PB96-963109
EPA/AMD/R05-96/300
September 1996
EPA Superfund
Record of Decision Amendment:
Sturgis Municipal Well Field
Superfund Site, Sturgis, MI
9/10/1996
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Record of Decision Amendment
Sturgis Municipal Well Field Superfund Site
Sturgis, Michigan
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Record of Decision Amendment
for the
Sturgis Municipal Well Field Superfund Site
Sturgis, Michigan
Site Name and Location
Sturgis Municipal Well Field Superfund Site
City of Sturgis, Saint Joseph County, Michigan
Statement of Basis and Purpose
This decision document amends the September 30, 1991, Record of Decision (ROD) for the Sturgis
Municipal Well Field Superfund Site, in Sturgis, Michigan. This decision document presents the
selected remedial action for the Sturgis Municipal Well Field Superfund Site, and was developed in
accordance with the requirements of the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). Specifically, this decision document has been
prepared in compliance with CERCLA Section 117 and NCP Section 300.43 5(cX2)(ii). This decision
document explains the factual and legal basis for selecting the remedy for this site. The information
supporting this remedial action decision is contained in 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 response action selected in this ROD Amendment, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of the Selected Remedy
The selected remedy is the final remedy for the site. The purpose of this remedy is to eliminate the
source of groundwater contamination and restore the aquifer to its beneficial use.
The major components of the selected remedy include the following:
Soil vapor extraction of VOCs in the Kirsch Property, source area soils to cleanup levels
contained in Part 201 of the Natural Resources and Environmental Protection Act
(NREPA), 1994 PA 451, as amended, Mich. Comp. Laws, § 324.20101 et seq
(hereinafter NREPA Part 201 cleanup levels) which are based on the need to protect
groundwater;
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Extraction and treatment of groundwater using air stripping with vapor phase granular
activated carbon to be used to treat the off-gases and/or treatment of groundwater with
liquid phase carbon. Extraction and treatment will be conducted until Federal drinking
water standards (Maximum Contaminant Levels-("MCLs")) are reached for VOCs. In
addition to achieving Federal cleanup levels, a risk evaluation shall be performed to verify
that there is no unacceptable risk associated with the groundwater;
Discharge of treated water to surface waters (via storm sewer) or to the municipal system;
A minimum of a 30-year groundwater monitoring program to assure the effectiveness of
remedial action and the quality of the municipal water supply.
Declaration of Statutory Determinations
The selected 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. This remedy uses permanent solutions and alternative
treatment or resource recovery technologies to the maximum extent practicable, and satisfies
the statutory preference for remedies that employ treatment that reduces the toxicity, mobility,
or volume as a principal element. Because this remedy will not result in hazardous substances
on site above health based levels, the five year review will not apply to this action.
William E. Muno, Director/ Date
Superfund Division
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STATE OF MICHIGAN
JOHN ENGLER, Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOLLISTER BUILDING. PO BOX 30473. LANSING Ml 48909-7973
RUSSELL J. HARDING, Director
August 23, 1996
Mr. Valdas V. Adamkus, R-19J
Administrator, Region 5
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago, Illinois 60604-3590
Dear Mr. Adamkus:
The Michigan Department of Environmental Quality (MDEQ) is pleased to concur with
the July 3, 1996 draft amendment to the September 1991 Record of Decision for the
Sturgis Municipal Well Field Superfund site in St. Joseph County, Michigan. We agree
that the amended remedy better reflects current site conditions and compliance with
current state and federal environmental cleanup regulations.
If you have any questions, please contact the project manager, Mr. Robert Franks,
Superfund Section, Environmental Response Division, at 517-335-3392, or you may
contact me directly.
Sincerely,
RusselfJ. Harding
Director
517-373-7917-
cc: Mr. Alan J. Howard, MDEQ
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DECISION SUMMARY AMENDED REMEDIAL ALTERNATIVE
STURGIS MUNICIPAL WELL FIELD SITE
STURGIS, MICHIGAN
I. INTRODUCTION
The Sturgis Municipal Well Field Site is located in the City of Sturgis, Michigan. The city
is located in south central Michigan in St. Joseph County. The city encompasses
approximately five (5) square miles and approximately 10,000 people reside in the city.
The aquifer beneath the city supplies the city's residents and numerous industries with
water. Several of the wells have been contaminated with trichloroethene (TCE) or
tetrachloroethene (PCE) and have either been shut down or used for non-consumptive
purposes. Two primary source areas have been identified for the aquifer contamination:
the Kirsch Company Plant No. 1 property (Kirsch) and the former Wade Electric property
(Wade).
The Kirsch property currently consists of offices for the Kirsch Co. and a vacant lot. The
vacant lot and existing buildings had previously been a large manufacturing facility. The
manufacturing facilities previously located on the vacant lot have been demolished.
The Wade property is currently occupied by the Sturgis Archery Center. The Wade
Electric facility closed in 1966 and burned down in 1974. The current property owner
removed six underground tanks from the rear of the Wade facility. According to the
owner, these tanks contained a thick oily substance and were not leaking.
H SITE HISTORY AND ENFORCEMENT ACTIVITIES
On September 30,1991, U.S. EPA signed a Record of Decision (ROD) for the final
remedy at the site. The ROD required soil vapor extraction of volatile organic compounds
(VOCs) (the principal threat) in the source area soils to Type B cleanup levels established
pursuant to the Michigan Environmental Response Act (MERA), 1982 PA 307, as
amended, Mich. Comp. Laws, § 299.601 etseq. and the administrative rules promulgated
thereunder, excavation and disposal of soils contaminated with low-level polynuclear
aromatic hydrocarbons (PAHs) to MERA Type B Cleanup Levels; extraction and
treatment of groundwater by air stripping, with discharge of treated water to surface water
(via storm sewer) or to the municipal system; and a minimum of a 30-year groundwater
monitoring program to assure the effectiveness of the action and the quality of the
municipal water supply. On October 23, 1992, U.S. EPA issued a Unilateral
Administrative Order ("UAO") to Cooper Industries, Inc., ("Cooper") the parent company
of Kirsch, for remedial design and remedial action for an Interim Groundwater
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Extraction/Treatment System. Since its issuance, Cooper has been in compliance with the
UAO. The Interim system was designed to contain the majority of the groundwater
contamination in order to prevent any further degradation of the aquifer and to prevent
groundwater contamination from affecting any other municipal wells.
The interim system was installed and has been operational since May 1994.
ffl. ROD AMENDMENT COMPONENTS
Soil data collected from the Wade and Kirsch source areas as part of the predesign
investigation indicate significant decreases in soil contamination due to natural processes;
most notably VOCs at the Wade source area. This current data prompted U.S. EPA to
reevaluate the necessity of soil remediation for VOCs and PAHs. In addition, U.S. EPA
has reevaluated cleanup standards at the site to reflect current Federal and State
regulations for soil and groundwater and has reevaluated risk at the site to reflect current
Federal guidance on calculating risk at Superfund sites. Cleanup standards for ground
water and soil which were included in the September 30, 1991 ROD were developed to
meet requirements of the Michigan Environmental Response Act (Act 307). In 1994, Act
307 was revised and incorporated into Part 201 of the Natural Resources and
Environmental Protection Act (NREPA). In light of the 1995 amendments to NREPA
Part 201, cleanup standards at the Sturgis Municipal Well Field site will be revised to
reflect current State and Federal regulations. U.S.EPA and the State of Michigan have
determined that the following changes to the ROD cleanup standards are appropriate and
are protective of human-health and the environment.
The major components of the alternate remediation consist of:
• Soil vapor extraction of VOCs in the Kirsch source area soils to cleanup levels
contained in Part 201 of the Natural Resources and Environmental Protection Act
(NREPA), 1994 PA 451, as amended, Mich. Comp. Laws, § 324.20101 etseq
(hereinafter NREPA Part 201 cleanup levels) which are based on the need to protect
groundwater,
• Extraction and treatment of groundwater using air stripping and/or liquid phase carbon
with vapor phase granular activated carbon to be used to treat the off-gases.
