PB98-963120
EPA 541-R98-099
March 1999
EPA Superfund
Record of Decision Amendment:
Springfield Township Dump
Davisburg, MI
6/10/1998
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
RECORD OF DECISION
AMENDMENT
for the
Springfield Township "Dump" Superfund Site
Oakland County, Michigan
June 1998
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CONTENTS
Section Page
I. Declaration ii
II. Administrative Record Index iv
III. State Letter of Concurrence xi
t
IV. Decision Summary 1
Introduction ' 1
Background 1
Figure 1 2
, Figure 2 2
Site History Post-1990 ROD 3
Proposed ROD Amendment/Community Participation 7
Tables 1-4 8
Detailed Description of ROD Amendment 9
Evaluation of Proposed ROD Amendment (The Nine Criteria) 12
Statutory Determinations 17
V. Responsiveness Summary (follows page 17)
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DECLARATION
SELECTED REMEDIAL ALTERNATIVE
FOR THE
Springfield Township "Dump" Site
Oakland County, Michigan
Statement of Basis and Purpose
This decision document presents the amendments to the remedial action for the Springfield
Township "Dump" site, Oakland County, Michigan, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the administrative record for the site. The
attached index identifies the items that comprise the administrative record upon which the
amendment determination is based.
Description of the Amended Remedy
The amended remedial action changes the selected method of addressing PCB-laden soils and
also changes certain soil and groundwater cleanup standards previously selected in the 1990
Record of Decision (ROD) to reflect current state standards:
PCB-laden soils will be excavated and treated on-site using one of the following three
treatment alternatives - soil washing, solvent extraction, or low temperature thermal
desorption - instead of on-site incineration.
PCB-laden soils will be excavated to achieve a cleanup standard of 1 part per million
(ppm) in the upper 6 feet of the soil horizon and then 50 ppm to depth.
PCB-treatment residuals containing 5 ppm or less may be backfilled on-site. Upon
completion of the cleanup action, the excavated area will be regraded and a minimum
1-foot cover of clean soil shall be placed and maintained over the backfilled treatment
residuals. Deed restrictions shall be placed on the site property to prevent disturbance
of the soil cover and the treatment residuals below the soil cover.
Groundwater and soil cleanup standards shall be modified as shown in Tables 1 -4 of the
attached Decision Summary.
The groundwater and soil vapor extraction and treatment systems and the arsenic and lead
groundwater cleanup standards identified as pan of the selected remedy in the 1990 ROD and
in the 1993 Explanation of Significant Differences remain unchanged.
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Declaration Statement
The selected amended remedy is protective of human health and the environment, attains
Federal and state requirements that are applicable or relevant and appropriate for this remedial
action, is cost-effective, and is otherwise in compliance with CERCLA. This remedy satisfies
the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element and utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining on-site above health-based
levels, a review will be conducted every 5 years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection of human health and the
environment.
State Concurrence '
U.S. EPA provided the State of Michigan with an opportunity to concur with the amended
remedy and the State of Michigan has indicated that it does not object to the changes in the' soil
remedy and cleanup standards included in this ROD Amendment. A letter from the State of
Michigan signifying its position on the ROD Amendment is attached.
IV
-fir William E. Muno, Director Date
Superfund Division
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U.S. BNVIRONMSNTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RXCORD
FOR
SPRINGFIELD TOWNSHIP SITE
SPRINGFIELD TOWNSHIP, OAKLAND COUNTY, MICHIGAN
ROD AMENDMENT
MARCH 25, 1998
MO. DATE
1 05/15/87
2 08/00/88
APTHOR
Huff, S.
U.S. DOI
U.S. EPA/
OSWBR
Constaotelos,
B., U.S. EPA
U.S. EPA
3 08/00/88
U.S. EPA/
OSWBR
U.S. EPA
4 03/01/89
Porter, J.,
U.S. EPA
U.S. EPA/
Regional
Administrators
5 07/00/89
U.S. EPA/
OSWER
U.S. EPA
6 07/00/89
U.S. EPA
247
244
TTTTiB /P KQUPTIOM
Memorandum re:
Preliminary Natural
Resource Survey
Region S
Guidance: CERCLA
Compliance with Other
Lawa Manual: Interim
Final (OSWBR Directive
540/G-89/006)
Guidance: CERCLA
Compliance with Other'
Laws Manual (DRAFT)
[OSWER Directive 9234.1-
OlJ
Memorandum re: Interim 77
Guidance on Administrative
Records for Selection
of CERCLA Response
Actions (OSWBR Directive
9833.3)
Interim Final Guidance 198
on Preparing Superfund
Decision Documents: The
Proposed Plan, the Record
of Decision, Explanation
of Significant Differnces,
the Record of Decision
Amendment (OSWER Directive
9355.3-02)
Final Remedial Invest-
igation Report for the
Springfield Township
Dump Site: 3 Volumes
(DOCUMENT INCORPORATED
BY REFERENCE: SEE U.S
EPA ADMINISTRATIVE
RECORD--UPDATE 02--
DOCUMENTS #2-4)
-IV-
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Spring£i«ld Townahiy AR
ROD AnMn&Mnt
PATH
11/20/89
AUTHOR
Fred R. Hart
& Associates
Springfield
Township
Steering
Committee
TTjyt^/DKflCRIPTION
Report: Distribution
of Arsenic and Pesti-
cides at the Springfield
Township Dump Site
(DOCUMENT INCORPORATED
BY REFERENCE: SEE U.S.
EPA ADMINISTRATIVE
RECORD--UPDATE #3--
DOCUMENT #27)
02/08/90
07/00/90
McBride, R.;
Kemp, Klein,
Dmphrey,
Endelman &
Beer
U.S. EPA
Martin, M.,
U.S. EPA
10
08/00/90
U.S. EPA/
OSWER
U.S. EPA
Letter Forwarding 103
Attached Notice Letters
That Here Sent to PRPs
Dated January 23, 1990
w/Copies of the Certified
Mail Receipts
Final Feasibility Study
Report for the Spring-
field Township Dump Site
(DOCUMENT INCORPORATED
BY REFERENCE: SEE U.S.
EPA ADMINISTRATIVE
RECORD--UPDATE #3--
DOCUMENT #28)
Guidance on Remedial 160
Action for Superfund
Sites with PCB Contam-
ination (OSWER Directive
9355.4-01)
11
08/00/90
U.S. EPA/
OSWER
U.S. EPA
12
13
09/02/90
04/00/91
U.S. EPA
U.S. EPA/
OSWER
Public
U.S. EPA
Quick Reference Fact
Sheet: A Guide to
Remedial Action at
Superfund Sites with
PCB Cont amination
(OSWER Directive
9355.4-01FS)
Record of Decision for
the Springfield Township
Dump S i te
Guide to Addressing
Pre-ROD and Post-ROD
Changes (OSWER Directive
9355.3-02FS-4
172
-V-
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ROD Amendment
po.
AUTHOR
TXTIiK/DKSCRIPTION
14 04/00/91 U.S. EPA/
OSWER
15 11/00/91 Gradient
Corporation
16 01/00/92 CH2M Hill
17 01/00/92 CH2M Hill
18 03/20/92 Ullrich, D.,
U.S. BPA
19 04/17/92 Merrill, D.,
Gradient
Corporation
20
12/11/92
CH2M Hill
21
03/26/93
Gorka, J. and
D. Cleveland;
Springfield
Site Action
Committee
U.S. EPA
PAOK8
U.S. EPA
U.S. EPA
U.S. EPA
Lerminiaux, K.;
Dickinson,
Wright, et al.
Clarizio, R.
and M. Martin;
U.S. EPA
U.S. EPA
Ullrich, D.
U.S. EPA
Guide to Developing 6
Superfund No Action/
Interim Action and
Contigency Remedy RODa
(OSWER Directive 9355.3-
02PS-3)
STSSC Type B/C Remedy 49
Proposal for the Spring-
field Township Dump Site
Predesign Report for 132
the Springfield Town-
ship Dump Site
Remedial Design Field 265
Investigation for the
Springfield Township
Dump Site
t
Administrative Order on
Consent w/Attachments
(DOCUMENT INCORPORATED
BY REFERENCE: SEE U.S.
BPA ADMINISTRATIVE
RECORD FOR THE ESD--
DOCUMBNT #15)
Methodology for Estab-
lishing Background Levels
for Arsenic and Lead
in Groundwater Report
w/Cover Letter (DOCUMENT
INCORPORATED BY REFERENCE.
SEE U.S. EPA ADMINISTRA-
TIVE RECORD FOR ESD--
DOCUMENT #17)
Assessment of Residual
Risk (DOCUMENT INCORPORATED
BY REFERENCE: SEE U.S. EPA
ADMINISTRATIVE RECORD--
UPDATE #7--DOCUMENT #22)
Letter re: SSAC's 2
Involvement in the
Planning Process of the
Cleanup at the Spring-
field Township Dump Site
-VI-
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Springfield Townahip AR
ROD Anandaant
MO. DAIS
AUTHOR
22 04/01/93 Martin, M.
U.S. EPA
23 08/02/93 GMCE, Inc.
Gorka, J.,
Springfield
Site Action
Committee
U.S. EPA
24 09/13/93 Merrill. D.,
Gradient
Corporation
Martin, M.,
U.S. EPA
25 11/10/93 U.S. EPA
Respondent s
26 11/10/93 U.S. EPA
Public
TITLK/PMCRIPTION
Letter re: U.S. EPA'a
Response to SSAC'a
Request for a Meeting
(UNSIGNED)
Final Design Report for
the Ground Hater Recovery
and Treatment System
(DOCUMENT INCORPORATED
BY REFERENCE: SEE U.S.
EPA ADMINISTRATIVE
RECORD FOR THE ESD--
DOCUMBNT #102)
Evaluation of Background
Arsenic and Lead in
Groundwater Report w/
Cover Letter (DOCUMENT
INCORPORATED BY REFERENCE:
SEE U.S. EPA ADMINISTRATIVE
RECORD FOR BSD--DOCUMENT
#113)
»
Administrative Order 45
for Remedial Action for !
the Springfield Township
Dump Site
Explanation of Signifi-
cant Differences for the
Springfield Township
Dump Site (DOCUMENT
INCORPORATED BY REFERENCE:
SEE U.S. EPA ADMINISTRATIVE
RECORD FOR THE BSD--
DOCUMENT #137)
27
03/09/94
Bradford, W.
