50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R05-90/143
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Springfield Township Dump, MI
First Remedial Action - Final
5. Report Date
09/29/90
7. Author(s)
8. Performing Organization Rept No.
8. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(C)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abatract (Limit: 200 words)
The 16-acre Springfield Township Dump site is in Davisburg, Springfield Township,
Michigan. The site is comprised of an open field area surrounded by dense woods.
Surrounding land use is mixed agricultural and residential. The site overlies both a
shallow and deep aquifer, and there are several wetlands adjacent to the site. A 4-acre
portion of the site was used for industrial waste disposal between 1966 and 1968.
Unknown quantities of industrial waste were drained into onsite excavated pits in a
central disposal area or deposited on low ground areas. Random dumping of refuse
occurred onsite, and many drums containing liquid wastes were seen scattered throughout
the woods. In 1978, the State identified PCBs, paint sludge, solvents, oils, and
greases in 1,500 onsite drums. State studies also determined that a portion of the
aquifer underlying the site was highly susceptible to contamination, due to the absence
of a clay layer. In 1979 and 1980, VOC-contaminated well water was found at private
residences near the site. In 1979, the State ordered the 1,500 onsite drums removed and
disposed of offsite. From 1979 to 1980, 711 tons of contaminated soil were'excavated
and removed from several onsite areas including the centrally located disposal pits.
Because of limited funding, some wastes remained onsite, but the pits were subsequently
(See Attached Page)
MI
17. Document Analysis a. Descriptors
Record of Decision - Springfield Township Dump,
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (TCE, toluene), other organics . (PCBs), metals (arsenic,
chromium, lead)
b. Identifiers/Open-Ended Terms
c. COSAT1 Held/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
144
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R05-90/143
Springfield Township Dump, MI
iFirst Remedial Action - Final
Abstract (Continued)
filled in and regraded. In 1980, the State identified onsite PCB- and DDT-contaminated
soil and onsite VOC-contamination in ground water. This Record of Decision (ROD)
addresses remediation of onsite contaminated soil and ground water and will be a final
remedy for the site. The primary contaminants of concern affecting the soil and ground
water are VOCs including TCE and toluene; other organics including PCBs; and metals
including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating and treating onsite a
total of 11,820 cubic yards of VOC- and other organic-contaminated soil by
incineration, and solidifying the resulting ash; treating metal-contaminated soil using
solidification and redepositing the treated soil and ash onsite or temporarily storing
the treated soil onsite in a solid waste unit; treating remaining soil using in-situ
vacuum extraction and performing a treatability study to determine its effectiveness;
ground water pumping and treatment using carbon adsorption, followed by onsite
reinjection of the treated ground water; and implementing site access restrictions,
such as fencing. The estimated present worth cost for this remedial action is
$9,271,290, which includes an annual O&M cost of $97,659.
PERFORMANCE STANDARDS OR GOALS: Soil remediation goals are based on a 10~6 cancer risk
and State Michigan Act 307 Standards. Chemical-specific soil cleanup levels include
PCBs 1 mg/kg, toluene 0.08 mg/kg, and TCE 0.08 mg/kg. Ground water will be remediated
to meet or exceed SDWA Federal MCLs or MCLGs including toluene 0.4 mg/1 (MCL) and TCE
0.003 mg/1 (MCL). Lead and arsenic will be remediated to background levels for both
soil and ground water.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SPRINGFIELD TOWNSHIP SITE
Oakland County, Michigan
Prepared by •/•'
U.S. Environmental Protection Agency
Region V, Chicago Illinois
September 1990
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RECORD OF DECISION
Remedial Alternative Selection
Site Name and Location
The Springfield Township Dump site is approximately a 400 by 500
foot fenced area located on an approximately 16 acre parcel of
land, south of Davisburg in Oakland County, Michigan.
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Springfield Township Dump site in Oakland County, Michigan,
which was chosen in accordance with CERCLA, as amended by SARA,
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision is
based on the administrative record for this site. The index to
the administrative record is attached to the Record of Decision
(ROD).
The State of Michigan has concurred with the selected remedy.
Assessment of the Site ^
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of Selected Remedy
The selected remedy addresses the principal threats posed by the
site, and is the final remedy for the site. The major components
of the selected remedy are:
•Excavation and thermal destruction of soils to remove to
specified cleanup levels polychlorinated biphenyls (PCBs),
volatile organic compounds (VOCs), semi-volatile organic
compounds (SVOCs), and pesticides in the source area;
•Solidification of incinerator ash according to ARARs;
•Solidification of soils contaminated only with metals;
•Redeposition of ash and treated soil on-site (the ash will
either be stabilized to make it inert prior to its on-site
disposal or will be placed in a properly designed solid
waste unit on-site);
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*Recontouring of the excavated areas and control of the ash
or dust emissions;
•Installation of an in-situ vacuum extraction system to
remove VOCs and SVOCs from remaining unsaturated
contaminated soils at depth; and
•Installation and operation of a ground water extraction and
treatment system which utilizes a carbon adsorption unit to
treat the groundwater before reinjection into the aquifer.
A detailed discussion of each of the components of the selected
remedy is presented in Section 9 of the ROD and in both the
Feasibility Study and Proposed Plan developed for the site.
Statutory Determinations
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element and utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
Because this remedy will not result in hazardous substances
remaining on-site above health-based levels, the five-year
facility review will not apply to this action once the cleanup
performance standards are achieved.
fc
Valdas V. rtdamkus
Regional Administrator
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TABLE OF CONTENTS
Section Page
The Declaration
1.0 Site Name, Location, and Description 3
2.0 Site History and Enforcement Activities 4
3.0 Community Relations Activities 7
4.0 Scope and Role of the Response Action 8
5.0 Summary of Site Characteristics 9
5.1 Geology and Hydrology 9
5.2 Drum Wastes 10
5.3 Soil Contamination 10
5.3.1 Surface and Shallow Subsurface Soil 10
Contaminat i on
5.3.2 Subsurface Soil Contamination 11
/?'
5.3.3 Test Pit Soil Contamination '.' 12
5.4 Surface Water/Sediment Contamination 12
5.5 Ground Water Contamination 12
6.0 Summary of Site Risks 13
6.1 Contaminants of Concern 14
6.2 Exposure Assessment 14
6.3 Toxicity Assessment 15
6.4 Risk Characterization 15
6.5 Environmental Risks 17
7.0 Description of Alternatives 17
7.1 Remedial Cleanup Levels 17
7.2 Volume of Soil Remediation 18
7.3 Volume of Ground Water Treatment 19
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Section Page
7.4 Soil Alternative 1: No Action 19
7.5 Soil Alternative 2: Off-site Land Disposal 19
7.6 Soil Alternative 3: Surficial Capping 20
7.7 Soil Alternative 4: On-site Incineration, 20
Solidification
7.8 Soil Alternative 5: On-site Incineration, 21
Solidification, In-situ Vacuum Extraction
7.9 Ground Water Alternative 1: No Action 21
7.10 Ground Water Alternative 2: Ground Water 22
Extraction and Carbon Adsorption
8.0 Summary of Comparative Analysis of Alternatives 22
8.1 Threshold Criteria 24
8.1.1 Overall Protection of Human Health and the 24
Environment
8.1.2 Compliance with ARARs 24
• /'
8.2 Primary Balancing Criteria / 25
8.2.1 Long-term Effectiveness and Permanence 26
8.2.2 Short-term Effectiveness 26
8.2.3 Reduction of Toxicity, Mobility, or Volume 27
8.2.4 Implementability 27
8.2.5 Cost 28
8.3 Modifying Criteria 29
8.3.1 Support Agency Acceptance 29
8.3.2 Community Acceptance 29
9.0 The Selected Remedy 29
10.0 The Statutory Determinations 32
10.1 Protection of Human Health and the Environment 32
10.2 Compliance with ARARs 33
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Section Page
10.3 Cost-Effectiveness 35
10.4 Utilization of Permanent Solutions and 35
Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent
Practicable
10.5 Preference for Treatment as a Principal Element 36
11.0 Documentation of Significant Changes 36
12.0 Summary 3 6
Attachment 1 - State Letter of Concurrence, September 28, 1990
Attachment 2 - Responsiveness Summary/List of Commenters
Attachment 3 - Administrative Record Index
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
SPRINGFIELD TOWNSHIP DUMP SITE, MICHIGAN
1.0 Site Name, Location, and Description
The Springfield Township Dump site is located south of the town
of Davisburg, in Springfield Township, Oakland County, Michigan.
The site is located on approximately 16 acre parcel of land in a
residential/agricultural area near the junction of Ormond Road
and Woodland Trail (see Figure 1). The site is located on a
local topographic high and consists of an open, fenced area
surrounded by dense woods.
The site is located within the Huron River system on a knoll with
kettle wetlands occupying low elevations to the west, southwest,
and southeast. The kettle wetlands are located within a 1/4 mile
radius of the site and are geographically isolated. Wetlands
further west of site are intermittently connected to adjacent
wetlands and ultimately discharge to Big Lake which is 1 mile
northeast of the site. The surface water drainage patterns are
poorly developed due to rapid infiltration of rain water.
$•'
Springfield Township and the area around/ the site is mixed
residential and agricultural. According to the Oakland County
Planning Department, this area is zoned for medium density
development which requires 1 to 1 1/4 acre lot size per single
family dwelling. The township population is currently 10,063 and
projected to be 13,381 in the year 2000. The Springfield
Township Site is located on the Nickson property and is situated
on the 16 acre parcel of land on which the 4 acre site is
located.
Area geology consists of unconsolidated glacial drift overlying
the Early Mississippian Coldwater Shale bedrock formation. The
geology below the site is glacial outwash plain comprised of
fine-to-coarse grain sand with some silt-sized material. This
glacial outwash deposit extends to an approximate depth of 140
feet and overlies interbedded sands and clay lenses. Bedrock is
located at an approximate depth of 345 feet and consists of shale
or limestone. There is no evidence to indicate that the clay
lenses are contiguous and form a continuous layer throughout the
area.
The glacial outwash deposit aquifer is utilized as a drinking
water source by local residents (Class I aquifer). Ground water
flow is to the north east. The nearest well is at the Nickson's
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'I:.
•TKINCFIELO
TOWNSHIP
SOURCE: USGS Topographic'
Itep. 1973.
FIGURE 1
LOCATION MAP
SPRINGFIELD TOWNSHIP
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residence, several hundred feet dovngradient of the site.
Regular groundwater sampling by the Michigan Department of
Natural Resources (MDNR) indicates that the residential wells
have not yet been impacted by groundwater contamination.
The site is approximately 400 by 500 feet, defined by an 8 foot
fence installed by MDNR. The fenced area is on a topographical
high and is surrounded by woods and kettle wetlands. The dune-
like topography of the area provided a natural basin on the back
portion of the Nickson property in which to store drums and
dispose of liquid wastes. Drums were scattered throughout the
woods and in a central disposal area in which the liquid wastes
also appeared to have been dumped.
There are signs of casual use of adjacent property. Also, there
have been several instances of trespassing and vandalism at the
site which have caused the need for well repair and fence
installation. There are all terrain vehicles (ATV) and other
vehicular trails throughout the area. There are also indications
of random dumping, i.e. burned-out car, trash site with burn-
barrels and miscellaneous items.
2.0 Site History and Enforcement Activities
The site was used for industrial waste disposal between 1966 and
1968 but may include other years. An unknown amount of
industrial waste was drained into excavafted pits or low areas on
the ground surface (See Figure 2). In addition, approximately
1,500 barrels were found on the site.
The dumping of wastes was done by waste haulers under contract or
other agreement with the waste generators. The first official
notification of illegal dumping was made by the supervisor of
Rose Township in a letter to the Oakland County Health Department
(OCHD) in June 1968. In a MDNR memorandum dated December 10,
1968, a staff member reported that the OCHD had recently found
another dumping site, the Springfield Township site.
In July 1971, the OCHD issued a certified letter to the property
owner, Mr. Joseph Nickson, stating that corrective action was
required. In April 1979, a Pollution Emergency Alerting System
(PEAS) complaint was filed by the OCHD to the MDNR. As a result
of this complaint, the MDNR conducted limited drum sampling at
the site on June 4, 1979. Subsequent analyses by the MDNR
identified the drum contents as paint sludges, solvents, PCBs,
oils, and greases.
From August 1979 through June 1980, sampling of well water at
private residences near the site was conducted. During initial
sampling episodes, several residential wells in the vicinity of
the site were reported to be contaminated with low levels of
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LEGEND
D
MOTE:
TAKEN r*OM W0A1CB KIT ME-f ICAVATION
ACMAL PHOTO.
SCALE
0 Su TOC
ni|T| INF
FIGURE 2
OISPOSAI ARFA«;
200
SlTf SUXVf » O«TtO «.'«»
FEASIBILITY STUDV
MICHIGAN DEPARTNflENT OF
NATURAL RESOURCES
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layers of hardened multicolored sludges located near the center
of the site.
The RI report was completed in April 1989. The results of the RI
indicated surface and subsurface soil contamination. PCBs,
dieldrin, toluene, chlorobenzene, trichloroethene, barium, lead
and arsenic are identified as the contaminants of concern in the
on-site soils. The shallow soil contaminants pose both a direct
contact threat and a threat to the food chain through
bioaccumulation of toxics. The shallow and subsurface soil pose
an additional threat to the ground water, acting as a continual
source of degradation. Ground water contamination, found mainly
within the site boundaries, consists primarily of
trichloroethene, dichloroethene, arsenic, and lead.
The MDNR conducted several additional ground water sampling
episodes since the RI investigation. The results of the sampling
indicated that ground water contamination had spread away from
the disposal area and was migrating to the north-northeast. The
Nickson residential well, which is located on the 16 acre parcel
of land on which the site is located, was sampled in November
1987 and found not to be contaminated.
The Feasibility Study (FS) was initiated by the lead agency,
MDNR. In January 1988, the lead agency responsibility was
transferred to the U.S. EPA, and the project was completed in
July 1990. The FS and Proposed Plan we£e released for the public
comment period which began on July 13, 1990. The FS presented
several soil remediation alternatives and a ground water remedy
that will be explained in detail under the Description of
Alternatives section of this document. A more detailed analysis
of all alternatives are presented in the "Final Report on the
Feasibility Study of the Springfield Township Site11 (July 1990).
Identification of potentially responsible parties (PRPs) was made
through interviews with haulers, review of state and private
records pertaining to the site, and examining photos taken of the
site.
On January 30, 1990, U.S. EPA issued general notice letters to
the members of the Springfield Township PRP Steering Committee
and other potential responsible parties known at that time.
A Steering Committee was formed by some members of the
potentially responsible parties and met with U.S. EPA and MDNR on
several occasions. The initial meeting was on September 6, 1989
in Lansing, Michigan and was to discuss the cleanup levels,
possible remediation technology and the Remedial Action Plan
(RAP) submitted to the agencies by the Steering Committee. A
subsequent meeting was planned so that the Steering Committee
could provide further clarification and expanded methodology
introduced in the RAP. In the interim, the Steering Committee
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tetrachloroethene and trichloroethene, volatile organic compounds
(VOCs), that were similar to those found on the site.
In September 1979, the site was declared an environmental
emergency by the State of Michigan Toxic Substances Control
Commission (TSCC) based upon potential threat to health and
environment. During the same month, the MDNR commenced the
excavation and removal of drums from the site. In December, a
special appropriation was made by the State legislature for the
cleanup of the wastes and investigation of the impact on ground
water. By July 1980, 1,500 55-gallon drums had been removed.
In 1979-1980, 711 tons of contaminated soil was removed to a
licensed hazardous waste facility in Alabama. This included much
of the material contained in the disposal pit located in the
central portion of the site. Because available funding was
insufficient, some wastes were left on-site. This removal action
left the disposal pit area several feet below original grade.
Backfill, composed primarily of sand, was brought in and the
disposal pit area was regraded.
In September 1980, MDNR initiated and performed a Phase I
Hydrogeologic Investigation, during which four monitoring wells
(MW IS through 4S) were installed. The Phase I Hydrogeologic
Investigation report, completed in 1981, indicated the presence
of significant soil contamination including PCBs at
concentrations up to 240 ppm and the pesticide DDT at up to 10
ppm. Lows levels of 1,1,1-dichloroethane (35 ug/L in MW-1S) ,
1,1,1-trichloroethane (12 ug/L in MW-4S), and several heavy
metals were detected in the ground water.
Based on the findings of the Phase I report, a Phase II
Hydrogeologic Investigation was begun in May 1982 by MDNR.
Thirteen additional monitoring wells were installed (MS-ID
through MW-4D and MW-5 through MW-13). Completed in 1983, the
report concluded that the portion of the aquifer underlying the
site was highly susceptible to contamination due to the absence
of an impermeable material such as clay. Contaminants had
migrated through the existing sands impacting the ground water
and creating a plume of contamination which had since migrated
downgradient, but had not reached residential wells.
In 1983, the site was placed on the National Priority List. The
Phase I and II Hydrogeologic Investigation reports were
incorporated in to the U.S. Environmental Protection Agency
(U.S. EPA) Remedial Action Master Plan (RAMP) which recommended
that a Remedial Investigation/ Feasibility Study (RI/FS) be
undertaken at the site.
In February 1985, MDNR initiated the RI at the site. At the
time, the major evidence of past disposal practices consisted of
soil with entrained sludges and tar-like material and surficial
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8
Springfield Township representative attended meetings at MDNR in
Lansing and provided assistance and support to MDNR efforts
during the site investigation and cleanup. An organization
called the "Schindler Road Residents" has been involved in
•onitoring site cleanup activities since 1979. This group has
been represented at several public meetings and also some members
filed a class action suit regarding this site which was settled
without a judication.
Substantial interaction with the community occurred during the
remedial investigation and feasibility study phase conducted by
the MDNR. Eight newsletters, several public meetings and
numerous one on one discussions both in person and over the
telephone occurred. In addition a citizen information committee
was formed and several meetings were held with that group.
The lead agency responsibility for the RI/FS was transferred in
January 1988 from MDNR to U.S. EPA. U.S. EPA held a public
meeting on July 11, 1989, to update area residents about the site
work and RI/FS schedule, and to explain that the cleanup remedy
was delayed pending modifications in the cleanup levels. In
October 1988 and October 1989, the U.S. EPA sent to the members
of the public on the site mailing list updates on the status of
the project.
As the Feasibility Study concluded, a local official and citizen
requested a tour of a transportable incinerator in the Chicago
area because incineration was one of the7 alternatives under
consideration for the site remedy. On July 18, 1990, the local
official, citizen, and the U.S. EPA site RPM received a tour of
the incinerator by the Illinois Environmental Protection Agency.
On July 24, 1990, a public meeting for the proposed plan and FS
was held. Approximately 30 people from the community as well as
members of and contractors for the PRP Steering Committee
attended. Oral and written comments were recorded and are
summarized in the Attachment 2, Responsiveness Summary, within
this document. The provisions of Sections 113 (k) (2) (B) and 117
of CERCLA have been satisfied.
An information repository has been established at the Springfield
Township Hall, 650 Broadway, Davisburg, Michigan 48019 and
periodically updated. According to Section H3(k)(l) of CERCLA,
the Administrative Record File has been made available to the
public at Springfield Township Hall.
4.0 Scope and Role of the Response Action
The Remedial Action for the site will address the principal
threats to public health and the environment posed by the
contaminated soils and contaminated ground water found on-site.
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submitted another report which addressed the presence of
pesticides and arsenic in on-site soils. A meeting with the
Steering Committee, U.S. EPA and MDNR was held at U.S. EPA
offices in Chicago on January 30, 1990. At that time, MDNR
informed U.S. EPA and the Steering Committee that the cleanup
levels for certain chemicals would be revised if Michigan
promulgated its Act 307 Rules. Subsequently, a conference call
on April 12, 1990 and a meeting on May 9, 1990 at the MDNR
offices occurred between the Steering Committee, U.S. EPA and
MDNR to continue discussions on the proposed cleanup levels for
the site. As indicated in the Administrative Record, the
Steering Committee and U.S. EPA continued to discuss the
proposed cleanup levels.
3.0 Community Relations Activities
The MDNR began field sampling during the summer of 1979 as a
result of the PEAS complaint. In August 1979, the Detroit Free
Press printed a story titled, "Dump Sites Leak PCB's in Oakland:
Tests Due." The article was the first notice for many residents
and local officials that a toxic chemical problem existed at the
site. On September 1, 1979, a portable communications center for
MDNR was moved onto the site to help improve field
communications.
On September 4, 1979, MDNR hosted a meeting attended by a variety
of agency and public officials interested in the effects of
illegal dumping. The purpose of the meeting was to summarize
action that had occurred to date and to determine
responsibilities for future actions. Public warnings were issued
not to drill new water wells.
On March 29, 1983, MDNR held a public meeting at the Davisburg
school in Springfield Township.
MDNR contracted with the Southeast Michigan Council of
Governments to complete a review of social and economic impacts
related to the toxic waste sites in Oakland County. Based on
interviews, the following citizen concerns and issues related to
the presence of the sites were identified:
•potential lower property values,
•potential drinking water supply contamination,
•health effects of ingesting contaminated drinking water and
the future health of families, and
•perceived lack of communication and concern from government
agencies.
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LEGEND:
O toc*TioN or taunt
W SAMPIC MNTTKATOM NMMEH
or son.
MOTES:
». MH surni otNons « SUMHCUI siuooc
SCALE
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FIGURE 3 j
ESTIMATED EXTENT OF
PROPOSED^ SOIL ^REMEDIATION '
; i-«^iu.w. i i Si uu t
MICHIGAN DEPARTMENT OF
NATURAL RESOURCES :
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The affected area is an area in which the contaminated soils
extend to depths of 85 - 90 feet and have contaminated the ground
water underlying the site. This response action is the final
remedy for the site and will remediate this area by excavation,
incineration, solidification and in-situ vacuum extraction of
contaminated soils and extraction and treatment of contaminated
ground water (see Figure 3). As a result of this remedial
action, the site will not require monitoring, deed restrictions,
or institutional controls, if the cleanup levels are attained and
the residual incinerator ash is either disposed of off-site or
stabilized prior to its on-site disposal.
5.0 Summary of Site Characteristics
The investigations conducted for the emergency removal action,
for the RAMP, and for the RI produced information on the site's
geological and hydrological conditions, soil contamination,
groundwater contamination, environmental setting and area
demographics. The following sections will present the major
findings.
5.1 Geology and Hydrology
A geologic cross section of the Springfield Township site from
northwest to southeast is shown in Figure 4. The cross section
shows that the geologic materials immediately beneath the site
are relatively homogeneous, consisting primarily of deposits of
water-laid sand with some silt-sized material. The materials
encountered in the unsaturated zone consist of moist, brown or
gray, fine to coarse sand with occasional pebbles and lenses of
silt. Only two definite geologic changes were noted in the
materials above the water table, which occurs at depths of 85 to
95 feet below ground level. One change was a layer of fine to
medium sand with cobbles which was present from surface to a
depth of 26 feet northwest of the site. The other was a brown
clay layer which was encountered in the upper 4 feet in an area
immediately northeast of the site. The glacial outwash deposits
extend to a depth of 140 to 150 feet.
A seismic profile conducted approximately 40 feet south of the
main disposal area measured velocities indicative of clay and
sand beginning at 175 feet below grade extending down to
approximately 345 feet. At about 345 feet, bedrock was indicated
and is believed to be the Mississippian Coldwater Shale.
The site is bordered on three sides by low-lying marshy areas and
has no well developed drainage pattern. The most probable
surface drainage route appears to be to the west towards an
adjacent marsh. Surface water flow would terminate here except
possibly in the case of extremely heavy rainfall.
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10
The aquifer at the site is a Class I aquifer (drinking water
source). Horizontal direction of ground water movement within
the vicinity of the site is varied. The ground water from the
site may move east and west around a ground water mound, which is
located just north of the site, as it flows in a north and
northwest direction (see Figure 5) . At other times of the year,
these pathways may become blocked hydraulically, and ground water
underlying the site may change direction for short periods of
time (see Figure 6). Ground water flow at the site is occurring
too slowly for seasonal variations in the infiltration rate and
for ground water movement to be a significant concern.
Horizontal ground water flow rates in the area of the site range
from 1 to 50 ft/yr.
5.2 Drum Wastes
Drum contents and pools of water around the drums were sampled in
the summer of 1979. Six of the drum samples indicated PCBs in
concentrations ranging from 32,000 ug/1 to 11,600 ug/1 with
Arochlor 1254 the most prevalent. Analysis for heavy metals
indicated cadmium, chromium, copper, iron, nickel, lead, and
zinc. The gas chromatograph and infrared scans showed the
presence of lubricating oil, fuel oil, gasoline, benzene,
toluene, mineral spirits, methyl isobutyl ketone, and xylene.
All drummed wastes have been removed from the site. There is
presently insufficient evidence to conclude that the drummed
wastes were specific RCRA listed hazardous wastes.
During excavation and removal, additional drums were sampled for
PCBs. PCBs were detected in 253 of 525 drums with solid contents
and 70 of 431 drums with liquid contents.
5.3 Soil Contamination
The soil sampling program for the site consisted of surface and
shallow subsurface sampling, two phased subsurface sampling and
test pit investigations (see Figures 7 and 8).
5.3.1 Surface and Shallow Subsurface Soil Contamination
The surface and shallow subsurface sampling consisted of
approximately 300 samples taken by hand auger at three depths (up
to 4.5 feet) in 100 locations. Concentrations of contaminants
encountered included: PCBs at up to 3,800 ppm; pesticides at up
to 48 ppm; and lead at up to 5,470 ppm. Most shallow soil
contamination was encountered within the top 2.5 feet.
VOCs were generally present in the shallow soil at typical levels
of less than 100 ppm. The exception was at the former disposal
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AREA
MWS
(MOUNO SURFACE
1140-
«ite-
1100-
Ji lit r ttrr -
1OTC-
tooo-
SILTS AND CLAYS
WW( « WILL MUMIIR
— I- ODOUHOWATCN LIVIL
- SCREEN INTERVAL
• •OTTOU Of •ORINO
«- »00
HORIZONTAL SCALE
NOTES:
1. WATER LEVELS CASED ON MARCH It. IMS DATA.
I VBTTCA1. fXAOOEBATUN OF ABOUT «T»€a
o too loo
«00 FEET
FIGURE «
INTERPRETIVE GEOLOGIC
CROSS SECTION A-A'
SPRINGFIELD TOWNSHIP SITE
FEASIBILITY STUDY
MICHIGAN DEPARTMENT OF
NATURAL RESOURCES
-------
ft' »Jo* tie' 300' «5(T-»6o
/ A
f i
* •
• •
• •
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« •
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h
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19
FIGURE 6
d|r»cliori
DNR
Environ «nt«
R*tp< '§•
Dlvlf on
5prln|fl«ld Twp. S»t»
3-13-88
-------
*{»'•
I I I. I 1
100 700'300 '00 >n
FICURE 5 Arff»»« i
-------
LEGEND:
O LOCATION Of CAMPlC POINT
ER
NOTES:
t. one STSTCM KT/HLtSHto IT MONK simvEr.
». AM H SIFFII DENOTES * »UNFCUl SLUOOE SAMPLE.
a. SAimcs OCNCMAUV TAKEN AT SUMFACE. >.t FEET
AND 4.S rttt OCEP.
4). *A«nes *m< tokens OFCATEK TMAN too AfC
Or aifFA
SCALE
0 SO 100 ZOO FECT
•AtC MA» PDOU MDMII SITE »UOVf T DATED 4/lt.
FIGURE 8
HAND AUGER SOIL SAMPLE LOCATIONS
S8RINGFIELD TOWNSHIP SITE
FEASIBILITY STUDY
MICHIGAN DEPARTMENT OF
NATURAL RESOURCES
-------
'00
! O •
MW-6
'•MW-8
MW-IO
DO- 10" •'•'•'•' '0"
•— j
2SO FEET EAST'
LEGEND:
A •oftmos TO *e tin «v JOROANIKECK d«»s>.
