PB95-964104
EPA/ROD/R05-95/276
February 1996
EPA Superfund
Record of Decision:
Rockwell International Site,
Landfill Contents O.U., Allegan, MI
7/11/1995
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Landfill Contents Operable Unit,
Rockwell International Site, Allegan, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Landfill Contents
Operable Unit of the Rockwell International Site, in Allegan, Michigan, which was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act
(SARA) of 1986, and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the administrative record for
this Site.
DESCRIPTION OF THE SELECTED REMEDY
U.S. EPA has selected "No Action" for the Landfill Contents Operable Unit.
DECLARATION
U.S. EPA has determined that the Landfill Contents Operable Unit does not pose a current
or potential threat to human health or the environment. Remaining Site areas, including
groundwater and the Kalamazoo River adjacent to the Site, will be addressed in a separate
record of decision (ROD).
As this is a decision for "No Action," the statutory requirements of CERCLA Section 121
for remedial actions are not applicable for the Landfill Contents Operable Unit and no five
year review will be undertaken.
STATE CONCURRENCE
The State of Michigan concurs with the Selected Remedy. The Letter of Concurrence is
attached to this ROD.
0
y
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TABLE OF CONTENTS
I. Site Name, Location and Description
II. Site History and Enforcement Activities
III. Highlights of Community Participation
IV. Scope and Role of Operable Unit
V. Summary of Landfill Conditions
VI. Health Risk Assessment
VII. Environmental Risk
V1H. Risk Summary
IX. Documentation of Significant Changes
X. Statutory Determinations
Responsiveness Summary
Glossary
State Letter of Concurrence
Administrative Record Index
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DECISION SUMMARY
I. SITE NAME. LOCATION AND DESCRIPTION
The Rockwell International site is a former drive line manufacturing facility located at 1
Glass Street in Allegan, Michigan (Figure 1). The site occupies approximately 30 acres in
an industrially-zoned area and is bound on the north and northwest by the Kalamazoo River;
to the east by private residences and River Street; on the south by private residences and
North Street; and to the southwest and west by vacant, low-lying land and u^e City of
Allegan municipal wastewater treatment plant. North Ward Elementary school is also
located east of the site, east of River Street.
Buildings and facilities at the site (Figure 2) include two former manufacturing/assembly
buildings (east and west buildings), a former heat treatment building, east and west parking
areas, an unused grassy field, and Rockwell's former industrial wastewater treatment plant
consisting of a control house building and three inactive wastewater treatment ponds.
In 1991, the western portion of the site, including the west manufacturing building,
Rockwell's wastewater treatment plant and ponds, and the west parking area, were sold. The
west manufacturing building and parking area are currently occupied by light industrial
operations, however, the Rockwell wastewater treatment plant has been dismantled and the
ponds are not in use. Operations in the eastern portion of the site, including the east
manufacturing building and the heat treatment building, were discontinued in 1992. These
buildings were sold in 1995 and are currently occupied by light industry.
Located at and adjacent to the southwest corner of the Rockwell International site is the
former City of Allegan municipal landfill (Figure 3). The landfill occupies approximately 11
acres. Approximately two-thirds of the landfill is covered by the City of Allegan wastewater
treatment plant (2.5 acres), a maintained lawn (0.5 acres), and an unpaved parking lot (4
acres). The remaining portion of the landfill occupies approximately 4 acres of vacant,
vegetated, low-lying land south of North Street that is poorly drained and frequently covered
by areas of standing water. The landfill property is currently zoned for and expected to
remain under industrial use. The City of Allegan has also proposed to expand their
wastewater treatment plant facilities over approximately 2 acres of the unpaved parking lot
area.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Operations at the Rockwell International site began in approximately 1901 with the
manufacture of glass. In 1916 the facilities at the site were sold and thereafter operated for
the machining and assembly of automotive drive line parts until 1992. Materials known to
be used in the drive line manufacturing operations at the site include carbon steel, welding
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A
ALLEGAN
SCALE. FTET
SITE LOCATION
MAP
ROCKWELL INTERNATIONAL SIT
ALLEGAN, MICHIGAN
-SGS ~ 1 MINUTE TOPOGRAPHIC 3UAORANGLE.
. MICHIGAN. GATED 1981.
S-CALE '.2*000.
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FIGURE 2
SITE MAP
ROCKWELL INTERNATIONAL SITE
ALLEGAN, MICHIGAN
CITY OF
! ALLEGAN
LANDFILL
CITY OF ALLBOAN
. WAJTBWATU
TIIATMIHT PLANT
I
I
APPROXIMATE .SITE
BOUNDARY/PROPERTY I INI
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FIGURE 3 V
LANDFILL AREA
ROCKWELL INTERNATIONAL
ALLEGAN, MICHIGAN
I
\ APPROXIMATE EXTENT
OF LANDFILL
(EST. 11 ACRES)
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rods and flux, soluble and non-soluble cutting and quenching oils, cleaning agents and
solvents, heat treatment chemicals and maintenance paints.
The manufacturing process at the site generated two types of waste streams: contact
quenching fluids and contact cutting fluids. In general, these waste streams contained
lubricants, emulsifiers. oxidation inhibitors, cleaning compounds, treatment compounds,
metal filings and metal salts.' From 1916 to approximately 1945, process wastewaters from
the plant were discharged to the Kalamazoo River. In 1945 an oil floatation house was built
to intercept and recover the oil fraction of the wastewater. During the 1960s, however, the
oil floatation system was no longer adequate and several overflows of oil were observed in
the Kalamazoo River.:>3 An interview with plant personnel and U.S. EPA's analysis of an
aerial photograph of the site in 1955 also indicate that wastewater from the plant was
discharged to the backwater area of the Kalamazoo River behind the plant.4-3 This area was
subsequently filled and is now used for other purposes» however, oily deposits and metal
fragments were detected below the water table in a soil boring collected within this area at
location P-14 (Figure 4).
From approximately 1964 to approximately 1972, water soluble wastes were discharged to
two unlined ponds adjacent to the river. When the use of each pond was discontinued, the
pond was filled to surface grade and built over. In 1972 a plant was constructed to treat the
plant's wastewater. Following treatment, the treated wastewater would discharge to a series
'National Priorities List Ranking Hazardous Ranking Score Package. December 19,
1984, Reference No. 18: Conversation record of William Sebright, Environmental Control
Technician. Rockwell Allegan Plant, Phil Backlund, Environmental Engineer, Rockwell, and
Paul Hess, Field Investigation Team Leader, Ecology and Environment, under contract to
U.S. EPA, regarding "History of Allegan Plant," June 20, 1984.
2Waste Disposal. Allegan. Michigan. Proposal Desien Report. March, 1971, Prepared by
E. E. Paulson, Plant Engineer, Approved by S. L. Cams, Factory Manager.
3Michigan Water Resources Commission Memorandum from J. Pope to R.J. Courchaine
and Files, Re: Rockwell Standard Corporation Allegan. December 1, 1965.
'National Priorities List Ranking Hazardous Ranking Score Package. December 19,
1984, Reference No. 18: Conversation record of William Sebright, Environmental Control
Technician, Rockwell Allegan Plant, Phil Backlund. Environmental Engineer, Rockwell, and
Paul Hess, Field Investigation Team Leader, Ecology and Environment, under contract to
U.S. EPA, regarding "History of Allegan Plant," June 20, 1984.
5Aerial Photographic Analysis of the Rockwell International Site. Allegan. Michigan.
U.S. EPA, 1986.
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Liquid Waslc Dumping Point
Idem.ded by U.S. EPA -
Liquid Wasie Identified
by U.S. EPA
1 M.IICAN Ii9sa)l
'
APPKOXIMAIt SHE BOUNOASr
CONil/UlHV,
POOCH
SUBSIAIION
!"•!' I)
FIGURE 4
fACItirr CONHCIINAllUN
HiUIUUI INVt^MGAIIOII/M 4MUUIII
AKlftM. U1CHIL«M lACIIIIr
HOCK W[ 1 1 INICRNAIIOHA1
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of three newly constructed ponds and then to the Kalamazoo River under a National Pollutant
Discharge Elimination System (NPDES) permit.
In the early 1970s, oil seepage was observed along the east bank of the Kalamazoo River
adjacent to one of the three wastewater treatment ponds. In 1974, a shallow clay barrier was
installed along the length of the pond to prevent the seepage. The seepage continued, and
further investigation indicated that two underground equalization tanks in the wastewater
treatment plant were leaking. In 1976 the underground tanks were cleaned and lined with an
impermeable liner, and three oil recovery wells were installed near the tanks to recover the
oil and potentially impacted groundwater. Operation of the oil recovery wells was
discontinued in 1992 when the western portion of the site was sold and the wastewater
treatment plant was dismantled.
t
In 1984, a U.S. EPA field investigation team conducted a site inspection and collected
groundwater samples from one of the oil recovery wells, and sediment samples from the
Kalamazoo River adjacent to Rockwell's NPDES outfall. Arsenic and 4-methylpentanone
were detected in the groundwater samples, and elevated levels of arsenic, chromium, 4-
nitrophenol, chrysene and pyrene were detected in the sediment samples adjacent to the
outfall.
In 1985, U.S. EPA proposed the Rockwell International site for inclusion on the National
Priorities List (NPL), and in 1987 the site was officially placed on the NPL and designated a
Superfund site. An Administrative Order by Consent to conduct the remedial
investigation/feasibility study (RI/FS) was signed by Rockwell in 1988, and the RI/FS was
initiated in 1989. The first phase of the RI was completed in 1990, and, based on the
results, a second phase of work was initiated in 1992. The second phase of work was
completed in 1993, and the RI/FS reports are in progress. Based on historical records and
other information and data collected during the RI, the potential areas of contamination at the
site include Rockwell's wastewater treatment plant and ponds, the two buried unlined ponds,
an area of former metal chip washing operations and a former oil floatation house, and the
former City of Allegan municipal landfill.
