PB98-963122
                               EPA 541-R98-101
                               November 1998
EPA Superfund
      Record of Decision Amendment:
      Ott/Story/Cordova Chemical Co.
      Dalton Township, MI
      2/26/1998

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     DECLARATION FOR  THE AMENDMENT  TO THE RECpRD  OF DECISION

SITE NAME AND LOCATION

Ott/Story/Cordova Site
North Muskegon,  Michigan

PURPOSE

This decision document presents the amendment to  the Record  of
Decision  (ROD) for Operable Unit  (O.U.) #3 at the Ott/Story/
Cordova Site  (the "Site") in Muskegon, MI, 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 the
National Contingency  Plan  (NCP).

BAS_IS_

The decision to amend the ROD is based upon the Administrative
Record.  Indexes  attached to this ROD Amendment identify items
that comprise the latest updates to the Administrative Record
upon which the amendment of the O.U. #3 Remedial Action is based.

DESCRIPTION OF THE AMENDMENT

On September 27,   1993 a ROD was signed for the O.U.  #3 Remedial
Action choosing Low Temperature Thermal Desorption  (LTTD) to
treat contaminated plant area soils and sediments in  Little  Bear
Creek and its unnamed tributary.   The remedy required excavation
and LTTD treatment of contaminated soils/sediments, backfilling
of adequately treated soils, and off-Site disposal of residue not
attaining acceptable cleanup criteria.   That Remedial Action was
consistent with the previous two remedies selected for the Site.

This amendment to the ROD:
     eliminates LTTD from the remedy,
     revises the volume of soils to be remediated by  excavation
     and off-site disposal as a result of an understanding that
     the land use for the site will remain industrial instead of
     residential as provided for in the 1993 ROD;
     requires regular sampling of surface water and sediments to
     determine the need for remedial action in the Little Bear
     Creek,  and
     requires deed restrictions to insure that use of the site
     remains industrial.

This ROD amendment is being issued to reflect new information
concerning the reasonably anticipated future land use of the
site,  which,  in turn,  affects the level of risk estimated as  a
result of site contamination.   In addition,  the State of Michigan
revised its cleanup levels in 1995,  which resulted in a reduction
in the volume of soil requiring remediation at the Site.

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Finally, based on information acquired after _the 1993 ROD, U.S.
EPA believes that a high potential for re-contamination of
treated soils by contaminated groundwater would remain under the
original remedy, thereby calling into question the effectiveness
of on-Site disposal.  After evaluating remediation goals of the
OU#3 ROD and reasonable future land use, U.S. EPA believes it is
more feasible to restore the Site for future industrial or
commercial use rather than residential.

The goal of this amended remedy is to eliminate the primary human
health risks posed by direct contact with contaminated soils, to
eliminate the threat to the environment, and to reduce pump and
treat activity by removing the groundwater contamination source
embodied by O.U. #3 soils.  This amendment to the O.U. #3 is
consistent with past Remedial Actions and is expected to be
consistent with potential future Remedial Action.

STATUTORY DETERMINATIONS

This amended remedy is protective of human health and the
environment,  complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
Remedial Action, and is cost effective.  Because soil
constituting the primary risk at the Site does not contain
principal threat waste, this remedy does not require treatment.
This remedy will result in hazardous substances remaining on
Site,  requiring a review every five years after the start of
Remedial Action to assure that the selected remedy remains
protective of human health and the environment.

The State of Michigan concurs with the amended remedy put forth
in this document.
     Date                          William E.Munto//Director
                                      Superfund Division

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 DECISION  SUMMARY FOR  THE AMENDMENT TO THE RECORD OF DECISION FOR
     OPERABLE UNIT #3  OF THE OTT/STORY/CORDOVA SUPERFUND SITE
                          MUSKEGON, MICHIGAN
                           TABLE OF CONTENTS             PAGE NUMBER
 I.    INTRODUCTION                                                 3
 A.    Site  History                                                 4
 B.    Summary of  Site  Contaminants                                  5
      1.    Plant Area Soils                                        5
      2.    Sediments                                               5
      3.    Comparison to Acceptable State Standards                6
 C.    Summary of  Site  Risks                                         6

 II.   REASONS FOR ISSUING  THE  ROD AMENDMENT                         7
A.    Steps Taken to Implement The  Original Remedy                 7
B.    Supporting  Information for The Fundamental Change             9
      1.    Shallow Depth of Groundwater                            9
      2.    Increase in LTTD Cost Estimates                        10
      3.    Changes to Land Use and State of  Michigan
                 Cleanup Standards                                 10
      4.    Decrease in Creek Contaminants Due to O.U.  #1 and #2
                 Operation                                         10

III.  SELECTION AND DESCRIPTION OF  THE FUNDAMENTAL CHANGE          11
A.    Plant Area  Soils - The Fundamental  Change                    12
B.    Capping and 'Post-Excavation1  Fill                           15
C.    Sediments                                                    16
D.    Deed  Restrictions                                            17

IV.   NINE  CRITERIA EVALUATION OF THE REMEDY CHANGE                17
A.    The Nine Criteria                                            17
B.    Nine  Criteria Analysis of the  Preferred Amended Remedy       18
      THRESHOLD CRITERIA
      1.    Overall Protection  of Human Health and  the
                 Environment                                       18
      2.    Compliance  With ARARs                                  19
      PRIMARY BALANCING CRITERIA
      3.    Long Term Effectiveness  and Permanence                  20
      4.    Reduction of  Toxicity,  Mobility,  or Volume
                 Through Treatment                                 20
      5.    Short  Term Effectiveness                               21
      6.    Implementability                                       22
      7.    Cost                                                   23
      MODIFYING CRITERIA
      8.    State  Acceptance                                       24
      9.    Community Acceptance                                   24

V.    STATUTORY DETERMINATIONS                                    24

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                 LIST OF FIGURES.,  TABLES.  AND APPEJTOICES
                                                           PAGE NUMBER
FIGURE  1  -  COUNTY  LOCATION OF  SITE                                 F-l
FIGURE  2  -  LOCAL LOCATION OF SITE                                  F-2
FIGURE  3  -  PROPOSED  LTTD EXCAVATION AREAS                          F-3
FIGURE  4  -  SEDIMENT  SAMPLING LOCATIONS                              F-4
FIGURE  5  -  REVISED EXCAVATION  AREAS FOR  OFF-SITE DISPOSAL          F-5

TABLE 1 - CONTAMINANT CONCENTRATIONS - O.U.  #3
                 (PLANT AREA) .SOILS                   T-la through T-lg

TABLE 2 - CONTAMINANT CONCENTRATIONS - SEDIMENTS IN LITTLE BEAR
                 CREEK AND ITS  UNNAMED TRIBUTARY               T-2a,b,c

TABLE 3 - EXCEEDANCE OF SOIL CLEANUP STANDARDS FOR OTT/STORY/CORDOVA
                 O.U. #3 PLANT  AREA SOILS             T-3a through T-3e

TABLE 4 - RISKS  ASSOCIATED WITH OTT/STORY/CORDOVA PLANT AREA SOILS
                 AND  LITTLE BEAR CREEK SYSTEM                    T-4.1
TABLE 4A  -       Current Resident  and Trespasser                 T-4A.1
TABLE 4B  -       Future Worker                                    T-4B.1
TABLE 4C  -       Future Construction Worker                      T-4C.1
TABLE 4D  -       Future Maintenance Worker                       T-4D.1
TABLE 4E  -       Future Resident                                 T-4E.1

TABLE 5A  - HISTORICAL COMPARISON  OF LITTLE BEAR CREEK
                 SEDIMENT CONTAMINATION AT LOCATIONS 15 TO 34  T-5A.1,2

TABLE 5B  - HISTORICAL COMPARISON  OF LITTLE BEAR CREEK WATER
                 CONTAMINATION                                    T-5B.1

TABLE 6 - COMPARISON OF ORIGINAL  REMEDY ALTERNATIVES AS
                 CITED IN ORIGINAL O.U. #3 ROD                      T-6

TABLE 7 - ESTIMATED  COST BASED ON WORST CASE  EXCAVATION DEPTH AND
                 OFF-SITE DISPOSAL FOR THE AMENDED
                 O.U. #3 REMEDY                                 T-7a,7b

TABLE 8 - O&M COST ESTIMATE FOR O.U.  #3 AMENDED REMEDY         T-8/9.1

TABLE 9 - PRESENT WORTH CALCULATION FOR O.U.  #3 AMENDED REMEDY T-8/9.1

TABLE 9A  - PRESENT WORTH FORMULA                               T-8/9A.2

APPENDIX A - DISCUSSION OF ARARS                        A-l through A-10
APPENDIX B - RESPONSIVENESS SUMMARY  ,                  B-l through B-9

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                                       THE RECORD OF PI
     PPERABLE UNIT #3 OF THE OTT/STORY/CORDOVA SUPERFUND SITE
                        MUSKEGON. MICHIGAN


I.   INTRODUCTION

The  purpose of this document is to explain fundamental  changes  in
the  Remedial Action  (RA) selected by the U.S. Environmental
Protection Agency  (U.S. EPA) in the Record of Decision  (ROD)
signed on September 23, 1993 for Operable Unit  (O.U.)  #3  for  the
Ott/Story/Cordova Site  (the "Site") located at 500 Agard  Road,
Dalton Township, Muskegon County, Michigan (see Figures 1 and 2).
The  former production area, where the majority of the
contaminated soils to be remediated are located, is approximately
20 acres in size and surrounded by wooded land and a rural
residential area.  Little Bear Creek (the "Creek") and  its
unnamed tributary are located about one-half mile east  of the
Site  (see Figure 2).

U.S. EPA has re-evaluated O.U. #3 remediation goals and considers
it reasonable to restore the Site to a level of protectiveness
acceptable for industrial land use, which is the current  land use
at the Site.  It is also reasonable to expect that future land
use will continue to be industrial.  Also, after the O.U. #3  ROD
was signed,  the State of Michigan  (the "State") issued revised
environmental statutes and cleanup standards in keeping with
reasonable future land use that resulted in a reduction of soil
requiring remediation.  These considerations have allowed for a
reduction in the volume of soils to be addressed by this remedy.
The presence of the compound Dioxin in some Site soils precluded
treatment in the LTTD unit based on concerns with air quality,
further reducing the viability of the previously selected remedy.
Finally,  U.S. EPA believes that a high potential for re-
contamination of treated soils by contaminated groundwater would
occur under the original remedy,  thereby calling into question
the effectiveness of LTTD and subsequent on-Site disposal of
treated materials.

Under CERCLA § 117 and Section 300.435(c) (2) (ii) of the National
Contingency Plan (NCP), the lead agency is required to propose an
amendment to the ROD  ("ROD Amendment")  and allow the public the
opportunity to comment on the proposed changes if differences in
the remedial action alter the basic features of the ROD.  A
public meeting for the original ROD was held on April 20,  1993.
A notice of availability of the administrative record and new
proposed plan for this ROD Amendment was published in the
Muskegon Chronicle on May 27,  1997, commencing a public comment
period from May 27 through June 25, 1997.   In addition, a public
meeting to discuss the new proposed plan was held on June 3,  1997
at the Dalton Township Hall.  U.S.  EPA responses to comments

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received during this period and from the meeting are contained  in
a Responsiveness Summary, attached to this ROD Amendment.

This ROD Amendment and all other Site related documents are part
of the Administrative Record File which is available for public
inspection at the following locations:

Walker Branch Library         Dalton Township Hall
1522 Ruddiman Drive           1616 East Riley Thompson Road
Muskegon, Michigan            Dalton, Michigan

The Administrative Record may also be reviewed at:

               U.S. EPA Region 5
               77 West Jackson Boulevard
               Chicago, Illinois

The lead agency for the remedial action at this site is the U.S.
EPA.  The State of Michigan Department of Environmental Quality
(MDEQ) is the support agency.  The Agencies encourage the public
to review these and other documents to gain a better
understanding of the Site.

This ROD Amendment provides an updated list of soil cleanup
criteria, discusses the extent of plant area and sediment
contamination at the Site, the scope of necessary excavation
activity, and several options (including cost) for off-Site
disposal.  This is followed by a description of the amended
remedy and an analysis of how the proposed new remedy meets the
statutory criteria provided in Section 121 of CERCLA.

A.   Site History

The Ott/Story/Cordova Superfund site is a former organic chemical
production facility that operated under a series of owners from
1957 until 1985.  Unlined seepage lagoons were used during many
years of site operations for disposal of both industrial
wastewaters and residuals from chemical production vessel
cleanout.  These disposal practices resulted in contamination of:
an aquifer below and downgradient of the Site, Site soils, and
nearby Little Bear Creek and its unnamed tributary.  In addition,
thousands of drums of waste material, some of which contained
phosgene gas in pressurized containers,  were stockpiled on-Site.

A partial removal was conducted between 1977 and 1979 by MDEQ
(then the Michigan Department of Natural Resources, or MDNR),
with the assistance of the new and present Site owner Cordova
Chemical Company.  These activities included the removal of
stockpiled drums and thousands of cubic yards of contaminated
soils and sludge.  By the time of the removal, a contaminant
plume containing at least 40 organic chemicals had migrated

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approximately one mile off -site to the southeast , contaminating
Little Bear Creek, an unnamed tributary, and several private
wells.  Residents were supplied with bottled water until a
municipal water system was installed.

The Site was placed on the National Priorities List  (NPL) in 1982
and U.S. EPA completed a Remedial Investigation and Feasibility
Study  (RI/FS) in 1990.  A ROD for O.U. #1 signed on September 29,
1989 and affirmed on March 3, 1990, specified Site groundwater
containment by extraction to prevent groundwater discharge to the
Creek.  A ROD for O.U. #2 was signed on September 29, 1990 and
required restoration of the aquifer through additional extraction
and treatment by a Groundwater Treatment Plant (GWTP) .  On
September 27, 1993, U.S. EPA signed the third ROD selecting LTTD
as the remedy for contaminated soils and sediment at the Site.
U.S. EPA, using an Interagency Agreement, contracted with the
U.S. Army Corps of Engineers (USAGE)  to design and construct all
three operable units.  GWTP construction was substantially
complete in August 1996 and is currently operating and meeting
all effluent discharge standards.

This ROD Amendment modifies the O.U.  #3 ROD by eliminating LTTD
as a treatment remedy for the Site based on information from
initial attempts at LTTD implementation, the USACE Remedial
Design (RD)  for the LTTD remedy,, subsequent technical documents
summarizing additional sampling and analysis, and the RI/FS for
the Site.  Information contained in these documents indicates
that LTTD will not be a cost effective remedy due to the reduced
volume of soils to be treated,  the increases in post-ROD cost
estimates,  modification of Site cleanup standards due to re-
evaluation of future land use and associated remediation goals,
and the potential for re-contamination of treated soils by
contaminated groundwater that would occur.
B .    Sunun9-r"y of site
           Area Soils:  Table 1 shows the type and maximum
     concentrations of contaminants discovered in O.U. #3 soil
     (Figure 3) by excavation area (noted as Areas A through S) ,
     and lists current cleanup standards in State law.  Values
     shown in columns A through S represent the maximum
     concentration of contaminant that was discovered during Site
     studies, including RI/FS, RD, and other post-ROD sampling
     and analyses.  As shown, all O.U. #3 excavation areas showed
     some Site-related contamination.

2.   Sediments ;  Although not included in the RD for the LTTD
     remedy, the 1993 ROD allowed for excavation and treatment of
     Creek sediments with plant area soils.  Table 2 shows the
     type and maximum concentration of contaminants discovered in
     the sediments of Little Bear Creek and its unnamed tributary

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     (Figure 4), and the State of Michigan Residential Direct
     Contact Values for soils.  Although these soils direct
     contact values do not represent sediment cleanup standards
     they have been included for comparison purposes only and
     provide a gauge as to what may constitute a contaminant
     level unacceptable to an individual inadvertently exposed to
     the Creek.  These standards are being referenced because
     definitive sediment standards have yet to be established.

     A review of sediment contamination information by MDEQ
     Surface Water Quality Division personnel resulted in a
     recommendation to monitor the Creek and Creek sediment.
     Although the O.U. #3 ROD allowed the possibility of
     excavation and treatment of sediments, a final determination
     has not been made regarding the requirement for sediment
     removal.  To that end,  the LTTD Remedial Design did not
     include any excavation in the Creek area.

     Comparison to Acceptable State Standards:  Table 3 presents
     a summary of O.U. #3 soils that in 1988 and/or 1992 have
     been shown to be contaminated at concentrations in
     exceedance of current State standards.  Areas that have
     shown exceedances based on historical data are Areas A, B,
     F,  G, I, K, L,  M, O, P,  Q, and R.   Results of subsequent
     sampling in 1994, 1995,  and 1996 indicate that all areas
     except R have either no detections or detections at
     concentrations below acceptable State standards.  In
     addition,  Area G presented ecological risk by exhibiting
     highly toxic effects when subjected to biological testing.
     All information shown in Table 3 has been summarized in a
     document entitled "Technical Memorandum for Soil and
     Sediment at the Ott /Story/Cordova Superfund Site" dated
     April 1997.  Data shown in Table 3 from more recent sampling
     and analysis events supersede historical data.
C .    SuBBMry of Site Risks

Table 4 summarizes all risks associated with O.U.  #3 soils and
sed_...ents calculated for the O.U.  #3 ROD.   This ROD Amendment,
however, requires a level of protectiveness for future industrial
use for plant area soils and future residential use for the
sediments of Little Bear Creek and its unnamed tributary, in
accordance with reasonable future  land use for the Site.   Tables
4A through 4D are risk summaries consistent with future
industrial, commercial, and residential users of the Site.  These
values take into account exposure  to contaminated soils,
sediments, surface water, air and  groundwater.  Residential risk
values are included to demonstrate that unacceptable O.U. #3 risk
is not attributable to Creek sediments.  Current zoning of the
Site, deed restrictions, and Site  security will increase the

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likelihood that future exposure to the Site will only be through
a controlled industrial scenario.

When the Hazard Index  (HI) is greater than l, there is a
potential for health problems such as damage to vital organs,
birth defects, and anemia and other blood disorders.  A ixlCT6
cancer risk value corresponds to a 1 in 1,000,000 chance that an
individual develops cancer as a result of exposure to these
concentrations of contaminants over a period of 70 years.
Similarly, 10~5 corresponds to a 1 in 100,000 chance, 1x10"",  1  in
10,000, and so on.  Current environmental statutes allow U.S. EPA
to perform a Remedial Action if an HI is 1.0 or above and if
cancer risks exceed IxlO"4.  The State of Michigan is required to
take action at an HI of 1.0 or above and cancer risk of IxlO"5 or
greater.

As shown in Table 4, the greatest risks associated with O.U. #3
are to a future resident  (3x10""; HI of 2.4) and future worker
(1x10"") .  Consideration of all the contaminants found on-Site
results in the greatest risk to a future Site worker (1.52x10""),
a future maintenance worker (2.0x10""), and a future resident
(5.81x10"") .

Risk values shown in Table 4E consider the likelihood of a future
Site resident or visitor being exposed to both plant area soils
and/or Creek water and sediments.  As shown, unacceptable risk
(HI of 1.44)  exists for a resident due to the compound 4,4'-DDT.
This compound, however, has not been detected in recent Creek
sediment and surface water sampling (December 1996, March 1997).

Site specific leachability testing of soils (which is discussed
in more detail on page 12 and 13 of this document) indicate that
soil contaminants in some areas of the Site present an
unacceptable risk due to the potential to migrate to groundwater.
In addition,  toxicity testing suggests these contaminants present
an adverse ecological impact (i.e.,  the lack of vegetation).

II.  REASONS FOR ISSUING THE ROD AMENDMENT

A.   Steps Taken to Implement the Current Remedy

The O.U. #3 ROD selected LTTD as the remedy for contaminated Site
soils and sediments at the Site.  An LTTD unit was to be situated
on-Site to thermally treat excavated contaminated soils and
sediments.  Treated soil and other LTTD residue with
contamination exceeding acceptable State of Michigan standards
would have been disposed of off-Site in a licensed landfill and
acceptably treated soils would have been used as back-fill in
excavated areas.

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In February 1994, approximately five  (5) months after the O.U.  #3
ROD was issued, USAGE began the O.U. #3 Remecfial Design to
determine locations, areas, and depths of soils and sediments  to
be excavated and treated.  In addition, the RD would provide LTTD
treatability characteristics by quantifying types and
concentration of contaminants in soils.  In April 1995, the 30%
Design  (Pre-Design) Report was issued which delineated those
areas of the Site requiring excavation.

