EPA Superfund
Record of Decision:
Spartan Chemical Co.
Wyoming, MI
4/9/1998
PB98-964113
EPA 541-R98-159
March 1999
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INTERIM ACTION RECORD OF DECISION
FOR THE
SPARTAN CHEMICAL COMPANY SUPERFUND SITE
Kent County, Michigan
April 1998
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TABLE OF CONTENTS
Declaration-Selected Interim Remedial Action 1
A. Site Name, Location, and Description 3
B. Site History 3
C. Community Participation 7
D. Summary of Site Conditions 7
E. Summary of Risk 8
F. Rationale for Action and Scope of the Selected Remedy 15
G. Soil Alternatives 15
H. Summary of Comparative Analysis of Alternatives 16
I. The Selected Remedy 19
J. Statutory Determinations 20
K. Summary .«. 21
APPENDICES
A. Glossary
B. Responsiveness Summary
C. Administrative Record Index
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Declaration
Selected Interim Remedial Action
for the
Spartan Chemical Company Site
City of Wyoming, Kent County
Michigan
Statement of Basis and Purpose
This decision document presents the selected Interim Remedial Action (RA) for the
Spartan Chemical Company site, in the city of Wyoming, Kent County, Michigan. This
Interim RA was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act, 1980 PL 96-510, as amended by the
Superfund Amendments and Reauthorization Act of 1986, and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan.
This decision is based on the Administrative Record for this site.
Assessment of the Site
Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the Interim RA in this Record of Decision, may present an imminent
and substantial endangerment to public health, welfare, or the environment.
Description of the Selected Remedy
The selected remedy utilizes Soil Vapor Extraction (SVE) for remediation of the volatile
organic compounds (VOCs) in the soil. Primary components of the remedy are as
follows:
• SVE technology for remediation of the VOCs found in the site soil.
• Treatment of the off-gases generated from the SVE process to meet acceptable air
quality standards.
Declaration
This interim RA is protective of human health and the environment, complies with federal
and state applicable or relevant and appropriate requirements directly associated with this
action, and is cost-effective. This action utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum extent practicable, given
the limited scope of the action. Because this action does not constitute the final remedy
for the site, the statutory preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as a principal element, although partially addressed in this
remedy, will be fully addressed by the final response action.
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MAR-04-99 09.53 FROM ID PA.^E S
Subsequent actions are planned to address the remaining principal threats posed by this
site.
V. f.
William E. Muno. Director. Superfund Division Date
United States Environmental Protection Agency
RussellJ. Harding, Director " ' Dat^
Michigan Department of Environmental Qyg^y
PS.G
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A. SITE NAME. LOCATION. AND DESCRIPTION
The Spartan Chemical Company Superfund site (Spartan) is located at 2539 28th
Street about one block northwest of the intersection of Byron Center Avenue and 28th
Street (see Figure 1). It is in the southeast one-quarter of Section 9, T6N, R12W, city
of Wyoming, Kent County, Michigan.
Spartan is located on the eastern edge of an industrial/commercial area, with a school
and residential area to the east and northeast. Residential areas are also located to the
north and northeast beyond the industrial/commercial area located directly adjacent to
the site. This area is serviced by the city of Wyoming municipal water supply and
sanitary sewer system. The municipal water supply system draws water from Lake
Michigan. No known private wells exist in the vicinity of the site.
The 2-acre site is located in the Grand River drainage basin and exhibits approximately
13 feet of topographic relief. The elevation of the site ranges from 615 to 628 feet
above mean sea level. The site consists of an office building, two warehouses, one
drum/tank storage building, several smaller storage/maintenance buildings, tank farm
areas, and a loading dock in the southern portion of the site. The northern two-thirds of
the property is an open vegetated area with a small groundwater treatment system
building in the northwest corner, which contains an inactive air stripper. A 7-foot fence
surrounds the Spartan property, providing security against unauthorized site access.
Five underground storage tanks have been removed from the site, while 34
above-ground storage tanks remain. The above-ground tanks rest on concrete pads
which are surrounded by concrete containment walls. Figure 2 presents the layout of
the site.
B. SITE HISTORY (See Glossary for definitions of terms used in this section)
Spartan operated as a bulk chemical transfer, blending, and repackaging plant from
1952 to 1992. During its operation. Spartan handled a variety of chemicals, including
aromatic solvents, naphthas, alcohols, ketones, ethers, chlorinated solvents, and
lacquer thinners. The corporation filed bankruptcy in 1992, and the property has been
vacant since that time. There are no other known responsible parties.
The Michigan Department of Natural Resources (MDNR) reported that prior to 1963,
Spartan discharged its wastewater to the groundwater. Groundwater contamination
was detected in December 1975 during dewatering operations at an adjacent facility.
The discharge from the operations contained various solvents. At that time, Spartan
was the only known handler of solvents in that area. The contamination consisted of
Volatile Organic Compounds (VOCs), such as toluene, benzene, ethylbenzene, and
xylenes. Various ketones and alcohols have also been detected in the groundwater.
The MDNR also reported that three minor chemical spills occurred before 1963, as
documented by plant personnel.
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Figure 1.
SPARTAN CHEMICAL
SPARTAN CHKMICAL
COMPANY
SUPERFUND SITE
SHE LOCATION
INTERSTATE Hiciiwnrs
U.S. H1CHWATS
STATE HIGHWAYS
OTHER MAJOR ROODS
MINOR ROADS
TWO-TRACK ROADS
AIRPORTS
CRASS AIRSTRIPS
RAILROADS
ABANDONED RAILROADS
RIVERS AND STREAMS
INTERMIT TENT STREAMS
POLITICAL BOUNDARIES
SUPERfUNO SITE
MIUS
. I .
O'j
Michigan Drpnr t inrut of I'ulilli llrnllli
mnp Informnl lull pruvlilcil by UlililRnn Iiepnrliiiont of Nnturnl Hrsuurccs. UtKIS Program
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SPARTAN
CHEMICAL
COMPANY
SHE
KfNF DOOR tc
SPCCIAI. IY. INC
APPHOXIMAIt PROPERTY BOUNDARY
LEGEKD
—- socaR rifin-
SECONDARY CONTAINMENT STRUCTURES
(3O»NOO AOOVECROUND STORAGE TANKS
0 POVKR POIE
CONCRETE AREA
/VOTES
KARf HOUSE
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ViliXR ROOM
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VUaXM SPARTAN CHEMICAL COMPANY SITE FOCUSED FEASIBILITY
PIRNIF WYOMING, MICHIGAN
...*!«!;.,, SITE MAP
1. SOURCE CHEniEOuHCll * ASSOCIATES.
GRAND RAfiDS. UICIIICAN (AuCuSI IJ. 1994)
2 DllS DRAWING UAT BE REPROOUCCD f"OR USE I
BY IMC SIAIC OF UICIIICAN OR IIS
AUTHORISED REPRESENTATIVE.
SCAIE IN ftEl (I'-IOO)
0 SO
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FIGURE 2
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On September 8. 1983, Spartan was added to the National Priorities List of Superfund
sites. This list is made up of hazardous waste sites throughout the country that are
eligible for further study and remediation under the federal Superfund program.
In May 1992, the United States Environmental Protection Agency (EPA) conducted a
site assessment to determine the need for an emergency response action at the site.
The principle focus of the assessment was to determine if there were any threats to
human health or the environment from soil contamination and any onsite containers or
tanks at the site. The findings of the assessment did not support the need for an
emergency removal action.
In June 1993 an Interim Action Record of Decision (ROD) was issued for remediation of
the groundwater. Spartan owners had installed and started operation of a groundwater
treatment system in 1988 as a result of an agreement between the state and the
owners. This treatment system was shut down in January 1993 due to concerns with
continued discharge to the city of Wyoming wastewater treatment plant. The interim
action included an evaluation of the effectiveness and ability of the existing
groundwater treatment system to remediate the groundwater and of discharge options
available for the treated groundwater. It included startup of the system after any
necessary system modifications had been completed. The ROD also stated that
additional investigation would be necessary to better characterize the site, with a focus
on identifying source areas. The need for this additional work resulted in the initiation
of the site Remedial Investigation/ Feasibility Study (RI/FS) in 1994. After review of the
preliminary Rl data, it was determined that the design modifications should be placed
on hold pending completion of the site RI/FS. It became apparent that significant
modifications to the treatment system would be necessary to effectively remove and
treat the contaminated groundwater, above and beyond the scope of the interim action
as specified in the June 1993 ROD. It is anticipated that the additional groundwater
investigation will be completed in two to three years.