MDNR
Tyson, M.,
U.S. EPA
28
07/21/94
GMCE, Inc.
U.S. EPA
Letter re: MDNR's 351
Identification of ARARs
for the Springfield
Township Dump Site
w/Attachments
Construction Completion 162
Report: Groundwater
Recovery and Treatment
System for the Spring-
field Township Site
-VII-
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Township AK
ROD Amendment
PATH
AUTHOR
29 09/29/94 Geraghty &
Miller, Inc.
RECIPIENT
U.S. EPA
PAQK3
30 11/14/94 Geraghty &
Miller, Inc.
U.S. EPA
31
32
00/00/95
05/00/95
U.S. BPA/
RREL
U.S. EPA
33 06/05/95 MDNR
U.S. EPA
Report: Alternative PCB 57
Treatment Technology
Evaluation for the
Springfield Township
Superfund Site
Results of the Soils 90
and Leachate Testing
at the Springfield
Township Site (DRAFT)
Solvent Extraction
Technology Report
(CURRENTLY UNAVAILABLE)
Project Summary: 25
Removal of PCBs from
Contaminated Soil
Using the CF Systems
Solvent Extraction
Process: A Treatability
Study (EPA/540/SR-95/
505) w/Cover Letter
MERA Operational Memo 18
#8, Revision 4: Generic
Residential Cleanup
Criteria
34 06/05/95 MDNR
U.S. EPA
35 06/21/95 Kratzmeyer, J.; Martin, M.
Geraghty & U.S. EPA
Miller, Inc.
36 10/00/95 U.S. EPA/
OSWER
37 03/00/98 U.S. EPA
U.S. EPA
MERA Operational Memo
#6, Revision 4: Dermal
Contact Standards and
Groundwater Standards
(CURRENTLY UNAVAILABLE)
Letter re: Estimated
Costs for Treatment of
PCB Soils at the Spring-
field Township Site
Soil Vapor Extraction
(SVE) Enhancement Tech-
nology Resource Guide
(EPA/542-B-95-003)
ARARs Finding and Anal-
ysis for the Proposed
Plan for the ROD Amend-
ment for the Springfield
Township Dump Site
40
27
-VIII-
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SSL. Q&XK AOTHOR
38 03/00/98 U.S. EPA
RICIPIPTT
Public
39 03/00/98 U.S. BPA
Bprlng£i»ld Township AR
ROD Am*ndn*nt
Fact Sheet: Proposed
Plan for the ROD Amend-
ment for the Springfield
Township Dump Site
Proposed Plan for the
ROD Amendment for the
Springfield Township
Dump Site
10
18
-IX-
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DRAFT
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
SPRINGFIELD TOWNSHIP DUMP SITE
SPRINGFIELD TOWNSHIP, OAKLAND COUNTY, MICHIGAN
UPDATE #8
MAY 19, 1998
NO. DATE
1 05/00/95
AUTHOR
U.S. EPA/
REEL
05/00/97
U.S. EPA/
OERR
RECIPIENT
U.S. EPA
TITLE/DESCRIPTION
U.S. EPA
PAGES
Project Summary: Removal
of PCBs from Contaminated
Soil Using the CF Systems
Solvent Extraction
Process: A Treatability
Study (EPA/54O/SR-95/
505)
Engineering Bulletin:
Separation/Concentration
Technology Alternatives
for the Remediation of
Pesticide-Contaminated
Soil (EPA/540/S-97/503)
16
5, *,'/??
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STATE OF MICHIGAN
JOHN ENGLER. Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOLLISTER BUILDING. PO BOX 30473. LANSING Ml 48909-7973
INTERNET www deq slate mi us
RUSSELL J. HARDING, Director
March 20, 1998
Mr. William E. Muno, Director
Superfund Division
United States Environmental Protection Agency
Region 5
77 West Jackson Boulevard, S-6J
Chicago, Illinois 60604-3590
Dear Mr. Muno:
The Michigan Department of Environmental Quality (MDEQ), on behalf of the state of Michigan,
has reviewed the Proposed Plan for a Record of Decision (ROD) amendment received
December 8, 1997, for the Springfield Township Dump Superfund site located in Oakland
County, Michigan. The MDEQ does not object to the changes in the soil remedy and cleanup
standards outlined in the Proposed Plan for the ROD amendment.
If you have any questions, please feel free to contact Ms. Kim Sakowski, Superfund Section,
Environmental Response Division, at 517-335-3391, or you may contact me.
Sincerely,
Russell J. Harding
Director
517-373-7917
cc: Mr. Kevin Adler, U.S. EPA
Mr. Alan J. Howard, MDEQ
Ms. Claudia Kerbawy, MDEQ
Dr. George Carpenter, MDEQ
Ms. Kim Sakowski, MDEQ
Springfield Township Dump File
EQPOIOOe
(Rev 10/96)
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Record of Decision Amendment
Springfield Township "Dump" Site
Oakland County, Michigan
Introduction
This Record of Decision (ROD) Amendment describes changes to the 1990 ROD for the
Springfield Township "Dump" Superfund site ("Site"), Oakland County, Michigan. The
United States Environmental Protection Agency (U.S. EPA) is making these changes to the
1990 ROD as pan of its responsibilities under the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended.
The ROD Amendment includes modifications to the estimated volume of soil to be treated on-
site, revisions to certain soil and groundwater cleanup standards, a modification of the method
of on-site treatment of certain contaminated soils, and the placement of deed restrictions on the
future use of a portion of the Site.
Background
The Springfield Township "Dump" Site is located at 12955 Woodland Trail, about 3 miles
south of Davisburg, Springfield Township, Oakland County, Michigan (see Figure 1). The
Site is a rural, residential lot surrounded by dense woods. During the 1960's, approximately
4 acres of the property were contaminated by the unauthorized dumping of liquid chemical
wastes (see Figure 2). Liquid wastes were drained into low areas of the site and eventually
about 1500 55-gallon drums of wastes were deposited on the ground. The State of Michigan
was able to perform a partial cleanup of the Site in 1979. Since that time, the Site has been
extensively studied and tested to determine the nature and extent of residual chemical
contamination.
The studies conducted at the Site have used data collected from the sampling and analysis of
groundwater from 38 monitor wells and of soil from the more than 400 surface and subsurface
sampling locations. In addition, several tests of treatment technologies have been performed
to determine potential Site cleanup alternatives and an extensive evaluation of the sampling and
analysis data was made to determine the actual or potential risks to human health and the
environment caused by the unauthorized dumping.
The 1990 ROD contains a detailed description of the results of the testing and studies that had
been performed at the site up to that time. The pre-1990 studies indicate that certain areas of
the ground surface are contaminated with organic compounds such as polychlorinated
biphenyls (PCBs) and with heavy metals such as lead and arsenic. Volatile organic compounds
(VOCs) are found below the ground surface; further, these substances have the potential to
leach from the soils into the groundwater. Lastly, variable concentrations of VOCs, lead, and
arsenic have been detected in several groundwater monitor wells at the Site.
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Springfield
Township Dump
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Presented below is a brief chronology of the cleanup actions and studies which had been
performed at the site until the 1990 ROD was issued:
1979 - The Oakland County Health Department filed a complaint against the property
owner regarding the illegal dumping of chemicals at the Site.
1979 - The Michigan Toxic Substances Control Commission declared an environmental
emergency at the Site and commenced the excavation, removal, and off-site disposal of
55-gallon drums of liquid wastes and contaminated soils.
1980 - The Michigan Department of Natural Resources (MDNR) initiated a
hydrogeological investigation at the Site and subsequently discovered a plume of
groundwater contamination beneath the property. '
1983 - U.S. EPA placed the Site on the Superfund National Priorities List (NPL).
1985 - MDNR began a Remedial Investigation (RI) to determine the nature and extent
of soil and groundwater contamination.
1989 - MDNR completed the RI.
1990 - The Feasibility Study (FS) report and a Proposed Plan for Site cleanup were
completed and released to the public for comment. U.S. EPA selected a cleanup
remedy for the site as described in the 1990 ROD.
The 1990 ROD details the approach U.S. EPA selected for addressing groundwater,
subsurface soil, and surface soil contamination at the site. U.S. EPA determined that, to
protect human health and the environment, the Site groundwater contaminant plume must be
cleaned up to meet certain groundwater cleanup standards and that surface and subsurface soils
must be cleaned up to meet certain soil cleanup levels. The methods to be used to perform the
cleanups were:
the extraction and treatment of the groundwater contaminant plume;
the excavation and on-site incineration of soil contaminated with PCBs; and
the conduct of a soil vapor extraction (SVE) remedy on VOC-contaminated soils after
the incineration step was completed.
U.S. EPA estimated that it would cost $9.3 million (present worth) to conduct the selected
cleanup action at the Site ($9.0 million capital plus operation and maintenance costs).
Site History Post-1990 ROD
The 1990 ROD required that PCBs in the soil column, regardless of depth, be excavated to a
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cleanup standard of 1.0 mg/kg (part per million (ppm)) and then incinerated on-site. The
selection of the PCB cleanup level (1 ppm) and of the treatment method (incineration) was
consistent with the Agency's goal to clean up the chemical contaminants at the Site to levels
that would allow for unrestricted residential use of the property in accordance with U.S. EPA's
(1990) risk assessment guidance, State identified regulations and laws, and with the PCB
disposal requirements of the Toxic Substance Control Act (TSCA) (40 CFR 761.60).
In selecting the remedial action for the PCBs in the soil, U.S. EPA had relied upon, among
other factors, a volume estimate drawn from the Remedial Investigation (RI) report. Based
upon the soil sampling data in the RI, U.S. EPA estimated that there were 12,000 cubic yards
of PCB-contaminated soils to be excavated and incinerated at the Site. After releasing the
1990 ROD, and in preparation for implementation of the cleanup, U.S. EPA conducted
additional soil sampling at the Site in 1991 to ascertain the* accuracy of the soil volume
estimate. (The results of this sampling effort are contained in the "Remedial Design Field
Investigation (RDFI) Report" (1991), which was placed in the administrative record.)
The RDFI Report indicated that an estimated 28,000 cubic yards of PCB-contaminated soils
would have to be excavated and incinerated in order to meet the PCB-cleanup level contained
in the 1990 ROD. The soil volume estimate had more than doubled; thus, U.S. EPA prepared
a Predesign Report to re-evaluate the original ROD remedy. Based upon the findings of the
RDFI, the Predesign Report contained a recalculated cleanup cost estimate totalling $34
million (present worth), a substantial increase from the original $9.3 million cost estimate.