Concurrent with development of the RD in early 1995, the decision
was made by U.S. EPA to have USAGE utilize the Rapid/Immediate
Response Procurement Procedure,  avoiding the time-consuming
competitive acquisition process.  This decision was justified
because the U.S. Government competitive acquisition process would
delay Site construction activity for at least 1 year, due to the
length of the competitive bidding process and the resultant loss
of seasonable weather for construction.  On May 21, 1995, USAGE
provided a notice to proceed to a LTTD contractor.

In June 1995,  the State of Michigan issued changes to their
cleanup standards due to legislative amendments to Part 201 of
the Natural Resources and Environmental Protection Act (NREPA),
1994 PA 451 ("Part 201"), which governed these standards.
Shortly after,  U.S. EPA was petitioned to review the O.U. #3
remedy decision and consider the effectiveness of the LTTD
remedy.   Based upon a review of  Part 201 and consideration of
anticipated industrial future land use at the Site, the
possibility developed for a significant decrease in the volume of
soil to be treated.

The cost effectiveness of LTTD was questioned given increases
shown in post-ROD cost estimates and the fact that contaminated
groundwater could permeate treated areas during periods of
increased groundwater levels,  potentially 're-polluting'  clean
soils.  Continued expenditure for LTTD would not have been
appropriate compared to excavation and back filling without
treatment.   Potential for 're-pollution'  exists for either
alternative and it was decided to suspend the LTTD remedy in July
1995 as <-  cost _ /ing measure.

Shortly after this decision,  U.S.  EPA proceeded to reconsider the
anticipated land use for the Site and the degree of remediation
needed for all areas shown in Figure 3.  This reconsideration was
based on reasonable future land  use and the flexibility allowed
by the newly revised State of Michigan environmental law.
Additional sampling and analysis was completed to determine the
threats posed by the contaminated plant area soils.  Even though
risks attributable to O.U. #3 soils remained at levels requiring
Remedial Action, U.S. EPA compared new and historical data
(including soils leachability tests) against allowable State of
Michigan soils Direct Contact Values (cleanup standards)  and
considered the degree of additional burden that contaminated

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soils are adding to Site groundwater.  This was also consistent
with Federal and State guidance that notes the propensity for
leaching determines the risk involved with contaminated soil and
should be considered when developing remediation plans.  Because
contamination in O.U. #3 soils, hov/ever, largely remain at
concentrations identical to those at the time of the ROD, risks
as identified in Table 4 are still present, requiring Remedial
Action by U.S. EPA.

Original cleanup standards cited in the O.U.  #3 ROD were for
residential use of Site groundwater and soils.  After completion
of the RD, consideration of post-ROD sampling data, and the
relatively remote and industrial nature of the Site,  U.S. EPA
believes that soil cleanup standards consistent with future
industrial or commercial land use are more appropriate.

B.   Supporting Information For the Fundamental Change

1.   Shallow Depth of Groundwater;  Studies completed during the
     RI demonstrate that Site groundwater is present on Site at
     relatively shallow depths, ranging approximately 5 to 15
     feet below ground surface.  Soil sampling and well
     installation showed the lack of well defined stratigraphic
     layers,  resulting in similarity in material properties and
     bedding patterns throughout the depth of the groundwater
     aquifer.   No distinct aquifer confining layer was discovered
     above a depth of approximately 130 feet,  at which a bedrock
     layer is known to exist.

     In excavation areas F and G,  groundwater was discovered at a
     depth of 2.5 feet below grade during RI  soils sampling in
     March 1988.   In general,  RI activity discovered groundwater
     at depths ranging from 2  feet below grade to 5.5 feet,  in
     all Site areas depicted in Figure 3.   These shallow depths
     were confirmed when monitoring wells were installed.   In
     January 1992,  U.S.  EPA supplemented 1988-89 Site studies and
     discovered that soils were wet between 3  and 5 feet below
     grade as well as standing water in several instances.

     In October 1994 to better define excavation areas as part of
     the LTTD RD,  U.S. EPA performed additional soils sampling.
     In June and July 1995,  confirmatory sampling and analysis
     was performed by the Site owner.   By that time, these
     additional studies provided accessory groundwater depth
     information because it was fairly well known that the
     aquifer exists at average depths between 3 and 5 feet
     throughout the O.U.  #3 area.   Shallow groundwater depth may
     make excavation and back-filling of excavated areas with
     clean material counter-productive because of the high
     potential for contaminated groundwater to re-contaminate
     clean soil.

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                                       The September 1993 ROD
     cited a present worth cost (including annual operation and
     maintenance  ("O&M") costs over 30 years) of approximately
     $6,900,000 for the LTTD remedy.  The March 1995 final design
     cost estimate calculated a capital cost  (not including
     annual O&M costs) of approximately $12,200,000, not
     including excavation and treatment of sediments.
     Considering the potential for re-contamination with any
     excavation activity and the significant increase in the
     anticipated cost of LTTD, proceeding with on-Site treatment
     of soils and sediments was determined not to be cost
     effective.

3.   Changes to Land Use and State of Michigan Cleanup Standards;
     Changes to the State of Michigan cleanup standards (based on
     a reconsideration of the anticipated future land use at the
     Site) results in a decrease in the number of soil areas and
     therefore the volume of soils requiring remediation.  Several
     months after completion of the O.U.  #j LTTD RD, the State of
     Michigan promulgated new soil cleanup standards that
     provided for more flexibility in considering reasonable
     future land use than those in effect at the time of the
     O.U. #3 ROD.   Michigan Act 307 (formerly known as the
     Michigan Environmental Response Act)  was in effect for
     remedial actions at the time  of the  1993 ROD and has since
     been largely replaced by Part 201 of the Natural Resources
     and Environmental Protection  Act (NREPA^, 1994 PA 451,  as
     amended ("Part 201") .

     Part 201 requires that a remedial action achieve generic
     limited categorical cleanup standards, such as residential,
     commercial,  or industrial.  The 1993 ROD specified that the
     LTTD remedy would seek to comply with Act 307 Type B cleanup
     goals which were based on a residential human exposure risk
     of 10"6.  A major change that  resulted with the enactment of
     Part 201 is the consideration of future land use and the
     establishment of a target risk level of 10'5 for remediation
     efforts.

     Part 201 requires cleanup standards  based on future land use
     (i.e.,  more realistic exposure scenarios) instead of "worst -
     case" possibilities.   Rather  than requiring residential
     soils direct contact standards be applied to the Site
     because of> the possibility of future residential use,
     standards for future industrial land use are more
     appropriate given the industrial history of the Site and the
     current zoning of the land for industrial use.

4.   Decrease in Creek Contaminants Due To O.U.#1 & *2 Operation;
     Tables 5A and 5B provide an example  of the decrease in Creek
     contamination that has occurred since initiation of the

                                10

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     O.U. #1 and #2 groundwater extraction and treatment
     remedies.  O.U. #1 and #2 extraction wells are intended to
     intercept contaminated groundwater before reaching the
     Creek, serving to remove the source of Creek contamination.
     Pre-1996 sampling found contaminants in the Creek at levels
     below State of Michigan residential direct contact standards
     for soil.  The further reduction of these contaminants
     suggests that the O.U. #1 and #2 remedies are successful in
     inhibiting Site contamination from reaching the Creek.

     Reduction in Creek contaminants has allowed U.S. EPA to
     suspend the excavation of Creek sediments.  Implementing
     Creek excavation at this time is not recommended because
     there may be unforeseen long term intrusive effects on the
     natural Creek system.  Additional monitoring must be
     performed for U.S. EPA to effectively develop the best
     approach to management of contamination at the Creek.  This
     information is also necessary to adequately determine the
     effectiveness of the O.U. #1 and #2 system.  The groundwater
     treatment plant has not yet been able to achieve full design
     capacity, meaning Creek data to date is not quite fully
     representative.

     Suspension of sediments excavation activity at this time
     does not preclude U.S. EPA from performing any Creek
     remediation at a later date,  but may result in attenuation
     of the Creek without disturbing the natural system.

III. SELECTION AND DESCRIPTION OF THE FUNDAMENTAL CHANGE

U.S. EPA defines principal threat wastes as "...[S]ource
materials considered highly toxic or mobile that...would present
a significant risk to human health or the environment should
exposure occur."  In general,  CERCLA contains a preference for
treatment of the principal threats to the maximum extent
practicable.  Although risk attributed to direct contact with
O.U. #3 soils for industrial land use is at a level requiring
Remedial Action,  mobile or highly toxic contaminants found in
O.U. #3 soils are noc at concentrations high enough for this
material to be classified as principal threat waste.

An LTTD treatment remedy is also not cost-effective because of
the small volume of soils posing unacceptable risk from the
direct contact threat.   This volume has been reduced due to the
revised State of Michigan requirements that allow reconsideration
of anticipated land use and the associated cleanup standards for
future industrial land use.  Most O.U. #3 soils do not present
any direct contact risk or act as a source of additional
groundwater contamination.  This smaller volume of soil
reinstates the practicability of off-Site disposal alternatives.
                                11

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Table 6 summarizes remedial alternatives considered in the O.U.
#3 ROD.  Except for the  'no action' and 'institutional control1
alternatives, a common component of all these options is
excavation of the O.U. #3 soils.  Conclusions put forth in the
O.U. #3 ROD in the nine criteria alternatives analysis continue
to be valid.  The 'no action1 and 'institutional control'
alternatives  (Alts.  1 and 2) are not acceptable as they do not
provide overall protection of human health and the environment
and would not comply with ARARs.  Alternative 6 is the LTTD
remedy that was selected.

There were three alternatives discussed in the O.U. #3 ROD that
included construction of an on-Site landfill.  Alternative 3a and
3b varied only in the degree of containment determined by
landfill construction requirements for hazardous (Michigan Act
64) and non-hazardous (Michigan Act 641) wastes.  Alternative 7
required construction of an on-Site landfill, coupled with some
off-Site treatment of a limited volume cf O.U. #3 soils and
Little Bear Creek sediments.  Although these three alternatives
provided an adequate balance of the nine remedy selection
criteria,  none of them were selected due to their higher costs
when compared against the LTTD remedy.

The remaining Alternatives  (Alt's. 4 and 5) are excavation and
off-Site landfilling and incineration, respectively.  The intent
of this O.U. #3 Remedial Action is to remove the threat to human
health and the environment as quickly as possible and in the most
cost effective manner.  Given the small volume of soil containing
unacceptable risk,  the consequent impracticality of treatment,
and the ease of implementation of these disposal options, this
ROD Amendment limits its nine criteria analysis to Alternatives 4
and S .

Treatment of soils using technology other than thermal was re-
considered during the compilation of this ROD Amendment.   The
detailed analysis of available treatment technologies contained
in the FS and O.U.  #3 ROD remains valid.  They are not cost
effective for the smaller soil volume, and the potential for
post-treatment re-contamination is identical to that for any non-
treatment alternative.

A.   plant Area Soils -

In 1995, shortly after implementation of the LTTD remedy was
halted,  additional sampling and analysis of O.U. #3 soils was
performed,  including leachability and toxicity tests.  A re-
evaluation of all Site data was also performed.  It was then
determined that three contaminated soil areas of O.U. #3 may
require remediation based on high leachability potential and/or
potential risk to human health or the environment.   Table 3
summarizes the conclusions of this re-evaluation.


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Unacceptable cumulative risks calculated for a future Site worker
or future Site maintenance worker by direct contact with O.U. #3
soil is attributed to a number of contaminants (see Table 4),
some of which were historically detected in Area F.  Comparison
of historical data for Area F against current State of Michigan
20 times industrial drinking water standards suggests a potential
for contaminant exceedances of these standards.   Even though
later sampling of Area F showed no detections of Dioxin or
leaching of contaminants at unacceptable levels,  the history of
previous incineration activities in this area suggests
questionable handling and cleanup procedures and the possible
presence of contamination at levels exceeding direct contact
standards.  This warrants further characterization and possible
excavation of a portion of Area F soils.  It is anticipated that
during implementation of the amended O.U. #3 remedy, U.S. EPA
will further characterize Area F and make a final determination
as to the necessity and degree of excavation of soils in this
area.

Soils in Area G exhibited highly toxic effects when subjected to
biological testing.  As noted in Table 3, Site studies have also
shown exceedances of cleanup criteria.  Specifically, historical
data shows that current direct contact standards were exceeded
for Methoxychlor,  Endrin,  PCBs,  and the 20 times the drinking
water standard was exceeded for bis (2-ethylhexyl)  phthalate, 4-
Chloroaniline,  Aldrin, Hexachlorobenzene, and 4,4'-DDT.
Leachability testing performed in 1995, however,  showed that the
contaminants present did not exhibit any tendency to leach.  The
lack of vegetation in this area combined with the results of
biological testing suggests that remediation of this area is
necessary for protection of the environment.  In addition,  the
presence of 4,4'-DDT is a contributing factor for excavation of
Area G soils.

Samples taken from Area R showed contaminants leaching from soils
at concentrations in excess of State of Michigan industrial
groundwater protective levels.  Specifically,  20 times the
drinking water standard was exceeded for the compound
Tetrachloroethene.  Historical exceedance of .he 20 times
drinking water standard was shown for the compounds 1,1,2-
Trichloroethane,  bis  (2-ethylhexyl)  phthalate,  1,2-
Dichlorobenzene,  1,4-Dichlorobenzene,  Hexachlorobenzene,  Aldrin,
4,4'-DDT,  and Arochlor 1248 (PCBs).   Carbon Tetrachloride was
discovered at a high concentration but not confirmed by later
sampling.   The exceedance noted for Tetrachloroethene warrants
excavation of Area R.  Other contributing factors include the
discovery of drum remnants, documentation of soil and water
discoloration during sampling events in the area,  and the history
of Area R as a former drum disposal area.
                                13

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40 CFR Section 300.430  (e)(2)(I)(A) requires JU.S. EPA to
establish remediation goals based on ARARS and additional factors
including "...(4)  [F]actors related to uncertainty; and
(5)  [O]ther pertinent information."  Former incineration and
disposal activity  in Areas F and R, and specific visual
confirmation of stressed vegetation and results of Microtox
testing  (demonstrating an unacceptable threat to the environment)
in Area G are contributing factors to the decision to excavate
these areas.

Precise depths of  excavation within Areas F, G, and R and
associated soil volume to be disposed will be determined during
implementation of  the Remedial Action.  It is presumed for the
purposes of this ROD Amendment that soils will be excavated to a
minimum depth of 1 foot and a maximum not exceeding either:
     1.   the depth at which contaminant concentrations meet
          State of Michigan Direct Contact Values for industrial
          land use, as promulgated by Section 20120A(1)(D) of
          Part 201 of the Natural Resources and Environmental
          Protection Act, P.A. 451 of 1994, as amended, or
     2.   the depth at which contaminants no longer leach from
          soil at  concentrations in excess of State of Michigan
          20 times drinking water standards for industrial land
          use, or
     3.   the depth at which groundwater is present, or
     4.   (for Area R)  the depth necessary to remove any drums,
          lab debris, or other containerized wastes,
whichever is necessary.   Contaminants of concern as identified in
the 1993 ROD are shown in Table 1 as well as the cleanup criteria
the amended O.U. #3 remedy is required to meet.

Based on Site hydrogeological and analytical information to date,
the final excavation depths will not likely exceed 6 feet for any
one area, and it is anticipated that the volume of soils actually
excavated will be approximately 4,000 cubic yards (yd3).   The
1993 ROD was based on an estimate of 7,200 yd3  of  contaminated
soil to be treated.  A final determination as to the quantities
and disposal fate of excavated soils can not be made until the
mat(  ial is sampled and analyzed.  Excavated material will be
composited within each excavation area,  contained, sampled,  and
analyzed to determine the final requirements for disposal.

All excavation spoils will be disposed of in accordance with all
applicable Federal and State laws.  Because specific information
on the origins of  the contamination on Site is not available,
excavated O.U. #3  soils are not assumed to be RCRA listed waste.
However, hazardous constituents have been detected in these
soils,  suggesting  that excavated material can potentially be RCRA
characteristic waste.  If excavated material contains hazardous
constituents in excess of RCRA Land Disposal Restriction  (LDR)
treatment standards,  the soils will be treated off-Site at a
licensed facility.  Similarly, if Dioxin is detected in excavated

                                14

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soils at a concentration in excess of the RCRA LDR Universal
Treatment Standard of 1 ppb, the Dioxin contaminated soils  will
be incinerated in an off-Site incinerator permitted for Dioxin
waste.  Cost allowances and contingencies included in this  ROD
Amendment and existing Remedial Action funds obligated for  the
LTTD remedy are adequate for whatever disposal option is
required.

Analytical data for O.U. #3 soils  (including Toxicity
Characteristic Leaching Procedure  (TCLP), Synthetic Precipitation
Leaching Procedure (SPLP),  and the ASTM Neutral Leach Test)
strongly suggests that excavated soils will not demonstrate RCRA
characteristics in excess of LDR standards.  It is therefore
anticipated that it will be possible to dispose of all of the
estimated 4,000 yd3  in a RCRA Subtitle  D  landfill.   The  cost
estimate for this amended remedy is based on a "worst-case"
disposal requirement, but U.S. EPA will utilize the most cost
effective option possible.

What will remain after completion of the amended remedy are
marginally contaminated soils covered with a 1 to 3 foot depth of
clean soil.  If anyone were to perform any future excavation,
soils 1 to 3 feet below grade may present a 1 in 100,000 chance
of an individual developing cancer if that individual performs
industrial work on the Site for 70 years.  U.S. EPA is required
to perform a Remedial Action when the cancer risk is 1 in 10,000
or worse (1 in 1,000, 1 in 100,  etc.).   In accordance with
current regulations,  the acceptable range of risk is between 1 in
10,OdO  (10"") and 1 in 1,000,000  (10'6) over a 70 year life  time.

As discussed in Section I.C - Summary of Site Risks, the risk
calculated for O.U.  #3 and the leachability and/or eco-toxicity
of some Site soils indicate that an unacceptable risk to human
health and the environmenc  exists at the Site.

B.   Capping and 'Post-Excavation'  Fill

Soil presenting a direct contact threat in Areas F and G can not
be _^ft in place because of potential risk involved with
excavation for industrial construction or maintenance activity.
At this point in time, capping of Area R in place without
excavation is not an acceptable option due to leaching of
contaminants from soils into groundwater underneath.

Excavated areas will be back filled with clean native soils.
Because no standing water can be allowed to accumulate in
excavated areas,  those areas must be filled to a level greater
than the seasonal groundwater peak.  That level may be as shallow
as 1 or 2 feet below grade resulting in grades very close to
current levels.   In the event that clean fill is affected by
rising groundwater,  soil closest to the surface (above the


                                15

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seasonal groundwater peak) will remain clean and will serve as
protection against direct contact with subsurface contamination.
Construction details will be established in the field, after
excavation begins and appropriate sampling and analysis of
underlying soils has occurred.  The source of soil or clay used
for fill will either be off-Site or from Site areas characterized
as clean which will not interfere with past or future Site
Remedial Action.

C.   Sediments

As previously mentioned, operation of the O.U. #1 and #2
groundwater extraction and treatment systems may allow natural
attenuation of sediments in Little Bear Creek and its unnamed
tributary.  Table 2 lists State of Michigan Residential Direct
Contact Values for soil.  Although these standards were not
developed specifically for sediments,  they have been included in
Table 2 because:
     no sediments cleanup standards exist,
     residents may come in contact with Creek sediment during
     recreational use, and
     surface water is in constant contact with sediment.
These soil standards provide a starting point against which
attenuation may be measured.  Creek monitoring will measure
contaminant decrease and the level of protectiveness in the Creek
will be assessed at least every five years.  Monitoring data will
be compared against sediment standards as soon as sediment
standards are developed.  It is anticipated that contaminant
concentrations will continue to decrease over time and that this
Site remedy will remain protective into the future.

