United States
           Environmental Protection
           Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R05-88/080
September 1988
&EPA
Superfund
Record of Decision
            Mason County Landfill, Ml

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 REPORT DOCUMENTATION j i- REPORT NO.
         PAGE
                        I
                                 EPA/ROD/R05-88/080
                                                                         3. Recipient's Accession No.
 4. Title «nd Subtitle
  SUPERFUND RECORD OF  DECISION
  Mason  County Landfill/  MI
         Remedial Action
                                                                         5. Report Date
                                                                            09/28/88
                                                                         8. Performing Organization Rept. No.
 9. Performing Organization Name and Address
                                                                         10. Project/Task/Work Unit No.
                                                                         11. Contract(C) or Grant(G) No.

                                                                         (C)

                                                                         (G)
 12. Sponsoring Organization Name and Address
  U.S.  Environmental  Protection Agency
  401 M Street, S.W.
  Wasnington, D.C.  20460
                                                                         13. Type of Report & Period Covered

                                                                            300/000
                                                                         14.
 15. Supplementary Notes
i
  • Ab*!ifn
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EPA/ROD/R05-88/080
Mason County Landfill/ MI
First Remedial Action

16.  ABSTRACT (continued)

placed in the top of the landfill.  The site has been separated into two operable units;
one for the landfill contents and one for the ground water.  This source control
remedial action addresses the landfill contents.  Contamination of the shallow and deep
aquifer will be addressed in a subsequent remedial action.  Site investigations indicate
that contamination of surface water, surface sediment, soil, and offsite air quality are
not sufficient to warrant remedial action.  The primary contaminants of concern
affecting the ground water are VOCs including benzene, PCE, TCE, and xylene.

   The selected remedial action for this site includes:  construction of a RCRA cap over
the landfill; access restrictions; deed restrictions on and near the site to prohibit
use of the shallow aquifer; and ground water monitoring.  The estimated present worth
cost for this remedial action is $2,800,000, with present worth O&M costs of $1,000,000
over 30 years.

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                                RECORD OF DECISION

                     SELECTED INTERIM REMEDIAL ALTERNATIVE

Site Nave and Location

    Mason County Landfill
    Mason County, Michigan

Statement of Basis and Purpose   ,

    This decision document presents the selected interim remedial action for
the Mason County Landfill, in Mason County, Michigan, developed  in accordance
with CERCLA, as amended by SARA, and to the extent practicable, the National
Contingency Plan.  This decision is based on the administrative record for
this site.  The attached index identifies the items that comprise the
administrative record upon which the selection of the remedial action is
based.

    The State of Michigan has concurred with the selected remedy.  The letter
of concurrence is attached to the Record of Decision package.

Description of the Selected Reaedy

    The selected remedy is an operable unit that will address the landfill
contents portion of the site by properly capping the landfill.  The operable
unit that will directly address the groundwater contamination and other off-
site contamination, or potential contamination, shall be addressed after more
investigation is done, including the assessment of the effectiveness of the
new landfill cap.  The selected remedy is considered cost effective and is
consistent with the eventual  final  remedy.  The specific components of the
selected remedy include:

    *  a RCRA subtitle C compliant soil/clay cap,
    *  a fence around the site,
    *  deed restrictions on and near the site to prohibit use of the shallow
       aquifer, and
    *  continued monitoring to apply towards the groundwater operable unit and
       to monitor the effectiveness of the new cap.
                                 -•'*•"
Declaration

    The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant and
appropriate to the remedial action, and is cost effective.  This remedy
utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site.  Because treatment of the principal
threats of the site was not found to be practicable, this remedy does not
satisfy the statutory preference for treatment as a principal element of the
remedy.

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                              -2-



*hn ^Uh'hl. JTV1'11  PeSUlt  ln*azardous  substances  remaining  on-site
above  health-based  levels, a  review  will be conducted  within  five years  after

commencement of remedial action to ensure that  the  remedy continues to provide
adequate protection of  human  health  and the environment.               yruviae

Date
                              Valdas V."

                              Regional  Administrator

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 Page No.
r
 TITLE
                                  AUTHOR
               MASON COUNTY,  MICHIGAN

                               DATE     PAGES
Apoendix A Kason County Landfill
Statement of Horn
For Conducting RI/FS

Letter to Ethel Lister,  Clerk
Pere Ha&ei'YoSnship,  re lab
analysis of waste confining
it is industrial waste.

Letter to Arthur L.  Sheman
answering questions on
"lason County Landfill

To Mason Cty Dept Punhc
Uorxs:  Concludes Phase I
of landfill program and
includes reconendations
for Phase II and a segment
of Phase III work

     Ann Sause, Ecology i
Enviromient, Inc.
Letter encloses sew re ouolic
cowaient on landfill
Prein i Newnaf
                               00/00/00   16
                                                                 75/11/26
Bureau of Envrrwtal Protection 76/11/OS
Uilhai i Works
                                                                 81/10/06   83
FWxrttshalk, Dcot Ntrl Resrs   82/05/13   2
Potential Hazardous waste Site    EPA
Site Inspection Report

Deposition of Tisotny 0.  Hansen

State of Michigan Deposition
of Dennis 3.  Forrest

Deposition of Sooert Dixon

.lison County Iris rtoad  Landfill   Aquatic Systems,  Ire.
vreoarea for:  Noraiuna DunJap
I Associates

Letter to Acne Disposal Company   'JSEPA Peg V

Final Ccffliounity Relations PUn    CKL1 HILL
     «to RUnippo - USEPA re:
    1 Ojunty Landfill
ft I Existing Data Analysis
Task EO
SMcBee - 0&1 HILL
                                                                 82/06/23   £8

                                                                 82/06/23   75


                                                                 83/06/2:3   ^

                                                                 85/07/25   26



                                                                 85/08/05    6

                                                                 86/04/00   35


                                                                 86/04/18   52

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Pagt No.      2
01/22/88
                                                »ASON COUNTY, filCHIGflN

TITLE                            AUTHOR                        OflTE     PAGES
Work Plan 8I/FS                  CH2K HILL                     86/06/27   78

fltt IV Zone I! QflPP *             CKffl HILL                     87/05/21  399

Work Plan Pnase II  ft I/PS          Q& HILL                     87/06/00   38

OfiflFT:  Pnase I RI                Ofi« HILL                     87/06/05  268
Tecmucal Report

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Pagt No.
  /22/Bfi
TITLE
                                   AUTHOR
     MASON COUNTY,  MICHIGAN
GUIDANCE DOCUMENTS - NOT COPIED
     MY BE REVIEW) AT EPA
         IN CHICAGO,  IL

                       OATE
Standard Operating Safety Guide
Manual

Outdance on Remedial  Investigations
under
Delegation of Remedy Selection
to Regions

Guidance on Feasibility Studies
Under CEfiOA

Superfund Public Health
Evaluation Manual

flOU Between tne fiTSDR and  EPA

   >ns Guidhnes and Ssecs for
        .q QAPPs (QAMS-005/80)
'Jsers Guide to tne U5£PA Contract
laooratsry Prograa
                                                                  80/12/W


                                                                  82/Ofl/OO
Intern Standard Owrating  safety
Guides
Sjcerfuro C
                    Selations
                                                                  82/M/OO
                      83/05/12
Cc-munity relations in superfuno:
Ccinunity Relations in Superfurio:
A Kandoo>;k

buidarce "leooranduti on Use  and
Issuance c-f Administrative  Orders
      Section 106 of CE.RCLS
Interia CtSC^A Sett lament  Policy
       Cotohance aitn otner
              Statutes
                                                                  8J/09/00


                                                                  SS/W/w


                                                                  83/03/08



                                                                  84/00/00

                                                                  85/02/12

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iC9 NO.
      hftHt PHGES  WTE
 TITLE
HbMINISTMTlVE RECORD INDEX-UPDflTE
      flftSGN COUNTY UWDFILL
      -MflSON COUNTY,

         HUTHGR
 RECIPIENT
                                                                DOCUMENT TYPE
             6  85/08/05
             £  65/08/20


             £  85/08/22
 Sepuest to PRP that tney       Kerry Weiss - USEPfl
 Voluntarily  undertake actions
 necessary to aoate or orevent
 the release  of hazardous
 suostances.
                                            ficse Disposal Co.   Corresponaence
Response to 6/5/85 Notice
Letter.
         J.KoiDa-atty.for EdiChristine Dams Jonn Oaks-USEPA     Corresoonaence
Response to UStPA letter of    Clay Olasteao-flason Co.
8/5/B5
and an oojection to being
considered a PRP in tnis
natter.
                                            John OaKS-USEPfl     Corresponoence
             1  85/06/23     Letter reouesting a response   Frank Hollins-uSEPfl
                             to
                             a letter sent 8/5/65
                             requesting
                             that tne PRP participate in an
                             RI/FS.
                                                                   Harm son-Walker     Correspondence
                                                                   Refractor
             1  85/08/23
             1  S5/08/25
             1  85/08/26
             1  35/06/28
             1   65/08/29
Request that the PftP respond   Frank Rollins-OSEPfl
to letter of 8/5/85 requetsing
that tney participate in
an RI/FS.

letter reauesting a response   FranK Rol1ins-uSEPP
to
tne USEPfl- letter of 8/5/65
whicn requested a response
en their willingness to
conduct or participate
in an RI/FS.
Letter declining to
participate
in an ki/FS.
        J.Ko:ca-atty. for Ed Dams
Invitation to attend a nesting FranK fiolhns-USEPH
to oee held on '3/6/85.
Invitation to PRP to
participate
in a neetmg to ce held on
        frank Rollms-USEPfl
                                            The County of
                                            nason,MI. •
                    Corresponaence
                                            ficue Disposal Co.    Corresponoence
Frank Rol1ins-USEWl Corresponaence
Clay Olrasteaa-.iason CorrespC'noence
Co.

L.Denooyer-Harbison Correspondence
Walker
           1!6  65/09/06     Response to Information
                                              Refractories
FranK
                                                         -uStf'H C.orre?conoence

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no.
     t PAGES GATE
           I  65/12/04
TITLE

Request..
HiMNlSTftATIvt RECORD IMtX-uPDATE
      BASON COUNTY LANDFILL
      DHoON COUNTY,  MICHIGAN

         AUTHOR
RECIPIENT
DGCUi€NT TYPE
Pi


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Page No.     i
  to
         E144S; E1624  to E  1447.

6c!/G7/l9 FtevieM and  data package for    Cnuck Eil
         EPA data set  no. 5F1658,
         i«0 traffic noi tlbio.
eo/ii/lfi review ano oata package  for    ^atricx  Cnuriila-uSEPA
         h'PA data set  no. SF3579,
         SMO traffic no. E01-E015.

86/12/22 Review and data package  of     Jay Thakker-USEPA
         EPA data set  no. SF3595
         SSO tarffic no. E0l-£0lc'
                                                                             B.Bartholoaew-Eeol  Sampling/Data
                                                                             4 Env.
                                                                             boo                 Saeipiing/Data
                                                                             BartnolmetHicoi. 4En
                                                                             v.
                                                                             B.Bartnolonetrtcol.  Saapling/Data
                                                                             tEnv.
                                                                             Chc'M Hill
                                                                             CH2J1 Hill
                                                                                                 Baapling/Data
                                                                                                 Sampling/Data
67/01/05 Review  and  data  package of     Jay 1 nakker-USEPfi
         EPA data set  no.  5F3534
         5«0 Traffic no.  r£C7il-739;
         fOaS'S-SlO; «EC234-i40;
         BEB369-268.

87/01/05 Review  and  data  package: USEPA Patrick. Qvjrilla-USEPA
         data  set no.  SF3S94 ,  SMO
         Traffic
         no.
b6/0l/il  Review  ano oata package for    Curtis *oss-u£EPH
          tFfi data set  no.  SF4/45:
          i^O traffic no.  "itc>
-------
Page No.
O'i/i'9/da
  nT< •'
  ;~t

SflO traffic no. I1E6673,680,
695,697-700, 793,794.997,;
1*1661,796.800;MEK302,322-327,
412,413.42S-434,442-445,464;«£
F3%.
                                            HDPIIN1S1 NATIVE SECflfiD SABPLING/DATA INDEX
                                            MftSON COUNTY LHNOFILL,  HflSON COUNTY NlCHISfiN
                                            DOCUMENTS  NOT COPIED,  HftY BE REVIEWED AT THE
                                            USEPfl KE6ION V OFFICES,  CHICAGO,  ILLINOIS.
                                                                             RECIPIENT
                                                        DOCUMENT TYPE
•.'8/02/12 Review e>.no  oata  package for
         EM oata set  no.  SF4739:
         S«0 traffic no.  EK161-175.
         Review  ana  oata  package of
         EPA data  set  no.SF4740:
         SMO traffic no.  EJc'6c:-£63;
         ER076-82, 084-086, EL198, £00,
         457,458,441,569,571,579.
86/02/25 Review ano  oata  package for
         EPi^ cata  set  no.  SF47!444-446, 443,501.
                 r>c c.'.ts pgc-Kfge  or
         kC'A cata 9=: ro. ic4/4/:
         S.r-0 traffic no. £3i-ttl,
Jay ThakKer-uScKfi
v'5:ricv. C'nun]io-'.'Sc^'ft
                                                                   CHclK                Sanpl ing/Data
                                                                   HilliB.Wuppo-USEPfl
                                                                   CH2B                iaraoiinq/l'ata
                                                                   hilliB.Hnippo-USEPrt

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Page to.
03/19/88
UHl'E
TITLE
         E53-fc73.
dtf/04/05 Review ana data package of
         EPA data sec no. SF<»746:
         3KO traffic no. a£K465-47l;
         KEH444-«46, 443,501.
d6/04/06 Feviei* and data package of
         EPfl oata set no. 3FW10:
         SnO traffic no. ullegioie;.
                                            MD«INISTKftTIVt' RECORD SfWPLlNS/DATfl INDEX
                                           MASON COUNTY LANDFILL, MSCN COUNTY WICHIGftN
                                           DOCUWBffS NOT COPIED,  NftY BE REVIEWED ftT THE
                                            USEPfl RESIGN V OFFICES,  CHICfiGO,  ILLINOIS.
RECIPIENT
Win
                               Jay ;haKker-USt>'A
                               Uinston Vijjeswarapu-OSEPfl
         TYf€
Saapling/Data
                                                                  HilltB.Wiiooo-USEPfl
CD,1 i Dan
Cozza-USEPfl
SaHDling/Data

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Page NO.
                                 WON COUNTY LANDFILL, HHSClN COUNTY,  MICHIGAN
                                        GUIDANCE OUCUWENTS - NOT COPIED
                                       KftY Be REVIEWED AT USEPA RESIGN V,
                                               CMCfltf), ILLINOIS
 TITLE
                                    AUTHOR
DATE
Stanaaro  Operating  Safety 6uioe
Manual
 buicance on  Ke«eo:ai  investigations
 Unoer CS
 Delegation of  ftewefly Selection
 to regions

 Suicance on heasiOiiity Studies
 Uncer LE^.LLrt
           Puohc Healtn
          n .lanuai
  Cij between tne  HTSDff  ano tP
Inter IK ouiahnes and  Soecs  for
   oaring Qrt
Upe
       Guice  to tne UsEPA Contract
 Laooratory Program
                                                                   80/12/29
                                                                  82/06/00
 interrd itancard Ooerating Safety
 Guices
                                                                  82/09/00
 Superfuno Coonunity Relations        WHednan
 Poiicy

 Corivunity Kelations in Superfunc:
 nanooooK
                                                                  83/05/12
                                                                  83/09/00
 CouBunity delations in Suoerfuna:
 A
                                                                  83/09/00
      xre r?j»randun en U5« aro
 issuance of icaimstrav.ve Orcers
 uncsr section lOb of C£,-(Cl>)
                                                                  83/09/06
 Interin CcSCLft Settie;ient  Policy

 Ccl-CLri CoMoharice witn  otner
               Statutes
                                                                  84/00/00

                                                                  85/02/12

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Page No.
            PhGtS DM it      TlftJ:
                                                                  t Xtt.UKb lUlrt-X UPl/Hlt NU. i
                                                                  LiN LUUfHr LWJUf'ILL
                                           HU'fWJH
                                                                           Kk'CIPiENf
OOCifltNT TYPE
-H
                                                           Corp.

                                                                               walker     Janet riaff - UctPH
                                                           Merract.
                                                                fson, area resicent       Crcce, Usci-vi
                                            neiiey for baae,  bit>'H

                                                 forquette funsnip.  bd.
                                           Joiies J. r.ooza
                                                                                ,  UStPri
                                                                                 Molhngs-DatPfl
                                                           na£cri, area resiac-nt
                                                                                                     Corresponaerce


                                                                                                     Ccrresporidence
Corresporidence


Correspondence

Correspondencll


Corresponoerice
                                                                                                     Correspc>noerce
                5  Bb/Os/iS Letter cobueiiting en draft     Pacific, us L'ept. of Interior  Coz:a, Use
J  efi/Ou/20 Letter cc-aatnt i ng on tPH's     Treup, atty.  fcr
            HOD
                                                                                  Lty.    uc-!:a  6  h'aaell,  uitPfl
                            Letter rei-p-jnaing to Pnv       Oavi;, btty. for P«P itr«its   Crcce,  uitPfl
                            rvitice letter afa couucnting   Steel
                            on tne hl/r-S and tne
                                     Action Plan
                      Oa/il Letter cc-Kuc-nting on Hl/rs     bunlao, HC-SI snore tngtneenng  Cozza,
                            and PropoEeo Pi in.
                          -: LOKerria ino c-:«.*iii£ oy       uar/
                            tna itite of tticnigin ar,o
                            a request tnit tf(*y rt;
                            incluaej u, tr.e fir.ii hiiu
                                                                                                     Cc'rresponderice


                                                                                                     Correspondence


                                                                                                     Corres(>jndence




                                                                                                     Correspondence
                                                                           Miry tiioe - ostPH         Lorre&poroerice

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                                                                   ' KtCOM  I (MX  Ut-iHil NO.
                                                               BliatJN  COUNTY LHiNllt-'lLL
                                                                            MlLMibHN
FICHt/Fhhft:
TlTLt

along HI in coromK>nal
acceptance of tne lira ft  ft
da recievea on u/T//tto.

Coriditional afcceptence of
tne Proposed Plan for
               j  68/0'i/cO tetter aaore&sing corcerns
                            in the Hub a/Kj inoicates
                            riOM tnose cc-riceiYiS nave
                            been or will oe addressed.

               4  twi/ua/00 Fact Sneet :
                            Mason Dvjnty Lanjfill
                            (•fcasiDihty biudy Ccaoleteo
                            Mitn information re:
                            tiue uA place of 6-1 /-fto
                            pijohc
                                                           til 11
                                         Mary bace - USti-'H
                                                                        ban Cozza -
bary Suentner-UbfiPA
              b'J  68/06/1 /  Transcript of o-l't-tio
                            puolic ueetinq
                                         NcLoutn,  lertified Electronic
                                         uper.
              cl  68/04/06  Letter responuintj to request   Herceg,
                            for State Hppiicacle or
                            helevant  arid Appropriate
                                                                        Cozza, Ubtf'ft
         to tne fliiuri County site,
         ucludir.g Hhtins ineritionea

t)7/liivOO Draft Ucnri.:a Hlternatives Dev
         Vecnnical Keuoranouu

66/0'//li Final HI Report

8a/0a/0t u&Pfl's Pr-oposeo Plan
         for rtaton Lty.  sue
                                                                Hill
UStPA
 a/i'O/Mj f-uolic Courient  Report
         on tne r'eoiioility Stuay
         riepOl't
                                                           iruli
USLt-'H
                                                                                                                     DOCU«£NT TYPE
                          Correspondence
                                                                                         Correspondence
                                                                                                  Fact Sheet
                          Meeting Notes


                          Other
                                                                                         Reports/Studies



                                                                                         Reports/Studies

                                                                                         Reports/Studies


                                                                                         Reports/Studies

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CF IMSRIM REtCnCAL MaEEtMTVE SELECTION
      mscw cousny
            OXJNIY,
                  , 1988

-------
                             TABLE: CF CCNTENTS


                                                                    page

I.    xi'iyi LCCAT1CW AND OESCRXFTKXT  ........................... . ...... 1'
H.   SITE: BACKGROUND AND ENfclULMfJM1 ACTIVITIES ..................... 2-10
      A.  Site History  ............................................... 2
      B.  Past Studies  ............................................... 3
      C.  current Site Status  ........................................ 3
      D.  Site Characteristics ....................................... 4-9
      E.  Summary of Site Characteristics ............................ 9^-10
      F.  CERCLA Enforcement ......................................... 10

IH.  OMUNITY RECAHCTE ............................................ 10

IV.   SCOPE CF FEftSTBTLTTT STUDY  ..................... f ............... 11

v.    SITE: RISK AssEsaiENr' SIMWOT ............. . .................... . 12-13
VI.   DESOKIPEICN" CF REMEDIAL AUERKMIVES  ........................... 14-28
      A.  Screening of Alternatives  .................................. 14-21
      B.  Alternatives Considered. ................................... . 21-28

VTII. SIMRRY CF CCME5VRATTVE MM3SIS CF AUEERWO1TVES ................ 28-29

IX.   PRTOSED FLAN AM) DOOJMENTftElCN GF SIOSEFICANr CHMX25 (Section
      117 (b) [[[ 29

X.    *«'3J«t?l'Hl REMEY AND SIMUTCBT TEEEPKUKTICKS ................... 30-34
      A.  Landfill Contents  Cperable Unit ............................ 30-33
      B.  Garoundwater Cperable Unit  .................................. 33-34

XI.   SOME ISSUES .................. ................................. 34

XII.  SIMftRY [[[ 34-35

ATEPOMENTS


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                     OF TNITRIM REMEBVL ACEEBNftTIVE SELECTION

                                 COUNT? I2BDETLL
                                 COUNTY,
I.  SITE LOOVHON" AMD EESCKEFnCKr

•Die Mason County Landfill Site is located three miles south of  the City of
Ludington and one  mile east of  Lake Michigan  (see Figures  1 and 2).   One
Site occupies approximately eighteen, acres of a predominantly rural area in.
Fere Marquette Township; approximately ten acres of the Site is landfilled.

Ludington, Michigan has  a population of  about 9,500.   The population of
Mason  County  was   estimated  at  26,400 based on the  1980  census.    "Die
population within a three mile radius of the Site was estimated at 1,112.

As Figure 3 indicates, just north of the Site is heavily wooded and orchards
are located to the  east and south of the Site.   The local topography varies
fromi relatively  level  upland, areas south and east of the landfill to steep
valleys north of the landfill.   Figure 3 shows both the current topography
and. Site  topography before landfilling began  in  1971.   Comparison  of  the
topographic contours indicates that an. estimated 140,000 cubic  yards (+/-
20,000 cubic  yards) of fill  is buried  in the landfill.   The  landfill is
generally a valley fill with a maximum depth estimated to be 40 to 50  feet.

Surface waters  in  the Site area are Iris  Creek,  the Fere Marquette  River,
Fere Marquette Lake, and Lake Michigan  (see Figure 2).  The  headwaters of
Iris Creek are located less than 500 feet from the landfill and consist of a
wet, marshy area southwest of Babbin  Road  (see Figure 3).  Water from,  the
marshy area drains  into  Babbin  Pond, which discharges directly into Iris
Creek.  Iris  Creek discharges into  Fere Marquette River, which discharges
into Lake Michigan.  A pumped-storage  power  reservoir operated by Consumers
Power Company is located approximately one  half mile south of the Site.

Lake Michigan is the main drinking water source in the area and is the City
of Ludington's water supply.   In rural Fere Marquette Township,  residents
generally  depend  on  small  domestic  wells screened in sand  and  gravel
aquifers for  potable water supplies.  There are fourteen residential wells
within about  a half mile radius of the landfill that vary in depth from 30.
to 150  feet  below ground surface (bgs).   They are monitored biannually by
the  Mason  County  Department  of  Public  Health  for a  range  of organic
parameters.

Other water uses in the area  include large capacity wells that produce salt
brine for  industrial use.  A salt brine well  about 1,000 feet west  of  the
landfill is screened in an aquifer at a depth  of 450 feet bgs.  The brine
aquifer is separated from the overlying aquifers  used for potable water by
more than 300 feet of low permeability glacial till.

Mason County  is  underlain by bedrock  formations  at depths from  300  to  700
feet.  Mississippi  Age Coldwater Shale lies beneath  the  landfill Site at a
depth of  650  feet.   The  formation  is predominantly shale with occasional
interbeds of sandstone and limestone.