The new cost estimate information, coupled with poor site logistics (the land area is not
thought to be conducive to on-site incineration), the availability of new Site risk information
(Assessment of Residual Risk (ARR) Report (1992)), and issues regarding worker safety with
having to excavate to very deep depths to effect the PCB cleanup, caused U.S. EPA to propose
an amendment to the 1990 ROD in 1992. The 1992 ROD Amendment proposal limited the
depth of soil excavation for the cleanup of PCBs and allowed for the treatment of the PCB-
contaminated soil in the on-site mobile incineration unit at the nearby Rose Township
Superfund site (which was operating at the time the proposal was made). The proposal also
called for construction of a soil cap over a portion of the Site and for institutional controls to
be placed on the capped area. U.S. EPA later withdrew the 1992 ROD Amendment proposal
based on public comments received during the public comment period.
Immediately following the withdrawal of the 1992 ROD Amendment proposal, U.S. EPA met
with citizens and elected officials of Springfield Township (who formed the Springfield Site
Action Committee (SSAC)) and with the potentially responsible party group, the Springfield
Township Site Steering Committee (STSSC), to discuss alternatives to the implementation of
the 1990 ROD. The discussions centered around the Agency's goal of cleaning up the Site to
levels that allow for unrestricted use of the property to the maximum extent possible, although
it was recognized that institutional controls would have to be placed on the property should a
remedy change cause residual PCB levels in treated soil or non-remediated soil (at depth) to
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exceed the original PCB cleanup level (1 ppm to depth) detailed in the 1990 ROD.
As a result of these discussions, the U.S. EPA and the STSSC conducted a number of studies
and tests at the Site during the next four-year period. In 1993, U.S. EPA performed pilot
testing of solvent extraction to determine whether it could be a viable alternative to the on-site
incineration of PCB-contaminated soil. The pilot test was completed in 1995 and the results
indicated that solvent extraction could be an effective and less expensive treatment alternative
to the on-site incineration of PCB-contaminated soil. (The results of this testing effort are
contained in the "Removal of PCBs from Contaminated Soil Using the CF Systems Solvent
Extraction Process: A Treatability Study" (May 1995), which was placed in the administrative
record.)
Further, the STSSC, in cooperation with U.S. EPA, also evaluated several alternative
remediation technologies capable of treating PCB-contaminated soil. The results of this
evaluation were presented in the Alternative PCB Treatment Technology Evaluation Report
(September 1994). This report indicated that both soil washing and low-temperature thermal
desorption could also be effective and less expensive alternatives to on-site incineration of
PCB-contaminated soil.
Next, the STSSC conducted a soils and leachate testing program to evaluate whether the
residual concentrations of PCBs and metals (lead and arsenic) under the 1992 ROD
Amendment proposal could be harmful to the Site groundwater quality. The evaluation
consisted of batch leaching tests and soil column studies. The soil column tests were
conducted on actual soil samples collected from the Site to determine the leaching potential of
PCBs and metals under simulated field conditions. The results of the leachate studies were
presented in the Soils and Leachate Testing Report, Springfield Township Site (November
1994). The test results indicated that, upon completion of a cleanup action as described in the
1992 ROD Amendment proposal, residual PCBs and metals in the site soil would not pose a
hazard by leaching at levels above the cleanup standards into the groundwater beneath the Site.
Lastly, the STSSC performed pre-design groundwater studies and treatment testing prior to the
construction of the groundwater extraction and treatment system. The STSSC began operating
the groundwater cleanup system at the Site in 1994.
Presented below is a brief chronology of the cleanup actions and studies which have been
performed at the site after the 1990 ROD was issued:
1991 - U.S. EPA conducted the Remedial Design Field Investigation (RDFI) at the Site
to further define the extent of contamination. Based on the RDFI, U.S. EPA re-
evaluated the selected remedy and its costs.
1992 - U.S. EPA and the STSSC signed an Administrative Order on Consent to initiate
design of the SVE system and the ground water extraction and treatment system.
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1992 - U.S. EPA prepared the Assessment of Residual Risk Report for the Site, based
upon the findings of the RDFI and Predesign Report.
1992 - U.S. EPA prepared a ROD Amendment proposal and presented the proposal for
public comment. U.S. EPA withdrew the proposal upon consideration of the public
comments received.
1993-1995 - U.S. EPA began meeting with local citizens on an informal basis to
explore methods for citizen participation in the Site cleanup process and to address
citizen concerns and questions.
1993 - 1995 - U.S. EPA evaluated the solvent extraction process as an alternative to on-
site incineration of PCB-contaminated soil.
1993 - U.S. EPA published an Explanation of Significant Difference (ESD) (which was
a minor modification to the 1990 ROD) document, in which a change was made to the
groundwater treatment system and to the published background concentrations for
arsenic and lead in the Site-area groundwater.
1993 - The STSSC agreed to construct and operate the groundwater extraction and
treatment system at the Site.
1994 - The STSSC began operating the groundwater treatment system.
1994 - The Springfield Site Action Committee (SSAC) began Site cleanup option
discussions with the STSSC.
1994 and 1995 - "Part 201" of the Michigan Environmental Response Act was passed,
triggering significant changes to existing state cleanup standards.
1994 - The STSSC conducted soil PCB, arsenic, and lead leach-tests.
1994 - The STSSC evaluated the effectiveness of the soil washing and low temperature
thermal desorption treatment methods as alternatives to the on-site incineration of PCB-
contaminated soil.
1996 - Discussions between the SSAC and STSSC continued.
1997 - Discussions between the SSAC and the STSSC were concluded.
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Proposed 1998 ROD Amendment
In March 1998, U.S. EPA determined that it had sufficient data to select an alternative cleanup
remedy to on-site incineration of PCB-contaminated soil. Additionally, the discussions
between U.S. EPA, the STSSC, and citizens of Springfield Township had led to an
understanding of community preferences. Therefore, U.S. EPA proposed that the following
cleanup remedy be implemented at the Site in place of the on-site incineration of PCB-laden
soil:
All soils which contain semivolatile organic contaminants (such as PCBs) in excess of
the Remedial Action Standards (RAS) shown in Table 1 would be excavated to a depth
of 6 feet.
i
All soils which contain over 50 ppm of PCBs would be excavated regardless of depth.
Excavated soils which are contaminated with semivolatile organics would be treated'
using either the soil washing, low temperature thermal desorption, or solvent extraction
treatment methods (described below). Treated soil containing residual levels of up to
5 ppm of PCBs and 620 ppb of dieldrin (a pesticide) may be backfilled into the
excavated area.
Treated soil that exceeds the RAS for metals (Table 2) would be solidified and
backfilled on-site or disposed of off-site at a permitted facility.
All areas of excavation would be returned to grade, covered with a J-foot thick, clean
soil cover (cap), and revegetated.
All soils on the portion of the site which is on the "Nickson property" (Figure 2) and
outside of the area of semivolatile organic contamination, and which exceed the RAS
for metals to a depth of 1.5 feet, would be excavated and either treated (solidification)
and backfilled on-site or disposed of at a permitted facility.
The future use of the south 500 feet of the "Nickson property" would be restricted to
prevent activities which would disturb the soil cap or the backfilled soils.
All contaminated soil outside of the "Nickson property" (the former "Tinsley property"
(Figure 2)) woi-'d be excavated to depth to meet the RAS in Table 2, and either
solidified and backfilled on the "Nickson property" or disposed of at a permitted
facility. Soil treatment residuals would not be placed on the "Tinsley property."
Further, the following changes were proposed to be made to the 1990 ROD:
Soils containing VOCs would still be treated using the soil vapor extraction cleanup
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Table 1
Remedial Action Standards for Semivolatile Organics in Soil
Contaminant 1990 ROD RAS 1998 ROD Amendment RAS
PCBs 1 ppm 1 ppm (a>
Dieldrin 80 ppb 620 ppb M
Table 2
Remedial Action Standards for Metals in Soil
Contaminant 1990 ROD RAS '1998 ROD Amendment RAS
Arsenic background 9 ppm
Barium 100 ppm 30,000 ppm(c>
Lead background 400 ppm(c)
Table 3
Remedial Action Standards for Volatile Organics in Soil
Contaminant 1990 ROD RAS 1998 ROD Amendment RAS
Toluene 0.8 ppm 16 ppm (d)
Chlorobenzene 2.8 ppm 2 ppm(d)
Trichloroethylene 0.06 ppm 0.10ppm(d)
Table 4
Remedial Action Standards for Groundwater
Contaminant 1990 ROD RAS 1998 ROD Amendment RAS
Toluene .04 ppm 1 ppm
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remedy previously selected in the 1990 ROD; however, certain cleanup levels would be
adjusted to current state standards (see Table 3)
Ground water would continue to be extracted and treated as under the 1990 ROD and as
designed and currently operated by the STSSC; however, certain cleanup levels would
be adjusted to current state standards (see Table 4)
U.S. EPA released a proposed plan for public comment on March 26, 1998. The comment
period was scheduled to run from March 26, 1998, through April 27, 1998. U.S. EPA hosted
a public meeting at the Springfield Township Hall, Davisburg, Michigan, on April 2, 1998. at
7:00 pm, and presented the proposed 1998 ROD Amendment and took official public
comments from the audience. The comments have been addressed in the Responsiveness
Summary attached to this ROD Amendment.
Detailed Description of 1998 ROD Amendment
The 1998 ROD Amendment provides for the protection of human health and the environment
through a combination of the following:
1. the excavation and treatment of contaminated surficial soils,
2. a limitation on the potential for future exposure to contaminants,
3. the in-situ treatment of subsurface soils through SVE, and
4. the extraction and treatment of contaminated groundwater.
The first two cleanup actions are described below. For the SVE and the groundwater
components, the remedy remains as described in the 1990 ROD (as modified by the 1993
ESD). The 1998 ROD Amendment merely updates certain RAS to meet current state law, as
shown in Tables 1-4.
1. Excavation and treatment of contaminated surficial soils
Surficial soils on portions of the Site are contaminated with organic chemicals and metals:
a. Semivolatile Organic Contamination
All soils within 6 feet of the ground surface which exceed 1 ppm of PCBs and/or 620 parts per
billion (ppb) of dieldrin will be excavated and treated on-site. In addition, all soils which
exceed 50 ppm of PCBs will be excavated, regardless of depth, and treated on-site.