Extraction and treatment will be conducted until Federal drinking water standards
(Maximum Contaminant Levels-MCLs) are reached for VOCs. In addition to
achieving Federal cleanup levels, a risk evaluation shall be performed to verify that
there is no unacceptable risk associated with the groundwater,
• Discharge of treated water to surface waters (via storm sewer) or to the municipal
system;
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• A minimum of a 30-year groundwater monitoring program to assure the effectiveness
of remedial action and the quality of the municipal water supply.
This ROD amendment differs from the ROD remedy as follows:
• Soil cleanup levels are changed to reflect current State requirements.
• No action for PAH-contaminated soils at the source areas.
• No action for VOC-contaminated soils at the Wade source area.
• Liquid-phase carbon absorption to treat contaminated groundwater as a possible
substitution or addition to air stripping.
IV. REASONS FOR AMENDING THE 1991 RECORD OF DECISION
Soil data collected from the Wade and Kirsch source areas as part of the predesign investigation
indicate significant decreases in soil contamination due to natural processes; most notably VOCs
at the Wade source area. This current data prompted U.S. EPA to reevaluate the necessity of soil
remediation for VOCs and PAHs. In addition, U.S. EPA has reevaluated cleanup standards at the
site to reflect current Federal and State regulations for soil and groundwater and has reevaluated
risk at the site to reflect current Federal guidance on calculating risk at Superfund sites.
Cleanup standards for ground water and soil which were included in the September 30, 1991
ROD were developed to meet requirements of the Michigan Environmental Response Act (Act
307). In 1994, Act 307 was revised and incorporated into Part 201 of the Natural Resources and
Environmental Protection Act (NREPA). In light of the 1995 amendments to NREPA Part 201,
cleanup standards at the Sturgis Municipal Well Field site will be revised to reflect current State
and Federal regulations.
U.S.EPA and the State of Michigan have determined that these changes to the ROD cleanup
standards are appropriate and protective of human health and the environment.
A. PAH Contaminated Soils
U.S.EPA reevaluated the human health risks associated with direct contact and incidental
ingestion of PAH contaminated soils to reflect current Federal guidance on calculating risk at
Superfund sites and found that there is currently no unacceptable health risks associated with PAH
contaminated soils at the source areas. In general, the 1991 ROD baseline risk assessment used
maximum chemical concentrations and an exposure frequency/duration of 365 days/year over 70
years (lifetime) to calculate risk. The recalculated risk value used the 95% Upper Confidence
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Limit on the Mean (UCLM) for chemical concentrations and an exposure frequency/duration of
350 days/year over 24 years for adults and 6 years for a child under a residential scenario in
accordance with U.S. EPA's Risk Assessment Guidelines ("RAGS"). The recalculated cancer
health risk numbers for dermal and incidental ingestion of carcinogenic PAH's was 3.9e-05 (total)
for children and 1.8e-05 (total) for adults at the Kirsch property and 7. le-06 (total) for children
and 3.2e-06 for adults at the Wade property. These cancer health risk numbers are within the
acceptable risk range under the NCP.
In addition, MERA Type B Cleanup levels for site specific indicator PAH compounds in soil were
changed as a result of the 1995 amendments to NREPA 451 Part 201. The following table
presents a comparison of the former and current cleanup standards which are based on the need to
protect groundwater:
SOIL PAH CLEANUP LEVELS
COMPOUND
1991 RODAct 307 Cleanup
Standards Based on Protection
of Groundwater.
1996 ROD Amendment
NREPA Part 201 Cleanup
Standards based on Protection
of Groundwater. (ng/kg)
Benzo(b)fluoranthene
330
14,000
Benzo(a)pyrene
330
1,400
State Cleanup levels for PAH contaminant compounds in soil were substantially amended under
the new law. Investigation for the cleanup of soil at the source areas indicated that PAH levels in
the soil are generally below the current State cleanup levels. In addition, at the two source areas,
PAHs have not been detected in the groundwater.
Based on the information presented above, excavation and disposal of soils contaminated with
low-level PAHs is no longer necessary. The remedy regarding PAH remediation is amended to no
action.
VOC Contaminated Soils
As part of the pre-design investigation conducted in the fall of 1994, extensive soil data were
gathered at the Wade and Kirsch locations. Analytical data from the soil investigation indicated
that levels of contamination at the Wade location have decreased since the time the ROD was
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written. In fact, when compared to ROD Amendment cleanup levels, the Wade location soil
levels have generally decreased to the point that active remediation is no longer necessary to
protect groundwater at the site. Moreover, the trend of decreasing VOC concentrations in soils
at the Wade location are expected to continue over time. The U.S.EPA and State agree that
implementing a remedy for VOC contamination at the Wade location would not currently add any
benefit to the protection of groundwater at the site. However, VOC soil contamination at the
Wade location will be evaluated over time to insure that the trend of decreasing VOC
concentrations in soil continues. This approach at the Wade location will be protective and
complies with State and Federal ARARs.
State cleanup levels for VOCs in soil were substantially amended under the new law. MERA
Type B Cleanup levels for VOC compounds in soil were changed as a result of the 1995
amendments to NREPA Part 201. The following table presents a comparison of the former and
current cleanup standards in the 1991 ROD for selected VOCs which are based on the need to
protect groundwater:
SOIL VOC CLEANUP LEVELS
COMPOUND
1991 RODAct 307 Cleanup
Standards Based on Protection
of Groundwater. (ug/kg)
1996 ROD Amendment
NREPA Part 201 Cleanup
Standards based on
Protection of Groundwater.
Trichloroethene (TCE)
60
100
Tetrachloroethene (PCE)
14
100
Vinyl Chloride
40
Soil vapor extraction of VOCs at the Kirsch property will still be performed to meet the new State
cleanup criteria, because contamination still consistently exceeds the revised standards..
Verification that cumulative risk associated with the Kirsch and Wade source areas falls within the
acceptable NCP risk range and Hazard Quotient (HQ) ratio requirements was demonstrated in the
original baseline risk assessment. The baseline risk level was calculated using direct contact and
incidental ingestion of VOC contaminated soils under a residential use scenario.
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C. Contaminated Groundwater
MERA Type B Cleanup Levels for VOCs in groundwater were changed as a result of the 1995
amendments to NREPA Part 201. New State cleanup levels for groundwater VOCs are similar
to Federal drinking water standards (MCLs) which are part of the Safe Drinking Water Act 40
CFR 141. Therefore, U.S. EPA chose to use Federal standards (MCLs) for initial VOC cleanup
goals in groundwater with the exception of bromodichloromethane (explained below). The
following table presents a comparison of the former and current cleanup standards for selected
VOCs and cyanide:
INITIAL GROUNDWATER CLEANUP LEVELS
COMPOUND
Trichloroethene (TCE)
Tetrachloroethene (PCE)
l,2Dichloroethane
Bromodichloromethane
1,1,2 Trichloroetnane
Vinyl Chloride
Benzene
Cyanide
1991 ROD Act 307 Initial
Cleanup Standards.
(Hg/kg)
3
1
1
1
1
1
1
100
1996 ROD Amendment
Federal MCL Initial Cleanup
Standards, (ug/kg)
5
5
5
*100
5
2
5
200
* Current NREPA Part 201 initial cleanup number.
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An MCL has not been established for bromodichloromethane. In addition, the cancer risk from
incidental ingestion of bromodichloromethane was 7.4e-06 which is within the acceptable risk
range under the NCP. U.S. EPA determined that it was not necessary to establish a risk-based
cleanup standard because risk was within the acceptable risk range under the NCP and, therefore,
Michigan's 201 cleanup standard which is based on residential groundwater consumption will be
used as an initial cleanup goal.
Once initial groundwater cleanup standards have been achieved for all VOCs, a risk evaluation
shall be performed in accordance with U.S. EPA RAGS to verify that the ultimate goal of the
remedy is met in accordance with the NCP; specifically, that the cumulative risk associated with
the groundwater falls within the acceptable cancer risk range and Hazard Quotient (HQ) ratio
requirements under the NCP. If it does not, U.S. EPA (in consultation with MDEQ) may
determine that additional remedial actions such as additional extraction wells and/or different
extraction well pumping rates are necessary.
