United States        Office of
          Environmental Protection   Emergency and
          Agency           Remedial Response
EPA/ROD/R05-93/243
September 1993
SEPA    Superfund
          Record of Decision:
          Ott/Story/Cordova Chemical,
          Ml

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50272-101
  REPORT DOCUMENTATION
          PAGE
1. REPORT NO.
EPA/ROD/R05-93/243
3. Recipient's Accession No.
   Title and Subtitle
   SUPERFUND RECORD OF ^DECISION
   Ott/Story/Cordova Chemical,  MI
   Third Remedial  Action - Final
                                          5.  Report Date
                                          	09/27/93
                                          6.
7.  Authors)
                                          8.  Performing Organization Rept. No.
9.   Performing Organization Name and Address
                                          10  Project Taskwork Unit No.
                                                                     11.  Contract(C) or Grant(G) No.

                                                                     (C)

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

                                             800/800
                                          14.
15. Supplementary Notes
                   PB94-964108
16.  Abstract (Limit: 200 words)

  The 20-acre Ott/Story/Cordova site  is an inactive  chemical production facility  located
  in North Muskegon, Michigan.  Land  use in the area is predominantly residential,  with
  woodlands  surrounding  the facility.    In addition  to three onsite  residential areas,
  houses and a mobile home park are located to the west and northwest of the site,
  respectively.   One half-mile east of the former production areas,  Little Bear Creek and
  an unnamed tributary of the creek flow south into  Bear Creek, which empties into  Bear
  Lake.  From 1957 to 1985, various sets of parent corporations, divisions, and
  subsidiaries used the  site to manufacture pharmaceutical intermediates,  veterinary
  medicines,  agricultural chemicals,  herbicides, dye stuffs, and other products.  For a
  significant portion of the site's operating history,  waste by-products from the
  chemical manufacturing processes were placed in unlined lagoons  or stored in drums
  onsite.  By 1959, issues with onsite ground water  contamination  were noted due  to
  improper storage and handling procedures.  An onsite water supply  well became
  contaminated by the spread of chemicals that had entered the aquifer after seepage from
  the lagoons.  In the mid-1960s, untreated ground water and process flows were directed
  to the Little  Bear Creek for discharge.  In the late 1960s, an incinerator was
  installed  onsite to treat more concentrated waste; however during  the considerable

  (See Attached  Page)
17. Document Analysis    a. Descriptors
   Record of Decision - Ott/Story/Cordova Chemical, MI
   Third Remedial Action - Final
   Contaminated Media: Soil,  sediment
   Key Contaminants:  VOCs (PCE,  TCE, toluene,  xylenes),

   b.  Identifiers/Open-Ended Terms
   c.  COSATI Reid/Group
                                  other organics  (PCBs, pesticides)
18. Availability Statement
                          19.  Security Class (This Report)
                                    None
                                                     20.  Security Class (This Page)
                                                               None
          21.  No. of Pages
                  52
                                                                              22.  Prica
(See ANSI-Z39.18)
                                   See Instructions on Reverse
                                                   OPTIONAL FORM 272 (4-77)
                                                        y NTIS-35)
                                                        ent of Commerce
                                                                              ^r^ • i^m**iB i ^nim ebl
                                                                              (Formerly NTIS-35)
                                                                              Departmen	

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EPA/ROD/RO5-93/243
Ott/Story/Cordova Chemical, MI
Third Remedial Action - Final

Abstract (Continued)

downtime for incinerator operations, the waste was stored in drums. As the drums
accumulated onsite, open lands were used for waste and drum disposal.  Beginning in 1973
or 1974, the plant extended its effluent pipe line to the Muskegon County POTW.  By the
mid-1970s contamination of offsite residential wells downgradient of the plant was noted.
In 1977, the State negotiated with a new site owner to remove several thousand drums and
thousands of cubic yards of lagoon sludge, and to destroy or neutralize phosgene gas left
onsite.  By 1982, an alternate water supply was installed in the site vicinity as a
settlement of a citizens' suit against a number of former site owners.  A 1989 ROD
addressed the interception and treatment of contaminated ground water before its entry
into the creek system, as OU1.  A 1990 ROD addressed the capture and treatment of all
known contaminated ground water below and downgradient of the site, as OU2.  This ROD
addresses the residual areas of contaminated soil and sediment at the site, as OU3.  The
primary contaminants of concern affecting the soil and sediment are VOCs, including PCE,
TCE,  toluene, and xylenes; and other organics, including PCBs and pesticides.

The selected remedial action for this site includes excavating and treating contaminated
soil and sediment onsite using low temperature thermal desorption; backfilling the
excavated areas with the treated soil that meets cleanup levels; disposing of treated soil
above cleanup levels offsite; and monitoring ground water.  The estimated present worth
cost for this remedial action is $6,808,254, which includes an estimated annual O&M cost
of $154,000.

PERFORMANCE STANDARDS OR GOALS:

Chemical-specific soil cleanup goals are based on health-risk criteria, and include PCB
1,000 mg/kg; butyl benzyl phthalate 22,000 mg/kg; chlorobenzene 2,600 mg/kg; 1,2-DCA 8
mg/kg; 4,4-DDT 2 mg/kg; 1,2-dichlorobenzene 30 mg/kg; dieldrin 0.04 mg/kg; ethyl benzene
1,500 mg/kg; endosulfan sulfate 3.3 mg/kg; hexachlorobenzene 0.4 mg/kg; methylene chloride
92 mg/kg; methoxychlor 700 mg/kg; PCE 14 mg/kg; 1,1,1-TCA 4,000 mg/kg; 1,1,2-TCA 13 mg/kg;
1,1,2,2-TCA 14 mg/kg; TCE 44 mg/kg; 1,2,4-trichlorobenzene 2,200 mg/kg; toluene 16,000
mg/kg; and xylenes 5,600 mg/kg.

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                        Table  of  Contents
                        Record of Decision
                       Operable Unit Three
                      Ott/Story/Cordova Site

                                   Page(s)
Site Location                      1
Site History and Enforcement       1-5
Community Participation            6-7
Scope/Role of Operable Units       7-9
Site Characteristics               9-14
Site Risks                         14-22
Alternatives Description           22-27
Evaluation criteria                27-28
Comparative Analysis               28-36
  -ARARs Discussion                29-33
Significant Changes                36-39
Selected Remedy                    39
Statutory Determinations           40-41
Figures:                           Following Page

-Vicinity Maps                     1
-Sampling Locations                8
-Areas Proposed to Undergo         20
 Remediation
-Cross-section of Act 641          22
 Landfill
-Cross-section of Act 64           22
 Landfill
-Depiction of Low Temperature      25
 Thermal Desorption Treatment
 Unit

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   RECORD OF DECISION

      ROD SUMMARY
 OTT/STORY/CORDOVA SITE
NORTH MUSKEGON,  MICHIGAN

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              DECLARATION FOR THE RECORD OF DECISION

 Site Name and Location

 ott/Story/Cordova site
 North Muskegon,  Michigan

 Statement of  Basis and Purpose

 This decision document presents the selected remedial  action for
 the ott /Story /Cordova  site, in North Muskegon, Michigan, which was
 chosen in accordance  with  the  requirements of the  Comprehensive
 Environmental Response, Compensation, and  Liability Act  of  1980
 (CERCLA),  as  amended by the Superfund  Amendments  and
 Reauthorization Act  of 1986 (SARA)  and, to the extent practicable,
 the National  Oil  and  Hazardous Substances Pollution Contingency
 Plan (NCP).   This decision is based on information  and documents
 contained in  the  administrative record for  this site.

 The State of  Michigan  concurs 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  Record  of Decision  (ROD),  may  present  an   imminent  and
 substantial threat to  public health, welfare, or  the  environment.

 Description of the Selected Remedy

 This remedy is the third of three operable units  selected for the
 Ott/Story/Cordova  site  and   consists  of   a   remedy   for   the
 contaminated  soils  and  sediments.    The  remedy  is  viewed as
 consistent with the  previous two remedies selected for  this site.
 The primary  goals  of  this  selected remedial   action  at   the
 Ott/Story/Cordova site are to reduce infiltration into contaminated
 soils  which may add  to the burden of groundwater  contamination to
 be  dealt with by Operable  Units  One  and  Two and to reduce  the
 health and environmental risks  associated with exposure to  such
 contaminated materials.

 The Ott/Story/Cordova  Operable  Unit Three  field  work,  which  was
 conducted in 1992, supplements the Remedial Investigation of 1988-
 1989.   The major components  of the selected remedy consist of
 excavation  of contaminated  soils/sediments,  treatment  of   such
materials  utilizing the technique  of low temperature thermal
desorption, on-site backfilling  of  those  treated   soils which
 successfully attain pertinent soil cleanup criteria,   and  off-site
disposal  of that  portion  of  treated  soils  which do not attain
cleanup criteria.  Emissions created from contaminants driven  off
the  soils by  this  treatment technique  would  be controlled as
necessary through utilization of such techniques as flaring of
vapors  thus  generated,  routing  such   vapors   through  carbon
adsorbants, and/or collection and subsequent treatment of vapor

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 condensate.   Monitoring  will  be necessary to ensure that  cleanup
 criteria are  attained.

 Declaration of Statutory Determinations

 The  selected  remedy  is  protective  of   human  health  and  the
 environment, and is cost effective.   The selected alternative will
 comply with all Applicable or Relevant and Appropriate Requirements
 (ARARs).    The  remedy  utilizes  permanent  solutions  treatment
 technologies to the maximum extent practicable.  There may  be some
 contaminated  sediments left  on or  near   the  Little Bear Creek
 portion  of the  site;  future monitoring  will  determine  if such
 sediments require remediation after the construction of extraction
 wells and  treatment facilities designed  to  serve the  goals and
 objectives of Operable Units One and Two.

 As required by SARA, when hazardous substances are left on  site, a
 review will be conducted within five years after commencement of
 remedial action  to ensure  that the  remedies continue  to provide
 adequate protection of human health and the environment.
                                                    f27/?3
Valdas. V. Adamkus, Regional Administrator          Date
U.S. Environmental Protection Agency,  Region V

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   DECISION  SUMMARY FOR THE RECORD OF DECISION

 1.  SITE NAME.  LOCATION.  AND DESCRIPTION

 The ott/Story/Cordova  Superfund site consists in part of a former
 chemical production site located at the end of Agard Road in Dalton
 Township, Michigan, five miles north of the city of Muskegon.   The
 former  production area is approximately 20 acres  in  size,  and is
 surrounded  by  wooded land.   Houses are located to the west of the
 site along Whitehall Road, and a mobile home park is located about
 a quarter of a mile northwest of the facility.   Residential areas
 are also located in close proximity to the former production areas
 along Central, River,  and  Russell Roads.  These residential areas
 are considered as  part of  the facility.   About one-half  mile  east
 of  the  former  production areas, Little Bear Creek and an unnamed
 tributary of the creek flow south, joining near River Road, to the
 southeast.  Little Bear Creek flows into Bear Creek,  which empties
 into Bear Lake.  Bear Lake eventually flows into Muskegon Lake,  and
 then into Lake Michigan. See the diagram denoted as "Vicinity  Map"
 for an  approximate depiction of  site  setting.

 2.  SITE HISTORY AND ENFORCEMENT  ACTIVITIES

 Since the 1950s,  various sets of parent corporations, divisions,
 and subsidiaries have owned and/or operated chemical plants on the
 site.   The  names of the previous and present owners most  likely
 familiar to the  public are  ott  Chemical Company, Story  Chemical
 Company, and Cordova Chemical Company.  The chemical plants used
 various raw materials to manufacture pharmaceutical intermediates,
 veterinary   medicines,   agricultural   chemicals,   herbicides,
 dyestuffs,  and other products.   For a significant portion  of  the
 site's  operating  history,  waste  by-products from  the  chemical
 manufacturing processes were placed in unlined lagoons or stored in
 drums on the property.

 As  early as 1959,  groundwater problems began  to be noted at  the
 site.   At that time,  an on-site  water supply well  used by  Ott
 Chemical became fouled, due  in part to the spread of contaminants
 that had entered the aquifer after seepage from the lagoons.   The
 act  of  seeking new water supplies,  and abandoning former  supply
wells was  repeated by site  operators  several  times  during   the
 site's history.

Later, in response to State of Michigan concerns,  efforts  were made
by  the  site   owners   to  slow   the  spread  of  the  groundwater
contaminant plume.  By  the  mid 1960s,  a program of purging certain
portions of the aquifer was begun, and by 1968 an effort was made
to  segregate particularly  high-strength organic  waste from more
dilute process and cooling flows.

Lagoon  utilization  for lower strength process  and cooling flows
continued for  a time.   Plant documentation  indicates that due to
spills  and  other mishaps,  the  conceived  plan  of  only  less-
concentrated waters reaching the  lagoons did not always occur.   By

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 the 1970s, lagoon usage on a day-to-day basis began to give way to
 usage  for cooling  water only, as  measures to  help protect  the
 integrity of water  supply wells needed for  facility operation.

 Neutralization  and  flow equalization basins were  installed about
 1968-69.  The purpose of the latter devices appears to have been
 for primary treatment of process wastewater flows  routed thereto.
 Certain plant wastewaters were highly acidic or basic; hence  the
 role of the neutralization basin.