Between 1994 and 1996, Rl activities were completed by a state contractor. A Rl
report was finalized in October 1996 that summarizes the investigation activities and the
nature and extent of contamination. It also presents an assessment of the potential risk
associated with exposure to the contamination. A focused FS report was initiated in
1996 and finalized in October 1997. This document includes an evaluation of remedial
alternatives for cleanup of the VOC-contaminated soil. An addendum to the FS will be
completed for the groundwater and any other identified soil contamination, if necessary.
The generation of that document will depend on the completion of the additional
investigation, as noted above.
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C. COMMUNITY PARTICIPATION (See Glossary for definitions of terms used in this
section)
The Responsiveness Summary (Appendix B) discusses the involvement of the
community during the RI/FS and remedy selection process, and shows that the public
participation requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), 1980 PL 96-510, Sections 113(k)(2)(i-v)
and 117 have been met at this site. The decision is based on the Administrative
Record in the Information Repository for Spartan, which is located at the city of
Wyoming Public Library.
D. SUMMARY OF SITE CONDITIONS
The Rl report dated October 1996 documents the results of the Rl at the site. This
summary focuses on soil conditions and the extent of VOC contamination in soil, since
this is what is addressed by the interim action. For additional details concerning site
conditions, please refer to the complete report.
Soil Investigation
During the Rl, 52 soil borings were drilled to the water table to evaluate the nature and
extent of the contamination in the unsaturated zone beneath known or suspected
source areas. In addition, five surface soil samples were taken, independent of the
subsurface boring locations, to evaluate contamination in the upper six inches of soil.
Geology
The boring logs taken from the site show that the unconsolidated material from the
ground surface, to depths ranging from 17 to 95 feet below the ground surface, is
comprised of sand and gravel, with a grain size classification ranging from fine sand to
coarse gravel. Zones of gravel, and sand mixed with gravel, are interbedded
throughout the sand. The confining layer beneath the site ranges from 80 to 90 feet
below the source area, with dramatic rises in the confining layer topography
hydraulically downgradient and adjacent to the source area. Additional investigation
will be necessary to better define the configuration of the confining layer and the effect
on contaminant migration.
Analytical Results
Soil samples collected during the Rl were analyzed for VOCs by the Michigan
Department of Environmental Quality (MDEQ) mobile laboratory. Approximately 20
percent of the samples were also submitted to Contract Laboratory Program (CLP)
laboratories for confirmation of the VOC results obtained by the mobile laboratory and
for base neutral/acid extractables, pesticide/polychlorinated biphenyls, and inorganic
compound analyses. A comparison of the VOC data from the mobile and CLP
laboratories indicates that, in general, the mobile laboratory identified more compounds.
The detection limits reported by the mobile laboratory were lower than those reported
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by the CLP laboratories. A review of the data showed that in most cases the data from
both laboratories were similar, with no one laboratory reporting consistently higher
concentrations than the other. Therefore, the VOC data from the mobile laboratory was
used interchangeably with the CLP data.
The area where soil concentrations exceed the residential cleanup criteria protective of
groundwater is primarily located on the southern portion of the site. Table 1 presents
the maximum concentrations of VOCs detected in site soils. The shaded area in Figure
3 indicates the area of soil contamination. The estimated area of soil contamination is
59,400 square feet, of which 52,723 square feet is on-site, and 6,677 square feet is off-
site. The depth to groundwater varies in this area due to site topography and geology,
therefore, an average depth to groundwater of 15 feet was assumed for the volume
calculations. Using this figure, the volume of soils requiring remediation is 33,000 cubic
yards, with 29,290 on-site, and 3,710 off-site.
Source of Contamination
One purpose of the Rl was to determine the source of groundwater contamination. A
single source has not been identified, rather it appears that there are several sources of
contamination. Likely sources include the former underground storage tanks, the
above ground tanks, and the loading dock area where chemical spills reportedly
occurred.
E. SUMMARY OF RISK (See Glossary for definitions of terms used in this section)
This section presents an assessment of potential human health risks associated with
exposure to contaminants found in the soil at Spartan. Risks associated with exposure
to contaminants in groundwater are not discussed in this interim action ROD, because
the interim action is for remediation of the soils, not groundwater. However, it is
important to point out that a primary reason for conducting a remediation of the soils is
to reduce contaminant migration to groundwater. Several exposure scenarios for the
groundwater that were evaluated in the site risk assessment resulted in unacceptable
risk. Furthermore, several contaminants in the groundwater were detected at
concentrations above federal Maximum Contaminant Levels and Part 201 residential
drinking water values in an aquifer designated as a drinking water resource. For more
detailed information on the risks associated with exposure to the contaminated
groundwater, refer to Volume II of the Rl report.
The objectives of the risk assessment were to provide an analysis of baseline risks in
the absence of any actions to control or mitigate site contamination and to assist in
determining the need for and extent of remediation. The evaluation compared
contaminant levels at the site with state and federal standards, considered the manner
in which people could be exposed to the contaminants, and estimated whether the
contaminants could pose a threat to human health and the environment. The risk
assessment determines actual or potential carcinogenic risks and/or toxic effects the
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Table 1. Maximum concentrations of VOC contaminants in soil and the Part 201
residential cleanup criteria .
Compound
'
Acetone
Benzene
Chlorobenzene
cis-l,2-Dichloroethene (1,2-DCE)
Ethylbenzene
2-Hexanone
Methylene chloride
Styrene
Tetrachloroethene (PCE)
Toluene
1,1,1 -Tnchloroethane (1,1,1 -TC A)
Trichloroethene (TCE)
1 ,3,5-Trimethylbenzene
1 ,2,4-Trimethvlbenzene
Vinyl chloride
Xylenes (total)
Maximum Concentration
in ug/kg2
44,000
8,400
15,000
24,000
450,000
39,000
3,400
3,900,000
1,000,000
3,300,000
190,000
460,000
240,000
920,000
! 46
4,000,000
State Generic Residential
Cleanup Criteria
ug/kg
15,000
100
2.000
1,400
1,500
20.000
100
2.700
100
16.000
4,000
100
460
5.100
40
5.600
^ Pan 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended.
[ug/kg = micrograms per kilogram
"Drinking water protection criteria.
Note: Site risks due to ingestion of, and dermal contact with, soils would be addressed by remediation to the generic residential
cleanup criteria. Also, high detection limits were reported by the laboratory for samples with high concentrations. This means
that there are likely other compounds in the soils that were not detected that could be above their respective cleanup criteria.
This will be addressed during verification of soil remediation sampling.
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BULDNQS
I WAREHOUSE
2 WAREHOUSE
3 OFFICE BUILDING
4 DRUM BUILDING
5 STORAGE
6 LOCKER ROOM
7 TOOL CRIB
8 EVAPORATOR BUILDING
9 WAREHOUSE
10 AIR S1RIPPER UNIT
SB-5JG
LEGEND
MONITORING WELL
SOIL BORING
A BENCHMARK
SOURCE AREA AND SOIL CONTAMINATION
EXCEEDING GENERIC RESIDENTIAL
CLEANUP CRITERIA
/VOTES
I. SHADED AREA IDENTIFIES LOCATIONS
WITH AT LEAST ONE VOt.AlllE
ORGANIC COMPOUND EXCEEDING THE
RESIDENTIAL CLEANUP CRITERIA.
2. SOURCE: CHETTLEBURCH & ASSOCIATES,
GRAND RAPIDS, MICHIGAN
(AUGUST 13. 1994)
3. THIS DRAWING MAY BE REPRODUCED
FOR USE BY THE STATE OF MICHIGAN
OR ITS AUTHORIZED REPRESENTATIVE.
SCALE IN FEET
60
120
240
PIRNIE
) i5u?
SPARTAN CHEMICAL COMPANY SITE
N
WYOMING, MICHIGAN
'H SMII Vdc CON I'AMINAIIHN
U41CVLU f>lf>N/[ CHONCCRS. tLP
£>Sr LAH3HC.
"IGURI" .5
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chemical contaminants at the site pose under current and future land-use
assumptions using a four step process. The four step process includes: hazard
identification, exposure assessment, toxicity assessment, and risk
characterization.
1. HAZARD IDENTIFICATION
During hazard identification, relevant site data are compiled to identify chemicals
of potential concern. The concentrations of contamination found in soil at the
site can be found in Chapter 5 of the Rl report. The chemicals of potential
concern detected in soil are listed in Table 2. Primary chemicals of concern
include sixteen VOCs, twenty inorganics, and cyanide. Due to the nature of this
site, it is anticipated that once background concentrations or leachate analyses
are completed, the inorganics will no longer be chemicals of potential concern in
the soil. However, if this is not the case, the need to conduct an additional
Remedial Action (RA) to address the inorganic contamination will be evaluated.