The former City of Allegan municipal landfill is located in the southwest corner of the
Rockwell International site beneath the west parking area, and extends beneath the City of
Allegan municipal wastewater treatment plant and grounds, and the low-lying, vacant
property south of North Street. The landfill was not identified as an area of potential
concern in the National Priorities List package for the site, however, approximately 4 acres
of the landfill purchased by Rockwell from the City in 1956 for use as the west parking area
were included as pan of the site in the NPL listing and have undergone limited investigation
during the RI. The landfill was briefly mentioned in the Administrative Order by Consent
with Rockwell for the RI/FS, and listed as one of six areas of potential contamination and
investigation in the RI/FS workplan.
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Final characterization of all site areas other than the former City of Allegan municipal
landfill, including groundwater and the Kalamazoo River adjacent to the site, is currently in
progress.
ffl. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The attached Responsiveness Summary discusses the involvement of the community during
the RI/FS and the remedy selection process for the Landfill Contents Operable Unit, and
shows that the public participation requirements of CERCLA Sections 113(k)(2)(i»v) and 117
of CERCLA have been met at this site. The decision is based on the Administrative Record.
IV. SCOPE AND ROLE OF OPERABLE UNIT
This Record of Decision (ROD) for the Landfill Contents Operable Unit addresses the
contents of the former City of Allegan landfill. The remaining areas of the site, including
groundwater and the Kalamazoo River adjacent to the site, will be addressed in a separate
ROD.
V. SUMMARY OF LANDFILL CONDITIONS
As shown on historical aerial photographs (Figure 5), the northwest-west portion of the
Rockwell International site and area south of the site, including the landfill, was formerly a
low-lying backwater area of the Kalamazoo River. From approximately 1950 to 1974, the
City of Allegan operated a municipal landfill in the southern portion of the backwater area
north and south of North street. Fill materials encountered in soil borings collected
throughout the landfill primarily consist of sand, gravel, and concrete debris. The City of
Allegan also reportedly burned municipal waste in the southern portion of the former
backwater area, and residues from burning could be mixed with the landfilled material.
Black-stained sands encountered in the landfill may also indicate the disposal of foundry
sand.
Oily deposits, irregular black staining, metal fragments and wire pieces were also found in
the landfill below the water table at two locations (soil borings MW-6 and P-12). These oily
deposits and metal fragments compare to similar findings encountered below the water table
at similar elevations in a soil boring collected in the former backwater area behind the
Rockwell plant (P-14). These soil boring results, in conjunction with the information
obtained from plant personnel and U.S. EPA's time-series analysis of historical aerial
photographs of the site, indicate that some portion of the landfill was operated over areas
previously impacted by manufacturing operations at the site prior to landfilling. These
impacts occur below the water table, however, and, as such, are considered to be part of the
saturated zone and will be evaluated with groundwater.
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tRDON f. JONES, P.
1HSULTING ENSINeeR
\LAMAZOO, MICHIGAN
FIGURE 5
CITY Of ALLE9AN
1949 AERIAL MAPPING
SHOWING RtVER FLQODPLAti
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The surface of the landfill is generally flat and at grade with the surrounding area, however,
the depth of the landfill varies with the base of the former backwater area, ranging from
approximately 25 feet below ground surface in the northern portion of the landfill to 8 to 9
feet below ground surface (ft-bgs) in the southern and western portions of the landfill.
Because the landfill materials were deposited within a low-lying backwater area and
subsequently filled to surface grade, the majority of the landfill contents (an estimated 50 to
80 percent based on soil boring logs) are now below the water table and constitute pan of the
saturated zone. The depth to the water table in the landfill ranges from approximately 4 ft-
bgs north of North Street to approximately 2 ft-bgs south of North Street. (Figure 6).
As part of the RI, a total of 18 surface and shallow subsurface samples were collected from
the landfill contents at depths ranging from 0-0.05 ft-bgs to 4-6 ft-bgs to horizontally and
vertically characterize *the contents of the landfill (Figure 7). Four samples (MW-15-001,
MW-16-001, P-19-001 and GS-004) were collected from 0 to 0.5 ft-bgs to characterize the
landfill materials at the surface of the landfill; nine samples (SB-1 through SB-8 and MW-16-
002 were collected from 2 to 4 ft-bgs to characterize shallow subsurface landfill contents in
the unsaturated zone; and five samples (MW-15-002, MW-15-003, MW-16-003, P-19-002
and P-19-003) were collected from 2 to 4 ft-bgs (-002 series) and 4 to 6 ft-bgs (-003 series)
and characterize materials at or near the water table which are likely to fluctuate between
saturated and unsaturated conditions. Eight of the 18 samples (SB-1 through SB-8) were
specifically clustered in the area of the proposed wastewater treatment plant expansion.
Samples of the landfill contents were also collected from MW-6, MW-7, MW-8 and P-12,
however, these samples were collected below the water table and at depths greater than 6 ft-
bgs, and, as such, are considered to be pan of the saturated zone and will be evaluated with
groundwater.
The analytical results for the landfill contents sampling are summarized in Table 1 and
indicate that several organic and inorganic chemicals are present in the landfill contents.
These include volatile organic compounds (VOCs), semi-volatile organic compounds
(SVOCs), pesticide and poiychlorinated biphenyl (PCB) compounds, and inorganic
compounds such as metals. The. results of the landfill contents investigation are documented
in the Risk Assessment for the Landfill Contents Operable Unit. Additional details
concerning the conditions of the landfill contents may be found in the Risk Assessment.
VI. HEALTH RISK ASSESSMENT (See Glossary for definitions of terms used in
this section)
Based on analytical data collected during the RI, a risk assessment for the landfill contents
operable unit was performed using contaminants detected in the landfill contents. The risk
assessment is a baseline risk assessment and assumes no corrective action will take place at
the landfill, and that no site-use restrictions or institutional controls such as fencing or
construction restrictions will be imposed. The risk assessment for the landfill contents
determines actual or potential carcinogenic risks and/or toxic effects the chemical
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FIGURE 6
GROUNDWATER ELEVATION CONTOURS
ROCKWELL INTERNATIONAL SITE
ALLEGAN, MICHIGAN
ROCKWELL1 WWU
BUHWMC j —-'
fORWCH
DRIVE-LINE
ASSCMBLY
B
CONSUMERS
POWER SUeStJAIION
APPROXIMATE
SITE BOUNDARY/PROPERTY LINE
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BOUNDARY/PROPERTY UNE^
\ HGURE 7
( SAMPLE LOCATIONS
^ LANDFILL CONTENTS OPERABLE UNT
ROCKWELL INTERNATIONAL SITE
ALLEGAN, MICHIGAN
rtrr
* i v
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TABLE 1
SUMMARY OF LANDFILL CONTAMINATION
CHEMICAL
MAXIMUM CONCENTRATION IN LANDFILL
CONTENTS'
VOLATILES
Acetone
2-Butanone
Chlorobenzene
Chloroform
Methylene Chloride
Toluene
SEMFVOLATILES
Acenaphthene
Acenaphihylene
Anthracene
Benzo(a)anthracene
Benzo
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CHEMICAL
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Sulfur
Vanadium
Zinc
Cyanide
MAXIMUM CONCENTRATION IN LANDFILL
CONTENTS'
(mg/kg)
9030
14.7
18.4
436
0.59
4.2
88400
85.6
6.6
379
36100
1150
33100
1410
1.3
31.9
270
8.4
4.1
408
1.8
24.4
1100
2.6
;. Based on Landfill Contents Samples SB-1 through SB-8; MW-15-001, MW-15-002. MW-
15-003; MW-16-001, MW-16-002, MW-16-003; P-19-001, P-19-002, P-19-003; and GS-004.
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contaminants detected in the landfill pose under current and future land use assumptions
using a four step process. The four step process includes: contaminant identification, health
effects assessment, exposure assessment and risk assessment.
A) Contaminant Identification
The levels of contamination found in the landfill contents can be found in Part I, Section 2.2
of the risk assessment for the landfill contents operable unit. Indicator parameters, or,
chemicals of potential concern for the landfill contents were selected based on their toxicities
and level of concentration. For the landfill contents, a chemical was considered to be a
chemical of potential concern if it was detected in any landfill contents sample at a
concentration above the Michigan Department of Natural Resources (MDNR^health-based
criteria for unrestricted land use (formerly the MDNR Act 307 Type B criteria). The
chemicals of potential concern in the health evaluation for the landfill contents include:
2-Methylnaphthalene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Arsenic
Lead
Manganese
B) Health Effects
The health effects for the contaminants of concern for the landfill contents are summarized
below:
2-Methylnaphthalene - 2-Methylnaphthalene belongs to a class of chemicals known as
polycyclic aromatic hydrocarbons (PAHs). PAHs occur in the environment as complex
mixtures of products of incomplete combustion. 2-methylnaphthalene has not been given a
weight-of-evidence carcinogenicity classification. Limited information shows that 2-
methylnaphthalene has caused changes in the trachea or bronchi in mice, and sister chromatid
exchanges in human lymphocytes.
Benzo(a)anthracene, Benzo(a)pyrene and Benzo(b)fluoranthene - Benzo(a)anthracene,
benzo(a)pyrene and benzo(b)fluoranthene are also polycyclic aromatic hydrocarbons (PAHs).
These chemicals are classified as probable human carcinogens (Class B2). Cancer associated
with exposure to PAH-containing mixtures in humans occurs predominantly in the lungs and
skin. Benzo(a)anthracene, benzo(a)pyrene and benzo(b)fluoranthene are harmful if
swallowed, inhaled or absorbed through skin, and may cause eye and skin irritation.
Chronic exposure to benzo(a)anthracene, benzo(a)pyrene and benzo(b)fluoranthene may alter
genetic material; skin and lungs are major target organs.