• •onwos u« TO u> FEET) BY MOHFI (itie).
::= ACCESS «O»D
NOTES:
BOXINGS OB-10S. 106. 10'. AND 108 WE«E CONVERTED
TO MONITORING WELLS MW-IOV 106. 107. AND ice
RLSt'LCUvtl*. Sit flliUHt 4 HJK LXAC1 LOCATIONS 0^
OB-10*. 107. AND IOC.
SCALE
100
200 FEET
FIGURE 7
TEST PITS AND DEEP BORING LOCATIONS
SPRINGFIELD TOWNSHIP SITE
FEASIBILITY STUDY
MICHIGAN DEPARTMENT OF
UATIIBAi Beer
-------
NORTH
8O ITH
I— 1120
— 1110
wrt^ 1^%^ >
INCL.UDED
TEST PIT J
2 ^-1
i ^1
Q:^
^\
TES r PIT 3,
** w * *
I * 2 I ^
0.03
0.45
0
001
0.5.'
0
0.14
0.37
0
0.04
046
0
11.7^*N_
0.22
0
115.6
0.48
0
. ^
3964
42.4
6HO
950
141.5
5?
1356
58
3.4
35289
931.5
780
r--***' 7732
15.7
94830 67
513
21
11639
787
310
0
196
?00 360
0
x^
.-^
\ •' '
0.09
19.2
° l
xn.08
0.08 6.6
3.2 U
0.7
^F
.T
°^*n b.osl . L o
A
1
100
29
070
116.7
0
439
0
0.73
1.49
0.46
1^ % 5.1 |0.82
g 85 R 0.64
f ^
0.4 610
•il 14S
14 2«
1.1
0.32
0
1
!
f 0.09
n tt 1 "-20
0.23 | n
0.76 • u
0
ORGANIC CONTAMIN/
I—1080
NO HORIZONTAL SCALE
LEGEND:
1356 TOTAL VOLATILES. PPM
58 TOTAL SEMIVOLATILES. PPM
3.4 TOTAL PCB. PPM
4465-53
FIG JRE 9
TS Ihf SOI S
PEEP BORINGS AND TEST PI S
SPRINGFIELD TOWNSHIP SI E
FFASIBILITY STU Y
MICHIGAN DEPARTMENT r
NATURAL RESOURC 3
, CJORDANCO •
-------
11
pit location where total VOCs were found at 9,000 ppm and 12,100
ppm at a depth of 2.5 feet. The chemicals found at high
concentrations were primarily aromatics (toluene and xylene).
PCBs, principally identified as Arochlor 1254 and Arochlor 1260,
were widely distributed through the shallow soils and detected in
one fifth of the samples analyzed. Indicative of the relative
immobility of PCBs, the distribution of PCBs in soils at the site
decreases with depth. The exception to this is in the principal
disposal pit area where infiltration of solvents may have
solubilized and carried semi-volatile organic compounds (SVOCs)
and PCBs deeper.
Pesticides in shallow soils were detected at relatively low
levels, and in some cases identification was tentative. Dieldrin
was found in two samples with the highest pesticide
concentrations.
The SVOCs are present at the site primarily as phthalates and
polynuclear aromatics (PNAs) with relatively low levels of phenol
and chlorinated aromatics. The highest concentration of total
PNAs (362 ppm) was found at the disposal pit location.
Elevated levels of inorganics in soils occur largely near the
main disposal areas. Lead, cadmium, barium and chromium are
elevated in some areas which are may be associated with the
disposal of paint wastes at the site. $he metals present in the
near surface soils included barium whiclr was detected at 4,540
ppm at a depth of 2.5 feet; cadmium which had a maximum
concentration detected at 2,220 ppm at a depth of 2.5 feet;
chromium which was found at a maximum concentration of 130 ppm;
and lead which was found at a maximum concentration of 5,470 ppm.
5.3.2 Subsurface Soil Contamination
Subsurface soil borings were located in areas where subsurface
contamination was indicated or suspected on the basis of former
site activities and results from the RI. The first phase of the
sampling consisted of 11 borings to a depth of 25 feet, followed
by a second phase which conducted 11 borings ranging in depths
from 44 to 112 feet (see Figures 9 and 10).
Analysis of the samples from the first phase indicated the
presence of PCBs and VOCs. PCBs were detected at 680 ppm at 0-2
feet, 5.2 ppm at 13-15 feet, and 3.4 ppm at 23-25 feet. Organic
chemicals were detected at greater than 1 ppm in 5 out of 11
borings at a depth of 25 feet. One sample had a concentration of
3 percent of total VOCs (e.g., 3% is equivalent to 30,000 ppm) at
a depth of 3.5 feet. Another sample result collected from 25
feet had 1,356 ppm of VOCs which led to a second phase of
borings.
-------
12
Borings from the second phase indicated soil contamination by
VOCs at 11 ppm, SVOCs at 76 ppm, pesticides at 1.3 ppm and PCBs
at 19 ppm at 10 feet. In one boring, PCBs were detected at 44
ppm at 25 feet and 6 ppm at 30 feet, and total VOCs were detected
at 36 ppm at 75 feet and 3 ppm at 85 feet. Lead was detected in
borings at 385 ppm at 10 feet and 222 ppm at 25 feet.
5.3.3 Test Pit Soil Contamination
Test pit excavations were made at three locations which were
identified as anomalous during a metal detector and magnetometer
survey conducted at the site (see Figure 11). These locations
coincided with former disposal and drum storage areas. Fifteen
samples of soils and sludges were collected and submitted for
analysis.
Test pit number 3, located directly in the area of the former
disposal pit, provided samples with the highest contaminant
concentrations. VOCs were present at a concentration of about 10
percent in the shallow soils which contained waste materials.
VOCs were detected at 360 ppm and total SVOCs were detected at 37
ppm at a depth of 9 feet. PCBs were detected at 6.4 ppm at 9
feet and 310 ppm at 8 feet. Lead was detected at 1,560 ppm.
The concentrations in the other two test pits were lower, but
still revealed significant contamination, i.e., PCBs were
detected at 248 ppm at 3 feet in test pit number 1 and 390 ppm at
2 feet in test pit number 2. Lead was detected at 5,470 ppm in
test pit number 1.
5.4 Surface Water/Sediment Contamination
There are five kettle wetlands which are located within a 1/4
mile radius of the site. The kettle wetlands appear to contain
perched water which recharges the groundwater; they are not a
reflection of the water table. The surface water/sediment
sampling of the kettle wetlands was to assess the extent of site-
derived contamination from Springfield Township site. Analysis
of the samples indicated that past site activities have not
impacted the surface water quality or the wetland sediments.
5.5 Ground Water Contamination
During earlier hydrogeologic studies, 17 monitoring wells were
constructed at the site. Thirteen additional monitoring wells
were installed in 1982 and eight monitoring wells were installed
in conjunction with the RI/FS.
-------
ul
ui
O
>
UJ
8
«»
o
-1110
- 1100
-1090
-1080
-1070
-1060
-1050
-1040
-1030
-1020
L-1010
m
o
0.01
NO
NO
0.01
NO
NO
0.01
NO
ND
0.04
0.04
ND
0.02
0.12
NO
0.02
0.1
NO
0.01
0.04
ND
NOH
NOTES:
1 NOT ALL SAMPLES ARE SHOWN. ONLY THOSE SELECTED AS REPRESENTATIVE
OF THE CONTAMINANT PROFILE WITH DliPTH
2. DATA QUALIFIED WITH A 'B' OR "JB" WAS NOT INCLUDED.
NTAL SCALE
s
S
LEGEND
11 TOTAL VOA(pt
7fi TOTAL SVOA(|
19 TOTAL PCB(pp
NDNOTOETECTE
NA NOT ANALYZE
•)
n)
FIGURE 10
ORGANIC CONTAMINANTS IN SOILS
MDNR DEEP BORINGS
SPRINGFIELD TOWNSHIP SITE
FEASIBILITY STUDY
MICHIGAN DEPARTMENT OF
NATURAL RESOURi
. ECJORDAf
-------
13
Ground water analyses completed through 1982 revealed that the
levels of contamination were relatively low and that groundwater
gradients were small. Contaminants were detected up to 40 feet
below the water table. Neither the total depth of the plume nor
the thickness of the water table aquifer beneath the site had
been defined.
Sampling analysis conducted during the RI revealed the presence
of organic and inorganic chemicals in the groundwater in the
vicinity of the site. Chlorinated aliphatics and ketones were
consistently detected in site monitoring wells. Only two wells
had concentrations greater than 10 ppb total chlorinated
aliphatics (primarily 1,1-dichloroethane and 1,1,1-
trichloroethane). Aliphatics were detected at ranges of 73 ppb
to 134 ppb; ketones were detected at ranges of 85 to 190 ppb
(though their inconsistent detection indicates that ketones are
not a predominant contaminant); and aromatics were detected at
ranges of 15 to 70.6 ppb.
Arsenic and lead were consistently detected in the ground water
samples collected from on-site monitoring wells in concentrations
up to 34 ppb and 67 ppb, respectively. Other metals found in on-
site ground water include cadmium (6 ppb), chromium (9.5 ppb),
cobalt (19 ppb), and mercury (0.12 ppb).
Analysis of ground water samples collected from 13 area domestic
wells indicated there were elevated concentrations of iron,
copper, and zinc in some samples when compared to background
wells. The presence of these metals were likely due to
dissolution of the individual water supply systems' piping and .
pumps. Analyses of area domestic water supply wells indicated no
contamination by site-related contaminants.
The MDNR conducted two sampling episodes in 1987 after the
completion of the RI field work.
Chlorinated aliphatics (primarily 1,1-dichloroethane and 1,1,1-
trichloroethane) were detected in four of the on-site monitoring
veils and two off-site monitoring wells. The highest on-site
concentration was 234 ppb total chlorinated aliphatics. Arsenic
was detected in four monitoring wells with the highest
concentration at 29 ppb. Lead was detected in six wells of which
two off-site wells had concentrations at 150 ppb and 110 ppb.
6.0 Sunary of Site Risks
CERCLA requires that U.S. EPA protect human health and the
environment from current and potential exposure to hazardous
substances found at the site. The RI Report contains a Risk
Assessment which characterizes the nature and estimates the
gnitude of potential and/or actual risks to public health and
-------
|00
f G.
J
MW-S
I - - .
• V V. 1 C
FIGURE 11
TEST PIT LOCATIONS
SPRINGFIELD TOWNSHIP SITE
-------
TABLE 1
CHEMICALS OF CONCERN
SPRINGFIELD TOWNSHIP SITE
VOLATILE ORGANIC COMPOUNDS
2-Butanone
Chlorobenzene
To!uene
1,1,1-Tri'c hi o roe thane
Trichloroethylene
SEMIVOLATILE ORGANIC COMPOUNDS
Bis(2-ethyl hexyl )phthala'#>
Naphthalene
PCBs/PESTICIDES
Dieldrin
PCBs
INORGANICS
Arsenic
Bar i'.jri
Lead.
Cadmium
Chromium
-------
14
the environment caused by the contaminants identified at the
site. A summary of the findings of the Risk Assessment is
presented in the following sections.
6.1 Contaminants of Concern
Chemicals identified as chemicals of potential concern and used
in the risk assessment consisted of a variety of organics and
inorganics. The chemicals of concern were selected to represent
all organic classes (e.g., volatile organic compounds,
semivolatile organic compounds) and inorganics present at the
site. Nine chemicals of concern were detected in on-site ground
water monitoring wells and were evaluated in the risk assessment
based on hypothetical exposure through ingestion of ground water.
Eight chemicals of concern were identified based on the soil data
analyses and evaluated in the risk assessment based on
hypothetical exposure through direct contact with and ingestion
of contaminated soils. The chemicals of concern are listed in
Table 1. These chemicals have been used to evaluate toxicity,
exposure pathways and potential health risks for individuals
residing near the site or workers/trespassers on the site.
6.2 Exposure Assessment
Potential human exposure pathways evaluated in the baseline risk
assessment include direct contact and ingestion of soils and
ingestion of groundwater under current and future land use
conditions. Current conditions at the site include a fence,
though access can still be obtained. Future conditions include
modelling the effects of continued leaching of source materials
into the groundwater and the possibility that even deep
subsurface soils will be disturbed. Exposure pathways for the
sediments in the marshes in the vicinity of the Springfield site
were also examined.
The exposure pathways for soils assumed recreational exposures
for children (ages 6-15) and adults. It was hypothesized that
children would access the site six times per year for 3 years and
adults only once in their lifetime under the most probable case
exposure scenario. For a hypothetical worse case exposure
scenario, it was assumed that the site was unrestricted. Under
this scenario, children access the site once per week from May
through October for ten years; while adults access the site twice
per week or fifty times per year for ten years. The groundwater
exposure pathways assumed a lifetime of exposure, 70 years, at an
ingestion rate of two liters of water per day.
The concentrations of chemicals used in the Risk Assessment for
significant exposure pathways are presented in Tables 2, 3, & 4.
-------
Table 3
Chemicals of Concern in Soils
Direct Contact and Ingestion of Contaminated Surface Soil
(Onsite; 0-2 ft. depth, Present Conditions)
Average
Concentration
(ug/g)
Maviimim
Concentration
(ug/g)
2-Butancne
Toluene
1, 1, 1-Trichloroethane
Trichloroethylene
Bis (2-etnylhexyl) Rithalate
Naphthalene
Dieldrin
PCBs
Arsenic
Barium
Lead
Cadmium
Chromium
0.97
6.49 J
248.4
0.0001 J
0.48
.71 J
.72 J
.33
7.
1.
1.
19.74
1.60
765.9
283.9
49.64
18.08
68.87
390.0
18000
0.0050 J
25.00
350.0
63.00
48.00
680.0
12.00
18400
5470
196.0
128.0
J = approximate: During the data validation process, certain reported values
were qualified by a "J*' due to a variations in detection levels achieved.
Values qualified with a "J" are, however, real values. Where these "J"
values were used, the WJ" was retained and listed above.
-------
Table 2
Conoc
in Groundwater
(Onsite; Present Conditions)
Average
Concentration
(ug/1)
Oonoentration
2-Butanone
Qhlorobenzene
Toluene
1, 1, l-Trichlaroethane
Trichloroethylene
Bis (2-ethylhexyl) Fhthalate
Naphthalene
Dieldrin
PCBs
Arsenic
Barium
Lead
4.5 J
0.1 J
0.2
4.6 J
1.2 J
1.6 J
—
-
6.0
57.2
14.6
110.0
3.0 J
7.0
65.0
12.0
10.0
-
-
34.0
349.0
67.0
J = approximate: During the data validation process, certain reported values
were qualified by a "J" due to a variations in detection levels achieved.
Values qualified with a "J" are, however, real values. Where these "J"
qualified values were used, the "J" was retained and listed above.
-------
15
6.3 Toxicity Assessment
Using data generated during the RI, a site-specific baseline risk
assessment was conducted to characterize the current threat to
human health and the environment for each of the actual or
potential exposure pathways discussed in the above section.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)"1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
effects on humans).
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g. to account for the use of animal
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
Based on toxicological studies of the contaminants of concern
found in the soil and ground water at the site, some chemicals
are classified as carcinogens (PCBs, dieldrin, TCE, and arsenic)
and noncarcinogens (chlorobenzene, toluene, barium, and lead).
6.4 Risk Characterization
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 1 x 10~6 or IE-6). An excess lifetime cancer risk of
1 x 10~6 indicates that, as a plausible upper bound, an
individual has a one in one million chance of developing cancer
as a result of site-related exposure to a carcinogen over a 70-
year lifetime under the specific exposure conditions at a site.
-------
Table 4
Chemicals of Concern in Soils
Sub-Surf aoe
(Onsite - 2' - 100' depth; Future Potential
Conditions Assuming Excavation)
Average
Concentration
(ug/g)
iff im
Concentration
2-Butanone
Chlorobenzene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Bis (2-ethylhexyl) Bithalate
Naphthalene
Dieldrin
PCBs (Total Aroclor)
Arsenic
Barium
0.32
11.80 J
147.16
0.002J
.60 J
.20 J
.60 J
0.
9.
7.
37.36
1.9000
79.8000 J
71.4000
34.81
770.00
12650.00
0.03
48.00
510.00
330.00
3800.00
39.0000
4540.0000
3240.0000
J «= approximate: During the data validation process, certain reported values
were qualified by a "J" due to a variations in detection levels achieved.
Values qualified with a "J" are, however, real values. Where these "J"
values were used, the "J" was retained and listed above.
-------
Table 5
Risk Assessment Summary - Present Conditions
Springfield Township Site
Exposed Most
Population Scenario Probable
NCNCARCDtXENIC
Child Drinking Water 2.6 E-04
Surface Soil
Ingestion 1.0 E-07 8.3 E-03
Direct Contact 9.0 E-08 6.7 E-04
Total Risk 2.6 E-04 1.0 E-02
Adult Drinking Water 2.6 E-04 1.5 E-03
Surface Soil
Ingestion 1.6 E-09 1.7 E-04
Direct Contact 4.0 E-09 7.0 E-04
Total Risk 2.6 E-04 ^ 2.4 E-03
Child Drinking Water 0.40 1.62
Surface Soil
Ingestion 0.20 622.0
Direct Contact 0.17 53.0
Total Hazard Index 0.77 677.0
Adult Drinking Water 0.40 1.6
Surface Soil
Ingestion 0.16 6.3
Direct Contact 0.13 26.4
Total Hazard Index 0.70 34.3
-------
16
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
The U.S. EPA attempts to reduce risks at Superfund sites to a
range of 1 x 10-4 to 1 x 10-6, with emphasis on the lower end
(1 x 10-6) of the scale. Any HI value of greater than 1.0
suggests that a noncarcinogen presents a potentially unacceptable
toxic effect.
Under present and future potential conditions on-site for
exposure to contaminated soils, four chemicals (PCBs, dieldrin,
arsenic, and trichloroethene) have incremental cancer risks
within or above the target range under present realistic worst
case conditions, with the highest risk posed by PCBs and
dieldrin. However, under future potential conditions on-site,
incremental cancer risks are within or above the target range for
only two of the four chemicals, PCBs and arsenic. ("Present
conditions" is defined as potential exposure to chemical levels
that are currently found in the surfacersoil, and "future
potential conditions" is defined as the /conditions that would
exist if, in the future, the subsurface soil were exposed, under
recreational use, and there was no remediation.) In addition,
four chemicals (chlorobenzene, toluene, barium, and lead) pose a
potentially significant risk of noncarcinogenic adverse effects
under realistic worst case conditions.
Under present conditions on-site for ingestion of contaminated
ground water, lead poses a potential hazard index ranging from
0.001 to 622 of non-carcinogenic adverse effects, and arsenic
and trichloroethene pose incremental cancer risks ranging from
1.46 X 10 -3 to 1.53 X 10 -9. Under predicted future potential
conditions (using the Organic Leachate Model), both non-
carcinogenic and carcinogenic risks would be much higher than
under present conditions. Future potential conditions on-site
take into account chemical leaching from contaminated soils.
A summary of the risk characterization for the site is presented
in Tables 5 and 6. Very low risk was associated with exposure to
marsh sediments and is not presented in the table.
The site is fenced, so access to the contaminated soil is
temporarily restricted. Casual usage of areas in and
surrounding the site might possibly expose individuals to
potential airborne contaminated particulates. Ground water in
-------
17
the area is a source for residential drinking water. However,
data from the nearby residential wells indicated that the
contaminated ground water has not yet impacted individual
drinking water wells.
6.5 Environmental Risks
The effects of the contamination on the environment were
evaluated using potential exposures for PCBs, VOCs, SVOCs, and
inorganics. Current and future potential impacts to the
environment are primarily the adverse effects to terrestrial
wildlife which inhabit or feed in the fenced site area where high
levels of contamination were detected in surface soils (3,800 ppm
PCBs, 2,200 ppm cadmium, 5,470 ppm lead). The site fence
minimizes the intrusion of the large mammals and thus their
contact to contaminated soil or ingestion of on-site flora.
Sampling of nearby kettle wetlands indicated no impact from site-
related activities. No critical habitats or endangered species
are associated with the site.
7.0 Description of Alternatives
The FS Report presented several remediation alternatives for the
cleanup of the Springfield Township site. A complete description
of the alternatives and the criteria used to initially screen
them are provided in the FS Report. Initially 13 alternatives
were examined for remediation of the soil contamination and seven
alternatives were examined for remediation of the ground water
contamination. Through a pre-screening process in which each of
the alternatives were evaluated with respect to effectiveness,
implementability and cost, five soil remediation alternatives and
two ground water alternatives were retained for final evaluation.
The alternatives are summarized in the following sections.
7.1 Remedial Cleanup Levels
As explained in detail in sections 8.1.2 and 10.0 of this
document, U.S. EPA has used the framework outlined in the NCP to
•elect a remedy that will reduce the concentration of hazardous
substances to levels presenting a site risk of not greater than
1 x 10 -6 or background for carcinogens and a hazard index of one
for noncarcinogens. These levels also meet the cleanup criteria
described in Michigan Act 307 Rules for Type A/B cleanups
(hereafter referred to as Type A/B cleanup levels). The cleanup
levels for the Springfield Township site reduce the concentration
of hazardous substances either to levels presenting a 1 X 10 -6
risk or background for carcinogens (Rule 299.5711), to levels
protective of the aquifer (Rule 299.5711), to levels based on
-------
Table 6
Risk Assessment Sunnary - Future Conditions
Springfield Township Site
CAHZCNDG39HC
Most Realistic
Population gT?n^riQ Probable
Child Drinking Water
On-Site 1.8 E-03 1.7 E-02
Off-Site 6.3 E-O4 5.8 E-03
Deep Soil 1.3 E-07 2.9 E-03
(direct contact)
Total Risk 2.4 E-03 2.6 E-02
Adult Drinking Water
On-Site 1.8 E-03 1.7 E-02
Off-Site 6.3 E-04 5.8 E-03
Deep Soil 7.0 E-09 3.6 E-04
(direct contact)
Total Risk 2.4 E-O3^ 2.3 E-02
Child
MQNCARC
Drinking Water
On-Site
Off-Site
LLNDGUUC EPH4CTS
0.40
0.16
6.7
2.3
0.04
(direct contact)
Total Hazard Index 0.6 41.1
Adult Drinking Water
On-Site 0.40 6.7
Off-Site 0.16 2.3
Deep Soil 0^0^ 16.1
(direct contact)
Total Hazard Index 0.6 25.1
-------
TABLE 7
Levels for Chemicals
of Concern in Soil
at Springfield Township Site
(PIM)
Cleanup levels
on compliance
with ARARs
Dieldrin .08*
Barium2 100
t*>*d Background**
Arsenic Background**
Toluene3 .800
Chlorobenzene4 2.8 #
7CE1 .06
1 - value calculated using 10"6 cancer risk and Michigan Act 307.
2 - value calculated using proposed Maxijiura Contaminant Level Goal (MCLG)
in Michigan Act 307.
3 - value calculated using secondary maxiiam contaminant level in
Michigan Act 307.
4 - value calculated using reference dose (Rfd) in Michigan Act 307.
• .08 or background which ever is higher in Michigan Act 307
** Background in Michigan Act 307 establishes the Type A/B cleanup levels
which reduces the concentration of hazardous substances to levels of 1
X 10 ~6 risk-based level for carcinogens (Rile 299.5711), to levels
protective of the aquifer (Rile 299.5711 (1) (a)), to levels based on
taste and odor threshold concentrations (Role 299.5709 (d)} or to
detection limits or background concentrations levels at the
Springfield Township site.
-------
18
taste and odor threshold concentrations (Rule 299.5709 (d)), or
to detection limits or background concentrations.
Cleanup levels for contaminants in soil at Springfield Township
site are 1 ppm for PCBs; 100 ppm for barium; .8 ppm for toluene;
2.8 ppm for chlorobenzene; .06 ppm for TCE; .08 ppm or
background, whichever is higher, for dieldrin; and background
levels for lead and arsenic (see Table 7) . Cleanup levels for
contaminants in ground water are .04 ng/1 for toluene and .003
•g/1 for TCE, and background levels for arsenic and lead (see
Table 8).
U.S. EPA selected the Type A/B cleanup because it will assure
permanence, reliability, and long-term certainty of protection of
human health and the environment; implementation will be cost
effective given the small size of the site and the isolated areas
of high contamination; the toxicity of PCBs at very low
concentrations; the area is zoned residential and agricultural
and anticipated to grow in the next ten years with increased use
for recreational or other use compatible with human presence; and
the State and local community strongly prefer EPA's selected
remedy.
7.2 Volume of Soil Remediation
Based on the soil sampling data collected during the RI, an area
of surficial, subsurface and deep soil requiring remediation was
identified. The estimated depth of excavation for remediation
ranges from 3 feet to 32 feet and is based on the above defined
cleanup levels. The estimated volume of excavated soil is
calculated by converting the area of contaminated soils to cubic
yards using the proposed excavated depths. The areas of
excavation and proposed depths are depicted in Figure 3. Further
sampling during the remedial design phase will be used to define
the exact areas of excavation and total volume. Based on
available data, the estimated volumes are as follows:
Area to be
Excavated Area Volume
Surficial 0- 3 feet 3,687 sq. yds. 3,687 cu. yds.
Subsurface 0-15 feet 657 sg. yds. 3,283 cu. yds.
Deep Soil 0-32 feet 455 sq. yds. 4,849 cu. yds.
The total volume of soil remediation is estimated at 11, 820
cubic yards.
-------
19
7.3 Volume of Ground Water Treatment
The volume of groundwater was not determined for the FS, because
the contaminated ground water is not immediately impacting area
drinking water wells. However, the capture zone was determined
to be 1000 feet perpendicular to ground water flow and 300 feet
downgradient.
7.4 Soil Alternative 1: No Action
Under the No Action Alternative, U.S. EPA would not take any
action to remove or reduce contaminant levels on-site. Ground
vater would continue to be degraded. Institutional controls
(deed and land-use restrictions) would be necessary to limit
exposure to surface contaminants by restricting the future use of
the site and to protect human health from direct contact. This
alternative may be effective in the short-term by minimizing
worker exposure and potential impacts to the environment from
construction of treatment systems but is not protective over the
long-term. Institutional controls would not be effective for the
long-term because they do not reduce the toxicity, mobility
and/or volume of on-site contaminants. Periodic site inspections
would occur, determining the need for maintenance activities on
the site fence. Little reduction in risk to human health or the
environment would occur.
The capital costs for this alternative would be $9,213 for site
fencing extensions and deed restrictions. Annual site
inspections and maintenance could cost $8,315, giving the project
a present-worth cost of $87,601. This alternative is easily
implementable, but does not protect the public health and the
environment. This alternative will not meet the identified ARARs
for this site.
7.5 Soil Alternative 2: Off-site Land Disposal
This alternative would consist of the excavation and transport of
contaminated soil to an off-site, RCRA permitted, land disposal
facility. About 11,820 cubic yards of contaminated soils would
be excavated and hauled away by truck. This would not address
contamination in the deep soil at 85 to 95 feet below the
surface. Surface depressions left by excavations will be
backfilled with clean soil and graded to prevent surface water
ponding. The RCRA land disposal restrictions, which regulate
the land disposal of RCRA hazardous wastes, may severely limit
the implementability of this alternative.
It is estimated that six months - one year would be required to
implement this alternative. The capital costs for this remedy
-------
TABLE 8
Cleanup Levels for Chemicals
of Concern in Groundwater
at Springfield Township Site
(PFW)
Cleanup levels
Contaminant based on compliance
with ARARs
Toluene-' . 04
TCE1 .003
Arsenic Background**
Lead Background**
1 - value is 10~6 Cancer risk
3 - value is secondary maximum contaminant level.
