PB97-964111
EPA/541/R-97/113
January 1998
EPA Superfund
Record of Decision:
J & L Landfill, OU 2
Rochester Hills, MI
9/30/1997
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Jones & Laughlin Landfill, Rochester Hills, Oakland County, Avon Township, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Jones & Laughlin Landfill
(JLLF), in Rochester Hills, Michigan, which was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfiind Amendments and Reauthprization Act of 1986 (SARA), and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This
Record of Decision (ROD) is for the groundwater operable unit (OU2) remedial action. The
landfill has already been addressed as OU1 in a separate ROD, dated June 30,1994.
The State of Michigan does not concur 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 ROD, may pose an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The purpose of this remedy is to eliminate the groundwater exposure pathway for potential
human receptors. The selected remedy for OU2 consists of implementing groundwater use
restrictions, installing monitoring wells, and performing periodic groundwater monitoring.
Other components of the selected remedy include:
• Requirement to implement enforceable deed restrictions which restrict groundwater use at
that portion of the facility where contaminated groundwater from JLLF has come to be
located under Sandfill Landfill #2, in addition to the deed restriction currently in place on
the JLLF property;
• Installing three monitoring well nests, one upgradient and two downgradient, with each
nest consisting of a shallow and a deep well;
• Perform baseline quarterly groundwater monitoring and subsequent annual groundwater
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monitoring, if deemed appropriate, of COCs at residential wells and at on-site and off-
site monitoring wells. As a contingency, if these downgradient wells indicate that there is
an unacceptable risk due to contamination from the JLLF site, residences will be
provided with an alternate water supply,
STATUTORY DETERMINATIONS
The selected remedial action is protective of human health and the environment, complies with
federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. The selected remedial action constitutes a final
groundwater remedy under CERCLA and complies with the requirements of Part 201 of the
Michigan Natural Resources and Environmental Protection Act 1994 PA 451, as amended. The
statutory preference for remedies that reduce the toxicity, mobility, or volume as a principal
element is not achieved with this action. However, unless or until indications that groundwater
degradation attributable to the JLLF site is occurring and contamination threatens private water
supplies, extension of the municipal water supply system is not supportable.
U.S. EPA has determined that its response at this site is complete. Therefore, the site now
qualifies for inclusion on the Construction Completion List.
This remedial action will result in potentially hazardous substances remaining on site above
health-based levels. A review will be conducted within five years after commencement of the
remedial alternative implementation. This will ensure that the remedy continues to provide
adequate protection of human health and the environment.
William E. Muno, Director Date
Superfund Division
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TABLE OF CONTENTS
I. Site Name, Location, and Description 1
II. Site History and Enforcement Activities 1
A. Site History 1
B. Past Studies 2
III. Highlights of Community Participation 3
IV. Scope of the Selected Remedy '. , 4
V. Summary of Current Site Conditions 4
A. Topography : 5
B. Geology 5
C. Hydrology 5
D. Contamination Source 6
VI. Summary of Remedial Investigation Results 6
VII. Summary of GeoProbe Sampling Results 8
VIII. Current Construction Activities at the JLLF..... 10
IX. Summary of Site Health Risks and Environmental Impacts 11
A. Identification of Chemicals of Potential Concern 11
B. Exposure Assessment 12.
C. Toxicity Assessment 13
D. Risk Characterization 14
E. Uncertainties 15
F. Additional Studies 16
1. On-site Groundwater - Residential Exposure 17
2. On-site Groundwater - Industrial Exposure 17
3. Off-site Downgradient Groundwater -
Residential Exposure 18
X. Rationale for Further Action 18
XI. Description of Alternatives 19
XII. Summary of Comparative Analysis of Alternatives 21
A. Threshold Criteria 22
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B. Primary Balancing Criteria 23
C. Modifying Criteria 27
XIII. The Selected Remedy... 27
XIV. Implementation of the Contingency Plan 28
XV. Statutory Determinations 29
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DECISION SUMMARY
J&L Landfill
I. SITE NAME. LOCATION. AND DESCRIPTION
The Jones and Laughlin Landfill (JLLF) Superfund site is located on Hamlin Road in Rochester
Hills, Michigan (Figure 1). The area surrounding and including the JLLF is generally level,
with the exception of a drainage ditch along the eastern boundary, Ladd Drain near the northern
boundary, the south ditch along Hamlin Road, and a sediment pond in the northwestern corner of
the site (Figure 2). The pond has been subsequently filled in and capped as a result of the
Operable Unit One (OU1) Remedial Action. Vegetation covers most of the site except in
scattered patches and roadways.
Land use in the vicinity of the JLLF includes residential, industrial, recreational, other landfill,
and mining facilities. The JLLF is bordered on the east and north by Sandfill Landfill No. 2, and
on the west by Sandfill Landfill No. 1. There are at least six other landfills within one-half mile
of the site. Residential areas exist within 500 feet of the southern property boundary,
approximately 1,000 feet northwest of the site, and approximately 600 feet east of the site along
Hamlin Road. The JLLF and adjacent properties are zoned light industrial.
The Clinton River is located less than one mile east of the JLLF, and flows from northwest to
southeast through the Rochester-Utica State Recreation Area. Ladd drain, which is located on
the northern boundary of the site, drains into the Clinton River. Surface water drainage from the
area flows primarily to the north and east toward the Clinton River. Groundwater flow direction,
similarly, is towards the north and east.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
Steel slag and steel manufacturing wastes were the primary wastes disposed at the site, which
was a former sand and gravel borrow area. During 1967 or 1968, baghouse dust filters were
installed on the electric arc furnaces at the J&L Steel, Warren, Michigan facility. The dust
collected by these filters, referred to as electric arc furnace (EAF) dust, was thereafter co-
disposed of with slag at the JLLF. This EAF dust, if classified today, would be considered a
listed hazardous waste under the Resource Conservation and Recovery Act (RCRA). Disposal
operations at the JLLF may have started as early as 1951, and were terminated in 1980 when the
site was closed and a cap was installed.
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By November of 1980, the JLLF had been brought up to grade, as specified by Avon
Township/Rochester Hills, and covered with a landfill cap. This cap appeared to have been
mixed with slag materials, and was dotted with areas void of vegetation and scattered with
debris. After investigation, a hew cap is being constructed in accordance with the specifications
stipulated in the ROD for OU1. A prefmal inspection was conducted on September 29, 1997.
Construction of the cap was determined to be substantially complete.
B. Past Studies
In 1976, the Michigan Department of Natural Resources (MDNR) conducted an area-wide
groundwater study and identified an area of groundwater contamination primarily attributed to a
landfill west of the JLLF. As a result, local residents were provided with an alternative drinking
water supply. This study also determined that although the area-wide groundwater
contamination problem was attributable to many possible sources, the JLLF was probably
contributing as well.
U.S. EPA Region 5 files indicate that the J&L Steel Company submitted a CERCLA notification
in June 1981, claiming ownership of the subject property for which it reported disposal of 55,555
cubic yards of steel slag from 1966 to 1980. Ecology and Environment, Inc. (E&E), completed a
Preliminary Site Assessment in July, 1983, followed by a Site Inspection in June, 1984 to verify
the site location and ownership. The Hazard Ranking System (HRS) scoring was completed by
an E&E Field Investigation Team (FIT) in July, 1985, with an HRS score of 31.65 based on the
site's potential for groundwater contamination. The site was proposed for addition to the
National Priorities List (NPL) in the June 10,1986 Federal Register (Volume 51, Number 111.
pages 21099-21108).
A comprehensive field investigation was conducted during the Remedial Investigation (RJ) in
order to determine the nature and extent of contamination at the JLLF. This investigation
included geophysical study, waste characterization borings followed by waste sampling and
analysis, surface soil sampling, surface w
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OU1 began in the summer of 1996. A prefmal inspection was conducted on September 29, 1997.
Construction of the cap was determined to be substantially complete.
Additional testing has been performed to determine an appropriate remedy for OU2. GeoProbe
sampling was completed in June, 1996. The results are summarized 'in a technical memorandum
issued on September 30,1996. The Focused Feasibility Study for OU2 was completed in
August, 1997, and outlines four alternatives for addressing this operable unit.
HI. HIGHLIGHTS OF COMMUNITY PARTICIPATION
An RI fact sheet was released by 'he U.S. EPA in July of 1990, followed by a public meeting on
August 6, 1990, to inform the local residents of the Superfund process and the work to be
conducted during the RI. In February, 1992, the U.S. EPA issued a second letter to the public to
inform them of the upcoming RI public meeting on March 12,1992, where the results of this
study were discussed.
Information repositories have been established at the Rochester Hills Public Library, 500 Olde
Towne Road, Rochester, Michigan and Rochester Hills City Hall, 1000 Rochester Hills Drive,
Rochester Hills, Michigan. In accordance with Section (113)(k)(l) of CERCLA, the
Administrative Record is available to the public at these locations, as well as the U.S. EPA
Region 5 office in Chicago, Illinois.
The Proposed Plan for OUI was available for public comment from January 25, 1994 to March
26, 1994 through the release of a fact sheet. A public meeting was held on February 9, 1994 to
present the Proposed Plan and U.S. EPA's recommended alternative for OUI at the JLLF. At the
public meeting, U.S. EPA and the Michigan Department of Natural Resources (MDNR)
answered questions about the site and the remedial alternatives under consideration. Formal oral
comments on the Proposed Plan were documented by a court reporter. A verbatim transcript of
this public meeting has been placed in the information repositories and the Administrative
Record.. Written comments were also accepted at this meeting.
Advertisements announcing the availability of the Proposed Plan for Obi and the start of the
comment period were published in the Oakland Press on January 17,1994. Post cards were also
sent out to parties on U.S. EPA's mailing list to announce the extension. Oral and written
comments received during the above mentioned Public Comment period and the U.S. EPA's
responses are included in the Responsiveness Summary of the ROD for OUI.
Advertisements announcing the availability of the Proposed Plan for OU2 and the start of the
comment period were published in the Detroit Free Press on August 17, 1997 and in the
Rochester Hills Eccentric on August 24, 1997. The Proposed Plan for OU2 was issued in August
1997, and was available for public comment from August 18,1997 through September 17, 1997.
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A public meeting was held in the Town Hall of Rochester Hills on August 26 to present the
Proposed Plan and U.S. EPA's recommended alternative for OU2 at the JLLF. At the public
meeting, U.S. EPA and the Michigan Department of Environmental Quality (MDEQ, formerly
MDNR) answered questions about the site and the remedial alternatives under consideration.
Formal oral comments on the Proposed Plan were documented by a court reporter. A verbatim
transcript of this public meeting has been placed in the information repositories and the
Administrative Record. Written comments were also accepted at this meeting.
The public participation requirements of CERCLA Sections 113(k)(2)(B)(I-v) have been met in
the remedy selection process for OU2 at JLLF. This decision document presents the selected
remedial action for the JLLF chosen in accordance with CERCLA, as amended by SARA and, to
the extent practicable, the NCP. The decision for this site is based on the Administrative Record.
IV. SCOPE OF THE SELECTED REMEDY
This ROD addresses the final remedy for groundwater (OU2) at the JLLF under CERCLA. The
threat posed by the site to human health and the environment is the potential for unacceptable
concentrations of contaminants found in the groundwater in on-site monitoring wells
(contaminants from the JLLF site) to migrate downward and horizontally in the direction of
groundwater flow, ultimately degrading the groundwater quality in the off-site private drinking
water wells. Based on the investigation conducted, a number of potential sources for
groundwater contamination exist within the direct vicinity of the JLLF site. Groundwater data
shows widespread impact by metals, namely Aluminum, Iron, Manganese and Sodium.
Concentrations exist upgradient to the JLLF site at levels comparable to down gradient data.
Based on groundwater monitoring data and GeoProbe data, the concentrations of those organic
constituents detected in the downgradient groundwater did not exceed their respective cleanup
criteria. In general, the inorganic constituents aluminum, iron, and manganese seemed to be
present on a regional basis at concentrations that exceeded their generic cleanup criteria.
However, to provide an additional level of assurance, it has been determined that the private
water supply wells and selected site monitoring wells should be sampled periodically for thirty
years for indications of groundwater degradation. If this is detected as defined, in the
contingency plan, the contingent remedy to provide alternate water supply will be implemented.
The trigger mechanisms for the contingency are further defined in section XIV of this Record of
Decision.
V. SUMMARY OF CURRENT SITE CONDITIONS
The RI performed at the JLLF was designed to characterize the nature and extent of
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contamination posed by the landfilled materials at the site, and to conduct a human health risk
assessment and environmental assessment. The RI included sampling and analysis of
groundwater, surface water, sediments of the surrounding ditches and pond, surface soil,
subsurface soil (waste borings), and residential wells. In addition to chemical analysis, waste
boring samples were collected and tested for their leaching potential (also known as Extraction
Procedure (EP) toxicity).
Based on the results of the RI, U.S. EPA had determined that current risks posed at the JLLF
include direct contact with sediments contaminated with polyaromatic hydrocarbons (PAHs) and
inhalation of surface soils containing chromium and other heavy metals. Surface samples along
the side slopes of the east ditch, sediment pond, and Ladd Drain also contain low levels of
volatile organic compounds (VOCs) and semivolatile organic compounds (SVOCs), in addition
to the heavy metals previously mentioned. In addition, waste boring samples analyzed for
leaching characteristics showed that selenium in one sample and lead in another, had the
potential to leach into the groundwater. Other heavy metals, including nickel and zinc, were
found to have leaching potentials, but do not have established EP toxicity maximum allowable
concentrations. As a consequence of this risk finding, U.S. EPA signed a ROD to address the
elements of the above mentioned risk the remedial action of which has been completed this fall.
Specific information related to the construction of the first OU can be found in section VIII of
this ROD. U.S. EPA also determined, through the RI results, that a threat to human health and
the environment is posed through future residential exposure upon ingestion of groundwater
directly beneath the site contaminated with arsenic, and through direct contact with sediments
contaminated with heavy metals and PAHs, which is the focus of this Record of Decision.