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Arsenic - Arsenic is a known human carcinogen (Class A). Oral exposures to arsenic are
associated with skin cancer; inhalation exposures are associated with lung cancer. Acute
exposure of humans to arsenic can cause muscular cramps, facial swelling, cardiovascular
reactions, severe gastrointestinal damage, and vascular collapse leading to death. Sensory
loss and hematopoietic symptoms delayed after exposure to high concentrations are usually
reversible. Inhalation exposures can cause severe irritation of nasal lining, larynx and
bronchi. Chronic oral or inhalation exposure can produce changes in skin; peripheral
neuropathy; liver injury and cardiovascular disorders. Oral exposures are associated with
peripheral vascular disease and blackfoot disease.
Lead - Lead is classified as a B2 carcinogen, which means there is sufficient evidence of
carcinogenicity from lead in animals but limited evidence of carcinogenicity ia humans.
Acute lead intoxication in humans is characterized by encephalopathy, abdominal pain,
hemolysis, liver damage, renal tubular necrosis, seizures, coma and respiratory arrest.
Chronic low levels of exposure to lead can affect the hematopoietic system, the nervous
system and the cardiovascular system. Lead inhibits several key enzymes involved in heme
biosyntheses. A characteristic effect of chronic lead intoxication is anemia. In humans, lead
exposure has resulted in nervous system injury including reduced eye-hand coordination,
reaction time, visual motor performance and nerve conduction velocity. The developing
child appears especially sensitive to lead-induced nervous system injury. Lead can also affect
the ir""i""g system. Human studies have indicated that chronic lead exposure may be
associated with increased blood pressure. Chronic exposure to lead is also associated with
sterility, abortion, neonatal mortality and morbidity.
Manganese - The weight-of-evidence carcinogenicity classification for manganese is class D,
which indicates that existing studies are inadequate to assess the carcinogenicity of
manganese. Acute inhalation exposure to manganese can cause manganese pneumonitis.
Chronic inhalation of manganese results in psychiatric symptoms such as irritability,
difficulty in walking, speech disturbances and compulsive behavior, and by encephalopathy
and progressive deterioration of the central nervous system. Chronic effects of manganese
poisoning are similar to Parkinson's disease. Liver changes are also frequently seen.
Q Exposure Assessment
The baseline risk assessment for the landfill contents operable unit examined potential routes
by which humans could be exposed to contaminants detected in the landfill. The exposure
routes selected for detailed evaluation for the landfill contents include:
Dermal contact with the landfill contents,
Ingestion of the landfill contents, and
Inhalation of the landfill contents.
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The potential exposure routes of dermal contact, ingestion and inhalation of the landfill
contents were also evaluated in terms of potential exposure scenarios. For the landfill
contents operable unit, the above routes of exposure were evaluated for the following
selected exposure scenarios:
commercial/industrial,
construction, and
trespasser (adult and older child).
For each scenario, it was assumed that workers and trespassers could be exppsed to any
landfill materials aboye the water table. The risk evaluation also assumes that any future
construction activities would not include any excavation below the water table.
Because the landfill is currently zoned for and expected to remain under industrial use, a
future residential scenario was not considered to be a complete exposure pathway for the
landfill contents operable unit, and was not evaluated. Similarly, the exposure pathway for
young children (ages 1-6) as trespassers is also considered incomplete based on the likelihood
of adult supervision and was not evaluated.
D) Risk Characterization (see glossary for a discussion of risk terms used in
this section)
For each potential human receptor, site-specific contaminants from all relevant routes of
exposure were evaluated. Both non-carcinogenic health effects and carcinogenic risks were
estimated.
1. Non-Carcinogenic Health Risks
The noncancer hazard for human exposure to the landfill contents under each of the
exposure scenarios is calculated as follows:
Exposure Scenario Hazard Index
Commercial/industrial worker 0.04
Construction worker 0.21
Adult trespasser 0.04
Child trespasser 0.12
A hazard index of less than 1.0 for an exposure scenario indicates that the calculated
intake of chemicals under that scenario would not exceed the established references
doses for those chemicals. Exposure to the contaminated media would therefore not
result in any unacceptable noncancer human health effects.
8
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2. Carcinogenic Health Risks
The excess lifetime cancer risk calculated for human exposure to the landfill contents
under each exposure scenario is calculated as follows:
Exposure Scenario Cancer Risk
Commercial/industrial worker 5E-06
Construction worker 3E-06
Adult trespasser 4E-06
Child trespasser 5E-06
U.S. EPA generally attempts to reduce the excess lifetime cancer risk posed by a
Superfund site to a range of 1E-04 to 1E-06 (1 additional case of cancer for every
10,000 individuals exposed to 1 additional case of cancer for every 1,000,000
individuals similarly exposed), with emphasis on the more protective end (1E-06) of
the scale. The excess lifetime cancer risks calculated for exposure to the landfill
contents fall within this range. These cancer risks are also below the maximum
acceptable risk level of 1E-05 (1 additional case of cancer for every 100,000
individuals similarly exposed) established under Part 201 of the Michigan Natural
Resources and Environmental Protection Act, 1994 PA 451, as amended (formerly
known as the Michigan Environmental Response Act).
VII. ENVIRONMENTAL RISK
A screening ecological risk assessment was conducted to characterize the biological resources
at the landfill and adjacent habitats, and identify actual and potential impacts to these
resources associated with releases of contaminants from the landfill contents. The results of
the screening ecological assessment indicate that the unsaturated portion of the landfill
contents is not expected to pose a significant threat to the environment. While the results of
the assessment indicate that there is a potential for individual plants and animals to be
exposed to contaminants in the landfill contents, existing data, current and projected land use
of the landfill and surrounding area, and existing habitat quality indicate that the soil
exposure pathway is incomplete. Exposure to the landfill contents via the soil exposure
pathway would therefore not be expected to result in any significant ecological impacts.
Given the higher levels of contaminants present in the saturated zone of the landfill and other
site areas (including the light non-aqueous phase liquid (LNAPL) encountered in groundwater
monitoring wells and piezometers proximate to the two buried ponds and Rockwell's former
wastewater treatment plant), the impacts to groundwater and the Kalamazoo River via surface
runoff and infiltration from the unsaturated portion of the landfill are also expected to be
insignificant by comparison (Table 2).
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TABLE 2
COMPARISON OF LANDFILL CONTAMINATION TO CHEMICALS IN SATURATED MATERIALS
AND LNAPL IN LANDFILL AND OTHER SITE AREAS
CHEMICAL
VOLATILES
Acetone
2-Butanone
Chloroform
Methylene Chloride
Toluene
SEMIVOLATILES
Acenaphthene
Acenaphthylene
Anthracene
Benzol a (anthracene
Benzol a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Bis(2-ethylhexyi)phthalate
Butylbenzyiphthalate
Carbazole
Chrysene
Di-n-butylphthalaie
Dibenzo(a,h)anthracene
Dibenzofuran
Dimethylphthalate
Fluorene
Fluoroanthrene
Indeno( 1 ,2,3-cd)pyrene
2-Methylnaphthalene
Napthalene
Phenanthreae
Pyrene
PESTICIDES/PCBs
Aldrin
Gamma-BHC (Lindane)
Alpha-Chlordane
Ganuna-Chlordane
ODD
DDE
DDT
Dieldrin
Endrin
Endrin Aldehyde
Endrin Ketone
Heptachlor Epoxide
Aroclor-1254
Aroclor-1260
LANDFILL
CONTENTS'
(ug/kg)
77
16
2
4
2
(ug/kg)
150
150
1000
,2500
930
2000
82
1600
1100
51
120
3200
77
47
280
60
650
5200
990
500
270
4500
4300
(ug/kg)
2.3
5.2
6.0
8.8
23
10
16
4.1
5.2
3.5
4.0
1.4
57
14
SATURATED
MATERIALS'
(ug/kg)
18000
190
14
98
55
(ug/kg)
47
80
63
1200
520
760
760
290
1600
ND
ND
1200
210
120
58
ND
510
840
290
1000
530
2100
840
(ug/kg)
ND
ND
15
18
100
18
100
ND
ND
3.3
ND
ND
1600
108
LIGHT NON- 1
AQUEOUS PHASE
LIQUID (LNAPL)1 |
(us /kg)
\"O O' 1,
ND
ND
ND
ND
ND
(ug/kg)
ND
ND
ND
19000
28000
<9057
< 11781
ND
800000
29000
ND
87000
9200
ND
6600
ND
26000
5900
ND
110000
44000
120000
32000
(ug/kg)
N/A
N/A
N/A
N/A
N/A
N/A
N/A •
N/A
N/A
N/A
N/A
N/A
12134
ND
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CHEMICAL
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
Cyanide
LANDFILL
CONTENTS'
(mg/kg)
6690
14.7
14.6
146
88400
23.6
5.6
35.7
30700
210
33100
794
0.32
18.9
270
8.4
204
19.5
289
2.6
SATURATED
MATERIALS1
(mg/kg)
9630
15.7
32.6
436
131000
85.6
21.4
379
50300
1150
65900
3610
1.3
31.9
1660
1.2
1320
51.8
1100
1.0
LIGHT NON-
AQUEOUS PHASE
LIQUID (LNAPL)3
(mg/kg)
5915
0.52
15.7
40.5
1850
12.4
0.93
6.66
1070
2.79
46.7
9.85
0.25
4.82
9.6
ND
41.4
10.2
65;s
ND
I. Based on Unseuurated Landfill Contents Samples SB-1 through SB~8, MW-15-001, MW-16-001. MW-16-002 and P-19-001.
2. Based on Saturated Samples Collected in Landfill and Other Site Areas Adjacent to Kalamazoo River, including MW-1, MW-
2, AfW-3, MW-4, MW-18. P-13. P-14 and P-17; and MW-6, MW-7, MW-S, P-12. MW-15-002, MW-15-003, MW-16-003, P-19-
002 and P-19-O03.