Approximately 11,500 cubic yards of PCB-laden soils would be excavated and treated.
Excavated soils will be treated on-site using one or more of the following treatment methods:
i) soil washing; ii) solvent extraction; or iii) low-temperature thermal desorption.
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i) Soil Washing is a process in which the fine-grained fraction of soil containing the bulk of
the contaminants is physically separated from the coarser-grained soil material. The technique
then uses water and emulsifying or surfactant additives as an extraction agent to treat the
coarse-grained fraction to remove the contaminants of concern. The soil is first broken up and
then mixed with water to form a slurry. Some of the contaminants are removed from the soil
into the water phase and are then treated using various water treatment technologies.
However, most contaminants usually remain in the fine-grained fraction, which is separated
from the cleaned, coarse-grained fraction and is then disposed of in a permitted facility. It is
estimated that the overall remedy would cost about $3.3 million (present worth) to implement
if soil washing was used to treat the PCB-laden soil.
ii) Solvent Extraction uses an organic liquid (such as propane) as a solvent to extract PCBs
and other organic compounds from the soil. The contaminated soil is first broken up and then
it is mixed in a container filled with the solvent. The solvent dissolves the contaminants out of
the soil and the soil is then removed from the container. The solvent is then treated to recover
the contaminants which are then properly disposed of. The cleaned solvent is then re-used 'on
the next batch of contaminated soil and the treated soil is placed back into the ground. It is
estimated that the overall remedy would cost about $12.3 million (present worth) to implement
if solvent extraction was used to treat the PCB-laden soil.
iii) Low Temperature Thermal Desorption is a process through which contaminated soils are
heated to high temperatures, but to lower temperatures than in an incinerator. The
contaminants are removed as a vapor. The contaminated soils are first broken up, then they
are fed into an oven which is heated to a temperature which will volatilize the PCBs and other
organic compounds but not burn them. An inert "carrier" gas, such as nitrogen, is swept
through the hot oven, displacing oxygen and preventing burning. Instead, the vaporized
contaminants are condensed from the carrier gas and collected for proper off-site disposal.
The cleaned soils are then replaced back into the ground. It is estimated that the overall
remedy would cost about $5.7 million (present worth) to implement if low temperature thermal
desorption was used to treat the PCB-laden soil.
The three technologies have been demonstrated to be capable of cleaning Site soils to a PCB
concentration of 5 ppm or less and are readily available from vendors who specialize in site
remediation. Final selection of the cleanup remedy to be used would be made by the STSSC
for implementation by the STSSC, subject to U.S. EPA review and approval. The selection
will be based upon a technology vendor's documentation and track record, capability to meet
the performance standards, compliance with applicable laws and regulations, health and safety
concerns, and the cleanup cost.
Treated soil that exceeds 5 ppm of PCBs and/or 620 ppb of dieldrin will be reprocessed on-site
until it meets the RAS. Soil that does not meet the RAS after re-processing may be disposed of
off-site at a permitted facility. Treated soils that contain 5 ppm or less of PCBs will be placed
back into the excavated area and covered with a 1-foot clean soil cap. If the treated soils
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contain metals concentrations which exceed the RAS, the soils will either be
stabilized/solidified (see next section) and backfilled on-site, or will be disposed of at a
permitted facility off-site.
b. Metals Contamination
Site soil is also contaminated with heavy metals, such as lead and arsenic. Much of this soil
contains PCBs and will be excavated and treated as described above. Areas of metals
contamination within the "Nickson property" that are not to be addressed in combination with
PCBs will be excavated to a depth of 1.5 feet, stabilized, and backfilled on the site or disposed
of at a licenced facility off-site. Soils treated for semivolatile organic contamination that have
heavy metals in them will also be stabilized and backfilled on-site or disposed of off-site.
r
Stabilization/Solidification is a technique by which contaminants are immobilized so that they
cannot be released throughout the environment. In this case, the purpose of solidification is to
minimize the potential for intake of metals-contaminated soil by mixing cement with affected
soil into a solid mass. This step can be achieved either by mixing the contaminated soil in-
place or by excavating the soil, mixing it with cement, and returning the soil mass into the
ground.
Soil on the former "Tinsley property" with metals contamination will be excavated regardless
of depth until the RAS are met. This soil will be then be treated using soil washing or
solidification and then it will be backfilled on the "Nickson property" or it will be disposed of
off-site at a permitted facility. Excavated areas on the former "Tinsley property" will be
backfilled with clean soil and revegetated.
2. Limitations on the potential for future exposure to contaminants
U.S. EPA requires that two methods be used to isolate residually-contaminated areas of the
Site to prevent future exposure to site contaminants:
a. Capping
All areas of the Site at which excavation and/or backfilling of treatment residues occurs will be
backfilled to grade and covered with 1 foot of clean soil and revegetated to stabilize the soil
against erosion. The soil cap shall be inspected on a quarterly basis and repaired as necessary.
Thus, potential exposure to PCBs on the ground surface will be limited to 1 ppm or less.
The former "Tinsley property" will be backfilled with clean fill to return excavated areas to
grade and revegetated. Inspection and repair of any soil cover will not be required on the
former "Tinsley property."
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b. Institutional Controls
A legally enforceable deed restriction (or "easement") will be placed on the "Nickson
property" so that the future use of the south 500 feet of the "Nickson property" will be
restricted to those activities which do not interfere with the performance of any cleanup
activities listed in the 1990 ROD and the 1998 ROD Amendment or disturb the integrity of the
soil cap to be placed over the treatment residuals.
3. In-situ treatment of subsurface soils through soil vapor extraction
Upon completion of the surface soil cleanup activities, an in-siru soil vapor extraction system
will be installed in the subsurface soils. Numerous vapor recovery wells will be screened in
the VOC-contaminant zone above the groundwater table. Vaporized contaminants will be
pumped out of these wells and recovered using granular activated carbon canisters. Once fully
loaded with VOCs, the carbon canisters will be replaced with fresh ones and the used canisters
will be taken off-site for destruction of the VOCs and reuse of the carbon. This portion of the
overall cleanup remedy is unchanged from the 1990 ROD, except that the RAS for certain
organics are to be changed to meet current state law (see Table 3).
4. Extraction and treatment of contaminated groundwater
This portion of the overall cleanup remedy, too, is unchanged from the 1990 ROD, except that
the RAS for certain organics are to be changed to meet current state law (see Table 4). A
groundwater extraction well has been installed at the site and is currently pumping 8-10 gallons
per minute from the contaminant plume. The contaminated groundwater is passed through a
granular activated carbon canister to remove VOCs from the water and then the treated water
is reinjected into the ground upgradient of the pumping well. The system has been in
operation since July 1994.
Evaluation of Proposed ROD Amendment
U.S. EPA has evaluated the 1998 ROD Amendment proposal in comparison to the 1990 ROD
remedy using the nine criteria below:
Overall Protection of Human Health and the Environment - addresses whether or not a remedy
provides adequate protection and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engineering controls, or institutional
controls.
Compliance with ARARS (Applicable or Relevant and Appropriate Requirements) - addresses
whether or not a remedy will meet all of the applicable or relevant and appropriate
requirements (ARARs) of Federal and State environmental laws.
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Long-Term Effectiveness and Permanence - refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup goals have
been met.
Reduction of Toxicity. Mobility, or Volume - refers to the anticipated performance of the
treatment technologies a remedy may employ.
Short-Term Effectiveness - involves the period of time needed to achieve protection and any
adverse impacts on human health and environment that may be posed during the construction
and implementation.
Implementability - is the technical and administrative feasibility of a remedy, including the
availability of goods and services needed to implement the chosen solution.
Cost - includes estimated capital and operation and maintenance costs and estimated present
worth costs.
Support Agency Acceptance - indicates whether, based on its review of the Proposed Plan, the
support agency concurs, opposes, or has no comment on the preferred alternative. This
acceptance will be assessed from support agency comments received during the public
comment period.
Community Acceptance - will be assessed following a review of any public comments received
on the Proposed Plan.
The nine criteria outlined above are commonly divided into three groups: threshold criteria,
balancing criteria, and modifying criteria. The first two criteria are threshold criteria and must
be satisfied by any proposed remedial action under consideration. The rest are balancing and
modifying criteria and are used to evaluate the strengths and weaknesses of the those
alternatives that satisfy the threshold criteria, leading to the selection of a cleanup alternative.
For reference, the 1990 ROD selected the following cleanup remedy:
1. Excavation and treatment of contaminated surficial and subsurface soils
Organic contaminants: All soils which exceed 1 ppm of PCBs or other listed RAS would be
excavated and incinerated, regardless of the depth of contamination. The incinerator ash
would either be solidified and disposed of on-site or would be placed in a properly designed
waste disposal unit on-site. The excavated areas would be re-contoured to control ash or dust
emissions.
Metals contaminants: All soils contaminated only with metals would be excavated regardless
of depth, solidified, and backfilled on-site.
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2. Limitations on the potential for future exposure to contaminants
The potential for future human exposure to contaminants would be limited by destruction of the
contaminants and through solidification of contaminated soils and residues. No deed
restrictions would be necessary.
3. In-situ treatment of subsurface soils through SVE
An in-situ SVE system would be installed in the soil zone above the ground water table.
Contaminated vapors would be pumped out of the wells and treated using granular activated
carbon.
4. Extraction and treatment of contaminated groundwater1
An extraction well has been installed and is being pumped to capture and treat the plume of
contaminated groundwater. This system has been in operation since July 1994.
Overall Protection of Human Health and the Environment
Both of the soil cleanup remedies set forth in the 1990 ROD and in the 1998 ROD Amendment
will protect human health and the environment. Potential routes through which humans and/or
environmental receptors could be exposed to site contaminants (pathways) include ingestion of
contaminated groundwater, direct contact of contaminants in surface soil, and the movement of
VOC-contaminants from the subsurface soil into the groundwater.
The 1990 ROD remedy addressed the surface soil exposure pathway through the excavation of
contaminated soil to the RAS regardless of depth, with the subsequent incineration of PCB-
contaminated soil and the solidification of soil contaminated with heavy metals. The 1998
ROD Amendment addresses the surface soil pathway through the excavation of soils
contaminated with PCBs and pesticides to the RAS within six feet of the ground surface with
further excavation of PCBs to a cleanup level of 50 ppm regardless of depth. The excavated
soil will be treated to remove organic contaminants and/or solidified to stabilize heavy metals.