2. EXPOSURE ASSESSMENT
The objective of the exposure assessment is to estimate the type and magnitude of
human exposure to the chemicals of potential concern that are present at, or migrating
from, the site. Actual or potential chemical release pathways are evaluated, and
potentially exposed populations and exposure pathways are identified. The risk
assessment examined potential pathways of concern to human health under both
current and future land-use scenarios for the immediate site property and surrounding
area. To differentiate between potential chemical exposures, the site was divided into
four separate areas. The areas include the concrete area on Spartan property, the
grass area on Spartan property, the surrounding industrial area, and the school area.
The following major pathways were selected for detailed evaluation under the current-
use and future-use conditions:
- Current preadolescent exposed to surface soil in the school area.
- Current adolescent exposed to surface soil in the grass area (i.e., trespassing).
- Current site worker exposed to surface soils in the industrial area.
- Future site worker exposed to surface soils in the concrete or grass areas.
- Future adult residential use (exposed to soils in the concrete, grass, industrial,
or school areas, to groundwater, and to intrusion of chemicals from soil and
groundwater through a basement).
- Future child residential use with the same exposures as noted above.
- Future construction worker exposed to soils in the concrete, grass, industrial, or
school areas.
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TABLE 2
COMPOUNDS OF CONCERN
SPARTAN CHEMICAL COMPANY SITE FEASIBILITY STUDY
Soil
Groundwater
VOCs
Tetrachloroethene
cis-1 ,2-Dichloroethene
Ethylbenzene
Methylene chloride
1 .1 ,1-Trichloroethane
Trichloroethene
1 ,3.5-Trimethylbenzene
1 ,2.4-Trimethylbenzene
"oluene
Xylenes
Styrene
Acetone
2-Hexanone
Benzene
Chlorobenzene
Vinyl Chloride
retrachloroethene
1 ,2-Dichloroethene (total)
Ethylbenzene
1 .1 ,1 -Trichloroethane
Trichloroethene
1 ,2,4-Trimethylbenzene
Toluene
Xylenes
Styrene
Acetone
2-Hexanone
Benzene
Chlorobenzene
Vinyl Chloride
Methylene Chloride
1,1 Dichloroetnane
4-Methyl-2-Pentanone
2-Butanone
Chioroethane
Chloroform
1,2 Dichloroethane
Ethyl acetate
1,1 Dichloroethene
BNAs
4-Methylphenol
Naphthalene
PestJcides/PCBs
Inorganic Compounds
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Cyanide
Aluminum
Antimony |
3arium |
Cadmium |
Chromium J
Cobalt I
ran
.ead
Manganese
Sodium
Thallium
Zinc
Cyanide
rhe concentrations of each compound listed exceed the Generic Residential Cleanup Criteria in greater than 5% of the samples.
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3. TOXICITY ASSESSMENT
In the toxicity assessment, toxicity data for each of the chemicals of potential
concern is summarized. The purpose of the toxicity assessment is to
characterize the relationship between the magnitude of exposure and the
potential that an adverse effect will occur. The potential health effects for the
identified chemicals of concern at Spartan are discussed in Section 7.3 of
Volume II of the Rl report. Additional information can be found in Appendix J of
the same report.
4. RISK CHARACTERIZATION
For each potential human receptor, site-specific contaminants from all relevant
routes of exposure were evaluated. Both noncarcinogenic health risk effects and
carcinogenic health risks were estimated. This section will focus on exposure to
contaminated soils only. Human health risks are quantified by calculating the
noncarcinogenic and carcinogenic risk factors for the chemicals detected at the
site. For noncarcinogenic health effects, the NCR states that acceptable
exposure levels shall represent concentration levels to which the human
population, including sensitive subgroups, may be exposed without adverse
effect during a lifetime or part of a lifetime, incorporating a margin of safety. In
practice, the EPA defines this as both hazard quotients for individual chemicals,
and hazard indices (HI) for multiple chemicals, that must be less than or equal to
1.0 to be considered an acceptable risk. For known or suspected cancer
causing chemicals (carcinogens), the NCR states that the acceptable risk range
is generally between one additional case of cancer for every 10,000 (1x10^) to
1,000,000 (1x10"6) people exposed. The MDEQ manages cancer risk to no
more than one additional case of cancer for every 100,000 (1x10"5) people
exposed to a chemical.
a. Noncarcinogenic Health Risks
The current scenario indicates there are no unacceptable risks due to
exposure to site contaminants under the current site uses, taking into
consideration the' school to the east of the Spartan property and the
existing industrial/commercial area to the west.
For the future scenario, the site presents a public health concern if the
Spartan property were to become a residential property. Potential risks to
an adult resident would be from dermal contact with contaminants in the
soil found in the concrete area (Hl=2). The primary noncarcinogenic risk
for a future child resident would be due to ingestion of soils in the concrete
area (Hl=4), dermal contact with soil in the concrete area (Hl=3), ingestion
of soil in the school area (Hl=2), and dermal contact with soil in the school
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area (Hl=2). The main contaminants contributing to the risk vary
somewhat depending on the specific exposure route, but includes PCE,
TCE, toluene, arsenic, and aluminum.
The final scenario evaluated was a construction worker in the site area.
Noncarcinogenic risk exceeding the acceptable level would be from
inhalation of respirable particulate matter from soils in the school area due
to manganese (Hl=2). Since this potential risk only slightly exceeds the
risk level and is based on only limited data, additional sampling will be
conducted for further evaluation.
b. Carcinogenic Health Risks
For the current scenarios, even though the calculated cancer risk is within
the risk range specified in the NCR, it is slightly above the state risk range
of 1 additional cancer case in 100,000. This potential risk is due to
ingestion of surface soil from samples taken on the school property near
the Spartan fence, resulting in a risk of 2 in 100,000, primarily due to the
presence of PCE and arsenic. Dermal contact with surface soils in the
same area, results in a risk of 5 in 100,000. This calculated risk is
primarily due to the presence of PCE and beryllium in the soils.
For the future residential scenarios, the state acceptable risk level of 1
excess cancer case in 100,000 would be exceeded for ingestion of soil in
the concrete area, dermal contact with soil in the concrete area, ingestion
of soil in the industrial area, ingestion of soil in the school area, and
dermal contact with soil in the school area by an adult resident. The state
risk level of 1 excess cancer case in 100,000 would be exceeded for
ingestion of soils in the concrete area (8x10"5), dermal contact with soils in
the concrete area (5x10"5), ingestion of soils in the industrial area (4x10'5),
ingestion of soils in the school area (7x10"5), and dermal contact with soils
in the school area (3x10'5) by a child resident.
No other exposure pathways evaluated resulted in unacceptable risk. The risks that
were reported are based on long-term exposure and actual ingestion of, or contact with,
the contaminated soil. This means that remediation of the contaminated soil is
warranted to prevent this long-term exposure.
A quantitative ecological risk assessment was not conducted for this site, due to the
location and nature of the site. No surface water is currently affected or threatened by
the contamination, nor are there any other current environmental issues, other than
protection of the groundwater aquifer as a resource.
A more detailed analysis of site risk can be found in Volume II of the Rl report.
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F. RATIONALE FOR ACTION AND SCOPE OF THE SELECTED REMEDY
This ROD addresses an interim remedy for VOC contamination in soil at the Spartan
site under CERCLA. The selected remedy will achieve soil residential cleanup criteria
protective of groundwater as a drinking water source under Part 201, Environmental
Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA
451, as amended (NREPA). There is a potential for unacceptable concentrations of
contaminants found in the soils to pose a threat of exposure as detailed in the above
section. The contaminant concentrations in soil also continue to act as a source of
groundwater contamination. By eliminating the source area, migration to groundwater
should be greatly minimized. This action will also achieve significant risk reduction
quickly, while a final remedial solution is being developed. This interim action will be
consistent with any planned future actions.
G. SOIL ALTERNATIVES (See Glossary for definitions of terms used in this section)
Based on the results of the Rl, the MDEQ conducted a focused FS on the contaminated
soils. Other than the no action alternative, to be considered, an alternative had to
prevent exposure to contaminated soils through ingestion, dermal contact, and
inhalation of soil particulates. The alternative also had to meet chemical-specific
concentration requirements for the soil or effectively eliminate pathways of exposure
(e.g., containment of contaminated soils). The chemical-specific cleanup goals for the
soil are the state generic residential cleanup criteria protective of groundwater as a
drinking water source generated pursuant to Part 201 of the NREPA.
