PB96-963112
EPA/AMD/R05-96/305
November 1996
EPA Superfund
Record of Decision Amendment:
Metamora Landfill Site,
Metamora, MI
8/28/1996
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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?. 1996
Mr. Valdas V. Adamkus. R19J
Regional Administrator. Region 5
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago, Illinois 60604-3590
Dear Mr. Adamkus:
SUBJECT: Record of Decision Amendment
Metamora Landfill Superfund Site
Lapeer County, Michigan
The Michigan Department of Environmental Quality (MDEQ), on behalf of the State of Michigan, has
determined that the proposed amendment to the 1986 Record of Decision (ROD) for the Metamora Landfill
Superfund site complies with the cleanup criteria in Part 201 of the Natural Resources and Environmental
Protection Act, 1994 PA 451, as amended (formerly known as the Michigan Environmental Response Act),
specifically Section 20118 (1). We therefore concur with the proposed amendment.
If you have any questions, please feel free to contact Mr. Ardon Toland, Chief, Superfund Section,
Environmental Response Division, at 517-335-3393, or you may contact me.
Sincerely,
cc: Mr. John Kuhns, EPA
Mr. Ken Glatz, EPA
Ms. Connie Puchalski, DOJ
Mr. Brian Devlin, DAG
Mr. Alan J. Howard, MDEQ
Mr. Ardon Toland, MDEQ
Mr. Walelign Wagaw, MDEQ
Mr. Robert MacLeod, MDEQ
Metamora Landfill File (J2)
Russell
Director
517-373-7917
EG ISII
AUGl 1996
OF-
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I ^^^7 CD
RECORD OF DECISION AMENDMENT
METAMORA LANDFILL SUPERFUND SITE
OPERABLE UNIT 1
AUGUST 28,1996
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ROD AMENDMENT
OPERABLE UNIT ONE
METAMORA LANDFILL SITE
METAMORA, MICHIGAN
Introduction
The United States Environmental Protection Agency (U.S. EPA) is changing a portion of the
remedy selected in the operable unit one (OU1) Record of Decision (ROD) dated September 30,
1986, for the Metamora Landfill Site.
Background
The Metamora Landfill Site is located in Metamora Township, Lapeer County, Michigan,
approximately one-half mile east of the village of Metamora, and 8 miles east-southeast of Lapeer,
Michigan (figure 1.1). The Site exists on a land parcel approximately 150 acres in size and
contains a 25-acre landfill and two drum disposal areas adjacent to the landfill identified as Drum
Area 1 and Drum Area 4 (figure 1.2). The Landfill was formed by filling pits created by earlier
gravel mining operations. Drummed wastes were also deposited in the Landfill. There are many
steep excavation faces and borrow pits on the Site. Gravel mining processing equipment exists on
the Site immediately south of the landfill, and a licensed solid waste transfer station currently
operates on the west side of the Site. There is a shallow and an intermediate aquifer present
above the bedrock aquifer (the Marshall Sandstone Aquifer). The Marshall Sandstone is the
primary aquifer for domestic wells in the Metamora area, although a few domestic wells obtain
water from the lower sand gravel deposits above the bedrock.
Remediation at the Site has been handled through two discrete operable units. Operable Unit 1
ROD (OU1 ROD) addresses the remediation of drummed waste and contaminated soils in Drum
Area 1 and Drum Area 4. Operable unit two (OU2) addresses the remediation of the landfill and
contaminated groundwater. This ROD amendment applies to the OU1 ROD. Specifically this
document presents an alternative for soil remediation in Drum Area 1. Drum Area 4 drums and
soils have been remediated through the OU1 ROD. The remedy selection for OU2 dated
September 28, 1990, is not changed in any way by this ROD amendment.
OU1 ROD selected off-site incineration of the drums and soils in Drum Area 1 and Drum Area 4.
State lead remedial action work began in the spring of 1989 and continued until December 1990.
During the summer of 1990, off-site incineration capacity became extremely limited and drums
awaiting disposal began to accumulate at the site. In addition, many more drums were discovered
than originally estimated in the Remedial Design. This, in combination with the new RCRA Land
Ban regulations, began to affect remedy implementation.
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In November 1990, negotiations began with Potentially Responsible Parties for the Remedial
Design Remedial Action (RD/RA) for OU2. In April of 1991 a settlement was reached that
addressed the completion of all remedial activity remaining at the site, including the completion of
OU1. This settlement is embodied in the Consent Decree in the matter of The United States vs
BASF-Inmont et al. In September 1991, an explanation of significant difference was issued, but
never implemented, to allow for the option of on-site incineration of drummed waste and
contaminated soils of Drum Area 1. Drum Area 4 had been completed. The consent decree was
entered on March 17, 1993. Off-site incineration of Drum Area 1 drums and severely
contaminated soils (soils containing mobile non-aqueous phase liquids {MNAPL}) continued in
November of that same year, and was complete one year later.
Reasons for Issuing the ROD Amendment
The 1986 ROD specified that Drum Area 1 and Drum Area 4 would be excavated and incinerated
off-site. As excavation activities progressed it became clear that the volume of soils in Drum
Area 1 and Drum Area 4 greatly exceeded the volume estimated as part of the OU1 design. Since
incineration is only required for certain types of contaminated soils, and given a volume of soils
far greater than originally estimated, feasible technologies that could equally protect human health
and the environment in a more cost effective manner needed to be considered. Soils containing
MNAPL and soils with polychlorinated biphenyl (PCB) above 500 ppm content, had to be
incinerated. These soil types were addressed under the Remedial Action completed at the Site in
1995. The Statement of Work (SOW), section I attached to the consent decree, allowed for the
further analysis of Drum Area 1 soils, in addition to the soils in the Soil Staging Area. The results
of the analysis of these soils are presented in the Soil Characterization Report by Conestoga
Rovers & Associates, dated April 12, 1995. The SOW further allowed the Settling Defendants to
propose and evaluate the remedial options available for these soils. The results of this study are
contained in the Soil Remedial Alternatives Report. The results of the studies indicated that these
soils did not require incineration. This ROD amendment evaluates remedial alternatives suitable
for remediating these soils. As provided for in section 300.515(e) of the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) a public comment period was open
from January 29, 1996, through April 29, 1996. Public meetings were held on February 20, 1996
and April 23, 1996. The responses given to the comments received during the public comment
period can be found in the responsiveness summary labeled as ATTACHMENT A to this
document. This ROD Amendment will become part of the Administrative Record pursuant to the
NCP Section 300.825 (a)(2) including responses to comments received during the public
comment period. The Administrative Record can be found at the Site repositories located at:
Lapeer Library
Metamora Branch
4024 Oak Street
Metamora, MI
-and-
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Marguerite deAngeli
Branch Library
921 West Nepessing Street
Lapeer, MI
The Soil Characterization Report
The objectives of the Soil Characterization Report were to characterize the nature and extent of
the constituents left in Drum Area 1 soils, undisturbed soils located beneath Drum Area 1 and
soils which are currently held in the Soil Staging Area; collect all data required to assess the
potential applicability of soil treatment alternatives; and determine the physical properties of the
soils in Drum Area 1.
Following completion of drum removal operations from Drum Area 1, the soils containing no
MNAPL were replaced and covered with two feet of clean soil. Borehole sampling was
completed at 25 locations across the areal extent of Drum Area 1. The boreholes were completed
at approximate 50-foot centers to provide adequate chemical and physical characterization data
for the Drum Area 1 soils. Figure 1.3 presents the typical sampling intervals and chemical
analyses which were conducted for each borehole.
Volatile Organic Compounds (VOCsV Trichloroethene, toluene, ethylbenzene, styrene, total
xylenes and other compounds were present in the Drum Area 1 soils. The highest concentrations
of VOCs existed in the backfilled soils (to 12 foot depths), and the soils within the first several
feet immediately below the bottom of the drum removal excavation (12 to 20-foot intervals). The
analytical data indicates that the total VOC concentrations decrease with depth after 20 feet. For
example, at BH-12, the total detected VOC concentrations in the fill material were 413 mg/kg,
1,832 mg/kg and 12,046 mg/kg at depths of 5, 10, and 20 feet below ground surface (BGS)
respectively. Total VOC concentrations then decrease to 4 mg/kg at a depth of 30 feet BGS and
are less than or equal to 1.5 mg/kg below 30 feet. Data for BH-3, BH-7, BH-9, BH-14, BH-17,
BH-19, BH-21, BH-22 and BH-23 follow a similar trend showing greatly reduced VOC
concentrations at depths greater than 30 feet BGS.
Data for BH-13 also shows a decrease in total VOC concentrations with depth; however, the data
identifies a slightly different pattern. The data at BH-13 shows a significant, but less dramatic,
decrease in total VOC concentrations in the backfilled soils. Total VOC concentrations in the fill
material were 234 mg/kg, 28 mg/kg and 4.4 mg/kg at depths of 5, 10 and 20 feet BGS
respectively. Total VOC concentrations decreased to 17 mg/kg at 30 feet BGS, 24 mg/kg at 40
feet BGS and were less than one mg/kg at depths greater than 40 feet BGS. Data for BH-8, BH-
11, BH-16 and BH-18 also follow this trend.
Semi-volatile Organic Compounds (SVOCs'); A pattern similar to VOCs was found for SVOCs.
Concentrations of phenol, isophorone, naphthalene, Di-n-butyl phthalate, butyl benzyl phthalate
and BIS(2-ethylhexyl)phthalate were consistently present. At the 40 to 42-foot intervals, the
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concentrations of SVOCs and the number of detected contaminants, decreased substantially. The
highest concentration of an SVOC compound in the 40 to 42-foot interval was benzoic acid
(4.1 mg/kg) in BH-18. The remaining detections were at or below one mg/kg. There were no
detections of SVOCs in the samples collected at 50 foot or below. This trend follows the VOC
data.
Polychlorinated biphenvls (PCBs) and pesticides: PCBs, identified as Arochlors 1242, 1248,
1254 and 1260 were detected in the soil samples collected from the Drum Area 1 boreholes at the
zero to 2-foot, 5 to-7 foot and 10 to-12 foot sample intervals. No PCBs were detected at the 40
to 42-foot, 50 to-52 foot or 60 to 62-foot sample intervals. Total PCB concentrations in all but
three samples were less than 50 mg/kg. No pesticides were detected at any interval.