Upon backfill of treated soils into the excavation areas, a 1-foot clean soil cap and a deed
restriction will be placed on the property. Thus, while the 1990 ROD cleanup remedy relied
solely on the destruction and/or solidification of soil contaminants, the 1998 ROD Amendment
relies on a combination of treatment methods and the on-site management of residual
contaminants to minimize exposure pathways.
The 1998 ROD Amendment does not change the groundwater and subsurface soil cleanup
methods. The only difference is that the cleanup standards (RAS) set forth in Tables 3 and 4
have been changed to meet current state standards pursuant to Michigan Act 201. These
standards remain protective of groundwater quality and of human health and the environment.
Further, the results of the leachability testing performed by the STSSC indicate that residual
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PCBs and metals in the subsurface soils will not pose a hazard to groundwater quality.
Compliance with ARARs
The 1990 ROD complied with the ARARs listed in that document. The 1998 ROD
Amendment will comply with all ARARs as well. (U.S. EPA has placed a detailed analysis of
the ARARs in the Administrative Record for the Site - See document entitled "ARARs
Findings and Analysis, Springfield Township Superfund Site, Proposed Plan for ROD
Amendment" (March 1998 and Addendum dated May 1998).)
Long-Term Effectiveness and Permanence
The 1990 ROD remedy achieved long-term effectiveness and permanence through the removal
and destructive treatment of groundwater, subsurface soil, and surface soil contaminants
(except heavy metals, which cannot be destroyed).
The 1998 ROD Amendment achieves an identical level of long-term effectiveness and
permanence for the groundwater and subsurface soil, since no changes are proposed for these
cleanup methods.
The 1998 ROD Amendment achieves a lower level of long-term effectiveness and permanence
for the surface soil since it is anticipated that 11,500 cubic yards of soil would be treated for
PCB-contamination versus the projected 12,000 to 28,000 cubic yards of soil to be treated
under the 1990 ROD provisions. However, the residual contaminant levels will be managed
over the long-term using conventional means, including the placement of a soil cap and
institutional controls on affected portions of the Site.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Both the 1990 ROD and the 1998 ROD Amendment utilize permanent treatment technologies
to address site contaminants. Again, whereas the groundwater and subsurface soil cleanup
methods are exactly the same, the surface soil cleanup methods are not the same although the
endpoints each would reach are very similar. Incineration of site soil under the 1990 ROD
would have destroyed PCBs and other organic compounds on-site. The soil washing, solvent
extraction, or low temperature thermal desorption methods, however, separate the
contaminants from the soil on-site, leaving the contaminants to be shipped off-site for further
destructive treatment methods at the point of disposal.
In addition to the sheer soil volume differences cited above (see Long-Term Effectiveness).
another difference between the 1990 ROD and the 1998 ROD Amendment is that, following
treatment, the volume of the concentrated waste stream removed from the soil is estimated to
range from 400 cubic yards to 1,800 cubic yards, depending on the treatment technology
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selected. This would represent a reduction in the volume of contaminated soil of 85% to 97%.
given the estimated 11,500 cubic yards of PCB-contaminated soils that would be excavated and
treated under the 1998 ROD Amendment.
Short-Term Effectiveness
Short-term impacts due to site cleanup work are estimated to be lower under the 1998 ROD
Amendment than under the 1990 ROD. The short-term impacts typically associated with
excavation activities (such as the generation of nuisance dust and worker safety issues) and the
methods to alleviate the impacts (conventional dust-control methods and adoption of a'health
and safety plan) would be similar in scope under either cleanup method. However, since the
soil volume that would be excavated under the 1998 ROD Amendment is significantly less than
that for the 1990 ROD, the duration of these impacts are expected to be much shorter under the
1998 ROD Amendment.
In addition, due to other factors besides the soil volume difference, the length of time the *
cleanup activities to be performed under the 1998 ROD Amendment is estimated to be much
shorter than under the 1990 ROD. It is estimated that the 1998 ROD Amendment would take
about 5-6 months to complete the PCB-cleanup work - from the time equipment is brought to
the site to begin work to the time the last of the treated soil is backfilled and covered with a
clean soil cap. The 1990 ROD remedy would have required about 18-24 months to complete
the excavation and incineration process.
Implementability
The 1998 ROD Amendment is expected to be less difficult to implement than the 1990 ROD.
Construction and operation of a mobile incinerator at the site would be more difficult
logistically than construction and operation of any of the PCB-extraction technologies (soil
washing, low temperature thermal desorption, or solvent extraction) under consideration. Due
to emission requirements, the mobile incinerator would require extensive site-specific design
specifications and trial burn tests prior to full-scale operation. Space for siting the incinerator
is a strong consideration. In contrast, each of the alternate treatment technologies are available
on a commercial scale and have been previously used for the treatment of PCBs. Trial burns
would not be needed and equipment siting requirements are not as limiting as for mobile
incinerators.
Note that the PCB-extraction technologies would each produce a concentrated PCB-waste
stream that will require off-site treatment and/or disposal. These requirements are similar in
scope to the off-site disposal component of the 1990 ROD remedy. Off-site transportation,
treatment, and disposal services must be performed by licensed and permitted operators and
facilities. Adequate levels of vendor services are currently available for cleanup of PCBs at
the Site.
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Cost
The 1998 ROD Amendment would cost significantly less to implement in comparison to the
estimated cost for the 1990 ROD cleanup (as revised by the RDFI data which reflected both a
greater volume of PCB-contaminated soil to be incinerated and a higher cost per unit volume of
soil to be incinerated). The estimated cost for completing the cleanup remedies under the 1998
ROD Amendment, using one or more of the various PCB-laden soil cleanup methods, ranges
from $3.3 million to $12.2 million (present worth). The revised cost estimate for
implementing the 1990 ROD was $34 million (present worth) in 1991.
Support Agency Acceptance
U.S. EPA provided the State of Michigan with an opportunity to concur with the amended
remedy and the State of Michigan has indicated that it does not object to the changes in the soil
remedy and cleanup standards included in this ROD Amendment.
Community Acceptance
Community acceptance of the 1998 ROD Amendment has been evaluated in the attached
Responsiveness Summary.
Statutory Determinations
Superfund law requires U.S. EPA to clean up NPL sites to achieve the protection of human
health and the environment in compliance with Federal and state environmental laws and
policies (ARARs). Selected cleanup remedies must also be cost-effective and utilize permanent
solutions and alternative treatment (or resource recovery) technologies to the maximum extent
practicable, with an emphasis on cleanup remedies that employ treatment to permanently and
significantly reduce the toxicity, mobility or volume of the hazardous substances, pollutants or
contaminants. Based upon the evaluation of the nine criteria, U.S. EPA believes that the 1998
ROD Amendment presented herein satisfies the requirements set forth in CERCLA in that the
ROD Amendment would be protective of human health and the environment, would attain
ARARs. would be cost-effective, and would use treatment technologies to permanently and
significantly reduce the toxicity, mobility or volume of the hazardous substances, pollutants or
contaminants to the maximum extent practicable.
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RESPONSIVENESS SUMMARY
Springfield Township "Dump" Site
Oakland County, Michigan
The public participation requirements of CERCLA §113(k)(2)(B)(i-v) and CERCLA §117 have
been met during the 1998 Record of Decision (ROD) Amendment process for the Springfield
Township "Dump" site ("Site"). Sections 113(k)(2)(B)(iv) and 117(b) of CERCLA require
U.S. EPA to respond "...to each of the significant comments, criticisms, and new data submitted
in written or oral presentations" on a proposed plan for a remedial action. This Responsiveness
Summary addresses those concerns expressed by the public, potentially responsible parties
(PRPs), and governmental bodies in written and oral comments received by U.S. EPA regarding
the proposed 1998 ROD Amendment for the Site.
t
Background
U.S. EPA issued a fact sheet/proposed plan for this ROD amendment in March 1998 to the
public in Springfield Township, Michigan, prior to the start of the public comment period. U.S.
EPA placed advertisements announcing the availability of the proposed plan and the start of the
comment period in the Oakland Press, Ifolly Herald-Advertiser. Clarkston News, and the
Cjarkston Eccentric.
Information repositories were maintained at the two following locations: U.S. EPA Region 5,
77 W. Jackson Blvd., Chicago, IL and at the Springfield Township Hall, 650 Broadway Street,
Davisburg, Michigan. The Administrative Record was made available to the public for review
at each of these locations as well.
The public comment period ran from March 26, 1998, to April 27, 1998. U.S. EPA received
no requests for an extension to the 30-day comment period.
The Agency hosted a public meeting in Springfield Township on April 2, 1998, to provide
background information on the Site, provide details of the proposed 1998 ROD Amendment,
and to take oral public comments regarding the proposed amendment to the Site cleanup action.
U.S. EPA answered questions about the Site and the 1998 ROD Amendment alternative 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 in the Administrative Record. Written comments were also accepted at this
meeting. The meeting was attended by approximately 40 persons, including local residents.
During the comment period, U.S. EPA received 8 written comments and 10 oral comments
concerning the proposed plan. Comments received during the public comment period and the
U.S. EPA's responses to those comments are included in this Responsiveness Summary, below,
which is a part of the 1998 ROD Amendment.
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Summary of Significant Comments
A. Written
Comment 1A: Township Board, Charter Township of Springfield, MI
"Now, therefore, be it resolved: That the Township Board of the Charter Township of
Springfield supports the proposed amendment to the [1990] Record of Decision and
concurs with residents in urging its speedy implementation." Note: see Administrative
Record for entire submittal.
Response 1A:
i
U.S. EPA acknowledges the support of the Township Board in this matter.
Comment 2A: Mr. & Mrs. Rick Rubenacker, Springfield Township, MI
"...We are anxious to see this project completed as it has been 19 years since the public
has been aware of the problem. We are in full support of the proposed plan."
Response 2A:
U.S. EPA acknowledges the support in this matter.
Comment 3A: Dave and Diana Hopper, Springfield, MI (via e-mail)
"....we would like to again express our support of the proposed 1998 ROD amendment
for the Springfield Township Superfund Site. The proposed ROD [Amendment] allows for
protection of the environment and is a cost-effective alternative that can be implemented in a
timely fashion. We feel that the ROD [Amendment] is acceptable with the proposed fencing
around the site, one foot minimum of clean soil, in addition to the amount necessary to maintain
the site topography over the entire PCB excavation area. We understand that following the
completion of the clean-up, the site and fencing will be monitored and maintained on a quarterly
basis to ensure continued safety to the community and the environment."