** - Background in Michigan Act 307
-------
21
incinerated; they will be treated in the same manner as proposed
for the resultant ash
from the incineration. Not all the on-site contamination will
be addressed by this alternative, so that future monitoring and
perhaps additional treatment will be required.
Construction is expected to take six months to one year. Based
upon an estimated feed rate of 5 tons/hour, it will take
approximately six months to complete the incineration process.
Capital costs total $8,642,736. Annual operation and maintenance
costs total $5,618, giving a present-worth cost of $8,664,035.
If inorganics are immobilized in the incinerator ash,
solidification will be unnecessary and a savings of approximately
$2,660,000 would result, giving a present worth cost of
$6,004,035.
7.8 Soil Alternative 5: On-site Incineration,
Solidification, In-situ Vacuum Extraction
This Alternative, like Alternative 4, utilizes excavation,
incineration and solidification for the removal and destruction
of contaminated soil as described in Alternative 4 summary.
Alternative 5 also utilizes in-situ vacuum extraction to remove
and treat the organics which have migrated to the deep soil unit.
The system involves the installation of /wells beneath the surface
to create a negative pressure in the ungaturated zone. The
vacuum induces a flow of air through the soil, thereby
volatilizing VOCs that are absorbed on soil particles and
extracting the contaminants in the vapor phase. The subsequent
treatment of extracted soil vapors is usually accomplished
through use of a liquid/vapor condenser, activated carbon
absorber, combustion, or a catalytic oxidation unit.
In-situ vacuum extraction would require site specific field
testing to ascertain its effectiveness prior to full
implementation. This system is highly reliable for removing VOCs.
Alternative 5 will protect human health and the environment as
the soil contaminants will be destroyed, treated or isolated, and
the ground water degradation source will be eliminated.
Construction and implementation of the Alternative is expected to
take approximately one to two years. Capital costs are estimated
to be $8,853,613. Annual operation and maintenance costs total
an estimated $63,418, giving a present-worth cost of $8,991,668.
7.9 Ground Water Alterative 1: No Action
Under this Alternative, the only remedial response to the present
ground water plume would be to attempt to restrict future ground
-------
20
would be about $6,717,258. Annual maintenance costs would be
about $5,618, resulting in a present-worth cost of $6,738,556.
7.6 Soil Alternative 3: Surficial Capping
Alternative 3 consists of capping the surfaces of the site which
exhibit chemical contamination. This Alternative is similar to
capping required for closure under the Resource Conservation and
Recovery Act (RCRA) Subtitle C. However, horizontal migration of
hazardous substances may continue depending on the ground water
flow on-site. The cap would serve to prevent dermal contact with
surficial contaminants, as well as to significantly reduce
further leaching of subsurface chemicals by diverting rainwater
away from the contaminated soil. The cap also minimizes erosion
by wind and water preventing migration of contaminants in the
soil. The cap system would consist of a 24 inch layer of
compacted clay, a synthetic liner, another 24 inches of earthen
materials, and finally clean topsoil and vegetation. Periodic
inspections and maintenance would be needed to maintain the
physical integrity of the cap to insure against further risk and
to evaluate the effectiveness of the cap to reduce horizontal
migration.
It is estimated that four months would be required to implement
this remedy. Capital costs total $753,740 for this remedy.
Annual inspection, maintenance, and security costs total $17,080,
resulting in a present-worth cost estimate of $914,752. The
technology required for this remedy is well established.
However, the potential for noise and dust problems exists during
construction.
7.7 Soil Alternative 4: On-site Incineration,
Solidification
The same volume of soil excavated for Alternative 2 would be
excavated and incinerated on-site for this Alternative. Thermal
destruction by incineration will permanently treat the PCBs,
VOCs, and pesticides currently contaminating the soil in the
excavated areas. The deep soil contamination will not be
remediated by this option but will be left on-site untreated.
The metals in the resultant ash will effectively be immobilized
by solidification, if the ash does not pass the required tests.
The treated ash will no longer be considered RCRA hazardous waste
once it no longer exhibits the characteristic of toxicity.
Treatment to stabilize the metals will render the ash inert. A
treatability study will be conducted to select the most cost-
effective method of solidification. The solidified ash will be
backfilled on-site, and the solidified material will be covered
with clean soil up to the previous grade. Those soils in which
only metals are detected above cleanup levels will not be
-------
23
health, attains applicable or relevant and appropriate
requirements (ARARs) , is cost-effective and represents the best
balance among the evaluating criteria (see Table 9). Comparisons
are based on the nine criteria, as determined to be applicable to
this final remedy, outlined in the National Contingency Plan
(Section 300.430(e) (9) (iii) and Section 121 of CERCLA, as amended
(Clean-up Standards) .
The nine criteria are summarized as follows:
Overall Protection of ljum,an Health and the Environment-
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
Compliance with ARARS (Applicable or Relevant and
Appropriate Requirements! -addresses whether or not a remedy
will meet all of the applicable or relevant and appropriate
requirements (ARARs) of other environmental statutes and/or
provide grounds for invoking a waiver.
Long-term Effectiveness and Permanence-refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time once cleanup goals have been
net.
Reduction of Toxicitv. Mobility, or" Voluiflf-is the
anticipated performance of the treatment technologies a
remedy may employ.
Short-term Effectiveness-involves the period of time needed
to achieve protection and any adverse impacts on human
health and environment that may be posed during the
construction and implementation.
Implementability-is the technical and administrative
feasibility of a remedy, including the availability of goods
and services needed to implement the chosen solution.
Cast-includes capital and operation and maintenance costs
and present worth.
Support Agency Acceptance-indicates whether, based on its
review of the RI/FS and Proposed Plan, the support agency
concurs, opposes, or has no comment on the preferred
alternative. This acceptance will be assessed from support
agency comments received during the public comment period.
Community Acceptance-will be assessed later in this Record
of Decision.
-------
22
water use through institutional controls and to monitor the
potential migration of contaminants off-site. Supplemental
monitoring wells would be installed on-site to help track the
plume. Bi-annual sampling of the wells would occur, and a
contingency plan for future site action would be developed if the
contaminants exceed predetermined limits.
The present-worth cost of this Alternative is estimated to be
$504,613. Capital costs for placement of additional monitoring
wells total $6,742. Annual operation, sampling, and maintenance
costs total $52,813. Additional costs may be incurred at a
future time if off-site drinking water wells are degraded by the
Springfield Township site plume. These costs have not been
calculated at this time. The remedy is easily implemented, but
ARARs are not met.
7.10 Ground Water Alternative 2: Ground Water Extraction
and Carbon Adsorption
This Alternative would utilize a system of extraction wells to
arrest and reverse the movement of the ground water plume on-
site. The pH of the extracted ground water would be lowered to
approximately 4.5 to enhance subsequent adsorption. Activated
carbon is then employed to remove TCE, toluene, lead and arsenic.
TCE would be treated to a target cleanup level of .003 mg//l and
toluene to .04 mg/1, and arsenic and le$d would be treated to
reduce their concentration to background levels. The area of
attainment would be throughout the area of the plume.
Following treatment, it is anticipated that the cleaned water
would be discharged back into the ground water system after the
pH is readjusted to the neutral range. The carbon would be
monitored for buildup of radon decay products and, if necessary,
may require disposal as a radioactive waste. It is anticipated
that the carbon units will be regenerated for reuse in the
treatment system. Additional ground water sampling will be done,
if necessary, during remedial design (RD) to redefine the extent
of ground water contamination. The ground water remedy will be
refined based on sampling conducted during RD.
It is estimated that one to one and half years would be required
to implement this alternative. Capital costs are estimated to be
$47,467 and annual operation and maintenance costs are projected
to be $61,241. The present-worth cost is estimated at $279.622.
8.0 Summary of Comparative Analysis of Alternatives
Alternatives were evaluated against each other to determine the
most appropriate alternative for remediation of the on-site soils
and ground water contamination that is protective of human
-------
TABLE 9 cont.
it tern* »• Protectlvenest
Koote x
1 Ho »i Ion Somewhat
protective
(monitorlnq)
t»tri tlon Remedy Is 'ully
Carb * protective.
*d»0' t Ion
long- tern
ll»ettlve'*is
•
Institutional cxitrolt
may be inrcllnt.le,
Concentrations of
C n^*ni c ( I S fR0y
1 f^c r^n)c ,
Inqrltlon r Uk wit 1
reduced.
Short -term
Inst (tut ion.il control'.
may be reliable iver
Short • term
Air emissions may
increase slightly.
Possible carbon
disposal problems.
• edt» tm of tnttclty
Mobf ir, or Volifn* Implcmentabl 1 My Co-,
No r • '• t ion o' t A S*ly A.
1.
toil* tv. ffx>bilttyt ii*pl emrnt etf .
or v unp ol
Cool' m.lltS.
• «xji> '. to'ieity C.irbon Is very '•
b .
o( w rrs. vohnr reliable, tosy c
and' hility to inplemcnt
ol f -meals.
Copfunity
tttt*
Complltnt
•no.eu
IRtD( »rp Won?
r«ot met
Hone
61,?4?
Acceptable Acceptable
• re "Ct
Preftn d »l terntt lve»
a. ( pit«l costs
b. ' rual operation »nd maintenance
c. I esent-tiorih cost
-------
1AULI 9
ALTIRNATIVC I VALUATION
Alternative
1. Ho Action
I. Olf-SItt
land Olspos.il
J. Capping
4. On- lit*
Inclnerat 'on
Jolldlf lean-in
*
J. On-«ltt»
Incineration/
Solidification
and In-tltu
toll Vapor
extraction
long- turn
Protect ivenrs* 1 f feet lv>ess
• isltS »rt not Inst ilul tonnl controls
•Hrnu.io-iy cviy l>e u certain.
reduced potentia' for M-
ditiongl remprli nt ion.
• is*s re-vr.f.
Direct fntitact, a'paUs "»y be
• T ion ri)t" protect '•••.
reduced
Remedy is not Some hazards
fully will be
protective. addressed.
lewedv It fully •educe-.! potential far
protective. hirwm exposure to
soil ftf-Vor
Contamu*nt mlqrgtion
to qrounrfwater.
Shof t • term
f f f PI t i vrn«". s
Inst t tut ion.il controls
mny !«• rel i»hle
over the short trri"
Potential for noise,
emissions oVi'tr*)
eicnvntions n'v)
Potential for noi',e
BrvJ dust dur in.)
Construct ion.
Potential for noisr,
dust, and air
excavation, nni|
incineration.
Increased potential
for noise, dust, and
air emissions
especially If off-
site Incineration
occurs.
PMuctinn of to«icM<
»'.liil Ity, or Voliit.
Mo rr-VlCt ion of
•lit ir ity, mnl,)) i(y_
or volume ol
ronto^lnnnu..
Ho reduction, only
1 rnnsfer to .1 more
"si-cure" fnc i 1 i ty.
No r rrVic t ion in
t i'i ic 1 1 y or vol irv
M..(il lily 1'. 1 r-lurf
Over shor t • t Cf i"
Cnntnminnnts ore
flrstt oyrd or
•'$;•.""" " '"* '
Siqni f icnnt
reduct ion ol
ton ic Ity, mrhil ity.
nml volu?ne o*
cont.imin,int \.
»t»f» Crminity St.it*
|mpl emrnt .itn 1 1 1 y Cost (%) Compliance iccept*n-n nrertrd
lor mnbi le
inc inrr nt or .
• Preferred »liernmivrs
n. C.ipilnl rosls
h. »iwi«l oprr.ilion nnd
c. Presrnl-Mor|h cost
-------
TABLE 10
ARARs
ALTERNATIVES
A
R
MCI 299.35« and MAC
299.3313 to 299.3317
42 U.S. C. 7401 Jt.
seo. and 40 CFR 50.
52
Executive Order
11986 and 11990 and
40 CFR 6. Appendix A
(Wetland and
Management
MCI 299,601 £t. seq.
MAC R. 299. 5101, et
seo. Parts 6 and 7
(Michigan
Environmental
Response Act)
No
Action
X
NA
X
X
Off-Site
Land
Disposal
X
X
X
X
Surficial
Cap
X
X
X
X
Incin
soil
solid of
ash
X
X
X
ff -.
X
Incin. soil
sol id of
ash, SVE
X
X
X
X
CW punp
» treat
carbon
absorpti
on
NA
X
X
X
-------
24
8.1 Threshold Criteria
The criteria outlined above are commonly grouped into three
groups: threshold criteria (the first two), balancing criteria
(the next five), and modifying criteria (the last two). The two
threshold criteria must be satisfied by any proposed remedy if it
is to be further considered. The balancing and modifying
criteria are used to evaluate the strengths and weaknesses of the
variously accepted threshold criteria and to thereby assist in
the choices of an alternative.
8.1.1 Overall Protection of Human Health and the Environment
The soil alternatives, with the exception of the No Action
Alternative, would provide at least some protection of human
health and the environment by preventing direct contact with
contaminated soil. However, the contaminated soil extends to the
ground water and is a potential source of degradation of the
ground water. The off-site land disposal, the surficial capping,
and the on-site incineration, solidification alternatives provide
limited protectiveness because these alternatives only partially
address the soil contamination. VOCs present in the deep soil
unit would not be eliminated, reduced or removed and could
potentially leach to the ground water. Alternative 5, On-site
Incineration, Solidification, In-situ Vacuum Extraction would
remediate the entire soil column, thereby providing protection of
human health and the environment by eliminating the threat
through direct contact and removing the source of continual
ground water degradation.
The No Action Alternative for ground water does not provide
protection of human health and the environment through ingestion
of contaminated ground water since it only proposes to monitor
the plume. Ground Water Alternative 2, Ground Hater Extraction
and Carbon Adsorption, would be protective of human health and
the environment, because it would treat the contaminated ground
water until cleanup levels were achieved.
8.1.2 Compliance with ARARs
Table 10 lists the operational ARARs for the Springfield Township
site. It only lists those ARARs necessary for on-site remedial
activities. In some instances, rules cited contain both
substantive and procedural or administrative requirements. Only
the substantive requirements are ARARs for the purpose of on-site
activities. Examples of administrative or procedural
requirements which are not considered ARARs include, but are not
limited to, reporting requirements and permit application
requirements.
-------
TABLE 10
(Continued)
ALTERNATIVES
R
A
R
NCL 691.1201, et. SfrQ.
(Anderson Gordon
Rockwell Environmental
Protection Act of
1970)
NCL 325.201 et. sea.
•nd MAC R 299.2901-
299. 2927 (Water Works
and Sewerage System
Act)
NCL 319.211 et. sea.
•nd MAC 299.2201-299.
2229 (Mineral Well
Act)
MCL 281.701 £t. seg.
and MAC 281.921-
281.925 (Goemeere
Anderson Wetland
Protection Act)
NO
ACTION
X
NA
NA
X
OFF-SITE
LAND
DISPOSAL
X
NA
NA
X
SURF1C1AL
CAP
X
NA
NA
X
INCIN.
SOILS
SOL10IFICA
T-ION OF
ASH
X
NA
NA
^-.
X
INCIN.
SOIL
SOLIDIFICA
T-ION OF
ASH, SVE
X
NA
NA
X
GU PUMP «
TREAT,
CARBON
ABSOPRTION
X
X
X
X
-------
TABLE 10
(continued)
ALTERNATIVES
A
R
40 CFR 141 (MCLs and
non-zero MCLGs for
Constituents of
concern
MCI 282.101 £t. seq.
•nd MAC 323.1701-
17U (Soil Erosion
•nd Sedimentation
control Act)
NCI 336.11 et. seq.
and MCA 336.1201 et.
seg.; 1301 et. seg.;
1701 and 1702 and
1901 et. tea. (Air*
Pollution Act)
49 C« § 107. 171.1-
171.5 (Packaging and
Shipping
requirements for
off-site
transportation
40 C« 268
No Action
X
NA
NA
NA
NA
Off-Site
Land
Disposal
X
X
X
X
X
Surficial
Cap
X
X
NA
NA
NA
Incin.
soils,*
sol idif ica
tion of
ash
X
X
X
/**
V
X
Incin.
•oils.
solidif ica
tion of
ash SVE
X
X
X
NA
X
GW punp
« treat,
carbon
absorpti
on
X
X
X
NA
NA
applicability of these rules will depend on the source of
emissions exceeding threshold quantity limits specified in
the rules for applicability.
-------
TABLE 10
(Continued)
ALTERHATIVES
R
A
R
MC 323.2201
H. sea.: and
NCL 323.1
i£. «eo.« (yater
•.•source
CeaBision Act)*
MC 299. 4101
It. sea. 4301 et.
sea, and 4601;
U. sea. NCL
299.401, H- sea.
(Sol id
Waste
Act)
NCI 299.501
ej. sea, and MAC
.299.9301 9401. 9501,
9601 it. sea.
(Hazardous Waste
Narisytaarit Act)
MCL 325.1001
and MAC
R. 10601,
et. sea.
Part 6
* The Sta1
Sti
No
Action
X
X
X
NA
Off-Site
Land
Disposal
X
X
X
NA
Surf icial
Cap
X
X
X
NA
Incin.
soils
solid-
ification
of Ash
X
X
NA
Incin.
solid
ifiation
of ash,
SVE
X
X
X
NA
CW punp +
treat
carbon
absorption
X
NA
X
X
be of Michigan has identified the Act as a
ite ARAR. The U.S. EPA disagrees.
-------
TABLE 10
(Continued)
ALTERHATIVEB
A
R
MCA 325.1666
(Abandonment of wells)
40 CFR 761.40, 60,79
and 40 CFR 266.42 (PCS
Requirements)
40 CFR 144,
146, 264. (Construct ion,
operation, maintenance
plugging, and
abandonment of
extraction, injection
and monitoring welts)
No
Action
NA
X
NA
Off-site
land
Disposal
NA
X
NA
Surficial
Cap
NA
X
NA
Incin.
soils
•olidifica
tion of
NA
X
NA
tncin.
soildifica
tion of
solids,
SVE
NA
X
NA
CW pump «
treat
carbon
absorpt i on
X
NA
X
-------
26
8.2.1 Long-tern Effectiveness and Permanence
The long-tern effectiveness criterion primarily requires
assessing the magnitude of residual risks remaining after an
alternative has been implemented and the remedial action
objectives have been met. Long-tern effectiveness of each
alternative's inpact on human health and the environment through
direct contact would be inproved by all of the soil alternatives,
except the No Action Alternative, by either containing, removing,
or treating the surface soil contamination. However,
Alternatives 2 through 4 would not address the contanination in
the deep soil unit, so long-term maintenance, operation,
monitoring and potential ground water treatment would be required
to ensure protection of the public health and the environment and
achieve a level of long-term protectiveness equivalent to that
provided by Soil alternative 5. Soil Alternative 5 remediates
the entire contaminated soil strata to cleanup levels that are
in compliance with all ARARs, and eliminates the need for any
further soil or ground water remediation once the soil and ground
water cleanup levels are attained.
Ground Water Alternative 2 would remove the contaminated plume
from the aquifer ensuring its safety as a drinking water source.
This Alternative would reduce the threat of ingesting
contaminants upon completion of the remedy. The source of
degradation of the aquifer would have to be removed to eliminate
the need for long-term maintenance and monitoring of the ground
water. This Alternative would have to be coupled with a soil
alternative which eliminates the source of further ground water
degradation to achieve long-term effectiveness and permanence.
8.2.2 Short-term Effectiveness
Short-term effectiveness considers the effects that result during
the implementation of the alternatives. Except for the No Action
Alternative, the soil alternatives pose a potential for noise,
dust and air emissions which may affect the workers during
excavation, hauling, construction, and/or incineration of the
contaminated soil and preparation of the site for remedy
implementation. Standard health and safety procedures would be
followed by workers. Community protection from indirect adverse
effects such as noise, air emissions, dust, and truck traffic
during the remedial activities will be minimized. Monitoring for
emissions would be performed during the excavation and dust
control measures would be enforced. Incineration increases the
likelihood of impacts to the on-site workers, area residents and
surrounding environment due to its method of treatment and
requirements for operation. There are safeguards which can be
incorporated into the incineration operation to insure its
compliance with safety guidelines and regulatory requirements.
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25
Only Soil Alternative 5, as developed in the FS and the Proposed
Plan, satisfies all identified ARARs for remediating the soil
contamination without development of further actions (e.g.,
implement at ion of a long-term ground water monitoring and
treatment system to clean any ground water contaminated by deep
soil contamination). Soils which are found at depth are
contaminated with VOCs and SVOCs and may continue to degrade
ground water quality. Since these contaminants remain on-site
with Soil Alternatives 1 through 4, these alternatives, without
further refinement or remedial action, do not satisfy all ARARs
identified in attached Table 12. As examples, these four
alternatives do not, by themselves, adequately treat or contain
the contaminated soils in a manner which would satisfy the "RCRA-
type-closure requirements of Michigan Act 64" (e.g., neither
removal of all contaminated subsoils nor long-term ground water
monitoring program to detect and remediate contaminated ground
water), or the preferences in Michigan's Act 307 Rules or SARA to
permanently reduce the volume, mobility or toxicity of the
hazardous substances. These alternatives may be redesigned or
combined with other remedial actions (e.g. ground water pump and
treat) to meet all of the identified ARARs. For instance,
Alternative 5 is a refinement of Soil Alternative 4 in that by
adding Soil Vapor Extraction to Soil Alternative 4, the deep soil
contamination is remediated and the potential for future ground
water contamination should be eliminated. Additionally, Soil
Alternative 2 is not consistent with SARA and the Act 307 Rules
in that it calls for disposal, the least preferred remedial
method. Soil Alternative 2 may also require further treatment of
the contaminated soils prior to their off-site disposal if it is
to comply with the RCRA land ban restrictions.
Ground water Alternative 2 would meet all respective applicable
or relevant and appropriate requirements of Federal and State
environmental laws. The No Action Alternative would not meet all
ARARs.
All treatment systems would be designed to operate in compliance
with ARARs.
8.2 Primary Balancing Criteria
Five primary balancing criteria are used to identify major trade-
offs between protective, ARAR-compliant remedial alternatives.
These trade-offs are ultimately balanced to identify the
preferred alternative and to select the final remedy. The five
criteria are as follows:
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27
Measures will be taken to minimize any adverse effects from the
handling of the soils and ash.
Air emissions may increase slightly during the ground water
treatment; however, air emissions would be monitored to comply
with Federal and State regulations. Spent-carbon units would be
treated and disposed at an off-site RCRA permitted facility. The
No Action Alternative would have little to no short-term impacts.
8.2.3 Reduction of Toxicity, Mobility, or Volume Through
Treatment
Soil Alternatives 2 and 3 would not reduce the toxicity,
•obility, or volume of the contaminants through treatment. Off-
site disposal would only remove the contaminants in the surface
and subsurface soil from the Springfield Township site and place
it in a disposal area which is controlled and monitored.
Surficial capping of the site would contain the contaminants and
reduce the infiltration process; however, it does not treat the
toxicity, or volume of the hazardous substances. Soil
Alternative 4 would reduce the toxicity, mobility, and volume of
contaminants through treatment in the surface and subsurface
soil, but it would not address the VOCs in the deep soil unit
which would continue to degrade the ground water. Soil
Alternative 5 would achieve this criterion by destroying or
immobilizing the contaminants in the surface and subsurface soil,
and removing the contaminants from the deep soil unit with the
use of the in-situ vacuum extraction system.
Ground Water Alternative 2 would reduce the toxicity, mobility
and volume of the contaminants by extracting them with the
activated carbon unit and subsequently regenerating the unit or
properly disposing of it. The No Action Alternative would not
satisfy this criterion.
8.2.4 Implementability
Soil Alternatives 2 through 5 utilize technologies that are well
established and easily implemented. Off-site land disposal would
require that licensed and permitted haulers be hired to haul the
waste and that a permitted special waste landfill be available to
receive the waste. The implementability of the off-site disposal
alternative will be affected by the treatment of these wastes
prior to their off-site disposal so as to comply with the RCRA
land disposal restrictions. Transportable incinerators have been
utilized at other Superfund sites and have been effective in
achieving the cleanup levels. The incinerator for Soil
Alternatives 4 and 5 would require site specific design
specifications and trial burn tests to insure that destruction
and removal efficiencies (ORE) are achieved. In-situ vacuum
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28
extraction is a simple technology that has been used
successfully. Soil Alternative 5 would require pilot testing of
the in-situ vacuum extraction and trial burn tests of the
incinerator.
Ground Water Alternative 2 technology is veil established and
easily implemented.
8.2.5 Cost
Cost comparisons of the soil alternatives are based on present-
worth costs. The No Action Alternative is the least costly of
the alternatives, however, it provides extremely limited
protection of human health and the environment. The least costly
of the containment or treatment soil alternatives is surficial
capping, however, it, by itself, does not meet ARARs and does not
satisfy the statutory preference for treatment to the maximum
extent practicable. The two soil treatment alternatives (4 and
5) are comparative in price for present-worth costs ($8,664,035
and $8,991,669, respectively). Soil Alternative 4 does not
address the source of degradation of the ground water, and could,
therefore, add additional costs in terms of a long-term ground
water remediation and monitoring program. The additional cost
incurred with Soil Alternative 5 would provide a complete
remediation of the soil, requiring no monitoring and eliminating
degradation of the aquifer. ^
Ground Water Alternative 2 is less costly than the No Action
Alternative, for remediation of the ground water would be
accomplished in a short time period compared to the long-term
maintenance and monitoring required in the No Action Alternative.
Alternative Capital Cost Annual Operation Present-
and Maintenance Worth Cost
Soil
No Action $ 9,212 $ 8,315 $ 87,600
Off-site Land
Disposal $6,717,258 $ 5,619 $6,738,557
Surficial
Capping $ 753,739 $ 17,080 $ 914,752
On-site
Incineration/
Solidification $8,642,737 $ 5,619 $8,664,035
-------
29
On-site
Incineration/
Solidification/
In-situ Vacuum
Extraction $8,853,613 $ 36,419 $8,991,669
Ground water
NO Action $ 6,742 $ 52,814 $ 504,614
Ground Hater
Extraction/Carbon
Adsorption $ 47,467 $ 61,242 $ 279,622
8.3 Modifying Criteria
These two criteria reflect the comments and concerns of the State
and the local communities on the alternatives presented to
address the Springfield Township site contamination. These two
criteria are as follows:
8.3.1 Support Agency Acceptance
The Michigan Department of Natural Resources had been the lead
agency for the emergency and removal activities and the RI. The
lead for the project was transferred to/gthe U.S. EPA in 1988 for
completion of the FS. The MDNR has proVided support and reviewed
this Record of Decision. A Letter of Concurrence is attached to
this ROD as Attachment 1. The MDNR in its June 29, 1990 letter
indicated a strong preference for a Type A/B cleanup for the
site. MDNR clearly indicated their rationale for this
preference, and is in agreement with the cleanup levels and
remedy selected for this site as contained in this Record of
Decision.
•
8.3.2 Community Acceptance
The comments and concerns from the public regarding the
Springfield Township site and the Proposed Plan are addressed
with the Responsiveness Summary which is Attachment 2 to this
ROD. In summary, the community is strongly in favor of the
proposed remedial action for the site and for the cleanup levels
established.
9.0 The Selected Remedy
Based on the findings of the RI/FS and the documents within the
Administrative Record and the results of the public comment
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30
period, the components of the selected remedy for the Springfield
Township site are as follows:
Soil Alternative 5: On-site Incineration, Solidification,
In-situ Vacuum Extraction
-Maintenance of the existing fence and, if necessary,
expansion of the fence to secure the site during
remediation;
-Trial burn test of the incinerator to demonstrate its
effectiveness and compliance with performance standards set
forth in 40 CFR 264, Subpart O and to determine
characteristics of residual ash, operating parameters and
limits, and expected emissions;
-Excavation and thermal destruction of contaminated soils to
the specified cleanup levels for polychlorinated biphenyls
(PCBs), volatile organic compounds (VOCs), semi-volatile
organic compounds (SVOCs), and pesticides from designated
areas;
-Solidification of incinerator ash according to ARARs;
-Solidification of soils contaminated only with
metals; /
-Redeposition of ash and treated soils on-site (the ash will
either be stabilized to make it inert prior to its on-site
disposal or will be placed in a properly designed waste unit
on-site);
-Recontouring of the excavated areas and control of the ash
or dust emissions;
-Installation of an in-situ vacuum extraction system to
remove VOCs and SVOCs consisting of a network of an
estimated 12 wells, screened in the unsaturated soils and
finished just below the water table, at the identified areas
of contaminated soils; the exact location and area
circumscribed by the system will be defined during the
remedial design phase of the RD/RA;
-Pilot test of the in-situ vacuum extraction system to
demonstrate its effectiveness and its compliance with
cleanup and performance standards; and
-Treatment of off-gases from the in-situ vacuum extraction
operation using vapor-phase carbon units.