Inorganics: Zinc and Lead showed elevated concentrations in several samples. Zinc ranged from
12-610 ppm and lead ranged from 1.4-1,000 ppm. Concentrations of other inorganics were low.
Based on the data collected, an estimate of the volume of contaminated soils was performed.
The volumes in cubic yards (CY) exceeding the following VOC Concentrations are as follows:
Volume of soils with
Greater than the Identified
Total VOC Concentration Total VOC Concentration
10 mg/kg 20,000 - 34,000 CY
100 mg/kg 9,000 - 15,000 CY
1,000 mg/kg 3,500- 6,000 CY
Soil Staging Area Characterization
Soil samples were collected from the soils currently stored in the Soil Staging Area (figure 1.2).
The pile consists of soils with PCB concentrations below 100 ppm and containing no MNAPL.
This soil is a combination of soils excavated from Drum Area 1 during the Remedial Action and
soils stockpiled during the state lead remedial action. The pile was analyzed for VOCs, SVOCs,
PCBs/Pesticides and Inorganics. The samples were taken from quadrants and the results are as
follows. Total VOCs for Quadrants A and C were approximately 1,200/1,900 mg/kg (duplicate
samples) and 1,300 mg/kg, respectively. Total VOCs for Quadrants B and D were approximately
80 mg/kg and 22 mg/kg, respectively. Total SVOCs for Quadrants A and C were approximately
1,900/1,500 mg/kg (duplicate samples) and 1,700 mg/kg, respectively. Total SVOCs for
Quadrants B and D were approximately 290 mg/kg and 99 mg/kg, respectively. PCB
concentrations were found throughout the pile and ranged from 66 mg/kg to 97 mg/kg. Elevated
concentrations of several metals were detected in the soils, including barium at 640 mg/kg,
cadmium at 8.7 mg/kg, chromium at 330 mg/kg, lead at 2,300 mg/kg and zinc at 870 mg/kg.
Cyanide concentrations ranged from 0.62 mg/kg (Quadrant D) to 2.2 mg/kg (Quadrant C).
Similar to the concentrations of VOCs and SVOCs, the highest concentrations of inorganics were
detected in Quadrants A and C. The Soil Staging Area volume is about 900 cubic yards.
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Sdil Remedial Alternatives
Pursuant to the SOW section 1.2:
"Upon U.S. EPA approval of the Soil Sampling Report. Settling Defendants shall submit
to the U.S. EPA, a report entitled Soil Remedial Alternatives Report, proposing feasible
technologies to remediate the contaminated soils...In this report, Settling Defendants may
propose soil clean-up levels and/or performance standards based on ARARs."
Soil cleanup goals for Drum Area 1 soils were developed to prevent contaminants from leaching
into the groundwater at levels above those specified in the Consent Decree. This approach was
developed to ensure consistency with the ARARs defined for the Site in the ROD and to ensure
that the final Drum Area 1 soil cleanup alternative will be developed and selected in a manner
consistent with the Site-wide (OU2) remedy as identified in the ROD. The excavation of soils
with contamination greater than the MDEQ soil clean-up levels (based on the 20 times the generic
residential clean-up criteria) for groundwater (TABLE 1) indicates that this approach will achieve
these goals as indicated by the analysis of the groundwater beneath Drum Area 1. Data from
March 1989 compared to February 1994 for wells 17S and 17D and 31 (located in and down
gradient of Drum Area 1) indicates that groundwater quality has not changed appreciably over
five years. Excavation and capping of soils from Drum Area 1 having contaminant concentrations
above the "20 times" criteria will achieve the clean-up goals for the Drum Area 1 soils. Based on
the above, the following remedial objectives are identified to address the soils in Drum Area 1:
1. Eliminate or reduce the potential for direct contact with contaminated soils;
2. Eliminate or reduce the potential for volatization of organics to the atmosphere;
3. Eliminate or reduce either Contaminants of Concern (COC) concentrations, or mobility, to
effect corresponding reductions in COC concentrations in the groundwater at the Site
boundary; and
4. Provide an on-site, long-term solution, which will minimize Operation and Maintenance
(O&M) requirements and is consistent with the Site-wide (OU2) remedy.
These objectives are also consistent with the goals established for sites with similar environmental
conditions within the State of Michigan.
The proposed revised cleanup for Drum Area 1 Soils and the Soil Staging Area soils, contain the
following components:
* The excavation of contaminated soils greater than the MDEQ soil clean-up levels based
on the 20 times the generic residential clean-up criteria for groundwater (TABLE 1)
* The placement of excavated Drum Area 1 soils on the south slope of the landfill
* The placement of the Soils Pile soil on the south slope of the landfill, separated from Drum
Area 1 soil.
* The capping of the landfill (OU2 remedy), including this relocated material, with a cap
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equivalent in performance to the SOW cap design criteria.
'* Long term groundwater monitoring (also part of OU2 remedy).
Comparative Analysis
This ROD amendment addresses the final remedy for remediation of contaminated soils which is
one of the principle threats at the site. The remedy selected for OU2 will address the remaining
principle threats, namely the landfill and contaminated groundwater. This amendment to the OU1
ROD incorporates the remediation of Drum Area 1 soils and the Soil Staging soils into the cap
portion of the OU2 remedy. Upon completion of the OU2 remedy, remedial action will be
complete at the site. Long term groundwater monitoring will commence following the
completion of the remedial action.
The Nine Evaluation Criteria
Based on current information, the proposed amended remedy is protective and cost effective
under the nine point criteria that the U.S. EPA uses to evaluate alternatives. This section
compares the performance of the amended remedy with the remedy selected in the September 30,
1986, ROD, and provides the rationale for the selection of the amended remedy.
Overall Protection of Human Health and the Environment. Both of the alternatives
provide protection of human health and the environment by eliminating, reducing or
controlling risk through treatment, engineering controls, institutional controls, or a
combination of these measures. The amended remedy in combination with the OU1 ROD
remedy already performed, addresses the principle threat of source contamination to
groundwater. Both alternatives prevent direct contact with contaminated material
providing protection of human health and the environment. The groundwater extraction
and treatment system will prevent off-site migration of the chemicals in the groundwater
beneath Drum Area 1.
Compliance with ARARs. The amended remedy is designed to meet all
applicable or relevant and appropriate substantive requirements (ARARs) of the
Federal and State environmental laws. As the Soil Staging Area contains PCBs
greater than 50 ppm, the TSCA waiver provisions under 40 CFR 761.75(c)(4) will
be exercised. OSWER Directive No. 9355.4-01 Guidance on Remedial Action for
Superfund Sites with PCS Contamination at 2.2.5, states "Where Superfund
remedial actions will leave PCB's in place or where PCB-contaminated material is
excavated, treated, and re-disposed at concentrations that still pose a threat,
capping consistent with chemical waste landfill requirements is generally
appropriate. (Long-term management controls for PCB-contaminated material
generally will also parallel RCRA closure.) However some of the requirements
specified under TSCA may not always be appropriate for existing waste disposal
sites like those addressed by Superfund. When this is the case, it may be
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appropriate to waive certain requirements, such as liners, under the TSCA waiver
provisions, 761.75(c)(4). Requirements may be waived when it can be
demonstrated that operation of the landfill will not present an unreasonable risk of
injury to health or the environment. This demonstration may require column
studies verifying that PCB movement through the soil will not adversely affect
ground water." Long term monitoring of the groundwater will meet the
substantative requirements of the column studies. Deed restrictions, pursuant to
the terms of the Consent Decree will be placed on the landfill, and will eliminate
possible incidental skin contact and ingestion. The substantive requirements of the
1990 OU2 ROD SOW cap design will meet RCRA cap closure requirements.
Relocating and capping roughly 900 cubic yards of marginally contaminated PCB
soils (less than 100 ppm PCBs) from the Soil Storage Area meets the substantive
requirements of TSCA.
Soils that contained PCBs over 500 ppm were incinerated under OU 1. This is consistent
with U.S. EPA's policy to treat hot spots of contamination when practicable. The original
remedy would incinerate the soils at a TSCA compliant thermal treatment facility.
Both the amended remedy and the original remedy would require compliance with the
substantive requirements of the clean air act and Part 55 of the Natural Resource and
Environmental Protection Act, 1994 PA451, during the excavation portion of the remedy.
Long-term Effectiveness and Permanence. The analysis under this criterion, as
required in the NCP, focuses on any residual risk remaining at the Site after completion of
the remedial action (55 FR 8720). The amended remedy, in combination with the OU2
cap remedy, will eliminate the potential risks for direct contact/ingestion of Drum Area 1
and Soil Staging Area soils. Groundwater monitoring will alert and indicate that
additional treatment is required, in the unlikely event of a contaminant breakthrough.
Deed restrictions, pursuant to the terms of the Consent Decree, will eliminate any
inadvertent use of these properties. The 1986 ROD remedy also provides long-term
effectiveness and permanence.
Reduction of Toxicity, Mobility, or Volume of the Contaminants through
Treatment. The amended remedy will effectively reduce the mobility of the chemicals
under the cap by reducing the infiltration of rainwater through the soils, thereby
decreasing the mobility of COCs. The 1986 ROD remedy reduces toxicity, mobility and
volume through off-site treatment.
Short-term Effectiveness. The benefits of the amended remedy would be realized
immediately upon completion of the remedy (two construction seasons). Dust production
and VOC emissions during excavation is a concern for either remedy, but were
successfully addressed during the first phase of OU1 ROD construction. VOC emissions
can be effectively controlled by regulating the removal rate of the Drum Area 1 soils and
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Soil Staging Area soils, or applying vapor control blankets during soil movement
operations. Wetting agents and engineering controls will be used to control dusts. The
amended remedy would also decrease local truck traffic, compared to the original remedy,
by eliminating the off-site transportation of soils.
Implementability. Soil excavation technologies are common for implementation of either
remedy. Excavation to the depth required is within the limits of standard construction
equipment. Relocation of soils poses no additional cap implementation problems.
Implementation of the proposed ROD amendment avoids off-site incineration problems,
which may include incinerator capacity limitations, incinerator regulatory compliance
considerations, increased personnel exposure, and shipping hazards.