V. COMPARATIVE ANALYSIS
The amended remedial alternative will address all remaining principal threats to the public health,
safety, welfare and the environment presented at the site. This section compares the performance
of the amended remedy and the alternative selected in the September 30, 1991 ROD.
The principal difference between the remedy selected in the ROD and the alternative remedy is
that the alternative remedy includes no action for the PAH-contaminated soil at the Kirsch and
Wade sites and no action for the VOC-contaminated soil at the Wade site. The remedy for the
VOC-contaminated soil at the Kirsch site, the VOC-contaminated groundwater in the well field
and the requirement for groundwater monitoring all remain the same. However, the cleanup
standards for these media have been revised to reflect current Federal and State regulations for
soil and groundwater.
A. Threshold Criteria
1. Overall Protection of Human Health and Environment
This criterion addresses whether a remedy provides adequate protection and describes how risks
posed through each pathway are eliminated, reduced or controlled through treatment, engineering
controls, or institutional controls.
Both the amended remedy and ROD remedy minimize the risks posed by direct contact or
ingestion of site-related contaminants by treatment and/or containment. Both remedies are
considered protective of human health and the environment.
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The groundwater component of the amended remedy and ROD remedy are equally effective in
remediating the contaminated aquifers because contaminants are actively contained or extracted,
until health-based cleanup criteria are achieved. Both alternatives are equally reliable in protecting
the water quality of the existing municipal system and private well users.
The soil component of both remedies result in soils which do not pose unacceptable risks due to
direct contact or ingestion and which are protective of groundwater.
2. Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs)
Compliance with ARARs addresses how the proposed remedy complies with all applicable or
relevant and appropriate requirements of federal and more stringent state environmental laws
(ARARs). This section also considers how the alternatives comply with advisories, criteria or
other guidance to be considered (TBCs) that do not have the status of law, but that the U.S. EPA
and the state have agreed are "appropriate" for protectiveness or to carry out certain actions or
requirements.
A summary of identified ARARs for the groundwater and soil alternatives is included below.
Only ARARs necessary for on-site remedial activities have been identified. In some instances,
rules cited contain both substantive and procedural or administrative requirements. Only the
substantive requirements are ARARs for the purpose of on-site activities.
a. Closure
i Federal
Portions of 40 CFR Part 264, regarding standards for owners and operators of hazardous waste
treatment, storage and disposal facilities, are ARARs. 40 CFR 264.94 and 264.100 requirements
are relevant and appropriate. They regulate circumstances sufficiently similar to those at the site
because source area soils are likely to be characteristically hazardous. The requirements in 40
CFR § 264.301,264.303-304,264.310,264.91-100,264.111, and 264.116-117 are applicable
since RCRA hazardous wastes (i.e., chemical precipitation sediments) may be placed in a landfill
after treatment to satisfy land disposal restrictions (LDRs).
ii. State
Certain Hazardous Waste Management requirements, which are contained in Part 111 of NREPA,
Mich. Comp. Laws, § 324.11101 et seq. are ARARs. MAC Rule 299.9612 requirements are not
applicable because source area soils are not contaminated with hazardous waste, which is
regulated under Part 111 of NREPA. However, the requirements are relevant and appropriate
since they regulate circumstances sufficiently similar to those at the site. Levels of contamination
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in the source area soils indicate that these soils would be characteristic hazardous wastes. MAC
Rule 299.9602-9604, 299.9611-9613, and 299.9619.9622 are applicable if NREPA Part 111
wastes are placed in a landfill.
iii. Discussion
Residuals from groundwater and soil treatment alternatives can be handled in such a way that
federal LDR requirements relating to the on-site activities will be met.
b. Groundwater Standards
i. Federal ARARs
Maximum Contaminant Levels (MCLs), and to a certain extent, Maximum Contaminant Level
Goals (MCLGs), the federal drinking water standards promulgated under the Safe Drinking Water
Act (SDWA), 40 CFR 141, are applicable to municipal water supplies servicing 25 or more
people. MCLs and MCLGs are relevant and appropriate to circumstances at the site, since the
aquifers are used for drinking water. MCLGs are relevant and appropriate when the standard is
set at a level greater than zero (for non-carcinogens). Otherwise, MCLs are relevant and
appropriate at Superfund sites. The point of compliance for MCLs and MCLGs is throughout the
plume.
The selected remedy will attain MCLs contained in the SDWA and 40 CFR 141.
ii. State ARARs
The Michigan Department of Environmental Quality has promulgated administrative rules
governing "Environmental Remediation" pursuant to Part 201 of NREPA (NREPA Part 201
Rules). The NREPA Part 201 Rules contain provisions establishing procedures for response
activities, selection of remedial action and cleanup criteria at sites of environmental contamination
where response activities are taken. These Rules contain requirements that are applicable to
remedial action at the Sturgis site because: (1) contaminant levels currently found in the site
groundwater exceed levels set by application of the cleanup criteria and (2) contaminants currently
found in the Kirsch site soils are a potential continuing source of contamination to the
groundwater.
The Michigan Safe Drinking Water Act, 1976 PA 399, as amended, Mich. Comp. Laws,
§ 325.1001 et seqr provides regulations establishing MCLs for certain contaminants in addition to
federal MCLs and would be relevant and appropriate for all groundwater alternatives. MAC Rule
325.10601-10607 requirements are applicable since the aquifer underlying the site is used to
supply a community water system.
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Part 31 of NREPA (formerly the Water Resources Commission Act, 1929 PA 245), Mich. Comp.
Laws, § 324.3101 et seq. contains state water quality standards, treatment plant operator
requirements and wastewater reporting requirements. NREPA Part 31 Rules also implement a
waste effluent discharge system compatible with NPDES requirements and provide for the
non-degradation of groundwater. Because NPDES requirements regulate discharge, these water
quality standards are applicable to both alternatives for on-site discharge to surface water.
iii. Discussion
Both alternatives comply with the requirements of the NREPA Part 201 and its Rules, NREPA
Part 31 and its Rules and the federal and state Safe Drinking Water Acts, as they pertain to
groundwater.
Both the federal and state Safe Drinking Water Acts are relevant and appropriate (the aquifer
under the site is used for a community water supply) to Sturgis groundwater considerations since
they regulate Maximum Contaminant Levels in drinking water for protection of human health.
Both treatment alternatives would meet federal and state groundwater ARARs.
c. Soil Standards
i. State ARARs
NREPA Part 201 and the NREPA Part 201 Rules establish the procedures for determining
cleanup criteria for contaminants in soils. NREPA Part 201 and its Rules are applicable for all soil
alternatives.
ii. Discussion
The ROD remedy was selected based in part on former MERA Type B cleanup criteria, which
have been changed as a result of the 199S amendments to NREPA Part 201. While still protective
of human health and the environment, the new cleanup criteria allow for less stringent soil cleanup
standards for VOC and PAH compounds. Based on the amended Part 201 soil standard, the
selected alternatives would meet federal and state ARARs.
d. Air Standards
i. Federal ARARs
Regarding the Clean Air Requirements, 40 CFR 50.1-50.12 requirements are applicable because
emissions from the groundwater and soil treatment systems would be subject to Primary and
Secondary Ambient Air Quality Standards. Construction and treatment system activities are
potential sources of fugitive dust, particulates and VOCs and would be subject to the TSP
standard.
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ii State ARARs
Certain state Air Pollution requirements, which are contained in Part 55 of NREPA, Mich. Comp.
