EPA/ROD/R05-02/065
2002
EPA Superfund
Record of Decision:
AIRCRAFT COMPONENTS (D & L SALES)
EPA ID: MI0001119106
OU02
BENTON HARBOR, MI
09/25/2002
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
RECORD OF DECISION
Selected Remedial Alternative
for the
Chemical Operable Unit (OU #2) of the
Aircraft Components, Inc. Superfund Site
Benton Township, Berrien County, Michigan
September 2002
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TABLE OF CONTENTS
Section Page
I. Declaration iii
II. Administrative Record Index v
III. State Letter of Concurrence vii
IV. Glossary ix
V. Decision Summary 1
A. Site Location and Description 1
B. Site History and Enforcement Activities 2
Site History 2
Enforcement 2
Previous Site Cleanup Actions 3
C. Community Participation 3
D. Scope and Role of the Chemical Operable Unit (OU #2) 4
E. Site Characteristics and Investigation Results 4
F. Current and Potential Future Land and Resource Uses 6
G. Summary of Site Risks 7
Chemicals of Concern 7
Fate and Transport 8
Migration Pathways 9
Exposure Assessment 9
Human Health Risk Characterization 10
Basis For Action 11
Ecological Risk Characterization 11
H. Remedial Action Objectives 12
I. Description of Alternatives 12
Alternative 1 (No Action) 13
Alternative 2 13
Alternative 3 14
Common Elements/Distinguishing Features 15
J. Comparative Analysis of Alternatives (The Nine Criteria) 15
K. Principal Threat Waste 18
L. Selected Remedy 18
Description of Alternative 3 19
M. Statutory Determinations 23
N. Documentation of Significant Changes 24
VI. Responsiveness Summary 25
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Figures
Figure 1 - Site Map
Figure 2 - Soil Borings Location Map
Figure 3 - Groundwater Wells Location Map
Figure 4 - Surface Water and Sediment Sample Areas
Figure 5 - Alternative 3
Tables
Table 1 - Chemical Compounds in Soil
Table 2 - Chemical Compounds in Groundwater
Table 3 - Chemical Compounds in Sediment
Table 4 - Compounds of Concern
Table 5 - Summary of Actual or Potential Risks
Table 6 - Summary of Ecological Risks
Table 7 - Evaluation of Alternatives - The Nine Criteria
Table 8 - Cost Estimate Summary for Alternative 3
Table 9 - Cleanup Levels for Chemical Compounds
Table 10 - Applicable or Relevant and Appropriate Requirements
VII. Appendix 1 - Site History for the Radiation Operable Unit A-l
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DECLARATION
Selected Remedial Alternative for the
Chemical Operable Unit of the
AIRCRAFT COMPONENTS, INC. SITE
Benton Township, Berrien County, Michigan
Statement of Basis and Purpose
This decision document presents the selected remedial action for the chemical operable
unit of the Aircraft Components, Inc. (ACI) site, Benton Township, Berrien County,
Michigan (CERCLIS identification number MID0001119106). The U. S. Environmental Protection
Agency (U. S. EPA), in consultation with the Michigan Department of Environmental Quality,
chose the remedy in accordance with 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. Our decision is based on the
Administrative Record for the ACI site.
Assessment of the Site
The response action selected in this Record of Decision is necessary to protect the public
health or welfare or the environment from the actual or threatened release of hazardous
substances into the environment.
Description of the Selected Remedy
The selected remedy is the final cleanup action for the chemical operable unit at the ACI
site and consists of the following components:
• the excavation and off-site disposal of metals- and semi-volatile organic
compound-contaminated soil which exceed clean-up standards;
• the implementation of an in situ groundwater cleanup remedy to biodegrade volatile
organic compounds in the groundwater beneath the site to meet groundwater clean-up
standards;
• the periodic monitoring of groundwater guality beneath the site to ascertain that
the cleanup is occurring; and,
• the use of institutional controls to help prevent human exposure to any residual
contaminants at the site following the completion of remedy construction.
The selected remedy is the final remedial action for the ACI site.
Statutory Determinations
The selected remedy is protective of human health and the environment, complies with
federal and state requirements that are applicable or relevant and appropriate to the
remedial action, is cost-effective, and utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable. The selected remedy, however,
cannot satisfy the statutory preference for treatment as a principal element of the remedy
because U. S. EPA determined that there are no wastes at the site identified as principal
threats under the chemical operable unit.
U. S. EPA will perform a statutory five-year review of the remedial action for the
chemical operable unit because this remedy will result in hazardous substances remaining
on-site in excess of levels allowing for unlimited use of the site and unrestricted
exposure to the residual chemical contaminants.
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ROD Data Certification Checklist
The following information is included in the Decision Summary section of this Record of
Decision for the chemical operable unit. Additional information is also included in the
Administrative Record for the ACI site (see attached index).
E. The chemicals of concern and their concentration levels
F. Baseline risks represented by the chemicals of concern
G. Cleanup levels established for the chemicals of concern and the bases for these
levels
H. How source materials constituting principal threats are addressed
I. Potential land use that will be available at the site as a result of the selected
remedy
J. Estimated capital and operation and maintenance costs for the remedy
K. Key factor(s) that led to selection of the remedial action for the chemical operable
unit
State Concurrence
The State of Michigan has indicated its intention to concur with the selected remedy. The
Letter of Concurrence will be attached to this Record of Decision upon receipt.
William E. Muno^Oirector 7Dare
Superfund Division
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
AIRCRAFT COMPONENTS, INC. SITE
CHEMICAL OPERABLE UNIT (OU #2)
BENTON HARBOR, BERRIEN COUNTY, MICHIGAN
ORIGINAL
JULY 24, 2002
NO.
1
DATE
AUTHOR
RECIPIENT
03/00/02 Roy F. Weston, U.S. EPA
Inc.
05/00/02 Roy F. Weston, U.S. EPA
Inc.
05/00/02 Roy F. Weston, U.S. EPA
Inc.
06/18/02 Roy F. Weston, U.S. EPA
Inc.
07/00/02 U.S. EPA Public
TITIiE/DESCRIPTION PAGES
Risk Assessment Report for 514
the Aircraft Components
Site
Remedial Investigation 588
Report for the Aircraft
Components Site: Volume I
(Text, Tables and Figures)
Remedial Investigation 522
Report for the Aircraft
Components Site: Volume II
(Appendices)
Feasibility Study Report 531
for Operable Unit #2 at
the Aircraft Components
Site
Proposed Plan for the 8
Aircraft Components Site
UPDATE #1
AUGUST 15, 2002
07/31/02 U.S. EPA
Public
Transcript for the July
31, 2002 Public Meeting
re: the Aircraft
Components Site
32
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State concurrence letter is pending.
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Glossary
Aircraft Components, Inc. Site
Benton Township, Berrien County, Michigan
Note: The following terms or expressions (highlighted in bold as they initially appear in
the Decision Summary text) may be used throughout this document:
Carcinogenic risk = The incremental probability that an individual will develop cancer
over a lifetime as a result of exposure to a carcinogen. A risk number is usually
expressed in scientific notation (e. g., 1x10-6) and is referred to as an "excess lifetime
cancer risk" because it would be in addition to the risk of developing cancer that
individuals face from other causes such as smoking or exposure to too much sun. An excess
lifetime cancer risk of 1x10-6 indicates that an individual experiencing the reasonable
maximum exposure to a carcinogen at a site has an extra 1 in 1,000,000 chance of
developing cancer over ones lifetime. (The probability of an individual developing cancer
from all other causes has been estimated to be as high as one in three.) U. S. EPA
generally cleans up Superfund sites to achieve a carcinogenic risk range of 1x10-4 to
1x10- 6 excess lifetime cancer risk.
gram = g = Metric unit of mass and weight measurement (about 28.3 grams eguals one ounce).
Hazard Index = HI = The ratio between the amount of a non-carcinogenic chemical
contaminant that an individual may be exposed to at a site to the amount of the
contaminant that causes a toxic reaction within the body. An HI value of 1 (one) or more
means that there is enough contaminant at the site to cause a toxic reaction in a person
should one be exposed to the contaminant. U. S. EPA generally cleans up Superfund sites to
achieve a hazard index of less than 1 for non-carcinogenic compounds.
kilogram = Metric unit of mass and weight measurement egual to 1000 grams (about 2.2
pounds or about 1 liter of pure water).
liter = L = Metric unit of volume measurement (about 3.78 liters eguals one gallon).
micro = u = One millionth (1 E-6) part of; 1 microgram (ug) is one millionth of a gram.
milli = m = One thousandth (1 E-3) part of; 1 milligram (mg) is one thousandth of a gram.
Operable Unit = OU = U. S. EPA sometimes divides up a complex cleanup site into discrete
portions, termed operable units, to better manage the overall cleanup action. At this
site, OU 1 is the Radiation Operable Unit and OU 2 is the Chemical Operable Unit, meaning
that all radiation problems were handled under OU 1 and the rest of the site was handled
under OU 2.
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DECISION SUMMARY
Aircraft Components, Inc. Site
Berrien County, Michigan
A. Site Location and Description
The Aircraft Components, Inc. (ACI) site is located on the outskirts of Benton Harbor at
671 North Shore Drive in Benton Township, Berrien County, Michigan (see figure 1). The
site is a 17-acre parcel of land adjacent to a residential area, and is bounded on the
south by the Paw Paw River, to the west by North Shore Drive, and to the north by Ridgeway
Drive. Lake Michigan, several schools, a hospital, and many residences are located within
a one-mile radius around the site and an estimated population of 12,000 lives within the
Benton Harbor area.
The western portion of the ACI site contains three (formerly five) interconnected main
buildings - two are partially-dilapidated single-story brick structures with concrete
basements and one building is a two-story glass-sided structure with a concrete basement.
The site also has two Quonset huts and other miscellaneous structures on it. Constructed
in the 1910s, the main buildings were used by various manufacturing concerns, including a
plating facility, until the mid-1950s, when Aircraft Components, Inc., a mail-order
airplane parts resale business, occupied the property. The site was sold to D&L Sales,
Inc. in the early 1990s.
The site is primarily flat, although Ridgeway Drive is atop a steep 50-foot bluff that
marks the northern boundary. The Paw Paw River marks the southern boundary at the edge of
a steep bank. The eastern half of the site is densely wooded and contains a wetland that
is fed by a culvert that drains a spring from the Ridgeway Road area at the top of the
bluff.
Numerous small debris piles containing bricks, shingles, and paint cans dot the property
and tires and empty paint cans have been discarded in the wetland. The bluff leading up
towards Ridgeway Road is littered with discarded household appliances, tires, etc.,
evidence of unrestricted dumping from the residential area.
The ACI site CERCLIS identification number is MI0001119106.
U. S. EPA is the lead agency and the Michigan Department of Environmental Quality (MDEQ)
is the support agency. To date, U. S. EPA has used Superfund trust fund monies to perform
a time critical removal action, a non-time critical removal action, a remedial
investigation and feasibility study, and a remedial design ( for the radiation operable
unit) at the ACI site. U. S. EPA is also prepared to spend Superfund trust fund monies to
perform the remedial action for the radiation operable unit beginning in September 2002.
B. Site History and Enforcement Activities
1. Site History
(Please see Appendix 1 for a brief recount of the site history for the radiation operable
unit.)
U. S. EPA Region 5 completed a Hazard Ranking System scoring package and nominated the ACI
site for inclusion on the National Priorities List (NPL) in Fall 1995. NPL final rule
listing of the site occurred on June 6, 1996, and publication in the Federal Register (FR)
occurred June 17, 1996 (61 FR 30510). The effective date of NPL listing was 30 days
following FR publication.
U. S. EPA, in consultation with MDEQ, began a remedial investigation (RI) at the ACI site
in 1998 at about the same time that we were performing the radiological removal action
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(see Section B. 3., below). Shortly thereafter, we found the site to have multiple
contaminant-problem areas, so we divided the site into two discrete phases, or "operable
units," for the purpose of more easily managing the site-wide response actions. We named
the ACI site operable units the "radiation operable unit" and the "chemical operable
unit." In March 2000, we completed our investigation of the radiation levels at the site
and issued the first Record of Decision (ROD), for the radiation operable unit, in
September 2000. The remedy we selected in the first ROD is the final remedial action for
the radiation operable unit and calls for the residual radium-226 levels at the site to be
cleaned up to a level that would allow U. S. EPA, in consultation with MDEQ, to release
the site to the owner for unrestricted use in terms of radiologic contamination.
U. S. EPA, in consultation with MDEQ, completed the third and final phase of the RI for
the chemical operable unit in May 2002. We then completed a feasibility study (FS) for
the chemical operable unit in mid-June 2002.
2. Enforcement
U. S. EPA identified several potentially responsible parties (PRPs) at the ACI site in
1996. These PRPs are D& L Sales, Inc. (current site owner) and U. S. Department of Defense
(DOD) agencies or organizations. At that time, U. S. EPA determined that it was not likely
that these PRPs would be willing and/or able to properly and promptly perform the
radiation removal actions or perhaps any other cleanup actions at the site.
U. S. EPA has issued general notices of liability and information requests to D&L Sales,
Inc., and the DOD. At present, U. S. EPA and U. S. Department of Justice (DOJ) counsel are
engaged in cost recovery discussions with a DOD agency, the Defense Reutilization and
Marketing Services (DRMS), and DOJ defense. The parties have agreed to exchange
information and evaluate the liability of DRMS and other DOD agencies.
3. Previous Site Cleanup Actions
U. S. EPA conducted a limited time critical removal action in July 1995 to stabilize and
secure portions of the ACI site. We installed a gate at the entrance of the access road
onto North Shore Drive on the west side of the site and we boarded up several broken
windows and doors on some of the site buildings. We also posted radiation warning signs on
the buildings and covered a radioactive ash pile and enclosed it within a fence. Lastly,
we containerized and staged in a secure area small amounts of waste material pending later
disposal.
U. S. EPA performed a detailed site inspection in February 1996. Later, we signed a
removal action memorandum in September 1996 and began the removal and off-site disposal of
radioactive airplane gauges and associated debris in July 1997. We completed the last
phase of the removal action in March 2000. Cleanup staff gathered up and disposed of,
off-site, many hundreds of radioactive parts and undertook initial decontamination steps
in some of the site buildings to reduce the risk of a large-scale release of radiation
into the environment. We halted the removal action in March 2000 when it became apparent
that it was not cost-effective to decontaminate the remaining site buildings and that
another radiation cleanup plan was needed.