In addition, arsenic was also found in a saturated area of general refuse currently below the water
table; however, data indicates that the arsenic is not currently mobile and has not migrated off the
JLLF site.
.A. Topography
The JLLF is on the surface of a glacio-lacustrine delta which slopes to the southeast at a
relatively shallow gradient. The delta is comprised of approximately 35 to 40 feet of sand and
gravel deposits which have been extensively mined throughout the area. Underlying the sand
and gravel deposits are thick lacustrine and morainal silty clay deposits, followed by bedrock
composed primarily of shales.
B. Geology
Three stratigraphic units consisting of landfill materials, deltaic sand and gravel, and clay
materials were encountered during drilling at the site. Landfill materials are further divided into
clay materials and waste fill material. Waste material encountered consists of slag from 2 to 18.5
feet thick and general refuse from 3.25 to 22.5 feet thick. In some areas, the two waste materials
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are mixed. EAF dust was not directly observed in discrete quantities, but may have been
encountered as very fine-grained material mixed within general slag material. Sand and gravel
deposits ranging from 7.5 to 25 feet thick and silty clay directly underlie the landfill materials.
C. Hydrology
An unconfined water table aquifer extends into JLLF waste materials. Monitoring wells installed
at on- and off-site locations indicate that groundwater flow in the upper and lower portions of the
aquifer is eastward, and that the water table elevations fluctuate seasonally. Slug tests performed
on all on-site monitoring wells indicate that the mean hydraulic conductivities for the upper and
lower portions of the aquifer are 8.14 x 10° cm/sec, and 1.43 x 10° cm/sec, respectively. This
data indicates that the upper portion of the aquifer is more permeable and more conducive to
contaminant transport than the lower portion of the aquifer. This is also reflected in the finer
material grain size and the decrease in moisture content observed with depth. The mean
groundwater flow velocity for the upper portion of the aquifer is approximately 175 ft/year, and
is approximately 15 ft/year for the lower portion. Laboratory permeability tests performed on
silty clay and clayey silt materials at the base of the shallow aquifer ranged from 5.5 x 10'7 to 6.6
x 10'7 cm/sec, indicating that the materials are capable of retarding, but not preventing, vertical
migration of groundwater.
Surface water flow rates were measured during both dry and wet weather conditions at various
locations upstream, adjacent to, and downstream of the JLLF in Ladd Drain and the east ditch,
and in the on-site sediment pond. Based on the depth of the pond, surface water elevation, and
groundwater elevations in nearby wells, it is probable that the sediment pond acts as a localized
groundwater discharge zone. The sediment pond contains water that flows actively through the
pond in a west-to-east direction via inlet and outlet culverts.
D. Contamination Source
The source of contamination at the JLLF is the landfilled waste, which is comprised of steel slag,
steel manufacturing waste intermixed with EAF dust, and general refuse. The estimated volume
of waste contained within the landfill is approximately 455,000 cubic yards, of which
approximately 65% (295,750 cubic yards) consists of steel manufacturing waste (slag intermixed
with EAF dust), and approximately 35% (159,250 cubic yards) consists of general refuse.
Section VIII of this ROD contains the specifics on how this source was addressed through
operable unit one.
VI. SUMMARY OF REMEDIAL INVESTIGATION RESULTS
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The Remedial Investigation was conducted during the summer of 1990, with additional sampling
conducted in January 1991. The scope of work for the investigation included the following:
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sampling and analysis of waste material, natural soil and surface soil, surface water and
sediment, residential water wells, and groundwater. A geophysical survey was also performed.
Results of the sampling indicate that the landfill contents are composed of clay materials
consisting of silty clay, clayey silt, sand, and waste fill material. Clay materials comprised the
existing landfill cap and solid fill in areas that were devoid of waste presumably to bring the
landfill up to the surrounding surface grade. (That cap is currently being replaced as part of the
remedial action for OU1.) Waste material encountered consists of slag from 2 to 18.5 feet thick,
and general refuse from 3.25 to 22.5 feet thick. In some areas the two waste materials are mixed.
There is also the possibility that EAF dust is mixed with some of the waste, although the data
collected to date does not confirm this.
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The hydrogeological investigation indicated that the groi ndwater flow is from west to east. The
water table surface was found at approximately 13 to 16 feet below ground surface in the central
portions of the landfill. These elevations correspond to levels within the landfill waste.
Results of the waste boring sample indicate that VOCs and SVOCs are predominantly associated
with general refuse, while inorganics (metals) are the primary constituents present in the slag
material. However, in an analysis performed by J&L Steel in 1980 of EAF dust collected from
the J&L Plant in Warrenville, Michigan, 2.1 weight percent of the EAF dust sample was found to
be composed of volatile solids/soils. Also, two waste boring samples collected from the area of
general refuse showed that EP toxicity values for selenium in one sample, and lead in the other
sample, exceeded the maximum concentrations of contaminants characteristic of EP toxicity, as
cited in Code of Federal Regulations (40 CFR 261.24). For this reason, the general refuse
material, at least at the two locations, can be considered hazardous based on the teachability of
lead and selenium. Eight waste boring samples were also collected and analyzed from the slag
and steel waste materials. Although these results indicate that EP toxicity metal concentrations
were very low and not above standards, there is the potential for low levels of selenium, lead,
chromium, nickel, and zinc to leach into the groundwater from the slag and steel wastes under
the right conditions.
In other analyses, the slag material exhibited elevated concentrations of antimony, arsenic,
calcium, chromium, cobalt, iron, magnesium, manganese, nickel, silver, thallium, and zinc. Of
these 12 inorganics, calcium, chromium, magnesium, manganese, nickel, and zinc were also
reported as components in the EAF dust analysis conducted by J&L in 1980. This indicates the
probable presence of EAF dust in the samples, although discrete quantities of the material were
not specifically observed during RI sampling.
Surface soil sampling results also indicate that low levels of organic compounds including
toluene, acetone, benzo(b)fiuoranthene, benzo(a)pyrene and fluoranthene are present on the side
slopes of the east ditch, on-site sediment pond, and Ladd Drain. High levels of inorganic
chemicals were detected in the southwest and northeast areas of the site devoid of vegetation.
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The presence of these contaminants, in addition to groundwater sampling results, indicate that
the landfill may be a source of groundwater contamination.
Groundwater sampling results, from wells located on the JLLF site, indicate that VOCs, SVOCs,
pesticides, and inorganic chemicals are present in the groundwater directly beneath the site. The
VOC contaminants found included acetone, 2-butanone, benzene, toluene, ethylbenzene, and
total xylenes. The Maximum Contaminant Levels (MCLs) for total xylenes, ethylbenzene, and
benzene were exceeded. The MCL for arsenic was also exceeded in groundwater underlying an
area of saturated general refuse within the JLLF. Although the detected VOCs in groundwater
beneath the site assisted in driving the future risk to human health and the environment up to the
calculated levels, groundwater in both the upper and lower portions of the aquifer was also found
to contain some VOCs as it entered the J&L site. Thus, the JLLF appears to be contributing to
the area groundwater contamination, most likely through the areas of general refuse where the
majority of VOCs and the highest concentrations were detected. The residential wells that were
sampled downgradient of the site were found to be free of contamination originating from the
site.
VII. SUMMARY OF GEOPROBE SAMPLING RESULTS
The results of the four rounds of groundwater sampling conducted during the RI suggested that
several constituents detected in the groundwater may be resulting from potential sources
upgradient from the JLLF site. Therefore, additional groundwater sampling was conducted
utilizing a GeoProbe sampling device in June 1996 to characterize groundwater quality in areas
immediately upgradient and downgradient of the JLLF. The procedures and results of the
GeoProbe sampling are described in "Technical Memorandum Documenting the Results of
GeoProbe Sampling", dated 30 September, 1996. The results are summarized below.
The GeoProbe groundwater samples were collected from the following four areas: the area
upgrccient of the Sandfill Landfill No. 1 (samples GP01, GP06, GP07, and GP08), the area
within the boundaries of the Sandfill Landfill No.l (sample GP03), the area within the
boundaries of the Sandfill Landfill No. 2 (samples GP09 and GP10), and the area downgradient
of the Sandfill Landfill No. 2 (samples GP11 and GP12). Sandfill Landfill No. 1 is upgradient of
the JLLF, and Sandfill Landfill No. 2 is downgradient of the JLLF. Figure VIM shows the
locations of the landfills in the area and the locations where the GeoProbe samples were
collected.
Each sample was analyzed for Routine Analytical Services (RAS) Target Analyte List (TAL)
inorganics and Target Compound List (TCL) organic parameters (except GP12, which was
analyzed only for TCL VOCs because of insufficient sample volume). The constituents detected
in the GeoProbe groundwater samples were compared to the MDEQ generic groundwater
cleanup criteria. The following exceedances were noted:
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• Aluminum, iron, lead, manganese, sodium and thallium exceeded the MDEQ
generic cleanup criteria in some.of the samples upgradient of the Sandfill Landfill
No. 1. However, VOCs and SVOCs did not exceed the MDEQ generic cleanup
criteria in the samples upgradient of the Sandfill Landfill No.l.
• Acetone, 4-methyl-2-pentanone, 4-methylphenol, naphthalene, aluminum,
antimony, cadmium, chromium, cobalt, iron, lead, magnesium, manganese, nickel
and sodium exceeded the MDEQ generic cleanup criteria in the sample within the
boundaries of Sandfill Landfill No. 1.
• Benzene, aluminum, barium, iron, lead, manganese, and sodium exceeded the
MDEQ generic cleanup criteria in some of the samples within the boundaries of
the Sandfill Landfill No. 2.
• Aluminum, iron, and manganese exceeded the MDEQ generic cleanup criteria in
some of the samples downgradient of the Sandfill Landfill No. 2. However,
VOCs and SVOCs did not exceed the MDEQ generic cleanup criteria in the
samples downgradient of the Sandfill Landfill No. 2.
• Pesticides did not exceed the MDEQ generic cleanup criteria in any GeoProbe
samples.
The following conclusions were reached based on a comparison of the results of the GeoProbe
sampling effort with the results obtained from the four rounds of sampling of the monitoring
wells located within the boundaries of the JLLF:
• The shallow groundwater upgradient of the Sandfill Landfill No. I had a fewer
number of VOCs, SVOCs, inorganics, and pesticides than the groundwater at the
JLLF. In addition, those constituents that were detected in the upgradient shallow
groundwater were detected at lower concentrations than in the groundwater at the
JLLF.
• The shallow groundwater within the boundaries of the Sandfill Landfill No. 1 had
many of the same constituents that were found in the groundwater at the JLLF
site; however, the concentrations of these constituents were typically higher at the
Sandfill Landfill No. 1 than they were at the JLLF. The one exception was
benzene, which was detected in the shallow groundwater at the Sandfill Landfill
No. 1 at a lower concentration than was detected in the groundwater at the JLLF.
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• Significantly fewer organic constituents were detected in the shallow groundwater
from the area that is downgradient of the Sandfill Landfill No. 2. The
concentrations of those organic constituents detected in the downgradient
groundwater to Sandfill Landfill #2 did not exceed their respective cleanup
criteria.
• In general, the inorganic constituents aluminum, iron, and manganese seemed to
be present in the local area at concentrations that exceeded their respective generic
cleanup criteria.
Thus, several constituents detected in the groundwater beneath the JLLF site may be resulting
from potential sources upgradient of the JLLF site. The inorganic constituents aluminum, iron,
and manganese appear to be present on the local level a., concentrations that exceed their MDEQ
generic cleanup criteria. The existing shallow groundwater data indicates that the organic
constituents do not exceed the MDEQ generic cleanup criteria downgradient of the area landfills.
VIII. CURRENT CONSTRUCTION ACTIVITIES AT THE JLLF
Construction at the landfill as part of the remedy for OU1 is nearing completion, and will result
in a reduction in the potential for migration of contaminants to the groundwater. The remedy
consists of a 1-foot compacted clay layer overlain with a Geosynthetic Clay Liner (GCL/60 mil
Flexible Membrane Liner (FML) barrier layer, a drainage layer consisting of geonet with
geotextile filter fabric, a 36-inch clean fill layer, and a 6-inch topsoil layer; consolidation of the
contaminated soil and sediments from the east ditch; and monitoring of the contaminated
groundwater beneath the site. In addition, a proper slope will be constructed and maintained so
that all surface water runoff properly drains off the cap into a collection system, or drainage
ditches around the perimeter of the site. Other components of this remedy include:
•
• Abandoning (plugging) the sediment pond culverts, consolidating any
contaminated soils/sediments beneath the existing landfill cap and back filling the
sedimentation pond to grade with clean fill;
• Consolidating any contaminated surface soils and sediments, including landfill
waste, from the east ditch to beneath the existing landfill cap;
• Regrading the south ditch to retain existing stormwater capacity;
• Retrofitting existing monitoring wells;
• Preparing the existing landfill surface in order to provide a foundation for the new
cap, as well as removing existing vegetation from the landfill surface;
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• Regrading the site to promote runoff;
• Installing a passive gas management system;
• Implementing a long-term groundwater monitoring program to ensure the
effectiveness of the remedial action;
• Placing a vegetative cover over the surface of the landfill;
• Installing a fence;
• Using institutional controls, including deed restrictions, to limit land and
groundwater use;
• Establishing a monitoring plan for cap integrity and fence inspection, and landfill
gas migration.
Construction in accordance with this remedy is underway and is expected to be completed in the
Fall of 1997. A pre-fmal inspection is scheduled for September 29, 1997 at which time the
agency will inspect the completed construction.
IX. SUMMARY OF SITE HEALTH RISKS AND ENVIRONMENTAL IMPACTS
As part of the J&L Landfill site investigation, U.S. EPA conducted a Human Health Risk
Assessment to determine if contamination from the landfill could pose a present or future risk to
human health. CERCLA, 42 U.S.C. §§ 9601 et seq., requires that U.S. EPA protect human
health and the environment from current and potential exposure to releases of hazardous
substances at or from the site. This assessment was prepared in a manner consistent with U.S.