Laws, § 324.5501 et seq. together with the administrative rules promulgated thereunder are
ARARs. NREPA Part 55 Rules contain requirements for emission limitations and prohibitions for
paniculate matter, fugitive dust and VOCs. MAC Rule 336.1702, 336.1901, and 336.1371-1373
requirements are applicable since emissions from the treatment system would be subject to state
standards for VOCs. Construction activities are potential sources of fugitive dust.
iii. Discussion
It is expected that selected alternatives for soils and groundwater will meet state and federal air
standards. Appropriate practices and controls will be used to achieve compliance.
e. RCRA Land Disposal Restrictions (LDRs)
i. Federal ARARs
RCRA LDRs, 40 CFR Part 268, are applicable for all action alternatives considered for the
Sturgis Municipal Well Field site. Filter media for both groundwater and soil treatment
alternatives are likely to become characteristically hazardous, and therefore, LDRs are applicable
prior to re-use or disposal. If characteristic spent carbon is to be land disposed, it must be placed
into a Subtitle C landfill. When treatment standards for newly identified Toxicity Characteristic
(TC) wastes are promulgated, the characteristic carbon will have to be treated to below the
treatment standard, but then may be disposed in a Subtitle D landfill.
ii. Discussion
Although it is expected that alternatives considered for soil and groundwater could meet RCRA
LDR restrictions, a Treatability Variance for contaminated carbon residuals would be established
to address the possibility that regeneration/thermal destruction cannot reduce ICE and PCE in the
spent carbon to LDR acceptable levels. The treatment level range established through a
Treatability Variance that regeneration/thermal destruction will attain for each constituent of
concern are:
TCE 95-99.9% reduction (Time Weighted Average)
PCE 95-99.9% reduction (Time Weighted Average).
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f. Transportation Regulations
i. Federal ARARs
Certain Department of Transportation requirements concerning on-site activities are ARARs at
this site. If contaminated treatment byproducts (i.e., chemical precipitation, spent carbon, etc.)
are determined to be hazardous wastes under RCRA and are transported off-site, the Department
of Transportation rules for transportation of hazardous materials (40 CFR Part 263) and RCRA
would be applicable to any off-site transportation or handling of the hazardous wastes. In
addition, 49 CFR 107 and 171 requirements are applicable when hazardous wastes are transported
to an off-site disposal facility.
ii. State ARARs
MAC Rule 299.9301-299.9311 generator requirements are applicable for all wastes transported
off-site.
iii. Discussion
It is expected that selected alternatives will meet the transportation ARARs and all legal
requirements for off-site activity identified above.
g. Miscellaneous ARARs
i. Federal ARARs
Since the levels of TCE and PCE in the groundwater are high enough to make the groundwater a
characteristic RCRA hazardous waste, any unit in which the groundwater is treated is subject to
RCRA regulations for tanks, 40 CFR Part 264 Subpart J and/or RCRA regulations for
miscellaneous units, 40 CFR Part 264 Subpart X.
If characteristic carbon is to be regenerated, RCRA regulations for miscellaneous units are
applicable, as set forth in 40 CFR Part 264 Subpart X.
ii State ARARs
Construction activities must comply with substantive requirements promulgated pursuant to Part
90 of NREPA (formerly Soil Erosion and Sedimentation Control Act), Mich. Comp. Laws,
§ 324.9001 et seq. NREPA Part 90 Rule requirements are applicable since construction would
involve earth changes and the potential for soil erosion.
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Certain requirements of Part 625 of NREPA (formerly the Mineral Well Act), Mich. Comp. Laws,
§ 324.62501 et seq. are ARARs. NREPA Part 625 requirements are applicable if extraction and
monitoring wells are installed on-site.
iii. Discussion
It is expected that both alternatives will comply with the miscellaneous ARARs identified above.
B. Primary Balancing Criteria
1. Long-Term Effectiveness/Permanence
This criterion delineates the residual risk and evaluates the ability of an alternative to maintain
reliable protection of human health and the environment over time, once cleanup objectives have
been met.
Both alternatives would offer protection of public health and the environment over the long term
by treating contaminants where necessary to meet NREPA Part 201 cleanup criteria.
2. Reduction of Toxicity. Mobility or Volume Through Treatment
This criterion evaluates the anticipated performance of the treatment technologies a remedy may
employ.
Both alternatives would reduce the toxicity, mobility, or volume (TMV) by removing
contaminants from the groundwater. Although air stripping and liquid phase carbon adsorption
only transfer contaminants from groundwater to another media (and thus do not reduce TMV),
the regeneration of the filter carbon used in the processes would reduce the TMV through
treatment. Both alternatives reduce TMV through the regeneration of the carbon filter media.
3. Short-term Effectiveness
Short-term effectiveness addresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the construction
and implementation period.
The groundwater alternative for both the ROD remedy and amended remedy would actively
reduce levels of contamination. Because of less stringent cleanup criteria, the amended remedy
will achieve cleanup in a shorter time frame. Until groundwater cleanup levels are achieved, only
institutional restrictions on the placement of private wells can be used to discourage the use of
private wells. The potential also exists for worker exposure to contaminated material during
treatment of groundwater for either alternative.
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The amended remedy for PAH-contaminated soil requires no time to implement as the soils would
remain in place. The ROD remedy which required excavation and disposal of PAH-contaminated
soil is no longer appropriate due to the amended Part 201 soil cleanup criteria and the
reevaluation of risk using current U.S. EPA guidelines. The amended remedy eliminates the
potential for worker exposure to contaminated material that would be present under the ROD
remedy.
The amended remedy for VOC-contaminated soil at the Wade site requires no time to implement
as the residual concentrations are protective of groundwater and do not require installation of an
SVE system. The amended remedy for VOC-contaminated soil at the Kirsch site will require less
time than the ROD remedy to achieve protection because the amended Part 201 soil cleanup
criteria are less stringent.
4. Implementability
This criterion considers the technical and administrative feasibility of implementing an alternative,
including the availability of material and services needed to implement a particular option.
Both alternatives considered for groundwater remediation would be relatively simple to implement
and would include construction of new wells for extracting groundwater. Careful planning of new
well installation will reduce the risk of spreading existing contamination. Both discharge options
for treated groundwater are implementable.
Both alternatives for soil remediation are easily implementable at the site. The use of SVE and
excavation with the ROD remedy would be more difficult to implement than the no action
component of the amended remedy.
5. Cost .
The net present worth (NPW) costs for both alternatives considered are presented on the
following table. Costs are based on estimates provided in the Feasibility Study and the September
30, 1991 ROD. The estimated cost to implement the ROD remedy is $13,524,000 and the
estimated cost to implement the amended remedy is $11,712,000. To date, approximately
$4,400,000 have been spent on the interim groundwater extraction/treatment system.
14
-------
ROD
Remedy
Amended
Remedy
Groundwater
Alternative
S11.20M
S11.20M
Kirsch Soils
voc
S.512M*
S.512M*
PAH
S1.664M
0
Wade Soils
VOC
S.057M
0
PAH
S.091M
0
TOTAL
S13.524M
S11.712M
M = Million
*Current estimates by MDEQ are at $1. 1M.
C. Modifying Criteria
1. State Acceptance
The State of Michigan supports the amended remedial alternative.
2. Community Acceptance
Community acceptance of the amended alternative has been evaluated in the Responsiveness
Summary which is a part of this Record of Decision Amendment.
VI.
THE AMENDED REMEDY
Based upon consideration of the requirements of CERCLA, as amended by SARA, and the NCP,
the detailed analysis of alternatives and public comments, U. S. EPA and MDEQ have selected the
amended remedy for remediation of contamination at the Sturgis Municipal Well Field site. The
amended remedy includes ground-water extraction with treatment, using liquid phase carbon
and/or air stripping and vapor phase granular activated carbon to be used to treat the off-gases for
remediation of groundwater contamination. The agencies have also determined that an ISVE
system shall be implemented to remediate source area soils contaminated with VOCs at the Kirsch
site. No action will be required for the PAH-contaminated soils at the Kirsch or Wade sites and
no action will be required for the VOC-contaminated soils at the Wade site.
15
-------
The soil alternative will use NREPA Part 201 residential standards for establishing cleanup levels.