Ground Water Alternative 2: Ground Hater Extraction/Carbon
Adsorption
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31
-Installation of a ground water extraction system with a
minimum of two extraction wells pumping at a minimum of
10 gpm to capture the contaminated plume plus the necessary
number of injection wells to handle the treated ground
water; development and preparation of detailed design of
system during the design phase; and
-Pilot test of ground water extraction and carbon adsorption
to demonstrate its effectiveness and its compliance with
performance standards.
The goal of this remedial action is a clean closure which will
treat the contaminated soils and ground water to the Michigan
Type A/B cleanup levels. This will restore the ground water to
its beneficial use as a drinking water source and eliminate the
direct contact threats resulting from the contaminated soils and
potential for further degradation of the aquifer. Based on the
information obtained during the RI and the analysis of all
remedial alternatives, the U.S. EPA and the State of Michigan
believe that the selected remedy will achieve this goal.
The selected remedy will include excavation and incineration of
contaminated soils which are expected to take six months to one
year for construction and six months to one year to complete the
incineration process; in-situ solidification of soils
contaminated only with metals (duration^time has not been
estimated); in-situ vacuum extraction Wfiich is expected to take
approximately one to two years for construction and
implementation; and ground water extraction and carbon adsorption
of the contaminated plume which is expected to take three to six
months for construction and approximately one to two years to
complete treatment of the groundwater.
The selected remedy will be carefully monitored on a regular
basis and adjusted as warranted by the performance data collected
during operation. Possible modifications to the remedy will
include:
-reprocess the soil through the incinerator should testing
indicate that cleanup levels of organics are not achieved;
-solidification of incinerator ash according to ARARs; and
-reactivation of the ground water treatment system or
implementation of other activities, should monitoring
indicate that concentration levels of contaminants have
increased above the aquifer final remedial action goals.
The projected remedial action costs for the selected remedy are
$8,853,613 for capital costs, $36,418 for annual operation and
maintenance costs, resulting in $8,991,668 for present-worth
costs for the soil remediation alternative (Table 11); and
-------
TABLE 11.
SOIL ALTERNATIVE NO. 5
ONSITE INCINERATION/SOLIDIFICATION/
IN-SITU VACUUM EXTRACTION
COST ESTIMATE
CAPUA! AMD HUD COSYS
UE«
OUAHT11Y
UMITS
UHM COST
lOUl
SITE rtEPAIATION
1. SITE ClEAtJNC
2. SITE WAD IMC
3. 0UVU SUSSASE
4. rcMCiMC
S. MOBU1UTIOM (ITEMS 1-4}
SOU TIEATNENT
1. tUOT TEST *UIM
2. WELL AIAMDQMMENT
3. SHEET P1LIXC
4. SOU CICAVATIQN
5. TMEtftAL TIEATMENl
6. SOLtOIMCATION
7. SACtflLL AID BECOMPACT
6. flHAL CO Vie
9. HMAL WASUG
10. TOPSOIL
11. VEGETATION
12. WELL IEPLACEMEN1
13. NOC1L12. (ITEMS 2-4. 7-12)
14. UCIHEIAT10N HOIlLlZATtOM
SOU VAPO* TIEATMEWT
1. SITE PIEPAIATIOM COUTUCENCT
(OME TIME COST)
2. INITIAL PU01 TEST
I. CAPPIMC
i. EITIACT10* WELLS (17)
S. Alt «AKOll«C STSTEM
(llOWEI AND DUCTUC)
A. CAtlOv ADSOKPTIO* TIEATMiNT
STSTEM (75 C'N)
7. IIHAUST CAS nx not me
1. VEtlMUTlOk SOU SAHPLIHC
AMD AKA1TSIS
1.55
4,200
1.«00
saoo.oo
i
i
7
10.000
11.870
11.620
10.636
12.766
5.200
16.000
1.800
16.000
7
1
1
ONE WEEK
1500
S50
4
1
4 PEI WEEl
20
ACtE
CU. TO.
CU. TD.
IIKEAI fl.
LUMP SUM
LUMP SUM
EACH
so. n.
cu. TD.
CU. TD.
CU. TD.
CU. TD.
CU. TD.
SO. TD.
CU. TO.
SO. TD.
EAC«*
LUMP/*U*
LUMP-SUM
CU. TD.
fEET
STSTEM
UNIT
rot OME TEAK
SAMPLE
3,n2.95
J.93
11.24
13.46
101
SUITOTAL
150.000.00
674.22
20.23
13.48
300.00
250.00
11.24
5.62
1.69
6.74
0.56
1.64S.5S
lOi
500,000.00
10.000
13.50
50
22.000
16.000
127
127
S6.096.07
16.506.00
20.232.00
10.784.00
5.361.61
S56.979.6E
S150.0DO.OO
4.7lP.ii
202.30C.CD
159.3JJ.6C
5.546.00C.CC-
2.659.500.00
14J.485.8-
29. 2?. .DC
27.040.0:
12.132.0:
6, 96:. CO
V.796.SV
5l.39J.7t
5oc.oo:.o:
i.occ-.o:
lo.ooc.o:
2C.25C.O:
2'.5o:.c:
BE.OOC.O:
i6. o::.::
26.416 ::
2.S-: ::
sucou.
-------
Table 11, cont.
WASTE CNACACTEtlZATIQN
1. -MILE LAftOMTOll
X. »llLO Cut" III
.5. lA»«ATOtT ANALYSIS
6
6
400
MONTHS
"JONTNS
tAAPLES
J.3T1.10
7.«6S.90
$61.8$
MTOTAL
TOTAL CAPITAL AMD MXED COSTS
CONTINGENCIES (SS)
ENC1NIEI1NC AMD ADMINISTIATION (SI)
TOTAL
S20.226.60
47.10$,40
224.740.00
S792.162.0C
8.&46.TJ9.47
402.4J6.97
402.4)6.97
M.B5J.6U.4?
O»EKAT10ft AND MAIIITEMANCE COSTS
ANNUAL CCS'
1. riNCINC AND SECUSITt
2. Alt (LOWER
3. IEPLACEMENT ACTIVATED CAIBO.
MESENT UOfTK COS! (r«<) yetrt. i«10S)
TOI»L
J.61B.SC
2D.oo:.o:
10.BO:.oo
M.W..66E f
ASSUMPTIONS USED IN THE DEVELOPMENT Of COST ESTIMATE
1. This cost cstiMte wtt pr*p*rtd uking eoct* eer>iifl»rttf appropriate those
i«d **»»*.
• -SOS to *Sn range.
2. Costs tstiiMttd
S. Unit cost for th«rwt trt«t«mt is considered • typieil vtndor Quote
to ircluOe •oeililttion. ioplomenttt tori, ond OC*r«iion »nfi Mim»r\*nce
of on- tit*
4.
o<
t(
in fipur* t-\ of tr,i» report.
S. field Chtnilt to conOuct «ir ojonitoring during project ioplownttt ion.
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32
$47,467 for capital costs, $61,241 for annual operation and
maintenance costs, resulting in $279, 622 for present-worth costs
for ground water treatment (Table 12). Total present-worth for
the selected remedy is $9,271,290.
10.0 The Statutory Determinations
U.S. EPA's primary responsibilities at Superfund Sites are to
undertake remedial actions that are protective of human health
and the environment. In addition, Section 121 of CERCLA
established several other statutory requirements and preferences.
These specify that when completed, the selected remedy must
comply with ARARs under Federal and State environmental laws,
unless a statutory waiver is justified. The selected remedy must
also be cost effective and utilize permanent solutions and
alternative treatment or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment to permanently and
significantly reduce the toxicity, mobility or volume of
hazardous substances, pollutants and contaminants. The following
sections discuss how the selected remedy, where applicable, meets
the statutory requirements and preferences.
10.1 Protection of Human Health and the Environment
The selected remedy will be protective of human health and the
environment through destruction and/or stabilization of
contaminated soils and by the extraction and treatment of
contaminated ground water. The human health threat via direct
contact with contaminated soils and ingestion of contaminated
ground water will be eliminated as well as the environmental
threat via off-site migration of contamination and ingestion,
direct contact, and/or bioaccumulation of contaminants in flora
and fauna. Upon remediation, carcinogenic risks presented by the
site will not exceed 1 x 10 -6 or background and hazard indices
will not exceed one.
Protection of human health and the environment will be achieved
by the selected remedy by the excavation and incineration of
surface and subsurface contaminated soils, solidification of
•oils contaminated with inorganics only, solidification if
necessary of incinerator ash, and in-situ vacuum extraction of
organics from contaminated soils in the deep soil unit. The
•elected remedy also calls for treatment of the ground water by
extraction and removal of contaminants by a carbon adsorption
unit. The used carbon adsorption units will be properly handled
and disposed.
Upon certification of completion of the selected remedy, the
site will be fully remediated and will not require monitoring.
-------
TABLE 12
GROUNDWATER ALTERNATIVE NO. 2
GROUNDWATER EXTRACTION/
CARBON ADSORPTION
COST ESTIMATE
CAHTAi AMD M«D COSTS
ESCALATED
ITEM fiUAKTITT UNITS IMIT COST
SITE m»A!AT10M
T. SITE CLEAtlHC 0.1 ACIE 3.371.10
2. SITE GRACING 1.100 SS. TO. 2.25
3. CRAVU SU8SASE 200 CD. TO. 11.24
4. CONCRETE EOUI»*E»a *A5 275 SO. TD. 17.98
S. ICiUlZATIOft (MEMS 1-4) 1 IUHP SUM 1DX
SUBTOTAL
StOUW WATER TREATMENT fAClLlTT
1. IMITIAL TES1IKC 1 LUMP $UH 4.494.80
2. CAtSO* AUSOSfTIO.
TtEATMEkl STS. (SO C^K) 1 LUX" SUM 12.360.7C
3. EVTtACTjOK WEUS 2 EACH 3.371.10
4. lECMACl yUiS 2 EACH . 1.6£5.55
SUBTOTAL
TOTAL CAPITAL AND flXEO COSTS
COMTINCEUC1ES (10X)
EHCINEEIIMC AMD ADMINISTRATION (151)
TOTAL
VERATIOli AND MINTEKANCE COSTS
ITEM
1 WATE> TIEATEMt.,1 STSTEX
2. Ok-SlTC C»OUKD MATE! n*»UC
3. ^ErtlNC UK SECUtlTT
A. CtOUH: WATER HON1TOVIK (•*l-A«KUAl IS «LlS)
ESCALATED
TOTAL
S3J7.11,
2.475.0C
2.24e.o:
4.944.5C
1.000.46
S11.005.07
S4.494.S:
12, 36:. 7:
6.74? ?:
3.37-, .1:
S26.965 E:
S37.97J.E7
3.797.J5
S.Wt.OS
147. 467. J.
ESCAi.AT(3
AMNUAv CCS1
IV f"? '"
2.605.PV
s.6'.e.5:
47.195.4?
MESEH1 WOtTM COST
«5 r"r».
S275.6?.- IE
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33
All contaminants will be reduced to below health-based levels, so
no five year review is required.
There will be no unacceptable short-tern risks or cross-media
impacts caused by the implementation of the selected remedy.
Some short-term risks will be created by the excavation and air
emissions from the incinerator, off-gases from the in-situ vacuum
extraction and ground water treatment system. However, regular
monitoring of the air, dust control measures, and proper
installation and operation practices will be implemented to
maintain the risks to acceptable levels.
10.2 Compliance with ARARs
The ARARs for this site are presented in Tables 13 and 14.
Following is a brief narrative summary of the major ARARs and
TBCs presented in the Tables. The selected remedy will be
designed to meet all applicable or relevant and appropriate
requirements of Federal and more stringent State environmental
laws.
The soil and ground water cleanup standards chosen for the site
are based on U.S. EPA's selection of a type A/B cleanup for this
site. Criteria for complying with Type A, B or C cleanups are
contained in Michigan's Act 307 Rules. /The substantive
provisions of Parts 6 and 7 of the Act $B7 rules are considered
ARARs for the remedial action to be undertaken at this site.
These rules provide, inter alia, that remedial actions shall be
protective of human health, safety, the environment and natural
resources (Rule 299.5705(1)). The Act 307 rules specify that
this standard is achieved by a degree of cleanup which conforms
to one or more of the Type A, B or C cleanup criteria. A Type A
cleanup generally achieves cleanup to background or non-
detectable levels (R299.5707); a Type B meets risk based cleanup
levels in all media (R299.5709-5713, 5723-5725), and a Type C
cleanup is based on a site specific risk assessment which
considers specified criteria (299.5715-19).
As indicated in the FS, reference doses, secondary MCLs, proposed
MCLGs 10-6 cancer risk numbers and background were used to
determine the cleanup levels for the Act 307 Type A/B cleanup.
MCLs, non-zero MCLGs and proposed secondary MCLs are considered
appropriate to the remedial action at the Springfield Township
site because the aquifers are or may be used for drinking water
purposes. As MCLs and MCLGs apply to water at its point of
distribution ("at the tap"), these levels are appropriate for
ground water at this site because residential wells that would
use this aquifer would have minimal treatment.
The U.S. EPA selected a Type A/B cleanup given the residential
and agricultural nature of the area around the site and its
-------
TABLE 13
FEDERAL ARARS
The major ARARs that will be addressed and net by the selected
reaedy and whether the ARARs are listed as follows:
Executive Order 11988 and 11990; 40 CFR 6, Subpart A which
requires that remedial actions must avoid adverse affects to
floodplain or wetlands and evaluate potential impacts to
these areas.
The Clean Air Act and 40 CFR 50 and 52 which require that
select types and quantities of air emissions be in
compliance with regional air pollution control programs;
approved State Implementation Plans and other appropriate
federal air criteria.
40 CFR 141 which requires that ground water used as
drinking water meet maximum contaminant levels (MCLs) for
pollutants of concern.
40 CFR 144 and 146 well plugging and abandonment and other
requirements for the injection of treated ground water under
the Underground Injection Control Program.
40 CFR 268 Land Disposal Restrictions for the handling,
treatment, and placement of hazardous wastes.
49 CFR 107 requirements for transporting hazardous materials
off-site.
40 CFR 761 TSCA regulations for the treatment, storage, and
handling of PCBs.
-------
TABLE 14
STATE ARARs
Act 60 of 1976 (PCB Compounds) which prohibits the disposal
of waste containing a concentration equal or greater than
100 ppm of PCBs.
Act 64 of 1979 (The Hazardous Waste Management Act) which
regulates the treatment, transport and disposal of hazardous
wastes from site restoration.
Act 98 of 1913 (The Waterworks and Sewerage Systems Act)
which are rules for construction and operation of sewerage
systems, as applicable for discharge of ground water via new
sewer connection and certification of the operator.
Act 127 of 1970 (The Michigan Environmental Protection Act)
which prohibits any action which pollutes, impairs, or
destroys the State's natural resources, due to any remedial
action at the site.
Act 203 of 1979 (The Goemare-Anderson Wetland Protection
Act) which regulates discharges to wetlands.
Act 307 of 1990 (The Michigan Environmental Response Act)
which provides for response activity to eliminate
environmental contamination as sites containing hazardous
substances and establishes cleanup standards.
Act 315 of 1969 (The Mineral Well Act) which establishes
requirements for monitoring wells at the site.
Act 347 of 1972 (The Soil Erosion and Sedimentation control
Act) which requires a soil erosion control measures at the
site consistent with locally approved soil sedimentation and
erosion control plans or rules.
Act 348 of 1965 (The Air Pollution Act) which requires air
emissions to have 'non-injurious effects."
Act 641 of 1978 (The Solid Waste Management Act) which
establishes provisions governing the regulation and
management of solid waste.
Public Health Code Act 368 which establishes the procedures
for well abandonment.
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34
future growth potential; the present and future potential use of
the property for recreational purposes; its amenability to a
totally clean closure; the small size of the site and the
isolated nature of the areas of high contamination; the increased
permanence, reliability, and long-term certainty of protection of
human health and the environment; the increased reduction in the
volume of hazardous substances remaining on site; and the State
and community's strong preference for a Type A/B cleanup
Since hazardous wastes will be treated and stored on-site, the
substantive requirements of the Resource Conservation and
Recovery Act (RCRA) and Michigan Act 64 are applicable
requirements which must be met. Additionally, excavation and
construction activities must comply with locally promulgated
rules pursuant to Michigan's Soil Erosion and Sedimentation
Control Act (MCL 282.106).
RCRA regulations concerning the design, construction, operation
and maintenance of incinerators are also applicable regulations
with which the remedy must comply. In addition, storage,
labelling, and packaging of PCB contaminated soil for
incineration must comply with the appropriate requirements found
in the Toxic Substance Control Act (TSCA) and Michigan PCB Rules
MAC 299.3313-3317. If there are any discharges of treated ground
water to the marshes or surface waters located off-site, they
will have to meet the permit and substantive requirements of all
applicable environmental regulations including, but not limited
to, the Michigan Water Quality Criteria or other specified levels
found in the Clean Water Act or the Michigan Wetlands Protection
Act. The emission control requirements of the Clean Air Act
(CAA) and Michigan Air Pollution Control Act are potential ARARs
for any on-site incinerator and fugitive dust emissions.
Parameters of concern are nitric oxides (NOx), VOCs, other gases
and particulates. Air pollution control may also be a part of
the ground water and soils remedial action.
RCRA regulations for the identification of characteristic
hazardous waste will be used to determine whether or not the
incinerator ash can be disposed off-site. If the incinerator ash
is determined to be a hazardous waste under RCRA, or if any other
hazardous wastes are transported off-site, the Department of
Transportation Rules for transportation of hazardous materials
and RCRA will be applicable to any off-site transportation or
handling of the hazardous wastes.
The ash and residue from the incineration of the contaminated
soils .must be tested to determine if they are non-hazardous,
solid waste regulated by Michigan Act 641 and its implementing
regulations. If they are regulated non-hazardous, solid wastes,
then the ash must be either: (1) stabilized prior to on-site
disposal; (2) disposed of off-site or (3) disposed of on-site in
an area which meets the location, liner, ground water monitoring
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35
and deed restriction requirements of Michigan Act 641 and its
implementing regulations.
The proposed remedy involves treatment of soils and debris wastes
and placement of residual ash. Placement of certain restricted
hazardous wastes or treated residuals is prohibited under the
RCRA Land Disposal Restrictions (LDRs) unless certain treatment
standards are met. Because the wastes are not RCRA listed or
unknown to be RCRA characteristic wastes prior to treatment,
they are not subject to any waste code-specific treatment
standards. Disposal of treatment residuals are subject to the
land disposal restrictions if it is determined that the
incinerator ash exhibits a hazardous characteristic.
10.3 Cost-Effectiveness
The selected remedy for the Springfield Township site is
considered the most cost effective when considering that the site
will be fully remediated requiring no institutional controls or
deed restrictions and that ground water contamination and its
source of degradation will be eliminated. The other soil
alternatives were less expensive; however, they do not remediate
all the contaminated soils and would not be fully protective of
human health and the environment. The Ground Water Alternative 2
is less expensive than the No Action Alternative, for it would
not require long-term monitoring and maintenance. The total cost
of the combined soil and ground water alternatives as the
selected remedy is $ 9,721,290.
10.4 Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable
The selected remedy represents the best balance of alternatives
evaluated to address the contamination problems at Springfield
Township site. By excavating, incinerating, solidifying, and in-
situ vacuum extraction treatment of the contaminated soils, and
by extracting, treating the contaminated ground water and
reinjecting clean ground water, the potential health threats to
area residents will be drastically reduced and/or eliminated.
The destruction and/or stabilization of the contaminants in the
soils eliminates the future degradation of the ground water. The
selected remedy offers permanent solutions by utilizing treatment
technologies where practicable with only minimal removal
activities such as the carbon adsorption unit in the ground water
treatment and in the in-situ vacuum extraction which will require
off-site disposal.
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36
10.5 Preference for Treatment as a Principal Element
The principal threats posed by the Springfield Township site are
the contaminants in soil and ground water in concentrations that
exceed acceptable human health risks. The selected remedy
directly addresses these threats by treatment using on-site
incineration, solidification, in-situ vacuum extraction and
ground water extraction and carbon adsorption which will destroy
or remove the contaminants in the soils and ground water.
11.0 Documentation of Significant Changes
The selected remedy has not changed significantly from the
preferred remedy that was presented within the Proposed Plan and
which was available for public review and comment from July 13,
1990 through September 12, 1990.
12.0 Summary
The presence of soil contamination and ground water contamination
at the Springfield Township site requires that remedial actions
be implemented to reduce the risk to public health and
environment. The U.S. EPA believes, based on the RI/FS and
Administrative Record, that the selectejJ remedy provides the best
balance of trade-offs among alternatives with respect to the
criteria used to evaluate the remedies. ' Based on the information
available at this time, the U.S. EPA believes that the selected
remedy will be protective of human health and the environment,
will attain ARARs and will utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
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MfttUUL MIOMICCI COMMIttlON
THOMAS j
MAMV.CNE J
t oi/ve»,
STATE OF MICHIGAN
5?
Attachment 1
JAMES J BLANCMARD. Governor
DEPARTMENT OF NATURAL RESOURCES
STCVEN5 T MASON BUILDING
P.O. BOX 300?t
LA.N5INO Ml 40409
DAVID t. MALES. Director
September 27, 1990
Mr. Valdas Adarakus, Regional Administrator
U.S. Environmental Protection Agency
Region V, 5RA-14
230 South Dearborn
Chicago, Illinois 60604
SUBJECT: Springfield Township Dump Superfund Site, Oakland County
Dear Mr. Adarokus:
The Michigan Department of Natural Resources (MDNR), on behalf of the
State of Michigan, has reviewed the proposed Record of Decision (ROD)
for the Springfield Township Dump site. The remedy in the proposed ROD
consists of the following:
s-
* excavation and thermal destruction of soils to remove
polychlorinated biphenyls to 1 ppm, as well as volatile
organic compounds (VOCs), semi-volatile organic
compounds (SVOCs), and pesticides from designated
areas;
* solidification of incinerator ash and residue to
comply with ARARs;
* solidification of soils contaminated only with
metals to comply with ARARs;
* in-situ vacuum extraction to remove VOCs and SVOCs
from the remaining unsaturated soils;
* groundwater extraction, treatment with carbon
adsorption and re inject ion of treated water upgradient
of the contaminant plume; and
* maintenance and possible expansion of the existing
fence to secure the site during remedial action.
We concur with this remedy for the Springfield Township Dump site.
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Yr. Valdas Adamkus -2- September 27, 1990
"he State does not concur with the omission of the Michigan Water
Resources Cowmission Act 245, PA 1929, MCI 323.6(4) and the associated
Part 22 Administrative Rules, MAC R. 323. 2201 fit seg. The State has
previously identified these requirements as ARARs for the remedial
action being selected for this site. The Mater Resources Commission Act
and the Part 22 Rules are ARARs for this remedial action as it includes
reinfection of treated water back into the groundwater, an activity
specifically regulated by those rules.
It is the Department's judgement that the selected remedial action for
this site can provide for attainment of all ARARs including the Michigan
Water Resources Commission Act and Part 22 Rules. The remedial action
Mill halt the migration of contaminated yroundwater and restore the
aquifer to a usable condition. The purged Mater will be treated prior
to reinfection. If it is reinjected upgradient and then hydraulically
contained on-site by the purge wells in a manner that will prevent
degradation of groundwater quality, it will be consistent with the Water
Resources Commission Act and Part 22 Rules.
I look forward to implementation of the final remedy for this site.
Sincerely,
OeVtert Rector
Deputy Director
517-373-7917
cc: Mr. Jonas Dikinis, U.S. EPA
Ms. Susan Louisnathan, U.S. EPA
Ms. Marilou Martin, U.S. EPA
Mr. Jeremy Firestone, AG
Dr. James Truchan, MDNR
Mr. Andrew Hogarth, MDNR
Mr. William Bradford, MDNR
Ms. Claudia Kerbawy, MDNR
Ms. Robin Campbell, MDNR
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ATTACHMENT 2
RESPONSIVENESS SUMMARY
SPRINGFIELD TOWNSHIP SITE
DAVISBURG, MICHIGAN
The Responsiveness Summary has been prepared to meet the
requirements of Sections 113(k)(2)(B)(iv) and 117(b) of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Super fund Amendments and
Reauthorization Act of 1986 (SARA), which requires the United
States Environmental Protection Agency (U.S. EPA) to respond
"...to each of the significant comments, criticisms, and new data
submitted in written or oral presentations'* on a Proposed Plan
for remedial action.
The U.S. EPA has gathered information on the types and extent of
contamination found, evaluated remedial measures and has
recommended remedial actions to address the contamination found
at the Springfield Township site, south of Davisburg in Oakland
County, Michigan. As part of the remedial action process, two
public meetings were held at the Springfield Township Hall in
Davisburg. The purpose of the meetings were to explain the
intent of the project, to describe the results of the Remedial
Investigation (RI) and the Feasibility Study (FS) , and to receive
comments from the public. The first meeting was held on July 11,
1989 and was attended by approximately 20 citizens. The second
meeting was the Proposed Plan Public Meeting which was held on
July 24, 1990 and was attended by approximately 30 citizens. A
court reporter was present to record the proceedings of the
second public meeting. A copy of the transcript is included in
the Administrative Record.
Public participation in Superfund projects is required by SARA.
Comments received from the public 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 the 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 in
Springfield Township Hall, 640 Broadway, Davisburg, Michigan.
Also, comments not directly related to the selection of the
remedial alternatives have not been addressed within the
Responsiveness Summary.
This document summarizes the oral comments received at the public
meeting held on July 24, 1990, and the written comments received
during the public comment period running from July 13, 1990
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through September 12, 1990. Please refer to Appendix A for a
list of the commenters.
Judging from the comments received during the public comment
period, the selected remedy specified in the Record of Decision
(ROD) is supported by the residents of Springfield Township. The
Michigan Department of Natural Resources (MDNR) also concurs with
the selected remedy. The Springfield Township Board also
supports the selected remedy which accomplishes their primary
objective, complete cleanup. The Springfield Township Board and
area residents urged that the project "move forward with as much
speed as possible."
Comments received during the public comment period on the FS and
Proposed Plan for the selected remedy along with U.S. EPA's
responses are summarized below. Comments and responses have been
divided into three sections and are further categorized by topic
within each section. The three sections are as follows:
A. Summary of comments received during the public meeting,
July 24, 1990;
B. Summary of comments submitted by the public during the
public comment period; and
C. Summary of comments prepared for the PRP Steering
Committee by their consultants.
The comments below have been paraphrased in order to effectively
summarize them in this document. Copies^ of the public meeting
transcript and written comments are available for review at the
public information repository.
A. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC MEETING,
JULY 24, 1990
Comment: One resident inquired as to the how long it would take
to implement the ground water treatment phase.
Response: The Groundwater Alternative, Ground Water Extraction
and Carbon Adsorption, technology has been widely used at
other hazardous waste sites, and equipment is readily
available. It is estimated that one month will be required
to complete construction of the system once the contractor
is selected. A two month pilot test may be required to
determine the final design parameters. The ground water
treatment is expected to take a year to a year and a half
before the ground water is remediated to cleanup levels.