 In the mid-1960s,  untreated groundwaters and  process flows were
 directed to  Little  Bear Creek for  discharge.   Correspondence  by
 representatives  of  the  Michigan  Water Resources  Commission  and
 later the Michigan Department of Natural Resources (MDNR) expressed
 concern as to the effectiveness of such efforts.  Several instances
 of exceedances of allowable  discharge limitations to the receiving
 stream as established by the State of Michigan occurred from time
 to time.  Citizen complaints and concerns  of the  State of Michigan
 resulted in the  construction of a  pipeline  in the later 1960s  to
 reroute wastewaters to the Muskegon River.   At that time, analysis
 of the wastewaters centered on conventional  parameters  such  as
 solids, pH,  phenol  content, and BOD/COD.   In an  effort  to help
 gauge  possible  biological  effects,  fish taint  tests were  also
 conducted from  the  mid to  late 1960s to the  early 1970s.   This
 consisted of a  panel of plant personnel  comparing the flavor  of
 control trout to those exposed to the plant effluent.   By about
 1973 or  1974,  the plant extended  the pipe  line to the Muskegon
 county  Publicly Operated  Treatment  Works  (POTW).   Production
 wastewater discharges from the site  to  the  POTW  via the pipeline
 continued until 1985.   (It may be of interest to the reader to note
 that in recent years,  and reinforced by a 1992 vote of the County
 Public Works Board,  Muskegon County has adopted a strict policy  of
 refraining  from  accepting;   a  discharge  which  originated  from
 contaminated groundwater within the County.)

 In an effort to reduce the volume of wastes accumulating on site,
 an incinerator was installed  on the site by the  late 1960s to treat
more concentrated industrial wastes.  Plant documentation indicates
 that this unit experienced considerable downtime, plus there were
 instances when this and  other  plant equipment actually exploded.
During such downtimes,  wastes  were stored  in drums.   While some
 effort was made  to  reduce  this backlog, the net effect was  that
drums of waste accumulated on site in the 1970s.  Testimony of past
plant operators  indicated that some open land areas of the site
were used for waste and drum disposal.

By 1977,  with the  then present site  owner (Story  Chemical)   in
bankruptcy,   a   removal action  was  undertaken  by  the Michigan
Department of Natural Resources (MDNR) and  financed in part  by a
new site  owner.   Several thousand  drums  and thousands of cubic
yards of lagoon  sludges were removed and disposed  of from the site.
 It appears that  even though lagoon usage as a day  to day measure of

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 handling plant: process flows declined over time, the sludges in the
 lagoons were not  removed until  several  years later.

 During the site's history,  various  information and documents were
 filed  with  federal  and  state governments.    Briefly,  and  in
 approximate chronological order, these  are:

       Information generated by Ott Chemical regarding  Michigan
       Orders of  Determination  concerning groundwater  and  lagoon
       usage (approximately 1965-1966).

       Information generated by Ott and Story Chemical  concerning
       effluent  content  to .waters  of  the  State  of  Michigan
       (approximately 1967-1973).

       Information generated by Ott Chemical and submitted  to the
       Corps of Engineers regarding the River and  Harbors Act,  (a
       forerunner  of the National Pollutant  Discharge Elimination
       System)  (approximately 1971).

       Filing for generator status and treatment /storage permits by
       Cordova Chemical of Michigan under the Resource Conservation
       and Recovery Act  (approximately  1980).

       Filing by Cordova Chemical for various Michigan air permits
       (early 1980s).

By at least the mid 1970s,  contamination of off-site residential
wells downgradient  of the plant  was noted.  For a time,  the county
and state helped to assist local residents by providing a supply of
bottled  water,  and  through   increased  monitoring  efforts   of
potentially affected wells.

In 1981,  the MDNR referred the  Ott/Story/Cordova site to  U.S.  EPA
for inclusion in the newly established Superfund program.  In 1982,
the site was placed on the National Priorities List (NPL) .  Also in
1982, an alternate water  supply was installed in the vicinity  of
the site as settlement of a citizens' suit against some former site
owners, and financed in  part by  a former site owner, and  in part by
the State of  Michigan.

Distinct  sets of  site owner /operators  have  been  involved in the
site during its history.  The Ott Chemical Company began operations
at the site in the 1950s as  an independent company.  In  1965, Corn
Products  Company,  now CPC International, Inc.,  purchased all stock
of Ott Chemical.   In 1972, CPC sold assets that comprised the Ott
Chemical  operations to  Story Chemical.   In late 1976-early 1977,
Story Chemical initiated bankruptcy proceedings.   In late 1977-
early 1978, Cordova Chemical Company of Michigan purchased  the site
after entering  into an agreement with the State of Michigan.  The
agreement called for Cordova to  destroy  or neutralize phosgene gas
left at the site,  and to finance in part the State's action to

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 remove drums of waste and lagoon sludges.  U.S. EPA was not a party
 to the agreement.

 In 1985,  U.S.  EPA sent a notice letter to Cordova and  CPC,  which
 advised them of their potential liability under CERCLA for cleanup
 of the site.  The  letter offered them an  opportunity to conduct a
 site  Remedial  Investigation/Feasibility Study (RI/FS).   Both  CPC
 and Cordova declined this offer, and U.S. EPA  conducted an RI/FS.
 In March  1989,  U.S.  EPA sent  demand letters for cost recovery to
 CPC  and  Cordova.   In May  1989,  U.S.  EPA  also informed  Cordova
 Chemical  Company of California  (Cordova  CAL),  parent company of
 Cordova-Mi,  Aerojet-General   (parent  company   of   Cordova   of
 California)  and  Swanton-Story Corporation  (successor  of  Story
 Chemical) of their potential  liability  with regards to  this site
 and sent demand  letters to these firms.

 In August 1989,  pursuant  to  a  Section  122(a)  letter,  Aerojet-
 General, Cordova CAL, Cordova-MI,  and CPC  International  were given
 notice that U.S. EPA had determined that  a period of negotiations
 would not facilitate an agreement  for  remedial design and  action
 for Operable Unit One.   The  availability of  the Proposed  Plan/
 Focused Feasibility Study,  and notice  of the start  of a public
 comment period were also stated in the letter.

 Litigation  among  the  various  private  parties,  the   State   of
 Michigan, and U.S.  EPA  began  in the summer  and fall of  1989 with
 the-filing in federal district court of various suits concerning
 claims for reimbursement and allegations of liability for actions
 taken and  environmental conditions at  the  site.   Following  the
 discovery phase of the litigation,  a trial concerning the issue of
 liability of the PRPs and the State of  Michigan commenced in  the
 U.S.  District Court in Grand Rapids, Michigan.  Although U.S.  EPA
 had not named the MDNR or the  State of Michigan as a PRP, Aerojet-
 General and CPC  asked the Court  to declare  Michigan as liable  on
 the theory of having arranged for disposal  of hazardous substances.
 Prior to  the commencement of  trial, the  U.S. EPA had  reached a
 tentative  settlement agreement  with  Dr.  Arnold Ott   for past
 response costs.   A Consent Decree memorializing such settlement has
 been entered by the Court,  and the terms of this Decree have been
met.   Trial  was conducted from early May to the middle of June
 1991.  A  verdict was reached concerning  liability on August  27,
 1991.  The Court found Aerojet-General  Corporation and Cordova-Mi
 liable  for  response   costs   under CERCLA  section  107(a)(1).
Additionally, the Court found these persons, plus CPC International
 Inc., and Cordova CAL liable under  CERCLA  section 107(a) (2).  MDNR
was found not liable under any part of  CERCLA section 107.

CPC,   Aerojet  and  the  U.S.  Government,  after  the  findings   of
 liability, entered into  a stipulated settlement over the amount  of .
federal response costs owed through June 1990,  subject to an appeal
of liability.   On  September 10,  1992 the  Court entered judgement
 for this  amount and also entered a declaratory judgement that the

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 Aerojet defendants and CPC  are  liable for future  response costs
 incurred by the  government.   Aerojet and  CPC have  appealed the
 district Court's  judgement to  the  Sixth  circuit Court of Appeals.
 Briefs have now been  filed with  the Court of  Appeals.

 U.S.  EPA also notes that litigation is currently proceeding in the
 state courts of Michigan between  Aerojet and the State of Michigan.
 A  lower court has found that Michigan breached the afore-mentioned
 contract.    This  decision  is  being  appealed  by  the  State  of
 Michigan.

 U.S.  EPA began field  work for the Remedial Investigation  (RI)  in
 January  1988.    The   report discussing  this  investigation  was
 completed  in  April  1989,  supplemented  in  1990,  with  further
 information on site soils/sediments becoming available in 1992. In
 August 1989, U.S. EPA initiated a public  comment period concerning
 the  Proposed Plan for the first operable unit, which dealt  with
 preventing  further groundwater contamination  from entering Little
 Bear   Creek.    Upon  consideration of  comments  made,  U.S.   EPA
 developed a Record of Decision  for  the first  operable unit  in
 September 1989.   U.S.  EPA  reopened the public comment period  from
 November to December 1989,  and based  upon  review  of comments
 received affirmed its  initial decision in March 1990.  In May 1990,
 U.S.  EPA obligated federal dollars  to initiate the Remedial Design
 for the first operable unit.

 The  Feasibility Study (FS)  for  the site was completed in early
 summer 1990.  In July  1990, U.S.  EPA began a public  comment period
 for  a  second operable unit  for the site,  which considered  the
 matter of aquifer restoration.   In response to a  request from one
 party,  U.S.  EPA extended  the comment period into September 1990.
 After evaluation  of  public  comment and  response to  significant
 comment, U.S. EPA selected a remedy which, through  extraction and
 treatment of contaminated groundwater, would be designed to  restore
 the contaminated aquifer.  In October 1990, PRPs were  informed by
 U.S.  EPA that  the Agency  could  not make a determination  that a
 period of negotiation would facilitate  settlement  between those
 persons and the  Agency,  but  that U.S.   EPA  would consider   PRP
 response which might  allow the making of such determination.   No
 responses  were received   which  caused  U.S.   EPA  to make  such
 determination.  In the first quarter of  calendar year 1991,  U.S.
 EPA obligated  funds for remedial  design of  the second operable
 unit.  In 1992,  U.S. EPA and  MDNR obligated remedial action funds,
 and  in  March  1993  the U.S.  Army  Corps  of  Engineers  solicited
 construction bids.  Bids were opened in July 1993,  and a contract
 awarded in September 1993.

 During  the RI,  U.S. EPA found elevated levels of numerous organic
 compounds in soils and groundwater at and  downgradient of  the site.
As noted previously, U.S. EPA has  developed two Records of Decision
 (ROD)   for  the   site  which  deal  with  halting  surface-water
 contamination at the site, and with groundwater restoration

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 efforts,  respectively.

 3.      HIGHLIGHTS  OF COMMUNITY PARTICIPATION

 An  RI/FS  "kickoff" availability session  was held near the site in
 November  1987.  Upon completion of the RI in April 1989, a copy of
 the RI  report was  made  available to the  public at the information
 repositories maintained at the Oalton Township Public Hall and the
 Walker  Memorial Library in North Muskegon.  The RI was also made a
 part of the administrative record file maintained in Region 5 and
 at  the  local repository at the Walker Memorial Library.  A Proposed
 Plan and  Focused  Feasibility Study for  operable Unit  one,  which
 dealt with  the contamination of Little Bear creek and its unnamed
 tributary,  were released to  the  public  on  August  i,  1989  to
 initiate a public comment period for the proposed action.  A public
 meeting was held  in August 1989.  U.S.  EPA extended  the comment
 period  into September 1989.  Upon consideration of  comments made,
 U.S.  EPA developed a ROD  for the first operable unit in September
 1989.  U.S.  EPA reopened the public comment period from November to
 December 1989, and based upon review of comments received affirmed
 its initial decision in March 1990.

 The Feasibility Study (FS) and Proposed Plan for Operable Unit Two
 were made  available  to the public  in  July  1990.    A notice  of
 availability was published in  the  Muskeaon Chronicle on  July 24,
 1990 to initiate a public comment period on the alternatives from
 July 2.5,  1990 to August 23,  1990.   In addition, a public meeting
 was held on August 16,  1990 in Muskegon County.   In  response to a
 request for extension,  U.S.  EPA  subsequently extended the  public
 comment period to  September 24, 1990.   After evaluation  of  public
 comment and response to significant comment, U.S. EPA selected a
 remedy  which, through  extraction  and treatment of  contaminated
 groundwater,  is designed to restore the contaminated aquifer.

 In  December 1991,  U.S. EPA conducted an informal public meeting at
 the Dalton  Township Hall to discuss with interested  citizens  what
 appeared at that time  to be  the leading  treatment concepts  for
 contaminated groundwater in the remedial design, and the objectives
 of  sampling envisioned  for the third operable unit.   MDNR  also
 participated, and  discussed design questions  and  explained  the
 goals and objectives of pump testing proposed by private parties.

 On  April 5,  1993,  U.S.  EPA released a supplement to the FS and a
 Proposed Plan for Operable Unit Three to the public.  A notice of
 the  availability of these documents  was placed  in  the Muskeaon
 Chronicle on March 31, 1993 to initiate a public comment period on
 the alternatives from April 5, 1993 to May 4,  1993.   In addition,
 a public meeting was held on April 20,  1993  in Dalton Township,
Muskegon County.   At this meeting, representatives from U.S. EPA
 and the MDNR answered questions concerning site conditions and

-------
 remedial alternatives under consideration.  A  court reporter was
 present to  record oral  comments.   Written comments were  also
 solicited  at the  hearing.   The  public  was reminded  that  anyone
 desiring additional information about the Superfund process or the
 activities to be  conducted  by U.S.  EPA at the ott/ Story /Cordova
 site can review the documents that have been prepared for the site.
 The location of such documents was noted.  In response to a request
 for extension,  U.S. EPA subsequently extended  the  public comment
 period to June  3, 1993.    In response to  a  further  request  for
 extension  of the public comment period received by U.S. EPA on May
 27,  1993,  U.S. EPA subsequently extended the public comment period
 to  July 6,  1993.

 A response to the comments received during this  period is included
 in  the Responsiveness Summary, which is part of this ROD.   This
 decision  document presents  the  selected  remedial  action  for
 Operable  Unit  Three  for  the Ott/Story/Cordova  Site  in  North
 Muskegon, Michigan, chosen in accordance with CERCLA, as amended by
 SARA,  and to the extent practicable,  the  National Contingency Plan
 (NCP).   The decision  for  this  site is based on  the  administrative
 record.