Presumptive Remedy Approach for Determining the Soil RA Alternatives
To expedite remedy selection at similar types of sites, the EPAffecommends the use of
presumptive remedies. They are based on common categories of sites, historical
patterns of remedy selection at other Superfund sites with similar contaminant types,
and the EPA's evaluation of past performance data of various technologies used at
these sites. The presumptive remedy approach eliminates the need to identify and
screen multiple potential treatment technologies. The EPA already conducted this step
on a generic basis in the document Feasibility Study Analysis for CERCLA Sites with
VOCs in Soils. The EPA recommends the Soil Vapor Extraction (SVE) technology as
the preferred presumptive remedy for sites where VOCs are present in soil and
treatment is warranted. Thermal desorption and incineration may be selected as
presumptive remedies where site conditions indicate that SVE is not appropriate.
Based on the results of a SVE pilot test and site conditions, the MDEQ has determined
that SVE is appropriate for this site. Therefore, no evaluation was done of thermal
desorption or incineration, as allowed by EPA guidance. By proceeding with selection
of a presumptive remedy, the alternative development process has been greatly
simplified and streamlined.
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DESCRIPTION OF ALTERNATIVES
The NCR requires that the alternatives evaluated include a no action response, to use
as a baseline if no action at the site is taken. Therefore, for addressing the VOC-
contaminated soils at this site the two alternatives evaluated in the FS were:
Alternative 1: No action
No response action is taken at the site; therefore, there are no Capital or Operation &
Maintenance (O & M) costs associated with this alternative.
Alternative 2: Treatment of VOC- contaminated soil by SVE
SVE requires the installation of screened extraction wells in the unsaturated soil of the
contaminated zone to remove the vapors in the soil column. Buried PVC piping will be
installed to convey the extracted vapors from the SVE wells to the above ground
treatment equipment. The SVE equipment will likely include an 80-gallon knockout
tank, vacuum pump, and all above ground piping, valves, fittings, monitoring devices,
and appurtenances necessary to make the system function properly. The offgas from
the SVE system would be treated by thermal oxidation. The use of SVE reduces the
risks associated with exposure to the contaminated soil and eliminates the soil as an
ongoing source of groundwater contamination. A pilot test was conducted at the
Spartan site in 1994 to assess the applicability of the SVE technology, and results were
favorable.
Based on the SVE pilot test, it is estimated that a total of five SVE wells will be required
to remediate the soil contaminated with VOCs. Two of the wells that were used during
the pilot test could be used for full scale implementation of this remedy. The time to
complete the soil remediation has been estimated at between one and three years.
The schedule for groundwater remediation could impact this estimate. If the
groundwater goes untreated, the soil in the capillary fringe could be recontaminated by
fluctuating groundwater levels.
Following completion of the soil treatment by SVE, confirmation soil sampling and/or
leachate analyses will be done to ensure that the cleanup goals have been achieved.
The estimated capital cost for this alternative is $872,000, with an annual O & M cost of
$130,000. The present worth cost, which takes into account the total duration of the
remediation, is estimated at between $995,000 if the remedy is completed in one year,
to $1,225,000 if it is completed in three years. Based on site information and the SVE
pilot test, it is predicted that the remediation will be completed in three years or less.
H. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The relative performance of each remedial alternative was evaluated in the FS using
the nine criteria set forth in the NCR. The nine criteria can be divided into three general
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categories: Threshold Criteria, Primary Balancing Criteria, and Modifying Criteria. The
evaluation compares Alternative 1, no action, with Alternative 2, Treatment of VOC-
contaminated soil by SVE.
Threshold Criteria
The following two threshold criteria, overall protection of human health and the
environment, and compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) are criteria that must be met in order for an alternative to
be selected.
V
1. Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether a
remedy eliminates, reduces, or controls threats to human health and the
environment.
Alternative 1 does not eliminate, reduce, or control existing risks to human health
or potential environmental receptors from contaminants at this site. No
protection is provided. Conversely, Alternative 2 would provide protection of
human health and the environment by reducing the concentration of and
eliminating the potential for unacceptable exposure to VOCs in soil. It would also
reduce the concentrations of contaminants migrating into the groundwater.
2. Compliance with ARARs
This criterion evaluates whether an alternative meets ARARs set forth in federal,
or more stringent state, environmental standards pertaining to the site or
proposed actions.
Alternative 1 would not comply with ARARs, since no action would be taken to
reduce or contain the contaminants in the soil that are above acceptable
concentrations pursuant to Part 201 of the NREPA. Under Alternative 2,
cleanup of VOCs in soils to generic residential cleanup criteria protective of
groundwater as a drinking water source, would result in compliance with
chemical-specific ARARs. Alternative 2 will also comply with other ARARs that
are applicable to the actual implementation of SVE, including the Michigan Air
Pollution Control Rules
(PA 451, Part 55) and fugitive dust control requirements (40 CFR 51).
Because Alternative 1 did not achieve the first two primary criteria discussed above, it
was not evaluated for the remaining criteria.
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Primary Balancing Criteria
3. Long-Term Effectiveness and Permanence
This criterion refers to expected residual risk and the ability of an alternative to
maintain reliable protection of human health and the environment over time once
cleanup levels have been met.
Alternative 2 is a well-established technology to effectively remove VOCs from
contaminated soils. A pilot scale test of the technology at the site further
evaluated its effectiveness, and provided confirmation that the technology is
appropriate for the conditions at this site. The generic residential soil cleanup
criteria protective of groundwater as a drinking water source, which is pursuant
to Part 201 of the NREPA, will be achieved for VOCs in soil. For soil, the SVE
technology represents a permanent solution to the VOC contamination.
4. Reduction of Toxicity, Mobility, or Volume through Treatment
This criterion evaluates treatment technology performance in the reduction of
chemical toxicity, mobility, or volume. This criterion addresses the statutory
preference for selecting remedial alternatives which include, as a principal
element, treatment that permanently and significantly reduces the volume,
toxicity, or mobility of the hazardous substances, pollutants, and contaminants.
Alternative 2 significantly reduces the toxicity, mobility, and volume of VOC
contamination through in-situ treatment of the impacted soils. Remediation of
the source area soils mitigates this source of ongoing groundwater
contamination. Thermal treatment of the off-gas from the SVE process results
in destruction of the extracted contaminants to acceptable air quality standards.
5. Short-Term Effectiveness
Short-term effectiveness considers the time to reach cleanup objectives and the
risks an alternative may pose to site workers, the community, and the
environment during remedy implementation until cleanup goals are achieved.
Due to the complexity and concentration of site contaminants, it is difficult to
estimate the time frame for remediation. However, the SVE process generally
takes about one to three years to achieve cleanup goals. The SVE technology
does not present substantive risks to on-site workers or to the community
because minimal disturbance of the contaminated subsurface soils is required to
install the SVE system. Treatment of the off-gases will be incorporated into the
design to reduce air emissions from the treatment system to acceptable levels. It
will take one construction season to implement this remedy.
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6. Implementability
This criterion addresses the technical and administrative feasibility of
implementing an alternative, and the availability of various services and materials
required for its implementation.
Implementation of Alternative 2 would present few, if any, administrative or
technical difficulties. Necessary equipment for SVE is readily available, and the
pilot test provided valuable information on what is necessary to implement SVE
at this particular site. Off-site disposal of contaminated soil would not be an
issue, which simplifies implementation of this alternative.
7. Cost
This criterion compares the capital and present worth costs of implementing an
alternative at the site.
Alternative 2 has an estimated capital cost of $872,000 and an annual O&M cost
of $130,000. The present worth cost is estimated at between $995,000 and
$1,225,000, depending on the time to reach cleanup criteria being one year or
three years, respectively.
Modifying Criteria
8. Support Agency Acceptance
The EPA is in agreement with the selection of Alternative 2 for addressing VOC
contamination in the soil at the Spartan site. Alternative 2, the only alternative
carried through the detailed analysis, is EPA's presumptive remedy for soils
contaminated with VOCs.
9. Community Acceptance
A Proposed Plan was released for public comment for 30 days. Comments and
responses to those comments are described in the Responsiveness Summary,
which is in Appendix B. The public did not express concern with implementation
of SVE for remediation of VOCs in the soil. There were concerns noted on how
long it is taking to remediate this site and the associated cost.
I. THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA and the NCP nine criteria,
the state of Michigan and the EPA, have determined that Alternative 2 is the most
appropriate remedy for addressing the VOC-contaminated soil at the Spartan site. The
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components of the selected remedy are treatment of the VOCs in soil using SVE, with
treatment of the off-gases to achieve acceptable air quality standards.