The Ground Hater Alternative will be developed during the
remedial design phase of the project. Pending the
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finalization of design plans, the ground water treatment may
not be implemented until soil contamination, the source of
ground water degradation, is eliminated. The Soil
Alternative is estimated to take between one and two years
before completion of the remediation.
Cement: One resident inquired as to the location of the
Springfield Township site.
Response: The Springfield Township site is located at 12955
Woodland Trail, formerly Shindler Rd., in Springfield
Township, Oakland County, Michigan. The Springfield
Township site is on the National Priorities List which
targets it for investigation as a potential source of risks
to the public health and the environment.
Comment: One public meeting attendee asked if there would be
further clarification as to how the cleanup levels were
derived from the new (Michigan) Act 307 Rules since they
were not fully explained in the Feasibility Study and the
Proposed Plan.
Response: The Michigan Act 307 Rules contain cleanup criteria
which include three different methods by which cleanup
levels can be determined. The levels are Type A, Type B,
and Type C. The methodology for Type A cleanup is based on
background levels or method of detection limits for
chemicals of concern. The methodology for Type B cleanup
uses standardized risk assumptions and exposure assumptions
to determine cleanup levels which will be protective of
human health and the environment and the use of the involved
resource. R. 299.5709 and R. 299.5711 provide thorough
explanation on how to apply the Type B cleanup to the
chemicals of concern and calculate the figures to the site.
The methodology for Type C cleanup reviews the actual
conditions of the site; the uses, present and future, of the
site; a site specific risk assessment; and cost-
effectiveness analysis. R. 299.5717 provides a thorough
explanation of how to apply the Type C cleanup to the
chemicals of concern to the site.
Comment: One public meeting attendee asked if the calculations
for the cleanup levels would be provided.
Response: The formula for calculation of the cleanup levels can
be found in Michigan Act 307 R 299.5711. The actual
calculations are as follows:
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Dieldrin Type B Cleanup Criteria
Direct Contact Soil Criterion
6.25 X 10 -8 ma/kcr/d x 70 ka x 1000 - 80 ppb or
(0.09 g/d X 0.5) + (0.9 g/d x 0.01) .08 ppm
PCB Type B Cleanup Criteria
Direct Contact Soil Criterion
5 X 10 -7 acr/ka/d X 70 ka X 1000 - 650 ppb
(0.09 g/d X 0.5) + (0.9 g/d X 0.01) rounded to
1 ppm
Barium Type B Cleanup Criteria
Ground Water Protection, Soil Criterion
5 ppm (MCLG) x 20 B 100 ppm
Chlorobenzene Type B Cleanup Criteria
Ground Water Protection, Soil Criterion
Rfd - 2 X 10 -2 ng/kg/d
HLSC - 2X10-2 ncr/kcr/d X 0.2X70kaxlOOO - 140 ppb
2 1 rounded
to 100 ppb
20 X 100 ppb (HLSC) = 2000 ppb or 2 ppm
TCE Type B Cleanup Criteria ••/'
Ground Water Criterion
10 -6 GW Concentration «
9.1 X 10-5 ma/kct/d X 70 ka =3.2 ppb
2 1 rounded to
3 ppb
(10 -6 Dose «= 1 X 10 -6
1.1 X 10 -2 mg/kg/d
9.1 X 10 -5 mg/kg/d
Ground Water Protection, Soil Criterion
20 X 3 ppb (HLSC) - 60 ppb, .06 ppm
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Toluene Type B Cleanup Criteria
Ground Water Criterion
Proposed Secondary Maximum Contaminant Level
40 ppb, or .04 ppm
Ground Water Protection, Soil Criterion
20 X .04 ppm (SMCLs) - .8 ppm
Arsenic Type A Cleanup Criteria
Ground Water and Soil Criteria
Background
Lead Type A Cleanup Criteria
Ground Water and Soil Criteria
Background
Comment: One public meeting attendee asked how long it would
take to excavate and remediate the soil.
Response: The soil remediation alternative consists of
excavation, on-site incineration, solidification, and in-
situ vacuum extraction. It is estimated that the
construction, excavation, and test burns for incineration
will take from 6 months to one year. Incineration of the
contaminated soils will take approximately one year.
Solidification, of the ash and residue, if necessary, and of
the soils contaminated with metals will be interfaced with
the incineration process when possible. The average time
required to construct an in-situ vacuum extraction system is
one to two months, and treatment duration is estimated from
one to two years. Total duration of this alternative
treatment may take from two to three years.
Comment: One resident asked how the implementation of the
preferred remedy would impact Shindler Rd.'s (currently,
Woodland Trail) present and future condition.
Response: The preferred remedy entails on-site treatment of the
soil and ground water contamination. Increased traffic on
Shindler Rd. would consist of vehicles transporting the
necessary equipment and supplies to the site, commuting of
on-site workers, and removal of the remedy equipment and
refuse.
During the design phase of the remedial action, Shindler
Rd. 's condition would be evaluated in terms of needed
improvements and accessibility. Any such improvements or
modifications to Shindler Rd. would be coordinated with the
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necessary agencies and in observance of applicable
regulations or requirements. Impact to Shindler Rd. would
be kept to a minimum, where possible. Following completion
of the remedial action, Shindler Rd. would be restored to
its original condition in so far as it is practicable.
Comment: One public meeting attendee asked for the time frame of
the preferred remedy from the date of the signature of the
Record of Decision through the remediation of the ground
water.
Response: The Record of Decision was signed by the Regional
Administrator on September 29, 1990. The actual start date
of the remedial design would depend on the negotiations
with the potential responsible parties (PRPs) and its
outcome. A projected date for the start of the design
phase is January 1990. This phase may take one and half
years before the remedial action can be implemented which
would be the summer of 1992. The total duration of the
remedial action is estimated at two to three years which
would place the completion of the activity in 1994 or 1995.
This time frame is estimated and is dependent on many
variables which can not be accounted for at this time. A
more accurate schedule will be provided upon completion of
the design.
Comment: One public meeting attendee asked how the treatments
for the preferred remedy might be sequenced.
/>
Response: The preferred remedy will remediate the soil and the
ground water contamination of the site. The soil
remediation will be implemented initially to control and
remove the source of degradation to the ground water and
the risk from direct contact. It is anticipated that
excavation and incineration of contaminated soils will
occur, followed by solidification, unless it can interface
with the incineration process, and in-situ vacuum
extraction. Upon completion of the soil remediation, the
ground water treatment system will be constructed and
operated. During the design and/or operation of these
treatments, measures will be taken to expedite the
remediation of this activity.
Comment: One resident asked what was the noise factor from the
excavation and incineration of the on-site soils.
Response: Noise levels are measured by decibels (dB). Normal
conversation is measured at 55-60 dB. Noise levels for an
incinerator stack, the main source of noise, is 65 dB. For
excavation, the noise levels for construction would be
applicable, and they are 50 dB. Both figures are estimated
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readings at a distance of 1/4 mile from the source. Noise
levels when positioned next to the incinerator stack would
be 120 dB, which is almost equal to an airplane taking off.
Noise levels at the excavation site would be 90 dB, which is
equivalent to the noises of highway traffic.
Measures to minimize the noise generated at the site are
installation of a stack silencer which would lower the
readings to 30 dB, and installation of an air intake
silencer and additional insulation of air jets. Possible
modifications for excavation are the use of mufflers that
reduce noise levels by 45 dB, the modification of the
radiation fan motor operation, and possible elimination of
beeper noises emitted by vehicles and equipment.
Comment: One resident asked if the excavation of soils increased
the likelihood of contamination moving deeper into the soil
unit.
Response: The excavation of soils would temporarily expose lower
soil profiles possibly containing contaminants to
precipitation which could potentially carry these
contaminants deeper into the soil unit. The inorganic
contaminants and PCBs are insoluble in water and generally
adhere to soil particles, making it less likely they will
migrate deeper via precipitation. However, the impact of
excavation and the exposure of the lower soil profile will
be considered during the remedial design. Safety
precautions for these concerns and other factors at the site
will be incorporated into the impl&entation of the remedy.
Comment: One resident asked why TCCD or dioxin which had
previously been identified as a contaminant at the site was
not mentioned in the current site documents.
Response: Specific sampling was performed for dioxins and
dibenzofurans during the remedial investigation. The
samples were analyzed for a congener-specific analysis. The
results of the analysis indicated that the health risk posed
by dioxins at the site is below current action levels. A
complete explanation of the analysis is provided in the
Remedial Investigation Report, Section 5.2.2.1, pages 5-11
through 5-13.
Based on the risk assessment of the chemicals detected at
the site, other chemicals were identified with much higher
concentrations and toxicity which were used to determine the
appropriate cleanup action and cleanup levels needed at the
Springfield Township site. Excavation and incineration of
on-site soils were determined to be the most effective
technology for removing all contaminants, except metals, in
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the excavated soils. The metal contaminated soils will be
addressed by solidification.
Content: One public meeting attendee introduced himself as a
•ember of the PRP Steering Committee for Springfield
Township site. He is acting on behalf of the Steering
Committee and wanted to express the Committee's concern that
"appropriate cleanup take place at the site..." and that it
is protective and completed in a timely fashion. He also
mentioned that the Committee has met with both EPA and MDNR
to discuss the site and that they have retained consultants
to assist with the evaluation of the site and the preferred
remedy. He stated that they have a number of concerns about
the proposed remedies and will be submitting them in a
written document within the public comment period. He then
introduced their consultant.
Response: U.S. EPA agrees with the Committee's concern that
appropriate cleanup action be implemented at the site in the
most timely manner. U.S. EPA selected what it believes to
be the best remedy based upon its evaluation using the nine
criteria (overall protection of human health and the
environment; compliance with ARARs; long-term effectiveness
and permanence; reduction of toxicity, mobility or volume;
short-term effectiveness; implementability; cost; support
agency acceptance; and community acceptance).
U.S. EPA acknowledges that meetings with the PRP Steering
Committee to discuss the site have^een held.
' /•'
Comment: The consultant for the PRP Steering Committee agreed
with the conclusions of the Remedial Investigation Report;
namely that there are two areas of concern, soil and ground
water. He stated that they did not agree with the cleanup
levels established by the U.S. EPA and MDNR, but recognize
that the ground water needs to be addressed in a timely
fashion.
He commented that the soil remediation identified as a
preferred alternative is based upon the results of the risk
assessment in the Remedial Investigation Report. He
continued that the risk assessment included calculations
and assumptions for future potential exposure at the site
for which the alternative has been developed. He added that
he did not necessarily agree with the assumptions and
calculations.
He acknowledged that the soil and ground water alternatives
outlined in the Feasibility Study and the Proposed Plan are
evaluated based on the nine criteria, of which one is
compliance with ARARs. He pointed out that one of the most
important ARARs for this site is Michigan Act 307
8
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administrative rules which were promulgated on July llth,
one day before the release of the Feasibility Study and
Proposed Plan for public comment and review. He expressed
the opinion that neither the Feasibility Study nor the
Proposed Plan provided a thorough or comprehensive
explanation of Act 307 and their application to the site.
He stated that an explanation and discussion should have
been included in these documents.
He commented that the Proposed Plan identified two
alternatives, one to remediate the soil, and one to treat
the ground water at a estimated cost of $300,00. He
restated his and the Steering Committee's position that the
ground water program should be implemented in a timely
fashion. However, he said he did not feel that the proposed
remedy for soil was necessary to protect the public health
and environment. He added that there are other alternatives
he will be evaluating which are as protective as the
preferred remedy and may be more timely implemented, more
technically feasible and more cost-effective.
Response: D.S. EPA agrees with the necessity of selecting a
remedy protective of human health and the environment which
is easily implementable, readily available and cost-
effective. By evaluating the alternatives against the nine
criteria, U.S. EPA was able to select a remedial action for
the Springfield Township site which satisfies protection,
permanence, implementability, cost-effectiveness, etc.,
and meets all ARARs. In response £o this detailed comments,
U.S. EPA has responded to the generic concerns raised by
this commenter in other portions of this Responsiveness
Summary.
Comment: One resident identified himself as a homeowner on
Woodland Trail who wanted to make a comment more for the
benefit of his neighbors in Springfield Township. He
indicated that he had been concerned about the use of
incineration as a method for cleanup. However, after his
visit to a mobile destruction unit in Chicago, he was
confident that it is a good alternative for this site.
He explained that he and the Township Supervisor were given
a tour of a transportable incinerator operating a facility
in the Chicago area by the engineer who supervises
the project. He learned that the soils of Springfield
Township, sand and gravel, are more suitable for use in an
incinerator.
He expressed his initial concern with emissions from the
incinerator, but upon learning about the system design and
the computer safe guards, he is convinced that any emissions
-------
from the stacks will be within the limits of EPA and DNR air
quality standards.
He described the computer system which is used to monitor
the operations and status of the incinerator and which can
be accessed by the citizens of that area. He noted that he
would like to have a similar computer system available to
the residents of Springfield Township.
He agreed with the Feasibility Study and Proposed Plan, and
supports the preferred alternative. He feels that the soil
contamination should be addressed before treating the ground
water contamination. He stated that as an engineer, he has
reviewed the documents and shared his opinions with
colleagues over the years. He noted that there may be some
questions that require answers, but they would best be
addressed during the remedial design stage.
His last point concerned the possibility of providing
expeditious fire protection for the site and the nearby
residential area; perhaps in the form of a neighborhood fire
truck and training for local residents.
Response: U.S. EPA thanks the resident for presenting his
comments and insights concerning the preferred remedy
technology. U.S. EPA acknowledges the resident's concern
for safeguards and fire protection during the remedial
activity and ensures that the remedial action, to the extent
necessary, is coordinated with local, State, and Federal
emergency response personnel. /
U.S. EPA would like to add to the resident's comment that
the incinerator toured at a site in the Chicago area
represents the type of facility that would be used at the
Springfield Township site, but not necessarily the actual
incinerator. The implementation of the preferred remedy
would be subject to the specifications developed during the
remedial design and the awarding of the contract based on
bid submittals.
During the design, all the safeguards and precautionary
measures and contingency plans including fire protection
will be examined and incorporated into the final remedial
alternative design.
Comment: One resident identified himself as a person who has
extensive knowledge in engineering and who has served the
county by studying the solid waste issues. He felt that it
provided him with the background to understand the concerns
and issues involved with technology associated with waste
handling. His primary concerns were air quality and noise.
He went to Chicago with a fellow township resident to tour
10
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the incinerator and learned from the on-site engineer that
there are technical measures which can be added to the
system to attain reasonable noise levels and to ensure the
air quality of the stack emissions.
He added that he supported the recommended alternatives and
reminded those present at the meeting that the llth
anniversary of the site discovery date will be observed in
two weeks. He stated that there is an obligation on the
part of politicians and government personnel to clean up
the site so that there are no remaining risks.
Response: U.S. EPA thanks the resident for his comments and
concerns regarding the preferred remedy. It is the U.S.
EPA's intent to proceed with this project in a timely
fashion until the cleanup levels are achieved and the
remedial action is completed.
Comment: Three area residents voiced their support for the
preferred remedy and urged that it be implemented in a most
expeditious manner.
Response: U.S. EPA thanks the residents for their comments on
the preferred remedy and recognizes the need to expedite the
project so that the cleanup action is performed quickly and
thoroughly.
B. SUMMARY OF COMMENTS SUBMITTED BY TH£ PUBLIC
Comment: Two letters were received from area residents stating
that they believe the only acceptable alternative is the
preferred alternative recommended by the U.S. EPA.
Response: The U.S. EPA thanks the commenters for their support
of the preferred alternative and appreciates their time and
interest on this project.
Comment: The Oakland County Health Division indicated that upon
review of the laboratory analysis of the soil, sediment and
ground water sampling; the 1987 report on the site; and the
remedial alternatives, the preferred alternative would be
the most effective means of eliminating the risk to public
health and the environment. Also mentioned, was that soil
remediation should be completed before the ground water
remedy and that some measure of fire protection should be
developed for possible fire threat from the operation of the
incinerator.
Response: The U.S. EPA thanks the commenter for their support of
the preferred alternative and notes the suggestions for
sequencing of remedial actions and fire protection measures.
11
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Content: The Springfield Township Board stated that they
supported the preferred alternative because it
"accomplishes the community's primary objective - complete
clean-up and an end to the project." They also urged that
the project "move forward with as much speed as possible."
Response: The U.S. EPA thanks the commenter for their support of
the preferred alternative. The U.S. EPA acknowledges that
the project has been in implementation for 11 years and will
expedite the process to the best of its abilities.
C. SUMMARY OF COMMENTS PREPARED FOR THE PRP STEERING COMMITTEE
BY THEIR CONSULTANTS
The following comments were submitted on behalf of the PRP
Steering Committee by Geraghty & Miller, Inc. and Gradient
Corporation: Comments Relative to the Remedial Investigation,
Feasibility Study, and Proposed Plan for the Springfield Township
Superfund Site and Technical Review Document and Proposal of
Remedial Alternative for the Springfield Township Site. The
comments are grouped into the following categories:
Summary Comments
Remedial Investigation
Risk Assessment
Feasibility Comments
Cleanup Levels
Proposed Remedial Action Plan
Evaluation of ARARs /*•
Compliance with NCP
The responses are divided into the same categories except for
Summary Comments and Proposed Remedial Action Plan. Since the
Summary Comments are addressed in detail in the respective
category heading, they are not answered to avoid redundancy.
Comments referring to the Proposed Remedial Action Plan are
addressed in the last section by the same name.
Remedial Investigation
Comment 1: Commenter states that the RI/FS and all conclusions
are derived from biased database and are scientifically
unreliable. Field screening of 476 collected soil samples
resulted in only 41% of the samples determined to not be
"clean" were forwarded for further analysis. Generating
data only from predetermined contaminated samples results in
overestimates of the degree and extensiveness of contaminant
concentration at the site. Average concentrations used in
the Risk Assessment were determined from the 41% analyzed
samples and do not reflect the number of "non detects."
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Response: According to the Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA (OSWER
9355.3-01, October 1988), "field screening techniques (e.g.,
soil gas analysis...) can be useful for directing soil
sampling into areas of greatest contamination or 'hot
spots.' ...Results of field screening can then be used to
determine which samples should be further analyzed using
more rigorous methods." The use of field screening at the
site optimized the sample analysis while employing cost
effective measures. The selection of specific samples for
further analysis from 476 samples collected provided data
indicating actual concentration levels at the site. The
samples targeted for further analysis were sent to Contract
Laboratory Program (CLP) labs which provide
quantitative data that is used for determining risk
assessment values.
The commenter states that those samples not used for further
analysis were considered free of organic chemicals. The
Review Report, Section 3.1.1.1, implies that field screening
was utilized to select 'those samples deemed contaminated'
for further analysis by the Agency. The RI Report, Sections
3.2.5.2 and 3.2.5.3, explains how field screening was used
to select samples and references Appendix B 5, 6, and 7. A
review of the Appendices indicates that the samples were
screened and ranked based on the instrument readings. Of
the 300 samples collected for surface soil sampling, 165
samples were ranked with 1 (1 on a scale of 3 indicated the
sample with the most pronounced reading) , and of these 165
samples, less than half (72) were forwarded to the CLP lab
for further analysis. Included in the samples designated
for further analysis were samples ranked 2 and 3. The
statement by the commenter that those samples not analyzed
further were free of organic chemicals is not substantiated
by the field screening summaries in the RI Appendices.
Surface soil sampling locations were based on a 100 ft. by
100 ft. grid blocks and topography, accessibility, and
observations of surficial contamination. Discrete samples
from three depths were collected and screened. The soil
boring samplings were located in areas where subsurface
contamination was indicated or suspected on the basis of
former site activities and the results from ongoing RI
exploration. The samples were selected from the area of
concern which is approximately 4 acres in size and within
the 4 acres the samples are well distributed through out as
evidence in Figure 8 of the ROD. Included in those samples
designated for further analysis are samples which range from
1 to 3 in the field screening ranking. The sample results
indicate that contamination is found throughout the site and
that the samples are representative of the conditions on
site.
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The corrected risk estimates presented by the commenter in
the Review Report, Section 4.0, were calculated according to
U.S. EPA's "Risk Assessment Guidance for Superfund" (OSWER
EPA 540/1-89/002, December 1989) which was not issued until
six months after the finalization of the RI Report. The RI
risk assessment was prepared according to "Superfund Public
Health Evaluation Manual" (SPHEM, 1986). As stated in the
Preface for the Risk Assessment Guidance for Superfund,
"issuance of the new manual does not invalidate human health
risk assessments completed before (or in progress at) the
publication date." Therefore, the comments are noted but
are not valid arguments.
The U.S. EPA does not recognize percentages of samples
collected containing a contaminant as a reasonable
determination for the remediation of that contaminant at the
site. Remediation is based upon the baseline risk
assessments using values that are based on analytical data
and not on the factoring of percentages of occurrences.
In summary, the comment that the risk assessment values do
not reflect the 59% "non detects" and are therefore
overestimates is incorrect because (1) the "non detects"
noted by the commenter are not "non detects," (2) the risk
assessment values are based on data results which show
overall soil contamination as representative of the site
conditions, and (3) the risk estimates which were prepared
according to the SPHEM guidance are valid.
Comment 2: The RI/FS fails to represent' the limited nature of
contamination at the site which in turn does not support the
depth and volume of soil proposed for excavation and
treatment in the final remedy by U.S. EPA. The commenter's
calculations for the excavated soil volume using U.S. EPA's
depth and area is 17,800 cy.
Response: The RI report provides a detailed description of the
sampling conducted during the field investigation and
provides the results in a descriptive narrative and in
Appendices B and D. It is true that the majority of the
samples containing PCBs are found at a depth of less than 2
feet and this is reflected in Figure 3 of the ROD in which
the area (3,687 sg yds) slated for excavation to 3 feet is
much greater than the other areas requiring deeper
excavation. The depths of excavation for the other two
areas are based on the detected concentration levels of PCBs
and the cleanup levels chosen by U.S. EPA and in compliance
with ARARs (applicable, or relevant and appropriate
requirements).
One of the ARARs for this site is Michigan Act 307 Rules
from which a Type A/B cleanup level was selected by U.S.
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EPA. The Type A/B cleanup level for PCBs is 1 ppm. The
comnenter explains in the Review Report, Section 5.1.1.1,
that PCBs at levels less than 100 ppm may be left on site if
contained according to the U.S. EPA Guidance on Remedial
Actions for Superfund Sites with PCB Contamination (OSWER
No. 9355.4-01, August 1990). This same guidance states
"(t)he concentration that defines the area over which some
action must be taken is the concentration of PCBs that can
protectively be left on site without management controls...
A concentration of 1 ppm PCBs should therefore generally be
the starting point for analysis at PCB contaminated
Superfund sites where land use is residential." Since the
guidance recognizes the validity of 1 ppm PCB concentration
as a starting point, it does not contradict the Type A/B
cleanup level for this site which is 1 ppm PCB cleanup
level. The guidance also recognizes full treatment of soils
to levels of 1 ppm PCBs for which no long-term management
controls (including access restrictions) are necessary.
The excavation depths and volume are based on the cleanup
levels for the site and the depths at which the contaminants
are located. The volume of soil to be excavated is an
estimated volume and will be refined during the remedial
design. U.S. EPA acknowledges that the volume noted in the
FS may change based on data collected during the design
phase, but an approximated volume was necessary for the
preparation of estimated remedy costs.
Comment 3: The RI report identifies numerous deficiencies in the
quality of data generated which ar^ not acknowledged in the
FS in terms of scoping the alternatives and cost estimates.
The commenter questions the U.S. EPA's entire evaluation of
the site and the selected remedy which are based on these
deficiencies (Review Report 3.1.1).
Response: Review Report, Section 3.1.1 was reviewed and it was
unclear what exactly the "numerous deficiencies in the
quality of data" are without specific citations. However,
an attempt will be made to deduce the referenced
deficiencies. These deficiencies seem to be a matter of
interpretation of the data and/or selective nature of the
sampling. The selective nature of the sampling was
addressed in the response to Comment 1. Interpretation of
data is a more difficult issue which is subject to
differences of opinion from both parties.
The first interpretation of data by the commenter is that
PCBs are not a concern at the site because of the detection
frequency when averaged for the total number of samples.
However, U.S. EPA's review of the samples themselves show
that levels of 1,938 ppm of PCBs were detected at the
surface and 44 ppm of PCBs were detected at a depth of 25
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feet. Given the carcinogenic nature of PCBs, the
residential nature of the area, and the preferred cleanup
level, the U.S. EPA believes that it is correct to select a
remedy that will remediate soils with PCBs to 1 ppm level
which is protective of human health and the environment and
will not require management controls.
The RI presents the PCB data analysis and provides an
assessment of its threat in the Risk Assessment section, but
it does not state that the site is a "PCB Site11 as stated by
the commenter.
The commenter questions the interpretation of RI data for
dieldrin which had a detection frequency of less than 1% if
all 476 samples collected were included. As noted in an
above statement, U.S. EPA does not recognize the validity of
using a detection frequency to determine the need for
remediation. Dieldrin was selected as a chemical of concern
according to the methodology stated in the SPHEM; namely,
the chemical represents the most toxic, mobile, and
persistent chemical within its given class. Some of the
dieldrin samples had lab qualifiers indicating the data
values could not be validated, but not indicating the source
of the difficulty. However, dieldrin, 4,4'-DDE, 4,4'-DDT,
and 4,4'-DDD were detected without qualifiers in the hand
auger samples from surface soil. Since dieldrin was
selected as a chemical of concern, its use for cleanup
level will ensure that the other pesticides detected in the
soil will be remediated. /
• /'•'
The commenter cites the interpretation of data of selective
sampling and its use for developing the Risk Assessment as a
problem. The U.S. EPA addressed the validity of the
sampling data and its use for developing the Risk Assessment
in its response to Comment 1. The commenter continues to
use detection frequency as a method for determining risk
estimates which is not acceptable to U.S. EPA. The U.S. EPA
disagrees with the commenter's opinion that it is an
unreasonable assumption to use the likelihood of continuous
exposure to the maximum contaminated soil in the Risk
Assessment. The response to Comment 4 in the Risk
Assessment section addresses this concern.
The commenter questions the background levels of inorganics
for the site citing published background soil concentrations
for the State of Michigan. The U.S. EPA acknowledges that
the background levels for arsenic, lead, and barium may be
those noted in Appendix A of the Review Report. However,
UiS. EPA prefers to determine the background levels based on
more local and site specific information. Therefore,
background samples will be collected during the remedial
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design to establish the background cleanup levels for the
above mentioned inorganics.
The RI and Feasibility Study indicate that the hydrogeology
of the site is complex and provides an explanation of the
hydrogeology and groundvater flow. Michigan Department of
Natural Resources provided interpretation of its ground
water sampling and data collection from which they provided
reasonably reliable information on the ground water
elevations and flow. The commenter indicates that the U.S.
EPA conclusions are not scientifically sound, because the
coamenter is assuming that the data collected was
inadequate. However, the data is current and quality
controlled.
The commenter states that the following are invalid:
A constant chemical source because drums and soils were
removed and the site's use as a disposal area was for a
short period. However, soil samples indicate the presence
of contaminants which have been detected in the ground water
samples and may continue to serve as a source of degradation
to the ground water.
No Dilution by Recharge statement in the Review Report is
unclear in its intent, therefore a response is not provided.
No Chemical Retardation because the movement of all
constituents detected at the site zTre known to be retarded
by the sorbent nature of the subsurface materials. U.S. EPA
acknowledges that PCBs and metals are not generally soluble
in water and may absorb to the soil particles, but it does
not agree with the assumption that the volatile organic
compounds (VOCs) and semi-VOCs are sorbing to the subsurface
materials, especially since they have been detected in the
ground water.
Receptor Location has not been identified, nor has a plume
been defined. Data analysis in the RI indicates that the
ground water beneath the site is contaminated. The plume
was identified in the FS in Figure 1-11 and indicates that
it is moving off-site to the north-northwest. The ground
water plume will be reanalyzed during the remedial design so
as to tailor the ground water treatment system to the actual
problem.