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                                                            TOWNSHIP
                                                            •OUNOAftlES
LAKE MICHIGAN
   MASON COUNTY
   LANDFILL SITE
   PERE MAROUrrTE
   TOWNSHIP
             KEY TO COUNTIES
                                      MASON
                                      COUNTY
                                      BOUNDARY-
                                                            SCALE IN MILES
                                                                    FIGURE   1

                                                                    LOCATION MAP
                                                                    MASON COUNTY LANDFILL Rl/FS

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                                                         PERE MAROUETTE RIVER
                             T-j^^ MASON COUNTY
                                    LANDFILL SITE
SOURCE: U.S.G.S 7.5' TOPOGRAPHIC MAP
       OF LUOINGTON. MICHIGAN QUADRANGLE.
                                                        FIGURE 2
                                                        VICINITY MAP
                                                        MASON COUNTY LANDFILL RI/FS

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             MARSHY AHEA
             (HEADWATERS OF
             IRIS CREEK)
  LEGEND
  .71*
1986 GROUND SURFACE CONTOURS

ORIGINAL GROUND SURFACE CONTOURS
(1971 TOPOGRAPHIC MAP PROVIDED
FOR ACME DISPOSAL)
CONTOUR INTERVAL-25 FEET
          LANDFILL (APPROXIMATE)

* — ' —  PROPERTY LINE (APPROXIMATE)


NOTE: Approx.mate landfill and property boundaries based on Mason County
       DPW legal property description and aerial photograph.
                                                                                          SCALE IN FEET
                                                                   FIGURE    3
                                                                   SITE MAP WITH ORIGINAL
                                                                   SITE TOPOGRAPHY
                                                                   MASON COUNTY LANDFILL FS

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Three or  four subsurface tills have been recognized in the  immediate  Site
vicinity-   The upper three tills  are  relatively thin and. are separated by
thick outwash deposits.  A conceptual model of the regional geology near the
Mason. county Landfill is depicted in Figure 4.
u.  SITE. HisTdor AND ENFORCEMENT

   A. Site History

The Site property was originally owned by Edward Dains when it was selected
for  use as  a sanitary landfill by  the Mason County Department of  Public
Works  (DPW).   In 1971,  Mason County DPW leased, the property from Mr.  Dains
and subsequently entered into an agreement  with Acme Disposal to operate the
landfill.  Mr. Dains was hired by Acme Disposal as a Sanitation Engineer to
oversee  the daily operations of the landfill  from 1972 until 1978.   The
Michigan Department  of  Public  Health  (MDPH)  approved  Acme's Solid  Waste
Disposal Area license  in  1971  with the  stipulations  that  no refuse  be
disposed of below the  710 foot elevation mean sea  level  (msl) , that  the
final cover contain at least twenty percent clay,  and that  monitoring wells
be installed.  The original Site topography is shown in  Figure 3.   In 1973,
landfill  licensing and  oversite were  transferred  from the MDPH  to  the
Michigan Department of Natural Resources  (MCNR).   The MDNR documented that
the slurry and. sludge wastes from local industries were  being dumped at the
landfill, allowed to dry, and then covered.  The Site's  license was renewed
annually  through  1977;   it  was  closed in August  1978  when  it  reached
capacity.   Public concerns over  the water quality in nearby Iris  Creek
prompted the Mason County DPW and the MDNR  to review closure activities.

In  1981, two  property owners  filed suit  against Mason  County.   One,  a
neighbor,  alleged that  the  landfill  run off  had. damaged  property  and
deteriorated  the groundwater quality,  while the  other, the  owner of  the
landfill property, alleged there had been a breach of contract regarding the
property  lease  agreement with  the  Mason County DPW.     As part  of  the
settlement with both parties, Mason County purchased, both properties  and is
currently the owner of the landfill property.

In 1983, the Mason County DPW received a  grant from the state  of Michigan
for  iirprovements  to  the landfill.  A clay cap was completed and berms  and
storm  drains were constructed  to improve Site drainage (Figure 5).   Two
surface aerators  were installed  in Babbin  Pond to help  aerate the pond and
facilitate biodegradation of organic matter.   Fifteen gas vents  were  placed
into the top of the landfill.

   B» Past
Site studies  and investigations, previous' to  the formal U.S. EPA  Remedial
Investigations  at  the  Mason  County  Landfill,  began  in  1971  with  a
preliminary evaluation of  the landfill  Site and have continued through the
Site  closure  work  completed by the  Mason  County DPW in  1984-85.   A
chronological  summary of the major  landfill investigations  is provided  in
Table 1.

-------
                                                                 TABLE   1  (Page  1   of  2)
                                                Summary   of  Previous  Site   Investigations
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                                                                                                          I Mlk«4* Mtt4 414 Ml
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                                   Hit
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Ml«lil|«n !*••§ Id* Cictk
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                                                                                                   fc piUrlly Mllultnl* «i*ljti*4

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                                                   l**ck«i* lio* ill* l*ii*l|l|

                                                   Ha •*• lltU 4
-------
                                                          TABLE   1  (Page  2  of  2)
                                         Summary  of  Previous   Site  Investigations
                                      (••I*
 H*M>n Cuunir OfW IkinllMlni          !•»•
 bill lfiM«ll«llon*
*!•• NanllMlnf Mil                1*11
ln«l*ll*lla«*
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•n4 !••! kofjflft
       ml law/  ••Ullnf Mil*
MD Mll*| (Mfl* «•<


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                                 «o4
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       k« I«i4ll
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• f (IM  iMtfflll ••« «*IM|«4 kl(|l
                                                                                                lw>4llll  tnt tilt Cf»»k
                                                                                                                                       414
                                                                                                                                           (l*»lU| »llan« nul


                                                                                                                                                 tuntf to*»i»4 » ttlf
H..QH County OTW Un4llll
                                   IMI
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                                                                                                                                       • II* >f<« Mllnuul (llMplIni !•
                                                                                                                                       Utmlly •Ullaci «n
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CLI1*1/11

-------
                                                                                       DOMESTIC
                                                                                       WELLS
                                                                                                            EAST
CO
5
CO
Z
Ul
_l
01
ui
x
o
oc
o.
a.
                                                  BRINE PRODUCTION WELLS
                                                                                          MASON COUNTY
                                                                                          LANDFILL
                                                                                               • !  . UPPER AQ
                                            'SILTS AND CLAYS
                                             (LOCALLY RTF* HREO TO AS TILLF
                                                                                                LOWER AQUIFER
            LAKE MICHIGAN
                                        .   .  .GLACIAL OUTWASH
                                              AND LACUSTRINE DEPOSITS* .
                                               GLACIAL TILL
                                                       GLACIAL OUTWASH
200-
     0-1
                                             BEDROCK AND BRINE AQUIFERS
                                                -NOT TO SCALE-
                                                                                          FIGURE  4
                                                                                          CONCEPTUAL GEOLOGY
                                                                                          AT MASON COUNTY LANDFILL
                                                                                          MASON COUNTY I ANOFII I FS

-------
As  indicated in Table 1, the  EPA. Field Investigation Team. (FIT)  inspected
the  landfill  Site  in  May  1982,  sampling  and  analyzing  the  existing
monitoring wells.  After the FIT data was evaluated, the Site was assigned a
hazard ranking system, score of 34.18, a score high enough to qualify it for
inclusion on the National Priority List (NFL,).  This score was given because
of  the  presence  in  groundwater  of  ethyl-benzene,   pentachlorophenol,
trichloroethene,  1,2 trans-dichloroethene, and 1,1-dichloroethene and the
associated toxicity and persistence of these compounds.   The Site was put on
the final NFL in 1982.

The MOPH replaced S.  Dains's and May's residential wells  (see Figure 5)  in
September 1987 because of health, risks identified by MQPH sampling done in
the fall  of 1986.   S.  Dains's  old well, approximately 400 feet  from the
landfill and screened at a depth, of 130 feet, was replaced by a  well 348
feet deep.  The well was  replaced because of the presence of 2-butanone and
4-inethyl-2-pentanane.   May's  old well,  located  approximately 1,200  feet
north of the landfill and screened at a depth, of 60 feet, was replaced by a
well 218 feet  deep.   The old May well  was replaced because of the presence
of trace concentrations of tetrachloroethene.

   C. Current Site Status

A Remedial  Investigation (RI) at the  Site  was conducted by the  U.S.  EPA.
through the use of its contractor, OEMHill.   The RI consisted of two phases
or  sampling  events.    Phase  I  of the-  RI  fieldwork  was conducted  fromi
September to November 1986  and Phase II was  conducted between October 1987
and January 1988.

The RI at the Site included the following:

     1. Review^ and evaluation of past  investigations as well as historical
practices and other records relating to the Site.   (RI Phase I)

     2. Extensive aquifer sampling and water level measurements (in both the
upper and lower aquifers) to determine  groundwater quality, flow directions
and gradients, etc.   (RI Phase I and II)

     3. An  electromagnetic  geophysical  survey was  conducted to  evaluate
whether  existing  landfill  monitoring  wells  were properly positioned  to
interpret potential plumes originating from, the Site.   (RI Phase  I)

     4. Samples  were collected  within  the wetland,  Babbin Pond,  and  Iris
Creek to define  the Site's impact on the surface  waters and sediment.   The
base  flow  in  Iris  creek  was   determined  to  help  estimate  groundwater
discharge rates into the creek.   (RI Phase I and II)

     5. Soil borings  and  the gamma logging of existing monitoring wells was
conducted to help define the geology of the Site.  (RI Phase I and II)

     6. The  Site's gas vents  and ambient air was sampled to determine the
Site's impact on air quality.  (RI Phase I and II)

-------
                                      LOWER GRATED
                                       ANHOLE
SLOPE
IMPROVEMENT
  LEGEND

            GROUND CONTOUR

            APPROXIMATE LANDFILL BOUNDARY

 ""	'-   SURFA« WATER .NTERCEPT.ON BERM

 *"~*   BURIE° 10" PLASTIC DRAIN PIPE WITH INLET AND OUTLET

L* -»0-> -*   BURIED 24" DRAIN P(PE WITH TWO MANHOLES

•»"•»»*«»  DRAINAGE  SWALE

           CLAY CAP
                                                              SCALE IN FEET
                                                        FIGURE  5
                                                        SITE IMPROVEMENTS
                                                        OF 1983 AND 1987
                                                        MASON COUNTY LANDFILL F

-------
     7. Surface  soil samples were taken  to determine if erosion along the
northern side of the Site presents a pathway of contaminant migration.   (RI
Biase II)

     8. Sanples  from a drainage pipe leading  from  the  Site to Iris Creek
were taken to determine if ground water and/or leachate is infiltrating  into
the  pipe  and  therefore  presenting  a  possible  pathway  of  contaminant
migration.  (RI Phase I and. II)

The results of the RI are detailed in the RI Report  (July  1988).  The  Site
FS was completed in July 1988.  The  FS documents  in detail the development
and. evaluation  of an array of  remedial  action alternatives for the Mason
County  Landfill  Site.     A   summary  of  the   physical  and  chemical
characteristics of the Site are discussed below.

  • D1.  Site Qy*rflgt-reristics

      1.  Physical Characteristics

            a.  Groundwater and Surface Water Conditions

The  interpretation   and  discussion  of  groundwater   and  surface water
conditions at the Site is based primarily upon  data obtained during the
remedial  investigation.   Site  hydrology  is described  in detail in the RI
report.

Groundwater  -  Two  aquifers  have  been  identified  at  the  Site.     The
potentibmetric surfaces of  the upper  and  lower  aquifers were determined
using water  level measurements  taken in December 1987  (Figures 6 and 7).
The hydraulic gradients  and  hydraulic conductivities of each aquifer are
summarized as follows:

      Hydraulic  Conductivity  (cm/s)       Hydraulic-Gradient  (ft/ft)

                  Range       Logarithmic         Range       Arithmetic
                	Average        	 Average
Upper Aquifer   5.0 x 10~4 to   2.5 x 10"3     0.040 to 0.064    0.052
                8.7 x 10-3
Lower Aquifer   6.1 x 10~3 to   4.4 x 10~3     0.018 to 0.310    0.025
                2.4 x 10-2

The upper aquifer is unconfined and possibly perched above the subsurface
till  units  as  evidenced  by  large head  differentials  between  the  two
aquifers.   The till units are thin  and possibly discontinuous'on the north
side of the landfill.   The outwash deposits overlying the till units have
interlayered  seams of  silt and/or  clay.   The tills  and. clay/silt  seams
retard  groundwater flow from the upper aquifer  to  the lower aquifer.   This
subsurface  condition combined with  recharge (including potential  recharge
from the nearby pump-storage reservoir)  could produce perched conditions.

-------
                          ;/  X /   I
                          " /  / /
                       '///73V
                       '';//;/+  -
LEGEND
 684.4
GROUND CONTOUR



WATER LEVEL RECORDED IN DECEMBER. 1987


INTERPRETED GROUNOWATER CONTOUR



INFERRED GROUNDWATER CONTOUR



BORINGS WHERE SHALLOW AQUIFER WAS

NOT ENCOUNTERED IN NOVEMBER 1987.
                                                 FIGURE 6

                                                 UPPER AQUIFER

                                                 POTENTIOMETRIC SURFACE

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  LEGEND

 .-»—*     GROUND CONTOUR

  • 619.4  WATER LEVEL RECORDED IN DECEMBER. 1987

	620 — INTERPRETED GROUNDWATER CONTOUR

, _ 630 _  INFERRED GROUNOWATER CONTOUR
            SCALE IN FEET


FIGURE  7
LOWER AQUIFER
POTENTIOMETRIC SURFACE
MASON COUNTY LANDFILL Rl/FS

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Water  fron the  upper aquifer  percolates downward  to  recharge the  lower
aquifer.    Downward  percolation  is  controlled  by  the  thickness  and
permeability of  the intervening till units and clay/silt seams.  There may
be  areas where  the  intervening layers are  missing, which would allow a
larger  quantity  of  water  to  percolate  downward to  the  lower  aquifer.
Groundwater  in  the upper  aquifer  flows  generally  to the  northwest  and
discharges into the wetlands, Babbin Pond and Iris Creek (see Figure 6).

la  the lower aquifer both  confined and  unconfined  conditions exist.   The
potentiometric surface in the  lower aquifer is  higher than the till unit
along Inman Goad, indicating a confined  condition.   East and south  of  the-
landfill, a 20 to 40-foot thick: unsaturated zone of sand lies  between the
water  surface  in  the  lower  aquifer  and.  the  till unit,  indicating an
unconfined condition.

Groundwater flow in  the lower aquifer trends  toward  the  northwest  (see-
Figure 7) and eventually discharges to the Pere Marquette Lake and River and
Lake Michigan.    According  to well  logs  from local  brine  wells owned  and
operated by Dow Chemical, the  aquifer  is underlain by a massive till unit
(see Figure  4).   The exact thickness of the lower aquifer  at the Mason.
County Landfill Site is unknown.

Surface Water  - The  Site lies  within  the Pere  Marquette River watershed.
Surface water units near  the Site include a wetland  area at the base of the
landfill that  discharges  to  man-made Babbin Pond, which in turn discharges
to Iris Creek.   Since no upslope stream feeds the wetland area,  the wetland
area forms the headwaters of Iris Creek.

Iris Creek, flows for about  one  mile  through a  series of  small ponds  and
eventually discharges to the Pere Marquette  River just west of Highway 31
(see Figure 2).

A  24-inch  storm  drain  carrying surface runoff  from  the  landfill  cap
discharges directly into Iris Creek.   Other surface runoff from the  landfill
is channeled to the north through gullies that lie on the side slopes of the
landfill (see Figure 5).

The  wetland area is  a  local  discharge "area for groundwater that  covers
approximately  0.8 acre.   Babbin Pond covers  approximately 0.1  acre  and
contains about 200,000 gallons  of water.   The storm, drain flow is  probably
intercepted groundwater because 1) the drain discharged water during several
Site visits but  no  surface water was observed to be  entering through grated
inlets,  2)  the  drain pipe  is  buried below the water  table  based on a
comparison of the  manhole  invert  elevation to  groundwater elevations in
nearby  wells   fW7   and  MC8S    (See  Figure  5) and,  3)  the   chemical
characteristics  of  water in  the drain  are similar  to those in  nearby
monitoring wells.

         b.  Groundwater/Surface Water Interaction

The   surface   waters   are   located   topographically  and   hydraulically
downgradient of  the  landfill.   Surface runoff  from the landfill  area  and

-------
groundwater from the upper aquifer discharge  to the wetland area.   Based on
the discharge from Babbin Pond, surface water in the wetland area appears to
be gaining about' 46 gpn from groundwater.   The contained, water  from Babbin
Pond and the 24-inch, storm drain feeds Iris Creek at a rate of about 48 gpm.
•Die flow volume of  16 gpn.  in Iris Creek  indicates that surface water is
apparently lost to groundwater at a rate of about 32 gpm.   One surface water
measurements  indicate  that Iris Creek may be  a flow-through, creek (i.e.,
both gaining and losing water).

      2.  Chemical Characteristics

The  following  discussion briefly summarizes  the nature  and  extent  of
contamination  according  to  the  respective media  sampled  during  the  two
phases of  the RE.   Table 2  indicates  the contaminants  found throughout all
media at the Mason County Landfill.

         a.  Groundwater

The upper aquifer - Thirteen monitoring wells and four residential wells are
screened in the upper  aquifer.  Fourteen volatile  organic  compounds (VOCs)
and. ten  semi-volatile  organic compounds (SVOCs)  were detected in the five
downgradient monitoring wells within 400 feet of the landfill.

In general, the target compound, list  (TCL) or  priority pollutant compounds
that  can  be  attributed to  the landfill  were  predominantly VDCs.    Six:
chlorinated, volatile hydrocarbons were detected in at least one phase of the
remedial  investigation at concentrations  ranging  from 1 to  59 ppb.   The
highest concentration  (59 ppb of  1,1-dichloroethene)  was detected  at M
-------
                                           Table  2  (Page l of 2)
                               CHEMICALS DETECTED AT THE MASON COUNTY LANDFILL
                                         Groundvater
         Chemical

VOLATILE ORCAKIC COMPOPNPS

Acetone
Benzene
2-Butaaone
Carbon Dliulfide
Carbon Tetrachlorlde
Chlorobenzene
Ch 1 or oe thane
Chloroform
Chlorome thane
2-Chloroethyl vinyl ether
1,1-Olchloroeehane
1, 2-Dichloroe thane
1,1-Dlchloroethene
1,2-Dtchloroethene
1 , 2-Dtcnl oropropane
Tr*n«-l,2-Dichloroethene
Ethylbenzene
2-Hexanone
A-Mecftyl-2-Pentanone
Keehylene Chloride
Scyrene
Tetracnloroethene
1,1,2,2-Tetrachloroethane
1,2, &-Tr ichl orobenzene
Toluene
1,1,1-Trichloroethene
Trichloroechene
Vinyl Chloride
Xylenes
BASE/NEQTRAL
                                 Monitoring
                                    Wells
X
X
X
X
X
X
X

X
X
X
X
X

X

X
            Residential
               Wells
            Surface
             Water
         Sediment
X


X*
X*

X*
X*

X
                                X
                                X
X
X
                                             X
                                             X
Cat
 X
 X
 X
 X
 X
 X
 X
 X
 X

 X
 X
 X

 X
 X
 X
 X
 X
                        X
                        X

                        X
                        X
                        X
                        X
                        X
Surface
  Soil
Polycycltc Aromatic Hydrocarbons

Acenaphchene
Acenaphchylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b) f luoranthene
Benzo(k)fluoranthene
Bis-(2>Oiloroisopropyl)ether
2-O> loronaphtha 1 ene
fc-Chlorophenyl*phenylether
Chrysene
Oibenzofuran
Fluoranthene
Fluor ene
2*Methyl Naphthalene
Naphthalene
Phenanthrene
Pyrene
N-Nitrosodiphenylaaine
l,2,fc-Trichlorobenrene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
                                             X
                                             X
                                             X
                                              X
                                              X
                                              X
                                              X
                                              X
                                              X
    X
    X
    X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X
                                                 X

-------
                                           Table  2  (Pig* 2 of 2)
                                         Grouxtdwater
         Chemical

Phthalatei

Bia(2-ethylhexyl)phthalate
Di-n-butyl phchalate
Dl-n-oeeyl phtfaalate
Diethyi phthalace
Dimethyl phthalace

AGIOS

Benzole Acid
4-CMoro-3-Hethyiphenol
2-Methylphenol
4-Hethylphenol
2,4-Dlmethylphenol
Phenol

PESTiaPE/PCBa

4,4'-DDE
4,4«-DD0
4,4'-DOT
Endosulfaa Sulfate

INORGANICS

AluBima
Anciaony
Arsenic
Barium
Berylllua
Boron
Cadmium
Calcium
Chroniua
Cobalt
Copper
Iron
Lead
Lithiua
Magnesium
Manganese
Mercury
Kolybdenuo
Nickel
Potassium
Selenium
Silver
Sodium
Strontium
Thallium
Vanadium
Zinc
Cyanide
Monitoring
   Uells
     X
     X
     X
     X

     X
     X
     X
Residential
   Wells
Surface
 Water
     X
     X
     X

     X
     X
     X
     X
     X
     X
     X

     X
     X

     X
     X
     X
     X*
     X

     X
     X
     X

     J-
     X
     X
     X
     X
     X
     X

     s-
     X
     X
     X

     X
     X
Sediment
                                                  X
                                                  X
Caa
Surface
  Soil
                    X


                    X
   X
   X
   X
   X
   X

   X
   X
   X
   X
   X
   X
   X

   X
   X
   X

   X
   X
   X
   X
   X

   X
   X
   X
                                                  X
                                                  X
                                                  X
    X
    X
    X
    X
    X

    X
    X
    X
    X
    X
    X
    X

    X
    X
    X
    X
                                  X
                                  X
                                  X
                                                                       X
                                                                       X
                                                      X
                                                      X
           X
           X
           X

           X
           X
           X
           X
           X
           X
           X

           X
           X
           X

           X
           X
                         X
                         X
                         X
 'Found  in one  residential well  (Phase I); well was replaced.
CLX791/43

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                                              Table 3
                            SUMMARY OF UPPER AQUIFER INORGANIC CONSTITUENTS



CLP
Range of
Observed •
Detection Background
Liait Concentrations
Constituent
Alualnua
Arsenic
Barium
Boron
Cadaiua
Calcium
Chroniua
Copper
Iron
Lead
Lithiua
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodiua
Thallium
Vanadium
Zinc
(ug/1)
200
10
200
80
5
5,000
10
25
100
5
10
5,000
15
0.2
40
5,000
10
5,000
10
50
20
(ug/1)
150-310
151*
13-28
[401 5
5.3
45,000-115,000
4*6 b
[»Y
[501°
14-38
(5J
19,000-47,000
4-44
[0.11°
[201*
91f
[SI*
3,800-4,500
[SI*
3.4-4.4
64-10,000
Range of
Observed
Downgradient
Concentrations
(ug/1)
120-1,100
10-16
4-450
82-170
0.5-6.4
24,000-220,000
4-19
8-97
320-21,000
5-260
12
8,500-250,000
4-2,320
0.2
15-23
690 - 62,000
27
1,300-840,000
1.8-2.2
3.4-9.8
45-18,000
Frequency of Downgradient Detections

Total Number
of
Detections
6
4
17
2
5
25
7
10
8
5
1
25
15
1
2
17
1
17
2
5
21

Number of Detections
an Order of Magnitude
Above Background
0
0
2
0
0
0
0
0
7
1
0
0
10
0
0
3
0
12
0
0
0
?Based on monitoring veils OWB, OWC and MC1S
"Element not detected in background; use 1/2 of detection limit  for
 order-of-magnitude comparison.
C8ased on monitoring wells OWA1, MW1A, MW3, MH4, and MW7; S. Dains's
 abandoned well; residential wells RW04, RW05.RW07,  RW08, and RW10; and
.Phase II monitoring wells MC3S, MC4S, MC5S, and MC8S.
^otal possible number of detections Is the total number of dovngradient
 samples taken in both phases (equal to 25).
 Mean value of background samples used for order-of-magnitude comparison.
  CLI717/80-1

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                                            Table  4

                        SUMMARY OF LOWER AQUIFER INORCAKIC CONSTITUENTS




Constituent
Aluminum
Arsenic
Barium
Boron
Cadmium
Calcium
Chroaiua
Cobalt
Copper
Iron
Lead
Lithiua
Magnesium
Manganese
Nickel
Potassium
Sodiua
Strontium
Zinc

CLP
Detection
Limit
(ug/1)
200
10
200
80
5
5,000
10
6
25
100
5
10
5,000
15
40
5,000
5,000
10
20
Range of
Observed
Background
Concentrations
(ug/1)
110-160
[5P
11-1,200
(40)
0.6-0.8
65,000-762,000
3-76
[318
6-28
500
3-28
10
23,000-33,000
1-22
120}*
13,000-180,000
2,700-59,000
79-84
110-6,300
Range of
Observed
Dovngradient
Concentrations
(u«/l)
...
18-2.9
10-54
54-160
0.3
25,000-103,000

7
7-21
500-3,900
2
12-13
10,000-58,000
19-390
...
560-9,300
9,500-100,000
110-120
12-370
Frequency of Dovngradient Detections

Total Number
of
Detections
0
2
6
3
1
11
0
1
7
3
1
3
11
7
0
6
5
3
8

Number of Detections
an Order of Magnitude
Above Background
0
0
0
0
0
0
0
0
0
0
0
0 .
0
2
0
0
0
0
0
'Based on monitoring wells OWD,  MW6,  MC2D,  and MC7D and  residential
.wells RW01, RW02, and RW03.
"Element not detected in background;  use 1/2 of detection limit for
.order-of-magnitude comparison.
cBased on monitoring wells MC3D, MC4D,  and  MCSD and residential
.wells RW06, RW09, RW10, RW11, and RW12.
 Total possible number of detections  is the total number of downgradient
 samples taken In both phases (equal  to 11).
"Mean value of background samples used  for  order-of-magnitude comparison.
CLX717/80-2

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                                                        TO PERE-MARQUETTE
                                                        RIVER
         WETLAND
         AMCA- HEADWATERS
         OMNISCAEEK
LEGEND
GROUND CONTOUR

PHASE I SURFACE WATER AND
SEDIMENT SAMPLING LOCATION

PHASE I AND PHASE II SURFACE
WATER AND SEDIMENT SAMPLING
LOCATION

PHASE II ONLY SURFACE WATER
AND SEDIMENT SAMPLING LOCATION

STREAM

STRUCTURE

APPROXIMATE LANDFILL BOUNDARY
                                                                             SCALE IN FEET
                                                               FIGURE 9 |
                                                               SURFACE WATER AND
                                                               SEDIMENT SAMPLING LOCATIONS
                                                               MASON COUNTY LANDFILL Rl/FS

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Hie lower aquifer - Seven monitoring wells and seven residential wells  are
screened in the lower aquifer in Phase I, no TCL organic contaminants were
detected in the three- residential wells and therefore these wells were  not
sampled  in Phase II.   During  Phase I,  five VDCs  and three  SWDCs were
detected in RWD6.  The  State of Michigan replaced FW06 (screened at about
130 feet below ground surface) with a. new well screened at about 365 feet,
and. no TCL organic  contaminants were detected in that new well during Phase
II.  FW10 was also replaced between Phase I and Phase II.  lhat well  and  all
other residential wells screened in the  lower  aquifer die not contain  TCL.
organic contaminants.