3. Based on LNAPL Samples Collected from KW~#3 and P-17.
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. RISK SUMMARY
Based on the results of the baseline risk assessment conducted for the Landfill Contents
Operable Unit, U.S. EPA has determined that conditions in the landfill contents do not pose
a significant current or future risk to human health or the environment. The noncancer
hazard indices calculated for exposure to the landfill are less than 1.0; the excess lifetime
cancer risk falls within the acceptable risk range of 1E-04 to 1E-06 as established in the
NCP; and the screening ecological assessment indicates that the landfill contents are not
expected to pose a significant threat to the environment via the soil exposure pathway. Based
on these results, U.S. EPA has determined that no remedial action is warranted to remediate
the Landfill Contents Operable Unit of the site. Additionally, because the landfill contents
do not pose an unacceptable risk to human health or the environment, and the.primary fill
material in the landfill consists of sand, gravel and concrete debris, approximately 50 to 80
percent of which is below the saturated zone, a presumptive remedy was not selected for
implementation at this operable unit. A presumptive remedy such as a landfill cap would not
result in a significant risk benefit. Additionally, because source contaminants are already
present in the saturated zone of the landfill and other areas of the site, and are present at
higher levels in the saturated zone than in the unsaturated zone, a presumptive remedy such
as a cap over the landfill contents would have a limited effect on groundwater contamination
or contaminant transport to the Kalamazoo River.
EX. DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the recommended alternative described in the proposed
plan.
X. STATUTORY DETERMINATIONS
U.S. EPA has determined that conditions in the landfill contents do not pose a current or
potential threat to human health or the environment, and that no remedial action is warranted
to remediate the landfill contents operable unit.
The Michigan Department of Natural Resources has determined that the selected remedy
meets the provisions of the Limited Industrial Category of Part 201 of the Natural Resources
and Environmental Protection Act, 1994 PA 451, as amended (formerly known as the
Michigan Environmental Response Act). The State of Michigan therefore concurs with the
selected remedy.
As this is a decision for "No Action," the statutory requirements of CERCLA Section 121
for remedial actions are not applicable and no five year review will be undertaken.
10
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RESPONSIVENESS SUMMARY
The public participation requirements of CERCLA sections 113 (k) (2) (i-v) and 117 of
CERCLA have been met during the remedy selection process. Section 113(k)(2)(B)(iv) and
117(b) of CERCLA requires the U.S EPA to respond "...to each of the significant
comments, criticisms, and new data submitted in written or oral presentations" on a proposed
plan for a remedial action. The Responsiveness Summary addresses concerns expressed by
the public, the potentially responsible parties (PRPs), and governmental bodies in written and
oral comments received by U.S. EPA and the State regarding the proposed remedy for the
Landfill Contents Operable Unit of the Rockwell International site.
BACKGROUND
U.S. EPA issued a fact sheet to the public in May, 1989, at the beginning of the Remedial
Investigation. The Agency also hosted an availability session on May 24, 1989, to provide
background information on the Rockwell International site, explain the Superfund process,
and provide details of the upcoming investigation. Phase I of the remedial investigation was
completed in November, 1990, and, in November, 1992, U.S. EPA issued a site activities
update announcing a second phase of work. The second phase of the remedial investigation
was completed in September, 1993, and, after additional sample collection, a risk assessment
for the landfill contents operable unit was completed in April, 1995. The risk assessment for
the landfill contents operable unit was released to the public in May, 1995.
The Proposed Plan for the landfill contents operable unit was released to the public for
review in May, 1995. Copies of the proposed plan were mailed to local residents and other
interested parties on U.S. EPA's mailing list for the site. Information repositories have also
been established at the two following locations: Allegan Public Library, 331 Hubbard Street.
Allegan, Michigan, and Waldo Library, Reference Section-Government Documents, Western
Michigan University, Kalamazoo, Michigan. The Administrative Record has been made
available to the public at the U.S. EPA Docket Room in Region V and the Waldo Library at
Western Michigan University. A copy of the Administrative Record Index is available at the
Allegan Public Library.
A public meeting was held on May 11, 1995, to discuss the risk assessment for the landfill
contents operable unit and U.S. EPA's proposed plan for the landfill contents. During the
meeting, representatives from the U.S. EPA discussed the remedial investigation and the
results of the risk assessment for the landfill contents operable unit, and presented U.S.
EPA's proposed plan for the landfill contents operable unit. Representatives from the U.S.
EPA and the Michigan Department of Natural Resources were available to answer questions.
and formal oral comments on the proposed plan for the landfill contents operable unit were
documented by a court reporter. A verbatim transcript of this public meeting has been
placed in the information repositories and Administrative Record. Written comments were
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also accepted at this meeting. The meeting was attended by approximately 15 persons,
including local residents and city officials.
The Proposed Plan was available for public comment from May 5, 1995 through June 3,
1995. Comments received during the public comment period and U.S. EPA's responses to
those comments are included in this Responsiveness Summary, which is a part of this ROD.
Advertisements announcing the availability of the Proposed Plan and the start of the comment
period were published in the Allegan News and Gazette and the Kalamazoo Gazette on May
4, 1995.
During the comment period, U.S. EPA received approximately 4 written submittals of
comments and 3 oral comments concerning the proposed plan. A summary of each comment
and U.S. EPA's response to the comment, is provided in the following section.
SUMMARY OF SIGNIFICANT COMMENTS
Comment 1: The commentor agrees that the State of Michigan should pursue measures such
as exposure barriers to minimize exposure to the landfill contents.
Response 1: The State of Michigan is working with the City of Allegan to develop measures
to minimize exposure to the landfill contents in the plans and specifications for the
wastewater treatment plant expansion.
Comment 2: The commentor lives and works in Allegan and states that he is interested in
expanding the economic base of Allegan, and agrees that existing industrial areas should be
redeveloped, rather than using "pristine" areas.
Response 2: The above comment is noted. The redevelopment of existing industrial areas
rather than expanding into non-industrial areas is the goal of U.S. EPA's "Brownfields"
initiative.
Comment 3: The commentor states that the Final Revised Community Relations Plan for
the Rockwell International site comments that citizens are not interested in the site; however,
he knows of three people who had serious concerns about the site that could not come to the
public meeting. The commentor did not receive a copy of the Proposed Plan in the mail,
and hopes that U.S. EPA makes a serious effort to update the mailing list.
Response 3: The Final Revised Community Relations Plan does not state that citizens are
not interested in the site. The plan states that the "level of interest in the site still appears to
be minimal." This statement is based on previous community interviews conducted for the
site; attendance at the RI/FS availability session; past requests for information; and, more
recently, eighteen interviews conducted with a cross-section of local officials and residents
near the site in April, 1994.
-------
U.S. EPA apologizes that the commentor did not receive a copy of the Proposed Plan. The
commemor's name and address are in U.S. EPA's records, and it is an oversight that they
were not included on the final mailing list. The mailing list has now been updated to include
the commentor's name and address, as well as the names and addresses of other attendants at
the public meeting who were not on U.S. EPA's mailing list.
Comment 4: Several commentors expressed concern that the Proposed Plan was not mailed
to residents living in the immediate vicinity of the site.
Response 4: U.S. EPA's mailing list for the Rockwell International site has been
continuously updated and maintained throughout the site's progress. The most recent update
was in April, 1994, when names and addresses of people living on streets surrounding die
site were obtained from local property tax records and added to the mailing list if they were
not already on the list. According to U.S. EPA's mailing list, the Proposed Plan for the
landfill contents was specifically sent to 161 residents on streets surrounding the site
including: Allet, Briggs, Cora, Delia, Grand, Ida, Jenny, Main, North, Race, River,
Riverside, Riverview, Water and Wolcott. U.S. EPA encourages anyone who wishes to
confirm or add their name to die mailing list to contact the U.S. EPA Community
Involvement Coordinator for the site, Dave Novak, at (312) 886-9840 or toll free at 1-800-
621-8431.
Comment 5: The Waldo Library at Western Michigan University in Kalamazoo has more
information about the site than the Allegan Public Library. Could U.S. EPA direct users of
the Allegan Public Library to the Waldo Library for more information.
Response 5: An index of additional site-related information available at the Waldo Library
was sent to the Allegan Public Library on May 15, 1995 for inclusion in the information
repository. Also included with the index is the location of the Waldo Library, its hours of
operation, and the telephone number. While the Allegan Public Library contains copies of
various work plans and the risk assessment for the landfill contents operable unit, the
administrative record for the site is being maintained at the Waldo Library. The decision to
maintain the administrative record at the Waldo Library was made in consultation with the
MDNR site project manager and is based on the Waldo Library having more available shelf
space, longer hours of operation, and better xeroxing facilities.
Comment 6: Concern was expressed whether a construction crew would be able to build a
wastewater treatment tank over the landfill without encountering the water table, which is
four to six feet below ground surface in the landfill.
Response 6: According to the final plans and specifications for the City of Allegan
wastewater treatment plant expansion, the foundations of the two tanks will be approximately
4 feet below ground surface, and the City plans to avoid any excavation below the water
table. From an engineering perspective, excavation below the water table would require the
implementation of dewatering controls, which could delay construction and increase cost.
-------
Comment 7: U.S. EPA's Proposed Plan for the Landfill Contents Operable Unit seems to
have overlooked continuing contamination to the Kalamazoo River resulting from storm
water runoff and percolation through the landfill. A review of the topography of the site
reveals a very significant gradient from both the east and north down to the river. Also, a
cursory inspection of the site and the surrounding residential neighborhood did not reveal any
storm sewers or catch basins. This, combined widi no sign of significant ponding on the site
suggests that all storm water received by the site and surrounding neighborhood must be
passing through the landfill enroute to the river. Therefore, the site should be completely
capped, and a provision should be made to prevent on and off-site runoff from migrating
over or through the site.