The final radiation operable unit cleanup action (selected in the first ROD) is
tentatively scheduled to begin in late September 2002 and be completed by December 2002.
C. Community Participation
U. S. EPA, in consultation with MDEQ, made the Remedial Investigation Report and the
chemical operable unit Feasibility Study Report and Proposed Plan available to the public
for review and comment in July 2002. These documents can be found in the Administrative
Record file and the information repository maintained at the U. S. EPA Records Center at
U. S. EPA Region 5, 77 W. Jackson Blvd., Chicago, IL and at the Benton Harbor Public
Library, 213 E. Wall St., Benton Harbor, MI. We placed a notice of the availability of
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these and other documents in the Saint Joseph Herald- Palladium, a newspaper of wide
circulation, in August 2002.
U. S. EPA opened a public comment period on the Proposed Plan from July 24 to August 23,
2002. In addition, we held a public meeting on July 31, 2002, at the Benton Harbor
Library, in an attempt to present the Proposed Plan to a broader community audience than
that which had already been involved at the site. At this meeting, representatives from U.
S. EPA and MDEQ answered guestions about the actual or potential health risks at the site
and the remedial alternatives that the agencies evaluated in response to those risks. Our
responses to public comments received during the comment period are included in the
Responsiveness Summary section of this Record of Decision.
D. Scope and Role of the Chemical Operable Unit
The chemical operable unit consists of the study and cleanup, if necessary, of
nonradiologic contamination (e.g. heavy metals and volatile organic compounds) which may
exceed human health or ecological risk- based cleanup levels in the soil and groundwater
at the site. The chemical operable unit remedial action is the second and final cleanup
action that U. S. EPA would undertake at the ACI site.
E. Site Characteristics and Investigation Results
As discussed above, the ACI site is a 17-acre property located adjacent to the Paw Paw
River (see Figure 1). One portion of the site contains low-grade wetlands and the rear
areas are forested. Much of the site is within the 100-year flood plain and the soil
layers beneath the site are primarily fluvial in origin. The upper aguifer is unconfined
and the water table is at about 7-12 feet below ground surface. Generally, the direction
of groundwater flow is south from the northern bluff area beneath the site and into or
towards the river.
U. S. EPA, in consultation with MDEQ, performed a number of field investigative tasks to
determine the nature and extent of any chemical contamination in these areas and the rates
at which any contaminants may be moving off-site. We used this information to perform an
ecological assessment, the characterization and estimation of the potential adverse
effects that site contaminants may have on local plants and animals, and a baseline risk
assessment, the characterization and estimation of the potential adverse effects that site
contaminants may have on human health in the absence of any further cleanup actions (see
Section G, Summary of Site Risks).
The field investigative tasks included:
i. Geophysical survey - We used a conductivity measurement device and a metal detector
( magnetometer) to determine whether there were any areas of buried wastes in
disposal drums 1 on site;
ii. Soil sampling - We took 76 soil borings on and near the site at various depths to
determine the thickness of soil layers, the distance to the groundwater table, and
if any chemical contaminants were present in the soil (see Figure 2);
iii. Groundwater sampling - We placed 23 groundwater wells in the ground to determine the
direction of groundwater flow, the thickness of the aguifer, to monitor for chemical
contaminants in the groundwater, and to see if any groundwater contaminants beneath
the site were moving off-site (see Figure 3);
1 We were investigating a report from a former site worker that there may have been
55-gallon disposal drums of plating wastes buried at the ACI site.
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iv. River and wetland water and sediment sampling - We took 23 river and 15 wetland
sediment samples and 10 river and 3 wetland water samples to determine if these
areas were impacted by chemical contaminants (see Figure 4); and,
v. Elevation surveys - We performed a number of surveys to locate site infrastructure
and sampling points on our maps, help us determine the direction of groundwater
flow, and aid in the design of the cleanup actions.
The results of our investigations are summarized below.
Magnetometer/Conductivity Surveys
U. S. EPA believes that the results of our conductivity and metal detection surveys show
that there are no areas with buried drums beneath the site. We did have some high
magnetometer and conductivity readings, but each time we were able to attribute them to
adjacent structures (such as the metal-sided Quonset huts) or fences. Other readings that
were slightly higher than background levels were very isolated and we were able to
attribute them to visible, non-hazardous metallic surface debris.
Soil Borings
U. S. EPA analyzed a total of 63 soil samples for chemical compounds and then we compared
the results to state and federal screening levels. The results of our soil sampling rounds
show, based on the chemical concentrations we found and other factors such as the number
of sampling locations with results above screening levels, that benzo(a) pyrene, a
semi-volatile organic compound (SVOC) , - chlordane, a pesticide, and the heavy metals
lead, mercury, arsenic, and selenium, are present in the surface soil (generally 0-2 feet
deep) in scattered locations above concentrations of concern (see Table 1 and Figure 5).
The results of our soil sampling rounds show that polychlorinated biphenyls (PCBs) and
volatile organic compounds (VOCs) are not chemicals of concern in the soil at the site. We
found no PCBs in any soil samples and only two soil samples had very low levels of
tetrachloroethene (PCE), a chlorinated volatile organic compound (VOC), in them.
U. S. EPA calculates that about 3800 cubic yards of soil are impacted by chemical
compounds at or above the selected soil cleanup levels (Table 9).
Groundwater Sampling
U. S. EPA analyzed 56 groundwater samples for chemical compounds and then we compared the
results to state and federal screening levels. We found the groundwater in one area of the
site to be contaminated with several chlorinated-VOCs, likely a degreasing solvent and its
breakdown products (see Table 2 and Figure 5), down to at least 80 feet in depth. To a
lesser extent, we found an occasional heavy metal result above screening levels in the
groundwater samples we analyzed. Because the results for metals are sporadic and because
we found some metals to be either naturally-occurring or found at similar concentrations
upgradient from the site, we could not define a metals groundwater contaminant plume.
Also, the results of our groundwater level measurements show that groundwater generally
flows from the north bluff area to the south under the site towards and likely into the
Paw Paw River.
U. S. EPA does not believe that there is a major source (principal threat) of metal
contaminants in the soil or groundwater at the site because the respective sampling
results were not indicative of results one would expect had there been widespread disposal
of plating wastes at the site, for example (none of the heavy metal soil sample analyses
results exceeded 900 mg/kg in the soil, levels generally found at such sites).
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Sediment and Surface Water Sampling
The results of our river and wetland sediment and surface water sampling rounds show that
one small area of the Paw Paw River sediment has high levels of lead and other heavy
metals in it. The impacted sediments seem to be indicative of a fill material placed in
the area to create more useable land space sometime very long ago and are not an area of
waste dumping. The high levels of metals in the sediment contribute to elevated levels of
metals in the river water directly above the impacted sediment due to the scouring and
mixing action of the river water. We also found that the wetland sediments are impacted by
heavy metals and perhaps benzo(a) pyrene to a smaller extent. See Table 3 and Figure 5.
U. S. EPA calculates that about 150 cubic yards of river and 2750 cubic yards of wetlands
sediment are impacted by chemical compounds.
F. Current and Potential Future Land and Resource Uses
The ACI site is zoned commercial-industrial, and residential and other commercial land
surrounds the property. With its location next to the Paw Paw River, U. S. EPA assumes the
site could be a candidate for commercial redevelopment or for conversion to park land in
the future. (A nearby "Brownfields" redevelopment project (the "Edgewater Project") is
already underway.) Based on current zoning and flood plain considerations, we set cleanup
goals for the chemical operable unit by anticipating a future commercial/industrial or
perhaps recreational use for the property. We did not assume a future residential use due
to the current commercial/industrial zoning and because much of the site is within the
100-year flood plain.
The groundwater beneath the site is not currently used for drinking; however, a few homes
on Ridgeway Drive and further north are on private wells. Since the city of Benton Harbor
is adjacent to the site, municipal water service is assumed to be readily available at the
site. Site groundwater is potentially available for beneficial uses such as drinking or
irrigation, once cleanup goals are met, but the flood plain designation could limit these
uses somewhat.
G. Summary of Site Risks
U. S. EPA evaluated the levels of chemical compounds found in site soil, sediment, and
groundwater to determine the actual or potential risks to human health and the
environment. First, using screening levels, we evaluated our sample results to identify
chemical compounds of concern, e.g. those compounds that exceeded health-based levels at
the site. Next, we evaluated contaminant fate and transport factors to determine whether
the chemicals of concern were potential short-, medium-, or long-term risks at the site.
We then examined potential pathways of concern to human health and the environment under
current and future site-use scenarios in an exposure assessment. Lastly, we applied the
results of the above steps to guantify actual or potential risks to human health by
combining exposure level assumptions with estimated carcinogenic risk or toxicity factors
for the chemicals of concern.
Chemicals of Concern
Soil
The chemicals of concern in site soil include the heavy metals, mercury and selenium, and
to a lesser extent, lead. These metals were found in defined areas of the site at levels
that exceed screening levels. We found other metals, such as cobalt, in site soil above
screening levels, but we found them at similar concentrations in upgradient, offsite
samples as well. (This means that the site is not a likely source of cobalt
contamination.)
Other chemicals of concern in site soil include benzo(a) pyrene, a semi-volatile organic
compound (SVOC) associated with coal tar, and -chlordane, a pesticide. We found low levels
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of PCE in two, isolated soil samples, and we do not consider it or other VOCs to be a
chemical of concern in site soil.
Groundwater
The chemicals of concern in groundwater are VOCs including trichloroethene (TCE)
and tetrachloroethene (PCE) and their respective breakdown products: 1,1-dichloroethene
(1,1-DCE), vinyl chloride, and cis-1,2-dichloroethene (cis-1,2-DCE) . We found very high
levels of these VOCs in several monitoring wells near the river.
We found slightly elevated levels of heavy metals in isolated groundwater samples from
the site, including in upgradient areas, but because heavy metals are not indicative of
widespread contamination, they are not chemicals of concern in site groundwater. 2
River and Wetlands
The chemical of concern in Paw Paw River water and sediment is the heavy metal, lead. Lead
is found in one area only (sample area SD-02, see Figure 4) and is not indicative of
widespread river sediment contamination. Possibly due to scouring, a river water sample
taken in the area of SD-02 contained lead and other heavy metals above upgradient or
background levels.
The heavy metals lead and mercury are chemicals of concern in the wetland sediment.
Potential chemicals of concern in the wetland surface water include chloroform and
bromochloromethane - both are VOCs known as trihalomethanes (THM) and are byproducts of
municipal water supply chlorination. We found these VOCs at very low levels in the
wetlands but the source of these compounds is unknown.
Table 4 summarizes the chemicals of concern at the ACI site.
Fate and Transport
Volatile Organic Compounds
Volatile organic compounds are chemicals of concern in the groundwater and, to a lesser
extent, the wetland surface water. Readily soluble, the VOCs will tend to move along with
groundwater or surface water flow. VOCs tend not to bioaccumulate in organisms and they
will biodegrade under proper conditions. Because of the rate of groundwater flow beneath
the site, U. S. EPA believes that the VOCs in the groundwater are unlikely to attenuate
very guickly and will persist for years to come.
Semi-Volatile Organic Compounds
Benzo(a) pyrene, an SVOC, tends to adhere to soil and sediment particles and therefore
the mobility of this compound is low. Bioaccumulation is moderately likely to occur, and
it may biodegrade slowly under aerobic conditions. A chemical of concern in surface soil
and in the sediment in the wetlands, benzo(a) pyrene, is unlikely to attenuate very
guickly and will persist for years to come.
2 For example, thallium was found at very low levels in two isolated site monitoring
wells in only one of three groundwater sampling rounds. Because of its toxicity,
thallium was carried forward as a potential chemical of concern in the risk
assessment. However, because it was detected in few, if any soil samples, U. S.
EPA did not carry it forward as a compound that could drive a cleanup action at
this site.
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Metals
Lead, mercury, and selenium are examples of heavy metals found at the site. Generally
insoluble in groundwater and tending to sorb onto clay particles in the soils, heavy
metals are likely to persist in the environment. Chemicals of concern in surface soil and
sediments, metals may be expected to bioaccumulate. Inorganic mercury compounds can be
biotransformed to more mobile and toxic organo-mercury compounds under proper conditions.
Migration Pathways
Contaminants may move from the site into the environment in several ways. U. S. EPA
performed a pathway analysis to determine whether off-site areas are potentially at risk
of being affected by on-site contaminants. We identified the following contaminant
migration pathways at the site:
Soil to Groundwater: Rainwater or snow melt may dissolve chemicals of concern
(metals) in surface soil and move them into the groundwater beneath the site;
Soil to Air: The wind may move chemicals of concern (metals, SVOCs) from the soil
into the air on dust particles;
Soil to Surface Water: Precipitation may move chemicals of concern (metals, SVOCs)
in surface soil into surface water bodies by erosion;
Sediment to Surface Water: Contaminated sediments may either leach chemicals of
concern into the surface waters above it or the water may move the contaminants by
eroding sediment particles as it moves over the sediment;
Groundwater to Air: Movement of dissolved chemicals of concern (VOCs) from the
groundwater into the air can occur at the water/air interface. This is a concern if
a building is built over a contaminant plume (VOCs may migrate into a basement
through cracks in the foundation and accumulate) or if excavation exposes
contaminated groundwater; and,
Groundwater to Surface Water: Chemicals of concern in groundwater (VOCs) could move
from the groundwater into the Paw Paw River as the natural flow of groundwater
occurs from the site towards and into the river.
Exposure Assessment
U. S. EPA examined potential pathways of concern to human health and the environment under
current and future site- use scenarios. Major pathways of concern for the actual or
potential exposure of nearby human populations, animals, or the food chain to hazardous
substances or pollutants or contaminants include the following:
Current Pathways
Inhalation or ingestion of dust containing chemicals of concern (SVOCs, metals) could
occur if people were to use those areas where surface soil is contaminated. Digging in
these areas could suspend dust particles into the air, causing them to be inhaled or
ingested.
Dermal contact with chemicals of concern (SVOCs, metals) could occur if people were to use
those areas where surface soil is contaminated. Digging in these areas could expose a
person to contaminants if one were to touch the soil. Wading in the wetland surface waters
could expose someone to very low levels of VOCs.
Future Pathways
Inhalation or ingestion of dust containing chemicals of concern (SVOCs, metals) could
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occur if people were to use those areas where surface soil is contaminated. Digging in
these areas could suspend dust particles into the air, causing them to be inhaled or
ingested.