Because:
     the source for contamination of these  sediments (discharge
     of contaminated groundwater)  appears to be contained by the
     O.U. #1 and #2 remedies,
     the MDEQ SWQD has recommended Creek and sediment monitoring,
     unacceptable residential  risks shown in Tables 4 through 4E
   .  are not attributable to contaminants found in sediments or
     suri ~ce (C±.^k)  water,  and
     the threat posed by contaminated drinking water has been
     addressed by connection of nearby residents to the Muskegon
     County water system,
there is no immediate need for removal of these sediments.   A
Creek and sediment monitoring  program will  be implemented for a
time period long enough to make an accurate assessment of O.U. #1
and #2 effectiveness and the condition of the Creek system.  At
least three years of quarterly Creek and sediment monitoring will
likely be completed before an  assessment of contaminant
attenuation can be made.  In addition, biological toxicity tests
will likely occur after the second and third years.
                                16

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D.   Deed Restrictions

The anticipated future land use of the Site is industrial.
Current zoning established by Dalton Township requires that the
Site can only be used for industrial use.  In order to enhance
the likelihood and insure that future land use at the former
Plant Area of the Site remains industrial in nature, an
appropriate notice or deed restriction will be recorded on the
title to the real estate on which the Site is located.  Legal
activity involving current and past owners and operators of the
Site is now occurring and may involve transfer of title to the
property to a government entity at v:hich time the appropriate
notice or deed restriction will be placed on the title.  Because
of this activity,  a final determination as to the ultimate
ownership of the Site can not be made at this time.  Provision
has been made in the cost estimate included in this ROD Amendment
for the implementation of deed restrictions.

IV.  NINE CRITERIA ANALYSIS OF THE REMEDY CHANGE

A.   THE NINE CRITERIA

U.S.  EPA is required to perform an analysis whereby each remedial
alternative is weighed relative to the following criteria:

     THRESHOLD CRITERIA

     1.   Overall Protection of Human Health and the Environment
          determines whether the alternative  eliminates,  reduces,
          or controls threats to public health and the
          environment through institutional controls,  engineering
          controls,  or treatment.

     2.   Compliance with Applicable or Relevant and Appropriate
          Requirements (ARARs)  evaluates whether the alternative
          meets Federal and State environmental statutes,
          regulations,  and other requirements that pertain to the
          Site.

     PRIMARY BALANCING CRITERIA

     3.   Long Term Effectiveness and Permanence considers the
          ability of the alternative to protect human health and
          the environment over time and the reliability of such
          protection,  including the degree of certainty that the
          alternative will prove successful.

     4.   Reduction of Contaminant Toxicity,  Mobility, or Volume
          Through Treatment evaluates the alternative's


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          effectiveness in reduction of the harmful effects of
          principal contaminants, reduction of the contaminants'
          ability to move in the environment, and the reduction
          in amount of contamination present.

     5.   Short Term Effectiveness considers the length of time
          needed to implement the alternative and the risks the
          alternative poses to workers, residents, and the
          environment during implementation.

     6.   Ixnplementability considers the technical and
          administrative feasibility of implementing the
          alternative, such as the practicability and difficulty
          of construction,  and the availability of goods and
          services.

     7.   Cost considers the estimated capital and operation and
          maintenance costs, as well as present net worth costs.
          Present net worth is the total cost of the alternative
          over time in terms of today's dollars.

     MODIFYING CRITERIA

     8.   State Acceptance considers whether the State agrees
          with U.S.  EPA's analyses and recommendations of the
          studies and evaluations performed.

     9.   Community Acceptance has been determined from che
          public comment period associated with the Proposed
          Plan.

B.   NINE CRITERIA ANALYSIS OP THE PREFERRED AMENDED REMEDY

Evaluation of the original seven alternatives against the nine
criteria was performed for the O.U.  #3 ROD and is summarized in
Table 6.  Alternatives were re-visited for this ROD Amendment and
their compliance with the nine criteria are briefly discussed.
This ROL Amendment will refer to original Alternatives in the
same order as the 1993 ROD, with the two excavation and disposal
options being Alternatives 4 and 5 (excavation and off-Site
landfilling and incineration, respectively).  A re-evaluation of
these two off-Site alternatives follows, including highlights of
the original nine criteria analysis performed for the 1993 ROD.

THRESHOLD CRITERIA

     1.   Overall Protection of Human Health and the Environment;
     Both Alternative 4 and 5 are protective of human health and
     the environment because contaminated soils constituting the


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O.U. #3 human direct contact threat or a^ threat to the
environment will be removed pursuant to acceptable State
soil cleanup criteria for an industrial land use.  The  'no
action' and 'institutional control' alternatives  (Alt's. 1
and 2) originally presented in the 1993 ROD did not and
still do not meet this criterion, and consequently were not
re-considered for this ROD Amendment.  Alternatives 3a, 3b,
6, and 7 met this criterion and would continue to achieve
protection of human health and the environment.

2.   Compliance with ARARs;  With the exception of those
related to operation of thermal treatment equipment,
requirements of ARARs as identified in the O.U. #3 ROD
remain applicable.   Federal ARARs identified have not
changed since the O.U. #3 ROD.  With the exception of Part
201 changes (formerly Act 307 as noted above),  substantive
requirements of State ARARs are essentially unchanged, but
may be identified differently.  Appendix A is a detailed
discussion of ARARs for the Site.

As noted in the O.U. #3 ROD, all Alternatives except for the
'no action1 (Alternative #1) and 'institutional control /
deed restriction1 (Alternative #2)  would have complied with
all ARARs identified,  provided appropriate soils
characterization and engineering controls are implemented
during remedy construction.

Alternative #4 will comply with these ARARs provided that
appropriate controls are applied for dust and emissions
control,  and the destination for excavated soils complies
with all land use and disposal statutes and regulations.
This includes disposal in an off-Site incineration facility
for selected excavated material if necessary.  Specific
requirements of Part 201 that Alternative #4 must comply
with are the industrial direct contact and groundwater
protection standards,  summarized in Table 1.

Residual contamination after completion of the amended
O.U. #3 ~emedy precludes future residential development for
the Site.  The Site constitutes an inactive or abandoned
site whose primary activity was industrial in nature and as
such can continue to be classified as industrial.  U.S. EPA
foresees that appropriate recorded notices on the title to
the Site property and deed restrictions combined with
security measures will be adequate to prevent or limit the
exposure potential for nearby residents and insure the Site
is not used for anything except industrial activity.  Thus,
Part 201 industrial cleanup criteria would be the relevant
ARAR.
                           19

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PRIMARY BALANCING CRITERIA



     the 1993 ROD, Alternative 4 represented U.S. EFA's least
     preferred option in because it requires off-Site
     landfilling.  Landfilling requires continual monitoring and
     maintenance to insure adequate containment of hazardous
     materials, making landfilling an impermanent solution.
     Although impermanent, however, landfill technology has been
     reliably utilized for many years.   In addition,  the
     containment options proposed in the O.U.  #3 ROD guarantee
     that contamination source material would remain out of
     contact with Site groundwater.  These considerations suggest
     that all Alternatives except 1 and 2 offer a good degree of
     long term effectiveness and permanence.

     Overall, the treatment Alternatives 5 and 6 were the most
     desirable with regard to long term effectiveness and
     permanence due to the finality afforded by thermal
     treatment.  Although Alternatives  5, 6, and to some degree 7
     continue to offer the greatest degree of initial permanence
     in that they would provide destruction of contaminants, the
     potential for re-contamination of  treated soils by
     contaminated groundwater reduces the long term effectiveness
     and cost effectiveness of these Alternatives.

     Considering the information that suggests potential re-
     contamination of treated soils,  the State's cleanup
     standards based on industrial future land use,  and the
     consequent reduction in volume of  contaminated soils
     requiring removal,  the degree of effectiveness of
     Alternatives 5, 6,  and 7 now appear to be reduced to a level
     closer to that of Alternative 4.

     Removal of the most highly contaminated soils in the O.U. #3
     area immediately eliminates the direct contact risk threat
     associated with exposure to contaminated surface soils.  All
     Alternatives remove a great portion of source material, thus
     offering a good degree of permanence and long term
     effectiveness with regard to treatment of Site groundwater.

     It is these considerations within  this remedy selection
     criterion that suggest that, except for Alternatives 1 and 2
     (eliminated based on non compliance with Threshold
     Criteria), and Alternative 6  (eliminated for reasons already
     stated), all remaining Alternatives have comparable long
     term effectiveness and permanence.

     4.   Reduction of Toxicity. Mobility, or Volume through
     Treatment;  Alternative 5, off-Site incineration, remains
     the best option for satisfaction of this criterion.

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Alternatives 6 and 7 which have treatment components achieve
this criterion, but to a lesser degree.  As previously
noted, however, treatment is not cost effective for O.U. #3
areas.  Alternatives 3a and 3b and certain portions of 7 do
not achieve this criterion because they are containment
technologies.

Although Alternative #4 would remediate the primary risks
associated with the contaminants in the O.U. #3 soils,
achievement of this criterion would not be realized because,
for the majority of excavated material, there would be no
treatment needed off-Site.  Even though removal of the most
highly contaminated soils (as in all Alternatives) may
assist in the reduction of toxicity, mobility, and volume of
contaminants going into groundwater and removed by the GWTP,
this criterion would not be achieved for soil excavation and
disposal.

This criterion would not be attained for most of the soils
to be addressed by this amended O.U. #3 remedy.  However, in
the event concentrations of specific hazardous constituents
within excavated material exceed substantive requirements of
appropriate disposal standards, then a portion of excavated
material may be disposed of at an approved incineration
facility.   For that portion of excavated material requiring
incineration,  this criterion is thus satisfied.

5.   Short-Term Effectiveness;  All Alternatives have a
short term exposure potential during excavation and
construction,  transport,  or treatment phases.  Instituting
proper health,  safety,  and emission control procedures will '
aid in minimizing such risk.   Design specifications require
that procedures should be developed and followed for dust
control,  erosion control,  and personal safety, if deemed
necessary.

If during construction activity,  Site dust and/or emissions
reach unacceptable levels,  the nature,  locations,  and amount
of Site activity will be raduced or adj.. jted accordingly.
If discharges continue after such changes are implemented,
physical means such as mist generation and application of
foam cover (or other material) directly at the point of
excavation may be utilized.   At the end of each daily
construction period, excavation and stockpile areas will be
covered appropriately to prevent releases during off-hours.
Based on the existing RD,  however,  it is expected that any
dust and/or emissions can be controlled without such
measures.

Elimination of on-Site thermal treatment as a component of
this O.U.  #3 remedy is expected to reduce overall short-term


                          21

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impacts at the site.  This will also reduce the time
required to implement the remedial action at the Site.

In general, off -Site disposal is undesirable because of
transportation of hazardous materials. Alternatives 3a, 3b,
and portions of 7 thus continue to be more desirable than
Alternatives 4 and 5 because of their retainage of hazardous
materials on Site and no risk of exposure during
transportation.  Even though under CERCLA, however, off-Site
disposal without treatment is a least preferred option, the
drastic reduction in the amount of soils to be removed
affords a shorter time period for their removal and thus
improves the short term effectiveness of Alternatives 4
and 5.  It is estimated that the amended O.U. #3 remedy will
require no more than I year to complete, not including
sampling and analysis of Little Bear Creek surface water and
sediments,  which will occur for a likely minimum of three
years.

All Alternatives have a roughly equivalent short term
exposure potential during excavation phase.  Exposure
potential for Alternatives 3a,  3b, and 7 however,  is
slightly greater given additional earth work and handling of
contaminants associated with on-Site containment.
Therefore,  Alternatives 4 and 5 better satisfy this
criteria.
6.   Implemenfeafrjl^tyf  Implementation of the amended O.U.
#3 remedy is expected to be easier than the original LTTD
remedy.  Issues associated with substantive regulatory
requirements for any on-Site thermal treatment unit are
eliminated while issues associated with construction
sequencing and material handling {as with on-Site
containment structures) will be simplified.  Implementation
of the amended O.U. #3 remedy will require some degree of
institutional control.  Specifically, U.S. EPA must insure
that future land use is limited to industrial application,
in keeping with the State of Michigan Part 201 Industrial
cleanup standards .

Operation and maintenance (O&M) associated with the amended
O.U. #3 remedy would be minimal due to the continuing
requirement for on-Site personnel operating the O.U. #1 and
#2 remedy.  In addition, because this Remedial Action will
be limited to immediate removal of the most highly
contaminated soils, O&M of the amended remedy will consist
of Site inspection, nominal maintenance of excavated areas,
continuation of institutional controls, and sediment and
surface water monitoring.  Standard construction methods for
all Alternatives are well established making all
Alternatives implementable .


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7.   Coat:   In the 1993 ROD, Alternative 4 was shown as
potentially  having the lowest present worth cost of
available remedy options.  Alternative 6  (LTTD), however,
was selected due to the preference  for treatment and State
and community acceptance.  The relative comparison of
alternatives demonstrated that on-Site containment options
 (3a, 3b, 7)  had costs comparable to Alternative 4.
Alternatives containing treatment components  (5, 6) showed
greater cost, with off-Site incineration of soils being the
highest.

The 1993 ROD noted that the community had responded
negatively to the creation of on-Site containment
structures.  Therefore, for the purposes of this ROD
Amendment, updated costs were obtained for excavation of the
soils and several off-Site disposal options (landfilling and
incineration).  Cost allowances for the soil components of
each disposal option are presented  in Table 7 with O&M and
Present Worth estimates shown as Table 8 and 9.

Off-Site landfilling (Alternative 4) appears to be the most
cost effective.  Costs presented are allowances representing
maximum potential excavation volumes.  It is anticipated
that 4,000 cubic yards is the more  likely soil volume to be
excavated and disposed of rather than the 10,000 used for
cost estimating purposes.  In the event off-Site
incineration is required for some excavated material, the
cost allowance shown for the landfilling option should
provide adequate contingency.  There may be some variability
in cost depending on:
a.   the depth at which contamination is no longer found;
b.   the depth at which groundwater is present, (a physical
     limitation to excavation);
c.   whether excavated soils are RCRA characteristic,
     associated hazardous or non-hazardous disposal
     including exceedance of RCRA LDR treatment standards,
     and the resulting off-Site disposal requirements;
d.   the presence and concentration of Dioxi/, which may
     require incineration in an incinerator permitted for
     Dioxin wastes;
e.   the degree of extraneous waste material found (such as
     drums or lab packs) ;
f.   the amount of fill actually used.

As with any Remedial Action,  it may become necessary or
possible to excavate more or less material,  or it may be
possible to dispose of excavated soils as non-hazardous
wastes.  Capital cost allowances shown for this Remedial
Action may therefore vary.  U.S.  EPA will monitor
contaminant concentration closely during excavation to

                          23

-------
     insure that unnecessary excavation or disposal does not
     occur.  Funds already obligated for the LTTD remedy will be
     utilized for this Remedial Action and should be adequate for
     completion of this amended O.U. #3 remedy.  As previously
     mentioned, it is most likely that 4,000 yd3 of excavated
     soils will be disposed of at a RCRA Subtitle D landfill.

MODIFYING CRITERIA

     8.   State AccffpbfrTlge -r   The State of Michigan concurs on the
     selected remedy for this Amendment to the Record of
     Decision.  MDEQ has recommended that this soil removal
     occurs to remove rigk threats associated with direct contact
     and biotoxicity and to assist in alleviation of the
     contaminant burden on groundwater.

     9.   Community Acceptance;  Community acceptance of the
     amended remedy has been evaluated after the close of the
     public comment period and is described in the attached
     Responsiveness Summary.   There was a moderate response to
     the Proposed Plan for the amended remedy.   Of the few
     comments received, however,  some members of the community
     appear to moderately disfavor the reduction in scope of the
     O.U. #3 Remedial Action.   This comes from the impermanence
     associated with landfill  disposal and the appearance that
     cleanup standards and the remedy's scope have changed
     without consideration of  adverse health effects.

V.   STATUTORY DETERMINATIONS

The amended remedy complies  with requirements of CERCLA § 121 by
controlling Site risks posed by ground water, air,  or direct
contact with hazardous materials through the removal and disposal
of Site soils.   This action  will  not cause unacceptable short-
term risk or cross-media impacts.   The amended remedy complies
with all State and Federal ARARs.   There are no chemical,  action
or location-specific ARARs identified for this action that were
not ident 'fied ^ i discussed in the original ROD   The amended
remedy is cost-effective and reduces costs associated with
construction sequencing,  material  handling,  temporary storage of
contaminated soils,  and possible recontamination of treated soil
used as fill.   In addition,  continuing capital and operational
costs of on-Site thermal treatment equipment will be eliminated.
For future industrial use, this amended O.U.  #3 remedy provides
an acceptable reduction of Site risks.

The amended remedy provides  the best balance of trade-offs with
respect to the evaluation criteria.   Treatment of O.U. #3 wastes
presenting the primary risk  at the Site was found not to be cost
effective because of the small soil volume.   Other considerations
include the re-evaluation of future land use for the Site as

                               24

-------
industrial instead of residential, the revised State of Michigan
statutes allowing this re-evaluation, the associated cleanup
standards, and the high potential for re-contamination of treated
soils.

This ROD Amendment is not inconsistent with past or future
Remedial Actions.  U.S. EPA intends to scrutinize the operations
of the groundwater extraction and treatment systems currently
operating and determine their effectiveness in preventing adverse
effects to Little Bear Creek and its unnamed tributary.  To that
end, surface water and sediment monitoring will be compared
against data being collected during GWTP operations.  At some
point in the future,  U.S. EPA may perform modeling to better
determine the effectiveness, nature and extent of past and future
Remedial Action.

Goals of this amended O.U. #3 remedy are to excavate soil in Site
areas identified as presenting:
     (1)  the greatest risk to human health from direct contact
          exposure,
     (2)  the greatest potential for continual leaching of
          contaminants into groundwater,  or
     (3)  the greatest threat to vegetative and other life forms
          as demonstrated by biological testing.