Cost. Based on a combined Area 1 soils and Soil Staging soils volume of 30,900 cubic
yards, the estimated capital cost for the amended remedy is $290,000; present worth
$381,000, roughly 1% of the $29,000,000 cost estimate for off-site incineration of the
30,000 cubic yards. The cost estimate includes excavation costs, cost of additional
material needed to cap the Drum Area 1 and Soil Staging Area soils, and
regrading/seeding of Drum Area 1. The capital costs for capping the landfill as described
in the OU2 ROD, is estimated to be $5,396,000.
State Acceptance. The State of Michigan Department of Environmental Quality has
reviewed and supports the components of the amended remedy.
Community Acceptance. Community acceptance of the amended remedy has been
evaluated in the Responsiveness Summary which is part of this ROD Amendment.
The Amended Remedy
U.S. EPA believes that the amended remedy is the most appropriate solution for the Site based on
the evaluation of its performance against the nine evaluation criteria discussed. The major
components of this remedial alternative include the following:
- excavation of approximately 30,000 cubic yards of Drum Area 1 contaminated soil,
- excavation of approximately 900 cubic yards of Soil Staging Area soils,
- placement in separated areas on the landfill, and capping of these materials under the
OU2 landfill cap,
- regrading and seeding of Drum Area 1,
- implementation of the OU2 remedy, as described in the 1990 ROD, consisting of a
landfill cap, groundwater pump and treat system and institutional controls.
The estimated cost for the amended remedy is approximately $290,000. Operation and
Maintenance and present worth costs are more appropriate for the Site wide OU2 remedy as
described in the September 28, 1990, ROD.
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Statutory Determinations
Protection of Human Health and the Environment:
The amended remedy provides overall protection of human health and the environment by
eliminating the direct contact/ingestion pathway and containing the contamination that could
migrate to the groundwater. Any short term health risks associated with excavation will be
minimized by the use of standard construction practices and limitations on the amount of soils
handled at a given time. Air monitoring will be conducted to assess possible exposure during
remedial action. Area 1 soils will be physically separated from the Storage Area soils to eliminate
any possibility of VOC's in Area 1 soils from solubilizing PCB's in the Storage Area soils.
No environmental impacts have been identified for the Site, except to the groundwater and soil
where drum disposal and landfill activities took place.
Attainment of ARARs:
The amended remedy will be designed to meet all the applicable or relevant and appropriate
requirements (ARARs) of federal and more stringent state environmental laws. These consist
mainly of the following:
TSCA waiver provisions under 40 CFR 761.75(c)(4) will be exercised through section
2.2.4 of OSWER Directive No. 9355.4-01 Guidance on Remedial Action for Superfund
Sites with PCB Contamination.
Clean Air Act/Part 55 Natural Resource Environmental Protection Act PA 451
governing air emissions during excavation.
Cost Effectiveness:
The amended remedy provides overall cost effectiveness. The remedy effectively eliminates direct
contact and ingestion risk and reduces migration of contaminants to the shallow aquifer at a
fraction of the cost of the remedy selected in the 1986 ROD.
Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent Practicable:
The amended remedy utilizes permanent solutions and has evaluated alternative treatment
technologies to the maximum extent practical for this site. The proposed amended remedy
is protective and cost effective under the nine point criteria that the U.S. EPA uses to evaluate
alternatives. With the presence of a landfill at the site, the inclusion of the Drum Area 1 soils is a
logical outgrowth of the Site wide OU2 remedy which had not been conceived at the time of the
OU1 ROD's creation. As clean closure cannot reasonably be an objective at this site, due to the
presence of a landfill, the amended remedy provides equal protection for far less than the cost of
the original remedy.
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Preference for Treatment as a Principle Element:
Because treatment of the principle threat posed by the remaining soils was not found to be
necessary to be protective of human health and the environment, this remedy does not satisfy the
statutory preference for treatment as a principle element of the remedy. The size of the landfill
and the fact that the OU1 ROD first phase remedial action already addressed hot spots (Areas 1 &
4) through treatment (which represented the major sources of contamination), precludes selecting
an off-site disposal/treatment remedy.
Five Year Review
Because this amended remedy and the OU2 ROD remedy will result in hazardous substances
remaining on-site, the statutory five-year review will be conducted at the site. As a five-year
review has already occurred at the Site based on the first commencement of the OU1 ROD
Remedial Action, the next scheduled review is due before September 30, 1998.
'•16-
William E. Muno Date
Director, Superfund Division
10
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Li , -L ;\-.li
SOURCE= LAPEER COUNTY MAP,
PRODUCED BY "THE JOURNAL
METAMORA
^8455,
figure 1.1
SITE LOCATION
I METAMORA LANDFILL SITE
| Lapeer County, Michigan
3298 169WAN 12/94 (W) REV. O
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LEGEND
SITE SECURITY FENCING
SOURCE:
DARREU. HUGHES AND
ASSOCIATES
DECEMBER 22. 1992
CRA
figure 1.2
SITE PLAN
METAMORA LANDFILL SITE
Lapeer County, Michigan
3298 (69) JAN 18/9S(W) REVO (P2O)
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• BH26-94
15
i
94 \ \ J07
•BH17-V4 •
-
.B.J7-I94/ .BHI2-94
lJ I I 12046
41 j » \
X BH10-94,,.'- ..-•"--J'^- "••'Jl
s. •_- V _<^'>-'5r^5^__""X... ..-"?'--^^--.'j/ 1M'J
SOURCE
DARREL HUGHES AND
ASSOCIATES
JANUARY 11. 1994
CRA
LEGEND
MW-17S* MONITORING WELL
BH26-94 • BOREHOLE
0.094 TOTAL VOC CONCENTRATION (mg/kg)
10- ISOCONCENTRATION LINE (mg/kg)
TOPOGRAPHY IS OF THE CLEAN TILL CAP
AS MAPPED ON 21 SEP. 1994
figure 1.3
TOTAL VOCs IN DRUM AREA 1 BOREHOLES
20 TO 22 FOOT INTERVAL
METAMORA LANDFILL SITE
Lapeer County, Michigan
3298 (£9) JAN IB/95(W) REVO (P242)
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ATTACHMENT A
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METAMORA ROD AMENDMENT
RESPONSE TO COMMENTS
This Responsiveness Summary was developed to respond to comments received during the public
comment period regarding the ROD Amendment proposal for the Metamora Landfill Site located
in Metamora, Michigan. An initial public comment period ran from January 29 to February 29,
1996, and was extended to April 29, 1996. Two public meetings were held to receive oral and
written comments and to answer questions regarding the remedial options presented in the
proposed ROD Amendment. These public meetings were held on February 20, 1996, and April
23, 1996 at the Metamora Township Hall. Since similar comments were received from several
individuals, the comments are summarized in this Responsiveness Summary. A list of
commentors precedes each comment. In addition, responses are also provided for comments
submitted that are not specifically related to the proposed ROD Amendment, but are community
concerns. The ROD Amendment also presents additional information on many of these issues and
it should be consulted. Both the comments, and this Responsiveness Summary, will become part
of the Administrative Record for this Site. All references to Michigan Department of Natural
Resources (MDNR) have been replaced by Michigan Department of Environmental Quality
(MDEQ) to reflect the reorganization of the State agency.
1. Commentors
Comment #1:
Response #1:
Gloria Rossi
State Rep. Karen Willard
Not all concerned citizens were informed in a timely manner about the
public comment period. An extension of the public comment period,
and an additional public meeting, was requested.
Typically, a comment period extension lasts only an additional 30 days.
However at the request of Representative Willard, the public comment
period was extended for 60 additional days. The second public meeting
was held April 23, 1996, six days prior to the close of the extended
comment period.
2. Commentors
Citizens United
Elizabeth & David Weisler
U.S. Rep. Dale E. Kildee
Kevin Strasser
Ward Hodge
Robert Kahle
Elizabeth Friedberg
Gary Bireta
Paul Pellerito
Comment #2:
What has changed since 1986 that no longer makes these soils a
principle threat (source soil)? Why is the U.S. EPA deviating from
the 1986 ROD remedy? Why is the U.S. EPA placing our community
at unnecessary risk by proposing that these soils be contained on-site
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rather than being incinerated off-site as specified in the 1986 ROD?
Response #2: The 1986 ROD recognized that as additional remedial investigation (RI)
information was generated, a re-evaluation of the final remedial action for
the Site might be necessary. The 1986 ROD states "This Record of
Decision (ROD) recommends the selection of the excavation of areas one
and four with off-site thermal destruction. However, the possibility exists
that at the time of implementation of the selected alternative, the cost of
waste disposal will change the recommended (cost effective) alternative. If
such a situation arises, this ROD may be amended." Further evaluation of
Drum Area 1 soils and Soil Staging Area soils both met this condition,
leading to the proposed ROD Amendment:
The following information summarizes the history and current status of the
Drum Area 1 soils and the Soil Staging Area soils:
Drum Area 1 Soils-
The ROD was written with the expectation that the soils co-mingled with
the drums would require incineration. Because only limited data was
collected for soils prior to the 1986 ROD, the remedy selected for these
soils was a conservative one - it was assumed that these soils would be
highly saturated with hazardous chemicals. The 1986 ROD states "Some
material between the drums [interstitial soil] may be highly saturated with
hazardous chemicals from leaking drums. For the purpose of the Phased
Feasibility Study (PFS) this interstitial material was considered to be waste,
rather than soil. This waste material would be disposed of along with the
drummed material." In addition, it was assumed for purposes of the 1986
ROD that this "highly saturated" soil was a potential source of
groundwater contamination, thereby characterizing it as "source soil."
Incineration was an appropriate remedy for soils of this nature at that time.
In 1994, contaminated soil remaining in Drum Area 1 was tested to
determine if mobile non-aqueous phase liquids (MNAPL) were present,
one requirement of "source soil." No MNAPL were present. In addition,
further chemical testing of this interstitial soil showed that this soil did not
meet the general criteria for "source soil." Specifically the results, which
can be found in the Soil Characterization Report issued in 1995, indicated
that these soils did not contain PCB's above 500 ppm or have a
halogenated organic content (HOC) above 1000 ppm. These are
conditions which, if exceeded, frequently lead to an incineration remedy.
Furthermore, only a few chemicals were present in these soils above
concentrations MDEQ has established for soil clean-up goals for the
protection of groundwater. These results indicated that the soils needed to
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be remediated, but they were not contaminated to the extent that they must
be incinerated. A comparison of the alternate remedies studied, using the
nine point criteria, resulted in the proposed ROD Amendment.