Comment 4: The RI and baseline risk assessment do not adequately
address the implications of naturally occurring elevated
levels of iron, arsenic, and lead; therefore, what values
were used?
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Response: The RI states on page 5-7 that "(i)n general, the
levels of most metals found in the surface soils are within
the range of naturally occurring concentrations of metals in
the environment (see Table 14)." On that same page, the RI
adds that levels of arsenic, lead, barium, and lead are
elevated at the site; barium is detected in one sample at
4,540 ppm, and lead was detected at 1,378 ppm. In Table 14,
the highest level of iron is 7,930 ppm in HA-97 and arsenic
is 4 ppm in HA-97 (arsenic was detected at 39 ppm in sample
HA-80 noted in Appendix D-9 of the RI). On page 5-18 of the
RI, a chart of the metals detected in the ground water is
given and their respective background concentrations.
Background levels for cleanup are applied only to lead and
arsenic in both soils and ground water and possibly to
dieldrin in soils. Since background levels will be used as
a cleanup standard for arsenic and lead, U.S. EPA recognizes
that it will be necessary to collect background samples
during the remedial design to establish site specific
background levels.
Risk Assessment
Comment 1: The RI incorrectly presents noncarcinogenic health
risks by not accounting for exposure frequency. This error
resulted in an overestimate of risk by factors of 100
(probable case) and 1,000 (worst case).
Response: The Risk Assessment (RA) was^prepared by the MDNR's
contractor, E.G. Jordan, utilizing /the Superfund Public
Health Evaluation Manual, (SPHEM) Office of Solid Waste and
Emergency Response, Directive 9285.4-1, 1986. On page 96,
it states "... any single chemical with an exposure level
greater than the reference level will cause the hazard index
to exceed unity, and when the index exceeds unity, there may
be a concern for a potential health risk." The omission of
exposure frequency and duration was used as an initial
screening to identify potential noncarcinogenic risk. Since
U.S. EPA does not use a probability approach to estimating
the potential for noncarcinogenic risk, the calculated
indices do not imply high, medium or low risk.
Comment 2: The U.S. EPA's use of an RfD for estimating health
risks from lead is in violation of its own policy. Use of a
scientifically valid risk assessment approach results in
lead posing no unacceptable health concerns under
•reasonable maximum exposure" scenarios which is the current
U.S. EPA method for conducting risk assessments. This is
significantly different from its own conclusion in the RI
that lead poses the most significant noncarcinogenic risk at
the Site.
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Response: As stated in the above response to comment 11, the RA
was conducted according to the SPHEM manual, which listed an
RfD for lead of 1.4 x 10-3 mg/kg/day. since that time, the
Agency has determined that the RfD for lead is not
protective because of background exposures to lead, and the
uncertainty of a safe exposure level for lead existing,
especially in light of the recent classification of lead as
a 62 carcinogen. The STSSC has identified a bio-kinetic
uptake madel to calculate a safe exposure level to lead
which has not been approved for use yet by U.S. EPA.
Consequently, U.S. EPA believes a determination of whether
the risk from lead was overstated or understated is not
known.
The STSSC has identified 500-1000 ppm lead as levels of
concern using USEPA policy and guidance (Review Document
p. ES-5). These levels are exceeded in the disposal area
as evidenced by the maximum concentration found there. The
STSSC is not familiar with the uses of a risk assessment at
Superfund sites. A risk assessment is always used to
determine if action is needed to protect public health and
the environment, but need not be used to set cleanup
levels. Cleanup levels may be based on risk management,
policy or compliance with ARARs. Clearly, at the
Springfield site there is a lead concern, and the cleanup
level is consistent with the Type A/B cleanup from Michigan
Act 307 Rules ARARs and RCRA clean closure policy.
Comment 3: According to the RI, human contact with site soil
poses a significant risk under basiftine, current conditions.
This is inaccurate and causes an unnecessary image of
imminent endangerment. The scenarios posed by the RI
includes very frequent visits onto the site despite the
existence of a fence. Despite acknowledgement of restricted
site access in at least two places in the RI, this fact was
ignored in developing on-site human exposure scenarios.
Response: U.S. EPA believes it characterized the site as a
potential imminent endangerment as a result of the risk
assessment. The exposure pathways developed in the RI are
very clear with respect to the scenarios developed and are
explained within the RI document. On page 5-75, it is
written explicitly, " ... derived risk estimates are all
based on hypothetical exposure scenarios ... However, it
should be emphasized that a risk does not exist unless there
are two basic conditions: 1) the presence of a chemical at
sufficient concentrations; and 2) an exposed population that
is coming into contact with that chemical." On pages 5-74
through 5-76 of the RI, uncertainties with the risk
assessment process that overstate or understate the risk are
enumerated.
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The U.S. EPA cannot use site access restrictions in the RA
process for Superfund sites. This has been the policy and
is stated in the 1986 SPHEM manual (page 41), the newer Risk
Assessment Guidance for Superfund (OSWER Directive
9285.701A), 1989, (page 1-11) and the final National
Contingency Plan (NCP) March 8, 1990. The rationale is
explained in the NCP on page 8711:
"The role of the baseline risk assessment is to address
the risk associated with a site in the absence of any
remedial action or control, including institutional
controls. The baseline assessment is essentially an
evaluation of the no-action alternative.
Institutional controls, while not actively cleaning up
the contamination at the site can control exposure and,
therefore, are considered to be limited action
alternatives. The effectiveness of the
institutional controls in controlling risk may
appropriately be considered in evaluating the
effectiveness of a particular remedial alternative, but
not as part of the baseline risk assessment."
Comment 4: The U.S. EPA's "reasonable" worst case human exposure
scenarios are indeed not reasonable at all, as demonstrated
by several examples which follow. For example, the 5,000
ng/day soil ingestion rate used is 25 times the 200 mg/day
value recommended in the USEPA's own guidance (USEPA, 1989)
and is representative only of a pica behavioral abnormality
which exists in less than 0.5% of the population (USEPA
Exposure Factors Handbook, 1989) . ^SMso, the absorption
factors used for inorganics were up to 10 times higher than
the literature suggests. In addition, the marsh sediment
dermal contact rate used, 2.77 mg/cm2, is five times higher
than the value most frequently used in Risk Assessment
(Hawley, 1985). Also, the use of maximum concentrations
found anywhere on the site for "worst case" exposures is
unrealistic. It assumes that each time a person contacts
the site (up to 500 total Site visits according to the
report) contact with precisely the same maximum occurs.
This is statistically not possible; a more valid approach
should use a statistically-based upper bound of the entire
data set. Finally, the USEPA guidance (USEPA), 1989)
discourages the use of two exposure scenarios, probable and
worst case, but recommends that a single "reasonable maximum
exposure" scenario be used which is representative of actual
conditions. When corrected to comply with the U.S. EPA
guidance while retaining the same exposure scenarios
described in the RI results, the risk estimates for soil
exposure are lower by a factor of 150. Using the same
corrections while also modifying the exposure scenarios to
be more realistic results in risk estimates 1,350 times
lower than those in the RI (Review Report Section 4.1.4).
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The Risk Assessment for this Site ignored the Agency's own
guidance on performing Risk Assessments and also violated
sound scientific and statistical principals to arrive at
inflated estimates of risk.
Response: The U.S. EPA recognizes that changes in Risk
Assessment guidance have occurred subsequent to preparation
of the RA for the Springfield Township site. As indicated
in the response to comment # 1, in this section, the RA was
completed using the SPHEM, 1986 guidance. The new guidance,
Risk Assessment Guidance for Superfund, was issued in
September 1989 and on page ii specifically states:
"Following the date of its publication, this manual is
intended to be used as guidance for all human health
risk assessments conducted as part of the Superfund
remedial investigations and feasibility studies.
Issuance of this manual does not invalidate human
health risk assessments completed before (or in
progress at) the publication date and based on
previously released Agency guidance."
The STSSC has challenged the use of average and worst case
exposure scenarios and soil ingestion rates developed for
the Springfield RA. The use of such scenarios is
recommended in the SPHEM on page 50, " A second, and
generally preferred, approach is to calculate both best
estimates and conservative upper bound estimates for all
exposure point chemical concentrations.11 A range of
possible soil ingestion rates is recommended on page 86,
"... soil ingestion rates can vary from 0.1-5 grams per
day, with higher values representative of pica behavior."
U.S. EPA believes that although the soil ingestion rates
have changed and the concept of reasonable maximum exposure
scenarios been implemented with the new guidance, this does
not have a significant effect on the Risk Assessment for two
reasons: the use of residential exposures is also in the new
guidance to replace exposure scenarios such as trespasser
scenarios used in the Springfield RA, and the use of
indicator chemical selection has been eliminated. In the
current Springfield RA, a maximum of 500 site visits took
place in the lifetime of an adult under the worst case
scenario, the new guidance would call for 365 days per year
exposure for at least 30 years, or 10,950 exposure events.
In the current Springfield RA, only 14 chemicals were
selected and evaluated, the new guidance would ask for an
•valuation of all 54 chemicals detected in the RI
(Table 19).
U.S. EPA recognizes that in the past, best professional
judgement was used to arrive at soil ingestion rates and
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exposure frequencies and durations. The move toward a
standard residential exposure scenario was meant to
eliminate the variation that occurred as a result of best
professional judgement. U.S. EPA believes that within the
context of the SPHEM the soil ingestion rates and exposure
frequencies and durations are justified.
U.S. EPA notes that as part of their Technical Review
Document, the STSSC has submitted a revised RA for the
Springfield Township site, addressing their concerns about
soil ingestion rates and frequencies of site visits. In
Table 2 of the document, the worst case risk levels are
still outside of the target risk range for U.S. EPA for PCBs
and dieldrin, just as they were in the RA prepared by E.G.
Jordan. The Hazard index for lead still exceeds one, even
with the new model suggested by the STSSC, just as in the
E.G. Jordan document. The revised RA calculations provided
by STSSC can still be used as a basis for action at the
Springfield Township site.
The STSSC also conducted their own RA for the Springfield
Township site purportedly using the new 1989 U.S. EPA
guidance (see page of the Technical Review Document).
U.S. EPA rejects this RA because it altered the basic
equation on page 6-21 for calculating chemical intakes by
inserting a multiplying factor based on the number of
detects of the chemical in samples. The effect of adding
this factor was to reduce the dose for each chemical of
concern and subvert the concept of reasonable maximum
exposure identified in the guidanc^ manual. U.S. EPA
rejects the RA because it also does not consider a
residential exposure scenario recommended by the 1989
guidance on page 6-7:
"Because residential land use is most often associated
with the greatest exposures, it is generally the most
conservative choice to make when deciding what type of
alternate land use may occur in the future. However,
an assumption of future residential land use may not be
justifiable if the probability that the site will
support residential use in the future is exceedingly
•mall."
As stated in the Feasibility Study and Proposed Plan, the
land is zoned residential, so the residential exposure must
be completed.
Nonetheless, despite the problems identified in the STSSC
Reasonable Maximum Exposure RA, U.S. EPA evaluated the
concentration values presented in Table 2 - Summary of
Reasonable Maximum Baseline Risk Calculations of the
Technical Review Document. Using a residential exposure
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with 10 years for children and 30 years for adults, and the
correct chemical intake equation (minus the illegal
multiplying factor but with other variables used by the
STSSC), the following table was constructed.
Pathway Soil Ingestion
95% Upper Dose Risk
Cone. Bound Child Adult Child Adult
PCBs 0.09 321 2.62x10-4 2.0x10-4 2.0x10-3 1.5x10-3
Pathway Dermal Contact
PCBs 0.09 321 3.3x10-4 7.9x10-4 2.5x10-3 6.0x10-3
As previously stated, these risk numbers are similar to
those in the Springfield RA and support our conclusion that
despite the changes in the guidance there has been no
significant effect on the conclusions of the RA.
Furthermore, because the risk numbers for PCBs are already
outside the risk range, a recalculation of risk for other
chemicals would only increase the risk in these two
pathways. U.S. EPA does not feel that exercise is warranted
to prove its point in this matter.
Likewise, U.S. EPA did not reevaluate the groundwater
pathway submitted by the STSSC because the risk was still
significant, and as before accountable by lead and arsenic.
Finally, U.S. EPA does not believe it is necessary to
respond to the marsh sediment contact rate comment as no
risk was identified for marsh sediments, and no remedial
action is being planned for them.
Feasibility Study
Comment 1: The FS appears to be based on policies and procedures
that are outdated by the current NCP and U.S. EPA guidance;
which version of the U.S. EPA RI/FS guidance is the site FS
based on?
Response: The FS preparation was initiated prior to the
issuance of the revised NCP and U.S. EPA guidance,
therefore, some sections may reflect procedures and
methodology that were utilized earlier. Neither the revised
NCP nor CERCLA required FS's to be revised. As stated
previously, certain guidances explicitly sanction continued
use of prior guidances. As the FS was reworked, however,
U.S. EPA did revise sections based on the revised current
NCP. The U.S. EPA acknowledges that not all the changes may
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have been incorporated and that for the reasons articulated
in this Responsivness Summary to specific examples given by
this commenter, does not believe that further refinement is
necessary.
Comment 2: Throughout the FS, sections of the NCP are cited
which were eliminated in the revised NCP; which version of
the NCP was utilized during the FS evaluation.
Response: Preparation of the FS and evaluation of possible
remedial alternatives began before the finalization of the
current NCP. It would have to be said that the evaluation
and preparation of the FS was conducted under both; however,
revisions and changes were to have been incorporated into
the final FS so that the FS would reflect the March 14, 1990
NCP. To the extent the commenter has provided explicit
examples where the FS has significant errors that U.S. EPA
agrees with, U.S. EPA will correct the error in the
Responsiveness Summary.
Comment 3: The FS does not incorporate the elevated background
levels of naturally occurring compounds like iron, etc.
during the screening and evaluation of the remedial
technologies. Specifically, did the U.S. EPA evaluate the
effects of elevated levels of iron on the ground water
treatment.
Response: The U.S. EPA stated in previous comments that
background levels for naturally occurring compounds in the
soil will be established during th^ remedial design phase,
so U.S. EPA does not necessarily agree with the commenter's
reference to elevated background levels. U.S. EPA
considered the naturally occurring compounds when evaluating
the technologies, for two of these compounds, arsenic and
lead, are chemicals of concern which are assigned cleanup
standards. In the RI, average on-site concentration levels
and average background levels for iron in ground water are
noted as 3,730 ppb and 122 ppb, respectively. U.S. EPA did
not consider the effects of iron content on the ground
water treatment system. During the remedial design, it will
be determined if a pre-treatment for iron is necessary to
the ground water treatment process.
Comment 4: The screening process from the RI/FS guidance
document dated October 1988 does not appear to have been
used for the technologies in the FS. Why was the current
guidance not followed?
Response: The Notice to the RI/FS guidance dated October 1988
states that "(t)he policies and procedures established in
this document are intended solely for the guidance of
government personnel... The Agency reserves the right to
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act at variance with these policies and procedures and to
change them at any tine without public notice." As stated
earlier, the preparation of the FS was initiated before the
issuance of the RI/FS guidance of October 1988. The earlier
screening process is reflected in the FS format and the
evaluation criteria used. It was deemed unnecessary to
mirror the new guidance in the FS since the criteria for the
evaluation process was valid and provided the same results.
Consent 5: The STSSC requests an explanation of why three of the
conventional and 14 of the treatment technologies were
removed from further consideration in the FS evaluation
without a discussion.
Response: The following provides an explanation to the removal
of the aforementioned technologies:
Conventional Technologies:
Subsurface Containment Wall was removed because the depth
to the confining layer at the site renders excavation
impracticable.
Site Fencing was removed since site fencing already existed
at the site.
Municipal Water was removed because of the non-existence of
a public water supply to the area and the inappropriateness
of proposing a technology that has social and economic
implications to the area. •£'
Treatment Technologies:
Biological Methods was removed because it is not effective
in remediating PCBs, pesticides, and inorganics and may not
be effective in remediating the VOCs located in the deep
soils.
Composting and Landspreading were removed because due to the
presence of PCBs, pesticides, and metals in the soils.
Acid Leaching, In-situ Thermal Destruction, Catalysis,
Crystallization, In-Situ Adsorption, Microwave Plasma,
Particle Radiation, and Polymerization were removed because
these technologies are consider conceptual or only proven on
a bench scale and nay not be implement able.
Hydrolysis and Oxidation/Hydrogen Peroxide were removed
because they were not considered appropriate for use at an
unconfined site with a mixed chemical waste stream since
they require strictly controlled environments.
25
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Distillation was removed because it was considered
inappropriate for treating a low concentration waste stream
such as the one at Springfield Township site.
Comment 6: The FS is deficient since it does not explain how Act
307 Rules were applied to this site and no calculations
supporting those levels were presented in the FS
consequently the public was not provided with an
opportunity to comment on the application of Act 307.
Response: The FS and the Administrative Record File contained
information on how the Michigan Act 307 Rules were applied.
Tables 2-la and 2-lb of the FS and the June 29, 1990 letter
from MDNR, which is in the Administrative Record, explain
the regulatory basis in Michigan Act 307 for each of the
clean-up levels presented in the FS. The Michigan Act 307
rules in turn specify the manner in which cleanup levels are
to be calculated. (For example, to satisfy the Type B clean-
up criteria for soils, where the migration pathway is
inhalation, the hazardous substance concentration shall not
result in air emissions that cause an increased cancer risk
Of 1 X 10-6 (R.299.5711(b) (4)) . MDNR'S June 29, 1990,
letter also presents MDNR's justification for preferring a
Type A/B clean-up of the site. This letter was available in
the Administrative Record File at the time the FS and
Proposed Plan were public noticed. Finally, although not
necessary or required, U.S. EPA provided this commenter, and
has included in the Administrative Record File, the staff
work sheets that were used to apply the Act 307 Type A/B
cleanup levels to the data contained in the RI for this
site.
Comment 6a: There are inconsistencies in the application of the
307 Rules. An August 31, 1990 letter adopts the Michigan
Act 307 Rules procedure for calculating "Human Life Cycle
Safe Concentrations" and cleanup levels in ground water for
PCBs, dieldrin, TCE, arsenic, and chlorobenzene. The Act
307 Rules specify under 299.5725 2 (b) that HLSC values for
noncarcinogens are to be based on MCLs when available.
Response: The U.S. EPA disagrees with this commenter. There is
no letter dated August 31, 1990 which adopts cleanup levels.
The U.S. EPA assumes that the commenter is referring to the
staff notes on the cleanup calculations that U.S. EPA
transmitted to the commenter at its request. These notes do
not adopt any cleanup levels. The cleanup levels proposed
for adoption by U.S. EPA and MDNR for this site are
contained in the FS and the June 29, 1990 MDNR letter.
Neither of these documents proposed ground water cleanup
levels for PCBs or dieldrin. Of the chemicals listed in
this comment, the FS and MDNR June 29, 1990 letter do
establish ground water cleanup-levels for TCE and arsenic.
26
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These chemicals are considered carcinogens. Use of Rule
299.5725 (2)(b) is inappropriate for establishing cleanup
levels for these chemicals since it is only to be used to
establish Type B cleanup levels for noncarcinogens. The
proper rule to use to establish a Type B ground water
cleanup level for TCE would be 299.5709(2)(a). For arsenic,
a Type A cleanup was chosen with the proper rule being
299.5707(a). This was explained in both the FS and the MDNR
June 29, 1990 letter.
Content 6b: Soil cleanup levels have not been based on any
identified consistent application of ARARs. The target
cleanup levels (TCLs) in soil are based on direct contact
for two chemicals (PCBs and dieldrin) , and are based on
ground water protection ("20 times" the ground water TCL)
for four chemicals (TCE, barium, toluene, and
chlorobenzene). The U.S. EPA failed to provide the
rationale for setting the TCLs.
Response: U.S. EPA established TCLs according to Type A/B
cleanup levels of the Michigan Act 307 Rules as explained in
the letter to Valdas Adamkus from Delbert Rector dated
June 29, 1990. Michigan Act 307 Rules call for cleanup
levels which protect from direct contact or groundwater
ingestion, which ever is more stringent. USEPA believes
this rationale is quite clear. The more stringent cleanup
levels are direct contact for PCBs and TCE.
Comment 6c: Toxicity constants (CPFs a#a RfDs) used in the
cleanup level calculations are in st>me cases inconsistent
with the values used in the Baseline Risk Assessment, and,
moreover, some are inconsistent with current U.S. EPA
guidelines.
The use of any toxicity values in the calculation of risk-
based cleanup levels which are not those currently
recommended for use in assessing human health risks and/or
are different from the values used in the Baseline Risk
Assessment is inconsistent with the Agency's own procedures
and policies. A consistent, and valid, toxicity standard
•ust be applied for both the cleanup levels and assessing
baseline health risks.
Response: The STSSC has misinterpreted the use of the Risk
Assessment (RA) for Superfund sites. The RA identified
risks in the disposal areas for several chemicals of
concern. The selection of cleanup levels can be based on
risk management, policy or ARARs. The changes in the
toxicity constants and risk reference doses for these
chemicals have been evaluated. These changes are reflected
in the MDNR letter to U.S. EPA dated June 29, 1990. These
27
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levels represent chemical specific ARARs which must be
achieved for the Type A/B cleanup standard.
Comment 7: The FS did not identify the soil volumes or areas
until after the alternatives had been assembled, and
therefore do not seem to have been used during the scoping
of the potential response requirements.
Response: The FS reports the soil volumes and areas in Section
3.5.1, because it was the most logical placement within the
report. The RI/FS guidance on page 4-15, Section 4.2.3,
states that "(d)uring the development of alternatives an
initial determination is made of areas or volumes of media
to which general response actions might be applied." The
areas requiring response actions were delineated based on
the data collected during the RI. The areas were further
differentiated by the depths of contaminants detected, it
is this information which was used during the scoping which
provided the magnitude of contamination. Soil volumes are
pertinent to those technologies requiring excavation which
is not the intent of the scoping step.
Comment 8: Based on comment 7, were the elimination of
technologies in any way related to the volumes or areas of
impacted media.
Response: The elimination of the three conventional and 14
treatment technologies was explained in the response to
comment 5 of this section.
?
Comment 9: The volumes of excavated soils presented in Section
3.5.1 of the FS are inconsistent with the areas and depths
presented in the same section and Figure 3-3 of the FS.
Response: The U.S. EPA will require more information to respond
to the comment concerning the sections which are
inconsistent with Section 3.5.1. The U.S. EPA acknowledges
that the legend on Figure 3-3 contains errors. For the
"Depth of Soil Remediation," 1st line, the box for 0-3'
should be darkened, and 3rd line, the box should be cross-
hatched with 0-32.'
Comment 10: Section 3.6.1 of the FS states that there is a one
percent volume difference between 10 ppm and 1 ppm PCB
contaminated soil. A re-evaluation of the information
indicates there is a 43 percent volume difference between 10
ppm and 1 ppm. The assumptions and calculations for the one
percent figure are requested.
Response: The estimated volume detailed in Section 3.5.1 in the
FS provided the following breakdown of areas and ranges of
depth to be excavated to meet 1 ppm PCB cleanup level:
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Surficial Soil Area Volume
0-3 feet 3,687 sq yd 3,687 cu yd
0-15 feet 657 sg yd 3,283 cu yd
0-32 feet 455 sg yd 4,849 cu yd
The excavated volume of soil required to meet the 10 ppm PCS
cleanup level is based on substituting the 0-32 feet depth
with 0-27 feet that results in a volume of 4,091 cu yd. The
RI data indicated that PCBs were detected at 44 ppm at a
depth of 25 feet, so to meet a 10 PCB ppm cleanup level it
was determined that excavation to a depth of 27 feet would
be required in the cross hatched area in Figure 3 of the
ROD. The volumes for 0-3 feet and 0-15 feet remain the
same. The estimated total volume for 10 ppm PCB cleanup
level is 11,060 and the estimated total volume for 1 ppm PCB
cleanup level is 11,820 and that calculates to .935 percent
difference.
Conent 11: The U.S. EPA estimates the volume of soil to be
excavated to be 11, 820 cy; the Review Report estimates the
volume of soil to be 17,800 cy; and MDNR estimates the
volume of soil to be 13,023 cy.
Response: As stated earlier, actual soil volumes will be
determined during the remedial design phase.
Comment 12: The calculation of the extent of impacted media is
essential in determining the nature, cost and duration of an
appropriate response. Since the FJy stated that the volume
of ground water to be remediated could not be determined, it
is questioned on what basis is the analysis for the proposed
soil vapor extraction and carbon treatment units; and how
were the cost and duration established?
Response: The soil vapor extraction system will be implemented
to remediate the soil contamination. The parameters of the
soil contamination were determined during the RI and were
used for the suggested design of the system. Ground water
sampling results provided information on which to estimate
the extent of ground water contamination, the ground water
flow velocity, and the ground water flow direction. The
suggested design, number of wells, and pump rate for the
ground water treatment system is proposed to capture the
plume. However, pilot testing will be conducted to
determine the capacity of the carbon column, retention time,
and pump rate. Cost for the ground water treatment is based
on the number of wells, construction of the system, and the
operation and maintenance over a 5 year period. Actual
duration of the ground water treatment will be determined
during the design.
29
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Comment 13: It was felt that air stripping was improperly
removed from consideration and it is requested that it be
reevaluated as a potential ground water alternative.
Response: The U.S. EPA may reconsider air stripping during the
remedial design of the ground water treatment system.
Comment 14: The screening evaluation of the carbon adsorption
alternative notes in Section 3.6.3.5 that "(t)he anticipated
contaminated water waste stream would be low in suspended
solids or other contaminants which would foul the carbon
filters.11 This is an incorrect statement since the
naturally high iron content in the ground water would be
expected to cause plugging and fouling of the carbon
filters. During regular maintenance requirements, it may be
necessary to pretreat the waste stream. Therefore, it is
requested that the Agency reconsider the carbon adsorption
alternative.
Response: During the remedial design, the.levels of iron and
their impact on the carbon treatment will be determined and
if necessary, a pretreatment system will be developed and
implemented to render the usage of the carbon filters more
effective and efficient.
The U.S. EPA may reconsider during the remedial design phase
the carbon adsorption treatment and may replace it with air
stripping as a ground water treatment alternative based on
remedial design determinations.
'$'
Comment 15: The soil vapor extraction system, ground water
treatment system, and removal of contaminated soil under any
alternative will effectively act together to reduce the
presence of volatile organics in all affected media. It is
asked why was this synergism not reflected in the U.S. EPA's
alternatives analysis as required by the RI/FS guidance?
Response: The U.S. EPA did consider the synergism of the
treatments on the effected media, and that is why
incineration was selected to remove the contamination by
PCBs, pesticides, VOCs, and semi-VOCs; solidification was
•elected to stabilize the inorganics in the incinerator ash,
if necessary/ and in soils containing only metals; soil
vapor extraction was selected to remove the VOCs and semi-
VOCs from the deep soil units; and the ground water
treatment system will remove those chemicals which have
migrated from the soils and contaminated the ground water.
It is recognized that the remediation of the problem at
Springfield Township site is inter-related, and that the
technologies must be interfaced to ensure the cleanup to the
levels selected by U.S. EPA.
30
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Comment 16: The solidification/stabilization of ash and
redeposition of soil on-site will effectively decrease the
permeability of the site surface soil which will lead to
lower percolation of rainwater through the soil, and thus
will lower the leaching potential of any contaminated
residuals left in the subsoil. Will the stabilized soil
"cap" have an effect on the efficiency of the soil vapor
extraction system or ground water treatment?
Response: The solidification/stabilization of ash and
redeposition of soil on-site does not necessarily decrease
the permeability of the site surface soil. The consistency
of solidified material can be selected and ranges from
gravel-like consistency to a type of monolithic cement
block. Gravel-like consistency solidified material would be
preferable for use at Springfield Township site.