The remote location and current zoning of the Site as industrial
supports the assertion that the anticipated future land use for
the Site is industrial in nature.  Part 201 recognizes that an
inactive or abandoned site whose primary activity was industrial
in nature (as is  the  case with this Site)  should continue to be
classified as industrial.  U.S. EPA foresees that appropriate
institutional controls (such as deed restrictions)  combined with
standard security measures will be adequate to prevent or limit
the exposure potential for nearby residents and will guarantee
that the Site is  not  used for anything except industrial
activity.
                               25

-------
      N
                 NOTE: DRAWING IS NOT
                        TO SCALE
                            APPROXIMATE
                             LOCATION
                             OF SITE
MUSKEGON
       COUNTY
FIGURE 1 - COUNTY LOCATION
 OF OTT/STORY/CORDOVA SITE
             F-l

-------
      N
01 t/Story/Cordova
                                                                L.UI» &•*- Cr«»«
                                                                         To 131 I
                    FIGURE 2 - LOCAL SITE LOCATION
                                  NOT TO SCALE
                                      F-2

-------
                             NOTES;
                             1. DRAWING NOT TO SCALE
                             2. ALL EXCAVATION AREAS APPROXIMATE
FIGURE 3 - PROPOSED LTTD REMEDY EXCAVATION AREAS
                   F-3

-------
      OTT/STORY
        SITE
     APPROX. M Ml.
                11  /  \   •  §
                 •'     \SDC-01
                  v       x   (1000ft. north)
                    \     \
                    x     x  Bowman's Club
                      s    v   Ponds
                                                    vt
                                                    SDC -02
                                                       (Boon. Upstream)
                      >
                     12
EXTRACTION
 WELL *1
                       ^ r"*
                        1 / SDC -03
               Swamp
                                      : DRAWING IS NOT
                                       TO SCALE;
                                       LOCATIONS ARE
                                  	RIVER ROAD
FIGURE 4-SEDIMENT
 SAMPLE LOCATIONS
                               / ' »    - (1500 ft.
                                SDC -OB -4-  Downstream)
                                  F-4

-------
                                             EQUALIZATION
                                               BASIN
        EMPLOYEE
        SERVICES
         SLOG.
                             NEW
                          GROUNDWATER
                           TREATMENT
                             PLANT
                                        NOTES:

                                        1. DRAWING NOT TO SCALE
                                        2. ALL EXCAVATION AREAS APPROXIMATE
FIGURE 5 - PROPOSED SOIL EXCAVATION AREAS FOR OFF-SITE DISPOSAL
                            F-5

-------
    TABLE I - CONTAMINANT CONCENTRATIONS - O.U. #3 (PLANT AREA) SOILS '
ALL VALUES SHOWN ARE IN ue/ke (parts per billion, ppb) UNLESS OTHERWISE NOTED.
CONTAMINANT
Acetone
Carbon Tetrachloride
Chlorobenzene •
Chloroform
1,2-Dichloroethane *
cis- 1 ,2-Dichloroethene
trans- 1 ,2-Dichloroethene
Ethylbenzene *
2-llexanone
Methylene Chloride *
4-Methyl-2-Pentanone
Styrene
Telrachloroethene *
1 , 1 ,2.2- Tetrachloroethane*
Toluene *
1 ,2,3-Trichlorobenzene
1,1,1-Trichloroethane*
1.1,2-Trichloroethane*
Trichloroethene *
Xylenes (total) *
Benzo(a)Anthracene '
Industrial
20 X DW2
Standard
42000
100
2000
2000
too
1400
2000
14000
58000
100
20000
2000
100
340
20000
ID5
4000
100
100
200000
96'
1 £«
MUL3
100
10
10
10
10
10
10
10
100
10
100
10
10
10
10
• 0
10
10
10
30
330
Michigan Part 201
DCV4 Standard
74,000,000
190,000
14,000,000
4,100,000
270,000
8,200,000
13,000,000
72,000,000
100,000,000
3,300,000
37,000,000
830,000
490,000
120,000
160,000,000
ID'
21,000,000
440,000
1,600,000
1,000,000.000
210.000
O.U. #3 Excavation Area
A









3.66 JB
3J



1 J






B


16J






1IOB
5J

1.21 J

620



I.09J
3.84 J

C














23






D


5J




5J
3J

7J
9
3J
18




4J
8

E






3J



ISO

21

6



6


F




6


1.2J

3.11 JB


22

I600J

17000
3.98 J

79000

G










6J



25






H










3J

1 J

5J






I
24








4.02 J B
2J

46 J

220






J












7

19






                               T-la

-------
    TABLE I - CONTAMINANT CONCENTRATIONS • O.U. #3 (PLANT AREA) SOILS '
ALL VALUES SHOWN ARE IN ue/ke (parts per billion, oob) UNLESS OTHERWISE NOTED.
CONTAMINANT
Benzo(b)Fluoranthene '
Bcnzo(k)FIuoranthene 7
Benzo(a)Pyrene '
Benzole Acid
bis (2-Ethylhexyl)
phthalate'*
Bul> Ibenzylphlhalate *
4-Chloroaniline
Chrysene '
1,2-Dichlorobenzene •
1,4-Dichlorobcnzene *
Di-n-Bulylphthalate
Di-n-Octylphthalate
Fluoranthene
Hexachlorobenzene *
2-Methylnapthalene
Napthalene
4-Nitroaniline
N-nitrosodiphenylamine
Phenamhrene
Industrial
20 X DW2
Standard
96'
960 '
4 '
1840000
120 '
66000
N/A6
(1660)
9600 '
12000
1500
50000
7600
50000
20
15,000
15000
N/A6
(1260)
14000
1500
Target
MDL3
•no
330
330
. K)
330
330
1300
330
10
10
330
330
330
20
. .0
330
1700
330
330
Michigan Part 201
Industrial Soils
DCV Standard
210.000
2,100,000
21,000
1,000,000,000
1 1,000.000
720,000,000
N/A6
(18,000,000)
21,000,000
64,000,000
1,000,000
540,000,000
81,000,000
540,000,000
94,000
160,000,000
160,000,000
N/A'
(13,000,000)
5.100,000
16,000,000
O.U. #3 Excavation Area
A




2100














B
400



150J





1600

730
53.3


2700


C



















D



















E




73 J














F
90 J
60 J


150J
68 J





130 J


82 J

630 J


G




1900

2700

43 J
330



710





H




69 J



320 J
130 J









1



2100

220 J


46 J


350 J
180 J



750 J

100J
J
290 J





1200
160 J




f

740
390


290 J
                               T-lb

-------
    TABLE I - CONTAMINANT CONCENTRATIONS - O.U. #3 (PLANT AREA) SOILS '
ALL VALUES SHOWN ARE IN ue/ke (parts per billion, cob) UNLESS OTHERWISE NOTED.
CONTAMINANT
Phenol
Pyrene
1 ,2,4-Trichlorobenzene *
Aldrin •
a-BMC
P-BHC
4,4'-DDT *
Dieldrin *
Endosulfan 1
Endosulfan sulfate *
Endrin 7
lleptachlor7
1 leptachlor cpoxide 7
Methoxychlor *
Arochlor )248(PCBs)7*
TCDD Toxicity Equivalent
(Dioxin)'
Industrial
20 X DW2
Standard
260000
32000
1400
4 '
11
38
200
4.4 '
96 '
IDS
40 '
8 '
4 '
800
10 •
0.0006 '
Note 9
Target
MDL1
"10
330
330
20
20
20
20
20
20
20
20
20
20
50
330
C(K)1
Michigan Part 201
Industrial Soils
DCV4 Standard
450,000,000
340,000,000
68,000,000
8,800
24,000
83,000
440,000
9.400
1,000,000
ID5
770,000
33,000
16,000
23,000,000
21,000
0.99
O.U. #3 Excavation Area
A
53 J















B

480











610J


C






120 J









D
















E
















F

140 J
230 J
72


270C






8400

0.77
G

51 J

52


5900
140
190

97


5300
5800
0.728
II
















1

IIOJ

290 J


25000







1250

J






270 J







1

                                T-lc

-------
    TABLE I - CONTAMINANT CONCENTRATIONS - P.P. #3 (PLANT AREA) SOILS '
ALL VALUES SHOWN ARE IN tie/kg (parts per billion, DPD) UNLESS OTHERWISE NOTED.
CONTAMINANT
Acetone
Carbon Tetrachloride
Chlorobenzene *
Chloroform
1,2-Dichloroethane*
cis- 1 ,2-Dichloroethene
trans- 1 ,2-Dichloroethcnc
Ethylbenzene *
2-Hexanone
Methylene Chloride •
4-Methyl-2-Pentanone
Styrene
Tetrachloroethenc *
1 , 1 ,2,2-Tetrachloroethane*
Toluene *
1 ,2,3-Trichlorobenzene
1,1,1-Trichloroethane*
1,1,2-Trichloroethane*
Trichloroethene *
Xylenes (total) *
Benzo(a)Anthracene '
Industrial
20 X DW2
Standard
42000
100
2000
2000
too
1400
2000
14000
58000
100
20000
2000
100
340
20000
ID'
4000
100
100
200000
96 '
Target
MDL3
)0
10
10
10
10
10
10
10
10
100
10
lv/0
10
10
10
10
330
,0
10
10
30
Michigan Pan 201
DCV4 Standard
7.40e+07
l.90e+05
l.40e+07
4.IOe+06
2.70e+05
8.20e+05
1.30e406
7.20C+06
I.OOe+07
3.30e+05
3.70e+06
8.30e+05
4.90e+05
l.20e+05
1.60e+08
ID 5
21,000,000
440,000
1,600,000
1,000,000,000
210,000
O.U. #3 Excavation Area
K














18






L





















M




3







18

IS


37



N














13





47 J
O









2.78 JB


I.I3J








P










2J










Q









5.54 D


160


18

38



R
7J
26000

0.9 J








2300

880


3100



S













«


4J




                               T-ld

-------
    TABLE I • CONTAMINANT CONCENTRATIONS - O.U. #3 (PLANT AREA) SOILS '
ALL VALUES SHOWN ARE IN ue/kg (parts per billion, ppb) UNLESS OTHERWISE NOTED.
CONTAMINANT
Benzo(b)Fluoranthene '
Bcnzo(k)Fluoran(hene 7
Benzo(a)Pyrene '
Benzole Acid
bis (2-Ethylhexyl)
phthalate'*
Butylbenzylphthalate *
4-Chloroaniline
Chrysene '
1,2-Dichlorobenzcne *
1,4-Dichlorobenzene •
Di-n-Butylphthalate
Di-n-Octylphthalate
Fluoranthene
Hexachlorobenzcnc *
2-Methylnapthalene
Napthalene
4-Nitroaniline
N-nitrosodiphenylamine
Phenanthrene
Industrial
20 X DW2
Standard
96 '
960 '
4 '
1,800,000
120 '
66000
N/A6
(1660)
9600 '
12000
1500
50000
7600
50000
20
ID5
15000
N/A6
(1260)
14000
1500
Target
MDL3
330
330
.. 10
330
3300
330
330
1300
330
10
10
330
330
330
20
330
330
1700
330
Michigan Part 201
Industrial Soils
DCV4 Standard
210,000
210,000
21,000
1,000,000,000
11,000,000
720,000,000
N/A6
(18,000,000)
21,000,000
64,000,000
1,000.000
540,000,000
81,000,000
540,000,000
94,000
ID5
160,000,000
N/A6
(13,000.000)
5,100,000
16,000,000
O.U. #3 Excavation Area
K


330 J

340 J

1700
190 J




470
3400



310

L




530

410












M
1300 DJ
1500 DJ


230 J

310
1800 DJ




190 J

1000



2600 J
N




91 J

I50J
150 J




62 J

170 J



38 J
O










70.4 J








P




150J














0



75000 J




IIOOOJ

121 J








R



2900 J
560 J
210J
1200

13000J
7600 J
137J

200 J
7800 J
780 J



340 J
S












>






                               T-le

-------
    TABLE I - CONTAMINANT CONCENTRATIONS - O.U. #3 (PLANT AREA) SOILS '
ALL VALUES SHOWN ARE IN ue/k2 (carts per billion, ppb) UNLESS OTHERWISE NOTED.
CONTAMINANT
Phenol
Pyrene
1,2,4-Trichlorobcnzene *
Aldrin •
a-BIIC
P-DUC
4,4'-DDT »
Dieldrin •
Endosulfan I
Endosulfan sulfate *
Endrin '
Heplachlor 7
Heptachlor epoxide '
Methoxychlor *
Arochlorl248(PCBs)7»
TCDD Toxicity Equivalent
(Dioxin)'
Industrial
20 X DW2
Standard
260000
32000
1400
4 '
II
38
200
4.4 '
96 '
ID5
40 '
8 '
4 '
800
10 '
0.0006 '
Note 9
Target
MDL3
330
330
330
20
20
20
20
20
20
20
20
20
20
50
330
0.001
Michigan Part 201
DCV Standard
450,000,000
340,000,000
68,000,000
8,800
24,000
83,000
440,000
9,400
1,000,000
ID'
770,000
33,000
16,000
23,000,000
21,000
0.99
O.U. #3 Excavation Area
K

450
300 J
43









1300


L
















M

1800 DJ

69
22
47

190



18

930
15000
0.2
N

72 J




37 J









O














3900
ND
P















0.128
Q



30





870



25000


R
690 J

480 J
29.5


I200J







950

S













V


                                T-lf

-------
FOOTNOTES FOR TABLE 1
*       An asterisk denotes that contaminant was identified in 1993 Record of Decision as a contaminant of concern.

1       Values shown are peak concentrations detected during all Site studies, including the Remedial Investigation, Remedial Design, as well as pre- and post-ROD
        independent studies. See Figure 3 for layout of OU #3 areas.

2       20 x DW • 20 times the Part 201  Industrial drinking water standard. This is the contaminant concentration in soils which, if exceeded, may cause leaching of
        contaminants into groundwater at levels exceeding acceptable drinking water standards.

3       MDL - Method Detection Limit. The Target Method Detection Limit is the lowest value accepted by the State of Michigan that laboratory equipment can measure. If
        the 20 x DW value is lower than what the  laboratory can detect, then the TMDL becomes the cleanup standard.

4       DCV - Pan 201 Industrial Direct Contact Value. This is the contaminant concentration in soils which, if exceeded, presents an unacceptable risk to human health and
        the environment within a typical industrial scenario.  Any exposure to plant area soils would be to an individual working on the Sitewithin a controlled work
        environment.

5       ID -  Inadequate Data. The State of Michigan does (did) not have enough health risk data to develop criterion for this contaminant.  U.S. EPA's support contractor,
        however, may calculate estimates for these compounds using accepted MDEQ methods. These estimates may be used to define the extent of excavation during
        implementation of the amended O.U. #3 remedy.

6       N/A  - Not available. U.S. EPA's support contractor, however, has calculated estimates for these compounds using accepted MDEQ methods (shown in parenthesis).
        These estimates may be used to define the CAtent of excavation during implementation of the amended O.U. #3 remedy.

7       Due  to its physicochemical properties, contaminant is not expected to leach into groundwater.

8       20 times Michigan Act 399 (Safe Drinking Water Act) drinking water standard.

9       The 20 times Michigan Act 399 (Safe Drinking Water Act) drinking water standard for this contaminant is not applicable here because, for soils, this contaminant was
        shown in Site specific sampling not to leach at unacceptable levels. The DCV is the applicable standard for soils removal.
                                                                                                                                                  i
DATA QUALIFIER LEGEND
When chemical analysis data is submitted to U.S. EPA, Limitations of analytical equipment must be noted with results so an accurate scrutiny can be performed. These
Limitations are shown as qualifiers, noted as letters next to numerical values.  Explanations of these qualifiers are as follows:
J -      Signifies a value that was estimated. This means that the compound was detected by the analytical equipment but the value shown may not be able to be reproduced
        exactly if the analysis were repeated.

B -     Signifies a compound that was also detected in a blank. A blank is a 'clean' sample prepared in the laboratory, carried with field samples, transported, and stored. If
        contamination is found in a blank, there is a possibility that contamination  may be from a source other than what was sampled (such as through faulty sampling,
        storage, transportation, or laboratory procedures).

D -     Signifies that the sample shown had to be diluted for the lab equipment to show results that are reproducible.


                                                                           T-lg

-------
TABLE 2 - CONTAMINANT CONCENTRATIONS - SEDIMENTS IN LITTLE BEAR CREEK AND UNNAMED TRIBUTARY '
     ALL VALUES SHOWN ARE (N uc/ke (parts per billion, ppb) UNLESS OTHERWISE NOTED,
:ONTAMINANT
\cetone
tenzene
'-Butanone
'arbon Disulflde
^hloro benzene
^hlorocthane
Chloroform
^hloromethane
1,1-Dichloroe thane
,2-DichlorocChane
•thylbenzene
!-Hexanone
Hethylene Chloride
l-Methyl-2-Pentanone
1 , 1 ,2,2-Telrachlorocthane
retrachloroethene
Toluene
Prichloroethcne
Vinyl Acetate

-------
TABLE 2 - CONTAMINANT CONCENTRATIONS - SEDIMKNTS IN IITTLE BEAR CREEK AND UNNAMED TRIBUTARY '
     ALL VALUES SHOWN ARE IN tie/kg (parts per billion, ppb) UNLESS OTHERWISE NOTED.
;ONTAMINANT
icnzoic Acid
)enzo(a)Pyrene '
>is (2-Ethylhexyl)phlhaJaic '
lutylbenzylphthalate
l-Chloroanilinc
Ji-n-Butylphthalate
)ibcnzofuran
1 ,2-Dichlorobenzene
,4-Dichlorobenzene
iiethylphthalate
:luoranthenc
'-Mcthylphi nol
l-Methylphenol
•l-nitiosodiphenylamine
'henol
•yrcne
I.4--DDT '
)ieldrin '
£ndosulfan II '
Michigan Part
201
Residential
Soils DCV
Level '
1,000.000,000
1,400
700,000
68,000,000
N/A*
(1,700,000)
51,000,000
ID1
9.400,000
110,000
320,000,000
51,000,000
5,500,000
2,100.000
520,000
66,000,000
32,000,000
29.000
620
97,000
TMDL'
3300
330
330
330
1300
330
330
10
10
330
330
330
330
330
330
330
20
20
3.3
SEDIMENT S/ MPLc POINTS '
2-3


120

1600






320
1000
230
410
69



4




780







250

210




II





389 J













12





129 J













13





109 J













14







2380
454 J










15-17
237 J
286 J

288 J

295 B











6.74

18-21
156 J


2320 J

128 JB

969 J









2.34 J

22-24



536 J

132 JB










8.42 J


25-27
I440J

575 J
19200

241 JB





550 J







28-30
3640 J


52.6 J
74.4 J
344 JB
394 J



88.9 J




81.1 J



31-34



2290
1040 J












3.I3J
I85J
35-37
823 J




173 J










40.8
10.5

38-40
360 J


165 J















41
I54J


267 J








'»




10.3

                                       T-2b

-------
FOOTNOTES FOR TABLE 2
I       Values shown are peak concentrations detected during all Site studies, including the Remedial Investigation, Remedial Design, as well as pre- and post-ROD
        independent studies.  See Figure 4 for sample locations.

2       Sample point labels shown correspond to locations shown in Figure 4.

3       DCV - Part 201 Residential Direct Contact Value.  This is the contaminant concentration in soils which, if exceeded, presents an unacceptable risk to human health
        and the environment based on exposure t   hose soils within a typical residential scenario.  These standards are shown here for comparison purposes only. Any
        exposure to Little Bear Creek would be to a resident using the Creek for recreational purposes, and, as such, uncontrolled (as opposed to an industrial scenario).

4       TMDL - Target Method Detection Limit.  This is the lowest value accepted by the State of Michigan that  laboratory equipment can detect. If the DCV value is
        lower than what the laboratory can detect.  'ien the cleanup standard becomes the TMDL.

5       Standard scientific notation. For example, a value shown as 2.0e+08 is 2.0 x 10', or, in standard numeric format, a value of 200,000,000.

6       N/A - Not available.  U.S. EPA's support contractor, however, has calculated estimates for these compounds using accepted MDEQ methods (shown in
        parenthesis). These estimates may be used to define the extent of excavation during implementation of the amended O.U. #3 remedy.

7       Due to its physicochemical properties, contaminant is not expected to leach into groundwater.

8       ID - Inadequate Data. The State of Michigan does (did) not have enough health risk data to develop criterion for this contaminant.  U.S. EPA's support contractor,
        however, may calculate estimates for these compounds using accepted MDEQ methods. These estimates may be used to define the extent of excavation during
        implementation of the amended O.U. #3 remedy.

9       20 times Michigan Act 399 (Safe Drinking Water Act) drinking water standard.

DATA QUALIFIER LEGEND
When chemical analysis data  is submitted to U.S. EPA, limitations of analytical equipment must be noted with results so an accurate scrutiny can be performed. These
limitations are shown as qualifiers, noted as letters next to numerical values.  Explanations of these qualifiers are as follows.

J -      Signifies a value that was estimated.  This means that the compound was detected by the analytical equipment but the value shown may not be able to be
        reproduced exactly if the analysis were  re  ated.

B -     Signifies a compound that was also detected in a blank. A blank is a 'clean' sample prepared  in the laboratory, carried with field samples, transported, and stored.
        If contamination is found in a blank, there is a possibility that contamination may be from a source other than what was sampled (such as through faulty sampling,
        storage, transportation, or laboratory procedures).