Dermal contact with chemicals of concern (SVOCs, metals) could occur if people were to use
those areas where surface soil is contaminated. Digging in these areas could expose a
person to contaminants if one were to touch the soil. Wading in the wetland surface waters
could expose someone to very low levels of VOCs.
Ingestion of contaminated groundwater could occur if someone placed a drinking water well
within the VOC contaminant plume.
Human Health Risk Characterization
U. S. EPA evaluated the actual or potential risks to human health using the above exposure
and migration pathways assumptions under a number of plausible site use scenarios. We
evaluated a Residential Use exposure scenario, the most conservative 3 land use
assumption, a Recreational Use exposure scenario, and a Commercial/Industrial Worker
scenario. For each of these scenarios, we estimated the carcinogenic risk for cancer-
causing chemicals of concern to determine whether the risks fall outside the Superfund
target risk range of 1 xlO-4 to 1x10-6 and the Hazard Index (HI) for non-carcinogens to
determine whether the risk falls below the Superfund target HI of 1. Table 5 summarizes
our findings.
Generally, under the residential scenario, U. S. EPA assumed that residences would be
built on the site property and site groundwater used for drinking in absence of any
further cleanup actions. Here, future residents would be exposed to chemicals of concern
in site soils and in groundwater by dermal contact (dust, digging, showering), ingestion (
drinking water, dust), and inhalation (showering, dust). Although we do not believe that
this site would support a residential use, we evaluated the scenario to determine the
levels of chemicals of concern that would allow unlimited use of the site and unrestricted
exposure. The total estimated risks exceeded the target risk range and target HI under
this scenario (see Table 5).
Under the recreational scenario, U. S. EPA assumed that occasional site visitors would
be exposed to chemicals of concern in site soils and in surface water by dermal contact
(dust, digging), incidental ingestion (water, dust), and inhalation (dust). Estimated risk
almost exceeded the target risk range and did not exceed an HI of one (see Table 5).
Under the commercial/Industrial worker scenario, U. S. EPA also assumed that a site
business would use groundwater as a potable water source, potentially exposing workers to
VOCs in addition to the recreational user type risks. Estimated risk exceeded the target
risk range and target HI under this scenario (see Table 5).
Basis for Action
The estimated carcinogenic risks posed at the site by chemical contaminants under
plausible site use scenarios, including the commercial/industrial worker scenario, exceed
U. S. EPA's recommended carcinogenic risk range of 1x10-4 to 1x10-6 and/or the HI of 1.
Thus, the response action selected in this Record of Decision is necessary to protect the
public health or welfare or the environment from the actual or threatened release of
hazardous substances into the environment.
3 Cleaning up a site to "residential levels" means that after the cleanup is
completed, one could have unlimited use of the site and unrestricted exposure to
residual contaminant levels.
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Ecological Risk Characterization
U. S. EPA examined the potential risks to ecological receptors based upon the chemical
compound levels found in site soil and in the water and sediments of the Paw Paw River and
the wetlands. We assumed that terrestrial and aquatic species at the ACI site could be
exposed to chemical compounds through external direct contact, ingestion of impacted soil
and food, and inhalation of impacted dust. Using recommended dose limits of the various
compounds for terrestrial and aguatic biota, we concluded that there is a potential for
adverse effects caused by some of the chemical compounds (SVOCs, metals) in the soil and
in the Paw Paw River sediment. U. S. EPA's hazard guotient calculations for potential
ecological receptors at the site show that the chemical concentrations yield hazard
guotient values for some receptors that are above 1, the value at which adverse effects
could occur. Table 6 summarizes these findings.
H. Remedial Action Objectives
U. S. EPA's objective for the remedial action for the chemical operable unit is to remove
or reduce the levels of chemical contaminants at the site to levels that would allow the
property to be re-used for commercial/industrial purposes or as a recreational area and
to meet protective levels for ecological receptors. This means that once we complete the
chemical operable unit cleanup action, the residual levels of chemical compounds at the
ACI site would allow people to use the site under the recreational and/or commercial/
industrial exposure assumptions and not be exposed to contaminant levels that cause them
to exceed the Superfund site target risk range of 1x10-4 to 1x10-6 or an HI of 1. In
addition, ecological receptors would not be exposed to harmful levels of chemical
contaminants at the site. Finally, we would also meet applicable or relevant and
appropriate reguirements (ARARs) for environmental cleanup actions at the site.
Specifically, U. S. EPA's cleanup goals would be to restore the groundwater quality to
drinking water levels (protects future commercial/industrial workers, meets ARARs,
protects Paw Paw River water guality), restore wetland sediment and surface water guality
(meets ARARs, protects future recreational users, protects ecological receptors), restore
Paw Paw River sediment guality (meets ARARs, protects ecological receptors), and to reduce
chemical levels in soil (protects future recreational users or commercial/industrial site
workers and ecological receptors). (Section L: Selected Remedy contains cleanup levels for
each media - see Table 9).
I. Description of Alternatives
Due to the nature of the chemical contaminants at the ACI site, U. S. EPA evaluated a
limited number of clean-up alternatives in the Feasibility Study (FS) Report to meet the
above remedial action objectives. Since the site is partially within the Paw Paw River
100-year flood plain, we screened out on-site containment remedies for soil cleanup
actions and evaluated off site disposal remedies, instead. In addition, because the amount
of soil contamination is somewhat limited, we determined that treatment remedies would not
be cost-effective at this site.
U. S. EPA evaluated the following three alternatives in detail in the FS Report:
Alternative 1: No Action
Alternative 2: Soil Excavation and Disposal; Groundwater Pump and Treat
Alternative 3: Soil Excavation and Disposal; In Situ Groundwater Cleanup
Description of Remedial Components
Alternative 1: No Action
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U. S. EPA evaluated the No Action alternative for comparison only. Under this alternative,
we would take no further clean-up action to remove or contain the chemical contaminants at
the ACI site. This alternative is easily implemented and costs nothing. However,
potentially harmful levels of VOCs, SVOCs, and metals would remain on-site, and we would
recommend no future use of the affected soil or sediment areas and groundwater because of
the potential health risks that the contaminants may pose over the long term. We would
work with state and local governments and the land owners to implement institutional
controls, such as restrictive covenants, re-zoning restrictions, and/or deed notices
concerning land and groundwater use at the site to achieve protection of human health over
the short term. However, this measure would not protect ecological receptors from
potentially harmful exposures to site contaminants.
Alternative 2: Soil Excavation and Disposal; Groundwater Pump and Treat
Under this alternative, U. S. EPA would excavate contaminated soil and sediment and
dispose of it off-site. We would excavate approximately 3,750 cubic yards of metals-and
SVOC-contaminated soil, generally 0-2 feet deep, and dispose of it off-site, and we would
replace the excavated soil with clean topsoil to grade. We would also excavate 2,570 cubic
yards of metals-contaminated sediment from the wetland area and 150 cubic yards of
metals-contaminated sediment from the Paw Paw River, dewater it, and dispose of it
off-site.
U. S. EPA would also install two groundwater pumping wells and a treatment system
consisting of an air stripper to clean up the groundwater contaminant plume. The two wells
would be designed to pump 20 gallons of water per minute from the ground into the air
stripper, where the VOCs would be removed from the water. After treatment, the water would
be discharged into the Paw Paw River in accordance with reguirements recommended by the
state. We would perform periodic groundwater monitoring to chart the cleanup progress
until its completion.
This alternative would leave residual SVOC and metals in the soil and sediment at or below
a nominal Ix 10-5 risk to future recreational or site workers. It would not allow for
unrestricted use or unlimited exposure to residual soil contaminants. The groundwater
would be restored to protective status. U. S. EPA could complete all construction
activities for Alternative 2 in about six months after beginning them, but the groundwater
remedy would likely need to be operated for at least 20 years to reach cleanup levels. In
the interim, we would work with state and local governments and the land owners to
implement institutional controls, such as restrictive covenants, re-zoning restrictions,
and/ or deed notices concerning land and groundwater use at the site to achieve protection
of human health until groundwater cleanup levels are reached and to ensure future site
uses are compatible with the soil cleanup levels.
The estimated cost of Alternative 2 is $2.68 million with a $1.54 million capital cost and
a total present worth operation and maintenance (O&M) cost of $1.14 million. The O&M
cost estimate is based on an estimated annual cost of $82,000 over a 20-year period.
Alternative 3: Soil Excavation and Disposal; In Situ Groundwater Cleanup
Under this alternative, U. S. EPA would excavate contaminated soil and sediment and
dispose of it off-site. We would excavate approximately 3,750 cubic yards of metals-and
SVOC-contaminated soil, generally 0-2 feet deep, and dispose of it off-site, and we would
replace the excavated soil with clean topsoil to grade. We would also excavate 2,570 cubic
yards of metals-contaminated sediment from the wetland area and 150 cubic yards of
metals-contaminated sediment from the Paw Paw River, dewater it, and dispose of it off
site.
U. S. EPA would also employ an in situ reductive dechlorination and oxidation groundwater
cleanup method to restore the groundwater to protective status. Under this method, a
series of injections of a reductive dechlorination compound are made into the groundwater
contaminant plume to assist the naturally-occurring anaerobic bacteria in the ground to
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remove the chlorine atoms from the chlorinated-VOCs. The reductive chlorination compound,
when metabolized by the bacteria, acts as a source of hydrogen which the bacteria use to
partially or fully dechlorinate the PCE in series to TCE, then DCE, then vinyl chloride,
and then ethene. Following a reaction time of one year, an oxidation compound, if
necessary, is injected into the groundwater to assist aerobic bacteria in completing the
dechlorination of the intermediate VOCs down to ethene.
U. S. EPA estimates that it could take 2-4 years to reach groundwater cleanup levels under
this alternative. We would undertake a pilot study of this cleanup method to help us
optimize the clean-up method under the conditions at the site. After full-scale
implementation, we would perform periodic groundwater monitoring to chart the cleanup
progress until its completion.
This alternative would leave residual SVOC and metals in the soil and sediment at or
below a nominal Ix 10-5 risk to future recreational or site workers. It would not allow
for unrestricted use or unlimited exposure to residual soil contaminants. The groundwater
would be restored to protective status. U. S. EPA could complete all construction
activities for Alternative 3 in about six months after beginning them, but the groundwater
remedy would likely need another injection after one year and reguire a total of at least
2-4 years to reach cleanup levels. In the interim, we would work with state and local
governments and the land owners to implement institutional controls, such as restrictive
covenants, re-zoning restrictions, and/ or deed notices concerning land and groundwater
use at the site to achieve protection of human health until groundwater cleanup levels are
reached and to ensure future site uses are compatible with the soil cleanup levels.
The estimated cost of Alternative 3 is $3.1 million with a $2.75 million capital cost and
a present worth operation and maintenance (O&M) cost of $0.3 million.
Common Elements and Distinguishing Features of Alternatives 2 and 3
The common elements of Alternatives 2 and 3 are the method used to clean up the soil and
sediment contaminants and the need for institutional controls on the property to ensure
that future site use plans conform with the soil cleanup action. Both alternatives employ
excavation and off- site disposal of contaminated soil and sediment. The excavated
material can be disposed of in a Michigan Type II landfill as nonhazardous waste in
accordance with all ARARs. Following completion of the soil and sediment cleanup, a
restrictive covenant could be placed on the property to restrict future uses to those
conforming with the cleanup assumptions and/ or the local government could be approached
to place a re-zoning restriction on the property.
The distinguishing feature between the two action alternatives is the method used to clean
up the groundwater contaminant plume. Alternative 2 uses a standard pump and treat method
to achieve cleanup levels in about 20 years or more. Alternative 3, however, uses an
innovative technology to clean up groundwater in situ in about 2-4 years. While slightly
more costly overall to implement, Alternative 3 could provide guicker beneficial use of
site groundwater than Alternative 2.
J. Summary of Comparative Analysis of Alternatives
U. S. EPA evaluated the proposed alternatives using the Nine Criteria below.
1. Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether each alternative
provides adequate protection of human health and the environment and describes how risks
posed through each exposure pathway are eliminated, reduced, or controlled, through treatment,
engineering controls, and/or institutional controls.
Alternatives 2 and 3 are protective of human health and the environment because they
reduce or eliminate ingestion, inhalation, or dermal contact hazards by reducing on-site
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contaminants to recommended levels for future site uses. The No Action alternative is not
protective since contaminants would remain on-site above recommended levels.
2. Compliance with Applicable or Relevant and Appropriate Requirements
Section 121(d) of CERCLA and NCP § 300.430(f)(1)(ii)(B) require that remedial actions at
Superfund sites at least attain legally applicable or relevant and appropriate federal and
state requirements, standards, criteria, and limitations which are collectively referred to as
"ARARs," unless such ARARs are waived under CERCLA section 121(d)(4).
"Applicable" requirements are those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under Federal environmental or
state environmental or facility siting laws that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance found at a Superfund
site. Only those state standards that are identified by the state in a timely manner and that
are more stringent than Federal requirements may be applicable.
"Relevant and appropriate" requirements are those cleanup standards, standards of control, and
other substantive requirements, criteria, or limitations promulgated under Federal
environmental or state environmental or facility siting laws that, while not "applicable" to a
hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance
at a Superfund site, address problems or situations sufficiently similar to those encountered
at the Superfund site such that their use is well-suited to the particular site. Only those
state standards that are identified in a timely manner and are more stringent than Federal
requirements may be relevant and appropriate.
Compliance with ARARs addresses whether a remedy will meet all of the applicable or relevant
and appropriate requirements of other federal and state environmental statutes or provides a
basis for a invoking waiver.
Alternatives 2 and 3 will attain federal and state ARARs. The No Action alternative
(Alternative 1) will not meet ARARs.
3. Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to expected residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment over time, once
clean-up levels have been met. This criterion includes the consideration of residual risk that
will remain onsite following remediation and the adequacy and reliability of controls.
Alternatives 2 and 3 provide the same degree of long-term protection. These alternatives
reduce or remove risks associated with chemical compounds at the site by removing or
reducing the concentrations to below recommended levels. The No Action alternative
(Alternative 1) does not meet this criterion as levels would remain the same over a very
long period of time. Since chemicals of concern would remain on-site at levels that do not
allow for unlimited exposure and unrestricted use, U. S. EPA would reguire that a Five-
Year Review be performed to evaluate the effectiveness of Alternatives 2 and 3.
4. Reduction of Toxicitv, Mobility, or Volume Through Treatment
Reduction of toxicity, mobility, or volume through treatment refers to the anticipated
performance of the treatment technologies that may be included as part of a remedy.