EPA policy, as expressed in "Role of the Baseline Risk Assessment in Superfund Remedy
Selection Decisions," dated April 22, 1991. The study compared contaminant levels detected at
the landfill with Michigan and federal standards, considered the manners in which people could
be exposed to these contaminants, and estimated whether these contaminants could pose a threat
to human health. The potential risks to human health were calculated based on the assumption
that no future remedial actions would be taken at the site.
A. Identification of Chemicals of Potential Concern
The purpose of selecting chemicals of potential concern (COPC) for the risk assessment is to
identify those chemicals present at the site most likely to be of concern to human health and the
environment. In general, a chemical was considered as a COPC in the risk assessment if:
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• The chemical was determined not to be an artifact of sampling and/or laboratory
analysis during data validation;
• The maximum detected concentration exceeded published risk-based screening
concentrations, i.e., MDEQ Generic Residential Groundwater Cleanup Objectives
(MDEQ, 1996) and U.S. EPA Region III Risk-Based Concentrations (U.S. EPA,
1996);
• The frequency of detection was greater than 5 percent
Monitoring well and GeoProbe data were screened separately because of differences in sampling
technique and sampling locations (on-site, upgradient, and downgradient). The COPCs in
groundwater are:
Monitoring Wells
Acetone
Benzene
2-Butanone
Toluene
Bis (2-ethylhexyl)phthalate
1,4-Dichlorobenzene
4-Methyl phenol
alpha-Chlordane
4,4'-DDT •
Aluminum
Antimony
Barium
Beryllium
Cadmium
Chromium
Iron
Lead
Manganese
Nickel
Sodium
Thallium
Zinc
Cyanide
GeoProbe
Acetone
Benzene
Chlorobenzene
Ethylbenzene
Xylene
1,4-Dichlorobenzene
4-Methyl phenol
alpha-Chlordane
4,4'-DDT
Naphthalene
Heptachlor epoxide
4,4'-DDE
Antimony
Arsenic
Barium
Cadmium
Chromium
Iron
Lead
Magnesium
Manganese
Nickel
Sodium
Vanadium
Zinc
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B. Exposure Assessment
The objectives of the exposure assessment are to identify actual and potential exposure pathways,
and to characterize potentially exposed populations at the site, and to determine the extent of
exposure. There are two scenarios to consider for an exposure assessment. The first is a current
use scenario and the second is a reasonable future use scenario. In order to complete an exposure
assessment, the exposure pathways must be identified. An exposure pathway must include the
following four elements: 1. a source and mechanism of chemical release to the environment; 2.
a transport media (e.g. groundwater); 3. an exposure point; and 4. an exposure route such as
ingestion or inhalation at the contact point. In summary, the exposure assessment is a review of
how contamination may come in contact with living organisms via groundwater.
Most residences within a mile downgradient of the site are hooked up to a municipal water
supply. A residential water use survey (November 1996) found three residences within one mile
downgradient that have private wells presumably set in the shallow aquifer (well depths were
unknown for two of these three wells). The remaining residences surveyed either receive
municipal water or their wells are set in the deeper aquifer.
The shallow groundwater at the JLLF and the adjacent Sandfill Landfills and the Kingston
Development site is not presently used as a potable water supply. This use is extremely unlikely
to occur in the future since deed restrictions are in place for the JLLF site as a result of the OU1
ROD. Therefore, this exposure pathway is considered not to be complete. This pathway is
included in the baseline risk assessment as part of a conservative approach to evaluate exposure
in the event of future use of shallow groundwater should deed restrictions fail.
Groundwater may also be used for nonpotable purposes. The use of groundwater for showering
or other general washing and bathing activities may result in inhalation of COPCs released as
vapors. This may be especially significant for VOCs. In addition, these same activities result in
whole or partial contact with the impacted water, potentially resulting in absorption of COPCs
through the skin. Daily derma xposure during showering or bathing is chosen to be
representative of all dermal exposure (e.g., washing hands, dishes, cars) because it includes
activities that people can be assumed to engage in throughout the year and because it involves
whole body contact with impacted water.
C. Toxicity Assessment
In evaluating potential health risks, both carcinogenic and noncarcinogenic health effects must be
considered. Excessive exposure to any pollutant can potentially produce noncarcinogenic health
effects, while the potential for carcinogenic effects is limited to exposure to certain substances.
Existing health criteria developed by the U.S. EPA were obtained from the Integrated Risk
Information System (IRIS) database or the Health Effects Assessment Summary Tables
(HEAST) documents. Values developed by the Environmental Criteria and Assessment Office
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(ECAO; as presented in U.S. EPA, 1996) were used for several chemicals. The carcinogenic and
noncarcinogenic toxicity criteria used in this risk assessment are provided in Tables 4-1 and 4-2,
respectively, in the Baseline Risk Assessment Addendum (28 July 1997).
Although total chromium was measured at this site, no RfD is available for total chromium.
Rather, two different RfDs have been determined for trivalent chromium and hexavalent
chromium. For this risk assessment, it was assumed that 90 percent of the total chromium at the
site is trivalent chromium and that 10 percent is hexavalent chromium.
D. Risk Characterization
Human health risks for carcinogenic and noncarcinogenic contaminants are discussed separately
because of the different lexicological endpoints and the different methods employed in
characterizing risk. Incidental human health risks associated with exposure to carcinogenic
contaminants are calculated by multiplying exposure levels for each contaminant by multiplying
exposure levels for each contaminant by corresponding cancer slope factors. The total combined
cancer risk is then estimated by summing the risk estimates derived for each compound. This
approach is in accordance with U.S. EPA guidelines on chemical mixtures, in which risks
associated with carcinogens are considered additive (U.S. EPA, 1986). This approach also
assumes independence of action by the contaminants (i.e., that there are no synergistic (positive)
or antagonistic (negative) interactions between contaminants) and that all of the chemicals have
the same lexicological endpoint (cancer).
When considering potential health risks, U.S. EPA examines two factors—the risk of
contaminants causing cancer, and the risk of contaminants causing other ailments, such as
respiratory, heart, or nervous system disorders. According to the NCP, U.S. EPA's general
cleanup policy under Superfund indicates that when the cancer risk falls between one additional
cancer case in every 10,000 people and one additional cancer case in 1 million people, action
may be necessary depending on site-specific factors such as location and environmental impact.
If the risk is less that one additional cancer case in 1 million, action is generally not required
unless there is an unacceptable "non-carcinogenic" or environmental risk.
When calculating non-cancer risk, U.S. EPA uses a hazard index (HI) for both short-term
(subchronic) exposures and long-term (chronic) exposures. An HI of greater than 1.0 indicates a
potential for adverse health effects due to exposure to toxic compounds and is also considered an
unacceptable risk level which requires action.
Cancer risks associated with the future potential on-site residential scenario exceed the 1 in one
million point of departure for ingestion, inhalation, and dermal absorption of groundwater, and
for ingestion and dermal absorption of soil. Non-cancer risks associated with the future on-site
residential use of groundwater as a potable water supply also exceed acceptable levels (HI greater
than 1), and are primarily due to arsenic.
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Residential and industrial use of groundwater under the JLLF site were considered in this
evaluation. Total cancer risk and total noncarcinogenic health effects are presented in Table IX-
1. Under an on-site residential scenario, total cancer risks ranged from 2E-04 to 6E-04, and the
total noncarcinogenic hazard index ranged from 12 for an adult to 28 for a child. Under an on-
site industrial land use, total cancer risk ranged from 3E-05 to 1E-04, and the total
noncarcinogenic hazard index ranged from 2 to 4.
Table IX-1
Re-evaluation of Oil-Site Groundwater Risks
JLLF
Exposure
Route
On-Site Residential
Cancer Risk
Hazard Index
Adult
Child
On-Site Industrial
Cancer Risk
Represent ative Average Exposure ( R A E ]
Ingestton
Dermal Contact
Inhalation
TOTAL:
Ingestion
Dermal Contact
Inhalation
TOTAL:
2E-04
1E-12
IE-OS
2E-04
Reasonab
6E-04
2E-06
2E-05
6E-04
12
0.02
0.02
12
28
0.04
O.I
28
le Maximum
12
0.04
0.02
12
28
0.07
0.1
28
3E-05 '
1E-07
1E-06
3E-OS
Exposure (RME)
IE-04
IE-06
7E-06
•IE-04
Hazard Index
2
0.01
0.01
2
4
0.03
0.01
4
With the exception of arsenic, these risks fall within the range of acceptable cancer risk. Excess
cancer risks in the range from IE-04 to IE-06 may not be considered acceptable depending on
site-specific factors. In an April 1991 memorandum (OSWER Directive 9355.0-30), the U.S.
EPA further clarified the acceptable carcinogenic risk range by stating that when reasonable
maximum exposures for both current and future land use are less than 10"*, action is generally not
warranted.
The Baseline Risk Assessment reinforces the existence of a potential threat to public health,
welfare or the environment. Actual or threatened releases of hazardous substances from this site.
15
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if not addressed by implementing the response action selected in this ROD, may present an
imminent and substantial endangerment to public health, welfare, or the environment
E. Uncertainties
Understanding the uncertainty associated with these risk estimates is an important point that is
vital to their proper interpretation. A major source of uncertainty associated with this risk
assessment is the assumption of future residential use of groundwater from under the JLLF site.
The site is a former landfill. It is extremely unlikely that residences will be built on this site and
that a private well will be developed in the shallow groundwater beneath the landfill. Deed
restrictions are in place as a result of the ROD for OU1; thus groundwater use at the JLLF is not
a complete exposure, pathway. The risk analysis was performed to evaluate the potential for
exposure should deed restrictions fail at some time in the future.
There is also uncertainty in the risk estimates for tngestion of inorganic arsenic. A memorandum
from the U.S. EPA Administrator (as described in IRIS) counsels that "the uncertainties
associated with ingested inorganic arsenic are such that estimates could be modified downward
as much as an order of magnitude relative to the risk estimates associated with most other
carcinogens." Thus, risks associated with exposure to arsenic may be overestimated by an order
of magnitude, resulting in a risk estimate that is within the range of acceptable risks. In addition,
the 95% UCL concentration of arsenic (24.8 ug/L) does not exceed its MDNR Generic
Residential Groundwater Cleanup Objective (50 ug/L).
The site-wide average and maximum concentrations of beryllium (0.503 ug/L and 0.59 ug/L,
respectively) does not exceed its MDNR Generic Residential Groundwater Cleanup Objective (4
ug/L). The maximum concentration of 1,4-dichlorobenzene (5 ug/L) does not exceed its MDNR
Generic Residential Groundwater Cleanup Objective (50 ug/L) and the site-wide concentration of
bis(2-ethylhexyl)phthalate does not exceed its MDNR Generic Residential Groundwater Cleanup
Objective (6 ug/L).
Another source of uncertainty is the toxicity value used to evaluate iron. There is no U.S. EPA-
established toxicity value for iron. An EPA-NCEA Regional Support provisional value
presented in the U.S. EPA Region 3 Risk-Based Concentration table was used. The 95% UCL
concentration of iron (81,000 ug/L) exceeds the MDNR Generic Residential Groundwater
Cleanup Objective (300 ug/L) for this metal. It should be noted that the drinking water standard
for iron is based on organoleptic properties (e.g., taste, odor, color, and non-aesthetic effects),
rather than health effects. In addition, iron is known to naturally occur at elevated levels in this
area.
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F. Additional Studies
A Baseline Risk Assessment Addendum (BRAA) considered groundwater data from the four
rounds of monitoring well sampling and the analytical data from the GeoProbe sampling. This
information considers risk from a regional perspective to help U.S. EPA make risk management
decisions and provide additional information. The JLLF site is directly adjacent to Sandfill
Landfills No. 1 and No. 2 and the Kingston Development site, which is also used for landfilling.
Since "off site" areas directly adjacent to the JLLF are also landfills for which future land use is
not anticipated to change, this risk study provides information on risk downgradient of the
landfill areas for which future land use is not determined and is currently residential. "On-site"
includes groundwater from under the JLLF site, Sandfill Landfill #1 and #2 and the Kingston
Development. "Off site" includes groundwater downgradient of the waste management unit of
Sandfill #2. The following exposure pathways and receptors were identified and evaluated in the
BRAA:
• "On-site" Groundwater - Residential Exposure
1. Ingestion
2. Dermal Absorption
3. Inhalation of volatiles
• "On-site" Groundwater - Industrial Exposure
1. Ingestion
2. Dermal Absorption
3. Inhalation
• "Off-site" Groundwater - Residential Exposure
1. Ingestion
2. Dermal Absorption
3V Inhalation
1. "Oil-Site" Groundwater - Residential Exposure
The carcinogenic risks associated with "on-site" residential groundwater use range from 2E-04 to
6E-04. These risk levels exceed the 1E-06 point of departure for establishing remediation goals
and fall slightly above the generally acceptable range of 1E-06 to 1E-04 set by the NCP for
Superfund sites. The predominant contributors to the carcinogenic risks associated with on-site
residential groundwater use were benzene, which contributed over 99% to the inhalation risk and
also exceeded the point of departure for ingestion risk, and arsenic, which contributed over 99%
to the ingestion risk and over 65% to the dermal contact risk. Beryllium, 1,4-dichlorobenzene,
and heptachlor epoxide also exceed the point of departure for ingestion. The cancer risks
associated with the remaining contaminants of concern (COCs) were at acceptable levels.
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The noncarcinogenic effects associated with on-site residential groundwater use ranged form a
hazard index (HI) of 28 for an adult to 65 for a child. The HI greater than I only for arsenic,
thallium, and iron for ingestion. The non-carcinogenic risks associated with the remaining COCs
were at acceptable levels. There is also potential for adverse health effects due to exposure to
magnesium and sodium, which were detected at concentrations above MDEQ generic residential
groundwater cleanup criteria.