The groundwater alternative will use as initial cleanup goals SDWA, 40CFR141 MCL standards
with the exception of bromodichloromethane which (due to a lack of an MCL) will use NREPA
Part 201 residential standards. In addition, once initial groundwater cleanup standards have been
achieved for all VOCs, a further risk evaluation shall be performed in accordance with U.S. EPA
RAGS to verify that the cumulative risk associated with the groundwater falls within the
acceptable cancer risk range and Hazard Quotient (HQ) ratio requirements under the NCP. If it
does not, U.S. EPA (in consultation with the MDEQ) may determine that additional remedial
actions such as additional extraction wells and/or different extraction well pumping rates are
necessary.
Based on the information available at this time, the U.S. EPA and the State of Michigan believe
that the amended remedy will reduce the risks to human health and the environment by removing
and treating solvent contamination in the groundwater and the source area soils. It is important to
note that the amended remedy will eventually allow for unrestricted use of the city's aquifers and
will remove contamination in the soils to levels protective of groundwater. The amended remedy
will also attain ARARs and use permanent solutions to the maximum extent practicable.
The goal of the amended remedy is to restore groundwater to its beneficial use, which is, at this
site, a drinking water source. Based on information obtained during the RI and on careful analysis
of both remedial alternatives, U.S. EPA believes that the selected remedy will achieve this goal. It
may become apparent, during implementation or operation of the groundwater extraction and
treatment system and its modifications, that contaminant levels have ceased to decline and are
remaining constant at levels higher than the cleanup levels over some portion of the contaminated
plume. In such a case, the system performance standards and/or the remedy may be reevaluated
by the U.S. EPA. However, the groundwater will be monitored for at least 30 years to ensure
that the groundwater remedy is protective of human health and the environment.
The amended remedy will include groundwater extraction for an estimated period of 20 years,
during which the system's performance will be carefully monitored on a regular basis and adjusted
as warranted by the performance data collected during operation. Modifications may include any
or all of the following:
• Discontinuing pumping at individual wells where cleanup levels have been attained;
• Alternating pumping at wells to eliminate stagnation points;
• Pulse pumping to allow aquifer equilibrium and to allow adsorbed contaminants to
partition into groundwater, and
• Installing additional extraction wells to facilitate or accelerate cleanup of the
contaminant plume.
16
-------
VII. STATUTORY DETERMINATIONS SUMMARY
The selected remedy must satisfy the requirements of Section 121 (a-e) of CERCLA, as amended
by SARA, to:
a. Protect human health and the environment;
b. Comply with ARARs (or justify a waiver);
c. Be cost effective;
d. Utilize permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable; and,
e. Satisfy the preference for treatment as a principal element or provide an explanation as
to why this preference is not satisfied.
The implementation of the amended remedy satisfies the requirements of CERCLA, as amended
by SARA, as detailed below:
A. Protection of Human Health and the Environment
This selected remedy will provide protection of human health and the environment through
treatment.
Implementation of the selected alternative will reduce potential risks to human health and the
environment posed by possible use of contaminated groundwater and will eliminate the Kirsch
property as a source of groundwater contamination. Re-evaluation of site risks also indicates
there is no unacceptable direct contact or incidental ingestion risk from PAH and VOC
contaminated soils to potential residential receptors.
No unacceptable short-term risks or cross-media impacts would be caused by the implementation
of the remedy. During the period required for remediation, institutional controls would be used to
mitigate the interim threats from possible use of contaminated groundwater and possible exposure
to contaminated soils. The community and site workers may be exposed to TCE and PCE in the
soils and air, and to dust and noise nuisances during implementation of the groundwater and soil
remedies. Standard safety programs, such as fencing, use of protective equipment, monitoring
and dust control measures, should mitigate any short-term risks..
17
-------
B. Compliance with ARARs
The amended remedy will meet or attain the applicable or relevant and appropriate federal and
state requirements, and will be implemented in a manner consistent with these laws.
In particular, the remedial action selected for implementation at the Sturgis site is consistent with
the National Contingency Plan, SDWA (40CFR 141), the state's NREPA Part 201 Rules, and the
NREPA Part 31 (MAC Rule 323.1041 - R323.1116).
U.S. EPA has selected extraction and treatment of the hazardous substances in the soils to Part
201 generic residential levels. U.S. EPA has selected extraction and treatment of the hazardous
substances in the groundwater to SDWA, 40CFR141 MCL standards as an initial goal. Once
groundwater cleanup standards have been achieved for all VOCs, a risk evaluation shall be
performed in accordance with U.S. EPA RAGS to verify that the cumulative risk associated with
the groundwater satisfies a 1 .Oe-05 cancer risk and an HQ of 1.
The cleanup levels for NREPA Part 201 carcinogens are based on a 1 x 10-' cancer risk and are
consistent with NREPA Part 201 Rules 299.5709 and 299.5723. Where the cleanup level for a
particular chemical is based on analytical detection (MDL), Rule 299.5707(b) has been applied.
Rules 299.5709(b) and 299.5725 provide for cleanup levels based on Human Lifecycle Safe
Concentrations (HLSC); taste and odor (T&O) thresholds are consistent with Rule 299.5709(d);
and Rule 299.5725(b)(I) is the citation for Maximum Contaminant Levels (MCLs), where used.
1. Chemical Specific
The treatment system will comply with the requirements of Michigan Safe Drinking Act, 1976 PA
399, as amended, Mich. Comp. Laws, § 325.1001 et seq. to provide water of an acceptable
quality. Monitoring, with the provisions of installing necessary treatment, provides water supply
protection. If treatment is needed, the water will be treated to levels at or below the Act's
Maximum Contaminant Level (MCL) for TCE and PCE.
The selected alternative for groundwater shall comply (for an initial goal) with the SDWA, 40CFR
141 MCLs with the exception of bromodichloromethane which shall comply (for an initial goal)
with the NREPA Part 201 Rules for generic residential clean-up levels. SDWA initial cleanup
levels for selected chemicals of concern in groundwater are identified in the following table.
18
-------
SDWA 40CFR 141 MCLs
Selected VOC Initial Cleanup Levels for Groundwater (u.g/1)
Trichloroethene (TCE)
, Tetrachloroethene (PCE)
1,2 Dichloroethane
Bromodichloromethane
l,l,2Trichloroethane
Vinyl Chloride
Benzene
Cyanide
5
5
5
*100 (total trihalomethane)
5
2
5
200
* Current NREPA Part 201 initial cleanup number.
The selected alternative for soils shall comply with the NREPA Part 201 Rules for generic
residential cleanup levels. NREPA Part 201 generic residential cleanup levels for ISVE removal
of VOCs in soils, based on twenty times the groundwater standard, are identified in the table
below.
NREPA Part 201
VOC Generic Residential Cleanup Levels for Soil
Protective of Groundwater (ug/kg)
Trichloroethene (TCE)
Tetrachloroethene (PCE)
Vinyl Chloride
100
100
40
The levels of contamination reaching the groundwater extraction wells could exceed the TCLP
limits. The TCLP replaces the Extraction Procedure (EP) in determining if CERCLA wastes are
characteristically hazardous wastes. Under NREPA Part 111, when the TCLP replaces the EP,
hazardous substances exceeding the TCLP limits would also be a hazardous waste under the
19
-------
NREPA Part 111 Rules. To comply with those requirements contained in the NREPA Part 111
and its Rules, the water would be managed as a hazardous waste.
The spent carbon from the air or water adsorption systems could potentially be a characteristically
hazardous waste. The spent carbon would be tested to determine if it would be a hazardous
waste. The generator and transportation requirements of NREPA Part 111 will be followed and
this alternative, therefore, will be in compliance with ARARs.
The soil and groundwater treatment systems will comply with NREPA Part 35 (Air Pollution)
requirements. Best Available Current Technology (BACT) requires treatment of the air emissions
from the air stripper system. These requirements are satisfied through the use of a vapor phase
activated carbon system to remove VOCs from the air stream.
2. Location-Specific
N/A
3. Action-Specific
NREPA Part 90 regulates erosion and sediment control measures during construction. The
selected alternative will comply with these requirements during construction of the treatment
systems.
The Michigan Vehicle Code, 1994 P.A 300, as amended, Mich. Comp. Laws, § 257.1 et seq.
requires a lower maximum axle load on some highways during March, April, and May to prevent
roadway damage. Depending on the weight of the spent carbon units, special routes or scheduling
around these months may be needed to allow unit replacement.