This remedy is selected because of its ability to protect human health and the
environment from exposure to VOC-contaminated soil, provides permanent treatment,
and is able to meet ARARs. Alternative 2 will also reduce contaminant migration from
the soil to groundwater. The goal of the treatment is to remediate soils to the state
generic residential cleanup criteria using the soil criteria protective of groundwater as a
drinking water source. By achieving these cleanup criteria, the unacceptable risks due
to ingestion of, and dermal contact with, the VOC- contaminated soil will be eliminated.
The soils remedy will cost an estimated $872,000, with $130,000 for annual O & M
costs.
J. STATUTORY DETERMINATIONS (See Glossary for definitions of terms used in this
section)
The EPA's primary responsibility at Superfund sites is to undertake RAs that protect
human health and the environment. Section 121 of the CERCU\ has established
several statutory requirements and preferences. These include the requirement that
the selected remedy, when completed, must comply with ARARs imposed by federal
and state environmental laws, unless the invocation of a waiver is justified. The
selected remedy must also provide overall effectiveness appropriate to its costs, and
use permanent solutions and alternative treatment technologies, or resource recovery
technologies, to the maximum extent practicable. Finally, the statute establishes a
preference for remedies which employ treatment that significantly reduces the toxicity,
mobility, or volume of contaminants. .«„
1. Protection of Human Health and the Environment
Implementation of the selected interim action for remediation of the VOC-
contaminated soil will protect human health and the environment by reducing the
risk of exposure to hazardous substances present in the soil to acceptable risk .
levels.
2. Compliance with ARARs
The selected interim action will comply with all identified federal ARARs, and with
those state requirements which are more stringent. See Appendix B of the FS
report for a complete list of federal and state ARARs. Below is a discussion of
the key ARARs for the selected remedy.
Part 201 of the NREPA incorporates the former Michigan Environmental
Response Act, 1982 PA 307, as amended, and establishes soil cleanup criteria
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to protect groundwater, as well as direct contact criteria, which consider long-
term, systemic exposure from ingestion of, and dermal contact with,
contaminated soil. The SVE treatment process is expected to reduce VOC-
contaminant concentrations in soil to at or below the soil residential cleanup
criteria protective of groundwater as a drinking water source. These criteria are
generated pursuant to Part 201 of the NREPA.
Rules generated bv Part 55. Air Pollution Control, of the NREPA will determine
the requirements to be met for discharge of the off-gases and pretreatment
requirements. The off-gas will likely be treated by either catalytic oxidation or
incineration before discharge to the atmosphere.
3. Cost Effectiveness
Cost effectiveness compares the effectiveness of an alternative in proportion to
its cost of implementation.
The selected remedy for this site is cost effective because it provides the
greatest overall effectiveness proportionate to its costs.
4. Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
The implementation of SVE as an interim action will permanently address VOC
contamination in the soil, by extraction of the VOCs for above-ground treatment
and discharge of the treated vapors to the atmosphere.
5. Preference for Treatment as a Principal Element
The statutory preference for treatment of the hazardous substances present at
the site as a principal element is satisfied, for this interim action.
K. SUMMARY
The selected remedy is the preferred alternative, as presented in the October 1997
Proposed Plan. It will satisfy the statutory requirements established in Section 121 of
the CERCLA, as amended by Superfund Amendments and Reauthorization Act, to
protect human health and the environment, will comply with ARARs, will provide overall
effectiveness appropriate to its costs, and will use permanent solutions and alternate
treatment technologies to the maximum extent practicable.
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APPENDIX A
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GLOSSARY
Administrative Record
A file which contains all information used by the lead agency to make its decision on the
selection of a response action under CEPCLA. This file is available for public review.
Applicable or Relevant and Appropriate Requirements (ARARs)
Section 121(d) of the CERCLA requires that RAs legally meet ARARs of other
environmental laws. Legally "applicable" requirements are those cleanup standards,
standards pf control, and other substantive environmental protection requirements,
criteria or limitations promulgated under federal or state law that specifically address a
hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstances at a CERCLA site. "Relevant and appropriate" requirements are those
requirements that, while not legally applicable to the RA, address problems or situations
sufficiently similar to those encountered at the site that their use is well suited to the
RA.
Nonpromulgated advisories or guidance documents issued by federal or state
governments ("to-be-considered or TBCs") do not have the status of ARARs; however,
where no ARARs exist, or for some reason may not be sufficiently protective,
nonpromulgated advisories or guidance documents may be considered in determining
the necessary level of clean up for protection of human health and the environment.
Aquifer
An underground waterbearing formation composed of sand, soil, porous rock, or gravel
that can store and supply groundwater to wells and springs. Most aquifers in the United
States are within 1,000 feet of the earth's surface.
Risk Assessment
The risk assessment is an analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of any actions to control or
mitigate these releases. The risk assessment assumes no corrective action will take
place and no site-use restrictions or institutional controls such as fencing, groundwater
use restrictions, or construction restrictions will be imposed. There are four steps in the
risk assessment process: data collection and analysis; exposure assessment; toxicity
assessment; and risk characterization.
Cleanup
Actions taken to deal with a release or threatened release of hazardous substances
that could affect public health and/or the environment. The term "cleanup" is used
broadly to describe phases of responses, such as the Remedial Design or Remedial
Action (see separate entries).
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Comprehensive Environmental Response. Compensation, and Liability Act
(CERCLA1 (also known as "Superfund")
A federal law passed in 1980 and modified in 1986 by the Superfund Amendments and
Reauthorization Act (SARA) to investigate and clean up abandoned and uncontrolled
hazardous waste sites. The act created a tax placed on chemical and petroleum
industries that provides revenues to a trust fund. The fund is used when those
responsible for contamination at Superfund sites cannot be found, or cannot perform or
pay for the cleanup work.
Contaminants of Concern
Any of a number of organic compounds or inorganic substances that were detected at a
concentration near or above the current regulatory standard for that particular
substance. The material would be "of concern" because if the concentration exceeds
the regulatory limit, it could be a potential risk to human health or the environment.
Feasibility Study (FS)
Process of evaluating alternative methods for cleaning up a site. Generally, it is
performed at the conclusion of the Remedial Investigation (see separate entry).
Groundwater
Water found beneath the earth's surface that fills pores between materials, such as
sand, soil, or gravel. In aquifers, groundwater occurs in sufficient quantities that it can
be used for drinking water, irrigation, and other purposes.
Hazard Index (HI)
The HI, an expression of noncarcinogenic toxic effects, measures whether a person
may be exposed to adverse levels of noncarcinogens. The HI provides a useful
reference point for gauging the potential significance of multiple contaminant exposures
within a single medium or across multiple media. The HI for noncarcinogenic health
risks is the sum of all contaminants for a given scenario. Any HI value greater than 1.0
suggests that a noncarcinogen potentially presents an unacceptable health risk.
Hazardous Substance
Any material that poses a threat to public health and/or the environment. Typical
hazardous substances are materials that are toxic, corrosive, ignitable, explosive, or
chemically reactive.
Information Repository
A file containing historical and current information, technical reports, and reference
documents regarding a Superfund site. It is usually located in a public building that is
convenient for local residents, such as a public school, city hall, or library.
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National Contingency Plan (NCR)
The NCR provides the organizational structure and establishes procedures for
responding to discharges and releases of hazardous substances, pollutants, and
contaminants.
National Priorities List (NPL)
The NPL is a published list of hazardous waste sites in the United States that are
eligible for extensive cleanup action under the Superfund program.
Operation and Maintenance (O&M)
O & M activities are conducted at a site after a RA has been completed to ensure that
the cleanup or containment system continues to function properly.
Part 201. Environmental Remediation, of the Natural Resources and
Environmental Protection Act. 1994 PA 451. as amended
Formerly known as Act 307. the Michigan Environmental Response Act. This part of
Act 451 provides for environmental remediation.
Parts Per Billion (ppbVParts Per Million (ppm)
Units of measurement commonly used to express low concentrations of contaminants.
For example, a drop of contaminant mixed in a competition-size pool would represent
about 1 ppb of the contaminant.
Presumptive Remedy
A preferred technology for common categories of sites, based on historical patterns of
remedy selection and EPA's scientific and engineering evaluation of performance data
on technology implementation. The purpose of the presumptKiaj-emedy process is to
facilitate and expedite the remedy selection process.
Record of Decision (ROD)
A public document that explains the cleanup method that will be used at a Superfund
site. The ROD is based on technical data gathered and analyses performed during the
Remedial Investigation and Feasibility Study (see separate entries), as well as public
comments and community concerns.
Remedial Action (RA)
The RA phase is the actual construction or implementation of the cleanup method. It
follows the Remedial Design (see separate entry) of the sele'cted cleanup alternative at
a Superfund site.