Trace  concentrations  of  five VDCS  were  detected in two  of  the three
monitoring wells located along Iiman Poad.   Benzene and tetrachloroethene-
were  detected  in MZ3D  and MC4D  at  concentrations  of 2  ppb- and  1 PFb,
respectively.    The other compounds detected in at least one of these wells
are   1,1-dichloroethane   (1  ppb),   1,2-dichloroethene   (2  ppb),   and
trichloroethene  (1  ppb)-  These  results suggest that Site-related  organic
contaminants are being transported into the lower aquifer.

Table  4  summarizes  the  inorganic ~ constituents   in  the   lower aquifer.
Manganese  was  detected  at  levels  one  order-of-magnitude  greater than
upgradient levels in MC4D and RW06  (Phase I).   This  is  consistent with
organic  data  indicating  that contaminants  are  migrating  to  the lower
aquifer.

         b.  Surface Water

As discussed above, surface runoff from the landfill and groundwater  flowing
beneath it discharge to the headwaters of Iris  Creek: about 500  feet north of
the landfill.   The largest number (eight)  of  TCL. organic contaminants  was
detected at  SW04 during Phase I  (see  Figure  9 for  all surface water  and
sediment sampling locations.    Sample SW04 was collected  at  the discharge
point of the buried 24-inch storm drain.   In Phase  II,  only chloroethene (2
ppb), xylene  (4 ppb), and 1,1-dichloroethane (3 ppb) were detected  at that
location, indicating a reduction of total VDC concentration from 220 ppb to
9  ppb.   The  contaminants  at SW04 are  representative  of groundwater just
south of Iris Creek, near Babbin Pond based on observations that indicate  the "
24-inch drain pipe is buried below the water table.

NO TCL organic  contaminants were detected downstream, in Iris Creek with  the
exception of 2  ppb toluene at SW01, about 1,200 feet downstream from Babbin
Pond, during Phase I.  Trace concentrations of  chloroethane  (3  ppb) and 1,1-
dichloroethane  (3 ppb)  were  detected in Babbin Pond in Phase  II,  but" no
organic  compounds were  detected  in  Babbin Pond  in Phase  I.   Three  TCL.
organic  contaminants were  detected  in  the wetland, area during  Phase  I;
however, Phase II results did not show organic  contamination, in that  area.

The  number of TCL  inorganic constituents  and their  concentrations were
generally higher  in the wetland area and Babbin Pond than further  downstream
in Iris Creek or in Phase  I background  sample  SW07.   Samples taken from  the
wetland area and Babbin Pond during both phases contained arsenic (3 to 13

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                                        8

ppb); nickel  (19 ppb)  and chromium.  (4 to  13 ppb>)  at this location in Phase
I.  Elevated concentrations of  iron, manganese,  and potassium found at SW04
during both, phases support the hypothesis that the  24-inch  storm drain is
intercepting groundwater.

      3.  Sediment

Volatile organic compounds,  semi-volatile  organic compounds,  and pesticides
were  detected in the  sediments in  the wetland area,  Babbin Fond,  and an
upstream  location  (SD04)  in Iris  creek.    Toluene  was  found  in sediment
samples  throughout that  area.    NO  TCL. organics were detected  at  either
downstream, location, in Iris creek.

The only polycyclic aromatic hydrocarbons  (PAHs)  detected  in any  of  the
sediment samples were found  in  Phase I  at  SD07.   The pesticide 4"4'-EOE was
also detected  at that  location.  Based on the topography of  the Site area,
SD07  is  not  affected by  drainage from the landfill and these contaminants
are probably  from another source.   The FAHs may be products  of runoff fronn
Bradshaw  Poad  (asphalt  surface)  and the EDE  is  probably  indicative  of
pesticides used  in the orchards.

Concentrations of chromium, lead, and nickel were all relatively high in the
wetland area  compared to levels  detected  in downstream  samples.   However,
the background sample SD07  had similar concentrations of these inorganics
constituents.   Arsenic was detected  in four Phase II samples,  but those data
are   questionable  because  of   a  problemi   encountered  with  laboratory
procedures.

      4.  Surface Soil

Surface  soil  samples were  taken only during Phase  II.   Few  TCL volatile
organic  compounds were  detected in surface  soils.  Toluene contamination
appears  to  be most widespread, but  that  might  not be attributable  to  the
landfill, as evidenced by background levels.  EETT was detected in the slopes
north of  the  landfill.    Tne  presence  of  DDT  and.  other  pesticides  at
background locations indicates  that  pesticides were used for  agriculture in
the area.  Sample SS17  (gully No.  3) was the only sample to contain PAHs as
well  as  a wide variety of other  semi-volatile organic  compounds.   Refer to
Figure 10 for all surface soil locations.

According to the Site background results, inorganic contamination of on-site
soils cannot be  directly  attributed  to  landfill  activities.   Arsenic, lead,
and cyanide  were detected sporadically throughout each group of samples.
Sample SS13 in gully NO. 3 contained 890  ppn  of lead.   However, the median
value of  lead in gully No. 3 was  2.7 ppm, and all  other samples  from this
slope were one to  two orders-of-magnitude less.  The  landfill cap has  the
most consistent  levels of arsenic  (4.2 to  8.9 ppm)--  These samples were all
taken  from  the  clay cap,  indicating  that  the  imported  clay  may  have
naturally occurring levels of arsenic in this range.   Cyanide was detected
in very  low concentrations  in all three gullies,  and the highest detection
occurred in the orchard east of the  landfill (5.8 ppm).

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'..  N&$^
'<'
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                                        9

      5.  Ambient Air And Gas Vent Emissions

The  ambient  air  results   indicate  that   only  trace  concentrations  of
relatively few  organic contaminants were present  along the north, and west
edge of the landfill.  These contaminants were present in the bacJcground  (up
wind) sample and cannot be attributed to the  Site.   Carbon molecular sieve
ambient air samples were taken at each location in Phase II and analyzed  for
vinyl chlorides.   Nb vinyl chloride was detected  in. ambient air samples on
or near the Site.

A  wide variety of  TCL organic  compounds  were detected in  the gas vent
emissions.  Trends in the data  between  Phases  I and II cannot accurately be
stated because  of the problems  during laboratory analysis.   In general,  the
variety  and concentrations  of  organic compounds were  smaller along  the
south-west edge of the Site (GV01, GV02, and  GV03)  and the north-east edge
of the Site  (GV09  and GV10)  where the landfill is  shallow.  Refer to Figure
11  for   all gas  vent  and  ambient  air  sampling  locations.     Higher
concentrations  occur in areas of  deeper  fill; however, there  are  elevated
concentrations  in   GV12,  GV13,  and  GV15.    This  may  indicate that  the
reported  sludge pits  were placed in these  areas  or that gas  is  migrating
southeastward from areas of deeper fill.

Organic compounds detected in both gas vent emissions and groundwater of  the
upper aquifer include benzene, ethylbenzene, tetrachloroethene, toluene,  and
xylene.  Vinyl chloride was detected at  106,000 ppb in GV06 in Phase I.   The-
highest concentration  in Phase II was 2,900 ppb in GV12.

   E'.  Summary of Site Characteristics

The TCL  organic and  inorganic  constituents  detected during both phases of
remedial  investigation  are  summarized  in Table 2.    Monitoring  wells,
residential wells, surface water,  sediment, ambient air, and  landfill  gas
vent emissions  were  sampled  during both phases;  surface soil was  sampled
only during  Phase  II.  The  following generalizations can be made based on
the chemical analyses:

     *    A. contaminant plume extends  north and northwest of the
          landfill,  and monitoring well chemical data  indicate
          little change in type  or amount of contamination from
          Phase  I  to Phase  II.   The contaminant plume appears to
          extend from the landfill to Inman Road.

     *    Residential  wells contained  a variety  of contaminants  in
          Phase  I, and the  State of Michigan has since  replaced  two
          wells.   Phase  II data suggest that none  of the  existing
          residential  wells   in  the  area  contain   Site-related
          contaminants; however,  the aquifers  where  the two wells  were
          abandoned could still be contaminated.

     *    Surface water and sediment contain low levels of Site-related
          contaminants, especially  inorganic and semi-volatile organic
          constituents that tend to accumulate.  Contamination of these

-------
                               LANDFILL
                                  cvi* .-—.•'
^  
-------
                                       10

          media is  limited to the headwaters of Iris Creek  and Babbin
          Pond.

     *    Surface soil  chemical data do not clearly indicate areas  of
          landfill   attributable   contamination,  because   background
          samples contained a  variety of volatile organic  compounds,
          pesticides, and inorganic contaminants.

     *    Landfill gas  vent emissions contain chlorinated hydrocarbons
          and  benzene,  ethylbenzene,  xylene,  and  toluene.     These
          compounds  may be  indicative  of the industrial sludges and
          liquids reportedly disposed of on-site because they were also
          detected at low concentrations in the contaminant plume north
          of the Site.

     *    Off-site   air quality  is  not affected by  the  landfill
          according to off-site ambient air sampling.
    F.  CFRCTA Enforcement

Notice  letters  informing potentially  responsible parties  (PRPs)  of  their
potential liabilities and offering them the opportunity to perform the RI/FS
were mailed via certified mail  in August of 1985 to six PRPs, including the
Site's owners, operators and waste generators.   Qi September 6,  1985,  the
U.S. EPA decided  to use Federal funds to conduct the RI/FS due to the PRPs
refusal to participate.   Ine U.S. EPA. contracted with.  CH2M Hill to conduct
the  RI/FS  under  contract number  68-01-7251, work  assignment number  006-
5LE3.0.

Negotiations for  the remedial design/remedial action (RD/RA) with the PRPs
are  presently  proceeding according to  the U.S.  EFA general guidances  and
policies.

III.  GGFMJNnY RELATIONS

A RI/FS public meeting was  held on November 13, 1986  to inform,  the  local
residents of the  Superfund process and the work to be conducted  under  the
RI.  No major issues were raised by the community at this meeting.

An information repository has been established at the Ludington Library, at
217  E.  Ludington in  Ludington, Michigan.    According  to Section  (k)(l) of
CERCIA,  the Administrative  Record is available  to  the  public  at  the
Ludington Library.

The  draft FS  and the Proposed  Plan were available for public conment from
August 8, 1988 to August  31,  1988.  A public meeting was held on August 17,
1988 to present the  proposed plan and FS.   Comments received during that
public  comment  period  and the U.S.  EPA's responses are  included in  the
attached Responsiveness Summary.  The provisions of Sections  113(k) (2){i-v)
and 117 of CERCIA have been satisfied.

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                                       11

IV.  SUUH£ OF THE. FS\SJHiiJTY
The exposure pathways and associated risks front hazardous  substances  at the
Site  are addressed in.  the  Site risk  assessment  in the RI Report and are
summarized in the FS Report and in this  Record of Decision Summary.   en the
basis of the exposure pathways  and risks identified by the risk assessment,
two operable units  or pathways  were selected at the Mason County Landfill
Site: 1) landfill contents,  and 2)  groundwater.

     The landfill contents  operable unit addresses all materials  contained
     beneath  the  existing  Site  cap,   such  as  general  refuse,  sludges,
     possible buried drums and the underlying soil contaminated by  leaching.
     The landfill contents operable unit also addresses gas generated by the
     decomposing buried waste.   The general  remedial  action goals for the
     landfill contents  operable unit  are to prevent  direct contact  with
     contaminant sources and to minimize future release of  contaminants.

     The groundwater operable unit addresses  the  shallow and  deep  aquifers.
     •Die general remedial action goals  for the groundwater  operable unit are
     to  minimize migration of  contaminants   in groundwater and to prevent
     exposure to contaminants in residential  wells.

Surface  water,  sediment, and  surface soil  are not  addressed as separate
operable  units.    Although,  potential  risks  to  public   health  and  the
environment were identified for those media,  based on conservative exposure
estimates , the estimated risks are not sufficiently high to warrant remedial
action.  Contamination  of surface water and  sediments  is  mainly the  result
of the discharge of contaminated groundwater  to the wetlands area and Babbin
Pond.  Contaminant concentrations in those areas would be reduced if actions
were taken to minimize the leaching of contaminants to the  groundwater or to
prevent migration of contaminated  groundwater to these areas.   These  issues
are addressed by the landfill contents and groundwater operable units.

Based on the  information developed on the Mason County Landfill Site,  U.S.
EPA. believes  that the  best approach to this Site is  to  separate the two
operable  units,  landfill  contents  and  groundwater,  into   two  separate
remedial actions.   This approach  is cost effective  and consistent  with a
permanent remedy.                -        :

The alternative chosen by the U. S. EPA. in this Record, of Decision  primarily
addresses the landfill contents operable unit and defers the decision on the
groundwater operable unit until more information is available.

The alternative  chosen  in this  RCD  is considered an interim  remedy  and is
consistent with  the eventual final remedial action for this Site.  Based on
available information,  the  U.S. EPA. believes that  the selected alternative
for the  landfill contents operable unit will meet  the previously  mentioned
general remedial action goals for  the  landfill contents operable unit.   The
selected alternative is cost  effective as it may  greatly  reduce the  extent
of future groundwater  remediation.  The specific  components  and evaluation
criteria of the chosen interim) remedial alternative  are detailed later in
this document.

-------
                                       12.
Another  Proposed Plan  and PCD  will be  issued at  the  conclusion of  the
groundwater operable  unit to  announce  and select a final remedy for  this
Site.  Currently there is not enough data to select an appropriate remedy to
address the groundwater contamination.   ffore data is needed to  define the
extent  of contamination,  evaluate the  effectiveness of  an upgraded  cap,
track the concentration of contaminants  in groundwater over time,  further
define  the  relationships  between  the  identified  aquifers  and  further
investigate the relationship  between  the shallow aquifer and the  surface
water bodies  near  the Site.    Further  groundwater  monitoring along  with
surface water,  sediment and gas  vent sampling will be conducted to evaluate
the requirements for the groundwater operable unit, and the effectiveness of
the chosen alternative for the landfill contents operable unit.

V.  STIE RISK ASSESSMENT SOWRRT

Within the RI,  a Risk Assessment chapter details a baseline risk assessment
that addresses  the potential threats to public health and the environment
from the Site associated with the no action alternative.

The potential  exposure pathways, the means  by  which contaminants may  move
fromi sources to receptors  under both current and  potential future land use
conditions, were identified in the exposure assessment.  After evaluation of
Site conditions, the  following pathways were identified as having potential
to be completed under the no  action alternative and were addressed in the
risk assessment:

     *    The  release of contaminants  from, the landfill to the
          groundwater, the migration of these contaminants to the
          residential  wells   downgradient   from  the  Site,  and
          subsequent human exposure through groundwater use.

     *    The trespass  of people onto the  Site where they might cone
          into  direct contact  with contaminants present on the ground
          surface.

     *    The  release of contaminants fron  the landfill gas vents  to
          the air where they could be inhaled by Site trespassers.


     *    The release of  contaminants  by groundwater  discharge to the
          wetlands, where  people or wildlife could come  into  contact
          with them.

     *    The  future  development  of  the   Site resulting  in  direct
          contact with contaminants unearthed during  excavation  work.

     *    The  future  installation of residential  wells on-site  or  in
          areas  adjacent  to  the  Site,   resulting  in  exposure  to
          contaminants in the groundwater.

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                                       13

The  following  exposure pathways  were  not  considered to  be  significant
because of prevailing Site conditions:

     *    Exposure  of  people  through  fish,  consunption.     Few
          contaminants  were  found in  upstream locations  (Babbin
          Pond). Iris  Creek is not  deep enough to support  large
          fish.   There is  no  evidence that contaminants  have
          migrated from the Site to the Pare Marquette River.

     *    Exposure  of  off-site  residents   through  inhalation   of
          contaminants  released from  the  landfill  gas  vents.    The
          contaminants  will  be substantially   diluted by mixing with
          air.

Potential hazards  to  human  health,  front the  Site were evaluated  for both.
carcinogenic and noncarcinogenic risks,   concentrations of contaminants in
groundwater were  also  cotpared to drinking  water standards  and criteria.
Human health, risks for the Site are summarized in Table 5.

Table 5 indicates the contaminants  of concern at this Site for each exposure
pathway.   In  summarizing the  exposure assessment,  Table 5 mentions  the
estimated potential  carcinogenic and  noncarcinogenic risks  at  this  Site.
More detailed explanations  and rationales involving methods to determine
risk at  the Site are  located within, the RI Report.    Risks associated with.
background (areas not believed  to be influenced by the landfill)  levels are
not addressed.   Potential environmental  concerns associated with  the Site
are  only  addressed  in  a  general qualitative  method  since  no  formal
evaluation of the plant and animal communities  on-site  or  in  surrounding
areas were determined to be necessary during the RI.

The RI  report further  details the baseline assessment for the site and the
baseline summary indicates the following areas of concern:

     *    The  use  of groundwater from wells  located between the
          landfill and Inman Road  may result in adverse health
          effects.   This  concern  comes  from the  detection of
          carcinogens   in  monitoring   wells   at concentrations
          greater than those associated" with a  1 x  10~7 excess
          lifetime cancer risk, the  presence  of noncarcinogens at
          levels higher than those needed to exceed, reference dose
          values, and the presence of two chemicals at levels  that
          exceed MZLs.

     *    The  ingest ion of lead found  in one  surface  soil  sample would
          exceed  the   reference  dose value.    However,  all   other
          detections of lead in soil were below a level of concern.

     *    The   release  of   vinyl  chloride   from gas vents to  the
          atmosphere  is a  concern  only under conservative  exposure
          conditions and only for individuals who come onto the Site.

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                                                                 TABLE   5  (Page  1   of  2)
                                                           Summary  of  Risk  Assessment
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 •* circlMf*«i ••!• 4cl*cli4 In wy
 I*ll6>nllll Mill.  till «MllM I*
 ConlMlntnt dolocllodi In Ittno II ll 4«o
 I* pall I* (ko r«pl*c«B«nt of l>o
 conlMlniltd mill bf lk« Sill* o(
 Hlcklgaii.

 Tolol biooii LKolla* Concor Rlik IMIMOI •
 JO-1*ft oiposur* to Itio kl«h*il dtl«cl*d
 concciilfilloni ol ill corclnoftnf IR ill
 •onlloilnf ••III.  t>po(uil Iflllnf onuatl
 Ikit onillo r**ld«nllil d««olop>cBl >lll
 occwf ond Inot dflnk|*f luppl* call* oilI
 k« ln«UII*d.  Tkll U uillkolf ktcout*
 Iktto li Illllo pitiiuro lor risldtntlil
 d*>*lof>Mi«t lo (k« iroi. Iko I end li to**4
 lor igrloilliiril mi. lod Iko prop*rlf li
 ov»rd bf • piAllc l«*ncy iHoion Coualf
 OKI.

 Tot• I brail lllolln Coocor Milk IIIUMI •
 TO-foor ••poinri I* Iki klfkoit d«locUd
 concentr«tlon( of ill eorclnoftoi lo ill
 MMllorlaf ••III.  bpoiuro lolllnf oiiuoci
 Ikol ooilU rilldMllll do«olop*oni olll
 •orar ind Ikit 4rl«kl»f lopplf ••III >lll
 bo loitillrd.  nil U uillltlr btriuii
 tkor* It lltllo proiwr* lor rotld*«tlol
 doiolopMit lo Iko or«o, Iko lond lo toned
 (or ogflcMUvrol 11*0, ood Iko pioporlf ll
 owned bf • pidtllc Ifonqr IH«*on Countr
 OMl.

 bpoouro br latoitlon or dlroct canlocl
 I lolled bf noil ill* of Motby population.
 tlooi Irlo Crook lo loo (hollo* lor ••lo»lnf
 •od •eciil U tobbU rood llollod lo
 Iroipooaori.   Huoon ovpoturo liooi Ingtillon
 •I contoaloolod Iquotlc orgonliai ll
 •ollktlf.

 Totol chioolMi coocontrot loo uoro lll»lr lo
 bo U tko Irltolont  for* Ikon koio»ol«nl
 (or* bocoui*  •( reduclnf noluro ft  ivrloro
 •ilir I* ill* ir*i.

 bpomro oolllnf li  roclrlcltd lo illo
 ir*tpoi(*ro U.f.i fclkori or ploflno;
dilldrtnl  ond II  o»uo*i  ln««tlon  of
O.I fiw/dor ol  «ol|  Inonrorclnogtnlc
 ollocltl  i«4 O.I  «>o«/dor lor  U  «»/ft  lor
 S |*oio  Irorclftoftnlc ollrclil.   Nl«h  l**d
co*r*nliollon  drlvclod ol o«lr  on*  i»»pll«9
point  *»r bo  irp(*i*nlol|»o ol  •  •••II,
 loccllird oiti of loll.  t>*ro«o  ontll*
ronconlrtllon* ol ronlooloonti »*ro b«lo»
«pp*r b»c»ffound cenrcoliollooi
 l**oo  •  1 ilondotd doTlollonil ompl for
•Ickol ond  lonodluo.

-------
                                                               TABLE  5
                                                          Summary  of
                                                  (Page   2  of  2)
                                                  Rfsk  Assessment
      e»pomro feint

 SrdUrai
    lipotuto rotkmf

ln««*tlow



Inhololloo
tipoood
                                                     Troipofiot*



                                                     Troopoiforo
            »Uk ClioTOC«orll«tlo»,

No »IO» oinodvd.

Totol Cftc*«« II lotto* Coocor »Uk • I • 10*'°

No RID* •»cndrd.

Toll I Bie»«i tlUIlM Cancer •!•» •

   S • lo"
                                                                                             I— cMiccr rl«k «u« Millr U >Url
                                                                                      chlocldtl
                                                                              I • IO"7 ln»*« II— cwc«r rlik *M
                                                                                                                    t* »Ufl
                                                     •ooldonU
                                                                           •Ul *ot
                                                                           ofltll* wOUnt «lc •Mp
                                                                          otur* Mltlnf I* Ik* *«M •• lot tur(«c»
                                                                       Mill.  .
                                                                                                    txpomtit ••Illnf !• r«ilflc(H le •!!•
                                                                                                    lc*«p*tt«r« l«.|.. fclttfi »r yltflM
                                                                                                    dtlldrcnl «n4 II ••*u**» l«k*Ulloii of
                                                                                                    -lool 4l»tonct fioo Iko «*nl.
                                                                                                    f«lo« eipomro ••Mint olollfr to lk*l lor
                                                                                                    • Ho Iroipoitoio, Iko ••• tonl coocvnlK-
                                                                                                    llono oovld bo 4ll«lonco.
CIT7*I/*|

-------
                                        14

VI.  DESQUPHQT CF REMEDIAL KL3SSSKTTJES

   A.  Screening of Alternatives

    . 1.  Screening Criteria and Goals

Screening:   Numerous  technologies and process  options were  evaluated for
applicability  at this Site.   These technologies  and process  options  were
screened  initially for the following to  determine if further consideration
was warranted:

         *  Inability to achieve remedial action goals.

         *  Failure to meet federal or state ARARs.

         *  Impracticable nature or difficulty of implementation given Site
            contaminants and physical conditions.

Figures 12 and 13  illustrate  the  initial  evaluation of the technologies and
process options for the landfill contents and groundwater operable units.

Goals:  The general remedial action goals for the landfill contents operable
unit are to prevent direct contact with contaminant sources and to minimize
future release of contaminants.  Specific remedial action goals are:

     1.    TD  prevent  direct  contact  with  landfill  sources  that  have
     contaminant  levels  exceeding target concentrations for  protection of
     public health from the effects of noncarcinogenic contaminants (based
     on reference doses), or excess lifetime cancer risk in the range of 1 x
     10~4 to 1 x 10~7.

     2.  To prevent contaminant migration from landfill sources to drinking
     water aquifers that would contaminate these aquifers to levels:

          *   Greater than maximum contaminant levels (MCLs) ;

          *   Exceeding the lifetime health advisories ;

          *   Exceeding reference doses for protection of public health fromi
              the effects of noncarcinogenic contaminants; or

          *   Resulting in an excess lifetime cancer risk of 1 x 10~4 to
              1 x 10~7.

     3.  To prevent contaminant migration from landfill sources to a surface
     water body  that  would result in contamination  levels  greater than the
     Ambient Water Quality Criteria.