Soil Staging Area soils-
The Soil Staging Area soils are a separate issue. These soils were
accumulated during the drum removal activities and stored on a bermed,
lined pad, with the expectation that these soils were more contaminated
than the bulk of Drum Area 1 soils. They did not contain MNAPL. These
soils were also subjected to the same chemical characterization as Drum
Area 1 soils. The analytical results, available for review in the Soil
Characterization Report of 1995, also indicated that these soils did not
need to be incinerated, but did contain PCB content above 50 ppm. As
the Soil Staging Area contains PCBs greater than 50 ppm, the TSCA
waiver provisions under 40 CFR 761.75(c)(4) will be exercised. OSWER
Directive No. 9355.4-01 Guidance on Remedial Action for Superfimd Sites
with PCB Contamination at 2.2.5, states "Where Superfund remedial
actions will leave PCB's in place or where PCB-contaminated material is
excavated, treated, and re-disposed at concentrations that still pose a
threat, capping consistent with chemical waste landfill requirements is
generally appropriate. (Long-term management controls for PCB-
contaminated material generally will also parallel RCRA closure.)
However some of the requirements specified under TSCA may not always
be appropriate for existing waste disposal sites like those addressed by
Superfund. When this is the case, it may be appropriate to waive certain
requirements, such as liners, under the TSCA waiver provisions,
761.75(c)(4). Requirements may be waived when it can be demonstrated
that operation of the landfill will not present an unreasonable risk of injury
to health or the environment. This demonstration may require column
studies verifying that PCB movement through the soil will not adversely
affect groundwater." Long term monitoring of the groundwater will meet
the substantative requirements of the column studies. Deed restrictions,
pursuant to the terms of the Consent Decree will be placed on the landfill,
and will eliminate possible incidental skin contact and ingestion. The
substantive requirements of the 1990 OU2 ROD SOW cap design will meet
RCRA cap closure requirements. Relocating and capping roughly 900
cubic yards of marginally contaminated PCB soils (less than 100 ppm
PCBs) from the Soil Storage Area is consistent with TSCA waiver
provisions.. Because the Soil Pile Soils contained PCBs above 50 ppm this
soil will be relocated to an area separate from the Drum Area 1 soils, in the
unlikely event that a PCB breakthrough to groundwater should occur.
Because of the relatively similar chemical make-up between the The Drum
Area 1 Soils and the Soil Staging Area soils (adjusting for the PCB content
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3. Commentors
Comment #3:
Response #3
discussed above) they were considered as one source for purposes of
remedy evaluation.
Remedies Evaluation-
As specified in the Statement of Work (SOW) attached to the 1991
Consent Decree between the U.S. EPA and the Settling Defendants,
remedial alternatives for the contaminated soil in Drum Area 1 and the Soil
Staging Area were evaluated in the Drum Area 1 Soil Remedial
Alternatives Report. This evaluation was conducted specifically to
examine remedial alternatives for contaminated soil and was based on
detailed chemical characterization data collected from samples of the soil
remaining in Drum Area 1 and the Soil Staging Area. The following
remedial alternatives were evaluated: 1) biotreatment; 2) capping; 3) soil
vapor extraction; 4) soil flushing; 5) solidification. Biotreatment, soil
flushing and solidification were determined to be inappropriate
technologies for the contaminated soil. Capping and soil vapor extraction
were evaluated in detail in the Drum Area 1 Soil Remedial Alternatives
Report. Capping was determined to be the preferred remedial alternative
based on the evaluation of the nine point criteria. (See the ROD
Amendment Fact Sheet for a summary of this evaluation, or the Drum Area
1 Soil Remedial Alternatives Report for a more thorough discussion).
Capping is protective of human health and the environment, is easily
integrated into the 1990 ROD remedy (which deals with groundwater
treatment and the landfill cap), and is cost effective. Copies of the Drum
Area 1 Soil Remedial Alternatives Report are available for review in the
information repositories located in the Metamora and Lapeer branches of
the County Library. In addition, copies of this report and the detailed
chemical characterization data were provided to the Technical Assistance
Grant (TAG) consultant, Dr. Stuart Batterman. Dr. Batterman also
provided comments that are supportive of the proposed remedy.
Norm Hughes
Richard Pullicin
Norm & Karen Camanagno
Elizabeth & David Weisler
Mr.& Mrs. Robert Kahle
U. S. Rep. Dale E. Kildee
Paul Pellerito
If soils (Drum Area 1 soils, and drums, and Soil Staging Area soils)
are to be relocated to the south face of the landfill as part of the
remedy, place a RCRA liner beneath the soils prior to capping.
All drums have been removed from Drum Areas 1 and 4.
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A RCRA liner is not proposed for a number of reasons. The soil in Drum
Area 1 and the Soil Staging Area exceed the proposed clean-up criteria,
therefore these soils require remediation. Relocating them to the south
face of the landfill and covering them with the landfill cap, is in agreement
with past remedial practice at CERCLA Municipal Landfill sites, and is the
proposed ROD Amendment.
In addition, the combined volume of these soils is small compared to the
volume in the landfill, and does not appreciably add to the risk of the
landfill proper. Building a landfill cell to contain this relatively small
volume of soil, complete with liner, leachate collection and independent
monitoring systems, offers only marginal additional protection, if any, over
the remedy as proposed, which includes a cap over the entire landfill and
relocated soils.
Furthermore the landfill cap will limit water infiltration into the fill, and
effectively eliminate the migration of chemicals to groundwater.
Also, United States District Judge Stuart A. Newblat wrote in his findings
of March 17, 1993, in United States of America v. BASF-Inmont et.al., in
upholding the decision to limit drum excavation to Drum Area 1 and Drum
Area 4, that "U.S. EPA made this decision, based on the recommendation
of the consulting firm that performed the Remedial Investigation/Feasibility
Study (RI/FS), that it would be more dangerous to perform excavation of
the other areas [2,3 and 5] than to cap the landfill, while leaving open the
possibility of additional clean-up activities if leakage to the environment
occurs." (emphasis added).
It should also be noted that the Resource Conservation and Recovery Act
(RCRA) regulations were put into effect after the landfill stopped accepting
waste, therefore RCRA is not an applicable requirement (ARAR) at the
Site. For the reasons stated above, the liner is not relative and appropriate
for this site. All regulatory requirements pertinent to the relocation of the
soils at the Metamora Site are being observed.
Additionally since waste is, and will be left on the Site, and in accordance
with Section 121 of CERCLA, a statutory Five-Year Review was
completed in August, 1993. Subsequent Five-Year Reviews will be
conducted as warranted pursuant to OSWER (Office of Solid Waste and
Emergency Response) Directive 9355.7-02 ("Structure and Components of
Five-Year Reviews") and/or other applicable requirements and guidance.
The next statutory Five-Year Review will be conducted prior to
September, 1998.
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4. Commentors
Comment #4:
Response # 4:
5. Commentors
Comment #5:
Finally, in addition to the Five-Year Review requirement, it should be
noted that the ground water at the Site and downgradient of the landfill will
be monitored at least annually for many years. (The details of the long
range monitoring program will be part of the groundwater remediation
plan).
Cynthia Bader
Norm Hughes
Robert Kahle
Norm & Karen Camamagno
The drinking water aquifer will become contaminated from the
chemicals in the soils if these soils are left on Site.
Limited contamination of the groundwater on the Site and north of the
landfill has been found, but is moving north toward the residential wells
more slowly than the groundwater modeling predicted. There is
preliminary evidence that biochemical natural attenuation is occurring in
the groundwater at the Site, evidence of nature healing itself. Other
chemical processes (hydrolysis) and physical chemical processes
(retardation) may also be occurring in the groundwater that could account
for the unexpected slow contaminant movement. No contamination above
background has been found in any residential drinking water wells north of
the Site. Additional groundwater studies north of the landfill are planned
this year, to establish the baseline for the long range Operation and
Maintance (O&M) plan. However if contamination is observed above
health-based standards during these studies, or at any time during the long
range O&M monitoring period (this typically consists of annual sampling
for thirty years), the groundwater contamination will be addressed.
The groundwater immediately down gradient of Drum Area 1 is
contaminated and will be remediated by a "pump-and-treat" system, as
specified in the 1990 ROD. This 1990 ROD1 addresses remediation of the
landfill and contaminated groundwater.
Stuart Batterman
There is support for the proposed ROD Amendment.
1 There are two operable units for this Site. The 1986 ROD and the proposed ROD
Amendment deal with a Operable Unit 1 (OU 1), the remediation of drums and soils from
Drum Areas 1 and 4. The 1990 ROD deals -with OU2, treatment of groundwater and
construction of a cap over all landfilled material.
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Response #5:
6. Commentors
Comment #6:
Response #6:
1. Commentors
Comment #7:
Response #1:
U.S. EPA appreciates this support.
Richard Espenshade Citizens United
Robert Kahle Norm Hughes
Gary Bireta
Take the soils off-site for disposal.
The cost to remove the contaminated soil to an off-site landfill is estimated
to be $5 million. This option did not pass the initial screening evaluation,
and does not meet the cost effectiveness criteria when compared to the
capping option. As discussed in the responses provided above, detailed
analytical data shows that the soil is not "source soil." Consolidation of
the contaminated soil under the landfill cap is consistent with U.S. EPA
guidance and past practice and meets the nine point criteria. Capping the
contaminated soil is protective of human health and the environment.
Norm & Karen Camamagno
Peter Stansen II
Cynthia Bader
Citizens United
The commentors are opposed to the concept of incorporating General
Motors Saginaw Metal Casting Operations (GM) foundry sand into
the landfill cap.
The Settling Defendants, with oversight by U.S. EPA and MDEQ, are
considering the use of foundry sand from the GM Saginaw operations in
the construction of the landfill cap. GM Saginaw facility uses sand molds
to cast engine blocks. The material used in the mold operation is a blend of
fine beach sand, finely ground coal and clay. No additional organic
chemicals are added. During the process of manufacturing the molds, part
of the sand blend becomes air-born. This sand is captured in a negative
pressure duct system, removed from the air stream while passing through a
hydro-clone scrubber, and the washed solids conveyed to a storage area.