Deed restrictions are in place on the JLLF as a result of the ROD for OU1. Therefore,
groundwater use is not a complete exposure pathway. However, this risk analysis was performed
to evaluate the potential for exposure should deed restrictions fail.
2. "On-site" Groundwater - Industrial Exposure
The carcinogenic risks associated with industrial/commercial groundwater use range from 2E-OS
to 1E-04. These risk levels exceed the 1E-06 point of departure for establishing remediation
goals and fall slightly above the generally acceptable range of 1E-06 to 1E-04 set by the NCP for
Superfund sites. The predominant contributors to the carcinogenic risks associated with on-site
industrial/commercial groundwater use were benzene, which contributed over 99% to the
inhalation risk, and arsenic, which contributed over 99% to the ingestion risk. Beryllium also
exceeded the point of departure for ingestion. The cancer risks associated with the remaining
COCs were at acceptable levels.
The noncarcinogenic effects associated with on-site industrial/commercial groundwater use
ranged form an HI of 5 to 10. The HI was greater than lonly for ingestion of iron. The non-
carcinogenic risks associated with the remaining COCs were at acceptable levels. There is also a
potential for adverse health effects due to exposure to magnesium and sodium, which were
detected at concentrations above MDEQ generic residential groundwater cleanup criteria.
Deed restrictions are in place on the JLLF site as a result of the first ROD. Therefore,
groundwater use is not a complete exposure pathway. However, this risk analysis was perforn i
to evaluate the potential for exposure should deed restrictions fail.
3. "Off-site" Downgradient Groundwater - Residential Exposure
Cancer risks were not calculated for this scenario because the COCs in downgradient'
groundwater were not carcinogenic. The noncarcinogenic effects associated with off-site
residential groundwater use ranged from an HI of 0.6 for an adult to 1 for a child. The
noncarcinogenic risks associated with off-site residential groundwater use were at acceptable
levels, indicating that the risk from these constituents do not pose an unacceptable risk to human
health and the environment.
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X. RATIONALE FOR FURTHER ACTION
Based on the COCs, exposure pathways and receptors, and an acceptable constituent level or
range of levels (chemical-specific ARAR or risk-based) for each exposure pathway, the
following Remedial Action Objectives (RAOs) were developed for OU2 for the JLLF:
For Human Health
• Prevent ingestion, inhalation, and dermal contact of groundwater under the JLLF
site having COCs in excess of MDEQ generic industrial cleanup criteria
• Prevent ingestion, inhalation, and dermal contact of groundwater under the JLLF
site having a total excess cancer risk for COCs of greater than 1E-04
• Prevent ingestion of groundwater under the JLLF site having COCs in excess of
an HI greater than 1.0.
For Environmental Protection
• Prevent migration of contaminants beyond the compliance point that would result
in downgradient off-site groundwater having COCs in excess of MDEQ generic
residential cleanup criteria and groundwater/surface water interface values.
XI. DESCRIPTION OF ALTERNATIVES
In developing alternatives, general response actions and the process options retained to represent
the various technology types were combined to form alternatives for the site as a whole. The
basis for the development of the alternatives is to meet the RAOs as described in section I. In
addition, remedial alternatives were developed based on the expectation for groundwater
remediation as expressed within 40 CFR 300.430[a][iii][F]. Since it is not practical to return the
groundwater beneath the JLLF to a beneficial use, the alternatives were developed to prevent
further migration of the plume (monitoring and containment) and exposure to contaminated
groundwater (deed restrictions and alternate water supply), and to initiate additional risk
reduction activities (deed restrictions where the facility groundwater has migrated under the
Sandfill Landfill #2). In determining remedial objectives at this site, U.S. EPA also considered
its directive on "Land Use in the CERCLA Remedy Selection Process". This directive asks U.S.
EPA to look at what cleanup objectives would be most in line with the reasonably anticipated
future land use at the site. At this site, it is anticipated that the current landfill areas on or
adjacent to the site will continue to be used as an active or inactive landfill in the foreseeable
future. When waste is left in place, it is EPA policy that groundwater remediation levels should
19
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be attained at or beyond the edge of the waste management area (NCP Preamble page 8753 FR
Volume 55 #46).
Based on the retained technology types, process options and site and waste characteristics, the
following preliminary remedial alternatives were developed for OU2 for the JLLF:
1. Alternative 1—No Action
2. Alternative 2-Limited Action
3. Alternative 3—Containment and Dewatering
4. Alternative 4—Extraction and Treatment
Alternative 1 - No Action
The No Action alternative is required by the Superfund Amendments and Reauthorization Act
(SARA) to provide a baseline comparison with other alternatives. The No Action alternative
implies that no remedial action would be undertaken at the JLLF for OU2.
Capital Costs: $ 0
30 Years Operation and Maintenance (O&M) $ 0
Total Present Worth $ 0
Alternative 2 • Limited Action
This alternative would consist of the following components:
• Requirement to implement enforceable deed restrictions which restrict
groundwater use at that portion of the facility where contaminated groundwater
from JLLF has come to be located under the Sandfill Landfill #2, in addition to
the deed restriction currently in place on the JLLF property;
• Install three monitoring well nests, one upgradient and two downgradient, with
each nest consisting of a shallow and a deep well;
• Perform baseline quarterly groundwater monitoring and subsequent annual
groundwater monitoring of COCs at residential wells and at on-site and off-site
monitoring wells. As a contingency, if these downgradient wells indicate that
there is an unacceptable risk due to contamination from the JLLF site, provide
residences with an alternate water supply.
Capital Costs: $ 88,000
30 Years O&M $ 515,000
Total Present Worth $ 603,000
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Alternative 3 - Containment and Dewatering
This alternative would consist of the following components:
• Requirement to implement enforceable deed restrictions which restrict
groundwater use at that portion of the facility where contaminated groundwater
from JLLF has come to be located under the Sandfill Landfill #2, in addition to
the deed restriction currently in place on the JLLF property;
Install slurry wall around the JLLF property boundary to prevent upgradient
groundwater from coming into the site and to prevent groundwater below the
JLLF property from migrating downgradient;
Dewater leachate/groundwater in contact with the J&L landfill waste using an
extraction well to create an inward groundwater gradient within the containment
system;
Treat the extracted leachate/groundwater in an above-ground treatment system
and discharge the treated water to Ladd Drain in accordance with the National
Pollution Discharge Elimination System (NPDES) requirements;
Install one upgradient (west of Sandfill Landfill No.l) and two downgradient (east
of Sandfill Landfill No. 2) off-site monitoring well nests;
Perform baseline quarterly groundwater monitoring and subsequent annual
groundwater monitoring of COCs at residential wells and at on-site and off-site
monitoring wells. As a contingency, if these downgradient wells indicate that
there is an unacceptable risk due to contamination from the JLI " site, provide
residences with an alternate water supply.
Capital Costs: $ 5,681,000
30 Years O&M $ 1,725,000
Total Present Worth $ 7,406,000
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Alternative 4 - Extraction and Treatment
This alternative would consist of the following components:
• Requirement to implement enforceable deed restrictions which restrict
groundwater use at that portion of the facility where contaminated groundwater
from JLLF has come to be located under the Sandfill Landfill #2, in addition to
the deed restriction currently in place on the JLLF property;
Install extraction wells at the downgradient edge of the JLLF property boundary
to prevent groundwater below the JLLF property form migrating downgradient;
Treat the extracted leachate/groundwater in an above-ground treatment system
and discharge the treated water to Ladd Drain in accordance with the NPDES
requirements;
Install one upgradient (west of Sandfill Landfill No. 1) and two downgradient (east
of Sandfill Landfill No. 2) off-site monitoring well nests;
Perform baseline quarterly groundwater monitoring and subsequent annual
groundwater monitoring of COCs at residential wells and at on-site and off-site
monitoring wells. As a contingency, if these downgradient wells indicate that
there is an unacceptable risk due to contamination from the JLLF site, provide
residences with an alternate water supply.
Capital Costs: $ 1,222,000
30 Years O&M $ 2,190,000
Total Present Worth $ 3,412,000
XII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, the relative performance of each alternative is evaluated using the
nine criteria, as specified in 40 CFR 300.430(eX9Xiii). as a basis for comparison. An alternative
providing the best balance of considerations with respect to the nine criteria is determined from
this evaluation. The following discussion evaluates the remedial alternatives separately using
each of these nine criteria.
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A. Threshold Criteria
The following two criteria must be met in order for an alternative to be selected:
\
• Overall protection of human health and environment addresses whether a
remedy would provide adequate protection to human health and the environment
from exposure to contaminated soils and sediments, and describes how risks
posed through each pathway would be eliminated, reduced, or controlled under
each alternative. At the JLLF, the major exposure pathways of concern are from
ingestion, inhalation, and direct contact with the groundwater and contaminated
sediments and soils.
Alternative 1 does not provide protection of human health and the environment.
Alternative 2 provides protection to potential human receptors through groundwater use
restrictions, off-site institutional controls (State and local ordinances restricting groundwater
use), and periodic groundwater monitoring. Alternative 2 also relies on the remedy for OU1
(landfill cap) for reducing contaminant concentrations in groundwater.
Alternatives 3 and 4 also provide protection to potential human receptors through groundwater
use restriction, off-site institutional controls (State and local ordinances restricting groundwater
use), and periodic groundwater monitoring. Alternatives 3 and 4 reduce the downgradient
migration of contaminants from beneath the JLLF by creating a barrier. Alternative 3 uses a
vertical barrier (slurry wall) to reduce the amount of upgradient groundwater coming in contact
with the JLLF site waste and to reduce the downgradient flow of groundwater beneath the JLLF.
Alternative 4 uses a hydraulic barrier (extraction wells) to prevent the groundwater beneath the
JLLF from flowing downgradient of the JLLF property boundary. Additional benefit to overall-
protection of groundwater quality through vertical or hydraulic barriers for Alternatives 3 and 4,
respectively, is suspect because the surrounding landfills may continue to act as a source of
groundwater contamination and no remedial measures are being implemented for these arc u..
• Compliance with ARARs addresses the extent to which each alternative will
meet all of its federal and sate ARARs.
Alternatives 2,3, and 4 achieve compliance with all of the potential federal and state ARARs.
Alternative 1 is not in compliance with the Response Activities requirements in the Michigan
Natural Resources and Environmental Protection Code 1994 P.A. 451. Alternative 1 is also not
in compliance with federal groundwater monitoring and response requirements (40 CFR 264.94).
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Alternatives 1,2,3, and 4 achieve compliance with federal drinking water standards (40 CFR
Part 141 and 40 CFR Part 143) and Michigan groundwater cleanup criteria (Part 201 of State of
Michigan Natural Resources and Environmental Protection Code 1994 P.A. 451) at the point of
compliance.
B. Primary Balancing Criteria .
• Long-term effectiveness addresses the potential risks remaining at the site after
remedial action has been implemented. The following factors are considered in
the long-term effectiveness:
1. Magnitude of the residual risks remaining at the completion of remedial
activities;
2. Adequacy and long-term reliability of management and technical
controls for providing continued protection from the residual risks.
For the No Action alternative, the magnitude of residual risk would be equal to the present risk
and other factors do not apply.
For Alternatives 2,3, and 4, there is residual risk because the surrounding landfills may continue
to act as a source of groundwater contamination and no remedial measures are being
implemented for these landfills. However, concentrations of COCs detected in downgradient
groundwater (downgradient of Sandfill Landfill No. 2) did not exceed their respective cleanup
criteria, with the exception of regionally elevated inorganics (i.e. aluminum, sodium, iron, and
manganese). Alternative 2 components would remain in effect beyond 30 years and a five-year
review is recommended. Alternatives 3 and 4 are reliable but long-term operation and
maintenance and some replacement would be needed.
• Reduction of toxicity, mobility, and volui : through treatment evaluates
treatment technology performance in the reduction of chemical toxicity, mobility,
or volume. This preference is satisfied when treatment is used to reduce the
principal threats at a site through destruction of toxic contaminants, reduction of
total mass of toxic contaminants, irreversible reduction in contaminant mobility,
or reduction of total volume of contaminated media. The following '
considerations are applied to each alternative:
1. The treatment processes the remedy will employ, and the materials they will
treat;
2. The amount of hazardous materials that will be destroyed or treated, including
how the principal threat(s) will be addressed;
24
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3. The degree of expected reduction in toxicity, mobility, or volume measured as
a percentage of reduction (or order of magnitude);
4. The degree to which treatment will be reversible;
5. The type and quantity of treatment residuals that will remain following
treatment;
6. Whether the alternative would satisfy the statutory preference for treatment
as a principal element.
Because the JLLF site is a land-based disposal unit and the shallow groundwater is in contact
with the waste, it is not technically practical to return the groundwater beneath the JLLF site to
the most beneficial use, but rather prevent contaminant migration beyond the compliance point.
In addition, even if it was attempted to achieve groundwater cleanup goals at the JLLF site
boundary, groundwater would then pass through the adjacent landfill contents and would most
likely become recontaminated Therefore, treatment is only employed on the extracted
groundwater and is not a principal element of any of the proposed alternatives.
The No Action alternative does not use a treatment process.
Alternative 2 also, does not employ a treatment process.
The principal element of Alternative 3 is containment. Only groundwater extracted because of
dewatering and for creating an inward hydraulic gradient across the slurry wall would be treated
in an above-ground treatment system.
The principal element of Alternative 4 is extraction which results in both hydraulic containment
and treatment of extracted contaminated groundwater.
• Short-term effectiveness refers to the speed with which the remedy would
achieve protection, as well as the remedy's potential to create adverse impacts on
human health and the environment during the construction and implementation
period. The following considerations are applied to each alternative:
1. Protection of the community from any risk that results from implementation of
proposed remedial actions;
2. Protection of workers from any threats that may be posed during remedial
actions and the effectiveness and reliability of protective measures that would be
taken;
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3. Environmental impacts that may result from the implementation of an
alternative and a corresponding evaluation of available mitigation measures;
4. The time required to achieve RAOs.
This criterion does not apply for Alternative 1 because no remedial measures would be
implemented.