Alternatives 2 and 3 include treatment to reduce the toxicity, mobility, or volume of
contamination as a component of the remedy. Alternative 3 provides a higher degree of
treatment because the VOCs are biodegraded to reduce their toxicity. Under Alternative 2,
the groundwater would be treated to remove VOCs from the water, but this technology merely
transfers the VOCs from the water into the air, where they are subject to dilution and
perhaps biodegradation in the atmosphere.
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Alternative 1 provides no treatment to reduce toxicity, mobility, or volume of site
contaminants.
5. Short-Term Effectiveness
Short-term effectiveness addresses the period of time needed to implement the remedy and any
adverse impacts that may be posed to workers, the community, and the environment during
construction and operation of the remedy until cleanup levels are achieved.
The initial construction activity for Alternatives 2 and 3 could be completed in
approximately 6 months. During this time, construction activity associated with excavation
and off-site disposal of soil and sediment would occur near the community. There would be
potential risks to construction workers as the work progresses; however, air monitoring,
both on-site and at the site, would be performed to detect unacceptable levels of dust.
Workers may be reguired to wear appropriate levels of protection to avoid exposure during
any excavation activity. Air monitoring and dust suppression measures will also be used to
ensure that adjacent residents and workers are protected.
The No Action alternative (Alternative 1) would not be an effective alternative because
current risks from inhalation, ingestion, or dermal contact with site contaminants would
remain.
6. Implementabilitv
Implementability addresses the technical and administrative feasibility of a remedy from design
through construction and operation. Factors such as availability of services and materials,
administrative feasibility, and coordination with other governmental entities are also
considered.
Alternatives 2 and 3 are easily implemented. All materials and services needed for
implementation of the cleanup action are readily and commercially available.
7. Cost
U. S. EPA estimates that it would cost $2.68 million to implement Alternative 2 and $3.1
million to implement Alternative 3. These cost estimates include capital cost estimates
and O&M of the groundwater cleanup remedy.
8. State/Support Agency Acceptance
MDEQ has expressed its support for Alternative 3 as a protective and cost effective remedy
for the chemical operable unit. MDEQ believes that the No Action alternative is not
protective of human health and the environment. MDEQ believes Alternative 3 is protective
of human health and the environment and that the selected remedy could clean up the
groundwater contaminant plume in less time than Alternative 2 if it performs as
anticipated.
9. Community Acceptance
The community expressed support for Alternative 3 during the public comment period. The
community did not consider the No Action alternative to be protective and recognized that,
while Alternative 3 would cost more to implement than Alternative 2, the groundwater
cleanup could be completed faster than under Alternative 2.
Table 7 below summarizes the evaluation of the clean- up alternatives versus the Nine
Criteria.
K. Principal Threat Wastes
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) establishes an
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expectation that U. S. EPA will use treatment to address the principal threats posed by a
site wherever practicable (NCP §300.430(a) (1) (iii) (A)). Principal threat wastes are those
source materials considered to be highly toxic or highly mobile that generally cannot be
reliably contained, or would present a significant risk to human health or the environment
should exposure occur. Remedies that involve treatment of principal threat wastes likely
will satisfy the statutory preference for treatment as a principal element.
U. S. EPA considered the radium- painted gauges that were removed for off-site disposal
during the removal action beginning in 1997 to be the principal threat waste at the ACI
site. These items presented a very high risk to future site users. We believe that the
metals and SVOCs in site soil and sediments may constitute a low level, long term threat
to human health or the environment, but they are not principal threat wastes. We do not
consider the groundwater contaminant plume to be a principal threat waste because we did
not find any evidence of dense non- agueous phase liguids (DNAPL) associated with the
contaminant plume. Thus, the statutory preference for treatment as a principal element
would not apply to this operable unit.
L. Selected Remedy
Rationale for Selection
U. S. EPA selects Alternative 3 - Soil Excavation and Disposal; In Situ Groundwater
Cleanup, to clean up the chemical operable unit waste at the ACI site. The No Action
alternative is not protective of human health and the environment and would not meet
ARARs. Both Alternatives 2 and 3, when completed, would protect human health and the
environment over the long term by removing potentially harmful levels of metals, SVOCs,
and VOCs from the site, meet ARARs, and be easily implemented in a short time period.
Alternatives 2 and 3 would use treatment technologies to reduce the toxicity, mobility, or
volume of VOCs at the site, although Alternative 3 would be more effective since the
groundwater cleanup method would help destroy the VOCs in the groundwater in situ whereas
groundwater pump and treat merely moves the VOCs from the groundwater into the air (at
regulated levels) without destroying them.
The decisive factor in our selection of Alternative 3 over Alternative 2 is its shorter
time period to achieve groundwater cleanup levels, despite its higher cost. U. S. EPA
estimates that Alternative 3 would cost about $400,000 more than Alternative 2 to
implement, but we believe the extra cost is acceptable since the site groundwater could
be cleaned up much guicker under Alternative 3 (2-4 years) than under Alternative 2 (20 or
more years). However, should Alternative 3's approach to groundwater cleanup later prove
to be not guite as successful as we think it would be, we would reevaluate the cleanup
method for means to complete the groundwater cleanup action within the targeted time
frame.
Description of the Selected Remedy
U. S. EPA would undertake the following to implement Alternative 3 (see Figure 5):
1. Site Access Restriction
U. S. EPA will need to maintain a safe working environment as the cleanup work
progresses. Accordingly, we will repair and maintain the chain-link fence that
encloses the northern and western areas of the site (roughly along the base of
the Ridgeway Drive bluff and along North Shore Drive) to limit access to the
site.
2 . Institutional Controls
U. S. EPA will work with state and local governments and the land owners to
place certain land-use restrictions on the property to ensure that groundwater
is not used as a drinking water source until cleanup levels are met and that
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the site is used for compatible purposes once the cleanup is completed. Such
restrictions will likely be a deed notice to alert the current and future
property owners to the presence of the groundwater contaminant plume until it
is cleaned up and governmental controls limiting groundwater use under state
groundwater-use regulations.
U. S. EPA will work with the current land owners to place a restrictive
covenant on the property to restrict future land uses to the current zoning
designation (commercial/industrial) and/or to future recreational uses due to
the estimated levels of residual contaminants ( mostly SVOCs) in the soils
following cleanup. We will work, too, with the local zoning board in
preventing re-zoning of the property without notice to us or the state.
3. Site Preparation
U. S. EPA will prepare the site for the cleanup action by clearing designated
areas of trees, brush, rubble piles, and other like items that may interfere
with the placement of the groundwater cleanup eguipment. We estimate that we
will need to clear about 4.5 acres of vegetation and that site preparation
will take about a week to complete.
4 . Excavation of Wetlands
U. S. EPA will clean up the on- site wetlands by excavating and removing
sediment that contain chemicals of concern above recommended levels. First,
we will de-water the wetlands by temporarily diverting the flow from the
outlet pipe that drains the spring at the top of the Ridgeway Drive bluff to
the Paw Paw River. We will also pump about 260,000 gallons of standing water
from the wetlands and drain it into the Paw Paw River (in accordance with the
substantive reguirements of a Michigan Pollutant Discharge Elimination System
(MPDES) permit, if necessary). This task should take about three days to
perform (concurrently with site preparation).
Next, U. S. EPA will excavate the wetlands sediments to a 2-foot depth using
conventional excavation eguipment. We will mix a drying agent, such as lime or
Portland cement, with the excavated sediment to reduce the free-liguids in the
spoils for ease of transport off-site. Based on the estimated surface area of
sediment targeted for cleanup, a 15% swell factor, and a 10% volume increase
due to mixing with a drying agent, we estimate that about 3250 cubic yards of
material will be disposed of off-site. We will take a number of verification
samples from the excavation to ensure that we have cleaned up all the impacted
sediments.
Following completion of the excavation and verification tasks, U. S. EPA will
place clean soil backfill into the excavation area to support re-vegetation of
the wetlands. We may need to mix mulch in with the soil as we backfill the
excavation. We estimate that we would use about 2800 cubic yards of topsoil to
complete the backfilling task. The excavation and backfilling tasks should
take about 27 days to complete.
Lastly, U. S. EPA, in consultation with the state, will restore the wetlands
by replacing the vegetation we removed with native plants and trees. We will
remove the temporary diversion of the outlet pipe to recharge the wetlands
with water, and we will monitor the re- vegetation progress for up to three
years to ensure recovery.
5 . Excavation of Soil
U. S. EPA will excavate impacted soil from five designated areas (Areas "A,"
"B," "C," etc. - see Figure 5) using conventional excavation eguipment.
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Generally, excavation will be to a 2-foot depth, except in Areas A and E where
we will further excavate down to 10 feet and 4 feet, respectively. We estimate
that we will remove a total of 4320 cubic yards of soil (including a 15%
expansion factor) for off-site disposal. We estimate that this task will take
about 16 days to complete.
U. S. EPA will dispose of the excavated material in a Michigan Type II
landfill as nonhazardous waste. We will dispose of the excavated material
concurrently with the excavation effort. After verifying that the excavation
task is complete by taking soil samples4 in the excavations, we will backfill
the areas to grade using clean soil. We will place grass seed and mulch on the
backfilled areas to re-vegetate them.
U. S. EPA will use standard controls to minimize releases or exposure to the
impacted soils as work commences. Some controls include dust suppression,
washing haul trucks prior to leaving the site, and following appropriate
health and safety precautions.
6. Excavation of River Sediment
U. S. EPA will clean up the Paw Paw River sediments by excavating the area
using standard construction eguipment. First, we will temporarily divert the
river flow around the designated area using cofferdams to help dewater the
sediments. Next, we will use a long- reach backhoe to excavate the river
sediments and place them into a holding area for mixing with drying agents.
Following completion of sediment removal and verification sampling, we will
backfill the excavation with clean soil. We estimate that we will remove about
150 cubic yards of sediment for disposal off-site. This task is estimated to
take about a week to complete.
7. Reduction Dechlorination in Groundwater
U. S. EPA will clean up the VOCs in the groundwater contaminant plume using
an in situ reduction dechlorination method. We will inject a food-grade
organic compound into the impacted groundwater zone to assist the
naturally-occurring bacteria in the ground to remove the chlorine atoms from
the chlorinated-VOCs in the groundwater. The reductive chlorination compound,
when metabolized by the bacteria, acts as a source of hydrogen which the
bacteria use to partially or fully dechlorinate PCE in series to TCE, then
DCE, then vinyl chloride, and finally to non- hazardous ethene. Following a
reaction time of one year, an oxidation compound, if necessary, is injected
into the groundwater to assist aerobic bacteria in completing the
de-chlorination of partially de-chlorinated VOCs down to ethene.
U. S. EPA estimates that it could take 2- 4 years to reach groundwater cleanup
levels under this alternative. We will undertake a pilot study of the cleanup
method to determine if the method will work under the conditions at the site
and to help design the most effective treatment procedures. After full- scale
implementation, we would perform periodic groundwater monitoring to chart the
cleanup progress until its completion.
4 U. S. EPA may consult or cite the state's "Verification Sampling Reguirements"
document to develop the soil sampling strategy to confirm that the cleanup is
complete.
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8 . Groundwater Monitoring
U. S. EPA will chart the progress of the groundwater cleanup action by
periodically taking groundwater samples and analyzing them for VOCs and for
several metals, as appropriate. We will install a small number of new
monitoring wells where needed to aid in this task.
9. Environmental Monitoring
U. S. EPA will chart the progress of the cleanup action with respect to
ecological receptors by taking several samples of Paw Paw River and wetlands
water from the former contaminant areas to verify that they are no longer
impacting water guality.
Summary of the Estimated Remedy Costs
Table 8 summarizes the major cost elements for Alternative 3.
Note: The information in Table 8 is based on the best available information regarding the
anticipated scope of Alternative 3. Changes in the cost elements may occur as a result of new
information and data collected during the engineering design phase of the cleanup action. U. S.
EPA may document major changes to the cost estimate, if any, in the form of a memorandum in the
Administrative Record file, an Explanation of Significant Differences, or a ROD amendment.
Table 8 presents an order-of-magnitude engineering cost estimate that is expected to be within
+50 to -30 percent of the actual project cost.
Expected Outcome of the Selected Remedy
After U. S. EPA completes Alternative 3, there will be residual SVOC and metals in the
soil and sediment at or below a nominal Ix 10-5 risk to future recreational or site
workers. We will also have restored the groundwater to protective status and other
beneficial uses. We could complete all construction activities for Alternative 3 in about
six months after beginning them; and, about one year later, we will then inject the second
part of the in situ groundwater remedy and monitor groundwater guality for at least 2-4
years as we reach groundwater cleanup levels.
Cleanup levels for the site are presented in Table 9, below. U. S. EPA believes that
residual chemical compound levels would be protective and that persons using the site
under a recreational scenario or a commercial/ industrial use would be exposed to levels
in the soil which represent an estimated risk of 1 x 10-5.
M. Statutory Determinations
Section 121 of CERCLA (42 U.S.C. §9621) and the NCP state that the lead agency must select
remedies for Superfund sites that are protective of human health and the environment,
comply with applicable or relevant and appropriate reguirements (unless a statutory waiver
is justified) , are cost-effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent
practicable. In addition, CERCLA includes a preference for remedies that employ treatment
that permanently and significantly reduces the volume, toxicity, or mobility of hazardous
wastes as a principal element and a bias against off-site disposal of untreated wastes.
The following sections discuss how Alternative 3 meets these statutory reguirements.
1. Protection of Human Health and the Environment
Alternative 3 will protect human health and the environment by removing or reducing the
chemicals of concern at the site to meet recommended cleanup levels. This will reduce the
threat of exposure to chemicals of concern via direct contact, ingestion, or inhalation.
U. S. EPA estimated that the actual or potential carcinogenic risk associated with these
exposure pathways is as high as 5 x 10-1. Alternative 3 will reduce the potential
-------
carcinogenic risks from exposure to site soils to about 1 x 10-5. This level falls within
U. S. EPA's target risk range of 1 x 10-4 to 1 x 10-6. Alternative 3 has no short-term
threats to human health or the environment that cannot be readily controlled as the
cleanup is implemented.
2. Compliance with Applicable or Relevant and Appropriate Requirements, Including Other
Criteria, Advisories, or Guidance To Be Considered (TBCs)
Alternative 3 will comply with all ARARs and identified TBCs. Table 10 presents federal
and state ARARs and TBCs for the chemical operable unit.