Remedial Design (RD)
The RD is an engineering phase during which technical drawings and specifications are
developed for the selected cleanup remedy that will be implemented during the
subsequent Remedial Action phase (see separate entry) at a Superfund site.
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Remedial Investigation (Rl)
The Rl is an analysis phase, during which an investigation is conducted into the nature
and extent of the contamination on site. During the Rl, data is collected through
sampling and monitoring to characterize the site. It generally is performed prior to the
Feasibility Study (see separate entry). Ultimately, the information gathered will help to
evaluate cleanup alternatives.
Remedial Investigation/Feasibility Study (RI/FS)
The Rl and FS are typically referred to together as they are usually performed in direct
or overlapping sequence. The Rl portion of the study examines the nature and extent
of the contamination; the FS considers and evaluates different methods to address or
resolve the contamination problems or conditions found during the Rl.
Responsiveness Summary
A summary of oral and/or written public comments received during a public comment
period on key documents prepared by the EPA or state agency and the agency's
responses to those comments. A responsiveness summary is required to accompany a
Record of Decision (see separate entry) at Superfund sites.
Soil Vapor Extraction (SVE)
A common treatment technology used to remove VOCs from within the soil unsaturated
zone. Air is injected into the contaminated zone, and then extracted with the
contaminants for above-ground treatment, if necessary to meet discharge requirements.
This technology is the presumptive remedy for treatment of VOCs in soil.
Superfund
The common name used for the Comprehensive Environmental Response,
Compensation, and Liability Act (see separate entry).
Superfund Amendments and Reauthorization Act (SARA)
Amendments to CERCLA enacted on October 17,1986.
Volatile Organic Compounds (VOCs)
An organic (carbon containing) compound that evaporates (volatilizes) readily at room
temperature. Examples include perchloroethylene, trichloroethylene, vinyl chloride,
benzene, ethylbenzene, toluene, and xylenes.
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Comment 1: How did this ever happen that a high toxic facility was allowed to
be so close to a residential area and a school? How many families are affected?
Who had oversight of that company and what is the company's liability?
Response 1: In the 1950s when Spartan started operation and the surrounding
area was being developed, the risks associated with an operation such as
Spartan was unrecognized. According to the risk assessment for this site, there
are no current risks associated with exposure to the site contaminants. The
majority of the soil contamination is within the fenced site boundary, and the
groundwater that is contaminated is not being used for drinking water. However,
when the future use of the Spartan property and potential future exposures are
examined, there is the potential for exposures to the contamination if it is left .
untreated. Oversight of the company over the years have varied and were the
responsibility of different entities, depending on the aspect of the company under
evaluation. Both state and local regulations have come into play over the years.
State environmental regulations in the 1950s were not the same as regulations
are today. Spartan Chemical owners and operators are liable for the
contamination, however, since bankruptcy was filed by Spartan Chemical, there
is not a viable party to pursue for payment of the investigation and cleanup of
this site. As a result, these activities are being funded by the Superfund
program.
Comment 2: A resident expressed concern with the potential of children being
exposed to contamination in the soil while placing on the soccer field.
Response 2: Nine soil samples were collected in the soccer playing field area
and the abandoned railroad right-of-way between the school grounds and
Spartan Chemical. Three of the samples, all from the area of the unfenced
boundary between the school grounds and the right-of-way, contained arsenic or
manganese at concentrations above the MDEQ generic residential cleanup
criteria. The arsenic concentration in one sample from the right-of-way also
exceeded the MDEQ generic industrial cleanup criteria.
The likelihood that an exposure will cause illness depends on the amount of
chemical present, how long the exposure lasts, how often the exposure occurs,
and personal variability. The Michigan Department of Community Health
(MDCH) has evaluated the data and information from the investigation of the
school grounds and right-of-way. Using conservative assumptions to estimate
the exposure parameters, the MDCH concluded that no one is likely to be
exposed to enough of the contaminants to suffer adverse health effects.
Comments: What about chemicals in the air and what will happen during the
cleanup process? Won't the chemicals be disturbed?
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Response 3: As part of the Rl, air sampling was done around the perimeter of
the Spartan property, and on the property itself, to determine if contaminants
were being released to the air. No contamination was detected. Generally, with
a site that is well-vegetated or covered in concrete, such as Spartan, chemicals
in the soil do not become airborne, unless disturbed. One major advantage to
the SVE process is that during construction, minimal disturbance of
contaminated soil will be necessary. Wells will be installed for injection of air and
extraction of the contaminated soil vapors for treatment. Trenching to install
pipes that transfer the contaminants from the wells in the ground, to the
treatment building will also be necessary. Otherwise, the contaminated soil will
be left in place for treatment. Air sampling will be done throughout this process
to ensure that necessary precautions are taken that will ensure that
contaminants above air quality standards do not go beyond the property
boundary.
Comment 4: Will the SVE be done over the whole property, including
Ambassador Steel, or just in the heavy area and where will the treatment
building be located?
Response 4: The SVE will be done over the entire area of soil contamination
that exceeds residential cleanup criteria for VOCs established pursuant to Part
201 of the NREPA. This will include a small area that extends off the Spartan
Chemical property towards the Ambassador Steel building. Most of the
contamination in the vicinity of the Ambassador Steel building is groundwater
contamination and will be addressed separately.
Comment 5: An area resident expressed concern with what is coming out of
the stack of the existing air stripper due to breathing problems.
Response 5: The air stripper has not been in operation since January 1993.
Any breathing problems due to odors being detected now must be from another
source.
Comment 6: Will there be any digging or trucking of material from the site, and
where would trucks access the site?
Response 6: It would be necessary to do some digging or trenching to install
pipes, as described above in Response 3. Various materials would need to be
trucked into the site, including construction materials for the treatment building,
piping, and other components of the treatment system. Truck access routes to
the site will be determined during the design stage of this project which will be
conducted during 1998, and possibly into 1999. The concern with truck traffic
being allowed down Thornwood Street is noted. Every attempt will be made to
address this concern during the design process.
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Comment?: During 1992, when the EPA did an assessment to determine the
need for an emergency action, why was one not conducted?
Response 7: The results of the assessment did not support the need for an
emergency action at this site. There is not an imminent health threat associated
with this site, however, it has been determined that cleanup of the site is
warranted, as described in the Proposed Plan and ROD.
Comment 8: Explain indemnification.
Response 8: Indemnification is the process of protecting against damage, loss,
or injury, or compensation for such damage, loss, or injury. In this case, it would
involve protection of the city of Wyoming wastewater treatment plant personnel
against liability for any damage, loss, or injury.
Comment 9: Is Lamar Park contaminated, including the lake in the park, and
how often are the monitoring wells checked?
Response 9: Contamination has not been detected in Lamar Park. The lake in
the park was sampled in the 1980s, and no contamination was found. As a
precaution, monitoring wells are located at the entrance of the park to monitor
the groundwater contamination. If contamination is detected, action will be
evaluated to ensure that contamination does not result in unacceptable levels of
contamination reaching the lake. Currently, the monitoring wells are not sampled
on a regular basis. The last time they were sampled was in 1995. Additional
groundwater investigation, including monitoring well sampling, is planned for
1998.
Comment 10: Was Spartan Chemical considered negligent or were there not
enough environmental standards at that time to really take care of the problem?
Response 10: The complete enforcement history of Spartan Chemical has not
been documented. However, there are records of chemical spills occurring at
the site during operation. It is not documented how the spills that were reported
by plant personnel in the 1960s were addressed. Spills that were reported in the
1990s were addressed by Spartan, and enforcement actions were not being
pursued against Spartan specifically related to these spills. However, in 1984,
Spartan Chemical signed a consent order with the MDNR to investigate and
clean up the contaminated groundwater.
Comment 11: What is involved with SVE to bring the toxic vapors and
chemicals up and will it have a high stack?
Response 11: The SVE process extracts the vapors from the ground by a form
of vacuum pumping, and the use of pipes to collect the vapors in the building for
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treatment before release to the atmosphere. The height of the stack will be
determined during the design phase.
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APPENDIX B
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RESPONSIVENESS SUMMARY
Introduction
The public participation requirements of CERCLA Sections 113(k)(2)(i-v) and
117 must be met during the remedy selection process. Section 113(k)(2)(B)(iv)
and 117(b) requires the EPA to respond "...to each of the significant comments,
criticisms, and new data submitted in written or oral presentations." on a
proposed plan for an RA. This Responsiveness Summary addresses any
concerns expressed by the public, potentially responsible parties, and
governmental bodies in written and oral comments received by the state during
the public comment period regarding the proposed interim action for the Spartan
site.