D -     Signifies that the sample shown had to be diluted for the lab equipment to show results that are reproducible.
                                                                          T-2c

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TABLE 3 - EXCEEPANCE OF SOIL CLEANUP STANDARDS FOR OTT/STORY/CORDOVA O.U. #3 PLANT AREA SOILS
               ALL VALUES ARE IN ue/kg (parts per billion, oob) UNLESS OTHERWISE NOTED
CONTAMINANT
Carbon Tetrachloride
Methylene Chloride
Tetrachloroethene
1,1,1 - Trichloroethane
Benzo(b)F)uoranthene
Benzo(k)Fluoranthene
O.U. #3
AREA
AreaR
AreaB
AreaQ
AreaR
AreaF
Area B, M
Area M
20 X DW, DCV,
or TMDL
VAL"1
EXCLUDED2
100(20xDW)
100(20xDW)
100(20XDW)
100(20XDW)
5 (RES) 4
4000 (20 x DW)
330 (TMDL; 20 x
DW= 96 ppb)
960 (20 x DW)
CONTAMINANT
CONC.
26000
HOB
160
2300 (year 1988)
100 (year 1995, with
leachate >5 ppb*)
17000
400, 1300DJ
1500 DJ
COMMENTS
Exceedance based on 1992 data, but contaminant not present at unacceptable levels
based on 1995 sampling. It is not expected, however, that this compound would be
reduced from 26,000 ppb to undetectable levels between 1992 and 1995. This
exceedance is a contributing factor J as to why this Area should be excavated.
Exceedance based on 1988 data, but contaminant not present at unacceptable levels
based on later sampling. Compound was also detected in a 'blank' (see Data Qualifier
Legend below).
Exceedance based on 1988 data, but contaminant not present at unacceptable levels
based on later sampling.
Exceedance based on 1992 data. In 1995, compound was shown to be present in soil at
100 ppb (equal to 20 x DW soil std.) and shown to leach from soil at concentrations
greater than 5 ppb* (industrial groundwater standard). There arc other contributing
factors ] as to why Area R should be excavated.
Exceedance based on 1988 data, but contaminant not present at unacceptable levels
based on later sampling. The history of activity in this Area is a contributing factor ' as
to why Area F should be excavated.
400 ppb exceedance discovered in 1995, but shown not to leach out of soil at
unacceptable levels. Area B was previously remediated and filled with clean soil.
1300 ppb exceedance discovered in 1988, not present at unacceptable levels based on
later sampling.
Exceedance based on 1988 data, but contaminant not present at unacceptable levels
based on later sampling.
                                           T-3a

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            TABLE 3 - EXCEEDANCE OF SOIL CLEANUP STANDARDS FOR OTT/STORY/CORDOVA O.U. #3 PLANT AREA SOILS
                               ALL VALUES ARE IN ue/kg (parts per billion, oob) UNLESS OTHERWISE NOTED
CONTAMINANT
O.U. #3
AREA
20 X DW, DCV,
or TMDL
VAL  «;
EXCEEDED2
CONTAMINANT
     CONC.
COMMENTS
bis (2-ethylhexyl)
phthalate
Area A,K,L
330 (TMDL J; 20
xDW= I20ppb)
 2100,890,530
Area A Exceedance based on 1988 data, but contaminant not present at unacceptable
levels based on later sampling.  Area K exceedance was discovered in 1995, but shown
not to leach out of soil at unacceptable levels. Area L exceedance based on 1988 data,
but contaminant not present at unacceptable levels based on later sampling.
                       Area G,R
             330 (TMDL)
                     1900, 560 J
                  Area G exceedance discovered in 1995, but shown not to leach out of soil at
                  unacceptable levels. Area R exceedance discovered in 1988, but contaminant not
                  present at unacceptable levels based on later sampling.  There are other contributing
                  factors3 as to why Areas G and R should be excavated.
4-Chloroaniline
AreaK
N/A; I660ppb
(est 20 x DW
level)5
      1700
Exceedance based on 1992 data. This compound was found not to leach from soil at
unacceptable levels during 1995 testing.
                       AreaG
             N/A;  1660ppb5
                        2700
                  Exceedance based on 1992 data, but contaminant not present at unacceptable levels
                  based on later sampling.
1,2-Dichlorobenzene
AreaR
12000 (20 xDW)
     13000J
Exceedance based on 1988 data, but contaminant not present at unacceptable levels
based on later sampling. There are other contributing factors ' as to why Area R should
be excavated.
 1,4-Dichlorobenzene
AreaR
 1500(20xDW)
     7600 J
Exceedance based on 1988 data, but contaminant not present at unacceptable levels
based on later sampling. There are other contributing factors 3 as to why Area R should
be excavated.
                                                                   T-3b

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TABLE 3 - EXCEEDANCE OF SOIL CLEANUP STANDARDS FOR OTT/STORY/CORDOVA O.U. #3 PLANT AREA SOILS '
CONTAMINANT
Hexach lorobenzene
4-Nitroaniline
Phenanthrene
Aldrin
a-BHC
O.U. #3
AREA
AreaB
AreaK
AreaG
AreaR
AreaB
Area M
Area F,G,R
Area I, K,
M,Q
Area M
20 X DW, DCV, or
TMDL VALUE
EXCEEDED2 (cob)
20 (20 x DW)
20TOxDW)
20 (20 x DW)
20 (20 x DW)
!260(20xDW)
1500(20xDW)
20 (TMDL)
20 (TMDL)
20 ( FMDL)
CONTAMINANT
CONC. (nob)
53.3
3400
710
980, 7800 J
2700
2600 J
72, 52,29.5
290 J, 43, 69, 30
22
COMMENTS
Exceedance based on 1994 data, but shown not to leach out of soil at unacceptable
levels during 1995 sampling.
Exceedance based on 1988 data, but shown in 1995 not to leach out of soil at
unacceptable levels.
Exceedance based on 1992 data, but contaminant shown not to leach out of soil at
unacceptable levels during 1995 sampling. There are other contributing factors > as to
why Area G should be excavated.
Exceedance based on 1988 data, but contaminant shown not to leach out of soil at
unacceptable levels during 1995 sampling. There are other contributing factors 3 as to
why Area R should be excavated.
Exceedance based on 1988 data, but contaminant not present at unacceptable levels
based on later sampling.
Exceedance based on 1988 (and 1995) data, but shown not to leach out of soil at
unacceptable levels during 1995 sampling.
Area F nd G exceedance based on 1995 data, but contaminant shown not to leach out of
soil at unacceptable levels. Area R exceedance based on 1994 data, but contaminant
not present at unacceptable levels based on later sampling. There are other contributing
factors 3 as to why Areas F and R should be excavated.
Area 1 and K exceedance based on 1988 (and 1995) data, but contaminant shown not to
leach out of soil at unacceptable levels in 1995. Area M and 0 exceedance based on
1995 data, but contaminant shown not to leach out of soil at unacceptable levels in 1995
testing.
Area M exceedance based on 1995 data, but contaminant shown not to leach out of soil
at unacceptable levels.
T-3c

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             TABLE 3 - EXCEEDANCE OF SOIL CLEANUP STANDARDS FOR OTT/STORY/CORDOVA O.U. #3 PLANT AREA SOILg '
                                ALL VALUES ARE IN ug/kg (parts per billion, oob) UNLESS OTHERWISE NOTED
CONTAMINANT
O.U. #3
AREA
20 X DW, DCV,
or TMDL
VALUE
EXCLUDED2
CONTAMINANT
     CONC.
COMMENTS
P-BHC
Area M
20 (TMDL)
       47
Area M exceedance based on 1995 data, but contaminant shown not to leach out of soil
at unacceptable levels.
4,4'-DDT
Area F,G,R
200 (20 x DW)
2700,5900, I200J
Area F, G, R, exceedances based on 1988 data, but contaminant not present at
unacceptable levels based on later sampling and shown not to leach out of soil at
unacceptable levels. There are other contributing factors' as to why Areas F,G, and R
should be excavated.
                       Area I, J
             200 (20 x DW)
                     25000, 270 J
                   Area I,J exceedances based on 1988 data, but contaminant not present at unacceptable
                   levels based on later sampling and shown not to leach out of soil at unacceptable levels.
Dieldrin
Area M
20 (TMDL)
       190
Area M exceedance based on 1988 data, but contaminant not present at unacceptable
levels based on later sampling.
                       AreaG
             20 (TMDL)
                         140
                   Area G exceedance based on 1988 data, but contaminant not present at unacceptable
                   levels based on later sampling. There are other contributing factors 3 as to why Area G
                   should be excavated.
Endosulfan I
AreaG
96 (20 x DW)
       190
Area G exceedance based on 1992 data, but contaminant not present at unacceptable
levels based on later sampling and shown not to leach out of soil at unacceptable levels.
There are other contributing factors3 as to why Area G should be excavated.
 Endrin
Area G
40 (20 x DW)
       97
Area G exceedance based on 1992 data, but contaminant not present at unacceptable
levels based on later sampling and shown not to leach out of soil at unacceptable levels.
There are other contributing factors3 as to why Area G should be excavated.
                                                                    T-3d

-------
TABLE 3 -EXCEEDANCI
r/STQRY/CORDQVA O.U. #3 PLANT AREA SOILS '
CONTAMINANT
Methoxychlor
Arochlorl248(PCBs)
TCDDTcxicity
Equivalent (Dioxin)
O.U. #3
AREA
Area K, Q
Area M
Areas F,G
Area I.M.O
Area G,R
AreaF
AreaG
Areas M, P
20 X DW, DCV, or
TMDL VALUE
EXCEEDED2 (oob)
800 (20 x DW) '
800 (20 x DW)
800 (20 x DW)
330 (TMDL)
330 (TMDL)
0.001 (TMDL)
0.001 (TMDL)
0.001 (TMDL)
CONTAMINANT
CONC. (nob)
1300,25000
930
8400, 5300
1250, 15000,3900
5800, 950
0.77
0.728
0.2,0.128
COMMENTS
Areas K and Q exceedances based on 1988 data, but contaminant shown not to leach
out of soil at unacceptable levels.
Area M exceedance based on 1988 data, but contaminant shown not to leach out of soil
at unacceptable levels.
Area F exceedance based on 1988 data, but contaminant not present at unacceptable
levels based on later sampling. Area G based on 1988 (and 1995) data, but contaminant
shown in 1995 not to leach out of soil at unacceptable levels. There are other
contributing factors3 as to why Areas F and G should possibly be excavated.
Area 1 exceedance based on 1994 data, Area M 1988 data. Area O 1992 data, but no
exceedances in later sampling events (1995).
Area G and R exceedances based on 1992 data, but contaminant not present at
unacceptable levels based on later sampling. There are other contributing factors1 as to
why Areas G and R should be excavated.
Area F exceedance of 0.001 ppb TMDL is based on 1995 data, but the TMDL standard
does not apply. The current State DCV ARAR of 0.99 ppb is applicable because it was
shown that contaminant is not leaching at unacceptable levels. Contaminant
concentration therefore does not exceed any State or Federal ARAR for industrial land
use. Although it has been shown that Dioxin does not leach to groundwater at
unacceptable levels, tl ere are other contributing factors3 for additional Area F sampling
and possible excavation. «
Area G exceedance of 0.001 ppb TMDL based on 1994 data. Detections of TCDD
above the 0.001 ppb TMDL occurred in 1995 and 1996 sampling, but below the 1994
level, and there were no exceedances of any State or Federal standards, including the
current State DCV ARAR (0.99 ppb) for industrial land use. Although it has been
shown that Dioxin does not leach to groundwater at unacceptable levels, there are other
contributing factors3 for additional sampling of Area G and possible excavation.
Area M and P exceedances of 0.001 ppb TMDL is based on 1994 data, but no
detections of TCDD occurred in 1995 and 1996 sampling, and it has been shown that
Dioxin does not leach to groundwater at unacceptable levels
                                         T-3e

-------
FOOTNOTES FOR TABLE 3
*       An asterisk (*) denotes the confirmed exceedance of a current State standard (corresponding to 10 $ industrial risk). Excavation of soils is warranted in these
        areas based on addressing  O.U. #3 risks associated with future industrial land use (identified in the 1993 ROD) and in accordance with State of Michigan
        standards.

1       Summarized in "Ott/Story/Cordova Site - Technical Memorandum for Soil and Sediment" dated April 1997 prepared by Black and Veatch for U.S. EPA.

2       20 x DW - 20 times the Part 201 Industrial drinking water standard.  This is the contaminant concentration in soils which, if exceeded, may cause leaching of
        contaminants into groundwater at levels exceeding acceptable drinking water standards.
        TMDL, - The Target Method Detection Limit is the lowest value accepted by the State of Michigan that laboratory equipment can measure. If the 20 x DW
        value is lower than what the laboratory can detect, then the TMDL becomes the cleanup standard.
        DCV - Part 201 Industrial Direct Contact Value.  This is the contaminant concentration in soils which, if exceeded, presents an unacceptable risk to human
        health and the environment within a typical industrial scenario. Any exposure to plant area soils would be to an individual  working on the Site within a
        controlled work environment.

3       40 CFR Section 300.430 (eX2XiXA) requires U.S. EPA to establish  remediation goals based on ARARs and additional factors including "...(4)[F]actors related
        to uncertainty; and (5) [O]ther pertinent information." The history of the Site in Area F (former incinerator area) including the historical detection of Dioxin, is
        enough basis to re-investigate and possibly excavate and dispose of soil.  Although 1995 sampling confirmed that there was no exceedance of the State DCV
        standard in Area F, it is an O.U. #3 area that will be examined during implementation of the amended remedy. In Area G,  specific visual confirmation of
        stressed vegetation by EPA contractors and demonstration of toxicity characteristics when subjected to Microtox biological testing in 1992 suggests an
        unacceptable threat to the environment. For the compound 4,4'-DDT, calculations for O.U. #3 in 1993 show a Hazard Index of 1.44 for age group 1 to 6 for a
        future Site resident. Although the reasonably anticipated future land use for the Site is industrial, the presence of 4,4'-DDT and associated toxicity is a
        consideration for excavation of Area G.

4       Residential Groundwater Criteria. In an Industrial scenario, the groundwater standard required by the State of Michigan for the compound Tetrachloroethene is
        the Residential Drinking Water Standard.

5       Estimated Cleanup Limit calculated by EPA contractor because no standard exists. This value may Ne used during implementation of the Remedial Action to
        assist in determining adequate excavation depth and is included here for comparison purposes.                                                     ,

DATA QUALIFIER LEGEND
When chemical analysis data is submitted to U.S. EPA, limitations of analytical equipment must be noted with results so an accurate scrutiny can be performed. These
limitations are shown as qualifiers, noted as letters next to numerical values.  Explanations of these qualifiers are  as follows:
J -      Signifies a value that was estimated. This means that the compound was detected by the analytical equipment but the value shown may not be able to be
        reproduced exactly if the analysis were repeated.
B -     Signifies a compound that was also detected in a blank.  A blank is a 'clean' sample prepared in the laboratory, carried with field samples, transported, and
        stored.  If contamination is found in a blank, there is a possibility that contamination may be from a source other than what was sampled (such as through faulty
        sampling, storage, transportation, or laboratory procedures).
D -     Signifies that the sample shown had to  be diluted for the lab equipment to show results that are reproducible.


                                                                        T-3f

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    TABLE 4 - RISK ASSOCIATED WITH OTT/STORY/CORDOVA PLANT AREA SOILS AND LITTLE BEAR
                        CREEK SYSTEM SEDIMENT AND SURFACE WATER fO.U. #31'
RISKS IDENTIFIED FROM CONTAMINANTS OF CONCERN (EXCEPT DIOXIN1 FROM BOTH SOILS

EXPOSED INDIVIDUAL
Current Resident and Trespasser
Future Worker
Future Construction Worker
Future Maintenance Worker
Future Resident
CUMULATIVE RISK ID
EXPOSED INDIVIDUAL
Future Worker
Future Construction Worker
Future Maintenance Worker
Future Resident
AND SEDIMENTS*
HAZARD INDEX 2
0.02
0.30
0.46
0.40
2.4
ENTIFIED FOR CONTAMH
RISK ATTRIBUTED TO
DIOXIN (0.77 ppb max)
5.15 E -05
6.71 E-06
1.10E-04
2.81 E-04

LIFETIME CANCER RISK '
2E-07
1 E-04
3 E-06
9E-05
3 E-04
SJANTS FOUND IN SOILS '
TOTAL LIFETIME CANCER RISK 3
1.52 E-04
9.71 E-06
2.0 E -04
5.81 E-04
FOOTNOTES FOR TABLE 4
*       There was no Dioxin ever detected in Creek sediment.

1       As calculated in the document "Ott/Story/Cordova Operable Unit #3 - Final Risk Assessment Technical Memo" dated
        December, 1992, prepared by Black and Veatch for U.S. EPA and corrected on December 7, 1997.

2       When the Hazard Index (HI) is greater than  1, there is a potential for health problems such as damage to vital organs,
        birth defects, and anemia and other blood disorders. U.S. EPA and the State of Michigan may perform Remedial
        Actions if an HI is  1.0 or above.

3       Using a basis of a 70 year life time.  A 1.0 E -06 cancer risk value corresponds to a 1 in 1,000,000 chance that an
        individual develops cancer as a result of exposure to these concentrations of contaminants over a period of 70 years.
        i  .ilarly, 1.0 E -05 corresponds to a 1 in 100,000 chance, 1.0 E -04, 1 in 10,000, a; J so on. U.S. EPA may perform
        a Remedial Action  if cancer risks are greater than 1.0 E -04.  The State of Michigan is required to take action at a
        cancer risk of 1.0 E -05 or greater.

4       "Current Resident and Trespasser" presumes exposure for an individual by ingestion and dermal contact with
        contaminants in Creek bank sediments and Site soils during trespassing events for the current Site conditions. "Future
        Worker" assumes exposure to Site surface soils during industrial production activity over 8 hours per day (such as
        chemical production or factory work). "Future Construction Worker" represents  an individual exposed to Site surface
        and subsurface soils for 8 hours per day for one year during construction activity required for capital projects.
        "Future Maintenance Worker" signifies an individual who would be performing maintenance such as landscaping,
        building dismantling, and railroad spur upkeep during an average six months per year.  "Future Resident" assumes
        daily exposure to Site soils for an individual living  in a residence located on the Site 350 days per year.  All  scenarios
        are in accordance with U.S.  EPA risk assessment guidance.
                                                   T-4 .1

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         TABLE 4A - OTT/STORY/CORDOVA OPERABLE UNIT #3 SOJLS AND SEDIMENTS
                     TOTAL RISK - CURRENT RESIDENT AND TRESPASSER '
  CHEMICAL3
                                      NONCARCINOGENIC
                                      HAZARD QUOTIENT4
                                           AGE GROUP
                                    1 -6
7-30
                  EXCESS LIFETIME
                   CANCER RISK 2
                 70 YEAR LIFE TIME
  1,1,2-Trichloroethane
                       8.00e-10
  Benzene
                       7.00e-08
  Chloroform
                       7.00e-13
  Methylene Chloride
                       3.00e-ll
  Tetrach loroethene
                       I.OOe-09
  1,4-Dich lorobenzene
                       2.00e-10
 bis-(2-ethylhexyl) phthalate
                       3.00e-09
 Hexachlorobenzene
                       l.OOe-07
 n-Nitrosodiphenylamine
                      6.00e-l I
 4,4'-DDT
                      2.00e-08
                                   AGE GROUP HAZARD INDEX
                   CANCER RISK
                                    0.01
0.00
2.00e-07
                                                  TOTAL HAZARD INDEX
                                                            0.02
FOOTNOTES FOR TABLE 4A

1      As calculated in the document "Ott/Story/Cordova Operable Unit #3 - Final Risk Assessment Technical
       Memorandum" dated December, 1992, prepared by Black and Veatch for U.S. EPA.

2      "Current Resident and Tresspasser" presumes exposure for an individual by ingestion and dermal contact
       with contaminants in Creek bank sediments and Site soils during trespassing events for the current Site
       conditions, in accordance with U.S. EPA risk assessment guidance.

3      Contaminants shown were those consistently detected within Site characterization data.

4      '-' indicates either no toxicity value, or the estimated hazard quotient is less than 0.01.
                                           T-4A.1

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         TABLE 4B - OTT/STORY/CORDOVA OPERABLE UNIT #3 SOILS AND SEDIMENTS
                                TOTAL RISK1 - FUTURE WORKER1 "
  CHEMICAL'
NONCARCINOGENIC
HAZARD QUOTIENT5
 FUTURE WORKER
 EXCESS LIFETIME
  CANCER RISK }
70 YEAR LIFE TIME
  1,2-Dichloroethane
                                       2.00e-09
  Tetrachloroethene
                                        I.OOe-09
  Benzo(a)pyrene
                                       4.00e-06
  Benzo(b)fluoranthene
                                       3.00e-06
  Benzo(k)fluoranthene
                                       2.00e-06
  bis-(2-ethylhexyl) phthalate
                                       9.00e-09
 Chrysene
                                       3.00e-06
  Hexachlorobenzene
        0.01
     5.00e-06
 n-Nitrosodiphenylamine
                                       3.00e-09
 4,4'-DDT
        0.26
     2.00e-05
 Aldrin
                                       9.00e-07
 Aroclor 1248(PCBs)
                                       8.00e-05
                                       HAZARD INDEX
                                            0.30
                                    CANCER RISK
                                       I.OOe-04
FOOTNOTES FOR TABLE 4B

1       As calculated in the document "Ott/Story/Cordova Operable Unit #3 - Final Risk Assessment Technical
        Memorandum" dated December, 1992, prepared by Black and Veatch for U.S. EPA.

2       "Future Worker" assumes exposure to Site surface soils during activity such as industrial production
        acti'  . over 8 hours per day (such as chemical production or factory work), in accordance with U.S. 2PA
        guidance.

3       Risks shown assume possible exposure by ingestion and dermal contact with contaminants by contact with
        soils on the facility.