Response 7: Releases to groundwater and the Kalamazoo River via surface runoff and
infiltration from the landfill contents were evaluated in Part I, Section 3.1 of the risk
assessment, and Part II, Section 1.4 of the risk assessment. The landfill is located within a
former, low-lying backwater area of the Kalamazoo River that was filled to surface grac ••
As a result, most of the landfill contents (approximately 50 to 80 percent based on soil
boring logs) are now beneath the water table ana constitute part of the saturated zone. T.
depth to the water table in the landfill ranges from approximately 4 feet below ground
surface (ft-bgs) north of North Street to approximately 2 ft-bgs south of North Street.
Contaminants are present in the landfill materials above the water table; in the landfill and
other areas of the site in materials below the water table; and in an oil phase liquid
encountered in one of the buried ponds north of the landfill and near Rockwell's former
wastewater treatment plant. The levels of contamination present in the saturated zone of the
landfill and other areas of the site, and in the oil phase liquid, are much higher than those
encountered in the unsaturated portion of the landfill. This is illustrated in Table 3.3 and
Table 5 in Parts I and n of the risk assessment. Because the levels of contaminants are
much higher in the saturated zone of the site and oil phase liquid than they are in the
unsaturated portion of the landfill, capping the landfill is not expected to be an effective
solution for reducing contaminant transport to the river. The most effective methods would
likely focus directly on groundwater.
Additionally, although there is a steep gradient to the north and east of the landfill,
stormwater from the surrounding residential area is intercepted by a series of storm sewers
before reaching the landfill. Catch basins for the sewer lines are located at several points
along North and River streets and direct the stormwater away from the landfill. A figure
showing the locations of the storm sewers has been provided by the City of AUegan and is
attached.
Comment 8: One commentor lives across die street from the Rockwell International site,
and notes that the site is a playing area for her two daughters and other children. She notes
that site progress has been slow, and that she is not surprised that U.S. EPA is proposing no
further action. She is concerned that some chemicals have been detected in the landfill at
levels above the Michigan Act 307 criteria, and is concerned for the health and safety of her
-------
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-------
children. She is against the city expanding the wastewater treatment plant, and feels that
expanding the plant can only create greater problems and expose more buried chemicals.
Response 8: U.S. EPA would like to clarify that the Agency's proposal for no further
action only applies to the landfill contents, not the rest of the Rockwell International site.
Groundwater, the Kalamazoo River and other site areas are in the final stages of
investigation and will be addressed in an upcoming proposed plan. U.S. EPA notes the
commentor's concern for the health and safety of her children, and recognizes the potential
for children and adults to trespass on the landfill property. For these reasons, the risk
assessment for the landfill contents operable unit included the evaluation of both a child
trespasser scenario (ages 7 to 12) and an adult trespasser scenario (ages 13 to 36). For the
child trespasser scenario, it was assumed that children would trespass on the landfill 3 days a
week for 10 months per year for 6 years. For the adult trespasser scenario, it was assumed
that adults would trespass on the landfill 3 days a week for 10 months per year for 24 years.
For both scenarios, it was assumed that on each visit children and adults would ingest a
certain amount of contaminated soil, inhale a certain quantity of contaminated air, and be
covered with contaminated soil over a certain portion of their body: Based on these
assumptions, the results of the risk assessment indicate that exposure to the landfill contents
under adult and child trespasser scenarios would not result in any non-cancer health effects or
unacceptable cancer risks. The absorbed chemical intake estimated from exposure to the
landfill contents is less than established thresholds; and the maximum cancer risk is estimated
to be 5 additional cases of cancer for every 1 million individuals similarly exposed for child
trespassers, and 4 additional cases for every 1 million individuals exposed for adult
trespassers.
While some chemicals were detected in the landfill contents at concentrations above
Michigan's Act 307 criteria for unrestricted land use, the Act 307 criteria were developed
using a conservative approach and were based on a maximum acceptable risk level of 1
additional case of cancer for every 1 million individuals similarly exposed. As of June,
1995, however, Act 307 is no longer in effect, and the state's cleanup criteria are now
regulated under Part 201 of the Natural Resources and Environmental Protection Act, 1994
PA 451, as amended. The current criteria under the new regulations are developed using a
less conservative approach, and are based on a ma*im""i acceptable risk level of 1 additional
case of cancer for every 100,000 individuals similarly exposed.
Additionally, the'criteria for unrestricted land use (under Act 307 and Part 201), are based
on different assumptions than those believed to represent the conditions at the landfill. The
most significant difference is that the criteria for unrestricted land use assume that a person
would be exposed to contamination at a site for 365 days a year for 70 years (i.e., over a
lifetime). For the landfill contents, however, a lifetime exposure to the contaminants in the
landfill is not likely to occur, as there are no residences on the landfill and the landfill
property is zoned for and expected to remain under industrial use. Additionally, more than
two-thirds of the landfill is covered by the existing wastewater treatment plant and grounds
and a vegetative covering, which also act to limit and/or reduce the potential for exposure.
-------
U.S. EPA notes that the commentor has indicated she is against the City's plan to expand the
wastewater treatment plant and feels that expanding the plant can only expose more buried
chemicals. While U.S. EPA recognizes the commentor is concerned about the exposure of
more buried chemicals, it must be stressed that the landfill contents above the water table
(approximately 0 to 6 feet below ground surface) have been sampled and characterized, and
that the risk assessment indicates that exposure to these landfill contents do not pose an
unacceptable risk to human health or the environment under current and reasonably expected
future use scenarios.
Comment 9: Rockwell International comments that the proposed plan and risk assessment
for the landfill contents operable unit does not include any information about the historical
operations of the City of Allegan wastewater treatment plant and only limited information
about the landfill. Additional information regarding the wastewater treatment plant and
landfill have been provided for U.S. EPA's consideration.
Response 9: The information provided to U.S. EPA regarding the operation of the City of
Allegan municipal wastewater treatment plant and the former municipal landfill has been
included in the Administrative Record. U.S. EPA would like to clarify, however, that the
Agency believes additional evidence is needed to demonstrate that sludge from the
wastewater treatment plant was landfarmed in the landfill and/or on the wastewater treatment
plant property, especially since air photographs do not indicate that any crops or vegetative
covering were ever cultivated in this area.
Comment 10: The proposed plan and risk assessment for the landfill contents operable unit
repeatedly implies without substantiating information that Rockwell disposed of wastewaters
and waste oils in the landfill. There is no evidence to suggest any waste materials from
Rockwell were discharged or taken to the landfill for handling/disposal by the City. To the
extent possible, Rockwell recycled or sold used oils and metals from the facility. Waste oils
were managed after 1945 through the oil floatation house. From approximately 1964 to
1972, waste oils from Rockwell were managed in on-site ponds or through the Rockwell
wastewater treatment plant. Consequently, Rockwell would have no reason to discharge
waste oils to the landfill, which did not begin operation until 1947.
Response 10: The Agency did not mean to imply that Rockwell disposed of wastewaters and
waste oils in the'landfill. There is evidence to indicate, however, that a portion of the
landfill, and some portions of the site, were constructed over areas that were previously
impacted by site operations prior to landfilling and operation of the on-site ponds. The
evidence further indicates that this area of impact coincides with portions of the former
backwater area (i.e., the northern portion).
During an interview in 1984, the environmental control technician at the Rockwell plant
stated that, in the early years of operation (prior to construction of the on-site ponds), the
waste streams from the facility were discharged to the wetland area of the Kalamazoo River
-------
behind the plant.1 Based on historic aerial photographs, the wetland area of the Kalamazoo
River behind the "plant coincides with the backwater area of the Kalamazoo River that once
existed north/northwest of the facility, most of which has been filled. Additionally, in a
1955 aerial photograph of the site, U.S. EPA identified both liquid waste and a liquid waste
dumping point in the backwater area to the north/northwest of the manufacturing building.2
Additional evidence is further provided in the soil boring logs for boring locations P-14,
MW-6 and P-12. According to a survey of the plant in 1968 and an air photo Rockwell has
of the plant in 1969, soil borings P-14, MW-6 and P-12 were installed outside the limits of
the on-site ponds; and MW-6 and P-12 were installed within the former City of Allegan
municipal landfill. As shown in the boring records, however, each of these soil borings
exhibit oily deposits at approximately 614 feet above mean sea level (ft-msl); metal
fragments at approximately 597 ft-msl in P-14 and P-12; and irregular black staining and
wire pieces at approximately 599 ft-msl in MW-6. As indicated in Figure 1-16 provided to
U.S. EPA by Rockwell3, all three borings are outside the limits of the former ponds, and
the metal fragments, wire pieces and irregular black staining encountered in P-12 and MW-6
are also more than 5 feet below the bottom of the landfill. In addition, a comparison of
Figure 1-5 (extent of former backwater area in 1955) provided to U.S. EPA by Rockwell in
the draft RI to Figure 2-1 (1990 sample locations) indicates that P-14 is located within the
extent of the former backwater area and the area of liquid waste as identified by U.S. EPA
in the 1955 aerial photograph. While soil borings P-12 and MW-6 are shown to be outside
the limits of the backwater area in the 1955 figure, the extent of the backwater area shown in
an aerial photograph from 1950 has not been delineated, and is not available for years other
than 1938, 1947, 1950 and 1955.
This soil boring evidence, in conjunction with the information provided by plant personnel
and U.S. EPA 's time-series aerial photograph analysis of the site, indicates that wastewater
(including waste oil) was discharged from the plant into areas other than the on-site ponds.
A portion of this area was then landfilled by the City of Allegan, while the remaining portion
was eventually filled and built over by Rockwell.