C. Cost Effectiveness
A cost-effective remedy is one for which the cost is proportional to the remedy's overall
effectiveness. The summarized costs associated with the implementation of the selected
groundwater and soil alternatives can be found in Section V.
The selected soil remedy for the Wade Electric source area includes no action for the
PAH-contaminated soil. The selected remedy for the Wade source area also includes no action
for the VOC-contaminated soil.. As the selected soil remedy for the Wade site is no action at no
cost, it is more cost effective than the previous ROD remedy.
20
-------
The selected soil remedy for the Kirsch source area includes no action for the PAH-contaminated
soil. As the selected PAH-contaminated soil remedy for the Kirsch source area is no action at no
cost, it is more cost effective than the previous ROD remedy.
The selected VOC-contaminated soil remedy for the Kirsch source area and the selected
groundwater remedy for the site are the same as in the previous ROD remedy; therefore, the cost
effectiveness is similar except that the soil and groundwater cleanup criteria are less stringent
under the selected amended remedy and can perhaps achieve cleanup in a shorter time period and,
therefore, at a lower cost.
D. Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent Practicable
U.S. EPA, with the State of Michigan's concurrence, has determined that the selected remedy
meets the statutory requirement to utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable for the Sturgis Municipal Well Field site. Of the
alternatives that are protective of human health and the environment and comply with ARARs,
U.S. EPA has determined that the selected remedies for addressing soil and groundwater
contamination provide the best balance of tradeoffs in terms of long-term effectiveness and
permanence, reduction of TMV through treatment, short-term effectiveness, implementability,
cost and state and community acceptance.
The selected remedy represents the maximum extent to which permanent solutions and treatment
can be practicably utilized for this action. The principal threat present in the Kirsch source area
soils will be treated through ISVE of VOCs. Groundwater contamination, which represents the
principal source of site risk, will be actively remediated to restore the resource to its beneficial
use. Institutional controls will be used during remediation to mitigate the risks posed by use of
contaminated groundwater and exposure to contaminated soils.
E. Preference for Treatment as a Principal Element
The selected remedy uses treatment as a principal element. The groundwater remedy will utilize
air stripping and/or liquid phase carbon to remove contaminants from the groundwater. Although
air stripping and liquid phase carbon only transfer contaminants from groundwater to their filter
media (and thus do not reduce TMV), the regeneration of the filter carbon used in the processes
would reduce the TMV through treatment.
The soil remedy utilizes ISVE to remove volatile contamination from the Kirsch source area soils.
Regeneration of the filter media used for the ISVE will reduce TMV through treatment.
21
-------
. DOCUMENTATION OF SIGNIFICANT CHANGES
U.S. EPA did not receive any written comments during the public comment period. Therefore,
U.S. EPA determined that no significant changes to the remedy, as it was originally identified in
the Proposed Plan for the amended remedy, were necessary.
RESPONSIVENESS SUMMARY
This Responsiveness Summary has been prepared to meet the requirements of Sections
113(k)(2)(B)(iv) and 117(b) of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986, which requires the United States Environmental Protection Agency (U.S. EPA) to
respond"...to each of the significant comments, criticisms, and new data submitted in written or
oral presentations" on a proposed plan for remedial action. The Responsiveness Summary
addresses concerns expressed by the public and potentially responsible parties (PRPs) in the
written and oral comments received by the U.S. EPA and the State regarding the proposed
remedy for the Sturgis Municipal Well Field Site.
PUBLIC COMMENT PERIOD/COMMUNITY INVOLVEMENT
A public comment period was held from July 10,1996 to August 9, 1996 to allow interested
parties to comment on the Proposed Plan in accordance with Section 117 of CERCLA. In the
Proposed Plan, the U.S. EPA offered to hold a public meeting to explain the Record of Decision
(ROD) Amendment if there was any public interest. U.S. EPA received no indication that there
was any public interest in a public meeting, therefore, none was held.
Public interest regarding the Site since the original ROD was signed has been minimal. During the
30-day public comment period, U.S. EPA received no written or oral comments concerning the
Proposed Plan. Therefore, no comments are documented in this Responsiveness Summary and no
significant changes to the remedy, as it was originally identified in the Proposed Plan for the
amended remedy, were necessary.
22
-------
AR
U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
STURGIS MUNICIPAL WELL FIELD
STURGIS, MICHIGAN
UPDATE *3
07/08/96
DOCI DATE AUTHOR RECIPIENT TITLE/DE5ER1PTIGN PABES
zzss z-ss ;=s=:s ssassszss zsssssssssxssssss sssss
1 06/19/96 lernll. D.. Padovjni. 3., U.S. .leiorindui re Sturais Hell Field Risk 4
Gradient Corporation EPA; et al. Asiessient
-------
U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
STURBIS MUNICIPAL WELL FIELD
STURGIS, MICHIGAN
UPDATE #2
04/29/96
DOCI DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PA6ES
sasu S3»« sssssa . ss»*as*sa ssxnusssaszasxs . :*sss
1 08/00/94 R.E. Kriqht U.S. EPA OptritiM and Raintinanct Manual for tht 94
Atsociatts, Inc. Sroundiitir Rittdiation Systit: Voluw 1 of 2
(Tut, Figurw, and Tabltt)
2 08/00/94 R.E. Bright U.S. EPA Optration and Haintinanct Hanual for tht 1292
Associate!, Inc. Sroundiattr Rtttdiation SyitMi Volui 2 of 2
[EquiptMt Banuals)
3 08/00/94 Sn.ll Environttntal HDNR/U.S. EPA fttwdial Dtsi|n Hork Plu 245
Group, Inc.
4 03/24/95 Snditnt Corporation Coopir Induitrin/ Nodification to Air Stripping Riport for the Hi
U.S. EPA Cooptr Induttrin-Unch Sitt
S 04/00/9) intll Environitntal HOKR/U.S. EPA Pilot Soil Vapor Extraction Tnt Riport 78
Group, Inc.
& 04/00/95 Snill Environnntal HONR/U.S. EPA Rmdial Otsign Stoproot Soil Invntifation 158
Group, Inc. Hork Plw
7 04/00/95 Sftill Environttfital nDW/U.S. EPA Talk 2: Rmdial taian Soil Inmtiqatioo 297
Group, Inc. Technical Hnorandu
8 04/00/95 Snill Environtentil HDMt/U.S. EPA Task It OMP Aquifir Rittdial Invtitigatioa 144
Group, Inc. Ttchnical Btforandui
9 06/09/95 Hydro-Starch, Inc. Cooptr Induitrits/ Sturqit Bunicipal Kill FitId Intirit ground 34
U.S. EPA Nattr Eitractiofl and Tnatnnt Syttit
Construction Co4plttion Riport •/AttachtMti
and hrch 3, 19f6 U.S. EPA Approval Lttttr
10 10/00/95 Sntll Environmtal RBM/U.S. EPA Tart 2i Rtttdial Ottian Gteproto Soil 214
Group, Inc. Inmtigation Tichaical NtMrandui
-------
t
4HE PACES DATE
91/W/12
91/06/19
91/07/17
91/07/17
91/07/23
91/07/2*
91/07/25
TITLE
ADMINISTRATIVE IECORO
UPOAIC »1
STUtOIS WELL FIELD
STUROIf, NICNICAM
AUTHOR
RECIPIENT
OOOMEMT TTPC
OOCMMCR
•BOTH JUW AND VALIDATED DATA CAN MS HADf AVAIUILE
THKOVGH THE U.S. tfA AHD TOE MICHIGAN DEPAM1MNT OF
NATUKAL RESOURCES (HONK). INTBtlSIED rAHTlCS SHOULD
CONTACT US. TUUSE VANDONSEL Of THE U.S. ETA AT
(311) 3334344 OK MIL KOi FXANX3 Of MONK AT
(SIT) 33S-33nm
Lttttr r«t $tur«U
rewdry Cerperttton't
option* to r««dUt
action p(«n
(Attiehid It Toxic! ty
•nd TLO> rttuttt)
Lttttr rt» Think you
for SO dty •xtwvlon
to eoRntnt on
FtMiblilty ItuoV Rtpertf
•nd rtqut*t for
4. UtMky,
Sturflt roudry Corp.