 4.      SCOPE AND ROLE OF OPERABLE  UNIT

 As with many Superfund sites, the problems at the Ott /Story /Cordova
 site are complex.   Consequently,  U.S.  EPA organized the  remedial
 work into  three planned  operable units at  the site.   This  ROD
 addresses  the third operable unit  planned for the site.

 As  noted within the  NCP,  total site remediation  is the desired
 objective.  However, as the NCP states, often it is  necessary  and
 appropriate,  particularly  when  dealing with  complex  sites,  to
 divide the site into remedial categories  for effective management.
 The  RI  developed  for the  Ott /Story /Cordova  site  indicated  the
 presence of a wide variety of hazardous substances in groundwater,
 surface  water, soils, and sediments.  Therefore, U.S.  EPA divided
 the  site into three operable units (OU) as follows:

   OU One:  Considers surface water degradation of Little Bear
            Creek due to the influx of a portion of the
            contaminated groundwater caused by past disposal
            practices at the site.

   OU Two:  Considers site groundwater and aquifer quality
            restoration.

   OU Three: Considers whether certain areas of site surface and
             near surface soils and sediments should undergo
             remediation.

U.S. EPA has  already  selected the cleanup remedy for  OU One  and
Two. Entry of contaminated groundwater into the  Little  Bear  Creek

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                                 8

 system constituted a threat at the site because of  the  resultant
 degradation of a portion of the creek system.  Therefore,  OU One
 seeks  to intercept contaminated groundwater before  it enters the
 creek  system,  and to provide treatment for waters thus collected.

 The  capture and treatment  of  all  known contaminated groundwater
 below  and downgradient of the site, and the matter of attempting to
 attain  pertinent   federal  and   state   regulations  concerning
 groundwater were addressed  by OU Two.

 OU  Three will  address  residual areas of  contaminated  soils  and
 sediments at the site.  U.S. EPA believes, in keeping with the NCP,
 that the selection and  execution of a remedy for OU  Three will be
 neither inconsistent with nor preclude the  implementation of other
 remedies selected  for the site.

 In this third  and final planned operable unit for the site,  U.S.
 EPA  considers  the  matter  of  contaminated  soil  areas at  the
 Ott/Story/Cordova  site.   In  1992,  U.S.  EPA  completed  a   Field
 Investigation  Memorandum concerning  results of  recent   sampling
 activity,  updated  risk calculations  to  account for the  recent
 sampling   activity,    and   supplemented    the   FS   for    the
 Ott/Story/Cordova  site.   This  information  helped U.S. EPA  assess
 the  potential  impacts  on remedial  alternatives  of  certain
 requirements under the  federal Resource Conservation and  Recovery
 Act (RCRA)  and the Michigan Act No.  307 which were effective  in the
 spring,  and  summer  of  1990,   respectively.    Under  RCRA,   new
 regulations  involving Toxicity Characteristic  Leaching Procedure
 (TCLP)  became  effective.  Approximately 25 organic compounds were
 added  to a  list  of compounds that  could  classify a  waste as
 hazardous dependent on  the leaching potential  of  such  compounds
 from that waste.   The  TCLP test now includes  such compounds as
 hexachlorobenzene, methoxychlor, and 1,4- dichlorobenzene which are
 compounds previously found in certain site soil samples during U.S.
 EPA's Remedial Investigation (RI) of the  site.   U.S. EPA  has also
 considered past acts of  disposal conducted at the site, and whether
 such  acts  may  involve disposal  of certain   listed  wastes  as
 discussed within Part  261  of  RCRA.   Under  Act 307, rules were
 enacted  specifying how cleanup criteria may be applied to a site.
 The volume of  soils to be managed have been revised somewhat from
 earlier  FS  estimates based on  these  new enactments, as  well as
 field findings from sampling conducted at the site in winter 1992.

 During  the  trial  on liability issues,   several  former  employees
 appeared as  witnesses  before the  Court  and  discussed  their
 recollections of past disposal activity at the site.  In planning
 for Operable Unit  Three sampling activity, U.S. EPA met some of
 these persons at the site and exchanged correspondence with others
 in an  effort to  better  locate  possible areas subject to  disposal
 activity.   In  January and February 1992, U.S.  EPA  performed the
 field  sampling for  Operable Unit  Three investigative  purposes.
U.S. EPA excavated and made visual examinations in certain  areas of

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-------
the  Site   in   order  to  check  areas  of  unusual  geophysical
characteristics  and points brought to the Agency's attention by
past plant operators.   The inspections  revealed  that  some site
areas were formerly used as places of waste disposal.  An area east
of the former production facilities and located in a field  south of
the  equalization basin,  in particular,  was  found through these
visual  inspections  to contain hazardous  substances and disposed
drum fragments.

U.S. EPA also  collected a  select  number  of soil  samples near
locations where past waste  incineration or other burning may have
been conducted.  U.S. EPA learned during the  course of recent site
investigations and  through review of  plant operator testimony at
trial  that the  former incinerator  had  been subject to  certain
process  upsets,  and that  combustion  efficiency of past  burning
operations may have been low.

U.S. EPA also  arranged  for the collection  of soil samples near
areas of sparse vegetation at the site, and through its Corvallis,
Oregon Research Laboratory conducted biological screening of such
samples  to see if,  compared to background conditions, such soils
pose an environmental threat due to past releases of raw materials,
intermediates,  or products utilized at the site.

Results  of  these sampling  efforts were  received  by  U.S.  EPA in
1992, and subsequently placed in the administrative  record file, as
well as pictures of the field investigation efforts.

Volumes of soils  estimated to be dealt with have also been modified
somewhat based  on the outcome of further exploration of surface and
shallow subsurface soil areas.  The areas explored were those noted
by plant operator personnel in court testimony presented in May
1991 and areas of unusual geophysical characteristics found by U.S.
EPA.
5.   SUMMARY OF SITE CHARACTERISTICS

An important site characteristic at Ott/ Story /Cordova is the sandy
nature of  site soils which have  a  high permeability.   Although
there  is  likely some  seasonal  variation,  the  groundwater  is
encountered only about five feet below the ground surface of the
site.  Past  usage of unlined waste lagoons and subsequent plant
spills/releases through vessel overfill, container failure,  pump
failure,  improper valve function, product line blockage, etc., have
resulted  in  introduction  of  pollutants  into   the  soil  and
groundwater.

The site is  at  the  headwaters of a very small  surface  water and
likely groundwater divide.  Drainage is generally to the southeast.
It should be noted  that  at the extreme western end of  the site,
toward Whitehall Road, surface drainage patterns likely shift to

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                                10

 the  Green Creek basin.  U.S. EPA  is  not aware to date  that site
 releases  have  affected this stream as opposed to the  Little Bear
 Creek basin.   Monitoring wells to  be  placed near  the site as part
 of  Operable Unit One  and  Two remedial  action will help  provide
 further information whether contaminated groundwaters have migrated
 or could  migrate beyond the Little Bear  Creek basin.

 Down to  about  the 65  foot depth,  soils  are  predominantly sandy.
 The  aquifer in this  zone is unconfined.   From about  65'-85'  below
 the  ground's surface,  there are  layers of silts and clays,  which
 tend to subdivide the  upper sandy zone from  the lower sandy zone
 which predominates  again below the 100 •  depth until a thick clay
 zone is encountered at about 150'.  Information from  a  pump test
 conducted by consultants for the  responsible parties in the winter
 of 1992 indicated that  the  silt/clay layers allowed leakage between
 deeper and intermediate aquifer  zones.    Some borings  performed
 during this  test,  which was  near the intersection  of River and
 Central Roads,   indicated some signs of soil  staining and chemical
 odors at  approximately the 90' depth.

 In the context  of Operable Unit Three, the term "subsurface  soil"
 includes  only  those areas  that  are  at  or  above  the  groundwater
 table.     As  discussed  in   the 1989   RI  Report,  a  contaminant's
 characteristics such as structure, solubility, and vapor pressure
 influence  its  potential  to migrate and  its  rate  of migration in
 soils and groundwater.

 Background sample collection  in the  area of the facility  in  1988
 revealed  negligible levels of  organic  contamination in soils,
 sediments, and  surface  waters. These  conditions held true  in 1992
 also.

 Highlights of  field  results for Operable Unit Three sampling are
 presented below. Results are presented in terms of micrograms per
 liter for water samples, and  in terms of micrograms per kilogram
 for  soil  or sediment samples.  Such  units  correspond roughly to
parts per billion.   Figures 1  and 2 provide a depiction of  some of
the key sampling points utilized  in the 1992  supplement to the FS
 field work.  Tentatively identified compounds and their estimated
concentrations  are indicated by "*."

 1992 Supplemental Sampling Results

Sample  Location/Type     Contaminant              Concentration

SW 3 (water)              Benzene                    6000
                         Toluene                    4800
                         4-Chloroaniline            1000
                         *  various alkyl            1100
                           benzeneamines

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                                11
 SO  3(sediment soil)
SO 4(sediment soil)
SW 4(water)
TP 3A(test pit soil)

TP 3B(test pit soil)


TP 5A(.test pit soil)
TP 5B(test pit soil)

SS 2(surface soil)




SS 3(surface soil)
SS 5(surface soil)
 Benzene                  17000
 Toluene                  42000
 4-Chloroaniline           1200
 4-Methylphenol             1000
 *  congeners  of  dimethyl   22000
   benzenamine
 *  congeners  of  ethyl      22000
   benzenamine

 Benzene                  17000
 Toluene                  99000
 *  congeners  of  ethyl      12000
   benzenamine

 Benzene                   4500
 Toluene                   6400
 Chloroethane              1000
 4-Chloroaniline            2300
 *  various alkyl            3600
   benz eneamines

 Arochlor-1254              3900

 Hexachlorobenzene          1600
 Lead                     102000

 Chloroform                 1600
 1,2 - Dichloroethane       3400
 Carbon  Tetrachloride      26000
 1,1,2 - Trichloroethane    3100
 Tetrachloroethene          2300
 4-Chloroaniline            1200
 Lead                      91700
 *  benzamide               15000
 *  l-chloro-2-isocyano-     2600
   benzene

 * Trifluralin              6700

 2,3,7,8- Tetra-              0.02
 chloro- dibenzo-
 1,4-dioxin (estimated
value)

Arochlor-1248              5800
Lead                      16800
 * 2,6-Dichlorobenzamide   19000
 * 2,6-Dichlorobenzo-      33000
      nitrile

 * 2,6-Dichlorobenzo-      17000
      nitrile

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 SS  7(surface  soil)
                                12
 4-Chloroaniline
 Hexachlorobenzene
 Lead
 Chromium
  1700
  1300
 28300
 21600
 Highlights of  1988  Remedial  Investigation Results for Soils
 Sample Location/Type
 SF-01SW(surface  soil)
 SF-01SE(surface  soil)
 SF-01NE(surface  soil)
 SF-02W(surface soil)
 SF-02E(surface soil)
 SF-05S(surface soil)
 SF-05N(surface soil)

 SF-06(surface soil)
 SF-09(surface soil)
 SF-10SW(surface  soil)
 SF-10NW(surface  soil)
 SF-11W(surface soil)
 SF-llE(surface soil)
 SF-12M(surface soil)
SB-07(near surface
soil in close proximity
to SF-12)
SF-16(surface soil)
SB-24(near surface
soil in close proximity
to SF-16)
 Contaminant
 4-Nitroaniline
 4-Nitroaniline
 4-Nitroaniline
 4,4'-DDT
 4,4'-DDT
 4,4'-DDT
 4,4'-DDT
 Methoxychlor
 4-Chloroani1ine
 Aroclor-1248
 Hexachlorobenzene
 Methoxychlor
 4,4'-DDT
 4,4'-DDT
 4,4'-DDT
 Methoxychlor
 1,1,1-Trichloroethane
 Xylene(s)

 Benzoic Acid
Hexachlorobenz ene
 4,4'-DDT
 1,4-Dichlorobenzene
 1,2-Dichlorobenzene
Hexachlorobenz ene
Concentration
  2300
  2700
  2400
 25000
  1900
  4200
  5900
  5300
  1200
 15000
  3400
  1300
  5500
  5400
  2700
  8400
 17000
 79000
  2900
  1300
  1200
  7600
13000
  7800

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                                13
              *
 SF-20(surface soil)      1,2-Dichlorobenzene       11000
                         Benzole Acid              75000
                         Methoxychlor              25000

 A  look  at this  information indicates that in general, aside  from
 the  areas subject to waste disposal activity, soil contamination
 tends  to predominate  in  those areas of  the  plant where raw
 materials/products were shipped in and out of the  plant, or where
 internal  routing  of wastewaters took place.

 The TCLP  testing  conducted at the site by U.S. EPA indicated  that
 the  contaminated soils/sediments  were  not  characteristically
 hazardous waste with regard  to  such  compounds  as methoxychlor,
 hexachlorobenzene, and 1,4-dichlorobenzene.  TCLP testing conducted
 by certain private persons  indicated that one soil sample may be
 characteristically hazardous for the compound carbon tetrachloride.

 U.S. EPA also performed  limited biological testing  on certain  site
 soil samples to  explore possible environmental damage consequences.
 Biological  testing  consisted of  the  standard vegetative   root
 elongation toxicity  test  and  "Microtox" testing.  Microtox  is a
 commercially produced bacterium used for toxicity testing which is
 luminescent.  If  its metabolic processes are inhibited such as by
 being   exposed   to  toxic  media,    its  luminescence  decreases
 proportionately  with relative luminescence  thereby  providing  a
 measure of  toxicity.   These  tests  were  conducted on  four  soil
 samples collected from  the site.   One of these points  was  from
 beyond the fenceline northwest of the former production area, and
 was collected for background purposes.  No indications of toxicity
 were revealed for this  sample.   Of  the other  three  samples, two
 were collected in the vicinity of the former pilot  plant area, and
 one from an  area south of Agard Road believed to have been used for
 fire training  purposes.   Notably  in  the  vicinity of the pilot
 plant, there were indications  of  significant toxicity with regard
 to both the root elongation and Microtox test.