This recovered material is identified as "Washed Classified Sand," and is
not suitable for recycling at the plant.
Reuse of foundry sand is regulated by the MDEQ under R299.4112, Rule
112(2)(b) and R299.4114, Rule 114(2)(g) of Michigan Act 451, Part 115.
This rule requires that the foundry sand meet "Type B" criteria before it
can be reused. Type B criteria were established by the MDEQ to be
protective for residential use. GM tests the foundry sand frequently. The
data base covers the time period 1983 through 1996. It meets the Type B
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8. Commentors
Comment #8:
Response #8:
criteria and MDEQ has approved the foundry sand for use at the Metamora
Landfill Site. In addition, shipments to the Metamora Landfill Site would
be sampled weekly to ensure Type B standards are continuously met.
The suggestion made at the April 23 public meeting that this foundry sand
contains PCS material is without foundation. The "Zilwaukee incident,"
mentioned during the April public meeting, referred to the use of foundry
sand that had become contaminated with PCBs while being temporarily
stored at a PCB contaminated location, off the GM Saginaw property.
Dr. Stuart Batterman, the community Technical Assistance Grant (TAG)
technical consultant, is aware of the possibility of using this material in the
cap construction. He has not expressed a technical concern about its use.
This "Washed Classified Sand" material is available for inspection at the
Saginaw facility.
Recovered foundry sand from the Saginaw facility is currently being used
at six landfill sites in Michigan and is being considered for use at additional
sites. The decision as to whether "Washed Classified Sand" will be used at
Metamora will be made in the near future and will be incorporated into the
Remedial Design/Remedial Action documents for the Site as the
documents are developed.
Citizens United
U.S. Rep. Dale E. Kildee
Norm Hughes
Additional studies need to be conducted to realistically characterize
the Site.
The Metamora Landfill Site has been investigated since the mid 1980s. A
significant amount of data regarding groundwater quality, soil quality and
content of the drummed waste has been collected. For example, 50
monitoring wells have been installed and 9 rounds of groundwater sampling
have been conducted (approximately 230 samples). The soil has been
characterized through drilling of soil borings, digging test trenches
(approximately 65 total) and collection of approximately 250 soil samples.
The results of these site characterization efforts are documented in the
following reports (available in the information repositories):
• Site Investigation Final Report, E.C. Jordan, February 1986
• Remedial Investigation Report, E.C. Jordan, March 1989
• Baseline Groundwater Monitoring Report, CRA, February 1994
• Soil Characterization Report, CRA, April 1995
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• Pre-Design Hydrogeologic Investigation Report, CRA, August
1995
• Bi-Annual Groundwater Monitoring Report, CRA, December 1995
While the Remedial Investigation Report identified data gaps concerning
groundwater contamination, those data gaps have been filled by
subsequent investigations. Additionally, more groundwater quality
information will be obtained during the O&M baseline groundwater studies
to be conducted later this year. The amount of information available
concerning the Metamora Landfill Site is consistent with that available for
other Superfund sites and is sufficient for remedy selection and design
purposes.
It has been stated during the public meetings that "hundreds of thousands"
of drums still remain in the landfill. In consideration of this concern, the RI
was reviewed for the expressed purpose of establishing if this concern had
been overlooked. The following comments summarize this review.
In 1982 the MDEQ conducted a magnetometer survey in five locations at
the Site where drums were alleged to have been disposed. The presence of
drums was confirmed by visual evidence in Drum Areas 1 and 4. The
magnetometer results showed that Drum Areas 1 and 4 likely contained the
highest number of drums and that the drums were present at shallow
depths. Drums were not confirmed by visual evidence in the other areas.
The magnetometer results indicated that drums may be present in these
areas, but that the drums were present at depths of greater than 30 feet and
were covered by tires and refuse. In addition, areas 2, 3 and 5 had
magnetic interference which may have been in part caused by white goods,
steel belted tires and refuse, making positive identification of drums
impossible.
The magnometer data presented by E.G. Jordan in the Phased Feasibility
Study was reviewed by the Region 5 Technical Assistance Group. They
did not find fault with the results presented in the report. They further
indicated that there have been no major advancements in equipment or
techniques since 1986, and an effective method to "see" into a highly
chaotic landfill environment is not available.
The 1986 ROD did not consider that the evidence of the presence of drums
in areas 2, 3 and 5 (no visual confirmation), combined with the significant
depth of the potential drums, warranted excavation of these areas. United
States District Judge Stuart A. Newblat wrote in his findings of March 17,
1993, in United States of America v. BASF-Inmont et.al., that "U.S. EPA
made this decision, based on the recommendation of the consulting firm
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9. Commentors
Comment #9:
Response #9:
that performed the RI/FS, that it would be more dangerous to perform
excavation of the other areas [2, 3 and 5] than to cap the landfill, while
leaving open the possibility of additional clean-up activities if leakage to the
environment occurs." The groundwater quality data supports this
conclusion. Significant contamination to groundwater quality has not
occurred at this Site.
Finally, the photographic evidence available for the Site, obtained from the
Aerial Photographic Analysis of Eight Priority CERCLA Hazardous Waste
Sites in Southeast Michigan, does not indicate any evidence of massive
drum disposal in any of the areas of concern. The pictures were taken
during flyovers of the Site on July 26, 1964; June 17, 1972; August 17,
1978; August 18, 1982; June 12, 1984 (two views). The 1978 photograph
indicates a fairly large area in the northeast corner of the landfill, identified
as a "sludge pit" which may in actuality be the "tire pit," and may have
been the fuel source for one of the large fires experienced at the Site. The
pit was not evident in the 1982 photograph.
Richard Pullicin
Elizabeth Friedberg
Stuart Batterman
Peter Stazen II
Robert Kahle
Use local sources for fill materials, in place of G.M. foundry sand.
The increased truck traffic caused by importing G.M. foundry sand
will impede the construction of the local sewer system and interfere
with the resurfacing of M24. It will also compromise the safety of our
children.
All material used in the construction of the landfill cap will pass through
the Village of Metamora. The only exception would be if John R Sand &
Gravel material were used, which would eliminate some of the truck traffic
through the village. The Defendants have expended considerable effort
attempting to negotiate purchase of the fill material from John R Sand &
Gravel. These negotiations have failed. As such, the fill material must be
obtained from an off-site source; truck traffic on local roads is
unavoidable. This is the situation whether the fill comes from local sources
or from Saginaw. The Defendants have met with the township trustees and
the county road commissioner to discuss the issue of truck traffic with the
hope of establishing alternate routes in and out of the landfill. It does not
appear that an alternate to Dryden Road, through the Village of Metamora,
is available at this time.
The proposed schedule for shipment of foundry sand to the Metamora
10
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10. Commentors
Comment #10:
Response #10:
11. Commentors
Landfill Site is based on approximately 1500 cubic yards per day.
Assuming a five-day work week, approximately six months would be
required to complete delivery of the sand to the Site. Local roads would
have approximately five additional trucks per hour as a result of delivery of
the material. Material shipped from a local source may result in more
frequent truck traffic for a shorter period of time.
In an effort to minimize disruption to other local activities, including
resurfacing of M24, local traffic, and construction of the local sewer
system, the Defendants will be flexible concerning the shipping schedule,
and will coordinate transportation issues with local officials.
On a positive note, one approved cap design modification will result in
more than 2000 fewer truck trips through the Village. The landfill cap will
use a geosynthetic clay layer (GCL) as an alternate to part of the clay layer
identified in the initial remedial design.
Gary Bireta
Citizens United
There is no community acceptance for this proposed ROD
Amendment.
The National Contingency Plan (NCP) at 300.430(f)(l)(i)(A) requires that
all remedies meet the threshold criteria of protection of human health and
the environment and compliance with ARARs. The NCP uses the criteria
of overall protection, short term effectiveness, long term effectiveness,
reduction of toxicity, mobility or volume, implementability, and cost as
balancing criteria. The balancing criteria are given equal weight in the
evaluation. The proposed remedy offers the best balance of these criteria.
The NCP uses the criteria of State acceptance and community acceptance
as modifying criteria. The State of Michigan has accepted the proposed
remedy. The community has offered comments on the remedy that are
both pro and con. The TAG technical consultant supports the proposed
remedy. Others have provided comments that are not supportive of the
remedy and these comments are addressed and evaluated in this
Responsiveness Summary. U.S. EPA has considered all public comments
submitted, but has not been made aware of any compelling technical
considerations that would warrant a change to the proposed ROD
Amendment.
Gloria Ross
Gary Bireta
11
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Comment #11: The contents of the landfill should be removed, and replaced with
clean material.
Response #11: As noted in responses #2 and #6, various alternatives were evaluated
against the nine criteria. In addressing the Drum Area 1 soils and Soil
Staging Area soils, relocation and capping were determined to best fit the
nine criteria, and are protective of human health and the environment. In
addition, there were no comments supporting removal of the landfill
contents during the public comment period for the 1990 ROD, the
appropriate time to have documented this concern. Eighteen commentors
presented this position during the public comment period for the 1991
Consent Decree. The full response to the public comments for the 1991
Consent Decree can be found in the Metamora Consent Decree Reply to
Comments, dated March 13, 1992. A few of the response highlights are
reproduced here:
"The landfill remedy selected for the Site is consistent with remedies at
similar sites across the state and throughout the country."
"Metamora is not unique in its landfill volume and contents. Old landfills
that operated before the institution of more rigorous or comprehensive
environmental regulations not only accumulated hazardous material but
also an extremely large amount of municipal waste."
"It is not practical or prudent to excavate a landfill the size of Metamora.
Not only does the volume of waste cause difficulties in excavation, but the
build-up of menthane gas within a landfill of this age and size would pose
an unacceptable risk if the landfill were to be excavated. Methane is highly
ignitible, and in large quantities could cause an explosion releasing
hazardous substances into the air."
"However, due to the large amount of landfill wastes and the high cost
(approximately $200 million) of excavation of the landfill, U.S. EPA
guidance ("Conducting Remedial Investigation/Feasibility studies for
CERCLA Municipal Landfill Sites," February 1991, EPA /540/P-91,
Section 4.2.3-4.2.3.1) states that removal of contaminated soils at
municipal landfill sites is generally limited to hot spots (such as drum
disposal areas 1 and 4 at Metamora) or, where practicable, to landfills with
low to moderate volume of waste (e.g., less than 100,000 cubic yards).