Alternative 2 poses minimal risk to the community, workers, and the environment during
implementation.
In Alternative 3, installation of the slurry wall would require trenching to approximately 50 feet
below ground surface (bgs) and mixing soil-bentonite slurry. Thus, in Alternative 3 there would
be an increase in noise, truck traffic, odor, and dust generation that would affect the community
and the workers. Conscientious construction and operating practices and appropriate health and
safety measures would significantly reduce any potential risks to the workers and the community.
Alternative 4 would also involve some increase in noise, truck traffic, and dust generation during
installation of extraction wells and associated piping, construction of a treatment building, and
installation of treatment equipment. Upon the implementation of the alternatives, the RAOs for
protecting human health would be achieved via use restriction, alternate water supplies, and off-
site institutional controls. RAOs for migration of constituents beyond the compliance point are
currently being achieved.
• Implementability is the technical and administrative feasibility of a remedy,
including the availability of materials and services required to implement the
remedy. This criterion involves analysis of the alternatives for the following
factors:
1. Ability to construct the technology and the reliability of its operation;
2. Ease of undertaking additional remediation, if necessary;
3. Ability to adequately monitor migration and exposure pathways;
4. Availability of services and materials;
5. Coordination between agencies.
This criterion does not apply to the No Action alternative because no remedial measures will be
implemented.
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Alternative 2 would be easy to implement and monitor. Future remedial actions can also be
easily implemented. Coordination from local agency and off-site property owners would be
needed for groundwater use restriction and off-site institutional controls.
Alternative 3 would require implementation of Alternative 2 components and installation of
slurry wall, an extraction well, and a treatment system. Special construction techniques would be
required to minimize the impacts to the OU1 cover system. An NPDES permit would be needed
for off-site discharge of treated groundwater.
Alternative 4 would require implementation of Alternative 2 components and installation of an
extraction and treatment system. Future remedial actions can be easily implemented. An
NPDES permit would be needed for off-site discharge of treated groundwater.
• Cost estimates for the alternative include operation and maintenance costs, as well
as present net worth. Total capital costs consist of the direct and indirect costs
required to initiate and implement a remedial action. Direct costs include costs
for construction, labor, and materials. Indirect costs consist of engineering,
"permitting", supervising, and other similar services. Construction contingencies
account for unknown costs. Unknown costs include a variety of factors that
would tend to increase costs associated with a given project scope, such as
bidding climate, adverse weather conditions, availability of materials, contractors'
uncertainty regarding liability and insurance, regulatory or policy changes that
may affect Feasibility Study assumptions, and geotechnical unknowns.
Contingencies do not include allowances for price inflation and unforeseeable
abnormal technical difficulties. The present worth cost represents the amount of
money that, if invested in the current year and disbursed as needed, would be
sufficient to cover all costs associated with the remedial action over its planned
life.
Cost estimates for the alternatives were prepared primarily by contacting potential materials
suppliers and other contractors. The costs were estimated from the information available at the
time of the estimate. Whenever possible, more than one supplier was contacted to estimate the
costs, therefore the costs will be within the desired range of accuracy of+50 to -30 percent.
Final costs will depend on actual labor and material costs, actual site conditions, market
conditions, final project scope, engineering between the feasibility study and final design, final
project schedule, productivity, and other variable factors. As a result, the final costs will vary
from the estimates presented in this report. However, most of these factors should not affect the
relative cost differences between the alternatives. In conducting the present worth analysis, a
discount rate of 7 percent and an operating life of 30 years was assumed.
The following lists the proposed costs for each of the alternatives (there is no associated cost for
Alternative 1 because no remedial measures will be implemented):
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Table XII-1
Estimated Costs for Proposed Alternatives
JLLF
Alternative
Alternative 2:Limited Action
Alternative 3:Containment and
Dewatering
Alternative 4 Extraction and Treatment
Total Capital
Cost($)
88,000
5,681,000
1,222,000
Present Worth of
O&M ($)
515,000
1,725,000
2,190,000
Total Present
Worth ($)
603,000
7,406,000
3,412,000
C. Modifying Criteria
State acceptance indicates whether, based on its review of the RI/FS and
Proposed Plan, the state of Michigan concurs with, opposes, or has no comment
on the preferred alternative.
The State of Michigan does not concur with the selected remedy.
Community acceptance refers to the public's opinion on the proposed action.
The community is provided with an opportunity to review the FFS and Proposed
Plan during the 30-day public comment period. During and after the public
comment period, U.S. EPA typically receives comments by mail and by
telephone. The public is also given the opportunity to express concerns and
comments during a public meeting which is usually held at the end of the 30-day
public comment period. Public concerns and comments are generally
incorporated during the preparation of the Responsiveness Summary and the
ROD.
A Responsiveness Summary has been prepared to address comments and concerns
raised by the public regarding the remedial alternatives. The Responsiveness
Summary is included as Attachment 2 of this Record of Decision.
XIII. THE SELECTED REMEDY
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Based upon considerations of the requirements of CERCLA, the NCP, and balancing of the nine
criteria, the U.S. EPA has determined that Alternative 2, Limited Action, is the most appropriate
remedy for the JLLF. The components of the selected remedy are described below.
• Requirement to implement enforceable deed restrictions which restrict
groundwater use at that portion of the facility where contaminated groundwater
from JLLF has come to be located under the Sandfill Landfill #2, in addition to
the deed restriction currently in place on the JLLF property;
• Install one upgradient (west of Sandfill Landfill No. 1) and two downgradient
(east of Sandfill Landfill No. 2) off-site monitoring well nests.
• Perform baseline quarterly groundwater monitoring and subsequent annual
groundwater monitoring of COCs at residential wells and at on-site and off-site
monitoring wells. As a contingency, if these downgradient wells indicate that
there is an unacceptable risk due to contamination from the JLLF site, provide
residences with an alternate water supply.
Because the JLLF site is a land-based disposal unit and the shallow groundwater is in contact
with the waste, it is not technically practical to return the groundwater to the most beneficial use.
Institutional controls that restrict groundwater use will provide an equivalent level of protection
from the contamination present in a more cost effective manner when compared to Alternatives 3
and 4. The community will not be impacted by any short term effects required to implement the
remedy. Long term monitoring with the contingency for alternate water will provide additional
protection should conditions change.
XIV. Implementation of the Contingency Plan
As stated in the description of alternatives (Section IX) should the monitoring results indicate an
unacceptable risk in groundwater contamination, an alternative water supply would be provided.
As regional groundwater shows a general elevation in inorganic substances such as Al, Fe, Mn,
and Na above MI 201 generic levels, a simple exceedance of said levels would not indicate a
need to provide alternative water. Rather background concentrations would be determined for
the region based on sampling and or existing data contained in the records of the Oakland county
health department for the residential sampling in the area. If monitoring data shows an increase
in inorganic levels through trend analysis above the regional background levels and these
inorganic constituents are also found in the monitoring wells on the JLLF site in comparable
levels, alternative water would then be provided to residents not currently hooked up to city
water.
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Trend analysis will be utilized to identify signs of ground water quality degradation in the aquifer
where private wells are installed. In addition, data from selected wells from the long term
monitoring of the landfill site as required per the ROD for operable unit 1 will be included to
further aid in the trend analysis. If trend analysis indicates that groundwater used for private
water supply is being adversely impacted by chemicals from the JLLF site, the contingency plan
will be invoked.
Currently, there are no organic accedences down gradient of the waste management units. The
trigger mechanism for organics would be similar to that for inorganics. If organics are detected
in off-site wells (wells beyond the waste management unit of Sandfill #2) for two successive
sampling events at half of their cleanup standard and these organic constituents are also found in
the monitoring wells on the JLLF site in comparable levels, alternative water would then be
provided to residents not currently hooked up to city water. Additionally, groundwaier use
restrictions would have to be implemented in the area of demonstrated impact.
XV. STATUTORY DETERMINATIONS
U.S. EPA's primary responsibility at Superfund sites is to undertake remedial actions that protect
human health and the environment. Section 121 of CERCLA has established several other
statutory requirements and preferences. These include the requirement that the selected remedy,
when completed, must comply with all applicable, relevant and appropriate requirements
("ARARs") imposed by Federal and State environmental laws, unless the invocation of a waiver
is justified. The selected remedy must also provide overall effectiveness appropriate to its costs,
and use permanent solutions and alternative treatment technologies, or resource recovery
technologies, to the maximum extent practicable. Finally, the statute establishes a preference for
remedies which employ treatment that significantly reduces the toxicity, mobility, or volume of
contaminants.
The selected remedy for the operable unit addressed by this ROD will satisfy the statutory
requirements established in Section 121 of CERCLA, as amended by SARA, to protect human
health and the environment, will comply with ARARs (or provide grounds for invoking a
waiver), will provide overall effectiveness appropriate to its costs, and will use permanent
solutions and alternative treatment technologies to the maximum extent practicable.
1. Protection of Human Health and the Environment
Implementation of the selected remedy will protect human health and the environment because:
(1) the contamination in the groundwater below the landfill does not currently affect human
health or sensitive environmental receptors; (2) the monitoring of the groundwater required by
the selected remedy will provide notice if any contamination in groundwater attributable to the
landfill should pose a threat to human health and the environment in the future, hi which case
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the selected remedy would require provision of an alternative water supply to potentially affected
users of groundwater; and (3) institutional controls provide an additional measure of protection.
No unacceptable short term risks will be caused by implementation of the remedy.
'2. Compliance with ARARs
The selected remedy will comply with all identified applicable or relevant and appropriate
federal requirements and with those State or local requirements that are more stringent, unless a
waiver is invoked pursuant to Section 121(dX4) of CERCLA. The Federal and State ARARs are
identified and discussed below.
Federal ARAR s
Chemical-Specific Requirements
Chemical-specific ARARs regulate the release to the environment of specific substances having
certain chemical characteristics. Chemical-specific ARARs typically determine the standard for
cleanup. Chemical-specific ARARs for the groundwater operable unit remedy selected herein
are'discussed and specified below.
Resource Conservation and Recovery Act (RCRA^
The waste at this facility was landfilled prior to November 19,19SO; therefore, the RCRA statute
and its implementing regulations are not applicable; however, because the waste disposed was
similar in chemical composition to waste currently listed as hazardous under RCRA, certain
RCRA standards are relevant and appropriate for purposes of remedy selection.
The chemical-specific requirements of RCRA are relevant. RCRA groundwater protection
standards are codified at 264.94. That regulation establishes the concentration levels which must
be met for contaminants of concern in site ground water.
The water table at this site is high, and the waste sits in water. Since institutional controls are
already in place, including deed restrictions forbidding consumptive use of groundwater a. the
site sufficient to assure that groundwater beneath the site will not pose a threat to human health
and
the environment, the standards referred to above are not appropriate as far as the
groundwater/leacriate in which the waste sits and will not compel a cleanup of the groundwater
in and under the landfill.
Although the contamination found in groundwater beneath the site has not shown evidence of
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migration, nevertheless, such potential for migration may still exist, and such migration could
pose a threat to human health and the environment as drinking water wells and the Clinton River
lie downgradient from the site. Therefore, the standards set forth at 40 CFR 264.94 are both
relevant and appropriate for groundwater downgradient from the facility and will, therefore, be
met at the downgradient boundary of the adjoining landfill, Sandfill Number 2 (i.e., Dequindre
Road).
The RCRA standards set forth at 40 CFR Part 261 for Identification and Listing of Hazardous
Waste are also relevant and appropriate and will be met.
Safe Drinking Water Act
40 CFR 141
Federal Drinking Water Standards promulgated under the Safe Drinking Water Act ("SDWA")
include both Maximum Contaminant Levels ("MCLs") and, to a certain extent, non-zero
Maximum Contaminant Level Goals ("MCLGs"), that are applicable to municipal drinking water
supplies servicing 25 or more people. At the JLLF Site, MCLs and MCLGs are not applicable,
but are relevant, because the unconfined aquifer below the site is a Class II aquifer which has
been used in the past for drinking water by residents downgradient from the site, and could
potentially be used as a drinking water source.
The National Contingency Plan ("NCP") at 40 CFR 300.430 (e)(2XIXB) provides that MCLGs
established under the Safe Drinking Water Act that are set at levels above zero shall be attained
by remedial actions for ground waters that are current or potential sources of drinking water.
Groundwater monitoring wells will be installed and monitored around the J&L Landfill to
ensure that contribution from the landfill to groundwater contamination beyond the landfill
boundaries does not present a threat to human health and the environment. Existing groundwater
wells in th<- aquifer will also be monitored, and additional wells may also be drilled and
monitored, if necessary to ensure compliance.
The SDWA standards cited above are considered relevant, but not appropriate as far as
groundwater directly underlying the J&L Landfill and the adjacent landfills are concerned.
Institutional controls should prevent consumptive use of groundwater and leachate directly below
the landfills. However, these same standards are both relevant and appropriate for the
downgradient groundwater, therefore, the remedy requires continued monitoring and requires a
contingent provision of an alternative water supply to downgradient users of groundwater if the
monitoring standards are not met. The SDWA standards cited above will be met at the
downgradient boundary of the adjoining landfill, Sandfill Number 2 (i.e., Dequindre Road).
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Location-Specific Requirements
Location-specific ARARs are those requirements that derive from the physical nature of the
site's location and features of the local geology and hydrogeology such as wetlands and
floodplains.
The physical nature of the site's location does not appear to implicate any additional ARARs for
this selected remedy beyond those already identified above and below as specific to the chemical
composition of the hazardous substances addressed and those specific to the action required by
the selected remedy.
Action-Specific Requirements
The selected remedy for the groundwater operable unit identified in this ROD provides for
implementation of institutional controls, and additional monitoring of groundwater. The ROD
also provides for provision of an alternative water supply as a remedial action to be implemented
as a contingent measure if at some point in time the groundwater being monitored exceeds the
levels specified elsewhere herein as a trigger for this contingency. Action specific ARARs are
discussed and specified below.