Response 3A:
U.S. EPA concurs with the above analysis and acknowledges the support in this matter.
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Comment 4A: Gisela Lendle King, Co-chair, Friends of Rose Township, Holly, MI
"....These proposed cleanup standards in the 1998 ROD [Amendment] are significantly
higher than the 1990 ROD standards, in some cases reflecting a 300 fold increase in levels of
toxins left in the soil and ground water.
"Coincidentally, this has reduced cleanup cost for the polluting industries by Millions of
Dollars from 34 million to 3-12 Million.
"Although the residues allowed for PCBs in Table 1 [of the proposed plan] state 1 ppm,
the text on page 4 of the EPA newsletter reveals that treated soils containing residual levels of
up to 5 ppm may be backfilled into excavated areas. This is inconsistent with the statements as
presented in Table 1 of the same publication, and justifiably raises doubt about the validity of
the rest of the standards.
"How high are the residual levels of the other toxins allowed to remain in the soils and
ground water? What will be the levels (true levels) that will remain, and how far will they
exceed standards that are considered protective of human health and the environment?
"The proposed deed restriction is absolutely essential to the protection of human health
and the environment, especially since the significantly higher residual levels of toxins may not
be. But I am strongly opposed to the possibility of amending or lifting this deed restriction, as
was mentioned at the public hearing. To be protective this should be an ironclad, strictly
enforced deed restriction, particularly since urban sprawl is changing land use in the area to
higher density residential and newcomers may be totally unaware of the fact that this is a relative
[sic] poorly remediated toxic site.
"There also must be long term monitoring of the ground water with continuous sampling
rather than endpoint sampling."
Response 4A:
The changes to some of the cleanup levels at the Site serve to bring the cleanup levels in
line with current state standards. The "300 fold" increase cited above refers to the change in the
barium standard for soil, in that the 1990 ROD cleanup standard of 100 ppm is being changed to
30,000 ppm. While it is a 300-fold increase, there is no corresponding impact on risk, for the
original cleanup standard of 100 ppm was based on dermal contact risk and the current level is
based on protection of groundwater quality. Since a soil cap, deed restriction, and fence will be
placed on the impacted area, routine dermal contact with or ingestion of soils containing higher
levels of barium is not anticipated. The 30,000 ppm level is the current state standard designed
for protection of groundwater quality, in that rainwater or snowmelt leaching through soil
containing barium at 30,000 ppm would not be expected to leach barium into the water table
above the barium groundwater quality standard. The combination of the unchanged 1990 ROD
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requirements and the 1998 ROD amendment standards still yield a residual risk within the 10-4
to 10-6 risk range that U.S. EPA considers to be the standard cleanup goal for Superfund sites.
Cost reduction is a legitimate goal at Superftmd cleanup actions, as long as protection of
human health and the environment is not compromised.
The PCB cleanup level of 1 ppm is applicable everywhere in the first 6 feet of soil. If
the PCB levels exceed 1 ppm in the upper 6 feet, the soil will be excavated and treated.
Treatment residuals containing up to 5 ppm PCBs will be placed back into the main excavation
area and covered with a 1-foot clean soil cover (i.e. no PCBs in the cover). Thus, to the extent
anyone comes in contact with the excavated areas, they will encounter the clean soil at the
surface first. Exposure for metals-contaminated soils will be limited in a similar manner (i.e., a
clean soil cover over the area of excavation) on the "Nickson" property with additional
protection on the former "Tinsley" property where the soil will be excavated to depth until the
metals cleanup levels are met.
The residual levels of other compounds of concern are noted in the 1990 ROD and in
Tables 1-4 of the ROD Amendment. These are actual levels and will be verified by soil
sampling upon completion of the excavation stage. Each cleanup standard is at or below levels
that are protective of human health and environment.
U.S. EPA agrees that deed restrictions are an integral part of the remedy. U.S. EPA,
however, did not propose to amend or remove them at the public meeting. This was a
hypothetical question raised by another commenter.
U.S. EPA disagrees with the implication that this ROD amendment will result in a
"poorly remediated toxic site." A "poorly remediated toxic site" is one that has residual risks
above human health or environmental protective levels and/or improperly managed risks upon
completion of the work. At the Springfield site, the cleanup standards and proposed remedial
action approach are protective and meet ARARs. Additionally, any residual risk will be
managed properly so that it will not be a "poorly remediated" site.
Groundwater monitoring is an integral part of the cleanup remedy - it will show us when
to turn off the groundwater cleanup equipment in the future. The endpoint sampling referred to
in the comment above is sampling performed to protect against discharge of improperly treated
water into the aquifer.
Comment 5A: Cynthia Balkwell, West Bloomfield, MI
"....it appears that cost rather than extent of treatment has played a major role in the
design of this plan.... A compromise in cost would be somewhere between $9 million and
$34 million, not the estimated cost of $3.3 to $12 million for treatment under this amendment.
Given a 3% average inflation factor from 1990 to 1998, $9 million would be equivalent to
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-5-
$11.4 million today. I would not object to an amended plan that provided a comparable level of
treatment at a reduced cost. However. I strongly object to the approval of an amendment that
treats a substantially reduced volume of soil and treats it to a reduced standard of cleanup ai a
savings to the potentially responsible parties.
"I am concerned about the large gap in levels of PCBs that would trigger soil treatment
above and below 6 foot jn depth. Is the risk of 30 or 40 or 49.9 ppm that substantially less that
no treatment is recommended or required? Honestly, would you build your family home, dig
your well and raise your children and grandchildren with this proposed cleanup abutting your
backyard?
"I also find the proposed depth of one foot of clean soil for purposes of capping the
cleanup site to be inadequate. The natural inhabitants of the area include many burrowing
animals and ant colonies known for their huge anthills. As more and more of the surrounding
land is developed more of these inhabitants are likely to seek refuge on this site. If this cap of
soil is to provide protection for humans from contact with semi-treated soils it will have to be
deep enough to accomodate the instinctive habits of the area's wildlife to prevent them from
raising soil unsuitable for dermal contact to the surface.
"I am concerned about the limit of access and ongoing maintenance of the site following
cleanup under the proposed plan. A deed restriction alone will not prevent the use or abuse of
the land by unauthorized persons, just as trespassing laws don't prevent trespassing. Four
wheelers, dirt bikes and other ATVs have torn up vegetation and created considerable erosion on
properties adjoining the Nickson's property. Will the access to the deed restricted area be
limited to the property owner and authorized persons by a gated fence high enough and of a
design adequate [to] prevent trespassing? Who will be responsible and at what intervals, for
monitoring and maintaining the soil cap and any fencing limiting access? Who will have
enforcement authority for the maintenance and protection of future generations?"
Response 5 A.:
Cost effectiveness is one of the nine statutory criteria which U.S. EPA must use when
evaluating and selecting cleanup alternatives. As such, cost savings is a legitimate factor for
U.S. EPA to consider for Superfund cleanup actions as long as human health and the
environment are protected, ARARs are complied with, and the other statutory criteria are
considered. The commenter assumes that the cost savings will be realized by the PRPs simply
because U.S. EPA is pursuing them to perform the cleanup remedy. Although U.S. EPA
expects the PRPs to conduct the cleanup at this site, the cost savings will be realized by any
entity who will implement the remedial action activities required for this site. Consequently, in
the event that the PRPs do not implement the ROD Amendment, U.S. EPA, and thus the
Superfund and the taxpayers, would realize this cost savings.
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-6-
U.S. EPA disagrees with the "make them pay dearly" tone of the comment. Although it
is reasonable to want and required by Superfund to have the responsible parties cleanup the site.
U.S. EPA is not allowed under Superfund to select a cleanup based on punitive factors or factors
other than the nine statutory criteria. U.S. EPA also believes that this commenter has
misunderstood the role of cost in U.S. EPA's proposed plan. Co'sts will be reduced from those
estimated in the 1990 ROD due the change in the depth of excavation (i.e., six feet for PCBs as
opposed to throughout the soil column) and the treatment technology (allowance for selection of
one of three proven technologies in lieu of incineration). As explained in the proposed plan
U.S. EPA proposed to amend the ROD not only due to cost concerns but also due to worker
safety issues and site logistical issues. The ROD amendment crafts a cleanup remedy that takes
into account all these issues and the other statutory criteria and still provides an equivalent level
of protection of human health and the environment.
i
PCBs below 6 feet are not anticipated to be routinely encountered by humans or others.
Therefore, leaving PCBs below that depth at concentrations of less than 50 ppm is acceptable,
provided that the other portions of the remedy are implemented - deed restrictions, fencing-, and
quarterly monitoring of the soil cover. Levels above 50 ppm could present a leaching hazard to
groundwater quality beneath the Site, thus, those areas will be excavated and treated to reduce
PCB levels to below 50 ppm.
The cleanup remedy is designed to not have adverse impacts on off-site receptors such as
abutting properties.
The cover of 1-foot of clean soil will be adequate to protect human health and the
environment as long as the other portions of the remedy are implemented as well. Depending on
the treatment remedy used on the PCB-laden soils, a small percentage of the excavated soils
would be transported off-site for disposal (the PCB-concentrates). The displaced volume of soil
would be made up with clean fill material or with soil containing residual PCBs up to 5 ppm
along with the 1-foot clean soil cover. Thus, the thickness of clean soil in the backfill area may
well exceed 1 foot which provides an extra measure of protection. In addition, quarterly
monitoring of the soil cover will assure that any breeches in the cover integrity due to animal
burrowing will be timely identified and repaired as this ROD Amendment specifies.
Except for the small portion of the former "Tinsley" property, trespass to adjacent
properties is irrelevant to this ROD amendment since U.S. EPA does not have information to
indicate that those properties are contaminated. The site fence will be adequate to prevent casual
trespass onto the areas where the contamination remains on-site. Elsewhere, the ATV's, etc..
will not be exposed to chemical contaminants above cleanup levels because soil above the
cleanup levels will have been excavated and treated or disposed of off-site. The fence and soil
cover will be monitored on a quarterly basis for as long as necessary.
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-7-
Comment 6A: Donald Balkwell, West Bloomfield, MI
"I do not support the proposed amendment [for the following reasons].
"1. I can accept the alternate [PCB-laden soil treatment] technologies only if they will
adequately remediate PCBs and Dieldrin their efficacy for treatment of Dieldrin
contamination is not mentioned [in the fact sheet].