There is an estimated 700,000 cubic yards to 1.5 million cubic yards of
waste at Metamora. U.S. EPA, in selecting the remedy for this Site, did
address the hot spots at the Site by excavating and incinerating Drum areas
1 and 4, estimated to contain 74% of all drummed material."
12
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Commentors
Comment #12:
Response #12:
Commentors
Comment #13:
Response #13:
"It should also be remembered that capping of the landfill was selected by
the U.S. EPA as the appropriate remedial action by the 1990 ROD. Prior
to the selection of this remedial option, U.S. EPA provided the statutorily
mandated public comment period on the proposed remedy. U.S. EPA
received very few citizen comments on this remedy, and none suggested
that the landfill should be completely excavated."
Stuart Batterman
U.S. EPA should provide more regular communication to the
community regarding Site progress and scheduling. The Site
information repositories, particular the one at Metamora Library,
need attention.
U.S. EPA has plans to provide more regular communication with the
community including providing update letters and fact sheets on
construction progress. U.S. EPA personnel have visited the Site
information repositories and provided updates. The effort to improve the
organization of materials at the information repository at the Metamora
library is limited by shelf space. Room to peruse repository material will
continue to be extremely limited until the new library is built in Metamora.
Repository users are asked to contact the U.S. EPA Community
Involvement Coordinator, Bri Bill, when materials are found to be in
disarray or missing. The toll-free number is 1 -800-621 -8431.
Gary Bireta
Norm Hughes
U.S. Rep. Dale E. Kildee
Citizens United
Cynthia Bader
Several commentors noted leachate seeps are present at the Site.
Leachate seeps are present at the Site; however, these seeps tend to be
ephemeral, lasting only a short time. Seeps are caused by infiltration of
water into the landfill. Reducing or eliminating the infiltration of water into
the landfill will eliminate the seeps. Because capping will greatly limit the
amount of water infiltrating into the landfill, capping the landfill is the
appropriate remedy for the seeps. The following table shows the
infiltration of water through the various capping options:
Landfill "as-is"
SOW Cap
GCL/Clay composite cap
8 inches per year
1.63 inches per year
1.37 inches per year (selected design)
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14. Commentors
Comment #14:
Response #14:
15. Commentors
Comment #15:
Response #15:
16. Commentors
These numbers translate to 4,900,000 gallons per year infiltration for the
"as-is" case; 993,000 gallons per year for the cap specified in the SOW;
and 835,300 gallons per year for the geosynthetic clay layer (GCL/Clay)
composite cap. (All based on a 25 acre landfill).
The presence of the seeps supports the position that the remedy should be
implemented as soon as possible.
Citizens United
Ann Deuteron
Include the residents in the decision making process.
The residents and other members of the public have had the opportunity to
participate in the decision making activities at the Metamora Site through
two avenues. Serving as a member of the TAG committee is one avenue.
The second avenue is through attendance at public meetings, and
submission of comments. All comments are considered, compared to the
tenets of the Superfund program, and are responded to in the
Responsiveness Summary.
James Phillips
Norm Hughes
The cap will infringe on the abbutors property.
Negotiations are underway with the affected property owners for purchase
of the land required for the cap construction. A suggestion to relocate
some of the landfill to avoid intrusion upon private property was
investigated. The preliminary study indicated that 250,000 cubic yards to
370,000 cubic yards would have to be moved to accomplish this.
Relocating this amount of material would create a serious health problem
during the six to eight month period required for this effort. Furthermore,
movement of this quantity of the landfill is contrary to U.S. EPA policy for
CERCLA Landfill Sites (U.S. EPA guidance "Conducting Remedial
Investigation/Feasibility studies for CERCLA Municipal Landfill Sites,"
February 1991, EPA /540/P-91, Section 4.2.3-4.2.3.1). The guidance calls
for removal of drums and/or heavily contaminated soils, that serve as
"source" material for contaminating groundwater, and the construction of a
site specific landfill cap. This is the remedial action being pursued at the
Metamora Site.
Norm Hughes
Citizens United
14
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Comment #16:
Response #16:
17. Commentors
Comment #17:
Response #17:
18. Commentors
Comment #18:
Response #18:
Faulty cost estimates were used in the decision making process.
The cost estimates need only to be within a +50%, -30% range of the
"true" cost, to be suitable for ranking the remedial alternates. U.S. EPA is
confident that the estimates used to rank the alternates for this proposed
ROD Amendment are within this range. The proposed remedy was
subjected to detailed analysis and comparison against all of the NCP
evaluation criteria. The proposed remedy is protective of human health
and the environment and is cost effective. The proposed ROD Amendment
is commensurate with the low levels of contaminants found in Drum Area 1
and the Soil Staging Area.
Robert Kahle
Cap only the soils. Leave the landfill uncapped for possible future
removal of contaminants.
The proposed ROD Amendment deals only with the Drum Area 1 soils and
the soils located in the Soil Staging Area (as part of Operable Unit 1).
Capping of the landfill (as part of Operable Unit 2) is not addressed in this
proposed ROD Amendment, but addressed instead in the 1990 ROD.
Capping of the landfill was selected by the U.S. EPA as the appropriate
remedial action as published in the 1990 ROD. Prior to the selection of
this remedial option, U.S. EPA provided the statutorily mandated public
comment period on the proposed remedy. U.S. EPA received very few
citizen comments during the 1990 ROD public comment period, and none
suggested that the landfill should not be capped.
James Phillips
More cap details should be supplied, especially the vent pipes.
To the extent possible the cap design was presented during the April 23,
1996, public meeting. The actual design details will be part of the 95%
design document. To date only the 30% design is available, and although it
addresses the cap vents, the details are not yet available. All design
concepts and calculations will be reviewed, stamped, and signed by a
Registered Professional Engineer in the State of Michigan. A copy of the
95% Design Report will be placed in the site information repositories for
review. The TAG technical representative will review these documents
and comments, if any, will be evaluated. Appropriate changes will be made
15
-------
19. Commentors
Comment #19:
Response #19:
as required.
Elizabeth Friedberg
James Phillips
The TAG committee should design the cap.
The TAG program was established in 1986 to assist affected communities
to understand and comment on site-related information. The technical
advisor hired by the TAG committee may review site-related documents,
meet with the community to explain technical information, provide
assistance in communicating the community's concerns, interpret technical
information, and participate in site visits, when possible, to better
understand clean-up activities. It is not within the scope of the TAG
committee's responsibility or authority to design the cap. In the case at
Metamora, it is the responsibility of the Defendants to design a cap that
meets the regulatory requirements. These regulatory requirements are
included in the Consent Decree between the U.S. EPA and the Settling
Defendants, as the Statement of Work (SOW). The design format being
followed at the Metamora Site is consistent with the Superfund program.
16
-------
TABLE 1
-------
PART 201 OF THE NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION ACT, 1994
PA 451
GENERIC RESIDENTIAL CLEANUP CRITERIA FOR GROUND WATER AND SOIL
(Revision 4)
sidentiai crrtena were calculated using currently available lexicological data. These criteria may change as new tenacity data Become
•liable. They are not necessaniy final cleanup standards. Please read the attached introduction tor details. Carcinogenic enemicate
»snown in oold italics. All values are exDressea in units of parts per pillion
0.05 NA 0.0014
ID 50(A,n (BJ
0(P) NA 20 NA 50 (A)
SO(A.C) NA 11 (A)
3{C] NA 75
7.7 NA (B)
ZOOO{A,C) NA 630 (A.O)
5(C) NA S3
04037 NA 0.0054
12 NA 031
12 NA OJ1
12 NA OJ1
_» NA {8}
MMhou
LMtei
Water
5
5
500
18.000
100
SO
S
05
NA
1
1
2
2
2
0.01
100
50
20
5
S
5
1
NA
200
5
50
5
S
5
S
SOIL (ppb:uo/kg)
20X
Orinkng 0*"*
Water 20X6SI Contact
Tun VMue Vata
2BOOO 76 7.66*7
520 {B} 1.56*6
19.000 (8) 1.46*7
54,000 (B) 636*7
15.000 546*5 1.16*7
2500 16.000 2.16*6
2,400 SO 156*8
35 180 2200
78400 (8) 556*7
32 44 4.700
40 980 126*5
00 (B) 426*5
80 (B) 556*5
40 {B} 4.66*5
(E» {B . 580
1.000 {B} ID
D(P} 400 ID(P)
3£00 80 1.76*6
156*5 226*6 426*8
120 W 1.000 156*5
1400 14400
(E) (E> t-4E*S
(E) {P 1-SE*
Tafoet
MeHea
Lkatki
Sol
330
330
2500
946*5
100
100
10
5
NA
10
20
SO
so
so
20
700
1400
1.700
330
500
100
so
NA
1400
10
1400
330
330
»
'330
6/5/95
-------
ENERIC RESIDENTIAL CLEANUP CRITERIA
REVISION
temical
me(P}
rte(P)
ttroonenoi
MttnasadJpAanytamfcM
^•VHUt
awnyi
ofrfcecytacrtatt
•nUOUOTOMnzene
D^fl**MMtA
fW*WiV
*ra
4>fcM«MM
own
••^MMMMtM
fWiuvw
•tfyferomfrufod ttofetnyts fJ)
fOffMun
PDfMCfiior
VQpyt •ksotiol
loeyim glycoi
yv»
yttftn.