Bebtrt If. Ttttt.
Coepor JndwtriM
l«tttr rtt Cooperation
of USEM ulth Klrtdi
Division of Coeptr
indMtrlM «nd thtlr
eanetmt •bout
ptctcntu of R!/Ff
Ptui Vcrtntr, Stctt
Sorator, Stitt of
Hletilgtn
Litter ret Installation Nelson N. Olevarrfe,
of fence at Clrsdi Plant Cooper Industrie*
No. 1 end enclosed '
Ttrttt A. VwOonMl,
USCM
Lttttr rt: Copy of
Nidi I gin Klik Asm
Cuidtllnn
Litter ret Clarification Robert U.,Teits,
eoneeminf data or Cooper Industries
deeiaMnts available In
the administrative record
for SturtU «•«» Met*
Lttttr rtt Copy of
ApptndU A and AppandU
D of the Quality
Atsuranca Project Ptm
dated Augwt 1987
Ttresa A. vanOemel,
user*
T. VanOon**!, USCI»A Corrnpandtne*
T. VinOeMcl, UStm CorrMpondwx*
T. VvOanitl, USOA Corrtspendcne*
T. VarConati, USCM Correapondtrc*
R. Perod, Gradient CorMepondenee
Corp*
T. VmOonael, USCFA Correspondence
•i
R. Perad, Gradient Correspondence
Corp.
91/07/30
Lttttr re: Request
Nutson H. OUvarrJt,
T. VanOonsei. US8P* Correspondence
-------
^e xo. 2
7/19/91
PACES DATE
9i/oa/ot
5 91/08/01
6 91/08/05
1 91/08/12
18 91/08/12
2 91/08/12
23 91/08/12
3 91/09/05
ADMINISTRATIVE RECORD INDEX
UPDATE ft
snxcis WELL FIELD SITE
STUtGIS, HICMICAH
TITLE
for hydrogeologlcal
information
(.ttter re: Thank you
for affording gradient
Carp, the opportunity
to review O» data
Letter ret Status
of dsta request node by
Cooper Industries
Letter ret Additional
deficiencies to Varzyn
RI/F8 dacunnt
Letter ret City of
Sturgls spprecietes
efforts of EPA and
MOM to obtain clean-up
of water contamination
Letter ret Eneloeed
copy of suHsry of the
trichlorootiiylene and
tetradiloroethylana
toiicologlcal literature
for inclusion to
administrative coHsants
AUTHOR
Coopar Industries
Ralph J. Parod.
Crodlant Corporation
Teresa A. VanDonsel,
USEPA
Chrlstophar L. S«iti»,
Coopar Induitrits
John Brand. City of
sturgla
Mart I. Nu(hollaa),
Cray, f (ant, Mooty.
Nooty. I Mmatt.
Attomaya for Coopar
Induitrlw, tne.
lattar roi Klrseh Ctam Oxandar, Stat*
Division of Coopar Isprosantatlvw, Stst*
IndwtrfM conetms about of Nlefilgan
eaapiatanasa of KI/FS
Lattar rat USEM Haklnt Robart V. Toots,
aaat of tha rocorda Coopar Industries
rtojjastad avallabl* and
•raiA" request for
additional docusents
(attactiod FOIA requests)
RECIPIENT
DOCUMENT TTPE
T. VanOonsal. USCM Correspondanee
R.Teeta. Correspondence
Cooperlndustries
N.ffyda, 0.».N.N.« I. Carrespondane*
T. VanDonaal, US9A Correspondtneo
11
12
T. VanOonsel, USt*A
T. rfanOonsal, USE»A Correspondence
T. VsnOonstl, MOA Correspondence
U
Letter re: Rtcponse to
tatter dated August
26, 1991 referencing
a telephone conversation
regsrdlng Coopar
Industries request to
Met with theUSEFA
Mary NcAullffe, USEFA N. Hydt, G.P.N.N.I. Cormpondsnca
16
-------
FRANC PAGES DATE
ADMINISTRATIVE IE COO INDEX
UPDATE »1
STUNS IS WELL MELD SITE
STUI6IS, MICHIGAN
TITtB
AUTHOR
RECIPIENT
DOCUMENT TTPf
OOOBJNKR
7t 91/09/12
2 91/08/30
letter rt: Cooper't
concerna about dtnial
of muting with USEPA
and tht remedial
Investigation
Mtws Article Entitled:
Cooper presents city
u«U cleanup plan
Robert u. Tects,
Cooper Industries
Robin Johnson, Sturtis
Journal
T. VftnOonsel. USEPA Correspondence
17
Artiela 18
2* 00/00/00 Cooper Induatries, Inc.'a Cooper Industries, Inc. USEPA, MONK
CosMnt In Regard to
USEPA/MDM Identification
of Potentially
Responsible Parties
Ottiar
27S 00/00/00
37 89/12/13
43 91/06/20
1160 91/08/07
Cooper InduttMM, Inc.'a Cooper InduatMtt, Inc.
CoaaMnta on tht ReMdial
Inwwtlgatfen/Faaaibllity
Study Mith attadMd
CEKLA CoBptfanea Mitk
Other laM Manual)
USEPA and (Out,
Other
Latter ret Eneleaad
responae of Cooper
Induatriee, on behalf
of Klrtdi. to Inforeetlon
Requeat Utter dated
HMMM«^A^» T 1OAO
HwWT^BV* if I ffUP
Tranacript ef Public
Hearint in the aattvr
of SturflU Municipal
Well Field Supertund
Sit*
Ulllatte A. LtMlle,
Cooper Industries
G. Watts, USEPA
Ott'
Other
Letter ret literature
review ef Effectiveneu
of Pu«p and Treat
RaaMoV to Attain ARAR»
(Attached copiea of
all publication*
referenced In letter
and additional
pertinent articles
Hated In the
bibliography)
Mark J. Slaonatt,
Cray, Plant, Moody,
Moody A Bennett,
Attorney* for Cooper
Industries
N. Olavarria, Cooper Other
Ind.
-------
= 39* H0.
•9/19/91
F!CNE/F«AKE PACES DATE
ADMINISTRATIVE R£COW> INDEX
UPDATE 11
STMCIS VELl FIELD SITE
STURGIS, MICNtGAM
Tine
AUTNOt
lECIPtENT
DOCUMENT TTPE
97 90/12/03
Draft, Stltt of
Michigan llsk Asses:
Guidelines
Council en
EnvironMntal Quality
Cesiiittee on llsk
Assess
Reports/studies
24
869 91/08/00
Critique of Vertyn's
••MlIn* lUk Asseaaeant
for the Sturaie W«ll
Field Supwfund Sltt
•nd attached rafaranead
Cradiant Corporation
Attomaya for Coapar *«perta/stud(aa
Ind.
23
1S8 91/08/09
30 91/08/09
321 91/08/09
52 91/08/1*
latter re: Nearby
luticipalitiea which
eenauae treated
cantaainated grounduatar
(Attached lecard of
Oeclaion, Selected
•aaadial Alternative,
Ueat n. Avenue Landfill
alte)
Report Entitled!
Alternative areund-
Uater leaadlation
Concept, Sturtia Well
Field, Sturfia, Michigan
Oirlitopher L. Saltfc
Cooper Induatriea
N. Hyde, G.P.N.N.A leportt/Studles
I.
Hydro-Search, Inc.
Attemeya for Cooper Reporta/Studiea 27
(nd.
Review COBHenta,
Sturfia Well Field
Reaodial Invntlgatlon/
Feniblllty Itudy
Latter rot Copies of
the Alternative
KeBodlatlon Concept,
Review CeaaHnts for
Roaodlal InvestiaatloV
Feasibility Study and
CurrleuluB Vitas for
the professional itaff
at Hydro-Search, Inc.
Hydra-Search Inc.
Maelay I. Hyde.