"2. I support deed restrictions in concept, but believe they need to be strengthened by
explicitly permitting enforcement by private citizens, and-requiring direct notice to surrounding
property owners and residents if any amendment, modification, or termination of the restrictions
is contemplated.
i
"3. I support surficial capping in principle, but I believe that the requirements of the
proposed amendment are not adequate to prevent leaching by rainwater of the residual
contaminants left in the soil after treatment, eventually contaminating the groundwater. As-a
minimal alternative, I would suggest that the entire contamination area be graded, covered with
an impermeable cap such as three feet of clay, subsequently covered by a drainage layer of
perhaps one foot of sand and/or gravel, protected by a geomembrane to prevent plugging of the
drainage layer, and, finally, topped by the proposed one-foot cap of clean soil and re-vegetated.
"4. I feel that long-term security of the deed-restriction area is inadequate. I believe that
a chain-link fence topped with barbed wire (equivalent to that which is presently in place around
part of the area) should enclose and secure the entire deed-restriction area. This is made
particularly necessary by the rural nature of the area, which attracts numerous recreational
trespassers on motorized vehicles (dirt bikes, 4-wheelers, etc.) which can readily breach a 1-foot
soil cap. Please be aware that on a summer weekend, it is common for there to be sufficient
such activity that a heavy cloud of dust hangs over the surrounding area; if that dust happens to
be contaminated, it doesn't require great imagination to suppose that not only the trespassers,
but residents and others could be exposed to not only dermal contact, but also breathing and
ingesting the dust, not to mention the airborn transport of the contamination to other
uncontaminated areas.
"5. I do not believe that the proposed amendment addresses in any way the potential
contamination of wildlife ... which could subsequently enter and climb the food chain.
"6. Perhaps most importantly, I am greatly opposed to the substantial relaxation of the
cleanup standards, particularly those for PCBs and Dieldrin in the soil, and also for VOCs in
both the soil and in the groundwater. I am especially opposed to the proposed provision for use
of soil with a residual PCB contamination level of to 5 ppm (500% of the Michigan Part 201
standard for dermal contact!) as backfill in excavated areas. This effectively relaxes the cleanup
standard to 5 ppm in the upper 6 feet, and 50 ppm at all depths below 6 feet, far in excess of the
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-8-
1990 ROD or the Michigan 201 standard. I believe any treated soil which still fails to meet the
applicable standard should be disposed of off-site at an appropriate facility.
"7. As it is known that the use of soil boring for the determination of soil VOC levels is
unreliable (tending to under-report those levels), I believe that it would be prudent to obtain
more-reliable data by re-testing using the readily available method (used by U.S. EPA in
Wisconsin and other areas) of methanol extraction testing. As a minimum, this method should
be used for process checking during the soil vapor extraction procedure.
"8. ...previously published studies ...showed that PCB contamination levels at many
depths down to the water-table depth (although less than the new proposed 50 ppm level) were
subsequently greater than those levels at or near the surface. Inasmuch as they were dumped on
the surface, this indicates that considerable downward migration has taken place (and probably
continues), invalidating the premise that the PCBs are bound to the soil and cannot migrate
down to the groundwater (at this site, the indigenous soils are almost entirely sandy, with
minimal organic fines which can be capable of binding PCBs). As the mechanism for this
migration is most probably (predominantly) transport by solvents (which remain at high levels at
all depths), this fact argues strongly for most urgent attention being given to the expeditious
implementation of the soil vapor extraction procedure which was agreed to nearly eight years
age! This seems to me to be the single most effective step that could be taken to protect the
groundwater from contamination (or further contamination) not only by solvents/VOCs
themselves, but also by PCBs by greatly reducing their downward mobility.
"9. I am concerned that little is said in the proposed amendment about Dieldrin. In the
1990 ROD, it was to be remediated along with the PCBs by incineration. Considering the huge
reduction in the volume of soil to be treated, together with the lack of information presented
regarding the effectiveness of the alternative technologies in eliminating Dieldrin contamination.
I feel that this issue requires greater attention.
"I believe the soil vapor extraction procedure as already agreed to could be implemented
immediately, which would reduce the immediacy of the need to settle on and to implement either
incineration or an acceptable alternative to remediate soil contamination with SVOCs and
metals...."
Response 6A:
1. The alternate PCB-treatment technologies will adequately remediate both PCBs and
Dieldrin. U.S. EPA acknowledges that their efficacy for treatment of Dieldrin contamination
was not mentioned in the fact sheet. U.S. EPA will place the Superfund Engineering Bulletin
entitled "Separation/Concentration Technology Alternatives for the Remediation of Pesticide-
Contaminated Soil" (May 1997) in the Site information repository for the commenter. U.S.
EPA examined various treatment technologies for cleanup of pesticides in soil and the three
technologies proposed for use at the Site to cleanup PCBs are also recommended for use to clean
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-9-
up pesticide-contaminated soils. The recommendations are based on pilot testing of soils
derived from cleanup sites around the country and containing dieldrin as a contaminant of
concern. Efficiency of removal ranged from 86-91 % for soil washing to greater than 99.95%
for a solvent extraction method. A low temperature thermal desorption unit was tested on soils
containing DDT and showed an effective removal rate of 90-99% of that pesticide.
2. The institutional controls proposed for this ROD Amendment (i.e., the deed
restrictions, cover and fence maintenance provisions), are an integral part of this remedy since
contamination will be left on-site. Superfund does not provide private citizens with the explicit
enforcement authority which this commenter requests. To ensure that these activities are
implemented, U.S. EPA is provided with authority under Superfund to either issue an
Administrative Order (AO) or enter into a Consent Decree with the responsible parties to effect
these activities. Both the AO and the Consent Decree may be enforced through judicial
proceedings if the responsible parties fail to complete the required activities under either an
issued AO or agreed-upon Consent Decree. Additionally, prior to entry of a Consent Decree the
public is provided with the opportunity to comment on the provisions of the Consent Decree.
If after issuance of an AO or entry of a Consent Decree the citizens in the area detect
violations of the deed restrictions, as embodied in either of these documents, they should report
such violations to U.S. EPA for investigation. U.S. EPA then may proceed with the appropriate
enforcement action as authorized by Superfund. If the citizens believe that the violations have
not been resolved or that U.S. EPA's actions are inadequate, then they have the ability to file a
citizen's suit pursuant to Section 310 of Superfund (42 U.S.C. 9659). Consequently, U.S. EPA
does not believe that the ROD amendment or the deed restriction need to be strengthened to
explicitly allow for private citizen enforcement.
In the event that U.S. EPA wished to modify these requirements in the future, then both
Superfund and the National Oil and Hazardous Substances Contingency Plan (NCP) would
require U.S. EPA, at a minimum, to issue either an Explanation of Significant Differences
(ESD) or another ROD Amendment. Both the ESD and ROD Amendment provide the public,
including adjacent property owners, with notice of the proposed modification and an opportunity
to provide comments on them. Consequently, U.S. EPA believes that adjacent property owners
will be provided with adequate notice required by Superfund and the NCP prior to a deed
restriction modification such as hypothesized by the commenter.
3. The cleanup standards for residual compounds in the soil at the site, whether beneath
the soil cap or not, are set to protect groundwater quality. That is, the residual levels would be
expected to leach, but at levels that would not cause the groundwater quality standards to be
exceeded. The soil cover is intended to prevent casual contact with treatment residuals. The
RCRA-type cap as suggested in the comment is excessive for prevention of casual dermal
contact of PCBs in the soil. Prevention of leaching is not a goal at this site since the soil vapor
extraction remedy will remove solvents that would tend to mobilize PCBs.
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-10-
4. It is not necessary to enclose the entire deed restricted area with a fence if cleanup
standards have been met in the soils. The soil cover is the only area that would need to be
protected from casual trespass since the soil cover would be placed to protect against dermal
contact of treatment residuals. Adjacent property owners need to restrict access to their own
properties against recreational trespassers on motorized vehicles on their properties. The site
fence will prevent vehicular trespass on the soil cover. U.S. EPA agrees that contaminated dust
clouds would be a concern; fortunately that is not the case here as contamination has only been
found in areas already delineated in the remedial investigation and other reports.
5. The cleanup standards take into account ecological receptors. The soil cover will help
prevent exposure to residual levels and prevent potential contamination of wildlife and
subsequent food chain considerations.
t
6. U.S. EPA disagrees with the term "substantial" as a decription of the change in
certain cleanup standards. From a percentage basis, a change from 1 ppm to 5 ppm is a large
percentage increase, but the effect is not nearly so dramatic in terms of risk. For example,-
changing the cleanup standard for TCE in groundwater from 3 ppb to 5 ppb is a 67% increase in
the standard but is still well within the target risk range (10-4 to 10-6) for Superfund cleanups
(3 ppb of TCE equates to a 1x10-6 risk for long term use of the water as a drinking water
source, 5 ppb TCE would equate to a 1.6x10-6 risk). The PCB cleanup level remains at 1 ppm
as described in a previous response to comments. The cleanup level is not 5 ppm, so no 400%
increase occurs. Although 5 ppm may be used as backfill, the relative risk is decreased by an
order of magnitude by the presence of the soil cover over the treated residuals. The 50 ppm
standard for PCBs below 6 feet, when coupled with the other remedial actions proposed for the
site is protective of human health and the environment, was set due to concerns regarding short
term effectiveness and site logistical reasons as well as cost effectiveness. Finally, treated soil
which fails to meet the 5 ppm residual standard for placement beneath the soil cover may be
disposed of off-site at an appropriate facility, should the PRP group choose to do so.
7. The commenter does not indicate what the purpose of the additional sampling would
accomplish. From a practical perspective, assuming the commenter is suggesting that higher
VOC concentrations might be found, delaying implementation of the cleanup to re-test for soil
VOC levels would be imprudent. The data we have is reliable, and it is reliable enough to have
caused a remedy to be chosen (soil vapor extraction) and scheduled for implementation. Further
delay is not warranted and would lead to the possibility of additional VOCs being leached into
the water table. Additionally, the soil vapor extraction component of the remedy was not
proposed for revision and thus is not open to modification at this time. U.S. EPA may consider
the use of methanol extraction testing following completion of the soil vapor extraction cleanup
remedy when soil sampling is performed to ensure that the cleanup has met soil cleanup levels.