iftmr
ikMEbna
ioawm
•^WfW
***•
rabutnuron
U7,*.rao?fcromodJtaRZo^>4fcu*T (OJ
* * * 1-Ymtomi ItLnttmrtuutm
GROUNOWATER (ppo:uq/t)
Haatth-
Batin Aesthete
Drinking Drinking
Waur Watar GSI
VakM Vakie Vak»
10,000 {C,P} NA (8)
1*00(C,P} NA {8}
3.4 NA 1*00
20 NA {8}
0.12 NA {8}
170 NA 160
200(0} NA {B}
73 NA {B}
880 NA 0.62
6.1 NA {B}
55 NA {8}
1(0} NA 0.8(0}
ID NA (B)
ID NA {B}
28 NA (B)
4,400 NA 1.100
500(0} NA {B}
32 NA {B}
0*96 NA (B>
0.5{C) NA 2*6-5
160 NA (8)
95 NA (8)
200 NA (8)
1ZOOO NA (B)
1.400 NA 15*00
126*5 NA 1*6*5
550 NA 11.000
7.3 NA 20
50(A.C} NA 5(A}
34 (A) 100 0.1 (A}
4(0} NA 3.4
1*E*5 NA (B)
100(0} NA 19
K) 2.5E*5 (B)
510 NA (B)
{0} NA (0>
ZSOO NA 0.4
3E-5(C} NA 1.4E-8
33 NA (B)
Target
Method
Dctecoon
LMtin
Water
100
100
5
5
5
5
NA
NA
0.1
2
2
20
100
NA
5
5
10
NA
NA
02
0*
1
0.5
100
NA
5,000
5
20
5
OS
10
NA
1
NA
NA
0*001
0.1
1.0E-5
1
SOIL (ppb:ug/kg) '
20X
Drinking Diraet
Watar 20X GSI Contact
value Value Valua
2.0E*5 {P} {8} ID
20.000 (P) {B} ID
68 38*00 51.000
400 (B) 126*6
2.4 (B) 370
3.400 3200 526*5
4.000 (B) 1.6E*7
1^00 (BJ 1.16*8
18.000 12 5.1 E*7
120 {8} 356*5
1.100 {8} 326*6
20 16 82*00
ID {B} ID
ID (8) ID
520 (B) 1*6*6
88,000 22*00 6.66*7
10.000 (B) 3.06*7
64 (B) 48*00
(E> (E> 1.100
{E} (E) 2JOO
3200 (8) 9JE*6
1*00 {8} 5.55*6
4.000 (8) 1-16*7
Z4E*5 (8} 1.96*8
28*00 3*6*5 2.16*7
10E*6 3*6*6 1.0E*9(G}
11.000 226*5 326*7
150 400 1.16*5
1,000 (A) 100 (A} Z16*6
680 (A} 2(A> 2JE*6
80 68 226*8
32E*6 {B} 1.06*9(6}
2*00 380 85*00
5*i*6 (81 IP
10*00 {B) 3.06*7
{E) {E} {0}
50,000 8 1-46*8
{E} {EJ 0.09
660 {8} 99-0°°
Taraet
Matnod
Daairtinn
LJnitm
Sol
NA
NA
330
330
330
330
NA
NA
20
SO
SO
3.400
1*00 I
NA m
330 "T
330
100 1
NA
NA
330
20
20
20
6,700
NA
5.000
330
330
500
500
40
NA
In*
n
0*1 I
20
0.001
10
-------
ENERJC RESIDENTIAL CLEANUP CRITERIA
REVISION 4
temicat
ry*tn»(Q)
at
«oe(R)
dha)
r-ooo
t'-ooe
i'-OOT
jattm alcohol
2-Dchtoratenzene
.3-DfcMaretarKene
fe.1 7 nirhiniruamjMm
W»>1 .Michta imhr*™
•WMtftLiuj ^-*uul
' l-Pte/ifafvwvp«~
fc~_
MMUrai
GROUNDWATER (ppD:uq/l)
HMttv
Drtntano OfMana
Water Water SSI
Value VakM Vak»
120 NA 051
37 NA (BJ
1,400 {A} 1,000 18{A,D}
15 NA 4.7
200 (C) NA S3
33.000 NA (BJ
73 NA {BJ
200 (C) NA {BJ
35 NA 0.0084
25 NA 0.0059
25 NA 0.00023
73 NA {8}
880 NA 12400
400 NA {BJ
0453 NA 3J2E-5
Mated
DaUcuui
Ufrttin
Water
5
10
25
10
20
50
1
10
0.02
0.02
0.02
10
5
5
5
NA
05
5
5
1
5
1
1
1
20
1
1
1
1
1
1
041
5"
10
1
1
0.1
5
0.02
SOIL (ppd:ug/kg)
2QX
Drifting Oiiact
Water 20X GS1 Cort*a
Value Vifen Vate
{EJ {EJ 1.46+6
740 {BJ 2.16*6
20,000 360 {A} 1.66+7
30 94 17.000
4.000 100 9.36*6
&6E+5 {BJ 546*6
1500 {BJ 4.26*6
4.000 {BJ 95E+6
{EJ {EJ 41.000
{EJ {EJ 29400
(EJ {EJ 29400
1,500 {BJ 4.26+6
18400 2.46+5 5.1E+7
8,000 {BJ Z1E+6
2400 {BJ 7.66+6
ID {BJ ID
28 0.04 78400
{EJ {EJ 1.400
ID {BJ ID
ZOOO 580 31400
1.600 {BJ 4.66+6
12400 140 9.46+6
12,000 3.600 9.46+6
1.500 300 1.16+5
38 0 5.700
34.000 {BJ 25E+7
18400 {BJ 156+7
100 11.000 28400
140 640 1.16+6
1.400 {BJ 1JE*«
2400 6400 1-96*6
44.000 {BJ 15E+8
1400 680 4.2E+6
1.400 940 4.26+6
100 1500 38400
96 60 14,000
S| {BJ 34400
ID {BJ ID
{EJ {EJ 820
Mafiod
Lin* in
Sol
330
500 -
1400
500
500
100
20
100
20
20
20
100
330
330
330
MA
10
330
330
10
10
10
10
10
2400
10
10
10
10
10
10
0,1
330
200
10
10
SO
330
20
6/5/95
-------
iENERIC RESIDENTIAL CLEANUP CRITERIA
REVlSIOf
ihemicai
*byl ether
Mhylphtnaiate
iethvtane glyeoi monobuM ether
fiaopropyHnune
kfaM^A^^ .^^4««tw*A
vnmyi pnuwflw
IJMftnethytacearrade
)M&TVi2-ineihvlbenzene
Ettiylenegfyc*
EBiytane giyeol monobutvl ether
Fkiorene
Ftuome
roniau Kid
attaMaM^MB) M*M4^^
^WMfiVT VMWK
Gtyptante
A^^M^MA^lKA
rfeoiacnior
HaotocMor aaaund*
GROUNDWATER (ppb:ua/l)
Heettn- i
Baaea fieethrfr: |
Orintanq Drinking |
Water Water GS1 l
VlkM Value value \
ID NA {8}
3,700 r4A (B)
5^00 NA 1.2E+5
88 NA {B>
&6 KA {B}
73.000 NA Z9E+6
180 NA {B}
16 NA {B}
700 NA 3.800
370 NA 31
4.4 NA - {B}
10 NA {B}
22E+5 NA {B}
1.3 NA 91
7{C} NA Oi{D)
77 NA ZOOO
2D(C) NA {8}
1.7 NA {8}
100(0} NA (B>
2(0} NA 0.0023
86 NA {B}
2DE*€ NA 41.000
6.600 NA 1,000
ID NA {B}
700(0) 74 31
005(0) NA 1.1
1S£00 NA 684)00
U) NA {B}
96 NA {B}
880 NA 370
880 NA 14.000
400(0) ZOOO 1,900
1.300 NA 170
10.000 NA (B)
80 NA {B}
8£ NA {B)
700 (C) NA {B)
0.4(0} NA 0.0016
02(0} NA 0.0011
rarget
Method
Maeoon
jnvt in
Water
10
SO
5
NA
NA
S
NA
NA
NA
5
5
S
NA
5
1
1
1
0.01
20
0.02
5
1.000
NA
NA
1
1
5.000
NA
NA
S
5
NA
100
18.000
NA
NA
100
0.01
'o.oi
SOIL (ppb:ug/kg) i
20X
Drfntana Direct
Water 20XGSI Contact I
Value Value Value j
10 {B} ID
74,000 (B) 5.SE+7
1.1E-^5 2.4E*€ 3^E*6
1.600 {B} 5.1 E*6
110 (B) 85^)00
15E*€ 5.8Ef7 1E-»«{G}
3,600 (B) 2.7E*6
320 {B} 2.4&»5
14.000 76.000 1.1 E*7
7.400 620 2.1 E*7
88 {B} XSE+5
200 {B} 5.9E+5
4.46*6 {B} 1.0E*9{G)
26 1.800 15.000
140 10 4.2E+5
1.500 404)00 Z3E*5
400 {B} 9-3E+5
(E) (E) 974)00
ZOOO {8} 7iE*6
(E) (EJ 7ZOOO
1.700 {B) 2.6E*5
4.0E*7 8.2E+5 1.0E*»(G)
1JEi« 20.000 9^E*7
ID (B) ID
1^00 620 1.1 E*7
1 22 30
34E+5 1.4&*6 8.4E*6
ID (B) ID
1*» (B) 1-4E«6
18.000 7.400 5.1E*7
184)00 2J&»5 5.1E*7
84OO 384)00 Z5E*7
26,000 3.400 24E+7
24)E*5 (8) 15E*8
1,600 (8) 1.2E+6
170 (B> 994)00
14,000 {BJ 4.2E+7
(E) (E) 2JOO
{E> (EJ L1«
Method
Detechun
Lint in
Sol
100
100
330
NA
NA
330
NA
NA
NA
330
330
330
NA
H
10
NA
U
NA
20
10
4.400
NA
NA
10
10
54)00
NA
NA
330
330
NA
»
9-OE-4M
-*m
NA I
NA
20 I
-3 — !