 Oioxin  sampling in the vicinity of  the  former incinerator pad
 indicated positively the presence of dioxins,  although at a level
 below quantifiable detection limits.

 Soil/Sediment Cleanup Criteria

 U.S. EPA  indicated in its April 1993  Proposed  Plan for this  site
that, in  this  situation,  it  appears appropriate  to  conduct any
 necessary site  soils/sediment cleanup  to  attain  Michigan Act 307
Type B soils criteria.   These  criteria are listed on the next page
 for contaminants  of  concern at the Ott/ Story /Cordova site.   It
 should  be noted  that  Type  B  criteria  take  into  account  the
potential  for contaminants  in  soil to contaminate groundwater, and
health  risk  from direct  contact  with  contaminated  soils.   The
potential  to contaminate  groundwater is based  on  a level  of 20
times the  corresponding  groundwater criterion for a given

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                                 14
 contaminant.   The selected Type B cleanup  level  is then based on
 the more restrictive of these two values.   However, in some cases
 one of the values calculated may  fall below  analytical detection
 limits for a given compound, in which case the analytical detection
 limit becomes the cleanup criterion.  In developing these criteria,
 calculations  by  U.S.  EPA  contractors  underwent  review by  MDNR
 staff.  It would be appropriate  to invoke these  criteria  if an
 examination of potential risk to human health or the environment at
 the site revealed an unacceptable degree of risk posed by the site
 soil/sediment  conditions.
                       Soil Cleanup Criteria
 Contaminant
Aldrin
Aroclor-  1248  (PCS)
Bis  (2-ethyl hexyl)  Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
4,4-DDT
1,2-Dichloroethane
1,2-Dichlorobenzene
1,4-Dichlorobenzene
Dieldrin
Ethyl Benzene
Endosulfan Sulfate
Hexachlorobenzene
Methylene Chloride
Methoxychlor
1,1,2,2-Tetrachloroethane
Tetrachloroethene
1,1,l-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
1,2,4-Trichlorobenzene
Toluene
Xylene
                             Type B Cleanup Criterion
                                 in parts per  billion*
                                  1.7
                               1000
                                 60
                              22000
                               2600
                                  2
                                  8
                              12000
                                 30
                                  0.04
                               1500
                                  3.3
                                  0.4
                                 92
                                700
                                  3.6
                                 14
                               4000
                                 13
                                 44
                               2200
                              16000
                               5600
(to detection limit)
6.
SUMMARY OF SITE RISKS
The purpose  of risk assessment  is to estimate  the magnitude of
potential risk to public  health  and the  environment which may be
due to  exposure to  contaminants identified at  the site.   Such
assessment involves identifying contaminants of potential concern,
routes  by  which such  contaminants may migrate,  and populations
which may come into  contact with the contaminants.  Furthermore,
the assessment is based on the premise that no action will be taken
at the  site to remediate  areas of contamination.  The assessment
may also consider current site conditions,  and possible future land
use changes.

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                                15

Factors  in selecting contaminants  of concern  include whether  a
given substance was found at levels above background, the degree of
occurrence  for the  substance, and  the  relative toxicity  of  a
compound.  For estimates of human health risk, the general types of
toxicity  may  be  subdivided  into the  two  major  categories of
carcinogenic  and  noncarcinogenic  effects.    As used  within  the
context of a site risk evaluation,  the term noncarcinogenic refers
to deleterious health effects other than cancer which may be caused
by  exposure  to  a  given  substance;  carcinogenic  refers   to  a
substance or agent which produces or incites cancer.

Contaminated soils, sediments, and water  may create pathways  for
exposure to such  chemicals through dermal contact, ingestion, or
inhalation.

With regard to Operable Unit Three,  the  pathways  of exposure of
primary  concern involving soils/sediments  are exposure  to site
workers,  and  future exposure to  soils and  sediments  should
residential usage of  the  site  occur.   Future workers may include
construction and/or maintenance workers performing most of their
activity outside,  as  well as  general workers who  may work both
inside and out of doors.  The routes of exposure would include
dermal absorption for contaminated soil particles adhering to the
skin,  ingestion of soil  particles,  and  inhalation  of materials
which may volatilize from soils/sediments into the air.

Different categories  of site users  or  workers may  have varying
degrees of exposure to site contaminants.   Factors which may affect
degree of exposure include the amount of  incidental ingestion of
soil and dust,  the number of times  a worker or visitor may come to
the site in a given length of time,  the type of activity engaged in
by an individual,  the weight of the individual,  the  degree to which
a substance may be absorbed through the skin, etc.  U.S. EPA makes
note of certain standard default exposure factors listed in a March
25, 1991 directive from its  Office of Solid Waste and Emergency
Response on these topics.  Using the information in this directive,
as well  as professional judgement, certain assumptions are made
concerning individuals  who may utilize the  site now  and in the
future:

General Workers:
Incidental soil ingestion of  50 milligrams/day (directive)
250 days/year of exposure during  a working career of 25
years (directive)
Body weight of 70  kilograms  (directive)
Exposure to surface soils only with no access restriction
(judgement)

Construction Workers:
Incidental soil ingestion of  480  milligrams/day (directive)
250 days/year of exposure during  a working career of
1 year for a  given project (directive)

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                                16

 Body weight of 70 kilograms (directive)
 Exposure to both subsurface and surface soils
 in former central plant areas (judgement)

 Maintenance Workers:
 Incidental soil ingestion of 480  milligrams/day
 50% of  working day;  otherwise 50  milligrams/day
 250 days/year  of exposure during  a  working career of
 25 years (judgement)
 Body weight of 70 kilograms (directive)
 Exposure to both subsurface and surface soils
 in former central plant areas (judgement)

 Future  Site Residents:
 Incidental soil ingestion of 100  milligrams/day
 for all persons above the age of  6  (directive)
 Incidental soil ingestion of 200  milligrams/day
 for persons up to the age of 6 (directive)
 350 visits/year (directive)
 Body weight of 70 kilograms for adults  (directive)
 Body weight of 15 kilograms for children (directive)
 Exposure to surface soils only (judgement)

 Data sets  were  evaluated  to consider  those  chemicals   above
 background  levels,  toxicity  constants  for  noncarcinogens and
 carcinogens were reviewed, and the degree of occurrence of a  given
 substance at the  site was considered.
EXPOSURE ASSESSMENT

Historically, during production periods at the site, non-regulated
releases  of  contaminants  occurred  to  the air, soil  and water.
Contaminants in  soils at  the  site  have  a  pathway for potential
exposure to humans by either direct  contact or use  of groundwater.
Allowable rates  of release to  waterways were established through
state  Orders;  the  history  of  the  site  indicates  that  several
instances of  exceedance of such allowable discharge  rates occurred.

Further releases  and migration of the  contaminants  can  occur by
movement of contaminants into groundwater with potential exposure
pathways by  means of  production  wells,  subsequent  discharge to
surface  water  of   at  least   a  portion  of  the  contaminated
groundwater,   volatilization  into   the  air  or  suspension  of
contaminated dusts into the  air,  or runoff of surface water that
may carry contaminated soils.   RODs developed for  Operable Units
One and Two addressed  risk and  exposure from contaminants in the
surface water and groundwater,  respectively.

The presence  of  contaminants  in  soils  and sediments result in
several exposure pathways.   Persons  who may come in contact with
soils/sediments are considered  a potentially exposed population.

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                                17

Operable  Unit Three will  address the  primary exposure scenario
posed  by   contaminated  surface  and  near  surface  soils  and
sediments.  This scenario focuses on ingestion  and dermal contact
by potential  site  users.   Volatilization of some substances from
soils into the air is also possible.

TOXICITY ASSESSMENT

The degree of toxicity which may be posed by a  given chemical may
be described in part  by  its acceptable intake or its reference dose
and in the case of carcinogens by its carcinogenic potency factor
(CPF).   Reference doses, or  RfDs,  are  derived from information
available from studies on animals or human epidemiologic studies.
Adjustments from animal studies to predicted behavior with humans
is subject to multiplication by various uncertainty factors.  These
values  are  normally  reported  in  rag/kg  body weight/day,  and
generally represent  the highest calculated  exposure  level below
which the  given  adverse effect  will  not occur.   A carcinogenic
potency factor is expressed as lifetime  cancer risk per mg/kg body
weight/day, and  is estimated  at the upper  95  percent confidence
limit of the carcinogenic potency of a given chemical.

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.   CPFs 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.

RfDs have been developed by U.S.  EPA to  indicate the potential for
adverse health effects  from exposure to chemicals.   The  RfD  is
based on the  assumption that  thresholds exist  for  certain toxic
effects such  as  cellular necrosis,  but may not exist for other
toxic effects such as carcinogenicity.   In general,  the RfD is an
estimate with an uncertainty spanning perhaps an order of magnitude
of  a  daily  exposure to  the   human  population.   This  includes
sensitive subgroups that are  likely to  be  without an appreciable
risk of deleterious effects during a lifetime. RfDs can be derived
for noncarcinogenic compounds, as well as for the noncarcinpgenic
health effects of compounds which are also carcinogens.  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.  Uncertainty factors help ensure that the RfDs
will not underestimate the potential for adverse noncarcinogenic

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                                18
effects to occur.

The  following  information  notes  ingestion RfDs  and  CPFs  for
selected chemicals  at the Ott/Story/Cordova site.   (The  term "E"
refers to exponential notation, and for example in the case of "E-
03"  means  to move  the decimal  point for  the  value given  three
places to the left.)  Also noted is the weight of evidence for the
various  categories  of  potential  carcinogens.    The  weight  of
evidence for  carcinogenic behavior is divided into the following
groups:

Group A chemicals,  known human carcinogens, are agents for  which
there  is  sufficient  evidence to support  the causal  association
between exposure to the agents in humans and the on-set of cancer.

Group Bl and B2 chemicals, probable human  carcinogens,  are agents
for  which  there is  limited  (Bl)  or  inadequate  (B2)  evidence  of
carcinogenicity  from  human  studies,  but  for  which there  is
sufficient evidence of carcinogenicity from animal studies.

Group C chemicals, possible human carcinogens, are agents for  which
there is limited evidence  of carcinogenicity in  animals.

Group 0 chemicals, not classified, are agents with inadequate  human
and  animal evidence of carcinogenicity or for  which no data  are
available.

Group E chemicals  are agents  for which there is  no evidence  of
carcinogenicity in adequately performed human or animal studies.
Hazardous Substance    RfD

1,1,2-trichloroethane   4.3 E-03
1,2-dichloroethane
Benzene
Chloroform              1.OE-02
Tetrachloroethene       1.OE-02
Toluene                 2.0E-01
1,2-dichlorobenzene     9.OE-02
1,4-dichlorobenzene
4-chloroaniline         4.0E-03
4-nitroaniline
Benzoic Acid            4.0E+00
Benzo(a)pyrene
Hexachlordbenzene       8.OE-04
4,4'-DDT                5.OE-04
Aldrin                  3.OE-05
Aroclor 1248
Methoxychlor            5.0E-03
Dioxin
Lead
Slope Factor Weight of Evidence
   9.1E-02
   2.9E-02
   6.1E-03
   5.1E-02
   2.4E-02

   3.0E-07
   7,
   1,
 .2E+00
 ,6E+00
3.4E-01
1.7E+01
7.7E+00

1.5E+05
B2
A
B2
B2
D
D
C

B2

B2
B2
B2
B2
B2

B2
B2

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                                19

 RISK CHARACTERIZATION

 Estimating  the   risk  of   a   noncarcinogenic  health  effect  is
 accomplished by calculating the hazard quotient (HQ); this is done
 by dividing the dose estimated to be received by someone exposed to
 a  substance by  the  established  safe  dosage  estimate for  that
 chemical.   If the resulting  answer  is greater than 1 then  the
 exposure  has exceeded a safe  level.   Adding all the HQs  for  the
 chemicals  of concern  in a given route  of exposure pathway  gives a
 hazard index (HI) for that pathway.  According to the NCP,  when the
 HI exceeds 1, there is  a potential health risk.

 Carcinogenic risk is estimated by multiplying the estimated dose of
 the  chemical by its published or calculated slope factor.   As with
 noncarcinogenic hazard quotients, carcinogenic risks are assumed to
 be additive for all chemicals  within an exposure pathway.  The NCP
 has  established  a carcinogenic risk of greater  than 1 x  10 "4  as
 being unacceptable  for  human health.    (This represents  the
 contracting of cancer due to  environmental exposure as  one in  ten
 thousand.)  The reduction of such  risk to within  the  risk range of
 1 x  10~4 to 1 x 10"6  is  viewed by the NCP as acceptable; U.S.  EPA
 often uses the  1 x 10"6 figure as a  desirable goal  for adequate
 protection.

 It  may then  be  calculated under Risk Assessment  Guidance  for
 Superfund  (1989  guidance  to  U.S.   EPA)   that  risk  for  human
 populations may be expressed as follows:

        Category          Noncarcinogenic      Carcinogenic
                          (Hazard Index)     (Excess Cancer Risk)


 General Worker              0.3                  1.18 x 10"4

 Construction Worker         0.46                 3.0 x 10"6

Maintenance Worker          0.4                  9.0xlO~5

 Future Site Visitor/        2.4                  3.Ox 10"4
Resident                 (HI of 1.9 age group 4-6;
                         HI of 0.5 age group 7-30)

Current Visitor             0.02                 2.0 x 10"7
 (assumes  exposure only to  presently  unrestricted   site  areas;
surface soils only)

As can be seen from the scenarios  reviewed above, risk associated
with  soils/sediments at  the Ott/Story/Cordova  site  are above the
threshold  of acceptability  for  the  general  site   worker,  and
threefold  above  this  threshold for  the  case  involving  future
residential usage.  A special  case is  presented  for soils in the
vicinity of the former incinerator pad.  At this point, dioxin

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                                20

 compounds were detected.  Because of the high slope factor utilized
 in calculations involving such compounds, exposure to surface soils
 at  this point results in the  following risk characterization for
 the  site users noted on the  previous page:

                              Carcinogenic
                           (Excess Cancer Risk)


 General Worker                 1.2 x 10"3

 Construction  Worker            9.1 x 10"5

 Maintenance Worker             1.2 x 10"3

 Future  Site Visitor/Resident  7.3 x 10"2

 Averaging  of dioxin values  across  the site  was  not performed
 because the dioxin detected occurred only at the single point noted
 above.