1 National Priorities Lifl RsnKuiE hazardous Ranking Score Package. December 19,
1984, Reference No. 18: Conversation record of William Sebright, Environmental Control
Technician, RoctweU Allegan Plant, Phil Backlund, Environmental Engineer, Rockwell, and
Paul Hess, Field Investigation Team Leader, Ecology and Environment, under contract to
U.S. EPA, regarding "History of Allegan Plant," June 20, 1984.
U.S. EPA, 1986.
'Letter from T. Defouw, Rockwell International Corporation to D. Novak, U.S. EPA,
Re: Comments on the Proposed Plan for the City of Allegan, MI Landfill Contents Operable
Unit, June 2, 1995.
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Additionally, while Rockwell comments that waste oils were managed after 1945 through the
oil floatation house, U.S. EPA would like to clarify that, according to a 1968 Rockwell
internal memorandum, waste disposal at the plant was accomplished through a roof drain
system consisting of three roof drains: east, west and north (dates of use unknown).4 In
addition, a 1971 Rockwell report on waste disposal further discusses how "The common
practice of hooking washer wastes, sump pumps and cooling water to roof drains continued
because overflows were small and most draining and cleaning was done on night shirts,
making detection of large effluent flow unnoticed."5 While historical information regarding
site operations is a useful tool in characterizing the site, the final evaluation as to whether an
area is contaminated, however, is based on analytical data from sampled media.
Comment 11: The Michigan Environmental Response Act will be amended by Michigan
Enrolled House Bills 4596, 4597 and 4598, which are to be signed by Governor John Engler
by June 3, 1995. These statutory changes will have immediate effect. The carcinogenic risk
estimates in the proposed plan for the landfill contents do not exceed the Michigan
Department of Natural Resource's (MDNR) new de minims risk level of 1E-05.
Response 11: Governor John Engler has signed the house bills, and the MDNR concurs
with this Record of Decision for the landfill contents operable unit.
Comment 12: The risk assessment for the landfill contents operable unit focused on
characterizing risk via the outdated individual reasonable maximum estimate approach, in
contrast to more current U.S. EPA exposure assessment methodology and guidelines which
state that risk estimates should include a characterization of central tendency, as well as high
end exposure (HEE) risk estimates. Moreover, U.S. EPA's guidelines also state that
population risks should be evaluated. U.S. EPA's risk assessment for the landfill contents
operable unit did not include the central tendency and population risk estimates. It appears
that if a central tendency estimate were undertaken, and population risk associated with the
site were evaluated, the potential health risk associated with the landfill contents would be
reduced.
Response 12: While the Agency has published more current exposure assessment
methodology and guidelines for presenting risk estimates, these guidelines do not pertain to
U.S. EPA's authority for selecting remedial actions at Superfund sites. This authority is
established in the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA) and
4Rockwell Internal Letter to D. Wilber from E.E. Paulson Re: Waste Disposal - Planning
Objective IM-18. December 6, 1968.
5Waste Disposal. Allegan. Michigan. Proposal Design Report. March, 1971, Prepared by
E. E. Paulson, Plant Engineer, Approved by S. L. Cams, Factory Manager.
-------
the National Contingency Plan (NCP), and requires the Agency to base remedial decisions on
evaluations of reasonable maximum exposure risk estimates. Departure from reasonable
maximum exposure methodology would require revision in the current Superfund law.
Comment 13: U.S. EPA states in the proposed plan that groundwater, the Kalamazoo
River, and other site areas will be addressed in a separate proposed plan. As a practical
matter, however, it must be recognized that the proposed remedial approach, if adopted by
U.S. EPA, will substantially affect future decisions regarding groundwater.
Response 13: It is unclear why the commentor believes the proposed remedial approach for
the landfill contents operable unit would substantially affect future decisions regarding
groundwater. Located within a former backwater area of the Kalamazoo River, the majority
of the landfill contents (approximately 50 to 80 percent based on soil boring logs) are below
the water table and constitute pan of the saturated zone. The depth to the water table in the
landfill is also fairly shallow, and ranges from approximately 4 feet below ground surface (ft-
bgs) north of North Street to approximately 2 ft-bgs south of North Street.
Contaminants are present in the landfill materials above the water table; in the landfill and
other areas of the site in materials below the water table; and in an oil phase liquid
encountered in one of the buried ponds north of the landfill and near Rockwell's former
wastewater treatment plant. The levels of contamination present in the saturated zone of the
landfill and other areas of the site, and in the oil phase liquid, are much higher than those
encountered in the unsaturated portion of the landfill. This is illustrated in Table 3.3 and
Table 5 in Parts I and n of the risk assessment. Because the levels of contaminants are
much higher in the saturated zone of the site and oil phase liquid than they are in the
unsaturated portion of the landfill, remediation of the unsaturated portion of the landfill (e.g.,
through capping or excavation) would not be expected to significantly reduce contaminants in
groundwater. Because source contaminants are already present in the saturated zone of the
landfill and other site areas, and are present at higher levels in the saturated zone than in the
unsaturated zone, any source control measures such as capping or excavation of the landfill
contents would not be an effective means to address groundwater contamination or transport.
Comment 14: The baseline risk assessment for the landfill contents operable unit assumes
that construction of the clarifiers will require daily, year round construction activity for three
consecutive year*. This is an unreasonably long exposure duration for construction of a
single clarifier. In all likelihood, the construction activity would occur for approximately
one year. In addition, this scenario assumes that exposures to surficial soils via ingestion
and dermal contact will occur 12 months of the year, with no regard for the fact that the
ground will be frozen during late fall, winter, and early spring. Amending the risk
assessment to incorporate these site-specific assumptions would result in a lowering of site
risk estimates.
Response 14: While the baseline risk assessment discusses the proposed wastewater
treatment plant expansion, the actual risk evaluation is based on exposure to the operable unit
-------
as a whole, not just the proposed construction area. As such, and, in an effort to be
conservative, the risk evaluation assumed a general construction scenario that could apply to
any type of construction at the landfill, and it was assumed that construction could last longer
than one year. Additionally, in the absence of any data to support the number of days in
which the ground surface of the landfill is frozen, and the effect, if any, it would have on
soil ingestion and dermal contact under a construction scenario, in an effort to be
conservative U.S. EPA assumed a standard default exposure frequency of 250 days per year.
Comment 15: The baseline risk assessment for the landfill contents operable unit assumed
that commercial/industrial workers will be in contact with contaminated soils on a daily basis
year round at the site. This seems highly unlikely considering the job responsibilities of
treatment plant workers. Use of a more realistic soil contact rate would lower site risk
estimates.
Response 15: While the baseline risk assessment discusses the City of Allegan's plans to
expand the waste water treatment plant over a portion of the landfill, the risk evaluation for
the landfill contents is based on exposure to the operable unit as a whole, not just the area of
expanded facilities. As such, and, in an effort to be conservative, the risk evaluation
assumed a general commercial/industrial scenario that could apply to any type of
commercial/industrial activity at the landfill. Additionally, the ingestion and inhalation rates
for exposure to the landfill contents were selected consistent with U.S. EPA's Risk
Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual,
Supplemental Guidance "Standard Default Exposure Factors" (U.S. EPA, 1991), and the
dermal contact parameters were selected consistent with U.S. EPA's Dermal Exposure
Assessment: Principles and Applications (U.S. EPA, 1992). As discussed in the guidance,
these estimated values are reasonably conservative, and, in the absence of any other data,
believed to be appropriate for evaluating the landfill contents under a commercial/industrial
scenario.
Comment 16: The baseline risk assessment for the landfill contents operable unit assumed
that trespassers will be on the site three days per week, every week of the year. It is
unlikely that trespassers will be present 12 months of the year as they will likely limit their
activities to warmer months. In addition, because the ground will be frozen during the
winter months, potential for exposure via dermal contact and soil ingestion would be very
limited even if they were there. Adjusting the hypothetical trespasser exposure to reflect
site-specific conditions would result in a lowering of site risk estimates.
Response 16: The baseline risk assessment for the landfill contents operable unit does not
assume that trespassers will be on the site three days per week, every week of the year. As
discussed in Section 3.4.1.3 of the risk assessment, the estimated exposure time for
trespassers is assumed to be 3 days per week for ten months of the year, for a total of 130
days per year. This site-specific estimate is based on the assumption that trespassing during
the coldest months of the year is likely to be limited.
10
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GLOSSARY
Applicable or Relevant and Appropriate Requirements.
Section 121 (d) of CERCLA requires that remedial actions meet legally applicable or relevant
and appropriate requirements (ARARs) of other environmental laws. Legally "applicable"
requirements are those cleanup standards, standards of control, and other substantive
environmental protection requirements, criteria or limitations promulgated under Federal or
State law that specifically address a hazardous substance, pollutant, contaminant, remedial
action, location, or other circumstances at a CERCLA site. "Relevant and appropriate"
requirements are those requirements that, while not legally applicable to the remedial action,
address problems or situations sufficiently similar to those encountered at the site that their
use is well suited to the remedial action.
Non-promulgated advisories or guidance documents issued by federal or state governments
("to-be-considered orTBCs") do not have the status of ARARs; however, where no
applicable or relevant and appropriate requirements exist, or for some reason may not be
sufficiently protective, non-promulgated advisories or guidance documents may be considered
in determining the necessary level of clean up for protection of human health and the
environment.
Baseline Risk Assessment
The baseline risk assessment is an analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of any actions to control or mitigate
these releases. The baseline risk assessment assumes no corrective action will take place and
no site-use restrictions or institutional controls such as fencing, ground water use restrictions
or construction restrictions will be imposed. There are four steps in the baseline risk
assessment process: data collection and analysis; exposure assessment; toxicity assessment;
and risk characterization.
Cancer Potency Factors fCPFs)
Cancer potency factors (CPFs) have been developed by EPA's Carcinogenic Assessment
Group for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs, which are expressed in units of (mg/kg-day)rl, are multiplied
by the estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with exposure at that intake level. The
term "upper bound" reflects the conservative estimate of the risks calculated from the CPF.