3. Cost-Effectiveness
U. S. EPA has determined that Alternative 3 is cost-effective and represents a reasonable
value for the estimated expenditure. U. S. EPA made this determination using the following
definition of cost-effectiveness from the NCP: "A remedy shall be cost-effective if its
costs are proportional to its overall effectiveness." (NCP §300.430(f) (1) (ii) (D)) . Since
both Alternatives 2 and 3 satisfy the threshold criteria (i.e., both are protective of
human health and the environment and comply with ARARs) and nearly equally satisfy three
of the five balancing criteria (long-term effectiveness and permanence, implementability,
and reduction in toxicity, mobility, and volume through treatment), U. S. EPA evaluated
overall effectiveness by assessing the cost and short-term effectiveness of each
alternative. Although Alternative 3 costs an estimated $ 400,000 more to implement than
Alternative 2, we estimate that groundwater cleanup levels might be reached as much as 16
years sooner than under Alternative 2. With the uncertainty associated with future
operating costs over the longer term, we believe that Alternative 3 is the cost-effective
remedy.
4. Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource
Recovery Technologies) to the Maximum Extent Practicable
U. S. EPA believes that Alternative 3 would use permanent solutions and treatment
technologies to the maximum extent practicable. We believe that using a stabilization or
solidification treatment technology on the excavated soil and sediments is not cost-
effective at this site, given the relatively low volumes of soil to be disposed of and the
relatively low levels of contaminants that are in the areas targeted for excavation.
Alternative 3 provides for the in situ destruction of VOCs in the groundwater over a very
short time frame while Alternative 2 merely moves the VOCs from the groundwater to
the atmosphere over a long period of time.
5. Preference for Treatment as a Principal Element
U. S. EPA notes that since there are no wastes identified as principal threats under the
chemical operable unit, no alternative evaluated for this cleanup action would satisfy
the statutory preference for treatment.
6. Five-Year Review Requirement
After U. S. EPA completes Alternative 3, there will be residual chemical contaminants in
the soil remaining on-site above levels that do not allow for unrestricted use and
unrestricted exposure. Thus, we will conduct a statutory Five Year Review at the ACI site
five years after initiation of the radiation operable unit remedial action to ensure that
the remedy is, or will be, protective of human health and the environment.
-------
N. Documentation of Significant Changes
U. S. EPA released the Proposed Plan for the chemical operable unit at the ACI site for
public comment on July 24, 2002. The Proposed Plan identified Alternative 3 - Excavation
and Disposal; In Situ Groundwater Cleanup as the preferred alternative for the chemical
operable unit. U. S. EPA reviewed all written and verbal comments submitted during the
public comment period and determined that no significant changes to the remedy, as
originally presented in the Proposed Plan, were necessary or appropriate.
-------
RESPONSIVENESS SUMMARY
Aircraft Components, Inc. Site
Benton Harbor, Berrien County, Michigan
The public participation requirements of Sections 113(k) (2) (B) (i-v) and 117(b) of CERCLA
(42 U.S.C. §§9613(k)(2)(B)(i-v) and 9617(b)) have been met during the remedy selection
process for the chemical operable unit of the Aircraft Components, Inc. site. Sections
113(k)(2)(B)(iv) and 117(b) require 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. This Responsiveness Summary addresses those concerns
expressed by the public, potentially responsible parties (PRPs) , and governmental bodies
in written and oral comments received by U. S. EPA regarding the proposed remedy for the
site.
U. S. EPA established information repositories at the following locations:
- U. S. EPA - Region 5, 77 W. Jackson Blvd., Chicago, IL 60604
- Benton Harbor Library, 213 E. Wall Street, Benton Harbor, MI 49022
The Administrative Record has also been made available to the public at these locations
during normal business hours.
Background
U. S. EPA placed the Aircraft Components, Inc. site on the National Priorities List in
June 1996 primarily due to the scope of the radiation hazard first discovered in the
warehouse buildings by the State of Michigan in September 1994. U. S. EPA then performed
several removal actions from July 1997 through March 2000. We performed the removal
actions to stabilize the site, remove the gross quantities of radioactive material for
proper disposal off-site, and to quantify the remaining low levels of radioactivity for
future cleanup.
U. S. EPA, in consultation with MDEQ, also began a remedial investigation and feasibility
study at the Aircraft Components, Inc. site in 1998 while the removal action progressed.
U. S. EPA sampled the soil and groundwater at the site for potential metallic and organic
contaminants. We combined the remedial investigation radiological data with the exit
radiation survey data derived from the removal action contractor construction reports, and
then issued a feasibility study for the radiation operable unit in July 2000. We also
continued the chemical operable unit remedial investigation. U. S. EPA signed a Record of
Decision for the radiation operable unit in September 2000.
U. S. EPA completed the remedial investigation and feasibility study at the site in May
2002. On July 24, 2002, U. S. EPA, in consultation with MDEQ, issued a proposed plan to
the public to summarize the results of the remedial investigation for the chemical
operable unit and to present our recommended final site cleanup remedy. U. S. EPA held a
public meeting and public hearing on July 31, 2002, to discuss the results of the remedial
investigation in greater detail, to answer any questions regarding the proposed final
cleanup action, and to take oral comments regarding the proposed final cleanup action. The
public meeting was attended by 4 persons, including local residents and media.
The proposed plan was available for public comment from July 24, 2002, through August 23,
2002. U. S. EPA placed an advertisement announcing the availability of the proposed plan
and the start of the comment period in the Saint Joseph Hera Id-Palladium, a local
newspaper of wide circulation in the Benton Harbor area. A court reporter documented
formal oral comments on the proposed plan, and U. S. EPA placed a verbatim transcript of
the public comments into the information repositories and the Administrative Record.
Written, e-mailed, or faxed comments, if any, were also accepted during the comment
period.
-------
During the comment period, U. S. EPA received no written (by letter, e-mail, or fax)
comments and 1 oral comment concerning the proposed plan. The comment received during the
public comment period and the U. S. EPA's response to this comment are included in this
Responsiveness Summary, which is a part of the chemical operable unit Record of Decision
for the Aircraft Components, Inc. site.
Summary of Significant Comments
A. Written Comments
None received.
B. Oral Comment
Scott Golden
Benton Harbor, MI
Comment 1: "In my opinion Alternative 3 is probably the best alternative. Although
it does take a little bit more money I believe it will probably be more
effective and in the interests of the Enterprise Zone from St. Joe and
some of the surrounding areas. The sooner we get that cleaned up I think
is better."
Response 1: U. S. EPA agrees.
-------
Figures
-------
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Figure 1: Site Map Aircraft Components,
Berrien County, Michigan
Inc.
-------
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Bertie IT County, Michigan
-------
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Figure 3: Gnoundwater monitor well locations Aircraft Components, Inc.
Berrien County, Michigan
-------
Figure 4: Sediment and surface water sampling locations Aircraft Components,
Berrien County, Michigan
Inc.
-------
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FigureS: Alternative.3 Aircraft Components, Inc.
Berrien County, Michigan
-------
Tables
-------
Table 1: Chemical Compounds in Soil
Chemical of
Potential
Concern
Lead
Benzo(a)pyrene
Arsenic
a-Chlordane
Mercury
Selenium
Cobalt
Zinc
Screening
Level
(mg/kg)
248
0.062
5.8
0.50
0.13
0.41
6.8
230
Source of
Screening
Level
Ecol. Risk
PRG
Bkgd
PRG
Bkgd
Bkgd
Bkgd
GSI
Concentration Range
(mg/kg)
N.D. -881
N.D. -17.0
N.D. -39
N.D. -7.3
N.D. -44
N.D. -1.7
N.D. -9.2
N.D. -767
Primary Locations
of Concern
(see Figure 2)
SB-66; SB-49; SB-47
SB-48; SB-47; SB-46
SB-61; SB-47; SB-55
SB-31; SB-29
SB-45; SB-49; SB-50
SB-32; SB-38; SB-49
SB-54; SB-38
SB-66; SB-11; SB-49
Samples above
Screening Level
4/63
16/63
7/63
2/63
11/63
5/63
2/63
3/63
Notes: PRG = Preliminary Remediation Goal from U.S. EPA Region 9 website.
Bkgd = State default background concentration in soil
Ecol. Risk = Level at which compound may present a risk to ecological receptors.
GSI = State groundwater-surface water interface protection level
N.D. = Not detected
mg/kg = Milligrams per kilogram - approximately "parts per million"
-------
Table 2: Chemical Compounds in Groundwater
Chemical of
Potential
Concern
Lead
Manganese
Arsenic
PCE
TCE
Vinyl Chloride
1,1-DCE
cis-1,2-DCE
Screening
Level
(M9/L)
4
50
10
1.1
1.6
0.041
0.046
61
Source of
Screening
Level
DW
DW
MCL
1 x 10'6risk
1 x 10'6risk
1 x 1 0'6 risk
1 x 1 0'6 risk
PRG
Concentration Range
(M9/L)
N.D. -105
N.D. -1980
N.D. -22
N.D. -790
N.D. -91
N.D. -66
N.D. -26
N.D. -21,000
Primary Locations
of Concern
(see Figure 3)
TW-04; MW-B
TW-01 ; MW-F;
MW-02;TW-01;
MW-08; MW-04
MW-08; MW-04
MW-B; MW-06
MW-06
MW-06; MW-04
Samples above
Screening Level
19/56
52/56
5/56
9/56
9/56
8/56
6/56
13/56
Notes: MW-F is an off-site, upgradient well in which manganese was detected at its highest concentration
MCL = Maximum Contaminant Level under Safe Drinking Water Act
DW = State drinking water protection level
PRG = Preliminary Remediation Goal from U.S. EPA Region 9 website
N.D. = Not detected
|jg/L = Micrograms per liter- approximately "parts per billion"
-------
Table 3: Chemical Compounds in Sediment
Chemical of
Concern
Lead
Arsenic
Mercury
Selenium
Screening
Level
(mg/kg)
248
5.8
0.13
0.41
Source of
Screening
Level
Ecological
Risk
Bkgd
Bkgd
Bkgd
Concentration
Range
(mg/kg)
N.D. -448
N.D. -22,400
N.D.-11.7
N.D. -30.6
N.D. -3.0
N.D. -7.1
Locations
(see Figure 4)
Wetlands Sed. -17
River Sed. -02
Wetlands Sed. -18
River Sed. -02
Wetlands Sed. -17
Wetlands Sed. -17
Notes: Bkgd = State default background concentration in soil
Ecological Risk = Level at which compound may present a risk to ecological receptors.
mg/kg = Milligrams per kilogram - approximately "parts per million"
-------
Table 4: Chemicals of Concern
Chemical of Concern
Lead
Mercury
Arsenic
Selenium
Benzo(a)pyrene
a-Chlordane
PCE
TCE
Vinyl Chloride
cis-1,1-DCE
1,2-DCE
Media
Soil; River and wetlands sediment
Soil; wetlands sediment
Soil
Soil
Soil
Soil
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
-------
Table 5: Summary of Actual or Potential Risks
Exposure Pathway
Ingestion, dermal contact,
inhalation of Groundwater
Ingestion, dermal contact,
inhalation of Groundwater
Ingestion, dermal contact,
inhalation of Soil
Ingestion, dermal contact,
inhalation of Soil
Ingestion, dermal contact,
inhalation of Soil
Ingestion, dermal contact,
inhalation of Soil
Receptor - Scenario
Adult and Child -
Residential
Adult - Commercial
Land Use
Adult - Residential
Adult - Recreational
Adult - Commercial
Land Use
Adult - Worker
Risk and/or Hazard Index
1.5x10-4to6.8x1Q-4
HI = 730 to 1020
4.2x10-5to1.9x1Q-4
HI = 130 to 180
4.5x10-5to3.4x1Q-4
Hl = 1.9to3.1
2.2x10-6to4.8x1Q-5
HI = 0.03 to 0.2
1.1 x10-5to1.3x1Q-4
HI = 0.1 to 0.4
2.0x10-7to3.2x1Q-7
HI = 0.3 to 0.4
Note: Risk and hazard index levels are combined carcinogenic and non-carcinogenic, respectively, risks
for receptors. The highest risk value is for the Reasonable Maximum Exposure level and the lowest is the
Central Tendency level. Hazard index is less than 1 for recreational exposure to surface waters and
sediments; total adult risk level is less than 1 x 10"6 for recreational exposure to surface waters and
sediments.
-------
Table 6: Summary of Ecological Risks
Exposure Pathway
Receptor
Criterion
Ingestion, dermal contact,
inhalation of soil
Meadow Vole
American Woodcock
Short-tailed Shrew
Pesticides, metals: HI > 1
Benzo(a)pyrene, others: HI > 1
Pesticides, metals: HI > 1
Ingestion, dermal contact,
inhalation of Paw Paw
River water
Aquatic organisms
Acute and Chronic Ambient
Water quality criteria are
exceeded at SW-02 only
Ingestion, dermal contact,
inhalation of wetlands
sediment
American Woodcock
Short-tailed Shrew
Lead: HI > 1
Mercury: HI > 1
Ingestion, dermal contact,
inhalation of Paw Paw
River sediment
Benthic organisms
Lead and other metals at
SD-02 location only exceed
recommended sediment levels
-------
Table 7: Evaluation of Alternatives Using the Nine Criteria
Criterion
Protection of
human health and
the environment
Direct Contact
GW ingestion
Environmental
Meets ARARs
Chemical-specific
Location-specific
Action-specific
Other Guidance
Long term
effectiveness
Alternative 1
No Action
Is not protective.
No reduction in risk
No reduction in risk
No reduction in risk
Does not meet
ARARs
GWwill exceed
MCLs and state
criteria for 50+ yrs.
None
None
Would likely
exceed state GSI
criteria for 50+ yrs.
No controls over
GW or soil
contamination,
risks remain.
Alternative 2
Soil Excavation,
Pump and Treat
Is protective.
Reduces risk to
less than 1x10"5
Restores GW to
protective status
Reduces exposure
to contaminants
Does meet ARARs
GWwill meet
MCLs and state
criteria in 20+ yrs.
None
Will meet water
and air discharge
requirements; will
meet disposal
requirements
Will likely meet
state GSI criteria in
20 yrs.
Reduces risks due
to soil immediately,
controls GW risks
until risks reduced
in 20+ yrs.
Alternative 3
Soil Excavation,
In Situ GW
Is protective.
Reduces risk to
less than 1x10"5
Restores GW to
protective status
Reduces exposure
to contaminants
Does meet ARARs
GWwill meet
MCLs and state
criteria in 2-4 yrs.