     4.   To  control  future  releases  of  contaminants to  an extent  that
     ensures protection of human  health and the environment  (SARA Sec.  121
     (d))

-------
OPERABLE tMT
                                        GENERAL
                                    RESPONSE ACTION
                                                                     REMEDIAL TECHNOLOGY
                                                                                                            PROCESS OPTION
                                        No Action
                                       ConlOiivnMI
                                                                               None
                                                                                                          I   •	""  ~"  '" ' "I    AN da*d«  lo*  p'Oportv »4thtn pOt«n|ioJlp eon-
                                                                      I                     .       I      I   Loqol ««»tr.cl.oni   I    tom«ol*d or*a* »avM indwtfo kmilalio**
                                                                     •j ACC... Ra.incTioTr]	                       	    ~ — " "•""'

                                                                                                   I      [	f«nc*ig	j    ^XetnSiS* a* wwlr**^* l*"tfl* ****
                                                                         Surloct Conl'olt
                                                                                                                                    ••i«l«iQ landfill coniou«t t»
                                                                                                                    _           I    ••itltftg landfill
                                                                                                            •9totjmq/R«vdq*tolKX|    »ot«*  t«iew»f*
                                                                                                                     ---_         J       .___
                                                                                                                 Soil Co.»
                                                                             Copping
                                                                                                                                    Spray Opplnlh«l.c Mtm  [    •»»• »oii i«i«»i U pro^d* oraoion ond
                                                                                                                               |    Compact*d clay and •ynlhatlc mombrona bofflar
                                                                                                                  n.  Mam.-Qay I    ea««r*d win »«4 i«|««a la p/o«do araaidn
                                                                         ^ ^ ^ S S~ f S f~7TJ~f7J\
                                                                        yr&£fa'&)Mi	
'/^T'/^T77///"/7777)     Trancfi la a»coMH*d •"•• fll»d «ltn o Mnl(
Sorf-Btnl.  Slurry WoU^j     ••>*' •>»"»  francn ia kackfatad -Mh a oo*<
                                                                                                                                              peHwn ol dfrftcd
                                                                                                          fc'/ x"/1^ x-/^/- J'X^T-^/'J'-/./]    Con trotted in|ccIiOO ol Hwfrr in noiCl«d
                                                                                                  i 	   1^ BtQCti  OilpTOC*n-)«nl^j    ln^el»on  no*at  10 p'OouC* noritoniai OO«»*«
                                                                     K^jH'K¥?'/}yyft       I       ^'^'^'/^V^y^    **n*olh ln< cortlomtnwftit
                                                                                                                                                                                  SH« tftll mo** a nong.ng -O»
                                                                       in*ff«ci<«o
                                                                       OitcontMwOwi coaming top*ft lo k*r ^'O. ontf
                                                                       •Irong wdicot yroo**nl» mo^* a n anting mtttt



                                                                       OifliCwll 10 O«l*«ntin* >n|*gfil|r ol DO'"*'  Not

                                                                       • KOl'f oo*ic  wntlt  b«n*alh londli»

                                                                       O'lliCwtl la dalvrmtn* ini*grt|r of DO">«>  rtoi
                                                                       *M*«I.<* b*COw»* Ot in* 00(*"C* Df (Onl-»«0u»
                                                                                                                                                                                    FIGURE  11 (PAGE 1 OF  31
                                                                                                                                                                                    APPLICABLE  REMEDIAL
                                                                                                                                                                                    TECHNOLOGIES
                                                                                                                                                                                    AND PROCESS  OPTIONS
                                                                                                                                                                                    FOR THE  LANDFILL CONTENTS

-------
3PERA8LE UWT
                                          GENERAL
                                     RESPONSE ACTION
                                                                        REUEDUI. TEOKXOQY
                                                                                                                 PROCESS OFTON
                                                                                                                                                   peacnrnon
     lonOI.ll
  (Conl.nuro)
                                           Remove!
                                          Trtolmtnl  :
                                                                                                                   	"            i  ConfUuClion
                                                                                                                MechontCOt CicovotiOrtl  OYOO«»* cron*
                                                                                                                                                                 •• a bochho* o*
                                                                            in  S-iu  lr«oim»MV3
                                                                             Y ^ f t ts s f ' t J Sfl
                                                                                                              ^
                                So* M
                                •••« k

                                U»« of planl on* animal
                                                                                                                                                                                            iftotmont  only Adflod itvl'ionit
                                                                                                               PV'/yJy't"f/yjjfffff\  **** °' D4°nl  °"* onimol *O*CM*  lo occwmwldt*     Not JOfi'Tttt'i to *N l|p*t *f conlofninont*

                                                                                                               Y**-*	'-'-'!_•' -'S^^A  hofw*tl*d ond «i*poMd of                       not occumuiai*.
                                                                                                                                                                                     MM Of>pl*COM« I* OH l)p«l ol coniominonlt
i      ryCftcfntCOt A«dCtions/J  owcn ot oton*. hydrogen pcromid*. v p*rm«n*      itttmat 7o*'oroundJo^*rn^Id«*r*aCl|t»na*mo^
      Y««f«ftStt«f{\  fonol* lor d*0*od*l.on «l oiaonict                oroouc* olW fM>l.dou. •ybfto'K**.

                                                                             Soi»onl m*r boeom* * arouA«**tor eoniom-
                                                                              tonl. Not OpptiCOM* lo ON  (>•«• Of contom*
                                                                              •nil lownd on Ml*
                                                                             Sftotio* p*n*ir«lton •*0|ft   M*t ood>coiM* I*
                                                                             l|p*t of  coniominonis town* onfl*.
                                                                                                               ^%
                                Aoplkollon ol tol«*nl *im*r «i* »wrloc* Koodin|
                                or injoellon. Cotiocllon of ••iroci ot
                                •out fon*.»*d  »r uvoimoni.
                                            lion of 104 cOAlon^nontt •«« »o«or
                                       On« in* oppMOlkM •! toiv«A1«
                                                                                                              fvyXSoil  AefOlior
                                                                                                              ^yV>x.-/y^>-yy^
                                    oU m^cfobitf b«OO«orMMl*on an* U •!«<>
                                    do offoriict ffom toil.
                                So* miH*d «llh *Ofb«rtl meU'MV «nicn con
                                conc*nlr«|* *nd Iw conlontMonlt.
—^jy°f5/ff°fftf^fl oo^*SoSihv?iFif««Tisc.!is;
                                 ontomlnoi.d mot.M It  luMd mio O>o»r ttoW*    ^"\^Tl^v^m^^^l^^^\\^"£*"
                                 lOKfi br liMlInt N to ploc* "•"» on otoclri*       m«lo) MoporiioM ol londlli coniorAt twga*ilt
                                 -•'onI                                        ^o»*Alf for  fir* ond tftorl tkcwlno^ r«tp*cit*««r
                                                                                                                                                                                     Not OPBKCOO4* lo Oil  lyplt Ol  ConlomMgnit
                                                                                                                                                                                     on».i* 0*t* n«l ch*mic«Hr tfnmobibl*
                                                                                                                                                                                     Contomlnonli.

                                                                                                                                                                                     Not oopikooi* lo on  IM»«* of  cenlomM«ni»
                                                                                                                                                                                     on*tl* Of  *rwmm*d •*•!*.  rf p«*»*n|.
                                                                                                                                                                                     Not oppjicobl* ID th* l*ndl« conlonl* btcout*
                                                                                                              K^f//.^ f-'-.'m.ZZ. 'S/l  SlohWiollon of conl«min«t*« malwM bv iAi»l
                                                                                                              l/x! .*?C|!°?J —yjyyyfl  f**< •"<• IM V*"* l»*ouon  »o« po-^U
                                                                                                                                    i~* Orfonic motoriol* olocod U controMvd on«won-
                                                                                                                                       mon» with *«*iUon of nuUlMll ond •*• I* <
                                                                                                                                       micro
                                                                                                                                       nucrobW d*oyod«tion  of orfOAkt.
                                                                                             Ih* I
                                                                              Of ion*f» conionl*.
                                                                                                                                                                                         FIGURE IX  (PAGE 2  OF 31
                                                                                                                                                                                         APPLICABLE  REMEDIAL
                                                                                                                                                                                         TECHNOLOGIES
                                                                                                                                                                                         AND PROCESS OPTIONS
                                                                                                                                                                                         FOR THE LANDFILL CONTENTS

-------
OPERABLE uurr























LOrtdliil Contdftl* I ii i. 	
(Combed)











GENERAL
RESPONSE ACTION
















1 	 1 *• 	 1 	

















- Qispoioi | ii • 	

REMEDIAL TECM40LOQY























I Thd'mol 0«s true lion 1


.




,?„,., 1

1 	 1


PROCESS OPTION DESCRIPTION
1
^"*" "T>yyyyPa'dP*'9nv'yyyyl PO'mongonoit mlroOuCta into O contactor Wi««t

•••JX/Soivtnt C»UoclK>o^j mwot •«!!» tondr C'iroci it COMOCIOO ond
___T pftt*ftt^-OD'« SorbonlsXJ conlomMtonl* art mi,»d .i|h Mil Utt ol mognttic
rt«no«at.



— W»fi&;f&fff%\ ssssji «•£&; '""" ""- •*•

Mhermpl ValoliliialionH VOC .wolnngluin « a iw «r"9 »"•>
t/^/xf7>y^yyyy^»^

	 ^^^duclien^^j Ij^'sS", i.rlSSI'.'^n'S^.liHrti

•«— ^™J FUolion | comonl. motion fl«»t. or voriowl aroprMlo/jr proawct

•i ••— 1 P>roty»it 1 dlmotpnoro lo prodwco oior ro»idu« ond ««4oU* org«
1 floior KMn 1 So»id» and Uauid* or* ltd inlo • nwUafflOr routing
Xol'do d ttau'do o fod bilo h1 n


— f uuiiipi. H.O/II. | ^jr/^SwV^n'i.i'.'.'i^vEr^,

, Fluidutd B«d | ., ^a ^^. hfal |rontlvr ^tf C0rnb3;lion ^e^,

TV^///^^?///^! lor inc-»*rol-»g* .o.i.t " *" '
' • j '""'Oreo voiol»tol>on J ^Jon^i'T,-^ ^^c^^oVo'o'^to? '•c'onflMl0'

^^tiqu«O ^*^ yvyyvl tltom and Owrntd •» •u«p«ns>on.

	 	 RCRA Incindrolor 'i»t»mot dtiirwction o' coniom^aitd tw^t ond
^^•— J/'LiC*" g*0 Londlor Tiy/! 9>o4OQrco' otg>ooolc(o*orgonifni in

i I.WIIMI* oppro.td MCJtA-ot"niHtd lanoM
	 1 iw, i
               APPUCABUTY
 S'O* ««oeiion|  f*Qf proOwc* oin*f n«i«f«OMf
 •w»«ionc*i No! •«•>!•« tor lr*«im*nl «l •w
 * ooa »li«t ol m«i»rlo*r

 Noi opplicoeit  lo 0« l|*«» Ol  contorvirfionli
 lOwnd on»>l« Not •'OClical an o l«ra«  »#•
 Not twll** lor  Irvotmartl O* tO**« O» *•«
 Uttt  ol «fi«t*ria>t
 Not Op*(iCO»«t  10 1>p«* Ol ean«omMonl|
 (•wna OAMU Not •MHO*  lor trtotntonl  ol
 •*!*• or  odd »>t«t  ol mot*****

 NOI locnnico*|r p^oclicai  lor r*mafOi ••
 prqontcf lo»nd in »ltt lot or lonol^ C*ni*nit
 Nol tuiUd 10*   liooimoni »l ood •••••
 ol mol«/>oit
 A«plitil|r iMnllco lo !••  coniomrfionl l«ptl
 tnot mor «»' •••*' !** *or$t %*oni.lr on»iU

 Not i«cnn<«n> prociicot on  torgt tcot* lor
 Otlirwction of coniomMtont lyp«t lOwna ont.ic


 Applicability IwnlICO tO It*  COnlOm^onl <*>••
 tnoi mor A«* fill »n l«rg* •uantily OA»I!<

 AppltCOO^lr l*nil»d le !••  coniom^iQni Irpci
 inot rn«|r nol *•••! M targt Qwoni.tr ontiit


 r»oltntloitr ««ooit
     o* warp 'org* t*«ci'r 0'
conion«>no»il
  FIGURE  12.   (PAGE  3  OF 31
  APPLICABLE  REMEDIAL
  TECHNOLOGIES
  AND PROCESS OPTIONS
  FOR THE LANDFILL CONTENTS

-------
3PERABL£ UNfT
  Cro«>no*»ol«r
     GENERAL
RESPONSE ACTION
                                      No Ac)
                                            Conl'ol>
                                      Co»n
                                                                tCMEIXM. TEOHOLOQY
                                                                         Noo«
                                                                  UlxnoK ttolw
                                                                                                     PROCESS OPTION
                                                                                                                                  DESCRIPTION
                                                                                                                                                                          APPUCABUTY
                                    S*U ftMlUcliong   |             [
                                                                                                                         |l«go> >«it'icliont lot •>op«ilr
                                                                                                                         COA1o<**«U0 OiOQ* *Owt« nclu
                                                                                                     	           o* MM of propwly.
                                                                                                      Uonilpftnq Welil	| io»i»pi»fl ond !••)•«
                                                                                                  •fX/'MuniCipol Supply
                                                                                                                         OH«CII< -t'l.
                                                                                                                                                                                     Action AOI
                                                                                                                                                  10 ini*fc«pl
                                                                                                                         «A« c*««cl cool •mine! •« o/owndv«l«r.
                                                                            .......... *r»»om of infection ond ««lrocllon •>••» w««d lo

                                                                            _;   .1        iir|«nu I* f
                                                                                                                                      Mm*, or I*M oi
                                                                           [ Trool. 6«d«| lo fomovi


                                                                           Of RtOCllOn/^ VwCtt •« oton*. pcrmangaAOlc
                                                                                                                                                                             l*«np«f«lwr« !•• cold lo •wpporl
                                                                                                                                                                             th.
                                                                                                                                                                             conlom*to»on loo do^i for
                                                                                                                                                of np«oo,on
                                                                                                                                                                   (too looclionB m*jr pfo
                                                                                                                                                                  ln»wn
                       Co"1"
                                                                                                                                                                         FIGURE >i   IPAQE  1  OF  21
                                                                                                                                                                         APPLICABLE REMEDIAL
                                                                                                                                                                         TECHNOLOGIES AND PROCESS
                                                                                                                                                                         OPTIONS FOR  GROUNOWATER

-------
3PEHABLE UNIT
                                           GENERAL
                                      RESPONSE ACTION
BEMEDIAL TECHNOLOGY
                                           PROCESS OPTION
                                                                          DESCRIPTION
   (Continued)
                                           Irtatfntnl
                                                                                                                        o,.~ » I»I.M     I  *M»»OI«on Ol Cn*m • Quit*'4 lo r.
                                                                                                                        PfQCipilOliOft     |  iOI-tei,;i, Q| m( congl.tMtnl
                                                                                                                        A* Stripping     I poci>*d .
                                                                                                                      Slcom
                                            _                          I   »•• j   On i< I* 0«»c*>O'g«


                                            	'•	'          I	^6ll*iiff'6iscn»9c-;^
                                                                                                                     CfKDOn  AdtO'pliOO
                                                                         IO Oif *lr  »t«O« !• •»,
                                                                                                                           POTW
                                                                                                                       RCRA rocili
                                                                                                                         on  ol
                                                                                                                                           •Alp IA« COTBOn »t*IOC«
                                                                                                                                           Otti^iCol O«HIOI»OA  ol
                                                                                                                                           ut««9 on Q*>d,ting ogcnl SwCfi  ai p«ro«*O«.
                                                                                                                                           AtvocnM»"lt. cniorin* oat. or oion*. o>  HMWI
                                                                                                                                           l«m0«'*lMi« «na pf«t»w'« cpnalltan*

                                                                                                                                           UM ol h.fth pri»»u(* Ip lorct  Clcon wol
                                                                                                                                                              ••cnong* ol  ion*
                                                                                                                                                               In* *4lor.
fol«nitoH|r MODI* lor tonif


^ol«nlio»y wool* (O» O*fOr<<  c on I *m wort It.



*OI*nltoHy viabl* IO* orgomc  COniontMOAIl



Poi«niioi>r «OO'» t wtorgontc cor>tominoni>
                                                                                                                                                      or*  lron*l**r«d from IN*  wotor  iorg>*   cpniom««*nl* moy •• <*rn*d Oll*il*
                                                                                                                                                             or fvrrayi ammoniwm
                                                                                                                                           Thwmol •••IrwCliort  *l OffOAic conl
                                                                                                                                           w«Mf onjr on* *l mort^ roocior  IM»
                                                                                                                                                    OQw«Ou* •«•!«»
                                                                  I(0n*porl gtowittfvolor  lo •OlW lor
                                                                  lr*oimonl.

                                                                  Trontporl ojrow/id«olOi  IP HCH*-lic*oi**
                                                                  locHtly lot lr*olm«nl ond/or ditpotot

                                                                  fr**l  orowrtd*Ol*<  Ol point  ol w«* «iirt
                                                                  norn*  *on ••cnongt o*  cor Don oatorplion
                                                                  wfttl*
                                                 Iris  C'CCk      I  j,^ rf€*i,

                                                '**'»'in'-'rl.ftny^i  O.««io««o contpm-»oi«a  o/o-nd-oi*. lo
                                                                                                                                                                                           Not  appbCOMO lo l|Q«t Ol contomtnonit
                                                                                                                                    i cno/aci««»liC> ond
                                                                                                                               vi« «OI •upporl combuilion
                                                                                                                               or* loo 10* lo o« cono^oro
Pol*nl>oiiv vtobl*


0««D OOu>l«' •• mined i
                                                                                                                                                                                             FIGURE  '£   (PAGE  2  OF 21
                                                                                                                                                                                             APPLICABLE REMEDIAL
                                                                                                                                                                                             TECHNOLOGIES  AND  PROCESS
                                                                                                                                                                                             OPTIONS FOR  GROUNDWATER

-------
                                        15

     5.   1b permanently  and significantly  reduce toxicity,  mobility,  or
     volume  of hazardous substances (SARA Sec. 121  (b))

Hie general  remedial action goals for the  groundwater operable unit are to
minimize migration of contaminants in groundwater  and prevent exposures to
contaminants in residential wells.  Specific remedial action goals are:

     1.  To  prevent exposure of receptors to contaminated groundwater.


     2.   To prevent migration  of contaminants  fron  the shallow  and deep
     aquifers to off -site receptors that would result in exposure:

             *   Greater than the *£Ls;

             *   Exceeding the lifetime health advisories;

             *   Exceeding reference doses for protection of public health
                f ran the effects of noncarcinogenic contaminants ; or

             *   Exceeding a lifetime cancer risk of l x 10~4 to l x 10~7.

     3.  To  prevent  migration of contaminants from, the shallow aquifer to a
     surface: water body that would result in contamination  levels greater
     than the Ambient Water Quality Criteria.

The technologies  and  process options carried forward through the initial
screening were evaluated further based on effectiveness, implementation, and
cost.
          1.  LflTlflflll Contents Op?r?i?Te Unit

The  technologies and process options evaluated  for the  landfill  contents
operable unit and corresponding evaluation summaries are as follows:

               a.  Access Restrictions

Access restrictions are  intended to prevent  prolonged exposure  to or direct
contact with contaminants, to control future development and excavation,  and
to prevent  the installation of water supply wells.   These objectives would
be accomplished  by placing  legal restrictions  on  the property and enclosing
the  Site with  a fence.   Access  restrictions are an  effective method  of
limiting public  access,  but they  do  not reduce the  level of contamination
and are not protective of the environment.

A Site fence with locking gates and warning  signs can prevent access to  the
landfill by humans  and  some  animals.   Its  effectiveness  depends on future
maintenance.  This action can protect the integrity of the landfill  cover or
cap, and it helps  prevent direct contact  with  contaminants.   Fences  are
easily installed at low cost.

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                                       16

Legal  restrictions would  control the  future use  of  property,  and  their
effectiveness is dependent on continued implementation in the future.   Legal
restrictions  are  subject  to changes  in  political  jurisdictions,  legal
interpretation, and regulatory enforcement.   However,  if legal restrictions
are properly implemented, they provide  low cost protection  against  direct
contact with contaminants and prohibit installation of water supply wells.
Both legal  restrictions  and a Site fence at  the Mason County Landfill Site
would be  effective for protecting human health, easy  to implement, and low-
in cost.  It was not possible to screen one in favor of the other because of
their significantly different effects on  remedial action  at the Site,  so
both were carried forward for assembly into alternatives.

               b.  Containment

At the Mason County Landfill Site, containment would  be limited*to surface
controls and  capping.   Tnese technologies would be effective at minimizing
the potential threat  of direct contact  with surface contaminants.    Tney
would address the issue- of surface water management and could reduce surface
infiltration.   Some degree  of protection against surface  infiltration has
already been achieved by  the single layer clay cap installed in  1979 and
upgraded  in  1984-85.    However,  large settlements  have created areas  of
ponded water and cracks along the landfill perimeter.

Ine existing  clay cap can be incorporated  into the final design of  any of
the contaminant  technologies considered for  the Site.   Hie  options  range
from a  maintenance procedure  (regrading  and revegetation)  to  a multilayer
cap  with  two  low  permeability  barriers  that  are  protected  from  the
environment  by overlying  soil layers  (soil-synthetic  membrane-clay  cap).
The main  difference between the  technologies is the degree  of  protection
provided for the low- permeability layer.

Regrading   and  revegetation with a soil  cover  would  reduce  leachate
generation,  but, regrading and revegetation with a soil/clay cover would be
more  effective  at  reducing  surface infiltration.    Regular  mowing  and
periodic  inspection and  maintenance  would, be  required for  either option.
Maintenance would consist of  filling depressions  with  soil  and  reseeding.
Since  the  costs  for both  options would be  low and  both  could be  easily
implemented,  the  regrading  and  revegetation  option was  carried  forward
because it  would be more effective.

The capping options would be an improvement over regrading  and revegetation
because the low permeability barrier would be protected from environmental
conditions  that can create cracks.  Ine soil-clay cap and the soil-synthetic
membrane  cap  would have roughly  equivalent  performance,   and  the  soil-
synthetic membrane-clay  cap  would have the  best  performance.   Ihe technical
feasibility of each cap  does not  vary greatly;  routine maintenance would be
similar   and  each cap   would probably   require   replacement  because  of
settlement  cracking.    It  has  not  been  demonstrated  that the  risk  of
contaminant release to  the  groundwater  at  this  Site  warrants the  extra
protection  and concurrent high capital and replacement costs associated with
the  soil-synthetic membrane-clay  cap.    Ine  lack  of  clear advantages  or
disadvantages between  the other two  capping  options makes relative cost  a

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                                       17

valid screening criterion,   since clay is available within  10  miles of the
Site, the  soil clay cap  could be constructed at  less cost than the soil-
synthetic  membrane cap.   Therefore,  the soil-clay cap  was  retained  for
further evaluation.

Gases produced by decomposition  of the landfill  contents beneath  the  low
permeability barrier layer would  be vented to prevent  the cap from cracking
or 'gases  from migrating off-site through  the  subsurface.     Gases  are
currently  vented  to the  atmosphere without  treatment  through a system of
fifteen vents.   The risk to the public associated with gas vent emissions
was determined to be negligible outside the  Site  boundaries.   A. Site fence
could adequately  prevent the risk: of direct contact  with landfill gases
without the need  for an expensive gas collection  and  treatment system so a
gas venting system similar to the existing system in conjunction with a Site
fence has been considered with each containment option.

Figure 14  illustrates  the cap configurations that were carried forward for
assembly  into  alternatives  for  the  tfeson  County  Landfill  Site.    Hie
anticipated, frost depth was conservatively estimated to be 3 feet.

               c.   Removal

Under the  removal response  action,  contaminated wastes would  be excavated
and.  disposed  of  or  treated  to reduce the potential  risk  associated with
direct contact to contaminants and migration of contaminants to groundwater.
Landfill contents can be excavated using backhoes or clamshells.  Excavation
and handling operations would vary because of the  variety of wastes.  Waste
would be  segregated  into garbage, soil,  sludges, and. drums  (if  present)
because different waste  types  require different  handling, treatment,  and
disposal.    All excavated areas would, be  backfilled with clean soil to  a
level consistent with the rest of the Site.

There is considerable  risk of worker exposure to hazardous materials during
excavation, including  potential contact with hot  spots (i.e.,  areas where
sludges and  liquids were deposited)  or  druntned  liquids  and contact  with
airborne contaminants.   Dust  and surface water runoff must be controlled
during  excavation to avoid or  minimize potential  off-site  release  and
exposure.                         ,••-.:-

Excavation would be an effective  and reliable technology  for the removal of
contaminant  sources  at  the Mason County  Landfill  Site.    It  would  be
protective of human  health  and  the  environment  when combined with  such
response actions  as  treatment or disposal.    However,  it would be difficult
to implement and  have a high capital  cost because waste types  are probably
mixed and the location of sludges or drummed  liquids is not known.  There is
no operation  and  maintenance associated with  excavation.  Excavation  was
carried forward for further consideration.

               d.   Disposal

The  disposal   response action  involves  placing  and  permanently  storing
excavated  material  in   an   off-site  or  on-site  PCPA-approved  disposal

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W63353RF\FIG 4-1 5/18/88
       PASSIVE CAS VENT
  UNDERLYING SOIL
           REGRADE AND REVEGETATE
                (Single-Layer Cap!
                                                         PASSIVE GAS VENT
UNDERLYING SOIL
               SOIL-CLAY CAP
                                            NOT TO SCALE
                                                                                   FIGURE  H
                                                                                   CAP OPTIONS
                                                                                   MASON COUNTY I ANOFll I

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                                        18

facility.   A RCRA  facility  is  controlled,  monitored,  and regulated  to
minimize the  potential  for uncontrolled, releases  of contaminants.   Disposal
in  a RCRA. landfill  is an effective and reliable means of controlling  the
migration of  and exposure to contaminants.   Since RCRA prohibits the direct
landfilling of containerized and buUc  liquids, they would be  separated from
the solid materials and treated before disposal.