4       Contaminants shown were those consistently detected within Site characterization data.

5       '-' indicates either no toxicity value, or the estimated hazard quotient is less than 0.01.
                                            T-4B.1

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          TABLE 4C - OTT/STORY/CORDOVA OPERABLE UNIT #3 SOILS AND SEDIMENTS
                       TOTAL RISK' - FUTURE CONSTRUCTION WORKER*
  CHEMICAL4
NONCARCINOGENIC
HAZARD QUOTIENT5
  FUTURE WORKER
 EXCESS LIFETIME
  CANCER RJSK 3
70 YEAR LIFE TIME
  1,2-Dichloroethane
                                        l.OOe-IO
  Tetrach loroethene
                                        6.00e-ll
  Benzo(a)pyrene
                                        3.00e-07
  Benzo(b)fluoranthene
                                        2.00e-07
  BenzoOOfluoranthene
                                        l.OOe-07
  bis-(2-ethylhexyl) phthalate
                                        8.00e-10
  Chrysene
                                        2.00e-07
  Hexachlorobenzene
                                        2.00e-07
  n-Nitrosodiphenylamine
                                        2.00e-10
  4,4'-DDT
        0.40
      l.OOe-06
  Aldrin
                                       2.00e-08
  Aroclor 1248 (PCBs)
                                        l.OOe-06
 Arsenic
        0.02
                                       HAZARD INDEX
                                             0.46
                                    CANCER RJSK
                                       3.00e-06
FOOTNOTES FOR TABLE 4C

I       As calculated in the document "Ott/Story/Cordova Operable Unit #3 - Final Risk Assessment Technical
        Memorandum" dated December, 1992, prepared by Black and Veatch for U.S. EPA.

2       Future construction and maintenance worker assumes exposure to Site surface and subsurface soils during
        work activity on the Site.  "Future Construction Worker" represents an individual exposed to Site surface
        and subsurface soils for 8 hours per day for one year during construction activity required for capital
        projects, in accordance with U.S. EPA risk assessment guidance.

3       Risks shown assume possible exposure by ingestion and dermal contact with contaminants by contact with
        soils on the facility.

4       Contaminants shown were those consistently detected within Site characterization data.

5       '-' indicates either no toxicity value, or the estimated hazard quotient is less than 0.01.
                                            T-4C.1

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          TABLE 4D - OTT/STORY/CORDOVA OPERABLE UNIT #3 SOILS AND SEDIMENTS
                        TOTAL RISK' - FUTURE MAINTENANCE
CHEMICAL*
1,2-Dichloroethane
Tetrach loroethene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
bis-(2-ethy!hexyl) phthalate
Chrysene
Hexachlorobenzene
n-Nitrosodiphenylamine
4,4'-DDT
Aldrin
Aroc!orl248(PCBs)
Arsenic

m^^^^^^^7/.
NONCARCINOGENIC
HAZARD QUOTIENT5
FUTURE WORKER
-
-
-
-
-
-
-
-
-
0.33
-
-
0.01
HAZARD INDEX
0.40
EXCESS LIFETIME
CANCER RJSK'
70 YEAR LIFE TIME
2.00e-09
l.OOe-09
6.00e-06
3.00e-06
2.00e-06
l.OOe-08
3.00e-06
4.00e-06
4.00e-09
2.00e-05
7.00e-07
5.00e-05
-
CANCER RJSK
9.00e-05
FOOTNOTES FOR TABLE 4D

I       As calculated in the document "Ott/Story/Cordova Operable Unit #3 - Final Risk Assessment Technical
        Memorandum" dated December, 1992, prepared by Black and Veatch foi U.S. EPA.

2       Future construction and maintenance worker assumes exposure to Site surface and subsurface soils during
        work activity on the Site. "Future Maintenance Worker" signifies an individual who would be performing
        maintenance such as landscaping, building dismantling, and railroad spur upkeep during an average six
        months per year, in accordance with U.S. EPA risk assessment guidance.

3       Risks shown ?"ume possible exposure by ingestion and dermal contact with contamimnts by contact with
        soils on the facility.

4       Contaminants shown were those consistently detected within Site characterization data.

5       '-' indicates either no toxicity value, or the estimated hazard quotient is less than 0.01.
                                             T-4D.1

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         TABLE 4E -OTT/STORY/CORDQVA OPERABLE UNIT #3 SOILS AND SEDIMENTS
                               TOTAL RISK1 - FUTURE RESIDENT *
 ZHEMICAL4
                                       NONCARCINOGENIC
                                       HAZARD QUOTIENT5
                                            AGE GROUP
                                     1 -6
                     7-30
                                       EXCESS LIFETIME
                                        CANCER RISK3
                                      70 YEAR LIFE TIME
  ,2-Dichloroethane
                                            5.00e-08
 Tetrachloroethene
                                            3.00e-08
 Benzo(a)pyrene
                                            l.OOe-05
 3enzo(b)fluoranthene
                                            8.00e-06
 Benzo(k)fluoranthene
                                            5.00e-C6
 3is-(2-ethylhexyl) phthalate
                                            3.00e-08
 Dhrysene
                                            7.00e-06
 Uexachlorobenzene
0.06
0.02
l.OOe-05
 i-N itrosodipheny lam ine
                                            8.00e-09
 t.4'-DDT
                       04 •
                      .HI
                       4.00e-05
 \ldrin
0.03
                       3.00e-06
 \roclor 1248 (PCBs)
                                            2.00e-04
 vlethoxychlor
0.05
0.01
 \rsenic
0.08
0.01
 Cadmium
0.07
 Chromium
0.08
0.01
 vlanganese
0.02
 Mercury
0.01
 Mickel
0.03
 /anadium
0.04
                                   AGE GROUP HAZARD INDEX
                                     1.9
                     0.5
                                        CANCER RISK
                      3.00e-04
                                                   TOTAL HAZARD INDEX
                                                             2.4
FOOTNOTES FOR TABLE 4E
1       As calculated in the document "Ott/Story/Cordova Operable Unit #3 - Final Risk Assessment Technical
       Memorandum" dated December, 1992, prepared by Black and Veatch for U.S. EPA.

2      "Future Resident" assumes daily exposure to Site soils for an individual living in a residence located on the
       Site 350 days per year, in accordance with U.S. EPA risk assessment guidance.

3      Risks shown assume possible exposure by ingestion and dermal contact with contaminants in Creek bank
       sediments and contact with soils on the facility.

4      Contaminants shown were those consistently detected within Site characterization data.

5      '-' indicates either no toxicity value, or the estimated hazard quotient is less than 0.01.
                                            T-4E.1

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TABLE SA - HISTORICAL COMPARISON OF LITTLE BEAR CREEK SEDIMENT CONTAMINATION
                             AT LOCATIONS 15 TO 34 '
         ALL VALUES ARE ug/kg fparts per billion, ppbl UNLESS OTHERWISE NOTED
CONTAMINANT
Acetone
Benzene
2-Butanone
Carbon Disulfide
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
1,1-Dichloroethane
1 ,2-Dichloroethane
Ethylbenzene
2-Hexanone
Methylene Chloride
4-Methyl-2-Pentanone
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
Vinyl Acetate
Xylenes (total)
Benzoic Acid
Benzo(a)Pyrene
bis (2-Ethylhexyl) phthalate
Butylbenzylphthalate
4-Chloroaniline
Di-n-Butylphthalate
Dibenzofuran
Diethylphthalate
Fluoranthene
PRE-19962
7420
47500
587
46.2 J
3090
1390
18.2
61.3 J
969 J
-
67 J
7.25 J
854
31.1 J
346 B
173 J
-
591 B
53100
57
-
20 J
5040
3640 J
286 J
575 J
19200
1040J
344 JB
394 J
-
88.9 J
DECEMBER
1996
255
4370
ND
ND
ND
609
ND
ND
215
ND
170
ND
ND
ND
ND
ND
349.2
ND
3440
ND
ND
ND
275
ND
ND
218
ND
2481
3026
ND
ND
ND
MARCH
1997
3100
12000
240
ND
1000
1100
ND
ND
97
ND
2200
320
53
ND
620
ND
1011
ND
14000
100
1200
ND
1200
ND
ND
ND
ND
7100
4400
ND
ND
ND
                                    T-5A.1

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 TABLE SA - HISTORICAL COMPARISON QF LITTLE BEAR CREEK SEDIMENT CONTAMINATION
                                     AT LOCATIONS IS TO 34'
            ALL VALUES ARE ug/kg Tparts per billion, ppbl UNLESS OTHERWISE NOTED
CONTAMINANT
2-Methylphenol
4-Methylphenol
N-nitrosodiphenylamine
Phenol
Pyrene
4,4'-DDT
Dieldrin
Endosulfan II
PRE-19962
550 J
-
-
-
81.1 J
8.42 J
10.5
1.85J
DECEMBER
1996
ND
ND
166
ND
ND
ND
ND
ND
MARCH
1997
ND
ND
ND
ND
ND
ND
ND
ND
        ND - Not detected.

FOOTNOTES FOR TABLE 5A

1       Locations are representative as shown in Figure 4 and can he compared against the recent quarterly
        monitoring sample locations SD-53 through SD-59. A final determination of Creek quality and
        contaminant attenuation can not be made until an adequate number of quarterly sampling events have
        occurred.

2       Pre-1996 sediment information summarized in Table 2.

DATA QUALIFIER LEGEND
When chemical analysis data is submitted to U.S. EPA, limitations of analytical equipment must be noted with
results so an accurate scrutiny can be performed. These limitations are shown as qualifiers, noted as letters next to
numerical values. Explanations of these qualifiers are as follows:
J -      Signifies a value that was estimated. This means that the compound was detected by the analytical
        equipment but the value shown may not be able to be reproduced exactly if the analysis were repeated.
B -      Signifies a compound that was also detected in a blank. A blank is a 'clean' sample prepared in the
        laboratory, carried with field samples, transported, and stored. If contamination is found in a blank, there
        is a possibility that contamination may be from a source other than what was sampled (such as through
        faulty sampling, storage, transportation, or laboratory procedures).
D -      Signifies that the sample shown had to be diluted for the lab equipment to show results that are
        reproducible.
                                             T-5A.2

-------
  TABLE 5B - HISTORICAL COMPARISON OF LITTLE BEAR CREEK WATER CONTAMINATION *
             ALL VALUES ARE ug/kg (parts per billion, oob) UNLESS OTHERWISE NOTED
CONTAMINANT
Acetone
Benzene
2-Butanone
Chlorobenzene
Chloroethane
1 , 1 -Dichloroethane
1,2-DichIoroe thane
Toluene
Vinyl Chloride
Xylenes (total)
Aniline
bis (2-Ethylhexyl) phthalate
4-Chloroaniline
2-Methylphenol
4-Methylphenol
4,4'-DDD
4,4'-DDE
4,4'-DDT
Dieldrin
Endosulfan I
Heptachlor Epoxide
PRE-1996
920 J
6000 J
-
82 J
1000J
26
140
6400
52
36 J
I7J
-
2400 D J
32 J
330 J
0.13J
0.01 J
0.088 J
0.072 J
0.016 J
0.013 J
DECEMBER
1996
ND
29
ND
ND
3
1
ND
15
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MARCH 1997
10
8.6
ND
ND
ND
ND
ND
4.5
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
        ND - Not detected.
•       Surface water samples taken between confluence with unnamed tributary and River Road.  This is
        representative and can be compared against the recent quarterly monitoring program location SW-13.  A
        final determination of Creek quality and contaminant attenuation can not be made until an adequate
        number of quarterly sampling events have occurred.

DATA QUALIFIER LEGEND
When chemical analysis data is submitted to U.S. EPA, limitations of analytical equipment must be noted with
results so an accurate scrutiny can be performed. These limitations are shown as qualifiers, noted as letters next to
numerical values.  Explanations of these qualifiers are as follows:
J -      Signifies a value that was estimated. This means that the compound was detected by the analytical
        equipment but the value shown may not be able to be reproduced exactly if the analysis were repeated.
B -     Signifies a compound that was also detected in a blank. A blank is a 'clean' sample prepared in the
        laboratory, carried with field samples, transported, and stored. If contamination is found in a blank, there
        is a possibility that contamination may be from a source other than what was sampled (such as through
        faulty sampling, storage, transportation, or laboratory procedures).
D -     Signifies that the sample shown had to be diluted for the lab equipment to show results that are
        reproducible.
                                               T5B.1

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TABLE 6 - COMPARISON OF ORIGINAL REMEDY ALTERNATIVES AS CITED IN ORIGINAL O.U. #3 ROD
DESCRIPTION OF
ALTERNATIVE
Alt. #1 -No Action
Alt. #2 - Institutional
Controls
Alt. #3a - Excavation
and On-Site RCRA D
(Act 641) Landfill
Alt. #3b - Excavation
and On-Sile RCRA C
(Act 64) Landfill
Alt. #4 - Excavation and
Off-Site Disposal in a
Land till
Alt. #5 - Excavate &
Off-Site Disposal by
Incineration
Alt. #6 - Excavate and
On-Site L TTD
Treatment
Alt. #7 - Combination
of On-Site Landfill with
Off-Site Disposal
(Incin. and Landfill)
NINE CRITERJA
Protection of
Human
Health &
Environment



XX


XX


XX

XX

XX


XX


Compliance
with
ARARs



XX


XX


XX

XX

XX


XX


Long Term
Effectiveness
and
Permanence
N/A
N/A

XX


XX




XX

XX


XX


Reduction of
Toxicity,
Mobility, or
Volume by
Treatment
N/A
N/A









XX

XX


XX


Short Term
Effectiveness
N/A
N/A

















Implementability
N/A
N/A

XX


XX


XX

XX

XX


XX


Cost
N/A
N/A

XX





XX



XX


XX


State
Accept-
ance
N/A
N/A











XX





Community
Acceptance
N/A
N/A










»
XX





o
T
A
1.
0
0

5


4


4

5

8


6


                                       T-6

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TARI F 7 - ESTIMATED COST ALLOWANCE BASED ON WORST CASE EXCAVATION DEPTH AND OFF-
                  SITE DISPOSAL FOR THE AMENDED O.U. #3 REMEDY
ESTIMATED WORST-CASE Area F = 1600yd2 2 feet excavation depth = C
SOIL VOLUME; Area G = 4700 yd2 2 feet excavation depth = 0
Area R = 5800 yd2 1 feet excavation depth = (
2 feet excavation depth = 0
TOTAL
Landfill will likely be in the State of Michigan, therefore tax = $ 0
1072 yd3 x ($ 140 / yd1 RCRA disposal + $ 30 / yd3 trans. + $ 0 tax) =
3 149 yd3 x ($ 140 / yd3 RCRA disposal + $ 30 / yd3 trans. + $ 0 tax) =
1914 yd3 x ($ 140 / yd3 RCRA disposal + $ 30 / yd3 trans. + $ 0 Uix) =
3886 yd3 x ($ 140 / yd3 RCRA disposal + $ 30 / yd3 trans. + $ 0 tax + $ 250 / yd3 stab
TOTAL DISPOSAL COST (HAZ L
Incineration Cost = (1072 + 3 149 + 1914 + 3886 yd3) x ($ 600 / yd3 + $ 6 / yd3 trans
TASK
Excavation & Earth Work 2
Buried Drums/Tanks Removal
Sub-Total
Contractor O/H & Profit (15%)
Sampling of Excavated Areas
Disposal (Landfill) 3
Disposal (Incineration) 3
Fencing 4
Institutional Control (Zoning/Permit)5
Backfill (Clean Native Soil) *
Emission Controls
Air Monitoring 7
Sub-total
Contingency (20 %)
TOTAL
UNIT COST '
$6.50 /yd3
$ 19,100 4


$ 1 ,330 / sample
See Above
See Above
$ 7.43 / foot
-
$ 9.30 per yd3
$2.25 per yd2




QUANTITY
10,021 yd3
N/A


22 samples
See Above
See Above
6400 feet
-
10,021 yd3
12,100yd2




1.67yd Subtotal = 1072yd3
67yd Subtotal = 3149yd3
).33ydDRY Subtotal = 1914 yd3
.67 vd 'WET Subtotal = 3886 yd3
VOLUME OF SOILS = 10,021 yd3
$ 182,240
$ 535,330
$ 325,380
ilization) = $ 1,632,120
andfill) = $ 2,675,070
. + $ 60 / yd3 tax) = $ 6,673,986
LANDFILL
ESTIMATED
COST
S 65,137
$ 19,100
$ 84,237
$ 12,636
$ 29,260
$ 2,675,070
-
$ 47,552
$ 11,260
$93,195
$ 27,225
$ 390,000
$ 3,370,435
$ 674,087
$ 4,044,522
INCIN.
ESTIMATED
COST
$65,137
$ 19,100
$ 84,237
$ 12,636
$ 29,260
-
$ 6,673,986
$47,552
$ 11,260
$ 91.195
$ 27,225
$ 390,000
$7,369,351
$ 1,473,870
$ 8,843,22 1
                                    T-7a

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FOOTNOTES FOR TABLE 7

1       Unless otherwise noted, all estimates shown have been taken from the Final Design Cost Estimate dated 3/6/95
        developed for the LTTD Remedial Design increased to reflect inflation to Year 1997.

2       U.S. EPA support contractor estimate dated  11/22/96 based on average unit cost over all 22 excavation areas from
        RD LTTD cost estimate.

3       Landfilling and incineration cost estimates were obtained by telephone quotations on or about October, 1996, by
        U.S. EPA RD support contractor.

4       This estimate is based on installation of fencing and signage around the entire Site property boundary (including
        labor). This allowance may be used for installation of new equipment or upgrade of exisitng Site security (to be
        determined in the field during construction).

5       Estimate is based on $  10,000 allowance provided in Feasibility Study dated March 1993, increased to reflect
        inflation to  1997.

6       Fill volume is equal to excavated volume shown above.

7       This estimate includes Health and Safety air  monitoring (portable equipment), full laboratory analysis for VOCs,
        PCBs, Dioxins/Furans, and meteorological monitoring for one year.
                                                   T-7b

-------
        TABLE 8 - O&M COST ESTIMATE FOR O.I). #3 AMENDED REMEDY
ITEM
Periodic Inspection of Excavated / Filled
Areas '
Maintenance of Fence and Signage 2
Little Bear Creek Quarterly Monitoring
(Surface Water / Sediment Sampling and
Analysis) 3
Sub-Total
CONTINGENCY (20%)
TOTAL
UNIT COSTS
$ 1,280 /event
(2 events per year)
$ 1.120/ event
( 1 event per year)
$ 20,000
(every 3 months - 4
times per year total)



TOTAL COST /YEAR
$ 2,560
$ 1,120
$ 80,000
$ 83,680
$ 16,736
$ 100,416
Estimated by U.S. EPA as : $ 80 /hr per person x 8 hrs x 2 people = $ 1,280
                            (including travel and other misc. costs)

Estimated by U.S. EPA as : $ 70 / hr per person x 8 hours x 2 people = $1,120
                            (local fencing crew - 2 people)

Estimate calculated by U.S. EPA contractor.
  TABLE 9 - PRESENT WORTH CALCULATION FOR O.U. #3 AMENDED REMEDY
TIME PERIOD FOR PRESENT
WORTH ANALYSIS
DISCOUNT RATE FOR PW
P/A FACTOR (See Table 8A)
Annual O&M Costs
PRESENT WORTH OF O&M
NET PRESENT WORTH
(INCLUDING CAPITAL COST)
30 years
5%
15.37
$ 100,416
$ 1,543,394
$5,587,9 16 -Landfill
$ 10,386,615 - Incineration
100 years
5%
19.85
$ 1 "0,4 16
$ 1,993,258
$ 6,037,780 - Landfill
$ 10,836,479 - Incineration
                                  T-8/9.1

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                               TABLE 9A - Present Worth Formula

Because different remedial alternatives have different operating costs and time periods, it is necessary to
provide some equivalent value between alternatives for comparison purposes. The present worth of an
alternative is a measure of how much money will nave to be put aside now to provide for one or more
future expenditures. To find the present worth of a series of cash disbursements (such as annual O&M),
it is necessary to discount  future amounts to the present by using an interest rate (for the appropriate
number of years) in the following manner:

       ( 1 )      Present Worth = F0( 1 + i)° + F,( I + i)'1 + ...
       where  Fk = future cash flow at end of period k
                      i = interest rate
                      k  = index for each compounding period (0 < k < n)
                      n  = number of years
                      A = annual cost (O&M cost)

This series is summarized by the following equations:

       (2)     Total P.W. = Capital Cost + Present Worth of Annual Cost

       (3)     P.W. of Annual Cost = Annual Cost x P/A Factor
                     A    i(l+i)n

Thus, for the second column of Table 9 ($ 100,416 for 30 yrs. @ 5%):

              P   (H-i)n-l      (1+0.05)30-!
              . = 	  =  	   =  15.37
              A     i(l+i)n      0.05*(1+0.05)30

and

       P.W. of O&M = $ 100,416 x 15.37 = $ 1,543,394

and

       Total P.W. of Landfilling Alternative = $ 4,044,522 (from Table 6) + $ 1,543,394 = $ 5,587,916
Source: Engineering Economy. 7th ed.. DeGarmo, Sullivan, Canada, Macmillan Publishing, 1984.
                                         T-8/9A.2

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                       APPENDIX A
    Discussion of ARARs - Ott/Story/Cordova O.U. #3

The 1993 ROD discusses ARARs that may no longer be
appropriate in light of revisions to the remedy.  For
example, ARARs dealing with control of emissions from an on-
Site incinerator or LTTD remedy need not be complied with,
as the fundamental change will not include incineration or
any other thermal treatment component.  Similarly, ARARs
concerning design and construction of waste containment
structures are no longer relevant or appropriate.