 Uncertainty  associated with site risk  concerns to  what  degree
 exposure parameter assumptions and land-usage patterns may change.
 For  example,  when  remedial actions  for  operable Unit One come on
 line fully, an improvement in  stream water quality is  the desired
 outcome.  This factor may tend to promote stream usage;  exposure to
 contaminated  sediments  may increase  if  sediment quality  does not
 change  as  rapidly  as water  quality.  Future  land-usage  patterns
 concerning former production areas and former administrative-type
 office  areas are not certain.

 Current and future risks to site users have the potential  for over
 and underestimation.  Should frequency or duration of  exposure to
 future  site users prove less  than assumed, actual risk  may be less
 than what  is projected now.   Current  remedial action  guidance
 emphasizes  an examination  of maximum  expected  risk,   and not
 necessarily the worst possible case.   Hence,  the  soils  actually
 sampled do not likely reflect the worst case potentially presented.
 U.S.  EPA  has reason  to  believe,  however,  that  more  severe
 contaminant concentrations may exist on the site. For example, the
 contractor's log  of test pit  5A as noted  in the Field Investigation
Memorandum speaks of a finding of a "...  white & creamy sludge in
 a 2  ft. [by]  3ft. cavity  in the bottom of pit w/lab bottles  floating
 in it...",  as well as "...black and purple staining..." elsewhere
 in the  pit.   Additionally,  the  tentatively  identified compounds
associated with both surface and subsurface sampling  points may
present some unknown risk to  site users which are not now factored
 into these discussions.  To illustrate this matter, 1992 sampling
results  indicate  that  there were  9300  ug/kg  of  tentatively
 identified semivolatile compounds associated with  the background
sampling location.   This value may be contrasted with the finding
of 329,000  ug/kg of tentatively identified semivolatile compounds

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                                21

 associated with a  sampling point  northwest  of the  former pilot
 plant  location,   and  44,000  ug/kg  of  tentatively  identified
 semivolatile compounds associated with a  sampling  point near the
 former plant's southern railroad spur., One  compound tentatively
 identified at test pit sampling  point SB was Trifluralin.   Page
 9599  of the eleventh  edition  of  The Merck Index as  published by
 Merck & Co.,  Inc.,  in 1989  informs  the reader that Trifluralin is
 used  as a pre-emergence  herbicide.  Tentative  identification of
 chlorinated   benzonitrile  compounds  occurred  at  surface  soil
 sampling points SS03,  SS04,  and SS05.   The reference source Sax's
 Dangerous  Properties  of  Industrial Materials,,  by R.  A.  Lewis,
 eighth edition as published in 1992  by Van Nostrand Reinhold of New
 York  provides safety profile information on these compounds.  This
 text  describes nitriles in general as organic compounds having the
 CN, or cyanide, grouping  within the molecule.   Chlorobenzonitrile
 is  further characterized  as  moderately  toxic  by ingestion,  and is
 considered an eye irritant.   Upon  contact with water, acid, or acid
 fumes,  Chlorobenzonitrile may release  toxic fumes.   This  same
 reference  source  also discusses  isocyanate compounds, and  notes
 that   organic  isocyanates   can  cause   irritation   and  allergic
 reactions.  Organic compounds tentatively identified as having the
 isocyanate structure within the molecule were indicated at surface
 soil  sampling points  SS03,  SS05,  and test pits TP3B, TP5A,  and
 TP5B.  Azobenzene was tentatively  identified at shallow soil boring
 SB03.    The  Condensed Chemical  Dictionary,  tenth  edition,  as
 published  in 1981 by Van  Rostrand Reinhold Company  indicates that
 azobenzene is used in the manufacture of fumigants and acaricides,
 and  that  it  is moderately toxic  and  may cause  liver  damage.
 Furthermore, some substances such as lead  which  were  definitively
 identified  and   quantified  do  not   have  necessary   toxicity
 information in the literature  to perform risk calculations;  hence
 risk may be underestimated for that reason.

 Notably in the vicinity of the pilot plant there were indications
 of  toxicity with  regard to  both  the  root  elongation  and  the
 Microtox   test.    U.S.  EPA  interprets these   test  results  as
 indicating that  some  past  disposal practices  may  be  having  an
 adverse effect on the  environment.

 In  summary,   quantifiable risk to  public  health  presented  by
 soils/sediments at the  Ott/Story/Cordova  site  are  above  upper
 limits  as  far as an acceptable degree of risk.   Such  calculations
 assume  zero risk from tentatively identified compounds, and  zero
 risk contribution from certain positively identified compounds for
which no values exist  in the literature to further  quantify  risk.
U.S.  EPA observes  that it appears  improbable that  the true  risk
contributions of such compounds is zero.   Furthermore, there  is
demonstration of environmental risk associated with such soils.

These results indicate that  a potential  ingestion or absorption of
soils/sediments from certain areas  at  the  Ott/Story/Cordova  site
pose significant health and environmental risks.  The above

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                                22

discussions  indicate that  the risks from  current and potential
exposure to contaminated soils/sediments are unacceptable.   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.


7.   DESCRIPTION OF ALTERNATIVES

The alternatives analyzed for OU Three are presented below:

Alternative l  - No  Action

U.S. EPA  is  required to consider a  no-action alternative.   This
alternative serves  as a baseline for comparison purposes.    Under
this alternative, U.S. EPA would take no further action at the site
to  monitor,   control,   collect,   treat,   or  otherwise   cleanup
contaminated soils/sediments.   The  cost  of  this  alternative  is
therefore zero.


Alternative 2  - Institutional Control

Capital Cost:  $ 54,000
Annual O & M Costs:  $ 10,000/year for up to 30 years
Net Present Worth:   $ 207,000
Time to Implement:  6 months

Access  to  some  portions  of  the  Ott/Story/Cordova  site  are
restricted, notably by  the  fencing  surrounding former production
areas.  Other portions of the site are unrestricted, and such areas
include contaminated soil zones east and south of Agard Road.  To
further restrict  public access to  such areas,  fencing could be
extended/constructed and warning  signs placed.  Property deeds may
need to be amended, so as  to  place restrictions on  land  use by
current/future owners, precluding such persons from using certain
land segments.   No excavation or treatment  of  contaminated soil
areas is envisioned.


Alternative 3a - Construction of an on-site landfill with
                 subsequent excavation and disposal of
                 contaminated soils/sediments therein, capping,
                 monitoring, attain RCRA subtitle D - Michigan
                 Act 641, restriction of further land usage,
                 security measures,  maintenance of the landfill,
                 clean fill

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                                23

 Capital Cost:   $  3,900,000
 Annual O & M Costs:  $ 50,000
 Net Present  Worth:   $ 4,700,000
 Tine to Implement:  23-28  months

 This alternative would involve  the  construction  of an  on-site
 landfill for  the disposal  of  contaminated  soils and  sediments
 excavated from the  site.   Excavation will be conducted  such that
 after disposal all  other  site areas will  have either  attained the
 cleanup criteria  or the groundwater table will  have been reached.
 The only exception  to this  excavation procedure would  be  in
 instances where obvious signs of  past waste disposal  activity are
 encountered  at the  groundwater table.   Because of  the relatively
 shallow groundwater  table at  the site,  the  landfill  would  be
 constructed  above grade.   It is estimated that  approximately 7200
 cubic yards  of contaminated materials  would undergo excavation.
 The landfill will be constructed to meet the requirements of  Act
 641, Michigan's solid waste regulations.  Providing adequate  cover
 over the contaminated soil and sediment would be at least two feet
 of  clay,  a  drainage  layer over the clay,  a suitable geotextile
 membrane between the drainage layer and  overlying soil of at least
 1.5 feet  in  thickness,  and finally topsoil and  a vegetative  cover
 to  help minimize erosion.   The  design life of  the  landfill  is
 estimated at 30 years.

 Alternative  3b  -  Construction of  an on-site landfill with
                  subsequent excavation  and disposal of
                  contaminated soils/sediments therein, capping,
                  monitoring, attain RCRA  Subtitle C - Michigan
                  Act  64, restriction of further land usage,
                  security measures, maintenance of  the landfill,
                  clean  fill

 capital cost:   $  4,600,000 to 10,400,000
 Annual 0 & M Costs:  $ 50,000
 Net Present Worth:  $ 5,400,000 to 11,200,000
 Time to Implement: 23-28 months


 Alternative 3b differs from Alternative  3 a in  that a more rigorous
 manner  of landfill  structure design  and capping  is  called  for.
 Alternative   3b  would   be  designed  to   manage   excavated
 soils/sediments as though they were hazardous wastes.  Alternative
 3b  presumes  that  the presence  of  numerous tentatively identified
 compounds, the  wide  variety of chemicals handled at the site during
 its history and the limited ability of routine analytical service
 to  detect all  such  compounds, and the evidence  that there may be
more  concentrated areas  of  contaminants on  site  than  sampling
 results have  thus  far quantified should result in more conservative
management of excavated soils than in Alternative 3a.  Operation
and  management costs  for both Alternatives 3a  and 3b reflect
Operable Unit Three monitoring obligations only.  U.S. EPA notes

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                                24

 that proper management  of  a waste disposal  facility is to include
 groundwater monitoring  to  check for releases from  such facility.
 U.S.  EPA further notes that design for both Alternatives 3a and 3b
 should likely consider whether monitoring  wells associated  with
 Operable Units One and Two  might be able to play a role in Operable
 Unit Three.    U.S. EPA also notes  that the  coming  on line  of
 construction planned for Operable Units one and Two may bring about
 a situation where sediment quality may improve,  such that sediment
 excavation may  be  of  minimal  volume.   U.S.  EPA will monitor  this
 situation, and observes that biological monitoring may be a useful
 measure.  Any excavation necessary in  the vicinity  of  Little  Bear
 Creek is expected to involve only light remedial activity.


 Alternative 4 - Excavation of contaminated soils/sediments,
                monitoring, transport  to an off-site landfill,
                placement of clean fill at the Ott/Story/Cordova
                site

 Capital Cost:  $ 4,500,000
 Annual 0 & M Costs: $ 10,000
 Net  Present Worth:  $ 4,600,000
 Time  to Implement: 8-10 months

 As with alternatives  3a and  3b,  contaminated soils and  sediments
 will  be excavated  but sent off site for disposal in an  existing
 landfill.  The off-site landfill selected must be compatible with
 receipt  of  such  waste material.     Any  off-site shipment  of
 contaminated hazardous  soils/sediments must consider rules which
 discuss shipment  to  treatment,  storage, or  disposal facilities,
 appropriate site security measures, inspection, etc.  Some further
 analysis required  by the  receiving  facility may  be appropriate
 before materials are accepted for disposal.


 Alternative 5 - Excavation of contaminated soils/sediments,
                monitoring, transport to an off-site incineration
                facility, treatment therein, disposal of  residue
                in an off-site facility, placement of clean fill

 Capital Cost:   $ 18,600,000
Annual 0 & M Costs: $ 10,000
Net Present Worth: $ 18,800,000
Time to Implement: 12-14 months

 In this  alternative,  the  contaminated soils/sediments  would be
excavated and  transported  to an  off-site incinerator  where  the
waste  materials  would undergo  thermal treatment.   conventional
 incineration is typically  performed  in the temperature range of
 1600-2200° F.    There  may be  more  than  one  combustion  unit.
Residuals consist of ash, stack gases,  scrubber/quench solutions.
There are three basic types of incinerators;  a fluidized bed model,

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                                25

 rotary kiln,  or  infrared type.  A fluidized bed type may eliminate
 some/all scrubber water compared  to the rotary kiln  or infrared
 models,  since the fluidized  bed  type  typically uses  limestone
 internally to help control emissions.  This model also operates at
 a somewhat lower temperature than the other two types.  A screening
 step after excavation  is important  to  eliminate large diameter
 objects from entering  the  device.    Some  metals  can lead  to
 troublesome emission control  problems,  that is, metals  that can
 volatilize at  temperatures  below  2000°  F.,  such  as  arsenic,
 mercury, and  lead.  This alternative may require test burns by the
 proposed treatment facility.  Once materials undergo treatment, the
 residuals  will require final disposal.  The  goal of  conventional
 incineration  is  to convert  organic  contaminants to harmless by-
 products .