Use of this approach makes underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human epidemiological studies or
chronic animal bioassays.
-------
Excess Lifetime Cancer Risks
Excess lifetime cancer risks are the sum of all excess cancer lifetime risks for all
contaminants for a given scenario. Excecs Lifetime Cancer Risks are determined by
multiplying the intake level by the cancer ~ -ency factor for each contaminant of concern and
summing across all relevant chemical* ar.c r;ihways. These risks are probabilities that are
generally expressed in scientific notation (<;._'. 1 X 10^). An excess lifetime cancer risk of 1
x 10"* indicates that a person's chance of contracting cancer as a result of site related
exposure averaged over a 70-year lifetime may be increased by as much as 1 in one million.
Hazard Index (HI)
The Hazard Index (HI), an expression of non-carcinogenic toxic effects, measures whether a
person is being exposed to adverse levels of non-carcinogens. The HI provides a useful
reference point for gauging the potential significance of multiple contaminant exposures
within a single medium or across multiple media. The HI for non-carcinogenic health risks
is the sum of all contaminants for a given scenario. Any Hazard Index value greater than
1.0 suggests that a non-carcinogen potentially presents an unacceptable health risk.
Reference Doses (RfDs>
Reference doses (RfDs) have been developed by U.S. EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting non-carcinogenic effects. RfDs,
which are expressed in units of mg/kg-day, are estimates of average daily exposure levels for
humans, including sensitive individuals. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated drinking water) can be
compared to the RID. RfDs are derived from human epidemiological studies or animal
studies to which uncertainty factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors help ensure that the RfDs will
not underestimate the potential for adverse non-carcinogenic effects to occur.
-------
STATE LETTER OF CONCURRENCE
(Pending)
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
- REGION V
DATE: July 11, 1995
SUBJECT: State Letter of Concurrence
Landfill Contents Operable Unit
Rockwell International Site, Allegan, Michigan
FROM: Karen Sikora, Remedial Project Manager
Remedial Response Branch, Section 2 _ ^ _
TO: File
On July 11, 1995, George Carpenter from the Michigan Department of
Natural Resources indicated that the State's Letter of Concurrence
for the Record of Decision for the Landfill Contents Operable Unit,
Rockwell International Site, Allegan, Michigan, will be forwarded
to U.S. EPA during the week of July 24, 1995.
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U.S. EPA ADMINISTRATIVE RECCRD
REMEDIAL ACTION
ROCKWELL INTERNATIONAL CORPORATION
ALLEGAN. MICHIGAN
ORIGINAL
05/03/95
:^z
rs:s
1UTKCR
RECIPIENT
?«S£S
:f Ailecar!
Hater »93:ur:ss
Coiussior.
.;6/0*/i* ?urST, R., "•»: ias:e 5is:oiai s!inni«?
Jt:ec::v» -r^SWITIJi flSJiGTiTrCNSi
.jt'.er r;: »SC's ^G-;JS: :: :e !n4:ned r
t*a Status :? f-e F':::5ec :i:r:veien:s t-:
-------
-srvtT, C.. !!::n::J.i «i:Ser. :.. N;r:-! .JUST '?: -:::3>: :-»-:es :: :•? Si!
iatir 'esaurces :Mrtc.a.i
n larsoratisn
:"•"•" "ateriais "sstinq :oii Borira .:;s h1-
rcrsuitwts. Ir.c. 1'70 B/Attacr.efl U:
nil Ccrcoration
J.. RiCuiaan ''lulss". £., "i:"* ,;::er T. Cct:ii:.v. :• Til :633i:s :-*.: '.'8
Hittr Resources AMrican nocx«eii 'i;ii*;;o ir:v;r r.S:IH.S£T;
n Coroorati;n
17 :J/97/?« PrtTbysz, R., S»bri;ht, K., Litttr r»: WC's ir,ssic::3.i of tfte Oil iia$t«
.1i:hiqan Mattr Rocknil intenatia- T-?»tnnt Facilities iUNSIHNEB)
i Coiiissicn nal Ccrsoratian
1: :::i2/7< Sebriqht, M., North ?r:voysz. S., Letttr r»: ieasage •:• C:l '*:» ;::: tl into 1
Aitrican Socinil *i:!ugan Hatir v.ie l^ivsr
Risourcis CoMissisn
L? 12/11/73 5rivn« L., Shilti, Sibright, »., Litttr rt: lnmti;atisn af thi Oil Sifpiqt 13
SrivH k Associatis, Rocfcitll Intirnatio- Probln at tin Alligan Plant n/Attachnnts
Inc. nal Corporation
20 C4/1Z/7& :rzrbT«, R., Sibriqht, N., Littir re: MC's Revn» af thi Oil Stioaqi :
lichiqan Hattr RoctMll Intirnatis- Probln and tltt Soils Invntiqatisn
Rnourcfs Comssion nal Corporation »/Attachid HRC April 1, 1976 HHorandui
(UNSI6NEO)
:i 04/20/76 Sebright, H., NDMi Littir re: Liakaqt »f •.'?s«nround Haste 1
Roekitll Intirnatio- Storaqi Tanks
nal Corporation
22 v4/27/T? Saruit, S., Michigan Sibriq!»t, »., Litttr re: Suuits :f t^e siudqt Satc'i taitn 1
Vattr Qualitr RoctMll Intirnatio- froi Pond 12 on Ftbruary 12, 197?
Sivition nal Corporation
23 07/04/84 HtM, P., Ecology U.S. EPA Sitt Insptction Rtpert 14
uii EnfiroflMfit,
:.ic.
24 CS/'iT'S* iisiduais Hanaqmnt Sock»tll irtirnati:- 'esort: Svaiuatisr :* Sur'act iicounditnts 35
Tectmoioqy, Inc. nal C:rcorati:n and Mills
I: ;:/:?/5* rjss. P., ecology :.'.s. I-''. :-RS Scrrmq riiiajs . ---
ira Envirarttnt.
lie.
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:cci :-
::-2*-;3-b :,:::-^f 1-'
Er< line's t.
..:. -?A
HrL£/D€3CKiPT::i
-?.S :;:-;-; :i;uq.e Adjusted .c:ral)
«/Stferenc9S i-I3
noes
-esfloncent
23 ;".'-}v-;5? ;.:;:n39r:r:-5::3nce J.3. EPA
AdeinistraUve Order 37 Consent
duality 4s;ur»,i;s 'rsject Plan i/Final QAC
Calient s
49
'6
Srauscn, ... ^et-cor, I.-.terMtisnai
he. Caraorati:-
10/20/9: Reicor. lac.
U.S. EPA
y ir.s 3:::e
lodifici'.ions
Health ir,i Safety 3!in Wdendu* for *ork Plan
:3 1';/2C.'9: ;sicor. :.-.:.
34 o:/05/93 U.S. E?ft
<:n =Ur, Aiiens^ji is ":-:;fis
the
'J.. r
Suooleient ts the Korlt Plan Addendui for
LNAPL Saiaiin;
33 04/20/93 Fietinq, H.. ftetcor, DcFoui, I.. RockMll Letter re: Identification of Select Suples
Inc. International for Recollection and Analysis
Carooratisn
36 04/20/93 3rovn. (.. U.S. Sikora. (... J.3. EPA leurandue re: Analytical Results of Light
EPA/ORO Nmaquecus Phase Liquid Saiples i/Attacftients
*7 04/29/93 Oanneffel. 6.. f!DHR cordon t. J"es. Letter r»: £t3ans::n of the Alleqan
P.£. Vastevater Treataert PUnt
33 05/24/93 3ardon £. Jones. Sikora. K.. J.3. E?A Latter F:r»arair,c Attached Details of the
r.E. ' Tank Ccr.stnicticn fsr the Allecjar! Kastewater
Trtatient Plant
39 06/08/93 Anthony, A., City of Sikora, L. U.S. EPA- Letter r!: Aiiegan Mstenater Trsatient Plant
Alleqan Expansion
40 06/10/93 Sikora. K.. U.S. EPA Gordon E. .""33. Caver Letter Fcnurc1:.:; the irfork Plan and
'.£. Suaiity issura-^ca 3-r;»:t ?U- fv Coiiectisn
ind Analysis •:: :rai;:» Sail Saaaies
il 06/2i:°3 ::kora,.K.. L!.S. i?A ssrdsn £. ::••?«, .stter -3: i real:.1! i-j :ai5i:s5 Plan 'or
P.E. :i«sU" -:t:v:::=3
33
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Hikcri. i.. -J.5. E-fl Litter re: tXCQTEC's 5ivie» of tf.t .V.e i*S9
-ealt.1 1-3 Safety Plan
Cor.trol Technology
Csroorati:n
•17 ;: -,;•:- *ONR Sorian E. Jcnes, Letter r«: WWs Counts on tht Puns and
p.E. 5oicif::it;cns for tht Eioansion of thi
ustsxtir Treauint Plant
103
i? IJ-'ZI/'" ::':•". E. J-:nas. Siksri. i'., 'J.3. £?A L»tt»r F:-»ardinq Attached Soil Testing 83
P.-. 4nairs;3 »itn Suiiary ra^uiiticn far Saioies