None
Will meet disposal
requirements
Will likely meet
state GSI criteria in
2-4 yrs.
Reduces risks due
to soil immediately,
controls GW risks
until risks reduced
in 2-4 yrs.
-------
Table 7: Evaluation of Alternatives Using the Nine Criteria (Cont'd)
Long term
effectivenes
Reduction of
toxicity, mobility,
or volume (TMV)
Treatment Used
Amount Treated
Or Destroyed
Reduction of TMV
Irreversible TMV
Residuals
Short-term
effectiveness
Community
Cleanup workers
Environmental
Cleanup workers
No controls over
GW or soil
contamination,
risks remain.
None
None
None
None
None
All contaminants
remain
None
Continued risks
due to no action
No risks
Continued impacts
to receptors
No risks
Reduces risks due
to soil immediately,
controls GW risks
until risks reduced
in 20+ yrs.
Some
Air stripping
90+% VOCs in GW
treated
Reduced volume
and toxicity in GW
Air stripping of
VOCs irreversible
Some soil and GW
contaminants
remain at or below
cleanup levels
GW 20+yrs.
Dust and air
emission protection
needed
Dust and air
emission protection
needed
Disruption during
excavation
Dust and air
emission protection
needed
Reduces risks due
to soil immediately,
controls GW risks
until risks reduced
in 2-4 yrs.
More than
Alternative 2
In situ reductive
dechlorination
90+% VOCs in GW
destroyed
Reduced volume
and toxicity in GW
Reductive
dechlorination is
irreversible
Some soil and GW
contaminants
remain at or below
cleanup levels
GW 2-4 yrs.
Dust protection
needed during
excavation
Dust protection
needed during
excavation
Disruption during
excavation
Dust protection
needed during
excavation
-------
Table 7: Evaluation of Alternatives Using the Nine Criteria (Cont'd)
Environmental
Time to reach
cleanup goals
Implementability
Ability to construct
Ability to do more
work if necessary
Ability to monitor
effectiveness
Other Agencies
Availability of
materials, workers
equipment
Availability of
technologies
Cost
Capital
O&M
State acceptance
Public
acceptance
Continued impacts
to receptors
None
Yes
No construction
Would require
ROD amendment
No monitoring -
exposures could go
undetected
Permit-type
approvals not
necessary
None required
None required
None
$0
$0
Not acceptable
because remedy is
not protective
Not acceptable
because remedy is
not protective
Disruption during
excavation
Less than 6 mos.
for soil, 20+ yrs for
GW
Yes
Easy to construct
GW system and to
excavate soils
Easy to expand
GW system or
excavation volume
Monitoring is easy
to perform for GW
treatment system
Requires air and
water discharge
criteria from state
Readily available
Readily available
$2.68 million
$1.54 million
$1.14 million
Acceptable
Acceptable
Disruption during
excavation
Less than 6 mos
for soil, 2-4 yrs for
GW
Yes
Easy to construct
GW system and to
excavate soils
Easy to expand
GW system or
excavation volume
Monitoring is easy
to perform for GW
cleanup method
Permit-type
approvals not
necessary
Readily available
Readily available
$3.06 million
$2.75 million
$0.31 million
Acceptable
Acceptable
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Table 8: Major Cost Elements for Alternative 3
DIRECT COSTS
MOBILIZATION/DEMOBILIZATION
SITE PREPARATION
Clearing and Grubbing
Access Improvements
Temporary Facilities
Demolition of Small Quonset Hut
EXCAVATION OF SOIL
Soil Excavation
Backfill
Confirmation Samples
Semivolatile Organic Compounds
Inorganic Chemicals
Pesticides
EXCAVATION OF PAW PAW RIVER SEDIMENT
Temporary Dam Structures
Dewatering Pumps
Excavator (Including Operator)
Front end Loader (including Operator)
Backfill
Sediment Drying Agent
Laborers
Confirmation Samples
Inorganic Chemicals - Sediment
Inorganic Chemicals - Surface Water
EXCAVATION OF ON-SITE WETLAND SEDIMENT
Stump Removal
Culvert Diversion Piping
Dewatering Pumps
Excavator (Including Operator)
Dozer (including Operator)
Compactor (Including Operator)
Backfill
Sediment Drying Agent
Laborers
Confirmation Samples
Inorganic Chemicals
ENGINEER'S ESTIMATES
Quantity Unit
1 Lump Sum
4.5 Acre
1 Lump Sum
8 WK
1 Lump Sum
3,800 CY
4,400 CY
26 Sample
18 Sample
1 7 Sample
1 Lump Sum
1 Lump Sum
3 Days
3 Days
150 Cubic Yards
23 Tons
96 Hours
9 Sample
10 Sample
1 Lump Sum
600 Linear Feet
1 Lump Sum
18 Days
12 Days
12 Days
2,800 Cubic Yards
390 Tons
288 Hours
1 5 Sample
Unit Price
$20,000
$3,500
$ 20,000
$1,500
$30,000
$5
$15
$350
$250
$300
$10,000
$2,000
$1,500
$1,000
$20
$100
$40
$250
$200
$4,000
$15
$2,000
$1,500
$1,000
$500
$30
$100
$40
$250
Cost Subtotal
$20.000
$20,000
$15,750
$20,000
$12,000
$30,000
$77,800
$19,000
$66,000
$9,100
$4,500
$5,100
$103,700
$10,000
$2,000
$4,500
$3,000
$3,000
$2,250
$3,840
$2,250
$2,000
$32,800
$4,000
$9,000
$2,000
$27,000
$12,000
$6,000
$84,000
$39,000
$11,520
$3,750
$198,300
COMMENTS
Mob/Demob of heavy equipment (i.e., excavator), drilling equipment, groundwater system equipment
Includes chipping and on-site stockpiling.
Haul road construction as necessary, moving pallets/debris piles on site, general grading, and entrance gate improvement.
Includes office trailer, furnishings, telephone, generator, and sanitary facilities.
In situ volume. Includes equipment and labor.
General fill material. Includes delivery, placement, and compaction. Includes 1 5% factor for compaction.
Includes 3 QA/QC duplicate sample. Cost includes shipping. 1 week turnaround time.
Includes 2 QA/QC duplicate sample. Cost includes shipping. 1 week turnaround time.
Includes 2 QA/QC duplicate sample. Cost includes shipping. 1 week turnaround time.
Rental.
Rental.
Long-stick excavator (40-ft boom).
Pea Gravel. Includes delivery and +10% volume to allow for settlement/compaction.
Assumes Portland cement at 10% by weight of 150 CY sediment removed (1 .5 ton/CY sediment density after excavation)
3 laborers for 3 8-hour days, plus two 12-hour overnight watchperson shifts
Includes 1 QA/QC duplicate sample. Cost includes shipping.
Two rounds of monitoring. 4 investigative and 1 duplicate sample per round.
Installed. 12" flexible hose.
Rental.
During excavation and backfill. Long-stick excavator (40-ft boom).
During back filling operations.
Topsoil. Includes delivery and +10% volume to allow for settlement/compaction.
Assumes Portland cement mixed in-situ at 10% by weight of 2,570 CY sediment removed (1.5 ton/CY sediment density)
2 laborers for 18 8-hour days.
Includes 2 QA/QC duplicate sample. Cost includes shipping.
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Table 8: Major Cost Elements for Alternative 3 (cont'd)
IMPLEMENTATION OF GROUNDWATER REMEDY
Pilot Test
Predesign Investigation
Monitoring Well Installation
Full Scale Implementation
Oxygen Release Compound
Hydrogen Release Compound
Injection Equipment
ENGINEER'S ESTIMATES
Quantity Unit
1 Lump Sum
1 Lump Sum
350 Linear Feet
26,040 Pound
31,530 Pound
78 Day
Reapplication of Oxygen/Hydrogen Release Compound 1 Lump Sum
TRANSPORTATION AND DISPOSAL
Transportation
Soil/Sediment Disposal
Sample Analysis - Disposal Parameters
Vegetation Disposal
General Debris/Wastes
SITE RESTORATION
Revegetation of Cleared Areas
Wetland Restoration
DIRECT COST SUBTOTAL
INDIRECT COSTS
ENGINEERING/DESIGN/INVESTIGATION
Engineering and Design
Deed Restriction Drafting and Implementation
7,800 CY
7,800 CY
5 Sample
0 Ton
1 Lump Sum
3.7 Acre
0.8 Acre
1 Lump Sum
1 Lump Sum
Unit Price
$90,000
$50,000
$20
$8.00
$5.00
$2,000
$85,000
$8
$23
$1,500
$20
$5,000
$2,000
$60,000
$150,000
$5,000
CONTRACTOR PROCUREMENTS (@1 % of direct costs)
CONSTRUCTION MANAGEMENT
Project Manager
Resident Engineer
Per Diem (2 Engineers)
Car Rental
H&S and Sampling Equipment
Admin/Office Support
Surveying
Site Security
80 HR
1,000 HR
100 DAY
50 DAY
50 DAY
-
1 Lump Sum
10 WK
$100
$60
$85
$65
$1,000
-
$20,000
$2,000
Cost Subtotal
$90,000
$50,000
$7,000
$208,320
$157,650
$156,800
$85,000
$878,570
$62,400
$179,400
$7,500
$0
$5,000
$254,300
$7,400
$48,000
$55,400
$1,621,000
$150,000
$5,000
$155,000
$16,200
$16,200
$8,000
$60,000
$8,500
$3,250
$50,000
$6,000
$30,000
$20,000
$185,800
CONSTRUCTION MANAGEMENT - GROUNDWATER REMEDY
Project Manager
Resident Engineer
Per Diem
Car Rental
H&S and Sampling Equipment
Admin/Office Support
64 HR
800 HR
80 DAY
80 DAY
80 DAY
-
Reapplication of Oxygen/Hydrogen Release Compound 1 Lump Sum
$100
$60
$85
$65
$1,000
-
$20,000
$6,400
$48,000
$6,800
$5,200
$80,000
$4,800
$20,000
$171,200
POST-CONSTRUCTION DOCUMENTATION AND CERTIFICATION
Reporting/Certification
INDIRECT COST SUBTOTAL
1 Lump Sum
$50,000
$50,000
$50,000
$578,000
COMMENTS
Includes addition of compounds in three test areas, monthly monitoring for 6 months, and technical paper preparation.
Includes installation, development and sampling of at least two monitoring wells east of Auxiliary Building 1
2-inch diameter stainless steel. Five 45-ft wells and five 25-ft wells.
410 injection points (80 ft deep). 5 points/day (400ft/day drilling).
Assumes approximately 25% of plume requires reapplication.
Includes transporation and delivery of soil to landfill.
Assumes +15% factor for expansion (soil/sediment) and +10% factor for drying agent (sediment only).
Includes shipment to laboratory.
Assumes all vegetation reused on-site.
For general debris, investigation- and construction- derived wastes, etc.
Does not include wetland area.
Includes preconstruction survey, initial planting, and quarterly inspection/replanting during first 3 years of sta
atup
Assumes 270 CY per day of soil excavation/placement(l 7 days), 27 days for wetland sediment, 3 days river sediment
8 hours/week for 1 0 weeks.
Two engineers for 1 0 weeks @ 50 hr/wk.
1 0% of construction management labor.
As built surveys of excavations, wetland boundary, and restored wetland.
4 hours/week for 1 6 weeks.
One engineer for 1 6 weeks at @ 50 hr/wk.
1 0% of construction management labor.
-------
Table 8: Major Cost Elements for Alternative 3 (cont'd)
ENGINEER'S ESTIMATES
Ouantitv
ANNUAL OPERATIONS AND MAINTENANCE (O&M) COSTS
GROUNDWATER MONITORING
Labor 304
Analytical
Volatile Organic Compounds 72
Inorganic Chemicals 22
Metabolic/Biological Parameters 72
Reporting 4
H&S and Sampling Equipment 16
Rental Vehicle 16
Per Diem 32
ANNUAL O&M COST SUBTOTAL
SUB-TOTAL of DIRECT AND INDIRECT COSTS
Unit
HR
Sample
Sample
Sample
Report
Days
Days
Days
SUB-TOTAL of DIRECT AND INDIRECT COSTS WITH 25% CONTINGENCY
SUB-TOTAL of ANNUAL O&M COSTS
SUB-TOTAL of ANNUAL O&M COSTS WITH 25% CONTINGENCY
PRESENT WORTH of O&M COSTS WITH CONTINGENCY
Unit Price Cost Subtotal
$60 $18,240
$150 $10,800
$150 $3,300
$500 $36,000
$2,000 $8,000
$1,000 $16,000
$65 $1,040
$85 $2,720
$96,100
$96,000
$2,199,000
$2,749,000
$96,000
$120,000
$315,000
TOTAL COST (DIRECT COSTS + INDIRECT COSTS + PRESENT WORTH COSTS) WITH CONTINGENCY $3,060,000
COMMENTS
Assumes 2 geologists, 30 hours/quarter on-site + 8 hours/quarter for travel.
1 6 wells quarterly. Includes 2 duplicates per quarter. Includes shipping costs
10 wells semiannually. Includes 1 dulicate semiannually. Includes shipping costs.
1 7 wells. Includes 2 duplicates per quarter. Includes shipping costs
4 days per quarter.
4 days per quarter.
4 days per quarter. 2 persons.
Assumes an interest factor of 7 % and an O&M period of 3 years.
-------
Table 9: Cleanup Levels for Chemical Compounds
Media
Groundwater
PCE
TCE
1,1-DCE
cis-1,2-DCE
Vinyl Chloride
Soil
Lead
Benzo(a)pyrene
Selenium
Arsenic
Mercury
a-Chlordane
Wetlands
Sediment
Mercury
Lead
Paw Paw River
Sediment
Lead
Cleanup Level
5 ug/liter
5 ug/liter
4.8 ug/liter
70 ug/lrter
2 ug/lrter
248 mg/kg
680 ug/kg
0.41 mg/kg
15.3 mg/kg
0.13 mg/kg
6.8 |jg/kg
0.13 mg/kg
385 mg/kg
35 mg/kg
Basis
MCL
MCL
Calculated level
MCL
MCL
Ecological Risk
Recreational Use
Commercial Use
Ecological Risk
Commercial Use
Ecological Risk
Commercial Use
Ecological Risk
Ecological Risk
Residual Risk
4x10-6
3x1Q-6
1 x10'5
1-11 = 1
5x10-5
Hl< 1
1 x10'5
background
HK1
background
Hl< 1
background
Hl< 1
No effects level to
benthic organisms
Note: Background = State default background level under Part 201 for Commercial/Industrial Use.