8. U.S. EPA believes that the soil vapor extraction procedure is an important step in the
cleanup at the Site; however, the proper sequence would be to implement it after the surface
soils have been cleaned up to protective levels. The surface soils present greater potential risks
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-11-
to receptors in relation to the subsurface soils based upon dermal contact or ingestion; thus, it
would be prudent to take care of these risks first.
Additionally, it is more efficient to treat the PCB-laden soil first before installing the soil
vapor extraction remedy because some of the excavated soils for PCB treatment may contain
VOCs that can be removed as well. PCB contamination at depth is due to the co-disposal of
solvents that leach them down towards the water table. Once the solvents are removed by soil
vapor extraction, based on the PCB leaching tests, it is not anticipated that PCBs at levels of
50 ppm or less will leach into the groundwater at levels above groundwater standards. Without
the actions of solvents, the PCBs will bind to the soils despite the relative absence of organic
fines and therefore not leach into the water table above standards. U.S. EPA agrees that the
expeditious implementation of the soil vapor extraction procedure is warranted upon completion
of the PCB cleanup step. ,
9. The PCB-treatment technologies will reduce Dieldrin levels to below the soil cleanup
level and the treatment concentrates containing PCBs, Dieldrin, and other compounds will be
properly disposed of off-site.
U.S. EPA believes that the soil vapor extraction procedure is an important step in the
cleanup at the Site; however, the proper sequence would be to implement it after the surface
soils have been cleaned up to protective levels. The surface soils present greater potential risks
to receptors in relation to the subsurface soils based upon dermal contact or ingestion, thus, it
would be prudent to take care of these risks first.
Comment 7A: Dave Dempsey, Policy Director, Michigan Environmental Counsel, Lansing, MI
"We are concerned that the proposed amendment leaves in place an unacceptable level of
PCB contamination in soils. The effective cleanup levels of 5 ppm in the upper six feet of soil
and 50 ppm below that level are inconsistent with the previous ROD and good public health
practice. We support requiring cleanup to levels that are consistent with the previous ROD or
the Michigan Pan 201 standard.
"The one foot of capping required in the proposed amendment is simply inadequate.
This will permit penetration by rainwater and animals. An adequate cap would require three
feet of clay for impermeability and an additional one foot of sand or gravel, and capped by the
proposed foot of clean soil.
"We are also concerned about long term security of the site in accordance with the
amendment. The area must be secured to prevent access by motorized recreational vehicles and
other visitors. This requires a chain link fence and barbed wire around the entire site.
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-12-
"As an altenative to your agency's proposal, we support implementation of the soil vapor
extraction method at once. This cost-effective remediation can be conducted while the issues
we've raised above are further explored."
Response 7A:
See responses to comments 6A, above. There is no need to fence the entire Nickson
property based on contamination being found primarily in the currently fenced area.
Comment 8A: Nancy Strole, Clerk, Charter Township of Springfield, Davisburg, MI
"I want to reiterate that I support the remedy proposed by U.S. E PA.
I
"At the public meeting held by U.S. EPA on April 2, an adjacent property
owner...expressed concern that the integrity of the cap would be breached by soil erosion, by
burrowing animals, or by other naturally-occurring, non-human events. I believe ...that her
concern will be addressed by the following: (1) the remedy will require that the PRPs regularly
inspect and maintain the cap and fence. A quarterly inspection schedule will assure that any
breaches of the cap will be quickly discovered and fixed; (2) potential soil erosion problems
would be minimized by the final grading plan, which will require a fairly level grade in the
restricted area; (3) depending on the technology selected for treatment of PCBs, the remedy
could result in 15-20% of excavated soils being removed for off-site disposal. These soils will
have to be replaced on site by clean fill. As a result, it's likely that portions of the site will
exceed the required minimum of one foot of clean soils and will further reduce the possibility of
exposure to contaminants beneath the cap."
Response 8A:
U.S. EPA agrees with the above analysis regarding the soil cover area of the Site.
B. Oral
Comment IB: Chip Acey, Springfield Township. MI
"...It's taken 20 years to get to this point, and I don't think really it's going to satisfy
everyone, but at some point we just have to bite the bullet and let this thing go forward
and get the .... job done."
Comment 2B: Steve Ausum, Springfield Township, MI
"....I stand in support of the site cleanup, and I would like to see it implemented as soon
as possible."
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-13-
Comment 3B: Mary Oosterhof, Springfield Township, MI
"...I support what has been done and appreciate all the actions that have taken place....!
would like to see things move forward on the project."
Comment 4B: Doug McGinnis, Springfield Township, MI
"I support what has been proposed here tonight, and I just ... got the feeling that the
sooner you can start on this project the better opportunity of seeing the land being put in the best
possible condition, that the longer you wait to do any of this work it's just going to be more
difficult to clean up the land and it's not going to benefit to waste any more time."
Comment SB: Dave Hopper, Springfield Township, MI ,
"...I fought through this long and hard and I echo the sentiments [support for the ROD
Amendment] said earlier."
Comment 6B: Jim Carlton, Springfield Township, MI
"...I support this also. I think it's a doable thing."
Comment 7B: Mark Heringhausen, Springfield Township, MI
"...I support it [ROD Amendment] a hundred percent, and I would really like to see it
move forward and be taken care of and we can all put it behind us and move on..."
Responses IB through 7B:
U.S. EPA acknowledges and appreciates the support in this matter.
Comment 8B: Don Balkwell, West Bloomfield, MI
"I have a couple of reservations. The primary one has to do with restriction of access to
the Site after cleanup is finished, and I would like to see that addressed in some manner, fencing
is what comes to mind of the entire 500 feet area of deed restriction. And also I would like to
see some way of permitting ordinary citizens to do something to enforce the deed restrictions if
for any reason the other parties to the agreement don't."
Response 8B:
The area of the Site to be capped with a 1-foot soil layer will be fenced to restrict casual
access; however, this area may not entirely coincide with the entire 500-foot parcel subject to
deed restrictions. It is not necessary to restrict the property owner's access to uncontaminated
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-14-
portions of her property. Adjacent property owners must do their part to restrict trespassing on
the adjacent properties, which will in turn farther restrict access to the soil cover area.
See response to written comment 6A.2 regarding the issue of citizen's enforcement of the
deed restrictions.
Comment 9B; Cynthia Balkwell, West Bloomfield, MI
"I have concerns about using only one foot of soil as top covering."
Response 9B:
One foot of clean soil will be adequate to prevent casual access to the treatment residuals
backfilled beneath the soil cover. Periodic inspection and maintenance will preserve the
effectiveness of the soil cover. (See also the response to the written comments regarding this
same point.)
Comment 10B: Tom Middleton, State Representative
"There's been concern about people getting into that fenced-in area. ...either put wild
raspberries in that area or poison ivy. That would keep them out."
Response 10B:
Thank you for the idea, but wild raspberries (thorns) or poison ivy may cause concern to
those charged with periodic inspection and maintenance of the soil cover, as well as to the
property owner.
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD FOR THE RECORD OF DECISION AMENDMENT
FOR
SPRINGFIELD TOWNSHIP DUMP SITE
SPRINGFIELD TOWNSHIP, OAKLAND COUNTY, MICHIGAN
UPDATE #1
JUNE 23, 1998
NO. DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
05/00/95
U.S. EPA/
RREL
U.S. EPA
05/00/97
03/18/98
03/21/98
04/02/98
04/10/98
U.S. EPA/
OERR
U.S. EPA
U.S. EPA
Public
Charter
Township of
Springfield
Hill, S..
U.S. EPA
Merrill &
Associates,
Inc.
Strole. N.,
Charter
Township of
Springfield
US. EPA
Hill, S.,
U.S. EPA
Project Summary: Removal 7
ofPCBs from Contaminated
Soil Using the CF Systems
Solvent Extraction
Process: A Treatability
Study (EPA/540/SR-95/
505)
Engineering Bulletin
Separation/Concentration
Technology Alternatives
for the Remediation of
Pesticide-Contaminated
Soil (EPA/540/S-97/503)
Public Notice: Announce- 1
ment of April 2, 1998
Public Meeting and the
March 26-April 27. 1998
Public Comment Period on
the Proposed Plan for the
ROD Amendment for the
Springfield Township Dump
Site
Letter Forwarding
Attached March 21. 1998
Newspaper Article: Local
Dump Site Targeted as a
Priority on Federal
Cleanup List (Oakland
Press)
Transcript of Public 85
Hearing re: the Proposed
Plan for the ROD Amend-
ment for the Springfield
Township Dump Site
Letter Forwarding
Attached April 9, 1998
Springfield Township
Board's Resolution re:
the Proposed Record of
Decision Amendment for
Springfield Township
Dump Site
-------
NO. DATE
7 04/27/98
8 04/27/98
9 04/27/98
10 04/29/98
AUTHOR
Concerned
Citizens
Lendle King.
G., Friends
of Rose
Township
Strole, N..
Charter
Township of
Springfield
Dempsey, D.,
Michigan
Environmental
Council
RECIPIENT
Hill. S..
U.S. EPA
Hill, S.,
U.S. EPA
Hill. S.,
U.S. EPA
Hill. S.,
U.S. EPA
Springfield Township
ROD Amendme
Upda
Pa
TITLE/DESCRIPTION
Five Public Comment
Letters re: the Proposed
Record of Decision
Amendment for the
Springfield Township
Dump Site Received
March 19-April27. 1998
Letter re: Comments on 1
the Proposed Record of
Decision Amendment for
the Springfield Township
Dump Site
Letter re: Comments on 3
the Proposed Record of
Decision Amendment for
the Springfield Township
Dump Site
Letter re: MEC's Comments 1
on the Proposed Record
of Decision Amendment
for the Springfield
Township Dump Site
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD FOR THE RECORD OF DECISION AMENDMENT
FOR
SPRINGFIELD TOWNSHIP DUMP SITE
SPRINGFIELD TOWNSHIP, OAKLAND COUNTY, MICHIGAN
UPDATE#2
JULY 27, 1998
NO. DATE AUTHOR
1 06/10/98 U.S. EPA
2 07/23/98 Clarizio, R.,
U.S. EPA
RECIPIENT
Public
Lerminiaux.
K.; Dickinson.
Wright, Moon.
Van Dusen &
Freeman
TITLE/DESCRIPTION
Record ofDecisior
Amendment for the
Springfield Township
Dump Site
Letter Forwarding the
Record of Decision
Amendment and U.S. EPA
Administrative Record
Indexes for Updates #1
and #2 for the Spring-
field Township Dump
Site
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