 Alternative 6 -  Excavation of  contaminated soils/sediments,
                 treatment on site  by means of low temperature
                 thermal desorption,  monitoring,  replacement of
                 clean fill and/or  transport  of residue to off-
                 site facility, land-usage restriction  as
                 appropriate

 Capital  Cost:  $ 6,800,000
 Annual O & M  Costs: $ 10,000
 Net  0 &  M:  $ 6,900,000
 Time to  Implement: 13-19 months

 This alternative would utilize the  technique of low  temperature
 thermal  desorption (LTTD)  for on-site treatment of contaminated
 soils/sediments.   To differentiate this treatment technique  from
 conventional  incineration, LTTD has  as its objective the driving
 off  of  contaminants  from  the  waste  mass,   rather  than   the
 destruction of such contaminants.   There is no combustion in the
 primary  unit  of the waste  itself;  instead  some portion of  the
 organic  contaminants  are  volatilized and  then  undergo  further
 treatment,  such as through an afterburner, condenser,  or sorption
 unit.   In  LTTD  application,  materials are heated in three basic
 ways: direct  heat, indirect heat,  or in-situ  steam  extraction.
 Direct heat application is rather like an 800° F.  rotary kiln;  such
 application is most often used for non-chlorinated organics
 handling.   Indirect heat may heat  a  fluid such  as oil first,  and
 pass the  heated  fluid through  some  jacket to  heat  the waste
 material.   In-situ steam extraction involves working temperatures
 of around 300-450° F.   In LTTD, the temperature 600° F. is seen as
 something of a "breakpoint".  Below this temperature, it is assumed
 that the main application is  for  volatiles; from  600-1150° F.,
 semivolatiles and PCBs are being attacked, also.   1150°  F.  is about
 the upper range for LTTD application.  At  these lower temperatures,
metals such as lead do not volatilize, making an easier emissions
 control situation.  After treatment, the residuals are soils, not
 ash. Unfavorable site characteristics  include excessive clay/silt
 content in the soil, many large diameter rocks, excessive  moisture

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:-.«*s-r  ?»:BP?S

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                                26

 content - since energy  is wasted driving off water first.  LTTD is
 best applied when the organic contaminants do not make up more than
 10%  of  the  soil matrix.   After treatment,  dust generation  may
 become a problem, so water is added to dampen the treated material.
 To prevent combustion,  sometimes  an  inert gas  such as nitrogen is
 injected countercurrent to the flow of treated material.  Following
 treatment the residual soils  may be suitable for replacement on
 site.   Prior  to commencing operation, treatability study would be
 necessary to  define optimum operating conditions.         '

 Alternative 7  - Construction of  an  on-site landfill with
                 subsequent excavation  of and  disposal of a
                 substantial portion of contaminated
                 soils/sediments  therein,  excavation and off-site
                 treatment of more highly contaminated
                 soils/sediments, capping, monitoring,
                 restriction of further land usage,  security
                 measures,  maintenance, clean  fill

 Capital Cost:  $ 4,113,000  (if 100 cubic  yards treated)
 Capital Cost:  $ 6,480,000  (if 1200  cubic yards treated)
 Annual  0 & M Costs:  $ 50,000
 Net  Present Worth:   $ $ 4,882,000 to $  7,249,000
 Time to Implement:  23-28 months


 This alternative combines the usage of containment to deal with  the
 majority of  contaminated soils/sediments  with treatment of that
 lesser  volume containing  more contaminated  materials.   From RI
 sampling,  and  supplemental  sampling  to obtain TCLP,  dioxin,
 toxicity, and excavation analysis  results, two site areas appear to
 have been more highly contaminated.   These are:  l)  The areas  around
 1992   sampling  area  test  pits  4  and 5   because  of   their
 concentrations  of  such mobile  and toxic compounds  as  carbon
 tetrachloride, 1,2-dichloroethane, chloroform,  etc.; and 2) Surface
 soils identified as  dioxin-contaminated near the former incinerator
 pad  area.   The  volume  of  soils  associated  with  these areas of
 greater soil contamination is estimated at from 100 cubic yards  for
 the  incinerator area to 1200 cubic yards for areas near test pits
 # 4  & 5.  For the purpose of cost estimation of this alternative,
 it is assumed that the treatment of such  higher  contamination areas
will be performed off site by  conventional incineration.

Common  Elements:  Except for the "No-Action"  alternative,   other
alternatives noted have certain elements in common.  Alternatives
which   would  leave   contaminated   soils   or   fill   on  the
ott/ Story/ Cordova  site  all  envision   some  form  of  land-usage
restriction.    In alternatives  3a, 3b and  7, the key objective of
restricting  land usage is  so that the  newly created on-site
 landfill is  not unduly disturbed.    This is  in addition  to  an
objective of alternative 2, where land usage restriction through

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                                27

 enhanced  security  or deed restriction has as a goal  the  reduction
 of exposure to otherwise contaminated soil areas.   Monitoring is a
 component of  alternatives  3  through 7.   In all cases, monitoring
 implies sampling of soils/sediments areas undergoing remediation to
 ensure  that  desired  cleanup  criteria  have been attained.    In
 alternatives  3a,  3b  and  7,  monitoring  also implies  periodic
 examination  of  the integrity of  the  landfill  cover,  while  in
 alternatives   5   and   6  monitoring   further   means  checking
 soil/sediment condition after treatment.  Appropriate  monitoring of
 such  units often involves placement and  sampling of groundwater
 monitoring wells as a means of checking  for effectiveness.   (In
 this instance remedial design may show that placement  of such wells
 may not be required because the execution of Operable  Units  one and
 Two  requires  the  development  of  an  appropriate  groundwater
 monitoring network which  may prove  to  be sufficient  for  such
 purpose.)    Operation  and  maintenance  might  normally  require
 consideration  of installation  of facilities a means of treating
 liquids/leachate that may be  gathered from the fill area.  However,
 U.S.  EPA  makes the assumption at  this  time that  any liquids  so
 gathered  from an  on-site  landfill will  be compatible  with  the
 contaminated  groundwater  treatment works necessary  for Operable
 Units one and Two.

 Excavation of  affected areas  is  also  a  common  component  of
 alternatives 3 through 7.   With regard to  excavation,  it  should be
 noted that excavation of contaminated soils  near former production
 areas.may involve relatively  heavy earth-moving equipment, whereas
 any excavation of any contaminated sediments in the vicinity of the
 creeks would  involve small  volumes  and  light manual equipment.
 U.S.  EPA  observes  that  the  principal  identifiable  hazardous
 substances associated  with deposits along  the stream  banks  are
 volatile  organic materials such as benzene and  toluene.  U.S.  EPA
 will be guided by monitoring and observation to be conducted as a
 part  of  Operable   Units  One  and  Two  to  changes   in  sediment
 condition, and the necessity  to actively perform light remediation
 activity  along  the stream  banks.    Another common element of
 alternatives  3  through 7  is the amount  of soil /sediment  to be
 excavated.  This volume is estimated at 7200 cubic yards,  and  is
 derived from calculations performed to attain Michigan Act 307 Type
 B criteria,  which  U.S. EPA  believes is  an appropriate Act  307
 application in this instance.


 8.  Summary of Comparative Analysis of Alternatives

A. The Nine Evaluation Criteria

 In selecting its preferred remedial alternative, U.S. EPA uses the
 following  criteria  to  evaluate each of the cleanup  alternatives
developed  in  the  FS  and its  supplement.   The  nine evaluation
 criteria are summarized below:

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                                28

   1)   Overall  protection  of human  health  and the  environment
       addresses  whether or not an alternative  provides adequate
       protection of human health and the environment and describes
       how  risks are  eliminated, reduced  or controlled  through
       treatment, engineering controls, or institutional controls.

   2)  Compliance with  Applicable or Relevant and  Appropriate
       Requirements (ARARs) addresses whether or  not an alternative
       will meet  all of  the ARARs pertaining to  federal  and state
       environmental  lavs  and  regulations  and/or  justifies  the
       invoking of a waiver of such ARARs.

   3)  Long-term  Effectiveness   and   Permanence refers  to  the
       expected residual risk and the ability of an  alternative to
       maintain   reliable  protection  of  human  health  and  the
       environment over  time, once cleanup  objectives  have been
       met.

   4)  Reduction of Toxicity,  Mobility, or Volume through treatment
       is the anticipated performance of the treatment technologies
       an alternative may employ.

   5)  Short-term Effectiveness involves the period  of  time needed
       to  achieve protection  and any  adverse  impacts  on  human
       health and the environment that may  be  posed  during  the
       construction  and  implementation  period  until   cleanup
      .. objectives are achieved.

   6)  Implementability  is  the  technical  and  administrative
       feasibility of an alternative, including  the availability
       of materials and services needed to  implement the given
       option.

   7)  Cost includes estimated capital  costs, as  well as operation
       and maintenance costs.   A  present net worth cost is then
       calculated from these costs.

   8)  State  Acceptance  indicates  aspects  of  the  preferred
       alternative and other  alternatives  that the  state support
       agency (MDNR)  favors or objects to,  and comments regarding
       state ARARs or the proposed use of waivers.

   9)  Community Acceptance indicates the public support of a given
       alternative.      This  criterion   is  discussed   in   the
       Responsiveness Summary.

B. Comparative Analysis

overall protection of human health and the  environment - The "no-
action" alternative does not  offer adequate protection  of human
health and  the  environment.   Taking no  action would  allow the
unabated presence of a level of risk beyond that deemed acceptable.

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                                29

Additionally,  as  biological testing performed  on site soils has
indicated, harm to the environment may result if certain site areas
do not undergo remediation.  Alternative 2,  which relies solely on
institutional  control as a means of remedy, is not protective of
human health and the  environment.  Even if measures limiting site
access and deed restrictions were rigorously observed,  areas of the
site would still pose possible problems.  While  site manufacturing
activity has been curtailed, a  "skeleton" staff still remains.  The
site gets  visitors from time  to  time  from  persons interested in
surplus chemical equipment. Furthermore, actions taken to restrict
access  by  persons would  not  provide sufficient environmental
protection to those site areas which appear to have some inhibitory
effect upon plant life and  soil bacteria.  Such restrictions also
would  do  nothing  to  mitigate  further  release  of  hazardous
substances  into groundwater.   Therefore,  while some  manner  of
institutional control may have a role to play in site remediation,
such  control  in  itself  does not  provide   adequate  protection.
Furthermore, the NCP at 40 CFR 300.430(a)(l) (iii) (g) indicates that
the use of institutional controls is  generally only appropriate as
supplemental   to   active  remediation,  such   as  treatment  or
containment, unless such active remedies are  not  practicable, which
they are in this case.

All other alternatives are  viewed as protective of human health and
the environment because they will remove contaminated soils and
leave behind concentrations attaining soil cleanup criteria.  Since
the "no action" alternative and the alternative relying solely on
institutional control (Alternatives 1 and 2) are not protective of
human health and the environment,  they will  not be considered
further in this document.

Compliance with ARARs -  The primary ARARs for Operable Unit Three
include federal and state regulations  dealing  with  soil  cleanup
criteria,  waste   management  and   landfill  cover   and   liner
construction, proper management of fugitive  dusts created through
excavation, management of  leachate generated and collected, soil
erosion   protection   measures,   proper   shipment   and   waste
characterization steps,  control  of air emissions generated,  and
restriction of inappropriate materials  from being disposed.  TCLP
testing conducted by U.S. EPA indicated  that the soils/sediments to
undergo disposal are not characteristically  hazardous with regard
to such  compounds  as methoxychlor,  hexachlorobenzene, and 1,4-
dichlorobenzene.  The significance of such testing was that at the
time of  release of  the proposed plan  to  the  public concerning
possible remedial action for Operable Unit Three that U.S. EPA did
not advocate a landfill design which would attain the even more
restrictive specifications which may be found in  RCRA Subtitle c or
Michigan Act 64 which deal with management  of  hazardous  wastes.
The Landfill Disposal Restrictions noted in  40  CFR Part 268 were
therefore  not  relevant  and  appropriate with   regard to  these
compounds.  Another key ARAR  for  this  and all  other alternatives
discussed is to minimize the creation of fugitive dusts that may

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                                30

 be created during the excavation and/or transportation phases of
 the remedial  action.   Parts 3, 7, and 9 of  Michigan Act 348 (Air
 Pollution Act)  discuss  the limitation of particulates,  fugitive
 dusts, and volatile organics which may result from construction and
 excavation activity performed to implement  a given  remedy.   Any
 collection and  subsequent  routing  of  leachate  or other  water
 generated by  undertaking action for Operable Unit Three would be
 subject to provisions  of the Clean Water Act of 1977, as amended,
 dealing with  the discharge of specific compounds  into navigable
 waters.   At this time,  U.S. EPA makes  the  presumption  that  any
 leachate  or other water generated and collected on-site would be
 compatible  with and would be routed to the treatment system to be
 built  to  serve  Operable Units  One  and Two.    The  substantive
 requirements  of  Michigan Act  347, dealing with soil erosion  and
 sedimentation, may also apply to acts of remediation.  It would be
 appropriate in the undertaking of  Alternatives 3a through 7 to take
 representative samples of soils handled or shipped with frequency
 sufficient  to adequately develop information  on  how  the  soils
 should be treated, stored, or disposed.   Alternatives 3a through 7
 should comply with all of the major ARARs 'noted  above provided  due
 care is taken in the construction and  maintenance phases of  the
 work to be done.   Given  the  numerous instances of  discarding
 specific  chemicals  on   the  site,  it  would  appear   that  for
 Alternative 4 a  compatible, landfill  for disposal of  untreated
 contaminated  soils  must  comply with  RCRA Subtitle  C design
 standards.  U.S.  EPA notes  that the greatest burden of  compliance
 with air emission regulations would appear to fall on Alternative
 6,  since that alternative contemplates on-site  treatment.

 It  is  noted for  purposes of ARARs  discussion  that the State  of
 Michigan   has  promulgated   rules   pursuant   to   the   Michigan
 Environmental  Response Act,  Act 307.   This   state  statute was
 originally enacted in 1982, but underwent significant amendment  in
 1990.  The State of Michigan issued rules reflecting such amendment
 in  July 1990.   In  general, U.S.  EPA maintains that substantive
 provisions  of state regulations  which  are  more  stringent than
 CERCLA requirements constitute ARARs.   Act  307  consists of  eight
 parts,  but  of particular note are parts 6 and  7  which deal with
 remedial action and cleanup criteria,  respectively.  U.S. EPA  notes
 that upon  examination  of  these parts,  certain   administrative
 provisions  are very  similar to the nine criteria  which form the
 basis for remedial decisions under the  NCP.   Such  administrative
 provisions are not ARARs.  However,  the substantive provisions  of
 these parts are considered ARARs for this response  action.

Rule 705(2) and (3)  require that all remedial actions  shall attain
 the degree of  cleanup for  a  Type A, B  or  C remedy, or a combination
 thereof.  U.S. EPA believes such cleanup selection to constitute  an
ARAR.  A Type A cleanup  generally achieves cleanup to background
 levels.   A Type  B  cleanup generally achieves  specific standard
risk-based cleanup levels.  A Type C  cleanup is based on a site-

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                                31

specific risk assessment that considers specific criteria.  Also,
Type A cleanup is to attain the standards noted in Rule 707.  Type
B cleanup must reflect  attainment  of  Rules 709-715 and Rule 723.
Rule  717  discusses  Type C cleanup.   U.S.  EPA notes  that it has
consulted with the MDNR concerning the soils cleanup criteria noted
elsewhere in this document.