MCL = Maximum Contaminant Level under Safe Drinking Water Act
ug = Micrograms - micrograms per liter or kilogram is approximately "parts per billion"
mg = Milligrams - milligrams per liter or kilogram is approximately "parts per million"
-------
Table 10
Federal Chemical-Specific ARARs
Federal Regulations
Requirements
Comments and Analysis
dean Air Act (42 USC 7401-7462)
National Ambient Air Quality Standards
(NAAQS) (40 CFR Part 50)
National Emissions Standards for Hazardous Air
Pollutants (NESHAPs) (40 CFR Part 61)
Establishes primary and secondary standards for ambient air
quality to protect public health and welfare.
Establishes emissions standards for those hazardous air
pollutants for which no ambient air quality standards exists, but
which cause, or contribute to, air pollution that may result in an
increase in mortality or an increase in serious, irreversible or
incapacitating reversible illness.
NAAQS do not apply directly to source-specific emissions limitations;
rather, they are national limitations on ambient concentrations. While
not applicable, NAAQS may, in some circumstances, be considered
relevant and appropriate for CERCLA cleanup activities. In the case of
the Aircraft Components site, they may be relevant and appropriate
because onsite workers and/or members of the general public may be
exposed to site-related contaminants released to the ambient air during
soil remediation.
With the exception of NESHAPs for asbestos and radionuclides,
NESHAPS for other pollutants are not generally applicable to CERCLA
activities because CERCLA sites do not usually contain one of the
specific source categories regulated. Many NESHAPs are not relevant
or appropriate because these standards of control are intended for the
specific types of sources and are not applicable to all sources of these
pollutants. Due to presence of mercury, and vinyl chloride at the
Aircraft Components site, NESHAPs for these constituents may be
relevant and appropriate.
dean Water Act (33 USC Sect. 1251-1376)
Water Quality Criteria (40 CFR Part 131 Quality
Criteria for Water, 1976, 1980, 1986)
Sets criteria for water quality based on toxicity to aquatic
organisms and human health.
WQCs are applicable, or relevant and appropriate since there is
contaminated groundwater with a surface water interface, as well as
impacted surface water associated with the site.
Safe Drinking Water Act (40 USC Sect. 300)
National Primary Drinking Water Standards (40
CFR Part 141)
National Secondary Drinking Water Standards
(40 CFR Part 143)
Establishes health-based standards for public water systems
(maximum-contaminant levels (MCLs)).
Establishes welfare-based standards for public water systems
(secondary maximum contaminant levels).
MCLs are applicable to public drinking water supplies and are relevant
and appropriate for groundwater at the site because the groundwater
could be a potable water supply.
Secondary MCLs are applicable to public drinking water supplies and
are relevant and appropriate for groundwater at the site because the
groundwater could be a potable water supply.
Table 10-1-
-------
Federal Regulations
Maximum Contaminant Level Goals (MCLGs)
(40 CFR 141.50, 141.51, 141.52)
Requirements
Establishes drinking water quality goals set at levels of no known
or anticipated adverse health effects, with an adequate margin of
safety.
Comments and Analysis
MCLGs are applicable to public drinking water supplies and are
relevant and appropriate for groundwater at the site because the
groundwater could be a potable water supply.
Resource Conservation and Recovery Act (as amended by HSWA) (40 USC 6901)
Groundwater Monitoring and Response
Requirements (40 CFR 264.94)
Identification and Listing of Hazardous Waste (40
CFR Part 261)
Standards for 14 toxic compounds to be monitored in the
groundwater at RCRA facilities.
Defines those solid wastes which are subject to regulation as
hazardous waste under 40 CFR Parts 262-265 and Parts 124,
270, and 271.
Site is not a RCRA facility, but monitoring and response requirements
may be relevant and appropriate.
Identifies definition of hazardous waste. Since there are potential
hazardous wastes at the facility, these regulationsmay be relevant and
appropriate.
To Be Considered (TBQ Standards
Soil Screening Guidance (EPA Document
Number: EPA540/R-96/0 1 8, July 1996)
U.S. EPA Region IX Preliminary Remediation
Goals
Canadian Council of Ministers of the
Environment - Canadian Sediment Quality
Guidelines for the Protection of Aquatic Life:
Summary Tables. (Canadian Environmental
Quality Guidelines, 1999)
Guidance designed to help standardize remediation at National
Priorities List (NPL) sites which contains risk-based soil
screening levels.
Risk-based soil screening levels derived from standardized
equations that combine exposure assumptions and EPA toxicity
data.
Establishes benchmark concentrations for contaminants in
sediment.
To be considered.
To be considered.
To be considered.
Long, et. al - Incidence of Adverse Biological
Effects within Ranges of Chemical
Concentrations in Marine andEstuarine
Sediments, 1995
Establishes benchmark concentrations for contaminants in
sediment.
To be considered.
Table 10-2-
-------
Federal Regulations
U.S. EPA Quality Criteria for Water. Office of
Water Regulations and Standards (EPA/440/5-86-
001)
Requirements
Establishes ambient water quality standards.
Comments and Analysis
To be considered.
Table 10-3-
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State Chemical-Specific ARARs
State Regulations
Michigan Emission Limitations and
Prohibitions (Mich. Admin. Code
R. 336.1301 - 1942)
Intermittent Testing and Sampling
(Mich. Admin. Code R. 336.2001 -
2060)
Michigan Water Quality Standards
(Mich. Admin. Code R. 323.1041 -
1117)
Michigan Effluent Standards (Mich.
Admin. Code R. 323.1201 - 1221)
Monitoring and Reporting
Requirements (Mich. Admin. Code
R. 299.9001 -2974)
Sewer Discharge Criteria (Mich.
Admin. Code R. 323.2101 - 2192)
Michigan Primary Drinking Water
Standards (Mich. Admin. Code R
325.10601- 10609)
Variances and Exemptions (Mich.
Admin. Code R. 325.10301 -
10312)
Michigan Groundwater Quality
Standards (Mich. Admin. Code
R.323.2201-22113)
Michigan Surface Water Quality
(Mich. Admin. Code R. 323.1041 -
1117)
Requirement
Establishes emission standards for opacity and emissions of contaminants and
particulate matter.
Establishes sampling and testing requirements for emission sources.
The purpose of water quality standards as prescribed by these rules is to
establish water quality requirements applicable to the Great Lakes, the
connecting waters, and all other surface waters of the state, to protect the
public health and welfare, to enhance and maintain the quality of water, and to
protect the state's natural resources.
Prescribes maximum concentrations of various contaminants that may be
discharged to the waters of the state.
Prescribes requirements for monitoring, reporting, and measuring contaminant
discharges.
Places certain restrictions on the types, concentrations and quantities of
contaminants which can be discharged into the sewer systems and POTWs.
Establishes health-based standards for public water systems.
Establishes protocols and allowances for variances and exemptions from
MCLs and state drinking water standards.
Sets groundwater classification and associated water quality standards.
Sets surface water classification and associated water quality standards.
Comment and Analysis
Many of these standards are only applicable to certain facilities and/or
industries and are therefore not applicable; however, since the soil
excavation may create dust emissions into air, these standards may be
relevant and appropriate.
Since the soil excavation may create dust emissions into air, these
standards may be relevant and appropriate.
Are applicable or relevant and appropriate if remediation activities may
result in effects to the surrounding surface water.
Maybe applicable to the discharge of the wetlands surface water into
the Paw Paw River (wetlands dewatering subtask).
Maybe applicable to the discharge of the wetlands surface water into
the Paw Paw River (wetlands dewatering subtask).
Standards would be applicable if water generated during remedial
activities is discharged to a POTW.
Standards are applicable to public drinking water supplies and are
relevant and appropriate for groundwater at the site because the
groundwater could be a potable water supply.
Standards are applicable to public drinking water supplies and are
relevant and appropriate for groundwater at the site because the
groundwater could be a potable water supply.
May be applicable to the groundwater cleanup (monitoring of
groundwater quality).
May be applicable to the groundwater cleanup (monitoring of Paw Paw
River quality).
Table 10-4-
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State Regulations
Identification and Listing of
Hazardous Waste (Mich. Admin
Code R. 299.9101 -11107)
Part 20 1 Environmental Response
Division of the Natural Resources
and Environmental Protection Act
(NREPA), Act 451 of 1994 as
amended by Act 71, formerly State
of Michigan Act 307
Administrative Rules
GSI
Cleanup Criteria (Mich. Admin.
Code R. 299.5701-5727)
Requirement
Defines those solid wastes which are subject to regulations as hazardous waste.
Administrative rules which address hazardous site identification, funding,
alternative water supplies, response action, selection of remedial action,
clean-up criteria, and site assessment. Act 307 amendments require that
Michigan DEQ seek out and use innovative technologies to address
contaminated sites.
Sets groundwater cleanup levels to protect groundwater/surface water interface
water quality.
Provides methodology for determining cleanup standards for environmental
media at contaminated sites.
Comment and Analysis
May be applicable to soils cleanup. Generated waste must comply with
waste identification requirements.
Applicable to Superfund sites in Michigan. Support for the site remedial
action will be determined by the State based on criteria set forth in these
rules.
To be considered in determining site groundwater cleanup levels.
This regulation is contained within Part 201 of the NREPA.
Table 10-5-
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Federal Location-Specific ARARs
Federal Regulations
Executive Order 11988, Floodplain Management
(40 CFR Part 6, Appendix A)
Executive Order 11990, Protection of Wetlands
(40 CFR Part 6, Appendix A)
Clean Water Act Section 404 (40 CFR Parts
230,231)
Discharges of Dredged or Fill Material into
Waters of the United States (33 CFR Part 323)
RCRA-40CFR264.18(b)
Requirements
Establishes agency policy and guidance for carrying out the
provisions of Executive Order 11988 "Floodplain Management."
Requires minimization of destruction, loss, or degradation of
wetlands.
Action to prohibit discharge of dredged or fill material into a
wetland without permission.
Established permit requirements for actions that involve
dredging or filling in of a navigable waterway or wetland.
A facility located in a 100-year floodplain must be designed,
constructed, operated, and maintained to prevent washout of
hazardous waste by a 100-year flood.
Comments and Analysis
Requirements maybe applicable since portions of the site are located
within a 100-year floodplain.
Applicable because wetlands exist on the site.
Applicable because wetlands exist on the site.
Requirements will be applicable if the Paw Paw River is dredged or
filled.
This requirement is relevant and appropriate (and is a major reason why
containment remedies were rejected in the FS).
To Be Considered (TBQ Standards
The Native American Grave Protection and
Repatriation Act (NAGPRA). Public Law
10 1-601 (Nov. 16,1990)
The Migratory Bird Treaty Act (16 USC 703)
The Archeological Resources Protection Act of
1979. Public Law 96-95
Law provides for protection of Native American graves, and for
other related purposes.
Law makes it unlawful to take, kill, or possess any migratory
bird, any part, nest, or eggs of any such bird.
Provides for the protection of archeological resources on federal
and Indian lands.
There is no evidence of Native American graves or artifacts at the site;
however, if found, these requirements will be considered.
There is no evidence of migratory birds on-site; however, if found, these
requirements will be considered.
There is no evidence of archeological resources at the site; however, if
found, these requirements will be considered.
Table 10-6-
-------
State Location-Specific ARARs
State Regulations
Wilderness and Natural Areas, Part
351 of the NREPA, Act 45 1 of 1994
(formerly State of Michigan Act
241 of 1972)
Natural Rivers, Part 305 of the
NREPA, Act 451 of 1994 (formerly
State of Michigan, Act 23 1 of 1 970)
Michigan Inland Lakes and Streams
Standards (Mich. Admin. Code R.
281.811-846)
Inland Lakes and Streams, Part 301
of the NREPA, Act 45 1 of 1994
(formerly State of Michigan Act
346 of 1972)
Michigan Wetland Protection
Standards (Mich. Admin. Code R.
281.921-925)
Wetlands Protection, Part 303 of the
NREPA, Act 451 of 1994 (formerly
State of Michigan Act 203 of 1979)
Requirement
This part provides for the creation and regulation of wilderness areas, wild
areas, and natural areas.
This part establishes zoning districts within the natural river area for which
specified land use may be encouraged, regulated, or prohibited. Activities and
projects within a natural river may require approval of the MDNR.
Permitting requirements and conditions for any operation involving lakes and
streams.
Lists operations that are prohibited in the bottom land of a lake or stream
without a permit.
Permitting requirements and conditions involving and operations regarding
wetlands.
Prohibits the construction, operation, or maintenance of any use of
development in a wetland without a permit. Outlines the requirements for
obtaining permits, performing wetlands determinations and mitigating wetland
impacts.
Comment and Analysis
This standard may be applicable or relevant and appropriate for
remediation of the Paw Paw River sediment.
This standard may be applicable or relevant and appropriate for
remediation of the Paw Paw River sediment.
This standard may be applicable or relevant and appropriate for
remediation of the Paw Paw River sediment.
This standard may be applicable or relevant and appropriate for
remediation of the Paw Paw River sediment.
This standard may be applicable or relevant and appropriate for
remediation of the Paw Paw River sediment and the on-site wetlands.
This standard may be applicable or relevant and appropriate for
remediation of the Paw Paw River sediment and the on-site wetlands.
Table 10-7-
-------
Federal Action-Specific ARARs
Federal Regulations
Requirement
Comment and Analysis
Occupational Safety and Health Administration (OSHA) Regulations (29 USC 651)
29 CFR 1910. 120
29 CFR Part 1926
Establishes limits for worker exposures to chemicals during response actions at
CERCLA sites.
Establishes construction standards.
Applicable to worker exposures during implementation of remedial
alternatives.
Standards will be applicable during the construction of remedial
alternatives.
Army Corps of Engineers Program
Discharges of Dredged or Fill
Materials into Waters of the United
States (33 CFR Part 323)
Establishes requirements for actions that involve dredging or filling in of a
navigable waterway or wetland.
Requirements will be applicable or relevant and appropriate to the Paw
Paw River sediment cleanup action.
Clean Air Act
National Primary and Secondary
Ambient Air Quality Standards (40
CFR Part 50)
U.S. EPA Regulation on National Er
40 CFR Part 61
Establishes standards for ambient air quality to protect public health and
welfare (including standards for particulate matter and lead).
Mission Standards for Hazardous Air Pollutants
Regulates emissions of hazardous air pollutants.
Relevant and appropriate. During excavation and grading associated
with remedial activities, fugitive dust emissions must not exceed
NAAQS requirements for particulate matter.