As part of the re-evaluation process, U.S. EPA has reviewed
ARARs put forth within the OU #3 ROD.  Substantive
provisions of the following statutes and regulations may or
may not be ARARs for this operable unit as discussed below:

a. Federal
     1. Action Specific:
     a. Clean Water Act, as amended  T33 U.S.C. 5 12511:
     The National Pollutant Discharge Elimination System
     (NPDES)  specifies the substantive requirements for
     discharges into surface waters,  including effluent
     standards and limitations.  40 CFR 122,  125 and 136
     establish guidelines and procedures for the National
     Pollutant Discharge Elimination System (NPDES).   The
     NPDES program is administered by MDEQ.

     These substantive requirements are applicable only to
     the groundwater treatment plant (GWTP) portion of the
     overall  Site remedy.  The GWTP has been designed to
     satisfy,  and has been satisfying,  _ae discharge
     requirements identified by MDEQ.  For the purposes  of
     this ROD Amendment, however, O.U.  #3 soils removal  does
     not need to comply with this ARAR.

     b. Clean Air Act, as amended F42 U.S.C.  S 74011 :
     The Clean Air Act was enacted to protect and enhance
     air quality.  40 CFR 6 provides that all Federal
     projects, licenses, permits, plans,  and financial
     assistance activities conform to any State Air Quality

                         A - 1

-------
Implementation Plan  (SIP) .  40 CFR _Part 50 establishes
primary and secondary ambient air quality standards
that are applicable to emissions generated during
construction activities.  It is anticipated that
construction of the amended O.U. #3 remedy would have
to comply with this ARAR by minimization of fugitive
dusts or other emissions created from excavation and
back-filling activity.  U.S. EPA anticipates that
adequate dust and emission control methods will be used
to insure that this ARAR is met.

2. Location Specific:
a. Section 10 of the Federal River and Harbor Act, as
amended:
This Act regulates obstruction or alteration of any
navigable water in the United States,  including
connected wetlands.  These requirements are implemented
through 33 CFR Parts 320-330.  Activity for this O.U.
#3 remedy could potentially affect Little Bear Creek
and its unnamed tributary  and/or connected wetlands,
this statute would be an ARAR if construction
activities pose a potential impact on the Creek and/or
the wetlands.   It is expected,  however,  that this O.U.
#3 remedy will not disrupt any navigable water or
connecting wetlands.  In the event it  appears during
construction that this remedy would disrupt such
navigable waters,  U.S. EPA will provide for any
necessary mitigative measures to comply with this ARAR.

b. Clean Water Act (CWA)  of 1977.  as amended.  F33
U.S.C.  13441.  33 CFR 322:
Section 404 of the Clean Water Act also specifically
establishes limitations on the discharge of dredged or
fill material into surface waters,  including adjacent
wetlands.  The O.U. #3 remedy will comply (or has
complied) with the substantive requirements of this
ARAR by subjecting construction documentation to review
by appropriate authority.

Executive Orders 11988 40 CFR 6 similarly requires that
construction activities avoid long- and short-term
adverse impacts associated with actions in the wetland

                    A - 2

-------
 or  floodplain areas.   This  remedy   would necessarily
 need  to  comply with  this ARAR  during  construction
 activities  as previously discussed.

 3.  Chemical Specific:
 a.  Clean Water Act  f33 U.S.C.  12511.  Toxic  Pollutant
 Effluent Standards  F40 CFR  1291 :
 Title 40, Part 129 of  the Code  of  Federal Regulations
 establishes toxic pollutant effluent  standards and
 prohibitions  of specific compounds  for specified
 facilities discharging into navigable waters.  40 CFR
 129.104  sets  ambient water criterion  for certain
 contaminants  in navigable water.  These standards may
 be  ARARs for  discharges from the GWTP that  is being
 used for the  overall Site remedy.   As noted previously,
 the groundwater treatment facility  has been designed to
 satisfy, and  has been satisfying, these requirements.
 Although the  O.U. #3 remedy does not directly deal with
 the GWTP, this Remedial Action  is not inconsistent with
 compliance with this ARAR.

 b. Resource Conservation and Recovery Act. Subtitle C
 (42 U.S.C. S  6901);
 RCRA ARARs are applicable to this Site only in the
 context  of off-site disposal of excavated soils which
 may exhibit one of the characteristics of hazardous
 waste as defined in 40 CFR 261.21 -261.24.  Based upon
 site characterization data,  excavated soils are not
 expected to exhibit any of the characteristics of
 hazardous waste.   If any of the excavated soils exhibit
 one or more of the characteristics of hazardous wastes,
 proper treatment will be employed to remove the
 characteristic and allow for appropriate disposal.   It
 is expected that after treatment the soils will not
 require disposal in a RCRA Subtitle C landfill.
Although Part A and B of the application for a RCRA
permit was submitted to U.S. EPA for the storage in
 containers of several wastes listed in 40 CFR 261.31-
 261.33 (suggesting possible on-Site generation of
hazardous wastes so listed), and there is evidence from
 former employees of improper disposal practices,  there
 is no evidence directly linking waste material at the

                    A - 3

-------
time of disposal to known listed wastes.  The processes
that produced the wastes are largely unknown.
Therefore the excavated soils are not considered listed
hazardous wastes based upon currently available
information.

c. Safe Drinking Water Act  (SDWA) of 1974
(42 U.S.C. 300(f)).  as amended:
The Safe Drinking Water Act was enacted to assure high
quality drinking water in public water supplies.
Specifically, 40 CFR 141 specifies maximum chemical
contaminant levels (MCLs)  for inorganic and organic
chemicals, maximum contaminant level goals (MCLGs)  for
organic chemicals,  and establishes national revised
primary drinking water regulations of MCLs for organic
chemicals.  Surface water in Little Bear Creek, its
unnamed tributary,  and groundwater in the Site vicinity
are not currently distributed through the public water
supply systems.   Therefore,  these regulations are not
applicable to the Site.  Because, however, the surface
water and groundwater aquifer are potential sources of
drinking water,  the MCLs and the non-zero MCLGs may be
relevant and appropriate requirements for the Site.
The final decision in this regard for groundwater will
be made in the future,  after U.S. EPA has assessed
current remedy operations and estimated time frames as
well as long term cleanup goals fox- the overall Site.
MCLs have been assumed as cleanup goals in cost
calculations under Site remedy decision documents to
date.  As noted above,  the groundwater treatment
facility currently satisfies MCLs and all other
discharge limitations to the Muskegon River.   Again,
because this fundamental change to the o.U.  #3 remedy
will deal with soils removal (which is directly
associated with contamination of groundwater), the
amended Remedial Action will comply with  requirements
of this ARAR.

d. Regulations for Hazardous Waste Generators and
Michigan Hazardous Waste Management Rules. Part 3.
R299.9301 to 9309:   "Generators of Hazardous Wastes."
40 CFR 262 :

                    A - 4

-------
  As identified in the 1993 ROD, this_ is an ARAR for the
  amended O.U. #3 Remedial Action because it is possible
  that excavation spoils may need to be handled and
  shipped as RCRA hazardous wastes.

State
  1. Action Specific
  a. Part 31 of the Natural  Resources and Environmental
  Protection Act.  PA 451  of  1994. as amended,  (formerly
  Act 245 of the Public Acts of 1929.  as amended:  Water
  Resources Commission Act:
  The National Pollutant Discharge Elimination System
  (NPDES) is implemented by the MDEQ,  which .administers
  and specifies the substantive requirements for
  discharges into surface waters,  including effluent
  standards and limitations under Part 21 of the
  Administrative Rules.  Part 4 of the Administrative
  Rules,  Rule 57 also establishes water quality standards
  for all waters of the state.   Those  requirements
  establish limits for discharge of  dissolved solids,  pH,
  taste and odor producing substances,  toxic substances,
  nutrients and dissolved oxygen.

  These substantive requirements are applicable to the
  overall Site remedy as it  includes extraction,
  treatment,  and discharge of groundwater off-Site to the
  Muskegon River in accordance  to the  NPDES permit issued
  for the GWTP.  The groundwater treatment  facility has
  been designed to satisfy,  and has  been satisfying,
  these discharge requirements  identified by MDEQ.   Both
  remedy alternatives will therefore comply with this
  ARAR.  Because the fundamental change to  the O.U. #3
  remedy will deal with soils removal  (wnich is directly
  associated with contamination of groundwater),  the
  amended Remedial Action will  comply  with  requirements
  of this ARAR.

  b. Part 55 of the Natural  Resources and Environmental
  Protection Act.  PA 451  of  1994. as amended.(formerly
  Act 348 of the Public Acts of 1965.  as amended.    Air
  Pollution Act:  Part 3);
  This law establishes standards for the density of

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emissions and emission of particulate matter.   The
fundamental change to the O.U. #3 remedy requires some
degree of excavation, resulting in agitation of Site
soils.  This Remedial Action will likely require some
degree of emissions control during construction.

For dust control, the most effective method is  wet
suppression using water alone, or a chemical
suppressant in water.  This will capture soil
particles, and will inhibit migration of volatile and
semi-volatile vapor.  At the end of each daily
construction period, excavation and stockpile areas
will.be covered appropriately to prevent releases
during off-hours.  In the event wet suppression alone
does not adequately control Site emissions to within
required levels, it will be possible to perform further
controls as discussed above, including erection of wind
screens.  It is expected that by using these measures,
the fundamental O.U. #3 remedy change will comply with
the substantive requirements of this ARAR.

c.  Part 55 of the Natural  Resources and Environmental
Protection Act.  PA 451  of  1994. as amended,  (formerly
Act 348 of the Public Acts of 3,965.  as amended.  Air
Pollution Act): Part 7. R336.1702; New Sources  of VOC
Emissions:
This was identified in the 1993 ROD,  but is no  longer
an ARAR as the amended O.U. #3 remedy no longer
requires any thermal treatment.

2.  Location Specific:
a.  Part 303 of  the Natural  Resources and Environmental
Protection Act.  PA 451  of  1994. as amended,  (formerly
Act 203 of the Public Acts of 1979.  The Goemaere-
Anderson Wetland Protection Act) ;
These rules apply to activities that result in
potential discharge to any wetland area around  Little
Bear Creek and its unnamed tributary.   These rules
include permitting requirements,  wetland determination,
and mitigation.  The amended O.U. #3 remedy will
include all necessary procedures needed to comply with
this statute.  These requirements will be included

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within the modified design for the O.U.  #3  amended
remedy.
               X
b. Part 91 of the JJatura?. Regources and Environmental
Protection Act. PA 451 of 1994.  as amended,  (formerly
Act 347 of the  Public Acts of 1972* Soil Erosion  and
Sedimentation Control Act):
Part 17 of the Administrative Rules, Soil Erosion and
Sedimentation Control, establishes general  soil erosion
and sedimentation control procedures and measures, as
well as earth change requirements and  soil  conservation
district standards and specifications.  The
modification to the O.U. #3  remedy may result in
agitation of one or more acres of land within 500 feet
of a stream.  Therefore, these are relevant and
appropriate, and the amended O.U. #3 remedy will
incorporate the requirements of this statute.

3. Chemical Specific:
a. Part 31 of the Natural Resources and Environmental
Protection Act.  PA 451 of 1994.  as amended,  (formerly
Act 245 of the Public Acts of 1929. as amended.   Water
Resources Commission Act). Administrative Rules Part 4.
Rule 323.1057  (Rule 57). Water Quality Standards
(Surface Water Quality Standards):
Part 31 of NREPA, Part 4, Rule 57 establishes limits
for all waters of the State.  Standards for toxic
substances are established on a site-specific basis.
As noted above, the groundwater treatment facility
recently constructed is currently required  to, and
does,  satisfy discharge limitations to the Muskegon
River.   The amended O.U. #3 remedy will incorporate the
requirements of this ARAR.

b. Part 55 of the Natural Resources  and Environmental
Protection Act.  PA 451 of 1994.  as amended,  (formerly
Act 348 of the Public Acts of 1965. as amended.   Air
Pollution Act): Administrative Rules Parts  7 and  9:
This establishes standards for the emission of
regulated contaminants into the air.   The fundamental
change to the O.U. #3 remedy evaluated here will
require excavation, resulting in agitation  of Site

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soils, which will result in emissions.  Although it is
not anticipated that the amended O.U. #3 Remedial
Action will stir up excessive airborne material, this
RA may require some degree of emissions control during
construction.   This is applicable to the overall Site
air quality and does not account for air releases
created by nearby industrial facilities.

For dust control, the most effective method is wet
suppression using water alone,  or a chemical
suppressant in water.  This will capture soil
particles, and will inhibit migration of volatile and
semi-volatile vapor.  At the end of each daily
construction period, excavation and stockpile areas
will be covered appropriately to prevent releases
during off-hours.  In the event wet suppression alone
does not adequately control Site emissions to within
required levels, it will be possible to perform further
controls as discussed above, including erection of wind
screens.

Rule 901 of Part 55 requires that no emissions of an
air contaminant can occur in quantities that cause
injurious effects to human health or safety.
Specifically, the contaminant concentration that
corresponds to a 10'6 70 year lifetime cancer risk can
not be exceeded at the Site boundary.

The amended O.U. #3 remedy will require excavation and
grading of the most highly contaminated plant areas.
It is anticipated, however, that real time perimeter
Site monitoring and dust control may not be needed.  It
is expected that the earth work required for this
amended O.U. #3 remedy will remain within acceptable
Part 55 levels, with the use of emissions control, if
needed.

c. Part 201 of the Natural Resources and Environmental
Protection Act;. PA 451 of 1994. as amended  (formerly
known as Act 307 of the Michigan Environmental Response
Act) :
The substantive provisions of Parts 6 and 7 of the

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rules promulgated under Act 307 wer~e identified as an
ARAR for the remedial action to be undertaken at  this
Site.  These rules provided, inter alia, that remedial
action be protective of human health, safety and  the
environment by a degree of cleanup  conforming to one
or more of three cleanup types; Type A, B, and C.  The
ROD and the amended ROD determined that the selected
soil remedy would satisfy Act 307 soil cleanup
standards.  The Act 307 standards have since been
replaced by new standards under Part 201.

The amended Part 201 now defines cleanup standards
according to categorical criteria that define the
nature of future land use at the site for which
Remedial Action is necessary.  Specific cleanup
categories are: residential, commercial, recreational,
industrial, limited residential, limited commercial,
limited recreational,  limited industrial, and other
land use based or limited categories as established by
MDEQ.  Part 201 groundwater standards will be
considered ARARs for determination of long term
groundwater cleanup goals.

Implementation of the amended O.U.  #3 remedy will limit
future development of Site property to industrial use.
The Site constitutes an inactive or abandoned site
whose primary activity was industrial in nature and as
such can continue to be classified as industrial.   U.S.
EPA foresees that appropriate deed restrictions
combined with standard security measures will prevent
or limit the exposure potential for nearby residents
and will guarantee that the Site j- not used for
anything except industrial activity.   Thus,  Part 201
industrial cleanup criteria would be the relevant ARAR.

Part 201 requires that remedial action cleanup criteria
meet a 10"5 carcinogenic risk level, or for non-
carcinogenic substances,  a hazard quotient of 1.0.
Because it will remove contaminated soils to acceptable
Part 201 soils levels,  implementation of the amended
O.U. #3 remedy would meet or exceed this standard for
Site soils and ultimately,  Site groundwater.

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d.  Part l]ll of the Natural Resources and Environmental
Protection Act.  PA 451 of 1994.  as  amended,  (formerly
Michigan Hazardous Waste Management Act. PA 64) :
Discrete portions of Part 111 of NREPA may not be
relevant and appropriate at the Site.  Because there
will be no on-Site containment of wastes, substantive
portions of Part 111 which deal with the design and
construction of hazardous waste covers are not ARARs.
Similarly,  substantive requirements for liners and
leachate collection systems are not relevant and
appropriate.  Disposal of excavation spoils, however,
will meet RCRA requirements as previously described.
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      OTT/STORY/CORDOVA SUPERFUND S^TE  -  OPERABLE UNIT THREE;
                        MUSKEGON. MICHIGAN
               AMENDMENT TO  THE  RECORD OF DECISION

               APPENDIX B -  RESPONSIVENESS  SUMMARY

 This  Responsiveness  Summary  has  been prepared  in order to  provide
 answers  to  the public  concerns regarding the cleanup  plan  for  on
 Site  soils  (O.U.  #3).   This  Responsiveness  Summary also meets  the
 requirements of Sections 113(k) (2) (B) (iv) and  117 (b)  of the
 Comprehensive Environmental  Response,  Compensation, and Liability
 Act of 1980, as amended by the Superfund Amendments and
 Reauthorization Act  of  1986  (CERCLA),  which requires  the United
 States Environmental Protection  Agency (U.S. EPA)  to  respond to
 comments received on a  proposed  plan for remedial action.  A
 not-ice of availability  of the administrative record and proposed
 plan  was published in the Muskegon Chronicle on  May 27,  1997.
 This  Responsiveness  Summary  addresses  concerns expressed during
 the subsequent public comment period of  May 27 through June 25,
 1997.  In addition,  a public meeting to  discuss  the proposed plan
 was held on June 3,  1997 at  the  Dalton Township  Hall  and comments
 recorded at the meeting  are  addressed  in this Responsiveness
 Summary.   Some of the comments appearing below have been
 paraphrased for brevity.  The Administrative Record contains
 copies of written comments and the transcript from  the  June 3rd a
 public meeting.

 COMMENT;

 U.S.  EPA should construct an on-Site landfill structure  that
 includes a certain area across River Road,  pump  out water  from
 excavation areas,  and try to identify non-identifiable
 conuaminants.

U.S.  EPA's RESPONSE;

U.S.  EPA has already considered  the possibility  of  constructing
an on Site containment structure within  the remedy  alternatives
decision analysis contained in the original Record  of Decision
 (ROD)  signed in 1993.  At that time, the cost estimate  for such a
 structure was comparable to the  Low Temperature  Thermal
Desorption  (LTTD)  option ultimately selected.  Because  LTTD
 technology changes contaminants  to more  benign compounds and

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elements, it afforded a more permanent solution than containment,
which simply confines wastes for management at a later time.   In
addition, some members of the community expressed a distaste  for
an on Site containment remedy.

In considering possible remedial alternatives for this ROD
Amendment, U.S. EPA re-visited the possibility of on-Site
containment.  The capital cost that would be required for such
containment is not warranted given the small volume of soils
constituting the primary risk.  The 1993 ROD cost comparison
between alternatives remains valid.  That is, had new estimates
been calculated, there would still.be an identical magnitude of
cost difference between on Site containment and LTTD, even though
actual values would have changed due to inflation.

For example,  in the 1993 ROD, Alternative 3b was construction of
an on-Site Act 64 / RCRA compliant landfill with excavation and
placement of 7,200 cubic yards of material.  The estimated
capital cost was $ 10,400,000,  or approximately $ 1,444 per cubic
yard.  Alternative 6 was LTTD treatment of 7,200 cubic yards for
a capital cost of $ 6,800,000.   U.S.  EPA discovered during
implementation that this cost would actually be $ 12,200,000, or
$ 1,694 per cubic yard.   A cursory adjustment of these estimates
to the year 1997 (accounting for inflation) increases both
numbers by 3 percent per year for 4 years (a factor of 1.13), to
$1,625 per cubic yard for an on-Site landfill and $1,914 per
cubic yard for LTTD.  These can be compared to the current
estimate of $ 4,050,000 (for 4,000 cubic yards)  which is $ 1,013
per cubic yard.  Because the regulatory and design requirements
of both an on-Site containment structure and treatment are still
the same in year 1997 as in year 1993,  these relative comparisons
are still valid.   In addition,  the smaller volume of soils to be
addressee make buch an on-Site containment alternative and a
treatment alternative not cost effective.