Precipitation will be able to percolate through a gravel-
like solidified material and could cause leaching of the
contaminants left on-site should the site not be cleaned to
the Target Cleanup Levels.
Redeposition of solidified ash, solidified soils containing
metals, and incinerated soil would occur above the ground
water table which is at an approximate depth of 85 - 90 feet
and in a limited area. The extent of redeposition will not
effect the ground water treatment system. Depending on the
soil type, sometimes it is necessary to cap the area to be
treated by soil vapor extraction to increase the efficiency
of the vacuum pumping. Pilot testing of the soil vapor
extraction system on-site will determine the need of a cap
at Springfield Township site. The physical state of the
solidified material should not affect the soil vapor
extraction operation. However, if additional soil is added
during regrading of the site, this soil cover may have the
beneficial effect of a cap.
Comment 17: The actual need for solidification of the
incinerator ash is unknown at this time. Without the
benefit of bench and pilot studies, the need for and type of
ash stabilization which may be necessary at the site, and
the implementability, effectiveness, and cost associated
with this process alternative cannot be accurately
determined.
Response: Solidification/stabilization has been used for the
control of inorganics at several hazardous waste sites, and
substantial documentation of the effectiveness of the
process exists for these waste types. Of the available
solidification processes currently being marketed, most can
be classified as either portland cement-based or silicate-
based. If solidification/stabilization is necessary, field
testing of the materials will be necessary to determine
31
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which of the processes would be successfully used at the
Springfield Township site. The selected remedy includes the
costs of solidification which nay not be necessary for the
incinerator ash and therefore could be an overestimate. The
costs in the FS are estimates, and according to the RI/FS
guidance "these 'study estimate' costs made during the FS
are expected to provide an accuracy of +50 percent to -30
percent and are prepared using data available from the RI."
The U.S. EPA recognizes that the costs presented in the FS
and Proposed Plan may be modified during the remedial design
of the selected remedy.
Comment 18: During the FS evaluation of the various soil
alternatives, the units of cy and tons were used
interchangeably which is not a correct assumption. A
conversion factor of 1.35 tons per cubic yard should have
been used which would increase the weight of the soil and
the length of time needed to complete incineration. The
underestimation of the incineration time is a significant
concern to the STSSC since it improperly presents the
actual implementation schedule.
Response: The U.S. EPA acknowledges that the interchanging of cy
and tons may be incorrect. The soil weight depends on the
types of soil and its physical state which will have to be
determined for the soil at Springfield Township site. A
test burn will be conducted to determine the operating
parameters and limits, expected emissions and residual ash
characteristics of the incinerator/; Results of the test
burn will provide information upon *&hich a more accurate
schedule for the selected remedy can be projected. The U.S.
EPA will continue to proceed in an expeditious manner.
Comment 19: It is apparent that the soil volumes were calculated
based on an incorrect analysis of Michigan Act 307
Administrative Rules. The FS contains numerous
contradictions and deficiencies which make it impossible to
determine whether the soil volumes will efficiently achieve
the level of protectiveness. The Review Report provides
calculations based on the RI Data and the RI/FS guidance for
identifying volumes and developing source control actions
which efficiently and effectively eliminate or minimize the
need for long term management. The U.S. EPA should evaluate
the analysis in the Review Report and provide a response to
it or a revision of its own calculated values prior to any
attempt to select an appropriate remedy.
Response: It is unclear as to what exactly the commenter would
like addressed. Therefore, the U.S. EPA will respond as
follows. The U.S. EPA recognizes that the estimated soil
volume of 11,820 cy may be modified during refinement of the
remedial design. The volume of soil as defined by the
32
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surface area and depth has been identified for remediation
purposes. The soil volume differences requiring
remediation, as noted by the commenter, refers to the
conversion of the cubic yards to tons which may impact the
duration of the selected remedy. The U.S. EPA selected a
remedy which will be protective, satisfy the remedial
action objectives cited in Section 2 of the FS, and
eliminate the need for long term management or monitoring.
The cleanup levels applied by the STSSC in the Review Report
does not eliminate long term management nor does is provide
full protection to human health and the environment.
Comment 20: It is requested that arsenic be eliminated as a
target compound because the average concentration of arsenic
in the ground water is more than 10-times less than the U.S.
EPA's MCL drinking water guideline and concentration levels
in the soils are within the range of Michigan ambient soil
levels determined by MDNR's background soil study.
Response: Arsenic will not be eliminated as a target compound
because the Michigan ambient soil level study does not
provide site specific information and is not an enforceable
document. The background level will be determined from
background samples collected during the remedial design.
Also, the U.S. EPA does not agree with the commenter's
calculation of average concentration of arsenic. The basis
of the arsenic contamination is the actual concentration
levels detected in the ground water samples. Due to the
carcinogenic nature of arsenic, the U.S. EPA believes that
it is in the best interest of protection of human health and
the environment to retain arsenic as a target compound.
Should information collected during the remedial design
prove otherwise, then arsenic as a target compound shall be
reconsidered.
Comment 21: Dieldrin has been selected by the U.S. EPA as a
chemical of concern. Because of its low detection
frequency, it is requested that dieldrin be deleted from the
list of chemicals of concern.
Response: This comment was previously addressed in the response
to this section's comment 3.
Comment 22: Because of the demonstrated background levels of
barium in Michigan soil, and the occurrence of barium off-
site in areas not affected by disposal at levels higher
than the TCL (100 ppm), it is requested that the Agency
provide data and justification for the 100 ppm cleanup level
for barium in soil.
Response: According to information provided in Appendix A of the
Review Report, the background concentration level ranges
33
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from 0-291 ppm and the median is 48 ppm. The target cleanup
level for in the FS is above the median background
concentration level. Hand auger sampling data in Appendix
D-9 of the RI identifies barium levels as high as 4,900 ppm
which was detected in HA 104; other examples include HA 105,
630 ppm; HA 48, 4,540 ppm; and HA 47, 2,945 ppm. The 100
ppm cleanup level for barium is based on Michigan Act 307,
R 299.5711, Rule 711.(2) which refers to R 299.5709 (2)(c)
that assures that soils do not pose a threat of aquifer
contamination. The calculations are available in the
Administrative Record and in Section A of the Responsiveness
Summary.
Comment 23: It is requested that toluene be removed as a target
compound for cleanup in both ground water and soil because
concentration levels for toluene detected in the ground
water is less than the TCL of 40 ppb and there is no health
risk identified for toluene in soil.
Response: Toluene was detected in hand auger samples (e.g., HA
48, l.OE+06 ppb), in deep soil borings (e.g., DB-05,
12,650,000 ppb at 3-5'; DB-03, 621,300 ppb at 0-2' and
346,000 ppb at 23-25'; and DB-103, 770,000 ppb at 30' and
13,000 ppb at 75'), and in the test pits (e.g., Test Pit 1,
170,000 ppb; Test Pit 2, 1,300 ppb; and Test Pit 3,
18,000,000 ppb). The concentration levels of toluene in the
soil sampling pose a significant threat as a source of
degradation to the aquifer. The presence of toluene in the
soils and thereby, its potential to contaminate the aquifer
and its toxicity to the central nervous system and liver
warrant its inclusion on the target compound list.
Comment 24 and 25: The FS is deficient in that it does not
contain a comprehensive discussion of the impact of the
ARARs on each alternative's ability to effectively meet
ARARs and such an analysis should be provided prior to
selection of a remedial alternative.
Response: U.S. EPA disagrees with the commenter that the FS is
• deficient. The FS and its ARAR discussion is consistent
with the revised NCP.
The revised NCP indicates that the level of analysis for a
particular site should be commensurate with the complexity
of the site problems being addressed (40 CFR 300.425(b) and
(e)(9)(iii)). The detailed analysis in the FS is to focus
only on viable alternatives (40 CFR 300.425(e)(9)(iii)(B)).
All alternatives must attain ARARs (42 U.S.C. 9621). If an
alternative does not attain ARARs then the alternative
cannot be selected and is not considered a viable
alternative worthy of further consideration.
34
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A number of potential alternatives did not pass the initial
screening stage due to factors other than ARARs.
Consequently, the alternatives that did not pass the initial
screening did not require any further analysis since they
were determined to be inviable for this site.
Those alternatives that passed the initial screening were
evaluated in the FS against all nine evaluation criteria,
including ARARs. In the detailed analysis section of the FS
there is a narrative summary of each alternative's ability
to meet the pertinent major ARARs. Additionally, Tables 2-2
and 2-3 of the FS present the operable Federal and State
ARARs for the site along with a brief summary of what is
required. Tables 2-la and 2-lb of the FS presents the
cleanup levels and an indication of the ARARs which were
used to establish these cleanup levels. Finally, the
Administrative Record file that was available for public
review contains further analysis by MDNR of the State ARARs
and its interpretation of the application of Act 307 to this
site (see the June 26 and 29, 1990 letters from MDNR).
Comment 26: Cleanup levels were claimed by the U.S. EPA to be
based on ARARs, primarily Michigan's Act 307 Rules. The
reason for and the way the 307 Rules were applied are
undocumented by the U.S. EPA. In addition, other
inconsistencies are noted: Michigan Act 307 Rule Type C is
applicable for cleanup, U.E. EPA's interim guidance on
cleanup levels for lead were not used, and arsenic is being
targeted for cleanup above the U.SV EPA's MCLs. The NCP
requires that the U.S. EPA use MCL3b at Superfund sites.
Response: Section 121 of CERCLA requires selected remedies to
comply with all promulgated applicable or relevant and
appropriate standards, requirements, criteria or
limitations. CERCLA Section 121.(d)(2)(A)(ii) states:
"any promulgated standard, requirement, criteria, or
limitation under a State environmental or facility
siting law that is more stringent than any Federal
standard, requirement, criteria, or limitation,
including each such State standard, requirement,
criteria, or limitation contained in a program approved
authorized or delegated by the Administrator under a
statute cited in sub paragraph (A) , and that has been
identified to the President by the State in a timely
•anner, is legally applicable to the hazardous
substance or pollutant or contaminant concerned or is
relevant and appropriate under the circumstances of
the release or threatened release of such hazardous
substance or pollutant or contaminant, the remedial
action selected under section 104 or secured under
section 106 shall require, at the completion of the
35
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remedial action, a level or standard of control for
such hazardous substance or pollutant or contaminant
which at least attains such legally applicable or
relevant and appropriate standard, requirement,
criteria, or limitation."
The law continues that "(s)uch remedial action shall
require a level or standard of control which at least
attains Maximum Contaminant Level Goals (MCLGs)..."
The U.S. EPA identified Michigan Act 307 Rules as an ARAR
for this site and selected the Type A/B cleanup. The
cleanup standards identified in R 299.5707, R. 299.5709, and
R. 299.5711 are more stringent than the Federal
requirements and therefore, supersede the applicability of
the MCLs as cleanup levels.
Guidance documents are not considered ARARs (55 FR 8745).
If an ARAR establishes a cleanup level the remedial action
must conform to that cleanup level and not to any level
suggested in a guidance document. Since U.S. EPA has
selected a Type A/B cleanup for this site the cleanup levels
required in Act 307 for a Type A/B clean-up are ARARs and,
consequently, must be attained at the site.
Evaluation of ARARs
Comment 1: U.S. EPA has not explained why a Type C cleanup is
not acceptable and should accept tMfe commenter's proposal of
a remedial action alternative which it alleges will meet Act
307 Type B/C cleanup levels.
Response: For the following reasons, U.S. EPA determined that a
Type A/B cleanup, not a Type C cleanup, is appropriate for
the site and is the best at balancing the nine evaluation
criteria contained in CERCLA and the NCP:
the small size of the site and the isolated nature of
the three distinct areas of high PCB contamination;
the small volume difference between the amount of soils
that would need to be treated to a PCB concentration of
1 ppm versus the 10 ppm proposed by the commenter;
the toxicity of PCBs at very low concentrations;
the residential and agricultural nature of the area
around the site and its future growth potential;
the potential present and future use of the property
for recreational and residential purposes;
36
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the ability to achieve a 1 ppm cleanup level for PCBs
in a cost-effective manner;
the increased permanence, reliability, and long-tern
certainty of protection of human health and the
environment with a 1 ppm PCB cleanup level;
the increased reduction in the volume of hazardous
substances remaining on site;
the State and community's strong preference for a Type
A/B cleanup;
the fact that a Type A/B cleanup for this site
complies with CERCLA's mandate in Section 121 to use
permanent solutions to the maximum extent practicable;
the fact that a Type A/B cleanup for this site is
consistent with EPA's CERCLA program goal to choose
remedies which maintain protection over time and is
consistent with U.S. EPA's August 1990 Guidance on
Remedial Actions for Superfund Sites with PCB
Contamination; and
the fact that there will be no need for long-term
monitoring and future remedial action if the Type A/B
cleanup levels are attained.
Since U.S. EPA's analysis indicates a Type A/B cleanup
level is the best at balancing the vCERCLA and NCP nine
evaluation criteria and complies with all ARARs, including
Michigan Act 307 Rules, U.S. EPA will not present a
detailed critique of whether the commenter's proposed
remedial action and cleanup levels meet the Type C cleanup
requirements of Michigan Act 307 Rules. U.S. EPA does note,
however, that the commenter's proposed remedial action plan
does not appear to satisfy the Type C cleanup levels since
it fails to establish cleanup levels for all of the
pertinent indicator chemicals. Dieldrin, arsenic and
toluene in the soils and arsenic, lead and toluene in the
ground water are chemicals of concern found at the site and
are considered either carcinogenic or highly toxic. As
such, they should be considered indicator chemicals with
cleanup levels. Additionally, since the commenter's
proposal calls for containment of PCBs (at one location the
residual concentration would be potentially as high as 44
ppm), U.S. EPA interprets Michigan Act 307 Rules to require
of a Type C remedial action plan, where containment is a
component, long-term monitoring, deed restrictions,
financial responsibility and a schedule for implementation
of the remedial action. The plan submitted by the commenter
did not contain any of these items. Finally, the commenter
37
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nay not be able to provide the deed restrictions required of
a Type C cleanup since the commenter does not own the
property where the site is located.
ent 2: The alternative proposed by the commenter is
consistent with Act 307, and pursuant to Rule 705(4) of the
Act 307 Rules its proposal must be granted.
Response: U.S. EPA does not agree that it must adopt a proposed
remedial alternative and alternate cleanup goals submitted
by commenters. Neither the revised NCP nor CERCLA require
such action either in response to comments on a U.S. EPA's
Proposed Plan or at any other stage in the cleanup process.
Additionally, the position articulated by the commenter
would negate CERCLA's clear delegation of decision-making
authority to the U.S. EPA and would lead to practical
implementation problems. The assertion that this portion of
the rule is an ARAR applicable to U.S. EPA is incorrect
since it explicitly states that it is to apply to MDNR or
the Director of MDNR.
Selection of the remedial action plan is to be made by U.S.
EPA (42 U.S.C. 9621). Under the commenter's interpretation
of Michigan Act 307 Rules, the remedy selection decision is
taken out of the hands of the U.S. EPA and placed into the
hands of any person who submits a plan to the Agency.
Additionally, since Michigan Act 307 Rules allow for any
combination of a Type A, B or C cleanup and do not limit
the number of remedial action plans, it is possible, under
the commenter's interpretation of pale 705(4), to have
multiple remedial action plans with varying or inconsistent
cleanup levels or remedial technologies.
Finally, U.S. EPA would note that the remedial action plan
submitted by the commenter does not meet the threshold
requirements for a cleanup in that it: 1. fails to provide
adequate long-term protection of human health and the
environment when balancing the long-term uncertainties
associated with containment of PCBs versus the relative
small volume of additional soils needed to be treated to
eliminate those uncertainties; 2. fails to establish cleanup
levels for all of the contaminants of concern found in the
ground water and soils; 3. fails to provide for long-term
monitoring, deed restrictions and financial responsibility;
and 4. fails to submit a schedule for implementation of the
actions proposed in their remedial alternative.
Comment 3: U.S. EPA failed to document the reason for its
choosing an Act 307 Type A/B cleanup. U.S. EPA's evaluation
of whether Act 307 is an ARAR must be provided to the
public for review and comment prior to signature of the
Record of Decision since it appears to be a fundamental ARAR
38
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for the site and U.S. EPA indicated in the FS that it did
not agree with or accept it as an ARAR. Failure to provide
its analysis prior to the signing of the Record of Decision
is contrary to the public participation requirements of
Section 117 of CERCLA and 40 CFR 300.430(f)(3)(C).
Also, The comnenter requested another meeting to discuss the
Act 307 rules and their application to the site.
Response: U.S. EPA agrees that its reason for choosing the
Michigan Act 307 Rules Type A/B cleanup levels was not
available in the FS and Proposed Plan. U.S. EPA indicated
in Table 2-3 of the FS that it was evaluating whether
Michigan Act 307 Rules was an ARAR. In addition, Tables
2-la and 2-lb of the FS and the June 29, 1990 letter from
MDNR, which are in the Administrative Record, explain how
Michigan Act 307 Rules were used to develop the cleanup
levels contained in the FS and the Proposed Plan. U.S.
EPA's rationale for choosing the Michigan Act 307 Rules Type
A/B levels for this site are presented in the Record of
Decision and in other sections of this Responsiveness
Summary and the Administrative Record.
U.S. EPA agrees that at the time it signs the Record of
Decision all ARARs must be identified. U.S. EPA does not
agree, however, that further public review or comment is
required or necessary* An additional public comment period
is required only if new information is made available and
the proposed plan is revised after the initial comment
period in such a manner that there ds a significant change
to the basic features of the remedy with respect to scope,
performance or cost and the change could not have been
reasonably anticipated by the public based on the
information available in the Proposed Plan or the
Administrative Record (40 CFR 300.430(f) (3c)). None of
these conditions is satisfied for this site.
As discussed in the ROD there have been no significant
changes in the Proposed Plan for the site. The only change
that has occurred is that U.S. EPA has indicated its
concurrence with MDNR that portions of Michigan Act 307
Rules should be an ARAR and that the Type A/B cleanup
levels are the appropriate cleanup levels for the site.
The cleanup level information was presented to the public
for their review and comment at the time U.S.EPA published
notice of the availability of the Proposed Plan and the FS.
Both documents identified Michigan Act 307 Rules as a
potential ARAR. Table 2-3 of the FS and MDNR's June 29,
1990 letter explained how the Michigan Act 307 Rules were
applied to develop the cleanup levels. Consequently, at
the time the public notice was published the public knew and
39
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had an opportunity to comment on the proposed remedial
action; the proposed cleanup goals; the application of
Michigan Act 307 Rules to this site; and MDNR's evaluation.
The comment period on the Proposed Plan and the FS provide
the public with reasonable opportunity to comment on the
preferred alternative and meet the criteria in the NCP (40
CFR 300.430(f)(2).
U.S. EPA disagrees that another meeting was necessary to
meet with this commenter. During the entire public comment
period, the public had available to it for review and
comment the June 26 and 29, 1990 letters regarding the
application of ARARs at this site and all other final
documents relied upon by the U.S. EPA to develop the
Proposed Plan. Neither the NCP nor CERCLA require U.S. EPA
to conduct private meetings with commenters. U.S. EPA
provided this commenter with the opportunity to present its
comments at the public meeting that it conducted on July 24,
1990. Representatives of this commenter did present
comments at that meeting as well as during the public
comment period. Additionally, U.S. EPA on July 20, 1990
extended the public comment period an additional 30 days at
the request of this commenter. The Administrative Record
indicates that the U.S. EPA and MDNR met with this commenter
numerous times from January to July to discuss the
appropriate cleanup levels for this site and the potential
application of Michigan Act 307 Rules to this site. Given
this level of information and access to U.S. EPA and MDNR
staff, U.S. EPA does not believe tftat a second meeting with
this commenter was necessary or required. Finally, the
public had notice and a reasonable opportunity to comment on
the proposed cleanup levels since the FS and Proposed Plan
clearly indicated what the proposed levels were and how they
were calculated.
Comment 4: The remedy proposed by the commenter should be
adopted because it comports with statements made by MDNR at
its presentation before the Joint Committee on
. Administrative Rules (JCAR) regarding application of the Act
307 rules. In particular, MDNR stated that "Type C clean-
ups would be developed on the basis of a site-specific risk
assessment taking into account expected real exposures,
rather than the assumed exposure in Type B clean-ups".
Response: The MDNR in its March 22, 1990, statement to JCAR
stated "that it expected most clean-ups would be Type B
actions" and that the Type B clean-up criteria in the rules
were chosen so that "after the completion of a remedial
action, the property could be used for any purpose without
concern for potential hazardous substance exposure." In its
June 29, 1990, correspondence MDNR indicated to U.S. EPA
that applying Michigan Act 307 Rules to this site, it
40
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preferred the Type A/B cleanup levels. Furthermore, it
believed that the Type B cleanup level for PCBs would be
"the most cost effective means to protect public health and
the environment."
Comment 5 and 6: The Draft September 1989 Guidance on Selecting
Remedies for Superfund Sites with PCS Contamination and the
PCB Spill Policy (40 CFR 761.120 - 129) should be added to
the ARAR chart as "to be considered" (TBCs) since they are
mentioned in the discussion of chemical-specific ARARs
(section 2.2.2.1 of the FS).
Response: The purpose of the ARAR chart was to present the
ARARs, not the TBCs. The use of TBCs is discretionary (55
FR 8745-46). TBCs may be used to establish cleanup levels
where there are no ARAR established cleanup levels.
However, when the ARARs establish cleanup levels, TBCs may
not be used in competition with the identified ARARs (55 FR
8745). The Michigan Act 307 Rules establish the cleanup
levels for a Type A/B cleanup for all contaminants of
concern at the site, including PCBs. Consequently, it would
have been incorrect to list these documents as TBCs. These
documents were included in the Administrative Record File
since U.S. EPA reviewed them as part of its decision process
on the selection of the appropriate cleanup action at the
site.
Comment 7: Michigan Act 60 regarding PCB compounds has been
superceded by U.S. EPA's TSCA regulations and therefore
should be removed from the list of -iistate ARARs.
Response: Both Michigan Act 60 Rules (299.3301-3318), Michigan
Act 60 and the federal TSCA regulations establish
requirements for the disposal, packaging, labelling and
transporting of PCB contaminated material. As stated
elsewhere in this Responsiveness Summary, more stringent
State regulations are ARARs. Michigan Act 60 was identified
as a potential ARAR in Table 2-2 and its potential impact
was summarized there also. Examples of two areas where the
Michigan Act 60 Rules and the Act are different from and
therefore potentially more stringent than the TSCA
requirements are:
a. Michigan Rule 299.3314 requires more information on
the warning label to be affixed to containers,
transport vehicles or storage areas handling certain
concentrations of PCB contaminated materials than
required under 40 CFR 761.
b. MCL Section 13.28(8) prohibits the disposal of PCB
contaminated materials if they have a concentration
greater than 100 ppm PCBs.
41
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The appropriate more stringent provisions of Michigan Act 60
and its rules along with the federal TSCA requirements will
be used during design and implementation of the selected
remedy to regulate the storage, packaging, labelling and
transport phases of the remedial action.
Comment 8: There is no discussion or reference in the FS for
the Hay 1986 study produced by the U.S. EPA's Office of
Health Effects Assessment (OHEA) regarding PCB cleanup
levels at Superfund sites. The OHEA study presented the
fundamental concepts regarding cleanup levels in soil and
was used as a basic reference during the development of both
the PCB spill policy and the draft cleanup guidance. It is
believed that the Agency should have included this pertinent
reference in its FS evaluation.
Response: The U.S. EPA notes that the commenter would have liked
a reference to the OHEA study in the FS. The U.S. EPA did
reference The Draft Guidance on Selecting Remedies for
Superfund Sites with PCB Contamination dated September 22,
1989 in the FS and noted that the cleanup standards were
based on ARARs and subsequently the selection of Type A/B
cleanup level of Michigan Act 307 Rules. The more
stringent ARAR takes precedent over the Draft Guidance and
OHEA study as they would be to be considered(TBCs).
Comment 9: The STSSC submits that its proposed alternative
remedy for PCB soil at the Site is not only fully protective
of human health and the environment, but unlike the U.S.EPA
preferred alternative, the Propose? STSSC alternative remedy
complies with all federal and state ARARs including the
TBCs.
Response: This comment is addressed in the Section on Proposed
Remedial Action Plan.
Comment 10: Section 3.6.1 of the FS states that as a result of
the one percent difference in soil volumes for a 1 ppm PCB
cleanup versus a 10 ppm cleanup, the final cleanup goal
will utilize a 1 ppm level of PCBs as the soil cleanup
goal. To the contrary, both Section 2.2 of the FS and Table
2-la of the FS clearly state that the Michigan Act 307
regulations were used as the basis of the 1 ppm cleanup
level. The commenter requests that the U.S. EPA explain
these contradictory statements and detail the exact basis
for the PCB cleanup goals for soil.
Response: The U.S. EPA does not consider the statement that 'as
a result of the one percent difference in soil volumes for a
1 ppm PCB cleanup versus a 10 ppm cleanup, the final cleanup
goal will utilize a 1 ppm level of PCBs' is contrary to
Section 2.2 and Table 2-la of the FS which indicate that
42
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Michigan Act 307 Rules are the basis for the cleanup levels.
Section 3.6.1, page 3-6, states that "onsite soil shall be
treated to a level where detected concentrations of the
target chemicals are below the preliminary cleanup goals
and TBCs for soil, as established in Section 2 of this
report. ...Surficial soil exceeded the preliminary cleanup
goals and TBCs for all the target chemicals. Deep soil
exceeded the preliminary cleanup goals for PCBs, toluene,
chlorobenzene and lead. Because the volume difference
between 10 ppm and 1 ppm PCBs is less than 1 percent, the
soil alternatives utilize 1 ppm as the final cleanup goals."
This paragraph indicates that the 1 ppm PCB cleanup level
was based on the ARAR and that the 1 percent soil volume
difference was used as a primary balancing criteria for
evaluation of the alternatives.
Compliance with the NCP
Comment 1: Section 117 Public Participation of SARA requires an
opportunity for submittal of comments on the proposed plan
and requires the President (U.S. EPA) to provide a response
to each of the significant comments, criticisms, and new
data submitted in written or oral presentations. The
failure on the part of the U.S. EPA to provide a reasonable
explanation of how the Act 307 based cleanup type selections
were made and how specified cleanup levels were prescribed
prevents the public participation envisioned by Congress and
debated heavily during reauthorization of CERCLA.
&
Response: Response to Comment 6 of the Feasibility Study section
addresses this comment.
Comment 2: The STSSC requests clarification of the specific
status of Act 307 as an ARAR and the opportunity to comment
on the application of this ARAR prior to remedy selection.
Response: Response to Comment 3 of the Evaluation of ARARS
section addresses this comment.
Comment 3: The draft FS prepared by the MDNR contractor and
U.S.EPA'B comments on it should be part of the
Administrative Record according to 40 CFR 300.810(a) and the
commenter was denied effective public participation because
it was denied these documents and provided with notes on
cleanup levels late in the public review process.
Response: Neither draft nor predecisional deliberative documents
are included in the administrative record regardless of
whether they are prepared by U.S. EPA, the State or their
contractors. (55 FR 8801, 40 CFR 300.810(b)). The only
exception to this general rule is where the draft document
43
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was relied on and there is no final document generated and
made part of the record at the tine the response action is
selected. This exception is inapplicable to the present
case since the final*RI and FS were the documents relied
upon by the Agency in selecting its remedy for this site
and they were available in the Administrative Record File at
the time the public was notified of the U.S. EPA's Proposed
Plan for the site. Additionally, the June 29, 1990 letter
from MDNR and Michigan Act 307 Rules explain how the cleanup
levels were derived (see also responses to comment in
Section A and Evaluation of ARARs). The cleanup
calculations were provided to the commenter as an aid in
their evaluation. In no event were the calculations
required to be in the Administrative Record, since the June
29, 1990 letter and Michigan Act 307 Rules indicate how the
cleanup levels were established.