11-9
•i; ll,";?/'; "crier, £. Ja.iei, :ik:*i, '.. ;.:. E=f' Lattsr "tmardinq Attached Tank Construction . 8
. La:ter •*; :;.a. EFA's Csaitnts sn tfte •
^lii;*.-, ^ddit::.-ai C:ntract Ssecifications for tht
City of Allan's Kastnattr TreatMnt Plant
Exoansis-t
01/21/94 Siith. S.. Clary, Sikora, KM U.S. EPA Letter re: City of Alltqaa's Rtqutit for a
Nant:. Mood. fleeting nth U.S. EPA
H'offius. Rankin 4
4? 0:/?7'« la.intMal, 3.. NOW Sorjsn E. Jones, Letter re: Retoval and Handling of I
P.E. Contaminated Soils During Construction of tht
Uastenattr Treattent Plant Expansion
50 c:/ll;?4 Siith, 3.. Clary, Sikcra. K., ij.3. E-A Lettar ^e: Citr of Allan's Kastewter 2
Nantz, Hood, Traatient Plant Expansion
Hoffius. Mnkin I
Cooptr
SI o:/:4/94 Sordor E. Jones. Anttaiy, A., City of Letter rt: tht Extension of tht Original 2
P.E. Alltqan Fioodciain Area Across tht Existing
• 4aste»ater t'tatient Plant Expansion Site
!2 ":,;::/?4 EUT. C.. '.'.5. Sikra. r,. •:.;. E?a "ev:e» -5* s*c:on 5 Cl? 2ata (Cast I PfiP 7705, 14
•?A/CRL 11 3:'*A ;ii3iesl
?T •::/::/?» ;::•/,:., J.S. -ikra, «.,;•.£. £?A R«vn» :- 'scion 5 CLP 2ata (Cast » PRP 7705, o
-------
T miE/oe--~:?r::)i »«S€S
". I!.-'"* £11?, I.. -.5. Sikora, I., J.3. -?A Sene» :• :;::" : C'.? «i*.i iCise in?, l :)
EPA/CRl Mater i-: • ::;: 3iioi«)
:::"/'* illy, :., J.3. Sikora, <., "J.3. EPA Review a? ;?qion 5 :i? 3it* (Csg I PRP 7703, s
:?ft/CRL ' VoUtiie ::;i S
): Zl/5* ::<:ri, (,, 'j.3. EPfl siith. S., Clary, Lettir r«: Csllection of Unfiltered
Nantz, Kooa. 5r5uncM:er Nicies
-'c'U'iS, 'iniin 4
";c:er
:.;. ^.ain cr I.»*.::y decora re: the araunomter
Saioies 5f -<-l5 and Bl-16
Final Ssviss-j Ccuunitr Relations Plan 33
:3.-'l?/:* -5r:in. .'.. iiiiara. r., j'.3. erfl Letter =:-«ir.3ng Att»cr,«iJ 1?94 Ketal 140
•.-v;r:ria':il Analytical I»t» fcr Srcundmter Saioles froi
:;^:r:: 'a:-::::- Mils rt-i; in «-l6
;:) .}?/:3/5* «sol3isiti. D., :J.S. Sikora, t., U.S. EPA Revitu of «iqion 5 CL? Data (Cast I 7712, « 14
•P3/CA33 Saaplis)
61 12/02/«» J:n*s. 3., 'J.3. EPA Sikora, (., U.S. EPA Neiorandui re: Scnminq Ecological 12
Asstssitflt
:1 o:/13/5? ::!ufe-. «.. «NR Eikora, (., U.S. EPA FAI fransiittal Fonardinq Attacntd February «
9, 1995 Letter frai Gordon £. Janw, P.E. to .
flONP re: 3;eciai Provision Acquired for the
WasteMter Treatitnt Plant Expansion
:•: JI/C?/'? -srian. :., Sikora. K.. U.S. EPA Latter ?arnrdinq Attached Ra« Analytical 99
rviror.iertji Data for Srcandwttr Suolis UK-IS and ftK-16
:ntr:i Tjcimalssy
•:r3ori-.:c-.
44 -:i-'",0,'?5 ..3. E?A Borehoi* Driilinq and Test Pit Logs: Phasi I 141
and Phase I! Rewdial Investiqation
i5 04/00/95 'J.T. £?A Caioietei Chain sf Custody Foris: Pfiase I ind 303
Phase :! :=tedui Investiqation
:: :*'00/95 J.:. £•? Data Vai::»::5n Resorts: Phase I and Phase li 1118
?:eid Ck.ir:s / ="ciifi:at:sn Fans: Phase i ;2
jnd rhass i: :?»e::»i hysstisatian
-------
3s r-.<0/9! J.3. EPA
:? 01/00/93 U.S. EPA
'? -M.'00/95 J.S. EPS
:':u.-:»a:jr 3-:.-;t jr,s :i§oi« C:;iact::n
•:-»y?s
;,:. £3-1
L',3. SPA
:J.3. EPS
".•'?
7s 04/00/93 J.S. £?A
•is:
•ase i ir.d P.L.ase ii
at::r
Ea'3*y C-ata Sheets
•a liell C3Pstrjct::n Si
: P*iast T4
•:Ti*.:r *q »*11 Devei::aent Fsris: ?";ase 1
!••: Pkasa ii ?eaediai I^.-es*:;at:3!i
?^ise I and Phase Ii 2ata S
^isk flssesstent (Fi.iai): Lanifill Contents
uctrabie Unit
Site Activity Loos: Phast I and Phast Ii
"?
Soil :ii5ie Screening Log: Phase i and Phase
Ii Rendiai Investiqation
Surface Soil, Pond and River Satoii
Collection Logs: Phut I and Phase II
Rendial Investiqation
82
r* ;*/i:/95. 3:!nfer, «., HDIffi Stkora, X., U.S. EPA FAX Transiittal Forwrdinq Attached April 11.
1993 RONft Reurandui re: flOW/ERO's Revu* of
the Revised Risk Assessment
71 04.'27''?3 ^enska, «., Black i Sovak, D., U.S. EPA Letter Forwrdinq Attached Public Notice for
Veatch «ast« the Bar 11. 1993 Public Beetinq
Science. Inc.
*' :!.;vO..'9« j.s. E?A
riblic
Praoosed Plan
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u.s.. EPA ADMINISTRATIVE RECC-.D
GUIDANCE ADDENDUM
ROO wELL INTERNATIONAL CORPORATION
ALLEGAN. MICHIGAN
i ORIGINAL
05/O3/95
AUTHOR
'. !7.'~!.-:! ';.:. :r*/C:ii£.'.
a . r
"... 3- ci. L .-;
tetc'ircui r?: -.lan -sjlih Evaiiii::-;*
•3-:ii. Su:::iie^t3i :u;:r:2: '-'.rSird
Ss'aalt Esses..*? r3:t:rs' .'"SMER :irs:*.iv8
;J.S. Erfl
.3. s?fl/SS>iES U.3. EPA
U.S. EPl»
r»: riu«n Hgiitfi Evaiuatisn
nanuii. Part 8: 'Ceviiooitnt cf Risk Based
Prelinnarr i>efffdiat::n ioali' (OSIER
Oinctivt 935.7-018)
Suidaace
to M65: Calruiatina the Ccncentratiar. Ten'
[Intinittent Bulletin Volme 1, Huibtr 1]
(Publication ?3!.7-v31J
Prsvisiona! Saidince far Huautititivs Sisk
Asiessient o* B3:ycy:ii-: ^r
ai
;:/C4/«< ^NR/EPI
;:, :4/r*
nDim
"UUfi
flEPH >ersticra! "eKrandm 113: 'Cefault Z
Type A Cleanup Criteria*
HERA Cperatisnai nnorandua 16 (Revision 3;: 43
'Analytical Jet set ion Level Guidance for
Enviranwntal Ccr.taiination Response.
Activities U-isr 4C: -37 Rules'
tEH.a Ozenti.-ai !?9israr.!M 18 Hsvisis,- :;:
•T/je B Cr:tsr:i Saiss :?9.5707. :??.;71i:::,
13
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'".'.'.z' :•'•.'.:':•' •!:«•• !:*=:
C::tis:
:3'.ri".LI. -:i2 :i5SC "11""..
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
ROCKWELL INTERNATIONAL CORPORATION
ALLEGAN, MICHIGAN
UPDATE *1
06/27/95
AUTHOR
?ECIP!EMT
T!TLE.'Dt!CS!?T!ON
PASES
05/00.-' 5 5
Ulaiazoo Sod and
3un Club
05/04/95 J.3. EPA.
05/04/95 U.S. EPA
4 05/11/95 U.S. EPA
Sovak, 3.. J.s. EPA wetter re: Public Coueni on the Prisosed
Plan far the Landfill C:ntents Operable Unit
Public
Public
Public
Public Notice Announcing the Nay 11. 1995
Public Meeting and 30 Day Public Coiient
Period on the Prasosed Plan for the Landfill
Contents Qperabli Unit (Kalaeazoo Gazette)
Public Notice Announcing the Hay 11, 1995
Public Meeting and 30 Day Public Couent
'eriod on the Proposed Plan for the Landfill
Content! Operable Unit (Allegan County Ne«s)
Transcript of Nay 11, 1995 Public Meeting on
the Proposed Plan for the Landfill Contents
Operable Unit
5 05/22/95 EdmrdJ, 3., Allegan Novak, 0., U.S. EPA Letter re: Public CoMint on the Proposed
Resident Plan for the Landfill Contents Operable Unit
6 Oa/02/9! QeFouM. T., Rockwell Novak, 0., U.S. EPA Letter Forwarding Attached REflCOR and Chei
International Risk's Junt 2, 1995 Coiitnti on the Proposed
Corporation . Plan for the Landfill Contents Operable Unit
7 06/05/95 Jones, S., Sikora, K., U.S. EPA Letter re: Store Hater Drainage at the
Consulting Engineer Landfill Operable Unit
55
11
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COMPENDIUM OF CERCLA RESPONSE SELECTION
GUIDANCE DOCUMENTS
:RCLED ITEMS ARE INCORPORATED BY REFERENCE
INTO THE ADMINISTRATIVE RECORD
DOCUMENTS MAY BE VIEWED AT
U.S. EPA REGION 5
77 W. JACKSON BLVD.
CHICAGO, IL 60604-3590
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(•Art Hi
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ROCKWELL INTERNATIONAL LUKI'UUA I 1 UN
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ALLEGAN, MICHIGAN
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