The  landfill  contents  could  be  transported to  an off-site  RCRA-approved
facility.  TWO interim status- RCRA landfills near the Mason County Landfill
have  reserve  capacity.   One is about 250 miles  from the Site  in  Detroit,
Michigan  and the  other  is  approximately  500  miles  from  the  site  in
Cincinnati, Ohio.

On-site disposal would involve the construction of  a  RCRA-type ^facility on
the  site  property.    The  facility would have  a  double-lined* bottom,  a
leachate  collection  system,  a gas  and  condensate  collection system,  a
monitoring system, and. a multilayer cap- (Figure 15).  Buried  waste would be
removed and a landfill cell  would  be constructed  before it  was redeposited.
Special  measures  would be  taken  to  prevent airborne  contaminants  from
reaching  nearby residents  and  erosion of  stockpiles  from  degrading  the
environment.  Erosion controls such as spray foams and temporary  dams  and
ditches could minimize these threats.

A RCRA facility would effectively control the migration of contaminants to
drinking  water  supplies.    The facility would  have  to be  monitored  and
maintained  to remain  effective.    Removal  to an  off-site location  would
involve risk to the public during transportation on. public highways, and the
stockpiling of wastes on the Site would involve risk to nearby residents  and
the  environment.    Capacity   and the  federal   land ban  are  potential
limitations on  off-site facilities.   Construction of an on-site  facility
would be  less costly than the hauling and disposal fees associated with an
off-site  RCRA  landfill,  but  the  on-site  facility  would   require some
operation  and maintenance.    The  on-site RCRA-type  landfill was  carried
forward for further evaluation.

               e.   Treatment

Treatment  alternatives  include < on-site  and  off-site  thermal  treatment',
biological treatment involving composting, and physical/chemical  treatment
involving  fixation.   These technologies are described in the FS and their
evaluations as pertaining to this Site are discussed below.

On-site  or off-site  thermal  treatment  could be used to  destroy  organic
contaminants  at  the  Site.    Off-site  incineration would be difficult  to
implement because  the material must be processed, packaged, and transported
several hundreds of miles.   This could take up to 20 years to  accomplish  and
the cost for packaging, hauling, and incinerating could range  from $2,000 to
$5,000 per cubic  yard.   On-site  incineration would  also  be difficult  to
implement because  material must be prepared for  feeding to the  incinerator
and then ash  and particulate matter need to  be handled and  disposed.  There
is little  field experience  to verify costs, but  they  could range from $500
to $1,000 per cubic yard.

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HEFUSE
LtALHAIt " ' ' ' ' • • ' '
SAND 	 •— -— »__.J
SYNTHETIC ^^-X Q
MtMUHANt < — - — - 	 "—
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9


CEOTEXTILE FILTER

PRIMARY
LEACMATE
COLLECTION PIPE
                                             SECONDARY LEACMATE
                                             COLLECTION SYSTEM
                                             (SYNTHETIC OHAINI
                                                                                       CEOTEXTILE
                                                                                       FILTER
                                                                                       SYNTHETIC
                                                                                       MEMBRANE
                                                                                       GAS
                                                                                       COLLECTION
                                                                                       PIPE	
                                                                    DRAINAGE


                                                                    CLAY

                                                                    GAS COLLECTION

                                                                    COVER

                                                                    REFUSE
                 LINER DETAIL
                                                                                                   CAP DETAIL CT
                                                                     GAS VENT
                         GAS VENT
                                                                                             GAS VENT
                                                    TYPICAL LANDFILL SECTION
                                                         NOT TO SCALE
                                                                                                      FIGURE IS
                                                                                                      ONSITE RCRA TYPE
                                                                                                      LANDFILL CONSTRUCTION

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                                       19
Both off-site  and on-site thermal treatments are cost  prohibitive compared
to  biological or physical/chemical  treatment,  so  they were not  carried
forward for further evaluation.

Composting could reduce  the  level of  organic contamination; however,  the
effectiveness  of composting  with respect  to the  degradation of  volatile
organics is not well known and it could take years for contaminant levels to
decrease  sufficiently.    During  that time,  landfill contents would remain.
uncovered  in  windrows  at the Site.   Composting would not degrade  heavy
metals, and certain toxic heavy metals could inhibit the biological growth
necessary  for the degradation  process.    Thus,   composting   would  not
effectively treat the variety of materials expected  to be present  in  the
landfill,  and  the  implementation time  could not be predicted.    For these
reasons, composting was not carried, forward for further evaluation.

Fixation  could  immobilize Site contaminants.    Implementation would  be
difficult  because excavated wastes must  be segregated  into  discrete types
based on physical properties  (i. e.,. material type and  size)  and reduced to
manageable sizes  for mixing.   A. variety of fixing agents and formulas would
probably be needed  to treat the expected  variety of materials.  Other types
of  treatment  might be  applicable for the  landfill contents but cannot be
selected at this time because of unknowns involving the types and quantities
of  buried materials  on-site.    Fixation was carried  forward  as  the
representative treatment option for the landfill contents.

          2.   Groundwater Operable Unit

The technologies  and process  options  evaluated for  the groundwater operable
unit and corresponding evaluation summaries are as follows:

               a.  Access Restrictions and Monitoring

 •Die objectives and. effectiveness of access restrictions are discussed under
"Landfill  Contents  Operable Unit."   Legal restrictions would be  imposed to
prohibit  the  use  of groundwater  as  a  drinking  water supply in  areas
downgradient   of  the  landfill  affected  by  the contamination  plume.
Monitoring  of  groundwater   downgradient-  of  the   landfill   would  detect"
increases  in contaminant  concentrations and the  spread  of the contamination
plume.   If  established  target  levels were exceeded,  additional  remedial
actions could  be taken.   Groundwater monitoring would  be accomplished by a
regular sampling and analysis program  of the  existing well network.   New
wells could  be  installed to  provide data  in  areas between wells  that  are
spaced far apart.  Monitoring would  verify the protection of human health
and the environment and could be easily implemented at low cost.

Legal  restrictions  and  groundwater  monitoring  are effective  methods  of
protecting human  health,  easy to implement, and low in cost.  Because they
are significantly different,   both  were  carried forward for assembly into
alternatives.

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                                       20

              b.  Collection

The  applicable collection  technology for  the Mason  County Landfill  Site
would be an extraction well system.   The collection, disposal  and treatment
of contaminated groundwater would prevent  contaminants in the groundwater
from migrating from the  Site.    Hie system  would, consist, of a series of
wells,  located  downgradient of  the landfill,  that  will  intercept the
groundwater contamination plume.  Contaminated groundwater is  pumped to the
surface and  routed by a gravity  or  pressurized pipeline to a treatment or
disposal  system.    The number  of  wells,   well locations  and groundwater
extraction rates would be determined during the  design stage  to ensure
effective and efficient control  of the contamination plume.

An extraction well system has moderate capital and operation and maintenance
costs and, properly designed and  constructed, would be effective,  reliable,
and. durable.   Mechanical breakdowns during operation of the  system should be
routine.   Therefore,  extraction wells  were  carried,  forward for further
consideration.

               c.  Treatment

Treatment alternatives  include  off-site treatment  including  the use of  a
RCRA. facility  or a  publicly  owned  treatment works  (POIW)  and on-site
treatment including physical/chemical treatment such, as reverse osmosis, ion
exchange,  precipitation,   air   stripping,   steam   stripping  and  carbon
adsorption.     These  technologies  are  described  in the  FS   and   their
evaluations as pertaining to this Site are discussed below.

Off^site treatment would  require transporting large volumes of groundwater
to a RCRA facility or POIW.   The POIW  is  within  3 miles  of the Site, so
transportation to the POIW would be less  costly.   However, treatment volumes
for  either  alternative  could  range as high as  500,000 gpd which  would
require hauling of 50 truckloads of  groundwater per  day and  a one million
gallon tank to provide two day storage.  Because of  the high volume of  water
that would need to be stored and  hauled, off-site treatment  was not carried
forward.

None  of  the  individual  on-site  treatment technologies  would  completely
remove  both. the organic  and  inorganic  constituents  in  the groundwater,
however, two technologies could  be  implemented together.   Reverse osmosis
and  ion exchange units  were eliminated from consideration because of  their
higher costs relative to other options.  Neither air nor steam stripping can
remove  inorganic  constituents,  whereas granular  activated carbon  adsorption
(CAC) can remove  some of the  inorganic constituents.   Thus,  the GAC process
is  more  versatile and  would  require  less  pretreatment  of contaminated
groundwater.    Since the &C process requires less  pretreatment and is less
costly  to operate  than air  and steam  stripping  because  of lower energy
demands, the GAC process was retained for further consideration.

The  treatment system that  appears to be most  suitable for the Site  would
consist of precipitation and carbon adsorption, although other systems  would
probably  work  and  may  be  determined  more  suitable  in  final design.

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                                        21

Precipitation  would  be  used  as pretreatment  to  remove  some  inorganic
constituents  in  the  groundwater.     The  low  contaminant  load  in  the
groundwater will require  high chemical  dosages to  precipitate the inorganic
constituents, which will generate high volumes of  sludge.   The  sludge is
excepted to contain high enough concentrations of certain toxic heavy metals
that  it would  have to be handled and. disposed  of  as a hazardous  waste.
Therefore,  the  treatment  system, should  be  designed  to  minimize  sludge
production.

Implementation  of  the treatment  sysLeuii  would,  require  a  pilot  study to
develop  the  most  efficient  balance  for  contaminant  removal  rates  by
precipitation unit and. the  (3X2 column.   Installation of the system would be
easy  because  skid-mounted  treatment  units  are  available.    An  on-site
operator  should be present  to  monitor  for  contaminant breakthrough  and
replacement of carbon beds.


     B. Alternatives Considered

Remedial alternatives  considered for this Site are combinations of actions
and technologies that  represent overall approaches to the Site problems and
remedial goals.   The  six technologies  that remained  after  screening range
from- simple,  low cost alternatives to  alternatives more  costly and complex
and. address the remedial  goals identified in  Section VII A of this ROD and
within  the FS.   The  alternatives  that underwent detailed evaluation  are
listed below along with a detailed description of each.

      Alternative 1 - No Action

Alternative 1 is the no action alternative, which the National Contingencies
Plan  (NCP)  requires for baseline comparison to  other alternatives.   Under
the no action alternative, no further remedial investigation or action would
be conducted, and the public health and environmental risks would be those
identified in the risk assessment.

The pathway of most concern  is the potential contamination of residential
wells downgradient of  the Site.   Those  wells are not currently contaminated
and do not pose an  immediate public  health  risk,  but  the potential  for
release  of  contaminants  fron  uncontrolled  hazardous   substances  in  the
landfill may  pose a future threat.   Lower  public health and  environmental
risks  are  associated  with  migration  of contaminated  groundwater  to  Babbin
Pond  and Iris  Creek.   Direct  contact  with buried waste and  ingestion of
contaminated groundwater  could occur  if future residential  development were
allowed on-site.

      Alternative 2 - Site Restrictions

Alternative 2 consists of Site access restrictions and a monitoring program,.
(Figure 16).  It would reduce the public health  risks by controlling access
to  on-site   contaminants  and  by  monitoring  contaminant  migration  in
groundwater.

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              2 WELLS IN
              CLUSTER

 3 WELLS IN
 CLUSTER


                            2 WELLS IN
                            CLUSTER
LEGEND


	APPROXIMATE LANDFILL BOUNDARY


  •    EXISTING MONITORING WELLS

  •    NEW MONITORING WELLS

	<—  SITE FENCE
       DEED RESTRICTIONS ON
       PROPERTY USE
                                                                      FIGURE  16
                                                                      ALTERNATIVE 2
                                                                      SITE RESTRICTIONS
                                                                      MASON COUNTY LANDFILL FS

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                                        22.

Access restrictions would, consist of a Site fence, warning  signs,  and deed
and zoning  restrictions on property use.  A six: foot high fence 4,800 feet
long,  with  locking  gates,  would  be  installed on or near  the  property
boundary.   Alternatives to  the site fence will be considered  if  they are
determined  to  adequately  protect  the  landfill cap  integrity  and  keep
trespassers away fron the area of the gas vents.  Signs would be posted to.
warn,  intruders  of  the  health hazard.   Deed  restrictions  would  prohibit
future Site development and the  installation  of water supply wells  on the
Site.

The monitoring program would consist of periodic sampling and analysis of 20
monitoring wells.  Four new monitoring wells would be  installed along Inman
Road  to  provide additional, information  about  the vertical and horizontal
migration  of  contaminants.    Groundwater would be analyzed annually for
Target Compound  List volatile organic compounds and. semiannually for typical
landfill  monitoring  parameters such  as pH,  specific  conductivity,  total
dissolved   solids,  total   organic  carbon,  total organic   halide,   iron,
chloride, nitrate, and sulfate.

Performance  and Reliability  - Alternative  2  does  not have processes  or
equipment that might fail  and the reliability of its components  has  been.
demonstrated.   It would prevent direct  public contact with buried waste,
landfill gases and contaminated sediment and surface soil.   In. addition, it
would track and  document the nature and extent of contaminant migration.

Changes in deed  restrictions would be unlikely because the property is owned
by the Mason County  DPW.   Groundwater use restrictions on  privately owned
property  downgradient  of  the  landfill would,  be  difficult  to  enforce.
Currently  such  restrictions  are  not  needed as no residential wells  are
contaminated  at  this  time; groundwater monitoring would provide warning if
contaminant levels increased in the future.   Msnitoring requires semi-annual
visits  to  the  Site  to collect samples and  continued  sample  management
efforts to  document water quality.  Future actions could  be implemented as
appropriate.

The Site  fence and warning signs would prevent human contact with  gas  vent
emissions and contaminated surface soils or sediments.   They would also help
protect the integrity of the landfill cap by  limiting  vehicle access.   The
fence would, require routine maintenance for a prolonged useful life.

Implementation - Alternative 2 could be  readily implemented.  The  four new
monitoring  wells  and  Site  fence  could  be  easily  installed by  local
contractors.  Construction of  the Site fence would require some clearing of
trees  and  shrubs,  and  a  survey  would  be needed to  define the  property
boundaries.   It appears that  some of the landfill is  outside the  property
boundary.

Alternative 2 would not pose  unusual  or high levels of risk to workers or
the public  during  implementation.   Installation of the  fence should not
disturb any buried  wastes  and the wells  would  be installed  in areas  of low
contaminant levels.   Sampling  team members for  the monitoring  program could
be exposed to volatile organic compounds  for the life of the  action, so well

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                                       23

construction  and sampling  work should  proceed under  Level D health  and
safety protection.   Air monitoring during sampling activities  would ensure
that exposure limits are not exceeded.

          Alternative 3 - Containment (Surface Controls)

Alternative  3 consists  of surface  control measures  as well  as the  Site
restrictions  associated with Alternative 2  (Figure 17).   It would, reduce
public  health,  and  environmental  risks by  restricting  Site'  access,  by
monitoring  contaminant  migration  in  groundwater,  and  by reducing  the
leachate volume and associated groundwater contamination.

Surface  controls would  consist of  clearing vegetation and regrading  the
Site.  Approximately 18,000 cubic yards  of imported clay would  be needed to
fill  Site  depressions,  such as  the  ponded  area,  to increase  the  cap
thickness to at least 2 feet and to establish a three to five percent grade.
Approximately 9,000 cubic yards of imported soil would  be needed for a six
inch thick  layer of topsoil  to  support vegetation.  Ihe existing drainage
structures  (berms, area drains,  and buried pipelines) would  be  incorporated
into the final grading plan and upgraded as necessary.   Erosion  control mats
would be placed  on  the  steep side  slopes  north of the landfill to  help
establish vegetation, and erosion gullies would be filled and reseeded.      ;

Performance  and  Reliability  -  The  components  of   Alternative   3   are
demonstrated  and reliable.    Surface controls  would reduce  the amount  of
water percolating through the  landfill  contents by eliminating  cracks  and
ponded  areas,  increasing  the  minimum  surface  slope  to   five  percent,
increasing  the   soil  moisture  storage   capacity,   and   increasing   the
evapotranspiration rate.  Based on water balance calculations (Appendix A of
the FS),  the percolation rate and,  thus,  the volume of generated leachate
would be reduced about fifty percent.

Periodic  inspection  and. maintenance  of the landfill cap is necessary  for
continued effectiveness  at reducing  water infiltration.  Moderate to  high
settlements are expected at the Site, considering the nature  of  the landfill
contents  (mainly. municipal  garbage  and trash) and  settlements that  have
already  occurred.   Maintenance would  consist  of  refilling and reseeding
areas of subsidence and erosion.    Replacement of  the cap  should not  be
necessary if proper maintenance  procedures are employed  throughout the life
of the remedial action.

Implementation   -  Alternative  3   could   be   implemented   using  routine
construction methods and  equipment.   Top soil,  clay,  and sand are available
within  ten  miles of  the Site,  and  other necessary materials are commonly
available.  A topographical survey would be needed to design a  Site grading
plan.  The 15 gas vents would probably be destroyed and have  to  be replaced.
Incorporating all existing drainage structures may  be difficult, so  some
area drains and buried pipeline may be needed.

fcforkers on the Site during regrading and gas vent replacement may be exposed
to  buried wastes.   Regrading  is not  intended to  disturb,  the  underlying
landfill contents; Level D protection  (minimum worker  protective clothing)

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LEGEND
        APPROXIMATE LANDFILL BOUNDARY

        EROSION CONTROL

        SURFACE CONTROLS OR SOI L-CLAY CAP

        NOTE: Alternitivts 3 and 4 includt all jits r*itriction
             options snown in Figurt 5-3.
                                                                          FIGURE  17
                                                                          ALTERNATIVES 3 AND 4
                                                                          CONTAINMENT
                                                                          MASON COUNTY LANDFILL FS

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                                       24

would  be  expected, for  this activity.   Installation  of gas  vents  would
require  drilling  through  the  landfill  contents;  Level c  (air  purifying
respirator  required)  protection may be  needed for  a portion of  the  work.
Sane short-term safety-risks to the public would result  from increased truck
traffic  in the area while soil  is hauled to the  Site.   Dust  levels  could
increase  during the-  earthwork  activities,  but  water sprayed  on dry  soil
would  limit the amount, of dust generated.  Total  suspended  particles  would
be monitored  daily during earthwork activities to ensure compliance  with
appropriate ambient air regulations.  Erosion of loose soil along Iris Creek
could  be prevented by use of plastic covers over  bare soil or  temporary
dams, ditches, or fences.

          Alternative 4 - Containment (Soil-Clay Cap)

Alternative 4  differs from Alternative 3  in that  a soil-clay cap would be
installed instead of surface controls.  Alternative 4 also includes the Site
restriction measures  of  Alternative 2.    The  components (see Figure  17)
consist of property use restrictions, a Site fence,  groundwater monitoring,
and a  soil-clay cap,  all of  which would  reduce  risk to  public health or the
environment.

Installation, of the soil-clay cap (see  Figure  14)  would involve removing
vegetation, regrading, and placing a clay layer.   An estimated  18,000 cubic
yards  of clay  (the  same quantity for Alternative  3)  would be needed to
increase the cap thickness to at least 2 feet.  Approximately  28,000  cubic
yards  of  sand  would be needed for an 18-inch drainage  layer just above the
clay barrier, and perforated drain pipes would be  installed  to  remove water
fromi the  cap.   The drain pipes would route  the water to storm drains  that
discharge  downhill from the landfill.   The existing  stream drains  could
possibly be incorporated into the drainage systan.   About 19,000 cubic yards
of fill and 9,300  cubic yards of  topsoil  would  be  placed above  the drainage
layer  to  provide frost protection and soil moisture storage.   A geotextile
filter between the fill and sand would prevent the  drains from clogging.

Performance  and  Reliability  -  The components  of  Alternative  4  are
demonstrated and reliable.   The soil-clay would reduce percolation  through
the  landfill  contents by providing a barrier to  pievait infiltration of
water  and a drainage layer to remove, water that might  accumulate  on the'
clay.   Based  on water balance  calculations (Appendix A in the FS), the
percolation, rate  would  be reduced  ninety percent  from current   Site
conditions.  This assumes that the compacted clay barrier has a hydraulic
conductivity of 1 x 10"7 cm/s.

Inspection and maintenance of the soil-clay cap would be similar to that for
the surface controls.   Since the cap must remain nearly impermeable to be
effective,  repair  may involve removing the  upper  layers to reach the  clay
barrier.   Settlements could eventually eliminate the slopes needed  for the
drainage  layer to remove water  from  the clay.   To account -for periodic
repairs,  it is assumed that annual maintenance for the soil-clay cap would
be needed for the 30-year design life.

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                                        25

Implementation - Alternative- 4 would be- more difficult and take more time to
implement than Alternative 3.  Additional attention to details during design
and  construction would  be required  for the  individual  components of  the
soil-clay clap to function properly.   Potential problems  include leakage of
water through the clay barrier at gas  vent  locations,  surface infiltration
collection  details,  and  construction on the  steep side  slopes.   Also,  a
potential problem, would be the  continued subsidence of  the landfill and its
effects  on.  drainage systems,  such  as perforated  pipes.   Protection  of
workers  and nearby residents during  construction would be similar to  that
for Alternative 3.

          Alternative 5 - Groundwater Collection and Treatment

Description -  Alternative  5  consists  of  the  components  described  in
Alternative  4 with, the addition of a groundwater collection  system and on-
site treatment plant  (Figure 18).  Alternative 5 would protect human health
and  the environment by  preventing contaminated  groundwater  from migrating
off the Site.  Contaminant levels in the groundwater contaminant plume north
of the  landfill  would be reduced below maximum contaminant levels, and the
water discharged after treatment would meet ambient water quality criteria.

Ten extraction wells spaced 200 feet apart and screened in the upper aq JLfer
would be sufficient  to intercept  the contaminant plume  (see Appendix  B- of
the FS).  Each well  would have a discharge control valve to ensure adequate
drawdown of the aquifer.  A buried header pipeline would route the pumped
groundwater  to Babbin Rand for discharge.   Discharge estimates range  from
35,000 to 500,000 gpd; the average estimated discharge  is 160,000 gpd.   The
groundwater  treatment system described herein was  based upon  the average
discharge and flow weighted, maximum, contaminant concentrations (see Appendix
 C of the FS).

Groundwater  treatment would consist  of flow equalization  and mixing  in
Babbin  Pond and treatment by  precipitation (with associated settling and
sludge  dewatering) followed by granular activated carbon (GAC)  adsorption.
The  precipitation  and   GAC  units   would   be  housed   inside  a  building-
constructed near Babbin Pond.    Babbin Pond  would be  enlarged from  its
220,000  gallon capacity  to  320,000  gallons (2-day storage  volume at  the
average  estimated collection  rate)   and lined with an impermeable  double
membrane system.  A leak detection system for  the basin would be installed
as required by RCRA.  An aerator would be installed in the pond to mix and
aerate  the  water.    This will  help  reduce algae growth  in  the summer and
prevent' ice  formation in the winter.   Water from the pond would be pumped to
a precipitation unit for treatment prior to GAC adsorption.  The pH would be
controlled within the precipitation system.   Sludges that accumulate would
be collected, solidified, and  disposed of  at an off-site  RCRA landfill.
Water would then be  pumped from the  precipitation unit to two 10,000 pound
GAC  columns  connected  in series.   After  treatment,  the water would  be
discharged by pipeline to Iris Creek.

Effectiveness  and Reliability -  Alternative  5  would effectively  reduce
contaminant  mobility  by  collection  and  treatment  of  the  grounoVater.
Toxicity  would  not  be  reduced because   hazardous   materials  would  be

-------
           EQUALIZATION POND
           WITH AERATOR
                                                                                    "«- 3
                                              
-------
                                       26

concentrated in sludges and. spent carton.  However, risks at the Site caused
by contaminants  in the groundwater would  be reduced because the  residuals
would be hauled to a RCEA facility.

The ^collection and treatment system has demonstrated reliable  performance.
Hie pumping system would require routine inspections,  but maintenance would
be  routine.    Pumps would  require  servicing  every  few years,  and  the
treatment plant would require a full-time  operator (8 hours per day). Many
of the components would require eventual  replacement  (e.g.,. storage tanks
and pumps), and activated carbon,  alum,  anionic polymer,  and soda ash would
have to be purchased periodically.

Hie discharged water and the contaminant plume would be monitored throughout
the  life  of  the action  to  measure compliance with state  and  federal
regulations.   Discharge parameters would  include  continuous monitoring  for
dissolved oxygen  and pH and bimonthly analysis  for  hazardous substances as
required by the NPDES permit.

Implementation  - Alternative   5  could  be  implemented  with  difficulty
associated with both collection and treatment.  Groundwater collection would
be complicated by the  hydrogeology at  the  Site  and  poor access  to well
locations.  Part  of the well alignment would go outside the property lines,
and additional property would need to  be purchased or permission granted by
the property owner for  installation.   Pumping could adversely affect nearby
residential  wells;  however, the effect  should  be  minimal  because  the
residential wells are either greater than 400 feet from the extraction wells
or are screened in the lower aquifer.