Gray. Plant, Moody.
Moody I lannatt, P.A.
Attorneys for Cooper
Industries, Inc.
usm
Reports/Studies 28
T. VarOonael. USCM Reports/Studies 29
-------
MO.
09/19/91
TITLE
GUIDANCE DOCUMENTS INDEX, UPDATE II
STUtGIS WELL FIELD SITE. STU1CIS. MICMICAM
Guidance Oocunents ere available for review it
USEPA ttqfen V-Chle««o II
AUTHOR
DATE
Coraunity del it ions in
Super fund: A Handbook
< Inter *• Guidance)
Guidance for Conducting
Remedial Investigations
•nd ftoibillty StudiM
(RI/FS) Undtr CERCU
Pol ley for Super firt
C«pll*ne« Mith tht
ROIA Land Olspoui
Rt«tr
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Paqe Me. 1
09/19/91
AttCNTH GUIDE for the A<*iniatrativa Record
Updata «1
SturoU W«U Maid Sit*
Stur4.ii, Michigan
ACRMTN DEFINITION
ARMS Applicable or lelevtnt
•nd Approprictt
Standard*, Ll«it«tiom,
CrittrU, and
Rfquirvwnts
EP Extraction froeadurt*
rs F*M
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PACES OATE
ADMINISTRATIVE REOKO 1ND«
STUH6I1 UELl F1ELO SITE
STUtCtS. NICHIGAM
rule
AUTHOR
RECIPIENT
OOCUKVT TTPC
JMM S. Llnton, Michigan N. Tyion, USEM
DepartfNnt of
Resourcea
2 91/04/30 letter re: leltef that
Sturgia Well should be
cleaned up to Michigan
Environmental Reponse
Act Type I levela for
both ground natec and
source area eoil
contamination
J30 91/03/20 Copit* ol Act 307 «nd Mldilfw OcpwtMftt of
tht Ad«(»tritlv» |U|M Ntturit Rnouren
to Act 307 (with covvr
Utttf)
1 87/08/19 Jturf<• Grounduatvr
Study to It oUcvmiod
•t
Cormpondcnc*
T. Vin Oenttt, USEPA •Uadino«/OrdM«
Public Hotlc*
t 88/04/20
4* 00/00/00
6 00/00/00
4 87/04/25
64 87/07/00
Notice, Public
SturtU GroundMotcr
Study
City of Stunt• • cow Asteciiti
Pr»ii«lnonr Invmtitation
of TrtchlorMthylwio
Cant••, Remedial Uartyn Engineering, inc.
Investigation/
Feaaibillty Study
•aparn/Studia*
Raporta/Studia*
10
247 88/02/00
Phaa* 1 Technical
Uariyn Engineering. Inc. MOW
Raports/Studiea
11
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«AME PAGES DATE
ADMINISTRATIVE RECOW IMDEX
STUflCIS VEIL FIELD SITE
STVJMIS, NICMICU
riue
MeMorandua. Sturgi* UtU
Field It/ft
AUTNOI
RECIPIENT
DOCUMENT nrpf OOOUCKI
3 68/04/08
131 SS/OS/00
24 88/05/00
9 88/07/18
36 89/03/00
19 89/04/00
S 89/04/OS
228 89/05/00
86 90/02/00
22 90/09/12
Progreaa Report t2
Sturgia Municipal
Wellfield SupeHund
Sltt
Phaaa II CAPP,
Reviaion 1. Baajadial
Inveetigation/feaaiblity
Studr
Phaao 11 Work Flan,
Revlalon I,
RaMdial InvMtigatien/
FtMibllty Study
covtr Ittttr with
attached
Safaty Plan
Raaadlal Invvstiaativ*
Activitln
PhaM III Wort Plan*.
Ht/Fl
11 89/03/10 Preliminary Health
Nidiigan Otpartaant of
Natural t«*curca*
Uanyn Enginacring, Inc. M)aV
Uarxyn Enginacring, Inc. WMI
Kervwth J. Ouim, S. Luxkow, MDM
Wanyn Enginaaring, Inc.
Uartyn Enginaarlng, Inc. NMi
Cantar for Envirotwantal AISDi
Health Sarvicai (CENS),
Nidiigan Oepartaant
of Public Maatth (WM)
Uanyn Englnaaring, Inc.
Michigan Oapartaant
of Natural Ra
work Plan -
Faaabillty Study
Prograaa Rtpert f3
Sturgis Municipal
Wallfiald Sitt
Praliainary rindinga and uartyn Enginacring, Inc. MOM
inttrpratationa, PhaM II
Technical Manorandmi,
Sturgia Wall Fitld Rt/FS
Phaaa III Technical
»I/FJ
Quality Ajauranca Tereia Van Donaal.
Project Plan. Addendua USEPA
Warxyn Engineering, Inc. MOM
USEP*. MOM
Rapertf/ttgdfM 12
Raporta/Studla* 13
Rapertt/Studia* 14
Raperts/Studia* 13
Raporta/Studiaa 16
«
Raports/Studlaa 17
Raportf/Studiea 18
teportt/Studie* 19
Reporta/Studiaa 20
Reports/Studiaa 21
Reporta/Studiaa 22
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.-,9. *0.
J6/OS/91
f[CKE/F*A*E PAGES DATE
ADMINISTRATIVE REOU IHOEX
srureit ucu FIEIO sire
STURGIS, NICIIIOUI
HUE
AUTNOt
RECIPIENT
DOCUMENT TYPE ooautttt
2(8 91/03/00
42 91/03/00
RMadlal Investigation
Raport, Raaadial
Investigation/
Faaeiblllty Study
Volua» 1 of 5
Wariyn Engineering, Inc. ICM
t Instigation Warsyn Enginaarinf, Ine. MMR
Raport, Roaadial
Invattigatien/
FtMiblllty
Voluw 2 of 3
(CDOfts/Studit* 23
(«parts/StudlM 2*
364 91/03/00
\
rt,
Ftnfbdty study
VelUH 3 of S
Uariyn EnfinMring, Inc. MM
••ports/StudlM 25
295 91/03/00
16S 91/03/00
Warsyn Enginaaring, Ine.
Raport. RaMdial
Investigation/
Fawibiifty Study
VolUH 4 Of S
Raaadiat Invaatigation Warsyn Enginaaring, Ine.
Raport, Raaadial
Invtatigation/
F«oalbllty Study
voluv 5 of S
laports/Studlaa
Icports/studiaa
189 91/05/00
179 91/05/00
Ftaaibillty Study,
Stunii wait Maid,
Votua* t
FaasibUlty Study.
Jturfii Wall Flald,
Warsyn Enginaarinf, Ine MMM
, Ine.
laporu/Studlaa 28
Raporta/Studiaa 29
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?J9« MO.
06/05/91
tITLE
GUIOAHCf DOCUMENTS (MDEX
STURGIS WELL FIELD SITE. STUICIS. NtCMICM
Guidance Oocunents tr« available for revteu at
USEPA Reaion v-OHcaao IL
AUTNOt
DATE
Risk Assessment Cufdtnet
far Suptrfund, Veluw I:
H(ji*n Health Evaluation
Part A
USEPA
89/12/00
Btcics of Pimp and Trtat
Ground Uattr Renadiatfon
Tadtnole^y
USEPA
90/09/00
Coamciity Rtlattons in
Suotrfund: A Handbook
(Inttri* Cuidanea)
USEPA
88/06/00
Th« FcMiblllty Study:
Oavclopramt and Sertcning
of R*atd(al Action
Altarnativt*
USEPA
89/11/00
A Guide to Oavolopinf
Suporftrid Propotad Plai
Potter for Suptrfund
Coapilanet with tha
ROM land OUpotal
(Mtrietlon*
USEPA
ROU/HS1M
89/11/00
89/M/17
Suptrfund ID* Cuida
*1: Ovarvim of «CU
Land Disposal
Restrictions (LORD
ROU/MSUA
89/07/00
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Pl?t NO. 1
06/05/91
ACIONTM GUIDE for tht A*hni«tr«tivt teeord
Sturita Wall Flold S
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