Comment 4: The commenter quotes section 300.430 of the NCP that
states "lead agency shall include a screening step, when
needed, to select a reasonable number of alternatives of
detailed analysis." Since the technology screening is
merely an intermediate step in the selection process, the
U.S. EPA should have included thorough documentation of the
screening methodology which was utilized in the FS.
Response: The U.S. EPA did not deem the screening step which
eliminated alternatives as necessary and therefore, it was
not included in the FS. Tables 2-5 and 2-6 of the FS
identify the technologies considered and screened for use at
Springfield Township site. Responses to comments 5, 24, and
25 of this Feasibility Study Section provide further
elaboration to this comment.
Comment 5: Aside from a single statement alluding to the Act 307
Rules, no discussion of the ARARs or their significance as
they pertain to the development of the remedial action
objectives has been presented in the FS or included in the
Record File. The U.S. EPA failed to provide both an
explanation for the omission and a proper and complete
discussion of the role of the identified ARARs for the Site
prior to its closure of the public comment period and the
initiation of the final remedy selection process.
Response: Responses to Comments 24 and 25 in the Feasibility
Study section and Comment 3 in the Evaluation of ARARs
section addresses this comment.
Comment 6: The detailed analysis of alternatives section of the
FS (Section 4) does not use the nine criteria to evaluate
the alternatives. This approach to the detailed evaluation
of alternatives is inconsistent with the intent of both the
statutes and the NCP. The analysis of the nine criteria
44
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provided in Section 5 of the FS report does not provide
sufficient detail to allow for informed public comment on
alternatives screening.
Response: The U.S. EPA acknowledges that the detailed analysis
of the FS (Section 4) used criteria stated as engineering
considerations, public health evaluation, environmental
evaluation, ARARs evaluation, and cost and not the nine
criteria evaluation cited in 300.430(e) of the NCP. As
noted by the commenter, the detailed evaluation in the FS
provides the information required of the nine criteria but
under different headings. Section 5.1 of the FS and the
Proposed Plan provide a comparison of the alternatives based
on the nine criteria. U.S. EPA disagrees with the commenter
that there is insufficient detail in the documents for an
informed public comment.
Comment 7: The current RI/FS Guidance states that when
calculating the present net worth of an alternative, a
discount rate of five percent before taxes and after
inflation should be applied. The FS, however, uses a ten
percent factor. This is significant in light of concern
related to the quality of the RI and the accuracy of
projections relating to volumes of contaminants and
treatment levels which could influence the length of the
proposed response actions and the costs.
Response: The U.S. EPA disagrees with the commenter's
conclusions concerning the guality^pf the RI, the volumes of
contaminants and the treatment levels in previous responses
in this Responsiveness Summary. The U.S. EPA acknowledges
that the discount rate of 10 percent was used to calculate
present worth of O&M costs for all alternatives. Since 10
percent was applied consistently to all alternatives, the
alternatives' O&M costs in the FS does represent the
relative difference in costs between the alternatives.
Comment 8: In general, numerous critical pieces of background
information are unavailable in either the FS, PRAP or
Administrative Record making informed public participation
impossible. By failing to provide this information, the
Agency has deprived the public an opportunity to review and
comment prior to remedy selection.
Response: This comment is a compilation of many previously
stated comments which have already been addressed in the
Responsiveness Summary.
45
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Proposed Remedial Action Plan
Quoted from Section 5.1 of the Review Report, "the STSSC
alternative consists of the following items:
* Fully health protective cleanup of soil meeting both
State and Federal ARARs.
* Thermal treatment of excavated soil either on-site or
off-site.
* Solidification, as necessary, of any ash prior to the
redeposition of on-site.
* SVE of organic constituents from the soil at specific
locations and depths.
* As necessary, extraction, treatment by air stripping,
and reinjection of groundwater which contains TCE at
levels in excess of 3 ppb.
"An Act 307Type B/C cleanup of soil is proposed.
This soil remediation will provide full protection of
human health and the environment but will eliminate the
unnecessary removal of a large quantity of soil to
eliminate a small amount of residuals that are deep
below the site surface. Any residuals following
treatment under this alternative are neither a direct
contact threat nor a groundwater source threat. Any
PCB-containing soil that is l&ated within the areas
outlined in Figure 5 (of the Review Report) will be
excavated and treated via thermal destruction. The
proposed STSSC alternative soil remedy is fully
protective of public health and the environment,
results in the removal and destruction of over 98% of
the total mass of PCBs currently on the site, and
effectively destroys all other organic constituents
within that soil volume."
The STSSC Proposed Remedial Action Plan is very similar to
the U.S. EPA's selected remedy. Both remedies proposed
excavation and incineration of PCB contaminated soils;
solidification of ash, if necessary; redeposition of soil
and ash on-site; soil vapor extraction; and a ground water
treatment system. The remedies differ in that the U.S.
EPA's remedy requires more soil to be remediated by
incineration, solidification of soils containing metals
above background levels, a larger scale soil vapor
extraction system, and carbon adsorption treatment for the
ground water rather than air stripping.
46
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The modifications of the STSSC Proposed Remedial Action Plan
are based on premises which are not acceptable to the U.S.
EPA. The STSSC recognizes the Michigan Act 307 Rules as an
ARAR and selected the Type B/C cleanup level standards. As
a result, the STSSC proposed a new target cleanup compound
list and cleanup level goals. This list eliminated the
following from the chemicals of concern for soils: toluene,
arsenic, and dieldrin; and the following chemicals of
concern for ground water: toluene, arsenic, and lead, in
the preceding sections of the Responsiveness Summary, the
U.S. EPA has provided explanation for the rejection of these
changes by the STSSC. As a result, though the STSSC
Proposed Remedial Action Plan presents reasonable
technologies for the remediation of Springfield Township
site, it does not offer complete remediation, leaving
contamination on-site which is not acceptable to the U.S.
EPA.
The STSSC provides a rationale for the selection of the Type
B/C cleanup levels, but as explained previously, the U.S.
EPA, in its discretionary position, selected the Type A/B
cleanup levels over the Type B/C. The selection was based
on a review of the best balancing of the nine evaluation
criteria and which included reasons such as the ability to
achieve a 1 ppm cleanup level for PCBs in a cost-effective
manner; the toxicity of PCBs at very low concentrations; the
residential and agricultural nature of the area around the
site and its future growth potential; the increased
reduction in the volume of hazardous substances remaining
on-site; and the State and community's strong preference for
a Type A/B cleanup.
The U.S. EPA rejects the STSSC Proposed Remedial Action Plan
for it does not fully satisfy the threshold criteria, that
of overall protection of human health and the environment
and compliance with ARARs. The selection of the Type A/B
cleanup level sets the concentration level of PCBs at 1 ppm
because of the direct contact threat from the point of
exposure with the contaminated soils. STSSC Proposed
Remedial Action Plan indicates that low level PCBs can be
left in the soils below the point of excavation based on
their risk assessment. However, the definition of point of
exposure in relation to direct contact as cited in Michigan
Act 307, R. 299.5711 (7), is "(f)or the purposes of this
rule, the point of exposure shall be assumed to be any
location at the site or any location which hazardous
substances in or emanating from, soil are transported by
runoff, air dispersion, or other natural forces.1* Based on
the State's interpretation of the point of exposure, PCBs
must be remediated to 1 ppm levels to be fully protective of
human health and the environment. Since the STSSC Proposed
Remedial Action Plan is based on STSSC's selection of Type
47
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B/C cleanup goals and not the recognized Type A/B cleanup
goals, the Proposed Remedial Action Plan does comply with
the subsets of the designated ARARS for the site.
A review of primary balancing and modifying criteria, the
U.S. EPA's selected remedy more completely satisfies the
criteria than the STSSC Proposed Remedial Action Plan. The
selected remedy provides long-term effectiveness and
permanence by removing and eliminating all contaminants
from the site, reducing the toxicity, mobility, or volume of
more contaminants through treatment; and by being cost-
effective in terms of the difference between a Type A/B
cleanup levels which require no management controls or deed
restrictions. It should be noted that the costs provided by
the STSSC for their Plan do not include the long-term
management, 30 year ground water monitoring program, and
institutional control costs which would be incurred on a
Type B/C cleanup level.
48
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f. C. Joroan
work Plan flugaentatienll E.C. Jordan
Oioxin and Furin S
Plan
E.C. Jordan
E.C. Jordan
E.C.Jordan I KDNR
RECIPIENT
jpr.r.vt e/ 'jt
keoorts/St
•»epcrts/St
Reports/5'
Sanphng/l
-------
Pane No.
07/c7/6fi
TITLE
6U1MNCE MCLTiNT IMEX
SPRINGFIELD fOUNJHlP OuT-P SITE:
DGCUnENiS NUT CO^lED-fAC K REVIEWED
flT USEPft RESIGN V,CHICflGO, IL
flUTHOR
DflTE
N.U.S. Corporation's
Revised Guidelines for
Data Evaluation Criteria
for Reviewing SflS Chlori-
natw Dioxin/UiDenzofuran
Data
on fteneoial
Invent oat ions L>naer
"
65/06/00
on FessiDihty
Stnoies Uncer
85/06/00
so Paolic Healtn
Evaluation flanusl
UtEPA
86/10/00
Intern Soioanc? on
Sucsrr'und Seise: ion of
USE: A
TStfl PCt Clean-uo
Policy
Off-Site Policy
Final Buioarce for the
CK'peration of ftlSDR
Hesltn »hE?srn9n:
Activities Nith the
Surer fund ftesedial
Process
OWSES Dir. 9585. *-02
87/04/22
Intena 6uioance on
fcnnistrative Secoros
for tensions on Selection
of CEfidA Keso-iTise Actions
F> '66 fegion V NOD
Process Guioance. Memo
froi Chief of the Euer-
eency I teoeoul Re;o-:
-------
Psae NO.
6U11MICE OOCUT-tNT INDEX
SFUHiL'HtLO TOWNSHIP C-UMP SITE:
DOMINI 5 WIT (.Ct-IEH-wOV K PfvltWf.D
flT USE>'rt REGION V.CHICAGO, II
TITt.1-: flUTH'Jrt DflTE
ftecorfl of Decision 88/0*/Ol
Question; t ftnsvors-DIWFT
-------
nit to. i
C7M/JS
ncu/tua nus tin finr
iwriijsrwiri mow • HMH 11
sniiermn ronssir urn sin
omuo cowrr, KI
UTSOl
ucninr
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Docmm
|J/«5/cr letter
leetJBj ritt SSEPl
ut MIR to illor
fifi tie oppor-
tisitf to present
reietfiitjoo pictige
tferejopetf /or toe
Jite
MeriiaiioMttr. f.L.I«Jicti,tfSm Correipoodeoce
-------
ACRONYM LIST
MDNR Michigan Department Of Natural Resources
PRP Potentially Resposible Party
USEPA United States Environmental Protection Agency
-------
lo. 1
u/09/89
msiinm mis om nm
KtcoKD • mm n
rommf WHP sin
ouun mm, HI
ncitiw
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31 H/07/21 fraotiittiJ jttter t.Ltnioisai,
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tctioo flte
tf Btit
for
M.IeJioo.BSIM Correspondence j
23t H/6T/OC Intiitl Itnstigitiet tSttA
(FoJoit 1 of 3)
32! 19/04/00 Sttttitl JBffStiyatico PSfFA
(FcJoie 2 of Ji
ippeotfiees A • C|
2(9 19/04/00 tnttitl Isrtstigttici
(Mate 3 et 3:
Appendices 0 • I)
Rtpont/Stvtits 2
leporti/Stodies 3
KepoTti/Sttiiits ^
-------
10. J
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rmi
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2 D/I7/H
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letter re? lefoestia?
i leetiaf rite U.S.IM
lid IMF CO llf 22,1199
letter ret Proeresi
report ei i propouJ
tkit vjj] be lobiitted
to i.S.m lit IP««
tfirii; tfte Jitter pirt
et tie teet of JoJr J',
letter re> Ceoeero
tifTttttt it tie Sept.
(, 198* leetu; ret
tie pretence of irseiie
lerf ftstieitn it tbe
Sprie;fjeJtf f»p. Site
r.leniiiior-riidereer
(irzii
r-leriiiiiox-riifereer
Stint
T.l.leJioB-f.S.IFI CorreipoDdeoet
Comipoodeoee
Meruolior-riotfereer
Cirzii
I.CJirJric-ff.S.IPA Correipoodeoee
1CJ JO/02/M
2 !0/»/2f
( ff/05/14
2 9I/IS/25
I f0/H/0«
letter fcrnrdio? toe
lotice letter! that
rere tent to tKfs,
dited JIB. 23, 1*50,
titi copies of tie
receipt; for tbt
letters itticbed
letter re: SpriojfieJd
fomoip Site/FCB
CJeiiop lerejt
letter ret Joyemico*
for PCI CJeiDop, »iti
rei50oi listed nd
bickfroued uteriij
•id diicnijoo of PCI
letter ret leipoase
to tie Kir It, 1910
Jitter rejirdicj toe
appropnite fCt JereJ
for PCI coBtiiiiited
lOJJl
letter ret lespoose
to tie Hlf 25, 1990
Jitter ititio; tilt
Vipfirer.lideJiac t leer
I.Iirtia-t.S.IPA Correipoadesce 4
r.lenioiioi-Dictj'iioB,
fri^ot.Koofi.rifi losee,
i freeno
Irijot.etiJ.
I.CJiririe-P.S.IPA Correipoadeace 5
CorreipoBdeice
I.CJiirlzio-D.f.fPI
Correspoadejce
IB
MeriiBim*!>JctiiioB,
Iriett.looB, fit
i freeiio
I.CJiririo-I.S.IPA Correipeadeace 8
-------
«ff Io. 2
'1/11/90
•icumus tuts tin
wru
JpriiffieJd feraiDip
Steer Ja; Ceilittee
ill let lid tie
but tit tl ttrin ct
tie fS er prcpoied
tin for ti<
fcniiip
iMiiisriirm IICOID mil • nun
tniisniii roiisijf M» sin
MUSIIK, IJtlJCAI
ncinnr
mmit mi
tocmm
7 J0/M/JJ
letter re.- Spriaffjeld
5ite HAS!
«tiJ.
Cvrreipoadeoet
4 9C/H/2S
I $«/>{/?«
I Kftt/tt
20 15/16/02
letter re> I Jilt cf
peteatiiJ Stite IM*s
ideatified iptcitietllj
fcr tie SpriaifieJd frp.
Soperfoad iJte
letter re: CJirifieitica
of MM'i position re:
tee ipplicitiPB et tee
Art 307 loJei tc
reiediite
Spriaofield fowsaJp lite
AtteadiBce Saeet for
tbt Sept. I, 1*90
leetiBj for Spria;field
Site, IJ
i?esdi for leetia; vita
tltf Steenay Ceiiittee
SpriBy/ieJd ferasaip
Coip, rita MIC re:
•eetiaj iBtef for tie
Ju. 30. 1*)0 Metiagl
l.lirtie-O.S.IPJI Cerrespoodeice
DJeetor-fCM
CBrrespoodeore
I.Iirtio-o.S.IPJI
file
I.KirtJO-ff.S.IM
filt
leetia; lotes
leetiic lotes
3 N/15/10 leio re i leetiar,
I.Kirtie-O.S.rN
fjjf
leetiae letei
fersiiip Site, rito
iiit «f itteideei
attiebed
CIRCll Cetpliiare ritb
Oteer firiroDieatil
Sutotes (Coidiaee)
i.s.m
lejicfliJ
1-1
leierifidoi
15
-------
aye Io. 3
7/11/50
icii/nut ruts
rmi
mow urn - mm 13
sum/in* tonsut wit sin
, IKIISAI
iicimir
pocmir mi
I 17/05/15
1 11/05/24
77 IJ/03/01
1 J0/0I/20
23 17/01/02
ITeio rei PrelJiiaarr S.laff-ff.S. Dept. «f
litonJ Icioorce Sorr«f». Iittrier
n
Reio rei Fiodiliii
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iitttllti itllt
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itritirt tttcetts for
SfJcrtjcB of emu
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eaJJ rat ttitb
caJJj eoBcerfiiB; tot
iCBfdoJt /or proprstd
pjao tad iptrjiJ
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'folfeoJorieated
liptetfJi SpiJJ
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J.r.forter-P.S.m
I.ClaritJo-P.S.IU
IPA
LCoBitasteJei-0.S.I leiorafidoi
n
Spriagfield f»p tilt it tor to tut
idilos., leioraadui
M
file
leioraadui
Ocaer
17
241
ClSClt Cttflitect till
Ctoer iars 8aBoaJ-fra/t
(Coidioee)
C.5.IM/05HR Cir.
Otber
21
I l!/»/(0
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fjejd foiBtajp flip
fpdate
Septeiftr f
rjnaaact i
foJlOf-Bp i lev IllBfJ
leiaiader of Reio ii
redacted
I.Iirti8-P.5.IfA
FiJe
Otber
22
10 8I/0J/22 Drift (gidiaee OB
P.S.IM
Otaer
-------
ate lo.
1/11/30
iat/mu run IIR
J M/IJ/14
1 JI/I4/1J
192 «/«/«
IT 99/11/26
144 N/17/00
17 M/17/00
rmi
feJeetiBf Inttiti for
Siperfud Sitei titb
PCI Ceitjiiojtjca
WIOI
ircoie inn - mm «
ronsiip tw sin
Misms, IKIIMI
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CeertriitieB leeord ret
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it
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ttsittttitl
I.Iirtii-V.S.IPJ
l.lirtii-I.S.IPJ
C.CMft-OikiiBd Co. PBOBI Iteordi
C.Cieit-OitJiBd Co. Pfloflt leeordi
ttrtltftttt of
ter«Ji for PoJfcoJcr-
utrtf iJpifflfJs (tCtl
C It IBtp
listribstics of irstaic
lod ftsticitti
SpriB;fi(Jd frp. Site
SpriBffidd ftp., II
P.5.IPA-raiBiBctoB B.C./ PaeJje
f.S. Pept. ef CoBierce
laticciJ fecbaieaj
IsforiitioD SerrJce
fred C. fart JiioeJacef, SpriBjfieJd frp
IBC. Steer COB
(eport OB tb<
5todf of
tie SpriijfieJd
fetBjfiip Site
Oitlaid
CfiJcifO,!!
Propoied Piio for
fiBaj IfirdiaJ letice
SpriBffJtld fovaiBip
loip
liriitirf, licfliyaa
P.S.fPI/Ur*
25
teportf/Stodjes
leportt/Stodies 27
leporti/Stodies 26
Itporti/Stodies 2$
-------
•Pao* to.
J7/.N/JO
imt/mu nets cm
TIJLS
wnismriri mow JWH - mm n
roimit am sm
nmme,
mifinr
I 90/01/20
Kt»0 Tt: JtOt Of
Jttaspcntblt
Joeioeracor at
IJJOCDS
Sprisgtiti lip. Sitt
lilt
-------
fag; Ho. 1
19/16/98
ricBE/mu PAGES DAT!
ADHIHSTRATW RECORD IRDEI - DFDATE IS
SPRIPGPIELD rOIRSRIP DDKP SITE
DAVISEORG, KICBIGM
TITLI
AUTHOR
RECIPIE1T
DOCUKERT TIP!
DOCNl'H!!-F.
4 91/18/27
I H/I8/2S
2 H/IS/2S
M 91/18/31
2 9f/«W
II 88/12/19
Ittttr res Request for
Ull'i position OD tbe
reiaininq issues prior
to ISIPi laking a final
deteriitation OD tbt
llU't tbt Statt
Ktitifitd
Ittier foriardiog a
ecpy of tbt transcript
froi tbt Proposed Plan
Public Httting btld on,
Tatsdaf, Jo IT 24, 19?6
as ptr request
Lttttr rt: DSEFA hs
eeipleted its revi«w
of the Act 3C7 Rules
tbat (HUP. identified
is MA? for the
Springfield Tovnsbip
Site
leto {warding
Calcolitioa? for
Cleaoap Levels
Itio re: Springfield
loiufbip Site
la? 39, \m Cleanup
Ltrels Docoient
Italtb ls;essient for
Springfield Tovnsbip
Dnp Sitt
Oakland Coontr.Nicbigan
J.Dikiois-OSEPA
R.MartiD-OSEPA
J.Oikinis-OSEPA
LBradford-KDRP. Correspondence
K.LeniDiaui-Vrigbt, Correspondence
etal.
K.Bradford-NDRR Corresponienc*
K.Kartin-USEFA & HDSR Official File Mcionnd'ji
K.Hartio-UFEPA
Official File Neiorandut
ATSDR-U.S. Pnblie
Health Sttrice
Reports/Studies 6
(S M/IB/B9
Transcript of Public
Btetiag, btld en
TlCldaT, JQl? 24. 195?
at Springfield Toinsbip
Ball IB Divisburg.KI
I.Turner-leporttr
Transcript
-------
Date
5/1/89
9/10/90
9/13/90
9/14/90
9/6/90
8/30/90
9/27/90
9/28/90
8/14/90
9/13/90
8/29/90
9/13/90
Title
Final Guidance on
Administrative Records
for Selection of CERCLA
Response Actions.
Letter requesting extension
of public comment period.
Letter regarding
comments on the draft ROD
(confidential portion of
Administrative Record).
Letter responding to
select ARAR issues.
Letter responding to
Act 307 as an ARAR.
(confidential portion of
Administrative Record)
Letter responding to
Act 307 as an ARAR.
Letter regarding appli-
cation of ARARs to certain
alternatives.
Memo regarding application
of certain ARARs to the
Springfield site.
Letter regarding FS and
Proposed Plan.
Letter, with attachments,
regarding comments on the
FS and Proposed Plan.
Letter regarding Act 307.
Letter regarding public
comment period extension.
Author
U.S. EPA
Keith J. Lerminiaux
Robin L. Campbell
William F. Bradford
Jeremy M. Firestone
William F. Bradford
Claudia Kerbawy
David A. Ullrich
Keith J. Lerminiaux
Keith J. Lerminiaux
Jonas Dikinis
Richard J. Clarizio
-------
9/10/90
9/5/90
8/31/90
8/27/90
7/20/90
8/15/90
8/7/80
2/13/84
Letter regarding trans-
mission of information.
Nemo transmitting clean-
up information to the
Administrative Record.
Letter transmitting
information to Keith
J. Lerminiaux
Letter regarding select
ARAR issues.
Letter regarding extension
of public comment period.
Guidance on Remedial Actions
for Superfund Sites with
PCS contamination.
Notification of Hazardous
Waste Activity
Notification of Hazardous
Waste Activity.
Marilou Martin
Marilou Martin
Marilou Marting
Jonas Dikinis
Richard J. Clarizio
Henry L. Longest II
J.V. Burke
P. Dugan
-------
APPENDIX A
LIST OF COMMENTORS DURING THE PUBLIC COMMENT PERIOD
FOR THE SPRINGFIELD TOWNSHIP SITE
FROM JULY 13 THROUGH SEPTEMBER 12, 1990
COMMENTS RECEIVED DURING THE PUBLIC MEETING ON JULY 24. 1990.
NAME AND AFFILIATION
Mr. John Lowell, Resident
Mr. Martz. Resident
Mr. Keith Lerminiaux, Springfield Township Steering Committee
Mr. Bernard Dooley, Resident
Mr. Dan Caplice, Geraghty & Miller
Mr. Chris Moore, Resident
Mr. Don Balkwell, Resident
Mr. Joe Gorka, Resident
Mr. Collin Walls, Resident
Ms. LeeAnn Oliver, Resident
Mr. Noel Maxim, Resident
COMMENTS SUBMITTED BY THE PUBLIC DURING THE PUBLIC COMMENT
PERIOD.
NAME AND AFFILIATION
/
',
Mr. J. Calvin Walter, Clerk, Charter Township of Springfield.
Mr. Keith L. Krinn, R.S., M.A., Environmental Health Supervisor,
Environmental Health Services, Dept. of
Institutional and Human Services, Oakland
County, Michigan.
Mr. & Mrs. Harold Robinson, Residents.
Ms. Mary E. Duncan, Resident.
COMMENTS PREPARED BY THE POTENTIALLY RESPONSIBLE PARTIES (PRPs)
AND THEIR CONSULTANTS.
Springfield Township Site Steering Committee,
Letter signed by Keith J. Lerminiaux,
on behalf of the Committee.
Geraghty & Miller, Inc. Environmental Services.
Comments Relative to the Remedial Investigation, Feasibility
Study, and Proposed Plan for the Springfield Township Superfund
Site Springfield Township, Michigan.
-------
Geraghty & Miller, Inc. Environmental Services & Gradient
Corporation.
Technical Review Document and Proposal of Remedial Alternative
for the Springfield Township Site.
-------
RECORD OF DECISION
Remedial Alternative Selection
Site Name and Location
The Springfield Township Dump site is approximately a 400 by 500
foot fenced area located on an approximately 16 acre parcel of
land, south of Davisburg in Oakland County, Michigan.
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Springfield Township Dump site in Oakland County, Michigan,
which was chosen in accordance with CERCIA, as amended by SARA,
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision is
based on the administrative record for this site. The index to
the administrative record is attached to the Record of Decision
(ROD).
The State of Michigan has concurred with the selected remedy.
Assessment of the Site ,;
•?
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of Selected Remedy
The selected remedy addresses the principal threats posed by the
site, and is the final remedy for the site. The major components
of the selected remedy are:
*Excavation and thermal destruction of soils to remove to
specified cleanup levels polychlorinated biphenyls (PCBs),
volatile organic compounds (VOCs), semi-volatile organic
compounds (SVOCs), and pesticides in the source area;
*Solidification of incinerator ash according to ARARs;
*Solidification of soils contaminated only with metals;
*Redeposition of ash and treated soil on-site (the ash will
either be stabilized to make it inert prior to its on-site
disposal or will be placed in a properly designed solid
we.ste unit on-site) ;
-------
*Recontouring of the excavated areas and control of the ash
or dust emissions;
installation of an in-situ vacuum extraction system to
remove VOCs and SVOCs from remaining unsaturated
contaminated soils at depth; and
installation and operation of a ground water extraction and
treatment system which utilizes a carbon adsorption unit to
treat the groundwater before reinjection into the aquifer.
A detailed discussion of each of the components of the selected
remedy is presented in Section 9 of the ROD and in both the
Feasibility Study and Proposed Plan developed for the site.
Statutory Determinations
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility/ or volume as a principal element and utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
Because this remedy will not result in hazardous substances
remaining on-site above health-based levels, the five-year
facility review will not apply to this action once the cleanup
performance standards are achieved.
2 9 SEP 1990 t*l orieinal signed ty
Valdas V. Adaiakus
Date Valdas V. Adamkus
Regional Administrator
-------
SSXTES BWIROMENIAL HOTECTIGN A2MCY
FHUCN V
SEP 2 8 1990
Itaqnrrt for concurrence en the Record of Decision for the
Springfield Township Site located in Davisburg, Michigan.
David A. Ullrich, Acting Director Bertram C. Frey
Haste Management Division Acting Regional Counsel
TO: Valdas V. Adamkus
Regional Administrator
By this memorandum we are recommending that you authorize the
Pamela! Action for the Springfield Township Site by executing the
attached Record of Decision (ROD). The site is located in
Davisburg, Michigan.
The ROD was prepared in accordance with the Comprehensive
Budronmental Response, Compensation, and Liability Act (CZRdA),
42 U.S.C. §9601 et seq.. and the National Contingency Plan, 40 CFR
Part 300, and is consistent with Agency CFRCIA policies. We have
reviewed the documents attached and have concluded that the ROD
is both legally and technically sufficient. As such, we believe
that the implementation of the remedial measures as stated within
the ROD, is proper exercise of your delegated authority.
Please feel free to contact either of us should you have any
Questions.
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