Federal ARARs
Occupational Safety and Health Act
29 CFR 1910,1926 and 1904
Resource Conservation and Recovery Act ("RCRA"1
As the Record of Decision for the first operable unit indicated, contamination present in soils on
t "^ site will remain in place and the facility is still subject to requirements for closure of a
landfill. The requirements considered both relevant and appropriate in this area include, but are
not necessarily limited to:
40 CFR 264.117-120
These regulations require 30-year post-closure care and groundwater monitoring.
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Post-Closure Care
40CFR264.117(a)
The requirements for post-closure care are set forth at 40 CFR 264.117 through 40 CFR 264.120.
The Regional Administrator may revise the length of the post-closure care period pursuant to 40
CFR 264.117(aX2)(I) if he finds that a reduced period is sufficient to protect human health and
the environment; or extend the length of the post-closure care period pursuant to 40 CFR
264.117(aX2)(ii) if he finds that the extended period is necessary to protect human health and the
environment.
40 CFR 264.117©
The remedy selected for this site requires U.S. EPA to restrict post-closure use of this property as
necessary to prevent damage to the cover systems.
The standards cited above are relevant and appropriate and will be met. As indicated earlier 40
CFR 264.94 and 40 CFR Part 261 are also relevant and appropriate and will be met by the
selected remedy.
MICHIGAN ARARS
The selected remedy (Alternative 2) involves remediation activities and will comply with
Michigan Act 451 Part 201 (Environmental Response).
3. Cost Effectiveness
Cost effectiveness compares the effectiveness of an alternative in achieving environmental
benefit in proportion to the cost required to achieve that benefit. The FS discusses the costs of
me alternatives considered, and a comparison of those costs is presented in the section of this
ROD summarizing the analysis of the relevant criterion, above.
The selected remedy for this operable unit action is cost effective because it provides the greatest
overall effectiveness proportionate to the cost when compared to the other alternatives evaluated,
the net present worth cost of the selected remedy being estimated at $603,000.
4. Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource recovery to the Maximum Extent Practicable
The selected remedy represents the maximum extent to which permanent solutions and treatment
technologies can be used in a cost-effective manner at this site. Of those alternatives that are
protective of human health and the environment and that comply with ARARs, U.S. EPA has
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determined that the selected remedy provides the best balance in terms of long term effectiveness
and permanence, reduction of toxicity, mobility, or volume of contaminants, short term
effectiveness, implementability, and cost, taking into consideration State and community
acceptance.
5. Preference for Treatment as a Principal Element
The statutory preference for selection of remedial actions in which treatment is a principal
element cannot be satisfied by this decision; however, EPA believes that the selected remedy will
satisfy the statutory requirements specified in Section 121 of SARA to protect human health and
the environment, attain ARARs (or provide grounds for invoking a waiver) and utilize permanent
solutions to the maximum extent practicable.
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ATTACHMENT 2
RESPONSIVENESS SUMMARY
J&L Landfill Site
Rochester Hills, Michigan
The U.S. Environmental Protection Agency (U.S. EPA) has gathered information on the types
and extent of contamination found, has evaluated remedial measures, and has recommended
remedial actions to address the contamination found at the Jones and Laughlin Landfill (JLLF)
Site, located in Rochester Hills, Oakland County, Michigan. As part of the remedial action
process, a public meeting was held at the Rochester Hills City Hall on August 26, 1997, and was
attended by about 20 people. The purpose of the meeting was to explain the intent of the project,
to describe the results of the Feasibility Study (FS), and to receive comments from the public. A
court reporter was present to record the proceedings of the public meeting. A copy of the
transcript is included in the Administrative Record.
Public participation in superfund projects is required by the Superfund Amendments and
Reauthorization Act of 1986 (SARA). Comments received from the public are considered in the
selections of the remedial action for the site. The responsiveness Summary serves two purposes:
To provide the U.S. EPA with information about the community preferences and concerns
regarding the remedial alternatives and to show members of the community how their comments
are incorporated into the decision-making process. Comments not directly related to the
selection of the remedial alternatives have not been addressed within this Responsiveness
Summary, which includes all comments relating to operable unit two.
Comment #1:
There was concern expressed about a body of water located 500 yards to the South of JLLF: as
to whether or not there was contamination present, and as to whether or not this lake could be
included in the monitoring plan. There was also concern that groundwater levels and lake water
levels may be affected by the cap.
Response #1:
Although this body of water is close to the JLLF site, it is not considered down gradient as the RI
report has indicated that the flow direction is to the East and Northeast. Additionally the
southern monitoring well located on the JLLF site shows .the presence of only 3 Volatile organic
compounds and these are only present at levels below the MDEQ standards. The same well
shows the presence of inorganics, aluminum, manganese and iron, above MDEQ standards, but
these levels are comparable to samples taken up gradient from the JLLF site, indicating that the
JLLF site is not the sole source of these inorganics. In light of these facts, if any contamination
were reaching this body of water, it would have to come from a source other than the JLLF site
which would be outside of the scope of this response action. It is also very likely that the
subdivision development that was mentioned is having a greater affect on lake water levels and
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lake water quality especially if dewatering discharge is flowing into the lake. If that is the case,
the permitting authority should be made aware of the change in water quality.
If the southern wells that will be included in the long term monitoring plan for the JLLF site
indicate a change in conditions in groundwater leaving the site, EPA would evaluate additions to
the monitoring program. Based on EPA's experience, the cap placed on JLLF site would not
have such a significant effect on groundwater levels as to affect lake elevations. However in
light of this comment, EPA will take water level measurements in the monitoring wells for
comparison with data gathered before the final cover was placed on the JLLF site.
Comment #2:
Residents want to be informed of construction activities and their impact and duration.
Response #2
EPA will coordinate with local government and other interested parties to go over details such as
traffic routes and other expected impacts from construction of the additional well nests required
by the selected remedy as well as a schedule for such construction.
Comment #3
The local government is opposed to the use of local ordinances and institutional controls because
they could not be enforced. The commenter suggests the purchase of the lands affected by the
restrictions.
Response #3
EPA does not see a need to restrict groundwater use across Dequinder road unless groundwater
quality deteriorates. The groundwater up gradient shows certain inorganic constituents at
comparable levels, which means that they may not be coming from the JLLF site. The risk
assessment completed in July of 97 indicates that inorganics do not have a Hazard Index greater
than 1.0. This number means that there is no unacceptable health risk from inorganics. Should
conditions deteriorate, an alternate water supply, most likely a hook up to city water, would be
provided to those residents affected.
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Comment #4
A concern was raised on what effects deed restrictions may have on future land development
since the current zoning was residential.
Response #4
EPA inquired of the zoning office in Rochester Hills and was informed that the property due
West of Dequindre road is zoned light industrial. Regardless, the deed restrictions that are
contemplated here would only affect the use of groundwater for potable purposes. The land
would still have redevelopment potential as a park or for any other use that would not present a
risk from groundwater ingestion.
Comment #5
There was concern expressed about the contribution of site contaminants to surface water bodies.
Additionally, the overall problem created by the large number of landfills in the area should be
addressed. It doesn't make sense to address the problem piece-meal.
Response #5
Potential contamination contribution to surface water bodies can be evaluated in the monitoring
program. Should sampling data indicate that site related contamination is causing an impact off-
site, the monitoring scope would be increased to determine how far the problem extends. The
data that EPA possesses at this time shows no impacts of volatiles outside of the waste
management units. The inorganics that have been detected above their standards are found at
comparable levels up gradient and adjacent to the site which indicate a source from other
locations.
EPA agrees that regional groundwater has been impacted by many sources across a substantial
portion of the local area. There are approximately 19 landfills within a 6 mile radius. Some of
these sites are NPL sites, some are not. Under CERCLA, a site is not eligible for Superfund
monies unless it is on the NPL. In order for a site to be placed on the NPL, it must go through a
scoring process and receive a score high enough to place it on the list. This scoring system is set
up so those sites presenting the greatest potential threats in the nation get on the list and are
addressed under CERCLA. Additionally, for a site on the list, EPA can require response actions
for actual or potential releases from a site. However, in this instance, for certain specific
inorganic contaminants, like Iron, Aluminum, Manganese and Sodium, it cannot be determined
that a release is emanating from the site since the data on water quality entering the site is
comparable to water exiting the site indicating that another source or sources may be contributing
adversely to groundwater quality. In addition, it is not practicable to restore groundwater to
beneficial use under Sandfill #2 since waste is in the water table. The risk assessment performed
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in 1997 does not show a health risk beyond the waste management unit boundary (/. e., the
Eastern boundary of Sandfill Landfill #2). The groundwater under Sandfill #2 has been
contaminated by hazardous substances migrating from JLLF; therefore, this ROD requires the
PRP at JLLF, LTV Steel Company, to impose deed restrictions at Sandfill #2.
Many of the landfills in the area are not NPL sites. However, just because a site does not fall
under CERCLA jurisdiction, other authorities are not precluded from taking action. Given the
elevated inorganics in the local area and the concern of the local community, EPA would
encourage MDEQ to either evaluate the local area for listing, or pursue addressing the non-NPL
sites under separate State authority.
Comment #6
Commenter indicated support for EPA's recommended alternative
Response #6
EPA thanks the commenter for their support.
Comment #7
The groundwater analytical data presented by the U.S. EPA indicates the groundwater
contamination is an area-wide problem caused by multiple landfills. Therefore, the U.S. EPA
should be identifying potentially responsible parties (PRPs) other than LTV Steel for adjacent
landfill sites. LTV Steel has installed monitoring wells and has a draft Operation and
Maintenance (O&M) plan that defines a groundwater monitoring program in accordance with the
landfill (Operable unit 1) remedy. The data that will be acquired by LTV steel as part of the
O&M of the site is all the data necessary to evaluate the potential environmental impact of the
JLLF. Data concerning off-site properties should be acquired by PRPs for the individual
properties.
Response #7
Data from monitoring wells located on the down gradient side of the JLLF indicate exceedances
of State and Federal Standards. Exceedances found in the ground water under Sandfill #2,
immediately adjacent to and directly downgradient from the JLLF site, indicate that CERCLA
hazardous substances from the JLLF site have come to be located in the groundwater under
Sandfill n 2; therefore, EPA has determined that the JLLF "facility," as that term is defined by
CERCLA, includes the groundwater under Sandfill #2. Therefore, it is necessary to monitor
down gradient to ensure that the contaminants found in these wells do not migrate further and
adversely affect groundwater quality which may pose an unacceptable risk to human health and
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the environment. EPA agrees that the monitoring wells sampled as part of the O&M plan will
play an important role in determining the state of groundwater contamination. These wells, plus
those envisioned as part of this second operable unit ROD, will enable us to detect any further
adverse change in groundwater conditions. See also Response #5.
Comment #8 ,
It is premature to commit to a 30 year groundwater monitoring program with the current data. A
more thorough evaluation and determination of the source or sources of any groundwater impacts
is necessary prior to developing a Proposed Plan and Record of Decision. Groundwater
analytical data from monitoring wells located off-site, up gradient and down gradient should be
obtained along with the data to be obtained by LTV Steel at JLLF to provide the data for the
evaluation. Several rounds of sampling and analyses would be required to provide the level of
confidence necessary to clearly identify the sources of impacts. U.S. EPA has previously
reached RODs that call for a period of time, less than 30 years, of groundwater monitoring
followed by an evaluation to decide on any additional remedial action for another site in
Michigan. It is suggested that a period of one to three years of periodic sampling and analysis be
conducted to develop the data to complete the evaluation. PRPs, not LTV Steel, should be
responsible for data collection from sites beyond the boundaries of the JLLF site.
Response #8
EPA has enough information to reach a decision with regard to the groundwater operable unit
(OU2). The Superfund Amendments and Reauthorization Act (SARA) calls for periodic or 5
year reviews of any remedy where hazardous substances remain on site, as is the case with the
JLLF. Data from the monitoring wells proposed in this ROD plus the O&M data will allow EPA
to evaluate the groundwater, and if necessary following careful evaluation of the data, amend the
monitoring program. This ROD plus the 5 year review will address the concerns noted in this
comment. Response #7 explains why LTV Steel . ompany is responsible for monitoring beyond
the boundaries of the landfill property it owns.
Comment #9
It is premature to commit to sampling and analysis of residential wells given the current data.
Groundwater data does not indicate impacts down gradient of Sandfill Landfill #2 that exceed
residential criteria. The decision whether to include residential well monitoring could be made
after identifying the groundwater transport mechanisms and contaminant levels after an
evaluation of the additional groundwater monitoring data described above.
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Response #9
As stated in response #7, the exceedance of state and federal standards require us to monitor
down gradient groundwater (i.e. residential users) in order to ensure that there is no unacceptable
risk from drinking the groundwater related to the JLLF site. EPA has sufficient information on
fate and transport from the RI report to determine the transport mechanisms of the groundwater.
As stated in response #8, the five year review will allow us to evaluate the data and make
changes to the monitoring program, if any such changes appear to be appropriate.
Comment #10
The commenter does not agree with the proposed remedy. The commenter has also referenced
transcript page:, from the July 9, 1994 public meeting concerning EPA's summary of
groundwater contamination and risk from the contaminants as well as his comments
concerning contaminated groundwater migrating off the JLLF property.
Response #10
As indicated in the response to Comment #3, there is no unacceptable risk downgradient of
Dequindre Road based on the July 1997 risk assessment. Although the JLLF site may be a
source of groundwater contamination and there is an unacceptable risk to users of the
groundwater beneath the JLLF site, there is no data to indicate that site-related constituents are
migrating across Dequindre Road toward the residential wells. The only constituents
(aluminum, iron, manganese, and sodium) detected above MDEQ standards across Dequindre
Road in the Geoprobe samples or the residential wells were also upgradient of the landfills at
similar concentrations.