Relevant and appropriate. Emissions from any on-site treatment action
must meet emission standards. Selected alternatives such as excavation
may generate hazardous air pollutants.
Federal Water Pollution Control Act as Amended by the Clean Water Act of 1977
Section 208(b)
The proposed action must be consistent with regional water quality
management plans as developed under Section 208 of the Clean Water Act.
Substantive requirements adopted by the State pursuant to section 208
of the Clean Water Act would be applicable or relevant and appropriate
to direct discharge of treated water to the Paw Paw River.
U.S. EPA National Pollutant Discharge Elimination System (NPDES) Permit Regulations
40 CFR 122.21
Permit application must include a detailed description of the proposed action
including a listing of all required environmental permits.
Substantive requirements would be applicable or relevant and
appropriate to direct discharge of treated water to the Paw Paw River.
Table 10-8-
-------
Federal Regulations
Requirement
Comment and Analysis
US. EPA National Pollutant Discharge Elimination System (NPDES) Permit Regulations (Continued)
40 CFR 122.44
40 CFR 122.44(a)
40 CFR 122.44(e)
40 CFR 122.44(1)
40 CFR 125. 100
Federally approved state water quality standards. These may be in addition to
or more stringent than federal water quality standards.
Requires the use of the Best Available Technology (BAT) for toxic and
non-conventional wastewaters or the Best Conventional Technology (BCT) for
conventional pollutants.
Discharge limits must be established for toxics to be discharged at
concentrations exceeding levels achievable by the technology-based
(BAT/BCT) standards.
Requires monitoring of discharges to ensure compliance. Monitoring programs
shall include data on the mass, volume, and frequency of all discharge events.
The site operator shall develop a best management practice (BMP) program
and shall incorporate it into the operations plan or the NPDES permit
application if required.
Substantive requirements would be applicable or relevant and
appropriate to direct discharge of treated water to the Paw Paw River.
Substantive requirements would be applicable or relevant and
appropriate to direct discharge of treated water to the Paw Paw River.
Substantive requirements would be applicable or relevant and
appropriate to direct discharge of treated water to the Paw Paw River.
Substantive requirements would be applicable or relevant and
appropriate to direct discharge of treated water to the Paw Paw River.
Substantive requirements would be applicable or relevant and
appropriate to direct discharge of treated water to the Paw Paw River.
Clean Water Act (33 USC Sect. 1251-1376)
40 CFR Part 131
States are granted enforcement jurisdiction over direct discharges and may
adopt reasonable standards to protect or enhance the uses and qualities of
surface water bodies in the states.
Substantive requirements would be applicable or relevant and
appropriate to direct discharge of treated water to the Paw Paw River.
US. EPA Regulations on Test Procedures for the Analysis of (Water) Pollutants
40 CFR 136. 1-136.4
These sections require adherence to sample preservation procedures including
container materials and sample holding times.
Substantive requirements would be applicable or relevant and
appropriate to direct discharge of treated water to the Paw Paw River.
Resource Conservation and Recovery Act (RCRA) (42 USC 6901)
40 CFR Part 261
Identifies those wastes subject to regulation as hazardous wastes.
Relevant and appropriate. Waste generated as residuals from any
treatment processes may require management under these rules.
Table 10-9-
-------
Federal Regulations
Transportation of Hazardous Waste
(40 CFR Part 263)
Requirement
Requires that transporters must be licensed hazardous waste haulers. In the
event of a discharge during transportation, the transporter must take immediate
action to protect human health and the environment and cleanup the discharge
such that it no longer presents a hazard.
Comment and Analysis
These regulations would only be applicable to transportation of
hazardous waste, but may be relevant and appropriate for transportation
of certain non-hazardous wastes if these wastes present risks similar to
those associated with hazardous wastes.
Resource Conservation and Recovery Act (RCRA) (42 USC 6901) (Continued)
Land Disposal Restrictions (LDRs)
(40 CFR Part 268)
Requires any waste placed in land-disposal units to comply with LDRs by
either attaining specific performance- or technology-based standards.
Relevant and appropriate. Excavated soil may be subject to land
disposal restrictions and treatment requirements.
U.S. Department of Transportation (DOT) Regulations
40 CFR Parts 170 through 179
To Be Considered (TBCs) Standards
The Native American Grave
Protection and Repatriation Act
(NAGPRA). Public Law 101-601
(Nov. 16, 1990)
The Archeological Resources
Protection Act of 1979. Public Law
96-95
The Migratory Bird Treaty Act (16
USC 703)
Establishes requirements for off-site transportation of site-generated waste.
Law provides for protection of Native American graves, and for other related
purposes.
Provides for the protection of archeological resources on federal and Indian
lands.
Law makes it unlawful to take, kill, or possess any migratory bird, any part,
nest, or eggs of any such bird.
Applicable or relevant and appropriate for off-site transportation of
contaminated waste for treatment or disposal.
No evidence of Native American graves or artifacts or other
archeological resources at the site. However, if found, these
requirements will be considered.
No evidence of Native American graves or artifacts or other
archeological resources at the site; however, if found, these
requirements will be considered.
No evidence of any migratory bird on-site; however, if found, these
requirements will be considered.
Table 10-10-
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State Action-Specific ARARs
State Regulations
Michigan Emission Limitations and
Prohibitions - Particulate Matter
(Mich. Admin. Code R. 336.1301 -
1374)
Michigan Water Quality Standards
(Mich. Admin Code R. 323.1041 -
1117)
Michigan Effluent Standards
(Mich. Admin. Code R. 323.1201 -
1221)
Soil Erosion and Sedimentation
Control, Part 91 of the NREPA, Act
45 1 of 1994 (formerly State of
Michigan Act 347 of 1972)
Wastewater Discharge Permits
(Mich. Admin. Code R. 323.2101 -
2192)
Water Resources Protection - Part
3 1 of Act 45 1 (formerly Michigan
Water Resources Commission Act -
P.A. 245) General Rules Parts 1,4,5,
and 21.
Michigan Primary Drinking Water
Standards (Mich. Admin. Code R.
325.10601- 10609)
Michigan Groundwater Quality
Regulations (Mich. Admin. Code R.
323.2201-22113)
Michigan Surface water Quality
Standards (Mich. Admin. Code R.
323.1041- 1117)
Solid Waste Management - Part 115
of Act 45 1 (formerly State of
Michigan Solid Waste Management
Act - P.A. 641)
Requirement
Establishes emission standards for visible and particulate matter.
Establishes general use water quality standards for protecting water for aquatic
life, agricultural use, primary and secondary contact use, most industrial use,
and ensuring the aesthetic quality of the aquatic environment.
Prescribes maximum concentrations of various contaminants that may be
discharged to the waters of the state.
The purpose of this Act is to prevent uncontrolled erosion and sedimentation in
lakes, streams and rivers from earth changing activities.
Establishes permit requirements for treatment, pretreatment, and discharge
requiring NPDES permit.
These rules address discharges to both surface waters and groundwaters of the
State, developed in accordance with Part 3 1 of Act 45 1 .
Establishes health-based standards for public water systems.
Sets groundwater classification and associated water quality standards.
Sets surface water classification and associated water quality standards.
Addresses solid waste management including general landfill design
requirements as promulgated in the administrative rules of the Michigan Solid
Waste Management Regulations.
Comment and Analysis
Relevant and appropriate since soil excavation may create fugitive
emissions to air.
Relevant and appropriate to discharge of treated wetlands water to the
Paw Paw River.
Relevant and appropriate to discharge of treated wetlands water to the
Paw Paw River.
Relevant and appropriate to Paw Paw River sediment cleanup action.
Relevant and appropriate to discharge of treated wetlands water to the
Paw Paw River.
Relevant and appropriate to discharge of treated wetlands water to the
Paw Paw River.
Standards are applicable for the quality of public drinking water
supplies and relevant and appropriate for groundwater quality at the site
because it is a potential source of potable water.
Is relevant and appropriate for groundwater quality at the site because it
is a potential source of potable water.
Relevant and appropriate to discharge of treated wetlands water to the
Paw Paw River.
Relevant and appropriate because the remedial action may produce non-
hazardous solid waste which must be disposed in a Type II landfill.
Table 10-11-
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State Regulations
Transportation Standards and
Recordkeeping (Mich. Admin.
Code R. 299.9608 - 9609)
Land Disposal Restrictions (Mich.
Admin. Code R. 299.9627)
Michigan Occupation Safety and
Health Act (MIOSHA) - Act 154,
P.A. 1954 - Occupational Health
Standards of General Industry -
(Rules 1101-50071)
Michigan Occupation Safety and
Health Act (MIOSHA) - Act 154,
P.A. 1954 - Construction Safety
Standards (Part 1-30)
Michigan Public Health Code
(MPHC) - Act 368, P.A. 1978 (Part
127)
Act 127 of 1970 (The Michigan
Environmental Protection Act)
Act 347 of 1972 (The Soil Erosion
and Sedimentation Control Act)
Endangered Species Act - Act 203,
P.A. 1974 - Endangered and
Threatened Species (Mich. Admin
Code R. 299.1021 -1028)
Wetlands Protection Act 203 of
1979.
Groundwater Quality Control
(Mich. Admin. Code R. 325.1601 -
1781)
Requirement
Requirements for utilizing a manifest system to track type and quantity of
hazardous waste received by or shipped from a facility. This rule specifies the
type of records an owner or operator must maintain on site.
Requires any waste placed in land-disposal units to comply with LDRs by
either attaining specific performance- or technology-based standards.
Occupational health standard adopted to provide healthful employment or
places of employment. Standards have been developed for air contaminants,
physical agents, health hazard control measures, illumination, sanitation,
employee right-to-know, and others.
These regulations set forth safety standards for construction and construction
related activities. Standards adopted include those for excavations, trenching
and shoring, ladders, demolition, personal protective equipment, electrical, and
many others.
Regulated construction of private drinking water and monitoring wells.
Prohibits and action which pollutes, impairs, or destroys the State's natural
resources, due to any remedial action at the site. Act 245 of 1979 (The Water
Resources Act) establishes water quality standards that groundwater discharge
could threaten.
Requires a soil erosion control and sedimentation plan for any earth change.
These rules contain a listing of the fish, wildlife, and plant species that have
been determined to be endangered or threatened.
The purpose of this Act is to provide for the preservation, management
protection, and the use of wetlands by prohibiting certain activities, requiring a
permit to alter certain wetlands, and imposing fees for violations of the Act.
Establishes regulations for well construction, pump installation, and well
abandonment.
Comment and Analysis
These regulations would only be applicable to transportation of
hazardous waste but may be relevant and appropriate for transportation
of certain non-hazardous wastes if these wastes present risks similar to
those associated with hazardous wastes.
Relevant and appropriate. Excavated soil and treatment residues may be
subject to land disposal restrictions and treatment requirements.
Relevant and appropriate. Remedial action will require human labor to
implement.
Relevant and appropriate. Remedial action will require human labor to
implement.
Relevant and appropriate. Remedial action may require the installation
of additional monitoring wells.
Relevant and appropriate for groundwater remedial action at the site.
Relevant and appropriate for excavation activities.
Relevant and appropriate for remedial action.
Relevant and appropriate. Remedial action activities may threaten
wetlands.
Relevant and appropriate for groundwater cleanup action.
To Be Considered (TBQ Standards
VSR
The Verification Sampling Requirements document establishes a sampling
methodology to detemime whether a soil cleanup action has been satisfactorily
completed.
To be considered when taking soil cleanup verification samples at the
site.
Table 10-12-
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State Regulations
Michigan Compiled Laws
Annotated (MCLA) - Section
257.722
Requirement
Rules governing the reduction of maximum axle loads during the period of
March, April, and May (i.e. frost laws).
Comment and Analysis
Relevant and appropriate. Soil excavation may require heavy loads of
equipment or media to be moved on roads affected by these rules.
Table 10-13-
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Appendix 1
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Appendix 1
Site History for the Radiation Operable Unit
Aircraft Components Site
The source of the radiological contamination at the ACI site was the radium-226-painted
aircraft components that Aircraft Components, Inc. purchased in the late 1940's as
military surplus for later resale. The company stored the war surplus materials in several
Michigan area locations, including its main warehouse building complex at the ACI site.
Aircraft Components, Inc. sold these and other materials (to aircraft owners and to WWII
memorabilia collectors) from this location for several decades until the owners of the
company died in the early 1990's. The main warehouse building was then sold along with the
contents, including the surplus materials.
Later, some of the surplus materials were sold as scrap to a salvage facility in Arkansas.
During one such delivery to the Arkansas facility, a radiation alarm was tripped. The
facility notified the Arkansas Department of Health (ADH), and the ADH traced the shipment
to Michigan. The Michigan Department of Public Health, Division of Radiological Health
(now the Drinking Water and Radiological Protection Division of the Michigan Department of
Environmental Quality (MDEQ)) was informed of the incident and, upon further
investigation, determined that the origin of the radioactive material was the ACI site.
MDEQ conducted an investigation of the ACI site in late September 1994 and estimated that
hundreds of radium-painted gauges and other aircraft components were packed in wooden
crates inside the site buildings. MDEQ, using radiation detection eguipment, measured
ambient gamma radiation dose rate readings within some of the buildings at over 500 times
the naturally occurring or background level of radiation in Michigan. Following this
discovery, MDEQ reguested immediate assistance from U. S. EPA.
In October 1994, U. S. EPA and MDEQ conducted a radiological survey at the site and
confirmed MDEQ's initial findings. Site investigations have shown that the
radioluminescent paint was beginning to deteriorate into a powder, so that radioactive
particles could leak out of the aircraft gauges into the environment and/or create an
inhalation risk to anyone who handled them.
In addition, the Agency for Toxic Substances and Disease Registry (ATSDR), in response to
a reguest for consultation from U. S. EPA, recorded its observations about the site during
a site visit on May 10, 1995. Following the site visit, ATSDR issued a health advisory on
June 28, 1995. ATSDR advised that the site be addressed by U.S. EPA without delay, for
there was a concern that because each building held numerous wooden crates of materials
and a fire at the warehouse complex could result in the widespread dispersal of radiation
into the environment by a smoke plume and water run-off into the adjacent Paw Paw River.
Vandalism and theft at the site were also considered to be potential means for releasing
radiation into the environment.
As a result, U. S. EPA completed a Hazard Ranking System scoring package and nominated the
ACI site for inclusion on the National Priorities List (NPL) in Fall 1995. We placed the
site on the NPL in 1996.
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