Background
The MDEQ issued Bulletins #1 and #2 to the public in February 1993 and July
1993, respectively, which focused on a groundwater interim action at the site.
Bulletins #3 and #4 were sent out in January 1994 and August 1994,
respectively, on the initiation of the RI/FS for the site, and site update information
with regard to the groundwater interim action. Bulletin #5 released in September
1995 presented results from Phase I of the Rl and plans for a Phase II Rl. The
MDEQ also hosted public meetings on December 17, 1992, August 25, 1994,
and September 19, 1995, to keep the public updated throughout the RI/FS
process.
The Rl report was finalized and released for public review in October 1996. The
FS report and the Interim Action Proposed Plan for the Spartan site were
released to the public for review in October 1997. An information repository was
established at the city of Wyoming Public Library, 3350 Michael Street,
Wyoming, Michigan. The Administrative Record was made available to the
public at the Superfund Section, Environmental Response Division (ERD),
MDEQ, 301 South Capitol Avenue, Lansing, Michigan, and at the information
repository.
A public meeting was held on October 14, 1997, to discuss the FS and the
Interim Action Proposed Plan. At this meeting a representative from the MDEQ
answered questions about the site and the remedial alternatives under
consideration. Formal oral comments on the Proposed Plan were documented
by a court reporter. A verbatim transcript of this public meeting was placed in the
information repository and Administrative Record and written comments were
also accepted. The meeting was attended by approximately 15 persons,
including local residents and business owners, and city of Wyoming and
Michigan Department of Community Health representatives.
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The FS and Interim Action Proposed Plan were available for public comments
from October 8, 1997, through November 8, 1997. Comments received during
the public comment period and the MDEQ's responses to those comments are
included in this Responsiveness Summary. An advertisement announcing the
availability of the Proposed Plan and start of the comment period was published
in the Wyoming Advance and the Grand Rapids Press. In addition, copies of the
Proposed Plan were mailed to all persons on the site mailing list and general
mailing list for all Superfund sites. Over 450 copies of the Proposed Plan were
mailed.
The MDEQ received several oral comments during the October 14, 1997, public
meeting and one written comment letter during the comment period. A summary
of significant comments on the Proposed Plan follow.
Summary of Significant Comments
Written comments:
One letter was received from an adjacent property owner. His issues will be
responded to separately as follows.
Comment 1: The Proposed Plan mailing was not received until the day after the
public meeting.
Response 1: It is unfortunate that the mailing did not make it out to everyone on
the mailing list before the public meeting. Internal review of the draft Proposed
Plan resulted in an unexpected delay in mailing of the document to the public. If
any comments had been received after the public comment period, we would
have considered them during the decision process. The MDEQ did not receive
any late comments or any requests to extend the public comment period.
Comment 2: The personnel at Calvin Christian Junior High School,
Ambassador Steel, and Kent Door should have input into this cleanup problem,
since they are all adjacent to the Spartan site.
Response 2: The Superfund process allows anyone to be involved, including
adjacent property owners. Throughout the process several public meetings were
held and mailings sent to keep interested individuals, including the above,
updated on the progress at the site. The state exceeded the minimum
requirements for public participation throughout the RI/FS process. The state
project manager has also been accessible to address any questions or concerns
throughout the process. No indication was ever made to the MDEQ advising
them that the three entities listed above desired more involvement.
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Comment 3i Spartan is an eyesore and constant drain on the Thornwood
Industrial area.
Response 3: We can not argue that Spartan Chemical is an eyesore. We are
attempting to remediate the contamination under the limits of the Superfund
program to assist with the return of this property to the taxbase.
Comment 4: Nothing has been done in twenty-two years (since the problem
was identified), and nothing will happen in the next twenty-two years. Remove
the complex, clean the dirt in the tank storage area the best you can, and sell the
property. The MDEQ or EPA should remove all tanks and level the remaining
dilapidated structures.
Response 4: The frustration expressed with the length of time that it is taking to
address the contamination is noted. A significant amount of time has been spent
investigating the nature and extent of the contamination. Very high
concentrations of several different contaminants exist in a complex mixture at
this site. Characterization of the site is necessary to be able to design a
remediation system that will be effective. Unfortunately, neither the MDEQ nor
the EPA has the authority to remove all the tanks or level the existing structures
because these actions would not contribute to cleanup of site contamination.
The property had been abandoned as part of the bankruptcy settlement, and will
likely not revert back to the state as part of the tax reversion process, since a
third party is paying the back taxes and now has an interest in the property.
Comment 5. It is tough to justify a million dollar plus expense on a problem that
has been around for over forty years. This is a waste of taxpayer dollars.
Everyone is using municipal, not well water.
Response 5: The Superfund process includes a risk assessment that
evaluates the risk associated with potential exposures to both the contaminated
groundwater and the soil. Based on the results of this risk assessment, there is
the potential for unacceptable exposure to occur other than by drinking the
contaminated water. Unacceptable risk from potential exposure includes dermal
contact with, and ingestion of, contaminated soil; and ingestion, inhalation, and
dermal contact with contaminants in the groundwater.
Comment 6. Once the site has been leveled and cleaned, sell the property for
warehouse space or light industrial so employees can be hired, taxes can be
paid, and the world will go on. This problem was identified over twenty years
ago, yet nothing has been done. In most countries that is beyond the statute of
limitations.
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Response 6: As noted above the state does not have ownership of the
property, hence does not have the authority to sell the property. It is possible
that the party with an interest in the property has plans for reuse. The statute of
limitations does not apply to sites of environmental contamination.
Comment 7. Spartan spent over a million dollars on their groundwater treatment
system from 1988-1993. This was supervised by the MDNR, and shut down by
the city of Wyoming. How many millions of dollars are going to be spent on a
forty year-old problem with no direction?
Response 7: It is noted that cleanup of hazardous waste sites is expensive.
The reason that the treatment system had to be shut down was unavoidable.
When Spartan went bankrupt, the state assumed operation of the treatment
system. The state approached the city of Wyoming to transfer the service
agreement, which allowed discharge of the treated water from the treatment
system to the sanitary sewer, from Spartan to the state. Due to the issues and
legalities associated with accepting this type of wastestream, the city required
that the state indemnify the city as part of the agreement. As a state
government, we could not legally indemnify the city, and could not reach an
agreement without the indemnification language. Therefore, the treatment
system had to be shut down. A state project manager has been assigned to this
site throughout the Superfund process to ensure that the Superfund and state
processes are properly followed. The state project manager has coordinated the
RI/FS activities with both oversight and approval by the EPA, which is resulting in
decisions to clean up the site.
Comment 8. There is no sure fix or solution sponsored by the MDEQ and EPA,
only time and money. If the city of Wyoming residents and general taxpayers
knew the whole story, there would be some very tricky questions that could not
be answered.
Response 8: The SVE treatment will be a permanent solution to VOC
contamination identified in the soil. Groundwater technologies appropriate for
the site are still under evaluation, due to the complexity of the contamination. All
cost information is available, and no information is being withheld from the
public.
Oral comments from October 14.1997 public comment period:
During the oral public comment period, no one at the meeting objected to the
proposed alternative. The public comments consisted of questions about
potential health effects, the proposed remedy, and about the site in general.
Concerns were expressed due to the proximity of the site to a residential area
and school.