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ATTACHMENT #3
ADMINISTRATIVE RECORD INDEX
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U.S. ENVIRONMENTAL * PROTECTION. AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
J&L LANDFILL SITE
ROCHESTER HILLS, MICHIGAN
UPDATE *9
SEPTEMBER 25, 1997
NO. DATE
1 08/26/97
2 09/00/97
3 09/15/97
AUTHOR
Ham! Iton-
Legato
Deposition
Centers
U.S. EPA
Kerwaby, C.,
MDSQ
RKCIPIBMT
U.S. EPA
File
Carney, w.,
U.S. EPA
4 09/17/97
Billock, T. U.S. EPA
and H. Billock
5 09/17/97
6 09/26/97
Nagel, K.,
LTV Steel
Company
Carney, W.,
U.S. EPA
U.S. EPA
Kerwaby, C.,
MDEQ
7 00/00/00
8 00/00/00
Muno, W.B.,
U.S. EPA
Muno, W.E.,
FILE
TITI.H/DESCRIPTION PAGES
Transcript of August 26, 53
1997 U.S. EPA Public
Meeting res the J&L
Landfill Site
Addendum to the Final 1
Focused Feasibility
Study for the J6L Land-
fill Site
Letter re: MDBQ's 14
Contents on the Proposed
Plan and the Final
Focused Feasibility Study
for the J&L Landfill Site
Public Consent Sheet re: 2
Citizens' Comments on
U.S. EPA's Recommended
Alternative Cleanup
Method for Contamination
at the J&L Landfill Site
Letter ret LTV Steal's 3
Comments on the Proposed
Plan for the J&L Landfill
Site
Letter re: U.S. EPA's 18
Response to MDBQ's
Comments on the Proposed
Plan and Final Focused
Feasibility Study for
the J&L Landfill Site
J6L Landfill Record of
Decision for
Operable unit two. Compliance
with Michigan Act 451, part
201
PENDING
J&L Landfill Record of
Decision for Operable unit two
PENDING
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-------
U.S. EPA ADMINISTRATIVE RECORD
J & L LANDFILL SITE
ROCHESTER HILLS, MICHIGAN
UPDATE #2-
01/12/94
DOCI DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
rrsr ssss :===== ssacszssz sssssssssssssssss sssss
1 12/30/91 Babusukuur, S., Roy U.S. EPA Remedial Investigation, VoluM 1 417
F. Heston, Inc.
2 12/30/91 Babusukumar, S., Roy U.S. EPA Remedial Investigation, VoluM 2 262
F. Heston, Inc.
3 01/23/92 Hart in, N., U.S. EPA Szuhay, L., LTV Cover Letter for the Final Remedial 1
Steel Company Investigation
4 03/05/92 O'Brien, B., NDNR Nartin, N., U.S. EPA Letter re: U.S. EPfr's Involvement M/the 4
Focused Feasibility Study and NDNR's
Potential ARARs
S 04/09/92 Noodmrd-Clyde U.S. EPA Hoodnard-Clyde's Revien and CoMents on the - 14
Consultants Reiedial Investigation
6 06/26/92 Szuhay, L., LTV Martin, «., U.S. EPA Final Focused Feasibility Study -/Cover 108
Steel Company Letter
7 OB/10/92 Graan, T. and Nartin, «., U.S. EPA Heston's Review of Hoodnard l/
Babusukuiar, S., Roy Clyde Comments on the Risk Assessment
F. Heston, Inc.
8 00/00/93 Boschuk, J., et al. Journal Article: 'Gusto* Beocotposite for 15
Superfund Closure Cap-A Case Study*
9 09/00/93 U.S. EPA U.S. EPA Guidance: 'Presumptive Remedies: Policy and 8
Procedures,' OSNER Directive I93SS.O-47FS
10 09/00/93 U.S. EPA U.S. EPA Guidance: 'Presumptive Remedy for CERCLA 14
Municipal Landfill Sites,' OSHER Directive
•9355.0-49FS
11 09/24/93 Heller, 0., U.S. EPA Evans, L., U.S. EPA RCRA's Revien of the Landfill Cap 1
Alternatives for Equivalency to Recommended
RCRA Cap as ARARs
12 10/14/93 Vanderpool, L., U.S. Evans, L., U.S.. EPA Technical Support Section's Review of THO 3
EPA Additional Landfill Cap Alternatives
13 11/02/93 Fabinski, L., ATSDR Evans, L., U.S. EPA Public Health Assessment a/Cover'Letter 52
-------
U.S. EPA ADMINISTRATIVE RECORD IP
J & L LANDFILL SITE
ROCHESTER HILLS, MICHIGAN
UPDATE #3.
02/08/94
DOCI DATE AUTHOR .. RECIPIENT TITLE/DESCRIPTION PP3ES
1 01/14/94 Roy F. Heston, Inc. U.S. EPA Focused Feasibility Study 161
-------
U.S. EPA ADMINISTRATIVE RECORD
J 8t L LANDFILL SITE
ROCHESTER HILLS, MICHIGAN
UPDATE #4
03/21/94
DCC« DOTE AUTHOR RECIPIENT TITLE,'DESCRIPTION PASES
1 02/27/90 Larsen, D., NDNR Hartin, R., U.S. EPA Letter re: Confirmation af January 2, 1990 2
Telephone Conversation Concerning NDNR's
Approval of Nork Plan
2 08/08/90 Kar'in, KM U.S. EPA O'Brien, B., HDNR Letter re: Notiifications Discussed Curing 3
August B, 1990 Confernece Call Concerning the
Hork Plan
3 08/09/90 O'Brien, B., HDNR Hartin, N., U.S. EPA Letter: Conclusions Reached at the August 8, 6
1990 Conference Call Concerning HDNR's
Concerns and Recoiiendations re: Proposed
Revisions to RI Activities
4 01/07/91 FUga, C., NDNR O'Brien, B., NDNR Henrandui: Special Services' Review of the 5
RI Report
5 07/30/91 Taszreak, R., HDNR O'Brien, B., flDNR Ifemrandui: Air Quality Division's Cowents 1
on the Draft RI
6 08/12/91 Siions, 6., HDNR O'Brien, B., HDNR Hewrarvdui: Environmental Response Division's 2
Review of the Draft RI Report
7 08/13/91 Sraff, C., HDNR O'Brien, B., HDNR Netorandui: Geological Services' Review af 4
the Draft RI Report
S 08/21/91 3'Brien, B., HDHR Hartin, ?•., U.S. EPA Letter re: HDNR's Review of the Draft RI 9
Report (UNSIGNED)
9 03/05/92 O'Brien, B. *DNR Hartin, H., U.S. EPA Letter re: U.S. EPA's Interest in Pursuing a 4
Focused Feasibility Study n/Attachients
10 06/10/92 Siuns, 6., «DW O'Brien, B., HOUR Reurandui: Special Services' Review of the 3
Draft FFS
11 06/17/92 Taszreak, R., NDNR 3'Brien, B., HDNR Heiorantiui: Air Quality Division's Cocierts 1
on the FPS
12 ?:/:;,• 92 O'Brien, P., fllSR lartin, H., U.S. EPA Letter re: ISWs Pevie« of ^he Draft ?FS
13 06/25/92 Delaney, R., PDNR O'Brien, B., RONR Nenrandua: Seological Services' RfvieN of 2
the Draft FFS
1* 07/09/"2 1ontgo«ry, 3., HSHR O'Brien, B., HDNR Heaorandui: Permits Section's Review =f the 2
Draft CFS
-------
lOCI DATE AUTHOR RECIPIENT TITLE/OESMIPTIDM . PflBES
15 07/22/92 Delaney, R., J1DNR O'Brien, B., 1DNR Hemorindue: Geological Services' Revieii of 1
the Proposed plan for Operable Unit II
15 07/24/92 Bradford, U., HDHR «ayka, J., U.S. EPA Letter re: Discussion of Proposed Cap B
a/Attachment
'J 08/25/92 Krajcovic, 5., KDNR O'Brien-, B., HDNR Hemorandum re: June IS, 1992 Site Inspection 1
for Hetland Determination
13 09/10/92 Hayka, J., U.S. EPA Bradford, N., NDNR Letter re: Request for NDNR's Position on the 1
Proposed Plan
19 09/29/92 Burda, K., NDNR Bradford, «., KDNR Hemorandum re: Request to Evaluate ARARs and 24
Cap -Design Clarification a/Attachments
20 10/14/92 Bradford, H., HDNR Hayka, J., U.S. EPA Letter re: NDNR's Determination that Michigan 2
Act 64 and RCRA are ARARs
21 10/26/92 Hayka, J., U.S. EPA Bradford, H., NDNR Letter re: Legal Application of RCRA or 2
Michigan Act 64 to Past Disposal Activities
22 09/21/93 Natour, T., HDNR flontgoiery, D., NDNR Heiorandm re: Evaluation of Cap Design 28
Alternative
23 11/12/93 Naaour, T., HDNR O'Brien, B., HDNR Heaorandui re: Foil on Up on the Evaluation of 1
Cap Design Alternatives
I* :'!/17/« 'j,S. EFA Public announcement Df February 9, 1994 'ublic 1
Meeting (Oakland Press; Pontiac, nil
25 01/18/9^ O'Brien, B., HDNR File Hetorandui re: Michigan Act &41, Solid Haste
Cap Requirements for a Pre Existing Facility
Hithcut a Bottom Liner
26 31/31 :94 Evans, L., li.5. EPA Fil Reiorardm re: Correction/Clarification tc
January 18, 1994 *DNR Interoffice r-etorandum
17 02/14/94 3'Srien, B., flDNR Evans, L., U.S. EPA Letter Fonrarding January 4, 1994 HDNR
Hemorandum re: Sandhill Landfills II and 42
•/Attachments
-------
U.S. EPA ADMINISTRATIVE RECORD
J ft L LANDFILL SITE
ROCHESTER HILLS, MICHIGAN
UPDATE "4*5 •
OS/2O/94
DOCI L'ATE fiUTHCR RECIPIENT WiE/DESCRlPTlOU PASES
Johnson, P., Oakland U.S. EPA Transcript of February °, 1994 Public Meeting
Court Reporters,
Inc.
-------
DOC* DATE AUTHOR
U.S. EPA ADMINISTRATIVE RECORD
J & L LANDFILL SITE
ROCHESTER HILLS. MICHIGAN
UPDATE *6
07/19/94
RECIPIENT
TITLE/DESCRIPTION
PAGES
1 09/00/90 USHER: U.S. EPA U.S. EPA
Quiet Reference Fact Sheet: 'Streamlinino the
RI/FS for CERCLA Nunicioal Landfill Sites'
'•OSHER Directive I9355.3-11FS1
2 10/26/90 Truchan. J.. ERD: ERD: HDNR
NONR
3 05/10/91 Keller. J.. RERB: RERB: U.S. EPA
U.S. EPA
4 12/00/91 Daniel. D. and
Koerner. R.
5 05/26/92 U.S. EPA
U.S. EPA
6 09/00/93 QSHER. U.S. EPA U.S. EPA
•Verification of Soil Remediation' (Draft). 1?
•/ftemorandum
Kemorandum re: Future Residential Land Use 2
Ground Hater Exoosure Point Concentrations
for the Baseline Risk Assessment
Journal Article: 'Landfill Liners fro§ TOD to
Bottoi* (Civil Engineering)
Memorandum: 'Iioieientinq the Deoutr
Administrator's Risk Characterization
Memorandum*
Quick Reference Fact Sheet: 'Presumotive
Remedies: Policy and Procedures" fOSHER
Directive I9355.0-47FS: EPA 540-F-93-047)
19
11
7 09/00/93 OSHER: U.S. EPA U.S. EPA
B 09/00/93 OSHER: U.S. EPA U.S. EPA
Quick Reference Fact Sheet: 'Presumptive
Remedies: Site Characterization and
Technoloov Selection for CERCLA Sites with
Volatile Oraanic Csmoounds in Sails' (QSMER
Directive 19355.0-4BFS: EPA 540-F-93-048I
Quick Reference Fact Sheet: •• resumptive
Pemei" for C€°CL4 Nunnioal Landfill Sites'
(OSki.- Directive I9355.0-49FS: EPA
540-F-93-0351
14
9 ^9/23/93 Howard. A.. ERD: ERD: HOUR
HDMR
10 00/00/94 Evans. L.. U.S. EPA File
11 00/00/94 Green. J.. Oakland
Press
Ooerational Memorandum 114: Generic Remedial
Action Plans Usinq Industrial Site Risk
Assessment Cleanuo Criteria: Other
Reouirements for Type C Remedial Action Plans
Demorandum re: Corrections to the Court
Record for the Public Heetino Held on
February 9. 1994
NeHSoaoer Article: 'EPA's Cleanuo Plan for
Landfill Doesn't Please Neighbors'
-------
DOC* DATE AUTHOR RECIPIENT !ITLE.;OESCR1PT!3N PAGES
12 02/00/94 Various U.S. EPS Public Coieents on the Prooosed Plan 22
13 02/03.'«4 Green. J.. OaHand Nenscacer article: 'EPA Outlines Cleanuo !
Press Ootions*
14 92/Q9'°4 U.S. EPA Putlic Ao?r.da
-------
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U.S. EPA ADMINISTRATIVE RECORD
J «< L LANDFILL SITE
ROCHESTER HILLS. MICHIGAN
UPDATE 4*7
08/< 3/94
CD:* C*TE
07/:?/« Vjletkevitch. H.. 'Rjsisiert;
U.S. £Pfl
al Letter "e: il) Clsanuo Plan
a'ian: (2; srjundwter
rG»tiar-: and '35 PRP Negotiations
-------
0.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
J&L LANDFILL SITE
ROCHESTER HILLS. MICHIGAN
HO. DATE
1 . 02/10/95
2 05/15/95
3 06/30/95
4 08/15/95
S 09/30/96
6 01/31/97
7 04/04/97
AUTHOR
OPDATB ft8
AUGUST 12, 1997
RECIPIENT
Babusukumar, S., Evans, L.,
Roy F. Weston, U.S. EPA
Inc.