-------
3E&JER1C RESIDENTIAL CLEANUP CRITERIA
REVISION 4
:hemical
h-HoptW
^fta^ancMoracyctaftaicaM
vHaxane
2-Hexanone
In*tno<1.l3-c fc j^a»^«^^» «^a»«^» ••
atHMwlyVfta^nniMnB
2 Matttylphanol
^_U^*akJB*^*«MMU
44btattiylpfmi
ttLbdaran
aaaaaK--*— «j^_ .
nvpranaMna
JNtakal
GROUNDWATER (ppb:ug/U
i
Haattw
Baaad AaMwac |
OlMbng Oiinlanq
Water Watar QSI
Valua Valua Valut i\
32.000 NA 4
20 NA (B)
1 {Q NA 0.0019
11 NA 500
0.14 NA 0.13
0.47 NA 0.46
50 (C) NA OS4
61 NA 13
3,000 NA (6}
1.000 NA (B)
12 • NA 0.31
ID 300 {A} (B)
2JOO NA {B}
900 NA 860
470 NA 21.000
4{A,L) NA 6.6 (A.O)
02 (C) NA OJ8
426*5 NA (B)
160 {A} SQ|A) (B)
2{A.C) NA 0.0013 (A)
3,700 NA 41.000
40{C) NA (B)
29 NA (B)
73 NA {B}
2J NA 0.59
370 NA (B)
240 NA 380
20 NA (B)
ID NA {8}
088 NA (8)
5{C) NA 59
10 NA (B)
370 NA 38
370 NA {B}
37 NA 62
160 NA 150
37 (A) NA 800 (A)
260 NA 29
100 (A.C) NA 57{A.O)
raraet
wMhod
Maebon
Jmitin
/Vater
NA
(K)
(KJ
(K>
0.01
0.01
P 14,000
6.000 (A) {8} ID
48.000 (B) 356*7
18.000 17.000 2.76*6
9.400 426*5 7.06*6
80 (A) 130 (A) 4.06*5
4 1.6 7.600
6.46*6 1.06*9 1.06*9{G)
1,000 (A) (B> 2X6*6
40(A) 0026 {A} 1.36*5
74,000 826*5 556*7
80 {B} 2.16*6
580 {B} 4.46*5
150 {8} 426*5
52 12 1.56*5
7,400 (B) 556*6
4500 7.600 3.66*6
400 {B} 3.06*5
ID (B> ID
(EJ {EJ 104)00
100 1200 3.46*5
ID {B} ID
7,400 760 556*6
7.400 {B} 2.16*7
740 120 2.16*6
3200 3.000 156*6
740 16.000 {A} 2.16*6
5200 580 15E*7
2.000 (A) 1.100 (A) 326*7
Malhoa
Larttti
Sol
NA
(K)
OQ
(KJ
20
20
{KJ
50
NA
100
330
ZOOO
4,400
330
4.400
1,000
20
3,000
zooo
100
4,400
50
NA
100
1,700
100
100
NA
500
50
10
330
330
330
330
50
100
330
1.000
6/5/95
-------
IERIC RESIDENTIAL CLEANUP CRITERIA
REVISION 4
mical
nfajpyran* {Q)
ncaod
yi alcohol
lyfcntarMe
mam
n
nooamne
MMNcMoramMtaM
utanoi
utanone NA (B)
ID NA {8}
100 {C.S} NA 24
100 {C.S} NA 65
10 NA 11
950 NA {B}
13X00 NA 7200
550 NA 40
3JOO NA 8.300
1200 NA {B}
S{A.Q NA 0.64 15.000
80 {8} Z300
ID {B) ID
15 84 2JOO
(E) (E) 7.0E*5
8 JOO (A) (B) 2.56*7
ID {8} ID
2X00 {S} 480 41.000
2X00(5} 1JOO 326*5
200 220 156*5
19.000 {B} 1.46*7
2JE*5 1.46*5 2XE*6
11.000 800 8.36*6
78X00 1.75*5 SJ6*7
24.000 {8} 6JE*7
100 (A} 13 (A) Z1E*5
ID (8) ID
12E*5 (B) 3.46*6
14,000 (B) 4.16*7
800 32 5.56*5
16X00 (8) 126*7
100 420 20X00
(E) (E> 7.800
5X6*5 {8} ID
2X00 1.400 2.16*6
4.400 {8} 6.76*5
D (8) ID
2X00(5} .600 426*5
1^00 (8) 2X6*5
3X00 88 226*6
38X00 {B) 2.7E*7
900 200 6JE*5
3^00 {B} 22E*6
440 0.04 1.36*6
2X00 {A} 1.500 (A) 6.36*8
Method
Umftin
Sol
330
3.300
1JOO
200
200
330
330
330
8.000
10
10
10 I
10 J
4.400 T
100 I
20
4.400
330
50
NA
NA
1.000
200
100
10
10
2X6*5
10
10
100
10
10
" 4
^^Q ^B^B|
" 1
10 1
10
2JBOO
-------
3ENERIC RESIDENTIAL CLEANUP CRITERIA
REVISION 4
Chemical
rtottflVCnpoyoctfiyMffM
rttrahyofofunn
Datum
return
p-rofafcHM
TiWate
Trtbutytanww
f,W-7ftehtoro*«rtan» — •
Tifc~fifcat¥aa^tiMa^«M
* AT •F-"-*-* — •» j
TMtonan
Z^,4-Tnmatny) peraane
2j2.4-Tf»ne«nv(-2-o«ntene
i t*»f*v i iiimiyuwwiQ
M^ZMMbraiiwpnipyOptaxataai
Una
Vanadium
U^BM^ ^ ^^a,
Wiyf CfMOffM
Xyfanes
Zinc
GROUNOWATER (ppb:ua/l)
Haelttv
Baaeo Aeathebc
Drtnlong Drinking
Water water GSI
Value Value Value
4.3 NA 32
5(0} NA 22
240 NA 3,300
2{A.C} NA 5.4 (A)
1.000 NA 8 (A}
840 NA {B}
2{C) NA 3.1
0.11 NA (B)
10,000(0} 280 59
i400{A) 5.000 (A) 81(A,D)
Taraa
Moowd
Datacaon
Unit in
Water
1
1
1,000
2
1
NA
1
1
NA
5
1
1
1
1
50
5
1
1
NA
NA
NA
1
50
NA
1
1
NA
400
20
50
1
NA
3
20
SOIL (ppb:ug/kg)
20X
Drinking Diract
Water 20X GSI Contact
Vah» VafeM Value
86 640 13,000
100 440 504100
4,800 68.000 3J6*6
40 (A) 110 (A) 284)00
16,000 Z200 2.46*7
90 (B> 524X»
80 0.004 2X0
1,900 {B} 556*8
200 (B) 156*5
1.400 440 6.36*6
4.000 Z400 3.16*6
100 1,300 454)00
100 1.900 1.66*5
524)00 124XX) 336*7
154XX) 500 4.26*7
1500 540 84J6*5
14XJO 420 32*6
840 {B} 2.46*6
4.06*6 880 1J6*B(G)
744» {B} 556*7
904XX) 640 Z6E*6
2^00 {B} 1J6*6
ID {8} ID
ID (B) ID
600 440 456*5
480 520 3.46*5
9.4 (B) 5500
O(P) (8} ID{PJ
1X0 (A) 160 (A) 3.76*6
134X30 {B} 9.76*6
40 62 1.200
22 (B) 6X0
5.600 1X0 24E+8
48,000 (A) 1.600 (A) 1.46*6
Malhca
Limln
Sol
10
10
10JOOO
500
10
NA
170
20
NA
330
10
10
10
10
1.700
330
50
10
NA
NA
NA
50
500
NA
10
10
NA
204)00
1.000
100
10
NA
30
1.000
6/5/95
-------
=ootnotes
{A} Background, as defined in Rule 701 (c), may be substituted if higher than the cleanup criteria.
{B} Chemical has either not been evaluated or an inadequate data base precludes the development of a GSI value.
Contact an ERD toxicologist for assistance.
(C) State of Michigan Drinking Water Standard established pursuant to Section 5 of the Safe Drinking Water Act. Act
No. 399 of the Public Acts of 1976 used as the default.
(D) GSI value is pH, temperature, or water hardness dependent. Contact an ERD toxicologist for details.
{E} Chemical, due to its physicochemical properties, is not expected to leach through soils to groundwater under
most conditions.
(F) Professional judgment used to determine that 50 ppb of aluminum in drinking water is protective of human
health.
(G> Criteria exceeds 100% in soil, hence it is reduced to 100%.
(H) Criteria is based on agricultural impacts (phytotoxicrty), not 20X groundwater criterion.
{I} Valence-specific chromium data (Cr III and Cr VI) must be compared to the same valence-specific deanup
criteria. Jf analytical data are provided for "total" chromium only, then values for chromium VI must be applied as
the cieanup-criteria. Chromium III cleanup criteria can only be used at sites where groundwater is prevented
from being used as a public water supply, currently or in the future.
{J> Chemical may be present in several isomer forms. Isomer specific concentrations must be combined for ,
comparison to criteria. Contact an ERD toxicologist for further explanation.
{K} Two different analytical methods and target method detection limits are available for this chemical. Refer to
Operational Memorandum #6 for details.
(L) Criteria developed using the U.S. EPA Integrated Uptake Biokinetic Model for children. No risk assessment
method(s) is currently available to evaluate lead toxictty in adults. Higher level may be acceptable if soil
concentration is less than 400 ppm and groundwater migrating off-site will not impact adjacent properties.
Contact an ERD toxicologist for further explanation.
{M} Also known as MBOCA.
{N> Also known as Silvex.
{O} Use 2.3.7,8-TCDD toxkaty equivalence factors' fTEFs) for other chlorinated and /or brominated
dibenzo-p-dioxins and chlorinated and/or brominated dibenzofurans for comparison to deanup criteria. Contact
an ERD toxicologist for details.
(P) AH potential sources of nitrogen-nitrate must be combined and compared to nitrate criteria. Contact an ERD
toxicologist for details.
(Q) Criteria for carcinogenic polynudear aromatic hydrocarbons (PAHs) were developed using 'relative
potential potencies' (RPPs) to benzcv ;-vrene.
{R> Chemical may be reactive in soil
(S) Concentrations of trihalomethanes in groundwater must be combined to determine compliance with the nealth-j
based drinking water value of 100 ppb.
fO Toxic Substances Control Act, Subpart G - PCB Spill Cleanup Policy standards may be more restrictive.
rrrtorinn- NA = Not available.
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U.S. EPA ADMINISTRATIVE RECORD
METAMORA LANDFILL SITE
METAMORA, MICHIGAN
OPERABLE UNIT ttl
UPDATE *7
O2/15/9&
DOCI DATE
AUTHOR
RECIPIENT
1 04/00/95 Conestoga-Rovers I U.S. EPA
Associates
2 08/00/95 Contstoqa-Rovers t U.S. EPA
Associates
I 01/00/96 U.S. EPA
Public
TITLE/DESCRIPTION
Soil Characterization Report
Soil Remedial Alternatives Report for Orui
Area 1
Fact Sheet: 'U.S. EPA Recouends Change in
Soil Cleanup Decision' H/Announceient of a
Public Couent Period and the February 20,
1996 Public fleeting
PAGES
434
90
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