Under the NCP, U.S.  EPA  is responsible for determining how Act 307
applies to the site.   U.S.  EPA has examined  this  matter and has
determined that  the  attainment  of Type  B soil  criteria  is  an
appropriate application.

The following summary lists other  ARARs of significance for this
operable unit, as may they pertain to a given alternative:

    Clean Air Act and National Ambient Air Quality Standards (CAA
    and NAAQS),  40 CFR  Part  50:   These regulations  discuss site
    emissions including  par'ticulates  during  on-site  excavation.
    They provide  methods and procedures for measuring specific air
    pollutants; such methodology may  apply to operation  of soil
    treatment  systems.     They  are  action-specific,  regarding
    alternatives  3a  through 7.

    Michigan Act  641 landfill regulations  299.4305(10),  deal with
    appropriate landfill topsoil application and drainage/sloping
    requirements; 299.4308(1)  deals with  means of leachate
    collection; 299.4307(2)(a)  deals with  synthetic liner usage;
    299.4307(2)(a) deals with thickness  of clay liners;  299.4310
    deals with appropriate vertical isolation  from the bottom of
    the landfill  to  the  top of the  groundwater table.

    40  C.F.R.  Part  61;  EPA Regulations  on  National  Emission
    Standards for Hazardous Air  Pollutants:   These rules denote
    substances designated as  hazardous  air pollutants,  prohibit
    certain   activities  and   describe   procedures   involving
    construction  and start of operations.   These  regulations  may
    provide substantive  requirements concerning operations.   They
    are  action-specific,  regarding  design  of   treatment  for
    alternatives  5 through 7.

    Resource  Conservation and Recovery Act   (RCRA)  of  1976,  as
    amended by the Hazardous Solid Waste Amendments  (HSWA) of 1984,
    42 U.S.C.  6901.  Subtitle C regulates disposal of that portion
    of solid  waste  designated as  hazardous  and the  generation,
    transport, storage, treatment and disposal of hazardous wastes.

    RCRA ARARs are not strictly applicable to this situation  but
    are relevant  and  appropriate  information, since  RCRA wastes
    were known to have been managed here and waste chemicals were
    known to have been improperly land disposed on the site.  RCRA
    ARARs may pertain to remedial action regarding alternatives 3a
    through 7,  since residuals created require proper  management.

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                             32
 Michigan Air Pollution Act,  Public Act 348 of 1965, as amended:
 This  act regulates  air quality  in the  presence  of new  or
 modified  air  sources.   Parts 3, 7,  and 9 of this  regulation
 discuss emissions  and  limitations  for particulates,  fugitive
 dust, volatile organic compounds, and other contaminants which
 may be injurious or adversely affect human health or welfare,
 animal life, vegetation, property, or interfere with normal use
 and enjoyment.  Substantive portions of this regulation may
 apply to  excavation of  contaminated soils,  operation of any
 soil treatment system,  and related construction activity.  This
 act is action-specific, regarding monitoring or  any  needed
 control of volatile organics in alternatives 3a  through 7.

 40 C.F.R. 262; Regulations for Hazardous Waste Generators and
 Michigan Hazardous Waste Management Rules, Part 3, R299.9301  to
 9309; "Generators of Hazardous Wastes."

 Note:  This, as well as the CERCLA off-site policy,  is  "to  be
 considered" information which may pertain to any necessary off-
 site shipments of still-contaminated soils after treatment  by
 low temperature thermal description,  such regulations are ARAR
 if  CERCLA  site  materials  are shipped   off  site   to  RCRA
 treatment, storage or disposal  (TSD) facility and constitute a
 hazardous waste.   They are chemical-specific, as related  to
 soils/sediments and as  pertaining to alternatives 4 through  7.

40 C.F.R. 264, Subpart C; Preparedness and Prevention.

40 C.F.R.  241, concerning construction of a RCRA  Subtitle  D land
fill for disposal of nonhazardous wastes.  This is an  action-
specific ARAR for alternatives 3a or 6.

40 C.F.R. 264.340-351, concerning incinerator performance
standards.  A potential ARAR if on-site incineration is
selected.

40 C.F.R. 264 Subpart X.   Describes substantive requirements for
miscellaneous RCRA treatment units,  such as low temperature
thermal desorption.  Pertinent to alternative 6.

 Michigan Hazardous Waste Management Rules.

 Note:  As  with RCRA, these State rules constitute relevant and
 appropriate information, especially  to the degree  that they
 exceed their counterpart  federal  regulations  in substantive
 requirements.    They  are potential  ARARs for  post-closure
 detection monitoring after  remediation  if hazardous wastes
 remain on-site.  Action-specific, for alternatives 2 through 7.
 (Design  may indicate compliance is possible with portions of
 these rules through monitoring necessary to undertake surface
 water and  groundwater restoration measures called  for by Oper-

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                                33

     ble  Units  One  and  Two, respectively.)   Should an Act  64-
     compliant  landfill be selected, pertinent measures from Act 64
     include regulations 299.9619(6) dealing with appropriate means
     of synthetic cap installation, topspil placement, and  drainage
     measures;  299.9619(1) and  (2) dealing  with  synthetic  and clay
     liners, respectively; 299.9619  (3) and (4)  dealing with leak
     detection  and  leachate collection, respectively;  and  299.
     9603(5) which discusses bottom layer thickness and permeability
     characteristics of soils which are to  intervene  between the
     landfill and the top of the groundwater table.

     Part 7, R336.1702; New Sources of VOC  Emissions.

     Note:  This is an ARAR for new sources of VOC emissions for new
     remedial action.  Any person responsible for any  new source of
     VOC  emissions  shall  not cause  or allow the  emission of  VOC
     emissions  from the new source to exceed the lowest maximum
     allowable  emission rates.  A design consideration for
     alternative .6 if treatment is performed on-site, since volatile
     organics are a component of some soils/sediments  and transfer
     from soils to air without proper emission control is not
     appropriate.

    Michigan Environmental  Response Act; Act No. 307

   As discussed above.

Long- Term Effectiveness and Permanence - Through on-site or off-
site containment  measures,  Alternatives 3a,  3b,  4,  and  7 would
provide effectiveness  and permanence by reducing human exposure  via
ingestion  or  direct  contact  to  contaminated  materials,   and by
reducing the amount of water  infiltration  through such materials
thereby aiding in the reduction of amounts of contaminants that may
be  introduced  to the  groundwater below the  site.   For  on-site
alternatives,  long-term maintenance would be required,  and portions
of the cap may need repair in the  future.  Alternative 4 calls  for
off-site landfill usage.  U.S.  EPA  notes that under CERCLA, off-
site disposal  without  treatment is considered  a  least preferred
option for alternatives that otherwise  offer adequate protection
and  comply with ARARs.   Alternatives  5,   6  and  7  may  offer a
superior degree of attainment of this criterion in that they call
for the destruction or  capture of the highest concentrations of the
contaminants.     While employment of  either  a  containment  or
treatment remedy could  result in attainment  of appropriate criteria
concerning degree of risk remaining in  soils  to which site users
could be exposed, a treatment remedy  offers less uncertainty and
greater permanence in the continuing attainment of cleanup criteria
than either institutional control or containment remedies.  This,
in the case of the Alternatives 5, 6 and 7  is accomplished either
through  the  direct destruction  of hazardous  substances  or the
driving off and subsequent destruction of such compounds.  U.S. EPA
notes that site remedies previously selected call for the capture

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                                34

 of the groundwater contamination.  The  excavation and subsequent
 treatment/disposal of  contaminated  materials  will  reduce  the
 ability of such materials to act as a future source of groundwater
 contamination.   An alternative featuring  such source  reduction
 capability   is  therefore   compatible with  remedies  previously
 selected.

 Reduction of Toxicity, Mobility,  or Volume  of the  contaminants
 through Treatment  - Alternative  5,  conventional  incineration,
 offers the highest degree of attainment  of  this criterion in that
 the entire mass of contaminated soil would be subjected to intense
 thermal treatment.  Alternatives 6 and  7 (LTTD and  treatment  of
 certain more highly  contaminated soil  areas)  also attain  this
 criterion, although to a lesser degree.   Although in Alternative 6
 the entire waste mass is to be treated, the intensity of treatment
 is not  as  rigorous as  in Alternative  5.   Treatment  addresses
 principal threats  posed  at the  site,   in  that employment of  a
 technique such as LTTD is expected to result in significant removal
 and subsequent destruction of  site soil  contaminants  such  as
 aniline compounds, 4,4'- DDT,  PCBs, carbon  tetrachloride,  etc.
 Benefits  of  LTTD   employment  as  compared  to   conventional
 incineration  are   less  risk of  generation of  metallic  compound
 emissions, and less risk  of generation of products of  incomplete
 combustion, since  there is  no direct  combustion  of the waste mass
 itself.   Selection of  LTTD at  other sites  indicates  that  this
 technology would appear to  have practicable application.

 Alternatives  3a and  3b,  on-site landfilling  and  capping, and
 Alternative 4, off-site landfilling,  do not provide  for reduction
 of  toxicity, mobility, or volume through treatment.

 Short-Term Effectiveness -  Alternatives 3a through 7  all  have the
 potential  for  exposure  during  excavation  and  construction,
 transport, or  treatment phases.   Instituting  proper health and
 safety and emission control  procedures will aid in minimizing such
 risk,  one possible advantage of Alternatives 3a, 3b, 6,  and 7 when
 compared to Alternatives  4  and 5 is  that they  call for on- site
 handling of  all  or  most contaminated  soils   and  sediments.
 Therefore, there is no risk  of exposure during transportation. The
 on-site  treatment that Alternative 6 envisions may require  a more
 rigorous means of  emissions control  than Alternatives  3a or 3b,
 such as  employment of flaring,  condensation, or carbon adsorption
 techniques for contaminants driven off the soil mass.

 Implementability - Alternatives 3a through 7 are  all considered to
be implementable.   Landfill  capping techniques and  construction or
usage are well established.  U.S. EPA notes that Alternatives 4 and
 5  rely  to  a  large degree on  presumed  existing disposal and
treatment capacity, respectively.  It  is also presumed that vendor
developed mobile equipment  would be  utilized  for  Alternative 6.
Therefore, remedial design efforts in  implementing Alternatives 4,
5 and 6 may be less rigorous than for other alternatives such as 3a

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                                35

or 3b.  Techniques involving on- or off-site treatment should also
be  implementable from  a  technical standpoint;  however U.S.  EPA
cannot predict with certainty as to what degree vendor services and
capacity  at  the time  treatment  is  needed  will  be  available.
Alternative  6 may require further information to be derived  from
pre-design  work prior  to implementation.   Such information  may
focus  on whether all  soils thus treated  should be  heated to  a
common  temperature,  or whether a portion thereof  would be  more
effectively  treated   at   a higher  temperature.    Design   for
Alternative  6  also considers  what proportion of emissions  thus
created from driving contaminants  off the soils should be performed
by flaring,  condensation, or  usage of  carbon adsorption.   These
emission control techniques are considered reliable, and necessary
monitoring can be performed for each.

Cost - The present worths of Alternatives  3a,  3b, 4,  5, 6, and  7
were  estimated  as:  (3a)  $ 4,700,000;  (3b)  $  5,400,000 to  $
11,200,000;  (4)  $ 4,600,000; (5) $ 18,800,000;  (6)  $  6,900,000;  and
(7) $ 7,249,000, at the time of issue of the proposed plan to  the
public.   Based  on  review of  commentary  received,  U.S.  EPA  now
believes  that  the upper-most  cost range  for Alternative  3b ($
11,200,000)  is  more  truly indicative  of  the cost  for on-site
containment without prior treatment,  and that the  present worth of
Alternative  6 is revised to an estimated $ 6,808,000 as discussed
in  the  Documentation   of significant  Chances  section of  this
decision record.  Hence, the selected alternative, Alternative 6,
is  far  less costly  than  either  conventional   incineration or
Alternative  3bf  which  features  containment  only in  an on-site
landfill   taking   into   account  the  possibility   of   risk
underestimation in managing the contaminated soils.   One possible
uncertainty  in  predicting cost  of any alternative is  with the
volume of soil  to be  managed.   With regard to Alternative 6, it
should be noted  that U.S.  EPA  has utilized a  cost per cubic yard
basis at  the high end of  an expected  spectrum of  costs.   As is
noted in U.S. EPA's Responsiveness Summary,  U.S.  EPA has utilized
an estimate  of  $  340  per  cubic  yard  for LTTD  treatment.   The
literature and vendor information suggest a range of from $ 45 to
$ 350 per cubic yard.   Variance in these figures is attributed to
contract terms,  soil moisture content, type of organic contaminant
to be dealt with, and degree of treatment efficiency sought.

State Acceptance - The  MDNR has indicated a decided preference for
low temperature  thermal desorption  treatment  of  the contaminated
soils.  The  MDNR has  also indicated that if  containment of such,
soils without prior treatment were contemplated, an Act  64 type of
landfill with full vertical isolation measures incorporated would
be preferable to an on-site Act 641 landfill.

community  Acceptance   -  Community  acceptance of the  preferred
alternative  has been  evaluated  after  the close  of  the  public
comment period  and is  described  in  the Responsiveness  Summary
portion of the ROD.  The public responded negatively to the

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                                36

 creation of landfills in the Muskegon area.  The public's reaction
 to the suggestion of the possibility of combined response action at
 Muskegon area  CERCLA sites  was mixed; the public did not advocate
 combined response action involving the Ott/Story/Cordova and Bofors
 sites,  but  did advocate  combined  response action between  the
 Ott/Story/Cordova and Duell & Gardner sites especially in the area
 of contaminated soils.  It should be noted that the Ouell & Gardner
 proposed plan called  for dealing  with  portions of  contaminated
 soils  at  that site through  usage of   low  temperature  thermal
 desorption treatment followed by  management of residuals and site
 closure through placement of an Act 641-compliant cover  over that
 site.   The public  sent 10  letters to U.S.  EPA urging  that  some
 manner of treatment technology be utilized, as opposed to landfill
 utilization.