Rabbin Pond would need a double liner with  a leak detection system.   The
area would have  to  be dewatered during construction of the liner  and  the
water hauled off-site for treatment.   The dewatering- system, would be left in
place  in  case of emergency repair  to  the  liner.   Pump tests  would  be
performed  for each  well  installation  to determine  the  actual  cones  of
depression and, thus, adequate  well spacing.   Water generated from the pump
tests would also need to be contained and named off-site for treatment.

After  the  extraction  and  collection  system  is  installed,   the  actual.
contaminant  loadings to  the  treatment  system, will  be determined;  pilot
testing would determine the necessary treatment plant components,  holding
times, and rates of chemical addition.   Ine groundwater  contaminant plume
might be diluted during extraction,  but it was  conservatively  assumed that
the maximum, detected contaminant levels could be collected and the treatment
system  was  sized accordingly  for  this  study.   Ine components  of  the
treatment system  could be purchased complete  from  various vendors.   Several
mechanical  parts  would  require  routine  maintenance,  and the  treatment
process must be  carefully monitored to prevent breakthrough.   An automatic
alarm system would be installed for after-hour plant emergencies.  The plant
would produce about 640 gallons of sludge  at thirty percent solids per day.
The sludge would require periodic transport and disposal at a RCRA facility.

Health and safety risks during implementation would, include potential direct
contact with contaminated  water  during well  installation and dewatering

-------
                                       27

activities  associated  with installation  of  the  pond  liner.    However,
contaminant  levels  are  low and  Level D protection  is  expected  to be
adequate.  There  are some health risks associated with sludge handling and
carbon regeneration, and trained personnel would be required.  Risks  to the
public would consist of transport of contaminated water and sludge on  public
highways.

          Alternative 6 - Removal,  Treatment, and Disposal

Alternative 6 consists of the components of Alternative 5 with the addition
of  the  removal  and treatment  of landfill contents (Figure  19).    Only
removal, treatment, and disposal of landfill contents  is described below.  A
RCRA-type  landfill  facility would be  constructed  on-site  to   contain the
landfill contents.  Alternative 6 would reduce the mobility of contaminants
through treatment (fixation) and contaminant.

An  estimated  140,000  cubic yards  of  material  would  be excavated and
segregated for treatment.  Materials would be sorted according to  waste type
(i.e., metal,  paper, plastics) and  size.   Preprocessing would consist of
shredding  or  breaking the materials to sizes that could readily be mixed
with  the  appropriate  fixing  agents.    All  excavated  material would be-
temporarily  stockpiled  during preprocessing  in  a  specially constructed!
building with a  leachate collection system.   Waste materials  and  fixing
agents could  be mixed  in a pit or directly in. the newly  constructed RCRA
facility  using   equipment  such  as   front-end  loaders,   bulldozers, and
backhoes.

It  is difficult to  estimate accurately the size  of  the on-site RCRA-type-
facility  necessary  to  store hazardous  materials  because  of inaccuracies
associated with the  landfill volume estimate, the increase  in volume  caused
by  the  addition of  fixing agents, and the final depth of fill  in the new
facility.   Based on the estimated 140,000 cubic yards of material  and an
assumed volume increase of ten percent, the RCRA-type  facility would need to
contain a volume of roughly 150,000 cubic yards.  Assuming that wastes could
be  placed to an  average  thickness of  twelve feet, an area of about eight
acres would be needed.   Quantities of earthwork and other  materials  needed
to  construct  the  RCRA-type facility are  based  on the cross-sectional
dimensions shown in Figure 15.   ' '     "'

Effectiveness  and  Reliability -  Alternative 6  would  effectively  reduce
contaminant mobility at  the  Site, but  would not reduce the  toxicity and
volume of contaminants.  Groundwater monitoring would  be necessary to  ensure
that  contaminants do  not  leak  through the  liner of  the  landfill.  The
effectiveness of the facility would depend upon continued  maintenance  of the
cap and upon collection, treatment, and disposal of leachate.

By  controlling  the  contaminant  source,  contaminant   loading  of the
groundwater would be virtually eliminated.  At some future  time contaminant
levels in the groundwater contaminant plume are expected to be reduced below
levels that would cause public health or environmental risks.   Since it is
not  possible  to  predict  the  time  period  necessary for  this  to  occur,

-------
            EQUALIZATION POND
            WITH AERATOR
LEGEND

 	APPROXIMATE LANDFILL BOUNDARY

        EXTRACTION WELLS AND HEADER

        INFLUENT AND DISCHARGE PIPELINE

        EXCAVATED AREA

        RCRA-TYPE LANDFILL
NOTE: Excavation limits art tha approximate
     landfill boundary. Altarnativa 6 include!
      all tita restriction options shown in Figure 5-3.
FIGURE 19
ALTERNATIVE 6
REMOVAL. TREATMENT, AND
DISPOSAL
MASON COUNTY LANDFILL FS

-------
                                       28

groundwater collection and treatment is assumed for the full 30-year life of
the action.

Implementation  -  Alternative  6  would be  difficult  to  implement.    Wbrlc
schedules  would  require  constant adjustment depending  on  the  type  of
materials encountered.  Hazardous or toxic materials have  to be sorted from
nonhazardous and nontoxic materials prior to  treatment.  Size  reduction and
several different  treatment mixtures  would, probably be needed for adequate
fixation.   The construction sequence would  require excavating an  area and
stockpiling materials  until construction of the on-site RCRA.  landfill cell
was completed.   Large volumes of material would have to  be stockpiled, and
protected fron wind, and water erosion.

Workers would be exposed to health and  safety risks for  the  length of the
action,  but Levels  B and C protection would be used to protect  worker
health.   Public health  and environmental risks  could occur  from airborne
contaminants during excavation or from wind and water  erosion  of stockpiled
wastes.   An air monitoring programi would be implemented during  any waste
handling  activities  to  detect  emissions of  volatile  organic  compounds  or
particles.

VIII.. SIMftRY OF COMRVRAIIvE ANALYSIS CF ALT£ra»HvES

This section  compares the six remaining  alternatives using-  the  following
nine criteria:

          Short-Tenni Effectiveness
          *  Protection during remedial actions.
          *  Time until protection is achieved.

          Long-Term. Effectiveness
          *  Magnitude of residual risk.
          *  Long-term controls.

          Reduction of Toxicity, ftobility, and Volume
          *  Treatment process used, and materials treated.
          *  Amount of hazardous materials destroyed or treated.
          *  Type and quantity of'residua is remaining after treatment.
          *  Degree of expected reductions in toxicity, nobility,  and
             volume.
          *  Degree to which treatment is irreversible.

          Implementation
          *  Technical feasibility.
          *  Availability of necessary services and. materials.
          *  Administrative feasibility.

          Cost
          *  Direct capital costs.
          *  Indirect capital costs.
          *  Operation and maintenance costs.
          *  Total present worth.

-------
                                        29
          Compliance with ARARs
          *  Compliance with, contaminant-specific ARARs.
          *  Compliance with action-specific ARARs.
          *  Compliance with location-specific ARARs.

          Overall Protection
          *  How alternative provides protection of human health and the
             environment.

          State Acceptance
          *  Aspects of the alternative that the state supports.
          *  Aspects of the alternative about which the state has
             reservations.
          *  Aspects of the alternative that the state strongly opposes.

          Conirunity Acceptance
          *  Aspects of the alternative that the community supports.
          *  Aspects of the alternative about which the community has
             reservations.
          *  Aspects of the alternative that the community strongly opposes.

Seven  of  the nine  evaluation  criteria  (excluding  state acceptance  and
community  acceptance)  are  sunmarized in Table  6.    State acceptance  and
connunity acceptance are discussed later in this  ROD.   Specific ARARs that
apply or nay apply to each alternative are listed in Table  7.

Costs  for  each alternative  are  detailed within the  FS  report  and  are
smmarized in Table  8.

IX.  m'lH «KM1 PLATS AND DOCOMENIATTCN OF SK2HFICA11HP CHANGES [SECHCN 117 (b) ]

The U.S. EPA's  Proposed Plan was released for public comment from August 8
through August 31, 1988.  In the Proposed Plan, the U.S. EPA. stated  that the
remedial action at this Site will be divided  into two separate  operable
units; one  dealing with landfill contents  and the other with groundwater.
The Proposed Plan announced Alternative 4 (containment-soil/clay cap),  which
also  includes the Site restrictions of  Alternative  2,  as the  U.S.  EPA's
preferred  remedial  action alternative  for the  landfill contents  operable
unit.  Remedial  action on the groundwater operable  unit was deferred until
the  effectiveness  on  the  landfill  contents  remedial  action could be
measured.

After  the  Public  Comment  Period  and  comments  from the  Coimunity  were
received,  no significant  changes  were  made to the  U.S.  EPA's preferred
alternative for the landfill contents operable unit  (Alternative 4) and the
deferring of the selection of a remedy for the groundwater operable  unit.

-------
       EVALUATION
         FACTOR
ALTERNATIVE 1

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  ALTERNATIVE I

SITE RESTRICTIONS
                                                                                              ALTERNATIVE J

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                                      CONTAINMENT
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REMOVAL. TREATMENT
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-------
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  ALTERNATIVE I

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 CONTAINMENT
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                                                                                                                                                                 MOuM itm» ociun
                                                         Mmo M MonoliM t

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                                                         kig kom dMMcHWl. kooiMUM knd MHO-
                                                         m«nl. *nnu*t Inipocllo)! ond molntonanc*
                                                                     Nip to knokMlionl.
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                                                                                                                              W aa AM>MIM* I.

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                                                                                                                                                                      i aa AlamaiM t
                                                                                                                                                                                           E*o tonca Mnia ai
                                                                                           Ooxtd.
                                                           to M«l«n*nl. lOpW moio «lk«i« Man tot
                                                           AHaiiuih* a and tapiataiiiam MgM to
                                                           •acaaaanv kt M IMA
                                                                                                                                                           too/** 4M|f «ia»«ii«ig and kitpoCM* to
                                                                                                                                                                 a**ofk*»noi»; ottiNa •spotat al
                                                                                                   !** cotaction an« liawntaAt NOW'O
                                                                                                 oWgr maMoixt and meonon n on
                                                                                            Him dlocMonoii. dhvio akipotai ot Wutfai
                                                                                            and ipanl uroon •oukj nm«« camanwiaoi
                                                                                            koM *•»; awnkii«g atoM<oar t»
                                                                                                                                                                                           f anlaMng vatfat D>v*n «k«|)ocMn ana) Wfrn
                                                                                                                                                                                           kxunca ruaiwi >ouid aikxtnoty i*duc>
                                                                                                                                                                                        TABLtt  (PAGE I OF 31

                                                                                                                                                                                        {VALUATION AND COMPARISON

                                                                                                                                                                                        Of REMEDIAL ALTERNATIVES
                                                                                                                                                                                        UAIOXroUNI* LA^OIUL II

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     •VALUATION
       FACTOR
ALTIKNATlVe I
  NO ACTION
  ALTERNATIVE I
SIT! RESTRICTIONS
   ALTERNATIVE I

   CONTAINMENT
(SURFACE CONTROLS)
 ALTERNATIVE 4
 CONTAINMENT
(SOU CLAY CAP)
     ALTERNATIVE •

OROUNOWATER COLLECTION
     AND TREATMENT
   ALTERNATIVE •
REMOVAL. TREATMENT
   AND DISPOSAL
OVERALL PROTECTION
OF HUMAN HEALTH AND
THE ENVIRONMENT
                                                                                             IMCIUM
                                                                                                                                          4 i
                                                                                                                                        C4V4W1
                                                       • Mi bMk.
                                                                                                          MvMlh* 1 M* Mtl


                                                              11* fOIMIMM
                                                              «•«•.

                                                                                                    Mn ol Ml* t
                                                                                                                                     •I
                                                                                                                                     m M

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                                                             Table 7   (Page 1  of  3)
                                                       ARARs FOR THE MASON COUNTV  LANDFILL
   Regulation

FEDERAL

Clean Air Act,
Section 101

40 CFR  52


40 CFR  50
Clean Water Act,
Section 208
40 CFR 122

40 CFR 125

40 CFR 131


40 CFR 136


40 CFR 257



40 CFR 261


40 CFR 262


40 CFR 263
40 CFR 264.1
through .117(C)

40 CFR 264.191
through .198
           Requirement
 Implementation of regional air
 pollution  control programs.

 Rules  for  implementation of
 regional air quality plan.

 Air quality standards.
Actions consistent with regional
water quality management pro-
gran.

NPDES pernlt regulations.

Criteria for NPDES permit.

Enforcement jurisdiction over
discharges granted to states.

Adherenece to sampling
procedures.

Standards for solid waste dis-
posal facility; management
delegated to states.

Definition and Identification
of hazardous waste.

Regulations for generators of
hazardous waste.

Regulations for transport of
hazardous waste.

Regulations for closure of a
hazardous waste site.

Regulations for tank storage
of hazardous waste.
            Regulated Action
              or Condition
Emissions during excavation.  Possibly
gas vent emissions.

Emissions during excavation.  Possibly
gas vent emissions.

Emissions during excavation.  Possibly
gas vent emissions.

Discharges to Iris Creek.
Discharges to Iris Creek.

Discharges to Iris Creek.

Discharges to Iris Creek.


Discharges to Iris Creek.


U.S. EPA to determine If Subtitle D
landfill closure is appropriate.
Excavated materials and groundwater
treatment residuals.

Groundwater treatment residuals hauled
offslte.

Groundwater treatment residuals hauled
offslte.

U.S. EPA to determine If Subtitle C
closure regulations are appropriate.

Groundwater treatment system  tanks.
                                                                                                                     Alternative
1 2 3 4
t
9
X X X X
X X XX
X X X X



X X X X



X X X X

5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X

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                                                             Table  7  (Page 2 of 3)
   Regulation

 40 CFR 264.301
 through .314
 40 CFR 264
 Subpart X


 40 CFR 268
 Subpsrts C and D

 40 CFR 403
40 CFR 141
Executive Order
12372,
40 CFR 29

Executive Ordera
11988 and 11990,
40 CFR 6,
Subpart A

Fish and Wildlife
Coordination
Act

STATE

ACT 348
ACT 315
ACT  641
ACT 64,
Parts  2  and  3
          Requirement

 Riilos for construction, main-
 tenance and closure of a
 hazardous waste landfill

 Standard* for environmental
 performance of miscellaneous
 treatment units.

 Land-banned waste materials.
Pretreatment standards for
discharge to local POTW.
Establishes maximum contami-
nant levels for drinking water
quality.

Requires state and'local
coordination and review of
EPA-asslsted projects.

Avoids adverse affects to
flood plain or wetlands and
evaluates potential impact* to
those areas.

Protects fish and wildlife
when natural stream ia •
modified.
Regulates air emissions and
requires monitoring of air.

Regulates permitting, construc-
tion, and abandonment of
wells.

Regulatea the disposal of
nonhazardous waate.

Requirements for identifica-
tion, recordkeeping, and man-
agement of hazardous waste.
            Regulated Action
              or Condition
    i
 Construction and closure of a
 RCRA type landfill


Physical/chemical treatment.
Would apply to certain solvent-containing
wastes if present in landfill contents.

Discharges to POTW after installation of
extraction wells but before Installation
of onslte groundwater treatment plant.

Croundwater at the site.
Mason County Landfill ia a CERCLA site.
Croundwater extraction and collection
will probably "dry up" the marshy area
near Babbln Pond.
Discharges to Irla Creek.
Handling and treatment of landfill
contenta; gaa vent emissions.

Monitoring wells onslte and near site.
Croundwater extraction wells.
May be appropriate for landfill closure.
Generated groundwater treatment residuals
and excavated landfill contents.
                                                                                                                      Alternative
                         tr

                         x
jr

 X
X


X

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                                                             Table   7  (Page 3 of 3)
   Regulation                 Requirement

 ACT 64,             Regulations  for construction
 Part 5             and licensing a new hazardous
                    waste facility.

 ACT 64,             Specifies  technical standards
 Part 6             for locating operating and
                    closing  a  hazardous waste
                    facility.

 ACT 136             Requirements for  transport of
 ACT 64,             liquid or  solid waste offslte.
 Part  4
ACT 347,           Requires a soil erosion and
Rule 1704          sedimentation plan for earth
                   changes within 500 feet of a
                   laXe or stream.

ACT 245,           Rules for reporting discharges
Part 9             to state waters.

ACT 245,           Rules for NPDES permit.
Part 21

ACT 98 .            Supervision and control of
                   sewerage systems.

ACT 203            Regulates activities that
                   affect wetland areas.
ACT 346,           Permit for construction In
Section 3          "bottom  land."
            Regulated Action
              or Condition

Onslte RCRArtype landfill.
Onslte RCRA-type landfill and containers
or tanks used for treatment may be
appropriate for landfill closure.
Hauling contaminated groundwater to local
POTH during Installation of groundwater
collection and treatment system.  Trans-
port of groundwater treatment residuals.

Erosion control measures along north
slope of landfill and construction
activities for groundwater collection and
treatment systems.

Discharges from groundwater treatment
plant.

Discharges from groundwater treatment
plant.

Construction and operation of groundwater
treatment plant.

Construction and operation of groundwater
collection system; discharges to Iris
Creek.

Burled pipeline for groundwater
collection and discharge.
                                                                                                                     Alternative
5       6

        X
X


X


X


X
X


X


X


X
 "X"  Indicates  that  regulation  is  applicable or relevant and appropriate.
GLT806/1

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                                              Table 8
                                        COST ESTIMATE SUMMARY
         Description

Sic* Fence
MontcorIng Well Installation
Surf«ce Controls
Soil-Clay Cap
Croundvater Collection
Crouadvater treataeat
Excavation
Onalte Fixation
Onsite ROU Landfill
Allowances
Other Coats

Direct Capital Cost

Present Worth of 04M Costs
Alternative
2
S 67,000
21,000
0
0
0
0
0 "
0
0
11,000
67.000
$166,000
530.000
3
$ 67,000
21,000
345,000
0
0
0
0
0
0
52,000
322.000
$807,000
765.000
4
$ 67,000
21,000
0
868,000
0
0
0
0
0
115,000
687.000
$1,758,000
1.070,000
5
$ 67,000
21,000
0
868,000
184,000
937,000
0
0
0
353,000
1.840,000
$4,270,000
7.970.000
6
$ 67,000
21,000
0
0
184,000
937,000
4,026,000
8,749,000
2,711,000
2,838,000
14.668.000
$34,201,000
9j 100, 000
Total Present Worth Estimate     $700,000    $1,600,000     $2,800,000    $12,000,000   $43,000,000
 Allowances consist of aobilization/deaobilization and a field
 detail allowance.  See Appendix D for detailed breakdown.
 Other costs consist of contingencies for bid and scope iteas aad
 allowances for adainistrative services, engineering design, and
 services during construction.  See Appendix D for detailed breakdown.
 Present worth estimates assume a discount rate of 5 percent annually
 over a period of 30 years.
 Cost estimate is order-of-aagnitude level with expected accuracy of
 +50 percent to -30 percent.  Total present worth estimate is
 rounded to two significant figures.
OLT626/81

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                                        30

X.  SELECTED RfcMJJJT AND SIKTUKKT DE3ERHEBVEICM5

     A.   Lapri-Fiii Contents Operable Unit.
    Delected remedy for tJbe landfill contents operable unit is Alternative 4
wnich  innjiyto?  the fmt-j>-iniMii_  of the- landfill contents by  means of  a
soil/clay RCRA subtitle C compliant cap. Site restrictions and groundwater
monitoring.

Alternative 4  is protective of human health and the environment, attains or
defers applicable or relevant and appropriate requirements promulgated under
Federal and State  environmental laws and is cost  effective.   Alternative 4
is  not  the final  remedial action for the  Site but' is consistent with  the
final remedy.  Ine final remedy at the Site will include the remedial action
alternative from the landfill contents operable unit (Alternative 4)  and the-
remedial  alternative   chosen  after  the  groundwater   operable unit   is
completed.

         1.   Protection of Human Health and the Environment.

Alternative  4  provides protection of  human  health and the  environment
through  the  use  of  containment  of  landfill  contents  and  institutional
controls such  as Site access  restrictions.   Protectiveness is achieved with.
the upgrading  of the present  cap to a RCRA compliant, subtitle C, soil/clay
cap.  Ine cap is  a reliable  method to alleviate  the  direct contact threat
from the  landfill  contents.   3ne RCRA compliant cap is  estimated to reduce
leachate generation by ninety percent, which, in turn should lower the amount
of  contamination   reaching   the  groundwater.    Also,   by  reducing  the
concentrations  of  contaminants reaching the groundwater,  less contamination
will reach the surface water bodies near the Site  (the wetlands, Babbin Pond
and Iris Creek) .

Since untreated wastes will remain within the landfill, the groundwater will
continue  to be monitored  to  ensure  the  protectiveness  of  the selected
operable  unit remedy.   Hie  results of this  monitoring will  also  aid  in
determining the  remedy for the groundwater operable unit.

The  institutional  controls   implemented from. Alternative  2 will  aid  in
achieving the  protectiveness to human  health and the environment.  Tne Site
access restrictions (Site fence and warning signs)  will reduce public health
risks  by  preventing  public  contact  with  buried  waste,  landfill  gases,
contaminated sediment and  surface soil.   The  Site access restrictions win
also help protect  the  integrity of the landfill cap by  limiting  vehicle
access.   The continued groundwater  monitoring will track and document  the
nature  and  extent of  contamination  migration.    Deed  restrictions will
prohibit future  Site development and the installation of  water supply wells
on and near the Site.

No treatment technologies are  being applied to reduce toxicity,  mobility or
volume of hazardous waste  with the  implementation of  Alternative 4,  so  the
permanence  of  this  interim  remedy  depends   on  the maintaining  of  the
integrity of  the  upgraded cap.  Also,  with  the  installation of the RCRA

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                                       31

subtitle C compliant soil/clay cap, leachate production is anticipated to be
reduced  by ninety percent,  thereby reducing  the volume of  contaminants
reaching groundwater and indirectly reducing the mobility and toxicity of
contamination in the groundwater.

         2.   Attainment of Applicable or Relevant and Appropriate
              Requirements of Environmental Laws.

Alternative 4 will be designed to meet all  the applicable, or 'relevant and
appropriate  requirements  (ARARs)  of  Federal  and  more  stringent  State
environmental laws.   ARARs, including maximum, containment levels  (MZLs) in
groundwater, may  be met with the implementation of Alternative 4,  but the
MZLs will not be  addressed until the conclusion  of the groundwater operable
unit.   Table 7 lists the ARARs  that apply to each of the alternatives and
the following discussion provides the details of  the  ARARs that will be met
by Alternative 4.

            a.   Feder^ 1; pgs,ource Conservation and Recovery Act

RCRA.  closure and. post-closure  requirements for  landfills  with  hazardous
wastes are outlined in 40 CFR subpart G.  Section 264.310 of RCRA, subpart
N,  specifies  the  performance-based requirements for  a cover  at  final J
landfill closure.  Tne cover in Alternative 4 will be a cap- as prescribed in
RCRA guidance and will comply with RCRA regulations.   Ine cap will minimize
migration of liquid, through the landfill, function with minimum-maintenance,
promote drainage,  minimize  erosion,  accommodate settling, and be  less than
or equal to the permeability of natural subsoils present.

After closure is completed, the substantive monitoring and maintenance post-
closure requirements contained in Section 264.117 through 264.120  of Subpart
G will be conducted.  The facility will be closed according to the standards
in  Subpart G,  Section  264.Ill-closure  performance  standards.   After the
closure activities have  concluded,  a survey plat, as prescribed  in Subpart
G, Section 264.116,  indicating location  and  dimensions of the disposal area
will be submitted to the local  zoning authority, or to  the  authority with
jurisdiction over local land use,  and  the  Regional  Administrator  and the
Michigan state Director.        ,      •&.
                                 -     •  *f
            b.   State! htezfliT'itous Waste Management. Act (Act 64)

To  the  extent  that  Act  64  is more  stringent than  the Federal  RCRA
regulation, Act 64 will be followed.

Relative to landfill  closure provisions, Act  64, Rule 619 specifies the
closure standards, including  a minimura  cover  requirement,  and  requirements
for venting, which will be followed.

            c.   Federal: Clean Air Act

The Clean  Air Act  (CAA.)  identifies  and. regulates pollutants that  could be
released during  earth-rroving  activities associated with landfill regrading
and cap installation.  CAA. Section 109  outlines  the criteria pollutants for

-------
                                        32.

which National Ambient Air Quality Standards have been established.  The CAA.
is  an  ARAR and the regulation standards will be complied with  during the
implementation of Alternative 4.

            d.   State; Air Pollution Act (Act 348)

Under  Act 348  Rule 901, the Michigan Air Quality Division  exercises its
authority to  ensure that a person does not cause or permit the emission of
an air contaminant in quantities that will cause "injurious effects to human
health or safety,  animal life, plant life  of  significant economic value or
property" or  "unreasonable interference  with the comfortable enjoyment of
life and property. "  Also , Rules  371 and 373 address fugitive dust programs
and. control  methods  for emissions of  dust  from a variety of  sources
including haul trucks, roads and stockpiles of materials.
            e.   Federa.il ; foiTT^pationrn safety and H^gJth Administration Act
                 (OSHA.)