During the Remedial Action described in this ROD Amendment,
excavation areas will have any water pumped out in accordance
with normal excavation procedures.  This may assist in the
remediation of contaminated groundwater..However,  the primary
mechanism dealing with contaminated water continues to be
extraction wells pumping to the treatment plant.

The term 'non-identifiable'  refers to a limitation of laboratory

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analytical equipment whereby compounds with similar properties
can not be distinguished from one another.  U.S. EPA has
determined that the proposed excavation areas contain
contaminants that constitute the primary risk as well as non-
identifiable compounds.  If there are non-identifiable compounds
in those areas, they will be handled identically to contaminants
identified as presenting primary risk.

COMMENT;

Several commenters disagreed with using revised State of Michigan
soil cleanup standards as a basis for amending the O.U. #3
remedy.  The scope of the Remedial Action must be based on
addressing Site health risks and not a (potentially less
protective) changing regulation.

U.S. EPA'a RESPONSE;

Revised State standards are only a contributing factor to U.S.
EPA's decision to amend the remedy.  As noted in the ROD
Amendment,  cost effectiveness and future land use were also
considered in light of the cost increase shown for LTTD
treatment.   Treating soils by LTTD, then back-filling excavated
areas with acceptable residue is not cost effective when compared
against using soil from an already clean source.  Although newly
clean filled areas may be re-contaminated by contaminated
groundwater,  a significant cost savings is realized by not
implementing LTTD, and the Site returns to a state suitable for
industrial  re-use.  The areas identified as presenting an
unacceptable risk will continue to be addressed as in the 1993
ROD,  but other areas with risks now deemed acceptable for
industrial  use are being removed from the scope of the remedy.

After consideration of the location and likely future land use
for the Ott/Story/Cordova site,  it is more appropriate to
remediate the Site in keeping with future industrial or
commercial  land use.  Tables 4 through 4E (Summary of Site Risks)
of the ROD  Amendment shows the primary O.U.  #3 risk driving 'the
Remedial Action is cumulative risk to Site workers attributed to
all Site contaminants including Dioxin,  which was detected in
Areas F and G during earlier Site sampling events.
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COMMENT, t

Several commenters noted that the removal of contaminated
sediments in the Little Bear Creek system should occur regardless
of any other considerations.

TT „ S , EPA' S RESPONSE;

This amended remedy has. not eliminated future implementation of
Remedial Action for Creek sediments.  Previous Creek data and
risk calculated therefrom presented a picture at the time of the
1993 ROD that does not reflect current decreases in sediment
contamination.  U.S. EPA is postponing any Creek excavation and
dredging activity (and expenditure)  until the effectiveness of
all Site remediation to date has been determined.  Rather than
initiate an intrusive Remedial Action on Creek sediments and
possibly disrupt the natural configuration of the Creek system,
the mitigating effect of the groundwater extraction and treatment
system should first be measured in order to define the most
effective strategy for the Creek.   As is the case at the Bofors-
Nobel Site,  revival of the Creek system may occur naturally if
contaminated groundwater is intercepted before reaching the
Creek.   U.S. EPA and MDEQ are also investigating the possibility
of recirculating clean treated groundwater back into the Creek
system to assist in attenuation of contaminants.

COMMENT:

Results of Creek sediments and surface water sampling should be
made available for review by the community.

U.S.  EPA'S RESPONSE!

U.S.  EPA will add all such Creek surface water and sediments data
to the Administrative Record and the Site Information Repository
on a regular basis.

COMMENT!

The government has not stated a valid legal basis for proceeding
with the amended remedy.  EPA uses State standards as a basis,
yet Areas F and G meet State cleanup standards.  There is no
legal support anywhere in the Administrative Record for basing a

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remediation decision on the nature of past activities  or
unspecified environmental damage and no valid basis exists  under
either CERCLA or the NCP.

U.S. EPA'3 RESPONSE;

This amended ROD is consistent with and nearly identical to the
alternative remedy proposed by these commenters during the  1993
public comment period for the original ROD.  By re-evaluation of
future land use and the associated remediation goals and risks,
U.S. EPA is demonstrating innovation and believes this amended
O.U. #3 remedy is a more reasonable approach and reflects a
faster, fairer, more efficient Superfund program.

Document #3 of Update #9 to the O.U. #3 Administrative Record is
a Technical Memo presenting the Risk Assessment for the O.U. #3
area.  This memo includes tables included in this ROD Amendment
showing risk levels for future workers and residents in
exceedance of the 10"* carcinogenic and 1.0 Hazard Index  limits
established by CERCLA and the NCP.  The State of Michigan is also
required by law to take action at levels such as these.

40 CFR Section 300.430 (e)(2)(i)(A)  requires U.S. EPA to
establish remediation goals based on ARARs and additional factors
including "...factors related to uncertainty; and (5)   [0]ther
pertinent information."  The history of the Site in Areas F, G,
and R,  the unacceptable cumulative Site risk, and the historical
exceedances of cleanup standards is enough basis to warrant soil
removal in those areas.  Further,  in Areas G and R,  specific
visual  confirmation of soil discoloration and stressed vegetation
by EPA contractors and the results of Microtox testing
demonstrate an unacceptable threat to the environment.

COMMENT;

RCRA must be both relevant and appropriate (dependent on site
specific considerations)  in order to be imposed at this Site,  and
not made an ARAR based on conceptual relevance alone.   "Relevant
and appropriate" requirements are clean-up standards or other
requirements promulgated under Federal or State law that, while
not legally applicable to the remedial action,  address problems
or conditions sufficiently similar to those encountered at  the
Site.

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U.S.  EPA'S RESPONSE;

RCRA  is applicable  in determining disposal  fate  of  any  excavation
spoils.  Sampling and analysis will be performed during the
Remedial Action to  determine the required disposal  destination.
The ROD Amendment establishes off-Site landfilling  as the
disposal option, but if it is determined that excavated material
demonstrates RCRA characteristics in exceedance  of  Land Disposal
Restriction treatment standards, it must be treated before
disposal in a RCRA  licensed hazardous waste landfill, or
incinerated at an appropriately licensed off-Site incinerator,
regardless of costs.  Conversely, if it is determined that
excavation spoils can be disposed in a more cost  effective,  'non-
hazardous1 manner,  U.S. EPA will dispose of them  as such.

COMMENT;

The RCRA Universal  Treatment Standard (UTS) is not  an ARAR for
this site and thus  U.S. EPA is not warranted applying it by
requiring testing of the soils to determine whether Dioxin and
Furan levels exceed the RCRA UTS.  Applying the UTS to  site soils
would conflict with EPA's own guidance on determining whether
RCRA requirements are relevant and appropriate for  the  site -
dioxin levels in these soils pose no realistic threat to human
health or the environment if landfilled,  making incineration
unnecessary.

U.S. EPA'S RESPONSE;

The commenter fails to provide a basis to support the statement
that Dioxin levels  in Site soils pose no threat to human health
or the environment.   RCRA is applicable to the determination of
appropriate disposal facilities for excavation spoils
demonstrating appropriate substantive characteristics.
Conversely,  a more  cost effective 'non-RCRA' disposal method will
be used if possible.

COMMENT;

Area R should not be excavated based on one residential drinking
water exceedance of a single leachate analysis.  Any concern
regarding possible  impact on groundwater from Area R is
misplaced.   Rainwater has percolated for over 20 years  and it is

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 obvious  that  the  soil  is  no  longer  contributing  to  groundwater
 contamination.  Even  if the  contaminant  leaches  into  the
 groundwater it would  have no measurable  impact on the groundwater
 remedy already in place and  operating  at the  Site.

 U.S. EPA'S RESPONSE;

 As previously stated,  40  CFR Section 300.430  (e)(2)(i)(A)
 requires U.S. EPA to establish remediation goals based on ARARs
 and additional factors including  "... factors  related  to
 uncertainty;  and  (5)  [0]ther pertinent information."   Visual
 confirmation  by EPA contractors of  foreign substances (such as
 drum remnants and discoloration)  in Area R native soil and the
 known history of  the area as a disposal  area  are part of the
 basis for excavation of Area R.   Further, State of  Michigan
 cleanup  standards require 20 times  the inductrial drinking water
 standard to be used as a  remediation goal.  Analytical data for
 samples  from Area R have  been in  exceedance of this standard.

 The commenter fails to support the  statement  that the soil is no
 longer contributing to groundwater contamination.   The fact that
 contaminants  identified in soils  continue to  be discovered in
 groundwater being extracted  and treated  demonstrates  the
 likelihood that soils  are still contributing  to groundwater
 contamination.  The presence  of these contaminants  results in
 continued (possibly perpetual) extraction and treatment,  which
would be inconsistent  with O.U. #2 and unnecessarily  increases
 the cost of groundwater remediation.  Also,  the basis  for this
 comment is seemingly inconsistent with the commenter's recent
correspondence to U.S. EPA requesting the immediate cessation of
 all groundwater remediation  efforts.

COMMENT;

The costs for the work described by U.S.  EPA  should be
significantly less than the  cost estimate shown in the Proposed
Plan.

U.S.  EPA'S RESPONSE;

As stated in this ROD Amendment,  the $5,600,000 present worth
estimate is an allowance  that covers a worst-case scenario and is
used here merely as a means  to compare alternatives.  U.S.  EPA

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fully anticipates that the actual costs realijzed during
implementation of the amended remedy will be less based  on  the
actual soil volumes excavated and the nature of the  final spoils
disposal  (RCRA hazardous, non-hazardous, or incineration).  A
firm determination of Remedial Action costs can not  be made until
implementation of the amended remedy begins.

COMMENT;

U.S. EPA's proposed monitoring of creek sediments is excessive.
Costs noted by U.S. EPA should be approximately 4 times  less than
what was estimated.
                                v
U.S. EPA'S RESPONSE;

Again, U.S. EPA's estimate is an allowance that includes an
appropriate contingency for any needed variances in  the  surface
water and sediment monitoring plan.

COMMENT;

The amended remedy as described in the Proposed Plan is  letting
the responsible companies off easy.   EPA should enforce  the
treatment method that is most effective in returning the soil and
groundwater to its virgin state as quickly as possible regardless
of costs.

U.S. EPA'S RESPONSE:

Although potentially responsible parties identified for the Site
continue to dispute their responsibility for the contamination
and clean up costs,  the U.S.  Government continues its effort to
recj-ctim funds spent at the Site.  U.S.  EPA,  however, as a steward
of public funds must be 'judicious in making decisions on where
and how much money is spent on remedies.

COMMENT;

What has changed since 1993 when MDNR supported LTTD and
sediments removal ?  Why does one of the worst sites in  the
county now merit a minimal cleanup ?  The commenter does not
support the proposed amended remedy and protests the lack of
cleanup at this site.

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U.S. EPA's RESPONSE;

Justification for Remedial Action at this Site is the
unacceptable risk to a future Site worker  (I in 10,000 chance of
cancer over 70 years from cumulative effects of contaminants,
including the possibility of Dioxin).  The areas denoted for
removal by the amended remedy will remove contaminants from O.U.
#3 soils and dispose of them off-Site, including incineration if
required.  What will remain after the amended remedy is completed
are marginally contaminated soils covered with a 1 to 3 foot
depth of clean soil.  If anyone were to perform any future
excavation, soils 1 to 3 feet below grade may present a 1 in
100,000 chance of an individual developing cancer if that
individual performs industrial work on the Site for 70 years.
U.S. EPA is required to perform a Remedial Action when the cancer
rick is 1 in 10,000 or worse (1 in 1,000, 1 in 100, etc.).  In
accordance with current regulations, the acceptable range of risk
is between 1 in 10,000 (10'4) and 1 in 1,000,000  (lO'6} over  a  70
year life time.

In the O.U. #3 ROD,  the decision analysis demonstrated comparable
risk reduction and costs between several containment options and
LTTD.  U.S. EPA selected LTTD primarily because of the preference
for treatment.  Unfortunately,  the LTTD estimate used in the
comparison did not adequately encompass the requirements needed
for Site preparation and other LTTD support costs.   In 1993, the
groundwater extraction and treatment system was not operating and
there was no reduction in Creek contamination as there is today.
Consequently,  the State of Michigan concurred with the decision
to reconsider the O.U.  #3 remedy based on concerns with possible
excessive expenditure and the desire to more accurately gauge the
benefits of groundwater extraction and treatment over an adequate
enough time period.

Although the Ott/Story/Cordova site represents one of the higher
overall risk Superfund sites in the State of Michigan,  the remote
location of the Site, the Site's reputation as a contaminated
area, and the historical remedial and removal actions to date
have mitigated the situation whereby U.S. EPA and the State can
reconsider the highly conservative goals established in the O.U.
#3 ROD and tailor them to reflect a more innovative, 'real world'
approach.  In this case,  the Site would be used for some
industrial use after the Remedial Action is complete.

                               B-9

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             REGION 5

   DATE:  Wednesday, September 17, 1997

SUBJECT:  TRANSMITTAL OF THE OTT/ STORY /CORDOVA SUPERFUND SITE
          AMENDMENT TO THE RECORD OF DECISION FOR THE THIRD
          OPERABLE UNIT
   FROM:  Wendy L. Carney, Chief          Bertram C. Frey
          Remedial Response Branch #1     Acting Regional Counsel

     TO:  William E. Muno, Director
          Superfund Division

Enclosed for your review and signature is the Ott/Story/Cordova
Site Amendment to the Record of Decision for Operable Unit #3 .
The Amendment includes the Declaration, Decision Summary, and
Responsiveness Summary.  The latest update to the Administrative
Record is also included and additional documents will be added
shortly.

We concur with the amended Remedial Action for the third operable
unit for the Ott/Story/Cordova site,  which eliminates Low
Temperature Thermal Desorption (LTTD) treatment of O.U. #3 soils
and Little Bear Creek sediments and provides protection of human
health and the environment through excavation and disposal of
contaminated soils and monitoring of Little Bear Creek surface
water and sediments .

Please feel free to contact us if you have any questions.

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             REGION 5

   DATE:  Wednesday, February 25, 1998

SUBJECT:  TRANSMITTAL OF THE OTT/STORY/CORDOVA SUPERFUND SITE
          AMENDMENT TO THE RECORD OF DECISION FOR THE THIRD
          0>E
   FROM:
     TO:
We
Remedia'
                    espouse Branch #1
Bertram C. Frey
Acting Regional Counsel
William E. Muno, Director
Superfund Division
Enclosed for your review and signature is the Ott/Story/Cordova
Site Amendment to the Record of Decision for Operable Unit #3.
The Amendment includes the Declaration, Deciaion Summary, and
Responsiveness Summary.  The latest update to the Administrative
Record is also included and additional documents will be added
shortly.

We concur with the amended Remedial Action for the third operable
unit for the Ott/Story/Cordova site, which eliminates Low
Temperature Thermal Desorption (LTTD)  treatment of O.U. #3 soils
and Little Bear Creek sediments and provides protection of human
health and the environment through excavation and disposal of
contaminated soils and monitoring of Little Bear Creek surface
water and sediments.
Please feel free to contact us if you have any questions.

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                        0.S. ENVIRONMENTAL PROTECTION AGENCY
                                   REMEDIAL ACTION

                                ADMINISTRATIVE RECORD
                                         FOR
                          OTT/STORY/CORDOVA SUPBRFUND SITE
                                 MUSKBGON, MICHIGAN

                                  OPERABLE UNIT #3
                                     UPDATE #13

                                    MAY 21, 1997
NO.

 1
12/14/94
      03/00/95
      04/00/95
      04/00/95
      05/18/95
      05/19/95
      05/22/95
      06/00/95
AUTHOR

Fluor Daniel,
Inc./Black &
Veatch Waste
Science, Inc.
            U.S.  Army
            Corps of
            Engineers/
            Omaha District
            Fluor Daniel,
            Inc./Black &
            Veatch Waste
            Science,  Inc.
            Fluor Daniel,
            Inc./Black &
            Veatch Waste
            Science,  Inc.
            Black & Veatch,
            Inc.
            Lavis,  B.,
            U.S.  EPA
            McMahon,  T.
            Sidley &
            Austin
            Roy F.  Weston,
            Inc.
RECIPIENT

U.S. Army
Corps of
Engineers/
Omaha District
                  U.S. EPA
                  U.S. Army
                  Corps of
                  Engineers/
                  Omaha District
                  U.S.  Army
                  Corps of
                  Engineers/
                  Omaha District
                  U.S.  EPA
                  Region 5
                  Palensky,  J.,
                  U.S.  Army
                  Corps of
                  Engineers/
                  Omaha District

                  Johnson, L.,
                  U.S.  EPA
                  U.S.  Army
                  Corps of
                  Engineers
TITLE/DESCRIPTION        PAGES

Conceptual Design  for      122
the Low Temperature
Thermal Desorption
Treatment System for
OU#3 at the Ott/Story/
Cordova Site                 <

Drawings: Low Temper-      19
ature Thermal Desorption
(LTTD) Treatment System
for OU#3 at the Ott/
Story/Cordova Site

Predesign Investigation    165
Report for OU#3 Remedial
Design at the Ott/Story/
Cordova Site: Volume 1
(Report and Appendices
A-C)

Predesign Investigation    330
Report for OU#3 Remedial
Design at the Ott/Story/
Cordova Site: Volume 2
(Report and Appendices
D-E)

Evaluation of Cleanup      25
Criteria Report for OU#3
at t   Ott/Story/Cordova
Site

Letter re: U.S. EPA         i
Request for Design
Modifications for OU#3
at the Ott/Story/Cordova
Site

Letter re: Request for      4
U.S. EPA to Reconsider
LTTD Remedy for OU#3
at the Ott/Story/Cordova
Site

Sampling and Analysis      771
Plan for Low Temperature
Thermal Desorption for
OUH3 at the Ott/Story/
Cordova Site

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                                                               Ott/Story/Cordova AR
                                                                   Operable Unit #3
                                                                         Update  #13
                                                                             Page 2
NO.
DATE


06/00/95
10
06/02/95
                  AUTHOR
                  Roy F. Weston,
                  Inc.
                  Earth Tech
11
06/26/95
12
07/27/95
13
08/00/95
Foster, D.,
U.S. Army
Corps of
Engineers/
Grand Haven

Lavis, B.,
U.S. EPA
Earth Tech
14
09/00/95
                  Earth Tech
15
09/22/95
McMahon, T.
Sidley &
Austin
                              RECIPIENT
                  U.S. Army
                  Corps of
                  Engineers
CPC Inter-
national
and Aerojet
General/
Cordova Chem-
ical Company

Peden, D.,
Cordova
Chemical
Company
Foster, D.,
U.S. Army
Corps of
Engineers/
Grand Haven

CPC Inter-
national
and Aerojet
General/
Cordova Chem-
ical Company

CPC Inter-
national
and Aerojet
General/
Cordova Chem-
ical Company

Johnson, L.,
U.S. EPA
                                    TITLE/DESCRIPTION        PAGES
Work Plan for Low          290
Temperature Thermal
Desorption for OU#3 at
the Ott/Story/Cordova
Site

Review of Low Temper-       38
ature Thermal Desorption
Treatment and Revised
Cleanup Standards for
OU#3 at the Ott/Story/
Cordova Site "(DRAFT)

Letter re: Ott/Story/        6
Cordova OU#3 Construc-
tion Schedule w/Attached
Weston LTTD Construction
Schedule

Letter: Stop Work Order      1
for IAG DW96947723-01-0
for OU#3 at the Ott/Story/
Cordova Site
Soil Sample Collection    256
and Analysis at the Ott/
Story/Cordova Site
Review of Revised          20
Cleanup Standards and
Low Temperature Thermal
Desorption Treatment for
OU#3 ooils at the Ot..
Story/Cordova Site

Letter re: Comments on     12
OU#3 Remedy at the Ott/
Story/Cordova Site
16
17
18
03/13/96
04/00/97
05/00/97
Eagle, D.,
MDEQ
Black & Veatch
Special Pro-
jects, Corp.
                  U.S. EPA
Fagiolo, J.,
U.S. EPA
                                    U.S.  EPA
                                    Region 5
                                    Public
Letter re: Ott/Story/
Cordova OU#3 and Little
Bear Creek Sediment
Cleanup

Technical Memorandum
for Soil and Sediment
at the Ott/Story/Cordova
Site

Proposed Plan for the
Ott/Story/Cordova
Superfund Site
                                                                           112

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