Babusukumar, S., Evans, L.,
Roy F. Weston, U.S. EPA
Inc.
U.S. EPA/
OSWER
U.S. EPA
Babusukumar, S., Evans, L.,
Roy F. Weston, U.S. EPA
Inc.
Kinsall, G. and Evans. L.,
S. Babusukumar; U.S. EPA
Roy F. Weston,
Inc.
Bosko, T. and
M. Kleiner;
Roy F. Weston,
Inc.
Boyle, B. and
J. Filpus;
Michigan Dept.
of Community
Health
Linnear. D.,
U.S. EPA
O'Brien. B..
MDEQ
TITLE/DESCRIPTION
PAGES
Letter re: Groundwater 52
Sampling Technical Memo-
randum for Rounds 1, 2
and 3 an the J&L Landfill
Site
Letter re: Groundwater 4
Elevation Data and
Contour Maps for the May
1995 Round 3 Sampling
Event at the J&L Landfill
Site
Memorandum Transmitting 14
the "Considering Land
Use in the CERCLA
Remedy Selection Process"
Directive
Letter re: Groundwater 55
Sampling Technical Memo-
randum for Round 4 at the
J&L Landfill Site
Better re: Technical 13
Memorandum Documenting
the Results of GeoProbe
Sampling at the J&L
Landfill Site
Letter re: Completion 46
of the Residential Well
Survey for the J&L
Landfill Site
Memorandum re: J&L 16
Landfill Area well-Use
Survey
8 07/00/97
9 08/00/97
Roy F. Weston,
Inc.
Roy F. Weston.
Inc.
U.S. EPA
U.S. EPA
Baseline Risk Assess* • 115
ment Addendum for the
J&L Landfill Site
(REVISED.FINAL DRAFT)
Focused Feasibility 278
Study for the J&L Land-
fill Site (FINAL DRAFT)
-------
10 08/11/97 Kerbawy, C., Carney, W., Letter re: MDEQ's Review
MDEQ U.S EPA of the Draft Proposed Plan
for the J&L Landfill Site
11 08/00/97 U.S. EPA Public Proposed Plan for the 11
Groundwater Operable Unit
at the J&L Landfill Site
-------
U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
J & L LANDFILL SITE
ROCHESTER HILLS, MICHIGAN
ADMINISTRATIVE RECORD FOR 1O6 ORDER
06/09/95
DOC! DATE . AUTHOR
RECIPIENT
nansns
TITLE/DESCRIPTION
PASES
1 04/02/90 Papajcik, D., LTV
Sttel Conpany
2 04/04/90 U.S. EPA
Adaekus, V., U.S.
EPA
3 09/08/90 U.S. EPA
4 01/12/94 U.S. EPA
3 02/08/94 U.S. EPA
6 03/21/94 U.S. EPA
7 05/20/94 U.S. EPA
8 07/19/94 U.S. EPA
9 08/03/94 U.S. EPA
Letter ri: Ptrforunct of an Rl/FS
Adiiniitrativt Retort: Original (1 Hicrofiche 854
Voluat) [Docuwnts Comprising the AR are
Incorporated by Reference and Nay be Viewd
at U.S. EPA Region 5, 77 H. Jackson Blvd.,
Chicago, II 60604-3590]
Administrative Record: Update II (1 Volume) 3
(Oocueentt Comprising the AR are Incorporated
by Reference and Ray be Viewd at U.S. EPA
Region 5, 77 V. Jackson 81vd., Chicago, IL
60604-3590]
Adeinistrative Record: Update 12 (2 Volutes) 902
[Documents Comprising the AR are Incorporated
by Reference and Ray be Viewd at U.S. EPA
Region 5, 77 V. Jackson llvd., Chicago, IL
60604-3590]
Adeinistrative Record: Update 83 (1 Voloea) 161
[Documents Comprising the AR are Incorporated
by Reference and Hay be Viewd at U.S. EPA
Region 5, 77 H. Jackson Blvd., Chicago, IL
60604-3590)
Adeioistrative Record: Update 14 (1 Volute) 131
[Documents Comprising the Aft are Incorporated
by Reference and Ray be Viewd at U.S. EPA
Region 5, 77 H. Jackson Blvd., Chicago, IL
60604-3590]
Adniniitrative Record: Update IS (1 Voline)
[Documents Comprising the AR are Incorporated
by Reference and flay be Viewd at U.S. EPA
Region 5, 77 V. Jackson Blvd., Chicago, IL
60604-3590]
Adeinistrative Record: Update M (1 Volute)
[Documents Coeprising the AR are Incorporated
by Reference and Hay be Viewd at U.S. EPA
Region 5, 77 H. Jackson Blvd., Chicago, IL
60604-3590]
Adeinistrative Record: Update 17 (1 Volwe)
IBocueeets Comprising the All are Incorporated
by Reference and Hay be Viewd at U.S. EPA
Region 5, 77 «. Jackson Blvd., Chicago, IL
60604-3590]
76
21B
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DOM DATE
AUTHOR
RECIPIENT
10 OS/24/93 Evans, L, U.S. EPA File
TITLE/DESCRIPTION
PAGES
Hetorandut re: Non Significant Oi ft erenow
letieen tht Septetter 30, 1994 Record of
Decision for Optrablt Unit I! and tht RD/RA
Scope of Hork attached to the Unilateral
Order for Operable Unit II
-------
AR
U.S. ENVIRONMENTAL PROTECTION AGENCY
ADDENDUM TO THE ADMINISTRATIVE RECORD
SECTION 1O4 UNILATERAL ADMINISTRATIVE ORDER
J&L LANDFILL SITE
ROCHESTER HILLS, MICHIGAN
O4/2i/96
90CI DATE AUTHOR RECIPIENT. TITLE/DESCRIPTION PASES
s::= sssr , zsssss sxcssssrs sssssssrsssssssss sssss
1 07/16/87 State of Kichigtn/ Real Property Records: Tax Deeds for TMO 2
Oakland County Properties
2 07/06/90 Golden, R. U.S. Bankruptcy Proceedings for a Reorganization Under 29
Court/Southern Chapter 11: Hetorandui of Points and
District of Nn York Authorities in Opposition to Motion to
Disallo* Claiis of Richard A. Golden
3 10/23/90 U.S. Bankruptcy Respondents Eicerpts frot October 23, 1990 Hearing 6
Court/Southern ' Transcript re: Objections to Clain of
District of Nn York Richard Golden
4 08/25/95 Papajcik, D., LTV Evans, L. and T. Letter re: Access to Property Adjacent to the 2
Stee! Coipany Nash, U.S. EPA :tl Landfill Site
S 08/31/9! Etchiscn, J., LTV Evans, L., U.S. EPA Letter re: LTVs 3tatetents Relating to 1
Steel Csipan; Actions ar.d Activities Undertaken Pursuant to
t.ie June ". 1??5 Administrative Order
6 03/19/96 Nash, T., U.S. EPA File Keiorandui re: Telephone Conversation nth 1
Richard Bolder
7 04/10/96 Papajcik, D., LTV U.S. EPA Indemnification and Hold Hanless Agreement 1
Steel Cotpany, Inc.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
SEP 30 Ut?
REPLY TO THE ATTENTION OF:
FROM: William E. Muno, Director A*/ f
MEMORANDUM
Superfund Division
TO: File
SUBJECT: T^J, landfill Record of Decision for Operable Unit 2.Compliance with
Michigan Act 451 part 201
Michigan Administrative Rule 299.5705(5) of Act 451 part 201 indicates that unless a waiver
has been granted, the horizontal and vertical extent of hazardous substances is not to increase
after the initiation of remedial activities. Part 201 of Act 451 at Section 324.20118(5) permits
implementation of a remedy that does not comply with Administrative Rule 299.5705(5) if
there is "a finding that the remedial action is protective of public health, safety, and welfare,
and the environment." U.S. EPA has determined, and has made a finding that Alternative 2.
the selected remedy, is protective of public health, safety, welfare, and the environment, and
therefore U.S. EPA has complied with the substantive requirements of Part 201 of Act 451 at
Section 324.20118(5). Similarly, this U.S. EPA finding is sufficient to conclude that the
grounds for acquiring a waiver of Rule 299.5705(5) have also been met. Therefore, U.S.
EPA has also met the substantive requirement of Rule 299.5705(5) by determining that a
waiver of this requirement should be issued based on U.S. EPA's finding that public health.
safety, welfare and the environment are protected by the selected remedy, Alternative 2.
This determination and finding is based on the fact that the alleged exceedances downgradient of
residential criteria established by regulation promulgated under the Michigan statute referenced
above, for Aluminum, Iron, Manganese and Sodium, are not necessarily related or attributable to
the J&L Landfill in the first place, as similar levels of these same substances are found in
groundwater upgradient of the site, as well as to the North and South of the site.
This determination and finding are consistent with past practice of this Agency at Michigan
Superfund sites where the Michigan Act referenced above has been found to be applicable.
R«cyckxl/R»cycl«ble-Pr1m»d with Vegetable Oil B«Md Inks on 100% Recycled Piper (40% Postconsumer)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
29 September 1997
MEMORANDUM
FROM:
William E. Muno, Director
Waste Management Division
Linda M. Nachowicz,
THROUGH: W
Remedial Response Bi
SUBJECT: Final Record of Decision for the Jones & Laughlin Landfill (JLLF) Superfund Site,
Oakland County, Rochester Hills, Michigan
For your review and signature, I have attached a copy of the Final Record of Decision (ROD)
for the JLLF Site, Oakland County, Rochester Hills, Michigan. This briefing memo is used
for your convenience since a briefing was held for the Proposed Plan. A formal briefing on
the ROD can be held should you so desire.
BACKGROUND:
The Jones and
Landfill (JLLF) Superfund site is located on Hamlin Road in Rochester
Hills, Michigan. Land use in the vicinity of the JLLF includes residential, industrial, recreational, .
other landfill, and mining facilities. The JLLF is bordered on the east and north by Sandfill
Landfill No. 2, and on the west by Sandfill Landfill No. 1 . There are at least six other landfills
within one-half mile of the site. Residential areas exist within 500 feet of the southern property
boundary, approximately 1,000 feet northwest of the site, and approximately 600 feet east of the
site along Hamlin Road. The JLLF and adjacent properties are zoned light industrial.
Steel slag and steel manufacturing wastes were the primary wastes disposed at the site, which was
a former sand and gravel borrow area. During 1967 or 1968, baghouse dust filters were installed
on the electric arc furnaces at the J&L Steel, Warren, Michigan facility. The dust collected by
these filters, referred to as electric arc furnace (EAF) dust, was thereafter co-disposed of with slag
at the JLLF.
In 1976, the Michigan Department of Natural Resources (MDNR) conducted an area-wide
.groundwater study and identified an area of groundwater contamination primarily attributed to a
landfill west of the JLLF. As a result, local residents were provided with an alternative drinking
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water supply. This study also determined that although the area-wide groundwater contamination
problem was attributable to many possible sources, the JLLF was probably contributing as well.
U.S. EPA Region 5 files indicate that the J&L Steel Company submitted a CERCLA notification
in June 1981, claiming ownership of the subject property for which it reported disposal of 55,555
cubic yards of steel slag from 1966 to 1980. Ecology and Environment, Inc. (E&E), completed a
Preliminary Site Assessment in July, 1983, followed by a Site Inspection in June, 1984 to verify
the site location and ownership. The Hazard Ranking System (MRS) scoring was completed by
an E&E Field Investigation Team (FIT) in July, 1985, with an HRS score of 31.65 based on the
site's potential for groundwater contamination. The site was proposed for addition to the
National Priorities List (NPL) in the June 10, 1986 Federal Register (Volume 51, Number 111,
pages 21099-21108).
An RI/FS was conducted in 1991-1994 and a ROD was signed to address the direct contact risk
from the landfill by the placement of a RCRA subtitle C cap over the landfill. In 1995 EPA issued
a UAO to LTV steel to perform the remedy which will be complete this fall. In 1996 additional
groundwater investigation and another baseline risk assessment was performed which indicated a
risk from groundwater use beneath the site and beneath the landfill adjacent No unacceptable
risks were found downgradient of the adjacent landfill's (SandfiU Landfill #2) waste management
unit.
DESCRIPTION OF THE REMEDY:
The purpose of this remedy is to eliminate the groundwater exposure pathway for potential human
receptors. The selected remedy for OU2 consists of implementing groundwater use restrictions,
installing monitoring wells, and performing periodic groundwater monitoring. Other components
of the selected remedy include:
• Reliance on enforceable institutional controls (i.e. deed restrictions) which restrict
groundwater use under Sandfill Landfill #2 in addition to the deed restriction currently in
place on the "LLF property;
• Installing three monitoring well nests, one upgradient and two downgradient, with each
nest consisting of a shallow and a deep well;
• Perform baseline quarterly groundwater monitoring and subsequent annual groundwater
monitoring, if deemed appropriate, of COCs at residential wells and at on-site and off-site
monitoring wells. As a contingency, if these downgradient wells indicate that there is an
unacceptable risk due to contamination from the JLLF site, residences will be provided
with an alternate water supply.
State/Public:
The State of Michigan has indicated they do not concur with this decision. A written
confirmation is expected by September 30, 1996, and will be added to the administrative record
upon receipt.
The U.S. EPA has hosted a public meeting to inform local residents of the Superfund process.
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initiate the remedial investigation, and solicit public comment on the Proposed Plan.
Community involvement has been limited.
Information repositories have been established at the Rochester Hills Public Library, 500 Olde
Towne Road, Rochester, Michigan and Rochester Hills City Hall, 1000 Rochester Hills Drive,
Rochester Hills, Michigan.
Only 7 comments were received during the public comment period. The general concern was
how and when the larger area, outside of the superfund site, would be addressed, especially in
relation to this groundwater decision. All comments were addressed in the Responsiveness
Summary.
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