The selected remedial  action contractor must develop and implement a health
and. safety program for its workers if such program does not already exist.
All on-site  workers must meet  the minimum training  and. medical monitoring
requirements outlined  in 40 CFR 1910.


                       f6 Coordination Act
Executive Carders 11988 and 11990 and the Fish and Wildlife Coordination Act
pertain to the protection of flood plains and wetlands and protect fish and
wildlife if the wetlands or natural streams are modified.  The provisions of
these Orders  and Act will be  implemented if during the design phase of the
remedial  action,  they are  determined  to be  applicable  or relevant  and
appropriate.

            g.   Stater Michigan Water Resources Act (Act 245)

Act  245,  Part  21  requires  that any remedial action  in which  site runoff
would be  channeled directly to  a surface water body via a ditch, culvert,;
storm sewer,  or other means shall be governed by this  Act.  The provisions
of  this Act  will  be  met at  this site  to the  extent that it  applies as
determined by the MDNR after the design stage is completed.

            h.   State! Mineral  Well Act  (Act 315)

Act  315 and the Administrative  Rules require  that test wells be permitted,
constructed property, recorded,  and. properly plugged upon abandonment.  This
Act  is an ARAR and treatment of  all test wells will be dictated by it.

            i.   State; Soil Erosion and Sediment at ion Control Act (Act 347)

Under Rule  1704  of this Act,  a  soil  erosion control and sedimentation plan
is required for  any  earth change within 500 feet of a lake or stream.  This
Act  and its Rule call  for soil erosion and sedimentation control procedures

-------
                                       33

and.  measures  to minimize  such erosion  and  sedimentation.    Hie  erosion
control  measures  along the  north  slope of  the  landfill will  meet  the
requirements of this Act.

            j.   Other Federal and State ARARs

Since  Alternative 4  is an interim/ remedy,  directly  addressing  only  the
landfill  contents operable unit, ARARs concerning groundwater, such as 40
CFR  141,  regarding MZLs, and ARARs  concerning the surface waters,  such as
the  Clean Water Act are being  deferred until a remedy is selected  for  the
groundwater operable unit.   Alternative 4  may indirectly address these other
ARAR concerns but the degree cannot be determined at this time.

All  Federal  and  State  ARARs  will be satisfied, by the final Site remedial
action  which  will be   selected  after the groundwater  operable  unit  is
complete.

         3.   Cost-Effectiveness.

Alternative 4 affords a high degree of effectiveness by providing protection
against  direct   contact  threats   and the  threat  of  releases  to   the
groundwater.    The cost of Alternative 4 is  $1.8 million  with  a  present
worth,  including operation and. maintenance,  of  $2.8  million over  thirty
years.    Alternative  4 is less  costly   to  implement and  maintain  than
Alternatives  5 and  6,   and provides protection, for human  health and  the
environment.    The  additional  costs  of Alternatives  5  and 6  can not  be
justified  at this  time since  Alternative  4  may  address  the  groundwater
concerns.  Additional  costs may be  incurred depending upon the outcome of
further  studies  at the  site  involving the  groundwater operable unit.    By
providing  a  greater reduction  in leachate  generation than Alternative  3,
Alternative   4  may  reduce  future  costs  associated  with   groundwater
remediation more than Alternative 3.

         4.   Utilization of Permanent Solutions, Alternative Treatment
              Technologies to the Maximum Extent Practicable,  and Preference
              for Treatment as a Principal Element.

Although  the selected remedy for the  landfill contents operable  unit will
reduce  leachate generation by  an estimated ninety percent, Alternative  4
does   not  utilize  any  permanent   solutions  or  alternative   treatment
technologies.    Alternative 4  is considered  to  be  an  interim remedy  to
address  the  landfill contents  operable unit, one  that will be consistent
with the final  overall site remedy.   Alternative  5  and  6 offer  greater
degrees   of   permanence  and  alternative   treatment  technologies,   but
Alternative  5  is not feasible at this time  since Alternative 4 may address
the   groundwater  contamination  concerns   that  would  be  addressed   by
Alternative  5; Alternative 6  is deemed impractical because of  the quantity
and  heterogeneous nature   of   the  landfill  contents.    Depending  on  the
effectiveness  of Alternative 4, alternative treatment technologies may be
applied as part of the final remedy at this Site.

   B»   Groundwater Operahig Unit-

-------
                                        34
TJris Record of Decision selects  a remedy to address  the landfill contents
operable unit;  this remedy calls for the  installation of an upgraded., RCRA.
compliant cap .and institutional controls.  As the selected landfill contents
operable  unit  remedy  (Alternative 4)  will  indirectly address  groundwater
concerns, the  effectiveness of the upgraded cap needs to be measured prior
to selecting a  remedy to address the groundwater operable unit.  Alternative
4  indicates  that  four additional  groundwater  monitoring  wells will  be
installed to help define the geological conditions at the Site.   A. total of
twenty monitoring wells will be sampled on a semi-annual basis.

To  enable  a  final  remedy  to be  selected  for  the Site,  the  remedial
investigation regarding the groundwater operable  unit needs to be continued
until the effectiveness of Alternative 4 can be measured.   TO fully evaluate
the effectiveness of Alternative  4 and to establish enough justification to
select a remedy for the groundwater operable unit, further monitoring of the
twenty groundwater  monitoring wells,  as noted above,  will be conducted,  as
well as, the further monitoring of residential wells, gas vents, and surface
water and sediments within the wetlands, Rabbin  Pond and Iris Creek.   To
enable  a  most  current baseline of  groundwater contamination  and site
conditions,  and. to  provide continued  protection of  human health and the
environment,  the groundwater  operable unit monitoring program will  begin
prior  to the  design  and  construction of  the  RCRA. compliant  cap.    The
specific  requirements  of  the  continued remedial  investigation for  the
groundwater operable unit will be established during the design stage of the
selected landfill contents remedial action.

XL.   STATE ISSUES

The Michigan Department of  Natural Resources  (MNR) has concurred with this
Record  of  Decision  (ROD).    This   concurrence   is   conditional  upon  the
incorporation  of their concerns  and  comments  into this PCD as  stated  in
their September 13, 1988 letter to the U.S. EPA.   (See Attachment 1)

These concerns and  comments have been addressed  in this ROD  or will  be
addressed during the design phase of  the project,  as noted in the letter of
September 20, 1988 from the U.s: EPA, to the M3UR (See Attachment 2).

xii.  sun&Kf

Considering the various evaluation factors in  SARA Section  121 (b) and the
National Contingency Plan, selecting Alternative 4 for the landfill contents
operable unit  and  the deferring of the  selection  of a remedial alternative
for the groundwater operable unit until the effectiveness of Alternative 4
can  be  measured,   offers   a  cost-effective  solution to the  contaminant
problems at the Site.   Alternative 4  either  satisfies the Federal and State
ARARs or defers them until a  final remedy is selected after the conclusion
of the groundwater operable unit.

Alternative 4 is an interim remedial  action that  is consistent with a final
remedy for  this site and provides adequate  protection of human health and
the environment.    Another  Proposed  Plan and  Record of Decision will  be

-------
                                       35

issued at the conclusion of the ongoing remedial investigation involving the
groundwater  operable  unit to  announce and  select a final  remedy for the
Mason County Landfill.

Ine cost of  Alternative 4 is $1.8 million, with a present worth,  including
operation and maintenance, of $2.8 million over thirty years.   The  cost of a
final remedial action can not be fully determined until a remedy  is chosen
to address the groundwater operable unit.

-------
                                      ATTACHMENT 1


                                      STATE OF MICHIGAN

JUMAL mSOUNCeS COMMISSION
THOMAS J. ANDERSON
MARLENE J. FLUHAflTY
KERRY HAMMER
6. STEWART MYERS                                                             i I
OAVIOO.PLSON__                        JAMES J. BLANCHARO, Governor             ' 'J'

                         DEPARTMENT OF NATURAL RESOURCES
                                      STEVENS T. MASON BUILDING
                                           8OX3002S
                                         LANSINO. MI 4*atm                   ','r«
      .                                    .          ,                    ,  .     .,,     ,-  -„
  RAYMOND POOPORE                                                            ' .7 J  "*  W  !4  1 JV7
                                                                        -0        -*  U J
                                 David F. Hales, Director


                                                    September 13,  1988
           Ms. Mary Cade
           U.S.  Environmental Protection Agency
           Remedial and Enforcement Response Branch
           SHR-li
           230 South Dearborn Street
           Chicago, Illinois  60604

           Dear  ilia. Gade:

           The Draft ROD received August 17, 1988, regarding the Mason County
           Laudflll site in Ludington, is conditionally acceptable.   I would  like  to
           have  the following concerns and comments incorporated into the  final ROD
           as uhi  State's response for this site.

           1.  The proposal to fence the entire site does not  seem practical  given
               the limited potential for exposure to contaminants.  We prefer that
               alternatives to fencing such as landscape modifications or  some
               other reasonable alternative be considered prior to the selection of
               fencing.

           2.  There should be institutional controls provided such as deed
               restrictions or restrictive covenants to assure that land uses are
               controlled.

           3.  Groundwater monitoring as part of the deferred  groundwater  operable
               unit should be funded and initiated prior to design and construction
               c*  the RCRA compliant cap.  Monitoring data should  enable the
                involved agencies and PRP's to better evaluate  the  effectiveness of
                the cap by providing current background conditions  at  the site.

           4.  CTI  page 25, add as a potential problem the fact that subsidence has
               already caused the cap to fall.  A drainage system  such as  perforated
               pip-; would fall if the clay layer below it subsides.

           Finally, the State of Michigan encourages EPA to pursue PRP involvement
           by using all means available including issuing a Section 106
           Administrative Order to all viable potentially responsible parties.
R1026

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Ms. Mary Gade
Page 2
September 13, 1988
Attached is a letter to Mr. Dan Cozza regarding the State's position
concerning the Proposed Plan received July 19, 1988.  Please let me know
if you have questions.
                                        Sincerely,
                                        Gary B^Jfuenther, Chief
                                        Environmental Response Division
                                        517-373-4823
Attachment
cc: --/Mr. Dan Cozza, U.S. Environmental Protection Agency
     Mr. William Bradford, Acting Chief, Remedial Action Section
     Mr. Peter Ollila/Mr. Bill Herceg/Mason County Landfill file

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                                   ATTACHMENT 2


^'^^\    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
*  ^^  1                          REGIONS
         r *                   230 SOUTH DEARBORN ST.
         ^                     CHICAGO, ILLINOIS 60604
                                                                   REPLY TO THE ATTENTION OF:

    SEP 2~0 1385

Mr. Gary E. Guenther                                         5HS-11
Michigan Department of Natural Resources
Stevens T.  Mason Bldg.
Box 30028
Lansing, Michigan   48933

RE:  Mason  County Landfill ROD

Dear Mr. Guenther:

Thank you for your concurrence on the Mason County Landfill  Record of
Decision (ROD).  It is understood that this concurrence  is  conditional.
upon the incorporation of your concerns and comments  into the ROD, as
addressed in your letter of September 13, 1988.   As this letter addresses
those concerns and indicates how your concerns have been or will  be
addressed,  it is assumed that your conditions of concurrence have been
met.

Below are your concerns followed by the U.S. EPA's response.

1)  MDNR concern:
    Alternatives to fencing the entire site should be considered.

    U.S. EPA response:
    The sentence, "Alternatives to the site fence  will be considered
    if they are determined to adequately protect the  landfill  cap
    integrity and keep trespassers away from the area of the on-site gas
    vents", has been added to the Alternative 2  (site restrictions)
    description in Section VI-B of the ROD.  Alternative 4  (the chosen
    alternative) uses the site restrictions as described within
    Alternative 2.

2)  MDNR concern:
    There should be institutional controls provided such as  deed
    restrictions or restrictive covenants to assure that land  uses are
    controlled.

    U.S. EPA response:
    Deed and zoning restrictions are mentioned in  the description of
    Alternative 2 within Section VI-B of the ROD.   These restrictions
    pertain only to site property use, while off-site property
    restrictions may be necessary in the future.  Because there is no
    federal  authority to implement deed or zoning  restrictions, state and
    local governments would have to be coordinated with  to  pursue these
    options.

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3)  MDNR concern:
    Groundwater monitoring as part of the deferred groundwater operable
    unit should be funded and initiated prior to design and construction
    of the RCRA compliant cap.  Monitoring data should enable the
    involved agencies and PRPs to better evaluate the effectiveness of
    the cap by providing current background conditions at the site.

    U.S. EPA response:
    The sentence, "To enable a most current baseline of groundwater
    contamination and site conditions, and to provide continued
    protection of human health ancL the environment, the groundwater
    operable unit monitoring program will  be initiated prior to the
    design and construction of the RCRA compliant cap" has been added to
    the last paragraph in Section X-B of the ROD.

4)  MDNR concern:
    It should be mentioned that another implementation problem associated
    with Alternative 4 would be that since subsidence has caused the
    present cap to fail, subsidence of the new clay cap will cause any
    drainage system, such as perforated pipe, to fail.

    U.S. EPA response:
    This concern has been noted within the description of Alternative 4
    implementation in Section VI-B of this ROD and will be reviewed
    during the design phase.

5)  MDNR concern:
    The State of Michigan encourages EPA to pursue PRP involvement by
    using all means available including issuing a Section 106
    Administrative Order to all viable potentially responsible parties.

    U.S. EPA response:
    Special Notice Letters for RD/RA negotiations have already been sent
    to six PRPs on August 24, 1988.  if the negotiations are not
    successful, other means of enforcment will be considered.

If you have any questions or further comments regarding this letter or
the Mason County Landfill ROD, please let me know.


Sincerely,
Mary A. Gade
Acting Associate Director
Office of Superfund

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                                    -3-
cc:  0. Cozza, WMD
     M. Radell, ORC
     B. Herceg/P. OTIila, MDNR

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                         ATTACHMENT 3
                   RESPONSIVEHESS SUMMARY

                   MASON COUNTY LANDFILL
                   MASON COUNTY, MICHIGAN
The  U.S.  Environmental  Protection  Agency  (U.S.  EPA)  has
gathered   information  on.  the   types  and  extent   o'f
contamination found,  evaluated  remedial measures,  and  has
recommended  a  remedial     action   at   the  Mason  County-
Landfill.    As  part of  this  process, a public  meeting  was
held to explain the intent of the project,  to describe  the
results, and to receive comments from, the public.

Public participation  in Superfund projects is  required in
the  Superfund  Amendments and Reauthorization Act  of  1986
(SARA).   Comments  received  from the pub-lie are considered
in the selection of the  remedial action for the site.   The
Responsiveness Summary serves two purposes:   to provide  the
U".S. EPA  with  information about community  preferences  and
concerns  regarding the  remedial  alternatives and  to  show
members   of  the  community  how   their  comments  were
incorporated into  the decision making  process.   Comments
regarding information  specifically  contained, in  the RI/FS
are  not  addressed in  this  Responsiveness  Summary  as  this
information  is  contained  in  the  reports available  for
public viewing at the Ludington Library.

This document summarizes  the oral comments  received at  the
public  meeting  held  August 17,  1988,  and  the  written
comments  received  during the public comment  period August
8, 1988 to August  31,  1988.  Each comment is  followed by a.
letter which  refers  to  the  originator(s)  of  the comment.
Please  refer  to  Appendix  A   for   a   complete  list   of
respondents.  The Responsiveness Summary addresses concerns
in the following general areas:

     1.  Design concerns.

     2.  Implementation concerns;^

     3.  Environmental Impact/Risk Assessment concerns.

     4.  Funding concerns.

     5.  Property value concerns.

     6.  Notification period and response time concerns.

Individual  comments  have been  summarized  and grouped in
these  six general  areas.   U.S.  EPA responses  follow  each
comment.

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     1.  Design concerns

l.a.  Comment

The north  end of the landfill was exposed, at  one  time and
just covered over.  There  is  no  cap to upgrade,  or repair.
How will that be dealt with?   (see A. in Appendix A)

l.a.  Response

The specifics  of the  cap  will  be  examined in  the design
stage of the  remedial  action.   If there was no  cap in one
section,  Alternative  4  suggests  the  cap  be a  specific
uniform thickness throughout,  so a new  cap would  be built
in that area.

1.b.  Comment

Has a permeability  test  been  done on the existing landfill
cap since  the existing  cap will be incorporated  into the
Alternative 4 clay cap?  And,  if the existing clay cap does
not meet RCRA requirements, will this alter the quantity of
clay and the cost of the remedy?  (E)

l.b.  Response

Permeability tests  were  not conducted on the  existing cap
during the  RI/Fs.   It  is  possible that the  existing clay
may have to be reworked and that more clay than estimated
may  be  needed,  increasing  the estimated  cost.    These
questions will be addressed as part of the design phase.

I.e.  Comment

The design  of  the soil/clay cap for the landfill specifies
the placement of  1.5  feet  of  topsoil  and fill  material
above the  geotextile  fabric.   Depending upon  the  depth  of
the frost  line  in the  area, this depth may be insufficient
to permit  the  permanent  establishment  of soil invertebrate
populations,  particularly  earthworms.   This  in  turn may
hamper the viability of a permanent vegetative cover on the
cap.   It  may be necessary to  increase  the  depth  of the
topsoil  and  fill  layers  so  as  to  create  a  suitable
environment for the soil amending invertebrates.

A  permeability rating of  10~7  cm/sec  is  expected  of the
clay layer  in  the soil/clay layer,  provided the  clay layer
is protected  from  the  frost  and wet/dry  cycles.    Is the
three feet  of topsoil,  fill,  and sand to be  placed above
the  clay  layer  sufficient  protection in  this  area  of

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Michigan?  Additional material may be  necessary to provide
adequate protection for the clay layer.  (L)

i.e.  Response

Both of these comments will be addressed, in  the pre-design
and design phases of the remedial action.

l.d.  Comment

The RI report indicates  that  surface runoff/percolation of
precipitation will be collected  from the soil/clay cap and
discharged  to  Iris Creek.    Under  pristine  conditions,
surface water runoff and groundwater recharge  at  the  site
would  discharge  to and  sustain the  wetlands  adjacent  to
Babbin Pond.   Removal  of  this  water source, coupled  with
possible  future  extraction of  groundwater  for treatment,
threatens to  "dry up"  the wetland  area, as  identified in
the  FS study.    One  way  to minimize this  impact is  to
redirect the collected  surface runoff/percolation waters to
the  wetland  area  rather  than  to   Iris Creek,  which  is
further downgradient.  Of  course, this would be contingent
upon the  collected water  being free  of contamination  as
expected.   (L)

l.d.  Response

This will be  addressed  in the pre-design and design phase
of  the Remedial  Action.   The discharge will  comply  with
state NPDES regulations.

     2.  Implementation Concerns

2.a.  Comment

How  long  would  the responsible parties  be responsible  for
anything  that  might pop up,  even after   a thirty  year
period?   (F)             .•  '  •   -

2.a. Response

This varies  on  a case  to  case basis,  but   it  is  usually
resolved by a cooperative agreement,  or consent  Degree that
will   be   established   between  the   U.S.   EPA  and  the
Potentially Responsible  Parties  (PRPs).   In  some cases,
monitoring may be done  by the PRPs,  the MDNR, or even,  on a
local level, by the Public Health Department.

2.b.  Comment

How will  the  problem of subsidence  and maintenance of  the
cap be dealt with?  (E)

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2.b.  Response

The subsidence factor will be an important consideration in
the Remedial  design  and action  portion of the remedy.   The
design will take  into  account the  settling of the cap that
has occurred  in the  previous capping action.   The cap will
also be monitored, and repaired when necessary.

2.c.  Comment

Rather than fencing around the landfill, the county request
that  U.S.  EPA consider planting  trees,  shrubs  and other
vegetation that will accomplish the purpose of restricting
entry to the  landfill.    (H)

2.c.  Response

The main  purpose  for installing a  fence  at the site is to
protect the  integrity  of the cap  by preventing pedestrian
and vehicular traffic  across  it  and to  keep trespassers
away from the gas  vents.  A "shrub- fence"  would not be as
effective of  a barrier  as a chain link  fence.   However,
alternatives  to a  chain link fence may still be discussed
during the design stage of the project.

2.d.  Comment

I would  like to express my feelings  about the closing of
the landfill.   I  am a  resident of the area  and am. in the
process of buying a  home at 5745 Iris Street.   I feel very
good  about  Alternative  4.    I  am.  satisfied  that  the
recommenced' solution,  from what was said at the meeting at
the Town  Hall on August  17, 1988,  is the best  way to go.
(J)

2.d.  Response

Comment noted.

2.e.  Comment

The Pere  Marquette Township Board, wishes to  go  on record
recommending  that  Alternative  5 rather  than  Alternative 4
be  implemented  by  the  U.S.   EPA,  since it includes  a
groundwater collection system and an bnsite water treatment
plant.    We   feel   very  strongly  that  the  groundwater
contamination  problem  must   be  addressed  and   that
Alternative 4 is  an inadequate  plan of  action  because it
does not address the groundwater problem.  (K)

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 2.e.   Response

 The   U.S.  EPA.  believes  that  more  information  regarding
 groundwater  contamination is needed  before  a decision can
 be  made  on a  groundwater remedial  action, such  as more
 information  on  the concentration  of contaminants  in the
 groundwater  and  on  the  relationship between  the groundwater
 and  the surface water.    In addition, the effectiveness of
 the  soil/clay cap of Alternative 4 must be measured  before
 resources  are expended  on a pump and  treat system.  Testing
 indicates  that  the soil/clay cap  will  reduce the  leachate
 generation within the  landfill as  much  as ninety  percent.
 This   will  in turn decrease the   amount  of contamination
 reaching  the  groundwater and  therefore,  in  the  future,
 contaminants in  the  groundwater may be dilute  enough to
 fall  below federal drinking water  standards and acceptable
'risk  levels.

 By  separating the  remedial action at  this  site  into two
 separate  operable  units,  one  addressing  the   landfill
 contents and one addressing-the groundwater,  the U.S. EPA
 can   implement   the   remedial   action  for  the   landfill
 contents,  a remedy  that  is  consistent with the   final
 remedy,  while investigating the options needed to address
 the groundwater  concerns.   This is the  most cost effective
 approach for the remedial action at the  site.

 2.f.   Comment

 Considering  the  known contamination of environmental  media,
 the U.S.  Fish and Wildlife Service  recommends that  selected
 organisms   in  Babbin.  Pond,  Iris  Creek,   and  associated
 wetlands  be  collected   and   analyzed   as   part  of  the
 monitoring program for the two  operable units.   This will
 permit the  identification of  actual risks  to  aquatic and
 wetland biota,  and,  if actual  risks are  found,  provide a
 means to  assess  effectiveness of the  selected   remedial
 actions through  the  life ;of thef: monitoring program.  The
 Service is  willing to provide  assistance  in establishing
 this  program to  monitor biota.   (L)

 2.f.   Response

 Your  recommended additions to  our monitoring program will
 be  taken  into consideration during the  development  of the
 monitoring  program  established   to  assess the   landfill
 contents  operable  unit   and  to  further investigate the
 groundwater  operable  unit.

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2.g.  Comment

A.  limited number  of  surface water  and sediment  samples
should be reanalyzed for the trivalent and hexavalent forms
of 'chromium,  so  as to confirm the  assumed  predominance of
the less toxic trivalent form.  (L)

2.g.  Response

Please see Response 2.f.

2.h.  Comment

I am  wondering if the consultant had a  vested interest in
future  work  being  accomplished  on  this site and  I  ask,
"does the  investigative  consultant  proceed  with the design
of  any  remedial actions?"   If this  is  the policy  of the
agency, that  I believe that there  exists an opportunity to
unconsciously  prejudice the  report  and its  conclusions.
While this  may not  be the case,  I found  the table which
listed  all  of the organic  contaminants  found  at  the  site
impressive, but  misleading, as ninety-five  percent  of the
compounds  listed  were  found in either soil samples  or air
samples from the existing methane vents.

These two  sources were  found to  have assessment  risks of
5xlO~10  for  soils  and  2xlO~7  to  trespassers  and  not
quantified or non-detectable to residences with 400 feet of
the source of the bents.  The listing of these contaminants
was misleading without clarification of some kind.   (N)

2.h.  Response

Initially, the U.S. EPA offered the PRPs the opportunity to
conduct the RI/FS, but since  no  agreement was reached, the
U.S. EPA. had its contractor conduct the studies.  While the
contractor  conducted  the  investigation  and  compiled  the
RI/FS  reports,  the  U.S.   EPA in  consultation  with  the
Michigan Department  of Natural Resources approved the work
plans and  the RI/FS  report  and selected  the alternative to
best  remedy the  problem following  established criteria and
guidelines.

The PRPs  will have an opportunity  to design and implement
the chosen remedy if  an agreement  can  be  reached  during
RD/RA negotiations.   If they decline it is  possible  that
the same  U.S.  EPA contractor could be  awarded the  design
and  remedial  action  phases, although, usually,  in  the
absence of  a  settlement with the  PRPs,  the Army  Corps of
Engineers conduct this phase.

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In response  to the comment on  the table of  contaminants,
reports  of  industrial  sludges   and   liquid wastes   are
documented in site project  files.   They are  not highlighted
other than to indicate past disposal practices at  the site.
Table 3-3 of the RI report is  useful  as a catalog of  all
contaminants found onsite and. their  respective media.   The
table reports the facts about  the  site.   The interpretation
of these facts  is presented in the risk assessment.