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APPENDIX C
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REVISED March 1998
ADMINISTRATIVE RECORD INDEX
SPARTAN CHEMICAL COMPANY SITE
WYOMING, MICHIGAN
Document Title
Installation of Ground
Water Observation Wells
Hydrogeo. Investigation
Author
STS Consultants
STS Consultants
Recipient
MDNR
MDNR
Date
1/9/81
12/81
Location
Administrative
Record
Available upon
Request
Hydrogeo. Investigation
Proposed Work Plan
Prein & Newhof
MDNR
6/22/84
Administrative
Record
Hydrogeo. Study -
Preliminary Remedial
Action Master Plan
Prein & Newhof
MDNR
10/85 Administrative
Record
Work Plan for
Groundwater Purging and
Treatment system
Prein & Newhof
MDNR
12/10/85
Administrative
Record
Letter from EDI to
Spartan Chemical
EDI Engineering
Science
& Spartan 6/3/86
Chemical
Administrative
Record
Phase I Remedial
Action Plan
EDI Engineering
Science
& MDNR
1/87 Administrative
Record
Work Plan on Demo, of
Treatability of Discharge
at Wyoming POTW
EDI Engineering
Science
& MDNR
3/27/87
Administrative
Record
MDNR Review of Work Plan MDNR
on Demo, of Treatability
of Discharge at Wyoming POTW
EDI Engineering 3/27/87
& Science
Administrative
Record
Letter re: Demo, of
Treatability of Discharge
at Wyoming POTW
EDI Engineering
Science
& MDNR
4/7/87 Administrative
Record
Demo, on Treatability of
Proposed Spartan Chemical
Discharge
EDI Engineering
Science
& MDNR
5/6/87 Administrative
Record
Approval Letter Re:
Discharge to POTW
MDNR
EDI Engineering 5/18/87
& Science
Administrative
Record
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REVISED March 1998
ADMINISTRATIVE RECORD INDEX
SPARTAN CHEMICAL COMPANY SITE
WYOMING, MICHIGAN
Document Title
Letter from EDI to MDNR
(re: purge well 2)
Letter from EDI to Litwack
& Litwack (re: purge well 2)
Letter from EDI to t'DNR
(re: purge well 2)
Letter from Litwack &
Litwack to EDI
(re: purge well 2)
Groundwater Monitoring
Program Work Plan
Author
EDI Engineering
Science
EDI Engineering
Science
EDI Engineering
Science
Litwack &
Litwack
EDI Engineering
Science
Recipient
& MDNR
& Litwack &
Litwack
& MDNR
EDI Engineering
& Science
& MDNR
Date
7/24/87
8/19/88
8/26/88
8/29/88
10/28/88
Location
Administrative
Record
Administrative
Record
Administrative
Record
Administrative
Record
Administrative
Record
Groundwater Monitoring
Report
EDI Engineering &
Science
MDNR 2/2/89
The Public 3/89
Administrative
Record
Preliminary Health
Assessment
MDPH/ATSDR
Administrative
Record
Groundwater Monitoring
Report
EDI Engineering &
Science
MDNR
4/21/89
Administrative
Record
Letter from EDI to MDNR
(re:purge well 2)
EDI Engineering
Science
MDNR
9/12/89
Administrative
Record
Groundwater Monitoring
Report
EDI Engineering &
Science
MDNR
11/14/89
Administrative
Record
Letter from EDI to
Spartan Chemical
(re: purge well 2)
EDI Engineering &
Science
Spartan 11/22/89
Chemical
Administrative
Record
Letter from Spartan
Chemical to EDI
(re-, purge well 2)
Spartan
Chemical
EDI Engineering 3/1/90
& Science ^
Administrative
Record
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REVISED March 1998
ADMINISTRATIVE RECORD INDEX
SPARTAN CHEMICAL COMPANY SITE
WYOMING, MICHIGAN
Document Title
Author
Recipient
Date
Location
Letter from WW WW Engineering & Spartan 3/15/90 Administrative
Engineering & Science Science Chemical Record
to Spartan Chemical
(re: purge well 2)
Groundwater Monitoring WW Engineering & MDNR 11/19/90 Administrative
Report Science Record
Letter to the City of WW Engineering & City of 5/30/91 Administrative
Wyoming re: sanitary Science Wyoming Record
service agreement
Groundwater Monitoring WW Engineering & MDNR 6/18/92 Administrative
Report Science Record
Site Assessment Report Ecology & EPA 9/4/92 Administrative
Environment Record
Final Remedial MDNR The Public 10/92 Administrative
Investigation/Feasibility Record
Study Summary Document
Groundwater Monitoring WW Engineering & MDNR 11/4/92 Administrative
Report Science Record
Proposed Plan for Interim MDNR The Public 11/92 Administrative
Remedial Action (Groundwater) Record
Public Notice for Interim MDNR The Public 11/92 Administrative
Groundwater Cleanup Record
Public Comment Period and
for 12/17/92 Public Meeting
Public Meeting Transcribed by MDNR 11/17/92 Administrative
Transcript O'Brien & Bails Record
Air testing results Jim Bedford, Spartan 2/3/93 Administrative
MDPH Chemical Files , Record
Interim Action Record MDNR EPA and the 6/30/93 Administrative
of Decision for Groundwater Public Record
with Responsiveness Summary
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REVISED March 1998
ADMINISTRATIVE RECORD INDEX
SPARTAN CHEMICAL COMPANY SITE
WYOMING, MICHIGAN
Document Title
Groundwater Monitoring
Report
Groundwater Monitoring
Report
Field Sampling Plan
(Groundwater only for 1994)
Interim Groundwater
Monitoring Program - QAPP
RI/FS Work Plan
RI/FS Work Plan
(supplement to CCJM's Plan)
RI/FS Data Package
Explanation of Significant
Differences Document
Work Plan Addendum for
Phase II RI/FS
Author
WW Engineering &
Science
WW Engineering &
Science
Eder Associates .
Eder Associates
CCJM
Malcolm Pirnie
CCJM
MDNR EPA
Malcolm Pirnie
Recipient
MDNR
MDNR
MDNR
MDNR
MDNR
MDNR
MDNR
Date
6/7/93
12/3/93
3/16/94
3/16/94
8/94
B/26/94
3/95
and the Public J.^95
MDEQ
9/95
Location
Administrative
Record
Administrative
Record
Administrative
Record
MDNR Lansing Office
(See Contact Box)
Administrative
Record
Administrative
Record ^^
Replaced by the R^P
Report, which is in
the Administrative
Record .
Administrative
Record
Administrative
Record
Quality Assurance Project
Plan Addendum for Phase II
RI/FS
Malcolm Pirnie
MDEQ
9/95 Administrative
Record
RI Report
Volumes I and II
Malcolm Pirnie
MDEQ
10/96 Administrative
Record
Letter on Risk Assessment
Malcolm Pirnie
MDEQ ,12/12/96 Administrative
Record
Focused Feasibility Study
Report
Malcolm Pirnie
MDEQ 10/3/97 Administrative
Record
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REVISED March 1998
ADMINISTRATIVE RECORD INDEX
SPARTAN CHEMICAL COMPANY SITE
WYOMING, MICHIGAN
Document Title
Author
Recipient
Date
Location
Proposed Plan for an
Interim Action
MDEQ
Public 10/97 Administrative
Record
Supplemental Fact Sheet MDEQ Public 10/97 Administrative
to the Proposed Plan for Record
an Interim Action
Letter on Risk Assessment Malcolm Pirnie MDEQ 10/20/97 Administrative
Record
EPA GUIDANCE:
Presumptive Remedies: Site EPA Various 9/93 Administrative
Characterization and Technology Record
Selection for CERCLA Sites with
Volatile Organic Compounds in
Soils
Presumptive Remedies: Policy EPA Various 9/93 Administrative
and Procedures Record
Feasibility Study Analysis for EPA Various 1993 Available for review
CERCLA Sites with Volatile upon request
Organic Compounds in Soils
-------
REVISED March 1998
For additional information contact:
Sally Beebe, Project Manager
Superfund Section
Environmental Response Division
Department of Environmental Quality
P.O. Box 30426
Lansing, MI 48909
517-373-4110
MDEQ: Michigan Department of Environmental Quality (formerly part of the MDNR)
MDNR: Michigan Department of Natural Resources
MDPH: Michigan Department of Public Health
ATSDR: Agency for Toxic Substances and Disease Registry
RI/FS: Remedial Investigation/Feasibility Study
EPA: U.S. Environmental Protection Agency
-------
REVISED March 199B
ADMINISTRATIVE RECORD INDEX
SPARTAN CHEMICAL COMPANY SITE
WYOMING, MICHIGAN
Document Title Author Recipient Date Location
Proposed Plan for an MDEQ Public 10/97 Administrative
Interim Action Record
Supplemental Fact Sheet MDEQ Public 10/97 Administrative
to the Proposed Plan for Record
an Interim Action
Letter on Risk Assessment Malcolm Pirnie MDEQ 10/20/97 Administrative
Record
EPA GUIDANCE:
Presumptive Remedies: Site EPA Various 9/93 Administrative
Characterization and Technology Record
Selection for CERCLA Sites with
Volatile Organic Compounds in
Soils
Presumptive Remedies: Policy EPA Various 9/93 Administrative
and Procedures Record
Feasibility Study Analysis for EPA Various 1993 Available for review
CERCLA Sites with Volatile upon request
Organic Compounds in Soils
-------
REVISED March 1998
For additional information contact:
Sally Beebe, Project Manager
Superfund Section
Environmental Response Division
Department of Environmental Quality
P.O. Box 30426
Lansing, MI 48909
517-373-4110
MDEQ: Michigan Department of Environmental Quality {formerly part of the MDNR)
MDNR: Michigan Department of Natural Resources
MDPH: Michigan Department of Public Health
ATSDR: Agency for Toxic Substances and Disease Registry
RI/FS: Remedial Investigation/Feasibility Study
EPA: U.S. Environmental Protection Agency
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