 9.  Documentation of Significant  Changes

 U.S. EPA has reviewed  and  responded to  all significant  comments
 received from interested parties during the public comment period.
 Comments were made on the alternative indicated as preferred in the
 Proposed Plan  as well  as  other alternatives.  Based on  review of
 these comments, the U.S. EPA has determined that there should be a
 significant change made in the alternative  selected.   At the  time
 of the release of U.S.  EPA's Proposed Plan to the public,  U.S.  EPA
 indicated that Alternative 3a was the preferred alternative.   This
 alternative  includes construction  of an on-site  landfill  with
 subsequent excavation and  disposal of contaminated soils/sediments
 therein, capping, monitoring,  restriction of further  land usage,
 security measures,   maintenance,  clean   fill placement.   After
 evaluation  of  the  comments  received,  and  a  review  of   the
 alternatives using the nine evaluation  criteria,   U.S.  EPA now has
 a preference for Alternative 6,  as set forth in the Proposed Plan,
 with  slight  modifications  thereto.     Alternative   6   involves
 excavation of  contaminated  soils/sediments,  treatment on site by
 means of low temperature thermal desorption, monitoring, usage of
 treated soils  which successfully  attain  soil cleanup criteria as
 on-site backfill material, and transport  of residue not  attaining
 soil cleanup criteria  to  an appropriate  off-site facility, with
 imposition of land-usage restrictions as  appropriate.

 Compared to either Alternative 3a or 3b,  Alternative 6 provides a
 shorter  estimated  implementation  time,   provides   for  superior
 reduction of toxicity, mobility, or volume of hazardous substances,
provides for  a superior  degree  of long-term effectiveness  and
permanence,  and  appears  to be  far  more  cost-effective  than
Alternative  3b.     Alternative  6  provides  superior  short-term
effectiveness in that the  amount of  time necessary to complete the
remedial design is less than Alternative 3a or 3b.  There is also
a higher degree of state and community acceptance  of LTTD treatment
as opposed  to construction of a landfill.

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                                37

U.S.  EPA makes  note of  certain  public  comments  received which
argued  that untreated  contaminated  soils should  be disposed of
within  a  landfill structure attaining the more rigorous Michigan
Act  64  criteria, due  to the presence  of tentatively identified
compounds within the soils.  These tentatively identified compounds
appeared  to include  substances  which  are  used as  a herbicide,
pesticide, or which have a chemical structure featuring the cyanide
grouping.  Some commentary suggest that certain site soils may be
characteristically  hazardous.  Discarded  chemicals were known to
have been improperly land disposed on the property.  Since relevant
and appropriate criteria associated with the construction of an Act
64 compliant  landfill call for,  among  other measures,  a 20 foot
thick layer of  compacted clay beneath the landfill and above the
groundwater  table,  the  cost  of  appropriate  on-site  landfill
construction  is  at the high end,  i.e., $ 10-11  million,  of U.S.
EPA's estimate for construction of such an on-site hazardous waste
landfill.  While U.S. EPA may elect to waive a given ARAR, it may
not  be  appropriate to  do  so  in  this instance  because of  the
relatively high groundwater table  at the Ott/Story/Cordova site.

As noted in the supplement to the FS and the  proposed plan, it was
assumed that  soils which did not achieve soil  cleanup criteria
after  initial treatment by low  temperature thermal  desorption
(LTTD) would undergo more rigorous treatment through incineration
in an effort to achieve cleanup criteria.  Hence, capital costs for
the  LTTD alternative  in  the  proposed  plan  include costs  for
treatment by incineration for the 25% of contaminated soil volume
which was estimated not to attain soil cleanup criteria after LTTD
treatment.    The  supplement   to  the   FS   estimates  off-site
incineration costs as $ 2,952,000.   Comment received by the State
of Michigan indicates that  application of LTTD technology should
provide an acceptable degree of treatment  such that soil residuals
not attaining  soil cleanup criteria will have  attained a sufficient
degree of treatment such that placement  in  an Act 641 compliant
landfill would be acceptable.  This comment appears  to be supported
by treatability information which appears  in the Ott /Story /Cordova
record which was  obtained from studies  performed  at  the Anderson
and  Duell  &  Gardner  sites.   In  both  those  instances,  LTTD
application resulted in 90-99% removal of organic compounds.   The
99% removal rate was achieved at  the Duell  & Gardner site.  Because
of the  similarity  of  soil characteristics  between  the Duell  &
Gardner and Ott /Story /Cordova sites (the sites are both located in
Dalton Township, only a  few miles apart) ,  U.S. EPA has reason to
believe similar removal efficiencies could be  realized through LTTD
application  at   the  Ott/Story/Cordova   site.      In  removing
contaminants with this degree of efficiency,  U.S. EPA concurs with
the  State's  assertion  that subsequent  management  after  LTTD
application could  be conducted  in accordance with  solid  waste,
rather than hazardous waste, regulations.

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                                38

 Deleting the incineration cost, and  adding in a  disposal fee of
 approximately $ 25/cubic yard for usage of a commercially available
 Act 641 compliant landfill results in revised  cost estimates for
 the LTTD alternative as shown:

                          Previous  Estimate   Revised Estimate

 option subtotal           $ 7,575,950          $  4,683,950

 -i-bid contingency  (8%)         606,075              374,716
 +scope contingency  (15%)   1.136.390              702.592

 construction  cost          9,318,415            5,761,259

 +permit/legal (5%)            465,920              288,063
 +construction service (5%)    465.920              288.063

 implementation costs     10,250,255            6,337,385

 +design costs                512.515              316.869

 total capital costs       10,762,770            6,654,254

 +O  &  M COStS                  154.000              154.000

 present net worth         10,919,800            6,808,254

 As noted in the proposed plan, were an on-site landfill to be built
 so as to fully comply with all aspects of Michigan Act 64,  capital
 costs would be approximately $ 10,400,000.   Allowing for operation
 and maintenance costs present worth would total approximately
 $ 11,200,000.   Hence, assuming that  more  intensive  treatment of
 those  soils  which do not fully attain  soil  cleanup criteria is
 unnecessary,  LTTD treatment  followed  by  usage of  a  less  rigorous
 landfilling  option  would appear  to  be  a  distinctly more  cost-
 effective  form  of remediation  as  opposed  to disposal  in a more
 rigorously designed  on-site  landfill.   Upon review of  comments
 received,  and  in   light  of  the  existence  of  TICs  and the
 observations  made during test pit  excavation, U.S.  EPA concludes
 that untreated contaminated soils, if landfilled on site, should be
 put in a hazardous waste landfill.  After considering LTTD results
 at the Anderson and Duell & Gardner sites, U.S. EPA  has reason to
 believe that a significant amount of contaminated soils will attain
 soil cleanup criteria after LTTD treatment at the Ott/ Story /Cordova
 site such that designing an on-site landfill for this lesser volume
would be impractical and not cost effective.  Because of the high
 level of removal efficiency realized in LTTD testing at the  Duell
 & Gardner  site,  and  the proximity of that site  as well as its
similar    soil    and   contaminant   characteristics   to   the
Ott/Story/Cordova  site,  U.S.  EPA  presumes  that,  after  LTTD
treatment, soils not fully attaining soil cleanup  criteria can be
managed off-site in an Act 641 (nonhazardous) landfill.

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                                39

 In the event that additional data or information during the design
 of  the remedy reveals  the need for  modification,  U.S. EPA  will
 notify the public  of any changes to the remedy presented  in  this
 ROD  in accordance with  applicable  law and  Agency  guidance.

 10.    Selected Remedy

 The selected alternative for the third Operable Unit is Alternative
 6.      Alternative   6   involves   excavation   of   contaminated
 soils/sediments, treatment on site by means  of  low  temperature
 thermal  desorption,  monitoring,   usage  of  treated  soils which
 successfully attain soil cleanup criteria as on-site fill material,
 and transport of residue not attaining soil cleanup criteria to an
 appropriate  off-site  facility,   with  imposition  of  land-usage
 restrictions as appropriate.

 Alternative 6 provides a high degree of long-term effectiveness and
 permanence and is compatible with remedies previously selected.

 Based on the current information,  this alternative would appear to
 provide the best balance or trade off among the alternatives with
 respect  to the  nine criteria  that  U.S.   EPA uses  to evaluate
 aIternatives.

 The selected alternative would be protective of human health and
 the  environment, and would comply  with  all ARARs.   The  goal of
 Operable Unit Three is to bring about the disposal  and treatment of
 those soils and sediments  which  pose unacceptable risks to human
 health and the environment.  The selected remedy utilizes permanent
 solutions  and  alternative treatment technologies,   not  solely
 because of  the  need  to  provide  treatment of  a  principal threat
 involving  risk  to  human health or  the environment,  but rather
 because usage of treatment techniques in this instance appears to
 result in  selection of  a more cost-effective  remedy rather than
 usage of containment measures only.  Due to certain characteristics
 of this  site,  specifically  the high  groundwater table  and  the
 possibility for underestimation of risk, selection of a treatment
 technique  to manage most  of the contaminated  soils/sediments
 appears warranted.

 Some changes to  this alternative may result due to normal remedial
 design and construction  processes.   For  example,  items which are
 physically  incompatible  with the LTTD process,   such  as  the
 introduction of excessively  large drum  fragments,  discarded  lab.
 bottles, or potential highly concentrated waste forms - as opposed
 to  contaminated soils  -  should  likely  be  placed  in  overpack
 containers and subsequently managed in accordance with pertinent
waste regulations.

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                                40

 11.   Statutory Determinations

 Protection of  Human Health and the Environment

 The soils  and sediments associated with the OTT/STORY/CORDOVA site
 have  been degraded  through  the  introduction  of  contaminants
 associated with former material or product usage activity  at the
 site.   At least a  portion of the soils and sediments pose  an
 unacceptable risk to potential site users, with excess cancer risks
 greater than  1  x  10"4  for  future site workers.   The  toxicity
 results of vegetative   root  elongation  and  Microtox testing
 performed  on soil samples collected in  areas of sparse vegetation
 when  compared  to background sample conditions  also  indicate that
 the site as it exists may pose an  environmental risk.

 The selected remedy protects human health and the environment with
 regard to contaminated soils.   The excavation of these contaminated
 areas and the subsequent treatment/containment of such contaminated
 soil/sediments utilizing techniques of appropriate design will aid
 in reducing contaminant  levels and assist in  preventing  exposure
 above acceptable levels.   Monitoring and institutional  controls
 will  also  promote the  evaluation of effectiveness of  remediation
 measures.

 Implementation of the remedy will not pose unacceptable short-term
 risks or cross-media impacts.   With regard to risk to human health,
 the selected remedy will  reduce levels  of risk to potential  users
 of the soils/sediments  such that levels of protection as called for
 through achievement of Michigan Act 307 Type B cleanup criteria are
 attained.   With  regard  to protection  of  the  environment, the
 selected remedy  will eliminate undue toxicity to life forms now
 posed by soil conditions.

 Chemical and biological monitoring  so as to assure the attainment
 of soil/sediment cleanup  criteria and toxicity  reduction goals in
 the surface and near surface site soils will be  a necessary part of
 ensuring the achievement  of these goals.

 Compliance with Applicable or Relevant and Appropriate Requirements
 rARARsl

 The selected remedy  is required to fully comply with all federal
 and more stringent  state ARARs unless a waiver is  invoked.   The
 selected remedy complies with all ARARs. With  regard to soils and
 sediments,  the selected remedy has as its goal the  attainment of
 all soil cleanup criteria as  determined by  Michigan Act No. 307,
 and the attainment  of  all federal/state  ARARs concerning the
management and handling of waste materials.  The selected remedy
therefore will be in conformance with CERCLA Section 121.

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Cost Effectiveness

The selected remedy affords overall effectiveness proportionate to
its  cost.   The  remedy promotes the  attainment  of  soil cleanup
criteria.    Alternative   6  is  far   less  costly  than  either
conventional  incineration  or  Alternative  3b,  which  features
containment only in an on-site landfill.

Utilization  of  Permanent  Solutions  and  Alternative  Treatment
technologies  or  Resource  Recovery  Technologies to  the Maximum
Extent Practicable

The remedy selected provides  the best  balance of tradeoffs among
the alternatives considered with  respect to  the nine evaluation
criteria.  The  selected remedy utilizes permanent  solutions and
alternative treatment technologies.   The  site poses unacceptable
risks with regard to soils/sediments,  and U.S. EPA perceives that
the presence of numerous tentatively identified compounds as well
as compounds for which no  pertinent slope  factors exist may have
resulted in an underestimation of risk to human health.    There
appears to have been some  demonstration of  environmental risk as
well.    Given  the  number  of tentatively  identified  compounds
detected in site soils, the high groundwater table at the site, the
likelihood that certain treatment techniques may be brought to bear
on site soils  at less cost than certain "contain-only" options, it
appears  prudent  to  select  a remedy   featuring such  treatment
techniques for most contaminated  site  soils/sediments.

The MDNR has  been  consulted  during development of the  site FS,
proposed plan,  and participated in the public comment period.
Community views were solicited during the public comment period.
U.S.  EPA  attempted to  keep the  community  informed  of  site
developments  via the local information repositories and by the
local establishment  of  certain documents  in  the administrative
record for this  site  prior  to  the  commencement of the  public
comment period.

Preference for Treatment as a Principal Element

The alternative selected,  Alternative  6, features treatment of
contaminated  soils  as a principal element  of the remedy utilizing
the technique of  low temperature thermal desorption.

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