     3.  Environmental Impact/Risk Assessment Concerns

3.a.   Comment

What type of contaminants are  in the landfill? How  much of
a threat are they to the aquifer?  HOw  persistent are they
in both the aquifer layers  and in  the landfill, assuming we
terminate the leachate with a cap?  Is there direct  contact
between the  aquifer layer and what is in. the landfill now?
(B)

3.a.   Response               -

The wastes  found are similar to  those found in  paint  and
plating   wastes  such  as  solvents   (benzene   and  1,1-
dichloroethene)  and  heavy  metals   (lead,  arsenic   and
chromium).     Two   contaminants,  benzene   and  1,1-
dichloroethene,  have  been  found  in  levels  exceeding  the
drinking  water  standards  in  the  upper  aquifer  near  the
landfill.   The  proposed  landfill cap  should decrease  or
eliminate these concentration  levels.

Groundwater concerns will,  however, be addressed after more
investigation  is  performed.    Based  on  historic  aerial
photographs, soil borings, and  present  water levels, we do
not believe the waste is sitting within the  aquifer.

The  groundwater operable  unit  will  address the drinking
water  standards,  and.  the  Applicable  or  Relevant   and
Appropriate Regulations (ARARs).

3.b.   Comment

What  will  the  cap  do  to prevent  contamination  of   the
springs in the area?  (C)

3.b.   Response

The cap addresses the downward percolation of the  leachate;
it does not address the lateral  movement of  the groundwater
underneath it which flows to the north.   However,  since  the
cap will  prevent leachate  generation, and  the springs  are

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                                8

outside the  immediate  area anyway,  there  is no reason  to
expect them  to  be fed by anything other than  just  natural
groundwater.

3.c.  Comment

When  you  state  that  benzene  and  toluene  are   in  the
landfill, what  are  they contained in?  Are  they in drums,
and  if  so,  when  these  drums  deteriorate,  will a cap keep
the chemicals from reaching the groundwater?   (D)

3. c.  Response

The  records  available for  the landfill indicate that  the
industrial wastes were in the form of sludge  or liquid that
was disposed of  in  bulk within drying beds and later mixed
with the  refuse.   The landfill cap  in  Alternative  4, with
its  drainage features,   will  alleviate  the  percolation  of
water  through  the  landfill  and.  the contaminated  wastes
whould   therefore  remain  within  the confines   of  the
landfill.

3.d.  Comment

The FS appears to take a rather limited view  of the  role of
Executive Orders  11988  and  11990  and the Fish and Wildlife
Coordination Act  at the  site.   For example,  the FS  implies
that only vegetated wetlands  are covered under Executive
Order 11990.   The  Service  would classify  Babbin Pond  and
Iris Creek as  open-water wetlands and  include  these areas
under the authority of  the  order.   The  Coordination Act  is
also interpreted to apply solely to  modification of flows
on  Iris  Creek.    These statutes   should,  be  re-examined
regarding their applicability to the site.   (L)

3.d.  Response

If  Executive  Orders  11988 and  11990 and  the  Fish  and
Wildlife  Coordination  Act   are  deemed  relevant  and
appropriate for the Babbin Pond and/or Iris Creek wetlands,
the regulations will be applied to the site.

3.e.  Comment

At this time, we object to  the remedial action proposed  by
the FS and the  proposed. Plan  to the extend that the chosen
alternative  is  inconsistent   with  CERCLA  and  other
applicable laws  or  regulations,  and. further, to the extent
that the  alternative  is not warranted by actual conditions
at the site.   (M)

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3.e.  Response

The U.S. EPA believes that Alternative 4 is consistent with
CERCLA  and other  applicable  laws  and  regulations.    The
groundwater contamination at and near  the  landfill  and the
presence of contaminants  in  excess of  the  Federal drinking
water standards warrant CERCLA action.   While Alternative 4
does not directly address the groundwater contamination,  it
is consistent  with  any final remedial action that  will  be
implemented at the  site.    In addition,  the presence  of
hazardous substances in the site requires a RCRA subtitle C
landfill closure.

3.f.  Comment

Part of  the investigative work seemed  either  inconclusive
or  in  need of  further  study.    In  particular,  was  the
electromagnetic  portion  which  only   suggested possible
plumes, the gamma  ray logging of existing wells which was
intended  to confirm existing  well   logs,  and  the  purge
testing  of  the   aquifer  which   gave  values   of  the
coefficients of transmissivity of  between  20,066 gpd/foot
and 348,654 gpd/foot.   In my opinion,  this  range of values
is  not  usable  for   aquifer  characterization,   or  for
conclusions to be  based upon,  although this  information
would  be  needed   more  for   the  remedial  action  of  the
groundwater than for the feasibility study.   (N)

3.f.  Response

The  EM  survey detected,  a  zone  of  elevated  electrical
conductivity in the area  directly  north of the  landfill.
There is a buried metal pipe in this  vicinity that may have
caused the  elevated readings.   It is possible that  a thin
layer of  clay, characteristic of the  site's  stratigraphy,
could  have  caused  the  elevated   conductivity.     Since
contaminants were  detected  in well  MW07 which  is  located
north of the landfill,  the  report concluded that there was
a contaminant  plume migrating to  the north and northwest
from the landfill.

Gamma  log  data corroborated the  stratigraphy of existing
logs  (of wells that were not installed as part  of  the Rl)
and provided data  for  wells  without recorded logs.   Well
logs were  used to  develop the site  stratigraphy which was
used to interpret  aquifer characteristics.

Based on the  information presented in Table B-l of  the  FS
report, the transmissivity of the upper aquifer ranges from
260  gpd/foot  to   12,000  gpd/foot.     The  transmissivity
depends  both  upon  aquifer  thickness  and  hydraulic

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                               10

conductivity, but the variation of hydraulic conductivities
is   responsible   for   most   of  the   difference   in
transmissivities at  this  site.    Hydraulic  conductivities
can and  typically  do  range several orders  of magnitude for
different  points  within  the  same aquifer,  and the  data
obtained  in  the  RI  fall  within  this range.    For  all
calculations  involving  groundwater  flow  or  groundwater
collection, the range of hydraulic conductivities was used.
This  was   intended   to   provide  a  reasonable  range  of
contaminant migration velocities and groundwater collection
rates.   The sensitivity of the  groundwater  collection and
treatment alternative to  the  range of collection rates was
provided as parj: of the cost estimate in the FS.

3.h.  Comment

The report  identifies the various vehicles  from, which the
public could come into  contact with pollutants from the
landfill  and then assesses the risk  of  this  contact  by
calculating  the probability  of a  death  caused by  this
exposure.   A more complete "discussion of Risk Assessment
could  have  been  accomplished  so  that  the  readers  could
understand risk assessment and its effect on what should or
should not  be  accomplished as  far  as remedial  action  is
concerned..   From.  Table  1-1 the following  are summarized
with comments:

VEHICLE FOR EXPOSURE

Drinking water  off-site  - The exposures for this category
were determined from two sampling events of two residential
wells off-site.   In  the  first phase  (Nov.  1986) detection
of  two   organic  compounds  were   found   which  gave   a
probability  risk of  3xlO~6 and 7xlO~7.   These  two  wells
were  replaced  by  deeper  wells  and  the  second phase  of
testing  (Dec. 1987) found these and other organic compounds
to be non-detectable  and  having  a  risk of  zero.  Recently,
the EPA.  determined that,, simply-speaking,  landfills should
pose a health risk of no  more  than 1  in 10,000,000  or
IxlO"7.    It  is  seen  from  this  that this vehicle  for
exposure  is  not a particular problem  for  this landfill  in
its existing geologic setting  and  is  above EPA's published
expectations for landfills.

Drinking  water  on-site  -  This  vehicle  assumes  that  a
drinking  water  well  will be placed  on-site and used for
potable water purposes.   The  risks for this occurrence are
between  IxlO"3  and 2xlO~5 for the  upper aquifer and 2x10 °
for  the  lower  aquifer.    These  assessments   are  from Well
No.7 which  contained  benzene  and Well OWAI which contained
1,1-dichloroethane during the phase one testing.. This is a
real risk,  one  that cannot be ignored.   However, it should

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                               11

be tempered  with the knowledge that  the chance of a  well
being drilled on site is nil.   The county owns  the  site and
understands  the  ramifications  of  a well  being  drilled.
Intelligent use  of  deed restrictions would prevent a  well
from being drilled on this site.   If a well  is  not  drilled,
then the risk: is zero.

Surface water - Not quantified, no levels to report, and no
risks.   This  vehicle  is well beyond  EPA. standards  and
should  become  one  of the  most   important  yard sticks  of
determining a course  of  remedial  action,  and to what degree
the existing cap is to be addressed.   (N)
        "•
3.h.   Response

A. complete discussion of the methodology,  assumptions  and
results  of   the   risk  assessment,  including   numerous
references to published  documents,  is  provided in  Appendix
H of the RI report.

Existing residential wells downgradient  of  the landfill do
not currently  pose  a health  threat  to  receptors.   Since
contaminated  wells  were  abandoned  after   Phase   1,   the
sampling point was  not available  in Phase II.   The aquifer
could,   still  be  contaminated  at   that location.     The
hydrogeologic   setting  of   the  site  indicates   that
groundwater in the  upper aquifer  flows beneath the site to
the  north  and  northwest  in  the  direction  of  off-site
residential  wells.     Also,  groundwater  from  the  upper
aquifer has  a  pathway to the lower aquifer.   Trace levels
of volatile  organic compounds were detected in monitoring
wells screened  in the lower aquifer along  Inman Road,  and
an excess  lifetime cancer  risk of 7xlO~°  was determined.
There is  a potential for  contaminants to migrate to  off-
site residential wells.

It is not possible to predict  the  future  use of the site or
ensure that drinking supply wellsVwili not be installed on-
site.    The  aquifer  is  contaminated  above   established
federal  and  state  limits,  and future  contaminant levels
cannot be predicted.

Surface water bodies on or near the site  are not considered
to be sole  indicators of groundwater contamination at  the
site.   Much of  the  health  risk  that was  determined  for
exposures  to  groundwater at  the  site  results  from  the
presence  of  volatile  organic compounds   (VOCs).     These
compounds volatilize upon contact  with  air.   Thus,  they
would   not   be   detected  at  concentrations  that   are
representative of the groundwater  after it discharges  to
the wetlands and  Iris Creek.   Also,  all  of  the groundwater
that flows beneath  the  landfill  in the  upper  aquifer  does

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                               12

not discharge  to  t^he wetland or Iris Creek.  Rather,  some
groundwater migrates  to  the north and northwest, and  some
migrates to the lower aquifer.

3.i.   Comment

Supposedly, the report does  identify  two  separate operable
units which need to be addressed and they are one; landfill
contents and two;  groundwater,  on site.   Based,  on  results
within the report,  I  believe that  these conclusions should
be questioned.

Based  on computer  modeling results  presented  in  the  RI
report,  it seems  that  the landfill  contents   are not  a
problem  as a  single  source of  contamination.   Further,
since  the  leachate  discharges  to surface  water  and  the
surface water  risks  are  zero under current  conditions,  the
landfill contents are not a risk. (N)

3.i.   Response

The  site was  separated  into  the landfill  contents  and
groundwater operable  units  because  these  are the two media
onsite  with  contaminant  levels  high enough to threaten
public  health  and  the  environment.   Operable  units  for
surface  water,  surface  soils,   and.  sediments  were  not
included because  risk associated  with  exposures to  these
media are low.   Also, it is anticipated that remediation of
the other operable units will reduce the  contaminant levels
of these media.

The computer analyses done  in  the RI used  approximate  and
idealized   models   of  the   existing   aquifer  system.
Assumptions of the  models were presented  in the  RI  report.
Two models were investigated,  one representing  a.  slug of
contamination,  the  other representing a  continuous  source
of contamination.   Based on the results of the analyses, it
was concluded that a slug of contamination is not likely to
cause  exceedance  of  maximum contaminant  levels  (MCLs)  or
aquatic  water  quality criteria  (AWQC).   However,  it  was
also concluded that  continuous loading of small  quantities
of  contaminants  (2  x  10-3 to  7  x  10-4  gpd)   to  the
groundwater could cause exceedances for MCLs and  AWQC.   The
intent of  the  analyses was not  to  specifically  predict or
quantify aquifer contamination.   Instead,  it indicates that
continual  leaching  of contaminants to  the   groundwater  is
more likely  to cause problems in  the aquifer than sudden
releases.

Using   the   surface  water   to  indicate  groundwater
contamination  at  the  site  was  discussed in the previous
comment.     Surface   water  is   not  considered   to   be

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                               13

representative of  the groundwater^.   Although,  the health
risk   associated,  with  exposure  to  surface  water   are
anticipated to be low, they are not quantified.  This does
not signify that such risk is  zero.

Based  on  the data generated  in  the  RI,  the   landfill
contents  are  currently  causing  the  aquifer  to  be
contaminated to levels that exceed MCLs for  benzene and  1,1
dichloroethene.  For this reason,  the landfill contents  are
a threat to public health and the  environment.

3.j.   Comment

The estimate of leachate  generation should  be reevaluated.
The long-term  ability  of the drainage layer  in the soil-
clay cap to  drain excess water is doubtful, and a surface
layer  cap would  be more advantageous  because  of easier
inspection and maintenance. (N)

3. j.   Response

Leachate  generation  was  estimated  according  to water
balance   procedures   outlined  in  EPA. guidance.     The
calculations  and  necessary  assumptions  are  presented in
Appendix  A  of the  FS  report.  All  three  capping  options
(i.e.   existing cap,  regrading and revegetating, and soil-
clay cap) were evaluated using the same runoff coefficients
of 20%  (summer) and 15%  (winter).  The  runoff  coefficient
was selected based  on  surface slope and vegetative cover,
form published data (Handbook of Applied Hydrology, Chou,
1964,   p.  14-8).   After visual examination  of the  existing
cap it was estimated  that runoff for existing conditions
could,  be reduced  about 25% because of landfill subsidence
that  has created  ponded  areas  and loss  of slope.    The
resulting  water  balance  calculation  gives  an estimated
infiltration of 5.2  inches/year.   If the 25% reduction is
not  applied,  the  resulting  infiltration  would   be   4.7
inches/year.    This does; not  'significantly  change  that
percentage  of   reduction   associated  with   each   cap
improvement.

The ability  of the soil-clay cap at reducing  infiltration
is partially  dependent  on the  drainage layer  to remove
water.   Subsidence  is  a problem and the final  design win
have to  take it  into consideration.   Slopes might  need to
be  exaggerated  to  reduce  the  effect   of  subsidence,
differential  settlement   could  be  monitored  to   indicate
where   subsidence   is  occurring   (to  indicate  where
maintenance may be needed), and different materials besides
sand and drainage pipe might be need (e.g. geodrains).

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                                14
3.k.  Comment

I  believe two  questions should be  asked and  answered as
simply as possible before proceeding with a remedial action
project.   First  -  is  the  affected,  aquifer  (the  upper)
available now  and in  the  future as a  source for drinking
water?   The  answer  is no.   And  secondly  -  In this area is
it  economically  feasible  to  locate  a  usable  source  of
drinJcing  water?  The  answer  is  yes, as  documented  by the
re-drilling  of two  residential  wells, mentioned earlier.
Based  on these answers, I  do  not  believe  that remedial
action .of the  ground water  is currently needed or apparent
based, upon the  performance of the existing cap and the risk
assessment  given  to  the   surface   waters  and  off-site
drinJcing water  aquifers.

I also believe that  the public can be protected by fencing
this  site,  passing  deed  restrictions  (if  not  already
accomplished)  and by  continuing to  monitor  the site.   I
also feel  that the  cap should be maintained on a regular
basis  and  believe  that  the  MCDPW  has  the  staff  and
experience to  accomplish this function and  suggest  that a
modified  Alternative  Number  2  be  accomplished to  that
effect.  (N)

3.k.  Response

Even though  there are  no drinJcing water wells  within the
upper aquifer  right  at the  landfill, a number of residents
around  the  area  still  use  the upper  aquifer  for  their
drinJcing water supply.   Although no  residential wells are
presently contaminated, the potential for the contamination
to migrate away from the landfill  and to these residential
wells is real.

It is  economically  feasible to  utilize the  deeper aquifer
for an  alternate  drinking water supply,  as  some residents
have done.   However, the existing cap is not effective at
reducing  infiltration,  contaminants  are present  in  the
aquifer  immediately  downgradient of  the landfill and the
potential exists  for contaminants  to migrate offsite.   The
RI report  has   shown  that  the upper aquifer  does intermix
with the deeper aquifer, so  the potential  does exist that
if the  contamination  of  the upper  aquifer  continues, the
deeper aquifer also  would become contaminated.   To achieve
the  protection  of   human   health  and  the  environment,
Alternative  4  was chosen as  an  interim  remedy  because it
will secure  the landfill contents better than  the present
landfill  cap,   and   therefore  help  reduce  the  amount  of
contamination  reaching the groundwater.

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                               15

     4.  Funding concerns.

4.a.  comment

Who is going to pay for the clean up?  (E)

4. a.  Response

The  Potentially  Responsible  Parties,   PRPs,   will  be
ultimately responsible.  U.S.  EPA will not,  however,  wait
for  the  case  to be  settled if  we can  not negotiate  an
agreement.   We will  go ahead with the  remedial  action and
attempt to recover the costs later.

4. b.  Comment

The  county  recommends  that  EPA   carefully  review  its
estimates  of the  cost for  remedial Alternative  4.   The
county believes that the cost estimates are unrealistically
high. (H)

4.b.  Response

The cost estimates are order-of-magnitude estimates with an
expected  accuracy  of  +50%  to  -30%.     cost  estimating
references and  assumptions  are presented  in the FS report.
The  cost  estimate  is  intended  to  help  in the  decision
making process  by estimating budget requirements  for each
alternative.   If costs are inflated or deflated "across the
board" for each alternative, the relative effect is minimal
and the decision making process is not prejudiced.

4.c.  Comment

The RI lists different PRP's than what the original summons
did  two  years  ago  and I'd like to  see  that  is  properly
addressed.   (E)
                          '-  '  •  •>•"
4.c.  Response

The PRP  list at this  time  is the  same  as  it was during the
RI/FS  negotiations  two years  ago.    The  RI  report  states
that D&C Disposal is  a PRP  but they  are not now considered
a PRP, while Ed Dains, past site owner is considered a PRP,
though even  he  is not listed in  the RI  report.    If the
county or any one else has information that indicates other
PRP's, the U.S.  EPA  is willing to send information request
letters  to those parties  if there is  substantial  evidence
to warrant such a. request.

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                                16


     5.  Property value concerns.

5. a.  Comment

We'have  a pond that is fed by  Iris  Creek,  downstream from
the   landfill.    Since  around   1981,   we  have  noticed
deterioration  of this  pond and the  loss  of fish,  can this
be caused  by the landfill,  as several realty companies are
suggesting?   Can any  sampling be done  of  my pond?   Will
this new cap help taJce care of our problem? (G)

5.a.  Response

As noted  in the RI  report.  Iris Creek was  sampled and no
significant  contamination  was   found in downstream  Iris
Creek,  locations.    Where  as  it  is possible  that  past
contamination from the landfill may have reached downstream
locations, our surface water and sediment sampling does not
suggest this.    More  investigations will  be  occurring to
evaluate the groundwater  effects to  the  surface  water and
to evaluate  the effectiveness  of  the cap.    This on-going
investigation  may  be  expanded to  include  points further
downstream.

     6.  Notification period and response time concerns.

6.a.  Comment

We  (the  governing  bodies  of  the county)  have been allowed
only  one  month to  respond  and comment.    It   is  almost
impossible for  a government to  respond that cniickly.   Will
you accept any comments after August 31?  (E)

Mason  County  was not  aware  that the U.S.  EPA intended to
select  remedial  Alternative  Number  4   until  the  public
meeting on August 17, 1988.  The county did not receive the
final  reports  until about  a week after the  start  of the
public comment period on August 8, 1988.  The 23 days total
or  14  days from the public  meeting, given to  for public
comment  is not  long  enough  for the county to  review the
documents  and  respond   can more time be given for comments
from the county? (H)

6. a.  Response

The  U.S.   EPA  is  under Congressional  deadlines  and  time
limits to clean up Superfund sites.  While we cannot accept
comments after  August  31,  no  comments will  be ignored.  It
may  be possible  to work them  into the design  stage or
further on in  negotiations.   We  realize that it is  very
difficult for a municipality to respond quickly; this issue

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                                17

is  being  discussed currently  in  agency headquarters  in
Washington D.C. with the Municipal Settlement Group.

According  to  U.S.  EPA  record, Tim  Hansen, Mason County
Department of Public Works was sent  a Final RI  report on
JUly  14,  1988 and a Public Comment FS  report on  August 5,
1988.    The  proposed  plan  was  expressed  mailed to  Tim
Hansen, on August 4, 1988.  Also,  all these documents were
available for public review on or before August 8, 1988.

6.b.  Comment

The public comment period on the Feasibility Study  (FS) and
proposed RAP was  initiated on August 8, 1988 and expires on
August 31, 1988,  allowing only  21 days  (15 working days) to
.provide written  comments.   The  only apparent notice of the
public comment period to  Straits Steel  as  a  PRP in this
matter  was  provided by  the EPA's  August 24,  1988 letter
(the  "special Notice  of Potential Liability").    This is
clearly  inadequate notice, coming well  after the public
comment period was initiated.1

Given the complexity and importance of the issues  involved,
this  short comment  period  does  not provide sufficient time
to thoroughly  review the relevant materials and has unduly
restricted our ability to comment on the appropriateness of
the proposed  alternatives.  The lack  of an adequate period
to provide  for thorough review and submission  of comments
may constitute a  violation of due process.   (M)

6.b.  Response

The U.S. EPA, following NCP guidelines, has allowed 21 days
for public  comment.   The FS report and the proposed plan..
Actually, 23 days were available for public comment, August
8  through August 31,  1988.   Appropriate notice  was given
announcing  the  public  comment   period  and   the  EPA's
preferred  remedial action; as  tnis  was  published  in the
local  newspaper  prior to  August  8,  1988.    Also,  Mason
County, the  main contact throughout the RI/FS negotiations
was   informed  of the   timeframe  for  the   public comment
period.    All  appropriate documents  were  available  for
reviewing at the  Ludington Library, Mason County Courthouse
and at the Pere Marquette Township Hall, on or prior to the
initiation of the public comment period on August  8, 1988.

6.c.  Comment

We  object  to  the  initiation  of  the  60  day period  of
negotiation  to   establish  a   "good  faith"  proposal  for
implementing  and conducting the remedial  action  as having
been  initiated too early.   First, the Record  of Decision

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                                18

("ROD") to  select the appropriate remedial  action has not
yet been issued.  In the absence of a final decision on the
remedial action,  it  is  impossible  for  the PRPs to agree to
"a  detailed statement  of  work" identifying how  they may
proceed  with the  remedial action,  or  to meet  the  other
elements which  the  U.S.  EPA has indicated must be included
in a "good faith" proposal.  Second, while the U.S. EPA has
prepared a  list of  six  (6)  PRPs,  it is probab-le that other
PRPs remain  unidentified in connection with this municipal
landfill.  We fail  to understand how the negotiations on a
"good  faith"   proposal  can   proceed  until  all  of  the
necessary  parties  are  at the table.    Accordingly,  we
request that the period of negotiation  be extended to run
60 days  from such time as  the ROD has been issued and/all
PRPs have been  identified.   (M)

6.c.  Response

The negotiation period  for the Remedial  Action routinely
starts prior to the  signing of the ROD so that by the time
the PRPs  arrange  themselves   into  an  organized  group and
review the pertinent  documents, the ROD  is well on its way
toward finalization.   By doing it  this  way EPA resources,
as well  as  time, are conserved.   With regard to obtaining
more PRP's for  this  site,  at  the present time EPA, does not
have any other  information  indicating PRPs other than, those
that have  already received special  notice regarding RD/RA
negotiation.  U.S.  EPA  is  willing  to pursue other PRP's if
the  information  provided   indicates  PRP  involvement  with
hazardous substances being disposed of at this site.

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                                  APPENDIX A
                   List of CooKnters on the Mason County
                     Feasibility Study and Proposed Plan
      liaae
(A) John Wolkow
(B) Dave Cherba
(C) George Cluehey
(0) Kathy Uinczewski
(E) Tim Hansen
(F) Connie Anderson
                           Affiliation
                           Resident
                           Resident
                           Resident
                           Resident
                           Mason County
                           Pere Marquette TWP
(G) Mr & Mrs Robert Rasch  Resident  -
(H) Robert P.Tremp

(I) Tim Hansen

(J) Larry Gustafson
(K) Stanley Jansen/
    Joanne Kelley
(L) Robert D. Pacific

(M) George B. Davis

(N) Dennis Dunlap
                           Attorney representing
                           Mason County
                           Mason County
                           Resident
                           Pere Marquette
                           Charter TWP Board
                           U.S. Fish & Wildlife
                           Serv ice
                           Attorney representating
                           Strains Steel  &.;:Wire Co.
                                  •        ~. ~
                           Westshore Engineering
                           and Surveying  Inc.
Source of Coaaent
8/17/88  Meeting
8/17/68  Meeting
8/17/88  Meeting
8/17/88  Meeting
8/17/88  Meeting
8/17/88  Meeting
8/29/88  Letter
8/30/88  Letter

8/12/88  Phone Call and
8/17/88 Meeting
8/19/88  Letter
8/24/88  Letter

8/29/88  Letter

8/31/88  Letter

8/31/88  Letter

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