»
earn*
OSTOM
iviim
0*02*4
OVOW4
OJ4BM
OMM4
OVD1X
0*02*4
OTOM
i
i.ooe«oo
i.oot««
i.0o**oo
I.ODC««
IOOC««0
].00€*00
I.OOC«CO
i.oot««o
I.OOE4I
I.OOE4I
I.OOE4I
1 .00141
1. 00X41
I.OOE4I
i.ooc-oi
I.OOC4I
I.OOC4I
I.OOC4I
100141
1.0*41
1.00Z4I
1.00141
I 00141
I.OOZ4I
1.00(41
I.OOI4I
I.OOC4I
I.OM41
I.OOC4I
100*41
100C4I
hmtov/MA
CMS
NA
NA
HA
NA
ttm
HA
-------
Table "H (Continued)
Chemical-Specific Toxicity Values
Dermal Exposures
Orrf
(TO
I.O*»flJ
|jCC
-------
Table £
Compulation of Daily Intake Values From Maximum Habitat Concentrations
Compound
Acetone
tarium
)enzo(a)Anthracene
Benzo(a)Pyrene
Benzo(b)Fluoranthene
Jeryllium
Cadmium
Chlordane(total)
Chromium
Chrysene
5ibenzo(a,h)anthracene
lndeno( 1 ,2,3-cd)pyrene
VianRanese
Maximum Concentration(ing/kg)
OWWH |FWH SSWH IOFTH
0.029S
108
0.37
0.52
1.2
0.3
11
0.0053
13.2
0.365
0.305
0.81
306
0.0295
108
0.37
02
0.2
0.69
0.21
0.001
II
0.2
0.2
0.2
792
0.044
95.1
0.2
0.2
0.97
0.57
0.21
013
193
0.2
0.2
0.2
972
0.025
108
6
6
6
0.57
I.I
5.7
26.2
6
6
6
685
Daily Intake
OWWH |FWH
0.0003
. 1.08
00037
00052
0.012
0.003
0.011
0.00005
0.132
0.00365
0.00305
0.0081
3.06
0.0003
108
0.0037
0.002
0.002
0.0069
0.0021
0.00001
0.11
0.002
0002
0.002
7.92
(mg/kg/day)
SSWH IOFTH
0.00044
0.951
0.002
0.002
0.0097
0.0057
0.0021
00013
0.193
0.002
0.002
0.002
9.72
0.00025
1.08
0.06
0.06
0.06
0.0057
0011
0.057
0.262
006
0.06
0.06
6.85
OWWH= Open Water Wetland Habitat SSWH= Scrub-Shrub Wetland Habitat
FWH = Forested Wetland Habitat OFTH - Old Field Terrestrial Habitat
Daily Intake = (Maximum Concentration, mg/kg) x (0.001 kg/day)/(. I kg)
-------
Table &
Determination of Ecological Hazard Indices for the Habitats of Concern
Compound
Acetone
Barium
Benzo(a)Anthracene
Benzo(a)Pyrene
Ben£o(b)Fluoranthene
teryllium
Cadmium
Chlordane(total)
Chromium
Chrysene
Dibenzo(a,h)anthracene
lndeno(1 ,2,3-cd)pyrene
Manganese
Appendix O
Dally Intake Rate
mo/kflMay)
LOAEL
500
5.1
2
0.002
40
0.273
2.4
99
0.006
72
0.06
NOAEL
0.166
0.01
Ecological
Screening Leva
(mo/ka/day)
500000
5100
2000
2
40000
16.6
1
273
2400
99000
6
72000
60
Daily lntake(mg/kgAday)
OWWH |FWH
0.0003
1.08
0.0037
0.0052
0.012
0.003
0.011
0.00005
0.132
0.00365
0.00305
0.0081
3.06
0.0003
1.08
0.0037
0.002
0,002
0.0069
0.0021
0.00001
0.11
0.002
0.002
0.002
7.92
SSWH IOFTH
0.00044
0.951
0.002
0002
0.0097
0.0057
0.0021
0.0013
0.193
0.002
0.002
0.002
9.72
•
0.00025
1.08
0.06
0.06
0.06
0.0057
0.011
0.057
0.262
0.06
0.06
0.06
6.85
Hazard Indices (HI)
OWWH |FWH |SSWH
6E-10
0.00021
2E-06
0.0026
3E-07
0.00018
0.011
2E-07
0.00006
4E-08
0.00051
1E-07
0.051
8E-10
0.00021
2E-06
0.001
5E-08
0.00042
0.0021
4E-08
0.00005
2E-08
0.00033
3E-08
0.132
9E-10
0.0002
1E-06
0.001
2E-07
0.0003
0.0021
SE-06
8E-05
2E-08
0.0003
3E-08
0.162
OFTH
5E-10
0.00021
0.00003
0.03
2E-06
0.00034
0.011
0.00021
0.00011
6E-07
0.01
8E-07
0.11417
Total HI 0.07 0.14 0.17 0.17
OWWH Open Water Wetland Habitat SSWH = Scrub-Shrub Wetland Habitat '
FWH = Forested Wetland Habitat OFTH - Old Field Terrestrial Habitat
Ecological Screening Criteria = (LOAEL, mg/kg/day) x (1000) or (NOAEL, mg/kg/day) x (100)
Hazard Index =• (Daily Intake, mg/kg/day)/(Ecofogical Screening Criteria, mg/kg/day)
-------
Table 7 Determination of Soil Cleanup Goals Based on Evaluation of Chemical-Specific ARARs
and Risk-Based Concentrations
Contaminants
of
Concern
Benzo(a)anthracene
Benzo(a)pyrene
Jenzo(b)fluoranthene
Bis(2-ethylhexyl)phthalate
ieryllium
Chromium (VI)
Lead
)ibenzo(a,h)anthracene
Indeno(l ,2,3-cd)jjyrene
Dieldrin
2,3,7,8-TCDD (TEF)
PCB (Aroclor- 1248V
Chemical-Specific ARARs
USEPAA
OSWER
Directive for lead
(ug/kg)
• <*
--
«• «•
--
•» «*
500,000
--
Background
Concentrations
for Inorganics
(ug/kg)
..
^HSiHK
19,840
13,990
MDEQ** « .
Generic Industrial1 ' '
Cleanup Criteria
(ug^cg)
210,000
21,000
210,000
1E+07
35,000
2.2E+07
f 1 ^^^^Mlli^^l^
21,000
210,000
9,400
0.99
21.000
Analytical
Detection
Level
(ug/kg)
330
330
330
330
200
200
r.ooo
330
330
iSi(fl^ii
0.001
330
Risk-based
Acceptable
Concentration
Levels
(ug/kg)
||ll|l:5liii!
Spl^liii
iifSfllip
333
|^l5l^3illli
Sp^J^Q||pl;
^feiilii^
19.3
s,;^ 6,085
^W,739 ' V
'USCPA OSWER Directive #9355.4-02 Memorandum. Interim Guidance on Establishing Soil Lead Cleanup Levels at Superfond Sites 1989
*USEPA, Drinking Water Regulations & Health Advisories. May 1994.
"MDEQ, MERA Interoffice Communication Operational Memorandum #14, (Revision 2), Remedial Action Plans using Generic Industrial
or Generic Commercial Cleanup Criteria, June 5,199S.
MA - Not available
]=chosen cleanup goal for each chemical of concern
------- |